Tribunal Criminal Tribunal for the Former Yugoslavia

Page 22795

 1                           Tuesday, 5 July 2011

 2                           [Open session]

 3                           [The accused entered court]

 4                           --- Upon commencing at 9.07 a.m.

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

 6     everyone in and around the courtroom.

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

 8     Stojan Zupljanin.

 9             JUDGE HALL:  Thank you, Madam Registrar.

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

11     please.

12             MR. HANNIS:  Good morning, Your Honours.  For the Prosecution,

13     I'm Tom Hannis along with Crispian Smith.

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

15     Slobodan Cvijetic, Eugene O'Sullivan, Ms. Tatjana Savic, and joined by

16     our intern, Rodolphe Genissel, appearing for Stanisic Defence this

17     morning.  Thank you very much.

18             MR. ALEKSIC: [Interpretation] Good morning, Your Honours.

19     Aleksandar Aleksic for the Zupljanin Defence.

20             JUDGE HALL:  Thank you.

21             Before we begin with the witness who is scheduled today, there

22     are a number of matters which the Chamber would raise.

23             The first is that to settle the matter of the UN holiday which

24     intervenes shortly after the scheduled beginning of the resumption of

25     this case, we confirm that we will reconvene on the 31st of August,

Page 22796

 1     instead of the 29th.

 2             The second matter is that the sitting arrangements that have been

 3     confirmed has confirmed e-mails that the Stanisic and Zupljanin case will

 4     sit in sets of two weeks from Monday of the first week to the Friday of

 5     the one following.  Accordingly, in the week when the court reconvenes on

 6     the 31st of August, it will adjourn for two weeks and all other factors

 7     remain unchanged.  That is, it will reconvene on the 9th of September.

 8             The Zupljanin Defence, we expect, would start its case when the

 9     Chamber reconvenes on the 31st of August, and, accordingly, the

10     Zupljanin Defence is to provide its list of witnesses in the order that

11     they will be called by the 8th of July, which is the end of this week.

12             Yesterday, there was filed a motion by the Stanisic Defence for

13     leave to amend its Rule 65 exhibit list, and we would request the

14     Prosecution urgently respond to that.  As you would be aware from reading

15     it, the motion seeks the addition of two documents both of which were

16     disclosed to the Defence by the Prosecution, and the Prosection itself

17     intends to use one of the documents with the witness who is next on the

18     stand.

19             Mr. Hannis, could we inquire as to whether you are able to

20     respond immediately or whether we could expect to hear from you at the

21     close of business today.

22             MR. HANNIS:  No, Your Honour.  It was on my list to tell you this

23     morning that the Prosecution has no objection to the addition of those

24     two documents.

25             JUDGE HALL:  Thank you.  So noted.

Page 22797

 1             Could we go into private session for the other two matters,

 2     please.

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 5                           [Open session]

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

 7             JUDGE HALL:  Sorry, before you begin, Mr. Hannis, I'm reminded

 8     that having regard to what the -- you said earlier that we should

 9     formally grant the motion of the Stanisic Defence to amend its Rule 65

10     list.  Thank you.

11             Yes, Mr. Hannis.

12             MR. HANNIS:  Thank you, Your Honour.  You mostly answered the

13     questions I had on my list to raise this morning.  But I just wanted to

14     clarify your ruling.  As I understand it then, after the recess, the

15     first time we will be sitting will be on 31st of August, that's the

16     Wednesday after the Tuesday UN holiday.

17             JUDGE HALL:  That is correct.

18             MR. HANNIS:  We would sit then for the remaining three days that

19     week and five days the following week, and that is through September 9th?

20             JUDGE HALL:  You understand us correctly.  Thank you.

21             MR. HANNIS:  And then am I correct then for the next two weeks

22     you and Judge Delvoie would be in Haradinaj, and we would return to this

23     case on the 26th of September?

24             JUDGE HALL:  Well, as we understand it, the previously announced

25     two week/two week pattern would then pick up.  So whatever your calendar

Page 22799

 1     tells you, that would be correct.  Of course, to state the obvious, once

 2     this pattern begins, we would see whether for purely practical reasons it

 3     has to be varied, but that's how we start.

 4             MR. HANNIS:  Thank you.  The other matter is you have directed

 5     the Zupljanin Defence to file by the end of this week the --  their

 6     batting order for their witnesses.  We would ask that they also indicate

 7     or confirm the mode of testimony for those witness.  That is, the ones

 8     that have previously been listed as viva voce to inform us whether or not

 9     they're still viva voce, there's no request to change any of the proposed

10     modes of testimony.

11             And I believe that was the last thing I needed to raise.

12             Thank you.

13             JUDGE HALL:  Thank you.

14             Yes, Mr. Zecevic.

15             MR. ZECEVIC:  Your Honours, may we go back in a private session

16     for just a second.

17             JUDGE HALL:  Yes.

18                           [Private session]

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22                           [Open session]

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

24             MR. ZECEVIC:  Your Honour, with all due respect, I must

25     respectively remind the Chamber that there are still three pending

Page 22801

 1     motions from -- from Stanisic Defence, and those are two -- two motions

 2     for amendments to 65 ter of 6th of May and 3rd of June, and the admission

 3     of expert report and the -- and the footnotes filed on the 23rd of June.

 4             JUDGE HALL:  You needn't feel embarrassed about that reminder,

 5     Mr. Zecevic.  The Chamber, of course, is alive to the fact that these

 6     motions are outstanding and that you couldn't formally close your case

 7     until they are resolved.  But we will tell you that they are well in hand

 8     which is an explanation that you would have heard before.  I can say

 9     nothing further.  The Chamber certainly hasn't forgotten them.  But as I

10     said, you needn't feel embarrassed in terms of the exercise of your own

11     duty to so remind the Chamber.

12             MR. ZECEVIC:  Thank you, Your Honours.

13             JUDGE HALL:  And if there is nothing else that need delay us,

14     could the usher please escort the witness in.

15             While the witness is on his way in, I know I have this written

16     down somewhere but could the parties indicate to me the times that we're

17     dealing with.

18             MR. HANNIS:  Your Honour, I think Mr. Zecevic originally

19     indicated 20 hours for direct examination.  I had not indicated a time.

20     I thought something in the neighbourhood of 12 to 16 hours.  When I got

21     the proofing note this morning, seeing the eight very broad somewhat

22     vague topics, I guess I want to say 20 hours to be on the safe side.  I'm

23     confident it will be less than that.  But given what is in the proofing

24     note, I have some concerns that I may need more time than I originally

25     anticipated.

Page 22802

 1             And I don't know for the Zupljanin Defence if they have an

 2     estimate.

 3             MR. ALEKSIC: [Interpretation] Your Honours, my learned friend

 4     Mr. Krgovic will examine this witness.  Just to be on the safe side, I

 5     will state my estimate of two hours.  We may, after all, refrain from

 6     examining this witness all together.  But to be safe, I'll say two hours

 7     for D2.

 8                           [The witness entered court]

 9             JUDGE HALL:  Thank you, counsel.

10             Sir, will you please read the solemn declaration on the card that

11     the usher is now handing to you.

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

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

14                           WITNESS:  GORAN MACAR

15                           [Witness answered through interpreter]

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

17             And from your responses so far, I take it that you are hearing me

18     in a language that you understand?

19             THE WITNESS: [Interpretation] Yes.

20             JUDGE HALL:  I would begin by pointing out to you that the solemn

21     declaration that you have just taken imposes upon you an obligation to

22     speak the truth, and not to mislead the Trial Chamber.  This Chamber is,

23     as a part of the Tribunal, set up under the Statute which sets it up --

24     is empowered to impose sanctions for giving misleading or false testimony

25     before the Chamber.  So that is a reminder that I would give you at the

Page 22803

 1     beginning of each session -- of each day's sitting of the solemn

 2     declaration that you have taken and the obligations it imposes upon you.

 3             I would begin by welcoming you to the Chamber -- to the Tribunal

 4     and agreeing to appear as a witness.  And the first question I have is

 5     whether you have previously given testimony before this Tribunal or

 6     before any of the courts in any of the territories that comprise the

 7     former Yugoslavia.

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

 9             JUDGE HALL:  I will come back to explain to you briefly the

10     procedure so that you have an understanding as to how we -- how your

11     evidence will be led.  But would you begin by telling us your name,

12     please.

13             THE WITNESS: [Interpretation] Goran Macar.

14             JUDGE HALL:  What is your profession, or what was your

15     profession, and what is your date of birth, please.

16             THE WITNESS: [Interpretation] I was born on 14th November, 1954,

17     in Sokolac, Sokolac municipality, Republika Srpska, Bosnia-Herzegovina.

18             I'm an economist by training.

19             JUDGE HALL:  And what is your ethnicity?

20             THE WITNESS: [Interpretation] Serbian.  An Orthodox Christian.

21             JUDGE HALL:  Thank you.  You have been called as a witness by the

22     Defence of Mr. Stanisic, and council representing Mr. Stanisic will begin

23     by asking you questions.

24             When he is through, counsel for Mr. Stanisic's co-accused,

25     Mr. Zupljanin may, as you may have heard as you were walking into the

Page 22804

 1     courtroom, himself opt to ask questions of you.  That remains to be seen.

 2             After counsel for Mr. Zupljanin, then counsel to your left, who

 3     represents the Prosecution, would have a right to cross-examine.  And

 4     then counsel calling you would have a right to re-examine in matters

 5     which -- on which they wish clarification arising out of your testimony,

 6     out of your cross-examination.

 7             The Judges who comprise the Trial Chamber may at that point or

 8     indeed at any earlier point themselves have questions of you.

 9             In terms of the time that this exercise will take, counsel

10     calling you have indicated that your testimony is expected to run over a

11     period of 20 hours.  Counsel for the Prosecution has indicated a like

12     period of time, so a total of 40 hours.  And Mr. Aleksic, on behalf of

13     the Zupljanin Defence, has said that if they have any questions it is

14     unlikely to exceeds two hours.

15             The Court sits either in morning or afternoon sessions because

16     with the limited courtroom space, we must make the courtroom available

17     for other trials.  And I believe we are scheduled to sit in morning

18     sittings for the entirety of this week.

19             Those periods of time that I have given you are broken up

20     according to each day's sitting, which, for the morning would begin at

21     9.00 and end at 1.45, are broken up in periods of not more than an hour

22     and a half, for the technical reasons that the proceedings of the

23     Tribunal are recorded and the tapes have to be changed at those

24     intervals.  That allows for the convenience of yourself, counsel, and

25     everyone else concerned to have breaks during the course of the day's

Page 22805

 1     sitting, that is, between the 9.00 to 1.45 day that comprises the period

 2     that the Court would sit.  And -- but if for any reason you are

 3     distresses and need a break before the scheduled time, you would indicate

 4     that to us and we would certainly accommodate you.

 5             So unless you have any other questions by way -- that I can

 6     clarify for you, I would invite Mr. Zecevic, who appears as lead

 7     counsel ...

 8                           [Trial Chamber confers]

 9             JUDGE HALL:  The -- before -- I would invite Mr. Zecevic, who is

10     lead counsel for Mr. Stanisic, to begin his cross-examination [sic].  But

11     before he does, the Chamber requires and Mr. Zecevic would have

12     communicated this to you, and I -- I'm going to invite him and perhaps we

13     should go into private session briefly before his examination begins.

14             Could we do that now, please.

15                           [Private session]

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Page 22806

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12                           [Open session]

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

14             JUDGE HALL:  Yes, Mr. Zecevic.

15             MR. ZECEVIC:  Thank you, Your Honours.

16        Q.   [Interpretation] Good morning, Mr. Macar.

17        A.   Good morning.

18        Q.   Mr. Macar, tell me something about your professional background.

19     When did you first get a job with the Ministry of the Interior of the

20     Socialist Republic of Bosnia and Herzegovina?

21        A.   After obtaining my BA in economics in 1977, I started working on

22     the 6th of June, 1977, with the city secretariat of the interior of the

23     Ministry of the Interior of the former Socialist Federative Republic of

24     Bosnia and Herzegovina.  I worked in the white-collar crime unit as an

25     inspector.  I remained in that unit until 1982 when I moved on to work as

Page 22807

 1     chief of the crime unit in the secretariat of the interior, the municipal

 2     secretariat of the interior in Sarajevo's Centar municipality.  Centar.

 3     I remained in that position until 1987, which was when I went back to

 4     Sarajevo's SUP, secretariat of the interior of the city of Sarajevo, and

 5     I was back working with white collar crime.  I worked as an inspector

 6     there until 1990.

 7             At that point in time, I was appointed head of general crime unit

 8     with the crime police of the city secretariat of the interior.

 9             In 1992, I started working as a co-ordinator with the crime

10     police directorate of the Ministry of the Interior of the RS.  I was then

11     appointed chief of that directorate, and I remained in that position

12     until the end of 1995.

