Tribunal Criminal Tribunal for the Former Yugoslavia

Page 13633

 1                           Friday, 18 March 2011

 2                           [Open session]

 3                           [The accused entered court]

 4                           [The witness takes the stand]

 5                           --- Upon commencing at 9.02 a.m.

 6             JUDGE KWON:  Good morning, everyone.

 7             Yes, Mr. Tieger.  Good morning to you.

 8             MR. TIEGER:  Good morning, Mr. President.  Good morning,

 9     Your Honours.

10             Before we resume, may I take this opportunity to rectify an

11     oversight in the tendering of exhibits.

12             The Court will recall that there were a number of references to

13     the fact that the witness listened to quite a number of intercepted

14     telephone conversations during his visit this time to The Hague,

15     specifically, I think, on March 2nd.  I had -- Mr. Robinson and I had

16     agreed that the proofing note reflecting that list of intercepted

17     conversations, and the witness's indication that he recognised his own

18     voice and the voices of others in the conversation, would be tendered for

19     admission.  It's one of those circumstances where because of the

20     agreement, that fell to the bottom of the list, and I simply didn't

21     perfect that at the conclusion of the examination-in-chief, and I would

22     like to do so at this time.

23             JUDGE KWON:  Do you have the list?

24             MR. TIEGER:  It's 65 ter 23099.

25             JUDGE KWON:  Okay.  Shall we up-load it.

Page 13634

 1             Speaking for myself, I'm fine with the intercepts the witness

 2     recognised as his voice, but in other cases, he dealt with in his -- we

 3     didn't admit his statement dealing with those --

 4             MR. TIEGER:  In fairness, Your Honour, I wasn't -- I'm not

 5     tendering the underlying intercepts at this time.

 6             JUDGE KWON:  Just that exhibit, the proofing note?

 7             MR. TIEGER:  Yes.  And as I say, I spoke with Mr. Robinson about

 8     that, outlined the procedure.  We also made sure that in any extraneous

 9     comments were eliminated and so this deals with those intercepts,

10     specifically.

11             JUDGE KWON:  I take it there's no opposition from you,

12     Mr. Karadzic.

13             THE ACCUSED: [Interpretation] Our position as regards the

14     intercepts remains the same, so whatever the Trial Chamber decides.

15             THE WITNESS: [Interpretation] I have something against it.

16             JUDGE KWON:  We are talking about this supplemental information

17     sheet, proofing note, which you can see in the e-court.

18             MR. TIEGER:  And for the accused's benefit, the agreement with

19     Mr. Robinson was not understood as altering the Defence position on

20     intercepts in any way.

21             JUDGE KWON:  No, no.

22             THE ACCUSED: [Interpretation] We have no objection.

23             JUDGE KWON:  Yes.

24             Mr. Prstojevic, do you like to say something in relation to this

25     document?

Page 13635

 1                           WITNESS:  NEDJELJKO PRSTOJEVIC [Resumed]

 2                           [Witness answered through interpreter]

 3             THE WITNESS: [Interpretation] Yes, I would, and thank you for

 4     allowing me to speak.

 5             A few days ago, I listened to 27 intercepted telephone

 6     conversations, only one of which was in writing.  Twenty-five, I did not

 7     wish to comment at all, though I confirmed that I did recognise my voice

 8     and the voice of some of my interlocutors.  But I believe that I should

 9     not comment on that, but rather do it in the courtroom.

10             Two of these conversations were eventually dropped as atomic

11     bombs, because I had an argument with the Prosecutor -- or, rather, the

12     investigator.  And when he presented these two, one was in writing and

13     not valuable at all.  The discussion concerned old-age pensions, and I

14     commented a bit on that.  And another one which dealt with mobilisation.

15     And I saw that the investigator simply did not understand that what was

16     being done was legal and lawful and legitimate.  He saw something else in

17     that.  And I am opposed to having conversations that I did not comment to

18     be admitted as part of my evidence.

19             JUDGE KWON:  Thank you.

20             At this moment, what we admit is the fact that you recognise

21     certain voices in these intercepts.

22             Yes, Mr. Karadzic, please continue your cross-examination.

23             We'll give the number for that proofing note.

24             THE REGISTRAR:  Your Honour, that's Exhibit P2521.

25             THE ACCUSED: [Interpretation] Thank you.

Page 13636

 1             Good morning, everyone.  Good morning, Mr. Prstojevic.

 2             THE WITNESS: [Interpretation] Good morning, Mr. President.

 3             THE ACCUSED: [Interpretation] Could we please see in e-court

 4     65 ter 6591.

 5                           Cross-examination by Mr. Karadzic: [Continued]

 6        Q.   [Interpretation] Do you remember, Mr. Prstojevic, that when we

 7     had the Joint Assembly session on the 25th of January, 1992, we had

 8     almost achieved an agreement, Cengic and myself, that the government

 9     should effect regionalisation and that we should hold a referendum?  It

10     was a well-known meeting next to the microphone where Mr. Cengic and

11     myself were.  Do you remember that?

12        A.   Yes, I do.

13        Q.   Do you remember that after the break, it was unsuccessful again,

14     and they continued to press their intention to slate a referendum?

15        A.   I know that the leadership of the SDA, headed by Mr. Izetbegovic,

16     did not accept what Mr. Cengic had achieved with you and that it all fell

17     through.

18        Q.   Thank you.  In the Serbian version, it begins at the bottom,

19     under number 21, so please have a look at the left-hand bottom corner of

20     the Serbian version, where it says that the Assembly of the Republic of

21     Serbian People of Bosnia-Herzegovina adopted certain conclusions.  But in

22     the English version, I think we would need to move on to the next page.

23             THE INTERPRETER:  Interpreter's correction:  We should keep this

24     page in English.

25             THE ACCUSED: [Interpretation] In the Serbian version, we would

Page 13637

 1     need the next page.

 2             MR. KARADZIC: [Interpretation]

 3        Q.   I will just re-tell this, so I wouldn't read everything.  Anyone

 4     can read it.

 5             Point 1 talks about our position; namely, that the decision to

 6     slate a referendum was unlawful, that it was adopted against the

 7     positions of one of the constituent peoples, and that it can only oblige

 8     these other two peoples or that it would have to do with them expressing

 9     their will.

10             Point 2:

11             "Assembly of the Serbian People in Bosnia-Herzegovina will

12     continue its efforts to find the best solution for democratic transition

13     of Bosnia-Herzegovina and best position for every of three nations on

14     their common meetings.  In case of reaching common solution, then the

15     Assembly of the Serbian People in Bosnia-Herzegovina could accept

16     referendum as democratic way for citizens and peoples of

17     Bosnia-Herzegovina to declare their will and reconfirm reached

18     agreement."

19             Mr. Prstojevic, was this Serbian position something that was

20     widely known to the public in Bosnia-Herzegovina, including our officials

21     on the ground?

22        A.   Yes, it absolutely was well known to everyone, all the leaders

23     and the people as well, because at the time the people very carefully

24     followed what was going on in the Republican Assembly.

25             THE ACCUSED: [Interpretation] Thank you.

Page 13638

 1             Can this document be admitted?

 2             JUDGE KWON:  Yes.

 3             THE REGISTRAR:  Exhibit D1185, Your Honours.

 4             THE ACCUSED: [Interpretation] Could we now please see 1D3069 so

 5     that we can see how, a week before the referendum, you addressed the

 6     journalists and explained our position.

 7             MR. KARADZIC: [Interpretation]

 8        Q.   Do you recognise this statement from the press conference?

 9        A.   I do.

10        Q.   Is this your signature at the bottom?

11        A.   It is.

12        Q.   Point 1 says:

13             "The Serbian people will not turn out for the scheduled

14     referendum, nor will it participate in its work."

15             That means that there wouldn't even be observers at the election

16     posts; correct?

17        A.   Yes.

18        Q.   Point 2 says:

19             "The Serbian people and the SDS of Bosnia-Herzegovina will not

20     present any obstacles to the Muslim people, or any other people,

21     partaking in the referendum if they demonstrate an interest in it.  We

22     will respect the will of other peoples."

23             And point 3, similar to point 4:

24             "In its future work and political activity, the SDS will fully

25     respect the will of the Serbian people and the leadership of the SDS of

Page 13639

 1     BH, in the interest of seeking a peaceful, durable and just solution for

 2     life, work and political activity in our Bosnian and Herzegovinian

 3     lands."

 4             Was this a sincere and fully applied position of the Serbian

 5     people and the local authorities on the ground?

 6        A.   Yes, it was our sincerest position that we held on to as a matter

 7     of principle in the entire period preceding the war and even during the

 8     initial stages of the war.  It was always our priority to try to achieve

 9     a peaceful resolution in any way that the leaderships would agree at the

10     republican level.  We always said that it was something that we would

11     honour, and until such a time we strove to keep the peace and security of

12     all citizens.

13        Q.   Thank you.  Do you remember that we had power in 37 out of 109

14     municipalities in Bosnia-Herzegovina?

15        A.   I wouldn't know exactly the number of municipalities in which we

16     held power of the roughly 109 municipalities in Bosnia-Herzegovina, but I

17     do know that in some municipalities, we had one.  But I don't know the

18     exact numbers.

19        Q.   And is it correct that the territory of Bosnia-Herzegovina with

20     the Serbian majority spreads over more than 60 per cent of the territory

21     of BH?

22        A.   That is correct, for the reason that the Serbs were sparsely --

23     populated sparsely the areas where they lived.  Even in Sarajevo, it was

24     the same.  It was a larger area where the ethnic Serbian territories are.

25     Then the areas where the Muslims are the majority, they are the majority

Page 13640

 1     only in the urban parts, and all the surrounding settlements of the city

 2     have the Serbian majority.  That means they are not the absolute --

 3     absolutely dominant ethnic group, but they are the majority in all the

 4     surrounding municipalities.

 5        Q.   Thank you.  Do you know whether anywhere in Bosnia-Herzegovina we

 6     did not want to provide election lists, electoral rolls, or the

 7     infrastructure, or made any obstructions for the referendum?

 8        A.   I'm not aware of that.  And in Ilidza, we did not obstruct this

 9     in any way, so this is 100 per cent correct.

10             THE ACCUSED: [Interpretation] Thank you.

11             Can this document be admitted?

12             JUDGE KWON:  Yes.

13             THE REGISTRAR:  Exhibit D1186, Your Honours.

14             THE ACCUSED: [Interpretation] Thank you.

15             Can we now please have 65 ter 1007.

16             MR. KARADZIC: [Interpretation]

17        Q.   Do you remember that on the 18th of March, an agreement was

18     definitely reached, the so-called Lisbon Agreement, the basis of which

19     was the Carrington-Cutileiro Plan about transforming Bosnia into three

20     ethnic republics?

21        A.   Yes, I remember that that was in mid-March and that an agreement

22     had been reached, and it was a great relief for the whole people, for all

23     the people in Ilidza and wherever else I was moving.  But as we know,

24     later on the Muslim leadership rejected this agreement.  The Serbs would

25     say they had changed their minds, when you accept it and then later on

Page 13641

 1     you say, Well, I cannot accept it any longer.  And everything fell

 2     through.

 3        Q.   Here, we have a document from the Executive Board of the

 4     Serbian Democratic Party, signed by Mr. Dukic, in which there is a

 5     request that the party be informed about the areas which can be included

 6     in the Serbian municipalities.

 7             Paragraph 2 says that:

 8             "The projection of the territory of the Serbian municipality

 9     should comprise the local communes and populated areas, or parts of

10     populated areas, which will become part of the Serbian municipality."

11             And the last sentence says:

12             "... by Tuesday, the 17th of March, 1992, at the latest."

13             Do you remember that at the time, all three sides were vying to

14     declare, as fast as they could, what their ethnic entities would

15     comprise?

16        A.   Well, frankly speaking, I don't remember this well and I don't

17     remember this memo, but I know that, generally speaking, in Ilidza at

18     this time, there was already a sort of tacit division, that the Croats

19     had sort of their own municipality which covered the area of two local

20     communes.  We assessed that we had 13 or 11 local communes, and there

21     were two that we shared with Muslims, and the Muslims at the time

22     dominated in six local communes.  However, as opposed to the Serbs and

23     the Croats, they believed that they had the right to hold all of Ilidza.

24     They were not satisfied with having just the local communes where they

25     were the majority population, that is to say, where their population made

Page 13642

 1     up more than 90 per cent of the population.

 2             And I am generally aware of the Cutileiro Plan, and I have, to

 3     this day, the maps which were part of the plan.

 4        Q.   Thank you.  Am I right if I say that this did not have to mean a

 5     division with borders, but rather administrative division about who would

 6     be wielding power in the Serbian-populated areas, or the Croat, or the

 7     Muslim-populated ones?

 8        A.   Yes, it was implied that certain territories would be ruled by

 9     specific authorities.

10        Q.   Thank you.  Would you agree that this request was made in the

11     context of this conference and the expected date of the 18th of March,

12     when everyone should have voted?

13        A.   I do.

14             THE ACCUSED: [Interpretation] Thank you.

15             Can this be admitted?

16             JUDGE KWON:  Yes.

17             THE REGISTRAR:  Exhibit D1187, Your Honours.

18             THE ACCUSED: [Interpretation] Could we now please have

19     65 ter 11698.

20             MR. KARADZIC: [Interpretation]

21        Q.   Do you recognise these minutes and these people, and are these

22     the minutes from the meeting of the Municipal Board of the SDS for

23     Ilidza?  Trnovo, but it was held in Ilidza; correct?

24        A.   Just bear with me for a second.  I have to read it, because I

25     can't see it well.  I do not see my own signature, and there are some

Page 13643

 1     other elements that I do not see.

 2             Yes, this is a document drawn up by the members of the

 3     Municipal Board of the SDS in Trnovo, because at the time there were

 4     requests made by the deputies and members of the Municipal Board of the

 5     SDS in Trnovo that the ethnic areas of Trnovo should be joined to the new

 6     Serbian municipality of Ilidza which was about to be formed.  At the same

 7     moment, there were such requests by the deputies and members of the

 8     Municipal Board of the SDS from the Novi Grad municipality because of the

 9     37.000 Serbs from the Novi Grad municipality.  A new municipality, a

10     small municipality, Rajlovac, would be formed comprising 3.000 people.

11     At the same time, the representatives of the Kiseljak municipality, which

12     bordered our municipality in the west, where there were around 800 Serbs,

13     who were living right along our border and who requested that they should

14     also join the Ilidza municipality.  And there were also talks about the

15     Hadzici municipality, but the president of the SDS from Hadzici,

16     Mr. Ratko Radic, said that they wanted to be an independent municipality.

17             And these activities of the legitimate representatives from these

18     three neighbouring municipalities, and the Ilidza SDS representatives,

19     headed by me in this period, were an expression, primarily, of a great

20     anxiety and fear of the Serbs from this area about what would happen with

21     them, because they were practically nowhere.  I was personally in charge

22     of these activities, I co-ordinated them, and we can see here that a

23     certain division of duties or posts was already agreed and which

24     positions people from Trnovo would have in the new Joint Assembly to be

25     established on the 5th of April.  And these activities, which can be seen

Page 13644

 1     from the minutes and which were ongoing at the time, had nothing to do

 2     with the Instruction 093 about setting up crisis staffs and so on.  This

 3     was practically a self-organised activity at a local or, let me say,

 4     regional level, because the Serbian municipality of Ilidza will be

 5     formed.  It was rather large, in terms of territory, but sparsely

 6     populated.

 7        Q.   Thank you.  Is it correct that according to our Constitution and

 8     laws, the local communes were authorised to request to belong to a

 9     different municipality, administratively; to be joined, in administrative

10     terms, to another municipality if there were conditions for that?  Was

11     that part of the responsibilities of a local commune?

12        A.   Yes, that is true, and I think I'm competent to confirm that

13     because since 1977, since when I have been living in the area of the

14     Ilidza municipality and the Kasindol Local Commune, I was a member of the

15     Council, and Assembly, and other organs of the Kasindol Local Commune.  I

16     was the last president of the Socialist Alliance of the working people in

17     Kasindol.

18             And I want to emphasise that I was a member of the League

19     of Communists since I was a pupil in 1967, so I'm very well aware of the

20     way in which the local communes operated.

21             Since 1977, when I built my house in the Kasindol Local Commune,

22     nothing happened there without my active involvement.  The local communes

23     had authority about deciding on street names.  They were authorised to

24     request reorganisation if that was in accordance with their interests;

25     that is to say, achieving the rights of the working people and citizens,

Page 13645

 1     as the formulation was used at the time.  So, therefore, I can answer in

 2     the positive and say that this request was practically in accordance with

 3     all that.

 4        Q.   Thank you.  Do you remember that Mr. Izetbegovic withdrew his

 5     approval of the Lisbon Agreement on the 25th of March?

 6        A.   I do not remember the date, but I do know that the

 7     Lisbon Agreement fell through because of the Muslim leadership, because

 8     it had changed its mind.

 9        Q.   Thank you.  Am I right if I say that you proclaimed the Serb

10     municipality politically on the 3rd of January, I believe, 1992, and up

11     until the end of March it wasn't actually constituted and did not start

12     functioning?

13        A.   Well, you see, Mr. President, this is the way it was:  On the 3rd

14     of January, 1992, we established the Assembly of the Serb People of the

15     Municipality of Ilidza.  We elected the president of the Assembly and a

16     secretary.  I think that two or three decisions were reached, and that

17     was it.  After that, a press conference was held, and we didn't do

18     anything more than that.  So that was a formal declarative assembly of a

19     preventive nature.  The real one would be the one that would be

20     established only later during the war.

21             THE ACCUSED: [Interpretation] Thank you.

22             Can this be admitted?

23             JUDGE KWON:  Yes.

24             THE REGISTRAR:  Exhibit D1188, Your Honours.

25             THE ACCUSED: [Interpretation] Thank you.

Page 13646

 1             Can we now have 65 ter 07177, and then page 21 in e-court.

 2     Unfortunately, this only exists in English, so I'm going to read it out,

 3     and the interpreter will interpret it.

 4             Page 21, please.  Oh, that's it, yes, all right.

 5             MR. KARADZIC: [Interpretation]

 6        Q.   I'm going to read from that answer that you provided:

 7             [In English] "Look, political activity was going on in Bosnia and

 8     Herzegovina aimed at finding a peaceful solution to the situation in

 9     Bosnia-Herzegovina.  That's what our leadership was involved in.  And the

10     Ilidza leadership went along with that idea at all levels.  At the local

11     level, together with people from other parties, HDZ and SDA, we had talks

12     in order to ensure peace in the area of Ilidza, and no matter what sort

13     of agreement could be reached by our leaders, we would have accepted it.

14     And throughout the war, the Croats and the Serbs stuck to that agreement,

15     but due to an order of the staff commander of the Territorial Defence of

16     Bosnia-Herzegovina, I think his name -- I did mention his name, but

17     I think the order was dated the 14th of April, 1992, and the order was

18     given to carry out an attack, and it was meant to be carried out by the

19     Green Berets and the Patriotic League, that is to say, the Muslim forces,

20     and they were ordered to attack Ilidza, and they did attack on the

21     22nd of April.  We had 11 people killed and 56 were injured."

