Tribunal Criminal Tribunal for the Former Yugoslavia

Page 23424

 1                           Monday, 18 July 2011

 2                           [Open session]

 3                           [The accused entered court]

 4                           --- Upon commencing at 9.24 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.  Whereas we were alerted to the 9.30

11     start tomorrow morning, we didn't know about the one this morning.

12             For the record, we will sitting for today and the remainder of

13     this week under Rule 15 bis; Judge Harhoff being absent.

14             May we have the appearances, please.

15             MR. HANNIS:  Good morning, everyone.  For the Prosecution,

16     Tom Hannis and Crispian Smith.

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

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

19     for Stanisic Defence this morning.  Thank you.

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

21     Aleksandar Aleksic for the Zupljanin Defence.

22             JUDGE HALL:  Thank you.  And may we have the witness escorted

23     back to the stand, please.

24                           [The witness takes the stand]

25             JUDGE HALL:  Mr. Macar, good morning to you.  As may have been

Page 23425

 1     explained, the reason for the late start today is for technical reasons.

 2             Before Mr. Hannis continues his cross-examination, I remind you

 3     you're still on your oath.

 4             Yes, please proceed, Mr. Hannis.

 5             MR. HANNIS:  Thank you, Your Honour.

 6                           WITNESS:  GORAN MACAR [Resumed]

 7                           [Witness answered through interpreter]

 8                           Cross-examination by Mr. Hannis: [Continued]

 9        Q.   I want to start with one of the documents we looked at on Friday

10     and that I gave you a copy of to look at over the weekend.  That's the --

11     that's 65 ter 20218.  This is the minutes of the collegium in

12     November 1993.  And we saw before that you and Mr. Drljaca were present

13     at that meeting.

14             But I just had one question to ask you about, and it's at page 8

15     of the English in e-court.  Pages 8 and 9.  And in the B/C/S, it starts

16     at page 7 and goes onto page 8 of the B/C/S.

17             For you, Mr. Macar, I think it's the page numbered 5.

18             It's Stojan Zupljanin speaking.  Do you find that?

19        A.   Yes.

20        Q.   And he is explaining his proposal on giving contracts to the

21     non-Serb employees.

22             And if you go onto the next page, there's a note that Mr. Kijac,

23     Mr. Bjelosevic, Krsto Savic, and Milenko Karisik disagreed with

24     Mr. Zupljanin's proposal.  And that you -- my English has your last name

25     spelled wrong, but in the B/C/S we see:

Page 23426

 1             "Goran Macar stressed that such people could not work for the

 2     forensic department during the war."

 3             Is that an accurate reflection of your position at the time, that

 4     you didn't think non-Serbs should work for the forensic department?

 5        A.   Your Honours, before I begin with my reply to this question, I

 6     would like the OTP to present me the transcript of the session, if

 7     possible, as well as the rule-book on the job classification of the

 8     Ministry of the Interior that was in force at the time.

 9        Q.   Well, Your Honours, I don't have either one of those documents,

10     and I would ask that the witness try and answer the question as best he

11     can, whether or not what's written reflects his position at the time.

12             JUDGE HALL:  Yes, Mr. Macar.  It's a fair question.  If you -- to

13     the extent that you're able to answer it, please proceed.

14             THE WITNESS: [Interpretation] The item of the agenda was the

15     report on the activities aimed at assigning job duties to employees of

16     the ministry and the manufacturing of official IDs to authorised

17     officials.  In order to better understand what assigning job duties means

18     in 1993, let me explain.

19        Q.   I'm sorry, Mr. Macar.  I just want to know if it was your

20     position in November 1993 that non-Serbs should not have jobs in the

21     forensic department.

22             Can you answer that yes or no, please.

23        A.   Your Honours, it was not my position that non-Serbian employees

24     could not work in the forensic department, nor was that the position of

25     Kijac, Bjelosevic, Savic or Karisik.  That is why I cannot give a yes or

Page 23427

 1     no answer.  Instead, I must explain what the discussion was about.  These

 2     minutes --

 3        Q.   No, please --

 4        A.   -- are not certified and I --

 5        Q.   Mr. Macar, I have limited time.  We had a late start today.  I'm

 6     just asking you if what is said there is correct.  And I gather from your

 7     answer, you're saying the way it's written down there is not correct.  Is

 8     that what you're saying?

 9        A.   I haven't stated anything like this.

10        Q.   Okay.  Thank you.  Let's go onto another document then.  We see

11     Mr. Drljaca is still working for the MUP in 1993.  I want to show you

12     65 ter 1470.  This is tab 102 in the Prosecution's list.  I'm sorry, this

13     is just a short one-page document.  I'll ask if you can make it out on

14     the screen.  It's dated the 15th of May, 1993, from the minister

15     Ratko Adzic, apparently addressed to the executive committee of the

16     Municipal Assembly in Prijedor.  It says that Mr. Adzic is appointing

17     Mr. Drljaca to their commission for investigating crimes of genocide.

18     And it notes that Mr. Drljaca is head of the information office in the

19     minister's cabinet.

20             You were aware in 1993, weren't you, that Mr. Drljaca was in that

21     position in the minister's cabinet?

22        A.   No, I wasn't.  But, if I may add, Mr. Ratko Adzic was appointed

23     minister.  I don't know pursuant to whose nomination.  And he may have

24     been a good man in another position but --

25        Q.   I'm sorry.  Please, I haven't asked you to comment --

Page 23428

 1        A.   [No interpretation]

 2        Q.   I haven't asked you to comment on Mr. Adzic.  Again, I have

 3     limited time.  I'm sure you would like to be done with me as I would like

 4     to be done with you.  So please try and focus on my questions and just

 5     answer my questions.

 6        A.   Just half a sentence.  It won't take much of your time, if I may.

 7        Q.   [Previous translation continues] ...

 8        A.   Due to some activities of Mr. Adzic's, some senior officers of

 9     the ministry filed a request to the government to remove him.  And I

10     don't believe that he stayed in office long.

11        Q.   Okay.  Thank you.  In 1993, did you know a Colonel Bogojevic from

12     the VRS.  He was in the security administration for the VRS in

13     General Mladic's Main Staff or General Staff.  Did you know him?

14        A.   I don't remember meeting him.

15        Q.   Okay.  You knew Mile Matijevic from Banja Luka?

16        A.   Yes.

17        Q.   I'd like to show you Exhibit P1767.  And I can hand you a hard

18     copy.  Although this is a handwritten document and may not be easy for

19     you to read.  With the usher's assistance, and I will tell you this is in

20     evidence as an excerpt from one of the diaries --

21             MR. ZECEVIC:  Could we have the tab number, please.

22             MR. HANNIS:

23        Q.   -- of General Mladic.

24             MR. HANNIS:  Yes, it's tab 92 on the Prosecution's list.

25        Q.   And I've put a sticky tab on there to show you the part I want to

Page 23429

 1     ask you about specifically.  It's an entry recorded as reflecting what

 2     Colonel Bogojevic is saying.  He says that:

 3             "Four, five days ago, Simo Drljaca arrived.  He was sent by the

 4     minister, and he came about the Tomasica mine."

 5             This is an entry from the 27th of May, 1993, by the way.  And

 6     goes on to say.

 7             "... that mine near Prijedor where earlier they had buried about

 8     5.000 Muslims.  Drljaca came to leave this with us and they want to get

 9     rid of it by burning, grinding or some other way.  There are all kinds of

10     bodies, and they have involved Subotic in this.  This team includes

11     Drljaca.  He was in charge even while this was being done.  At the

12     meeting were General Subotic, Arsic, Drljaca, me," Bogojevic, I guess,

13     "and Mile Matijevic from the Banja Luka or BL SUP.  I ask you for your

14     position."  And then an asterisk, "My position," and based on the

15     testimony of General Milovanovic we take this to mean General Mladic,

16     "they killed them so they should get rid of them?"

17             JUDGE DELVOIE:  Mr. Hannis, shouldn't we have this on the screen?

18             MR. HANNIS:  Yes, we should, Your Honour.  And I'm sorry, I

19     didn't realise it was not up.  It starts at page 4 and goes on to page 5

20     of the English.  And in the B/C/S, in e-court it starts on page 4, and

21     goes on page 5.  I apologise, Your Honour, I wasn't looking at the

22     screen.

23             JUDGE DELVOIE:  Thank you.

24             MR. HANNIS:

25        Q.   There, on the English, you see the first paragraph and once

Page 23430

 1     you've had a minute, perhaps we can go on to page 2.

 2             Mr. Macar, did you ever hear about these 5.000 bodies in the mine

 3     that's mentioned here.

 4        A.   No, not so far.

 5        Q.   Okay.  And we saw that on the 17th of May, apparently,

 6     Ratko Adzic was still the minister.  This is reflecting something that

 7     would have happened about four or five days earlier than the 27th of May.

 8     So do you know if Mr. Adzic was still the minister on the 22nd or

 9     23rd of May, 1993?

10        A.   I cannot specify the date he was removed, but it was done upon

11     the initiative of some officials of the MUP because he was disrupting the

12     organisational and functional system of the ministry.  Because the man

13     didn't know much about these things, nor about the functioning of public

14     administration, the Ministry of the Interior included.  I don't know the

15     exact date when he was removed.  I can't remember until I see ...

16        Q.   Do you know when Mr. Mico Stanisic became minister of the

17     interior of the RS for the second time?  Do you recall when that was?

18        A.   In 1994.

19        Q.   Let me show you another one now.  This is tab 66 of the

20     Prosecution's list.  65 ter 20151.  And, again, it's just a

21     one-page document so I'll ask if you can look at the monitor.

22             It's dated the 16th of May, 1994.  It's from Simo Drljaca, as

23     chief of the CJB.

24             MR. HANNIS:  I'm sorry, did I -- I said -- it's tab 66, yes.

25     Thank you.

Page 23431

 1        Q.   Let me ask you, CJB, what does that stand for?

 2        A.   Public security centre.

 3        Q.   Okay.  Is -- is that the same as the old CSB?

 4        A.   Yes.

 5        Q.   When did the terminology change from CSB to CJB; if you recall?

 6        A.   I think that was done in the framework of the change of internal

 7     organisation.  But I haven't seen a document showing the exact date, and

 8     I don't recall.

 9        Q.   Okay.  And we see from this document that apparently Mr. Drljaca,

10     in 1994, is the chief of the -- the public security centre in Prijedor.

11     And the minister is Mr. Mico Stanisic; right?

12        A.   So we can see from the document.

13        Q.   And this is from Mr. Drljaca to his SJBs informing him about

14     appointments made by the minister which include Mr. Kovac, as acting head

15     of public security; you, as chief of crime prevention, and number 6, Mile

16     Matijevic, who we saw in General Mladic's diary entry as your

17     deputy chief; right?

18        A.   Yes.

19        Q.   Thank you.  The other one I want to ask you about is the Law on

20     Administration, Law on State Administration.  Did you have a chance to

21     look at that?  This is L0032 from the law library.  I'm not sure what

22     tab it was in the Prosecution's list.  Oh, 113.

23             And the reason I had asked you to look at that was to see if you

24     could point to me an article or provision in that law that stands for the

25     proposition that Crisis Staffs could not pass regulations or laws on

Page 23432

 1     subject matters that were already covered by some other law.

 2             Were you able to do that; and, if so, can you tell which

 3     provision that is?

 4        A.   I'll even amend what I said initially.

 5             We spoke about the powers of the executive bodies at municipal

 6     level, which means the executive committee and the Municipal Assembly and

 7     these powers were later assumed by the Crisis Staffs.  I began to reply

 8     to your question by saying how things were regulated and who had which

 9     remit.  And I mentioned the Law on Public Administration.  Now I can add

10     the constitution, the Law on Public Administration, the Law on

11     Local Administration, the Law on Ministries that regulates the respective

12     remits, down to municipal bodies.  In order to learn what the powers of

13     the municipal authorities were, you have to study these laws and

14     regulations, and it so happened that when I was taking my intern's exam,

15     way back in 1978, I had to learn the basics of the organisation of public

16     administration, and that's where I got this information.

17             In order to assist the Trial Chamber to understand this matter, I

18     would like to remind you that the Ministry of the Interior of the RS,

19     just like the former ministry of Bosnia-Herzegovina, was a centralised

20     public administration body headed by the minister, and it has in place a

21     system of subordination from the top of the ministry down to the public

22     security station.  That's a public administration body of the republic,

23     which means that the public security station is not a municipal

24     administration body to which the local executive committee and the local

25     Assembly can give instructions or orders.  By that very fact, the

Page 23433

 1     Crisis Staff that had taken over the powers of the executive committee of

 2     the municipality and the Municipal Assembly could not be in charge of the

 3     public security station.

