Page 32494

 1                           Wednesday, 23 January 2013

 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, everybody.

 7             Good morning, Mr. Harvey.

 8             MR. HARVEY:  Good morning, Mr. President.  And may I say it's a

 9     pleasure to see Judge Lattanzi restored to us.  And may I introduce,

10     please, Kalin Stoyanov from Bulgaria, a law student here at The Hague who

11     has been with my team since October of last year.  Thank you.

12             JUDGE KWON:  Thank you.

13             Yes, Mr. Karadzic.  Please continue.

14             THE ACCUSED:  Good morning, Excellencies.  Welcome, Honourable

15     Judge Lattanzi. [Interpretation] Good morning to all.

16                           WITNESS:  DRAGOMIR MILOSEVIC [Resumed]

17                           [Witness answered through interpreter]

18                           Examination by Mr. Karadzic:  [Continued]

19        Q.   [Interpretation] Good morning, General, sir.

20        A.   Good morning.

21        Q.   Can you please tell us where you were when the war broke out in

22     Slovenia and Croatia.  Where were you and what was your post?

23        A.   Well, I've just understood.  I wasn't in Slovenia when the war

24     broke out.  I was in another area when the war started in Slovenia.  I've

25     just now understood what you are asking.

Page 32495

 1             When the war broke out in Slovenia and Croatia, I was in the area

 2     of Bosnia-Herzegovina, in Han Pijesak.  I was brigade commander, of

 3     course.

 4        Q.   Which brigade was that?

 5        A.   This was the 216th Mountain Brigade.  It belonged to the

 6     4th Sarajevo Corps, and it was part of the then new system to the

 7     2nd Military -- it was part of the 2nd Military District.

 8        Q.   Thank you.  And you mentioned some difficulties in mobilisation

 9     yesterday, so we can skip that, but if you can just briefly tell us how

10     the mobilisation proceeded in 1991, and how did the first mobilisation

11     proceed and then the second one?

12        A.   I don't remember talking about problems.  I just said that the

13     brigade was mobilised.  Therefore, yes, that is correct.  As for this

14     second part about problems, that is even more correct, I mean now that I

15     hear it this morning.

16             The brigade that I was in command of comprised 50 per cent of the

17     Muslim population and 50 per cent of the Serb population.  So it was a

18     very rational structure, and it corresponded to the place, the area, that

19     was -- that the troops were being drawn from.  It was an excellent unit,

20     and it was a good system until the -- the system of mobilisation or

21     gathering the men broke down.  The structure worked very well both as far

22     as the civilian structure was concerned and as far as the military

23     conscripts who manned the brigade.  It all functioned very well.  It was

24     a very broad area around Srebrenica, Zvornik, Kladanj, Olovo, Rogatica,

25     Sokolac, Han Pijesak.  That was the territory that was being mobilised

Page 32496

 1     and where we drew our forces from.

 2             And then on the 30th of June, 1991, an order was issued on the

 3     mobilisation of the brigade, and then both -- members of both ethnic

 4     groups responded to the call-up, the Serbs and the Muslims.  However, in

 5     the meantime, the Bosnia and Herzegovina leadership, in this case the

 6     Muslim part, issued instructions to their soldiers and to their

 7     population, their people, not to respond to the mobilisation, and then we

 8     had the situation in which I concluded actually these same soldiers were

 9     the ones who most regretted that this had happened.  Some did obey that

10     instruction or order.  Many of them did not.  So then there was a very

11     difficult situation then for the survival of the brigade in that

12     composition and also as far as the possibility of engaging the brigade in

13     any kind of capacity.  These conscripts, these soldiers, did not create

14     any problems other than not responding, and those who did respond were

15     loyal.  Their conduct was normal.  They could see that everything was all

16     right.

17             Later this escalated, so then a selection was made later so that

18     later all of them left the unit and did not respond to the call-up any

19     more for the brigade and that was it.

20        Q.   I would like to ask you to give as brief answers as possible,

21     although it's good to hear it all, but we do have a limited amount of

22     time at our disposal.

23             Who was authorised to order the mobilisation, and who issued the

24     mobilisation order in June 1991?

25        A.   I know who issued the order to me, but who issued the order to

Page 32497

 1     them is something that I cannot confirm.  I was given the order by the

 2     corps commander.  There was a written order issued, and then the

 3     mobilisation got underway, that procedure got underway.

 4        Q.   And the Presidency of Bosnia-Herzegovina, was it in its full

 5     composition or was it the Rump Presidency, but did it have the authority

 6     to issue the mobilisation order?

 7        A.   Well, it was a matter for the Yugoslav People's Army.  So it

 8     wasn't the Territorial Defence that was being mobilised, but it also

 9     belonged to the whole of Yugoslavia, like the army did.  So I assume that

10     they did not have the authority to do that, because they interfered.  And

11     I know who they mobilised.

12        Q.   Thank you.  And who was your deputy?  Who was the Chief of Staff

13     of the brigade?

14        A.   Well, the question is very specific.  It is not just who was my

15     Chief of Staff, if you permit me to say.  The Chief of Staff specifically

16     was Lieutenant-Colonel Asim Dzambasovic [Realtime transcript read in

17     error "Dzambasevic"].  However, the structure of the command, I would

18     say, was absolutely multi-ethnic, and the chief of security was a

19     Slovenian.  The main operative officer was a Muslim.  The chief of the

20     technical service was Hungarian.  It was a wonderful structure.  It was a

21     team that one could work with absolutely.

22        Q.   Thank you.  And can you please tell us how long these people

23     stayed in the unit?  When did Dzambasovic leave and when did the

24     Slovenian and Hungarian leave and so on and so forth?

25        A.   Lieutenant-Colonel Dzambasovic belonged to the type of people who

Page 32498

 1     were reasonable, educated, trained in the military sense, and he was just

 2     a normal man to work with and to co-operate with.  I cannot specify

 3     exactly when he left.  I cannot give you the date, but it was in that

 4     initial period.  Actually, no, no.  It was in 1992, 1992.  If I'm not

 5     mistaken, it was in late 1991, early 1992.  He asked in regular channels

 6     to leave to go to the corps command, to go and report to the corps

 7     commander and to see with him what would happen afterwards.  I provided

 8     him with a vehicle.  I provided him with staff to transport him.  So it

 9     was a relationship of a civilised nature between people who respect each

10     other.

11        Q.   Thank you.  And where were you and the unit when the conflict

12     broke out in Bosnia-Herzegovina, and what happened with the unit while it

13     was still part of the JNA?

14        A.   In view of the fact that this is a bit detailed to say where it

15     was, I mean, it was in a number of places on a wide area, and in the

16     context of the whole situation, at the point in time when the conflict

17     became more serious and before we realised that the conflict would

18     escalate, the brigade was in the Mesici sector.  This is close to the

19     Drina River.  Raca or Praca and Visegrad, that's where we were, and we

20     waited for a solution.

21        Q.   And how did the brigade find itself in Sarajevo, on whose orders,

22     and where was it deployed, and what were its tasks?  It's a complex

23     question, but I know that you will give us a detailed answer in any

24     event.

25        A.   As I already said, the brigade was in the Drina River Valley, in

Page 32499

 1     the area from Mesici to Visegrad.  Along the depth it was in Rogatica

 2     sector and so on and so forth.

 3             At the point in time when - how shall I put it? - the escalation

 4     occurred or events that had to do with pulling out the column of the

 5     2nd Military District command from Sarajevo and from the Bistrik area,

 6     that's when the situation began to become complicated.  I had the

 7     impression that the corps commander made an assessment that the brigade

 8     should come to Sarajevo probably in order to assist in the withdrawal of

 9     the forces of the 2nd Military District.

10             I'm not going to go into that.  If somebody's in command, they

11     know what their criteria are, and by getting there there was no way that

12     we could help in any way this command of the 2nd Military District, even

13     if we had helicopters and parachutes.

14             So the brigade reached the Lukavica sector.  The situation was

15     underway with this column from Sarajevo.  It was in progress.  The column

16     was cut in half.  They fired at those people, and a part of the column --

17     I heard all of this, and I could see that it was going on.  I could hear

18     that it was going on.  I couldn't see it.  And then those who were

19     wounded or killed there, nobody could help them, and those who in the

20     meantime had managed to get out, they just said what had happened.  And

21     my brigade happened to be in the staging area in Lukavica without any

22     fire.

23        Q.   Thank you.  And where was this brigade deployed later, and what

24     happened to it when the JNA withdrew?

25        A.   The brigade was deployed in the Grbavica sector, a part of

Page 32500

 1     Lukavica, to Vraca and then up there the area below mount Trebevic or

 2     close to Trebevic.

 3        Q.   And was the Jewish Cemetery also in the area of responsibility of

 4     the brigade, Bosut and the Jewish Cemetery?

 5        A.   Yes, yes.  Bosut is a military facility, and it's a

 6     communications centre.  It's a building with all the equipment and

 7     installations inside.  There's no staff or personnel to defend it.  Of

 8     course, the area of Bosut was supposed to be secured.  I received an

 9     order to deploy a part of the forces to protect Bosut.

10        Q.   Thank you.  And what happened with the brigade when the JNA

11     pulled out and when the Sarajevo-Romanija Corps was formed?

12        A.   I went through the situation, because the cadres, the personnel,

13     the officers who were in the brigade had come from all over Bosnia and

14     Herzegovina and from outside of Bosnia and Herzegovina.  They were

15     permitted to pull out and go back to Serbia or Montenegro, to that

16     territory.  I personally felt that there would be some difficulties and

17     problems, considerable problems.  However, we managed to deal with that

18     by additionally engaging the existing cadre so that the command

19     continuity of the forces could be maintained, and we adapted the

20     structure to the given situation, to the conditions, and to the system of

21     command which was possible to apply at the time.

22        Q.   Did the brigade change its name, and did its area of

23     responsibility change?

24        A.   Yes.  The brigade was renamed after the divisions, and it was

25     called now the 1st Romanija Brigade and was part of the

Page 32501

 1     Sarajevo-Romanija Corps.  And my apology, I'm not sure I heard your

 2     second part of your question.

 3        Q.   Well, the area of responsibility, did that change?

 4        A.   No.  The area of responsibility remained as it was at the outset

 5     when we arrived there.

 6        Q.   How many battalions did you have?

 7        A.   Well, as I've said, the -- the team or the group, the entire

 8     unit, was a wonderful unit.  You could use them in very difficult

 9     situations.

10             The brigade was left without some battalions that had remained in

11     the area, for instance, in Vlasenica.  The brigade had two battalions,

12     but we started a new recruitment procedure, mobilisation, from Sarajevo

13     and Lukavica so that we replenished -- rather, brought up the personnel

14     and manpower level to three battalions, and it existed in this form for a

15     while.  That's how it [indiscernible], but later on it grew and became a

16     little bigger, and it was active in the wider area of Sarajevo.

17        Q.   Thank you.  Can you tell us when you arrived, what did you find

18     there?  With units in terms of the municipality, the area there,

19     territorial units, what did you find?  What situation did you find, and

20     what happened with those units?

21        A.   Yes.  Well, they reported to me, and I had contact with them as

22     well.  This was a brigade that was called the Novo Sarajevo Brigade of

23     Territorial Defence, and when the name Territorial Defence was lost, then

24     it was just called the Novo Sarajevo Brigade, and it remained as part of

25     the defence of the Republic of BH as a whole.

Page 32502

 1             Now, as far as I can remember, the commander of the brigade was

 2     Mr. Garic.  He was a reserve officer from the area itself.  They had two

 3     battalions, that was their structure, and they explained to me where they

 4     were.  And the third battalion was on the other side in Pofalici.  In

 5     other words, behind the Marsal Tito Barracks, on the slopes of the area

 6     that gravitates towards Sarajevo.

 7             I asked him whether they were able to command that battalion,

 8     because there was already an obstacle between them.  They had no contact

 9     except for radio contact, and they said, Yes, we can maintain contact

10     with them.

11             This battalion later had a disaster met -- a disaster of sorts,

12     not the battalion itself but the people.  There was a raid and an

13     incursion of certain forces from Sarajevo and these people were

14     massacred.  And that brigade, Garic's brigade, could no longer count on

15     any help from that battalion, but, rather, should rely only on the forces

16     that were on the southern side.

17        Q.   Thank you.  The Territorial Defence structure that you found when

18     you got there, was it in keeping with the Law on All People's Defence and

19     Social Self Protection or was it a paramilitary force of sorts?

20        A.   No.  As long as it was Territorial Defence, of course, it

21     couldn't be a paramilitary force.  It was structured and formed on the

22     basis of the regulation that were in place and they existed as such.

23        Q.   Thank you.  General, sir, how long did you remain in the post of

24     commander of the 1st Romanija Motorised Brigade, and where did you go

25     from there?

Page 32503

 1        A.   I was commander of that brigade until the end of 1992, but more

 2     accurately, what -- I left the brigade and I happen to recall this by

 3     chance, I left on the 4th of February, 1993.  I remember that, because

 4     that was my birthday.  So I left the brigade and handed over the command

 5     to the Chief of Staff, Lieutenant-Colonel Savcic, and I went to the

 6     Drina Corps where I was the Chief of Operations of the corps.

 7        Q.   Thank you.  Did you return at any point to

 8     Sarajevo-Romanija Corps?  If so, when and to what position?

 9        A.   That's nicely put, when did I return, but please bear with me,

10     but it would be probably better to say I -- it would have been better if

11     I had not returned, but perhaps then you won't take me seriously.

12             Well, I returned toward the end of June 1993.

13        Q.   And to what position were you assigned?

14        A.   I was the Chief of Staff of the Sarajevo-Romanija Corps.

15        Q.   How long did you remain in the Sarajevo-Romanija Corps, and what

16     positions did you fill?

17        A.   Well, from early July 1993, I was the Chief of Staff in the corps

18     up until August 1994, more specifically until the 10th of August, when I

19     was appointed corps commander, and I remained in that post through the

20     end of 1995 and early 1996.

21        Q.   Can I take it that as the second person and then the first man of

22     the Sarajevo-Romanija Corps as of July 1993 up until the end of war, your

23     adversary was the 1st Sarajevo Corps of the BH Army?

24        A.   Well, your question is good, but it wasn't that I had an

25     adversary.  It was the Sarajevo-Romanija Corps that had on the other side

Page 32504

 1     the 1st Corps of the Army of Bosnia and Herzegovina.

 2             It's very important for me to point out at this point that these

 3     were two armed forces that were well acquainted with one another.  I

 4     would say they were acquainted in detail.  Neither me nor my command or

 5     my superiors never -- we never thought or were deluded thinking that the

 6     adversary didn't know us, didn't know much about us.  Well, in the same

 7     manner we knew very well what their strategy would be, what their

 8     employment would be, their activities.  I would say that we knew it to

 9     the last little detail, because this was the same people.

10        Q.   Does that imply that you also knew the deposition, the deployment

11     of forces, the weapons that they had, the infrastructure?  And I'm asking

12     you about the entire 1st Corps of the Army of Bosnia-Herzegovina.

13        A.   Well, you cannot command successfully unless you are very

14     familiar with your enemy, and I can confirm here that the deployments,

15     the engagement, the combat fighting, the objectives and intentions, we

16     were very well aware of all of those so that we knew what objectives they

17     had, what intentions they had, and what their purpose was.

18        Q.   Thank you.  How did you learn these things, or in what manner or

19     manners did you get by information of this nature?

20        A.   Well, yes.  There were several ways.  There were a number of ways

21     that we learned about them.  The troops -- or, rather, the command, first

22     of all, relies on its intelligence.  The collection of data and their

23     analysis would be cross-checked and compared, so one of the sources of

24     information was intelligence.

25             The other manner was this:  We were brought to the point where we

Page 32505

 1     had to organise an observation system that would confirm the movements

 2     and measures and actions taken by the enemy at any particular moment.  So

 3     there was the observation system or surveillance.

 4             The next -- the next manner would be this:  On a daily basis,

 5     citizens left Sarajevo.  They found different ways to accomplish this,

 6     and they would provide information to us about what they had seen there

 7     and what deployments they had observed, what forces were there, and so

 8     on, and of course we had to check this.  It is no secret that soldiers

 9     informed one another mutually.  In other words, from either side, because

10     the lines were very close.  They were some 50 metres away, one from the

11     other, so that they communicated amongst themselves, not in terms of

12     providing information, but there were contacts.

13             And the next way, and I think that's probably the most reliable

14     way was that we would assess what the situation was and see what the

15     enemy was employing, what forces, whether they were employing strong

16     forces or weaker forces.  So through all these manners, we would -- it

17     would come to the point where we knew everything about our adversary.

18        Q.   Could you tell us how, in a bit more in detail, how and when you

19     knew the enemy would use stronger or weaker forces?  How does ...

20        A.   Well, I understand what you're asking me.  That's clear to me,

21     but I don't think that was a decisive element.  But it was significant,

22     because then we would adapt our own deployments and employment of forces

23     in order to create a situation where we would not be caught by surprise.

24        Q.   Thank you.  General, sir, on page 11 you said that you were

25     familiar and that you knew the objectives, the intentions that they were

Page 32506

 1     trying to accomplish and the purpose of their actions.  Could you tell

 2     us, first of all, what type of establishment and organisation did the

 3     Army of Bosnia and Herzegovina adopt, including that of the 1st Corps in

 4     Sarajevo?  Did that differ in some way?  What was the type of

 5     organisation and structure that they had?

 6        A.   I understood your question.  I have to try to be more precise in

 7     my answer in terms of their organisation and formation from the time when

 8     they started establishing it at the time when I assumed my post.  There

 9     was a difference between the early period when they were organised and

10     the second period.

11             Specifically, in 1994, they transitioned to a new type of

12     organisation, new to them.  This is not new in the history of the

13     military, but there was this:  The command -- brigade commands were

14     attached to the corps command, and that's how this structure functioned.

