Tribunal Criminal Tribunal for the Former Yugoslavia

Page 24852

 1                           Wednesday, 12 October 2011

 2                           [Open session]

 3                           [The accused entered court]

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

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

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

 7     the Prosecutor versus Mico Stanisic and Stojan Zupljanin.

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

 9     everyone.

10             May we have the appearances today, please.

11             MR. HANNIS:  Good morning, Your Honours, for the Prosecution I'm

12     Tom Hannis, along with Gerard Dobbyn and Sebastiaan van Hooydonk.

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

14     Slobodan Cvijetic, and Ms. Deirdre Montgomery appearing for

15     Stanisic Defence this morning.  Thank you.

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

17     Miroslav Cuskic appearing for Zupljanin Defence.

18             JUDGE HALL:  Thank you.  And if there are no preliminary matters,

19     may the usher -- would the usher please escort the witness back to the

20     stand.

21                           [The witness takes the stand]

22             JUDGE HALL:  Mr. Jankovic, good morning to you.  Before --

23             THE WITNESS: [Interpretation] Good morning.

24             JUDGE HALL:  -- counsel for Mr. Stanisic begins his

25     cross-examination, I remind you you're still on your oath.

Page 24853

 1             Yes, Mr. Cvijetic, is it?

 2             MR. CVIJETIC: [Interpretation] Thank you, Your Honour.

 3                           WITNESS:  MILOS JANKOVIC [Resumed]

 4                           [Witness answered through interpreter]

 5                           Cross-examination by Mr. Cvijetic:

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

 7        A.   Good morning.

 8        Q.   I will start my examination proceeding from your answer to my

 9     learned friend Mr. Krgovic's question which is at page 24842 of

10     yesterday's transcript.  Mr. Krgovic asked you about the difficulties you

11     had in receiving and transmitting dispatches in the period you discussed

12     yesterday, and I will read just a part of your answer from the

13     transcript.

14             [As read] "For instance, there is one dispatch that I saw, it was

15     shown to me by the gentleman from the Prosecution when I was giving them

16     my statement.  My signature can be found on that dispatch?"

17             And you go on to say the dispatch speaks of the scope of what I'm

18     discussing now and it would be the best illustration of what I'm saying.

19     Do you recall what you said yesterday?

20        A.   Yes.

21        Q.   So do you recall that this is precisely what you told colleague

22     Krgovic yesterday?

23        A.   Yes.

24        Q.   Very well.  I'll show you the dispatch.  It's an exhibit.  It's

25     P668.  I need page 1 in both versions.  Yes.  That's what we need.

Page 24854

 1             Mr. Jankovic, let me ask you first, is this the dispatch you were

 2     discussing yesterday?

 3        A.   Yes, this is the one I had in mind.

 4        Q.   Please pause before answering.

 5        A.   Yes.  This is the dispatch I had in mind.  Yes.  It is a good

 6     copy.  You can read it.

 7        Q.   Well, I have a hard copy if you want to have it.

 8        A.   Yes, please, it would be much easier.  If you don't mind.  It is

 9     a bit tiring to read from the screen.

10        Q.   I would like to clarify a point from this dispatch.  So is this

11     the dispatch, please confirm that?

12        A.   Yes, that's the dispatch.

13        Q.   And this is the dispatch shown to you by the Prosecution during

14     the interview; right?

15        A.   Yes, and that's where I remember it from.

16        Q.   Tell us, we have a signature in handwriting.  Whose is it?

17        A.   That's my abbreviated signature.

18        Q.   Mr. Jankovic, there is a note on the dispatch indicating that it

19     was impossible to transmit it to the first two addresses, i.e., the MUP

20     of the Serbian Republic of Bosnia and Herzegovina and Army of the

21     Serbian Republic of Bosnia and Herzegovina.

22        A.   Yes, yes.

23        Q.   And there's a bracket there and one Goran signed it?

24        A.   Yes.

25        Q.   This is my question:  Were these precisely the difficulties that

Page 24855

 1     you were referring to, namely, in this case, you weren't able to transmit

 2     dispatches to the MUP at Pale and the army?

 3        A.   Yes, that's precisely why I cited this dispatch.

 4        Q.   Very well.  You no longer need to look at the dispatch because I

 5     will be putting questions of a general nature to you now.

 6        A.   Can I just add something?  The reason, in fact, why I referred to

 7     the dispatch.

 8        Q.   Well, perhaps I'll ask you about it in some of my questions.

 9     But -- right.  Go ahead.

10        A.   I'll try to be as brief as possible.  The contents don't matter.

11     I will not be talking about them.  I saw the dispatch for the first time

12     when it was shown to me by a gentleman from the Prosecution, otherwise I

13     would have long forgotten about it.  It speaks very clearly to the issues

14     we were discussing, namely, the quality of the communication links,

15     et cetera.  Look at what it says at the top "dx open" and then circled

16     and then a "sh" is added and then my signature.  "Open" or "sh" stands

17     for the status of confidentiality of the document and it would normally

18     be indicated by the author of the document.  Apparently the author of

19     this particular document - and it is Simo Drljaca who signed - wasn't so

20     privy to these rules and didn't put it properly.  And then the operator

21     who transmits dispatches and makes corrections where they are needed in

22     this case contacted me and ask that the designation of confidentiality be

23     changed, in other words, that it not be an open dispatch but that it be

24     coded and that's why I made the correction that you can see here.

25             There are three addresses to which the dispatch is supposed to be

Page 24856

 1     transmitted, namely, the MUP of the Serbian Republic of

 2     Bosnia-Herzegovina, Army of Republika Srpska, and the CSB in Banja Luka.

 3     The communications operator, one Goran, indicated that we were unable to

 4     send the dispatch to the two first addresses.  Now, the CSB which was

 5     closest to us in terms of communication links was reached and the

 6     dispatch was sent.  The handwritten note contains a date, the 18th, or

 7     rather, 1840 Rodic and then the 3rd of August at 10.00 Milan.

 8             It was standard procedure that dispatches designated as "dx"

 9     would be sent no later than within two hours, whereas in reality they

10     would be sent right away.  However, this dispatch indicates that the

11     dispatch was sent two days later, which indicates the length of time that

12     the dispatches had to be delayed before they were sent and in certain

13     circumstances it really defeated the purpose of the dispatches to begin

14     with, but that was the circumstance prevailing at the time.  That's it.

15        Q.   And at times you, or rather, you've just anticipated my next

16     question.  The teleprinter system, the telex system with the various

17     coding and confidentiality designations constitute the basis of the

18     workings and the running of the Ministry of the Interior; is that right?

19        A.   Yes.

20        Q.   Mr. Jankovic, it was precisely that system which failed to

21     operate for most of 1992 and in most of the areas in Bosnia-Herzegovina,

22     even locally; would you agree with me?

23        A.   Yes, but I cannot speak in greater detail about the links outside

24     of the routes between Prijedor, Banja Luka, and Sarajevo.  I wouldn't be

25     able to speak about them with any certainty.

Page 24857

 1        Q.   Let me take you back to your yesterday's evidence.  You spoke of

 2     your deployment to the front line as part of that unit.  Do you recall

 3     talking about it as part of that police unit?

 4        A.   Yes.

 5        Q.   In that role of yours, you also dealt with communications; is

 6     that right?

 7        A.   Yes, solely with communications.

 8        Q.   But at the time what you were doing had a military purpose, did

 9     it not?

10        A.   The way this combat unit was organised was that it was part of a

11     military organisation.

12        Q.   Let me follow-up this answer of yours with this question.

13     Members of the Prijedor public security station would, as part of these

14     military purposes, be deployed to other front lines, not just this one;

15     is that right?

16        A.   Yes.

17        Q.   On occasions such as these, would they be part of the

18     communications system of the public security station in Prijedor, i.e.,

19     would they have been in communication with you?

20        A.   No.

21        Q.   I will show you two more documents now to support some of your

22     answers of yesterday.

23             MR. CVIJETIC: [Interpretation] Can we call-up 65 ter 616D1.

24        Q.   Mr. Jankovic, if you need a hard copy for your easier perusal --

25        A.   No, it's all right.  I can read it off the screen.

Page 24858

 1        Q.   Please read it to yourself and then I'll put questions to you.

 2        A.   The contents?

 3        Q.   Yes.  It's a short document.

 4        A.   I've read it.

 5        Q.   Mr. Jankovic, yesterday you said that, locally, members of the

 6     public security station would receive their salaries and the equipment

 7     they needed from the local level; is that right?

 8        A.   Yes, and this document confirms it.

 9        Q.   We can tell that the document is of the 16th of June.

10        A.   Yes.

11        Q.   Can you tell us how long this situation prevailed?

12        A.   I don't know.  Not just a couple of days.  At least the entire

13     summer, perhaps through to the end of the year.  Anyway, throughout that

14     period.

15        Q.   Can you recognise the signature at the bottom?

16        A.   No.

17        Q.   And can you read the signature block?

18        A.   Well, it says Milomir Stakic, president of the municipality, but

19     I don't recognise his signature.  I don't know if it's his.

20        Q.   But in general, were you aware that Simo Drljaca, Ranko Travar

21     dealt with salaries, uniforms, and everything else in co-operation with

22     the Crisis Staff.  Were you aware of this?  You did speak about it

23     yesterday.

24        A.   Well, I can tell you all of us worried about whether we would be

25     paid our salaries and we would talk about it amongst ourselves that the

Page 24859

 1     municipality had set aside funds for this purpose, that a salary would be

 2     forthcoming, et cetera.  As for uniforms, there were uniforms that were

 3     procured, but I don't know who paid for them.  I can only assume that

 4     they came from that quarter, whereas I am certain that this was the case

 5     with salaries.

 6             MR. CVIJETIC: [Interpretation] Your Honours, I don't know how

 7     come this document hasn't been admitted yet and I don't see any other way

 8     of admitting it than through this witness.  The witness spoke in great

 9     detail yesterday about payments and the supply of uniforms.  So I do

10     believe that we have passed the threshold required for the admission of a

11     document.  I think it is helpful for the case in general and it's helpful

12     for some of the submissions that the Defence will be putting in our final

13     brief.  So I please -- I would like to tender this document, please.

14             MR. HANNIS:  Your Honour, I have an objection or two.  The fact

15     that may be helpful to Defence submissions is not a reason for admitting

16     it.  The witness says it says Stakic but he doesn't recognise his

17     signature.  At most it says there was a conclusion that Mr. Drljaca and

18     two others were charged with making a comprehensive review of the

19     possibilities but there's no indication from this witness or any other

20     evidence so far that a review was done or what happened.  So I don't know

21     what it adds to the witness's testimony at this point and he is not able

22     to establish the foundation for the authenticity of this document.  And

23     it has limited relevance.

24             JUDGE HALL:  Mr. Cvijetic, do you have a response?

25             MR. CVIJETIC: [Interpretation] Your Honour, the witness described

Page 24860

 1     how things worked in practice and this document confirms it quite

 2     clearly.  There's not a shred of doubt about the authenticity of this

 3     document, contrary to what the Prosecution are saying.  This is an

 4     official document received from the Prosecution.  It is not a Defence

 5     exhibit.  I mean, we are tendering it but we received it from the

 6     Prosecution.  There are no doubts about its authenticity, and as for the

 7     contents, well, the witness did speak about that.  So I believe that's

 8     the foundation for the admission of the document.

 9             THE WITNESS: [Interpretation] Can I say a word or two?

10             JUDGE HALL:  I would prefer you to -- not to volunteer evidence.

11     If counsel has a supplemental question, he may proceed.

12                           [Trial Chamber confers]

13             JUDGE HALL:  The document is admitted and marked.

14             THE REGISTRAR:  Exhibit 1D813, Your Honours.

15             MR. CVIJETIC: [Interpretation] Thank you, Your Honour.

16        Q.   Mr. Jankovic, I'll show you another document which is an exhibit.

17     We will have no difficulty there.  It's P803.

18             MR. CVIJETIC: [Interpretation] Can I have the usher's assistance

19     to give the document to the witness.  It may be easier for him to read

20     this way.

21        Q.   Please read it to yourself and then I'll put my question to you.

22     I'll give you three to four minutes.

23        A.   I've read it.

24        Q.   First of all, Mr. Jankovic, did you know that there was a special

25     unit in town, an intervention platoon of this kind, as it says in the

Page 24861

 1     document?  Did you have the opportunity to see these people?

 2        A.   No, I cannot recall seeing anything of the kind that is described

 3     here.

 4        Q.   As you can see, it states here that this was formed by the

 5     Crisis Staff.  Can you confirm that?

 6        A.   I don't know that.  This is at another level that has nothing to

 7     do with me, so I really don't know anything about that.

 8        Q.   Thank you.  So my question has to do with your work.  This, or an

 9     intervention unit of this kind, was it in the communications system of

10     the public security station and did it have anything to do with you and

11     did you provide communication means?

12        A.   No.  There was an intervention platoon that was called that way

13     in unofficial talk, and I can see here that it refers to personnel from

14     existing police forces.  Carry out from the existing police forces.  But

15     I didn't know anybody from that so-called intervention platoon.  I knew

16     them but outside of the service that Zigic, he was there but he was never

17     in the service.

18        Q.   You said from the military and the police?

19        A.   That's what it says here, paragraph 2, that's what it says, from

20     the police and the army.  I didn't know those people.  They were not from

21     the police thus.

22        Q.   So the essence is that they were not from the police and they

23     were not in your police system of communication, yes or no, I mean answer

24     please whether they were in your system?

25        A.   To be quite clear, they were not in our system.

Page 24862

 1        Q.   Thank you.  And finally, Mr. Jankovic, now when we look at this

 2     order together from which we can see that the Crisis Staff is forming

 3     some sort of special unit over there that had nothing to do with the

 4     public security station, and we can see that salaries for the police were

 5     being -- and for uniforms were being provided at the local level.  It

 6     seems then that Prijedor - when I say "Prijedor," I mean the Prijedor

 7     authorities - was quite independent in relation to the rest of

 8     Republika Srpska.  Do you share this view?

 9        A.   Well, the question is a little bit unclear to me, but as far as I

10     understand I can just repeat what I said yesterday.  Simo didn't really

11     pay much attention to these others except for those that had brought him

12     there and that's the municipal authorities.  I'm sorry, I apologise --

13        Q.   I'm going to ask you directly.  From these documents that I have

14     showed you -- I apologise.  Or actually, I want to clarify my question.

