Tribunal Criminal Tribunal for the Former Yugoslavia

Page 18641

 1                           Tuesday, 13 September 2011

 2                           [Open session]

 3                           [The accused entered court]

 4                           [The witness takes the stand]

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

 6             JUDGE KWON:  Good morning, everyone.

 7             Good morning, Mr. Witness.  My understanding is that there's

 8     something about which you want to clarify.

 9             THE WITNESS: [Interpretation] Yes, I do have something to clarify

10     because I do believe that I was quite vague in answering several

11     questions.

12             JUDGE KWON:  Yes, please proceed by all means, Mr. Witness.

13             THE WITNESS: [Interpretation] It has to do with sketches 01 and

14     02, when I said that there was some sort of misunderstanding with the

15     OTP.  Could we please have the sketch -- both sketches, 1 and 2, on the

16     screen so that I could clarify which one is which, which is the sketch of

17     the KP Dom.

18             JUDGE KWON:  Exhibit P3299 -- or 3300.

19             MS. EDGERTON:  3301 as well.  3301, page 3.

20   (redacted)

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24             JUDGE KWON:  Just a second.  Shall we go into private session.

25                           [Private session]


Page 18642

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 7                           [Open session]

 8             THE REGISTRAR:  We're now in open session.

 9             JUDGE KWON:  Please proceed, sir.

10             THE WITNESS: [Interpretation] The buildings indicated in 02 were

11     the ones that had previously been shelled by the Federation --

12   (redacted)

13             Sorry for the interruption.  Yes, please continue, Mr. Witness.

14             THE WITNESS: [Interpretation] So the sketch, 02, indicates the

15     housing residential area outside of the KP Dom Butmir which had been

16     shelled in the days prior to ...

17             JUDGE KWON:  Yes.

18             THE WITNESS: [Interpretation] Could I kindly ask you to show both

19     pages of the sketch 01.

20             JUDGE KWON:  Ms. Edgerton, you can help us.  What we should

21     upload, both pages of --

22             THE WITNESS: [Interpretation] Thank you.

23             MS. EDGERTON:  The only thing I can think of is the unannotated

24     versions of 3301, so that would be pages 1 and 3 of 3301.

25             JUDGE KWON:  But the first page of 3300 is almost identical to


Page 18643

 1     page 1 of 3301 so we can show both pages?

 2             MS. EDGERTON:  Absolutely.

 3             JUDGE KWON:  Sir, can you proceed.

 4             THE WITNESS: [Interpretation] Thank you.  May I.  The sketch 01

 5     indicates two-thirds of the KP Dom which had previously been a

 6     penitentiary of a semi-open type, has a fence around it which was some

 7     metre or 120 centimetres tall, whereas on the other side there was no

 8     protective fencing.  It had either been removed before my arrival there

 9     or it never existed at all.  The compound was easily accessible from that

10     side and it was specifically that side of the compound that was mostly

11     used after the shelling that I referred to.  And that's all that I had to

12     give by way of comment.

13             JUDGE KWON:  Thank you.

14             THE WITNESS: [Interpretation] I'd like to make a comment on the

15     military police unit we discussed.  It used military vehicles which bore

16     the insignia of the military police.

17             I'd also like to say the following.  When I said that it was the

18     first time that I was looking at the official document containing a list

19     of policemen and materiel and technical equipment, there was an

20     interruption in my evidence simply because I was surprised positively and

21     I was quite emotional looking at a document that I had last seen in

22     August of 1992 again.  It was a document that had disappeared along with

23     some other official notes I made after my departure from that work-place.

24     However, the Defence team asked me to look at the signature and confirm

25     it.


Page 18644

 1             I wanted to make this comment because I didn't want to leave any

 2     impressions that would defeat the purpose of my being here.  Over the

 3     past couple of days I reviewed the transcript of my interview with

 4     investigators a couple of times.  I found the translation somewhat

 5     peculiar; in other words, I did not find it to be faithful to what I had

 6     to say and to the formulations I used.  Quite the contrary, there were a

 7     couple of points which remained pretty incomprehensible as they stand in

 8     the transcript.  Thank you.

 9                           [Trial Chamber confers]

10             JUDGE KWON:  Thank you, Mr. Witness.  We'll leave it at that.

11             Mr. Karadzic.

12             THE ACCUSED: [Interpretation] Good morning, Excellencies.  Good

13     morning to all those in the courtroom.

14                           WITNESS:  KDZ601 [Resumed]

15                           [Witness answered through interpreter]

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

17        Q.   [Interpretation] And you, Witness.

18        A.   Good morning.

19        Q.   If the Defence had more time at its disposal, it would very much

20     like to clear up these points that remain unclarified due to various

21     issues including translation, et cetera, but we don't have time for that.

22             Last Thursday we left off discussing the issue of war crimes.

23     You confirmed to us that the police force was vastly understaffed.  Would

24     you also agree with me that there was also a shortage of judicial

25     personnel and that it took us more than a year to put together a proper


Page 18645

 1     judiciary?

 2        A.   Well, I can confirm that in the area of my station there was no

 3     civilian court of law which would have jurisdiction for either

 4     misdemeanour or criminal cases.

 5        Q.   Let us look at P1096 briefly, please.  Do you agree that even

 6     nowadays domestic courts are seized of certain reports that were filed

 7     back in that period of time?

 8        A.   Yes, I can agree with that.

 9        Q.   Thank you.

10             THE ACCUSED: [Interpretation] Can we have page 3 in English and 5

11     in Serbian.  Perhaps the participants to the proceedings won't be quite

12     clear on what we are clear on.

13             MR. KARADZIC: [Interpretation]

14        Q.   So do you agree that still today certain Serbs, perpetrators of

15     crimes, are being tried based on the documentation that had been gathered

16     by the police force back in that period of time that had not been

17     suppressed or in any way covered up by the police?

18        A.   Yes, I can agree with that.

19        Q.   Let us look at paragraph 2.  This is a brief on certain aspects

20     of the past work and the date is the --

21             THE INTERPRETER:  The interpreter didn't catch the date.  Can,

22     please, the speakers make a pause.

23             JUDGE KWON:  Please slow down and could you repeat the number or

24     date.

25             THE ACCUSED: [Interpretation] Can we have page 1, the date is the


Page 18646

 1     17th of July, 1992.  I just want the witness to identify the document.

 2     It's already been admitted.

 3             MR. KARADZIC: [Interpretation]

 4        Q.   Ministry of the Interior, report on certain aspects of work done

 5     to date and the tasks ahead.

 6             THE ACCUSED: [Interpretation] Could we have page 5 in Serbian and

 7     3 in English.

 8             MR. KARADZIC: [Interpretation]

 9        Q.   Paragraph 2:

10             "The priority of the crime service is the uncovering of war

11     crimes complete with all the documentation, forensic documentation,

12     medical documentation ..." et cetera.  Document any and all cases of war

13     crimes were committed by the Serbs.

14             Is that a position as it existed at the time by ministry?

15        A.   Yes, I am aware of it.

16        Q.   Thank you.  The institution you worked for was some 400 to 500 or

17     600 metres away from the confrontation line and the separation line?

18        A.   Yes, that's correct.

19        Q.   Thank you.  Along the stretch from your institution to the

20     barracks, was this an area where snipers, mortars, and other artillery

21     pieces were active?  Was it a safe stretch of the road or a very

22     dangerous one?

23        A.   The stretch of the road between the two locations you mention was

24     definitely a dangerous one.  At some periods we would even place screens

25     4 or 5 metres high in order to make it possible for pedestrians to move


Page 18647

 1     along freely.  Sniper fire was a daily occurrence.  Civilians were

 2     wounded or killed.  What's more, in this material, I mean my interview,

 3     you can read that my own vehicle had come under fire and was hit in the

 4     front right-hand door.

 5        Q.   Snipers were able to fire from Mojmilo, whereas mortars and

 6     artillery both from Mojmilo, Igman, and from the town itself, direct fire

 7     was possible from the town itself, was it not?

 8        A.   I do agree.  In the main heavy artillery pieces were positioned

 9     at Igman, somewhat fewer pieces at Mojmilo, where there was a sniper and

10     a Browning active daily.  Frequently such fire could also be seen from

11     Dobrinja.  Our offices were on the second floor and the buildings in

12     Dobrinja generally were five storeys high plus the attic.  So there was

13     daily sniper fire.  And in this report of mine, you were able to see that

14     in the office where we had our desks we came under sniper fire on two or

15     three occasions.  There is evidence to that effect in the rooms such as

16     damage to the walls and the door to the office.  For that reason we would

17     hang blankets on the window-panes frequently.

18        Q.   Thank you.  On pages 22 and 23 of this statement of yours you say

19     that policeman Dragan Kablar was killed and Milovan Knezevic was wounded

20     by sniper fire.  Do you recall that as a result of sniper fire, chief of

21     the security services centre Zoran Cvijetic was killed.  I'm sorry, the

22     relevant page is 20 and the lines 22 and 23.

23        A.   The late Drago Kablar and Knezevic came under artillery fire.  It

24     was a shell fired by the BH army, or rather, by the BH Federation.  I

25     also know that the chief of the Sarajevo centre, late Zoran Cvijetic, was


Page 18648

 1     killed by sniper fire.

 2        Q.   Thank you.  Your institution, including the KP Dom and the entire

 3     compound, were within range and were frequently fired at, as the sketch

 4     indicated.  Were there any more deaths as a result of shelling in

 5     addition to the two policemen we mentioned?

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12        Q.   Thank you.  And then Mr. Tepavcevic resorted to evacuation or

13     withdrawal of personnel and inmates as far as Pale and Sokolac at times;

14     is that right?  In other words, from what was practically the front line

15     they were moving deeper behind and you do mention this at page 16,

16     lines 1 through 16.

17        A.   Yes.  What lends support to what you say are the instructions

18     sent by Mr. Tepavcevic to the Ministry of the Interior and Minister of

19     Justice Mandic are asking for appropriate locations to be pin-point at

20     Sokolac and Pale.

21             MS. EDGERTON:  Your Honour --

22             MR. KARADZIC: [Interpretation]

23        Q.   Thank you --

24             MS. EDGERTON:  -- I think there should be a redaction of lines 5

25     to 10 on page 8.


Page 18649

 1             JUDGE KWON:  Thank you.

 2             MR. KARADZIC: [Interpretation]

 3        Q.   What we have here was a document of General Galic's.  In it he

 4     asks the civilian authorities to take care of civilians from the combat

 5     areas, to take care of them elsewhere, actually, because they're sending

 6     them to him in the barracks.  And he doesn't mind protecting them, but

 7     they are in his way, they're an impediment there.  Do you know about

 8     these civilians from combat areas, not only from Dobrinja and Kotorac,

 9     but also from places further away?  Do you know that they were brought

10     into the correctional facility KP Dom and the barracks?

11        A.   Yes, I know that.

12        Q.   Thank you.  Now I would like to ask you about paramilitaries.

13     You pointed that out to us and this is what I want to ask you.  Do you

14     know that volunteers were regulated by the Law on National Defence and

15     reinforced by the decision of the Presidency of the SFRY just before the

16     break-up of the country, when -- when -- when there was a decline in the

17     call-up, or rather, the response of conscripts of Muslim and Croat

18     ethnicity?

19        A.   I know about that.

20        Q.   Thank you.  Do you agree that all of those who came or actually

21     the majority of those who came had reported as volunteers, whereas some

22     remained volunteers with all their obligations towards the military and

23     the police, whereas others turned into renegades abruptly or gradually

24     and turned into fighters on their own?  Actually, to put it more

25     precisely.  If somebody reports or volunteers and behaves in accordance


Page 18650

 1     with regulations for a while, there is no guarantee that at a certain

 2     point in time he's not going to avoid the front line as such and go back

 3     to urban areas and behave in accordance with his own wishes and motives?

 4        A.   I know about that.  I know of cases like that.

 5        Q.   You mentioned this Oljaca and his men.  Did they start as

 6     volunteers and end up as paramilitaries?

 7        A.   Believe me, I don't know.  I want to have a clear conscience.  I

 8     really cannot say.  I know them as a paramilitary formation.

 9        Q.   Thank you.  Is it correct that Oljaca arrested many persons and

10     brought them to prison, he would arrest Serbs too, not only his own

11     soldiers, but quite simply he arrested all of those who should be

12     arrested in his assessment?

13        A.   This statement is correct.  In my documentation there were

14     official notes that had been written by policemen.  Unfortunately, this

15     documentation is missing.

16        Q.   Thank you.  That episode with two persons, two men, in unusual

17     uniforms who wanted the police station to be subordinated to them in the

18     KP Dom and to have everything placed under their command, is this really

19     one of the absurdities of a civil war?  Was that as you had described it

20     and how did they end up?  Is it true that Tepavcevic sent them to Kovac

21     and Kovac kicked them out of the zone?

22        A.   The statement I gave to the investigators is correct --

23             MS. EDGERTON:  Your Honour.

24             JUDGE KWON:  Yes.

25             MS. EDGERTON:  The witness has already answered.  It was just


Page 18651

 1     that there were five different questions in there.

 2             JUDGE KWON:  Let us continue, Mr. Karadzic.

 3                           [Defence counsel confer]

 4             THE ACCUSED: [Interpretation] Thank you.

 5             MR. KARADZIC: [Interpretation]

 6        Q.   Was Kula considered a collection centre where interviews were

 7     conducted and through which detainees passed in order to be sent further

 8     on?  Some would be released and others would be part of further

 9     proceedings?  In other words, was this a type of investigation centre?

10     Were interviews, investigations, carried out there?

11        A.   I think it was a collection centre where investigations were

12     carried out and from where these persons were sent to other locations

13     depending on the assessment of those who conducted interviews with them.

14        Q.   Thank you.  What was of crucial importance for the fate of a

15     given person as to whether he would be released or whether he would be

16     processed further -- actually, was it only important what he had done or

17     what his origin was?

18        A.   I'm not familiar with the mode of conducting interviews.

19     However, my conclusion can be that they were sent to barracks or police

20     stations in order to have the police force manned.  You can put it that

21     way.  I think that what was of crucial importance was the location that

22     they had come from and whether any fire-arms had been found on them or

23     whether they were civilians.

24        Q.   Thank you.  So it was what they did that was of crucial

25     importance, not their origin?


