Tribunal Criminal Tribunal for the Former Yugoslavia

Page 24936

 1                           Thursday, 13 October 2011

 2                           [Open session]

 3                           [The accused entered court]

 4                           --- Upon commencing at 9.06 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 take the appearances, please.

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

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

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

14     Slobodan Cvijetic, and Ms. Deirdre Montgomery appearing for Stanisic

15     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.

19             We are informed that there is one matter the Defence has before

20     we call the witness back to the stand.

21             MR. KRGOVIC: [Interpretation] Yes, Your Honour, just a brief

22     procedural matter.  Mr. Zupljanin's Defence submitted on the 30th of

23     September a motion asking to change the manner of testimony of

24     Witness SZ-012 and to have him testify by way of 92 bis.  The Prosecution

25     responded to the motion by the Defence, seeking that the whole transcript

Page 24937

 1     and exhibits be admitted, specifically two of them that were referred to,

 2     65 ter numbers 20279 and 20280.  The Defence would like to inform the

 3     Trial Chamber that they have no objection to the admission of these two

 4     exhibits.  So I think that we can resolve this matter of having this

 5     witness testify pursuant to 92 bis.

 6             JUDGE HALL:  So noted.  Thank you, Mr. Krgovic.

 7             So could the usher please escort the witness back to the stand.

 8                           [The witness takes the stand]

 9             JUDGE HALL:  Mr. Jankovic, good morning to you, sir.  Before I

10     invite Mr. Hannis to resume his cross-examination, I remind you, you're

11     still on your oath.

12             Yes, Mr. Hannis.

13             MR. HANNIS:  Thank you, Your Honour.

14                           WITNESS:  MILOS JANKOVIC [Resumed]

15                           [Witness answered through interpreter]

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

17        Q.   Good morning, Witness.  When we left off yesterday afternoon --

18        A.   Good morning.

19        Q.   -- when we left off yesterday afternoon I think you and I were

20     both a little tired but we were trying to go through that list.  It's

21     Exhibit P790 at tab 57 in the Prosecution binder.  Did you have a chance

22     to look at that overnight and if so were you able to tell us now whether

23     any of the people listed among the 41 who did not sign the new solemn

24     declaration, did any of them continue to work in Prijedor SJB?

25        A.   Yes, I did read it.  I did read the list.

Page 24938

 1        Q.   And, first of all, let me ask it this way.  How many of those 41

 2     names of those who did not sign did you know?

 3        A.   Well, I didn't count, but if you like I can go over all of them

 4     and tell you.

 5        Q.   It's not so important how many you know.  I guess the question I

 6     want to know is -- because --

 7        A.   40 per cent.

 8        Q.   Okay.  What I'm trying to understand is:  It's my understanding

 9     that none of them continued to work, they all left.  And if I'm wrong

10     about that, tell me who stayed.

11        A.   This is the date, the 29th of May, that's the day before the

12     attack on Prijedor.  That's when the big mess happened so I don't know

13     where some of the Serbs were either.  Perhaps I did meet some of them,

14     but I don't remember who I met and where.

15        Q.   But my question is:  After the 29th of May or the 30th of May,

16     are any of those 41 people still working in June and July, August of

17     1992?  They were all gone, weren't they?

18        A.   I don't know.  I don't know.  The station is physically -- is

19     actually quite far away from me, work-wise.  Not physically, but as far

20     as work is concerned, it's quite remote.  I don't -- I didn't co-operate

21     with those people so I really don't know.

22        Q.   Okay.  Let's move on to another document then, if we could look

23     at P377.  This is at tab 52.  And I can give you a hard copy of this one.

24     I'll exchange it for that other one, if I may.  Thank you.

25             Now, Mr. Jankovic, this is what appears to be a telegram dated

Page 24939

 1     the 28th of May, 1992, from Chief Zupljanin to all SJB chiefs.  And he's

 2     saying, basically informing, that all employees who did not sign the

 3     solemn declaration are dismissed as of the 15th of April, 1992.  Did you

 4     know about this?  Did you see this?  What can you tell us?

 5        A.   I don't recall it from that time.  I perhaps did see it when

 6     somebody from the OTP showed it to me or from the Defence.  I don't

 7     remember.  But I do recall seeing it recently.  I don't recall it from

 8     that time.

 9        Q.   Let me ask you a couple questions just about the handwriting on

10     this document.  At the top where we see number 11-12/458 and the date, I

11     think that's probably the handwriting of Mira Topic; right?

12        A.   Yes.

13        Q.   Okay.  At the bottom there's some handwriting which my English

14     translation records as saying:

15             "The Chief decided that employment is terminated as of 1 April

16     1992."

17             And a signature I guess.  Do you know whose writing that is?

18        A.   It was a long time ago but it's familiar.  I think and I'm

19     certain of it 80 per cent that this is Milutin Cadjo.

20        Q.   And who was he?  Where did he work?  What was his job?

21        A.   Until the power take-over, he was the reserve -- not reserve, I'm

22     sorry, I made a mistake.  He was a retired policeman.  After the

23     take-over he was the komandir of the police that was located in our

24     building, it was Prijedor 2 and so on and so forth, Omarska, Ljubija, and

25     so on.  He was in the headquarters.

Page 24940

 1        Q.   Okay.

 2        A.   Just some additional explanation.  I cannot tell you the official

 3     date that he became the komandir because he was putting himself forward

 4     right at the beginning and then later he did receive the decision.  I

 5     don't know exactly the date that he assumed his duties, but he was at

 6     that post.

 7        Q.   Assuming that's correct, can you tell us if he's the one who

 8     wrote that then who is the chief that he's referring to?  Would that be

 9     Drljaca?

10        A.   It's a difficult question who he was referring to.  I mean, I can

11     just make an assumption that that would be that.

12        Q.   No, that's fine.  Okay.  That's all I had to ask you about that

13     one.  Now, you told us about the 9th of April meeting, and then we know

14     what happened on the 29th and 30th of April.  And I think you at some

15     point said between the 9th and 29th during those 20 days you said at page

16     24774 is that there were obviously some processes, something -- things

17     were going on during those three weeks.  I wanted to ask you -- yeah, I

18     want to ask you about a couple of things that appear to be going on.  And

19     first of all I want to show you document P354 which I need to find the

20     right page number.  It's tab 12 and I'll give you a hard copy of this

21     one.  As that's coming to you, sir, I'll tell you that this is a document

22     that's dated the 10th of April.  And it's a dispatch from Delimustafic,

23     the minister of the BH MUP to all CSBs and all SJBs.  And he's referring

24     to what he called the forcible formation of organisational units in the

25     so-called Serbian MUP being in progress and talking about in his view

Page 24941

 1     workers being pressured or blackmailed to sign some declarations of

 2     loyalty.  He goes on to say that this is -- the activities of the Serbian

 3     MUP are illegitimate and that workers aren't required to sign those

 4     things.

 5             Did you see this?  Because based on the number handwritten on the

 6     top right, it appears this is a document that was received in Prijedor.

 7     I'm sorry, what I've got on the screen is --

 8             MR. CVIJETIC: [Interpretation] Different dispatch is on the

 9     screen.

10             MR. HANNIS:  I'm sorry, I've called the wrong number.  I wanted

11     to look first at 1D138.  I've got my numbers reversed.

12        Q.   I'm sorry, witness.  The one you're looking at in your hand is

13     from Delimustafic.

14             JUDGE DELVOIE:  Is it tab 12 all right, Mr. Hannis?

15             MR. HANNIS:  It's tab 12 in my binder.  It's 1D138.

16             JUDGE DELVOIE:  Thanks.

17             MR. HANNIS:  I don't know if I just crossed my numbers or not.

18             My apologies to the court officers.

19        Q.   Yeah, did you see this one or did you know about this back in

20     April 1992?

21        A.   No, no.  The way it looks, I believe that it did pass through my

22     communications centre, but unnoticed by me because it wasn't important

23     and the operator didn't inform me and neither did the chief.

24        Q.   Okay.  And the handwriting in the upper right-hand corner, again

25     that appears to be the handwriting of Mira Topic, the secretary for the

Page 24942

 1     chief.

 2        A.   Mira, yes.

 3        Q.   Thank you.  Now I want like to look at the other one I referred

 4     to, P354, which is at tab 13 and I'll give you a hard copy of that one.

 5     Thank you.

 6             And you'll see this one is also dated the 10th of April, but it's

 7     from Stojan Zupljanin.  But it makes specific reference to the one you

 8     were just looking at from Delimustafic, that MUP dispatch 09/4-382.  I'll

 9     tell you that's the number of the one you just looked at.  And

10     Mr. Zupljanin is denying that anybody's being forced and that everybody's

11     free to sign up with no pressure.  And the last thing he says is the

12     dispatch, Delimustafic's dispatch, does not have any legal effect in the

13     territory of the Serb Republic of BiH and is being put out of force.  And

14     again this has what appears to be Mira Topic's handwriting in the upper

15     right-hand corner.  So I take it this was another one that was received

16     in Prijedor?

17        A.   Yes, yes, yes.

18        Q.   Did you see this one or did you know about this one?

19        A.   I didn't see this document either, but in view of that period,

20     April 1992, and what I said that Chief Talundzic did not, as was

21     customary in earlier times, summon a collegium and interpret the

22     instructions from the top, from the centre.  This time he didn't call us

23     chiefs, so I didn't know about it because of that.  But he did go to his

24     people.  I said that a few times, "his people," but he went for

25     consultations where they interpreted that.  But there was no collegium.

Page 24943

 1     If there was, perhaps it was an inner circle that I was not a part of.

 2     Nobody isolated me per se; I just would like to note that, though.

 3        Q.   Okay.  So I understand that Chief Talundzic didn't call any kind

 4     of collegium and have a discussion about this document, but did you hear

 5     any --

 6        A.   No, no.

 7        Q.   But did you hear any informal talk about it, like among the

 8     employees in your communications department?  Because somebody in your

 9     section must have seen it; right?

10        A.   The communications personnel, including me, were already so

11     immune to the information that we were transferring and perhaps I think

12     that an employee of mine or I could have taken a dispatch to the chief

13     which said that they should kill me and we still would have done it.

14     There were too many information -- pieces of information passing through

15     for us to be able to pay attention to each one.  It's -- sounds

16     incredible but that's how it was.

17        Q.   Well, I understand that general practice of communication workers

18     to just be the conduit for transferring information.  And I believe you,

19     what you told us before, that generally you would only look at the

20     address and then deliver the mail, basically, without reading contents.

21     Although, in certain exceptional situations sometimes communications

22     workers did read documents; right?  They're human beings.

23        A.   Yes, yes.

24        Q.   Okay.  Okay.  That's --

25        A.   Just one.  Most often they would read the things that they were

Page 24944

 1     interested in, for example, salary increases or decreases.  Nobody read

 2     the politics.

 3        Q.   Okay.  Let me then show you Exhibit P1616 at tab 19.  This --

 4     I'll hand you a hard copy with the assistance of the usher.  And I will

 5     tell you, this is a document that I doubt that you have seen before

 6     because it's the minutes of a crisis -- or minutes of a Municipal Board

 7     meeting or Crisis Staff in Prijedor.  It's dated the 23rd of April, so

 8     this is during that 20-day period we've been talking about.  Have you

 9     seen that document before?

10        A.   Never.  If I did see it during the interview with your side or

11     with the Defence, I don't recall that either.  Earlier, I definitely did

12     not see it.

13        Q.   I want to point out a couple things to you.  This is apparently

14     President Miskovic is running the meeting.  Mr. Drljaca is one of the

15     attendees at this meeting.  And if you would look at number 5 on the

16     decisions that they adopted, number 5 says:

17             "To immediately start working on the take-over, the co-ordination

18     with the JNA notwithstanding."

19             See, I think this is an example of some of the processes that

20     were going on between the 9th and the 29th of April, but I take it from

21     what you've told us before you didn't know anything about that; right?

22     You didn't know anything about the SDS working on preparations for

23     take-over; right?

24        A.   That is correct.  I didn't know anything.  As I said already, I

25     had nothing to do with the SDS.  This Simo Drljaca and the date of the

Page 24945

 1     23rd of April is something I saw for the first time on the 29th of April.

 2     In other words, I didn't know him before then, so he was unable to convey

 3     anything to me or any police employees unless it was through private

 4     channels but not officially.

 5        Q.   Okay.  That -- fine.  I understand that.  But with that then I do

 6     want to go now and talk a little bit about the 29th of April and the 30th

 7     of April.  You testified on Tuesday this week you mentioned that you

 8     didn't have any previous knowledge about the meeting that occurred on the

 9     29th.  You'd been out working in the field on that day and then I think

10     you said --

11        A.   Correct.

12        Q.   You said at page 24777 you came back around 2.00 in the afternoon

13     and found out -- and found out about the meeting?

14        A.   Correct.

15        Q.   That's the first time you knew there was going to be a meeting

16     that day?

17        A.   Yes.  When I arrived back from the field, someone called on the

18     phone saying that all people from the communications department ought to

19     attend a meeting.  We were notified by phone.  It wasn't done in writing.

20        Q.   And I think you said the entire active and reserve police force

21     were invited.  Were they also all invited on short notice?

22        A.   I don't know.  I didn't bother to check, although I suppose as

23     much.  The communications department alone would not be left out or not

24     included.

25        Q.   You went on to tell us that when the meeting started there was

Page 24946

 1     only one item on the agenda, which was whether or not Prijedor should

 2     continue to belong to Banja Luka or should it join Sarajevo.  Is that

 3     right?  That was the topic?

 4        A.   Yes.

 5        Q.   Was there any written agenda or was this only announced orally

 6     once everybody was gathered together?

 7        A.   The latter.  It was done orally only.  No one read out anything.

 8     The presiding, the chief of station, Hasan Talundzic introduced the

 9     meeting and announced the agenda, the topic.

10        Q.   And I take it you didn't take any notes of this meeting like you

11     did of the 9th of April meeting, did you?

12        A.   Because I arrived among the last people.  I had nowhere to sit

13     down.  I was standing, as I said in my statement, next to a pillar like

14     this.  I leaned against it and I was unable to write.

