140826ED

Page 24746

1 that the trial record is both accurate and speaks for itself.

2 [The witness entered court]

3 MS. BIBLES: As a result, we will not be filing additional

4 submissions.

5 JUDGE ORIE: Yes, thank you, Ms. Bibles.

6 For us to understand, does this support or not support the

7 Defence's position?

8 MS. BIBLES: We do not believe it support it is Defence's

9 position.

10 JUDGE ORIE: Okay. And you say that will be clear from the

11 sources.

12 Good morning, Witness, Mr. Adzic, I assume.

13 Mr. Adzic, before you give evidence in this court, the Rules

14 require that you make a solemn declaration. The text is now handed out

15 to you. May I invite you to make that solemn declaration.

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

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

18 WITNESS: RATKO ADZIC

19 [Witness answered through interpretation]

20 JUDGE ORIE: Thank you, Mr. Adzic. Please be seated.

21 Mr. Adzic, you will first be examined by Mr. Lukic. You'll find

22 him to your left. Mr. Lukic is counsel for Mr. Mladic.

23 Please proceed, Mr. Lukic.

24 MR. LUKIC: Thank you, Your Honour.

25 Examination by Mr. Lukic:

Page 24747

1 Q. [Interpretation] Good morning, Mr. Adzic.

2 A. Good morning.

3 MR. LUKIC: [Interpretation] First, can we have a look at 1D1634.

4 JUDGE FLUEGGE: In the meantime, I could remind you, Mr. Lukic,

5 you should ask the witness for his name.

6 MR. LUKIC: Yes, thank you.

7 Q. [Interpretation] Before we go on, Mr. Adzic, please tell us for

8 the record what your first and last name is. It is just for the purposes

9 of the record.

10 A. Ratko Adzic.

11 THE INTERPRETER: Mr. Lukic is kindly asked to wait for the B/C/S

12 translation to be finished before he begins speaking. Thank you.

13 JUDGE ORIE: The interpreters, Mr. Lukic, are kindly asking you

14 to wait for the B/C/S translation to be finished before to resume

15 speaking.

16 MR. LUKIC: I will go to English channel so I don't make any

17 problems.

18 Q. [Interpretation] On the screen before you --

19 A. Yes.

20 Q. -- you see a signature. Do you recognise it?

21 A. I don't see any signatures on the screen. I only see printed

22 text. Oh, yes, on the right-hand side. I apologise. You mean the

23 witness statement?

24 Q. Yes.

25 A. It is my signature. I apologise. I was looking at the left-hand

Page 24748

1 side screen.

2 Q. Did you indeed provide a statement to representatives of

3 General Mladic's Defence?

4 A. Yes.

5 MR. LUKIC: [Interpretation] Can we please go to the last page of

6 the document.

7 Q. Do you see a signature here and do you recognise it?

8 A. Yes, I do.

9 Q. Whose signature is it?

10 A. Mine.

11 Q. The statement you provided to General Mladic's Defence, is it

12 accurate and truthful?

13 A. Yes, it is.

14 Q. If you were asked the same questions today, would you, in

15 principle, answer the same way?

16 A. Completely.

17 MR. LUKIC: We would like to have this statement into evidence.

18 JUDGE ORIE: Madam Registrar.

19 THE REGISTRAR: Document 1D01634 receives number D597, Your

20 Honours.

21 JUDGE ORIE: In the absence of any objections, D597 is admitted.

22 MR. LUKIC: I will read a short summary of the statement of this

23 witness, and then I will just have a few questions for him.

24 May I, Your Honours?

25 JUDGE ORIE: Yes.

Page 24749

1 MR. LUKIC: Thank you.

2 JUDGE ORIE: Yes, Mr. Lukic.

3 MR. LUKIC: Witness Adzic Ratko was born on 5/11/1948 in the

4 village of Kadarici, Ilijas municipality, Sarajevo. He currently resides

5 in Belgrade, Republic of Serbia. In relevant period he was the president

6 of municipality of Ilijas, as of 1st January 1991. After that he became

7 the president of Crisis Staff in Ilijas municipality, and at the same

8 time he continued to be the president of municipality. From 20th of

9 January 1993 until July 1993, he was the minister of internal affairs in

10 Republika Srpska.

11 The witness will testify on overall situation in BiH before and

12 after the first multi-party elections in 1990, and functioning of

13 municipality authorities. He will testify on the census of population

14 conducted in 1991, and on the demographic situation in Ilijas

15 municipality where he was the president of the same. He will testify on

16 functioning and work of municipality authorities, creation and activities

17 of national parties such as HDZ and SDA, and activities of their

18 representatives in the municipality of Ilijas.

19 The witness will testify on creation of Crisis Staff staff in the

20 Ilijas municipality, its structure, composition, and activity of its

21 members, implementation of its decisions, as well as of the relationship

22 of the civilian and the military authorities.

23 Also, this witness has knowledge on organisation and the armament

24 of Muslim and Croat population, on creation of paramilitary units as

25 Green Berets and Patriotic League, their training and activities,

Page 24750

1 particularly in emerge of conflict in former Yugoslavia.

2 He will testify on his work during his tenure as minister of the

3 interior in Republika Srpska and will explain his knowledge on

4 relationship between police and VRS in the relevant period. He will

5 explain structure and functioning of the MUP and command and control over

6 police units, and modalities of their engagement in operations in the

7 relevant period.

8 That would be a short summary, and I will just have a few

9 questions for the witness.

10 JUDGE ORIE: Please put them to the witness --

11 MR. LUKIC: Thank you, Your Honour.

12 JUDGE ORIE: -- Mr. Lukic.

13 MR. LUKIC: [Interpretation]

14 Q. Mr. Adzic, was a Crisis Staff formed in your municipality?

15 A. Yes, it was. It was established in late December 1991 on

16 recommendation from the presidency of Republika Srpska and its national

17 assembly.

18 Q. While the Crisis Staff was in operation, was the municipal

19 assembly in operation as well?

20 A. It was. Let me clarify. Given the fact that the assembly

21 bodies, the executive council, and other administrative bodies

22 functioned, there was no need for the Crisis Staff to take their place,

23 but it was set up because the situation was becoming more serious and the

24 war was looming. It was actually established in order to provide defence

25 and protect the resources of the RS so that people would be designated

Page 24751

1 who were supposed to be held accountable for preserving those and to

2 secure their proper functioning.

3 Q. How were the members of the staff appointed?

4 A. On recommendation, the municipal president was the president of

5 the Crisis Staff. As for the secretary and other staff, the Serb

6 representatives, that is, in the municipality itself, also were made

7 members of the Crisis Staff. It also included the head of the police

8 station and managers of some state-owned enterprises which covered the

9 issues of supplies, commodity reserves, and so on and so forth.

10 Q. Were any members of the Crisis Staff also members of the JNA or

11 later VRS?

12 A. No. If I may, I'd like to clarify. Before that, the civilian

13 protection of the Serbian people staff was established on recommendation

14 from the SDS, and the territorial units were established which then

15 became units of the VRS. Members of that staff had the exclusively

16 obligation to organise the Serbian people for defence. Their domain

17 regarded the issue I mentioned, and there was no need for them to be

18 engaged as members of the Crisis Staff as well.

19 Q. I would like to change topics now and ask you whether in Ilijas

20 after the outbreak of the conflict, the Muslim population remained, left,

21 separated, or whatever? Please explain the ethnic structure of the

22 municipality following the outbreak of the conflict.

23 A. If I may, I'd like to invoke the 1991 census in

24 Bosnia-Herzegovina. As regards the municipality of Ilijas, it had around

25 25.000 inhabitants. Ten and a half thousand of them were Muslims, 11.600

Page 24752

1 Serbs, 1.700 Croats, and some 2.000 pronounced themselves as Yugoslavs

2 and the rest. So in total, around 25.000.

3 The ethnic structure? Well, Ilijas is a small town and with its

4 urban nucleus. The rest of the municipality covered villages and

5 hamlets. The villages were either Serbian or Muslim or Croatian. We

6 agreed with the representatives of the Muslim people, the SDA, and the

7 HDZ, that the bodies they were to form in the territory inhabited by

8 Croats or Muslims, they were to take up responsibility in organising the

9 system of functioning for the authorities.

10 Just before the outbreak of the war, in March 1992, there was a

11 division in the police station. On my initiative, I called a general

12 meeting including representatives of the SDA and HDZ and proposed that

13 all of the policemen, who -- of whom ten or eleven were Muslim, would

14 receive all weapons and equipment so that they can establish, in

15 agreement with the political representatives of the SDA, the functioning

16 of their police in the territory inhabited by Muslims.

17 Prior to that, the HDZ and the SDA, when the assembly was divided

18 in 1992, established their own municipal body. I apologise, that was in

19 1991, December 1991. They had their own bodies of authority and they

20 were responsible for their work.

21 In all parts of the municipality inhabited by Muslims or Croats,

22 the functioning of authorities was organised by the SDA and HDZ. They

23 had their own police station, and all of the policemen - who were Muslim

24 or Croatian - worked in that station and were responsible to their own

25 bodies. We did the same in the territories inhabited by Serbs, that

Page 24753

1 included the police station of Ilijas which was responsible for law and

2 order.

3 It was agreed that the Serb police was not to enter Muslim

4 settlements without previous announcement, and if there were any

5 incidents they were to be tackled jointly. So each side covered their

6 own ethnic territory, so to speak.

