Tribunal Criminal Tribunal for the Former Yugoslavia

Page 8278

 1                           Tuesday, 30 March 2010

 2                           [Open session]

 3                           [The accused entered court]

 4                           --- Upon commencing at 9.11 a.m.

 5             THE REGISTRAR:  Good morning, Your Honours.  This is case

 6     IT-08-91-T, the Prosecutor versus Mico Stanisic and Stojan Zupljanin.

 7             JUDGE HALL:  Thank you, Madam Registrar.

 8             Good morning to everyone.  May we have the appearances for today,

 9     please.

10             MS. KORNER:  Good morning, Your Honours.  Joanna Korner assisted

11     by Crispian Smith, Case Manager, for the Prosecution.

12             MR. ZECEVIC:  Good morning, Your Honours.  Slobodan Zecevic,

13     Slobodan Cvijetic, Eugene O'Sullivan, appearing for Stanisic Defence this

14     morning.  Thank you.

15             MR. PANTELIC: Good morning, Your Honours.  For Zupljanin Defence

16     this morning appearing Igor Pantelic, Dragan Krgovic, and Miroslav

17     Cuskic.   Thank you.

18             JUDGE HALL:  Thank you.

19             Yes, Ms. Korner.

20             MS. KORNER:  Your Honour, before the witness comes in, I raised

21     on Friday a query or asked for clarification of the ruling made on the

22     24th of March in respect to our application to add I think it was three

23     documents to the 65 ter list which was refused by Your Honour's ruling.

24     And the reasons given for the ruling state that notwithstanding the

25     Prosecution's contention that the Defence would not be prejudiced by the

Page 8279

 1     inclusion of the proposed document, it is is not established to the

 2     satisfaction by the Trial Chamber that there is good cause for its

 3     request or that the proposed documents are of sufficient importance to

 4     justify their late inclusion.

 5             And my request for clarification was whether the denial of our

 6     application was on the basis that the documents were not relevant or on

 7     the basis that the Prosecution had made it too late and, therefore,

 8     effectively, if I can put it that way, was to be punished for not making

 9     the application earlier.

10             So, Your Honours.  May I ask for clarification.

11             JUDGE HALL:  With respect, Ms. Korner, the Chamber is of the view

12     that nothing further need be said.  The Chamber gave its ruling and no

13     clarification is, in the Chamber's view, necessary.  So the Chamber has

14     nothing to add.

15                           [Trial Chamber confers]

16                           [Trial Chamber and Legal Officer confer]

17                           [The witness entered court]

18             JUDGE HARHOFF:  Good morning to you, sir.

19             THE WITNESS: [Interpretation] Good morning.

20             JUDGE HARHOFF:  Would you be kind enough to read the solemn

21     declaration.

22             THE WITNESS: [Interpretation] I solemnly declare that I will

23     speak the truth, the whole truth, and nothing but the truth.

24             JUDGE HARHOFF:  Thank you, sir.  You may sit down.

25             And welcome to the Tribunal, and thank you for coming to give

Page 8280

 1     your testimony today.

 2             THE WITNESS: [Interpretation] Thank you very much for making it

 3     possible for me and for acknowledging my reasons to testify now.

 4             JUDGE HARHOFF:  Very well.  And I take it that can you hear me in

 5     a voice -- in a language that you understand?

 6             THE WITNESS: [Interpretation] I do.

 7             JUDGE HARHOFF:  Very well.

 8             Let's start by asking you to give us your name and your date and

 9     place of birth, if you would be so kind.

10             THE WITNESS: [Interpretation] My name is Slobodan Skipina.  I was

11     born on the 24th November, 1944, in Brojnici, municipality of Pale.

12             JUDGE HARHOFF:  Thank you, sir.  And what is your -- what is your

13     current occupation?

14             THE WITNESS: [Interpretation] I'm retired.  Otherwise, I have a

15     degree in economics.

16             JUDGE HARHOFF:  Thank you very much.

17             And what was your occupation in 1992?

18             THE WITNESS: [Interpretation] In 1992, I was re-called from

19     retirement, in which I had been since 1990, and I worked in the National

20     Security Service of the Serbian Republic of Bosnia and Herzegovina, as

21     leader of the service.

22             JUDGE HARHOFF:  And where was that?

23             THE WITNESS: [Interpretation] It was at Pale.

24             JUDGE HARHOFF:  Thank you very much.

25             What is your ethnicity?

Page 8281

 1             THE WITNESS: [Interpretation] Serb.

 2             JUDGE HARHOFF:  Thank you very much.

 3             Sir, have you ever testified before this Tribunal, earlier on?

 4             THE WITNESS: [Interpretation] No.  Not before this Tribunal or

 5     any other.

 6             JUDGE HARHOFF:  And so I understand that you have not been asked

 7     to testify before any other Tribunal in your home country; is that

 8     correct?

 9             THE WITNESS: [Interpretation] Yes, that's correct.

10             JUDGE HARHOFF:  Very well.

11             Let me then explain to you, then, the proceedings, as we have it

12     here.  You have been called to testify by the Prosecution, who is sitting

13     to your right, and I assume that you have already met with the

14     Prosecution.

15             The Prosecution has asked for four hours to go through your

16     testimony in-chief.  And the Defence has then, after that, asked for four

17     hours by the Defence for Mico Stanisic, and one and a half hours for the

18     Defence of Stojan Zupljanin.  And the Defence is sitting to your left.

19             After completion of your testimony in-chief and

20     cross-examination, the Judges may have some questions for you.  And then

21     the Prosecution will be given an extra chance to have some questions for

22     you in re-direct examination.

23             So that is the course of the events.  So, in short, four hours

24     for the Prosecution; four hours for the Defence of Stanisic; and one and

25     a half hours for Mr. Zupljanin, which will bring us well through the day

Page 8282

 1     of today and probably also the day of tomorrow, and so your testimony is

 2     going to last at least a couple of days.

 3             The system here is that we have to have a break every 90 minutes,

 4     because the tapes need to be changed, and so every 90 minutes we will

 5     have a 20-minutes' break.  And the proceedings this morning will be

 6     completed at a quarter to 2.00.  Then we adjourn for today and we resume

 7     again tomorrow.

 8             If at any point you feel that you're tired or exhausted or you

 9     want to put a question to the Judges, then feel free to do so.

10             And then, finally, I shall remind you that you are obliged to

11     speak the truth, the whole truth, and nothing but the truth, and I should

12     also remind you that is there a severe plenty for providing false

13     testimony to the Court.

14             Is this clear?  Thank you very much.

15             In that case, I will pass the floor on to Ms. Korner for the

16     Prosecution.

17             MS. KORNER:  Before I begin, two problems:  Judge Harhoff turned

18     into Judge Hall at the end of page 3.  And in addition to that, we don't

19     have LiveNote.  It's gone.

20             JUDGE HARHOFF:  Sir, while we're waiting for the system to come

21     up, there is another little issue that I would just wish to mention to

22     you.  As can you see on the screen in front of you, everything you say is

23     being recorded by the stenographer, who is sitting over here, and -- and

24     I would advise you to keep an eye on the cursor on the screen, in order

25     to avoid overlap between the questions and the answers.  The difficulty

Page 8283

 1     is that if you speak too fast or if you overlap, the interpreters will be

 2     unable to catch what either of you are saying and so there is going to be

 3     a lacunae in the transcript.

 4             So please just speak slowly and speak clearly and do not overlap.

 5             Ms. Korner.

 6                           WITNESS:  SLOBODAN SKIPINA

 7                           [Witness answered through interpreter]

 8                           Examination by Ms. Korner:

 9        Q.   Mr. Skipina, can I just add, as you were told yesterday, please

10     only answer the question that you're asked.  If any more details are

11     required, then you will be asked for further details.

12             Do you understand that?  I'm afraid you have to say yes or no.

13        A.   Yes.

14        Q.   Mr. Skipina, I want to deal, first of all, with how you came to

15     give evidence.  I think it's right that you were interviewed by the

16     Office of the Prosecutor over two days on the 4th and 5th of November,

17     2004; is that right?

18        A.   Yes.

19        Q.   And you were interviewed as a suspect.  That is, you had the

20     right to have a lawyer present, and you did have a lawyer present.

21        A.   Correct.

22        Q.   Mr. Branko Lukic?

23        A.   That's correct.

24        Q.   Before you were interviewed, had you, in fact, been contacted by

25     Vlastimir Kusmuk, and Goran Radovic?

Page 8284

 1        A.   Yes.

 2        Q.   And also Dragan Kijac, who replaced you as head of the SNB in

 3     1992?

 4        A.   Yes, sometime after Radovic and Kusmuk.

 5        Q.   Did you discuss with any of these three gentlemen the matters

 6     about which you were to be interviewed?

 7        A.   No.

 8        Q.   Did they contact you about the fact that you were to be

 9     interviewed?

10        A.   Yes.  But I'd like to explain, if you allow me.

11        Q.   If you would do that very shortly, please, because we have a lot

12     of matters to get through.  But if you think it's relevant, then,

13     shortly, please, tell us.

14        A.   I got a telephone call from Vlastimir Kusmuk who told me that he

15     had been interviewed by the Office of the Prosecutor and that someone

16     from the Office of the Prosecutor told him that they should also

17     interview a friend of his, a good friend of his, and since the two of us

18     were close, he called me up and said, I suppose it's you.

19             I told him if they ask, give them my telephone number so they can

20     contact me, and that is how I was contacted by the Prosecution.

21        Q.   All right.  And, finally, before you came here on Sunday, when

22     you agreed you would speak to the Defence, had you been contacted by

23     Milan Scekic?

24        A.   Yes.

25        Q.   And did he tell you that he had given evidence?

Page 8285

 1        A.   Yes.

 2        Q.   Did you discuss what he had said in evidence with him?

 3        A.   No.

 4        Q.   But as a result of speaking to him, you having deadlined to speak

 5     to the Defence, did you then agree?

 6             MR. KRGOVIC:  That's leading.

 7             MS. KORNER:

 8        Q.   Mr. Skipina.

 9        A.   I apologise, could you please repeat the question.

10        Q.   Did you originally agree to meet the Defence?

11        A.   No.  Because I didn't know the procedure.  Namely, that as an OTP

12     witness, I had a right to also meet with the Defence.

13        Q.   And what was it about your conversation with Mr. Scekic that made

14     you change your mind?

15        A.   Scekic described to me briefly his stay at the ICTY, said that he

16     was pleased.  We did not discuss the substance of his evidence, and in

17     that conversation, he told me that he had been proofed, both by the OTP

18     and the Defence.

19        Q.   And?

20        A.   I asked him, What do you mean with the Defence?  And he said,

21     Yes, one can also contact Defence before reading out the solemn

22     declaration.

23             When they called me from the OTP to postpone my testimony, I then

24     told them that I would like to also contact the Defence.

25        Q.   All right.  As a result of your meeting with the Defence on

Page 8286

 1     Sunday, did you make any decision to change any part of what you said in

 2     your interview?

 3        A.   I didn't make a decision to change.  Everything mostly remained

 4     as I had stated it in my interview.  It's just that I may have a dilemma

 5     about the question that you put to me about the membership of

 6     Mr. Stanisic in the Serbian Democratic Party.

 7        Q.   Yes, we'll come on to that in a moment.  But does your dilemma

 8     arise from any decisions with the Defence?

 9        A.   Which dilemma do you have in mind?

10        Q.   The one you've just mentioned.

11        A.   Well, I have accepted, given that the procedure allows for me to

12     meet with the Defence too.

13        Q.   Yes.  You told us, I asked you whether as a result of your

14     meeting with the Defence you had made a decision to change any part of

15     what you said in your interview.  And your response was:  "I didn't make

16     a decision to change.  Everything mostly remained as I had stated it in

17     my interview.  It's just that I may have a dilemma about the question

18     that you put to me about the membership of Mr. Stanisic in the Serbian

19     Democratic Party."

20             And now I'm asking you what your dilemma is.

21        A.   We will clarify that, as you have said, later.

22             As for the rest, I stand by the statement that I gave to the OTP

23     in 2004 with a proviso that that interview with me was never completed,

24     that I had some additional relevant matters to say, and we left it off

25     where the OTP said that they would call me again but they never did, and

Page 8287

 1     we never met up again.  So that's my first interview with the OTP was

 2     actually never completed.

 3        Q.   Yes.  Even though it lasted two days.

 4        A.   Yes.  Two long days, nine hours each.

 5        Q.   All right.  Let's move, then, to your actual career as a police

 6     officer.

 7             Now, sir, I don't want the full details of your career.  I'm just

 8     going summarise, I hope, accurately, your career with the police.

 9             I think you joined the police with the then-SDB, as it was

10     called, in 1968 in Doboj.  Is that right?

11        A.   That's correct.

12        Q.   You, in fact, took an economics degree in 1974, and then you went

13     back -- well, you remained in the police and you became an inspector

14     under the old BiH MUP still with the SDB in charge of investigating

15     Serbian nationalism; is that right?

16        A.   Yes.  You skipped some details though.

17        Q.   Yes, I know.  I -- I'm sure that if they become relevant the

18     Defence will ask you about them.

19             Did you then, in 1980, become head of the department for internal

20     problems in -- I think that was in Sarajevo?

21        A.   Yes.  Within the SDB in Sarajevo.

22        Q.   You then, I think, became head of the SDB then head of the CSB in

23     Sarajevo and then in 1990, did you retire as an assistant under-secretary

24     of the state security -- I'm sorry, 1991.  No, 1990, sorry, all right.

25        A.   I can give you the exact date.

Page 8288

 1        Q.   Yes, the exact date of your retirement.  Yes, why don't you tell

 2     us that.

 3        A.   I first served as deputy chief of the SDB centre in Sarajevo and

 4     then chief of the SDB centre in Sarajevo, and then after the

 5     reorganisation which took place in the Ministry of th e Interior, in

 6     1986, I became chief of centre for security services both public and

 7     state security.  I remained there the full term, and then in the spring

 8     of 1990, I was appointed assistant under-secretary for the State Security

 9     Service of Bosnia-Herzegovina.  And then in late 1990, on the 31st of

10     December, I retired.

11        Q.   Thank you.  And then as you told the Judges, were you brought

12     back after the split of the MUP in Bosnia and Herzegovina, at the

13     beginning of April 1992?

14        A.   That's correct.

15        Q.   And who was it who brought you back into the MUP?

16        A.   Mr. Mico Stanisic offered me to come back.  It's not that he

17     brought me back.  He offered me to come back.

