Tribunal Criminal Tribunal for the Former Yugoslavia

Page 24773

 1                           Tuesday, 11 October 2011

 2                           [Open session]

 3                           [The accused entered court]

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

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

 6     everyone in and around the courtroom.

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

 8     Stojan Zupljanin.

 9             JUDGE HALL:  Thank you, Madam Registrar.

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

11     please.

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

13     I'm Tom Hannis, along with Gerard Dobbyn, our Case Manager,

14     Sebastiaan van Hooydonk, and today, one of our interns, Andrew Pattel.

15             MR. CVIJETIC: [Interpretation] Good morning, Your Honours.

16     Slobodan Cvijetic and Ms. Deirdre Montgomery for the Stanisic Defence.

17     And we shall have Mr. Zecevic joining us very shortly.

18             MR. ZECEVIC:  Good morning, Your Honours.  Dragan Krgovic and

19     Miroslav Cuskic appearing for Zupljanin Defence.

20             JUDGE HALL:  Thank you.

21             May the usher please escort the witness back to the stand.

22                           [The witness takes the stand]

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

24     Mr. Krgovic to continue his examination-in-chief, I remind of the solemn

25     declaration you made yesterday.

Page 24774

 1             Yes, Mr. Krgovic.

 2             MR. KRGOVIC: [Interpretation] Thank you, Your Honours.

 3                           WITNESS:  MILOS JANKOVIC [Resumed]

 4                           [Witness answered through interpreter]

 5                           Examination by Mr. Krgovic: [Continued]

 6        Q.   [Interpretation] Good morning, Mr. Jankovic.

 7        A.   Good morning.

 8        Q.   Mr. Jankovic, yesterday we finished the questioning at the time

 9     when I asked for us to adjourn sooner because I noticed that you were

10     having problems.  So if at any point you feel that you might develop --

11     be developing a headache or you feel fatigue, I will ask for a break to

12     be given to you so that you can concentrate on your testimony.

13        A.   Thank you.

14        Q.   Mr. Jankovic, yesterday, when you were looking at the document on

15     the screen, you spoke about the speeches given by Mr. Kadiric and

16     Talundzic in which they proposed the forming of the Prijedor CSB.  Do you

17     recall that?

18        A.   Yes, yes, that's how it was.

19        Q.   After the meeting with Mr. Zupljanin, were Mr. Talundzic and

20     Kadiric involved in any activities with the aim of continuing this

21     process?  Was there any debate about this debate -- about this subject?

22        A.   Since this was a short period, if we're talking about the 9th of

23     April, when Mr. Zupljanin came, and the meeting where the dispatch

24     arrived was the 29th of April, so within the span of those 20 days, there

25     were obviously some processes going on but it was not very easy to notice

Page 24775

 1     that.  The one thing that I observed is something that happened in the

 2     second ten days, from the 20th onwards, and what I noticed was that

 3     whenever I went to Chief Talundzic, Avdo Hebib would come as well.  I

 4     already said that.  He was an assistant minister.  And no assistant

 5     minister used to come as often as he did.

 6             There were also some things that, superficially, if you're not

 7     paying attention enough, seemed insignificant but were rather out of the

 8     ordinary.  What I'm talking about.  I'm talking about a frequent

 9     occurrence in which there -- wealthy entrepreneurs would be coming to the

10     SUP building to see Chief Hasan, but that was not something ordinary.

11     For example, I saw a man who was called Cuko.  He would come in his jeep

12     right in front of the stairs and the entrance to the SUP, which is only

13     allowed to be done by official and police cars.  However, he didn't take

14     any care whatsoever, so he parked his vehicle wherever he wanted.  So all

15     this plethora of minute details speaks something about the situation

16     which was not quite normal.

17        Q.   Mr. Jankovic, just one question more.  Avdo Hebib, what was his

18     ethnicity?

19        A.   Judging by his surname, he was a Muslim.  But, then again, I'm

20     telling you ...

21        Q.   And those people that you described coming to the SUP building in

22     Prijedor and particularly Cuko --

23        A.   Cuko was a Muslim too.  I forgot his surname, but I know where

24     his restaurant was, and I know that he was quite a prominent figure in

25     the catering business.

Page 24776

 1        Q.   And these people whom you described coming to see Chief Talundzic

 2     to the SUP, what was their ethnicity, including Cuko, and the rest of it?

 3        A.   I keep talking about specific examples but maybe I should rather

 4     paint the whole situation to you.

 5             My job required me to go see the chief at least three times a day

 6     to ask him something or seek approval.  So whenever I went to see him,

 7     there would be someone coming into his office, and saying "Merhaba,

 8     Hasan" and he would reply, "Merhaba."  We used to say good morning or

 9     good afternoon.  That was never the way that we greeted each other

10     before.

11             Later on I would say the same to Hasan.  I would say "Merhaba."

12     And then when he came to my office he says, "God help you, hero," which

13     is a Serbian phrase.  And I didn't know what to respond.  So he asked me,

14     "So why are you using the Muslim greeting if you don't know your own?"

15             So that was just an illustration of the whole situation.  All

16     these greeting phrases had never been used before because we were an

17     institution that was serving, that was at the disposal of all the

18     citizens, and we should have stuck to the normal greeting in our tongue,

19     which is good morning or good afternoon.

20        Q.   Let us go back to the meeting of the 29th April 1992.

21             Can you tell us briefly what preceded the meeting, when did you

22     find out about the meeting, and how did it happen?

23        A.   You're referring to the one on the 29th of April, are you?

24        Q.   Yes.

25        A.   All right.  Briefly.  This whole period in 1992 was divided into

Page 24777

 1     stages.  The first stage was up to the multi-party elections.  Second

 2     stage was between the multi-party elections and the 29th of April.  And

 3     that's the one I'm going to talk about, although I told you everything

 4     about it already.  And then we have a third stage, which occurred after

 5     the meeting of the 29th of April, and it lasted until the 30th of May,

 6     when an attack on Prijedor took place.  So I'm talking about this third

 7     phase, in fact.

 8             Whatever I've been telling you this morning, and if you look at

 9     the whole picture, one could see that tensions were rising.  And whoever

10     was there on the spot and was able to listen to things, it was very easy

11     to establish a connection between the meeting on the 9th, when

12     Mr. Zupljanin was there, and when Fikret spoke about reorganisation and

13     the separation and the creation of a new centre in Prijedor, and as a

14     result of all of this, we are having this meeting of the 29th of April.

15             I hadn't had any previous knowledge about this meeting being

16     planned because I was somewhere out in the field doing my job relating to

17     communications system.  And when I came back, at around 1400 hours, all

18     authorised officials including communications officers, which means the

19     entire active and reserve police force, were invited, including the

20     criminal investigation police, to assemble in a hall for a meeting.  And

21     that's all that was said.

22             Now, I called my fellow communications officer.  We went down.

23     We just left one officer on duty because the -- one must never leave the

24     centre -- communications centre unattended.

25             So the meeting started, and I saw that the chair of the meeting

Page 24778

 1     was actually composed of five persons.  They were sitting at a table, or

 2     maybe two tables, from left to right.  The first one was Mirza Mujagic,

 3     who was at the time the president of the SDA.  So from left to right.

 4     Next to him was sitting Cehajic.  I don't know what his first name was.

 5     Either Muhamed or Muharem.  Anyway, it begins with an M.  He was the

 6     president of the municipality.  In the middle was sitting the

 7     chairperson, so to say, Hasan Talundzic, the chief of the police station.

 8     And next to him, Fikret Kadiric was sitting, an associate of his, and I

 9     think that, at the time, he was the commander of the traffic police.  And

10     the fifth one viewing from left to right was Simo Miskovic.  He wasn't

11     working at the police at the time.  He was a retired police officer, but

12     as far as I know, at that point, he was the president of the SDS.  I

13     cannot be positive about that.  I think that he was the president of the

14     SDS, but I wasn't a member.  I think he was the president.

15             So let me continue.

16        Q.   I'm sorry, can you just tell me, where was this meeting held?

17        A.   The venue was the hall that was within our station.  It was not

18     in the main building, actually, but across the yard there was this hall

19     and there was some garages.  And this hall was normally used for the

20     meetings of police employees.  However, this hall, on this occasion, was

21     too small to accommodate all the people who gathered there.  I don't know

22     how many of them, but it was packed.  People were even standing outside

23     in front of the door.  There are some pillars, just like in this room,

24     and I was standing and leaning on one of those pillars, about 5 metres

25     from the chair.

Page 24779

 1             The meeting eventually started, and there was only one item on

 2     the agenda.  The chairs addressed those in attendance and raised various

 3     reasons, based on which we, that is to say, the Prijedor police station,

 4     should cease to belong to the Banja Luka centre and join the Sarajevo

 5     centre.  At that point, we were already owed two salaries, and these two

 6     salaries that were in arrears were presented by them as the main reason.

 7     They said that we would be paid one of these salaries on the following

 8     day, and the next, several days later.  All the explanations they

 9     provided went along that line, and all those present seemed to be happy

10     with them.  They were maybe only two or three of them who raised their

11     voice and I think they were Serbs.  I knew Milivoje Mutic, for instance,

12     one of them, whereas the others I didn't know them because they were on

13     the reserve force.  They spoke against the proposal; the rest were

14     silent.  Or those who did take the floor said that they were in agreement

15     with what was stated because we would refuse to go on working without

16     being paid.

17             The meeting lasted perhaps 45 minutes, an hour, I'm not sure.  At

18     any rate, everything was over quite soon.

19        Q.   My apologies.  Did Mr. Miskovic speak at the meeting at all?

20        A.   No.  He was present there, but he didn't speak.  He may have said

21     something, very little, and of such insignificance that I didn't remember

22     it.

23        Q.   And who was it who set out this proposal that the Prijedor police

24     station should be connected directly to the Sarajevo centre?

25        A.   Well, it was the chief of the station, Hasan Talundzic, who was

Page 24780

 1     the chair, and seated in the middle of the room.  But, likewise,

 2     Mr. Talundzic and the president of -- Mr. -- the president of the

 3     municipality, him -- also took the floor and others who provided

 4     explanations.

 5             Now, who said what at that point, I really don't remember.

 6             Anyway, the general idea that was expressed at the meeting was

 7     what I just related to you.  Only that.

 8        Q.   Go ahead, Mr. Jankovic.  Did anything happen during the meeting

 9     which --

10        A.   Yes, yes.  At that point, the entire police station was empty.

11     There was only a duty policeman at the front door, and there was only the

12     duty communications officer in the communications centre, the one that I

13     was superior to.  And at one point, the communications officer sent word

14     to me through the duty officer at the front door that I should show up

15     there because they were having some problems with communication devices,

16     because we didn't have a phone in the conference room so he wasn't able

17     to call me there.

18             So I went up there.  He told me it was urgent.  I left the

19     meeting, which went on.  There was Dusko Sarac there.  He was the

20     communications duty officer.  He showed me a dispatch that he had

21     received from Sarajevo.  It had been coded.  The dispatch bore an address

22     and it required him to send it on to the municipalities that were linked

23     with us, i.e., Sanski Most, Bosanski Novi, and Bosanska Dubica.  However,

24     he was unable to, because the Banja Luka communications officer refused

25     to connect him to the various stations that he needed.  So he applied to

Page 24781

 1     me, asking what was -- what he was supposed to do.

 2             In general, whenever communications officers had problems with a

 3     dispatch, they consulted me for a decision rather than inadvertently make

 4     an erroneous move.  I would then cast a glance at the dispatch to gauge

 5     its importance and decide on my next steps.  At times, a dispatch can

 6     wait; at others, it can't.  Normally such dispatches would have their

 7     designation of urgency at the top.  This one read:  Very urgent.  In our

 8     police standard procedure, this was the top of the scale of urgency and

 9     it had normally only to do with matters of state significance.  As a

10     rule, such dispatches had to be sent to the head office of an

11     organisational unit, i.e., the chief of the station, as a matter of

12     utmost urgency.  If he wasn't there, then the dispatch would have to be

13     sent to his deputy with the deputy being obliged to find the chief as

14     soon as may be, in order to convey to him the contents of the dispatch.

15     And, as I said --

16             JUDGE HARHOFF:  Mr. Jankovic, were you able to read the contents

17     of the dispatch?

18             THE WITNESS: [Interpretation] Yes.

19             JUDGE HARHOFF:  And what was it about?

20             THE WITNESS: [Interpretation] As I said, even before, whatever

21     the contents of the dispatch, where I saw that it was impossible to apply

22     the standard procedure, I would decide on what measures are to be taken

23     on the basis of the contents of the dispatch.  So I cast a cursory glance

24     at this dispatch and saw that it had been issued by the minister,

25     pursuant to the decision of the Presidency.  Well, I can't really list

Page 24782

 1     all the various items one, two, three, but I could tell that it had to do

 2     with the mobilisation of the police and Territorial Defence, that it had

 3     to do with the need to cordon off all the strategic roads, vital

 4     institutions, barracks, with the need to disarm the army in the barracks,

 5     and it said that wherever opposition was met, one should engage in

 6     combat.

 7             To my mind, it was a shock.  I had been working for the police

 8     force for quite a long time by then, and I had occasion to see a variety

 9     of contents but none of them produced such a shock as this one.

10             My understanding of it was that it marked the beginning of a war.

11             MR. KRGOVIC: [Interpretation]

12        Q.   A moment, please.  Can I show you a document at this point.

13             MR. KRGOVIC: [Interpretation] Can the witness please be shown

14     Exhibit 1D00150.  In the Zupljanin Defence binder, it's behind tab 9.

15             Can I have the usher's assistance.

16             THE WITNESS: [Interpretation] I'd like to apologise and kindly

17     ask you something.

18             I made a mistake of leaving my jacket in that room outside the

19     door here where my reading glasses are, and I think the lady saw me leave

20     the jacket.  If she could go and get it, or I should perhaps, because I

21     don't have prescription on these glasses.  I left my jacket on the door,

22     and it's got my reading glasses in.

23             MR. KRGOVIC: [Interpretation] Mr. Jankovic, we'll wait for you to

24     get your glasses then.