Page 18652

 1        A.   I think that that is one of the criteria.

 2        Q.   Now I would like to ask that we take a look at 1 --

 3                           [Defence counsel confer]

 4             MR. KARADZIC: [Interpretation]

 5        Q.   This is an investigation that the Defence carried out in

 6     connection with that and it shows that there had been paramilitaries,

 7     that there were persons who had been drugged, who would come to the gate,

 8     who'd pester people, there wasn't any special security at the gate, and

 9     there was basically no fence, and if there was a fence it could be jumped

10     over, and that it was a true art to try to mollify these people and

11     neutralise them.  Was that your experience too?  That, yes, hoodlums, if

12     I could put it that way, could show up and maltreat people and officials

13     had problems with neutralising such persons.

14        A.   Oh, there were situations like that and how.  There were persons

15     who had lost their nearest and dearest and, as they were totally

16     distraught, they would come and even use fire-arms.  In their view, they

17     wanted the police to act, they wanted to carry out revenge, and that's

18     what they did.  People were under the influence too.  You know what?

19     It's a war.  There is a euphoria and it's hard to express this in words

20     but there were situations like that, yes.

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 5             JUDGE KWON:  Yes.

 6             Shall we go into private session.

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25                           [Open session]


Page 18656

 1             JUDGE KWON:  Yes, we are now back in open session.  Please

 2     continue.

 3             THE WITNESS: [Interpretation] The main communication centre had

 4     its headquarters in the Federation of Bosnia-Herzegovina.  It was under

 5     the control of the Federation forces.  I think that there were only about

 6     ten days involved, not more than that.  Certain attempts were made via

 7     radio; however, as you read these reports, you can see that very soon,

 8     due to a lack of professionalism on the part of persons who were

 9     operating it, it did not function.

10             MR. KARADZIC: [Interpretation]

11        Q.   Thank you.  And now if we look at the communications problems and

12     then orders issued orally.  In addition to all of that, was there the

13     possibility of abuse, that is to say taking advantage of somebody's name?

14     If somebody would say I was with such and such a person, such and such a

15     person told me I could do this and that, was that made possible due to

16     that lack of communication?  More specifically, could you always check

17     whether people were telling the truth?

18        A.   There were such cases of abuse, especially when it comes to names

19     of high-ranking politicians and officials of the Ministry of the Interior

20     in order for something to be implemented, which otherwise would have been

21     impossible.

22        Q.   Thank you.  Was that one of the main reasons for Mr. Zuban to

23     establish the internal inspections, the internal audit in the MUP?  So

24     all of these factors probably affected it, verbal orders, the possibility

25     of misusing other people's names and authority, lack of proper


Page 18657

 1     communications system, and so on.  Was all of that the reason for

 2     establishing the system of internal audit of public security stations and

 3     various other levels of police?

 4        A.   I think that this was one of the reasons.  However, the Law on

 5     Internal Affairs in the then-Republika Srpska mandated the establishment

 6     of normal conditions for proper work of the Ministry of the Interior.

 7     Inspection and audit is one of the important elements of the work in the

 8     ministry because the ministry was answerable to the political leadership

 9     of the country.  It had to inform them on all relevant security issues

10     and developments.

11        Q.   Thank you.

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14             JUDGE KWON:  The Chamber will move into private session.

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Page 18669

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22                           [Open session]

23             MR. KARADZIC: [Interpretation]

24        Q.   In your statement page 42 -- or actually, page 37 in English most

25     probably.  You say that it was difficult to identify perpetrators of


Page 18670

 1     crime, of wrong-doing, that the police force was successful in that on

 2     occasion, but that in general there were difficulties in work due to

 3     this.  Can we now look at what it is that you mention was part of

 4     policing work, armed activities --

 5             MS. EDGERTON:  I'm sorry, Your Honours, but I just can't find

 6     where this was said.

 7             JUDGE KWON:  I couldn't either.

 8             THE ACCUSED: [Interpretation] Page 42, lines 11 through 17 in the

 9     English version; and page 37, 14 through 20, in Serbian.

10             [In English] "... this is why the identification of all

11     perpetrators of evil deeds was very difficult.  It was difficult to say

12     whether something was done by the military or police organisation was

13     poor."

14             JUDGE KWON:  Yes, your question, Mr. Karadzic.

15             MR. KARADZIC: [Interpretation]

16        Q.   Is this your view that the difficulties in identifying these

17     perpetrators persisted perhaps throughout the war?

18        A.   That was one of the basic problems in identification.  At times,

19     a perpetrator of misdemeanour or crime did not have identity papers on

20     him which would indicate who he was.  Since there was general chaos, it

21     was very hard to intervene in any way.  Even under normal circumstances,

22     a criminal, a person who puts up resistance -- well, at times it calls

23     for the engagement of special police units.  The situation is even worse

24     in times of war.  Policemen manning check-points were unable to identify

25     individuals even where these had identification papers on them because


Page 18671

 1     they were -- wore camouflage colours, had their faces blackened,

 2     et cetera.  And very often, such groups of criminals moved in large

 3     numbers.  At times they even had military combat assets at their

 4     disposal, such as the Pragas, APCs, and similar.

 5        Q.   And their level of equipment was better than that of the police

 6     force; right?

 7        A.   Yes, at least that we were able to see in the list of equipment

 8     that you showed here, it does lend support to what you say.

 9        Q.   You said in the circumstances of war and chaos.  We don't have

10     that reflected in the transcript.

11        A.   Yes.

12        Q.   My last question, Witness:  In cases where a perpetrator could

13     not be identified or visually even identified, were such cases documented

14     and were criminal reports filed against unidentified perpetrators to open

15     up a possibility of the case being resolved at a later stage?

16        A.   Yes.  There was strict attention paid to that -- to there being a

17     trace in the documentation, and such cases were registered against

18     unidentified perpetrators until such time as their identity was

19     established and proceedings could follow from there.

20        Q.   Thank you very much, Witness.

21        A.   You're welcome.

22             JUDGE KWON:  Why don't you proceed before we take a break,

23     Ms. Edgerton, if you can finish in ten minutes.

24             MS. EDGERTON:  Less than that, Your Honours.  Actually, I have a

25     question just relating to one document.  I think I need to move into


Page 18672

 1     private session for the question, please.

 2             JUDGE KWON:  Yes.

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Page 18673

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Page 18675

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21                           [Open session]

22             JUDGE KWON:  Sir, that concludes your evidence.  On behalf of the

23     Chamber, I would like to thank you for your coming to The Hague.  Now

24     you're free to go.  Please have a safe journey back home.

25             THE WITNESS: [Interpretation] Thank you very much.


Page 18676

 1             JUDGE KWON:  We'll have a -- we'll take a break for half an hour

 2     and resume at ten past 11.00.

 3                           --- Recess taken at 10.41 a.m.

 4                           [The witness withdrew]

 5                           [The witness entered court]

 6                           --- On resuming at 11.13 a.m.

 7             JUDGE KWON:  Could the witness take the solemn declaration,

 8     please.

 9             THE WITNESS: [Interpretation] I solemnly declare that I will

10     speak the truth, the whole truth, and nothing but the truth.

11             JUDGE KWON:  Thank you, sir.

12             Please be seated and make yourself comfortable.

13             Yes, Ms. Sutherland.

14             MS. SUTHERLAND:  Thank you.  Good morning, Your Honours.

15                           WITNESS:  MIRZET KARABEG

16                           [Witness answered through interpreter]

17                           Examination by Ms. Sutherland:

18        Q.   Good morning, Mr. Karabeg.  Can you please state your full name.

19        A.   Mirzet Karabeg.

20        Q.   I discussed with you that part of your evidence would be admitted

21     in writing.  I need first to deal with the formalities in relation to

22     that submission.  You testified in the Brdjanin case over four days,

23     between the 27th and the 30th of May, 2002; is that right?

24        A.   Yes.

25        Q.   You've subsequently had an opportunity to review the audio


Page 18677

 1     recordings of that testimony?

 2        A.   Yes.

 3        Q.   You wish to clarify an answer --

 4             MS. SUTHERLAND:  And for Your Honours and the accused, this

 5     appears in the English transcript at page 6159, lines 1 and 2, and the

 6     answer relates to a question put at the bottom of 6158.

 7        Q.   Mr. Karabeg, this deals with when you were questioned about a

 8     statement regarding the surrender of weapons which the Bosnian Serbs

 9     responsible for your arrest had asked you to make along with

10     Redzo Kurbegovic and Suad Sabic and this is at transcript 6156.  And you

11     responded at transcript 6159:

12             "We wrote it on a piece of paper, we signed it.  Somebody took it

13     to the radio station and read it there."

14             The clarification that you wish to make is in relation to the

15     sentence "we signed it," is it not?

16        A.   Yes.

17        Q.   Did you sign this statement with Redzo and Suad which was later

18     read on Radio Sana?

19        A.   No.

20        Q.   And can you confirm that with that clarification the audio

21     recordings accurately reflect your testimony?

22        A.   Yes.

23        Q.   If you were asked today about the matters you testified to in the

24     Brdjanin case, would you provide the same information to the

25     Trial Chamber, that is, even if you would probably not be able to


Page 18678

 1     formulate everything in the same words, the essence would still be the

 2     same?

 3        A.   Yes.

 4             MS. SUTHERLAND:  Your Honours, I noticed a couple of names in the

 5     English transcript which need to be corrected.  Clearly when the witness

 6     was listening to the audio recordings, they're not a correction for him.

 7     There is a name and then this square bracket with the words "phonetic,"

 8     and this is at transcript 6071, lines 10 and 20.  There's a reference to

 9     a person called Asim Medaric and then the words "phonetic."

10        Q.   Mr. Karabeg, this is in relation to the meeting that you attended

11     in 1991 in Banja Luka with 17 or so presidents of the Executive Boards

12     from the Krajina area.  What is the last name of the Bosniak friend that

13     you met there from Kljuc?

14        A.   Asim Egrlic.

15        Q.   And that's spelled E-g-r-l-i-c?

16        A.   Yes, L-i-c with a diacritic.

17        Q.   And at transcript page 6082, lines 20 and 21, it states that the

18     head of the SDK was a woman called Dobrija Sanica and then the words

19     "phonetic."  What was the name of the head of the SDK?

20        A.   Dobrijevic.  I can't remember the first name.  I know the last

21     name is Dobrijevic.

22             THE INTERPRETER:  Interpreter's note:  Could all other

23     microphones please be switched off when the witness is speaking.  Thank

24     you.

25             MS. SUTHERLAND:  And, Your Honours, I also note in the header of


Page 18679

 1     the transcript, and that's from page 6065, that it incorrectly states

 2     Mirket Karabeg instead of Mirzet Karabeg.  And I seek to tender the

 3     65 ter 22133, which is the witness's Brdjanin testimony.

 4             JUDGE KWON:  That will be admitted.

 5             THE REGISTRAR:  As Exhibit P3303, Your Honours.

 6             MS. SUTHERLAND:  And with Your Honours' leave, I'll now read a

 7     summary of the witness's evidence.

 8             Mr. Karabeg is a Bosnian Muslim born in Sanski Most.  He trained

 9     as a lawyer and worked in the Famos manufacturing company in Sanski Most

10     as chief of personnel.  He was an SDA candidate during the 1990

11     multi-party elections.  He was subsequently elected to the position of

12     president of the Executive Board, or Committee, of the Sanski Most

13     Municipal Assembly, holding that position from the 1st of January, 1991,

14     until the 17th of April, 1992.  He describes the election results and the

15     make-up of the Municipal Assembly, noting that Nedjeljko Rasula, a Serb

16     and an SDS member, became president of the Municipal Assembly.  He also

17     names other leading figures in the local SDS.

18             From around September 1991 to May 1992, a series of explosions

19     were directed against the property of non-Serbs in Sanski Most.  The

20     witness recalls that 42 buildings were targeted, mostly private shops,

21     cafes, boutiques, and two houses.  The witness recalls one cafe owned by

22     a person of Serb ethnicity being targeted during the same period.  The

23     witness states that the local JNA unit in early 1992 was the

24     6th Krajina Brigade under the command of Colonel Branko Basara.

25             In February 1992, the SDS, together with the SOS, tried to take


Page 18680

 1     over the public accounting service in Sanski Most.  In early April 1992,

 2     the SDS began insisting on dividing the municipality along ethnic lines

 3     and creating a Serb -- separate Serbian municipality of Sanski Most.  A

 4     first step in the process was the 11th April 1992 reorganisation of the

 5     police force with new insignia and a loyalty oath to the Serbian

 6     authorities.  The SDS continued to insist on a division of the

 7     municipality and wanted the non-Serbs to move to the other side of the

 8     river.  Many check-points were set up in the municipality and only

 9     non-Serbs would be stopped and searched.

10             On the 17th of April, 1992, the SDS Serbs, SDA and HDZ

11     representatives continued to negotiate the situation.  On that date, the

12     witness and other non-Serbs including a number of non-Serb policemen,

13     went to the municipal building where they stayed for the next two days.

14     On the 19th of April, Rasula gave an ultimatum to the non-Serbs in the

15     municipal building that if they did not leave by 2200 hours and surrender

16     all arms, they would be attacked.  The witness and others in the

17     municipal building noticed a column of about 30 vehicles belonging to the

18     6th Krajina Brigade approaching and managed to leave the building by a

19     side entrance before the artillery and shell attack on the building by

20     the Serbs.

21             On the 20th of April, SDS -- sorry, SDA and HDZ representatives

22     met with SDS officials and military personnel, including JNA

23     General Momir Talic.  The Muslims and Croats made several requests in

24     relation to the security of the non-Serb population which were approved

25     by Talic at the meeting; however, these requests were then not fulfilled.


Page 18681

 1             Between the 20th of April and late May 1992, the situation grew

 2     worse.  The witness was arrested at his home on the 25th of May, 1992,

 3     and detained in the prison behind the Sanski Most SJB building - this is

 4     scheduled incident C.22.1 - until around the 9th of June when he was

 5     taken to the Betonirka garage where he was detained for one month until

 6     the 7th of July.  This is scheduled incident C.22.2.  On that date, he

 7     was moved back to the prison where he was detained for a further seven

 8     weeks.

 9             The witness describes the terrible conditions of detention

10     including interrogations and physical violence inflicted upon him and the

11     other detainees, including one beating where he was kicked in the head

12     and face and as a result lost all his teeth.  On one occasion he was told

13     that the beating was done based on the order of the chief of police

14     Mirko Vrucinic.  The witness did not receive any medical care while he

15     was detained.