7 Q. How long was that agreement in place?

8 A. Until the 3rd of May, 1992, when the first bigger offensive took

9 place launched by Muslims from Visoko and Breza. On the 3rd of May at

10 around 10.00 a.m., there was intensive shelling of Ilijas and the

11 settlements around it such as Podlugovi and the attack on defence lines

12 in Cekrcici and other villages. There was fighting all day long. We

13 repelled the attack, defended our territory, and later on there was no

14 longer any communication with the Muslim authorities save for a few

15 instances when I was invited to attend. It was actually before the 26th

16 of April that I attended a meeting in Visoko, the municipal president of

17 Visoko and Breza was there and we tried to establish some kind of

18 co-operation.

19 I was always open for any agreement, anything that would protect

20 the interests of all peoples, and I was there to represent the interests

21 of the Serbian people. But I also accepted that the Muslims and Croats

22 also had to protect their own interests.

23 After the 3rd of May when the attack occurred -- I apologise.

24 There was another round of talks on the 3rd of May organised by the

25 municipal president of Breza, Mr. Opacina [phoen], sometime in the

Page 24754

1 afternoon. I went to Breza, together with the brigade commander,

2 Markovo Polje [phoen]. We analysed the reasons for the attack. I asked

3 them why they attacked us, and I located their precise artillery position

4 which they used to shell the centre of Ilijas.

5 The very first shell that came from Breza killed a Muslim,

6 interestingly enough. He was seriously wounded at the time. In Ilijas,

7 we had no hospital resources and could not treat seriously wounded.

8 There was an ambulance which took him to the Kosevo hospital in Sarajevo

9 together with his wife. Upon his return at Kobilja Glava, the Green

10 Berets, having realised that the ambulance was driven by a Serb driver

11 wanted to kill him and take the vehicle. But the wife of the wounded

12 Muslim saved him. She explained that she had no means to return to

13 Ilijas, started to cry, and they released the ambulance.

14 After that I called an SDA representative, and I said that I

15 could not longer send Serb drivers to take the wounded Muslims to Muslim

16 controlled areas, otherwise I would be endangering their lives. We

17 agreed that if a Muslim were wounded, they were to organise transport and

18 we would provide gas. And then they took their wounded either to

19 Visoko -- well, mostly to Visoko because it was the easiest thing to do.

20 It went on until the 3rd of May, 1992.

21 Q. When did the war in Bosnia start, according to you?

22 A. On the 4th of April 1992.

23 Q. So from the 4th of April until the 3rd of May, the agreement on

24 co-operation --

25 A. That agreement was in place and it was honoured by both sides, by

Page 24755

1 Muslims and by my side, of course, as the representative of the Serbian

2 population.

3 Q. And all the party agreement on the transport of the wounded, when

4 was that made?

5 A. Somewhat earlier -- actually, it was on the 3rd of May. On the

6 3rd of May, because a girl was wounded in Bircana [phoen] during

7 shelling. She was a Muslim, and her father brought her in a car. But

8 she was so seriously wounded that she couldn't be hospitalised there and

9 that's why they suggested that she should be transported to Visoko. No

10 ambulance was needed but we provided them with fuel, and some relatives

11 of hers transported her to Visoko and they returned.

12 Then I talked to the President of the SDA, Mehed Mesovic [phoen],

13 and we agreed that all the cases of the wounded Muslims, because they did

14 not have resources to care for the Muslims, that all the Muslim civilians

15 in the city would be transported to Visoko and we would supply them with

16 fuel for that transportation.

17 THE INTERPRETER: Could the witness please be asked to slow down.

18 JUDGE ORIE: Mr. --

19 THE WITNESS: [Interpretation] I apologise.

20 Obviously they could choose to be treated at Serbian hospitals,

21 in Pale, for example, but they wanted to go to Visoko. That was their

22 choice.

23 JUDGE ORIE: The interpreters ask you to slow down so that they

24 are able to translate all your words.

25 THE WITNESS: [Interpretation] I apologise.

Page 24756

1 MR. LUKIC: [Interpretation]

2 Q. Teachers are known to speak faster more than lawyers.

3 A. Yes, it goes then with the job.

4 Q. When it comes to Ilijas -- or, rather, all of the parts of Ilijas

5 municipality, were they all under Serb control?

6 A. No, no. All parts of Ilijas municipality and the villages, they

7 were mixed - the Muslim and Serb villages. That's how things were. We

8 talked to the representatives of the Muslim powers, and we agreed that in

9 all of the villages where the Muslim population prevailed they should

10 organise their authorities. Neither I nor the Serbian bodies had any

11 control of that territory. We knew that the units of the

12 Patriotic League were being armed.

13 As we spoke to the representatives of the SDA, we confronted them

14 with that fact. We told them that we are aware of that, that we

15 considered that to be their choice, and that we would not undertake any

16 measures in order to prevent them from doing that because that was their

17 choice. However, we also told them that we should agree that everybody

18 should protect their own village and their own settlement, and us Serbs,

19 we did that as well. That agreement was honoured and no armed formations

20 crossed over from one village to the other. Only our chosen

21 representatives could talk to each other and deal with some issues at

22 hand.

23 Q. Did Serbs leave Ilijas?

24 A. Yes, they did. If you will allow me just briefly. The situation

25 was created after the 4th of April. The war had started. That was

Page 24757

1 obvious. I talked to the police and the Red Cross. During that period

2 of time, there was a wave of displaced persons coming from Central

3 Bosnia, Visoko, Konjic, and Breza. The situation was very chaotic. A

4 lot of people needed assistance. They needed food and medical aid, and

5 we hardly had resources for that. When it comes to the movement of

6 people, I ordered the enforcement bodies not to prevent people from

7 moving around, not to restrict that freedom.

8 When it comes to the town itself and its centre, we had a lot of

9 ethnic groups there, but in that period of time they could talk to the

10 Red Cross. They could give them the statement in order to cross the

11 check-points that were controlled by the police on the borders of the

12 municipality. They had the right to leave, nobody could bother them.

13 Some Muslims and Croats left the municipality in that way but also a lot

14 of Serbs did that.

15 I'm again speaking too fast, aren't I? Well, I apologise.

16 During that period, I tried to make sure that everybody had the

17 right of movement, irrespective of their ethnicity. They had the right

18 to choose the place where they wanted to go in light of the dramatic

19 situation that prevailed in the area at the time.

20 Q. My next question is this -- or, rather, I already asked you

21 whether Muslims and Croats were leaving and you already answered.

22 However, when we are talking about the departure of Muslims and Croats

23 and you said that they did leave, was there a plan in place for the

24 expulsion of Muslims and Croats from Ilijas municipality?

25 A. Absolutely not. No. It was their own free movement, their free

Page 24758

1 departure, which was the result of the chaotic situation. It was their

2 personal choice to leave the war-struck area.

3 Q. Were there any people who decided to leave but then returned?

4 A. Yes, I'm aware of just one case. But that happened in the month

5 of June. There was an accident resulting from a conflict between Muslims

6 and Croats in Ilijas. There was an exchange of the population in

7 agreement with the Muslim authorities in Breza and Visoko. All of that

8 was organised with the help of the Red Cross. It was broadcast in the

9 media that everybody who wanted to leave Ilijas or Breza could do that

10 freely. They could go to Visoko. The Serbs wanted to come from Breza

11 and Visoko to Ilijas and Muslims wanted to go to Breza.

12 There was one case, as far as I know, that a Muslim who applied,

13 together with his son, I believe that his name was Mujo Dzafic, he was

14 put on the exchange list, he headed for Breza. And later he told me

15 about the incident that had occurred and he returned to Ilijas. I didn't

16 know it on the day the Red Cross was involved in that.

17 On the following day, he wanted me to see him as the president of

18 the municipality. I received him to see what the situation was all

19 about, and he asked me, "President, can I stay in Ilijas?" And I said,

20 "Why not? Every citizen has a choice. But you have to be aware that you

21 will have to share the situation as it is with the rest of us. Whatever

22 we have you will have and every other citizen, of course." And then he

23 said, "I want to stay."

24 And then he was -- since he was an acquaintance of a military

25 police unit, he told me he wanted to join that unit because he trusted

Page 24759

1 his acquaintance. And I said this does not depend on me, it depends on

2 the secretariat of defence in the municipality and the brigade command.

3 Obviously whoever wanted to volunteer and join any of the units, he would

4 not be denied that opportunity and that's how he actually joined that

5 unit, and this is the only case that I'm aware of.

6 THE INTERPRETER: Could the witness please be asked to slow down.

7 Thank you.

8 JUDGE ORIE: Witness, could I again ask you to slow down because

9 part of your testimony will be lost if you continue in this speed of

10 speech.

11 THE WITNESS: [Interpretation] I'll do my best to slow down. I'll

12 try and focus.

13 MR. LUKIC: [Interpretation]

14 Q. After the conflicts started, can you just briefly tell us whether

15 there was an exit from Ilijas towards the Serb held territory? How wide

16 was that corridor? Which other municipalities were forced to use that

17 corridor? Were you encircled? Were you in a semi-encirclement? Just

18 briefly answer.

19 A. In very brief outlines, let me you. Ilijas was blockaded to --

20 in the direction of Visoko, Breza, and Olovo, and we could not use any

21 roads in those directions.

22 Across Vogosca municipality towards Sarajevo, all the roads were

23 blocked. So we could leave Ilijas only via Semizovac towards Srednje.

