Tribunal Criminal Tribunal for the Former Yugoslavia

Page 16479

 1                           Thursday, 28 October 2010

 2                           [Open session]

 3                           [The accused entered court]

 4                           --- Upon commencing at 2.24 p.m.

 5             THE REGISTRAR:  Good afternoon, Your Honours.  Good afternoon,

 6     everybody in and around the courtroom.

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

 8     Stojan Zupljanin.

 9             JUDGE HALL:  Thank you, Mr. Registrar.

10             And good afternoon to everyone, and welcome back after our

11     extended weekend.

12             The -- we have been alerted -- Mr. Hannis, you seem to be about

13     to rise.  We have been alerted that the witness has something to say, and

14     we intended to deal with that first.

15             But do you have a matter?

16             MR. HANNIS:  No, Your Honour, I was only rising in anticipating

17     of announcing the appearances.

18             JUDGE HALL: [Overlapping speakers] ... the appearances.  Yes,

19     please.  Thank you.

20             MR. HANNIS:  I'm Tom Hannis along with Crispian Smith for the

21     Office of the Prosecutor.  Thank you.

22             MR. ZECEVIC:  Good afternoon, Your Honours.

23             Slobodan Zecevic, Slobodan Cvijetic, Eugene O'Sullivan, Ms.

24     Tatjana Savic, and Ms. Melody Whittaker appearing for Stanisic Defence

25     this afternoon.  Thank you.

Page 16480

 1             MR. KRGOVIC:  Good afternoon, Your Honours.

 2             Dragan Krgovic, Igor Pantelic, and Aleksandar Aleksic appearing

 3     for Zupljanin Defence.

 4             JUDGE HALL:  Thank you.

 5             Yes, the -- as I said, we have been alerted that the witness

 6     wishes to say something.  So unless there are some preliminary matters

 7     that we should deal with before that, I propose to have the witness

 8     brought into the stand to see what -- what he wishes to say.

 9                           [The witness takes the stand]

10             JUDGE HALL:  Good afternoon to you, sir.  Welcome back.  You may

11     be seated.

12                           WITNESS:  DOBRISLAV PLANOJEVIC [Resumed]

13                           [Witness answered through interpreter]

14             THE WITNESS: [Interpretation] Thank you.

15                           [Trial Chamber confers]

16             JUDGE HALL:  Good afternoon to you, sir.  We are given to

17     understand that there -- that before we resume your examination-in-chief

18     and -- there is something that you wish to say to the Chamber.

19             THE WITNESS: [Interpretation] Good afternoon.

20             First of all, I would like to greet everybody present, and I'll

21     bring forward the matter immediately.

22             The reason why I'm taking the floor is the article that was

23     published on SENSE Tribunal.  The article is biased, but I'll -- I don't

24     want to go into that.  It, however, concerns also some lies.  And before

25     we continue, let me ask you if you can do anything about it.  And I can

Page 16481

 1     say to you what is wrong there.  I don't know how this works anyway.  Is

 2     there a -- a PR representative here, or is the press present during the

 3     trials, or how does everything work?

 4                           [Trial Chamber confers]

 5             JUDGE HARHOFF:  Thank you, Mr. Witness.  We have, indeed, seen

 6     the article in SENSE, and we're also somewhat surprised to learn of the

 7     contents.

 8             However, we find that it would be inappropriate for the Court

 9     itself to address any journalist or newspaper every time something wrong

10     is written about this Tribunal, so this is normally taken care of by the

11     Registry, in which there is a Press and Information Section which

12     normally deals with foreign press relations.

13             So I assume that the Press and Information Section has already

14     sought to clear up the -- the wrongful information that appeared in

15     Sense.  But we can check that.  Thank you.

16             JUDGE HALL:  I'm grateful to Judge Harhoff addressing the

17     witness's legitimate concerns.

18             And if there is nothing else, I, sir, would remind you that

19     you're still on your oath and invite Mr. Hannis to conclude his

20     examination-in-chief.

21             MR. HANNIS:  Thank you, Your Honour.  I would just indicate that

22     I wasn't aware of the article, I haven't seen the article myself.  The

23     witness may want to speak to Victim Witness to see if there's a way that

24     maybe he can speak directly with people from SENSE.  I don't know what

25     the issue is, but that's a possibility.

Page 16482

 1                           Examination by Mr. Hannis: [Continued]

 2             MR. HANNIS:  With that, I have about, I think, five or ten

 3     minutes, Mr. Planojevic, and then Mr. Zecevic will have his turn.

 4             I just want to establish the number of times and the chronology

 5     on -- regarding the occasions that official representatives have spoken

 6     with you about some of the events from 1992.

 7             We've already talked about your interview with OTP in

 8     June of 1992 -- or in June of 2004, I'm sorry.

 9             Do you recall having given a statement or a deposition in

10     November of 2004 - I think it was the 23rd of November, 2004 - in

11     connection with an investigation that was being done by the prosecutor's

12     office in Bijeljina concerning the deaths of three Muslim families in

13     September of 1992?

14             Do you recall that?

15             MR. ZECEVIC:  I'm terribly sorry, but could we have the date when

16     this -- when this last document was disclosed to the Defence, please?

17             MR. HANNIS:  It's -- it's contained within Exhibit P1543, which

18     is the document from the regional prosecutor.  And the witness's

19     statement is at page -- begins at page 47 of the English in e-court, and

20     I think it's page 41 of the B/C/S in e-court.  I'm only asking to confirm

21     the date.

22             MR. ZECEVIC:  Well, I mean, I'm sorry, Mr. Hannis, but wasn't it

23     agreed between the parties that we would be notified that you want to use

24     another document which is not on your list previously?

25             MR. HANNIS:  As far as I'm -- [Overlapping speakers] ...

Page 16483

 1             MR. ZECEVIC: [Overlapping speakers] ... I'm not -- and I'm not

 2     concerned that -- I'm not aware that it was on your list.  I might be

 3     mistaken, though.

 4             MR. HANNIS:  I'm sorry, I ...

 5                           [Prosecution counsel confer]

 6             MR. ZECEVIC: [Microphone not activated] ... I'm sorry, it's

 7     tab 21.  I withdraw.  I'm sorry, Mr. Hannis.

 8             MR. HANNIS:  Thank you.

 9        Q.   Mr. Planojevic, all I want to ask right now is if you remember

10     having given that deposition?

11        A.   That wasn't given to the OTP.  I gave that statement to the

12     police.

13        Q.   Correct.  I think it was the police that were taking the

14     statement or the deposition on behalf of the public prosecutor's office.

15             Do you recall having met with other representatives of the OTP in

16     February of 2009, Ms. Joanna Korner and Jusu Yarmah?

17        A.   It was at Nedzarici, near Sarajevo; right?

18        Q.   I believe it was near Sarajevo.

19        A.   I remember.

20        Q.   And then in May of this year, on May the 12th, in Bijeljina, a

21     meeting with a Mr. Paul Grady and Belinda Pidwell and an interpreter from

22     the OTP?

23        A.   Yes.

24        Q.   I wanted to ask you about your contacts with Mico Stanisic

25     after -- after the war.

Page 16484

 1             And I guess I will ask you: Did you have any contacts with

 2     Mico Stanisic after the year 2004, after you had your first interview

 3     with the OTP?

 4        A.   Yes, I had one contact with him in Belgrade.  But I'm not sure

 5     whether it was before or after that date.  It was probably after.

 6        Q.   In -- in speaking with Ms. Korner and Mr. Yarmah in 2009 you

 7     informed them that you had had a contact from Mr. Stanisic about the

 8     possibility of being a witness for him regarding events before the war,

 9     and at that time I think you said it had been a couple of months earlier,

10     so maybe the end of 2008; does that sound about right?

11        A.   That contact must have taken place much earlier.  I'm not sure

12     now because it's been a long time, but I did say to him that I had had

13     that contact.

14        Q.   And was that a face-to-face meeting, or by phone, or ... or what?

15        A.   It was face to face.

16        Q.   Did he tell you in that meeting that he had read your 2004

17     interview?

18        A.   I'm not sure, really not.  We -- we spoke a little, and I --

19     actually, I volunteered the information.  I spoke about the circumstances

20     of the war.

21        Q.   If I were to tell you that in the brief witness statement that

22     Ms. Korner and Mr. Yarmah took from you on the 24th of February, 2009, it

23     was reported that Mico Stanisic, you said, in paragraph 6, "He told me

24     that he had read my statement which I gave in Banja Luka in 2004," would

25     that refresh your memory, or do you disagree with that now?

Page 16485

 1        A.   I said as much to them, but Mico said that he knew what I had

 2     said.  That's the crux of the matter.  But there may be a discrepancy

 3     there.

 4        Q.   Okay.  Thank you for that.  We were talking last time you were

 5     here about Zoran Jasarevic and Goran Abazovic, two of the men who

 6     provided personal security for --

 7        A.   Abazovic.

 8        Q.   Abazovic -- who provided personal security for the minister in

 9     1992.

10             In 1992, do you recall what they wore?  Did they wear civilian

11     clothes, did they wear a uniform?  What do you remember?

12        A.   Abazovic was in uniform, and I think that Jasarevic was in

13     civilian clothes.  Actually, I only saw him two or three times.  I'm

14     really not sure about him.

15        Q.   And Abazovic's uniform, can you tell us what colour it was, what

16     type it was, was it a camouflage uniform; and, if so, what colour?

17        A.   As far as I remember, it was a camouflage uniform.

18        Q.   And the basic colours, was it a forest camouflage green; was it

19     blue camouflage; or some other colour?

20        A.   Well, forest green, maybe.

21        Q.   Now the Malovic Unit, we've heard evidence from some witnesses

22     that they had a distinctive kind of camouflage.  Do you recall the

23     uniforms that they wore?

24        A.   They had various kinds of uniforms.  I don't know which you're

25     interested in.

Page 16486

 1        Q.   Do you recall that their camouflage uniform was somewhat

 2     distinctive from the normal blue camouflage or green camouflage that most

 3     others were wearing at that time?

 4        A.   They had both blue camouflage and glean camouflage, I think.  But

 5     when they arrived at Vraca, and that's probably what you were interested

 6     in, they had black and white.  But only for a very brief period.  They

 7     probably understood that those uniforms were unsuitable for combat.  So

 8     after a month, I never saw them in such uniforms again.

 9        Q.   Did you see them in other kinds of uniforms after that month, or

10     did you see them at all?

11        A.   I told you that they held the line behind the school where we

12     basically lived for a month and a half or two.  And they would come to

13     lunch often, and we would meet them there.  I know I saw them there in

14     the compound.

15        Q.   Thank you.  When you moved from Vraca to Pale, I think you said

16     that was in June of 1992, early June.  Would that be correct?

17        A.   Yes.

18        Q.   Where did you work, where was your office located in Pale?  What

19     building or hotel or ...

20        A.   At that time, it was at Kalovita Brda.  Before the war, it was a

21     scouts centre, or dorm.

22        Q.   And how long did you remain in that facility?

23        A.   Until I resigned.  But I did come by even later, informally or

24     unofficially.

25        Q.   Do you know where Mico Stanisic's office was located in June and

Page 16487

 1     July and the rest of 1992?

 2        A.   I have already said that I remember such a contact at hotel -- at

 3     the Kosuta hotel.  I believe that his office was up there, but I'm not

 4     sure.  It may have been at the Bistrica hotel because part of the cabinet

 5     was there too.  But I met the then-minister at the Kosuta hotel.

 6        Q.   And you mentioned the government, Mr. Djeric.  Do you know where

 7     his offices were in June and July of 1992?

 8        A.   At the Bistrica hotel.

 9        Q.   Thank you.  And then I think you told us that you started working

10     for the national security in September of 1992; is that -- is that about

11     right?

12        A.   Yes.

13        Q.   And where was your office when you started working for them,

14     until the end of 1992?

15        A.   In the same building.  Until October or November, when we went to

16     Bijeljina.  The headquarters moved then.  Part of the service left a bit

17     earlier, two or three men, to -- they went to look for accommodation.

18     And I think that we followed in November.

19        Q.   And when you say your office was in the same building, you mean

20     in Kalovita Brda?

21        A.   Yes.

22        Q.   And in Bijeljina, when you got there, where was your office?  Was

23     it in the SJB building or the CSB building?  Are those two different

24     buildings; and, if so, which one were you in?

25        A.   We were accommodated at the CSB, and the ministry moved to the

Page 16488

 1     same building.  Even now, it's the services centre.

 2        Q.   And was the minister housed in Bijeljina in late 1992; and, if

 3     so, where was his office?

 4        A.   You can believe me that I never saw the minister in Bijeljina,

 5     either in that period or later.  I believe another man was in charge of

 6     affairs there, one or two men.  It may seem ridiculous, but that was

 7     really the case.

 8        Q.   And who are the one or two men that you're referring to in that

 9     context?

10        A.   Cedo Kljajic, when we arrived.  But only very briefly.  And then

11     he left.

12        Q.   [Previous translation continues] ...

13        A.   Dragan Kijac was in charge of state security.  And I think that

14     Tovo [as interpreted] Kovac, as the chief of the police, or the

15     [indiscernible] service, took care of these affairs.

16        Q.   Thank you, Mr. Planojevic.  Those are all of the questions I have

17     for you now.