15        Q.   [Microphone not activated]

16             THE INTERPRETER:  Microphone, please.

17             JUDGE DELVOIE:  Microphone.

18             MR. HANNIS:  I'm sorry.  Thank you, Your Honour.

19        Q.   I understand that during the meeting you got word that one of

20     your communications officers wanted to talk to you because of a problem

21     he was having sending something; correct?

22        A.   Yes.

23        Q.   And what was the name of that communication officer?  It's

24     recorded as Dusko --

25        A.   I have said already Sarac, S-a-r-a-c.

Page 24947

 1        Q.   Thank you.  I wanted to confirm the spelling.  And you said you

 2     went to see him, he showed you a dispatch -- a coded dispatch received

 3     from Sarajevo with an address that required him to send it on to

 4     Sanski Most and Novi and Dubica.  But he was unable to, you said, because

 5     Banja Luka communications officer refused to connect him.  Can you

 6     explain that technology for me.  Why did you and Prijedor need Banja Luka

 7     to connect you to your three sort of subordinate stations in terms of

 8     communications?  I didn't understand that Banja Luka had to be involved

 9     when you were communicating with Sanski Most, Novi and Dubica.  Is it

10     because this was a coded communication?  Can you explain, please.

11        A.   Yes.  If you recall, when the two of us discussed the schematic

12     of yesterday, I will remind you that there were two types of

13     communication between Prijedor and Sanski Most.  One was a direct line

14     and then a document could be transmitted with a code.  The other type of

15     connection was by way of circulars.  If they wanted to use the circular

16     communication, then one had to go through Banja Luka because only they

17     had the equipment; if not, then the work you had to do tripled because

18     you would have to take one code, the next code, and the third code,

19     because every participant had its own, whereas in circular communication

20     there was only one.  I hope you understand me now.

21        Q.   I think so.  And part of this was because it was a coded

22     communication; right?

23        A.   Yes.

24        Q.   But if Banja Luka -- if Banja Luka's communication officer was

25     refusing to make the connection, you could have done it yourself from

Page 24948

 1     Prijedor.  It just would have taken longer because you would have had to

 2     have three separate communications?

 3        A.   Yes.

 4        Q.   Okay.  Do you know -- do you know who the communication officer

 5     in Banja Luka was who was refusing to connect you for purposes of sending

 6     this on?  Was that Rakovic, the chief?

 7        A.   No, he's ignorant of it.  Not Rakovic, definitely not.  He

 8     doesn't do that work.  It must have been one of his employees but I don't

 9     know who.  Dusko Sarac was a lazy person, that's why he refused to patch

10     him through.  All the rest is excluded.  The one in Banja Luka based on

11     his own previous experience of the month before or so -- well, they knew,

12     although I barely noticed it at the time, that some dispatches from the

13     then-republican SUP in Sarajevo in terms of content were such that they

14     were not supposed to arrive at the stations where the SDS was in power

15     with their own cadre.  It was because of that that Banja Luka, although

16     the document says "distribute to all CSBs and CJBs," but there was this

17     written or unwritten rule up there that they circumvented them.  I

18     realised that there were some such dispatches addressed to Banja Luka

19     which arrived to us and the signalsman in question must have noticed that

20     and that's what he did.  If I may add anything --

21             MR. KRGOVIC: [Interpretation] A correction for the transcript.

22     Page 13, line 19 -- 18 and 19.  It says that the dispatches were

23     addressed to Banja Luka but arrived to us, whereas the witness said

24     something else.

25             THE WITNESS: [Interpretation] That is correct.

Page 24949

 1             MR. HANNIS:

 2        Q.   Can you tell us what you said about that.

 3        A.   I will repeat.  A dispatch reads "to all CJBs and CSBs."  That

 4     means it includes Banja Luka.  However, some dispatches - and this one

 5     obviously ...  - how do I know this one circumvented Banja Luka?  Because

 6     my signalsman said that this colleague of his there refused to patch him

 7     in the circular communication and he said, "Why don't you ask those you

 8     work for to patch you through?"  He rejected him flatly.  That's all I

 9     know concerning the dispatch.

10        Q.   Okay.  So if I understand that last bit correctly, you're saying

11     the communications worker on duty at the time in Banja Luka told your

12     communications worker in Prijedor, "Why don't you contact your people" or

13     ask those you work for to patch you through, meaning he was referring to,

14     what, Muslims?

15        A.   Probably.  I don't know.

16        Q.   Okay.  But again, you told us that the reason that you read this

17     particular dispatch, contrary to your usual communications worker

18     practice of not reading the contents, this time you read the contents to

19     try and figure out how you can solve the problem of passing this on to

20     the three addressees, Sanski Most, Dubica, and Novi.  But I don't

21     understand because you told me you had another way to send it on without

22     Banja Luka connecting you.  You could have sent three separate messages.

23     So why did you read this one?  You understand?  It seems to me you could

24     have solved the problem without having to read the contents but you did

25     read the contents.  So why was that?

Page 24950

 1        A.   No.  First of all, not reading documents was a principle I

 2     followed in my work.  It would have required reading an enormous amount

 3     of dispatches and this would be a great burden.  I had previously --

 4        Q.   Sorry, let me stop you there because I think I understand what

 5     you're saying, but your answer was recorded as:

 6             "First of all, not reading documents" -- oh, I'm sorry, it's been

 7     changed.  So not reading was a principle that you generally followed;

 8     correct?

 9        A.   But there was also a regulation in place which stated that an

10     employee of the coding department as well as the officer in charge can

11     read any coded document only to the extent necessary for him to do his

12     job.  Whatever he reads is something he may not share with anyone unless

13     the law prescribes otherwise.  If this or that document was sent to a

14     particular person, then I can convey information but only to him.  That

15     is why being familiar with the situation in terms of communication and

16     knowing that it was a very urgent matter as a rule, dispatches had to

17     leave immediately, at the same moment the signalsman could contact the

18     courier to take it on to the chief because as a matter of principle

19     urgent dispatches concern state matters rather than criminal issues or a

20     fire which had taken place.  Since I knew that the chief was there in the

21     meeting and I had to go back, anyway it was only logical that I took the

22     dispatch to him.

23        Q.   I understand that.  Let me ask you, though, about part of your

24     testimony about this.  At page 24781 you said even before, whatever the

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

Page 24951

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

 2     the basis of contents of the dispatch."

 3             I'm not sure I understand what you mean there.  What standard

 4     procedure are you talking about and why was it impossible to apply?

 5        A.   For example, if a dispatch arrived in our office and was supposed

 6     to go to, say, Bosanski Novi and I know that they cannot receive the

 7     dispatch because of technical malfunction, then I'll try to come up with

 8     another possibility.  If it's an open dispatch, it can be dictated over

 9     the phone; if it's a coded dispatch and if so required by the contents --

10     for example, a dispatch actually arrived saying that this many policemen

11     ought to be provided by Prijedor, Bosanska Dubica, et cetera, to take

12     part in an operation.  It was before the war.  And I knew that

13     Sanski Most was unable to receive the dispatch, what to do then?  You

14     dispatch a courier and a vehicle to take you to them.  But I could only

15     propose that and the chief, as a matter of fact, approved.  This is what

16     I meant more or less.

17        Q.   On the 29th of April do you know who was in the position of chief

18     of the SJB in Sanski Most, Bosanski Novi, and Bosanska Dubica?  Do you

19     know, were those chiefs Serbs or non-Serbs or do you know?

20        A.   I don't know.  I did know then, but I no longer remember.

21        Q.   Okay.  But with regard to this dispatch, given Banja Luka's

22     refusal to make the connection so a circular could be sent, it seems one

23     of the possible solutions as we talked about was to send a separate coded

24     communication to each of the three.  But you didn't do that.  Was it

25     because it was very urgent and time was of the essence?  Is that why you

Page 24952

 1     didn't send three separate messages to those three places?  Or was it

 2     because after you read the contents you decided:  Oh, I don't want to

 3     send that on.  I better tell the chief about it and then we'll decide

 4     what to do?

 5        A.   No.  Because of the situation in the communications centre and

 6     because of what I did when I referred to Prijedor, when I left I no

 7     longer came back to control my employee to see what he did what he was

 8     supposed to, which was to send it individually to the three addressees.

 9     As for the rule that he had to do it, it is so clear he must have known

10     he was supposed to do it and he knew he would bear consequences if he

11     didn't.  Concerning the topic of mobilisation, I no longer controlled

12     whether he indeed sent it on, but I am convinced he did, otherwise my

13     work, my job, would have in jeopardy as well.  As a matter of fact, no

14     one raised any questions subsequently.

15        Q.   Okay.  I understand better now.  Thank you.

16             So then you took the dispatch to -- well, you took the dispatch

17     and the book to the meeting?

18        A.   Yes, yes.  The dispatch log-book.

19        Q.   I have one question about the dispatch.  You told us -- we saw

20     the typewritten letters "dzz/m" at the bottom, which you told us you

21     understood to be the -- referring to a communications worker in Sarajevo

22     whose last name was Dzanko; correct?

23        A.   Yes.  And I think that.  I'm positive.

24        Q.   Okay.  And I think you said his name was Mirsad.  But my

25     information is that communications worker in Sarajevo at that time last

Page 24953

 1     name Dzanko his first name was Muhamed.  Would you disagree with that?

 2        A.   That is possible too.  For example, today I no longer remember

 3     the counsel's first name.  I've forgotten already.  I'm not very good

 4     with names, but Dzanko is something I did remember and there were many

 5     such work-mates of mine whose initials I was familiar with.

 6        Q.   Okay.  You got back to the meeting with dispatch in hand and the

 7     book and I think you said you gave it to Mirsad Sahuric to - what? - to

 8     fill out in the book the information?

 9        A.   Yes.

10        Q.   And to give it to the chief and have the chief sign for it?

11        A.   Yes.

12        Q.   You don't know where that communication book is anymore, do you?

13     Was it destroyed?

14        A.   It's a book for the chief or by the chief.  It could be the one

15     you showed me yesterday.  It is only logical.  However, I don't remember

16     whether the dispatch is in there.  You could check.  I think it should

17     be.  It should be in his book.  As for the communications book where

18     Sahuric made the entry, it's much the same as all the other books.

19        Q.   Let me see if I understand.  So the book the chief signed in

20     acknowledging receiving this dispatch on the 29th of April was the book

21     that Mira Topic kept in the chief's office.  Would that be the one you're

22     talking about?

23        A.   The official book according to the regulations was the

24     communications book, and it not only included the chief's dispatch but

25     all the other, including the one signed by Mirsad Sahuric.  The auxiliary

Page 24954

 1     book, so to say, that Mira kept, which I saw yesterday or the day before,

 2     I expect you could find it there.  I said that the books were destroyed.

 3     And I have another remark about destroying books.  It wasn't as if we

 4     burned a single book at a time.  Every month or every week -- actually,

 5     every week we would have a full sack of such books to be burned.  And

 6     when it was this book's turn, it went in the sack as well.  Two coding

 7     department workers did that.  They would take the sack and burn it in a

 8     safe place, and it was always done by two people, not a single person.

 9        Q.   We did look at one book recording I think coded telegrams

10     outgoing.  I have another book that I'll show you later on that appears

11     to be incoming dispatches of all kinds that went to the chief.  But for

12     now I wanted to ask you, you said the reason that you spoke out at the

13     meeting on the 29th was because of the nature of what you read in the

14     dispatch made you feel as though this was the beginning of a war.  Is

15     that a fair summary?

16        A.   When you sum up everything I said, it boils down to that, yes.  I

17     think I said yesterday too that the answer to your question would be yes.

18     I also said that I started relying on my emotions rather than my senses,

19     and the only thing I felt was this hellish fear of having to face some

20     earlier bad things that had taken place.  Before that, I never used to

21     reason that way.  I always relied on my rationality alone.

22        Q.   The reason I ask you about that, I know you told us that you

23     didn't really watch television or read the newspapers, but I wonder were

24     you aware -- well, were you -- first of all, were you aware of the

25     existence of the Autonomous Region of the Krajina and the Crisis Staff of

Page 24955

 1     the ARK in Banja Luka?  Did you know about that political body that was

 2     operating and doing things in April of 1992?

 3        A.   It is correct that I did not follow politics, but I wasn't

 4     isolated from the world either.  I knew that this SAO Krajina existed.

 5     As for any Crisis Staff in Banja Luka, I was truly ignorant of that and

 6     this is the first I hear of it from you.

 7        Q.   You didn't see any references to the Autonomous Region of Krajina

 8     Crisis Staff decisions, for example, in some of the dispatches received

 9     from Banja Luka?  Maybe we'll look at a couple later on, but there's some

10     forwarded to Prijedor making reference to ARK Crisis Staff decisions.

11     You don't recall seeing anything like that?

12        A.   If you showed it to me, I might be able to tell you something.

13     Otherwise, I don't recall anything off-the-cuff.

14        Q.   We'll maybe come to that later.  I wanted to stick to my line of

15     questions for right now.  So did you not know or hear about a decision by

16     the ARK Crisis Staff on the 27th of April where the -- I'm sorry, it's

17     not the Crisis Staff but it's the Assembly for this point, the Assembly

18     of the Autonomous Region of the Krajina on the 27th had taken the view

19     that the JNA was to be prevented at any cost from withdrawing the

20     equipment and ordnance from the area of the autonomous region.  I take it

21     you didn't know about that?

22        A.   Not at the time, but I did see a document in the papers I

23     received from either you or Defence.  I saw it, say, a month or two ago,

24     but I don't recall it from back then.  Just another thing.  I think you

25     said "Crisis Staff" the first time around and the next time around you

Page 24956

 1     said "Assembly."  That I remember.

 2        Q.   You're right, I did initially mention "Crisis Staff."  But that

 3     particular position was by the Assembly.  In late April -- well, in April

 4     of 1992, had you heard anything about a group of armed Serbs in

 5     Banja Luka that called themselves the Serbian Defence Forces, the S-O-S,

 6     did you know anything about them?

 7        A.   No.

 8        Q.   So I assume you didn't hear anything about them blockading the

 9     JNA from leaving Banja Luka, starting the 27th of April, 1992?

10        A.   Well, I have the feeling that I'm hearing this from you for the

11     first time, but perhaps I did hear about it earlier but it was so

12     important that I completely forgot about it.  So perhaps I did hear about

13     it, perhaps I didn't.  I mean, Banja Luka was so far away in a sense from

14     us that I never heard it.  There was no need for me to hear it.  And let

15     me correct myself, I did have a TV set then, but I very rarely watched

16     the news and I don't know if this ever was in the news.