24 And there was a mountain road there which had been used for forestry

25 purposes. Wood was transported across Visojevica. We repaired that

Page 24760

1 road, and that was the only road. But even that was not safe.

2 There were Muslim villages on both sides, and there were frequent

3 attacks. Fire was often opened for the columns of vehicle that used that

4 road. That was our only communication with Pale, and that communication

5 was used by Vogosca, Rajlovac, Hadzici, and Ilijici. That was the only

6 exit and only road leading to Pale at the time.

7 Q. Is it true that, as a matter of fact, the entire road was within

8 the outer ring of the BiH Army forces?

9 A. Yes. Or, no. Or rather, partly from Semizovac to Srednje, it

10 was not safe. On the left-hand side there were Croat-Muslim villages,

11 Ostomorine and Korota [phoen]. There were no military units there due to

12 the configuration of the terrain, so the road could not be protected.

13 That's why we used military escorts for buses and vehicles like that.

14 The police and the military secured us such convoys until they reached

15 Srednje from where they were safe.

16 Q. I'd like to tackle another topic, and we will finish with that.

17 Please tell us briefly whether there were any attempts to hand over

18 absolute property rights or either the sale of property and cars. How

19 was that dealt with in your municipality?

20 A. On the 4th of April, when we realised that the situation was very

21 dramatic and that the war had started, people were obviously scared.

22 They were afraid. I was aware of the situation, but my first warning of

23 the possible abuse of the situation -- or, rather, it was the chief of

24 the secretary for administration who warned me about that. A Serb,

25 possibly with a criminal record, arrived at the secretariat for

Page 24761

1 administration and requested for a sale contract for a house to be

2 stamped. He -- the person who sold the house was a Croat. I inquired

3 about the situation, then -- then I realised this -- there was room for

4 possible abuse. I made the decision, which I conveyed to all the

5 municipality organs, according to which during that period the bodies of

6 the municipal assembly in charge of property matters were not allowed to

7 register any sales or purchase agreement or transfer a property deed, and

8 that included apartments, houses, and cars. Thus I prevented possible

9 manipulations and abuses, because there were identified criminals who

10 were capable of making the most of the fear of individuals later on.

11 And it turned out that some of them had three or four, or even

12 five purchase agreements according to which they allegedly bought

13 apartments from their original owners. But those were not registered and

14 those contracts were never made valid.

15 JUDGE FLUEGGE: Only now the interpretation was finished.

16 You should really slow down. It's impossible for the

17 interpreters to follow.

18 THE WITNESS: [Interpretation] I'm a teacher. It's a habit, and

19 old habits die hard.

20 JUDGE FLUEGGE: But even teachers should learn something.

21 THE WITNESS: [Interpretation] I couldn't agree more.

22 MR. LUKIC: [Interpretation].

23 Q. Mr. Adzic, this is all that we had to ask you, and I would like

24 to thank you for answering our questions.

25 JUDGE ORIE: Judge Fluegge has a question before the Prosecution

Page 24762

1 will start its cross-examination.

2 JUDGE FLUEGGE: I would like to ask you to explain one matter of

3 timing, which I really didn't understand. Just a moment.

4 THE WITNESS: [Interpretation] I'm listening.

5 JUDGE FLUEGGE: You said, and this is on page 12:

6 "After the 3rd of May when the attack occurs," and then some

7 lines down at the beginning of page 13, you said: "The very first shell

8 that came from Breza killed a Muslim." Then you explain how you reached

9 an agreement with the Croatian --

10 THE WITNESS: [Interpretation] The 3rd of May, yes. The 3rd of

11 May.

12 JUDGE FLUEGGE: The 3rd of May, indeed.

13 And then you explain how you reach an agreement with the other

14 side about transportation of wounded people. And then you said, this is

15 page 13, line 19:

16 "It went on until the 3rd of May 1992," this agreement.

17 Perhaps it was a slip of the tongue. Explain the dates again,

18 please.

19 THE WITNESS: [Interpretation] I apologise. I meant the 3rd of

20 June. When it comes to the transportation of wounded people, the

21 agreement was in place until the 3rd of June. Why the 3rd of June?

22 Because on the 3rd of June, there was a second offensive.

23 JUDGE FLUEGGE: I just wanted to ask you a --

24 THE WITNESS: Okay.

25 JUDGE FLUEGGE: -- clarification of the date. Now you say it

Page 24763

1 went on until the 3rd of June, 1992; correct?

2 THE WITNESS: [Interpretation] The agreement on the transportation

3 of wounded people. That was in place until the 3rd of June.

4 JUDGE FLUEGGE: Thank you.

5 THE WITNESS: [Interpretation] When I said the 3rd of May, I

6 probably had a different development or event in mind.

7 JUDGE FLUEGGE: I think it was a slip of the tongue. Thank you

8 very much.

9 JUDGE ORIE: I have one or two questions for you as well.

10 In your statement, we do not find a lot about the establishment

11 of the Crisis Staff. Neither about your position as president of the

12 Crisis Staff. You said it was established in December 1991. Was this

13 openly done or was it secretly done?

14 THE WITNESS: [Interpretation] It was done openly. The municipal

15 assembly of Ilijas functioned and it had all of its bodies. Perhaps it

16 was not even necessary to set up a Crisis Staff. However, we honoured

17 the decision of --

18 JUDGE ORIE: Yes. Let me first -- I didn't ask you whether it

19 was necessary or not but just on whether it was openly done or secretly

20 done. You've answered that question.

21 You also said that it was --

22 THE WITNESS: [Interpretation] Precise -- yes, it was done openly.

23 It was done publicly.

24 JUDGE ORIE: Yes. And you said it was done, and that's where I

25 interrupted you, on the instructions of whom?

Page 24764

1 THE WITNESS: [Interpretation] It was a recommendation by the

2 presidency of Republika Srpska.

3 JUDGE ORIE: The presidency, the complete presidency --

4 THE WITNESS: [Interpretation] A complete presidency. Yes, the

5 complete presidency of Republika Srpska. That's what we saw in their

6 letter.

7 JUDGE ORIE: Yes. They sent a letter to whom?

8 THE WITNESS: [Interpretation] Personally, I think it was sent to

9 all the presidents of the municipalities where they existed or those Serb

10 bodies who -- which had been set up in the Serbian territory before the

11 war broke out.

12 JUDGE ORIE: You said, "... sent to all the presidents of the

13 municipalities where they existed," what do you mean by "they"?

14 THE WITNESS: [Interpretation] After the elections, there was a

15 distribution of power in all of the 109 municipalities. Where the SDS

16 participated in the elections, it had the right to participate in the

17 authorities of that municipality, its representatives. There were places

18 where they were a minority, there were places where they did not even

19 exist, and there were places where they were a majority. And based on

20 the relationship of the participation of powers in every municipality, if

21 there was a nucleus of Serbian representatives in that power, they

22 inherited that line of management as bodies of the Serbian political

23 authorities.

24 JUDGE ORIE: Yes. Was this a public decision where it was

25 represented to establish the Crisis Staff?

Page 24765

1 THE WITNESS: [Interpretation] Of course. The Assembly of

2 Republika Srpska was already set up after the division in the parliament

3 of Bosnia-Herzegovina. The government of Republika Srpska was also

4 established, and the establishment of all the other bodies including

5 ministries was underway. There was also a presidency which comprised the

6 president, the vice-president, and so on and so forth. Those were

7 legitimate decisions made by the state bodies --

8 JUDGE ORIE: I didn't ask you whether it was legitimate or not.

9 I only asked you whether it was public or not.

10 THE WITNESS: [Interpretation] I apologise, then. Yes, of course.

11 It was public. Yes.

12 JUDGE ORIE: Now, finally, do I understand that you were, as

13 the -- and I'm reading from paragraph 18 of your statement, that as the

14 president of the Crisis Staff, that Serb units, until the establishment

15 of the Army of Republika Srpska, were under your command?

16 THE WITNESS: [Interpretation] Partly, yes. Partly. Those were

17 TO units of the Serbian people.

18 JUDGE ORIE: Yes. And you say "partly." Was there any other

19 Serb units not commanded by you?

20 THE WITNESS: [Interpretation] No, there were in other units.

21 There were only TO units. And the reason why --

22 JUDGE ORIE: No. What does then "partly" mean?

23 THE WITNESS: [Interpretation] I said partly, meaning that the

24 brigade commander was appointed when the staff was established. We tried

25 to select trained officers. Obviously they were responsible, and they

Page 24766

1 were in charge of decision-making. However, that was a TO unit. We

2 consulted each other. If their decisions went beyond the scope of

3 defence, those decisions obviously concerned the use of those units.

4 JUDGE ORIE: Thank you for those answers.

5 Ms. Bibles, I'm looking at the clock, perhaps it would be better

6 to start the cross-examination after the break, and take an early break.

7 We take a break, Mr. Adzic, of 20 minutes. We would like to see

8 you back. You may now follow the usher.

9 [The witness stands down]

10 JUDGE ORIE: We resume at quarter to 11.00.

11 --- Recess taken at 10.28 a.m.

12 --- On resuming at 10.49 a.m.