18             JUDGE HALL:  Cross-examination?

19             Yes, Mr. Zecevic.

20             MR. ZECEVIC:  Thank you very much, Your Honours.

21                           Cross-examination by Mr. Zecevic:

22        Q.   [Interpretation] Good afternoon, Mr. Planojevic.

23        A.   Good afternoon.

24        Q.   On Friday we had some problems with your fast speech, so I will

25     ask you to speak slowly to enable the interpreters to interpret both my

Page 16489

 1     question and your answer.

 2             On Friday, you -- the -- your -- the statement was given to you

 3     that you made on the 8th and 9th of June, 2004.  You had it in front of

 4     you.

 5        A.   Yes.

 6        Q.   Do you still have it, or did you return it to the OTP?

 7        A.   It -- I left it in my suitcase in my room.  It's here in

 8     The Hague.

 9        Q.   I'll remind you of some parts of that interview which you

10     discussed with my learned friend on Friday and at the beginning of this

11     hearing.

12             You gave this interview to the OTP's investigators, among whom

13     there was a lawyer of the OTP, and you did so on the 8th and

14     9th of June, 2004, in Banja Luka; right?

15        A.   Yes.

16        Q.   On that occasion, you were interviewed as a suspect, and you were

17     told as much; right?

18        A.   Yes.  And that's mentioned in the interview.

19        Q.   But it's true, isn't it, that until three days before you gave

20     that interview, that is, round about the 5th of June, you were the acting

21     chief inspector of the State Security Service, or the intelligence agency

22     as it was called then, which service used to exist on the 5th of June so

23     that when you were giving that interview, you were a ministry employee

24     without a particular task or position; right?

25        A.   Yes.

Page 16490

 1        Q.   Mr. Planojevic, please just wait for a couple of seconds after my

 2     question and then answer, for the sake of the interpreters.

 3             At that moment, you didn't have a post when you were invited to

 4     come and talk to the OTP representatives.  They told you that they were

 5     interviewing you as a suspect and then they read out to you the

 6     definition of the notion of "suspect."

 7             Do you remember that?

 8        A.   Yes.

 9        Q.   And on that occasion, on page 1 of the transcript of this

10     interview, it says that a suspect is a person concerning whom the

11     Prosecution has reliable information indicating that there is a

12     possibility that that person has committed a crime which falls under the

13     jurisdiction of the International Tribunal.

14             Do you remember this being said to you?

15        A.   Yes.

16        Q.   On that occasion, the OTP investigators also advised about your

17     rights, including that --

18             MR. HANNIS: [Previous translation continues] ... sorry to

19     interrupt, but my English translation of what was read out to him on

20     page 1 is:

21             "The definition of a suspect is a person concerning whom the

22     Prosecution possesses reliable information which tends to show that the

23     persons may have committed a crime."

24             And I don't see "may have" in what was appearing in the

25     transcript.

Page 16491

 1             MR. ZECEVIC: [Interpretation]

 2        Q.   I fully agree.  I see that this was omitted.  I said that

 3     indicating that there is a possibility that the person has committed --

 4             THE INTERPRETER:  The interpreters note that we do not have the

 5     original text, so we're doing simultaneous interpretation.

 6             MR. HANNIS:  For purposes of the interpreter, this is 65 ter

 7     9106.  And I have a hard copy in B/C/S for the witness, if that will

 8     help.

 9             MR. ZECEVIC: [Interpretation] Could we please have 65 ter 9106 in

10     e-court.  And could the witness be given a hard copy in the Serbian

11     language; that would be very useful.

12             MR. HANNIS:  I would alert my friend that unfortunately the

13     English page and the B/C/S page don't exactly much up, as is usually the

14     case.

15             MR. ZECEVIC:  As usual is the case, I will have to deal with

16     that.  Thank you.

17             [Interpretation] Could we now go to page 2, please, of this

18     document, both -- in both versions.

19             And I will repeat the question.

20        Q.   The Prosecutors of the OTP advised you of your rights that, among

21     others, you have a right to have a lawyer present during the interview;

22     isn't that right?

23        A.   Yes.

24        Q.   Mr. Planojevic, you have been a professional policeman since

25     1973; right?

Page 16492

 1        A.   Yes.

 2        Q.   Throughout your career with the police, and it was a continuous

 3     career that went on for 31 years, if I understood it right, and during

 4     that time, you completed all police schools that existed within the

 5     former SFRY, including the university in Skoplje; right?

 6        A.   Yes.

 7        Q.   I wouldn't want you to misunderstand me but you would agree with

 8     me, wouldn't you, that you belonged to the old police school?  I'm not

 9     criticizing you; this is by no means intended as a criticism.  Rather, I

10     just want to inform the Chamber, acquaint the Chamber, with the context.

11             Would you agree with me?

12        A.   Yes.  And it had a positive connotation in our system when one

13     said that one belonged to the old police system, old police school.

14        Q.   Yes, I fully agree with you.  And in my mind it also has a

15     positive ring to it.

16             Now tell me, please, it's true, isn't it, that this connotation

17     of the old classic-type police school had a rather cautious attitude or

18     suspicious attitude toward those suspects who asked for a lawyer to be

19     present during interview?

20        A.   Yes.

21        Q.   As you were taught in the former Yugoslavia, if somebody was

22     innocent, then that person didn't need a lawyer; right?

23        A.   Precisely so.  Because it wasn't really customary in our system

24     to have lawyers present when somebody was interviewed.  It just wasn't

25     something that was widespread in practice, until the changes.  And when I

Page 16493

 1     say "changes," I mean the changes that came with the war and after the

 2     war.

 3        Q.   Yes, I fully agree with you.  Our Law on Criminal Procedure did

 4     not envisage mandatory presence of counsel in pre-indictment proceedings;

 5     right?

 6        A.   Yes, correct.

 7        Q.   So, according to that old police school to which you belonged, as

 8     soon as somebody asked for a lawyer to be present or asked for legal

 9     assistance, that was a signal to you that there were some elements of

10     criminal responsibility present with respect to that person?

11        A.   Precisely so.

12        Q.   Sir, I'm sure that you will agree with me that, among other

13     things, that was also the reason why you did not ask for a lawyer to be

14     present when you were interviewed in 2004; right?

15        A.   Yes, correct.  And I -- and if I can give you a clarification for

16     additional reason or you will come to that yourself?

17        Q.   Well, to be more efficient, let me put questions to you.  And if

18     I miss something, you will be given an opportunity to add what you need

19     to say at the end.  Will that work?

20        A.   Yes.

21        Q.   This interview that you had on the 8th and 9th of June, 2004, was

22     recorded; right?

23        A.   Yes.

24        Q.   The investigators of the OTP told you that at the conclusion of

25     the interview you would be given a copy of tapes.

Page 16494

 1        A.   Yes.

 2        Q.   And on page 3 of this interview, they also said to you, in

 3     paragraph 1, that -- they said to you that should you become no longer a

 4     suspect but an accused, then the transcripts of the tape that was

 5     recorded would be made; right?

 6        A.   Yes.

 7        Q.   And we see that the transcript was subsequently made.  When did

 8     you learn that the transcript had been made?

 9        A.   Before the interview in Bijeljina.  I don't know the date, but

10     that was the last time I talked to the OTP.  In the evening, at

11     8.00 p.m., the interpreter brought the transcript to my house.

12        Q.   I suppose that that was the meeting you had with the

13     representatives of the OTP in May of this year; right?

14        A.   Yes.

15        Q.   And since this was brought to your house at 8.00 p.m., you were

16     supposed to show up in the morning for that meeting at what time?

17        A.   I'm not sure, but I think it is recorded in the document.  I was

18     supposed to come at 9.00 or 10.00 in the morning, but I'm not sure.

19        Q.   And you were expected to go over the transcript from 8.00 p.m.

20     until the meeting in the morning.  And the transcript contains, as far as

21     I know, about 150 pages; right?

22        A.   Precisely so.

23        Q.   Tell me, please, you will agree with me, won't you, that,

24     essentially, the first opportunity you had to read in detail the

25     transcript of your interview given on the 8th and 9th of June, 2004, only

Page 16495

 1     here, when you came to The Hague last week; right?

 2        A.   It is then that I started thinking about the actual meaning of

 3     each and every word and sentence.

 4        Q.   Well, when I said "in detail," that's precisely what I had in

 5     mind.

 6             And if I understood your evidence on Friday well, you immediately

 7     informed the OTP, as soon as you met with them on the 19th, in the

 8     morning -- you told them that you had certain amendments and

 9     interventions in relation to this transcript.  Also, if I understood your

10     evidence on Friday well, the Prosecutor got somewhat angry; right?

11        A.   Yes.

12        Q.   Very well.  Let us now go back to this 2004 interview.

13             It is a fact, isn't it, and this is somewhat [as interpreted]

14     that was put to you by the Prosecutor on Friday, that in 2004 the

15     investigators of the OTP in the presence of one counsel of the OTP told

16     you that you were not the target of the investigation.

17             Do you remember that?

18        A.   Well, something along those lines.  Something to that effect was

19     said to me.

20        Q.   Very well.  We will read it now.  It is the last sentence on

21     page 3.

22             Nicolas Sebire, the investigator of the OTP, says as follows:

23             "Since, during this interview, you had status of a suspect,

24     before we start the questioning I would like to inform you that you are

25     not the target of our investigation.  Do you understand that?"

Page 16496

 1             That's what was said to you, and you answered that you understood

 2     it.

 3        A.   Yes.

 4        Q.   However, on Friday, when you answered the questions of

 5     Mr. Hannis, even though back in 2004 you said you understood it, on

 6     Friday you said that that wasn't entirely clear to you what that meant,

 7     to have the status of a suspect without being the target of the

 8     investigation.  Do you remember saying this in evidence?

 9        A.   Yes.

10        Q.   When you were told that you were a suspect and when the

11     definition of the term "suspect" was read out to you, which said that the

12     Prosecution had reliable information indicating that that person may have

13     committed a crime from the jurisdiction of the Tribunal, when one

14     translated this into our legal system, that meant that somebody -- that

15     there were reasons to suspect, that there were grounds to suspect,

16     that ... you committed a crime.  And this is how you understood your

17     status; right?

18        A.   Yes.

19        Q.   Even when you were told that you were not the target of the

20     investigation, you could rationally conclude that even though you had the

21     status of a suspect, you could have been suspected of being an accomplice

22     or a co-perpetrator of the person against whom the investigation was

23     conducted; right?

24        A.   Yes, absolutely.

25        Q.   Mr. Planojevic, I'm sure that did you not feel comfortable in

Page 16497

 1     that situation; right?

 2        A.   Not in the least comfortable.

 3        Q.   Tell me, please, you served as a professional policeman for

 4     31 years, had you ever been in a situation where you were interviewed as

 5     a suspect?

 6        A.   No.

 7        Q.   Tell me, please, what I'm particularly interested is, is

 8     something you said on Friday, page 16442 of the transcript.  You said,

 9     among other things, in your answer, that when somebody sent you a message

10     to the effect that you had to be cooperative or else you would be fired,

11     and this something you mentioned in the context of your interview with

12     the Prosecutor, when you received this message, I would like to know

13     whether this message was conveyed to you by an investigator or the OTP

14     counsel or somebody else.  And I'm not really interested in the name or

15     other details of the person sending you the message.

16        A.   This was given to me indirectly, and it could have been conveyed

17     by the lawyer -- was Trivun a lawyer?  I don't remember.

18        Q.   Sir, when you were interviewed, there were five of you all

19     together.  There were two investigators of the OTP; there was

20     Julian Nicholls, counsel of the OTP; there was the interpreter; and you.

21     Those are the people who were there in June.

22        A.   Yes.

23        Q.   So if I understood you well, this message that you should be

24     cooperative or else you would be fired was not conveyed to you by any of

25     the three persons from the OTP, neither the investigators, nor

Page 16498

 1     Mr. Julian Nicholls?

 2        A.   No.

 3        Q.   So this warning, if I may call it that, was conveyed to you by

 4     another person; right?

 5        A.   Yes.

 6        Q.   When did you receive this warning?  How long before the interview

 7     held on the 8th and 9th of June?

 8        A.   Well, perhaps five to six days before that.

 9        Q.   And it was then, precisely, that you were given notice that you

10     would be interviewed by the OTP; right?

11        A.   Yes, just after that.

12        Q.   Tell me, please, Mr. Planojevic, did you have any reason to doubt

13     that should you be non-cooperative when talking to the OTP investigators

14     you would not be fired?

15        A.   Well, that was always present, because such things were known to

16     happen.

17        Q.   It's a fact, isn't it, that you really did retire some six months

18     after that, in 2004; right?

19        A.   Yes.

20        Q.   Thank you.  We'll move on to another topic.

21             You say in the interview, and I believe you repeated it on Friday

22     in this courtroom, and I mean the interview given on the 8th, that you

23     were a member of the Communist party, that is, the League of Communists

24     of Yugoslavia before 1990; correct?

25        A.   Yes.

Page 16499

 1        Q.   It is also a fact - and you spoke about that on Friday, I

 2     believe - that on one occasion the newly appointed minister, after the

 3     elections on the victory of the ethnic parties, you were in charge of an

 4     operation when the minister was deprived of liberty; right?

 5        A.   But it was not me.  It was one of the participants.

 6        Q.   That's what I said.  You didn't understand.  You were involved in

 7     an investigation in which Alija Delimustafic was targeted, among others,

 8     and he was placed in a remand prison for about 30 days; right?