17        Q.   Thank you.

18             JUDGE HARHOFF:  Mr. Jankovic, could I just ask you to clarify a

19     bit.  What did you make of the information that you did receive and which

20     you did remember that the Assembly of the ARK had issued a dispatch with

21     the purpose of trying to prevent the JNA from pulling out along with its

22     weapons?  What was your interpretation of that information?

23             THE WITNESS: [Interpretation] I didn't understand you properly.

24     You said the Assembly.  Are you talking about the Assembly of the Krajina

25     because that was not in the dispatch?  If you're thinking about the

Page 24957

 1     dispatch that I brought, then that was on the basis of a decision of the

 2     Presidency of the BiH, not of the Krajina.  That's what I meant.  If

 3     that's what you meant.  I don't know.  Could you please clarify your

 4     question.

 5             JUDGE HARHOFF:  Yes, I can.  And I'm glad that I put the question

 6     because apparently there is perhaps a misunderstanding.  From the

 7     transcript of your testimony just a couple of minutes ago, it would

 8     appear that you remember having seen the dispatch that was issued by the

 9     ARK Assembly --

10             MR. HANNIS:  Your Honour, if I may, if that's in there I don't

11     remember asking a question because the document that I was relying on

12     didn't refer to a dispatch, but it referred to a decision or a position

13     taken by the Assembly.

14             JUDGE HARHOFF:  Thank you for this clarification.  In any case,

15     the way I interpreted your answer, Mr. Jankovic, was that you actually

16     heard of the decision taken by the ARK Assembly on the 27th of April and

17     that this decision was designed to try and prevent the JNA from pulling

18     out its weapons from the Banja Luka area.  And my question to you is:

19     Since you seem to remember this decision, what did you make of it?  How

20     did you understand the purpose of this decision?  Why should the JNA be

21     prevented from pulling out its weapons?  Do you understand my question

22     now?

23             THE WITNESS: [Interpretation] I do understand it now and I think

24     there is a misunderstanding that originates from what the Prosecutor and

25     I were saying.  So I'm going to try to be as clear and as brief as

Page 24958

 1     possible.  All that I said about the isolation and everything, it all

 2     refers exclusively to the dispatch of the BiH Presidency which I brought

 3     to that meeting.  This was the only thing that I knew.  All the other

 4     dispatches, documents, that are mentioned in any way, including the ones

 5     from the SAO Krajina, I don't know anything about that nor did I ever

 6     know.  Was I clear?  Thank you.

 7             JUDGE HARHOFF:  But, Mr. Jankovic, let me then put the direct

 8     question to you.  Did you hear at the time of a decision, not a dispatch

 9     but a decision, taken by the ARK Assembly on the 27th of April, 1992, a

10     decision to try and prevent the JNA from pulling out along with its

11     weapons from the Banja Luka area?  Did you hear of that decision?

12             THE WITNESS: [Interpretation] I didn't hear anything.  That's

13     still the period when Talundzic was the chief and if any document did

14     come to the station, as I said a number of times, I was totally

15     "isolated" there.

16             JUDGE HARHOFF:  Thank you.

17             Back to you, Mr. Hannis.

18             MR. HANNIS:  Thank you, Your Honour.

19        Q.   Do you recall -- well, let's have a look.  I have a technical

20     question for you.  Could we bring up Exhibit 1D150, tab 24 of the

21     Prosecution binder.  And actually, I know there are two B/C/S versions.

22     It doesn't matter which one we look at first because I want to look at

23     both.

24             Can you see that one on the screen?

25        A.   I cannot really see this very well.  Perhaps you have a better

Page 24959

 1     copy.

 2        Q.   It's not much better, but I do have hard copies.  If I can hand

 3     them to you, I'll hand you copies of both B/C/S versions we have for

 4     this.  The copy you're going to get may not be much better, but the first

 5     point I want to ask you about is:  I recall, perhaps in your OTP

 6     interview, you explained about the technical functioning of the equipment

 7     when sending or receiving these kinds of messages.  And there's a unique

 8     function of that regarding how the text is oriented on the page if you

 9     follow me.  I understood if the letters are straight up and down that

10     tells you something about where this one came from, whether it was a sent

11     document or a received document.  Do you follow me?  Do you know what I'm

12     talking about?  And if the letters leaned to the right, that means

13     something else; and if they leaned to the left, that means a third thing.

14     Can you explain that to us?  I'm looking at the one that's on the screen

15     now and that seems to be attached -- looking at the one that's on the

16     screen now, that appears to be text that is upright, standing straight up

17     and down.  So what does that say to you about where this one came from?

18     That's -- I think that's the one you were looking at in the hard copy.

19     If the letters are upright, what does that tell you about where this came

20     from?

21        A.   I will explain.  First of all, based on my experience, I

22     recognise the device on which this was done.  This is a teleprinter

23     produced by the Elektronska Industrija Nis factory.  And the licence

24     is --

25             THE INTERPRETER:  The interpreter did not catch the word.

Page 24960

 1             THE WITNESS: [Interpretation] So these letters are made up of

 2     dots.  You cannot see it here but the letters are made up of dots.

 3             MR. KRGOVIC: [Interpretation] I apologise.  The interpreters did

 4     not hear the licence.  Could the witness please repeat it.

 5             THE WITNESS: [Interpretation] Sagem, yes, that's the French

 6     company.  Perhaps you know it.  They also make mobile phones.

 7             That machine has the option of differentiating -- I'm going to

 8     tell you now.  When the operator is working on the machine, typing on the

 9     machine, and the letters are being written, then there is one regime of

10     operation.  Can you hear me?  When it's being received, when he's

11     communicating with a participant and is receiving the text and directly

12     typing it, that's a second regime.  And the third one is when you are

13     making a copy from memorised recorded data.  So this particular format

14     indicates that this arrived from a communications line.  Recently I did

15     see a document with a copy leaning to the right, recently when I was

16     working with the Defence I saw a dispatch which according to what I know

17     was not a copy but was leaning to the left.  So it means that I've

18     forgotten a little bit, but right now I am convinced that the dispatches

19     that were received are straight.  And so this dispatch, I think, would

20     have been received directly.

21        Q.   Okay.  If in e-court could we put up the other B/C/S version of

22     1D150 side by side with the one that's currently on the screen.  I'd like

23     to have both B/C/S versions up and not the English because I'm just

24     trying to compare the orientation of the text.

25             You see on the screen those two documents and the two documents

Page 24961

 1     in your hand.  To me it seems -- we've got two copies of the same thing

 2     on the monitor.  Now, yeah.  It seems to me that the darker hard copy,

 3     those letters seem to be slanting slightly to the right; am I correct?

 4        A.   Yes, and this is now confusing me.  This is opposite to what I

 5     have just told you and I don't have an explanation.  Why is it opposite?

 6     By logic because this dispatch was recorded into the book by Mira Topic,

 7     then it would be logical that the dispatch that the chief received, he

 8     would hand it over for her to record in the log-book and that it arrived

 9     directly, it was received directly.  That was the usual thing in the way

10     we worked.

11        Q.   Okay.

12        A.   And the dispatch that would be a copy should be slanted.  So

13     something is not quite clear to me right now.  I don't know how we could

14     get to the bottom of it.

15        Q.   Don't give up yet.  I think you may be right still.  You see the

16     handwriting at the top of that one you're holding in your hand which is

17     the one on the right side of the monitor as we're looking at it has the

18     handwriting of Mira Topic; right?  Right?

19        A.   Yes, yes, that's what I said.

20        Q.   And it's dated the 11th -- I think it's the 11th of May, 1992,

21     that she's written there; correct?

22        A.   Yes.  Let me just remind you of what I said yesterday or the day

23     before.

24        Q.   No, I'm going to ask you because I think that's correct.  You

25     told us that, after the take-over, Mr. Drljaca called you into his office

Page 24962

 1     and introduced you to a couple of journalists?

 2        A.   Yes, that's it.

 3        Q.   And asked you whether you still had the dispatch?

 4        A.   Yes.

 5        Q.   And you went back to your workers to look to try to find the tape

 6     whether it was still there?

 7        A.   Yes.

 8        Q.   And you made a copy?

 9        A.   Perhaps that's what it is.

10        Q.   And that's why the letters lean to the right on this one; right?

11        A.   Very probable, but I'm not sure.

12        Q.   Okay.  But that would indicate that this one is not the original

13     that Chief Talundzic had because his should have been oriented otherwise,

14     standing upright, not leaning to the right?

15        A.   Yes, yes.  From what I can remember on the actual device, that's

16     how it was.

17        Q.   Okay.  All right.  Thank you.  That clears up one mystery for me.

18             Now, I want to go on into the evening of the 29th.  You told us

19     how after all this happened at the meeting and the hubbub you went home

20     and later on you were called by, I think, your communications officer who

21     was on duty and told to come in.  So you went to the police station and

22     when you got there you were told to go to Cirkin Polje; is that right?

23        A.   Cirkin Polje.

24        Q.   Okay.  And who told you to go there?  When you got to the police

25     station who told you to go to C. Polje?

Page 24963

 1        A.   I'm just recalling this.  I said that yesterday or the day

 2     before.  The system to summon me when I was needed by anyone, a superior

 3     or anybody who really needed me officially, nobody would ever call me at

 4     home.  They would call the duty officer at the communications centre who

 5     was there from 00.00 to 24.00 hours and they would just say:  Call the

 6     boss to report at such and such a place.  And that's how it was this

 7     time.  I didn't ask him who told him that, but I was summoned to the

 8     communications centre.

 9        Q.   Yeah, I understand that.  But my question is:  When you got there

10     then somebody must have told you to go to Cirkin Polje.  Who told you?

11        A.   The duty communications officers were already there and I could

12     see that everybody was getting ready to go, not just the communications

13     staff but the police and ...

14        Q.   Yeah, but can you tell me the name of the person who once you got

15     to the police station told you:  We're going to Cirkin Polje?  Was that

16     somebody else in communications?  Was that the deputy commander of the

17     station?  Who do you remember first hearing that you were going to

18     Cirkin Polje?

19        A.   Most probably, most probably the situation proceeded in this way.

20     The person who sent the duty officer didn't say:  Call the boss.  But he

21     said:  You should all assemble.  So that when I got there there was some

22     other communications personnel there.  It wasn't just me.  There were

23     perhaps three of them.  I cannot remember who else was there.  Raus,

24     Mladen, was there, Milan Batajnica, I don't know if anybody was missing.

25     There were four or five of us.  And then there was an assembly already of

Page 24964

 1     people there.  The communications people were already there.  We didn't

 2     wait for anybody else.  They were all living much closer than I was to

 3     the place.

 4        Q.   Now, you told us before about when you got there and the number

 5     of people and the kinds of uniforms they were wearing.  Do you recall

 6     what building specifically you went into?  Had you ever been out there

 7     before to know what building it was that you were in?

 8        A.   Yes, I'd never been there before.  This was a building of the

 9     local commune, as we referred to it, over there.  This is the place where

10     the secretary of the local commune is.  It's a low building about the

11     size of this whole area here, but there are many rooms in that building.

12     I entered an office where there were people whom I knew, perhaps the

13     komandir or I don't recall who it was.  In any case, familiar faces.  I

14     think that it probably was the office of the secretary himself, that was

15     his place of work.  I don't know.  There were two or three offices.

16        Q.   And if I understand correctly, this was the very first time that

17     you met Simo Drljaca; is that right?

18        A.   Yes, yes.

19        Q.   And was it from him that you learned that he was the chief from

20     now on?  Did he tell you that at that first meeting?

21        A.   Yes, yes.  He didn't tell Milos alone.  We were just sitting and

22     chatting at the desk, the komandir, all of these were leading officers of

23     the station.  I don't remember their names, but I saw them in the days

24     after that.  I don't believe that they were all there but many of them

25     were there.  And we were just chatting, nothing in particular.  There was

Page 24965

 1     no panic, then Simo comes in a multi-coloured uniform, I remember the

 2     face, tall, he sat.  Hello, hello.  I'm Simo Drljaca, such and such a

 3     thing.  And that's it.

 4        Q.   You said he was in a multi-coloured uniform.  You mean

 5     camouflage?

 6        A.   Yes.

 7        Q.   [Previous translation continues]...  Blue camouflage, do you

 8     remember?

 9        A.   Well, the blue one came into fashion much later.

10        Q.   So I take it you're saying you think it was green on the 29th of

11     April, the one --

12        A.   The military one, green/brown/grey, not blue, a little bit more

13     or a little bit less blue, no, not that.

14        Q.   Thank you.  And when he asked you who you were, you told him you

15     were a communications officer and then he gave you, you said, a piece of

16     cardboard that said "official ID" on it; right?

17        A.   [No verbal response]

18        Q.   I see you nod your head, but you have to answer out loud for the

19     transcript.

20        A.   I don't know if you didn't say it correctly or it wasn't

21     translated correctly.  Piece of cardboard, no.  It was a stack of cards

22     this thick and it said "official ID" and that was something that was to

23     be filled in by hand.  And let me just tell you, I remember it was typed

24     in a local printer shop.  There were some small letters which said "vila"

25     which indicated to me that it did not come from anywhere outside.  Had it

Page 24966

 1     come from Banja Luka, the name of the printer would have been one of

 2     theirs.  So it was obvious that it was printed there.

 3        Q.   Thank you.  It's time for our first break and we'll follow on

 4     from that after we return.  Thank you.

 5             JUDGE HALL:  So we would resume at 10.45.

 6                           --- Recess taken at 10.24 a.m.

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

 8             MR. HANNIS:  Thank you.

 9        Q.   Witness, you were just telling us about being handed a stack of

10     blank official ID cards I think you called them.  In terms of size, were

11     they about the size of --

12        A.   Yes, that's what was written on them.  It was paper that was much

13     lower quality than what you have, but it was the kind of paper you would

14     use for cigarette packages, but it was the size that you are showing.

15             MR. HANNIS:  For the record, Your Honour, I was just showing the

16     witness my ICTY badge.  It wasn't on my list of exhibits, but I trust

17     there's no objection.

