Tribunal Criminal Tribunal for the Former Yugoslavia

Page 10706

 1                           Tuesday, 25 May 2010

 2                           [Open session]

 3                           [The accused entered court]

 4                           --- Upon commencing at 9.09 a.m.

 5             THE REGISTRAR:  Good morning, Your Honours.

 6             Good morning to everyone in and around the courtroom.

 7             This is case IT-08-91-T, the Prosecutor versus Mico Stanisic and

 8     Stojan Zupljanin.

 9             JUDGE HALL:  Good morning -- thank you, Madam Registrar.

10             Good morning to everyone.

11             May we have the appearances for today, please.

12             MR. OLMSTED:  Good morning, Your Honours.  Matthew Olmsted,

13     Joanna Korner, and Crispian Smith for the Prosecution.

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

15     Slobodan Cvijetic, Eugene O'Sullivan, and Ms. Tatjana Savic appearing for

16     Stanisic Defence this morning.  Thank you.

17             MR. KRGOVIC:  Good morning, Your Honours.  Dragan Krgovic for

18     Zupljanin Defence.

19             JUDGE HALL:  Thank you.  And if there is nothing to delay us ...

20             Yes, Mr. Olmsted.

21             MR. OLMSTED:  Sorry, Your Honour, I just want to raise that we do

22     have a pending motion to amend our 65 ter exhibit list.  Two of the

23     documents subject to that motion we will want to show this witness.

24     There was a SNB -- a state security payroll document as well as an

25     extended video footage of the Banja Luka Security Day Parade back in

Page 10707

 1     1992, and we're wondering whether we could get a ruling on that before

 2     the witness is called.

 3             JUDGE HALL:  I noticed you said "show."  I take it you use that

 4     word deliberately, in contrast to "exhibit through"?

 5             MR. OLMSTED:  No, we would tender it through that witness as well

 6     because this witness -- we're nearing the end of our case, particularly

 7     with regard to Banja Luka, and so I think this is the appropriate witness

 8     to tender those two exhibits through.

 9                           [Trial Chamber confers]

10                           [Trial Chamber and Legal Officer confer]

11             MR. OLMSTED:  Your Honours, if I may point out just one thing.

12     I'm not sure you had a chance to fully review our submission, but both of

13     these documents we only recently discovered through a search of the

14     records at the CSB Banja Luka, and upon getting them here, getting them

15     into the evidence unit, we had a very short time-frame.  And that is why

16     we filed the motion last week.  So, really, it was the soonest point

17     possible to file that submission.

18             JUDGE HALL:  Is the Defence in a position to respond to this at

19     this moment?  I know from -- as Mr. Olmsted has said, that you are not --

20     the question of time is with you.

21             MR. ZECEVIC:  Your Honours, we -- we would -- just for the -- we

22     don't want to complicate things further, we just wanted that our

23     objection be recorded as an objection, because of the -- of the lack of

24     time.  I mean, it was -- it was only a week before -- before this witness

25     comes, and -- and the documents have been given to us.

Page 10708

 1             But, on the other hand, if this is the situation, that -- that

 2     our friends from the OTP are facing, we -- we -- there is not much we can

 3     say on that, of course.  And that is why we want just that our objection

 4     be recorded.  Thank you.

 5             JUDGE HALL:  Yes.  But your objection in terms of time --

 6             MR. ZECEVIC:  Yep.

 7             JUDGE HALL: -- We understand as a matter of fact it would be

 8     taken for granted.  What I was asking is whether you are in a position to

 9     indicate whether you have an objection on the -- on other grounds, in

10     terms of relevance and the -- the -- the other grounds in which an

11     objection could be taken.

12             MR. ZECEVIC:  No, Your Honours, we don't.

13             JUDGE HALL:  Yes.

14             Mr. Krgovic.

15             MR. KRGOVIC: [Interpretation] Your Honours, we would like to

16     support what Mr. Zecevic told.

17             On Friday I had an opportunity to show this video to my client,

18     so, in principle, we cannot provide any detailed submission regarding

19     relevance.

20             Concerning this parade, we have seen quite a few videos on that.

21     So I'm afraid that it might end up in duplicating evidence.  I think we

22     have seen enough about the parade.  And we heard a lot of evidence.  And

23     this video is -- has indeed been admitted into evidence.

24             MS. KORNER:  I'm sorry, Your Honours, can I just take over for

25     this aspect alone.

Page 10709

 1             Your Honours, we disclosed this as soon as we got it.  We didn't

 2     even have a translation.  The reason that the -- the filing of the motion

 3     was only last Tuesday was literally because we got the material, I think,

 4     very shortly before that.

 5             I don't know why Mr. Krgovic hasn't shown it to Zupljanin, but

 6     that's a matter for him.

 7             It is a video that not only shows the speeches, which we did not

 8     have before, at the parade.  It shows the people who are sitting at the

 9     podium.  And, if I put it this way, it's the great and the good of the

10     Republika Srpska.

11             And so, Your Honours, we did everything we could as quickly as we

12     could.  For once it was only real investigation by the OTP because

13     requests were made for this in advance to produce these documents.

14             So, Your Honours, with that in mind, we hope you'll assent to the

15     motion.

16             MR. ZECEVIC:  If I may just shortly comment.

17             Your Honours, we have -- we have a video of the parade already as

18     an exhibit.  There is no dispute between the parties that there was an

19     assembly of the Republika Srpska with all the president and the

20     Presidency and all the -- all the parliamentaries on that particular date

21     in Banja Luka.  That is -- that is not in dispute.

22              I mean ... I just wanted to raise that.

23                           [Trial Chamber confers]

24             JUDGE HALL:  We note the Defence objection and accede to the

25     application by the OTP to amend its 65 ter list in respect of the two

Page 10710

 1     items in respect of which Mr. Olmsted has given details.

 2             MR. ZECEVIC:  I'm sorry, I do have one -- one small preliminary

 3     matter.  I announced it.  If I may be heard on --

 4             JUDGE HALL:  Yes.

 5             MR. ZECEVIC:  Your Honours, the Defence had a brief interview

 6     with the coming witness yesterday in the presence of Mr. Olmsted and the

 7     other people from the -- from the Office of the Prosecutor.  During the

 8     interview, despite the fact that the witness is a lawyer by profession,

 9     I'm -- I'm -- it is my -- it is my opinion that he is not aware of the

10     consequences of his -- possible consequences of his testimony over here.

11     In respect to the -- to his status of the suspect and the -- the state of

12     affairs in the -- in the court of Bosnia and Herzegovina.

13             Therefore, I would -- it is just out of the professional courtesy

14     that I wanted to raise this with the Trial Chamber, and I think the

15     Trial Chamber should inform him of the -- of the Rule 90(E), because he

16     should be informed about that.  My impression was that he wasn't really

17     informed about what are his rights and what are the possible

18     consequences.  And being a fellow lawyer, I thought that this is -- this

19     is absolutely my duty to raise this with the Trial Chamber.

20             Thank you very much.

21             JUDGE HARHOFF:  Thank you, Mr. Zecevic.

22             It would normally be for the party calling the witness to raise

23     this issue, so let's hear from Ms. Korner.

24             MS. KORNER:  Your Honours, this is actually a remarkable day

25     because 90 per cent of the time the complaint of the Defence is that we

Page 10711

 1     interview these people as suspects, we therefore terrorise them into

 2     giving evidence, and when the boot is on the other foot there's a

 3     complaint.

 4             Your Honours, we have interviewed the next witness not as a

 5     suspect.  He is, as Mr. Zecevic points out, a lawyer.  He is a practicing

 6     lawyer and is fully aware of his rights.  If Your Honours feel there is a

 7     time when he needs to be advised that he need not say anything that may

 8     incriminate him, then I have no doubt Your Honours will see that point

 9     and give him the warning.  But, at the moment, we see no reason why he

10     should be given any such warning.  And it may well be that the reasons

11     why the Defence want him to be given a warning are perhaps not in the

12     interests of justice.

13             JUDGE HARHOFF:  Thank you, Ms. Korner.

14             I didn't understand Mr. Zecevic's comment as a complaint but,

15     rather, and truly as a professional attempt to support the Court.  But

16     thank you for this.

17             I think the proper way to proceed is to remind the witness of --

18     of the situation covered by Rule 90(E), if and when the situation arises.

19             So let's just take it from there.  If there's a risk that the

20     witness is going to provide information that might incriminate him in

21     other proceedings, then we will address the issue.

22             Is that okay with you, Mr. Zecevic?

23             MR. ZECEVIC:  Your Honours, I read the -- I read the interview

24     yesterday.  He was interviewed as a suspect.  And Ms. Korner was

25     interviewing him, as a matter of fact, in 2009, in March, 24th and 25th.

Page 10712

 1     This is one thing.

 2             And the second thing:  Your Honours, I stated what my reasons are

 3     for this, and I resent the comment of Ms. Korner on that subject.  I

 4     stated very clearly what is my -- what I feel is my professional duty to

 5     raise this -- this issue with the Trial Chamber.

 6             And the third thing, we never ever, the Defence of Stanisic never

 7     ever raised the issue of -- of interviewing the witness as a suspect.  We

 8     understand that it -- it's the possibility that the OTP has.

 9             Thank you very much.

10             JUDGE HARHOFF: [Microphone not activated] Bring in the witness.

11                           [The witness entered court]

12             JUDGE HARHOFF:  Good morning to you, sir.

13             THE WITNESS: [Interpretation] Good morning.

14             JUDGE HARHOFF:  Do you understand me?

15             THE WITNESS: [Interpretation] Yes.

16             JUDGE HARHOFF:  Thank you very much.

17             Would you be good enough to read the solemn declaration.

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

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

20                           WITNESS:  PREDRAG RADULOVIC

21                           [Witness answered through interpreter]

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

23             THE WITNESS: [Interpretation] Thank you.

24             JUDGE HARHOFF:  First of all, good morning to you, and welcome to

25     the Tribunal, and thank you for coming to give your testimony today.

Page 10713

 1             You have been called as a witness by the Prosecution, who is

 2     sitting to your right, in the trial against Stojan Zupljanin and

 3     Mico Stanisic, who is sitting to your left.

 4             You have been called as a witness viva voce, and the Prosecution

 5     will begin by asking you some questions.

 6             But before we get to that, sir, I would like you to state your

 7     name and date of birth.

 8             THE WITNESS: [Interpretation] My name is Predrag Radulovic.  I

 9     was born on the 13th of September, 1952.

10             JUDGE HARHOFF:  Thank you very much, sir.

11             And what is your profession?

12             THE WITNESS: [Interpretation] I have a university degree in law,

13     and I'm a practicing lawyer.

14             JUDGE HARHOFF:  Thank you.

15             And what was your occupation in 1992?

16             THE WITNESS: [Interpretation] I was an employee of the

17     State Security Service.

18             JUDGE HARHOFF:  Where -- sorry.  In -- where did you serve and in

19     which capacity?

20             THE WITNESS: [Interpretation] In Banja Luka, in the capacity of

21     an inspector in the State Security Service.

22             JUDGE HARHOFF:  Thank you very much.

23             And, sir, what is your ethnicity?

24             THE WITNESS: [Interpretation] I have been declaring myself as a

25     Yugoslav, until this was rendered impossible by an administrative ban.  I

Page 10714

 1     am of the Serbian descent, and this is how I declare myself nowadays.

 2             JUDGE HARHOFF:  Thank you very much.

 3             Mr. Radulovic, did you ever -- or have you ever testified before

 4     this Tribunal?

 5             THE WITNESS: [Interpretation] No, I haven't.

 6             JUDGE HARHOFF:  And have you testified in other trials in your

 7     home country or elsewhere in relation --

 8             THE WITNESS:  [No interpretation]

 9             JUDGE HARHOFF: -- to crimes committed during the war?  If so, do

10     you remember the persons who were indicted in the trials in which you

11     gave testimony?

12             THE WITNESS: [Interpretation] Yes.  Unfortunately, I was the

13     indictee, and criminal proceedings were conducted against me, starting in

14     1992 until 2001, on the grounds that it is stated in the indictment that

15     I had been undermining the combat spirit of Republika Srpska by spreading

16     brotherhood and unity in Republika Srpska and Bosnia and Herzegovina by

17     releasing non-Serbs from detention facilities and camps.

18             In 2001, the proceedings were suspended due to the lack of

19     evidence and because the county prosecutor of Doboj decided not to

20     prosecute the matter further.  I last appeared before the court in 2001

21     or 2002 with regard to these proceedings.  Never again after that was I

22     either an indictee, a suspect, or did I appear in any other capacity, not

23     even as a witness, with regard to anything that had to do with the war

24     and the consequences of the war.

25             JUDGE HARHOFF:  Thank you, sir.

Page 10715

 1             Do you know if the proceedings against you have been altogether

 2     suspended, or are they still pending?

