Page 25018
1 Wednesday, 22 February 2012
2 [Open session]
3 [The accused entered court]
4 [The witness takes the stand]
5 --- Upon commencing at 9.03 a.m.
6 JUDGE KWON: Good morning, everyone. Good morning, Mr. Lesic.
7 THE WITNESS: Good morning, sir.
8 JUDGE KWON: Today we are sitting pursuant to Rule 15 bis,
9 Judge Morrison away due to his urgent personal matters.
10 Yes, Ms. West. Please continue. Good morning to you.
11 MS. WEST: Good morning, Mr. President. May I be heard on one
12 quick housekeeping matter from yesterday.
13 JUDGE KWON: Yes, please.
14 MS. WEST: You will remember that Mr. Mitchell was discussing
15 with the witness 65 ter 7981. He inadvertently forgot to tender it to
16 the Court. You will remember this was the document regarding
17 Mr. Karadzic's orders regarding the journalists and how they were to
18 travel. I can be -- I can be -- I can speak on its admissibility if
19 there is any objection.
20 JUDGE KWON: That may be similarly treated as the exhibit at that
21 we admitted as P4407, but can I hear from you, Mr. Robinson.
22 MR. ROBINSON: Yes, Mr. President. We have the same objection
23 that the witness didn't confirm anything about the document, but other
24 than that it's the same issue.
25 [Trial Chamber confers]
Page 25019
1 JUDGE KWON: We'll admit it for the same reason. That will be
2 admitted as Exhibit P4408.
3 THE REGISTRAR: Your Honours, that will be Exhibit P4439.
4 JUDGE KWON: Thank you. Yes, Ms. West.
5 MS. WEST: Thank you.
6 WITNESS: MILAN LESIC [Resumed]
7 Examination by Ms. West: [Continued]
8 Q. Good morning, Mr. Lesic.
9 A. Good morning.
10 Q. Now, yesterday when we had stopped you had mentioned that you
11 travelled to the region between 1992 and 1995 about ten times. Do you
12 remember talking about that?
13 A. Yes.
14 Q. Okay. Let's talk a little bit more about that. Now, in general
15 in regard to those trips, how often did you meet with General Mladic?
16 A. I would presume each time I went there I met with General Mladic.
17 Q. And how often would you meet with Mr. Karadzic?
18 A. I would say half of that time, not every time.
19 Q. Okay. Now, at one point in the course of those trips did
20 General Mladic make a request of you regarding a video of
21 General Mladic's daughter?
22 A. Yes, he did. His daughter passed away, and he asked me could I
23 next time I came back could I provide him a film. He would like to see
24 it. So I said, Yes, I will. So I made a few -- few my trips copies and
25 put all in one film and delivered to him.
Page 25020
1 Q. But specifically did he ask for footage of his daughter?
2 A. Yes, he did, but I give him more than just the footage of his
3 daughter. I give him three or four times that I been there and all those
4 footages.
5 Q. Okay. Now, yesterday you indicated that when you were
6 interviewed in August of 2009, you brought video-tapes with you to the
7 interview. You brought four with you. Do you remember talking about
8 that?
9 A. Yes.
10 Q. Now, when you went to that interview in August of 2009, were you
11 shown a video-tape that was not one of the four that you brought with
12 you?
13 A. Yes, I was shown, yes. The one that they -- when they raided
14 Mrs. Mladic house they showed me that video that I brought them
15 originally.
16 Q. All right. So, just to be clear, the video that they showed you
17 that you had not brought, did you recognise that video?
18 A. Yes, I did.
19 Q. What did you recognise that video to be?
20 A. I recognised my video and I put together, made over, and I give
21 to General Mladic.
22 Q. All right. So, this was the video you gave to Mladic years ago?
23 A. Yes.
24 Q. Now, I'm going to show you some footage, and this is footage from
25 that video which is a small part of that video. It's 65 ter 45349. This
Page 25021
1 is July 11th, 1993.
2 MS. WEST: There's -- Your Honours, there's a transcript in
3 e-court as well. And we're going to show you a short part from minute
4 26:30 to minute 27:50, and if I can correct myself, 65 ter 45349A.
5 Q. Do you see a video in front of you?
6 A. I will see it will come up. It hasn't come up yet.
7 Q. Okay.
8 A. Yes, I see it now.
9 Q. Okay. Now, sir, you've seen this video in the last couple days.
10 Do you remember this meeting?
11 A. Yes, I do.
12 Q. What was this meeting?
13 A. This meeting I happened to be there the day before that they came
14 from the Trnovo when they sort of free the Trnovo took over was -- and
15 that was discussion about it.
16 Q. All right. And in the screen we see in front of us at 26 minutes
17 33 seconds, can you identify the people there? The person on the left,
18 who is that?
19 A. That is Dr. Karadzic.
20 Q. And then?
21 A. Myself and General Mladic, and I would believe was Koljevic in
22 the back. It's hard to see it.
23 Q. All right. Now, this is -- we're going to play it this is video.
24 Is -- was the video camera yours?
25 A. Yes, it was.
Page 25022
1 Q. And who was operating it at the time?
2 A. My brother-in-law that came with me from Belgrade.
3 Q. And on the occasions that you used your video camera, when you
4 were actually seen in the photo, was it typical that you gave your camera
5 to someone else to operate?
6 A. Yes, that's correct.
7 Q. Okay. So now we'll play.
8 [Video-clip played]
9 MS. WEST: Mr. President, if the translators could translate
10 this. I know there is a transcript that exists, but it might be easier
11 if they simultaneously translate.
12 THE INTERPRETER: Interpreter's note: The soundtrack is not very
13 good.
14 JUDGE KWON: Were they given the transcript?
15 MS. WEST: They were. Maybe if we could wait a moment.
16 JUDGE KWON: I see the -- I'm seeing the transcript in the
17 e-court. Why do you have a redaction there?
18 MS. WEST: Mr. President, that part's not in this clip. That's
19 the reason.
20 JUDGE KWON: So what we are going to hearing is Mr. Karadzic's
21 words?
22 MS. WEST: First we're going to hear from Mr. Mladic, then we're
23 going to hear from Mr. Karadzic.
24 JUDGE KWON: Could you give the 65 ter number again.
25 MS. WEST: Yes, 65 ter 45349A.
Page 25023
1 JUDGE KWON: But in the transcript Mladic's words do not appear.
2 MS. WEST: Your Honour, I'm sorry for this confusion. The part
3 we'll focus on is Mr. Karadzic's words. Mr. Mladic will speak first and
4 then he will speak. So if I can just play it through Mladic, we don't
5 need an interpretation, and then Mr. Karadzic's speech, if that could be
6 interpreted that would be helpful.
7 JUDGE KWON: Very well.
8 MS. WEST: Thank you very much.
9 [Video-clip played]
10 MS. WEST: All right. We are at 26:58, and this is the beginning
11 of Mr. Karadzic's speech. Mr. Lesic, if you can follow along, please.
12 [Video-clip played]
13 THE INTERPRETER: "[Voiceover] Mr. Karadzic: Congratulations to
14 General Mladic and all his commanders, generals, colonels for the success
15 and the speed with which they achieved it. There was a time when we had
16 a very long front line and difficulties with the entire world. That was
17 about Konjevic Polje, Zepa. They thought it was an immense city. It was
18 a village with 3.000 inhabitants. However, they didn't bat an eyelid for
19 Trnovo and there was not a campaign to save Trnovo and to proclaim it a
20 protected area, and that goes to the credit of this army which is as fast
21 as wind. I notice in a Japanese TV series ..."
22 MS. WEST: We're going to stop right there.
23 Q. Mr. Lesic, you heard that speech; correct?
24 A. Yes, I did.
25 Q. Okay. And I know that you've heard it before as well. And
Page 25024
1 Mr. Karadzic's -- can you tell us what event prompted this speech? What
2 was the event this dinner was celebrating?
3 A. Well job done at Trnovo, and they were so quick and no blinked an
4 eye. That was job well done. President congratulate General Mladic.
5 Q. Okay. And in particular, Mr. Karadzic is talking about the
6 international community. He says the entire world knew about -- he
7 mentions Konjevic Polje and Zepa, and then he goes on to say, "However,
8 they," the entire world, "didn't bat an eyelid for Trnovo and there was
9 not a campaign to save Trnovo."
10 Mr. Lesic, was the international coverage, the media coverage, of
11 the events in Trnovo less than the others cities that he had mentioned,
12 Konjevic Polje and Zepa?
13 A. Yes, definitely it was. It was said that evening that no one
14 made any comments or anything. Everything went well, was no any
15 obstructions or any discussions that president heard from anybody.
16 Q. And he goes on to say that there was not a campaign to save
17 Trnovo and proclaim it a protected area. When he says that there wasn't
18 a campaign to save it, who did he believe would support the campaign?
19 Who would have been behind that campaign, from your experience and your
20 presence at this meeting?
21 MR. ROBINSON: Objection, Mr. President.
22 THE WITNESS: The way I understand it --
23 JUDGE KWON: Just a second.
24 MR. ROBINSON: Yes, Mr. President. I believe this is calling for
25 speculation on the part of the witness.
Page 25025
1 [Trial Chamber confers]
2 JUDGE KWON: Could you reformulate your question, Ms. West.
3 MS. WEST: Yes.
4 Q. Sir, when you first came to the area in December of 1992 and you
5 went to the Assembly session meeting, you specifically gave some money to
6 media and propaganda, and you talked about this yesterday; right?
7 A. Yes, that's correct.
8 Q. And so was the issue of international -- the international media
9 coverage of the area one that was of concern to you?
10 A. It was concern to all of us. Like media was always against the
11 Serbs and was never in the middle, and that's what we all in Canada or in
12 Serbian Republic believed.
13 Q. And had you had discussions about this concern with the
14 leadership in Pale?
15 A. Yes, I did. I mentioned to them and what can we do about it. We
16 had some media from Israel there, but they need sort of funds to be
17 spended travelling and cars and gas and all that to be right time and
18 right places. So we as a Humanitarian Organisation Republika Srpska from
19 Canada we tried to help as much as we could to sort of change that, but
20 it was not that easy.
21 Q. And earlier today at page 7, line 9, you said it was said that
22 evening no one made any comments or anything. Everything went well.
23 There was no obstructions or any discussions that the president heard
24 from anyone. When you talk about obstructions or discussions the
25 president heard from anyone, with do you mean by that? Can you tell us a
Page 25026
1 little bit more?
2 A. Well, the UN or Western media didn't make a big outcome that
3 Trnovo was fallen back to Serbian hands. That's what -- what we all felt
4 it, that went nice and easy and quiet.
5 Q. And from that dinner that evening, did you understand that
6 Mr. Karadzic was pleased about that?
7 A. Well, we were all pleased. We were all in that room pleased the
8 way it went. That's how I got that impression. We should be.
9 Q. From your discussions with Mr. Karadzic about this issue of the
10 international media, did you understand whether he placed any blame on
11 the media for interfering with the affairs of the war?
12 A. In my opinion, when I was there visiting and talking to different
13 people like Biljana Plavsic and all of them, we all have some comments
14 about the media position they took, that even though in Canada I recall
15 was long time ago, my boys went to school, 10 and 12 years of age, and
16 the media really played if you're Serb, you sort of -- what the heck you
17 people doing over there, that kind of a thinking was.
18 Q. Okay. We're going to turn to 65 ter 32769, and this is --
19 JUDGE KWON: Yes, Mr. Robinson.
20 MR. ROBINSON: Yes, Mr. President. Before we leave this video, I
21 notice that in the Prosecution's summary of this witness's testimony and
22 particularly in the 92 ter summary that I'm looking at, they've indicated
23 that was said -- what was spoken about on this particular clip involved
24 Konjevic Polje and Cerska, but we received interpretation of
25 Konjevic Polje and Zepa. So I'm wondering which is correct. What did
Page 25027
1 Dr. Karadzic refer to?
2 MS. WEST: I think if we were to look at the transcript we might
3 get an answer to that. I think when we heard the translation perhaps it
4 was a little bit different. I did today hear Konjevic Polje and Zepa. I
5 understand in the transcript itself it says Cerska as well. I think
6 we'll have to go back to the clip.
7 JUDGE KWON: Shall we try it now again?
8 MS. WEST: Thank you.
9 JUDGE KWON: Yes.
10 [Video-clip played]
11 THE INTERPRETER: "[Voiceover] Mr. Karadzic: Congratulations to
12 General Mladic and all his commanders, generals, colonels for the success
13 and the speed with which they achieved it. There was a time when we had
14 a very long front line and difficulties -- the kinds -- the entire world
15 knew about Cerska, Konjevic Polje, and as for Zepa they thought it was an
16 immense city, but it was a village with 3.000 inhabitants. However, they
17 didn't bat an eyelid for Trnovo and there was [sic] a campaign to save
18 Trnovo and proclaim it a protected area, and that goes to the credit of
19 this army which is fast as mind. I noticed in a Japanese ..."
20 MS. WEST: Mr. President, I tender that video-clip.
21 JUDGE KWON: We'll admit it.
22 THE REGISTRAR: As Exhibit P4440, Your Honours.
23 MS. WEST: We may have 65 ter 32769.
24 Q. Mr. Lesic, this is an intercept from October 10th, 1994. And
25 your -- you've looked at this before. Is this a conversation you
Page 25028
1 remember?
2 A. Yes, I do.
3 Q. Okay. Can you tell us who initiated this phone call?
4 A. As I can see it, I believe I called a few times, many times over
5 there with Ned Krajisnik, and with president of humanitarian
6 organisation, Ranko Rakanovic, and we had discussion with different
7 people like General Mladic and his secretary and -- his intelligence,
8 Petar Salapura.
9 Q. And what were the circumstances of the call? Why did you call?
10 A. Well, we just want to sort of say hello and see how they doing.
11 All different calls go to different times. I can't say right now which
12 call. Was many calls.
13 Q. Okay. Fair enough. We're going to focus particularly on page 3
14 of the English, which is the same as the B/C/S. It's the top of the
15 page. And the L is you, the M is Mladic. I'm going to read this small
16 portion out:
17 "Mr. Lesic: Well, now it is time to take advantage of this
18 situation, Iraqi and this situation.
19 "Mladic: I agree. Is it congested there?
20 "Lesic: It is congested, all right. There's 600.000 soldiers.
21 "Mladic: How much, a million?
22 "Lesic: I said America send an army of half a million.
23 "Mladic: What do they want? They want to conquer the world?
24 "Lesic: Well, it certainly looks that way. They want to be the
25 world's police force and Husein is objecting, but for us, this is turning
Page 25029
1 out good.
2 "Mladic: Yes, this is good -- it is good."
3 Mr. Lesic, you remember this call; correct?
4 A. Yes, I do, and I agree with all this that was said.
5 Q. Okay. So now let's just talk a little bit about. It at the very
6 beginning you said it's time to take advantage of this situation, Iraq
7 and this situation. Please explain what you meant by that.
8 A. Well, now, sort of media and all other countries were sort of
9 occupied with Iraq rather than Serbian Republic and former Yugoslavia
10 what's happening there. That was my opinion, and I said that will work
11 in our favour, sort of that they left us alone. Just my opinion and
12 that's how we felt it and that's what I told him over the phone.
13 Q. And towards the end of the conversation you said it's turning out
14 good and Mladic said yes, it is good. Just tell me, good for whom?
15 A. Good -- we've been criticised, like, for example, Gorazde and
16 Zepa, all other little bit -- other little villages that was going on.
17 So we were saying now they maybe left us alone. They won't bug us or
18 media or anything like that. They'll be occupied in Iraq, over there.
19 Q. Mr. Lesic, we're not going to go through the rest of the
20 conversation, but you looked at this transcript the other day. Is this
21 transcript an accurate representation of the entire conversation at the
22 time?
23 A. Yes, it is. It's accurate.
24 MS. WEST: Mr. President, would I move to -- I would tender
25 this --
Page 25030
1 JUDGE KWON: Any objection?
2 MS. WEST: -- intercept.
3 MR. ROBINSON: No, Mr. President.
4 JUDGE KWON: We can admit it.
5 THE REGISTRAR: As Exhibit P4441.
6 THE ACCUSED: I suppose it's MFI as usual.
7 JUDGE KWON: Is it not our practice to admit it in full when one
8 of the interlocutors testified as to the content?