15     But in the second half of 1994, the 1st Corps of the BH Army transitioned

16     to a new system, the so-called division establishment or system, and

17     specifically they established three divisions.  Of the three, one was

18     deployed in Sarajevo.  That was the 12th Division of the ground forces.

19             The second one was the 14th Division, which was deployed in the

20     Tarcin sector, which means to the west of Ilidza.  And the next division

21     is the 16th Division, whose command was in the Varos sector.  This is to

22     the north-west of the theatre in -- vis-a-vis Sarajevo.  So there were

23     these three divisions.

24             The corps commander maintains the command in addition to these

25     three divisions that were later structured, and I will explain that in a

Page 32507

 1     moment, but he also commanded six independent brigades that were not

 2     attached to the divisions.  He referred to them as light brigades.  Light

 3     brigades because they were manoeuvring units.  They were not active in

 4     combat but were to be used for action along a certain axis.

 5             So this was the global structure of the corps.  So the command of

 6     the corps and its organs, the military police battalion, and the forces

 7     that were attached to the corps as a rear structure.

 8             Would you like me to describe the structure of the 12th Division?

 9     Perhaps I can do that.  It's important and topical in view of the fact

10     that these two other divisions were outside of Sarajevo, but this one was

11     deployed in Sarajevo itself.

12        Q.   Could you use this map to show the Chamber the locations of these

13     division.  This is 1D7048 in e-court.  Could we please have that map on

14     our screens, and then I'll be asking General Milosevic to use the map to

15     indicate these positions for us.

16             THE ACCUSED: [Interpretation] 1D7048, please.

17             THE WITNESS: [Interpretation] I'm not sure we can actually see

18     anything on this one.

19             MR. KARADZIC: [Interpretation]

20        Q.   I have nothing showing in e-court.  Could you please, sir, use

21     the map on your left-hand side right behind you.  Thank you.

22             JUDGE KWON:  Just a second.  Can we not upload it?

23                           [Trial Chamber and registrar confer]

24             JUDGE KWON:  I was told that the Registry got an error message

25     because it might be too big in its size.

Page 32508

 1             THE ACCUSED: [Interpretation] All right.  In that case, I would

 2     like to ask General Milosevic --

 3             JUDGE KWON:  I think it's uploaded now.

 4             THE WITNESS: [Interpretation] It's uploaded, but it's still

 5     difficult for me to see.

 6             MR. KARADZIC: [Interpretation]

 7        Q.   General, sir, you can point out the positions for us on the big

 8     map on your left-hand side, and then everybody else can follow on their

 9     screens if they like.

10             JUDGE KWON:  Just a second.  Mr. Karadzic, do you want the

11     witness to mark on this map or just to explain the general layout?

12             THE ACCUSED: [Interpretation] If the general sees the map clearly

13     enough, it would be very good if he could mark for us the contacts or the

14     units of the BH Army that he was actually clashing with, the three

15     divisions first and foremost, and then he can tell us about the meaning

16     of these markings, 3K, 2K, 4K.

17             THE WITNESS: [Interpretation] All right.  I'm getting started.

18     I'll start with positions inside Sarajevo city.  As I said, position here

19     fighting actively and engaged here is the 12th Division.  The location of

20     Sarajevo city itself, you can see it on this map.

21             I'm not sure if I should mark it at all.  It's plain for all to

22     see, Sarajevo, the city itself.  The 12th Division --

23             MR. KARADZIC: [Interpretation]

24        Q.   Can you just put 12D right next to it.  Thank you.

25        A.   [Marks]

Page 32509

 1             All right.  That's that position.  I know it all too well, if I

 2     can put it that way.

 3             As for their operations, the operations that they conducted in

 4     the actual fighting, well, we'll be showing that in due course.

 5        Q.   Can you please mark out the 14th Division of the 1st Corps for us

 6     now?

 7        A.   Not likely, unfortunately.  I can't mark the whole sector for

 8     you, but I can draw an arrow there to indicate the general direction in

 9     which they would operate.  I can't quite see it on the map.  But here,

10     I'll mark this, although it's for the working.

11        Q.   Do you see this bit where it says "OG Pazaric"?  Can you see

12     that?

13        A.   No, it's not on my map.  Oh, right.  Okay.  It's there.  All

14     right.  Yes.  Operative Group, that's right, near Pazarici, the distance

15     being maybe 5 to 7 kilometres.  We have Tarcin.  So this is sort of on

16     the Herzegovina side, and that's where the command of the 14th Division

17     was positioned.  Its exact combat disposition is something that I can't

18     be very specific about because they held all of this western side of the

19     territory under their control.  It's difficult to locate each and every

20     individual unit that belonged to that division, but I can only tell you

21     that they were facing us.

22        Q.   How far in the direction of the city centre did they ever get,

23     the 14th Division?

24        A.   Yes.  That's an excellent question.  They covered Igman,

25     Hrasnica, Sokolovic Kolonija, and Butmir, and Kotorac, Donji Kotorac

Page 32510

 1     specifically.

 2        Q.   Thank you very much.

 3             JUDGE KWON:  Before going further, could you tell us as to the

 4     provenance of this map?

 5             THE ACCUSED: [Interpretation] I think General Milosevic could

 6     probably tell us about that.  We shouldn't move it about too much before

 7     it is signed, but perhaps we could explain.

 8             THE WITNESS: [Interpretation] I read on the map itself that it is

 9     a working map, but that's all that I have been able to ascertain.  I

10     don't know the provenance.

11             MR. KARADZIC: [Interpretation]

12        Q.   General, sir, could you perhaps check the physical map over there

13     to your left and then see whether you can tell who it belonged to, who it

14     was produced by?

15             JUDGE KWON:  In your back, you can take the actual map.  Left, to

16     your left, on back side.  There.  No.  Can you see the actual map which

17     is managing on the -- yeah, there.  Please look back.  You can move, yes.

18     Yes.  Do you know what -- the provenance of this map?

19             Could we show the top of the map.  It shows Radna Karta or

20     something.  Could we unclip the left.

21             Yes.  Whose map is this, Mr. Milosevic?

22             THE WITNESS: [Interpretation] This is a war map of the

23     Sarajevo-Romanija Corps.

24             JUDGE KWON:  Thank you.

25             THE INTERPRETER:  Interpreter's correction:  "This is a working

Page 32511

 1     map of the Sarajevo-Romanija Corps."

 2             MR. KARADZIC: [Interpretation]

 3        Q.   General, sir, it says the 1st of July, 1994.  Did I see that

 4     right?

 5        A.   Yes, quite right.  That's what it says.

 6        Q.   Thank you.  Could you please draw a line, a simple line,

 7     connecting the positions of the 14th Division that were closest to you in

 8     the city and Pazaric?

 9        A.   Can I please erase the previous mark that I left there?  It's a

10     very poor mark.

11        Q.   Yes.

12        A.   Right.  Fine.  So I was trying to draw that arrow before, but

13     that was about something else.

14             It was in this area that the command of the 14th Division was

15     located.  This area right here which I'm about to mark is the area

16     covered by the 14th Division along with its 104th Motorised Brigade.  So

17     the X that I drew there, the 104th.  If you like, I can mark that for you

18     too.  104th Motorised Brigade.

19        Q.   At their forward end, facing you, in other words, could you put

20     an arrow there to mark how far they got in your direction, which is the

21     city itself, and what ground specifically did they cover there?

22        A.   I don't seem to be very good at drawing things, do I.  The area

23     that I marked is about Hrasnica, as far as I can tell.  That is the

24     Hrasnica area.  But this arrow does not underline the fact sufficiently,

25     because it's showing in exactly the opposite direction.  The closest area

Page 32512

 1     covered by this brigade is Hrasnica, Sokolovic Kolonija, Butmir, and then

 2     down the depth of Igman.

 3        Q.   Where was the border between you and them in relation

 4     specifically to the location of the airport?

 5        A.   They had some forces in Butmir and some in Donji Kotorac.

 6        Q.   Thank you, General.  No need to worry about your drawing skills.

 7     I'd just like to tell you that.

 8             JUDGE KWON:  Speaking for myself, I have difficulty following

 9     this line of evidence.  While this is a map that was produced at the

10     time, i.e., July 1994, why do we not see the markings then on this map of

11     14th Division of 104th Unit, et cetera?  Why should we rely on the

12     markings of the general now, and what are these markings then which we

13     see on this map?

14             THE ACCUSED: [Interpretation] I'm about to ask the general that

15     very same thing.

16             MR. KARADZIC: [Interpretation]

17        Q.   General, this is a working map of the Sarajevo-Romanija Corps.

18     What about these markings, PRB and so on and so forth?  What exactly does

19     that mean?  And were the enemy units marked on that map as well?

20        A.   This is a rough disposition and positions of the units of the

21     Sarajevo-Romanija Corps and their engagement.  Anything that was outside

22     these areas, well, that was the enemy, such enemy forces as actually

23     existed.

24             If we were talking about Ilidza, so we're looking at the

25     Ilidza Infantry Brigade.  If we're talking about Hadzici then that would

Page 32513

 1     be the Igman Infantry Brigade.  If we're look at the area surrounding

 2     Rukavica and Trebevic, then that would be the 1st Sarajevo Brigade.  If

 3     we're talking about area just north of Rajlovac, Vogosca, and all the way

 4     up to the eastern side where the Miljacka River meets the city at

 5     Sarajevo, that's the 3rd Sarajevo Brigade.

 6        Q.   Yes, but why don't we have the structure of the 1st Corps based

 7     on divisions?  On the 4th of July, 1994, were they organised like that

 8     already, a division-based structure?

 9        A.   That's quite right, and that's a good question.  They had a

10     brigade-based system back then, not a division-based system.  The

11     1st of July, 1994, no such thing around -- was there.  It wasn't before

12     the latter half that they started restructuring.  And then the names were

13     new, the numbers were new, and the whole organisational structure was

14     new.

15        Q.   Did that change anything about the confrontation lines,

16     specifically the forward ends?

17        A.   No.  They're restructuring effort did not affect the combat

18     disposition at all.  Well, aside from the fact that the units now had

19     different names and numbers.

20        Q.   General, sir, I'm looking at Pazaric and Tarcin.  Can you mark

21     that as 14D, please, 14D.  And then also mark for us the sector covered

22     by the 16th Division.

23        A.   [Marks].

24        Q.   Thank you.  The 16th Division, please.

25        A.   You can't actually see part of it on this map, but ... [Marks]

Page 32514

 1        Q.   Thank you.  Can you please explain to the Chamber what this

 2     means, 3K and then the number 2 over there?

 3        A.   Please try to understand me in the right way.  It doesn't mean a

 4     thing.  3K, that should mean the 3rd Corps.  The trouble is it wasn't

 5     there at all.  So I think it's a mistake that they actually marked this.

 6     Right where it says 3K, this was actually covered by the 16th Division

 7     and not the 3K that they had in mind.  So I stick to my previous remark.

 8     I think this is an error in marking.

 9             Likewise, here you can see 4K, meaning that on at that side, so

10     from Tarcin onwards in that general direction, which is Mostar, 4K should

11     be the 4th Corps.

12             So you could take that at face value, but what we see around the

13     Sarajevo-Romanija Corps -- I hear some background noise.  What you can

14     see about the Sarajevo-Romanija Corps, that is the 1st Corps of the

15     BH Army, including the brigades that I specified earlier on.  So I'm not

16     talking about the 3rd Corps and the 4th Corps and others.  I'm not saying

17     they were actually involved in the fighting.  What I'm saying is there

18     was no direct line of contact between them and us at the outset.

19        Q.   All right.  Tell us about the meaning of that red line just

20     outside the contact zone between 3K and 16D, the red line reaching the

21     lower end of the map.

22        A.   Yes.  You can see it going through Sarajevo and also beyond.  The

23     third line represents the forward end of the defence of the

24     Sarajevo-Romanija Corps.

25        Q.   General, sir, I did not mean the dotted line.  I meant the full

Page 32515

 1     line there between the number 1 that we see there and --

 2        A.   Yes.  Essentially that is the area of responsibility of the

 3     corps.

 4        Q.   Can you mark that on the map, please.

 5        A.   Yes.  We'll use a small cross to mark that, and then we'll call

 6     it "Area of responsibility of the SRK."  I have trouble finding my feet

 7     in terms of how things are actually marked on this screen.

 8        Q.   You mentioned the 2nd, 3rd, and the 4th Corps that you were not

 9     in contact with.  Can you please tell us if there was any fighting with

10     those corps and on which occasions?

11        A.   First of all, we had battles with the 2nd Corps throughout the

12     war; in the sense that the 101st Olovo Brigade from the area of Olovo, an

13     inhabited town, that 101st Glorious Brigade, as they called it, was part

14     of the 2nd Corps of the B&H Army, and it was in contact with us in the

15     Nisici sector, the broader area of the Nisici sector, the village of

16     Krivajevici, and so on and so forth.  And to be more precise, the

17     Gajne [phoen] village area where the Sarajevo-Romanija Corps was in

18     contact with the Drina Corps, that's where the initial contact and the

19     conflict with this 101st Brigade began, and that stretched further, our

20     disposition, and now I'm talking about the contact with the 16th Division

21     under the Zvijezda mountain.  Then it lay below mount Cemerska, the

22     broader are of the inhabited town of Breza, up to Visoko, and then from

23     Visoko up to Fojnica and then all the way to Mount Igman.

24        Q.   Thank you.  Can I ask you to tell us how long was your forward

25     end on the outside edge with the enemy and how long was it in the inner

Page 32516

 1     perimeter around the city centre?

 2        A.   We were in the city centre.  This is what I'm trying to say.

 3        Q.   Yes.  Yes.  Thank you.  You are correct.  But can you please tell

 4     us how long the contact -- the line of contact was between you and the

 5     12th Division.

 6        A.   Sometimes these estimates are not precise.  However, using the

 7     instruments that we had to measure this length, we calculated that it was

 8     somewhere in the area of 50 kilometres.  The total area of our forward

 9     defence and was 240 kilometres from the north, north-east to be more

10     precise, from the north-east through these areas that I mentioned below

11     mount Zvijezda and then Visoko up to mount Treskavica is 250 kilometres;

12     or, if I were to use different parameters, from -- then from the extreme

13     right left wing [as interpreted] of the corps to the extreme left wing, I

14     would need 250 kilometres length along the front.

15        Q.   Based on this map, can you also tell us which area on the map

16     could be considered to be an area where there was no front, no firing, to

17     be an area where life was normal?

18        A.   No.  There is no area there without fierce fighting.  Of course,

19     the intensity of the fighting centred on Sarajevo, mutual fighting, but

20     there were situations, very difficult ones at that, when the intensity of

21     fighting would increase precisely from the sectors of the 16th and the

22     14th Division, and of course in strict joint action with the

23     12th Division.

24        Q.   Thank you, General, sir.  Could I please ask you to put your

25     initials and the date in the lower right-hand corner.  And I would like

Page 32517

 1     to draw everybody's attention to P842.  This is a map, a Prosecution

 2     document that perhaps demonstrates the structure of the divisions in the

 3     1st Corps.

 4        A.   You want me to put the date here?

 5        Q.   Yes, in the lower right-hand corner.  Could you please put

 6     your -- date and have no concerns about your handwriting.  We are all

 7     aware that you did lose an eye in the war.

 8        A.   [Marks]

 9             THE ACCUSED: [Interpretation] Your Excellencies, thank you very

10     much.  I would like to tender the map.

11             JUDGE KWON:  Could you kindly turn back and read the legend for

12     us, which is on the left bottom of the map.  You can see it on the actual

13     map.  Could you read out for us the three lines.

14        A.   In the first line, "Line of contact."  Second line says "Line of

15     contact as of the 3rd of August, 1994."  And the third line states "Line

16     of contact as of the 24th of May, 1994."  Actually, no, I apologise.  The

17     24th of August, the 24th of August, 1994.

18             JUDGE KWON:  Thank you.  We'll admit this marked map as well as

19     the unmarked map.

20             Do you have any objection, Ms. Edgerton?

21             MS. EDGERTON:  No, and Dr. Karadzic was quite right.  P842, if

22     part of the point of this was to illustrate the division structure, is

23     the map that is the witness's own map that sets that out.

24             JUDGE KWON:  Thank you.  Shall we give the number.

25             THE REGISTRAR:  Yes, Your Honours.  The unannotated map which is

Page 32518

 1     65 ter 1D7048 will be Exhibit D2788, and the annotated version will be

 2     Exhibit D2789.

 3             JUDGE KWON:  Thank you.  Please continue, Mr. Karadzic.

 4             THE ACCUSED: [Interpretation] Thank you.  We don't need to look

 5     at the map any more.  Thank you.

 6             MR. KARADZIC: [Interpretation]

 7        Q.   General, sir.  Can you help us with this:  Can we take a look at

 8     the forces that were later part of the 12th Division?  These were forces

 9     that were in Sarajevo itself.  What was the strength of that force?

10             I'm going to try to put my questions in such a way that you can

11     give me short answers.

12        A.   Well, would I kindly ask, but I will also try to be rational and

13     try to give short answers, but you don't get good information in short

14     answers.

15        Q.   Well, you please just go ahead and say as much as you need to.

16        A.   I will.  Thank you.  Could you please put your question again?  I

17     didn't understand the point of it properly.  I didn't understand the

18     question.  I'm sorry.

19        Q.   Oh, never mind.  In the town itself, the forces that later made

20     up the 12th Division, could you please tell us what the structure was,

21     what the forces were that made up the division?  What were you faced with

22     from the city in terms of forces?

23        A.   This is why I asked you to repeat the question, because it's not

24     only the 12th Division that's involved.  It would be insufficient just to

25     discuss the structure of the 12th Division.

