Tribunal Criminal Tribunal for the Former Yugoslavia

Page 10486

1 Tuesday, 8 June 2004

2 [Open session]

3 [The accused entered court]

4 [The witness entered court]

5 --- Upon commencing at 2.16 p.m.

6 JUDGE LIU: Call the case please, Mr. Court Deputy.

7 THE REGISTRAR: Good afternoon, Your Honours. This is Case Number

8 IT-02-60-T, the Prosecutor versus Vidoje Blagojevic and Dragan Jokic.

9 JUDGE LIU: Thank you.

10 Good afternoon, Witness. Can you hear me?

11 THE WITNESS: [Interpretation] Yes. Yes, I can hear you.

12 JUDGE LIU: Would you please stand up and make the solemn

13 declaration in accordance with the paper Madam Usher is showing to you.

14 THE WITNESS: [Interpretation] I solemnly declare that I will speak

15 the truth, the whole truth, and nothing but the truth.


17 [Witness answered through interpreter]

18 JUDGE LIU: Thank you. You may sit down, please.

19 Yes, Mr. Karnavas.

20 MR. KARNAVAS: Good afternoon, Mr. President, Your Honours.

21 Examined by Mr. Karnavas:

22 Q. Good afternoon, sir.

23 A. Good afternoon.

24 Q. Could I get the assistance for the ELMO to be lowered a little

25 bit or -- not -- thank you.

Page 10487

1 Okay. If you could please, sir, tell us your name.

2 A. My name is Petar Salapura.

3 Q. And could you please tell us your last name letter by letter.

4 A. S-a-l-a-p-u-r-a.

5 Q. Thank you, Mr. Salapura. Now, I want to get right into the

6 subject matter. So in July 1995 were you a member of the VRS?

7 A. I was.

8 Q. Could you please tell us what position you held.

9 A. Head of administration for intelligence.

10 Q. Thank you. Now, could you please tell us a little bit about that

11 position that you held. What did it entail?

12 A. That position involved work on the organisation and gathering of

13 intelligence within the Army of Republika Srpska on the enemy and only

14 that.

15 Q. All right. Now, as part of your position, did you have a large

16 staff working for you?

17 A. No.

18 Q. All right. You indicated that you were in the Main Staff. Is

19 that correct?

20 A. Correct.

21 Q. Could you please tell us who was your immediate superior.

22 A. My immediate superior was the chief of sector, and at the same

23 time assistant commander for intelligence and security Major General

24 Zdravko Tolimir.

25 Q. Just so we're clear here because you said he was the assistant

Page 10488

1 commander for security and intelligence, would Mr. -- would

2 General Tolimir also be the immediate superior officer for Colonel Beara?

3 A. Yes.

4 Q. And above General Tolimir, what was the next level?

5 A. Commander of the Main Staff.

6 Q. And who would be the commander back in 1995 in July?

7 A. General Ratko Mladic.

8 Q. All right. Now, were you engaged in the activities surrounding

9 Srebrenica? And I'm speaking of a period sometime from July 6th to

10 the -- July 11th when Srebrenica fell.

11 A. No. In late June, between the 20th and the 25th, I went to

12 Banja Luka for treatment. I was on sick leave, and I was supposed to stay

13 there for a month. And after my recovery, I was supposed to work on the

14 coordination and focal gathering of information concerning preparations

15 for the attack on the Republic of Serbian Krajina. I was not aware of our

16 activities before I learned about them in the media as far as our side is

17 concerned. I arrived on that territory on the 13th, but I was not engaged

18 in any related tasks.

19 Q. All right. Now, let me stop you here for a second. How long had

20 you been on sick leave, from what period?

21 A. Well, I cannot tell you exactly when it was now. It was somewhere

22 between the 20th and the 25th. I was supposed to be away for a month with

23 the approval of my superior, General Tolimir. However, in view of the

24 tasks that I was assigned and certain information that I was supposed to

25 receive on the 12th of July in Belgrade, I cut my sick leave short and

Page 10489

1 went to Belgrade.

2 Q. All right. And very briefly, could you tell us what information

3 you were trying or you were expected to receive on the 12th of July in

4 Belgrade, with respect to which area, which location.

5 A. That information regarded preparations that were going on on the

6 part of the Croatian army for an attack on the Republic of Serbian

7 Krajina.

8 Q. And did you get that information when you went to Belgrade on the

9 12th?

10 A. Yes, including the exact date of the attack, the force of the

11 attack, and the axis.

12 Q. And just so we don't go into it in great detail, the information

13 that you received did that prove to be accurate or correct?

14 A. Yes, only the date of commencement was shifted by two or three

15 days in relation to the date that I received.

16 Q. Now, in light of getting this information from your contact person

17 that you met in Belgrade, what did you do?

18 A. Acting from Bijeljina, I tried to get General Tolimir on the

19 phone; however, I didn't succeed. I wanted to give him a brief summary of

20 that information on the phone. Then I tried to contact General Mladic,

21 but I was told from the Main Staff that they do not have direct contact

22 with him either because he was in the area of Srebrenica. That was on the

23 12th, in the evening. I tried again early the next morning, the morning

24 of the 13th, but since I didn't succeed and the information that I had was

25 very urgent and important, I decided not to go on to Banja Luka but to go

Page 10490

1 to Han Pijesak instead and look for either General Mladic or

2 General Tolimir and advise him of the details of the forthcoming action in

3 that area.

4 Q. All right. And let me stop you here and just to clarify one point

5 before we go on, your contact in Belgrade, was he from Belgrade? Was this

6 a Serbian contact?

7 MR. McCLOSKEY: Objection --


9 MR. McCLOSKEY: To foundation. All the talk of contact has only

10 been from the questions that Mr. Karnavas is asking. If the witness could

11 explain if there is a contact at all. The way the questions are coming

12 out Mr. Karnavas is providing the information in a leading way. I know

13 he's probably just trying to facilitate it. But "contact in Belgrade"

14 would be best coming out of the mouth of the witness.

15 MR. KARNAVAS: I'll rephrase.

16 JUDGE LIU: Yes.


18 Q. How did you know to go to Belgrade on July 12th? Because you told

19 us you were convalescent and then you went to Belgrade on the 12th. Now

20 did you know go there, number one? What was the purpose? And number

21 three, with whom did you meet? Don't tell us the person's name but in

22 general what this person was.

23 A. I told you, I was recovering and I had problems with my spine.

24 More exactly, lumbar sciatica. I also had acute ulcer problems on the

25 large curve of my intestinal tract, that is the reason I was on sick

Page 10491

1 leave. But I was constantly in contact with people from my service and I

2 monitored the information that was available. They either brought it to

3 my home or I went to the office in Banja Luka. On the 10th or the 11th,

4 they received information about this meeting. And on the 12th in the

5 morning, I went to Belgrade to attend the meeting. That person in

6 question is a contact, a liaison who is not from Yugoslavia.

7 Q. All right. I just wanted to clarify that point. Now, you told us

8 you were trying to track down General Mladic on the 12th. And then I

9 believe you indicated on the 13th you were heading towards Han Pijesak.

10 Is that correct?

11 A. Yes, in the morning.

12 Q. In the morning. And you were -- if I remember correctly, you were

13 in Bijeljina at the time that you were placing these phone calls or trying

14 to make these contacts?

15 A. Yes.

16 Q. So if you could please tell us what you did on that particular

17 day, the 13th, step by step.

18 A. I arrived from Banja Luka, together with two other officers,

19 information specialists, software specialists who were supposed to work on

20 various programmes in Han Pijesak. They were supposed to take another

21 car. But since I was unable to find either General Tolimir or

22 General Mladic on the phone, I decided to go and find them in person. I

23 cannot tell you exactly what time it was when we arrived. It's -- it was

24 a long time ago. But we arrived in Konjevic Polje, more precisely,

25 Kasaba. And there I stopped by the command of the Protection Regiment - I

Page 10492

1 believe it was the military police battalion - to see one of the officers

2 and find out how I can get in touch with either General Mladic or

3 General Tolimir, because I thought the military police should know. They

4 explained to me that Tolimir was somewhere in the area of Zepa, while

5 General Mladic was in Bratunac.

6 Q. All right. Let me stop you here for a second, just so we can

7 orient everybody here where Kasaba is. From Bijeljina, as you would

8 travel, you would be heading towards Zvornik. Correct?

9 A. Yes.

10 Q. Then the next location after Zvornik would be the intersection of

11 Konjevic Polje? And then if you were to take a left on the road, that

12 would take you towards Bratunac, but if you went straight --

13 A. Yes.

14 Q. But if you went straight --

15 A. Vlasenica.

16 Q. And then you were on your way towards Vlasenica when you stopped

17 in Kasaba. Is that correct?

18 A. Yes.

19 Q. All right.

20 A. In Kasaba, correct.

21 Q. All right. Now, do you recall who it was exactly that you met in

22 Kasaba when you got this information that General Mladic was I believe you

23 said in Bratunac or Srebrenica -- Bratunac you said.

24 A. I cannot recall precisely whether it was the duty operations

25 officer or somebody else's, well, a commander or somebody, those are

Page 10493

1 details.

2 Q. Now, do you recall the approximate time when you would have

3 reached that location?

4 A. I can't tell you the time exactly. I attempted to get him on the

5 phone at 7.00, the time it took to get ready. It could have been 9.00,

6 maybe 10.00, 11.00, that range.

7 Q. All right. Now, let me show you what is marked as D197 for

8 identification, 197/1. And perhaps we can put the -- do we have one for

9 the ELMO? We do, yes. You may want to keep your glasses handy, because

10 I'm going to be going through some documents with you.

11 Now, this is a document provided to us by the Office of the

12 Prosecution, and this is purported to be an intercept and it has your name

13 there. Do you see it?

14 A. Yes, I can see that.

15 Q. And it also makes reference to a Major Malinic, the commander of

16 the 65th Protective Motorised Regiment Armoured Battalion. Do you see

17 that?

18 A. Yes.

19 Q. Now, first of all do you know -- what are we talking about when it

20 says here the 65th Protective Motorised Regiment? What is that?

21 A. That is the protective regiment of the Main Staff.

22 Q. Are they like military police for the Main Staff?

23 A. They had within their structure a battalion of the military police

24 and some other units, whether it was an armoured battalion --

25 Q. All right. But nonetheless --

Page 10494

1 A. -- or something else. But anyway, these are units providing

2 protection and security for the Main Staff.

3 Q. All right. And would it be fair to say that this is a Main Staff

4 asset? It belongs to the Main Staff?

5 A. Yes.

6 Q. Could you please tell us under which unit, which sector, was the

7 65th Protective Motorised Regiment.

8 A. It was a unit directly under the Main Staff under the command of

9 the chief of staff. It had its peculiarities, because the battalion of

10 the military police is under the command of a commander.

11 Q. All right. Did you know Major Malinic?

12 A. Yes.

13 Q. Now, it says here according to this intercept that it's 13 July at

14 approximately 10.15 in the morning. Would that be about the time that you

15 were at that area?

16 A. Maybe.

17 Q. All right. Do you recall whether you saw on that particular day

18 when you were at Kasaba, Major Malinic?

19 A. Whether it was Malinic or some other officer, I could not tell you

20 with any degree of certainty, no.

21 Q. And it says here. It says: "Pero Salapura," Pero is not your

22 first name is, is it?

23 A. Yes, Petar, but they call me Pero.

24 Q. And it says: "VRS security service," but that's not correct, is

25 it?

Page 10495

1 A. That's not correct.

2 Q. All right. Now, it also states here that there were some

3 prisoners that were at the football field in Kasaba, about 500 of them.

4 Do you recall whether you noticed them when you stopped there on that

5 particular morning?

6 A. Whether it was the football pitch in Kasaba or Konjevic Polje, I

7 don't know. It's on the right when you go from Zvornik along the road,

8 but that's not where I stopped. I went straight to the command. Yes,

9 there were prisoners there, quite a lot. I don't know the exact number.

10 Q. Do you know what they were doing there?

11 A. Nothing. They were sitting. They were gathered there. Guards

12 were around them. Our soldiers were standing guard. Some of them were

13 standing, others were sitting.

14 Q. Do you know who was in charge of those particular prisoners, at

15 that particular location, on that particular day?

16 A. No.

17 Q. Could you please tell us how long you were in Kasaba or in that

18 area.

19 A. I cannot tell you exactly, but not long. Just the time it took

20 for me to get that information. So much time has elapsed, I cannot give

21 you the exact time.

22 Q. All right. Well, once you received that information, what did you

23 do next?

24 A. I returned to Bratunac and then -- sorry, there at the brigade

25 command I looked for General Mladic, and I was told he was in Srebrenica.

Page 10496

1 So I went to Srebrenica.

2 Q. All right. Now, it says you returned, you actually turned

3 back -- went backwards?

4 A. Yes. I went back to the turn-off for Bratunac.

5 Q. Now, did you at any point in time locate General Mladic?

6 A. Yes, in Srebrenica, when I got there. I don't know whether it was

7 soldiers or policemen, some troops told me he was in the building of the

8 town hall or somewhere where he was giving an interview. There were some

9 TV crews and a group of officers around.

10 Q. All right. Now, in order to get to Srebrenica you would have to

11 go -- at least one way would be through Potocari. Is that correct?

12 A. Yes, yes.

13 Q. Did you go to Potocari or through Potocari on that particular day?

14 A. Yes.

15 Q. Did you stop in Potocari at all?

16 A. No.

17 Q. Well, where was it that you learned that General Mladic was in

18 Srebrenica as opposed to Potocari?

19 A. In Bratunac I was told he was in Srebrenica. I passed through

20 Potocari and went on to Srebrenica.

21 Q. Now, when you passed through Potocari, did you at any point in

22 time see Colonel Jankovic?

23 A. No. At that time I didn't even know he was there.

24 Q. But you know Colonel Jankovic?

25 A. Yes, yes.

Page 10497

1 Q. And I'm going to reserve that topic for later on. We'll get to

2 Colonel Jankovic. But now let's stay with Mladic in Srebrenica. Do you

3 recall about what time it was when you got to Srebrenica?

4 A. I don't know. It's difficult to determine now how long the road

5 to -- I believe I didn't stay very long in Bratunac. And I left the two

6 officers who had come with me there to have lunch. I don't know how long

7 it took. It could have been until noon. It's really very difficult to

8 give you the exact time.

9 Q. And I take it when you got to Srebrenica you found General Mladic?

10 A. Yes.

11 Q. Did you speak with General Mladic?

12 A. He was giving an interview. I came close at a distance of several

13 metres from where he was standing. He noticed me and he gave me a sign

14 with his hand to stop right there and wait. I'm not sure how much longer

15 it took. He came up to me and we greeted each other. He asked me what I

16 was doing there. I started to tell him about how the preparations were

17 going, the time frame, and the Croatian forces that were preparing for an

18 attack against the Republika Srpska Krajina. He told me to cut the story

19 short by interrupting me all the time by says: "And? Yes, yes. And?"