22             [Interpretation] This is a page of your transcript in the

23     proceedings against Mr. Krajisnik.  Do you stand by what you said?

24        A.   This is absolutely correct.  What was said here and what I said

25     then was stated in several places.  This is what I have to add:

Page 13647

 1             We always tried, number 1, to accept everything that was agreed

 2     upon at the top.  Secondly, regardless of the security situation around

 3     Ilidza, in Sarajevo, when the war broke out, where people were losing

 4     their lives, we tried to maintain peace and security for the citizens.

 5     Had there not been external influences, regardless of the fanaticism of

 6     the Sandzaki from Sokolovic Kolonija, everything would have ended with

 7     just minor trouble.

 8             As a matter of fact, in some parts of Ilidza, the last local

 9     commune, Rakovica, in the north-western part, the local Muslims never

10     attacked us.  However, I saw many orders during the war.  We were

11     attacked by Muslims from Visoko, from other municipalities in

12     Central Bosnia, and through the municipality of Kiseljak if the HVO would

13     allow them to pass through that municipality.

14             The order to attack Ilidza was issued by the commander of the

15     Staff of the Territorial Defence of BiH, Hasan Efendic, I think that was

16     his name, and it is dated the 14th of April.  Our intelligence service

17     found out, and the chief of the police station, Mr. Tomo Kovac, sometime

18     around the 17th of April, informed me as well.  And the vice-president,

19     Nikola Koljevic, who sat in the Ilidza Hotel, informed us about this.

20             And then at the session of the Crisis Staff, the Crisis Staff was

21     informed, the Crisis Staff of the Serb Municipality of Ilidza.  And our

22     commanders in the TO, who mostly held the rank of captain, reserve

23     captain - there was also a reserve major - they knew that what was

24     supposed to be set was only the day and time of the attack.

25             I know, at the time, how disturbed we were by information coming

Page 13648

 1     in about attacks by the Berets, by the HOS, by various units that were

 2     technically equipped in this and in that way.

 3             This is what I'm trying to say:  From the 3rd of April onwards,

 4     when the war started, I and the TO commanders did not sleep at home.  We

 5     slept in Ilidza, the Command of the Territorial Defence, a new building

 6     that we took for ourselves, in a new building.  We slept there.  We were

 7     there day and night, vigilant, and we were waiting for that attack.

 8        Q.   Thank you.  We have documents.  We'll get to that.

 9             Could we please have the next page, 22, so that we finish dealing

10     with this document.

11             From line 7, I'm going to read it out:

12             [In English] "And actually in the field, in many places, it had

13     not been the case because Muslims basically, when we talked about the

14     Ilidza area, and I've got proof of that because Muslims were better armed

15     than we were, and they took over all the weapons of certain structures

16     from the former Territorial Defence and special units of MUP at Krtelji."

17             [Interpretation] Is it correct that the Muslim component in

18     Ilidza had seized the weapons of the Territorial Defence and took the

19     weapons, equipment and APCs from the MUP from Krtelji, where the special

20     unit had been headquartered?

21        A.   Absolutely.  It is absolutely correct that the Green Berets and

22     the Muslims, taking advantage of a certain agreement between the

23     leadership of the MUP regarding division on the 1st of April, they took

24     advantage of the situation.  And on the 3rd of April, around 1.30, while

25     I was having coffee with the president of the SDA and the president of

Page 13649

 1     the municipality, Mahmutovic, they entered the special base, Krtelji,

 2     that is, in the territory of the municipality of Ilidza, Donja Kotorac.

 3     Actually, it is in the middle part of Kotorac that is not populated.

 4     They took weapons without anybody's knowledge, because the Serb special

 5     forces, as far as I know, were so frightened that they didn't go to work

 6     on the 2nd.  On the 3rd, when they hadn't arrived, this was a sign for

 7     the Green Berets to enter to get the APCs to Butmir and to Gornji

 8     Kotorac.

 9             We found out about that later.  On the 3rd, I didn't know about

10     this.  And they took out everything that they could on that day.  I found

11     out about that only at twilight, you know, when darkness falls.  You know

12     when it gets dark.  I received this information accidentally on the 3rd,

13     and I immediately took measures.  Between the 3rd and the 4th, there was

14     even a conflict because of that special unit there.

15             It is correct we have information from the political party called

16     the SK Movement for Yugoslavia.  The Muslims in that area at that moment

17     were much better armed than we were.  We did not have any combat

18     equipment, except for small arms and anti-tank equipment.  They would

19     even get weapons from the TO from Pazaric, via Bjelasnica and Igman.

20     They even got some tanks out into Sokolovic Kolonija.

21             THE ACCUSED: [Interpretation] Thank you.

22             Your Excellencies, is the transcript sufficient or should we have

23     these two pages admitted as well?

24             JUDGE KWON:  It's up to you.

25             THE ACCUSED: [Interpretation] Well, these two pages could be

Page 13650

 1     admitted.

 2                           [Trial Chamber confers]

 3             JUDGE KWON:  The less exhibits, the better we will be off.  In

 4     that sense, I don't think it will be necessary to admit this.

 5             THE ACCUSED: [Interpretation] If the transcript is sufficient, we

 6     don't really need to pile up documents.

 7             JUDGE KWON:  Yes, Mr. Tieger.

 8             MR. TIEGER:  I agree, in principle, that sometimes the submission

 9     of a transcript -- a relevant transcript can obviate the need for longer

10     questioning, and efficiently ends up resulting.  In this particular case,

11     I would only -- I don't have a particular objection.  I leave it to the

12     Court to assess the efficiency aspects, but I believe that that

13     discussion continued into the next day.  So if this is going to be

14     submitted, we will be reviewing the transcript to see if there are

15     further portions of the Krajisnik testimony relevant to this particular

16     issue and to this discussion and whether it's only a truncated portion.

17             JUDGE KWON:  Yes, that may be a subject for your re-examination.

18     I don't know.

19             Let's please -- let's continue, Mr. Karadzic.

20             THE ACCUSED: [Interpretation] Thank you.

21             Can we have 65 ter 1020.

22             MR. KARADZIC: [Interpretation]

23        Q.   Do you remember, Mr. Prstojevic, that the Muslim part and the

24     Croat part of the Presidency, despite the disagreement of Mr. Koljevic

25     and Mrs. Plavsic, declared general mobilisation on the 4th of May?

Page 13651

 1        A.   I remember this very well, absolutely, because practically this

 2     was the beginning of the war.  In a way, it was a declaration of war.

 3     The Presidency called that -- the people called that Presidency the rump

 4     Presidency because it had no Serb representatives.  I remember that in

 5     detail.  If necessary, I can describe all of it.  I know all of that by

 6     heart.  I know what Mr. Alija Izetbegovic ordered.  This is practically a

 7     military matter, but that is where my knowledge seems to be the best.

 8             THE ACCUSED: [Interpretation] Thank you.

 9             Can we have the second part of the page.

10             MR. KARADZIC: [Interpretation]

11        Q.   This is a letter of our negotiating team, that is to say,

12     Mr. Krajisnik and myself.  This is addressed to Ambassador Cutileiro, and

13     you can see now that we are telling him that we are facing a civil war,

14     and that the situation is dramatic, and that they -- and that we were not

15     sure that we would be able to continue contacts with him, and that

16     Izetbegovic gave an order for mobilisation and a march to Bijeljina, a

17     town torn by conflict.  At the same time, strong-armed forces from

18     Croatia are attacking Serb areas in Bosnia and Herzegovina and are

19     killing people.  Izetbegovic took some very irresponsible moves,

20     mobilising the whole population.  The state does not function, chaos is

21     accelerating.  This is also the way in which Mr. Izetbegovic is

22     derogating the results of our talks.

23             "Could you please help by exercising your influence ..."

24             Do you remember that on the 26th of March, just before this, the

25     25th and 26th of March, there were entire columns of the National Guards

Page 13652

 1     Corps and other paramilitary formations that crossed the border near

 2     Bosanski Brod and committed a massacre, a well-known massacre, in

 3     Sijekovac?

 4        A.   Well, you see, all the citizens of Bosnia-Herzegovina know this,

 5     regardless of the fact that information was being hidden from the media.

 6     But I didn't explain something else a moment ago.

 7             On the 4th of April [Realtime transcript read in error "May"],

 8     Mr. Izetbegovic declared general mobilisation of units of the

 9     Territorial Defence and Civilian Protection.  Then, number 2, the reserve

10     forces of the MUP.  3, weapons and military equipment were being taken

11     out of JNA and MUP depots.  It is quite clear that in this way, the JNA

12     and the reserve force of the MUP were attacked, in a way, and that war

13     was declared on the Serbian people and the Croatian people, because he's

14     not the commander of the Croatian people, because the Croatian part of

15     the Presidency, on the 8th - I remember that date - declared the

16     establishment of the HVO army, the army of the Croatian people, of the

17     Croatian community.

18             Everyone knows about Sijekovac.  It was the regular units of

19     Croatia, I believe, that committed a terrible massacre of the civilian

20     population, assisted by locals.  But that's the way it is among the

21     people.  If that kind of thing happened, people did not expect it to

22     happen in Sarajevo.  They thought it was far away.  But thunderstruck

23     already on the 4th of April, especially in the urban area.  That is why

24     the 4th of April is called the Day of Blood.

25        Q.   Thank you.  When we are saying that from Croatia, it was the

Page 13653

 1     forces that were crossing the border, do you remember that the

 2     Croatian Army entered the area of Kupres, slaughtering all the Serbs that

 3     they could lay their hands on in the village of Malevo [phoen]?

 4        A.   Well, you see, Mr. President, I cannot remember the date.

 5     I think that General or Colonel Galic at the time was in this area.

 6     Then, later on, he would be assigned to be the commander of the

 7     Sarajevo Romanija Corps.  And I know something about this from my

 8     conversations with him, but we had big problems where we were.  We were

 9     following what the enemy was doing, and even though we had a TV at the

10     TO Staff, we did not have enough time to watch TV.  That was where we

11     slept, worked, spent the nights, but I'm not really in a position to tell

12     you any details about Kupres.

13             THE ACCUSED: [Interpretation] Thank you.

14             Can this document be admitted?

15             JUDGE KWON:  Yes.

16             THE ACCUSED: [Interpretation] I think that there is a stamp

17     confirming that it was received where it was sent.  I think that's on the

18     third page.

19             JUDGE KWON:  Exhibit D1189.

20             THE ACCUSED: [Interpretation] Thank you.

21             Can we now please have 65 ter 16771.  I believe we also have a

22     translation.  I believe that 65 ter has a translation, so if we could

23     please find it.

24             I will read it, but I will also show another text which carries

25     this as a new piece of news from "SRNA."

Page 13654

 1             MR. KARADZIC: [Interpretation]

 2        Q.   Is it correct that it says here:

 3             "Yesterday, on the 10th of April, 1992, a session of the

 4     Executive Board of the Municipal Assembly in Ilidza was held at which,

 5     among other issues, the general situation in the area of Ilidza

 6     municipality was discussed"?

 7             Can we please have 1D3053.  It's the same, but formulated as a

 8     news report, and it has an English translation.  1D3053.  Could we please

 9     have the English version as well.

10             It says here:

11             "At the latest session of the Ilidza Executive Board, held on the

12     10th of April, the general situation in Ilidza municipality was examined.

13     Mr. Nedjeljko Prstojevic informed the municipal government that on the

14     5th of April this year, the Serbian Assembly founded and set up the

15     Serbian Municipality of Ilidza with all organs of authority and

16     administration.

17             "Mr. Nedjeljko Prstojevic, the president of the

18     Serbian Municipality of Ilidza, pointed out that the peace and security

19     in the area depended entirely on the Muslims and the Croats.  The Serbs

20     most certainly will not begin anything or disturb the peace in the area

21     by any action.  They will not do so even if, for instance, the last Serb

22     were to move out of the Sokolovic Kolonija settlement, as long as this is

23     done in a peaceful and civilised fashion.  Thanking the Muslims and the

24     Croats for their conduct so far, he proposed that the representatives of

25     all three peoples should meet in order to preserve the current security

Page 13655

 1     in the area."

 2             Does this piece of news from the "SRNA" agency faithfully

 3     reproduce this statement for the public which we saw before this?

 4        A.   Yes, it mostly reproduces our statement faithfully, though there

 5     is an imprecision here at the beginning; that I informed the

 6     Executive Board.  At the meeting held on the 5th of April, we had set up

 7     all the organs, and primarily the Executive Board; first, the Assembly

 8     organisations and then the Executive Board, that is to say, the

 9     government and all the others that were necessary, so that it was

10     practically a joint session of the president of the municipality with the

11     Executive Board.  And it is completely clear that this was our position,

12     the position we had before the war, during the war.  And as for Ilidza,

13     the war could have ended at any given moment, because our army would stop

14     shooting at the moment when the Muslim army wasn't shooting.  No one

15     needed to reach any sort of agreement.  The war would have ended by

16     itself, because no one wanted to die, and we suffered the greatest number

17     of victims in Republika Srpska.  And what about municipalities that had

18     195.000 inhabitants, and we had only 25.000?

19        Q.   May I then wrap it up, Mr. Prstojevic.

20             You adopted a political declaration on setting up the Serbian

21     municipality of Ilidza on the 3rd of January, but up until the 5th of

22     April, it was not functioning; is that correct?

23        A.   That is absolutely correct.

24        Q.   On the 3rd of April, the Muslims, the Green Berets and others

25     attacked Krtelji or, rather, without any resistance, went in and

Page 13656

 1     devastated Krtelji, because they took away all the weapons and

 2     ammunition; correct?

 3        A.   Yes, that's correct.  They entered without any resistance, and

 4     later on they would set fire to it.  At the moment when we tried to

 5     oppose them, they set on fire the entire MUP special unit, and it will

 6     burn down.

 7        Q.   Thank you.  Can you just help us now?  When was the Crisis Staff

 8     formed, because it says here that this is the Information Service of the

 9     Crisis Staff?

10        A.   Well, look, we were doing this as we went along.  My main

11     responsibilities in this period were what I did by authority that I was

12     given by the Assembly on the 5th of April.  I was authorised by the

13     Assembly to make decisions, issue instructions and orders, and do

14     everything else as necessary that would be aimed at the defence and

15     self-defence; that is to say, protecting the territory.  And, formally, I

16     would do it on behalf of the Crisis Staff, but the actual

17     Municipal Crisis Staff was only formed by me on the 10th of April, at a

18     meeting of the Municipal Board, when I believe I also set up our press

19     centre.  I could see that the previous document was signed by

20     Ranko Mandic, who was chief of the press centre.

21             THE ACCUSED: [Interpretation] Thank you.

22             Your Excellencies, could these be admitted, perhaps both of these

23     as one number?

24             THE INTERPRETER:  Could the accused please repeat the numbers of

25     the documents.

Page 13657

 1             THE ACCUSED: [Interpretation] I'm informed the documents are

 2     similar, and in terms of documents, they are virtually identical.

 3             JUDGE KWON:  We cannot rely on that submission.

 4             So do you tender both the SDS announcement and "SRNA" news

 5     clipping, or is "SRNA" sufficient?

 6                           [Trial Chamber and Registrar confer]

 7             JUDGE KWON:  We have the translation, we have them both.  We'll

 8     admit them both.

 9             THE REGISTRAR:  As Exhibits D1190 and D1191 respectively,

10     Your Honours.

11             THE ACCUSED: [Interpretation] Thank you.

12             Could we please have 65 ter 01502.

13             MR. KARADZIC: [Interpretation]

14        Q.   Can you tell us whether what is announced here is that the

15     commander of the Territorial Defence,

16     Colonel-General Drago Vukosavljevic, was relieved of his post and that

17     Hasan Efendic was elected to this position, with the task to drag Serbs

18     into the war against the Serbs, as this document says?

19        A.   Yes, it's completely correct that Hasan Efendic was appointed to

20     this position.  And this is a statement from our Information Service

21     which was already working, though people who were appointed to certain

22     positions would be appointed on the 10th of April.  But it was already

23     active.

24        Q.   Thank you.  Was it the very same Hasan Efendic who, several days

25     after his appointment, would issue the directive for an all-out attack

Page 13658

 1     against the Serbs?

 2        A.   Yes.  We did see this order in the war.  An attack against the

 3     Yugoslav People's Army was practically ordered, an attack on the depots

 4     of the JNA and the MUP.  And the third point was an order to attack, with

 5     the excuse of opening up the axis Ilidza-Hadzici, because Ilidza cuts

 6     through this area.  And according to the sources that I'm familiar with,

 7     this was the first order for attack against certain ethnic -- that is to

 8     say, Serb-populated areas, regardless of what was happening in Bijeljina,

 9     in Sijekovac and Kupres.  But in this case, there was an order by the

10     commander from the very top, which means that the highest political

11     leadership of the Muslims had to know about this.  And this was the

12     number-one person, that is to say, the commander of the

13     Territorial Defence Staff of Bosnia-Herzegovina, but just the Muslim part

14     of Bosnia-Herzegovina.

15             THE ACCUSED: [Interpretation] Thank you.

16             Can it be admitted?

17             JUDGE KWON:  Yes.

18             THE REGISTRAR:  Exhibit D1192, Your Honours.

19             THE ACCUSED: [Interpretation] Could we now please have 1D3070.

20             MR. KARADZIC: [Interpretation]

21        Q.   Do you recognise your signature in this document, Mr. Prstojevic?

22        A.   I do.

23        Q.   Was your military logic from the other document, the A and B

24     options, was that something that was accepted?  You were the commander of

25     the Crisis Staff at this moment?

Page 13659

 1        A.   Yes, I was.  But when this Crisis Staff was set up, we forgot

 2     these instructions.  It does not exist anymore, and I do not remember it

 3     and did not implement it.  Rather, on the basis of the Assembly's

 4     decision and the newly-established Serbian municipality of Ilidza, I set

 5     up the Crisis Staff according to a certain organisational and

 6     establishment model.  It comprised state structures and military

 7     structures, so practically the political elements were the fewest.  And

 8     this was practically already in accordance with the strategy of

 9     All People's Defence and Social Self-Protection, and for that purpose, I

10     brought it here.  This is the strategy.  It is the war book, and on the

11     22nd of April, the fifth column, it is known exactly who and from which

12     house shot at it.  It was a sniper.  But that was the biggest document

13     which regulated the combat of Territorial Defence units.  And then there

14     are documents to be implemented at lower levels, at the level of

15     companies and detachments and the smallest units.

16        Q.   Thank you.  Can you tell us who is under number 10?  Obviously,

17     they couldn't decipher it.  Was it the chief of the Public Security

18     Station, by his function?

19        A.   Yes, number 10 is the chief of the Public Security Station,

20     Tomislav Kovac, and number 11 is the commander of the Territorial Defence

21     Staff, Captain Obrad Popadic.  After him is the chief of the

22     Communications of the Territorial Defence, Vaso Jeremic.

23        Q.   Jeremic, rather than Jeremija, which would be a first name.

24     Jeremic.

25        A.   Yes, Vaso Jeremic.  After him is Rade Ristic, who was in charge

Page 13660

 1     of civil affairs from the eastern part, and then he is followed by

 2     Commander Novica Vulovic.  He was the commander of the Territorial

 3     Detachment of Ilidza Centre.  I cannot read who the last one is.

 4        Q.   Petko or Petar?  One Petar, it seems?

 5        A.   It could be, perhaps, one Petar Maksimovic, who was a

 6     commissioner for civilian affairs from the Blazuj Local Commune.

