Tribunal Criminal Tribunal for the Former Yugoslavia

Page 20812

 1                           Wednesday, 18 May 2011

 2                           [Open session]

 3                           [The accused entered court]

 4                           --- Upon commencing at 9.04 a.m.

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

 6     everyone in and around the courtroom.  This is case number IT-08-91-T,

 7     The Prosecutor versus Mico Stanisic and Stojan Zupljanin.

 8             JUDGE HALL:  Thank you, Madam Registrar.  Good morning to

 9     everyone.  May we have the appearances, please.

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

11     Alexis Demirdjian and Crispian Smith for the Prosecution.

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

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

14     Stanisic Defence this morning.  Thank you.

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

16     Aleksandar Aleksic appearing for Zupljanin Defence.

17             JUDGE HALL:  Thank you.  And if there are no housekeeping --

18             MS. KORNER:  Just one, Your Honours, and that is the question of

19     scanning the diary, so that it's quite clear.  We've spoken to the

20     evidence unit, it's going to take, because of staffing problems, a couple

21     of days to do it so what we propose to do, we've brought them back for

22     the witness and at the end of each day we'll take them away and try and

23     get them scanned.

24             JUDGE HALL:  Thank you.  And I'm resisting the opportunity to

25     say -- to make any comment on the fact that the OTP is experiencing

Page 20813

 1     staffing problems.

 2             Could the usher please -- I see he has gone to escort the

 3     witness.

 4             Ms. Korner, perhaps you could repeat in the hearing of the

 5     witness when he comes the delay -- reason for the delay in getting the

 6     documents back to him.

 7             MS. KORNER:  Yes.  But without the staffing problems.

 8                           [The witness takes the stand]

 9             JUDGE HALL:  Good morning, to you, sir.  Before I invite

10     Ms. Korner to resume her cross examination, I remind you you are still on

11     your oath.

12                           WITNESS:  ANDRIJA BJELOSEVIC [Resumed]

13                           [Witness answered through interpreter]

14             JUDGE HALL:  Yes, Ms. Korner.

15             MS. KORNER:  Your Honour, first of all, we'll give Mr. Bjelosevic

16     his original notebooks back.

17                           Cross-examination by Ms. Korner:  [Continued]

18        Q.   Mr. Bjelosevic, can I explain, we wanted to copy them properly

19     but it's going to take a little time.  So what we are going to ask you to

20     do is at the end of each day, if you leave them with us so they can be

21     copied.  It will take about two days.  I see you shrugging, but you agree

22     with that, you are happy?

23        A.   Yes.

24        Q.   And just one final the matter, the documents that you brought

25     with you yesterday which you hadn't provide copies of before, leaving

Page 20814

 1     aside the CDs, are those statements taken by Inspector Solaja about the

 2     incident involving the Mice in Teslic?

 3        A.   Yes.

 4        Q.   Because it wasn't entirely clear exactly what they were.

 5             I want to go back, please, then to where we left off yesterday,

 6     namely discussing membership of the SDS.  You told us in interview, and I

 7     believe in court as well, that although you would be a member of the

 8     communist party, you had not joined one of the nationalist parties which

 9     sprung up in -- for the purpose of the 1990 elections; that's correct, is

10     it?

11        A.   That's correct.

12        Q.   You equally told us that you were sympathetic to the aims of the

13     SDS which was to remain in the former Yugoslavia.  However, at the time

14     the SDS was founded, that wasn't a consideration, was it, because at that

15     stage, nobody was suggesting the split of the various republics?

16        A.   Their programme was defined from the very point of the foundation

17     of the party and their aims were publicised and that was already a time

18     when there was talk about the so-called disassociation of Yugoslavia, and

19     on the top of that list was Slovenia.  These programme aims were from the

20     very beginning placed in the public domain.

21        Q.   After you became the head of the CSB Doboj in about May of 1991

22     was there at least one occasion when Radovan Karadzic visited Doboj?

23             THE INTERPRETER:  Could the counsel please switch off the mike

24     while the witness is speaking.  Thank you.

25             THE WITNESS: [Interpretation] I'm not sure, believe me.  It is

Page 20815

 1     possible but I don't remember any such event.

 2             MS. KORNER:

 3        Q.   An occasion when you -- an occasion when you and Mr. Ninkovic,

 4     who was the head of the SDS, were seen together with Mr. Karadzic, did

 5     that ever happen?

 6        A.   No.

 7        Q.   Had you ever met Mr. Karadzic?

 8        A.   Yes, but never with Ninkovic.

 9        Q.   Where and -- firstly, how often have you met Mr. Karadzic?

10        A.   In person?

11        Q.   In person.

12        A.   I could hardly remember after such a long time.

13        Q.   Well, you have a pretty clear memory of most things,

14     Mr. Bjelosevic, as we've already seen.  Surely you remember how often you

15     met the president of the Republika Srpska.

16        A.   I used to be in the same locations where the president of the

17     Republika Srpska was, those were different locations.  However, how many

18     times that took place, I honestly cannot remember.  What you mentioned a

19     minute ago about the meeting with Ninkovic and myself, I know that that

20     didn't happen because otherwise I would have remembered.

21     President Karadzic used to come to Brod.  He sometimes came to Derventa

22     as well.

23        Q.   Yes, I'm sorry --

24        A.   Therefore, we had certain obligations in order to provide

25     security details and things like that, but I can really not remember on

Page 20816

 1     how many occasions that took place.

 2        Q.   All right.  Well, let me ask you about some things --

 3             THE INTERPRETER:  Microphone please.

 4             MS. KORNER:  Can I leave it on, please?

 5        Q.   Let me ask you, please, sir, about some things that were said

 6     about you and see whether you can assist us.

 7             MS. KORNER:  Could we have a look, please, at the document which

 8     is -- its 65 ter number is 20000 and it's tab 2 of our documents.  You

 9     haven't got a binder, Mr. Bjelosevic.

10        Q.   Now, this is an intercept of a conversation between Mr. Karadzic

11     and Branko Ostojic.  Did you know Mr. Ostojic?

12        A.   I didn't know him personally, but if I'm not mistaken, he was in

13     the government.  However, I don't know which position he held.

14        Q.   We'll come back to this in a minute.  It's on the 23rd of July of

15     1991, and Mr. Ostojic is speaking to Karadzic, you can see, it's not

16     altogether clear who, but asked about that guy, and you said:

17             "Doboj and Banja Luka and Gorazde."

18             And Karadzic said:

19             "Yes."

20             Branko Ostojic says:

21             "Is there someone in Doboj, a name of a person he could call?"

22             And Mr. Karadzic says:

23             "Andrija Bjelosevic."

24             MS. KORNER:  And if we go, please, to the next page in both B/C/S

25     and English.  I think it's the bottom of the B/C/S, sorry, could we go

Page 20817

 1     back to the first page.  Sorry.

 2        Q.   Karadzic says:

 3             "Yes, because they have a procedure for everything to go

 4     through...," whatever it means, "all right."

 5             Karadzic says:

 6             "Just get and Andrija."

 7             Ostojic says:

 8             "He is a good man."

 9             Karadzic:

10             "Excellent, we need a professional."

11             Mr. Ostojic:

12             "He's a real one."

13             Karadzic:

14             "We need a professional and he is 100 per cent professional."

15             Now, this is July, a couple of months after you've been appointed

16     as CSB Doboj.  Do you have any idea on what basis Mr. Karadzic is calling

17     you Andrija and saying what an excellent fellow you are?

18        A.   As far as I can see here, it is Ostojic who is referring to

19     someone as a proper guy or the right guy.  And, yes, he did ask Karadzic

20     who can this guy report to, if I understand properly, but if I were to

21     find any logic in this, since there is mention also here of this guy

22     being the right one and a true professional and then President Karadzic

23     says, Yes, excellent, we do need professionals.  So if I were to put this

24     picture together, that probably referred to someone to be admitted into

25     service or somewhere else.  If I'm not wrong in drawing these kind of

Page 20818

 1     conclusions because this is the first time I've seen this document and --

 2        Q.   I'm sorry.  I think you misunderstood the question.  You can't

 3     remember how many times you met Karadzic but he is calling you Andrija in

 4     July of 1991, and says that you are a professional --

 5             MR. ZECEVIC:  I am sorry, Your Honours, I don't understand where

 6     Ms. Korner finds this reference to calling -- Karadzic calling the

 7     witness professional.  This is a complete misinterpretation of the

 8     document and the witness explained what the document says.  I don't

 9     see -- I've been trying to find out in the English translation, but the

10     English translation appears to be genuine, but it's obvious that it's

11     referred to another person.

12             MS. KORNER:  Well, I am sorry, this is a matter of comment and an

13     improper one, I may say, Mr. Zecevic.

14             But my reading of it is that Mr. Karadzic says:

15             "Just get Andrija."

16             Ostojic says:

17             "He's a good man."

18             Karadzic:

19             "Excellent, we need a professional."

20             Ostojic:

21             "He's a real one."

22             Now ...

23             MR. ZECEVIC:  Ms. Korner, you have to read the whole document.

24             MS. KORNER:  I've read the whole document.

25             MR. ZECEVIC:  No.

Page 20819

 1             MS. KORNER:  Right.  I don't want to waste time on unnecessary

 2     argument.  We've got enough to get through as it is.

 3        Q.   Explain to me, would you please, Mr. Bjelosevic, how it is that

 4     Karadzic in July of 1991 is calling you Andrija?

 5        A.   For God sake, that's my name.  I don't see anything here.  That's

 6     my name and I really don't understand.

 7        Q.   Yes, but if he didn't know you at all in 1991 in July, wouldn't

 8     he be calling you Andrija Bjelosevic in full or Bjelosevic or

 9     Mr. Bjelosevic?

10        A.   You can see here there's my full name mentioned twice and then

11     further down below there's only my first name.  I am not saying that

12     Mr. Karadzic didn't know the people on the ground who were discharging

13     some important duties, and I believe that the head of CSB is an important

14     position.

15        Q.   Right.  Between -- well, by July of 1991, shortly after you had

16     been appointed to Doboj CSB, did you know and had you -- sorry, had you

17     met Mr. Karadzic?

18        A.   In person?

19        Q.   In person.

20             THE INTERPRETER:  Could the witness please repeat the answer.

21     The interpreters couldn't catch it.

22             THE WITNESS: [Interpretation] I don't think that by that time I

23     had an opportunity to meet Karadzic in person.  Of course, I knew who he

24     was and what he was doing and things of that nature, but, if I remember

25     correctly, there was no meeting in person by that time with him.

Page 20820

 1             MS. KORNER:

 2        Q.   Had you spoken to him on the telephone?

 3        A.   Yes, I spoke with him on the telephone, but I cannot remember at

 4     this moment when that happened.

 5        Q.   And why were you speaking to Mr. Karadzic?

 6        A.   If I remember correctly, the first time, I think, had to do with

 7     my appointment to the position of the head of the Security Services

 8     Centre because Mr. Ninkovic reacted very overwhelmingly from the very

 9     beginning, and I postponed, or rather, I did not accept to proceed with a

10     hand-over with the previous head Nikolic knowing what it means if you

11     don't have the approval of the political circles and that could create

12     problems.  Then, maybe two days later, I received a call from

13     Mr. Karadzic from the office of the political party, that he told me that

14     I should ignore the opinion of the local politicians and that I should

15     accept what had been ordered by the MUP to be done.

16        Q.   That's the situation, isn't it, that went throughout 1991, that

17     unfortunately, presumably for a professional police officer, politics,

18     nationalist politics had entered into the MUP; that's right, isn't it?

19             THE INTERPRETER:  Could the counsel please switch off the mike.

20             THE WITNESS: [Interpretation] I didn't understand this correctly,

21     whether it's a bad translation or whether it's some confusion between

22     nationalism and national politics.  Could you please be more specific.

23             MS. KORNER:

24        Q.   Yes, from what you've told us about having to ring Mr. Karadzic

25     about your appointment which should have been entirely an internal MUP

Page 20821

 1     matter, you are describing, are you not, a situation which prevailed

 2     through 1991, namely that politics, and by politics, I mean nationalist

 3     politics, had entered into the MUP?

 4        A.   The only wrong statement is that it was me who called

 5     Mr. Karadzic.  I didn't call him.  It was the other way around.  I

 6     received a call and that was a very prominent feature when it had to do

 7     with the personnel of all ethnic groups.  The local politicians had their

 8     respective favourite and that applied to the personnel from all the three

 9     communities, the Serbs, the Muslim and the Croat.  And maybe it would be

10     advisable if we clarified this in more detail.

11        Q.   No, I'm sorry, Mr. Bjelosevic, I really have a lot to get

12     through.  I accept entirely that it's not only the SDS, it is the HDZ and

13     the SDA who also are bringing politics into the MUP.  Now, unless you

14     really feel that something else needs to be said, can we move on because

15     I do have a lot to get through.

16        A.   I really think that we should do this for the sake of clarity.  I

17     said earlier that Milan Ninkovic was the preferred candidate.  However,

18     since this had not been endorsed by the MUP, Mr. Ninkovic and the people

19     around him were dissatisfied from the very beginning and they reacted

20     against me which prompted me to call Mr. Zepinic because I had known him

21     from before, and I told him that there was a problem and that

22     Mr. Ninkovic was the preferred candidate.

23             Mr. Zepinic said also that I should take no notice of that, that

24     I should assume my duties and that as far as the political problems were

25     concerned, he was going to have certain talks within certain circles and

Page 20822

 1     that after that I should report to my duty station.  After that, I

 2     presume that Mr. Zepinic contacted Mr. Karadzic which was followed by the

 3     call from Mr. Karadzic because that is when I was told that I should

 4     assume my position.

 5        Q.   Yes.  I want to move on, please.

 6             MS. KORNER:  Could we have a look, please, now at the next

 7     document which is tab 3, please.  Sorry, it's 65 ter 2001.  20001.

 8        Q.   This is roughly two and a half weeks later.  This is an intercept

 9     of a conversation between Karadzic and a man called Neso, whoever that

10     may be.

11             And Neso, at the bottom of the page in English, says:

12             "What I wanted to say to you was, I said, I should send somebody

13     to Doboj, this Bjelosevic.  He says he has some news for you."

14             Karadzic says:

15             "Bjelosevic?"

16             MS. KORNER:  Can we go to the second page in English.

17        Q.   And then Neso says:

18             "Yes, to send somebody in the morning by car to his place," he

19     says, "you can't possibly like it this."

20             And Karadzic says:

21             "He can't come, can he."

22             Neso says:

23             "He can't.  Somebody," he says, "should come over to him ..."