16             On the 28th of August, 1992, the witness was transferred to the

17     Manjaca camp - this is scheduled incident C.1.2 - where he was detained

18     for two months until the 31st of October, 1992, when he was sent to

19     Travnik as part of an exchange.  The witness describes the conditions at

20     Manjaca and the physical violence that was taking place in the camp

21     during the time he was there.

22             Your Honour, that completes the summary of the witness's written

23     evidence.

24             JUDGE KWON:  Thank you.

25             MS. SUTHERLAND:


Page 18682

 1        Q.   Mr. Karabeg, I now have a number of -- limited number of

 2     questions to expand on some matters in relation to your written evidence

 3     which is now before the Court.  But first can I just say I've spoken with

 4     the Court deputy and asked him when we're showing you any documents or if

 5     Mr. Karadzic is going to show you any documents, that we are going to

 6     enlarge them on the screen as much as possible and you also have a

 7     magnifying glass in front of you to use.

 8             Mr. Karabeg, at transcript page 6076 and 6077 you stated that the

 9     42 buildings belonging to non-Serbs were targeted by explosives.  Who was

10     responsible for this?

11        A.   Let me tell you, we knew straight away that it was the Serb side

12     because grenades were thrown, or rather, explosives to -- into non-Serb

13     shops.  We insisted - especially I as president of the

14     Executive Board - that the crime service of the police that was manned by

15     Serbs only at the time investigate the matter.  The answer that we were

16     given was we are going to resolve the matter but, unfortunately, that

17     went on day after day, or rather, night after night when these

18     explosives --

19             THE INTERPRETER:  Interpreter's note:  Could all the other

20     microphones please be switched off when the witness is speaking.  Thank

21     you.

22             JUDGE KWON:  Just one clarification -- clarifying question,

23     Ms. Sutherland.  The 65 ter number of this transcript has an A at the end

24     of its digit.

25             MS. SUTHERLAND:  Yes, I'm sorry, Your Honour, I should have said


Page 18683

 1     A, which is only the Brdjanin transcript.  The complete 65 ter number has

 2     his other transcripts from other trials.

 3             JUDGE KWON:  Correct.

 4             MS. SUTHERLAND:  Thank you.

 5             JUDGE KWON:  Thank you.

 6             MS. SUTHERLAND:

 7        Q.   Mr. Karabeg, you stated that it was the Serb side, but can you be

 8     more specific as to who was doing these acts.

 9        A.   Well, let me tell you, specifically these were Serb defence

10     forces --

11             THE INTERPRETER:  The interpreter did not hear the second

12     sentence.

13             THE WITNESS: [Interpretation] This was a group of Serbs that

14     established this kind of formation.

15             MS. SUTHERLAND:

16        Q.   Mr. Karabeg, the interpreter didn't hear the second sentence

17     after you said that it was a group of Serbs -- these were Serb defence

18     forces --

19        A.   Members of the Serb defence forces.

20        Q.   And is that -- does that have an acronym SOS?

21        A.   SOS, yes.

22        Q.   And do you know who made up the SOS?

23        A.   Well, let me tell you, we didn't know their names at the time.

24     For example, these defence forces were headed by Tomo Delic, who together

25     with us participated in talks, negotiations, and let me put this very


Page 18684

 1     simply.  He lied to us.  He said we could reach agreement if there hadn't

 2     been for our extremists, but later on we found out --

 3        Q.   Mr. Karabeg, sorry, can I just stop you there.  In relation to

 4     the question do you know who made up the SOS, were there any locals which

 5     were part of the SOS?

 6        A.   Yes.

 7        Q.   Do you now recall the names of those persons?

 8        A.   Let me tell you, I know their nicknames, Lunja, Medeni,

 9     Tomo Delic, and there are some others whose names I can't recall now.

10     And then there are also those whom I never knew, people who had come from

11     the villages in Sanski Most municipality.

12        Q.   At transcript page 6078 when you were testifying about the

13     February 1992 referendum for the independence of Bosnia and Herzegovina,

14     you said that a small number of Serbs told you that they had voted in it.

15     You also said that some Serbs were subject to pressure.  What sort of

16     pressure were you referring to there?

17        A.   Let me tell you, up until the 6th or 7th of April, 1992, we lived

18     in fairly harmonious circumstances in relation to the times before.

19     There were people who supported Bosnia and Herzegovina but who said:  I

20     do not dare vote because I was told that a bomb or an explosive would be

21     thrown on my apartment.  I simply do not dare, otherwise I have nothing

22     against it.

23             Let me give you a specific example.  When the commission was set

24     up, commission for organising the referendum, there was a man called

25     Miladinovic, who was a permanent member of that commission, and naturally


Page 18685

 1     the Executive Board nominated him into that commission and he was

 2     otherwise a judge.  So I asked him whether he wanted to be on that

 3     commission and he said, "Sure, why not?"

 4             THE INTERPRETER:  Interpreter's note, could all other microphones

 5     be switched off.

 6             THE WITNESS: [Interpretation] And then the next day he called me

 7     and he told me this, "Mirzo, please scrape my name from the list of

 8     members of that commission because people found out about that and they

 9     told me that if I should remain a member of the commission, they would

10     throw a bomb on my apartment."

11             MS. SUTHERLAND:  Could the witness be shown 65 ter 04988.

12        Q.   Mr. Karabeg, you were shown a copy of this document during your

13     Brdjanin testimony of Rasula's diary.  If I can go to B/C/S page 139 and

14     page 122 in the English, I want you to look at an entry there for the

15     23rd of February, 1992.  It's a session of the Municipal Board of the

16     SDS.  We can see here the text says:

17             "How to behave during the referendum.

18             "No one may participate in any other function of the referendum

19     (electoral committee, members of electoral boards), the manufacture of

20     ballot papers, the distribution of ballots.

21             "No one may give permission that the referendum be held in his

22     house.

23             "Do not allow ballot boxes to be set up in purely Serbian local

24     communes.

25             "Do not allow ballot papers to be handed over to Serbs and that


Page 18686

 1     potential pressure be exerted on our people.

 2             "Discreetly control the work of polling places in town and in

 3     mixed communities outside of town, and pay special attention to ... those

 4     Serbs who attempt to vote and they should be prevented in that and their

 5     names noted."

 6             Now, is this consistent with what you were told at the time?

 7        A.   Yes.

 8        Q.   I now wish to turn to transcript page 6102 of your testimony.

 9     You reviewed a document dated the 3rd of April, 1992.  I don't intend on

10     calling it up.  It's associated exhibit 65 ter 04996, which is a decision

11     on the Serbian municipality of Sanski Most to become part of the

12     Autonomous Region of Krajina, otherwise known as the ARK.  Do you recall

13     that?

14        A.   I remember that.

15        Q.   I'd now like to take you -- I'd now like you to take a look at a

16     document which predates that document and that's 65 ter 04894.

17             JUDGE KWON:  Can I hear from the witness again who the Rasula --

18     Mr. Rasula was?

19             MS. SUTHERLAND:  Yes, Your Honour.

20        Q.   Mr. Karabeg, may -- can you answer the Presiding Judge's

21     question?

22        A.   He was the president of Sanski Most municipality.  That is to

23     say, he was the head of the legislative power in Sanski Most.

24             JUDGE KWON:  And the diary which we saw a part of it, is one of

25     the associated exhibits?


Page 18687

 1             MS. SUTHERLAND: [Microphone not activated]

 2             JUDGE KWON:  Microphone.

 3             THE INTERPRETER:  Microphone, please.

 4             MS. SUTHERLAND:  I'm sorry.

 5             The associated exhibit is 20591, which was the copy that was

 6     actually shown to Mr. Karabeg during his testimony in the Brdjanin trial.

 7     And at that stage it was given the Brdjanin exhibit number of P759.  In

 8     that case, we subsequently tendered a certified copy of the diary,

 9     covering a wider period, and that is what is -- and that is what is our

10     65 ter 04988.  And that is -- that was given -- that was given the

11     exhibit number in the Brdjanin case as P759.1.  And I listed both of the

12     exhibit numbers in our notification, first of all, as an associated

13     exhibit and then I filed the final notification when I clarified that, in

14     fact, the exhibit that was shown to the witness was 65 ter 20591.  And so

15     then I added 65 ter 04988 to additional exhibits to be used with the

16     witness.

17             I'm in your hands, Your Honour, what I -- we would seek to tender

18     the certified copy covering the larger period of time, which goes from

19     1990 through to 1992, but Your Honours may want --

20             JUDGE KWON:  Which has 179 pages?

21             MS. SUTHERLAND:  Yes, Your Honour.  But Your Honours may want to

22     have 65 ter 20591 as a reference exhibit as well.

23             JUDGE KWON:  Do you have any observation, Mr. Robinson?

24             MR. ROBINSON:  Yes, Mr. President.  I think our -- first of all,

25     Mr. Rasula is deceased and so it's impossible now to question him about


Page 18688

 1     what he meant by any of these diary entries.  I understand it was

 2     admitted in the Brdjanin case and to some extent you can take judicial

 3     notice of its authenticity, but our position is that -- and I also accept

 4     that portions of the diary are indispensable to understanding the

 5     witness's testimony in the Brdjanin case.  But as with the Mladic

 6     diaries, we -- our position is that only those entries that are testified

 7     about by witnesses ought to be admitted.  But you've rejected that and

 8     you've admitted the entire Mladic diary.  And so if you are being

 9     consistent, I would imagine you would admit this diary.  But our position

10     is basically the same, that for confrontation reasons we believe that

11     only those parts of the diary that are discussed by witnesses in court

12     ought to be admitted.  Thank you.

13                           [Trial Chamber confers]

14             JUDGE KWON:  The Chamber is of the view that the case in relation

15     to this Mr. Rasula is different from that of Mr. Mladic.  The Chamber

16     will admit only those pages shown to the witness here or at the time of

17     the Brdjanin case.

18             MS. SUTHERLAND:  Very well, Your Honour.

19             If --

20        Q.   Mr. Karabeg, you can see 65 ter 04894 on the screen.  This is a

21     decision dated the 23rd of March, 1992, that all Serbian territories of

22     Sanski Most municipality should become part of the Serbian Republic of

23     Bosnia and Herzegovina.  When was the Serbian municipality of Sanski Most

24     proclaimed?

25        A.   The Serbian municipality of Sanski Most was proclaimed on the


Page 18689

 1     3rd of April, 1992.  It was proclaimed by the Assemblymen who were ethnic

 2     Serbs and also a large number of highly educated residents of

 3     Sanski Most.  This was how they voted, they did so without us knowing

 4     about it.  They adopted a decision to annex Sanski Most to the Banja Luka

 5     region.  That issue was not put on the agenda of the Assembly until 6 or

 6     7th of April, 1992.

 7        Q.   Mr. Karabeg, can I --

 8        A.   In the meantime they prepared all that --

 9        Q.   Can I direct your attention to page 3 of this document.  And it

10     says under the exposition that this -- the passing of such a decision was

11     necessary because "they want to remove them from Serb Republic of Bosnia

12     and Herzegovina unjustly and without basis ..."

13             Who is the "they" that they're referring to in this document?

14        A.   Could you please repeat your question --

15        Q.   [Microphone not activated]

16        A.   -- because I can't see the text well.

17             MS. SUTHERLAND:  If we could blow up just under the exposition.

18        Q.   It says there that this -- this was necessary, this decision,

19     because "they want to remove them from Serb Republic of Bosnia and

20     Herzegovina unjustly and without basis ..."

21             Now, do you know who the "they" is being referred to in the

22     document?

23             JUDGE KWON:  I think we need to zoom in the first paragraph;

24     right?

25             MS. SUTHERLAND:  Yes, Your Honour.


Page 18690

 1             JUDGE KWON:  And then we can zoom in further on.

 2             MS. SUTHERLAND:

 3        Q.   Mr. Karabeg, have you read the first paragraph?

 4        A.   I can read that just now.  I couldn't do it earlier.

 5        Q.   Do you understand my question?

 6        A.   I do, I do.  This pertains to the Serbs.  They wanted to secede

 7     from Sanski Most municipality, allegedly because they were subjugated,

 8     they were in a subordinate position and they wanted to secede.

 9        Q.   Who was allegedly subjugating them?  Who's the "they" that

10     they're referring to in that document?

11        A.   Well, let me tell you, "they" means the non-Serbs.  It actually

12     means Bosniaks and Croats.

13        Q.   And was this true?

14        A.   No.

15        Q.   What did the non-Serb representatives of the legally elected

16     municipal authorities want to do in relation to the Serb population?

17        A.   Let me tell you.  I would need to explain.  The authorities --

18        Q.   If you can do it very briefly, please, Mr. Karabeg.

19        A.   We had elections in 1990.  We implemented the results of the

20     elections.  The SDS received 23 votes, the SDA 22 votes, and the HDZ

21     4 votes, and the left 9.  Since the SDS received the most votes, they

22     could elect the person for the top position, the president of the

23     municipality, that was Nedeljko Rasula.  Since the SDA had 22 votes, then

24     they elected me as the second person in the municipality.  And then the

25     other positions were the president of the Executive Board and the


Page 18691

 1     vice-president, that went to HDZ.  So the SDA had four members there and

 2     the SDS had three members there, and the deputy was nominated by the HDZ.

 3        Q.   Mr. Karabeg --

 4        A.   That is to say that the authorities and the organs were

 5     established based on the results of the elections.

 6        Q.   Mr. Karabeg, I'm sorry, I -- I may have confused you a little.

 7     You mentioned a moment ago that the "they" means the non-Serbs.  It

 8     actually means Bosniaks and Croats.  So what -- what did the Bosniaks and

 9     Croats want to do in relation to the Serb population?  If you're able to

10     tell the Chamber, could you please do it as briefly as you can.

11        A.   Let me tell you, we wanted to support what was legal.  That is to

12     say, we wanted Bosnia and Herzegovina, we wanted all to live together in

13     Bosnia and Herzegovina, we wanted the authorities to be fully functional

14     based on the results of the elections in 1990 --

15             THE INTERPRETER:  Could the microphones be switched off.

16             THE WITNESS: [Interpretation] We didn't want anything else other

17     than that.

18             MS. SUTHERLAND:

19        Q.   [Microphone not activated].

20             I'm going to move on now to the 17th of April.  At transcript

21     page 6106 and following, you described that on that day you and a group

22     of individuals, including the non-Serb police officers, went to the

23     municipal building for the reasons that -- that have already been

24     explained there.  At transcript page 6155, you stated that on the

25     19th of April, 1992, at 9.30 p.m., Rasula, the president of the


Page 18692

 1     Municipal Assembly, issued an ultimatum for everyone to get out of the

 2     building and surrender the weapons or the municipality building would be

 3     attacked.

