Tribunal Criminal Tribunal for the Former Yugoslavia

Page 11034

 1                           Monday, 31 May 2010

 2                           [Open session]

 3                           [The accused entered court]

 4                           --- Upon commencing at 9.05 a.m.

 5             THE REGISTRAR:  Good morning, Your Honours.

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

 7     Stojan Zupljanin.

 8             JUDGE HALL:  Thank you, Madam Registrar.

 9             Good morning to everyone.  May we have the appearances, please.

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

11     Joanna Korner, and Crispian Smith for the Prosecution.

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

13     Slobodan Cvijetic, Eugene O'Sullivan, Ms. Tatjana Savic, and

14     Dominic Kennedy appearing for Stanisic Defence this morning.

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

16     Defence, Igor Pantelic, Dragan Krgovic, and Jason Antley.  Thank you.

17             JUDGE HALL:  Thank you.

18             MS. KORNER:  Your Honour, before the witness comes in, can I just

19     make one inquiry.  I think I know the answer, but I just want to confirm

20     it.  Mr. Riedlmayer will be testifying, as I understand it, as an expert

21     under the provisions of Rule 94 and so his reports will be the evidence

22     rather than previous testimony which would be under 92 ter?

23             JUDGE HALL:  Yes.

24             MS. KORNER:  The reason I'm asking is we made a slight error on

25     the documents we submitted.  Because we, for some reason, we have a

Page 11035

 1     slight - I don't know quite what the word is - but brain-storm.

 2                           [Trial Chamber confers]

 3             MS. KORNER:  Your Honours, that's right, isn't it?  Yes, thank

 4     you very much.  Because we'll have to resubmit the package because we put

 5     in, I don't know, as I say, I think we had a brain-storm slightly and we

 6     put in his previous testimony, but it will his reports.

 7             JUDGE HALL:  Thank you.

 8             Could the usher please escort the witness back to the stand.

 9                           [The witness takes the stand]

10             JUDGE HALL:  Good morning to you, Mr. Radulovic.  Before

11     Mr. Zecevic resumes his cross-examination, I remind you you're still on

12     your oath.

13                           WITNESS:  PREDRAG RADULOVIC [Resumed]

14                           [Witness answered through interpreter]

15             JUDGE HALL:  Yes, Mr. Zecevic.

16             MR. ZECEVIC:  Your Honours, I have no further questions for this

17     witness, except I would like to tender the documents as per list which I

18     submitted on -- on Friday.  I see that there was no reaction, so I

19     assumed that there is no objection from the Office of the Prosecutor.

20             JUDGE HALL:  Mr. Olmsted.

21             MR. ZECEVIC:  I believe the list has been forwarded to Registry

22     as well.  Yes.

23             JUDGE HALL:  Thank you.

24             Mr. Olmsted.

25             MR. OLMSTED:  Yes, we did receive a list of 31 documents.  We

Page 11036

 1     don't object to them.  We question the relevancy of a number of them, but

 2     I think that will be for the Trial Chamber to determine on its own.

 3             JUDGE HALL:  Thank you.

 4                           [Trial Chamber and Registrar confer]

 5             JUDGE HALL:  Yes, Mr. Zecevic.  The -- in -- within the -- within

 6     the course of this morning's first session we would be able to tell what

 7     you the numbers are, but that's a process that's going to take a little

 8     while.  But the -- but they're all in.

 9             MR. ZECEVIC:  Thank you very much.

10             JUDGE HALL:  It's a matter of assigning numbers to them.

11             MR. ZECEVIC:  I appreciate.  Thank you very much.

12             MR. KRGOVIC: [Interpretation] Good morning, Your Honours.

13                           Cross-examination by Mr. Krgovic:

14             MR. KRGOVIC: [Interpretation] Good morning, Mr. Radulovic.

15             THE WITNESS: [Interpretation]  Thank you especially for calling

16     me Comrade Radulovic.

17             JUDGE HALL:  Why won't my mic turn off?

18             THE INTERPRETER:  Microphone, please.

19             JUDGE HALL:  Mr. Krgovic, give me a moment, please.  We have a

20     slight technical problem here.  I can't get my mic off.

21                           [Trial Chamber confers]

22             MR. KRGOVIC: [Interpretation]

23             MR. ZECEVIC: [Microphone not activated] ... the witness's

24     microphone is off as well.

25             MR. KRGOVIC: [Interpretation] It seems there's a technical

Page 11037

 1     problem of some sort with the mics.

 2        Q.   Just in order to check out, can you hear me?

 3        A.   Yes, I can hear you very well.

 4        Q.   Comrade Radulovic, in answering the Prosecutor's questions, you

 5     mentioned some people and said, as far as I understood you, that the word

 6     "gentleman" was used very frequently even for those people who could not

 7     possibly be understood to be gentlemen.  But I will, when I ask you

 8     questions about these people, I will just use the word "person" for them

 9     so -- to -- as -- so as to avoid using other terminology.

10        A.   I agree, because I'm very selective in using that particular

11     term.

12        Q.   Very well.  Comrade Radulovic, I will begin my cross-examination

13     with trying to establish a context of your work and the group Milos and

14     the circumstances surrounding its establishment.

15             You said that this was in June, the 28th of June, 1992?

16        A.   It was the 28th of July, 1991, when the group was formed as the

17     Milos Group.

18        Q.   The establishment of the this group, Milos, actually came at a

19     time when the Socialist Federal Republic of Yugoslavia was breaking up,

20     Croatia and Slovenia had seceded, and amidst national and ethnic rifts,

21     and at the beginning of the breakup of the Socialist Republic of Bosnia

22     and Herzegovina; correct?

23        A.   Yes, that's correct.

24        Q.   The entire area of the Banja Luka region, where Milos Group

25     operated, and especially the border area towards Croatia, saw the

Page 11038

 1     worsening of the security situation and serious breaches and violations

 2     of the constitutional and legal order of the Republic of Bosnia and

 3     Herzegovina; correct?

 4        A.   Yes, that's correct.  If you allow me, I would just like that add

 5     a sentence to what I've said.  The violations -- or, rather, the

 6     break-down in the ethnic relations had occurred earlier, so if you only

 7     confine this to 1991 then you're only right in part, because all these

 8     things had happened post-festum, as it were.  Everything had already

 9     fallen apart.  And the only thing that was left was the breaking up of

10     whatever shards and bits and pieces had been left unbroken.

11        Q.   I agree with what you've said.  But because of the time-frame of

12     the indictment in which is 1992, I wanted to go back to certain events in

13     1991 because they were -- they reflect on the indictment period.  And,

14     therefore, I will focus my question to the period from mid-1991 up until

15     the end of 1992, mid-1991, because that was the time when the Milos Group

16     had been formed.

17             At this point in time, in 1991, war was on in the territory of --

18     of Croatia, and that war spilled -- or was spilling over into the area of

19     the Banja Luka CSB and the border areas of Bosnia and Herzegovina;

20     correct?

21        A.   Correct.

22        Q.   The border areas of Bosnia and Herzegovina were being shelled by

23     the Croatian side.  There was a strong presence of the ZNGs and the

24     Croatian Defence Council and Croatian armed forces in that area; correct?

25        A.   Correct.  I apologise, I will try to follow the cursor so as not

Page 11039

 1     to barge in on your questions.

 2        Q.   The Milos Group, in its activities, as far as I understood, this

 3     group, at this point in time, was active primarily on monitoring these

 4     events and collecting intelligence, gathering intelligence, in order to

 5     be able to assess the possible implications of the war in Croatia on to

 6     the Bosnia and Herzegovina and Banja Luka regions.  And in that context,

 7     they tried to identify certain security issues and problems which

 8     affected security; correct?

 9        A.   Yes.  But I have to stress that a lot of information was missing

10     at the time.

11             I apologise, but if I can just expand on this, there was

12     insufficient information on Sijekovac, Kupres, many events from early

13     1992 when the war started, and this was characteristic specifically for

14     this region, where conflicts broke out between Serbs an armed units of

15     the HOS and the HDZ.  And I mention these two towns because they are

16     characteristic of these events, but there are other places where the same

17     was happening.

18        Q.   And as a result of wartime -- of war operations in Croatia and

19     combat in the border area towards Bosnia and Herzegovina, there was a

20     large influx of refugees from Croatia into the Banja Luka region and its

21     surrounding areas?

22        A.   That's right.  I don't know how important it is for you, but

23     since the war broke out in Croatia, there were some 600.000 refugees

24     coming over into the Banja Luka area.  Some of them remained there, most

25     of them, while others moved on to other areas in Republika Srpska and

Page 11040

 1     Serbia.

 2             JUDGE HALL: [Previous translation continues] ... when we have a

 3     moment, may we interrupt to have the Registry assign those exhibit

 4     numbers.

 5             MR. KRGOVIC:  Yes.

 6             JUDGE HALL:  Could we do it now?

 7             MR. KRGOVIC:  Yeah, can you do it now.

 8             JUDGE HALL:  Yes.  Thank you.

 9             THE REGISTRAR:  Your Honours, the 30 tendered documents will

10     become Exhibits 1D287 through 1D317.  And additionally the Defence

11     tenders 1D279 and 1D282 which were MFI'd during the last session.  Thank

12     you.

13             MR. KRGOVIC:

14        Q.   Mr. Radulovic, this fact and the arrival of the expelled people

15     from -- into that area actually exacerbated the situation, both the

16     security and the economic situation, in the Banja Luka area; correct?

17        A.   If you want my opinion, I can tell you that that is correct.

18        Q.   When I say "expelled people," I am actually referring to Serb

19     refugees.  I'm repeating this for the sake of the transcript.

20        A.   Well, that is what I understood you to mean.

21        Q.   With these refugees, a number of people were coming back from the

22     battlefields, from the front lines in Croatia, into this area which was

23     under the control of your CSB.  So I am referring here to the -- to the

24     members of HOS and ZNG who had fought in Croatia.  Also, I'm referring to

25     a number of Serbian people who -- who reported when they were called up

Page 11041

 1     and went to fight in Croatia as well as a certain number --

 2             THE INTERPRETER:  The interpreter did not hear the last portion

 3     of the question.

 4             MR. KRGOVIC:

 5        Q.   Could you please clarify?  I didn't quite understand.

 6        A.   Well, in addition to the refugees who came and who exacerbated

 7     the security situation --

 8             JUDGE HALL: [Previous translation continues] ...

 9             MR. KRGOVIC: [Interpretation]

10        Q.   In other words, the refugees who arrived in Croatia, and I am

11     hear actually mentioning two different issues, and I'm not necessarily

12     implying that they are related, but in the Banja Luka area there were

13     members of the armed forces of the Republic of Croatia who are now making

14     their appearance and who hail from Bosnia-Herzegovina.

15        A.   Correct.  Now I understood what you meant by your question.

16     Correct.

17        Q.   And then we see that all three ethnic groups in Bosnia and

18     Herzegovina are beginning to arm themselves, each ethnic group is

19     organising and trying to arm themselves.  And at one point in time in

20     Banja Luka there was a large number of armed people in the Banja Luka

21     area.  Some of them organised in various units.  Correct?

22        A.   Yes.  But I would just like to add that I myself took part in an

23     investigation where we conducted interviews with an influential person

24     from the SDA who admitted to us that the SDA leadership had purchased

25     5.000 rifles, automatic rifles, from Slovenia.  After the interview with

Page 11042

 1     this person, this same individual reported publicly what he had said, and

 2     he also sent it to the media.  And as for him, he was supposed to be

 3     processed further or prosecuted, but I'm not sure how that whole thing

 4     ended and whether there was a final judgement by a court.  But I do

 5     remember that figure very clearly, 5.000 rifles, which Slovenia had

 6     because they had left behind -- they had been left behind by the

 7     Yugoslav People's Army in their depots in Slovenia.

 8             Of course, I do not wish to reiterate here the well-known facts

 9     about how the Croatian side armed itself, and I wouldn't wish any part of

10     my statement or testimony to be understood as my attempt to give credit

11     to myself for something that Mr. Aco Vasiljevic did.  He was the general

12     of the Yugoslav Army who conducted this operation at the time.

13             But I would like to say that our Gradiska source, through his

14     connections who were operating in the border area, the border with

15     Hungary, was the first to actually initiate or put -- set in motion that

16     event.  I would especially like to point this out, and I hope this will

17     not cause him any problems, because he was the first to learn that fact,

18     or, rather, our -- one of our reservists at the SDB and an active-duty

19     member of the SDB, Drago Sobot, they were the first ones who actually

20     obtained that information, that intelligence.

21        Q.   Comrade Radulovic, in parallel with these processes conducted by

22     the SDB, also the leadership of the HDZ and the SDA, were involved in the

23     process of establishing the independent Bosnia-Herzegovina dominated by

24     Muslims and Croats, to the detriment of the Serbian nation, right?

25        A.   Mr. Krgovic, is there a difference between the period then and

Page 11043

 1     the period nowadays?  It's an identical situation.