 4        Q.   Okay.

 5        A.   That's what I know about public administration, which goes back

 6     to my internship, and I don't want to go on elaborating about the

 7     individual pieces of legislation.  But this is among the basics that I

 8     had to learn when doing my -- when taking my exam at the end of my

 9     internship.

10        Q.   Okay.  I -- I think -- I don't want to go over the discussion we

11     had before about Article 27 of the Law on Internal Affairs.  So let me

12     move onto another topic.

13             I want to talk to you about Exhibit 1D348.  This is at tab 65.  I

14     think it's a Defence -- yes, it's a Defence document.  So that will be in

15     your binder from Mr. Zecevic, if you want to have a look at it.  And

16     that's your report -- or the report of the commission that you were on

17     with Mr. Spasojevic, and Mr. Gajic, I think.  It's dated the

18     31st of August, 1992.

19        A.   [No interpretation]

20        Q.   Number 65?  Tab 65.

21             Do you recall how long or how many days your commission worked on

22     putting together this report?  It looks like the commission was set up by

23     a decision dated the 20th of August.  So ten days?

24        A.   Well, thereabouts, since it was typed on the 31st.

25        Q.   Okay.  Now, prior to August 20th, had you been -- had you been

Page 23434

 1     working directly for Mr. Kljajic?  Were you -- were you in Bijeljina at

 2     the time?

 3        A.   On the 20th?  Well, yes, I was in Bijeljina in August.  On those

 4     days, I may have gone to Trebinje or Pale.

 5        Q.   Okay.  Did you -- did you or anyone on the commission interview

 6     Mr. Kljajic in connection with this report?

 7        A.   No.  The report was commissioned as a consequence of the

 8     information received that Mr. Dragan Andan had taken a poker machine, I

 9     believe, from the depository of the public security station of Bijeljina

10     for some operative needs.  I don't know if that information had been

11     received from citizens or another way; but, at any rate, the ministry was

12     aware of that.  And that was the first thing that was checked.

13             It was established that Mr. Andan had Mr. Cedo Kljajic's approval

14     to take that machine.  I don't doubt his honest intentions, and I don't

15     doubt that he did so for official purposes, but it was established that

16     it wasn't done in accordance with the procedure that was in place for

17     something like that too.

18             After the end -- and I believe that even disciplinary proceedings

19     were initiated against Mr. Andan and that he was relieved from his duty

20     because of that procedural fault.  And since we had the information that

21     Mr. Kljajic had approved his act, the minister ordered that the entire

22     depository be inspected, and that's why this commission was set up.

23        Q.   Okay.  This report, it's three pages long.  I think I see

24     Mr. Andan's name mentioned three times; whereas, the bulk of the

25     remaining checks and findings relate to Mr. Kljajic, who is mentioned

Page 23435

 1     eight or nine times.

 2             Let me ask you:  When and where was the last time you saw

 3     Mr. Kljajic in 1992?

 4        A.   I can't remember whether it was in late October or early

 5     November.

 6        Q.   And do you recall how you first realised or discovered or learned

 7     that he was, indeed, gone from the MUP?

 8        A.   There was an agreement with the minister first, and then one

 9     gained an insight into the status of the deposits.  This was then

10     forwarded for further operative processing and checks which, among other

11     things, envisaged a number of interviews with a number of persons,

12     additional checks regarding the deposit, and I think this was something

13     that was done by the public security station holding the actual deposit.

14     The procedure took at least a month or two because some persons were away

15     on the front line, or for other reasons.  I believe it was sometime in

16     late October or early November that this particular issue was analysed.

17     It was round about this time that I noticed that Mr. Kljajic had been

18     away for quite a long time, that he actually wasn't there at all.  I

19     received information suggesting that he left for the Republic of Serbia,

20     and I have not seen him since, quite literally.

21        Q.   I know from collegium meetings that Mr. Kljajic is listed as

22     attending the collegium on the 3rd of October and the one on the

23     5th of November, 1992.  So, as far as these findings of your commission

24     relate to Mr. Kljajic, was any disciplinary action initiated or taken

25     against him, as far as you know?

Page 23436

 1        A.   Not right away, I don't think.  The assessment was that checks

 2     should be conducted in relation to each and every item from the report

 3     that required further interviews or checks.  I think it was up to the

 4     public security station to do that.  The security centre had not been set

 5     up by this time.

 6        Q.   The findings as described in your report, if they turned out to

 7     be true, would they amount to something that could be prosecuted as a

 8     violation of the Criminal Code?

 9        A.   This depended on the checks that were conducted.  That's why the

10     record was drawn up, saying that further checks should be conducted, in

11     order to establish whether there were any elements of crime involved or

12     not.  Nevertheless, once the operative procedure was over, we were no

13     longer able to get in touch with Mr. Kljajic.

14             Now, as I said, I can't remember whether all of this was

15     happening in late October or early November, which leaves me unable to

16     speculate as to the date.  We then went to Pale and then back to

17     Bijeljina and we were preparing our move.  So I can't remember exactly

18     but it to had be to either late October or early November.  He had been

19     gone for as long by this time.

20             Perhaps you're interested in hearing my own position based on my

21     conversations with the minister.  Had we had all the operative material

22     available to us at the time, we certainly would have taken certain

23     detention measures against Mr. Kljajic.  If I'd had the kind of operative

24     material available to me, indicating the commission of any crime and

25     given his position, steps like that would have been taken, I can say that

Page 23437

 1     much.

 2        Q.   Okay.  In anything you heard from the minister or anybody else in

 3     the collegium, did you find out whether Mr. Kljajic had given any kind of

 4     notice to the MUP or to the minister that he was leaving?  Or did he just

 5     go, in essence, abandon his post and leave?  Do you know?

 6        A.   I'm not sure if he gave any kind of notice.  I know that most of

 7     his colleagues didn't know where he was or what he was doing.  The one

 8     thing I do know for sure is he didn't tell me.

 9        Q.   I think you said last week that you heard he gone to Serbia; is

10     that right?

11        A.   The information available to me at the time indicated that, yes.

12        Q.   And am I correct in understanding that if he had left the MUP and

13     remained in the Republika Srpska, he would be subject to being sent to

14     the army, because the war was on; is that right?

15        A.   Mr. Kljajic did have a war assignment, and it was actually a

16     high-ranking one within the Ministry of the Interior.  Based on that

17     retroactive procedure, that need not have been the case.  He could have

18     used his private contacts to get a position in some lower-ranking units.

19     I can't speculate any further, but my information at the time certainly

20     suggested he was somewhere in the Republic of Serbia.

21        Q.   In your answer, you said you could have used his private contacts

22     to get a position in some lower-ranking unit.

23             You mean within the RS MUP?

24        A.   No.  I mean in the RS -- in the VRS.  There was a shortage of men

25     in all of the units.  Any senior officer would have been eager to get

Page 23438

 1     another man capable of carrying a rifle.  But this all amounts to mere

 2     speculation.  It certainly is a possibility.

 3        Q.   Did you or anyone in the RS MUP, as far as you know, send an

 4     attempt to locate Mr. Kljajic to the Republic of Serbia?

 5        A.   I can't remember whether that was done at the time.  The case was

 6     being handled by the public security station.  I know that he was

 7     unavailable for an interview.  As the acting coordinator in that case, I

 8     was busy elsewhere.  Even this information wasn't verified information at

 9     the time, suggesting that he was somewhere in the -- the Republic of

10     Serbia.

11        Q.   Okay.  And do you know if -- for a fact that he's alive and well

12     today and living abroad?

13        A.   No.

14        Q.   You -- you just don't know one way or another; is that right?

15        A.   That's right.

16        Q.   Okay.  Thank you.  Now, on the other hand, as far as Mr. Andan

17     was concerned, there wasn't much delay in doing something about him;

18     right?

19             Did you know that he was disciplined very shortly after this

20     report was issued?

21        A.   As for Mr. Dragan Andan's case, this was something that was

22     unrelated to this report.  We obtained information back in August that

23     Mr. Andan was using a poker machine in some facility or other, or that he

24     had requisitioned a poker machine from the depot.  And that's why the

25     Andan case was opened and checks were being made; at least as far as I

Page 23439

 1     can remember.

 2             Mr. Andan's explanation for all that was that this item was being

 3     used for operative purposes.  I think there was a note that was written

 4     up and that he was actually allowed to use the machine by Mr. Kljajic.

 5     Nevertheless, in order to use an item or an object like that for

 6     operative purposes, one must process this in a procedurally correct way,

 7     showing why a case was being opened and to collect just what information

 8     specifically.  Once that was done, approval would have been sought to use

 9     a thing like a poker machine, for example, an item like that, perhaps

10     some funds, and so on and so forth.  Unfortunately, the procedure was not

11     observed.

12             There is one thing you could notice about back in 1992.  The

13     minister himself issued orders on the need to observe discipline, checks,

14     control.  It was established beyond a shadow of a doubt that procedures

15     had not been followed.  Therefore, one was not allowed to use this poker

16     machine for operative purposes, and that's why disciplinary proceedings

17     were set in motion.  After that, I'm not sure whether the minister was

18     actually in possession of any other information.  One thing that I do

19     know is that he was now issuing an order to check the depot in Bijeljina.

20     In order to check the depot, you first gather certain types of

21     information, data, and so on and so forth, whereupon you take operative

22     steps to establish the actual facts.

23        Q.   Okay.  Let me show you P1269, which is tab 87.  And with the

24     usher's help, I'll hand you a hard copy.  This is a record of the

25     collegium meeting held on the 9th of September, 1992, at the

Page 23440

 1     Kosuta facility on Mount Jahorina.

 2             You'll see on the first page the listing of those attending, and

 3     you're listed as being present, as well as Mr. Stanisic and Mr. Kljajic,

 4     among others.

 5             I'd like you to go to page -- well, I've tabbed the page for you.

 6     It's page 7 -- or 6 in English.  I think it's the next -- I'm sorry.  If

 7     you could go back one page.  There's a list of persons against whom

 8     disciplinary measures --

 9             MR. ZECEVIC:  It's page 3 in the Serbian text, the last

10     paragraph.  It starts and it --

11             MR. HANNIS:  Thank you.

12             MR. ZECEVIC:  -- goes on to page 4.

13             MR. HANNIS:  Thank you.

14        Q.   You see the bottom of page 3, number one is Mr. Andan.

15             "Dragan Andan temporarily suspended for illegal use of poker

16     machine discovered by the working group which has been appointed by the

17     minister."

18             Right?

19        A.   Yes.

20        Q.   So, is the minister able to suspend employees without a

21     disciplinary proceeding having been conducted?  Can he just do it

22     immediately, or do the rules require some kind of procedure to take place

23     first?

24        A.   In order to answer that question, I would need to jog my memory

25     about the rules on disciplinary proceedings.

Page 23441

 1             At the HQ, I didn't have the disciplinary proceedings, and for

 2     that reason, I can't remember specifically what the rules envisaged.

 3        Q.   Okay.  Thank you.  I don't know the answer myself.  That's why I

 4     asked you --

 5             Let me show you, then, Exhibit P2349, which is tab 98 of the

 6     Prosecution binder.  And I'm sorry, Mr. Kljajic [sic], that's not in your

 7     binder.  I can give you a hard copy of this one as well.  And actually,

 8     I'll give you P2348 as well, which is tab 99.  Because these two

 9     documents are closely connected.

10             The first one -- they're both dated the 11th of September, 1992.

11     If you'll look at the one that has number 09-2511 at the top.  My English

12     translation translated as a request to initiate proceedings to establish

13     disciplinary responsibility against Dragan Andan.

14             You find that one?

15        A.   Yes.

16        Q.   And the statements of reasons makes reference to Andan

17     requisitioning a gambling machine from the Bijeljina SJB depot.  And the

18     evidence is:

19             "Dragan Andan confessed to me in the presence of Dusko Malovic

20     and Sinisa Karan."

21             While we're there, you knew Dusko Malovic, right?  He was from

22     Sokolac.  You know him in 1992?

23        A.   If that's the man, yes.  Sinisa Karan, yes, I know him.  There's

24     Dusko Malovic, the one from Sokolac, or a different Dusko Malovic, I

25     really don't know.  I do know Dusko Malovic from Sokolac.  I met him back

Page 23442

 1     in 1992.

 2        Q.   Okay.  The one that you knew in 1992, was he the head of a

 3     special police platoon?

 4        A.   He was commander of a unit from the public security centre in

 5     Sarajevo.  I'm not sure what level the unit was.  Was it a platoon, a

 6     company?  Not sure.

 7        Q.   And his unit, we've been told, was referred to sometimes as

 8     Mico Stanisic's Men.  Did you ever hear that term used for them?

 9        A.   Some of the men working there may possibly have called them that.

10     I know that some men from the administration under me were referred to as

11     Macar's Men.  I can't say that I ever witnessed that myself, anyone

12     calling them Stanisic's Men.  But it certainly would have been possible

13     to apply that moniker to a number of persons working for the ministry.