18        Q.   And when was that?  How many days before your appointment?

19        A.   Approximately ten days before I was appointed to the position

20     that I was to discharge.  Around the 20th of March.

21        Q.   And why was it that you agreed to return to the MUP, even though

22     you had only just retired, effectively?

23        A.   My reasons for retiring at the age of 45 were of a personal

24     nature.  If you wish to learn about it, I can tell.

25        Q.   No, I don't want to know the reason why you retired.  I want to

Page 8289

 1     know the reason why you returned to the new MUP.

 2        A.   Throughout my retirement, I was constantly attacked by the

 3     Bosniak side due to cases that I had worked on previously in my work,

 4     especially the case of Alija Izetbegovic, which was solely my case.

 5             So for that reason, and also other reasons, I retired.  I was

 6     given death threats.  Same goes for the members of my family.  In late

 7     1991, at night, I would illegally go and hide with my family and friends,

 8     spend a night there, because there was a campaign in place against me,

 9     especially on the part of the MUP.  Hilmo Selimovic, he was assistant

10     minister for personnel whom I had investigated due to white-collar crime

11     and then he decided to take revenge and so on.

12        Q.   All right.  Can I stop you there.  I simply want to know in one

13     sentence why you agreed to join the new Serbian MUP.

14        A.   I accepted it, because I thought that that could possibly protect

15     me.  I thought that if I worked at the MUP I would have personal

16     protection.  And in addition to that, Minister Stanisic told me that he

17     wanted me to come, due to my great experience in working in the police.

18     He said that he needed men like me.

19        Q.   All right.  Let's deal with Minister Stanisic.

20             How long had you known Mico Stanisic?

21        A.   Before meeting him on the 20th of March, I had met Mr. Stanisic

22     only twice in my life.  The first time was when he was, I think, an

23     executive within a company called Upi; and the second time when he was

24     appointed secretary of the city SUP in 1991.

25             An inspector who worked with me, the late Jozo Leutar, was

Page 8290

 1     appointed deputy of Stanisic.  He was deputy secretary of the city SUP,

 2     and we met in front of the building of the city SUP where I lived nearby.

 3     I congratulated him, he asked me to go and have coffee with him, we had

 4     coffee together, Jozo Leutar and I, and he told me, Do you know Mico?  I

 5     told him, I met him once.  He said, Let's go over to see him to

 6     congratulate him, so we went over to Stanisic, I congratulated him.  We

 7     didn't talk much.  We said good-bye, and I left the city SUP.  That was

 8     the only time that I had ever visited any MUP facility after retiring.

 9        Q.   Right.  Anyhow having agreed to re-join the MUP, to what position

10     were you appointed?

11        A.   Minister Stanisic talked to me.  I think that the course of that

12     conversation is relevant, so I should tell you about it.

13        Q.   All right.

14        A.   He called me on the telephone at around the 20th of March, asking

15     me to meet at the Holiday Inn hotel.  I accepted that invitation.  I came

16     to the hotel.  He was sitting there with his wife.  Later on, he

17     introduced her to me and said that that was his wife.

18             So we sat there and talked a bit and then at one point he told me

19     that the Assembly of the Serbian people in Bosnia and Herzegovina had

20     adopted a decision to split from the joint Assembly and that that was in

21     accordance with the Cutileiro Plan about the cantonisation of

22     Bosnia-Herzegovina, which is something that I knew of from the media.

23        Q.   He actually told you that, did he, that this was to do with the

24     Cutileiro Plan?

25        A.   Yes.  He told me that, that Cutileiro Plan envisaged the

Page 8291

 1     cantonisation of Bosnia-Herzegovina, and I knew that myself from the

 2     media.

 3        Q.   And?

 4        A.   I asked him then, given the terrible heated atmosphere,

 5     especially in the city where I lived, in Sarajevo, I asked him, Mico,

 6     what is your assessment?  Is there going to be a war in Bosnia and

 7     Herzegovina?  He told me that that was out of the question, that the

 8     politicians had come to their senses, and that it was just rhetorical

 9     that they were heating up the situation so that the people would accept

10     the division easier.

11             Then he told me that they, the Bosniak, Serbian, and Croatian

12     side, had agreed on the separation of property within the MUP and that

13     the school centre in Vrace, according to that agreement, was going to

14     belong to the Serbian MUP where they were going to have their

15     headquarters; whereas, the republican SUP, city SUP, and the CSB centre,

16     were going to be divided between the Bosniaks, Muslims, and Croats.

17        Q.   Right.  In any event, can I ask you what position - which is my

18     original question - what position was he offering you in the new MUP?

19        A.   Then further on, during that conversation, he asked me whether,

20     given my police experience, I would be ready to assist in establishing

21     the National Security Service.

22             I asked him, How come, Mico, when you know that I don't have good

23     reputation in the Serbian political circles.  He said to me, Just leave

24     that to me.  You were proposed by the operations service that you headed

25     before your retirement.  We did not really discuss the position that I

Page 8292

 1     was going to have.  That came later.

 2        Q.   All right.

 3        A.   I agreed, in principle.  I said that within my abilities I was

 4     ready to assist.

 5        Q.   So that was the meeting at the Holiday Inn.

 6             Did you meet him again before your appointment?

 7        A.   I didn't.  No, actually, I did.  At around the 27th of March.  He

 8     called me on the telephone again and he said that he would send a car to

 9     fetch me, to bring me to Pale, to a small administrative building which

10     was a hotel of the scout organisation or something like that, to join the

11     team working on the rules of internal organisation and job classification

12     within the MUP.  I accepted that.  I went up there at around the 27th of

13     March.  I found a team working there with a lawyer called Nenad Radovic,

14     Slavica Krstovic and another lawyer whose name I don't know.  I think

15     that he had started working in the meantime in 1991, I'm not sure.  And

16     as for the state security, Sukalo, Ranko, my former colleague, also a

17     lawyer was there.   They had already started working on the rules for the

18     public security, the rules of the Ministry of Interior, whereas Ranko

19     Sukalo, and I started drafting the rules for the national Security

20     Service.

21        Q.   By that stage, had Mico Stanisic explained how he had the power

22     to ask you to re-join the MUP or what his position was going to be?

23        A.   I apologise, I omitted to say that when we talked at the

24     Holiday Inn at around the 20th of March, he told me that he was supposed

25     to become the minister of the interior of Republika Srpska.

Page 8293

 1        Q.   Did you ask him how it was that he was going become the minister,

 2     given that there were other people, such as Momcilo Mandic, who held

 3     higher positions in the old MUP?

 4        A.   I didn't ask him.

 5        Q.   Well --

 6        A.   It wasn't up to me.  Didn't concern me.

 7        Q.   Well, weren't you -- can I put it this way:  Did it come as a

 8     surprise to you that he was going to be the minister?

 9        A.   What should I tell you?  What do you mean surprise me?  I

10     accepted the fact he that was going to become minister.  I knew that he

11     used to work at the Ministry of the Interior earlier, so there was really

12     nothing to surprise me or not surprise me.  I simple accepted the fact as

13     it was.

14        Q.   Did you know anything at that stage about his political

15     affiliations?

16        A.   No.

17        Q.   All right.  Later did you discover from anything that he said

18     what his political allegiance was?

19        A.   As for political allegiance, given the heated atmosphere, the

20     Serbs were supporting SDS, the Muslims SDA, and the Croats the HDZ.  This

21     is whom people favoured, 90 per cent of them.

22        Q.   Let's move further than political allegiance.  Did you understand

23     that he was ever a member of any political party?

24        A.   I never knew about that, nor did he ever utter in front of me

25     that he was a member of the party, nor did I hear from anybody else that

Page 8294

 1     he was a member of the party, nor did I see any document proving that he

 2     was a member of the party.

 3        Q.   All right.  You may not have seen a document, you may not have

 4     heard it from anybody else, did you believe him to be a member of a

 5     political party?

 6        A.   I was of the belief that all people holding top positions in the

 7     government, all ministers, members of the Presidency, were members of the

 8     party.  It was only later on that I learned that Mr. Dzeric was not a

 9     member of any party that, that deputy president of the Republic,

10     Professor Nikola Koljevic was also not a member of any party.

11             In the beginning, however, I truly believed that everybody who is

12     appointed to any top position was a member of the party.

13        Q.   All right, now, let's move on.   Was there a discussion with Mico

14     Stanisic when others were present about the SDS membership?

15        A.   Yes.  Sometime in the beginning perhaps around the 15th of April,

16     roughly, I can't remember exactly.  There were two or three of us sitting

17     together.  I think that Kusmuk was one of them and another person whom I

18     can't remember now, Mr. Stanisic, as we sat there informally, it was not

19     a formal meeting or anything of the sort, just three of four of us

20     meeting, and Mr. Stanisic said something like this, I think that all

21     officials in leading positions, member of the collegium need to be

22     members of the party.  I told him that I did not want to become one nor

23     that the operations officers who were working for the SNB would.  And

24     that was the only discussion that I ever had with Mr. Stanisic concerning

25     that.  He did not reply anything to what I said.  He did not insist.  All

Page 8295

 1     I know is that none of the members of the collegium, as far as I know,

 2     were members of the Serbian Democratic Party.

 3        Q.   All right.  So when you said members of -- Mr. Stanisic said

 4     something like, I think that all officials in leading positions, members

 5     of the collegium need to be members of the party, which party did you

 6     mean?

 7        A.   Well, I suppose he did not mean the league of Communists.  He

 8     meant the Serbian Democratic Party.

 9        Q.   Can we then return, please, to your appointment.  Were you

10     actually formally appointed to the position by Mr. Stanisic on the 1st of

11     April?

12        A.   Well, the letter of appointment says I was appointed acting

13     under-secretary of the National Security Service as of the 1st of April,

14     although the actual appointment was only on the 5th of April.  But the

15     letter of appointment said as of 1st April.

16             Let me add this:  I was resisting this decision.  I didn't want

17     to become that.  I was suggesting Sredoje Novic to become under-secretary

18     because he had been the last in that position at the level of the former

19     Bosnia and Herzegovina, and he was supposed to become secretary of the

20     federal National Security Service, but he eventually didn't.  Then I was

21     told Sredoje Novic cannot occupy that position because Mr. Krajisnik

22     won't let him.

23        Q.   Did you understand that the political leadership outside of

24     Mr. Stanisic, therefore, had some say in who was appointed?

25        A.   Excuse me, which position do you mean?

Page 8296

 1        Q.   You told us that you would have preferred that Sredoje Novic

 2     would become the under-secretary, but you were told that that couldn't

 3     happen because Mr. Krajisnik wouldn't let him.

 4             So I'm asking you whether, from that, you understood that the

 5     political leadership, that is to say, Krajisnik, Karadzic, Plavsic,

 6     whoever, had some say in the appointments within the MUP?

 7        A.   I suppose that Mr. Stanisic, if he wanted to form a team, and I

 8     think he was trying to form a team from people in the field, he was

 9     trying to form a team of professionals.  However, that didn't necessarily

10     mean that he was going to be allowed to do that.  There was certain

11     resistances, like in the case of Mr. Sredoje Novic.

12        Q.   That's what I'm asking you.  Was your understanding from this

13     conversation that Mr. Stanisic had to consult with Krajisnik, as leader

14     of the Assembly; Karadzic as President; Plavsic as a member of the

15     Presidency with political leaders?

16        A.   I don't know if he had to consult them, or perhaps he mentions

17     Sredoje Novic in conversation, and Sredoje Novic was the focus of certain

18     problems even before the war.  I don't know whether he actually had

19     consultations or not, sir.  I'm not aware of that.

20        Q.   I'd like you now to have a look, please, you explained in

21     interview at length the various people and the structure of the SNB but

22     it has been reduced to a diagram which you had a look at yesterday and I

23     think you say is correct, so I would like you to look at it, please.

24             MS. KORNER:  Obviously it's a brand new diagram, Your Honour, so

25     oit has been given a number 10326 [Real-time translation read in error

Page 8297

 1     "10329"].  It's a bit like the diagram we did for the CSB Banja Luka.

 2     And some of the names, Your Honours, appear, as you will see, on the

 3     bigger chart of the RS MUP.

 4             MR. PANTELIC: I do apologise.  Did you mention, Ms. Korner, 1 --

 5             MS. KORNER:  10 something or other, 10326.

 6             MR. PANTELIC: Because in the transcript it's page 19, line 19

 7     it's 10329, so I just want to clarify.  Yeah, thank you.

 8             MS. KORNER:  All right.

 9        Q.   This is a sort of basic guide, if one can put it that way, to the

10     structure of the SNB between April and July when you resigned.

11             We see yourself as chief of the SNB or under-secretary, and then

12     under you, Mr. Radovic, as the assistant chief, and for a short period of

13     time, as we can see, which is why it is in slightly difficult writing to

14     read, you have a deputy chief assistant under-secretary Dragan Devedlaka,

15     and Nedo Vlaski.  Is that right?

16        A.   Right.

17        Q.   Both of whom went off to Belgrade with some speed.   Is that also

18     right?

19        A.   That's right.  Especially Nedo Vlaski.  He occupied his position

20     only one day.

21        Q.   Then do we see under that, the -- the six different departments

22     within the SNB?

23        A.   Yes.

24        Q.   The administration for intelligence headed by Dragisa Mihic?

25        A.   The only one.

Page 8298

 1        Q.   Yeah.  Then administration for affairs and -- really foreign

 2     intelligence services.  Again, was this Mr. Blagojevic for a short period

 3     of time?

 4        A.   Yes.

 5        Q.   And was he ever replaced while you were still head?

 6        A.   No, because he was the only one in the administration.

 7        Q.   Right.  But if he left apparently also in April so he wasn't

 8     there for very long, why was no one else appointed once you were head?

 9        A.   We did not have enough operatives.

10        Q.   All right.

11        A.   We started from scratch.  Whatever resources we had, we used to

12     fill at least fictionally vacancies in the administration.  But some

13     administrations had no personnel.