 2             By using the percentage of the majority nation, they want to give

 3     advantage to the two minority nations and establish a country whose major

 4     goal will be to fulfil the objectives of the SDA.  This is what the

 5     current political leadership led by Haris Silajdzic, Zlatko Lagumdzija,

 6     and others, is trying to do under a different guise, so to speak, under a

 7     different decorum.  This is a problem described by Ivo Andric who

 8     depicted it with great accuracy and beauty in his book called, in

 9     Serbian, Prokleta Avlija.

10        Q.   Such policies by Muslim and Croats' parties had their unavoidable

11     effect on the MUP of the then-Bosnia and Herzegovina, and the unity of

12     MUP was disturbed.  The Muslim and Croat side started outvoting the

13     Serbian personnel there.  Isn't that right?

14        A.   I stated my opinion concerning this on the first day of my

15     evidence; that's correct.  But I think that it should be well-known to

16     Mr. Mico Stanisic in what way were the Muslims within MUP of

17     Republika Srpska armed.  They used illegal channels to do that via a

18     company from Macedonia.  They bought the most modern, at the time,

19     weaponry to conduct a street war.  To be fully precise, they purchased

20     hecklers, short and long-barrels, the so-called 3s and 5s, and they also

21     purchased other equipment.  Mostly for street combat and sabotage

22     operations.

23        Q.   Comrade Radulovic, I have to correct you.  When discussing how

24     the unity of MUP was disturbed, you said the MUP of Republika Srpska, but

25     you meant the MUP of Bosnia and Herzegovina.

Page 11044

 1        A.   Of course.  Of course, I meant the MUP of Bosnia and Herzegovina.

 2        Q.   And you were referring to the employees of MUP who were Muslims.

 3        A.   Yes.  Predominantly Muslims, although there were some Croatians

 4     as well.

 5        Q.   And the system of reporting and communications was also disturbed

 6     because the Muslims employees used the ethnic lines for sending their

 7     reports so that the reports from the Banja Luka CSB, which were supposed

 8     to follow the usual channels, did not follow them.  Rather, the Serbian

 9     employees were skipped over in that reporting system.

10        A.   Mr. Krgovic, it is very difficult for me to give answers to

11     everything that you are referring to.  God, if I may invoke God, did not

12     give me the talent whereby I could use few words to say a lot.  But I

13     have to tell you that this parallel structure is something that we felt

14     back in 1988 and then onwards.  And by your leave, there's no need for me

15     to be afraid.  I can point a finger at the people from the Banja Luka

16     centre who are Muslims and Croats who maintained their contacts with

17     Croatia, Croats with Croatia, and Bosniaks with the centre in Sarajevo.

18     And whatever they did, they did exclusively - and I repeat, exclusively -

19     in the interest of their nation, of their ethnic group, and their

20     national political parties.

21             I don't know to what extent I need to tell you this.  The

22     Republic of Croatia, back in 1988, adopted a voluminous plan by way of

23     which it organised or attempted to organise the Croats living outside of

24     Croatia.  In order to avoid portraying myself as an historian and a

25     political analyst, I'm telling you this from the angle of my work at the

Page 11045

 1     time and the information I collected.  Therefore, there is no background

 2     whatsoever to what I'm going to tell you now.  I did not use opinions of

 3     any other authors.  What I'm telling you, I'm telling you on the basis of

 4     what I did as an operative, which, unfortunately, wasn't put forward

 5     here, because, allegedly, the explanation given was that nobody was

 6     interested in that period of time.

 7             On the other hand, I as a human being have great difficulty

 8     speaking of consequences without mentioning the causes, and this is why I

 9     already voiced my objection, saying that this does not reflect my style

10     of work.

11             Now, to be more specific, in 1988, the Ministry of the Interior

12     of the Republic of Croatia, supported by some of then-compatriots -- or,

13     rather, some members of the parliament of Croatia at the time, adopted a

14     plan, asking that check-points be established and routes in Bosnia and

15     Herzegovina so that all those who did not have a university education

16     would be admitted into schools for national defence which they could

17     complete in an accelerated manner so that they could take up leading

18     positions in the Ministry of the Interior of Bosnia and Herzegovina, as

19     well as in other organs.

20             This was done in order to establish the pyramid principle by way

21     of which intelligence centres and check-points would be established for

22     certain regions.  So, for example, for the area from Bosanski Brod via

23     Derventa to Doboj to Maglaj, ending in Zepca and Zavidovici, this was a

24     channel used by operatives.  I know exactly the person who was in charge

25     of this.  His name was Marko Lukic.  He was a commander of the

Page 11046

 1     Special Detachment of the Republic of Croatia, and his first assignment

 2     was in combat near the Plitvice lake.  We who hail from that area know

 3     when this combat took place at the Plitvice lake.  This man was involved

 4     in a traffic accident.  He is still alive nowadays, but he had an

 5     accident in his BMW.  And without going into all the details, he managed

 6     to establish this connection via his brother, Stipe Lukic, who worked for

 7     the national defence in Doboj.

 8             And to everybody's great surprise, a rather young operative, such

 9     as Stipe Lukic, managed to recruit and engage many other people, even

10     reactivate some.  Some persons who were considered legendary in the

11     intelligence world, such as Ivan Curko via his brother, Marko Lukic, he

12     went to Zagreb and established contact with the then-assistant chief of

13     national security -- or whatever it was called at the time, I'm not quite

14     familiar with their terminology.

15             The same channels existed in other areas, such as Krajina and

16     some other regions.  The same method of establishing information hubs was

17     used by the Bosniak side.  I know exactly who were key Bosniak figures in

18     Banja Luka when it comes to collecting intelligence and creating

19     paramilitary formations.

20             Now, since this is a very broad topic, let me summarise.  It came

21     as no surprise to us long-term operatives.  Those who worked in the

22     State Security Service could observe all of this.  This was observed by

23     the Milos Group and by myself as an individual before the Milos Group was

24     established.  However, what lacked was the courage.  Had we done it in

25     time, had we acted in time, there would have been no war.

Page 11047

 1        Q.   Comrade Radulovic, I will show you now a report by the

 2     Milos Group which is of a later date but speaks of the same topic.

 3             MR. KRGOVIC: [Interpretation] Could we see 2D02-1611.

 4             MR. PANTELIC:  And, Your Honours, while we are waiting for

 5     document, just a small correction to the transcript.  It's at page 10,

 6     line 8, when this witness spoke about the book of well-known author,

 7     Ivo Andric, Noble Prize author.  He said that -- I mean, in transcript

 8     it's "Prokleta Avlija" in B/C/S, but the proper translation should be the

 9     "Damn Yard."

10             MR. KRGOVIC:  I apologise.  I went too fast in giving the number.

11     2D02-1611.

12             MR. OLMSTED:  Apologies, could you give us the tab number as

13     well?

14             MR. KRGOVIC: [Interpretation] That's tab 66 of the

15     Stanisic Defence.

16        Q.   You spoke of the name of the people, saying that you knew the

17     names of the people who had organised this in Banja Luka.  This is your

18     report, isn't it?

19        A.   Yes.  This is a short report of ours.  The information we have

20     about this phenomenon is much broader, much greater.

21        Q.   And those who conducted this illegal activity of arming the SDA

22     and who conducted this anti-state activity according to the standards of

23     your service are precisely these persons:  Jahic Bajazid occupied the

24     position of the chief of public security in the Banja Luka centre, right?

25        A.   Yes, correct.

Page 11048

 1        Q.   And while he held this position, since he was not a professional

 2     policeman and he had previously been the president of the executive board

 3     of the SDA, he directly communicated by a parallel structures with

 4     Avdo Hebib and Bosniak members in Banja Luka, right?

 5        A.   Well, yes, Mr. Krgovic.  I'm grateful to you for summarising this

 6     and asking me just to confirm or deny this.  The situation, however, was

 7     much more mixed up than could be gleaned from this dispatch.  You have to

 8     bear in mind that dispatches sometimes had to be rather brief and no

 9     explanations were given that could fully clarify just how well connected

10     and structured and effective this group was.

11             I don't know if you can gain the appropriate impression from this

12     report.  But, at any rate, what is stated here is correct.

13        Q.   Except for what we see here in this note, there is also some

14     mention of a different situation?

15             MR. KRGOVIC: [Interpretation] My colleague Mr. Zecevic suggests

16     that there was some unclarities in relation to these people, at least as

17     far as the translation was concerned.

18        Q.   Now, you're talking about an organisation an organised formation

19     or a group of Muslims who were arming themselves and structuring in a

20     military fashion?

21        A.   That's correct.  In a way, these were the most important such

22     people in the area of Banja Luka.  Among them you can find some extremely

23     rich people who owned millions upon millions and who used their own money

24     to support this supply of armaments and formation of units for a large

25     number of military formations, but each of the formation was a small

Page 11049

 1     unit.  I don't know whether you understood me correctly.

 2        Q.   So small mobile groups in order to be more difficult to discover

 3     but then linked up to form big formations.

 4        A.   That's correct.

 5        Q.   What we see here mentioned as a situation is a Serbian state

 6     security locating Mr. Becirevic who lived in Banja Luka and who provided

 7     them with information about the issue.  And as far as I know - and I

 8     would like to ask you to assist me with this - the Milos Group took part

 9     in the interview with this Becirevic person and took a statement from him

10     in relation to the arming of this group?

11        A.   Yes, that's correct.  This gentleman confirmed all that we knew

12     based on our operative work, but we didn't know the exact numbers, we

13     didn't know through which channels they obtained weapons, what's the

14     value of it.  These were little details we couldn't find out without

15     interviewing him and some other people he pointed out to us.

16        Q.   During your conversation or interview of this person, you were

17     not forcing him, you were treating him fair.  He gave you the information

18     voluntarily.  He even accepted to work with the service, and he asked to

19     be placed somewhere else and become a source for you?

20        A.   We are entering issues that of intelligence nature, so if we

21     could ...

22             MR. KRGOVIC:  Can we move into a private session now.

23             JUDGE HARHOFF:  We didn't hear him ask for private session.  Was

24     that the idea?

25             MR. KRGOVIC:  I have asked for it, but it didn't enter the

Page 11050

 1     transcript because the witness told us that we are reaching information

 2     that he wouldn't want to say publicly.

 3             THE WITNESS: [Interpretation] It does not involve persons but

 4     methods of work.

 5             MR. KRGOVIC: [Interpretation] Yes, I understood it like that.

 6             THE WITNESS: [Interpretation] Thank you.

 7             JUDGE HALL:  Yes, so we move into private session.

 8                           [Private session]

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18   (redacted)

19                           [Open session]

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

21             MR. KRGOVIC: [Interpretation] I would like to tender this

22     document and receive a number for it.

23             JUDGE HARHOFF:  Before you do so, Mr. Krgovic, could you

24     enlighten us as to who was this message sent to?  If you read the

25     dispatch, it seems to be a reply to an Official Note.  Who was the

Page 11053

 1     recipient of this dispatch?

 2             MR. KRGOVIC: [Interpretation]

 3        Q.   You've heard the question put to you by the honourable judge.

 4     Based on this, I think it was sent to the Serbian RDB?

 5        A.   Yes, that's correct.  You understood me.  I thought it was

 6     obvious.  But, yes, I can confirm that.

 7             MR. PANTELIC:  I do apologise.  Your Honour, maybe it's a

 8     mistake.  It's page 19, line 19, it's "Official Note," not

 9     "unofficial note."  That's the part of the document.

10             MR. KRGOVIC: [Interpretation]

11        Q.   Just another correction for the transcript, when mention of

12     Serbian security is concerned, in the transcript it says RDB, and you

13     mean the Republic of Serbia state security, right?

14        A.   That's right.

15             JUDGE HARHOFF:  Mr. Radulovic, do you know whether this dispatch

16     was also brought to the attention of the MUP of Republika Srpska?

17             THE WITNESS: [Interpretation] Yes, they were informed about that.

18     This went through regular mail, Your Honours.  The first person who was

19     informed about this was Vojin Bera, who was chief of number 1 -- of 01 in

20     the state security of the Banja Luka centre.  And this can be confirmed

21     by the fact that this very report was found in their archives.

22             JUDGE HARHOFF:  I'm just curious to know because I'm not sure

23     that I have fully understood the implications of your parallel providing

24     information to Serbia as well as to the RS.  And judging from this

25     dispatch, it would seem that you were in a dialogue with the Serbian RDB

Page 11054

 1     about events happening in -- in Bosnia and Herzegovina, as late as in

 2     June 1992.

 3             I'm not sure I fully understand the reasons why you had this

 4     communication with the Serbian authorities and -- and what the

 5     implications of it were, in terms of the Serbian authorities'

 6     communications with the authorities of the Republika Srpska.