18        Q.   Now, did this say anything on it other than "official ID"?  Did

19     it say "SJB Prijedor" or "MUP," or did it just have the words

20     "official ID" and then you filled in a name?  Was there any other

21     information on these cards?  Did you hear my question?

22        A.   Yes, yes.  It was that side, but it was a bit like this --

23                           [Trial Chamber and Registrar confer]

24             JUDGE HALL:  The procedural issue is that what is now being shown

25     to the witness is something that's not on the record and unless the

Page 24967

 1     parties have some violent objection, we propose to have it assigned an

 2     exhibit number at this point.

 3             MR. HANNIS:  Your Honour, I wasn't trying to enter myself into

 4     posterity, but I thought perhaps with the agreement of the parties or the

 5     Trial Chamber that we can take judicial notice of the size of the ICTY

 6     badges that --

 7             JUDGE HALL:  No, no, not that, Mr. --

 8             MR. HANNIS:  Oh, okay.  Good.  Thank you.

 9             JUDGE HALL:  It's the document on the screen.

10             MR. HANNIS:  The documents on the screen are already part of

11     Exhibit 1D150.

12             JUDGE HALL:  This is the document where there was this difference

13     of views as to the translation.

14             MR. HANNIS:  Yes, but I understood both were attached to 1D150 in

15     e-court --

16             THE REGISTRAR:  If I may assist.

17             MR. HANNIS:  Yes.

18             THE REGISTRAR:  The second B/C/S translation the counsel is using

19     is not entered in the exhibit list yet.

20             MR. HANNIS:  Well, I thought we'd had a proposal at one time to

21     give it a number of 150.1 or .01.

22             THE REGISTRAR:  Thank you, Your Honours.  The second version

23     uploaded by the Prosecution will be assigned Exhibit Number 1D150.1.

24     Thank you.

25             MR. HANNIS:  Thank you, Madam Registrar.  Thank you.

Page 24968

 1             JUDGE HALL:  Thank you, Madam Registrar.

 2             MR. HANNIS:

 3        Q.   Witness, I'm sorry about that.  Do you recall my question or

 4     should I re-ask it?

 5        A.   No, I remember it and I was going to say that is the size but it

 6     was double, it was folded over, and "official identification" was written

 7     on that -- on the front.  Inside something else was written.  But as far

 8     as I can remember, it did not say "MUP" or "Banja Luka" anywhere.  Most

 9     probably it said "Prijedor public security station," something like that.

10     And I have a copy, my copy, in my own personal archive.  So if necessary,

11     I can provide that.  99 per cent -- well, there was very little text of

12     any kind.  There were just lines for the first and last name.  There was

13     no post, space for that; there was no space for a photograph or the year

14     of birth of the person to whom it belonged.

15        Q.   And I take this -- I take it that this was only intended to be

16     used as a temporary document for the purposes of what was happening on

17     the next morning; is that right?  This didn't continue to be your

18     official ID at Prijedor after that day; right?

19        A.   No.  It was used for a long time.  It was quite worn from being

20     carried in my pocket.  I don't know for how long, but it was months,

21     perhaps longer.

22        Q.   And you filled it out, you put in the names of people as they

23     came up?

24        A.   Yes.  I did, yes.

25        Q.   Did -- what information was filled in on the card other than just

Page 24969

 1     the name, any other information?  Did you sign on the card as the

 2     issuing --

 3        A.   No, just the first and the last name.  Just the first and the

 4     last name, nothing else.

 5        Q.   Okay.  And neither you nor Mr. Drljaca or anybody else from

 6     Prijedor signed as the issuing officer, anything like that?

 7        A.   I definitely did not.  I think that there was a small stamp, but

 8     it seems that there was no signature.  I really can't remember that, but

 9     perhaps there was a very small stamp.  I don't remember whether there was

10     a signature or not -- his signature.  Mine definitely wasn't there.

11        Q.   Okay.  If after you're done testifying when you go home, could

12     you have a look and see if you still have yours; and if so, would you be

13     willing to furnish it to us to make a copy of and we'll return the

14     original to you?  Are you willing to do that?

15        A.   I can.  Perhaps your staff member can call me on the phone and

16     then we can make some sort of arrangement.  I do have an e-mail address.

17     I don't know it off by heart.  I can send him a copy by e-mail if that is

18     acceptable to you.

19        Q.   If you're willing to do that, I would ask the Judges to direct

20     the victim/witness people to co-ordinate the logistics with you on that.

21     Okay.

22        A.   It doesn't matter to me who would call me.  The important thing

23     is for me to know that this is an official thing and that -- and that

24     it's for the needs of this Tribunal.  Of course I will do everything

25     else.  The important thing for me is to know that it's just not going off

Page 24970

 1     somewhere without any control.

 2        Q.   [Previous translation continues]... That's why it will be

 3     victim/witness, not me or not the other side.  It will be somebody who

 4     works directly for the Court.

 5        A.   The Tribunal, the OTP, the Defence, that is really not in

 6     dispute.  That will all be fine.

 7        Q.   Thank you.  As far as you know, were you the only person who was

 8     filling out those cards and giving them to people that night or did

 9     somebody else help you do that?

10        A.   It was only me that evening.  Later on I returned whatever forms

11     were left to the secretary.  Later on others received it, but I was no

12     longer familiar with it.

13        Q.   Did you keep a list of the names of people to whom you had given

14     cards or did you simply fill out the card and give it to them?

15        A.   No, no.  This is how it was.  Say you arrived, you say your name

16     was this and that, and I write it down.  Then the next person came,

17     et cetera.  There was no other type of control.  Even the people I didn't

18     know personally were included.

19        Q.   Well, that's my next question.  So you gave cards -- you gave

20     official cards -- official ID cards to some people that you didn't know

21     who they were; right?

22        A.   Well, yes.  But whoever was there I supposed were all -- I don't

23     know.  I didn't then -- well, I was -- I did what I was told.

24        Q.   And you didn't ask anybody to show you an ID that they were a

25     policeman before you gave them one of those official ID cards?

Page 24971

 1        A.   No, no.

 2        Q.   But I take it several of the people to whom you gave cards were

 3     people that you already knew and worked with as police persons; right?

 4        A.   Yes.

 5        Q.   Thank you.  You said something that I thought was percipient of

 6     yourself.  You said that when you were thinking about this you said at

 7     page 24798:

 8             "So I was asking myself:  How come I know nothing about that,

 9     whereas there were obviously huge preparations made ahead of it."

10             And I understood you were talking about all these people gathered

11     out there and the take-over being done the next day.  Is that right?  I

12     mean, it seems the type of thing that must have been planned farther in

13     advance than just the 12 or 13 hours since the meeting where the dispatch

14     was read out.  Do you understand my question?

15        A.   I do.  I remember I mentioned that I was surprised, but can you

16     tell me more about the context in which I provided that statement?  I

17     think I did say that yesterday, but what was the actual context?  Perhaps

18     you can expand a bit more or read out a larger portion.

19        Q.   Well, the question to you was about the meeting in Cirkin Polje

20     and where it was and where the rooms where.  And you said:

21             [As read] "It's a big facility.  There are many rooms inside.

22     There was one officer where I sat, but since" --

23        A.   Yes.

24        Q.   [Previous translation continues]... "lighting was bad quite a few

25     of them were lit only if you had moonlight.  So I was asking myself how

Page 24972

 1     come I know nothing about it."

 2             And I took that to mean how come you didn't know anything about

 3     it before the night of the 29th about all this.  That is what you were

 4     referring to?

 5        A.   Yes, that is what I said and that is what I meant.  Now I know

 6     what you mean.  For example, in passing I saw some crates or boxes in a

 7     room and they were of the military olive-drab colour.  It must have been

 8     military equipment.  I didn't what it was, where it had come from, who

 9     brought it in, and why.  It must mean that this was an ongoing process I

10     was unaware of.  Of course as a signalsman I wasn't in any situation to

11     know and it's obvious I didn't.  Sometimes I learned of things

12     indirectly.  For example, before I used to attend collegium meetings when

13     the chief agreed on certain things with the commanders and I was there as

14     an observer and I didn't contribute.  But, for example, in this situation

15     I was completely ignorant of the whole thing.

16        Q.   You mentioned at page 24832 when you were asked about what most

17     of the people were wearing at Cirkin Polje, you said there were a motley

18     crew of all sorts of colours, JNA uniforms, then police uniforms that the

19     reserve forces had, the blue ones of poorer quality, there were

20     active-duty policemen in their own uniforms, so everything was there.

21     And then in the transcript I think there's an error you said:

22             "I didn't count, but there were perhaps 1350," 1-3-5-0, "to

23     200" --

24        A.   No, no.

25        Q.   So I thought -- did you mean 150 to 200 men?

Page 24973

 1        A.   Yes, approximately.  The room was the size of this one and

 2     perhaps another half of the courtroom.  It wasn't completely packed, but

 3     there were a lot of people.  I didn't count.  Let's put the figure at 150

 4     or between 1- and 200.

 5        Q.   Did you know any of the local JNA commanders in Prijedor at that

 6     time?  Did you know who any of those were?

 7        A.   No.  I did know of them, but I didn't know them personally.  For

 8     example, Mr. Zeljaja, I had seen him perhaps twice although I didn't see

 9     him on that occasion.  I'm not saying that he wasn't there, but he wasn't

10     in the same rooms where I was.  There were two officers there, though.

11     One was a major and asked for my radio, hand-held radio, Motorola.  I had

12     never seen him before.  I didn't give it to him because per establishment

13     the military was not part of my structure and I didn't have enough

14     hand-held devices for my own people, let alone the army.

15        Q.   Okay.  Did you recognise any of the people that were in military

16     uniforms?

17        A.   I didn't recognise anyone, but at that time or just before there

18     was fighting in Slavonia where the JNA had participated.  There were

19     people from our area who went there who kept their relatively worn out

20     military uniforms.  There were not police uniforms.

21        Q.   And the number 150 to 200 that you told me about, is that the

22     total number of people in the room where you were?

23        A.   No, no.  We have to be clear.  I meant the area around the house.

24     In the house itself there were -- there was a number of smaller rooms and

25     there were far fewer people inside.

Page 24974

 1        Q.   Do you recall approximately how many official ID cards you handed

 2     out that night?  Was it 50?  A hundred?  More than a hundred?

 3        A.   I can't recall.  But that was the only thing I did, although I

 4     wasn't at that task all the time.  When someone turned to me, I wrote out

 5     the IDs.  Then there may have been people who didn't even know they would

 6     have to come to me.

 7        Q.   All right.  Thank you.  Now I want to turn to another topic

 8     unless the Judges have any questions about that night.  Let me show you

 9     Exhibit P652.  This is at tab 29.  I think you may be able to read this

10     one on the screen.  Can you see that okay?

11        A.   I can.

12        Q.   This is a dispatch number 11-12 and there's a handwritten number

13     1873 at the top.  It appears to be from Chief -- from Chief Drljaca to

14     Banja Luka, reporting, among other things, that:

15             "In accordance with the conclusions of the Executive Board of the

16     Serbian Assembly of Prijedor at 0400 hours in the municipality control

17     was seized over SJB and all other major facilities."

18             That is right, that is what happened on the 30 of April?

19        A.   Yes.

20        Q.   Handwritten at the bottom we see the date 30 April and 0720

21     hours, Dragan.  Do you know whose writing that is?  Is that a

22     communications officer?

23        A.   Just a moment.  The number of 1.587 seems enormous.  I'm not

24     trying to say something there wasn't, but it just sounds out of place.

25        Q.   I understand that.

Page 24975

 1        A.   And now about the note.  In all dispatches where you come across

 2     a handwritten note, it means the following.  This is a textbook example

 3     and if you remember you can apply it to all other such documents.  Each

 4     communications worker had their own sign.  In the circle it reads BM,

 5     Milan Batinica.  I was his boss in Prijedor.  He sent it.  Once he did,

 6     the equipment types out who received it.  So it was received on the 30th

 7     of April, 1992, at 7.20 by Dragan, a signalsman in Banja Luka.  It was

 8     sent to the CSB there.  I don't know this person, but I know that there

 9     was a Dragan there.  It was standard practice.  The person sending it

10     would hand-write their initials.  It was much like the DZM on the other

11     document.  As for the date, it should be the date when it was sent to

12     Banja Luka and received by Dragan there.

13        Q.   Okay.  Thank you.  Can we go to another topic.  I want to ask you

14     what you know, if anything, about some crimes that may have been

15     committed in Prijedor municipality after the take-over.  And the first

16     document I want to look at is P659, tab 66.  I can give you a hard copy

17     of this one with the usher's assistance.  While it's on its way to you, I

18     will tell you this is a -- appears to be a document from Chief Drljaca

19     sent to CSB Banja Luka and dated the 13th of June.  And he's complaining

20     about some of the activities of the Banja Luka special unit.  Have you

21     had a chance to read that?

22        A.   No.

23        Q.   Let me know when you're done.

24        A.   You want me to read it?

25        Q.   Yes.

Page 24976

 1        A.   Okay.

 2        Q.   Thank you.  Among other things he's complaining that these

 3     special unit people were arbitrarily arresting, interrogating, and

 4     abusing prisoners and taking money and jewellery from them and they even

 5     got into a conflict with the Prijedor policemen who were on security

 6     duty.  Did you hear about that at the time, back in 1992, problems with

 7     the Prijedor special -- with the Banja Luka special unit in connection

 8     with Omarska?

 9        A.   No.  I didn't hear about that.  It was so far removed from my

10     tasks that I didn't even know of this "Strazivuk".  I don't recall such a

11     last name.  I'm not saying they weren't there but I know nothing about

12     it.

13        Q.   And the last paragraph there's a reference there to Mirko Jesic.

14     Do you know who he was?

15        A.   He was the chief of the State Security Service office in

16     Prijedor.

17        Q.   Okay.  Thank you.  All right.  The other item is he mentions that

18     there were also complaints about the conduct of the special unit and

19     looting during mopping-up operations.  Was that referring to operations

20     in the Muslim villages in Prijedor municipality that was done in May and

21     June of 1992?  What did you know about that?

22        A.   I don't know what is referred to specifically in the document,

23     but I believe there were such incidents.  There was chaos and I could see

24     it for myself.  I was stopped once by someone.  They weren't police, and

25     they wanted to take away my vehicle.  It was an official Golf vehicle.