9 THE ACCUSED: I understand, yes. Thank you.
10 MS. WEST: I'm now going to show another video. This is
11 65 ter 40567A. Mr. Lesic, this is one of your videos. It's just a small
12 clip of one of them, and it's from August 1994. And we'll just start
13 playing.
14 [Video-clip played]
15 MS. WEST: We stopped at 40 seconds -- 40 seconds.
16 Q. Were you in this car at the time?
17 A. Yes, I was. And I was moving. I was sort of holding camera.
18 Q. And who else was in the car?
19 A. General Mladic and the other soldier.
20 Q. Okay. And what were the circumstances of this ride? Why were
21 you doing this?
22 A. We just went little bit for ride around Han Pijesak, Crna Rijeka,
23 what they call it, and that's about all. He just want to show us a bit
24 around. There was no reason.
25 MS. WEST: Okay. We'll continue to play it.
Page 25031
1 [Video-clip played]
2 MS. WEST: We're at 1:28.
3 Q. Is that Mr. Mladic driving the car?
4 A. Yes, it is driving the car at that time.
5 [Video-clip played]
6 MS. WEST: We've now stopped at 2:29. And as we saw in the
7 subtitles, it said in the Podrinje, we crash them. And here, if the
8 Americans and the English, the Ukrainians, the Canadians in Srebrenica in
9 the meantime, it's the Dutch would not protect them. There is no sound,
10 but it then follows with they would have disappeared from this area a
11 long time ago.
12 Q. Now, this is August of 1994. By this time how long had you known
13 Mladic?
14 A. Two years, I met him first time 1992 in December, and this was in
15 August 1994, about a year and a half or so, year and eight months, two
16 years, close to two years.
17 Q. And what did you understand Mladic's view to be of the
18 international community's involvement in the war?
19 A. Well, at that day when we were driving around, he was showing me
20 around and how we are well equipped with the trees and with the -- that
21 we could open a sawmills and that country is so rich, had a granite to
22 sell to Switzerland and all that, that is Turks were not there hundred
23 years, and now he's hoping they won't be there. That was just
24 conversation in that vehicle.
25 MS. WEST: All right we're going to continue to play for just
Page 25032
1 another 40 seconds, and I hope that there's sound.
2 [Video-clip played]
3 MS. WEST:
4 Q. And, Mr. Lesic, you remember being on this car ride and having
5 this discussion; correct?
6 A. Yes.
7 MS. WEST: Your Honour, I tender this clip.
8 JUDGE KWON: Yes.
9 THE REGISTRAR: Exhibit P4442, Your Honours.
10 MS. WEST:
11 Q. Sir, I'm going to show you a little bit more video, and this is
12 your footage, but we're actually going to show it from the Srebrenica
13 trial video. It's on another video that we put together. That's P4201.
14 And this is footage from July 16th, 17th and 18th. But before we start,
15 I just want to ask a couple questions. In July of 1995, did you go to
16 Belgrade?
17 A. Yes, I did.
18 Q. And what did you bring with you?
19 A. We were a group of asking from Canada. We brought a scanner tube
20 for the hospital in Belgrade.
21 Q. All right. You said scanner tube, was this a machine --
22 A. This was sort of medical instruments. I tried to get a permit
23 which could be exempt. It was sort of -- gotta wait eight weeks so we
24 got some -- couple husband and wife and they took there as their luggage
25 and they went to Sofia, and two days later when this all arrived three of
Page 25033
1 us came over and we sort of presented to Belgrade hospital, VMA.
2 Q. All right. And so the scanner that was brought over it was
3 actually brought over by a colleague of yours; right?
4 A. Yes, friends from Toronto.
5 Q. And those friends put it in their luggage?
6 A. That's how we travelled.
7 Q. All right. Now, on July 16th, you said you went to the hospital.
8 Which hospital was this?
9 A. In Belgrade called army hospital VMA. It is famous, the best
10 hospital in former Yugoslavia.
11 Q. And there did you have discussions and was there a conference
12 with Mr. Mladic?
13 A. Yes, we did. Was quite a few of us, and we sort of talked about
14 it, and we were congratulated that instruments arrived and president of
15 Humanitarian Organisation Republika Srpska spoke. He was there as well
16 as Ned Krajisnik and I and Mr. Zaroban and his wife and Ilija Rakanovic
17 was six of us from Canada.
18 Q. Did you film parts of this meeting?
19 A. Yes, I did. I believe I did film quite a bit.
20 Q. Okay. So we're going to show you part of that.
21 [Video-clip played]
22 MS. WEST: For the record, this is V009016 of the Srebrenica
23 trial video. We start at 48 minutes and 55 seconds.
24 Q. Sir, do you recognise this room?
25 A. Yes, I do.
Page 25034
1 Q. And what was that room?
2 A. This was sort of reception room where we could have a 10, 20
3 people discussion around the troubles and --
4 MS. WEST: Okay. We'll continue.
5 [Video-clip played]
6 JUDGE KWON: Just a second. Do you have the transcript page in
7 hard copy?
8 MS. WEST: I do, Your Honour. In the -- in the book itself it
9 begins at 07047906. 7906 is where we're beginning with Mr. Mladic's
10 words.
11 JUDGE KWON: Thank you.
12 MS. WEST: Thank you.
13 [Video-clip played]
14 MS. WEST:
15 Q. We stopped at 49 minutes and 41 seconds. This looks to be
16 different, not the meeting any more. What was happening here?
17 A. Mladic was sort of went to the phone and arranging a two cars for
18 us to drive following morning to Pale to Han Pijesak, Crna Rijeka for six
19 of us.
20 Q. And you, in fact, videotaped his conversation?
21 A. I did. Whatever shows here I videotaped, yes.
22 MS. WEST: Okay. Continue.
23 [Video-clip played]
24 MS. WEST: We stopped at 50 minutes and 6 seconds.
25 Q. And here he says you don't have to accepted a car for me. I'll
Page 25035
1 get there. You should send two cars and have them report tomorrow. They
2 should leave in the morning, not tonight. You just mentioned something
3 about cars. Who are these cars for?
4 A. They were for us, for six Canadians that we arrived with scanner
5 tube from Sofia.
6 Q. Okay. And where were you going the following day?
7 A. We are going on Pale and we are going to Mladic headquarters and
8 Crna Rijeka there just sort of give him some morale and see them all and
9 that's about it.
10 Q. And do you know how Mr. Mladic was travelling?
11 A. I don't.
12 Q. We'll continue.
13 [Video-clip played]
14 MS. WEST: We're at 50 minutes and 50 seconds.
15 Q. Mr. Lesic, do you know who Vinko is?
16 A. No, I don't. I just hear the name. He was some kind of a
17 commander somewhere else.
18 MS. WEST: Okay.
19 [Video-clip played]
20 MS. WEST: We're going to stop there, an we're at 51 minute and
21 22 seconds.
22 Q. Now, the following day, did you leave Belgrade?
23 A. Yes, we left Belgrade. We went to Intercontinental. Met over
24 there intelligence Petar Salapura and another driver from army -- jeep.
25 And six of us left with two cars and a jeep.
Page 25036
1 Q. Okay. You just mentioned the Intercontinental. That the hotel
2 where you stayed that night?
3 A. That's the hotel we usually stay when we go there.
4 Q. When you left the next day you mention the Petar Salapura and
5 another driver from the army. Is this the person who accompanied you?
6 A. Every time we would come, Mr. Krajisnik and myself or anybody
7 else, they give us a sort of a security guard to take us around because
8 we are bringing humanitarian aid so that we know where to go.
9 Q. Okay. On the 17th, did you also take footage?
10 A. Yes, I did.
11 Q. All right. So we're going to continue and we're just going to
12 finish out this footage because I think that will be quicker, and we'll
13 continue on to the next day.
14 [Video-clip played]
15 MS. WEST: We're at 52 minutes and 45 seconds.
16 Q. Do you recognise this room?
17 A. Yes, I do.
18 Q. And what is it?
19 A. This is a room where General Mladic in Crna Rijeka was staying,
20 as far as I know, and we were in that room, always invited having a
21 coffee, whatever.
22 Q. And the person we see on the screen right now, who is that, the
23 one who is speaking?
24 A. Yes, this is Ranko Rakanovic, president of
25 Humanitarian Organisation Republika Srpska that we have started organised
Page 25037
1 and registered in 1992 and we got our registration 1993.
2 Q. So he was one of your colleagues; right?
3 A. Yes, he was.
4 Q. And the person to his right who is in the middle of the screen,
5 who is that?
6 A. That's his brother, Ilija Rakanovic.
7 Q. And the person to Ilija's right on left-hand side of the screen,
8 who is that?
9 A. It's moved away from my screen. I can't recognise.
10 Q. Okay. I'll ask you when we see it again.
11 [Video-clip played]
12 MS. WEST: Now we're at 52 minutes and 52 seconds.
13 Q. Who are these two gentlemen on the screen?
14 A. General Mladic and General Milan Gvero.
15 Q. Thank you.
16 [Video-clip played]
17 MS. WEST: We stopped at 54 minutes and 5 seconds.
18 Q. And here General Mladic said he hopes the area of Zepa will be
19 taken care of in the same way as the area of Srebrenica. At this time,
20 at this moment, what did you understand had happened in Srebrenica?
21 A. From this speech, I presumed that Srebrenica was sort of
22 conquered, take over, two or three days before our arrival.
23 Q. And prior to the speech, had you heard anything else about
24 Srebrenica?
25 A. Just on travelling from Belgrade to Han Pijesak, Crna Rijeka. We
Page 25038
1 had to turn to Bratunac, go little bit around half an hour away, rough
2 road was, so that we avoid our intelligence. Petar Salapura was driving
3 with us says we better go the other route. Someone could come out from
4 the forest. It's safer for us to go back around by the Bratunac.
5 Q. And what was the normal route that you typically took from
6 Belgrade to Han Pijesak?
7 A. Normal route was that sort of you could go the better road and
8 much straighter, much quicker, but then that incident we took a bit a
9 round route to be safer.
10 Q. And, if you remember, you said you can go the better road much
11 straighter, much quicker. Do you know where that went?
12 A. Well, not exactly. I wasn't driving, but we went to the sort
13 of -- not to Bratunac but to the -- to the farther straighter. I can't
14 recall the --
15 Q. That's fine.
16 A. -- cities.
17 Q. That's fine. Thank you. We'll continue playing.
18 [Video-clip played]
19 MS. WEST: We're at 55 minutes and 42 seconds.
20 Q. And General Mladic is saying thank you for helping us solve our
21 problems regarding Srebrenica and congratulate you, both you and us, on
22 the occasion of the liberation of the Serb Srebrenica. At that meeting
23 what problems did you understand they had in Srebrenica?
24 A. I really didn't understand any of the Srebrenica. He was here
25 more saying that he thank us for bringing that scanner tube when he
Page 25039
1 approached me. I didn't understand anything about Srebrenica here.
2 Q. Okay. Mr. Lesic, yesterday you spoke about the type of media you
3 watched when you were in Canada. In the days leading up to this trip in
4 July 1995, were you watching Serbian television from the region for your
5 news?
6 A. I was watching on a satellite dish that was showing from Belgrade
7 or Bijeljina or from somewhere what was going on over there.
8 Q. Okay. We'll continue.
9 [Video-clip played]
10 MS. WEST: We're at 57 minutes and 10 seconds.
11 Q. And here General Mladic says half the world attacked us through
12 the Croats and the Muslims because almost half of the world has been
13 helping them. What did you understand half the world to indicate? What
14 did you mean that half the world was helping them?
15 A. What he was saying he was sort of happy that we were together and
16 we brought humanitarian help. We are concerned what's happening in those
17 area, and six of us arrived. He was saying half of world, half of world,
18 in other words -- well, rest of the Western world was against them.
19 That's what they felt at that time.
20 Q. All right. And we're not going to continue to play this video,
21 but it goes on for a bit, and this is on the 17th. On the night of the
22 17th, where did you sleep?
23 A. I would say I -- as I can remember, I slept there at the
24 Crna Rijeka in a bunker as usual when I don't travel same day back to
25 Belgrade.
Page 25040
1 Q. All right. So at Crna Rijeka they had at least a facility where
2 guests could sleep, where you could sleep?
3 A. Yes, they did. They had quite a few beds and underground there.
4 It was quite nice apartment.
5 Q. Okay. And the following morning on the 18th, did you have
6 breakfast at Crna Rijeka?
7 A. We had something, coffee or something. I don't recall. It was
8 long time ago.
9 Q. And then where did you go?
10 A. We went farther. As far as I know today, we went to see
11 President Karadzic and his -- and his headquarters.
12 Q. All right. And was that in Pale?
13 A. Yes, it was. That was only short 15, 20 minutes' drive.
14 Q. Okay. I'm going to show you some photos, Mr. Lesic. And when
15 you gave the interview in August of 2009 to the OTP, you brought not only
16 videos with you but photos; correct?
17 A. Yes.
18 Q. And you brought many. I think you brought over 30 photos with
19 you, and I'm just going to show you some to at least get a sense of how
20 many trips you took. So we're only going to look at some of them.
21 A. Yes.
22 MS. WEST: If we can have 65 ter 21939A. And the first photo
23 we're going to look at ends in the numbers 7196.
24 Q. Sir, do you recognise this photo?
25 A. Yes, I do.
Page 25041
1 Q. Was this your first trip?
2 A. This one, yes. It was my first trip where we are five of us.
3 Q. All right. If you can go from left to right, tell us who these
4 people are?
5 A. General Mladic, President Karadzic, myself, and
6 General Milan Gvero, and Ned Krajisnik.
7 MS. WEST: I tender this photo, please.
8 JUDGE KWON: Yes.
9 THE REGISTRAR: Exhibit P4443, Your Honours.
10 MS. WEST: We can go same 65 ter number photo ending in 7204.
11 Q. Do you remember where this photo was taken?
12 A. At President Karadzic's reception or his office or somewhere
13 there.
14 Q. Let me ask you this: In early 1993, did you have an occasion to
15 meet Mr. Karadzic in New York?
16 A. Yes, I did meet him twice.
17 Q. Okay. And why did you do that?
18 A. Well, we came from Canada, four of us, to give him support. They
19 had a hell of a time with UN negotiations and all that. They were there
20 two or three days, and we went there to spend with them two days or so.
21 We drove over, four of us, sort of talk to them, help them. We felt -- I
22 was self-employed and we felt we had enough time, Ned Krajisnik and
23 myself and others, to go there and give them support.
24 Q. And can you identify the people in this photo, please?
25 A. Ned Krajisnik, Dr. Karadzic, and myself.
Page 25042
1 Q. All right.
2 MS. WEST: I'll tender this one, please.
3 JUDGE KWON: Yes.
4 [Trial Chamber and Registrar confer]
5 JUDGE KWON: This is a part of a compilation of nine photos. Are
6 you tendering each photo separately?
7 MS. WEST: If it's easier, they can be all one.
8 JUDGE KWON: If there's no objection, we'll admit it in one.
9 Mr. Robinson.
10 MR. ROBINSON: Well, in principle, we would prefer that only the
11 photos that are discussed with the witness be admitted. So if she
12 intends on going through each one of them, then you can admit them all as
13 one, but if you are going to select just a few, we would ask that those
14 be admitted.
15 MS. WEST: And if --
16 JUDGE KWON: Show us the photos you want to tender and then we
17 will admit them all.
18 MS. WEST: Thank you. Thank you. Then we'll now go to 7212.
19 Q. This is dated October of 1993. Do you recognise this place?
20 A. Yes, I do.
21 Q. Where is this?
22 A. This is at Crna Rijeka, Han Pijesak.
23 Q. All right. And if we can start from the left-hand side and go
24 down the table, can you tell us who's there?