 9        A.   Yes.  I signed the order to conduct that investigation, and

10     that's how it was conducted.

11        Q.   I'm sure I won't be wrong when I say that you did not exactly

12     enjoy the trust of those ethnic parties; right?

13        A.   Well, yeah, mostly.

14        Q.   You related an incident to us when you got a job at Marin Dvor,

15     which is a significantly lower-ranking position than your previous one

16     and was not in line with your qualifications.  Do you agree?

17        A.   Yes.

18        Q.   Then you tried to contact Mr. Zepinic, who was the

19     highest-ranking Serb official in the MUP and who was in charge of Serb

20     personnel in the MUP, but he never got back to you; correct?

21        A.   Exactly.

22        Q.   And after that, you contacted -- or, rather, went to see

23     Mr. Momo Mandic, who, in terms of rank, was the second-highest-ranking

24     Serb official in the -- in the Serbian [as interpreted] MUP of

25     Bosnia-Herzegovina, and you saw him in an office where he was with Bruno

Page 16500

 1     Stojic, the representative of the Croatian Democratic Union, and Hilmo

 2     Selimovic, representative of the SDA; they were both high-ranking

 3     officials of the MUP of the Socialist Republic Bosnia-Herzegovina;

 4     correct?

 5        A.   Yes.

 6             MR. ZECEVIC: [Interpretation] Just a moment.  I'm informed that

 7     there is a mistake in the transcript.  Page 21, line 22, it says

 8     Serbian MUP of Bosnia-Herzegovina, but I was speaking about the MUP of

 9     the Socialist Republic of Bosnia-Herzegovina.

10        Q.   And when you came there to complain, Mr. Mandic and the other two

11     were making jokes about you; right?

12        A.   Exactly.

13        Q.   Mr. Planojevic, you are not the only professional police officer

14     who fared this way after the victory of the ethnic parties and got

15     inappropriate treatment; right?

16        A.   There were many like me.

17        Q.   Tell me, sir, in 2006, you were a member of the

18     Parliamentary Commission of the Assembly of Bosnia-Herzegovina for

19     investigating crimes committed against the citizens of Sarajevo during

20     the war.  You said that during the interview, but I believe Mr. Hannis

21     didn't ask you questions about that?

22        A.   Yes, that is correct.

23        Q.   If I understood correctly, your mother-in-law also disappeared in

24     1992 in Sarajevo ; correct?

25        A.   Yes.  And she's still missing.

Page 16501

 1        Q.   If I remember your testimony correctly, in late June, throughout

 2     August, and onto September, and certainly even later, you tried to find

 3     out through private channels what was happening to your mother-in-law in

 4     Sarajevo but you were unable to get any information; right?

 5        A.   Yes.  I made many attempts.

 6        Q.   If I understood correctly, even today you don't know what

 7     happened to her, nor have you been able to get any information; right?

 8        A.   I can only make conjectures.  I don't know enough.  What I do

 9     know is insufficient.

10        Q.   Such cases of people, that is, civilians going missing in

11     Sarajevo in 1992 and later on, were not rare; right?

12        A.   Yes.  Only in the neighbourhood where I lived five Serb houses

13     were left empty, that is round the place where mother-in-law lived, and

14     these people are still missing.  I can give you their names, in case

15     anybody doubts my words.

16        Q.   I'm not opposed to that.  I don't know how relevant it is to this

17     case.  But maybe you can mention their names.

18        A.   Mila Saratlija, Mara Saratlija, the Mijanovic married couple, and

19     my mother-in-law.  They were all taken away on -- the same way and are

20     missing still.

21        Q.   We're talking about mid-1992; right?

22        A.   It was late July.  We -- that's more precise.

23        Q.   All right.  I will take you back to the situation in

24     1992 [as interpreted], late 1992, because I think it's relevant to this

25     case.

Page 16502

 1             Tell me --

 2             MR. ZECEVIC: [Interpretation] Actually, I said 1991, and 1992 is

 3     recorded.  So let's go back to late 1991.

 4        Q.   On which day were you appointed to your new post in Marin Dvor,

 5     and what kind of a position was that?

 6        A.   I believe that I was transferred on the 1st of June, and the

 7     decision bore the date of a few days earlier, so I cannot be very

 8     accurate.

 9        Q.   If I understood correctly, since June 1991, all the way through

10     mid-September, there were no particular problems in your work; correct?

11        A.   No.

12        Q.   But I can see from some statements of yours that as of the

13     18th of September, when you were taking your family to the seaside, and

14     that's why you remember the exact date, the situation changed; right?

15        A.   Yes.

16        Q.   When you returned, you were told that the reserve police force

17     had been mobilized and that over 95 per cent of the weapons belonging to

18     the police had been given, or handed out, to Muslims; right?

19        A.   Yes.

20        Q.   And you expressed your concern, that is, the concern of Serb

21     police officers, you expressed your concerns to Rusdo Kuhinja, the chief

22     of the police station of Marin Dvor?

23        A.   Yes.

24        Q.   And if I understood correctly, he tried to persuade you that

25     95 per cent of the reserve police that were mobilized were Muslims and

Page 16503

 1     that they received weapons.  He tried to persuade you that wasn't true;

 2     correct?

 3        A.   Yes.

 4        Q.   To check that, you and your deputy, Muhamed Agic, who was also a

 5     Muslim, you went to visit some of these reserve police stations; right?

 6        A.   Yes.

 7        Q.   And once you had visited those police stations, if I understood

 8     correctly, you found four reserve police stations which had almost

 9     exclusively a Muslim staff; they were armed and mobilized?

10        A.   Yes.  But Agic accompanied me only to two such stations, and I

11     visited two on my own.

12        Q.   But there were four stations that had almost exclusively Muslim

13     staff; right?  I mean, reserve police stations.

14        A.   Yes.  Almost 100 per cent.

15             MR. ZECEVIC: [Interpretation] On page 24 of the transcript, in

16     line 10, it said -- it says, or it was recorded -- actually, I was saying

17     that your chief Rusdo Kuhinja tried to persuade you that it wasn't true

18     that 95 per cent of the reserve police that were mobilized were Muslims

19     and that they received rifles.  It was recorded otherwise in the

20     transcript, hence my intervention.

21        Q.   You had also information that one Skrijelj, about whom you had

22     intelligence that he was engaging in smuggling weapons, was the one who

23     distributed those weapons to reserve police officers from official police

24     warehouses; correct?

25        A.   Well, I can provide explanation to make it clearer.

Page 16504

 1        Q.   Go ahead.

 2        A.   The municipality of Centar had --

 3        Q.   Do slow down.

 4        A.   That municipality where I was had two police stations and one

 5     public security station, because, mind you, one public security can

 6     include several stations.  At Bjelave, the second police station that

 7     belonged to the public security station of Centar, the -- most police

 8     officers were Muslims, and that reflected the composition of the

 9     population.  That man Skrijelj, that was his family name, he was a target

10     of a search of the -- by the members of the city SUP because he was

11     suspected to be involved in smuggling weapons some two or three months

12     before this distribution of weapons took place.

13             So that man Skrijelj entered the police station at Bjelave and he

14     distributed weapons as he thought fit.  For those weapons, I had no

15     information who had received them; whereas, for the Marin Dvor station, I

16     did have all lists.

17             I wanted to add that to make it clearer so that there be no

18     misunderstanding.

19        Q.   Tell me, these irregularities, to use this euphemism, are

20     something you informed the MUP about; namely, the minister and

21     Deputy Zepinic and probably Momo Mandic, as Assistant Minister for the

22     police, as well as the chief of Centar, Mr. Sabovic; correct?

23        A.   Yes.  If I may add something that was of particular concern in

24     this case, which was that in the list of people who were issued with

25     weapons in Marin Dvor, I found 32 persons who had either been held

Page 16505

 1     responsible or criminal reports were filed against them for committing

 2     acts which are incompatible with the job of police officers.

 3        Q.   All right.  But to move on, the essence is that there was no

 4     feedback from the MUP of the Socialist Republic of Bosnia and Herzegovina

 5     in relation to your letter; correct?

 6        A.   I received nothing.

 7        Q.   And then after a certain passage of time, a delegation came from

 8     the Federal Secretariat of the Interior, and they were accompanied by

 9     some senior people from the centre, and also from the MUP of the

10     Socialist Republic of Bosnia-Herzegovina; and, once again, you informed

11     them about the situation; right?

12        A.   Yes.

13        Q.   Tell me, please, sir, do you know that the Hadzici SJB, which is

14     one of the municipalities within Sarajevo, isn't it?

15        A.   Yes, one of the urban municipalities belonging to Sarajevo.

16        Q.   Therefore, this SJB provided physical security to the MUP

17     facilities in Rakovica, which were weapons depots.  Are you aware of

18     that?

19        A.   Yes.  Each station covered the facilities in their territory,

20     facilities of importance, such as depots and so on.

21        Q.   Do you know that in the territory of that SJB, the Hadzici SJB,

22     there were several cases of similar abuse where the weapons from the

23     police depots were distributed without authorisation to the Muslims in

24     late 1991 and early 1992?

25        A.   In the meeting that I described, the meeting which I think took

Page 16506

 1     place in Ilidza at the Hotel Bosnia or Hotel Serbia, Glavas, Tiho - I

 2     think that he was the commander of the station in Hadzici - spoke about

 3     the problems which were of a similar nature as the problems that I

 4     encountered at Marin Dvor, concerning weapons, distribution of weapons,

 5     and so on.

 6        Q.   Tell me, please --

 7        A.   If I may just add:  It just came to me that I did not mention

 8     this man earlier.  And when you started talking about the subject, his

 9     name popped up in my mind.

10        Q.   In addition to these cases of distribution of weapons and

11     transfer into reserve police force of persons who did not get security

12     clearance, there were also problems with personnel in the MUP of the

13     Socialist Republic of Bosnia-Herzegovina, other problems; right?

14        A.   Yes.

15        Q.   So that some persons who, based on their way of life and their

16     qualities, were appointed to leading positions in the police, despite the

17     fact that their -- they had no adequate qualities?

18        A.   Yes.

19        Q.   And this was particularly widespread among the Muslim community,

20     as far as you know; right?

21        A.   Yes.  It took place in the area where I was too.

22             MR. ZECEVIC: [Interpretation] Your Honours, I'm not quite sure

23     whether it's time for the break now.

24             JUDGE HALL: [Previous translation continues] ... We've got

25     four minutes.

Page 16507

 1             MR. ZECEVIC: [Interpretation] Thank you.

 2        Q.   Sir, the last topic before the break.

 3             I think that in one of your statements - and you testified in the

 4     case of Lalovic et al. before the Court of Bosnia and Herzegovina - you

 5     spoke about how you learned about being put on the elimination list, on

 6     the list of people to be eliminated.

 7             Could you please explain briefly what sort of a list it was, and

 8     how did you learn about your name on that list?

 9        A.   Well, due to everything that went on, and there were a number of

10     things going on, the situation escalated from the point where they were

11     just issuing warnings to the point where a friend of mine - and this was

12     sometime in October - and I knew her because I had sent her family to

13     Germany early on, so she called me on the phone and asked to meet with me

14     urgently.  I had a young child and I also had guests in my house and I

15     didn't feel like going out, so I asked if that could wait.  And since

16     this friend of mine insisted, I asked her to come to my apartment and she

17     did.

18             In a brief conversation, she told me, Beware, you are a target.

19     And initially I didn't quite understand what she was aiming at, until she

20     took out a list.  It was just a plain sheet of paper with a list, written

21     in -- written with a pen, and out of seven people, my name was one of

22     them.

23             She told me that this list was read out in Stari Grad SJB, and

24     then the list was simply copied down.  And this was the list of people

25     who had to be eliminated.  Until then, I didn't really take this

Page 16508

 1     seriously.  I thought that everybody had the same frame of mind as I did,

 2     and I never thought that peoples' lives were worthless.  This was the

 3     first time I realised that I was at risk, and in two days I put my wife

 4     and our eight-month-old child on a plane to Hamburg.

 5             And this is what I can tell you in brief.

 6        Q.   Just two things that need to be clarified:  When you say October,

 7     you're referring to October of 1991?

 8        A.   My family left for Hamburg on the 11th of October, 1991.

 9        Q.   So the information that you received is something that you

10     received on the 8th or 9th of October; right?

11        A.   Precisely.  This was 20 days after the mobilisation and

12     everything that was going on, and throughout that time I was advocating

13     lawfulness in work.

14        Q.   Sir, and the lady who brought you that document, who brought you

15     the list of the persons to be eliminated, was actually the elimination

16     that was supposed to take place, should certain events occur?

17        A.   Yes.  That was the list of people that were to be eliminated

18     first.

19        Q.   And in addition to you -- you said that there was a total of

20     seven persons on that list.  In addition to you, were the other six also

21     Serbs?

22        A.   All of them were Serbs and members of police.

23        Q.   And my last question:  The chief of the Stari Grad station was

24     Ismet Dahic; right?

25        A.   I'm not sure whether it was Ismet or --

Page 16509

 1             THE INTERPRETER:  The interpreters didn't hear the other name.

 2             THE WITNESS: [Interpretation] It's possible that it was Ismet,

 3     but I'm not sure.

 4             MR. ZECEVIC: [Interpretation]

 5        Q.   At any rate, both Ismet Dahic and Bezdrob, Enes, were Muslims;

 6     right?