 7        Q.   Thank you.  Is it correct that you set up the Crisis Staff six

 8     days -- or, rather, for six days while the combat and fighting was raging

 9     in down-town Sarajevo?

10        A.   That is absolutely correct, because throughout Sarajevo there was

11     terrible shooting going on.  On the 4th of April, on the evening of the

12     4th, the Muslims used the combat equipment that they had seized from

13     Krtelji.  So from Butmir, they were firing at the centre of Ilidza, the

14     headquarters of the SDS, the SDA and the HDZ in Mala Aleja.  I was in

15     that building myself in the evening when APCs were firing at that

16     building and that area.

17             From the 4th onwards, Ilidza was being targeted all the time.

18     There was so much gun-fire that already in mid-April, they ran out of

19     ammunition.  We have information to that effect, we have proof of that.

20             THE ACCUSED: [Interpretation] Thank you.

21             Can this document be admitted?

22             JUDGE KWON:  Yes.

23             THE REGISTRAR:  Exhibit D1193, Your Honours.

24             THE ACCUSED: [Interpretation] Can we have 65 ter 9387.

25             MR. KARADZIC: [Interpretation]

Page 13661

 1        Q.   Can you recognise this document?  This is immediately after the

 2     Crisis Staff was established.  Can you tell us what this document is?

 3        A.   This is a press release of our Crisis Staff, or, to be more

 4     specific, of the Press Centre, the Information Service.  And it is signed

 5     by Nedeljko Zugic, a writer.  He is providing information here on general

 6     mobilisation of the population, and he is calling upon the Serbs to

 7     report to JNA military units, to the units of the Serb MUP and the units

 8     of the Serb Territorial Defence.  That is the only way for you to defend

 9     yourselves, your homes, your country and your families, from the assaults

10     of Alija's army.

11        Q.   Thank you.  After all, we can all see this.

12             Let me ask you this, Mr. Prstojevic:  According to our laws that

13     were in force then, were these the only legitimate and legal military

14     formations; that is to say, the JNA, the MUP and the Territorial Defence

15     units?

16        A.   That is absolutely correct.  I would just like to add one thing

17     here.

18             Because we were under threat, and because mobilisation was

19     declared by the Muslim leadership, I personally had to declare

20     mobilisation immediately on the 6th.  This is stepping up the

21     mobilisation effort.  It became even more topical at that point.

22        Q.   Is it correct that according to our law, the president of the

23     municipality is at the same time president of the Council of Defence for

24     that municipality and, practically, the supreme commander of the

25     Territorial Defence in that municipality?

Page 13662

 1        A.   That's the way it was before the war too.  The president of the

 2     municipality is the president of the Committee for All People's Defence

 3     and Social Self-Protection.  The top officials of that municipality are

 4     members of that committee, as are officials of the National Defence and

 5     Territorial Defence.  Practically, the president of the municipality is

 6     at the very top of the pyramid.  He is the commander.  Sometimes there is

 7     a reference to the president, sometimes there is a reference to the

 8     commander, but basically it is a commander.

 9        Q.   Thank you.  So in accordance with that law, he has the authority

10     to declare general mobilisation; right?

11        A.   That is correct, but this is what I was guided by here.  On the

12     basis of this strategy of DSZ and immediate threat of war, the Assembly

13     said what they had to say, and then I, as an officer, went along the

14     lines of Territorial Defence.

15        Q.   Thank you.  Is it correct that at that moment, you did not have

16     any other military formations except for the JNA, the MUP and the

17     Territorial Defence?

18        A.   It is absolutely correct.  No one can prove that there was any

19     paramilitary unit in April.

20        Q.   Thank you.

21        A.   We have specific information from three meaningful groups, who

22     they were and what they were doing.  I didn't agree with the Prosecutor

23     on that the other day, so I would like to have that corrected.  The man

24     was diluted.

25        Q.   So it is only the legal formations that are being called upon

Page 13663

 1     here; right?

 2        A.   That is absolutely the case.  You can only use legal formations

 3     to defend yourself.

 4             THE ACCUSED: [Interpretation] Thank you.

 5             Can this be admitted?

 6             JUDGE KWON:  Yes.

 7             THE REGISTRAR:  D1194, Your Honours.

 8             THE ACCUSED: [Interpretation] Thank you.

 9             1D3071, can we have that now, please.  It's not a very good copy.

10             MR. KARADZIC: [Interpretation]

11        Q.   Could you please take a look at this document.  It seems that

12     someone else signed it on your behalf.  I'm not sure that this is your

13     signature down here, but it is a document of the Serb municipality of

14     Ilidza.  Can you please tell us about this, especially paragraph 4?

15        A.   The day is the 10th of April.  There were many meetings taking

16     place.  Many decisions were taken.  A crisis staff was established.  The

17     head of the Press Centre was appointed, and, inter alia, this was

18     released, this document.  And it is my signature down here, although it

19     is underneath the seal.

20             Would you please focus your attention on page 2.  I -- or,

21     rather, paragraph 2.  I clashed with one of the investigators on this.

22     She said that it suited me to have a lack of order, anarchy, and things

23     like that going on.  I felt that that was really brazen.  I found that it

24     was work, order and discipline that suited me, and organisation too.  I

25     cannot read this either, I cannot read it, it's illegible, but I know all

Page 13664

 1     of that by heart.  That's what should prevail in the work of the crisis

 2     staffs.

 3             I cannot read this further on, because we have a developed

 4     structure by now.  In 20 or so local communes where we were, we were

 5     developing crisis staffs.

 6             And then paragraph 4, what is being forbidden is taking -- I

 7     cannot read this, but I know what it was.

 8        Q.   "Actions," that is what is written here.

 9        A.   "... actions without the approval of the crisis staffs and

10     Territorial Defence ..."

11        Q.   "In particular"?

12        A.   "... in particular, from fire-arms, except when this is done with

13     the aim of protecting one's own lives."

14             And I think that it also says "the lives of working people and

15     citizens."

16        Q.   Thank you.  So this was one of the first orders -- this is the

17     10th of April, isn't it, or the 30th?  It's the 10th?

18        A.   This is the 10th, and practically the OTP heard a series of my

19     intercepted conversations where I say, Run, work, and then things will be

20     fine.  And that reflects my views as a railwaysman who worked in

21     accordance with international rules regulating the functioning of

22     railroads.

23        Q.   It is only the necessary defence of life that is referred to

24     here, right, Mr. Prstojevic?

25        A.   That is absolutely correct.

Page 13665

 1             THE ACCUSED: [Interpretation] Thank you.

 2             Can this be admitted?

 3             JUDGE KWON:  Yes.

 4             THE REGISTRAR:  Exhibit D1195, Your Honours.

 5             THE ACCUSED: [Interpretation] Thank you.

 6             Can we have 65 ter 08964.

 7             MR. KARADZIC: [Interpretation]

 8        Q.   If I tell you, Mr. Prstojevic, that on the 12th of April, we

 9     signed a cease-fire with Mr. Cutileiro -- well, cease-fire, cessation of

10     all operations, and on the same day, the 12th of April, Hasan Efendic

11     wrote that well-known directive, and the MUP probably sent it on the 14th

12     along their own chain, then this attack that was carried out on 13th,

13     does it seem to you like something that was not spontaneous at all, but

14     rather implementation of Efendic's directive?

15        A.   That's exactly the way it is.  This is a lesser attack.  But,

16     strategically, the moves of the Muslim leadership of the

17     Territorial Defence, or later the Army of BiH, are based on what the

18     leaderships agree upon.  You will see, on the 13th of May, exactly a

19     month after this date, they will immediately, within a day or two, carry

20     out awful attacks.  Again, the same thing.  Peace is agreed upon, but war

21     is waged.

22             THE ACCUSED: [Interpretation] Thank you.

23             Can this be admitted?

24             JUDGE KWON:  Yes.

25             THE REGISTRAR:  D1196, Your Honours.

Page 13666

 1             THE ACCUSED: [Interpretation] 1D3072.  It's not exactly from hour

 2     to hour, but it is from day to day that we are following the situation

 3     through documents.  1D3072.

 4             MR. KARADZIC: [Interpretation]

 5        Q.   Is this your signature down here?  Actually, no, it says "For,"

 6     F-o-r.  Somebody signed on your behalf?

 7        A.   Yes, Mr. Momcilo Ceklic, secretary of the Crisis Staff.  I can

 8     recognise his signature.

 9        Q.   Can you tell us what this document is?

10             "Halting the activity of all --"

11             It says up here:

12             "In view of mobilisation, all activities shall be stopped."

13        A.   Well, the text that I see here is practically illegible.  I read

14     one word out of three and then I realise what it is.  In English, you can

15     see it very nicely.  Why don't you read it in English, please, so that I

16     don't have to stutter and stammer.

17        Q.   I'll try to do it in Serbian:

18             "In view of the fact that general military mobilisation has been

19     carried out, on the basis of a demonstrated need and the authority I have

20     been given, and for security reasons, I hereby order: that in the

21     territory of the municipality of Ilidza, the activity of all state --"

22             Now I'm going to move on in English:

23             [In English] "... the activity of all state, socially-owned,

24     co-operative, private and other enterprises shall be suspended until

25     further notice."

Page 13667

 1             "... other enterprises shall be suspended until further notice.

 2             "2.  The activity of suburban public transport and --"

 3             [Interpretation] I don't see what kind of transport:

 4             [In English] " ... operating in the territory of Serbian

 5     municipality of Ilidza shall be suspended.

 6             "The following shall be exempt from this order:

 7             "A) food shops;

 8             "B) health-care institutions;

 9             "C)" something "of traffic."

10             [Interpretation] I have "city transportation."

11             Again, D is illegible.

12             And E is:

13             [In English] "Enterprises involved in supplying electricity.

14             "All enterprises exempt from this order shall operate to a

15     limited extent, and their activity will be regulated by supplementary

16     instructions."

17             [Interpretation] This was on the 14th.  Was this based on the

18     attack that took place on the 13th, Mr. Prstojevic?

19        A.   Yes, the attack on the 13th, but other attacks too.  It went on

20     all the time.  Fire was opened all the time along the entire front-line,

21     because the front-line was about 30 kilometres by then.  The territorial

22     units, practically the units of the reserve MUP, are facing each other.

23             THE ACCUSED: [Interpretation] Thank you.

24             Can we lower the Serbian version a bit.

25             MR. KARADZIC: [Interpretation]

Page 13668

 1        Q.   It seems to me that subsequently -- no, no, no.  Can we look at

 2     the top of the page, rather.

 3             Is this your signature up here, whereby you authorised this at a

 4     later stage?

 5        A.   Yes.

 6        Q.   In English, it says "Trbovic?"

 7        A.   No, no, it is my signature.  I verified it later on.  I was

 8     probably somewhere out in the field and the secretary signed on my

 9     behalf.

10             THE ACCUSED: [Interpretation] Thank you.

11             Can this be admitted?

12             JUDGE KWON:  Yes.

13             THE REGISTRAR:  Exhibit D1197, Your Honours.

14             JUDGE KWON:  Shall we take a break now, Mr. Karadzic?

15             THE ACCUSED: [Interpretation] We can deal with another one or we

16     can take a break, whatever you decide.

17             JUDGE KWON:  We'll have a break for half an hour.

18                           --- Recess taken at 10.30 a.m.

19                           --- On resuming at 11.01 a.m.

20             JUDGE KWON:  Yes, Mr. Karadzic.

21             THE ACCUSED: [Interpretation] Thank you.

22             Can I ask for a small intervention?  In the transcript, page 18,

23     line 24, general mobilisation was declared on the 4th of April by

24     Mr. Izetbegovic, and the transcript says "the 4th of May."

25             Could we now please have 1D3073.

Page 13669

 1             MR. KARADZIC: [Interpretation]

 2        Q.   May I ask you to have a look at this.  There's your signature on

 3     the top of the page.  Trnovo managed to link itself with Ilidza, as a

 4     larger and more powerful municipality; correct?

 5        A.   Yes, but I did not comment on the document dated the 14th of

 6     April, where we halted the work of state institutions and so on.

 7             Let me just say this:  That document practically verifies the

 8     situation that was already existing on the ground, because from the

 9     beginning of the war up until the 14th of April, the municipality was not

10     operational.  The security situation was such that many institutions were

11     not operational, and we simply verified that.  And the reasons for this

12     were strictly security reasons.

13        Q.   Thank you.  Is it correct that here, on the 16th of April, 10

14     days after the conflicts broke out in Sarajevo, itself, one Sarajevo

15     municipality, that is to say, Trnovo, the president of the SDS and the

16     president of the SDA, Radivoje Draskovic, and Alija Kucuk, made certain

17     conclusions?

18             And can you please tell us something about that.  Please have a

19     look at points 3, 4 and 5, where it says that efforts are being made to

20     keep and maintain peace in that municipality.

21        A.   I'm familiar with this document and these conclusions, because

22     Radivoje Draskovic was a member of our Crisis Staff, and the deputy

23     president of the Trnovo-Ilidza Municipal Assembly was Mr. Nenad Lalovic

24     from this municipality.  This was an agreement practically concerning

25     peace between the two major political parties.  There was also a

Page 13670

 1     citizens' forum which was suspicious because it may include elements of

 2     paramilitary units, such as the Patriotic League.

 3             Do I need to read out what was concluded, because what was agreed

 4     and confirmed here was to maintain peace in the territory of the Trnovo

 5     municipality.  It is one of the urban municipalities, but it is quite

 6     clear that the Muslims will not stand by this and that a horrible

 7     massacre would happen there, as well as persecution of the Serbian

 8     population.  That was practically the worst massacre in the territory of

 9     the city of Sarajevo, and I mean the entire area of this municipality.

10     They will be expelled, and those who didn't manage to flee will be

11     killed, have their throats slit, massacred, and so on.

12             And I even have -- I believe I have here some documents relating

13     to this, where, in Presjenica, that was the neighbouring municipality

14     next to Ilidza, in the month of July a massacre of 13 elderly people was

15     committed.  They were aged between 60 and 90.  There was no combat.  They

16     were loyal citizens.  They even had certificates to the effect that

17     security was guaranteed to them.  And then at a certain moment, they just

18     cut their throats.

19             And I believe I should have that somewhere here with me, the

20     original minutes or documents.

21             JUDGE KWON:  Mr. Prstojevic, as I said to you yesterday, if you

22     could keep your answers short and simple.  Mr. Karadzic will take care of

23     his questioning.

24             Mr. Karadzic, please continue.

25             MR. KARADZIC: [Interpretation] Thank you.

Page 13671

 1        Q.   May I ask you the following:  Is this proof that issues of peace,

 2     and preserving peace and good relations, were completely left to the

 3     local level, wherever this could be achieved?

 4        A.   That is absolutely correct.  It was left up to the local level,

 5     even by the leadership of the municipality of Ilidza.  In each of our

 6     local communes, there were authorised local boards.  The presidents of

 7     local boards and commanders of TO staffs were authorised to maintain

 8     peace at the local level, and this was also the case with Trnovo.

 9        Q.   Thank you.  Was it thanks to that that in some places, there was

10     fighting with the Croats, for example, and in some other places, there

11     was no fighting, and does that illustrate the freedom of local

12     initiative?

13        A.   That is also correct, primarily thanks to local relations at the

14     level of local communes and then also municipalities.  In the territory

15     of the Ilidza municipality and Kiseljak municipality, there was no

16     fighting with the Croats at all throughout the war.

17             THE ACCUSED: [Interpretation] Thank you.

18             Can this document be admitted?

19             JUDGE KWON:  Yes.

20             THE REGISTRAR:  D1198, Your Honours.

21             THE ACCUSED: [Interpretation] Can we now please have

22     65 ter 07177.  07177.  And in e-court, we would need page 159, and then

23     we will move on to 160.

24             MR. KARADZIC: [Interpretation]

25        Q.   This is your testimony in the case -- I believe it's the

Page 13672

 1     Krajisnik case, and the date is the 16th of June, 2005.  I'm going to

 2     read the question first:

 3             [In English] "Mr. Prstojevic, can you tell us about the visit

 4     following the starting of the uprising in Sarajevo by the Serbs during

 5     which you and the others [indiscernible] encouraged?"

 6             [Interpretation] And the reply is:

 7             [In English] "I've already said a few things about that:  Namely,

 8     on the 17th of April, I think the Crisis Staff at Ilidza held a somewhat

 9     shorter meeting of the government of the Serb people of Bosnia and

10     Herzegovina, and it was attended by Presidents Krajisnik and Karadzic.

11     At any rate, the session itself was very encouraging for us, and I can

12     only say one sentence that I remember very well that was uttered at that

13     session.  Dr. Karadzic said that no citizen of Ilidza should be harmed in

14     any way, and to a certain extent, he criticised us.  But our defence

15     lines were not safe enough, and then they said, Yeah, you have these

16     defence lines which are not safe and you want the government to be based

17     to Ilidza."

18             [Interpretation] Do you remember that the phrase which I used,

19     and which is translated a bit differently here, is that no citizen of

20     Ilidza, regardless of who he or she was, had to -- that all the citizens

21     had to remain safe and sound?

22        A.   Yes, it was precisely stated like that.  It's a well-known saying

23     in the Serbian language.  You have to take more than 100 per cent care

24     that something should remain secure.  Then you say, Not a hair on

25     anyone's head would be touched.  That is literally --

Page 13673

 1             THE ACCUSED: [Interpretation] All right, thank you.

 2             Can we have this admitted, please?  Or if I have read out

 3     everything, if it's sufficient to have it on the record, then it can

 4     remain as it is.  I think I have read out everything that's important.

 5             JUDGE KWON:  I think that's the case.  Let's move on.

 6             THE ACCUSED: [Interpretation] Thank you.

 7             Could we please have 65 ter 22231.  22231.  In the English

 8     version, we need page 27, and in Serbian version, page 46.

 9                           [Trial Chamber and Registrar confer]

10             JUDGE KWON:  Could you check the number.

11             THE ACCUSED: [Interpretation] 22231.  It's a statement dated the

12     6th of May, 2005.

13             JUDGE KWON:  You said -- it says it's a duplicate of something

14     else, which seems to be a video-clip.

15             THE ACCUSED: [Interpretation] It seems that identification is

16     [In English] document ID EN04-0243.

17             MR. KARADZIC: [Interpretation]

18        Q.   This is your interview with Mr. Stephen Margetts, and the last

19     answer:

20             [In English] "First of all, I never went to Pale without their

21     invitation.  There was a meeting in the Crisis Staff of the government.

22     However, there was a meeting of the Government of the Serb People in

23     Bosnia and Herzegovina, held in Ilidza, at which Karadzic, Krajisnik and

24     Miodrag Simovic, the deputy president of the government, were present,

25     and there it was discussed where the Government of Serbian People of

Page 13674

 1     Bosnia and Herzegovina should have its seat.  There were other

 2     representatives present at the meeting, but I, as a host, as a president

 3     of municipality where the meeting was organised, I was present there, and

 4     a few more Ilidza Serbs."

