Tribunal Criminal Tribunal for the Former Yugoslavia

Page 19407

 1                           Tuesday, 12 April 2011

 2                           [Open session]

 3                           [The accused entered court]

 4                           --- Upon commencing at 9.03 a.m.

 5             THE REGISTRAR:  Good morning, Your Honours.  Good morning to

 6     everyone in and around the courtroom.

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

 8     Stojan Zupljanin.

 9             JUDGE HALL:  Thank you, Madam Registrar.

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

11             MS. KORNER:  Good morning, Your Honours.  Joanna Korner,

12     Alex Demirdjian, and Crispian Smith for the Prosecution.

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

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

15     Ms. Deirdre Montgomery appearing for the Stanisic Defence this morning.

16     Thank you.

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

18     Aleksandar Aleksic appearing for Zupljanin Defence.

19             JUDGE HALL:  Thank you.

20             And if there are no housekeeping or similar matters, could the

21     Usher please escort the witness to the stand.

22             MR. ZECEVIC:  Your Honours, just one thing, if I may, before the

23     witness is -- while the witness is ushered in.

24             I failed to announce and I -- and I found out only right now, I

25     failed to announce two documents which I would like to use at the

Page 19408

 1     beginning.  Those are the charts prepared by the Office of the

 2     Prosecutor.  The structure of the MUP, and the -- and the map of Bosnia

 3     and Herzegovina.

 4             I don't know if there would be any opposition to --

 5             MS. KORNER:  No opposition, Your Honour, except I haven't got

 6     them here.  All right.  We can arrange for someone to bring them down.

 7             MR. ZECEVIC:  Well, I can borrow you mine.

 8             MS. KORNER:  Or even lend it to me.

 9             MR. ZECEVIC:  Lend it, yes.  Thank you.  And I'm really sorry for

10     this.

11             JUDGE HALL:  Could somebody remind me as to what the status is?

12     Were they merely working documents or were they exhibits?

13             MS. KORNER:  No, they're admitted as exhibits, Your Honours.

14             JUDGE HALL:  Thanks.

15                           [The witness entered court]

16             JUDGE HALL:  Good morning to you, sir.  Would you please make the

17     solemn declaration from the card the Usher is now handing to you.

18             THE WITNESS: [Interpretation] Good morning.  I solemnly declare

19     that I will speak the truth, the whole truth, and nothing but the truth.

20             JUDGE HALL:  Thank you.  You may be seated.

21             THE WITNESS: [Interpretation] Thank you.

22             JUDGE HALL:  From your responses to this point, I assume that you

23     are hearing me in a language that you understand?

24             THE WITNESS: [Interpretation] Yes.

25             JUDGE HALL:  Would you tell us your name, please.

Page 19409

 1             THE WITNESS: [Interpretation] Andrija Bjelosevic.

 2             JUDGE HALL:  Well, I will leave it to counsel at whose instance

 3     you are being called to lead you on evidence about particulars about

 4     yourself and your qualifications.  I would, however, first of all,

 5     welcome you to this Tribunal and thank you for coming to give evidence.

 6             Have you testified previously before this Tribunal or before any

 7     of the courts in any of the countries that comprise the former

 8     Yugoslavia?

 9             THE WITNESS: [Interpretation] No, not in these cases.

10             JUDGE HALL:  Thank you.  You have been called by counsel for the

11     accused Stanisic, and counsel would begin -- the procedure is that

12     counsel -- the side -- counsel for the side calling you would begin by

13     asking you questions following which the side opposite -- well, following

14     which the side for the co-accused would have an opportunity to

15     cross-examine you.  Followed by counsel for the Prosecution, the side

16     opposite.

17             Counsel calling you would then have a right to re-examine you on

18     matters that would have arisen out of cross-examination, and usually, at

19     that stage but indeed at any stage the members of the Bench may put

20     questions to you.

21             It is estimated by counsel for the accused Stanisic that you will

22     be on the witness-stand for a total of 20 hours.  Counsel for the

23     Prosecution has indicated that their cross-examination is likely to take

24     the same period of time.  Counsel for the co-accused, Mr. Zupljanin, have

25     indicated that they would not be nearly as long with you, but all told,

Page 19410

 1     it will mean that you are expected to be before the Tribunal giving

 2     evidence for the remainder of this week and indeed for the next three

 3     weeks, according -- if I recall the schedule correctly.  But from what I

 4     would have indicated in terms of the numbers of hours, you would have an

 5     idea as to how long your testimony is likely to take.

 6             You needn't be alarmed that you would be on the stand for

 7     20 hours continuously.  For technical reasons, the Tribunal's work is

 8     broken up into sessions of approximately 90 minutes and there are two

 9     reasons for this.  One is the technical reason that the tapes that

10     memorialise and record the proceedings have to be changed at

11     approximately 90-minute intervals, and the secondary reason is that that

12     allows for the comfort and convenience of witnesses, counsel, and

13     everyone to take a break and then come back.

14             Now, notwithstanding those set times that I have indicated, if,

15     at any point in your testimony there is any reason that you would need to

16     take a break, please indicate that to us, either directly or through your

17     counsel, and it is something that we would, of course, accommodate.

18             And unless you have any questions with which I may assist, I

19     would invite counsel for Mr. Stanisic to begin their

20     examination-in-chief.

21             MR. ZECEVIC:  May I, Your Honours.

22             JUDGE HALL:  Yes.

23             MR. ZECEVIC:  Thank you.

24                           WITNESS:  ANDRIJA BJELOSEVIC

25                           [Witness answered through interpreter]

Page 19411

 1                           Examination by Mr. Zecevic:

 2        Q.   [Interpretation] Good morning, Mr. Bjelosevic.

 3        A.   Good morning.

 4        Q.   Mr. Bjelosevic, please tell us briefly something about yourself.

 5     Where you were born, what schools you graduated from and so on.

 6        A.   I was born in Derventa, and I have a degree in national defence

 7     from Belgrade university.  And in early 1990, I worked in -- in the

 8     1980s, I started working in secondary schools.  Thereupon I went to work

 9     for the Secretariat for National Defence, and then, as of 1991, I started

10     working for the MUP, and that's where I work to this day.

11        Q.   Mr. Bjelosevic, let me explain one matter to you.  Since what you

12     are saying is being interpreted, please speak slowly so that the

13     interpreters have ample time to catch up with you?

14             Tell us, please, the year of your birth and the place where you

15     graduated from secondary and other schools?

16        A.   I was born in 1954.  I completed my primary education in my

17     native town, and the secondary school in Derventa.

18        Q.   If I understood you correctly, you graduated from the Faculty of

19     National Defence in Belgrade; is that right?

20        A.   Yes.

21        Q.   You also told us that upon your graduation, you worked in a

22     secondary school and then in the Secretariat for National Defence; is

23     that right?

24        A.   Yes.  In Derventa.

25        Q.   Please explain for us, what were the activities of the

Page 19412

 1     Secretariat for National Defence at the time?

 2        A.   The Secretariat for National Defence was structured, let me

 3     organise the hierarchy.  There was the Federal Secretariat for National

 4     Defence which covered the whole of Yugoslavia.  Then the Republican

 5     Secretariat for National Defence in each of the republics.  And then at

 6     municipal level, there were Municipal Secretariats for National Defence

 7     which dealt with the recruitment and assignment of recruits to the JNA,

 8     the manning of JNA units and Territorial Defence units, the organisation

 9     of defence activities for all the other sectors of society at

10     municipality level, mobilisation schedules for all the various

11     structures, civilian protection, and engaged in certain forms of training

12     in these particular areas.

13        Q.   Tell me, the military records of conscripts were kept where

14     exactly; and did they have anything to do with the secretariats for

15     national defence?

16        A.   Yes, it was precisely there that all the military records were

17     kept at a certain territorial organisation unit, and it was there that at

18     the request of certain wartime units and other authorities which dealt

19     with the organisation of wartime matters that individuals were recruited.

20     This was also the place where mobilisation was worked out, the way in

21     which was to proceed, and it was already carried out, both the

22     mobilisation of personnel and of assets, as well as of members of the

23     civilian protection and all the other individuals who had specific

24     wartime assignments.

25             Furthermore, there were also emergency plans.  All those were

Page 19413

 1     developed according to a uniform methodology that was prescribed by the

 2     Law on National Defence and a number of bylaws.  They were to provide

 3     guide-lines and instructions, and similar.

 4        Q.   Can we please describe it quite plastically for Their Honours the

 5     issue of recruitment and how it worked.  Were all conscripts, let's say,

 6     males of military age in a given, let's say, municipality, were they all

 7     listed as recruits; and at what point in their life would this be?

 8        A.   Well, these were males, as you yourself said, who, as they turned

 9     18, would be listed in the military records and referred to recruitment

10     commissions where they would undergo physical and psychological

11     examinations to determine their fitness for military service.

12             This was a sort of screening process, the aim of which was

13     precisely to determine who, among those conscripts, was fit to do

14     military service, and those who were declared unfit would be listed in

15     special records, as precisely such individuals.  The remainder who were

16     deemed fit for military service --

17             JUDGE HARHOFF:  Excuse me.  There is one little thing which is

18     not quite clear to me, Mr. Bjelosevic.

19             Counsel Zecevic asked you whether the military records of the

20     conscripts were kept where exactly and did they have to do anything with

21     Secretariat for National Defence, and then your answer was, as it was

22     recorded, that:

23             "... it was precisely there that all the military records were

24     kept ..."

25             And my question is simply, was that at the federal level in

Page 19414

 1     Belgrade or were these records kept regionally in the various departments

 2     of the secretariat?

 3             Do you understand my question?

 4             THE WITNESS: [Interpretation] Yes.  And that's precisely what I

 5     was about to talk about in my answer.

 6             I said that there was this screening process which took place,

 7     and once these individuals were listed in military records and these

 8     military records were kept at the level of Municipal Secretariat for --

 9     Secretariats for National Defence, which, through the structure of

10     Military Districts were sent on to the Republican Secretariats for

11     National Defence and the Federal Secretariat for National Defence.

12             Next, in keeping with the wartime and peacetime plans for various

13     units, a plan of war -- or, rather, a plan of assignments or posting of

14     these various recruits to the JNA would be made, and this plan, from the

15     Federal Secretariat for National Defence, via the Republican Secretariats

16     and Military Districts would be delivered to the various Municipal

17     Secretariats for National Defence, and they would be the ones who would

18     physically dispatch recruits to the destinations as determined by the

19     structures higher up.

20             JUDGE HARHOFF:  Thank you very much.

21             Back to you, Mr. Zecevic.

22             MR. ZECEVIC:  Thank you, Your Honour.

23        Q.   [Interpretation] Mr. Bjelosevic, once the recruits completed

24     their training in the Yugoslavia People's Army, they would, on their

25     return, I assume, report again to the Secretariat for National Defence

Page 19415

 1     when they would be assigned to the reserve force; is that right?

 2        A.   Their individual and unit files would be sent from the area where

 3     they served to their, let's call it home Secretariat for National

 4     Defence, and into these files it would be entered that they had completed

 5     their compulsory military service, their speciality and specific skills

 6     would also be listed in their files, and it was on that basis, and on the

 7     basis of the requirements in the army, their wartime assignments would be

 8     made.  They would be assigned to either units or other structures, such

 9     as the police, territorial units, that's to say, units of the

10     Territorial Defence, or units of the civilian protection.  Alternatively,

11     it could have been a wartime assignment to a certain company or

12     institution.  It all depended on the person's qualifications and

13     knowledge.

14        Q.   Therefore, the Municipal Secretariat for National Defence would

15     be the body which, if I understand you correctly, made specific

16     assignments for individuals who had completed their compulsory military

17     service.  Is my understanding correct?

18        A.   Yes.

19        Q.   And based on their files and skills acquired during their

20     training in the Yugoslav People's Army, they would be assigned to the

21     police reserve force, among others.

22        A.   Yes.  As I said, it is based on that that they would be assigned

23     to various structures, including the police reserve force, depending on

24     the number of police stations available and a number of other factors.

25        Q.   In practical terms, would the files of these individuals in that

Page 19416

 1     case be transferred to the Ministry of Interior or, as they were called,

 2     the secretariats of the interior?

 3        A.   No.  The master copy of their file would be kept with the

 4     Municipal Secretariat for National Defence.  So the individual's file

 5     would be kept by the secretariat, whereas the file for the entire unit

 6     would be sent to the structure receiving the individual under this

 7     assignment.

 8        Q.   So the master copies of these files were always kept with the

 9     Secretariat for National Defence in the territory of the municipality

10     where the individual resided; is that right?

11        A.   Yes.

12        Q.   Thank you.

13             JUDGE DELVOIE:  Mr. Bjelosevic, if I understand you well, the

14     assignments after the person has finished his -- his military service,

15     his normal military service, the assignments after that, are only wartime

16     assignments; is that correct?

17             So you were, for instance, in the -- in the reserve police only

18     for wartime.  You wouldn't be bothered by it in peacetime.  Is that -- do

19     I understand that correctly?

20             THE WITNESS: [Interpretation] That was wartime deployment, and

21     stations of the so-called military police were established thereby.

22             However, that composition was occasionally summoned primarily for

23     further training and, secondly, in case of some exceptional circumstances

24     or ...

25             JUDGE DELVOIE:  Thank you.

Page 19417

 1             MR. ZECEVIC:

 2        Q.   [Interpretation] Mr. Bjelosevic, you've told us that at the

 3     Secretariat for National Defence you spent seven or nine years working

 4     there.

 5        A.   Seven years.

 6        Q.   After that, you joined the MUP of the Socialist Federative

 7     Republic of Bosnia and Herzegovina, right?

 8        A.   Yes.

 9             MR. ZECEVIC:  Your Honours, we have prepared a binder of

10     documents to facilitate the -- for the witness so he can look at the

11     whole document once it is shown to him so if -- if Usher can ...