Page 32519

 1             Right from the start, what I want to say is that besides the

 2     12th Division, there was also action by other forces that I will mention

 3     later.

 4             The 12th Division, under the command of Colonel Prevljak - I've

 5     forgotten his first name for the moment - it comprised eight brigades,

 6     eight mountain brigades.  There were changes there.  Some were renamed to

 7     motorised brigades later, then mountain brigades, but in essence the

 8     point is that there were eight brigades.  These were strong units, very

 9     uniformly deployed, and I can add that I was quite amazed at their

10     military skill in deploying the defence and also the way those forces

11     were used.  Not just the defence.

12             It was under the command of Fikret Prevljak, that's right.  That

13     was the 101st Mountain Brigade.  That 101st Mountain Brigade was one of

14     the most or one the strongest units in this particular set-up, and it was

15     under the command of Colonel Fikret Hodzic, an officer who belonged to

16     the category of smart people.  I know him, and I know all the others as

17     well.

18             Then the next unit, I don't have to go by the actual sectors, but

19     they all focused on Mojmilo, Grbavica, up to the Vrbanja Bridge.

20        Q.   General, can you also give us the sector roughly, the area of

21     responsibility?

22        A.   Yes.  That's the area, Mojmilo Hill, which dominates Lukavica.

23     It covers the territory and protects in the form of a geographical

24     topographical feature that is 3.5 kilometres long at an elevation of

25     620-something metres above sea level, and that area was where the

Page 32520

 1     101st Mountain Brigade was deployed, and this brigade stretched across

 2     Ozrenska Street, in the Zeljeznicar stadium sector.  Then it reached the

 3     Miljacka River all the way to the Vrbanja Bridge up to Marin Dvor to be

 4     precise.  It had its area and the depth that it was covering, and it was

 5     covering all the neighbourhoods that were behind its back:

 6     Otokaz [phoen], Rakeno Selo [phoen] and the annex Cengic Vila 1 and so on

 7     and so forth.

 8             Then from the Vrbanja Bridge was where the 115th Brigade was

 9     deployed.  It's a famous brigade known to all because it was under the

10     command of the infamous Caco, whom they then liquidated in an action.

11     That's the 115th Brigade.  It's area of responsibility begins from

12     Vrbanja Bridge, and then it stretches above Vraca up to Debelo Brdo hill.

13     From Debelo Brdo it is deployed towards the so-called Colina Kapa.  From

14     Colina Kapa, the area then continues to the east to the Miljacka River

15     where the Miljacka River enters Sarajevo, and that's where its forward

16     end begins.  And its depth is up to the centre of town itself, including

17     Skenderija, Sirokaca, Bistrik, that whole area of the city with its line

18     of decisive defence and launching attacks at us.

19             From there that brigade demonstrated a lot of extreme conduct.  I

20     know the commander.  They probably inherited their aggressive stance from

21     a previous period and so on and so forth.

22             Then the 152nd Brigade takes over which covers that area from the

23     Miljacka River towards the Hladivode sector.  That's its forward end.

24     And its depth stretches all the way to the city hall, the famous city

25     hall in Sarajevo.  Actually it's the Bascarsija area.  That's that

Page 32521

 1     sector.  The commander of that brigade belonged to the category of people

 2     who knew how to carry out the command duties, and he demonstrated a

 3     normal attitude, one that can be given respect and was chivalrous.  Then

 4     this is the 105th Brigade that was in charge of the Jajce barracks in

 5     that area.

 6             Then the 105th Mountain Brigade takes over which was a brigade

 7     with seven battalions.  It's a very large powerful unit.  I cannot recall

 8     the name of the commander right now, but I do know it well.  He had seven

 9     battalions, and out of those seven, four were infantry battalions.  There

10     was one Engineers Battalion, an artillery division and then one was a

11     Logistics Unit.  The brigade held the area of Sedrenik, everything above

12     the Kosevo Hospital, the Breka area, and it linked up to the

13     152nd Brigade, and its depth lay all the way back to the railway station,

14     and it held the centre of the city.  The brigade was stronger than a

15     third of the Sarajevo-Romanija Corps.  It was very strong.  It was very

16     well equipped, had good combat equipment, powerful equipment and I would

17     say that not everything was quite proper in their relationship and in

18     these conflicts and in the fighting.  They didn't fire in a normal manner

19     but in a manner which would turn into an attempt to destroy us.  And they

20     tried to do that.

21             So then Hladivode towards Orahov Brijeg hill.  That's where their

22     area was.  The same brigade went over Prevoj, the Grdonj peak, and it

23     joined up through Pionirska Dolina valley with the 111th.  The 111th

24     would sometimes be called a Mountain Brigade and sometimes a

25     Motorised Brigade.  The 111th, its forward disposition spread from that

Page 32522

 1     geographical feature, Orahov Brijeg, through the faculty for transport

 2     which is now in Vogosca, to the elevations, the so-called Krcevine

 3     elevations, and it covered the highest elevations in Sarajevo, above the

 4     town of Sarajevo; and that is Orlic, 840 metres, then Zuc, then Vis, all

 5     of them all the way to the area above Rajlovac.  And it dominated

 6     Vogosca.  It could see it really well.  It was an inhabited settlement.

 7     It was impossible to move around in Vogosca because of the very strong

 8     shelling.  Perhaps there was some obstacles or barriers put up.  Some

 9     railway carriages from the railway carriage factory were put up so that

10     people could move.

11             If you permit me, that area was so exposed to fire that it was

12     impossible, unbearable to live there but people managed somehow.

13             Then that linked up to the 112th Brigade, which from that place,

14     from the 111th Brigade, took over the area all the way to the place where

15     the Miljacka River leaves Sarajevo.  Miljacka enters Sarajevo on the

16     eastern side.  It leaves it on the western side, and that is where the

17     area covered by the 112th Division ended.  That division -- actually, not

18     division, that brigade, had a powerful artillery component.  These were

19     key positions, artillery firing positions, which they fired from with the

20     weapons that they had at their disposal.  From the 112th, the -- and let

21     me add that the 112th and the 111th also covered in the depth the area

22     all the way to Dzemala Bijedica [phoen] Street.

23             Then follows 102nd Mountain Brigade.  That was one of the more

24     agile brigades, because they were constantly engaged in combat and in

25     trying to destroy the area of Nedzarici.  That was their idea, or

Page 32523

 1     whatever, and over that area to link up with the 104th that I mentioned

 2     earlier.

 3             Now, the 102nd Brigade held or covered the area from the Miljacka

 4     bridge over the Stup hill, along the student halls, and there it would

 5     cross into Nedzarici.  On -- onward from it was the 155th Brigade,

 6     Mountain Brigade, under the command of Ismet Hadzic, who was a civilian.

 7     The 155th Brigade was in Dobrinja, and in my view it was a unit that was

 8     very numerous, the personnel, and they were in a very small area, so they

 9     were getting out of control.  So I understood that they needed more space

10     to try to break through.  So they opened fire on Lukavica and Trapare

11     neighbourhood, as well as some houses on our side.

12        Q.   General, sir, I would like to call up 1D7047 in e-court.  You

13     will be familiar with this document.

14             THE ACCUSED: [Interpretation] And in line 1 on the 30th page, the

15     general didn't say that they were out of control.  He said that they were

16     acting in a very wild manner.  They were uncontrolled.  They were

17     aggressive.

18             Now, could I request that the usher provide a printout of the

19     document that we've called in e-court, 1D7047.

20             JUDGE KWON:  Is it not uploaded in e-court?  I don't see it on

21     the --

22             THE ACCUSED: [Interpretation] It should be.

23             MR. KARADZIC: [Interpretation]

24        Q.   General, sir, who drafted this map -- or, rather, this

25     disposition of units?

Page 32524

 1        A.   Well, I did.  Observing the situation, revealing their

 2     disposition and deployments and observing their direction of action, I

 3     managed to put together a mosaic of their activities, and right now

 4     looking at it, I'm not quite happy because you cannot really see clearly

 5     the extent to which they engaged in combat and opened fire.  You can't

 6     really see it from this map, but it gives you an idea.

 7        Q.   Thank you.  Now, you talked about the brigades and their

 8     dispositions.  Can that be seen on this map?  You started with the 101st,

 9     moved eastward all the way to 155th to the west.

10        A.   Well, that's what I tried to present here.

11        Q.   You do have a printout of the map that you can look at.

12        A.   Well, yes.  You see, the semicircles there, the arcs -- maybe I

13     can show it here.  For instance, here.  This marks the place where these

14     units had contact, physical contact.  Likewise, right here, that's where

15     they linked up.  You can see it here.

16        Q.   And which units were adjacent above Kobilja Glava?

17        A.   Well, that was the point contact between 105th and 112th -- no,

18     111th.  No, 112th.  My apology.  So the 112th and the 105th, which spread

19     from Sedrenik via Grdonj to Orahov Brijeg.

20        Q.   Thank you.  We will -- we're approaching the time for our break,

21     so would you please date and sign this map.

22        A.   Very well.  This is okay.  I've checked again.  It's okay.  So I

23     should put the date there?

24        Q.   Yes, the date and your signature, please.

25        A.   [Marks]

Page 32525

 1             JUDGE KWON:  I'm afraid today is the 23rd, Mr. Milosevic.

 2             THE WITNESS: [Interpretation] Correction.  I need to correct

 3     that.

 4             JUDGE KWON:  While the general is putting the date, probably we

 5     need the translation of each legend later on.  So we'll mark this map for

 6     identification pending translation.

 7             THE REGISTRAR:  As MFI D2790, Your Honours.

 8             JUDGE KWON:  I see the time, Mr. Karadzic.  Shall we take a break

 9     if it is convenient?

10             THE ACCUSED: [Interpretation] Very well.

11             JUDGE KWON:  Mr. Bourgon, do you have a point?

12             MR. BOURGON:  A very quick point, Mr. President.  The witness

13     wanted to address the Trial Chamber in respect of his detention

14     conditions very quickly, Mr. President.

15                           [Trial Chamber confers]

16             JUDGE KWON:  Yes, Mr. Milosevic, you have the floor.

17             THE WITNESS: [Interpretation] Thank you, Your Honour.

18             JUDGE KWON:  Mr. Milosevic, I have to turn to Mr. Robinson and

19     Mr. Bourgon whether we can stay in public session.

20             MR. BOURGON:  Actually, he just wants to say that he's satisfied

21     and say thank you to the Trial Chamber, Mr. President.

22             JUDGE KWON:  Very well.  Please proceed, Mr. Milosevic.

23             THE WITNESS: [Interpretation] Thank you for giving me this

24     opportunity to say this.  Perhaps I should have asked for this myself,

25     but very well.

Page 32526

 1             I need to thank the Trial Chamber for allowing me to have, while

 2     in detention, the conditions that are similar to the ones that I have in

 3     the prison in (redacted).  In other words, I'm not isolated from the other

 4     prisoners.  And let me just add one thing.  Yesterday when I was asked

 5     about the notes that I had jotted down, it was only then that I concluded

 6     that I was happy that I had already jotted down some of my notes while I

 7     was still in (redacted) in Estonia, because when I arrived here and under the

 8     conditions that I originally had, I wouldn't have been able to

 9     concentrate, but right now everything is fine, and thank you very much.

10     I'm quite happy.

11             JUDGE KWON:  Thank you.

12             Could the court deputy approach the bench.

13                           [Trial Chamber and registrar confer]

14             JUDGE KWON:  We'll a break for half an hour and resume at 3 past

15     11.00.

16                           --- Recess taken at 10.33 a.m.

17                           --- On resuming at 11.03 a.m.

18             JUDGE KWON:  Yes, Mr. Karadzic, please continue.

19             THE ACCUSED: [Interpretation] Thank you, your Excellency.

20             MR. KARADZIC: [Interpretation]

21        Q.   General, sir, I would now like to show you a document from the

22     command of the 12th Division of the 1st Corps.

23             THE ACCUSED: [Interpretation] Could we pull up, please, in

24     e-court 1D2839.

25             MR. KARADZIC: [Interpretation]

Page 32527

 1        Q.   General, sir, first of all, could you tell us what the

 2     handwritten note means, and could you tell us who wrote that?  Could you

 3     read it out to us?

 4        A.   Yes, I can.  This is my own handwritten note when I tried to

 5     communicate with my attorney and show him a source document, an original

 6     document, which shows the exact deployment and shows accurately the

 7     engagement of the 12th Division forces, and the intention was for him to

 8     understand the problems and to gain insight into this from this document,

 9     to gain insight into the adversary or the other side for the

10     Sarajevo-Romanija Corps.  And this request of mine was something he did

11     not like.  I can't explain why, but he just couldn't understand it, and

12     he did not want to tender this document, and this document was never used

13     in trial -- in my trial.  So this is my answer to your question, to

14     explain what happened with this document and my request to use it.  But

15     if you need anything else, please just let me know.

16        Q.   Thank you.  Now, what -- first of all, tell us what kind of

17     document is this?  This is an order.  What kind of order?

18        A.   This is an order for decisive defence by the commander of the

19     12th Division, dated the 14th of April, 1995.  The gist of the document

20     is this:  He expresses here the deployment of his forces, and he gives a

21     detailed account of everything that his commanders need to know,

22     including what assets they have at their disposal, what resources, what

23     area of responsibility they're responsible for and the direction or the

24     axis, the axis of their advance and attacks, although here it says this

25     is a command for a decisive defence.

Page 32528

 1        Q.   Could you please tell us what it says in the third line of this

 2     text.  What was his estimate of the forces that he had against him, the

 3     forces of the Sarajevo-Romanija Corps?

 4        A.   Well, yes.  He states here that that's 9.000 troops, yes.  He

 5     wasn't far off the mark.  I believe that his estimate was correct.

 6        Q.   What about the other 9.000 troops of the Sarajevo-Romanija Corps?

 7     Where were they deployed?

 8        A.   The remainder or the other part of the corps -- although let's be

 9     clear on this, both these men and the other men, they're all part of one

10     and the same corps.  They were deployed at the wider area at the

11     Nisici plateau, Nisiskavi Soravan [phoen], and including all the areas

12     that were tied up to Visoko and Olovo and Breza.

13             Now, the other elements of the Sarajevo-Romanija Corps were

14     deployed in the general area in the southern front below Treskavica; in

15     other words, in the Trnovo settlement area.

16             JUDGE KWON:  Please bear in mind that it's very difficult to

17     follow this line of questioning without having an English translation.

18     And I find it also difficult to understand why we do not have English

19     translation of this document while it was put to one of the witnesses,

20     i.e., Martin Bell, about two years ago, one and a half years ago.  Two

21     years ago, more than two years ago, according to what e-court says to us.

22             THE ACCUSED: [Interpretation] We have requested a translation.

23             JUDGE KWON:  When did you put in a request for translation,

24     Mr. Karadzic?  I think the e-court says it was put to Martin Bell on

25     15th of December, 2010.

Page 32529

 1             THE ACCUSED: [Interpretation] Your Excellency, we always have to

 2     prioritise, and it is possible that we've overlooked this document as one

 3     of the priority documents, but I do believe that we have made a request

 4     for its translation, and of course there is a logjam in the translation

 5     service, so we do understand that they don't have time to meet the

 6     dead-lines.

 7             JUDGE KWON:  I leave it at that.

 8             Mr. Milosevic, could you kindly read out your handwriting for us

 9     to understand it.

10             THE WITNESS: [Interpretation] Yes, thank God.  Your Honour, it

11     says here, that's what I wrote in my own hand -- well, first of all what

12     you see there which is kind of pale, that says "Important."  That meant

13     that it was an important document, as far as I was concerned.

14             Now, what it reads here in handwriting is:

15             "We should finally resolve with the attorney the issue about the

16     presentation on a map of a developed deployment of the 12th Division in

17     the town of Sarajevo.  Decidedly developed deployment of the

18     12th Division in the town of Sarajevo."

19             In other words, I asked him to translate this onto a map so that

20     we can see from the map where that was, but he never did any of those

21     things that I asked him to do.

22             JUDGE KWON:  And I also find it difficult if your attorney did

23     not tender this document, how could this document be in the custody of

24     Mr. Karadzic?  Do you have any clue?

25             THE WITNESS: [Interpretation] Are you asking me?

Page 32530

 1             JUDGE KWON:  Yes.

 2             THE ACCUSED: [Interpretation] I believe, Your Honour -- your

 3     Excellency, that this is somewhere --

 4             THE WITNESS: [Interpretation] No, no.  All I know is that this

 5     was what I asked my attorney to do, my Defence counsel.  This document

 6     was important, as I've already said, in my view.  Now, whether this was

 7     transposed, I actually had the same suggestion for the trial of Mr. --

 8     the Chief of the General Staff who was also connected to this, yes,

 9     Perisic, for the Perisic case.  And perhaps in that form it actually

10     appeared somewhere.

11             THE ACCUSED: [Interpretation] We will look at the bottom of the

12     page, because perhaps the document was marked for identification.

13     Further down, please.

14             THE WITNESS: [Interpretation] Yes, that's right.  We have a

15     number there.

16             JUDGE KWON:  Please continue, Mr. Karadzic.

17             MR. KARADZIC: [Interpretation]

18        Q.   General, sir, line 3, what was the estimate of troops facing the

19     12th Division, overall strength?

20        A.   Nine thousand men.

21        Q.   All right.  Page 2, please, paragraph 4.  It starts with the

22     words "I hereby decide."  What about the structure of their decisions?

23     Are they similar to the your decisions, because I noticed in VRS

24     documents that paragraph 4 is always "I hereby decide."

25        A.   Yes.  That's quite true, but let me just add one thing.  We all

Page 32531

 1     come from the same military background.  Officers on both sides were

 2     trained in much the same way, and the same applied to procedures based on

 3     which orders and reports were written up.  So the command methods were

 4     very much alike on both sides of the front line.