14        Q.   Okay.  And their unit, as I understand, was in Bijeljina in

15     September of 1992; did you know that?

16        A.   What I do know is that the unit was part of the special police

17     detachment, specifically the component under the command of

18     Mr. Davidovic, in the month of August.  I don't know exactly whether they

19     remained in Bijeljina for this long.  I was busy elsewhere, so there was

20     no way I could know.

21        Q.   And this unit, we're told, wore some rather unique camouflage

22     uniform.  Rather than green or blue, it was primarily grey, white, and

23     black.  You recall their unusual camouflage uniforms?

24        A.   Many units had different uniforms, blue, just plain overalls, or

25     combat uniforms.  What would their peculiarity be as compared to other

Page 23443

 1     units at the time, I don't know.  People got whatever they could at the

 2     time in terms of uniform.  We still didn't have the sort of uniformity,

 3     in terms of uniform that was required.  There were many wearing combat

 4     uniforms.  Some were even wearing police uniforms.  All kinds of

 5     different uniforms in one word.

 6             MR. HANNIS:  Your Honours, I calculate it's been about an hour.

 7     Is this an appropriate time for the first break?

 8             JUDGE HALL:  Well, it was near 9.30 that we started, so I

 9     intended to run until 10.30 and take the break then.

10             MR. HANNIS:  I'll continue on.  Thank you.

11        Q.   And Sinisa Karan, what was his job and where was he working in

12     September 1992?  Was he stationed at Bijeljina?  Do you know?

13        A.   Sinisa Karan was dispatched to Bijeljina a lot earlier than that.

14     Perhaps even as far back as Mr. Vukovic and Mr. Andan.  What was his

15     position in Bijeljina, though, was he working with the public security

16     station, I can't remember.  I do know that he was transferred to the

17     crime police administration later on, late that year or thereabouts, but

18     you should really check his file to see the exact date.

19        Q.   Thank you.  And the second document is the one that is numbered

20     09-2512.

21             09 is a reference to which administration in the RS MUP?  Is it

22     legal affairs?

23        A.   Probably, yes.  And personnel too.

24        Q.   Okay.  And the second one is the decision.  And it's the decision

25     based on the request we saw in the other document, which is referenced

Page 23444

 1     here by number.

 2             So the request is made by Mr. Stanisic on the 11th.  And the

 3     decision temporarily suspending Dragan Andan is made on the

 4     11th of September by Mr. Stanisic.  But this is two days after the

 5     collegium meeting on the 9th, where it said that he was already

 6     temporarily suspended.  Do you have any explanation for that?

 7        A.   As far as this decision is concerned, the question should

 8     probably be addressed to someone from legal and personnel affairs.  I

 9     don't know under what conditions this decision was made.  It's not for me

10     to say because that wasn't my job.

11        Q.   All right.  On -- on the 11th of July, you were talking about the

12     document that purported to authorise Mr. Kovac to sign for the minister

13     during his absence.  I think that was dated the 21st of October, 1992.

14     But Mr. Stanisic was still -- still on the job and working as the

15     minister in November and December of 1992, wasn't he?

16        A.   Which document are you talking about?

17        Q.   It's the one that was not signed but you told us you'd seen the

18     original.  It's just a very short document saying, "I hereby authorise

19     Tomo Kovac to sign for me."

20             Do you remember that one?  I can find it, if you need to see it,

21     but ...

22        A.   I remember the document, not the date of the document, though.

23             MR. ZECEVIC:  It's tab 77 in our binder, if --

24             MR. HANNIS:

25        Q.   It's tab 77 in your binder, Mr. Macar, if you want to have a

Page 23445

 1     look.

 2             But my question was:  Mr. Stanisic was still working and holding

 3     his position as minister in November and December of 1992; isn't that

 4     right?

 5        A.   Yes, he remained there until his replacement.  I can't say

 6     exactly to what extent he was able to exercise his function for all the

 7     reasons that I've mentioned.  I know that most of the communication at

 8     the time was with Mr. Kovac.  With the exception of the things that I

 9     know and told you about, I can't address anything else that went on at

10     the higher levels.  There was pressure being exerted on the ministry, and

11     so on and so forth.

12        Q.   Do you recall him presiding at the collegium meeting in Bijeljina

13     on the 5th of November, 1992?

14        A.   Unfortunately, I would need to see the actual minutes.  There

15     were just so many meetings.  It's difficult to distinguish the dates.

16             If you could please show me the minutes --

17        Q.   Okay.

18        A.   -- I'm certain that I could remember when the meeting was held

19     and what it was about.

20        Q.   The last one then before the break, we'll show the witness

21     Exhibit P1270, tab 54 of the Prosecution list.  I think it's tab 86,

22     actually, in your Defence binder.  86.

23             You see Mr. Stanisic presiding over that meeting, where you're

24     listed as an attendee?

25        A.   Yes.

Page 23446

 1        Q.   Thank you.

 2             MR. HANNIS:  Would this be an appropriate point, Your Honour?

 3             JUDGE HALL:  Yes.  We return in 15 minutes.

 4             MR. HANNIS:  Thank you.

 5                           [The witness stands down]

 6                           --- Recess taken at 10.28 a.m.

 7                           --- On resuming at 10.47 a.m.

 8                           [The witness takes the stand]

 9             MR. HANNIS:

10        Q.   Mr. Macar, a general question about procedure in relation to the

11     collegium meetings.

12             We see that the minutes are typed up.  Are these then circulated

13     to you and the other people who attended the meeting afterward?  Was it

14     standard practice for you to get a copy of the record of the meeting?

15        A.   Everybody was supposed to get a copy, but we didn't always get

16     one.  At the meeting, everybody takes notes of the conclusions and of

17     their respective tasks for the coming period.  That is why we didn't

18     really insist on receiving a copy.  But there were cases when the minutes

19     were distributed to everybody, to all or maybe not each and every one.

20     But there certainly were cases where the minutes were not distributed.

21        Q.   And in the event that you got a copy of the minutes and saw that

22     something was incorrect, was not reported the way you said it or meant

23     it, you would have an opportunity to have that changed; right?

24        A.   Even when the minutes were distributed to a senior officer - me,

25     for instance - I didn't have to be in my office all the time, because I

Page 23447

 1     was out in the field a lot.

 2             I didn't really do that.  And you see how these minutes were

 3     taken.  When I speak fast here, sometimes the interpreters don't catch

 4     everything.  It is much the same at a meeting.  Sometimes only a sentence

 5     or half a sentence is put down and mentioned in the minutes, although the

 6     original presentation was much longer.  And if you read the minutes, you

 7     sometimes wonder what did the people do there for so many hours.

 8        Q.   Okay.  That -- that causes me to want to go back to the first one

 9     I showed you this morning, 65 ter 20218, tab 120, for two more questions.

10             This is that collegium from November 1993.  I think you still

11     have a hard copy.  That is the one that you took over the weekend, one of

12     the two documents.  Do you have it there?  There it is, I think, yeah.

13             And if you could go to the page where I'd asked you about whether

14     that reflected what you said about people working in the forensic

15     department.  I know your answer about that.  But, Mr. Kijac,

16     Mr. Bjelosevic, Mr. Savic, and Mr. Karisik are simply reported as having

17     said they disagreed with Mr. Zupljanin's proposal.  That's correct, isn't

18     it?  They just disagreed with what Mr. Zupljanin proposed about giving

19     contracts to non-Serb employees.

20        A.   You didn't let me answer why they disagreed.  It wasn't only

21     Mr. Zupljanin's proposal --

22        Q.   [Previous translation continues] ...

23        A.   -- because those employees worked at the CJB before the collegium

24     and after collegium.

25        Q.   I'm sorry.

Page 23448

 1        A.   And I must say two or three sentences --

 2             MR. ZECEVIC:  And I'm sorry also.  This is the second time, Your

 3     Honour --

 4             MR. HANNIS:  No --

 5             MR. ZECEVIC:  -- the witness is trying to give the answer.

 6     Mr. Hannis is asking him then he stops him in the middle of the answer.

 7             MR. HANNIS:  I didn't ask him --

 8             MR. ZECEVIC:  This is the four -- this is the second time.  But

 9     the question -- he needs to explain on what they didn't agree with

10     Mr. Zupljanin's proposal.

11             MR. HANNIS:  Your Honours --

12             MR. ZECEVIC:  That is the gist of the question, I'm sorry.

13             MR. HANNIS:  The precise question was did they disagree.  I

14     didn't ask why they disagreed.  I'm just asking if this is accurately

15     reported that they disagreed with his proposal.  I'm not asking why.

16     Mr. Zecevic can ask about that during his time.

17             MR. ZECEVIC:  But, with all due respect, Your Honours, at the

18     beginning of today's session, the first session, the very same question

19     was asked and the witness said:  No, that is -- I'm sorry.  No, the

20     recording here is wrong.  They did not disagree.  They did not.

21             And now Mr. Hannis is asking again and the witness wants to

22     explain, and again Mr. Hannis is blocking him.  That's why I'm objecting.

23             MR. HANNIS:  His answer just now, at page 23, line 23, was, Let

24     me tell you why they disagreed.  I infer from that he is now saying, Yes,

25     they did disagree.  Let me tell you why.

Page 23449

 1             All I'm asking is, is that correct, correctly recorded, if they

 2     disagreed.  And he has said yes.  If he wants to answer why, he can do

 3     that on re-direct.

 4             JUDGE HALL:  Please proceed, Mr. Hannis.

 5             MR. HANNIS:  Thank you.

 6        Q.   If you could go back to the page where it has Mr. Zupljanin

 7     explaining his proposal, if would you read that and tell me, do you

 8     remember is that an accurate reflection of what he said at the time?  Or

 9     do you remember?  It was almost 18 years ago.

10        A.   It seems to me that the most concise summary of what

11     Mr. Zupljanin said is reflected here.  But his presentation certainly

12     contained much more detail, and if you were in a position to read that,

13     you would be better put to understand the whole minutes.

14        Q.   Thank you.

15             MR. HANNIS:  Your Honours, I'd like to tender that document.

16             MR. ZECEVIC:  Your Honours, we do object.  This document has no

17     relevance for the -- for this case whatsoever.  It's a November 1993

18     collegium.  If this is a document that -- that -- that is supposed to --

19     to go to the credibility of the witness, then -- then the witness should

20     be given the opportunity to answer.  If it's -- if it's anything else, we

21     do object.

22             JUDGE HALL:  Mr. Hannis, without going down the road of

23     separating credibility from other purposes, and by now counsel would have

24     had the benefit of the Chamber's views on that distinction, the -- isn't

25     there a problem in your tendering this document for the reason that --

Page 23450

 1     and we come back to the -- well, as Mr. Zecevic has just said, that

 2     the -- apart from the fact that it's dealing with the collegium meeting

 3     in 1993, if you're using it for other purposes, then you have placed

 4     yourself into the position of having -- not only in fairness to the

 5     witness but in order for the comprehension of the Chamber of having the

 6     witness explain the answers which you had indicated earlier would be best

 7     left for re-examination.

 8             MR. HANNIS:  If I could ask that the witness take his headphones

 9     off.

10             Your Honours, as with most documents, I'm offering it for more

11     than one purpose.  One of the purposes this document is being offered for

12     to show that Mr. Drljaca, in spite of good cause for him to be removed

13     and in spite of claims by some witnesses that he was removed, indeed he

14     wasn't removed in the sense of being kicked out of the MUP.  He is in a

15     higher position than he was as chief of the SJB in Prijedor.  He is at

16     the cabinet level in the ministry.  So that's one purpose for this

17     document.

18             With regard to Mr. Zupljanin, it's been his position that he --

19     the Defence position that he no bias against non-Serbs and here is a

20     reflection where he is saying, We should hire non-Serbs.  That is

21     consistent with the Defence, but from the Prosecution point of view, the

22     rest of the answer suggests that, really, the reason that he is in favour

23     of hiring non-Serbs is because of the public perception.  He talks about

24     the interests of journalists and media personnel in the fact that

25     Banja Luka has hired non-Serbs.

Page 23451

 1             And that's part of the reason the Prosecution wants to answer,

 2     yes, there is some evidence that he appeared not opposed because he had

 3     non-Serbs working for him.  But we say, in reply to that, yes, but that

 4     was for appearances' sake.  So that's another reason that I would tender

 5     it.

 6             JUDGE HALL:  I hear all of that, Mr. Hannis, but I come back to

 7     the question as to the -- in order for this to be added as an exhibit,

 8     isn't the context necessary, hence the matters which the witness wished

 9     to expand upon, and which at that point, ex facie, appeared to be

10     irrelevant for the limited purposes of your question.