15     When you actually say that he didn't pay too much attention to others,

16     are you thinking of Pale, for example, or Banja Luka and that he

17     actually -- actually, he did these people at the local level more --

18     well --

19        A.   I said yesterday that he was going by his own mind.  If he needed

20     to co-operate with somebody, then he would go to the municipality.  I

21     don't know who he talked to, who was issuing what sort of assignments to

22     whom, that is something that I don't know.  But I do know that what was

23     earlier was disrupted.  The relationships were regular.  Before the chief

24     of the police would go to Banja Luka and Sarajevo.  He would also go to

25     the Komitet as well.  But this one, he mostly went there across the road

Page 24863

 1     to that municipality.  When I say "municipality," I would just like to

 2     make sure that we're not talking about the municipality, we're talking

 3     about the building.  Where he went, I don't know whether he went to the

 4     municipal authorities, to the SDS, to the board, I don't know about that.

 5        Q.   So you mean he went to Banja Luka and Sarajevo.  When you said

 6     that you're thinking about the pre-war period?

 7        A.   Yes, the pre-war period up until the multi-party elections --

 8     well, not Simo but whoever was at that post.

 9        Q.   So it was like that until Simo Drljaca came and then it changed?

10        A.   Yes.  And then it came back after that, but 1992 was turbulent.

11        Q.   So when you're talking about this disruption in relations, you're

12     talking about 1992; is that right?

13        A.   Yes, 1992.  I -- I would just like for the sake of caution.  I

14     couldn't say that in 1992 he didn't go to Banja Luka.  I don't know.

15     Perhaps he did, but I'm not aware that he ever went to Pale.  Perhaps he

16     did but I don't know that, I really don't.

17        Q.   Very well.  Mr. Jankovic, I don't have any further questions for

18     you.  Thank you.

19                           Cross-examination by Mr. Hannis:

20        Q.   Good morning, sir.  I will have a lot of questions for you.  I

21     would ask that -- well, first of all, let me ask you:  Do you understand

22     English?  Do you read or understand English?

23        A.   No, no.  English texts that have to do with electronics or

24     technical texts, yes, that I can use.  But as for the rest, no.

25        Q.   The reason I ask was that it seemed at times you were looking at

Page 24864

 1     the transcript and you were able to follow somewhat in English where we

 2     were.  That's why I asked the question.  I would ask that you do try and

 3     watch the transcript and see when the typing stops before you begin your

 4     answers to my questions.  That will make it easier for the interpreters

 5     to keep up with you because you're a pretty fast talker.

 6        A.   I'm sorry, yes, that is why I am looking at the transcript, so

 7     that when it stops I can continue.  This is why I was looking at it, not

 8     in order to translate.  And I don't actually understand it, no.

 9        Q.   Okay.  Thank you.  I just want to ask you a few questions about

10     your background.  I understand you started working in the police in 1980

11     and you retired in 2008; correct?

12        A.   Yes, from late June 2008, in late June 2008, yes.

13        Q.   And when were you first appointed to the position of chief of the

14     communications and cryptographic data protection section or department?

15        A.   I think it was the 15th or the 20th of August, five days here or

16     there, so August 1980.  1980.  It was definitely mid-August, I think it

17     was the 15th, but ...

18        Q.   So you started out as the chief; is that correct?

19        A.   Yes, yes.

20        Q.   And was that the position you held throughout your entire career,

21     until your retirement?

22        A.   Well, the official names for that post changed, but the

23     description of duties was always the same.

24        Q.   And then, as I recall, you moved to Banja Luka in 2001; is that

25     right?

Page 24865

 1        A.   The 1st of November, yes, yes, 2001.

 2        Q.   And you worked as the chief in Banja Luka from 2001 until your

 3     retirement?

 4        A.   Yes, but I wasn't chief of the department, but I was chief of a

 5     sector, technical maintenance, whereas in Prijedor I was in charge of

 6     maintenance and utilisation because the station was smaller.

 7        Q.   Thank you.  I understand.

 8             I think you told us that your wife worked at Prijedor SJB in 1992

 9     as -- in the economic or white collar crime section; is that correct?

10        A.   Yes.

11        Q.   Did she work there throughout 1992, the whole year?

12        A.   Yes, yes, in Prijedor.

13        Q.   And is her name Miroslava?  I've seen that on a payroll document

14     I think.

15        A.   Miroslavka, Miroslavka.

16        Q.   Thank you.  You'll have to help me with my Serbian pronunciation

17     sometimes.

18        A.   Yes, yes.

19        Q.   I think you told us before that there was a Dusan Jankovic who

20     was the commander of the police at Prijedor during at least part of 1992.

21     Are you and he related in any way?

22        A.   No.  He is from Kozara and I'm from Eastern Bosnia from near

23     Brcko.

24             MR. HANNIS:  Your Honours, could we go into private session?  I

25     have a couple of questions that I want to ask that relate to a personal

Page 24866

 1     matter that doesn't need to be discussed openly.

 2             JUDGE HALL:  Yes.

 3                           [Private session]

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

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Page 24867











11  Pages 24867-24868 redacted. Private session.















Page 24869

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 6   (redacted)

 7   (redacted)

 8   (redacted)

 9                           [Open session]

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

11             THE WITNESS: [Interpretation] Allow me just to say one thing to

12     finish.

13             MR. ZECEVIC:  I'm sorry, I'm sorry --

14             THE WITNESS: [Interpretation] After that I worked normally.

15             MR. ZECEVIC:  If he intends to talk about his health, maybe we

16     should go back to the closed session --

17             JUDGE HALL:  Yes.

18             MR. ZECEVIC:  -- private.

19                           [Private session]

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 24870

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 3   (redacted)

 4   (redacted)

 5   (redacted)

 6                           [Open session]

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

 8             MR. HANNIS:  Thank you.

 9        Q.   Witness, we're back in open session.  I want to ask you about

10     something that you were asked on Monday.  Page 24725 you were asked by

11     Mr. Krgovic about any changes in the reporting rules or how things were

12     done in 1992 after Mr. Drljaca came into the job as chief in Prijedor.

13     And you said the reporting rules were the same in 1990 and in 1992, but

14     they were not adhered to in 1992, thus, for instance, at times it was

15     obligatory for us to hold morning briefings, where we superiors would be

16     duty-bound to report our activities and then it would so happen they

17     would tell us the meeting would not be held.  Now, my question is:  What

18     reporting rules were you referring to and where are those found?  Are

19     there some reporting rules in the Law on Internal Affairs or are these

20     something more informal and local?

21        A.   The rules on the communications where I was an official, I mean

22     there are rules, they are known, and they were held at the communications

23     centre in their place.  It was like a booklet or some kind of manual.  As

24     for the rules of work that I referred to a number of times and yesterday

25     I used the term "police illiteracy" -- well, I really couldn't say that I

Page 24871

 1     read the whole thing but when I did come to the service in the 1980s as

 2     an engineer, I saw how the others were working and I did the same.

 3     Always those who came would learn from those who were already working.

 4     For example, if I went to another station on another kind of job I could

 5     see the people there working in the same way so that meant that really

 6     was the way the job should be done.  Each police station had its own

 7     collegium, also the centre also had that.  There would be a different

 8     make-up, though.  As for where this was written, I really couldn't tell

 9     you that.

10        Q.   Okay.  Between the time you started in 1980 and the time that

11     Drljaca became the chief in 1992, how many different chiefs did you work

12     for at SJB Prijedor?

13        A.   From 1982 until ...  Simo came on the 30th in 1982 -- no, no,

14     1992, I'm sorry.  Simo came on the 30th of April, 1992.  Up until which

15     date are you asking me about?

16        Q.   My question was between the time you began working in the police

17     in 1980 until Drljaca came in 1992, how many different chiefs did you

18     work for during those 12 years?

19        A.   Stojan Panic from August until the new year, he retired;

20     Rajko Zigic after him, one mandate for four years, and then another

21     incomplete term of office for three years, that was the second one, he

22     died; then Sead Besic came for a brief period, just briefly because they

23     said that he had to go to Banja Luka to be the chief of the centre there.

24     I don't know how short his term of office was, perhaps a couple of

25     months.  Then Slobodan Stojanovic came.  And then the multi-party

Page 24872

 1     elections were held and then instead of Slobodan this Hasan Talundzic

 2     came.  That was that.  I don't think I've forgotten anyone.

 3        Q.   And is it fair to say that when you worked under those prior

 4     chiefs at least up until Hasan came, did you have regular morning

 5     meetings or regular collegiums?

 6        A.   Yes, yes, from day one.

 7        Q.   Okay.  How about under Hasan, did he also have regular

 8     collegiums?

 9        A.   Yes, but they were not regular.  They were not regular.

10        Q.   And then under Drljaca, it sounds like you didn't have very many

11     at all; is that right?

12        A.   Yes.  And "yes" meaning there weren't any.

13        Q.   But one difference in addition to Drljaca being the new chief was

14     that after April 30th there was a lot of combat and fighting going on in

15     Prijedor after April 30th, 1992; right?

16        A.   I don't quite understand the question.  Can you clarify.

17        Q.   One thing that changed after April 30th, besides getting a new

18     chief in Simo Drljaca, was that there was a lot of combat going on in

19     Prijedor in 1992; right?

20        A.   Yes, there was fighting, but everything changed.  A man came into

21     the police force who had never been there unless he had been brought in

22     by the policemen, and so on and so forth.  There were many other reasons.

23        Q.   And you mentioned after Mr. Drljaca became chief there were

24     certain personnel changes within the SJB in Prijedor; right?

25        A.   Yes.

Page 24873

 1        Q.   Which you said is not unusual, that that often happens when

 2     there's a change in the chief; right?

 3        A.   Well, not really in the Socialist system.

 4        Q.   Well, at page 24726 when talking about this you said -- you

 5     mentioned a couple of specific changes and then you said:

 6             [As read] "There were similar examples like this one.  It is the

 7     prerogative of a chief to move people around.  The first thing that they

 8     always do is they always change their secretary."

 9             Do you remember that?

10        A.   Yes, that is true, yes.  That I said.

11        Q.   But let me ask you about that.  The secretary for Hasan was

12     Mira Topic; right?

13        A.   I did think about it.  I know that for a period of time she was

14     there, but I am 1.000 per cent sure that she was there, Mira Topic,

15     during that meeting on the 9th of April when Mr. Zupljanin came.  Now I

16     can't remember, there was either Sead or Hasan, one of those, who

17     appointed a Muslim secretary who had earlier worked for the commander of

18     the traffic police.  She was there, but for a short time.  And I can't

19     remember whether it was Sead or Hasan who appointed her.  What I do know

20     is that Mira was there in those last days and stayed on when Simo was

21     there.

22        Q.   Thank you.  We'll talk about her some more when we look at some

23     of the communications logs because I think you indicated recognising her

24     handwriting on some of the documents and some of the entries in the

25     log-books from Prijedor.

Page 24874

 1        A.   Yes.

 2        Q.   At page 24726 and going on to 727 on Monday you were asked about

 3     some of the outlying police units being a part of the communications

 4     system, specifically about Ljubija, Kozarac, and Omarska.  And you said

 5     they had an ultra short-wave radio set, a stationary one, and a telephone

 6     line as well.  Is that right?

 7        A.   Yes.

 8        Q.   But you mentioned that none of those had a teleprinter, so you

 9     couldn't send them coded written information; right?

10        A.   No, that's right, that's right.

11        Q.   So how was written information sent from Prijedor to Ljubija,

12     Kozarac, and Omarska?  Just by courier?

13        A.   Yes.  A policeman would carry a great deal of things, not just

14     dispatches.

15        Q.   None of these were very far away from Prijedor, right, none of

16     those three places?

17        A.   Kozarac 12, Ljubija likewise, and Omarska perhaps 25 kilometres,

18     not far away.  By car, not far.

19        Q.   And how often did couriers go?  Did they go every day?  Twice a

20     week?  Or just as often as necessary?  How was that?

21        A.   Well, officially I don't know, but let me also say that there was

22     always somebody from that police station over here in town because they

23     needed consultation, to see the commander, so there was constant

24     communication.  We were in contact or so -- in physical contact because

25     we were close.

Page 24875

 1        Q.   Thank you.  Then you mentioned that according to the

 2     organisational chart in the MUP in 1991/early 1992 that Sanski Most,

 3     Bosanski Novi, and Bosanska Dubica were under Prijedor in terms of the

 4     communications.  Am I saying that correctly?

 5        A.   I'll repeat it briefly and then you'll see if your understanding

 6     is correct.  Officially the organisation changed at times.  At times

 7     Banja Luka was a centre for all of us, Prijedor, Sanski Most, and Dubica

 8     would in those circumstances be on equal terms vis-a-vis Banja Luka.

 9     Under a different organisation, Prijedor would become the centre, in

10     which case the three municipalities would gravitate toward Prijedor.

11     However, the technology was always in the hands of Prijedor.  It never

12     changed even though the organisational structure did, Prijedor was always

13     in a superior position in relation to the other municipalities when it

14     came to communications technology if I was clear enough.

15        Q.   What I'm trying to understand is I have the understanding that

16     when Banja Luka was sending out dispatches to Prijedor and its other

17     SJBs, that communications that were intended for Sanski Most, Novi, and

18     Dubica came to Prijedor and then Prijedor forwarded them on to those

19     three SJBs.  It didn't go directly from Banja Luka to Sanski Most; it

20     went through Prijedor; is that right?

21        A.   If Banja Luka is sending a dispatch to Sanski Most only, then it

22     would go directly to Sanski Most.  Technically speaking, it would go

23     through Prijedor, but it would not go through any person's hands.  It

24     would merely go through the equipment.  However, if Banja Luka was

25     sending a dispatch to all the municipalities, then it was a circular and

Page 24876

 1     it would be sent from Banja Luka to Prijedor only and the operator in

 2     Prijedor would be forwarding a circular to all equally if everything

 3     worked as it should, which often was not the case.

 4        Q.   Okay.  I understand that now.  That's better.  And if Sanski Most

 5     or Dubica or Novi wanted to communicate with Banja Luka, they had direct

 6     links to Banja Luka and they didn't have to go through Prijedor; is that

 7     right?