 3             THE WITNESS: [Interpretation] I have been notified by the

 4     County Prosecutor's Office that the proceedings against me were truly

 5     terminated or suspended.  I have to say that I never received a decision

 6     to that effect, so formally and legally speaking, I cannot say firmly

 7     that -- whether it was only suspended or terminated.

 8             JUDGE HARHOFF:  Thank you for this.

 9             As I told you before, Mr. Radulovic, you're being called here to

10     testify viva voce.

11             And the Prosecution has asked for how much time?

12             MR. OLMSTED: [Microphone not activated]

13             JUDGE HARHOFF:  For eight hours.

14             MR. OLMSTED: [Microphone not activated] You were giving -- you

15     granted us eight hours.

16             JUDGE HARHOFF:  Thank you very much.

17             The Prosecution will examine you in-chief for eight hours

18     altogether.

19             And the Defence counsels have asked for how much in cross?

20                           [Trial Chamber and Registrar confer]

21             MR. ZECEVIC:  Six hours.

22             JUDGE HARHOFF:  I'm being told -- thank you, Mr. Zecevic.

23             I'm being told that the Defence counsel for Mr. Stanisic has

24     asked for six hours.  And the Defence for Mr. Zupljanin have asked for

25     four and a half hours.

Page 10716

 1             This will keep us occupied for the next couple of days.  We will

 2     begin the trial every morning here in this courtroom, I think, at 9.00.

 3     And we have to adjourn the proceedings every 90 minutes because the tapes

 4     have to be changed.  So every one hour and a half we will have to have a

 5     break of approximately 20 minutes.

 6             Mr. Radulovic, if at any time you wish to put a question to us or

 7     if you have any comments to make, then please do not hesitate to contact

 8     us, and we will address your concerns immediately.  And finally, I should

 9     remind you that you have taken the solemn declaration and that there is

10     an severe penalty for providing false or incomplete information to the

11     Tribunal.

12             That's all I have to say.  Do you have any questions at this

13     time?

14             THE WITNESS: [Interpretation] Yes.  It's clear to me.  I'm

15     relatively familiar with the protocol of the ICTY, but identical rules

16     are in force in the country from which I come.

17             JUDGE HARHOFF:  Thank you very much, Mr. Radulovic.

18             Let's get on with it.  I give the floor to the Prosecution.

19                           Examination by Mr. Olmsted:

20        Q.   Good morning, Mr. Radulovic.

21        A.   Good morning.

22        Q.   You were interviewed as a witness by the ICTY Office of the

23     Prosecutor on a number of occasions last year; is that correct?

24        A.   Yes, it is.

25        Q.   And the information that you provided during those interviews

Page 10717

 1     were -- was consolidated into a written statement which you signed on the

 2     5th of December of last year; is that correct?

 3        A.   Correct.

 4        Q.   And I see that you brought that written statement with you; and,

 5     if, necessary, let us know if you need to refer to it.

 6             In the last year, have you been contacted by counsel for either

 7     of the accused in this case?

 8        A.   By telephone.  He wanted to know whether I would be willing to be

 9     Mr. Zupljanin's witness, after the conversation that I had previously had

10     with Mr. Zupljanin from the Detention Unit.

11             I told him then that I was already short-listed as an OTP

12     witness.

13        Q.   And was that Mr. Pantelic who called you?

14        A.   Yes, Mr. Igor Pantelic.

15        Q.   And you mentioned that the accused, Stojan Zupljanin, contacted

16     you directly.  Can you tell us approximately when he gave you that call?

17        A.   It may have been a few months after he had been detained.  I took

18     that as something normal, because I had known Mr. Zupljanin before the

19     war.  But more specifically, I got to know him better once the war

20     started because he was my superior, my highest ranking superior in the

21     area of the SDB in Banja Luka.  So I considered that something normal.

22     So if he contacted me before the OTP, I certainly would have consented to

23     be his witness.  There's a saying in my country:  Whoever approaches the

24     girl first, she'll be his.

25        Q.   And were you also contacted by any investigators for the Defence

Page 10718

 1     last year?

 2        A.   Twice directly and once over the phone.  Initially the

 3     investigation team had the idea of my joining them, but since I had

 4     already had contact with the OTP, I naturally refused.

 5             After that, there was another occasion to talk to a member of the

 6     investigation team.  He wanted to know whether I had any private

 7     documentation about crimes or war-time events in Bosnia-Herzegovina as a

 8     whole, and that was all.

 9             One of the investigators had worked with me for a long time in

10     the National Security Service.  I consider him a friend.  I don't think

11     he did anything that could affect my statement or my testimony before

12     this Tribunal.

13        Q.   I want to begin with briefly going over your professional

14     background.

15             When did you join the police?

16        A.   I graduated from the Faculty of Law in Belgrade and immediately

17     after graduating -- or, rather, after two or three months of vacation, in

18     November of 1976, I took employment with the inter-municipal SUP in Doboj

19     as an inspector for violent crime as well as sexual offences and illicit

20     trade in narcotics and weapons and explosive devices.

21             I worked for the inter-municipal SUP which was later transformed

22     into a regional SUP for four years, after which, based on an agreement

23     between the SJB and the SDB, I was transferred to the SDB centre in

24     Doboj, and that was in 1980.

25             Do you need any more?

Page 10719

 1        Q.   Yes.  In fact you anticipated my next couple of questions which

 2     is fantastic.  But I ask that you try to keep your answers short and let

 3     me ask the questions that lead into the next issues.

 4             You joined the State Security Service at Doboj.  What was your

 5     position in the SDB?

 6        A.   I took employment with the SDB in Doboj in the intelligence

 7     department.  I -- my work consisted in collecting operative intelligence

 8     relevant for security of my then country, the SFRY.

 9        Q.   In 1987, you transferred to the SDB in Banja Luka.  Can you

10     explain to us why you transferred to Banja Luka?

11        A.   Of course.  But a transfer may not be the best use of term.  I'm

12     not an object that is transferred somewhere.

13             I went to Banja Luka pursuant to my own application to get a job

14     with the SDB, and I was in the position to choose, myself, where in the

15     former Yugoslavia I wanted to work for the SDB.  I chose Banja Luka

16     because I had a professional conflict with those who were covering up

17     some events, and I didn't want to be part of that.

18             Later on, I was rewarded by being offered the opportunity to

19     choose my next position, in which centre.

20        Q.   What position did you hold at the SDB in Banja Luka?  What was

21     your title?

22        A.   In Banja Luka, I was a senior inspector; and, later on, a chief

23     inspector.

24        Q.   And within the SDB at CSB Banja Luka, what unit did you work?

25        A.   That was line 01, intelligence.

Page 10720

 1        Q.   And what sort of intelligence did 01 collect?

 2        A.   I can tell that, although I don't have to because this

 3     falls under my discretionary right.  The things I was in charge with were

 4     considered state secrets.  But since my state is no longer in existence

 5     and nothing is so secret anymore, I can tell you that I collected

 6     intelligence about trans-border activities of foreign intelligence

 7     services and the security of interesting persons who jeopardised the

 8     security of my country from without.

 9        Q.   And how long did you remain with SDB in Banja Luka?  When did you

10     finally leave that position?

11        A.   I remained until the end of 1994, when I joined the SDB of

12     Serbia.

13        Q.   In 1992, were you a leader of an intelligence officer team?

14        A.   One can call it that.  It was a group that consisted of three to

15     five individuals at the most, and the group was not established in 1992.

16     It was in 1991, if we want to be precise.

17        Q.   And what was the name of that team?

18        A.   The group -- the group's code-name was Milos.  We often

19     introduced ourselves by our own first names or initials.  For a while, we

20     also used the pseudonym of Sigma.  And a small amount of information was

21     attributed to code-name Colonel Pukovnik.

22        Q.   Can you tell us why did you operate under a code-name, why did

23     you operate under a pseudonym?

24        A.   Well, these are actually the basics of the business of an

25     intelligence officer.  The basic task of any intelligence man is to

Page 10721

 1     protect himself and the people he works with against being identified,

 2     because of the importance of information that we collected and that we

 3     forwarded to some addresses.  And, honestly speaking, I don't know who

 4     was in the position to read that information and what anybody outside our

 5     service would have to know to be able to attribute that information to

 6     any individual.

 7        Q.   How long did the Milos Group operate?  For how long?

 8        A.   It operated from the 28th of July, 1991.  I remember that day

 9     very well because that day is especially important in the history of the

10     Serbian People.  And the group was disbanded when I joined the SDB of

11     Serbia.

12        Q.   Can you tell us, in 1992, who were the members of the

13     Milos Group?  If you could just list them for us.

14        A.   That's not a secret.

15             JUDGE HALL:  The witness's answer answers the question I was

16     about to raise.

17             MR. OLMSTED:  Yes, and I'm trying not to ask any questions that

18     would be secret or cause any problems though.

19        Q.   So, Mr. Radulovic, if you feel safe to do so, could you please

20     provide us with the names of the operatives who worked for the

21     Milos Group in 1992.

22        A.   Certainly --

23             JUDGE HALL: [Previous translation continues] ... Mr. Radulovic,

24     may we have a moment, please.

25             Mr. Olmsted, notwithstanding what the witness has indicated, we

Page 10722

 1     wonder ex abundanti cautela whether we should not go into private session

 2     for this.

 3             MR. OLMSTED:  Despite the Latin, I understand what you're saying.

 4     Yes, let's -- why don't we move to a private session.

 5                           [Private session]

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Page 10723

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20                           [Open session]

21             THE REGISTRAR:  Your Honours, we're in open session.

22             MR. OLMSTED:

23        Q.   Mr. Radulovic, who decided which matters the Milos Group would

24     gather intelligence on and report on in 1992?

25        A.   That was determined based on the interests of the SDB.  It had a

Page 10724

 1     programme of work and a plan.  It was a very well-organised service.

 2     There was no need for us to reinvent the wheel.  We had everything in the

 3     rules and the programmes of work of the SDB.  Every -- we only

 4     implemented in practice what was regulated by the rules.  It was up to me

 5     as the chief of that team to assist the importance of some subject with

 6     regard to directing the efforts of the people who worked with me so they

 7     could collect intelligence.  Neither Mr. Kesic nor Mr. Stojan Zupljanin

 8     interfered with that.  I was free to decide what we would do on the

 9     ground and decide on some matters that we considered interesting from the

10     security point of view.

11        Q.   From what sources did the Milos Group collect its intelligence?

12        A.   Certainly, Your Honours, if you allow me, maybe this should be

13     answered in private session, because this information was considered a

14     state secret.  But it's for you to decide.

15             JUDGE HALL:  We go into private session.

16                           [Private session]

17   (redacted)

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 10725











11 Pages 10725-10727 redacted. Private session.
















Page 10728

 1                           [Open session]

 2             THE REGISTRAR:  We're in open session, Your Honours.

 3             MR. OLMSTED:

 4        Q.   In the period between 1 April through 31 December 1992, who was

 5     your direct superior?

 6        A.   Up until 1993, my direct superior was Vojin Bera.  I would like

 7     to emphasise that I intentionally omitted to say "Mr." Vojin Bera.

 8        Q.   And who did Mr. - well, I'll call him Mr. - Mr. Bera report to?

 9        A.   His direct superior was Nedeljko Kesic.

10        Q.   And could you tell us who Mr. Kesic reported to?

11        A.   He reported to Mr. Stojan Zupljanin.

12        Q.   Did he also report to the SNB at the RS MUP level?

13        A.   Who are you referring to in particular?

14        Q.   Well, I think there's been evidence already that at the level of

15     the RS MUP there were under-secretaries for state security.  I think

16     there were a few that were there in 1992.  Would Mr. Kesic report to them

17     as well?

18        A.   Of course.  Kesic reported along the State Security Service line

19     to the under-secretary for the State Security Service or the chief of the

20     State Security Service at the level of the Republika Srpska.

21             Now, there was a change in 1992.  I think Dragan Devedlaka took

22     his place.  There was Skipina after him, if I'm not wrong; then Kijec.

23     So all these people were at higher position than Nedjelko Kesic, and

24     therefore, Kesic had to report to them.  And he was subordinate to these

25     people that I named or, let's say, to the position of the under-secretary

Page 10729

 1     for state security.  I don't know how this particular position was called

 2     at a later stage.

 3        Q.   In 1992, when you and your team gathered intelligence, would you

 4     write reports on the intelligence that you collected?

 5        A.   That was mandatory.  After we identified any security-related

 6     information, we had to record it.  And if it was particularly important,

 7     we provided a shortened version, which was dubbed a dispatch.  The

 8     dispatch contained, most often, an indication that a more detailed report

 9     was to follow.

10        Q.   Between the 1st of April and the 31st of December, 1992, can you

11     just list for us for now, list for us, the police organisational units

12     that you submitted your written reports to.