12        Q.   [Interpretation] Mr. Bjelosevic, you started working at the

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

14     Herzegovina when exactly?

15        A.   I believe that that was in early May or perhaps the end of

16     April 1991.

17        Q.   Did you apply for a job?  Was there a vacancy announced?  How did

18     you get the job?

19        A.   The procedure that was in place for such appointments was a bit

20     complicated, I would say.  And I mean by that that there were supposed to

21     be at least -- at least -- at least three candidates, or, rather,

22     proposals for at least three candidates had to be submitted.  After that,

23     all the applicants were invited to undergo a physical examination, or,

24     rather, their physical and mental abilities were tested.  After the

25     results came out, one of the three or more candidates were selected for

Page 19418

 1     the job in question.

 2             One of the conditions that a candidate had to meet was for the

 3     political parties that formed a coalition at that time endorsed the

 4     appointment of any such candidate.  And those arrangements were usually

 5     made between the personnel commission of the MUP and a representative of

 6     the party.

 7        Q.   Mr. Bjelosevic, was there also security check for each candidate?

 8        A.   Yes, absolutely.  That was a must.

 9             Let me just digress a little and tell you that if somebody was

10     deployed into the police, they would be vetted.  And for management

11     staff, there were very detailed security checks.  And, of course, that

12     included checking references from a previous time.

13        Q.   When you said, on page 12, point 1, that if somebody was

14     transferred to the police force, you meant your job in the Secretariat

15     for National Defence, and you meant when somebody was transferred to the

16     police reserve, even then, there had to be security checks for such

17     people, right?

18        A.   Yes.  This is precisely what I meant.

19        Q.   Mr. Bjelosevic, in late April or early May, you became the chief

20     of the Security Services Centre of Doboj, right?

21        A.   Yes.

22        Q.   I'm now going to show you a document.

23             MR. ZECEVIC: [Interpretation] Could we please call it up in

24     e-court.  It's 65 ter -- the Prosecutor's 65 ter 10137, paragraph 3, or

25     item 3, which is a map of Bosnia and Herzegovina.

Page 19419

 1             65 ter 10137.3, which is a map of Bosnia and Herzegovina.

 2             I apologise, this is not the map that I had in mind.  Strike

 3     that.  I don't need this document.  The number must have been wrong or --

 4     obviously.

 5        Q.   Sir, in terms of the position of Doboj municipality, could you

 6     please provide us some detail about its geographical position, its

 7     placement in Bosnia and Herzegovina.

 8        A.   Doboj is in the northern or central northern part of Bosnia and

 9     Herzegovina on the axis from Sarajevo to Slavonski Brod, on the river

10     Bosna.

11        Q.   Sir, could you please tell us how many municipal secretariats or

12     public security stations at the moment when you were appointed the chief

13     of the Security Services Centre in Doboj were there, and could you tell

14     us which stations those were.

15        A.   Under the Doboj centre, there were the following.

16        Q.   Could you please do it slowly.

17        A.   The public security station Brod; Derventa; Odzak; Samac;

18     Modrica; Doboj; Tesanj; Teslic; and Maglaj.

19        Q.   So if I understood you properly, there were nine public security

20     stations within the framework of the Security Services Centre of Doboj.

21        A.   Yes, that was the case in 1991.

22        Q.   At that time, in 1991, who were the persons that were chiefs of

23     those public security stations?  Can you give us their names?  Who were

24     there in 1991?  Who was appointed in 1991?  Could you please do it slowly

25     again.  It is rather difficult to record the names.

Page 19420

 1        A.   It was a long time ago, but I'll try and remember all of their

 2     names.

 3             In the Brod station, the person in charge was Slavko Pranjic.

 4     Later on, there was a shake-up, and he was replaced by Zvonko Nedanovic,

 5     I believe.

 6             In Odzak, it was Stjepan Mikic.

 7             In Samac, Vinko Dragicevic.

 8             In Modrica, the person's last name was Ibel and I'm not sure

 9     about his first name.  I think it was Zvonko.

10             In Doboj, Obren Petrovic.

11             In Derventa, I found Novak Novic there, but he was soon removed

12     and replaced by Ivan Duspara.

13             In Maglaj, Osman Rahmanovic.  I believe that that was the

14     person's name.

15             In Tesanj, Semsudin Mehmedovic.

16             And in Teslic, Dusan Ismanovic [as interpreted].

17             I believe that I gave you all of their names correctly.

18        Q.   Thank you.  Just for the transcript, Obren Petrovic, page 14,

19     line 1, he was chief of the police station in Doboj, right?

20        A.   Yes.

21        Q.   And in Tesanj, the person's name was Semsudin Mehmedovic, right?

22        A.   Yes.

23        Q.   And in Teslic, 14, 5, the person's name is Dusan Kuzmanovic.

24             Sir, let's look at a document at tab 1; 752, document D1.

25             65 ter 00752D1.  That's a Defence 65 ter, tab number 1.

Page 19421

 1        A.   Yes, I can see the document.

 2        Q.   Can you please describe the document for us.  Just briefly.  What

 3     is it?

 4        A.   This is the regulation on internal organisation and the list of

 5     positions in the Secretariat of the Interior, as it was still known, in

 6     1990.  That regulation was in force in 1991 when I joined as the chief of

 7     the Security Services Centre.

 8        Q.   In other words, that was the regulation on the internal

 9     organisation of the republican SUP of the Socialist Republic of

10     Bosnia-Herzegovina which was still valid, and it was still in effect at

11     the time when you were appointed the chief of the Security Services

12     Centre in Doboj, right?

13        A.   Yes.  And this document also provides a description of the entire

14     structure.  For example, on page 59 you can see it.  You see what the

15     centre is made up of, what elements went into it, and it also gives you

16     job descriptions of each of the organisational elements.

17             MR. ZECEVIC: [Interpretation] Can we please look at page 2?  This

18     the page that the gentleman was referring to.  I'm interested in

19     Article 59 on the following page of the same document.

20             JUDGE DELVOIE:  Mr. Zecevic.

21             MR. ZECEVIC:  Yeah.

22             JUDGE DELVOIE:  Is this -- what strikes me in the first page is

23     that it is a proposal.  It is said to be a proposal.

24             MR. ZECEVIC:  Yes.

25             JUDGE DELVOIE:  So shouldn't we have the final text of it?  I

Page 19422

 1     mean, is this the final text?  How do we know?  If it's a proposal, it

 2     means that it still can be subject to changes before it becomes -- before

 3     it gets into force.

 4             MR. ZECEVIC:  Well, Your Honours, I agree entirely with you.  But

 5     this is the -- the only document, unfortunately, that we have.  And this

 6     is dated 8th of January, 1990.

 7             The witness became a chief of the CSB in April or May 1991.  So

 8     by that time, this -- while we were proofing the witness, he recognised

 9     this -- this is just concerning the organisational structure of the CSB.

10     And that is the only reason that I'm showing this to the witness, and the

11     witness recognised during the proofing and he will testify to that, that

12     this is the situation in the organisational sense that he found when he

13     became the chief of the CSB.

14             So, therefore, we can assume that this -- in this part, this

15     proposal was accepted somewhere in the meantime between 1990 and 1991.

16             JUDGE HALL:  I was about to say I am surprised that counsel for

17     the other side wasn't on their feet.  Because you -- it appeared to me

18     that you were crossing the line into giving evidence, Mr. Zecevic.

19             MS. KORNER:  It wasn't so much that.  I don't think this is a

20     particularly important point, Your Honour.  But for future reference, to

21     say with the witness with his headphones on listening to us, This is what

22     the witness will say, is not, in my judgement, a very good way of going

23     about things.

24             MR. ZECEVIC:  Well, I'm sorry.  I understand.  I was trying to be

25     helpful.  I didn't thought that this was in the point of contest between

Page 19423

 1     us.

 2             MS. KORNER:  It isn't, Your Honours.  But nonetheless, just for

 3     future reference, this is not a proper way to do it.

 4             MR. ZECEVIC:  I understand, and I'm sorry.  [Microphone not

 5     activated].

 6             May I continue?

 7             JUDGE DELVOIE:  Please do.

 8             MR. ZECEVIC:

 9        Q.   [Interpretation] Mr. Bjelosevic, what can you tell us about the

10     content of this document, in terms of the organisational scheme and

11     structure of the Security Services Centre, as you found it when you

12     joined in 1991?

13        A.   When it comes to the organisational structure, this is what it

14     was.  There was the public -- public security centre, which had its

15     departments.  The first one was the department for the detection and

16     prevention of crime; the police department; the administrative legal and

17     personnel department; there was an anti-arson department; the department

18     for finances; and there was also the state security sector with its own

19     departments; and there was a common -- communications centre.

20             And here you can see all the elements and who was doing what.  If

21     we are talking about individual departments, you see that their job

22     descriptions are also given in here.

23        Q.   Mr. Bjelosevic, when you are talking about the lines of work and

24     when you listed them for us, along a certain hierarchy, did they go from

25     the lowest structure, and when I mention the lowest structure I mean

Page 19424

 1     public security stations, up to the republican MUP.  Yes or no?

 2        A.   Yes.  And in that, the police department in the centre had the

 3     role to organise and direct the work of police stations.  They were not

 4     order issues [as interpreted].  However, the police administration in the

 5     ministry issued orders to the police in the centre.  Their role was also

 6     instructive and supervisory.

 7        Q.   Thank you.  If I understood your comment properly, this document

 8     which is the proposal for the regulation on internal organisation

 9     reflects the organisational situation that you found upon becoming chief

10     of CSB in April and May of 1991?

11        A.   Yes.

12             MR. ZECEVIC: [Interpretation] If there's no objection, I tender

13     this into evidence.

14                           [Trial Chamber confers]

15             JUDGE HALL:  Mr. Zecevic, there are a number of questions --

16             MR. ZECEVIC:  Well --

17             JUDGE HALL:  -- that --

18             MR. ZECEVIC:  If I may, Your Honours, I just checked.

19             I withdraw my proposal because we actually have the -- in our law

20     library, we have the whole ... it's P850.  Sorry.  I'm sorry,

21     Your Honours, I interrupted you.

22             JUDGE HALL:  That was the second question I was about to ask.

23     The first question is coming back to the question Judge Delvoie asked.

24     And I heard after the exchange what the witness said, but I'm still not

25     clear as to the -- what is termed a proposal, on the one hand, and what

Page 19425

 1     he saw when he came in, on the other.

 2             Could you clarify that for us, please.

 3             MR. ZECEVIC:

 4        Q.   [Interpretation] Mr. Bjelosevic, just very briefly, please,

 5     explain to us the structure that existed at the Doboj CSB at the time

 6     when you became chief.  If I may assist you further, please give us the

 7     description of how it was divided, both within public and state security

 8     lines of work and what were joined services.

 9        A.   As I have already said, there was the department for public

10     security and the department for state security.  Each department was

11     headed by a chief.

12             The public security had the following structure:  A crime

13     detection and prevention section, within which --

14             JUDGE HALL:  If I might interrupt, I think I got that when the

15     witness said it initially.

16             My question is a much simpler one, and it is whether -- despite

17     the fact that we don't have, I suppose, a final version, whether,

18     although called a proposal, this is it.  That's -- that's all I'm asking.

19             MR. ZECEVIC:  I'm sorry, it's obviously entirely my fault.

20             The thing is that I -- I consulted -- we do have the final

21     version and it's P850.  It is -- it is a document which contains the

22     actual -- the whole rule-book of the -- which was -- which was in force

23     at the time.  And that is why I withdrew this -- my proposal to admit

24     this document.

25             I'm sorry, I mis -- I misinterpreted Your Honours' wish.

Page 19426

 1             JUDGE HALL:  Thank you.

 2             JUDGE DELVOIE:  And then a last question just to understand it.

 3     It's not specifically -- but shouldn't this be an L number then, law

 4     library?  It's a P number.

 5                           [Trial Chamber and Registrar confer]

 6             JUDGE DELVOIE:  Okay.  Thank you.

 7             MR. ZECEVIC:  I am -- over the break, I can provide this answer

 8     because I ... I don't know at this point what is the explanation, why it

 9     not L but P number.

10             JUDGE DELVOIE:  The explanation seems to be that this was

11     tendered before we made an L category.

12             MR. ZECEVIC:  Thank you very much.

13        Q.   [Interpretation] Mr. Bjelosevic, you just enumerated public

14     security stations which were branch stations of the CSB, and you gave us

15     the names of their chiefs at the time.  The only other remaining item

16     that could be relevant would be ethnic background of the chiefs.

17             So if you know this information, could you please tell us,

18     listing each SJB and the ethnic background of their chief at the time.

19        A.   In Brod, Samac, Derventa, and Modrica, the chiefs were Croats, of

20     Croat background.

21             In Doboj and Teslic, the chiefs were Serbs.

22             In Tesanj, Maglaj, the chiefs were of Muslim or Bosniak ethnic

23     background.

24        Q.   Thank you.  Mr. Bjelosevic, at the time, in 1991, how did local

25     policy-makers view your appointment as chief of the Doboj CSB?

Page 19427

 1        A.   As far as the politicians were concerned, from the very

 2     beginning, I faced a sort of obstruction and disagreement with my

 3     appointment to that position due to the fact that I was apolitical at the

 4     time.  I did not belong to any of the political parties which took part

 5     in the coalition government.

 6        Q.   Perhaps it would be best to illustrate this by way of a document.

 7             MR. ZECEVIC: [Interpretation] 65 ter of the Defence, 749D1,

 8     tab 1A, please.  Dated 29th of May, 1991.

 9        Q.   Just a minute.  We're waiting for the English translation of the

10     document.

11             Yes, please go ahead now.

12        A.   This document was sent out to the field.  As you can see in the

13     heading, it says "Regional Board," or actually, that's at the bottom of

14     the document.  The Regional Board of the SDS.  This document was sent to

15     a number of addressees in all municipalities within the jurisdiction of

16     the Doboj CSB.