24             MS. KORNER:  I think we need to go to the next page in B/C/S.

25        Q.   And there's a conversation about a man called Micevic.

Page 20823

 1             And then Karadzic at the bottom says:

 2             "We'll see."

 3             And Neso says:

 4             "He tells me it's very important and to pass it on to you."

 5             First of all, do you know who this man Neso is?

 6        A.   I don't know.  I'm trying to put this all together into a logical

 7     whole.  This is the first time I see this.  I cannot understand who Neso

 8     might be and what this is all about.

 9        Q.   Well, can you think of any reason why in August of 1991, why you

10     so urgently needed to give some news to Mr. Karadzic?

11        A.   I have no idea what this might be, and I do not remember that I

12     sent any kind of information in that period.

13        Q.   You see, Mr. Bjelosevic, were you close to the political

14     leadership of the SDS?

15        A.   Well, you saw from that document what my standing with them was

16     like.  I was under permanent pressure, and I think that this culminated

17     sometime in December 1992 when at the meeting of the Municipal Assembly a

18     few members of the Municipal Assembly had been prepared in a way to

19     degrade my work and my position.

20        Q.   I'm not talking about the Doboj SDS, Mr. Bjelosevic, I'm talking

21     about the leadership at the top of the party, that is to say, Karadzic,

22     Stojic, Plavsic, Zepinic at that stage?

23        A.   I have known Mr. Zepinic since before the war.  As for the other

24     people you mentioned from the leadership, I absolutely had no, how should

25     I put this, close contacts or any special contacts except when somebody

Page 20824

 1     would call me.  I just remembered that sometime in the summer of 1991

 2     Mr. Koljevic called me as well.  Perhaps that could be linked to that

 3     telephone conversation, but I truly cannot remember who Neso is.  The

 4     name doesn't ring a bell at all.  Mr. Koljevic called me, the late

 5     Mr. Koljevic called me, in relation to what had happened in

 6     Slavonski Brod.  If you allow me, perhaps I could explain that, perhaps

 7     that has something to do with it.  I'm really doing my best to find some

 8     logic, some connection, but I am not sure that that is it.  In Slavonski

 9     Brod --

10        Q.   No, no, this is August 1991 so that has got nothing to do with

11     what happened in Slavonski Brod, has it?  This conversation?

12        A.   Well, I don't know.  I'm trying to see what this might be linked

13     to.  And what crossed my mind just now is what happened in Slavonski Brod

14     in the summer of 1991.  That is when I received a call in relation to

15     what had happened.  It was the late Koljevic who called me.

16        Q.   All right.

17        A.   Perhaps that was it.  But I cannot remember who Neso is and who

18     that might be.  I really don't know.  However, I remember this event and

19     I know that there were a few calls in relation to that, but the first

20     person to call me about this was the late Mr. Koljevic.  He called and

21     asked me about what had happened in the settlement of Bjelis.  That is a

22     settlement that came into being when the population from the right bank

23     of the Sava river moved into Slavonski Brod in order to be protected from

24     floods and that is when that settlement had been blocked.

25        Q.   All right.

Page 20825

 1        A.   And then all of these people were arrested, brought into custody,

 2     and I was asked whether I could find out what this was all about.  I went

 3     to Bosanski Brod then and I spoke to Chief Pranjic, and I went with him

 4     to Slavonski Brod as well to see Mr. Dedic, the chief of the police

 5     administration.  Perhaps that is what this was all about.  I don't know

 6     what else it could have been though.  At that point in time, we did have

 7     some talks there.

 8        Q.   I simply am asking you, and you can say yes or no,

 9     Mr. Bjelosevic, whether or not you were -- and whether or not you were a

10     member of the SDS, you were close to the political leadership of the SDS

11     at the top level?

12        A.   I was not.

13             THE INTERPRETER:  Interpreter's note:  Could all other

14     microphones please be switched off.  We cannot hear the witness.  We did

15     not hear the beginning of the sentence.

16             THE WITNESS: [Interpretation] ... by the members of the

17     Presidency of the BH.  I remember that Koljevic contacted me.  I remember

18     that once or twice Mrs. Plavsic contacted me as well, if I remember

19     correctly, but as members of the BH Presidency.

20             MS. KORNER:

21        Q.   And you cannot remember how many times --

22             MR. ZECEVIC:  I am sorry, Ms. Korner, the interpreter's note says

23     that the first part of the answer was not important, and I think it's

24     important because he gave the answer to your question.

25             MS. KORNER:  Amazing.

Page 20826

 1        Q.   All right.  I'm told the first part of your answer wasn't

 2     interpreted.  Could you tell us, please, what you said.  My question was,

 3     let me repeat it, and it can be answered in one sentence, Mr. Bjelosevic,

 4     believe me:  Were you close to the political leadership of the SDS at the

 5     top level?

 6        A.   No.

 7        Q.   Now, one further question on this business of your contacts with

 8     the top.

 9             MS. KORNER:  Can we look, please, at document P198 which is

10     tab 11.

11        Q.   Right.  These are the minutes of -- it seems to be a stenographic

12     record, but there's two separate documents, but this is the one I want

13     you to look at the for the moment, of the Assembly of the Serbian people

14     on the 24th of March, 1992.

15             MS. KORNER:  Can we go, please, to page 4 in English and page 5,

16     I think, in B/C/S -- no, page 4 in B/C/S, please.

17        Q.   This is the election of the members of the government of the

18     Serbian Republic.  And we need to go to the next page in both B/C/S and

19     English.  This is where Djeric proposes Mico Stanisic of the minister of

20     foreign affairs.

21             MS. KORNER:  Then could we go to the next page in both English

22     and B/C/S.

23        Q.   Now, this is a document you've seen before, isn't it,

24     Mr. Bjelosevic?

25        A.   No, I really haven't seen it until now.

Page 20827

 1        Q.   It was shown to you, wasn't it, in interview in 2004 by

 2     Mr. Sebire?

 3             THE INTERPRETER:  Interpreter's note:  We did not hear the

 4     witness.

 5             MS. KORNER:

 6        Q.   Your answer wasn't recorded.  I don't know why this is, but

 7     there's a real difficulty in the mike picking up your voice, I don't know

 8     whether they can be adjusted.  Could you repeat your answer, please,

 9     Mr. Bjelosevic.

10        A.   I do not recall having seen this before, that's what I said.

11        Q.   All right.  Well, I'm going to take you to the bit in the

12     interview at the moment.

13             Mr. Djuric, whoever he may be, suggests:

14             "On behalf of the Municipal Board of the SDS, I would like to

15     suggest a candidate who does not come from Prnjavor, but from Doboj.  I

16     refer to Mr. Andrija Bjelosevic, a very competent and honourable man."

17             Jovo Mijatovic, I assume you know who he was:

18             "Considering the present state of affairs in the MUP, it would be

19     a good idea if the candidate addressed the Assembly and said a few words

20     about it."

21             Now, do you know who Mr. Djuric was?

22        A.   I do, he was an MP from Prnjavor.

23        Q.   And was he somebody that you had friendly relationship with?

24        A.   No, we just knew each other.  I just knew who the man was.  We

25     did not have any kind of a personal or friendly relationship.

Page 20828

 1             MS. KORNER:  Can we then go, please, to page 9 in English.

 2     Mico Stanisic then makes a speech which I don't think we need trouble you

 3     with.  Page 9 in English and 8 in B/C/S.

 4        Q.   Srdjo Srdic says:

 5             "I am a very close and good friend of Mr. Bjelosevic.  I do not

 6     understand, however, why we should start to discuss new suggestions ...,"

 7     et cetera.

 8             Who is Mr. Srdic?

 9        A.   Mr. Srdic was an MP from Prijedor.  I don't know since it's only

10     the last name that is involved, maybe it refers to the late

11     Milovan Bjelosevic, he was no friend of mine, and I just note that he was

12     an MP.  I don't think that this had to do with me, what it says here,

13     that he is a great friend of Bjelosevic's because we were not friends.  I

14     just knew Mr. Srdic as an MP.  He was considerably older than myself and

15     I really don't think that this has anything to do with me, if you thought

16     that it was about me.

17             May I just comment upon Mr. Djuric's proposal, too.  I'm honoured

18     by that kind of praise.  And you saw that in that letter and decision of

19     the regional SDS board that they also say that they are not challenging

20     my professional or moral qualities but that I'm not their representative.

21        Q.   Well, going back to the reference by Mr. Srdic, who was, in fact,

22     not only assembly man but the leader, was he not, of the SDS in Prijedor?

23     That's right, isn't it, until he was replaced by, forgot the man's name

24     now.

25        A.   I don't know about him being in the top echelons of the SDS.  I

Page 20829

 1     just know him as an MP.

 2        Q.   Replaced by Mr. Miskovic, I think it was.  Did you know him?

 3        A.   No.

 4        Q.   All right.  But going back just very brief to this quote because

 5     I don't want it to get too buried in it, it's clearly referring to you

 6     isn't it.  Because it says:

 7             "I'm a close and very good friend of Mr. Bjelosevic.  I do not

 8     understand, however, why we should start to discuss new suggestions when

 9     the matter falls in the competence of the prime minister designate."

10             And this is all about the suggestion that -- of who should be

11     minister of internal affairs.  So do you accept he is clearly referring

12     to you and not to your cousin?

13        A.   I would not agree with you because this seems to me to be a

14     response to what somebody else had said during the debate.  I'm really

15     not familiar with the details, but it is possible that the late

16     Milovan Bjelosevic said something when he took part in the debate.

17     Perhaps he relied on Djuric's proposal.  Because how could he mention me

18     as an excellent friend of his when that was absolutely not the case?  As

19     for Mr. Srdic, in person, I may have seen him only three or four times in

20     my life.  However, I did see him on television when sessions of

21     parliament were telecast and he often took part in the debate.

22        Q.   All right.  Well, I don't propose to pursue this any further.  I

23     want to look next, please, with you, Mr. Bjelosevic, at the events, some

24     of the major events which -- about which you've said nothing during the

25     course of your testimony to -- when Mr. Zecevic was asking you questions,

Page 20830

 1     which surrounded the break-up in the MUP.

 2             Now, you talked a lot about what you called the parallel

 3     structure that was being set up by the SDA or the HDZ within the

 4     Socialist Federal Republic MUP.  For example, at page 19451.  In fact,

 5     this was in answer to a question from Judge Harhoff, and this was to do

 6     with the Bosanski Brod-Slavonski Brod discussions:

 7             "At the time, there existed a certain amount of co-ordination,

 8     and there were plans between certain people in the Bosanski Brod police

 9     station and the police administration in Slavonski Brod; that is to say,

10     there was a parallel structure."

11             And then later, you were talking about, at page 19455:

12             "Stations establishing direct communication with the personnel

13     administration and some of the chiefs and pointed in violation of some of

14     the regulations, and gradually it all gained the hallmarks of a shadow

15     parallel system which caused the whole entire system to be undermined."

16             And there were other quotes as well.

17             You were aware, weren't you, however, that the SDS was also

18     planning its own parallel system within the MUP?  The MUP, certainly by

19     the end of 1991, was already beginning to be divided, wasn't it?

20        A.   What you quoted is something I explained sufficiently when I

21     spoke at the time and I supported it with documents.  You will see from

22     these remarks made by Prkacin on television that he confirms that.  As

23     for the break-up of the MUP that you referred to just now, I don't know

24     where you see the Serbian side doing something parallel in 1991.  I did

25     not see any such thing, at least not in the area where I was chief.

Page 20831

 1        Q.   All right.

 2             MS. KORNER:  Let me show you one more intercept, please, which is

 3     P897 and it's at tab 2A.

 4        Q.   That is conversation between Mr. Zepinic and Karadzic in July of

 5     1991.  In fact, the day after there's a conversation that we showed

 6     you -- I showed you that refers to you.  It's a very long conversation

 7     and it relates to appointments in the MUP.

 8             MS. KORNER:  Can we go, please, in the English page 9; and in the

 9     B/C/S page 6, I think it is.

10             MR. ZECEVIC:  In anticipation what Ms. Korner intends to do, I

11     object because I don't see the basis that she can pose the question to

12     this witness showing him a document.

13             JUDGE HALL:  Let's have a question, Mr. Zecevic.

14             MR. ZECEVIC:  Yes, but -- well, I understand.  Thank you.

15             MS. KORNER:

16        Q.   You said that you had no evidence that the SDS was planning a

17     parallel structure at the same time, and, indeed, we would suggest

18     earlier than -- there was any suggestion of this by the SDA or the HDZ.

19     Now, appreciating that you haven't seen this particular intercept before,

20     do you see in the middle of the page Karadzic saying:

21             "Please let the collegium meet every morning and clear all that

22     out.  I was with Izetbegovic last night and with Zulfikarpasic, and I

23     told him right into his face, we'll establish a parallel government,

24     parallel police, we'll withdraw our people and they'd have to be paid by

25     the government.  We'll withdraw all our people under arms.  We'll

Page 20832

 1     establish an entire parallel state, if you keep on screwing us."

 2             Now, you knew, didn't you, because, I suggest, of your contacts

 3     with the leadership that this was happening, that already the SDS was

 4     saying, We are going to set up a parallel police?  Mr. Zepinic, your

 5     friend, didn't he tell you about this?

 6        A.   No, this is really the first time that I see this.  And I would

 7     like to say once again in the area where I was chief, in those

 8     municipalities at that time no parallel system had been established by

 9     the Serbs who were in the police.

10        Q.   All right.

11        A.   In that area, as far as I know, and I think that I had a good

12     overview of the situation and that I was following all the developments,

13     I had no information in that regard.  And this is the first time that I

14     see these particular minutes.

15        Q.   Yes, no, no, can I say and make it clear entirely, I'm not

16     suggesting that you have ever seen the record of this conversation

17     before.  What I'm asking you is whether your good friend Mr. Zepinic, who

18     you knew, you told us, did not explain to you what was going on between

19     Karadzic, the SDA, the SDS and the MUP?

20        A.   No, we never spoke about this subject, but if you would permit me

21     to explain my relationship with Zepinic, we knew each other before the

22     war because of the sports.  I complained to him about certain things that

23     were mentioned in my earlier testimony, and it is my opinion that there

24     was never a serious reaction to my complaints, an effort to change

25     something.  I spoke to him and complained to him about the problems that

Page 20833

 1     I had encountered in my area.  So his role and his power was undefined,

 2     if you ask me.  Whenever I complained to him about the problems that I

 3     had encountered, the fact that didn't have enough materiel, vehicle, and

 4     other things, he would always assure me that Mr. Delimustafic was a good

 5     man and the two of them were going to see to it, while actually nothing

 6     happened.  And we had very little materiel compared to other areas,

 7     compared to other centres.  Whatever help arrived went strait to the

 8     local stations.  And I would like to repeat it once again that Zepinic

 9     never spoke to me about this subject.