 5             [Interpretation] Is it correct that at this meeting, the main

 6     topic and the reason for our visit was to establish whether Ilidza was

 7     the place in which the government could be seated?

 8        A.   Yes.  But, Mr. President, as the president and as the host, in my

 9     introductory speech I talked about the situation in Ilidza.  I glanced at

10     my documents, and I noted the two key points: that we were trying to

11     maintain peace by continuing negotiations with the SDA and the HDZ.  And

12     the other thing, if, God forbid, we would be attacked, that we should be

13     able to defend ourselves.  And the remainder was discussion about the

14     seat of the government.  And what is more, other people remember that

15     better than me.

16             A voting took place, because Minister Milivoj Nadezdin, who was

17     from Ilidza, was an advocate of having Ilidza as the government seat.  As

18     far as I remember, the vote was four against four, and in the end, when

19     that was the outcome, you and Mr. Krajisnik agreed on something between

20     the two of you, and you said that people should go home and that they

21     would be informed as to where the government seat would be located.

22             And one of our men, who was the deputy commander of the TO - that

23     was what he was at the time already - Dragan Markovic, he said that it

24     was uncertain, if we were to be attacked by Muslims, whether we would be

25     able to defend ourselves.  And then you criticised us for that.  You

Page 13675

 1     said, and I have said this many times, There, you want the government to

 2     be here and see what the situation is like and what sort of security you

 3     have here.

 4             THE ACCUSED: [Interpretation] Thank you.

 5             I trust that what I have read out is sufficient for the record,

 6     we should not pile up documents.  And if the Trial Chamber agrees, we can

 7     move on.

 8             Could we now please have P1489.  P1489, that's General Mladic's

 9     diary.  In both Serbian and English, we need the page 168.

10             MR. KARADZIC: [Interpretation]

11        Q.   I believe that this is already the second half of 1995, and you

12     still didn't forgive us for the fact that we did not come to Ilidza.

13             We need the typed version in Serbian, and that's page 168.  And

14     in English, it's also page 168.  We already have it in English.

15             We can see that you said, and Mladic noted:

16             "Our political leadership has been in chaos for a long time, and

17     we've been betrayed several times during this war:"

18             That was:

19             "On the 17th of April, 1992, when they left for Pale; when the

20     seat of government was designated; when the airport was handed over; when

21     the army was withdrawn from Mount Igman; when some army operations were

22     stopped and the eastern part of Sarajevo is not without a future."

23             So you hadn't forgiven us this through to the end of the war, in

24     fact?

25        A.   Well, I can tell you that even today, the people down there

Page 13676

 1     believe that had the seat of government been located anywhere in the

 2     Serbian Sarajevo, the peace process would have taken a different course

 3     and matters would have been resolved differently.

 4             Secondly, as regards the hand-over of the airport,

 5     Vice-President Nikola Koljevic said that at that point in time, Ilidza

 6     was the most important municipality in Republika Srpska.  However, as the

 7     airport was handed over, we found ourselves severed into three pieces,

 8     the western part of the municipality, the eastern part, and the Trnovo

 9     part.  It was a very difficult situation for us.

10        Q.   Thank you.  Do you recall that we were given the promise by

11     UNPROFOR, and they undertook that they would see to it that we could use

12     the runway connecting the western part of Ilidza and the eastern part,

13     where the large hospital, Kasindol, was located, and that this promise

14     was not honoured?

15        A.   That is absolutely true.  However, we were in grave problems, and

16     Mr. Koljevic, once he reached the agreement on the hand-over of the

17     airport, nobody took care of the airport from that point on.  It was

18     mostly staff from the Muslim part of Sarajevo who were employed there,

19     and for a long time after that we would be unable to use the runway at

20     all.  It was only at a time when UNPROFOR would assume these duties that

21     we would be able to use the runway to transit the area, but that was a

22     year later or more.

23        Q.   Is it true that because this promise was not honoured, our

24     wounded had to travel four or five hours, rather than make a trip of

25     fifteen minutes, and that we lost some of our fellows because they could

Page 13677

 1     not reach the hospital in time before the Zica Hospital was opened and

 2     even after that period?

 3        A.   Well, you see, that is absolutely true.  And I know soldiers,

 4     wounded people, by name from Hadzici and Ilidza who succumbed to their

 5     wounds as they were transported from Ilidza to Pale.  What's more, some

 6     of my relatives were among them.

 7        Q.   I am sorry to hear that, but I do know that that's how the

 8     matters stood.  But do you agree that this was not the only promise that

 9     was not honoured by UNPROFOR?  Do you recall that we handed over an

10     important feature, Stojicevac, to UNPROFOR, which had some very good

11     residential facilities, which UNPROFOR, upon their departure, handed over

12     to the Green Berets rather than to us?

13        A.   I do recall that.  But at that time -- my apologies.  I do

14     remember, but we regarded UNPROFOR as the European Economic Community.

15     They were located in the Stojicevac and Serbia facilities.  I have

16     evidence to show in the form of protest letters that were sent to

17     UNPROFOR, and I also have some correspondence with Colm Doyle, if that

18     was his name, who -- they sided with the Muslims, and they were aware of

19     the Muslim intentions to attack Ilidza on the 22nd of April.  To put it

20     simply:  While we were constantly asking for permanent peace, they were

21     asking for 24-hour truces.

22             And on a crucial day, and I think it was the 15th of May, after a

23     failed Muslim offensive, when the whole of Sarajevo was attacking Ilidza,

24     both they and we had sustained grave losses.  At that point, they would

25     hand over the entire Stojicevac facility and complex to the Muslims.  At

Page 13678

 1     that point, they would engage in a fierce attack on the 15th of May.

 2     They had enormous quantities of artillery ammunition.

 3        Q.   Since we do have that point envisaged in our line of questioning,

 4     we'll go back to that later.  Let's stick to chronology and let's finish

 5     with this document that we have before us.

 6             Mr. Prstojevic, does this not show that you were no one's blind

 7     follower, and even less a yes-man; rather, you were a person of your own

 8     mind?

 9        A.   You see, Mr. President, my personal view had always been that

10     where I was given an order from the top, I would check to see if it fit

11     with the interests of Ilidza, in terms of security and economic

12     interests.  If it proved to be contrary to them, I would immediately

13     oppose the idea and expound on it.  In the event the person who issued

14     this order stuck with his view, I would not implement the order if it

15     went contrary to the local interests of the community and if it

16     threatened them, and I was a local politician.  The same sort of right

17     was enjoyed by the people who held the positions in the local communes

18     when it came to me passing down instructions to them.  They were able to

19     tell me that I was misinformed and that whatever I was telling them to do

20     would go contrary to the interests of their communities.

21        Q.   Thank you.  Mr. Prstojevic, is it not true that an enormous

22     responsibility lay on your shoulders, and on the shoulders of those who

23     headed the local communes, when it came to the possibility that the

24     Green Berets would break through and massacre the population?  Was this

25     not the reason behind your persistence in fulfilling your goals?

Page 13679

 1        A.   Yes, but you missed out on a very aspect of our defence effort.

 2     Our defence was successful precisely thanks to the lowest levels of the

 3     TO staff commanders, company commanders, platoon commanders, squad

 4     leaders.  Even where the republican leadership or the municipality

 5     leadership did not live up to the expectations of others, they always

 6     did, because they had their own families, women and children, that they

 7     had to defend.

 8             THE ACCUSED: [Interpretation] Thank you.

 9             Can we now have 1D1366, please.  Can we zoom in and have the

10     English version.

11             MR. KARADZIC: [Interpretation]

12        Q.   Mr. Prstojevic, is this your document, dated the 19th of April,

13     1992?  Let me tell you, before you answer, that in some of the

14     intercepts, they spoke of the fact that food supplies were not let

15     through, and they raised this issue as a sort of justification behind

16     their attacks.  Can you tell us, what is this decision about?

17        A.   First of all, it was never true that we would not let cars pass

18     through carrying food stuffs.  Quite the contrary.  We can have some

19     Muslims who were eye-witnesses to the fact that I would be allowing them

20     passage, in the interests of peace, even in the cases where they were

21     clearly transporting weapons.  For instance, a garbage truck for

22     Sokolovic Kolonija and Butmir, a cattle fodder truck which it was quite

23     clear who it was intended for.

24        Q.   Does item 4 not state that:

25             "The following shall be exempted from this decision:  Food

Page 13680

 1     stores; emergency aid; PTT enterprises; local food supply delivery

 2     vehicles; electric power enterprises; water control by the public

 3     utilities enterprise; SDK and --"

 4        A.   Business banks, that's what it means, because the SDK was

 5     providing service for them:

 6             "The companies exempt under number 4 of this decision shall work

 7     limited hours from 900 to 1500 hours, with the exception of the emergency

 8     medical assistance, which shall work around the clock."

 9             THE ACCUSED: [Interpretation] Thank you.

10             Can this document be admitted, please?

11             THE WITNESS: [Interpretation] This decision was reviewed, as can

12     be seen from the annotation at the top, also on the 21st of April, on the

13     eve of the attack against us.  It was our wish to be as flexible as

14     possible.  We didn't have any barricades on our intersections; we had

15     check-points.  People were passing through on their way to work in

16     Sarajevo until the 14th of May.

17             MR. KARADZIC: [Interpretation]

18        Q.   Both the Serbs and Muslims?

19        A.   Yes, yes, absolutely.  In our testimony, we always referred to

20     the Muslims and Croats, because the Serbs are not considered as reliable

21     a witnesses.

22             THE ACCUSED: [Interpretation] Can this be admitted, please?

23             JUDGE KWON:  Yes.

24             THE REGISTRAR:  Exhibit D1199, Your Honours.

25             MR. KARADZIC: [Interpretation]

Page 13681

 1        Q.   We can see here that even though there was a war on, voting was

 2     taking place, and out of the 10 of those in attendance, 9 voted in favour

 3     of maintaining the flexible measures regime; is that right?

 4        A.   Yes.  There was this one person who abstained, and that

 5     individual believed that everything we were doing made no sense.  He said

 6     there was a sea ahead of us and behind us, Ilidza would fall sooner or

 7     later.  To put it simply, he was in favour of a surrender.  We never held

 8     this against the man.  That was his psychological make-up.

 9             THE ACCUSED: [Interpretation] Thank you.

10             Can we now have 1D3087.

11             MR. KARADZIC: [Interpretation]

12        Q.   Can you tell us what this document is about?

13        A.   This is a protocol from a meeting held on the 23rd of April,

14     1992, I believe, which I wrote -- or, rather, which I personally

15     chaired -- or which I wrote, and it was chaired by the representatives of

16     the EEC.  Members were representatives of the SDA and SDS.  This was

17     after the failed aggressor's attack on the entire Serbian areas of Ilidza

18     municipality.

19        Q.   You're talking about the attack of the 22nd of April; is that

20     right?

21        A.   Yes.  We had 11 persons killed, 56 wounded.  In certain books,

22     they wrote -- they boast about the fact that they had only two

23     individuals killed and that they were able to take over Ilidza, but that

24     somebody had ordered them to retreat.

25             You see, what was our undoing was our fifth column from within.

Page 13682

 1     They attacked us, and yet we sat at a table to negotiate with them.

 2     Their representatives were Avdo Hebib, I think, and Hodzic, Enver, aka

 3     Enko, because the official representative of the commander of the

 4     Crisis Staff, Mahmutovic, Husein, did not dare to show his face because

 5     he did not believe that things would end well.  Nevertheless, we pulled

 6     it off.  Some people came into a fight with Husein in front of the

 7     Serbija  Hotel, and some people were killed, two brothers.  We would be

 8     meeting with them on a daily basis from this day on.

 9        Q.   I'll be reading from English because it's more visible:

10             [In English] "From the direction of Glavogodina, at 2120 hours,

11     two rockets, one illumination round, and then the attack began on the

12     Health Centre in Ilidza.

13             "The firing stopped at 2400 hours.

14             "For a time, we did not return fire, but then we had to."

15             [Interpretation] Does this reflect what was happening as you were

16     signing this document; namely, that you were being attacked from the

17     direction of Glavogodina?

18        A.   Well, you see, this protocol was something that I was practically

19     in charge of.  What you are reading out now happened immediately after

20     the protocol was signed; on the same day, but in the evening.  This is my

21     original handwriting, what I wrote there.  I sort of jotted this down

22     during the course of that evening.  So this is authentically what

23     happened at 2120 hours on that day and later.

24        Q.   Thank you.  A 120-millimetre and an 80-millimetre mortar is being

25     referred to, and APCs?

Page 13683

 1        A.   Yes, yes, all of it, and Vehbija Karic, too, and asking the

 2     Croatian -- or municipality of Fojnica to help, because since their

 3     attack failed, they're trying to draw the Croats into the war.

 4        Q.   You mentioned that the fifth column was your undoing.  What do

 5     you mean by that?

 6        A.   Well, Mr. President, until the 22nd of April, all the Muslims

 7     were in the central part of Ilidza.  As a matter of fact, I claim with

 8     full responsibility that more Serbs had fled, even those who held

 9     positions within the party, and others who held various positions in

10     companies and so on, because they were afraid for their own lives.

11             When the attack took place at the crack of dawn, then the

12     Muslims, certain extremists, were shooting from snipers and hunting guns

13     from the depth of the settlement, and it is well known from which

14     particular points.  The closest building to the Crisis Staff and to the

15     TO on the front-line was Fijaker.  From there, it is well known who lived

16     there, so it was from there that the TO staff was fired at.  Two soldiers

17     were wounded in front.  The man was lying and hit in the leg.  Another

18     person was hit by a bullet in the buttocks.

19             I ran out of the staff and asked what was going on, where was the

20     gun-fire coming from, because there were people who were older than I am

21     now who were guarding the staff building.  I practically opened fire at

22     that other building, and I prepared a group for a search to find the

23     sniper there.  The man who was there, it was sufficient for him to run

24     50 metres and no one would touch him afterwards.  He could just get lost

25     in the crowd.

Page 13684

 1             This attack was filmed by 10 TV cameras before the eyes of the

 2     European Economic Community; inter alia, TV Sarajevo, the official Muslim

 3     TV, allowed the filming of this -- was allowed to film this.  And from

 4     there, you can see our people who got killed.  You can see that from the

 5     institute.  That's the Institute for Rehabilitation.  It's a health

 6     institution.  You can see the dead.  You can see when a sniper hits a

 7     cameraman - I think it was a BBC cameraman - in the right hand.

 8             And, unfortunately, some Robert Donia, in General Milosevic's

 9     materials, claimed that we were the ones who were shelling that institute

10     and that we opened sniper fire at it, and that was within our territory.

11     I am mentioning this as an example of the kind of bad mistake that an

12     expert can make and thereby create the wrong picture.

13        Q.   Thank you.  May I be allowed to summarise what you were saying?

14             You are attacked by the Green Berets and the Muslim

15     Territorial Defence from the territory that is not under your control,

16     and you were fired at -- or you were shot in the back by Muslims who

17     lived in Serb-held territory.  Does that correspond to what you were

18     trying to say?  And this gun-fire came from Fijaker, that was under Serb

19     control, and the institute that was under Serb control; right?

20        A.   Precisely.

21             THE ACCUSED: [Interpretation] Thank you.

22             Can this be admitted?

23             JUDGE KWON:  Yes.

24             THE REGISTRAR:  Exhibit D1200, Your Honours.

25             THE ACCUSED: [Interpretation] Can I now have 65 ter 30689.

Page 13685

 1             MR. KARADZIC: [Interpretation]

 2        Q.   The 20th of April, this is a telephone conversation between

 3     Cedo Kljajic and Tomislav Kovac.  Is it true that Tomislav Kovac is the

 4     local police chief and Cedo Kljajic is some official in the Ministry of

 5     the Police or, rather, of the Interior?

 6        A.   That is correct.  Mr. Kovac was the chief of the police station

 7     in Ilidza, and Cedo is a high official at the Security Centre of Serbian

 8     Sarajevo in Vraca.

 9             THE ACCUSED: [Interpretation] Thank you.

10             Can we have the next page.

11             MR. KARADZIC: [Interpretation]

12        Q.   Is it true that they were in the police before that as well, that

13     they are not any kind of new policemen?

14        A.   That is fully correct.  They are professionals in the MUP; that

15     is to say, starting with school and then the prewar period.  As a matter

16     of fact, Mr. Kovac was for a long time a member of the League of

17     Communists of Yugoslavia before the war, and so was I ever since I was a

18     pupil.  And, as a matter of fact, Mr. Kovac was not even a member of the

19     SDS at that point in time, as far as I know.

20        Q.   Thank you.  Can you look at this part, where it says:

21             "All top officials of the MUP ," that's what Kljajic says.  And

22     then he says that they went to Presidency with a single request; that

23     they be allowed to break through all barricades on the approaches to the

24     city of Sarajevo?

25             And then Kovac says:  "Yes."

Page 13686

 1             And Cedo Kljajic says now they are counting on that solution, and

 2     they are going to try that during the afternoon and night hours.  So Cedo

 3     is saying that the Muslim part of the police is asking for permission for

 4     an armed breakthrough, and Kljajic says:

 5             "All of those conversations that we had previously are no longer

 6     valid."

 7             And down here, he says:

 8             "See, they are consolidating their forces.  They are going to try

 9     a break through, and we don't know which way, and it is most probable

10     that they will first try to do this through Ilidza."

11             And then towards the bottom in Serbian:

12             "Well, I cannot reach Prstojevic.  I did not even talk to him, so

13     if you talk to him, convey this message to him."

14             Does this correspond to the situation as you remember it?

15        A.   Well, you see, in this period I heard about this day when several

16     conversations took place.  It was believed that we, the

17     Territorial Defence, headed by yours truly, imposed strict controls that

18     were not justified.  However, after these conversations - there is one of

19     Cedo's, one of Mr. Mandic's - Cedo learned something else, but he's

20     making a mistake.  It's not that the Muslim leaders of the MUP went there

21     because they wanted to do so themselves.  They were asked by the Muslim

22     leadership, and they were asked to carry out an order of the 14th of

23     April.

24             We have information - I even have it here - to the effect that at

25     that moment, about 3.600 members of the Green Berets, the

Page 13687

 1     Patriotic League, the Muslim TO and the HOS were about to attack us.  He

 2     sees that we are about to be attacked.  Attacks were announced to us

 3     every day through different channels, but we knew about this.

 4             On the 21st, I tried to prevent an attack.  I shall talk to MP

 5     Ljubo Bosiljcic in Sokolovic Kolonija, then the president of the

 6     Association of World War II Veterans, Sveto Dragovic, and a member of the

 7     League of Communists Movement for Yugoslavia, Milenko Jaslar.

 8             However, as for these talks in Sokolovic Kolonija around 2100

 9     hours, Juka Prazina, one of the commanders of the paramilitaries and

10     later on a general in the police of the MUP, he will shew them away

11     because they stood in his way, in the way of the attack that would follow

12     in the morning.

13             THE ACCUSED: [Interpretation] Thank you.

14             Can this be admitted, or, rather, marked for identification for

15     well-known reasons in view of the position we hold?