20 So I proposed as for that replacement, the marginal involvement of

21 the Main Staff in that territory to be terminated as soon as possible and

22 that I should get involved with the preparations and planning of the

23 activities to be undertaken by the Army of Republika Srpska in the western

24 section, defensive actions. There was a possibility that as many as 30

25 kilometres of totally undefended front line could open up there. He was

Page 10498

1 probably still enthusiastic from the success of that operation and from

2 talking to the journalists.

3 My report was a bit of an embarrassment, to put it that way. He

4 raised his voice and he shouted at me. He said that what I was saying was

5 not true, something along these lines, that I was exaggerating, that I was

6 a doom merchant, and that it was not for me to propose what should be

7 done, that he would be the one to call that particular shot, that sort of

8 thing. I was probably a little angry on account of his reaction. I was

9 still quite ill, after all. So I said goodbye to him and I turned back.

10 I went back to the car and drove back to Han Pijesak.

11 Q. All right. Let me stop you here and let me clear up a point. A

12 little bit earlier, I'm not clear, were you to get involved or was

13 somebody else to get involved in the preparation, in setting up the

14 defensive line of this territory where you said it was some 30 kilometres

15 that was undefended?

16 A. That's the western part of Republika Srpska, the line towards the

17 Republic of Serbia and Krajina, not 30, 300. The Main Staff and the

18 commander based on all this information were to carry out a swift

19 assessment and take a decision as to what should be done.

20 Q. All right. Now --

21 A. Because there was very little time left.

22 Q. Okay. Just -- if we could just fast-forward a little bit in time.

23 Could you please tell us whether this -- these activities occurred, and if

24 so what were the results of those activities that you had learned, that

25 is, the attack that was about to ensue from that area?

Page 10499

1 A. Yes, the operations took place in early August. The Army of the

2 Republic of Srpska Krajina, to the best of my recollection, very soon,

3 three days later, started their withdrawal. We were ill-prepared and we

4 started late to transfer our forces into that section. So that's what

5 happened. Large sections of the front remained undefended. Units were

6 gathered or parts of units were gathered from different formations. And

7 very soon, the front line started breaking up. Therefore, the whole

8 western section of Republika Srpska was at risk.

9 Q. All right. Now, you said you went back to Han Pijesak. Could you

10 please tell us whether you stopped anywhere from Srebrenica to Han Pijesak

11 on that particular day, and I believe we're speaking of the 13th of July,

12 1995.

13 A. No.

14 Q. Could you please tell us about what time it would have been when

15 you arrived in Han Pijesak.

16 A. I don't know. It was sometime in the afternoon. It's difficult

17 for me to say now what time exactly.

18 Q. Would you please tell us why you went to Han Pijesak. What's

19 there?

20 A. I had those two officers with me, the IT experts who were supposed

21 to install a unique programme for the benefit of the administration, the

22 centre itself and all its institutions. I was supposed to leave them

23 there and return immediately to Banja Luka.

24 Q. Why were you to return to Banja Luka?

25 A. I was supposed to get on with my treatment and continue to monitor

Page 10500

1 these activities in as far as that was possible. But the journey had been

2 quite long and I was on painkillers, so I was suffering severe pain and I

3 stayed there and spent the night there in Han Pijesak. I couldn't

4 continue the journey immediately on account of the pain that I was

5 suffering.

6 Q. And that would have been the night of the 13th of July, 1995?

7 A. 13th, yes. The 13th and the 14th.

8 Q. And that's where the Main Staff is, correct, Han Pijesak? The

9 headquarters of the Main Staff?

10 A. Yes. That is where the headquarters were.

11 Q. Where did you stay in Han Pijesak? Did you have any quarters

12 yourself, sleeping quarters?

13 A. Yes, I had a room, a small room, to sleep in.

14 Q. Now, when did you leave Han Pijesak to go to Banja Luka?

15 A. I'm sorry. I afraid I didn't understand.

16 Q. You indicated you spent the night in Han Pijesak and you had

17 planned to go to Banja Luka. Could you please tell us when. Was it the

18 next day? Did you stay more days in Han Pijesak? When did you return to

19 Banja Luka?

20 A. The next day I was to return immediately, first thing in the

21 morning. However, the duty officer or the duty operations officer,

22 whoever, informed me that the road had been closed for all traffic moving

23 from Vlasenica to Zvornik. One of my assistants knew about that. He had

24 received the message, and he informed me that I could not travel, that I

25 had to stay until further notice, stay put where I was.

Page 10501

1 Q. All right. Now, you can just sit back and relax. You don't have

2 to lean forward to speak into the mike. It picks it up, so just relax,

3 from where you are.

4 All right. Now, why was the road closed again?

5 A. I don't know that. I didn't know it then, because no other reason

6 was given, no explanation. Probably there were units being moved about or

7 prisoners of war being moved about. There was probably some kind of

8 activity underway, some kind of activity I suppose. I didn't see any

9 reason.

10 Q. All right. And could you tell us how long did you have to wait

11 there in Han Pijesak before you could leave.

12 A. I can't be sure about the date, whether it was the 17th, the day

13 we received information that the road was now again open for traffic. I'm

14 not sure if it was the 16th, the 17th, possibly the 18th. I came back on

15 the 18th. That much I can say.

16 Q. All right. So if -- just to make sure that I'm clear. From the

17 evening of the 13th to about some time in the 18th, you were in

18 Han Pijesak?

19 A. Yes.

20 Q. All right. Now, I want to go back to the 13th. When you got to

21 Han Pijesak and you stayed there that night, the night of the 13th, the

22 same night that you had returned from seeing Mladic in Srebrenica, do you

23 recall whether you saw any high-ranking officers, higher-echelon officers,

24 on that evening? Did you come into contact or see anyone?

25 A. No. I don't think there was anyone up there, with the exception

Page 10502

1 of General Miletic, as far as higher-echelon officers were concerned. As

2 for my own administration, there was a major and there was an ensign, a

3 junior lieutenant. And what I was told was what the situation was like,

4 that some people were on leave, that some people were up and about

5 carrying out assignments. There were very few officers there at the

6 command post.

7 Q. During that period of time, did you have any contact with

8 General Mladic?

9 A. No.

10 Q. Did you see General Mladic? Did you see him walking about?

11 A. No, not after that.

12 Q. All right.

13 A. Not after that. I don't know that he had arrived from that

14 section. If he was there, he was probably sleeping in a different place,

15 about 200 metres further into the forest.

16 Q. Now, General Miletic, what was his position within the Main Staff?

17 A. He was the chief of operations.

18 Q. Did you have any conversation with General Miletic to find out

19 what was going on?

20 A. No.

21 Q. All right. Now, you indicated that General Tolimir who was your

22 immediate superior officer was in Zepa or that's what you had heard. Did

23 you see him at any point in time from the 13th in the 18th?

24 A. No, I didn't see him. I failed -- I tried, but I failed to get

25 through to him on the phone. There were no phone lines that were open to

Page 10503

1 him. It was only he who picked up the phone himself. But during that

2 period of time, he never did. I kept looking for him, because I was

3 angry. I was angry that people had been involved in other assignments.

4 One of our analysts was even allowed to go on leave during a time at which

5 we faced so many difficulties.

6 Q. All right. Did you see Colonel Beara during those days?

7 A. No.

8 Q. Did --

9 A. He wasn't up there either.

10 Q. All right. Well, since we're on with Colonel Beara, you're

11 intelligence; he's security. Did your two sectors interact, exchange

12 information, work together?

13 A. As for exchanging information, we did that. His section was

14 sending information on to my section, because they had more men. They

15 were a strong unit, section, and we were just a very small section of the

16 staff. And they kept receiving much more intelligence than we did. My

17 section did not have the information that they had, because we were not

18 authorised to deal with that sort of information. Therefore, it was

19 precious little that we could give them. Our relations were regular.

20 General Tolimir coordinated all these relations, and everything went

21 through him.

22 Q. All right. Now, there's been some testimony here with respect to

23 how the security organ functioned. In particular, that - just to give an

24 example - with respect to the mail, that the commanders of the brigades,

25 for instance, could not open up the mail of the security officers, could

Page 10504

1 not read the mail, and that the security officers could directly report on

2 certain matters, especially if it was counter-intelligence, directly to

3 their higher echelon. Did the intelligence organ operate in the same

4 fashion?

5 A. No. The intelligence organ received information and sent it on to

6 the chief of staff and the commander directly. It did not have the same

7 level of protection, and this wasn't the kind of information that would be

8 gathered in the same way as with the security service. The intelligence

9 organ is attached to the staff. At its lower levels, it was subordinate

10 to the chief of staff, and at the staff level through the sector directly

11 to the commander. The commander ran the security organ directly.

12 Q. All right. The commander -- now, you're saying the commander at

13 the brigade level ran the security organ or the commander at the Main

14 Staff level? Are we speaking about security or are we speaking about

15 intelligence?

16 A. You asked me about both, so I provided both answers. Intelligence

17 is related to the chief of staff. In principle, whichever bodies had an

18 intelligence organ, an intelligence body, and the security service would

19 be related to the commander. And that's the overall command structure.

20 At the level of the Main Staff, there was a separate sector where both

21 services were closely tied to the sector chiefs, in addition to which the

22 security service had a direct link with the commander.

23 Q. All right. Now, during that -- those days, I just want to make

24 sure that we have a clear understanding, the 13th -- the evening of the

25 13th, the 14th, the 15th, the 16th, the 17th, all the way up to the 18th,

Page 10505

1 did you have any contact with Mladic or Beara or anyone else while you

2 were in Han Pijesak?

3 A. No. I did have contact probably with the officers who were over

4 there. I don't know exactly. I believe only General Miletic was there.

5 I don't seem to remember that there was anyone else.

6 Q. Did you at any point in time get involved with any of the

7 activities after the fall of Srebrenica? And I'm talking about the 12th,

8 the 13th, the 14th, anything dealing with the prisoners or men that were

9 separated in Potocari?

10 A. No. I didn't and the body that I was in charge of didn't either,

11 because that was not part of our remit, certainly not.

12 Q. All right.

13 A. Nor did we have the necessary resources or forces or manpower. It

14 simply wasn't within our remit. Our job was the other side, from the

15 beginning to the very end of operations.

16 Q. All right. Well, I want to show you a document that has been

17 marked as P507. It has already been admitted I'm told. P507. It's a

18 notation. If you could please look at that. It says here: "14th July,

19 Jokic."

20 And underneath it, it says: "Colonel Salapura called - Drago and

21 Beara are to report to Golic."

22 All right. Do you see that, sir?

23 A. Yes.

24 Q. Okay. Now, Drago, do you know who they're talking about in this

25 particular -- do you know who might this person be, Drago?

Page 10506

1 A. I don't know and I can't remember what the whole thing is about,

2 what the purpose is. Beara, Golic -- Golic was a major, Beara was a

3 colonel and these two, I don't know. I can't remember what the whole

4 thing was about or what the reason was behind it. This tells me nothing

5 about it.

6 Q. Let's take it one step at a time. First I wanted to identify the

7 people. Do you know who Drago is? Do you know who they might be

8 referring to; yes, no, or maybe?

9 A. No, no.

10 Q. Beara, we're clear on him. Right?

11 A. Yes, I know that.

12 Q. Now, Golic, do you know who Golic is?

13 A. I do. This is Golic, he was the assistant for intelligence with

14 the command of the Drina Corps.

15 Q. Okay. So he would have been in your sector, but at the corps

16 level?

17 A. Precisely.

18 Q. All right. Now, you briefly touched on it and I was going to ask:

19 Do you have any idea of what this is referring to? After all, it

20 says -- has your name that you called. And then it says: "Drago and

21 Beara are to report to Golic."

22 In other words, these two individuals, one of who is a colonel in

23 the security sector of the Main Staff, are to report to Golic of the

24 intelligence sector within the Drina Corps. Do you know anything about

25 that?

Page 10507

1 A. No, no. I can't venture a guess. I don't see any inherent logic

2 in it. That's what it says, but I don't know what the reason is. I don't

3 think I can comment on this.

4 Q. Well, please tell us why you don't see the inherent logic, so at

5 least we can follow that.

6 A. I don't see what I was to convey at the time or what the whole

7 thing was about. I may have happened to be on the phone at the time. I

8 had spent some time there, but I was in bed most of the time. I may have

9 been at the room at this particular point in time. Maybe there was a

10 message that was to be conveyed, but who from and who was the recipient?

11 I can't make it out. I don't see any logic in it. Officially, if you

12 look at the official channels, it just doesn't make sense. And I can't

13 see any specific task as such. I can't link it up.

14 Q. All right. But because we're not in the military and we're --

15 A. It's possible that I did convey someone's orders but I really

16 don't know now and I don't think I can comment on this.

17 Q. Just if you hear me out for one second, we're not in the military

18 and we're trying to follow this and why it doesn't have any logical sense

19 to you. Based on your last answer you said: "Officially, if you look at

20 the official channels, it just doesn't make sense."

21 What do you mean by that?

22 A. Yes. I mean, these are two different services. Here you have a

23 major and here you have a colonel. But as I said, I don't know what this

24 is about. It's very difficult to think back and remember now. It's been

25 nine years after all.

Page 10508

1 Q. All right. Thank you.

2 A. It was written down in a journal, but by hand.

3 Q. Do you recognise the handwriting?

4 A. No. I'm not sure which journal this is an excerpt from. I'm sure

5 that it's not my handwriting.

6 Q. All right. Now, very briefly I told you earlier that we were

7 going to discuss Colonel Jankovic. Perhaps you can tell us who he was at

8 that time that is, because I understand he's still with us, that is, in

9 the physical sense.

10 A. Colonel Jankovic was an analyst with the intelligence

11 administration of the Main Staff.

12 Q. And could you please tell us as an analyst with the intelligence

13 administration of the Main Staff what his functions were. And again, you

14 don't have to lean forward. Just from there where you're sitting you can

15 tell us, nice and gently.

16 A. Well, I think he worked on processing and analysing information,

17 monitoring the situation with regard to HVO units, Croatian Defence

18 Council and Croatian army.

19 Q. Was he a commander in any sense of the word?

20 A. No. He was an analyst. He couldn't give orders to anyone, not

21 even to himself, in the military sense of course.

22 Q. But he was a colonel?

23 A. Yes.

24 Q. All right. But I mean, we all had this impression that colonels

25 go around commanding and issuing orders.

Page 10509

1 A. No. He was with the intelligence administration. He had no

2 subordinates. And we were fully staffed. I believe he was to have

3 another three or four assistants, but he didn't have any. He was working

4 by himself.