 7        A.   Yes.

 8        Q.   And one of them, at that point in time, was the chief of the

 9     Stari Grad station; right?

10        A.   Yes.

11        Q.   Thank you.

12             JUDGE HALL:  [Previous translation continues] ... we return in

13     20 minutes.

14                           [The witness stands down]

15                           --- Recess taken at 3.44 p.m.

16                           --- On resuming at 4.08 p.m.

17             JUDGE DELVOIE:  Just one brief thing before the witness comes in.

18     We have seen that a formal motion has been announced for the stipulated

19     facts.  I think ... I think we -- we made it clear on Friday that no

20     formal motion is needed.  We have -- we have now those -- the facts that

21     you -- that are already stipulated, and that's okay.  We have your signed

22     notice on that, so there is no further problem.  The only thing that

23     we -- we are still awaiting for, the follow-up of the other -- the

24     discussions over the weekend.  But that's another matter.

25             MR. ZECEVIC:  I understand, Your Honours.  It's obvious that

Page 16510

 1     probably we, as well as our friends from the Office of the Prosecutor,

 2     misunderstood your instruction, because we -- it was my understanding

 3     that, for the already stipulated facts, that we are supposed to send an

 4     e-mail with a signature, as a notice.  But for the -- for the ones that

 5     we were discussing over the last three, four days, that we would need to

 6     file a joint motion.  That is -- that was my understanding.  I might be

 7     wrong, so whatever the Trial Chamber is --

 8             JUDGE DELVOIE:  As long -- as long as we know what happens, it's

 9     in the parties' hands to stipulate, so if we are -- if we get normal

10     notice of the fact of what is stipulated, it's okay with us.

11                           [The witness takes the stand]

12             MR. ZECEVIC:  I understand.  We will discuss with our friends

13     from the Prosecution.  And, of course, what -- what we are doing is

14     precisely that the Trial Chamber should -- should be aware of.  That goes

15     without saying.

16             JUDGE DELVOIE:  Okay.  Thank you.

17             MR. ZECEVIC:  May I continue?

18             JUDGE HALL:  Just a moment, please, Mr. Zecevic.

19             Mr. Planojevic, I just wanted to bring to your attention that in

20     terms of the matter that you raised when we began this afternoon that we

21     have observed that the article in question has since been removed from

22     the web site of SENSE.  Thank you.

23             Yes, Mr. Zecevic, you may continue.

24             MR. ZECEVIC:  Thank you, Your Honour.

25             THE WITNESS: [Interpretation] Thank you.

Page 16511

 1             MR. ZECEVIC: [Interpretation]

 2        Q.   Mr. Planojevic, since we established that your experience as an

 3     active-duty policeman spans over 30 years, perhaps you can tell me

 4     something about the check-points at which ID checks were carried out, as

 5     well as vehicle control, in terms of security measures, and it pertained

 6     to all vehicular traffic.

 7             Such exercises were conducted in the former Yugoslavia as a type

 8     of operational measures undertaken by the police?

 9        A.   Yes.  These were tactical operational measures.

10        Q.   Such tactical operational measures as setting up check-points was

11     standard practice when erected along access routes to towns or at

12     important intersections of regional roads; is that correct?

13        A.   Yes.

14        Q.   Such operational tactical measures, namely, the establishing of

15     the check-points, is something that was pursued throughout the former

16     Socialist Republic of Yugoslavia even before 1994 [as interpreted]; is

17     that correct?

18        A.   Yes.  It had always been done, ever since I began working.

19             MR. ZECEVIC: [Interpretation] Page 32, line 20, I think it says

20     "1994," whereas I believe I said "1990."

21        Q.   Especially after the events of 1990 and 1991, such operational

22     tactical measures became much more frequent, in terms of the number of

23     check-points that were set up throughout the SFRY; is that correct?

24        A.   Yes, it is.

25        Q.   Including Bosnia-Herzegovina; correct?

Page 16512

 1        A.   Yes.

 2        Q.   You are probably familiar with an operation jointly carried out

 3     in 1992 by the ministry of the socialist republic -- the Ministry of the

 4     Interior of the Socialist Republic of Bosnia and Herzegovina and the

 5     federal SUP called Punkt 1991.  Or perhaps it was the JNA; I'm not

 6     certain.

 7             Are you familiar with the operation?

 8        A.   There were both.  In agreement with the minister, they arrived in

 9     the location where I represented the federal ministry.  And there were

10     representatives of the B&H MUP there.

11             On the other hand, there was the agreement between Kukanjac, as

12     the army commander, and Minister Delimustafic, I believe, to have joint

13     patrols because there were raising tensions at the time.  I believe this

14     is how it worked.

15        Q.   So in addition to the check-points which were set up as a result

16     of the agreement between the Ministry of Interior of the

17     Socialist Republic of Bosnia and Herzegovina and the federal SUP, there

18     were also joint check-points manned by military policemen and civilian

19     policemen pursuant to another agreement between the commander of the

20     2nd Military District, General Kukanjac, and the interior minister of

21     B&H, Alija Delimustafic.  Is that the gist of your answer?

22        A.   Yes, it is.

23        Q.   Very well.  Another routine operational measure in police work is

24     to ascertain the identity of persons by checking their IDs or other

25     personal documents.

Page 16513

 1        A.   If there is a operational measure to put in place, that would be

 2     the first step to take, which would then be followed by others.

 3        Q.   In 1989 and the period up to 1992, the -- there was an increasing

 4     problem of illegal smuggling of arms, hence, one of regular operational

 5     measures undertaken at such check-points was also to check the trunks of

 6     motor vehicles as well as any luggage found therein; is that correct?

 7        A.   Yes.

 8        Q.   On Friday, you briefly discussed a topic with Mr. Hannis, namely,

 9     the event of the 4th of April in the evening.  I would simply like to

10     briefly enumerate all the things that took place on the 4th of April.

11             It is a fact that on the 4th of April, in the evening, your

12     workmate Risticovic [phoen] from the town SUP was attacked in the public

13     security station?

14        A.   A correction:  It was the town SUP, meaning that the unit covered

15     the whole town.  He was an employee of the town SUP.  And at the very

16     entrance of the building, he was badly beaten up and left unconscious.

17        Q.   It took place on the 4th of April in the evening?

18        A.   Yes.

19        Q.   He was attacked and beaten up by members of the Green Beret;

20     correct?

21        A.   Yes.  He told me that when I went to visit him.  He was in

22     hospital for quite a long time.  It was the makeshift hospital that we

23     had at the time.

24        Q.   Did the members of the Green Berets put the barrel of a gun in

25     his mouth, pulling the trigger, but the chamber was actually empty; is

Page 16514

 1     that correct?

 2        A.   Well, he believes that the gun actually misfired, not that the

 3     chamber had been empty.  He was simply lucky enough, but he still feels

 4     the consequences of that shock.  He never fully recovered.  I believe he

 5     resides in the Netherlands now.

 6        Q.   It is also true that your workmate Lazar Bojanic was also beaten

 7     up that evening; is that correct?

 8        A.   Yes.  And if you need any further explanations, I'm ready to

 9     offer them.

10        Q.   He was also a member of the police and was on duty when he was

11     beaten up; is that correct?

12        A.   He was, yes.  He was the shift leader in the Novo Sarajevo Police

13     Station.  Therefore, yes, he was on duty.

14        Q.   On that occasion, he saw Ismet Dahic accompanied by Mr. Puskar,

15     who was at the helm of the Green Berets, I believe?

16        A.   It was some 150 or 200 metres away from the Novo Sarajevo

17     Police Station.  He went there to assist the station, which had been

18     attacked, and he received a blow to the head with a butt rifle -- with a

19     rifle butt, and he asked the man you mentioned to allow him to go to the

20     nearest emergency ward to receive assistance, and was allowed to do so.

21        Q.   When Lazar Bojanic was attacked, another Serb police member was

22     killed.  I believe his first name was Pero.  Is that correct?

23        A.   Pero Petrovic was killed.  He was not an employee of that

24     particular station.  He just happened to be there because he came to

25     report a crime.  He was there by chance.  First, he received a blow with

Page 16515

 1     a rifle butt and was then shot at the back of his head.

 2        Q.   And it all took place inside the Novo Sarajevo Police Station; is

 3     that correct?

 4        A.   In the room of the shift leader.

 5        Q.   You -- we mentioned Ismet Dahic, who was a career policeman and

 6     either the chief or commander of the SJB in Stari Grad in Sarajevo; is

 7     that correct?

 8        A.   We attended high school together, and our careers developed in a

 9     similar fashion.  We had always worked for the police.

10             I -- he used to be the chief there, but at the moment when I

11     received that document, I don't remember whether he was any longer in

12     that position.

13        Q.   Since he was near the Novo Sarajevo Police Station accompanied by

14     Sakib Puskar, who was the leader of the Green Berets, he was there in an

15     area which was not under the competence of his public security station.

16        A.   Yes.  There was another police station between the two.  That was

17     the approximate distance.

18        Q.   A certain Slobodan Vreco also had a number of hooded men enter

19     his SJB on the night of the 4th of April; is that correct?

20        A.   If I remember well, Slobodan Vreco was in front of the

21     Novo Sarajevo Police Station when they stormed the premises and he fled.

22     He wasn't in the building itself and was not affected by the attack.  He

23     simply escaped before it all took place.

24        Q.   That same evening, in your station, where you were on duty, a

25     person was brought in, as you described, whereupon you learned that the

Page 16516

 1     person had been armed and had been ordered to guard the municipal

 2     assembly building.  Given that it made you conclude that there was

 3     something going on, you went home.

 4        A.   Yes.

 5        Q.   And everything we have just been discussing, these incidents, is

 6     something you were informed of by telephone that evening, as they

 7     transpired; is that correct?

 8        A.   Some of the information I received that evening; whereas, other

 9     information I received in contact with the witnesses, the participants of

10     those events.

11        Q.   What you were able to conclude, and it is why you left the

12     station in Marin Dvor to go home, is something that amounted to a

13     sychronised attack on most SJBs in Sarajevo territory; is that correct?

14        A.   Yes.  Perhaps I can clarify further.  The Serb police in

15     Stari Grad left the area a month before the war, so there was a police

16     station with only one Serb policeman; I believe his name was Tosic.  The

17     other policeman arrived in the centre, where I was, there were four of

18     them, because of the pressure that had been put on them.

19             The ethnic make-up in -- of the population in Stari Grad is some

20     70 per cent of Muslims.  Marin Dvor, which is the next station, and

21     Bjelave, were in the territory that had already been abandoned by most

22     Serbs.  And that evening, as I said, I asked that station commander to

23     keep them there until the next morning.

24             So in the centre there were nearly 400 beret members in action.

25     There was the police hall in the area of the town centre which was also

Page 16517

 1     taken over by Jusuf Prazina, a hardened criminal.  And there was a number

 2     of other stations that were taken over as well.  The same goes for the

 3     traffic police.  They were close to the Novo Sarajevo station.  I already

 4     told you about the Novo Sarajevo station.

 5             As for the Novi Grad SJB, when I called them that evening, I

 6     learned that they had two Serbs in that shift.  So it was only Ilidza

 7     that was left.  And there were some 60 to 70 per cent of Serbs living in

 8     Ilidza.  And that station had a Bosniak chief, Edin Milic [phoen].  He

 9     appeared on TV in mid-April.  I believe his name was

10     Edin Mlijevic [phoen].

11             That was more or less the sequence.  Those stations were taken

12     over during that night.  It wasn't that we left because we wanted to; our

13     lives were at stake.

14        Q.   You also received some threats on the phone that night.  You

15     spoke about that already.  There's no doubt that you and other Serb

16     police officers were scared for yourselves and for your families; right?

17        A.   Yes.  But most of us had already taken our families out of

18     Sarajevo.

19        Q.   Tell me, Mr. Planojevic, the events on the 4th of April were

20     really a -- crossing the point of no return; right?

21        A.   Well, you would have to be blind not to notice that.

22        Q.   Tell me, on the following day, with a group of colleagues, you

23     went to Vraca.  And you said on Friday, giving evidence to Mr. Hannis,

24     that it had been agreed that Vraca should be the headquarters of the SUP

25     of the Republika Srpska.  That's why it wasn't expected that there would

Page 16518

 1     be a conflict.

 2             Do you remember that?

 3        A.   Yes.

 4        Q.   However, upon your departure on the 5th, in the afternoon hours,

 5     a conflict did break out; right?

 6        A.   Yes.

 7        Q.   I hope that you know that the agreement about the division of the

 8     MUP of the Socialist Republic of Bosnia-Herzegovina was part of the

 9     Cutileiro Plan; right?

10        A.   Yes.  I said as much on Friday.

11        Q.   Very well.  On Friday, you stated that upon leaving Vraca on the

12     5th in the morning, you first went to Pionirska and then to Rogatica, I

13     think, and that you reported for duty at the MUP on Monday.  You said it

14     was the 19th of April.  But I checked, as -- Monday was the

15     20th of April.

16             Do you remember it was a Monday?

17        A.   It certainly was Monday.  I thought it was the 19th.

18        Q.   Very well.  You were appointed assistant minister, and you got an

19     office at the school at Vraca; right?

20        A.   Yes.

21        Q.   At that moment, your immediate superior was the under-secretary

22     for public security, Mr. Cedo Kljajic, since the administration you

23     headed belonged to public security; right?