13 JUDGE ORIE: While we are waiting for the witness to be brought

14 in, I briefly deal with the following matter. It's about P6680 and

15 P6682.

16 During the testimony of Milutin Vujicic on the 17th of July, the

17 Prosecution indicated that the parties would discuss a possible agreement

18 on whether certain portions of P6680 and P6682 should be tendered. On

19 the 25th of August, the Prosecution informed the Chamber through an

20 informal communication that no agreement was reached with regard to P6682

21 and that the Defence intended to make written submissions.

22 With regard to P6680, the Prosecution indicated that the parties

23 agreed to tender the entire document but that there were some translation

24 issues for which the Prosecution had already made the appropriate

25 requests.

Page 24767

1 The Chamber notes that the document is 74 pages long, and the

2 Chamber is not inclined to admit it in its entirety. The Chamber,

3 therefore, gives the parties one week to file submissions explaining why

4 they deem it necessary to admit the document in its entirety rather than

5 the portions that were discussed with the witness.

6 [The witness takes the stand]

7 JUDGE ORIE: Mr. Adzic, you'll now be cross-examined by

8 Ms. Bibles. Ms. Bibles speaks slowly. You're invited to do the same.

9 You'll find Ms. Bibles to your right. Ms. Bibles is counsel for the

10 Prosecution.

11 Please proceed, Ms. Bibles.

12 MS. BIBLES: Thank you, Mr. President.

13 Cross-examination by Ms. Bibles:

14 Q. Mr. Adzic, in your statement and in your testimony, you describe

15 being elected to the local SDS board. Isn't it true that you were also

16 elected a member to the SDS Main Board starting in 1991?

17 A. It is correct. I practically participated in the establishment

18 of the SDS. I was elected a member of the SDS Main Board, and I was one

19 of the main organisers of the SDS in the territory of the Ilijas

20 municipality. Based on that, I was elected president of the SDS council

21 that was registered in August 1991 with the competent authorities of BiH

22 as a legitimate political party preparing itself for the elections.

23 Q. I want to turn now to your discussion about paragraph 18 of your

24 statement and some of the questions right before we went to break. This

25 has to do with the Serb units that made up the defence of Ilijas prior to

Page 24768

1 the formation of the VRS. You've told us that the TO was -- made up part

2 of these units. Were the Serbian police also part of these units?

3 A. The Serbian police did not make part of those units until the

4 30th of March 1992 when there was a split in the police at the republican

5 level. On the 30th of March, the Ilijas police station also reflected

6 that division. It was divided into the Serbian and Muslim police

7 station. In agreement with the SDA and HDZ on my proposal, since in some

8 other police stations some Serbians were arrested or persecuted, I

9 insisted that the Muslim members of the police be allowed to take

10 material and equipment assigned to each policeman so that they could

11 establish their own police station in the territory where they believed

12 necessary in order to set up police authority in the settlements where

13 there was a majority Muslim population.

14 Q. Can we agree that the VRS was formed on the 12th of May 1992?

15 A. I think the Main Staff, by a decision of the RS presidency, was

16 formed on the 12th of May.

17 Q. Is it accurate that the Ilijas Light Infantry Brigade was created

18 on the 27th of May 1992?

19 A. Yes. Don't hold me exactly to the date given the number of years

20 that have passed, but it was around that time. It was pursuant to the --

21 to a decision of the Serbian Crisis Staff headed by Mr. Bogdan Jevtic, a

22 colonel. It was on his proposal that the established TO units were

23 placed under a single command and the unit called the Ilijas Brigade.

24 Q. Is it true that this initial brigade was comprised of ten

25 infantry companies and a mixed artillery division?

Page 24769

1 A. At the moment of establishment, we did not have a mixed artillery

2 regiment. It was only established later. The TO companies that existed

3 at the time -- well, I don't know whether there was -- there were

4 precisely 14, but the number of TO companies that existed before that was

5 the number of the companies that made part of the Ilijas Brigade.

6 Q. Perhaps we should take a look at the order establishing the

7 brigade.

8 MS. BIBLES: If we could have P3797 on our screens, please.

9 JUDGE ORIE: While we're waiting for that to come up.

10 Mr. Adzic, I asked you before the break - clearly - whether there

11 were any other units than the TO that were referred to in paragraph 18

12 and were under the command of the Crisis Staff. You said there were no

13 other units, whereas I now understand from your previous answer that from

14 the 30th of March - that is the whole month of April - and the beginning

15 of May that, that the police forces were among those units as well.

16 Where I specifically asked you whether there were any other units, you

17 said there were not. It now turns out that police units were, at least

18 during five or six weeks, part of that.

19 Will you please, instead of giving long answers not always

20 related to the questions, would you focus on what is asked and would you

21 please be precise in your answers. Is that clear to you?

22 THE WITNESS: [Interpretation] It is. Perhaps I misunderstood,

23 especially in terms of time, because the police separated only as late as

24 the 30th of March. That is why I didn't pay attention to it.

25 JUDGE ORIE: I asked you about the time until the establishment

Page 24770

1 of the VRS, which was on the 12th of May. So perhaps you should be

2 focused more listening to the question rather than expanding on matters

3 which are not asked.

4 Ms. Bibles, if the witness goes, dwells away from what you ask

5 him, please stop him and bring him back to what you asked him. Please

6 proceed.

7 MS. BIBLES: Thank you, Your Honour.

8 Q. Sir --

9 MS. BIBLES: And if we could go to page 2 in the English. Thank

10 you.

11 Q. -- we're looking at the 27th May 1992 description of the creation

12 of the Ilijas Light Infantry Brigade. And I'd ask you to look in section

13 2. It's the second bullet pointed area where it's describing the

14 brigade. Excuse me, I'm sorry. In the first bullet point, where it

15 indicates:

16 "There are ten infantry companies and a mixed artillery division

17 in the brigade."

18 Do you see that?

19 A. Yes. Yes, ten. I can see. It is on the 27th. I apologise.

20 The report is dated the 27th of May. In the meantime, the brigade --

21 THE INTERPRETER: Interpreter's note: The witness trailed off.

22 Could he kindly repeat the end of his answer.

23 JUDGE ORIE: Could --

24 MS. BIBLES: Could -- oh, I'm sorry.

25 Q. Could you tell us the end of your last answer? We were not able

Page 24771

1 to articulate it.

2 A. When the corps command was established around the 20th of May,

3 any further structuring and organisation as well as arming fell within

4 the competence of the corps command. Before the 20th of May, as part of

5 the brigade, there was no --

6 JUDGE ORIE: Witness --

7 THE WITNESS: [Interpretation] -- specific location where the MAP

8 was designated, the mixed artillery battalion.

9 JUDGE ORIE: -- you're not here to give any lessons. You're here

10 to answer a question. The only question that was put to you was whether

11 you saw, in this document, what Ms. Bibles referred to. Wait for --

12 THE WITNESS: Okay.

13 JUDGE ORIE: -- any further question. And Ms. Bibles will be --

14 THE WITNESS: Okay.

15 JUDGE ORIE: -- precise on it.

16 Ms. Bibles, please proceed.

17 MS. BIBLES:

18 Q. Can you tell us whether you had a position of authority with

19 respect to the Ilijas Light Infantry Brigade in May of 1992?

20 A. Not in the sense of a particular position in the brigade. I was

21 simply the municipal president and the president of the Crisis Staff.

22 Q. In your capacity as president -- municipal president and

23 president of the Crisis Staff, did you have any type of authority over

24 the light brigade?

25 A. I did have authority in consulting the command in certain

Page 24772

1 circumstances if they so required.

2 MS. BIBLES: I'd now like to turn to 65 ter 3714.

3 Q. Sir, this is a letter, it appears, that you wrote to

4 President Karadzic.

5 MS. BIBLES: And, Your Honour, before we go into some of the

6 areas that are raised in this letter, this may be an appropriate time for

7 the witness to receive a caution regarding 90(E).

8 [Trial Chamber confers]

9 JUDGE ORIE: Witness, Ms. Bibles asked me to give a caution under

10 Rule 90(E). You may not be aware of what that is, but I'll explain it to

11 you.

12 If any of the answers you would give to any of the questions put

13 by Ms. Bibles, if any of those answers might tend to incriminate

14 yourself, then you may object to answer such a question. The Chamber

15 will then consider whether or not we'll compel you to answer the

16 question.

17 Now, if we do compel you to answer the question, your answer

18 shall not be used as evidence in a subsequent prosecution against

19 yourself for any offence other than false testimony. So if you are

20 afraid that you would -- that the answer would tend to incriminate

21 yourself, you may address me.

22 Please proceed, Ms. Bibles.

23 MS. BIBLES:

24 Q. Sir, can you look at the letter on the screen and tell us whether

25 that is your signature at the bottom?

Page 24773

1 A. Yes, it is.

2 Q. We note that it is signed, "Commander of the Ilijas ..." Sorry,

3 "the army of the Serbian people in Bosnian and Herzegovina." Can you

4 explain to us what that position means?

5 A. I didn't pay attention to it. It was probably it the typist's

6 habit. In practice, that was the way the Crisis Staff command was

7 designated. He probably typed it that way because it was considered to

8 be the command of the Crisis Staff.

9 Q. Sir, this is a letter that you've told us that you're writing to

10 the president of the Republika Srpska. Are we to understand that you

11 didn't look at the title under which you were writing that letter before

12 you signed it?

13 A. It doesn't say "VRS."

14 JUDGE MOLOTO: [Previous translation continues]...

15 MS. BIBLES:

16 Q. Could you read what the title says?

17 A. It could be treated as "The Military Forces of the

18 Territorial Defence." I coordinated those forces at the time and that is

19 what the abbreviation stand for.