10        Q.   And just for the record, Mr. Bjelosevic, in your interview in

11     2004 going back to the Assembly document I showed you, you were shown

12     that at page 10 of 14, and you said exactly then what you said today,

13     namely, I saw this document for the first time.  And, in fact, you, at

14     that stage, said, I don't know which Djuric this is.  Now, can we move

15     on, please, through the major events, as I say, which you didn't touch

16     upon during your earlier evidence.  You no doubt recall on the 17th of

17     October of 1991, the walkout by the SDS from the Assembly and the

18     subsequent declaration of sovereignty that was made, if you can put it

19     that way, but the Rump Assembly?

20        A.   I remember that event.

21        Q.   Right.  I want you to look at a document that's dated two days

22     later, please.

23             MS. KORNER:  Which is tab 6A.  Sorry, the 65 ter number -- sorry,

24     Your Honours, I forgot to update my own document.  It's, Your Honours --

25     I'm so sorry.  It's P521.

Page 20834

 1             MR. ZECEVIC:  [Microphone not activated]

 2             MS. KORNER:  I'm told it's 6B.  For some reason I put it in 6A

 3     but it's 6B.

 4             JUDGE DELVOIE:  For a very good reason, Ms. Korner, because there

 5     is no 6A.

 6             MS. KORNER:  Now, what happened was I selected it then thought it

 7     will be 6A because of the date, and obviously for some reason we missed

 8     out A.

 9        Q.   Now, this is a document, as I say, two days after the walkout,

10     which is headed: "Possibilities of Organising a Serbian Ministry of the

11     Interior."

12             MS. KORNER:  And if we go, please, to the second page in B/C/S

13     and it's the third page in English, please.  There's a paragraph that

14     begins -- second paragraph in English, and it's the -- sorry, we need the

15     third page in B/C/S as well.  I am sorry:

16        Q.   "The minister of the interior, as an official in charge of the

17     MUP, is legally entitled to issue orders, direct the work of, and assert

18     control over, the administrations at the MUP headquarters, the CSB,

19     Sarajevo SUP, and the public security stations.  He is the only person

20     authorised by the law to hire staff, assign them to posts, transfer and

21     suspend them, conduct disciplinary procedures against them...," and so

22     on, "he may, however, transfer elements of his authority to other

23     employees."

24             MR. ZECEVIC:  I am sorry.  Your Honours, I have to object.  I

25     think Ms. Korner should establish, first of all, with the witness whether

Page 20835

 1     he saw the document, does he know anything about the document, and then

 2     read from the document because this is just reading for the purposes of

 3     record, I think, and not for posing a question.  I don't see how.  How

 4     can that be a basis for a question if the first part, like I said, wasn't

 5     established first?

 6             MS. KORNER:  If Mr. Zecevic waits, he will hear what my question

 7     is when I finish reading the paragraph.

 8             JUDGE HALL:  And, I, myself, don't see any harm insofar as it may

 9     be the more efficient way of directing the witness's attention to the

10     particular portion in respect of which -- out of which a question would

11     be framed.

12             MS. KORNER:

13        Q.   I won't go on reading because you've had a chance to read it

14     yourself.  Do you agree, Mr. Bjelosevic, with that summary of the

15     authority and duties of the minister of the interior?

16        A.   Well, it's not up to me to agree or disagree with the rights and

17     duties of the minister are stipulated by law, the Law on the Government

18     and the Law on the Ministry of the Interior.

19        Q.   Mr. Bjelosevic, you've been a policemen in the Republika Srpska

20     and the previous administration since 1991.  Would you agree that is a

21     correct summary of the minister's authority and powers?

22        A.   Maybe you misspoke.  You said the Ministry of Republika Srpska in

23     1991, if I heard you correctly, maybe it was a mistake.  Did I understand

24     you well?

25        Q.   Just don't try and avoid the question, please, Mr. Bjelosevic.

Page 20836

 1     Answer the question.

 2        A.   I'm not trying to avoid anything, really.

 3        Q.   As an experienced police officer now, do you agree that that is

 4     an accurate summary of the authority and the powers of the minister of

 5     the interior?

 6        A.   As stipulated by law.  That's about it, yes.

 7        Q.   I'll ask it one more time:  As an experienced police officer

 8     knowing the law, is that an accurate summary of the powers and the

 9     authority of the minister of the interior?

10             MR. ZECEVIC:  The witness's answer was recorded, I think.

11             MS. KORNER:  Your Honour, I'm asking him for his own knowledge.

12     I don't want him to say what the law is.

13        Q.   Is that an accurate -- is that an accurate summary from his own

14     knowledge and experience?

15             JUDGE HALL:  Ms. Korner, the answer as at line 21, isn't that a

16     clear answer to the question?

17             MS. KORNER:  Well, as stipulated by -- I don't know what line 21.

18     I've got.

19             JUDGE HALL:  Line 22:  "As stipulated by law.  That's about it,

20     yes."

21             MS. KORNER:  I make that line 11 on this -- I see.  The computer

22     is playing up slightly differently.

23             JUDGE HALL:  I interpret it as he agrees with you.

24             MS. KORNER:  Your Honours, that's right, it may just be me ...

25             [Microphone not activated]

Page 20837

 1        Q.   All right.  Now, the next part says, "Given the above

 2     organisation of the MUP," and he dealt with -- the author of this paper

 3     which is not clear, I dealt with it earlier:

 4             "The establishment of a Serbian MUP as a parallel organ of

 5     authority is possible in a number of ways."

 6             And he sets out those ways.

 7             Now, Mr. Bjelosevic, have you seen this document before?

 8        A.   No, I don't remember seeing it.

 9        Q.   However, were you aware because of your position as the head of

10     the CSB that because of what had happened on the 15th of October there

11     was active discussion going on in the SDS about setting up a separate

12     Serbian MUP, a parallel structure?

13        A.   At the time, there was a discussion about the Assembly of the

14     Serbian people and the establishment of the minister council.  As for the

15     establishment of the Serbian MUP, I do not know that there were any

16     activities in that direction at the time.

17        Q.   You were one of, I think, five CSBs, because at that stage there

18     were nine, headed by a Serb, weren't you?

19        A.   I don't know the number of Serbian personnel, but, yes, it is

20     correct that I was in Doboj.  In Banja Luka, there was Mr. Zupljanin.  I

21     can't remember others.  If it's really important, maybe I can --

22        Q.   We'll come to which ones they were in a later document.  So you

23     were never privy in October 1991 to any discussions about a parallel MUP?

24             THE INTERPRETER:  Interpreter's note:  Microphone off, please.

25             THE WITNESS: [Interpretation] I don't remember.  I think that I

Page 20838

 1     had no knowledge about anything like that at the time.  I know that there

 2     was some talk about the Assembly.  That was the time when the declaration

 3     on the independence of Bosnia-Herzegovina was about to be proclaimed, and

 4     I know that there was quite a lively discussion at the Assembly about

 5     that topic.  I also know that after that it was concluded that the

 6     Assembly of the Serbian people had to be established as well as the

 7     council of ministers.  I also know that there was some talk about the

 8     referendum, about remaining in Yugoslavia.  I remember that at the time

 9     it was a very, very live political activity related to these topics.  As

10     for the organising of a parallel MUP in that period, I really do not

11     remember that there was anything like that.

12             MS. KORNER:

13        Q.   You see, because the Assembly, as you rightly said, the first

14     Assembly met a few days later, about a week later, on the 24th of

15     October.  Now, in your evidence to Mr. Zecevic, you were shown a letter

16     dated the 24th of October, 1991.

17             MS. KORNER:  And for that, we need the Defence documents, tab 2,

18     and I am afraid I have not the faintest idea -- tab 7.  I have not the

19     faintest idea what the number is.  764D1.

20             MR. ZECEVIC:  It's 1D439.

21             MS. KORNER:  Thank you, Mr. Zecevic.

22        Q.   Before we get into the detail of this and the point I want to

23     make about it, this is one of the documents you allegedly -- you provided

24     to the Defence of Mr. Stanisic.  It is on the list number 73, I believe,

25     764D1.  You didn't give any indication of where you got this letter from.

Page 20839

 1     In other words, was it a copy that you kept yourself, is it something

 2     that you copied from the archives; are you able to assist?

 3        A.   I am afraid I can't remember with any certainty, but I remember

 4     this document.

 5        Q.   Yes.  You had been describing all the abuses, as you put them, to

 6     Mr. Zecevic that had been going on about staffing and the like.  And when

 7     you were asked about it at page 19459, you said, "This is precisely

 8     my" -- you were asked for your comments:

 9             "This is precisely my response to the violation of regulations

10     and procedures where change in personnel was concerned.  That's precisely

11     what we were discussing a moment ago.  These are the issues that

12     undermined the very system of work."

13             Is it a sheer coincidence that the very first letter of complaint

14     that you wrote to the minister, Mr. Delimustafic, is dated the 24th of

15     October, the day of the first Serbian Assembly and about a week after

16     this document that we've just been looking at was produced.

17        A.   This is probably just a coincidence.  It has absolutely nothing

18     to do with the political events in Sarajevo.  As you can see here, in

19     this letter I listed specific examples, what happened and where it

20     happened, when things were -- when activities were going on which were

21     contrary to the law.

22        Q.   Why had you waited until the 24th of October to write this

23     complaint which deals with a number of different incidents?

24        A.   Well, maybe if it was dated on another day you would ask me why

25     this other day.  I really don't know.  By then it was far too obvious

Page 20840

 1     that some things were going on contrary to the law and the regulations.

 2     There were some telephone warnings, and, after that, I thought that there

 3     should be some written trace, some written warning about the fact that

 4     some things were going on which were not supposed to be going on.

 5        Q.   But if you considered this was so important why hadn't you

 6     written earlier letters to the minister saying, Look, there are all --

 7     for example, that you appointed a chief to the Derventa SJB who doesn't

 8     meet the requirements?  Immediately that happened, why didn't you write

 9     the letter or get in touch with the minister or Mr. Zepinic?

10        A.   I said a moment ago that I complained by telephone on a number of

11     occasions, but if you really want me to explain what exactly was my

12     intention in writing this document, you can see that in the last

13     paragraph.  If I had some other ideas, I wouldn't have written the last

14     paragraph where I say I propose that a working meeting should be held

15     with the chiefs of CSB, wherein a friendly atmosphere should be discussed

16     in with all the colleagues, and so on and so forth.  So if I had some

17     other intentions, I probably wouldn't have written this.

18        Q.   Wasn't this all, Mr. Bjelosevic, setting up the reasons why you

19     could legitimately say there has to be a -- or try and say legitimately

20     there has to be a separate MUP?  That you had no -- I put it to you

21     squarely, Mr. Bjelosevic, you had no real intention of trying to cure the

22     problems through the MUP as it then existed?

23        A.   That is something that you claim and you have the right to claim

24     whatever you want.  As for me, I'm telling you once again, on the full

25     responsibility and quite honestly, at that time I knew nothing about the

Page 20841

 1     activities that you showed me a moment ago mentioned in the minutes you

 2     showed me.  And my ultimate and very serious intention was to stop the

 3     unlawful activities and to have the MUP act in a way stipulated by law

 4     and other regulations.

 5             MS. KORNER:  Your Honours, I'm going to move on to another

 6     document.

 7             JUDGE HALL:  So we take the first break for the morning and

 8     return in 20 minutes.

 9             MS. KORNER:  Your Honours, can I ask, it may be just me but it

10     seems incredibly hot in here, whether the air conditioning could be

11     turned up.

12                           [The witness stands down]

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

14                           --- On resuming at 10.49 a.m.

15                           [The witness takes the stand]

16             MS. KORNER:

17        Q.   Mr. Bjelosevic, I want to move on through the events towards the

18     end of 1991.

19             MS. KORNER:  Could we have up, please, on the screen the document

20     which is P1353.19, tab 7A.

21        Q.   This is the document which proclaims the Serb autonomous region

22     of Northern Bosnia as an inseparable part of the state of Yugoslavia, and

23     it's dated the 4th of November -- or, it states that the decision was

24     made on the 4th of November, 1991.  I take it, Mr. Bjelosevic, you were

25     aware of the Serb autonomous regions?

Page 20842

 1        A.   Yes.

 2        Q.   I take it equally that you were aware of the founding or the

 3     declaration of Northern Bosnia Serb autonomous region?

 4        A.   Yes, only this never came into being, nor were any organs

 5     constituted at this level.  However, I am aware of this decision.

 6        Q.   May I say straightaway, Mr. Bjelosevic, I don't disagree with you

 7     on this.  That unlike the Krajina, nothing much happened after the

 8     declaration and there certainly was no Crisis Staff, was there, of the

 9     autonomous region of Northern Bosnia?

10        A.   There was not a single organ there.  This was a purely political

11     decision and it never became operational, nothing materialised.

12        Q.   Okay.  There was, however --

13             MS. KORNER:  Well, we can look at the next document on this,

14     please.  If we look at, please, P1353.18, which is at 7B.

15        Q.   There was, in fact, the day of the declaration a founding

16     Assembly session, wasn't there?  We can see that nominated to the -- not

17     sure to the chair means exactly, but Blagoje Simic, he was from

18     Bosanski Samac, wasn't he, leader of the SDS?

19        A.   Yes.

20        Q.   Your cousin Milovan Bjelosevic?

21        A.   Yes, he was an MP.

22        Q.   Yeah.  And other people, I don't think we need worry too much

23     about them.  And Mr. Nikola Perisic, who -- if we go over to the third

24     page in English and the second in B/C/S, we'll see that Mr. Perisic was

25     elected to the position of president and Mr. Bjelosevic was elected

Page 20843

 1     vice-president.  And you were aware of that, were you not?

 2        A.   I was aware of the Assembly.  However, I don't see page 2 on my

 3     screen.

 4        Q.   It should be, I hope.  Is it the under 2E?

 5             MR. ZECEVIC:  2E.

 6             MS. KORNER:

 7        Q.   Yes, that's what I said, 2E.  Do you see it there?

 8        A.   Yes, yes.

 9        Q.   And it would not be right to suggest, would it, Mr. Bjelosevic,

10     that your appointment into the head of the CSB had anything to do with

11     the SAO Northern Bosnia because, as you say, it never really operated?