14        Q.   Then we see the security section, headed by Milan Skekic.

15     Defence preparations, Todar Cicovic.  I'm not sure about the

16     pronunciation there.  Then administration for analytical information,

17     Ljiljana Trisic, and finally legal department personnel, Mr. Sukalo.

18             Is that right?

19        A.   That's right.  These people were appointed to these positions

20     although within their structures, these administrations had actually no

21     personnel.  So these people were one-man shows.  There were the chiefs

22     and their staff.  But I have to say about this administration for Defence

23     preparations led by Todor Cicovic, that's an administration that exists

24     only in peacetime, and his job was to train reserve staff for

25     contingencies such as natural disasters and war in which they would be

Page 8299

 1     activated.  Since war broke out this administration no longer had any

 2     reason to exist.

 3        Q.   But Mr. Cicovic was still there, was he?

 4        A.   Yes, yes, he continued doing other jobs.

 5        Q.   Where was the SNB at the RS MUP based?

 6        A.   It was based in that building that I mentioned before where the

 7     rules on the activities of the MUP were being developed.

 8             We had a conference room that was available to other personnel

 9     and even third parties, such as political parties without any special

10     bars or supervision.  Plus there was one office where Lila Trisic [phoen]

11     worked as an analyst with a typist next to her.  So we really had no

12     proper premises.

13        Q.   Right.  Sorry, I meant geographically, where was the building?

14        A.   Overlooking Pale, there is an feature called Kalovita Brda about

15     a kilometre from the centre of Pale.

16        Q.   Right.  Is that on Mount Jahorina?

17        A.   Oh, no.  It's at Pale, the first hill next to Pale.  One

18     kilometre from the centre of Pale.

19        Q.   All right.  So your department was based there.  What about the

20     rest of the MUP?  Where was that?  In April of 1992, to begin with.

21        A.   Minister Stanisic came by occasionally.  It wasn't exactly an

22     office that he used.  It was more like a room where he sometimes spent

23     the night, and there were another two rooms for his body-guards.  Also,

24     for a while, the assistant minister for finance, Bogdan Kosarac would

25     come sometimes and use the office because the government was close by and

Page 8300

 1     it was convenient for him to communicate with the government from there.

 2     Other executives would come and go.  Most of them were based in Vrace,

 3     where the deputy minister Momcilo Mandic was based permanently along with

 4     Cedo Kljajic, chief of public security; Milenko Karisik, commander of the

 5     special police, and I know also the assistant minister for general crime,

 6     Dobro Planojevic was also there.  But, in fact, it was all pending the

 7     decision, the final decision to establish a seat at Vrace, because the

 8     security situation was very bad.  The enemy was targeting us constantly

 9     with snipers and mortar fire until the MUP moved finally to Vrace.

10        Q.   The enemy was targeting you where?  In Pale or in Vrace?

11        A.   At Vrace.  The seat of the MUP and its supporting services was

12     supposed to be at Vrace.

13        Q.   Right.  Now I want to deal at this stage with the -- what part

14     you played after the takeover of the school at Vrace in April, 6th of

15     April.

16             Were you given any particular task by Mico Stanisic?

17        A.   Yes.  After the clash at Vrace, when the special police led by

18     Milenko Karisik, separated from the joint special police of the former

19     MUP, and when they moved to Vrace, to a destination designated earlier,

20     they were met by fire from the school building, and it was the teachers

21     and cadets in the police school who were firing.  These were young men

22     who had done their compulsory military service and applied, after that,

23     for a six-month course to become policemen.  They met the special police

24     unit with fire.  And on that occasion, two special policemen were killed,

25     another five or six were wounded but still the special police managed to

Page 8301

 1     get into the building at Vrace, and some of the instructors and students

 2     from this course were arrested.

 3             After that, Minister Stanisic ordered that they should be

 4     interviewed, and since we didn't have enough operative officers, we

 5     decided to use combined teams consisting of both national security

 6     personnel and the police from the CID.  After that, I reported to the

 7     minister that there were no elements of criminal responsibility in any of

 8     the individual cases, and he then said, Slobodan, contact the Bosniak MUP

 9     and have these people exchanged, because - and I already knew this from

10     reports by citizens - some Serbs had been arrested, so go and contact the

11     Bosniak MUP and organise an exchange.

12             I told the minister there is no chance I'll be able to do that.

13     I don't have the resources.  I don't have the men or the vehicles or

14     anything else.  So then he called Radomir Kojic on the telephone.

15     Radomir Kojic came in from Pale.  We talked, and he told this man, From

16     now on, obey Slobo Skipina and do whatever he tells you to do, and he

17     told me, Now contact the Bosniak member, which did I.  I called Avdo

18     Hebib, assistant minister for the police, and I believed that some of his

19     family members were among those arrested.  He directed them to Simo

20     Grubisic, a man on their staff as a man who was in charge of exchange,

21     and then the two of us exchanged lists and conducted three or four

22     exchanges on the separation line between the municipalities of Stari Grad

23     and Pale.

24        Q.   All right.  Thank you very much for that lengthy explanation,

25     sir.  But in future, can we just have it slightly shorter.

Page 8302

 1             First, how many people were being held and integrated at the

 2     school, roughly?

 3        A.   I can't remember exactly.

 4        Q.   [Previous translation continues] ... are we talking 100 or more,

 5     or less?

 6        A.   Well, we certainly didn't have 50 operatives to interview these

 7     people, let alone 100, so that was less than 50 certainly.

 8        Q.   I'm not talking about your operatives, but how many people had

 9     been, as you put it, arrested after Mr. Karisik had taken over the

10     school?

11        A.   I don't know how many people were arrested there.  I'm trying to

12     tell you that we didn't have more than 50 operatives in total to

13     interview them.  So there were less than 50 men invited to be

14     interviewed.

15        Q.   [Previous translation continues] ... logic in the two because

16     surely an operative could conduct one interview on one day and a second

17     interview with somebody different on another day.

18             So why do you equate the two?

19        A.   Well, we conducted all the interviews within a day or two.

20        Q.   During the course of any of these interviews, were any of these

21     prisoners assaulted?

22        A.   Not that I know of.  I don't know of any assaults.  What kind of

23     assaults do you mean?

24        Q.   Beatings.

25        A.   I don't know.  I wasn't there at Vrace, so I don't know whether

Page 8303

 1     anything of the sort happened.

 2        Q.   [Previous translation continues] ... but you dealt with the

 3     exchange personally, didn't you?

 4        A.   Yes.

 5        Q.   Did you see any signs of injury to any of the people that you

 6     were exchanging?

 7        A.   I did not personally take these people to be exchanged.  Radomir

 8     Kojic did that. I only harmonised lists and agreed with Simo Grubisic was

 9     exchanges would be taking place.  I did not see any of the men with my

10     own eyes.

11        Q.   And one final question: Your operatives who conducted the

12     interviews found that there were no grounds for detaining these people.

13     Why weren't they released without having to be exchanged for Serbs?

14        A.   I'm trying to tell you that, in the meantime a large number of

15     Serbs had been arrested in Sarajevo, and they were not going to be

16     released without an exchange.  So this exchange was organised to have all

17     of them freed, and that was done very efficiently.  The first exchange

18     took place within three or four days with great efforts invested by both

19     sides.

20        Q.   I understand you say that the Serbs were not going to be released

21     without an exchange, but this question of an exchange -- or this

22     suggestion, I'm sorry, came from Mico Stanisic, you've told us.

23        A.   Yes.  He told me, Contact the Bosniak MUP and have these people

24     exchanged because, in the meantime, a number of Serbs had been arrested

25     in Sarajevo.

Page 8304

 1        Q.   Yes.  How did he or, indeed, you know whether there were any

 2     grounds for the arrest of the Serbs?

 3        A.   At Pale, at least ten Serbs had come to my office with reports

 4     that they had received telephone calls from their families in Sarajevo

 5     who had said that the male members of their family had been taken away

 6     without any explanation.  At first I was supposed to exchange only those

 7     who had been arrested by the police, but then, hearing these reports, I

 8     included those people too.

 9        Q.   I'm so sorry.  I don't think I quite follow that.

10             You had arrested people -- or police had arrested people, had

11     they, outside of those who were in the Vrace school?

12        A.   No.  I'm saying that citizens from Pale came to me and begged me

13     to put on the exchange lists their relatives from Sarajevo, that the

14     Bosniak police had rounded up from their apartments and took them nobody

15     knew where.  So I did that.

16        Q.   Final two questions on this topic and then I think it is probably

17     time for a break.

18             The people at the school who you had interviewed and decided to

19     use to the exchange, were they all non-Serbs?

20        A.   Frankly, I didn't pay attention.

21        Q.   Are you saying that your operatives didn't -- well, you had a

22     list of the names because you discussed that with your opposite number,

23     Mr. Hebib.  Were they all non-Serbs?

24        A.   I suppose that they were most of them non-Serbs, but I cannot

25     rule out the possibility that there were a few Serbs among them.  But in

Page 8305

 1     any case, they wouldn't ask for Serbs in exchange.

 2        Q.   Right.  And finally this:  This sort of feature of exchanging

 3     prisoners against whom there were no grounds for detaining them, was that

 4     something that happened quite often than you dealt with?

 5        A.   I don't know whether it happened often.  I didn't deal with that

 6     sort of thing a lot because I left that job very soon afterwards.  I

 7     refused to do any more of that for reasons that I can share with you, if

 8     you insist.

 9        Q.   Yes, all right.  After the break I'm going to ask you about how

10     you came to stop dealing with exchanges.

11             Did you deal with -- after the school exchange and before you

12     stopped, did you deal with other exchanges of prisoners?

13        A.   There were more prisoners, such as one group of five or six from

14     Ilidza.  I got a report that some of them had killed a number of Serbs

15     with sniper fire and they had reports about it.  I asked to receive these

16     reports, which I never did, so I had these people exchanged.

17             Then we also had one case where the police arrested a certain

18     Senahid Memic at Vrace.  He was member of the SDA, an official of the SDA

19     carrying false IDs.   He had six or seven false IDs in Serbian names.  He

20     had membership card of the SDS.  He had had laissez-passer to SDS

21     offices, and a number of other badges all in Serbian names.

22             I, or, rather, the National Security Service took over that case,

23     and he confessed that he was the chief organiser of the arming of Muslims

24     before the war, that he acquired weapons in Croatia, transported it

25     across Mount Igman, via Samac and Gracac along roads where there would be

Page 8306

 1     no patrols.  Let me finish, please.

 2        Q.   No.  We really don't need all the details of what this man did.

 3     What did you do with him?

 4        A.   We recorded the interview with him, and we invited a report from

 5     the SRNA agency to record our interview with him and broadcast it on TV.

 6     And then after that programme, Bakir Alispahic, chief of the CSB

 7     Sarajevo, called me, and he was a man, by the way, whom I had hired, and

 8     he told me, Look, chief, it's not exactly what it looks like.  And I told

 9     him, Man, what have you done?  Because he was using Bakir Alispahic's

10     personal car to transport weapons, and he received all these false IDs

11     from Bakir Alispahic and Munir Alibabic.  I'm talking about his case

12     because it's interesting.  And then I told Bakir, Look, I'm sending him

13     back to you in the next exchange, and did I that.

14        Q.   All right.

15             JUDGE HALL:   Ms. Korner, we'll take the break.  And we will

16     resume in 20 minutes.

17                           [The witness stands down]

18                           --- Recess taken at 10.36 a.m.

19                           --- On resuming at 10.59 a.m.

20             MS. KORNER:  Your Honour, while the witness is being brought, can

21     I tender the diagram, if there's no objection, as an exhibit.  That is,

22     10326.

23             JUDGE HALL:   Yes, admitted and marked.

24             MS. KORNER:  Thank you.

25             THE REGISTRAR:  This will be Exhibit P1251, Your Honour.

Page 8307

 1             JUDGE HALL:  Ms. Korner, could you remind me as to -- I remember

 2     several months ago you had helpfully prepared for our use these large

 3     folders of maps and diagrams.  Could you remind me as to whether they

 4     were formally tendered or whether they were just working copies that

 5     we're using.

 6             MS. KORNER:  No, they're both.  I'm not sure about the maps, but

 7     certainly the diagrams of the various parts of the government and the MUP

 8     and the like are -- are an exhibit.  I don't remember about the maps.

 9             JUDGE HALL:  The reason why I ask is that when we have a diagram

10     such as the present whether we are adding it to things that have been

11     previously exhibited or --

12             MS. KORNER:  No, I think, if you recall, Your Honour, there is a

13     difficulty about sort of adding things in to previous exhibits all to do

14     where the electronic display, I think, because the diagram we did of the

15     CSB as well has got a separate exhibit number.

16             But we can -- Your Honours, we can certainly add them to the

17     booklets that Your Honours have got them, if you would like them all

18     together in one place.

19             JUDGE HALL:   Of course, the advantage of that is that they would

20     be in a size which is readable.

21             MS. KORNER:  Yes.  Your Honours -- well, certainly after Easter

22     we'll make sure you get, as it were, if you give us your booklets back

23     unles you've marked them, and then we can add in the two new diagrams.

24             JUDGE HALL:  Thank you.  That would be helpful.

25                           [The witness takes the stand]

Page 8308

 1             MS. KORNER:

 2        Q.   Mr. Skipina, I want to stay on the topic of those exchanges.  You

 3     told us there came a point where you declined or told Mr. Stanisic that

 4     you would no longer deal with this; is that right?

 5        A.   That's right.

 6        Q.   Can you tell the Court, please, briefly about the two incidents

 7     which led you to tell Mr. Stanisic you would no longer engage in exchange

 8     of prisoner activities.

 9        A.   The first case was as follows:  One morning as I was coming to

10     work in front of the building where I worked I saw 2 or 300 Bosniaks and

11     a truck with a tarpaulin, perhaps two trucks even and three armed men who

12     had brought them there, escorted them there.  I asked them who they were,

13     and where they were from.  They told me that they had been sent by the

14     Bratunac Crisis Staff.  Now to whom these Bosniaks were sent I asked them

15     and they said, We were just told to bring them to Pale, and then I asked,

16     Whom to Pale?  And then they said, We don't know.

17             I was standing there, thinking what to do.  If he were to return

18     them, to send them back, I was afraid they could be killed.  If I were to

19     get in touch with Grubisic about organising an exchange, that would take

20     a couple of days.  These people were standing by a road.  It was possible

21     that a member of a paramilitary unit could come along or somebody else

22     who could just open fire on those people, throw a hand-grenade or

23     something like that, and R that moment I remember that Dobro Planojevic

24     assistant minister for general crime several days prior to that told me

25     that Maric, who was chief of public security station in Ilijas, was a

Page 8309

 1     good lad, a good professional, and previously I learned that Serbs from

 2     Zenica and Kakanj used to come across the border crossing at Cekrcici to

 3     go into Ilijas.