16             JUDGE KWON:  Yes, we'll come to that issue later on.

17             We'll mark it for identification.

18             THE REGISTRAR:  As MFI D1201, Your Honours.

19             THE ACCUSED: [Interpretation] Could I please have 65 ter 30709.

20             MR. KARADZIC: [Interpretation]

21        Q.   This is a day later, the 21st of April, 1992.  This is a

22     conversation between yourself and Momo Garic.  On page 1, we see that he

23     is asking to speak to you, and he's calling from Novo Sarajevo,

24     New Sarajevo.

25             The next page, please, in English and in Serbian.

Page 13688

 1             Garic is providing information to you here - it's line 4 and 5

 2     from the top - that the army cannot do anything about the tanks:

 3             "We are encircled.  Do you have any armour, manpower?  Please,

 4     I'm begging you."

 5             And then this man is handing over the receiver to you because you

 6     were just coming in.  Garic is complaining that they were encircled and

 7     that the army did not want to get involved.

 8             Can we have page 3.

 9             And then you are asking:  "Where are you?"

10             And then he is trying to mollify someone and saying:  "In Vraca."

11             And then:

12             "Where in Vraca?  Are you by the MUP down there or up there?

13     Someone will be waiting for those people there by the underpass."

14             Can we have the next page in Serbian and in English.

15             He's asking you for help:

16             "We went down to a town by Miljacka.  They're too strong.  They

17     are encircling us, and the army refuses to move."

18             And then you say:

19             "Wait a second.  Are you fighting there?"

20             And Garic says:

21             "We are fighting fiercely.  We have many casualties, dead and

22     wounded."

23             And then further down, you say:

24             "What are the special forces doing?"

25             And he says:

Page 13689

 1             "They don't want to leave the compound.  There you go."

 2             And:

 3             "The reserve police force also made a promise."

 4             Can we have page 6 in English and the next page in Serbian.

 5             Your question is:

 6             "Where is the fighting actually taking place?"

 7             And he's saying:

 8             "Vrbanja, Grbavica, Ivan Krndelj, all the way to

 9     Elektroprivreda."

10             We see all of it.

11             And then, tell us, is it true that Grbavica, like all of

12     New Sarajevo, after all, is a predominantly Serb-populated area and that

13     the Muslim Green Berets and paramilitaries are attacking Grbavica on that

14     day, on the 21st of April, and Momo Garic is asking that you send in some

15     help?

16        A.   Well, yes, that is quite correct.  That is in line with the

17     tactics of the Muslim Territorial Defence, because they are attacking on

18     several fronts.  According to some documents, in 1995, in the territory

19     of Novo Sarajevo, there is a negligible difference between Serbs and

20     Muslims, in terms of the census.  And Grbavica, with its surrounding

21     area -- I mean, people said that Grbavica was a dormitory.  It was a

22     newly-built area.  The population was predominantly Serb, and lots of JNA

23     officers had their apartments there and so on and so forth.

24             As for Mr. Garic and his men, I spoke to them several times

25     during that day.  He was the commander of the Territorial Defence there.

Page 13690

 1     I did not really know the man very well until then, and I'm giving him

 2     advice here, because I see that the JNA doesn't want to do anything.

 3     They didn't take part in anything on the 22nd of April either.  They

 4     didn't help us at all, us in Ilidza.  They were rather reserved.  Also,

 5     here they hardly did anything.  Those who fought the best were ordinary

 6     soldiers who were defending their own homes.

 7             I was in a difficult situation here, but, nevertheless, I did

 8     prepare a unit for him, a platoon from Kasindol, taking the shortest

 9     route possible in order to help.  And you see already the next day, there

10     would be an attack against us over here.  It is quite clear that the

11     attacks were synchronised.

12        Q.   Thank you.  You say that a soldier who defend his home,

13     et cetera.  Is there anyone here, except for the local population, that

14     actually lives there?  I mean, among these Serb forces of the

15     Territorial Defence.

16        A.   Absolutely.  In Ilidza, absolutely no one else.  And from this

17     conversation, you see there's no one else.  The only reference is to the

18     entire local population being mobilised.  The MUP is trying to avoid a

19     fight, and it is well known that the JNA didn't want to fight in the

20     first place.

21             THE ACCUSED: [Interpretation] Thank you.

22             Can this be admitted?

23             JUDGE KWON:  Yes.  I don't think -- we don't need to mark it for

24     identification, since Mr. Prstojevic acknowledged it's his voice.  We'll

25     admit it.

Page 13691

 1             THE REGISTRAR:  As Exhibit D1202, Your Honours.

 2             THE ACCUSED: [Interpretation] Can we now please have 65 ter 1036.

 3             MR. KARADZIC: [Interpretation]

 4        Q.   Please, if you can familiarise yourself with this document.  It

 5     was issued and signed by me.

 6             It says here that on the 22nd of April, 1992, in the early

 7     morning hours -- and can you describe to us, just briefly, what this

 8     document says?

 9        A.   Well, here you give an announcement that in the early morning

10     hours on the 22nd of April, an attack was launched on the territory of

11     the Serbian municipality of Ilidza by the Sokolovic Kolonija.  But,

12     President, this was an attack from the entire 16-kilometre line along

13     which we bordered the Muslim ethnic space.

14             Then further on you say that there is a large number of wounded

15     and dead, and you appeal to all individuals and commanders to stop the

16     conflict unconditionally.  You emphasise that the fighting and the

17     attacks on Grbavica, as well as on Ilidza, as we have seen, were aimed at

18     obstructing the peace process and the coming of Lord Carrington, and thus

19     make it impossible to have a peaceful resolution of the crisis in

20     Bosnia-Herzegovina.

21             THE ACCUSED: [Interpretation] Thank you.

22             Can it be admitted?

23             JUDGE KWON:  Yes.

24             THE REGISTRAR:  Exhibit D1203, Your Honours.

25             THE ACCUSED: [Interpretation] Could we now please have

Page 13692

 1     65 ter 08175.  08175.  And in the English version in e-court, we would

 2     need page 76, and in the Serbian version, 86.

 3             MR. KARADZIC: [Interpretation]

 4        Q.   This is your statement from 2003.  I shall read it in English

 5     because I have it in English.  And you can control, in Serbian, whether

 6     the translation is good:

 7             [In English] "On 22nd of April, besides all the agreements about

 8     cease-fire, unannounced, without announcement, the Muslim forces attacked

 9     Ilidza at 5.00 and 45 minutes in the morning, and they attacked regular

10     police, reserve police and Territorial Defence.  We had 11 dead and 56

11     wounded.  So how that happened and who was attacking who was recorded by

12     at least 20 cameras of journalists that were located in Hotel Srbija at

13     that time.  And there is an authentic movie of the BBC cameraman.  And I

14     know that person who lives in Ilidza and he still has that movie and he

15     can give it to you.  According to the information that we have today,

16     only two Muslim soldiers got killed, out of which one was Albanian, that

17     means foreigner," Albanian from Albania, probably, "and I have a book

18     here in my bag where the Muslim commander writes about that attack on

19     Ilidza.  That is a very good -- another document that speaks about who

20     was who."

21             [Interpretation] Does this correspond with what you said, and

22     does it correspond with what took place?

23        A.   This is absolutely correct.

24             But let me also add something on the number of cameras.  As you

25     can see, I now said 10.  It always seems that the number is smaller than

Page 13693

 1     it is.  A number of people, cameramen, had made certain recordings which

 2     are now on the Internet, and certain clips about this fighting can be

 3     found.  It has been recorded from a number of angles.

 4             THE ACCUSED: [Interpretation] Thank you.

 5             Is what I read out sufficient or should we have it admitted?

 6     From the point of view of the Defence, I think this is sufficient.

 7             JUDGE KWON:  Yes, let's move on.

 8             THE ACCUSED: [Interpretation] Could we now have in e-court P1489.

 9     That is General Mladic's diary, P1489, and the page in both Serbian and

10     English that we need is 167.  But in the Serbian version, if we could

11     please have the type-scripted page.

12             MR. KARADZIC: [Interpretation]

13        Q.   Here, you were with General Mladic.  There's one "Gogovac," but

14     probably "Glogovac."  And it says then, President Prstojevic:

15             "Ilidza municipality makes up one-third of Serbian Sarajevo.

16             "We had 3.001 wounded and 930 dead and 150 civilian victims of

17     war."

18             Mr. Prstojevic, is this a frightening result, considering such a

19     small area?

20        A.   It is correct that the result is frightening.  Miso Glogovac, who

21     is mentioned was the director of the construction company Put, or The

22     Road.  However, here with me I have the most correct data which I

23     prepared during the winter.  The exact number is 3.001 soldiers who were

24     wounded.  Practically, every second fighter in Ilidza was wounded, and

25     every eighth died.  The number of -- of the soldiers who died, of the

Page 13694

 1     861, because here they were mixed with the civilians, but the number was

 2     higher, the number was the highest in Republika Srpska, and Banja Luka

 3     has 195.000 inhabitants.  And the other number, 3.001 -- or I am wrong.

 4     The number of wounded is the highest and the number of the dead is the

 5     second highest.

 6             As for the civilian casualties, from what I established, in the

 7     territory that the Ilidza municipality controlled, the number was around

 8     210.  That included the Serbs, the Muslims and the Croats, because we did

 9     not divide civilian casualties on the basis of ethnicity.  However, due

10     to the set of circumstances in the Muslim part of Ilidza, in Dobrinja,

11     and in the Croatian-populated part which, over time, the Muslims will

12     take over by force, it was 208, what I managed to establish in winter.

13     That's the number of the Serbs who lost their lives.  They were mostly

14     taken away from their homes.

15        Q.   Is it a fact that you had many refugees, and that you were

16     literally living on the confrontation line or the separation line, that

17     you were within reach of all sorts of weapons, and that this was decisive

18     both for the number of casualties and also the state of mind, I mean, the

19     fear that the population was living in, and also the sort of

20     responsibility that you were feeling, as the leadership in the area?

21        A.   The first refugees in Ilidza practically arrived from the parts

22     of Ilidza which were under Muslim control, and these were

23     Sokolovic Kolonija and Hrasnica.  And as early as by the 28th of April or

24     so, all the Serbian population fled as refugees from these two local

25     communes, whoever could.  Around 100 Serbs remained in

Page 13695

 1     Sokolovic Kolonija, and around 300 remained in Hrasnica.  At that moment,

 2     we already had around 4.000 refugees in the centre of Ilidza.  They were

 3     accommodated with their relatives and in a car camping site in Ilidza,

 4     and also at the Forestry School, some of them, and that school was later

 5     on transformed into barracks.

 6             Another important thing is that refugees from down-town Sarajevo

 7     were arriving daily.  Refugees from Central Bosnia were also beginning to

 8     arrive through Kiseljak.  And in this period, more than 30.000 Serbs left

 9     Central Bosnia via Kiseljak.  There are reports about that, some of them

10     very touching, because people sometimes left barefoot or in their socks.

11     I have two reports.  One is from the commander of the Igman Brigade and

12     another one from the president of the Local Commune Rakovica, which was

13     the first one to receive these refugees.

14             And to cut the long story short, the population of Ilidza, which

15     we were controlling, I mean, in that part of Ilidza, grew from 20-odd

16     thousand during this period, according to some estimates, to almost

17     40.000, and there were fluctuations all the time.

18        Q.   Thank you.  Is it correct, Mr. Prstojevic, that with such a high

19     number of refugees and the doubling of the population, and also

20     considering the fact that some of the local Muslims were shooting at them

21     from behind their backs, was it difficult to maintain public order in the

22     Serbian-populated part of Ilidza?  Was it difficult to come to terms with

23     the population, who were impoverished and afraid and so on?  Was it

24     difficult for you, as the president of the municipality, to deal with all

25     this?

Page 13696

 1        A.   Well, you see, in the early stages, before the

 2     Army of Republika Srpska was established and throughout 1992, the

 3     situation was very difficult.  What is more, there is a document issued

 4     by the chief of the -- Colonel Marcetic from the Sarajevo Romanija Corps,

 5     who said at the end - I think he wrote that in December - that no one's

 6     life could be guaranteed in this region, because a group arrested even

 7     him at the hotel in Vogosca, where he was sleeping.  There was great

 8     disturbance and unrest, even though the local citizens, the Serbs, were

 9     very tolerant and very mild.  But if someone lost two brothers or two

10     sisters, there were whole families in Sarajevo that perished.  Such

11     people acted in a manner that was uncontrollable.

12             And I will emphasise:  In this period, Ilidza municipality was

13     fired on once, and I had to move everyone out of the municipality, except

14     for myself, I remained there.  And it was only by chance that the

15     municipality building was not set on fire, because the Zolja shell hit a

16     tree rather than a specific office.

17             It also happened that Serbs would kill one another.  The

18     League of Communists Movement for Yugoslavia was also very strong, and it

19     co-operated with its elements across Sarajevo.

20             So as civilian authorities, we hardly managed to maintain our

21     positions.  And when the Muslims and their units did not kill me, it

22     almost happened that Serbs killed me.  It was really very critical.

23        Q.   Thanks a lot.  Now I will try to ask you to identify certain

24     documents, mostly originating from you.  And if possible, I would ask you

25     for as short answers as possible, because otherwise we cannot do

Page 13697

 1     everything that we envisaged.

 2             When you said that someone fired at the municipality, you

 3     actually meant the municipality building, the seat of the municipal

 4     authorities, and that you had to evacuate the building; correct?

 5        A.   Yes, it happened twice, and the Serbs fired at me; once, before

 6     September, and the next time it was on the 1st of September.  And the

 7     Muslims were targeting the municipality building all along.

 8             In October 1992, a shell killed eight passengers and wounded 33

 9     passengers at a bus stop in front of the municipality building, and the

10     shell was fired from the Muslim part.  And the eight casualties included,

11     for example, two sisters who were Croats by ethnicity.  I knew them.  And

12     at the moment I ran out of the municipality building to try to save them,

13     when they fell down, because it was a real disaster --

14             THE ACCUSED: [Interpretation] Thank you.

15             Can we now please have 1D1369.  I will now try to move as quickly

16     as possible through these documents.

17             MR. KARADZIC: [Interpretation]

18        Q.   This is your document, so I hope you will be able to confirm what

19     it is, and the others will be able to read what it refers to.

20             Is this your document, dated the 26th of April?

21             The English version is contained on a single page, so I would ask

22     the parties to pay attention to it.

23             Can we now just say briefly whether this your documents and what

24     it deals with?  But as briefly as possible, please.

25        A.   Yes, it's our document, but I cannot see a signature at the

Page 13698

 1     bottom.

 2        Q.   Your signature is on the second page?  In the Serbian version,

 3     it's the second page?

 4        A.   Yes, yes.  This is a memo sent to the representative of

 5     UNPROFOR -- or, rather, the European Economic Community, in which, as far

 6     as I can say, on the top of my head, I have no time to read.

 7             THE ACCUSED: [Interpretation] Can we please bring back the first

 8     page.

 9             MR. KARADZIC: [Interpretation]

10        Q.   You talk about the attack on the 22nd, and then you also say

11     that:

12             "We have reliable information that one of the vehicles

13     transported Avdo Hebib, the special adviser in the MUP."

14             I believe that somewhere you mention the possibility that they

15     might be painting their vehicles white.

16             Could we now please have a look at the second page.

17        A.   Yes.

18        Q.   It says here that you used your combat vehicles to shield the

19     Muslims from Hrasnica.  And then further on:

20             "The Green Berets paint their vehicles white to camouflage

21     them ..."

22             And so on and so forth.

23             Is this an authentic letter which you sent?

24        A.   Yes.  Here we protest, because they engaged in fighting and they

25     drove around Muslim officials who were recording our combat lines.  We

Page 13699

 1     also had reliable information that on the 21st of April, they had a

 2     meeting with the SDA at the Stojicevac Hotel.

 3             THE ACCUSED: [Interpretation] Thank you.

 4             Can it be admitted?

 5             JUDGE KWON:  Yes.

 6             THE REGISTRAR:  Exhibit D1204, Your Honours.

 7             THE ACCUSED: [Interpretation] 1D3054, can we have that, please.

 8             MR. KARADZIC: [Interpretation]

 9        Q.   This is your letter to Ferrera and Mr. Doyle, dated the 30th of

10     April, 1992.  And you say that at 9.55 of the 29th of April, 1992, the

11     Green Berets opened heavy fire from the direction of Sokolovic Kolonija

12     at the Forestry School, et cetera, et cetera:

13             "We returned fire 20 minutes later, when our soldiers started

14     getting wounded."

15             Can you confirm that the events and the letter are authentic?

16        A.   I confirm that this is my signature and that the document is

17     authentic.

18             THE ACCUSED: [Interpretation] Can we please admit the document?

19             JUDGE KWON:  Yes.

20             THE REGISTRAR:  Exhibit D1205, Your Honours.

21             THE ACCUSED: [Interpretation] Can we have 1D3074, please.

22             MR. KARADZIC: [Interpretation]

23        Q.   This is a public announcement of the Crisis Staff, dated the

24     1st of May, 1992, where you inform the public of the disinformation

25     coming from some media that the Serbian authorities of the Serbian

Page 13700

 1     municipality of Ilidza have blocked Sokolovic Kolonija, Hrasnica and

 2     Butmir settlements:

 3             "We emphasise once again that access has been made possible for

 4     vehicles transporting food stuffs, and particularly milk and bread, in

 5     the whole territory of the Serbian municipality of Ilidza, including

 6     Sokolovic Kolonija, Butmir and Hrasnica."

 7             You go on to say:

 8             "We would like to emphasise that the Serbian authorities of the

 9     Serbian municipality of Ilidza allow freedom of movement across the

10     territory of the municipality to all people, regardless of their

11     ethnicity, party affiliation, sex, or any other affiliation."

12             Is this true, and did you issue this document?

13        A.   This is our document, and this is true.  And that was the way we

14     proceeded.

15             THE ACCUSED: [Interpretation] Thank you.

16             Can the document be admitted, please?

17             JUDGE KWON:  Exhibit D1206.

18             THE ACCUSED: [Interpretation] Can we have 1D01276, please.

19             MR. KARADZIC: [Interpretation]

20        Q.   Mr. Prstojevic, when a Serb or a Muslim wanted to cross the lines

21     or approach our lines, would he have asked the authorities to issue him

22     with a certificate of some sort testifying to his involvement in a work

23     detail, proving that he was not a deserter?

24        A.   Well, I don't know.  But I believe that by this time, you already

25     had certain forms granting permission to leave.  Primarily, this was

Page 13701

 1     meant for our military conscripts, the Serbs.  But until the 14th of May,

 2     whoever knew which route to take could move about, but there were certain

 3     permissions of this sort being issued in this period.

 4        Q.   Thank you.  In this letter, you write to Ferrera and Doyle.  The

 5     translation reads "Sereda," and I believe it's "Ferrera" in Serbian.  Do

 6     you recall the document, although it's a very poor copy, but at the

 7     bottom it says that in all the three neighbourhoods, Hrasnica, Butmir,

 8     Sokolovic Kolonija, Muslims keep the Serbs as hostages?

 9        A.   Yes, that's absolutely true.  I have found an original - not a

10     photocopy, but an original - bearing a blue stamp which clearly shows

11     what it was that we wrote, and it's true that Muslims were hostages in

12     Sokolovic Kolonija.  In December, they sent us a list of those intended

13     for an exchange, including women and children, and some killed

14     individuals.  I think the total was 266 of those who were intended to be

15     exchanged --

16        Q.   Did I understand you right that the Muslims held 266 Serbs as

17     hostages, and that the women they held were pregnant?