Page 24977

 1     They were trying to seize it in the name of the people they said.  I did

 2     scare them away when I said I was a policeman, but they simply wanted to

 3     take the car away.  I believe there were such instances.  As for what was

 4     official, unofficial, or semi-official is difficult to discuss from this

 5     point in time.

 6        Q.   I don't think you mentioned this incident before.  When and where

 7     did that happen?

 8        A.   I didn't.  I didn't mention it.  I was reminded by what you just

 9     said.

10        Q.   Okay.

11        A.   I think I was on official business to the radio station in

12     Prijedor.  It had something to do with communications.  I don't remember

13     exactly.  There was a person with an old olive-drab coat and an old rifle

14     and he said, "Hand-over the keys in the name of the people."

15        Q.   Okay.

16        A.   Just a silly elderly guy.

17        Q.   All right.  Let me show you Exhibit P812.  It's at tab 111 of the

18     Prosecution binder.  And I'll hand you a hard copy, although it's not

19     very good either.  It appears --

20        A.   Oh my.

21        Q.   Yeah, it appears to be to the Prijedor SJB from CSB Banja Luka,

22     forwarding a telegram from Minister Stanisic, wherein he orders that an

23     investigation be done into the fate of about 150 Muslims who apparently

24     were killed in the area of Skender Vakuf at Koricanske Stijene.  Did you

25     ever hear about that event?

Page 24978

 1        A.   I did, but much later.

 2        Q.   Do you recall the circumstances under which you first heard about

 3     it, when and where and how you heard about it for the first time?

 4        A.   I recall very little.  Brane or Branko Siljeg was an inspector in

 5     charge of property crimes and crimes related to economics.  It's the

 6     person I mentioned in relation to the medication in Keraterm.  By that

 7     time he was a ruined person, ruined by alcohol.  He told me he went there

 8     with someone - he never said who - and he didn't even tell me the whole

 9     story.  He just said, "We went," and he said, "I'm tired because I went

10     beyond Knezevo" and that some people were killed and I guess they were

11     there to clean up and that's why they went there.  But at the time it

12     didn't mean much to me.  The topic of death was an everyday thing at the

13     time.  And I also didn't take his information seriously, having in mind

14     what kind of person he was.  He died later on because he had drunk too

15     much.

16        Q.   Okay --

17        A.   Later on when I worked in the CSB in Banja Luka, they

18     commemorated it, it seems.  After the war when I moved following 2001, I

19     think Bosniaks commemorated the event; and we provided security, the

20     police.  We from the communications department didn't attend the scene

21     itself, but we were around the perimeter, say almost a kilometre away.  I

22     was never on the spot.  I simply took part in preparing the

23     communications side of the operation.

24        Q.   Okay.  So in 1992 did you hear anything else about this event at

25     the Koricanske Stijene being discussed in Prijedor police department, if

Page 24979

 1     you remember?

 2        A.   No, no.  No one discussed it.  The first news came from this

 3     colleague.  As I said, he said he was tired because he had been there.  I

 4     have a feeling it was 15 or 20 days after the crime, maybe less, 10, but

 5     then it could be 30 as well.

 6        Q.   You're not aware of a number of dispatches back and forth between

 7     CSB Banja Luka and Prijedor regarding that event?  Do you remember seeing

 8     any dispatches about that?

 9        A.   Not from that time, but you prompted me or perhaps the

10     Defence - I don't remember who - because your dispatches resemble theirs.

11     It could be one of yours.  I may have seen it, and I think I even saw on

12     a dispatch that Simo -- well, I can be disrespectful and tell the -- I

13     think he said:  "I didn't conduct an interview because the people were

14     absent."

15             In our service this was not a normal way to go about things.  He

16     could have gone out in the field and find them, but I did see it when I

17     read your dispatches, not before.

18        Q.   Okay.  Certainly not in 1992; right?

19        A.   Just one more thing in this context.  The dispatch I have in my

20     hand, this one, from the minister, obviously this was not typed out on

21     any communications equipment.  Perhaps a typewriter and then it was

22     faxed.  If it was received by Banja Luka, I can't even read what it says,

23     but speaking from my experience, if Banja Luka received it from Sarajevo

24     by fax then this is it.  I don't think this had gone through the

25     communications centre, any communications centre, including Banja Luka.

Page 24980

 1     That's why the copy is so poor.

 2        Q.   Okay.  Yeah, let me show you a couple other documents that may

 3     shed some light on this.  If we can look at Exhibit P1380, it's tab 112.

 4     Witness, this one you may be able to read on the screen, it's a better

 5     copy.  It you need a hard copy, let me know.  Can you read that one all

 6     right?

 7        A.   No, no, this is enough, what's on the screen.

 8        Q.   Okay.  This one is dated the 11th of September, 1992, it looks

 9     like, from CSB Banja Luka to Prijedor to the chief and it says:

10             "We received the following dispatch numbered 10-245/92 dated 31

11     August ...  from the MUP ..."

12             And then it's from Minister Stanisic ordering you to conduct a

13     full investigation.  So it looks like basically the same order that you

14     were looking at on that bad copy just a minute or two ago.  And then

15     below the text of Minister Stanisic's order are some specific directions

16     from Mr. Zupljanin to the Prijedor chief.  At the top we see handwriting

17     with a number 11-12-668 and a date.  Is that again Mira Topic's

18     handwriting?

19        A.   Yes, yes.

20        Q.   And then what appears to be maybe different writing, I'm not

21     sure, the word that has been translated as the name "Marko."

22        A.   I see it as Marko.

23        Q.   [Previous translation continues]... Do you know what that or who

24     that refers to?

25        A.   As far as I know, there was just one Marko, Marko Djenadija, who

Page 24981

 1     I already mentioned.  So at that time Marko -- well, Marko was a komandir

 2     somewhere.  Even later after the war he was chief of the station.  But

 3     right now I don't see any role for Marko.  I don't know of any other

 4     Marko except Marko Djenadija.  I don't know what his role there is

 5     either.

 6        Q.   Do you know what position he held in September of 1992?

 7        A.   Well, I just said I cannot remember.  For a time during the war,

 8     he was the komandir of the station Prijedor 2, I think, or the traffic

 9     police because they were outside of the centre building.  But from when

10     to when, I really couldn't say.  Cadjo, Marko, they all followed one

11     another.  So I'm afraid I would make a mistake now.

12        Q.   Okay.  Let me show you two other documents relating to this and

13     then I think we'll move on.  Exhibit P682, which is tab 113.  This is

14     another one I think maybe you can read on the screen.  It's dated the

15     14th of September from Simo Drljaca to CSB Banja Luka, to the chief.  And

16     it's -- I think it's a response to the one -- yes, the one that you were

17     just looking at, 11-1/02-2-345.  And here he's saying we can't

18     investigate because those policemen that escorted the convoy have been at

19     the battle-field since 9 September.  Is this the document you referred to

20     before when you said you thought you'd seen one where Drljaca was

21     saying --

22        A.   Yes, yes, I was thinking about him earlier.  I don't remember

23     from what period.  The first time I saw him, I don't know whether this

24     was in conversation with your people or the defence, but I did see that

25     recently.

Page 24982

 1        Q.   And one more, tab 114.  This is 65 ter number 20268.  It appears

 2     to be a coded dispatch dated the 14th of September from Drljaca to the

 3     chief in Banja Luka, again referring to that same dispatch number.  It

 4     says:

 5             "We're not able to conduct an investigation since all the

 6     policemen have been deployed on the front since 9 September and also

 7     we're unable to provide you a list of the citizens who travelled on those

 8     convoys because this public security station didn't organise the convoys

 9     but only assigned a certain number of policemen to providing physical

10     security."  The Dusko S. and the date of 15 September, tell us about

11     that.  Is he a worker in your comms centre?

12        A.   Yes.  That is not the S, but it's the Sh, Sarac that I mentioned

13     before who had called me about that dispatch.  And then again you can

14     apply the logic that I spoke about recently in relation to these

15     handwritten parts, that means the dispatch was handed in, the chief wrote

16     the 14th of September, it was sent on the 15th of September; at a normal

17     time this would be an incredibly long time for it to be sent off to

18     Banja Luka.  You see 0750 here.  So I'm talking about what we talked

19     about, the difficult operation of the communications system, meaning that

20     it had stayed there all day.  Then this guy, Dusko, there's a Dusko up

21     there as well.  This Dusko received it from this other Dusko.  There are

22     two Duskos, one in Banja Luka and one up here.  Received by Dusko at 7.50

23     and it was dispatched by Dusko Sh, Sarac, that's our guy at our end.

24        Q.   Okay.  So it was sent and it was received in Banja Luka then

25     according to this?

Page 24983

 1        A.   Yes, this was received according to what Dusko wrote, at 7.50.

 2        Q.   Thank you.

 3             MR. HANNIS:  Your Honour, I'd like to tender that one.

 4             MR. KRGOVIC: [Interpretation] Your Honours, I would object to

 5     this because I believe that this document should not be admitted because

 6     the Prosecutor is actually tendering new evidence and in light of fresh

 7     evidence this document does not meet that criteria.  The Prosecutor did

 8     not give a clear reason why the document was not admitted earlier when it

 9     admitted the identical document as P00682.  And for those reasons, I

10     believe that the document should not be admitted.

11             JUDGE HALL:  Mr. Hannis, why would -- why was not this tendered

12     at the time that the Prosecution tendered the - I will call

13     them - companion documents?

14             MR. HANNIS:  Your Honours, I don't know the answer to that

15     question, but I do know I came across this in preparing for this witness

16     and trying to identify documents that dealt with what I perceived to be

17     the allegation in the 65 ter summary for this witness that Mr. Drljaca

18     was not -- was acting independently and was not responding to requests

19     for information from CSB Banja Luka and Mr. Zupljanin.  And that's why it

20     was proposed.

21             JUDGE HALL:  Apart from that, this is -- seems to be tangential

22     in terms of the witness who is presently on the stand.

23             MR. HANNIS:  Well, Your Honour, he is able to verify that it was

24     sent and it was received based on his knowledge of how the system works

25     and recognising the handwritten information with the names of two Duskos.

Page 24984

 1     I wasn't able to present that evidence through any other witness.

 2             MR. KRGOVIC: [Interpretation] Your Honour, if I may reply.  The

 3     previous document was shown to the communications chief by the

 4     Prosecutor.  He could have done the same with this document as he had

 5     with the previous one.  There were several witnesses, actually, in

 6     particular the communications chief who discussed it.  And that witness

 7     was used to introduce a number of documents through by the Prosecution.

 8     They had an opportunity to deal with it.  A number of other books were

 9     tendered through the same witness.

10                           [Trial Chamber confers]

11             JUDGE HALL:  We will have the document only marked for

12     identification because one of the considerations that we would wish to --

13     upon which we would wish to reflect is the -- any degree of prejudice

14     that the Defence suffers and how it could be remedied.  So for the time

15     being we -- the document is marked for identification.

16             THE REGISTRAR:  As Exhibit P2394, marked for identification,

17     Your Honours.

18             MR. HANNIS:  Thank you, Your Honours.

19        Q.   Witness, I want to move to another topic.  Did you know a police

20     officer in Prijedor named Slobodan Miljus, M-i-l-j-u-s?

21        A.   No.  I never heard such a name.

22        Q.   Okay.  Let me ask you, did you -- did you know about the

23     disciplinary procedures in the MUP in 1992, how that system worked, what

24     the rules were?  Did you know anything about that?

25        A.   I didn't.  Actually, I was familiar with it before the war and I

Page 24985

 1     know how things worked when I was in Banja Luka after 2002.  Before the

 2     war there was a disciplinary commission.  The chief in question had to

 3     put forth a proposal and then the commission would sit and decide on

 4     one's disciplinary liability.  After the war in the Banja Luka centre,

 5     there was a prosecutor who was there only to deal with cases involving

 6     official personnel.  Upon receiving a proposal from the commander, the

 7     Prosecutor dealt with it by way of an internal court of sorts.  It was

 8     not a state court.  They ruled according to the disciplinary regulations

 9     in place.  When that -- the transfer occurred between the previous and

10     the new system is something I can't recall.

11        Q.   Okay.  Thank you for that.  I'll move on to something else then.

12     I'd like to ask you in terms of communication, were you aware of -- I

13     don't know what to call it.  Related to the ministry on National Defence

14     or the defence ministry, are you aware of a communications system that

15     sometimes was referred to as the, I don't know, the information and

16     warning system, something like that?  Do you know what I'm talking about?

17        A.   I suppose.  You weren't quite precise in your definition, but I

18     think the name was centre for information, reconnaissance, and warning.

19     It was in the municipality, I think.  It was used in terms of -- in cases

20     of disasters, et cetera.

21        Q.   Yeah, that's -- I think you're talking about the thing I was

22     curious about.  I want to show you Exhibit P179.9.  This is tab 31.  I'll

23     just show you the cover page and then take you to a specific paragraph.

24     This document's from May 1992 and it's called "decision on the

25     organisation and work of the Crisis Staff of Prijedor municipality."  And

Page 24986

 1     if we could go to page 4 in the English and in e-court the B/C/S is page

 2     4.  And at the bottom item 8 or Article 8.  Can you read that okay,

 3     Witness, Article 8?  It says:

 4             "In order to work effectively within the area of civilian

 5     protection and reconnaissance and information service, the Crisis Staff

 6     shall do a couple of things and the second one is:

 7             "Via the Municipal National Defence Secretariat undertake

 8     measures and actions aimed at ensuring the successful functioning of the

 9     Communications System and the Reconnaissance and Information service."

10             Did you know about that?

11        A.   Sorry?  Via the municipal staff -- can you repeat again the

12     second item of Article 8.  It says I think via the Municipal National

13     Defence Staff and other elements, undertake measures and actions aimed

14     at -- I can't read it.  Civil protection, its tasks.  I can't read it.

15        Q.   Okay.  Well, I take it what the interpreters have translated into

16     English is saying that:

17             "Via the Municipal National Defence Secretariat, undertake

18     measures and actions aimed at ensuring the successful functioning of the

19     Communications System and the Reconnaissance and Information Service."

20        A.   Well, I understand now what the question is.

21        Q.   Okay.  So my question is:  Did you know about the existence of

22     that service and its communications system?