24        A.   Yes.  He was chief of police and the crime services.

25        Q.   You will agree with my conclusion that the MUP of the RS was

Page 16519

 1     being created in April from scratch; right?

 2        A.   Yes.  But we called it building it from a -- from a tree stump.

 3        Q.   It's a fact that when you reported for duty you didn't even have

 4     typewriters; right?  Or at least not enough.

 5        A.   More of us shared one.  That was the police school.

 6        Q.   If I understood correctly, the shortage of personnel was a huge

 7     problem.  I mean, personnel of the MUP of the RS at the time.  Right?

 8        A.   Yes.  Our ranks were sparse because many of us had left to see

 9     their families at their homes.

10        Q.   At that moment, there was a chaotic situation, and if I

11     understood correctly, most people first took their families to a safe

12     place, and that was their first priority, rather than doing their job;

13     right?

14        A.   Yes.

15        Q.   Tell me, at the time when you arrived and during the following

16     period that you spent at Vraca, that is, about a month and a half, you

17     had no communication with any CSB, did you?

18        A.   No.  Most of them still weren't in existence.  They hadn't yet

19     been established or up and running.

20             When I say that, I mean they existed on paper, but there was no

21     infrastructure in reality.

22        Q.   Do you know, sir, that even the Law on the Interior of the RS

23     from March 1992 envisages the CSB of Ugljevik as one of the CSBs and --

24     rather than Bijeljina?  Do you know that?

25        A.   Yes.  But there were no conditions.  I don't think I need

Page 16520

 1     explain.  But the law said Bijeljina.  But there was never one man there,

 2     so it couldn't -- it couldn't function.

 3             MR. ZECEVIC: [Interpretation] Page 40, line 25, the law said

 4     Ugljevik, but that was a mistake.  Later the law had to be amended to --

 5     to say Bijeljina.

 6             THE WITNESS: [Interpretation] Yes.

 7             MR. ZECEVIC: [Interpretation]

 8        Q.   Sir, if I understood your evidence given on Friday correctly, on

 9     the 25th of April you arrived at Vraca, and you stayed there until the

10     8th of May, when you went to Belgrade because your wife had given birth

11     to a child?

12        A.   Yes.  But in the meantime, I also went there and spent three days

13     there for Easter.

14        Q.   And then you returned on or about 27th of May to Vraca.  And then

15     between the 5th and 7th of June, 1992, you were transferred to

16     Kalovita Brda, that is, the building at Pale?

17        A.   That is correct.  But I'm not certain about the dates.  It may be

18     a day or two earlier or later.

19        Q.   In June, you went to some municipalities in the territory of

20     Sarajevo:  Vogosca, Ilidza, Ilijas.  Right?

21        A.   Yes.

22        Q.   On 9 July, did you go to Belgrade to attend the first collegium

23     which was held on the 11th, and did you return from that collegium on or

24     about the 19th of July?

25        A.   I have a correction.  I went there on the 9th of June and spent

Page 16521

 1     seven days there.  And then did I go there in July.  I remember the date

 2     because of the funerals and the -- the fighting on the 8th.  Once the

 3     fighting stopped, I -- on the following day, I immediately went to

 4     Belgrade and stayed there seven days, or eight.

 5        Q.   Tell me, it's a fact that on or about 9 July you went to Belgrade

 6     and returned about the 19th.  And then on the 21st or 22nd of July, you

 7     were relieved of your position; correct?

 8        A.   Yes.

 9        Q.   In July, the shortage of materiel and equipment, shortcomings in

10     communications lines, shortage of personnel in the MUP of the RS were all

11     acute problems; right?

12        A.   Yes, practically throughout the war, but especially during that

13     time-period.

14        Q.   I'll show you a document.

15             MR. ZECEVIC: [Interpretation] P1419.

16        Q.   And I'll ask you to comment.

17             While we're waiting, I see that your answer -- or, yes, it has

18     been recorded.  I apologise.

19             Sir, this is a list of employees of the MUP headquarters for

20     July 1992.  It says:  MUP headquarters collegium.

21             Can you see it?

22        A.   Yes.

23        Q.   I'm saying this because at one moment, even today, you commented

24     on two persons, and that is Zoran Jasarevic, number 10; it says driver of

25     the minister or the ministry.  And number 14, Goran Abazovic, escort.

Page 16522

 1             Can you see it?

 2        A.   Yes.

 3        Q.   Are these the persons you said accompanied Minister Mico Stanisic

 4     in July 1992?  One was his driver, and the other his escort.

 5        A.   Yes.

 6        Q.   On Friday, document 1D46 was shown to you.

 7             MR. ZECEVIC: [Interpretation] May we have it again, please.

 8        Q.   Do you remember this document?  It's dated 15 May 1992.

 9             Do you remember seeing this document?

10        A.   Yes.

11        Q.   Your evidence was that -- on Friday, that on 15 May you were not

12     at Vraca but in Belgrade.  However, you were pretty certain that

13     Cedo Kljajic familiarized with you the contents of this document.

14             Do you remember saying that on Friday?

15        A.   Yes, the contents of the document; that's true.  But I'm not sure

16     whether I saw the document itself.

17        Q.   At the beginning of my examination, we mentioned the mobilisation

18     of the reserve force of the MUP of the Socialist Republic of

19     Bosnia-Herzegovina in September 1991, that is, when we were discussing

20     that and the -- the arming of the reserve force.  Now tell me about this

21     mobilisation and this arming process.  This -- was this in line with the

22     defence plans of the MUP of the Socialist Republic of Bosnia and

23     Herzegovina?

24        A.   Yes.  I apologise.  But every station had its own plans and

25     everything was prescribed in these station-level plans, not only at the

Page 16523

 1     level of the republic.  Because each station had to develop its plans,

 2     and it had to be ready to act upon them.  Especially in wartime, this

 3     meant the implementation of all the laws upon which these plans were

 4     founded.

 5        Q.   Sir, it is a fact, isn't it, that according to the then-laws, the

 6     laws in force then, and specifically the Law on All People's Defence and

 7     Social Self-Protection, which was both at the republic level and at the

 8     federal level, each organ, each institution, and each company had to have

 9     a plan for wartime organisation; right?

10        A.   Absolutely.

11        Q.   As you have testified, let me just summarise that.

12             Such a plan on wartime organisation existed at the level of the

13     Ministry of the Interior of the Socialist Republic of Bosnia and

14     Herzegovina, and also at the level of all CSBs, and, finally, at the

15     level of each individual SJB in the territory of Bosnia and Herzegovina;

16     right?

17        A.   Yes.

18        Q.   To go back now to this document dated the 15th of May.

19             Mr. Planojevic, it is a fact, isn't it, and you testified about

20     it, that you never ever issued an order as a member of the MUP staff?

21        A.   No, I didn't.

22        Q.   I formulated the question erroneously, so it's not entirely

23     clear.

24             Therefore, it's true that you never ever issued an order as a

25     member of the staff; right?

Page 16524

 1        A.   Yes, that's true.

 2        Q.   Mr. Hannis showed you, on the second page of this document,

 3     paragraph 9, where it says that you, as assistant minister, pursuant to

 4     this order, are also a member of the staff.

 5             Do you see that?

 6        A.   Yes.

 7        Q.   Tell me, it is true, isn't it, that you never even received an

 8     order from some alleged staff of the Ministry of the Interior of

 9     Republika Srpska.  That's true, isn't it?

10        A.   Yes, that's true.

11        Q.   Do you know whether any of your colleagues, including

12     under-secretaries of the ministry and other individuals, received any

13     sort of an order that would have the heading of the Ministry of the

14     Interior of Republika Srpska?

15        A.   I'm not aware of anybody receiving such an order.

16             MR. ZECEVIC: [Interpretation] I said heading of the staff of the

17     Ministry of Interior of Republika Srpska.

18        Q.   It's true, isn't it, that you never attended or heard of a

19     meeting of the staff of the Ministry of Interior being held?

20        A.   I neither heard of a meeting ever being held, nor did I attend.

21        Q.   Sir, given that you were assistant minister and a member of the

22     staff, it would be logical to expect that, had a document of such a staff

23     ever been issued, you would have seen it; right?

24        A.   I suppose so.

25        Q.   Very well.  Tell me, sir, the Law on All People's Defence and

Page 16525

 1     Social Self-Protection, and the Law on The Internal Affairs of Republika

 2     Srpska, or, rather, the federal Law on All People's Defence and Social

 3     Self-Protection, that federal law was simply taken over by the Assembly

 4     of Republika Srpska.  Are you aware of that?

 5        A.   Yes.  Like the majority of laws.

 6        Q.   It is a fact that the Law on Internal Affairs of Republika Srpska

 7     had very few differences as compared to the law of Yugoslavia?

 8        A.   Yes, they were very similar.

 9        Q.   And you will agree with me, won't you, that the MUP of

10     Republika Srpska was duty-bound to also adopt a so-called wartime plan;

11     right?

12        A.   Yes.

13        Q.   However, due to events and the speed with which they were taking

14     place, such a plan was not adopted in the course of 1992; right?

15        A.   It wasn't adopted, but there probably are additional reasons for

16     that.  And if I may expand on that.

17             We lived in one state where all plans were alike.  And I have to

18     be creative in phrasing this.  The plans were drafted with scenarios

19     where there were attacks from the west and from the east, and one needed

20     great minds to create such plans from scratch.  And that was an

21     additional reason.  That was also the problem we were encountering; we

22     had neither resources nor people capable of drafting such plans, let

23     alone the conditions that were difficult at the time.

24             This was just by way of clarification.

25             So the concept was completely different.  The whole system was

Page 16526

 1     created on different foundations.

 2        Q.   Sir, we're about to move to your meetings with Mico Stanisic in

 3     1992.  I would just like to explore some general views and positions

 4     right now.

 5             It's true, isn't it, that Mr. Mico Stanisic, as minister,

 6     insisted that the police do the tasks that were under its jurisdiction

 7     under the law, to take care of law and order rather than take part in

 8     combat and wartime operations.  That's true, and that was the position of

 9     the minister; right?

10        A.   Yes.

11        Q.   Also, you, as assistant minister in charge of suppressing crime,

12     received a carte blanche from Mico Stanisic, the minister, to do your

13     work; right?

14        A.   Yes.

15        Q.   And when I say a "carte blanche," I meant that you were to take

16     action in accordance with powers that you had under the law; right?

17        A.   Yes.

18        Q.   And to that effect, I think that you gave an example whereby at

19     one point in time the minister gave powers to you and Mr. Karisik,

20     commander of the special police detachment, to use members of that

21     special unit when you saw fit, when there was a need for that; right?

22        A.   Yes, right.

23        Q.   Tell me, Mr. Planojevic, the role of the ministry and the

24     ministry administrations is first and foremost of an instructive nature;

25     right?

Page 16527

 1        A.   Yes.  They instruct and coordinate.  That is their role.

 2        Q.   Very briefly, give us explanations for the instructive role of

 3     the ministry.

 4        A.   The instructive role means that the general policy that guides

 5     the work of the administration is set, is given guide-lines, instructive

 6     enactments or instructions, and possibly, in very complex cases,

 7     inspectors are to get involved in operative work.  But, again, only to

 8     give instructions, not to actually carry out work or implement it.

 9        Q.   And to that effect, you, as chief of the administration for crime

10     suppression, sent out inspectors from your administration precisely in

11     order to give instructions to some CSBs and SJBs in 1992, to those that

12     you were able to reach physically; right?

13        A.   Yes.

14        Q.   It's right, isn't it, that you also had cases where some

15     inspectors that you had sent out on a mission never came back to the

16     ministry but, rather, they would flee abroad.  They would move out abroad

17     while being on official mission; right?

18        A.   Yes, that's correct.

19        Q.   And that is quite telling of the situation as it was in 1992.  It

20     is a good illustration of what the discipline of the members of the

21     ministry was.

22        A.   It speaks of the entire society, what the society was like, not

23     of how disciplined persons were.  We had problems in providing livelihood

24     and safety for our families, and I personally didn't have such great

25     problems but others did.  So it is not up to me to judge them, to condemn

Page 16528

 1     them.  That's how the times were.  You can't even imagine it now.  And I

 2     hope for you that you -- you personally would never experience this.

 3        Q.   That's precisely why I'm asking you this, because the context is

 4     very important for the case.  The context of the entire situation.  I

 5     think that you said that this also involved the personal courage of

 6     various individuals.  Not everybody was equally brave.  And that didn't

 7     get recorded in the transcript.

 8             Can you please confirm that you said that?

 9        A.   Yes, yes.  I didn't understand that this was a question.

10        Q.   I apologise.

11             Now to go back to what you discussed with Mr. Hannis on Friday,

12     that is to say, meetings with Mico Stanisic in 1992.

13             If I remember -- if I understood you well, you mentioned a total

14     of five encounters, and I will enumerate them for you now.  The first one

15     was in early May at the school in Vraca; the second one you mentioned was

16     in early June at the Kosuta hotel; the third meeting was in late June,

17     accidental chance meeting in front of the Bistrica hotel; the fourth

18     meeting was around the 20th of July, when you argued with the minister

19     and resigned; and the fifth meeting was sometime in October of 1992,

20     when, again, you met by chance in the forest when the -- the defence

21     lines at Praca fell.

22             Did I summarise all your meetings with the minister in 1992

23     correctly?

24        A.   You did.

25        Q.   When you met him for the first time in early May in Vraca, you

Page 16529

 1     met Mico Stanisic in the presence of Mr. Mico -- Cedo Kljajic,

 2     under-secretary for public security; right?