 7             Can you clarify this, if you know?

 8             THE WITNESS: [Interpretation] I will do my best to clarify this.

 9             As an operative, I wasn't all that much interested in

10     relationships between political institutions and organs, the authorities

11     of Republika Srpska and Serbia.  What I know is that I was linked with

12     the state security of Serbia for several reasons.

13             The first reason was something that's identical to the reason why

14     Bosniaks from Banja Luka were linked up with Sarajevo or Zagreb.  Namely,

15     because I understood that the question of the Serbian People cannot be

16     resolved partially only at the Banja Luka level or only at the

17     Bosnia-Herzegovina level, but only as an issue to be dealt at the level

18     of the Socialist Federative Republic of Yugoslavia or what remains of

19     this country.  So I wanted, for the people in the country that I see as

20     my home country, to know what are the risks and what comes out from the

21     intentions of these entities or autonomous provinces and so forth.

22             That was one motive.

23             The other motive was the issue of not-yet-defined relationship

24     with the JNA because we had rather poor communication between us and

25     them, meaning intelligence they gathered they should send to us so that

Page 11055

 1     we would know how to organise ourselves.  And also, for us, for our

 2     parts, to take information that we have that are not related only to

 3     Banja Luka so that such information would be submitted to the centre, to

 4     the base, so that the base or the home would be able to use such relevant

 5     information.

 6             And the third reason or motive, although I could enumerate more

 7     motives, but the third was that there were many of us in the

 8     State Security Service who could not part ways so easily and forget about

 9     the Socialist Federative Republic of Yugoslavia and the services that

10     existed at the federal level.

11             And, Your Honours, I would really like you to understand that our

12     linking up with the state security was for the purpose of preventing

13     crimes, of all crimes against any potential victims.  To be honest with

14     you, I am proud to say that thanks to the service, the

15     State Security Service, we managed to save many people and prevented them

16     from disappearing from the face of the earth.  Well, that would be all.

17             I don't know whether you've understood me.

18             JUDGE HARHOFF:  Maybe I did.  Thank you, Mr. Radulovic.

19             You made reference to what you called the "question of the

20     Serbian People."

21             And I understood from your answer to me that the question of the

22     Serbian People would require that you exchanged information with the

23     Serbian intelligence authorities, with the Serbian SDB.  And I also

24     understood from your answer that, in fact, you did receive valuable

25     information from the Serbian side which would enable you to provide a

Page 11056

 1     clearer picture and an overview of the situation.

 2             And then you went on to say that you did all of this in order

 3     to -- to prevent crimes from being committed, yet you were also aware

 4     that, in fact, crimes were committed; on both sides, yes.

 5             So did it ever occur to you that, as much as you thought that

 6     your activity would prevent crimes from happening, they might also, on

 7     the other hand, actually promote the commission of crimes?

 8             THE WITNESS: [Interpretation] Your Honour, I never doubted for a

 9     moment that you would understand me correctly, and you have understood me

10     well, in terms of everything that I have said.  But as for whether we

11     were able to actually assess whether there would be omissions, of course.

12     Of course, we were aware that there would be omissions and that some

13     things may occur.

14             But, you know, if you save a single human life, as the Israelis

15     would put it, then you have saved the whole world.  And that is what

16     guided us.  We wanted to save those that we could within our limitations.

17             But, of course, I did not at any moment imagine that I was a

18     Messiah or some kind of saviour.  But, of course, was wasn't able nor

19     were my superiors able to keep everything under control.

20             JUDGE HARHOFF: [Previous translation continues] ... to you,

21     Mr. Krgovic.

22             JUDGE DELVOIE:  Just one moment, please.  Mr. Radulovic, a small

23     detail.  Can you give us the first name of Mr. -- what was his name

24     again?  Sorry.  Becirevic.

25             THE WITNESS: [Interpretation] I really cannot recall at this

Page 11057

 1     point.  I can't remember his first name now as I sit here.

 2             But I'm sure you can find that in your information.

 3             JUDGE DELVOIE:  Thank you.

 4             JUDGE HALL:  [Previous translation continues] ... admitted and

 5     marked.

 6             THE REGISTRAR:  Thank you.  Exhibit -- this will be Exhibit 2D84,

 7     Your Honours.

 8             MR. KRGOVIC: [Interpretation] Your Honour, responding to

 9     Judge Delvoie's question, I will look up the first name in one of the

10     earlier statements.  And then after the break maybe we can show the

11     document to the witness so that he can authentic it.  I didn't want to go

12     in such detail, but we will show him the statement.

13             JUDGE DELVOIE:  Thank you.

14             MR. KRGOVIC: [Interpretation]

15        Q.   I will now show you another document that is related to what you

16     were telling us about.

17             MR. KRGOVIC: [Interpretation] Could we now please see 1D03-3395

18     in e-court.  In Stanisic's tab, that's under tab 56.

19             Could we have the second page of this document, please, shown to

20     the witness.

21             MR. OLMSTED:  Do we have an English translation of this document?

22             MR. KRGOVIC:  I think we have.

23                           [Defence counsel confer]

24             MR. KRGOVIC:  I'm not sure, but I check.

25        Q.   Anyway, I ask witness to -- I will ask witness to see the report

Page 11058

 1     and the -- in the [indiscernible] the signature and the date.

 2        A.   This is a report by the Milos Group dated 3 June 1992.

 3             MR. KRGOVIC: [Interpretation] Could we now go back to page 1,

 4     please.

 5             MR. OLMSTED:  I'm sorry, before we ask any questions about this

 6     document, the Prosecution raises the same objection as it did last

 7     Friday, which is until we have an English translation, it's not

 8     appropriate for a witness to be cross-examined about the document.

 9     Neither the Trial Chamber nor the Prosecution can confirm what the

10     witness is saying is consistent with the document that we're looking at.

11             And, therefore, we'd ask that we get a translation before any

12     questions are asked about the document.

13             JUDGE HALL:  Mr. Krgovic, I would have thought that this would

14     have --

15             MR. KRGOVIC: [Interpretation] Your Honour, I do not intend do put

16     any questions to the witness related to this document.  I will only ask

17     him about the events underlying this document.  And when we do get a

18     translation, I will have it uploaded.

19             In other words, I will not use this document when I put my

20     questions to the witness.

21             JUDGE HALL:  So what's the point of putting it up?

22             MR. KRGOVIC: [Interpretation] Your Honour, I wasn't aware that

23     there was no translation uploaded.  I was informed that we did have a

24     translation but it hasn't been uploaded yet.  So it's really a technical

25     issue.

Page 11059

 1             Therefore, I suggest that I just ask the witness about the event

 2     itself and nothing to do with the document itself.

 3             JUDGE HALL:  Yes.

 4             MR. KRGOVIC: [Interpretation]

 5        Q.   Mr. Radulovic, you must be aware that in Simici, in Banja Luka

 6     municipality, Simici village, Banja Luka municipality, there was a

 7     Croatian unit which had -- which was well-armed and organised as a

 8     military unit; correct?

 9        A.   Yes.  But it was not a military unit; it was a paramilitary unit.

10        Q.   At this time, in other words, in July 1992, had you a list of

11     names of those individuals who were armed and the weapons that they had;

12     correct?

13        A.   Yes.  But this is not the only list.  And this is not the only

14     area where there were armed units.

15             I would like to remind you, because you remind me -- you keep

16     reminding me all the time of things, so let me remind you that in 1989 we

17     learned that in the Cazin Krajina, in the Cazin district, in the

18     Velika Kladusa area, there was an armed Bosniak unit which numbered

19     approximately, according to what we learned, which numbered -- or was

20     company-strong.  And that they were organised as a military unit,

21     following military rules, and now, if I tell you that we were able to

22     confirm this information -- or, rather, that this is corroborated in a

23     book that was published in Velika Kladusa after the war, it was published

24     by the chairman of the Executive Board, or Executive Council of

25     Velika Kladusa during the war and one of the closest associates of a

Page 11060

 1     well-known politician from that area.  And this man said in his book, in

 2     this memoire of his, he provided a photograph of one of those units and

 3     dated it as having been taken in 1989.

 4             Now, this information that we had from this period was, as we

 5     see, confirmed some ten years after the fact, and it is even more tragic

 6     that no one at all paid any attention to this bit of information that we

 7     provided.

 8             MR. KRGOVIC: [Interpretation] Your Honour, I believe this would

 9     be a good time for a break.  And in the meantime, we will have the

10     document translated -- or, rather, the translation of the document

11     uploaded.

12             So if could I just get a MFI number, please.

13             JUDGE HALL:  Yes, Madam Registrar.

14             THE REGISTRAR:  Exhibit 2D85, marked for identification,

15     Your Honours.

16             JUDGE HALL:  So we take the break now.

17                           [The witness stands down]

18                           --- Recess taken at 10.25 a.m.

19                           --- On resuming at 10.50 a.m.

20             THE REGISTRAR:  Your Honours, just to correct the transcript.  On

21     page 7, line 8 of today's transcript, 30 documents are assigned numbers

22     1D287 to 1D316; and document P75, MFI'd on 7th October, 2009, will become

23     exhibit now.

24             JUDGE HALL:  Thank you.

25                           [The witness takes the stand]

Page 11061

 1             MR. KRGOVIC: [Interpretation]

 2        Q.   Comrade Radulovic, we were dealing with a document.

 3             MR. KRGOVIC: [Interpretation] And, Your Honours, in the meantime,

 4     I was told that this document -- or, rather, its translation is now in

 5     e-court.  So I would like to ask for the 1D03-3395 to be uploaded.

 6     That's D285 [sic].

 7             I apologise, Your Honours.  I won't be needing this document

 8     then.  We'll deal with it at the very end when I have an official

 9     confirmation that it's been entered into the e-court system.

10             Can we please have 1D03-2061.

11             MR. OLMSTED:  And if you could just provide us with a tab number.

12             MR. KRGOVIC: [Interpretation] This document is the last document

13     on our list.  I think it was added -- it's 41.

14        Q.   What we have here is a statement by Dzemo Becirevic, a statement

15     to the SNB sector in Banja Luka.  And it's related to a political linking

16     up of SDA in Banja Luka and procurement of weapons, all related to his

17     escape from Banja Luka.

18             On page 1, as well as on page 2, he discusses the issues related

19     to the organisation of the party.

20             MR. KRGOVIC: [Interpretation] Can we please have page 2 of the

21     document, where he is stating the following.

22             Page 2, please.  In the B/C/S version as well, please.

23             Can we have the last paragraph zoomed in.  I think ... in the

24     English version, it's the first paragraph; in the B/C/S version, it's the

25     last on the page.

Page 11062

 1        Q.   It says that from the nine sub-branches, five military formations

 2     were established in the sub-branches with a Muslim majority?

 3             In the second sentence, we can read that each of the military

 4     formations numbered around a hundred men armed with automatic rifles, and

 5     a sub-branch president was simultaneously the commander of the military

 6     formation.

 7             MR. KRGOVIC: [Interpretation] Can we please have page 3 in the

 8     B/C/S, and in the English version, it's still the first paragraph related

 9     to the settlement of Novoselija.

10             Here it is stated:

11             "I know that the president of the Novoselija sub-branch

12     Bajazid Jahic was the chief of the Banja Luka SJB and that he personally

13     brought the weapons from Sarajevo in a truck and distributed them to the

14     presidents of the five sub branches with a Muslim majority."

15             Mr. Radulovic, the information contained in this statement, is

16     this what you referred to when you said that you can elaborate on this

17     issue?  Is this exactly what you had in mind?

18        A.   Yes.  Thank you.  This, what you've presented, is much more

19     credible than any statements I may make about it.  But, yes, that is

20     exactly it.

21             JUDGE HARHOFF:  Mr. Krgovic, I didn't see the date of this

22     document.  Can you remind us?

23             MR. KRGOVIC: [Interpretation] Your Honours, we can see it on

24     page 1:  22nd September, 1992.  On the first page of the document.

25             JUDGE DELVOIE:  And is this a report of the Milos Group?

Page 11063

 1             JUDGE HARHOFF:  No, it is [Microphone not activated]

 2             MR. KRGOVIC: [Interpretation] No, Your Honours.

 3        Q.   Let me show you the last page of the document.  This is a record

 4     of a statement given by Dzemo Becirevic.

 5        A.   Yes.

 6        Q.   It was taken by the National Security Service, Banja Luka.

 7             MR. KRGOVIC: [Interpretation] Can we please have the last page of

 8     the document?  Yes, thank you.

 9        Q.   In accordance with the rules of the time, we can see on the

10     left-hand side who provided the statement.  Next to it is the recording

11     clerk.  And then we have initials of the persons taking the statement.