25             MR. HANNIS:  While this document is coming up, Your Honour, I

Page 24783

 1     need to bring to your attention something that I raised before.

 2             The English translation of this document has something in the

 3     upper right-hand corner that was a handwritten notation which does not

 4     appear on the B/C/S version of this document that's in e-court.  I

 5     brought this to the attention of the Defence previously, and I believe we

 6     marked it as an additional number.  I believe we marked this as 150.1.

 7     So for that to be consistent, I think we should bring that version up.

 8                           [Trial Chamber and Legal Officer confer]

 9                           [Trial Chamber and Registrar confer]

10             MR. KRGOVIC: [Interpretation] I agree.

11             JUDGE DELVOIE:  I think in the English version, we would be

12     better off with - what is it again? - 1D150.1.

13                           [Trial Chamber and Registrar confer]

14             THE INTERPRETER:  Microphone, please.

15             THE WITNESS: [Interpretation] This dispatch isn't it accurate.

16     It isn't the right one.

17             MR. KRGOVIC: [Interpretation]

18        Q.   Behind 9.

19        A.   No.  Because it doesn't say "very urgent," whereas the original

20     did.  In the upper right-hand corner, we don't have that designation.

21             MR. KRGOVIC: [Interpretation] Perhaps we should show the third

22     document in the binder in e-court.  That's the document referred to by

23     Mr. Hannis.

24        Q.   Do you see it now?  It does say "very urgent" up there.

25        A.   Yes.  It's a poor copy, admittedly, but it does look like the

Page 24784

 1     original.  It does have the heading, although can you barely make it out.

 2        Q.   Mr. Jankovic, is this the dispatch that you --

 3        A.   Yes, yes.  What, with all the blurs and blots, I would say that

 4     it is.  No, actually.  Is this the one?  No, please, find it somewhere.

 5     I did see it.  You had it.

 6        Q.   Mr. Jankovic, I'm sorry, let me explain.

 7             There are various copies of the document.  I showed you a copy

 8     which has already been admitted into evidence, and this is another copy,

 9     different from the one you saw, but it does contain all the elements you

10     refer to like "very urgent"?

11        A.   Well, I'm not aware of any copies.  I only know of the document

12     that I had in my hands, and I can tell that it says "very urgent" here.

13     And it is not insignificant, let me tell you.  Under our rules governing

14     communication, dispatches are classified according to the varying degrees

15     of urgency.  O stands for regular; that's the lowest on the scale.  Then

16     you have D.  Next on the scale, DD.  Still next, DX.  It only reads X

17     here.

18        Q.   Why don't you look at the top, at the heading?  What does it say?

19        A.   And the topmost is "very urgent."

20        Q.   Do you see that it reads "very urgent" at the top there?

21        A.   Well, it does, but it is a very poor copy.

22        Q.   Please look at the copy that you have on your monitor.

23        A.   Yes, I can see that the handwriting belongs to the chief's

24     secretary.  I recognise her handwriting.  And, yes, it does say "very

25     urgent" just as it did at the time.

Page 24785

 1        Q.   Please look at the contents of the dispatch.

 2        A.   Well, it's going to be quite hard, but I do remember the

 3     important bits.  Fine, well, we have the addressees up there, though this

 4     is also important.  And what it should read, among others, is:  To SJB,

 5     to all, to the chief.  And the -- this is what I can try and make out.

 6     So to all the chiefs of all the stations.  And I suppose to the police in

 7     Sarajevo, to the secretary.

 8        Q.   Well, here you are.  You have a better copy there, Mr. Jankovic.

 9        A.   This one?

10        Q.   Yes.

11        A.   Well, it's so good that ... this is like the hieroglyphs.  I'm

12     really afraid that I'm going to make a mistake there.  I don't remember

13     particularly the heading.  Why would I know?  What I know is what the

14     standard heading was.  Normally there you would have the MUP there, the

15     reference number and the date, and you can tell that there's -- the

16     reference number is the latter part of it, 10-70, and the first few blots

17     up there should be probably the MUP and the date.  And the address.

18     That's also important.  So I suppose it says CJB, public security centre,

19     all, meaning all in Bosnia-Herzegovina.  SJB, all - chief.  So all the

20     municipalities, all the chiefs.  And it used to be called the Sarajevo

21     town SUP and then the secretary.

22             MR. HANNIS:  Your Honours, if I may, for the convenience of the

23     witness, now that we've gotten past the heading, the top part of the

24     document that was not on the other version of the B/C/S, I don't mind if

25     we put up in e-court or let him look from the hard copy that was

Page 24786

 1     originally shown to him which has the text from below "very urgent" on in

 2     a document that is more legible than the one that he is looking at.

 3             I'm satisfied that those texts are identical based on the English

 4     translation and comparing them.  I think it would be easier for him.

 5             MR. KRGOVIC: [Interpretation]

 6        Q.   Mr. Jankovic, could you please, as it is one and the same

 7     document with the identical contents and the Prosecutor and I agree.  I

 8     think it is more legible.  In the document you have, the upper part is

 9     lacking, but please look at the contents.

10        A.   All right.  All right.  It is the same.  "I order," and

11     everything down from there it's all legible to me.  But what is at the

12     top:  "Pursuant to the decision of the Presidency of the Republic of

13     Bosnia-Herzegovina," number so-and-so, "I hereby order ..."

14             So the minister is ordering it pursuant to the decision of the

15     Presidency of Bosnia-Herzegovina.

16        Q.   Can you tell us who signed it?

17        A.   It is signed as we can see on the screen.  I remember that it was

18     so.  It was the then-minister of the interior of Bosnia and Herzegovina,

19     Alija Delimustafic.  You can see it here on the screen.  And here on

20     paper that I have as well.

21             MR. HANNIS:  Well, can I clarify?  We don't have a signature on

22     the screen.  We have typed letters.  Unless he's seeing something that

23     I'm not.

24             MR. KRGOVIC: [Interpretation] No, no, it's not visible.  He just

25     said signature.

Page 24787

 1             THE WITNESS: [Interpretation] Please let me explain this, if you

 2     will.

 3             MR. KRGOVIC: [Interpretation]

 4        Q.   Please do.

 5        A.   The dispatches as a form of conveying information have, among

 6     others, the characteristic that a signature which is typed out like this

 7     has the weight of a real sign, a real signature and stamp because all the

 8     officers who work on encryption and encryption data protection were

 9     authorised officials just like any other authorised officials.  We were

10     not authorised as the police in order to bring people in and question

11     them, but we had the responsibility for what we did.  Therefore, if we

12     made a mistake, I think that the penal code of the Socialist Federal

13     Republic of Yugoslavia had Article 220, which envisaged a prison sentence

14     between ten or even 15 years.

15             So there had to be the words that it was signed by the minister

16     and whoever received such a document or a dispatch as this one would know

17     what I just told you.  And for him, if an employee brought a dispatch as

18     it is, would be the same as if the minister had signed it in front of

19     him.

20             I hope I made myself clear.

21        Q.   Yes, you did.  Mr. Jankovic, please have a look at the contents

22     of the dispatch and tell me whether it is the contents which you saw on

23     the 29th of April, 1992?

24        A.   Yes.  Well, I cannot remember as precisely as that verbatim what

25     stood there, but generally as I remember the document and its contents, I

Page 24788

 1     would say that what I read up here, it's all correct.  If I should read

 2     it, I will read all the rest.

 3        Q.   No.  Please read it for yourself silently and just confirm for me

 4     whether the contents is the same in this dispatch.

 5        A.   Block all the roads in Bosnia-Herzegovina.  The units of JNA are

 6     pulling out materiel and equipment.  This is to be completely blocked in

 7     direct coordination with the Ministry of Interior.  Larger areas with

 8     military.  I guess this word should be military installations but there

 9     is a typing error.  From which they are trying to pull out materiel and

10     equipment are to be blocked by using various manmade and natural

11     obstacles.  Yes, that's correct.  That's the contents.

12             Unannounced convoys of former JNA units and convoys without MUP

13     escorts shall not be allowed to leave the barracks.  That was what I

14     termed block off the army.  Prepare and begin combat operations.  That's

15     what meant that it was war for me.  In the entire territory of

16     Bosnia-Herzegovina coordinate this with Territorial Defence Staffs in

17     regions, districts and the Republic of Bosnia-Herzegovina as part of the

18     plans for combat operations.  Plan widespread measures to protect the

19     population.  Yes, right.  As far as I remember it was so.  Perhaps there

20     could be some minor details that are different, but it was like this.

21        Q.   Mr. Jankovic, can you please have a look at the lower left-hand

22     corner, the initials which are there.  Can you see that?

23        A.   Yes.  It's not easy to see but I know what it is.  It says:

24     DZZM.  DZZ is actually the letter Dz from B/C/S in teleprinters, because

25     DZ stands for the letter Dz because the machines do not have the

Page 24789

 1     diacritical signs above some of the letters so that the letter zh would

 2     be written as double ZZ.  And the M, these are the initials of the

 3     communications officer who sent this from Sarajevo and I know who it was.

 4     His name was Mirsad Dzanko.  This is why you have Dz M, for Dzanko,

 5     Mirsad.  The communications officers, once they sent the dispatch, would

 6     include their own initials so that their colleague, if there was a need

 7     to make an addition or to correct something, he would know who to call.

 8     From Prijedor he would call Sarajevo, for example --

 9        Q.   Can you please repeat the name of this communications officer,

10     Mr. Jankovic.

11        A.   These are the initials Dz M.  Dz, if you know the letter, and it

12     means Dzanko Mirsad.  I didn't know him personally, but I remember all

13     the names, including Mirsad Dzanko, from my work.  I know him by name,

14     but I didn't know him by sight.

15             MR. HANNIS:  Could I ask counsel to clarify the spelling of that

16     last name.

17             MR. KRGOVIC:  I was trying.

18        Q.   [Interpretation] Can you please spell letter by letter the first

19     and last name of this person?  Please do it slowly.

20        A.   All right.  First of all, if you don't have the voice and letter

21     Dz in your language, it's Dz like for dzamija, which is a mosque.

22        Q.   Please no comments.  Just spell it out.

23        A.   D-z-a-n-k-o, which reads Dzanko; M-i-r-s-a-d, which stands for

24     Mirsad.

25        Q.   Thank you, Mr. Jankovic.

Page 24790

 1             Can you please tell us, once you read the dispatch, what did you

 2     do after that?

 3        A.   Excuse me, it stands here Dzanko so perhaps you could use the

 4     same rule on our machines.  DZZ so that it would then read Dzanko, but as

 5     you like.  Can you now please repeat the question.  I'm sorry.

 6        Q.   When you read the text of this dispatch, what did you do after

 7     that?

 8        A.   Well, first of all, I said that I was shocked, but my work taught

 9     me not to do my job in accordance with shock but according to the rules

10     of service.  So knowing that this should be submitted to the chief of the

11     station urgently, and I also knew that the chief was down at the meeting,

12     and I needed to go down there again anyway, it was not my duty to do

13     that.  The communications officer who received the telegram would take

14     the book, that was the rule.  The book with telegrams.  He would then

15     note the receipt of the telegram in the book.  He would take it, together

16     with the telegram, to the person to whom it needed to it be handed.  He

17     would hand it over.  The chief would sign in the book that he received it

18     and the communications officer would bring back the book, so that was the

19     proof that he handed the dispatch.

20             So as the chief, I was not in charge of such duties but

21     considering the urgency and that I had to go downstairs anyway and that

22     the communications officers couldn't leave his room because he was alone

23     there, I took the book, together with the dispatch.  I went downstairs to

24     the meeting and other communications officers whose superior I was were

25     sitting together in one row.  They were all equal among themselves.  I

Page 24791

 1     addressed the first one who was the closest to me.  It was Mirsad Sakulic

 2     [phoen].  It happened to be him.  It was the person I talked about

 3     yesterday.  I gave him the book, together with the dispatch, and I told

 4     him, Please, enter this dispatch and give it to the chief.  And he did

 5     that.

 6             The course of the meeting was such that the meeting was already

 7     nearing the end.  One could see that they had reached an agreement about

 8     what was proposed.  That was accepted, as far as I could see, though I

 9     did not attend the second half of the meeting.  And I then asked to speak

10     for the first time in that meeting.

11             I said that what they were promising, namely, that we would

12     receive two salaries, was not correct.  I said, Gentlemen, you're doing

13     one thing and something else is happening.  You're saying something and

14     something else is going on.  You are doing something else.  I don't know

15     exactly how I worded but I know that that was the thrust of my words.

16     Those who should give us the money ordered us to go into war.  And they

17     asked me, How come you're saying that?  And I said, Well, that's what it

18     says here in this telegram.  And then those present shouted, Read it out,

19     read it out, because the chief already had the telegram in his hands.

20     And then those who were present, the president of the municipality, the

21     president of the SDA, Hasan and so on, they all came close together and

22     they read it out in whispers.  It lasted for perhaps four or five

23     minutes.  And other people were heckling and shouting, Read it out.  Both

24     Serbs and Muslims, as far as I could see.  I didn't sort them and try to

25     distinguish them from one another, but that's what I could see.

Page 24792

 1             And then after the consultations, the chairman decided that it

 2     should be read out and he gave it to Radovan Makecan [as interpreted],

 3     who was sitting there and keeping the minutes.  Radovan Kecan.

 4             Excuse me, I'm very fast.  And it has not been typed out.  It is

 5     not Radovan Makecan, but Kecan.  Right, that's it.

 6             He read it out, this dispatch, out loud.  And all those present

 7     rose to their feet.  There was disturbance.  They were shouting at one

 8     and the same time.  I just remember that the president of the

 9     municipality, Cehajic, was saying, It is a lie, it's an insinuation, it's

10     not true.  I'm leaving this meeting in protest.

11             Dr. Mujagic, who was the president of the SDA, did the contrary.

12     He was saying, People, sit down, let us reach agreement.  It's not quite

13     like this, and so on and so forth.  However, there was no meeting

14     anymore.  Everyone got up and left.

15             Should I add anything?

16        Q.   Mr. Jankovic, now that we're talking about the dispatch, where

17     was the dispatch left?