13        A.   It was my duty and obligation to report my direct superior

14     officer, Vojin Bera.  I did that on a regular basis.  And he actually

15     received every single dispatch and piece of information that I had

16     provided.

17             Honestly speaking, in addition to that, all my reports and

18     dispatches relating to the period that you are interested in were also

19     sent to the State Security Department of Serbia, the section for

20     relations with the Serbs without the home country.

21             I don't know if you would like to know more about this.  Please

22     feel free to ask me.

23        Q.   In a bit.

24             Would your reports also, at least under the existing procedures,

25     go up the chain of command to the SNB at the RS MUP level in Pale?

Page 10730

 1        A.   I know how this was done, pursuant to the rules of service.  But

 2     I didn't have a chance to check that.  I was never in a situation to

 3     verify whether all my reports and information were sent further on, not

 4     only to Vojin Bera.  I even don't know whether Vojin Bera passed this

 5     information to his superior, Nedeljko Kesic.  But if I tried to think

 6     logically, and I know how the service operated, and I know, from

 7     practice, some of my reports ended up at Pale, I can only assume that

 8     this was done through regular channels in the service.  However, whether

 9     any of this information or these reports were halted, I don't know.

10        Q.   In addition to your written reports, did you have meetings or

11     briefings with Mr. Kesic regarding your intelligence reports that you

12     created?

13        A.   To tell you the truth, I did, relatively frequently, and

14     particularly when events took place that had grave consequences in

15     relation to security.  We always tried to provide more detailed and --

16     and a more accurate report, an oral report, to Mr. Kesic, or if you want

17     to call it "directly."

18        Q.   And you've mentioned event -- you particularly had meetings with

19     Mr. Kesic regarding events that had grave consequences in relation to

20     security.

21             Would that include intelligence you gathered concerning crimes

22     against the non-Serb population in 1992?

23        A.   Of course.  Excuse me, but I have to say this.  I made no

24     distinction whatsoever between Serb and non-Serb victims.  I am not

25     Boris Tadic.  In my view, all the victims enjoyed the same status, and I

Page 10731

 1     have equal respect to all of them, and I think that these are all tragedy

 2     figures.  I'm not offended by the question you put to me, but I can say

 3     that really, in that respect, we were passivists, and we tried to that be

 4     as much as was possible at the time.

 5        Q.   How did the CSB chief Mr. Zupljanin receive information contained

 6     in your intelligence reports?

 7        A.   Stojan Zupljanin, the chief, received our reports and information

 8     through Vojin Bera and Nedeljko Kesic.  As far as I know, this was done

 9     at their expert staff meetings.  But I'm not sure whether all pieces of

10     information or the extent of the information that reached

11     Stojan Zupljanin.  I know that, concerning certain specific events, I

12     directly got in touch with Stojan Zupljanin.  I remember when that

13     happened for the first time.  And, of course, there was several of them.

14        Q.   And I don't want to go into the details of the particular

15     situations that you did meet with Zupljanin.  We'll cover those

16     throughout your testimony.

17             But could you tell us, generally in what situations would you

18     meet directly with Zupljanin?  What kind of events would trigger such a

19     meeting.

20        A.   Well, let's start from the beginning.

21             For the first time, in the area of Doboj, I noticed that members

22     of the special detachment of the CSB Banja Luka were committing crimes.

23     I informed Mr. Zupljanin, both in writing and orally, about these events.

24     All instances in which there were certain abuse of other structures,

25     organs of the police and army, or crimes committed by these structures,

Page 10732

 1     in addition to a written report, I always made an effort to inform

 2     Mr. Stojan Zupljanin orally as well.

 3             I don't know how much you're interested in the outcome of these

 4     meetings and how this all happened.

 5        Q.   We are interested in them, and we will address them one by one as

 6     we go through your testimony.

 7             You mentioned that the procedures required that your reports go

 8     up your chain of command from Bera, to Mr. Kesic, and then up to the SNB

 9     at the RS MUP level.  Could you tell us how these reports would be

10     transmitted?  By what technical means would they be transmitted from

11     Banja Luka to Pale?

12        A.   Of course, I can only talk about what I know.

13             First, we used regular mail because the road between Pale and

14     Banja Luka was passable for vehicles and people.  I would submit my

15     written report to Vojin, and then he, through the analytical department,

16     would, I suppose only, pass this information on directly to Pale.

17             In addition to this form of communication, a certain number of

18     pieces of information that were short but which I assessed as being

19     particularly important for security, I sent through certain technical

20     devices, because in our group there was always a communications officer,

21     a trained communications officer, who was in charge of establishing other

22     forms of communication as well.  Among other things, we sent our reports

23     sometimes via the fax and other devices used by the State Security

24     Service, and these devices guaranteed full secrecy of this information up

25     to the level that they were technically able to provide the secrecy of

Page 10733

 1     this kind of information.

 2        Q.   To your knowledge, between the 1st of April and the

 3     31st of December 1992, was this system of communications between state

 4     security in Banja Luka and state security at the RS MUP functioning?

 5        A.   I had never been informed about this not functioning, except

 6     under some extraordinary circumstances.  But this does not certain the

 7     period when certain political problems arose between the two parts of

 8     Republika Srpska.  But that was later.

 9        Q.   Now, you mentioned that you had no direct means to verify whether

10     your intelligence reports made them -- made its way to Pale.  But did you

11     ever received responses to your intelligence information coming from the

12     RS MUP in Pale?

13        A.   Well, to tell you the truth, that happened on very few occasions.

14     That mainly consisted of their reaction, particularly at the time when

15     Dragan Kijac was appointed the chief, who thought that this kind of

16     feedback information was not necessary.  I wouldn't like to repeat what

17     kind of language was used with a view to devaluing this information as

18     well as the people who gathered them.  I don't think that is relevant for

19     this Court, but if do you think that it's relevant, I can provide this

20     information.

21        Q.   Well, I want to go into a little more detail about what you just

22     said.

23             Did you ever receive threats against you from the RS MUP level

24     about what you were reporting up the chain of command?

25        A.   Of course.  The people who were members of the Milos Group faced

Page 10734

 1     enormous problems; they were arrested, they were ill-treated.  The murder

 2     of Miodrag Susnjica still remains unsolved.  You know, I was also the

 3     subject of extreme abuse on the part of my co-workers and colleagues,

 4     which was directly instigated by the then-minister; I think his name was

 5     Kovac.  Who, among other things, on one occasion, kept me or had me kept

 6     in an interrogation process for 18 hours and then later on for 12 hours.

 7             Well, you know how a person feels when the person is interrogated

 8     by his co-workers, and this was exactly what happened.  One of them was a

 9     person that I personally trained.  And then he used me as a guinea pig to

10     test all the methods that he actually learned from me.  And, of course, I

11     was branded as a traitor.  I was, in their eyes, a deluxe or

12     super-traitor.  The English have a good term for that: high treason.

13             So these were the circumstances or, let's say, the situation that

14     I don't feel like -- don't feel comfortable remembering, but I clearly

15     remember what kind of threats they were sending to me and to my children

16     who were minors at the time, starting from sending paper shoes that I

17     used for burying people, and they also threatened to put hand grenades

18     without safety pin into the mouth of my children.  So I went through a

19     lot.  I don't want to go through this with you here.

20             This would be in a nutshell.

21        Q.   Thank you for the answer.

22             MR. OLMSTED:  And I think we're in time for the break.

23             JUDGE HALL:  We resume in 20 minutes.

24                           [The witness stands down]

25                           --- Recess taken at 10.26 a.m.

Page 10735

 1                           --- On resuming at 10.54 a.m.

 2             MR. OLMSTED:  I would just like to alert the Trial Chamber that

 3     the Prosecution team has been joined by one of our interns,

 4     Lejla Terzimehic.

 5             JUDGE HALL:  Thank you.

 6                           [Trial Chamber confers]

 7                           [The witness takes the stand]

 8             MR. OLMSTED:

 9        Q.   Mr. Radulovic, I now want to turn, just briefly, to the

10     intelligence reports that you submitted to the Serbian MUP in 1992.

11             Can you tell us whether Mr. Kesic and Mr. Zupljanin were aware

12     that were submitting intelligence reports to the Serbian MUP in 1992?

13        A.   Should I answer orally or look it up?

14        Q.   No, no.  Just answer orally whether Mr. Zupljanin and Mr. Kesic

15     were aware that you were sending information to the Serbian MUP in 1992.

16        A.   I'm sure of Mr. Kesic.  I'm sure that he knew of the connections

17     between the Milos Group and the SDB of Serbia.

18             About Stojan Zupljanin, I cannot say with certainty, because I

19     never directly informed him of my connections with the SDB of Serbia.  If

20     you're interested in my assumptions - I don't know how relevant it is -

21     but I assume that Stojan Zupljanin was aware of that too.

22        Q.   And can you tell us, How did the information that you sent to the

23     SDB in Serbia compare to the information that you submitted up the chain

24     of command of the RS MUP?

25        A.   Information identical in content to that which I sent to my

Page 10736

 1     immediate superior, Vojin Bera, was also sent to the MUP of Serbia.  We

 2     did not edit the information that was sent to Belgrade in any way or --

 3     nor did we actually in -- fail to inform the security service of

 4     Republika Srpska of anything that we sent to Belgrade.

 5        Q.   You mentioned that you assumed that Mr. Zupljanin was aware that

 6     you were sending intelligence information to the SDB in Serbia.  Why do

 7     you assume that?

 8        A.   I assume that because I received information from Mr. Kesic that

 9     he had informed Mr. Zupljanin of that.  But I was never in the position

10     to be present to a conversation between Mr. Kesic and Mr. Zupljanin to be

11     able to know whether Mr. Zupljanin was informed and to which extent.

12             I acted as if Stojan Zupljanin knew.  In other words, I concealed

13     nothing.

14             JUDGE HARHOFF:  Mr. Olmsted.

15             Mr. Radulovic, I'd like just to be sure that I have understood

16     this correctly.  You're saying that you sent your reports to Mr. Bera and

17     from him on to Mr. Kesic.  Then you also sent your reports directly to

18     Belgrade, or some of your reports.  Is that correct?  To the MUP in -- of

19     Serbia in Belgrade?

20             THE WITNESS: [Interpretation] Let me be more precise.

21             My reports or information, whatever, at the level of the SDB of

22     Republika Srpska, I directly submitted in writing to Vojin Bera.  The

23     very same identical information I sent to the SDB of Serbia.

24             When I say "SDB of Serbia," I say that this information did not

25     go to the SJB, that is, the public security service of Serbia.  It went

Page 10737

 1     exclusively to the State Security of Serbia, the SDB.

 2             JUDGE HARHOFF:  I understand.  But what I'm not sure of is why

 3     did you do this?  Were you ordered to send it to Belgrade as well?  Or

 4     did you do it on your own account; and why?

 5             THE WITNESS: [Interpretation] Now I must state my reasons.

 6             There was the Socialist Federal Republic of Yugoslavia.  Even

 7     before the war started in Bosnia-Herzegovina, I had contacts with the

 8     federal State Security Service and the SDB of Serbia too, because when I

 9     established those contacts, and with regard to the time when I worked and

10     my contacts in the service, I was convinced that this was our attempt to

11     save the SFRY.  I'm a Communist by conviction and a Yugoslav and,

12     therefore, my decision to preserve ties with the federal SUP to save

13     Yugoslavia.  Maybe I was mistaken in my attitude that links me more to

14     the former Yugoslavia than to any republic that came into being after

15     Yugoslavia broke apart.

16             During the events in Slovenia, it was clear to me that my country

17     was being destroyed, which I loved.  I loved my country.  So I worked

18     according to instructions of Mr. Kesic and sent information to the SDB of

19     Serbia.  He knew about that, and he made it clear to me that he was not

20     opposed to that information flow to Serbia.  And, well, you know, finally

21     the interest of the Serbian People was not only to protect certain areas

22     inhabited mostly by Serbs but there were also the overall interests of

23     the Serbian People in the entire territory of the former Yugoslavia.  So

24     my motivation, the motivation I had in my work, was that everything that

25     was opposed to the interest of the Serb people was information I should

Page 10738

 1     collect and inform who else than Serbia proper, where the representatives

 2     of the authorities and the institutions of the Serb People were.

 3             Of course, I didn't fail to inform all structures of any bad

 4     things that my fellow Serbs were doing.

 5             JUDGE HARHOFF:  What happened after the Republika Srpska was

 6     created?  Did you still pass your information on both to Belgrade and

 7     also to Pale?

 8             THE WITNESS: [Interpretation] Yes, correct.  You understood me

 9     correctly.  My contacts with the MUP of Serbia, its state security, were

10     not interrupted until the end of 1994.

11             JUDGE HARHOFF:  And all along, the MUP of Republika Srpska was

12     aware of this?