13        Q.   Thank you, sir.  You say that you went back to Sarajevo city SUP

14     in 1990.  How long did you work there for?

15        A.   I stayed with Sarajevo's SUP as chief of the general crime unit

16     between 1990 and the 3rd of April, 1992.

17        Q.   When did you start work with the Ministry of the Interior of the

18     Serbian Republic of Bosnia-Herzegovina?

19        A.   I started working with the Ministry of the Interior in the second

20     half of April, after the 19th of April, as far as I remember.

21        Q.   Mr. Macar, when did you first meet Mico Stanisic?

22        A.   I first met Mico Stanisic late in 1977, I believe, possibly early

23     1978.  I was doing a SAJ in his unit.

24        Q.   Thank you.  As for the period between 1990 and 1992, you said you

25     worked with Sarajevo's SUP, S-U-P; right?

Page 22808

 1        A.   Yes.

 2        Q.   The national parties emerged as victorious in the 1990 elections.

 3     Did that change anything about the way the Ministry of the Interior

 4     operated, and if so, what exactly?

 5        A.   After the victory of the national parties, all the politics in

 6     Bosnia and Herzegovina changed and obviously that reflected on the work

 7     of the Ministry of the Interior.  First, there was a peaceful lustration

 8     of the personnel working there from the municipal level all the way to

 9     the top of the MUP.  Many of the people working at the time took an early

10     retirement under the laws that then applied and some moved on to other

11     jobs in the Ministry of the Interior.  Obviously that had an immediate

12     effect on the quality of the work being performed by the ministry.  Late

13     in 1991 and early 1992, the impact of these national parties on the way

14     the Ministry of the Interior operated became very obvious.  The ministry

15     started breaking up at the seams along national lines or ethnic lines.

16        Q.   You said that there was a lustration effort in progress.  Can you

17     please explain what you mean.  A quiet purge.

18        A.   There were experienced professionals working there, probably

19     pursuing cases at the time against certain categories of persons.

20        Q.   I'm talking about this term that you used, the purge.  What does

21     that mean?

22        A.   That means certain people in leading positions were removed from

23     these leading positions in the Ministry of the Interior.  And this all

24     started with public security stations, the leading people there, and then

25     went all the way up to the very top of the Ministry of the Interior.

Page 22809

 1     People were removed from their positions.

 2        Q.   In 1991, what sort of a HR policy or personnel policy did you

 3     have in the MUP of the Socialist Republic of Bosnia and Herzegovina?

 4        A.   Before I answer this question, let me point out the following:

 5     Early in 1991, sometime in March, there was a census in Bosnia and

 6     Herzegovina.  Members of the Ministry of the Interior of both the public

 7     security and the state security following the census had information

 8     indicating that the leaders of the party of democratic action, along with

 9     certain people in leading positions who were ethnic Muslims from the

10     public security stations and the very top level of the MUP, had amplified

11     the results of the census, during the census and after the census,

12     representative of there being more people than there actually were.  They

13     included many of the citizens from the Sandzak area.  This is an area

14     straddling the border between the south of Serbia and the north of

15     Montenegro, ethnic Muslims living there, and also some in Kosovo, a small

16     portion of those.  This information was available to the public security

17     services and the State Security Services.  I don't think the census was

18     ever verified.  Information was just passed along like that, passed on to

19     the Ministry of the Interior.

20             I am not aware that anyone from the ministry ever responded to

21     those data or, indeed, that data was ever checked.  Doubts persist about

22     the results of the census.  The Muslim part of the population in

23     Bosnia-Herzegovina tried to avoid being registered all together, and they

24     wanted all the parameters from the 1991 census to simply be adopted for

25     the new round.  The Party of Democratic Action, after this last census,

Page 22810

 1     asked for the results of the census and the relevant proportions to be

 2     applied to the work and the manning and personal policies in the Ministry

 3     of the Interior as well.

 4        Q.   Let's take this one step at a time, sir.

 5             Mr. Macar, first of all, I have to ask you to slow down a little.

 6     All of your evidence is being interpreted, which is no simple task at

 7     all, given the fact that we are using a lot of data here.

 8             Based on such information as was available to you regarding the

 9     alleged blowing up of the numbers of Muslims from the Sandzak territory,

10     and then adding those numbers to the census lists in Bosnia and

11     Herzegovina, can you please tell me this:  Did Sandzak belong to Bosnia

12     and Herzegovina?

13        A.   No.  The Sandzak area straddled the border between south Serbia

14     and north Montenegro.

15        Q.   As far as you could tell, what was the ethnic makeup of the

16     Sandzak area?

17        A.   There was a Muslim majority there.

18        Q.   The information that was available to you in 1991 regarding the

19     numbers being boosted, the census numbers, I'm talking about the 1991

20     census, of course, do you remember what the discrepancy was, what the

21     differential was between the real numbers and the boosted numbers?

22        A.   I had an opportunity to check the numbers in my superior's

23     office.  The numbers would have been about 300.000 or 310.000 persons.

24        Q.   You mentioned your superior.  Who are we talking about here?

25        A.   Jozo Leutar, chief of the crime police sector in the secretariat

Page 22811

 1     of the interior of the city of Sarajevo.

 2        Q.   What was his ethnicity?

 3        A.   He was an ethnic Croat.

 4        Q.   Sir, first of all, the Republic of Bosnia and Herzegovina, how

 5     many citizens did it number, roughly speaking, at the time of the 1991

 6     census?

 7        A.   About 4 million, several 100.000s.  Maybe 300.000 or 400.000, as

 8     far as I remember.

 9        Q.   What about the Ministry of the Interior of the Socialist Republic

10     of Bosnia and Herzegovina?  Was the general principle that applied to

11     hire people along ethnic lines in order to have some sort of an ethnic

12     balance within the service?

13        A.   In the former Bosnia-Herzegovina, we tried to achieve some sort

14     of ethnic equality in terms of the numbers of people being hired and that

15     applied to the Ministry of the Interior, too.

16             At the time in the Ministry of the Interior, there were maybe

17     slightly over 40 per cent Serbs working there.  It is all about the

18     people who applied for these jobs.  The Serbs tended to apply more for

19     the uniformed jobs, and that is why the quality was slightly disrupted

20     there, as far as the uniformed jobs were concerned.

21        Q.   Can you please pause each time after I ask you a question so that

22     the interpreters can hear your answer and also one step at a time.

23             The 40 per cent Serbs, which segment of the Ministry of the

24     Interior is that in reference to?

25        A.   The police, the uniformed police on the beat.

Page 22812

 1        Q.   Thank you.  Let's go back to my original question:  What was the

 2     personnel policy following the census in the Ministry of the Interior of

 3     the Socialist Republic of Bosnia and Herzegovina?

 4        A.   Following the census, the Party for Democratic Action, in

 5     particular, tried to have this parity principle established in line with

 6     the results of the census.  Nevertheless, this equality, in terms of

 7     equal numbers, was not what it should have been, especially within the

 8     police, and I'm talking about the city of Sarajevo.  In the public

 9     security stations, you had reserve police forces.  And in most

10     municipalities the balance was disrupted and there were far more Muslims

11     being hired as reserve policemen.

12             One thing that is particularly noteworthy is this:  Many of the

13     Muslim citizens from Sandzak were being taken on as reserve policemen at

14     this time.

15        Q.   What about the citizens who arrived from the Sandzak territory?

16     Did they have the republican citizenship of the Socialist Republic of

17     Bosnia and Herzegovina?

18        A.   No they didn't.  They were either citizens of Serbia or

19     Montenegro.

20             And if I may just point out something else.  Already back as far

21     as 1990 and early 1991, there was a large-scale influx of people, ethnic

22     Muslims from Sandzak and Albanians from Kosovo.  Over that period, they

23     took over the black market economy across the city of Sarajevo.  They

24     started exchanging foreign currency out in the street.  They became

25     dealers of foreign currency.  There wasn't a single neighbourhood in

Page 22813

 1     Sarajevo where these people weren't operating.  Dozens and dozens of them

 2     literally selling money.  And they pursued all different kinds and forms

 3     of illicit trade in the city's markets, cigarettes, alcohol, food

 4     products, chemical products, that sort of thing.  The police assessment

 5     and the assessment of the inspectors was that in 1991, late in 1990 and

 6     in 1991, over the several hundreds of millions of euros were missing from

 7     the state budget of Bosnia-Herzegovina because of this illicit trade.  We

 8     tried to take a more organised approach in terms of fighting these types

 9     of crime.  In 1991, we had several police operations involving large

10     police numbers, and the operations were planned by the very leadership of

11     the police.  The principle being to gather as much information as

12     possible -- to keep the information from leaking out.  Most of the

13     operations failed because information leaked all the time.  Several

14     hundred policemen were involved in these operations.  We were trying to

15     fight this type of crime that was rife across the city.

16             I spoke to Mr. Leutar about the Muslim men involved with us in

17     the planning and carrying out of these operations, and it appeared at one

18     point that they were the source of these leaks.

19        Q.   Tell me, please, there's one thing we should clarify:  Was it

20     possible under the then-laws and regulations for citizens of another

21     republic to be -- to become members of the reserve police force in a

22     republic whose citizens they were not?

23        A.   The basic condition for somebody to be a member of the reserve

24     force was to have a permanent residence and to go through a vetting

25     process.  They had to be checked in -- whether they had a police file and

Page 22814

 1     so on.  And citizens of Bosnia and Herzegovina only should have become

 2     members of the police force.

 3        Q.   Was a condition -- was one of the conditions that they have a

 4     permanent employment?

 5        A.   That was one of the criteria.  It was not a criterion that could

 6     preclude anybody from becoming a member of the reserve force, but it --

 7     that was something that was considered too.

 8        Q.   You mentioned the checks in criminal records and police files for

 9     people who wanted to join the police force.  Were any other categories of

10     persons hired by the police during that period; and, if so, who?

11        A.   I can say that it was observed that people with a shady past had

12     been hired by the police, that some members of the reserve force had

13     committed crimes, although it was a strict rule that perpetrators of

14     crimes cannot become members of the reserve force.  That was especially

15     pronounced in the municipalities of Stari Grad and Centar, and I would

16     like to add the following, speaking about the reserve force:

17             In the Centar municipality, a huge number of reserve police

18     officers was employed, exceeding all reasonable criteria, so that, in my

19     street, for example, the citizens were wondering where are all these

20     reserve police forces had all come from.  They were all from Sandzak

21     because you could easily tell by their accent so that my street was

22     colloquially called Little Novi Pazar, and they were walking the streets

23     armed, even with long-barrelled weapons, and I didn't know at the time

24     why that was so.

25        Q.   When you said "my street," I didn't quite understand whether you

Page 22815

 1     lived there or ...

 2        A.   I lived in Sarajevo, in down-town Sarajevo, the Vanja Racica

 3     [phoen] street, and the municipal secretariat was two metres from my

 4     courtyard.  It was a small street, and it was easy to observe who entered

 5     the station, who exited, and who gathered round it.  The building itself

 6     was close to the government building of Bosnia-Herzegovina where my late

 7     wife worked, and a school and kindergarten to which our children went

 8     were also nearby.

 9        Q.   Thank you.  Did that situation create any problems for some

10     public security stations?

11        A.   In late 1991 and early 1992, there was an escalation of

12     disobeying the Law on Internal Affairs, especially in the Stari Grad

13     municipality.  The municipal leadership hired a huge number of Muslim

14     citizens for the reserve force and reduced the number of stations where

15     Serbs were reserve police officers.  They also replaced the leadership.

16     Where Serbs were commanders, they were replaced overnight by Muslims.

17             Let me add that especially at the Stari Grad police station, it

18     was a daily occurrence that some criminals were more often received by

19     the police leadership than police staff, especially Serbs who needed to

20     communicate with their superiors.

21        Q.   This police station of Stari Grad, or the municipal secretariat

22     of Stari Grad, if you will, is that a municipality that belongs to the

23     city of Sarajevo?

24        A.   Yes, it is.  The population was predominantly Muslim.  And the

25     adjacent municipalities were Pale and Centar.

Page 22816

 1             If I may continue?

 2        Q.   Go on.

 3        A.   The way the leadership of the reserve force was replaced, and I'm

 4     referring to Serbs, since the police force had long-barrelled weapons,

 5     the -- these weapons were taken away from them.  In the reserve police

 6     stations where most of the police officers were Serbs, the commanders of

 7     those reserve stations were replaced by Muslims, and the weapons were

 8     taken to the secretariat of internal affairs and redistributed to

 9     stations where the Muslims were the majority.

10        Q.   How was this situation resolved in the Stari Grad municipality?

11        A.   I'd have to add, if I may, that in the Stari Grad municipality,

12     criminals came to see the police leadership daily.  Open threats had

13     already been issued to police officers of Serbian ethnicity, not only by

14     criminals but also by some police officers from that station.

15             In the process of assigning regular tasks, Serb police officers

16     would mostly get marginal tasks, although, until the end of 1991, they

17     had their respective areas where they worked.  Muslims were assigned to

18     work there instead.