25 A. Myself, Milan Gvero, Ned Krajisnik, General Milosevic,
Page 25043
1 Marko Sandal from Canada, General Mladic, and Mrs. Mladic.
2 Q. If we can go to 7216. This is in 1994. What room is this?
3 A. This is in Pale at -- either at Momcilo Krajisnik office or
4 President Karadzic office. I'm not sure.
5 Q. Okay. But the map on the wall --
6 A. Yes. Map on the wall is President Karadzic, I believe.
7 Q. All right --
8 A. Office.
9 Q. And on other occasions that you were in that office, had you seen
10 that map before?
11 A. Yes. Yes, I have, yes.
12 Q. All right. If we can go around the table and tell us who's
13 there.
14 A. Mile Jelicic, he came from Belgrade with me, my brother-in-law,
15 and that was a lady - I don't know her name - she's some kind of a worker
16 there, secretary of Mr. Karadzic, myself, Momcilo Krajisnik, and
17 President Karadzic.
18 Q. If we could have 7220, please. This is December 1994. Do you
19 recognise this room?
20 A. Yes, I do.
21 Q. What room is it?
22 A. This is at Pale as well, at the President Karadzic headquarters.
23 Q. And can you start from the left and go around the room and give
24 us the IDs.
25 A. Deyan Zaroban from Canada, Toronto, Momcilo Krajisnik,
Page 25044
1 President Karadzic, myself, and soldier down there I don't remember his
2 name --
3 Q. Okay?
4 A. -- or the two people turned back to me I don't remember them.
5 Q. Well, fair enough. If we can go to 7238, please. And this is
6 18 July 1995. Where was this taken?
7 A. This was taken in Crna Rijeka outside at the picnic table.
8 Q. And go from the left to right. Can you give us the
9 identifications?
10 A. Branko Zaroban from Canada, Toronto, General Mladic and
11 General Momcilo Perisic and Ned Krajisnik.
12 Q. May we have 7242. This is also July 18th, 1995. Where was this
13 taken?
14 A. This was taken same place, Crna Rijeka, Han Pijesak.
15 Q. And go from left to right.
16 A. General Milan Gvero, Ilija Rakanovic from Canada, Ned Krajisnik
17 from Canada, and Ksenija Zaroban.
18 Q. Can you tell us what that house is in the background. What is
19 that?
20 A. On the back of the -- their back -- Ned Krajisnik back this is
21 entrance going upstairs to the office and reception.
22 Q. May we have 7250, please. This is from January 1996. Do you
23 recognise this room?
24 A. I would -- yes. This is in Crna Rijeka, Han Pijesak, up on the
25 first floor up going to steps, myself, General Mladic, Petar Salapura
Page 25045
1 intelligence, and Ned Krajisnik.
2 Q. All right a number of times you have seen Han Pijesak and
3 Crna Rijeka together. Can you tell us what the difference is between the
4 two places?
5 A. Well, Han Pijesak is called all region. There is a region,
6 Han Pijesak, and Crna Rijeka is a little bit farther that is in the
7 mountains under the mountain build.
8 Q. All right. So when we saw photos where there are woods, is that
9 Crna Rijeka?
10 A. Yes, yes.
11 Q. And is that the place where you stayed overnight?
12 A. Yes, that's the place.
13 Q. And the building we saw in the background is that the place where
14 General Mladic would stay overnight?
15 A. At that time, while I was there, he did, yes, as far as I know.
16 MS. WEST: Your Honour, I would move to -- I would tender these
17 photos as one.
18 JUDGE KWON: Yes, that will be all included in Exhibit P4443.
19 Added to --
20 [Trial Chamber and Registrar confer]
21 JUDGE KWON: So only those photos shown will be admitted, added
22 to the exhibit. Yes.
23 MS. WEST: Okay. Thank you. Your Honour, at this point I'd like
24 to move to an area upon -- I would like the witness to speak and it's an
25 area that takes place in 2001 and 2009, and I believe the subject matter
Page 25046
1 is relevant to the indictment. I know the Defence is of a contrary
2 position. And I know it may be an issue. I looked at your Ruling
3 yesterday, and you ordered the Prosecution to focus on parts of the
4 evidence were relevant to the indictment. It is my position they are
5 relevant to the indictment, but if I may be heard I'd like to be.
6 MR. ROBINSON: Yes, Mr. President, we would also like to be heard
7 and outside the presence of the witness.
8 JUDGE KWON: Very well. So, Mr. Lesic, if you could excuse
9 yourself for a moment.
10 THE WITNESS: Yes, sir.
11 [The witness stands down]
12 JUDGE KWON: Yes, Ms. West.
13 MS. WEST: Thank you, Mr. President. In 2001, several years
14 after these events that we've been talking about, the witness met with
15 General Mladic and Mr. Karadzic in Belgrade and in Bosnia. There is a
16 photo reflecting a dinner that the witness had with General Mladic and
17 then the witness would give evidence that following that he went to the
18 area where General Mladic was hiding, and then the following day he went
19 to an area where Mr. Karadzic was hiding. As you recall this is a period
20 of time where the two -- their whereabouts were unknown.
21 I believe that in addition to this, the witness will also tell us
22 about early 2009 when he was home in Canada and he was at a church event
23 and Ned Krajisnik, the person who's colleague involved in this
24 organisation, came to him with Mr. Karadzic's niece, and Mr. Karadzic's
25 niece asked whether Mr. Lesic would organise a fundraising banquet at the
Page 25047
1 church to raise money for Mr. Karadzic. I believe that these events in
2 2001 and 2009 are relevant to the indictment because they go to the
3 nature of the relationship between Mr. Lesic and the leadership of the
4 Republika Srpska and that's important because if we were -- if we
5 understand that in 2001 and 2009 General Mladic and Karadzic reach out to
6 this witness at a very risky time, that they reach out to this witness,
7 it shows the strength of their relationship thereby giving weight to the
8 impressions and observations that this witness has testified about that
9 he made in 1992 and 1995. And my argument is that if Mr. -- had
10 Mr. Karadzic and Mr. Mladic not reached out to Mr. Lesic in those
11 following years, you might be left with some notion that the relationship
12 they had during 1992, 1995, was not so substantial, but because they
13 reached out at a time that was very risky for them, I would suggest that
14 it's relevant to show you that the relationship they had was a very
15 strong one, and that's why I think that these events are important.
16 JUDGE KWON: Ms. West, could you give me the examples of
17 impressions and observations that Mr. Lesic has testified about --
18 MS. WEST: Yes.
19 JUDGE KWON: -- what he made in 1992 and 1995.
20 MS. WEST: For example, we spoke -- much of the time we have been
21 speaking about the international community and the media and the
22 propaganda that was going on. And Mr. Lesic testified that in June of
23 1993 at this Trnovo dinner there was this speech from Mr. Karadzic.
24 Several times Mr. Lesic has talked about what Mr. Karadzic and
25 General Mladic's view was of the international community getting involved
Page 25048
1 with their war and what their impressions were about the media and the
2 propaganda and the bias that they believed was going on in international
3 media. Now, this was an opinion that was shared by this witness as well,
4 but several times he has indicated to you that they also had this
5 impression.
6 JUDGE KWON: Very well. Yes, Mr. Robinson.
7 THE ACCUSED: [Interpretation] There's just something I'd like to
8 say and then I'll hand over to Mr. Robinson. Money wasn't requested for
9 Radovan Karadzic but for the services that isn't being paid for by the
10 court, various services in Belgrade. It wasn't for Karadzic and that is
11 not what the witness said. Mr. Robinson could now take the floor.
12 JUDGE KWON: Very well. Yes, Mr. Robinson.
13 MR. ROBINSON: Yes, Mr. President. This is a very thin reed upon
14 which the Prosecution wants to bring in inadmissible evidence. The
15 relationship between Dr. Karadzic and Mr. Lesic is absolutely irrelevant
16 to anything that he's testified about. We're still wondering really why
17 he's here at Dr. Karadzic's trial. I can see why he would maybe want to
18 come for -- or wanted -- be wanted for General Mladic's trial but he
19 hasn't offered any evidence about Dr. Karadzic other than what was shown
20 on the video-tape, and we can all see what Dr. Karadzic said. So any
21 relationship that Mr. Lesic had with Dr. Karadzic is completely
22 irrelevant. And we're not contending that he's untruthful in bringing
23 his video-tapes and showing us what was said at the time. So I don't
24 think that you can bootstrap otherwise inadmissible evidence by trying to
25 establish a relationship that is of no moment to the witness's evidence
Page 25049
1 or to the Trial Chamber's deliberations.
2 JUDGE KWON: Would you like to reply, Ms. West?
3 MS. WEST: No.
4 [Trial Chamber confers]
5 JUDGE KWON: Given the time, the Chamber will take a break now
6 for half an hour. We'll rise.
7 --- Recess taken at 10.11 a.m.
8 --- On resuming at 10.44 a.m.
9 JUDGE KWON: Ms. West, the Chamber is not satisfied that the
10 portions you referred to are relevant. The objection is sustained.
11 Shall we bring in the witness.
12 MS. WEST: Thank you, Mr. President, and I have no further
13 questions.
14 MR. ROBINSON: Mr. President, I would like to commend Ms. West
15 for the way that she brought that issue up in advance to the Chamber so
16 that we could deal with it before -- outside the presence of the witness.
17 JUDGE KWON: The Chamber appreciates it as well as. Thank you.
18 MR. ROBINSON: Mr. President, while we're waiting, yesterday the
19 Prosecution filed a motion concerning our access to materials in a
20 completed case involving Vasiljevic, and I wanted to let you know that we
21 won't be responding to that motion and we don't oppose the relief that
22 they seek.
23 JUDGE KWON: Thank you, Mr. Robinson.
24 [The witness takes the stand]
25 JUDGE KWON: My apologies for your inconvenience, Mr. Lesic.
Page 25050
1 THE WITNESS: It's okay, sir.
2 JUDGE KWON: Ms. West, could you repeat your last words.
3 MS. WEST: Thank you, Mr. President.
4 Thank you, Mr. Lesic, I have no further questions.
5 THE WITNESS: Thank you.
6 JUDGE KWON: Yes, Mr. Karadzic.
7 THE ACCUSED: [Interpretation] Thank you. Good morning,
8 Your Honours.
9 Cross-examination by Mr. Karadzic:
10 Q. [Interpretation] Good morning, Mr. Lesic. Good morning to
11 everyone in the courtroom. I'd like to thank you for meeting with us,
12 for meeting with me and the Defence. I hope this will be of assistance
13 to us. I hope it will assist me to put brief questions to you and
14 receive brief answers so that we can finish within the time allocated.
15 Thank you again.
16 Mr. Lesic, you left Yugoslavia because you objected to the
17 previous regime that imposed restrictions on you in economical and
18 political terms. Isn't that the case?
19 A. Yes. Yes, that was the case. Economical, better life somewhere
20 else.
21 Q. Thank you. Given that you operate as a Serbian diaspora society
22 in Canada, is it true that in a democratic Serbia you recognised us in
23 1995 as being a new democratic force that would be fighting on behalf of
24 democracy and that would be fighting against a one-party system. Was
25 that your understanding of the situation, and did you support the
Page 25051
1 political efforts we were making?
2 A. Yes, Dr. Karadzic. We supported. As I recall, we give you and
3 Mr. Krajisnik and Biljana Plavsic membership as well from our
4 Humanitarian Organisation Republika Srpska, and at that time in Pale I
5 said, well, it is a good news. We have charted that Canada recognise
6 Serbian Republic after all.
7 Q. Thank you. I want to dwell on the previous war period. We had
8 the support of the diaspora from the democratic world. Do you remember
9 that at that time we strove to preserve Yugoslavia -- or, rather, we
10 strove to have Bosnia remain within Yugoslavia, whatever the extent of
11 that state?
12 A. Yes. In diaspora Serbian community in Toronto, Canada, all
13 different cities, we supported all your work and Serbian Republic and to
14 stay in Republika Srpska. We supported the effort at that time what was
15 happening, what was going on. We were all enthusiastic and with you
16 that's how we put ourselves. We had 420 members
17 Humanitarian Organisation Republika Srpska to help your cause and to
18 bring humanitarian help because we supported you at that time.
19 Q. Thank you. I would still like to deal with the pre-war period.
20 Prior to the war breaking out, did you notice that we were in tolerant in
21 relation to the Muslims, or would you agree that we wanted the Muslims to
22 remain together with us within Yugoslavia?
23 A. Yes. I agree with you, sir, that we want to go together with
24 Muslims and with Yugoslavia. We did not want a war with them. That was
25 discussion, and that was our opinion as well before the war breakdown,
Page 25052
1 but political field didn't let us do that direct -- that way. We were
2 all aware that was an ideal thing to do.
3 Q. Thank you. Among the leadership of the Bosnian Serbs, did you
4 notice anyone having shown their tendencies of any kind in relation to
5 the Muslims or the Croats, or would you agree that we were an openly
6 democratic community?
7 A. Yes, sir. During my visit over there and discussing with
8 intelligence Petar Salapura, he was telling me during a car ride from
9 Belgrade to Pale that we had some Croats and Muslim forces, individuals,
10 going on our side and being with us during that time. I was surprised,
11 but that's what they tell me, that we want -- that that's what was going
12 on there.
13 Q. Thank you. On page 10, a question was put about Trnovo today,
14 and something with relation in relation to Trnovo was shown. I praised
15 the army for having acted expeditiously. Do you remember something in
16 relation to the declaration of the protected zones of Zepa and
17 Srebrenica? Prior to that declaration there was a large-scale Muslim
18 offensive that was launched against our territory, and at the time no one
19 criticised them for doing this, and what I have in mind above all is the
20 media that you could follow in Canada.
21 A. Yes. I recall that very well, that Trnovo was quite difficult,
22 that the Muslims was Muslim area one time, and another time they did kick
23 Serbs out that I recall, and I was talking to some people in the media as
24 well, and then as you were praising General Mladic how well job was done,
25 quick and with no any consideration from the West, nobody blinked an eye,
Page 25053
1 and so on. That was not -- that was my understanding at that time, but I
2 was occupied. I was new there. I really didn't know half of it, what
3 was going on. I stay here a night, a day here, a day there. I wasn't
4 very much involved in all that discussion, just what I know, that's what
5 I'm saying.
6 Q. Thank you. With regard to Cerska, Konjevic Polje, and so on and
7 so forth, do you remember that before our counter-offensive, there was a
8 Muslim offensive from Cerska, Konjevic Polje, and Srebrenica? And do you
9 agree that the international media didn't attack them for having launched
10 that offensive. You could hear about that only from our own local media,
11 not from the international media?
12 A. Yes, Dr. Karadzic, I would agree with you. That's what I hear
13 from it that no one criticising when they were attacking and when they
14 were sort of on the battle-field against the Serbs. I've been watching
15 that Serbian media and listening to that. I would agree with you all the
16 way.
17 Q. Thank you. Do you remember that the international media spread
18 propaganda according to which a terrible crime had been committed in
19 Cerska and this continued until General Morillon entered Cerska and
20 showed that this was not the case, denied that that had happened?
21 A. Yes, I recall that as well through discussion with the army
22 intelligence that that happened the way you said, sir.
23 Q. Thank you. Today we had a look at a video excerpt. The date was
24 the 16th, and it was at the VMA in Belgrade. Do you remember what time
25 it was when you went to visit Mladic on that occasion?
Page 25054
1 A. The time, sir, I'm not aware of the time. I remember that we
2 came from Sofia first day in VMA, and I don't recall the time unless
3 video or picture shows otherwise, and from the Belgrade when we -- the
4 scanner arrived, scanner too, following morning we went to Pale. As
5 well, I don't remember exact time. Was in afternoon, as I believe, that
6 we were there.
7 Q. Thank you. Do you remember whether one day before the 16th you
8 spoke to General Mladic? Did you speak to him a day earlier, on the
9 phone perhaps? Can you confirm, in fact, where General Mladic was one
10 day earlier?
11 A. I don't remember where General Mladic was one day earlier. I
12 remember seeing him as -- in Belgrade in hospital, and following day I
13 saw him on Han Pijesak, Crna Rijeka. That's all I remember where he was.
14 Q. Thank you. Do you remember whether on the 16th or the 17th there
15 was a conversation of any kind with General Mladic and his entourage, a
16 conversation that concerned people who may have been killed? And when I
17 mention these people who may have been killed, it's in relation to
18 Srebrenica.
19 A. I don't remember any discussion over the people being sort of
20 killed or anything like that. No one would tell us anything what was
21 this. I just know that Srebrenica was sort of taken over two or three
22 days prior my arrival there, that's all. They did not discuss with us
23 about those things, sir.