12        A.   Yes, that's correct.

13             MR. KRGOVIC: [Interpretation] Could we please have the first page

14     of the document back on the screen.

15        Q.   It shows the circumstances under which the statement was taken.

16             The statement starts with the words:

17             "I gave the first statement before the SNB inspectors on

18     20 September 1992.  Since they have treated me fairly, I decided to tell

19     them the real truth regarding the political and military organisation of

20     the SDA party in Banja Luka and the circumstances of the purchase and

21     smuggling of weapons and my flight from Banja Luka."

22             From this, Mr. Radulovic, we can see that the operatives who were

23     taking the statement treated him fairly, which was something that you

24     that told us about already, that there was no coercion involved.

25        A.   I personally interviewed Mr. Becirevic.  That was this incident

Page 11064

 1     when he was kidnapped from us and other people signed.

 2        Q.   I have shown you several pages of the document.  If you want, I

 3     can even give you a copy of a document so that can you go through it and

 4     tell me whether everything is correct.

 5             MR. KRGOVIC: [Interpretation] Your Honours, instead of going

 6     through it via e-court, maybe this would be ...

 7             JUDGE HARHOFF:  Mr. Radulovic, you just mentioned that you

 8     personally interviewed Mr. Becirevic.

 9             Did your interview with him form the basis of Becirevic's

10     statement, which we now have in front of us; or did you interview him

11     long before his statement was given?

12             THE WITNESS: [Interpretation] The interview lasted several hours.

13     After having heard him, we started taking the official statement.  That

14     was the modus operandi.  Then, and today as well, according to the law, a

15     statement was taken from him.  He was warned about everything as

16     prescribed by the law, and this is his personal statement.  In other

17     words, neither I or the operatives who conducted interview put any

18     constructions of ours and incorporated it into the statement.  No, this

19     is his statement.  This statement, in this form, in this style, was

20     something that was also recorded for a camera.

21             JUDGE HARHOFF:  Let me put my question to you in a different way

22     then.

23             Do you recall when in September of 1992 you interviewed

24     Mr. Becirevic?

25             THE WITNESS: [Interpretation] I'm certain it was on the

Page 11065

 1     22nd of September, 1992, but I do not exclude the possibility, namely, I

 2     told you that we've had several conversations.  Before you reach the

 3     stage of a statement, before you've opened him up, before you've conduced

 4     him to give you a statement to -- before you make sure that he understood

 5     that your intentions are good, which is something that experienced

 6     operatives know how to do; so, in short, I may have had conversations

 7     with him prior to this and maybe even after the taking of the statement.

 8     But the statement was taken on the 22nd of September, 1992, as you can

 9     see in this document, in the record.

10             Your Honour, it is stated here that it was taken as defined by

11     Article 151 of the ZKP, but my colleagues would know that the practice at

12     the time, it was not required to record all the things the client or

13     party was warned about.  You can see at the end of the statement recorded

14     that the person who gave the statement read his statement and that by

15     signing it he confirms its accuracy.  That's how things were done then;

16     that's how things are done now.

17             JUDGE HARHOFF:  Do you -- thank you.  Do you recall who were

18     present during the interview with Mr. Becirevic, apart from yourself?

19             THE WITNESS: [Interpretation] Yes.  I stated that

20     lieutenant-colonel -- or, rather, at the time he was Major Bogdanic; then

21     my colleague, Goran Sajinovic.  Occasionally present was a person who

22     operated the camera; I can't remember his name.  And then occasionally

23     some of the people from our operative branch would enter the room, and

24     some of the military security employees as well.  But I can't remember

25     who because that was a long time ago.

Page 11066

 1             JUDGE HARHOFF:  Thank you.

 2             MR. KRGOVIC:  Can I have an exhibit number for this document.

 3             JUDGE HALL:  Admitted and marked as ...

 4             THE REGISTRAR:  As Exhibit 2D86, Your Honours.

 5             MR. KRGOVIC: [Interpretation]

 6        Q.   Comrade Radulovic, I would like to ask you to take a look at

 7     another document related to the activities of the Milos Group.

 8             MR. KRGOVIC: [Interpretation] It's 1D00-3294.

 9             JUDGE DELVOIE:  Can we have a tab number, please.

10             MR. KRGOVIC: [Interpretation] 53 in the Stanisic Defence

11     register.

12             JUDGE DELVOIE:  Thank you.

13             MR. KRGOVIC: [Interpretation]

14        Q.   Mr. Radulovic, for the purpose of illustrating your activities,

15     this is why I'm presenting this document to you.  And I would like you to

16     take a look at page 3 of this document.

17             This is a report by Milos?

18        A.   Yes.

19             MR. KRGOVIC: [Interpretation] Let us go back to the previous

20     page -- or, rather, the first page; I apologise.

21        Q.   What we see here is a partial list of members of Patriotic League

22     from the area of Prijedor.  Only one company -- or, rather, only one

23     platoon.  You knew about more, but this is just one segment of your work

24     presented here.

25             Can you confirm that this is accurate?

Page 11067

 1        A.   Yes.  This is just a partial view of one military unit.  We

 2     received our information from a rather large number of associates.  And

 3     according to rules of the service, these -- the information contained in

 4     here is absolutely accurate.

 5             I know that we also had information concerning the fact that the

 6     wider area of Prijedor, Trnopolje, Kozarac, and Omarska, there were about

 7     1200 members of the Bosniak people bearing arms.  For all of these people

 8     who were armed, we had lists similar to this one.  We also had

 9     description of what kind of weapons they had.  We also had a list which

10     showed that they had artillery pieces, which I understand you will know

11     is not something used in civilian purpose.

12             MR. KRGOVIC: [Interpretation] Could I have a number for this

13     document, please.

14             MR. O'SULLIVAN:  Your Honour, just one observation.  The previous

15     document which was given 2D86 was previously MFI'd as 2D85 before the

16     break.

17             THE REGISTRAR:  No.

18             MR. O'SULLIVAN:  No?  Well, if I'm mistaken, I apologise.

19                           [Trial Chamber and Registrar confer]

20             JUDGE HARHOFF:  Mr. O'Sullivan, 2D85 was the Milos report of

21     3rd June; whereas 2D86 was the statement by Becirevic dated the

22     22nd of September.  So they're two different documents.

23             MR. KRGOVIC: [Interpretation] Yes, it is two different documents;

24     I can confirm this for the Registrar.

25             JUDGE HALL: [Microphone not activated] ... admitted and marked.

Page 11068

 1             Well, Mr. Olmsted.

 2             MR. OLMSTED:  Yes, Your Honour, I just wanted to note that I

 3     think this document was tendered through Mr. Zecevic as amongst his

 4     31 documents, so I think it has already been given an exhibit number.

 5             Oh, I'm wrong.  I have the wrong list then.

 6             JUDGE HARHOFF:  But, Mr. Krgovic, apart from this, I have a

 7     question about the relevance of this document.  It shows that the Muslims

 8     were arming themselves and -- and I think there's no question about this.

 9     This is not contested by the Prosecution, and it's well established

10     already in the evidence we have.

11             So why would you wish to put yet another document in to show

12     this?

13             MR. KRGOVIC: [Interpretation] Well, this is why:

14             We want to show that not only did they have weapons, but they

15     were also organised as a military unit.  That is our first argument.

16             As a result, a conflict broke out.  They attacked the Army of the

17     TO of the Republika Srpska, and then there was -- there were some

18     prisoners taken, war prisoners, who had been captured at Kozarac and

19     handed over to Omarska which was a military camp, or camp of prisoners of

20     war, and they had the status of prisoners of war.

21             JUDGE HARHOFF:  The information from the Registrar seems to

22     exhaust my concerns because it appears that this document is already in

23     evidence as 1D200, if I'm correctly informed.

24             THE REGISTRAR:  312, Your Honour.

25             JUDGE HARHOFF:  Mr. Krgovic, please move on.

Page 11069

 1             MR. KRGOVIC: [Interpretation]

 2        Q.   Comrade Radulovic, we have exhausted all these documents, and I

 3     will no longer refer to them.  I might occasionally have to refresh your

 4     memory to help you recall a fact.

 5             But, generally speaking, the picture that we can get from your

 6     reports is that in the Banja Luka area, and especially in some areas of

 7     the Banja Luka district, there were a number of paramilitary units, both

 8     on the Bosniak Muslim side and the Croat side; correct?

 9        A.   Yes.

10        Q.   In fact, the intelligence work of Milos, as part of state

11     security, or, rather, the National Security Service, was to gather -- or

12     consisted in gathering intelligence information on such groups, as well

13     as some events that were of security -- of security concern for -- of the

14     security of Republika Srpska; correct?

15        A.   Correct.  But I would like to add that we also gathered

16     intelligence that were also of relevance for Republika Srpska and not for

17     Banja Luka alone.

18        Q.   And in some cases, which involves state security matters, you

19     also interviewed certain individuals so that your work actually included

20     more than just gathering intelligence.

21        A.   Of course.  Whenever we assessed that that was necessary because

22     of the circumstances and also when we assessed that it was on us to do

23     that.

24        Q.   This brings me to the next topic, which is the scope of work of

25     the State Security Service and the various methods used by these two

Page 11070

 1     different services, the public security service and the State Security

 2     Service, because these are two quite distinct areas of work.

 3             Could you please assist and describe this better?  Perhaps my

 4     wording was not -- was a bit clumsy.  Perhaps can you make the

 5     distinction between the two services.  But what I'm trying to say is that

 6     the State Security Service has a special method of work as well as a

 7     special area of work.

 8        A.   Well, to put it in brief, what we did was intelligence and

 9     counter-intelligence.  Everything else was logistics, logistical support,

10     as it were.  And there is another distinction:  The so-called border

11     area -- or, rather, external security operations as well as internal.  So

12     when we say external - and I'm talking about the former Yugoslavia - this

13     referred to the territory outside of the Yugoslavia.  We were most

14     concerned with groups, ethnic groups, abroad -- extremist ethnic groups

15     abroad, coming from this area; but we were also interested in other

16     intelligence that other intelligence services would also like to obtain

17     in the former -- in the former Yugoslavia and then later on in the

18     Republika Srpska.  So that this wide scope of our operation -- because,

19     for instance, in addition what you have seen here, I was also involved in

20     special activities relating to members of transcendental meditation,

21     members of the Adventist Church, members of the Maharishi Sect, and so

22     on, Rotary Club et cetera, and so forth.

23             So my activity and my involvement was multi-faceted, and it is

24     from that time that I actually had made a lot of acquaintances and

25     contacts.  So I had contacts with members of military security and

Page 11071

 1     members of State Security Services in each and every republic of the

 2     former Yugoslavia because no one else had anything to do with those

 3     documents at the CSB at Doboj but me.  And also, I was also interested,

 4     in a way, in the theoretical aspects of those groups, and I still have

 5     some of those documents in my private possession.

 6        Q.   On the other hand, the public security service has another field

 7     of operation, and when we speak of crimes, it would be the crime service

 8     that would actually discover and fight crime.  That was not part of your

 9     work, correct, that was public security?

10        A.   Yes.  Well, as for the methodology, I -- well, let me wait for

11     interpretation.

12        Q.   You may go on.  Please complete your sentence.

13        A.   Well, I'm waiting for the interpreter to finish.

14             As for the method of work of the State Security Service, it is by

15     it's very nature conspiratorial or secret; and in the one-time

16     Law on Criminal Procedure, it was exempt from that law.  In other words,

17     there was a law -- there was a -- an Article in the Law on Criminal

18     Procedure which provided for our freedom to conduct certain activities

19     which no other service in the former Yugoslavia was allowed to do.

20             I apologise, Mr. Krgovic, but I cannot really discuss the details

21     in open session because this would encroach on security interests of the

22     present services because they adopted the -- an identical method of work,

23     and I wouldn't want to be misconstrued by someone in the area where I

24     have to go back to.

25        Q.   I will not dwell on the details of the method of work.  We also

Page 11072

 1     have people in the public gallery, so we don't want to go into closed

 2     session now.  I will return to that a little later.  But I'm just trying

 3     to show that there is a clear distinction in the spheres of work of the

 4     public and the State Security Services.  Correct?

 5        A.   Absolutely.  You know, for a while, I also worked for the public

 6     security service.

 7        Q.   When you send a report, a Milos report, the information contained

 8     therein are treated as intelligence information -- or, rather, evidence

 9     of certain events or a certain -- certain facts; correct?

10        A.   Yes.

11        Q.   And your Milos reports actually contain information that would be

12     indicia that a certain event had occur, and you will agree with me that

13     the difference between indicia and evidence or proof, there is a long way

14     to cover in order to check the facts and confirm them, and, of course,

15     also, collecting proof for that?