17        Q.   Tell me, please, this document was also sent to the MUP

18     headquarters and also to the Main Board of the SDS in Sarajevo, as well

19     as to the SJBs in the Doboj region?

20        A.   Yes.  You can see exactly to whom it was addressed in the top of

21     the document.  I had some problems regarding this because -- where it

22     says here that I was not their representative and did not have their

23     support, and they were entitled to have their man in that position.

24        Q.   Would you please explain this to us in a bit more detail.  Who

25     was their man?  Why did they formulate it in this manner?

Page 19428

 1             Would you please give us some background information and also

 2     explain the second page which is part of this document.

 3             MR. ZECEVIC: [Interpretation] Could we see the second page of

 4     this document in e-court, please.

 5             THE WITNESS: [Interpretation] It is clear here that, among three

 6     of us, three candidates for this post, the SDS had its favourite, which

 7     was Milan Ninkovic.  After all of the procedures were completed, and once

 8     I was appointed to the post, they were displeased that their man was not

 9     appointed.  At the SDS meeting, they adopted this decision, and they sent

10     it to all of the addressees listed on the first page.

11             However, the minister and the others who were together with

12     Minister Delimustafic abided by their original decision.  They did not

13     want to amend it.  However, in my work, in my further work, I faced

14     constant problems with respect to these political structures.

15             MR. ZECEVIC:

16        Q.   [Interpretation] So if I understood you well, despite this

17     intervention of the regional board of the SDS, which was sent to the

18     Ministry of the Interior of the Socialist Republic of Bosnia-Herzegovina,

19     to its headquarters, it was therefore sent to the ministry which was

20     headed at the time by Minister Alija Delimustafic, the ministry did not

21     want to amend its initial decision to appoint you as chief of the CSB,

22     right?

23        A.   Yes, that's correct.

24             JUDGE DELVOIE:  If I may, Mr. Bjelosevic, this, let's say,

25     opposition against your appointment, was this normal procedure?  Was this

Page 19429

 1     done by the rules?  Was it in the rule, the possibility that the -- that

 2     this board could oppose and that the minister had -- had to reassess and

 3     eventually change his appointment or keep it as it was?

 4             So was it in the rules, or was this something extraordinary?  Was

 5     this an unusual intervention of this board?

 6             THE WITNESS: [Interpretation] I think that something of this

 7     nature was not set forth in the rules.  However, there was a sort of a

 8     political agreement among the political parties which did not have a

 9     force of law or any other mandatory regulation.

10             JUDGE DELVOIE:  Thank you.

11             MR. ZECEVIC:

12        Q.   [Interpretation] To clarify this, Mr. Bjelosevic, is it true that

13     among national coalition parties, that is to say, the SDS, the SDA, and

14     HDZ, there was a coalition agreement reached?

15        A.   Yes.

16        Q.   Are you aware that there was also agreement on allocation of

17     senior positions in all state agencies and structures, including the

18     Ministry of the Interior?

19        A.   Yes.

20        Q.   Are you aware that this agreement also entailed the duty on the

21     part of the proposing party which was entitled, in accordance with the

22     coalition agreement, to propose a candidate, a duty to propose three

23     candidates so that the other two coalition parties would then be able to

24     give their consent to appointment of one among these three candidates?

25        A.   Yes.  As I have already told you, there was an inter-party

Page 19430

 1     coalition agreement, and none of us could have been proposed for a post

 2     without there being a prior political agreement regarding this, without

 3     there being a prior consent for these candidates.

 4             However, the parties usually had their favourite among the

 5     three candidates.  Mr. Ninkovic was the favourite of the party, although

 6     they did consent to my candidacy and that of the third candidate.

 7     However, they preferred that Milan Ninkovic be appointed.  This is why

 8     they sent this letter.

 9             However --

10        Q.   Just a moment, Mr. Bjelosevic.  Let's clarify.

11             You have to be clear in your answers.  When you say "the party,"

12     are you referring to the SDS?  If I understood you well, the SDS, which,

13     according to the coalition agreement, was entitled to appoint the chief

14     of the Doboj CSB, they proposed three candidates.  That was their

15     proposal.  Was that right?

16        A.   Yes, that's precisely how it was.

17             MS. KORNER:  Your Honours, again, I haven't objected so far, but

18     each and every one of these questions was leading.  There is not a lot of

19     dispute about this.  But I would ask that Mr. Zecevic is quite careful

20     because he is actually literally putting words into the mouth of the

21     witness.  It's not what the witness said at all.  Mr. Zecevic said that.

22             MR. ZECEVIC:  I'm sorry, I'm trying to save the time and sort of

23     direct the witness.  Because the witness is obviously inexperienced in

24     giving a testimony, so that's why I'm crossing the line a bit and I'm

25     fully aware of that, but I didn't thought that this was an issue that is

Page 19431

 1     contested.

 2        Q.   [Interpretation] Sir, as you see, we have objections from the

 3     Prosecutor.  So in order to avoid that, would you please explain in

 4     detail how that looked in practice in the case of Doboj.  How come this

 5     document came about?  How come you were the person appointed by the

 6     minister and not the person who was the SDS favourite?

 7        A.   In respect of each and every post that was deemed to be

 8     important, an agreement had to be reached first among the coalition

 9     parties.  And in this specific case, since there had been an agreement

10     reached that the right of choice for the chief in this instance lay with

11     the SDS, three candidates were put forth.  Once the proposal is made, the

12     party making the choice can choose any of the three.  However, the case

13     of the matter was that whenever any of the parties nominated their three

14     candidates, they would have their favourite.

15             In this particular instance, their favourite or, rather, their

16     candidate number one wasn't the one that was chosen.  Rather, it was me,

17     and it was in this way that the party expressed their dissatisfaction

18     with it.  You see that they sent this memo to the presidents of the

19     municipal assemblies present in the region, presidents of

20     Executive Boards, the MUP of Sarajevo, and even to the chiefs of

21     stations.  In other words, individuals who were within the hierarchy

22     below the chief of CSB and the Main Board of the SDS, they were the

23     addressees.  Still, the minister and whomever it was who made the choice

24     with him stuck to me as being the one from among the three candidates.

25             JUDGE DELVOIE:  I'm still not clear about one detail.  It all

Page 19432

 1     starts with the inter-party agreement, and that means that the parties

 2     agree upon the affiliation of the person to be appointed.  It will be an

 3     SDS candidate or a candidate of the Muslim party or a candidate of the

 4     Croat party.

 5             Is that right?

 6             THE WITNESS: [Interpretation] It wasn't based on party

 7     affiliations but on ethnicity.

 8             JUDGE DELVOIE:  On ethnicity, okay.  Okay.  And then the three

 9     names within the ethnicity that had been chosen, were those three

10     names -- was this list made upon the agreement between the parties?  Was

11     that a party agreement as well?

12             THE WITNESS: [Interpretation] What remained was the right to

13     challenge any of the candidates, if there was an underlying reason.  For

14     instance, in respect of some of the functions --

15             JUDGE DELVOIE:  The three -- the -- the parties had to agree on

16     the candidates, on the three persons proposed by, in this case, the SDS.

17     Is that right?

18             So what -- what I wasn't sure about was whether the three parties

19     had to be -- had to -- whether the parties had to agree on the three

20     candidates, or that it was the right of the SDS to -- to propose three

21     candidates.

22             THE WITNESS: [Interpretation] Let me explain this more broadly.

23             Let's stick to the Security Services Centre.  It was agreed

24     amongst the parties that the chief of the centre would be a Serb.

25     Specifically, the chief of the public security service in Doboj would be

Page 19433

 1     a Muslim, and the chief of the State Security Service would be a Croat.

 2     And that was the result of an inter-party agreement.

 3             Now, since every party basically clung to ethnicity itself, they

 4     each had the right to nominate three candidates, and they didn't have to

 5     seek the agreement of the other two parties for the three candidates.

 6     For instance, the SDS didn't have to seek the approval of the HDZ and the

 7     SDA in respect of its three candidates.

 8             JUDGE DELVOIE:  So it was, in this specific case, the SDS who

 9     appointed three candidates.  The other parties had nothing to say about

10     that.  But, still, within the three candidates, the SDS had a preference,

11     which I can understand.  But then they had the right to say, We want that

12     candidate and not one of the other two.  Why did they have to propose

13     three candidates then?  Why not just say, That's the one.

14             THE WITNESS: [Interpretation] There was the obligation to

15     nominate at least three candidates.  And there were many reasons why this

16     was insisted on.

17             JUDGE DELVOIE:  Thank you.

18             MR. ZECEVIC:

19        Q.   [Interpretation] Mr. Bjelosevic, did the other coalition parties

20     have the right to challenge the candidates put forth by one of the

21     coalition parties?

22        A.   I don't think that they did at this level.  Or for this level.

23        Q.   Let me phrase the question this way.

24             Mr. Bjelosevic, when you were nominated for the post of chief of

25     CSB Doboj, did you enjoy the support of the Party of Democratic Action

Page 19434

 1     and the HDZ?

 2        A.   I don't know what you -- what you mean, if I enjoyed their

 3     support.

 4        Q.   Let me clarify this.  Did Alija Delimustafic, the then-minister,

 5     represent the Party for Democratic Action?

 6        A.   Yes.

 7        Q.   Did Alija Delimustafic sign your candidacy?

 8        A.   Yes.

 9        Q.   Did Alija Delimustafic -- or, rather, tell me, who was in charge

10     of personnel issues within the MUP of the Socialist Republic of Bosnia

11     and Herzegovina?

12        A.   Yes, there was an administration for personnel.  Hilmo Selimovic

13     was the head.  Later on there was a change.

14        Q.   And who replaced him?

15        A.   Srebrenikovic.  I can't recall his first name.

16        Q.   Was it Mirsad?

17        A.   Possibly.  An individual, at any rate, who had not been living in

18     Bosnia-Herzegovina before that point.

19        Q.   Let's take it slowly, Mr. Bjelosevic.

20             Hilmo Selimovic, who was the chief of the personnel

21     administration within the MUP of the Socialist Republic of

22     Bosnia-Herzegovina, and the individual who replaced him subsequently,

23     Srebrenikovic, were both of them SDA cadres?

24        A.   Yes.

25        Q.   Mr. Bjelosevic, the SDS Doboj --

Page 19435

 1             JUDGE DELVOIE:  Mr. Zecevic, I'm sorry, but I am a little bit

 2     confused here.  Or rather, aren't you confusing political parties and

 3     state authorities?  The authority that has the power to nominate?

 4     Because you're talking about the minister and the head of the -- the head

 5     of the personnel service in the administration.  And you -- you --

 6             Could the witness remove his -- his headphones, please.

 7             And you -- if I understand you well, you're trying to suggest

 8     that this is a party challenge to the candidates proposed by the SDS.  Is

 9     that a party challenge?

10             MR. ZECEVIC:  Your Honours --

11             JUDGE DELVOIE:  That's -- that's the normal consequence of three

12     candidates proposed to the government and the government taking a

13     position, whether that government -- whether the minister is of this

14     ethnicity or that ethnicity or the head of personnel is of this ethnicity

15     or that ethnicity.

16             So I'm confused.

17             MR. ZECEVIC:  But that -- that's precisely the point,

18     Your Honours, I'm trying to establish.

19             The -- according to the coalition agreement between the parties,

20     they have -- they have designated a certain system, or how it was

21     understood which party is having the right to name its own candidates for

22     a certain position within the government structures.  For example, like

23     this example, the chief of the CSB of Doboj.

24             So according to the coalition agreement, it was the right of the

25     SDS.  And the witness explained that -- that the system existed.

Page 19436

 1             JUDGE DELVOIE:  But the right of the SDS was to -- to nominate

 2     three candidates.

 3             MR. ZECEVIC:  That is correct.

 4             JUDGE DELVOIE:  So where's the problem?  It leaves a -- even in

 5     that -- in that coalition agreement, it leaves -- it leaves room for

 6     appreciation for the minister who has to nominate.  It -- there are three

 7     SDS candidates.

 8             MR. ZECEVIC:  Yes.  Yes, there are three SDS candidates, and that

 9     is sent -- the -- the system with the three was that -- the system was

10     designated with the three so as that the other parties or the -- the

11     actual minister or the -- the government authorities have the right to

12     choose.  But it is -- it is also understood, at least it is my

13     understanding, that if the minister or the people who are choosing are of

14     the -- of the certain -- are the representatives of the certain party,

15     they do have, in their mind, the position of that particular party.  And

16     that's what I'm trying to establish with the witness.  When taking the

17     decision.

18             MS. KORNER:  Your Honour, may I say we're taking an awful long

19     time over what seems to be a fairly simple point.

20             But I do really want to reiterate my objection.  Whatever

21     Mr. Zecevic may believe is the case is not relevant.  He can ask

22     non-leading questions of the witness to establish what the witness's

23     knowledge of this is, and then if he wants to call further evidence or

24     point us to what evidence there is about it, that's something different.

25             MR. ZECEVIC:  Well, I'm sorry, but I was invited by Their Honours

Page 19437

 1     to explain my position, and that is what I was doing.

 2             MS. KORNER:  Every question has been a leading one to the

 3     witness.  As it turns out, the witness isn't actually agreeing with you,

 4     and it may well be that the witness doesn't have the faintest idea.  And

 5     if you ask it in a non-leading form, you may get an answer.

 6             JUDGE DELVOIE:  My impression, Mr. Zecevic, was that the witness

 7     clearly said that there was no possibility to challenge the -- the --

 8     within the three names, possibility for the other parties to challenge

 9     the candidates.

10             MR. ZECEVIC:  Well, I will -- I will give my explanation at the

11     end, I guess.  Otherwise, it would be -- it would be -- there would be an

12     opposition from the Office of the Prosecutor.  But there is a very clear

13     answer to that, Your Honour.