18        A.   Hasan held it in his hand.  It was addressed to him and given to

19     him.  Whether he took it with himself or not, I wouldn't know that.  I

20     don't remember what happened with it later.  However --

21        Q.   Did you ever have a chance, later on, to make another copy of it?

22        A.   I'll tell you now.  It's the first time I see this.  Here, on the

23     dispatch I see on the screen before me there is something written in hand

24     and it's the handwriting of Mira Topic, who was Hasan's secretary.  And

25     she was the one who would enter the dispatches in the book, so this seems

Page 24793

 1     to be a copy of that dispatch.  But I don't know.  Perhaps it is or

 2     perhaps not.  I don't know.  Maybe.

 3        Q.   Please tell me whether, after there was a takeover of power, you

 4     had a chance to make another copy of the dispatch?

 5        A.   Yes.  Perhaps two days after the takeover, maybe not on the very

 6     next day, I wouldn't know exactly, so perhaps after two days,

 7     Simo Drljaca called me to come downstairs, down to his office.  I was on

 8     the upper floor.  I came there, and there were one or two men sitting

 9     there.  I don't remember anymore.  And it's not important.  He told me,

10     These are the local journalists from the local newspaper

11     "Kozarski Vjesnik."  They want to write about this.  Do you have that

12     dispatch?  I said, Chief, I personally have nothing, but I know that the

13     communications officers, after the procedure of receipt, they had the

14     yellow ribbons from teleprinter.  They threw everything in a bag.  I'm

15     explaining that to you.  I wasn't explaining that to him.  They would put

16     everything in a bag and later on they would burn it all, two or three

17     days later, once the bag was full.

18             So if I told them if they didn't burn it, then we might find it.

19     I went down to the communications centre.  I issued a duty to the present

20     employees to try and find it and they did find it, the yellow ribbon,

21     that was the trace from the dispatch.  It hadn't been burned.  So it

22     could have been three days later.  Because after that, the ribbon

23     wouldn't have survived.  It would have been thrown into the fire.

24             The employees made a copy for me.  I took it to Simo and gave it

25     him, and he gave it to those journalists.  I remember that a dispatch

Page 24794

 1     like this one was published in the newspapers.  It was small, though, and

 2     it wasn't really legible, perhaps like this one, but it was printed

 3     there.  And later on I wouldn't know what happened because I didn't

 4     follow it anymore.

 5        Q.   Mr. Jankovic, what happened after the meeting ended?

 6        A.   It was already after the end of business hours.  It might have

 7     been 3.30 p.m., or maybe 3.00 p.m.  As I said, people dispersed.

 8     Everybody went their own way.  I went home.  I spent time with my family

 9     because I didn't have anything particular to do.  And then in the

10     evening, although it was still daylight, but the sun was setting, my duty

11     communications officer called me.

12             By the way, whenever I was needed on an official business, they

13     would never contact me directly.  They would do that through the duty

14     communications officer and he would locate me, and then I would call him

15     back.  Because that was the standard procedure to locate me because this

16     duty communications officer was available 24 hours.

17             Anyway, he found me and asked me to come over to the station.  I

18     went to the station, and I saw that there weren't many members of our

19     service present.  We were told that everybody should go to Cirkin Polje

20     local commune, which is some 3 or 4 kilometres away from the entry point

21     into the town.  We were told that everybody must be there, including the

22     police force, et cetera.

23             I went there, but, of course, I left two of my workers behind in

24     order to attend the centre and everybody else, including myself, went to

25     Cirkin Polje.

Page 24795

 1        Q.   Yes, please.

 2        A.   As soon as I arrived there, I can tell you that I saw quite a few

 3     people assembled there and amongst them were people looking in a variety

 4     of ways.  People were dressed in old JNA uniforms, new JNA uniforms,

 5     camouflage uniforms, blue reserve police uniforms, proper police

 6     uniforms, et cetera.  I knew some people from the regular police;

 7     whereas, I would say that 99 per cent of them I didn't know at all.  And

 8     there was a total of them of approximately 150.  They surrounded this

 9     building because, actually, this local commune was a pre-fabricated

10     building.

11             I entered the building.  I found all the bosses and the

12     commanders with whom I normally was in touch on a permanent basis in my

13     line of work, and at around 8.00, when it was already dark, there comes a

14     man whom I hadn't ever seen before.  I heard of him, but I didn't know

15     how he looked like.  I didn't care.  And he introduced himself by saying,

16     My name is Simo Drljaca.  He was in a military camouflage uniform, not

17     the blue one, and he didn't have any cap on his head or any insignia.  He

18     said, I had been sent by the SDS, and from now on, I'm going to be the

19     chief of station.

20             All the executives from the police station were sitting there,

21     minus the Muslims.  But all the rest were there.  Quite briefly, and

22     without going into details, I saw that they were drawing up a plan, and

23     the result was that they formed five groups made up of those people

24     present, which approximately corresponded to two squads of 20 people

25     each.  I didn't go out to count the people, but, as far as I can

Page 24796

 1     remember, there were five groups of 20 men each, and each group was

 2     tasked of seizing all the vital facilities in the town, and amongst them

 3     definitely were the municipal building, the police building, the post

 4     office, the bank, and I think the court-house.  I'm sure about the first

 5     two ones.  Yes, there was a bank as well.  The court-house and the post

 6     office.  That's how it was.

 7             All of that was agreed.  They went out, and then Simo asked me,

 8     Who are you?  And I said, I'm a communications officer.  What are you

 9     doing?  I said, Nothing.  He said, If that is the case, he gave me a

10     piece of cardboard and it says "Official ID" on it.  And he told me to

11     write any name I wanted.  I first wrote the name of Simo Drljaca.  But

12     people came to me.  Because I didn't know them, they had to tell me their

13     names.

14             At 4.00 in the morning, they left because this whole procedure

15     was lasting that long.  Since it was dark, I couldn't see what was going

16     on, and I wasn't interested anyway.  There was no noise, there was no

17     shouting.  Everything was normal.

18             After they left, at around 7.00, we were asked to go there.

19     There was not a single bullet fired.  We didn't hear anything to that

20     effect.  There were no signs of violence.  At least as far as I was able

21     to observe.  I only heard from my communications officers who remained on

22     duty, as well as the police who were on duty, that they were taken out of

23     the building, and they were told that now the police of Republika Srpska,

24     or, rather, the Serbian Republic of Bosnia-Herzegovina, as it was called

25     at that time, was taking over.  They gave them some kind of ledgers or

Page 24797

 1     lists or whatever.  Anyway, they were asked to sign the pledge of oath to

 2     the police that we used to do before anyway.  And the people from my

 3     department didn't do that.  They just went back to their offices and

 4     continued their work.

 5             But since that was happening at 7.00 in the morning, people were

 6     coming to work to the police, and whoever wanted to sign, they signed,

 7     and who didn't, they didn't.  Those who signed proceeded to their

 8     workplace and continued to work as usual.  Those who didn't sign was

 9     obliged to return -- turn in their official badge and their fire-arm.

10             There were Muslims as well who signed this oath.  I don't know

11     how many.  But I'm sure about a man called Enes, a Muslim, who worked in

12     the same office with my wife.  And there were a number of them as well,

13     but I can't give you their names at the moment.  I have forgotten them.

14             As for those who did not want to sign, they were obliged, without

15     any use of force, to return their official badges and their service

16     fire-arms, and they were told that they were free to go, home or wherever

17     they wanted.

18             I didn't see it myself, but I heard from some of my co-workers

19     the Muslims who refused to sign did not go back home on that morning,

20     but, rather, assembled in a small park in front of a self-service

21     restaurant which is about 100 metres from our building, and they were

22     trying to draw up some plans of their own about what to do; but, as far

23     as I know, they didn't make any attempts in that direction.

24             And that is what happened on this first day, which was calm.

25             I know that a young man called Dzapa, I think, was killed that

Page 24798

 1     day.  That was the only casualty.  He was a reserve police officer.  He

 2     left the office and was headed home, and at a cross-roads, which is

 3     called Sacko's cross-roads in Prijedor, everybody knows where it is, and

 4     it's a busy junction, a bullet hit him on that spot.  I don't think it

 5     had ever been established who fired that shot, but, anyway, he was

 6     killed.  He was the first fatality.  There were quite a few after that,

 7     but I remember him.  So he was the first casualty in the aftermath of the

 8     takeover of power, and he was a Serb reserve police officer.

 9        Q.   I forgot to ask you when you spoke about the venue of the meeting

10     held on the 29th of April.  In addition to this hall, within that

11     complex, in addition to the garages, were there any other rooms?

12        A.   Well, it's a high -- it's a -- it's a big facility.  There are

13     many rooms inside, and there was one office there where I sat and I

14     didn't go out.  But since lighting was very bad, quite a few of them were

15     lit only if you had moonlight shedding light on these rooms.  So I was

16     asking myself, How come that I know nothing about it, whereas there were

17     obviously huge preparations made ahead of it?  There was a lot of SNB, or

18     for the benefit of the interpreters that stands for olive-drab colour,

19     and there were quite a few pieces of equipment of that colour which

20     indicated that it belonged to the army.  So there was a large amount of

21     military equipment there, in addition to the camouflage uniforms that the

22     army used and also the old army uniforms.

23             Is that what you in mind?

24        Q.   Yes, that's one thing.  But my second question was:  In the SUP

25     building, in this building, actually, in the yard, was there any other

Page 24799

 1     room?

 2        A.   Well, maybe it's not so important at the moment, but when you

 3     enter this building, the hall is on the left-hand side, and on the

 4     right-hand side is a smaller room that previously was designed and

 5     constructed as a detention room.  People were put in custody there by the

 6     police, and it had to comply with standards.  There were no radiators

 7     allowed, et cetera, so this was a custody room.

 8        Q.   At the public security station, was there any such detention

 9     room?

10        A.   Well, under the law that was in force before the war, every

11     police station had to have such a room but we didn't have it inside the

12     building itself.  We had it in another building, and all the standards

13     had to be complied with in order to prevent suicide of the detainees,

14     et cetera.  And the distance between the main building and that room was

15     about, let's say, 20 metres, 15, 20 metres.

16        Q.   Were there any detention rooms in the cellar?

17        A.   No, no, not in the police building because there is no cellar.

18             JUDGE HARHOFF:  Mr. Jankovic, just in order to get the chronology

19     right, could you remind us when exactly the meeting that was called at

20     Cirkin Polje and the subsequent takeover of the buildings in Prijedor,

21     when did that take place exactly?  On which date; do you recall?

22             THE WITNESS: [Interpretation] Now I'm going to give a more

23     precise and more concise answer.

24             I myself don't know anything about it.  I know that the date was

25     the 29th of April.  As I said, I knew nothing about what was going to

Page 24800

 1     happen.  The first I heard of the meeting was at around 1400 hours or,

 2     let's say, 1445.  The dispatch arrives.  I did what I did, as I explained

 3     to you.  There was some commotion around 1500 hours, or 1515, after which

 4     I went home.  And my house is about 1 kilometre away.  I knew nothing

 5     about what was going on during that afternoon.  As I said, I was spending

 6     time with my family.

 7             In the evening, or, rather, dusk, I would say that it could have

 8     been at around 7.00 or 7.30, that was the time when I was called to come

 9     to the SUP building, which I did, and then I went to Cirkin Polje, which

10     is 3 or 4 kilometres away.  We, from the communications service, took a

11     Golf car.  A driver drove us there, and then he went back so that we

12     wouldn't have to walk over there.

13             Let me tell you that Cirkin Polje is just a suburb of Prijedor.

14     It looks like a village but it's a local commune that belonging to the

15     town of Prijedor.  So we come to this local administration building of

16     this local commune, which was a prefabricated house.  It has a yard that

17     is the size of, let's say, three rooms of this size.  So the sun was

18     setting and, at that time, it was already pitch dark.  I entered and what

19     I explained took place.

20             JUDGE HARHOFF:  Thank you.  I just wanted to be -- to have

21     confirmed that the takeover then, I understand, happened in the early

22     morning hours of the 30th of April; is that correct?

23             THE WITNESS: [Interpretation] Yes.  And we're still on the 29th,

24     mind you.

25             JUDGE HARHOFF:  Thank you.

Page 24801

 1             THE WITNESS: [Interpretation] And, of course, 4.00 in the

 2     morning, that was the 30th.

 3             JUDGE HARHOFF:  Thank you.

 4             MR. KRGOVIC: [Interpretation]

 5        Q.   Mr. Jankovic, tell us, please, after the takeover of power by the

 6     Serbs in the municipality of Prijedor on the 30th of April, in these

 7     early days, before the incidents that took place outside of Prijedor,

 8     were there any armed clashes in and around Prijedor?  And I'm referring

 9     to the period before the 20th of May.

10        A.   Well, I need to recall the events, and the easiest for me to

11     remember was what was happening at the station.  As I said, there was

12     this takeover of power.  There were these first incidents, one of which

13     was the one involving the death of a young man that I referred to.  And

14     the police began rounding up individuals and bringing them in for

15     interviews more and more frequently.  I wasn't privy to that.  I can't

16     tell you anything specific about it because I wasn't involved in it, but

17     I do recall that this practice was on the increase.  I can't even tell

18     you specifically when exactly they took place.  There were incidents

19     before and after the period you mentioned.  There were some incidents

20     involving the killing of soldiers in Ljubija.  They were killed by

21     Muslims.

22             I can't remember, really, at this point.  It was tumultuous, but

23     there wasn't fighting as such.  If somebody refreshed my memory, I might

24     remember.

25        Q.   Mr. Jankovic, do you recall the conflicts in Hambarine and

Page 24802

 1     Jakupovici?

 2        A.   Well, yes, Jakupovici does ring a bell.  And not just those,

 3     there was Kozarac there as well.  It's just that there was no police

 4     involvement in that.  Well, I say that I heard about it, but -- and that

 5     there was no involvement of the police.  Rather, there was the army.

 6             As for Hambarine, what I know is that they came across soldiers

 7     who were then killed.  There's information in my mind that I can't be

 8     really sure of, that there was a car full of soldiers coming back from

 9     somewhere, were stopped at a check-point manned by Muslims.  Something

10     happened.  They were killed.  I don't know the date.  I know that the

11     check-points in the direction of Ljubija were manned by Muslims.  I know

12     that the soldiers who were killed were Serbs.  I don't know the

13     circumstances involved.