18        A.   Yes.  In December of 1992, the Exchange Commission from the

19     municipality of Ilidza sent to me, and the MUP at Ilidza, a list of some

20     266 individuals who would be allowed to leave.  They were minors,

21     children, pregnant women.  And the list also included individuals who had

22     long been killed; for instance, Zdravko Gligorevic is one for whom I knew

23     that this was a fact.

24             THE ACCUSED: [Interpretation] Thank you.

25             Can we have the next page in Serbian.

Page 13702

 1             MR. KARADZIC: [Interpretation]

 2        Q.   So to avoid any confusion, it was the Muslims holding the Serbs

 3     hostages?

 4        A.   Yes, yes.

 5        Q.   Here, it makes mention of break-ins into apartments, names

 6     mentioned, and here you appeal to the European Community to immediately

 7     set up a mixed commission which would --

 8        A.   Yes, tour each flat and go in a fact-finding mission as to the

 9     situation with regards to the Serbian population in the area.

10        Q.   Thank you.  And was such a commission established?

11        A.   No, it wasn't.

12             THE ACCUSED: [Interpretation] Thank you.

13             Can the document be admitted, please?

14             JUDGE KWON:  Yes.

15             THE REGISTRAR:  Exhibit D1207, Your Honours.

16             THE ACCUSED: [Interpretation] The last thing we will deal with

17     before the break.

18             MR. KARADZIC: [Interpretation]

19        Q.   In relation to this event we just discussed, Mr. Prstojevic, was

20     the Ilidza municipality authority under pressure from those who were

21     kept, tortured, et cetera, and were you asked to explain to them what

22     were the reasons why you couldn't help them?

23        A.   Well, we had a hundred problems, and this was one of them.

24             On the 22nd of April, an APC, which set out for an exchange of

25     Serb TO members and Muslims, had skidded off the road.  The crew, all of

Page 13703

 1     whom were people from Ilidza, were taken prisoner.  Let me mention just

 2     one name, Stevan Djokanovic.  These prisoners would be killed, in early

 3     May, somewhere, apparently, near to the police hall.  Their relatives

 4     approached us and appealed to us for assistance, but we were helpless

 5     there.

 6        Q.   Let me be quite precise.  The JNA sent an APC to separate the

 7     Serbs from the Muslims.  The Muslims captured them and killed them in

 8     this large parkland near to the police hall?

 9        A.   Yes.  It was the Caterpillar track on the APC that fell off, and

10     that's how they captured them.  But they couldn't reason with them.

11        Q.   And the last thing I'm going to ask you is this:  Were there any

12     problems, and was it difficult to prevent people from taking revenge on

13     the Muslims living in Ilidza?

14        A.   I don't have any information to the effects that the Serbs in

15     Ilidza would engage in any sort of revenge.  We were not of that sort of

16     character that we would engage in revenge.  It was more the refugees from

17     Central Bosnia and elsewhere who had that sort of nature.

18             Certain problems arose from this situation.  We had a Serb from

19     Central Bosnia killing another Serb because he wanted to take his cow to

20     feed the army, and he killed him because he needed the cow to feed his

21     family.  It was a Bugarin.

22        Q.   And Bugarin is the surname, is it not?

23        A.   Yes, his first name is Dragan.  Dragan Bugarin.  He was a

24     scoundrel.  He wanted to take the cow from this other Serb for his own

25     troops, and the other man killed him because he had to feed his family.

Page 13704

 1             THE ACCUSED: [Interpretation] Thank you.

 2             Are we going to have a break now?

 3             JUDGE KWON:  Yes, we'll have a break for half an hour and resume

 4     at 1.00.

 5                           --- Recess taken at 12.33 p.m.

 6                           --- On resuming at 1.02 p.m.

 7             JUDGE KWON:  Yes, Mr. Karadzic.

 8             THE ACCUSED: [Interpretation] Thank you.

 9             Can we call up 65 ter 01510.

10             MR. KARADZIC: [Interpretation]

11        Q.   Mr. Prstojevic, I will try, in the briefest of the terms, to

12     present to you the substance of a number of documents, and it will be up

13     to you to confirm them or deny them.

14             This is a bulletin of daily events, issued by the Ministry of the

15     Interior of the Serbian Republic of Bosnia-Herzegovina, as it was called

16     at that point.  And the first paragraph says that during the past night,

17     between the 3rd and the 4th of May, an attack was launched on the Serbian

18     territory, on JNA facilities, by paramilitary forces of former

19     Bosnia-Herzegovina; that Ilidza came under attack from the direction of

20     airport.  Is this what the document says?

21        A.   Yes.

22             THE ACCUSED: [Interpretation] Can we have the next page, please.

23             MR. KARADZIC: [Interpretation]

24        Q.   The question was:  Does the document correspond with the events

25     as they transpired between the 3rd and the 4th of May of that year?

Page 13705

 1        A.   Yes, that's right.

 2        Q.   It says here that a Muslim TO vehicle was passing through the

 3     area, and whoever refuses to respond to their calls is being mistreated,

 4     their house damaged, et cetera.  Was this true?

 5        A.   Well, I wasn't informed of this particular incident, but I know

 6     that at that point in time, there were less than 100 Serbs in the area.

 7        Q.   Is it true, Mr. Prstojevic, that we had never forced the Muslims

 8     and Croats to join our army?

 9        A.   That is correct, but there is information in the Muslim documents

10     as to how many Serbs were present in their army.

11        Q.   The last paragraph says that they came to learn that a new

12     Muslim-Croatian MUP station was set up in Stup, and it says that

13     Edin Mlivic was the chief who, before the outbreak of hostilities, was

14     chief at Ilidza; is that right?

15        A.   Yes.  Around the 6th of April, 1992, the Muslims would set up the

16     War Presidency of the municipality of Ilidza, and they would station

17     their MUP in this particular neighbourhood.

18             JUDGE KWON:  Just a second.

19             Yes, Mr. Tieger.

20             MR. TIEGER:  It just may be time for another reminder for the

21     witness to attempt to place a pause between the question and answer.  On

22     a number of occasions recently, his answer began as the translation was

23     still being rendered.

24             JUDGE KWON:  Yes.  It's very difficult for us to follow,

25     Mr. Prstojevic.  Please put a pause.

Page 13706

 1             Yes, let us continue.

 2             MR. KARADZIC: [Interpretation]

 3        Q.   Did they set up their own Muslim municipality of Ilidza on the

 4     6th of April, in accordance with the prewar negotiations, or was this

 5     something else?

 6        A.   At the time, they set up their own municipality, but they also

 7     set up a war presidency which included even a Serb, Dusan Sehovac, for

 8     instance.  And I know that they chose, as the seat of the Muslim MUP of

 9     that Muslim municipality, Stup I, and I have reliable evidence to that

10     effect.

11             THE ACCUSED: [Interpretation] Thank you.

12             Can we admit the document, please?

13             JUDGE KWON:  Yes.

14             THE REGISTRAR:  Exhibit D1208, Your Honours.

15             THE ACCUSED: [Interpretation] Can we now have 65 ter 01512.

16             MR. KARADZIC: [Interpretation]

17        Q.   This is a daily report issued by the Ministry of the Interior for

18     the 8th of May.  The fourth bullet reads:

19             "The Serbian forces continue to hold a firm grip on all the

20     territories seized in all the areas of the town.  In particular, control

21     was established over the parts of the town running along the valley of

22     the River Miljacka ..."

23             Et cetera:

24             "The Serb forces are in full control, and in some areas life of

25     all the inhabitants in the area has returned to normal."

Page 13707

 1             Does this correspond to the situation as it was ahead of that

 2     large attack on the 14th of May?

 3        A.   Yes, because as of the 22nd of April, we didn't have those

 4     frontal attacks and life could return to normal.

 5             THE ACCUSED: [Interpretation] Thank you.

 6             Can the document be admitted, please?

 7             JUDGE KWON:  Yes.

 8             THE REGISTRAR:  Exhibit D1209, Your Honours.

 9             THE ACCUSED: [Interpretation] Could we have 65 ter 30750.

10             MR. KARADZIC: [Interpretation]

11        Q.   This is a telephone conversation, or rather its transcript,

12     between you and a man called Grandic on the 12th of May.  And on page 1,

13     we can see that you are asking to speak to someone who's in charge.

14             Can we have the next page in Serbian and keep the English.

15             You got hold of someone who introduces himself to you as

16     Lieutenant-Colonel Grandic.  You say:

17             "Grandic," which means you're not really familiar with him --

18             Could we have the next page in English, please.

19             You are seeking to speak to Colonel Gagovic, and you want him to

20     do something to allow you to defend yourselves from those -- from the lot

21     from Hadzic.  Does it mean that on this date, the Muslims from Hadzici

22     were attempting a breakthrough?

23        A.   Precisely so.  On the 12th, the Muslims would launch a great

24     offensive at the Serb-held positions in Hadzici and at the Local Commune

25     of Blazuj, at the Mostarski intersection.  Obrad Popovic, the TO staff

Page 13708

 1     commander, and I would be compelled to deploy elements of our forces from

 2     the eastern side from Vojkovici and Kasindol to western side of the

 3     municipality on that particular day.  In this way, we would practically

 4     leave them in the hands of the TO Hadzici.  And at twilight, they would

 5     be handed over to their control.

 6        Q.   This man, Grandic, informs you here that he survived the column.

 7     Is it the column of the 3rd of May, when the Command of the 2nd

 8     Military District was being evacuated and came under attack by groups of

 9     volunteers?

10        A.   Yes, that's what it refers to, and that was unheard of.

11             Let me remind you that in 1912, when the Serbian Army liberated

12     Skadar, it had against itself the Turkish Army, but they allowed them to

13     withdraw towards Istanbul in a dignified way.

14             THE ACCUSED: [Interpretation] Thank you.

15             Can we have the last page in both versions.

16             MR. KARADZIC: [Interpretation]

17        Q.   Here, you go on to explain that this was a struggle for survival,

18     that Hadzici was as shaky as a castle made of cards, et cetera.  Is this

19     not yet another proof of the fact that you were unable to convince the

20     JNA into defending you?

21        A.   That's fully correct.  The JNA did not participate in the

22     fighting at all.

23             THE ACCUSED: [Interpretation] Thank you.

24             Can this document be admitted?

25             JUDGE KWON:  Yes.

Page 13709

 1             THE REGISTRAR:  Exhibit D1210, Your Honours.

 2             THE ACCUSED: [Interpretation] Can we now have 1D3075, please.

 3     1D3075.

 4             MR. KARADZIC: [Interpretation]

 5        Q.   So this is Ranko Mandic, the person in charge of the Information

 6     Service of the Crisis Staff, who cautions about the falsity of all the

 7     agreements.  And he says in paragraph 2, just as the agreement that was

 8     reached unanimously and made public by the BiH Presidency, the Muslim

 9     forces opened fire from all of their assets at Ilidza and Hadzici, their

10     goal being to seize the area of Hadzici, et cetera:

11             "At Sokolovic Kolonija, a settlement situated near Ilidza, they

12     are even seizing bacon and lard from the Serbian population, and they do

13     not allow the Serbs from Hrasnica, Sokolovic and Butmir to leave these

14     neighbourhoods, even though they have signed agreements to the contrary."

15             Is that consistent with the events of the 12th of May?

16        A.   Yes, this is absolutely correct.

17             THE ACCUSED: [Interpretation] Thank you.

18             Can it be admitted, please?

19             JUDGE KWON:  Yes.

20             THE REGISTRAR:  Exhibit D1211, Your Honours.

21             THE ACCUSED: [Interpretation] Can we now have 65 ter 30751.

22             MR. KARADZIC: [Interpretation]

23        Q.   This is your telephone conversation of the 13th of May, of the

24     same day, therefore, where you managed to get hold of Colonel Gagovic at

25     last.  I do believe that there's a translation of this.

Page 13710

 1             Could we have the next page in Serbian and in English, I believe.

 2     There must be a translation.

 3             JUDGE KWON:  I was advised that there's not.

 4             THE ACCUSED: [Interpretation] Right.  Then I'll just have to read

 5     a bit more.

 6             MR. KARADZIC: [Interpretation]

 7        Q.   You say here:

 8             "Those down there are constantly in contact with me."

 9             And you were asked:  "Which ones?"

10             And then you say:

11             "Those on the boundary with Hadzici."

12             And then the person you are talking to says:  "Well, I

13     believe ..."

14             And then you say:  "Well, I'll have to return fire."

15             And then the other individual tells you:

16             "You do know -- don't -- you do know that --"

17             I'm having problem with time.

18             So you were asked who was it who was engaging in contact with

19     you, and then you say:

20             "Those on the boundaries with Hadzici."

21             And then you say:  "I'll have to return fire."

22             And the unidentified male says:

23             "You do know -- don't -- you do know that -- it's been denied.

24     I think that the Serbian Assembly agreed that the truce, as it were, just

25     as did the army and the other ones, that focus should 100 per cent be on

Page 13711

 1     the negotiations in the next couple of days, so let's leave it at that,

 2     please."

 3             And then further down, the individual is asking you:

 4             "Are they opening fire?"

 5             And you say:  "Yes, they are."

 6             And you also say:

 7             "And they are building up forces."

 8             And the unidentified male says:

 9             "Well, if they are opening fire, everything that is done in

10     defence is allowable, but one should exercise full restraint ..."

11             Et cetera.

12             Is this a conversation with the Lukavica Barracks, where this

13     member of the Yugoslav People's Army is trying to dissuade you from

14     engaging in a fight, reminding you of the truce announced by the Serbian

15     Assembly, and in response you say that the municipality may fall unless

16     you return fire?

17        A.   Everything you've said is absolutely correct and is consistent

18     with the developments at the time at the front-lines of the municipality

19     of Hadzici and the edges of the Ilidza municipality.

20             THE ACCUSED: [Interpretation] Thank you.

21             Can we have it marked for identification?

22             JUDGE KWON:  No, we'll admit this.  1212, Exhibit D1212.

23             MR. TIEGER:  I think the problem is, Your Honour, there's no

24     translation.

25             JUDGE KWON:  Yes, I was mistaken.  We'll mark it for

Page 13712

 1     identification, pending English translation.

 2             THE ACCUSED: [Interpretation] Thank you.

 3             Can we have 65 ter 30761.

 4             MR. KARADZIC: [Interpretation]

 5        Q.   What follows next is your feverish activity on the 14th of May,

 6     1992.  Do you recall that date, Mr. Prstojevic?  Just yes or no.  Let's

 7     keep it as short as possible.

 8        A.   Yes.  It's only a day after the other thing.  Yesterday, it was

 9     the 13th; today, it is the 14th.

10        Q.   This is your conversation with a certain Tadija.  Maybe it's

11     Tadija Manojlovic, who later became the commander of the Artillery of the

12     Sarajevo Romanija Corps.  And I may be mistaken, on the other hand.

13             Further down, you say:

14             "I am expecting combat to break out any moment here on the right

15     flank near Vrutaci."

16             And further down, you say:  "It is almost started."

17             Can we have the next page in Serbian, please.

18             This is what you say here:

19             "Please, as soon as you have the time, come in.  I need people

20     urgently to come back to the positions.  I'm expecting fire or fighting

21     to break out any moment."

22             Can we have the next page, please.

23             And then he says:

24             "All right, I'll tell them, him, so let him --"

25             And then you say:  "Tell Gagovic."

Page 13713

 1             Is this fresh evidence that the JNA is totally unfeeling in

 2     respect of what you are suffering on the 13th of May, and they are just

 3     not moving?

 4        A.   It is true that on that day, at 5.08, we were attacked at the

 5     front-line, and the front-line was over 20 kilometres' long.  We had

 6     eight fatalities and fifty wounded, and the fighting went on for twelve

 7     hours, more than that.

 8             THE ACCUSED: [Interpretation] Thank you.

 9             Can this be admitted?

10             JUDGE KWON:  Yes.

11             THE REGISTRAR:  Exhibit D1213, Your Honours.

12             THE ACCUSED: [Interpretation] 1D3076, please.

13             We are going to get the English version too, I hope.

14             MR. KARADZIC: [Interpretation]

15        Q.   Is this your people from the Information Service, Ranko Mandic,

16     Nedeljko Zukic, that are issuing this piece of information, and it says:

17             "It is now 1730 hours and the battles at Ilidza go on.  They

18     started at 5.08, and they've been going on for more than 12 hours."

19             And then also:

20             "We found out that while withdrawing from Otes, the enemy

21     intentionally fired at a residential building with gas installations in

22     order to destroy this Croat neighbourhood which had refused to fight on

23     the side of the Muslims."

24             Does this correspond to what happened until 5.30?

25        A.   Yes, it is fully correct, and there are Croatian sources that say

Page 13714

 1     the same thing.

 2        Q.   Thank you.  Is it not evident, on the basis of this, that it is

 3     one neighbourhood fighting against another neighbourhood, and that there

 4     are no foreign troops there, or, rather, troops from somewhere else?

 5        A.   It is quite clear that there are no troops from anywhere else.

 6     Any well-intentioned person sees that.  However, I have to point out that

 7     on this day of the fighting, about 10 of Arkan's men were participating

 8     in this as well.  Perhaps there were a few more.  They are involved in

 9     the Stup front-line, where the fighting actually started.

10             THE ACCUSED: [Interpretation] Thank you.

11             Can we have this admitted?

12             JUDGE KWON:  Yes.

13             THE REGISTRAR:  Exhibit D1214, Your Honours.

14             THE ACCUSED: [Interpretation] Can we have 65 ter 30754.

15             MR. KARADZIC: [Interpretation]

16        Q.   Yet another one of your many telephone conversations on that day.

17     You are talking to Djogo, so this is Djogo and Prstojevic, and then

18     Prstojevic and Radivoje Grkovic.

19             It says here -- or, rather, Djogovic [phoen] is informing you

20     that he has talked to Gagovic and that contact should be established with

21     Deda and Sjever.  And then you say there is an all-out attack in your

22     area.  And then he says:

23             "All right, it's the same over here too."

24             Is he talking about the eastern part of Ilidza, east of the

25     airport, Nedzarici?  Where are they at that point in time?

Page 13715

 1        A.   At this point in time, they are in Nedzarici; that is,

 2     Captain Djogo.  However, the attack at the airport is an attack at the

 3     airport area, Ajramsko Naselje [phoen].  It is a single whole.  There was

 4     a strong attack against the airport on that day.

 5        Q.   Thank you.  The JNA is not getting involved, they are only

 6     talking; right?

 7        A.   No, no, they are in Lukavica.

 8             THE ACCUSED: [Interpretation] Thank you.

 9             Can this be admitted?

10             JUDGE KWON:  Yes.

11             THE REGISTRAR:  Exhibit D1215, Your Honours.

12             THE ACCUSED: [Interpretation] Can we have 65 ter 30758.

13             MR. KARADZIC: [Interpretation]

14        Q.   It's the same day.  It is Djogo and Mandic -- and Mandric who is

15     talking.  It's probably Mandric.

16             Mandric says:

17             "Here we are.  We've taken Cenex and we're holding it."