13             THE WITNESS: [Interpretation] Yes.

14             JUDGE HARHOFF:  Thank you.

15             Back to you, Mr. Olmsted.

16             MR. OLMSTED:

17        Q.   I now want to change to a different topic.

18             Prior to April 1992, were you aware whether there were any

19     meetings in Banja Luka between the high-level police officials of Serb

20     ethnicity regarding the division of the MUP along ethnic lines?

21        A.   Yes, of course.  As a member of the State Security Service, I

22     knew.  It was public knowledge.  Everybody knew.  Can you imagine a

23     situation where a common citizen knows something and an operative of the

24     SDB doesn't?  There had been a reorganisation of the MUP of the RS.  I

25     didn't have detailed knowledge about that; I wasn't present at the

Page 10739

 1     meeting; I didn't know the conclusions of the meeting; but I knew that

 2     such a meeting had been held, and I knew that it was about the

 3     transformation of the MUP of the former BiH and the establishment of the

 4     MUP of the RS.

 5             And if I may add, soon after that, I noticed the most conspicuous

 6     changes in insignia, because they differed from the insignia worn by

 7     police officers before that.  I didn't see anything special in that,

 8     because I had observed that earlier in the Bosniaks and the Croats, so I

 9     came to the conclusion that they all had their respective policies to

10     forward the cause of their own people.  To what extent that that was okay

11     to my mind is another issue.

12             As I said, I only believed in and respected the

13     Socialist Federal Republic of Yugoslavia.

14        Q.   Let's take a look at P864.

15             MR. OLMSTED:  And if we can turn to, I think, page 2 in the

16     English.  There we go.

17        Q.   Now, I'd like you to take a look at the article that's

18     entitled "Peace - The Strategic Aim."

19             This is an article in the Glas newspaper dated 5 March 1992.

20             And the article reports statements made by Mr. Zupljanin at a

21     press conference on the day before, after an Assembly meeting by the

22     Autonomous Region of Krajina Assembly.

23             First of all, could you tell us, to your knowledge, how

24     frequently did Mr. Zupljanin attend Assembly meetings?

25        A.   I couldn't say.  I didn't keep a register.  But from what I know,

Page 10740

 1     he did attend those meetings.  How often, in which capacity, with which

 2     interest, I really wouldn't like to speculate.  But -- anyway, I know

 3     that he attended such meetings.

 4        Q.   Now, this report states that Mr. Zupljanin informed journalists

 5     that the Assembly of the Serbian People in Sarajevo adopted a decision to

 6     found an interior ministry of the Serbian Republic of BiH and that there

 7     was a plan to found five centres of National Security Services, including

 8     one in Banja Luka, amongst other places.

 9             And it further states that Mr. Zupljanin stated the centre he was

10     responsible for would not carry out the orders of the Bosnia-Herzegovina

11     interior ministry that might possibly be directed against the interests

12     of the Serbian people.

13             Mr. Radulovic, do you recall this announcement being made around

14     this time, March 1992?

15        A.   The information is familiar, if we talk about the reorganisation

16     of the centres of the ministry and so on.  But I don't recall whether I

17     had ever seen the article published in Glas before you showed it to me.

18        Q.   Let's take a look now at 65 ter 10185.

19             This is a report dated 6 March 1992 that states that:

20             "After the announcement about the new organisation of the

21     Internal Affairs Service in Bosnian Krajina and in the general area, an

22     obvious dissatisfaction is present with the SJB and SDB employees with

23     Croatian and Muslim nationality.  This is particularly apparent within

24     the SDB.  Among the employees with Croatian and Muslim nationality, there

25     is an uncertainty present regarding their future work and professional

Page 10741

 1     destiny ..."

 2             Is this one of your intelligence reports?

 3        A.   Yes.

 4        Q.   And how does this particular report relate to the announcement

 5     that we just talked about?

 6             MR. KRGOVIC:  Objection.  That's leading.

 7             JUDGE HALL:  I don't -- I don't see that, Mr. Krgovic.

 8             Mr. Zecevic.

 9             MR. ZECEVIC:  I'm sorry, I don't think this document is on the

10     65 ter list.

11             MR. OLMSTED:  No, it's not on the 65 ter list.  We'll just be

12     marking it for identification.  I just want him to comment on it.

13             The document was part of this witness's 92 ter package ...

14                           [Prosecution counsel confer]

15             MR. OLMSTED:  I'm sorry, I just want to note that this document

16     was part of his original 92 ter package, which the Trial Chamber denied,

17     and I just wanted to -- I'm not going to seek to admit it into evidence,

18     but I just want the witness to comment on it.

19        Q.   Would you answer the question, please.

20        A.   Certainly.  The previous information that you showed me and which

21     was published in the newspapers was the first instance in which the

22     further fate of the ministry and, if you will, the political structure of

23     Republika Srpska was made public.  Clearly, comments about this

24     announcement started on the very same day.  The colleagues of Croatian

25     and Muslim ethnicity who were in direct contact with colleagues of Serb

Page 10742

 1     ethnicity and with me, too, they voiced their apprehension or maybe even

 2     fear of what was to come, and I considered it necessary to inform the SDB

 3     at the centre, and even higher up, because I expected that Bosniaks and

 4     Croats would say not accept that.

 5             MR. OLMSTED:  May this be marked for identification only?  No.

 6     Okay.  That's fine.  We'll move on.

 7             Can I please 65 ter 2833 on the screen.

 8                           [Prosecution counsel confer]

 9             MR. OLMSTED:

10        Q.   Sir, is this another report that was generated by the

11     Milos Group?

12        A.   Yes, of course.

13        Q.   And can you just tell us, Is this the typical format that you

14     used for your Milos reports?

15        A.   Yes.  This format of information was called a dispatch.

16        Q.   And at the bottom we see handwritten the number 027/92.  Can you

17     tell us what those numbers signify?

18        A.   This is an internal protocol which was made by the Milos Group.

19        Q.   So would I be correct in saying that the first number was the

20     number of the report and the second number was the year; is that correct?

21        A.   Yes, of course, you're correct.

22        Q.   And was there anywhere where these reports were recorded?

23        A.   This report and this type of report are registered in a log-book

24     that was kept with the SDB at the level of the Banja Luka centre.  And

25     this internal register of ours was for us to be able to find earlier

Page 10743

 1     information sooner.  So we had our own internal register that we kept.

 2             And just to make myself perfect clear, this number, 027/92, does

 3     not necessarily correspond to the entry in the official log-book of the

 4     SDB.  Actually, I'm -- it's pretty certain that the entry number is

 5     different there than here.

 6             JUDGE HARHOFF:  Mr. Radulovic, can I just ask, what does this

 7     document really say?

 8             You are filing a report to say -- in which you have obtained

 9     documentation of the organisation of the Banja Luka CSB.

10             What did this documentation show?

11             THE WITNESS: [Interpretation] The documentation was compiled for

12     wartime use.  It was compiled much -- or, rather, a long time before the

13     conflicts started in the territory of the SFRY.

14             The SDB also had wartime plans.  There was a special department

15     for restructuring to -- to adapt to the requirements of war.  We were in

16     the possession of this documentation which was important because it

17     included information about materiel, technical equipment, weapons,

18     practically everything, so this was interesting for the CSB at --

19             JUDGE HARHOFF: [Previous translation continues] ... but --

20             THE WITNESS: [Interpretation] -- the level of the centre itself.

21     So this was not only interesting for state security but also for public

22     security for them to have a more complete insight.

23             JUDGE HARHOFF:  But you also seem to suggest in your report that

24     you anticipate a national conflict and a splitting of the CSB along

25     national lines.

Page 10744

 1             What was that all about?

 2             THE WITNESS: [Interpretation] Well, of course, this is not the

 3     first report in which I make such an assessment that Bosnia-Herzegovina

 4     would be split up.  That was to be expected since the Socialist Republic

 5     of Yugoslavia had been broken up.  And bearing in mind assessments of

 6     others - not only mine - I assumed that the same would happen to

 7     Bosnia-Herzegovina, which all the time was seen as a miniature

 8     Yugoslavia; and even today it is seen as such.

 9             With regard to the ethnic trends and the intentions of the ethnic

10     parties, these were my assumptions of what could happen at the level of

11     the centre of the security services in Banja Luka.  That was the context

12     in which this was drafted.

13             I think that you understood it correctly.

14             JUDGE HARHOFF:  So what you're saying that as early as the

15     21st of March, 1992, plans were made in the CSB of how to split up the

16     CSB in Banja Luka on ethnic terms; and, secondly, that this information

17     was passed on also to Belgrade.  Is that correct?

18             THE WITNESS: [Interpretation] Yes.  But you misunderstood the

19     time-line of when these plans were drafted.

20             These kind of plans existed back in 1980, and I'm talking about

21     the time when I worked for the SDB.  When I joined the service, the

22     wartime plans existed already, so the SDB was never without such plans

23     incorporated into its regular work, which means working under

24     extraordinary circumstances or wartime circumstances.

25             So these plans date back a long time before the outbreak of war

Page 10745

 1     in the SFRY.  So these plans were worked out in great detail, which meant

 2     that it was well known who in which local area was in charge of what,

 3     what kind of materiel was to be available, because that was a

 4     well-organised service.  Of course, it had undergone the same fate, that

 5     is to say, that it also disintegrated.

 6             JUDGE HARHOFF:  Thank you for this.  Could I just ask to you keep

 7     your answers a bit short.

 8             You said in your response to my question that these plans existed

 9     back in 1980.  Is that a correct -- was this correctly understood?

10             THE WITNESS: [Interpretation] Yes, yes.  It was correctly

11     understood.  I can even add that these plans existed even before that

12     date, but I'm talking about the period when I was working in the SDB

13     because that's what I know for sure.  And I was personally involved in

14     drawing up certain plans by virtue of my position as the head of the

15     intelligence section.

16             JUDGE HARHOFF:  Thank you.

17             Back to you, Mr. Olmsted.

18             MR. OLMSTED:

19        Q.   I just want to focus on the language that you have in this

20     report, that this information about the war documentation is interesting

21     in terms of assessment should the -- a national conflict and splitting of

22     the CSB along national lines come about.

23             Could you just tell us - and maybe I understood your last

24     answer - how these particular plans were adjusted or modified to

25     anticipate the splitting of the MUP?

Page 10746

 1        A.   I can answer that, but forgive me if I can't do it briefly.

 2             At the level of the Banja Luka CSB, we knew exactly the

 3     proportionality of each community, Mrkonjic, Jajce, Bosanski Novi,

 4     Dubica, Prijedor, Prnjavor, et cetera.  Each of these areas within

 5     wartime plans had its own place, had its own materiel and logistical

 6     resources which were envisaged to be used in the event of war.  So we

 7     knew exactly what was supposed to be available in Jajce, Mrkonjic, Grad,

 8     Kljuc, et cetera, and this was written because we knew the ethnic

 9     composition of our organisation both in terms of active-duty officers and

10     reserve officers of the SDB; we knew more or less who had what kind of

11     weaponry, what kind of equipment they had, and where their wartime

12     assignments would be in the event of war.

13             So we quite simply compiled this information -- compiled this

14     information for the CSB to have this information available - and I see it

15     was written on the 23rd of March - for them to know that outside of

16     Banja Luka itself and the centre itself there were concern resources in

17     terms of equipment and personnel, both active and reserve, who

18     constituted a kind of security structure at the level of Banja Luka CSB.

19             Since I knew that the CSB didn't have this kind of information, I

20     thought it advisable to send this to the management of the CSB, but --

21     both the public and security services, for them to be aware of that in

22     case a war broke out, because we were afraid that conflicts might break

23     out within certain services in Kljuc, Jajce, or elsewhere.  Because if

24     Serbs Croats and Muslims start warring -- fighting each other, that would

25     have ended in a blood bath.

Page 10747

 1        Q.   Under these war plans, members of which ethnic groups were given

 2     the important posts in the event of a war?  Which ethnic group?

 3        A.   Well, you see, I think that we should go into a private session

 4     again.

 5             JUDGE HALL:  I -- I hear the witness's request, but I'm not sure

 6     that I appreciate the question necessitates that course.

 7             Perhaps, Mr. Radulovic, the -- without answering the question,

 8     you could indicate why, in your view, it is necessary for us to revert to

 9     private session.

10             THE WITNESS: [Interpretation] Because we are talking about

11     wartime plans which was top secret.  Therefore, I'm afraid that I might

12     make an -- a slip or probably divulge some information that might

13     jeopardise certain people and, of course, myself as well.

14             JUDGE HALL:  Yes.  We go into private session.

15                           [Private session]

16   (redacted)

17   (redacted)

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 10748

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

19   (redacted)

20                           [Open session]

21             THE REGISTRAR:  We're in open session, Your Honours.

22             MR. OLMSTED:  Can we please take --

23             MR. ZECEVIC:  I'm sorry.  Could we have the number again, please,

24     because it wasn't recorded.