 8        A.   Well, what is important again is to stress that in organisational

 9     terms you're right; however, technically speaking, yes, if there was a

10     malfunction in any place, like in Prijedor, again what I'm saying is it

11     wouldn't go through any physical person.  It would go through the

12     technology itself.

13        Q.   All right.  Let me show you a document that maybe will help me

14     understand a little better.  It's Exhibit P1471.  It's tab 3 of the

15     Prosecution binder.  This will come up on your screen in a minute.  Let

16     me know if you can read it there.  It's a diagram I think of the

17     telephone network in Bosnia before the war, before April of 1992.  Can

18     you see that all right or do we need to enlarge it?

19        A.   Yes, if text can be enlarged.  I can't read it.

20             MR. HANNIS:  I don't think we need the bottom half right now.

21        Q.   Can you see, we have the republican SUP in the middle and in the

22     upper left quadrant you'll see CSB Banja Luka and Prijedor.  Can you see

23     that?  I can hand you my copy if that's easier.

24        A.   It's very hard for me to read.  Yes, please, if I could be given

25     a copy and if I can read from that copy.  Yes, excellent.  I can see

Page 24877

 1     everything now.

 2        Q.   Let me ask you, have you seen that before, that diagram?

 3        A.   This is a very old chart.  It depicts what used to be the

 4     communications plan much, much earlier.  It does not mean much without

 5     the supporting text.  But you can ask me about it and I can see what it

 6     is that you've marked.

 7        Q.   Let me ask you this:  The key has been translated for me.

 8     Banja Luka has a small circle within a bigger circle and that is

 9     explained to be a nodal switchboard.  Do you understand that term and can

10     you explain it to me?

11        A.   Yes, yes, there's the key at the bottom.  Let me first note that

12     the key and the designations are not universal.  They were chosen by the

13     author, but then we have the key so we can have a look at it and how it

14     is logically.  So I do understand it.  The main switchboard and the nodal

15     switchboard or the hub switchboard.  The main switchboard was the SUP and

16     Banja Luka was a node or a hub.  If we wanted to explain it in somewhat

17     broader terms, the main switchboard can get connected to anyone, whereas

18     the hub or the node is just the node.  What it connects.  For instance,

19     the CSB Banja Luka, how can they place a call to Vitez, CSB Zenica and

20     then Vitez.  They can do so via Sarajevo.  That's why I say the main one

21     can do whatever it wants, can get connected to anyone and the node needs

22     to go through the main switchboard, if this is enough for you.

23        Q.   Yeah, I think so.  And on this diagram Prijedor is listed as a

24     nodal switchboard as well and I take it that's because it has the ability

25     to communicate directly with Sanski Most, Dubica, and Novi.  That's why

Page 24878

 1     it's a hub?

 2        A.   Yes, not the main but the nodal switchboard.  It is only Sarajevo

 3     that is the main one.

 4        Q.   And --

 5        A.   What I was just saying corresponds to what we have here.  I said

 6     that Prijedor could transmit circulars to these three municipalities.

 7        Q.   If you needed to get -- if you needed to get a written

 8     communication -- a coded written communication from Banja Luka to

 9     Sanski Most, could Banja Luka send that directly without any human being

10     in Prijedor having to do anything with it?

11        A.   There existed in parallel to this transmission system that we see

12     here a different system of encryption or cryptographic data protection.

13     That particular chart or system could not be as extensive as this one.

14     Why?  Because every two participants have to have a document in order to

15     be able to interact.  Now, imagine how many participants there are and

16     each interacting with the other.  Well, there would be a roomful of these

17     and you have that yellow tape with -- that is perforated.  I don't know

18     if you've seen that before.

19        Q.   Actually, I have, about 40 years ago when I was in my army doing

20     something I did see some of those things.  But if I understand correctly,

21     if Sanski Most and Banja Luka have the encryption device or the tape on

22     each end, they also need a connection through which to send that message;

23     right?

24        A.   Yes.

25        Q.   And there was such a link between Banja Luka and Sanski Most?

Page 24879

 1        A.   There is a link.  There is the equipment, but there is no tape or

 2     ribbon under that organisational chart because what we have in

 3     Prijedor -- I'll say this very briefly to make it clear to you.  You have

 4     two tapes or ribbons that form a pair.  Let's say they are between you

 5     and me.  And that there's two more between me and Sanski Most and that

 6     there's four ribbons or tapes, it's one I would have and then each would

 7     belong to one of the three municipalities.  That's it.  Nothing can

 8     happen unless you have a tape.  You can have all the devices you want and

 9     all the equipment you want unless you have that tape.

10        Q.   [Microphone not activated]

11             THE INTERPRETER:  Microphone, please.

12             JUDGE DELVOIE:  Microphone, please.

13             MR. HANNIS:  Sorry.

14        Q.   If I and Sanski Most have the tape and you and Banja Luka have

15     the corresponding tape, you can send me a message directly without any

16     human being in Prijedor having to do anything with it; right?

17        A.   Yes.

18        Q.   Thank you.  We'll talk some more about that later, but let me now

19     go on sort of chronologically based on the questions that were asked of

20     you Monday.  You were talking at page 24729 about when Hasan Talundzic

21     came to work as chief and one of the problems that you had with him was

22     that he had no prior police experience; right?

23        A.   That's right.

24        Q.   And I think you said also that he didn't consult with you on a

25     regular basis.  You said after he came you could only talk to your

Page 24880

 1     colleagues below you.  You didn't have anyone upwards to consult with

 2     because he didn't do that; right?

 3        A.   Yes -- well, he didn't have any knowledge about it.  It wouldn't

 4     have made any sense to consult him because he had no knowledge of the

 5     things that we are discussing right now.

 6        Q.   Okay.  And he had -- and you said he also was doing most of his

 7     consulting with the local political authorities as far as you could see

 8     and not with policemen?

 9        A.   Yes.

10        Q.   Okay.  I want to ask you -- that sounds like you could say the

11     same thing about Simo Drljaca when he came, no prior police experience,

12     not consulting with you, and consulting with the local political

13     authorities; right?

14        A.   I did say so yesterday.

15        Q.   The only difference is Talundzic is a Muslim and Drljaca was a

16     Serb; right?

17        A.   And those who they went to to be told what to do were Muslims in

18     one case and Serbs in the other.

19        Q.   Correct.  I think this would be a good time to take our first

20     break for the morning.  Thank you.

21             JUDGE HALL:  Yes, we would resume in 20 minutes.

22                           --- Recess taken at 10.22 a.m.

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

24             MR. HANNIS:  Thank you.

25        Q.   Witness, I'd like to spend a little time going through some of

Page 24881

 1     the log-books, communication log-books, from Prijedor.  If I could with

 2     the usher's assistance hand you a binder with four or five of the

 3     log-books I want to talk about.  I think you were shown some of these

 4     when you were interviewed by Mr. Yarmah and --

 5        A.   You mean in Banja Luka, yes, yes.

 6        Q.   And if you open the binder you will see the first one has a tab

 7     number 129.  That's the first one I want you to look at and I'll give you

 8     a specific page in a moment.  This is Exhibit Number P2080, Your Honours.

 9     And, Witness, before you go could you look at the cover page of that

10     document -- yeah, that -- the very first page -- yeah.  Can you tell us

11     what that word is on the cover of that notebook, the black page?

12        A.   Well, I would just like to mention the basic things.  In

13     cryptographic work there is no term that would be used as a register or a

14     notebook.  There are books like that in other departments with the

15     cleaning department or something, but I don't know anything about that.

16     I never worked with books like that, log-books.  This is a log-book of a

17     sort.  I opened it.  I could see right away that it was from 1985.  I

18     recognised the signature of my former superior, Rajko Zigic.  It says

19     here authorised staff so this is what I said in relation to 1992 --

20        Q.   Staying on that page if we could.  If we could go to page 3 of

21     the B/C/S in e-court.  And, Witness, it's the page you're looking at

22     right now.  We don't have an English translation of that.  Could you read

23     to us what it says on that page that you've got open in the book there.

24     Yes.  It has the big word in Serbian "delovodnik."

25        A.   Log-book, "delovodnik," yes.

Page 24882

 1        Q.   Can you tell us what else is written on that page on the top in

 2     handwriting?

 3        A.   It states Municipal Secretariat for Internal Affairs, Prijedor.

 4     That was our official name at the time.

 5        Q.   And I think you mentioned it had a reference to 1985.  I think

 6     that's where the first entry begins is in --

 7        A.   Yes, that's what it says here.

 8        Q.   But I only want to talk about 1992, and I've put a yellow stickie

 9     note at the place where 1992 begins in your hard copy -- no, at the top.

10     Yes, that first yellow stickie note, if you could go to that page and in

11     e-court that's -- in B/C/S that's page number 166, which matches up with

12     the English page we have in e-court on the screen.  Now, Witness, on that

13     left-hand page do you see at the top I think it says "1992"?

14        A.   Yes.

15        Q.   Looking at this, can you tell me what this book is about, which

16     types of communications are logged in here.  Is it incoming or outgoing

17     and which department is keeping this book?  Are you able to tell?

18        A.   That would be hard.  It would be very irresponsible for me to

19     interpret anything because this is a document that I had nothing to do

20     with.  Only on the basis of my experience I can see that this is the

21     handwriting of Mira Topic, the secretary.  This is what I see, nothing

22     more than that.  I can see that it's her signature.  She did enter some

23     official documents but I don't know pursuant to what rule.

24        Q.   If you would go to -- it's item number or transmission number 15.

25     Do you find that?  In the left-hand column --

Page 24883

 1        A.   14.

 2        Q.   -- number, do you find number 15?  Yeah, okay.  My English

 3     translation says the subject of that is a plan for short-wave radio

 4     connections for the month of April 1992 dated the 30th of March and under

 5     distribution code it has your name; is that right?

 6             Can you tell us about that?  Were there monthly plans for radio

 7     communications that were distributed to communication chiefs in the MUP

 8     in 1992?

 9        A.   Could we zoom in a little bit.  This is the KT plan so this is

10     the short wave.  I'm keeping my hand here, this is the KT radio

11     connection and that connection actually is not used at all.  This is just

12     there as the last reserve in case all the other systems should break

13     down, all the post offices, all the wires, then it just goes from device

14     to device via antenna and you can, for example, set up a KT connection

15     from Prijedor to Japan.  And that is why the signals people, even though

16     they didn't use that connection practically, they did hold trainings in

17     order to keep up their skills to use the keyboard.  So that is what the

18     trainings were for.  If you lose practice or if you are out of practice,

19     you cannot use the keyboard.  So, for example, the training centre would

20     refer to something which sounds quite important.  It's called the

21     communication plan, but actually what it indicates is just at what time

22     we should communicate and using which signals.  For example, TFS, your

23     name would be QI or whatever, I don't know.  That's the plan actually.

24     Has nothing to do with actual transfer of information.

25        Q.   Okay.  What I'm trying to find out in regard to this under the

Page 24884

 1     column that says "sender" it says CSB was the sender of this document and

 2     then it looks like you were the one who received it.  Is that a fair

 3     reading of that entry?

 4        A.   Yes, when the secretary received it she knew it was for

 5     communication, and then as the chief, as the head, I would receive that

 6     and then I would issue it to the workers who were working on that.  So

 7     every day at a certain time we would establish communication at that

 8     particular frequency and that was just for the sake of keeping up the

 9     practice.

10        Q.   We'll see in a minute, but it seems like many of the documents

11     referred to in this particular log-book are longer documents.  For

12     example, this -- the one that you were just looking at, there's another

13     one that's rules on internal organisation, a plan for confiscating

14     weapons, a telephone or ultra short-wave directory.  So these appear to

15     be longer documents which I think you explained to me wouldn't be sent by

16     Teletype.  Those were the kind of things that would be sent by a courier

17     because they were too long.  Do you understand what I'm asking?

18        A.   Well, there's a lot mixed up in there.  You mentioned weapons.  I

19     don't know which weapons.  That has nothing to do with me.  But as for

20     the telephone connections and communications, yes, that has something to

21     do with me.  I would like you to be just a little bit more precise.

22        Q.   Yeah, I'm trying.  Maybe I didn't form my question well.  You'll

23     see, we'll look at --

24        A.   I'm listening.

25        Q.   -- we'll see on some other documents, but the nature of most of

Page 24885

 1     the documents that are listed in this log-book, they're not short

 2     one-paragraph, one-page document, like are sent as dispatches via

 3     Teletype.  They're the longer documents which I think you explained in

 4     your earlier testimony were the kind of things that would not be sent by

 5     Teletype because they're too long and they're not secret, they're not

 6     urgent so they go by courier.  It might be a 30-page document or a

 7     50-page rule book.  Do you understand so far?

 8        A.   Well, the question is very broad so I really need to tell the

 9     story in order to answer the whole question.  I don't know if you mean

10     whether it was adopted, why -- I don't know what exactly the question is.

11        Q.   Okay.  Fair enough.  Let's look at a couple and it may be that --

12        A.   I will answer -- all right.

13        Q.   If you could go to number --

14        A.   Just one general remark.  The papers that you've seen plenty of

15     them of that particular kind, as the state of Yugoslavia we had the

16     doctrine of All People's Defence, so the concept was that if anybody ever

17     attacked us every village would have everything they needed and we would

18     defeat anybody.  So I myself really wasn't that familiar with all the

19     documents, I didn't understand all of them, and I didn't use them all.

20     However, there were professional National Defence services who were

21     writing that.  So they were showing the results of their work through all

22     those papers so there were so many of those papers but when there was a

23     need to use them none of them were used.  Perhaps that's the sort of

24     papers or documents that you looked at.  If you can show them to me then

25     I will talk about it.

Page 24886

 1        Q.   Okay.  Well, let me show you a couple of documents and I'll ask

 2     you some further questions.  Could you look at number 19.  I think it's

 3     the next page on for you.  Item number 19, it's -- the subject described

 4     is plan for confiscation of illegally acquired or owned weapons and mines

 5     and explosives from groups and individuals in the Prijedor area.  The

 6     date is 27 May.  The sender is SJB Prijedor.  It says three copies

 7     delivered to the CSB.  And then in the far right column it says

 8     CSB Banja Luka to the CSB chief sent via colleagues from CSB, delivered

 9     by M. Djenadija.  Do you know who M. Djenadija was, by the way?