19             When members of paramilitary Muslim formations began to come and

20     see the police leadership regularly, the Serbian police officers wrote an

21     open letter in which they listed the problems they were facing.  They

22     requested that these problems be resolved.  However, the MUP

23     headquarters, more specifically the police administration, did nothing to

24     take measures to improve the situation and the -- and sanction the

25     officers who had been at the root of the problem.  It was agreed that

Page 22817

 1     some Serbian police officers be transferred to other public security

 2     stations.  Four inspectors then joined my department, and they were to

 3     stay there until the situation at the Stari Grad station changes.

 4             MR. ZECEVIC: [Interpretation] let us see 1D132, please.  I have

 5     this binder for the witness.  If the usher could please hand it to him.

 6             THE INTERPRETER:  Could the witness kindly speak closer to the

 7     microphones.  Thank you.

 8             MR. ZECEVIC: [Interpretation]

 9        Q.   Could you please approach the microphones so you can be heard

10     better.

11                           [Trial Chamber and Registrar confer]

12             MR. ZECEVIC: [Interpretation] Tab 3, please, in your binder.  But

13     let us wait for a moment.

14             MR. HANNIS:  Is there no English available?

15             MR. ZECEVIC: [Interpretation]

16        Q.   Sir, this is a document, and we read that it was drafted by the

17     staff of Serb ethnicity in the Stari Grad public security station, and

18     this document was sent to the Ministry of the Interior, the Sarajevo

19     Security Services Centre, and the Sarajevo Secretariat of the Interior.

20             Can you comment?

21        A.   I know this document.  The police officers at Stari Grad who were

22     Serbs outlined the problems they were facing in 1991 and 1992.  Right at

23     the beginning, I remember these comments, especially because four

24     officers were transferred to the SUP of the city of Sarajevo.

25             They say that members of the Green Berets were in communication

Page 22818

 1     with the leadership and the leadership of the SDA, and let me explain.

 2     The MUP and the public security services, as well as the State Security

 3     Service, as soon as May 1991, got information that the SDA party was

 4     establishing paramilitary units called the Patriotic League, or

 5     Green Berets, respectively.  The officers of my department found out, in

 6     the course of their operative work, that some criminals from Sarajevo

 7     were recruited by the Green Berets, and some of them even became

 8     commanders of those units.

 9             Let me mention some of these criminals:  Juka Prazina, a

10     well-known criminal who had been convicted to serve prison sentences;

11     Ismet Bajramovic, also known as Celo, who had been convicted for the most

12     serious crimes such as plotting to murder somebody and robbery and so on.

13     He was convicted to serve -- he was sentenced to ten years in prison and

14     was to serve in Lepoglava, Croatia.

15        Q.   Just a moment.  Let me just ask you to slow down once more

16     because the interpreter failed to understand what you are trying to say.

17             Whose murder was Ismet Bajramovic, also known as Celo, preparing?

18        A.   The murder of the Sarajevo prosecutor who was in charge of the

19     case against Bajramovic and his group.  They were committing crimes,

20     robbery and theft.

21        Q.   Thank you very much.  Did these persons have any official

22     documents?

23        A.   I know that Ismet Bajramovic, Celo, had a BH MUP ID.

24        Q.   Did you have any information indicating that candidates were sent

25     for training to the MUP of the Republic of Croatia in 1991?

Page 22819

 1        A.   As far as I remember, it was sometime in the summer of 1991.  We

 2     received information indicating that the Party of Democratic Action was

 3     sending ethnic Muslims to the Ministry of the Interior of the Republic of

 4     Croatia in Zagreb to be trained there.  We believed that this was quite

 5     revealing.  This was a political party sending people to be trained as

 6     police officers elsewhere; whereas, we, in Sarajevo, had a specialised

 7     training centre where the police were trained.  They had a secondary

 8     school for police officers where courses were organised for new police

 9     officers for forensic experts and crime -- future crime squad officers.

10     We, among the topmost police ranks, commented on these policies, and I

11     think Leutar actually wrote up some documents to that effect.

12     Nevertheless, as far as the HQ was concerned, I'm not sure whether anyone

13     continued or indeed performed any checks in order to find out about the

14     real intentions of the people behind this operation.  We even had some

15     individual Muslim citizens who came to ask questions about this.  They

16     had heard that people were being sent to Zagreb for training.  They

17     wondered how this could be done because they thought the Ministry of the

18     Interior of Bosnia-Herzegovina was behind this operation.

19        Q.   According to your information, was the Ministry of the Interior

20     involved in that operation, or was this something that was being done by

21     the SDA party?

22        A.   You had the leaders of the SDA, on the one hand, and the MUP's

23     Muslims on the other.  There were strong links between the two, so I

24     should imagine that they were somehow involved in that as well, simply

25     because no one organised any activities whatsoever to check that

Page 22820

 1     information and to check the background to everything that was going on.

 2        Q.   Thank you.  From a security aspect, how would you characterise

 3     the situation in Sarajevo, since that was where you worked?  I'm talking

 4     about late 1991.

 5        A.   The security situation was highly complex.  Ethnic tensions were

 6     high.  There was the Ministry of the Interior being broken up along

 7     ethnic lines.  There were lots of deviations from the police norm, such

 8     as Stari Grad municipality which is an example that I mentioned and that

 9     I would like to say more about because it is also in relation to this

10     issue.

11             Many of the perpetrators of crimes whom arrest warrants were out,

12     be it because they were suspected of committing a crime, or because court

13     orders had been issued for these people to be caught and sentenced and

14     punished, walked around Stari Grad municipality freely or even went to

15     the secretariat of Stari Grad municipality, particularly to see

16     Ismet Dahic and Mr. Bezdrop.  One of the names is Enko Sakic.  He was a

17     commander of the Green Berets, specifically in Bistrik which is part of

18     Stari Grad.  He would see Mr. Dahic on a daily basis.  In practical

19     terms, people from my unit would keep them informed, and we kept telling

20     them that there was an arrest warrant out on this person and that he had

21     been sentenced and should serve his term.  Nevertheless, no one ever even

22     tried to arrest this person and to put him in prison, and the same state

23     of disorder applied to more or less all of the policing there.  Caco, a

24     known criminal, who was a deputy commander of the Green Berets, would

25     also go and see Mr. Dahic on a daily basis and the other Muslims in

Page 22821

 1     leading positions in that municipality.  The municipal bodies did less

 2     and less in order to combat crime.  On the other hand, crime, especially

 3     general crime, was on the rise.

 4             Sometime in September 1991, we took some steps against a group

 5     that was breaking into peoples' flats and houses in the broader Sarajevo

 6     area.  During that operation, we arrested Caco, his brother, Suro [phoen]

 7     and other members of his family who were later arrested for the murder of

 8     the son of Avdo Hebib.  We filed a criminal report against these people.

 9     One thing that is particularly noteworthy:  During the interview that was

10     conducted with this person, he told us that the deputy commander of the

11     Green Berets for Bistrik, that he was the deputy commander, the deputy of

12     Emir Sakic [phoen].  This was a company, there were armed men there.

13     They had their own communications equipment.  But this was an open

14     secret.  Everybody in Stari Grad knew about this, and, to some extent, in

15     Sarajevo, too.  There were links between the ethnic Muslims within the

16     police force and these groups operating outside the system, and these

17     links were open an obvious which certainly affected the way the police

18     operated.  That's why this letter was written by the police and the crime

19     inspectors of Serb ethnicity from Stari Grad municipality.

20             THE INTERPRETER:  Could the witness kindly speak into the

21     microphones and could we please lower the microphones so that the witness

22     can actually speak into them.  Thank you very much.  The interpreters are

23     really having a hard time hearing the witness.  Thank you.

24             MR. ZECEVIC: [Interpretation]

25        Q.   Mr. Macar, given the situation that you just described, and given

Page 22822

 1     the malfunctioning, if I may call it that, of the Ministry of the

 2     Interior, did the Ministry of the Interior of the Socialist Republic of

 3     Bosnia and Herzegovina do anything about it; if so, what exactly?

 4        A.   The leaders of the Ministry of the Interior within the HQ and

 5     most of the municipal bodies did nothing.  There were some individual

 6     cases -- I can talk about my line of work.  We tried to act on any

 7     information or tip-offs that we received.  For example, we received

 8     information indicating that there was something going on at the Konjic

 9     factory, that ammunition was being sent from the factory to Hrasnica,

10     Ilidza and Novi Grad.  Members of Patriotic League and the Green Berets

11     were working together with these Konjic-based organisations and with the

12     leaders of the Party of Democratic Action.  We had information indicating

13     that lorries were being escorted by the Muslim police members from

14     Hadzici, specifically the deputy commander of that particular police unit

15     who was also an ethnic Muslim, in the village of Drozgometva, or

16     something like that, which is near Hadzici.  We tried to mount an

17     operation to monitor these activities but, at this point in time, we

18     tried to take account of the fact that there could be information leaks.

19     We tried to prevent that from happening because it had happened before.

20     I was involved in this operation.  Nevertheless, one of these lorries

21     of the -- passed our car, we were on a stakeout, and they got as far as

22     Novi Grad but we couldn't identify the location.  My inspector and I

23     drove straight to the home of this deputy commander.  I can't remember

24     his name.  He was an elderly police officer, gaunt and tall.

25             I called on him.  His wife answered the door.  I said I needed to

Page 22823

 1     speak to her husband for professional reasons.  When he saw us he was

 2     quite unsettled, even scared.  We shared a cup of coffee.  I told him

 3     that we knew what he was up to, and said that he would be facing an

 4     arrest soon.  Our operation had failed.  But I had information, recent

 5     information indicating that this person specifically had given up

 6     escorting those convoys.

 7        Q.   Sir, I would like you to focus on the question that I actually

 8     asked you.

 9             The situation as you have just described, and please just provide

10     brief answers, did you discuss this particular situation with any of your

11     men in the leading positions in Sarajevo city SUP?

12        A.   Yes.  I spoke to my own superior.

13        Q.   What about your superior?  What was his position or his view

14     regarding the situation in Sarajevo?

15        A.   He believed that because the Ministry of the Interior wasn't

16     operating properly and wasn't doing enough, the situation would becoming

17     more and more complex every day.  The hands of the police were tied, as

18     it was, because there was no co-ordination between the ministry in the

19     Security Services Centre of the SUP of the city itself and the public

20     security stations and because of the direct influence in some segments of

21     the ministry's HQ and the public security stations along ethnic lines.

22             JUDGE HALL:  Is this a convenient point to the take the break,

23     Mr. Zecevic?

24             MR. ZECEVIC:  Yes, Your Honours.

25             JUDGE HALL:  So we resume in 20 minutes.

Page 22824

 1                           [The witness stands down]

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

 3                           --- On resuming at 10.51 a.m.

 4                           [Trial Chamber confers]

 5                           [The witness takes the stand]

 6             MR. ZECEVIC: [Interpretation]

 7        Q.   Mr. Macar, you told us about the situation in Sarajevo.  What

 8     about the remaining territory of Bosnia and Herzegovina?  What was the

 9     situation like?

10             MR. HANNIS:  Objection, Your Honour.  I would like some more

11     foundation about how this witness would know about the rest of the

12     territory of Bosnia and Herzegovina.

13             I would also like to put on the record my objection to the nature

14     of -- much of this is in the nature of tu quoque, and, therefore, I think

15     it's irrelevant.  I would like to have a standing objection in that

16     regard so I don't have to keep getting up.

17             Thank you.

18             MR. ZECEVIC:  Well, Your Honour, I'm just trying to show the

19     context of the events and the knowledge of the witness concerning the

20     contents and how he understood the situation to be, and it doesn't -- it

21     doesn't have to -- it's not tu quoque at all.  It's just the events which

22     the witness describes.

23             MR. HANNIS:  Well, then, Your Honour, I would suggest that a

24     preliminary question or two might be, What do you know about the

25     situation in other parts of the territory and how do you know it before

Page 22825

 1     we hear an expansion on whatever he might want to say.

 2             JUDGE HALL:  Perhaps I was wrong in assuming that that would have

 3     been implicit in Mr. Zecevic's question.  But perhaps Mr. Hannis is

 4     formally correct.

 5             MR. ZECEVIC:  Yes, I fully agree.  And I'm grateful to Mr. Hannis

 6     for this.

 7        Q.   [Interpretation] Sir, you heard the question?  Are you familiar

 8     with the situation in the other parts of Bosnia and Herzegovina?  And

 9     what is your basis for knowing that?

10        A.   I am, in part, familiar with the situation, as it was in the

11     other parts of Bosnia and Herzegovina as well.