 4             So I called Maric up, and I asked him whether he could transfer a

 5     group of Bosniaks safely to Visiko.  He told me he could organise that.

 6             I called up Radomir Kojic immediately, and I exaggerated the

 7     seriousness of the case and I said, Based on the order of Karadzic and

 8     Stanisic, please take this group of Bosniaks urgently to Ilijas to Maric

 9     so that he could then transport them to Visoko area.

10             In the meantime, I called an operative of the National Security

11     Service who was at Ilijas at the moment, and I asked him to follow up on

12     that activity.  Kojic went there, drove those people there, and the first

13     one who called me up on the phone was Mile Renovica.  He told me that the

14     operation had been successfully completed, that the people had been

15     transported to Visoko.

16             The minister came on the following day I told him about this.  I

17     told him that I used his name without authorisation as well as as the

18     office of the president of the Republic but that I had no other choice.

19     It was very important for me to protect these people.

20             Several days after that, on radio Sarajevo, which was the BH

21     radio, people were calling up Radomir Kojic, sending greetings to him,

22     and thanking him for saving them.  But this left a trace on me,

23     traumatised me --

24        Q.   Right.  Thank you.  Can you pause there before you deal with the

25     second incident.

Page 8310

 1             First, you said you were going to get in touch with Grubisic or

 2     you couldn't get in touch with Grubisic about organising exchange.  Who

 3     was Grubisic?  Very briefly.

 4        A.   Grubisic was in charge of the exchange.  He represented the

 5     Bosniak MUP.  I have mentioned him earlier today.

 6        Q.   All right.  Second, you said you -- you were frightened that if

 7     they remained in the street they could be attacked by paramilitary.

 8             This is paramilitaries in Pale, is it?

 9        A.   Yes.  Because I didn't know who could have come by.  Perhaps a

10     person whose family had been killed could have come by, learned that

11     Bosniaks were there, and done something terrible to these people, so I

12     was afraid that somebody could have done something without thinking.  It

13     could have been a member of a paramilitary unit, it could have been a

14     member of the Territorial Defence.  Anybody, really.

15        Q.   Was Captain Dragan -- sorry, Captain Dragan.  Were Arkan's Men in

16     Pale in this period?

17        A.   Ever since I came to work at Pale, I never heard that Arkan's Men

18     were ever present there.  I'm not aware of that.  It is possible that

19     they were, but I simply don't know about that.

20             I know that they were in Bijeljina, in Zvornik, but as for them

21     being in Pale, I don't know about that.

22        Q.   But Pale is a tiny place, isn't it, what we sometimes call a

23     one-horse town?

24        A.   Well, there could have been two, but it is small.

25        Q.   A two-horse town.

Page 8311

 1             Are you saying that you could have been wholly unaware if Arkan's

 2     Men were in Pale?

 3        A.   I didn't know about that, nor did anybody ever mention in my

 4     presence that Arkan's Men were in Pale.  It is possible that they were

 5     there.

 6        Q.   Did you come across Captain Dragan at all?

 7        A.   God forbid, no.

 8        Q.   What about a gentleman called, forgive me, Dusko Malovic?

 9        A.   No.

10        Q.   Did you ever have any discussion at all with Mr. Kijac about

11     Dusko Malovic?

12        A.   I don't know Dusko Malovic, any Dusko Malovic.  But I can't

13     exclude the possibility that Kijac may have mentioned something to me.

14     But I don't know any Dusko Malovic.

15        Q.   So you didn't know him to be a paramilitary?

16        A.   I don't know about that first and last name.

17        Q.   All right.  We got slightly side-tracked from these Bosniaks.

18             Did you make any inquiries as to why these Bosniaks had been sent

19     to Pale from Bratunac, what they had done to justify sending them to

20     Pale?

21        A.   Looking at those people, just casting a superficial glance, I

22     don't think that they did anything.  But I didn't have my operatives in

23     Bratunac nor in nearby municipalities, so I don't know.  I never received

24     any information nor did I seek one.

25             On the following day, I told Minister Stanisic that the Crisis

Page 8312

 1     Staff from Bratunac had sent those people.

 2        Q.   The people who were guarding the 300 Bosniaks, who were they?

 3     Members of the MUP?  Members of the army?

 4        A.   They had different sorts of uniforms.  I think camouflage bottoms

 5     and jackets.  They were not blue ones.  They didn't have anything

 6     indicating that they were members of the MUP.

 7        Q.   And you say they didn't look like people who had done anything.

 8     Do you mean there were women and children there?  Or did they all look

 9     like civilians?

10        A.   They were all male, civilians, but so scared, so frightened, that

11     I simply couldn't see them as a threat.

12        Q.   All right.  Did -- when you reported all this to Minister

13     Stanisic, did you say that, really, something should be done about this

14     expulsion of civilians from Bratunac, some complaint made to anybody?

15        A.   I didn't suggest anything to the minister.  I simply told him

16     about the event, about how it unfolded.  He told me, Well, done.  And

17     this is where it ended.

18        Q.   And he didn't say, Right, I'm going to tell Mr. Karadzic or

19     anybody else in the Presidency, that civilians are being expelled from

20     Bratunac, Muslim civilians, Bosniaks, as you put it?

21        A.   He didn't say that, but that doesn't mean that he didn't do

22     anything about it.  I don't know.

23        Q.   No.  All right.  And the second incident that you say led you to

24     tell Mr. Stanisic you would no longer deal with exchanges, can you

25     briefly tell the Court what that was about.  And I mean briefly, please,

Page 8313

 1     because we've got a number of things to deal with.

 2        A.   Commander of Green Berets, or commander of the Patriotic League

 3     from Sarajevo, whose headquarters was located in the Bosna hotel, called

 4     me up.  He introduced himself.  I can't remember his name.  But I do know

 5     that his headquarters was in the Bosna hotel.

 6             He told me that somewhere in the Vogosca area the Serbian forces

 7     had arrested one of his men.  He told me to find him within that same day

 8     and to return the man to him, in Sarajevo, or else he would kill 40 Serbs

 9     who were in his custody at the hotel.  Or maybe -- I don't remember

10     whether the hotel was called Bosna or Evropa.  I apologise.  I forget the

11     name of the hotel.

12        Q.   Don't worry about the hotel.  Describe briefly, please, the

13     incident.

14        A.   All right.  So I made numerous phone calls, calling people in

15     Ilijas, Vogosca, Ilidza.  He gave me the name of this man of his who was

16     missing.  I couldn't find the man.

17             Earlier as he told me this, he put one of those Serbs on the

18     phone and said, Let's have this Serb tell you about this.  Vojo Milijas

19     [phoen] took the phone.  He was the director of the Privredna bank in

20     Sarajevo, and while crying he said, Slobo, do something and save us.  I

21     did everything I could.  The man we were looking for was simply missing.

22             In the afternoon the commander called me again asking whether

23     there was anything new.  I said, No.  And he said, Well, I'm taking over

24     now.  And I told him, Well, it's up to you now.  Show us whether you're

25     human or inhumane.  This is where the conversation ended.  Later on, I

Page 8314

 1     heard that Vojo Milijas had fled to Belgrade.  I don't know about other

 2     people.  I never spoke to Vojo Milijas again to inquire about the

 3     details, so I don't know what happened.  It is possible that nobody died

 4     in that incident.  I simply don't know.

 5        Q.   Well, wouldn't you have heard if 48 Serbs had been killed that

 6     day by this man?

 7        A.   Forgive me, but he didn't need to kill all 40 of them at once.

 8     He could have killed one by one, one a day.  I never heard about an

 9     incident in which 40 Serbs were killed at once.

10        Q.   No.  And as far as you know, Mr. Vojo Milijas was clearly

11     released because he went to Belgrade; is that right?

12        A.   Yes, he fled to Belgrade after the war and then -- at any rate,

13     the man is alive.  He had been released.

14        Q.   All right.  I now want to move then off the question -- I'm

15     sorry.

16             You said it was these two incidents that made you speak to

17     Mr. Stanisic.  Did you speak to Mr. Stanisic about this question of

18     dealing with exchanges?

19        A.   Yes.  When Minister Stanisic came, I told him, Minister, please

20     let us establish a committee for exchange at the government level.  I do

21     not want to do this any longer.  I had experienced two huge traumas and I

22     wanted somebody else to take over to do that job.  Several days later,

23     certain Rajko Tolovic [phoen] arrived.  I don't know whether he was

24     appointed by the cabinet or by whom.  He introduced him as deputy

25     military prosecutor in Vlasenica.  I handed over to him all of the

Page 8315

 1     documents concerning the exchange, and I was done with it.

 2        Q.   When was it that you spoke to Stanisic about replacing you,

 3     roughly?

 4        A.   Well, let's say mid-May.

 5        Q.   Thank you.  And between dealing with the Vrace prisoners and

 6     mid-May, how many exchanges of prisoners all together do you think you

 7     dealt with?

 8        A.   As far as I can remember, I did four exchanges with Sime Grubisic

 9     plus the exchange, or whatever you want to call it, the freeing of 200 of

10     Bosniaks and sending them off to Visoko. So as far as I remember I did

11     the four exchanges plus this other event.

12        Q.   Now I want to move to some other aspects of your work, please.

13     First of all, I want you to have a look, if you would, at -- sorry, I'll

14     just get my ...

15             MR. ZECEVIC:  Sorry, Your Honours, 37, 22 -- oh.  It has been

16     corrected right now.  Thank you very much.

17             MS. KORNER:  I'm not quite sure ... yes.

18        Q.   Can you have a look, please, at a document with the 65 ter number

19     87.

20             MS. KORNER:  No, I don't think that's it, at least not in B/C/S.

21     It's definitely not it.  It should be -- the B/C/S version should be

22     2089524.  See, it's a different date.  No -- sorry, in that case -- it's

23     the 17th of April I want, not the 3rd of April, both in English and

24     B/C/S.  That now says the 3rd of April.  Thank you.

25        Q.   Looking at the B/C/S please, Mr. Skipina,  Can you tell us,

Page 8316

 1     somebody is signing on behalf of Mico Stanisic.  Can you tell us whose

 2     signature that is?

 3        A.   Excuse me, could I see the date?

 4        Q.   Yeah.  17th of April.

 5        A.   This is my signature.

 6        Q.   All right.  Can I ask, this is -- it's an order or a dispatch, I

 7     should -- to the CSBs.  It's to do with people stealing property.

 8             How is it that you signed on behalf of Mr. Stanisic?

 9        A.   Minister Stanisic called me two or three times on the phone,

10     saying that they would bring a dispatch to me.  I think that it was in

11     April.  And then he would say, Please sign it so that it can be sent to

12     the centres.  I did sign it.

13             These are the matters within the scope of the public security.

14     The minister told me, I read it, and in relation to one dispatch, the

15     minister told me, If have you any suggestions incorporate them into the

16     dispatch and sign.  And this is what I did.

17        Q.   But -- well, this is the first thing.  This is all connected with

18     the public security, isn't it, not the state security, of which you were

19     head?

20        A.   Correct.

21        Q.   So why was he asking you as head of state security to sign a

22     document that related to public security matters?  Why not Mr. Kljajic,

23     for example?

24        A.   I don't know.  It's possible that Kljajic was absent at that

25     moment and that he couldn't sign the dispatch, and that the minister was

Page 8317

 1     also absent and couldn't sign the dispatch.  And then, as the second

 2     under-secretary, the second person in charge within the MUP, he told me

 3     to sign the dispatch, which is what I did.

 4        Q.   All right.

 5             MS. KORNER:  Your Honours, this has not yet so far been

 6     exhibited, so can I ask it be admitted and marked.

 7             JUDGE HALL:  Admitted and marked.

 8             THE REGISTRAR:  This would be Exhibit P1252, Your Honour.

 9             MS. KORNER:  Now I want to move next to a whole series of daily

10     events, bulletins or the like.

11             Now, Your Honours, I do not want to have go through everything

12     single one of them.  Some are signed, I think, by him and others by other

13     people.  Can I ask that if there's no objection, they simply -- I can

14     give you the numbers after we've been through one or two and just have

15     them all admitted and marked and explain what they are, obviously.

16             JUDGE HALL:  Is there likely to be an objection?

17             MR. ZECEVIC:  Well, Your Honours, I don't know what we are

18     talking about.  It is likely we don't have the objection, but I would

19     like to know what -- what specific documents are we -- Ms. Korner has in

20     mind.

21             MS. KORNER:  Well, we'll put up one of them.

22             Can we have up, please, document number 937.

23             JUDGE HALL:  While we're waiting for the document, I suppose, Ms.

24     Korner, that what you are attempting to do is the practice we have sort

25     of adopted of marking the batch according to one or two specimens.

Page 8318

 1             MS. KORNER:  Yes, and you will see that they're all the same type

 2     of document.

 3        Q.   This is a documented dated 23red of April headed Daily Events

 4     Bulletin.  It's got the stamp and it's, I think, says, Minister of the

 5     interior, Mico Stanisic.  But can you tell us who signed that?

 6        A.   It's not my signature.

 7        Q.   Are you able to ... [Microphone not activated]

 8        A.   And I don't know whose it is.  I can't identify it.

 9        Q.   All right.  But before we move to the next one, can you tell us

10     what these daily events bulletins were, daily reports they're sometimes

11     called.

12        A.   There were daily events, bulletins, and daily reports which were

13     intended for the people in leading positions to inform them about the

14     events.  And then when it came to more serious bulletins, then prime

15     minister was also informed of them.

16             However, in the list of addressees, if there were any external

17     addressees, say cabinet members, then the bulletin would say that it was

18     sent to the cabinet as well.  If nothing of the sort was stated then it

19     was meant for only internal use.

20        Q.   But these daily events, reports, or bulletins were intended for

21     people in leading positions, and by that, do you mean the -- the

22     politicians or leading positions in the MUP?

23        A.   There were no politicians in the MUP.

24        Q.   No, sorry.  You said, "these daily reports were intended for

25     people in leading positions."  Leading positions in the MUP or outside

Page 8319

 1     the municipal, for example, in the government?

 2        A.   Those that do not contain any indication to whom they were copied

 3     were intended for senior staff in the MUP.

 4        Q.   All right.  And what was the purpose behind senior staff in the

 5     MUP getting these reports?

 6        A.   Well, that was their purpose, to provide as much information

 7     about developments on the ground.