11             MR. HANNIS:  Well, I think if I'm going to insist that his claim

12     now that it's -- inaccurately reflects what he says goes to credibility,

13     I suppose, yeah, he should be entitled to explain why it doesn't reflect

14     what he said.  But I'm more interested in tendering it for those other

15     reasons than for his credibility.  My arguments about his credibility are

16     going to rely more on other documents and other answers than this one

17     about something in November 1993.

18             MR. ZECEVIC:  With all due respect, Your Honours, the reasons

19     which Mr. Hannis just stated have nothing to do -- are irrelevant for

20     this case, entirely irrelevant.

21             First of all, Mr. Drljaca was appointed as -- as the aide of the

22     minister during the time when Mr. Mico Stanisic was not a minister.

23     Therefore, his position in the MUP is totally irrelevant in respect to

24     our clients and the subject matter of this case because it is limited

25     until 1992, the whole 1992.

Page 23452

 1             As for Stojan Zupljanin, the state of mind of the -- of the

 2     accused in the end of 1993, as opposed to 1992, I don't see how that can

 3     be even more -- even relevant at all.

 4             Therefore we strongly object, and there has been a number of

 5     occasions when the Office of the Prosecutor was using the same, precisely

 6     the same reasons when we offered the documents which were even more

 7     specifically targeting events in 1992, where they were saying that it is

 8     irrelevant because it's from 1993.

 9             This particular document has no connection with the situation in

10     1992 whatsoever, Your Honours.

11             Thank you.

12             MR. HANNIS:  Really, Your Honour, I expected Mr. Aleksic to speak

13     for Mr. Zupljanin.

14             MR. ALEKSIC: [Interpretation] I fully agree with what my learned

15     friend Mr. Zecevic has said.  I have nothing to add.

16             As for the document itself, it is stated that Mr. Zupljanin

17     submitted his speech in writing which the witness has also mentioned.  If

18     we don't have that either, then that's one more reason to consider the

19     document irrelevant, in addition to what Mr. Zecevic has said.

20             JUDGE HALL:  Thank you, Mr. Aleksic.

21                           [Trial Chamber confers]

22             JUDGE DELVOIE:  Mr. Hannis, don't we have the evidence about

23     Mr. Simo Drljaca in the -- in the cabinet in previous documents that you

24     tendered today or --

25             MR. HANNIS:  Friday, I think --

Page 23453

 1             JUDGE DELVOIE:  -- last Friday -- yes?

 2             MR. HANNIS:  Yes.  Yes.

 3             JUDGE DELVOIE:  So this is just repetitive in that --

 4             MR. HANNIS:  Well, Your Honour, I think the previous document I

 5     had was when Mr. Adzic was the minister, and in November of 1993, it was

 6     someone else other than Mr. Adzic, and before Mr. Stanisic returned for

 7     his second term.  So I guess I'm trying to show a continuous stream of

 8     Mr. Drljaca being employed in the MUP.

 9                           [Trial Chamber confers]

10             JUDGE HALL:  In the Chamber's view, this document doesn't assist

11     and it would not be admitted into evidence.

12             MR. HANNIS:  Thank you, Your Honour.

13        Q.   Mr. Macar, let me go now to some documents dealing with the issue

14     of prisoners and detained persons.

15             I'd like to show you P427.18.  This is tab 121 in the

16     Prosecution's list.  And I think it will assist you if we can give you a

17     hard copy.

18             While you're waiting for the hard copy, I'll tell you it's a --

19     it's the minutes of a Presidency session dated the 6th of August, 1992.

20     And to put it in chronology, this is just the time that some of the

21     international media about persons detained in Manjaca and Omarska and

22     Keraterm is being broadcast in the greater public.

23             I want to specifically ask you about something that's on your

24     page 2, and page 2 of the English.

25             There's a reference to the work of the Commission for

Page 23454

 1     Investigating War Crimes Committed Against the Serbian People in the

 2     Serbian Republic of BH and the former Republic of Bosnia and Herzegovina.

 3             Did you know about the existence of this commission in the

 4     Republika Srpska?

 5        A.   Are we looking at the same document?

 6        Q.   I hope so.  Page 2.  Yes, page 2, the back of that page.  It's a

 7     two-sided document.  The one in your right hand.

 8             Did you know of the existence of that commission?

 9        A.   I learned of its existence in late 1992.  I had many problems

10     because of the way they worked, or, to be more precise, because they

11     didn't pass on information.  In 1993 or 1994, I even wanted to search the

12     premises and even the private home of a man who was a commission member.

13     Toward the end of 1992, I held the opinion that the commission was to

14     collect documents to be analysed and so on.  I didn't see it as a

15     commission that would assume some powers of the MUP or military security

16     organs.  And the worst thing is that from early 1993, which you were able

17     to see because you had access to the archives of crime enforcement, we

18     contacted that commission at least twice a year with very specific

19     requests.  According to the information I had, the commission was to be

20     part of some sort of documentation centre for war crimes and not a

21     commission that would actually investigate war crimes.

22        Q.   Let me ask you --

23        A.   The ministry, I believe it was in 1994, had some problems because

24     of our efforts to place the problem of war crimes under the jurisdiction

25     of the ministry of the -- of justice and military judiciary bodies.  But

Page 23455

 1     we didn't have any documents, so that in 1994, we wanted to conduct a

 2     search if for no other reason than for the reasons of concealment of

 3     documents about crimes.

 4        Q.   Against Serbs; correct?  That's what this commission was for.

 5        A.   It was a commission for documenting war crimes, as far as I know.

 6     Whether they were tasked to collect evidence about crimes against one

 7     side or another side is -- is something I don't know.  But we did get

 8     documents from the army and lower-ranking units, from combat areas, then

 9     from citizens who had escaped from the territory controlled by the

10     opponent.  But then there was some information that was not accessible to

11     the Ministry of the Interior.

12        Q.   Please, Mr. Macar, you see the name in the document.  It's a

13     Commission for Investigating War Crimes Committed Against the Serbian

14     People.  That's the name of the committee.  Doesn't that reflect what its

15     job is?  Or, if you don't know, say so.

16        A.   I haven't seen this document before.  And it was my idea --

17        Q.   I'm sorry.  Please --

18        A.   -- that the task --

19        Q.   Please, Mr. Macar.

20        A.   -- of the commission was to set up a documentation centre.

21        Q.   Please try and focus on my specific question and answer that, if

22     you can.

23             Let me ask you this:  Do you know who any of the members of the

24     commission were in 1992; and, if so, what was their job in real life,

25     apart from being on the commission?

Page 23456

 1        A.   I know that one of the members I had communication with as of

 2     1993, I think, was Mr. Toholj.  I believe that he was minister of

 3     information for a while.

 4             Let me try and remember.  Trbojevic, I think, or somebody.  It's

 5     based on information from the field that I got information about this

 6     commission.  I got it from crime police operatives who informed the

 7     administration that at Pale there was a commission for documenting war

 8     crimes which is contacted by citizens, that is, refugees, from the

 9     territories controlled by the enemy, and the commission was also getting

10     documents from some military units which they had obtained during combat

11     and seizing enemy documents.  And there were attempts to establish

12     communication to see what their activity consisted in and whether we

13     could get access to materials that were security relevant.

14        Q.   Anybody from the MUP a member of the commission in 1992?  Yes or

15     no.

16        A.   The Commission for Documenting War Crimes, as I remember from

17     early 1991 ... but, anyway, toward the end of 1992, I received

18     information about that commission.  There may have been MUP members on

19     the commission when it was established.  But in 1993, I don't think so

20     because it was a body that was dealing with matters that were from the

21     jurisdiction of other institutions.

22             If we're talking about the same thing.  Because it's not an

23     ad hoc commission.  It was a commission that was meant to be active for a

24     longer time.

25        Q.   One clarification.  Your answer is recorded:

Page 23457

 1             "In 1993, I don't think there were MUP members."

 2             Did you mean 1992 or what?

 3        A.   I said already that I learned about the existence of the

 4     commission in late 1992 or in early 1993.  And according to the

 5     information that I had received, I took them to be a commission

 6     documenting war crimes rather than investigating.

 7        Q.   The question was -- you partially answered and said:

 8             "There may have been MUP members on the commission when it was

 9     established.  But in 1993, I don't think ..."

10             So the question is:  Were there MUP members on the commission in

11     1992, if you know?

12        A.   I don't know.

13        Q.   Thank you.

14        A.   Before I see --

15        Q.   The document you have, if you could continue on from where we

16     left off, it's talking about the treatment of prisoners of war detained

17     in prisons in Serbian territory being discussed.  And if you could go on

18     to the third page, there's a conclusion that says:

19             "The MUP -- the Ministry of the Interior ... will be ordered to

20     examine through its municipal branches the behaviour of all civilian

21     authorities and individuals guarding prisoners of war.  The information

22     will be passed to the MUP which will pass it to the Presidency ..."

23             Were you aware that this task was ordered for the Ministry of the

24     Interior and was it being carried out after the 6th of August, 1992?

25        A.   Obviously I'm not the right person to answer this question

Page 23458

 1     because, as you know, in August, I worked in Bijeljina on a specific task

 2     as operative coordinator.  And I see that this document is dated

 3     6th August.  I cannot comment on this matter.

 4        Q.   Okay.  I understand that answer.  But it appears to be an ongoing

 5     task and so I take it after August 6th, you didn't see any -- anything to

 6     indicate whether this was something that was being done in the MUP at the

 7     level of the SJBs?  For example, in the course of the instructive tours,

 8     nothing was reported back to you from your inspectors about that?

 9        A.   As you know, and as I have already said, I know about it from a

10     later period, but I don't know any details that commissions were

11     established and that there was information flow toward the ministry.

12             I know from visits in late 1992 that, at a certain time, in

13     Samac, there was a prison, or camp, or a collection centre, I don't know,

14     but I don't know whether it was in existence during our visit.  Probably

15     not.  But at an earlier time, the police were engaged in that facility.

16     That was in late 1992, when we were visiting the Doboj centre and the

17     Samac station.

18        Q.   All right.  Let's look at a report from another SJB that talks a

19     little bit about detained persons and how that was handled in Prijedor.

20             This is Exhibit P684.  It's tab 115.  And I'll ask the usher to

21     give you a hard copy of this one.

22             Mr. Macar, this is from Simo Drljaca, and it appears to be the

23     report for the third quarter of 1992 on the activities of Prijedor SJB.

24             Did you see this document before?  Is this the first time you've

25     seen it?

Page 23459

 1        A.   This was a document sent to the Security Services Centre of

 2     Banja Luka.  I don't think I've ever seen the document in this format

 3     before.

 4        Q.   Okay.  In terms of these kinds of quarterly and semi-annual and

 5     annual reports from SJBs, is that something that you or your inspectors

 6     would have occasion to see in connection with your instructive tours or

 7     on occasion of formulating your own end-of-the-year report at

 8     headquarters level.  Is this something that you would see?

 9        A.   I believe that following one of your previous questions I

10     established that in 1992 the information flow from the public security

11     stations to the centre and to the ministry HQ, for objective reasons, was

12     not possible, at least not the kind of quality that would allowed the

13     ministry to know what was really going on further afield.  And that is

14     why there followed orders from the minister, midway through that year and

15     in some documents later on, for periodic reports to be produced.

16             When visiting or touring police stations on the ground, and the

17     visit to Prijedor happened at a very late stage, people from the crime

18     police wanted information, first and foremost, technical information on

19     the resources and so on and so forth.  They would visit all the

20     departments and units and wanted to know about the crime situation in

21     each of these areas.  When we did this on our own, we didn't deal with

22     the active or reserve police issues but only our own speciality,

23     crime-related issues.

24             As I said, those were the first visits, and one attempted to take

25     in the general situation in the group, department or unit itself,

Page 23460

 1     including the overall situation regarding crime in a certain

 2     municipality.

 3        Q.   Let me ask you, if we could go to page 5 of the English, and I'm

 4     not sure what page it is in the B/C/S since I've given away my hard copy.

 5             Mr. Macar, there's a reference to the third quarter of 1992,

 6     especially months of July and August, being characterised by the

 7     processing and investigation of Muslim and Croatian extremists in

 8     Keraterm and Omarska reception centres.

 9             MR. ZECEVIC:  Second paragraph on page 3 in Serbian.

10             MR. HANNIS:  Thank you, Mr. Zecevic.

11        Q.   Do you find that?  Are you with me?

12        A.   Page 3, right.

13        Q.   And it says that:

14             "Operational and investigative activities determined those

15     persons interesting for security reasons who directly or indirectly

16     participated in the armed rebellion in the Prijedor municipality, and all

17     operatives participated in the processing of these persons."

18             I take this to mean that the operatives from Prijedor SJB helped

19     with that work at Keraterm and Omarska.  That's right, isn't it?

20        A.   That is my inference too.  I don't know whether that is correct,

21     though.