 4             If I can ask you to look at 65 ter 05008.  This is a document

 5     dated the 20th of April, 1992, a regular operations report of the

 6     5th Corps mentioning the municipal building.

 7             JUDGE KWON:  Ms. Sutherland, transcript page 6155?

 8             MS. SUTHERLAND:  That's what I said, Your Honour, but I see that

 9     it's not that page.  Hold on.  6115.  Thank you, Your Honour.

10             JUDGE KWON:  Thank you.

11             Yes.

12             MS. SUTHERLAND:

13        Q.   Mr. Karabeg, looking at this document, 05008, it says under

14     point 3, under "Situation on the Territory in the Zone of

15     Responsibility," that the municipal building was set on fire.  Is this

16     correct?

17        A.   See here, the municipal building was not set on fire; however,

18     bombs were thrown on it.  It wasn't set on fire, but the hand-grenades

19     were thrown on the building.

20        Q.   At transcript page 6118 and following, you mentioned a meeting

21     that you attended on the 20th of April, that was the day after the

22     municipal building had been attacked with hand-grenades and shells.  You

23     had a meeting with General Talic, Basara, Major Zeljaja, and

24     representatives of the SDS, SDA, and HDZ.  Do you know where

25     Major Zeljaja was stationed?


Page 18693

 1        A.   On that day you mean?  On that day, Major Zeljaja escorted

 2     General Talic when we met exactly at 12.00 noon to discuss these events.

 3             THE ACCUSED: [Interpretation] Could I intervene.  The witness

 4     said the hand-grenades were thrown on the building and then the witness

 5     said "after we left the building," and "after we left the building" was

 6     not recorded in the transcript.

 7             JUDGE KWON:  Mr. Karabeg, can you confirm that?

 8             THE WITNESS: [Interpretation] Yes.

 9             THE INTERPRETER:  The interpreter's note that they really cannot

10     hear the witness well unless all other microphones are switched off.

11             JUDGE KWON:  Mr. Karabeg, when you speak, could you come closer

12     to the microphone.  Thank you.

13             MS. SUTHERLAND:  Your Honour, I seek to tender those last two

14     documents, 65 ter 04894 and 05008.

15             JUDGE KWON:  Yes, both will be admitted.

16             THE REGISTRAR:  As Exhibits P3304 and P3305 respectively,

17     Your Honours.

18             MS. SUTHERLAND:

19        Q.   Mr. Karabeg, the document also notes that -- 65 ter 05008, which

20     is now P3305, talks about ethnical divisions.  Is that right?  Was the --

21     was there actual divisions on ethnic lines that were occurring in the

22     municipality?

23        A.   Let me tell you --

24             THE INTERPRETER:  Could all other microphones be switched off.

25             THE WITNESS: [Interpretation] I told you that up until the last


Page 18694

 1     Assembly session was held, the situation was quite normal.  Following

 2     that, the Serbs insisted on divisions, they wanted to have their part,

 3     they had various outbursts in order to create tensions between Serb and

 4     non-Serb population.  They wanted in every possible way to stir up

 5     conflict because they were the stronger side and they would win in that

 6     conflict.  We always tried to avoid it.  They wanted to have their own

 7     police force, they wanted to have their own organs, they wanted their own

 8     municipality.  Moreover, they even wanted their own parts of certain

 9     streets.  For example, some longer streets had Bosniaks living in it,

10     Serbs, and then in another part they had Bosniaks again.  They even

11     wanted to split those streets.  They tried to provoke the others in every

12     possible way.  They wanted to -- the outcome -- exactly the outcome that

13     came about.

14             MS. SUTHERLAND:

15        Q.   Mr. Karabeg, just a couple of follow-up questions, and you

16     mentioned that the Serbs were stronger.  In what sense did you mean that?

17        A.   Let me tell you.  I think sometime until the 17th or

18     18th of March, 1992, there was a withdrawal of the 6th Krajina Brigade

19     from Pakrac.  That was the brigade that came fully equipped with full

20     weaponry, heavy weapons, and small arms, and so on, and they took

21     positions on all check-points in Sanski Most municipality.  In early

22     days, they wanted just to formally to see people's IDs and then some

23     seven or eight days they started searching vehicles, people who were

24     non-Serbs --

25        Q.   [Previous translation continues] ...


Page 18695

 1        A.   -- which -- yes?  And the situation remained until the end, even

 2     further after we were arrested, after the 25th of May I think.  That is

 3     to say that they took the entire Sanski Most municipality.  They had the

 4     power, they held everything in the municipality as compared to Muslims,

 5     Bosniaks, and Croats.

 6        Q.   Mr. Karabeg, can I ask you to look at another document,

 7     65 ter 05025.  It's a document dated the 30th of April, 1992, and it's

 8     "Conclusions of the Crisis Staff of the Serbian Municipality of

 9     Sanski Most."  In that document under point 1, it says that negotiations

10     and discussions conducted with extremist segment of the SDA and HDZ have

11     ended.  Who were the Serbs conducting the negotiations with?  Who were

12     the -- who were the individuals from the SDA and the HDZ?

13        A.   See here, they were the leaders of the SDA and the HDZ

14     specifically.  I was one of the extremists, as they put it --

15        Q.   Do you --

16        A.   -- the discussions were attended by the president of the HDZ

17     party as well as the vice-president.  On behalf of the SDA there was the

18     president of the party and the president of the Deputies Club and myself

19     as the president of the Executive Board.  On behalf of the SDS there was

20     the president of the party, the president of the municipality, and

21     president of the SDS Deputies Club of the Sanski Most Municipal Assembly.

22     In other words, all those who held functions in the municipality of

23     Sanski Most attended these discussions.

24        Q.   And did you or any of the others from the SDA and the HDZ hold

25     extremist views?


Page 18696

 1        A.   Well, see here --

 2        Q.   Mr. Karabeg, are you able to answer that with a yes or a no?

 3        A.   Yes.

 4        Q.   Did any -- or did you or anticipate of the others from the SDA

 5     and the HDZ hold extremist views?

 6        A.   Let me tell you, according to them, the Serb side, yes.  Had I

 7     been an extremist of any sort, I would not be sitting here today --

 8        Q.   According to you --

 9        A.   -- or anyone else --

10        Q.   Okay.  So according to you, did you or any others from the SDA

11     and the HDZ hold extremist views?

12        A.   No.

13        Q.   What was the SD -- what was the SDA policy in 1992 towards other

14     ethnic groups that lived in Bosnia-Herzegovina at the time?  And this --

15     specifically the Croats and the Serbs.  And if you can very, very briefly

16     tell the Chamber that.

17        A.   Let me tell you.  The policy was for an independent whole

18     Bosnia-Herzegovina where all the peoples present in the area would live

19     together.  The same applied to our parts, Sanski Most.

20        Q.   Mr. Karabeg, I want to turn now to the 25th of May, when you were

21     arrested and taken to the SJB and detained in the prison facility behind

22     the police station.  And this is at transcript page 6139.  I only want to

23     ask you a couple of questions in relation to your detention at the SJB in

24     prison and the Betonirka garage because your arrest and detention are

25     covered very well, very detailed, I should say, in the Brdjanin


Page 18697

 1     testimony.  Do you know a person called Simo Simetic?

 2        A.   Simo Simetic with an S, yes.

 3        Q.   What was his occupation?

 4        A.   I think he was a butcher.

 5        Q.   How long had you known him for in 1992?

 6        A.   Well, let me tell you, I knew him or I had known him for

 7     ten years.  When I said that he was a butcher, well, I have to in fact

 8     say that he worked in an abattoir, a place where you slaughter cattle.

 9        Q.   How often would you see him around the town?

10        A.   Well, let me tell you, I would see him often about the town.  I

11     wasn't in his company nor were my friends, but he did socialise mostly

12     with the Bosniaks, Muslims.  He liked to make jokes, he was joyful, and

13     he was a decent man, not prone to any outbursts or making any sort of

14     trouble.

15        Q.   Did you see him during your detention; and if so, where?

16        A.   Well, I did see him not just once.  I saw him in garage 3 when a

17     man was arrested as were his three sons, and he was taken to the garage.

18     And when this man Sales got in with his two sons, they were crying.  And

19     I asked them, "What's wrong with you?  You are alive?  Why are you

20     crying?"  But then I heard noise, somebody shouting, "Get in, get in."

21     And then I saw his son.  Simo -- well, they were pushing him --

22             THE INTERPRETER:  Can the witness repeat what he said.  He was

23     incomprehensible.

24             MS. SUTHERLAND:

25        Q.   Mr. Karabeg, the interpreters haven't understood your answer very


Page 18698

 1     well.  You mentioned the name of the son and then in the transcript it

 2     says "Simo."  Was Mr. Sales's son called Simo or was he called something

 3     else?

 4        A.   No.  It was Simo Simetic.  Sales was the parent --

 5        Q.   Yes.

 6        A.   -- the father of the three sons.

 7        Q.   And what was the name of the son who you saw getting -- being

 8     beaten?

 9        A.   I know that one of them is called Amir and the other one Damir, I

10     think.  I think Amir was being beaten.  At any rate, it was the middle

11     son who was being beaten.

12        Q.   Does he have a son called Sulejman?

13        A.   Sulejman is the father.

14        Q.   Ah-ha.

15        A.   Sulejman Sales is the father of the three sons.  Amir, Damir and

16     I don't know what the youngest one's name was.

17        Q.   In any event you mentioned that this was happening in the garage,

18     garage number 3.  Is this Betonirka garage?

19        A.   Yes, yes.

20        Q.   Now, you said that they were pushing him, Sulejman Sales's son

21     and that was where the interpreters lost you.  Can you please just very

22     briefly tell the Trial Chamber what you saw Simo Simetic doing.  And

23     could you please be very brief.

24        A.   Simo Simetic stopped in front of the entrance with Sales's son,

25     the middle son, and he was beating him outside the garage, forcing him to


Page 18699

 1     enter the garage though the door to it was locked.  And the little one

 2     was telling me later on that he grabbed him by his head, beating his head

 3     against the door and telling him, "Why don't you get in?"  I heard it, I

 4     didn't see it, I wasn't able to.  But I did see Simo Simetic pushing his

 5     bloodied son into the room whilst holding a submachine-gun in his other

 6     hand and wearing sunglasses.  That's why I knew it was Simo Simetic,

 7     because I saw him there and then I heard the story from the young man

 8     later.  I was unable to see what was happening outside the door, but I

 9     heard the punches.

10        Q.   [Previous translation continues] ...

11        A.   And it lasted for a while.

12        Q.   Did he have any function at the Betonirka garage that you're

13     aware of?

14        A.   I think he was one of the guards, but he was standing at the gate

15     leading to the garages there.  I don't think he was guarding the garages

16     themselves.

17        Q.   [Previous translation continues] ...

18        A.   And I think he was ashamed because most of us who were held there

19     knew him.

20        Q.   And how often did you see him there?

21        A.   Where?

22        Q.   Betonirka or anywhere else where you were detained.

23        A.   Let me tell you, I saw him once in Betonirka.  And since I was

24     transferred from there to the prison facility and from there to Manjaca,

25     I wasn't able to see him later.


Page 18700

 1        Q.   Mr. Karabeg, I want to turn now to the 31st of October, 1992.

 2     You were on a convoy sent from the Manjaca camp to Travnik as part of an

 3     exchange; is that right?

 4        A.   Yes.

 5        Q.   I don't intend asking you any questions today about your

 6     detention in Manjaca because it's covered in your Brdjanin testimony.  At

 7     page -- transcript page 6068 of your testimony you state that after you

 8     arrived in Travnik, you and others set up the Presidency of the

 9     Crisis Staff for Sanski Most in exile.  In that position or any other,

10     were you aware of what was happening with the non-Serb population in

11     Sanski Most municipality other than those of you who were detained or had

12     been detained?  Were those people staying or leaving the municipality?

13        A.   Well, see here, we set up a War Presidency for the municipality

14     of Sanski Most with a provisional seat in Zenica.  Next we moved to

15     Travnik.  It was no Crisis Staff.  It was a legal body of the

16     municipality of Sanski Most provisionally seated in Zenica first and then

17     Travnik.  As president of the War Presidency, I was there to receive

18     every convoy carrying people for exchange from Travnik to Turbe.  Every

19     year there were four to five convoys of some five to ten buses each, and

20     it was from these people that I learned what the situation was like in

21     Sanski Most.  And it was, I think, in the month of March of 1995 that I

22     received the last convoy.  So that was the basis of my information about

23     the events in Sanski Most.  I would learn it from those people who were

24     being exchanged in the period between 1992 and 1995.

25        Q.   In relation to people leaving the municipality in convoys, were


Page 18701

 1     you aware of any requirements that were imposed by the Serb or the SDS

 2     authorities on non-Serbs to leave the municipality around -- at that

 3     time, in 1992?

 4        A.   Let me tell you, whoever wanted to leave their native area, they

 5     had to sign a statement that they were handing over that property.  They

 6     had to pay all the outstanding fees, such as tax on land, waste disposal,

 7     water-supply, et cetera.  So they had to cover all the outstanding debts

 8     and sign a statement saying that they were leaving the property to

 9     someone, giving it as -- away as a present.  Whoever decided to stay had

10     to sign a statement of loyalty to the municipality of Sanski Most or --

11     that is to say, Banja Luka.  Whoever refused to do so received threats to

12     the effect that their homes would be blown up, that hand-grenades would

13     be hailed at them, which is what did happen at the time.

14             So nobody went of their own free will, though it appeared that

15     way.  In effect, it was done under threat and duress.  The goal of the

16     Serbian side was not to have more than 10 per cent of the population in

17     Sanski Most, that everything else should be driven out, and the same went

18     for the Croatian -- the Croat population.

19        Q.   Mr. Karabeg, just a follow-up question on that.  How -- how do

20     you know -- what is your source of information in relation to the goal of

21     the Serbian side was not to have more than 10 per cent of the population

22     in Sanski Most?

23        A.   Well, let me tell you, there were these documents of theirs.

24     There were their documents, and what's more, Gornji Mahala and Otoka, the

25     neighbourhoods of Sanski Most, used to have 100 per cent Muslim


Page 18702

 1     population.  We saw a blueprint which envisaged that their homes would be

 2     destroyed and new housing development built.  Some 70 per cent of the

 3     homes and buildings that used to be populated by the non-Serbs in

 4     Sanski Most --

 5        Q.   Mr. Karabeg --

 6        A.   -- was destroyed.  There were neighbourhoods --

 7        Q.   When you say "we saw a blueprint," who was "we" and where did you

 8     see this?