 8        Q.   All right.  And if Mico Stanisic didn't sign for some reason, and

 9     I think we'll come to ones that you did sign, would he be aware of the

10     contents of these reports?

11        A.   If he signed under the report, it's only reasonable to assume

12     that he was familiar with a particular bulletin.

13        Q.   If it has his stamp and his typed signature but actually somebody

14     like you had signed on his behalf, would he still be aware, would you

15     sign without his permission to sign, or his instructions?

16        A.   If a report was intended as internal information, then it was not

17     particularly valuable as a document, and I could sign it or any other

18     senior staff member could sign it because it did not have any particular

19     importance.

20        Q.   Well, just for a moment, let's just have a look at this

21     particular one even though you didn't sign it.

22             Did you get these reports in your position?

23        A.   I did not.  But I'm familiar with those that I signed.

24        Q.   Sorry.  If it was meant -- if these reports were meant for

25     leaders -- those in leading positions in the MUP, did you hold a leading

Page 8320

 1     position in the MUP?

 2        A.   I was nominally one of the leading people in the MUP, but in

 3     practice, the National Security Service was a separate service within the

 4     security system, and it was only nominally linked to the MUP.

 5        Q.   All right.  Well, let's just -- the contents of this daily events

 6     bulletin, the young Predrag Mocevic was monstrously killed, or, rather,

 7     massacred by the Green Berets today in Sarajevo ... the autopsy report

 8     shows exactly how the butchers went around their -- abut their job,

 9     et cetera, et cetera.

10             Is that sort of language that you expect in this period to be

11     found in a police report?

12        A.   I would not expect it.  But it was up to the person who did the

13     writing.  We did not have professional analysts in charge of writing

14     these reports.

15             I wouldn't say this is appropriate language, but it is also not

16     appropriate for the media to name me and my son as the key

17     throat-slitters in Pale.  And my son who had been the subject of many

18     death threats, has lived in Belgrade since 19 --

19             THE INTERPRETER:  The interpreter didn't hear the end.

20             MS. KORNER:  I don't think it matters when his son left for

21     Belgrade.

22        Q.   Mr. Skipina, I'm sorry, would you say this language was intended

23     to incite hatred of non-Serbs amongst the police officers who were going

24     to read it?

25        A.   Perhaps you could read that into it.  But aren't the things that

Page 8321

 1     I'm mentioning about to you also inappropriate?  I worked for a long time

 2     in Sarajevo, and I had friends among both Croats and Bosniaks, and they

 3     called me a throat-cutter; whereas, I saved many of these people.  And

 4     that's -- you can't say that's propaganda.

 5        Q.   Were you ever aware of Mr. Stanisic saying, I'm not going to let

 6     a report in this sort of language go out under my name?

 7        A.   I saw Mr. Stanisic only very seldom.  I don't know how he would

 8     react if a particular report came to his desk.  So I cannot answer in

 9     general terms.

10        Q.   All right.

11             MS. KORNER:  Your Honours, this particular report not signed by

12     him by somebody else, but I'm go to go on to ones that are actually

13     signed by him.  I don't know whether I can have this exhibited on the

14     way, as it were.  I mean, he is familiar with these reports.

15             JUDGE HALL:  Well, perhaps we better see the other specimens that

16     you intend to show first and then we'll come back to the question of

17     exhibits.

18             MS. KORNER:  All right.  Then can I -- can I have it marked for

19     identification, Your Honour?

20             JUDGE HALL:  Yes.

21             THE REGISTRAR:  This would be Exhibit P1253 marked for

22     identification, Your Honour.

23             MR. ZECEVIC:  I'm sorry, Your Honours, just for the sake of

24     accuracy of the transcript 43, 13, I believe the witness said, I

25     mentioned -- I'm mentioning about me.  What the things that are

Page 8322

 1     mentioning about me are also inappropriate, and it is recorded as you.

 2     So it doesn't make sense like it is recorded.  Thank you.

 3             JUDGE HALL:  Thank you.

 4             MS. KORNER:  Can we look, please, at document 942, please.  Can

 5     we just ...

 6                           [Prosecution counsel confer]

 7             MS. KORNER:  Yeah.  30th of April.  Could we have a look just at

 8     the bottom, the signature, again, somebody signing on behalf of

 9     Mr. Stanisic.

10        Q.   Whose signature?

11        A.   With 95 per cent certainty, I think it is Radomir Ninkovic.  At

12     the time, he was assistant minister for analysis and information in the

13     MUP.

14        Q.   All right.  Can you --

15             MS. KORNER:  Can we have the second paragraph of that report down

16     which says:

17        Q.   "According to reports received from the public security station

18     of the Serbian municipality of Bosanski Samac, the town is now free and

19     the situation is gradually becoming normal."

20             What do you understand is meant by "the town is now free"?

21        A.   Well, in my understanding, it had been earlier attacked by

22     Bosniak and Croat forces before Serbian authorities finally re-asserted

23     their control over that area.  That's how I would understand it.

24        Q.   The town is now free.  When it is being attacked, you say, by

25     Croats and Muslims?

Page 8323

 1        A.   Well, I suppose because it says according to reports from the

 2     public security station of the Serbian municipality of Bosanski Samac,

 3     this town is now free, which means that it had been attacked by some

 4     forces.  The members of the Croatian paramilitary forces had been

 5     disarmed, et cetera, et cetera, which means that some activity had taken

 6     place before and they now report the town is free again.

 7        Q.   So it doesn't read to you that the very opposite, that the

 8     Bosniaks and Croats were in the town and the Serbs were attacking it, and

 9     that's how they freed it; that doesn't read that to you?

10        A.   Well, I don't know.  Maybe you could read it that way too.  I

11     don't know what the situation was.  Maybe you could read it that way.

12             But I read it the way I already described.

13        Q.   When weren't you collecting intelligence from all these areas, as

14     head of the SNB?

15        A.   I did not have any contact whatsoever with the national security

16     sectors in Banja Luka and Doboj throughout my tenure, that is, up to the

17     3rd of July when I resigned.  I had no communication whatsoever with the

18     national security sector in Doboj and its leader Dusan Zivkovic all with

19     Nedeljko Kesic in Banja Luka.

20        Q.   We'll come on to your contacts with Mr. Kesic, but, I'm sorry,

21     you're saying that Samac -- Samac came under Doboj, because it certainly

22     didn't come under Banja Luka, did it?

23        A.   That's right.  It was under Doboj.

24        Q.   And when you say you had no contacts with them, you were

25     receiving -- reports were being received, weren't they, from these areas

Page 8324

 1     both from Doboj and Banja Luka because if we go through these daily

 2     reports we'll see there was information.  So what do you mean, you had no

 3     contact?

 4        A.   I said sometime ago that the National Security Service was a

 5     separate service which has its own rules.  It was dealing with

 6     intelligence and counter-intelligence work, anti-terrorist activity

 7     against attacks from abroad, and this service does not communicate in

 8     open text, not even on the telephone.  All its communications have to be

 9     encrypted.  If I did any different as head of the service, I would be

10     breaking the rules.

11        Q.   So what you're saying, you had a lack of ability to have

12     encrypted conversations with Mr. Kesic or the other gentleman that you

13     mentioned from Doboj, Mr. Zivkovic?

14        A.   That's correct.  That's right.

15        Q.   But if the absolute worse came to the worst, could you have rung

16     Mr. Kesic or Mr. Zivkovic on an open line saying, I need a report,

17     however you get it to me?

18        A.   Yes, I would be able to do that, but I would be breaking the

19     rules.  And if they sent a report, all the telephone communications went

20     across the territory of Bosnia and Herzegovina.  From the viewpoint of

21     operative work, the -- such a conversation on the telephone would be

22     fraught with consequences.  I could only use those communications that

23     were allowed.

24        Q.   All right.  Could we have -- I have forgotten whether we asked to

25     you look at the signature on this one.  Again it has gone out under

Page 8325

 1     Mr. Stanisic's name, but who has signed on his behalf?

 2        A.   I've already said, Radomir Ninkovic, assistant minister for

 3     analysis.

 4             MS. KORNER:  All right.  Your Honours, may that be marked for

 5     identification as well until we actually come to one he actually did

 6     sign.  That's 946.

 7             JUDGE HALL:  So marked.

 8             THE REGISTRAR:  That would be Exhibit P1254 marked for

 9     identification, Your Honour.

10             MS. KORNER:  All right.  Can we now look, please, at a document

11     that's already been marked for identification, P142.

12             And I just for these purposes want to have a look at the

13     signature on the bottom of the B/C/S.

14        Q.   Again, somebody signing on behalf of Mr. Stanisic.  Whose

15     signature?

16        A.   It looks like my signature, but it's not mine.  It's a good

17     imitation.

18        Q.   All right.  Pause -- how do you know it's not your signature,

19     sir?

20        A.   It's not, because I never put that line across at the end.  The

21     first letter, Sh, is identical, the K is not mine, and I'll compare later

22     my real signature to this one, if you wish.

23        Q.   Why was somebody forging your signature then?

24        A.   I have no idea.  Maybe it is not a forgery.  Maybe it is somebody

25     who signs his name in this way.  But if you show me a real signature, I

Page 8326

 1     will certainly not deny it is mine, whatever the content above it.

 2        Q.   Was -- were only people in -- in your sort of position able to

 3     sign these reports?

 4        A.   Well, there was a number of senior staff in the state security.

 5     But even -- I mean, whoever signed it, he must have been instructed by

 6     his superior.  In this case, this is a daily events report intended

 7     exclusively for the internal information of those employed with the MUP.

 8        Q.   Okay.  Well, that's already been marked for identification.

 9             MS. KORNER:  Can we move to the next document, please, which is

10     948.

11        Q.   Signature, please?  Whose is that?  Somebody signing again on

12     behalf of Mr. Stanisic?

13        A.   Let me say that both the previous and this one are my signatures.

14        Q.   When you say "let me say," do you mean they are your signatures?

15        A.   I'm not sure.  But I'm prepared to accept that any signature that

16     looks like mine is mine.

17             JUDGE HALL:   Sorry, you're talking about the previous document?

18             MS. KORNER:  Yes.  The one that he just said it wasn't his

19     signature.

20             JUDGE HALL:  I see.

21             MS. KORNER:

22        Q.   Mr. Skipina, giving evidence, you're on oath.  Are -- was this --

23     is this your signature?  Not that you're prepared to say it is.  Is it

24     your signature?

25        A.   I'm saying I'm not sure.  Certain features would seem to indicate

Page 8327

 1     it's my signature, but if there is any problem, I -- I have given a

 2     solemn declaration, I stand by that solemn declaration, and I'm certainly

 3     not going to violate it in any way.

 4             This is some sort of report, so ...

 5        Q.   [Previous translation continues] ... this is a whole series of

 6     daily reports during April and May.  The one we looked at before was the

 7     6th of May; this is the 8th of May.

 8             The one on the 6th, you said, you thought was a forgery.  You

 9     have now looked at the one on the 8th.  And you are saying that you now

10     believe that the one on the 8th and the one on the 6th are your

11     signature; is that right?

12        A.   Both this one and the previous document are similar in terms of

13     signature.  There are elements of my signature.  I cannot claim with

14     certainty that it's a forgery.  Why would anyone forge a signature on a

15     simple daily bulletin?

16        Q.   Exactly.  [Microphone not activated]

17        A.   But maybe -- maybe I was out of sorts when I was signing this.

18        Q.   Well, just for a moment let's have a look, shall we, what's in

19     the first paragraph of this report?

20             Just look at the language there.  Innocent civilians in the

21     general area of Sarajevo increasingly terrorised by the so-called TO of

22     the former BH and the Muslim extremists.  Military defeats and clashes

23     with Serbian forces and the fact they are gradually losing territory have

24     made them rampant.  Serb slaughtering, Muslim gangs, the Green Berets,

25     and the Patriotic League, even more bloodthirsty.  More and more

Page 8328

 1     frequently, men are taken away, maltreated, and finally executed in a

 2     most hideous manner.

 3             Let me ask you the same question I asked you about the first:  Is

 4     that appropriate language to go into a daily report?

 5        A.   It shouldn't be the language.

 6        Q.   [Previous translation continues] ... then why did you sign it

 7     instead of saying, I'm not going to allow a report like this to go out?

 8        A.   Well, in view of the purpose and intent and the recipients of the

 9     bulletin and in view of the fact that I was not authorised to change the

10     contents of any information, I was just given to sign it.

11        Q.   Who could authorise the change in such a bulletin?

12        A.   The chief of the department for analysis and information was

13     responsible and authorised, but, at that time, he was absent.

14        Q.   This was going under -- out under Mico Stanisic's name as

15     minister of the interior.  Did he have the authority to alter the

16     content?

17        A.   He would have if such a bulletin reached him.  But he normally

18     didn't read these bulletins.  He didn't have time for such things.  This

19     was more intended to inform the employees.

20        Q.   How do you know, given that you say you didn't have that much

21     contact with him, whether he read the bulletins and whether he had time

22     to read them?

23        A.   Well, if he were absent for three days, and if three bulletins

24     were published in those three day, then how could he have had any

25     influence on the content?

Page 8329

 1        Q.   This is not -- this is not an argument, please, Mr. Skipina.  You

 2     stated as a fact that he didn't read, he normally didn't read the

 3     bulletin, he didn't have time.  And I'm asking you how you know that?

 4        A.   Well, I suppose that this is a small matter, these bulletins.

 5     I -- I suppose he wouldn't have time for such things.  I don't know

 6     actually how much he read and what he read.  I'm not claiming anything.

 7        Q.   All right.

 8             MS. KORNER:  Your Honours, may this be marked for identification?

 9     I mean, we are going to come to one where he actually says, It is my

10     signature, but ... I don't know whether you consider what he says, well,

11     it probably is my signature is sufficient.

12             JUDGE HALL:  I -- I would have thought so, Ms. Korner, because

13     the explanation he would have given, and we're talking about a passage of

14     time and his recollection, and I think we've all had the experience of

15     our signatures evolving over time, so the -- as I understand the

16     evidence, I -- he accepts that this and the previous document in the

17     set-up they had must be his.

18             MS. KORNER:  In that case, Your Honour, can I have all the

19     earlier ones?  Also as I say -- as you can see it's all part of a group

20     which were marked for identification actually admitted.