5 Q. All right. So was he working by himself, is that what you're

6 telling us, without a staff, analysing?

7 A. No. No, he was subordinated to himself or to no one.

8 Q. Who did he report to?

9 A. He wrote briefs, reports, the results of his analysis that he

10 submitted to the head of section for analysis, Karanovic, and to me when I

11 was around.

12 Q. Now just to make sure because I see we may need to make a

13 correction, were you fully staffed or not fully staffed? Which of the

14 two?

15 A. What did you say? Did I have what?

16 Q. Okay. Just check -- relax for a second. In my previous --

17 previously, it says here on the record that you were "fully staffed," you

18 being the intelligence unit. And I want to make sure whether that's what

19 your answer was. Was it that you were fully staffed, your intelligence

20 unit, where Jankovic was working?

21 A. No, no. We had less than 20 per cent.

22 Q. Okay. I just wanted to correct that.

23 Now, when we --

24 MR. KARNAVAS: I think this might be a good time for us to take a

25 break, Your Honour, because when we get back I would like to discuss what

Page 10510

1 Colonel Jankovic was doing -- oh, I'm told I've discombobulated this new

2 environment. Since we have all this time, as I was saying.

3 Q. If you could tell us, first of all, we know that Colonel Jankovic

4 was in Bratunac sometime in early July. Could you please tell us who

5 issued him that order to go there?

6 A. When I arrived at the command post on the 13th, I was informed by

7 Major Malinic, I think he was the man who made the report, that

8 Colonel Jankovic had been designated and sent to the command of the

9 Knin Corps [as interpreted] as liaison officer for UNPROFOR troops, or

10 rather, the UNPROFOR base in Potocari.

11 Q. Which corps was he sent to?

12 A. Drina Corps.

13 Q. All right. Okay. I was worried there.

14 Now, who was his immediate superior officer, Jankovic's, normal?

15 A. Well, at that time when I was not around, it was General Tolimir.

16 Q. Okay. But listen to my question, then we'll -- I'll take you

17 back. Who was normally Colonel Jankovic's immediate supervisor? Who did

18 he answer to?

19 A. Karanovic, Lieutenant Colonel Karanovic.

20 Q. So a colonel was reporting to a lieutenant colonel?

21 A. Yes.

22 Q. And in which sector was this Mr. -- Lieutenant Colonel Karanovic?

23 A. Head of section for analysis.

24 Q. Okay. And who did this Karanovic report to?

25 A. To me.

Page 10511

1 Q. All right. Now, you've -- concretely speaking, did you order

2 Jankovic, Colonel Jankovic, to go to Bratunac?

3 A. No, because I wasn't even there when he left. I was in

4 Banja Luka.

5 Q. When he did -- when the issue -- when the order was issued to

6 Colonel Jankovic, were you informed of that order?

7 A. No, I was in Banja Luka. It was General Tolimir who was in

8 command, who organised the work as head of sector in my absence. They did

9 not need to inform me.

10 Q. All right. Do you know then who was the individual, who was the

11 officer, that ordered Colonel Jankovic to go to Bratunac and be

12 subordinated to the Drina Corps or attached? However -- whatever the

13 precise terminology is.

14 A. Well, I don't know.

15 Q. Who could have possibly -- given the universe of choices, who

16 could have possibly issued that order to Colonel Jankovic, in light of his

17 position and in light of where he was serving?

18 A. General Tolimir, or the commander of the Main Staff in person.

19 Q. All right. Now, did you ever learn what Colonel Jankovic was

20 doing in Bratunac at the time? Or let me put it this way: Who he was

21 supposed to be doing when he first arrived? We'll take it step by step.

22 A. Yes. I was told when I arrived, because he was not around, that

23 he had been designated to be the liaison officer with the UNPROFOR in

24 Potocari.

25 Q. Why would they need someone like him? Because as I understand it

Page 10512

1 they already had Captain Momir Nikolic in Bratunac; why would they need

2 Colonel Jankovic to come from Han Pijesak?

3 A. I don't know where Momir Nikolic was at that time. And I don't

4 know -- I'm not aware anyway that Momir Nikolic was the liaison officer.

5 Jankovic was in our forces the only officer who had a good command of the

6 English language, and that must have been the reason.

7 Q. All right. Now, did you ever learn whether his portfolio, if I

8 could use that term, was expanded so he would have commanding powers while

9 he was in Bratunac? In other words, did anyone make him a commander so

10 that he could issue orders to command others below him, such as, for

11 instance, Momir Nikolic, to just pick an example?

12 A. No, I don't see why he would be. He was an analyst and he was

13 designated to be the liaison officer. I don't see why.

14 Q. All right. Now, after the events in Srebrenica, did you ever have

15 an opportunity to speak with Colonel Jankovic and find out what exactly

16 happened while he was there, Bratunac, Potocari, during those days?

17 A. I spoke to Colonel Jankovic, but only later when I saw him in

18 Banja Luka after the Croatian offensive had already started. And then

19 everybody from Han Pijesak came to Banja Luka. But I didn't speak to him

20 at that time. At that time, we were pre-occupied with much more urgent

21 problems and all the rest was forgotten.

22 Q. Were the problems you were speaking about with regard to the

23 information you had received on the 12th of July of the ensuing attack?

24 A. Yes.

25 Q. All right. But would it have been normal - I don't know, maybe

Page 10513

1 you can help us out here - for Colonel Jankovic to make some sort of a

2 report or give you some sort of an update as to what he was doing in your

3 absence when he was subordinated to the Drina Corps?

4 MR. McCLOSKEY: Objection.


6 MR. McCLOSKEY: There's lots of assumptions in these leading

7 questions, that this person is subordinated and other issues that are

8 really Mr. Karnavas's developments and not the witness's.


10 MR. KARNAVAS: Your Honours --

11 JUDGE LIU: You have asked a lot of --

12 MR. McCLOSKEY: "The ensuing attack." I don't think there was an

13 ensuing attack at that time. Perhaps you could ask the date of the attack

14 and we could get down to business.

15 MR. KARNAVAS: The attack was coming and we know that it came, and

16 it's a fact, he testified to it. He indicated that he was sent down to

17 the corps. In the spirit of cooperation, I'll go about it in another way,

18 Your Honour.

19 Q. And perhaps I could show you a document at this point in time and

20 we'll touch upon this very issue. If I could show you what is

21 Exhibit D164, a document provided to us by the Office of the Prosecution.

22 We're not going to discuss it in detail; I just first want you to look at

23 it. And you see it has a date on top of it, 13 July 1995.

24 Do you see that, sir, the top, the date?

25 A. Yes, yes.

Page 10514

1 Q. And at the bottom on the right-hand it says: "14 July 1995,

2 0030."

3 So that would be 30 minutes into July 14th. Do you see that, sir?

4 You need to answer so we can make a record.

5 A. Yes, yes.

6 Q. Okay. All right. Now, just a couple more questions. And we're

7 talking about the same Jankovic, Colonel Jankovic. Right? This was his

8 first name, was it not?

9 A. Yeah.

10 Q. Okay. Well, getting closer -- now, could you please tell us,

11 Colonel Jankovic of the Main Staff security sector, to whom is he

12 addressing this report?

13 A. We see from this that this report is addressed to the sector of

14 the Main Staff, namely to General Tolimir, and the command of the

15 Drina Corps, the intelligence section.

16 Q. Okay. And so this -- and underneath we see it says here

17 specifically: "To: Command of the Drina Corps intelligence department."

18 Do you see that?

19 A. Yes, yes.

20 Q. Well, why would he be making this report to the command of the

21 Drina Corps intelligence department?

22 A. To the command of the Drina Corps, section for intelligence. They

23 settled it within the Drina Corps. I don't know who decided, the

24 commander or somebody else decided how the communication would go to the

25 base. I don't want to make any comments, but when he arrived the order

Page 10515

1 was that all the information should be sent through the intelligence

2 section.

3 Q. All right. And to your knowledge at this point in time, was

4 Colonel Jankovic working on behalf of the Main Staff in Bratunac, the

5 Drina Corps, the Bratunac Brigade, or some other brigade?

6 MR. McCLOSKEY: Your Honour, objection to the form of the

7 question.


9 MR. McCLOSKEY: You're working for all those units when you're

10 working in the army, so without some specificity, it doesn't make sense.

11 JUDGE LIU: Well, Mr. Karnavas, the full series of questions may

12 be not proper to put to this witness, because we heard that this witness

13 was there on -- only on the 17th of July. I don't know whether he's well

14 informed about the situation.

15 MR. KARNAVAS: I'll rephrase, Your Honour -- I said -- I'll

16 rephrase.

17 Q. Did you ever learn, did there ever come a time where you learned,

18 to whom Colonel Jankovic was working for at that particular time?

19 A. I was informed, as I told you, when I arrived at the command post

20 that he had been sent to the command of the Drina Corps as liaison officer

21 with the UNPROFOR on behalf of the Drina Corps. And of course, he

22 reported, as you can see here, to the intelligence section of the command.

23 And it was up to him to decide whether it was necessary or not. What I

24 have just told you is the way it functions.

25 Q. All right.

Page 10516

1 MR. KARNAVAS: This may be a good time to take the break,

2 Your Honour.



5 Q. And I'm going to be asking you about the last paragraph when we

6 come back.

7 JUDGE LIU: Yes. We'll resume at 4.00.

8 --- Recess taken at 3.32 p.m.

9 --- On resuming at 4.02 p.m.

10 JUDGE LIU: Yes, Mr. Karnavas.

11 MR. KARNAVAS: Thank you, Mr. President, Your Honours.

12 Q. Mr. Salapura, I believe we left off with document D164. In light

13 of your position in the intelligence unit or sector, I would like you to

14 focus on the last paragraph of Colonel Jankovic where it states: "I think

15 that if we want to take over the enclaves of Zepa and Gorazde in the same

16 way, it will be necessary to present the operation in Srebrenica in the

17 media, so as to show that we had rendered adequate treatment to the

18 civilians, and even to soldiers who surrendered their weapons."

19 In light of your position and knowing Colonel Jankovic, could you

20 please give us some explanations about this particular paragraph. What

21 conclusions, if any, can you draw?

22 A. You have a postscript down here and a personal opinion attached by

23 Colonel Jankovic. At that point in time, this only seems logical, and it

24 arises out of the position that he held at the time. Looking at this from

25 the perspective of the presence of the international community as well as

Page 10517

1 the public opinion, internationally speaking, concerning the overall

2 picture in the war in Bosnia and Herzegovina, especially as regards

3 Republika Srpska and its army. This is a recommendation and a desire that

4 this unfavourable image that we enjoyed at the time be righted in a way.

5 And the whole of this communique in terms of its contents speaks for

6 itself and speaks with sufficient clarity as to what his tasks were and

7 the problems that he encountered. It was about simple coordination

8 liaising between the UNPROFOR forces and the corps command and here you

9 have his personal view, representing an attempt to perhaps help in a way.

10 Q. Had you seen such opinions expressed in the past in the sense

11 that, for instance, someone like Colonel Jankovic would give a report and

12 then attach as well his personal opinion?

13 A. In our organ we used to do this, because our job was of a peculiar

14 nature in relation to the other staff organs as well as his own. Because

15 our job was to deal with the enemy and the environment. Everything that

16 was outside the territory under the control of Republika Srpska.

17 Obviously we were interested in gathering information and we were

18 interested in how the world saw the entire situation. This was frequently

19 the case, namely, that analysts made proposals or submitted reports

20 containing proposals and recommendations which were sent by the

21 administration to other institutions.

22 Q. Now, we've heard testimony that right about that time

23 Colonel Beara was engaged in other activities and that the men that were

24 separated and others that were captured were ultimately killed. In

25 looking at that particular paragraph, the opinion expressed by

Page 10518

1 Colonel Jankovic, an analyst with the intelligence department of the

2 Main Staff, can you, based on looking at this, can you tell us whether you

3 can make any conclusions, draw any conclusions, as to whether at the point

4 in time when this was written Colonel Jankovic would have been aware of

5 any activities ongoing by Colonel Beara?

6 MR. McCLOSKEY: Objection. That is extremely speculative.

7 JUDGE LIU: Yes, I believe so, Mr. Karnavas.

8 MR. KARNAVAS: Well, I had to ask it, Your Honour. I couldn't

9 resist. Good objection.

10 Q. All right. Now, I want to go through some other documents

11 briefly. I'll stick with this period in time. And I first want to talk

12 to you about some information that has come to the attention of the Office

13 of the Prosecution by one of -- by someone whom they've had numerous

14 contacts with, someone by the name of Dragomir Vasic. And he has

15 indicated in one of their statements -- one of his statements, I believe

16 it's 10 June 2003, that it was on the 13th of July when Mladic ordered you

17 to kill the prisoners. And he states, and I'm quoting from page 61, he

18 states that you refused, that you went to Han Pijesak and you took a

19 medical certificate. And then he said: "They started looking for Beara."

20 So first of all, do you know this Mr. Vasic, Dragomir Vasic? Do

21 you know him personally?

22 A. No, I don't know who this person is. No, I don't remember. I

23 don't believe I know this person.

24 JUDGE LIU: Yes, Mr. McCloskey.

25 MR. McCLOSKEY: If I could just briefly interject. There is a

Page 10519

1 suggestion in that question that Mr. Vasic is somehow an agent or a

2 cooperator with the Office of the Prosecutor. And just for clarity, I

3 want to make sure that the public knows that he is a target of an

4 investigation; he is not a cooperator. People that are thought to be

5 cooperators could be in potential danger.

6 JUDGE LIU: Thank you.

7 MR. KARNAVAS: Well, first of all, I never suggested that -- I

8 really don't understand what that last part was. The gentleman has met

9 with the Prosecutor six times and has given him documents. So certainly

10 somebody's cooperating with somebody.

11 JUDGE LIU: Well, well, Mr. Karnavas, all those statements

12 concerning the relationship between that person and the Prosecution are

13 totally irrelevant to your question to this witness.

14 MR. KARNAVAS: I agree, Your Honour, but I haven't said anything.

15 JUDGE LIU: Well, I think you know -- I think I advised you many

16 times, if not absolutely necessary, do not mention the other party.

17 MR. KARNAVAS: Very well, Your Honour.

18 JUDGE LIU: I believe you could do your job much better without

19 mentioning the Prosecutor.