14             Now you also mentioned Jakupovici.  It's a large village,

15     eastern-most in the municipality of Prijedor, in the direction of

16     Banja Luka.  One edge of the village lines the Prijedor-Banja Luka main

17     road.  Along that road, there travelled a column.  I don't know who they

18     were.  Apparently there was an ambush of sorts.  There was fire opened on

19     a tank.  The only thing I know is that a soldier by the name of

20     Zgonjanin, from Prijedor, was killed.  I don't know if anybody else was

21     killed or wounded.  I happened to know where that lad's house is, and I

22     know that Muslims attacked a column passing by Jakupovici.

23             The only thing I can tell you about still is about the radio

24     station.  That's what I know of.

25        Q.   Yes.  I will be putting questions to you later on about that.

Page 24803

 1             MR. KRGOVIC: [Interpretation] Perhaps it's the time for our

 2     break, Your Honours.

 3             JUDGE HALL:  Yes.  So we take a break to return in 20 minutes.

 4                           [The witness stands down]

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

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

 7                           [Trial Chamber confers]

 8                           [The witness takes the stand]

 9             MR. KRGOVIC: [Interpretation]

10        Q.   Mr. Jankovic, let us resume.

11             I was asking you about the incidents occurring in the last

12     ten days of May.  You mentioned Jakupovici, Hambarine, and Kozarac.

13             In that period of time, did you have occasion to hear some of the

14     conversations between the warring parties in your communications centre?

15        A.   Let me tell you, between the 29th and the 30th of April and the

16     20th of May -- I apologise for using the term SUP all the time but that

17     was the term that we used for so many years.  So in the SUP, let me just

18     tie all of this in.  There was increased police activity, people were

19     brought in and interviewed, and they were, in the main, people from

20     Prijedor.  However, Kozarac and its surroundings which were predominantly

21     inhabited by the Muslims -- by the way, let me give you a piece of

22     information that I came to know in my line of work, which was that the

23     Kozarac substation covered 22.000 inhabitants.  It is the size of two

24     municipalities, in fact.  And there was only a few Serbs and Ukrainians;

25     the rest were Muslims.

Page 24804

 1             So this same Kozarac became directly inaccessible to the newly

 2     established authorities.  The Muslims mounted their own barricades and

 3     placed their own guards.  I don't know how -- how specifically it worked.

 4     I didn't go there.  So any of us from the police force, when we had to go

 5     to Omarska, we took the route via Tomasica.  For those you who are

 6     unfamiliar with the area, let me tell you that I have to take

 7     25 kilometres straight, 25 kilometres to the right, and then back again,

 8     so I make this triangle sort of detour to go around Kozarac.  Because it

 9     was quite evident that the new government was unable to have that area

10     under control.

11             Now, what I'm telling you right now were feelings that I had, not

12     that I knew anything about it.  This was one of the problems that the new

13     authorities, the way I called them, it's not the official title, but to

14     make things simple, this was one of the problems that the newly

15     established authorities were confronted with.  And this problem - meaning

16     Kozarac - had to be resolved.  They had their own leadership and their

17     own senior officials who were consulted for things.  It was an issue that

18     went beyond the capabilities of the police force, and that's why the army

19     was concerned with this.

20             I didn't know much about it, but what I knew was that these

21     people in Kozarac had their own staff or headquarters housed in what used

22     to be the police substation or the police branch, and the only

23     connections that they used to be in contact with the army was the ultra

24     high frequency link normally used by the police, not by the army, because

25     so far as I know, the army didn't have -- or the military equipment did

Page 24805

 1     not use that frequency.  Thus, all these negotiations, or perhaps not

 2     all, there may have been direct negotiations, but a great deal of them

 3     took place over radio communications.

 4             In my communications centre, there were radio sets where one

 5     could overhear these conversations, and I did hear a few over the course

 6     of a couple of days.  It wasn't the case, of course, that I was sitting

 7     there with my ear glued to that.  I merely had an interest in having this

 8     matter resolved and would, on occasion, stop by the radio equipment to

 9     hear what the outlook seemed to be like.  But this was more my personal

10     interest.  It wasn't something I did professionally.

11             So I came to hear their commander, Osman Didovic, who used to be

12     our commander, talk to them.  He was -- or, rather, talk to Zeljaja.  He

13     was at the other end and he was the senior military officer in Prijedor.

14     So Osman Didovic speaking to Zeljaja.

15             Whenever said Zeljaja, Things have to be done this way, this is

16     what we want, do this and that, Osmet would say, Well, I'm calling you

17     from a vehicle.  I have to convey your message to my colleagues and then

18     we'll get back to you in an hour's time.  The device I had in the

19     communications centre had the ability of identifying the interlocutors

20     because we would be able to tell by the number of the device used by the

21     speakers.  So I was able to tell that the device used by Osmet was no

22     device used in a mobile facility such as a vehicle.  Rather, it was part

23     of their equipment in their station that they had over there.  I didn't

24     feel that I was best placed to go over to Zeljaja and tell him that what

25     Osmet was telling him about where he was calling from was not true.  I

Page 24806

 1     kept it to myself.  And I'm saying it now.  I don't know how significant

 2     it is.

 3             From what I know, over there in Kozarac they had their - how

 4     shall I call him? - man number one, man in charge, he was called

 5     Medunjanin or something like that.  Or Medunjani.  I'm not sure if he is

 6     from Kosovo originally.  Just before the multi-party elections, he was in

 7     charge of national defence in the municipality.  He joined them over

 8     there in Kozarac, and, from what I know, he was -- no, no, I'm not able

 9     to say what his title was because I don't know what his title was.  So

10     let me just say that he was the man in charge with them.  So Osmet, when

11     he was saying that he was going to convey this to other gentlemen, I

12     could hear them because we had very sophisticated equipment in our

13     centre.  I could hear them whispering amongst themselves, so I suppose it

14     was some sort of tactics that they employed.

15             So this was how things went on for two or three days.  They

16     didn't manage to come to an agreement and the army set off for that area.

17        Q.   Mr. Jankovic, let us just go back to Medunjanin.  There is one

18     bit missing in the transcript from what you said in your answer and I

19     heard you say.  Can you repeat, you said you didn't know what his

20     function was but he was and can you tell us what he was exactly?

21        A.   I didn't perhaps say this right.  I don't know what the official

22     title of that role was because it kept changing, secretary, chief,

23     et cetera.  From what I know, and I'm almost certain that after the

24     multi-party elections he, or rather, the SDA, got the mandate for the

25     position of the person in charge of national defence in the municipality.

Page 24807

 1     So let's say that that would be the equivalent in the municipality of the

 2     position of the minister of defence in the government.  What exactly his

 3     function was, I don't know.  And given the circumstances, he moved from

 4     Prijedor to Kozarac.

 5             Let me also say that they had carried out a sort of mobilisation

 6     of their own.  After the military interventions that took place over

 7     there, I received from some of these soldiers -- well, easy come, easy

 8     go, I lost it somewhere.  I received from one of those soldiers anyway, a

 9     tape with footage of their mobilisation.  I was able to see fire engine

10     sirens going off.  They were running in all directions.  Running toward

11     the police station.  Others were just walking in that direction.  They

12     gathered over there.  I recognised a man by the name of Emir, who was a

13     car mechanic and came to our station to repair our vehicles.

14             I gave the tape to someone or lost it.  At any rate, there's this

15     one image I remember.  My colleague Djuro Prpos, who I mentioned as

16     having been present at the meeting, who was the commander of traffic

17     police, well, this man was Djuro's brother-in-law.  He was a JNA officer

18     in Zagreb and came back.  He was a Muslim, I forget his family name.  So

19     I saw him in this footage because he was a rather tall man of good

20     physique.  He had this camouflage uniform on and green beret with a

21     crescent made of brass or something.  He had a belt and tucked behind it

22     he had a Heckler, the gun -- the rifle -- I mean, the pistol, you know.

23     And he also carried a rifle.  And there was some five or six of them

24     outside the station and he came to them and said, Here I am.  Allah is --

25     has given me the mission of doing you know what to Serb women and

Page 24808

 1     procreate young Muslims.  And as we were watching this Djuro said, This

 2     is my brother-in-law.  And the only thing I know of him is that he got

 3     killed in the subsequent fighting.

 4             And let me say that I have never told this to anyone before, this

 5     story.  And the details I'm giving you now serve to put together the

 6     mosaic of it all.  And even if the police had any role to play in it, it

 7     was so insignificant that I didn't know of it, and as the chief of

 8     communications centre, I had to know everything, every action that was

 9     being taken because I had to give them support from my end in terms of

10     communications.  And, of course, that fell onto me.  So I can tell that

11     you I didn't take part in any action, and none of the actions could have

12     taken place without me doing appropriate communications work.

13             So I have no knowledge of it taking place, and I have no basis to

14     state that there were any policemen involved in the combing of the area

15     covered by that Kozarac station.  I heard that there were deaths on both

16     ends, not many, but it was not an insignificant action.  That's what I

17     remember.

18        Q.   Mr. Jankovic, can you tell us something about the events which

19     took place on the 30th of May and the combat which occurred in Prijedor?

20        A.   Yes.  I haven't told anyone but I wish to give you as good a

21     picture of the situation as I can, to anyone who may be listening, and

22     sometimes it may seem simple when you put into words.  But one example is

23     often very illustrative so I would give you one, if you allow me.  It

24     won't take long.

25             The power changed hands.  The SDS was in power.  Now, according

Page 24809

 1     to the old system, the politicians are the ones who appoint managers, top

 2     officials, and so on.  I was at the communications centre, and let me say

 3     that there were several rooms in it, and not everyone had access to it,

 4     including even the police employees.  There was a key and there was a

 5     separation, as here.  And I was sitting at my office.  And one of my

 6     employees who was on duty at the time called me and said, There's a man

 7     who wants to see you.  I came there, but I didn't know him.  He told me,

 8     Are you the boss here?  Yes, I am.  Give me one Matorola - he didn't even

 9     know how to say Motorola and he meant the radio - and two batteries.  I

10     was looking at him and I could see that he did not have all his wits

11     about him.  Who are you, I asked him.  He said, Don't ask me too many

12     questions but just give it to me.  I could see that there was something

13     strange about that.  So therefore, in order to be convincing I told him,

14     You probably came to a wrong address.  This is the police and the only

15     thing can you get for free here is to be beaten.  It is not really like

16     that, but I was convinced that it was the only way to persuade him.  And

17     he did take that correctly.  So he left.

18             After that, I asked the other guy, Who was this?  Maki Specijalac

19     [phoen], he said.  And this Maki, the special, was Marinko, a special,

20     who had completed a special school for people with special needs and he

21     was at the time holding the position of the director of all kiosks in

22     Prijedor.  But there was no single director or manager who was not

23     appointed by the SDS.  And who had appointed this Maki?  It means that

24     people who appointed him were not much better.  And now a short break.

25        Q.   Please don't speak so fast.

Page 24810

 1        A.   I hope they will manage to record all this.  I apologise.

 2             The point of all this is that a manager was somebody who was

 3     retarded and the main question is who appointed him?  If these were the

 4     authorities that appointed him, then how could the other socially owned

 5     enterprises work, institutions, the police?  What would the chief of

 6     police do if such a man came to see him?  But he was sent by the person

 7     who appointed him so he would have to be respected.  For me all that was

 8     questionable, but I told you this example in order to illustrate the

 9     situation that existed at the time.

10             And now to go back to what you asked me.  Namely, what happened

11     in the latter part of this period between -- or, rather, up until the

12     attack on Prijedor.  As I said, the police summonsed some people, not too

13     many.  Those they termed the extremists and these were actually the

14     Muslims who were holding higher positions in the organisation before

15     there was a takeover of power.  They questioned them but slowly, with a

16     lot of inertia.  I'm not sure where that was leading to.  They also

17     stepped up some sort of security and they set up some so-called

18     check-points.  They placed policemen to stand there on the roads that

19     were leading into the town.

20             Comment on one check-point and its fate.  And that was just

21     typical of the overall situation.  You might know that was the

22     check-point where we met for the first time, the Lepont cafe restaurant,

23     and across the road from it there was one police vehicle and two -- or,

24     rather, three reserve policemen.  Three policemen.  They just stood

25     there.  At the time everyone was very active, both the Serbs and the

Page 24811

 1     Muslims.  Usually I don't mention the Croats because they were much fewer

 2     in numbers and no one paid too much attention to them.  But, of course,

 3     they had their own beliefs, as all the people did.  At the time, as I

 4     said, when everyone was carrying out activities in a hectic manner,

 5     whether these were important or unimportant activities, even the elderly

 6     ladies in the town who, I guess, were worried about their future, managed

 7     to attract attention.  And it even happened to me that an old woman who

 8     just knew that I was employed in the police would tell me, Neighbour, I

 9     saw such and such a thing.  Hoping that I would then inform the police

10     about it, that in a certain spot -- because, for example, one old woman

11     said, Neighbour, in Alija's house, and Alija was one of our colleague, a

12     policeman, a Muslim, I saw that 14 men were in his house.  I counted them

13     through the window.  At 2.00 they came out of their apartment.  That was

14     not a usual occurrence.  It was interesting for this old woman and he

15     would inform me about that.  And that was all.

16             So people paid attention even to insignificant things.

17             Somebody else, never mind who, or, rather, I don't remember who

18     it was, told me, and I heard from many sources -- I never asked him.

19     There was just the information circulating.  Everybody else would know

20     that, not just me.  Somebody knew more, somebody knew less about it --

21             JUDGE HARHOFF:  Mr. Krgovic, I just ask where are we going with

22     all of this.  I should remind you, Mr. Krgovic, I should remind you that

23     I think you have a little more than one hour left.

24             MR. KRGOVIC: [Interpretation]

25        Q.   Mr. Jankovic, I asked you and I will ask you later about the

Page 24812

 1     general situation in the town, but let us return to the 30th of May and

 2     the attack on Prijedor, if we can.