20 Q. Sir, does it not read: "Commander of the Ilijas VSN BiH"?

21 A. Yes, of the municipality of Ilijas.

22 JUDGE ORIE: Witness, Witness, VSN stands for what, literally?

23 Not your explanation, but what does VSN stand for?

24 THE WITNESS: [Interpretation] It was considered to be the

25 military forces of the Territorial Defence. It --

Page 24774

1 JUDGE ORIE: [Overlapping speakers].

2 THE WITNESS: [Interpretation] -- had been established at the

3 time, but it was in the stage of harmonisation.

4 JUDGE ORIE: You're not teaching. I asked you VSN, three

5 letters, stand for what, exactly? I expect three words.

6 THE WITNESS: [Interpretation] The military forces of Ilijas. And

7 it was understood to mean the Territorial Defence.

8 JUDGE ORIE: Well, Witness, again, I instructed you not to give

9 your explanation at this moment but just to give us the three words. You

10 apparently ignore my instructions.

11 THE ACCUSED: [Microphone not activated].

12 JUDGE ORIE: And no loud speaking from Mr. Mladic. No speaking

13 aloud.

14 THE WITNESS: [Interpretation] The VS stands for military forces.

15 As for the N, it is "peoples." That is what was understood. That is why

16 you do not find the acronym TO. I was the municipal president

17 representing the --

18 JUDGE ORIE: [Overlapping speakers].

19 THE WITNESS: [Interpretation] -- inhabitants of the Serbian

20 municipality of Ilijas.

21 JUDGE ORIE: I now instruct you clearly to answer questions. And

22 if I said twice to you that I'm not seeking your explanation but that I'm

23 just asking you a very specific question, if you continue like this, we

24 may have to take measures which possibly could include that your

25 testimony will be invalid before this Court. That is a possible

Page 24775

1 consequence if you continue to act like you do at this moment.

2 Ms. Bibles, I would appreciate if you would also pay attention to

3 the heading of this letter. I don't know whether you intended to do

4 that, but especially the third line.

5 MS. BIBLES:

6 Q. Sir, in trying to articulate what this letter means both in terms

7 of your position and what is going on at the time, I'll ask you to please

8 read the very top three lines of this letter.

9 A. "It is my pleasure to inform you" --

10 Q. Sir, sir --

11 A. -- "that in the battles waged thus far" --

12 Q. At the very top of the letter, the very left-hand side.

13 A. At the very beginning?

14 Q. Yes, the very beginning, which indicates --

15 A. [In English] Okay. Okay. Yes. [Interpretation] Serbian

16 Republic of Bosnia-Herzegovina. Serbian municipality of Ilijas. Command

17 of the Ilijas Serbian army. To the president of the presidency of the

18 Serbian Republic of BiH.

19 "It is my pleasure to inform you that" --

20 JUDGE ORIE: [Overlapping speakers].

21 THE WITNESS: [Interpretation] "... that in the battles waged thus

22 far, the enemy forces ..." Is that what you want?

23 JUDGE ORIE: Sir, you were asked to read the first three lines.

24 Please try to carefully listen to the question --

25 THE WITNESS: Okay, okay.

Page 24776

1 JUDGE ORIE: Please proceed, Ms. Bibles.

2 MS. BIBLES:

3 Q. Sir, in looking at the first three lines on the upper left-hand

4 side, doesn't this suggest - in fact, openly state - that you were

5 writing President Karadzic as the commander of the Serbian -- of the

6 Ilijas Serbian army command?

7 A. President Karadzic, as RS president, was the Supreme Commander.

8 We followed that line of authority and we addressed him on behalf of the

9 military units command. It was considered appropriate for me to address

10 the president of the republic in that way. That is what it means.

11 Q. Sir, let's turn now to the content of the letter. Without

12 reading it verbatim, is it accurate to say that you were asking

13 President Karadzic to use his influence to obtain very specific military

14 equipment for the Ilijas Brigade?

15 A. That is correct. Precisely because --

16 Q. That's all I asked. We see in the second paragraph that you

17 justify this request by saying:

18 "I need these artillery pieces for further defence and the

19 self-propelled anti-aircraft guns to cleanse certain pieces of terrain in

20 the Ilijas municipality."

21 Can you tell us in what direction you wanted the self-propelled

22 Praga anti-aircraft guns to be aimed?

23 A. In that period, since the territory of Ilijas municipality is

24 mostly in hilly terrain, there were some sabotage groups, Muslim groups,

25 in parts of our territory which cut off our roads and communication. The

Page 24777

1 army and the command of the Ilijas Brigade could not successfully engage

2 them without additional assets. I had such forested areas in mind. To

3 neutralise those groups which made incursions around the clock in order

4 to secure our communication with Pale, road wise.

5 MR. LUKIC: I'm sorry, if I way.

6 JUDGE ORIE: Yes, Mr. Lukic.

7 MR. LUKIC: Obviously, Ms. Bibles, I don't have English

8 version -- translation, actually, of this document, but "Praga" is not

9 self-propelled. It's a machine-gun. So if it says in the translation

10 "self-propelled" it's not correct. I don't have translation in front of

11 me.

12 JUDGE ORIE: You see the original.

13 MR. LUKIC: Yes. It just says "Praga."

14 JUDGE ORIE: It just says "Praga."

15 MR. LUKIC: There is no "self-propelled." Three Pragas.

16 JUDGE ORIE: There may be a translation issue there. So let's

17 forget about the "self-propelled" and let's leave it to "Praga."

18 MS. BIBLES: Yes.

19 Q. Sir, does the fact that you're asking President Karadzic to use

20 his influence to get these weapons for you mean that the SRK command

21 rejected a request to give the brigade this equipment? Do you have an

22 answer?

23 A. This doesn't mean that the request was turned down. Due to the

24 difficult situation and the necessity to equip the units of the brigade

25 as quickly as possible, I tried to ask President Karadzic to speed that

Page 24778

1 process along. That's all.

2 Q. Did you reach out to other political leaders at the republic

3 level?

4 A. No.

5 MS. BIBLES: Your Honour, I move to tender 65 ter, I think it's,

6 3714.

7 JUDGE ORIE: Madam Registrar.

8 THE REGISTRAR: Document 3714 receives number P6695, Your

9 Honours.

10 JUDGE ORIE: P6695 is admitted -- no, is marked for

11 identification pending a verification of the translation.

12 MS. BIBLES:

13 Q. Sir, your letter to President Karadzic was dated 12 June 1992.

14 I'd like to show you an entry from General Mladic's notebook from the

15 following day, which would be 13 June 1992.

16 MS. BIBLES: If we could have P353, page 155 in English and 154

17 in the original.

18 Q. Now, sir, as this comes up or as it's come up in the original,

19 this entry notes that on this date General Mladic is at a meeting at the

20 presidency. Here in this initial section of that meeting, Mladic reports

21 or refers to "president of Ilijas SO" wants tanks and anti-aircraft

22 weapons.

23 First, can we agree that Mladic is referring to you in this line?

24 A. I assume so.

25 Q. And just for the record, does SO refer to "Srpska Obstina"?

Page 24779

1 A. Yes.

2 Q. Now, sir, isn't it true that Ilijas did not get tanks and Praga

3 anti-aircraft weapons from the VRS as a result of your request, did they?

4 A. I don't know that. It received weapons later, but I was not

5 involved in that. It was the corps command who decided on those matters.

6 Q. So just to make sure that we understand. In some capacity,

7 military capacity, you wrote to President Karadzic, and the military

8 did -- basically, the military made the decision at the corps level as to

9 what the brigade needed. Is that accurate?

10 A. Yes.

11 Q. During mid-June --

12 MS. BIBLES: And we can take this from the screen at this point.

13 Q. During mid-June, 1992 --

14 JUDGE ORIE: Before we --

15 MS. BIBLES: I'm sorry.

16 JUDGE ORIE: Before we do so, apparently a similar issue arises

17 as Pragas being more or less interpreted as self-propelled anti-aircraft

18 guns. Now, I'm not insisting on a review of the whole of the -- of the

19 notebook, but at least could you try to seek an agreement whether Pragas

20 are in any way self-propelled or whether we should ignore the

21 self-propelling feature of what is called Pragas.

22 MS. BIBLES: Yes, Your Honour.

23 JUDGE ORIE: Please proceed.

24 MS. BIBLES:

25 Q. During mid-1992 at the same time -- excuse me, mid-June, the same

Page 24780

1 time in which you were asking for tanks, isn't it true that you also sent

2 out requests for additional manpower?

3 A. No, I did not send any requests for additional manpower to

4 anybody.

5 MS. BIBLES: If we could have 65 ter 3301 on our screens, please.

6 Q. Sir, when this comes on our screen, we'll see a letter requesting

7 help from the Serb Volunteer Guard for the Ilijas Brigade or the Ilijas

8 municipality.

9 Sir, I'll give a few minutes to review the letter. It appears

10 that you've had a chance to look at it. Did you authorise this request?

11 A. I can only say that I've not seen this request before. It was

12 not drafted on my request. It doesn't contain a stamp or a signature. I

13 was not familiar with its contents and anybody could have drafted this.