 9        A.   When I say "we," I mean -- I actually mean I, I saw these

10     documents.  As a representative of the civilian government, I was among

11     the first to go to the municipality of Sanski Most and I held in my hands

12     this very blueprint, according to which there would have been a new

13     housing development in Sanski Most for the purposes of the Serb

14     population.  Another project of theirs was also --

15        Q.   Sorry --

16        A.   -- well-known --

17        Q.   Sorry, Mr. Karabeg.  When you say that you saw these documents

18     first, you're talking about after the liberation of Sanski Most in

19     October 1995, are you not?

20        A.   Yes, yes.  I never stepped foot in Sanski Most from

21     22nd of August, 1992, up until 12th of October, 1995, when Sanski Most

22     was liberated.

23        Q.   Mr. Karabeg, I have very limited time.  I want to show you one

24     more document and then ask you a couple of questions, but you mentioned

25     that "another project of theirs was also" and then I interrupted you.


Page 18703

 1     Can you very, very briefly explain what you were about to say.

 2        A.   No.  What I wanted to say was this:  When they shelled

 3     Sanski Most, there were streets and neighbourhoods where there was mixed

 4     population.  So they issued reports over the media that those Bosniaks

 5     who were loyal to the Serb people should hang white sheets out of their

 6     windows.  This was an indication for them to be able to target these very

 7     Muslim homes with artillery that was -- with long-range artillery.  So

 8     that's how they were able to target them in these mixed neighbourhoods.

 9        Q.   Mr. Karabeg, can I ask you to look at 65 ter 05115.

10             MS. SUTHERLAND:  And while that's coming up, Your Honour, I

11     tender 05025.

12             JUDGE KWON:  Thank you.

13             MS. SUTHERLAND:  The document that we just saw.

14             JUDGE KWON:  Referring to extremists?

15             MS. SUTHERLAND:  Yes.

16             JUDGE KWON:  Yes.  We'll admit that.

17             THE REGISTRAR:  As Exhibit P3306, Your Honours.

18             MS. SUTHERLAND:

19        Q.   Mr. Karabeg, this document 65 ter 05115 is dated the 2nd of July,

20     1992.  It's a decision of the Sanski Most Crisis Staff on the criteria

21     for the possibility of departure from the municipality.  The document

22     states that voluntary departure from Sanski Most municipality shall be

23     allowed only under two conditions, either a statement stating voluntarily

24     leaving on a permanent basis and that they are signing immovable property

25     over to the Sanski Most municipality or if they exchange the property


Page 18704

 1     with someone else.  Is this consistent with what you were aware of at the

 2     time as to the requirements for leaving the Sanski Most municipality by

 3     the non-Serb population?  And I think you've alluded to it a little

 4     earlier in your answers.

 5        A.   Yes.

 6             THE ACCUSED: [Interpretation] Can we intervene in the

 7     translation.  Took place at the disposal of does not mean to sign

 8     property over.  It is stated here that the property should -- shall be

 9     signed over to the municipality of Sanski Most, whereas the original

10     document reads it shall be signed over or it shall be handed over to the

11     municipality of Sanski Most at their disposal, and that's something else.

12             MS. SUTHERLAND:

13        Q.   Mr. Karabeg, do you see the original?

14        A.   Yes.

15        Q.   Does it state what Mr. Karadzic is stating it states?

16        A.   Can it be enlarged a bit.

17        Q.   Actually I think it's -- I think it would be better if the

18     interpreters read out the text.

19             JUDGE KWON:  Or they can translate as we read.  That's

20     probably -- somebody could read out.

21             MS. SUTHERLAND:  Yeah.  If we could read Article 1 of the

22     decision, please.

23             Voluntary departure from Sanski Most municipality shall be

24     allowed to families and persons -- or, sorry, I'm reading the English

25     translation which -- is it possible the interpreters could read


Page 18705

 1     Article 1, please, of the document.  It's on the screen.

 2             JUDGE KWON:  Or, Mr. Karadzic, can you kindly read Article 1.

 3             THE ACCUSED: [Interpretation] Thank you.

 4             "Voluntary departure from the territory of the municipality of

 5     Sanski Most is hereby permitted to the families and individuals who give

 6     a statement to the appropriate municipal body of administration

 7     (Municipal Secretariat for general administration, physical planning and

 8     housing and utilities) to permanently leave the territory of the

 9     municipality and leave their immovable property at the disposal of the

10     municipality of Sanski Most."

11             This is what I'm interested in -- or rather, I can finish.  And I

12     continue:

13             "The individuals referred to in the paragraph above may take out

14     all their movable property from the territory of the municipality where

15     they have drawn up a list of property to be certified by the appropriate

16     body of municipal administration."

17             That is the end of the article.

18             THE WITNESS: [Interpretation] Can I explain this?  Mr. Karadzic,

19     you would perhaps be right in saying "leave at the disposal of."

20     However, do not disregard the bit where it says "the citizens who leave

21     the municipality of Sanski Most permanently," permanently, that's what it

22     says.  This means that this citizen who permanently leaves this area will

23     never get the property back if their departure is permanent.

24             MS. SUTHERLAND:

25        Q.   [Previous translation continues] ...


Page 18706

 1        A.   Permanently, off you go, and it is well-known what the procedure

 2     is when the transfer of property is concerned --

 3             JUDGE KWON:  Mr. Karadzic just read out the article for the

 4     benefit of us understanding the article.

 5             Do you have more?

 6             MS. SUTHERLAND: [Microphone not activated]

 7             JUDGE KWON:  But then we can take a break or you would like to go

 8     on until the break?

 9             MS. SUTHERLAND: [Microphone not activated]

10             JUDGE KWON:  Microphone.

11             Yes.

12             MS. SUTHERLAND:  I have approximately three questions.

13             JUDGE KWON:  Yes, please proceed then, Ms. Sutherland.

14             MS. SUTHERLAND:

15        Q.   Mr. Karabeg, the document that you see in front of us, is that

16     consistent with what you were aware of at the time as to the requirements

17     for leaving the Sanski Most municipality?  Were people -- were people

18     voluntarily leaving --

19        A.   Yes.

20        Q.   Were people voluntarily leaving?

21             THE INTERPRETER:  Interpreter's note:  We cannot hear the

22     witness.

23             THE WITNESS: [Interpretation] Not a single man said that he had

24     left voluntarily.  They were crying because they had to leave.

25     Nevertheless, they said freedom is freedom.  The pressure was so great


Page 18707

 1     all the time, torture as well against them, and then they had to leave

 2     the municipality of Sanski Most.  And all of them said to me:  It seems

 3     that their plan, or rather, wish will be carried out, namely, that

 4     Sanski Most will not have more than 10 per cent Bosniaks.

 5             MS. SUTHERLAND:  [Microphone not activated]

 6             Your Honour, I seek to tender this document.

 7             JUDGE KWON:  That will be admitted.

 8             THE REGISTRAR:  As Exhibit P3307, Your Honours.

 9             MS. SUTHERLAND:

10        Q.   I have two more questions, Mr. Karabeg -- three.  What was the

11     approximate figure of the non-Serb population pre-war, that is, around

12     the 1991 census, if you know?

13        A.   I do know.  I took part in these censuses too.

14        Q.   Are you able to give us the --

15        A.   This is the way it was --

16        Q.   -- the figures, I just need the figures, please, for the non-Serb

17     population if you're able to tell us.

18        A.   Non-Serbs, there were 28.000 of them and 4.700 Croats --

19             THE INTERPRETER:  And the interpreter did not hear the other

20     figure.

21             MS. SUTHERLAND:

22        Q.   Mr. Karabeg, you gave two figures, one was for the Muslims and

23     one was for the Croats; is that right?

24        A.   Yes, that's right.  So all together it was non-Serbs.

25        Q.   And approximately how many non-Serbs were left in the


Page 18708

 1     municipality in -- by October 1995 when the town was liberated?

 2        A.   On the 13th of October, 1995, we were conducting a census and the

 3     population of Sanski Most was 575, 284 of which were Croats and the rest

 4     were Bosniaks.

 5        Q.   And my last question:  What physical or psychological effects, if

 6     any, do you suffer as a consequence of the beatings and the mistreatment

 7     during your detention at the Sanski Most police station, the Betonirka

 8     garage, and the Manjaca detention facilities?

 9        A.   First of all, I don't have a single tooth of my own.  All of

10     these are fake teeth because I was kicked in the teeth.  When they throw

11     you on the ground, then they kick you in the face and teeth.  I'm

12     diabetic since then and the result of that diabetes is the weakening of

13     my eyesight, as you have seen, and there is the possibility of me going

14     blind all together.  Also when the weather changes I feel pain and I

15     feel ...

16        Q.   [Microphone not activated]

17             JUDGE KWON:  Microphone, please.

18             MS. SUTHERLAND:

19        Q.   Mr. Karabeg, I'm sorry, the interpreters didn't catch the last

20     part of your answer.  You said you feel -- when the weather changes you

21     feel pain and I feel ... what?

22        A.   I feel pain and I feel -- I feel -- I mean my legs, in my legs,

23     it's hard for me to walk.

24        Q.   Thank you, Mr. Karabeg.

25             MS. SUTHERLAND:  Your Honours, I have no further questions and we


Page 18709

 1     could possibly deal with associated exhibits after the break.

 2             JUDGE KWON:  Or we can do that right now.

 3             MS. SUTHERLAND:  Okay.  I seek leave to add one of the associated

 4     exhibits listed on the Rule 92 ter notification and that's 65 ter 23453.

 5     It's the fifth item listed on the notification which was filed on the

 6     2nd of September.  This was discussed both in evidence in chief and in

 7     cross-examination in the Brdjanin trial --

 8             JUDGE KWON:  You are not adding 23404 -- I'm sorry, 23450 to

 9     23452?  My understanding you are seeking --

10             MS. SUTHERLAND:  Yes, Your Honour --

11             JUDGE KWON:  -- leave in relation to those four documents?

12             MS. SUTHERLAND:  Yes, Your Honour.  I'm sorry.

13             JUDGE KWON:  I don't think -- do you have any objection,

14     Mr. Robinson?

15             MR. ROBINSON:  No, Mr. President.

16             JUDGE KWON:  Given that they are part of indispensable and

17     inseparable associated exhibits, we grant it.

18             There are -- any objection in relation to other associated

19     exhibits?

20             MR. ROBINSON:  No, Mr. President.

21             JUDGE KWON:  Ms. Sutherland, can I draw your attention to

22     65 ter 00545, which is referred to in the transcript page 6160, where the

23     Prosecution just drew the attention of the Chamber and didn't ask any

24     question to the witness.  So you might -- in Chamber's view that it does

25     not form an inseparable and indispensable part of the transcript.  So if


Page 18710

 1     you find it necessary to tender this document, I would like you to lead

 2     the evidence.

 3             MS. SUTHERLAND:  Yes, Your Honour.  Did you want to have a break

 4     now.  I can look at the document in the break?

 5             JUDGE KWON:  And in the meantime, if you could take a look at

 6     65 ter numbers 5022, 5073, and 5090.  The thing may be that in relation

 7     to these final three documents you are tendering not for the truth of the

 8     content of those documents, but just to have the Chamber understand the

 9     context of the witness's evidence.

10             We'll take a break for an hour, after which we'll hear the

11     cross-examination of the witness by the accused.

12             But, Mr. Karadzic, with respect to Mr. Robinson's request to

13     extend your time for cross, at the moment the Chamber is not minded to

14     extend your time for your cross-examination.  At the end of those

15     three hours, the Chamber may reconsider your application.

16             MR. ROBINSON:  Mr. President, would the Chamber consider removing

17     the cross-examination from the 92 ter package and giving us the five and

18     a half hours that were used on cross-examination because we don't -- it

19     seems like perhaps that's one of the things that has allowed the Chamber

20     to conclude that three hours for Dr. Karadzic is sufficient in the face

21     of seven and a half hours of direct examination, and we don't find that

22     that five and a half hours is that useful to us, given that Mr. Brdjanin

23     was blaming the military, General Talic was blaming civilians, and

24     Dr. Karadzic is charged with responsibility for both.  So if you feel

25     that the reason you've diminished our time was because there was


Page 18711

 1     cross-examination in Brdjanin, we would prefer to remove that

 2     cross-examination from the evidence and use the time in a way that is

 3     more consonant with Dr. Karadzic's defence.  Thank you.

 4             JUDGE MORRISON:  Well, that's certainly a point that we will

 5     reconsider at the end of the three hours, Mr. Robinson.  I see the logic

 6     behind the application.

 7                           [Trial Chamber confers]

 8             JUDGE BAIRD:  Mr. Robinson, I do agree with the comments of

 9     Judge Morrison.

10             MR. ROBINSON:  Thank you very much, Judge Baird.

11             JUDGE KWON:  This may be the case that Mr. Karadzic can show us

12     an example that he can be efficient and focused.

13             We'll have a break for an hour and resume at 1.40.

14                           --- Luncheon recess taken at 12.42 p.m.

15                           --- On resuming at 1.45 p.m.

16             JUDGE KWON:  Yes, Ms. Sutherland.

17             MS. SUTHERLAND:  Your Honour, in relation to 65 ter 00545, I

18     agree that the exhibit isn't associated.  Mr. Cayley simply read in two

19     lines into the record on the back of another document which dealt with

20     events happening in Vrhpolje and Hrustovo.  In relation to -- so I don't

21     seek to have that admitted as an associated exhibit.

22                           [Trial Chamber confers]

23             MS. SUTHERLAND:  At least with this witness.

24             JUDGE KWON:  Yes.

25             MS. SUTHERLAND:  In relation to 65 ter 05073, at transcript


Page 18712

 1     page 6298, Defence counsel read out one sentence to the witness about

 2     this Milos document dated the 29th of May, 1992, and he was asked whether

 3     he knew anything about the incident of people from the SDA being killed

 4     and quite a number of them being captured or arrested.  And he said:

 5             "I heard about these events.  As I said already I was in prison

 6     and couldn't witness it myself."

 7             So basically albeit hearsay, but he has confirmed what was read

 8     to him.  So I would seek the admission of that document.