10        A.   I think you skipped two words and those two words are very

11     important.  Sent to the chief through colleagues from the CSB.  So

12     evidently this was not conveyed by any kind of communication.  Okay,

13     Djenadija, Marko, at the time was some kind of commander.  I don't

14     know -- I don't want to mix them up.  Maybe he was at the police station

15     number 2, the one in Urije.  I don't know.  They changed so really it's

16     been a while.  I can't tell anymore but he was some sort of komandir.

17        Q.   In the police?

18        A.   Yes, yes, he had a uniform.

19             MR. HANNIS:  If we could look on the screen for the moment at

20     exhibit P1036.  This is at tab 49.

21        Q.   Witness, we're going to show you a document I think may relate to

22     the log-book.  You see, this appears to be a cover letter from

23     Mr. Drljaca.  It's addressed to the chief at Banja Luka, and my English

24     translation says:

25             "Please find herewith enclosed for further comment and approval

Page 24887

 1     the plan for confiscation of weapons ..." et cetera.

 2             And you see at the top the number of this communication is

 3     11-12-19 dated the 26th of May, 1992.  Can you explain for us again ABOUT

 4     the numbering system of communications within the RS MUP in 1992?  What

 5     does the 11 stand for in that number?

 6        A.   Well, I know generally but I don't want to make any mistakes.

 7     But I can tell you the principle.  Between the lines, the first part of

 8     the number talks about the organisational unit.  11, I think was at the

 9     time referring to Prijedor, that stood for Prijedor.  12 is a subunit, it

10     could be the chief that's separate, then the police station, the criminal

11     investigations police, communications, and so on and so forth.  And the

12     next one, the last one should be the log-book, log number.  I mean, to me

13     that's a foreign term, but I think that should be the number there.  Did

14     we say 19?  Yes, that's it.  Let's say by hierarchy, company Prijedor,

15     for example.

16        Q.   Okay.  We'll look at some more.  I know it's been a long time

17     since you dealt with these, but I would suggest to you that 11 seems to

18     refer to CSB Banja Luka.  And 11-12 refers to Prijedor SJB.

19        A.   You're most probably right because as you were speaking I

20     remembered.  When we were part of the Banja Luka centre - and that's that

21     period - then the centre was the first number, so 11 then would be

22     Banja Luka and then Prijedor would be 12.  But, however, here this number

23     is kind of small.  There were more numbers.  The number should have the

24     chief, criminal investigation police, perhaps communications.  My number

25     was 04 and so on and so forth.  And then the last number would be the

Page 24888

 1     log-book number.  So this number is very short.  So I cannot really tell

 2     what goes with what in terms of the police departments.

 3        Q.   I understand.  We'll look at numbers that are longer.  And is it

 4     correct, most of the time I'm used to seeing on the end of a number on a

 5     document like this a slash and the year, two-digit year, 92, 93,

 6     et cetera.

 7        A.   Yes, that's the year, yes.  And these longer ones I forgot about

 8     them even more.

 9        Q.   If we could go back to the log-book, I want to show you another

10     one, Exhibit P2080 and for you it's item number 20, the very next item in

11     the book.  You were looking at 19, if you could look at 20 -- no, it's

12     still on the same page, I think, where you were.  You were looking at

13     number 19.  Look at the very next one, number 20.  It's -- my translation

14     says the subject is order regarding treatment of arrested persons.

15     Sender is SJB Prijedor.  It's delivered to the Crisis Staff, some

16     co-ordinators, a couple words are not translated because they're

17     illegible according to our interpreters.  But the name Jasic,

18     Majstorovic, Banja Luka CSB, chief of security, administrator of the iron

19     ore mines and archives.  Do you see that?

20        A.   [No interpretation]

21        Q.   Just keep that number 20 in mind and I want to show you another

22     document and that's P1560, that's tab 58 on the Prosecution's list.  I

23     can give you a hard copy of this one with some help from the usher.

24             MR. KRGOVIC: [Interpretation] Your Honours, I have a general

25     objection to the line of questioning by Mr. Hannis, because this witness

Page 24889

 1     is being shown a document that is not a communications document and he's

 2     being asked to look at the document and to read what it says.  But it's

 3     already been admitted so what would be the purpose of this line of

 4     questioning of this witness?  Just to read what it states in the document

 5     and to confirm that that's what is written.  It's not a communications

 6     document so I don't know how that can assist.

 7             MR. HANNIS:  Well, Your Honour, it goes to a host of issues.

 8     This witness worked in the SJB in Prijedor and although he was the head

 9     of communications I believe it's fair to assume that he had some fair

10     knowledge about the general workings of the police station.  He knows

11     various individuals, he recognises handwriting, and I think he can shed

12     some light on how books were kept, what kinds of information were

13     received by whom, how they were distributed, et cetera.  And he can also

14     comment on the content of a number of these documents, at least as to

15     whether he knew about them or not.  And the level of his knowledge is

16     going to be very important in assessing the credibility of all his

17     evidence at the end of this case.

18             JUDGE HALL:  Yes, I suppose so, Mr. Hannis.  One thing that

19     struck me, though, is that apart from the basis of Mr. Krgovic's

20     observation that the documents which have been admitted speak for

21     themselves, the witness's answer to some of your earlier questions,

22     having indicated his unfamiliarity with the contents, as it were, seeing

23     these exhibits for the first time, I wonder how much usefulness is going

24     to be derived from the line of questions that you propose.

25             MR. HANNIS:  Well, Your Honour, perhaps I could ask the witness

Page 24890

 1     to take his headphones off while I respond to that.

 2        Q.   Witness, could you take your headphones off for a minute while I

 3     speak to the Judge about something.  Thank you.

 4             MR. HANNIS:  Your Honours, communications apparently still

 5     appears to be a hotly contested issue in this case, at least from the

 6     Defence perspective.  We think there is lots of evidence about

 7     communications and although there was evidence about electric part of

 8     communications not working, we say there are lots of other ways to do

 9     communications, regular mail, courier, et cetera.  This witness was not

10     in a position to know about all those, but he can corroborate that these

11     documents are from Prijedor, that he recognises signature of the

12     secretary of the chief on some of these documents.  So they're authentic

13     and they reflect that communications were going on beyond and above and

14     outside what's in the communication log-books per se.  This is not a

15     communication log-book that was kept in his centre; rather, it appears it

16     was one kept by the chief's secretary.  But it reflects communications

17     that won't show up that he hasn't seen.  So we need to supplement his

18     evidence about the level and quantity of communications with other

19     evidence, otherwise we're left with him saying:  Oh, communications

20     didn't work and, you know, it was terrible and we weren't able to

21     communicate with anybody to the extent that he said something like that.

22     And I think we're entitled and it's necessary for me to try and establish

23     that that's not the case.

24             JUDGE HALL:  I see.  Please proceed, Mr. Hannis.

25             MR. HANNIS:  Thank you, Your Honour.

Page 24891

 1        Q.   You can put your headphones back on.  This relates to what I was

 2     asking before about lengthy documents.  This is more than just one or two

 3     pages, this document, so I understand from your earlier evidence this is

 4     not something that would have been transmitted electronically through

 5     your communications system simply because of the length of the document;

 6     is that right?

 7        A.   I remember the gentleman from the OTP asked me about this.  I

 8     don't remember literally what I said, but I repeat it because I want to

 9     say it.  The rule of transfer of written information is that half a page

10     up to one page of text can be transferred by teleprinter.  Everything

11     else is conveyed by courier.  That's the rule.  However, often because of

12     the urgency, even two or three pages if necessary are sent, if they have

13     to be sent, but this did not constitute a rule.  And usually the signals

14     operator would ask for my opinion.  If it has to be sent then it would be

15     typed.  It's not a problem, you could send two or three pages, but never

16     10 pages or 20 pages.  If that's what you meant.  I said that before and

17     I'm repeating that now.

18        Q.   Did you ever see any documents from Chief Drljaca addressed to

19     the Crisis Staff?  Did any of those documents ever get sent via the

20     communications centre that you know of?

21        A.   Not through the communications centre.  That's because the

22     Crisis Staff is nearby, and as for me monitoring or keeping track of

23     these things on any other basis, no, that was not possible.

24        Q.   Thank you.  I want to go now to the next tab in your binder,

25     tab number 130.  Thank you.  Tab number 130 and if you could tell me --

Page 24892

 1     this is Exhibit P2088.  Can you read for us what's written on the cover

 2     of that book or printed on the cover of that book in Serbian because we

 3     don't have an English translation of that cover page?

 4        A.   The book of outgoing coded telegrams.

 5        Q.   And could you look at the next page in B/C/S in e-court and the

 6     inside cover, could you look at the next page in your hard copy.

 7        A.   Yes.

 8        Q.   Can you tell us what's there, the stamp and the printed words?

 9        A.   The book contains 100 sheets of paper with the numeration between

10     1 and 100 and bound and I'm -- I signed it as head of the communications

11     and KZ, that's encryption section.

12        Q.   So was this a book that was kept in your communications centre in

13     Prijedor SJB in 1992?

14        A.   This book is obviously an official document containing records of

15     coded documents that the centre transmitted.  As I said yesterday, it

16     normally had its official designation, the form, and it does say, in

17     fact, K20, but what I see here that it's not really the book of records

18     of our centre but rather of the chief's secretary.  Let me explain this

19     further, the secretary, the administrative secretary, was duty-bound to

20     keep a separate record of her own of all these coded dispatches.  Since

21     she didn't have a notebook of her own to do this, I gave her the book

22     that we normally used.  Since the book is one of coded dispatches

23     encrypted, it has to be bound in this way.  You can't really tell it here

24     because you can't see it, but it's the way of binding a book in such a

25     way that the sheets of paper cannot be taken out, cannot be interchanged.

Page 24893

 1     This is part of the cryptographic data protection system.  And you can

 2     also see that it's her handwriting here so she made the entries.  And in

 3     column number 7 you can see the signatures of the various individuals who

 4     actually worked under me, they were various encryption operators.  I know

 5     their names.  So she would note down the date and time of a dispatch, the

 6     person who received it, and so you have all the information there.

 7        Q.   This particular book then, where was it kept?  Was it kept in the

 8     secretary's office or in the communications centre or the chief's office?

 9     Physically, where was it located?

10        A.   I'm sorry, the beginning of your question was cut off.  I didn't

11     hear it.  Can you repeat your question.

12        Q.   Sure.  This particular book, where was it physically kept in

13     1992?  Was it in the communications centre --

14        A.   It was kept by the secretary, the personal assistant.  I never

15     checked this book.  I gave her an empty notebook and that was all.

16        Q.   And that would be Mira Topic that we've talked about before?

17        A.   Well, the date here is back in 1986 and I think it was

18     Nada Markovska who occupied the post and not Mira Topic.  Well, at any

19     rate, in these various times a lot of them changed.  I don't know how

20     many.  I don't think this is Mira's signature.  It may have been Nada,

21     who if I remember correctly, was there first.

22        Q.   Sorry, my mistake.  Can you go to the yellow stickie note, go to

23     that one and I think that will take you to the entries for 1992 in this

24     particular log-book begin.

25        A.   Yes.

Page 24894

 1        Q.   That's page number, I believe, 19 in e-court.  It's ERN P0042544

 2     do you recognise the writing in 1992, is that Mira Topic?

 3        A.   In most of them, yes, but there are entries where it is not her

 4     from what I can tell.  Under 19 that doesn't seem to be her, but item 6,

 5     for instance, 7 as well, or rather, from 1 to 10, yes, that's Mira Topic.

 6     I am certain that it is her.  Maybe somebody will say that it isn't, but

 7     I'm sure that that's not her under 19.

 8        Q.   All right.  Could you go to the very next page -- or actually,

 9     can you go two pages further on and two pages further on in e-court.  I

10     want you to look at item numbers 49, 50, and 51 -- I'm sorry, I may have

11     sent you too far.  Can you go back and find the items 49, 50, and 51.

12     Looks like telegram numbers 2023, -25, and -31.  Do you see those?

13        A.   Yes, 2023, and 2025 and 2031.

14        Q.   Okay.  The signature for item number 49, that appears to be

15     Goran.  Who would that be?

16        A.   One of the communications officers --

17             THE INTERPRETER:  The interpreter didn't catch the family name.

18             MR. HANNIS:

19        Q.   Could you repeat his family name for us.

20        A.   K-o-v-r-l-j-a, Kovrlja.

21        Q.   Thank you.  Now is --

22        A.   I apologise.  I'm sorry, there is an "I" missing,

23     K-o-v-r-l-i-j-a, so his name is Kovrlija.

24        Q.   Now --

25        A.   Now it's all right.

Page 24895

 1        Q.   It appears that the numbers assigned to these dispatches are in

 2     ascending order, numerical order.  Where does the assignment of numbers

 3     come from?  How do you know what number to put on the next outgoing

 4     telegram?

 5        A.   Well, the last number -- let me think it over rather than make a

 6     mistake.  I'm trying to remember these things.  It was a long time ago.

 7     Normally the number in its entirety, which is found within the heading of

 8     any typical dispatch, the former part would be written by the author and

 9     the last four digits would have been added by the communications officer

10     dealing with the dispatch.  And those would normally be added by hand.

11     Since this is Mira's book and the numbers are not in sequence and they

12     are not even Mira's as far as I can tell by looking at the

13     handwriting - and this is me making an inference - I believe that Mira

14     left this particular box empty whenever she prepared a dispatch and

15     wanted to take it over to the communications and encryption section, she

16     would fill in all these save for that number, time, and signature.  And

17     then the communications officer would use the first next number available

18     in his book and Mira would take it over and write it in here and she

19     would write the date when she handed the dispatch over and ask the

20     operator on duty to place his signature there.  That's how things should

21     have worked.

22        Q.   Okay.  But the book where the running list of numbers is kept is

23     in the communications centre?  Do you understand?

24        A.   Yes, yes, yes.  In the communications centre.

25        Q.   And because it appears there are only 100 coded telegrams sent in

Page 24896

 1     1992 with the first one having a number of 141 and the last one having a

 2     number of 2.580, that means there's something like 2.480 other numbers in

 3     that range from 1 to 2.580 that weren't coded telegrams.  What documents

 4     did those other numbers go to, if you follow my question?  Open

 5     telegrams?  Other kinds of communications that aren't telegrams --

 6        A.   The question is clear and now let me tell you.  As I said, the

 7     book was of the format which belonged to cryptographic data protection.