25             THE REGISTRAR:  Exhibit P1366.

Page 10749

 1             MR. OLMSTED:  Let's take a look at -- can we please take a look

 2     at 65 ter 2834.

 3        Q.   Mr. Radulovic, is this another one of your Milos reports?

 4        A.   Yes, it is.

 5        Q.   Now, this report says:

 6             "All the information gathered so far indicates [sic] that the

 7     establishment of Serbian Republic BiH MUP might lead to total ethnic

 8     division among authorised and unauthorised employees of SJB and SDB.  The

 9     division would manifest itself in various way, primarily, Muslim and

10     Croatian employees would make their own public and state security

11     services in towns in BiH which would unquestionably lead to international

12     conflicts."

13             This report is quite prescient.  What prompted you to write it?

14        A.   It was prompted from intelligence from the ground because we

15     already had information that in certain areas, like municipalities,

16     certain services were being formed -- security services were being formed

17     along ethnic lines.  The Croats had their own, the Bosniaks had their

18     own, the Serbs had their own.  Although, there was no place for the

19     Yugoslavs in that structure.

20        Q.   Did you personally warn the CSB chief that a division of the MUP

21     along ethnic lines could lead to international conflict?

22        A.   As far as I can remember, and not only with respect to this

23     report but also to similar reports, I talked several times with

24     Mr. Kesic, and I always informed the then-chief, Stojan Zupljanin, and,

25     of course, I informed Belgrade as well.

Page 10750

 1        Q.   Do you recall how Mr. Zupljanin reacted to your warnings that the

 2     split of the MUP would cause conflict amongst the ethnicities?

 3        A.   I cannot remember what his response was with regard to this

 4     particular report because that would be sheer guess-work.  But these were

 5     initial reports and information relating to inter-ethnic conflicts.  I

 6     don't know how he accepted this, whether he took it seriously or not

 7     seriously, whether he was concerned or not concerned.  If I should

 8     venture to say anything about this, it would be just my personal

 9     construct, and I'm reluctant to do that.

10             MR. OLMSTED:  May this be admitted into evidence.

11             JUDGE HALL:  Admitted and marked.

12             THE REGISTRAR:  Exhibit P1367, Your Honours.

13             MR. OLMSTED:  May we have on the screen 65 ter 2835.

14        Q.   This is a report dated 9 April 1992.  Is this a Milos report?

15        A.   Yes, it is.

16        Q.   Now, you are again reporting on the danger of inter-ethnic

17     conflict resulting from the division of the SJB stations along ethnic

18     lines.  And the report describes a meeting that Mr. Zupljanin had with

19     employees of SJB Prijedor regarding the insignia on police uniforms.

20             Can you tell us, What insignia is this report referring to?

21        A.   In short, it refers to displaying symbols of Republika Srpska in

22     visible places such as on the shoulders and on the caps.  The caps were

23     in the shape of a French cap with very distinct insignia of

24     Republika Srpska.  These insignia still exist in Republika Srpska, and

25     nothing has been changed with respect to the colours or the shape.

Page 10751

 1        Q.   And according to the information that you had at the time, what

 2     was the purpose of the CSB chief's visit to Prijedor SJB?

 3        A.   From what the Milos Group managed to gather, in terms of

 4     information, Mr. Stojan Zupljanin in -- the CSB chief, wanted to become

 5     personally involved and provide some explanation at the meeting in

 6     Prijedor and elsewhere.  He wanted to impart on people that the situation

 7     was serious, and he wanted to point out to the local executives of local

 8     police stations that such restructuring and the change of insignia was

 9     prompted by initiative from the top echelons of the MUP of

10     Republika Srpska, that it was coordinated with the authorities of the

11     Republika Srpska, and that that was something that simply had to be

12     accepted as the future organisation and the insignia in both services,

13     and I mean the public and the state security services.

14        Q.   And what if -- what happened to the police officers who refused

15     to wear the insignia or accept the changes?  What would happen to them?

16        A.   Those who did not sign the so-called solemn declaration left

17     their jobs in the public or state security service.  Many left even

18     before that.  Therefore, in these two services, after this, in all the

19     municipalities listed in this information, and, of course, elsewhere,

20     only a small number of Croat and Bosniak members remained in the service.

21        Q.   At the time of this meeting - it's -- it must have been around

22     the time of this report, 9 April 1992 - had the takeover of Prijedor by

23     Serb forces taken place?

24        A.   No, not at that time.  We had an incident in which employees of

25     the police station in Prijedor along with a number of volunteers tried to

Page 10752

 1     take over the station before it was taken over by the Serbian forces.  We

 2     know that snipers were involved, et cetera.  And I know for sure that we

 3     had information to this effect.

 4             Mr. Stojan Zupljanin, in order to prevent bloodshed in this kind

 5     of conflicts, issued an order to prolong these adoption of new insignia

 6     for a certain period of time until such time when the situation of the --

 7     on the ground would be brought under control.  I think that the situation

 8     was such that it allowed for these changes to take place.  However, the

 9     Bosniaks left the state and public security services in large numbers.

10             MR. OLMSTED:  May this be tendered into evidence.

11             JUDGE HALL:  Admitted and marked.

12             THE REGISTRAR:  As Exhibit P1368, Your Honours.

13             MR. OLMSTED:  May we see 65 ter 10189.  This document also is not

14     on our list.  It was part of his 92 ter package, so we'll just ask him

15     some questions about it.

16             MR. KRGOVIC: [Interpretation] Your Honours, I object to this

17     document be shown to the witness at all, and I object to this line of

18     questioning.  He is trying to tender this into evidence through the back

19     door.  He is showing him a document that is not on the 65 ter list, and I

20     think this is impermissible and unacceptable since this document is not

21     on the 65 ter list and cannot be put to the witness.

22             MS. KORNER:  Your Honours, we've been through this on a number of

23     occasions before, which is why I'm dealing with it rather than

24     Mr. Olmsted.

25             Your Honours' ruling has been that we can't, when it's not on our

Page 10753

 1     65 ter list and in the absence of an application to add it, we cannot

 2     make it an exhibit but we can show it to the witness, and I don't know

 3     why we keep on having these interruptions.

 4             JUDGE HALL:  Yes, Mr. Olmsted, please proceed.

 5             MR. OLMSTED:  And I called up the wrong document.  It's

 6     65 ter 10186.

 7        Q.   Now, this is a report dated 24 April 1992.  Can you confirm

 8     whether this is a Milos report?

 9        A.   Yes, it is.

10        Q.   The report states that:

11             "The majority of authorised officials of the Muslim and Croatian

12     nationality who are employed in the civil sectors and who sign the solemn

13     pledges took annual leave or sick-leave.  The authorised official of

14     these nationalities" --

15             JUDGE HALL:  Mr. --

16             MR. ZECEVIC:  I'm really sorry.

17             JUDGE HALL:  Mr. Olmsted, aren't you attempting to do what

18     Mr. Krgovic pointed out before, getting it through -- you aren't merely

19     showing it to him; you're reading it into the record.

20             MR. OLMSTED:  I don't know how I will be able to ask a question

21     without at least laying the foundation of what my question is going to

22     be.  I have to go to the portion of the document and then -- so can he

23     hear what it is about, and then I will ask a question that will lead from

24     that, and I -- I don't really know how I can get around that.

25             MR. ZECEVIC:  I'm sorry, Your Honours, the witness confirmed that

Page 10754

 1     is his report.  Can he read it for himself.  Why doesn't Mr. Olmsted ask

 2     the question only and that would be it?

 3             MS. KORNER:  Your Honours, I'm sorry.  This is the whole point.

 4     And I'm sorry that it's a bit - we shouldn't be going up and down,

 5     different counsel like this - but this is something that's clearly of

 6     importance.

 7             You cannot make any sense at all unless have you some of the

 8     context of what's in the document.  What it's -- what your ruling is

 9     stopping us doing is making the document an exhibit.  The whole

10     document's not being read out, just the part that the witness is going to

11     be asked about.

12             JUDGE HALL:  But the -- but the -- we have ruled that it is

13     not -- that it cannot be exhibited.

14             As Mr. Zecevic has helpfully indicated, it would be simpler for

15     the witness to read it and then Mr. Olmsted could ask his question.

16             MS. KORNER: [Microphone not activated]

17             THE INTERPRETER:  Microphone, please.

18             MS. KORNER:  Sorry.

19             It doesn't make much difference which way around it is, provided

20     you want to have some idea of what the document is for the purposes of

21     the record.

22                           [Trial Chamber confers]

23             JUDGE HALL:  Mr. Radulovic, have you read the document?

24             THE WITNESS: [Interpretation] Yes, I have.  Of course.

25             MR. OLMSTED:

Page 10755

 1        Q.   Okay.  Well, let me just quickly summarise for the record what

 2     the document states.

 3             It states that non-Serbs -- well, how can I ask him a question

 4     without at least -- okay.

 5             Well, this report, does it relate to non-Serbs who were at the

 6     CSB Banja Luka at the time-period of this report?

 7        A.   Yes, it does.

 8        Q.   And the part of the report that deals with those who signed the

 9     solemn declaration, by signing this solemn declaration, did it guarantee

10     that they would have job security and be able to stay in Banja Luka by

11     signing it?

12        A.   As far as I know - and I know some individual cases and I can

13     give you the names - this is exactly what it meant.

14        Q.   Well, what happened to those non-Serbs who did sign the solemn

15     declaration?  Did they stay in their posts?  It says here they went on

16     some kind of annual leave.

17             Were they able to return to their posts?  Did they stay in

18     Banja Luka?  Can you tell us?

19        A.   Most of them who were on annual leave or sick-leave or some other

20     leaves left the area of Banja Luka.  The same happened to people in other

21     areas such as Kljuc, Prijedor, and others.

22             So, for the most part, members of the State Security Services,

23     who were in active duty, left the service before -- before a direct

24     conflict, so to speak, broke out between the Bosniaks and the Serbs.

25     More precisely, they left immediately after the public announcement that

Page 10756

 1     reorganisation of the service was imminent, that the insignia would be

 2     changed, et cetera.

 3             They left the service without informing the service about it.

 4     Some left, though, both with the knowledge and the assistance of the

 5     service because they applied for that by saying that they wanted to leave

 6     the area of Republika Srpska peacefully.  For that purpose, the CSB made

 7     it possible for them to leave the area together with their family and

 8     their extended families and to go to the places where they wished to go.

 9     That was one of the tasks of the Milos Group to make it possible for all

10     our active-duty officials and collaborators, due to disrupted

11     inter-ethnic relations and the war and everything else that was

12     happening, be allowed to safely leave the area, provided they wanted to

13     do that, in order to avoid any of them living in fear and let alone any

14     one being maltreated or wounded or killed eventually.

15             So we wanted to prevent any of that from happening.

16        Q.   Thank you.  And let me say again, please try to keep your answers

17     as short of as possible because we do have a lot of area to cover with

18     you.

19             You just stated that your Milos Group were helping some of them

20     leave the area because they were -- so that they could avoid living in

21     fear and, of course, avoid being maltreated or wounded or killed.

22             Are you saying that the non-Serb members of the police at CSB

23     Banja Luka were facing threats and harassment during this time-period?

24        A.   It did happen.  There were such cases.  And that was done by

25     members of unofficial armed units.  I won't call them either paramilitary

Page 10757

 1     or parapolice.  I'll call them undefined armed units that weren't under

 2     anybody's control, and they did even the most horrible things like

 3     killing people and beating them up and other bad things.  There have been

 4     such occasions.

 5        Q.   What about from within the police force?  Did these non-Serb

 6     police officers, to your knowledge, receive any threats or harassment

 7     from within the police force?

 8        A.   As far as I know, there have been no such instances, not only in

 9     the territory of the CSB of Banja Luka, but elsewhere too.  But there may

10     have been instances of which I'm unaware.

11             I repeat, however, that I didn't know of any such events.

12             However, the situation was different in Doboj and some other

13     places.  But you're asking me about Banja Luka, so I don't know whether I

14     need to expand and say that there have been such events in other places.

15     I don't know whether I'm supposed to go into that now.

16        Q.   No.  And, again, please, just wait for further questions before

17     you go into -- expand -- expanded areas.

18             MR. OLMSTED:  Can we please take a look at 65 ter 2829.

19        Q.   Now, this is a report dated 2 April 1992.

20             Can you tell us if this is one of your Milos reports?

21        A.   Yes, it is.

22        Q.   Now, the report states that:

23             "We have insufficiently verified intelligence that armed

24     formations of SDS are intending to block all roads towards Banja Luka on

25     3 April 1992 in order to thereby force individual members of the

Page 10758

 1     Government of the Autonomous District of Bosnian Krajina to resign and

 2     also to pressure the JNA to make personnel changes ... in keeping with

 3     the interests of the SDS ..." et cetera, et cetera.