12        A.   The Security Services Centre of Doboj, as well as the others, as

13     far as I know, had been established on a territorial principle much

14     earlier before all these events took place, and, as I understand it now

15     and I did so at the time, implies political moves made by those who were

16     in favour of the preservation of Yugoslavia, as well as the moves of

17     those who were in favour of disintegration.  That was the policy pursued

18     at the time.

19             As for the service itself, I already explained how it operated at

20     the time.

21        Q.   Yes, I'm sorry, you misunderstand.  Your later appointment to the

22     chief of the CSB Doboj once the CSB Doboj was part and parcel of what was

23     then known as the Serbian Republic of Bosnia and Herzegovina?

24        A.   Well, as far as my status was concerned, there was continuity.

25     I'm not quite sure if I understood you correctly.

Page 20844

 1        Q.   Yes.  It may be my fault and I accept that entirely.  It would

 2     not be right, would it, to suggest that your appointment as chief of the

 3     CSB Doboj when it was part of the Republika Srpska had anything to do

 4     with the SAO Northern Bosnia or Mr. Perisic?

 5        A.   Well, no.  The centre operated, as you saw, until the end of

 6     April and the reports and everything else was being sent to the MUP of

 7     Bosnia-Herzegovina.  You see, when this was happening and I don't see any

 8     connection between the two.

 9        Q.   You never became a member of any Crisis Staff of the SAO

10     Northern Bosnia because no such thing existed; is that right?

11        A.   Well, I wasn't a member of any Crisis Staff, neither of those in

12     existence nor any other that didn't exist.

13        Q.   And you did not take orders, did you, from Mr. Perisic or

14     instructions from Mr. Perisic or from your cousin, Mr. Bjelosevic, in

15     their capacities as president or vice-president of the SAO

16     Northern Bosnia Assembly?

17        A.   No, and I would like to reiterate once again as far as I can

18     remember these things were not functioning.

19        Q.   Whether they functioned properly or not, officially, Mr. Perisic,

20     apart from being the head of the Municipal Assembly in Teslic -- or

21     Serbian Municipal Assembly in Teslic, also held officially the title of

22     president of the Assembly of the Serb autonomous region of

23     Northern Bosnia, didn't he?

24        A.   That is what the decision reads.  However, these are political

25     issues that I don't know much about, therefore I don't believe I am

Page 20845

 1     capable of giving you proper answers.

 2        Q.   Yes, but this declaration whether or not in reality it ever

 3     worked or not of the Serb autonomous region of Northern Bosnia was part

 4     and parcel, wasn't it, of the planned break-up of Bosnia; isn't that

 5     right?

 6        A.   Well, it all depends on the angle from which you perceive things.

 7     One may look at it that way, but, on the other hand, one may look at it

 8     from the point of view of the ambition to preserve Yugoslavia and prevent

 9     the cessation of Bosnia-Herzegovina.  Again, I say these are political

10     issues and probably would warrant some more sensitive analysis because

11     this is really not an area of my expertise.

12        Q.   Well, you see, Mr. Bjelosevic, I understand that you are saying

13     you are a policeman.  But I thought we had already established, politics

14     and the police, however regrettably, were inextricably mixed up, weren't

15     they, certainly by November of 1991?

16        A.   We saw from some documents that the policy pursued by all

17     political parties was based on their wish to exert as much influence as

18     they could.  As I understand things, people want to gain power in order

19     to exert influence, and I can only speak relevantly about the issue that

20     pertained to the Doboj CSB, given the fact that my reaction to every

21     political pressure was as we discussed here already.

22        Q.   I understand what you are saying was your reaction, but my

23     question was a very simple one:  Do you agree, it can be answered yes or

24     no, that by -- certainly by November 1991, politics and the MUP were

25     mixed up together?

Page 20846

 1        A.   Yes, there was influence, however I don't think we can say that

 2     things were mixed up.

 3        Q.   Right.  Let's just move on a few days, shall we.  The next

 4     document, please, is P2095, tab 7D.  Now, this is the document that was

 5     issued by -- adopted by the Assembly of the Serbian people on the 21st of

 6     November as a result of the plebiscite which took place on the 9th and

 7     10th of November.  Did you vote in that plebiscite, Mr. Bjelosevic?

 8        A.   Yes, I did.

 9        Q.   And did you vote in favour?

10        A.   In favour of Yugoslavia, yes, I did, and even nowadays if I could

11     do anything to bring this state back, I would do my best to achieve that.

12        Q.   All right.  You see, it says:

13             "The decision on the territories, municipalities, local communes,

14     and inhabited places, Bosnia-Herzegovina, are considered as territory of

15     the federal state of Yugoslavia.  The territories of municipalities,

16     local communes, and inhabited places, where on the 9th and 10th of

17     November, the plebiscite was conducted for the Serbian people and other

18     peoples to opt for remaining in the common state of Yugoslavia together

19     with the Republic of Serbia, Montenegro, the Serbian Autonomous District

20     region of Krajina."

21             That refers not to north-west Krajina and Bosnia but to the area

22     in Croatia, does it not?  Mr. Bjelosevic, the Krajina there is not the

23     Bosnian Krajina but what loosely, I will call, the Croatia Krajina?

24        A.   Give me a minute just to look at it more closely, which paragraph

25     in particular was that?

Page 20847

 1        Q.   Under 1.

 2        A.   Yes, there is a whole list here of what is to be incorporated.

 3        Q.   I don't want anybody to be confused.  The Krajina mentioned here

 4     is not the Serb Autonomous Region of Krajina in north-west Bosnia where

 5     Zupljanin was head of the CSB, it is the Krajina over the border in

 6     Croatia; correct?

 7        A.   Can you please assist me to find this particular portion.  I

 8     really went through all the paragraphs.  Is it immediately under where it

 9     says the decision under Roman numeral I?

10        Q.   Yes, but, please, I think it's self-evident anyhow, so I'm not

11     going to trouble you.

12             MR. ZECEVIC:  I am sorry.  I'm probably missing what you are

13     suggesting, Ms. Korner.  This is precisely the region Krajina from

14     Bosnia-Herzegovina.  It says:

15             "The decision on verification of the proclaimed Serbian

16     autonomous district in Bosnia-Herzegovina."

17             And all the municipalities are actually Bosnia-Herzegovina.

18             MS. KORNER:  [Microphone not activated]... no, if you look --

19     unless we have a translation problem.  The plebiscite was conducted for

20     the Serbian people and other peoples to opt for remaining in the common

21     state of Yugoslavia together with the Republic of Serbia, the Republic of

22     Montenegro, the SAO of Krajina, the SAO Slavonia, Baranja, and

23     Western Srem.  Now, as far as I know, Montenegro is not in Bosnia.

24             MR. ZECEVIC:  No, no, no.  But you are directing us to under I

25     and it says "Autonomous Region of Krajina."  I don't have the document,

Page 20848

 1     unfortunately, with me and I don't know where you are reading from.

 2             MS. KORNER:  Quite right.

 3             MR. ZECEVIC:  And I should maybe suggest that you provide the

 4     copy of the whole document for the benefit of the witness.

 5             MS. KORNER:  No, I was looking at my own copy and it's the wrong

 6     document that was up.  I apologise, I wasn't looking at the document on

 7     the screen and I don't know -- sorry.  It should be, I thought as I said,

 8     P20 -- it's a different document.  Your Honour, it's my fault.  I think

 9     I've got it.  There's a different document which has gone in as a

10     document from the one I'm looking at.  But it doesn't really matter

11     because I just wanted to know whether Mr. Bjelosevic had voted in the

12     plebiscite.

13        Q.   Right.  Now, one other question:  After the plebiscite in

14     February was held the referendum, that's right, isn't it, February 1992?

15        A.   Yes.  On the 29th of February, and I think on the 1st of March as

16     well.

17        Q.   Right.  I just want to ask you to look at one further document on

18     this.

19             MS. KORNER:  It's P1936.  Tab 8B.

20        Q.   This is slightly jumping ahead, but at its session held on the

21     26th of January, 1992, the Assembly of the republic adopted the

22     following:  The decision to hold a referendum for the citizens of Bosnia

23     and Herzegovina which would be a basis for transforming Bosnia and

24     Herzegovina into an independent state, was adopted in a regular manner

25     and without presence of the Serbian deputies.  Can only be binding on

Page 20849

 1     these two peoples.  For the Serbian people of Bosnia-Herzegovina, this

 2     decision is invalid and directed against the existential interests.

 3     Mr. Krajisnik, as president of the Assembly, was making the point, wasn't

 4     he, that nobody should vote, no Serbs should vote in this referendum; is

 5     that correct?

 6        A.   This is another political decision and political affairs.  In

 7     order for you to understand me and my attitude towards certain political

 8     issues, let me tell you just one thing:  There was a political rift back

 9     in 1997 in Republika Srpska, and this rift spread around.  We had

10     Biljana Plavsic as the president on the one side, and the government,

11     headed by Mr. Klicko [phoen], on the other side.  No, no, please let me

12     explain my position.  I didn't want to take sides at that time either.

13     That was my principle.  I always thought that the political issues should

14     never be tackled by either the army or the police, otherwise that could

15     be called a coup d'etat and it could produce completely different

16     consequences.  I didn't want to be part of that.  I can read this

17     document and tell you what I think about it, but I, myself, was never

18     directly involved in this.  And I always advocated a position that nobody

19     from the police should be involved in that, either at that time or in

20     1997, so I have subscribed to the same position and attitude throughout

21     the whole period.

22             I have never been involved in politics and I always stayed away.

23        Q.   So you don't consider the fact that you voted in the plebiscite

24     in November was making a political decision or taking a political

25     standpoint?

Page 20850

 1        A.   That was my personal attitude which was conditioned on

 2     anything -- wasn't conditioned on anything else.  It wasn't imposed on me

 3     by anyone.  That was my constitutional right.  And I would like to say

 4     once again, I still believe that the greatest mistake that was made was

 5     that Yugoslavia was broken up and that it ended in a war.  That used to

 6     be quite comfortable and good country for everyone living in it.

 7        Q.   Did you exercise your personal vote and decision in the

 8     referendum and vote against the independence of Bosnia so that, as you

 9     put it, Yugoslavia could be kept together?

10        A.   I already stated my preferences when it was a for-or-against

11     Yugoslavia.  Of course I couldn't vote once for and the second time vote

12     against -- if you can help me, if I misunderstood your question.

13        Q.   You did.  You told us you took part in the Serb plebiscite held

14     in November.  You exercised your personal right to vote, nothing to do

15     with politics, so that in favour of Bosnia staying in Yugoslavia.  Did

16     you equally exercise that vote, your right to vote when the referendum

17     was held, and vote against the suggestion that Bosnia should be

18     independent but instead vote again for staying in Yugoslavia?

19        A.   I didn't go to the referendum for the second time because I had

20     already voted once before.

21        Q.   Mr. Bjelosevic, you are not telling the Court, are you, that you

22     didn't realise that this was something completely separate.  If you were

23     so keen on Bosnia staying in Yugoslavia and you did not consider that

24     politics was something that should concern you, why didn't you vote in

25     the referendum?

Page 20851

 1        A.   Well, because the referendum was aimed at getting

 2     Bosnia-Herzegovina out of Yugoslavia.

 3        Q.   Yes.  But if you had voted against it and enough Serbs had gone

 4     along and voted against it, things might have been different, mightn't

 5     they?

 6        A.   No, it was my understanding that the outcome was the same because

 7     not voting and voting against boiled down to the same thing.  Voting in

 8     favour meant voting to have Bosnia and Herzegovina taken out of

 9     Yugoslavia.

10        Q.   Yes, you know exactly what I mean and I'm going to pursue this,

11     Mr. Bjelosevic.  By that time, by the time the referendum was held at the

12     end of February, it was absolutely plain to you, wasn't it, that there

13     was going to be an independent state -- Serbian state within Bosnia?

14     That had already been declared, hadn't it?

15        A.   That was not clear to me, and I don't think that it was clear to

16     anyone at the time what would happen next.  If you remember, there was

17     lively diplomatic and political activity underway at the time, both in

18     the area of Yugoslavia and also with mediators in Geneva, and I cannot

19     remember now who were all the people involved in unravelling this crisis.

20     I think that in that period of time February, March, no one was clear on

21     what would happen, at least it wasn't clear to me.

22        Q.   All right.  Just have a look, please, at the document which is

23     apparently part of the law library, L00029 exhibit, tab 8A.  On the 9th

24     of January, 1992, the Assembly of the Serbian people declared the

25     Republic of the Serbian people of Bosnia and Herzegovina.  Now, you are

Page 20852

 1     not telling the Court, are you, Mr. Bjelosevic, that you didn't know

 2     that?

 3             THE INTERPRETER:  Interpreter's note:  We cannot hear the

 4     witness.

 5             MS. KORNER:

 6        Q.   Sorry, Mr. Bjelosevic, you have to start again, the interpreters

 7     didn't hear you?

 8             JUDGE HALL:  I wonder whether the usher could see whether his

 9     microphones need to be adjusted because this appears to be a recurring

10     problem.

11             THE INTERPRETER:  Interpreter's note:  We can hear speakers when

12     all other microphones are switched off.  Thank you.

13             THE WITNESS: [Interpretation] Is it all right now?

14             MS. KORNER:  Your Honours, it seems that although this is not a

15     problem that's occurred in the early years that if anybody else leaves a

16     microphone on, the interpreters cannot hear the witness.  I don't know

17     why that is and it shouldn't be.  There's something obviously wrong with

18     the sound system, but it meant, I gather from what the interpreters are

19     saying, that's the problem.  I am afraid I am the guilty one because I

20     forget to turn it off when I ask the question.

21             JUDGE HALL:  We are observing that your microphone seems to be

22     more sensitive than any of the others.

23             MS. KORNER:  I could try using the other microphone, actually.

24             JUDGE HALL:  Thank you.

25             MS. KORNER:

Page 20853

 1        Q.   Sorry, Mr. Bjelosevic, I was asking you whether you were aware of

 2     the declaration of proclaiming the Serbian Republic?

 3        A.   Yes, that was publicly declared.  It was a generally known thing.

 4        Q.   In the first part, it says:

 5             "In the area of the Serbian autonomous regions and districts and

 6     other Serbian entities in Bosnia and Herzegovina, including the areas

 7     where the Serbian people are a minority due to genocide committed against

 8     them during the Second World War, and on the basis of the plebiscite, the

 9     republic of the Serbian people of Bosnia and Herzegovina is hereby

10     established and proclaimed."

11             What do you understand -- no, that would invite a very long

12     answer.  So let me put this to you:  Where the areas where the Serbian

13     people are in a minority due to genocide, that meant areas which were --

14     had a majority of non-Serbs, did it?