12             I would like to say something by way of introduction.  The

13     operative crime squad of Sarajevo SUP, while carrying out its missions,

14     did not just operate in Sarajevo city area but also throughout Bosnia and

15     Herzegovina, depending on the casual links between the various crimes and

16     while identifying and arresting any perpetrators that committed crimes

17     throughout the Sarajevo city.  That is why we had a presence in many

18     towns and cities across Bosnia and Herzegovina.  We worked closely with a

19     number of other services.

20             There is something that was an open secret, more or less, in

21     Bosnia and Herzegovina and I, too, knew about this.  In western

22     Herzegovina, military units had been set up called the Croatian armed

23     forces.  I had an occasion to see for myself that indeed these forces

24     were operating.  Towards the end of that year, we were work on a case

25     involving a group of perpetrators who were stealing passenger vehicles

Page 22826

 1     throughout the Sarajevo city area and then taking the stolen vehicles to

 2     Herzegovina.  The perpetrators were from the Mostar area, from Listica,

 3     from Grude and from Ljubuski.  All those are locations in western

 4     Herzegovina and the population there is mostly Croatian.

 5             Having gathered a certain amount of information and organised

 6     this information, we carried on with the case.

 7        Q.   Can you please explain what you mean by you carried on with the

 8     case.

 9        A.   Yes, I was just about to do that.  We had this plan of activities

10     that we were pursuing.  So the intention was to take these four

11     municipalities and bring in from the area of these four municipalities a

12     total of five perpetrators, take them to the secretariat of the interior

13     of Sarajevo city in order to conduct interviews with then in order to

14     analyse evidence that was collected against them that would eventually

15     result in a criminal report being submitted to the relevant prosecutor.

16             As for work in the areas of Mostar, Listica, Grude and Ljubuski,

17     two teams were set up for that purpose comprising three inspectors each

18     who had two official vehicles available to them.  They drove, first of

19     all, to the Mostar security centre.  The head of the local crime police

20     was Jovo Cokorilo.  And the head of at centre was an experienced officer,

21     whose name escapes me right now, but he was an ethnic Croat.  He warned

22     us that we might encounter incidents happening or that something untoward

23     might happen as we were trying to bring these persons in.  He also told

24     us that check-points had been set up along roads leading into these

25     municipalities.  These check-points were manned by armed members of the

Page 22827

 1     Croatian armed forces.  So there were these two teams in official

 2     vehicles that first drove to Listica, Siroki Brijeg municipality.  As

 3     soon as they spotted a check-point along one of the roads, they realised

 4     there were members of the Croatian armed forces wearing camouflage

 5     uniforms manning those check-points carrying long-barrel automatic

 6     weapons.  They stopped to observe the check-point, first of all, before

 7     driving up to it.  As they were doing that, they noticed that those armed

 8     men were allowing vehicles with no registration plates to pass through

 9     unchecked.  Our own vehicles carried Sarajevo plates with the letters SA

10     predominantly displaced.  So we took these off, let them in the boot, and

11     we were just waved through.  Had they tried to go through the check-point

12     with the plates on, they would have been checked and there probably would

13     have been an incident.  They would have been expected to explain why they

14     were on their way to Listica.

15             So the next thing was to bring in this suspect from Listica.

16     This was, if I may call it that, an abridged procedure.  The person was

17     located in his home, and the inspectors then brought him in and took him

18     to the Mostar security centre in order to avoid people gathering,

19     blocking their way, making it impossible to bring this person in and take

20     him to Sarajevo.  The same day, a similar job was done elsewhere.  Again,

21     there were barricades across the road, both in Grude and in Ljubuski.

22             After the person was brought into the premises of the city

23     secretariat of Sarajevo, at some stage I called in the chief of the crime

24     police sector --

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

Page 22828

 1             THE WITNESS: [Interpretation] Who was a Croat --

 2             MR. ZECEVIC: [Interpretation]

 3        Q.   Would you please repeat his name.  And go slowly.  Let's just

 4     make sure that my question is recorded and then we can proceed to your

 5     answer.

 6        A.   The name was Rezo Ivo, chief of the crime police sector in the

 7     Sarajevo CSB.  He was an ethnic Croat.

 8             Since we had this action being implemented in a number of

 9     municipalities, I called him in, in order to tell him about the case.

10     And on that occasion, after we assessed the intelligence, he agreed that

11     there had been sufficient evidence and indicia to file a criminal

12     complaint.  On that same day, an order was issued to keep the person in

13     detention for three days, and then the criminal complaint was forwarded

14     to the relevant prosecutor's office.

15             On that night, we concluded our activities at around 2.00 a.m.,

16     and, already at around 6.00 a.m., I received a phone call from Mr. Ivo,

17     Rezo.  He was all agitated and told me that he urgently needed

18     information about the activities concerning that case, because there was

19     a lot of pressure coming from the side of the Croatian Democratic Party,

20     HDZ, whose member he was himself.  I tried to calm him down, telling him

21     that I could not provide information to a political party and that for

22     anything he needed to know, he should contact Mr. Leutar, my superior.

23             As far as I can recall, I think that under pressure from the HDZ

24     he was soon thereafter removed from office, and as far as I know, he was

25     transferred to Zagreb where he now works.

Page 22829

 1        Q.   Thank you, sir.  I think that you have explained in detail the

 2     provenance of what you know.

 3             Tell me, do you remember, when was this operation in Herzegovina

 4     carried out, this arrest of five perpetrators?

 5        A.   As far as I remember, it was in late 1991.

 6        Q.   Now, as for the composition of the team of inspectors who went to

 7     arrest the perpetrators in Herzegovina, what was the ethnic background of

 8     the inspectors?

 9        A.   It was a mixed composition.  There were members of all three

10     ethnicities:  Muslim, Croat, and Serb.

11        Q.   Tell me, sir, do you know anything about the situation in

12     Bosanski Brod, and if so, tell us what you know and, again, how you

13     learned about it.

14             MR. HANNIS:  Again, Your Honour, I object to relevance.  This is

15     not one of our municipalities.  I don't know how it furthers our case.  I

16     think it is cumulative at best.

17             MR. ZECEVIC:  Your Honours, on a number of occasions, the -- the

18     Office of the Prosecutor insisted on leading evidence which were outside

19     the scope of the indictment, in the territorial sense.  And the

20     explanation given was that it shows the -- the widespread, the pattern,

21     the joint criminal enterprise, et cetera.

22             Now, what I'm trying to do with the witness is the very same.

23     I'm trying to counter that position of the Office of the Prosecutor, and

24     I'm trying to show the situation in the overall Bosnia and Herzegovina,

25     as it stood in 1991 and beginning of 1992.

Page 22830

 1             MR. HANNIS:  Your Honours, that is correct.  We did seek to lead

 2     evidence beyond the scope of the named municipality because it is an

 3     element of part of what we charged, that this was a widespread and

 4     systematic attack upon civilian populations.

 5             However, what Mr. Zecevic is trying to prove is a widespread and

 6     systematic tu quoque.

 7             JUDGE HALL:  I expect, Mr. Hannis, that when we come to

 8     submissions at the end of the day, this would, no doubt, be a significant

 9     plank in the platform on which the Prosecution attacks the evidence for

10     the Defence.  However, we have continually had to place the things in

11     their context and I confess I do not, for the moment, and let me

12     emphasise that, see the -- any difficulty with Mr. Zecevic broadening

13     his -- the scope of his questions in the way that he is, in order to --

14     himself, set the context for their Defence.  I am sure that he

15     appreciates that this, any leeway that he has here, should not take all

16     of us down paths which, at the end of the day, are going to lead nowhere.

17             MR. HANNIS:  Thank you, Your Honour.  I understand your point.

18     And maybe it's a matter of quantity.  And there's some sort of sliding

19     scale here, but I guess my point is widespread and systematic is

20     something we need to prove and it is contested by the Defence, so it is

21     clearly an issue in this case.

22             Tu quoque, we have not contested that much of what we have

23     alleged was being done by Serbs and the SDS and members of the alleged

24     joint criminal enterprise was also being done by Croatians and the HDZ

25     and by Muslims in the SDA.  We haven't contested that.

Page 22831

 1             So I don't know how much more of it that you need.  I guess that

 2     was part of the point that I wanted to make.

 3             Thank you.

 4                           [Trial Chamber confers]

 5             MR. ZECEVIC:  May I continue, Your Honours?

 6             JUDGE HALL:  Yes, please.

 7             MR. ZECEVIC:  Thank you very much.

 8        Q.   [Interpretation] Mr. Macar, do you still remember my question?

 9        A.   Yes.

10        Q.   Would you please answer.  Just please be brief, as much as you

11     can.

12        A.   I will attempt, but the topics are such that it's hard to put it

13     all into one sentence.

14             And the first thing I would like to say is that our working

15     meetings, given the difficult security situation in town itself, and most

16     of the meetings were held in Mr. Leutar's office, in these meetings, we

17     were informed about the problems in other parts of Bosnia and

18     Herzegovina.  Already then, in the information that we had in the

19     Ministry of the Interior, and also in the media, it was well-known that

20     the situation in Bosanski Brod was extremely complex, that there were

21     huge ethnic tensions.  Paramilitary formations were coming into the area.

22     Those were paramilitary formations of Croatian armed forces.  There were

23     also some indication, both from the media and from the material of the

24     Ministry of the Interior, that via the bridge, arms were being smuggled

25     to arm Muslim and Croat forces.  In order to resolve the situation and

Page 22832

 1     also assist the SJB in Bosanski Brod to establish a more stable security

 2     situation, the Ministry of the Interior created a mixed ethnic team, an

 3     organisational team, with members from the city SUP of Sarajevo and from

 4     the seat of the Ministry of the Interior, and this team was sent to Brod.

 5     The team was headed by Avdo Hebib, chief of police, and former

 6     psychologist, whom I respect as a good psychologist but not as a good

 7     policeman.  So he was in charge of the activities, and he was supposed to

 8     co-ordinate the work of this team with the work of the local SJB.  This

 9     team also counted two workers, Skipina, Nenad, who used to work with me

10     in the city SUP, who was an inspector, and also Pekic, Petko, who was my

11     inspector while I still worked in the municipal MUP of Centar

12     municipality.

13             Before the group departed, I had occasion to sit and talk with

14     Skipina.  We used to have offices on the same floor, and this is when I

15     learned that he was a member of the that team.  While on location there,

16     they took certain measures and they were supposed to secure the border

17     area on the Sava in order to help the SJB in their regular duties;

18     whereas the crime police workers were to help the workers of the crime

19     police in Bosanski Brod police station.

20             After a certain period of time, in early morning hours, Croatian

21     armed forces in the territory -- crossed the Sava from Croatia into

22     Bosanski Brod, and they were assisted by paramilitary formations from

23     Bosanski Brod, and together they took the facility who was normally

24     guarded by people who were on annual leave.  What was particularly

25     characteristic, and I learned this from Mr. Skipina, is that

Page 22833

 1     Mr. Avdo Hebib did not appear on the day before, even though it was his

 2     duty to co-ordinate the work on every day, including that day, and to

 3     give -- issue tasks for the following day.

 4             After members of the Ministry of the Interior were held up by

 5     paramilitaries who had come to Bosanski Brod and who started to harass

 6     them, I learned that both inspectors suffered grave mental injury and

 7     that they required daily treatment by psychiatrists for the following

 8     five to six months.

 9             JUDGE HALL:  Before you continue, Mr. Zecevic.

10             Mr. Macar, perhaps I should explain to you that, and I bear in

11     mind that, as you said, you have never given evidence before, that when a

12     witness is giving testimony, is something that he might not always

13     appreciate that -- and this is a word that you might hear lawyers use

14     often about relevance, and the reason for that is that, in order to make

15     any trial manageable, it is necessary to confine the evidence that is led

16     to what is determined by, in a criminal case such as this, the

17     indictment.  And, therefore, the lawyers who are trained in, among other

18     things, the rules of evidence and procedure, with this in mind, frame

19     their questions in a certain way to invite an answer from the witness

20     because, otherwise, if a witness merely -- were allowed to give a

21     narrative, instinctively because the witness would want to explain why

22     such a such of thing happened, we could find ourselves all the way back

23     in the Garden of Eden.

24             So I would, in this very early stage of your 40-plus hours that

25     you would be with us, ask you to, in the case of counsel for

Page 22834

 1     Mr. Stanisic, and, indeed, when it comes to the other side, to listen to

 2     the question that counsel asks because counsel has a reason for asking

 3     the question that he does and only answer that question.

 4             Do you understand?

 5             THE WITNESS: [Interpretation] I do.

 6             JUDGE HALL:  Please continue, Mr. Zecevic.

 7             MR. ZECEVIC: [Interpretation]

 8        Q.   Sir, just two things that need clarification.

 9             When you said, on page 38 that Croatian forces, together with

10     paramilitaries from the Bosanski Brod area, took the facility, it was

11     interpreted here that this facility was typically guarded by people who

12     were on annual leave.  I think that you said something else, but I hope

13     my learned friend and the Chamber will allow me to focus you on this

14     particular issue.