24 Q. Thank you. Did you notice that they were making some kind of
25 allusions when they talked amongst themselves? Was there anything in the
Page 25055
1 air, if you will, regarding any kind of unlawful killing?
2 A. As I -- as I was talking to the group of people and all that and
3 they were -- everybody had their own discussion, no one told me about any
4 group of killing or separate killing, nothing that I was aware of. I
5 recall seeing many, many buses going and people -- children and women
6 having put on the buses and drove away by seeing from international
7 media, but I don't remember any other discussion that people was telling
8 me.
9 Q. Thank you. I'd like to ask you now whether you followed in the
10 media what had been happening before that. For example, did you hear of
11 the slaughter in Dobrovoljacka Street on the 3rd of May, 1992? Did you
12 hear about that through our media or international media?
13 A. Yes. That meaning in market square in Sarajevo? Was that the
14 question?
15 Q. That could be the question too. In 1994, in February, there was
16 Markale I, the first Markale case. What did you learn about that, and
17 what was your understanding of it?
18 A. Well, it was awful thing to learn that this took place, but then
19 later on I hear from Canadian or Western media, French, I would say,
20 Mr. MacKenzie, General MacKenzie was sort of saying that did not happen
21 as they claimed it happened, so General MacKenzie sort of was always down
22 the street and talking the way things went, and he got replaced as a
23 general, and then General Morillon later on took his position, and also
24 he was sort of fair general. He was co-operating with General Mladic,
25 what I was told, and he was also replaced later on.
Page 25056
1 I don't believe that Serbs did that market square in Sarajevo.
2 Maybe I'm wrong, but I don't believe they did through my discussion and
3 through the after founding, that they done that to themselves so that
4 they have a Western media much more against Serbs.
5 Q. Thank you. So even in the Western media was this idea being
6 bandied about, namely that this crime had been staged, rigged, in order
7 to accused the Serbs?
8 A. Yes, sir. That was possible to be rigged because Serbia had no
9 media on their side. Was everything going against them at that time.
10 And I recall going up and about the Sarajevo meeting general in charge
11 that they were sort of shooting in the Sarajevo, and I was asking them,
12 Is that true what's happening? No, no, no. It is not true. It is just
13 the media. I don't know any more than what I was told over there.
14 Q. Thank you. As regards aid, you were indeed very helpful, you and
15 all Canadian Serbs. Do you agree that the aid that you brought, the
16 monetary part of that aid, was always handed over to officials in the
17 presence of several individuals and that certificates were issued to that
18 effect?
19 A. Yes. We were organised. We had, as I said earlier, so many
20 members in Humanitarian Organisation Republika Srpska, and we carried a
21 letter from committee how to disburse the funds and who to help, and then
22 we had our discretion over there asking Biljana Plavsic and asking other
23 officials where it's most needed, and we try to give to the places that's
24 most needed at their suggestion. We were strangers. We were out there.
25 We didn't know where what. We went to hospitals. We went here and
Page 25057
1 there. We always got a receipt. We always got sort of kind of a gramata
2 [phoen] certificate that we have. Yes, we have give funds where we
3 supposed to and that was always spended or used properly.
4 Q. Thank you. So you gave it to the final beneficiaries, the end
5 beneficiaries; right?
6 A. Yes. We give to the Red Cross in one case. In other cases, we
7 give to the parliament. In other cases, we give to the treasurer of army
8 for soldiers to have their meals or whatever, and one time we have given
9 cigarettes. That what they most needed. And Biljana Plavsic suggested
10 to me they should get some cigarettes, and we brought -- we found it
11 somewhere, and we give them what we could. And we really put ourselves
12 in -- some kind of a tiring spot and flying with helicopter but just to
13 help needy. That was our decision to do, and that's what we did at that
14 time.
15 Q. Thank you. Is it correct that you did not give any kind of
16 financial aid to individuals from the leadership, the civilian
17 leadership, or the military leadership, that would be used for their own
18 purposes? Rather, you gave this aid to people who needed it.
19 A. Yes. What we did we give first time in 1992 in parliament
20 session. My video camera taped it so I could show back home in Canada
21 how did we give the help and how did we disburse the funds. Other times
22 we give for the media 15.000, I give, and we sort of -- we give -- people
23 were waiting in a bake shop. I wish that what that footage would show
24 where there was people waiting for bread, and we were -- I was giving
25 them 10 and 20 Deutschmarks at that time, and I almost was run over, but
Page 25058
1 that was our goal, and that was our aim, to give where it was possible,
2 even give people on the street they are needy, like that incidents in the
3 bakery.
4 Other time, we always give in to -- we delivered a hundred tonne
5 of floor, and 20 tonnes we give to different cities, Banja Luka, Doboj,
6 Prijedor, and so on, as the footage will show wherever there is the
7 movies for those things as well. And we were quite happy when I arrived
8 back to Canada that we did well job done and -- at that time.
9 Q. Thank you. Since you saw how the soldiers were living and how
10 they were receiving food and how people in Republika Srpska lived, do you
11 agree that this was grave poverty, also that the people in the army were
12 barely surviving with a maximum of one or two meals per day?
13 A. Yes. I recall General Mladic would take me, I would say, hundred
14 or 200 metres away from Crna Rijeka, showing me a farm and some little
15 farmhouses where they had the pigs and chickens and growing and being
16 self-sufficient, and sort of telling me how they are doing themselves to
17 create food and to be not waiting till comes from outside or from
18 anywhere else. When I saw all that, every time we arrived from Belgrade
19 we brought some in the cars as much as we could, sort of bringing some
20 kind of food, smoked meat and all other things just to help everybody in
21 the needs as much as we could.
22 I recall one time I ask -- I saw about 20 or 30 soldier around
23 there watching soccer, and I ask General Mladic could I give them a
24 couple of bucks. He says, No. I would not advise you to do that. I
25 said, Why? He says, Well, I don't want just my army receive some kind of
Page 25059
1 a gift and other doesn't. I replied to General Mladic. I said, Who is
2 close to the fire, he gets a heat. I can't -- after all, you're not boss
3 of my money. I brought it here and I will disturb [sic] as I see fit and
4 I give them a 10 or 20 marks to 20 of them. I felt good about it. So
5 ...
6 Q. Thank you. We're not talking about the Main Staff now. Now
7 we're talking about other places in the field, the Krajina, for instance,
8 various towns. Did you see what kind of life our people had there and
9 how impoverished they were?
10 A. Yes, I saw terrible things towards my area. Personally I am from
11 the Krajina and Bihac over there, and that was sort of end of the line,
12 and from Banja Luka they didn't get much help over there, so as I was --
13 always when I had a chance to go close to Bihac, we delivered some help
14 to them as well. It was from my village few, five or six. They were
15 there, and I saw that they were not -- they were pretty poorly living,
16 soldiers and all that. They had no right uniform on them. They were
17 cold and all that. I made a call to General Mladic, and I said, Look,
18 call Banja Luka and send 20 uniforms over here. These people are
19 completely -- they're cold. They don't have much to wear or anything.
20 So he says, What size? I said, Give me the guy. So I told him size
21 so-and-so and all different sizes. And it was a tough for them, yes.
22 Q. Thank you. Do you agree that in such conditions it was also
23 rather difficult to feed large numbers of prisoners of war properly? We
24 could feed them only the way we fed our own army.
25 A. Yes. I never saw any prisoners, but I was told and I would
Page 25060
1 presume, yes, if you don't have food enough for yourself, you cannot give
2 it away as much either. So it's just going from day to day for survival.
3 I am aware of all that. I recall when I was in Austria 1958, young kid,
4 and we didn't have a good time either waiting to escape to -- waiting to
5 be emigrated to different countries, and that's what I put myself in a
6 position this time. I wasn't in army, so I said now I have a couple of
7 dollars in the pocket, and it's [indiscernible], and I want to help my
8 people as much as I can. Thank you God Canada did well for me and I did
9 well for Canada. So I was in a position with a group of others to give
10 that kind of donation and that kind of humanitarian work.
11 Just to explain, wasn't easy to register humanitarian
12 organisation. At that time we were turned down first time to change our
13 name, and I was persist. I says, No. I would like to be
14 Humanitarian Organisation Republika Srpska, and waited another three to
15 six weeks. We got approval from the Canadian government to receive the
16 charter, and when someone gives like a $10.000 donation, they paying high
17 taxes, so they can claim it, 30 or 40 per cent, depends on each
18 individual's salaries.
19 So when I got visited by Canadian intelligence every time I come
20 back, they say, Well, you took money over there. You did this. You did
21 that. I said, Yes, I did. My taxes are paid, and I spended the money,
22 was clear money, the way I saw fit, and we collected so-and-so on.
23 Wasn't any issue.
24 Q. Thank you. You mentioned the period you, yourself, spend as a
25 refugee. Did you see for yourself that in Republika Srpska, everywhere,
Page 25061
1 the Krajina included, at the time there were a large number of Serbs who
2 had fled not only from Croatia but also from Central Bosnia? Did you
3 come across them?
4 A. In Canada, yes, I came across with lots of immigrants, being
5 52 years in Canada, 1992, 1994, up to 2009. I personally employed 7.500
6 people to work in an auto motor industry parts for the cars, to help them
7 out to get settled. I employ -- I got them the jobs there, and they're
8 still working. Up to now is 8.500 people working in different companies.
9 They all settled. They all good tradesmen and machinists and all that.
10 The owner of the company is pretty happy with them.
11 Q. Thank you. I wanted to ask you about when you travelled through
12 Republika Srpska. Did you come across refugees there, people who had
13 fled to Republika Srpska from the Muslim and Croat parts of Bosnia?
14 A. Yes. When I went to visit hospitals and bishop from Chicago,
15 Irinej. They were at Kasindol hospital and there were -- some people
16 fled and I was -- pointed out I wasn't close with them, but they say
17 those people fled and we got to help them and all that, and I've been
18 told yes, you're right.
19 Q. And in the Krajina, Banja Luka, other municipalities, did you
20 notice a considerable number of refugees there? Did you help them as
21 well?
22 A. In Banja Luka, they are just outskirts of Banja Luka, Derventa or
23 somewhere, as I recall. We saw quite a bit from Sanski Most and from
24 other there were 80 people in one room, and I saw quite a -- quite a
25 refugees there that they had no place to go. They couldn't go back and
Page 25062
1 all that. It was quite disaster. That's when I -- when we brought them
2 the help. It was quite difficult for them. Yes, I saw all that, and I
3 believe I even took some movies from it.
4 Q. Thank you. Can we agree that you were quite happy with the
5 distribution of aid that the Canadian Serbs sent through you and that
6 there was no abuse of this aid?
7 A. Yes. We were quite -- quite -- quite agree with you, yes. The
8 aids was never abused. We give to the proper places. We got
9 documentation for it, and I even took the pictures and the movies when we
10 brought the aids to present it back to Canada committee that definitely
11 we give to the right places so -- as well we want to cover ourselves,
12 myself and Ned, that we didn't take to our family or whatever. We give
13 to the place that we supposed to.
14 Q. Thank you. We saw a transcript today -- or, rather, an
15 intercept -- or, rather, a video-clip. When General Mladic drove you
16 towards Zepa. This is what I'd like to ask you now: Do you know that on
17 that same road, the Muslim side, although it had been agreed that a
18 convoy should be allowed through, they killed a large number of soldiers
19 on the 4th of June, 1992? Did you hear of that case when we lost these
20 young recruits for no good reason whatsoever? This was an act of deceit
21 altogether.
22 A. Yes. I remember that General Mladic was telling me as well when
23 one Serbian young guy was put on a stick and burned at that area over
24 there, and when he was showing me Muslim house and another Muslim house
25 and so on, I recall. I was only told what was happening there prior to
Page 25063
1 General Mladic driving me around. Yes, that's correct. All I know what
2 I been told, yes, sir.
3 Q. Thank you. Did you take this seriously, his joke when he said to
4 you that he could give you that forest as a present, or was this sort of
5 playful bragging on his part?
6 A. I understood what he was saying. This was sort of a joke between
7 him and myself. He says, You are well-off in Canada. Come here and you
8 can get all this after the war and all that. And I said, Thank you, sir.
9 No, no, just keep up with work. And that was sort of really just a
10 kidding discussion, was nothing serious about that.
11 Q. Thank you. And also, knowing what had happened in June 1992 with
12 that ambush there, as for what he said to you about the Turks, did you
13 also understand that as a kind of bragging in order to correct the
14 picture a bit with regard to those deaths of ours? Quite simply, the
15 atmosphere in the car, was it one that was conducive to bragging,
16 exaggeration, and so on?
17 A. I remember my staying over there that was some kind of an ambush
18 from the Muslim side, that they broke the lines, and they came over to
19 the Serbian Republic side where were the lines, and they removed us from
20 one hotel to the other hotel overnight for our safety. It was quite
21 dangerous at that time, so -- I was quite myself in shock, Why did I come
22 here? And I recall that. That's all I know. I wasn't told all other
23 things what was going on, just that.
24 Q. Thank you. During the previous years and especially in
25 July 1995, when you came to Republika Srpska, did that involve danger of
Page 25064
1 ambushes, and were measures taken for you to be protected?
2 A. Every time I came over myself and with Ned Krajisnik or with
3 others we were always given sort of security. We don't know the roads.
4 We don't know the travel. And that was from 2000 -- 1992 to 2000 --
5 1995. Was always same sort of security from intelligence, Pete Salapura,
6 but it was much less danger in 1995, as I recall, than 1992 and 1993,
7 yes.
8 Q. Thank you. Since you've mentioned a small road, may I jog your
9 memory? Was it the Zvornik-Crni Vrh-Caparde-Sehovici road and Vlasenica
10 as well? In this way, one would avoid travelling between Srebrenica and
11 Zvornik. Was that that road that you took in order to get to
12 Han Pijesak, although it was a road that was much worse?
13 A. As far as I recall, we took farther road from Srebrenica and I
14 ask why I was told we are going to avoid? We didn't go -- we went to the
15 Zvornik or closer, Bratunac, to the Bratunac to avoid danger. That's all
16 I can remember. It's been a long time.
17 Q. Thank you. Tell us, please, you as Serbs from Canada, a country
18 in which there is a culture of democracy, to the best of your knowledge
19 did the Bosnian Serbs do anything for which you would feel ashamed?
20 A. The media was saying, and from beginning, how Serbs do this, do
21 that, rapes and all other things, killings and everything, and I just
22 couldn't believe it, so I sort of tried to find the true information and
23 truth about it, so I went over ten or some times to see what was going
24 on, and I am satisfied that those things did not happen as they
25 proclaimed, that Serbs were bad as they were painted -- they were painted
Page 25065
1 and accused of. It was difficult those years for everybody, including
2 you, sir, over there with so many meetings and all. I recall, I can't
3 even see you. Out of ten times, I saw you maybe three or five times.
4 You were always somewhere in a meeting or whatever. But that was the job
5 you people had to do, so ...
6 Q. Thank you. You confirmed today that you saw me every other time,
7 that is to say you saw me considerably less than General Mladic. Is it
8 correct that you were turned towards the military and helping the
9 military? I'm not saying you personally. I'm speaking of the
10 organisation as a whole.
11 A. Well, our organisation, Humanitarian Organisation Republika
12 Srpska, dictate to give the help where it's needed, and as we were going
13 forward and backward and come back with the movies, I saw you, as I will
14 say again, out of ten times maybe four or five times, not all the time,
15 but I saw Krajisnik or others in your headquarters, and mostly every time
16 I saw headquarters of General Mladic, and we give the help -- help and
17 need wherever we could, hospitals and people that they were wounded, and
18 I recall the bishop, we bought some equipment in Kasindol hospital and
19 was a French UNPROFOR there. Actually, they delivered it. We paid it
20 for and they delivered it.
21 Yes, we were sort of trying to do the best we can to spread our
22 help all around wherever is required, but was too difficult and is not
23 enough to go around to everybody.