23        A.   Well, yes.  The centre existed before I came to the police.  This

24     is a centre that is located in the basement of the municipal building,

25     and they had equipment that used different frequencies from ours and the

Page 24987

 1     purpose of that equipment was for natural disasters, floods, and that's

 2     why it's called the centre for alerting and informing.  So they also have

 3     the sirens that you can sometimes hear in town.

 4        Q.   Did you know that that service and its communications system,

 5     network, was sometimes used to transmit information from, for example,

 6     Pale and the republican-level authorities out to Crisis Staffs and

 7     Municipal Assemblies in places like Prijedor and Banja Luka?  Did you

 8     know about their system working and how it worked during the war?

 9        A.   I didn't know much about that centre because I wasn't interested.

10     I had no functional connections with them.  It's true that there were

11     some links between our centre and theirs, but I didn't have any

12     particular interest work-wise.  But it's true that each municipality in

13     Bosnia and Herzegovina has such a centre or had such a centre.  And by

14     size and complexity, this corresponded to the size of the municipality.

15     There was a large centre in a large municipality, a small centre in a

16     small municipality.  And organisationally and constructively they were

17     intended to facilitate communications within the municipality between the

18     local commune, and by virtue of that they had local connections and

19     frequencies.  I don't know if they had connections that were broader than

20     that or not, and perhaps they could set up communications further out or

21     not.  I don't know.  I never followed that.  I never visited.  I never

22     was interested.  It wasn't open access, where they worked just like at

23     our centre.  It was only for privileged persons.

24        Q.   You mean like the Crisis Staff, privileged persons like the

25     Crisis Staff?

Page 24988

 1        A.   No, no.  I know who could enter our premises and who could not.

 2     As for them, I don't know.  I was never interested.  I never asked.  I

 3     don't know whether the Crisis Staff entered or not.  Conditionally

 4     speaking, my centre where I was the chief, the only people who could

 5     enter would be the operators, the staff, the chief, myself.  Nobody else

 6     besides those people.

 7        Q.   Okay.  So in 1992 you never had occasion to ask for assistance of

 8     that service in transmitting any documents?

 9        A.   We did not, no.  Because we were more professional than they were

10     I think.

11        Q.   Okay.  Let me show you just before the break one more document,

12     Exhibit 1D397.  And hopefully you can see this on your screen.  This is

13     another document related to the 29th of April.  This is not the one from

14     Minister Delimustafic, but it's forwarding a document from Colonel or

15     Commander Hasan Efendic.  But I'm not so interested in the content.  I

16     want to ask you some questions about the delivery information.

17             MR. KRGOVIC:  Tab number, please.

18             MR. HANNIS:  I'm sorry, it's tab number 27, Exhibit 1D397.

19        Q.   Can you see it okay on your screen, Mr. Jankovic?

20        A.   Yes, I can see just a bit.  It's not complete.  The letter-head

21     or the heading is not good and I don't see the signature.

22             THE INTERPRETER:  We do not hear what the witness is saying.

23             THE WITNESS: [Interpretation] Yes, it says up here.

24             MR. HANNIS:

25        Q.   Okay.  You see a five-digit number 41505 and then little letters

Page 24989

 1     SO followed by the letters PLE.  Do you know what that --

 2        A.   I'm sorry, I couldn't see it at the angle that I was sitting at.

 3     I have to stand.  Yes, I can see it now really well.

 4        Q.   Do you want the hard copy so you don't have to stand?

 5        A.   All right.  I mean, I can do it like this as well if it's not a

 6     problem.

 7        Q.   [Previous translation continues]...

 8        A.   Yes, all right, you can see it really well.

 9        Q.   And the number 45254 SUPBL, do you know what those stand for?

10        A.   I think that that is for our communications, the police ones,

11     that probably has nothing to do with that.  But from what I can remember,

12     and I don't remember that very well, this YU at the end, these are public

13     PTT communications, that this was a dispatch sent through the public

14     system -- maybe, maybe.  I think this 4150 would be the public telecomms

15     just like if you were sending a telegram to somebody, congratulations.  I

16     think that that's that system; our system didn't have the letters YU.

17        Q.   Okay.  Did you ever hear of something that was called the

18     republican communications centre in the RS in 1992, located in Pale?

19        A.   No.

20        Q.   Okay.  I think it's time for our next break, Mr. Jankovic.

21             MR. HANNIS:  I see Mr. Zecevic on his feet.

22             MR. ZECEVIC:  Your Honours, I note that the translation of this

23     document is incomplete, unfortunately.  This is the first time I saw

24     that.  Because you will see that after the words:

25             "We are forwarding this ... for SDS BiH ..." there are two lines

Page 24990

 1     stating five numbers and then SOSMYU and then, again, five numbers that

 2     say Vlada [phoen], Government of Bosnia and Herzegovina YU.  So the

 3     document needs to be sent to translations in order that the translations

 4     are complete of the whole document.  And since it is a 1D document, we

 5     will do that.  I just wanted to put that on the record.  Thank you.

 6             JUDGE HALL:  Yes, thank you, Mr. Zecevic.

 7             So we will resume at 12.25.

 8                           --- Recess taken at 12.04 p.m.

 9                           --- On resuming at 12.30 p.m.

10             JUDGE HALL:  Before the witness comes back in, the counsel would

11     have been alerted by the Chamber through our Legal Officer about the

12     discoveries in terms of this document that was marked for identification.

13     Do you have anything to -- do you have any observations, Mr. Hannis?

14             MR. HANNIS:  Yes, Your Honour.  In the light of that discovery, I

15     don't think I have the same problem that I did.  I understand P682 is the

16     same document minus the handwritten notations by the two communication

17     officers the witness testified about.  So I think, given the fact that I

18     have P682 in evidence, which is the text of the telegram, and I have the

19     testimony of this witness about that, reflecting that apparently it was

20     sent and received based on viewing those two signatures, I don't need it

21     in.  I suppose I would prefer to have -- what's been MFI'd as P2394 in

22     evidence instead of 682 because it's a more complete document.  That

23     would be my preference.  I understand the one with the handwritten

24     notation by the communication officers was disclosed to the Defence back

25     in 2008.  Why we used the one without the signatures instead of the one

Page 24991

 1     with signatures, I don't know.  I think that was probably just a glitch

 2     in the selection process.  Somebody looked at it, thought it was the same

 3     thing, and picked what now I would say was the wrong one.

 4             JUDGE HALL:  Thank you.

 5             Mr. Krgovic, there appears to me to be an irresistible logic to

 6     what Mr. Hannis is suggesting.  We just substitute the incomplete

 7     document for the complete one.  Do you have a problem with that?

 8             MR. KRGOVIC: [Interpretation] Yes, Your Honour, it's a problem

 9     that's in principle.  That's what I was talking about.  This is new

10     evidence that pursuant to the instructions of this Trial Chamber should

11     not be admitted.  This is a principled objection.  The Prosecution had

12     the document, it was on its list, and it did not tender it, and it did

13     not provide a valid reason why they did not do this.  And that is why I

14     believe a precedent like this, no matter how logical it might seem, would

15     open the door to the admission of similar documents in the future.

16                           [Trial Chamber confers]

17             JUDGE DELVOIE:  Mr. Krgovic, what would be new about it?  You say

18     it's new evidence.

19             MR. KRGOVIC: [Interpretation] It's a new version of this

20     document.  I don't have a problem with old documents in the record for

21     them to stay in the record, that would be sufficient for me, and the

22     Prosecutor has the testimony of this witness.

23                           [Trial Chamber confers]

24             JUDGE HALL:  The Chamber is satisfied that the document that has

25     been marked for identification should now be entered in substitution

Page 24992

 1     for -- thank you, for P682.

 2                           [Trial Chamber and Registrar confer]

 3             JUDGE HALL:  And we vacate -- sorry, what was that number again?

 4     P2394.  Thank you.

 5             MR. HANNIS:  Thank you, Your Honours.

 6        Q.   Mr. Jankovic, I now want to turn briefly to a document about

 7     Prijedor SJB.  This is tab 74 in the binder.  It's Exhibit P657 and I

 8     think it will work best if I can give you a hard copy because it's

 9     several pages.  I will tell you as it's coming around, this is a report

10     from Chief Drljaca to Banja Luka and to the -- I guess to Banja Luka at

11     least, June 1992, and it's a report on activities in the first half of

12     1992.  And the first point I want to ask you about is page 2 in e-court

13     in English and B/C/S.  And for you, witness, it's that left-hand page on

14     the table in front of you, the bottom paragraph.  Yeah.  I think just

15     above that paragraph there's a reference to the take-over of power by

16     force which was carried out on 29 April without a single shot being

17     fired.  Do you see that?  It's above that paragraph about eight lines up.

18     You find the date 29 April.

19        A.   Yes.  It says:

20             [As read] "The incident of the 29th and beside that extremists

21     from the ranks of the HDZ have totally prepared to take absolute power

22     over and engage in unprecedented terrorism against the Serbian population

23     which necessarily resulted in intensive and continuous preparations for a

24     take-over of power by force which was carried out on the 29th of April

25     without a single shot being fired and without bloodshed."

Page 24993

 1        Q.   And two sentences after that it says, "They prevented" -- it's

 2     talking about the extremists from other national parties.  "They

 3     prevented non-Serb SJ employees from signing statements on loyalty."

 4             Did you know anything about that about HDZ or SDA extremists

 5     keeping non-Serb police employees from signing the new statement of

 6     loyalty or solemn declaration as it's sometimes called?

 7        A.   I don't know.  This is too narrow.  In the context of what?  I

 8     don't know if there were any.  I don't know.  It's -- I'm not aware of

 9     them.  Perhaps there were.

10        Q.   Okay.

11        A.   He's talking now about the taking over of power of the 29th of

12     April and that the extremists prevented that.  When?  Before or after?

13     When?  Nothing is clear to me.  And I don't remember any of that.  I

14     don't know.

15        Q.   Okay.  Let me take you to something that's more in your field.

16     It's page 4 of the English in e-court.  And for you, Witness, it's --

17     well, in e-court it's page 5 of the B/C/S.  Yeah.  You'll see a section

18     on "work and tasks and maintaining the communications system."  I think

19     you've got it there.  You see that?

20        A.   Page 5?

21        Q.   No, I'm sorry.  That number -- no, I think you're on the correct

22     page because when I say "page 5," it includes the cover page so it's the

23     page number 4, yeah.  And that talks about the kind of work that was done

24     to maintain the communications system.  So you guys were working not only

25     in Prijedor but were you also helping assist Dubica, Sanski Most, and

Page 24994

 1     Novi?

 2        A.   Yes, yes.

 3        Q.   Okay.  If you could turn to the next page and in e-court we have

 4     to go one page further in the B/C/S but stay on the same English.  If you

 5     could turn to the top of the next page.  My English translation says:

 6             [As read] "In addition to the above ...  activities, a whole

 7     number of other individual ones were ...  carried out, such as working on

 8     power generators and power supply equipment and ...  working on the UKT,"

 9     ultra short-wave equipment, "in war time conditions ..."

10             And the last sentence says:

11             [As read] "It is necessary to mention that during preparations

12     for military operations, four mobile and three fixed radio stations were

13     fixed using obsolete radio stations and given to users."

14             Did you know about that?  Did you participate in that activity,

15     providing four mobiles or fixing four mobiles and three fixed radio

16     stations in connection with preparations for military operations?

17        A.   Well, this here is a little bit.  If I understood this last bit

18     just a little bit, because Simo is talking about preparations to avoid

19     any unclear matters.  What was done?  I was definitely, just like all

20     bosses, producing reports for everything and submitting them to my boss,

21     who was Simo at the time.  So I would look at my records and all of this

22     that is written here, how many stations repaired, and so on and so forth.

23     And then that would be done and then I don't remember now but due to a

24     general lack of - how should I put it? - lack of -- well, equipment was

25     deteriorating and then perhaps we would repair old equipment that was out

Page 24995

 1     of commission.  But it was not something that was part of a preparation

 2     for a take-over of power.  That was part of our regular work.  And if

 3     Simo - perhaps I don't see this here, perhaps I'm making assumptions

 4     about all of this because I don't see if Simo wrote this or not because

 5     he maybe saw that as us doing that in some sort of preparation for his

 6     coming, perhaps he saw it like that, but it wasn't like that at all.  We

 7     were just doing that as part of our regular service.  And, yes, here he

 8     wrote:

 9             "It is necessary to note that during preparations for current

10     military operations ..." you could see that the technical job that was

11     done was correct that I put in a report that was done, and then when I

12     write I don't usually comment this station was nice, this one was good,

13     this one was no good.  I just put the numbers there from the staff that

14     was working on them, how much was done, as you can see on the list.  And

15     then you can see that Simo was evidently presenting that somewhere

16     further up as if we were doing some sort of something.  This was all done

17     as part of our work.  The communications centre could not have been

18     working parallel on two tracks.

19        Q.   Okay.  Let me ask you a few questions to clarify.  That text that

20     we just read out in this report, I'm operating under the understanding

21     that that was written by Mr. Drljaca, not by you; right?

22        A.   Yes, yes.  His, not mine.  My report perhaps has three pages and

23     then he just takes what he needs, numbers and then he puts his own

24     writing in it.

25        Q.   I'm assuming these numbers on the previous page about the types

Page 24996

 1     of equipment repaired and all those numbers came from you; right?

 2        A.   Yes, yes.

 3        Q.   Yeah.  But the reason I'm asking you about this reference to

 4     preparations for military operations and certain radio equipment in

 5     connection with that, is that I can't remember exactly where it was but

 6     you were -- you were asked about if you were aware of the Prijedor police

 7     being involved in any military operations in the municipality in May and

 8     June and you said something along the lines:  No, that couldn't be

 9     because I would have known about it, because they would have needed my

10     communications support.  Do you remember that?  Do you remember having a

11     question and answer like that?

12        A.   I remember it hazily.  Could you be more specific?  What do you

13     have in mind?  What operation?  I'll try to be clearer.  If there is a

14     one-time operation, they can ask for communications assets from me and

15     return them following their operation.  Now, whether they did something

16     without asking for my equipment is something I no longer remember.