 8     All the other rules related to encryption stemmed from those prescribed

 9     by the army.  We were called upon to adhere to those.  We were just one

10     group of users of those.  Having said that, as I said, the books were not

11     destroyed before the expiry of one year or -- well, one year at the most.

12     They could have been destroyed after six months as well.  So what

13     happened next?  Since we had a very low fluctuation of dispatches because

14     we were a small station, if I only filled in two of the sheets, two of

15     the pages, and the rest of the book was empty, the practice was that we

16     would if we had a lot of these books in stock, we would have this one

17     destroyed to adhere to the rules.  However, it also happened that we

18     would continue using that book and that was the case with this because

19     you see that the book stretches from page 88 to, or rather, from year

20     1988 to 1996.  So it was -- it had a long life and this was actually

21     contrary to the rules.  Had we had an inspection come in, they might have

22     had understanding for this and perhaps not.  I have not had experience

23     with the inspection looking into this sort of rules.  So I can't tell you

24     what the case was in this -- with this specific book.  I don't remember.

25        Q.   I'm sorry, I think we had a miscommunication.  I think you were

Page 24897

 1     explaining why we have more years than just 1992 in the book, but my

 2     question is:  Focusing on the year 1992, just the year 1992, in there we

 3     see there were 100 telegrams, coded telegrams, sent in the entire year

 4     1992 from Prijedor SJB with the first number --

 5        A.   From the chief, but if it was the commander who was sending a

 6     dispatch and believed that it had to be coded, it would be designated as

 7     coded but it would not be entered into this book.  Or, for instance, if I

 8     sent out a coded telegram from the communications centre, it would not

 9     have been entered into this book.

10        Q.   Okay.  Well, we'll look at your year-end report on communications

11     later and come back to this issue.  But do you understand the point I'm

12     making about the -- the last number that went out on a telegram, for

13     example, before the /92 at the end of the number?  It appears that in

14     1992 the first document that went out would have been 11-12-something/01.

15     But the first telegram that went out, the first coded telegram that went

16     out in 1992 appears to have been on the 6th of January and it was given

17     the number 141, do you see that, very first entry for 1992?

18        A.   6th January, 1992, yes, you're right.

19        Q.   And it was number 141; right?

20        A.   Yes.

21        Q.   My question is:  What were numbers 1 through 140 before the 6th

22     of January?  What kind of documents would those numbers have been

23     assigned to, if you know?  Something other than a coded telegram

24     obviously?

25        A.   Now the question is clear to me.  Since I've forgotten all the

Page 24898

 1     details, let me -- I would have said at first that these were only coded

 2     dispatches.  But if we have 141 -- if I look at that number I say that

 3     there's not a chance that they could all have been coded.  There must

 4     have been open ones among them.  Did I understand this now?

 5        Q.   Maybe.  Let me ask you another question.  Does that mean then

 6     that in total - because you'll see the last number in that log-book is I

 7     think 2.580 - does that mean to you that in 1992 the total number of

 8     coded telegrams and open telegrams sent from Prijedor SJB must have been

 9     at least 2.580?

10        A.   Things change.  It's very difficult.  There are four numbers in

11     the books, those received, those transmitted, those open, and those

12     protected.  And it changed.  And at times during the war the total number

13     would have been over 100.000.  However, at the time when this arrived,

14     there would have been a thousand at the most.  So thinking about these

15     approximations, I know that we had over 100.000 dispatches, but most of

16     them were open.  Those were the peaks, let's say.  But I couldn't give

17     you the figures, not even approximate ones.

18        Q.   Can you stay with me for a little bit.  Look at the last page,

19     telegram number 100 for -- can you go to number 100 for 1992.  If

20     you'll -- you'll have to keep turning your page, I think.  It should be

21     the last page.  There you go, on the right-hand side, the right-hand

22     page.  Witness, the other -- see number 100?

23        A.   Yes.

24        Q.   It's been assigned the number 2580, 2.580, on the 30th of

25     December, 1992.  To me that suggests that in 1992 there were 2.579 other

Page 24899

 1     documents before this.  We see by this book that 100 documents in 1992 --

 2        A.   Yes, that's logical, yes.

 3        Q.   Okay.  And we see that 100 of those documents are coded

 4     telegrams, the ones in that book.  But you also have open telegrams.  So

 5     am I right in assuming that there were 2.000 -- at least 2.480 open

 6     telegrams sent in 1992, to make up for all those numbers that aren't in

 7     this book?  Do you follow?

 8        A.   I understand your question clearly and I clearly understand what

 9     it is that you want.  And I'm trying to wrack my brains to recall all

10     these things.  And I'm trying to recall the way these books were kept,

11     such as this book of outgoing dispatches.  It is true to a large degree

12     that all the dispatches received by a communications operator received in

13     terms of the fact that he had to transmit them further, they would get

14     the next available number.  And then there would be a designation

15     indicating whether they were open or protected.  So it logically arises

16     from this book that by this date the total of 2.580 dispatches were sent,

17     of which 100 were sent only from the chief, but that does not mean that

18     they were all coded telegrams.  Jankovic could have sent coded telegrams

19     to Banja Luka and they would not have been noted here.  So I believe we

20     have resolved this problem.

21        Q.   I think so.  Thank you.  Now if you could go to the tab 132, not

22     the very next one but the second one after in your book, yeah, behind

23     132.

24             MR. HANNIS:  And, Your Honours, that's Exhibit P2090.

25        Q.   Witness, can you look at the first page.  That doesn't tell you

Page 24900

 1     much.  I think it just says CSB Banja Luka on it.  If you could turn

 2     inside --

 3        A.   I had never seen them.

 4        Q.   And inside do you recognise any of the handwriting or the

 5     numbering on those pages?  It appears to be some sort of courier or mail

 6     delivery log-book.  You've never seen this before?

 7        A.   Never.  Not even with your colleague who brought over these

 8     things.  I don't know anything about it.  However, this title, working

 9     lists, well, this is something that we had in our encryption work.  So I

10     suppose that this is something that they used for handling their papers.

11     It is similar to what we had in our department, but this is the first

12     time I see this.

13        Q.   Tell me about couriers.  Did you have couriers in the police in

14     Prijedor SJB in 1992; and if so, were they part of your department or

15     were they just regular policemen who did that duty or were they part of

16     the duty operations service?  Who were the people who actually delivered

17     hard copies to mail back and forth between Banja Luka and Prijedor, for

18     example?

19        A.   In the period before when everything was normal -- may I begin my

20     answer?  Very well.

21             Earlier on, as I say, when everything was normal, definitely

22     before the multi-party elections, there was a plan for the courier

23     service and I think it was normally on Tuesdays and Thursdays that a

24     policeman from the duty service would go to Banja Luka and come back, but

25     they had nothing to do with me in organisational terms.  If I needed to

Page 24901

 1     have anything sent, I would get in touch downstairs with the secretary of

 2     the chief and ask when the courier was due and I would send the envelope

 3     with him and he would deliver it to whoever I needed.  It was the police

 4     or the commander, I don't know who it was, who decided when these things

 5     would be sent out.  Now there arose a huge problem of the shortage of

 6     petrol.  So everybody was economising on this.  The chief was not able to

 7     provide the sufficient amount of petrol.  So everything was done to make

 8     sure that the courier was not sent to Banja Luka for any little errand.

 9     If I needed to have anything sent, I would then use their services, but

10     it was rarely that I would do that.

11        Q.   [Previous translation continues]... I understand you started that

12     answer talking about before the war, was the system with couriers still

13     generally the same after April 30th, 1992?  I take it they went as often

14     as was necessary; is that right?

15        A.   Well, I just told you, the system remained the same.  But even

16     where everything remains the same, if there is no petrol, then nothing is

17     the same.

18        Q.   [Previous translation continues]... I'm sorry, I didn't

19     understand that.  Thank you.  Okay, I think I've lost my audience a

20     little bit so let's not talk about log-books for a while and switch to

21     something else.

22        A.   Yes, there was no petrol and economising with petrol and vehicles

23     and personnel.  There was a shortage of personnel as well so we had a

24     number of problems, not just one.  Under such circumstances, the chief

25     and the commander had to organise things and it was difficult.

Page 24902

 1        Q.   Thank you.  Let me ask you now about something else you talked

 2     about on Monday.  You were at page 24730 talking about the tensions in

 3     town in April/May of 1992, both before -- well, let's talk about before

 4     the Serb take-over and the first month or so immediately after.  You

 5     mentioned that one could feel that in the town and that there were people

 6     who didn't react the same way.  You had a colleague and you maintained

 7     good relations.  What particular colleague were you talking about that

 8     you maintained a good relationship with after the Serbs took over, do you

 9     remember?

10        A.   Well, there were plenty that I maintained a good relationship

11     with.  I don't know.  Well, anyway, if I was thinking of my colleague

12     with whom I was on good terms with and then there was a certain cooling,

13     I think that this was perhaps Ago Sadikovic, this was an inspector who

14     worked with my wife on white collar crime.  But there was also

15     Suljo Dzonlagic who was my colleague from university, he was a neighbour

16     within an engineer as well.  He taught in school.  Until the end I was on

17     good terms with him because those who were friends for a longer period

18     with Suljo, for example, our friendship was never jeopardised, but with

19     Ago there was a kind of cooling in relations without any quarrel or

20     conflict.  It's different from person to person.  It depends.

21        Q.   Those that you just mentioned, do you know if any were detained

22     and taken to Keraterm or Omarska?

23        A.   I don't know about Ago because he didn't sign for that thing in

24     the morning when he came.  I don't know afterwards, I didn't see him

25     after that.  He didn't even live close to me.  As for Suljo, he didn't go

Page 24903

 1     to Keraterm or Omarska.  He managed to join some kind of convoy or

 2     something and now he's in Sydney, I mean he was in Austria somewhere.

 3        Q.   What about Nusret Sivac, did you know him?  He worked in the

 4     state security in Prijedor?

 5        A.   Well, you can ask me about him as much as you want.  I was his

 6     boss.

 7        Q.   Do you know what happened to him after the -- [Microphone not

 8     activated]?

 9             THE INTERPRETER:  Microphone, please.

10             MR. HANNIS:  I'm sorry.

11        Q.   Do you know what happened to him after the Serbs took over in

12     Prijedor?  Wasn't he detained and kept at Keraterm or Omarska?

13        A.   Sivac was detained twice.  I don't know if that's in his

14     statements.

15        Q.   And do you know where he was detained and how he was treated when

16     he was there?

17        A.   Like this, Sivac was a signals operator just like the others.

18     There is that book by Mira Topic from earlier on.  I think there are

19     signatures by him there too until 1989 and then he retired.  The book

20     that we had before this one, there are signatures by Sivac there.  I

21     think you can check that that was until the end of 1989 and then he

22     went -- he retired because he wanted to and also because he had the legal

23     condition.  Sivac was always a communications operator and I was his

24     boss, officially.  Unofficially, Sivac was carrying around a film camera

25     and recorded or taped things part time and sent it to Sarajevo

Page 24904

 1     television.  He made short news items from Prijedor.  Usually in the TV

 2     crew there would be -- the journalist who would be the one in charge, but

 3     he turned that around.  So he was the main person in the crew and he

 4     would always find a journalist.  So the journalists would change but

 5     Sivac would always be there.

 6        Q.   Sorry, let me stop you because my question was do you know where

 7     he was detained and how he was treated when he was there?  Do you know

 8     about that?

 9        A.   I was about to say that.  I was about to tell you.

10        Q.   Please do.

11        A.   And Sivac -- and Sivac was detained, he wasn't working those days

12     that were bad when people were being detained, I didn't have any contact

13     with him.  But then later he said when we met that he was taken away - I

14     don't know who took him away - he was taken to Omarska.  Omarska was

15     already set up by then.  He wasn't detained before that.  As far as I

16     know he wasn't brought in to the SUP, to the police, either.  Perhaps he

17     was, but as far as I know he wasn't.  He was taken to Omarska and there

18     was an interview with him there and then in a day or two Sivac was

19     released as not guilty.  But then he was in Prijedor for a few days, I

20     don't remember how many, and then he was detained again because allegedly

21     in the investigation some new circumstances were established.  And I

22     think that he told me that he was there for 40 days.  Perhaps he wasn't.

23     I don't know.  I can't remember that.  In any event, Sivac was released

24     after his second stay and then he came to me asking me for help.  He said

25     that he wanted to go somewhere, I don't know, Germany, somewhere in

Page 24905

 1     Europe with his own vehicle.  He happened to have a Ford Escort.  He had

 2     a wife and two children.  The children were just like my children, 7 and

 3     10 years old, something like that.  And as I said, at the time there was

 4     no petrol so these people - how shall I put it? - not from the police but

 5     those people who were not respecting the laws, they would seize a car

 6     from somebody for as long as there was petrol in it and then they would

 7     just discard it and take a new one.  So close to some creche next to the

 8     SUP I saw his car just there.  I just noticed it by accident.  And then

 9     he came to me and he said, "Boss" -- he was afraid to come, he was scared

10     to come.  I mean, he had no reason to be afraid, but I guess he did.  If

11     he was afraid, well then let him be afraid.  He asked if I would be able

12     to somehow get this car to him because he wanted to go.  I said I would

13     try.  I didn't do it myself, I sent a technician, Mladen Raus to find out

14     who was driving that car, it was somebody close to the SUP, some kind of

15     reserve soldier or police officer.  In any case, he found the keys to the

16     car, took the car to Sivac, and Sivac used that car to go to Europe.

17     This is it in brief.  I don't know where he went.

18        Q.   Well, that was -- that was more than brief I think.  You've

19     indicated to us you are quite detailed and meticulous --

20        A.   You mean details.

21        Q.   Because I have limited time, I'll have to ask you from time to

22     time to try and keep your answers short and if I need more I will ask

23     more.  Okay?

24        A.   Yes, you just give me a sign with your hand and I will cut it

25     short.  It's not a problem.  I'm trying to adjust it.