15        A.   I don't know which area this referred to.  I really would not

16     take it upon myself to interpret what this means.

17        Q.   Well, there were a number of municipalities, weren't there, which

18     later on were claimed to be part of the Serbian Republic where the Serbs

19     were not in a majority?

20        A.   As far as I know, the territories were being declared at the time

21     and there were inter-party talks that were being held so such and such

22     Serb municipality was declared, such and such Croatian municipality.  And

23     Crisis Staffs were later formed on the basis of that principle, and so

24     on.

25        Q.   Not an answer to my question and you know it's not.  There were

Page 20854

 1     municipalities which were claimed to be part of the Serb Republic, were

 2     there not, where the Serbs were not actually the majority population?

 3        A.   I can speak for the area where I worked.  As far as I know, in

 4     all these areas, in all these municipalities, some kind of inter-party

 5     agreements had been reached and this was divided.  It wasn't that an

 6     entire municipality would be taken as such.  Say the Serb municipality of

 7     Derventa would be proclaimed or Teslic, and as you could see, there was

 8     Doboj Istok, et cetera, some kind of inter-party agreements were reached

 9     there.

10        Q.   Well, your municipality is one, we'll look in more detail at

11     Doboj, but there were according to the census in 1991, 39 -- nearly

12     40.000 Serbs, 41.000 Muslims, and 13.000 Croats.  So that's an area where

13     the Serbs were not a majority; that's correct, isn't it?

14        A.   Yes, that's right.  I don't know whether you know specifically

15     that some lines and divisions were agreed upon between the SDA, the SDS

16     and the HDZ, and the result of that was the existence of these

17     municipalities that we've already discussed, if you recall.

18        Q.   I am a going to -- yes, no, no, no, you say, Mr. Bjelosevic --

19     I'm going to come back in detail to Doboj, but I just want to deal with

20     this declaration which said that where Serbs were in a minority due to

21     genocide.  Let's take Prijedor, for example, there were 49.000 Muslims,

22     47.000 Serbs and 8.000 Croats.  So, again, Prijedor, that was not a

23     municipality, was it, where the Serbs had a majority?

24        A.   If the information you have presented now is accurate, and I'm

25     not doubting it at all, there's nothing I can say to that.  I was not in

Page 20855

 1     Prijedor.  I'm not familiar with all these details, but then that's the

 2     way it is.

 3        Q.   But you are an intelligent man, Mr. Bjelosevic, and you know full

 4     well the point I'm making.  The moment that there was this declaration of

 5     the Serb -- so-called Serb Republic on the so-called Serb Assembly in

 6     January 1992, it was inevitable, was it not, that there would be

 7     conflict?

 8        A.   Well, it wasn't inevitable still, although preparations for war

 9     were underway and formations were being established but it wasn't

10     inevitable to have them used.

11        Q.   You see, I've just been through this, I am afraid, at some length

12     because it's all a background, isn't it, to the meeting of the 11th of

13     February, 1992, attended by you and other high-ranking Serb MUP

14     officials.  And it's right, isn't it, Mr. Bjelosevic, that when you and

15     all of you attended, you all knew there was going to be a split in the

16     MUP, didn't you?

17        A.   I think that no one could have said that with any certainty.

18     After all, you saw from the minutes what I was saying, and I think that

19     that was still an attempt to bring pressure to bear against the MUP of

20     Bosnia-Herzegovina, to have it function in a lawful way, to do away with

21     some unlawful things, and so on.  I don't know how many times I have to

22     repeat that we were denied proper supplies as we should have had on the

23     basis of the regular programme of equipping the service.  And I don't

24     know how many times I have to repeat that in that period there was a

25     parallel system that was established.  You saw through those inspectors

Page 20856

 1     who came to the area and they established a parallel system of

 2     management.  Perhaps it was clear to some that there would be divisions,

 3     but it wasn't to me, believe me.  To the very end, I harboured hopes to

 4     the effect that this would start functioning properly.

 5        Q.   Yes, I'm going to come on to your action after [indiscernible]

 6     MUP later on, but I want to deal at this stage, please, with the events

 7     of the 11th of February.  You have told the Court, as you say, endlessly

 8     about your string of complaints that a parallel system was being set up,

 9     that you weren't getting supplies, that people were being appointed who

10     shouldn't have been appointed, and so on and so forth.  Now, we've

11     already looked at the first letter you ever wrote to the Mr. Delimustafic

12     about those complaints in October.  How did you get -- how did you come

13     to attend the meeting on the 11th of February in Banja Luka?

14        A.   I was invited to the meeting.

15        Q.   By whom?

16        A.   Well, now I could not remember exactly.

17        Q.   Look, you know full well, don't you, Mr. Bjelosevic, this was one

18     of the most important meetings that took place.  You've got perfect

19     recollection of other important meetings.  Are you seriously telling this

20     Court you do not know who asked you to this meeting?

21        A.   Well, I really don't know who invited me to the meeting.

22        Q.   Was it Mr. Mandic whose phone number you had in your book?

23        A.   It's possible that it was Mr. Mandic, but it was only natural

24     that I would have the telephone number of the assistant minister for the

25     area of crime prevention.  It was quite proper for me to have the numbers

Page 20857

 1     of these people.

 2        Q.   Not could it, was it, in fact, Mr. Mandic who telephoned you or

 3     wrote to you and said, Attend this meeting?

 4        A.   Well, I'm telling you that I really do not remember who it was

 5     that called me.  It may seem real or unreal to you, but I do not want to

 6     say anything that I do not know with certainty.  I don't know who called

 7     me.

 8        Q.   Was it made clear to you by whoever called you that this was a

 9     meeting of high-ranking Serbian members of the Bosnia-Herzegovina MUP?

10        A.   I don't even know the details what I was told at that point in

11     time, but I know who attended the meeting and what was discussed there.

12     And, after all, there are minutes about that.

13        Q.   Yes.  Was it made clear to you that this was going to be a

14     meeting of Serbian members of the MUP only?

15        A.   I don't remember.  I don't remember that that is what the

16     information said.

17        Q.   Did you understand, and was this supposed to be some sort of

18     collegium?  I mean, somebody must have told you what this meeting was

19     about, otherwise why would you have gone?

20        A.   I don't remember the details, how I received this information and

21     from whom and what that information said.  I really do not remember.

22        Q.   Is that true, Mr. Bjelosevic, or is it just that you don't want

23     to tell the Court that you knew this meeting was about the formation of a

24     separate MUP?

25        A.   Why would I not want to say what I know?

Page 20858

 1        Q.   Now, the day before you went to the meeting in Banja Luka you

 2     attended another meeting, didn't you, which you recorded in your diary?

 3             MS. KORNER:  And, Your Honours, that's now been translated and

 4     is -- forgive me, Your Honours.  I think it's 107A tab, which has been

 5     given the number 20103.01.  Right, go to the next page in English.  I

 6     think the 7th has also been translated.

 7        Q.   You've got your original with you, Mr. Bjelosevic.  10th of

 8     February, it says, "Hold meetings with reserve police for studying the

 9     rule book," et cetera.  And then on the 10th of February, there was

10     apparently a meeting attended by the minister; the assistant minister,

11     Mr. Zepinic; Mr. Jankovic; Mr. Masulovic; Mr. Pusina; Mr. Markovic;

12     Alicic; Mr. Bilic and Mr. Tokic.  Where was this meeting held?

13        A.   Klokic, not Tokic.  The meeting was held at the Doboj

14     municipality.

15             MR. ZECEVIC:  I am really sorry, just that we have the proper

16     page for the benefit of our clients on the ...

17             MS. KORNER:  I have no idea.

18             MR. ZECEVIC:  That's the next page in his diary.

19             MS. KORNER:  Right.  Next page, please, in B/C/S and in English,

20     please.  Sorry.

21        Q.   Right.  You told us that was a meeting in Doboj.  What was the

22     meeting attend by the minister, deputy minister, and I've forgotten what

23     Mr. Pusina's position was at that time?

24        A.   I think he was assistant minister.  Mr. Zepinic was deputy

25     minister.  Jankovic was, I think, commander of the Tuzla Corps,

Page 20859

 1     General Savo Jankovic.  Masulovic was assistant commander for security

 2     from the corps command, and so on.  Alicic Ahmet was president of the

 3     Municipal Assembly of Doboj.  Ilija Bilic was chief of the state security

 4     sector in the Doboj centre.  And Hasan Klokic was chief of the sector for

 5     public security in the Doboj centre.  If I remember correctly, Markovic

 6     was an inspector from the MUP from Sarajevo.  The topic that was

 7     discussed was, as you can see here, the repeater -- or, rather, the

 8     programmes, the TV programmes that were telecast via that repeater

 9     outside Doboj.

10        Q.   Yes, just so we put this into context, I think it's right that

11     some activists had turned the repeater, the television receiver, or

12     whatever it is, round so that it was only receiving programmes from

13     Belgrade; is that correct?

14        A.   No, not only from Belgrade.  Let me explain what this was all

15     about.  That repeater at the Becanj Hill covered the municipality of

16     Doboj with its signal and some other areas, and the signal was

17     distributed the signal TV Sarajevo.  The first program and the second

18     program of TV Sarajevo then TV Zagreb, that's what it was called at the

19     time, the first programme and the second programme.  And from time to

20     time, Yutel was telecast, the Yugoslav television.  And then the signal

21     of the second programme of TV Belgrade was taken over instead of the

22     second programme of TV Sarajevo.  So the number of programmes or channels

23     changed.  So this is the way it was, the first program of Sarajevo,

24     Belgrade second programme, then Zagreb the first programme, and I think

25     that somewhere around that time Yutel took over what used to be the

Page 20860

 1     second programme of TV Zagreb.  That is what was discussed.

 2        Q.   Yes, all right, thank you, Mr. Bjelosevic.  Whatever it was, this

 3     was considered a serious enough matter for the minister, deputy minister,

 4     assistant minister, and corps commander to be present; is that correct?

 5        A.   Yes.

 6        Q.   Did you use the opportunity when you had with you the three top

 7     members of the MUP to discuss with them your complaints about what you

 8     said was happening, the parallel system and the like?

 9        A.   I did not have an opportunity to talk to Mr. Delimustafic.  He

10     was very angry.  He was there only briefly.  Quite simply, there was no

11     opportunity to talk.

12        Q.   At the time that you attended this meeting, had you already been

13     invited to the meeting in Banja Luka the next day?

14        A.   I really don't know.

15        Q.   Did you mention to anybody, Mr. Zepinic, in particular, the

16     person you knew, that there was in meeting in Banja Luka and asked them

17     what it was about?

18        A.   I'm telling you that I don't know at all whether before this

19     meeting on the 10th I knew of the meeting in Banja Luka on the 11th.

20        Q.   Did you mention -- you say Mr. Delimustafic was very angry,

21     didn't stay long.  Did you mention to either Mr. Zepinic or Mr. Pusina

22     while you had them in Doboj the series of complaints that you say existed

23     at the time or the state of affairs that you say existed at the time?

24        A.   In relation to those problems, I spoke to Mr. Zepinic several

25     times on the telephone, to Mr. Mandic as well, to Pusina.  As a matter of

Page 20861

 1     fact, I communicated with Pusina in writing.  We looked at these

 2     dispatches here, I think.  I repeat once again that I'm not sure whether

 3     all of that was done that way with the approval and knowledge of

 4     Minister Delimustafic or whether it was at a lower level, Pusina and

 5     Hebib, whether they established this parallel system.  However, quite

 6     simply, during that year while I was chief of the centre, I had no

 7     opportunity to talk to Minister Delimustafic.  Had I had such an

 8     opportunity, then I would have understood whether that was his position

 9     as well or not.

10        Q.   Sorry, Mr. Bjelosevic, but you had that opportunity that day,

11     however angry he was, however much he was in a hurry, you could have said

12     to him, couldn't you, if what you are telling us is true, Minister, I

13     need to speak to you urgently about what was going on in the Doboj area?

14     You could have done that, couldn't you?

15        A.   Obviously you don't believe me and I simply don't know how to

16     convince you that this man did not want to talk.

17        Q.   I am sorry, Mr. Bjelosevic, did you take this opportunity, did

18     you try to speak to him?  That's all I'm asking.

19        A.   I did try.

20        Q.   You tried to speak to him and he said he couldn't speak to you,

21     is that what you are saying?

22        A.   He just stood up, turned and left.

23        Q.   Did you try to speak --

24        A.   My attempt -- my attempt to talk to him ended in the way that I

25     just described.  When the meeting ended and when we all stood up, I

Page 20862

 1     approached him, I tried but he simply turned around and left.  I cannot

 2     believe that he did not hear me.

 3        Q.   Sorry, I thought you said -- yes, I am sorry, I see.  So you are

 4     now saying you did try, but he wouldn't stay.

 5        A.   Yes.

 6        Q.   What about Mr. Pusina, Mr. Zepinic both of whom were there, did

 7     you try and talk to them?

 8        A.   This whole group of people left together with the minister.  And

 9     I talked to them many times earlier and also later on.

10        Q.   Let's move then, shall we, to the 11th of February meeting which

11     you looked at the minutes on many, many occasions because you were sent a

12     copy, weren't you?

13        A.   Yes.

14             MS. KORNER:  Could we have, please, on the screen then 1D00135,

15     tab 9.

16        Q.   Now, this meeting, as you said you thought, happened in the

17     hotel Bosna, didn't it?

18        A.   I think it was the Bosna hotel.

19        Q.   Did you believe when you arrived that this was some kind of

20     official collegium meeting?

21        A.   Well, when I arrived, I saw the people there.  I greeted them.  I

22     didn't have any opinion preformed about that meeting.

23        Q.   Well, if it had been an official collegium meeting, wouldn't you

24     have expected it to be held in the premises of the CSB Banja Luka?

25        A.   Well, bearing in mind that there was a large number of people who

Page 20863

 1     attended this meeting, I'm not sure that it was possible to find a

 2     suitable room at the centre.  I really don't know, I never thought about

 3     it.

 4        Q.   But it wasn't usual, was it, for official collegiums to be held

 5     in hotel premises?

 6        A.   Well, sometimes we had working meetings with the police,

 7     sometimes in the old bank or in the institution called Zojilo at the

 8     time.  It wasn't something completely out of the ordinary if a larger

 9     number of people had to be present.

10        Q.   This wasn't that large a number, was it?  There was about 15 of

11     you, give or take?  20.

12        A.   We can count them.

13        Q.   Twenty, yes, 20 people.  It wasn't that large, was it?  Easily

14     accommodated in Banja Luka CSB.