20 MR. KARNAVAS: All right. It's very difficult with this

21 particular statement, since it's to the Prosecutor. The Prosecutor

22 elicited this information from the gentleman. So I --

23 JUDGE LIU: You could not -- have the relationship of --

24 MR. KARNAVAS: Very well, very well.

25 Q. All right. Getting back to where we were. First of all, did this

Page 10520

1 ever occur, in other words did Mladic, General Mladic, order you on the

2 13th to kill all the prisoners as Vasic, Dragomir Vasic, told the

3 Prosecutor on 10 June 2003? Did this ever occur?

4 A. May I please add some clarifications? No, this is absolutely

5 untrue. I told you at the outset that I did have a conversation with

6 General Mladic, only a brief one. It only took several minutes. For me,

7 it was a most unpleasant conversation and I said why. The conversation

8 amounted to downgrading my own work by General Mladic. I don't think

9 General Mladic would ever have ordered something like this to me

10 personally, because my position, not only with regard to prisoners of war

11 but in a more general sense, the position which I held from the very

12 beginning of the war, was entirely in compliance with everything, as

13 Jankovic said a humane treatment and respect for all conventions. In our

14 rules of service, in our work, this is one of the key propositions, the

15 Geneva Conventions. And I don't think that any intelligence officer would

16 fail to comply with that. I do not know this person and I think this bit

17 of information is completely untrue. I'm not sure why it was provided and

18 what the intention was. It's -- it would have been absurd for me to take

19 a rifle and go and do whatever he had in mind I would have -- there were

20 other objectives there, perhaps, behind this statement. I'm not sure what

21 General Vasic's intention was when he said that. So much for that.

22 Q. Well, Vasic is not a General. Now --

23 A. Mr. Vasic, yes.

24 Q. Okay. Now, since -- let me ask you this: Has the Office of the

25 Prosecution ever contacted you? We know Srebrenica occurred back in July

Page 10521

1 1995. Today it's nine years later. We're in June 2004. Have they ever

2 contacted you, sir?

3 A. I believe it was in 2001 or 2002, team 9, I believe, if there is

4 such a team. There was a lady, an American lady. The subject matter was

5 Alija Izetbegovic and Naser Oric.

6 Q. All right. Did you speak to them?

7 A. Yes.

8 Q. How many times did they contact you?

9 A. This once and later they called me on my mobile phone, someone

10 did, but also in relation to the conflict between Muslims and Croats.

11 Q. Did anyone from the Office of the Prosecution, in light of your

12 position and in light of Colonel Jankovic's involvement or activities

13 during the events in Srebrenica, did anyone from the Office of the

14 Prosecution ever contact you to get any information?

15 A. No.

16 Q. Had they expressed an interest, would you have been willing to

17 meet with them and provide them information or talk to them as you talked

18 to team 9 who were interested in Naser Oric and the late Izetbegovic?

19 A. I noticed no interest whatsoever on their part. I certainly would

20 have been willing to talk to whoever was interested.

21 Q. All right. Now, we talked a little bit about Jankovic. Now I

22 want to talk to you about the 10th Sabotage Unit.

23 A. Yes.

24 Q. Could you please tell us to whom this asset belonged to.

25 A. The 10th Sabotage Detachment was a sabotage and reconnaissance

Page 10522

1 unit. It was an independent unit attached to the Main Staff. Like all

2 other independent units, it was directly subordinated to the commander.

3 As for its professional use, as for training and anything like that, the

4 intelligence organ would have been in charge. As for making proposals on

5 how this unit was to be used for special tasks, the proposals would also

6 be made by the intelligence organ, and then this proposal would be

7 approved or ordered by the commander himself.

8 Q. All right. And so I'm clear, would you be the person in charge of

9 the intelligence organ?

10 A. Yes. I was the chief of intelligence and administration -- I used

11 to be, that is.

12 Q. Now, the whole world by now has heard of Erdemovic. Have you

13 heard of this individual?

14 A. Yes, yes. Everyone has.

15 Q. And you've heard about his activities, his killings?

16 A. Yes.

17 Q. Could you please tell us who ordered the 10th Sabotage Detachment

18 to go to the Bratunac area during the events surrounding Srebrenica.

19 A. The 10th Sabotage Detachment, this is something that I verified

20 later, was involved in combat operations in Srebrenica. It was

21 subordinated to the command of the Drina Corps. After combat operations

22 were completed, that was only the one half. And the other half was in the

23 Modrica area. And I visited them when I was on my way to Belgrade. This

24 half was subordinated to the command of the Drina Corps when the combat

25 part of the operation was over. I'm not sure about the date, whether it

Page 10523

1 was the 9th or the 10th when the units of the Army of Republika Srpska

2 entered the town of Srebrenica itself. The corps commander issued

3 instructions that a return to the base was possible. On their way back,

4 an APC tumbled over and one soldier was killed. The detachment commander

5 was injured. I believe there were two or three soldiers that were wounded

6 in that accident. As for the rest of them, the remaining half, once they

7 had returned to base, the detachment commander granted them ten days, or

8 at least that's what they told me once I was back at the command post on

9 the 13th, he granted them ten days' leave.

10 On the evening of the 13th, I tried to get in touch with the

11 detachment commander by phone, however, he was away receiving treatment

12 for his injury. So I couldn't get through to him. But one of the

13 soldiers did tell me -- I asked them what was going on, and they told me

14 that all the soldiers were on leave apart from those providing security,

15 the few soldiers who remained back at the base. And the other half were

16 on a mission in the Modrica area.

17 Q. Let me stop you here for a second. Let me go back to my original

18 question. In very concrete fashion, just tell me if you know: Who was it

19 that ordered the 10th Detachment -- the 10th Sabotage Detachment to be

20 subordinated to the Drina Corps and go to the Srebrenica area during the

21 events concerning Srebrenica back on July 1995?

22 A. I'm not sure who exactly issued the order to the commander at the

23 time. It didn't strike me as very important. I was unable to get through

24 to General Tolimir at the time, therefore I don't know who exactly gave

25 the order, whether it was Tolimir or the commander directly, the commander

Page 10524

1 of the Main Staff, or whether it was through General Tolimir or perhaps

2 General Tolimir himself, but I can't say.

3 Q. And is that the universe of choices as to who could issue an order

4 to have this asset of the Main Staff subordinated to the Drina Corps?

5 A. If we are looking at a combat task for which this unit was not

6 meant to be used and the order on its establishment contained a clause

7 that this unit would only be used for particular special tasks, and that

8 all sort of non-special use was strictly forbidden. Therefore, the use of

9 this unit for combat operations could only have been ordered by the

10 commander of the Main Staff, since he was the one who signed the order.

11 Therefore, he was the only one who could have had the authority to change

12 it.

13 Q. Now, prior to the events of Srebrenica, which has we've indicated

14 commenced on July 6th, 1995, did you at any point in time make any

15 recommendations as to the usage of the 10th Sabotage Detachment, since as

16 I understand your testimony earlier, the head of the intelligence unit

17 would be making those recommendations for the usage of that particular

18 detachment?

19 A. Yes. On a number of different occasions, but only for

20 reconnaissance- and sabotage-related tasks. Outside that, the chief had

21 nothing to do with it.

22 Q. All right. But I'm speaking concretely for Srebrenica and that

23 period around July 1995. Did you make any recommendations for their usage

24 with respect to Srebrenica, yes or no?

25 A. No. I wasn't even there when the unit got involved in that area.

Page 10525

1 Q. All right. Now, you indicated that on the 13th you were trying to

2 get in touch with the commander who apparently was ill or injured. Who is

3 that commander?

4 A. Pelemis.

5 Q. And would this be --

6 A. Colonel, I believe.

7 Q. And would this --

8 A. Lieutenant.

9 Q. Is it lieutenant colonel or is it lieutenant or is it colonel?

10 Which of the three?

11 A. Lieutenant.

12 Q. Okay. Now, is -- was Lieutenant Pelemis the same commander that

13 authorised the ten days of leave that you had learned of?

14 A. Yes.

15 Q. And I take it all of the information -- well, let me ask

16 you -- after you heard about what had happened or Erdemovic had been

17 involved in, did you at any point in time look into those matters to see

18 what they did, under whose orders, and who exactly was involved?

19 A. Before Erdemovic surrendered and gave a statement, I had not been

20 aware of any of that, nor has anyone else been in the intelligence

21 administration. I didn't ask many questions, because later I left for

22 Banja Luka and the whole detachment was transferred there to a new zone of

23 combat operations. And I wasn't interested in that because most of them

24 were on leave at the time. There were only very few soldiers left in the

25 area. And for me, it was a very simple matter. I didn't count on them.

Page 10526

1 My intention and my plan was once they were back from leave to make a

2 proposal to the commander for the whole unit to be transferred to the zone

3 of the 2nd Krajina Corps. Therefore, I knew nothing about that nor do I

4 know anything today, who specifically issued those orders and based on

5 what. This is not an order to the detachment as such, because the

6 detachment was simply not there. There was a group of soldiers who were

7 on leave.

8 Q. All right. But if you could tell us, when would it have been that

9 you learned what Erdemovic had been involved in? How soon after the

10 events?

11 A. Only when he gave those statements, when the media started

12 covering it.

13 Q. Well, how is it, how is it, that you being the head of

14 intelligence, how is it that you didn't know what Erdemovic had been

15 involved in in the field, along with the other group of soldiers that were

16 from that 10th Sabotage Detachment?

17 A. I suppose it was one group, first of all; and second, nobody in

18 the Main Staff had ever mentioned anything about Erdemovic's arrest in my

19 hearing, nor was I ever interested in that. I never tried to find out.

20 If I had tried, I would probably have learned. Later I did try to find

21 out some information. And when I did, I found it hard to believe. And

22 investigations, by the way, are not part of my line of work. There are

23 other institutions that are competent and qualified to react.

24 Q. Well, you said that you were not interested in that. How could

25 you not be interested in the fact that someone such as Erdemovic and the

Page 10527

1 others executed these prisoners of war, if you want to call them that?

2 Certainly they were unarmed, certainly they hadn't done anything, and

3 there they were being executed. Why wouldn't you, assuming that you were

4 the person who would be issuing directives or suggestions as to how this

5 unit should be utilised, why wouldn't you take an interest in seeing what

6 they were up to or what they had been up to?

7 A. I made proposals only for those tasks that my organ was in charge

8 of, and that is scouting expeditions, reconnaissance, and intelligence

9 gathering. Second, at the moment when I found out about this from media

10 coverage, I had already submitted my request for early retirement. I had

11 been granted annual leave, and I was placed on call for six months, on

12 stand-by. Sometime in that period I visited the Main Staff as an outsider

13 this time. I was about to retire, and I wasn't really interested. And I

14 talked to another commander who had already volunteered to be retired

15 early, and I asked him whether it was true that they had really

16 participated in that action.

17 Q. Who was that commander? Who was the commander?

18 A. Pelemis.

19 Q. And what did you learn from Pelemis?

20 A. He told me that they had.

21 Q. Based on that information, did you react? Did you do something?

22 A. No. I was not able to react. It was not up to me. It was not my

23 job. The ICTY had already reacted and all the other institutions and

24 authorities had reacted. At that time, I was on stand-by, pending

25 retirement.

Page 10528

1 Q. All right. Now, incidentally, had the Office of the Prosecution

2 contacted you, would you have provided this information to them, the

3 information, that is, that you are providing to us today under oath?

4 A. Why not?

5 Q. So the answer is yes?

6 A. Yes.

7 Q. Okay. Now, I want to go through a couple of -- some other

8 documents. If I can show you what has been marked as P265 or actually has

9 come into evidence as P265. This is -- I'm showing you what is purported

10 to be an intercept conversation. If you could look at it. Do you see

11 your name in this intercept?

12 A. Yes, I see. I see that in one place and there's another one.

13 Q. All right. First of all, are you in this intercept?

14 A. Yes. I see one mention of my name. I don't know what it refers

15 to, or rather, I don't know between whom this conversation is taking

16 place.

17 Q. That's what I wanted to get at, and it was a poorly phrased

18 question. Were you one of the speakers in this intercept?

19 A. No. I'm not a collocutor here. I am -- in fact, somebody is

20 saying that some commander ordered something to me, I don't know which

21 commander, and that some order or request would be issued to me. I don't

22 know why this would be true, because I never wrote any requests or orders

23 towards state authorities. I don't know what this is about -- towards

24 MUP, rather. We always contacted only with state authorities. And there

25 is also a reference to some Kovacevic.

Page 10529

1 Q. Do you know a Mr. Kovacevic?

2 A. Kovacevic, I don't know even know which Kovacevic this is a

3 reference to. I don't know that we had a Kovacevic in our employ.

4 Q. It also mentions a Keserovic, does it not?

5 A. Keserovic, I know, I know him.

6 Q. And he was from where? Where was he from?

7 A. Keserovic was in the security administration. Whether he was a

8 clerk or something like that, in charge of military police.

9 Q. At what level was he?

10 A. I am not sure. I don't know exactly what his position was,

11 whether it was an administrative assistant, whether they had a section for

12 it or department, whether he was chief of that section.

13 Q. Was he in a corps or was he with the Main Staff? Where

14 exactly -- in which unit was he in?

15 A. At that time, I believe he was in the Main Staff.

16 Q. Okay. Now, I just want to briefly go through some other

17 documents. First, I want to show you what has been marked as D194 for

18 identifications purposes, D194/1. Could you please look at this document

19 and first tell us if you know what this document is.

20 A. This is an intelligence brief that we used to submit to the state

21 security service of Republika Srpska.

22 Q. All right. And if you look at the last -- very last page, it

23 says: "Deputy chief, Colonel Petar Salapura."

24 Would that be you?

25 A. Yes, yes.

Page 10530

1 Q. And the date of this report is 8 February 1995, is it not?

2 A. Yes.

3 Q. Now, in this particular report -- well, first of all, could you

4 please tell us how is it -- a report like this generated?

5 A. This intelligence summary was processed and written by Jankovic.

6 You can see the initials JR, JR at the bottom. He wrote it based on the

7 daily in flow of information processed by analysts, segment by segment.

8 And then a summary is made integrating all this and is submitted to corps

9 staffs and other clients, if I can call them that. This is an

10 intelligence summary that was done every day.

11 Q. All right. Now, is there anything in this particular intelligence

12 summary with respect to the Muslim army that is located in the

13 demilitarised or the supposed or supposed-to-be demilitarised zone of

14 Srebrenica, enclave of Srebrenica?

15 A. Yes.

16 Q. And could you please tell us: What is this information about?

17 A. Do you mean Srebrenica?

18 Q. Yes, that's what I'm talking about. That's the only thing I'm

19 interested in at this point in time with this document.

20 A. It speaks of the preparation of forces that were in Srebrenica for

21 an offensive scheduled for the spring. It was expected to start in May.

22 Q. All right. Thank you. We can go on to the next document. Let me

23 show you what has been marked for identification purposes as D195/1. And

24 for the ELMO, I'll be referring to page 3, the last page in the English

25 version. But first of all, what is this document, D195 for

Page 10531

1 identification?