Page 24906

 1        Q.   I understand, thank you.  You said you weren't sure what

 2     Mr. Sivac was afraid of.  Wasn't he afraid of the kind of thing that was

 3     happening to non-Serbs in Prijedor at the time, that he might be arrested

 4     and detained again without any criminal charges being filed?

 5        A.   Yes, he was afraid.  But, sir, I was also lying down on a stone

 6     in front of these semi-savage Serbs.  Somebody hit me a number of times

 7     over here.  I was afraid as well.  Perhaps Sivac was a little bit more or

 8     a little bit less afraid.

 9        Q.   I remember you telling us about the incident where you were shot

10     at as well.

11        A.   Yes, yes.

12        Q.   You talked --

13        A.   Not just that.  I was hit by a rifle when I was coming back from

14     Omarska, not hit, I was beaten by brother Serbs.

15        Q.   Army?  Police?  What?

16        A.   I think that even they don't know who they were.  They had old

17     JNA uniforms from Comrade Tito times.  Somebody had trousers, somebody

18     had a shirt, it was an odd combination, somebody didn't have any of the

19     uniform items.  They did have weapons, though, but this was the military

20     I think, not the police.  The police knew me.

21        Q.   You mentioned I think before that you visited Omarska three

22     times.  Which one of your three visits did this happen on, the first,

23     second, or the third?

24        A.   The first, the first.

25        Q.   Thank you.

Page 24907

 1             MR. HANNIS:  I see it's nearly time for our break, Your Honour.

 2             JUDGE HALL:  Yes.  So we would return at 12.25.

 3                           --- Recess taken at 12.02 p.m.

 4                           --- On resuming at 12.31 p.m.

 5             MR. HANNIS:

 6        Q.   Witness, on Monday when you were talking about the situation in

 7     Prijedor after the take-over on 30 April, you talked about a number of

 8     the non-Serbs or mostly Muslims leaving.  And you talked specifically at

 9     page 24735 about a communications worker under you, Mirsad Sahuric, did I

10     pronounce his name correctly?

11        A.   S-a-h, Sahuric, you pronounced it well.

12        Q.   Thank you.  I seldom hear that.  You mentioned that he was

13     probably one of the last ones to leave, but while he was there you said:

14             [As read] "I tried to the best of my ability to make it as

15     comfortable for him to stay in that environment.  I tried as best I could

16     to help him.  There were other colleagues and I as well who helped him to

17     get food-supplies because they were people who did not dare to walk about

18     the town."

19             What was it in Prijedor after the 30th of April, 1992, that made

20     it so uncomfortable for the non-Serbs?

21        A.   It's hard to say.  I'm going to try to be brief.  I mean, this is

22     a complex question.  One would need to write a serious study about it but

23     it's impossible to explain it in ten sentences.  But I will do my best.

24     The gist, and I always say that not just here, everywhere, it's not that

25     the Serbs are no good or the Muslims are good or the other way around.

Page 24908

 1     It's not a battery with a plus or a minus end.  You cannot have a big one

 2     and a small one.  They're always the same but they're opposites.  After

 3     the 30th of April, the day this guy was killed, Japa [phoen], on that

 4     night, somebody killed him, a Muslim, but we never found out who it was.

 5     And the process began.  Every day, every minute, there was a chance you

 6     could get killed no matter who you were.  For example, I concluded for me

 7     it would be better not to wear a uniform because if I wore a uniform

 8     before the war, I didn't have the right to one during the war.  I did.

 9     But if I wore a uniform there was a chance I could be hit by some

10     residential building by some Muslim.  They didn't leave, they were still

11     there, they didn't reconcile them to the situation.  Some people are

12     staying, some are leaving, some people want to go and there was more and

13     more shooting, there were more and more dead people of all ages from all

14     ethnic groups.  And that's why I say I never took a uniform.  Perhaps it

15     was better for some of my people from the police to stop me and search me

16     without a uniform rather than to be in a uniform.  So that situation

17     wasn't any better or worse than any other situation.  And in all of that,

18     this is the main thing, there were shortages of power.  When there's no

19     electricity, you know what happens.  Trade was dwindling down.  There

20     were shortages.  There was no petrol, there was no bread.  I happened to

21     have my wife's parents living in a village nearby, some 15 kilometres

22     away, I mean it's doable by bike.  I couldn't use the car, there was no

23     petrol.  So I would go by bike.  I would get some bread, some vegetables

24     and that's how we lived.  There were no salaries being paid.  So in all

25     of that some people had it good, they made it through, and some didn't.

Page 24909

 1     As time passed, however, and then on the 30th of May when that came

 2     around with that attack, then there was a selection that started to be

 3     made.  Before then there was no selection.  They were not bringing in

 4     citizens, they were just bringing in suspects for existing incidents, but

 5     there was no systematic thing.  Then with the 30th, with the attack on

 6     Prijedor, it all began suddenly so that when I started to listen to the

 7     other side through the media, then I could see how the evil Serbs

 8     couldn't wait to start catching the poor Muslims.  That is not correct.

 9     Earlier when you mentioned Nusret Sivac, he was not an innocent lamb that

10     was brought to Omarska.  He came back for the second time when he was

11     telling me about this vehicle for me to try to get it back for him, he

12     told me:  "Well, boss, I spent" -- I don't know how many days he said he

13     spent in Omarska for nothing.

14             I said:  "No, Nusret, that is not true.  On the 30th of May you

15     were in Obala."  I am telling you Obala is a restaurant around which

16     there was a large battle and one hero of theirs, one of their men was

17     killed and then Kaduc [phoen], a Serb after whom a square now is named in

18     Prijedor.  So there were some battles and that's where Sivac happened to

19     be.

20             And I said, "How come you were there?"

21             And he said, "Well, boss, I came to pick up the money from my

22     private personal slot machine."

23             So I don't know after all he was released twice he could have

24     encountered some fool and something else could have happened and similar

25     things happened to other people in other circumstances.

Page 24910

 1        Q.   Okay.  I understood when you asked to be able to go on a bit that

 2     it's not a simple question to answer and even though you did go on a bit,

 3     you didn't precisely answer the question I was asking which was what it

 4     was about that made it hard for the non-Serbs, the Muslims --

 5        A.   Ask me, yes, go ahead.

 6        Q.   But I think I got part of your answer that did address that.  I

 7     guess after the 30th of May when there had been the attack on Prijedor by

 8     Muslims then it sounds like you're saying there was a much more

 9     systematic rounding up of all kinds of Muslims, not just suspects.  Is

10     that fair?

11        A.   [No interpretation]

12        Q.   I'm waiting for the translation.

13             Could you answer again.  I don't think we got a translation.

14        A.   The first part of the question, what happened and what is the

15     uncomfortable thing for those who are not Serbs before Serbs -- I mean,

16     it's the same answer to the question of what happened to those who were

17     not Muslims in areas where the Muslims were a majority, for example, in

18     some other location.  I mean, you could write a book about it.  That is

19     the essence, though it is complex.  Okay.  That's the first part of the

20     question.

21        Q.   Can I rephrase the question and maybe it will be easier -- maybe

22     it's easier to answer this way.  Is it fair to say in Prijedor

23     municipality in areas where Muslims were a majority, it was difficult for

24     non-Muslims because there was the danger of harassment, discrimination,

25     even violence?  And likewise in the Serb majority parts of Prijedor it

Page 24911

 1     was uncomfortable and dangerous for non-Serbs for the same reasons,

 2     because there were extremist Muslims and there were extremist Serbs.

 3     Right?

 4        A.   That is right, but if you permit me, I will add something.  I

 5     will try to be as brief as possible.  I always think that for anyone who

 6     wants to look at that situation without dwelling on this, then that look

 7     is incomplete.  There is no town or place or area in Bosnia and

 8     Herzegovina and most probably in Yugoslavia, just like the area of

 9     Prijedor and Kozara, where the most recent past from World War II is so

10     horrible.  According to some data, I cannot really talk about that, but

11     the numbers stayed with me.  19.472 children from that area were either

12     killed or expelled.  I'm talking about children now.  To the -- compared

13     to 20- to 30.000 adults.  So this was during World War II.  There is no

14     house in that area, in the area where I was born all of this that we are

15     talking about makes no sense because there were no casualties.  In this

16     area there is no Serbian home that does not have at least one horrible

17     story to tell.  And so this then arises in this semi-literate villager.

18     It would be the same thing as if I, for example, was afraid of having

19     AIDS or some sort of horrible disease because they were in a war before

20     that and before that and so on.

21             And just one more thing.  I don't like to bring out examples all

22     the time, but I think it's important briefly, and I'm not going to

23     mention examples anymore, if you permit me.

24        Q.   Briefly.

25        A.   The moment when I took the dispatch there and read it, I wasn't

Page 24912

 1     so crazy and unaware of the situation and many times when it was

 2     dangerous, but all I had in my head was one guiding thought.  I mean, it

 3     wasn't a thought so much as an emotion and emotions never lead to

 4     happiness in such a situation and that is the following.  A few days

 5     before the start of the war I went out for a walk with my son, who at the

 6     time was 5 or 6 years old and I met an old fighter from World War II, a

 7     Partizan, Mladjo Stanic who didn't know me, but I knew him because

 8     there's only one Mladjo, and there are many such as I, myself.  I didn't

 9     ask him anything and he was speaking and he was already a bit off his

10     rocker, mentally.  So I didn't ask him anything but he was going and

11     speaking, "These people in the municipality are fools" - and he meant the

12     multi-party assembly - "I have been telling them why are you fighting?

13     You will cause a war and they don't want to listen to me and because of

14     these" - and he showed -- pointed to my child - "in 1941 so-and-so called

15     me or let me know," he mentioned the names in Kozara, "they took away the

16     children towards the Krecane, the local Ustashas caught them.  I was

17     running behind them with my fighters to catch up with them, but they had

18     already killed the children.  One male child they had impaled on a small

19     pine and it was plucking at the blades of grass and I am still all shaken

20     up about it."

21             It's a horrible story and I cannot forget it to this very day and

22     it's much worse for those whose forefathers, their grandfathers, were a

23     part of that.  Perhaps some of them can restrain themselves and some of

24     them cannot.  Because all of this -- this is a very uncommon region and

25     everything that can be critically looked at from the side has to be

Page 24913

 1     looked at in the light of what applies to them is one thing and that does

 2     not apply to everybody else, it's just not the same situation.  This is

 3     how I see things.

 4        Q.   Okay.  I understand what you're saying there.

 5             But because of those -- those kinds of strong feelings, wasn't

 6     it -- not only was it in Prijedor hard for your former coworker

 7     Mr. Sahuric, it was also difficult for you, wasn't it, as a Serb to try

 8     and help a non-Serb because that was just as dangerous in a way.  Those

 9     Serbs who had hard feelings about the Muslims and made life hard for them

10     in Prijedor would make life hard for you if they found out you were

11     helping a non-Serb; right?

12        A.   Yes, yes.  However, a person always builds a defence mechanism of

13     sorts.  I believe in God and I believe that if I do good that I will fare

14     well.  And I also know that a good person cannot get in harm's way, I

15     don't know why.  But most of the time it turns out to be true.

16        Q.   All right.  Let me now go and talk about April 9th.  This is the

17     meeting that you told us about that you had the notes from.  Do you

18     remember that?  We looked at your handwritten notes --

19        A.   Yes, yes, what I said or the day before.

20        Q.   I had some questions based on what you said on Monday.  I wasn't

21     clear about a few things.  At page 24.755 you mentioned that:

22             [As read] "Somebody brought a prototype of the badge to show what

23     it would look like."

24             I think this was the three-coloured flag, the wavy flag that you

25     mentioned.  Do you remember who that was who brought that insignia and

Page 24914

 1     showed it at the meeting?

 2        A.   I didn't say "someone."  Perhaps you didn't hear it.  It was

 3     Mr. Zupljanin who brought it along.  That's the feeling I have.  Yes,

 4     that was him.  He said that that was the symbol that was proposed for

 5     this police force of ours.

 6        Q.   Okay.  Thank you.  I wasn't clear on what it was.  And then you

 7     said:

 8             [As read] "I think that the chief didn't even take the badge for

 9     himself.  He gave it to Zijad Basic and said, 'Your wife is a Serb.  Why

10     don't you take the badge?'"

11             Which chief were you talking about there, Talundzic or Zupljanin?

12        A.   No, no, Zupljanin, I think it was him, yes.  I do allow for the

13     possibility that I am mistaken, but that's the way I remember things.

14     After the meeting Zijad was showing us the badge and he was pleased.  He

15     wasn't angry about it.

16        Q.   In your note, I think one of the last notes you had a remark that

17     you said referred to your own comments and you said you spoke about the

18     concrete agreement or the specific agreement for us to be united.  What

19     specific, concrete agreement were you referring to when you said that?  I

20     didn't understand.

21        A.   If I understood you now, it was there at the meeting that we were

22     supposed to come to an agreement, not that we were supposed to draw up an

23     official agreement.  Rather, that we were supposed to come to an

24     agreement through our discussions, to be united, to have a single voice,

25     to have the Prijedor station as part of the centre.  Why would we be an

Page 24915

 1     island within a region?  It was in that context that I mentioned it.  I

 2     don't recall these words specifically.

 3        Q.   Was that in relation to what I think you had reported that

 4     Mr. Zupljanin said "you all," meaning you police in Prijedor needed to

 5     resolve it among yourselves about whether or not you were going to go

 6     with Banja Luka or go with Sarajevo.  Was it in connection with that?

 7        A.   It's a compound question or perhaps a bit complex.  I'm afraid I

 8     didn't understand it.  The story boiled down to the chief saying that we

 9     were supposed to arrange our relations within the centre.  He didn't say

10     you do it.  He said, "We will set about doing it.  We have the badges

11     proposed here.  All the other municipalities have agreed to it.  We hope

12     you will as well."  That's the gist of it and then there was later on the

13     decision that Prijedor and Kotor Varos would be exempted.  It was within

14     that context that the conversation took place.

15        Q.   Okay.  All right.  Now, you explained a little bit about the

16     notes that you took and you said that you acquired a habit over the time

17     of making "... such cryptic notes that would be clear only to me and

18     nobody else.  For that reason it makes no sense to seek something and to

19     read into this document.  I'm the only one who can make use of that

20     document."