 4             Now, could you tell us, Did this blockade that you describe in

 5     this report actually take place?

 6        A.   Yes.

 7        Q.   And were the armed forces of the SDS, which you refer to in this

 8     report, known by any other names?

 9        A.   They were called Red Berets.

10        Q.   Can you tell us whether they were also referred to as the

11     Serbian Defence Forces or SOS?

12        A.   SOS, yes.

13        Q.   Were you in Banja Luka on the day that the blockades were set up?

14        A.   I think so.

15        Q.   Besides setting up the blockades, were the SOS members doing

16     anything else in Banja Luka?  Were they guarding any facilities or

17     anything else?

18        A.   Well, let me tell you very briefly.  Literally speaking, they

19     blocked all life in Banja Luka.  They even took the building of the CSB

20     in Banja Luka.  They were at almost all significant spots, such as

21     bridges and so on, at all entry-points to the city.

22             And here's a paradox:  One of our good experts who was a normal

23     man, a member of the CSB, was killed on the Venezija [phoen] bridge in

24     Banja Luka because this man Goran Bijelic did not stop when he was hailed

25     by the Red Berets.  So you can imagine what the situation was like in

Page 10759

 1     Banja Luka at the time, and it didn't go on for just one day.

 2        Q.   And could you tell us, Where did the members of the SOS come

 3     from?

 4        A.   The members of the SOS, with some honourable exceptions, were

 5     mostly local criminals with thick police files and with previous

 6     convictions.

 7        Q.   And based on your intelligence information, who were the leaders

 8     of the SOS?

 9        A.   Well, if I could ask this Trial Chamber, I would like to go into

10     private session now, because we're about to -- to mention names and

11     about -- and mention live people.

12             JUDGE HALL:  Well, we would go into private session.  But

13     although we are four minutes shy of the break, perhaps, inasmuch as this

14     appears to be a -- somewhat involved answer, we should take the break now

15     and deal with the -- answer the question when we return.

16             MR. OLMSTED:  That's fine, Your Honour.  Thanks.

17                           [The witness stands down]

18                           --- Recess taken at 12.02 p.m.

19                           --- On resuming at 12.29 p.m.

20             JUDGE HALL:  Mr. Olmsted, although not for the first time the

21     initiative about private session has come from the witness, I assume that

22     you agree with the prudence of that course.

23             MR. OLMSTED:  Well, I think the issue is more how he feels

24     comfortable, given his safety concerns.  And so I'm going leave that to

25     his assessment.

Page 10760

 1             JUDGE HALL:  I see.

 2             MR. OLMSTED:  I'm not quite sure that the actual individuals,

 3     these names, are not already known to this Trial Chamber and to the

 4     public, but I guess if it's his feeling that if he is mentioning their

 5     names that that might somehow result in some harm to him.

 6                           [Prosecution counsel confer]

 7             MR. OLMSTED:  Yes.  And as Ms. Korner pointed out to me, one of

 8     them that we assume he is going to mention is considered quite a serious

 9     criminal currently in that region.

10                           [The witness takes the stand]

11             JUDGE HALL:  So we move into private session.  And, Mr. Olmsted,

12     for continuity, perhaps you could repeat the question.

13                           [Private session]

14   (redacted)

15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 10761











11 Page 10761 redacted. Private session.















Page 10762

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16                           [Open session]

17             JUDGE HALL:  So we are back in open session.

18             THE REGISTRAR:  We're in open session.

19             MR. OLMSTED:

20        Q.   Mr. Radulovic, could you please tell us, What were the links

21     between the SOS and the SDS leadership at the republican level?

22        A.   At the level of the republic, I cannot provide a precise answer.

23     I can only speak about the Banja Luka level.

24             The members of the SOS had close relations with the people who

25     were most prominent then as those forwarding the ideas of the SDS.  I

Page 10763

 1     don't know whether you want to hear the names of these politicians, but I

 2     can mention them.

 3        Q.   Yes, please mention those.

 4        A.   Well, let's see, they had good relations with Mr. Brdjanin then

 5     with the then-president of the Executive Council of the city of

 6     Banja Luka.  He's a professor and has a doctoral degree of -- I don't

 7     know of what.  He used to be a waiter before.  They were the most

 8     important representatives of the SDS in Banja Luka on what I was able to

 9     observe.

10        Q.   The Executive Council person that you just mentioned, the

11     president, was that Rajko Kasagic?

12        A.   Yes, yes, correct.  Rajko Kasagic.

13        Q.   Can you tell us --

14        A.   Yes, I apologise.  I forgot a very prominent person; Dr. Vukic,

15     also known as Vozd.

16        Q.   Can you tell us, Did President Radovan Karadzic have contact with

17     any of the SOS leadership such as Ljuban Ecim or Nenad Stevandic, based

18     upon the intelligence information you were receiving?

19        A.   At that time, we had no information about any direct contact

20     between Mr. Karadzic and individuals belonging to SOS.  I don't know if

21     you're interested, but we subsequently found out that Dr. Karadzic had

22     close relations with Ljuban Ecim and the whole Ecim family from

23     Banja Luka.

24        Q.   Okay.  So if I can just clarify what you've just said.  At the

25     time, in early April, you did not know about any links between

Page 10764

 1     Dr. Karadzic and the SOS leaders but you subsequently received

 2     information regarding that; is that correct?

 3        A.   You may draw that conclusion.  Later, maybe halfway through 1992

 4     or toward the end of 1992, we learned that Ljuban Ecim was rather close

 5     to President Karadzic.  I believe that this closeness and this bias

 6     were -- became especially significant when Dragan Kijac became the chief

 7     of the service.

 8        Q.   Now, in the document that we, I think, still have in front of us,

 9     your report is drawing a link between this SOS blockade and the

10     identification and selection of personnel who supported SDS policies.

11             Could you tell us how that linkage worked?  What role was the SOS

12     playing in this personal selection policy?

13        A.   Well, in some cases, the role was decisive.  The opinion of

14     someone from SOS was a decisive factor for that someone to become what

15     they wanted him to become.

16             I remember well that the SOS influenced the removal of the

17     chancellor of the Banja Luka university, which you will admit is absurd.

18     The chancellor at the time, Mr. Kuzmanovic, who nowadays is the president

19     of the RS, he was informed that as of day so-and-so when the -- when the

20     SOS man talked to him he was no longer the chancellor, and he was

21     replaced by a man of their choice who later became prime minister of the

22     RS.

23             I'm talking about these things, but that's what happened with the

24     placing of the people they had selected and previously vetted in other

25     positions, and they didn't even leave out education, where they also

Page 10765

 1     placed a man of their choice.

 2        Q.   And the SOS influence over personnel decisions, did this also

 3     apply to the police as well, the CSBs and SJB?

 4        A.   I think that the SOS did have influence.  I don't know how much

 5     exactly, but there was some.  It's hard for me to assess the percentage.

 6     But I know that some people were unable to meet the criteria of the SOS.

 7        Q.   Now, was this aim of the SDS, as you described in the report,

 8     making these personnel changes for policy reasons, were they in fact

 9     achieved in Banja Luka in 1992?

10        A.   I must say that I tried to clarify this matter in the book that I

11     wrote, and that's entitled "Alone Against All."  I think that this is one

12     of the crucial problems of the entire Serbian tragedy; namely, that it

13     was allowed for such people to influence the selection of personnel

14     because I believe that only the very worse were selected.  For the reason

15     that they wanted to manipulate these people.  And that also had

16     consequences for the MUP, where, I must admit, their influence was

17     smallest, because most of the executive in the MUP and the SDB had been

18     there from the earlier period, and they were experienced.  And they were

19     relatively well-able to protect themselves against the influence of the

20     SOS from -- and protect their service from the catastrophic influence of

21     the SOS.  And than includes the SDB also.

22             I can tell you that most of these people were literally

23     illiterate, with the exception, of course, of Ljuban Ecim and

24     Zdravko Samardzija, but the others I mentioned, at a certain moment,

25     became masters of life and death.  They became someone they -- they were

Page 10766

 1     feared by everybody.  Banja Luka was in fear and in terror, and that

 2     applied not only to the Serbs who were not to their taste but also to

 3     Bosniaks and Croats.  Everybody was afraid of that group that called

 4     themselves members of the special detachment or the SOS.  That is most

 5     certainly true.

 6        Q.   Thank you, Mr. Radulovic.  But, please, please, try to keep your

 7     answers a bit shorter.  My question was quite directed, and I think you

 8     could have answered it a little bit shorter.  I hate to keep on reminding

 9     of this, but because we do have a limitation on time, I really want you

10     to try to keep your answers short.

11             MR. ZECEVIC:  I'm sorry.  I just have one inquiry.  We were never

12     disclosed the book of -- the witness's book "Alone Against All."

13             This is the first time we ever heard about it.

14             MR. OLMSTED:  The Prosecution is not in possession of any such

15     book.

16             JUDGE HALL:  It is something the witness volunteered?

17             THE WITNESS: [Interpretation] Can I answer?  May I answer?

18             JUDGE HALL:  Yes, please.

19             THE WITNESS: [Interpretation] Dear colleague, you are probably

20     unaware of the existence of the remaining ten books of mine.  And this

21     book has not been published yet because I first wanted to finish my

22     testimony here.  And then this 11th book, "Alone Against All," will be

23     published.

24             JUDGE HALL:  Thank you.

25             MR. OLMSTED:  While I'm thinking about it, can we tender the

Page 10767

 1     document that's on the screen into evidence.

 2             JUDGE HALL:  Admitted and marked.  But before -- so sorry.

 3             THE REGISTRAR:  As Exhibit P1369.  Thank you, Your Honour.

 4             JUDGE HARHOFF:  Before we take the document off the screen, I

 5     would just have one additional question in relation to the policy changes

 6     in personnel that were made or prompted by the SOS people.  Because you

 7     say in your report, Mr. Radulovic, that:

 8             "The personnel changes in the Banja Luka Corps should also be in

 9     keeping with the interests of the SDS with the aim of putting the Banja

10     Luka Corps in the function of the police and other interests of the SDS."

11             This prompts me to put two questions:  First of all, was the

12     personnel policy changes also implemented in the Banja Luka Corps?  And,

13     secondly, what did you mean by saying that the Banja Luka Corps should be

14     keeping with the interests of the SDS with the aim of putting the Banja

15     Luka Corps in the function of the political and other interests of the

16     SDS?

17             Can you clarify?

18             THE WITNESS: [Interpretation] Yes, I can clarify.  I don't know

19     how long it will take though.

20             There had been some changes.

21             JUDGE HARHOFF:  Please be brief.  Thanks.

22             THE WITNESS: [Interpretation] There were some changes within the

23     Banja Luka Corps.  Some positions were filled by people who had been

24     selected by the SDS.

25             Let me tell you that, in keeping with that logic, one of the

Page 10768

 1     Chiefs of General Staff - I can't remember him now; he is from Gradiska

 2     or somewhere - he was an -- a half-literate man.  He needs a whole sheet

 3     of paper to sign.  That's the way we put it.  A whole sheet of paper

 4     for -- to just put his signature.  A man who had no military or

 5     professional or other abilities.  And he was put in the position at the

 6     top of the Army of Republika Srpska.  I don't know whether Mladic was

 7     above him or not.  Probably he was -- he was subordinate to Mladic.

 8             And let alone -- let me not go into the structure at the brigade

 9     levels on the -- on the ground.  Masons became officers in charge of

10     morale.  They meet -- they met no criteria for these positions, but they

11     were placed there anyway because they had been selected by the SDS.  They

12     were SDS men.

13             And it was similar in the MUP.  A man from Bosanski Novi became

14     minister who ran a gravel pit before.  I think he used to sell sand.  But

15     he was minister of the interior for a while.  So just imagine.  When you

16     bring such people in, what can you expect?  How can an institution such

17     as the MUP function under these circumstances?

18             JUDGE HARHOFF:  Mr. Radulovic, were you able to form an opinion

19     about whether the command of the Banja Luka Corps changed after this?

20     And can you give us some examples, if -- if that was so?

21             THE WITNESS: [Interpretation] In part, yes.  I said that there

22     had been some changes.  And as for the commander of the Banja Luka Corps,

23     the late Talic, sincerely speaking, I never held him in high regard.  I

24     didn't think he was a person who deserved to be in such a high position.

25     The man didn't have any moral or other criteria, and I'm sorry that I

Page 10769

 1     have to say this because the man is dead.

 2             But I didn't hide this opinion of mine even while he was alive.

 3     So I'm at peace with my conscience because I spoke this way even before

 4     and wrote about it and published it.  He was -- he was suitable for that

 5     position [as interpreted].