22        Q.   Fair enough.  If we could go to page 8 of the English.  I think

23     it's the last page for you, Mr. Macar.  Just one question --

24             MR. ZECEVIC:  I'm sorry -- I'm terribly sorry.  Again, we have

25     a -- I believe we have a problem with the interpretation.

Page 23461

 1             On the previous page, if we can return back.  Perhaps the witness

 2     can read, because I don't think the whole sentence is missing [sic] in

 3     the English translation.

 4             MR. HANNIS:  Could you be a little more specific.

 5             MR. ZECEVIC:  The -- the page 3, the part which you read.  Oh,

 6     it's okay, I'm sorry.  I'm terribly sorry.

 7             MR. HANNIS:

 8        Q.   Okay.  Mr. Macar, are you on the last page?  Yeah, you see a

 9     highlighted paragraph.  This is dealing with communications from

10     Prijedor.  You see it says it's sent 696 dispatches, 678 which were

11     unsealed and 18 were in code.  Do you see that one?  Yes.

12             Now, above that, it says that they received and there's a number

13     that can't be read, I guess, from the B/C/S copy.  "... of which 234 were

14     unsealed and 19 were coded."

15             Would you agree with me that probably that illegible number

16     should be 253 because that is the total of coded and uncoded documents?

17     19 plus 234 equals 253.  Makes sense, doesn't it?

18        A.   It's possible.

19        Q.   Okay.  Thank you.  I'm going to ask you about another topic now.

20             In 1992, did you ever hear about the six strategic goals of the

21     Serbian people in Bosnia and Herzegovina?

22        A.   No.

23        Q.   After 1992, did you ever hear about the six strategic goals that

24     were first pronounced at an Assembly session on the 12th of May, 1992?

25     Did you never hear about that?

Page 23462

 1        A.   No.

 2        Q.   Let me show you Exhibit P -- let me show you Exhibit P187.  And

 3     this was tab 82 in the Prosecution's list.  It will be up on the screen

 4     in a minute.  It's just a one-page document.

 5             You see this is the decision.  And this -- the objectives are a

 6     border separation between the Serbian people in Bosnia-Herzegovina and

 7     the other two national communities.

 8             A corridor between Semberija and Krajina.

 9             A corridor in the valley of the Drina so as to eliminate any

10     border between the RS and the Republic of Serbia.

11             Another border on the Una and Neretva rivers.

12             Division of Sarajevo into Serbian and Muslim parts.

13             And an exit for the RS to the sea.

14             You never heard of these six strategic objectives.  Is that

15     right?

16        A.   No, I never heard of those.

17        Q.   And in conjunction with Crisis Staffs, did you ever hear of a

18     document called the Variant A and Variant B instructions issued by the

19     SDS in December of 1991?  Did you never hear of that document?

20        A.   As I told you before, I was not a member of the SDS.  I wasn't

21     even close to the inner circle of the SDS leaders.  I didn't know about

22     their activities.

23        Q.   I understand that.  But you've given us a lot of evidence and

24     testimony about Crisis Staffs, so I thought you may have heard of that

25     document.

Page 23463

 1             Let me show you --

 2        A.   No.

 3        Q.   Let me show you 65 ter -- it's tab 94.  It's a map.  It's

 4     65 ter 20050.  I can hand you a copy.  I'll tell you this is from -- from

 5     the Defence expert's report, and this is a colour version of the map that

 6     was attached to one of his documents in his expert report.

 7             If the usher could assist me, I'll hand you this.

 8             It's a map of Bosnia and Herzegovina, and it's colour coded.

 9     This was being used in conjunction with the discussions that were going

10     on in late 1991 and early 1992 before the conflict broke out in April.

11     Now I think you've told us it was your understanding that this new RS MUP

12     was being created because of the agreement of the three parties.  But

13     you'll see that under the plan, a number of municipalities that were

14     foreseen as Muslim areas were, indeed, taken over by the Serbs and

15     Serb SJBs were established.  For example, in Foca, Visegrad, Rogatica,

16     Vlasenica, Bratunac, Zvornik, Brcko.

17             So, in effect, isn't it true there wasn't agreement and the

18     Bosnian Serbs had already decided which territories they wanted and that

19     was further reflected in the strategic objectives we saw in that

20     May 12th, 1992, document?

21        A.   The six strategic objectives were part of the war operations.

22     Therefore, I wasn't familiar with that.  Nor, indeed, could I tell you

23     anything now about the ethnic makeup back in 1992, 1991, or, indeed,

24     1990.  I had an opportunity to share some information here, but I never

25     saw the ethnic makeup represented like that.  I couldn't tell you about

Page 23464

 1     the exact figures in any of the municipalities.  Therefore, I'm hardly

 2     the right kind of person to talk to about that.  The issue or, indeed,

 3     the map.

 4        Q.   Okay.  Isn't it true that -- that the civilian authorities and

 5     the Crisis Staffs, for example, and the police and the army were working

 6     together, sometimes better, sometimes not so well, but were working

 7     together to achieve those strategic objectives?

 8        A.   I really can't address that.  I can't say whether the strategic

 9     objectives were something that the municipal bodies were dealing with,

10     or, indeed, the Ministry of the Interior, and, if so, to what extent.

11     Had this been the case with the ministry, I think I would have bound to

12     notice, to some extent.

13        Q.   All right.  Let me show you another document.  This is it

14     65 ter 1640.  I believe it is tab 43.

15                           [Prosecution counsel confer]

16             MR. HANNIS:  Tab 43.

17        Q.   And with the usher's help, I can give you a hard copy.

18             It's dated the 12th of September, 1992.  I don't know if you're

19     able to read the last page of my copy.  But I can tell you it comes from

20     Commander Stanislav Galic from the Sarajevo-Romanija Corps.  You know who

21     he was; right?

22        A.   I heard of him, but I didn't know him.

23        Q.   Okay.  After the war, you've heard about who he was; right?

24        A.   Yes.

25        Q.   On the first page, item number 3, he is talking about things that

Page 23465

 1     need to be done.  And it says:

 2             "Ensure absolute agreement and unity with the civilian

 3     authorities and MUP forces at all levels.  Eliminate the creation of any

 4     paramilitary units or para political, and eliminate any squabbles because

 5     we have the same goals."

 6             That's true, isn't it, what General Galic, or Colonel Galic at

 7     the time, is saying?

 8        A.   Could you please repeat the specific item you were referring to?

 9        Q.   It's number 3 on my list.  Did you find it?

10             "Ensure absolute agreement and unity with the civilian

11     authorities and MUP forces at all levels.  Eliminate ... paramilitary

12     units ... eliminate any squabbles because we have the same goals."

13             Do you disagree?

14        A.   And the question is?

15        Q.   That's correct isn't it?  That the police and the civilian

16     authorities and the VRS had the same goals in September 1992.

17        A.   If by objectives you mean the preservation of Republika Srpska

18     and the establishment of appropriate authorities in Republika Srpska, to

19     guarantee the safety of all citizens there, in that case the answer is

20     yes.

21             The objective of the army was to preserve the territory of

22     Republika Srpska.  The civilian authorities were to do their own jobs,

23     including logistics for the army.  The police were to do their work.  The

24     common objective was to preserve Republika Srpska and to make sure that

25     it was functioning properly, as well as to ensure the safety of all its

Page 23466

 1     citizens and the survival of its economy.

 2        Q.   But as we saw on the 12th of May, the first strategic objective

 3     was a border separating from the other two ethnic parties; right?

 4             MR. ZECEVIC:  I would just remind Mr. Hannis to read the whole

 5     strategic objective if he is putting that to the witness.

 6             MR. HANNIS:

 7        Q.   Number 1 was border separation of the state from the other two

 8     national communities.

 9             JUDGE HALL:  The witness has indicated that we would take a break

10     now --

11             MR. HANNIS:  Ah, okay.

12             JUDGE HALL:  -- and we're near the time for -- that we rise.  So

13     will --

14             MR. HANNIS:  Thank you.

15                           [The witness stands down]

16                           --- Recess taken at 11.42 a.m.

17                           --- On resuming at 12.02 p.m.

18             MR. HANNIS:  Your Honours, while the witness is coming in, I just

19     wanted to inquire what time should I take the next break.

20             JUDGE HALL:  I was seeing whether we could do with anything with

21     this odd half-hour we would have at the end of the day if we sit

22     according to the schedule we're having now.  But I think it would be

23     simpler to just continue the hour pattern and then the 15-minute break,

24     and the half-hour that we lost this morning is simply irrecoverable.

25     That's ...

Page 23467

 1             MR. HANNIS:  Mm-hm.  So I was thinking I would take a break at

 2     12.45 or 1.00 or ...

 3             JUDGE HALL:  Well, between 12.45 and 1.00, depending on the

 4     witness's disposition.

 5             JUDGE DELVOIE:  Mr. Hannis.

 6             MR. HANNIS:  Yes.

 7             JUDGE DELVOIE:  Tab 94 of your binder, you showed the witness the

 8     Cutileiro map.  You remember?

 9             MR. HANNIS:  Yes.

10             JUDGE DELVOIE:  You didn't tender that one.

11                           [The witness takes the stand]

12             MR. HANNIS:  Your Honour, I'd like to tender it.

13             JUDGE DELVOIE:  Is there a problem why it shouldn't be tendered?

14     Is it a special number or something --

15             MR. HANNIS:  No, Your Honour.

16             JUDGE DELVOIE:  -- 94, 2050 --

17             MR. HANNIS:  I think the difference -- as I recall, that's a map

18     that we took from one of the annexes to Mr. Bajagic's expert report and

19     we had put in colour because I think what we had from him was a black and

20     white version.  And I don't remember if his map had the names of all the

21     municipalities.  I think that is how this map is different.  But in terms

22     what was showing what was Serb, Muslim and Croat, it's the same.

23             JUDGE DELVOIE:  And where does this map come from, then?  Is it

24     something OTP put together?

25             MR. HANNIS:  Yeah.  We have colourised it and put in the names of

Page 23468

 1     the municipalities.

 2             JUDGE DELVOIE:  Okay.  Okay.

 3             Then perhaps you will object, Mr. Zecevic?

 4             MR. ZECEVIC:  By all means, I would, Your Honours, because I

 5     don't know what was the basis for -- for -- for this colouration and

 6     adding and what is the original map.

 7             JUDGE DELVOIE:  Okay.  Yeah.  Okay.  Thank you.

 8             MR. HANNIS:  I will get back to that, Your Honour, because I

 9     think that the showing of the territories was reflected on the black and

10     white by various shades of grey and it was just putting in the names of

11     the municipality, and I'll talk to Mr. Zecevic about that.

12        Q.   Mr. Macar, you mentioned a conflict that existed between

13     Mico Stanisic and the MUP on the one hand and Mrs. Plavsic, among others,

14     on the other side.  And this conflict was rooted, in part, over the fact

15     that Mrs. Plavsic had early in the conflict invited outsiders to come and

16     assist the Bosnian Serbs in the conflict, and a number of those people

17     that she invited later turned out to be problems for the

18     Republika Srpska, some of those volunteers.

19             Is that a fair statement so far?

20        A.   You could say that that is one of the reasons.  But the best part

21     of the reason is a certain amount of misinformation in the work of the

22     ministry, regrettably, also spread by Mr. Djeric and some others about

23     Ms. Plavsic, or, rather, being forwarded in the direction of Ms. Plavsic,

24     based on which she created an opinion concerning the minister and the

25     work of the ministry.  I know that in 1993, 1994, and 1995 there were

Page 23469

 1     continuing attacks on the ministry at meetings.  Unfortunately, she never

 2     visited the ministry in order to familiarise herself with the MO of the

 3     Ministry of the Interior and any problems that we encountered in our

 4     work.

 5             MR. ZECEVIC:  I believe the witness -- yeah.  Thank you.

 6             MR. HANNIS:

 7        Q.   I want to show you Exhibit P591.  It's Prosecution tab 96.  And

 8     if you could just look at the screen at the first page, it's up, I will

 9     tell that you is a report from the VRS, in particular from

10     then-Colonel Tolimir and it's a report on paramilitary formations in the

11     territory.  Did you ever see this before?

12        A.   No.  I'd appreciate a copy, in case you have a spare one for me.

13     It's difficult for me to read this.

14        Q.   Okay.

15             MR. HANNIS:  And I see Mr. Zecevic has one.  Thank you.

16        Q.   The usher will hand it to you in a second?

17             Among those listed are Arkan's Men and Seselj's Men,

18     Captain Dragan's Commandos, Carli's Men, and White Eagles.  You're not

19     saying, are you, that all of these groups were ones that came because of

20     Mrs. Plavsic, are you?

21        A.   No.

22        Q.   You were aware that these groups, like Arkan's Men and

23     Seselj's Men, and White Eagles were operating in the territory in 1992

24     and in some cases committing crimes.  They weren't merely defending the

25     Serbian people in the RS and fighting in combat but they were also

Page 23470

 1     committing crimes; right?