2 A. This is also an intelligence summary of the intelligence

3 administration, that is, originating from the intelligence administration.

4 Q. All right. That would be your sector?

5 A. Yes.

6 Q. All right. Now, if we could turn to page -- well, it's 3 in the

7 English version. The third from the last paragraph. Is there any -- do

8 you see what I'm directing your attention to?

9 A. Yes, the part that you highlighted.

10 Q. Okay. Well, let me just read it here for a second and maybe

11 perhaps we can ask a question or two. It says here: "Muslim propaganda

12 is emphasising alleged VRS operations towards enclaves in the Podrinje

13 region. They have started occupying UNPROFOR checkpoints in the

14 Srebrenica area, while in the Gorazde area on the Gorazde-Ilovaca road,

15 they are using UNPROFOR vehicles to manoeuvre forces and transport

16 materiel and technical equipment, which all indicates that they are

17 preparing offensive operations from the enclaves."

18 Do you see that portion, sir?

19 A. Yes, yes.

20 Q. Now, one may think that this particular paragraph is propaganda in

21 and of itself, that is, Serbian propaganda. Would that be correct, sir?

22 JUDGE LIU: Yes.

23 MR. McCLOSKEY: Objection. That's leading.

24 MR. KARNAVAS: Well, I think the latter part of the question,

25 Your Honour, focused the gentleman in the right area. I can go about it

Page 10532

1 in a different way. I can rephrase. I can rephrase.

2 JUDGE LIU: But -- well, I don't think this document is relevant

3 to our case.

4 MR. KARNAVAS: Your Honour --

5 JUDGE LIU: It's going back far from that attack on Srebrenica.

6 MR. KARNAVAS: Yes, I understand. If -- as Your Honour may recall

7 two weeks ago or last week, they're all blending in these days, last week,

8 we had a witness who indicated that he had been receiving information

9 about an offensive from the Muslims coming from Srebrenica. Now we see

10 that we have intelligence reports here stating the same. So, one, it

11 verifies that that individual who was a combat -- he was a commander,

12 battalion commander on the ground had this sort of information or would

13 have had this sort of information. Secondly, the Prosecution has made a

14 major offensive, if I could call it that, regarding attacks on UNPROFOR

15 checkpoints. And here we see now a document being generated by the

16 intelligence office or intelligence sector of the Drina Corps which says

17 that the Muslims are, in effect, starting to occupy UNPROFOR checkpoints

18 and they're using their vehicles. So we seem to be getting some mixed

19 information, and I'm merely trying to establish that this information was

20 known at the time to those who were on the ground. So I'm trying to put

21 it in perspective.

22 JUDGE LIU: Yes, Mr. McCloskey.

23 MR. McCLOSKEY: I object to the long rambling argument. The last

24 witness could have been asked about whether or not he attacked the

25 UNPROFOR checkpoint because there was Muslims there. He was not asked

Page 10533

1 the --

2 MR. KARNAVAS: That's not the point of the document, Your Honour.

3 MR. McCLOSKEY: All these long arguments telling the witness

4 about, you know, what he's interested in, it's inappropriate, it's not

5 relevant, and the question is leading.

6 MR. KARNAVAS: Your Honour, I indicated that I was willing to

7 withdraw the earlier question and rephrase. And then I was invited to

8 give an explanation and I gave an explanation. So --

9 JUDGE LIU: Well, you may rephrase your question.

10 MR. KARNAVAS: Thank you, Your Honour.

11 Q. Now, with -- could you please tell us from looking at this

12 particular paragraph what exactly are you trying to say? Because I

13 noticed at least it has your name at the bottom, Deputy Chief,

14 Colonel Petar Salapura, so one might assume that you're competent to

15 elucidate on this matter.

16 MR. McCLOSKEY: Objection, vague. It speaks for itself. Do we

17 need to have this man repeat what he's already said? If he has some

18 specific question about what's said, I think that's appropriate. But

19 "please, elucidate on this matter," this is not a proper question.

20 JUDGE LIU: Yes, yes, I agree with the Prosecution.

21 MR. KARNAVAS: Very well. I'll ask another question.

22 Q. Was this information true or false? In other words, was it

23 created for the purpose of providing false information to the VRS army of

24 the Main Staff, the Main Staff of the VRS army? I know, it's a silly

25 question, but I've got to ask it.

Page 10534

1 A. How on earth? I don't know what to say. Whoever has been in the

2 business that we were in wants to get to the truth as much as possible.

3 The truth and the real information is our main goal. And it would have

4 been a big mistake if our organ has engaged in disinformation. This piece

5 of information we received on a number of occasions. There may be another

6 explanation, however. The enemy may have tried to plant some

7 disinformation on us; however, this particular report was later confirmed

8 because Zepa was under the same command as Srebrenica, and an attack was

9 indeed mounted against the building of the Main Staff. I believe it was

10 in the end of June. I cannot vouch for the date now.

11 Q. All right. Well, let me show you another document that we

12 received from the Office of the Prosecution. And this has been marked for

13 identification purposes as D196. Just for the sake of time and for the

14 record, it says that it's 10 June 1995.

15 Sir, is this another intelligence report from you?

16 A. Yes.

17 Q. All right. And if we could look at the second-to-last paragraph,

18 that would be on page 2 in the English version. It says here: "Muslim

19 forces in Gorazde (81st Division), in Srebrenica (28th Division) enclaves

20 have raised their combat readiness to the highest level and strengthened

21 their forces at the forward line. They are planning to carry out

22 offensive actions in order to insert troops behind our lines and among our

23 ranks."

24 This was dated 10 June 1995. Sir, to the best of your knowledge

25 was this information accurate at the time you put it into your

Page 10535

1 intelligence information?

2 A. I believe it was true, it was accurate, otherwise it wouldn't be

3 featuring here. That was the information that was available to us. I

4 cannot tell you where it had come from. It was a long time and I don't

5 have the original primary documents, but it must have come from more than

6 one source. Because what you find in this report is in the form of an

7 assertion, concerning planning and intent, so it must have been accurate

8 information.

9 Q. All right. Now, could you please tell us when you left or retired

10 from the JNA.

11 A. I cannot give you the date now. I don't have my papers with me,

12 but it was in 1996. I cannot be more precise, but I left on my own

13 initiative, on my own request, a request for early retirement.

14 JUDGE LIU: Yes --

15 MR. McCLOSKEY: A small correction. I know it's getting late, but

16 JNA --

17 MR. KARNAVAS: I'm sorry. Yes. Thank you. Wrong army.

18 Q. VRS.

19 A. Yes.

20 Q. Okay. All right. Well, you should have corrected me,

21 Mr. Salapura. Okay. Thank you.

22 So it was sometime in 1996. Now, could you tell us the reasons

23 for retiring in 1996. Were there any particular reasons other than

24 perhaps old age, if I can be so forward?

25 A. No, it was not because of old age. I had personal reasons and I

Page 10536

1 had announced my intention to retire early a long time in advance. I had

2 told General Tolimir while the war was still raging that I intended to

3 leave as soon as it was over.

4 Q. All right. Well, I have another document from the Prosecution. I

5 just wanted to get your input on this, and this has been marked for

6 identification purposes as D198.

7 MR. KARNAVAS: And I apologise to Madam Usher for having to travel

8 back and forth.

9 Q. Now, this document, sir, it would appear is a -- an article in a

10 magazine from the RS. And in here it has your name and it states that in

11 essence, for lack of a better term, you were fired, terminated, from your

12 position. That could be found on page 3 in the English version. And it

13 states and I'll just read it for the record, the second paragraph, a part

14 of the second paragraph on page 3: "However, the RS political leadership

15 ended the longstanding disagreements with the military top without a real

16 and objective understanding of its causes and, even more important,

17 without finding the most suitable solutions which would ensure the

18 continuity of the army and the defence of the Serbian people."

19 And then it goes down and it says that a decree was issued by

20 Biljana Plavsic on the retirement and termination of active duty and it

21 goes on and names you, Colonel Petar Salapura.

22 So my question is: Were you terminated by Biljana Plavsic when

23 apparently she was trying to re-organise or adjust the RS, as is suggested

24 in this particular article, D198 for identification.

25 A. No, Milutinovic wrote this. I don't know based on what, but it's

Page 10537

1 not true. Nobody retired me. I retired early on my own request, and I

2 was the first one to do so in the Main Staff.

3 Q. And since your retirement, where have you been living?

4 A. Banja Luka.

5 Q. Now, sir, I want to thank you very much for answering all of my

6 questions. Perhaps Mr. Stojanovic has some questions and I'm sure the

7 Prosecutor may have some as well as the Judges. If you could be as

8 forthright and frank with them as you have been with him, I would

9 appreciate it very much.

10 MR. KARNAVAS: Your Honours, I have no further questions on direct

11 examination.

12 JUDGE LIU: Thank you very much.

13 Any questions, Mr. Stojanovic?

14 MR. STOJANOVIC: [Interpretation] Good afternoon, Your Honours.

15 Cross-examined by Mr. Stojanovic:

16 Q. [Interpretation] Good afternoon, Mr. Salapura. I will try to

17 focus on that part of the examination-in-chief which was in relation to

18 P507, which is the logbook of the operations duty officer and I do have

19 some questions arising from that. First of all, I wanted to ask you: Do

20 you know Dragan Jokic personally?

21 A. I'm not sure if we ever met, actually. If we ever saw each other

22 anywhere, I have no recollection of that.

23 Q. You have no direct personal knowledge of ever having had any

24 personal contact with Dragan Jokic?

25 A. No, we never had any contact. We might have passed each other,

Page 10538

1 but I don't remember.

2 Q. Thank you.

3 MR. STOJANOVIC: [Interpretation] Can I have the usher's

4 assistance, please.

5 Q. I would like to show you P507 again.

6 MR. STOJANOVIC: [Interpretation] It has been used before,

7 Your Honour. For the sake of the transcript, let me say that the page we

8 will be looking at is ERN 02935744.

9 Q. Sir, this is just one page from a logbook kept by the duty

10 operations officer of the Zvornik Brigade. This is a document, or rather,

11 a logbook, that chief of staff Dragan Obrenovic, when he pleaded guilty,

12 submitted to the OTP. And this is a document that has been used here.

13 Can I please draw your attention to the last passage of the text. As

14 stated before it reads: "Colonel Salapura called - Drago and Beara to

15 report to Golic."

16 Okay. Up here, if you could just look at the date, 14th of July,

17 and then it says: "Jokic." According to Mr. Obrenovic's statement, this

18 was added by him. And then further you have notes taken by the duty

19 operations officer. My question to you is as follows, just to elaborate

20 on something that you have already said: Am I right in stating that you

21 don't in fact remember having had any communication at all on the 14th of

22 July in the morning hours with the command of the Zvornik Brigade?

23 A. No, I did communicate with them on one occasion, in fact. Now,

24 whether it was me personally or perhaps I delegated this to someone,

25 whether it was to Obrenovic or someone else, there was this piece of

Page 10539

1 information that we received. This is something that I still remember.

2 It said that there would be a counter-offensive, a counter-attack,

3 launched from the direction of Tuzla. I'm not sure exactly where from.

4 This is in the Zvornik Brigade zone, and I can't remember off the top of

5 my head exactly along which axis. But I do know that this information was

6 classified as urgent and I asked to have it conveyed. Whether it was

7 myself or perhaps one of my analysts, it's hard to remember now. That's

8 one thing.

9 And another thing that we received in relation to the

10 Zvornik Brigade, something that struck me as noteworthy at the time,

11 whether it came in on the 14th, the 15th, I can't really remember,

12 however, it was either of those two days. I'm not sure for how long the

13 operations had gone on for down there, whether it was during the same

14 offensive, the same attack, the information about an attack by the Muslim

15 units, units of Bosnia and Herzegovina, on an anti-aircraft gun and many

16 people were killed and wounded. This was a result of electronic

17 surveillance. That's how the information was obtained. And it was

18 obtained directly from a Muslim source. These two bits of information, to

19 the best of my recollection, that's what I talked about. How they were

20 monitored and how they were being monitored, well it has been nine years

21 after all. I can't remember any specific details of the situation, but

22 this is what I do remember. And who it was forwarded to, I really can't

23 say.

24 Q. But in terms of what this report says, this wouldn't lead you to

25 conclude that you took part in anything like this?

Page 10540

1 A. No, I don't see how this makes sense and I can't relate it to

2 anything. It's impossible for me to say. It may as well have been the

3 case, but I can't say what it's about. I can't. I don't know. If you

4 look at it, you see what it says. And I don't know. I can't make any

5 sense of it, why anyone would call Golic or why Drago would, but I don't

6 know, as I said. I'm not -- I simply don't remember. What can I do?

7 Q. Colonel, we have information that there was a hill above the

8 Standard barracks where the headquarters of the Zvornik Brigade was.

9 There was a radio communications centre that was used for communicating

10 with the duty operations officer at the brigade. Is it possible that a

11 communication like this, a message like this, was relayed to the duty

12 operations officer at the radio communications centre and then this duty

13 officer merely conveyed this message to the duty operations officer

14 further down and for the message not to be conveyed directly?

15 A. I'm not sure which system they used in the brigade. I simply

16 don't how messages were forwarded, whether their lines of communication

17 were fully functional or not. I can't say exactly how they went about

18 this.

19 Q. Let me phrase it this way: Do you think it would have been

20 possible for this kind of message to first be relayed to the radio

21 communications centre and then that they forwarded this to the duty

22 operations officer, so the communication was not done directly, but

23 rather, the officer up there was told to convey this message to another

24 man to get back to such-and-such a person, and then the duty operations

25 officer went back to the brigade with this bit of information?

Page 10541

1 A. Yes, that would have been entirely possible, why not.


3 MR. McCLOSKEY: He's already answered. He doesn't know how it

4 worked. So I think that's asked and answered and just keep asking the

5 same question is not appropriate.

6 JUDGE LIU: Yes. And by the way, Mr. Stojanovic, I think the

7 question is very speculative, because that person really doesn't know the

8 communications.

9 MR. STOJANOVIC: [Interpretation]

10 Q. Just another question, Colonel. What about infantry

11 unit -- brigades, did they have a reconnaissance and sabotage detachments

12 within their composition?

13 A. They were supposed to have those. Some did and some didn't. For

14 example, the command of the Drina Corps was supposed to have a platoon and

15 then a detachment, but it never had either of those. Whether a specific

16 brigade had any or not, I really can't say. But all in all, those units,

17 generally speaking, in the Army of Republika Srpska only very rarely got

18 involved in any special missions. More often in combat missions and

19 activities. And they, as a rule, suffered very, very high casualties.

20 Q. So these units, wherever they existed, would have been

21 subordinated to the commander or to the chief of staff?