14             May I continue --

15             JUDGE HALL:  Mr. Zecevic, is this a convenient point to take the

16     break?

17             MR. ZECEVIC:  Yes.  Thank you very much.

18             JUDGE HALL:  We will continue afterwards.

19             We would resume in 20 minutes.

20                           [The witness stands down]

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

22                           --- On resuming at 10.57 a.m.

23                           [The witness takes the stand]

24             JUDGE HALL:  Yes, Mr. Zecevic, you may continue.

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

Page 19438

 1        Q.   [Interpretation] Mr. Bjelosevic, who was it who ultimately signed

 2     your appointment to the chief of CSB Doboj?

 3        A.   The then-minister, Alija Delimustafic.

 4        Q.   Thank you.

 5             MR. ZECEVIC: [Interpretation] If there are no objections, I wish

 6     to tender the document into evidence.

 7             MS. KORNER:  No objections, Your Honours.  But could I just ask,

 8     is this a document that was provided by Mr. Bjelosevic to the Defence?

 9             MR. ZECEVIC:  Yes.

10             MS. KORNER:  Thank you.

11             JUDGE HALL:  Admitted and marked.

12             THE REGISTRAR:  Exhibit 1D435, Your Honours.

13             MR. ZECEVIC:

14        Q.   [Interpretation] Mr. Bjelosevic, we touched upon the structure of

15     the MUP of the Socialist Republic of Bosnia-Herzegovina only briefly, and

16     that at the time when you became the chief of CSB Doboj.

17             MR. ZECEVIC: [Interpretation] Can we have P875?

18        Q.   And I'll ask you to give us your comments.

19             MR. ZECEVIC: [Interpretation] Could the Usher please assist me in

20     giving the witness my folder to have a look.

21             Can we please see it on the monitor, the whole breadth of it.

22        Q.   Mr. Bjelosevic, can you give us your comments on this organigram

23     of the MUP of the Socialist Republic of Bosnia-Herzegovina in the period

24     between January 1991 and March 1992 that you have before you?

25        A.   I see this organigram from the minister down to assistant

Page 19439

 1     ministers to the various territorial units, including public security

 2     stations within the centres.

 3        Q.   Can you see the names of assistant ministers who are divided up

 4     by their line of work?  And can you confirm that this was, indeed, the

 5     case at the time, that these were the individuals who held these posts?

 6        A.   Yes.  Alija Delimustafic was minister at the time.  His assistant

 7     was Zepinic, as is reflected here, indeed.  And then -- or, rather, his

 8     deputy was Zepinic.  And then from assistants, yes, I do recognise these

 9     names, and I would say that this was, indeed, the case.

10        Q.   Thank you.  Mr. Bjelosevic, can you explain to us what sort of

11     situation existed on the ground when, in late April/early May, you took

12     up the position of chief of the CSB Doboj?

13        A.   In terms of organisation, the situation reflected this

14     organigram.  That's what it looked like.  There was some change in the

15     personnel at the time, but this was the result of previous agreements.

16             However, as early as in 1991, there was a very complex security

17     situation in the then-Yugoslavia, primarily because of the war in Croatia

18     which began in early May, and with that conflict spreading.  There

19     emerged a wave of refugees in Croatia who were moving to our region, and

20     when I say "to our region," I mean the Bijeljina [as interpreted] area.

21     There were quite a few refugees arriving from Western Slavonia,

22     specifically Grubisno Polje.  Some of the refugees stayed in the region

23     and others headed onto Serbia or, rather, Yugoslavia.  Well, it was all

24     Yugoslavia at the time.

25        Q.   Here, at page 33, line 9, it says:  "When I say 'our region,' I

Page 19440

 1     mean the Bijeljina region."

 2        A.   I said Doboj.

 3        Q.   Yes, that's what I wanted to correct on the transcript.

 4             Can you tell us what was the ethnicity of the refugees you were

 5     referring to?

 6        A.   The refugees arriving in the Doboj area were Serbs.  There were

 7     some Croats among them, but most of them were Serbs.

 8        Q.   Go ahead, please.

 9        A.   Another issue that was typical for that period of time was that

10     quite a few individuals went from Bosnia-Herzegovina to the Croatian

11     front line.  This was also a cause of interethnic mistrust.  Quite often

12     it would so happen that members of all sorts of formations would come

13     back from Croatia to their home areas in the Doboj region.  They would

14     come wearing uniforms, and they would often carry weapons as well.

15             Fear was widespread among the population.  In some places, there

16     were instances of sabotage taking place.  In particular, the bridge on

17     the Vijaka river, between Derventa and Prnjavor, was blown up.  This took

18     place in September, sometime in September.  It was a long time ago; I

19     can't remember exactly.  But I do believe it was in September.

20        Q.   When say September, what year do have you in mind?

21        A.   1991.  This caused some distress among the citizens in the area.

22     And I know that very soon after that, the first guards appeared on the

23     bridge across the Ukrina river because people feared for the safety of

24     that bridge.  They feared that it might be blown up as well, and that's

25     why they guarded it at night.

Page 19441

 1             The position of that bridge is between the villages of Strpci and

 2     Detlak, near the fish pond.

 3        Q.   When you say guards, what guards do you mean?

 4        A.   I mean village guards.  People who simply organised themselves,

 5     they took weapons that they had to hand, and they stood guard on both

 6     sides of the bridge.

 7        Q.   Sir, Mr. Bjelosevic, at that time, and I mean September 1991,

 8     were there any onslaughts by armed forces from the territory of Croatia?

 9        A.   In September, if my memory serves me well, I believe it was on

10     the 15th of September, 1991, an attack was launched at the barracks in

11     Slavonski Brod, and that is across the river Sava from -- across

12     Bosanski Brod, and during the state of Yugoslavia, Slavonski and

13     Bosanski Brod functioned as one whole, as one unity.

14             In the evening hours, that clash escalated into a proper armed

15     combat.  From the Slavonian side, fire was opened across the river

16     towards the right bank, towards Bosanski Brod, primarily an engineering

17     point of the Yugoslav People's Army that was there.  And after that,

18     there was mortar fire of a higher calibre, targeting the villages of

19     Gisca [phoen], Klakar, both of them in the territory of Bosanski Brod

20     municipality.  At the Klakar brick-works we also had a victim, if I

21     remember it properly.  That person was an engineer.  His name was

22     Goranovic; I can't remember his first name, though.  He was killed on

23     that occasion.

24        Q.   Sir, you have to explain what you said on page 35.

25             THE INTERPRETER:  And the microphone is not on.

Page 19442

 1             MR. ZECEVIC:

 2        Q.   [Interpretation] On page 35, 1 and 2, can you explain what you

 3     said on that page?  And I mean the situation involving Slavonski and

 4     Bosanski Brod settlements.  You said that in the former Yugoslavia those

 5     two settlements functioned as one whole.  Can you please explained

 6     geographical location of those two places, and what did you mean when you

 7     say that?  It is not very clear in the transcript.

 8        A.   When I said that they functioned as one whole, I mean the

 9     organisation of health care in these two cities, I mean the education

10     system, as well as the economy, of course.

11             To this very day, this is an oil refinery in Bosanski Brod.  Back

12     then, about 800 people who worked in the refinery were from

13     Slavonski Brod.  In Slavonski Brod, there was a large factory whose name

14     was Djuro Djakovic.  It was a large industrial complex.  A lot of people

15     from Bosanski Brod commuted to Slavonski Brod and worked in that

16     industrial complex.

17             The hospital and all other health care institutions are funded --

18     were funded jointly by Bosanski and Slavonski Brod.  Bosanski Brod didn't

19     even have a maternity ward.  That's what I meant when I said that the two

20     cities functioned as one whole.

21        Q.   In fact, those were two cities in two different republics

22     separated by a river, right?

23        A.   Yes, right.

24        Q.   Sir, could you please look at document 117 -- or, rather, that's

25     tab 117.  65 ter 758D1.

Page 19443

 1             JUDGE DELVOIE:  Mr. Zecevic, before we go to that one.

 2     Mr. Bjelosevic, a few minutes ago you said that it would happen that

 3     members of all sorts of formations would come back from the -- from

 4     Croatia, the Croatian front, I suppose, to their homes, to their home

 5     areas in the Doboj region.  They would come wearing uniforms and they

 6     would often carry weapons.  They would come wearing uniforms and all

 7     different sort of formations, you said.  Am I correct by the taking that,

 8     generally, the uniforms were JNA uniforms?  Or would that be other

 9     uniforms as well?

10             THE WITNESS: [Interpretation] Of course, some wore JNA uniforms,

11     those who belonged to JNA units.  However, what I meant here were

12     primarily members of the Croatian National Guards, the HOS units from

13     Croatia, and other units that had been established there.  People from

14     Doboj region went and joined those units as volunteers.  Therefore, the

15     situation was such that we had members of the JNA as the regular military

16     of Yugoslavia at the time, and, other hand, there are also members of

17     those paramilitary units from Croatia who had returned in uniforms, often

18     carrying weapons, and they would come back to our region.  And that had

19     quite a strong impact on creating distrust among ethnic groups and

20     instilling fear among people.  There were armed components from Croatia

21     which clashed with the JNA in our immediate vicinity.  Fear was rife and

22     there was a lot of mistrust as a result of that.

23             JUDGE DELVOIE:  That's an important clarification.  I understand

24     now that there were people from both sides fighting at the Croatian front

25     in the same area in Doboj.  Thank you.

Page 19444

 1             MR. ZECEVIC:  Thank you, Your Honour.

 2        Q.   [Interpretation] Mr. Bjelosevic, before we look at the document

 3     that I have just called up, and before I invite your comments, let me ask

 4     you this:  Which of the municipalities in your region bordered on the

 5     Republic of Croatia?

 6        A.   Bosanski Brod, Odzak, Samac, and Derventa, partially.

 7        Q.   So it was just the river Sava that separated those municipalities

 8     from the Republic of Croatia?

 9        A.   Yes.

10        Q.   Thank you.

11             MR. ZECEVIC: [Interpretation] 758D1 is the document that I would

12     like to call up now.

13        Q.   Sir, could you please comment on this document.  The title is

14     report.  The date is 14 September 1991, issued by the public security

15     station in Bosanski Samac.  The signatory is a certain Djordje Tesic.  Do

16     you know him?

17        A.   Yes.

18             MR. ZECEVIC:  I'm sorry, I said tab number 117.

19        Q.   [Interpretation] Can you tell us something about this document,

20     please, and about this case as well.

21        A.   Yes.  I remember the incident.  That was precisely one of those

22     events that involved members of those formations who had arrived in

23     Bosanski Samac.  The police went to the place of the incident.  As you

24     can see from the document, they brought those armed men in.  However, no

25     criminal reports were ever filed.  There was no prosecution against those

Page 19445

 1     men.

 2             As you can see in the document, the reason was that the chief of

 3     the police station in Bosanski Samac, Vinko Dragicevic, ordered that the

 4     individuals had their weapons returned and that they were released.

 5             Later on, that incident kept on being commented in town.  It also

 6     instilled a certain degree of fear and mistrust, even among the members

 7     of the public security station.

 8        Q.   Thank you very much.  We will come back to that situation in

 9     Samac.  We will revisit that.

10             MR. ZECEVIC: [Interpretation] If there are no objections, I would

11     like to tender this document.  It is 65 ter -- it has been misrecorded.

12     65 ter 758D1.  I would like to tender this document into evidence,

13     please.

14             MS. KORNER:  Can I just ask, is this a document given by the

15     witness?

16             MR. ZECEVIC: [Interpretation] Yes.

17             MS. KORNER:  Thank you.

18             JUDGE HALL:  Although I heard what the witness -- if I understood

19     him correctly, that this incident formed the background to later comments

20     that were made, I'm still not sure that I see how it assists,

21     Mr. Zecevic.  Could you assist me, please.

22             MR. ZECEVIC:  Well, this is precisely in relation to the -- to

23     the answer that the witness gave to His Honour Judge Delvoie's question,

24     about the -- the incidents created by people -- the members of the units

25     from Croatia who came to the territory of -- of the region of Doboj and

Page 19446

 1     the CSB of Doboj, and the problems that that fact caused in the -- in the

 2     territory.  That is precisely the document that confirms that situation.

 3                           [Trial Chamber confers]

 4             JUDGE HALL:  Admitted and marked.

 5             THE REGISTRAR:  Exhibit 1D436, Your Honours.

 6             MR. ZECEVIC:  Thank you.

 7             [Interpretation] Can we look at the document under tab 2.  1D253,

 8     tab 2.

 9        Q.   Mr. Bjelosevic, this is a dispatch already in evidence.  You

10     signed this dispatch, and you sent it out on the 16th of September, 1991.

11     It was delivered to the Ministry of the Interior of the Socialist

12     Republic of to Bosnia-Herzegovina to the minister and deputy minister.

13             What do you remember about the dispatch and its contents?

14        A.   Well, this is information about that armed incident.  Or, rather,

15     about the armed conflict that had taken place on the 15th of September.

16             On the following day, we set up an investigation team.  They went

17     to inspect the place.  They carried out an on-site inspection.  They

18     found mortar shell craters around the water works in Bosanski Brod, in

19     Lijesce and around the Klakar brick-works.

20             In the evening, on the day when the incident had taken place, and

21     the incident was a major event, I spent some time in Bosanski Brod

22     myself.  I experienced the incident first-hand.  I experienced fire being

23     opened from all sorts of weapons.  I dare say that that was already an

24     attempt to transfer the armed conflict that had been taking place in

25     Croatia into the territory of Bosnia and Herzegovina.

Page 19447

 1        Q.   Tell me, please, this conflict that erupted on the

 2     15th of September, 1991, was it the first such serious conflict in your

 3     area or not?

 4        A.   It was the first serious conflict.

 5             MR. ZECEVIC: [Interpretation] Could the witness be shown

 6     65 ter 760D1, tab 4, please.