21             I understand that way of doing things.  I've done that myself.

22     But let me ask you:  Have you ever had the experience of going back after

23     a long period of time and looking at some of your cryptic notes and not

24     being able yourself to remember what the cryptic parts meant?  Does that

25     ever happen to you?

Page 24916

 1        A.   Yes, but in some other notes, not this set.  Perhaps one in a

 2     hundred, very rarely, and it doesn't apply to these notes.

 3        Q.   Okay.  That was my next question.

 4        A.   When I was younger it never happened, but now it does more

 5     frequently.

 6        Q.   Welcome to the golden years.  You said that -- then you were

 7     asked after this meeting if there were any changes that occurred before

 8     the end of April, and specifically about whether the Serb insignia or

 9     these new tri-coloured flag insignia were used.  And you said:

10             [As read] "No, they were not attached.  As far as I know we

11     received a dispatch from the centre saying that Prijedor and

12     Kotor Varos" --

13        A.   Surely not before the take-over.  Afterwards, yes, but I don't

14     know when.

15        Q.   Let me show you Exhibit 2D18.  This is tab 60 in the Prosecution

16     binder.  I can hand you a hard copy.  Sorry, the record said tab 6-0 but

17     I meant 16, 1-6.

18             This is a dispatch from CSB Chief Zupljanin.  Is this the one you

19     were referring to?  It's dated the 16th of April.

20        A.   The only thing I remember is that there was a dispatch and that

21     the message was what is written here.  I suppose it dates back to the

22     discussions I had with a representative of the Prosecution.  I don't

23     remember anything else.  But it must be the dispatch.  I don't think

24     there's any other.  This does not refer to Prijedor and comes from this

25     time-period.  That I remember.

Page 24917

 1        Q.   Okay.  And you'll see in the body of the text, I think it's the

 2     fourth paragraph referring to the insignia, it said that:

 3             "The obligations do not apply to the Prijedor and Kotor Varos

 4     SJB.  They can continue to wear the current insignia until the political

 5     situation in these municipalities is solved."

 6             Do you see that?

 7        A.   Yes, I do.

 8        Q.   And the way the political situation in Prijedor was resolved was

 9     two weeks later the Serbs took over; right?

10        A.   Well, this is a political question.  Please don't put political

11     questions to me.  I have no knowledge of that.  It would be very

12     irresponsible of me to say either way.  I don't know.

13        Q.   Well --

14        A.   What did the take-over of power bring?  Was it good or bad

15     things?  Time will show.  I don't know.  Things were different; that much

16     is true.

17        Q.   Okay.  But --

18        A.   As for anything else, I think people wiser than me should be the

19     ones to judge that.

20        Q.   But really, Mr. Jankovic, between the 16th and the 30th of April,

21     there wasn't like any free election in Prijedor about whether or not our

22     police should wear this new insignia; right?  The thing that happened was

23     that there was a take-over by the Serbs on the 30th.  That's how the

24     situation was resolved and the police started wearing the tri-coloured

25     insignia; right?

Page 24918

 1        A.   I don't quite understand.  Is this a question you're putting to

 2     me?  To me it is a political statement you're putting to me rather than a

 3     question.  Please ask me a question and I'll try and answer it.

 4        Q.   I'll ask you another question that's more in your field.  At the

 5     top we see a number of names written and at the very top the letter R.

 6     Can you tell me what that refers to?  Does that have to do with

 7     distribution of this message?

 8        A.   Yes, precisely so.  It was written by the secretary.  The letter

 9     R is short for "raspis," which stands for distribution.  You would copy

10     this and distribute among a number of recipients.  And then I can read

11     out the names for you, if this means anything.

12        Q.   Let me ask you a couple of questions first.  The Serbian word you

13     use, "raspis," I think has been translated into English before as

14     "circular".  I don't know if I can inquire of the interpreters if that's

15     right.

16        A.   Well, by function it is similar, very similar.  Let's say we have

17     this one document and I have to send it to five recipients, so I make

18     five copies and distribute the document to them.  So in a way, yes, you

19     could say that it was a circular.

20             THE INTERPRETER:  Interpreter's note:  Not necessarily the

21     immediate translation of the word.

22             MR. HANNIS:  Okay.  Thank you, interpreters.

23        Q.   And thank you, Witness.  In this case, "R" refers to what?  To

24     whom else was this message sent?  Did this thing go to Sanski Most and

25     Novi and ... ?

Page 24919

 1        A.   Well, no.  When such a handwritten note is made by the secretary,

 2     it is only for our purposes.  I think it was the secretary, Mira, who

 3     made this note and I don't know who wrote the word "raspis."  It may have

 4     been Hasan.

 5        Q.   I thought maybe it was the secretary, Mira, but I see M. Topic is

 6     listed as one of the persons on here --

 7        A.   This is her handwriting, whereas this other is not.

 8        Q.   Where you're pointing to is the top middle where it has the

 9     number 11-12/363 and the date of 16 --

10        A.   It is Mira's handwriting, yes, yes, for sure.

11        Q.   Okay.  On the right --

12        A.   Whereas this other definitely is not.

13        Q.   Okay.  And on the right that Jankovic, that first one, is that

14     Dusan?

15        A.   Yes.

16        Q.   Okay.  And you're the one that's M. Jankovic?

17        A.   Milos, M.

18        Q.   Kadiric was the commander?

19        A.   Yes, Fikret, the commander.

20        Q.   [Previous translation continues] ... who was Mihic?

21        A.   Mihic was the head of the crime police, those who were in

22     civilian clothes.

23        Q.   And the other two names under you, who were they?  Temcuk,

24     Sormaz?

25        A.   This tells us something else.  The first row above the line lists

Page 24920

 1     the individuals who are more important, whereas those below the line are

 2     not as important.  Jankovic, that's me, Rada is the person from the

 3     accountancy service, the one who was in charge of the payroll, works for

 4     the police but is not an authorised official.  That was Rada Temcuk,

 5     finances Ranka Sormaz, she was charged with identity cards, passports,

 6     et cetera.  So she was unimportant, just as I was.  And OM, 3 copies,

 7     that's for the three branches or substations, namely Ljubija, Kozarac,

 8     and Omarska.

 9        Q.   Okay.  Let me show you a related document to that, it's P651 at

10     tab 17 of the Prosecution's binder and with the usher's help, I'll hand

11     you a hard copy and trade you for the one you've got right now.

12             This one is also dated the 16th of April and it appears to come

13     from Chief Hasan Talundzic and it appears that he's simply forwarding

14     that one that we were just looking at.  So is this one that was forwarded

15     on from Prijedor to Sanski Most, Novi, and Dubica?

16        A.   No.  This is a follow-up on the story from the previous document,

17     where I said distribution or circular, where a number of copies had to be

18     made -- well, this is one of those copies.  It's just that on the others

19     that were sent you wouldn't have Temcuk as the addressee but others.  As

20     I said, we were the public security station and Hasan Talundzic was in

21     charge of our station only.  The Sanski Most station was an independent

22     one.  Perhaps they received this dispatch from the centre.  I am not in a

23     position to know that.

24        Q.   So who did this go to from the chief?  Is this just an internal

25     memo in Prijedor SJB or who does it get circulated to?

Page 24921

 1        A.   Well, yes, of course.  Within the CSB and the list of addressees

 2     was contained in the previous document, you were able to see that.

 3        Q.   So here where it says "circular letter" it refers simply to those

 4     people we saw named on the last document and nobody else in Prijedor SJB?

 5        A.   Yes, yes.  If I can add something, we had the line in the

 6     previous document where it said "3x OM," there had never been three

 7     police substations.  Ljubija was always a station and apparently the

 8     author of the document was unaware of this.  It was most probably Hasan,

 9     since he had been there for a very short time and he was a superior of an

10     organisation he was not familiar with.  Those who were more knowledgeable

11     and experienced would not have written something like that.  Of course

12     physically it was Mira writing it up, but he chose the numbers -- I mean

13     the names that were amongst the addressees in the previous document.

14        Q.   Okay.  Okay.  Judge Harhoff, when you were talking about the

15     April 9th meeting, at page 24768, asked you about Mr. Zupljanin exempting

16     Prijedor and Kotor Varos from having to wear the new insignia for a

17     while.  And then he asked you what else Mr. Zupljanin actually did to

18     help.  You said that Zupljanin was speaking in a reconciliatory tone and

19     trying, in your view, to calm the situation down.  Don't you think that

20     given the circumstances of that meeting at that time, April 9th, 1992,

21     and the number of Muslims in the police department, coming to that

22     meeting with that new insignia might make some of the non-Serbs, the

23     Muslims, in the Prijedor SJB feel uneasy about the situation?

24        A.   As for this issue, I wouldn't be able to tell you, even as I

25     think about it on my own without your question.  I don't know how

Page 24922

 1     millions of people feel in their own state where they wear their own

 2     insignia and where is that boundary between this feeling of bearing one's

 3     own insignia or somebody else's?  Since I have no personal experience, it

 4     is very difficult to proffer any opinion.  I recall His Honour's

 5     question.  I did think about it later.  What was the merit of

 6     Mr. Zupljanin?  Well, I could sum it up in the following.  What is the

 7     merit of head of fire brigade once that fire brigade was able to save

 8     only three houses from burning down?  That's how I view the situation.

 9        Q.   Okay.  I understand what you're saying and I'm, you know, I'm

10     glad I didn't have to live through what you lived through or be in that

11     place at that time.  I think it was --

12        A.   Well, you were lucky in that.

13        Q.   Yes.  But you said you thought about what Mr. Judge Harhoff had

14     asked you.  Let me ask the question this way and see if you might have an

15     answer for it.  If it had been the other way around.  What if it had been

16     Hebib or somebody coming from Sarajevo and telling you all in the

17     Prijedor station that from now on you were going to wear this new

18     insignia with the three lilies or the crescent moon?  How do you think

19     the Serbs in Prijedor SJB would have felt about that?  Wouldn't they have

20     felt uneasy?

21        A.   Well, that was not an assumption.  It was a reality in some other

22     areas because in our region some stayed behind, others left, and that was

23     true for other areas.  All of these were lived-through realities.  This

24     happened in Prijedor.  The situation that happened in Zenica was the

25     inverse one as well as in Bihac.  Who was right?  That I don't know.

Page 24923

 1        Q.   No, my question, though, wasn't about who was right or wrong.  It

 2     was about how a particular group felt.

 3        A.   How they felt?

 4        Q.   Yeah, I was asking you originally how do you think the Muslim

 5     police in Prijedor felt when Mr. Zupljanin came and was proposing that

 6     they wear this new insignia.  And you said you couldn't know that, you

 7     didn't know how they felt.  So I gave you sort of the reverse question

 8     and said how would you and the other Serbs in the Prijedor SJB feel if it

 9     had been --

10        A.   Yes, I understand what you're saying.

11        Q.   [Previous translation continues]... You wouldn't have felt

12     uncomfortable if somebody tried to get you on April 9th to start wearing

13     an insignia with the Bosnian emblem?

14        A.   What is at stake is the feelings of every single individual.  You

15     remember when I spoke of that meeting where that dispatch was received?

16     I told you that there was several hundred people present there and that

17     only few of them said that they were opposed to the idea.  Everybody else

18     was in favour of us joining Sarajevo.  Why?  Well, the motivation was the

19     salary.  Well, and then if you come up with this idea of the insignia

20     coupled with secure money, some people will fall for it.  There is no

21     point in me giving you a universal answer.

22        Q.   We'll talk about the 29th meeting and I wasn't trying to tie the

23     insignia to salary because I understand salary is a different motivation

24     that may motivate everybody whatever their ethnicity is.  Let me continue

25     on with one more question about the 9th of April and then we'll go to a

Page 24924

 1     different topic.  One of the last things you said about the meeting was

 2     that you were concerned that "... they had the opportunity to decide that

 3     fate of ours, and in that context I was bit concerned by the fact that

 4     these two took up such a hard line where they wouldn't desist an inch."

 5             I just want to be clear.  I understood there you were talking

 6     about Hasan Talundzic and Fikret Kadiric?

 7        A.   Fikret.

 8        Q.   What was his last name, Kadiric?

 9        A.   Kadiric, right.

10        Q.   That's who you meant who were taking a hard line and not --

11        A.   Yes, yes.

12        Q.   And then you were asked about something you said earlier where

13     you said your higher-ups did not want a war and you were asked who you

14     meant by your higher-ups.  And you said:

15             "My minister, my president of the country, or my prime minister."

16             Can you tell me who you meant in that context.  Who was your

17     minister?  Who was your president of the country?  Who was your prime

18     minister when you said that?

19        A.   Yes, that's what I said.  But I really have to explain that.

20     Why?  For a long time, relatively long time until that time, I was in the

21     police so I had learned to be thinking in a police way.  So for me it was

22     only Mr. Zupljanin there.  As for everything else, I wasn't interested in

23     the name of the minister or the name of the president of the state, but I

24     know that their will was being carried out through him.  This is what I

25     believe.  So you cannot have the minister, for example, asking for one

Page 24925

 1     thing and then the chief of the centre to come and to be saying something

 2     else.  No name was put forward.

 3        Q.   No, no, but this was your answer and you said --

 4        A.   Yes.

 5        Q.   Who were you referring to by name?  Who was your president of

 6     your country?  Who was your minister --

 7        A.   Am I not clear?  Am I not clear?

 8        Q.   No --

 9        A.   In my police system of thought there are no names, there is just

10     him and then above him those up there.  There are no names.  Those up

11     there.  And as they say that what he says is the will of those --

12        Q.   [Previous translation continues]... but the reason I -- but the

13     reason I --

14        A.   What reason?

15        Q.   The reason I asked the question and asked for names as to who

16     you're referring to is that on the 6th of April Bosnia had been

17     internationally recognised by European Union and United States.  So in

18     essence in that area there were arguably two presidents of the country

19     and two ministers because there was Minister Mico Stanisic of the Serb

20     Republic of Bosnia and there was Minister Delimustafic of the other MUP.

21     And there was President Karadzic of the Serb Republic of Bosnia and there

22     was President Delimustafic -- Izetbegovic.  So who were you referring to

23     when you said "my minister" and "my president"?  By name which ones were

24     you talking about in that answer on April 9th?