15        A.   I don't know.  I did not think about that.

16        Q.   I mean, you've been to Banja Luka CSB, haven't you?

17        A.   Yes.

18        Q.   You know there's a large meeting -- or, a number of large

19     meetings rooms in the CSB, don't you?

20        A.   I stayed in the office of the chief of the centre --

21        Q.   Well --

22        A.   -- and I don't believe that in that office you could accommodate

23     20 people.

24        Q.   Next door to the chief's office is a large meeting room, isn't

25     there?

Page 20864

 1        A.   It's possible.  I don't know.

 2        Q.   Let's get on to the contents.  You saw all the people were there,

 3     we've been through them, I think, as to those you knew and those you

 4     didn't know.  Were you not surprised to see that Mr. Zepinic wasn't

 5     there?

 6        A.   Well, no, I wasn't surprised.

 7        Q.   Why was that?

 8        A.   Well, I don't know why I should have been surprised.  I didn't

 9     know who was invited to that meeting.  I didn't invite anybody to that

10     meeting, and I couldn't have been surprised whether this or that person

11     arrived or not.  It wasn't that kind of situation.  I never thought about

12     that.

13        Q.   There was Mr. Mandic; there was Mico Stanisic, the head of the

14     SUP Sarajevo -- advisor at that stage, senior Serb member of the MUP;

15     Mr. Mandic, the assistant minister; and everybody else, Mr. Zupljanin,

16     head of the CSB; yourself; Mr. Savic and other members of the senior Serb

17     MUP.  Did you say to anybody, Where is Zepinic?

18        A.   No.

19        Q.   Was that because you knew that he wasn't there because he was, in

20     fact, in favour of keeping the MUP together and was considered a traitor

21     to the Serb cause?  Did you know that and is that why you didn't ask?

22        A.   No.  I didn't know that.  And I do not know about, how should I

23     call it, a qualification or a chip on his shoulder to call him a traitor.

24     I don't know.

25        Q.   Well, let's have a look, please, at some of the entries.

Page 20865

 1     Mr. Stanisic --

 2             MR. ZECEVIC:  It's tab 18 of the binder that the witness has.

 3             MS. KORNER:  It's on the screen.

 4        Q.   Mr. Stanisic opened, after Stojan Zupljanin dealt with it, and

 5     said, indeed, on the line you've been going, that the socialist republic

 6     MUP is being divided by the Muslims, not the Serbs, so on and so forth.

 7     Work has to be done by the organisation of the Serbian MUP starting from

 8     the municipal and regional levels up to the Serbian ministry.  A list of

 9     minimal outstanding demands should be assembled at this meeting and

10     submitted to the Minister Delimustafic.

11             Now, have a look, please, at the conclusions because you say that

12     you understood what was going to happen, and it may well be it's easier

13     for you, I suppose, to go through the Defence binder, tab 18.

14             MS. KORNER:  And could we go please on the screen to the fourth

15     page in English and the sixth page in B/C/S.

16        Q.   Now, although that's what Mico Stanisic on the face of it was

17     suggesting, in actual fact, that's right, isn't it, Mr. Bjelosevic, and

18     you are very familiar, as I say, with this document, that was not one of

19     the conclusions of the meeting, was it?

20        A.   What conclusion was not one of the conclusions of the meeting?

21        Q.   The suggestion -- it's been put to you, and you say you think

22     that that is what happened, that Mr. -- a minimal -- a list of minimal

23     outstanding demands should be assembled at this meeting and submitted to

24     the minister, Alija Delimustafic.  That's what Mr. Stanisic was

25     suggesting.  That however, I'm suggesting to you, Mr. Bjelosevic, is not

Page 20866

 1     something that the meeting decided to do, and indeed it was never done?

 2        A.   I'm not sure that I understood you correctly.  Your position is

 3     that Mr. Stanisic did not say that, that minimal requirements should be

 4     established and sent to Minister Delimustafic.  I am not quite sure,

 5     maybe something was lost in the translation.  Could you help me to

 6     understand your question.

 7        Q.   Or are you just prevaricating.  Mr. Bjelosevic, no conclusion at

 8     the meeting was to the effect, was it, that a list of demands should be

 9     sent to Mr. Delimustafic?

10        A.   Well, it was mentioned, yes, it was mentioned that we should ask

11     for manpower, and I was one of the persons who highlighted the problems

12     about materiel and other technical equipment that we should have

13     obtained.  Yes, we spoke about that at length.  And it wasn't only the

14     Doboj centre that was short changed in the whole --

15        Q.   Don't side track, please, Mr. Bjelosevic, you are very good at

16     that.  The meeting, the conclusion of the meeting was not, was it, that

17     anything should be said to Mr. Delimustafic, the only person, the only

18     organisation that was to be informed was the council of ministers, if you

19     look at number 18 of the conclusions.

20             MS. KORNER:  Can we go to the next page in English and in B/C/S.

21             THE WITNESS: [Interpretation] Yes, it's conclusion number 18.

22             MS. KORNER:

23        Q.   So this was, wasn't it, a secret meeting.  Nobody told

24     Mr. Delimustafic or Mr. Pusina or, indeed, Mr. Zepinic that this meeting

25     was taking place or even afterwards that it had taken place?

Page 20867

 1        A.   I wouldn't agree with you because if you look at the conclusion

 2     number 19, you can see that it contradicts your statement:

 3             "Ensure maximum media coverage of our work and the decisions made

 4     about the Serbian MUP."

 5             It wasn't a secret meeting at all.

 6        Q.   "Ensure maximum coverage of our work and the decisions made ..."

 7     is not the same thing, is it, Mr. Bjelosevic, as ensure media coverage of

 8     our meeting in the hotel Bosna on the 11th of February?

 9        A.   Well, no, but you said that Zepinic had not been informed about

10     the meeting and Delimustafic as well.  I don't know whether they had been

11     informed.  Some of their close associates were there and you also said

12     that they were not informed about it later on and you also said it was a

13     secret meeting, and I'm saying it wasn't a secret meeting.

14        Q.   I will get back to the beginning of the document.

15             MS. KORNER:  Sorry, Your Honours, I'm told it's time for the

16     break.

17             JUDGE HALL:  So we will resume in 20 minutes.

18                           [The witness stands down]

19                           --- Recess taken at 12.07 p.m.

20                           --- On resuming at 12.30 p.m.

21                           [The witness takes the stand]

22             MS. KORNER:  Could we have back up, please, on the screen the

23     11th of February meeting which 1D135.

24        Q.   And if it helps you, Mr. Bjelosevic, you have the document.

25     Mr. Radovic informed the meeting - do you see that on the first page --

Page 20868

 1     second page in B/C/S, sorry - that the Assembly of the Serbian people had

 2     made a decision on the establishment of the Serbian MUP and informed them

 3     of the text and the contents of the above decision?  Were you aware that

 4     a decision had been made by the Assembly that there should be a Serbian

 5     MUP established?

 6        A.   Mr. Radovic informed us about it at the time.

 7        Q.   Yes.  But had you heard it before Mr. Radovic informed you about

 8     it?

 9        A.   No, no.  I only knew about the Assembly and about the council of

10     ministers.

11        Q.   Right.  Once you knew about that, Mr. Bjelosevic, it was clear to

12     you, wasn't it, that there was no way that a Serbian MUP declared by a

13     Serbian Assembly in Bosnia could co-exist in any way at all with a joint

14     MUP?

15        A.   If I remember right, there were some talk at that meeting that

16     this issue had been discussed at the collegium with the minister,

17     Mr. Delimustafic, and that it was a part of -- what is the name of that

18     agreement, and later on it was mentioned in the dispatches.  It was said

19     that that was a part of a political agreement that had been reached,

20     whether it was in Geneva or some place else, I can't remember.

21        Q.   Sorry, my question was:  Once you knew that the Serbian Assembly

22     had said that there would be a Serbian MUP, you knew, didn't you, that it

23     could not co-exist within a joint Bosnian MUP?

24        A.   And I'm telling you that there had been some talk about the fact

25     that the same issue had been discussed at the collegium with the minister

Page 20869

 1     of the interior of the Bosnia-Herzegovina.  So it was something that had

 2     been discussed and agreed with Delimustafic and others.

 3        Q.   Right.  But where do you see that, please, in the minutes of this

 4     meeting or in your own notes?

 5        A.   Somebody among those people present there spoke about it.  I

 6     would have to find it here.  There was also a dispatch or a number of

 7     dispatches.  I don't know whether it was immediately after this about the

 8     activities that were carried out at this particular level.  I think that

 9     we already saw such a dispatch in my earlier testimony.

10        Q.   We'll come on to the dispatches in a moment.  All right.  Let's

11     go to what you actually said, which we see at the bottom of the page.

12             MS. KORNER:  I think we need the next page in B/C/S and the next

13     page in English, please.

14             THE WITNESS: [Interpretation] Yes.  These are the problems that I

15     enumerated.

16             MS. KORNER:

17        Q.   Yes, but it's your remarks about Mr. Zepinic that I want to refer

18     to because you told us that as far as you were concerned, you had no idea

19     that he had been side-lined or that he was regarded as any kind of a

20     traitor to the Serb cause.  You are the person who puts in the complaint

21     against him:

22             "I have complaints against the Deputy Minister Vitomir Zepinic.

23     He signs decisions on the employment of the Muslims in Doboj, but will

24     not sign for Serbs.  I also support the decision to establish the Serbian

25     MUP."

Page 20870

 1             Did you mention those complaints to Mr. Zepinic the previous day?

 2        A.   I told him about it on a number of occasions before he went to

 3     the MUP in Sarajevo and also in a telephone conversation.  Every time he

 4     promised that he would solve that, but then he also complained that after

 5     the chief of the personnel department had been replaced, that is after

 6     Vesinovic [phoen] left and Srebrenikovic arrived, that he was now holding

 7     practically everything in his own hands and that nothing could be done at

 8     the moment.

 9        Q.   Did you think of saying when you made your speech at the meeting,

10     Mr. Zepinic should be here to hear our complaints from all of us?

11        A.   I really wasn't thinking about why Zepinic wasn't present at the

12     meeting.  I simply said what I think should have been said, and that is

13     that I contacted him on a number of occasions because of various issues,

14     that he always promised that he would solve things.  And I already told

15     you how he explained the fact that he couldn't solve them.  He said that

16     he had forwarded the file and that he was currently waiting for the

17     department personnel to prepare the file for the signature.  But it never

18     really happened.  My feeling is that he didn't have either the authority

19     or the power to resolve this issue with the personnel department, or more

20     precisely with Mr. Srebrenikovic.

21        Q.   Mr. Bjelosevic, it is no good repeating endlessly the same things

22     in answer to every question I ask you.  It was a simple question:  Did

23     you think of saying to the meeting or asking the convenors, Mr. Mandic,

24     Mr. Stanisic, Why isn't Mr. Zepinic here so that we can put our

25     complaints to him and hear what he has to say?  That's all I asked.  Now,

Page 20871

 1     was that something that ever crossed your mind during this meeting?

 2             MR. ZECEVIC:  I am sorry, Your Honours, I have to intervene.

 3     57/14:

 4             "I really wasn't thinking about why Zepinic wasn't present at the

 5     meeting."

 6             I believe the witness answered, and this is at least fifth time

 7     that Ms. Korner is making inappropriate comment, in my opinion, when

 8     posing the question to the witness.  The comments we can have at the

 9     final submissions about our positions concerning the witnesses.  I would

10     kindly ask that she poses the question without commenting or expressing

11     her opinion about the witness.  Thank you very much.

12             MS. KORNER:

13        Q.   All right.  So your answer is it never crossed your mind during

14     this meeting to suggest that Mr. Zepinic should be there?

15        A.   No, that's not the way I thought.

16        Q.   Now, let's move down to Mr. Zugic, who says that:

17             "The Serbian MUP has to start work as soon as possible, if only

18     to pursue the bridges across the Drina River."

19             What was that a reference to?

20        A.   At that time, there were some well publicised threats.  And also

21     during our operative work, it was found out that certain extremist forces

22     wanted to destroy the bridges.  Later, the same applied to the Visegrad

23     dam.  It was the well known case of Murat Sabanovic who threatened that

24     he would blow it up and flood the whole area.

25        Q.   Sorry Mr. Bjelosevic, that was much later than this.  Why did it

Page 20872

 1     it need a Serbian MUP in order to pursue, as you put it, "extremist

 2     forces wanting to destroy the bridge"?  Why shouldn't a joint proper MUP

 3     have dealt with that?

 4        A.   There was much talk about that, also in the regular MUP, as you

 5     put it, or maybe I should say the MUP of the Socialist Republic of

 6     Bosnia-Herzegovina.  The situation was very complicated at the time and

 7     it was quite obvious that it was getting militarised and that a door was

 8     being opened for certain para-structures which were supposed to

 9     infiltrate it.  Because Mr. Zugic was the chief of the state security

10     sector in Tuzla, he had detailed information about what was being

11     prepared in that area and that is what he spoke about.  This sentence

12     here is simply a summary of what he had said before it about those

13     problems.  I remember that he mentioned a name, Alija Silak [phoen].  He

14     was part of the extreme emigration and he said that he had returned to

15     Bosnia and Herzegovina and that he was preparing some sabotage groups.  I

16     don't know if you are aware of this, but even before the war, well before

17     the war, there were some terrorist actions all over the world under his

18     leadership.

19             MR. ZECEVIC:  Sorry, but there is an intervention concerning the

20     translation.  I just noticed the English translation of the last sentence

21     that Mr. Zugic is talking at this meeting is not appropriate.

22             MS. KORNER:

23        Q.   Can you read out, please, from the B/C/S, Mr. Bjelosevic, the

24     last sentence of what Mr. Zugic said?

25             MS. KORNER:  May I say it's a bit late after the billions of

Page 20873

 1     times after we've been through this document to mention this.

 2             MR. ZECEVIC:  Well, I am sorry, Ms. Korner, I believe this is the

 3     Office of the Prosecutor translation.  That is why we have these problems

 4     repeating.

 5             MS. KORNER:  I understand that.  If there was a mistake in the

 6     transcript it should have been pointed out a long time ago.

 7        Q.   Please read out the sentence, Mr. Bjelosevic.

 8        A.   "The Serbian MUP has to start work as soon as possible, if only

 9     to preserve the bridges across the Drina River."

10             MS. KORNER:  Actually it makes more sense, it has to be said.  I

11     rather think, Your Honours, rather than it being a mistake, I think it's

12     just a misspelling.

13        Q.   All right, can we move, please, because I don't want to spend too

14     much time on this document again.  Mr. Jesuric, later became, did he not,

15     the chief the CSB in Bijeljina; is that right?