 3        A.   Yes, of course, of course.  I'm sorry, I don't think I strayed

 4     from the situation, because all this information is connected with the

 5     attack itself.  If I talked only about it, then it would seem that it

 6     came out of the blue.  And that's not true.  There were preparations

 7     ongoing.

 8             Let me just finish one sentence where you interrupted me.

 9             They told me that Dr. Eso Sadikovic travelled up every day to the

10     hill, they meant Hambarine, and also one Cida, bringing equipment and all

11     kinds of things up to the top of the hill so that the Muslims would

12     organise themselves.  The Serbs in Prijedor, at the station, heard that

13     but they didn't do anything about, or perhaps they did somebody that was

14     insignificant.  And simply, on 30th May, at 4.00 a.m.  in the morning,

15     4.00 a.m., no one expected that.  There was shooting all around the SUP

16     building and the court building.

17             These days it was our duty, including myself, to be in the

18     station building day and night.  We had the right to go home to have a

19     bath perhaps once in every three or four days.  And it happened that that

20     very night I went to my apartment, which is perhaps 1 kilometre away, in

21     order to wash myself.  And in the morning, when I was supposed to go to

22     work, they called me and said, Cema [phoen] is shooting in the town.  And

23     my communications officers called me and said, Don't come here, because

24     there's much combat going around, around the SUP building and the

25     municipality building.  And so I stayed there and waited for them to call

Page 24813

 1     me and tell me that I could get to the station.  And I was only able to

 2     do so at 11.00.

 3             I later heard that the police was poorly armed and defended

 4     itself only up until the -- until 7.00, so that is to say between 4.00

 5     and 7.00 a.m., from the building.  And at 7.00 a.m. the army came along.

 6     It was assistance from them and I think there were one or two tanks.

 7     There was one for sure because I could see the cartridges and I also

 8     heard shots, perhaps one or two, not too many, but I'm sure I saw spent

 9     tank shell.

10             So the army began fighting in order to separate them and push

11     them back from the municipal and SUP buildings in a westerly direction,

12     that is to say, towards the Raskovac suburb.  And when they moved for

13     about 500 metres, I was able to access the SUP building and then I joined

14     everyone else from the communications service and remained there.  The

15     fighting went on in the town itself until the end of the day.  It did not

16     stop but they were moving away from the town centre.  They went all the

17     way to Ljubija and further, and I wouldn't know the details about that.

18     That was already several days later.

19        Q.   Mr. Jankovic, can you tell me how many people were killed on that

20     occasion?  I mean, policemen.

21        A.   Yes.  Let me first tell you that I have the number of 17 on my

22     mind.  I never had the need to try and remember that in any official

23     manner.  But that evening, when the fighting had already moved away from

24     the town centre for perhaps 1 kilometre, Djuro Prpos, whom I mentioned,

25     who was the commander -- or, rather, the deputy commander of the traffic

Page 24814

 1     police, called me to go with him to the Prijedor hospital.  It was

 2     already at night.  Perhaps at 8.00 or 9.00 p.m.  I was to try and help

 3     him to recognise the policemen at the hospital morgue because the groups

 4     which were pulling out the dead and wounded didn't know who was a Muslim,

 5     who was a policemen or what.  They just took them all there, the sick,

 6     the wounded, the dead, and it was necessary to recognise who was a

 7     Muslim, who was not, who was the attacker, and who was a member of our

 8     police, if I may put it that way.

 9             I don't know how many there were, but there were many, many

10     bodies there.  There were two rooms that were perhaps 10 by 6 metres, and

11     they were laid out on tables and under them.  Perhaps around 40 people.

12     I recognised the ones I knew.  I recognised all the active-duty

13     policemen.  And as for the reserve policemen, I didn't even know them.

14     There were our people I didn't know and didn't recognise.  I only

15     recognised all the active-duty policemen, as many of them as there may

16     have been.  Perhaps four or five.  I don't remember anymore.  I remember

17     that the little Lukic was there, Zeljko Ignjatovic, then Brane Jurtic

18     [phoen] and so on.

19             That's what I remember about that.

20        Q.   After the attack on Prijedor and the conflict in Hambarine and

21     Kozarac, did the security situation in Prijedor change in any way, and

22     what sort of impact did that have on the work of the station?

23        A.   That was the biggest change, right then.  Why?  The units that

24     had attacked, I never counted them, but as far as I know, the units which

25     attacked on Prijedor were perhaps three or four companies.  Three, I

Page 24815

 1     would say.  Three, I guess.  One attacked us from the factory.  One from

 2     the bridge where we met at a cafe restaurant.  And one from the east,

 3     from the area of Puharska.  And Puharska is a local commune which

 4     belonged to the town.

 5             And, as I said, when the army and those who were chasing them

 6     began to push them back and they were withdrawing, there were those who

 7     withdrew and fled while fighting and there were many who surrendered

 8     themselves in one way or another.  So that suddenly there was a huge

 9     number of these prisoners, if I can call them that.  And then they

10     detained those prisoners because they were so numerous.

11             At first, what their plan was, as far as I could see, and I was

12     present, they were to be treated as if one or two terrorists were caught

13     in peacetime.  They would bring him in, detain him and then process him.

14     But as there were so many prisoners and the detention room was too small,

15     I don't know how they had reached the agreement, I have no idea, but I

16     remember that they began to collect them on the premises of the Keraterm

17     company.  Keraterm was a construction company.  They had a big -- big

18     hall but there were no machines so they found that as an appropriate

19     place.

20        Q.   When you say a company under construction what do you mean by

21     that?

22        A.   Well, it wasn't a working company.  It never really became

23     operational.  Someone found it and made it and put up the hall but there

24     were no machines.  And this was very appropriate because it was summer,

25     not winter, this is the place where you could bring so many people.

Page 24816

 1             I only went once to Keraterm, perhaps for 20 minutes or half an

 2     hour, and I saw many troops, policemen, and whoever of all -- uniforms of

 3     all colours, but I just passed through and I glanced at them.  I did not

 4     really observe anything because I didn't need to.  All I remember is this

 5     sight that I saw of many people dressed in various uniforms.

 6        Q.   Have you ever been to Omarska?

 7        A.   Yes.  After that -- it was something that I didn't know much

 8     about.  I only once went to Keraterm to fix a telephone.  But then I

 9     heard that they were short of space due to the large number of detainees,

10     and they wanted to move to a bigger premises in the Omarska mines.  And

11     that's the first time I heard of it, and I went there.

12             On that day, I don't know when it was, when the first prisoners

13     were taken to Omarska, it was 1800 hours, and I remember that precisely

14     because Simo, my superior, called me and asked me, Do you have any

15     available radio sets?  You need to establish a connection urgently.  And

16     I said, Yes, I always have an emergency radio set available.  He asked

17     me, Can you go to Omarska and install that?  I looked at my watch.  It

18     was 6.00; I remember clearly.

19             He told me, Go there.  You will find our policemen up there.

20     Tell them that you need to install a radio set, and they will tell you

21     where to do that.  Of course, I took the device with me and a technician

22     and an official car.  On that day, one had to travel to Tomasica, so one

23     had to bypass Kozarac for security reasons, although via Kozarac was a

24     much shorter way.

25             When we arrived, it was still daylight, but darkness fell soon

Page 24817

 1     thereafter.  I found our policemen there who -- who were members of the

 2     Omarska police squad.  Among them, I remember seeing Miroslav Kvocka, who

 3     was here later on.  I remembered him because he was a neighbour of mine

 4     in Prijedor --

 5        Q.   Since we don't have much time, can you briefly tell us how long

 6     you stayed there and when you went back.

 7        A.   All right, all right.

 8             So I installed the radio set.  I made it operational.  It was

 9     already darkness.  I was -- wanted to go back.  The police told me that I

10     couldn't leave at that time because the buses with the detainees were

11     just arriving, and it was not advisable that I travel in the opposite

12     direction.  Therefore I parked my vehicle some 100 metres away until this

13     whole operation was completed.  Then we travelled at around midnight back

14     home.  We came across the Serb check-point and it was towards the dawn

15     when we reached Prijedor.

16        Q.   When was the second time you went there?

17        A.   Only when they had some broken-down telephone line, and again I

18     went with a technician there.  I have to tell you that this whole

19     facility had only one telephone line.  That was in the office of the

20     secretary of the former company manager.  I fixed this broken telephone

21     line.  We didn't spend more than 20 minutes on the job, and we went back.

22             And the third time was when two people at the police station in

23     Prijedor, actually, two servicemen, a captain and a staff-sergeant,

24     approached me, and they both spoke in the Ekavian dialect which was

25     predominant in the army --

Page 24818

 1        Q.   Sir, this wasn't quite clear.  Who these people were membered of?

 2        A.   Yes, there were in the army uniforms.  I don't know to which unit

 3     they belonged.  I never asked them.  They were from the army, they were

 4     outsiders, not from our region judging by their accents.  Maybe they were

 5     just attached to this unit in Prijedor.  I perceived them to be some sort

 6     of military investigators.  And they asked me, they did not request

 7     decidedly, they just asked me to go with them to Omarska as a kind of

 8     professional who would accompany them there, as a kind of expert to

 9     accompany them.  When I understood what their request was, I said, yes, I

10     was prepared to help them, because I always want to help people.  But I

11     told them that I will not discuss anything else with anyone there except

12     the things that have to deal with this particular piece of equipment.

13     Because that was without my scope of responsibility.  My sole

14     responsibility had to do with technical issues, and as an engineer, it

15     was my duty to assist them.  And they didn't ask for more, to be honest,

16     and that's how it happened.

17             They brought two men and started questioning them in turn.  One

18     of them was an elderly man, looked like a farmer, and the other one was a

19     rather well-off owner of equipment for logging.  I don't know what his

20     name was.  They were allegedly accused of buying a radio set for the

21     Muslims, and he was a Muslim.  The other one was called, I think, Mihajl.

22     He was a teacher from Lamovita, from the elementary school there, and he

23     was accused of allegedly operating this radio set to communicate with

24     Kozarac and to tell them that a unit from Banja Luka was on its way.

25             They were questioned for about half an hour.  Being someone who

Page 24819

 1     is not versed in these issues, I thought that they were quite innocent.

 2     The first one said that somebody came and that he was asked to sent a

 3     message to Kozarac, an encoded message, a wedding party is passing

 4     through, and that referred to this unit that was heading for Kozarac.

 5             Soon thereafter they admitted to having done that, to having this

 6     radio set --

 7        Q.   Just one thing that wasn't recorded.  I heard you say that this

 8     one reported which kind of unit was coming from Banja Luka?  Police or

 9     army?

10        A.   An army unit.  And that happened approximately at the time when

11     this young man Zgonjanin was killed.  I suppose it was an army unit with

12     one or more tanks because I remember that a tank came under attack.

13             Anyway, this man called Nihad perhaps, I'm not sure, his -- their

14     communications officer, if I can call him that, sent this coded message

15     which read:  The wedding party is passing through.  And this interview

16     lasted only until the point when they admitted to the location of the

17     radio set and this radio set is -- appeared to be -- to have been hidden

18     in a nearby house.

19             I went there with them.  We found this little house.  And in a

20     wooden stove, we found the radio set.  However, when we -- actually when

21     we looked there, we couldn't find it, but we found only cables for an

22     Accu battery.  That was indicative, obviously, of the fact that a device

23     used to be there.

24             And not far from that point, there was an old point where some

25     elderly Serb peasants set up their check-point and all the uniforms that

Page 24820

 1     they had was some ancient SNB reserve military uniforms.  They didn't

 2     deny things for a long time.  They admitted to this very quickly.  They

 3     told us about the house.  And when we went there, we found the mother and

 4     the wife of this man called Dusko.  He wasn't around, and after some

 5     threats were made, the radio set was handed over.  I took the radio set

 6     and I realised that it was a rather new type of CB radio set.  CB stands

 7     for civilian band which is a radio set that the can be used by anyone

 8     without a licence throughout Europe.  That was in the era before mobile

 9     phones.

10             So one did not need any licence or permit to either purchase this

11     set or to use this.  That was the only type of radio set that was allowed

12     to be used.

13             They took the radio set with them, and I never heard of them

14     again or discussed this issue with them again.

15        Q.   These people where this radio set was found and confiscated, what

16     was their nationality?

17        A.   They were all Serbs from that village.

18        Q.   Mr. Jankovic, I'm going to move to another subject now.  And it

19     has to do with ...

20                           [Trial Chamber confers]

21             MR. KRGOVIC: [Interpretation]

22        Q.   Can you explain this to me because we have to go back to

23     something.  I don't know if I understood you correctly.

24             Whose radio set was it and how come that it was in the hands of

25     the Serbs?

Page 24821

 1        A.   Well, how?  This communications officer Nedzad said that it was

 2     in this road by the Prijedor-Banja Luka road.  This was their

 3     communications centre, if I may call it.  And he hid it underneath the

 4     oven in this stove which means that he wanted to conceal it and to come

 5     later to fetch it and use it again.  In the meantime, the situation

 6     changed because Serbs came after the Muslim attack to guard this point.

 7     These were those elderly Serbs.  They even had some rifles, M48 rifles

 8     from Second World War.  And they were all so-called old timers, both them

 9     and their rifles.  Just like all nosey people, they looked around this

10     house and they discovered the radio set, and they took it away, because

11     people thought that anything is worth taking away.

12             And that's how had came to be in their hands.  That was just

13     greed.  There was no organisation behind it.

14             THE INTERPRETER:  Interpreter's correction:  That was just greed.

15             THE WITNESS: [Interpretation] Yes, he was personally a greedy

16     person.  If I had seen that radio set, I wouldn't have taken it, ever.

17             MR. KRGOVIC: [Interpretation]

18        Q.   Mr. Jankovic, let's go back to the operation of the Prijedor

19     police station prior to the outbreak of conflict and the time when

20     Simo Drljaca was appointed SJB chief.

21             Did anything change in the mode of operation of the public

22     security station?  What was his methodology and how did he run the

23     station?

24        A.   Can you tell me exactly which period are you referring to?

25        Q.   After the takeover of power and at the outset of the conflict in

Page 24822

 1     the municipality.