 5        Q.   Thank you very much.  Can you please focus on 5.1.  What is the

 6     brigade that he is talking about there?  We shall not be dwelling on

 7     this, but what is that brigade, and how does he identify their position,

 8     and is that consistent with your information at the time?

 9        A.   Yes.  The 101st Brigade minus one battalion.  This sort of

10     indication minus one, you'll find that elsewhere, too, because they'll

11     always have one battalion from a brigade and then send it out elsewhere,

12     send it to Niksic, for example, that area over there.  So we're looking

13     at the 101st Brigade and what I see here is consistent with the

14     disposition that I was aware of at the time.

15             THE ACCUSED:  [Interpretation] Could this please be MFI'd.  We

16     have a similar document that we do have a translation for that again

17     gives you the deployment of units belonging to the 12th Division two

18     months later.  It is an attack plan.

19             THE WITNESS: [Interpretation] May I ask the Chamber something,

20     please.

21             JUDGE KWON:  Yes, Mr. Milosevic.

22             THE WITNESS: [Interpretation] I think it would be a good idea to

23     focus on this part where it talks about the combat disposition.  The fact

24     reflected here shows the force and equipment available to the commander

25     of the 12th Division.  He states in unambiguous terms that he has some

Page 32532

 1     forces in one of the echelons with some reservists and that there were

 2     some support forces available too.  So support was available.  And the

 3     other commander knew that he could lend support if he needed.  So he had

 4     artillery.  He had the anti-armour, he had anti-aircraft, he had some

 5     obstacles available to him, and he has the appropriate command forces

 6     available to him; in one word, he has everything that he needs to

 7     effectively run the forces available to him.

 8             THE ACCUSED: [Interpretation] Your Excellency, I was moving to --

 9     to have this MFI'd, and then perhaps we could sum up in e-court a very

10     similar document that we do have a translation for and all the same

11     elements are actually there.

12             JUDGE KWON:  Mr. Karadzic, for the record, I was told that the

13     number we saw at the bottom of page 1 is a Defence identification number,

14     not anything else.

15             Yes.  Ms. Edgerton, do you have any objection to marking this

16     document for identification?

17             MS. EDGERTON:  For identification, no.

18             JUDGE KWON:  Yes, we'll do that.

19             THE REGISTRAR:  It will be MFI D2791, Your Honours.

20             THE ACCUSED: [Interpretation] Thank you.  Could we please have

21     1D2567.

22             MR. KARADZIC: [Interpretation]

23        Q.   General, sir, this is an attack order.  What is the date, please?

24        A.   Attack order by the commander of the 12th Division,

25     11th of June, 1995.

Page 32533

 1        Q.   Was this attack carried out?

 2        A.   Yes.  This is no ordinary attack.  This is an offensive.  The

 3     scope of this offensive is brought, the scope of the operations is

 4     brought.  This operation was meant to crush the forces of the

 5     Sarajevo-Romanija Corps.

 6        Q.   Thank you.  Page 1, line 3.  This is two months later.  What is

 7     the estimate of -- of the men he was facing, the number of men he was

 8     facing now?

 9        A.   Now it's down to 8.000 men.

10        Q.   Thank you very much.  Next page, please.

11        A.   And the estimate was actually correct, because many of my men had

12     been killed in the meantime.

13        Q.   What does he say there about the 12th Division and the

14     neighbouring divisions, the 14th and the 16th?

15        A.   Even without reading I know the context, and I know what you're

16     asking me.  There was a full co-ordination of combat operations between

17     both of these units.  It's a very clever way to co-ordinate your

18     operations from Sarajevo on the one hand - when I say clever, I mean

19     clever for their own purposes, of course - and combining that with the

20     forces outside Sarajevo but moving in on Sarajevo.  The 12th Division was

21     in Sarajevo, and the 14th and 16th Divisions from the area that I

22     specified.  Vares.

23        Q.   Could we have the next page in English, please.  Please continue,

24     General, sir.  Tell us briefly about what -- what this is about.  What

25     force, are available to him and what exactly does he intend to do?

Page 32534

 1        A.   You mean the commander of the 12th Division?

 2        Q.   Yes.  What does the document tell us about his intentions?

 3        A.   The document tells us that all of his forces were active by this

 4     time.  A while ago we were talking about him co-ordinating with the 14th

 5     and the 16th Divisions.  In actual fact, it was the corps commander who

 6     was doing the co-ordination for him, but he knows that co-ordination will

 7     be there, that there will be concerted action.  He knows with sure and

 8     certain knowledge that heading his way are these other units, but not

 9     just from the 1st Corps in relation to this specific situation, and it's

10     not he who is saying this, it's the corps commander telling him what

11     other forces would be involved.  The 3rd Corps under General Mahmuljin's

12     command, the 7th Corps, another powerful unit in his own area.  The

13     4th Corps under elements of the 2nd Corps.  So all these units together

14     along with the 1st Corps were the strike force threatening the

15     Sarajevo-Romanija Corps.  So they're calling this -- they're labelling

16     this as deblocking [Realtime transcript read in error "disabling"]

17     Sarajevo.  I don't mind that, because that's what it was from their

18     perspective, I suppose.  So that certainly was not a deblocking effort.

19     This was about crushing the Sarajevo-Romanija Corps.

20             THE ACCUSED: [Interpretation] Could we please scroll down to the

21     bottom of the English page where it starts to talk about forces and

22     combat disposition.  And that is the next page in the Serbian copy, so

23     you can tell us about what it means, combat disposition.  Can we have the

24     next page in both versions of the document, please.  Can we zoom in,

25     please.  We need page number 3 in the Serbian.  Page number 3 in the

Page 32535

 1     Serbian.

 2             MR. KARADZIC: [Interpretation]

 3        Q.   Please tell us briefly about what the decision comprises and then

 4     what forces would actually be used.

 5        A.   The meaning of this decision.  First of all, he decides to hold

 6     on to what he has already, use some of his forces to secure the defence

 7     line, and also to use some other units available to him to carry out

 8     certain operations and to achieve certain breakthroughs in certain areas.

 9     I don't know this by heart, but I know the general direction in which

10     they were moving.  Talking of the 12th Division, it was launching

11     operations, trying to break out of Sarajevo using its own brigades along

12     its own axes of operations.

13             Talking about the combat disposition of these forces here, what

14     you see here constitutes a corroboration.  He wanted to do this, and he

15     was indeed able to do this.  He was able to launch this operation.

16             When a commander decides to lend support to someone, then the

17     other person has to be aware of the fact that there is support coming his

18     way, support in terms of firing, in terms of firepower, support in terms

19     of reinforcements being sent his way.  This person must know that he will

20     not be left to his own devices, but help is coming.

21             So these are not particularly adventurous or risky decisions.

22     These are well-thought-out decisions and they are at this point in time

23     ready to go ahead with this.

24        Q.   Thank you very much.  Could you please tell us about the combat

25     disposition and the units that were available to him?

Page 32536

 1             JUDGE KWON:  Before -- before you answer, Mr. Milosevic.

 2             Yes, Ms. Edgerton.

 3             MS. EDGERTON:  I'm sorry for interrupting but just before it

 4     appears on our screen at page 41, line 5, we see the word "disabling

 5     Sarajevo" used and I distinctly heard the witness say "deblocking

 6     Sarajevo."

 7             JUDGE KWON:  Thank you.  Before we go on further, Mr. Milosevic,

 8     could you read the handwritten part at the bottom of paragraph 5.1, and

 9     tell us whether it is written in Cyrillic or in Latin.

10             THE WITNESS: [Interpretation] Uh-huh.  If this is what you're

11     asking me about -- it's gone now.  Latin script it is.  Yes.  It's a

12     clarification that I jotted down myself, because this is my handwriting.

13     It's about this abbreviation, DAG-12, the division artillery group.  I

14     did this because I knew that my Defence counsel understood nothing about

15     these abbreviations and he couldn't possibly figure out what it meant.

16     So I would expand these for his benefit in a bid to explain to him what

17     he was going through.  So this is the division artillery group belonging

18     to the 12th Division in this case.

19             JUDGE KWON:  Thank you.  We'll come back to this page, but can we

20     see the first page, page 1 of this document in B/C/S.

21             So, Mr. Karadzic, this document is from Mr. Milosevic's case.

22     Exhibit D417 is from his case?

23             And, Mr. Milosevic, I see "Plan B" in Cyrillic in the middle

24     of -- on top of the page in Cyrillic.  Do you read -- do you see that,

25     "Plan B"?

Page 32537

 1             THE WITNESS: [Interpretation] Yes.

 2             JUDGE KWON:  Is it your handwriting, Mr. Milosevic?

 3             THE WITNESS: [Interpretation] No, it isn't.  I don't know whose

 4     it is.  I don't write in Cyrillic.  I think this is probably written by

 5     my Defence counsel, "Plan T."  So linking up the code-name of the entire

 6     operation, Tekbir.  The 1st Corps, the BH Army as a whole.

 7             JUDGE KWON:  Thank you.  The last question for you was whether

 8     you could tell us about the combat disposition and the units that were

 9     available to this commander.  That is the question from Mr. Karadzic.

10             THE WITNESS: [Interpretation] Yes, but could we please go back to

11     that portion of the text.

12             MR. KARADZIC: [Interpretation]

13        Q.   Page 3 in the Serbian.  Combat disposition and then the units.

14        A.   Yes.  I was about to embark on that.  The commander here decides

15     to keep some attacking forces, some of the units involved.  And to also

16     use some of the units to defend and to offer support, some of the units

17     to be involved in anti-armoured combat.  Artillery support, that is

18     understood.  When he says support, it's not about actually fetching them

19     a glass of water.  Of course, it's about offering support in terms of the

20     firepower, anti-aircraft, and then also some forces to secure the actual

21     combat operations, and that is an element, the importance of which cannot

22     be overestimated.  Very important.  Signals and command and also reserve.

23     We see everything that is available to him, and he has all of the

24     required elements assembled him there, leaving him in an almost ideal

25     position to carry out combat operations.  He has everything that he needs

Page 32538

 1     in order to carry out this task.

 2        Q.   Thank you, General.  What about 5.1, 5.2?  What are the forces

 3     there that he's using?  Where are these forces positioned, and what about

 4     the command posts and forward command posts?  Where are those?

 5        A.   When discussing these forces that he engaged, first of all, he

 6     engaged all of the forces at their disposal, the brigades that I

 7     mentioned previously.  These are the brigades from the 12th Division.

 8     What you can see here, that the independent brigades are also taking

 9     part, which are directly in line of command under the corps.  These are

10     light brigades.

11             The list of documents with the commanders receiving the order,

12     other than his commanders from the 101st, 102nd, 115th, and so on and so

13     forth, there is also the signature of the commander of the police forces

14     brigade, Mr. Mirkovic.  And this is an additional unit outside of the MUP

15     B and H special brigade.  It was called the Bosna Brigade.  This brigade

16     is purely a police brigade.  They had an excess of police.

17        Q.   Could you please show us this entire paragraph 5.1 about the

18     112th Brigade?  Can you tell us, General, sir, when you lost your right

19     eye?

20        A.   I lost my eye in 1995 at Bosut.

21             THE ACCUSED: [Interpretation] Could you please enlarge this for

22     the General.

23             MR. KARADZIC: [Interpretation]

24        Q.   And how did you lose your eye?

25        A.   I don't know.  It was a direct hit by a tank shell at the

Page 32539

 1     observation post of the commander, my observation post.  It hit directly

 2     the observation post.  I wasn't hit myself directly, but I did lose my

 3     right eye in this hit.  The fire originated from Sarajevo, from the

 4     Velesici incline.

 5        Q.   Could you please read this, and then for the others could you

 6     please tell us what is supported and what the command forces are?  Could

 7     you read 5.1, please.

 8        A.   112th Viteska Mountain Brigade in decisive defence defends the

 9     area of responsibility of the brigade while a part of the forces from the

10     forward section Vis Lemezi is to carry out an attack along the axis of

11     Vis, Perivoj, trig point K 6.34, Dvor and Mijatovici, Mijatovici Kosa,

12     Zabrdje with the objective as follows:  By energetic action of the forces

13     from the front route the enemy along the axis of attack, inflict as many

14     losses as possible in manpower and materiel, capture the facilities at

15     Perivoj, elevation 6.34, Mijatovici Strana, trig point 5.82, the village

16     of Mijatovici, the village of Zabrdje, and break out to the

17     Rajlovac-Semizovac road, and in close joint action with the

18     111th Light Brigade and the 143rd Light Brigade organise a defence,

19     repulse a possible attack, and be prepared to link up with the forces of

20     the 7th Corps.  And the 7th corps would then proceed from that direction

21     towards Reljevo from the direction of Visoko.

22             THE INTERPRETER:  Interpreter's note:  We do not have the

23     translation on our screen.

24             JUDGE KWON:  Just a second, your last question and answer were

25     not reflected in the transcript because you overlapped with the

Page 32540

 1     interpreter's note.

 2             THE ACCUSED: [Interpretation] I apologise to the interpreters.

 3             MR. KARADZIC: [Interpretation]

 4        Q.   General, sir, are you able to tell us as it refers to 5.1, who

 5     supports?  What does that imply?  Where's the command post, and where's

 6     the forward command post?

 7        A.   Yes, yes, all right.  I understood it now.  I thought you meant

 8     the overall support for the entire 12th Division.  All right.  So as far

 9     as this brigade is concerned you noticed that well.  This brigade is

10     being supported by the 12th Division Artillery Group.  The command post

11     of this brigade is in -- at Astra.  Astra is right in the middle of town.

12     And the forward command post is in the sector of Sokolje, and that

13     Sokolje dominates Rajlovac, and throughout the war Rajlovac was under the

14     same pressure as Vogosca.

15        Q.   Can we now scroll up where it says this part is -- supports also

16     the 146th Light -- not to scroll down but to scroll up.  [In English] All

17     the way down.

18        A.   What is discussed here is the support provided to the

19     143rd Light Brigade.  They are supported by the artillery group of the

20     division, the command post would be in the sector of the

21     Ramiz Slacin barracks.  That used to be my barracks, Victor Bubanj.  And

22     its command post, the command post of this brigade pursuant to the

23     decision of the brigade commander, I mean the commander picks his own

24     command post, the command post of the 143rd Light Brigade.

25        Q.   [Interpretation] Thank you.  And all of this, is that in the town

Page 32541

 1     itself?

 2        A.   Yes, yes.  I will wait.  Sorry.

 3        Q.   Can we have the next page, please.

 4             JUDGE KWON:  Mr. Karadzic, we have English translation for this.

 5     There is no point of asking the witness to read out whole paragraphs.  Of

 6     course, it is for you to use your time --

 7             THE ACCUSED: [Interpretation] No, no.  Not entire paragraphs,

 8     your Excellency.  I just wanted him to identify the support and the

 9     command post for each brigade and to tell us where.

10             MR. KARADZIC: [Interpretation]

11        Q.   Mr. General, can you please tell us where the 111th -- actually,

12     just these three paragraphs.  Just these three lines at the end of the

13     paragraphs.

14        A.   Ah, yes.  I can see the 111th at the top of the page.  It's being

15     supported by the artillery group 12, the command is in the sector of the

16     Blagoje Parovic school.  The forward command post is in the Orlic sector.

17     It's a trig point.

18        Q.   And now I'm going to try in order to get things to move faster,

19     let's look at a hundred -- the 105th.  Let's skip the MUP forces

20     paragraph.  105th.  Does it not state here it's supported by the

21     division's artillery group?  The command post is in the sector of the

22     park, and the forward command post is in the sector of the

23     Kosevo Hospital?

24        A.   What it states here is what it is, and the fact that the command

25     post is in the park sector --

Page 32542

 1             JUDGE KWON:  Ms. Edgerton.

 2             MS. EDGERTON:  With respect, I don't think that's the best way to

 3     move forward in phrasing your question.  Dr. Karadzic has led the witness

 4     a few times now, and as we get into the documents particularly, perhaps

 5     he could be cautioned.

 6             JUDGE KWON:  But it has been the practice of the Chamber to allow

 7     the accused to put leading questions until objected to by the

 8     Prosecution, and unless it is a serious problem, we'll let him continue.

 9             Please bear in mind, Mr. Karadzic.

10             THE ACCUSED: [Interpretation] Thank you.

11             MR. KARADZIC: [Interpretation]

12        Q.   I will just ask the General then where the forward command post

13     was supposed to be for the 105th Brigade, the command post and the

14     forward command post.

15        A.   Evidently the forward command post -- the commander, this

16     commander, was obviously told that he could legally place his command

17     post at the Kosevo Hospital.

18        Q.   And then the next command, where would the command post be?

19     General, sir, is all of this within the city?

20        A.   Yes.  Yes.  This is a neighbourhood when we're talking about the

21     forward command post, and if we're talking about the 152nd Brigade, this

22     area of Vratnik, this is a neighbourhood above Bascarsija.

23        Q.   Thank you.  Can we scroll up, please, so we can see the bottom of

24     the page.  What about this 115th?  What is this 6th April square, and

25     what is Mala Kula?

Page 32543

 1        A.   Yes, yes, yes.  The 6th April square, that's the area where the

 2     command of the 2nd Military District was, and it's a -- actually, it's in

 3     the very centre of town, Bistrik.  The forward command post is in Mala

 4     Kula.  I really cannot tell you what this place is.  There was a number

 5     of "kulas," towers, around Sarajevo, so I don't know exactly which one it

 6     is.

 7        Q.   Thank you.  Can we please look at the following page, so that we

 8     can see -- we will not be looking at the other ones because there is a

 9     translation.  And then where it says firing support, what is this firing

10     support and what do they have at their disposal in the town itself?

11     Let's look at the page in B/C/S, and the participants can look for

12     themselves for the English version.