14 Q. Sir --

15 MS. BIBLES: If we could move to 65 ter 3717 next.

16 Q. And, sir, this appears to be another request for help. This time

17 from the Serbian National Renewal Belgrade. This is dated also 14 --

18 actually, this one appears -- we believe that there is a, perhaps, a date

19 issue. In any event, please take a look at this letter and tell us

20 whether you authorise this request.

21 A. No.

22 Q. And, sir, then --

23 MS. BIBLES: If we could turn to 65 ter 10722.

24 JUDGE FLUEGGE: Before you do that, then I would like to ask the

25 witness: Can you tell us if you ever seen this document which is now on

Page 24781

1 the screen?

2 THE WITNESS: [Interpretation] No, no, no.

3 JUDGE FLUEGGE: Did anybody tell you about this document?

4 THE WITNESS: [Interpretation] No, not about the document.

5 However, at the time --

6 JUDGE FLUEGGE: No, I -- I'm asking --

7 THE WITNESS: [Interpretation] -- I heard from a --

8 JUDGE FLUEGGE: -- I'm asking about the document. I'm only

9 asking about this document.

10 THE WITNESS: [Interpretation] No, no.

11 JUDGE FLUEGGE: Have you any explanation about why your name is

12 written at the end of this document?

13 THE WITNESS: [Interpretation] Anybody's name can appear in any

14 document. I didn't know anything about this document. I tried to

15 explain, with your leave, of course --

16 JUDGE FLUEGGE: No.

17 THE WITNESS: [Interpretation] -- that I --

18 JUDGE FLUEGGE: No, I don't -- you said you don't have any

19 explanation for that. Thank you.

20 THE WITNESS: [Interpretation] No, I don't.

21 MS. BIBLES: And I'd -- at this time if we could go to

22 65 ter 10722.

23 Q. And, sir, this appears to be a similar, although longer letter.

24 Now, sir, the three requests have all born very similar information on

25 the upper left-hand corner as to where they were coming from, including

Page 24782

1 numbers. Can you tell us whether the numbering at the upper left-hand

2 corner --

3 A. [In English] No, no.

4 Q. -- is something that looks familiar to you?

5 A. [Interpretation] No. Usually documents contain protocol numbers

6 and it seems that somebody used random numbers. I have never seen these

7 documents before. And, as you can see for yourself, I never signed them.

8 At that time, anybody could draft a document of this kind. I claim

9 categorically I had absolutely nothing to do with these documents. I

10 don't know about them. They were not drafted on my instruction. I

11 didn't draft them myself.

12 Q. Sir, would you agree that there were already Serb volunteers in

13 Ilijas by June of 1992 as part of the Serb forces?

14 A. Organised volunteer forces did not exist. There was not a single

15 unit. All the units that were armed were part of the Ilijas Brigade.

16 There were perhaps individual cases or, rather, individuals who arrived

17 from other territories in Ilijas and they joined voluntarily because they

18 couldn't be mobilised. That's why they were considered volunteers in the

19 units of the Ilijas Brigade.

20 MS. BIBLES: If we could go to --

21 JUDGE ORIE: Could we --

22 MS. BIBLES: Oh, I'm sorry.

23 JUDGE ORIE: Could we go -- again, carefully look at the

24 question. The question was whether there were already Serb volunteers in

25 Ilijas by June of 1992 as part of the Serb forces. You started your

Page 24783

1 answer by saying "Organised volunteer forces did not exist ..." The real

2 answer is that volunteers may have been in the Serb forces in Ilijas by

3 June of 1992.

4 No one asked you whether they were organised as volunteer units.

5 The question was whether volunteers were there and apparently the answer

6 is yes, that, at least, on an individual basis.

7 Please start your answer to focus on the question rather than to

8 what apparently you consider more important to tell us. Most important

9 is an answer to the question.

10 Please proceed, Ms. Bibles.

11 JUDGE FLUEGGE: Can we go to the end of the document in both

12 languages. I am not sure if we are at -- really at the bottom of the

13 page in B/C/S. I would like to see the far end.

14 Witness, do you see in the B/C/S at the end there is a kind of an

15 initial or minimal handwriting thing. Do you know what that could mean?

16 THE WITNESS: [Interpretation] I apologise. Which initials do you

17 have in mind? I can't find them.

18 JUDGE FLUEGGE: I don't know if that -- if these are initials --

19 THE WITNESS: [Interpretation] If you mean the initial which looks

20 like a cross, like an encircled cross.

21 JUDGE FLUEGGE: Possible. At the end of the document, I assume

22 that you see the words "president of the Crisis Staff." There is --

23 THE WITNESS: [Interpretation] Yes, and then it says "SSR," I

24 don't know what that means. There is a dash as well. Or perhaps "SRR."

25 JUDGE ORIE: If I can assist, I think that Judge Fluegge is

Page 24784

1 referring to what appears to the letter K and R at "crisis" before

2 "staff."

3 JUDGE FLUEGGE: There is a handwritten line. Do you know what

4 that means?

5 THE WITNESS: [Interpretation] The only thing I see is a

6 semicircle, a line. That's what I see on my screen.

7 JUDGE FLUEGGE: Have you any explanation for that?

8 THE WITNESS: [Interpretation] No, I have no clue.

9 JUDGE FLUEGGE: Thank you.

10 MS. BIBLES: Thank you.

11 If we could next go to 65 ter 14471A.

12 Q. Sir, this is an excerpt from a book about the Seselj Chetnik

13 movement. We'll be looking at an order that is reprinted from that book

14 or reprinted in the book.

15 And, sir, as you see the document come up, you see that it's

16 dated 20 March 1994. I would direct your attention down to the prominent

17 number 1. It describes an individual, Vidovic. Do you see that?

18 A. Yes, I do. Yes.

19 Q. After describing his efforts elsewhere, towards the end we read:

20 "At the end of February 1992, he went to the

21 Sarajevo-Ilijas ... where he still is today."

22 JUDGE ORIE: Part of the quote --

23 MS. BIBLES: Oh, I'm sorry.

24 JUDGE ORIE: -- was the word "battle-field."

25 MS. BIBLES: Oh, yes, I'm sorry.

Page 24785

1 Q. "Sarajevo-Ilijas battle-field where he is today."

2 Do you know this individual?

3 A. Yes.

4 Q. Do you know him to be a Seselj fighter or one of the Seselji?

5 A. He presented himself as a member of the Serbian Radical Party.

6 Q. And did he participate as part of the Serb forces for Ilijas

7 starting in February of 1992?

8 A. Yes, in TO units. But exclusively under the command of the

9 Territorial Defence, nobody else's, irrespective of party affiliations.

10 Q. After the TO did he become part of the brigade under the VRS?

11 A. Yes. He was the commander of an intervention platoon of the

12 Army of Republika Srpska in the Ilijas Brigade.

13 MS. BIBLES: Your Honour, I would tender 65 ter 14471A.

14 JUDGE ORIE: Madam Registrar.

15 THE REGISTRAR: Document 14471A receives number P6696, Your

16 Honours.

17 JUDGE ORIE: Yes. And that is only the excerpt [Microphone not

18 activated] That's only the excerpt.

19 MS. BIBLES: Yes, that's correct. I'm sorry. I should have

20 explained it.

21 JUDGE ORIE: Yes.

22 MS. BIBLES: Just that portion.

23 JUDGE ORIE: Yes, P6696 is admitted into evidence.

24 MS. BIBLES:

25 Q. Sir, I'd like to shift topics a bit and go back to some areas

Page 24786

1 that you touched on earlier today in your testimony. And that has to do

2 with the departure of non-Serbs from Ilijas.

3 You testified that individuals had a right to leave and that

4 there was, I believe, free departure. In order to leave, did Bosniaks

5 need to have your permission?

6 A. Not from me. They were supposed to report to the Red Cross in

7 order to be provided with passes, because the police units at

8 check-points had an order to the effect that if they had such passes,

9 they were not supposed to be stopped at those check-points or prevented

10 from crossing them.

11 MS. BIBLES: If we could look at 65 ter 31131.

12 Q. Sir, this appears to be an authorisation signed by you allowing

13 certain named Bosniaks to leave Ilijas. Do you recognise this document?

14 A. I recognise the signature.

15 Q. All right. Let's start at the top left-hand -- the --

16 JUDGE ORIE: The question was whether you recognised the

17 document. Do you recognise the document? No, you said you recognised

18 the signature. Do you recognise the document?

19 THE WITNESS: [Interpretation] Yes. May I explain the whole

20 situation?

21 JUDGE ORIE: No.

22 Please proceed, Ms. Bibles.

23 MS. BIBLES: Thank you.

24 Q. First, I should clarify. The signature, is that your signature?

25 A. Yes.

Page 24787

1 Q. And the upper left-hand corner of this letter indicates that it

2 comes from the command of the 1st Sarajevo-Ilijas Brigade, and it appears

3 to be dated 29 June 1992. Sir, next to your -- or above your signature,

4 your title is commander. So can you tell us your position at that time

5 as of the 29th of June 1992?

6 A. My position was as the president of the municipality. Those were

7 chaotic times. Somebody typed up the document. I remember this case.

8 The brigade command and the check-points where people were checked at the

9 separations lines could not meet their requests, which is why they came

10 to me to allow them to leave.

11 Q. Sir, I asked you your position as of the 29th of June 1992. Sir,

12 you have testified now that in order to leave Bosniaks simply needed to

13 have something from the Red Cross. This appears to be a document signed

14 by you as a commander allowing these individuals to leave. I'll put it

15 to you that your testimony, that people had freedom to depart and a right

16 to leave, was not accurate.