21             JUDGE HALL:   There's just one clarification that I'm -- do I

22     understand, Mr. Skipina, that the arrangement or set-up was - I'm

23     building on Ms. Korner's last question - was that although the minister

24     was as minister responsible for anything that issues from his department,

25     that these documents were at a level of routine that the minister didn't

Page 8330

 1     necessarily see them?

 2             Is that what I understand the tone of your evidence to be, that

 3     they were just issued at a lower level in the ordinary work of the

 4     ministry?

 5             THE WITNESS: [Interpretation] That is the best possible

 6     formulation, Your Honour, the one you just made.

 7             JUDGE HALL:  Thank you.

 8             So are we exhibiting the -- how many documents -- we have seen

 9     four or five.  How many comprise the whole batch?

10             MS. KORNER:  The ones -- I think there are about ten in all.

11     I'll go quickly through them.

12             MR. ZECEVIC:  I'm sorry, Your Honours, we have two different

13     documents.  Namely, six documents out of totally 12 of the daily reports

14     are signed -- or actually more than 12.  15.  There's 15 daily reports.

15     Out of 15 daily reports, six are signed by somebody, and it says "for

16     Mico Stanisic, the minister of interior."

17             The rest of the documents are signed by the department for

18     analysis and information, informational tasks, so, therefore, if this is

19     the purpose that Ms. Korner wants to use these documents, she can exhibit

20     these six and then maybe the other as a -- as in another batch because

21     there is a difference between the documents.

22             MS. KORNER:  The purpose for the admission of these documents is

23     to show the amount of information that was coming up to the MUP at the

24     republican level -- at the level of the the Serbian Republic.

25             JUDGE HALL:  What I understand, Mr. Zecevic's, I'm sorry,

Page 8331

 1     observation to be, is that the ones that we have seen are in one

 2     category, but the others are in a different category so you may have to

 3     select a number of those and separately exhibit them.  That is all I

 4     understand his observation to be.

 5             MS. KORNER:  Your Honour, whether they are signed, not signed

 6     whatever, the purpose is, and I think for all the reports, is to inform

 7     either internally the MUP or sometimes, and we can see it on some of the

 8     documents, they are clearly marked to be sent to members of the

 9     government.

10             We say that all part and parcel.  I'm reluctant to waste the time

11     that I have in going through them.  But if -- if Your Honour feels that

12     there's some merit in Mr. Zecevic's objection, then I will have to do

13     that.

14             JUDGE HALL:  Not going through all of them but to separately

15     select say one or two of the other set that went through a different

16     department.  That is what I understand his --

17             MS. KORNER:  All right.  Your Honours, in that case, can I just

18     go back through, so document 937 which I had marked for identification

19     should be admitted, 942 should be admitted.  946, 947, 948, and 949

20     should all be fully admitted.

21             JUDGE HALL:  Yes, admitted and marked.  That's that set.

22             MS. KORNER:  Yes.  I think there is a bit more to come actually.

23             THE REGISTRAR:  So 65 ter 946 becomes Exhibit P1255; 948 becomes

24     Exhibit Number 1256; 947 becomes Exhibit 1257; 949 becomes Exhibit P1258,

25     Your Honour.

Page 8332

 1             MR. ZECEVIC:  I'm sorry, if I can be of assistance, I don't want

 2     to use up Ms. Korner's time, I'm just -- just for the clarification.

 3             65 ter 947 is already admitted.  It is P142, MFI.  So in this

 4     respect, this should be changed.

 5             And I believe 65 ter 950 belongs in the same category, the ones

 6     which are signed by his signature.

 7             MS. KORNER:  Yes, it does.

 8             MR. ZECEVIC:  So --

 9             MS. KORNER:  I was going to say ... so, Your Honour, can that --

10     without me having to go through it, could that be marked as well?

11             JUDGE HALL:  Admitted and marked.

12                           [Trial Chamber and Registrar confer]

13                           [Trial Chamber confers]

14             JUDGE HARHOFF:  Ms. Korner, could I just ask you if your purpose

15     of seeking to have all of these daily reports admitted into evidence is

16     to point to the propagandistic tone of the information that was passed

17     around, or is there another purpose?  Because if it is only for the issue

18     of propaganda, then I don't think we need to admit the whole batch.

19             MS. KORNER:  Your Honour ... [Microphone not activated]

20             JUDGE HARHOFF:  [Microphone not activated]

21             MS. KORNER:  Your Honours, the reason -- the propaganda is

22     actually ancillary, and it only occurred to me when I was reading through

23     them last night, is the amount of information they were getting from the

24     various areas.  As we've been through before, it's a big issue in this

25     case as to what was known to the republican MUP.  And, secondly, I

Page 8333

 1     haven't gone through the content, but at an appropriate stage I may well,

 2     the reports that are getting contain almost no reference to any killings

 3     of non-Serbs or crimes against non-Serbs.

 4             So that's the -- the purpose.

 5             JUDGE HARHOFF:  Thank you.

 6             THE REGISTRAR:  So first the 65 ter 947 will not get a number

 7     P1257 because it's been already exhibited.

 8             So 65 ter 946 becomes Exhibit P1255; 65 ter 948 becomes Exhibit

 9     P1256; 65 ter 949 becomes Exhibit P1257; and 65 ter 950 becomes Exhibit

10     P1258, Your Honour.

11             JUDGE HALL:  And we are conveniently at the time for the break.

12             MS. KORNER:  Sorry ... [Microphone not activated] ... bogged

13     down.  Did we have 942 exhibited?

14             THE REGISTRAR:  942 is Exhibit P1254 marked for identification.

15             MS. KORNER:  No.

16             THE REGISTRAR:  Not anymore.

17             So then 65 ter 937 is not marked for identification, so it is now

18     Exhibit P1253 and 65 ter 942 is Exhibit P1254.

19             MS. KORNER:  Thank you.

20                           [The witness stands down]

21                           --- Recess taken at 12.10 p.m.

22                           --- On resuming at 12.31 p.m.

23                           [Trial Chamber confers]

24                           [The witness takes the stand]

25                           [Prosecution counsel confer]

Page 8334

 1             MS. KORNER:

 2        Q.   Mr. Skipina, before we go on to the next bunch of documents, can

 3     I just return for a moment to a topic that came out of one of the

 4     reports, Bosanski Samac.

 5             And you explained that you thought that the town had been

 6     surrounded by Croat and Muslims and was then -- the Serbs re-established

 7     control.

 8             Who did you get that information from?

 9        A.   It's an assumption based on reading the text.

10        Q.   [Previous translation continues] ... did you ever have a

11     conversation on the telephone with Stevan Todorovic?

12        A.   Yes.

13        Q.   And when did you have that conversation with him?

14        A.   It's possible that it was in late April or in May.  I'm not sure.

15        Q.   And when Mr. -- who rang whom?  Was Mr. Todorovic ringing you or

16     the other way around?

17        A.   Mr. Todorovic rang the number, and I picked up the phone.  He

18     introduced himself saying that he was Stevan Todorovic, chief of public

19     security station in Samac, and asked for some senior MUP staff members.

20             I introduced myself, said I was Slobo Skipina, chief of national

21     security.  And then he told me, Mr. Skipina, we have major problems.

22     They are firing artillery at us from Croatia, from the village of Prud.

23     It's the Croats firing at us and also from Domaljevac, but we think that

24     we will persevere, that we will survive.  That was the only conversation

25     I had.  I never met Stevan Todorovic before that or after that.

Page 8335

 1        Q.   Did you have one conversation with him or more than one

 2     conversation?

 3        A.   Just that one.

 4        Q.   And did you ever hear of Mr. Todorovic committing crimes in

 5     Samac?

 6        A.   Yes.  And I know that he was on trial here.

 7        Q.   But did you know at the time that he was committing crimes in

 8     Bosanski Samac?

 9        A.   No.  Because I had no communication with my service in order to

10     learn from them --

11        Q.   [Previous translation continues] ...

12        A.   -- at the time.

13        Q.   Did you not get any reports through anybody who was based in the

14     Doboj area about the crimes that were being committed against Muslims,

15     not only in Bosanski Samac, but in other places?

16        A.   No.

17        Q.   [Previous translation continues] ... not one?

18        A.   Not one.

19        Q.   So you were receiving a multitude of information about crimes

20     committed against Serbs or -- when I say "you," the MUP headquarters, but

21     nothing against crimes committed against non-Serbs; is that what you're

22     saying?

23        A.   Information about crimes against Croats or Bosniaks never reached

24     me.  I never received information of that nature except for one case in

25     Sarajevo that I can tell you but now or later.

Page 8336

 1        Q.   No.  Let's leave that.  I want to -- apart that from that one --

 2     I don't want the detail.  If Defence want it, they can ask you.  Apart

 3     from that one incident in Sarajevo you never heard any information about

 4     crimes committed against Croats or Bosniaks during the whole period

 5     whilst you were, first of all, in charge of the SNB?

 6        A.   While I headed the SNB, not a single trace, not a single piece of

 7     information reached me.  Later on, I heard people talked about crimes in

 8     Visegrad, about crimes in Vlasenica, in Brcko, in Zvornik that had been

 9     committed by persons of Serb ethnicity against Bosniaks.  I heard in 1993

10     in Bijeljina that a crime had been committed at Koricanske Stijene, so

11     these are the crimes that I heard about later on, subsequently.  But I

12     did not receive any piece of information about these crimes while I

13     headed the SNB.

14        Q.   What about camps?  Places or -- camps -- buildings where people

15     were being held, guarded by members of the MUP?  Did you hear about that

16     during your period as head of SNB?

17        A.   No.

18        Q.   What about in Pale itself?  Were you aware of people being kept

19     in any building that was not the police station?

20        A.   I didn't hear of that, nor did I see a single facility in Pale or

21     go down there.  So I have no information about Pale.

22             If anybody, it could be the public security station in Pale that

23     could have such information.

24        Q.   Well, I want to ask you, do you remember being asked about this

25     in your interview?  Which you listened to, you told us, before you

Page 8337

 1     arrived here.

 2        A.   I didn't listen to it.  I stopped listening to it.  I

 3     interrupted.

 4        Q.   I'm sorry, I understood you to -- well, when did you stop

 5     listening to it?  How far through the interview?

 6        A.   Approximately halfway through.  130 pages were read to me,

 7     translation from English.  It would take me ten days to sit there.  For

 8     two and a half hours they read to me the translation of my biography from

 9     English.  There was no need for that.

10        Q.   I'm sorry, did you, before you came to The Hague, listen to the

11     tapes of your interview which were delivered to you?

12        A.   I did.  When it was sent to me, sometime in the summer of last

13     year.  I listened to it.  And I think that your question was whether

14     there was a camp in Pale.  Cultural hall was mentioned and some sort of

15     gym or a sports hall, something like that.  Even though I was born in

16     Pale municipality, during that time I did not go down to Pale itself.  I

17     don't know where the gym is or the culture hall.  I never went down into

18     the town.  Never went -- never descended from the hills.

19        Q.   What about a primary school?

20        A.   Well, I suppose that the gym was part of the primary school.

21     That's my assumption.

22        Q.   Well, let me just perhaps see if this refreshes your memory as

23     it's a long time since you've listened to the interview and, as you say,

24     we didn't get through it, owing to the lack of time yesterday.

25             Do you remember being asked:

Page 8338

 1             "Did you know about any detention facilities, which would be

 2     established in Pale apart from the prison which was in the SJB building?"

 3             And your answer, page 91:

 4             "I think there was.  I never went there, but I think there was

 5     one in the school, primary school, in Pale?"

 6        A.   Well, that's possible.  If that's the gym, it's possible.  People

 7     talked about the gym.  And in Pale, only a school could have a gym.

 8        Q.   So people were talking about the fact, were they, that non-Serbs

 9     were being held in the gym of the school?

10        A.   Yes.  People talked.  They even said that Muslims or Bosniaks

11     asked from the chief of the public security station in Pale to find

12     accommodation for them somewhere, for their safety.  And then they made a

13     collective request to move out, which was made possible, to move out to

14     Sarajevo.  If that pertains to that, that's the only thing I can think

15     of.

16        Q.   I'm sorry, are you now saying that your understanding is that

17     people were being held -- Bosniaks were being held in the gym of the

18     primary school at their own request?

19        A.   Who would ask to be held there?  I suppose that some people were

20     kept there without their consent.  Who would voluntarily go to the gym?

21        Q.   You may well ask, indeed, Mr. Skipina.  It is a question, no

22     doubt, the Court will ask.

23             Right.

24             MS. KORNER:  Can we go back, please, to the collection of

25     documents that we were looking at --

Page 8339

 1             JUDGE HARHOFF:  Ms. Korner, could I just kick in one little

 2     question in relation to the answers that we have just heard from -- from

 3     Mr. Skipina.

 4             Because there was something that struck my mind when you told us

 5     that you had never received in 1992, while you were at the SNB, any

 6     information about crimes committed by Serbs against Croats or Muslims,

 7     neither in the field nor in the camps.

 8             But that, in my understanding, would seem to stand against the

 9     evidence that you gave us earlier this morning, when you were talking

10     about the exchange of detainees that came from Bratunac, and where you

11     said that you feared for their safety just by virtue of the fact that

12     they could be standing on the road, because if they were just standing

13     there, some paramilitaries could come and -- and shoot at them.  So

14     obviously these people were in danger.

15             Would that not suggest that crimes could be committed against

16     anyone who was detained?

17             THE WITNESS: [Interpretation] Your Honour, I'm not talking about

18     the entire 1992.  I'm only talking about the period up until the 3rd of

19     June, until when I headed the service.

20             The only relevant information from me would be the one I received

21     from my inspectors, from my men on the ground about something that may

22     have happened.  There were such cases.  Batko, a certain Batko was

23     mentioned in Grbavica who committed misdeeds against the Bosniak people.

24     I spoke to Dobro Planojevic, assistant minister for general crime, about

25     doing something about it.  Dobro Planojevic told me that the minister

Page 8340

 1     knew of this and that he took it upon himself to inform the army about

 2     it, because that Batko was a member of the army, territorial defence of

 3     the army, and that he came under their jurisdiction.

 4             Then another case took place while I was in office.  A case in

 5     which Serbs, I don't know which Serbs, whether they were members of

 6     the -- of a paramilitary formation or some other unit, we, as SNB asked

 7     for information but in that incident about 30 Bosniaks were killed who

 8     had been captured in the vicinity of Sarajevo in the village of Kotorac

 9     and then killed.