13             Can we look at the bottom of the page, item 6.

14        A.   Could we please zoom in a little bit on the text?  Ah, all right.

15     Thank you.  I don't know if I should read this.  The fire support is

16     provided by the division of the artillery group which is part of the

17     3rd Battery of the 2nd MAP.  There's an anti-air -- a rocket battery.

18     The commander of the 3rd MAD, all the weaponry from the 3rd MAD are to be

19     deployed at the basic firing positions in the sectors of Hum, Busca,

20     Mojmilo, Zrak, Orlovaca.  The main observation posts in the sectors of

21     Hum, Orlic, Svabino Brdo, Mojmilo Brdo, the command post of the 12th DAG

22     is in the sector of Velesici and the forward command post is in the

23     sector of Hum.

24        Q.   Thank you, General, sir.  I would like to tender this document.

25     I don't need to go any further and read the document because the document

Page 32544

 1     speaks for itself.

 2             JUDGE KWON:  We'll receive it.

 3             THE REGISTRAR:  As Exhibit D2792, Your Honours.

 4             MR. KARADZIC: [Interpretation]

 5        Q.   General, sir, you saw the command post, the forward command

 6     posts, and then you said that all of them were located in the city

 7     itself.  I wanted to ask you what a command post of a force consists of.

 8     What are the elements, where are they deployed, and what kind of an area

 9     do they occupy?

10             JUDGE KWON:  Yes, Ms. Edgerton.

11             MS. EDGERTON:  I don't know that the general has said that he saw

12     the command posts and saw the forward command posts, as Dr. Karadzic has

13     just said.

14             JUDGE KWON:  Mr. Karadzic.

15             THE ACCUSED: [Interpretation] I said that the general said, not

16     that he saw.  He said that he read from the document that these command

17     posts were at localities that he indicated as being within the city

18     areas.

19             THE WITNESS: [Interpretation] May I answer?

20             MR. KARADZIC: [Interpretation]

21        Q.   Yes, General, sir.  Can you please tell us, all those command

22     posts and all of that that refer to the 12th Division, all of that, was

23     that in the city of Sarajevo itself?

24        A.   Yes, yes.  Just allow me to clarify that a little bit, the

25     question of that structure, the command structure.  That is a key

Page 32545

 1     structure for the -- for any combat unit.  No one can act in any way if

 2     they don't have a command that would provide guidance.  And may I add,

 3     with the indulgence of the Trial Chamber, when my lawyer -- actually, he

 4     just talked about the number of people.  There are 50.000 people in

 5     Sarajevo, 50.000 people in Sarajevo, and so on and so forth, and I said

 6     that that was not sufficient, because if the people are disorganised and

 7     there's no command, then it's just a mob and nothing else.  We're talking

 8     about organised structures here with a command structure that is

 9     developed, and this is what is significant.

10             It is correct that these command posts were located in the city.

11     When it says in the park, in the park that is in the Trapare Street, and

12     that is a street and an area that I am familiar with.  I know where it is

13     located.  It's in the centre of the city.  Specifically, the command of

14     the 12th Division was located in the Skenderija sector and the brigade

15     commands practically in the same way had their own command posts just

16     like the corps command did in the centre of town.  All of them were in

17     the centre of town.  If we're talking about command posts, these are

18     elements that have their complete infrastructure, I would say, which has

19     to do with the system of communications, the system of security, system

20     of parking, and system of processing and preparation of food in order to

21     feed the cadre, to issue tasks, for holding meetings, to also have the

22     functioning messenger and courier service so that in the existing command

23     posts which function in Sarajevo, there is a very lively activity going

24     on constantly which was observable.  When madam said that I did not see

25     that, it's not me, but using our observation system, we could all observe

Page 32546

 1     that.  You could see all of this, and then when you look at these

 2     documents, you can see that all of that was correct.

 3             I don't know if I was clear enough, that when you talk about the

 4     system of command posts and the distribution of command posts, that it's

 5     not just one point where a person is sitting and issuing orders.  That is

 6     where everything originates from.

 7        Q.   Thank you.  Can we now look at 1D7202, and can I ask you to

 8     explain to us what this document is and what these markings are and who

 9     drafted the document?

10        A.   I can.  What I would like to stress here is that I drew this

11     myself in an attempt to just give you an idea what -- how these things

12     work.  So this is not any particular command post.  This is really just a

13     concept, a depiction of the deployment of forces at a command post.

14             So on the right-hand side where we see the communications system

15     or signals system, there are certain command organs that are connected,

16     interconnected, within this entire system.  In other words, via the

17     Chief of Staff, they all are connected to the commander.  All organs of a

18     certain command have to be there represented, including the operations

19     organ, and they're in charge of monitoring the entire situation, giving

20     proposals and guidelines.  Then there's the security organ, and attached

21     to these two, the operations and the Chief of Staff organs, we have the

22     various arms, infantry, artillery, and other arms that would be part of

23     their complement of a certain -- of any given unit.

24             The system of technical and radar support is also depicted here,

25     and this is in fact the key service.  All the other elements are just

Page 32547

 1     auxiliary elements such as security units, military police units, and

 2     very close to them are the reconnaissance companies, depending on the

 3     unit, because not every unit would have a reconnaissance company.  Then

 4     there is also the area for the military police, and we see the location

 5     where food is prepared as well as supplies for the organs that are in

 6     that area that operate there.  And we also see support services or

 7     support resources for fire purposes in the event that this command post

 8     would be discovered and that somebody opened fire on them.

 9             So this would be a battery, an elaborate battery for the

10     protection of the command post.

11             THE ACCUSED: [Interpretation] Thank you.  Could the usher please

12     assist the general with the pen so that he can mark this on his drawing.

13             MR. KARADZIC: [Interpretation]

14        Q.   And could you please tell us where it says at the bottom an

15     elaborate or developed command post?  What does that mean?

16        A.   Well, that's what it means.  It means that this is a depiction of

17     an elaborate developed command post with all the services that are within

18     it.

19        Q.   Thank you.  Could you please tell us what the designation there

20     which says "Staff Command" or "Headquarters Staff"?

21        A.   Well, they are the assisting organs that assist with logistics,

22     that provide logistics for a system like this.

23             For instance, a brigade would have its logistics department; so

24     does a command post.  It has to have its own logistics, and it is called

25     staff -- headquarters staff.

Page 32548

 1        Q.   Thank you.  Could you please put a number 2 where it says IC or

 2     Ech.  What does that mean?

 3        A.   Well, that is the reconnaissance company.  That's all it could

 4     mean, nothing more.

 5        Q.   Thank you.  And the other marking there where it says "Potential

 6     force -- intervention forces," what does that mean?

 7        A.   Well, each command post has to have a unit nearby that is to be

 8     employed for interventions.  Now, how large that unit should be, the

 9     intervention unit, that would depend on the circumstances.  If the

10     commander feels that he should have an intervention unit, then he would

11     establish it.

12        Q.   Thank you.  Could you please put the number 3 next to the

13     possible intervention force?

14        A.   Here it is.

15        Q.   Could you please put a number 4 next to "CVP" or "CVP" and tell

16     us what that is?

17        A.   Well, that is the Military Police Company.

18        Q.   Thank you.  Could you put a number 5 next to the parking area.

19        A.   That's probably a universal international signal for parking.

20     Well, here it is.

21        Q.   What is "Pija"?  There is something there which reads P-i-j-a.

22     What is that?

23        A.   Well, that is the reception area.

24        Q.   Could you tell us there at the top what that is and mark it?

25        A.   Well, I'll put number 7 here, and that's the artillery battery.

Page 32549

 1     It's a support unit.

 2        Q.   Support -- in support of what?

 3        A.   Well, in the event that the command post is discovered and is

 4     targeted, if the sector of the command post is targeted, then there must

 5     be a support unit that would be used to neutralise the enemy.

 6        Q.   Thank you.  Now, could you move to the right and tell us what

 7     this image, the tripod there, what is that?  What does that depict?

 8        A.   Well, that's the radar, so I'll put an R next to number 8.  I

 9     apologise.  In fact -- my apologies.  I really am sorry.  It's my fault.

10     This is a radio relay device, in fact, a radio relay device which assists

11     in maintaining communications with the brigades.  The commander has

12     communication with brigades and subordinate units.

13        Q.   Thank you.  What does this CV stand for?  CV, communications

14     centre.

15        A.   Well, yes, that's what it means, the signals centre or

16     communications centre.  Here's number 9.

17        Q.   Could you now tell us what this POM stands for, POM and then

18     Moral, M-o-r-a-l.  What does that mean?

19        A.   Well, that's the assistant for morale.  Well, this is the heart

20     of the command.  The command -- the commander has everything tied to him.

21     So he has the assistant for morale, an assistant for intelligence, and

22     also an entire structure at his disposal to enable him to monitor the

23     operation that he's in charge of.

24        Q.   Thank you.  Well, you don't have to go -- we don't have to go any

25     further -- into any further detail here.  It will be translated.  But can

Page 32550

 1     you tell me what this flag represents?

 2        A.   Well, each command has its own flag.  So this would represent

 3     schematically the command post of the division.

 4        Q.   Would you put a number 10 next to it, and could you tell us what

 5     the marking for a brigade or a battalion would be?

 6        A.   Well, I could show you if you give me a piece of paper so I could

 7     draw on it -- or maybe I can try doing it here.  So this type of flag

 8     would indicate a battalion, a command post of a battalion, because you

 9     have to make a distinction, because not all commands are of the same

10     level.

11        Q.   Thank you.  Please put a number 11 next to it, and please date

12     and sign this drawing.

13        A.   Okay.  So it's the 23rd.

14             THE ACCUSED: [Interpretation] I would like to tender this

15     document, please.

16             JUDGE KWON:  Ms. Edgerton, would you agree that we need a

17     translation of this?

18             MS. EDGERTON:  Yes, and I'm actually not sure how my colleagues

19     who are very qualified will be able to deal with the very slim

20     abbreviations and acronyms.  It might be more useful if the general

21     explains them.

22             JUDGE KWON:  The remainder that he hasn't explained.

23             MS. EDGERTON:  Correct.

24             JUDGE KWON:  Will you start with the security, Mr. Milosevic, OB.

25             THE WITNESS: [Interpretation] I see.  OB stands for security and

Page 32551

 1     intelligence, a security and intelligence organ.

 2             JUDGE KWON:  Number 10.

 3             THE WITNESS: [Interpretation] Sorry, let me just explain.  This

 4     can only be -- this can be either an intelligence organ or an

 5     intelligence plus security organ, both.  They could both be.

 6             THE ACCUSED: [Interpretation] Twelve, your Excellency.

 7             THE WITNESS: [Interpretation] We already have an 11.

 8             JUDGE KWON:  Correct, 12.  And 13 for the commander.

 9             THE WITNESS: [Interpretation] Thirteen for the commander.  Here

10     it is.  His vehicle is there, and he's always ready to be on the move.

11             JUDGE KWON:  And 14 for Chief of Staff.

12             THE WITNESS:  Okay.

13             JUDGE KWON:  What does OC mean, Mr. Milosevic?

14             THE WITNESS: [Interpretation] Operations Centre.  It's a room

15     where operations officers sit and work.

16             JUDGE KWON:  Ms. Edgerton, do you need more explanation?

17             MS. EDGERTON:  No.

18             JUDGE KWON:  Very well.  Do we need to -- I don't think so.

19     We'll admit this marked diagram, but I will mark it for identification

20     pending -- I don't think we need translation at this time.

21             MS. EDGERTON:  No.  Now I think it's fine, Your Honour.

22             JUDGE KWON:  We'll admit it.

23             THE REGISTRAR:  As Exhibit D2793, Your Honours.

24             THE ACCUSED: [Interpretation] Thank you.

25             MR. KARADZIC: [Interpretation]

Page 32552

 1        Q.   General, sir, could you now tell us how many of these elaborate

 2     staffs or headquarters of units were there in total in Sarajevo as part

 3     of what was later to be called the 12th Division?

 4        A.   In addition to the 12th Division and its subordinate units, there

 5     were other command posts as well there, so that the number of command

 6     posts in Sarajevo were not solely restricted to the 12th Division, and

 7     I'll explain that in a moment.

 8             This division had three command posts of its own, the basic

 9     command post; the rear command post, that's a separate post; and the

10     forward command post.  So these are the division command posts alone.

11             Now, the 1st Corps had the same structure, the same, the same

12     system.  Of course it was a larger command, but there was a larger number

13     of personnel there.  There was the basic command post, the forward

14     command post, and the rear command post.

15        Q.   Thank you.  You said Danijela Ozme, at Danijela Ozme.  What does

16     that mean?

17        A.   Well, that's the Danijela Ozme Street.  That's where the basic

18     command post was.  And this is the area that they claim had never been

19     hit by anything, and of course no one would even attempt to target it,

20     because that was the centre of town itself.

21        Q.   Please go on.

22        A.   Well, in addition to these, I represented in a different form --

23     I've explained that the division numbers eight brigades, these mountain

24     brigades, and each of these brigades has a similar command post as the

25     one depicted, but perhaps with a fewer number of men.  They would all

Page 32553

 1     have these three different posts.

 2             Now, the next thing is this:  Within Sarajevo itself, there were

 3     two brigades which were located in Sarajevo itself, but they were not

 4     attached to this division but, rather, to the 1st Corps.

 5             Now, these eight brigades, separate from the ninth that I

 6     mentioned that belonged to the 14th Division which was the 104th Brigade

 7     in Hrasnica.  Brigades have their own battalions, and the total number of

 8     battalion command posts, and I stress these are smaller sites with a

 9     fewer number of men.  There were 55 of them in total in Sarajevo.  Now,

10     each of those battalions has a company.  Some have three companies, some

11     have four.  But if we add all that up, the total number of command posts

12     including the battalion companies and the independent companies that

13     belong to the 12th Division or, for instance, the

14     Military Police Company, the reconnaissance, sabotage company and so on

15     and so forth, they all existed, and their command posts that are placed

16     by the company commander with his own structures, there were 164 of

17     those.

18             I have written all this down.  I'm not sure if I've added up this

19     correctly, if I did the calculation right, but I believe that in total

20     there were 200 or so command posts in total there.

21             THE ACCUSED: [Interpretation] Would the Trial Chamber allow the

22     witness to look at his notes?

23             JUDGE KWON:  If necessary.  I don't understand any problem.

24             THE WITNESS:  Thank you.  [Interpretation] The number of command

25     posts was 275.  These were command posts for the units that I've already

Page 32554

 1     mentioned, the command posts that existed within the brigades and

 2     divisions, but I failed to mention that there is another structure there,

 3     a police command structure.  This was the special MUP Brigade.  So in

 4     addition to the others, there were eight other command posts that were

 5     command posts at Ilidza, at Pale, Vogosca -- not command posts but

 6     commands, commands that commanded forces.  They were in all these

 7     municipalities that were on the outskirts of Sarajevo.  These were

 8     military commands that existed in Sarajevo and had their own structure,

 9     but of course these were smaller.  So that's how they increased these

10     numbers.  And they were working on preparing the forces that would break

11     out of Sarajevo so that they could continue commanding those units when

12     they entered, for instance, Rajlovac, Pale, Ilidza, and so on and so

13     forth.

14             So from this we can see that they had -- that their intention was

15     offensive and the area that they called, they would use the term

16     "temporarily captured territory," which is a category that existed in the

17     one-time JNA strategy of combat, and it referred to situations where NATO

18     would carry out an aggression against Yugoslavia or the Warsaw Pact so

19     that then each area, had it been captured, would have been referred as to

20     temporarily captured.

21             Now, from this fact -- or on this fact they built this structure,

22     and the families that had lived there for ages, they were treated as

23     civilians being in captured territories, and they wanted to expel them

24     from those areas.

25             So I am just trying to say that there were these command posts.

Page 32555

 1     They were visible.  They functioned.  They commanded and directed their

 2     forces, and in the end there was fighting against those forces with us.

 3        Q.   Thank you very much, General.  What about the 275 plus 8 for all

 4     these peripheral municipalities.  What about all these command posts, the

 5     275?  Does that imply a single location or could a single command post

 6     occupy a number of different locations?

 7        A.   I think that is perfectly clear.  There are some levels that have

 8     command posts in three different versions, the basic command post, the

 9     rear command post, and the forward command post.  But a platoon or a

10     company wouldn't have that.  A company would not have a rear command

11     post.  A company commander would have his own station, then a station for

12     his combat needs.  He would have several assistants.  He would have

13     messengers and so on and so forth.  They would only be in a single

14     location, the company would, because that is a lower level so to speak.

15        Q.   And what about larger units, a command post in a single location

16     or perhaps in several different locations?

17        A.   No.  There would be three locations, as I said, in order to be

18     able to operate.  That is the first thing.

19             Secondly, they wouldn't even need to be in a single location,

20     strictly speaking.  There would be some distance between the various

21     sections of the command.  Just to name an example, the 104th Brigade, for

22     example, has a part of its command in Butmir, and the 104th Brigade is

23     the brigade that we're talking about.  It operates and exists in the

24     Hrasnica area.  So a part of it is there.

25             And then if I may just clarify now that I've been given an

Page 32556

 1     opportunity.  In the Butmir area and the Sokolovic Kruna area, you can

 2     also find a part of the corps command.  I didn't indicate their existence

 3     here as a separate component.

 4        Q.   Thank you very much.  Could you please tell us where the

 5     Supreme Command of the BH Army was located?

 6        A.   Truth to tell, I don't know.  It is known that the Presidency

 7     occupied the Presidency building.  I'm not sure if they saw the same

 8     building also as their Supreme Command.

 9        Q.   What about elements of the Main Staff of the BH Army within the

10     city itself, because that's what we're talking about, the city itself.