 3        A.   Yes.

 4        Q.   And, among other things, you discussed how, according to you and

 5     to Cedo Kljajic, Mr. Momo Mandic should not be deputy minister of the

 6     interior; right?

 7        A.   Right.

 8        Q.   That was so because you had some indications and also because of

 9     the fact that he was having contacts with Skrbo and Vuletic, persons who

10     were - let me put it like this - people who were on the shady side?

11        A.   That's correct.

12        Q.   In addition to the indicia that you had -- or, rather, except for

13     the indicia that you had, you did not have any evidence that would make

14     it possible for you to have Mr. Mandic and the other persons taken

15     through some kind of legitimate criminal proceedings; is that correct?

16        A.   Yes.

17        Q.   You made a proposal to the minister; you presented him with your

18     position on the issue.  However, even then it was clear to you that

19     Mico Stanisic does not have the authority to replace Momo Mandic from

20     this position of deputy minister.  Am I right?

21        A.   I did already tell the OTP that the procedure was the same for

22     appointing both the minister and the deputy minister.

23        Q.   When you say "the procedure is the same for appointing both the

24     minister and the deputy minister," by that you mean that this appointment

25     is something that is reached, that it's a decision reached by high-level

Page 16530

 1     organs and more important people who are in charge of making such

 2     decisions?

 3        A.   Yes, that's what the law prescribes.

 4        Q.   Thank you.  Your next meeting was held in early June in the

 5     Kosuta hotel.

 6        A.   Yes.  Upon my request.

 7        Q.   On that occasion, you asked the minister -- or, rather, you

 8     presented to the minister that the withdrawal of the special detachment

 9     from Vraca would create certain problems.  Let's now -- let's not get

10     into that because you've already testified about it.  Is that correct?

11        A.   Yes.

12        Q.   On that occasion, if I understood you correctly, you also told

13     him about what you knew about certain Vlahovic, Batko; you told the

14     minister about him?

15        A.   I'm not sure whether it was on that occasion or maybe when we

16     just meant accidentally, later on.  The way I remember it, it was when we

17     meant in front of the Bistrica hotel.  Because during the first meeting I

18     didn't have the information that I told him about at this later meeting.

19     One must bear in mind that it was all happening within a short period of

20     time and I cannot be precise about the dates.

21        Q.   I understand you completely.  It's been a long time ago, and I do

22     not insist on specific dates here.  I would just like to put things into

23     a proper context.

24             As I understood you, during your stay in Belgrade, you had heard

25     from a friend of yours, so that was in Belgrade, when you heard about

Page 16531

 1     Batko who also used to go to Belgrade, that he was bragging in Belgrade

 2     about crimes he had committed in Sarajevo.  That's where you got your

 3     information.

 4        A.   Yes, that's correct.  But I must add something, because things

 5     come to my mind as I speak.  Upon my return, I went to a Croatian

 6     family's flat at Grbavica.  I was aware that people who were non-Serbs

 7     know more, or at least talk more, about it.  I think the surname of this

 8     family was Mihic.  They told me that they had heard this Batica being

 9     mentioned.  So that was -- motivated me to take further steps, and I

10     explained the steps I took.

11        Q.   After your return, in addition to going to speak to the Croats

12     that you knew at Grbavica, you also asked one of your colleagues, an

13     inspector, to check the information you had, and he did tell you that

14     there were certain indicia, or at least rumours, that this Batko was

15     involved in some kind of crime.

16        A.   Yes.

17        Q.   You informed the minister about it; the minister told you that he

18     will inform the Main Staff of the VRS; and he also tasked you with

19     monitoring the situation, namely, whether the army is going to take

20     measures in relation to this Batko character.  Is that correct?

21        A.   Yes.

22        Q.   You did as you were told, and after a certain period of time, he

23     was arrested by the military police and detained in the military prison

24     at Lukavica, which is within Sarajevo; am I right?

25        A.   But before that, he had been informed by someone that the police

Page 16532

 1     had started -- had started taking measures, and he was not in the area

 2     for, as I was told, about 20 days.  Upon his return, he was arrested.  I

 3     know that for a fact because it -- it was immediately known that this

 4     person was arrested by the military police and that he's at Lukavica.

 5             JUDGE HALL:  When you reach a convenient point, Mr. Zecevic.

 6             MR. ZECEVIC:  Just one question, Your Honours.

 7        Q.   [Interpretation] Later on, you received information that he was

 8     released by the military authorities from that prison, but you don't know

 9     anything else about it?

10        A.   I don't know.  This arrest of his may have taken place at the

11     time when I resigned and I wasn't there.  He was absent for a period of

12     20 days, and it may be that I resigned in the meantime, and all the

13     information I have was second-hand information.

14        Q.   Thank you.

15             MR. ZECEVIC: [Interpretation] I think this would be a good

16     moment, Your Honours, because I would like to move to the next meeting,

17     and ...

18             JUDGE HALL:  We return in 20 minutes.

19                           [The witness stands down]

20                           --- Recess taken at 5.21 p.m.

21                           --- On resuming at 5.46 p.m.

22                           [Trial Chamber confers]

23                           [The witness takes the stand]

24             MR. ZECEVIC:  May I continue?

25             JUDGE HALL: [Microphone not activated] ... yes.  Yes, please.

Page 16533

 1             MR. ZECEVIC:  Thank you.

 2        Q.   [Interpretation] Mr. Planojevic, we've reached the third meeting

 3     now, your third meeting with Mr. Mico Stanisic.  You said you

 4     accidentally ran into him in front of the Bistrica hotel.  Am I correct?

 5        A.   Yes.

 6        Q.   On Friday, a few questions were put to you about this meeting.

 7     You remembered it.  Mr. Stanisic had a German Shepherd with him, which

 8     was unusual, and my learned friend asked you about it, and then you made

 9     some jokes about this German Shepherd dog.  Do you remember saying that?

10        A.   Yes.

11        Q.   When you were joking on that occasion, you said it was a

12     German Shepherd that was owned by Josip Broz, Tito, during the

13     Second World War and it was called Rex the dog.

14        A.   Yes.

15        Q.   Mr. Planojevic, for a long period of time there were jokes

16     circulated about Mr. Stanisic concerning the fact that in 1973 he was

17     honoured, as a member of a youth organisation, to take the -- to take the

18     staff on occasion of Tito's birthday.  He was the one who carried it from

19     Sarajevo.

20             I don't know what the proper word for this relay staff that

21     people pass on in English, but it was one of the traditions of former

22     Yugoslavia.  On the 24th of May, which was the National Youth Day,

23     President Tito would be handed this baton by a representative of the

24     youth organisation of former Yugoslavia.

25        A.   Yes, that's correct.

Page 16534

 1        Q.   It is a fact also that this was a honour awarded only to the best

 2     among the youth.

 3        A.   Yes.

 4        Q.   It is also a fact that the concept of brotherhood and unity was

 5     one of the central elements, pillars, of the Socialist Federative

 6     Republic of Yugoslavia; am I right?

 7        A.   Yes.

 8        Q.   Your answer hasn't made the transcript -- oh, it has.  I

 9     apologise.

10             So, on the basis of what we've just said, one can conclude that

11     Mr. Mico Stanisic neither at that time nor later had any dislike for

12     people of different ethnic groups of former Yugoslavia.

13        A.   That's absolutely true.

14        Q.   And that was also the case in 1992, when you became assistant

15     minister.  And you know Mr. Stanisic since 1973, or even before, from

16     your school days.

17        A.   We know each other since 1971, and he never in any action or

18     statement of his would show that he had that kind of attitude.

19        Q.   Were there any such elements pronounced in him, he wouldn't have

20     been honoured to carry this baton for President Tito.

21             You already told my learned colleagues what the topic of the

22     discussions were on that occasion, so I won't go into that.

23             And then your next meeting took place on or about 19 or 20 July,

24     after your return from Belgrade, when you had an argument with

25     Mr. Stanisic.

Page 16535

 1        A.   That's correct.

 2        Q.   If I understood your testimony on Friday correctly, you had

 3     information that he was looking for you.  You found him sitting in an

 4     office or a room in a hotel together with Momo Mandic.  They were just

 5     having a conversation of informal nature?

 6        A.   My colleagues from the administration, or the employees, told me

 7     that he'd been looking for me for the two or three days preceding that

 8     and that I should report to him immediately.  But I arrived in the

 9     evening hours, so I went to see him in the morning next day.

10             And upon my arrival at the Bistrica hotel, I asked where he was.

11     I think he even had a room there; it was apartment 305, I think.  But he

12     wasn't there, and the people at the desk told me that he was in one of

13     the rooms, and that's how I found him.

14        Q.   Thank you.  Your next meeting was sometime in October 1992, when

15     you met him somewhere in a forest after the lines at Praca fell, when

16     Mico Stanisic was there to visit his parents.  That was in October 1992.

17        A.   Yes, that's correct.  It may have been September, but I'm not

18     sure.

19        Q.   I think you told my learned colleague - and I'm not sure whether

20     it was today, early today, or on Friday - you told him that you remember

21     that, on that occasion, when you had met Mico Stanisic in the forest,

22     that with him were his driver, Jasarevic, and an escort of his,

23     Goran Abazovic.  Is that correct?

24        A.   Yes.

25        Q.   Mr. Planojevic, in addition to the meetings with the minister

Page 16536

 1     that we discussed, during the direct examination you also mentioned two

 2     meetings with Branko Djeric, who was the prime minister.  Do you remember

 3     talking about that?

 4        A.   Yes.

 5        Q.   The meetings with prime minister, Mr. Djeric, they were not

 6     official meetings, were they?

 7        A.   One was arranged, when I brought some written material.  But the

 8     first one, the first one was informal.

 9        Q.   On the first occasion, you went to see him together with a

10     professor.

11        A.   Vaso Dragovic.

12        Q.   Thank you.  So you went to have a cup of coffee with

13     Professor Vaso Dragovic, and then Professor Dragovic invited

14     Prime Minister Djeric to join you.  And you'd known Prime Minister Djeric

15     because you are from the same town and you know each other from way back.

16        A.   Yes.

17        Q.   Your second meeting was, as you told us, four or five days after

18     the meeting you had had with Minister Stanisic at Kosuta hotel.  Do you

19     remember that?

20        A.   Yes, that's what I stated.

21        Q.   Sir, please, on that second occasion, you also discussed this

22     Batko.  Batko Vlahovic.

23        A.   Yes.

24        Q.   Since you had a conversation with the minister four or five days

25     prior to that, when the minister told you that he would inform or,

Page 16537

 1     rather, discuss with the men from the Main Staff about the problem, you

 2     had no reason to doubt that Mr. Stanisic would actually talk to the army

 3     representatives about the arrest of this Batko Vlahovic?

 4        A.   Yes.  I can elaborate, but, please, go on with your questioning.

 5        Q.   So that your conversation with Prime Minister Djeric does not

 6     mean that you requested him to intervene because you fostered doubts that

 7     Minister Stanisic would intervene with the military bodies.

 8        A.   No.  I didn't suspect that.  But the situation being what it was,

 9     and it was serious, the prime minister asked me, once I had spoken about

10     the problems I had had earlier, I added that I had spoken with the

11     minister.  And I considered that to be a serious problem.  And I said to

12     him, Let's not delay tackling this problem.

13             Some people, as you know, don't like to communicate without

14     authority.  I don't want to say more because given my experience with the

15     press, I really must watch my Ps and Qs.  But the prime minister was a

16     man of authority, and I don't know who had spoken to him, whether it was

17     the president or the General Staff.  The prime minister would have said

18     if he had been against that.

19        Q.   [Microphone not activated]

20             THE INTERPRETER:  Microphone, please.  Microphone.

21             JUDGE DELVOIE:  Microphone.

22             MR. ZECEVIC:  Thank you.  I'm sorry.  My apologies.

23        Q.   [Interpretation] If I understand correctly, you mentioned the

24     case of Batko Vlahovic to Prime Minister Djeric.  Firstly, because you

25     considered that a serious problem; and, secondly, because you thought

Page 16538

 1     that the prime minister doubtlessly had -- would be respected more in

 2     military circles than the minister.

 3        A.   Yes.  The army and the police weren't really on friendly terms,

 4     even in peacetime.  There was always a sort of rivalry, who was more

 5     important.

 6        Q.   Thank you.  The prime minister then spoke to somebody; you or I

 7     don't know who.  And, at any rate, after some time, Batko Vlahovic was,

 8     indeed, arrested.

 9             We have made that clear, haven't we?

10        A.   Yes.

11        Q.   You were on friendly terms with Mr. Djeric, right, because you

12     knew him before he became prime minister, because you hailed from the

13     same place?

14        A.   Yes.  We are, even now, on good terms.  We have always been.

15        Q.   During those two encounters with Mr. Djeric in May and June 1992,

16     did the prime minister complain to you about Minister Stanisic in any

17     way?

18        A.   No, he didn't explain about the minister, but there was a problem

19     with Momo.  And at one point in time, maybe later, he told me that it was

20     about -- that it was time for change.

21        Q.   When you say "Momo," you mean Momo Mandic, who was minister of

22     justice at the time; right?

23        A.   Yes.

24        Q.   Mr. Djeric didn't confide in you or inform you that he had a

25     problem with the minister who allegedly didn't inform him, so he wasn't

Page 16539

 1     aware of the security situation in the territory of the RS.  Did he

 2     mention any of that?