24 Q. Thank you. So can we agree that when you were there in July in
25 our area you never heard anything about any killings? When was it the
Page 25066
1 first time that you heard there were killing around Srebrenica? Was that
2 after you returned to Canada, and when was it exactly, and from what
3 media did you learn that?
4 A. At that time, I was occupied -- my head was occupied and my
5 travelling and business in Canada as well to get the scanner tube over,
6 and after scanner tube arrived two days or something that's when I
7 arrived and I been questioned about the Srebrenica, how come you didn't
8 know, you didn't know. I didn't know. I travelled all night, and I
9 travelled from Sofia to Belgrade. I was exhausted and tired. I didn't
10 heard of any killing or anything until media then carry on and carry on.
11 After few days when I returned to Canada, that was things done in
12 Srebrenica.
13 Q. Thank you. When you first heard reports in the media about this,
14 did that bring to mind all the earlier instances of propaganda in the
15 media you, yourself, could see what it was -- for what it was? So was it
16 the same way of blackening the Serbs, as it were?
17 A. Yes. Those things were happening there. Serbs were painted --
18 painted black even though they weren't guilty. As I recall discussion,
19 if they kill one soldier, they made a big issue out of it, killing 10 or
20 20, and I question intelligence. What, did it happen? No, that's only a
21 media, Pete Salapura says. Don't believe everything you hear. So it was
22 tough. It was tough for everybody there to know the truth. Somehow we
23 didn't have the finance or anything to have a media, Serbian media or any
24 other media to go there, right, and see what's happening and record it to
25 get some time on CNN or CBC or some other. It's very difficult to get to
Page 25067
1 those stations to tell your side of the story.
2 That's what we went through, and I guess we'll never go through
3 again, I hope we never do again.
4 Q. Thank you. Do you agree that there was a general prevailing
5 perception that the Serbs had lost the media war, and was a war also
6 waged in the media that we never actually took part in, and that is
7 probably the reason why we had lost it?
8 A. Well, the way I understand it, living in a Western country for so
9 many years, media can make you or break you. In Canada, if you run for
10 prime minister or party or president, media is a crucial -- crucial
11 things, and TV and publicity and everything. It was the same in the war.
12 I believe personally that Serbs never had a good media on their
13 side from nowhere at that time. So, yes, I agree we lost the war in the
14 media and could not be any differently. I don't see why, but it
15 happened.
16 Q. Thank you. This type of biased reporting, did that provoke in
17 Serbs a bitterness, and did the Serbs in Canada find this difficult to
18 cope with the way that the media portrayed the Serbs and whether you had
19 occasion to see for yourself where all those lies were coming from and
20 what the lies were?
21 JUDGE KWON: Mr. Lesic, I was advised that you are speaking too
22 close to the microphone. Could you move back just a bit.
23 THE WITNESS: Sorry, sir. Unexperienced.
24 JUDGE KWON: Please proceed, Mr. Lesic. Could you answer the
25 question.
Page 25068
1 THE WITNESS: Yes. The media in Canada, for a moment I actually
2 believed that first time I went over what was going on. Then went over
3 and I saw for myself, and I even ask and ask over and over, and I was
4 never given that was -- that media was on the right track. We were
5 always, always discriminated. We had no media on our side.
6 Just the way we all felt in Canada was rough for us, as I
7 mentioned earlier, when kids go to school and all that and the war's
8 every hour or every ten minutes on the TV, so people talk about it and
9 that's the way it was.
10 MR. KARADZIC: [Interpretation]
11 Q. Thank you. Is that how you interpreted the intercept of the
12 conversation between you and General Mladic, that both of you actually
13 hoped that this hunger in the media for sensationalism would be slaked by
14 stories coming from Iraq and that they would sort of leave us aside?
15 A. During discussion with General Mladic about that incident, yes.
16 I was really hoping that media would leave us alone because they were
17 occupied with Iraq. Yes. That was my opinion, and I said that to him is
18 good.
19 Q. And he agreed with you in that respect?
20 A. Yes. Yes. He agreed with me. General Mladic agreed with me.
21 Q. Thank you. I have to ask you the following: Is it possible that
22 regarding this meeting with me in 2001, you were confused and that it
23 would have been a different year? I do understand that it may have been
24 sometime before the year 2000. So is it possible that an error was made
25 in the year?
Page 25069
1 JUDGE KWON: Is this serious? Is he opening the door to --
2 MR. ROBINSON: I hope not. If you would give me a moment to
3 speak with him about that, please.
4 THE ACCUSED: [Interpretation] My apologies. I was not aware of
5 the Chamber's decision.
6 May I take advice from Mr. Robinson?
7 [Accused and counsel confer]
8 THE ACCUSED: [Interpretation] My apologies. I wasn't aware of
9 the Ruling and that the extent of things that were excluded was.
10 MR. KARADZIC: [Interpretation] Mr. Lesic, I thank you for your
11 evidence, and I hope that you didn't find it too difficult. Thank you.
12 I have no further questions.
13 THE WITNESS: Thank you.
14 JUDGE KWON: Yes, Ms. West.
15 MS. WEST: Just briefly, sir.
16 Re-examination by Ms. West:
17 Q. You were just asked a short time ago from Mr. Karadzic whether
18 the Bosnian Serbs did anything for which you would feel ashamed. Do you
19 remember that question?
20 A. Yes, I remember. When I was in Canada, I couldn't believe that
21 they did anything to be ashamed of, so when I went there and I got
22 different story, so I didn't see anything or found anything that Serbians
23 would be ashamed of that.
24 Q. Okay. So, Mr. Lesic, do you believe that in 1995 that thousands
25 of Bosnian Muslim men were executed by the Bosnian Serbs in the vicinity
Page 25070
1 of Srebrenica?
2 A. That's what media says, but I did not learn from anybody else. I
3 don't know.
4 Q. Okay. And at page 41 of today's transcript, Mr. Karadzic asked
5 you -- we were talking about feeding a large number of prisoners, and he
6 asked you whether you agreed that --
7 JUDGE KWON: Just a second. Mr. Lesic, you said that's what
8 media said, but I did not learn from anybody else. Did you mean you
9 didn't know at the time?
10 THE WITNESS: I didn't know. I didn't see anything. I didn't
11 know.
12 JUDGE KWON: What do you think now, Mr. Lesic?
13 THE WITNESS: What do I think now? Yes, there could be on both
14 sides some of it, but not as much as they proclaimed it to be, sir.
15 JUDGE KWON: Thank you. Yes, Ms. West, please continue.
16 MS. WEST:
17 Q. Sir, earlier today you were asked about feeding prisoners of war
18 and specific the question was:
19 "Do you agree that in such conditions it was also rather
20 difficult to feed large numbers of prisoners of war properly? We could
21 feed them only in the way that we fed our own army."
22 And you were answer was: Yes, I never saw any prisoners, but I
23 was told and I would presume, yes, if you don't have food enough for
24 yourself then you can't give away much of it either.
25 Now, earlier today you said that you also gave money to the
Page 25071
1 Red Cross. Is that true?
2 A. Yes, we give Red Cross for the medicine to buy from Galenika in
3 Belgrade. In hospitals we give not the big money, $5.000, $6.000 here
4 and there. Was not enough to go around. When we give flour as well
5 later on. We helped as much as we could. But when I said I didn't see
6 prisoners, I didn't see everywhere prisoners, but in one incident when I
7 was with bishop I saw some prisoners there, and when I was giving money,
8 cash money to the people waiting for the bread, I saw there prisoners by
9 the Banja Luka from Sanski Most, from all over. Eighty people or hundred
10 people sleep in one big large room.
11 Q. Okay.
12 A. One area I didn't see, another area, yes, I did see.
13 Q. Okay. But I want to speak more about the issue of food for
14 prisoners. Are you -- you said you gave money to the Red Cross. You
15 must be familiar with the Red Cross's job of registering prisoners and
16 feeding them and providing for them. Are you familiar with that?
17 A. Not really. What -- what we did, we go to the little room and
18 they have their thing even for Montenegro delegate. Six or seven people
19 came from Red Cross from Montenegro to Han Pijesak, and they were
20 Red Cross representative. They brought help. And something like that in
21 Banja Luka or in Prijedor or somewhere Red Cross office. You give them,
22 but we get sort of get the pictures and get the paper certificate, get
23 the receipt for it.
24 Q. Okay. Thank you very much, Mr. Lesic.
25 MS. WEST: Thank you, Mr. President.
Page 25072
1 JUDGE KWON: Mr. Lesic, that concludes your evidence. On behalf
2 of this Chamber and the Tribunal, I would like to thank you for your
3 coming to The Hague to give it.
4 THE WITNESS: May I ask you, sir, to say couple words in regard
5 of my witness being here?
6 [Trial Chamber confers]
7 JUDGE KWON: Mr. Lesic, if you could understand, the Chamber
8 usually does not hear from the witness out of its formality.
9 THE WITNESS: All I want to thank.
10 JUDGE KWON: Very well.
11 THE WITNESS: I was very impressed with the witness -- the way
12 witnesses being looked after here and a job well done. They look after
13 these people and witness and all that, asking them how they feel and the
14 hotel and driving back and forth. It is well -- well planned, and I want
15 to thank you all the way I was here treated.
16 JUDGE KWON: Thank you. Please have a safe journey back home.
17 THE WITNESS: Thank you, sir.
18 [The witness withdrew]
19 JUDGE KWON: Could the Chamber move to private session briefly.
20 [Private session]
21 (redacted)
22 (redacted)
23 (redacted)
24 (redacted)
25 (redacted)
Page 25073
1 (redacted)
2 (redacted)
3 (redacted)
4 (redacted)
5 (redacted)
6 (redacted)
7 (redacted)
8 (redacted)
9 [Open session]
10 JUDGE KWON: Yes. We are in open session.
11 Mr. Tieger.
12 MR. TIEGER: Mr. President, I'm advised that the next witness is
13 not yet in the building and is, in fact, en route. I am trying to obtain
14 as clear and specific information about how much time that will take. I
15 presume it's a matter of minutes, in the order of 15 to 20, but I'd like
16 to get that information as quickly as possible and relay it to the
17 Court.
18 JUDGE KWON: Given the timing, the Chamber is minded to take a
19 two times half an in our break now. So starting from now, and we will
20 have just a bit more than one hour session twice. That may suit the
21 situation.
22 Then we will have a break for half an hour and resume at 20 past
23 12.00.
24 --- Recess taken at 11.49 a.m.
25 --- On resuming at 12.27 p.m.
Page 25074
1 [The witness entered court]
2 JUDGE KWON: Good afternoon, sir. Will you take the solemn
3 declaration, please.
4 THE WITNESS: [Interpretation] I solemnly declare that I will
5 speak the truth, the whole truth, and nothing but the truth.
6 WITNESS: LJUBOMIR OBRADOVIC
7 [Witness answered through interpreter]
8 JUDGE KWON: Thank you, Mr. Obradovic.
9 Yes, Ms. Edgerton.
10 MS. EDGERTON: That's fine, Your Honour. Not a problem at all.
11 Thank you.
12 Examination by Ms. Edgerton:
13 Q. General, would you be able to state your full name for us,
14 please.
15 A. My name is Ljubomir Obradovic. I was born on January 30th, 1950,
16 in Visegrad, Bosnia-Herzegovina.
17 Q. Thank you. Now, General, you've appeared before Judges of this
18 Tribunal before, first as a Defence witness in the trial against
19 General Miletic and others in 2008, and then last year you gave evidence
20 as a Prosecution witness in the Tolimir case; is that correct?
21 A. Yes.
22 Q. And before coming here to give evidence today, you had a chance
23 to listen to a recording of your testimony in the Tolimir case in your
24 own language; is that correct?
25 A. Yes.
Page 25075
1 Q. Were you satisfied with the accuracy of the recording?
2 A. I think it is identical.
3 Q. And if I was to ask you the same questions today that you were
4 asked during your testimony in the Tolimir case, would your answers be
5 the same?
6 A. Yes.
7 Q. Thank you.
8 MS. EDGERTON: Now, Your Honours, pursuant to your order
9 yesterday, we've created a redacted version of General Obradovic's
10 Tolimir transcript, and that's been uploaded as 65 ter 23610. If that
11 could please be a Prosecution exhibit.
12 JUDGE KWON: I commend your promptness very much. Yes. That
13 will be admitted.
14 THE REGISTRAR: As Exhibit P4444, Your Honours.
15 MS. EDGERTON: Thank you. And as for promptness, I extend that.
16 That's due in large measure to the support that we work with. Thank you.
17 Q. Now, General, during your testimony in the Tolimir case, you gave
18 some details about your function. You said -- actually, I'll start a
19 different way.
20 General, in your Tolimir testimony, you made to clear that you
21 were transferred to the Main Staff of the Bosnian Serb Army on
22 1 September 1994. Do you remember that?
23 A. Yes.
24 Q. And you described your function at page 11929 of the transcript.
25 You said you followed the operative situation and the situation in the
Page 25076
1 battle-field. You wrote orders, reports, warnings, plans, and followed
2 the operative log-books. Do you remember that as well?
3 A. Yes.
4 Q. Could you just explain to us briefly how you -- how you were able
5 to do that job? What information did you rely on to be able to follow
6 the operative situation, the situation in the battle-field and write
7 orders?
8 A. All of that was done on the basis of regular daily and interim
9 reports that we received from subordinate units.
10 Q. Thank you.
11 MS. EDGERTON: And before I move on too quickly, Your Honours, I
12 realise I omitted to read the summary of evidence which I would normally
13 have done before this first question.
14 JUDGE KWON: Yes.
15 MS. EDGERTON: And I will do that now with your leave.
16 JUDGE KWON: And I also omitted asking you whether Rule 90(E) is
17 necessary for this witness. It was given at the Tolimir case, so I need
18 your guidance.
19 MS. EDGERTON: Indeed. I think that would be the best way to
20 proceed, Your Honours.
21 JUDGE KWON: General, probably you are aware of this already, but
22 I would like to draw your attention to a particular Rule here at the
23 Tribunal. Under this Rule, Rule 90(E), you may object to answering a
24 question from the Prosecution or the accused or from the Judges if you
25 believe that your answer will incriminate you. When I say "incriminate,"
Page 25077
1 I mean that something you say may amount to an admission of your guilt
2 for a criminal offence or could provide evidence that you have committed
3 an offence. However, even if you think your answer will incriminate you
4 and you do not wish to answer the question, the Tribunal has the
5 discretion to oblige you to answer the question, but in such a case the
6 Tribunal will make sure that your testimony compelled in such a way shall
7 not be used as evidence in other another case against you for any offence
8 other than false testimony.
9 Do you understand what I have just told you, sir?
10 THE WITNESS: [Interpretation] Yes, and I was advised of the same
11 in the Tolimir case by the Presiding Judge.
12 JUDGE KWON: Thank you, General.
13 Yes, Ms. Edgerton.
14 MS. EDGERTON: Thank you. And very briefly, the summary of the
15 witness's written evidence as filed is as follows:
16 From September 1994, General Obradovic served as the head of the
17 Operations Department in the administration for operations and training
18 organ of the Main Staff of the --
19 THE WITNESS: [Interpretation] I'm not receiving any
20 interpretation. No interpretation.
21 JUDGE KWON: Did you hear me when I explained the Rules?
22 THE WITNESS: [Interpretation] I'm not getting any
23 interpretation.
24 JUDGE KWON: Yes. I hope you are now hearing me, General.
25 THE WITNESS: [Interpretation] Yes.
Page 25078
1 JUDGE KWON: Yes. Please continue, Ms. Edgerton.
2 MS. EDGERTON: Thank you.
3 From September 1994, General Obradovic severed as head of the
4 Operations Department in the administration for operations and training
5 sector of the Main Staff of the Army of Republika Srpska. His duties
6 included following the operative situation, the situation on the
7 battle-field, and drafting documents which included orders, reports, and
8 plans.
9 General Obradovic explains the command structure of the
10 Main Staff of the Army of Republika Srpska. He identifies in his written
11 evidence core members of the Main Staff of the Bosnian Serb Army and
12 their various areas of responsibility and competence. He explains the
13 structure of the Main Staff. He sets out the various duties and
14 responsibilities of different organs, including the
15 67th Communications Regiment, the 10th Sabotage Detachment, the
16 65th Protection Regiment, and the Department of Civil Affairs.