 9             JUDGE KWON:  Yes.

10             MS. SUTHERLAND:  In relation to 65 ter 05090, at transcript

11     page 6253, Defence simply asks the witness to confirm who this

12     Crisis Staff decision of the 6th of June was sent to.  And I agree that

13     the witness can't confirm that the Crisis Staff were ordering the SJB to

14     evacuate 150 prisoners to Manjaca, but he did say in his evidence today

15     that five convoys of detainees were taken from Sanski Most to Manjaca.

16             JUDGE KWON:  Given the position of the Defence, that can be

17     admitted.

18             MS. SUTHERLAND:  Yes, I seek its admission, Your Honours.

19             JUDGE KWON:  Yes.

20             MS. SUTHERLAND:  And finally in relation to 65 ter 05022, at

21     transcript page 6133, the witness was read the first paragraph of this

22     conclusions of the Crisis Staff meeting held on the 28th of April, 1992,

23     dealing with the fact that all citizens were -- who possessed any kind of

24     weapons should hand it in to the public police station.  And he was asked

25     whether he was aware of the decision at the time, and he said no.  But


Page 18713

 1     then he was further questioned on transcript page 6134:

 2             "Were you aware that the population was being disarmed at the end

 3     of April?

 4             "A.  I was.

 5             "Q.  Were all ethnic groups within the population being disarmed,

 6     Serbs, Croats, and Muslims?

 7             "A.  Only non-Serbs were being disarmed.

 8             "Q.  How do you know this?

 9             "A.  I saw it with my own eyes."

10             And then he's taken to another part of the document and asked a

11     question about that, to which he didn't know the answer to.  But I think

12     that he sufficiently dealt with the issue of disarming of the population

13     and I seek the admission of that document.

14             JUDGE KWON:  Yes, that can be admitted as well.

15             Finally, in relation to Mr. Rasula's diary, is it 65 ter 4988 or

16     20591 that you are tendering?

17             MS. SUTHERLAND:  I would seek to tender the 65 ter number

18     04988 --

19             JUDGE KWON:  Okay.

20             MS. SUTHERLAND:  -- because that's the certified copy of the

21     larger range of the diary.

22             JUDGE KWON:  But we are going to admit only those pages shown to

23     the witness, so could you liaise with the court deputy to identify the

24     page numbers.

25                           [Trial Chamber and Registrar confer]


Page 18714

 1             JUDGE KWON:  Is it your intention, Mr. Robinson, that the Defence

 2     is going to use that document as well?

 3             MR. ROBINSON:  Yes, Mr. President.

 4             JUDGE KWON:  Then you do not object to admitting it in its

 5     entirety or ...?

 6             MR. ROBINSON:  Yes, we do object to admitting it in its entirety.

 7     We think that it ought to be limited to the pages used by either side.

 8             JUDGE KWON:  Very well.  So if the parties could co-ordinate with

 9     the court deputy to identify those page numbers later on.

10             MS. SUTHERLAND:  Your Honour, can I just say that this document

11     is going to be used with other witnesses as well, it's not just this

12     witness.  So I don't know whether --

13             JUDGE KWON:  Then they can be added later on when you are going

14     to use that document later on.

15             MS. SUTHERLAND:  Yes, Your Honour.  And I would just note that it

16     was admitted also in its entirety not only in Brdjanin but in the

17     Krajisnik trial as well.

18             Mr. Tieger wants to add something, Your Honour.

19             MR. TIEGER:  I was just going to say perhaps we can speak to

20     Mr. Robinson about this further and perhaps come to some consensus about

21     the admissibility of this document and similar types of documents.

22             JUDGE KWON:  We'll admit only those pages at the moment and we'll

23     come back to it later on.

24             MS. SUTHERLAND:  Very well, Your Honour.

25             JUDGE KWON:  Thank you.


Page 18715

 1             Yes, Mr. Karadzic.

 2             THE ACCUSED: [Interpretation] Thank you.

 3                           Cross-examination by Mr. Karadzic:

 4        Q.   [Interpretation] Good afternoon, Mr. Karabeg.

 5        A.   Good afternoon.

 6        Q.   I have to remind both you and myself to pause so that we do not

 7     cause the interpreters any headaches.  I wanted to thank you because you

 8     were kind as to talk to the Defence via videolink.  I hope that this will

 9     help us be as efficient as possible and with a view to cross-examining

10     you as smoothly as possible.

11        A.   Thank you.

12        Q.   I would like to start with something that you said today on

13     pages 50 and 51 of the transcript; namely, that you - that is to say, the

14     Muslim community in Sanski Most - were in favour of what was legal and

15     what was lawful and that you were in favour of life together.  Do you

16     agree that tensions arose considerably before the outbreak of the

17     conflict in Sanski Most?

18        A.   Well, I have said that we did not have any problems until the

19     Municipal Assembly of Sanski Most on the 6th or 7th of April.  There were

20     tensions but it wasn't major tensions.  We sat together, we co-operated.

21     I tell you, I as the number two man, together with the president of the

22     municipality, Rasula, we had meetings every day, working hours started at

23     7.00, but every day from 7.00 until 8.00 we would sit and have a cup of

24     coffee and consult about our work.

25        Q.   Thank you.  Why then was it necessary for the Muslim community to


Page 18716

 1     arm secretly and organise itself for war considerably before the

 2     6th of April?

 3        A.   Let me tell you, that is what you are saying.  That is what you

 4     are saying.  We in Sanski Most did not arm ourselves; we felt no need to

 5     do so.  Because until then, there were joint guards, there was joint

 6     guard duty, the Territorial Defence had distributed weapons to everyone,

 7     that is to say, Serbs and Muslims and Croats.  The people did feel

 8     something, though, and they were arming themselves, at least that's what

 9     I think.

10        Q.   Thank you.  Are you trying to say that these guards were

11     organised because of the war in Croatia or because of mutual suspicions

12     and fears?

13        A.   Well, let me tell you, it was both, it was both.

14        Q.   Thank you.  Now I would like to call up a document, a book, and

15     I'm sure that you know about it.  Zilhad Kljucanin and Hazim Akmadzic, do

16     you know them?  They are the authors.

17        A.   Yes, yes.  Kljucanin is from a village near Sanski Most and

18     through Zilhad I also met Akmadzic.  They are writers.

19        Q.   Thank you.

20             THE ACCUSED: [Interpretation] 1D31, can we have that, please,

21     that is to say, 1D00031.  I beg your pardon 1D4253, can we have that,

22     please.  1D4253.  Thank you.

23             MR. KARADZIC: [Interpretation]

24        Q.   This is the first page.  Do you know this book?

25        A.   Yes.  Yes, yes.


Page 18717

 1        Q.   Thank you.

 2             THE ACCUSED: [Interpretation] Can we have a look at page 3 of

 3     this book.  Thank you.

 4             MR. KARADZIC: [Interpretation]

 5        Q.   Is the publisher the Municipality of Sanski Most, is the

 6     co-editor Bosnjak, and then there is a reference here to the board, that

 7     includes yourself, Mehmed Alagic, Adil Draganovic, Kljucanin, Lemes, and

 8     so on?

 9        A.   Yes.

10        Q.   Thank you.

11             THE ACCUSED: [Interpretation] Can this be admitted?  Actually,

12     this is just in order to identify a book which we do not have in its

13     entirety.  We are just going to be tendering parts of the book that have

14     been translated.  So can it be MFI'd for the time being, that is to say,

15     the front page and the third page, so I'm talking about those two pages.

16             JUDGE KWON:  I don't see a basis to admit it now.  I don't hear

17     anything from the witness except for the author.

18             THE ACCUSED: [Interpretation] Your Excellency, Mr. Karabeg is a

19     member of the editorial board.  This is a book that they edited and

20     published.  I'm not going to tender the entire book because I don't have

21     a translation of the entire book.  This is just for the sake of

22     identification and the parts that I'm going to tender can then be

23     registered under the same number.  So what we need is some kind of cover

24     page, as it were, where these other pages can fit in.

25             JUDGE KWON:  Very well.  We'll admit those five pages, first


Page 18718

 1     five pages, which -- and we'll mark it for identification.

 2             THE REGISTRAR:  As MFI D1677.

 3             MS. SUTHERLAND:  Sorry, Your Honour, I don't understand what's on

 4     the first five pages that we're admitting.

 5             JUDGE KWON:  We'll see.  The witness confirmed that he's a member

 6     of this board.  I see that he -- the witness's name --

 7             MS. SUTHERLAND:  Yes.

 8             JUDGE KWON:  -- and what relevance it will have --

 9             MS. SUTHERLAND:  Okay.

10             JUDGE KWON:  -- we can find out.

11             THE ACCUSED: [Interpretation] Thank you.

12             Can we now have 1D00031.  Thank you.

13             Can we have page 51 now, please, in the book itself.  It would be

14     page 4 if it were a separate document but if we're looking at the entire

15     book it is 51.  We do have a translation for pages 51 and 52.  Actually,

16     can we go back to the previous page in English.  I would like to draw

17     your attention to this part in the box, where it says that the SDA

18     started collecting money for the procurement of weapons.  In August 1991

19     a certain amount of money for weapons was collected, you can see that for

20     yourself.  I don't need to read it out.  So from August 1991 the SDA was

21     collecting money to buy weapons in Sanski Most.

22             And Hasib Kamber is the man in charge as well as Rasim Karabeg.

23     What is Rasim Karabeg to you?

24        A.   Nothing.  I know him but we're not related, very distantly

25     perhaps.


Page 18719

 1        Q.   But you are from the same family, aren't you?

 2        A.   Well, we're supposed to be but sort of seven or eight times

 3     removed.  Well, yes, my ancestors and his come from the same village.

 4        Q.   Thank you.  Do we agree, Mr. Karabeg, that explosive is not a

 5     hunting weapon in any conceivable way?

 6        A.   I agree.

 7             THE ACCUSED: [Interpretation] Can we have the next page and the

 8     English translation, too, of page 52.  Next page in Serbian -- actually,

 9     the previous one in Serbian.  Yes, that's it.

10             MR. KARADZIC: [Interpretation]

11        Q.   Now, this is how it continues, Rasim Karabeg and then it goes on

12     to say -- you see it for yourself:

13             "Kamber obtained in late 1991 and the beginning of 1992 a certain

14     amount of explosive ..."

15             Do you agree that one can only use explosives for destruction,

16     that this is a terrorist device?

17        A.   Well, let me tell you, you can do all sorts of things with

18     explosives.  You can destroy, you can blow up things if you need to do it

19     for your own purposes.

20        Q.   Thank you.  Please look at the names.  Who else raised funds for

21     buying weapons?  And it is the elite of the SDA that is referred to,

22     yourself included, and it is also hodza Husein Efendija Kovacevic and all

23     these names, we can all see them here.  And it says here that the ways in

24     which the Green Berets are going to be used have been differentiated.

25        A.   Let me tell you, collecting money for the procurement of weapons


Page 18720

 1     is not the same thing, I mean procuring and buying weapons.  What you say

 2     about the Green Berets, well, yes, for the most part it was the

 3     Territorial Defence where people were arming themselves and where they

 4     did organise themselves.

 5        Q.   All right.  So we see here that due to heightened police and

 6     military checks -- you see what it says here, that communication is more

 7     difficult because police and military checks have been heightened and

 8     also supervision on the part of the State Security Service and the

 9     military security.  So it is these checks that made it more difficult to

10     conduct the activity that you were involved in?

11        A.   I did not quite understand what you were saying.

12        Q.   Well, read out this part that I've just read out.

13        A.   Can it be zoomed in, please.

14        Q.   I am going to read it out.

15             "It is important to point out the fact here that in Sanski Most

16     there was not a clear differentiation as to how and when the combat

17     groups of the Green Berets should be used, primarily because

18     communication was more difficult with the regional centre and the centre

19     in Sarajevo.  The reason for impeded communications should be sought in

20     heightened police" --

21             JUDGE KWON:  Mr. Karadzic, don't waste time reading out the

22     documents.

23             Mr. Karabeg, can you read the document?

24             THE WITNESS: [Interpretation] Yes, I understood this.

25             JUDGE KWON:  Yes.


Page 18721

 1             What is your question?

 2             THE WITNESS: [Interpretation] Yes, yes.

 3             MR. KARADZIC: [Interpretation]

 4        Q.   My question is:  Do you agree that this document clearly shows

 5     that checks and patrols were justified and that they were impeding the

 6     consolidation of the Green Berets?

 7        A.   That is what you're saying.  That is what you claim.  Checks

 8     could not be justified because this is only the Serb side that was

 9     carrying out these checks at these check-points.  But I am talking about

10     this part, where Sanski Most, Prijedor, and Banja Luka, and Kljuc, and

11     Mrkonjic are and so on and so forth, where the Serb side absolutely took

12     over.  That was one of the reasons, one of the causes, that led to the

13     beginning of this instability.  You know that full well.  A proposal had

14     been made and at first there were joint patrols, but the Serb side did

15     not agree to that.  They just wanted to have their own patrols and their

16     own checks.

17        Q.   Thank you.  Did you inform the Serb side about the fact that you

18     had established the Green Berets, that you had purchased 2 tonnes of

19     explosive and weapons?

20        A.   I don't know what kind of 2 tonnes of explosives are you talking

21     about, what kind of weapons are you talking about?  I am saying that in

22     Vrhpolje and Hrustovo people had organised themselves.  But informing

23     someone about something, whoever wants to do things legally and these

24     others are doing it illegally and destroying everything, I think that

25     that is absurd.  You are now trying to say that we -- I mean when I say


Page 18722

 1     "we," it's not Bosniaks.  You are trying to say that we did what you did.

 2        Q.   Thank you.

 3             JUDGE KWON:  Sorry, I was not clear and so I'm asking you,

 4     Mr. Karabeg, again.  According to this book, you are referred to as

 5     having participated in the raising of funds and collection of arms and

 6     you also -- you referred to -- you said that collecting money for the

 7     procurement of weapons is not the same thing.  But you agree that you

 8     participated in collecting money?

 9             THE WITNESS: [Interpretation] Yes, I said that and, if I may add,

10     the weapons that were bought were bought from the Serbs, who sold

11     dysfunctional weapons.  And when they asked for the weapons to be

12     returned, he knew which piece of weaponry was located with what person.

13             JUDGE KWON:  Thank you, Mr. Karabeg.

14             Yes, Mr. Karadzic.

15             THE ACCUSED: [Interpretation] Thank you.

16             MR. KARADZIC: [Interpretation]

17        Q.   Can we see the bottom part where it is stated that in early 1992,

18     before the war, it says that around 900 Bosniaks were armed.  Is that

19     right?