 7        Q.   Mr. Bjelosevic, what was the impact of this conflict of

 8     15th September in Bosanski Brod and in the entire region?

 9        A.   The Croatian side, from that time on, blocked the bridge.  The

10     bridge was mined and a check-point was established on the Croatian side

11     in Slavonia.  It wasn't allowed to have anybody cross from Bosanski Brod

12     into Slavonski Brod, anybody without their passes.  When I say "their,"

13     I'm referring to those from Slavonski Brod.  This meant that people from

14     Bosanski Brod could not go to Slavonski Brod to work there.  However, the

15     people from Slavonski Brod could cross over and come into Bosanski Brod.

16     They could go to the refinery, to their work there.

17             As a result of this ban on crossing from Bosanski Brod to

18     Slavonski Brod, a lot of people were fired from their jobs, and

19     consequently a protest was organised.  The demands that people voiced

20     during that protest meeting were quite clear.  They wanted reciprocal

21     measures to be introduced; that is to say, they either wanted that

22     everybody be allowed to use the bridge, all citizens of Bosanski Brod and

23     Slavonski Brod, or that the bridge be closed off for everyone.  This is

24     why I sent a dispatch regarding this to the prime minister of Bosnia and

25     Herzegovina, as well as to the deputy prime minister for internal policy,

Page 19448

 1     as well as to the minister and deputy minister.  I believe this to be an

 2     important incident with serious consequences for the citizens of Bosnia

 3     and Herzegovina and the citizens of Bosanski Brod, and I also thought

 4     that I needed to provide first-hand information to the government of

 5     Bosnia and Herzegovina as well.

 6        Q.   Sir, this is what this dispatch of yours is about.  The dispatch

 7     of the 30th of September, 1991, that we can see on the screens now,

 8     right?

 9        A.   Yes.

10             MR. ZECEVIC: [Interpretation] If there are no objections, I

11     tender this into evidence.

12             MS. KORNER:  I'm assuming, Your Honours, unless otherwise stated,

13     that all of these documents come from the witness; is that right?

14             MR. ZECEVIC:  Well, not all of them, but this one does.

15             MS. KORNER:  Yes.  Thank you.

16             JUDGE HALL:  Admitted and marked.

17             THE REGISTRAR:  Exhibit 1D437, Your Honours.

18             MR. ZECEVIC:

19        Q.   [Interpretation] Sir, I will now show you 65 ter 759D1, tab 3.

20     And I would like you to comment on it.

21             Could you please explain this document to us and tell us, if you

22     remember, what prompted Minister Delimustafic to send this dispatch.

23     What was the event?

24        A.   I remember this dispatch.  I think that it was written, inter

25     alia, due to the conduct of the chief of the station in Brod, in

Page 19449

 1     Bosanski Brod.  There was some information indicating that when it came

 2     to this incident, it was first the Crisis Staff and the police

 3     administration in Slavonski Brod that were informed about it, and only

 4     subsequently and in a limited volume was the information sent to the MUP

 5     in Sarajevo and to the centre.

 6        Q.   Let's clarify this.  When you say "information," are you

 7     referring to the information from the Bosanski Brod SJB, from the Bosnian

 8     side which was subordinated to you, the Doboj centre.  Is that -- is that

 9     what you're referring to?

10        A.   Yes.  And, later on, I learned that there was a special telephone

11     line set up, of which we knew nothing at the time.  The telephone line

12     between the police administration in Slavonski Brod and the SJB station

13     in Bosanski Brod.

14             JUDGE DELVOIE:  Mr. Zecevic, just one moment.

15             Your previous question - let's clarify this - and the answer, is

16     that to say that the transcript of the previous answer is wrong, where it

17     is referred to Slavonski Brod and not to Bosanski Brod?

18             MR. ZECEVIC:  Well, that is precisely why I wanted to clarify

19     that, because I see that there is some --

20             JUDGE DELVOIE:  There was some -- something illogical --

21             MR. ZECEVIC:  -- some problems in understanding.

22             JUDGE DELVOIE:  So the reference to Slavonski Brod is not

23     correct.  It was not that this information was first sent to the -- to

24     the Crisis Staff and the police administration in Slavonski Brod.

25     That's --

Page 19450

 1             MR. ZECEVIC:  No, that is correct.  Sorry --

 2             JUDGE DELVOIE:  That's not correct, Mr. Witness, if I understand

 3     the next answer correctly.

 4             THE WITNESS: [Interpretation] That is correct.  I said and I will

 5     repeat, that the chief of the public security station in Bosanski Brod

 6     first got in touch and sent information to Slavonski Brod, to the police

 7     administration in Slavonski Brod.

 8             MS. KORNER: [Microphone not activated] ... demonstration, I

 9     think, of please, please, let the witness answer the questions and not

10     counsel.

11             MR. ZECEVIC:  I'm sorry, when I said "correct," I meant that the

12     witness's answer was correctly recorded.

13             JUDGE DELVOIE:  Okay.  Thank you.

14             MR. ZECEVIC:

15        Q.   [Interpretation] Mr. Bjelosevic, please, you have to understand

16     that we, including myself, are not very familiar with the situation you

17     are describing.

18             Is it true that Slavonski Brod is in the Republic of Croatia?

19        A.   Yes.

20        Q.   And Bosanski Brod is a town in the Republic of Bosnia and

21     Herzegovina.

22        A.   Yes.

23        Q.   Was your reply that the chief of police in Bosanski Brod - that

24     is to say, a town in Bosnia - first informed the Crisis Staff of the town

25     in Croatia and their police administration before informing the MUP of

Page 19451

 1     Bosnia and Herzegovina?  Was that what you said?

 2        A.   Yes, that was my answer.

 3             JUDGE HARHOFF:  What was the purpose of this call to

 4     Slavonski Brod?

 5             THE WITNESS: [Interpretation] The chief of the police station

 6     relied on Slavonski Brod outside of the rules and contrary to the

 7     hierarchy, outside of the hierarchy.  Simply speaking, he slowly was

 8     turning himself in the direction of Slavonski Brod.

 9             JUDGE HARHOFF:  But if I understand it correctly, the attack came

10     from the Croatian side.

11             THE WITNESS: [Interpretation] Yes.

12             JUDGE HARHOFF:  So when the chief of SJB in Bosanski Brod called

13     his colleague on the other side, was that to stop the attack or ...

14     why -- what was the purpose of the call?

15             THE WITNESS: [Interpretation] At that time, there already existed

16     a certain amount of co-ordination, and there were plans between certain

17     people in the Bosanski Brod police station and the police administration

18     in Slavonski Brod.  That is to say, there was a parallel structure.

19             JUDGE HARHOFF:  And what were these plans about?

20             THE WITNESS: [Interpretation] Well, later on, it will be

21     implemented, in a way.  That is to say, that Croatian forces, with the

22     assistance of certain paramilitary forces from Bosanski Brod, would

23     occupy the SJB in Bosanski Brod, all key positions in Bosanski Brod, and,

24     later on, the wider area of the territory of Bosnian Posavina.

25             JUDGE HARHOFF:  So am I right to conclude that -- that the

Page 19452

 1     communication between the two SJBs on each side of the river was really

 2     designed to have the chief of the SJB on the Bosnian side in

 3     Bosanski Brod, to facilitate the attack and the possible subsequent

 4     takeover of Bosanski Brod by forces from Croatia.  Is that how it was?

 5             THE WITNESS: [Interpretation] That's correct, Your Honour.

 6             JUDGE HARHOFF:  Thank you.  This wasn't at all clear to me,

 7     but ... thank you.

 8             MS. KORNER:  Your Honours, may I just raise something about this

 9     whole line of -- and perhaps the witness should take off his earphones

10     for a moment.

11             JUDGE HALL:  Yes, please ...

12             MS. KORNER:  Thank you.

13             Your Honours, I haven't stopped this so far, but at the moment

14     I'm not clear at all how -- how this is relevant to the issues which

15     Your Honours have to deal with.

16             Your Honours, I don't certainly want to have spend any time

17     dealing with this area of the conflict which is not part of our

18     indictment, and, of course, what you're getting, not surprisingly, is one

19     side of it.  And I could spend, clearly, if I wanted to, and I fully

20     appreciate that, in cross-examination, time dealing with the other aspect

21     of this part of the conflict.  But it seems to me at the moment I'm not

22     clear how that is going to assist Your Honours in any way in arriving at

23     a decision on the events which are related to this indictment.

24             I merely raise it at this stage.  If Your Honours feel that, you

25     know, this is helpful, then I will sit down.  But, at the moment, I'm

Page 19453

 1     saying the relevance to the issues which Your Honours have to deal with

 2     is not clear to me.

 3             MR. ZECEVIC:  May I?

 4             [Interpretation] Your Honours ...

 5             MS. KORNER: [Microphone not activated]

 6             MR. ZECEVIC: [Interpretation] Well, yes.

 7             [In English] Okay.  I will speak in English.

 8             MS. KORNER:  It is obviously -- and I'm afraid I forgot about

 9     that.  His microphone -- he can hear through the earphones even when

10     they're like that.  They're turned up quite loud.  I'd forgotten that.

11             MR. ZECEVIC:  Your Honours, I --

12             Your Honours, I didn't -- I didn't plan to use this much time

13     before on -- on this.  I think this is significant because this is the

14     first really serious armed conflict that happened in the territory of the

15     CSB where -- where our witness was chief of the CSB, and this is the last

16     document I have on that, and I don't have any more questions.  Because

17     this is how I'm bringing you to the context of what is happening and what

18     repercussions this incident had on the -- on the structure of the CSB

19     which is, of course, very relevant for the -- for the case.

20             JUDGE HALL:  I think I follow that, Mr. Zecevic.  Thank you.

21             MR. ZECEVIC:  Thank you very much.

22        Q.   [Interpretation] Can you hear interpretation?  Fine.

23             You've explained to us that the order which we have before us is

24     the response from the Ministry of the Interior of the Socialist Republic

25     of Bosnia-Herzegovina to what happened; is that right?

Page 19454

 1        A.   Yes.

 2             MR. ZECEVIC: [Interpretation] Well, if there is no objection to

 3     the document, I would like to have it admitted.

 4             JUDGE HALL:  Admitted and marked.

 5             THE REGISTRAR:  Exhibit 1D438, Your Honours.

 6             MR. ZECEVIC:

 7        Q.   [Interpretation] Mr. Bjelosevic, following these events in

 8     September 1991, what sort of bearing did these events and the general

 9     atmosphere have on the workings of the CSB Doboj, in terms of their

10     dealings with public security stations?

11        A.   It was already at this time that the system began collapsing, if

12     I may say so; the system of management and the hierarchy itself within

13     the MUP.  Certain paramilitary formations came into being already at this

14     time in our regions, and, as a result, there was fear, there was growing

15     fear, and there was also a growing mistrust between the various

16     ethnicities.

17             There was a sort of differentiation which was occurring on the

18     ground and becoming ever more serious.  In retrospect, it seems to me

19     that the state of Bosnia-Herzegovina failed to respond properly to this

20     situation.

21        Q.   What I'd like to know is:  What sort of consequences, if any, the

22     situation had for the functioning of CSB Doboj?  And I mean in

23     professional terms.

24        A.   Well, negative consequences, by all means.  The subordination

25     system, the reporting system that existed within it began to collapse.

Page 19455

 1     It was disrupted.

 2        Q.   When you say "negative consequences," and the information or

 3     reporting system that you mention, was this the only aspect of it that

 4     you could experience within the CSB or was there more to it than that?

 5        A.   Well, if we look at the situation as it existed in the field,

 6     that was the extent of it.  But if we look at it more broadly, and if we

 7     look at what sort of relations there existed between the ministry and the

 8     centre, as well as the stations that were present within the centre,

 9     that's where things get even more complicated.

10             Some of the stations would establish direct communication with

11     the personnel administration where it came to personnel issues.  Some of

12     the chiefs of stations were appointed in violation of some of the

13     regulations envisaged under the state administration law.  Gradually, it

14     all gained the hallmarks of a shadow, parallel, system which caused the

15     entire system to be undermined.

16        Q.   Let me ask you specifically:  You, as the chief of CSB, were you,

17     under the rules of service and under the law, supposed to be informed of

18     the appointments made to the various posts within the stations in your

19     area?

20        A.   Yes.  That's what the standard procedure was like.

21        Q.   Were you informed and consulted of these issues; and, if so, can

22     you give us specific examples?

23        A.   No, I wasn't consulted on these issues.  And I can give you an

24     example of that.

25        Q.   Please go ahead.

Page 19456

 1        A.   The appointment of the chief of public security station in

 2     Derventa, for instance, where Ivan Duspara was appointed chief, an

 3     individual who did not meet the requirements under the -- prescribed

 4     under the state administration law where it came to his educational

 5     background and the requisite qualifications.  At a later stage, he would

 6     directly apply to the personnel administration, visit there, and bring

 7     along the decisions on the assignment of policemen to various areas

 8     without applying the standard procedure which was that the administration

 9     was supposed to be contacted via the CSB.  He would, instead, go directly

10     to the personnel administration with all the relevant documentation.

11        Q.   Tell me, did you inform the Ministry of the Interior of the

12     Socialist Republic of Bosnia and Herzegovina of such occurrences?  Did

13     you intervene in that sense?

14        A.   Of course I did.  I even asked for Mr. Duspara to step down after

15     he was appointed, precisely by stating all these underlying reasons.  But

16     there were other examples, such as the one involving the deputy chief of

17     state administration in Doboj, where, again, the standard procedure was

18     not applied.  So I drew their attention to this as well.

19             MR. ZECEVIC: [Interpretation] Can we have a look at 65 ter 764D1.

20             JUDGE DELVOIE:  Mr. Zecevic.

21             MR. ZECEVIC:  Yes.

22             JUDGE DELVOIE:  Mr. Bjelosevic, Mr. Zecevic's question was, a few

23     minutes ago:

24             "Let me ask you specifically:  You, as the chief of CSB, were

25     you, under the rule of service and under the law, supposed to be informed

Page 19457

 1     of the appointments made to the various posts within the stations in your

 2     area?"