17        Q.   Well, I had the impression that you were saying that as far as

18     you knew in May and June of 1992 no police were involved in combat

19     operations in Prijedor municipality because you would have known about it

20     because you would have had to have been involved in communications

21     support.  And I took it your answer to mean that all those combat

22     activities in the area of the Muslim villages, Kozarac and Hambarine and

23     Biscani, et cetera, were done by the army with no police.  I took that to

24     mean that was what you were saying.  Is that what your belief was, that

25     the police didn't anything to do with any of those?

Page 24997

 1        A.   What you just said is something I believe I said already.  I'm

 2     trying to recall it now, but from the fact that I don't know you can't

 3     conclude that the police did not participate.  I'm simply saying that

 4     they did not ask for my assistance.  There were always pieces of

 5     equipment that were constantly used and then if they needed a surplus,

 6     they asked.  They could have carried out an operation with such pieces

 7     without requiring any additional ones.  In any case, if they did anything

 8     of the sort, I wasn't included.

 9        Q.   Okay.  Thank you.  That answers my question.

10             If we could go to page 5 of the English in e-court and,

11     Witness --

12             MR. KRGOVIC:  I apologise, but I think that this part of

13     witness's response is not properly recorded.  Line -- it's page 61, line

14     from 10 until 17.  Witness said something different - it's not recorded -

15     about the -- he used the word "vecim operacijama" [Interpretation] larger

16     operations or more important operations.  That part is missing.  Could we

17     please have it repeated.

18             MR. HANNIS:  [Microphone not activated]

19             THE INTERPRETER:  Microphone, please.

20             MR. HANNIS:  Sorry.

21        Q.   Witness, you heard what Mr. Krgovic said.  I understood you to be

22     saying that the police may have participated in combat operations without

23     you knowing about it because they may have been able to use radio

24     equipment that they already had or perhaps that they got from somewhere

25     else.  Is that right?

Page 24998

 1        A.   Not from someone else.  They definitely could not receive that.

 2     They either had their own or, actually, the ones they were issued

 3     with - and I'm the custodian, actually -- however, I only see such pieces

 4     of equipment when they break down or when they need to be recharged by my

 5     technicians.  In any case, I was the boss and in charge of monitoring it

 6     all.  The police definitely used communication means that they had at

 7     their disposal, although I don't know whether these were pieces of

 8     equipment that they regularly used or if they needed something on top of

 9     that.  I don't remember.  It could have happened that someone asked for

10     one or two hand-held radios, but it's such a small number that I wouldn't

11     remember it anyway.

12        Q.   Okay.

13             MR. HANNIS:  If we can go to page 5 of the English.

14        Q.   And for you, Witness, it's -- in e-court it's the B/C/S page 7.

15     I think for you, Witness, it's page number 6 at the top.  Yeah, I think

16     it's that page.  And the paragraph that starts under the bullet point

17     that says 14 charges were filed.  It says "in the second quarter," do you

18     find that?  "In the second quarter, the take-over of power took

19     place ..."

20             Do you have that?

21        A.   Yes, I see it.

22        Q.   Yeah.  "...  and fighting broke out.  All Muslim and Croatian

23     officers refused to sign statements of loyalty and some even actively

24     participated in the armed rebellion.  Activities were focused on covering

25     the terrain, protecting socially owned and private property and

Page 24999

 1     participating in combat operations."

 2             So from that I understand that some of the Prijedor police were

 3     participating in combat during this time-period prior to Mr. Drljaca's

 4     report; would you agree?  That seems clear.

 5        A.   We need to be precise.  Who and in what fighting?  Do you mean

 6     Muslims or Serbs when you say "some"?

 7        Q.   Well, he's talking about -- the report is about the Prijedor SJB

 8     and so he says "... activities were focused on covering the terrain,

 9     protecting socially owned and private property and participating in

10     combat operations."

11             I assume he means the Prijedor police were doing that?

12        A.   Yes.  Keep going.

13        Q.   And then it talks about the captured extremists from these combat

14     operations because there were so many three reception centres were

15     established, Omarska, Keraterm, and Trnopolje.  My question is about the

16     next sentence.  It says:

17             [As read] "All operative officers were engaged in carrying out

18     investigative activities."

19             One question comes to mind.  You said your wife worked in the

20     department in economic crimes.  To your knowledge was he involved in

21     investigations on Omarska, Keraterm, and Trnopolje?  Was she an

22     operative?

23        A.   Yes, she was, but she was also the only female among all

24     operative employees.  It was probably for that reason that her boss did

25     not send her to Omarska or Keraterm to work.  It was quite tiresome even

Page 25000

 1     for men.  They needed a person in the centre at all times anyway for some

 2     small tasks.  There were no interrogations or operative treatments there.

 3     They simply needed someone who would be there on duty and it was because

 4     she was a woman.

 5        Q.   Thank you.  I think that answered my question.  She didn't have

 6     to go to Omarska or Keraterm or Trnopolje in 1992?

 7        A.   According to the rules of service, she should have.  But she did

 8     not have to thanks to her boss.  She wasn't made to go.

 9        Q.   Thank you.  I think that's all the questions I had for that

10     document.

11             JUDGE HALL:  Mr. Hannis.

12             MR. HANNIS:  Yes.

13             JUDGE HALL:  As you move on, appreciating that you began with the

14     comparative disadvantage of not having had the opportunity to speak with

15     this witness beforehand, the -- do you think that you would, having now

16     spent some time with him on the stand, do you think you would need all of

17     the two hours and 40 minutes that you have left of what you had required?

18             MR. HANNIS:  [Microphone not activated]

19             THE INTERPRETER:  Microphone, please.

20             MR. HANNIS:  I'm sorry.

21             My estimate earlier today when somebody asked me I think I will

22     need one session tomorrow.  I don't need time beyond the eight hours, but

23     I think I may need my full eight hours.  I suppose I might finish in an

24     hour tomorrow.  I know I have two particular topics and documents that I

25     want to cover tomorrow that are the most important remaining things and

Page 25001

 1     I'll try and do everything else between now and 1.45.

 2             JUDGE HALL:  Thank you.

 3             MR. HANNIS:  Thank you.

 4        Q.   Witness, I want to show you now another document regarding

 5     Mr. Drljaca.  It's tab 30, but before I bring that up, though, let me ask

 6     you this:  Do you remember when Mr. Drljaca left the Prijedor SJB and

 7     took up a position in the office of the Ministry of the Interior?  Did

 8     you know that?  He held a position in I think the office of public

 9     information?  Did you know about that?

10        A.   I don't know what he did, but I do know he was replaced.  He was

11     no longer in Prijedor but in Bijeljina.  I don't know what he did there,

12     though, and he did return later on.  He wasn't away too long, but I don't

13     know what he did there.  As far as I remember, Bogdan Delic was the

14     station chief in the interim period.  It's been quite a long time ago and

15     many people rotated.  I think it was Bogdan and I'm sure the other was in

16     Bijeljina, although I don't know what he did there.

17        Q.   Okay.  But in Bijeljina it was with the police, it was a job with

18     the police, with the Ministry of the Interior; right?

19        A.   I suppose so.

20        Q.   Okay.  And he returned to be the chief in Prijedor, at least by

21     sometime in 1994, he was again the chief; right?

22        A.   Yes, he did return and again he was the chief.  I think it was

23     when I was on sick leave.  I did used to see him, but I can't be specific

24     as to the dates.

25        Q.   Okay.  Do you remember when you began your sick leave in 1994?

Page 25002

 1        A.   In 1994 it was definitely sometime in March.  I would have to try

 2     and recall it all.  I was in the hospital for a month and then there was

 3     a recovery period of 40 days.  There was an operation in June, but all

 4     the medical checks they had to do took quite a long time.  I think

 5     sometime in March, in the spring of that year.

 6        Q.   All right.  I think the document I have that reflects him back as

 7     chief in Prijedor is from April of 1994, so you may not know about that.

 8     And speaking of Mr. Drljaca, you mentioned Tomasica as a place you had to

 9     drive by sometimes when you were travelling from Prijedor.

10        A.   Yes.

11        Q.   It's my understanding there is a mine there?

12        A.   Yes.

13        Q.   Did you ever hear about hundreds or thousands of Muslim bodies

14     having been placed in the Tomasica mine in 1992?

15        A.   How would I know that?

16        Q.   Well, it seems like --

17        A.   One doesn't hear such things, and even if you do you don't want

18     to listen to it.  Who killed whom where and what they did with them.  If

19     I heard such a thing, I forgot it on the spot.  But I'm pretty sure I

20     have never heard this.

21        Q.   If we could look at 65 ter -- no, I'm sorry, tab number 143,

22     Exhibit P1767.  And, Witness, I think I need to give you a hard copy of

23     this one.  You will not have seen this before I'm sure.  I will tell you

24     this is an excerpt from what's been identified as a diary of

25     General Mladic from 1993 and the entry we're looking at is from the 27th

Page 25003

 1     of May, 1993, and I would like to go to page 4 of the English and page 4

 2     in the B/C/S in e-court.  And this is Colonel -- at the bottom of the

 3     fourth page for you it's got that little green stickie on it.  Yeah --

 4     no, go back, go back one page.  Yeah.  The bottom left page you'll see is

 5     highlighted in pink.  It's Colonel Bogojevic speaking apparently and he

 6     says:

 7             "4 to 5 days ago Simo Drljaca arrived, the former Chief of

 8     Prijedor SUP, sent by the minister of the RS and he came about the

 9     Tomasica mine."

10             And you have to go on to the next page in English and B/C/S:

11             " ...  near Prijedor, where earlier they had buried around 5.000

12     Muslims bodies.  I'm sure the world knows about this from the released

13     prisoners.

14             "Drljaca came to leave this with us and they want to get rid of

15     it (by burning, grinding, or some other way).

16             "There are all kinds of bodies and they have involved Subotic,"

17     who I believe is a reference to the minister of defence Bogdan Subotic.

18             "The team includes Drljaca, he was in charge even while this was

19     being done, at the meeting were General Subotic, Arsic, Drljaca, me, and

20     Mile Matijevic from the BL SUP."

21             So you never heard any rumours about this, about bodies in the

22     Tomasica mine?

23        A.   To tell you the truth, I hear about something like this for the

24     first time in my life, about Tomasica.  I never came across a number of

25     5.000 corpses.  It's an enormous number.  I would have remembered

Page 25004

 1     something of that sort.  I didn't hear of any much smaller numbers, let

 2     alone 5.000.  It would involve columns of trucks.  I don't believe this.

 3     If Simo did, there must have been reasons for it.  But as for the entire

 4     entry, it's something I have never heard about.  The number of 5.000?  No

 5     way.  It must be a hundred times over whatever it could have been.

 6        Q.   Well, did you ever hear of any smaller number of bodies of

 7     Muslims being in the Tomasica mine?

 8        A.   Yes, not in Tomasica but, for example, what we mentioned a moment

 9     ago, Koricanske Stijene, and the figure of 50 or 80.  I heard about such

10     figures in different situations, but not 5.000.  Not in my life.  I don't

11     think even in Jasenovac there were as many people killed.  I have never

12     heard of Tomasica being mentioned in this context.  I know there was a

13     mine there.

14        Q.   Okay.  Thank you.  Next I think I need to go back to one

15     log-book.  I think you and I like to do that, but I'm not sure anyone

16     else does.  I'd like to hand you tab 128.

17        A.   I was hoping you lost them along the way, but you kept them it

18     seems.

19        Q.   I think you're not the only one that was hoping that.  I'm sorry,

20     I do want to show you this one if I may.

21             And I'll have the usher hand you a hard copy.  And let me just

22     find the correct starting page for you.  This is Exhibit P1025.  And can

23     you tell us from the cover page anything about what it is?  It simply

24     seems to say "book 91, 92, 93, 94."

25        A.   I think archaeologists would be better suited.  I don't remember

Page 25005

 1     this book.  Perhaps if I opened it I might be able to see something more.

 2        Q.   Okay.  If you could go to the page I've marked, we'll look at

 3     some of the documents listed in there and that may help you identify what

 4     it is, the yellow tab at the top will take you to 1992.  That's page 86,

 5     I believe, in e-court in the B/C/S.  And it's the first page in the

 6     English translation.

 7             MR. ZECEVIC:  I'm sorry, I think the witness is having problems

 8     with the clip.

 9             MR. HANNIS:  He's got it off now.  Thank you.

10        Q.   Do you see that, "1992"?  I believe you were shown this book or

11     parts of this book --

12        A.   Yes.

13        Q.   You were shown parts of this book during the OTP interview by

14     Mr. Yarmah and Ms. Beausey and you were able to identify some of the

15     handwriting.  Now, I'm not so interested in the first part of the year

16     when Mr. Talundzic was the chief.  If you could begin by looking at --

17     well, first, before I take you to the first entry I wanted to ask you

18     about, could you go to the last page for 1992, which as you page through

19     you will see the last entry is numbered 828.  So if you're reading the

20     numbers in the left-hand column, can you go until you get to 828, which

21     is 118 in e-court in the B/C/S and the last page of the English.

22        A.   Very well.  I understand it.

23        Q.   And at the bottom --

24        A.   I found it.

25        Q.   Okay.  At the bottom we see a -- some writing and a date and what

Page 25006

 1     appears to be a signature.  Do you recognise any of that?

 2        A.   This looks like MT, Mira Topic.  But I don't remember her

 3     specific signature.  I'm also looking at the hand-writing.  All things

 4     put together it should be her.  I think it's her handwriting and the

 5     initials could be MT, Mira Topic, but otherwise she didn't use to sign

 6     documents much.  She was a secretary.

 7        Q.   Okay.  I understand.  I think when you looked at this document

 8     before you identified some of the handwriting in this as being

 9     Mira Topic's, but there was a portion where you indicated that some of

10     the writing appeared to be by some of your communication people.  I would

11     like you to look first at page -- or for the entry that is number 300

12     and --

13        A.   Which one?

14        Q.   302.  And that's --

15        A.   I couldn't have said that it was our signalsman.  I don't

16     recognise this handwriting --

17        Q.   No, right now I just have a question about --

18        A.   302?

19        Q.   Yeah, right now I just have a question about some of the

20     abbreviations.  Under the column "from" it says MUP of the SRBHSSR.  Do

21     you know what SSR stands for in that context?