 3        A.   No, he didn't.  I didn't spend so much time with the prime

 4     minister.  We only discussed two or three matters.  It lasted half an

 5     hour only.

 6        Q.   You were assistant minister of the police.  And since you

 7     were - and even now - are friends with Mr. Djeric, certainly if he had

 8     had a problem with the police, he would have told you.  Or do you have a

 9     reason to doubt that?

10        A.   Well, I suppose he would have told me.

11        Q.   Let me show you document 1D98, which is an order by Mr. Djeric

12     dated 25 May 1992 sent to the MUP, to the attention of the

13     under-secretary for public security, Mr. Cedo Kljajic.

14             MR. ZECEVIC: [Microphone not activated] [Interpretation] 1D98.

15             THE INTERPRETER:  Microphone, please.

16             JUDGE HARHOFF:  Microphone.

17             MR. ZECEVIC: [Microphone not activated]

18             THE INTERPRETER:  Microphone, please.

19             JUDGE HARHOFF:  Still not on.

20             MR. ZECEVIC: [Interpretation] I apologise.

21             It's document 1D98.  And it is marked 1D00-0496.

22             The English document is the right one, but we also need the

23     Serbian version.

24             Could we please enlarge it.

25        Q.   This document is dated 25 May 1992.  I think it was signed by

Page 16540

 1     Mr. Trbojevic, who was vice or deputy prime minister; right?

 2        A.   Well, it would seem so, judging by what's written here.

 3        Q.   It was signed by Mr. Trbojevic, by -- who was deputy prime

 4     minister, on behalf of the prime minister, Mr. Djeric.  And here, the

 5     Ministry of the Interior is sent the decision of the cabinet, dated

 6     25 May, obliging them to collect information and submit a report about

 7     the safety of people and property.  And in the conclusion it says: With

 8     special regard to facts concerning vehicles from TAS Sarajevo, a car

 9     factory in Vogosca, all in Ilidza, et cetera.

10             Can you see that?

11        A.   Yes.

12        Q.   These are also matters that you discussed in your conversation

13     with Mr. Djeric; correct?

14        A.   Yes.

15             MR. ZECEVIC: [Interpretation] Could we show 1D62 to the witness.

16     The 65 ter number is 138.

17        Q.   I don't know if you are familiar with this document, sir.  It's

18     dated 26 May, which is the following day after the document we have just

19     seen, where government demands information from the ministry urgently.

20     And this document is dated 26 May, which is the following day.  And it

21     says:

22             "Since it is essential that we should urgently write a report for

23     the Government of the Serbian Republic of Bosnia and Herzegovina, you are

24     required to provide information about offences against people and

25     property in the territory of the Serbian Republic of Bosnia and

Page 16541

 1     Herzegovina."

 2             And then what follows are instructions as to how this should be

 3     done.

 4             And on page 2 --

 5             MR. ZECEVIC: [Interpretation] Could we please turn the page.

 6     Could we please see page 2 of the document.

 7        Q.   You see here, halfway through the page under the heading Roman V,

 8     describe especially serious offences.  The SJB of Vogosca is especially

 9     tasked to do that with regard to car theft; and the SJB of Ilidza with

10     regard to oil theft.

11             MR. ZECEVIC: [Interpretation] Could we please see page 3.

12        Q.   It says the deadline to submit the report is 31 May 1992.

13             MR. ZECEVIC: [Interpretation] Could we please see page 4 of the

14     English translation.  Let's stick to the page we see in Serbian.

15        Q.   And you see that this was signed on behalf of Mico Stanisic.  I

16     believe it says:  "For the minister."

17             And do you happen to know whose signature this is?

18        A.   I couldn't say.

19        Q.   Cedo Kljajic?

20        A.   That's possible, but I'm not sure.

21        Q.   Thank you very much.

22             So on the day after the request made by the cabinet, we see that

23     the ministry required the CSBs to submit relevant information to -- to

24     act upon the request of the government; correct?

25        A.   Yes.

Page 16542

 1        Q.   Among others, your administration, and you as its chief, sent two

 2     inspectors, Mr. Drago Borovcanin and Milomir Orasanin, to carry out an

 3     audit of the SJBs of Vogosca and Ilijas round about the 27th and 28th of

 4     May.  I suppose that it had to do with the request of the cabinet and the

 5     instruction of the minister.

 6        A.   As far as I remember, somebody informed me.  I arrived from

 7     Belgrade on the 27th, and this was already prepared.  I basically just

 8     approved it.  It wasn't a real audit, because that wasn't possible under

 9     the circumstances.  We just went there to see what things were like and

10     make an assessment what was in place and what wasn't.  The crime

11     department consisted of one man whose name was Stanko in Vogosca, and

12     that was all there was.

13        Q.   I'll show you P989, which is 65 ter 397.  Tab 89.

14             This is a report which was shown to you by Mr. Hannis.  On the

15     title page, it reads:

16             "Report on the work of the Vogosca and Ilijas SJBs."

17             It's dated 30 May.

18             MR. ZECEVIC: [Interpretation] Let's see page 2, please.

19             I called P989, which is 65 ter 397, page 2.  Could we see it,

20     please.  The English translation too.  Thank you.

21        Q.   It says here:

22             On the 27th and 28th of May, 1992, the Ministry Inspectors

23     Drago Borovcanin and Milomir Orasanin visited the Vogosca and Ilijas SJBs

24     and reviewed their work on that occasion.

25             It's very true, as you said, they went to see how these two SJBs

Page 16543

 1     worked, Vogosca and Ilijas; right?

 2        A.   Yes.  And I have a correction.  They were sent by Cedo.  Mico

 3     called me on the phone the following day.  He asked about some

 4     instructions, what he should do.  So Cedo Kljajic had sent them before I

 5     came back from --

 6        Q.   Cedo Kljajic was the under-secretary?

 7        A.   Yes.

 8        Q.   Under-secretary for public security, and he was authorised to

 9     send out your inspectors; right?

10        A.   Yes.  He was the only one who could do so for the police and the

11     crime service.  He was the only one apart from the minister who could do

12     so.

13        Q.   I would like to comment on the last paragraph.  And I follow up

14     upon what you said, that in Vogosca they only had one man in crime

15     enforcement.  And here it says -- or, rather, here we can see these

16     proposals made by your inspectors, that -- namely, that Zivko Lazarevic.

17     And he's the one person who worked on -- in crime enforcement in Vogosca;

18     right?

19        A.   Yes.

20        Q.   And it says here that the proposal was for Lazarevic, Zivko,

21     given his experience and knowledge of the area, be appointed chief;

22     whereas Branislav Vlaco, hereto inspector in the form Sarajevo CSB, be

23     appointed to duties and tasks of inspector for crime prevention.  Which

24     means that he was to be inspector for crime prevention in the

25     administration for crime prevention at the Vogosca SJB; right?  That was

Page 16544

 1     the proposal?

 2        A.   Yes.

 3        Q.   We will get back to Branislav Vlaco, but I first want to show you

 4     the following document.

 5             But just to conclude.  On the 25th of May, we saw the first

 6     document from the government, whereby the government issued instruction

 7     to the ministry to provide urgently some information.

 8             On the 26th of May, the ministry issued order to CSBs to provide

 9     such information.  And, at the same time, the ministry sent out, on the

10     27th and 28th of May, some people to review the work of some SJBs.  And

11     all of this happened within these three or four days; right?

12        A.   Yes, we can see based on the documents.

13        Q.   And this report was sent out on the 30th of May; whereas, we saw

14     that the final deadline for sending out the report, based on the decision

15     of the ministry, was the 31st of May; right?  Do you agree with that?

16        A.   Yes.

17        Q.   I will show you 1D106 now, which is 65 ter 1398.

18             This is a report dated the 12th of July, 1992.  This report was

19     prepared by the operative workers of the Romanija-Birac CSB who sent this

20     report to their chief, Zoran Cvijetic.  Do you see that?

21        A.   Yes.  They sent it to their chief and to the minister.

22        Q.   To the ministry, not the minister.

23        A.   Yes, yes.  You're quite right.  I apologise.

24        Q.   We will see subsequently it says, On the 3rd of July, 1992,

25     operatives of the Sarajevo CSB were sent by the chief of that CSB to the

Page 16545

 1     Vogosca SJB and that they were tasked with reviewing the crime situation

 2     in the territory of that municipality.

 3             And further on, on page 1, it says:

 4             "It was concluded that the crime service in Vogosca SJB did not

 5     exist, and special concern was expressed over cases of stealing new cars

 6     from the TAS Sarajevo car factory grounds from which 2300 cars had been

 7     stolen."

 8             This was discussed on Friday, this theft of cars from TAS.  Do

 9     you remember that?

10        A.   Yes.

11        Q.   And to put everything in context, your evidence was that you, on

12     the 2nd of June, went to a meeting in Vogosca, Ilidza, and Ilijas, and

13     that on that occasion you talked to the commander of the military unit

14     which secured the TAS car factory in Vogosca; right?

15        A.   No.  It wasn't me.  It's -- it was that his commander, the

16     brigade commander, communicated with him in my presence.

17        Q.   But if I understood you well, you talked to the commander of the

18     brigade and that during the conversation, and as you urged him to improve

19     the security of the factory, the commander of the unit came to him,

20     telling him that precisely on that day somebody had removed, without

21     authorisation, 20 vehicles and that he was unable to do anything about

22     it.

23        A.   Yes, that's true.  He went back to Skipina.  And this was while

24     the meeting was under way between the people I mentioned.

25        Q.   Yes, precisely.  And I mention it because it's quite an unusual

Page 16546

 1     incident.

 2             MR. ZECEVIC: [Interpretation] Could we now see page 2 of the

 3     document.

 4        Q.   Just a comment.  It is clear that on the 27th and 28th of May

 5     your people went there.  You went there on the 2nd of June.  But despite

 6     the proposals and suggestions and review of the situation, it is obvious

 7     that in early July the situation was not significantly different at the

 8     Vogosca SJB; right?

 9        A.   Right.

10        Q.   This report will tell us why that was the case.

11             On this page, we'll see that these two operatives of the CSB

12     explain what kind of problems they encountered upon arriving there:

13     namely, that the chief had gone to Serbia; that they were unable to go

14     into the office because, allegedly, the escort of the chief who had the

15     keys to the office had also gone to Serbia; and to put it short, their

16     work at the Vogosca SJB was obstructed.

17             This is what we can derive from this report; right?

18        A.   I'm not sure I have the right document on my screen.  Page 2;

19     right?

20        Q.   Yes, yes.

21        A.   I didn't quite follow, but that's it.

22        Q.   It says here that on the following day, upon arriving at the

23     Vogosca SJB, we learned that the chief had gone to Serbia and would come

24     back in two or three days.  And then it says: Following this, we talked

25     to the commander of the station, asking him to unlock two offices of the

Page 16547

 1     crime department, to which he said that the keys were with a certain

 2     Radenko who had gone to Serbia together with the chief.

 3        A.   Yes, yes.  That's right.

 4        Q.   The penultimate sentence reads that it was agreed that a crime

 5     service was to be established comprising Vlaco, Brano, as head of the

 6     service, hereto worker of the service and CSB Sarajevo.  And this is the

 7     same Brano Vlaco who, in the previous document, was proposed by your

 8     inspectors; right?

 9        A.   Yes.

10             MR. ZECEVIC: [Interpretation] And could we see the last page of

11     this document, please.

12        Q.   Based on this, we can see what were the reasons for such a

13     situation at Vogosca.

14             Finally, on the 9th of July, they managed to have a meeting with

15     the chief, and they say that they expressed grave criticism concerning

16     the centre and the work of municipal authorities.  And then in the last

17     two sentences they say, in addition to this, at the meeting, the opinion

18     was expressed that the personnel policy at the Vogosca SJB can be

19     formulated only by the chief of the SJB and his staff and that nobody

20     from MUP and the municipality could appoint people in his institution.

21             And then it was said at the meeting that they, the workers who

22     came to inspect, were non- -- not wanted and not needed and that they

23     should have come before.

24             It is hard to comprehend this attitude, isn't it?  But it is also

25     good illustration of the situation as it was at the time; right?

Page 16548

 1        A.   There were very many such examples.  What is curious is that

 2     wherever there were combat activities going on, the situation was always

 3     like this.  First of all, they did not have enough staff; and, in

 4     addition to that, they also had people with weapons imposing their will.

 5        Q.   And following all that, due to these combat activities and the

 6     situation that a particular municipality encountered, you objectively

 7     were unable to do anything about it.

 8        A.   Yes, that's true.  And this is why in one of the documents they

 9     stated that all traces need to be documented regardless of what happened

10     and where it happened so that people could be prosecuted eventually.

11     Because we were quite aware that in such radical situations it was

12     impossible to do anything until everything was properly documented, let

13     alone in combat situations.  So this is why they said in that document

14     that they should make every effort to record and document evidence and

15     that when the conditions were ripe, something would be done about it.

16        Q.   We will get to that document too.

17             But, here, we can see that the chief of the SJB directly said to

18     the inspectors from the superior CSB that they were unwanted there,

19     underlying that personnel policy within the Vogosca SJB would not be

20     directed either by the superior CSB or the MUP.

21             When I asked you whether this was one of the typical features of

22     the condition, you said yes.  Is it because you had in mind examples of

23     such arbitrary behaviour by certain chiefs of SJBs?