15             The facility that was occupied, that was taken, was the facility

16     where there were members of the MUP who had come to assist the

17     Bosanski Brod SJB, and those people were led by Avdo Hebib; right?

18        A.   Yes.  And if I may ...

19        Q.   Tell me, sir, did -- you mentioned the two colleagues of yours.

20     Did you talk to any other members of that team that was sent to

21     Bosanski Brod to assist them there, upon their return?  Just briefly.

22     Yes or no.

23        A.   No.

24        Q.   You did not talk to them upon their return from Bosanski Brod.

25        A.   I only talked to Nenad Skipina and Pekic, Petko.

Page 22835

 1        Q.   Did those two blame anyone for being detained by the Croatian

 2     forces and paramilitaries in Bosanski Brod?

 3        A.   They were clear in blaming Mr. Avdo Hebib for not taking up

 4     measures to prevent the situation from escalating.  One of the measures

 5     was supposed to be to cover the border area with Croatia on the Sava

 6     river and securing the bridge over Sava with sufficient number of

 7     policemen who had been brought to the municipality, precisely for that

 8     reason, to assist with that.

 9        Q.   Thank you.  Now let's move to early 1992.  Do you remember any

10     specific events taking place in Sarajevo which, in your opinion, were

11     relevant for the security situation in Sarajevo?

12        A.   What was particularly typical for early 1992, that is to say,

13     January and February, was the complete blocking of the work of municipal

14     organs in the city.

15        Q.   Just a minute, please.  When you say "municipal organs," what

16     municipal organs do you have in mind, please?

17        A.   Primarily municipal secretariat of the interior, in Stari Grad

18     municipality, where police tasks and duties that they were in charge of

19     were not carried out.

20             I also have in mind the police organs in Centar municipality,

21     where parts of the Serb staff members were not included in daily, routine

22     tasks.

23             As for Stari Grad municipality, in several locations there, there

24     were check-points manned by active policemen from the Stari Grad police

25     station, reserve policemen, and Green Berets.  That is to say, those were

Page 22836

 1     mixed crews.

 2             What I saw myself was a check-point in a location just outside of

 3     Stari Grad, leading towards Pale, and also near the Stari Grad police

 4     station.  The constant complaint that arrived to the city secretariat of

 5     the interior was that there was a lack of organisation in the police

 6     force.  The Muslim members tried to include as many Muslim reserve

 7     policemen as they could, and through the reserve police forces, they

 8     tried to arm them.

 9             There was intelligence that the Rijeka neighbourhood, which was

10     populated mostly by people from Sandzak, and where weapons were

11     distributed almost in plain daylight.  But nothing was done against that.

12             At some time in 1991, we received intelligence that a truck-load

13     of weapons --

14        Q.   Thank you.  In -- we're in 1992, and my question was about some

15     events that you may be able to single out.  I didn't want you to tell us

16     the whole story.  We have already heard a lot about it in this trial, but

17     I expected you to mention some crucial events, if any.

18        A.   Well, there was the murder of a member of the wedding party in

19     early March at Bascarsija.  The perpetrator was identified, but nobody

20     from the Stari Grad police station, in whose territory this happened,

21     took anything to apprehend the perpetrator after identification.

22             And what is even more serious, to my mind, is the blockade of the

23     headquarters of the 2nd Army District, which happened on the 15th of

24     March.  On that day, in Mr. Leutar's office, we both were informed that

25     the headquarters was blockaded, and due to the ethnic tensions that

Page 22837

 1     prevailed in the city, we agreed to go there to see personally what the

 2     situation was and to assist the scope of the incident.  I think it may

 3     have been 11.00 or 12.00 on the 15th of March when we went there.

 4             What we witnessed both did and didn't surprise us, with regard to

 5     the information about the deviations in the Stari Grad police station.

 6     We saw the headquarters surrounded by thousands of citizens.  In the

 7     first rows, there was Ismet Dahic, the commander of the station; from the

 8     MUP, there was Ismet Dautbasic, he was the head of state security; and

 9     another executive from the MUP who was in charge of the uniformed police,

10     I forget his name now.  Large numbers of police, active and reserve

11     forces with long-barrelled weapons, but they were not protecting the

12     facility from the civilians that had gathered.  And in the buildings near

13     the headquarters, or facing the headquarters, there were civilians with

14     weapons, and they didn't even hide.  They were very conspicuous.

15             Green Berets were there with Mr. Dahic.  I remember the following

16     persons:  Ismet Bajramovic, also known as Celo, who even said something

17     vulgar when we were approaching; there was Enko Sakic, a company

18     commander from Bistrik for whom there was a wanted warrant;

19     Enver Svrakic, a Green Berets commander from the city.  It was Mr. Leutar

20     who tried to get information directly from Dahic how this had come about,

21     and what the intentions of the police were with a view to preventing

22     further escalation.  He mumbled something negative and walked away from

23     us, some 10 metres away, and he didn't want to communicate further.  We

24     spent about half an hour there.

25             We returned to the city SUP, where Mr. Leutar briefed his

Page 22838

 1     superiors.  It was obvious that the police from the municipal secretariat

 2     of Stari Grad was not protecting the facility or calming the situation

 3     there.  Unfortunately, the blockade continued until the tragic incident

 4     on Dobrovoljacka Street.

 5        Q.   Thank you.  Sir, all these circumstances you have spoken about

 6     since you began testifying, how did they affect the functioning of the

 7     MUP, at least as far as the city SUP of Sarajevo was concerned, where you

 8     worked?  Were there any comments about that?

 9        A.   Up until the 15th of March or so, we were trying -- I think that

10     we were the only crime police service from Sarajevo who at least tried to

11     go about our security tasks.  But since the 15th of March, when

12     communication lines were disrupted between the organisational units of

13     the police, nearly all security work in town stopped.

14        Q.   Sir, were you aware of the intention to split the Ministry of the

15     Interior of the Socialist Republic of Bosnia-Herzegovina; and, if so,

16     when, and from whom?

17        A.   In late March 1991, in Mr. Leutar's office, I learned that the

18     Croats, due to the recent developments and the newly created situation,

19     had already established their own police headquarters in Mostar and that

20     some staff had already gone there.  Then -- and also that they were

21     active about equipping that institution.

22        Q.   Just a moment.  It was said here in late March 1991.

23        A.   Actually, it was 1992, I think.  I misspoke.  It was 1992.

24        Q.   Do continue, please.

25        A.   I heard of the establishment of the Ministry of the Interior of

Page 22839

 1     the Serbian Republic of Bosnia and Herzegovina round about the 30th of

 2     March.  Let me add that my daughters, because schools and kindergartens

 3     stopped operating --

 4        Q.   Let's drop that now.  We'll get there yet.

 5             When you were speaking to Mr. Leutar in his office about the

 6     establishment of this Croatian MUP in Mostar, what did he say to you on

 7     that occasion?

 8        A.   He called me to see him because of the disruption of

 9     communication channels and because of the impossibility to do regular

10     policing, and also due to the attempts of the Muslim population to

11     dominate everybody else, for all these reasons the Croatians had decided

12     to set up their own headquarters of the MUP to provide for security in

13     the municipals where the Croats were the majority.  And for all these

14     reasons they had decided to establish a Croatian MUP in Herzegovina, its

15     headquarters being in Mostar.

16        Q.   Did he say to you then what measures had been taken to that

17     effect; and, if so, elaborate, please.

18        A.   He informed me that some Croatian personnel had already gone to

19     personnel and that they were engaged in equipping that ministry with

20     materiel and technical equipment.

21        Q.   Were you aware of some attempts from the media, if not otherwise,

22     attempts of the international community to resolve the situation in

23     Bosnia-Herzegovina?

24        A.   Yes, I was.  I heard about it from the media, and we also learned

25     at working meetings about negotiations.  And, finally, there was -- there

Page 22840

 1     was agreement reached on the 17th of May or something, about the

 2     Cutileiro Plan that envisaged the creation of Ministries of the Interior

 3     for all three ethnic communities.

 4        Q.   Just a minute, please.

 5             You said a short while ago, and I interrupted you, that you were

 6     aware of the establishment of the MUP of the Serbian Republic of

 7     Bosnia-Herzegovina in late March.  And you were explaining the situation

 8     with your daughters.

 9             Tell us how you found out about that.  Briefly describe the

10     circumstances of that.

11        A.   I was born in Sokolac, as I have said.  That's where my parents

12     lived.  And because of the security situation in the city of Sarajevo, in

13     mid-March, the schools and kindergartens stopped working.  I took my

14     daughters to my parents' house, partly also due to my being so busy, and

15     I didn't want them to be at home alone.  And in late March, my wife and I

16     went to see the children and brought them some of things, and so on.  And

17     that's when I learned that around the sports complex in Sokolac, on the

18     30th, there would be a parade of the police of the MUP of the Serbian

19     Republic of Bosnia-Herzegovina.

20        Q.   Very well.

21             MR. ZECEVIC: [Interpretation] Could we please play a video-clip

22     to the witness.  The reference is 2D1; the transcript of the video

23     material is 1D1.

24                           [Video-clip played]

25             MR. ZECEVIC: [Interpretation] Just a moment, please.  Stop here.

Page 22841

 1        Q.   Tell me, Mr. Macar, did you go to that review in Sokolac?

 2        A.   Yes, I did.

 3        Q.   Tell us who these people are in this still.

 4        A.   On the right, in a black overcoat, that's me.  Next to me there

 5     is Milorad Maric, the chief of the Ilijas station, or the SUP of Ilijas.

 6        Q.   Why did you go to that police troop review in Sokolac?

 7        A.   Well, it was a normal thing to do as a police officer, and as a

 8     human being.  I wanted to go there and see what was going on, and I was

 9     hoping to hear why and how this MUP of the Serbian Republic of

10     Bosnia-Herzegovina was being established.

11        Q.   I play you this video-clip so we may see if you remember this

12     part and the speech given at Sokolac on the 30th of March.

13                           [Video-clip played]

14             THE INTERPRETER: [Voiceover] "The police force of the Serbian

15     Autonomous Region of Romanija is ready for your review.  There are 230

16     policemen in the lineup, including 70 for carrying out special tasks."

17             MR. ZECEVIC: [Interpretation]

18        Q.   Do you recognise the persons that we see here?

19        A.   Yes.  Mr. Stanisic in the overcoat, Zoran Cvijetic in uniform.

20     And the third one is Mr. Krunic, I think.  He may have been a member of

21     the Executive Board of Sokolac municipality.

22        Q.   And Mr. Zoran Cvijetic, who was he at the time?

23        A.   Chief of the Sokolac police station.

24                           [Video-clip played]

25             THE INTERPRETER: [Voiceover] "The solemn declaration will be read

Page 22842

 1     by the minister of the interior of the Serbian Autonomous Region of

 2     Romanija, Zoran Cvijetic."

 3             MR. ZECEVIC: [Interpretation] Just a moment, please.  The

 4     presenter introduced him as the minister of the interior of the Serbian

 5     Autonomous Region of Romanija, Zoran Cvijetic.

 6        Q.   Can you explain that?

 7        A.   There were a number of earlier political decisions in Bosnia and

 8     Herzegovina by the majority executive authorities, creating autonomous

 9     regions which comprised executive bodies, meaning those included

10     representatives of the Ministry of the Interior.  In the Romanija-Birac

11     region, it was Zoran Cvijetic who acted as minister.

12        Q.   Thank you very much.

13             MR. ZECEVIC: [Interpretation] Can we press on with the video,

14     please.

15                           [Video-clip played]

16             THE INTERPRETER: [Voiceover] "I declare that I will perform the

17     duty of authorised official conscientiously and responsibly, that I will

18     abide by the constitution of the Serbian Republic of Bosnia-Herzegovina

19     and Yugoslavia and the law, and that I will protect the constitutionally

20     established order of the Serbian Republic of Bosnia and Herzegovina and

21     Yugoslavia, rights freedoms and security, and that I will carry out these

22     and other tasks and assignments of authorised officials, even in cases

23     when carrying out these tasks and assignments would bring my life into

24     jeopardy.

25              "The minister of the interior of the Serbian Republic of

Page 22843

 1     Bosnia-Herzegovina, Mico Stanisic, will address the members of the police

 2     unit of the Serbian Autonomous Region of Romanija.

 3             "As of today, the Serbian Republic of Bosnia-Herzegovina has its

 4     own police force.  Legality of our existence is provided by the

 5     constitution of the Serbian Republic of Bosnia-Herzegovina and the Law on

 6     Internal Affairs recently adopted by the Assembly at its session.

 7     Moreover, the legality of our existence is based on the result of

 8     negotiations of the three ethnic communities under the auspices of the

 9     European community.  As of today, we will act as the police force of the

10     Serbian Republic of Bosnia-Herzegovina which will carry out its tasks and

11     assignments professionally and not politically, as the MUP of the old

12     Bosnia-Herzegovina has done so far, in order to protect, property, life,

13     body, and other securities of all citizens in the Serbian Republic of

14     Bosnia-Herzegovina, equally.

15              "Members of the police, we are not involved in politics.  We

16     must carry out our tasks professionally.  For these reasons, long

17     speeches do not belong to us.  But as of today, good luck.  Get to work

18     in the interests of all who live in the Serbian Republic of

19     Bosnia-Herzegovina.  Thank you."

20             MR. ZECEVIC: [Interpretation]

21        Q.   Mr. Macar, did you recognise this speech and the footage?  Were

22     you present there on the 30th of March, 1992, at Sokolac?