22 A. To the chief of staff.

23 Q. They would have been attached to the staff itself, wouldn't they?

24 A. Yes. It was a unit attached to the staff and it was subordinated

25 to the chief of staff. He was the one who decided on the unit's

Page 10542

1 involvement, obviously, and I'll repeat this. The intelligence officer

2 from the brigade would make proposals for the use of that unit and

3 reconnaissance and sabotage. If the chief of staff grants his approval,

4 then that's how it's going to be. But as a rule, those units in 99 per

5 cent of the cases were either used as some sort of reserve by the

6 commander or the chief or used directly in combat operations as some sort

7 of an assault unit perhaps. But they didn't have any other units and

8 those units were not informed.

9 Q. Thank you very much, Witness. These are all the questions that we

10 had.

11 JUDGE LIU: Thank you.

12 We are almost approaching the time for a break. Could we break

13 first and continue, Mr. McCloskey?

14 MR. McCLOSKEY: Yes.

15 JUDGE LIU: Yes. And we'll take a break and we'll resume at 20

16 minutes to 6.00.

17 --- Recess taken at 5.10 p.m.

18 --- On resuming at 5.41 p.m.

19 JUDGE LIU: Yes, Mr. McCloskey, your cross-examination, please.

20 MR. McCLOSKEY: Thank you, Mr. President.

21 Cross-examined by Mr. McCloskey:

22 Q. Good afternoon, Mr. Salapura.

23 A. Good afternoon.

24 Q. I want to start with just asking you a few questions, and you'll

25 notice we repeat many of the same topics, so bear with us and our

Page 10543

1 repetition. I hope to have you out by our 7.00 deadline, but we'll just

2 have to see how it goes. You spoke about intel officers and their

3 relationship to recon units. I take it you were speaking of brigades and

4 corps and Main Staffs. And what you were telling us that it was the intel

5 officer's job to propose to the commander how those units were used. Is

6 that right?

7 A. Yes.

8 Q. And it worked that way in the brigade and in the corps and in the

9 Main Staff in terms of -- well, the 10th Sabotage Unit for the Main Staff?

10 A. Yes, that's correct.

11 Q. And it was really the commander that made the decisions on how to

12 use the people. Is that right?

13 A. Absolutely, he approved or failed to approve.

14 Q. And he was the one that would be responsible for that unit's use

15 and what they did?

16 A. The sole command and the right to command was held by the

17 commander and the chief of staff, in his own sector. Chiefs of services

18 and chiefs of the different branches had no authority to exercise command,

19 except within their own administration and unit, their assistants, their

20 administrators, that's in terms of everyday activities.

21 Q. And that applied to security as well as intel officers?

22 A. Yes. It also applied to security officers, but security officers

23 had their own methods that they applied. Those were also approved by the

24 commander. Those were two different areas, so to speak. Maybe if we look

25 at military police units, they had a higher degree of autonomy when

Page 10544

1 deciding on the possible unit.

2 Q. But a security officer would recommend how the military police

3 would be used, and the commander would decided to take that recommendation

4 or not and he would provide the orders for the military police. Is that

5 right?

6 A. Yes.

7 Q. Now, also in going back to the intel model, once the commander

8 makes a decision on how to use, in your situation, the recon platoon,

9 is -- would the intel officer be responsible for seeing to it that the

10 commander's orders were carried out?

11 A. Yes. He would be the one who would monitor the entire

12 implementation and get involved in preparing a specific unit for a

13 specific task. He monitors the entire course of implementation and he is

14 responsible for the orders to be carried out pursuant to the commander's

15 order. He has been trained for that and he is the most qualified person

16 or should be.

17 Q. He should know most about the orders that the commander has issued

18 since he's likely proposed them. Is that right?

19 A. Yes.

20 Q. And in that context, would the -- well, the intel officer in the

21 context of the recon platoon be able to pass on orders to the recon

22 platoon that were consistent with the commander's original intent?

23 A. I'm afraid I don't understand. What do you mean by passing on?

24 Passing on the commander's order, the order that came from a brigade

25 commander, for example, to pass this on to the commanders of the recon

Page 10545

1 platoon or the chief of staff, yes.

2 Q. That's what I mean, pass on the orders?

3 A. Yes, yes. Passing on the orders, yes.

4 Q. And as a -- basically as a conduit for the commander?

5 A. Yes, the commander could go directly to whoever or could decide to

6 go through the intelligence officer or the chief of that particular unit.

7 This could be transmitted orally in the eventuality of war or in

8 emergencies, or he could do it in writing.

9 Q. In a war situation, let's say with a recon platoon, when the intel

10 officer makes a proposal, the commander supports it, issues an order be it

11 verbal or written, and then the intel officer passes on that order to the

12 recon unit but keeps in touch, and as you've said helps make sure that

13 those orders are carried out. What kind of communication does the intel

14 officer have with the recon unit to make sure those orders are carried out

15 the way the commander intended? What kind of directions, for example,

16 would you expect the intel officer to give in that situation to the recon

17 unit?

18 A. He is the qualified person who agrees on all the details. He

19 monitors the whole thing until the task has been implemented. He looks

20 into whether the men have been trained for such a task, if there had been

21 enough time, whether they have all the equipment that's necessary to carry

22 out a certain task, he considers the nature of the task and the risk

23 entailed. He considers how the unit will carry out a certain task,

24 because now the commander of that recon unit based on the task that has

25 been assigned must take his own decision in his own area of activity. And

Page 10546

1 he reviews this decision with the chief of the intelligence organ

2 thoroughly. Because the objective is to have the task carried out and to

3 keep the casualties down.

4 Q. Okay. Now, in the situation -- let's go to a real-life situation

5 of the 10th Sabotage Detachment. We have heard evidence here that on

6 about, I believe, the 9th or 10th of July when the fall of Srebrenica was

7 anticipated, the VRS command was able to bring in Mr. Pelemis and a

8 certain number of his members from the 10th Sabotage Detachment. And were

9 you aware of that at the time?

10 A. I was not aware of that. I learned about that, that they had

11 taken part in fighting on the 12th in Modrica.

12 Q. Were you -- you knew that the 10th Sabotage Unit had a base in

13 Vlasenica and one in Bijeljina. Correct?

14 A. Yes. Yes.

15 Q. And you -- were you aware that General Krstic has used the guys in

16 Vlasenica on other operations when the need arose, in June for example?

17 A. Yes. Yes, there was an attack against the command post, I

18 believe.

19 Q. And did General Krstic, was he able to get that 10th Sabotage Unit

20 and put them to work in the defence in that campaign or that skirmish or

21 battle?

22 A. I am not sure which task he assigned to them precisely. I was in

23 Banja Luka at the time, and I was not familiar with the situation on the

24 ground. Because the unit had been subordinated to the command, but it was

25 not within the competence of the Main Staff, not that section anyway.

Page 10547

1 Q. I'm not talking about Srebrenica, I'm talking about

2 another -- something else in June. You talk about it, it was an attack on

3 a command post.

4 A. Yes. Yes, if that's what we're talking about. That was supposed

5 to be in late June.

6 Q. All right. Now, you say that you went to Banja Luka for this some

7 kind of treatment in late June.

8 A. Yes, yes.

9 Q. And you were obviously aware of the situation in the Srebrenica

10 enclave and the Zepa enclave as it was developing through the spring of

11 March, April, and May. Is that correct?

12 A. Yes.

13 Q. This was a potentially volatile situation. The communication

14 between Zepa and Srebrenica was causing problems to the VRS?

15 A. Yes.

16 Q. Were you aware that earlier that year President Karadzic had

17 issued a directive to make life impossible for the Muslims in Srebrenica?

18 A. No.

19 Q. Is this the first time you've ever heard of it, is now?

20 A. Yes.

21 Q. All right.

22 A. That's for sure.

23 Q. Going back to Srebrenica, as we build up that problem that you're

24 aware of in May and in the end of May, were you aware of the Drina Corps

25 operation to attack and remove a Dutch operation -- observation post in

Page 10548

1 the area of Zeleni Jadar in the south of the enclave?

2 A. First I hear of it.

3 Q. So you're not aware -- you didn't participate in any intel

4 analysis or any intel regarding that what I believe was one of the first

5 significant attacks on the enclave by VRS forces?

6 A. No.

7 Q. Were you aware of the operation that the 10th Sabotage Detachment

8 did a little earlier that year when they went through some tunnels to get

9 to Srebrenica and fired some rockets?

10 A. Yes.

11 Q. That was an operation proposed by you?

12 A. Yes.

13 Q. But you're not aware of the operation regarding Zeleni Jadar?

14 A. No.

15 Q. Now, there was obviously an operation to attack the Srebrenica

16 enclave, the attack we know began on the 6th of July, the attack plans are

17 dated a little earlier than that in the first week of July. Were you

18 involved in the intelligence, analysis, and preparation for the attack on

19 the Srebrenica enclave?

20 A. No. At the time I was in Banja Luka. And I was not involved. I

21 didn't even know that a decision had been taken, nor was I aware of the

22 time frame. It was only later that I found out from the public media.

23 The information I received in Banja Luka in terms of intelligence reports

24 concerning that part, the beginning itself, and that early part I knew

25 nothing about that. But it was immediately in the media, so that's how I

Page 10549

1 found out.

2 Q. It would appear from the reports that we see, May and June, that

3 you were probably one of the most knowledgeable people in the Main Staff

4 regarding the situation inside the enclaves and the Muslim forces. Is

5 that right?

6 A. I was not the most knowledgeable person. Perhaps the body itself,

7 the organ, the analysts, and those people who processed this information

8 directly. We continually monitored the situation in Srebrenica ever since

9 1992.

10 Q. Who was your best analyst that knew the situation the best at that

11 time?

12 A. Karanovic.

13 Q. What was your other analysts' names?

14 A. Jankovic.

15 Q. Radislav --

16 A. That's all. That's all. Unfortunately.

17 Q. They never called you or consulted with you while you were in

18 Banja Luka on this major operation?

19 A. No. I think once the decision had been taken, it was not allowed

20 for them to inform anyone. And I was not interested. I'm not sure if

21 they knew themselves. You know if you have a commander or a chief of

22 staff or the head of sector requests all possible information on

23 Srebrenica or on the general area, then within ten minutes they receive

24 the requested information. There are maps, of course. Maps are updated

25 every day. One of the officers is in charge of updating maps on a daily

Page 10550

1 basis. Therefore, the operation organ, the staff always keeps these maps

2 in the operations room, and whatever information they request in terms of

3 intelligence is always forwarded to them. I'm not sure about the level at

4 which this operation took place, whether it was corps level or Main Staff

5 level.

6 Q. You said something and maybe you didn't mean it, but you said you

7 weren't interested. And this was a significant event, the enclaves, the

8 attack on the enclaves. You had written reports about it. You must have

9 been interested. Did you -- or were you not interested?

10 A. You mean who made the decision and how the decision was reached?

11 I'm not sure what reason I could have had to be interested in that.

12 Q. All right. So from what you've told us you come out of your

13 health retreat because of an opportunity to gain information in Belgrade.

14 Is that right, something like that?

15 A. I did not come out of my retreat. I was still in that same

16 situation. My health problems continued. I simply went to Belgrade under

17 the effect of palliative injection for my spine. I went there to be

18 briefed.

19 Q. And who did you first hear about this Belgrade thing from? And

20 let's start, who within your own army told you about it?

21 A. It was not within the army. It was one of my operational contacts

22 from Banja Luka. I don't know which one of them it was among the four or

23 five who existed. We had communications, telephones.

24 Q. So this is what we would call a source, a sensitive source, that

25 you had that provided you with information?

Page 10551

1 A. Yes.

2 Q. Sorry. I didn't -- I don't think they heard you when you said

3 "moromor" or something like that?

4 A. Yes, yes.

5 Q. And I don't need the names of -- certainly of sources here. We

6 understand that. But can you tell us, was this source a civilian or

7 military?

8 A. I think that is irrelevant whether it was a civilian or not.

9 Q. I understand you don't want to give anything that might identify

10 the source. Is that right?

11 A. Absolutely.

12 Q. Okay. Well, then, did you tell Mr. Tolimir that you got this

13 information that you wanted to follow up on?

14 A. He was aware of the initial information, even before. The staff

15 was aware of it, too. But to give him more details, I simply could not

16 get hold of him. He was in Zepa and he learned the details later. There

17 was no telephone communication with him.

18 Q. Clearly some superior approved your trip to Belgrade.

19 A. This trip did not need to be approved by anyone. I could approve

20 myself.

21 Q. So no one approved it, no one knew about it?

22 A. In that specific case, I cannot tell you -- it's not that nobody

23 knew. Of course somebody knew. But there is a certain plan of activity

24 involved, a plan of my activity, which was of course known to Tolimir, in

25 the operational sense that applied to everyone. But the exact date,

Page 10552

1 whether it would be today or tomorrow did not depend on either him or me;

2 it depended on the call that I was supposed to get.

3 Q. All right. When you went -- you went actually to the city of

4 Belgrade?

5 A. Yes.

6 Q. And did you inform the VJ authorities that you would be in the

7 area?

8 A. No, why would I inform anyone?

9 Q. Well, weren't you a member of the VJ? Weren't you being paid by

10 the VJ?

11 A. No. No. I was a member of the Army of Republika Srpska. And

12 payment arrangements were settled and agreed at the level of their

13 leadership. I received my salary in Banja Luka.

14 Q. Weren't you being paid from Serb sources through the VJ?

15 A. Well, financial officers brought money probably from Yugoslavia,

16 yes.

17 Q. And we've seen most of the senior VRS officers were -- had what's

18 been referred to as shadow promotions, that when we were promoted in the

19 VRS they were also promoted to the same rank in the VJ. In fact, we've

20 heard that before VRS officers initially would agree to go to Bosnia to

21 fight the war, they wanted to make sure their Yugoslav careers stayed

22 intact, so that even though they were working for the VRS, they were still

23 being promoted by the VJ. Wasn't that the way it worked?

24 MR. KARNAVAS: If I could just interject here.

25 JUDGE LIU: Yes.

Page 10553

1 MR. KARNAVAS: Perhaps my memory is failing, which is possible, I

2 don't recall hearing this information. This is kind of the first time.

3 Now, I could be terribly wrong on this in this particular case. I'm not

4 saying that perhaps it's not accurate, but I'm just saying I don't recall

5 hearing it.

6 JUDGE LIU: Well --

7 MR. McCLOSKEY: I don't think that really matters.

8 JUDGE LIU: Well, Mr. Karnavas -- Mr. McCloskey, put this

9 information into the form of a question. Ask this witness whether --


11 Q. Isn't that the way it was working?

12 A. That was the job of personnel organs through the 30th Personnel

13 Centre. That was their area of competence. It's true that it functioned

14 that way.