18             So there was a counter-offensive and Cenex was taken.  Does Cenex

19     belong to the minister of the interior, Delimustafic?

20        A.   I heard that it was his building that was under construction

21     during the war, enormous concrete hallways and elements.

22        Q.   Thank you.  Look further down.  Mandric says:

23             "There is an assault from another side through a street."

24             And then it says:  "From Energoinvest?"

25             And Mandric is saying:

Page 13716

 1             "Can you send me an APC, by any chance?"

 2             Can we have the Serbian version, page 2.

 3             Djogo says:

 4             "No way.  You know how heavy the attacks are from Vojnicko Polje,

 5     I think, Alipasino.  These men here have just called Gagovic.  Now, we

 6     have to hold on to this at any cost."

 7             And then he says:

 8             "I have information that 500 had set out from Alipasino, 200 from

 9     Vojnicko."

10             And then he's talking about that assault in that street, is this

11     street-fighting?

12        A.   Well, this is an urban area.  It is street-fighting.  Throughout

13     the war, we were able to go to Nedzarici only during the night, but we

14     did hold that settlement:  As for this assault from Vojnicko Polje that

15     is referred to, that is close to the airport and Ajramsko Naselje.  If

16     you look at it from their side, it is the left flank, and the right faces

17     Nedzarici.

18        Q.   Thank you.  You are being quoted here as having said that:

19             "Stup has to be cleared today."

20             Cleared of what, Mr. Prstojevic?

21        A.   Well, we have defended ourselves, and now I am putting forth a

22     clear request that it has to be clear of enemy soldiers or that enemy

23     soldiers should be mopped up.  At one point, our troops want to withdraw.

24     And this is what I'm literally saying to Captain Djogo, Tell them it's

25     better to get killed by the Turks than to get killed by the Serbs,

Page 13717

 1     because we are resolute, we do not have any reserve positions.  It is

 2     only possible to enter Serb neighbourhoods by going over the dead, going

 3     over dead bodies.

 4             THE ACCUSED: [Interpretation] Thank you.

 5             Can this be admitted?

 6             The transcript doesn't reflect that you said that -- you said

 7     that that there were no reserve positions, that there can be no

 8     withdrawal.  That's what you meant; right.

 9        A.   Precisely.  Throughout the war, Ilidza did not have any reserve

10     positions, throughout the war, during those four years of war.

11        Q.   So if the front-line breaks, everything is done and over with?

12        A.   If it breaks, then they withdraw to the next house, and then they

13     try to retake what was lost.  And there are examples like that.

14     Murat Kahrovic describes this in detail in his book, "How We Defended

15     Sarajevo:  The 1st Sandzak Brigade."  From July until the end of

16     December, they all got killed in this part of the front-line here, and he

17     describes all of that very specifically and in detail.

18             THE ACCUSED: [Interpretation] Thank you.

19             Can this be admitted, or, rather, marked for identification,

20     because Mr. Prstojevic is not one of the interlocutors, but people who he

21     does know.

22             JUDGE KWON:  Yes.

23             THE REGISTRAR:  As MFI D1216, Your Honours.

24             JUDGE KWON:  Yes, Mr. Tieger.

25             MR. TIEGER:  Yes, I just want to make a request that the accused

Page 13718

 1     not depart from the text of the documents in question, imposing

 2     questions.  I mean, there are many formulations posed to the witness with

 3     which he's asked to agree, but, in any event, they shouldn't take the

 4     form of -- and particularly, for the record, of appearing to be part of

 5     the document in question.

 6             In this case, it was an addition to what was ostensibly said by

 7     one of the participants in the intercept after it was clear that there

 8     was no further comment in the transcript from that person.

 9             JUDGE KWON:  Thank you, Mr. Tieger.

10             Bear that in mind, Mr. Karadzic.  Please continue.

11             THE ACCUSED: [Interpretation] Certainly, Excellency.  I just wish

12     to give you the entire name.  For example, if it is put in very brief

13     terms, "Vojnicko," it is actually "Vojnicko Polje," so that's why I'm

14     trying to clarify matters.

15             30757, can we have that, please.

16             MR. TIEGER:  Sorry, I notice Mr. Karadzic did that as well.  I

17     didn't object to that.  It was the last comment after the interlocutor

18     Djogo had finished speaking, and there was an additional that was

19     attributed to him after there was no further comment from Djogo other

20     than:  "Okay."

21             MR. KARADZIC: [Interpretation]

22        Q.   Could I ask you to confirm whether this was a conversation

23     between you and Mr. Gagovic on that same day?  So you finally managed to

24     get in touch with him and you're flattering him a bit, Great leader,

25     whatever.

Page 13719

 1             And you say:

 2             "I do not have power for recoilless guns."

 3             And he says:  "I know all about that."

 4             And you say:

 5             "Can anyone bring it to me?  And four of their APCs are in the

 6     middle of a combat by the Institute."

 7             Gagovic says:  "Okay."

 8             And then you say:

 9             "I know you want to help.  Do this and we can shake on it when I

10     come to see you tomorrow."

11             "Okay."

12             So you promised that you would kiss him, embrace him only if he

13     helped you?  Was this your conversation?

14        A.   Yes.  I listened to this conversation and I recognised my own

15     voice, but I know that on that very difficult day during the war, I had

16     this conversation at this institute.  Quite a few of our men got killed.

17             THE ACCUSED: [Interpretation] Thank you.

18             Can this be admitted?

19             JUDGE KWON:  Yes.

20             THE REGISTRAR:  Exhibit D1217, Your Honours.

21             THE ACCUSED: [Interpretation] P1086, can we have that, please.

22             MR. KARADZIC: [Interpretation]

23        Q.   It is that conversation during which you are leaving your rifle

24     aside.  It's the end of the day.  And as you had put it, if it is looked

25     at as an isolated thing, you like a raven, everything is so dark.

Page 13720

 1             Do you say:  "Good evening"?

 2        A.   Yes, yes.

 3        Q.   Is this, at any rate, after 5.00, which means that the fighting

 4     had gone on for over 12 hours?  If it started at 5.08, and it is a May

 5     evening, so it's rather late, is it correct that the fighting went on

 6     considerably longer than 12 hours?

 7        A.   Yes, yes, at different front-lines, yes.

 8        Q.   Thank you.  The men who got killed and who were wounded, were

 9     they persons who had lived there, and are their families there, the

10     families that are supposed to bury them?

11        A.   Absolutely.  These are all local people from Ilidza, from

12     different neighbourhoods that are the closest to the defence line.  We

13     mobilised people in such a way so that they would be defending their own

14     homes, where it was the quickest for them to reach the front-line on

15     foot.

16        Q.   Thank you.  At that moment, are you the number-one man, with top

17     responsibility, as far as these people are concerned?

18        A.   Absolutely.  If anything is wrong, then I'm to be blamed the

19     most.  And if things go well, then it is everyone's merit.

20        Q.   Thank you.  Because of this tremendous psychological pressure and

21     the very real armed pressure, did some people -- some Serb officials

22     resign even before this happened because they could not take all that

23     responsibility?

24        A.   Yes, some officials tender their resignations, and some just ran

25     away, fled from Ilidza.

Page 13721

 1             THE ACCUSED: [Interpretation] Thank you.

 2             Can we have the next page in the Serbian version.

 3             MR. KARADZIC: [Interpretation]

 4        Q.   What is identified here is that Mika called you:

 5             "Mika called me."

 6             And you are trying to establish what it was that Mika wanted, and

 7     they are informing you that they have people from Kotorac.  And you are

 8     asking whether they were arrested, and what they did with them, and so on

 9     and so forth.

10             You see this entire conversation, and he says:

11             "They're down there by the road.  Women and men are separated."

12             And then it says:

13             "I've just been informed men are in prison in Kula and the women

14     have gone towards Butmir."

15             Can we have the next page in Serbian.  I think that we have the

16     correct page in English.

17             And now here you inquire whether they were mopping up Kotorac.

18     And further on, we can all see the conversation, and you are asking

19     him -- appealing to him:

20             "In God's name," you say, "why did you take women to Butmir?"

21             And he says:

22             "Not to the KP Dom, but to Butmir, the settlement, so to speak."

23             I'm just paraphrasing it now.  I'm not reading.  And you said,

24     They couldn't go to Butmir because we would be mopping up Butmir in time

25     as well, and so on and so forth.

Page 13722

 1             And down towards the bottom:

 2             "Come on, tell me.  The one who would accept the Orthodox faith

 3     might stay, and so also the women and the children."

 4             Do you remember what they published in the "Vox" magazine, that

 5     the Serbs who would convert to the forefathers' faith of Islam would be

 6     safe?

 7        A.   Well, look here, Mr. President.  At this moment, I didn't know

 8     what my name was.  I had eight killed, fifty wounded, and my territory

 9     was in danger.  Someone called me here and used his code-name, which we

10     didn't normally do, and someone was interfering with the conversation.

11     And later on, I called the man who was the manager of the chicken farm,

12     but I was so beside myself, I was probably talking with

13     Milenko Tepavcevic, who was the chief of the Public Security Station in

14     Kula.  I say "probably."  And I asked to speak to him.  I'm not aware

15     that I'm already speaking with him, but everything seems to indicate that

16     I am.  And practically what is requested here is that I should give my

17     approval.

18             It is well known when darkness falls in the month of May.  So for

19     what had happened up until 2.30 p.m., what's the substance?

20             On that day, from the enclave of Gornji Kotorac, which is two

21     kilometres in the depth of our territory, they joined the general all-out

22     attack on Ilidza, but to the east.  There was a reaction to that from the

23     police station in Kula, which had numerous staff and which is at the

24     bottom of the hill in the direction to this settlement.  It is actually a

25     part of the settlement.  And the people from the military police, or the

Page 13723

 1     Territorial Defence, or the JNA; I could not determine which of these.

 2     But it says here it was Grujo Kutlaca, literally, was wearing a

 3     camouflage uniform, and the Territorial Defence at that moment did not

 4     have camouflage uniforms; but it's all the same, who it was.

 5             The essence is this:  They launched an attack against Kasindol

 6     and lower settlement of Lubore [phoen] and in the direction of Donji

 7     Kotorac.  The MUP reacted, and the police frisked and seized weapons.

 8     It's noted how many weapons they took away.  Some Muslims remained there,

 9     but it was more or less just 70 households.  The others, according to

10     their own wish, went wherever they wanted to in luxury cars, on tractors.

11     And between the place where I was talking and the Muslim defence line,

12     the distance was only 300 metres in one place.  In another place, it was

13     700 metres.  So the population had decided that who wanted to stay could

14     stay, and who wanted to leave could leave, according to their wish.  The

15     able-bodied were taken to prison if they were found with weapons, and

16     they remained in prisons for about 10 days and then they were set free.

17             So all the discussion about the 70 households is here, if someone

18     wants to try to use this as a basis to build a theory that we were doing

19     anything there.

20        Q.   Thank you.  And did you ever -- did it ever come to pass that

21     Butmir would also be mopped up, or was Butmir left in peace from our

22     part?

23        A.   We left Butmir in peace.  And, look here, I was not doing

24     anything.  Butmir would be mopped up, so Sokolovic Kolonija would be

25     mopped up, Hrasnica would be mopped up.  But when I calm down for a

Page 13724

 1     minute or two, I then said, Butmir will be mopped up.  Go on and tell the

 2     men.  It was just formal.  It was moral.  We never attacked these areas.

 3     In order to attack them, we had to have an order from the corps, an order

 4     from brigades, and no one could have that.  I claim this with full

 5     responsibility, and no one had it.

 6             There is also a point from the meeting which took place, I

 7     believe, on the 12th or the 20th of September, when General Mladic said,

 8     Liberate.  That was a strategic trick, because during passing on the

 9     information and reporting that would reach the soldiers at the lowest

10     level and the soldiers' wives, and therefore the Muslims would learn it

11     too, that was just a trick so that later on Lukavac 93 operation would be

12     launched.  I considered this later on, and it was 90 per cent like this.

13             THE ACCUSED: [Interpretation] Thank you.  It was not recorded

14     that the witness said at one moment, I became very angry, but then he

15     added he calmed down very quickly.

16             Tomorrow, or, rather, on Monday, we will show a map of Butmir.

17             MR. KARADZIC: [Interpretation]

18        Q.   Is it correct that from Butmir, they attacked only the airport,

19     and that the Serbian settlement of Ilidza was not attacked by the local

20     Muslims, and that that was why you did not turn against Butmir?

21        A.   In one or two first battles, they attacked Ilidza, and they would

22     have two APCs from there.  But on the 14th, when I talk about this

23     battle, of the 180 of their soldiers, 140 deserted immediately after the

24     first clash and, I don't know, several hours of fighting.  And later on,

25     as it developed, after this 14th of May, and on the 4th of August, during

Page 13725

 1     the attack on the eastern part, they simply will not have enough strength

 2     or will to attack us, because they had casualties on the side and the

 3     local Muslims did not wish to lose their lives and to attack.  And we did

 4     not touch them later on.  It was practically decent peace that we had,

 5     especially towards the centre of Ilidza.

 6             And in the eastern area, in the direction of Kotorac, well,

 7     there, those from Donji Kotorac killed some civilians by sniper fire,

 8     civilians and passersby on the Lukavica-Bijelo Polje-Kupres-Trnovo road.

 9             THE ACCUSED: [Interpretation] Thank you.

10             This is a document that has already been admitted.

11             Can we now have 1D3077, please.

12             MR. KARADZIC: [Interpretation]

13        Q.   Do you agree, Mr. Prstojevic, that whether one becomes angry or

14     not, flares up or not, it does not really mean that if you said

15     something, that it was really implemented?  Would you agree with me that

16     much more is said than done?

17        A.   Yes, I agree.  I simply lost control over myself, and nothing

18     came about of what I then said.

19        Q.   Is this the police station in Ilidza, the

20     National Security Department, and it says here:

21             "Attack on Ilidza, the 14th of May."

22             And it says:

23             "Retain this analysis --" or, rather:  "Keep it."

24             Is that correct?

25        A.   Yes, it's correct.

Page 13726

 1             THE ACCUSED: [Interpretation] Thank you.

 2             Can we please move on to the next page.

 3             MR. KARADZIC: [Interpretation]

 4        Q.   Is it correctly described here, how things developed, and the

 5     last three lines:

 6             "At 0550 hours, an infantry attack which was fierce started with

 7     fire opened from infantry weapons on the vital sections of Ilidza," as it

 8     says?

 9             And up there, it says on the 13th of May, at 1700 hours, it was

10     called to the police station that an attack against Ilidza was to be

11     launched from the direction of Stupsko Brdo?  Did your police station

12     inform you about this piece of information?

13        A.   Well, yes, this is the original report from the

14     Serbian National Security.  And if you can see, our press centre also

15     announced the attack one day ahead.  So everything you can see here is

16     absolutely correct.

17             THE ACCUSED: [Interpretation] Thank you.

18             Can we now please see page 5.

19             Another page onwards, please.  And in English -- yes.

20             MR. KARADZIC: [Interpretation]

21        Q.   It says here that:

22             "During the attack on Ilidza, the following members of the

23     Serbian forces were killed:  Andzic, Sava; Gajic, Zoran; Janjic, Dragisa;

24     Kocic, Andras."

25             And you also seem to have had a Hungarian living in Ilidza;

Page 13727

 1     correct?

 2        A.   Well, I don't know that, but I can judge by his last name.  Of

 3     these men who were killed, I only know one, for instance.  I knew one at

 4     that time.

 5        Q.   And two other unidentified soldiers, you say a total of eight

 6     wounded and fifty -- or eight dead and fifty wounded?

 7        A.   Yes.

 8        Q.   Do you know the wounded, more or less?

 9        A.   These were all the locals.  Generally, I recognise their last

10     names.  As soon as I see a last name, "Staka," for example, he's from the

11     Vrelo Bosne.  Then Suco Naselje, Nedzarici, Vojnicko Polje, Pindzo,

12     directly at the front, where most people were killed, that's where their

13     houses were.  Krajisnik, directly at the front-line.  Tosic, likewise.

14     These were the men who were closest to the confrontation line.

15             THE ACCUSED: [Interpretation] Thank you.

16             Could we now see the last page, please, so that we could see the

17     number of the 50 wounded, so that we wouldn't owe anything to them.

18             MR. KARADZIC: [Interpretation]

19        Q.   Kocic is the last name.  The first name was not known at the

20     moment.  Is that the list of the 50 men?

21        A.   Yes, yes.  Yes, but the best information can be obtained from our

22     Zica Hospital.  But this is correct, because it was made after the

23     battle.

24             THE ACCUSED: [Interpretation] Thank you.

25             Can it be admitted?

Page 13728

 1             JUDGE KWON:  Yes.

 2             THE REGISTRAR:  Exhibit D1218, Your Honours.

 3             THE ACCUSED: [Interpretation] Thank you.

 4             MR. KARADZIC: [Interpretation]

 5        Q.   If you agree, Mr. Prstojevic, on Monday, we would discuss the

 6     alleged ethnic cleansing, and para-groups and paramilitaries, and then I

 7     would like us to shed light, in the time that remains, on the nature of

 8     our relations between you and me.

 9             So if we could now have 65 ter 30549.

10             In one of your statements, you confirmed that before the war or,

11     at any rate, before the multi-party political system was introduced, we

12     had not known each other; is that correct?

13        A.   Yes, it's absolutely correct.  It wasn't only you; I didn't know

14     anyone from the leadership of Republika Srpska and the SDS before the

15     war.  At the Municipal Board of the SDS in Ilidza, I only knew one man

16     from Kasindol.  We were completely unknown to one another.  We didn't

17     know what the other person used to do before the war, what education he

18     had, how worthy or unworthy he was, and so on and so forth.

19        Q.   Thank you.  Was that because not only the government changed, but

20     so did the whole system, Mr. Prstojevic, and the new authorities included

21     people who previously did not have any power?

22        A.   Yes, precisely, because they now entered the politics, they

23     became members of political parties.  These were people who had not been

24     in power earlier, and, therefore, their names were not well known.

25             THE ACCUSED: [Interpretation] Can we please have a look at the

Page 13729

 1     next page.  I believe we need the next page in English as well.

 2             MR. KARADZIC: [Interpretation]

 3        Q.   Let me just focus on this part.  It's the fourth or fifth from

 4     above in Serbian, "Nedjeljko Prstojevic":

 5             "This is not the line, you say.  We honour what you said when you

 6     did as you say.  Any man of another ethnicity who is in favour of

 7     Yugoslavia has a maximum of -- so the line would not be according to

 8     membership, he's not even a member.  Simply, he is not good enough.  Then

 9     we should leave these men, the Council of the Assembly ..."

10             And so on.

11             You are talking about relieving someone, relieving a person from

12     his or her post, and this is what we're discussing.  And you confirm that

13     you know that my position is that ethnicity cannot be an important

14     factor; isn't that so?

15        A.   Yes.  But this person was the secretary of the

16     Kasindol Local Commune, and it was a Serb woman.

17        Q.   Thank you.  Later on, I tell you:

18             "Okay, listen.  Let me tell you, let -- first, set up the

19     commission, have a commission be set up, and someone from our

20     Executive Board should be in it to see whether the allegations are

21     correct ..."