16        A.   I think that he was the chief of a public security station in

17     this relevant period.

18        Q.   Yes, but I said later he became, did he not, chief --

19        A.   Probably later.

20        Q.   He says -- he is talking about -- not like you, complaining about

21     not receiving assistance from MUP and says that:

22             "I do not trust our people.  I only trust my own people and

23     weapons that I have acquired and hidden."

24             You heard him say that, did you?

25        A.   Yes, that's part of his contribution to the debate.

Page 20874

 1        Q.   Did it strike you in any way as odd or unusual or criminal that

 2     Mr. Jesuric should be acquiring and hiding weapons?

 3        A.   Well, a lot of things were disjointed, I may say so, at the time.

 4     So I would characterise this as one such phenomenon.  If you look at

 5     daily bulletins from that period and see what was point happening, you

 6     would realise that the security system had been disrupted to a great

 7     extent, that there was general mistrust not only on ethnic bases but also

 8     among staff, but here he says it is true that he couldn't receive

 9     anything that he required through the usual channels.

10        Q.   Right.  Mr. Savic, who then became the CSB chief in Trebinje,

11     says, "We are already establishing a Serbian SJB."  So it's right, isn't

12     it, by the 11th of February there were active moves taking place to

13     separate up the territories and the MUP to go with them?

14        A.   Yes, but all of this should be perceived in the context of cause

15     and consequence.  You can see that Jesuric, as well, and Mr. Savic are

16     saying here that there are problems concerning recruitment, employment,

17     and things of that nature.  Therefore, that was a consequence of a

18     situation that was prevailing at the time and, as I said, should be

19     perceived in that context.

20        Q.   Let's look at one more final speech on this document.

21     Mr. Draskovic, which you will see on the bottom of page 3 in English and

22     it's fifth page in B/C/S.  Mr. Draskovic really sums it all up, doesn't

23     he:

24             "This is the first time we are telling one another the truth,

25     without the people who have been holding us back."

Page 20875

 1             And can I suggest, Mr. Bjelosevic, that he was talking about

 2     Mr. Zepinic there, wasn't he?

 3        A.   Well, I really would like [as interpreted] to presume to try and

 4     interpret what somebody else said in this meeting.

 5        Q.   "We need to disassociate ourselves from Alija Delimustafic and

 6     his policies which are directed against the Serbian people.  The decision

 7     from this meeting is to be submitted to the council of ministers and the

 8     Assembly of the Serbian Republic of the BiH ratified and put into

 9     action."

10             And Mr. Devedlaka.

11             MS. KORNER:  Over the page, please, in English.  Next page in

12     English, please.

13             MR. ZECEVIC:  Is there a question?

14             MS. KORNER:  Just a minute, please.

15        Q.    Mr. Devedlaka:

16             "I think we can see the people we can count on and the Law of

17     Internal Affairs and the rule manual should be adopted immediately."

18             Now, Mr. Bjelosevic, it's right, isn't it, that the whole of this

19     meeting was convened and discussed how to set up an independent Serbian

20     MUP with its own minister, its own laws?

21        A.   Well, I never saw in any place anywhere the word "independent."

22     I already told you how I saw this meeting and how I understood the

23     conclusions, and I believed at the time that that was something that was

24     or had been discussed with the collegium of Minister Delimustafic.

25        Q.   But, I mean, just look at conclusion number 3, please.

Page 20876

 1             MS. KORNER:  Sorry, the next page in B/C/S.

 2             THE WITNESS: [Interpretation] Yes.

 3             MS. KORNER:

 4        Q.   Number one says:

 5             "Establish the Serbian collegium in the SRBH MUP.  The Serbian

 6     collegium of the SRBH is hereby instructed to carry out all the

 7     preparations necessary for the functioning of the Serbian MUP after the

 8     promulgation of the Serbian Republic constitution."

 9             A separate state was in the process of -- had been set up and was

10     in the process of being organised.  That's what was happening, wasn't it?

11        A.   Well, that was a political way of resolving certain issues.  As

12     you can see, also discussed here was to go in that direction but only

13     after the promulgation of the constitution.  Well, now, I'm reminding you

14     again of the political negotiations that were conducted in various places

15     and where various options about the division of Bosnia-Herzegovina or

16     about keeping Bosnia-Herzegovina in Yugoslavia, et cetera, were

17     discussed.

18        Q.   Leaving that aside, and can I say, Mr. Bjelosevic, that's all I'm

19     trying to get at.  In one sense, I'm not suggest there's anything wrong

20     with it, but what was being discussed here was clearly, as you say, it

21     was a political way of resolving certain issues, as you can see, also

22     discussed here was to go in that direction but only after the

23     promulgation of the constitution.  Now, that's right, isn't it,

24     Mr. Bjelosevic, this was a discussion of the police force that had to go

25     with the establishment of the independent state of Serbia -- independent

Page 20877

 1     within Bosnia of Serbia, Serbian Republic?  That's what this meeting was

 2     about, wasn't it?

 3        A.   But take a look at conclusion number 1.  They are talking the

 4     whole time about the MUP of the Socialist Republic of Bosnia-Herzegovina

 5     and its composition.

 6        Q.   Yes, Mr. Bjelosevic, I agree.  It's an accruing series of steps

 7     in the same way that the political was going on.  You have the Assembly

 8     followed by the declaration of the state, followed by the constitution,

 9     and then the various executive arms, if you like, of that body.  And this

10     is beginning with the Serbian collegium in BiH MUP going on to the

11     eventual separation; that's right, isn't it?

12        A.   But what had led to this final separation and the conflict is

13     something that is really very complex.

14        Q.   Mr. Bjelosevic, I understand that and I'm not suggesting to you

15     that it isn't complex, but all I'm concerned about is that what was --

16     and you were there, that this meeting was part and parcel of the series

17     of accruing steps that was going to create the police force that went

18     along with the Serbian Republic.  And it really is obvious, isn't it, and

19     you were there, you can see it from what was happening and from the

20     background?

21        A.   But I would just like to remind you that I have the feeling that,

22     let me put it this way, you are looking at this unilaterally.  I would

23     like just to remind you what was the significance of sending exclusively

24     Muslim inspectors to the Doboj CSB.  Wouldn't you call that a separation

25     or tearing up?

Page 20878

 1        Q.   No, no, I am sorry, Mr. Bjelosevic.  I'm going to stop you

 2     because it's not like this isn't something that you haven't said over and

 3     over again.  I understand your position on this.  You are saying that the

 4     BiH MUP was behaving exceedingly badly under Mr. Delimustafic and that he

 5     was operating separatist policies.  I have grasped what you said.  I

 6     simply want your take on this meeting.  Was not, and I'll repeat this for

 7     one last time, this meeting designed to establish at the right time the

 8     Serbian MUP?  It's a simple question.

 9        A.   I told you earlier how I perceived this meeting, and if I remind

10     you of my conduct, you would see that it is consistent with what I said.

11     I saw this meeting as the forming of the personnel within the Bosnian MUP

12     with a view to improving things.  My behaviour in a later period proves

13     that I thought about this seriously and I thought that communication was

14     possible, that there were dispatches and I did my best for us to function

15     within the MUP of the Socialist Republic of Bosnia-Herzegovina and I did

16     my best not to allow into the MUP all sorts of groups, volunteers,

17     criminal elements, et cetera.  And that is how I understood it at this

18     particular period as well.

19        Q.   Last time then, are you saying to this Court now that this

20     meeting had nothing whatsoever to do with the eventual when the

21     constitution was promulgated, totally separate Serbian MUP?

22        A.   No, that's not what I said.  I just explained how I understood it

23     at the time.

24        Q.   All right.  I really think the time has come to stop this one.

25     And just for the last time, Mr. Zecevic asked you a leading question,

Page 20879

 1     namely, about this meeting and the conclusions, 19524:

 2             "To the best of your recollection, was one of the conclusions

 3     that the positions reached at the 11th of February meeting should be

 4     notified to Minister Delimustafic, that the ministry should be given

 5     dead-lines, that the situation established to be irregular would be

 6     rectified?"

 7             And you answered:

 8             "Yes."

 9             Well, we've looked at the conclusions and that conclusion is not

10     there, is it?

11        A.   I have to take a look.  There was mention about making a request

12     of the minister and, actually, that members of the collegium were going

13     to ask for rectification, but I don't know whether that was entered as a

14     separate conclusion or not.

15        Q.   Can we move on, please, to the very next day, please.

16             MS. KORNER:  Can we have, please, document P527, tab 10.  Not a

17     document you were shown before, I think, by Mr. Zecevic.  Two days later,

18     sorry.

19        Q.   This is a dispatch from Mr. Mandic dated the 13th of February,

20     addressed to the CSB Banja Luka, Mr. Zupljanin; Doboj, yourself; Gorazde,

21     Stojanovic, and then various SJB chiefs, Savic as they then were,

22     Cvijetic, I think Bijeljina should be -- it says illegible but it should

23     be Jesuric.  We can just make that out in the B/C/S.  And to Mr. Stanisic

24     who, in fact, was still at the meeting and then apparently head of the

25     SUP for the city of Sarajevo, in fact the very next day he was appointed

Page 20880

 1     the advisor to Mr. Delimustafic.

 2             Now:

 3             "Following the conclusions reached at the meeting, please set up

 4     and have a meeting with all senior executives of the MUP SRBiH in your

 5     area and inform me accordingly."

 6             It's only addressed, isn't it, to the -- I said there were five

 7     Serbian CSB heads.  It appears that there were four if you include the

 8     city of Sarajevo.  Did you get that dispatch?

 9        A.   Yes.

10        Q.   Are you able to say why it was only addressed to Serbs?

11        A.   Well most probably because these people were present at the

12     meeting held on the 11th.

13        Q.   First of all, did you hold the meeting with your senior

14     executives?

15        A.   No, not on this issue.

16        Q.   What was the issue that you were holding a meeting about, because

17     that's not clear from this dispatch?

18        A.   I don't understand.  I did not hold a meeting with my senior

19     staff on this issue.  That's my answer.

20        Q.   I understand that, but I don't know what you mean and that's why

21     I'm asking you by this issue, what issue?

22        A.   The issue that is requested or contained in this dispatch.

23        Q.   Well, forgive me, Mr. Bjelosevic, what this says is please set up

24     and have a meeting with all senior executives following the conclusions

25     at the Banja Luka meeting.  Sorry, what issue were you to discuss with

Page 20881

 1     your senior executives?

 2        A.   What stems from this dispatch, it says that all the senior staff

 3     members should be informed about the conclusions in a meeting and that

 4     these conclusions, as I said, be imparted on them.  Inform them.

 5        Q.   Are we talking -- as you said, the conclusions we looked at

 6     forever, I think there are 18 of them or whatever, should be given to the

 7     senior executives?

 8        A.   Yes, that's what the dispatch says.

 9        Q.   Right.  And was -- did the senior executives mean executives from

10     all nationalities or just Serb?

11        A.   If you read this, you can see that this applies to all

12     executives.  There is no specific nationality mentioned.

13        Q.   In that case, and you may not know the answer to this, why didn't

14     Mr. Mandic want this -- these conclusions put to every single CSB area,

15     all nine of them, so that they should all understand the conclusions of

16     the meeting?

17        A.   I think this question should better be asked of Mr. Mandic.  It

18     was him who sent this and maybe he could explain why he wanted these

19     meeting to be held.

20        Q.   All right.  Why didn't you hold the meeting then to put the

21     conclusions of the Banja Luka meeting to your staff?

22        A.   I was contemplating on how this might affect the functioning of

23     the service.  I was concerned about that.

24        Q.   I don't -- well, do you mean that you actually understood that to

25     put those conclusions would be effectively saying we are setting up a

Page 20882

 1     separate Serbian MUP?

 2        A.   Well, not exactly like that, but my assessment was that at that

 3     time they could have caused certain turbulences within the already shaken

 4     and undermined relationships and lack of trust and everything else

 5     because that was also the time when there were very intensive political

 6     talks being held about Bosnia-Herzegovina, and I thought it was better to

 7     wait for the outcome because it would never be late to put this issue on

 8     the agenda.  In other words, I tried to take a pragmatic approach and to

 9     try as much as possible to keep the service together and operating as a

10     single entity.

11        Q.   Would it be right to say, Mr. Bjelosevic, then and indeed much

12     later, you weren't sure which side to align yourself with?

13        A.   Well, maybe you have phrased it in a way that seems either/or and

14     that's not the way my thinking went.  I had a clear-cut Yugoslav

15     orientation and there is nothing uncertain about that.  In this

16     situation, however, what was in my mind was the role of the service and

17     what it was.  I made a maximum effort for it to function as prescribed by

18     law and to keep a stable security situation in place as much as possible.

19     My position was always one of principle, that politics should do its own

20     job but not at the expense of the service.

21        Q.   All right.

22             MS. KORNER:  Sorry, Your Honours, trying to see whether I can

23     just skip a document just to move on.

24        Q.   Did you know that there was an Assembly on the 15th of February

25     of 1992?

Page 20883

 1        A.   Which Assembly?  I don't know.  I cannot remember now what

 2     happened on the 15th of February.

 3        Q.   Sarajevo, it was the 7th session.  Did you know Vojo Kupresanin?

 4        A.   Yes, I knew who Vojo Kupresanin was.

 5        Q.   Yes, but had you actually ever met him?

 6        A.   Was an MP.

 7        Q.   From the Krajina?

 8        A.   I think that he was an MP from Srbac.  I know him.  I think that

 9     we met somewhere, but, how should I put this, there was no relationship

10     involved.  I know who Vojo Kupresanin is.  I know that he was an MP.  I

11     know who you are talking about.

12        Q.   I just want to ask you about something he said during this

13     session when there was a discussion on the constitution and see if you

14     agree with that.  He said, "I fail to find" --

15             MS. KORNER:  I am sorry, Your Honours, I'm not going to put it

16     up:

17             "I've failed to find a reference to a Serbian police in the

18     constitution or to any other police for that matter "--

19             MR. ZECEVIC:  I understand that you are not going to put it on

20     the monitor, but can we at least have the reference so we know what you

21     are reading from.

22             MS. KORNER:  Yes, it's the 7th Assembly of -- I suppose there's

23     no way of avoiding it.  Can we have it up, please.  P1988.  It is at

24     page 42 in English, tab 10 bis, and at page 43 in B/C/S.  Can we go,

25     please, in English to page -- probably 42.  Yes, that's right.  And in

Page 20884

 1     B/C/S to page 43.  I think we'll find that is on the next page in B/C/S.

 2     It shows Vojo Kupresanin, one of the few I can read in Cyrillic.  Sorry,

 3     I need the next page in English, please, and the next page in B/C/S as

 4     well.