 2        A.   Yes, yes, now it's clear.

 3             Everything started in a stormy way.  Starting with the events

 4     surrounding Keraterm.  Then the emergence of Omarska.  There was almost

 5     no practice that was pursued before, in terms of the chief having us in

 6     his office and reporting to him.  It was only individuals who went to

 7     Simo's office.  They were agreeing things.  I also went to see the chief

 8     whenever I needed to ask him something, but more and more frequently, his

 9     secretary was telling me that I couldn't get in because someone was in a

10     meeting with the chief.

11             So I was pushed aside more and more.  There were fewer and fewer

12     people with whom he conducted these so-called operative activities that

13     had nothing to do with police work.  I don't know what I was supposed to

14     do with that situation.  I just could make suppositions.  People were

15     coming and going.  And you know better than I do what was going on when

16     you talk with those people.  I was not interested much in that.  But this

17     operation of this particular police station was far, far from normal.

18     That's in a nutshell.

19        Q.   Tell me, Mr. Jankovic, what was the situation on the streets of

20     Prijedor?  Was it safe?

21        A.   No, far from it.  In the town of Prijedor and in the general

22     area, the situation was extremely chaotic.  Some wanted to seize

23     somebody's house because people had fled and abandoned their property.

24     People were starting to drink.  Some other people started developing all

25     sorts of ambitions of becoming heros or what.  Others, as I said, took to

Page 24823

 1     binge drinking.

 2             There was a man who -- and I'd like to tell you this.  There was

 3     no organised shooting by the Serbs at the Muslims.  In the evening I was

 4     at the SUP building.  It was still daylight, and I went to a house where

 5     my children were being minded by a woman and there was a man standing on

 6     the carriageway by -- close to the curb.  He was in a military uniform

 7     and there were another two men in the civilian clothes talking to him.

 8     There was no one else around.  When I was passing by, one of them called

 9     me, Hello, you, big head.  And I turned towards him, and he said, Yes,

10     yes, I'm addressing you.  Are you a Balija?  Which is a derogatory name

11     for Muslims.  And I said, No, I'm not.  He said, Show me your ID.  Now

12     let me tell you this.  At that moment I had my ID, I had my police ID, I

13     had my fire-arm with me, but I decided that in spite of that, the best

14     possible approach was -- would be to show him my papers in a peaceful

15     manner.

16             He looked at it and there was the old name of the village where I

17     was born, which was Zabar, and he read this, and he swore at me, saying,

18     Oh, you are from Zabar.  And then he took out his pistol and fired a shot

19     at me.  He missed me by this much from my right leg.  There was a big

20     linden tree behind me.  I could have jumped behind its trunk and shoot

21     him dead but that would require too much investigation and proving on my

22     side.  I saw that he was under the influence of alcohol.  His eyes were

23     bloodshot, and these two started wrestling with him in order to grab the

24     pistol off him.  So I decided that the best policy would be for me to

25     withdraw and leave it be.

Page 24824

 1             This is just an illustration of what was going on in the town at

 2     the time, irrespective of your ethnicity, of your background, whatever.

 3     There were all kinds of motivations and all sorts of negative traits came

 4     to the surface.  So this was resembling more a chaotic situation and

 5     there was no -- any thought for organisation.

 6             I was not the only such case.  The daughter of Zoran, a Serb, was

 7     fired by someone.  She was shot with a bust of bullets and she was raped

 8     as well.  So I won't go into that.

 9             Total chaos.  So everybody who was an ordinary person tried to

10     avoid moving around the town, and I restricted my movements only to the

11     things that had to do with my duties and job.  I didn't go for a stroll.

12        Q.   Now that we're discussing reporting, I have a document I want to

13     show the witness.

14             MR. KRGOVIC: [Interpretation] Exhibit P00374.  That's behind

15     tab 2 of the Zupljanin Defence binder.

16        Q.   Sir, you have tab 2 in a photocopy there.

17        A.   What am I supposed to do there?

18        Q.   Have a look at the document.  The document is instructions on

19     reporting.  Have a look at page 2 and the signature block which reads:

20     Stojan Zupljanin.

21             MR. KRGOVIC: [Interpretation] Turn the page, please.

22        Q.   Herein, Mr. Zupljanin reads as follows -- writes as follows:

23             "Every day reporting on daily activities of the CSB Banja Luka

24     coming from the various stations is riddled with faults and shortcomings

25     as follows ..."

Page 24825

 1             Do you have the document there before you?

 2        A.   Yes, I do.

 3        Q.   Then follow as I'm reading it.

 4        A.   Is it 0043234?  So that is dispatch 11-0-11, 26th of May, 1992.

 5        Q.   Right.  And the first sentence which reads that the reporting is

 6     riddled with shortcomings.  And under 2 it reads:

 7             "Not all important events are reported on.  Frequently

 8     information is not complete.  Morning dispatches are not sent out in a

 9     timely fashion.  The events which are learnt of subsequently are not

10     recorded and incomplete reports are sent out.  Supervisory staff barely

11     check and supervise any these reports."

12        A.   Very well.  What is your question?

13        Q.   My question is:  What sort of situation prevailed in Prijedor

14     when it comes to reporting?  Could this be said to apply to Prijedor as

15     well when it comes to the reports that were being sent out?

16        A.   The situation in Prijedor was practically inefficient.  Let me

17     explain.

18             This sort of dispatches were textbook dispatches, and requests

19     were sent for dispatches to be corrected if they went out of the ordinary

20     format by 5 per cent.  Now let me tell you that what happened in this

21     period of time was that illiterates came to work for the SUP so you --

22     the dispatches couldn't be said to deviate by 5 per cent on what was the

23     ordinary dispatch but by 95 per cent.  And attempts were made to remedy

24     this, but I think it was not really within his ability.

25             I haven't had occasion to read such documents as this one before,

Page 24826

 1     but as I look at it, I can see that the situation in Prijedor had nothing

 2     to do with what was proper police work.  Incompetents came to work.

 3     Simo Drljaca used to be a lawyer, I think, and I think he worked for a

 4     music school and I think he also worked in this local government

 5     department for education.  And then can you imagine?  A lawyer working in

 6     a music school and then coming to work for police?  His level of

 7     knowledge was nil.

 8             When you come to a police station and you see a duty officer

 9     behind his desk, and next to him some ambitious men like Zdravko Torbica,

10     these were people who had high pretensions but were practically

11     illiterate.  Plus, they had no sort of support from Simo.  He didn't

12     force them to do their job properly.  Their reports did pass through my

13     hands because they went through the communications department, but I

14     didn't read them.  I'm sure there's as many as 50 of items in this

15     document that were not really addressed in everyday work, and I don't

16     think even five of them may have been covered in everyday work, and if

17     they were, they were probably worded in an illiterate manner.

18             I hope my answer was sufficient for your purposes.

19             THE INTERPRETER:  The interpreter didn't hear.  Mr. Krgovic

20     didn't switch his microphone on.

21             THE WITNESS: [Interpretation] Very well.  Did I answer your

22     question?

23             MR. KRGOVIC: [Interpretation]

24        Q.   Yes.  Let me see, you said a moment ago -- you said that they

25     were illiterate in police terms.  What does that mean?

Page 24827

 1        A.   Well, I coined that expression, if I can say so.  It doesn't

 2     really exist.

 3             Let me explain, well, illiterate in police terms.  He was

 4     ignorant of the basic police work.  They didn't know that they were

 5     supposed to receive tasks from the superiors and report back to them on

 6     the tasks accomplished, that Simo had to have problem information from

 7     his subordinates and had to properly inform his superiors thereof.  He

 8     didn't know that.  His superior was the chief of centre and he was

 9     supposed to report to the chief of the centre.  He never did so.  He got

10     hold of a position of power, and he probably thought that the chief, as

11     well as gods, were beneath him.  In other words, basic policing duties

12     that every policemen ought to have been aware of were not something that

13     any of the incumbent policemen knew.

14             And let me tell that you not of all of them were as incompetent

15     as that.  There were people working in the police force before and

16     couldn't work in ways that weren't prescribed by standard procedure

17     because they had come to learn it.  Of course, quite a different issue is

18     what sort of influence these people who were literate in police work were

19     able to wield.

20        Q.   Mr. Jankovic, in your evidence so far, you said that there were

21     difficulties in the payment of salaries.  Can you tell us, in this period

22     prior to these events, who did the police receive their salaries from?

23        A.   The municipality.  Well, I say "municipality."  We know what it

24     is.  There's also the party organisation, the SDS.  However, in reality,

25     they were people who were municipal functionaries as well as SDS members.

Page 24828

 1     They sent one of their own lot, that's to say, Simo, to take charge of

 2     our duties.  They had their own plans that they tried to put into effect

 3     through Simo and us.  And, of course, they paid us our salaries.

 4             In the previous system, during Yugoslavia, there was local

 5     administration, and the SUP received their salaries from the

 6     municipality.  So in that sense, not much had changed with the new

 7     government.  They knew that it was the municipal revenue that served to

 8     pay for municipal justice administration, police, schools, et cetera.

 9     And, in fact, even I myself had to obey what they had to say, not

10     directly, but through Simo.

11        Q.   From what I understand, you did not feel that this power was

12     being exerted directly to you.  Rather, through Simo?

13        A.   No.  They would approach Simo and give him a task and, of course,

14     as part of the police force, I was duty-bound to perform the task.  And

15     it was never the case that Simo received a task from them that had solely

16     to be performed by the communications department.

17        Q.   The influence wielded by the municipal government, was it

18     something out of the ordinary to you, something that did not exist in the

19     previous period?

20        A.   No, no, far from it.  In the former Yugoslav system, we had the

21     municipal committee of the League of Communists, and whatever they said

22     had to be done was done.  And, of course, the chief of the police station

23     would go there to learn what he had to do.  Now it wasn't the League of

24     Communists any longer.  Now it was the SDA, and Hasan would go there to

25     get his instructions on what he was supposed to do.  Then it was the SDS,

Page 24829

 1     and Simo had to go over there to learn what it was that he to do.

 2             So that's how the situation changed in just under a year.

 3             Eventually, as the government grew stronger, things changed.  We

 4     received our salaries from the republican levels, as well as orders,

 5     et cetera, but it took time to get to that point.

 6        Q.   I will show you a document now.  Or, in fact -- yes.  Let's look

 7     at it briefly, P00621.

 8        A.   Which number is it?  4?

 9        Q.   Tab 10.

10        A.   Yes, I've found it.  Report on the work of the Security Services

11     Centre Banja Luka.  Is that it?

12        Q.   Yes.

13        A.   The 1st of July until the 30th of September.

14        Q.   We have several minutes before we take our break.  So please take

15     the document with you over the break and have a look at what it has to

16     say, and then I'll put a couple of questions to you after the break.  We

17     are nearing the end of my examination.

18             So please have a look at page 21, 22, and 23.

19        A.   A moment, please.

20        Q.   Would you please take it with you?

21        A.   Yes, let me just find it.  You mean the typewritten 21?

22        Q.   Yes.

23        A.   21 through to the end.

24        Q.   Yes.

25             MR. KRGOVIC: [Interpretation] Your Honours, I intend to move onto

Page 24830

 1     my last topic, or one of the last topics in my examination, so perhaps we

 2     should take the break now so that the witness may have an opportunity to

 3     review the document.

 4             JUDGE HALL:  Very well.  We will take the break and return at

 5     12.25.

 6                           [The witness stands down]

 7                           --- Recess taken at 12.02 p.m.

 8                           --- On resuming at 12.46 p.m.

 9             JUDGE HALL:  When we took the adjournment a little before 12.05

10     and I said we would return at 12.25, I thought that the extra three

11     minutes would have been sufficient for the business that the Chamber knew

12     it would have to do.  We apologise to everyone for the inconvenience of a

13     break that has extended long beyond what we anticipated.  But we -- we --

14     we spent the time trying to solve a problem with which Mr. Zecevic is

15     immediately concerned.

16             It's in the process of being worked on.  Thank you.

17             MR. ZECEVIC:  I'm grateful to Your Honours.  Thank you.

18                           [The witness takes the stand]

19             MR. KRGOVIC: [Interpretation] Your Honours, I have 20 minutes

20     left to finish my examination.  As I have lost quite a lot of time to

21     clarify some issues, I would ask you for additional time until the end of

22     today's session, if possible, so that I could complete all the topics

23     that I have discussed until now.  That's about 40 additional minutes.  I

24     have talked to the Prosecution and Mr. Cvijetic and they do not oppose

25     this.

Page 24831

 1             JUDGE HALL:  Please proceed.  We would only ask your assistance,

 2     Mr. Krgovic, in getting the witness to focus on answers to -- you know,

 3     without wandering.  Thank you.

 4             MR. KRGOVIC: [Interpretation]

 5        Q.   Mr. Jankovic, I gave you these documents to read.  But before

 6     you -- before we get to the document I forgot that we need to clarify a

 7     few things in the transcript because we overlapped while speaking.

 8             You talked about your visit to Omarska, and as you were

 9     approaching Omarska, who was securing the part where the prisoners were

10     and also the road leading to Omarska itself?

11        A.   Well, I once saw when the telephone was repaired, that was my

12     second visit, around the building, there was a concrete slab that was 15

13     or 20 metres wide, perhaps from here to that wall, and the prisoners or

14     the detainees were all there.  It was really hot and they had a hose with

15     water, and they were splashing one another in order to cool down.  And

16     around that was a grassy field with a few trees and bushes, and young men

17     in military uniform were standing in the shade and they had light

18     machine-guns, M53, from the JNA.  These were light machine-guns with

19     ammunition.  They lay down.  And at the entrance were two such men.  And

20     as I was passing through, it was really unpleasant.  Two light

21     machine-guns would be pointed to you and I told them, Well, if anyone

22     made a disturbance now would you shoot?  And they said, Yes, of course,

23     we would.  And I said, Well, here I am.  And they said, Never mind, you

24     are together with the others.