 2        A.   As for the number and types of paramilitary formations active

 3     throughout the territory of Republika Srpska, I can't really say how many

 4     exactly there were.  Some came as volunteers to the VRS.  As far as some

 5     of them are concerned, we received information that they tore themselves

 6     away from their rightful commands in Foca and some other parts of the

 7     Krajina.  It's very difficult for me to say which of these were brought

 8     in by Ms. Plavsic herself.

 9             The one thing I do remember is that there was one of these

10     meetings at Pale attended by Ms. Plavsic herself.  At this meeting she

11     said she herself made an effort to get some volunteers in, but she didn't

12     say which exactly; was it the Wolves, was it the Spare Ribs or whoever,

13     she didn't say.  I didn't hear of any of these at the time.  I heard

14     about some of them later.  But one thing that I can say is that I didn't

15     see this specific document.

16        Q.   But my question was:  You were aware that these groups, like

17     Arkan's and Seselj's and White Eagles, not only were participating in

18     combat, were also committing crimes in the RS.  You knew about that,

19     didn't you?  Didn't hear about Seselj's Men committing crimes?  Or

20     Arkan's Men?  Or White Eagles?

21             You were the chief of the crime police in the RS MUP.  You must

22     have heard that?

23        A.   Military formations were just that for me, military formations.

24             As to their individual components, that's not something that I

25     knew about it.  The one thing I did hear, which was also one of the

Page 23471

 1     reasons that we started arresting people from those units, was the

 2     Yellow Wasps.  All of that was under the jurisdiction of the military

 3     security people and the military police, so they did their job.  Whenever

 4     our stations came by information, they would have by default informed our

 5     own security officers under who had jurisdiction they worked.

 6             I heard about the crimes committed by the Yellow Wasps

 7     specifically.  But this was a job that was done by the security people of

 8     the army and the military prosecutor.  I received no feedback as to

 9     whether they were successful in shedding any light on that particular

10     crime.

11        Q.   Are you telling us that you never heard of any crimes being

12     committed by Arkan's Men, Seselj's Men, or White Eagles in the

13     Republika Srpska in 1992?  Is that what you're saying?

14        A.   I spent the best part of that period of time in Sarajevo, in

15     Vrace, and then later I went to Bijeljina.  You've given me all these

16     names, but I wasn't aware of most of them at the time.  I knew there were

17     some volunteers in the VRS.  Were those Seselj's Men, Carli's Men,

18     Jovic's Men?  They were under the jurisdiction of the VRS, and they

19     deployed them in their units the best they could.  I don't think they

20     were marked out as something special or different; marked out, in other

21     words, as Seselj's Men, as Jovic's Men, and so on and so forth.  There

22     was no way I could have known that they constituted some sort of a

23     special or separate component.

24        Q.   Really, Mr. Macar, the VRS wasn't created until 21st of May -- or

25     the 12th of May was when it was pronounced and it started on the

Page 23472

 1     21st of May.  You weren't aware of Arkan's or Seselj's Men operating in

 2     Sarajevo before that?  And, thus, they could not have been part of the

 3     army because it didn't exist yet.

 4        A.   There was the Territorial Defence.  That, is the people were

 5     organised through the TO and their military units defended their

 6     territory.  Whether there were any Arkan's Men in Sarajevo, I really

 7     don't know.  Roads were not safe, so it wasn't easy to go from one part

 8     of Sarajevo to another at the time, so they may have been present in a

 9     part of town.  And the army consisted of organised territorial units.

10     They were organised through the staffs of Territorial Defence.  And what

11     kind of volunteers there were, that's something I really cannot comment

12     on.  Our main concern was, from late April on, to establish the MUP

13     headquarters, create the conditions necessary for that at Vrace, where we

14     were almost cut off from everything.

15        Q.   In Sarajevo, did you never hear of Slavko Aleksic?

16        A.   I learned more about Mr. Slavko Aleksic by following the trial at

17     the ICTY and the information about that in the Bosnian media.  Most of

18     what I know originates from this Tribunal.

19        Q.   Okay.  Are you aware he was a member of the reserve police?

20        A.   I did not know that.  There were hundreds of them, so how should

21     I have known by name, by face, or any other way?

22        Q.   There were hundreds of Slavko Aleksics?  Is that what you're

23     saying?

24        A.   In the situation that prevailed in late April until the time I

25     left Sarajevo, the name Slavko Aleksic meant nothing to me.

Page 23473

 1        Q.   Which trial in the ICTY were you following where you heard about

 2     Slavko Aleksic?  Was it this one or some other one?

 3        A.   I think it's another case.  It could be Seselj or some other.  I

 4     don't recall.

 5        Q.   How many trials have you been following?

 6        A.   I did so very rarely.  Perhaps before going to bed, I would see a

 7     news flash of about a minute or two, but I didn't really follow

 8     attentively.

 9        Q.   And the Slavko Aleksic you heard about is the one who was

10     commanding forces in the front line neighbourhood near the Jewish

11     cemetery in Sarajevo?

12        A.   I'm under oath, so I must say that I was not familiar with his

13     movements, nor do I know which unit he led.  I can say no more.

14        Q.   Did you ever meet him?

15        A.   Mr. Aleksic?  No.

16        Q.   Did you ever see him on the news or in the newspaper?

17        A.   If he were to walk past me right now, I wouldn't recognise him by

18     face.  But I do remember the name.

19        Q.   What about Batko?  Did you hear of a man whose nickname was

20     Batko?  Veselin Vlahovic, I think, is his full name.

21        A.   The name Batko is something I remember in -- yes, I heard of

22     Veselin Vlahovic who was arrested in Spain, I think.

23        Q.   Just recently, right, in the past year?

24        A.   I don't know exactly.

25        Q.   And in 1992, you must have heard about him.  He was, in some

Page 23474

 1     ways, a one-man crime wave in certain parts of Sarajevo.  I think

 2     particularly in the Grbavica area.  You knew about that, didn't you?

 3        A.   Whether he started a crime wave or not, I don't know.  But the

 4     MUP, through the public security station, received information from the

 5     citizens about Batko's activities.  He was said to belong to some

 6     military unit, and then the station first informed the military police.

 7     After that, I remember that, pursuant to Mr. Planojevic's orders, and

 8     after consultations with the minister, attempts were made to arrest him,

 9     but a short while before that, the military police arrested him and

10     launched the relevant procedure.

11        Q.   You were aware that part of the conflict between Mrs. Plavsic and

12     Mr. Stanisic, and, indeed, on Mr. Stanisic's side, Mr. Mandic and

13     Radovan Karadzic, was over Batko and the failure to effectively do

14     anything about him.  You knew that, didn't you?

15        A.   I cannot comment that, but I know that the police did everything

16     necessary, once it received information from the citizens of the area, to

17     arrest Batko.  They even informed the military police there.  I don't

18     remember what their organisation was like, but I think that it went

19     through the public security station.  After some time, and I remember

20     that a larger-scale action was planned, but then before it -- the

21     operation was launched, the military police arrested him, if I remember

22     correctly.

23        Q.   And he was released within ten days and nothing else ever

24     happened to him, in terms of prosecution, until his recent arrest last

25     year; right?

Page 23475

 1        A.   What happened to him later, if he was released, or if he escaped,

 2     or if he was tried, I don't know, but I know that he was no longer in the

 3     area.  Quite some time later, it transpired that he had escaped from the

 4     military police detention facility, which caused revolt in the police and

 5     also among the citizens, Serbs and non-Serbs alike.

 6        Q.   You all right?  Can we continue --

 7        A.   Yes, yes, I'm just trying to find the right position.

 8        Q.   I'd like to show you now Exhibit P746.  It's tab number 97.

 9             If the usher could assist me, I'll hand you the hard copy.  It's

10     apparently processed on the 18th of August, 1992.  And it's from

11     Colonel Sipcic in the Sarajevo-Romanija Corps.

12             Did you know who Colonel Sipcic was?  He was in the VRS in the

13     Sarajevo area.

14        A.   The name is familiar, but I don't remember the colonel.

15        Q.   The first paragraph is talking about sniper activity --

16             MR. ZECEVIC:  I'm sorry.

17             MR. HANNIS:  Yes.

18             MR. ZECEVIC:  Mr. Hannis, I have to object.  The first document

19     that you show, I didn't, because I was wondering whether you intend to

20     inquire with the witness, has he ever seen the document.  Like you are

21     teaching me during my direct, I now have to obviously remind you that you

22     have to establish whether the witness have seen this document at all, has

23     he read it, and all the other things that you need before you can read

24     from the document.  Otherwise, you can pose the question, I guess.  That

25     was the -- so far, that was the rulings that I remember in this trial.

Page 23476

 1             MR. HANNIS:  Well, I'll leave it to Their Honours.  I don't know

 2     that that's necessarily always true.  And I will ask him.

 3        Q.   Have you seen this document before?

 4        A.   No, I haven't.  But I see that it says Major-General rather than

 5     Colonel Sipcic.

 6        Q.   I -- if I said "colonel," I misspoke.

 7        A.   I have not seen the document and don't know what it contains.

 8        Q.   Okay of the first paragraph he is talking about activities in

 9     Nedzarici, Dobrinje, Grabovica, Rajlovac.  In paragraph 4 --

10             JUDGE HALL:  Well, let him read it and then pose a question,

11     Mr. Hannis.  That is what Mr. Zecevic was reminding you about.

12             MR. HANNIS:  Well, Your Honour, I didn't think it was necessary

13     to have him read the entire document.  I wanted to direct him to a

14     specific paragraph and then I'll read that paragraph to him and ask him a

15     question.

16             JUDGE HALL:  Yes, well, you could direct -- ask him to read only

17     that paragraph to which -- on the basis of which you wish to pose your

18     question.

19             MR. HANNIS:  Your Honour, it's been my practice before now,

20     oftentimes that I will read the paragraph.  Is there a problem with that?

21             JUDGE HALL:  The problem is the -- putting on the record

22     documents which may not become evidence.  And that is what we are trying

23     to avoid.

24             MR. HANNIS:  Your Honour, this one is P746.  It is already in

25     evidence.

Page 23477

 1             JUDGE HALL:  Oh, I'm sorry.

 2             MR. HANNIS:  That's why I was confused.

 3             JUDGE HALL:  Yes, you are correct, Mr. Hannis.

 4             MR. ZECEVIC:  But there's one other slight problem, Your Honours.

 5             Can we -- can Mr. Hannis establish whether this document, what is

 6     the date of this document?  Does this document actually refers to 1992 or

 7     some other time in the war?

 8             MR. HANNIS:  I already indicated that the document itself

 9     indicated that it was processed on the 18th of August.

10             MR. ZECEVIC:  But it doesn't say which year.  That's the point.

11             MR. HANNIS:  Given where the locations are, and the sniper

12     activity ...

13             MR. ZECEVIC:  Well, Mr. Hannis, with all due respect, we had --

14     with had the trial of Sarajevo for the -- for the period of time between

15     1992 and 1995, and there has been allegations about the snipers and

16     everything else during the whole period of war in Sarajevo.

17             So, therefore, I don't think -- I'm pretty sure, actually, that

18     this document does not refer to 1992 at all.  That is -- that is the

19     point.

20             MR. HANNIS:  Then, Your Honour, that objection should have been

21     made when the document came into evidence.

22             MR. ZECEVIC:  Well, I'm just trying to find out whether this

23     document was offered or it was introduced through a package or some other

24     way.  But I'm trying to find the reference.

25             MR. HANNIS:  Okay.

Page 23478

 1             JUDGE HALL:  Well, Mr. Zecevic, save for the witness being

 2     assisted, in terms of the greater precision as to the date of this

 3     document, it is by whatever means already before the Tribunal so

 4     Mr. Hannis should proceed.

 5             MR. HANNIS:  Thank you.

 6        Q.   The last sentence in paragraph 4 about morale says:

 7             "Paramilitary formations that are still not disarmed are causing

 8     big problems.  They behave more violently and are arrogant.  Disarming

 9     these formations will not possible without armed clashes with them,

10     especially since they are supported and established by certain organs in

11     the local authorities and the police."

12             Isn't that true that some of these paramilitary formations were

13     supported by the municipal Crisis Staff or the SDS and/or the police in

14     some of the municipalities in the Republika Srpska in 1992?

15        A.   Let me first say that if the document is from 1992, I wasn't in

16     Sarajevo on 18 August.  On the other hand, I can't help wondering,

17     because it says Major-General.

18        Q.   Yes, but if you could focus on my question.  My question is:  Is

19     that statement there true?  Isn't it true that in 1992, in various

20     municipalities throughout Republika Srpska, that there were paramilitary

21     formations that were supported by the local authorities, Crisis Staffs,

22     and/or by the local police?  That was the situation in some

23     municipalities in the Republika Srpska in 1992, wasn't it?