23        A.   Yes, I was present for the entire review and also for

24     Mr. Stanisic's speech.  I think this speech brought the whole parade to a

25     conclusion.

Page 22844

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

 2     like to tender both of these, the individual footage, which is D2, and

 3     the transcript of Mr. Stanisic's speech, which is D1.

 4                           [Trial Chamber and Registrar confer]

 5             JUDGE DELVOIE:  Mr. Zecevic, do we have a tab number?

 6             MR. ZECEVIC:  105 and 106.

 7             MR. HANNIS:  That's correct, Your Honour.  It wasn't on the

 8     original list, but I did get an e-mail indicating that he wanted to add

 9     it.  I think it's on my list, anyway.  And I have no objection.

10             JUDGE HALL:  I'm advised by the Court Officer that the transcript

11     is a part of the -- as a part of the documents as one exhibit.

12             So it is admitted and marked.

13             THE REGISTRAR:  As Exhibit 1D633, Your Honours.

14             MR. ZECEVIC: [Interpretation] Thank you.

15        Q.   Mr. Macar, on that day, did you meet any of the persons who

16     attended the Sokolac parade?

17        A.   Yes.  Following the parade, I first accosted Mr. Stanisic.  I

18     asked him where the ministry HQ would be located and how they will go on

19     establishing the operative functions of the ministry throughout Bosnia

20     and Herzegovina.

21             As far as I remember, following the speech, Mr. Stanisic told me

22     that the HQ would be at the Ministry of the Interior of Bosnia and

23     Herzegovina, and that there would be structural talks on the way the work

24     and activities of the ministry would be structured at the BH level and

25     the way work would be co-ordinated.

Page 22845

 1             After the parade, I went back to Sarajevo to my office in the

 2     Sarajevo city SUP.

 3        Q.   Sir, P353 is our next document.

 4             MR. ZECEVIC: [Interpretation] This is tab 4.

 5             [In English] I don't see the document on my screen.  I don't know

 6     whether -- oh, thank you very much.

 7        Q.   [Interpretation] Sir, this is a dispatch of the assistant

 8     minister of the interior of the Socialist Republic of Bosnia-Herzegovina,

 9     Mr. Momcilo Mandic, dated the 31st of March, 1992.

10             Sir, did you see this dispatch on the 31st of March?

11        A.   I didn't see it, but I do remember.  The 31st of March, there was

12     a meeting in Mr. Leutar's office, it was one of our regular briefings

13     with the department chief, and all the sector heads would be there.  He

14     told us about this document, because he had just been to see the

15     secretary, and I see that this is addressed to the secretary of the

16     Sarajevo SUP.

17             He told us about the existence officially now of the Ministry of

18     the Interior of Bosnia-Herzegovina with its regional units.  It was based

19     on a decision taken by the Assembly of the Serbian People, and on the

20     Cutileiro Plan that a decision had been taken to establish the Ministry

21     of the Interior.  He also told us that preparations had been completed in

22     Mostar for a Croatian ministry to be set up.  As far as I remember,

23     following this meeting, and I had been to the stadium in Sokolac as well

24     where the parade had taken place, that I met people who worked with the

25     general crime department whose superior I was, and I informed them about

Page 22846

 1     all these facts.

 2             I talked with the inspector, and we concluded that we would press

 3     on until we could work out all the modalities involved in the work of

 4     these various ministries and until we could have a proper co-ordination.

 5     Given also the peculiar nature of the Sarajevo city SUP covering, as it

 6     did, a total of ten municipalities across the Sarajevo city area, we just

 7     pressed on with other work, as usual.

 8        Q.   You say that you talked to the inspectors and you drew some

 9     conclusions.  Did you receive from your own superior, Jozo Leutar, any

10     instructions as to how the ministry would continue to function following

11     this 31st of March, 1992, dispatch?

12        A.   He told me that the HQ of the Serbian Ministry of the Interior

13     would be in the building of the former BH ministry.  He talked about the

14     regions of Banja Luka, Trebinje, Doboj, Sarajevo, and Trebevic, saying

15     that public security stations would be established across these regions.

16     The MUP of the RS would co-ordinate the work of these centres and the

17     Croatian MUP would do the same kind of co-ordination in western Bosnia

18     and Herzegovina, the Croat dominated areas.  He also told me that further

19     talks would occur about the way the three MUPs would be co-ordinated in

20     terms of security work.

21             If I may just add one thing:  Even nowadays, we have an

22     organisation model in the Federation that is very similar.  We have the

23     cantonal MUPs.  We have the federal MUP.  So it very much the same model

24     or a similar model, you might say, as we tried to establish here.

25        Q.   Did you receive any instructions, and if so, what instructions,

Page 22847

 1     precisely, regarding your work at this precise point in time?

 2        A.   The instructions were, Let's press on until we reach the final

 3     agreement on the way the city SUP would operate.  The departments would

 4     continue to operate until the whole process was over and the three

 5     ministries were fully set up.

 6             The Sarajevo city SUP was an institution that covered a total of

 7     10 municipalities across the city area with different ethnic makeups, and

 8     so on and so forth.

 9             I continued to work with the general crime unit of the Sarajevo

10     city SUP.

11        Q.   That's just what my question was about.  Following your meeting

12     with Mr. Leutar where he told you about the substance of the dispatch and

13     following your meeting with your own department of which you were head,

14     did you continue to perform your tasks as usual in the Sarajevo SUP?

15        A.   I continued to go about my business as usual.

16             There is one thing that I have to say:  All the activities

17     performed by the organs of the Ministry of the Interior were limited

18     because some links were breaking up, and it was getting more and more

19     difficult to perform our daily tasks.  This was reduced to a minimum and

20     some organs were practically unable to function in any way at all.

21        Q.   Thank you very much.

22             MR. ZECEVIC:  Your Honours, I see the time.  Since I'm moving to

23     something else, I think it's an appropriate moment.

24             JUDGE HALL:  You couldn't make use of the five minutes

25     practically?

Page 22848

 1             MR. ZECEVIC:  I can.  I can.  I'm sorry.  I wasn't aware it was

 2     five minutes.

 3        Q.   [Interpretation] Mr. Macar, how long did you continue to work

 4     like that for?  How many days after this dispatch.

 5        A.   I continued to work in the city SUP until the 3rd of April, which

 6     I believe was a Friday.  The 30th -- let me do the math.  I remember it

 7     was a Friday.  The 30th might have been a Monday, the 31st, a Tuesday, so

 8     until that Friday, the 3rd.

 9        Q.   What happened on that day, on that Friday?

10        A.   The day was noteworthy more than one way.  1992, the trade and

11     the financial markets were not operating normally, so we tried to get

12     some food supplies and create stocks to last us a longer period of time.

13     So I'd asked me father to bring me some 30 or 40 kilograms of meat

14     because it simply wasn't being sold anymore.

15             After work, I went back to my flat to take delivery of the meat,

16     and to deep freeze it.  I packed the meat.  I was done doing this by 2.00

17     that afternoon, at which point I went back to work in the Sarajevo SUP.

18             Throughout the best part of March, and part of February too, the

19     people in the leading positions would go on doing their jobs mostly in

20     Mr. Leutar's office.  The security situation was such that we needed to

21     stick together so that we could exchange information if necessary.  At

22     about 1400 hours that day, I came to Mr. Leutar's office.  I found

23     Mr. Stanko Nuic and another colleague there whose name I can't remember.

24     I noticed that Mr. Leutar was worried.  Several minutes later, he asked

25     me to move to one of the neighbouring -- one of the adjacent offices

Page 22849

 1     normally occupied by the Sarajevo city secretary but it was now vacant.

 2     So we moved to that office.

 3             I remember his shaky voice when he told me that the Muslim people

 4     in the leading positions in the Ministry of the Interior at 2.00 that

 5     afternoon had held a meeting in the ministry HQ.  Among other things, it

 6     was decided at that meeting to arrest a total of 14 ethnic Serbs in the

 7     leading positions in the MUP, starting with the municipal level and then

 8     all the way up to the top of the ministry.  I was taken aback by this.  I

 9     was hoping that some explanation would be forthcoming but there was none.

10             He mentioned some of the names that he could remember of the

11     people involved.  I know that there were the following people:  Kovac,

12     Kukobat from the security centre; myself; Planojevic; a total of 14 names

13     that were facing arrest.  His comment, verbatim, was this, and that's why

14     I still remember it:  What are these fools busy doing?  We tried to

15     figure out the reason for them doing this, what the legal basis was.  He

16     saw that there was a lot of anarchy across the city.  Some of the things

17     happening involving people working for the Ministry of the Interior, but

18     to take a decision like that, to have Serb police officers arrested, was

19     really an entirely unreasonable thing to do.

20        Q.   Thank you very much, sir.  We'll press on after the break.  It is

21     time for the break now.

22             MR. ZECEVIC:  I'm sorry, Your Honours, I didn't mean to decide on

23     my own.  I was just informing the witness.

24             JUDGE HALL:  Yes, we will resume in 20 minutes.

25                           [The witness stands down]

Page 22850

 1                           --- Recess taken at 12.07 p.m.

 2                           --- On resuming at 12.31 p.m.

 3                           [The witness takes the stand]

 4             MR. ZECEVIC: [Interpretation]

 5        Q.   Tell us, after this conversation with Mr. Jozo Leutar, your

 6     superior, your direct superior, what happened on the 3rd of April, 1992?

 7        A.   After this conversation, I tried to contact Mr. Kijac.  However,

 8     he wasn't in his office.

 9        Q.   Tell us, please, what position did Mr. Kijac hold at the time?

10        A.   Secretary of the city SUP of Sarajevo.  I wanted to learn whether

11     he had any similar information.  However, he wasn't in the building, so I

12     went back to Mr. Leutar's office and spent time there, until about

13     4.00 p.m.  Prior to that, I tried to get in touch with my wife, because

14     we had a plan to go to Sokolac to visit my parents and children, and we

15     were supposed to take some things to them.  My wife was with her

16     colleagues, trying to get some of the items that were in shortage at the

17     time, and then she came to me.  She joined me.  And we went to Sokolac.

18     As we set out --

19        Q.   Were there any check-points at the exit/entry points into

20     Sarajevo and who manned them?

21        A.   At the exit point of -- in Sarajevo, which is exactly where we

22     had to pass by going to Sokolac, there were huge back -- there were huge

23     lines of cars.  And when I came to Bembasa, there was a check-point

24     there.  Typically in previous months, such check-points were manned by

25     reserve policemen from Stari Grad municipality SJB and Green Berets.

Page 22851

 1        Q.   Just slowly.  Just slowly, Mr. Macar.  You're going too fast, and

 2     not everything that you say is recorded in the transcript because

 3     interpreters cannot follow you.  I can barely follow you.

 4        A.   I apologise.

 5        Q.   Tell me, please, where was this check-point that you mentioned.

 6     It was a road to Bembasa, but next to which building in Sarajevo?

 7        A.   The check-point was next to the city hall, or near the city hall.

 8        Q.   And who controlled that check-point?

 9        A.   The check-point was controlled by active policemen who were

10     ethnic Muslims, from the municipal SUP of Stari Grad, also reserve

11     policemen from that secretariat, as well as members of the Green Berets.

12        Q.   Was this one of the check-points that you mentioned earlier; and

13     how long had this check-point been in existence?

14        A.   This check-point had existed from late September/October 1991.

15     And, yes, I did mention it earlier in my testimony.

16             If I may add something?  All those who manned that check-point --

17     rather, the check-point had the left side and the right side.  The left

18     side controlled entry into Sarajevo, and the right side controlled exit.

19     They had long barrels.  And the members of the Green Berets - and there

20     were three of them - one had camouflage uniform with a green beret,

21     whereas the other two had civilian clothes with the green beret on their

22     heads.  All of them had long barrels.  And together with the other

23     policemen they searched all vehicles, including the vehicles that were in

24     front of me.

25        Q.   Members of such forms, as Green Berets, pursuant to regulations

Page 22852

 1     and laws in force at the time, where they authorised to check IDs, search

 2     vehicles and basically man such check-points?

 3        A.   Members of Green Berets were paramilitaries who, in accordance

 4     with the then-laws, should not have existed.  Most rigorous law measures

 5     should have been taken against them.  Legal measures.