11        A.   Yes, I understand that.  The part of the General Staff command,

12     the part, and that is why they had some men there for their own security,

13     the Guards Brigade, a unit that we have not mentioned so far, although it

14     was there in addition to all the brigades that I have so far enumerated.

15     So a part of the General Staff command was indeed in Sarajevo in a number

16     of different locations, as a matter of fact.  And I can't say for sure

17     what those locations were.

18             The remainder, and the principal component of the command was

19     the --

20             THE INTERPRETER:  The interpreter did not hear the location.

21             MR. KARADZIC: [Interpretation]

22        Q.   What about the 1st Corps command?  Was it in the city itself or

23     elsewhere?

24        A.   Yes.  The 1st Corps command, as I said, was at

25     Danijela Ozme Street near the main hygiene office.  There's a big park in

Page 32557

 1     the middle of Sarajevo, just across the street from the Presidency

 2     building.  It's difficult to keep track, because I have forgotten a lot

 3     of the streets involved, although I did live there at one time, but I

 4     think I'm right about this.  It was across the way from the Presidency

 5     building.

 6        Q.   Thank you very much.  General, sir, you mentioned the division

 7     artillery group.  Were there other artillery groups, and can you explain

 8     what weapons were available to the 12th Division within the city itself?

 9             THE ACCUSED: [Interpretation] I would like the Chamber to rule

10     whether the general is allowed to use his notes.

11             JUDGE KWON:  Yes.

12             THE WITNESS: [Interpretation] It's not very practical for me to

13     use so.  It's slightly complicated, because I don't have my notes in

14     electronic format.

15             So there was the structure that was shown as the command

16     structure with all of its elements.  And then I also have this

17     information here, reliable information, on combat equipment.  If I may, I

18     have a lot of information to share here, and I'd just like to specify the

19     provenance if the Chamber allows, what the supply sources were, where all

20     of this came from.

21             JUDGE KWON:  Yes, Ms. Edgerton.

22             MS. EDGERTON:  I think we need to explore that, Your Honour,

23     because this is not about the general, with respect, testifying on the

24     basis of his notes.

25             JUDGE KWON:  I have no clue what the -- what general was

Page 32558

 1     referring to.  It's for Mr. Karadzic to take up this, but -- yes,

 2     Mr. Milosevic, what document were you referring to?

 3             THE WITNESS: [Interpretation] I would like to make one thing

 4     clear.  I wanted to say what the indicators are telling me that the

 5     numbers here are true and that these numbers existed.  If I may be

 6     allowed to explain that.  You will receive an answer, because that will

 7     then tally with the previous confirmation.

 8             JUDGE KWON:  The question you were asked about is the artillery

 9     group, and in particular what weapons were available to the 12th Division

10     within the city itself.  So you can tell us what weapons were available,

11     not necessarily the numbers.

12             THE WITNESS: [Interpretation] Yes.  I understand.

13             MR. KARADZIC: [Interpretation]

14        Q.   If I may, General, sir, if I may assist.  According to your

15     records, according to your information, how many mortars, 80-millimetres,

16     62-millimetre -- 82-millimetre, 60-millimetre, and 122-millimetre mortars

17     were there in the city itself?

18        A.   I can proffer some information that will corroborate this, if I

19     may, just in order to follow a sequence that will confirm the existence

20     of these figures.  So if I may, if the Chamber can allow me to explain

21     that I can move on to the figures afterwards because that is quite --

22     well, you know.

23             JUDGE KWON:  Let's hear him out, Ms. Edgerton.

24             Yes, please proceed, Mr. Milosevic.

25             THE WITNESS: [Interpretation] There's a story behind all of this.

Page 32559

 1     When the crisis first began in the former Yugoslavia and combat equipment

 2     was brought in from Croatia, from Slovenia, and from elsewhere, why was

 3     it being brought to Sarajevo?  I don't know.  What I do know is that it

 4     was now there.  Specifically, it was now at the Marsal Tito Barracks at

 5     the Jusuf Dzonlic Barracks, and some of it went to Lukavica; meaning when

 6     the situation finally began to unravel, when certain areas were created

 7     under the control of this party or that party, then all this equipment at

 8     the Marsal Tito Barracks, Jusuf Dzonlic, Jajce, Victor Bubanj, all these

 9     military compounds, the weapons were kept there, held back, and ended up

10     in the hands of the 1st BH Army Corps.  All the companies that used to

11     operate in existent peacetime, these were large-scale systems and they

12     all had their anti-aircraft weapons or anti-aircraft weapon systems.

13     That was part of the protection set-up.  So everything that was there was

14     now within the 1st Corps.

15             In this case we're talking about the 12th Division, in a narrower

16     sense.  The more weapons that came in simply boosted these figures.

17             Now there was this entire infrastructure in place in terms of

18     accommodation, in terms of command, in terms of the supplies, logistics,

19     repairs.  This was all now in the hands of the 1st Corps.

20             As for any military facilities that ended up in the hands of the

21     Sarajevo-Romanija Corps, there was only one such facility, Lukavica.

22     It's also true that some of the equipment ended up in Lukavica and that

23     was where it stayed.  I'm talking about the equipment coming in from

24     Croatia, Slovenia, and other territories across the former Yugoslavia.

25             So when I say that there were six howitzers, 120 millimetre, it's

Page 32560

 1     a self-propelled weapon, these are the same howitzers that ended up in

 2     the Marsal Tito Barracks.  So as soon as the men pulled out, students,

 3     pupils, secondary military school, military academy, and so on and so

 4     forth --

 5             THE INTERPRETER:  The interpreter did not hear the last part of

 6     the witness's answer.

 7             THE WITNESS: [Interpretation] Everything else that I'm talking

 8     about here are weapons that ended up in that area and they now had them.

 9     The weapons were available to them.  Talking about anti-aircraft,

10     PAT 20/1 and 20/3, these came from the previously operating civilian

11     companies that I mentioned and these weapons were part of the erstwhile

12     protection and defence set up.

13             So if we put this all together, 60 millimetre, 82- and

14     120-millimetre mortars, there were between 140 [Realtime transcript read

15     in error "100"] and 150 of those in the city itself.  Howitzers,

16     122-millimetre, the self-propelled howitzer, six of those;

17     105-millimetre, three howitzers; T-55 tank, three of those;

18     130-millimetre gun, and to be quite specific, it was not in Sarajevo.  It

19     was on Mount Igman, and it was firing Sarajevo from Mount Igman because

20     the range for that particular gun is over 30 kilometres; 76-millimetre

21     gun called ZiS, it's a reference to Stalin.  Four of those were

22     available; recoilless cannons, 82-millimetres, we discovered that they

23     had a total of 16 of those, but possibly many more than that that we

24     didn't find.  So when you fire this cannon, you can see it from miles

25     away, because normally when it fires there's a plume of smoke rising from

Page 32561

 1     the gun.

 2             What I didn't say, all of the weapons of the special brigade for

 3     Yugoslavia.  I'm talking about the MUP.  I'm not sure what they called it

 4     at the time.  There was this special brigade whose task it was to prevent

 5     terrorism.

 6             So this equipment was kept at a location known as Krtelj, which

 7     is right next to Donji Kotorac.  Earlier on we said that the

 8     104th Motorised Brigade was stationed there.

 9             So this was a selection of equipment, APCs, and what was known as

10     Vidra.  All of this was, in a manner of speaking, grabbed by the MUP,

11     Sarajevo's police.  Then it stayed there and was used as combat

12     equipment.

13             These are sophisticated weapons.  These are wood weapons, and

14     commanders were using these to drive across Sarajevo and not expose

15     themselves to danger, although actually it was meant to be used by

16     someone else, but that was a different matter altogether.

17             So everything that I've been telling you about is in relation to

18     1994.  I'm talking about this period and information telling us what

19     weapons were available to the corps command, and then additional weapons

20     started coming in for the 1st Corps in its entirety with equipment coming

21     in from wherever, further afield, and their friends were helping.  And

22     these are the Crna Strela rockets, and the 9K11 rockets, and then

23     107-millimetre rockets, the so-called VBRs, multi-rocket launchers.

24             JUDGE KWON:  General, could we pause there.  Could we see the

25     memo or document you are looking at now with the assistance of the usher

Page 32562

 1     through the ELMO.

 2             I see the time.  Shall we take a break now?  In the meantime,

 3     you'd like at that take a look at the document, Ms. Edgerton, yourself?

 4             MS. EDGERTON:  If it's what I think it is, the General's just

 5     read most of page 6 of his aide-memoire into the record, but I will take

 6     a look at it to confirm that.

 7             JUDGE KWON:  In English, what page it would be?

 8             MS. EDGERTON:  English page 6.

 9             JUDGE KWON:  Did the Chamber receive that aide-memoire?

10             THE ACCUSED: [Interpretation] I believe that it did.  The Serbian

11     version is in the -- in the handwriting is page 11.  It was sent by

12     electronic -- it was sent out on Sunday electronically.

13             JUDGE KWON:  What Chamber received is a document titled proofing

14     note.

15             MR. ROBINSON:  Yes, Mr. President.  The exact situation is that

16     you didn't receive the English.  So only the Prosecution received that.

17             JUDGE KWON:  That's why I was asking.  We'll take a break for 45

18     minutes and resume at 1.25.

19                           --- Luncheon recess taken at 12.39 p.m.

20                           --- On resuming at 1.26 p.m.

21             JUDGE KWON:  Now I understood the nature of the document you

22     relied on, but where did you get those information, Mr. Milosevic, which

23     is written on this document which we see now in front of us?

24             THE WITNESS: [Interpretation] I -- well, the information is the

25     result the direct discovery of the existence of firing position and the

Page 32563

 1     fire from these weapons from the relevant firing positions from the

 2     Sarajevo area.  This is one source of the information.  This is through

 3     the observation system and by observing the existing weapons as they were

 4     firing and also while the weapons were being transferred from one firing

 5     position to another.  This is one type of information.

 6             Then in the system of their documents, documents created by the

 7     commands that we're talking about from the 1st Corps or from the 20th --

 8     12th Division according to the type of fire they were planning and the

 9     actual firing that they executed, we worked out what their resources were

10     in this sense at their disposal.  There is a document.  These are their

11     original documents in which General Siber divided 100 mortars,

12     60-millimetre -- 160-millimetre mortars were distributed to the units.  I

13     really couldn't see that many, but it turns out that there were one

14     hundred 60-millimetre mortars.  I don't know if they fired or not.

15     That's a different matter.  That would be that.

16             JUDGE KWON:  Very well.  I'll leave it at that.

17             Please continue, Mr. Karadzic.

18             Just one matter.  For the record, Mr. Milosevic, you referred to

19     Lieutenant-Colonel or Colonel Dzambasevic.  I take it his name is

20     Dzambasovic, not s-e-v-i-c with last five letters s-o-v-i-c.

21             THE WITNESS: [Interpretation] Dzambasovic.

22             JUDGE KWON:  It appears on transcript page 4, line 16, 22, and

23     24.  And he was one of the Prosecution witnesses, Ms. Edgerton?

24             MS. EDGERTON:  Correct.

25             JUDGE KWON:  Thank you.  Please continue.

Page 32564

 1             THE ACCUSED: [Interpretation]

 2        Q.   General, sir, on page 66, line 10, I heard you say that there

 3     were between 140 and 150 mortars, but in the transcript it states between

 4     100 and 150?

 5        A.   What is correct is what is written.  That's what I should have

 6     said, and that's probably what I said, that there were between 140 and

 7     150 mortars.

 8        Q.   Thank you.  General, I admire your thoroughness and I'm very

 9     grateful for that, but we really must now start dealing with conduct and

10     actions and things like that.  So we need to complete this as soon as

11     possible.

12             Are you able to tell us whether all of these resources were

13     stationary or whether some of them were movable and would appear in

14     several places and how was this done?

15        A.   My screen is not working.  I don't know.

16        Q.   Do you have page 11 in front of you now?

17        A.   Yes, yes, I do have it.  I thought that I had to see your

18     questions on the monitor.  All right.  Very well.  Thank you.

19             It's quite clear that these were not stationary weapons.  None of

20     them were stationary and installed only in one place.  It's a rule, it's

21     a principle that weapons would change their firing positions because they

22     would be discovered when they are used and so on and so forth.  So some

23     of them were stationary, some were not, but generally speaking, their

24     positions would change.

25        Q.   Thank you.  Were there any mobile resources of large calibre that

Page 32565

 1     could be fired?

 2        A.   Of course, there were.  I don't know if I should describe it as a

 3     major folly, but there were vehicle-mounted weapons.  They would be

 4     fired, and then they would be moved away.  I don't consider that to be

 5     warfare with any kind of logic or anything that would take into account

 6     the rules of warfare.

 7        Q.   Thank you very much.  And these mobile assets, they were fired

 8     from which areas?

 9        A.   Those assets often moved from the Zitomlin sector.  This is the

10     area of the Blagoje Parovic Street or possibly behind some larger

11     buildings so that they would be less noticeable, but always you would

12     notice if they were fired.  In any case, they were mostly around the

13     Blagoje Parovic Street.  This is the new Sarajevo, centre of new

14     Sarajevo.

15        Q.   Thank you.  In order to finish with this question of the

16     deployment of forces, could you please tell me whose forces, for example,

17     were in Hrasnica, Sokolovic Kolonija, and Butmir?

18        A.   It's very important that I should give a clear answer to this

19     question.  This is the 104th Motorised Brigade that we're talking about

20     here, which by its size was third largest brigade in that area.  As for

21     its combat assets, it was a brigade that had the greatest amount of these

22     assets.  That was the 104th in the area of Hrasnica, Butmir,

23     Sokolovic Kolonija, and the eastern slopes of Igman.

24        Q.   Thank you.  Perhaps we could call up a map which we marked

25     earlier with a witness, foreign witness, and then we could ask you to

Page 32566

 1     tell us whether the map correctly reflects who is where.  Can we look at

 2     1D32243, please.

 3        A.   Yes, yes.

 4        Q.   Could you begin from the south?

 5             THE INTERPRETER:  The interpreter did not catch the names.

 6             MR. KARADZIC: [Interpretation]

 7        Q.   You told us who was there.  Who was in Dobrinja in that central

 8     area?

 9        A.   The 155th Mountain Brigade was in Dobrinja, and as I said it was

10     under the command of Hadzic, Ismet Hadzic, a civilian.

11        Q.   Thank you.  And who was at these elevations at Mojmilo Brdo and

12     Hrasno Brdo?

13        A.   The 101st Mountain Brigade was there.  That entire line was held

14     by them from Hrasno Brdo all the way down to the Miljacka.

15        Q.   Thank you.  Who was at Debelo Brdo and Colina Kapa?

16        A.   The 115th Mountain Brigade.

17        Q.   And you're talking about brigades that were part of the

18     1st Corps; is that correct?

19        A.   Yes, of course.

20        Q.   And who was at Jajce?  What does that mean, Jajce, and who was

21     there?

22        A.   Jajce is a barracks.  It's a military facility.  That's where the

23     152nd Brigade was.  It was somewhat smaller in terms of its strength and

24     Hilmo Kovac was in command.  He was an officer that I admired highly,

25     even in his conduct towards the enemy he was knightly, chivalrous.

Page 32567

 1        Q.   Thank you and who was at Grdonj?

 2        A.   Well, I'm not managing to wait for this -- ah, all right.  In

 3     Grdonj and in a broader area than that, but specifically at Grdonj the

 4     105th Mountain Brigade was situated.  It was under the command of

 5     Major Izet Bisevic.

 6        Q.   Can you tell the Trial Chamber about the Grdonj and the

 7     disposition of the 105th Brigade, and how did that relate to

 8     Spicasta Stijena and the village of Mrkovici?  Could you please mark the

 9     village of Mrkovici here on the map.

10             MS. EDGERTON:  Your Honour.

11             JUDGE KWON:  Yes.

12             MS. EDGERTON:  Just for the sake of the record, it's a satellite

13     photograph, not a map.

14             THE WITNESS: [Interpretation] Should I mark this?

15             MR. KARADZIC: [Interpretation]

16        Q.   Well, you can mark it in black because in the original we are --

17     already have markings in red and blue.  Could you please mark Mrkovici

18     and could you please tell us what -- the census of the events around

19     Spicasta Stijena and Mrkovici?

20        A.   I'm not going to be able to pinpoint Spicasta Stijena here.  All

21     I can do is indicate the direction in which it could be in relation to

22     the Grdonj location.  This is here in this area, which has to do with the

23     disposition of the 1st Corps.  The forces of the Sarajevo-Romanija Corps

24     were not at Spicasta Stijena.  They were in the area of Mala Kula, and

25     that area is behind Spicasta Stijena.  And this is what -- is something

Page 32568

 1     that is being stated throughout the whole course of things that we were

 2     at Spicasta Stijena, but actually it's just a normal area, not a rock or

 3     a -- anything like that, and that's where the forces of the

 4     Sarajevo-Romanija Corps were.

 5        Q.   All right.  Thank you.  Could you mark the village of Mrkovici

 6     with a number 2.

 7        A.   I don't see the word indicating the village of Mrkovici, but I

 8     know where it is.  So it would be somewhere here.  Mrkovici.

 9        Q.   Thank you.  And, General, sir, are you able to tell us briefly

10     why in the reports Spicasta Stijena is mentioned so frequently?  Mrkovici

11     as well.  What were the military activities there, and what was the

12     purpose of the same?

13        A.   The key area that is of particular significance for the

14     Sarajevo-Romanija Corps is the road leading from Pale via Sumbulovac to

15     Vogosca, and then on to the rest of the front covered by the

16     Sarajevo-Romanija Corps, that road passes in the immediate vicinity of

17     the village of Mrkovici.  As for the 1st Corps, or, rather, the

18     12th Division, what was key was to attempt to cut off this road and in

19     that way divide in two our front, one in the north-west and the other

20     part would stay in the south, south-east or south-western area.  So their

21     activities were aimed via Spicasta Stijena at Mrkovici with the objective

22     of severing the road and gaining a military advantage.  Our situation did

23     not permit us to lose this military advantage in terms of how we would

24     live and function and carry out our combat activities.