25             And the light machine-gun, as the weapon, was something that did

Page 24832

 1     not exist among the weapons that the police had at its disposal.  It's a

 2     piece of combat equipment.  I know it from the JNA.  It was the army that

 3     had it.  Who these men belonged to, which unit, I don't know.  But I'm

 4     sure that they were not policemen, at least judging by their uniforms and

 5     by the weapons that they had.  I didn't analyse that any further so I

 6     don't know who they were and which unit they belonged to.

 7        Q.   Mr. Jankovic, when you talked about the meeting held in the night

 8     between the 29th and 30th, you mentioned something that has not been

 9     recorded.  How did the majority -- what did the majority of the people

10     wear?  How were they dressed?

11        A.   They were a motley crew, all sorts of uniforms, all sorts of

12     colours, camouflage, military, then the old olive-drab JNA uniforms, as I

13     said, then police uniforms that the reserve police forces had.  These

14     were the blue ones of poor quality.  There were active-duty policemen in

15     their own uniforms, so everything was represented.  I didn't count but

16     there were perhaps 150 or 200 men.  The police station itself couldn't

17     have had so many employees.  There were many others there.  Those were

18     those who were not uniformed, who were wearing civilian clothes.

19        Q.   Were there any army officers present?

20        A.   Yes, two officers came.  Everyone was looking for me and wanted

21     to get a Motorola.  I don't know who it was, a major by rank.  It was the

22     first time I saw him.  He asked for two radio sets and batteries.  I

23     asked him, Who are you?  And he said, I am a major.  Major, you're wrong,

24     I said.  I have no majors on my list.  I just have policemen.  And he

25     left and never looked for me again, but he didn't get what he wanted.

Page 24833

 1     These were the two officers.  There may have been others but these were

 2     the two that I noticed.

 3        Q.   Can you just tell us the rank of these officers?

 4        A.   The one who requested a Motorola was a major.  As for the other

 5     one, I don't quite remember.

 6        Q.   Mr. Jankovic, can you now please look at the document which I

 7     gave to you.  That is P00621.  I asked you to look at page 21 but I will

 8     ask you also to look page 20 before that.  That's the previous page.

 9     It's typed out, the page number 20.

10        A.   Yes, yes.

11             MR. KRGOVIC: [Interpretation] In e-court in B/C/S, it's page 43,

12     and also page 43 in the English version.

13             THE WITNESS: [Interpretation] I don't get what you said.  Page?

14             MR. KRGOVIC: [Interpretation]

15        Q.   No, no, it has nothing to do with you.  It's in the upper

16     right-hand corner page 20, and I'm interested in the second

17     paragraph from top.  It's the report from the centre which says:

18             "Inefficiency, lack of professionalism and superficiality of work

19     in a number of SJBs contributed to a large extent to the functional

20     detachment of a number of SJBs from the centre.  This has gravely

21     affected the overall unity and the social role of the security organs and

22     services.  Parallel to that, some of the SJBs connected themselves with

23     the local politics and local political leaders, thereby neglecting their

24     legal obligations and authorisations.  Namely, the top-ranked staff of

25     some SJBs, instead of keeping a highly professional attitude towards

Page 24834

 1     [sic] their work, occupied themselves with issues which are outside of

 2     their remit."

 3             And then - let me not read the whole paragraph:

 4             "Their intention was to avoid responsibility for what has been

 5     done and to lay it on others.  But various concessions have also been

 6     made under the influence of those organs and individuals at the expense

 7     of the service, that is to say, of the law ..."

 8             Mr. Jankovic, Mr. Zupljanin is here discussing certain

 9     occurrences.  What I read out to you from this paragraph, does this

10     illustrate the situation which existed in Prijedor?  In light of

11     everything I have read to you, does this correspond -- I apologise

12     because this is perhaps too long and suggests it was a leading question

13     so I will try to reformulate the question.

14        A.   You don't have to say anything.  I understood from what you asked

15     me and what you said.

16             MR. HANNIS:  I do have an objection, first, that it was leading

17     but also I think there's a lack of foundation for this witness to answer

18     the question so far.  In terms of what he's said about Mr. Drljaca, he

19     talked about how he really didn't have much dealing with him, that

20     Mr. Drljaca was cutting him out more and more, that he saw him meeting

21     with people unspecified as to who these people were.

22             Without some further foundation, I don't know that he is in a

23     position to express a meaningful opinion to you regarding this.  Unless

24     there's some further foundation laid.

25             JUDGE HALL:  And I confess, I've lost what the question was.

Page 24835

 1             MR. KRGOVIC: [Interpretation] I never asked it, Your Honours.  I

 2     just read this.  And when I saw Mr. Hannis on his feet, then I could see

 3     that the first half of the question was not satisfactory so I stopped

 4     before asking the question.

 5        Q.   Mr. Jankovic, there is an assessment given in this report by

 6     Mr. Zupljanin.  Can you tell me, when we talk about Prijedor and the

 7     relations and how everything functioned, can you comment for us on the

 8     situation in Prijedor in terms of the relations between the Security

 9     Services Centre and the public security station in Prijedor?

10        A.   Let me first tell you that I read this, and I thought about this

11     while I was sitting in that room over there.  What is written here, what

12     I can see here, is -- was much, much worse in Prijedor - I don't know

13     about other places - than as it is stated here.  Yes, that was the

14     character of things but it was much worse in Prijedor.

15             And let me tell you what I said and what Mr. Prosecutor, who is

16     to the right of me, said, that I was left out.  It was not just me.

17     Everybody else from the town was present all along and they felt that in

18     a thousand ways.  One could feel that there was anarchy and many

19     individuals had a wish mainly to become rich and to do other things that

20     were not allowed.  There were policemen who abused their positions, who

21     imposed conditions.  For example, what a policeman could have used, they

22     would help someone who wanted to flee not to do it in a legal manner.  If

23     people wanted to move out and go to Europe or somewhere.  It is known now

24     what the way to do that is.  You need to have a travel document and so

25     on.  So a policeman would use the uniform and the official ID and

Page 24836

 1     everything.  He would take money from the person, drive him through ten

 2     police check-points, and they would let him pass.  So this was a well

 3     worked-out system.  It wasn't something that was not visible.  The

 4     citizens could see it and feel it on their own skin.  And Mr. Zupljanin

 5     writes here about that, inter alia.  But, still, let me know -- let me

 6     not be too extensive but it's the same like when I told you about what

 7     was in the previous document.

 8             This is how the superiors used to write that even previously, but

 9     previously you would have five criminals in two groups and there would be

10     an activity carried out by the group, and now it was the other way

11     around.

12             Five per cent of people were not criminals, and now the question

13     is how efficient the service can be.  We can see from his attempts and

14     how he tried hard and he wanted to rectify the situation and one cannot

15     say that there were no results.  Unfortunately, although on the other

16     hand, luckily, the situation did not last too long, nothing much could

17     have been done, and I wish that Simo had informed me in a better way

18     about this.

19             So would you like to hear something more about this?

20        Q.   When we talk about reporting, it says here that:

21             "Regularly a number of SJBs are ignoring the requests from the

22     CSB to address certain issues, that is to say, that the requests from the

23     centre remain unheeded, which jeopardises the unity and -- of the organs

24     as a single security mechanism.  Under such circumstances it is difficult

25     to keep the total security situation under control, to evaluate and make

Page 24837

 1     valid security estimations at the level of the region and the republic."

 2             Mr. Jankovic, while you were working as a communications officer

 3     at the communications centre, you knew, given the quality of the

 4     communication equipment that you had and the quality of the people that

 5     you had working in the centre, how did this process of exchange of

 6     information between the SJB and the CSB go?

 7        A.   I told you a minute ago when I spoke about political illiteracy,

 8     every member of the centre from the lowest level to the highest level

 9     should have known how to receive the tasks and how to write reports.

10             THE INTERPRETER:  Could the witness please start all over again.

11             THE WITNESS: [No interpretation]

12             JUDGE HALL:  Sorry, did the witness hear the interpreter's

13     request?

14             MR. KRGOVIC: [Interpretation]

15        Q.   Please, since the interpreters didn't manage to follow what you

16     were saying, can you please repeat your answer that you gave to me.  I'm

17     sorry, we didn't get an interpretation, so can you please repeat what you

18     told us about the process of sharing information, et cetera.

19        A.   I cannot give you a precise answer to your question, but since I

20     spoke about this topic many times in the past, when I gave statements to

21     the Prosecution and elsewhere, maybe can you find it there.  Maybe you're

22     referring to that.  I'm going to repeat what I said before.

23             I said there were many things there involved, and I'm going

24     enumerate them.

25        Q.   Please slow down.

Page 24838

 1        A.   All right.

 2             Initially, people didn't know that they had to report, so they

 3     failed to report.  Report to whom?  Report to your superior.  Not only

 4     report but send him proper information and reports.

 5             After this, the senior officers knew that they had to report, but

 6     they didn't have any interest of their own, because they had their own

 7     private vested interests not to do that, including some internal policies

 8     that were detrimental to the service itself.

 9             Now, what does this have to do with communications system?  Well,

10     it has a direct link with this, because that was the worse time for the

11     communications system, due to the lack of power, due to the lack of spare

12     parts and faulty equipment.  However, even when there was communication,

13     people would resort to such excuses by saying, You know, Boss, I tried to

14     get in touch with you but the communications system was down and I failed

15     to send you a report.  What I'm trying to say, people were trying to

16     blame the communications system for everything because that was the most

17     convenient excuse that they could have resorted to when they wanted to

18     evade something.

19             Now if this is the answer to your question regarding the

20     communications system, fine.  If you need additional information, please

21     tell me so.

22        Q.   Mr. Jankovic, there is some ambiguity in the interpretation here.

23     You said when somebody wanted to evade something.  Who was it who wanted

24     to avoid sending a report?

25        A.   Every member of the police from the lowest level up to the level

Page 24839

 1     where Simo was; I'm talking about Prijedor only.  I'm not going into the

 2     ministerial levels.  If there was a need for him to deceive his superior,

 3     they found a cunning way of blaming the communications system for such

 4     failure.  I'm not inventing this.  For example, there was a policeman who

 5     simply would cut off the cable of the microphone or to cause a shortcut

 6     to occur.

 7             As the head of this department, I introduced a rule in order

 8     to -- to stop this.  For every device that is being brought to us to be

 9     repaired, if some malfunction happened normally, then the technicians

10     would fix it.  However, if it was damaged, then the policeman, through

11     his commander, should report to me and should confirm whether this was

12     damaged on purpose or not.  I'm talking about ordinary police officers,

13     but even the bosses were not immune from that.  If they wanted to find

14     some kind of excuse, they would say, Oh, the system was down.  Maybe this

15     was due to some totally mundane and trivial reasons, but that's how it

16     was.  But I didn't try to fight this when it comes to those senior

17     officers, as I did try to find -- fight this practice with the ordinary

18     policemen.

19        Q.   Mr. Jankovic, after the outbreak of hostilities and the

20     commencement of fighting in Prijedor, can you tell us what the

21     communications was like in Prijedor.  What did you have at your disposal?

22     What kind of communications devices did you have?

23        A.   When?

24        Q.   After the outbreak of hostilities and all these events and the

25     takeover of power.

Page 24840

 1        A.   Well, as these tumultuous times proceeded, the system was not

 2     harmed too much.  However, it was persistently being hampered by the loss

 3     or disappearance of devices.  But for the most part, the most harming was

 4     that of the power outages.

 5             In that period, as far as the operations activities were

 6     concerned, there was a VHF [as interpreted] radio communication.  It

 7     shouldn't be VHF.  If you want to have it in English, it should be UHF.

 8     Not very high frequency but, rather, ultra high frequency, UHF.  All

 9     right.  So we had this UHF system for operative purposes, and for the

10     transmission of written information, we still used teleprinters with

11     their in-built crypto protection systems and all the devices that go with

12     it.  However, now, the flow capacity of those systems was dramatically

13     reduced.  Why?  Because of the lack of electricity supply.  Secondly,

14     this system used transmission routes of the general telecommunications

15     system, what we used to call the post and telegraph and telephone.  And

16     we were simply just users of some of their channels.  And once those

17     channels are cut off, we lose them as well.

18             Now that given that much, much earlier, before we faced these

19     difficulties, we had a communication line between Prijedor and the

20     neighbouring municipalities such as Sanski Most, Bosanski Novi, and

21     Bosanska Dubica.  Then we had a connection upwards, hierarchically

22     speaking, that is towards the Banja Luka centre, and then further on

23     towards the republican MUP.  That was a normal state of affairs, and

24     nobody changed anything in that organisational system.

25             Now, with the emergence of all these difficulties, the damage to

Page 24841

 1     the channels that we experienced, some experienced more problems, other

 2     experienced fewer problems, the connections with Banja Luka was partly

 3     operational, but as soon as we were cut off from electricity supply, or

 4     if the post office was affected in the same way, then everything breaks

 5     down.

 6             However, as for Sarajevo, that was a long way away.  There were a

 7     long [as interpreted] of channel joints and connections there, and I

 8     don't think that later on, nobody even bothered to try to send any

 9     dispatch.  Maybe at the beginning, but later, never.  We used fax

10     machines to convey and relay written information because we still had a

11     telephone line operational, surprisingly.  So it was somewhat difficult

12     to pass on information to the republican SUP somewhere in Sarajevo, or

13     close to Sarajevo, Pale, I presume, but I know that, as for Banja Luka, I

14     can't give you the exact percentages, because it went up and down.  The

15     volume of communication was reduced, and the exchange of information was

16     getting more and more difficult.

17        Q.   In comparison to the pre-war period, before the conflict, and if

18     you compare the number of incoming and outgoing messages, what was the

19     percentage of the successfully transmitted outgoing messages in that

20     period?

21        A.   I don't know.  It varied as well.  You know how it is.  Before,

22     in peacetime, we could manage to send the dispatch very quickly.  People

23     were entitled to have eight hours to do that but they would do it

24     immediately.  Now, however, there was a two- or three-day's delay for

25     even those of the most important dispatches.  It was impossible to send

Page 24842

 1     them.