 6        Q.   Given that the situation had been in existence for some time,

 7     meaning those mixed check-points controlling the exit out of Sarajevo,

 8     basically close to the down-town of the city, since this had been in

 9     existence since September 1991, from September to April of next year, was

10     anything done to remove such check-points?

11        A.   No.  Nothing was done about it.  Even some considerations that we

12     had in certain parts of the Sarajevo city MUP to talk to Muslim leaders

13     about it, didn't bring any results.  And if something was done without

14     the participation of Muslim staff members, especially those in high

15     positions in the ministry, then that would have meant further escalation

16     of tensions in that area.

17        Q.   Thank you.  Did you manage to pass through that check-point on

18     that day and arrive in Sokolac?

19        A.   I did pass through the check-point.  They attempted to stop me,

20     but to tell you the truth, I simply could not allow to be stopped by

21     criminals whom I used to arrest, to stop me and harass me.  Even though I

22     was armed, I assumed they wouldn't fire at me because there were a lot of

23     civilians around us, and I was right, I passed through, and continued on

24     to Sokolac.

25        Q.   It says here that you were armed.  Is that what you said or did

Page 22853

 1     you say something else?

 2        A.   No, I wasn't armed.  On that Friday, as I was packing food to

 3     take with us on the road, I left my police Heckler and the flakjacket

 4     back in my apartment.  Typically when I was with children, I tried not to

 5     have any weapons nearby.  So I wasn't armed on that day.  I only had an

 6     official pistol on me that I used to carry with me.

 7        Q.   Tell me, please, what about the people manning the check-point?

 8     Were they armed?

 9        A.   Everybody, including active policemen, reserve policemen, and

10     members of the Green Berets, was armed.  They had plenty of automatic

11     weapons, automatic rifles on them.

12        Q.   And what happened once you reached Sokolac?  That was Friday

13     evening, wasn't it?

14        A.   Yes.  Friday, towards the evening at about 6.00 p.m.

15             Well, we just had a typical family gathering with children.  I

16     saw that my parents were also concerned because the media broadcast a lot

17     of information that frightened them.  I spent the weekend in Sokolac with

18     children.  And on Sunday evening, we were supposed to go back to

19     Sarajevo.  The plan was to return on Sunday rather than Monday morning,

20     which previously we always used to do.  But on this occasion, we wanted

21     to go back on Sunday because my wife worked at the ministry of finance.

22     And on Monday at 9.00 a.m., they were supposed to have a meeting and she,

23     as a secretary of the collegium that was to meet, was supposed to prepare

24     material for the meeting.

25        Q.   Continue, please.

Page 22854

 1        A.   I spent Saturday with my wife and children.  They needed some

 2     clothes, which we tried to find locally, as well as some other items.

 3     And then on Sunday morning, I think it was around 8.00 or 8.15, I called

 4     my neighbour, who lives in the apartment next to me in Sarajevo, in

 5     Marin Dvor.  Since she had a key to our apartment, I -- and normally my

 6     wife was in charge of such matters.  But I called this lady neighbour,

 7     and she was visibly agitated.  And she said the following to me, those

 8     were her words roughly:  That active policemen and reserve policemen from

 9     the municipal Secretariat of the Interior in Centar municipality had

10     broken into my apartment.  And I was surprised to hear that.  I asked her

11     whether she knew any of those people.  And she said that, yes, she knew

12     one of them, Nihad Colic, who had worked at the Centar SUP for some ten

13     years.  I also used to know him, while I was chief of the crime

14     prevention sector in Centar municipality.  Nihad was a policeman, ethnic

15     Muslim, and I asked my neighbour how she knew about the reserve

16     policemen, and she said that even the neighbours commented on their

17     accents and dialect.  Because people from Sandzak spoke in a different

18     dialect.

19             There are nine apartments in our building and most of the tenants

20     objected when they saw police doing that.  They questioned them about

21     what they were doing.  My neighbours were of mixed ethnic composition,

22     and we always were on friendly terms.  But once the policemen showed

23     their weapons, the neighbours stepped back.  While I talked to my

24     neighbour, the activity was ongoing, because just a couple of minutes

25     prior to that, they had broken into the apartment.

Page 22855

 1             So I asked my neighbour about what they were doing and she said

 2     that she could hear the sounds of something being broken, and she said

 3     that Nihad Colic was in the process of taking my wife's fur coat.  It was

 4     a fur coat that I had bought for my wife earlier.  And then she said that

 5     they were also taking out the meat from the freezer, the microwave oven

 6     and some other appliances.  They took away a large painting that was

 7     about 100 years old.  It was a panorama of Sarajevo, and it was a gift

 8     from a Muslim friend of mine when we moved into that apartment.

 9             Then she said that -- that somebody had taken my flakjacket and

10     also the police Heckler that had been issued to me, and also some other

11     smaller items that I no longer remember.

12        Q.   Was any explanation given for that break-in into your apartment?

13        A.   Other than chasing the neighbours away, they didn't provide any

14     explanation.  They didn't say why they had broken into the apartment or

15     why they had removed some items.  This just further confirmed information

16     I received from Mr. Leutar.  I realised that what he had said was true,

17     and that this was an attempt to arrest me, pursuant to the decision

18     issued on Friday.

19        Q.   Very well.  On that day, or in the following days, did you speak

20     to any of your colleagues from the city SUP about this?

21        A.   I spent Sunday trying to inform my wife of these events.  All my

22     family was frightened.

23             I turned in very late on Sunday, and, on the Monday, between 9.00

24     and 9.30, I know that I was still asleep because I fell asleep very late

25     the previous night.  So on Monday morning, Stanko Nuic, chief of

Page 22856

 1     white-collar crime, called me up - he's a Croat - and then I asked him

 2     whether he knew that the polices from the Centar municipal SUP had broken

 3     into my apartment, whether he was aware of that.  And he answered in the

 4     negative.  He had called because his superiors had tasked him with

 5     calling up some Serbian officers to ask them whether they were coming to

 6     work, and if they weren't, they would be -- they would lose their jobs.

 7             Communication lines with Sarajevo were disrupted and I said to

 8     Stanko, I'm coming, if you can tell me which route I should take.  And

 9     then he laughed because there were roadblocks on both sides.  I cannot

10     say precisely whether it was him or one of my inspectors who told me that

11     that on Sunday night the Novo Sarajevo police station had been assaulted

12     and police officer Pero Petrovic killed.  He was -- everybody -- he was a

13     person everybody liked and he was a good police officer.  I'm not sure

14     that it was Nuic who told me that, but I know that I learned of this

15     event on that morning.

16        Q.   What did you do then?

17        A.   Bearing in mind that the communication lines were disrupted and

18     that my apartment had been broken into, which meant that the decision

19     made by the Muslim leadership of the MUP was being implemented, my

20     upper-most goal was to provide for my family.  We only had things we

21     needed for a couple of days.  The shops were half empty because we were

22     in a small town.  Starting from Monday and Tuesday, many people came to

23     Sokolac, a couple of thousand.  They had all fled.  They were also --

24     among them there were also my relatives.  Some 30 or so adults and

25     children were in a 44-square metre apartment.  And for two weeks I had to

Page 22857

 1     sleep in the garage, and my father slept on a truck.  Such were the

 2     conditions.  And it was similar with all families.

 3             Because of the situation my family was facing, my wife and I

 4     decided -- and communication lines with Serbia were intact.  And we have

 5     some relatives in Belgrade.  So we decided that our children should go to

 6     Belgrade with my wife.  It was on the 19th of April.  I remember the

 7     date.

 8             JUDGE HARHOFF:  Mr. Zecevic, the Chamber acknowledges the

 9     hardship that the witness has been through.  But we wonder where you're

10     going with the questions relating to the arrest and his -- and the

11     break-in, in his apartment.

12             MR. ZECEVIC:  Well, perhaps the witness can take the earphones

13     off.

14                           [Trial Chamber and Registrar confer]

15             MR. HANNIS:  Can we confirm that he doesn't understand English.

16             JUDGE HARHOFF:  Yes, Mr. Macar, do you understand English?  I was

17     just making a test on you, Mr. Macar.  Do you understand English?

18             THE WITNESS: [Interpretation] No, I don't.

19             JUDGE HARHOFF:  Thank you.  Would you be good enough to take off

20     your headphones just for a short while.

21             Thank you.

22             MR. ZECEVIC:  Well, Your Honours, I believe it is important to

23     show what was the situation in Sarajevo on the 3rd of April.  That

24     is because the events of the 4th and 5th have already been explained to

25     Your Honours by other witnesses.

Page 22858

 1             Now, especially the -- the specific situation of this witness,

 2     and what are the reasons why he stayed on Sokolac and why the witness,

 3     after that, joined the MUP RS.  That was the only purpose of the -- of

 4     the specific situation relating to this witness.  Nothing else,

 5     Your Honours.  And I'm actually, at this point, moving into his

 6     employment with the MUP RS.

 7             JUDGE HARHOFF:  Thank you for this explanation.  But,

 8     Mr. Zecevic, please be aware that -- I think we've spent about 20 minutes

 9     on this line of questioning for a reason which may not justify that we

10     spend too much time on -- on issues that are only secondary to -- to your

11     case.

12             So please speed up, in other words.

13             MR. ZECEVIC:  I understand, Your Honours.

14        Q.   [Interpretation] Mr. Macar, when did you join the MUP of the

15     Serbian Republic of Bosnia-Herzegovina?

16        A.   As early as April, able-bodied men were mobilised in the Sokolac

17     municipality, pursuant to the Law on All People's Defence.

18             Once I had sent my family to Belgrade, and since my war time

19     assignment was with the MUP, although that was at the Centar municipality

20     of Sarajevo, in order to avoid trouble with the military police, I went

21     to the Buducnost facility at Pale, where I enlisted as a former MUP

22     employee.  Mr. Planojevic was there already.  I think I saw him first.

23     There was also Nikola Milanovic and who knows who else.  And talking to

24     Mr. Radovic, I learned that I had to contact the Ministry of Defence,

25     when I explained that my conscript's file was with the Ministry of

Page 22859

 1     Defence, and Radovic promised me that he would take care of it.  There

 2     was this procedure that had to be gone through between the two

 3     ministries, and I believe that the final decision on my war time

 4     assignment or employment was handed to me on the 14th of May.

 5        Q.   What was the situation you saw when you entered the Buducnost

 6     facility at Pale, in other words when you meant to the MUP of the RS BH?

 7        A.   Pale is a municipality with a shortage of office space.  There

 8     were only a couple of rooms in that building, with one phone, and all

 9     colleagues, all staff of the MUP were more or less in the same room.  We

10     hardly had any technical equipment.  There was simply one office and one

11     meeting room.

12        Q.   I'll show you document P876, which is at tab 5 in your binder.

13             It may be easier for you to look at the large screen.

14        A.   Yes, but then the image must be rotated.

15             MR. ZECEVIC: [Interpretation] Can we rotate the image so that it

16     is in horizontal position.

17        Q.   Take a look at this.  It's a document made by the Prosecution for

18     this trial.  I would like us to zoom in on the left half of the document,

19     on the crime prevention and detection administration.  That's

20     organisational unit 02.

21             Could you comment on these persons listed here and tell us when

22     did these persons join the MUP of the RS BH, as far as you know.

23        A.   In April, the administration chief was Mr. Planojevic.  I was

24     appointed co-ordinator of operative tasks.  The inspectors were

25     Mr. Milanovic and Mr. Orasanin.  Mr. Sinisa Karan arrived much later.

Page 22860

 1     And Ostoja Minic was only hired in August 1992 or so, so that this list

 2     is not accurate.

 3        Q.   How many staff did the administration for crime prevention and

 4     detection of the MUP RS BH have from your arrival up until July 1992 or

 5     so?

 6        A.   Mr. Kovac must be added here.  His name is missing.

 7        Q.   Please give us his given name, because --

 8        A.   It's Ljubomir Kovac.  He work the in crime prevention even before

 9     the war.  There was Orasanin.  I don't know if Kapetanovic was already

10     there by July.  And that's about the composition.  I may be wrong by one

11     name, possibly.

12        Q.   How many inspectors did the crime prevention and detection

13     administration of the MUP RS BH have, in terms much numbers?  I'm not

14     interested in the names now.  And I'm referring to the period from

15     April till the end of July 1992.

16        A.   Four to five.

17        Q.   Did you get any assignments and who gave them to you, when you

18     took up employment with the RS MUP?

19        A.   I got them from Dobro Planojevic.  The activities concerning the

20     establishment of the MUP headquarters had also to do with crime

21     enforcement.  Parallelly to the establishment of administrations at

22     headquarters, assistance was required for the establishment of the CSBs

23     which were not in existence in April 1992.  And the centres are Sarajevo,

24     Trebinje, Bijeljina, Banja Luka, and Doboj were already there; but these

25     three centres were starting from scratch, as it were.

Page 22861

 1        Q.   Continue.

 2        A.   When we sat down to talk, we found out that we didn't real start

 3     from zero.  We started from a negative balance.  Pale is a small town, so

 4     the basic conditions weren't met.  We lacked office space.  We had

 5     limited human resources as well as materiel and technical equipment.