16        A.   I will try to use the technical terms here.

17             We are now talking about underlying information.  When you have a

18     number of indirect facts or indicia and they actually coincide, then they

19     can become proof.  So by properly drawing conclusions, they become

20     evidence.  Once you check the original information, they are no longer

21     hypothesis; they become postulates.  And as a colleague, you will know

22     that postulates are irrefutable facts, and some of this information

23     actually had the quality of proof -- or, rather, postulates and not just

24     indirect proof or indicia.

25        Q.   When I asked on page 38, line 19 -- or, rather, 20 to 23, I was

Page 11073

 1     referring to indicia.  I have to make a correction in the transcript

 2     because I think the two -- we understand each other, but I'm afraid the

 3     interpreters did not understand us.

 4             So when I talked about indicia, I was actually talking about

 5     indirect evidence.  For your -- so let us go back to the way you work.

 6     So when you get -- receive certain information at the centre, 01 receives

 7     them at the service, based on that information, the analysts should

 8     actually review all those facts and put them together to provide an

 9     analysis and a foundation which then you would have to check, and then it

10     would also relate them to other indicia or other facts, and this then

11     serves as a foundation for an analysis of an event or an incident or a

12     situation, a specific situation.  Correct?

13        A.   Yes.  Yes, but, in fact, Milos Group had an obstacle to overcome,

14     and that obstacle was called Vojin Bera, who had turned into both an

15     analyst and an authorised official who assessed the value of information

16     received based on the source and not based on the very substance of the

17     intelligence gathered.

18             If we were -- if we, for instance, provided an information

19     report, a written information on Kotor Varos, for instance, his duty was

20     to forward it to the chief of national security of Kotor Varos - and

21     the same was true for all municipalities - and then those people on the

22     ground would have to complete this picture by collecting additional

23     information, which we had just indicated, as you said, and then they were

24     supposed to get back to us so that -- so there was supposed to be

25     feedback so that it can be determined whether these were just indicia or

Page 11074

 1     facts.

 2             Now, he took it upon himself to keep the information for himself.

 3     Very frequently, he would not forward it to his superiors.  And, which is

 4     worse, he had a great influence on the then-chief of National Security

 5     Service, Nedeljko Kesic, who trusted him completely, believing that he

 6     was an experienced operative of the State Security Service; and Kesic, in

 7     fact, was an inexperienced official of the State Security Service.  And

 8     this is where the ghost was put back in the machine or the lid was put

 9     back on Pandora's box, and so a lot of the information that we collected

10     never went further; they remained with Bera or with Kesic, but it was

11     accompanied by Bera's assessment or evaluation of that information.  And

12     this is why I find myself in a position today to be reminded of various

13     reports, information reports, that had been drafted before the events in

14     Sijekovac, Teslic, and many others.  Whereas, had that information been

15     evaluated properly, probably many of the tragic events would never have

16     unfolded.

17             Now, please understand me.  I'm not referring here only to the

18     misfortunes that befell the Serbian People.  I'm primarily referring to

19     the nature of that information, the confidential nature of that

20     information; and in this, this also explains the belated reaction to what

21     happened in Trnopolje, in Koricanske Stene, in many other places where

22     the largest number of people who died or were killed were innocent

23     people.  And this is why I'm in a situation, where, to this day, I

24     believe that because of this -- the improper conduct of my immediate

25     superior, many people found their deaths, although they were innocent.

Page 11075

 1             MR. KRGOVIC: [Interpretation] 41, 8, what's missing in the

 2     transcript is Keraterm and Omarska.

 3        Q.   There's another additional problem related to your work, was your

 4     pro-Yugoslav orientation and affiliation, namely, you did not hide your

 5     views when you were looking for associates among the Croats and Muslims;

 6     you used this -- had you to use this to establish a connection.  Is that

 7     correct?

 8        A.   Partially.  I always clearly stated who I was, what I was.  None

 9     of you have ever visited my office where I'm a lawyer, but in any of my

10     offices one would have found a picture of Josip Broz Tito, or his bust,

11     and other paraphernalia managed to collect related to

12     Socialist Federative Republic of Yugoslavia, national liberation

13     struggle, and so forth.

14             And let me correct you just in one segment.  Namely, you said

15     that I was doing that to gain trust of Bosniaks.  Well, that's not true.

16     Among those of the Bosniak people who were of the same views, or of the

17     Croat people who were of the same views, they understood that we had same

18     views all together.

19        Q.   You may have misunderstood me.  What I wanted to say was that

20     this view of your, this position of yours, pro-Yugoslav character

21     position, helped you establish better contacts with members of Bosniak

22     and Croat ethnic groups who trusted you then?

23        A.   Who trust me still today.  My friendships established before are

24     still ongoing.

25        Q.   Of course, this position of yours was something that caused some

Page 11076

 1     of the employees of your service to view you as a traitor, as an enemy to

 2     the Serbian People.  They had resistance in regard to trusting you.

 3             Am I correct?  Or let me summarise that.  I'll show you a

 4     document --

 5        A.   I can answer.

 6        Q.   No, I'll show you a document where you make some statements of

 7     this nature.

 8             MR. KRGOVIC: [Interpretation] It's 1D03-3403, please.

 9             JUDGE DELVOIE:  Tab number, please.

10             MR. KRGOVIC: [Interpretation] I apologise, 63; Stanisic tab.

11             JUDGE DELVOIE:  Thank you.

12             THE WITNESS: [Interpretation] Yes, I can see it.

13             MR. KRGOVIC: [Interpretation]

14        Q.   This is your report, Milos Group report?

15        A.   Yes.

16        Q.   What I wanted to say -- I may have summarised the document not

17     clearly.  What you said here is that you have problems in communication

18     with your colleagues who do not understand you and cause problems in your

19     work.

20        A.   I will try and provide you brief answers from now on.

21             Yes, your conclusion is correct and it's accurate, what you can

22     see here in the document.

23        Q.   And that was one of the reasons why people mistrusted you.  You

24     say here that for the purpose of protecting ourselves and to create

25     better conditions for our work, I would like to ask you to ask our

Page 11077

 1     colleagues to view us different and not as potential traitors and enemies

 2     of the Serbian People.

 3        A.   Yes, that's correct.  We've had lots of problems.  We were

 4     occasionally brought in.  Criminal reports were submitted in relation to

 5     some of our members.

 6        Q.   This is --

 7        A.   I apologise.  But there is just one sentence I would like to add,

 8     with your permission.

 9             It is very difficult to find yourself in a situation, either

10     during wartime or in peacetimes, where you discuss certain events and

11     trends that you condemn as a person that were committed by members of

12     your people because one is not forgiven for something like that, yet I

13     believe that all my actions and my testimony today and in the previous

14     days is something that's in the interests of the Serbian People.  And as

15     an old proverb says, one must divide chaff from wheat, separate chaff

16     from wheat, instead of putting everything into one basket.

17        Q.   And, in conclusion, consequence of this -- of this element, your

18     hard work in gathering information was not something that was treated in

19     an appropriate manner nor were your warnings an information analysed in a

20     proper way or forwarded.

21        A.   That's correct.

22        Q.   I used the word Strakhanovian.  This is something that we used in

23     our terminology in socialist times, meaning hard work.

24             MR. KRGOVIC: [Interpretation] Could we please have an number for

25     this document, Your Honours.

Page 11078

 1             JUDGE HALL:  Admitted and marked as ...

 2             THE REGISTRAR:  Exhibit 2D87, Your Honours.

 3             MR. KRGOVIC: [Interpretation]

 4        Q.   Comrade Radulovic, let me ask you about a specific set of events

 5     in Teslic.  You discussed this, but only briefly, during the direct

 6     examination, and I would just like to elaborate this in certain elements,

 7     to go through this operation you were at the head of.  And then I'll also

 8     show you a few documents.

 9             MR. KRGOVIC:  Just one more correction:  The word I used was

10     Strakhanov-like; that's 44:8.

11             Mr. Radulovic wouldn't know about that.  Strakhanov-like is

12     something that had to do with the Russian miners.  Strakhanov, who was a

13     world champion in terms of how much coal he managed to dig out.  So when

14     one uses this term "Strakhanov-like work," it means hard work, massive

15     work.

16        A.   Mr. Krgovic, thank you.  But I would have preferred had you used

17     Alija Sirotanovic because his shovel was bigger than the Russian guy's.

18        Q.   That's because we, from Montenegro, seem to be closer to the

19     Russians than --

20        A.   Yeah, that's why you are where you are now.

21        Q.   I will start with my questions concerning Teslic by asking you

22     about a meeting that was organised in the CSB building in the office of

23     Mr. Zupljanin.

24             During the direct examination, you told us who took part.  And I

25     would just like to go back to two of the participants.  One is

Page 11079

 1     president of the Court from Teslic, Mr. Kovacevic, and the public

 2     prosecutor, Mr. Peric.

 3             As I understood it, these people were invited to the meeting for

 4     several reasons.  I will give you two, and you can correct me if I'm

 5     wrong.  First reason was for them to confirm, together with Mr. Perisic,

 6     the information about the events in Teslic?

 7        A.   Yes, that's correct.

 8        Q.   The second reason:  It was necessary, after the arrest that was

 9     agreed at the time, and after the conducting of pre-investigation

10     process, it was necessary to -- to order a detention for the group of

11     people in Teslic, and only a court could have done that?

12        A.   Yes.

13        Q.   Their very presence at the meeting had that precise purpose,

14     namely, to avoid something that was happening up until that point, namely

15     that the police arrest some of the paramilitaries who would immediately

16     then be released and even threaten those who had arrested them.

17        A.   Yes.

18        Q.   I mentioned "those who were to be arrested."  I mentioned

19     military, paramilitary, para-police groups, because there were people,

20     especially in the early stages of war, when people were undefined in

21     their membership, as far as -- in which group they were?

22        A.   That's correct.

23        Q.   You were assured by those present at the meeting that once the

24     evidence was gathered, which was a task for your group, that they would

25     order detention for the members of the group and that, furthermore, their

Page 11080

 1     arrest will finally be something that will be brought before courts.

 2        A.   That's correct.  Maybe I can assist you here.

 3             Before setting off for Teslic, we were aware that everything will

 4     be done completely in accordance with the law in regard to documenting

 5     all the crimes committed by the group.  I was authorised, I was promised

 6     assistance, which enabled me to take inspectors, experienced inspectors,

 7     for the service who would help me do this completely in accordance with

 8     the law.

 9             In other words, this investigation was done in full keeping with

10     the law, with full respect of their rights -- I mean, the rights of the

11     detained, and it included interviewing all surviving witnesses as well as

12     members of families of those who were killed or tortured.  And we

13     collected all material evidence so that the criminal report -- and

14     believe me, I had written I don't know how many criminal reports, but

15     this criminal report had more evidence supporting it than dozens of

16     indictments I'm coming across nowadays before the courts in Bosnia and

17     Herzegovina.

18        Q.   If you want, we can go to private session, but could you please

19     tell us the names of the people who went with you?

20             MR. KRGOVIC: [Interpretation] Maybe it would be better to go to

21     private session.  Mices are still at large.

22             JUDGE HALL:  Yes, we would move into private session.

23                           [Private session]

24   (redacted)

25   (redacted)

Page 11081











11 Page 11081 redacted. Private session.















Page 11082

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9                           [Open session]

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

11             MR. KRGOVIC: [Interpretation]

12        Q.   Comrade Radulovic, before you got the assignment from

13     Stojan Zupljanin, you said that he seldom gave you any orders or anything

14     of the sort, but when it was discussed that somebody needed to go to

15     Teslic, he directly, as you said, ordered you to go to Teslic and arrest

16     and file criminal charges against the people who had committed the crimes

17     in Teslic?

18        A.   Yes, that's correct, as far as I can remember, but just a second

19     please.

20             That's precisely how it was.  As far as can I remember, that was

21     the first and only time that Mr. Zupljanin issued an order to me.  In all

22     our contacts up until that time, and after that time, Stojan Zupljanin

23     did that in a diplomatic form.  He wasn't a person issuing orders.  And

24     if I have a grudge against him, if I have something that I want to blame

25     him for, then it's precisely that, that he wasn't a person issuing

Page 11083

 1     orders.

 2        Q.   And in order for that operation to be carried out, in order for

 3     you to have legitimacy, you were appointed chief of the public security

 4     station in Teslic?

 5        A.   Correct.

 6        Q.   And that was done before you set out to Teslic.  You were

 7     appointed prior to that?

 8        A.   On the same day.  Or, rather, the day before; the day before the

 9     operation.

10        Q.   And, at the same time, it was said that you would remain there

11     for some time, until you put things at the station under control and

12     until you ensured that there was that satisfactory level of work at the

13     police station in Teslic.