20        A.   I don't know how many there were in Vrhpolje and Hrustovo.  I

21     know that there were around 170 of them when they took prisoners --

22     prisoner those Serbs, but I believe that those who remained were arrested

23     by the Serbs.

24        Q.   Yes, but we're talking now about the period of 1992 three months

25     before the war, where it says that 900 Bosniaks were armed.  And this is


Page 18723

 1     the book that you helped edit and released for publication the way it is

 2     now; right?

 3        A.   Well, I'm saying that it is possible this was the case because

 4     people were arming themselves independently, illegally, and you did

 5     everything legally.  You had the territorial weapons and everything else.

 6        Q.   Thank you.

 7             THE ACCUSED: [Interpretation] Can we have the next page.

 8             MR. KARADZIC: [Interpretation]

 9        Q.   Well, this is precisely what puzzled me because you said earlier

10     on that you were the ones doing everything legally and the Serbs

11     illegally.  And now it turns out that the Serbs had weapons legally,

12     through the TO, and the Muslims were the ones arming illegally.  This is

13     what you just said, did you not?

14        A.   Well, yes, of course.

15        Q.   Thank you.  Let us go back to the text in the box.  It says that

16     the most important activity during that period of time was that of

17     intelligence and that Serb policemen knew everything that was being done

18     and who it was done by.  And then you also mention the municipalities

19     like Vrhpolje, Trnovo, Hrustovo, Sehovci, Kamengrad, and then the towns

20     neighbourhoods of Mahala and Muhic, all of which were armed.  So we're

21     talking about the local communes that were further away from the town

22     proper, whereas the neighbourhoods of Mahala and Muhici were part of

23     town?

24        A.   Well, I can't see that.

25        Q.   We're talking about the lower box.


Page 18724

 1        A.   Well, I can't read it properly.  Are you talking about the read

 2     line, the red box?

 3        Q.   Yes.

 4        A.   This is fine now.

 5        Q.   Is Mahala in the very centre of the town, part of the town, and

 6     Muhici is on the periphery, is it a suburb?

 7        A.   Yes.

 8        Q.   Thank you.

 9             THE ACCUSED: [Interpretation] Can we have the next page.

10             MR. KARADZIC: [Interpretation]

11        Q.   Look at the third paragraph from the top where it is stated that

12     a meeting was held where the Serbs asked for their organs -- and it is

13     stated there that following this meeting, Mirzet Karabeg went to the

14     Sanski Most Municipal Assembly, the Serbs and -- the Muslims and the

15     Croats and said that they had legal state organs behind them.  Is that

16     right, there was a division within the police force, the Serbs asked for

17     two police stations, two Municipal Assemblies, and listed what in their

18     view was to constitute the municipality of Sanski Most.  And then you

19     went on to say that the Muslim and Croat part of the police force was the

20     legitimate power behind this police station?

21        A.   Well, it wasn't the term "police" that was used at the time,

22     rather, it was "milicija," and our police force was driven out of the

23     police station to the fire brigade premises.  And when we left this

24     meeting where attempts were made at resolving the issue, they did not

25     want to agree to any other discussion but that we should pledge loyalty


Page 18725

 1     to the Serbs, embrace the Serb flag, et cetera.  I was the president of

 2     the Executive Board at the time and I left the police building with Redzo

 3     for the municipal building, where I heard that our police force had been

 4     chased away and was now housed in the fire brigade building.  At that

 5     point we decided to invite them to join us in the municipal building.

 6     That's how it was.

 7        Q.   Mr. Karabeg, they were not chased away.  Rather, they were

 8     offered that they should form a Muslim-Croat police station within the

 9     fire brigade building.  Now, let me ask you this:  Was Mr. Rasula a man

10     number one in the municipality of Sanski Most, was he not the president

11     of the Municipal Assembly?

12        A.   Yes, he was the man in charge because the man in charge in a

13     municipality is the president of the municipality.

14        Q.   Thank you.  Is it not the case that under our Law on All People's

15     Defence a president of the municipality is ex officio the president of

16     the defence council for a municipality and commander of the

17     Territorial Defence, meaning its supreme commander?

18        A.   This was the case indeed up until the tensions emerged on the

19     6th and the 7th of April.  I as the president of the Executive Board

20     dealt with these issues which were subsequently taken over by the

21     president of the municipality.  Because under the regulations in force, I

22     was the person in charge of the executive government and he was in charge

23     of the legislative branch.

24        Q.   [No interpretation]

25             THE INTERPRETER:  Can Mr. Karadzic please repeat his question.


Page 18726

 1             THE WITNESS: [No interpretation]

 2             JUDGE KWON:  I'm sorry, Mr. Karabeg, because of the overlapping,

 3     the interpreters were not able to catch what you were just talking about.

 4             So could you start from your question again.

 5             MR. KARADZIC: [Interpretation]

 6        Q.   The question was, which Mr. Karabeg affirmed, whether the

 7     president of the municipality was, under the prevailing system, the

 8     person in charge in the municipality?

 9        A.   Yes, he was.

10        Q.   Very well.  This person who was in charge was man number one.

11     Was he also not in favour of having the Muslim and Croat policemen

12     proclaimed as the legitimate police force?

13        A.   Which police force do you mean, the Serb police force?  Which

14     legitimate force of milicija?

15        Q.   You say or the book says that Kurbegovic and you went and told

16     the Muslims and Croats in the fire brigade building that they were the

17     legitimate police force and that legitimate state organs were backing

18     them up and Rasula was not backing them.

19        A.   No.  Well, Rasula was the person who was mostly in favour of the

20     divide in the police force.  He was the person undermining the whole

21     system.

22             THE ACCUSED: [Interpretation] Can we have pages 50 through 55 of

23     this document admitted, please.

24             JUDGE KWON:  We'll add these pages from pages 51 to 55 to the

25     previous one which has been marked for identification.


Page 18727

 1             Yes, please continue.

 2                           [Trial Chamber and Registrar confer]

 3             THE ACCUSED: [Interpretation] Thank you.

 4             JUDGE KWON:  Yes, I forgot to mention to you, Mr. Karadzic, given

 5     that this is translated only partially, we need a full translation.

 6     That's part of the reason we put it marked for identification.

 7             THE ACCUSED: [Interpretation] Thank you.

 8             MR. KARADZIC: [Interpretation]

 9        Q.   Is it true that in mid-March in the building of the Islamic

10     religious community a meeting took place between the leadership of the

11     SDA of Sanski Most with Mr. Osman Brka, high official of the Main Board

12     of the party in Sarajevo?

13        A.   I don't know when this happened, but Osman Brka was in

14     Sanski Most in that period of time.

15        Q.   Thank you.

16             THE ACCUSED: [Interpretation] Can we have 1D00009, 1D9, in

17     e-court.

18             MR. KARADZIC: [Interpretation]

19        Q.   Did you attend this meeting?

20        A.   No.

21        Q.   But you do know that the meeting took place?

22        A.   Yes, but I wasn't there because the president of the

23     Executive Board of Bosanska Krupa was killed in a traffic accident and I

24     attended his funeral that day.  But I do know about the meeting.

25        Q.   Thank you.  Do you see that the meeting took place on the


Page 18728

 1     16th of March, 1992?  Can you confirm that?  We can all tell that, can we

 2     not?

 3        A.   Well, I did say that the meeting took place, but I don't know if

 4     that was the date.  It is possible.

 5        Q.   Thank you.  Do you recall that on the 18th of March we achieved,

 6     in Konak, in Sarajevo, an agreement all three sides with regard to the

 7     Cutileiro Plan that three cantons or three constituent units should be

 8     established in Bosnia-Herzegovina two days after the meeting, this

 9     meeting?

10        A.   Well, I don't know when it took place, but I did learn of the

11     Cutileiro Plan from the media.

12        Q.   Thank you.  Can you now please look at the agenda and I can read

13     it out for you if you have difficulties with your eyesight.  Under 1,

14     report on the current political and security situation in the republic.

15     And under 2, the functioning of the SDA.

16             Can you tell us why were these meetings taking place in the

17     Islamic religious community since they were party meetings?

18        A.   Well, I can tell you right away that the meeting took place in

19     the building of the workers' university where all of us, including the

20     Serbs and Croats, met and not in the Islamic religious community.  And

21     let me tell you, even if it had been held in the Islamic religious

22     community, I don't see anything wrong with that.  The Islamic religious

23     community did not have the appropriate rooms for such meetings.

24        Q.   But the text does say that the meeting took place there.  Could

25     it not have left the impression with the Serbs that this was some sort of


Page 18729

 1     a secret meeting?

 2        A.   I don't know.  I don't know.

 3        Q.   Can you have a look at the text below the date.  It says here in

 4     the premises of the building of IVZ.  Does it not stand for the Islamic

 5     religious community?

 6        A.   Yes, it does.  I told you that it wasn't held there, but I don't

 7     even see that it would have been problem if it had been held there.

 8        Q.   Thank you.

 9             THE ACCUSED: [Interpretation] Can we have the next page.  If we

10     could -- well, the others can follow the text in English.

11             MR. KARADZIC: [Interpretation]

12        Q.   Perhaps we can keep the Serbian version for you to read.

13             THE ACCUSED:  Do you need the English on the screen?

14             [Interpretation] Could the OTP and the Trial Chamber have the

15     English version and the witness only the other one.

16             JUDGE KWON:  We are following the English version on our personal

17     computers.  Please proceed.

18             THE ACCUSED: [Interpretation] Thank you.

19             MR. KARADZIC: [Interpretation]

20        Q.   Please look at the following portion.  Osman Brka reads, and I'll

21     read from English:

22             [In English] "... Has everything that was supposed to happen

23     really happened.  I must say that all of this is absolutely necessary.

24     We could have been destroyed as a people and that is why we took this

25     stand.  The space opened for democracy in the areas of the former


Page 18730

 1     Yugoslavia has enabled for the historic Muslim issue to be resolved in a

 2     just way.  The awakening of the people, Muslim people, is in full swing

 3     relating to one's own religion and tradition, it is becoming more and

 4     more evident.  The Muslims in the areas where they have been a minority

 5     amongst the Serbs went through the most difficult times.  It is important

 6     to become organised.  With the help of Allah and Alija Izetbegovic we

 7     will eventually come out of this chaos as moral and ultimate victors.

 8     The fact ..." and so on and so forth.

 9             [Interpretation] So the SDA position was that the Muslim people

10     was awakening and that it should reach its goal.  What was the goal of

11     the Muslim people?

12        A.   A united and independent Bosnia-Herzegovina where all three

13     peoples would live together, namely, the Croats, the Serbs, and the

14     Bosniaks.

15        Q.   But of course, in order for that marriage to work, there had to

16     have been the consent of the Serbs as well?

17        A.   Well, of course.  I have to smile at what you're saying.  And my

18     apologies to the Trial Chamber.

19        Q.   And was there the consent of the Serbs for the idea of leaving

20     Yugoslavia and living in an independent Bosnia?

21        A.   I am addressing the Chamber now.  The questions you are putting

22     to me are nonsensical and they are common knowledge.  Of course there was

23     no consent on the part of the Serb people to leave Yugoslavia, of course

24     there wasn't.

25        Q.   Very well.  Let's see what Mr. Brka has to say further down.  He


Page 18731

 1     says that there would be -- there would be more victims and there would

 2     be trouble, but in return we will get what we want.  Conflict is possible

 3     but, day to day, it is growing less likely.  The world has understood who

 4     wants what and so on.  And then he goes on to say that Alija Izetbegovic,

 5     Silajdzic and Ganic are doing their job well.  And then on the next page

 6     in Serbian he says that the legal army, we have to gain time and

 7     procrastinate.

 8             At the time you went to Sarajevo to consult Mr. Izetbegovic;

 9     right?

10        A.   Let me tell you, seldom.

11        Q.   Well, this was on the 16th.  And on the 19th you went to

12     Sarajevo, didn't you?

13        A.   Which month?

14        Q.   March.

15        A.   Possible.  Possible.  I think that I did.

16        Q.   On the 19th of March, when you were together with the late

17     Mr. Izetbegovic, did you receive information on the agreement that had

18     been reached on the 18th of March?

19        A.   Yes, in principle.  It was touched upon briefly.  Do you think

20     that Mr. Izetbegovic had that much time that he could spend as much as we

21     wanted him to spend with us?

22        Q.   But you received information that Bosnia would look differently.

23     Were you told at the time that it was a true, genuine, agreement or not?

24        A.   Let me tell you, he didn't really tell us anything about it.  He

25     wanted to hear our opinion on occasion, wanted to hear the opinion of as


Page 18732

 1     many of us as possible, and he never revealed his decisions.

 2        Q.   Well, this is why I'm interested in this, Mr. Karabeg.  If, on

 3     the 19th of March, you were informed that an agreement had been reached

 4     on the future form of Bosnia to which we agreed that such a Bosnia could

 5     secede from Yugoslavia, providing that it had the form that was agreed on

 6     the 18th of March, did you go back to Sanski Most thinking that it was

 7     all a trick or that it would indeed be that way?

 8        A.   Let me tell you, I went to Sanski Most in fear.  I had to pass

 9     through all those check-points.  I was arrested in Mrkonjic with Redzo.

10     We were taken away, mistreated, and interrogated for five hours.

11     Therefore, I really had no time to formulate my opinion and to reflect on

12     that.  Moreover, I think that it was Ramadan and Redzo and I were on

13     fast.

14        Q.   All right.  Upon learning that three ethnic communities agreed

15     that Bosnia would be independent in the then-existing borders and that it

16     would have three constituent units, did you stop the campaign of arming

17     and --

18             JUDGE KWON:  Yes, Ms. Sutherland.

19             MS. SUTHERLAND:  Your Honour, the witness has just said that he

20     didn't know much about the disagreement and Mr. Karadzic is now putting

21     words into his mouth as to what he did know.

22             JUDGE KWON:  Very much so, and still complaining about the

23     shortage of time.

24             MS. SUTHERLAND:  Quite, Your Honour.

25             JUDGE KWON:  Move on to your next topic, Mr. Karadzic.


Page 18733

 1             THE ACCUSED: [Interpretation] Excellencies, with all due respect,

 2     if the witness was there one day after the agreement and they did

 3     continue with their war preparations in Sanski Most despite of that,

 4     that's quite an important piece of information.  And I want to obtain it

 5     from the witness.  Whether after the 19th of March they stopped with war

 6     preparations in Sanski Most.