 6     There was a shortage of means of communication.

 7             Talking about the crime detection and prevention administration,

 8     those who were available, were hired.  It was -- it was due to the

 9     situation at the beginning -- beginning of the war.

10        Q.   Please go ahead, sir.

11        A.   Some of the Serbs who worked in the Ministry of the Interior, or

12     in the public security services centre in Sarajevo, the city SUP, and

13     some of the municipal organs went to other places where they could put up

14     their families and would report there in those other places to the local

15     bodies of the Ministry of the Interior.  So we started setting up our own

16     directorate, using personnel, using men who had some experience working

17     with the municipal organs and with the city SUP.  And for as long as we

18     had no people who had positions within the MUP of Bosnia and Herzegovina

19     and who were familiar with the general layout of the headquarters too.

20             In order to achieve that, we had to adapt the existing structure

21     to the circumstances that prevailed.  We had large-scale population

22     migrations.  I am talking about the very beginning, April and May.  We

23     didn't know what the actual situation was in the public security

24     stations, what sort of personnel there was, what sort of equipment was

25     available to them, particularly in terms of materiel and equipment.  This

Page 22862

 1     was all centralised in the Ministry of the Interior.  All the supplies

 2     came from Sarajevo, from the HQ of the former Ministry of the Interior.

 3             On the other hand, the lie of the land, lacking communication

 4     lines, the inability to establish communication using the existing

 5     equipment with many of the outlying areas.  All of this left us unable to

 6     make quality assessments, not in terms of just managing and organising,

 7     but also in communicating with those outlying stations and areas in order

 8     to know what the security situation was that prevailed, in those areas.

 9        Q.   Thank you very much.  Sir, when you arrived, were you shown any

10     documents produced by the ministry, the ministry of RS, prior to your

11     arrival?

12        A.   Yes.  I was shown some documents.  I wanted to know more about

13     the activities that had been performed before my arrival so that I might

14     find it easier to simply smoothly join in the work of the ministry.

15        Q.   I will be showing you a number of documents now.  Please simply

16     confirm whether you have ever seen them.

17             The first one is 1D61, tab 7.

18        A.   Yes, I am familiar with this document.  Part of the this order is

19     in relation to the activities of the crime police.

20        Q.   Just a minute, please.  We would like this to come up on our

21     screens first.  My apologies.

22             Thank you very much.  Could we please have the next document,

23     65 ter 4D1, tab 8.  The date is the 16th of April, 1992.

24        A.   Yes, I'm familiar with this document.  I'm not sure if this

25     continues anywhere else.

Page 22863

 1        Q.   Sir, do you perhaps remember an order at the time to step up

 2     measures to directly protect the republic, the way it's organised, the

 3     private security and safety of its citizens, and to step up crime

 4     prevention measures, which is what this document talks about; right?

 5        A.   Yes, I'm familiar with all of those.  Some of those activities

 6     are in relation to the work of the crime police.

 7        Q.   Do you remember who showed you this document?

 8        A.   When I arrived, I received some documents from Mr. Planojevic,

 9     and I saw some documents in the analytics department of the ministry.

10     There was a person who was in charge of that.

11        Q.   Do you remember the name of the person in charge of the analytics

12     department in the BH MUP at the time?

13        A.   I believe the name was Petar Vujicic.  There was somebody else

14     there too, but I can't remember precisely.

15             MR. ZECEVIC: [Interpretation] Your Honours, unless, of course,

16     there is an objection, I would like to tender these documents.

17             MR. HANNIS:  Well, with regard to tab 8, I think the witness said

18     at line -- at page 67, line 25:

19             "Yes I'm familiar with this document.  I'm not sure if this

20     continues anywhere else."

21             Which leads me to believe that the document he saw had something

22     more on it than the one he is looking at now.  So this appears to be an

23     incomplete document, and for that reason, I would ask that it not be

24     admitted or at least marked MFI for now.

25             MR. ZECEVIC:  This is a document, as you can see, it comes from

Page 22864

 1     the disclosure of the Office of the Prosecutor.  That is the provenance

 2     of the document.  Unfortunately, we have only one page.  Perhaps it's

 3     from the EDS.  I'm sorry, but -- yeah, this is the -- I'm just reminded

 4     now that this document was on the 65 ter list of the Office of the

 5     Prosecutor.  It is an incomplete document.  It has just the first page,

 6     but, unfortunately, that is all we have at the moment.

 7             MR. HANNIS:  Yes, I was about to say, Your Honour, the fact that

 8     it came from us doesn't necessarily mean that it is sacrosanct.  You

 9     understand how we receive documents.  Some are recovered during searches,

10     some pursuant to requests, some handed to us by various individuals with

11     all kinds of motives.  The fact is this witness, by his answer, indicated

12     that what he saw apparently contains something more.  And for that

13     reason, I maintain my objection.

14             JUDGE HALL:  I believe, Mr. Hannis, that we have been faced with

15     similar problems where counsel, like the Chamber, can only work with what

16     we have.  And whereas, I suppose your unstated reservation that when the

17     document is, if the rest were filed, looked at in its entirety, you may

18     give a different impression and colour than what we have.  In fairness to

19     the side which wishes to tender it, at this point, since that is all they

20     have, I think that we would have to take it in and make of it what we

21     could.

22             MR. HANNIS:  I understand that, Your Honour.  I did want to

23     indicate that because it appeared to be incomplete, there is a

24     possibility that this is the draft and the final document was something

25     very different.  But as you say, we -- we tender documents under similar

Page 22865

 1     circumstances.  And I think what it is, it's up to the Court then to

 2     decide what weight to give it at the end of the day with all the other

 3     evidence in the case.  Thank you.

 4             JUDGE HALL:  Thank you.  So the document is admitted and marked.

 5             THE REGISTRAR:  As Exhibit 1D634, Your Honours.

 6             MR. ZECEVIC:  Thank you.

 7        Q.   [Interpretation] Sir, the next document is 2D18, tab 19

 8     [as interpreted].

 9             Did you have a chance to see any documents from the Banja Luka

10     Security Services Centre at the time?  Number 9.

11             JUDGE DELVOIE:  Instead of 19, Mr. Zecevic?

12             MR. ZECEVIC:  I said -- I said 2D18, tab number 9.

13             JUDGE DELVOIE:  Okay.  Thank you.

14             THE WITNESS: [Interpretation] I didn't see this document at the

15     time.

16             MR. ZECEVIC: [Interpretation]

17        Q.   Thank you.  Next document, tab 10, P1252.

18             The date is the 17th of April, 1992, signed on behalf of the

19     minister of the interior of the RS, Mico Stanisic.  And then a signature.

20     The number is 10-18.

21             First of all, can you tell us whether you were familiar with this

22     document when you came to the RS MUP?

23        A.   Yes, I was familiar with this document.  The substance of this

24     document is also about the work of the crime police.

25        Q.   Can you please explain what this number here means, specifically

Page 22866

 1     the number 10 in the header of this document?

 2        A.   The number 10 should be in relation to the analytics department.

 3     02 stands for crime police.  03 is uniform police.  And then it goes on

 4     like that.

 5        Q.   What about 01?

 6             THE INTERPRETER:  The interpreter didn't hear the witness.

 7             MR. ZECEVIC: [Interpretation]

 8        Q.   Apologies, your answer was not interpreted.

 9        A.   01, minister.

10        Q.   Thank you.  Just pause, please.  Mr. Macar, in case you're

11     feeling unwell, if there are any problems, please feel free to tell us.

12     As the President, Judge Hall, explained at the outset of today's session,

13     if at any time you feel unwell, please just say so and we will have a

14     break.

15             May we continue?

16        A.   Yes, sure.

17             MR. ZECEVIC: [Interpretation] 1D72 from tab 11.  Thank you.

18        Q.   Another document dated April 1992, signed by minister of the

19     interior, Mico Stanisic.  The number is 01-50.  It's in reference to an

20     instruction on the delivery of the daily incident bulletin and other

21     security-related information.

22             Were you familiar with this document, sir?

23        A.   Yes, I was.  When I came to the administration, there was no

24     police communication system in place, so most of the communication

25     occurred through the existing telephone lines and numbers.

Page 22867

 1             I know that I, too, jotted down these numbers, just to have them

 2     on me, in case I needed to get in touch with the ministry or the

 3     minister's cabinet.

 4        Q.   You stayed both at Pale and at Sokolac at the time.  What was the

 5     situation regarding the electricity supply, the water supply, supplies,

 6     generally speaking, in those two municipalities throughout April and

 7     May 1992, sir?

 8        A.   One word: Disaster.  No electricity, no water at Sokolac.  I do

 9     remember that quite distinctly.

10             We had two vehicles that we used at work.  I would get fuel from

11     my personal supplies that I kept at Sokolac.  And it went on like that

12     until late May or even early June.  And then I ran into trouble with my

13     father.  He did not want me to take fuel from there any longer.  He drove

14     a lorry that he used to supply the neighbourhood from a source

15     15 kilometres away, to supply the neighbourhood with water for the use of

16     local families for personal hygiene.  So the situation was dreadful.

17        Q.   How were the telephone lines operating, linking the area to other

18     parts of Bosnia and Herzegovina?

19        A.   The phone lines were down in April and May.  I remember at Vrace

20     right after my arrival at Pale, we moved over to Vrace with the ministry

21     HQ.  The Muslim forces left two or three lines operating because the

22     lines went through the central post office in Sarajevo.  So there were

23     two or three telephone lines remaining that they could eavesdrop on and

24     we had to use those for our communications.

25             As for the communication between the municipalities, it just

Page 22868

 1     didn't work, particularly --

 2             THE INTERPRETER:  The interpreter missed the last two locations

 3     that the witness mentioned.

 4             MR. ZECEVIC: [Interpretation]

 5        Q.   Sir, the last two locations that you mentioned, the interpreters

 6     couldn't hear that.  And to be perfectly honest, I didn't hear them

 7     either.  You were simply going too fast.

 8             THE INTERPRETER:  The interpreter didn't get the witness's

 9     answer.

10             THE WITNESS: [Interpretation] The phone lines were down

11     particularly those to Krajina and those to Herzegovina but also with most

12     municipalities across the Sarajevo region and Romanija-Birac region.

13     This made our work a lot more difficult so we had to revert to a more

14     primitive way of organising ourselves by courier which was only possible

15     very occasionally.  Someone from the government and from an institution

16     would go somewhere and then give us this or give us that.  Some things

17     would come in several days late.  And the worst thing was when we needed

18     to forward some urgent information, and it would take us over a week,

19     between seven and ten days, to get the information across.  This is an

20     particular example that I remember vividly of a situation that occurred

21     like this:  I was supposed to be headed for Belgrade to visit my family

22     there.  My wife had left behind her wallet, all the money and everything

23     else.  I'm going to tire you with all that detail now.  So I brought

24     along some of the mail that was forwarded -- that was meant to be

25     forwarded to the stations of Milici, Vlasenica, Bratunac, Zvornik, and I

Page 22869

 1     don't know where else.  Fortunately, I decided to go to the Milici

 2     station.  I think the station chief was called Bilanovic.  And then I

 3     said, You distribute this to the other stations.  Driving ahead of me

 4     were about nine or ten bauxite Milic trucks, civilian trucks.  We were

 5     driving in a single column.  Then I turned off -- got off the road to see

 6     Mr. Bilanovic and to give him some documents.  Fifteen or 20 minutes

 7     later, information reached us that at a distance of about 10 kilometres

 8     from Milici in Konjevic Polje, the Muslims had killed the drivers there

 9     and some civilians.  It was only thanks to our courier services that I

10     was able to avoid this incident myself.

11        Q.   Thank you.

12        A.   I'll try to remember the exact date when it happened.

13        Q.   Sir, I think or, rather, I'm not sure I heard you correctly.  It

14     seems like you're in pain.  If you are, we only have ten minutes to go to

15     the end but we can stop now.

16        A.   Yes.  If possible, I would like to stop now because I have a

17     stomach-ache and a sore back, too.

18             MR. ZECEVIC:  Yes, Your Honours, we could adjourn for the day.

19             JUDGE HALL:  Thank you.  So we will take the adjournment for the

20     day.

21             This being the first adjournment, Mr. Macar, I remind you that

22     having taken the solemn declaration, you cannot have any communication

23     with counsel for either side in this matter until you are released as a

24     witness.  Furthermore, in such conversations as you may have with persons

25     outside of the chamber, you cannot discuss your testimony.  So we would

Page 22870

 1     rise now to resume in this courtroom tomorrow morning at 9.00.

 2             Thank you.

 3                           [The witness stands down]

 4                            --- Whereupon the hearing adjourned at 1.34 p.m.,

 5                           to be reconvened on Wednesday, the 6th day of July,

 6                           2011, at 9.00 a.m.