14        A.   Correct.

15        Q.   And the Teslic operation was completed successfully.  The persons

16     who had committed crimes were arrested.  And as the arrest was in

17     progress, and there was an exchange of fire between your group and the

18     criminals, there were some casualties; and, as far as I could understand,

19     one of your men was killed and one person on the side of the Mice Group?

20        A.   Correct.

21        Q.   And, naturally, given the power and the brutality and level of

22     organisation of this group, you and the men that had set out from

23     Banja Luka established contact with the local military units, not at the

24     level of the command of Bilanovic, but at a lower level.

25        A.   Correct.  We didn't trust Dejan Bilanovic because we knew from

Page 11084

 1     before that he had been in contact with the Mice Group.

 2        Q.   And naturally you also had the political support of the local

 3     authorities of Mr. Perisic and the entire municipal leadership in Teslic.

 4     More or less.  I know, I know.  I have expanded the question.  But let me

 5     narrow it down.

 6             Mr. Perisic and the people around him?

 7        A.   Yes, you stated correctly.  Because not everybody supported me.

 8             Shall I tell you who didn't?

 9        Q.   Please do.

10        A.   One of the current politicians in power today, Stojicic.

11             Shall I tell you who else didn't?  The priest, Savo Knezevic.  I

12     didn't see him, I didn't perceive him as a politician, but at the time he

13     was the main figure.

14             Shall I give you more names?

15        Q.   Well, I'm interested in people who supported you.

16        A.   Fortunately it was the majority.  The majority of the Serbs who

17     supported me.  And as for these two, whose names I gave you, I don't

18     consider them to be great Serbs, at any rate.

19        Q.   And you also received assurances that the local police station,

20     where Mr. Markocevic was, also wouldn't stand in your way, nor would they

21     put themselves on the side of the Mice Group?

22        A.   Those who could have caused trouble for us, we managed to win

23     them over, to bring them over to our side.  Had we not done that, there

24     would have been ... I have no idea what would have been.

25             May I add a sentence?

Page 11085

 1        Q.   Please go ahead.

 2        A.   In that operation, the biggest problem arose when all of the

 3     soldiers from front lines, citizens of Teslic, and all civil population

 4     of Teslic wanted to join this operation.  We didn't want to have the

 5     front lines emptied from soldiers, and we knew that the more people

 6     participated, the greater there were chances for casualties.  That was an

 7     assessment I made as a reserve officer from the Bileca school, and I was

 8     top of my year while I was at that school, just so you know.

 9             Therefore, I wanted to have a operation that would involve as few

10     people as possible from the ratio was 1:3.  In areas where there were ten

11     of them, we would send 30 of ours.  And so on.

12             As for the rest who wanted to participate, we put them in reserve

13     forces.  We made sure they were not in the front.  It may look comical to

14     you now, but in just one location, in the Kardijal Hotel, at the

15     Vrucica Banja, we found 1200 casings from machine-gun bullets that had

16     been fired at us when we surrounded them at the hotel.  You can just

17     imagine there were perhaps some 20 of them there, just so you don't think

18     that all they had was slingshots.

19             JUDGE HALL:  Mr. Krgovic, it's time for the break, so if we

20     could -- if this is a convenient point.

21             Before we rise, the -- we received a motion from the

22     Office of the Prosecutor on the 27th of May in relation to a witness who

23     is scheduled to attend within the next three weeks.  It -- the -- the

24     application for that witness would be heard by videolink.  It appears to

25     be a matter without controversy, and we are inviting an expedited

Page 11086

 1     response from the Defence.

 2             20 minutes.

 3                           [The witness stands down]

 4                           --- Recess taken at 12.08 p.m.

 5                           --- On resuming at 12.32 p.m.

 6                           [Trial Chamber confers]

 7             JUDGE HALL:  The document that had been previously marked for

 8     identification, Mr. Olmsted, I take it you've seen the English

 9     translation?

10             JUDGE HARHOFF:  Of 2D85.  1D03-3395, Exhibit 2D85.

11                           [Prosecution counsel confer]

12             MR. OLMSTED:  Yes, we have the English translation.

13             JUDGE HALL:  And you have no reservations about the application

14     to exhibit it, having read it?

15                           [Prosecution counsel confer]

16                           [The witness takes the stand]

17             JUDGE HALL:  I thought it was a rhetorical question, but

18     apparently it isn't.

19             MR. OLMSTED:  Sorry, Your Honours, I just have -- too many

20     numbers that I can't remember the document.  But I have been reminded of

21     it, and we have no objection.

22             JUDGE HALL:  So we lift the MFI marking on it.

23             MR. KRGOVIC: [Interpretation] Let's continue.

24        Q.   Since we finally have the translation of this document, the

25     document we discussed, let me show you briefly 1D -- 2D85; I apologise.

Page 11087

 1             MR. KRGOVIC: [Interpretation] 2D85.

 2        Q.   That's the document you already saw.  It has the description of a

 3     number of persons.

 4             All right.  We have the English version now too.  It says that

 5     the persons listed below have weapons which were made available to

 6     protect the interests, and names of the HDZ?

 7        A.   Yes, yes, correct.

 8        Q.   All right.  We made a digression, but let us go back to Teslic

 9     now and the answers you provided to us.

10             You said that you managed to ensure the unity and consent of all

11     relevant authorities in Teslic municipality, civilian and military, and

12     you had the consent of the corps and a direct order from the Banja Luka

13     CSB to carry out that operation, right?

14        A.   Yes.

15             JUDGE HARHOFF:  I am wondering if there is any urgent need to

16     elicit yet more information on the Mice operation.  I think it has been

17     cleared and -- and we've heard a lot of it so far.  So unless you are

18     able to convince me that there is a compelling need to proceed into this

19     question, I suggest that you move on to something else.

20             MR. KRGOVIC: [Interpretation] No, Your Honours, I just need a few

21     more pieces of information, not really details.

22        Q.   And to conclude, so had you not been able to ensure this kind of

23     a support at the local level from the Crisis Staff, military authorities,

24     and so on, and the judiciary, this operation of yours -- it is not

25     certain how it would have been carried out, and it could have produced

Page 11088

 1     many casualties, and its outcome could have been uncertain?

 2        A.   Yes, you're absolutely right.  First of all, I could not have

 3     embarked upon that operation had there not been an order, had not the

 4     Banja Luka CSB stood firmly behind it.

 5             As for everything else, all the additional support, that was the

 6     prerequisite for us getting involved in that operation.

 7        Q.   You must know that in certain municipalities in the territory

 8     under the jurisdiction of the CSB, certain Crisis Staffs and certain SJBs

 9     were absolutely beyond the control of the CSB due to political reasons?

10        A.   Yes, that's the right reason, and I can enumerate additional --

11     or, rather, I can enumerate some examples.  The most prominent one being

12     Prijedor and Simo Drljaca, which represented a strong-hold that neither

13     the Banja Luka CSB nor the entire republic, as far as I know, could do

14     anything about.

15             Why do I say "as far as I know"?  Because, at the time, we tried

16     first via military security and then later on via the Tajfun to insist

17     on the removal the Simo Drljaca.  Don't ask me how we wanted to move him,

18     but we wanted to move him.  And our request was not granted.  They had no

19     understanding for our request.  Everybody kept saying that he had a

20     support of local political organs so that any operation along the lines

21     of the one carried out in Teslic could have resulted in serious

22     bloodshed.  And its outcome would have been completely uncertain, bearing

23     in mind that, at the time, Simo Drljaca had full support of the entire

24     army and police in that area.

25             Also, do not underestimate the fact that the strongest military

Page 11089

 1     units in Republika Srpska came from that area.

 2             I don't know whether you need additional information.  I can

 3     certainly tell you that.  There were some other SJBs that were also

 4     prominent in this sense.  The Prnjavor station tried to act in a similar

 5     way, as did Kotor Varos station for a while.  But there were certainly

 6     very strong pressures at the local level exerted so that it wasn't

 7     possible to communicate with people in a civilised manner.

 8        Q.   And to follow up, for the sake of transcript, when you said that

 9     Simo Drljaca had support of the army and police in that area, you were

10     referring to Prijedor?

11        A.   Yes, yes, I was referring to the local level.

12        Q.   And when this operation was completed and when the criminal

13     reports were filed and these people arrested and turned over to

14     authorities, to your surprise, if I may say so, two or three days later,

15     some of these people were released, Slobodan Karagic and some of his men,

16     and this was done on the basis of an order from the basic court in

17     Teslic?

18        A.   Correct.

19        Q.   And before that, had you threats coming from that group.

20        A.   Yes, yes.  But let me explain how come he and his group were

21     released first.

22             He came just one day before the operation, and this fact was

23     established.  Since it was also established who had killed one of our men

24     at the Kardijal Hotel, we knew exactly who killed him and how, then it

25     was a position of both the prosecution and the court, and I also

Page 11090

 1     acquiesced in that, that there was no evidence whatsoever that some of

 2     these people had committed a serious crime that would justify pre-trial

 3     detention.  So everybody who had arrived Teslic on the eve of the

 4     operation was released.

 5        Q.   And this man, Karagic, actually sued you after the war, but if I

 6     understood the list that you showed us --

 7        A.   There were three cases in court against me in Teslic.  One

 8     pursuant to an indictment submitted by the district prosecutor.  He --

 9     his name was Djuric.  And then when he actually annulled the crime -- the

10     criminal report submitted against me by the CSB in Doboj, this was

11     followed by a private suit initiated by Slobodan Karagic and

12     Stojan Djuric.

13             These proceedings were also completed or ended, and the court,

14     pursuant to the criminal report submitted by Slobodan Karagic, decided

15     not to conduct the proceedings, or, in other words, it remained

16     unresolved.

17             And as for Stojan Djuric, prior to his death, and he fell

18     seriously ill - he had cancer - so prior to his death, he actually

19     revoked his criminal report against me before a court -- or in court, and

20     he addressed the court on that occasion, apologising to me, to me

21     personally.  I accepted his apology because I knew -- I knew that the

22     outcome of his disease was very predictable and that he only had days to

23     live.

24             MR. ZECEVIC:  I'm sorry, Your Honours, if I may be of assistance.

25     Page 56, line 17, it's a private criminal complaint.  "Privatni

Page 11091

 1     crimnial tuzba" in Serbian.  Thank you.

 2             JUDGE HALL:  Thank you.

 3             MR. KRGOVIC: [Interpretation]

 4        Q.   As for the rest of the group --

 5             MR. KRGOVIC: [Interpretation] Can we see document 1D03-1381.

 6             JUDGE DELVOIE:  Tab number, please.

 7             MR. KRGOVIC:  Tab number 19.

 8             JUDGE DELVOIE:  Thank you.

 9             MR. KRGOVIC:  In Zupljanin register.

10             [Interpretation] 1081; my apologies.  In other words, 2D03-1081.

11             There seems to be a problem with this document, so I will move on

12     to something else.

13             Perhaps we can have the document placed on the ELMO.  Oh, all

14     right, now we have it.

15             No, I'm sorry, that's not the right document.

16             JUDGE DELVOIE:  It seems to be the one that you asked for

17     Mr. Krgovic, isn't it?  21st of July, 1992.

18             MR. KRGOVIC: [Interpretation] No, it is the 22nd of July, but I

19     can't -- the 21st of July --

20             THE INTERPRETER:  Interpreter's correction.

21             MR. KRGOVIC: [Interpretation] But I can't see it here on our

22     screens.  2D03-1081.

23                           [Defence counsel confer]

24             MR. KRGOVIC:  Can I put on the ELMO the B/C/S version and the

25     participant can follow.

Page 11092

 1             MS. KORNER: [Microphone not activated]

 2             MR. KRGOVIC:  No English.  It was ...

 3             It was English, but it's disappeared somehow.

 4             MS. KORNER: [Microphone not activated]

 5             MR. KRGOVIC:  Yeah, yeah, that's it.  It's English version.

 6             So can I put the B/C/S version on the ELMO for the benefit of the

 7     witness.

 8             MR. OLMSTED:  Your Honour, I note that it is on Sanction right

 9     now.  Yeah, okay, there you go.

10             MR. KRGOVIC:  Yeah.

11        Q.   [Interpretation] Would you please take a look at this document.

12     This is a ruling of the lower court in Teslic, dated the

13     21st of July, 1992, whereby detention of a large number of members of the

14     Mice Group is cancelled.  Correct?

15        A.   Yes.

16             MR. KRGOVIC: [Interpretation] May I have the second page of this

17     document, please.

18        Q.   This was signed by investigating judge Nenad Kovacevic.

19        A.   Yes.  At the time, he was the president of the lower court in

20     Teslic.

21        Q.   Please take a look at the second paragraph, reading:

22             "The investigating judge, in his letter number 1492/92 of

23     20 July 1992, the public prosecutor of Teslic agreed to release from

24     custody individuals named in the disposition herein."