17 A. No, those were exceptional situations. And as I've already said,

18 the times were chaotic. And sometimes there were discrepancies in the

19 Red Cross and in the brigade command. Then they wanted for my -- asked

20 for my arbitration as to how to proceed, and then I suggested that people

21 should be allowed to move freely wherever they wanted to go. If there

22 was anything in dispute, I mean. And whoever typed up the word

23 "commander" is a mistake. I was not a brigade commander. I may have not

24 paid too much attention when I approved this request. In any case, I was

25 not a commander. I was only the president of the municipality.

Page 24788

1 Q. Sir --

2 JUDGE MOLOTO: I have a question.

3 Sir, just in response to the answer you've just given, the

4 heading of that letter says: "Command of the 1st Sarajevo-Ilijas

5 Brigade." Didn't you see that when you signed the letter?

6 THE WITNESS: [Interpretation] That document was drafted in

7 agreement with the command, because --

8 JUDGE MOLOTO: I --

9 THE WITNESS: [Interpretation] [Overlapping speakers].

10 JUDGE MOLOTO: I stop you. My question is: Did you not see the

11 words "Command of the 1st Sarajevo-Ilijas Brigade" when you signed this

12 letter? Yes or no.

13 THE WITNESS: [Interpretation] It was not of major importance.

14 JUDGE MOLOTO: That's not the question.

15 THE WITNESS: [Interpretation] It was not decisive.

16 JUDGE MOLOTO: Did you see the words, yes or no? You have been

17 told so many times to please concentrate on the question.

18 THE WITNESS: [Interpretation] [Overlapping speakers].

19 JUDGE MOLOTO: Don't talk when I'm talking. Don't talk.

20 THE WITNESS: [Interpretation] I understand. I understand.

21 JUDGE MOLOTO: You have been told many times to concentrate on

22 the question and answer the question and not give your explanations. Did

23 you see these words before you signed this letter?

24 THE WITNESS: [Interpretation] It is very possible that I did not.

25 At that moment it was --

Page 24789

1 JUDGE MOLOTO: Stop.

2 THE WITNESS: [Interpretation] -- simply not important.

3 JUDGE MOLOTO: Stop there. Did you also not see the word

4 "commander" above your signature?

5 THE WITNESS: [Interpretation] Again, it was of no importance at

6 all.

7 JUDGE MOLOTO: And my last question to you is: Can you read us

8 what's written on that stamp, the official stamp?

9 THE WITNESS: [Interpretation] "The Serbian municipality of

10 Ilijas, the Serbian Republic of Bosnia-Herzegovina," and this is the

11 president of the municipality of Ilijas's stamp. When I needed to

12 intervene on behalf of anybody, I --

13 JUDGE MOLOTO: Sorry, I --

14 THE WITNESS: [Interpretation] -- signed such a document and

15 stamped it.

16 JUDGE MOLOTO: I stop you there. Just read what's inside the

17 document and not --

18 THE INTERPRETER: The witness is sitting too close to microphone.

19 THE WITNESS: [Interpretation] The Serbian Republic of

20 Bosnia-Herzegovina, the Serbian Republic of Ilijas.

21 JUDGE FLUEGGE: Can that be enlarged, please.

22 THE WITNESS: [Interpretation] This was a stamp that was valid

23 between 4th of April and the 12th of May.

24 JUDGE MOLOTO: [Overlapping speakers].

25 THE WITNESS: [Interpretation] It was a stamp of the Serbian

Page 24790

1 Ilijas Brigade. It says the Serbian Ilijas Brigade.

2 JUDGE MOLOTO: That's right. Serbian Ilijas Brigade. Thank you.

3 THE WITNESS: [Interpretation] Now I have just realised that it is

4 actually the stamp of the Ilijas Brigade, now that the document has been

5 enlarged.

6 JUDGE MOLOTO: Which you signed.

7 THE WITNESS: [Interpretation] Please, if you allow me. Which was

8 valid from the 4th of April until the 20th of May. That was the period

9 during which the stamp was actually valid.

10 JUDGE MOLOTO: And when you did sign, you signed it as the

11 official in the Ilijas Brigade, didn't you?

12 THE WITNESS: [Interpretation] Not during that time.

13 JUDGE MOLOTO: Thank you so much.

14 THE WITNESS: [Interpretation] People were leaving because of --

15 JUDGE MOLOTO: Thank you, Madam Prosecutor.

16 JUDGE ORIE: It's time for a break.

17 MS. BIBLES: Your Honour, if I could tender --

18 JUDGE ORIE: Witness, Witness -- no. Put on your earphones

19 again.

20 Witness, during the break, you should carefully consider whether

21 you want to continue to answer questions that are not put to you, to give

22 explanations which you're not asked to do, and not to follow

23 instructions. If that is what you want to do, your position as a Defence

24 witness might have to be reconsidered by this Chamber. So therefore

25 suppress your apparent natural inclination to tell us what you want to

Page 24791

1 tell us and focus on what we want you to tell us; that is, an answer to

2 the questions that are put to you. Our patience is not without

3 limitations. Let that be clear to you. Take your time to consider it.

4 And it's time for a break now.

5 We'll resume at five minutes past 12.00. But --

6 THE ACCUSED: [In English] Please.

7 JUDGE ORIE: Mr. Mladic wants to consult which he can do during

8 the break, Mr. Lukic.

9 You may follow the usher.

10 We resume at five minutes past 12.00.

11 [The witness stands down]

12 --- Recess taken at 11.49 a.m.

13 --- On resuming at 12.08 p.m.

14 JUDGE ORIE: Ms. Bibles, do you have any plans with the last

15 document on our screen, that is, the permission document?

16 MS. BIBLES: Yes, I tender 31131, Your Honour.

17 JUDGE ORIE: Madam Registrar, the number would be?

18 THE REGISTRAR: Document 31131 receives number P6697, Your

19 Honours.

20 JUDGE ORIE: And is admitted into evidence.

21 Ms. Bibles, you earlier showed to the witness and you didn't

22 tender three documents not signed by him but bearing his name. The

23 Chamber wonders where they come from.

24 MS. BIBLES: They were seized by OTP from Sarajevo aid, Your

25 Honour. Not as -- I'm just looking for a date. But they were all

Page 24792

1 seized, like I said, from Aid Sarajevo.

2 JUDGE ORIE: Yes. And were they part of a larger series with

3 sequential numbering --

4 MS. BIBLES: Yes.

5 JUDGE ORIE: -- of documents or? Or were they just more or less

6 isolated?

7 MS. BIBLES: Obviously these documents had this -- the code. If

8 I could get back to the Court, I'd like to ask for a little more

9 information, actually, about --

10 [The witness takes the stand]

11 MS. BIBLES: -- the date of the seizure as well as the

12 sequential.

13 JUDGE ORIE: Yes.

14 MS. BIBLES: Yes.

15 JUDGE ORIE: Because the suggestion was that numbers were just

16 invented for it now.

17 MS. BIBLES: Yes.

18 JUDGE ORIE: Of course, there may be ways of, to some extent,

19 verifying whether they fit into a series and whether they are then

20 duplicates --

21 MS. BIBLES: Yes.

22 JUDGE ORIE: -- same numbers but different documents. That's

23 something to be carefully considered, perhaps, in this respect.

24 Mr. Adzic, I hope you have had sufficient time to carefully

25 consider my instructions and advice, and Ms. Bibles will now continue her

Page 24793

1 cross-examination.

2 MS. BIBLES: Thank you.

3 Q. Sir, I'd next like to show you 65 ter 3722. Sir, this appears to

4 be a list for exchange of captured persons. And when it comes -- the

5 document comes up, I would ask you --

6 MS. BIBLES: We would go to last page, actually, first, and look

7 at the signature.

8 THE WITNESS: [Interpretation] There is no signature of mine on

9 this document.

10 MS. BIBLES:

11 Q. Right.

12 MS. BIBLES: And perhaps if we could start at the front page.

13 Q. Okay. Sir, the top of the document.

14 JUDGE FLUEGGE: This can't --

15 THE WITNESS: [Interpretation] This document [Overlapping

16 speakers].

17 JUDGE FLUEGGE: In B/C/S, it can't be the first page.

18 MS. BIBLES: No, this isn't the first. There we go.

19 Q. Now, sir, the top left-hand corner, although it's a little hard

20 to see in the B/C/S version, this document reads Serbian municipality of

21 Ilijas, number 100-03, date 25 June 1992. It's titled: "List for as

22 Exchange of Captured Persons from Ilijas municipality for Persons

23 Captured in Breza and Visoko Municipalities." Do you see that?

24 A. I do.

25 Q. Sir, this document, as we saw at the end, appears to have your

Page 24794

1 name at the end although not a signature. Do you recognise this

2 document?

3 A. I have never seen this document before. I recognise some of the

4 names and I do know what situation it refers to, but this document has

5 never been shown to me.

6 Q. Are you familiar with these names as individuals who were

7 captured in Ilijas municipality?

8 A. Some of the last names do ring a bell.

9 Q. Sir, this appears to be a five-page document, and apparently the

10 B/C/S document is out of order.

11 MS. BIBLES: Your Honour, we'll -- we'll fix that up.

12 JUDGE ORIE: The second page is the original of the front page.

13 MS. BIBLES: Yes.

14 JUDGE ORIE: Please proceed.

15 MS. BIBLES:

16 Q. Sir, this -- at the top of the right-hand top of the page is a

17 reference to transcript, do you see that?