 6             JUDGE HALL:  Mr. Radulovic, let me be more direct then.  You seem

 7     to suggest - and this is my question to you, if this is correctly

 8     understood - but you seem to suggest in your report that there was a sort

 9     of resubordination of the Banja Luka Corps under the political

10     institutions that had developed in Banja Luka.

11             And so my question to you was:  Is it correctly understood that

12     after the SOS was successful in implementing a change in the command

13     structure of the Banja Luka Corps, there was a situation in which the

14     Banja Luka Corps were given instructions by the political establishment

15     and that they followed these instructions?

16             I realise that this is a leading question, but the question arose

17     out of your own remarks in your report, so I simply just want to clarify

18     if this was a correct understanding of what you wrote in your report.

19             THE WITNESS: [Interpretation] In spite of a lengthy explanation

20     that you provided, I will be try to be brief.

21             You understood well what I meant.  I thought that the politics

22     definitely took over control and influence over the army, making it act

23     as a politician -- politicians wanted, instead of the army functioning as

24     it is supposed to in any society.

25             JUDGE HARHOFF:  Right.  And my question was then: Can you give us

Page 10770

 1     a few examples of that?  In detail.

 2             Did you know of any instructions given by the political

 3     leadership in Banja Luka to the army?

 4             THE WITNESS: [Interpretation] I have to admit that you're asking

 5     me now to state my personal opinion.  I can do that.  I can give you my

 6     definite opinion with regard to specific cases.  May I just give you an

 7     example which will be enough for you to understand?

 8             JUDGE HARHOFF:  Yes, you may give me an example.  But I was

 9     asking you if you had concrete information about any instruction given or

10     submitted by the political establishment to the corps command.  If you

11     don't have any such examples, then just tell us.

12             THE WITNESS: [Interpretation] No, no.  No.  I don't have any

13     information about any instructions of that kind in terms of me being

14     present on the spot or seeing a document to that effect.  I had my

15     perception from what I was able to observe on the ground, and what I

16     observed on the ground was disastrous.

17             JUDGE HARHOFF:  Thank you.

18             MR. OLMSTED:

19        Q.   Mr. Radulovic, was the CSB Banja Luka leadership aware in advance

20     of the 3rd of April that the SOS was going to take over Banja Luka?

21        A.   I'm not sure if they knew or not.  They were present there, but

22     since I myself knew and saw these members, I don't see any reason for

23     others not to have been able to see that.  And I think that we even wrote

24     about these events before.  At about that time, Goran Bjelic got killed

25     at one of the barricades.  People were being stopped every day on the

Page 10771

 1     barricades, ordinary people.  Banja Luka is not a big town, and I think

 2     that everything resident of Banja Luka knew what I knew.  Therefore, we

 3     informed the service about this.  We asked for certain steps to be taken

 4     in order to neutralise these groups, and that is all I can say at the

 5     moment.  After all, can you find all this in my reports.

 6        Q.   Were you aware whether any members of the CSB Banja Luka

 7     leadership maintained close contacts -- close contacts with SOS members?

 8        A.   Yes, I knew about that.  To begin with, Kesic Nedjelko, my chief

 9     of the security service, was in contact with them on a daily basis.  He

10     kept their pictures framed on their -- on his walls.  He was proud of

11     those knights, as he called them.  But as for my picture, he probably

12     never saw it on my ID either.  I don't want to criticise him for that,

13     but I won't be keeping quiet about his being on very close terms with

14     them and about his not being close to me.

15        Q.   Who else from the CSB Banja Luka leadership?

16        A.   To tell you the truth, I know about these close relationships

17     only between Kesic, Ecim, and Samardzija and others because they were in

18     a his office on a daily basis.  They didn't need to ask his secretary to

19     ask permission to come and visit him, whereas I had to put forward a

20     written request to meet with my chief.

21        Q.   If you could take a look at paragraph 46 of your written

22     statement, you mentioned that deputy chief Djuro Bulic as well as a

23     police officer by the name of Stojan Davidovic also had --

24             MR. KRGOVIC:  I object to that.  What's the point to show the

25     witness statement?  It's not yet the evidence.

Page 10772

 1             MR. OLMSTED:  It's simply to refresh his memory.

 2             MR. KRGOVIC:  No.  Ask him directly.

 3             JUDGE HALL:  If I might add, the witness hasn't asked to refresh

 4     his memory from his written statements, so ask the question.

 5             MR. OLMSTED:  I'll ask the question then.

 6        Q.   Deputy Chief Djuro Bulic and Stojan Davidovic, were they also in

 7     contact with SOS on a regular basis?

 8        A.   To tell you the truth, there were a lot of facts.  I made an

 9     oversight about Davidovic and Bulic.  Of course, these two were in

10     equally close contact with those people as Kesic Nedjelko.

11        Q.   Could you tell us who Stojan Davidovic was?  What was his

12     position within the police?

13        A.   Stojan Davidovic was in the uniformed section of the police.  For

14     a time, he was, I think, the assistant of the chief for police.  And even

15     for a period of time he was a police station chief.  I know that he has

16     recently been appointed warden of the Tulica penal and correction

17     facility in Banja Luka, after which he retired.  I know that from the

18     very outset he was a member of the SDS.  And I know that he maintained

19     close relations with this group.

20        Q.   Did any members of the CSB Banja Luka leadership have close

21     contacts with the SDS leadership in Banja Luka?  And if they were, could

22     you please name who those individuals were?

23        A.   From the leadership?  Well, I don't know who wasn't on close

24     terms with the SDS.  The SDS was an official party.  It was the ruling

25     party.  And, of course, as such, it decided the rules governing the

Page 10773

 1     elections, selection, and appointments.  The majority of executive had

 2     certain obligations by virtue of their position to attend political

 3     meetings at the level of Banja Luka municipality and in the more expanded

 4     area.

 5        Q.   Let me show you 65 ter 2864.  And this document is subject to

 6     protective measures, so perhaps we could go into private session.

 7             JUDGE HALL:  Yes, we go into private session.

 8                           [Private session]

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 10774











11 Page 10774 redacted. Private session.















Page 10775

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15                           [Open session]

16             THE REGISTRAR:  We're in open session, Your Honours.

17             MR. OLMSTED:

18        Q.   Mr. Radulovic, when the SOS set up the blockades in Banja Luka

19     and started guarding certain facilities around the municipality or around

20     the town, did the police offer any resistance to the SOS?

21        A.   No, as far as I know.  There were some altercations, arguments

22     and the like, but none of the SOS members were ever arrested.

23        Q.   In your view, based upon your experience as a -- both a police

24     officer and as an operative for the SNB -- or SDB, did the police have

25     the manpower, the training, and the equipment to prevent the SOS from

Page 10776

 1     taking over the town?

 2        A.   Yes.  That would be my short answer.

 3        Q.   How long did the SOS operate in Banja Luka?  They came in on the

 4     3rd of April.  How long were they there?

 5        A.   At least 20, 30 days.  Maybe even longer.  Please don't hold me

 6     to it.  It's been a long time ago.

 7             But they stayed for a long period of time.

 8        Q.   And while they were in Banja Luka, how were they treating the

 9     non-Serb population?

10        A.   Unfairly.  If I am requested to provide you a detailed

11     description and explanation, I can do that.

12        Q.   Well, could you very briefly just describe.  Were they committing

13     crimes against the non-Serb population; and basically what those crimes

14     were.

15        A.   They committed crimes of seizure of valuables, physical abuse,

16     seizure of everything they considered they needed.  And they even

17     committed a number of crimes of rape.

18             During that period, however, no non-Serbs were killed, but I have

19     to add that they treated the Serbs who in any way whatsoever tried to

20     confront them and oppose this behaviour of theirs in the identical

21     manner.

22        Q.   And, to your knowledge, did the police do anything to prevent

23     these crimes from occurring?

24        A.   The police were aware of their conduct.

25             When I talked to my colleagues from the public security sector, I

Page 10777

 1     learned that the people from the public security who were in charge of

 2     general crimes requested that the perpetrators of these crimes be

 3     arrested, and that is what I know.  But I don't know if they were

 4     actually arrested.

 5        Q.   Did you attempt to bring these crimes by the SOS to

 6     Mr. Zupljanin's attention?

 7        A.   To tell you the truth, there were conversations about that.  For

 8     the first time, I reacted to the SOS contact when I talked to

 9     Mr. Zupljanin after I heard from Mane Popovic that the SOS members were

10     transferred to the active-duty section of the police.  In my mind, that

11     was absolutely incomprehensible and unnecessary.  And truth to say, no

12     one will ever be able to convince me that was necessary for some tactical

13     or strategic reasons because in order to bring this kind of cancer into

14     the service you can only expect the whole service to become ill.

15        Q.   When you told this to Mr. Zupljanin, how did he respond?

16        A.   Of course, it's difficult for me, after such a long time, to

17     explain his behaviour.

18             At any rate, I know that he told me - and I remember that

19     vividly; he used to address me as Radule - he said - and I think that he

20     was referring to SOS - he called them Serbian knights.

21             I personally didn't see them as Serbian knights.  I rather saw

22     them as Serbian criminals, who, by becoming active-duty officers of the

23     state and public security services, were simply given the basis and the

24     protection to act in a more rampant way, so to speak, in what they were

25     doing and which was directed against all ethnic communities in Banja Luka

Page 10778

 1     and in other regions where they were also engaged.

 2        Q.   And can you confirm:  After these SOS members joined the police,

 3     they did, in fact, continue to commit crimes against the population?

 4        A.   Of course.

 5        Q.   Are you --

 6        A.   But not only in Banja Luka.  Relatively speaking, they committed

 7     the fewest crimes there because the service was the most powerfully in

 8     that area.  Their activities were more prominent when they were sent out

 9     into other municipalities such as Kotor Varos and, of course, Doboj, and

10     other places.  No need for me to name them now.

11        Q.   And you mentioned that they were committing crimes against all

12     ethnicities.  Can you explain why they would be targeting Serbs?

13        A.   They did that because a large number of the Serbs did not agree

14     with that sort of conduct of those scum, I have to say.  I am fully aware

15     that this is being broadcast to the public, but I called them scum 15 or

16     17 years ago, and I could never identify myself and relate to them as

17     members of my own people.  Those were wild beasts in uniform, so I don't

18     know how to put it differently.

19             If you're asking me about the information that I had, then I can

20     tell you specifically what I directly witnessed, in terms of their

21     activities, and that is what prompted me to take this attitude towards

22     their behaviour.

23             MR. OLMSTED:  Let take a look at 20 -- sorry, 65 ter 2832.

24             JUDGE DELVOIE:  Mr. Olmsted, just one small question to the

25     witness.  He says that the SOS people were sent out to other

Page 10779

 1     municipalities.  Sent out by whom?

 2             THE WITNESS: [Interpretation] You're asking me?

 3             JUDGE DELVOIE:  Yes.

 4             THE WITNESS: [Interpretation] I don't know that.  I wasn't their

 5     superior, and I wasn't in a position to be able to tell who the

 6     individual was who sent them to a certain area.

 7             JUDGE DELVOIE:  And who was their -- who was the superior once

 8     they were in the police force?

 9             THE WITNESS: [Interpretation] A -- their superior was

10     Stojan Zupljanin by virtue of his position.  And later, I believe, it was

11     only Dragan Kijac who issued them orders when he became chief of state

12     security or -- and subsequently minister.

13             As far as I know, based on the information I had, he was the only

14     one who issued them orders and sent them to different places.  Until he

15     arrived, that was the responsibility of Stojan Zupljanin, and he had the

16     authority to do so.

17             JUDGE DELVOIE:  Thank you.

18             MR. OLMSTED:

19        Q.   Now, this is a report that we're looking at, dated 15 April 1992.

20             Is this one of your reports?

21        A.   Yes.

22        Q.   Now, the report describes much of what you've just told us about

23     the activities of the SOS.  It states that the self-named Serbian Dukes,

24     leaders, and ring-leaders hold the majority of the SDS leadership in

25     their surrounding and under their control, et cetera et cetera.

Page 10780

 1             Could you tell us, Who were the self-named Serbian Dukes and

 2     leaders you were referring to in this statement?

 3        A.   Well, you know, I don't know a single duke, or whatever they

 4     called them, who really were dukes.  I know Dr. Vukic who was a drunkard,

 5     a man completely disreputable, and he was given the title of duke.  They

 6     certainly had exerted influence on him.  They also exerted influence on

 7     Brdjanin and others who have been mentioned here.  I don't need to repeat

 8     all that.  And I know some three or four people who called themselves

 9     dukes.

10             I don't know how important this is, because these are really

11     disreputable men who proclaimed themselves dukes and that, later on,

12     became accepted, although there was no special significance to it.  I

13     remember that a priest in Banja Luka, who slipped in the winter and died

14     as a consequence, also called himself a duke.

15             There were such clowns around who called themselves dukes.

16        Q.   [Previous translation continues] ...

17        A.   If you know who were the real dukes in Serbian history, well,

18     these people don't stand a chance in comparison.