24        A.   Whether the police was supporting paramilitaries or took part in

25     the creation of such units, is something I don't know.  And that's why I

Page 23479

 1     am surprised to read the words of a major-general to make such a general

 2     statement.  One would expect more precision from such a high-ranking

 3     officer, such as the police from Nedzarici or the police from Ilidza,

 4     that would be more precise.  But some Crisis Staffs, some police

 5     organisations, all that makes me wonder.  I don't know what to say about

 6     this document.

 7        Q.   You haven't answered my question.  Are you saying -- you just

 8     didn't know of that -- you didn't know of that happening in any

 9     municipality in Republika Srpska in 1992?  Is that your answer?  You

10     weren't aware of any local -- any paramilitary being supported by the

11     local authorities, Crisis Staff, or the local police?  Never heard of

12     that happening?  Is that what you're saying?

13        A.   The police supporting paramilitaries, no.  I'm not aware of that.

14        Q.   Crisis Staffs?

15        A.   If Crisis Staffs did, where I was involved and had information, I

16     mean, where I was involved in breaking up these paramilitaries, to what

17     extent the Crisis Staff of Zvornik supported the Yellow Wasps or whatever

18     those people in Teslic were called or anywhere else, that is a segment I

19     didn't deal with being in my administration.  Receiving information from

20     a centre chief that they had problems because some Crisis Staff was

21     supporting a paramilitary unit is something else, but those paramilitary

22     units were part of the army.  So what exactly is supported?  Is it the

23     army or some unit that had broken loose?  That's how I look at

24     paramilitary units.

25             I am not aware of such renegade units being supported by the

Page 23480

 1     police.

 2        Q.   Okay.  You asked for some more precision.  Let's go back to P591.

 3     Tab 96.  This is Mr. Tolimir's report, Colonel Tolimir's report.  I only

 4     showed you the first page, but in light of your comments, I think I need

 5     to show you one more.

 6             Do you still have the hard copy of that?  That's the one that

 7     has -- it's dated the 28th of July, 1992.  Information on paramilitary

 8     formations.  Do you have that in front of you?

 9        A.   Yes.

10        Q.   If you could go to your page 3 in B/C/S at the bottom.  No, I'm

11     sorry, I think I misinformed you.  It's your page 5.  English page 4 at

12     the bottom.  Your page 5.  And it's the second bullet point down:

13             "Serbian defence forces SOS from Banja Luka ..."

14             Do you see that?

15        A.   Yes.

16        Q.   Serbian defence forces SOS from Banja Luka under the command of

17     Nenad Stevandic, who was also president of the Serbian Sokol Society,

18     private businessmen and some senior SJB and SNB officials in the

19     Banja Luka CSB have considerable influence over the SOS, but many

20     infamous Banja Luka criminals have joined the SOS.  Part of the SOS

21     formations joined the Banja Luka CSB special police detachment, but it's

22     not really under either the control of the detachment's command or the

23     CSB.  Som SDS members have joined the Banja Luka TO."

24             Doesn't that show that the local police and local officials are

25     supporting one of these paramilitary formations in Banja Luka?

Page 23481

 1        A.   If I may read it, because I haven't seen this document before.

 2        Q.   You mean you want to read the whole document?

 3        A.   No, no, this paragraph.

 4        Q.   Go ahead.

 5             JUDGE HALL:  Mr. Aleksic, you have an interjection.

 6             MR. ALEKSIC: [Interpretation] Thank you, Your Honours.

 7             I have the same objection as put forward by Mr. Zecevic earlier.

 8     The witness gave evidence that he hadn't seen this document before.  Now

 9     Mr. Hannis is reading something to him, and the witness said that he had

10     no information about any municipality.

11             Or perhaps the witness should remove his headphones.

12             [In English] Yeah, but I'm talking in Serbian, so it is the same.

13             [Interpretation] To cut a long story short, the same objection,

14     the witness hasn't seen the document, and he said earlier that he didn't

15     have any information.  Now Mr. Hannis is reading something out to him and

16     asking him, "Do you agree?"  But the witness has already said that he

17     didn't have any particular information and that includes SOS in

18     Banja Luka.  Thank you, Your Honours.

19             JUDGE HALL:  Yes, I note your objection, Mr. Aleksic, but isn't

20     the position that counsel, in this case from the OTP, has a witness on

21     the stand, and he -- who is testifying generally about matters which are

22     dealt with -- which have been dealt with in this case through a document.

23     Admittedly, the witness has explained that he hasn't seen this particular

24     document before, but it seems to be perfectly permissible, as Mr. Hannis

25     did with to the previous witness, to ask him to -- I'm trying to phrase

Page 23482

 1     it correctly because it would be improper for him to ask the witness to

 2     comment on what another witness has said.  But for -- for his --

 3     understanding of the same events.  If you understand that balance that

 4     Mr. Hannis I'm sure is aware that he has to strike.

 5             MR. HANNIS:  Thank you, Your Honour.  And I dealt with it because

 6     the witness said he was unaware of any municipality where that was the

 7     situation, and I was trying to show him where there was an example to see

 8     if that might refresh his memory.

 9             All right.  Your Honours, I see it is 12.43.  Might this be an

10     appropriate time for the break.

11             JUDGE HALL:  If this is convenient for everyone, we may as well

12     break now, yes.

13             MR. HANNIS:  Thank you.

14                           [The witness stands down]

15                           --- Recess taken at 12.43 p.m.

16                           --- On resuming at 1.02 p.m.

17             MR. HANNIS:  Your Honours, I know you indicated that I should

18     finish my cross-examination in the course of day.  I'm still hoping to do

19     so.  Depending on how well I'm able to phrase my questions and get short

20     answers, I -- I hope to do so.  If not, I may find myself in the position

21     of requesting 15 additional minutes tomorrow.

22             JUDGE HALL:  So noted, Mr. Hannis.

23                           [The witness takes the stand]

24             MR. HANNIS:  Thank you.

25        Q.   Mr. Macar, I want to ask you if, in 1992, you received any

Page 23483

 1     information about crimes being committed by policemen in Foca?

 2     Specifically, policemen who were guarding non-Serb detainees in Foca.

 3             Did you or your inspectors ever become aware of that?

 4        A.   I can't remember that, in 1992, I received any information about

 5     members of the police committing a crime.

 6             May I put this document aside, please, the military one?

 7        Q.   Yes, you may.  Did you, in watching proceedings at this Tribunal,

 8     never see the proceedings regarding Foca, where there were allegations

 9     against police in Foca, among others, having committed a sexual assault

10     against female detainees in Foca?  Did you know about that?

11        A.   No, no.

12        Q.   Okay.

13        A.   I said I didn't watch regularly.  I would just happen to see a

14     snap-shot or two sometimes.

15        Q.   In September 1992, where were you living and working?  Were you

16     still in Pale?  Were you in Bijeljina yet; do you recall?

17        A.   Both.  On the 3rd of September, the whole team that worked on the

18     Yellow Wasps case returned.  In September, we were at a collegium

19     meeting, after which we went back to Pale.  Preparations were in progress

20     in September to relocate the HQ of the Ministry of the Interior.

21        Q.   Do you recall hearing about the murders of three Muslim families

22     in Bijeljina on about the 25th of September, 1992?  It was, as I

23     understand, highly publicised in the municipality.  Did you learn about

24     that in 1992?

25        A.   No.  I think I was in Pale at the time.  It was sometime in

Page 23484

 1     October that we returned to Bijeljina.  The murder of these three

 2     families, I'm not sure if they were all murdered at the same time or at

 3     various intervals.

 4        Q.   I understand that this all happened on one night, about the

 5     25th of September.  And Mr. Blagojevic from the Serbian Radicals

 6     published something in the local media, suggesting that the crimes had

 7     been committed by Dusko Malovic's unit from the MUP.

 8             And you're telling us you never heard about that in 1992?

 9        A.   No.  When the administration arrived Bijeljina and when it was

10     set up there, it received no information concerning the murder of these

11     three families during the same night, as you suggest.  I only met

12     Mr. Blagojevic in mid-1993 -- rather, not met, not personally.  I learned

13     of him.

14        Q.   Okay.  You never heard about it from Tomo Kovac in 1992?

15        A.   No.

16        Q.   Who was the head of state security at Bijeljina CSB in September

17     1992?  Vukovic?  Vuckovic, something like that?

18        A.   Mr. Drago Vukovic or perhaps someone else.  State security, the

19     boss.

20        Q.   And you never heard from him about these murders either?  Is that

21     right?

22        A.   From?

23        Q.   Mr. Vukovic, state security?

24        A.   No, no.

25        Q.   And you've personally have never been interviewed by anybody from

Page 23485

 1     the prosecutor's office in connection with your knowledge, if any, about

 2     that event?

 3        A.   No one before you.

 4        Q.   All right.  I think the total number of persons killed was

 5     somewhere between 20 and 30.  That still doesn't ring a bell.  Sejmenovic

 6     and Sarajlic are the names of two of the families.

 7        A.   Now that you've mentioned the family name of Sarajlic, I know

 8     about that from the media.  I learned about that in the media two or

 9     three years ago, the Sarajlic case being mentioned.

10        Q.   I want to ask you about Koricanske Stijene.  When was the first

11     time you heard about the killing of 150 to 200 non-Serbs in August of

12     1992?

13        A.   If memory serves, at the time we were preparing for our move to

14     Bijeljina, and when I drew up that list, I was gathering some

15     information.  I can't say this with absolute certainty, but I think I saw

16     some dispatches by the minister and was there a reference there to the

17     murder of hundreds of Muslims or Croats, and I read the instructions and

18     that he gave, or, rather, his response to that event.  It wasn't before

19     the first trimester in Banja Luka that I was informed by the leading men

20     in the crime unit about what had occurred at Koricanske Stijene and also

21     about what measures had been taken following that event.

22        Q.   Okay.  We have information in the case, I think it's

23     Exhibit P2303, at pages 3 to 5, for counsel's reference, that

24     Mr. Stanisic knew about this two or three days after it happened.

25     Wouldn't he have informed you, given your position as head of the crime

Page 23486

 1     police administration, of an event as significant as this one?

 2        A.   As you know, I was in Bijeljina at the time with specific

 3     missions there.  I was coordinating all of the operative work there.  It

 4     wasn't until after the event, because the centre probably hadn't informed

 5     me about the event, that I had a chance to respond to an event as

 6     momentous as that.  I think it wasn't before I arrived in Pale on the

 7     3rd of September, when we started our preparations, that I saw the

 8     dispatch by the minister containing specific instructions and a response

 9     to the events.

10             MR. ZECEVIC:  I'm sorry.  Can the witness -- because none of his

11     answer was properly recorded, can he be instructed to talk slowly because

12     what we are getting in the transcript is not what he said.

13             MR. HANNIS:  Certainly not what he said before.

14        Q.   Can you repeat your answer.  Because you're recorded as having

15     said when you arrived in Pale on the 3rd of September, "I saw the

16     dispatch by the minister."  Is that what you said?

17        A.   No.  I said I think that that the first I learnt about the event

18     was during our preparations for the move from Pale.  This was the first

19     time I saw a dispatch sent by Mr. Minister to the public security centre

20     in Banja Luka with the adequate response to the event.

21             As you know, the reporting system between October and as late as

22     November did not go from the centre stations to the administration.

23        Q.   I'm just trying to be clear now.  I had understood you to say

24     last week that the first time you heard about the Koricanske Stijene case

25     was in March of 1993.  Now you're telling me about it -- you knew about

Page 23487

 1     it in, what, September 1992?

 2        A.   I think I said it the last time around.  Information on the

 3     event, and then it wasn't before March that I had an opportunity.

 4        Q.   Maybe we're not understanding each other.  I'm trying to find out

 5     when was the first time you personally had any information, orally or in

 6     writing, about this crime at Koricanske Stijene that happened around the

 7     20th, 21st of August, 1992?

 8             Did you find out it in 1992 or not until 1993?  I'm not saying

 9     full information.  When was the first time you heard anything about it?

10        A.   About the event, meaning, as I said a while ago, I think it was

11     in September 1992; information that an event like that occurred.

12        Q.   And how did you find that out?  Were you told personally by

13     somebody, or did you see a document?

14        A.   During the preparations for the move and while gathering

15     information, I saw a document sent by the minister to the public security

16     centre, or, rather, the -- the communique.  Specifically, I remember a

17     document, the dispatch, sent by the minister to the public security

18     centre with certain instructions that were more of a response to a

19     serious event, and the public security centre knew how to act on it.

20        Q.   Okay.  Let's show you Exhibit P847.  This is tab 128.

21             MR. HANNIS:  This is one that I just added this morning,

22     Your Honours.

23        Q.   And I would hand you a hard copy but my hard copy is not very

24     legible.  And I don't know if e-court is any better.  That's not it yet.