15 Q. So most officers in the VRS got a -- promoted in the VJ when they

16 got their promotions in the VRS. In fact, many of them have retired to

17 Belgrade now and are receiving pensions. Isn't that right?

18 A. I think that those were fictional promotions and retirements for

19 the purpose of justifying these outlays, but that is a question that would

20 be more properly asked of this personnel centre and higher authorities.

21 That's not my job.

22 Q. I think I have heard it described as fictional or shadow

23 promotions. But my question is: Were you getting those same fictional or

24 shadow promotions that the others were?

25 A. I did, but in Republika Srpska. What exactly the 30th Personnel

Page 10554

1 Centre wrote about it, how they put it down on paper, I couldn't tell you

2 because I didn't see their papers. And I was promoted before the war.

3 Q. All right. And did you have any contact with the authorities of

4 Yugoslavia, either the army or the police, during this short trip there?

5 A. I had with the police at the border crossing.

6 Q. Okay. Well, we also see that you have -- from your reports that

7 you shared, your reports with the Bosnian state security service, the MUP,

8 the various corps, and the Main Staff, so you had detailed dealings with

9 at least the state security and the MUP in Bosnia. Is that right?

10 A. No, we did not have any contact with the MUP. We sent our reports

11 only to the state security administration, not to the MUP.

12 Q. SDB?

13 A. Yes.

14 Q. So I would guess you would have had some contacts over in

15 Yugoslavia with those state security services? I'm not going to get into

16 that, don't worry.

17 A. I had contacts with many people.

18 Q. All right. And why did you decide to leave Serbia and go back to

19 Bosnia on this trip?

20 JUDGE LIU: Yes.

21 MR. KARNAVAS: Well, it was the last part that -- I guess I don't

22 object to it at this point, but I thought it was with respect to

23 going -- never mind, Your Honour. I'll just sit down.

24 JUDGE LIU: Thank you.

25 MR. McCLOSKEY: It's not that heavy, don't worry.

Page 10555

1 JUDGE LIU: Thank you.


3 Q. Can you tell us, was your work done? Why did you pick the time

4 and date that you did to go back to Bosnia?

5 A. Well, I came from Bosnia to finish that business. I did that and

6 went back.

7 Q. Okay. And so what day did you leave Serbia?

8 A. On the 12th, the evening of the 12th. The same day.

9 Q. And how far did you get that evening before you stopped to rest?

10 A. I went up to Bijeljina.

11 Q. That's just right up on the border between Bosnia and Serbia?

12 A. Yes.

13 Q. And you had obtained this very valuable information about when the

14 Croat offensive would start. Is that correct?

15 A. Yes.

16 Q. And was that what was called Operation Storm, I think, by the

17 Croats?

18 A. Yes.

19 Q. And when did that operation actually start? When did they start

20 shooting?

21 A. Well, I couldn't tell you the exact date now. I don't remember

22 it. I think, according to the information I received, it was supposed to

23 start on the 1st, but it was postponed by a couple of days. It started on

24 the 3rd or the 4th, I'm not sure.

25 Q. I'm not asking you about the information; I'm asking you when it

Page 10556

1 actually started.

2 A. I told you I can't tell you the exact date now.

3 Q. Just roughly then.

4 A. Well, as I said, the 3rd or the 4th, around that time.

5 Q. What month?

6 A. August.

7 Q. We're a little bit stuck in July in this case, so we need to make

8 sure we know the months that we're talking about. And I don't want to get

9 into this in detail, but I think we know and history knows that many

10 innocent Serbs were killed in that offensive. Is that right?

11 A. Probably. This Tribunal knows about it.

12 Q. And -- so this information you had was extremely valuable, it

13 could save lives. Did you stop at the East Bosnia Corps in Bijeljina,

14 where there were secure communications?

15 A. Yes.

16 Q. Were you able to get off a secure, coded Teletype to Han Pijesak

17 or Pale or wherever your superiors were?

18 A. No. I sought to establish direct contact with either Tolimir or

19 with --

20 THE INTERPRETER: The interpreter didn't hear the other name.

21 THE WITNESS: [Interpretation] And only based on their answer would

22 I be able to draw up a written report with details included.


24 Q. Sorry. The interpreter -- they heard Tolimir, but they didn't

25 hear the name of the other person you were trying to contact.

Page 10557

1 A. The commander. The commander, yes.

2 Q. And who went with you to Belgrade? So who was with you on this

3 trip?

4 A. Only the driver.

5 Q. So had you been --

6 JUDGE LIU: Well, well --

7 THE WITNESS: [Interpretation] From Bijeljina to Belgrade, I only

8 had the driver with me. And up to Bijeljina, there were two more officers

9 with me.

10 JUDGE LIU: Well, Mr. McCloskey, sorry to interrupt. Here in the

11 transcript it's still not clear, because we don't have the name of Mladic

12 there. We only have: "The commander, the commander, yes."

13 So would you please --

14 MR. McCLOSKEY: Yes, Mr. President.

15 Q. We just need to make clear for the written record, the commander

16 you wanted to get a hold of was General Mladic. Correct?

17 A. Yes, yes.

18 Q. Okay. And so let me just -- who did you go from Banja Luka to

19 Bijeljina with when you went -- when you were going to Serbia, going to

20 Belgrade? Did you have a driver?

21 A. I had a driver with me and two officers.

22 Q. And what were their -- what were the names of the driver and the

23 two officers? And if you want to go into private session for that, we

24 can.

25 A. I don't know why -- in fact, I don't quite understand what a

Page 10558

1 private session means.

2 Q. It just means that it doesn't go out to the public. I don't mean

3 anything by it. You just have that opportunity if there's some sensitive

4 information you have, it's the Court's discretion to allow that or not.

5 I'm sure victim and witnesses has explained that to you. In any event,

6 can you tell us the names of the three people?

7 A. I can. One of them was Mirko Obradovic.

8 Q. And if we could get the rank and the unit so we can distinguish

9 who they are.

10 A. Well, I don't know whether he was a lieutenant in reserve or not.

11 You have to take my word for it, I cannot remember. I think he was a

12 reserve lieutenant, but he was an information technology specialist, a

13 software programmer.

14 Q. Who else?

15 A. Another one was Braco Erceg, also reserve lieutenant, programmer.

16 Q. And the driver?

17 A. And the driver was Radan -- I cannot remember his last name. He

18 was from Bijeljina. Was it Kovacevic? At any rate, he has a nickname of

19 Brdjak, B-r-d-j-a-k. I believe his last name was Kovacevic.

20 Q. And who -- did anyone go with you from Bijeljina to Belgrade?

21 A. Only the driver.

22 Q. Okay. And when you came from Belgrade to Bijeljina, only the

23 driver or did you have anybody else with you?

24 A. Only the driver.

25 Q. So from Bijeljina down towards the Bratunac area, if you had been

Page 10559

1 in an accident or been attacked and killed, that information would have

2 gone with you?

3 A. Yes.

4 Q. When you were at the East Bosnia headquarters, were you able to

5 become acquainted and updated about the situation around Srebrenica

6 on -- and this would have been I guess the 12th of July?

7 A. No.

8 Q. Had you heard that Srebrenica had fallen on the 11th of July, the

9 day before?

10 A. Yes, I did. I heard of it in Modrica.

11 Q. So when you were at the Bijeljina headquarters, weren't you

12 curious to find out from the duty officer, from the intel officer, from

13 the commander, from anyone how things were going down there. I mean, this

14 was your area, this was your army.

15 A. I don't know why I would be curious. Srebrenica was taken over;

16 end of story. For me as an intelligence officer, it was the end of story.

17 At the moment our units entered Srebrenica. The entire intelligence work

18 in that area was over and the service was no longer interested in

19 Srebrenica; it was now interested in Tuzla and the possible

20 counter-attack. Our electronic reconnaissance and our entire activity

21 became focused on that. And all the developments in that other area, the

22 columns of people, and everything else that happened was the job of the

23 security services of the command. Our intelligence service no longer had

24 anything to do with it.

25 Q. Isn't one of the most important sources of intelligence prisoners,

Page 10560

1 prisoner debriefings?

2 A. Absolutely. That is the job of unit intelligence officers from

3 battalion downwards, field intelligence officers and in especially

4 interesting cases, somebody can come down from the corps.

5 Q. And that can even go, of course, to the Main Staff, can't it?

6 A. Yes.

7 Q. And you described earlier how you worked closely with the security

8 branches and you share information. So you share more information with

9 them than they with you, but you stand by that?

10 A. No. Our information was available to all organs of the staff on a

11 daily basis.

12 Q. And so the prisoners of Srebrenica would have been a very fertile

13 source of intelligence information for the brigades, for the corps, and

14 for the Main Staff?

15 A. Not really fertile. I don't know what could be especially

16 interesting about them from our point of view. What would be interesting

17 would be to hear from prisoners from Tuzla, Zenica. Srebrenica was an

18 enclave. There was nothing particularly interesting about it after all

19 those years.

20 Q. Well, we'll talk about that a little bit later, but before that

21 let me show you a document. It's P445. Take a look at the B/C/S. It's

22 dated 12 July to the Drina Corps command intelligence section, very

23 urgent -- actually, it appears to be from the Drina Corps command

24 intelligence section, very urgent, to the Main Staff of the VRS

25 intelligence sector. And it's also sent off to the Drina Corps forward

Page 10561

1 command post at Pribicevac, General Krstic personally, and some brigades

2 and Lieutenant Colonel Popovic, chief of intelligence organs for the

3 brigades, also to the MUP of the RS, and the RDB. I want you to take a

4 look at that, if you could. And I want to ask you about whether things

5 were really over in terms of intelligence at that time.

6 A. Yes.

7 Q. Okay. Let me read you a paragraph, it's, I think, the

8 second-to-the-last one very near the end of the document. It says: "We

9 have informed organs of the MUP, the RS, and Konjevic Polje about the

10 illegal corridor used by the Muslims of Srebrenica, since it is their task

11 to control the Bratunac/Konjevic Polje road."

12 And incidentally this starts off with a statement that -- from a

13 Muslim prisoner who appears to be retarded and it's a -- comes out, as you

14 can see, under the name of your boss, Zdravko Tolimir. And it goes on to

15 say: "Brigade commands have the duty to fully inform the SJB (public

16 security station) in the area of responsibility."

17 And then it says: "Intelligence organs shall propose measures to

18 be taken by commands to prevent armed Muslims from illegally reaching

19 Tuzla and Kladanj, such as setting up ambushes along the routes they use

20 in order to arrest them and prevent possible surprises against civilians

21 and our combat units along those routes."

22 That's directed to the commands of the Bratunac, Zvornik, Milici

23 brigades. So this is your boss, Tolimir, writing this. Right?

24 A. Just a minute. "We have informed" -- yes, yes.

25 Q. So there is a role that the intelligence units are playing. And

Page 10562

1 you were playing a role in this work yourself, weren't you?

2 A. No. This is OB. Since we are at the level of battalion and light

3 brigades and some other units. On those levels, we were unified. It

4 says: "Organs for intelligence and security, OB."

5 Q. Right. And that's -- General Tolimir was in charge of that, and

6 that's intelligence and security. So it's intelligence and security

7 working together?

8 A. Yes, yes.

9 Q. So there was -- here we have intelligence and security working

10 together. Correct?

11 A. As you see from this, there is an exchange of information. The

12 information we receive, we make available to others for their purposes and

13 everybody else was required to make their information available to others.

14 There's nothing special about that.

15 Q. And much of this information could have come from captured

16 prisoners, couldn't it?

17 A. Yes, it could have.

18 Q. So intel officers would have had direct contact with captured

19 prisoners?

20 A. They could have had, but I can't say whether a particular officer

21 in the battalion did, in fact, have because he was also the assistant for

22 intelligence and security. This sort of information would have been more

23 interesting to the security service rather than to the intelligence

24 service. If there was an intelligence officer who obtained this sort of

25 information, of course he forwarded information to the security officers

Page 10563

1 or he would perhaps inform the chief of staff and so on and so forth.

2 Q. Do you know that on the early morning hours of 16th July, more

3 Serb young men were killed in battle than probably any other day in the

4 war, partly because of bad intelligence in the area of Baljkovica? Do you

5 want to tell us that that information didn't matter to the infantry units

6 of the Republika Srpska?

7 A. All information is equally important in terms of command. The

8 question is: How much information is there and how do you get the

9 information? But again, I must tell you this is at our rear deep within

10 our territory. And the system is now within the jurisdiction of the

11 security service, as a priority, tracking down those groups, that sort of

12 thing and informing the MUP.

13 Q. You just said that one of your main jobs as an intelligence

14 officer was to get at the truth.

15 A. Yes.

16 Q. And you were right there in Nova Kasaba on the 13th of July --

17 A. Yes.

18 Q. You were right there with -- so you had the ability to see the

19 truth, didn't you?

20 A. I told you what I saw. Nothing special was going on back then. I

21 drove through a line of fire in my vehicle.

22 Q. Okay. Well, do you know that Colonel Beara was -- happened to be

23 at the 65th Protection base about the same that you were on the 13th. Did

24 you meet him there or see him there?

25 A. No. No, not then. He wasn't.

Page 10564

1 Q. No one gave you any reports about Mr. Beara being there?

2 A. No. Why should anyone have reported to me about that?

3 Q. You're an intelligence officer. What Beara was doing would have

4 been of interest to you, wouldn't it, given the relationship between the

5 two?

6 A. I don't know why.

7 Q. Well, for example, if Beara had several hundred prisoners that I

8 think you saw at the soccer pitch, wouldn't you have been interested in

9 the information that those prisoners had?

10 A. Yes.

11 Q. So what effort did you make to find out about the information that

12 those prisoners could be providing?

13 A. Well, not me. I was not the one to talk to those prisoners or to

14 seek information from those prisoners. From the battalion down you have a

15 whole system, information is gathered, and finally it is likely to reach

16 the analysts working with the administration. Whatever is needed urgently

17 will be forwarded to the commander.

18 Q. So what effort did you make to find out what information was being

19 provided to intel services and security services about those prisoners

20 that were right there in front of your eyes?

21 A. I didn't do anything at the time. I didn't know about if anyone

22 had gone or not. Later I just wasn't interested in the source. As you

23 have seen, what I receive is processed information, second-hand

24 information. And you can't tell where the information was obtained, where

25 from this source or that source, except in such exceptional cases as this

Page 10565

1 one, what we see written here. You have the battalion, the brigade, the

2 corps, the Main Staff. And everyone processes this information. And what

3 reaches the Main Staff is only what is pertinent to that particular level.

4 Q. You were on the ground. You had the ability to find out what

5 might be pertinent by asking a few questions to the officers in charge

6 around you, didn't you?