19        Q.   Thank you for that answer.  And, again, please keep your answers

20     as short as possible.

21             MR. OLMSTED:  May this document be tendered into evidence.

22             JUDGE HALL:  Admitted and marked.

23             THE REGISTRAR:  Exhibit P1371, Your Honours.

24             MR. OLMSTED:  May we take a look at 65 ter 2831.

25        Q.   Now, this report is dated 12 May 1992.  Can you confirm:  Is this

Page 10781

 1     one of your Milos reports?

 2        A.   Yes, it is.

 3        Q.   It reports that:

 4             "The SOS are carrying out certain terrorist and other actions

 5     against citizens of Muslim, Croat and Albanian nationality."

 6             Can you tell us, Where these -- well, I think you've already

 7     mentioned this, and so I'm -- but you mentioned that they were carrying

 8     out activities in other municipalities; is that right?  Not just

 9     Banja Luka?

10        A.   That's correct.

11        Q.   Based on your intelligence information, were the SOS that existed

12     in other municipalities in Banja Luka, were they connected to the one

13     that operated in Banja Luka?

14        A.   Certainly.  The members of SOS from Banja Luka, I told you,

15     later, became members of a special detachment when they were active-duty

16     members of the CSB.  Then they were sent out to some areas.  Only then

17     they were members of the special detachment.  But practically all those

18     who were members of SOS became active-duty security officers, and they

19     were set out to other locations.  That would be my answer.

20        Q.   Leaving aside the CSB Special Police Detachment, let's just talk

21     about SOS units in other municipalities.  I can't remember -- I don't

22     recall which ones you've particularly mentioned, but you said there were

23     others, Perhaps Sanski Most and other places.  Those volunteer units,

24     were they somehow linked to each other?

25        A.   We had information to that effect.  And I must say, since I

Page 10782

 1     suppose you want me to elaborate on this, that they were most active in

 2     Doboj.  I mean, SOS members.  And they were the most extreme too, judging

 3     by their deeds.  We also considered the Sanski Most to be a place where

 4     there were very extreme SOS members.  But that doesn't mean that I want

 5     to say that in other areas in other municipalities there were no similar

 6     SOS units, stronger or less strong.  But we never received information

 7     that they -- that their conduct was fair and becoming.

 8        Q.   In this last sentence of this report, you say that:

 9             "The SOS's actions caused mistrust towards even the citizens of

10     Serbian nationality, and we believe that even in wartime circumstances

11     fairness and legality are necessary, and it is one of the ways out of

12     this difficult and complex situation."

13             To whom were you directing that?  It appears that you're making a

14     statement directed at a particular person.

15        A.   I sent this to the SDB, to Mr. Kesic.  And this was my appeal,

16     my -- I cried out to the SDB of Serbia, because I believed that the tone

17     of this report would induce somebody to take interest and deal with this

18     matter.  Because the situation on the ground was really catastrophic.

19        Q.   How did Mr. Kesic respond to this report, to what you said here?

20        A.   Well, let me tell you frankly.

21             Mr. Kesic was a rather casual man.  He was more interested in

22     women than the war.  And he saw his chance to profit from the war

23     materially.  Such information that I sent him was seen by him most often

24     as something that we shouldn't [Realtime transcript read in error

25     "should"] meddle with; this isn't our job; why should we interfere.  But

Page 10783

 1     to my mind, what could there be more important in wartime than this,

 2     this -- these matters with which this foolish Milos Group dealt.

 3             MR. OLMSTED:  May this be admitted into evidence.

 4             JUDGE HALL:  Admitted and marked.

 5             THE REGISTRAR:  As Exhibit P1372.

 6             MR. ZECEVIC:  I'm sorry, Your Honours, I believe 75, 24, the

 7     witness said we "shouldn't" meddle with.  That is not our job.  And it

 8     was recorded as opposite.

 9             JUDGE HALL:  Thank you.

10             MR. OLMSTED:  That's what I heard as well.  Perhaps I'll just get

11     a clarification.

12             Mr. Radulovic, when Mr. Kesic responded to your report here, is

13     it correct that he said that we should not meddle in this; it is not our

14     job; why --

15        A.   That's correct.

16        Q.   [Previous translation continues] ...

17        A.   Yes, you understood me correctly.

18        Q.   Very good.

19             Mr. Radulovic, you've explained how members of the SOS were

20     absorbed into the CSB Banja Luka, and I think you mentioned in particular

21     the Banja Luka Special Police Detachment; is that right?

22        A.   That's right.

23        Q.   Did any members of the SOS also enter into the

24     State Security Service for which you were a part of?

25        A.   Unfortunately, yes.

Page 10784

 1        Q.   Can you please tell us which SOS members entered into the

 2     state security?

 3        A.   Among others, the three Kajkut brothers; then Subara, this

 4     certain Subara; then Predrag Boziroda; then a certain Baja.

 5             There was several.  I know them because I used to meet them.

 6        Q.   [Previous translation continues] ... you mentioned the Kajkut

 7     brothers.  Would that include, Nenad and Danko Kajkut?

 8        A.   No, they aren't brothers.  Nenad and Danko Kajkut are close

 9     relatives.  The three Kojic brothers were actually brothers.

10        Q.   Okay.  I apologise.  Then I guess my question is - I did misread

11     the transcript:  Were the -- Nenad and Danko Kajkut, did they also become

12     part of the state security?

13        A.   Yes.

14             If I may provide the clarification:  All these persons first

15     became security service officials -- officers, and then they became

16     members of a special police detachment.  I believe that Mr. Kesic wanted

17     to get rid of these persons.  And then he found the most convenient way

18     of putting the burden on the SJB because he was probably aware of the

19     possible consequences of the activities of these mentioned -- these

20     members that I have been mentioning.

21             MR. OLMSTED:  Let's take a look at P550.

22        Q.   This is a report dated 27 April 1992.

23             Is this one of your reports?

24        A.   Yes.

25        Q.   The report discusses the creation of a special purpose police

Page 10785

 1     detachment to be formed at the CSB, consisting of 157 plus 3 members.

 2     And is this the detachment that you've talked about so far?

 3        A.   No, not this one.

 4        Q.   This -- well, let me clarify that.  This is a -- let's read it

 5     out.  It says that:

 6             "The ARK Assembly session on 27 April 1992" --

 7        A.   Just a minute, please.  Just a moment.

 8             If you mean this line reading "157 plus 3," is that what you

 9     mean?  This detachment?

10        Q.   [Previous translation continues] ...

11        A.   [Previous translation continues] ... the last line?

12        Q.   Essentially that's what I mean.  This is a report where you're

13     talking about the creation of a special police detachment --

14        A.   [No interpretation]

15        Q.   Let me ask the question -- at the CSB.  And I'm just clarifying

16     that this is the CSB Special Police Detachment that you've referred to

17     thus far in your testimony?

18        A.   That's correct.  Yes, I was focussed on the first part of this

19     report.  But, yes, this is the detachment that we spoke about earlier,

20     this special purpose police detachment within the CSB of Banja Luka.

21     Yes, this is it.

22        Q.   Can you tell us, Who were the commanders of the special police

23     detachment in 1992?

24        A.   For a while, it was Captain Lukic, who was a professional soldier

25     of the JNA.  I knew him personally.

Page 10786

 1        Q.   [Previous translation continues] ...

 2        A.   I thought it would be the best thing to have them under his

 3     control, but the man soon informed me that they were impossible to

 4     control, and he walked out on that position.  He left.

 5        Q.   Can you tell us who appointed Mr. Lukic, Mirko Lukic, to this

 6     position?

 7        A.   I suppose it was the chief of the centre, I mean the CSB.  I

 8     never saw all the decision -- official decision to that effect.  It could

 9     have been the minister of the interior, but it should have been,

10     according to the rules, it should have been the chief of the CSB.

11        Q.   And could tell us, Ljuban Ecim, did he hold a leadership role in

12     the special police detachment?

13        A.   He was the most important man, irrespective of his official

14     position in that detachment.  He was the alpha and omega of everything.

15        Q.   And what about Zdravko Samardzija, did he have a leadership

16     position within the detachment?

17        A.   Yes, he did.  He was Ljuban Ecim's deputy.

18             MR. OLMSTED:  Let's take a quick look at 65 ter 3597.  And if we

19     could turn to the next page.

20        Q.   And while we're doing that, this is what is represented to be an

21     SNB Banja Luka payroll for June 1992.

22             Is that what this is, Mr. Radulovic?

23        A.   I had nothing to do with these payrolls.  But knowing how they

24     worked, I know that such payrolls, such lists, were possible.  Here the

25     salary is determined based on the number of hours worked and your

Page 10787

 1     previous years of service, et cetera, then you get a certain factor or

 2     coefficient and thus your salary is calculated.

 3             Yes, this is correct.

 4        Q.   And had you a chance to look at this document during proofing.

 5     Is this a fair representation of who was working --

 6        A.   [No interpretation]

 7        Q.   -- for the SNB back in June 1992?

 8        A.   This is correct, not only because I saw it but also because I

 9     remember the people who were employed at the time.  But it is possible

10     that someone mentioned here may have been on sick-leave at the time, but

11     they were still on the list and, therefore, their salaries were paid out.

12        Q.   I noticed upon reviewing this list that there were a couple of

13     names that were non-Serbs.  For instance, Sead Besic.  By June 1992, were

14     these non-Serb employees still performing their duties at SNB?

15        A.   They were mostly still employed in the service.  I know about

16     Sead Besic.  He was a chief for a while in Prijedor, but he was taken

17     back to Banja Luka to protect him so that he would be safer.

18        Q.   And the non-Serbs that we -- will appear on this list, did they

19     remain in Banja Luka throughout 1992, or did they leave?

20        A.   Of the employees of the SDB, the only one who stayed all the

21     time, either in the SDB or the SJB was Zeljko Domazet.  He is, even now,

22     in the SDB.  But most of these persons on the list left Banja Luka.

23        Q.   And the one that stayed, what was the ethnicity of his spouse?

24        A.   I know that Zeljko Domazet was a Croat by ethnicity and a

25     Roman Catholic by religious affiliation.  I know that he stayed in the

Page 10788

 1     SDB.  Later on he was transferred to the SJB to deal with general crime.

 2             Now he was a deputy chief of the CSB in Banja Luka.

 3        Q.   Can you tell us his spouse.  What was the ethnicity of his

 4     spouse?

 5        A.   Yes, of course, I can.  I still maintain contact with the

 6     Domazet family.  His wife is a lawyer and a Serbian woman.

 7             MR. OLMSTED:  May this be admitted into evidence.

 8             JUDGE HALL:  Admitted and marked.

 9             THE REGISTRAR:  As Exhibit P1373, Your Honours.

10             MR. OLMSTED:  And I think that is all we have for today, or --

11             JUDGE HALL:  Yes.

12             MR. ZECEVIC:  Sorry, Your Honours, we have been exchanging the

13     e-mails with our friends from the Prosecution, and apparently they were

14     not aware that this witness has published ten books previously, so that

15     is why they don't have them in their possession and -- nor do they -- nor

16     did they ever disclose to us that information because they didn't have

17     it.

18             Now, if we can ask the Trial Chamber to -- to see with the VWS

19     that they can talk to the witness and inform us back where can -- are

20     these books published, where they were published, and additional

21     information which would enable us to probably find these books.

22             Thank you very much.

23             JUDGE HALL:  And, of course, you would pursue your own inquires,

24     Mr. Zecevic.

25             MR. ZECEVIC:  Yes.

Page 10789

 1             JUDGE HALL:  Mr. Radulovic, yes, sir.  You wanted to say

 2     something.

 3             THE WITNESS: [Interpretation] Yes, if you allow me, Your Honours.

 4     I published ten books out of which six books are poetry.  I think that

 5     my -- my colleague Mr. Zecevic has outgrown that because there is also

 6     some children's poetry among that.  There is also some love poetry.  But

 7     possibly I can lend him a copy of the latter; it may be inspiring for

 8     him.

 9             JUDGE HALL:  Mr. Radulovic, we have reached the point where we

10     must take the adjournment for the day.

11             We will resume tomorrow morning at 9.00 in another courtroom.

12     According to the latest calendar, we are in Courtroom III tomorrow;

13     Courtroom II for the remaining days of this week.

14             Having been sworn as a witness, I'm obliged to caution you that

15     you cannot have any communication whatever with the lawyers from either

16     side the -- in this case.  And in addition to that, such conversations as

17     you may have persons outside the courtroom, you cannot discuss your

18     testimony.

19             So, with that, we take the adjournment to tomorrow morning

20     at 9.00.

21                            --- Whereupon the hearing adjourned at 1.47 p.m.,

22                           to be reconvened on Wednesday, the 26th day

23                           of May, 2010, at 9.00 a.m.