24        A.   Yes, precisely so.

25        Q.   And given -- or, rather, if there were combat operations in a

Page 16549

 1     particular municipality, then, naturally, there were many armed

 2     individuals there, belonging either to the TO, or paramilitaries, or the

 3     Army of Republika Srpska; right?

 4        A.   Precisely so.  People were trying to defend the positions, to

 5     maintain the lines.

 6        Q.   And you will agree with me, Mr. Planojevic, won't you, if -- or

 7     when -- if you wanted to use your powers, you from the MUP, you could

 8     have come into a situation where you would be criticised for undermining

 9     the combat powers of the military in a certain territory; right?

10        A.   Yes.  Especially in that area down there.  You did not dare do

11     anything because people didn't have enough men for combat and they were

12     happy to get anybody they could, and commanders used anybody they could.

13     And this is why things happened that should not have been allowed to

14     happen.

15        Q.   Now that we have touched upon Brano Vlaco, when asked by my

16     learned friend Mr. Hannis, you explained how they -- there were two

17     individuals with the same first and last name.  Do you remember that?

18     One of them was inspector for corporate crime at the town SUP of Sarajevo

19     before the war; right?

20        A.   Yes.

21        Q.   If I remember your comment well, this was a man with a moustache;

22     right?

23        A.   Yes.  That's true to this day.

24        Q.   That Brano Vlaco went to Vogosca, and that is precisely this

25     Brano Vlaco mentioned in these two documents as a man nominated to work

Page 16550

 1     in the department for crime suppression in Vogosca; right?

 2        A.   Yes.  They nominated him because he lived in Vogosca.

 3        Q.   What is important with -- for me, however, is that the two

 4     documents that we just saw - 1D106, which was the report dated

 5     12th of July, report of the CSB, and P989, which is the report of your

 6     inspectors, dated the 30th of May - in both of these documents, they

 7     nominate inspectors, or operatives.  Or, rather, the operatives nominate

 8     Brano Vlaco as inspector of the administration for crime suppression.

 9             Does this refer to this particular Brano Vlaco, with a moustache,

10     who was inspector for corporate crime at the town SUP of Sarajevo before

11     the war?

12        A.   Exactly him, precisely him.

13        Q.   And this Brano Vlaco, after a certain time, probably having

14     gotten acquainted with the situation in Vogosca, packed his bags and set

15     off for Bijeljina.  Do you know that?

16        A.   I'm not sure.  But I believe that for a short while he worked at

17     the SDK of Vogosca municipality, while the clearance system was still

18     functioning.  He worked there for a short while and then he left.

19        Q.   But at any rate, he left the Vogosca SJB, worked for a while for

20     the SDK, and after a short period, he went to Bijeljina; right?

21        A.   Yes.

22        Q.   And that man now lives in Bijeljina and is a bank manager there;

23     right?  Brano Vlaco.

24        A.   He's the manager of the Raiffeisen Bank in Bijeljina.

25        Q.   Yes, Raiffeisen Bank.

Page 16551

 1             The other Brano Vlaco, whom you also know, was a member of the

 2     special unit of the MUP of the Socialist Republic of Bosnia-Herzegovina

 3     before the war; right?

 4        A.   Yes.

 5        Q.   And you saw him on 8 June 1992 at Kalovita Brda.

 6        A.   Correct.

 7        Q.   You didn't see him from 1 April through 8 June, or did you?

 8        A.   I don't remember seeing him then.

 9        Q.   When you saw him on 8 June - and you remember the

10     8th of June because of the large-scale Muslim offensive - he said to you

11     that somebody -- he had an appointment with somebody -- rather, a job

12     interview, to be employed by the MUP of the RS; right?

13        A.   Yes.

14        Q.   But after some 20 to 30 minutes, according to you, there was a

15     phone call made to Kalovita Brda that the Muslims had attacked Vogosca,

16     and he jumped in his car and set off for Vogosca; is that correct?

17        A.   Precisely.

18        Q.   And, basically, you know that on that day he didn't go to that

19     job interview; right?

20        A.   No.  He returned.  And the minister didn't come on that day.

21     Because I spent most of the day at Kalovita Brda.  I didn't see him there

22     at all.

23        Q.   After the 8th of June, you never saw this second Brano Vlaco

24     again, the one we have just talked about?  I mean in 1992.

25        A.   Well, I saw him after the war, but not before that.

Page 16552

 1        Q.   And you don't know what happened to him after the 8th of June, do

 2     you?

 3        A.   No.  I believe that the Prosecutor told me -- or, rather, he

 4     asked me whether he became commander at Vogosca in late 1992.  So he

 5     said.

 6        Q.   I'll show you document 1D339; 65 ter 1435.

 7             Mr. Planojevic, you told me that the Prosecutor asked you about

 8     Brano Vlaco and his appointment in November when he became commander, or

 9     something, at the Vogosca SJB.

10             Did the OTP, during the proofing, show you this document, dated

11     21 July 1992?

12        A.   No, not one document was shown.

13        Q.   I don't know if you can make it out.  This is document of the

14     Ministry of Justice.  I believe you can read that.  It is marked 01-131,

15     Sarajevo, 21 July 1992.  And it says:  "Decision."

16             I don't know whether can you read that.

17        A.   I can read that, as well as the name.

18        Q.   Brano Vlaco from Vogosca shall be appointed warden of the

19     detention department of the penal and correctional facility Butmir at

20     Ilidza, located in Vogosca.

21             And the last sentence:

22             "This ruling shall enter into force on the day of its passing and

23     shall apply from 14 July 1992."

24             And on behalf of the Ministry of Justice, Mr. Avlijas signed the

25     decision.

Page 16553

 1             I suppose you haven't seen this document before.

 2        A.   I see it for the first time.

 3        Q.   Do you know that this Brano Vlaco, in July, was appointed

 4     warden -- prison warden by the Ministry of Justice of the RS?

 5        A.   I can only see it now.  I didn't know it before.

 6        Q.   Thank you.  Sir, we have about a quarter hour left, and I'll

 7     introduce another topic.

 8             You may remember that an hour, an hour and a half ago we

 9     discussed the role of the ministry as a body giving out instructions.

10     And there were work instructions, suggestions, and we mentioned that

11     the -- the controlling role of the ministry.  So tell me whether the MUP

12     of the RS ever issued any instruction known to you, as assistant

13     minister, about discrimination of non-Serbs in the activities of the

14     police?

15        A.   No, I haven't seen anything like that or heard of its existence.

16     And if I had, I certainly would have reacted.

17        Q.   Do you know that there was an attitude, without a written order

18     or official instructions, and was there an overall attitude of

19     discrimination of non-Serbs in the MUP of the RS while you were there?

20        A.   If you are referring to the executive officials of the

21     ministries, then my answer is:  No, absolutely not, as far as I can tell

22     from my contacts that I had at the time.

23        Q.   Well, I'm asking you about the contacts that you may have had

24     with regard to the fact that you were assistant minister and, later, you

25     worked in the National Security Service.

Page 16554

 1        A.   Absolutely.  There were no such documents or deeds or behaviour.

 2             JUDGE HARHOFF:  Mr. Zecevic.

 3             MR. ZECEVIC:  Yes.

 4             JUDGE HARHOFF:  It comes as no surprise, I would imagine, that

 5     there would be no written instructions from the top of the ministry to

 6     discriminate non-Serbs.  So your next question to the witness, when he

 7     had confirmed that no such instructions were known to him, was whether he

 8     was aware of any attitude that would favour discrimination, and

 9     Mr. Planojevic answered that no such attitude existed in the executive

10     level, as far as he was aware.

11             So that begs the question whether the witness - you,

12     Mr. Planojevic - were aware if any such attitude existed at lower levels

13     of the MUP organisation.  Can you help us out here?

14             THE WITNESS: [Interpretation] It's difficult for me to answer

15     that question.  I didn't have that many contacts.  Most of my contacts

16     were indirect.

17             If you consider the times, I had no time to contact anybody

18     than -- other than my closest co-workers.

19             JUDGE HARHOFF:  Thanks.

20             MR. ZECEVIC: [Interpretation]

21        Q.   It's a fact, isn't it ...

22                           [Trial Chamber and Registrar confer]

23             MR. ZECEVIC: [Interpretation]

24        Q.   It is a fact, isn't it, that while you were assistant minister of

25     the interior of the RS all instructions from the ministry to the CSBs in

Page 16555

 1     the territory of the RS, and consequently to the local SJBs, insisted on,

 2     above all, obeying the law and act -- the police acting in accordance

 3     with laws and regulations; correct?

 4        A.   Yes.

 5        Q.   And there were many such orders; right?

 6        A.   Well, considering all the circumstances, yes.

 7                           [Trial Chamber and Registrar confer]

 8        Q.   Well, that's exactly what I want to ask you, about the reason of

 9     repeatedly issuing orders and stressing duties that clearly stem from the

10     law.

11             Isn't it true that due to the objective situation and the war,

12     the Ministry of Interior, to make sure that it gets through to the lowest

13     level - the SJBs - repeatedly sent out orders with basically the same

14     contents?

15        A.   Yes, that's -- that's true.  But you had to be flexible.  When I

16     say "flexible," I mean that you had to balance things.  Whether it was

17     justified to, say, sacrifice a village, or not insist on things, and I've

18     already explained the conditions under which we worked.

19        Q.   I understand you fully.  But that -- that's why one of your

20     instructions said that all cases must be documented.  But we'll get there

21     yet.

22             Apart from the inspectors who were sent out by Cedo Kljajic in

23     late May 1992 to Vogosca and Ilijas, the inspectors of the MUP were also

24     sent to other places in the RS whenever they were able to make it to some

25     CSBs or SJBs; right?

Page 16556

 1        A.   Yes.

 2        Q.   I'll show you some documents.

 3             MR. ZECEVIC: [Interpretation] Could we please see 1D00-0513.

 4             JUDGE HALL: [Previous translation continues] ... you said some

 5     documents.  It's two minutes before we rise for the evening.  Is it

 6     possible to finish these, quote/unquote, documents within that time?

 7             MR. ZECEVIC:  No, definitely not.  But one I can, if I may,

 8     Your Honours.

 9             JUDGE HALL:  Yes.

10             MR. ZECEVIC:  Thank you very much.

11             [Interpretation] 1D0513.

12        Q.   Sir, I'll remind you:  Danilo Vukovic was a crime inspector of

13     the MUP of the RS; right?

14        A.   Yes.

15        Q.   And he was in your administration; right?

16        A.   Correct.

17        Q.   This is a document dated 24 June 1992, I believe, and it

18     authorises Danilo Vukovic to engage in some activity in the territory of

19     the Bijeljina CSB, the Bijeljina SJB, and, well, in the east of the RS;

20     and he coordinates and directs the work of the crime investigation

21     services there.  Can you see that?

22        A.   Yes.

23        Q.   I believe the signature is that of Mr. Njegus, correct, or that

24     of Cedo Kljajic?

25        A.   I think it's Kljajic's.  But it -- maybe it's Radomir's, after

Page 16557

 1     all; I'm not sure.

 2        Q.   But, at any rate, you know that Danilo Vukovic, in June, had the

 3     authority to visit the CSB of Bijeljina and some CSBs in the east of the

 4     RS.

 5        A.   That is correct.

 6             MR. ZECEVIC: [Interpretation] Unless there's opposition, I seek

 7     to tender this document into evidence.

 8             MR. HANNIS:  No objection.

 9             JUDGE HALL:  Admitted and marked.

10             THE REGISTRAR:  As Exhibit 1D391, Your Honours.

11             MR. ZECEVIC: [Interpretation]

12        Q.   Thank you, Mr. Planojevic.  We will continue tomorrow.

13             MR. ZECEVIC:  I believe it's proper time to adjourn.

14             JUDGE HALL:  Thank you.  So we --

15             THE WITNESS: [Interpretation] Excuse me, may I ask a question?

16             JUDGE HALL: [Previous translation continues] ... yes, sir.

17             THE WITNESS: [Interpretation] I would just like to know whether I

18     will be free tomorrow, so I can plan my activities.  Will we finish

19     tomorrow?

20             MR. ZECEVIC:  Well, Your Honours, I believe I will be able to

21     finish, I don't know, one session, maybe a bit longer than one session.

22             JUDGE HALL:  I'd inquired of the Court Officer as to how much

23     time had you left, and I was calculating, and I -- from what he had said

24     in terms of what you had left, I was thinking we might not finish this

25     witness tomorrow, but I'm anxious -- I'm glad to learn that you are alive

Page 16558

 1     to this and that, to answer the witness's question, it seems as if we are

 2     headed in that direction.

 3             Mr. Krgovic, we had had an hour and a half for you.  Is that

 4     still the position?

 5             MR. KRGOVIC:  Your Honours, I don't think that we have any cross

 6     for this witness.

 7             JUDGE HALL: [Microphone not activated] ... so, Mr. Planojevic, to

 8     answer your question, it appears that we, more likely than not, would be

 9     completed your testimony tomorrow.  Yes.

10             I believe we are in Courtroom II tomorrow.  Yes.  So 9.00

11     tomorrow morning.

12             THE WITNESS: [No interpretation]

13                           [The witness stands down]

14                            --- Whereupon the hearing adjourned at 7.02 p.m.,

15                           to be reconvened on Friday, the 29th day of

16                           October, 2010, at 9.00 a.m.