 7             THE WITNESS: [Interpretation] What preparations?  I told you what

 8     happened.  We were arrested and mistreated for five hours, just as you

 9     are mistreating me now here as I'm giving evidence to this Court.  I

10     asked you, do you really think that Alija had time to talk to us as much

11     as we wanted and when we wanted?  It was just coincidental that I as the

12     president of the Executive Board of the municipality went to visit

13     waterworks in Sarajevo and then I stopped by to see whether there was

14     anything new there.

15             JUDGE KWON:  Mr. Karadzic, Mr. Karadzic, Mr. Karabeg, please put

16     a pause between the questions and answers.

17             And, Mr. Karadzic, please bear in mind that cross-examination is

18     not an opportunity to argue with the witness.  Put your question and you

19     had heard the answer and please get on with it.

20             THE ACCUSED: [Interpretation] Thank you.

21             MR. KARADZIC: [Interpretation]

22        Q.   Could I ask you to look at --

23             THE ACCUSED: [Interpretation] Do we need to go into private

24     session?

25             JUDGE KWON:  Yes, yes.


Page 18734

 1            [Private session] [Confidentiality partially lifted by order of Chamber] 

 2             JUDGE KWON:  We are in private session, Mr. Karadzic.

 3             MR. KARADZIC: [Interpretation]

 4        Q.   Mr. Karabeg, do you see here that a conclusion was reached to set

 5     up the Crisis Staff and that Mr. Sabic was tasked with it, and then Sabic

 6     goes on to say that you were all well organised and that the headquarters

 7     had been informed.  Do you see what it says here?

 8        A.   No.

 9        Q.   Here at the top it says -- when did you set up the Crisis Staff

10     in Sanski Most and when did you do that in the surrounding villages and

11     local communes?

12        A.   Never.  I would like to know what is this document that you're

13     putting to me, what is this?

14        Q.   These are minutes of the SDA meeting held in the premises of the

15     Islamic religious community during the visit of Osman Brka, we're still

16     working on the same document.

17        A.   I repeat that I was not present, that this meeting was not held

18     in the premises of the Islamic religious community, and I don't know what

19     you want from me when it comes to these documents.  What is it

20     specifically that I'm supposed to tell you in respect of what is before

21     me?

22        Q.   Tell us, please, was Mr. Sead Sabic in charge of setting up the

23     Crisis Staff?

24        A.   Yes.

25        Q.   Thank you.


Page 18735

 1             JUDGE KWON:  Just a second.  This is very minor, but can we show

 2     the first page to the witness, top.

 3             I take it this is the minutes of the SDA, the 7th Session of the

 4     Executive Board of the SDA, and it is noted here that it was held on the

 5     premises of the IVZ, but the English translation says IVZ means

 6     Executive Council of the Association.  But Mr. Karadzic is repeating that

 7     it is some Islamic foundation or something.

 8             Could you help us in that regard?

 9                           [Trial Chamber and Registrar confer]

10             THE WITNESS: [Interpretation] Let me tell you, these are the

11     minutes of the 7th Session of the Executive Board of the SDA in

12     Sanski Most.  It does say here "IVZ," which does stand for the Islamic

13     religious community.

14             JUDGE KWON:  Thank you.

15             Please continue, Mr. Karadzic.

16             THE ACCUSED: [Interpretation] Thank you.

17             Can we go back to page 3, please.

18             MR. KARADZIC: [Interpretation] What it says here, what Mr. Sabic

19     says.

20             "We have already informed the headquarters with a lot of

21     information.  We thought that we would receive from the headquarters some

22     weaponry.  It is not a good time to keep silent about the current

23     situation.  We have to take a responsible attitude towards the arming.  I

24     think that Sanski Most is being neglected by the headquarters."

25             So tell us, please, did they continue with arming in the second


Page 18736

 1     half of March?

 2        A.   Well, how could they have done it when you came in with the

 3     6th Brigade and the entire Sanski Most was divided.  The citizens were

 4     unable to move about.  As for the weapons, I'm not denying that people

 5     obtained weapons, procured weapons, on their own, seeing what the

 6     situation was.

 7        Q.   Thank you.

 8             THE ACCUSED: [Interpretation] Could we see next page.

 9             MR. KARADZIC: [Interpretation]

10        Q.   Until it comes up, did they conceal anything from you --

11             MS. SUTHERLAND:  Your Honour -- sorry.

12             JUDGE KWON:  Yes, Ms. Sutherland.

13             MS. SUTHERLAND:  Your Honour, it would help with Mr. Karadzic if

14     he's going to quote what's in the document to actually put where the

15     quotes are starting and also where they're finishing because I don't know

16     whether it's part of the document or it's Mr. Karadzic's comment at the

17     end of the part that he's reading out because I don't have the English --

18     I don't appear to have the English translation of what's being read out.

19     So --

20             JUDGE KWON:  Given that this was a short one so that I was able

21     to follow in my case, but I see your point what you just submitted.

22             So I take it that Mr. Karadzic will heed to your advice.

23             MR. KARADZIC: [Interpretation]

24        Q.   Could you please look at who is proposing this at the -- the name

25     at the top, Rasim something.  He's proposing to get in touch with police


Page 18737

 1     commander, commander of the TO, ensure weapons and units, ensure

 2     Territorial Defence units, gather the Crisis Staff so that they could

 3     give proposals, get together the defence ministry, I guess their offices,

 4     organise ourselves, and have a meeting of the Crisis Staff and subunits.

 5        A.   Let me tell you, I can make out some words, TO and so on.  All of

 6     this was supposed to be joined.  The municipal defence secretariat was

 7     not headed either by a Bosniak or a Croat, but by a Serb.  His name was

 8     Mladen.

 9             JUDGE KWON:  Yes.

10             MS. SUTHERLAND:  Your Honour, I don't know whether we need to

11     still be in private session.

12             JUDGE KWON:  Yes, I was about to ask the reason for that, but I

13     forgot.

14             What was the reason why we should be in private session,

15     Mr. Karadzic?

16   (redacted)

17   (redacted)

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)


Page 18738

 1             We go back to open session and we will lift the confidentiality

 2     as well as the video and audio of the previous part.

 3             Thank you for your reminder, Ms. Sutherland.

 4             MS. SUTHERLAND:  Except for just the last discussion that we've

 5     just had.

 6                           [Open session]

 7             JUDGE KWON:  Very correct.  Yes.

 8             Yes, Mr. Karadzic.

 9             THE ACCUSED: [Interpretation] Thank you.  Thank you.  This suits

10     the Defence better.  I'm just trying to be cautious and not cause any

11     difficulties.

12             MR. KARADZIC: [Interpretation]

13        Q.   Therefore, you were a prominent member of the SDA, you were one

14     of the founders, and the Serb side considered you one of the more extreme

15     individuals, as you have put it yourself.  Now, let us put aside whether

16     they were right or not.  Do you understand that, given what they

17     believed, they suspected you and your actions, some of the things you

18     did?

19        A.   Let me tell you this.  The Serb side had this policy whereby some

20     200 or 250 of us were declared to be extremists.  They said that those

21     250 extremists, had it not been for them, we could live together with

22     Muslims and Croats.  And among those 250 there were Muslims and Croats.

23     Some of them -- some of us were killed, some were put in prison, in

24     Betonirka, and so on, and some were deported to Manjaca.  And when we

25     disappeared, the 250 of us, they said again that had it not been for


Page 18739

 1     extremists things would have been better.  So this is how it was, from

 2     the 25th of May until the 10th of October of 1995, this was their main

 3     theme.  They killed 250 elderly people about a month before Sanski Most

 4     was liberated.  This is what I wish to say about what they termed

 5     "extremists."  As for the SDA, yes, I'm one of the first founders of the

 6     party.

 7             THE ACCUSED: [Interpretation] Before we leave this document,

 8     could we zoom in.  Osman Jukanovic.  They speak about subunits

 9     subbranches, Vrhpolje, Tomina, Caplje, Husimovci, Trnova, and Sehrevci

10     and Pobrijezje.

11             Could we see the lower third of the page, the lower third.  It

12     says here that they agreed that self protection should be set up in these

13     places Vrhpolje, Tomina, Kijevo -- could we scroll down to see the other

14     names of villages.

15             MR. KARADZIC: [Interpretation]

16        Q.   Are these the villages where you said that people organised

17     themselves, Vrhpolje, Tomina, Kijevo, Caplje, Husimovci, Trnova, and so

18     on?

19        A.   Yes, yes.  These are the villages with majority of Muslim

20     population except for Tomina.  I don't know what you mean by self-defence

21     of that population which was mixed.

22        Q.   However, Mr. Karabeg, this does not seem to be the case of self

23     organisation but, rather, the result of an order from the SDA.

24        A.   Well, you are free to hold views as you please and to interpret

25     things as you please.  All of these and can we please -- all these are


Page 18740

 1     documents taken from the diary of - what's his name? - Nedeljko Rasula.

 2     He relied on these issues and insinuated things as his documents and his

 3     evidence against us.

 4        Q.   But, sir, these are the minutes of your own party, not his.

 5        A.   No, these are not our minutes.  These are his notes.

 6             THE ACCUSED: [Interpretation] Can this be admitted, please.

 7             JUDGE KWON:  Yes.

 8                           [Trial Chamber and Registrar confer]

 9             JUDGE KWON:  I was told that this interpretation is not -- it is

10     not one done by the CLSS but by Defence team.  Is my understanding

11     correct, Mr. Karadzic?

12             THE ACCUSED: [Interpretation] I think it has a number, the

13     translation has an ERN number.

14             It's a draft summary so it must be a translation of the OTP, or

15     rather, the service.

16             JUDGE KWON:  We'll admit it.

17             Yes, Ms. Sutherland, can you help us in that regard?

18             MS. SUTHERLAND:  Your Honour, we can certainly look up the MIF

19     to -- because the English translation has an ERN number on it.

20             JUDGE KWON:  I think it's a full translation.  We'll admit it.

21             MS. SUTHERLAND:  Thank you.  Very well.

22             THE REGISTRAR:  As Exhibit D1678, Your Honours.

23             JUDGE KWON:  Yes, Mr. Karadzic.

24             MS. SUTHERLAND:  Your Honour, sorry, Mr. Reid informs me that

25     it's an AID translation.


Page 18741

 1             JUDGE KWON:  Thank you.

 2             THE ACCUSED: [Interpretation] Thank you.

 3             MR. KARADZIC: [Interpretation]

 4        Q.   Mr. Karabeg, you were able to see in that book that they were

 5     complaining about the military security and state security having been

 6     aware of these preparations that were underway.  So do you agree that the

 7     Serbs were well aware of what their neighbour -- Muslim neighbours,

 8     Muslims, were doing as they were preparing for battle?

 9        A.   What preparations for battle?

10             THE ACCUSED: [Interpretation] Can we have D5 just briefly,

11     please.

12             MS. SUTHERLAND:  Your Honour, while we're waiting for that to

13     come up --

14             THE ACCUSED: [Interpretation] Can we have the translation as

15     well.

16             MS. SUTHERLAND:  -- the MIF for the previous document says it's a

17     summary translation so we will have the document checked, and if it's not

18     a full translation, we'll advise the Defence.

19             JUDGE KWON:  Thank you very much.  We'll mark it for

20     identification.

21             THE ACCUSED: [Interpretation] Thank you.

22             MR. KARADZIC: [Interpretation]

23        Q.   Mr. Karabeg, look at this, on the 7th of March, one Milos, an

24     intelligence operative, reports about the fact that several individuals

25     were spotted in Sanski Most wearing the uniforms of the Green Berets,


Page 18742

 1     that they carried semi-automatic or automatic rifles, that they bore the

 2     insignia of the crescent and Islamic symbol.  It was assumed that

 3     3.000 citizens of Muslim ethnicity were in possession of long-barrelled

 4     weapons.  And the main proponents of these activities on behalf of the

 5     SDA were Ismet Saracevic, lawyer; Suad Sabic, lawyer; Adil Draganovic,

 6     president of a court; Revzid or Resid Kurbegovic, president of the SDA

 7     board; Mirzet Karabeg, president of the Executive Board of Sanski Most,

 8     et cetera.  Can you not see here that already on the 7th of March the

 9     Serbs were well aware of what was coming, of what was brewing?

10        A.   I don't know what sort of report this is.  Is this true at all?

11     Whose report is this?  What sort of a report is it?  I told you that

12     people at Hrustovo and Vrhpolje organised themselves.  Now, what you did

13     throughout the period up until the month of October 1995, what was it you

14     were doing all that time?  The questions you are putting now to me deal

15     with I don't know what.

16        Q.   Mr. Karabeg, the problem here is that participants in a joint

17     government, senior officials such as president of the court,

18     president of -- or the prime minister, local prime minister, are putting

19     together the Green Berets, procuring weapons, arming people, getting

20     consulted on these issues and the Serbs are fully aware of it all

21     throughout that time.  What do you expect them to do?

22        A.   Well, let me tell you this:  If this is indeed what we were

23     doing, how many Serbs lost their lives in that period of time?  Why don't

24     you ask me that?  And how many Serbs and Croats were taken prisoner and

25     killed?  Was there a single Serb who was taken prisoner and who could he


Page 18743

 1     have been taken prisoner by?  If indeed, as you put it, we had so many

 2     things and had procured so many things.

 3             JUDGE KWON:  Just a second.

 4             THE WITNESS: [Interpretation] Why don't you put the question

 5     of ...

 6             JUDGE KWON:  Ms. Sutherland.

 7             MS. SUTHERLAND:  Your Honour, I was only making -- going to make

 8     the observation that Mr. Karadzic puts the document to the witness.  He

 9     said I don't know what sort of report this is, whose report this is, what

10     sort of a report it is, and then went on to say a few sentences.  And

11     then Mr. Karadzic just says the problem here is that -- and then goes on,

12     when he could actually advise the witness what the report is.

13             JUDGE KWON:  I think it's time to adjourn for today.  Yes.

14             Mr. Karadzic, I would like to recommend you to have a word how to

15     conduct your cross-examination more efficiently with Mr. Robinson.

16             We'll rise for today and continue tomorrow at 9.00.

17             Mr. Karabeg, probably you have been briefed about it, but you are

18     not supposed to discuss about your testimony with anybody else.  Do you

19     understand, sir?

20             THE WITNESS: [Interpretation] Yes.

21             JUDGE KWON:  9.00 tomorrow.

22                           --- Whereupon the hearing adjourned at 2.59 p.m.,

23                           to be reconvened on Wednesday, the 14th day of

24                           September, 2011, at 9.00 a.m.

25