25             The attacks and the assaults were daily, and I'm not exaggerating

Page 32569

 1     when I say this.  However, the minor ones are not that important.  They

 2     attempted to break through with a considerably strong force, and then in

 3     the situation when they were prevented from doing that, then they would

 4     not report that somebody was firing at Sarajevo.  They would say the

 5     Chetnik forces turned us back to our positions.  So meaning that we fired

 6     at their positions and not at the city.  This is one thing, an attempt to

 7     concentrate forces.

 8             So this main thrust was attempted on the 18th of September, 1994,

 9     and it was not only directed at Spicasta Stijena and the axis towards

10     Mrkovici but other axes as well.  This attack was prevented.  It was

11     stopped.  I came to that place where there were soldiers attempting to

12     break through, encountered some of our mines, and in one place I could

13     see seven dead people there, men who were killed, and I couldn't help

14     myself.  Your Honours, if you believe me, I cried over those dead bodies.

15     It was sending people to their death.  That's what it was.  Seven people

16     in one place were beheaded.  Their limbs were blown off in that mine

17     explosion.  And I asked myself, who is it that is sending those people

18     towards us without any proper estimation?  These people were not skilled

19     for these tasks.

20        Q.   Thank you.  General, sir, who defended Mrkovici from the

21     Sarajevo-Romanija Corps, which unit?

22        A.   The entire -- the entire area between the Miljacka canyon where

23     Miljacka flows into Sarajevo, as I mentioned earlier, via Hresa, and the

24     positions at Mrkovici, Radava, Poljine, all the way to Rajlovac and the

25     place where the Miljacka flows out of Sarajevo, all these positions were

Page 32570

 1     held by the 3rd Sarajevo Brigade.  That was the main force and the only

 2     force that held the entire north-west and part of the north-eastern part.

 3        Q.   Thank you.  Where were these soldiers from?

 4        A.   What soldiers?

 5        Q.   Well, the members of the 3rd Brigade?  Where were they from?

 6     Where did they hail from?

 7        A.   Well, not just them when talking about the 3rd Sarajevo Brigade,

 8     but this will imply to -- this will be true of all those who were in

 9     Sarajevo.  They were all from the areas, for instance, from Vogosca,

10     Rajlovac, Poljine, Mrkovici, Hresa, in other words -- from Bulog [phoen].

11     In other words, from those villages and the surrounding areas that were

12     there.  They were mobilised from there and became members of the

13     3rd Sarajevo Brigade.

14        Q.   Thank you.  Could you please indicate on this image, this

15     satellite image, where Sedrenik was vis-a-vis Grdonj and what military

16     installations there were there if there were any, and what was the

17     distance between Spicasta Stijena and your positions and Sedrenik?

18        A.   Well, first the area of Grdonj, that's the line that was covered

19     by the 12th Division of the 1st Corps, and they had the 105th Brigade,

20     which I mentioned earlier.

21             Now, behind them or in there in their area was Hresa -- or

22     rather, not Hresa but --

23        Q.   Sedrenik?

24        A.   Well, that's correct, Sedrenik.

25        Q.   Well, where is Sedrenik?  Could you mark it with an S on these

Page 32571

 1     slopes below Grdonj?

 2        A.   Well, it should be here approximately.  This is the area right

 3     below Grdonj toward the town itself.

 4        Q.   Did you have any snipers deployed at Spicasta Stijena, and would

 5     they have been in a position to open fire from Spicasta Stijena?

 6        A.   Well, no.  These are great distances, so it would be absolutely

 7     impossible to use any type of infantry weapons.  You could only use

 8     artillery, of course.

 9        Q.   Well, the artillery that was in Mrkovici village, what did they

10     open fire at?

11        A.   Well, no.  The artillery was withdrawn, was extracted from there,

12     and it was placed under the command of UNPROFOR.  It was centred in

13     certain areas.

14        Q.   Well, my apologies.  Mortar tubes.

15        A.   Well, they too.  And I'm talking about the period when UNPROFOR

16     had made sure that all weapons would be placed under control.  So the

17     mortars were under their control as well.

18        Q.   Thank you.  Would you please now go on.  Let's take a look at

19     Kobilja Glava, Hum, Zuc, and Sokolje.  Who was in control of those hills

20     or elevations?

21        A.   Certainly.  Hum was within the system of deployment of the city

22     itself, except it was at a higher elevation.  But Kobilja Glava and Zuc,

23     let's talk about that.  But there is no Orlic mentioned here or indicated

24     here.  And that was the highest elevation there between Kobilja Glava and

25     Zuc, 800-something metres.  Orlic, mount -- or a hill -- a peak, a

Page 32572

 1     mountain peak.  This was the area that was under the control of the

 2     112th Division -- or, rather, brigade.

 3        Q.   Would you please indicate Orlic hill.  What about Sokolje.

 4        A.   Well, we'll come to Sokolje.  Orlic would be about here

 5     approximately.

 6        Q.   Can we take that to be the letter O?

 7        A.   Yes.

 8        Q.   And now could you just tell us who had control of Sokolje?

 9        A.   The area of Sokolje -- well, let me just make one thing clear.

10     Sokolje was both a hill, and there was also a settlement, a place where

11     people lived called Sokolje.  And that was under the control of the

12     111th Mountain Brigade of the 1st Corps -- or, rather, of the

13     12th Division.  This position is dominant over Rajlovac, so the entire

14     area of Rajlovac and the Sarajevo field are below these elevations such

15     as Sokolje, Bresce Brdo, and so on and so on and so forth.

16        Q.   Thank you.  We don't have time now to ask you to mark Balino Brdo

17     and Bresce Brdo, but --

18        A.   Well, here.  It's right here, right next to Sokolje, Bresce Brdo,

19     and I'll put a B there.  But I don't see -- well, it's a bit lower than

20     it should be.

21        Q.   Would you please date and sign this image in the bottom right,

22     and could you tell us whether you would make any alterations to this

23     image in terms of what areas were under the control of the BH Army?

24        A.   Well, there's no need to make any alterations.  I would just like

25     to make it quite clear what the situation was with the Nedzarici area.

Page 32573

 1     It was in disastrous position.  It was semi-surrounded and under attack,

 2     the objective being to destroy it.

 3             THE ACCUSED: [Interpretation] I'd like to tender this document,

 4     please.

 5             JUDGE KWON:  Yes.

 6             THE REGISTRAR:  Exhibit D2794, Your Honours.

 7             THE ACCUSED: [Interpretation] Thank you.

 8             MR. KARADZIC: [Interpretation]

 9        Q.   General, sir, at the beginning of your evidence today, you

10     mentioned the intentions, the objectives of the 1st Corps of the BH Army.

11     Could you --

12             JUDGE KWON:  Yes.  Just a second.  Yes, Ms. Edgerton.

13             MS. EDGERTON:  I'm very sorry, Your Honours.  Just to note with

14     respect to this document which I see is entitled in e-court "Annotated

15     map based on Harland markings in court," Your Honours may recall -- well,

16     in fact I direct Your Honours to page 2371 where there was a discussion

17     of that map, and Mr. Tieger indicated on my behalf that the map which you

18     now see in front of you is a map that included locations which were not

19     only generally referenced by Mr. Harland but also additional locations

20     requested by the accused.  So I just wanted to make that clarification

21     when I saw the title of the document.  It's not necessarily reflective of

22     locations marked by Harland at all.

23             JUDGE KWON:  I remember I encouraged some discussion and to reach

24     an agreement, and I take it that such agreement has never been reached.

25             MS. EDGERTON:  But we did engage in discussion in good faith,

Page 32574

 1     both parties.

 2             JUDGE KWON:  You have no problem admitting it as such?

 3             MS. EDGERTON:  No, no.

 4             JUDGE KWON:  With that caveat.

 5             MS. EDGERTON:  Of course.

 6             JUDGE KWON:  Thank you.

 7             Let's continue, Mr. Karadzic.

 8             MR. KARADZIC: [Interpretation]

 9        Q.   Today on page 11, you mentioned the objectives, the intentions of

10     the 1st Corps as well as the purpose of their activities.  Could you tell

11     us briefly what the intention of the 1st Corps of the BH Army was, and in

12     particular, the objective of its -- the intention of its 12th Division,

13     and that in relation to your area.

14        A.   Well, there is no brief answer to this question, but I'll try to

15     be as brief as I can.  The intention was to break through the front line.

16     Now, to be more specific, all operations that were directed through

17     Nedzarici along that axis towards the west had the objective of linking

18     up with airforces in Butmir and Hrasnica.  Now, the forces that were in

19     that area, our forces, my forces, they were exposed to constant and total

20     barrage fire with the strongest assets.  That's number one.  And as far

21     as we could assess the intentions of the enemy, and it's not difficult,

22     it's easy to assess what an enemy's intentions are in a situation like

23     this.  Now, the next thing.  The cutting off of the road that I mentioned

24     earlier, the road between Pale and Vogosca, that action, that operation,

25     was carried out on the eastward axis via Spicasta Stijena and Mrkovici,

Page 32575

 1     and that's where the road is.  It's in the vicinity near Mala Kula where

 2     our forces were deployed.  So if our forces were to be cut off there,

 3     then we would lose contact with several brigades.

 4             Next, there was an absolute attempt, and they did everything in

 5     their power, to cut off the communication leading toward Trnovo from the

 6     area of Mount Igman.  In other words, from the positions from which the

 7     104th Motorised Brigade engaged us.  So if they were to cut off the road

 8     at Krupac, which was close to Vojkovici village, if that were to happen,

 9     we would lose that part of the front line, and we would have no access to

10     it.

11             The other operations that I could tell you about also had to do

12     with attempts to cut us off in order to prevent us from moving and using

13     our units along the axis between Semizovac towards Nisici.

14             In the area of Srednje village they were in a dominant position

15     which was 800 metres at an elevation of 800 metres, so this road was

16     threatened, and if the road leading to Nisici were to be cut off, then

17     our entire area of Ilidza would be cut off and completely surrounded,

18     including Rajlovac, Hadzici, Vogosca, and Semizovici, not to mention what

19     the situation like with Ilijas.  So these were their general intentions,

20     and they kept trying to resolve this and to get it done and finally they

21     did with a Tekbir operation.

22        Q.   Thank you.  Now, you mentioned that -- the term temporarily taken

23     or temporarily captured territory.  What did that -- what meaning did

24     that have in terms of their intentions?  What was its significance?

25        A.   Well, they legalised, as it were, or legitimised their own

Page 32576

 1     actions.  So this was a temporarily taken position.  This meant that

 2     whenever an area was defended and protected by where the

 3     Sarajevo-Romanija Corps had its forces, they considered that those were

 4     areas that they could legitimately put back under their own control.  So

 5     this is the significance of the temporarily captured or -- territory.

 6     And I repeat that the original meaning of that was it was used in the

 7     event of a foreign aggression where people would have the right to defend

 8     themselves and there would be people living there, houses of Trapare and

 9     Ivcici and so on.

10        Q.   Thank you.  Now, what significance would this have on the entire

11     war operations in Bosnia and Herzegovina had the 1st Romanija Corps --

12     the 1st BH Army Corps managed to break out of Sarajevo and move on?

13        A.   What that would mean?  A disaster, a catastrophe.  That was

14     overambitious.  It was not realistic.  And there was an excess of

15     attempts to make it seem as if nobody would be left with anything else,

16     that everything belonged to them.  I don't want to go into what belonged

17     to whom, but I just know what the task of the Sarajevo-Romanija Corps

18     was.  That was to defend the area where they were deployed.  However,

19     that is abundantly clear.  Such a force, should it break through, would

20     advance and overwhelm the entire territory of Bosnia and Herzegovina.

21     And I would like to just point out here that it -- I'm not here in order

22     to worry about the Republika Srpska -- or, rather, the Sarajevo-Romanija

23     Corps' corps did not concern itself with the territory of

24     Republika Srpska.  Our job, our task was to defend that area where we

25     were deployed.  But were they to break through that would automatically

Page 32577

 1     jeopardise the rest of the territory.  But I don't want to go further

 2     into that and elaborate, because had they managed to cut off the

 3     Rogoj Pass and connect, link up with Gorazde, then Herzegovina would have

 4     been lost.  It would be cut off, and it would remain encircled.  They

 5     would have encircled it.  So that's how it was.  In other words, you

 6     would have had to be a giant in order to be able to fight back and fight

 7     with them.

 8        Q.   Can you tell us what the consequences would have been for the

 9     immediate surroundings and the Serb villages around Sarajevo had the

10     Sarajevo-Romanija Corps given in?

11        A.   Your Honours this is too broad a subject.  I'm going to try and

12     give you the basics on this and that have been quite a fine achievement

13     given the time available to us.  I'm talking about the area where there

14     were people that we were meant to protect.  They felt it would be a

15     disaster were the corps to give in and allow an enemy incursion into our

16     territory.  People were pleading so much.  People were trying to

17     encourage us to persist and to do everything in our power to protect them

18     from this incursion.  People were living in fear, because were there to

19     be a breakthrough by the enemy that would have meant their disappearance

20     from the area.

21        Q.   And what about the enemy getting into Serb villages such as

22     Cemerno and other villages?  Did that fear felt by the population appear

23     to be founded?

24        A.   Whenever anything like that happened it caused suffering to the

25     people on the receiving end.  And it's more than just Cemerno, the area

Page 32578

 1     around the village and the village itself.  I'm aware of that village for

 2     a different reason, not because I have direct experience.  I received

 3     word at the time that people were killed there, that houses were burned,

 4     but the disaster that struck Velesici -- or, rather, Pofalici was in my

 5     opinion an even greater disaster.  It was on the 15th of May, 1992.  Were

 6     those military units or paramilitaries units, I don't know, but they were

 7     certainly extremists who got there, who set fire to houses and killed the

 8     locals there in that area.

 9        Q.   Thank you.  What was the type of operations that the 1st Corps

10     conducted in order to achieve these objectives?  Can you tell us more

11     about that?  What type of combat operation?  What type of offensive?

12     What did you as a corps have to resist at your time as chief and later on

13     at your time as corps commander?

14        A.   As for the sheer variety of the operations unleashed against us,

15     I can only congratulate them here or elsewhere.  They devised their

16     combat operations in a very clever way.  All of the combat activities and

17     operations that were launched in a tactical, operational and strategic

18     sense we used.  They used everything that was available.  They tried to

19     break through the lines.  They tried to infiltrate and get behind our

20     lines.  They tried to use artillery.  They used night-time combat as

21     well.  Sometimes we would find out in the morning that five of our men

22     had been killed the previous night, men deployed at particular positions.

23     So there was a variety -- variety of different operations and actions

24     that they were using, sabotage operations, planting explosives, and so on

25     and so forth.  They were particularly good at sniping.

Page 32579

 1             I know the person who was in charge of devising this strategy.

 2     He's a highly skilled military officer.  So he created this environment,

 3     and he ran the whole show.  These activities and operations covered a

 4     particularly broad area, and this constituted an enormous danger to the

 5     safety of our own men.

 6        Q.   Thank you very much.  When you look at media reports or indeed

 7     when you look at evidence given before this Tribunal, one often mentions

 8     acts of provocation by the Muslims and our reaction to those taunts or

 9     acts of provocation.  How do you distinguish between the two, the mere

10     act of provocation on the one hand and a real combat operation on the

11     other?

12        A.   The two were difficult to tell, and the intention behind each was

13     difficult to distinguish, but we needed a working assessment in both

14     cases, and we had to sort of decipher this for ourselves every time.  It

15     would have been irrational.  It would have been needless to respond to

16     provocation.  So what we needed was reliable information indicating

17     whether there was any serious intention of a military incursion, an

18     attempt to break through our lines before we started firing back.

19     Normally we did not rise to the bait.  Obviously sometimes it was easy to

20     tell, but we needed to exercise some caution in terms of our own

21     assessments when assessing the intentions behind a particular move that

22     they were making.

23        Q.   Thank you.  When you were brigade commander, did you know where

24     they were, where their units and weapons were?

25        A.   I think I stated before this Chamber that we knew the enemy

Page 32580

 1     really well.  We had them down to a T.  But all this goes back to the

 2     initial stage in those early days when we all had to assess our own

 3     situations at our own basic level.  So we knew where they were.  We knew

 4     what they were doing, and we knew what their intentions were and what the

 5     danger involved for everyone was.  And we had to go on studying the

 6     situation, obviously.  The same thing that was done at brigade level was

 7     also studied elsewhere using certain methods, and then an assessment was

 8     drawn up at corps level in order to arrive at their intentions.

 9        Q.   Thank you very much.  I would like to show you a series of

10     documents that you produced at the time.  Therefore 65 ter 12446, please,

11     in e-court.

12             MS. EDGERTON:  I think that's also P4498, Your Honours.

13             JUDGE KWON:  Thank you.

14             MR. KARADZIC: [Interpretation]

15        Q.   General, sir, this has been admitted already, so we'll not be

16     dwelling on this.  You're talking about the disposition of enemy units;

17     right?

18        A.   Yes, that's right.

19        Q.   Boljakov Potok right next to the supermarket.  And then you

20     mention all these locations, the skyscraper near the Kosevo pharmacy,

21     Hrasno Brdo, Mojmilo, the Muslim Sandzak Brigade 900 to 1.000 men.  And

22     then you talk about Treska.  What is this Treska?