7 A. Again, I was not a unit intelligence officer. It just wasn't my

8 job to go to the soldiers and ask around.

9 Q. There was a commander that you said you met with at the 65th

10 protection area, 65th Protection Regiment.

11 A. Now, whether he was the commander, I'm not sure who it was. It

12 was either him or -- I can't exactly right now, but yes, the commander.

13 Yes, presumably that's what it says, but he may have been --

14 THE INTERPRETER: The interpreter didn't get the last portion of

15 the witness's answer.


17 Q. You didn't make any effort to find out what these prisoners could

18 offer the VRS?

19 A. If we take an example, what could possibly be of interest to me?

20 What could I get from those prisoners? What sort of information was it

21 that I would have been able to obtain from those prisoners at the time?

22 At the time none of that was of interest to me. At the time, every minute

23 that anyone from the Main Staff spent -- or me personally as an

24 intelligence officer, would have been wasting time. I focused all of my

25 attention to something entirely different and elsewhere. The Tuzla area,

Page 10566

1 the counter-attack, that's what was essential, and of course the western

2 sector and the forthcoming operation by the Croatian army. That's, as far

3 as I am concerned, on my level as far as the intelligence level further

4 down at brigade level, he is probably interested in every village and

5 every single house.

6 Q. The chief of the 28th Division intel could have been on that

7 soccer field, couldn't he have?

8 A. He could have.

9 Q. And by a helicopter flight, he could have been flown in the day

10 before from Sarajevo, having discussed the upcoming operations, yet you

11 weren't interested in the possibilities of those men on that soccer field.

12 I think that's clear enough.

13 MR. KARNAVAS: You know, I don't think that that's a helpful

14 comment -- excuse me. Again -- you know, I know it's late, but I don't

15 know that was a question. It was just a comment and it was gratuitous in

16 nature.

17 JUDGE LIU: Yes, it's a comment. I agree with you. But let's

18 move on.


20 Q. All right. Let's go to another document. It's P865. By the

21 way -- I'm sorry, before we leave that -- the last document, can you tell

22 us where you think Tolimir was as a result -- I'm sorry, can we go back to

23 the other document. It's my fault. Where do you think Tolimir was when

24 he issued this order?

25 A. I don't know. I can't say anything about the time or the

Page 10567

1 whereabouts.

2 Q. The fact that it says Drina Corps command intelligence section, is

3 that an indication that that's where he might be? I mean, you're the

4 intel officer, can you help us figure this one out?

5 A. What that means is he's probably somewhere in the Drina Corps

6 zone. Right?

7 Q. Well, you tell me.

8 A. I don't know exactly where. I mean, this would be a mere

9 assumption.

10 Q. All right. Let's go to the next document that I had mentioned

11 before, 865. It's another communication under the name of Major General

12 Zdravko Tolimir. And this has at the top of it -- well, yeah, take a

13 minute to read it.

14 A. Yes.

15 Q. Okay. Now at the top of this document it says the command of the

16 1st PLPBR, which we believe is an abbreviation for the Podrinje Light

17 Infantry Brigade. Is that right?

18 A. Yes.

19 Q. And where is the headquarters of the Podrinje Light Infantry

20 Brigade?

21 A. Well, based on this, I think the brigade was in Rogatica.

22 Q. All right. And --

23 A. Based on what this document says. Personally, I don't know what

24 brigade this was. I suppose it's the Rogatica Brigade.

25 Q. Right. That's what it looks like. Would that be -- would that

Page 10568

1 suggest that Mr. Tolimir is in Rogatica on 13 July?

2 A. Yes.

3 Q. Okay. And it says -- this is to the VRS Main Staff, to

4 General Gvero personally. Can you remind us very briefly what Gvero's

5 position was in the Main Staff.

6 A. Assistant commander for morale and for information.

7 Q. Okay. And this says: "Accommodations of r/z."

8 What does r/z stand for?

9 A. Prisoners of war.

10 Q. Okay. And it says: "If you are unable to find adequate

11 accommodation for all the r/zs from Srebrenica, we hereby inform you that

12 space" - with a word that they don't know what it means - "has been

13 arranged for 800 prisoners of war in the 1st PLPBR in Sjemec."

14 Now, first of all, let me ask you. There's a word that the

15 translation folks didn't know. So let me ask you if you can help us. The

16 word, "palaca". What does that mean? What's a palaca?

17 A. What that means is there was a room, a large or a small room, or a

18 room like this. Wooden boards were placed there on the ground. And

19 blankets were put there or those thin mattresses to sleep, to put people

20 up there.

21 Q. Okay.

22 A. That's what you call pallets.

23 Q. So it's the pallet that forklifts use to carry things on?

24 A. No, no, not at all. You lift it from the ground, you put a wooden

25 board in between so there's no bed. There's the ground and then on top of

Page 10569

1 that you place the boards, and that's how soldiers slept, too. But we

2 had -- back there in the army, we had very thin mattresses. It had rubber

3 underneath and tarp on top. You put blankets on top of that and that's

4 where you sleep. This is what you do when you need to put up a large

5 number of people when there are no beds available, that's what you use,

6 pallets.

7 Q. Okay. Thanks for that. Do you know what he's talking about in

8 this first paragraph, what your boss is talking about on the 13th? I

9 think you're in the Bratunac area at that point.

10 A. Yes. Well, it's clear enough what's being sent, a message or a

11 telex.

12 Q. I know what's being sent. I mean, aside from this document do you

13 know what he's talking about, from being on the ground and getting

14 information about prisoners, not from this document but from your own

15 personal knowledge of having been there?

16 A. It talks about putting prisoners up, rather detainees. There were

17 a large number of detainees and there was no room to put them up, no

18 conditions to accommodate them and how those people would be involved in a

19 time to come.

20 Q. Well, were you involved in this potential transport of Srebrenica

21 prisoners to Rogatica?

22 THE INTERPRETER: The interpreters didn't get the answer.

23 THE WITNESS: [Interpretation] How should I have been involved with

24 that? Only if I had my own car to drive.


Page 10570

1 Q. I didn't ask you if you went to Rogatica, but were you involved in

2 the organisation and the information related to moving a lot of prisoners

3 to Rogatica?

4 A. Absolutely not. I wasn't even aware of it until now.

5 Q. Okay. It goes on to say: "The 1st PLPBR can guard them with its

6 own forces, and would use them for agricultural work, maintaining the

7 horse, pig, and sheep farm.

8 "If you send them to this sector, this must be done at night,

9 using the brigade transport and troops."

10 Were you aware of any prisoners being sent to Rogatica, any

11 Srebrenica prisoners?

12 A. No.

13 Q. In the last sentence, it says: "It would be best if this is a new

14 group which has not been in contact with the other r/zs."

15 What does that mean? Why do they want a group that's not in

16 contact with the other Srebrenica prisoners?

17 A. I don't know. I wouldn't like to speculate. I don't know,

18 believe me.

19 Q. Do you know all the prisoners you saw on that soccer field that

20 day were all murdered by the Serb forces?

21 A. I don't know that they were killed.

22 Q. So from your trip to Bijeljina, why did you stop in Nova Kasaba?

23 A. On the way to Bijeljina, no, I was on my way back from Bijeljina

24 and I stopped there to ask where I could find the commander, as I

25 explained some time ago. The command where the military police were

Page 10571

1 stationed, they were in charge of the supplies. And that's why I came by

2 because I thought they should know.

3 Q. You drove right by the Zvornik Brigade barracks on your way from

4 Bijeljina towards Nova Kasaba, didn't you?

5 A. Yes.

6 Q. Did you stop there?

7 A. No. I don't think so. At least, I don't remember. I'm not sure

8 why I should have. I don't remember having stopped. I don't know what

9 the reason would have been. I don't know. I don't think so. There would

10 have been no reason for me to stop.

11 Q. Well, you knew a brigade would have had all kinds of communication

12 abilities to find out where Mladic or Tolimir or someone else was, but you

13 chose to go down to Nova Kasaba instead.

14 A. The same communications equipment was also in Bijeljina. I

15 couldn't get through using the communications equipment. I tried to get

16 through personally to get in touch with them in person.

17 Q. So on the 13th when you were in Nova Kasaba, you heard that Mladic

18 was in, where, Srebrenica at the time? Or in the Bratunac area?

19 A. No. I was told at that time in the area of Bratunac. That's what

20 I was told to the best of my recollection if ...

21 Q. So you then drove to the Bratunac Brigade headquarters. Right?

22 A. Yes.

23 Q. And about what time did you get to the Bratunac Brigade

24 headquarters, just roughly?

25 A. I don't know. I couldn't define it exactly now. I don't know.

Page 10572

1 It must have been around noon or I can't -- whether it was at 11.00,

2 12.00, I really can't define the time for you. After all, it's been nine

3 years and this would be mere speculation on my part.

4 Q. Well, just 11.00 or 12.00, that's fine. That's just your best

5 estimate. When you were driving from the area of Nova Kasaba, besides the

6 prisoners on the Nova Kasaba football pitch, did you see any more

7 collections of Muslim prisoners?

8 A. Between Nova Kasaba and?

9 Q. Konjevic Polje.

10 A. No. Between Nova Kasaba and Konjevic Polje, no, I don't remember

11 having seen anything like that, except for the football pitch, that area.

12 Q. What about the intersection at Konjevic Polje, a warehouse there

13 right on the crossroads?

14 A. No, no. I didn't notice anything there.

15 Q. Okay. How about as you go towards Bratunac maybe a kilometre or a

16 few kilometres from Konjevic Polje towards Bratunac in the little village

17 of Sandici, a big meadow. Did you see any prisoners compiled in a meadow

18 there?

19 A. No. To the left there was a group of prisoners but not many.

20 Perhaps, I don't know, a rather small group.

21 Q. And --

22 A. That was past Konjevic Polje on the road to Bratunac, to the left

23 of the road. It was not a meadow exactly, it was just a small clearing.

24 I'm not sure if I noticed anything anywhere else. I can't remember now.

25 But this much I know for sure.

Page 10573

1 Q. When you got to the Bratunac Brigade, where did you go in the

2 brigade command?

3 A. Where specifically? Well, I don't know. I asked about

4 General Mladic. I think it was the duty operations officer that I

5 approached.

6 Q. Do you remember who that was?

7 A. I asked about the commander's whereabouts and I was told that he

8 was in Srebrenica. And -- yeah, the duty operations officer, but I can't

9 remember. I really can't remember.

10 Q. Were you in uniform at the time?

11 A. Yes, in uniform.

12 Q. You identified yourself as being from the Main Staff?

13 A. Whether I identified myself or not, these are details. I can't

14 state with certainty whether I did. I probably did, but I can't remember

15 specifically now. These are too many details that you're asking about.

16 Q. Did you ask the duty officer to acquaint you with the most recent

17 news of the situation on the ground?

18 A. No. Why would I have asked him? It was not his duty to inform

19 me.

20 Q. You were driving in an area where you must have known there were

21 thousands of Muslims running loose. You weren't interested in finding out

22 anything where they might be and what roads might be hazardous and what

23 the situation is along the roadway?

24 A. No, no, I wasn't interested. It was on the way back that I came

25 under fire in my car.

Page 10574

1 Q. About what time did you come back?

2 A. I don't know. It's really difficult for me to say, to talk about

3 the exact time, how long I stayed there and how soon I went back. I only

4 stayed for a brief while. How long exactly, it is difficult to say. It

5 may have been in the afternoon, it may have been a bit later. It may have

6 been at 1.00, maybe 2.00. It's really difficult to say. I think it's

7 impossible for me to say right now with any degree of accuracy.

8 Q. We don't need exact times; nobody knows exact times. We're just

9 trying to get an idea whether it's morning, around noon, afternoon, late

10 afternoon.

11 A. It certainly wasn't in the morning. It was in the afternoon or

12 around noon, some way into the afternoon, but I can't say exactly.

13 Q. Now, when you went through Potocari, did you have any trouble

14 driving through the crowd?

15 A. Yes. There were many people there, but the road was free, clear.

16 Q. Did you see what was going on in Potocari?

17 A. Nothing was going on, not at the time.

18 Q. Some people were sitting there, women were there, children. Some

19 were sitting, some were standing, and some were just moving about. At

20 that point in time, nothing -- well, there were many people there. White

21 UNPROFOR vehicles were driving by, our vehicles, our soldiers, their

22 soldiers, that sort of thing.

23 Q. Did you see Muslim civilians being loaded on to buses and trucks?

24 A. Not when I was leaving. On my way back, the buses, yes, I did, on

25 my way back.

Page 10575

1 Q. All right. And did you see the Muslim men getting separated from

2 their families as they were getting -- as they were getting on the buses?

3 A. No, on my way through I saw a vehicle. There were several buses

4 there. I can't think exactly how many. And people were being loaded. I

5 didn't notice that.

6 Q. At the time did you know who the chief of security for the

7 Bratunac Brigade was?

8 A. The Bratunac Brigade? I know now and I've known for quite some

9 time now. Whether I knew at the time, I don't know. I can't say with

10 precision. I may even not have known or I may have known. I really can't

11 say.

12 Q. Nothing special really struck you at the time that would cause you

13 to know him or not know him, apparently?

14 A. No. Nothing special.

15 Q. Did you see any soldiers or officers you recognised in Potocari,

16 either on the way through the first time or as you came back?

17 A. I don't think I saw anyone in Potocari that was familiar on my way

18 out.

19 Q. Did you get any information --

20 A. On my way back.

21 Q. Did you have any information that Muslim civilians were being

22 abused and in at least in one case shot and killed right there in front of

23 the Dutch soldiers in Potocari nearby where you were driving, bodies in

24 the woods? Did you get any information about that as an intelligence

25 officer, or as anyone else?

Page 10576

1 A. No. I did not get that, not even as an intelligence officer.

2 That would have been more interesting to the security service than to my

3 service.

4 Q. I apologise, I have a -- probably another 15 minutes. There's

5 another document or two, so I was hoping to finish today, as I know

6 everyone was. But I will be able to finish up pretty early tomorrow.

7 JUDGE LIU: Well, I think we have to stop here. It's 7.00

8 already. And tomorrow morning we'll sit in the same courtroom at 9.00.

9 Well, Witness, I'm afraid that we have to keep you here overnight

10 because we did not finish your testimony. And during the time you are in

11 The Hague I have to remind you that you are still under oath, so do not

12 talk to anybody and do not let anybody talk to you about your testimony

13 today. Do you understand that?

14 THE WITNESS: [Interpretation] Absolutely clear.

15 JUDGE LIU: Well, have a good rest.

16 And the hearing for today is adjourned.

17 --- Whereupon the hearing adjourned

18 at 7.02 p.m., to be reconvened on Wednesday,

19 the 9th day of June, 2004,

20 at 9.00 a.m.