25        A.   Yes.

Page 11093

 1        Q.   The prosecutor was?

 2        A.   Mr. Branko Peric.

 3        Q.   And that was the information that you had, that they were

 4     released from custody?

 5        A.   Correct.  But only for the group that was released from custody

 6     before they were all released.

 7        Q.   Very well.  I will show you the other documents as well.

 8             MR. KRGOVIC: [Interpretation] But could we now go back to page 1

 9     of this document, please.

10        Q.   You can see here on the right-hand side it says: "At 1000 hours"

11     and that -- or "at 1510," and then this is a sort of para -- signature or

12     some initials.  Correct?

13        A.   Yes.

14        Q.   This would suggest that this was received somewhere?

15        A.   Yes.

16        Q.   Now I would like to show you another document related to this

17     one.

18             MR. KRGOVIC: [Interpretation] Could we tender this document,

19     Your Honours.

20             JUDGE HALL:  Admitted and marked.

21             THE REGISTRAR:  As Exhibit 2D88, Your Honours.

22             MR. KRGOVIC: [Interpretation] Could we now have P1313, a

23     Prosecution Exhibit.

24        Q.   This is a log-book of the -- from the detention unit in Doboj,

25     the custody log-book.  I will now you show you the page indicated

Page 11094

 1     ERN 155935.

 2             MR. KRGOVIC: [Interpretation] I apologise, 0415-5935.

 3             I believe it's page 21 in e-court.

 4             I think it's the next page; I apologise.  22.  The next page.

 5             We should have on the screens number 143.  In the left-hand

 6     column, 143.  Page 5935, the last digits of the ERN number.

 7        Q.   So let's take a look at the first column.  Let's see which

 8     individuals this relates to.

 9             MR. KRGOVIC:  The second part of this page, please, the left

10     portion, as it were.

11                           [Trial Chamber confers]

12             MR. KRGOVIC: [Interpretation] I'm sorry, it's the left-hand page

13     of this log-book, not of this page, because the page is of a larger

14     format.  We only see the right-hand side of that page.  Now could we see

15     the left-hand side of that same page.

16             So I would like to see the first half of this page marked in

17     e-court as -- maybe -- it could be 5934.  Maybe you can try that number.

18             I apologise for the this, but, yes, right.

19        Q.   Now, please take look.  Can you see the names here.  So we have

20     under number 143, Pijunovic Miroslav.  And then we have Slobodan Tekic,

21     Dobrivoje Culibrk, Stojan Djuric, Slavko Spasovic; all of these men are

22     mens of the Mice Group?

23        A.   Yes.

24             MR. KRGOVIC:  Let's go back to the previous page.

25        Q.   So we see the last two names are Sljivic and Sljuka?

Page 11095

 1        A.   Yes.

 2        Q.   They were released from custody in Teslic; correct?

 3        A.   Yes.

 4             MR. KRGOVIC: [Interpretation] Could we go back to the page we had

 5     before, 5935.

 6        Q.   Now you can see that according to this log-book where it says

 7     "date of release," they were released on the 24th of July, 1992, at 1510.

 8     That is the same time that we saw where the ruling was received at the

 9     district court in Doboj.

10             Can you see it in the third column, the last box at the bottom,

11     the last two?

12        A.   Yes, I can.  The 24th of July, 1992, at 1510.

13        Q.   And they were released pursuant to the Teslic lower court ruling,

14     K 35/92.  That's what we saw -- that's the document we saw a moment

15     earlier?

16        A.   Yes.

17        Q.   Thank you.  I just wanted to show the connection between this

18     ruling, that note, and --

19             JUDGE HARHOFF:  Mr. Krgovic, I think we've been there before,

20     haven't we?

21             MR. KRGOVIC: [Interpretation] No, we haven't, Your Honour.

22     Namely, one of our witnesses mentioned that these people were released

23     from detention, and that's why I'm showing this.  That they were released

24     before the document reached the county prison in Doboj.  And what I'm

25     trying to show is what we can see in the upper right corner of this

Page 11096

 1     document, and we can also see it's the same handwriting as the one we

 2     found in the book.

 3             That was the purpose why I wanted to show this document to the

 4     witness, to present the entire release procedure.

 5             But we'll move to a different topic now.

 6        Q.   Sir, after you submitted a criminal report, after the persons

 7     were handed over to the investigative judge, the proceeding went on

 8     according to the law from that point on; is that correct?

 9        A.   Yes.  One could say so.

10        Q.   And all the further activities, investigation, and everything

11     else was under their jurisdiction.  Am I right in saying that?  All the

12     investigative activities were, according to the law, under their

13     authority?

14        A.   Well, that's how it was before, and that's how it is still today.

15        Q.   You are probably familiar with the fact that part of this

16     process, there is one investigative step, namely, it was necessary to

17     obtain forensic evidence as well and that the relevant organs issued an

18     order to that effect?

19        A.   I know of all that.  I don't know how to explain it differently.

20     That was under their jurisdiction.  You do know that the Ministry of

21     Interior, according to the law, cannot order exhumations, cannot order

22     any forensic expertise.  Even if they have an expert, forensic expert,

23     among their ranks, they cannot launch into such an expertise without

24     receiving an order from either a investigative judge or the prosecutor.

25        Q.   And when you addressed Mr. Zupljanin in relation to the

Page 11097

 1     investigative steps that are under the jurisdiction of the prosecutor,

 2     was for the purpose of him to try and maybe speed up the process through

 3     his influence, to use his clout to ask the judicial organs to provide the

 4     necessary resources?

 5        A.   Yes, that's correct.

 6             Let me explain why we needed -- why we asked for the process to

 7     be speeded up.

 8             We had two locations, two mass graves.  In one grave, there was

 9     20; in the other, 28 bodies.

10        Q.   You told us about it yesterday.

11        A.   Yes.  And that's why we asked for it.  Namely, we didn't want

12     something to happen, something that had occurred on other -- in other

13     cases earlier, namely, that remains should be removed.  We wanted to have

14     this exhumation and a post-mortem to be conducted, knowing that the

15     remains of persons killed -- for them to be something that can be

16     recognised by their closest relatives but also to almost everything in

17     Teslic because Teslic is a small town and people know each other.

18        Q.   Yes.  But unrelated to this, after prosecutor had suggested, the

19     investigative judge actually started the process which then took its

20     stride?

21        A.   That's correct.

22        Q.   And you do remember that at the same time, simultaneously, a

23     proper avalanche of accusations came that you did not abide by the

24     procedure that was reported by the CSB Doboj; there were some

25     privately-filed complaints by individuals involved.  It all came

Page 11098

 1     immediately after.  Do you remember those events?

 2        A.   Yes, of course, I do remember.  Sorry to say that.  It's a

 3     notorious fact.  I gave my statement before the relevant organs in

 4     Teslic, before the court in Teslic, and I saw there that they have this

 5     in their records.  In other words, for me to reiterate that would be a

 6     waste of time, of your time.

 7        Q.   No, I didn't mean it like that.  I wanted to lay the foundation

 8     for my next question.

 9             When you discussed with Mr. Zupljanin this issue, when he told

10     you, Radule, don't you get involved with that.  Let the court deal with

11     it.  You have enough problems as it is.  That was the essence of what he

12     was trying to tell you, wasn't it?

13        A.   Well, I remember now, and let me repeat this:  I did not have

14     frequent conversations with Stojan Zupljanin; I can only remember the

15     events about which we talked.  I told that to the Prosecutor, and I'm

16     telling you this again.  I did not have direct contact about various

17     information with Stojan Zupljanin.  And in relation to my conversation

18     with Stojan in Teslic, I believe that this was a conversation that was by

19     the book, a conversation between a superior and subordinate officer.

20             My arrival at SUP on the next day, at 9.00 a.m., showed me that

21     he was very much interested in making sure that the persons who

22     perpetrated the crimes were arrested and charges brought against them.

23     His first question was how many people were killed.  I thought he had

24     asked me about my group.  And when I responded by saying one was killed

25     among them and one among us, I remember Mr. Stevilovic then saying,

Page 11099

 1     Congratulations; that's fine.  Because, as a soldier, his assessment

 2     before the start of the operation was that there will be a lot of

 3     casualties among us and that we have to be prepared for that.

 4             The view was, so to speak, that only children should not be sent

 5     into this operation, namely, people who don't have brothers, for

 6     instance, or siblings.  And also not to send those who have small

 7     children, because we assumed that there would be many more casualties.

 8     To be fully honest, what we had in mind was casualties among our ranks.

 9     Nobody was thinking about how many casualties would there be among them.

10        Q.   And Stojan Zupljanin and Stevilovic congratulated you on the

11     success of the operation?  That's what they said?

12        A.   Yes, that's how I understood them.

13             Lest I forget, one of the reasons why I left Teslic rather soon

14     was because of a suggestion that came from Belgrade as well, saying, You

15     should not be dealing with public security service issues; you are

16     educated to be a state security personnel and to collect intelligence.

17             They already had information that somebody is getting ready to

18     kill me and that the person closest to the preparations for my killing

19     were people by the name of Predrag Rakocevic [phoen] and Marinko Dukic.

20     It was only 1998 that I had an opportunity to have a discussion with them

21     openly about all the aspects of the events past, and I still remember

22     Marinko Dukic telling me from a man I hated most to -- during the period

23     between 1992 and today, I realised that same man was my best friend.  I

24     remember that well.  And Marinko Dukic is a very straightforward person.

25     Predrag Markocevic [phoen] said the same thing.  And at about that time I

Page 11100

 1     managed to clear up matters also with Andrija Bjelosevic in relation to

 2     all the events that were unclear to him.  So one cannot say that all the

 3     traces we left behind were bad.

 4             After a while, through conversation, clarification of issues, we

 5     would come to a conclusion that a huge number of people who had initially

 6     seen us as enemies, traitors, and so forth, finally accepted us as

 7     professionals, human beings, and true members of our nation.

 8             I apologise for this discourse which was rather long, but that's

 9     how things were.

10        Q.   Following this, you handed over the public security station to

11     the people who were appointed, and then you left the area and re-joined

12     the State Security Service, continued your work as a part of the

13     Milos Group?

14        A.   That's correct.

15        Q.   There was a misunderstanding that occurred a bit earlier, and I

16     would like to ask you to clarify this for me.

17             We were talking about -- about the Milos Group members.

18             MR. KRGOVIC:  Can we move to the private session now.

19             JUDGE HALL:  Yes.

20                           [Private session]

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 11101

 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                           [Open session]

20             THE REGISTRAR:  We are in open session, Your Honours.

21             MR. KRGOVIC: [Interpretation]

22        Q.   I think it may have been the day before yesterday in responding

23     to the questions by the Prosecutor who showed you a document concerning a

24     unit from Teslic that was part of the VRS which was not within the

25     hierarchy.  We asked -- you asked for them to be -- to join the public

Page 11102

 1     security station in order to put them under control and help this public

 2     security station in their fight against self-proclaimed groups and

 3     para-formations and their criminal activities.  Mainly because this group

 4     was an experienced group of fighters.  According to you, they could have

 5     been incorporated with -- into the police force, and you believed they

 6     would be a positive force in resolving more complex problems?

 7        A.   That's correct.  It was a smaller company headed by

 8     Lieutenant Jocic.

 9        Q.   The idea was to put them under control because the risk was that

10     they might become a paramilitary formation on their own and become a

11     security problem?

12        A.   That's correct.  They took part in the arrest of the Mices.  Up

13     until that point, there was no reason to treat them as perpetrators of

14     crimes of any sort, especially not of war crimes.  And I believe that a

15     high-quality unit like that with good training should be signed on

16     because my intention was, in the capacity of the chief of the public

17     security station, to make sure that we, the public security station, will

18     take care of another two or three groups, primarily a group of rebels

19     from Blatnica, who were also committing crimes at the time, as well as

20     with a certain Bubic, from the area of the village of Pribinic, who, for

21     a while, was some kind of a warden or commander of some detention unit,

22     unorganised detention unit.  I don't know whose interests he was working

23     for, but we prevented him from continuing with his activities.

24             There were also other smaller groups present in Teslic, again,

25     involved in committing crimes against non-Serb population, and we had

Page 11103

 1     plans of taking care of that, making them -- putting them under control.

 2     We prepared reports about it.

 3        Q.   We have seen the reports.  We'll -- instead of going deeper into

 4     that, let me show you a document.

 5             The Prosecutor showed you a document --

 6             JUDGE HARHOFF:  Mr. Krgovic, excuse me.  Before we leave this

 7     issue, I was -- I was interested in exploring a bit Mr. Radulovic's

 8     comment that the Mice weren't really arrested for reasons of war crimes

 9     but, rather, for the commission of civilian crimes.