22             And so on:

23             "This has to be systematised and well documented.  Otherwise, it

24     will cause divisions of the Serbian people and will cause breaks among

25     the Serbian people to appear.  In some cases, it is better and wiser not

Page 13730

 1     to do it.  That is not the most urgent job at this moment."

 2             Could we see the next page, please, in both versions.

 3             But you said it was difficult, you didn't want to yield, and I

 4     said:

 5             "Hmm.  Listen, please, see to it, still see to it that ..."

 6             And so on and so forth.

 7             "... that the commission be set up, to consider it in all

 8     fairness and to determine whether it is necessary to do so.  And in case

 9     it is, we shall see what the arguments are.  We mustn't ..."

10             And so on.  And then further on I said that we must not -- that

11     the whole case should be examined, that the Serbs should not be divided

12     into various kinds.  And towards the bottom, I said:

13             "Then we should see.  If she really needs to leave, then an

14     option should be found, that it should be a transfer from one post to

15     another and to vacate one.  But dismissing someone and creating chaos

16     among the Serbian people, we mustn't do that.  It's better to stick with

17     the person and to correct the person, to demand things from him, then to

18     carry out a pogrom."

19             And then it says:

20             "You notice that Alija kept all his investigators ..."

21             And can we please turn to the next page in B/C/S:

22             "... who investigated him and beat him up in prison.  They still

23     work with the Secretariat of the Interior, even on higher positions."

24             And then you say:

25             "Okay, I have fully understood you.  But just to let you know,

Page 13731

 1     there's going to be this problem in Ilidza.  There's the issue of the

 2     secretary of the local community, Vojkovici.  There's also some problems

 3     in Krupac, et cetera, et cetera."

 4             And then I say:

 5             "And why in Vojkovici and Krupac?

 6             And then you say:

 7             "The same situation.  The people will not hear of that secretary,

 8     they just won't, and there has been a competition and the election will

 9     follow, because they cannot even prove legally that the regulation is

10     against the law.  They simply don't want him."

11             And then I say:

12             "Well, that won't do.  It mustn't be done that way.  Believe me,

13     Mr. Prstojevic, this is precisely what must not happen.  They cannot

14     prove that he did something wrong, but they still don't want him, they

15     cannot not want him, they cannot not want him.  This is a professional

16     post.  It is not a post to which someone has to be elected.  You have to

17     prevent that both in Krupac and then in the other place.  It mustn't be

18     done that way.  That would actually mean enforcing pure political will

19     against the legal regulations.  That mustn't be done.  That is what the

20     Communists did in 1945.  No errors, no mistakes, but they don't like him.

21     Please prevent that."

22             And so on and so forth.

23             Do you remember this conversation we had and the squabbling over

24     the phone?  It was the 11th of February, before the war, was it not?

25        A.   Yes, I remember this.  I listened to this intercept, and I

Page 13732

 1     recognised your voice and mine.

 2        Q.   Thank you.

 3        A.   And this is the first conversation we had, and soon there would

 4     be no conversations thereafter.

 5        Q.   Thank you.  Let's look at the transcript further down:

 6             "Believe me, as a democratic party, we must not allow this.  And

 7     as for the political will and for somebody liking someone or not, well, I

 8     wouldn't be socialising with half the people I co-operate with.  I would

 9     steer clear of them, just as I would with any smelly cheese.  But I have

10     to stick with them, because I don't have the right to introduce the

11     element of like or dislike."

12             Do you remember that?

13        A.   Yes, I do.

14             THE ACCUSED: [Interpretation] Thank you.  Can we have the next

15     page?  Or, rather, no, there's no need for that anymore.  You've had a

16     chance to look at it.

17             MR. KARADZIC: [Interpretation]

18        Q.   This intercept was used as proof of my intention to take control

19     of the municipalities around Sarajevo, to seize power there, and this is

20     part of our pre-trial brief.  Mr. Prstojevic, in our language, could you

21     make a distinction between "take" and "retake"?  Would "take" not mean

22     that you are taking something, whereas "retake," that you are taking it

23     from someone else?

24        A.   Yes, clearly, that is the distinction.

25        Q.   If you recall, we were criticised by people of having taken power

Page 13733

 1     at the elections and that we had handed over some important positions to

 2     experts.  I believe that the man you had in your municipality was not a

 3     member of the party either.

 4        A.   No, he wasn't.  Not even Mr. Kovac, the chief of the police

 5     station, was a member of the party.  The commander of the TO staff,

 6     Dragan Markovic, was not a member of the party, et cetera.

 7        Q.   Thank you.  Before the war, when we were still hoping that there

 8     would be no war, that a transformation would take part and that we would

 9     be given our republic, if at that point in time I say at our plenum

10     sessions, Please take the power in your hands, am I referring to the fact

11     that we should take charge of things or that we should take power from

12     someone else?

13        A.   It's quite clear that what you mean is legal and legitimate

14     taking of what belongs to us.  Before the war, we didn't have a firm

15     footing, because the administration that had been there from before was

16     still in power, it had a firm grip.  And to put it simply, we weren't

17     used to exercising power, to being in power.

18             THE ACCUSED: [Interpretation] Thank you.

19             If the document has not been admitted, I'd like to tender it now.

20             JUDGE KWON:  Yes.

21             THE REGISTRAR:  Exhibit D1219, Your Honours.

22             JUDGE KWON:  1219.

23             MR. KARADZIC: [Interpretation]

24        Q.   Mr. Prstojevic, it follows from this conversation that you

25     weren't all that frightened of me.  Do you know anyone else who was?

Page 13734

 1        A.   Mr. President, this conversation ended with me sticking to my

 2     position and saying that we would adhere to the law in everything we do.

 3     So despite all the discussions we had, I stuck by my view.

 4             Second, I don't know of anyone who was frightened of you.

 5             Third, 1995, after the Dayton, Mr. Krajisnik's office was against

 6     me going to Tuzla when the president of the US was supposed to come

 7     there.  Only two mayors went there, those of Banja Luka and Ilidza, and

 8     our metropolitan.  And regardless of the view of the office, I went

 9     there.

10             In that same year when State Secretary Warren Christopher came to

11     Sarajevo, when the security of the Serbs was being viewed in light of the

12     Dayton Accords, and the issue was discussed as to whether they could

13     remain in federal Sarajevo, Krajisnik's office directly told me not to go

14     to that meeting.  The Banja Luka mayor obeyed that instruction; I didn't,

15     just as the metropolitan didn't either.  I didn't jostle for positions.

16     I was forced to become the head of the Ilidza municipality.  I led the

17     party during the war on a voluntary basis.  And after the war, I handed

18     over the power over the municipality before the elections.  My assessment

19     was that this was in the interests of the people of -- whom I represent,

20     and I would not have gone against my views or positions on any score had

21     I not judged that this was in the interests of my people.

22             THE ACCUSED: [Interpretation] Was this given a number?

23             Can we have 65 ter 08715, please.  01875 is the 65 ter number.

24     Page 46 in English and 40 in Serbian in e-court.

25             I don't think that's the right number.  It may be our mistake.

Page 13735

 1     It's a statement from 2003.  8175, it should be 8175.  That's not the

 2     document.  This could be right.

 3             MR. KARADZIC: [Interpretation]

 4        Q.   Mr. Prstojevic, you'll see the Serbian version -- or, actually, I

 5     don't know if there is one.  There should be one, because it's page 40 in

 6     Serbian.  It reads:

 7             "It can be seen from the telephone conversation that Mr. Karadzic

 8     asked that things be done the way he thought they should be done.

 9     However, I stuck by my position, which was that agreed at the inter-party

10     discussions about the status of the secretary, and there was a certain

11     legal form to it as well."

12             Is this something that is consistent with the events, and is this

13     something that you stated in 2003?

14        A.   Yes, that's absolutely correct.

15        Q.   Thank you.  Please look at the part where it says:

16             "See, practically, the transfer of power was carried out, and the

17     last post was that of secretaries of local communes, so these were the

18     least significant posts.  Such a strong conversation between me and

19     Karadzic is something that was due to the fact that we hadn't met before

20     or shaken hands, and he wondered at the fact that somebody would refuse

21     to automatically accept whatever the suggestion was made to him.  And

22     later on, he asked who was that Prstojevic, and what was his position.

23     And as a person who was of some significance before, and where the issue

24     of honouring the will of the people and the agreed procedure was at

25     stake, I wanted the things to take that course without the interference

Page 13736

 1     of either me or President Karadzic ..." et cetera.

 2             Is this how it was?

 3        A.   Yes.  Previously, I was a younger man, I lived in Sarajevo, and I

 4     was able to clearly explain all the various elements to that

 5     conversation, more than I am able to do so today.

 6             THE ACCUSED: [Interpretation] Thank you.

 7             JUDGE KWON:  Yes.  Please put a pause.

 8             THE ACCUSED: [Interpretation] Is this sufficient, to have this --

 9     or should we have this page admitted only?  I think we have enough in the

10     transcript.

11             MR. TIEGER:  In this case, you probably want the page, I think.

12             JUDGE KWON:  Very well.  Mr. Tieger, so you want that page to be

13     admitted?

14             MR. TIEGER:  Yes.  I think that would be preferable in this

15     instance.

16             JUDGE KWON:  I think that's fair enough.  We'll admit it.

17             THE REGISTRAR:  As Exhibit D1220, Your Honours.

18             THE ACCUSED: [Interpretation] Can we have 65 ter 07177.  We've

19     had it before, 07177, page 71 and continued on 72.

20             MR. KARADZIC: [Interpretation]

21        Q.   From line 18, I will be reading in English, and it will be

22     interpreted to you:

23             [In English] "Q.  Let me ask you first about both the power to

24     appoint people and the power to terminate people.  For appointment to

25     positions in Sarajevo, did both Mr. Karadzic and Krajisnik have to give

Page 13737

 1     approval or one or the other or neither?"

 2             [Interpretation] Answer:

 3             [In English] "At this point, we should distinguish between

 4     various levels of authority, of government.  Neither President Karadzic,

 5     nor President Krajisnik, interfered or got involved in the election of

 6     officials into the Municipal Board of the SDS or municipal assemblies."

 7             [Interpretation] Was this your answer, and do you stand by that

 8     answer today?

 9        A.   That was my answer, and that was true.

10             THE ACCUSED: [Interpretation] Thank you.

11             Is what we have in the transcript sufficient or should we admit

12     it?

13             JUDGE KWON:  I take it his answer is continued on the next page.

14             THE ACCUSED: [Interpretation] Yes, yes.

15             MR. TIEGER:  I think we need at least the full answer,

16     Your Honour, at a minimum, which, as the Court notes, continues on the

17     next page.

18             MR. KARADZIC: [Interpretation]

19        Q.   Is it correct, what you said, that Karadzic, Krajisnik, and I'll

20     expand that to anyone on the top, had any of them interfered with the

21     lower levels in the democratic election procedures of various

22     representatives?

23        A.   You see, Mr. President, it is absolutely correct that nobody

24     interfered from among you in the prewar elections of the Municipal Board

25     and various office-holders.  There is one point which is unclear, which

Page 13738

 1     has to do with the Ilidza Municipal Board members.  I set out from the

 2     railways company to take up the post of the economy secretary, and there

 3     were stories about efforts in favour of Bozo Antic becoming a secretary

 4     for the economy, and that's why I became a secretary for inspection.

 5     That was all, and there was nothing more than that.

 6             Now, at the level of town, since Mr. Krajisnik hails from

 7     Sarajevo -- I'm not really in a position to know this, but this was the

 8     middle level which was dealt with by other people.

 9             THE ACCUSED: [Interpretation] Thank you.

10             Can we now have 65 ter 08175, page --

11             JUDGE KWON:  Just for the convenience, shall we admit the two

12     pages?

13             MR. TIEGER:  Yes, Your Honour.  I think that's --

14             JUDGE KWON:  Yes, that's fair.

15             THE REGISTRAR:  That's Exhibit D1221, Your Honours.

16             THE ACCUSED: [Interpretation] Can we have 65 ter 08175, page 36.

17             "SM" asks -- is this page 36 in e-court?  From what I can see, 36

18     doesn't fit into the picture.

19             There we have it at the bottom:

20             [In English] "Was there anything specifically that you can recall

21     that you were asked to do that you refused to do?"

22             [Interpretation] Can we have the next page in English, please?

23             MR. KARADZIC: [Interpretation]

24        Q.   Your answer, I will read it in English, because I am not sure

25     where it is in the Serbian:

Page 13739

 1             [In English] "You see this case, and I think at the Assembly when

 2     I was talking, but that was the -- after this date.  During the break, I

 3     kindly asked Mr. Karadzic to hear one question from me.  He told me, in a

 4     very harsh way, 'It's enough to spend a minute with everyone, that's

 5     killing me.'  So I did not ask the question, and I wanted to ask -- that

 6     I wanted to ask him.  And for a longer period of time, it was visible

 7     that there was a pretty big distance between two of us.  I did not have

 8     clear access to Karadzic, so these contacts had to be done by other

 9     people."

10             Is this correct, and did you state this in 2003?

11        A.   This is correct, and this is what I stated.  But let me add

12     something.

13             It was only in 2009 that I got translations into the Serbian

14     language from the interviews from 2003, 2005 and 2006, and then I had

15     about 15 objections that were of crucial value, objections to

16     interpretation or to what the investigator said from where I told one

17     Jonathan Harris.  I did not say that.  Then there was a break, and then

18     he continued after a pause and said, You said this and that.  That was

19     obviously malicious, but at the time I believed that investigators were

20     interested in truth, rather than that they wanted to prove what was not

21     truth.  And I did not know how to oppose them sufficiently so as to

22     request that people who were malicious should not take part in this,

23     because I asked for Haris Silajdzic.  There are errors here.  This is

24     correct, but in many other instances there are errors, and I have it here

25     in handwriting.

Page 13740

 1             THE ACCUSED: [Interpretation] Thank you.

 2             Can we now see page 27 in the English version and page 16 in the

 3     Serbian version, please, from the same document.  I think it's

 4     65 ter 07857, unless it's an error.  I think it's the same document, but

 5     page 27.  Page 27 in the English version and page 16 in the Serbian.

 6             I'm sorry, this is on the 27th of November, so we need

 7     65 ter 07875.  07875, and we need page 27 in the English version and 16

 8     in the Serbian one.

 9             MR. KARADZIC: [Interpretation]

10        Q.   It says here:

11             [In English] "Now, at the end of 1992, you were effectively

12     promoted.  You became a member of the Executive Board of the SDS, and you

13     also mentioned yesterday that at one stage, you became a member of the

14     Main Board.  Was it your understanding that the manner in which you

15     carried out your tasks in 1992 was approved by the leadership of the

16     SDS?"

17             [Interpretation] And here is your answer:

18             "At the same session, at the same meeting that is called

19     'Jahorina ple num,' I do not remember really when that session happened.

20     I was elected to the Executive Board and to the Main Board.  That was not

21     an easy procedure.  Mr. Karadzic, in particular, was breaking, pulling

22     the break for this appointment, he was pushing for another candidate.

23     But Ilidza, as the municipality and its army, had a very strong authority

24     among the people and among the members of the then Executive Board and

25     Main Board.  And some people worked with me in ZTP, and they knew me from

Page 13741

 1     the economy.  And upon their constant insisting, I passed."

 2             [Interpretation] Is this what you said?  Was it really like that,

 3     the way it happened?

 4        A.   Well, it was precisely that, what happened.  And I got more votes

 5     than your candidate, Mr. President.

 6             THE ACCUSED: [Interpretation] Thank you.

 7             I believe that we do not need to admit this document.

 8             JUDGE KWON:  Yes, Mr. Tieger.

 9             MR. TIEGER:  Sorry, Your Honour.  If I could have a couple of

10     bits of clarifying information.

11             I saw this is from the 27th of November, and if I could have --

12     it would be helpful to know the -- if it's apparent to the accused, the

13     starting point of the tape, that is, the time the tape began.  It helps

14     to identify among the several ones, if it's known.

15             JUDGE KWON:  Okay, that can be done outside the courtroom.

16             THE ACCUSED: [Interpretation] I would really inform Mr. Tieger

17     kindly, but I don't know.  I just know that the page is 27.

18             If it has been recorded in the transcript, we might move on to

19     another document.

20             JUDGE KWON:  The last document for today.

21             THE ACCUSED: [Interpretation] Thank you.

22             Could we please have 65 ter 5356.

23             MR. KARADZIC: [Interpretation]

24        Q.   Mr. Prstojevic, is it correct that the Main Board elects members

25     of the Executive Board by secret ballot, and the Assembly elects the

Page 13742

 1     Main Board?

 2        A.   It is correct that the Assembly elects the Main Board.  And

 3     believe it or not, I do not remember how the Main Board elected us at the

 4     time.

 5        Q.   Please have a look at the list.  Is it the list of people who

 6     were elected as members of the Main Board on that day, including

 7     yourself, when you were elected in spite of the fact that I was backing

 8     up another candidate?  Is this the composition of the Main Board?

 9        A.   Yes, that was this particular composition of the Main Board that

10     was elected at the Jahorina plenum or perhaps later.  I wouldn't know.

11     But this is the one that I was a member of and worked for.

12        Q.   Instead of the "Main Board," it should be "Executive Board."

13             Do you remember that many people participated in the election of

14     these people?

15        A.   Yes, that's absolutely correct, the entire Main Board.  I just

16     don't know how they elected us.

17             THE ACCUSED: [Interpretation] Thank you.

18             Can this be admitted?

19             JUDGE KWON:  Yes.

20             THE REGISTRAR:  Exhibit D1222, Your Honours.

21             MR. KARADZIC: [Interpretation]

22        Q.   Do you stand by what you said, that I tried on two occasions to

23     recommend another member who was your opponent, a different candidate?

24        A.   I absolutely stand by that, and that's truth and nothing but the

25     truth.

Page 13743

 1        Q.   Did I have to sign this once the voting was completed?

 2        A.   Well, certainly.  Such were the rules, and you had to, because

 3     you had to honour and observe what the Main Board decided.

 4             THE ACCUSED: [Interpretation] Thank you.

 5             JUDGE KWON:  Thank you.

 6             The English translation of 65 ter 30751, which we admitted as

 7     MFI D1212, has been up-loaded.  So, as such, we will admit it fully.

 8             And I suppose Mr. Karadzic will spend about three hours more.

 9     How long do you expect for your re-examination, Mr. Tieger?

10             MR. TIEGER:  At this point, I'd estimate approximately

11     45 minutes, Your Honour.

12             JUDGE KWON:  Mr. Karadzic, you have spent about six hours, a bit

13     more than six hours.  So if you could plan to conclude your

14     cross-examination in two sessions on Monday.

15             THE ACCUSED: [Interpretation] I will try to ask such questions

16     that would elicit as many yes-or-no answers.  If I manage to do that,

17     then I could do this.

18             JUDGE KWON:  Thank you.

19             We'll adjourn for today, and we'll resume on Monday next week at

20     9.00.  Thank you for your co-operation.

21             Have a nice weekend, Mr. Prstojevic.

22                           [The witness stands down]

23                           --- Whereupon the hearing adjourned at 2.32 p.m.,

24                           to be reconvened on Monday, the 21st day of March,

25                           2011, at 9.00 a.m.