17 General Obradovic explains the timely and accurate reporting system of
18 the Bosnian Serb Army from the lowest level through the Main Staff up to
19 the president, Dr. Karadzic. He addresses how military directives were
20 prepared with all sectors of the Main Staff taking part in their
21 drafting.
22 General Obradovic will describe the communications methods used
23 by the Army of Republika Srpska. These allowed for immediate contact
24 between military commanders and their subordinates, including forward
25 command posts, located through Bosnian Serb held territory.
Page 25079
1 That's the brief summary, Your Honours.
2 And just your indulgence for a moment to see where I left off.
3 Q. Thank you for that answer, General, in relating to the
4 information you relied on to carry out your function. I'd like to ask
5 you for a second about the accommodations of the Main Staff. Can you
6 tell us where the Main Staff of the VRS operated from?
7 A. The VRS Main Staff, as the high command, was housed in an area
8 that included an underground facility under the Zep mountain,
9 Crna Rijeka, and the Han Pijesak town.
10 Q. Would you be able to describe each of those accommodations in a
11 bit more detail for us in order that the Judges can understand the
12 facilities with a bit more detail, beginning with the last one,
13 Han Pijesak town.
14 A. Han Pijesak was the place where two sectors were accommodated,
15 the logistics sector and the organisation, mobilisation, and personnel
16 affairs sector, and for a while the moral guidance, religious, and legal
17 affairs sector was housed there as well.
18 Q. And what kind of facilities were located at Han Pijesak? Can you
19 describe the actual accommodations?
20 A. Well, for the most part these sectors were housed in a hotel. I
21 can't recall what the name of that hotel was. Some kind of lodge or
22 something like that, but it was a hotel, a catering facility of some
23 sort.
24 Q. And now moving on to Crna Rijeka. Could you describe the
25 facilities there?
Page 25080
1 A. There were two buildings in Crna Rijeka and subsequently another
2 one. They were built -- they were like cabins, log cabins, and they were
3 there for accommodating the 17th Communications Regiment and also for
4 parts of the 65th Protection Motorised Regiment. The staff sector was
5 housed also in these cabins: The security and intelligence sector, the
6 air force and air defence administration, the planning, development, and
7 finance administration.
8 Q. Now, I understood from the interpretation that the buildings the
9 Main Staff was housed in at Crna Rijeka were log cabins. Did you mean to
10 describe wooden structures or something else?
11 A. Well, they were wooden structures, yes, like huts.
12 Q. Were they prefabricated?
13 A. Yes. These structures are used for housing personnel. They are
14 prefabricated, yes.
15 Q. And I also understood from the interpretation that you also
16 referred to the 67th Communications Regiment -- - pardon me, the
17 17th Communications Regiment. Did you mean to refer to the 67th?
18 A. I did say the 67th Communications Regiment, and parts of it were
19 in Han Pijesak, in Crna Rijeka, and also in the underground facility,
20 because its elements were used to provide certain communications assets
21 and types of communications.
22 Q. Now, let's talk about that underground facility for a moment.
23 First of all, how far from it was your headquarters at Crna Rijeka?
24 A. About 2 to 2.5 kilometres, because the entrance to the facility
25 faced Crna Rijeka. It was on that slope.
Page 25081
1 Q. And was the underground facility in constant use throughout your
2 time in the Main Staff?
3 A. As it was an underground facility, it's not very comfortable.
4 It's not well aired, so it's not a good place to spend time. We would
5 stay there only when threatened with NATO bombing.
6 Q. The communications facility or a portion of the
7 67th Communications Regiment was permanently housed there; correct?
8 A. Yes.
9 Q. How big was the underground facility?
10 A. It was divided into blocks. One of the blocks was the technical
11 one, and it had generators for the heating, for ventilation, and for the
12 lighting. There was also a reservoir with drinking water. There was one
13 section or part that was used for the communications regiment, and there
14 was a part used for offices and for accommodation for the number of
15 people involved at that level of command. This facility had been built
16 for the command of the 7th Military District in the former SFRY.
17 Q. Now, just -- I'd just like to go back to communications for a
18 moment, and I wonder if you can list for us the different means of
19 communication that the Main Staff had available to it throughout your
20 time there.
21 A. Well, communications can be broken down into command
22 communications, co-operation communications, and intelligence
23 communications. You can use radio, the wire, relays. I'm not a
24 communications expert, so I could slip up.
25 As for the equipment, there were automatic telephone exchanges
Page 25082
1 and various types of relay devices. Again, it all depended on whom you
2 had to establish communications with. The communications equipment used
3 depends on the unit that needs to use certain kind of equipment.
4 Q. Well, let's just talk about telephone exchanges for a second.
5 How many telephone exchanges did the Main Staff have available to it?
6 A. I don't know.
7 Q. Did it have a PTT telephone exchange available?
8 A. It had an automatic telephone exchange, yes, and there were
9 so-called civil numbers. That's what we called them. That was the case
10 in the corps, and in the Main Staff.
11 Q. Did it have a military telephone exchange, military switchboard,
12 available to it?
13 A. I assume that there were a number of such switchboards. The
14 communications regiment had various types of devices that weren't that
15 large, but as for these fixed exchanges, I think that capacity was far
16 greater, and they had far more extensive series of numbers.
17 Q. Now, you talked in your Tolimir testimony about extension 155.
18 Do you remember that?
19 A. Yes, yeah.
20 Q. Was that part of the military -- a military telephone exchange?
21 A. Yes.
22 Q. Now, I'm a bit curious about this three-digit number, actually.
23 This first number, 1, does that -- do people who have an extension with
24 that first number have any specific means of communication available to
25 them?
Page 25083
1 A. I wouldn't know. These are three-figure numbers that each office
2 had or official in a military switchboard, and this had to do with the
3 agreement, the mutual agreement reached between the organs of command.
4 Q. You talked about relay devices, different types of relay devices.
5 What did you mean to describe when you referred to them?
6 A. Radio relays are used by high-level units. We communicate over
7 the phone, but up to a certain relay which then connects to the next
8 relay where the next unit is located, and then the transmission continues
9 towards the phones. These are radio relays, and they can be intercepted.
10 Conversations can be intercepted in spite of the fact that people might
11 be using phone devices, have phones in their hands.
12 Q. When you talk about these relays being available to high-level
13 units, from what level are you referring to?
14 A. From the level of the brigade as a tactical unit and upwards. So
15 the Infantry Brigade, motorised brigades, and other types of brigades
16 that are concerned. The light brigades did not have such equipment as
17 per their establishment.
18 Q. Now, in your testimony in the Tolimir case, you talked about an
19 encryption device that you referred to as KZU 63. Was that a device that
20 was used to protect the relay communications you've just described?
21 A. Yes. It could be used to protect radio relays, but it was also
22 used for radio links at a lower level. It would be installed for two
23 participants, for one participant on one device and for the other on the
24 other device. So you compress the information and in a very short period
25 of time the information is forwarded. It is an abbreviation for
Page 25084
1 crypto-protection device 63. The number 63 refers to the model. It is
2 the year in which the device was produced.
3 Q. Was this device part of the normal assets of the corps?
4 A. I don't know exactly how many such devices the corps had, but
5 they did have such devices.
6 Q. How would such a device -- or what organ would be responsible for
7 the supply of such a device?
8 A. Planning and organising communications in staff sector is done by
9 the communications organ. The implementing communications and having
10 equipment, well, it's the 67th Communications Regiment that should have
11 such equipment at its disposal.
12 Q. Just by way of an example, in the event of an operation that
13 required the establishment of a forward command post, what would the
14 procurement process be for forward command post to secure one of those
15 devices?
16 A. If we're dealing with the corps forward command post, then when
17 planning an operation, in addition to all the other tasks that concerned
18 assessing enemy strength, engaging one's own forces and equipment and so
19 on and so forth, in addition to those tasks, the communications organ
20 within the corps would plan for certain communications in accordance with
21 the decision of the corps commander. And if it was a plan when
22 establishing the forward command post taken -- or drawn up by the
23 Main Staff, when one functioned within the Main Staff you attempt to get
24 the 67th Communications Regiment, so the communication the organ, to plan
25 for the necessary communications system.
Page 25085
1 Q. If the forward command post related to an operation that involved
2 one or more corps and was therefore commanded by a member of the
3 Main Staff, what would the procurement process then be? How would they
4 get one of those devices for the forward command post?
5 A. Well, in accordance with the plan for the operation, the last
6 element of an order or a decision that has to do with the commands and
7 communications, and in that part of the order the commander will request
8 the kind of communications that need to be organised, and this will then
9 be the duty for the communications organ from the staff sector. They
10 will have to use the 67th Communications Regiment in order to organise
11 such communications at the forward command post in question.
12 Q. Thank you. On this subject, actually, I'd like us to look at a
13 document, please, 65 ter 02050, dated 14 July 1995. It's a document
14 bearing the reference number 04-520-56/95 from General Tolimir to --
15 General Tolimir, who is writing at the time from the 1st Podrinje Light
16 Infantry Brigade, to General Miletic. And he says:
17 "In order to have a complete review of the Drina Corps command
18 radio network, it's necessary to incorporate the Main Staff of the Army
19 of Republika Srpska in the work plan of the Drina Corps command
20 communication with an RU2/2 radio and a KZU-63 set."
21 Now, relating to what we've been discussing, I have a couple of
22 questions about this document. First of all, can you tell us what an
23 RU2/2 K set is?
24 A. It's a radio device. 2/2 K, it's a kind of radio device. It's
25 the kind of radio device that we had. A little more modern if compared
Page 25086
1 to a RUP 12.
2 Q. When you say "radio device," do you mean that it's just a radio
3 or do you mean it attaches to and works in conjunction with a radio?
4 A. With your leave, I'll explain the entire document.
5 JUDGE KWON: Yes, by all means, General.
6 THE WITNESS: [Interpretation] In the heading, you can see that
7 it's the command of the 1st Podrinje Light Infantry Brigade, and at one
8 of its command posts there is Major-General Zdravko Tolimir. It is
9 obvious that from that location -- it says, "In order to monitor combat
10 activities." That's with it says in the first sentence:
11 "In order to monitor combat activities around Zepa and gain a
12 complete -- gain complete insight into the Drina Corps radio network with
13 brigade commands, it is necessary for the VRS Main Staff to be included
14 in the Drina Corps command work plan for communications, and it should
15 have one radio RU2/2 with encryption, and it says that all brigade
16 commanders have this equipment."
17 So this radio network is protected by these devices. So in order
18 to be able to listen to communications between the Drina Corps and his
19 command brigades, because he was in charge of the operation, he needs
20 such a radio device.
21 JUDGE KWON: Ms. Edgerton, in your question, transcript page 66,
22 line 14 to 16, I said:
23 "If the forward command post relate to an operation that involved
24 one or more corps and was therefore commanded by a member of the
25 Main Staff."
Page 25087
1 That was your question, and we didn't hear from the witness, and
2 I wonder why don't you put a question to the witness whether the document
3 we are seeing now is related to an operation that involved one or more
4 corps.
5 MS. EDGERTON: Thank you, Your Honour.
6 Q. General, with respect to the document in front of us which
7 emanates from General Tolimir, do you know, first of all, whether this
8 relates to an operation that involves more than one corps?
9 A. Your Honour, this document shows that this operation had to do
10 with the Drina Corps. General Tolimir talks about the operations of the
11 Drina Corps. He talks about this with the brigade commanders. If it
12 concerned two corps or more, if this operation concerned two corps or
13 more, then the Main Staff would have the obligation of leading the
14 operation, and then all these types of communications would have been
15 planned and communication with all the participants would have been made
16 possible.
17 Q. General, you indicated in your Tolimir testimony that you were on
18 leave from January until the 17th of July, 1995. Now, I wonder after
19 your return to the Main Staff whether you became familiar with the
20 operation that found General Tolimir at the command of the
21 1st Podrinje Light Infantry Brigade.
22 A. I didn't become familiar -- well, the date here is the
23 14th of July. I returned on the 17th of July. I broke my leg on the
24 27th of January, and I recovered and returned on the 17th of July. But
25 the document shows -- well, I couldn't have even known about this because
Page 25088
1 the Drina Corps planned this operation, and it's the commander who is in
2 charge of the operation.
3 Q. Just one last question, General: What was General Tolimir doing
4 writing the Main Staff from the command of the 1st Podrinje Light
5 Infantry Brigade on the 14th of July?
6 A. Well, I can't tell you what he was doing. Obviously he was in a
7 brigade that was subordinated to the Drina Corps. The Drina Corps
8 carrying out the operation. As to whether he received a task from the
9 commander to gain insight into something or not, I don't know. I can't
10 answer that question.
11 Q. In what circumstances would one of the assistant commanders
12 normally be deployed to a brigade headquarters as in this situation?
13 A. In order to supervise certain combat activities, this can also be
14 done in the field. As to why Mr. -- why General Tolimir was there, I
15 don't know. Did he receive an order from the commander or was he simply
16 there and tried to find information and thought that perhaps someone
17 should listen in to the radio network within the Drina Corps in the
18 course of the operation. I don't know what his position was and on the
19 basis of whose order he was down there.
20 Q. So one last question before leaving this document. Based on what
21 I just understand you've said, this equipment would enable whoever has it
22 not only to communicate with units of the Drina Corps command but also to
23 monitor those conversations; is that correct? Is my understanding
24 correct?
25 A. Yes. If they have or if he has the same encryption device.
Page 25089
1 MS. EDGERTON: Thank you. Could I have this as a Prosecution
2 exhibit, please, Your Honours.
3 JUDGE KWON: Yes.
4 THE REGISTRAR: Exhibit P4445, Your Honours.
5 MS. EDGERTON:
6 Q. Now, I'd just like to go to one further documents and, to change
7 topics, back to the Main Staff and the structures per se, and that's
8 65 ter number 23594, an organigramme of the Main Staff prepared by the
9 Office of the Prosecutor based on your evidence in the Tolimir case.
10 Now, while we can call this up on the monitors, Your Honours, I
11 think the printing might be kind of small, so we have copies of this in
12 A3 format for Your Honours and for the witness and for the parties.
13 JUDGE KWON: That's very find of you, Ms. Edgerton. I take it
14 there is no objection to the addition of this and other documents to the
15 65 ter list, Mr. Robinson.
16 MR. ROBINSON: That's correct, Mr. President.
17 JUDGE KWON: It's granted.
18 MS. EDGERTON: If you could just in the fullness of time pass one
19 copy to the witness as well, I'd like to ask him a question about it.
20 JUDGE KWON: I was told that he has it.
21 MS. EDGERTON: He doesn't have a paper copy, Your Honour, and
22 just so he can see more clearly.
23 JUDGE KWON: It's on its way.
24 MS. EDGERTON:
25 Q. Now, General, do you remember looking at this organigramme
Page 25090
1 yesterday in preparation for your testimony today, setting out some of
2 the formations and structures of the Main Staff?
3 A. Yes.
4 Q. Now, at the time, you noted that the organigramme was accurate
5 but for the omission of reference to General Mladic's office; is that
6 correct?
7 A. The office, the cabinet, doesn't relate to the commander.
8 Q. Where would that fit into this organigramme?
9 A. Well, here to the right. You can see the where the sector for
10 co-operation with foreign military representatives is, so it would be in
11 that area.
12 Q. And who staffed that cabinet, to your recollection?
13 A. Well, I can't remember, but I do remember Rajko Banduka. He left
14 an impression on me, so I do remember him.
15 Q. Do you remember what his job was?
16 A. Well, he was a secretary. I didn't have a secretary, so I don't
17 know anything about the nature of his work.
18 Q. Now, having a second look at this document today, did --
19 A. I apologise. On the whole, he'd make notes, help the commander.
20 He would plan his agenda, receive calls, and so on and so forth. He
21 would sit in the office that was next to the commander's office.
22 Q. And where was that?
23 A. In the Zep Goljak 1 facility, G1.
24 Q. Just one question regarding the commander's office. Did he share
25 that office with anyone?