10             Mr. Radulovic, did I understand you correctly?

11             THE WITNESS: [Interpretation] No, you didn't, and I apologise --

12     I regret that.  They were, first of all, arrested because they had killed

13     a number of persons of non-Serb ethnicity.  That was the main reason why

14     they were arrested and why a criminal report was filed.

15             As for other things they did, everything was documented so that

16     their ordinary, if I may say so, crime activity was in the background at

17     the time.  It wasn't given the priority.

18             JUDGE HARHOFF:  Thank you.

19             MR. KRGOVIC: [Interpretation]

20        Q.   Now, another report of the Milos Group shown to you by Prosecutor

21     concerns the establishment of the special police detachment.  I'll show

22     you the decision of the Assembly of -- of the Serbian Bosnia and

23     Herzegovina.

24             So could you now please be shown --

25             THE INTERPRETER:  Could the counsel please repeat the number of

Page 11104

 1     the document.

 2             MR. KRGOVIC: [Interpretation]

 3        Q.   But before I put this to you --

 4             JUDGE HARHOFF:  Counsel, the interpreters ask you to repeat the

 5     number of the document, if you would be good enough.  Thanks.

 6             MR. KRGOVIC: [Interpretation] 2D55.

 7             JUDGE DELVOIE:  Your document list, Mr. Krgovic, tab number?

 8             MR. KRGOVIC: [Interpretation] Yes, Your Honours.  Tab 21.

 9             JUDGE DELVOIE:  Thank you.

10             MR. KRGOVIC: [Interpretation]

11        Q.   Within the Milos Group, you did not really focus on the special

12     detachment.  It wasn't a particular focus of your attention.  It's only

13     if you came across some information on their activities.  And you

14     informed about them, in general terms, if it was of security interest for

15     that region, right?

16        A.   Yes.  Absolutely right.

17        Q.   And please look at the second page of this document.  The

18     Assembly of Krajina established this detachment.  And in the document it

19     says that the detachment will comprise members of active and reserve

20     police force.

21             And then if you go to the next page then we will see what the

22     intention of the Assembly was at the time.  And you know how sometimes

23     very good intentions produce evil results.  It says here that the unit

24     would be established in order to protect law and order, especially to

25     protect against sabotage activities and so on.

Page 11105

 1             And then in paragraph 4 from the top it says how the detachment

 2     would be manned.  And we can see in this paragraph that, first of all,

 3     there would be some active policemen in it who were skilled and who were

 4     part of the "posebni" detachment, which existed before the war.  And then

 5     that out of the candidates that were available they should select those

 6     who had already been in similar units in Zagreb and Sarajevo and who had

 7     fled from the area as well as persons who already had some experience on

 8     the front line.

 9             It says here that some candidates have the relevant skills and

10     expertise which would allow them to execute successfully any tasks and

11     that those who were in reserve forces would remain in reserve forces

12     until certain conditions were met, following which they would be

13     transferred into active-force members.

14             I apologise for speeding.

15             So what is important?  It's that certain persons who had

16     front-line experience became members of the unit, and, unfortunately,

17     some persons who really did not belong in that units and who did not meet

18     the requirements also became members, right?

19        A.   Yes.  And, unfortunately, those who had no place in that unit had

20     the main role.

21             MR. PANTELIC:  I do apologise, Your Honours.  I have a problem

22     with LiveNote, so I would kindly ask the assistance of technical unit.

23             MR. KRGOVIC: [Interpretation]

24        Q.   And when speaking of this, you said, Yes, there were such

25     instances, and there were some honourable compensations and, yes, there

Page 11106

 1     were members who discharged their duties in a honourable and honest way.

 2        A.   Certainly.

 3        Q.   In your evidence in-chief, you said that after these events,

 4     speaking of Stojan Zupljanin, you said that you had told him, in general

 5     terms, about the behaviour of members of that unit - this is page

 6     10804 - when you came back from Doboj.  And you received information, and

 7     you mention some colleagues of yours.  And then in speaking of this

 8     event, you said that it wasn't really your job to wok on crime

 9     investigations.  You said that there were some irregularities in the

10     conduct of the members of that unit, saying that cars had been stolen and

11     there was some unlawful activities related to detention and bringing in

12     of persons, right?

13        A.   I'm waiting for the interpretation to finish.

14             Mr. Krgovic, as far as I remember -- or to the extent that I

15     remember events which took place 17 years ago, there's no reason why I

16     shouldn't remember what I said four days ago.

17        Q.   At the time when you were in Doboj, you said that you didn't know

18     what the circumstances were while they were there, who had sent them

19     there, and how -- how they worked.

20        A.   Mr. Krgovic, I conveyed this information, in general terms, to

21     Stojan Zupljanin primarily in order to protect the members of our special

22     detachment from the frequent occasions where they were used to shield

23     local criminals.  Everything that local criminals had done was mostly

24     attributed to the members of the special detachment of police from

25     Banja Luka and also partially was also attributed to members of the

Page 11107

 1     Red Berets unit.  After saying this to Stojan Zupljanin, I proposed that

 2     they be withdrawn, and I said explicitly that, based on what I knew, it

 3     wasn't done the next day by the day after; namely, members of the special

 4     detachment were withdrawn from Doboj to Banja Luka, and they took several

 5     days in pulling out because they carried with them the items that they

 6     had seized or had stolen from shops, private enterprises, and so on.  I

 7     saw with my own eyes.

 8             I concluded that Mr. Zupljanin accepted that information with due

 9     seriousness, giving it serious attention.  I don't know whether he

10     verified this with somebody or not, but the information about their

11     withdrawal was provided to him by the Milos Group.

12             MR. KRGOVIC: [Interpretation] Could we now see OTP 65 ter 10355,

13     please.

14             65 ter 10355.

15        Q.   This is a list, a payroll list, from Doboj, from the Doboj CSB,

16     their police station.  Here we can see that these people were on the

17     payroll in Doboj.  It is entitled:

18             "The 9th Company for Special Assignments, Banja Luka."

19             And then can you see the list of persons who were members.  This

20     is payroll for May.  This is a much longer document, and I have shown

21     only the first page.  This is the page that I'm interested in.  And based

22     on what we can see here, they, as a unit, were detached to the Doboj CSB

23     at the time.  They received their salaries there.  And they were issued

24     assignments an orders there.  It stems from this document, right?

25        A.   Yes, that would be my conclusion too.

Page 11108

 1        Q.   And these are the people that you have mentioned as being there

 2     at the time?

 3        A.   Yes.  But I also mentioned other persons.

 4             MR. KRGOVIC: [Interpretation] Your Honours, I seek to tender this

 5     document into evidence.

 6             JUDGE HALL:  Admitted.

 7             Mr. Olmsted.

 8             For one thing, we don't have an English translation of this.

 9     But ... and I guess, apparently, it's so illegible that we can't get an

10     English translation of it.  So that's the only problem with it.

11             JUDGE HALL:  Mr. Krgovic.

12             MR. KRGOVIC: [Interpretation] Your Honours, perhaps we could MFI

13     it at this point.  This document was on the OTP list in relation to the

14     witness from Doboj who spoke of the same events, and I was sure there was

15     a translation.

16             Could we perhaps MFI it for the time being until we get a better

17     copy, and then I'll give it to the CLSS.

18             JUDGE HALL:  Brief question:  How does this payroll list assist?

19             MR. KRGOVIC: [Interpretation] Your Honours, this is a payroll

20     list from Doboj for the members of the special unit from Banja Luka,

21     which, at the time, was deployed in Doboj and was under the jurisdiction

22     of the Doboj authorities, the CSB and SJB in Doboj.

23             This is why we want this to be tendered into evidence.  It bears

24     the stamp of the Doboj Crisis Staff, I think.  This is where that unit

25     was active in that capacity.

Page 11109

 1             JUDGE HALL:  But the assignment of such persons is independent of

 2     the specifics of the names on the list, isn't it?

 3             MR. KRGOVIC: [Interpretation] Yes, Your Honours.  I will get to

 4     that.  My question will also relate to other members.  But when it comes

 5     to this company that the previous witness spoke about, he was from the

 6     police station in Doboj, there was some talk about payroll, et cetera.

 7     And the Prosecutor did not tender that document into evidence at the

 8     time.  I guess it didn't suit them.  So this is why I want it to be

 9     admitted now.

10             MR. OLMSTED:  Yes, Your Honour, I think I understand your

11     concerns.  I don't see -- this document -- it's unclear who the special

12     unit was.  It's not clear from the witness's answer whether this is the

13     Banja Luka Special Police Detachment or some other special unit that was

14     created within Doboj.  And, therefore, there is a bit of confusion as to

15     its relevance to this case.

16             MR. KRGOVIC: [Interpretation] If I may reply.  It says clearly

17     here:

18             "The 9th Company for Special Tasks, Banja Luka."

19        Q.   So you will agree with me, won't you, that this refers to that

20     special unit from Banja Luka?

21        A.   Mr. Krgovic, no offence - and this pertains to the Prosecutor as

22     well - I know that this document pertains to the members of the special

23     detachment from Banja Luka who had been deployed to Doboj.  There's no

24     doubt there whatsoever.  I know that this is how they refunded salaries

25     for those who had left their original unit and went to the area of

Page 11110

 1     another unit.

 2             I recognise some names here.  And based on that, I can conclude

 3     that they were in the special police detachment from Banja Luka.

 4                           [Trial Chamber confers]

 5             JUDGE HARHOFF:  Mr. Krgovic, I'm a bit at a loss as to what it is

 6     you wish to show to the Chamber about these members of the Banja Luka

 7     special detachment that were apparently replaced and sent to Doboj.

 8             What is the Chamber to make of this information?

 9             MR. KRGOVIC: [Interpretation] Your Honours, the position of the

10     Defence is - and we're trying to prove this on the basis of this

11     document - is that the Assembly of the Autonomous Region of Krajina and

12     the Ministry of Defence made a decision to resubordinate one company from

13     the Banja Luka area and to redeploy them to Doboj where they acted under

14     the command of the authorities of that town in order to defend the town.

15             So they were there, they were active there, their salaries were

16     paid out to them there, and they were granted all the rights that they

17     were entitled to in Doboj.  And this is what I'm trying to show.  I'm

18     trying to show the link.

19             JUDGE DELVOIE:  Mr. Krgovic, this -- this is more or less clear.

20     Why don't you just ask that question to the witness?  Or is he not

21     supposed to know?

22             MR. KRGOVIC: [No interpretation] [Microphone not activated]

23             THE INTERPRETER:  Microphone for Mr. Krgovic.

24             MR. KRGOVIC: [Interpretation] Your Honours, the witness has

25     already answered my question.  He said that they were deployed there and

Page 11111

 1     that they were under their command.  But we can go over it again.

 2        Q.   Based on what you know and based on how they were redeployed --

 3             JUDGE HALL: [Previous translation continues] ... we must take the

 4     adjournment for the day.  So, the --

 5             MR. OLMSTED:  Can I just make my point quickly on this document.

 6             JUDGE HALL:  Yes.

 7             MR. OLMSTED:  Thank you, Your Honour.

 8             I mean, it's just still very unclear how this witness is coming

 9     to the conclusion that these are members of the Banja Luka Special Police

10     Detachment.  It's a very difficult document to read.  At the very least,

11     he should provide the names on this list who he leave believes were part

12     of the Banja Luka Special Police Detachment.  Otherwise, there's really

13     no need to even go any further with this line of questioning.

14             MR. KRGOVIC: [Interpretation] Your Honours, I will continue

15     dealing with this, and I will also show to the witness a larger document,

16     the list of the members of the special unit.  And when you compare the

17     names there with the names that the witness says he recognised, the

18     conclusion will be clear to you.  The document itself says that it is

19     about the members of the 9th Company from Banja Luka.

20             THE WITNESS: [Interpretation] If I may say something, I have

21     glasses, but the names are legible, although hard to read, but still

22     legible.  And I recognise the names, first and last names, of the people

23     whom I knew before the war and concerning whom I knew that during the war

24     they were members of the special detachment.  I told you everything now.

25     There is no need for me to read this any further.  I don't know all of

Page 11112

 1     these young men.  That's true, I don't know all of them.  But I saw two

 2     or three names on this list, and right now I can't tell you that I saw

 3     these persons in Doboj.  But if it says on the top that this is a

 4     payroll, then I don't see why I shouldn't believe that these were members

 5     of our special detachment.

 6             JUDGE HALL:  Anyway, we'll pick up on this tomorrow morning.  In

 7     the meantime, we'll marked for identification, so we don't lose it in

 8     the ...

 9             THE REGISTRAR:  As Exhibit 2D89, marked for identification,

10     Your Honours.

11                           [The witness stands down]

12                            --- Whereupon the hearing adjourned at 1.51 p.m.,

13                            to be reconvened on Tuesday, the 1st day of

14                            June, 2010, at 9.00 a.m.