25     Yes, the B/C/S copy is not very legible.  But I tell you, an English

Page 23488

 1     translation was made apparently by somebody working from a better copy.

 2     Perhaps the original from the evidence vault.  And it's dated the

 3     31st of August, 1992, from Mico Stanisic to the chief in Banja Luka CSB,

 4     ordering him "to conduct a full investigation regarding the deaths of

 5     150 Muslims in the territory of the municipality of Skender Vakuf at

 6     Koricanske Stijene."

 7             Is this the dispatch you were talking about; and do you think

 8     this is the one?  Sounds like you were describing the same thing.

 9        A.   I can't see what it says.  But I think it was a longer text than

10     this.

11        Q.   Okay.  I want to ask you if it would be -- well, what was the

12     procedure?  Was there a role for you in a case like this; or did you just

13     simply sit back and wait for something to be done by your administration

14     in the CSB?

15             This seems like a big case, and it seems like it would be

16     something that the minister would involve you in; but maybe I'm wrong in

17     assuming that.

18        A.   The minister responded in keeping with his function.  Public

19     security stations and the public security stations [as interpreted]

20     operate in keeping with the Law on Criminal Procedure and the

21     Criminal Code.  And the -- at the end of it all, it is my opinion that

22     the Banja Luka centre had much better men at its disposal than I did, the

23     seven or eight people that I had over at the crime police administration.

24        Q.   Was one of those persons a Brane Buhovac?

25        A.   Do you mean was one of those persons Brane Buhovac?

Page 23489

 1        Q.   Yes.  Yes, that's what I mean.  Was he one of those persons in

 2     CSB Sarajevo that was better for the job than people that worked for you?

 3        A.   Brane Buhovac was an employee of the Banja Luka CSB.  I didn't

 4     know the gentleman at the time.

 5        Q.   Okay.  I understood your answer to be that, in your opinion, the

 6     Banja Luka centre had better men at its disposal to work on this case.

 7     And my question was:  Is Brane Buhovac one of those better men at the CSB

 8     that you were referring to?

 9        A.   I didn't know Mr. Buhovac; therefore, I can't say.

10        Q.   Okay.  How about Milivoje Pavicic?  Was he one of the Banja Luka

11     guys you were referring to that was better than your guys to work on this

12     case?

13        A.   Let me remind you:  The men who, at the beginning, constituted

14     the crime police administration did not include anyone from the forensic

15     centre in Sarajevo.  Or, indeed, at the any of the lower levels.  The

16     names that you mentioned are names I know from later periods when we

17     started to establish a forensic centre over in Banja Luka.

18        Q.   Okay.  I understand now.

19             Could I show you tab 129.  This is Exhibit 2D35.  And, Mr. Macar,

20     with the usher's help, I will hand you a hard copy of this.  Well, maybe

21     I won't.  I don't seem to have the hard copy.

22             So if you could look at the screen, it's dated the

23     8th of September, 1992, from Stojan Zupljanin, chief of the CSB, to the

24     public prosecutor's office in Banja Luka.

25             Have you ever seen this document before?

Page 23490

 1        A.   I don't remember directly that I held in my hand and read it.  I

 2     think the gentleman who was in -- the boss of the crime service,

 3     Mr. Tegeltija, reported on the case file and there was probably the

 4     criminal report too.  Sometime in March 1993.  I can't remember the exact

 5     date but it was during that trimester.

 6        Q.   In terms of internal MUP procedure, would you and your

 7     administration in headquarters be advised or receive a copy of a criminal

 8     report like this?

 9        A.   After arriving in Bijeljina and setting up the ministry HQ, once

10     the visits began to the centres and stations, and once the technical

11     conditions were created in Bijeljina for communication, in technical

12     terms, and then it started in earnest in 1993 informing by way of

13     dispatches about the event.

14             As for the MUP, the administration at the HQ, as of 1993 on, I

15     can't be specific about the date when this system of reporting got off

16     the ground, it was then that we started reporting cases and any criminal

17     reports that were filed.  But those were never forwarded to the Ministry

18     of the Interior, not until 1992 or, indeed, after that date.

19        Q.   I'll -- let me show you another document, then.  This is P800.

20     It's tab 126.  If the usher could assist.

21             This is dated the 22nd of September, 1992, from the department

22     chief, Zoran Josic in the crime prevention and detection department in

23     Banja Luka.  Did you know him?

24        A.   I think he was the boss of the crime service, the Banja Luka SJB

25     department.

Page 23491

 1        Q.   And this is entitled "Reminder about the provisions on

 2     instruction of -- on urgent reporting."  And according to that

 3     instruction, it says:

 4             "It is obligatory for public security stations to submit urgent

 5     reports to the ministry ... and to the CSB on important security-related

 6     events and occurrences."

 7             And then farther down you will see at the top of the list the

 8     kinds that must be reported is murder and attempted murder, Article 36.

 9             So at least according to this instruction, in -- in the SJB in

10     Sarajevo, this is the kind of thing that should be reported up to the CSB

11     and the MUP; right?

12        A.   One of the tasks.  So up until 1992, there was the instruction on

13     urgent, current, and occasional reporting in the bodies of the Ministry

14     of the Interior.  But I pointed out on numerous occasions what the

15     problems were because of shortage of technology and equipment in the

16     stations, centres, and even the ministry itself, so that the instruction

17     could never become operational until the basic conditions were in place,

18     which was in October 1992.  Not just at the ministry HQ but also on the

19     ground.

20        Q.   Let me --

21        A.   As I have explained already, if I may just finish.

22             As I've explained already, working by courier is something that

23     perhaps saved my life.  Regrettably, though, in Doboj, sometime in

24     July 1992, we wanted to have better communication and we dispatched a

25     single engineer who was killed on the way.

Page 23492

 1        Q.   Please stop.  In September of 1992, the communications between

 2     Banja Luka CSB and the headquarters and Banja Luka CSB and Banja Luka SJB

 3     were fully functional, weren't they?  The corridor had been opened at the

 4     end of June or beginning of July.

 5             But my question wasn't about the technical problems.  My question

 6     was whether this instruction was such that this kind of thing should have

 7     been reported up to MUP headquarters in September 1992.  Would you agree

 8     or not?

 9        A.   An instruction that couldn't be implemented for a single period,

10     although we had it until 1992, and then we more or less copied it and had

11     this new one after 1992, could not be implemented in practice, just as

12     many other things.

13        Q.   Stop, please.  It could have been implemented by a courier even

14     if the other means of communication weren't working; right?  It could

15     have been.  Just yes or no.

16        A.   I know that the Sarajevo centre --

17        Q.   Please.  Please, Mr. Macar --

18        A.   -- used a courier service a lot --

19        Q.   -- I'm really giving up hope on finishing with you today if you

20     can't answer a question yes or no.  Please.

21        A.   There were war-time conditions, and I really cannot comment

22     whether a courier service could be set up over a distance of

23     300 kilometres.

24        Q.   Okay.

25        A.   Maybe if I were to see a document.

Page 23493

 1        Q.   Are you saying Mr. Stanisic's dispatch that we just looked at

 2     telling Mr. Zupljanin to investigate this case, are you saying that

 3     didn't get communicated, that didn't get through?  That's not what you're

 4     claiming, is it?

 5        A.   No, that isn't what I wanted to say.

 6        Q.   Okay.  Let me ask you about Exhibit P1567.  This is tab 118.

 7     This is a very thick document.  I want to go to English page 52, and

 8     B/C/S page 43.

 9             Now, Mr. Buhovac, you know, was a forensic guy in Banja Luka CSB

10     in 1992; right?  You know that.

11        A.   Could I get the document?

12        Q.   It's on the screen.  But, first, can you answer my question:  You

13     know that Mr. Buhovac was a forensic worker at Banja Luka CSB?

14        A.   I don't remember his exact position.  I tend to think that he was

15     a chief of the forensic section.

16        Q.   Have you ever seen this document before?  It's an Official Note

17     taken of Mr. Buhovac in October 1999 about the investigation in

18     connection with Koricanske Stijene.

19        A.   I haven't seen this document before.

20        Q.   Okay.  And no one ever told you before that at one point in time,

21     specifically 1999, Mr. Buhovac had made a claim which he later withdrew,

22     you should know.  But in 1999, in this Official Note, he said:

23             "As for the videotape of the scene ..."

24             This is on the last page, if we could go to page 44 in the B/C/S.

25     Page 56 in e-court in the English, at the last -- last page, right before

Page 23494

 1     he says, "This is all I have to say."  He says:

 2             "As for the videotape of the scene, I can tell you it has been

 3     erased using a VCR on the order of the UKP chief, Goran Macar."

 4             MR. ZECEVIC:  I'm sorry, can you -- I can't find what you are

 5     reading from in the document which is P1567.  1567 is a set of documents

 6     concerning the Koricanske Stijene.

 7             MR. HANNIS:  Yes.  And I'm looking at that in e-court, page 43 of

 8     a 60-some page document in e-court.  And English starts at page 52 of a

 9     longer document.

10             Am I incorrect?

11             MR. ZECEVIC:  No.  But I don't see it -- I don't see it on the --

12             MR. HANNIS:  Should be on the screen in both English and B/C/S at

13     the correct page now.

14             MR. ZECEVIC:  I'll check it out.  Thank you very much.

15             MR. HANNIS:

16        Q.   No one ever told you about that claim by Mr. Buhovac?  Never

17     heard about it until just now?

18        A.   No, not before you told me about it.  But what I can say before

19     looking at the document is that this is a blatant lie and I cannot

20     believe that Mr. Buhovac stated anything like that.  I would really like

21     to see the document to see the context.

22        Q.   That's all he says, what you see on the screen right there.

23     That's the only context.

24             But I will tell you that later, years later, in July of 2003, in

25     a witness statement to the -- to our office, to the Prosecutor's office,

Page 23495

 1     he said:  "The sentence that says that Goran Macar" -- I'm reading from

 2     page 6 of the witness statement of 27 July 2003 from Mr. Buhovac, which

 3     may be part of his 92 quater, I believe, but I don't have that exhibit

 4     number.

 5             The sentence that states -- paragraph 16:

 6             "The sentence that states that Goran Macar ordered me to erase

 7     this tape is incorrect.  I never had a conversation with him about this

 8     tape.  I actually called Goran Macar and told him that I did not have the

 9     means to safe-guard the tape and that someone might steal it.  Since the

10     original tape was in the possession of the inspector, I did not want to

11     have the responsibility of having the second tape in my possession.  I

12     decided to erase this tape and I think Pavicic is the one that actually

13     erased the tape, and I think there is some sort of record about that."

14             You never heard about this either, I take it.  Since you didn't

15     hear about the original claim that you had something to do with it, so I

16     assume you never heard about Mr. Buhovac withdrawing that claim; right?

17        A.   I state with full responsibility that what you have just said and

18     what this Official Note says -- and it's interesting that there is no

19     material for me to see.  Some officials made a note, and it says:

20             "As for the videotape of the scene, I can tell that you it has

21     been erased using a VCR on the order of the UKP chief, Goran Macar."

22             And that's all.

23             Now the question is -- I can't believe that Mr. Buhovac really

24     stated that.  But it's interesting that none of these officials was

25     interested enough to ask any questions, what, when, where, how.  Because

Page 23496

 1     this allegation isn't anything that you should take lightly without

 2     additional verification.

 3             So I needn't continue.  But I can't believe that Mr. Buhovac

 4     could have ever have said that.  I'm certain that this is all wrong.

 5        Q.   You and I agree about asking more questions about that.  I have a

 6     couple of minutes left today.  Did you ever have any conversation with

 7     Mr. Pavicic about a videotape, in relation to Koricanske Stijene; do you

 8     recall?

 9        A.   With Mr. Pavicic.  I think I remember that he was a forensic

10     technician.  I don't think I communicated with him.  Whenever we needed

11     forensic technicians, I communicated with Mr. Buhovac.  And if I happened

12     to meet any of his associates, it must have been at some meeting,

13     possibly in 1994 or so.  And as for the video cassette, I really have

14     nothing to do with that --

15        Q.   Okay.

16        A.   -- and I don't believe that Mr. Buhovac ever really stated that.

17     Because there's no basis for this.

18             MR. HANNIS:  Your Honours, I see it's about time to adjourn for

19     the day.  I think I do need 15 more minutes tomorrow, if I may.  We did

20     have a late start today and ...

21             JUDGE HALL:  I remind everyone that we reconvene at

22     9.30 tomorrow.

23             So we take the adjournment now for the day.

24             MR. HANNIS:  Thank you.

25                           [The witness stands down]

Page 23497

 1                           --- Whereupon the hearing adjourned at 1.45 p.m.,

 2                           to be reconvened on Tuesday, the 19th day of July,

 3                           2011, at 9.30 a.m.