10             So it's not that I didn't know about such cases but what was

11     relevant for me was what I received formally through formal channels

12     within my service.  I did not have enough of my people on the ground, I

13     did not have the a single operative or inspector in many municipalities,

14     and I didn't have communications with many of my operatives.

15             So my service was tiny, it was just being created.  We had no

16     technical equipment, no manpower, that was the reality.  I simply didn't

17     have resources.  Half of the people remained in Sarajevo.  Some went to

18     Montenegro, some went overseas.  I rehired all of those who had been

19     reserve officials and those had retired.  I rehired them and still that

20     wasn't enough to cover the entire area.

21             JUDGE HARHOFF:  I understand.  But what you're saying now would

22     seem to translate into a question of whether then, you did receive

23     information about crimes committed by Serbs against Muslims and Croats

24     through informal channels.

25             THE WITNESS: [Interpretation] I didn't receive information via

Page 8341

 1     informal channels either.   Not a single enactment reached me say from

 2     the public security department that had been sent to CSBs and SJBs.  I

 3     did not receive a single such document, and also when it comes to

 4     feedback, no documents reached me.  No documents sent by SJBs and CSBs to

 5     MUP.

 6             JUDGE HARHOFF:  No.  I understand.   But that would be through

 7     formal channel, would it not?  So my question to you is, did you receive

 8     through informal channels any information about such crimes?

 9             And when I'm pointing to informal channels, that could be press

10     releases, that could be rumours in town, that could be oral reports given

11     to you that could be in discussions at meetings, and so on.

12             THE WITNESS: [Interpretation] I frequently listened to the

13     Bosniak radio, Radio Sarajevo.  They announced such news, that crime had

14     been committed, that Bosnian population was terrorised and so on, but I

15     did not see receive any other pieces of information through any informal

16     channels.  I did not learn of it.

17             JUDGE HARHOFF:  Thank you, sir.

18             MS. KORNER:

19        Q.   Did you consider that you had -- [Microphone not activated]

20             THE INTERPRETER:  Microphone, please.

21             MS. KORNER:

22        Q.   Did you consider that you had a duty to be proactive in your job,

23     as opposed to reactive?

24        A.   I did not understand your question.

25        Q.   Well, did you consider that your job meant that you had to

Page 8342

 1     ensure, as far as was possible, that you were getting intelligence

 2     reports as opposed to just sitting back and saying, Well, I haven't got

 3     any.  That's just bad luck?

 4        A.   I wasn't just sitting.  Operatives were given a task.  If they

 5     learned of any information within their scope of work, to send it to the

 6     public security department for further processing.

 7        Q.   And as we will see later, you did, in fact, have information

 8     before you resigned, didn't you, about crimes both in Bijeljina and

 9     Zvornik?

10        A.   That I received information officially about Bijeljina and

11     Zvornik?  In Zvornik, yes.  If you are referring to my trip to Bijeljina

12     pursuant to the order of Minister Stanisic, and if you are referring to

13     the two groups that caused problems in Bijeljina, if that's what you have

14     in mind, then, yes.

15        Q.   That's what I have in mind.  And, as I say, we'll look at that a

16     little later as a separate topic.

17             Can we, however, just finish, for the moment, please, these daily

18     reports or bulletins.

19             Could you have a look, please, at document number 962.

20             MS. KORNER:  And can we look at the last page in both English and

21     B/C/S, please.  Second page that would be ... apparently not.  I must

22     say, Your Honour, when I calculate the time I should add in a further

23     half-hour for the length of time it takes for documents to come up.

24        Q.   It's a daily report, number 108.  So presumably there had been

25     107 before that.

Page 8343

 1             And if we ever get to the second page ...

 2                           [Trial Chamber and Registrar confer]

 3             MS. KORNER:  Is the machine stuck?

 4                           [Prosecution counsel confer]

 5                           [Trial Chamber and Registrar confer]

 6             MS. KORNER:  No, sorry.  Second page in English; second page in

 7     B/C/S.  Well, "Pale staff" is part of it.  Okay.  Can we look at the

 8     bottom of the second page in English.

 9        Q.   The date of this report is 24th of May, and it's addressed to the

10     ministry, the under-secretaries, times two under Serbian government, and

11     then as we saw, Pale staff.

12             Were you one of the under-secretaries to whom this report would

13     come?

14        A.   Yes.

15        Q.   And so this is one of the other batch of reports that you

16     describe that actually go outside the MUP itself to the Serbian

17     government; is that right?

18        A.   Correct.

19        Q.   All right.  And can you -- in B/C/S, we need to go back to the

20     first page, but stay on the second page, please.

21             MS. KORNER:  Can we go back to the first page in B/C/S.

22             JUDGE HALL:  I'm advised that these technical problems are going

23     to continue to occur from time to time until the system gets sorted out.

24             MS. KORNER:  Yes.  Can I have an extra number of minutes to make

25     up for this?  Thank you.

Page 8344

 1        Q.   Do we see there, this is the report from Banja Luka, and there's

 2     a whole bunch of things about Bosanska Gradiska, in fact, I don't want to

 3     move to the previous page in English.  Just leave it where it is.  It

 4     deals with Prijedor, which can you see, then Bosanska Gradiska,

 5     Banja Luka, a member of the CSB special unit tried to commit suicide.

 6     I'm sure that was relevant information for the MUP.  And then Kljuc,

 7     Prnjavor, Sanski Most explosive devices, and all the rest of it.

 8             So even if you weren't communicating with encrypted lines, it

 9     would appear that you were getting information from Banja Luka.  Would

10     you agree?

11        A.   Perhaps MUP was receiving information from Banja Luka, I'm not

12     denying that, but the National Security Service did not receive a single

13     document, a single report during the time I was head of the service.  Not

14     from Doboj and not from Banja Luka, from the CSB.

15             I -- I'm not ruling out that there could have been other means of

16     communication through which the Ministry of Interior received information

17     from these centres.

18        Q.   And you're saying it's because you couldn't have an encrypted

19     line.  Is that because you didn't have a person to encrypt, as opposed to

20     not having a line?

21        A.   No.  We did not have the equipment or the encryptor at least for

22     mobile communication systems.   We had nothing.

23        Q.   Well, I'm -- leave aside mobile communication systems, did you

24     have, as it were, non-mobile communication system which could be

25     encrypted, whatever non-mobile may be?  Land-line.

Page 8345

 1        A.   If you mean whether they existed, I know that it -- at Vrace

 2     before the war, there were mobile communication systems and laboratories

 3     of the National Security Service.  There were offices and equipment,

 4     cameras, still cameras, everything normally used by the National Security

 5     Service.  I knew that all that existed in Vrace, in the offices of the

 6     National Security Service, before the war, when I was retiring.

 7        Q.   Yeah.

 8             MS. KORNER:  Your Honour, then -- sorry, may that be admitted and

 9     marked.  And then there are another 1, 2, 3, 4, 5, 6, 7 -- seven reports,

10     a further seven reports like that.

11             So if Mr. Zecevic has no objection, could they -- I can read the

12     numbers out.

13             MR. ZECEVIC:  There's no objection, Your Honours.

14             JUDGE HALL:   Admitted and marked.

15             MS. KORNER:  And, Your Honours, that one is -- that was, sorry,

16     number 19 was P -- was 963.  I would like to have marked and admitted 65

17     ter numbers 965, 966, 967, 968, 969, 970, and 972.  Oh, sorry, stop.  I

18     have just seen that 972 is, in fact, a Defence exhibit.

19             THE REGISTRAR:  Yes, so 65 ter 962 become Exhibit P1259; 995

20     become Exhibit P1260; 966 become Exhibit P1261; 967 become Exhibit P1262;

21     65 ter 968 becomes Exhibit P1263; 979 become Exhibit P1264; 970 become

22     Exhibit P1265; and 972 become Exhibit P --

23             MS. KORNER:  No.

24             THE REGISTRAR:  It is already an exhibit.  Excuse me, did 963 was

25     also in this list?

Page 8346

 1             MS. KORNER:  Yes.

 2             THE REGISTRAR:  So this would be exhibit -- 963 becomes Exhibit

 3     P1266, Your Honour.

 4             MS. KORNER:  Right.  Thank you very much.

 5             THE REGISTRAR:  I apologise, I said 995 instead of 965, I

 6     apologise.  Just for the clarity of the record.  It becomes P1260.

 7             JUDGE DELVOIE:  Didn't 971 -- wasn't 971 included in your list,

 8     Ms. Korner?  I think --

 9             MS. KORNER:  I don't think so, no, Your Honour.  It is 970 and

10     then 972.  There was no 971.

11             JUDGE DELVOIE:  No 971.  Thank you.

12             MS. KORNER:  No.  Now next I want to move --

13             MR. ZECEVIC:  I'm terribly sorry, I am just completely lost now.

14     Which -- which document is 65 ter 979 which became Exhibit P1264?

15             MS. KORNER:  [Microphone not activated]... 969.

16             THE REGISTRAR:  969.  So 65 ter 969 becomes Exhibit P1264.

17             MR. ZECEVIC:  Okay.  Thank you very much.

18             MS. KORNER:  [Microphone not activated] I now have a query.  We

19     applied to add a document in the last motion as a proposed 65 ter 3575,

20     and you declined.  Does that mean that I cannot ask the witness to look

21     at the document for -- and whether he is familiar with the contents?

22             Am I prohibited from doing that?  That's what I want to know.

23     I'm not exhibiting is what I mean.

24             JUDGE HALL:  You may ask the witness -- you may show the document

25     to the witness, yes.

Page 8347

 1             MS. KORNER:  Thank you.  All right.

 2        Q.   Could you have a look, please, at - I hope it is in Sanction -

 3     3575.

 4             All right.  This is the first page of a -- double-sided.  So it's

 5     about a five-page document.  I want to know, could you just tell us, are

 6     you familiar with any of the telephone numbers that you can see there?

 7        A.   No.

 8        Q.   None of them at all?

 9        A.   I'm not very good at remembering telephone numbers.  I can hardly

10     remember my own home number.

11        Q.   071 611 377.  Is that -- ring any bells with you?

12        A.   No.

13        Q.   All right.  In that case, I won't pursue this.  Thank you.

14             Now, did you attend meetings, on behalf of Mr. Stanisic, of

15     sessions of the government in June of 1992?

16        A.   Yes, I think twice.

17        Q.   All right.  Could you have a look, please, at P231.

18             Does that show you attending, instead of Mico Stanisic, on the

19     16th of June?

20        A.   Yes, that's what it says.

21        Q.   And how come was it that you attended instead of Mr. Stanisic?  I

22     mean, why you rather than, for example, Mr. Kljajic?

23        A.   Both times the minister called me from somewhere, I don't know

24     where he was, and he said, Slobo, there's a cabinet session today.  You

25     go there.  You don't have to take part in the discussion, but just be

Page 8348

 1     there to see whether some assignments for the Ministry of the Interior

 2     will be given at that session.

 3             And that's how I came to attend both sessions.

 4        Q.   And were -- was it your job to report back to Mr. Stanisic about

 5     matters that affected the MUP?

 6        A.   Absolutely.

 7        Q.   All right.  Could you look, please, in the B/C/S version, at page

 8     3; and in the English version, it's also page 3.

 9             Under agenda item 6, the last item:  "It has been said at the

10     session that records office had to be established as soon as possible,

11     where information on crimes against Serb people would be collected."

12             Was that something that you decided affected the MUP and had to

13     be transmitted to Mr. Stanisic?

14        A.   That session did not adopt the decision to establish that,

15     because it was up to the government to establish it.  It was just noted

16     that this record office should be established, and I told the minister

17     that it is likely going to happen because the government intends to have

18     it established.  Once the government establishes that, they would also

19     designate the persons responsible for gathering information, et cetera.

20             This is just an expression of intention.

21        Q.   And who would be the persons responsible for gathering

22     information on these crimes?  What organisation?

23        A.   Any institution that could contribute.

24        Q.   Well, who was responsible for the investigation of crimes,

25     please, Mr. Skipina?  Which body?

Page 8349

 1        A.   Well, it could be the Ministry of the Interior, the Ministry for

 2     Refugees, the Ministry of National Defence.  A number of institutions

 3     would have to work together to establish such documentation or a

 4     documentation bureau.  Everyone would have to contribute.

 5        Q.   Did the -- did the Ministry for Refugees investigate crimes?

 6        A.   The Ministry of Refugees could receive information from refugees

 7     that war crimes had been committed against family members or others in

 8     places where these refugees used to live.

 9        Q.   Did it come as any surprise to you that apparently the only

10     information that was going to be placed into this records office was

11     crimes against the Serb people as opposed to crimes against non-Serb

12     people?

13        A.   The government was expressing its intention here.  It could

14     express its intention regarding all crimes committed, regardless of the

15     victims.  That would be more just, more fair.

16             But it could also handle crimes against Serbs separately from the

17     others.  The purview of the government is not my purview.

18        Q.   All right.  Thank you.  That's all I ask about that document.

19             Can you quickly, please, look at the session for the next day.

20             MS. KORNER:  Which is document P232.

21        Q.   Again, does -- oh.  I haven't got the English yet.  Yeah.  Does,

22     again, that show you attending in place of Mico Stanisic?

23        A.   Yes.

24        Q.   Where was Mr. Stanisic at this period; do you know?

25        A.   I didn't have the right to keep tabs on the movements of the

Page 8350

 1     minister of the interior.

 2        Q.   Yes, but --

 3        A.   I don't know.

 4        Q.   Sorry, I interrupted you.  When he rang you to say, Please attend

 5     these meetings instead of me, did he explain why he wasn't going to be

 6     there?

 7        A.   He was not obliged to explain to an underling why he would not be

 8     attending.  On the contrary, the underling is under the obligation to

 9     carry out his orders, unless they were unlawful.

10        Q.   All right.   Could you look, please, here at the the fifth page

11     in B/C/S, and I think it's the sixth page in English.

12             All right.  The top of the -- I'm not sure if it's the top of the

13     page in B/C/S but in English it's the top of the page.  I think it is

14     close to the top of the page:

15             "It is being concluded that the Ministry of the Interior prepare

16     a report on the work of the National Security Service and the Public

17     Security Service and propose measures for a more efficient functioning."

18             Is that something that you passed on to Mr. Stanisic?

19        A.   I had to report something like that.

20        Q.   All right.  And could you look, please, at the -- for English you

21     need to go onto the next page but in B/C/S, it's the same page.