 5        Q.   Top of the page in English and somewhere in that B/C/S part on

 6     that page he says:

 7             "If this is a Serbian Republic, can it have any other police but

 8     a Serbian police?  The Serbian police should have their own insignia,

 9     they should have their own symbols and their ties with Serbian history

10     and Serbian tradition."

11             That's what Mr. Kupresanin said.  Mr. Bjelosevic, do you agree

12     with that, that as a matter of common sense, if nothing else, by February

13     it was clear that there was and had to be a separate police if there was

14     a separate Serb state?

15        A.   Generally speaking, politicians have a wide field in terms of

16     their behaviour, discussions, their actions.  I have my own view but I

17     don't know whether it matters at all at this point in time and whether

18     it's relevant for the matter that was being resolved here.  When MPs are

19     elected, it is sufficient for someone to submit his name and he is placed

20     on a list.  And then -- I don't know, I don't know, this is his position,

21     this is his view and I wouldn't want to go into that.

22        Q.   All right.  Well, I'm going to try and move through a bit more

23     quicker.  Through your cousin, Mr. Bjelosevic, who was a member of this

24     Assembly, did you become aware that there were, during March in

25     particular, endless discussions, not endless, wrong word -- there were

Page 20885

 1     discussions about the setting up of a Serb police eventually culminating

 2     in Mr. Stanisic, as we saw, becoming the minister on the 24th of March?

 3        A.   I hardly ever saw the gentleman who was an MP, my relative, at

 4     the time because the situation on the ground was very complicated and

 5     there was very little time available.  I know that there were certain

 6     activities underway, there's no denying that.  That did happen.  I didn't

 7     have to hear about it from my relative because that was in the media.

 8        Q.   And, indeed, on the very Assembly on the 24th of March, can we

 9     just very briefly look at what Mr. Karadzic says.

10             MS. KORNER:  Could we have up, please, P708 which is - would you

11     believe it - tab 10 sexies, and could we go in that -- it's the entire

12     speeches of the 12th session on the 24th of March, in English, please, to

13     page 16.

14             THE WITNESS: [Interpretation] That's what I thought on the 18th

15     of March.  It's a stenogram.

16             MS. KORNER:

17        Q.   Sorry, no, I don't know what we are looking at.  It should be

18     P708, dated the 24th of March?

19             MR. ZECEVIC:  I don't think that document was announced.

20             MS. KORNER:  Well, it should be.  It's on my list.  I don't want

21     the 18th of March anyhow, it's the 24th of March.  And it should be -- so

22     sorry, it's tab, so sorry, it's my fault, I've got hem in the wrong

23     order.  I apologise, Your Honours, it's entirely my fault, it's tab 11,

24     which is P198.  Sorry.  Can we turn to page 16 in English, please, and in

25     B/C/S, it's ...

Page 20886

 1             THE REGISTRAR:  Your Honours, for the record the English version

 2     has only 15 pages.

 3             MS. KORNER:  It's the same -- no, no, okay.  Let's just forget

 4     that and I'll move on.  This is the problem, that's right, I inserted it.

 5     It was the extra one I inserted and sent a message around saying that I

 6     wanted the full stenographic records.  In fact, I think I gave

 7     notification because I realised it late at night or latish.  Anyhow,

 8     Your Honours, in order to not waste time this has become too protracted

 9     and order to -- can we move on, please, to the Serbian municipality of

10     Doboj which was declared two days later as a result of instructions

11     apparently that Karadzic gave which is tab 11A.

12             MR. ZECEVIC:  I am terribly sorry, there are two things in the

13     transcript.  On page 69/22, Ms. Korner's question was recorded as part of

14     the answer of the witness.  After the words -- after the sentence:

15             "I know who Vojo Kupresanin is.  I know he was an MP.  I know who

16     you are talking," I assume, "about."  And then it says, "I just want to

17     ask you about something he said," that is the question of Ms. Korner.

18     That's one thing.

19             And the second thing is on page 72, line 12:

20             "Can we move on, please, to the Serbian municipality of Doboj

21     which was declared two days later as a result of instructions apparently

22     that Karadzic gave which is tab 11A."

23             I'm not sure what is the reference to instructions apparently

24     that Karadzic gave.

25             MS. KORNER:  Yes, I am sorry, Your Honours, it's quite right.

Page 20887

 1     It's -- the problem is because somehow or other I must have got the wrong

 2     exhibit number when I was doing this but what should have been in there

 3     was the full speeches, the 24th of March and where Karadzic says, well,

 4     as I haven't got it up, I will have to leave it but I'll correct that.

 5        Q.   Can we look now, please, however, at tab 11A, "Decisions to

 6     establish the Serbian municipality of Doboj."  The Assembly of the

 7     Serbian people of the Doboj municipality.  Were you present at this

 8     meeting?

 9        A.   No.

10        Q.   All right.  And it says that the territory of the Serbian

11     municipality of Doboj, shall comprise the populated localities and then

12     gives a long list.  Now, if at all possible, I think we need to have up

13     the map of Doboj which you made, not the one you made markings on before,

14     but a clean map which is at -- yes, what is the exhibit number?  1344.

15     P1344.

16             MR. ZECEVIC:  I am sorry.  I am just trying to be helpful.  It's

17     tab 230 in the binders, so perhaps it would be easier for the witness to

18     look at the document.

19             MS. KORNER:  Yes, all right.

20             MR. ZECEVIC:  It's the red binder that he has before him, it's

21     tab 230.

22             MS. KORNER:  I'd like, if I may, please, to have a split screen.

23     Could we have that map up at the same time as the -- no, the page of the

24     other document that we were looking at.

25             MR. ZECEVIC:  Tab 11A.

Page 20888

 1             MS. KORNER:  But unfortunately that means nothing to the --

 2             MR. ZECEVIC:  1D --

 3             MS. KORNER:  1D420.

 4        Q.   Now, this is a list which the self-proclaimed Serb Assembly in

 5     Doboj decides is going to form part of the Serb municipality; correct?  A

 6     list of the places, I am sorry?

 7        A.   Yes, that's what it says here.

 8        Q.   Right.  One of those places is a place called Bukovica Velika; is

 9     that right?

10        A.   Yes, Bukovica Mala and then Bukovica Velika.

11        Q.   Which we can see Bukovica Velika are on the map as a large dot, a

12     Serb army, just to the top right-hand of the -- left-hand, as you look at

13     it, of the circle saying Doboj in the middle; is that right?

14        A.   Yes, Bukovica Mala and then Bukovica Velika.

15        Q.   Next door to it, literally right next door to it was largely

16     Muslim inhabited area, wasn't it, called - and this is one that I am very

17     difficult to pronounce - Civcije.

18             MR. ZECEVIC:  Civcije.

19             MS. KORNER:  Civcije, thank you.

20        Q.   And the next word ...

21        A.   Civcije Bukovica, yes.

22        Q.   Another Serb proclaimed village or town was Prnjava Mali [phoen];

23     is that right?

24        A.   Yes.

25        Q.   Which was pretty close to Johovac which was apparently a Muslim

Page 20889

 1     area?

 2        A.   No, Johovac is a mixed area, mixed, but the population is

 3     predominantly Croat, but it is a mixed area.

 4        Q.   And Johovac is next door to Kotorsko which is largely a Muslim

 5     area; correct?

 6        A.   Yes.

 7        Q.   Now, how, given the proximity of non-Serb villages and towns to

 8     the Serb, was it going to be even remotely possible to carve out a Serb

 9     municipality which would be separate from the non-Serb areas?

10        A.   I don't know about that.  I wasn't making this.

11        Q.   But, Mr. Bjelosevic, you told us earlier that there was being to

12     be a creation of separate Serb municipalities.  In Doboj, an area that

13     you were very familiar with, that simply was not possible, was it,

14     without causing conflict?

15        A.   I didn't say that that was supposed to be done.  I was saying

16     that that was the policy of the three national parties and that they had

17     agreed on that.  I didn't say that that is what was supposed to be done.

18     I was just saying that that is what they were doing.

19        Q.   Well, we are going to come to the documents in a moment, but they

20     didn't agree to that, did they?  This was a unilateral declaration by the

21     so-called Serb Assembly that these areas would be part of the Serb

22     municipality?  That's right, isn't it, on the 26th of March?

23        A.   I cannot really speak about this.  I was not present there, I was

24     not a member of the Assembly, I was not on any political body that was

25     involved in this, so this was something that was far away from me.

Page 20890

 1        Q.   I am sorry, Mr. Bjelosevic, Mr. Ljubicic who that very same day

 2     became the president of the Assembly of the Serbian people was somebody

 3     you knew, wasn't it?

 4        A.   Yes.

 5        Q.   And again whose phone number you had in your -- in your diary or

 6     whatever you call it, record of meetings?

 7        A.   Well, I don't know, but it's possible that I had it.  He stayed

 8     on as president of the Municipal Assembly afterwards.  Before that, he

 9     was vice-president of the Municipal Assembly and Ahmed Alicic was

10     president.  I don't know what the point of this number is.

11        Q.   Whether you knew it at the time or later, Mr. Bjelosevic, you

12     knew, didn't you, that there was this Serbian Assembly which had declared

13     this Serbian municipality of Doboj?

14        A.   I wasn't the only person who knew that.  It was a public matter.

15     It had been publicly declared.

16        Q.   I know.  But you, as chief of the CSB, as a police officer, could

17     see, couldn't you, that this was going to certainly cause conflict?

18        A.   I saw a great many things that was going to cause conflict and

19     the disintegration of the system, many, many things, but I don't see what

20     the point is now.  If somebody thinks that I could have prevented it and

21     changed the current, I am sorry, but there was no way I could have done

22     that.

23        Q.   I'm not suggesting for one moment, Mr. Bjelosevic, that you could

24     have changed the current.  I am suggesting, however, that you were

25     acquiescing with what was going on.

Page 20891

 1        A.   I don't know what that would mean acquiescing.  What could a

 2     person change?  I did not accept things, many things just happened.  Many

 3     things that I thought should not have happened.  Now, if everything that

 4     happened had not been prevented means acquiesce per se, then I do not

 5     agree.

 6        Q.   Well, you see --

 7        A.   Sorry, these are political matters.  I could not effect any of

 8     that, and it was not for me to accept or not accept.

 9             THE INTERPRETER:  The interpret are did not hear the end of the

10     sentence.

11             MS. KORNER:

12        Q.   Sorry, could you repeat the end of the sentence, Mr. Bjelosevic?

13        A.   I'm saying that everyone knows full well what is everyone's job:

14     what is the job of the politicians, what is the job of the army, what is

15     the job of the police.  This was a political issue and it was being

16     resolved at a political level.  I have presented my own position a moment

17     ago, what it means, in my view, if the police or if the military start

18     resolving political issues.  That is a coup d'etat then.

19        Q.   Sorry, Mr. Bjelosevic, we've been over and over and over again

20     this.  The police, the MUP, the Serbian members of the then BiH MUP were

21     inextricably linked, weren't they, with the political aspects?  That's

22     right, isn't it, we spent all morning looking at?

23        A.   I do not agree with you fully.

24        Q.   Well, let's finally --

25             MS. KORNER:  I see it's quarter to 2.00.

Page 20892

 1             JUDGE HALL:  When you said "finally," I thought you were going to

 2     ask one last question.

 3             No, no, I want to go on to another documents, Your Honours.

 4             JUDGE HALL:  Very well.

 5             MS. KORNER:  The witness can go, but can I just ask Your Honours

 6     one question after -- on the timetabling side.

 7             JUDGE HALL:  Yes.

 8             Mr. Bjelosevic, we will continue with your cross-examination

 9     tomorrow.  The usher will see you out.

10             MS. KORNER:  Yes, Your Honour, if he can just leave the diaries

11     with us.  Thank you.

12                           [The witness stands down]

13             MS. KORNER:  Your Honours, I was just wondering whether there was

14     any possibility, Your Honours, because it is taking a very long time to

15     get through this, whether we could sit an extra session tomorrow

16     afternoon, if that's at all possible.  I would hope and I definitely have

17     to conclude my cross-examination on Monday, but I'm a little concerned

18     that looking at the topics we've hardly moved at present.  So I'm just

19     wondering, I raise that as a query, whether it would be possible to sit

20     an extra session tomorrow afternoon.

21             MR. ZECEVIC:  Your Honours, if I --

22                           [Trial Chamber confers]

23             MR. ZECEVIC:  I am definitely -- I would love to be able to

24     accommodate Ms. Korner.  However, I have a witness coming for proofing.

25     The next witness is again my witness, and I have to proof the witness.

Page 20893

 1     Therefore I cannot -- otherwise we have to postpone his beginning of

 2     the -- of his testimony next week.  So I have to have the afternoons

 3     available.  That is what I planned, Your Honours.  I just wanted the

 4     Trial Chamber to have that in view.  Thank you.

 5             JUDGE HALL:  Ms. Korner, all in all, how much longer you expect

 6     you will be with this witness?

 7             MS. KORNER:  Well, Your Honours, certainly the rest of this week

 8     and into Monday.  As I said, it's 20 hours definitely and I think I've

 9     only had, so far, about four or five.  My anxiety -- can I say it's

10     purely personal I have to go to a funeral on Tuesday and in London, and

11     so I'm very anxious to be able to complete and also Mr. Zecevic's

12     re-examination by Monday afternoon -- by the end of the Monday session.

13     And that's why I raised it.

14             JUDGE HALL:  Anyway, we've heard what Mr. Zecevic has had to say.

15     We'll, nevertheless, make the usual inquiries and announce tomorrow

16     morning.

17             MS. KORNER:  Yes, thank you.

18             JUDGE DELVOIE:  Ms. Korner, there were two or three documents you

19     used today you didn't tender.  They don't have been exhibit number yet.

20     I suppose --

21             MS. KORNER:  Are those the intercepts?

22             JUDGE DELVOIE:  Yes.

23             MS. KORNER:  Your Honours, I wasn't -- if the witness says he

24     doesn't recognise them, it's the content rather than the actual --  I

25     think one of them was an exhibit, I hope.

Page 20894

 1             JUDGE DELVOIE:  No.

 2             MS. KORNER:  Yes, the Zepinic/Karadzic one was.  That's the only

 3     one that's --

 4             JUDGE DELVOIE:  Okay.  Thank you.

 5                           --- Whereupon the hearing adjourned at 1.48 p.m.

 6                           to be reconvened on Thursday, the 19th day of May,

 7                           2011, at 9.00 a.m.