 3             The question was informed.  You said yes.

 4             And then the discussion went on, not only to the point to know

 5     whether you were informed but also to the point to know whether you were

 6     consulted.

 7             So my question is:  Under the rule of law, was there an

 8     obligation to consult you or only to inform you after appointment?  To

 9     consult you before the appointment; or to inform you after appointment?

10     Or both.

11             THE WITNESS: [Interpretation] Under the Law on State

12     Administration, the degree and profile of professional qualifications for

13     each and every post was provided.  This was further explored through

14     various rule-books, which set out the procedure under which, for

15     instance, the chief of CSB was to be appointed, or the chief of public or

16     state security sectors.

17             In these two cases that I referred to, both the Law on State

18     Administration was broken and -- or, rather, because the requirement for

19     the post of chief of CSB was that of post-secondary school degree.  This

20     wasn't met.  And this was also a violation of the procedure that was in

21     place which made it incumbent on them to consult --

22             JUDGE DELVOIE:  To consult.  Go on.

23             THE WITNESS: [Interpretation] To consult and to send the proposal

24     or the candidacy once it's been agreed upon, to be sent to the ministry

25     from the CSB, and this wasn't done.

Page 19458

 1             JUDGE DELVOIE:  My very specific question was:  According to the

 2     rules, did you, as CSB chief, have to be consulted before a chief of SJB

 3     was appointed in your area?

 4             THE WITNESS: [Interpretation] I was supposed to be consulted, and

 5     under the rule-book, it was the CSB that was supposed to send out the

 6     proposal to the personnel administration of the Ministry of the Interior.

 7             JUDGE DELVOIE:  Thank you.

 8             MR. ZECEVIC:  Just for the record, I said "consulted" in the

 9     first place but it was -- it was -- it was translated -- interpreted as

10     "informed."  But never mind.

11        Q.   [Interpretation] Mr. Bjelosevic, let us clarify this.  Did you,

12     or did the chief of CSB submit the official proposal to the ministry for

13     appointments to chiefs -- to the posts of chiefs of SJBs as provided for

14     under the rules and regulations of the former Socialist Republic of

15     Bosnia and Herzegovina?

16        A.   Well, in these instant cases, that's not how it happened and it

17     should have, indeed, happened in such way that these proposals would go

18     out -- would be submitted from the centre.

19        Q.   So, under the rules, it should have been done this way; but, in

20     reality, it wasn't.

21        A.   Yes.

22        Q.   Was this the reason why you intervened?

23        A.   Yes.

24             MR. ZECEVIC:  I see the time, Your Honours.  Maybe this is the

25     proper time to break.

Page 19459

 1             JUDGE HALL:  Yes.  We would return in 20 minutes.

 2                           [The witness stands down]

 3                           --- Recess taken at 12.05 p.m.

 4                           --- On resuming at 12.28 p.m.

 5                           [The witness takes the stand]

 6             JUDGE HALL:  Please continue, Mr. Zecevic.

 7             MR. ZECEVIC:  Thank you, Your Honours.

 8             I requested a document, 764D1.  It's tab 7.

 9        Q.   [Interpretation] Mr. Bjelosevic, before you is a document dated

10     the 24th of October, 1991.  And I think that you signed it.  Can we have

11     your comments on the document?  What's it about?

12             It's behind tab 7 of your binder.

13        A.   This is precisely my response to the violation of regulations and

14     procedures where change in personnel was concerned.  That's precisely

15     what we were discussing a moment ago.  These are the issues that

16     undermined the very system of work.  You see that there are instances of

17     direct communication contrary to the laws and procedures in place, as

18     well as appointments, et cetera.  And the consequences are clear.

19        Q.   Is this your memo?

20        A.   Yes.

21        Q.   And who was it sent to, who was it addressed to?

22        A.   To the minister of the interior and his deputy.

23        Q.   Thank you.

24             MR. ZECEVIC: [Interpretation] If there no objections, I would

25     like to have this document admitted, please.

Page 19460

 1             JUDGE HALL:  Mr. Zecevic, how does this assist?

 2             MR. ZECEVIC:  Well, Your Honour, the witness -- the last

 3     15 minutes of the previous session we were talking about the situation in

 4     the SJB and the actual non-compliance with the laws at the time on

 5     appointments of the chiefs of the SJB.

 6             The witness said he informed and was protesting that with the MUP

 7     of SRBiH and here is the document that confirms that.

 8             JUDGE HALL:  So this supports the fact that he complained.

 9             MR. ZECEVIC:  Yes.

10             JUDGE HALL:  That's your purpose.

11             MR. ZECEVIC:  Yes, that's what the witness said:  I filed a

12     complaint and this is the actual document.

13             JUDGE HALL:  Yes.  Admitted and marked.

14             THE REGISTRAR:  Exhibit 1D439, Your Honours.

15             MR. ZECEVIC:  Thank you.

16        Q.   [Interpretation] Mr. Bjelosevic, what was the security-related

17     situation like in the area covered by the centre in the course of

18     autumn 1991, if you can tell us briefly.

19        A.   It was very complex.  As of roughly the month of September,

20     things grew gradually worse, due to the events we discussed; various

21     instances of sabotage, the bridge being destroyed, conflicts between the

22     forces of the National Guard Corps and the army, and the spilling over of

23     these conflicts to the territory of Bosnia-Herzegovina, the emergence of

24     paramilitary forces in our area as well, the arming and organising of

25     paramilitary structures.

Page 19461

 1             Naturally, all this made up for a very complex security

 2     situation.  To confirm that this was, indeed, the case, we have the

 3     statement by Sefer Halilovic, who was the first commander of the staff of

 4     the BH army, who confirmed, in one of the interviews he gave for the

 5     BH TV, that as of September, October, and by early November, around

 6     60 per cent of the work surrounding the formation of these units had

 7     already been completed.  We took notice of that, and the MUP, both along

 8     its public and state lines, was being notified of it, but the situation

 9     grew increasingly complicated.

10        Q.   When you say the statement given for the television, was this

11     something that you yourself saw or heard?

12        A.   Yes.

13        Q.   When was it?

14        A.   Sometime in June 2009, I believe.  He was explaining how things

15     were happening, what the objective was, how they frequently changed the

16     location of their staff, precisely in order to maintain the secrecy of

17     the exercise, and we -- those of us who were out in the field were aware

18     of these events.

19             However, we had -- we didn't have the power to confront it,

20     because by then it had gained momentum.

21        Q.   When you say, Mr. Bjelosevic, "we were aware," does it mean that

22     you were aware of the situation back in 1992?

23        A.   Yes.  We knew back then, thanks to the information we had from

24     the state security sector, and we also had some information that we

25     received from the JNA.  We exchanged information.  And what happened next

Page 19462

 1     confirmed that these sentiments were more or less true.

 2             MS. KORNER:  Your Honours, I'm sorry to interrupt, but I'm

 3     getting slightly confused about the dates.  I think there's an error,

 4     certainly, in line 25 of page 54, which reads:  "Sometime in June 2009."

 5     And Mr. Zecevic has just asked:  "Were you aware of the situation back in

 6     1992?"  I thought it was 1991 we were talking about.  But, in any event

 7     that line 25 must clearly not -- is clearly not right.

 8             MR. ZECEVIC:  Well, I can ask the witness again.

 9        Q.   [Interpretation] Sir, when did you hear Sefer Halilovic's

10     statement on BH television, as you put it, and which period did it refer

11     to?

12        A.   It was on the 2nd of June, 2009, that Sefer Halilovic made the

13     statement in a TV show.

14        Q.   Very well.  So that was in 2009.  But it referred to the

15     situation as it prevailed in 1991; is that right?

16        A.   Yes.

17        Q.   Thank you.  Tell us, Mr. Bjelosevic, what sort of measures did

18     the MUP and CSB take in the course of 1991, in view of the highly complex

19     security situation?  And were any measures taken at all?

20        A.   In view of the complex situation and developments at the time, we

21     were under the obligation to inform the ministry headquarters of all

22     these events, and we did as much.  So it went beyond the usual reporting

23     of crime which follow falls under the purview of either a station or a

24     centre.

25        Q.   Mr. Bjelosevic, did you take any specific measures; and, if so,

Page 19463

 1     which?

 2        A.   We informed the ministry of everything.

 3        Q.   Mr. Bjelosevic, in autumn of 1991, did you set up check-points at

 4     intersections?

 5        A.   This was an activity that had been agreed with the

 6     Federal Secretariat for National Defence of Yugoslavia and the

 7     Ministry of the Interior of Bosnia-Herzegovina.  Certain check-points

 8     were set up at key intersections and on the points of entry into

 9     Bosnia-Herzegovina.  The check-points were manned by mixed personnel,

10     meaning civilian and military police.

11        Q.   Can you tell us what sort of activity was going on at these

12     check-points?  What were their duties?

13        A.   Well, the task was precisely to heighten the control of movement

14     of paramilitary formations, of arms smuggling, illegal arming, foreign

15     currency smuggling, and any activities that had the hallmarks of

16     subversive activities or sabotage.

17        Q.   Can you tell us which specific measures did members of the

18     Ministry of the Interior of the Socialist Republic of Bosnia-Herzegovina

19     apply at these check-points?

20        A.   Their activity was regulated by instructions, and the military

21     police had the control over military and paramilitary personnel; whereas,

22     members of the MUP controlled vehicles, whether they were stolen vehicles

23     or not, and did all the other policing duties within the MUP purview.

24        Q.   Mr. Bjelosevic, I'm asking you very specifically what measures

25     were taken.  Do you know or do you not know what measures were taken?

Page 19464

 1        A.   Illegal cars were confiscated, people were brought in and so on

 2     and so forth.

 3        Q.   Mr. Bjelosevic, did you check the IDs of people who passed

 4     through those check-points?

 5        A.   Yes.  We controlled car papers, and we checked people's IDs when

 6     we deemed necessary.

 7        Q.   Did you search the vehicles?

 8        A.   Yes.

 9        Q.   Were such activities taking place in the entire territory of

10     Bosnia-Herzegovina, if you know?

11        A.   Yes.  In the entire territory.  On main roads, cross-roads, and

12     at the entry points into Bosnia-Herzegovina.

13        Q.   Do you know if that action had its name, as it were, or a title?

14        A.   I believe that the name of the action was Check-point 91, or

15     Point 91, if I remember it well.

16        Q.   And can you please repeat about that action, Point 91, which

17     members and of which services and organs participated in that action

18     known as Point 91?

19        A.   The Federal Secretariat for Internal Affairs of Yugoslavia, the

20     Ministry of Interior of Bosnia and Herzegovina, and JNA members.

21             If I may add, that we, on the ground, received a letter from the

22     Ministry of the Interior of Bosnia and Herzegovina.  That letter was

23     signed by the minister, and in that letter, he informed us that that

24     action or that activity would be taking place, and he also told us that

25     we should provide assistance and information to the inspectors from the

Page 19465

 1     federal SUP.

 2        Q.   And now can you please look at a document 65 ter D766, or D1,

 3     that's under tab 9.  766D1.  Tab 9.

 4        A.   Yes, this is information drafted by the Ministry of the Interior

 5     of Bosnia and Herzegovina, reporting the results that were achieved in

 6     the Point 91 operation.  In the introduction, there is reference to the

 7     goals.  The information was drafted on the 15th of November, 1991.

 8             And here you can see a list of all the results, as well as

 9     certain problems which were encountered on the ground.

10        Q.   Thank you.

11             MR. ZECEVIC: [Interpretation] If there are no objections, I would

12     like to tender the document into evidence.

13             JUDGE HARHOFF:  We can only see the front page.

14             How long is this document?

15             MR. ZECEVIC:  Four pages.

16             JUDGE HARHOFF:  Thank you.

17             JUDGE HALL:  Admitted and marked.

18             THE REGISTRAR:  Exhibit 1D450 [sic], Your Honours.

19             MR. ZECEVIC: [Interpretation] Thank you.

20        Q.   Mr. Bjelosevic, in autumn 1991, were MUP reservists mobilised;

21     and, if they were, on whose orders?

22        A.   Yes.  The reserve force was mobilised.  I can't remember exactly

23     on what date.  And it was done on the order of the minister of the

24     interior, Mr. Alija Delimustafic.

25        Q.   As we have heard, you worked at the Secretariat for

Page 19466

 1     National Defence, and previously you were the chief of the

 2     Security Services Centre.  Could you give us some technical details of

 3     mobilisation.  When you wanted to mobilise the reserve force of the

 4     police, how did you do that?

 5        A.   We had defence plans for every public security station which

 6     defined the number of people and the number of police stations in every

 7     specific municipality.

 8             A request was sent for a certain number of people to replenish

 9     wartime units.  In the centres, there was a division for wartime

10     preparations, and in the public security stations, there was a desk

11     officer in each of the stations that dealt in those things.  And in

12     keeping with the plans, we mobilised a certain number of units to

13     bring -- a certain number of men to bring units up to the strength.

14     There was a mobilisation plan, a plan according to which men were

15     mobilised.

16             Reserve policemen would be issued with uniforms in a timely

17     manner.  They would take those uniforms home.

18             In every wartime police station, there was a certain number of

19     official IDs, exactly the number that was needed by the wartime police

20     station for all its men.  Those IDs, however, did not contain any

21     personal data because the personnel changed all the time.  The numerical

22     strength remained the same, however.  In case reserve police stations

23     were activated, those IDs would have been issued to those men that were

24     at the stations at that time.

25        Q.   When the reserve police were mobilised, did the mobilised police

Page 19467

 1     reserve officers also get weapons?  Were they issued with weapons?