23        A.   It's a building.  There was a furniture shop there.  It was a

24     Skopje based company, a Macedonian company.

25        Q.   And you mentioned Zetra.  What is Zetra?

Page 32581

 1        A.   It's a sports hall.  It's a sports venue.

 2        Q.   Thank you.  The Kosevo Hospital perimeter, there was a unit there

 3     that was stationed there.

 4        A.   Yes.  I'm not sure it's necessary to go through all this

 5     information.  It was information that we obtained in a variety of ways.

 6     So it's just information that was available to us at this initial stage.

 7        Q.   Can we have the next page in the Serbian please.  Elementary

 8     school, medical school.  You see what it says there.  The use of civilian

 9     facilities and buildings such as schools and hospitals.

10             To what extent did the 1st Corps resort to measures such as those

11     using such civilian facilities and buildings for military purposes, that

12     is?

13        A.   Anything that was available, the facilities and buildings

14     available within the city of Sarajevo, any possible purpose at all that

15     these were used for.  All of that was taken by the 1st Corps.  Schools,

16     hospitals, too, but let's not focus on that, because it was only

17     Kosevo Hospital that they were using, not any of the other hospitals

18     across the city.  Nurseries, commercial buildings, shops, private homes,

19     pubs.  It was all covered.

20             Had I been able to use such facilities in my capacity as

21     commander in -- my position would have been a lot better than it was.  So

22     they had everything, all the facilities available to them, civilian,

23     military and so on.

24             Finally, when it came to the implementation of the

25     Dayton Accords, their own authorities found it very difficult to persuade

Page 32582

 1     them to actually leave those facilities.  The military had settled in and

 2     they ruled the roost, as it were.  They refused to leave.

 3        Q.   Thank you very much.  General, sir, but did they leave at least a

 4     single civilian area that would have been a safe place for civilians to

 5     stay inside Sarajevo and that did not comprise a single potential

 6     military target?

 7        A.   There were no such areas in Sarajevo.  I'll try and be more

 8     specific about this.  If we're talking about a distance, say, 100 metres

 9     between a weapon and the troops there, then you can't consider that to be

10     a civilian area, a safe civilian area.  They did not have a choice but to

11     use the space available in order to deploy their troops.

12        Q.   Thank you very much.  1D07036, please.  Thank you.

13             JUDGE KWON:  Mr. Milosevic, you said that, say, a distance of 100

14     metres between a weapon and the troops there, and you can't consider that

15     could be a civilian area.  Does it mean that you can shell any part of

16     the area, that being the case?

17             THE WITNESS: [Interpretation] We were not allowed to shell a

18     civilian area, nor indeed would we have chosen to shell a civilian area.

19     The Sarajevo-Romanija Corps didn't do that.  Wherever there were

20     civilians, that meant that was not a target for us.  We never fired at

21     those areas.

22             JUDGE KWON:  What did you mean that you couldn't consider those

23     area to be a civilian area?

24             THE WITNESS: [Interpretation] I probably misspoke in that sense,

25     because that's not what I meant.  What I'm trying to say -- if someone

Page 32583

 1     was a hundred metres away, that doesn't mean that this person is in an

 2     area that is exclusively civilian.

 3             JUDGE KWON:  Very well.  Please continue, Mr. Karadzic.

 4             MR. KARADZIC: [Interpretation]

 5        Q.   General, sir, this is the command of the 1st Romanija Corps, the

 6     1st of October.  What are you doing there?  You are simply rattling off a

 7     list of forces of the Sarajevo-Romanija Corps and then everything else

 8     that you see there:  Bosna Transport, Prorad [phoen], Hrasno elementary

 9     school, faculty of architecture, Kosevo Hospital.

10        A.   I have nothing special to add.  These locations that we

11     identified were their collection points.

12             THE ACCUSED: [Interpretation] Next page in English please, and

13     also the next page in Serbian.  Thank you.

14             MR. KARADZIC: [Interpretation]

15        Q.   Can you please read out loud the first paragraph from this page.

16        A.   I might find that somewhat difficult:

17             "At the railway station near the Vuk Karadzic elementary school,

18     the medical school, the Kosevo stadium, the Marsal Tito Barracks, and the

19     Victor Bubanj Barracks are deployed enemy artillery groups and individual

20     artillery weapons.  The artillery groups are of a mixed composition and

21     strength, and they cover a broad area."

22        Q.   Can you tell the Chamber where, for example, this medical school

23     used to be?  Do you remember the exact location in relation to Bjelovar?

24        A.   Yes, yes, right.  Right.  These schools, the medical school, the

25     secondary school for dentists and dental technicians, it's all within the

Page 32584

 1     Kosevo Hospital compound which was a large compound at Bjelovar.

 2        Q.   Thank you.

 3             THE ACCUSED: [Interpretation] I would like to tender this

 4     document.

 5             JUDGE KWON:  Yes, we'll receive it.

 6             THE REGISTRAR:  As Exhibit D2795, Your Honours.

 7             MR. KARADZIC: [Interpretation]

 8        Q.   You said that you did not always respond to any -- every

 9     provocation.  What was your reason not to respond to each provocation?

10        A.   Well, it's not only that it was provocations.  A response to

11     their fire would often be no response not even when there was firing but

12     it did not have the nature of a provocation.  Those who are to use their

13     weapons, and I'm talking from the position of the

14     Sarajevo-Romanija Corps, had to secure a whole series of indicators in

15     order to decide, to decide to open fire.  The system of observation, all

16     kinds of observation, observation of artillery, movements of the

17     infantry, surveillance of the terrain, all of that was covered by our

18     observation posts, and the observers had to provide information about

19     what they were seeing and what was happening there and from which area

20     did they open fire at us.

21             One detail that occurred very often was that they would open fire

22     at us, but they would fall below target because they use an insufficient

23     charge or because the crews were not working properly, so the shells

24     would fall short.  They would not reach the intended purpose.  So for

25     that reason there was no need for us to intervene or to open fire.  So

Page 32585

 1     for a senior officer to decide whether he would fire at a target or not,

 2     there had to be a certain number of indicators as well as there had to be

 3     an estimate as to whether there would be civilian victims or not.  If

 4     there was any chance that there would be civilian casualties, then one

 5     would not open fire.  If it was established that the area was clear but

 6     there was a danger, in that event we would open fire.

 7        Q.   General, sir, thank you.  This is intriguing to me that they even

 8     fell into their territory due to errors.  So are you saying that there

 9     were instances when they did not deliberately fire at their own

10     territory?

11        A.   Yes.  Yes.  The first point is correct factually.  They did that

12     without intending to fire at themselves, because there were some cases

13     when the projectiles fell short.  But there were also situations when

14     their explosives blew up at the very location where the fire was coming

15     from.  We don't know whether this was for technical reasons or

16     mishandling.  That is something else.

17             Secondly, it was very obvious that there were clans, I would call

18     them, in Sarajevo who would vie with one another, and they would shoot at

19     each other in order to silence them and to grab the area from them.  They

20     had their own calculations there.  But it was always with the expectation

21     that that would be considered as fire coming from us.

22             Observers would report and follow.  I did not ever manage to see

23     it, but I was interested in it.  They would report that, let's say from

24     the area of Sirokaca, which is an area below Trebevic, they were firing

25     at Kosevsko Brdo hill.  Why they were firing there, what they were

Page 32586

 1     settling accounts for we don't know, but this would happen.

 2             There was some other such instances, very original and very

 3     obvious.

 4        Q.   Thank you.  And what about Livanjska Street?  Where is

 5     Livanjska Street in Sarajevo?

 6        A.   Livanjska Street is on Kosevsko Brdo hill.

 7        Q.   Thank you.  Not counting the major incidents that were heard of

 8     internationally, did you register any deliberate firing from high-calibre

 9     weapons by Muslim forces in areas of Sarajevo which were under their

10     control?

11        A.   Well, I'm just looking at the English text.  If it's not too much

12     trouble, can I please ask you to repeat your question.

13        Q.   I'm not asking you about major incidents now such as Markale,

14     Vasa Miskina, and all the other ones cited as major instances.  Were

15     there any deliberate instances of firing from large-calibre weaponry on

16     their own territory?  Did you observe anything like that?

17        A.   There were such instances.

18        Q.   Can we look at 1D32016 in e-court now, please.  There is also a

19     translation.

20             In paragraph 1 there's talk about enemy activity in the following

21     sectors.  Could you please read the one that discusses the firing from --

22             THE INTERPRETER:  Interpreter's note:  We do not see the text in

23     English.

24             JUDGE KWON:  Just a second.  Is there a way that interpreters

25     could see the English translation?  Our public monitor shows only the

Page 32587

 1     B/C/S for the benefit of the witness.

 2             Can you read it, Mr. Milosevic?

 3             THE WITNESS: [Interpretation] Yes.  This is the third paragraph

 4     that you're looking at.  The fire from rifle grenades, and infantry

 5     weapons.

 6             MR. KARADZIC: [Interpretation]

 7        Q.   Rifle grenades an infantry weapons?

 8        A.   Rifle grenades an infantry weapons from positions above Breka and

 9     the monument at their own positions in the Bascarsija with the intention

10     blaming the Serbs for firing.  And so now I can see the content

11     indicating that we noted that there was some fire from positions above

12     Breka at Bascarsija and that is all their territory.

13        Q.   Thank you.

14             THE ACCUSED: [Interpretation] I would like to tender this

15     document.

16             MR. KARADZIC: [Interpretation]

17        Q.   And is this your document?  Can we look at the last page, please,

18     and the signature?

19        A.   Yes, yes.  This is my signature.  First and last name and

20     signature.

21        Q.   Thank you.

22             JUDGE KWON:  Yes.  We will receive it.

23             THE REGISTRAR:  As Exhibit D2796, Your Honours.

24             THE ACCUSED: [Interpretation] Can we look at 1D7505 in the

25     e-court, please.

Page 32588

 1             MR. KARADZIC: [Interpretation]

 2        Q.   This first paragraph up to this Serb side, but I will summarise

 3     it.  Near the school in Dobrinja they're also firing at and they have

 4     torched a house near the Jewish Cemetery, but this second thing, from the

 5     observation point.  Line 3.

 6        A.   "From the observation point at Vidikovac, the Muslims are opening

 7     machine-gun fire against the town and the building of the UN command,

 8     with the intention of 'crediting' the Serbian side with this action."

 9     Should I continue?

10        Q.   No, General.  No need to read any further.  Was this something

11     that was infrequent or surprising, or did you have instances like this

12     more often?  Was this an exception or the rule?

13        A.   The first thing that I know, that I'm very familiar with, is that

14     they constantly try to provoke UNPROFOR with the intention of creating

15     the impression with UNPROFOR that this was done by our forces, the forces

16     of the Sarajevo-Romanija Corps.  They would fire, and then they would

17     lodge a protest.  That was the form that it was done in.

18             THE INTERPRETER:  The interpret did not hear the last sentence.

19             MR. KARADZIC: [Interpretation]

20        Q.   Thank you.

21             THE ACCUSED: [Interpretation] Can we tender this document,

22     please.

23             JUDGE KWON:  The interpreters didn't hear your last sentence,

24     Mr. Milosevic.  As noted, your last answer was that this was the form

25     that it was done in.  Did you add anything after that?

Page 32589

 1             THE WITNESS: [Interpretation] I said that they would fire at

 2     UNPROFOR and then they would request UNPROFOR to intervene against us

 3     because they would allegedly inform them that the fire came from us.

 4     They would ask UNPROFOR to lodge protests with our side, because it was

 5     allegedly our weapons that fired.

 6             MR. KARADZIC: [Interpretation]

 7        Q.   Thank you.  And it says here that they also fired at the city.

 8     Does that mean that other than firing at the UNPROFOR building, they also

 9     fired at the town?

10        A.   Yes.  Yes.

11             THE ACCUSED: [Interpretation] Could we tender this document,

12     please.

13             JUDGE KWON:  Yes, Ms. Edgerton.

14             MS. EDGERTON:  Noting that Dr. Karadzic fed the witness the

15     answer.  He should really try and guard, in my submission, against

16     leading the witness in his questions.

17             THE ACCUSED: [Interpretation] I apologise.  I just wanted to get

18     whether this was on the town or at the building, because it says here in

19     the town and on the building.  I don't know how it was translated.  So

20     this is why I wanted to clarify where it was that they fired.

21             JUDGE KWON:  Mr. Karadzic, once you establish some foundation of

22     a document, you may put certain passages, but in doing so, you have to be

23     very precise in refraining from -- otherwise refrain from making leading

24     questions or comment.

25             Please continue.

Page 32590

 1             THE ACCUSED: [Interpretation] I have finished with this document.

 2     I with like to tender it, please.

 3             JUDGE KWON:  Yes.  We will admit it.

 4             THE REGISTRAR:  As Exhibit D2797, Your Honours.

 5             MR. KARADZIC: [Interpretation]

 6        Q.   Can we look at 1D7500 now, please.  You don't need to read, but

 7     you can just tell us what it was that happened at 1245 hundred hours.

 8     This is the third bullet in -- from the top.

 9        A.   Yes, yes.  I can see it.  Yes.  What happened was what it states

10     here.  Our observers noted that from this area they were shooting at the

11     Ernest Green [phoen] hospital.  This used to be a hospital specialising,

12     as far as I remember, in -- it actually partially belonged to the part of

13     Republika Srpska, to the Sarajevo-Romanija Corps, and I would say that it

14     was a good base, a good basis possibly to treat the wounded.  However,

15     they carried out fire at that area.

16        Q.   And this Miladin Cukovic, this doctor, was killed; is that

17     correct?

18        A.   Yes.

19        Q.   And are you able to tell us what it is that is stated in

20     paragraph 2, that you did not respond to provocations?  Why didn't you

21     respond to provocations, which is contained in this paragraph 2?

22        A.   The first and main reason was - and I'm sure now - is that a

23     certain cease-fire period had been established when firing at each other

24     was ruled out.  So in the situation when any kind of restriction or ban

25     was in force or when an agreement was in place we would not do that.  And

Page 32591

 1     in other circumstances when we did not do it, we did not do it in order

 2     to avoid hurting the civilian population.

 3        Q.   Thank you.

 4             THE ACCUSED: [Interpretation] Can I tender this, please?

 5             MS. EDGERTON:  Noting that it's not General Milosevic's document.

 6     It was signed by someone on his behalf.

 7             JUDGE KWON:  Very well.  We will admit it.

 8             THE REGISTRAR:  As Exhibit D2798, Your Honours.

 9             THE ACCUSED: [Interpretation] Can we look at one more document

10     today, please?  It's 1D7502.  It's a document of the

11     Sarajevo-Romanija Corps, and you signed it and the 30th of September,

12     1993.  1D7502.

13             What I am particularly interested in terms of your evaluations or

14     assessments of -- for provocations, I would like you to look at this last

15     paragraph which is the paragraph after the one marked number 8.  I think

16     this is on page 2 in the English.

17        A.   Yes, yes.  I see it.

18        Q.   Can you please read it out loud.

19        A.   "In view of the political situation, the enemy will try to

20     provoke our forces into action, especially against Sarajevo, and thus

21     provide for the enemy's political structures."

22             I cannot see:

23             "And provide trump cards for the enemy's political structures."

24             This is what this is about.  This is something that we had to

25     take into account and respect.  Statesmen, politicians, certain

Page 32592

 1     structures would come to Sarajevo for the purpose of contacts.  They had

 2     different important meetings in Sarajevo.  So it was important to them

 3     for us to go into action then at those times, and then they would

 4     undertake some action in order to prompt us to fire and show that we did

 5     not respect any behaviour codes in given situations.  And I know very

 6     well that during any kind of important gathering or even less important

 7     gathering, our forces did not do it in order not to provide any kind of

 8     pretext to them.  In that same period, even General Rose asserted,

 9     claimed, that at the time when the Turkish prime minister came, they

10     opened fire in order to show what danger they were in.  They opened

11     artillery fire from their positions in their zone.  That would be that.

12             THE ACCUSED: [Interpretation] Can we tender this document?

13             JUDGE KWON:  Yes.

14             THE REGISTRAR:  Exhibit D2799, Your Honours.

15             JUDGE KWON:  Mr. Milosevic, we will adjourn for today now, and

16     given the scheduling, you will interposed by another witness tomorrow

17     morning.

18             Is my understanding correct, that you will start with

19     Mr. Indjic's cross-examination?

20             MS. EDGERTON:  Correct.

21             JUDGE KWON:  And I take it we may start your -- resume your

22     evidence in the afternoon, but I'm not sure about it.  I'm just telling

23     you for your information.

24             Do you understand that, sir?

25             THE WITNESS: [Interpretation] Thank you, Your Honour.  Yes, I

Page 32593

 1     understand.

 2             JUDGE KWON:  Yes, Mr. Bourgon.

 3             MR. BOURGON:  Mr. President, I would like to have -- to make a

 4     request to the Trial Chamber, and on this table I have access only to one

 5     screen where I can see the -- what is on the public monitor.  However,

 6     because I do not have access to the materials, the confidential material

 7     in the case of Dr. Karadzic, I cannot have anything else loaded up on the

 8     other two computers, and I'm not able to see the transcript at the same

 9     time as a document is put up on the screen.  If -- with my undertaking,

10     Mr. President, that I would only look at the computer while in the

11     courtroom and look only at the transcript from the two computers, I would

12     ask the Trial Chamber to grant me permission so I can see the transcript,

13     and it will be my personal undertaking that I will not look at any other

14     material on those two computers.  This would make my life much easier if

15     I can see both at the same time.  Thank you, Mr. President.

16             JUDGE KWON:  The Chamber will consider that in due course.  We

17     will give a ruling in due course, but I'm not sure the Chamber should be

18     involved.

19             The hearing is now adjourned.

20                           --- Whereupon the hearing adjourned at 2.50 p.m.,

21                           to be reconvened on Thursday, the 24th day

22                           of January, 2013, at 9.00 a.m.

23

24

25