Page 25091
1 A. Well, I don't know. That office is at the very entrance into
2 this underground area, as you call it. So this entrance is marked by --
3 is masked, rather, by this villa, and in this villa there were a few
4 rooms and that's where the commander was and his closer co-workers from
5 the cabinet and from security.
6 Q. Did the commander have an office at each of the three Main Staff
7 facilities you've mentioned?
8 A. No.
9 Q. Where was -- where were his offices then? And just to be
10 perfectly clear, when the commander was at the Main Staff, where was
11 that?
12 A. He was staying at the entrance at this villa before you enter the
13 underground. When he'd come, he would just go to anybody's office to get
14 some business done, usually at the chief's office or some other close
15 co-worker. Over their barracks, he did not have an office that was
16 particularly his.
17 Q. I've just understood you to say, Over the barracks, he didn't
18 have an office that was particularly his. What do you mean by that?
19 Over what barracks?
20 A. Well, I mean there was no office where he would be the only
21 person who would be signature there and nobody else. If you have an
22 office, you are in that office. However, if your boss were to be
23 appointed commander, then he would come to get something done with you,
24 and he'd come to your office to get that done.
25 Q. Now, you've just said there was no office where he would be the
Page 25092
1 only person who'd be sitting there and nobody else, so who did he
2 normally sit with?
3 A. Yes. Well, for the most part he was up there, up there, this
4 establishment facility where his room was, his bedroom or the room where
5 he slept and where he worked, and downstairs he'd usually go to see his
6 assistants who were there, or he'd come to that small operations room
7 where we were. I mean, there was not a particular place that had been
8 envisaged for him to be there permanently.
9 Q. Just one last question. When you say "he was up there," General,
10 I'm afraid we don't know what place you mean by that. So what do you
11 mean?
12 A. You insist, or you think that down there where the barracks are
13 in Crna Rijeka, you're insisting on some room that he was staying at all
14 the time. He did not have any such room. When he'd go by car
15 2.5 kilometres, if he needed to exchange something with someone, then
16 he'd do that with the assistants. If he wanted to visit and check, then
17 he'd see everybody. If he had some business with the intelligence
18 people, then he'd stop by and see them. If he had something to talk to
19 the operations people, us, then he'd stop by our office and see us. So
20 he did not have this particular place where he would come all the time.
21 Q. Thank you. Now, just to go back to the organigramme, having a
22 second look at this since you last did, the day before yesterday, do you
23 have any information additional that you wish to add to it, anything you
24 feel needs to be filled in to make it accurate?
25 A. Well, nothing. I remembered my testimony in the Tolimir case.
Page 25093
1 The last name of the colonel who headed the communications unit was
2 Gredo.
3 MS. EDGERTON: Thank you, with that, could we have this as the
4 next Prosecution exhibit, please.
5 JUDGE KWON: Yes.
6 THE REGISTRAR: Exhibit P4446, Your Honours.
7 JUDGE KWON: Ms. Edgerton, I didn't go through the Tolimir
8 transcript, but I take it he explained the meaning of the dotted line on
9 this organigramme.
10 MS. EDGERTON: He did not, Your Honour, and it's something I'd
11 actually like to come back to in the presentation, which is why I wanted
12 it dealt with up front --
13 JUDGE KWON: Thank you.
14 MS. EDGERTON: -- if I may.
15 Q. Now, General, in your Tolimir testimony you explained the combat
16 reporting system of the Army of Republika Srpska and how it worked from
17 the brigade level right up to the Main Staff. You referred to the
18 Main Staff's reporting obligation to the supreme commander, Dr. Karadzic.
19 You explained how reports were prepared, who prepared them, and how
20 reports from subordinate units were excerpted and incorporated into the
21 Main Staff's report to Dr. Karadzic, and you were shown some examples of
22 this. That's in your Tolimir testimony at pages 11966 to 11982. Do you
23 remember all that?
24 A. Yes.
25 Q. Thank you. I'd like to ask you some additional questions about
Page 25094
1 reporting and then turn to a series of documents. My first question is:
2 Did forward command posts have the same reporting obligation as other VRS
3 units? And I mean forward command posts at all levels.
4 A. Yes. Forward command posts wrote daily operations reports and
5 combat reports just like all other units for the area for which they had
6 been established, and they sent this in encrypted form to the Main Staff.
7 Q. The reports that came to the Main Staff from the corps, were
8 those also in encrypted form or did that depend on the situation?
9 A. Well, most often they were sent in encrypted form.
10 Q. Would reports from the forward command posts come to the same
11 organ as the reports from the corps, the operations sector, in other
12 words?
13 A. Yes.
14 Q. In addition to the receipt of written reports from subordinate
15 units, did the commander General Mladic also --
16 JUDGE KWON: I'm sorry to interrupt him. I'm not sure I
17 understood the last question and answer:
18 "Q. Would reports from the forward command post come to the same
19 organ as the reports from the corps, the operations sector, in other
20 words?
21 "A. Yes."
22 If it is addressed to their organ, or does it mean that any
23 report from the IKM go to any command? Could you clarify?
24 MS. EDGERTON: Of course I could, Your Honour.
25 Q. Was there a particular sector that received reports -- particular
Page 25095
1 Main Staff sector that received reports from the corps?
2 A. Your Honour, I explained that in the previous trial. Within the
3 administration for operations and training, in addition to the operations
4 department and the training department, it was envisaged by establishment
5 to have a third body that was called the operations centre. According to
6 establishment, it was supposed to have a higher ranking officer as the
7 head of this centre and to higher ranking officers as shift leaders.
8 Since we did not have enough personnel, this centre never became
9 operational. So all these reports from the corps, from the
10 anti-aircraft, from the schools, and so on, and forward command posts
11 came to the Main Staff, addressed to the Main Staff, to the staff sector,
12 to the administration for operations and training.
13 JUDGE KWON: So I take it that that organ or that unit receives
14 all the reports addressed to the Main Staff?
15 THE WITNESS: [Interpretation] Yes.
16 JUDGE KWON: Thank you.
17 MS. EDGERTON:
18 Q. Thank you very much. In addition to these written reports from
19 all these units, did General Mladic also have direct contact with the
20 corps commanders?
21 A. Yes. He had direct communication with corp commands. That was
22 envisaged by the rules and instructions, and he had direct communication
23 with all.
24 Q. And similarly, did he have direct communication with forward
25 command posts for particular operations?
Page 25096
1 A. Well, they were not permanent, but he did have relay
2 communication with certain protection involving encryption.
3 Q. This direct communication with the corps commands, you referred
4 to it being envisaged by the rules and instructions.
5 A. These are stationary communications.
6 Q. Did they occur with any regularity?
7 A. Well, once they were established, they were there throughout.
8 Command posts of corps did not physically change their positions.
9 JUDGE KWON: Ms. Edgerton, we are on some irregular schedule
10 today. If it is convenient, we will take a break.
11 MS. EDGERTON: Oh, any time, Your Honour. I had no idea when the
12 break might be so I just thought I would continued until warned.
13 JUDGE KWON: Thank you. We will take the break for half an hour
14 and resume at 2.00.
15 --- Recess taken at 1.30 p.m.
16 --- On resuming at 2.02 p.m.
17 JUDGE KWON: Yes, Ms. Edgerton.
18 MS. EDGERTON: Thank you, Your Honours.
19 Q. General, just to continue where we left off before the break, I
20 understood you to be saying that once the lines were established,
21 General Mladic was in, effectively, permanent communication with the
22 corps commanders; is that correct?
23 A. Every point in time he had the possibility of having direct
24 communication with his subordinate commanders.
25 Q. Did he do that by using any special system?
Page 25097
1 A. No. It was a very ordinary Iskra switchboard, and when he'd
2 press a button without dialling a dial, he could communicate with the
3 commanders when they were at the headquarters of their respective corps.
4 Q. Just for those people who don't quite understand what Iskra
5 means, maybe you could explain. I'm sorry about that.
6 A. It's the make, the manufacturer from Slovenia that was called
7 Iskra, from the town of Kranj.
8 Q. Thank you. Now, how often or was there a routine to how often
9 General Mladic would speak with the corps commanders? Did he do it every
10 day, every second day?
11 A. Well, I cannot speak about each and every day specifically.
12 Perhaps every afternoon towards the end of the day.
13 Q. And similarly, do you have any idea how often he might speak with
14 forward command posts?
15 A. I cannot answer that, because I was not there sitting with the
16 commander, so I cannot -- I mean, it's someone who was with him all the
17 time that could answer that.
18 JUDGE KWON: What forward command post did you mean,
19 Ms. Edgerton?
20 MS. EDGERTON: Sorry, Your Honour. I was referring to those that
21 the general had mentioned shortly before we broke, and I'll just, with
22 your indulgence for a second, scroll back up to see the reference.
23 I'll clarify. The reference was at page 77, line 7.
24 Q. In the event one of the assistant commanders was deployed to a
25 forward command post for a particular operation, do you have any idea how
Page 25098
1 often General Mladic would be in contact with the assistant commander?
2 A. I can speak specifically about the point in time when I was at
3 the western front, Jasenica and Drvar. Usually when this assistant
4 commander would return from the field, reports would be written once they
5 were received from units, and they would be formulated so as to be sent
6 to the Main Staff. The commander would sometimes call the forward
7 command post via safe communication equipment the commander, in this
8 specific case, General Milovanovic, and ask about the situation in that
9 particular area.
10 JUDGE KWON: I'm sorry to interrupt you so often, but let me be
11 clear. To understand the meaning of deployment, what I understood from
12 your evidence, General, is that assistant commander can be sent out to
13 field. For example, to monitor or to control whatever, and then he can
14 use the facilities in the forward command post to communicate with his
15 commander. Am I correct in so understanding?
16 THE WITNESS: [Interpretation] Yes. The forward command posts
17 were established with a view to having direct insight into and influence
18 over combat operations. At these forward command posts, all types of
19 communications are organised like at basic command posts, except that
20 they're on a smaller scale.
21 I specifically spoke about the time when I was at the western --
22 JUDGE KWON: Then were you said to be deployed at that specific
23 forward command post?
24 THE WITNESS: [Interpretation] Yes.
25 JUDGE KWON: Yes, Ms. West -- I'm sorry, Ms. Edgerton.
Page 25099
1 MS. EDGERTON:
2 Q. This system you've just spoken about for communication with the
3 corps commanders where General Mladic would press a button, was that a
4 protected means of communication, free from interception?
5 A. We believed that it was a protected means of communication, but
6 how protected it actually was, I don't know.
7 Q. Now, just in terms -- or still on the subject of communication
8 with assistant commanders, would the Main Staff have briefings? Would
9 the Main Staff sectors and administration heads depicted in that
10 organigramme gather for briefings with the commander?
11 A. At certain points in time when necessary and when the commander
12 would ask for such a meeting, yes. Within the sector and other sectors
13 within their own sectors, we had meetings every morning discussing our
14 work.
15 Q. Do you know how often the inner circle of the command, if I can
16 call it that, would meet to discuss issues?
17 A. I cannot say. Probably they were held often without my being
18 aware of it. It's very few people involved. At some office, at the
19 commander's ...
20 Q. I think the last part of your answer wasn't heard. What I see
21 you've said is, "At some office, at the commander's." Would you like to
22 add to that?
23 A. Well, either at the commander's or in one of offices of one of
24 the assistant commanders or of the Chief of Staff or the assistant for
25 morale, logistics, et cetera. These are six or seven people plus the
Page 25100
1 commander.
2 Q. The Main Staff's daily combat reports, those sent to --
3 particularly those sent to the supreme commander and the corps commands
4 that you discussed in your Tolimir testimony, how frequently were those
5 sent?
6 A. The daily operative combat reports were sent as follows: One for
7 the preceding 24 hours, that is to say it pertained to the 24 hours that
8 had elapsed. These are regular reports, whereas extraordinary reports
9 were sent when necessary, and in that way subordinate units reported to
10 the command, the Main Staff, about the situation in their respective
11 areas of responsibility, that is to say about the enemy, about their own
12 forces, about neighbours, and about decisions taken by commanders, and of
13 course they pointed out what the requirements and needs of their corps
14 were.
15 Q. So reports were sent to the supreme commander on a daily basis.
16 Do I understand correctly?
17 A. Yes.
18 Q. Would the supreme commander also be sent extraordinary reports
19 when necessary?
20 A. If an extraordinary report would arrive from a corps, we would
21 incorporate it into the next one, or if there was something important --
22 well, I did not have that kind of a situation that in my presence an
23 extraordinary report would be sent especially to the commander and to
24 other corps. For the most part, they were sent all together.
25 Q. Were they transmitted by secure means?
Page 25101
1 A. They were transmitted through secure means, encrypted.
2 THE ACCUSED: [Interpretation] I believe we should intervene in
3 the transcript. The witness said to the Supreme Command, not to the
4 supreme commander.
5 JUDGE KWON: Very well. Could you clarify, General Obradovic?
6 THE WITNESS: [Interpretation] We sent reports to the
7 supreme commander. We addressed them to the supreme commander. However,
8 they went also to the Ministry of Defence, to the president of the
9 Assembly, the prime minister, and the minister of the interior, as well
10 as to the forward command posts and all corps commands for their
11 information so that they would be informed of the situation in the entire
12 theatre of war.
13 Now, here the question was about these extraordinary or interim
14 reports. I did not take part in any forwarding of such reports, and that
15 couldn't be the case anyway before the Chief of Staff was informed of it,
16 because this interim report was meant to be resolved, so if it was
17 resolved by the chief of staff then there was no reason for it to be sent
18 to the Supreme Command. That would depend on the contents of the interim
19 combat report.
20 MS. EDGERTON:
21 Q. In what way?
22 A. Well, whether the information that was contained in the interim
23 combat report was of interest to the Supreme Command or whether it was
24 just of relevance to the Main Staff.
25 Q. Just one question relating to your earlier answer: How do you
Page 25102
1 know that these reports were sent to the minister of defence, the
2 president of the Assembly, the prime minister, and the minister of the
3 interior?
4 A. Well, I know because at one point in time all of these instances
5 were mentioned in the address block, and then it would say to the command
6 of subordinate units.
7 Q. Would the assistant commanders also receive copies of these
8 reports?
9 A. No. They were not addressed to them unless they were at the
10 forward command post, and then they would receive it as the corps command
11 for the entire -- a bit of information for the entire theatre of war.
12 Q. Now, in addition to these written reports, do you know whether
13 the commander or other members of the Main Staff had meetings with
14 Dr. Karadzic?
15 A. Well, I assume that they did, but I can't really say with
16 certainty. If there was a meeting of the Supreme Command and if
17 representatives of the Main Staff were invited to that meeting, then they
18 would be there; if not, they wouldn't. But I don't know. I don't have
19 information to that effect.
20 MS. EDGERTON: Your indulgence for just a moment, please,
21 Your Honours.
22 Q. General, hearing your answer to that question, I thought I might
23 turn to a transcript of your evidence given when you appeared as a
24 Defence witness in the Popovic case, and I see at page 28244 you were
25 asked by Mr. Petrusic:
Page 25103
1 "General, do you have any knowledge whether the representatives
2 of the command of the Main Staff have meetings with the civilian state
3 leadership of the Republika Srpska, the government of the
4 Republika Srpska?"
5 And your answer was:
6 "Yes."
7 Do you remember that question and that answer?
8 A. Yes, I do, and I think it had to do with -- it was within the
9 context of an analysis of combat readiness, and when such analysis were
10 discussed, then there would be political representatives attending.
11 Q. Thank you. I'll leave that for the moment but come back to it in
12 due course.
13 THE ACCUSED: [Interpretation] Could we get the reference again
14 for that transcript page from the Popovic case?
15 JUDGE KWON: It's on the transcript. It says 28244.
16 THE ACCUSED: [Interpretation] Is it correct? Could you please
17 help with us a line citation?
18 MS. EDGERTON: Of course. Lines 1 to 6.
19 THE ACCUSED: [No interpretation]
20 MS. EDGERTON:
21 Q. In addition to these written reports and the meetings you've just
22 referred to, did General Mladic or other members of the Main Staff have
23 direct telephone contact with Dr. Karadzic?