22        A.   SRBH MUP, the Ministry of the Interior, the Socialist Republic of

23     Bosnia and Herzegovina.  It was the official title before the multi-party

24     elections and the new constitution.  That was in SFRY.

25        Q.   And there's a column for urgency and it's column number 6 and

Page 25007

 1     then column number 7, system.  I think you've explained about some of the

 2     designations, but I just want to be clear.  The DX, that stands for

 3     non-urgent; is that correct?

 4        A.   You're not correct.  You were rushing along, so I will repeat.

 5     O, DD, DX, and B are urgent.  The rest are usual dispatches or ordinary

 6     ones.  DX in terms of context are separate.  These are urgent operative

 7     measures.  If someone stole a bicycle or raped a woman or hit someone

 8     with a car and fled, then such information would be included in DX

 9     dispatches.  The contents defined that type of dispatch and the dead-line

10     was two hours.  DD and very urgent, these are state matters, say if there

11     was an attack.

12        Q.   Okay.

13        A.   These are designations for urgency depending on the type of

14     information they contain.  DX, urgent operational measures.

15        Q.   And the -- in the next column we'll see either I think one of

16     three designations, either O, which I understand means open; Sh, which

17     means coded; and very urgent is another designation?

18        A.   There were two designations, depending on the urgency and

19     confidentiality.  Both contained O's.  In the first one it means plain;

20     in the second case it is open.  You can have an OO dispatch, which is the

21     lowest on the list in terms of importance.  They could take the most time

22     and were of least relevance.  A double O would mean plain open.  However,

23     they could all be coded and they could all be open.  The very urgent

24     dispatches were regularly coded.  DX, for example, could be very urgent

25     but open.

Page 25008

 1        Q.   If you could go to page -- in e-court the B/C/S is page 92 and it

 2     has the first entry at the top as number 176, which in e-court the

 3     English is page 7.  Do you recognise the handwriting on that page,

 4     Mr. Jankovic?

 5        A.   Just one moment, 199 --

 6        Q.   176.

 7        A.   It's in the same year; right?

 8        Q.   Yes.  176 at the top of the page.

 9        A.   All right.  176.

10        Q.   Can you look at that and the following four or five pages and

11     tell me, is that the writing of Mira Topic or someone else?

12        A.   That first one definitely is not, but I cannot remember who it

13     is.  I don't know.  I know as much as you do.  When you look at the two

14     handwritings, they're not the same, no.

15        Q.   Okay.

16        A.   It's not as far as I can see.  I could be wrong.

17        Q.   And if you would continue on to page 98 in e-court in the B/C/S

18     and go to document number 320 and in English in e-court that's page 13.

19     Do you find that one?

20        A.   I think that's it, 2266, is that it?

21        Q.   That's it, that's it.  The top five or six entries appear to be

22     by someone else, and from number 332 on, that looks like the writing that

23     we've come to associate with Mira Topic; do you agree?

24        A.   Well, that's what it looks like to me too.

25        Q.   And from what -- take all the time you need and if you want you

Page 25009

 1     can take this home with you at the end of the day.  But would you take a

 2     look at the nature of the dispatches and in the right-hand column the

 3     indications as to who signed for it or for who it went and tell me if you

 4     can draw any conclusion about whose book this was, who kept this book,

 5     and what it is.  Is it incoming documents?  Is it outgoing documents?  Is

 6     it a book that was in your comms centre or was it a book that Mira Topic

 7     kept in the chief's office, if you can say based on looking at the

 8     documents.  And if you want more time, we can set that aside and you can

 9     take it home with you when you go home this evening and tell me in the

10     morning or if you think you only need a couple of minutes right now, we

11     can do it right now.  I leave it up to you.

12        A.   I leave here so tired, I don't recall when I felt so tired the

13     last time, when I was taking my final exams at school or university.  So

14     perhaps we can have an extra ten minutes and we can finish that together

15     with the Prosecutor.  So I might have a tendency to go off on a tangent

16     and perhaps if we go through this by talking, point by point, then I can

17     deal with that.  Otherwise, I have to worry about if I take the document,

18     where would I take it, what would I do with it.  Perhaps then we can just

19     have your permission to stay just ten minutes longer and just complete

20     this right here.  I mean, if I have to, I will take it with me.  I would

21     put it somewhere.

22        Q.   Okay.  The reason I ask was maybe I should go back and look at

23     your OTP interview because I know it was shown to you and talked about

24     with you and maybe if I can point you to some parts of that interview

25     that will refresh you memory.  That might be a more efficient way to do

Page 25010

 1     that.  I can do that in the morning.  I can go home, even though I'll be

 2     tired too, because this is hard work for both of us, I think and try and

 3     identify those parts that will make it easier.  Let's do it that way

 4     because I know at this time of day, I think both you and I were a little

 5     tired yesterday and I'm starting to feel that way now.  Is that all

 6     right?

 7        A.   Yes, that is better.  But I would like to say something else what

 8     is most tiring to me here.  Right now, this third time at the Tribunal, I

 9     am getting the most tired.  Why not?  Because I gave several statements

10     to the same circumstances and now I'm afraid, because I'm tired, I might

11     not say exactly the same thing and I don't want it to be -- to seem as if

12     I was not telling the truth or anything like that.  But in any case my

13     intentions are not bad.

14        Q.   I understand that and I believe that's absolutely true.  I know

15     you're meticulous and you've expressed several times, not only here but

16     in your prior testimonies and in your interview, that it's important to

17     you not to make a mistake.  So I understand that and I don't want to push

18     you into a situation like that.  Do you want to go on for another 10 or

19     15 minutes today or would you like to recess now?

20        A.   Whenever you wish.

21        Q.   Okay.  Let me then go away from that document for now and I'll

22     take you to Exhibit P1615.  It's tab number 4.  And let me actually skip

23     over that one and go to tab 5, that's more important.  Witness, tab 5,

24     Exhibit Number P531.  And I'll hand you a hard copy because it's two

25     pages.  I'll tell you as that's coming around to you, it's dated the

Page 25011

 1     23rd of March, 1992.  We need to get the -- yeah.  It's from

 2     President Radovan Karadzic to all municipal presidents, I guess SDS

 3     presidents.  And in paragraph 2, it says:

 4             [As read] "Assessing that an important condition for the

 5     protection of the Serbian people in the current situation is the rapid

 6     and timely transmission of data and information of significance for

 7     defence and security, and the passing on of decisions, directives, and

 8     instructions from the administrative organs, we have established a

 9     Republican Operations Centre and have decided that, besides the district

10     centre in Banja Luka, municipal centres in other areas will assume the

11     role of district centres."

12             I think you told me before you had not heard of the republic

13     communications centre or how about this term, the republican operations

14     centre --

15        A.   [No interpretation]

16             THE INTERPRETER:  Interpreters kindly ask that the witness repeat

17     what he said.

18             MR. HANNIS:

19        Q.   I'm sorry, I talked over you.  The interpreters ask if you can

20     repeat your last answer.

21        A.   I never heard of it.  I'm looking at this paper and seeing this

22     for the first time.  This is the first time that I'm hearing about this

23     operations centre.

24        Q.   Okay.  If you would go down two more paragraphs it says:

25             [As read] "The district centres in Banja Luka, Trebinje, Sokolac,

Page 25012

 1     and Bijeljina are already linked with the Republican TT, telephone and

 2     telegraph centre, and by radio link, while the district centres in

 3     Sekovici and Petrovo will be connected by 26 March 1992."

 4             Did you know about this communications system in March of 1992?

 5        A.   No, no.  I didn't know anything about that.

 6        Q.   Let me show you another document that may relate.  This is tab 69

 7     in Exhibit P1725.  I think you can work off the screen on this one.  It

 8     will be up in a minute and you should see it's dated the 18th of June,

 9     1992, from Minister of Defence Colonel Bogdan Subotic.  It's addressed to

10     the ministries of the government advising them that:

11             [As read] "The communications centre at Pale can send telegrams

12     to the Serbian Autonomous Region of Bosanska Krajina and to other Serbian

13     autonomous regions, which can be used for notifications and requests."

14             Did you know about that communications system which apparently

15     was associated with the government or with the Ministry of Defence?

16        A.   First of all, it's not defined here what communications centre?

17     Communications centre is the official name and it's known who that refers

18     to, the communications centre of the Ministry of the Interior and this is

19     some communications centre at Pale.  This is an amateur thing.  Which

20     communications centre?  I never heard of a communications centre in Pale

21     through which us communications personnel were supposed to -- I don't

22     know, what sort of a communications centre in Pale?  This was municipal,

23     military, police type of centre?  I don't know what it refers to.  We had

24     nothing to do with it.  I said at the time that they -- my operators had

25     some phone number which if they managed to get through, they did; if

Page 25013

 1     not -- this was a number to Pale.  So sometimes it would succeed and

 2     sometimes not.  It did not matter.

 3        Q.   Okay.  You talked about --

 4             MR. KRGOVIC:  I do apologise.

 5             MR. HANNIS:  Sorry.

 6             MR. KRGOVIC:  There is one mistake in the transcript.  77,

 7     line -- paragraph -- no -- page 77 and line 2 and 3.  Because what was

 8     recorded was it was said -- 5 and 6.

 9             "This was military, police type of centre," but that's not what

10     the witness said.

11             MR. HANNIS:

12        Q.   Mr. Jankovic, did you hear that.  The transcript says:

13             [As read] "I don't know what sort of a communications centre in

14     Pale?  This was military, police type of centre."

15             Is that what you said or did you say something different?

16        A.   No, no.  I said the first line right away after the heading it

17     says the communications centre in Pale is possible.  Everything else to

18     me makes no sense.  If you don't know who it is, then I don't care what.

19     You know, communications centre, communications centre of what?

20     Military?  Police?  The ham radio operators?  We had ham radio operators

21     during the war.  I don't know.  So for me, that means nothing.  Had I

22     received that then -- I am seeing this paper now for the first time and I

23     have nothing to say now other than what I have already said.  If there is

24     no name, then it's nothing, that communications centre has no name,

25     communications centre in Pale.  Only God knows what could have been in

Page 25014

 1     Pale.  Said the MUP communications centre, the CJB communications centre,

 2     the communications centre of the police in Pale, then I would have known

 3     what we had here, but this I have no idea.  So it makes no sense to make

 4     any further assumptions.

 5        Q.   I take it then that you weren't aware of the provision under the

 6     Law on Defence from 1 June 1992 in the Republika Srpska provided that the

 7     Ministry of Defence was to establish communications for the purposes of

 8     command and control in the case of war or imminent threat of war.  Did

 9     you know about -- okay.

10        A.   No, no.

11        Q.   Did you know a Mr. Vukovic who worked in the republican centre

12     for that body that you described in Prijedor that dealt with the early

13     warning system for disasters and floods and sounding the air-raid siren,

14     that kind of thing?  Did you know that there was a central office for

15     that organisation in Pale?

16        A.   I didn't know.  It's possible that it was there and possibly it

17     was not -- I did not convey any information to them.  I don't know.  I

18     don't know Vukovic.  There are a number of Vukovic's.  The only Vukovic I

19     knew was an engineer who worked in Banja Luka in the state security

20     before the war -- security, Vukovic, Drago, I think.

21        Q.   No, different guy.  What about -- did you know a Nebojsa Savic

22     who had some dealings in working with communications?

23        A.   I knew something.  He was a ham radio operator.  Before the war

24     he worked in the SUP of Sarajevo.  He was a policeman before, then he

25     joined communications, I don't know when, then he was this guy who writes

Page 25015

 1     the dispatches like those guys of mine, Sarac and others.  And then

 2     shortly before the war he went into the maintenance and repair of radio

 3     equipment.  And all of that was as part of the Sarajevo city SUP.

 4        Q.   Okay.  You weren't aware of any work he did in setting up a

 5     clandestine communications system for the SDS before the start of the war

 6     in 1992?  Did you know anything about that?

 7        A.   Before the war?  No, I don't know what he could have done.  He

 8     was a ham radio operator, that's true.  But I don't know what he was

 9     doing in Sarajevo.  I have no idea.

10        Q.   In Prijedor after the 30th of April, 1992, during 1992 did you

11     ever have any occasion to try to communicate directly with MUP

12     headquarters, whether it was in Pale or somewhere else in Sarajevo or in

13     Bijeljina?  Did you have any direct communication with them in 1992?

14        A.   I gave the example earlier of that director, the Laki [phoen]

15     award recipient.  I didn't really talk about that.  After the 30th of

16     April, a large number appeared in schools and all over the place of those

17     who wanted to be directors.  For example, a Muslim was a director before

18     so others wanted to be directors.  And so one of them addressed me, I

19     didn't know him before, his name was Milenko Vracar, I think, if he could

20     send a fax to Pale to the ministry, their Ministry of Education, so that

21     they would agree that he could be a director.  He was brought by some guy

22     from the SDS Dusko -- I don't know what his name was.  Well, it doesn't

23     matter.  I knew the person from security who had brought him.  And

24     knowing that these communications were not really going well, not

25     operating, and I said:  Well, there's no chance.  But then I thought I

Page 25016

 1     don't want to refuse you so just leave that paper and we will send it.

 2     And can you imagine, he had the luck and in about two or three minutes

 3     there was approval for him -- that came back for him to be a minister --

 4     no, I mean, not a minister -- I mean, it was like winning the lottery as

 5     far as I was concerned.  So judging by his example, we concluded that the

 6     communications were really working.  Sometimes it would take a few days

 7     for something to get through to Pale, but in his case it was very quick.

 8     So the communications went through very poorly, but then again you have

 9     this factor of probability.  Some important things did not get through

10     and something that was not important did.  And there you have it.

11        Q.   Thank you, witness.

12             MR. HANNIS:  Your Honours, I know it's five minutes early, but I

13     think this would be a good place for me to break, organise myself and try

14     and finish everything else in one session tomorrow.

15             JUDGE HALL:  So we resume at 9.00 tomorrow in this courtroom.

16                           --- Whereupon the hearing adjourned at 1.38 p.m.,

17                           to be reconvened on Friday, the 14th day of

18                           October, 2011, at 9.00 a.m.