22             MS. KORNER:  No, sorry, it's the next page in B/C/S as well.  So

23     sorry.  Just before we get to the end of the document.  So the next page

24     in both.

25        Q.   Now, at the very end of this meeting apparently it says:

Page 8351

 1             "The government has concluded that all measures be taken promptly

 2     for a more efficient work of the Republic Commission for the exchange of

 3     prisoners.  With regard to this fact, it is necessary to secure the

 4     accommodation and other conditions according to a previous decision of

 5     the government ..."

 6             Were you aware of the Republic Commission for the exchange of

 7     prisons?

 8        A.   While I was conducting those exchanges I don't think that

 9     commission existed.

10        Q.   No.  But before you attended this meeting in June, were you aware

11     that this commission had been set up?

12        A.   No.

13        Q.   Did you pass that piece of information onto Mr. Stanisic?

14        A.   It says the Ministry of Justice is in charge.  That's what the

15     document says so I'm not sure.  I cannot say with any certainty whether I

16     informed Stanisic.   It was 20 years ago.  I can't be so sure whether I

17     reported this part.  I'm just not sure.

18        Q.   Now, you described your relationship with Mr. Stanisic as --

19     sorry, I need to go back to get his exact words.

20             What you said was - when I asked you whether he explained why he

21     wasn't going to be - "he's not obliged to explain to an underling why he

22     would not be attending.  On the contrary, the underling is under the

23     obligation to carry out his orders, unless they were unlawful."

24             Now can you ask you in relation to that, first, what was Mico

25     Stanisic's attitude to the giving of information to people in the

Page 8352

 1     government, for example, people in your position?

 2        A.   Right at the very beginning when the MUP just started operating,

 3     Minister Stanisic explicitly forbade everyone to provide information to

 4     the leadership of the Republic or to the government without informing him

 5     and consulting him first, and it was his right to do that.

 6        Q.   All right.  What about the appointment of people within the MUP?

 7     Could appointments be made without his authority?

 8        A.   I can guarantee for the National Security Service that in case of

 9     each appointment and there were not many positions, Mr. Stanisic was

10     consulted, and gave his approval.  Whether it was possible to appoint

11     anyone in public security stations without his approval, I don't know.  I

12     know that when he came into office there were many staff already there in

13     the SJBs, people earlier appointed by the local authorities, and, in many

14     cases, those were people who simply didn't belong with the Ministry of

15     Interior.

16             Whether Minister Stanisic had the authority to replace them or

17     not, I have one example from Pale.  When he said, I'll replace Malko

18     Koroman, chief of the public security station, I don't why, it's just

19     something that he said before a number of us who were gathered.  He said,

20     I will replace that man.  And the next day a rally occurred suddenly at

21     Pale organised by Malko Koroman, the entire police force turned out as

22     well as many of the regular citizens.  There were many people and when

23     Mico Stanisic received the report, he said to me, Go there, Slobo, and

24     see what these people want.  I told him, You have the chief of the public

25     security sector, you have an assistant for the police force, and you

Page 8353

 1     yourself can do it.  It's not my job.  I have nothing to do with the

 2     police.

 3             So Minister Stanisic eventually went to that rally.  I don't know

 4     what was said there, what happened.  In any case, Malko Koroman remained

 5     the chief of that station, and I suppose, therefore, that

 6     Minister Stanisic was unable to replace them.

 7        Q.   Did you hear about Malko Koroman committing crimes?

 8        A.   I did not hear about him committing crimes, but there were many

 9     stories that implicated him in the smuggling of cars.

10        Q.   But Mico Stanisic did not remove him from his position as chief

11     of the SJB?

12        A.   I don't know.  I'm telling you what I know, the information that

13     came to my ears.  Whether he was unable to replace him or what actually

14     happened, I don't know.

15        Q.   All right.  Now you knew Mr. Djeric, didn't you, the prime

16     minister?

17        A.   Yes.  I knew him before the war.

18        Q.   Was there ever a time when you disobeyed Mr. Stanisic's

19     instructions and went to speak to Mr. Djeric directly together with

20     Mr. Planojevic?

21        A.   On two occasions Mr. Djeric invited me to have coffee with him

22     and although we knew each other well, I refused both times, because I

23     didn't want the minister to find out about it although I was not going to

24     reveal any information.

25             On one occasion, I can't remember the details, we were in the

Page 8354

 1     building of the government, myself and Dobro Planojevic, assistant

 2     minister for crime.  We were invited to have coffee with Djeric, and we

 3     talked about all sorts of things.  We discussed also the high incidents

 4     of crime.  We also said that this -- these goods should not be allowed to

 5     get into the hands of criminals, that are any goods that were seized

 6     should be placed with commodity reserves and used later to supply

 7     refugees.  We said that we should form a directorate for commodity

 8     reserves, find a warehouse and appoint a commission to distribute food,

 9     that resources should be found to open soup kitchens for refugees,

10     et cetera, and on that occasion he told us, considering that there are

11     few ministers in my ministry who had worked in state agencies before,

12     they have little experience, would you make me a draft document, a rough

13     document about what the government should do for the refugees?  So I sat

14     down and wrote what should be done for the refugees to protect the

15     property of citizens and various businesses that had been robbed.  There

16     were many such cases.  Goods would be taken overnight from a company

17     warehouse and taken God knows where.

18             We put all this on a piece of paper.  Djeric took it and put it

19     in his pocket, and we parted ways.  Otherwise, we didn't provide any

20     information in the sense of reports to Mr. Djeric.

21        Q.   Well, first of all, can I ask you about the property of citizens

22     and various businesses that are robbed.

23             Are we talking about non-Serb property that was being looted or

24     set on fire?

25        A.   The criminals didn't distinguish whose property it was, whether

Page 8355

 1     it belonged to Serbs or Bosniaks.  Whatever they put their hands on, they

 2     stole.

 3        Q.   And why was Mr. Djeric asking you, as head of the intelligence

 4     department, and Mr. Planojevic as -- he was head of the crime section,

 5     wasn't he?

 6             Why was he asking you two, the senior, senior police officers to

 7     talk about a collection centre, a warehouse for refugees?  To collect

 8     looted goods - sorry - and deal with refugees?

 9        A.   Because we said that the refugees in Pale were in a difficult

10     condition.  They were on the move, nobody was providing any assistance.

11     They had no shelter, no food.  We said that it was the task of the

12     government to open up soup kitchens and to provide all the aid to the

13     population.  A lot of population fled from Sarajevo, and the first stop

14     was Pale, and there were also people from Zenica, from Central Bosnia.

15     It was horrendous, and nobody was taking care of the refugees.

16             So that was the reason why we did it.  We didn't go to see him

17     intending to say that.  It's just that he saw us, and he took us to

18     coffee, and we talked to him about it, and then he said, Why don't you

19     write this for me?  Not a lot of my ministers have previous government

20     experience, and they don't really feel what it means to work for the

21     government, so why don't you two writing something for me.

22        Q.   Did you know Dr. Kalinic the minister of health?

23        A.   Yes.  But not that well.  I knew him, but -- his brother worked

24     in my service before the war SNB.  And then he moved to Belgrade and

25     worked for the SNB in Belgrade.

Page 8356

 1             So I knew Kalanic but not really well, not close.

 2        Q.   [Previous translation continues] ... wasn't that job more for him

 3     than for you two senior officers in the police?

 4        A.   Perhaps he asked the same from Kalanic later on.  At any rate,

 5     Kalanic's ministry belonged to the government as well.

 6        Q.   So Mr. Djeric and Mr. Stanisic didn't get on, did they?

 7        A.   It's hard for me to say that.  All I know is that they were not

 8     on good terms.  When Mr. Djeric, sometime in the fall, when I was no

 9     longer head of the service, in an Assembly session when Djeric was

10     removed or he resigned that at that session Minister Stanisic said

11     something against Djeric based on which I concluded that they were not on

12     good terms since Stanisic said that about him.  But I can't really be an

13     authority on this.  I never met with the two of them face to face to

14     discuss this.

15             It's very hard to ask me, whether they were on good terms.  I'm

16     not a reliable source of information on that question.

17        Q.   All right.  Finally, did you ever have any meetings with

18     Mr. Djeric when the question of police officers committing crimes was

19     being discussed, you and Mr. Planojevic?

20        A.   Which police officers committing crimes?

21        Q.   Police officers, members of the MUP being involved in crime.  Did

22     you ever discuss that with Mr. Djeric?

23        A.   Well, there is a difference between looting or robbery and a

24     crime committed against people.  That what's you said, didn't you?

25        Q.   I'm asking you whether you ever discussed with Mr. Djeric and

Page 8357

 1     Mr. Planojevic, at the same time, the matter that police officers were

 2     committing crimes such as thefts, looting, and robbery, those sort of

 3     crimes?

 4        A.   It's possible that we mentioned it at the time.  For example, it

 5     was public knowledge in Pale that there were policemen or criminals who

 6     were active with Golf vehicles so it is possible that we mentioned that,

 7     but I can't really be certain that I talked to prime minister about it.

 8     It's been 20 years.

 9             I know that I talked to him on the 3rd of July when I resigned.

10     That was the only meeting with Djeric that I had when Dobro Planojevic

11     and I went to see him.

12        Q.   So you went to see him at that time.  You tell us there was a

13     discussion about the warehouse for looted goods, and the second time you

14     and Planojevic went to see him was when you resigned on the 3rd of July?

15        A.   Yes, that was the second time without mentioning two government

16     cabinet sessions when I only attended but had no contact with him.

17             So the only contact was with Planojevic, and the second time was

18     when I resigned.

19        Q.   Right.  On that second occasion, did you complain to him that

20     police officers were committing crimes and not being either disciplined

21     or prosecuted?

22        A.   I did not speak about the crimes.  I didn't know.  I didn't have

23     information about police committing crimes, so I didn't speak about

24     crimes.

25             Now, as for criminal activity of individuals, it's possible that

Page 8358

 1     I mentioned that, saying that more needs to be done about it and that

 2     other organs need to get involved because the ministry could not be the

 3     only one working on it and so on.  He told me that he knew about that,

 4     that criminal activities were rampant, that he knew that some of his

 5     ministers were involved in theft and that he couldn't do anything about

 6     it, that he had no authority over them because he had not appointed them,

 7     in fact.  The ministers had been appointed by Mr. Krajisnik and Mr.

 8     Karadzic.

 9             On that occasion, he also complained especially about Karadzic

10     and Krajisnik about them pushing him aside, and not letting him do

11     anything, that the government is supposed to be in charge of foreign

12     policy, yet he was not really consulted by them on those issues.

13             So that -- he mentioned those things.

14        Q.   I will come back in a moment to the ministers involved in crime.

15             But why didn't you speak to Mr. Stanisic about the fact that more

16     needed to be done about the people committing crimes and, in particular,

17     police officers?

18        A.   If I were to tell you that I did not have a single piece of

19     information about what the public security department had done about

20     preventing and prosecuting those who committed crimes, I couldn't tell

21     the minister whether more needed to be done or less needed to be done.

22     In general, it is always more that needs to be done.

23             Now what we had to see was which public security station was

24     willing to do that, which one was knowledgeable enough to do that, which

25     of their members were involved in those things because I'm telling you, a

Page 8359

 1     lot of them did not feel that they belonged to the MUP.  They just took

 2     advantage of that opportunity.  By being members of the SDS, they were

 3     appointed as commanders and chiefs of police stations so it is

 4     questionable.  It is also questionable to which extent the army was

 5     involved and how equipped and what manpower police had, and so the

 6     greatest part of problems was within the domain of SJBs.  CSBs and the

 7     MUP provided technical assistance.  They couldn't really gather evidence

 8     and documents.  They couldn't get involved directly.  That's how the

 9     responsibilities and authorities had been set up.

10        Q.   Not five minutes ago, if you told the Court when I asked you

11     about meetings with Mr. Djeric when you and Mr. Planojevic went to see

12     him and about mentioning crime you said:  "It's possible that we

13     mentioned it at the time.  For example, it was public knowledge in Pale

14     that there were policemen or criminals who were active with Golf vehicles

15     so it is possible that we mentioned that ..."

16             Now, if you were going mention it to the prime minister, as you

17     did when you resigned, why didn't you mention this to Mr. Stanisic?

18        A.   There was chief of SJB in Pale, there was assistant minister for

19     general crime, so it was least up to me to inform the minister about the

20     crime.  It was not my responsibility whatsoever.

21        Q.   But you informed Mr. Djeric who could do less, surely, than the

22     minister of the interior.

23        A.   I'm telling you again that in an unrelated conversation about

24     refugees we touched upon that topic as well, how there were criminal

25     activities and how funds and resources could be secured for refugees that

Page 8360

 1     way.  So we didn't go there to inform him about the crime and what was

 2     happening.  It's just that we met him in the hallway and since he knew

 3     both of us he invited us to have coffee.  Had it been just me alone I

 4     would not have gone to have coffee, but since there were two of us --

 5        Q.   All right.  You've told us that already.  And, finally, I think

 6     probably the last question for today, you said that Mr. Djeric was

 7     complaining that his ministers were committing crimes.  Which ministers?

 8        A.   He said that he had information that some of his ministers were

 9     involved in crime but that he could do nothing against them without

10     giving anyone's name individually.

11             I wasn't on such close terms with Mr. Djeric, prime minister, to

12     have him tell me exactly which minister was involved in theft.

13        Q.   All right.

14             MS. KORNER:  Your Honours, that's probably ...

15             JUDGE HALL:  Yes.

16             Mr. Skipina, we are about to take the adjournment for today.

17     You, having been sworn as a witness, cannot communicate with counsel from

18     either side, and in such conversations as you may have with anybody

19     outside of the Chamber, you cannot discuss your testimony.

20             So we will resume in this courtroom at 9.00 tomorrow morning.

21             Before we adjourn, the -- I would alert Defence counsel that

22     the -- we are in receipt, as council would be aware, of a motion

23     yesterday from the Prosecution with respect to witnesses due to testify

24     in April, and we would wish to have your expedited oral responses by the

25     time we wind up tomorrow or Thursday, so I am alerting you to that now.

Page 8361

 1             So we take the adjournment until tomorrow morning at 9.00.

 2                           [The witness stands down]

 3                            --- Whereupon the hearing adjourned at 1.48 p.m.,

 4                                to be reconvened on Wednesday, the 31st of

 5                                March, 2010 at 9.00 a.m.