24 A. They did have a communication line. Now, whether it was a direct
25 line or whether they had to use the PTT lines, I don't know, but they
Page 25104
1 were at Pale.
2 Q. And just to go back to those written reports for a moment before
3 moving forward, you indicated that they were sent by secure means. Would
4 that imply that all the recipients would have had some way of protecting
5 that information or decoding that information at the other end?
6 A. I don't think so. I think it was printed out at one spot and
7 then from there it was disseminated to other addresses, taken there.
8 Q. When those reports were sent to Pale, to the supreme commander,
9 where would they be sent to and what then would happen to them next?
10 A. I don't understand your question.
11 Q. Well, you just said that they were printed out at one spot and
12 from there it was disseminated to other addresses. So my question is:
13 What was the spot at Pale they were printed out at?
14 A. It was the seat of the government. They would have had to have
15 some kind of communication unit that would have encryption equipment, and
16 then once it was printed out it would be done at that one spot because
17 not every minister would have one of these encryption machines.
18 This is my assumption. I don't know exactly how it worked, but I
19 assume they don't have so many -- they didn't have so many encryption
20 devices there.
21 Q. All right. Now just a question again about communications.
22 Based on your field experience that you talked about in your Tolimir
23 testimony where you were deployed to the command post at the western
24 front, did Dr. Karadzic have direct contact with the assistant commander
25 on that occasion or during that period because it was a lengthy
Page 25105
1 deployment?
2 A. Your Honour, in the Tolimir case I spoke about the general
3 practice, which was that at the forward command post, they would have
4 communications established towards the Main Staff and other points, but I
5 wasn't present to witness possible communications between
6 General Milovanovic and the president.
7 Q. These reports that were disseminated, I think you would agree,
8 were of a very detailed nature; correct?
9 A. Well, they were lengthy.
10 Q. Could the president issue orders based on the information in
11 those reports?
12 THE ACCUSED: [Interpretation] My remark was that this was a
13 leading question, and it did not make it into the transcript. That was
14 my prior remark to the previous question.
15 JUDGE KWON: You mean lengthy?
16 THE ACCUSED: Line 13. No detailed nature. The previous
17 question in interpretation I received that it was a leading question:
18 You would agree, wouldn't you, that they were of a very detailed nature;
19 correct? The question should have been: Were they detailed?
20 JUDGE KWON: Let's proceed. The witness answered anyway.
21 Ms. Edgerton, I was looking at the previous set of question and
22 answer. You mentioned a communication with assistant commander, but the
23 general spoke about General Milovanovic.
24 MS. EDGERTON: I apologise for not naming him.
25 JUDGE KWON: Were you satisfied with his answer?
Page 25106
1 MS. EDGERTON: Yes.
2 JUDGE KWON: Very well. But I take it General Milovanovic was
3 not one of the assistant commanders.
4 MS. EDGERTON: Perhaps I could ask the question to the witness.
5 JUDGE KWON: Yes. Yes.
6 MS. EDGERTON:
7 Q. General, when I referred to communications with the assistant
8 commander during your deployment to the western front, did you understand
9 me to be referring to General Milovanovic?
10 A. Yes, because I was at a forward command post only where -- in a
11 situation where he was the leading commander there, and per
12 establishment, he's also the deputy commander.
13 Q. And within the Main Staff, within the corps of the Main Staff,
14 did General Milovanovic have the designation "assistant commander"?
15 A. Well, generally speaking, the chief sector, the staff chief of
16 sector for logistics, for moral guidance, for personnel, security and
17 intelligence and these two independent administrations, planning,
18 development, and finance, and air force and air defence, they were
19 referred to as assistant commanders. However, General Milovanovic per
20 establishment was the Chief of the Main Staff, and at the same time he
21 was the deputy commander.
22 Q. Thank you. To move back to these reports that we've been
23 discussing, could the president issue orders based on the information
24 contained in these reports?
25 A. The contents of the report would not be the decisive factor in
Page 25107
1 whether the president would order it or not. He had the discretion to
2 bypass the Main Staff, but how it went, I don't know the details. But
3 generally speaking and under the rules of service, the second-in-line
4 commander could issue an assignment to the second subordinate, and he
5 could say that he received such and such a task from the second in
6 command.
7 Q. Could you just explain for us, please, second-in-line commander,
8 what you mean by second-in-line commander and second subordinate? It
9 might be easier to do that by reference to their titles.
10 A. For instance, let's take the 1st Krajina Corps. The commander of
11 the 1st Krajina command -- Krajina Corps has as the first superior the
12 commander of the Main Staff, and his second in command is the supreme
13 commander. In other words, the supreme commander can issue an assignment
14 to the 1st Krajina Corps, but the commander of the 1st Krajina Corps
15 would have to inform of that his immediate superior, in other words, the
16 commander of the Main Staff, that he had been issued such and such an
17 assignment or a task from the supreme commander.
18 Now, whether there were such instances of bypassing the immediate
19 superior within the chain of command, I don't know, but I just talked
20 about this as general possibilities within the rules.
21 Q. Even if the immediate superior had been bypassed in the issuing
22 of an order by the president, would the recipient of that order
23 nevertheless be duty-bound to comply with it?
24 A. Well, that's just what I've tried to explain. He is duty-bound
25 to implement that order, but at the same time, he would have to report
Page 25108
1 immediately to his immediate supreme -- to his immediate commander of
2 this assignment.
3 Q. Thank you. I'd like to actually look at a document, please,
4 65 ter 07514. It's an order dated 24 April 1994, from Dr. Karadzic to
5 the Main Staff, the commander, and the Chief of Staff personally, and
6 members of the Main Staff, and corps commanders for information,
7 responding to their report.
8 Now, General, I know you've seen this document the day before
9 yesterday in preparation for your testimony today, but because it's a bit
10 of a lengthy one, I wonder if you could take a few minutes to go through
11 the couple of pages that it is and tell us when you've had a chance to
12 have a look at it. And could you make the English side a little bit
13 smaller, please, so we can see the full page, if you can.
14 If you can scroll down just a little bit now.
15 Do you remember seeing this in preparation for your testimony
16 here today, General?
17 A. Yes.
18 Q. Can we go over now to the next page of this document.
19 Now, General, this document refers to a number -- or this order
20 refers to a number of things, including a withdrawal of forces of the
21 Army of Republika Srpska, the disposition of heavy weapons, the equipping
22 and disposition of mobile weapons, and the consolidation of positions.
23 On receiving such an order, would the Main Staff then normally
24 issue further orders and communications to subordinate units?
25 A. Could we please go back to page 1. In this order we see that the
Page 25109
1 addressees are the Main Staff of the VRS, and then to the commander and
2 Chief of the Main Staff personally, and then on line 3, it says:
3 "For information to members of the Main Staff and all corps
4 commanders."
5 In other words, this order makes it obligatory to the Main Staff
6 to inform thereof the most responsible members of the Main Staff and the
7 corps commanders of this order. I don't know exactly when this was. I
8 see that it is dated the 24th of April, 1994. I was not in the
9 Main Staff then, so I don't know whether it was sent in writing or how it
10 was communicated, but the command of the Main Staff was duty-bound to
11 implement it.
12 Q. Now, if we could just go down to paragraph 3 of this document
13 that refers to convoy movement and the instruction that these convoys
14 will be authorised by --
15 A. I can't see that part.
16 THE ACCUSED: [Interpretation] In Serbian that should be on
17 page 2.
18 MS. EDGERTON: Is there anyway of --
19 THE WITNESS: [Interpretation] Yes. Now I can see it.
20 MS. EDGERTON: Is it just me or is there anyway we can have the
21 English as well as the B/C/S version, because -- thank you.
22 JUDGE KWON: Third page.
23 MS. EDGERTON:
24 Q. Now, do you see the line at the bottom of the third paragraph
25 that says:
Page 25110
1 "... these convoys will be authorised by a co-ordinating body,
2 and the Main Staff of the Army of Republika Srpska will be kept
3 informed"?
4 A. Yes.
5 Q. Now, I want you to recall in your Tolimir testimony at
6 page 12022, you explained that -- you explained the process for requests
7 for convoy movement by UNPROFOR and international humanitarian
8 organisations and you said that all convoy requests were received by fax
9 in the department headed by Djurdjic, and he took them to the commander
10 for approval. It was up to the commander to approve these requests or
11 not to approve them.
12 So I'm wondering, actually, how this document and mention of the
13 co-ordinating body fits with your explanation about the processing of
14 convoy requests within the Main Staff?
15 A. The UNHCR convoys and UNPROFOR convoys were the types of convoys
16 that existed. UNPROFOR was -- was a peacekeeping military formation,
17 whereas the UNHCR was humanitarian aid, and it was approved by the
18 co-ordinating body.
19 Q. So then what was the relationship between the co-ordinating body
20 and the department for civilian affairs within the Main Staff?
21 A. This co-ordinating body informed by fax which convoys and along
22 which routes and what their destination was were approved and -- or
23 whether they were not approved. And as for the UNPROFOR supply convoys,
24 approval for them came from the army.
25 MS. EDGERTON: Do you know who was in charge of this
Page 25111
1 co-ordinating body?
2 A. Well, I've already said that I believe Professor Koljevic was.
3 I'm not absolutely certain, but I think it was him.
4 MS. EDGERTON: Could this be a Prosecution exhibit, please,
5 Your Honours.
6 JUDGE KWON: Yes.
7 THE REGISTRAR: Exhibit P4447.
8 THE INTERPRETER: The Registrar is kindly requested to repeat the
9 number.
10 THE REGISTRAR: Exhibit P4447.
11 MS. EDGERTON: Thank you.
12 Q. Could we go to another document related to convoy movement,
13 65 ter 03512. It's correspondence from the VRS Main Staff to the
14 Sarajevo-Romanija Corps and Drina Corps command dated 6 March 1995. This
15 document informs the corps commands of convoys which have been approved
16 and instructs them to inform the check-points in order to prevent
17 unapproved movement.
18 Now that we've got the document on the screen in front of us,
19 General, I'd actually like us to go to the signature block on the very
20 last page, please.
21 Now, General, this document has got General Miletic's signature
22 block, and just above that is a line that reads in your language "zastupa
23 nacelnika staba," which I understand means "standing in for the Chief of
24 Staff"; is that correct?
25 A. That is what it should mean. However, during my previous
Page 25112
1 testimonies, I did say that I have never seen an order on this kind of
2 standing in. There was no need for that because the Chief of Staff was
3 never absent from the territory of Republika Srpska. Perhaps this was
4 just incorrectly written. However, a stand-in commander would have all
5 the powers that the office that he represents should have.
6 Q. How -- could you -- because we looked at a large number of
7 documents issued or signed by General Miletic in this way the day before
8 yesterday, I wonder if you could explain in a little bit more detail this
9 term "standing in," and perhaps in that regard I could just ask you one
10 question. What kind of circumstances -- in what kind of circumstances
11 would someone be asked to stand in for a commander?
12 A. The commander has to have someone to stand in for him if he is
13 prevented from carrying out his duties for a certain period of time. An
14 order has to be written on having a person stand in for the commander in
15 this way, and that is in accordance with the Law on the Army. A person
16 who also has to stand in commander, in addition to his regular duties,
17 has all the authorities and powers of the position that he is in as a
18 standing commander, measures of reward, repression, everything.
19 Here, specifically, General Milovanovic is present in the area of
20 responsibility of the Army of Republika Srpska. He probably did give
21 some kind of authority, but he should not have said "zastupa." It should
22 have said "for the Chief of Staff" or "in accordance with the order of
23 the Chief of Staff." As far as I know, no such order was ever written,
24 and General Miletic did not have the powers that the Chief of Staff has.
25 He could sometimes tell him to organise something within the work of the
Page 25113
1 staff sector, but not both of them could have the powers of the Chief of
2 Staff, and they are -- and they are present there.
3 Q. So then in this context, what kind of freedom of action would
4 General Miletic have?
5 A. What the Chief of Staff would give him, tell him, that he should
6 stand in for him in some domains of his work, but he would certainly not
7 transfer all authority to him.
8 If you remember my CV, it says at some point in time, in addition
9 to being the Chief of Staff of the 327th Brigade, I also stood in for the
10 commander in his position two times during six-month periods, and I
11 enjoyed all benefits then, the benefits and everything that is given to a
12 commander.
13 Q. So in this context, in General Miletic's context, do I understand
14 you to be saying he's limited by directions he receives from the Chief of
15 Staff?
16 A. Yes.
17 Q. Now, in the process of convoy requests, review and approval that
18 you described in your Tolimir testimony, at what point would a direction
19 like this to the corps have issued? And I wonder if we could go back to
20 the first page in both languages, please. Top of the page in B/C/S.
21 What -- in other words, what happens to a convoy request before a
22 document like this issues?
23 A. Your Honours, this department for civilian affairs that is
24 attached to the commander as it says here, they receive fax messages.
25 Now, whether they are weekly -- I mean, are requests submitted weekly or
Page 25114
1 does it happen every time a convoy is supposed to pass, then
2 Colonel Milos Djurdjic, the head of this department, would collect all of
3 these requests and go to see the commander. The commander would look at
4 all of them together with him, and then perhaps he could say a few things
5 to him in relation to that activity, because that is the only thing that
6 he did, that Djurdjic did. And the commander on the margin of these
7 faxes wrote that he approved of this or that he imposed certain
8 restrictions with regard to the passage of convoys.
9 When they would go through all these documents, then the other
10 man would go back to the department and write up this kind of document.
11 This was open communication. That is what it says up here, above
12 Sarajevo-Romanija Corps. And then when he would write that information
13 that had to do with the mentioned units, then since the Chief of Staff
14 would not be there, then he would go to General Miletic for him to sign
15 it because his right was to communicate with subordinates just in that
16 way. He could sign this information, only Colonel Djurdjic did not have
17 this kind of authority.
18 Q. Just two questions, quick questions about the -- a couple of
19 notations on the document.
20 First of all, the number that appears above the date, number
21 06/18-104, does that number designate anything in particular?
22 A. I think that that's the number of the log-book of Djurdjic's
23 department.
24 Q. And what about the first number, 06? Does that mean anything in
25 particular?
Page 25115
1 A. That is a designation of the department. I don't know exactly
2 now. I cannot remember right now.
3 Q. And if we can just --
4 A. So if you look at this total number, 104, you see, 106/18, that
5 is the department. And then -104, that is the 104th number in the
6 log-book. So it was registered under that number.
7 Q. Thank you. If we can just display the handwritten notes. At the
8 top of the page for the General. Right there.
9 General, what do those handwritten words Bresa, Domar, and Caura
10 mean?
11 A. These are code-names of brigades that are the addressees to whom
12 this document is being sent. These are code-names, secret names.
13 Q. And finally, can we just go down to item 5 on this list in both
14 languages, please.
15 The last question on this document, General. Could you have a
16 look at item 5 on this list and tell me whether you see any military
17 reason for the Main Staff to be concerned with the passage of a convoy
18 between Sarajevo and Kiseljak, the one listed here, which was to supply
19 drinks, suites, and potato chips for the canteen.
20 A. I cannot say. It has to do with provisions for the canteen, and
21 that is a military catering facility.
22 MS. EDGERTON: Could I have this document as a Prosecution
23 exhibit, Your Honours?
24 JUDGE KWON: Yes.
25 THE REGISTRAR: Exhibit P4448, Your Honours.
Page 25116
1 MS. EDGERTON: Your Honours, I would next move into one more
2 document which would take probably more time than we have. I'll do
3 whatever I'm instructed, but I was just having a quick look at the clock.
4 JUDGE KWON: We'll adjourn for today. We resume tomorrow morning
5 at 9.00, General Obradovic. Oh, yes, we are sitting, because of some
6 certain circumstances, we will resume at 1.30.
7 Probably you are aware of this, but you are not supposed to
8 discuss with anybody else about your testimony. Do you understand that,
9 sir?
10 THE WITNESS: [Interpretation] Yes, I do.
11 JUDGE KWON: The hearing is adjourned.
12 --- Whereupon the hearing adjourned at 2.59 p.m.,
13 to be reconvened on Thursday, the 23rd day
14 of February, 2012, at 1.30 p.m.
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