 2        A.   In the autumn of 1991, they were issued with weapons.

 3             JUDGE DELVOIE:  Mr. Zecevic --

 4             MR. ZECEVIC:  Yes.

 5             JUDGE DELVOIE:  -- just one moment.

 6             Mr. Bjelosevic, this is a mobilisation order by the

 7     Minister Delimustafic.  Was this mobilisation order specific to the Doboj

 8     CSB area; or was it a nation-wide mobilisation order?

 9             THE WITNESS: [Interpretation] I believe that that mobilisation

10     applied to the entire territory of Bosnia-Herzegovina.  That it was

11     carried out across the entire territory.

12             JUDGE DELVOIE:  Thank you.

13             MR. ZECEVIC:

14        Q.   [Interpretation] Mr. Bjelosevic, in autumn 1991, were there any

15     visits to your Security Services Centre by anybody from the federal SUP,

16     from their inspectors?

17        A.   Yes, they did come.  Before the check-points were set up, in

18     keeping with the minister's order, we informed federal inspectors about

19     the current security and safety situation.  Later on, they occasionally

20     paid us visits when they wanted to analyse some things together with us.

21        Q.   Could you please look at 763D1, tab 6.

22             Can you comment?

23        A.   Yes.  This is the dispatch in question that was sent by the

24     Ministry of the Interior of Bosnia and Herzegovina announcing the arrival

25     of federal inspectors.

Page 19468

 1             MS. KORNER:  Sorry, Your Honours, our LiveNote seems to have

 2     stopped working.

 3             THE WITNESS: [Interpretation] May I proceed, please?

 4             JUDGE HALL:  [Microphone not activated] Has it come up yet?

 5                           [Trial Chamber and Registrar confer]

 6             JUDGE HALL:  It's in progress.

 7             MS. KORNER:  Your Honours, I don't know if that means it's going

 8     to come back at some stage or ... or what exactly?

 9             JUDGE HALL:  Are you so handicapped as Mr. Zecevic ought not to

10     proceed.  That is the question.

11             MS. KORNER:  The trouble is I've lost -- if he could repeat for

12     me the document tab number because that didn't come out.

13             MR. ZECEVIC:  It's tab number 6.

14             MS. KORNER:  All right.

15             MR. ZECEVIC:  Well, Your Honours, I can proceed because we have

16     the LiveNote on the monitor.  It's on our computers we don't have it.

17                           [Trial Chamber and Registrar confer]

18             JUDGE HALL:  Can you see the transcript, though, Ms. --

19             MS. KORNER:  Your Honours, I can.  Yes.

20             JUDGE HALL:  [Microphone not activated] So we can proceed, I

21     suppose.

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

23        Q.   [Interpretation] Sir, you started talking about the document.

24     Can you finish, please.

25        A.   Yes.  We, as chiefs of Security Services Centres, were given some

Page 19469

 1     tasks and obligations.  We were asked to brief the federal inspectors

 2     about the security situation in the -- in the area and to put in place

 3     conditions for the functioning of those check-points in our territory.

 4        Q.   Thank you.

 5             MR. ZECEVIC: [Interpretation] If there are no objections, I would

 6     like to tender this document into evidence.

 7             JUDGE HALL:  Admitted and marked.

 8             THE REGISTRAR:  Exhibit 1D441, Your Honours.  And page 59,

 9     line 1, exhibit number is 1D440.  I misspoke; I apologise.

10             MR. ZECEVIC:

11        Q.   [Interpretation] Sir, could you please look at 765D1, tab 8.

12             I would like to invite you to comment upon this order.  Who

13     signed it, first of all?

14             Could we please look at the second page of the document.

15        A.   The document was signed by the minister of the interior,

16     Alija Delimustafic.

17        Q.   Could you please explain this dispatch for us.

18        A.   This is an order for us to prepare, and it also gives us all the

19     elements that we should include into our briefing session with the

20     federal inspectors.

21             There are bullet points for us to prepare ourselves, and that's

22     what we followed.

23        Q.   Is this order connected with the previous order that we have just

24     seen?

25        A.   Yes.

Page 19470

 1        Q.   Does this order elaborate your obligations with regard to the

 2     visit of those inspectors from the federal SUP?

 3        A.   Yes.  It provides a lot more detail than the previous one.  It

 4     actually gives a list of all the things that we needed to prepare in

 5     advance and how we should brief the inspectors.

 6             MR. ZECEVIC: [Interpretation] If there are no objections, I would

 7     like to tender this document into evidence.

 8             JUDGE HALL:  Admitted and marked.

 9             THE REGISTRAR:  Exhibit 1D442, Your Honours.

10             MR. ZECEVIC: [Interpretation] Your Honours, I have just been

11     informed by my colleagues that they still don't have LiveNote.  I don't

12     know whether that presents any problems for Ms. Korner or the

13     Prosecution.

14             Shall I continue?

15             JUDGE HALL:  I think she's indicated that she doesn't have a

16     problem.

17             MR. ZECEVIC: [Interpretation] I thank you.

18        Q.   Mr. Bjelosevic, what measures did the Ministry of the Interior of

19     the Socialist Republic of Bosnia and Herzegovina take or put in place in

20     the course of 1991, with regard to the situation?  More specifically, in

21     your CSB and probably across Bosnia and Herzegovina.

22        A.   Are we talking about the check-points or the overall situation?

23        Q.   The overall situation.  We have already discussed the

24     check-points.

25        A.   Unfortunately, I have to say that the Ministry of the Interior of

Page 19471

 1     Bosnia and Herzegovina did not undertake adequate measures, measures that

 2     would be adequate with respect to the problems that arose in the area at

 3     the time.  I even had a feeling - and I also have some arguments to

 4     support this - that Operation Check-point 1991, which had given good

 5     results, is something that they did not like, and very soon they started

 6     obstructing that operation.

 7             I would especially like to highlight the arrival of inspectors

 8     from the MUP headquarters in Sarajevo.  They had been sent by the

 9     headquarters to the area of the CSB Doboj.  Contrary to some rules, these

10     inspectors were sent to public security stations; first and foremost,

11     Bosanski Brod and Bosanski Samac.  The inspectors moved some

12     check-points, as well as the personnel, policemen who manned the

13     check-points.  We provided policemen from the level of the Doboj CSB, and

14     once these inspectors from the police administration arrived, as well as

15     from other centres, those who had been sent, these police forces were

16     sent back; whereas, they selected policemen from some other centres and

17     brought them to Samac, and later on, to Bosanski Brod as well.

18        Q.   Could you please clarify your answer.  Who sent the inspectors

19     from the MUP of the Socialist Republic of Bosnia and Herzegovina; when

20     did they arrive?

21             And you also mentioned that it was contrary to some rules.  Would

22     you elaborate on that, please.

23        A.   Normally, when the inspectors from the administration come to the

24     centre, or to a station, they are typically announced, and they come

25     either to conduct supervisory inspection of the work of the centre or the

Page 19472

 1     station, or they come in order to provide certain instructions.

 2             In this particular case, first of all, they were not announced.

 3     They did not bring them any kind of an order, be it from the minister,

 4     from assistant minister, or deputy minister.  They simply came and said

 5     they came to conduct some co-ordination activities, as they termed it

 6     initially.  As the time passed, I asked that they either produce an order

 7     on sending them to us, or a plan of work that they were supposed to

 8     conduct.

 9             THE INTERPRETER:  Interpreter's note:  Could Mr. Zecevic's

10     microphone be switched off.

11             THE WITNESS: [Interpretation] I did not receive it from them, and

12     then, later on --

13             JUDGE HALL:  Mr. Zecevic, the interpreters need you to switch off

14     your microphone.

15             THE WITNESS: [Interpretation] They did not produce either of the

16     two documents that I asked for, and this is when I asked from the

17     ministry that an explanation be given for their visit.  It took several

18     written interventions of mine --

19             MR. ZECEVIC:

20        Q.   [Interpretation] Let us show the documents and you can continue

21     with your answer.

22             MR. ZECEVIC: [Interpretation] 65 ter 768D1, tab 10.

23             THE WITNESS: [Interpretation] Jusuf Pusina sent a dispatch at

24     that point.

25             MR. ZECEVIC:

Page 19473

 1        Q.   [Interpretation] Sir, we have a document on our screens.  Would

 2     you please comment and tell us whose document it is and explain the

 3     background of the document.

 4        A.   I sent this document to the minister, to the deputy minister, and

 5     to the then-Executive Council, to the deputy prime minister for internal

 6     policy, and to the president of the Assembly.

 7             In this memo I describe the problem, the one that I have just

 8     told you about, because the visit of the inspectors meant an introduction

 9     of a parallel system in the territory under the jurisdiction of the

10     Doboj CSB.  They directly interfered in the work of the centre, in the

11     management of the centre.  They took over the SJBs and sent separate

12     reports bypassing the centre which, in a way, meant that the centre was

13     almost suspended in all of its work and it meant that a parallel system

14     was established.

15             There is another matter that I wish to bring to your attention;

16     namely, that all of these inspectors who had come, and there were a total

17     of six of them staying there, were of Muslim ethnicity and that this

18     produced a reaction, both in the SJBs that they visited, as well as among

19     the population in the area.  Because it disturbed further an already bad

20     ethnic composition among the senior management and senior levels.

21        Q.   When you say "bad ethnic composition in the senior management,"

22     what are you referring to?

23        A.   There was a rule that if a chief of SJB was of one ethnicity,

24     then the commander of that SJB was supposed to be of a different

25     ethnicity.  And depending on what the composition of the population was,

Page 19474

 1     whether there were two ethnic communities or three ethnic communities, if

 2     it was a multi-ethnic community, then the third senior position was

 3     supposed to be given to a member of the third ethnic community.  And the

 4     inspectors, with their arrival, disturbed this agreement.  And especially

 5     once the police forces were brought in from elsewhere.  That further

 6     disturbed it.

 7        Q.   Tell me, please, the problems that you just spoke about, the fact

 8     that the agreement, the structure was disturbed, that a parallel system

 9     was introduced, that the command and hierarchy in MUP was suspended and

10     that basically the CSB became powerless.  All of these things that you

11     just described to us, were those the reasons why you sent this memo or

12     were there other reasons?

13        A.   Well, precisely those reasons, the ones that I have described to

14     you.  This is what prompted me to send this memo.

15        Q.   And to whom was this memo sent?

16        A.   I believed that the problem was quite a major one, and this is

17     why I sent this memo to the minister of the interior, to his deputy, and

18     to the Executive Council of Bosnia and Herzegovina, to the deputy

19     prime minister who was in charge of internal policy, and this was a

20     problem from that domain, and I also sent the memo to the president of

21     the Assembly of the Socialist Republic of Bosnia and Herzegovina.

22        Q.   Thank you.

23             MR. ZECEVIC: [Interpretation] Unless there are objections, I

24     would like to tender this into evidence.

25             JUDGE HALL:  Admitted and marked.

Page 19475

 1             THE REGISTRAR:  Exhibit 1D443, Your Honours.

 2             MR. ZECEVIC:

 3        Q.   [Interpretation] This memo of yours that was just introduced into

 4     evidence, did it produce a response?

 5        A.   I did not receive a response, either from the minister or from

 6     his deputy.  Rather, I received a reply from Mr. Jusuf Pusina.  And to

 7     this day, I have a dilemma whether Mr. Pusina was able to intercept these

 8     memos before they reached the minister and the deputy, or whether the

 9     minister and the deputy allowed him, on purpose, to correspond with me so

10     as to avoid any responsibility on their part for such a major problem.

11     And I thought this was a major problem.  This had long-ranging

12     consequences for further work in the Ministry of Interior.

13             MR. ZECEVIC: [Interpretation] Could we see 769D1, tab 11, please.

14        Q.   Sir, could you please comment on this document.

15        A.   This is a reply, signed by Mr. Jusuf Pusina, a reply to my

16     questions, to the questions I raised.  As I have said, I did not receive

17     a reply either from the minister or his deputy.

18             In this reply, there is no information on who decided to send

19     inspectors to Bosanski Samac and Bosanski Brod.  Rather, this reply says

20     that it was the ministry as an institution that did it.  And this is why

21     I had this dilemma; that is to say, it wasn't either the minister or the

22     deputy that made this decision.  Nor does he say that he, Jusuf Pusina,

23     as assistant, made that decision.  Rather, the document speaks of the

24     ministry as a whole that made the decision.

25        Q.   Did you receive, via this document or via contacts with

Page 19476

 1     Mr. Jusuf Pusina, any other obligations?  Were you informed of any other

 2     obligations you had in relation to the inspectors who had come from the

 3     ministry?

 4        A.   They asked for a car to be placed at the disposal of

 5     Omer Stambolic as well as a policeman who would be his security detail.

 6        Q.   Thank you.

 7             MR. ZECEVIC: [Interpretation] I tender this into evidence.

 8             JUDGE HALL:  Admitted and marked.

 9             THE INTERPRETER:  Interpreter's note:  Could Mr. Zecevic's

10     microphone be switched off when not in use, please.

11             THE REGISTRAR:  Thank you.  This will be Exhibit 1D444,

12     Your Honours.

13             MR. ZECEVIC:

14        Q.   [Interpretation] Sir, could you please comment on the next

15     document.  65 ter 770D1, tab 12.

16             JUDGE HARHOFF:  Mr. Zecevic, I -- I can't help just making the

17     comments that I think the Chamber is, by now, well-informed through the

18     witness of the situation and the various attempts from the witness to the

19     ministry to control the situation that evolved slowly by the end of 1991.

20     So I don't know for how much longer you wish to pursue this -- this

21     matter, but I think it's -- it's pretty clear the picture that emerges

22     from what we have heard so far and what we have seen.

23             MR. ZECEVIC: [Interpretation] Well, Your Honours, I believe that

24     during our Defence case, we need to show -- I don't know whether I should

25     switch into English and have the witness take off the headphones so as to

Page 19477

 1     avoid any perception that I'm giving instructions to him.