25        A.   Well, let me tell you, this is a political question and the proof

Page 24926

 1     that I don't know politics and that I'm not interested in that is that

 2     for three years I don't have a television and I don't even have a mobile

 3     telephone.  In my service I'm just listening to my superior, to my chief

 4     of the centre -- not the centre, actually, the chief of the station of

 5     course who's my immediate superior.  And then if it should come in -- I

 6     mean, if the chief of the centre would come as he would from time to time

 7     and says something, I do not doubt that what he says is in accordance

 8     with the official state policy and I don't think that it is.  I think

 9     whatever he says would be in line with that.  I don't even know the dates

10     when and who was there.  So what I'm saying is actually true.  You can

11     check that right now I don't have a TV in my house, meaning that I don't

12     listen to any news.  Perhaps I'm not like any other regular man, but

13     that's how it is.

14        Q.   I believe you that you don't have a TV in your house.  I won't

15     pursue that any further.

16             Let me show you another exhibit, this is tab 34.  It's

17     65 ter number 20063.  With the usher's assistance I'll hand you a hard

18     copy.  I think you mentioned before after the take-over on the 30th of

19     April that people were required to sign a solemn declaration in the

20     Prijedor police station.  Is that right?  Now that you were working in

21     this new police station of the Serbian Republic of Bosnia, later called

22     the Republika Srpska, everybody was required to do a new solemn

23     declaration, right, in Prijedor?

24        A.   Yes, yes.

25        Q.   Did you sign one yourself?

Page 24927

 1        A.   What?  You mean solemn declaration like this?  Well, I don't

 2     recall that I did, but I think that I had to have signed it because

 3     somewhere it must state that I did.  I did not sign it that morning when

 4     those who came to work that morning signed it.  I wasn't there.  Later I

 5     had to have signed it.  I think that I did.

 6        Q.   Do you know the person named on this document, Zivko Andzic, did

 7     he work in Prijedor?

 8        A.   I don't know, I don't know.  There were many reserve policemen

 9     who stayed after that.  I don't know this man.

10        Q.   Okay.  And I take it you don't -- do you remember, did you read

11     the declaration that you signed or did you just sign it?

12        A.   Yes, yes, perhaps I read it out of curiosity -- well, as but --

13     if it were important to me or not, I don't know.  When everyone signed

14     it, I signed it too.  Perhaps I read it.  I don't remember if I did or

15     not.  Perhaps I was rushing off somewhere, so I just signed and didn't

16     read it.  I don't remember.  Probably somebody was making lists to make

17     sure that each of the employees did sign it and I don't believe that my

18     name next to that was blank.

19        Q.   Okay.  And do you remember signing a similar declaration when you

20     first joined the police back in 1980?

21        A.   Yes, it was almost identical to this.

22        Q.   Okay.  But not exactly identical; right?

23        A.   Well, first of all, it wasn't in the Cyrillic script, but the

24     sense of it was -- it wasn't the same gazette, it was a different

25     gazette, and so on and so forth.  But the sense of it you could say was

Page 24928

 1     the same.

 2        Q.   Do you remember how many people in Prijedor declined to sign the

 3     new solemn declaration?  Was it very many?

 4        A.   As I said -- I mean, I said that yesterday more or less.  A

 5     smaller number stayed.  Perhaps those who were working in the offices,

 6     four or five.  As for the police working on the ground, I don't know.  I

 7     don't know how many of them stayed.  I didn't get that information

 8     through my work and there's no need for me to go around asking who did.

 9     I don't have the right or the need to do that.

10        Q.   Okay.  Do you know of any Serbs in Prijedor SJB who didn't sign

11     the declaration and stopped working after 30th of April, 1992?

12        A.   There were those who didn't come to work and then after a day or

13     two they did come.  I guess they were afraid that there would be shooting

14     so they ran away, but then when they saw that there would be no shooting

15     they came back, they came back for the salary.

16        Q.   All right.  Let me show you another document.  This is at tab 57.

17     I'll give you a hard copy of that one --

18             JUDGE HARHOFF:  Mr. Hannis.

19             MR. HANNIS:  Yes, Your Honour.

20             JUDGE HARHOFF:  Before we leave this document we could perhaps

21     try and clarify with Mr. Jankovic just how he understood the letter-head

22     of this solemn declaration.

23             Because, Mr. Jankovic, when you said that the gist of the

24     declaration that we have in front of us was the same as the one that you

25     had signed when you first entered the MUP forces back in the 1980s, the

Page 24929

 1     difference would seem to me to be the very first word of the letter-head

 2     of this declaration that we have in front of us.  And so my question to

 3     you, Mr. Jankovic, is:  Are you able to tell us whether any of those who

 4     refused to sign the solemn declaration, regardless of their ethnicity,

 5     refused because of the allegiance that you were now supposed to pledge

 6     towards the Serbian Republic of BiH?  Was that the reason why some

 7     members of the MUP refused to sign, do you recall?

 8             THE WITNESS: [Interpretation] As far as I remember, that morning

 9     when they were supposed to sign when they came to work, there was no

10     form.  There was just a kind of list.  The form appeared later.  I think

11     that that morning the form wasn't the way it is now and these people

12     signed some paper, a list of names.  As for this, who made it,

13     distributed it, signed it, I don't remember that, and the date is the 5th

14     of May, so five days later.  Somebody made that later, but it was being

15     signed already in the morning, that first morning.

16             JUDGE HARHOFF:  Let me put my question to you in a different way

17     then.  Were you aware when you signed this declaration on that morning

18     that you were now pledging allegiance to the RS?  Was that clear to you?

19             THE WITNESS: [Interpretation] Well, let me repeat this right

20     away.  I said that that morning when they were signing that list, I

21     didn't come there because I was away on some other tasks and I came to

22     the station later.  And I probably signed it then, maybe not the list.

23     As for this, the question whether I was aware -- well, you know what it's

24     like when the mass sets off.  If everybody's going to die, I'm going to

25     do that as well.  There's no question, if everybody signed, I'm going to

Page 24930

 1     sign it too.  But then as a result of that, there are other questions

 2     that follow.  If I don't sign, what am I going to do, how am I going to

 3     manage?  What am I going to do?  I have two children, an apartment, I'm

 4     living in a certain environment.  Roughly speaking, there are two groups

 5     in the population, there's the Serb side, the Muslim side.  Which side am

 6     I going to join?  I mean, it's not a wrong question.  I didn't declare

 7     myself as a Serb or a Muslim myself, I mean the nature would pull me one

 8     way, but as for the political and legal aspects of that question -- well,

 9     I never thought about that.  I don't know about the meaning of that now.

10     I mean, I was as sincere as I can be.

11             JUDGE HARHOFF:  But, Mr. Jankovic, it must have occurred to you

12     by the time you signed this declaration that this would have an impact

13     because you were now choosing side, weren't you?  And so since you

14     probably made those considerations yourself, I would imagine that you

15     also considered the reasons why some of the colleagues of yours did not

16     sign that declaration, meaning that they too had chosen a side but that

17     they had chosen the other side by refusing to sign.  Didn't this occur to

18     you?

19             THE WITNESS: [Interpretation] First of all, the events were fast

20     and furious then, so I didn't even have time to think.  Perhaps now that

21     we're free and we can think about and ponder things.  At the time what my

22     thing was was to organise the communications and -- well, it was I can't

23     say general chaos, but it was.  At that first initial moment I didn't

24     even think of a yes or a no, but there was no paper like this either.  I

25     said that I do not recall this paper.  I have a feeling I'm seeing it for

Page 24931

 1     the first time, but I believe I probably am not seeing it for the first

 2     time, that it exists, that I did sign it.  When I look at the date I

 3     think I could not have gone without signing it then.  So I simply went

 4     with the majority, and for me that was the only possible thing to do at

 5     the time and sufficient.  As for how I would fare in the end, would I

 6     die?  Well, I would fare just like the rest.

 7             JUDGE HARHOFF:  I'm not sure we can get any further here.

 8             Mr. Hannis, back to you.

 9             MR. HANNIS:  Thank you, Your Honour.

10        Q.   Let me show you another exhibit now.  This is P790.  It's tab 57.

11     And if I can trade this one for that one.  This is dated the 29th of May,

12     1992, and it's a list of Prijedor police station employees who signed the

13     solemn declaration and of those who did not.  I think on the back you'll

14     see it has the name of Dusan Jankovic as the station commander.  Can you

15     have a look at the back page.  Can you have a look at the back page, and

16     you see Dusan Jankovic's name as the commander, but it looks like

17     somebody else has signed for him on the bottom right at the back page.

18     Do you find it.  Is that Kecan?

19        A.   Looks like that.  I cannot say but it does look like Kecan as far

20     as I'm concerned.

21        Q.   And who was Kecan?

22        A.   Assistant commander.

23        Q.   Thank you.  You see, we've got I think 72 names of people who

24     signed it and 41 names who did not.  Based on your own personal knowledge

25     do you have any reason to disagree with this list as far as those who

Page 24932

 1     signed and apparently stayed on working there and those who didn't sign

 2     and therefore didn't continue to work in Prijedor?

 3        A.   I saw this list once when the gentleman from the OTP spoke with

 4     me earlier and I'm seeing it now, and since this is a list of workers of

 5     the SN -- the police station of Prijedor, this is above my organisational

 6     unit, I know the name -- the people by name.  I don't know anything else,

 7     what -- I mean anything else I would say would be superfluous.  What

 8     would I have to say about somebody else's organisational unit, the one

 9     with this commander?  At that time I had five or six workers.  I don't

10     know if I had to write about anybody then.  I didn't see this list

11     before, never really thought about it.  I don't have much thoughts about

12     it now either.

13        Q.   No, but I guess the point is you must have known several of these

14     people because they worked as police in Prijedor at the time you were

15     working there and you'd been in the police since 1980.  Didn't you know

16     most of these people by name?

17        A.   No, not most of them.  But, for example, I know Vahid Rizvanovic,

18     Mevlida Boric, I recall her a little bit.  Ermin Alagic.  There were

19     stations that were outside of Prijedor.  I said -- I mentioned these two,

20     but then also in Prijedor the police has their post on the street so I

21     know that it's a policeman.  When I encounter him I greet him, but I will

22     say which ones I know.  Are you saying those who didn't sign?  Who are

23     you thinking of exactly?

24        Q.   Well, of the names you know, is there anybody who is not

25     correctly listed if you understand what I mean.  Do you see anybody you

Page 24933

 1     know who is listed as having signed who did not continue to work or do

 2     you see anybody who is listed as having not signed who did continue to

 3     work?  Do you understand my question?

 4        A.   Yes, well, I don't know.  Why don't I know?  I don't know because

 5     I don't know about this action by the commander who signed and who did

 6     not.  As I say, I'm seeing this list for the first time.  I saw it from

 7     your associate.

 8        Q.   But what I'm saying is of the people you know do you see somebody

 9     on the list who did not sign who was still working after this date, 29

10     May, of those 41?  Any of those 41 who did not sign who you personally

11     know, did you see any of them still working for the police after 29 May

12     1992?

13        A.   The actual act of signing was so significant for me that I don't

14     know whether I signed it or not.

15             THE INTERPRETER:  Could the witness please be asked to repeat the

16     rest of his sentence.

17             MR. HANNIS:

18        Q.   The interpreters are asking if you could repeat the rest of your

19     sentence.  They didn't catch it.  Could you repeat your answer, please.

20        A.   I will be briefer and more slow, meaning the act of signing this,

21     as far as I'm concerned, was so significant that I don't even know if I

22     signed it or not.  I think that I did but I'm not sure.  Perhaps I did

23     not.  And because of that fact how can I know in the police station

24     whether such and such a person signed it or not?

25        Q.   No, no, that's not my question.  There's a list of people who

Page 24934

 1     Kecan or Dusan Jankovic are indicating did not sign.  The practical

 2     effect at that time, according to directions from Mr. Zupljanin in

 3     Banja Luka was that those who didn't sign couldn't continue to work in

 4     the police.  Now, do you know any names on the list of 41 on that

 5     document who did not sign?  Do you recognise any of those names among the

 6     41; and if so, tell me which ones?

 7        A.   Well, I have to be as specific as possible again.  The commander

 8     who was here, Jankovic Dusan, he made that list and then he went to his

 9     superior and handed it over.  For example, I have nothing to do with

10     that.  For example, I meet Jankovic, Dusan, I know him, I don't ask him

11     Dusan, did you sign it or not.  You don't ask people things like that.

12        Q.   You don't need to talk to him or know him to answer my question.

13     Let's take it one step at a time.  First of all, the names on the right,

14     1 through 41, do you know any of those people?

15        A.   Yes, the right side.

16        Q.   [Previous translation continues]... and if so, tell me the number

17     and name of the ones you do know or did know in 1992?

18        A.   Well, I remember the name.  I don't know where she was working,

19     Mevlida Boric; Ermin Alagic, I don't know; Edin Mrkalj, policeman, I

20     forgot his face, I don't know anything more; Senad Mujkanovic, I don't

21     even remember the name; Maid Bahonjic, never heard of him; Mirsad Alic, I

22     don't know about him --

23        Q.   And give me the number along with the name.  It will make it

24     easier for all of us.

25             JUDGE HALL:  Mr. Hannis, it appears to me this is going to take a

Page 24935

 1     little while so perhaps we should pick this up tomorrow morning.

 2             MR. HANNIS:  I think that's an excellent idea, Your Honour.

 3     Thank you.

 4             JUDGE HALL:  And perhaps he can keep the document overnight.

 5             MR. HANNIS:  I am happy to have him do that.

 6             JUDGE HALL:  And if I may assist, Mr. Jankovic, as I understand

 7     Mr. Hannis's question, it is this:  Assuming that the document is

 8     accurate in terms of those on the right as having not signed, so in other

 9     words you don't have to apply your mind as to how the names got there,

10     how this was prepared, but beginning with the assumption that that's an

11     accurate list of those who did not sign, there apply your mind to

12     Mr. Hannis's question and as we said you can keep the list overnight and

13     then he will resume tomorrow morning.

14             So we take the adjournment and continue at 9.00 tomorrow morning.

15                           --- Whereupon the hearing adjourned at 1.43 p.m.,

16                           to be reconvened on Thursday, the 13th day of

17                           October, 2011, at 9.00 a.m.