 2             There was one dispatch, for example, that I myself saw.  It was

 3     shown to me by a gentleman from the OTP when I gave statement to them,

 4     and there's my signature on that dispatch as well.  And it speaks volumes

 5     about what I'm talking about now.  And if you can find it, I can comment

 6     on it, and it really speaks a lot about the question that you have just

 7     asked me.  I don't know the contents of it.  But I know that there's my

 8     signature there and it's circled.  This dispatch would be immensely

 9     helpful in answering the question that you asked me --

10        Q.   Tell me, Mr. Jankovic, concerning the links with other centres

11     that ran over the territories that were controlled by the Muslims, was it

12     possible to use them?

13        A.   These communication lines towards Banja Luka travelled entirely

14     over the Serb-controlled territory.  Therefore, there was no trouble in

15     that respect.  There were, however, some cables that, for example, were

16     laid next to the railway tracks and for a period of time, this cable was

17     damaged so we have to -- had to use a bypass connection.

18             Now, as for the links with Sarajevo, only God knows how it

19     happened.  I don't know how it operated.  Vlasic was one of the hubs and

20     I know that there is a repeater at Mount Vlasic and I think, for a time

21     at least, it was in the Serb hands, maybe I'm wrong.  But there are other

22     summits that were never in the Serb hands.  You know, war has changed all

23     the routes that existed before.  I wasn't involved in that, but other

24     people know about that.  The only open communication line we had at the

25     time was via fax.

Page 24843

 1        Q.   You said that all these routes disappeared.  It was not recorded.

 2     What did you mean by that?

 3        A.   Well, I meant that the whole of Bosnia-Herzegovina was covered by

 4     a proper network of communication lines that the police used before the

 5     war.  However, at various places, various things happened, such as

 6     fighting, or this, or that, which would damage one communication link.

 7     It becomes severed.  Then they tried to find another route.  So

 8     eventually there were so many severed links that we were virtually cut

 9     off, except for the fax, as I told you.  I related this to the people

10     from the ATP.  There was just one case, where a fax was sent to

11     director -- just tell me -- I'll tell you briefly about this.

12        Q.   There's no need to go into that.  We've already explored this

13     area.

14             Tell us, were there difficulties experienced with that particular

15     line as well?

16        A.   Which line?

17        Q.   The fax line you referred to.

18        A.   Well, it so happened that it was impossible to get the number

19     that you dialed.  It required perseverance.  At times, it took 20 minutes

20     to get connected, and at times, it was impossible.  You'd dial a number,

21     and the line would be silent.  And, thus, for many more attempts, until

22     you get the line.

23        Q.   If my understanding is correct, you say that, in order for the

24     communications system to be up and running, you had to have electricity

25     to power it.  What was the situation in terms of power supply in

Page 24844

 1     Prijedor?

 2        A.   There were frequent power outages.  The longest period we went

 3     without any power was 40 days.

 4             Now the post office had its own power generator.  I improvised

 5     and made a makeshift system that hooked onto that generator.

 6        Q.   I have very little time left so can you please be brief.

 7        A.   Well, as I said, it would so happen that we have power at times;

 8     at others, we didn't.  It was in stops and starts.  That's how it went.

 9     The same was true for the spare parts that we had a shortage of.  There

10     were difficulties from every quarter.  I didn't keep an exact record of

11     how many dispatches were able to be transmitted.  On average, I could

12     tell you that one-third of transmissions were successful.  But that's

13     just a rough estimate on my part.  This was largely due to the fact that

14     many of the links that had been operational before did not work anymore.

15        Q.   You're talking about the system of dispatches, of telegrams, in

16     fact.  What was the procedure applied as soon as a dispatch arrived at

17     the MUP, where would it go before it reaches the person it was addressed

18     to?

19        A.   You mean in the MUP?

20        Q.   Yes.

21        A.   If a dispatch arrives in, you can tell whether it's open or

22     protected.  That's to say, coded.  If it's coded, then the communications

23     officer would decode it.  There were four ledgers or books.  You had open

24     dispatches received; protected dispatches received; open dispatches

25     transmitted; coded dispatches transmitted.  So if you receive a dispatch

Page 24845

 1     you look at whether it is open or protected.  Then you place it in the

 2     appropriate ledger.  It goes with the filing service.  They will file

 3     exactly the time and date of arrival.  And that's -- and then it's handed

 4     over to the person it's addressed to.

 5             Likewise, if you have an outgoing dispatch, then you have the

 6     person bringing in the dispatch to the service.  It's filed in the book.

 7     The communications officer places his signature to prove that he has

 8     received it.  He transmits it on.  And his job is done.

 9             Now, the form of the dispatch, let's say you have -- you have a

10     dispatch that comes in.  You send it, you transmit it.  And then the

11     communications officer would not keep it with him unless there was a

12     correction coming from the other end.  And then if there's no such

13     correction, he would merely return it to the person who brought the

14     dispatch in to be transmitted.

15        Q.   Let's go back to the books or ledgers that you mentioned.  Or the

16     filing books.  Were they books belonging to your department?

17        A.   Well, yes.  You see, the communications system was organised in

18     such a way that we had books, the pages of which were of a specific

19     format.  For instance, Sh 19, Sh 12, those were specific forms and they

20     had different columns.  Columns for dispatches received; for dispatches

21     transmitted, et cetera.  They conformed to the rules introduced by the

22     JNA.  You see, the cryptographic data protection that a country would use

23     would be normally the one chosen by the army.  Of course, we only used a

24     part of the system.  The system was partly also used by embassies, for

25     instance.  So we were given these rules by the JNA and had to adhere to

Page 24846

 1     it in our work, and this applied to the books as well.

 2        Q.   Mr. Jankovic, can you tell us, was there an obligation to store

 3     these books; and, if so, for what periods of time, for how long?

 4        A.   The coded books were supposed to be kept for up to a year.  And

 5     the open ones would be destroyed upon the expiry of six months.  You see,

 6     these books be used up very soon.  Normally, you wouldn't destroy a book

 7     that hasn't been filled.  If it is only half full, then you'd probably

 8     use it again for the next time-period.  Or, if it is almost full, then

 9     you'd destroy it and take a new book.

10             We drew up reports, as at the 25th of December, that was the

11     date, the cut-off date, and that was normally then the date when we

12     changed all these things.  Of course, you also had reports for the

13     trimester and half year.

14        Q.   Tell us, was this standard procedure which was applied both in

15     the pre-war and the post-war periods?

16        A.   Yes.  That procedure was in place before my arrival there.  I

17     applied it.  It was used in peacetime.

18             These books are not taken anywhere normally, so you can't really

19     misplace them.  They're always on the desk or kept in a safe.  Of course,

20     it wouldn't be just the books that would be kept in a safe.  You'd have

21     coding material there.  And then if you've got up to 15 books in there,

22     you wouldn't be able to fit anything else.  And you were then forced to

23     destroy them, of course.

24        Q.   Mr. Jankovic, lastly, tell me this:  At the start of your

25     testimony, I asked you about the sightings of Mr. Zupljanin in 1992.  So

Page 24847

 1     did you see him anywhere in Republika Srpska in 1992, as you assumed your

 2     duties there?

 3        A.   Yes.  It was in the month of November, as we were heading for

 4     Orasje.  Or, actually, it was November -- well, I don't know the date.  I

 5     think it was November.  It was an organised trip.  We had the police

 6     force from Sanski Most, Dubica, Prijedor, Banja Luka, Gradiska.  There

 7     were many of us.  We gathered in Banja Luka.  If I remember correctly,

 8     there were three battalions that constituted the brigade.  We gathered

 9     near the Borike hall and set out for Obrovac.  So I saw him there.

10             He reviewed the forces there, and it seemed to me that he handed

11     over us, so to speak, to the army Colonel Peusic or Peulic.

12        Q.   Can you tell us how this was done?

13        A.   Very well --

14             MR. HANNIS:  I have an objection.  This is a subject matter

15     that's not listed in the 65 ter summary anywhere.  So I haven't had any

16     preparations to cross-examine about this or any notification that he was

17     going to be talking about this with this witness.

18             MR. KRGOVIC: [Interpretation] Your Honours, when I provided my

19     proofing note, I did give notice of this because Mr. Jankovic testified

20     in the Stakic case and gave a statement on these issues to the

21     Prosecutor.  And I did say that he was going to be testifying to all the

22     matters that he mentioned in his interview.

23             Therefore, the Prosecution were on notice of what his testimony

24     would be about.  This is part of his interview.  I didn't mention it

25     specifically, but I did make reference to the interview.  And there are

Page 24848

 1     just two issues in connection with this.  He said that he saw

 2     Mr. Zupljanin twice in 1992, and I'm merely asking him to tell me about

 3     the circumstances of these two occasions.

 4             MR. HANNIS:  I'm sorry, Your Honour.  The proofing note is four

 5     paragraphs.  And it says he was shown a transcript of his interview and

 6     his testimony, and he confirmed the accuracy of his statement and the

 7     testimony regarding matters pertaining to Mr. Zupljanin.

 8             But there's no indication about being involved or handing over,

 9     something that goes to the issue of subordination, I assume.  It's been a

10     hotly contested issue in this case and certainly that something that

11     should have required further specification than is in this proofing note.

12             JUDGE HALL:  Mr. -- Mr. --

13             THE WITNESS: [Interpretation] May I say something?

14             JUDGE HALL:  Mr. Hannis, in any event, to the extent that you --

15     as you plead, you haven't been prepared for this, but having regard to

16     the length of time that you have available for cross-examination, no

17     doubt you would be able to put yourself in the position to deal with the

18     two issues that Mr. Krgovic has indicated he wishes to pursue.

19             So please --

20             MR. HANNIS:  I agree, Your Honour.  But I just want to put on the

21     record as a matter to maybe be aware of with regard to future witnesses,

22     and the fact that this is the last matter he is bringing up with this

23     witness suggests it's something that is very important to him because we

24     good trial lawyers try to start with our best and finish with our best.

25     So this was an important matter and certainly important matters are ones

Page 24849

 1     that deserve to be brought to the attention of the other parties in this

 2     kind of notification.

 3             JUDGE HALL:  Please proceed, Mr. Krgovic.

 4             MR. KRGOVIC: [Interpretation] Your Honour, if I may respond.  The

 5     last time we discussed the police brigade, Ms. Korner said that it was

 6     not an issue in dispute, that the brigade was subordinated.  So I did not

 7     see that this was a matter of contention between the sides, that the

 8     police brigade was resubordinated to the army.

 9             I didn't mean to speak about resubordination at all.  Rather,

10     about him seeing Zupljanin.

11             JUDGE HALL:  Let's get on with it, please.

12             MR. KRGOVIC: [Interpretation]

13        Q.   Mr. Jankovic, can you please describe for us what it was that

14     Mr. Zupljanin said when you got there and what comments, if any, your

15     colleagues had?

16        A.   Well, I just wanted to correct myself.  I said that this was him

17     handing us over.  I chose the word because of the authority that he had.

18     When I spoke to the Prosecutor, I did not choose words properly, so I

19     said you know how it happened.  Mr. Zupljanin brought along a colonel,

20     I'm not sure what his name is.  This should be double-checked.  I can't

21     recall it now even.  I just said it a moment ago.

22        Q.   Peulic.

23        A.   Yes, Peulic.  It would not have been important to me had it not

24     happened that, in that brief introduction that Mr. Zupljanin gave of this

25     colonel, he didn't say, I will not proceed from this place with you.  I

Page 24850

 1     had not go with you to Orasje.  Rather, it will be a colonel of our army.

 2     And then he wanted to commend him and he said, He is a senior officer who

 3     never lost a single battle.  And then somebody called -- somebody among

 4     the three battalions jeered and said, And never won a single battle

 5     either.  So that's why it stuck in my mind.

 6             So we didn't linger there.  We boarded the buses and set off for

 7     Orasje.  If that's enough for your purposes.

 8        Q.   So that was the second time you saw Mr. Zupljanin.  And, later,

 9     in 1992, save for --

10        A.   Yes, yes.  I saw him.  He accompanied the column, but just

11     outside of Modrica the column stopped, and Mr. Zupljanin got on our bus.

12     I didn't even know he was going to accompany us.  He asked if anybody

13     knew which road should be taken from thereon.  Everybody was silent.  And

14     then I spoke because I said that I hailed from the area.  He told me, So

15     why are you silent?  Why aren't you telling me anything?  And then I

16     said, Well, I know which roads we should take, but I don't know which

17     area was under whose control.  There were Serbs and Croats there in the

18     area.

19             But it so happened that I went into his vehicle.  He stayed

20     behind on the bus, I believe, Zupljanin did.  I went into his car, driven

21     by a soldier, and there was this colonel in the car as well.

22             So I directed them to take the road that I thought was best and

23     nobody attacked us, and we reached that village of Obrovac.  I never saw

24     him again.  I was there for a month and I was in the staff of the

25     Prijedor Battalion, the commander was Simo Drljaca.  I was the

Page 24851

 1     communications officer.  I spent my time in the headquarters, and he

 2     could not possibly have visited there without me seeing him.

 3             So for that month that I was there as a communications officer in

 4     the headquarters, he never showed up.  Peulic was in command of the

 5     brigade and Simo -- oh, let's me just say, briefly, that the entire

 6     organisation behind it all was military.  So brigades, battalions,

 7     companies, platoons.  There were some tanks attached by the army.  I

 8     think two of them.  And the Pragas; I think the anti-aircraft assets.

 9     Armoured vehicles and a battery of mortars.  That's not the sort of

10     weapons that the police would have by their establishment.  They even had

11     their own uniforms, those who were there with us.  And that's it.

12        Q.   Thank you, Mr. Jankovic.  That's all I had for you.  I have no

13     further questions.

14             MR. KRGOVIC: [Interpretation] And thank you for the extended time

15     granted to me.

16             JUDGE HALL:  Thank you.  So we will take the adjournment for the

17     day.

18             And, Mr. Jankovic, when we resume tomorrow morning, counsel on

19     behalf of the co-accused, Stanisic, would have their questions of you,

20     and then Mr. Hannis will begin his cross-examination.

21             So we rise, to resume at 9.00 tomorrow morning.

22                           [The witness stands down]

23                            --- Whereupon the hearing adjourned at 1.41 p.m.,

24                           to be reconvened on Wednesday, the 12th day of

25                           October, 2011, at 9.00 a.m.