 2             Would you please switch off your mikes?

 3             [In English] The point, Your Honours, is the following.  The

 4     allegation which was presenting during the Office of the Prosecutor's

 5     case is that -- that there was a joint criminal enterprise existing in --

 6     starting to exist in October 1991, and one of the aspects of it was

 7     the -- was the meeting in the -- on the 11th of February in Banja Luka.

 8     The witness was present on that meeting in Banja Luka.

 9             Now, I'm trying to establish now why, what were the reasons why

10     the witness and other people of Serbian ethnicity went to that meeting in

11     Banja Luka on the 11th of February and try to establish that this was

12     actually the only way they could cope with the -- with problems that they

13     have experienced in their work in the ministry of the Socialist Republic

14     of Bosnia and Herzegovina and that the level of inconsistencies of -- of

15     misuse of the -- of the police force and the -- and the work, not in

16     accordance with the laws and the regulations, was such that it justified

17     the meeting and the topics that were discussed at that meeting.

18             That is the aim.  And since we have the original documents from

19     that time, I -- I think only -- only proper way that would be that I

20     introduce these documents with a comment of the person who received these

21     comments [sic] and went, ultimately, to that meeting on the 11th of

22     February.

23             Thank you.

24                           [Trial Chamber confers]

25             MS. KORNER:  Your Honour, the only thing I have to say is can I

Page 19478

 1     just confirm that all of these documents, again, are ones provided by

 2     Mr. Bjelosevic.

 3             MR. ZECEVIC:  Well, some were disclosed to us by the Office of

 4     the Prosecutor [Overlapping speakers] ...

 5             MS. KORNER:  Well, I can see --

 6             MR. ZECEVIC:  When Ms. Korner says "all of them," I'm not sure --

 7             MS. KORNER:  I can see ones with ERNs which are clearly from us.

 8     But ones without ERNs, I'm taking it are produced by this witness.

 9             MR. ZECEVIC:  Well, yes.

10             MS. KORNER:  Thank you.

11             MR. ZECEVIC:  Let me consult, please.

12                           [Defence counsel confer]

13             MR. ZECEVIC:  I was just informed by my assistant that there are

14     a number of documents which we uploaded and then they were given the

15     ERN numbers afterwards and then returned to us from the Office of the

16     Prosecutor side.  But, Ms. Korner, Ms. Savic will give you the

17     explanation to the detail, why she claims this is the situation.

18             JUDGE HALL:  In any event, I think everything we've seen so far,

19     either documents that the witness generated or received by him whether --

20     or otherwise that he could speak to authoritatively.  So I don't -- the

21     apprehension that is implicit in Ms. Korner's question --

22             MS. KORNER:  [Overlapping speakers] ... no, no, can I explain why

23     I'm asking this each time.

24             This, as you all know -- I'd ask the witness to take his

25     earphones off.

Page 19479

 1             As Your Honours know because it has been uploaded, this

 2     interview -- this witness was interviewed in 2004.  I would think about

 3     1/20th of the documents which are now emerging from him were actually

 4     provided to us in that interview.

 5             MR. ZECEVIC:  With all due respect, the witness was interviewed

 6     on both occasions as a suspect.

 7             MS. KORNER:  Yes.  But his lawyer turned up, who was present, as

 8     Mr. Zecevic knows, with a selected handful of documents.  That's why I'm

 9     asking on each occasion to confirm that this is what he has now provided.

10             JUDGE HALL:  Let's proceed.  Thank you.

11             MR. ZECEVIC:  Thank you, Your Honours.

12        Q.   [Interpretation] Can you hear me, sir?

13        A.   Yes.

14        Q.   Sir, my question was that you should clarify this document behind

15     tab 12, 770D1.  Can we have your comments on it.

16        A.   This is yet another document drafted by Mr. Pusina following a

17     number of interventions insisting on receiving answers to the question as

18     to why the inspectors were sent, who, upon their arrival there, took

19     charge of what was happening in these stations and in -- in a way, in the

20     centre as well.

21             THE INTERPRETER:  Can Mr. Zecevic please switch his microphone

22     off.

23             THE WITNESS: [Interpretation] The suggestion was that he should

24     assign a technical secretary to work with me, although there was a civil

25     servant who had been working there previously but she was on maternity

Page 19480

 1     leave.

 2             In this letter, Mr. Pusina said that what was done was done under

 3     the instructions from the minister.  I had asked on several occasions

 4     that I get in touch with Minister Delimustafic because I wanted to talk

 5     to him about this issue.  I wanted to have a direct contact with him.  No

 6     answer was forthcoming.  Let me emphasise that throughout that time,

 7     which was almost a year, Minister Delimustafic did not hold a single

 8     meeting of the collegium to which he would invite all the chiefs of

 9     centres and which would have enabled us to discuss the problem together

10     and which would have enabled us to report on the events taking place on

11     the ground directly.

12        Q.   Thank you.

13             MR. ZECEVIC: [Interpretation] Can we have the document admitted,

14     please.

15             JUDGE HALL:  Yes, admitted and marked.

16             THE REGISTRAR:  Exhibit 1D445, Your Honours.

17             MR. ZECEVIC:

18        Q.   [Interpretation] Sir, please have a look at document 771D1, which

19     is tab 13.  It has to do with the same issue, so can you please explain

20     what it was about.

21        A.   Yes.  This is my dispatch which I sent to the minister and his

22     office, to his deputy, to Assistant Jusuf Pusina and to Assistant

23     Momcilo Mandic.  The purpose of the letter was to provide them with

24     information, since the situation in the two municipalities, namely, Samac

25     and Bosanski Brod, were quite dramatic by that time.  I drew their

Page 19481

 1     attention to -- or, rather, alerted them to what might follow.  There

 2     might be unrest, protests, et cetera.

 3             I asked that they withdraw Mr. Stambolic from Doboj because he

 4     was suspended at the time as there was a disciplinary procedure pending

 5     against him, and here I state, yet again, my dilemma as to whether

 6     Minister Delimustafic was aware of it all or not.  I tried to repeatedly

 7     to notify him of these problems directly.

 8        Q.   Tell me, Mr. Bjelosevic, if my understanding is correct.  The

 9     inspector who was sent out from the MUP headquarters, Stambolic, this one

10     Omer Stambolic, your impression was that at the time he was in the area

11     of your CSB, there was a disciplinary procedure pending against him and

12     that he was, in fact, suspended?

13        A.   Precisely so.

14             MR. ZECEVIC: [Interpretation] Can this document be admitted,

15     please.

16             JUDGE DELVOIE:  Just one moment, Mr. Zecevic.  I would like to

17     ask the witness to read, in Serbian, the sentence:

18             "For the above reasons, the police officers sent to

19     Bosanski Samac," and so forth, and so on.

20             Could you read that in Serbian, please?

21             "For the above reasons the police officers sent to the

22     Bosanski Samac SJB," and to the end of the sentence so that we'll get a

23     translation of what you are reading?

24             THE WITNESS: [Interpretation] "For the above-mentioned reasons,

25     the policemen who were posted or sent to the SJB Bosanski Samac will be

Page 19482

 1     withdrawn from their service in the SJB Bosanski Samac."

 2             JUDGE DELVOIE:  Thank you.

 3                           [Trial Chamber confers]

 4             JUDGE DELVOIE:  I -- Mr. Bjelosevic, I have a -- pardon?

 5                           [Trial Chamber confers]

 6             JUDGE HALL:  Admitted and marked.

 7             THE REGISTRAR:  Exhibit 1D446, Your Honours.

 8             JUDGE DELVOIE:  My question is this:  When it says, "For the

 9     above reasons the police officers will be withdrawn," are you asking the

10     minister to withdraw them, or are you -- or is this your decision to

11     withdraw them?  It's a little bit confusing in -- in the context of the

12     dispatch.

13             What do you mean by "they will be withdrawn"?

14             THE WITNESS: [Interpretation] The composition of the police

15     personnel that arrived from other areas included policemen from the

16     stations under the Doboj centre.  While those mixed check-points were

17     still in effect, in other words, while the Punkt 91 or Check-point 91

18     operation was still ongoing, the situation was brought under control.

19     The tensions eased and the security situation in general took a turn for

20     the better significantly.

21             JUDGE DELVOIE:  Let me --

22             THE WITNESS: [Interpretation] And then --

23             JUDGE DELVOIE:  Let me interrupt you for just one moment.  The

24     police officers sent to Bosanski Samac is not referring to Hodzic and

25     Panjek?  It is referring to the other police officers that they brought

Page 19483

 1     to Bosanski Samac; is that right?  So that's where my misunderstanding

 2     was.  Those police officers that -- this is not referring to Hodzic and

 3     Panjek?

 4             THE WITNESS: [Interpretation] Yes.

 5             JUDGE DELVOIE:  And this is your decision to withdraw those extra

 6     policemen who did not come from Bosanski Samac.  It is your decision to

 7     withdraw them; is that right?

 8             THE WITNESS: [Interpretation] Yes.  To avert the protests that

 9     were announced.  We wanted to avoid having mass-scale unrest.

10             JUDGE DELVOIE:  Okay.  So that's clarified.  Thank you.

11             MR. ZECEVIC:

12        Q.   [Interpretation] We'll look at one other document before we stop

13     for today.  779D1, behind tab 15.  Tab 15.

14             This is another document by Mr. Pusina.  Can we have your

15     comments on it.

16        A.   This letter did not change the situation substantially or solve

17     it.  Yet again, Mr. Pusina sends out inspectors in their stead.  As you

18     can see Jusuf Vatres from the Sarajevo CSB is going do come; whereas, we

19     do have inspectors within the police service of the CSB Doboj.  Obviously

20     there was something that they wanted to achieve with this, which only he

21     and his associates were privy to, although it wasn't difficult to draw

22     conclusions.  Panjeta would be leaving, therefore, and he would be

23     replaced by Inspector Jusuf Vatres.  So they would change, but the ethnic

24     structure, the ethnic makeup would remain roughly the same as would the

25     duties.

Page 19484

 1        Q.   Thank you.

 2             MR. ZECEVIC: [Interpretation] If there are no objections, I'd ask

 3     that the document be admitted.  And I would stop here for today.

 4             JUDGE HALL:  Yes, admitted and marked.

 5             THE REGISTRAR:  As Exhibit 1D447, Your Honours.

 6             JUDGE HALL:  Mr. Bjelosevic, you, having been sworn -- we're

 7     about to take the adjournment for today and we'll resume in this

 8     courtroom at 9.00 tomorrow morning.  Having been sworn as a witness in

 9     this matter, you cannot have any communication with counsel from either

10     side, the side that's calling you or the side that is examining you,

11     until after you would have been released by the Chamber.  Furthermore, in

12     such communication as you may have with persons -- anybody outside of the

13     Chamber apart from counsel, you cannot discuss your testimony.

14             Do you understand what I just said?

15             So you're now excused to return tomorrow morning at 9.00.

16             We take the adjournment for the day.

17             MS. KORNER:  Your Honour, may I just raise one technical

18     administrative matter.  Ms. Savic has very kindly --

19             JUDGE HALL:  I'm sorry, may the witness be escorted out.

20             MS. KORNER:  Oh, yes, the witness can go

21     [overlapping speakers] ...

22             JUDGE HALL:  Usher, yes.  Yes, please continue.

23                           [The witness stands down]

24             MS. KORNER:  Ms. Savic has kindly pointed out that some of the

25     documents we've notified to use for cross-examination are already on

Page 19485

 1     their list.  We attempted to do a check.  Theirs don't have ERN numbers

 2     in the same -- so we can't check against ERN numbers unless, quite by

 3     chance, they have them and there are many copies of the same document.

 4     But their spreadsheet does not have the date.  We put the date on all of

 5     ours, and the -- and apparently the reason is because that wasn't a

 6     requirement, but it makes it easier when we're looking at their list to

 7     prevent us trying to put in the same documents and, therefore, having

 8     double exhibits if the column -- there's a column added to their

 9     spreadsheet which has the date.  It's still not perfect, but it will make

10     it easier for us to try and check against the two, because, otherwise, we

11     are going to have -- end up with us trying to exhibit the same document

12     that's already been a Defence exhibit.

13             JUDGE DELVOIE:  So the document's date is --

14             MS. KORNER:  Yes, there's a -- at the moment --

15             JUDGE DELVOIE:  -- in the document's description is in the

16     wrong -- in the wrong column.

17             MS. KORNER:  Yes.  It makes it more difficult to search.  Where

18     if you've got a date, you can just simply search and see if the dates are

19     the same.  I mean, as I say, I don't think it's going to be perfect, but

20     it'll help.  And the reason I'm raising it with you is because I

21     understand your only order was that it should be -- the 65 ter number, or

22     whatever, so I'd ask that it simply includes the date.  It may not even

23     need an order.

24             JUDGE HALL:  So this is something we could leave to the attorneys

25     to sort out outside the court.

Page 19486

 1             MS. KORNER:  Yes.  But I -- the reply came [indiscernible] I'm

 2     raising it.  And, Your Honours, there's one other thing and I raise it --

 3     simply, Your Honours, may recall that each and every one of our

 4     witnesses, before they started their evidence, was given a warning about

 5     the consequences of perjury, as it so happens, wherever this witness

 6     is -- our witnesses came from.  That warning wasn't given, and I

 7     merely --

 8             JUDGE HALL:  The oversight is entirely mine.  Thanks for the

 9     reminder, Ms. Korner.

10             MS. KORNER:  Thank you.

11             JUDGE HALL:  And I would see that whether, practically speaking,

12     it is something that I can correct or patch tomorrow morning before the

13     witness resumes.

14             MS. KORNER:  Yes.  Well, Your Honours, I only raised it because

15     we just noted it this morning.

16             JUDGE HALL:  Thank you.

17                            --- Whereupon the hearing adjourned at 1.50 p.m.,

18                           to be reconvened on Wednesday, the 13th day of

19                           April, 2011, at 9.00 a.m.