18 JUDGE ORIE: Could you first seek an answer to your previous

19 question.

20 MS. BIBLES: I'm sorry. I'm sorry.

21 Q. Are you familiar with those last names as individuals who were

22 captured in Ilijas municipality, sir?

23 A. I know some of the last names as people who lived in some of the

24 villages in Ilijas municipality. I recognise some of them because I was

25 not in a position to know them all.

Page 24795

1 Q. Were these --

2 JUDGE ORIE: [Overlapping speakers].

3 MS. BIBLES: I'm sorry.

4 JUDGE ORIE: Yes. Witness, now I asked you to focus on the

5 question. Now there was a question put to you, whether you recognise

6 these names or perhaps some of them, as people that were captured. Did

7 you know of any persons being captured in Ilijas?

8 THE WITNESS: [Interpretation] I did not know them personally.

9 Not directly. But I do recognise some of the last names. They belonged

10 to some people who lived in Ilijas.

11 JUDGE ORIE: I'll stop you again. Were you aware of any persons

12 being captured in Ilijas?

13 THE WITNESS: [Interpretation] They were not arrested individually

14 or collectively. They were captured following combat operations as

15 civilians. Upon their insistence, they were exchanged or so they wished

16 to be, for people who --

17 JUDGE ORIE: Could you explain to me how civilians then can be

18 captured in combat?

19 THE WITNESS: [Interpretation] In case of an attack by a unit from

20 a Muslim village or a Muslim-held territory when there is combat, and if

21 those Muslim units are defeated, whatever civilians are left behind are

22 treated as captured persons by the army. They were captured in a combat

23 zone, but the treatment they were accorded was as civilians. However,

24 since they were in a combat zone, if there was still combat ongoing, they

25 needed to be removed.

Page 24796

1 JUDGE ORIE: Let me. So you captured civilians in combat zones.

2 That's what happened?

3 THE WITNESS: [Interpretation] It happened as a consequence of

4 combat operations.

5 JUDGE ORIE: Well, so it happened. Did you release them after

6 they were -- after combat was over?

7 THE WITNESS: [Interpretation] Yes.

8 JUDGE ORIE: Free to go back to their own place where they lived?

9 THE WITNESS: [Interpretation] They had the right to choose.

10 However, for the most part, they never asked to return. They asked to be

11 allowed to leave for Muslim territory; that is to say, to territory under

12 Muslim authority. We met their request and it was done that way.

13 JUDGE ORIE: Were they exchanged or were they just released in

14 accordance with their wish?

15 THE WITNESS: [Interpretation] Pursuant to their wish, they were

16 allowed to leave for Muslim-controlled territory. By the same token, in

17 agreement with the Muslim authorities of Breza and Visoko, the same was

18 done for the Serb population who wished to move to Serb controlled

19 territory.

20 JUDGE ORIE: Ms. Bibles, please proceed.

21 MS. BIBLES:

22 Q. Sir, was it your responsibility to provide for those captured

23 prisoners?

24 A. It was done by bodies of the Red Cross. Of course, it was also

25 my duty to assist the Red Cross, since I headed the municipal bodies, in

Page 24797

1 order to provide whatever assistance was needed to secure those civilians

2 and taken care of.

3 Q. When you refer to Red Cross in this time-period, June of 1992,

4 are you referring to the Serbian Red Cross?

5 A. Yes, precisely. The president of the Serbian Red Cross was

6 Veljko Mitar, who had been with the Red Cross for a number of years

7 previously and was very dedicated to performing his job.

8 Q. Sir, where were these captured people held in Ilijas?

9 A. We did not have any facilities. If any facilities were used,

10 they were mainly schools or halls with large premises so that food could

11 be provided for them. They were held as long as necessary, usually for

12 several days before the paperwork went through.

13 Q. Was the paper work co-ordinated for these exchanges through the

14 Republika Srpska Exchange Commission?

15 A. At that moment in time, no. It was co-ordinated locally with the

16 commission on the Muslim side as well as the Commission for Exchange of

17 Ilijas Municipality, which was actually part of the Red Cross.

18 MS. BIBLES: Your Honour, I'd tender 65 ter 3722.

19 JUDGE ORIE: Madam Registrar.

20 THE REGISTRAR: Document 3722 receives number P6697, Your

21 Honours.

22 JUDGE ORIE: P6697 is admitted.

23 JUDGE FLUEGGE: Could we please go to the page we saw earlier

24 with a stamp and a signature. That could be page 1 in B/C/S.

25 [Trial Chamber and registrar confer]

Page 24798

1 JUDGE FLUEGGE: Madam, I have a question for the witness in

2 relation to this page in B/C/S. It's a list of names beginning with

3 number 91 and -- oh, no, there are many different numberings. I see a

4 stamp and a signature there on the right-hand side.

5 Mr. Adzic, can you explain whose signature we see here?

6 THE WITNESS: [Interpretation] I don't consider it to be my

7 signature. The document is completely unknown to me. It looks very odd,

8 and to me it's more of a counterfeit than a proper document.

9 JUDGE FLUEGGE: Your name is written there. Do you have an

10 explanation for that?

11 THE WITNESS: [Interpretation] Yes, well, you can see my name

12 there. I can't explain how it came to be there. But the document is

13 very strange.

14 JUDGE FLUEGGE: In addition to your name we see, at least in the

15 English translation, "Crisis Staff President." That was your position.

16 THE WITNESS: [Interpretation] Yes, it was. But the document

17 itself, the original, well, you can see for yourself what it looks like.

18 There is nothing I can say about it. I assert that I have never seen

19 this document before.

20 JUDGE FLUEGGE: Thank you.

21 JUDGE MOLOTO: Madam Registrar, you gave us the last exhibit

22 number as P6697. What was the number of 4 -- 65 ter 31131.

23 THE REGISTRAR: Your Honour, I apologise. It should be number

24 P --

25 JUDGE MOLOTO: 98.

Page 24799

1 THE REGISTRAR: 98.

2 JUDGE MOLOTO: Thank you.

3 THE REGISTRAR: So document 3722 receives number P6698 not 97.

4 Thank you, Your Honours.

5 JUDGE ORIE: Yes, now being corrected. 6698 is admitted.

6 Please proceed.

7 MS. BIBLES:

8 Q. Sir, I'd like to shift topics and direct attention towards

9 paragraph 28 of your statement. In that paragraph you indicate that

10 Mladic visited "our front two or three times during the war." Can you

11 give us the dates and locations where General Mladic visited during the

12 war?

13 A. I can't recall the exact dates, and I'd rather not speculate

14 because it was a long time ago. The location was the brigade command.

15 General Mladic invited me to tour some other parts, such as the health

16 centre. He wanted to know the situation with the supplies and how the

17 people were going about their every day lives, whether they had

18 sufficient reserves. He simply wanted to have that kind of information

19 and I provided it to him.

20 Q. Do you have any idea where in the war -- was this early in the

21 war, the middle of the war, the end of the war, in terms of dates?

22 A. I think the first time was around October 1993. After that, it

23 was in 1994 once or twice. But it was already 1994.

24 Q. And I'd next like to shift directions to your tenure as minister

25 of interior in 1993. Do you agree the previous minister of the interior

Page 24800

1 was Mico Stanisic?

2 A. Yes.

3 Q. And you were appointed, I believe it's in your statement, in

4 January of 1993?

5 A. On the 20th of January.

6 Q. I'd like to ask just a couple of questions or go into a few areas

7 of some of your actions as the Republika Srpska minister of police. I'd

8 like to start by asking about Simo Drljaca. Wasn't he the chief of

9 police in Prijedor?

10 A. Yes.

11 MS. BIBLES: If we could have P3951, please.

12 Q. Sir, this is a 1 KK morale report. It's a 1st Krajina Corps

13 report on the state of combat morale dated 3 September 1992.

14 MS. BIBLES: And I'd ask that we go to page 4 in the English and

15 in the B/C/S.

16 Q. And, sir, while in the English we'll be looking at the top of the

17 page, you'll be looking at the bottom of the page in the B/C/S. Here in

18 the document it states that Prijedor police -- it states that the

19 Prijedor police under Simo Drljaca "committed a massacre in the Skender

20 Vakuf area of over 150 men who wanted to leave the ARK." Do you see

21 that?

22 A. I'm trying to -- yes, I see it. Towards the bottom. Let me read

23 it first. Yes, I see it.

24 Q. Sir, the Chamber has received evidence that this massacre was

25 known to members of the Bosnian Serb leadership and to the Main Staff of

Page 24801

1 the VRS in August of 1992.

2 MS. BIBLES: And, Your Honours, I could refer to Exhibits D58 and

3 P4239.

4 Q. As minister of the interior, you knew about this massacre, didn't

5 you? Though it preceded your time in the ministry, you were aware of

6 this as minister?

7 A. I wasn't aware of it at all, and no one provided me with any kind

8 of information in the ministry regarding it.

9 Q. Sir, I'd like to now go to 65 ter 31103. And, sir, this

10 appointed Simo Drljaca as a member of the commission for investigating

11 genocide. And, sir, we see this is type-signed by you on May 15th 1993

12 appointing Mr. Drljaca as a member of the commission for investigating

13 crimes of genocide against the Serbian people. Now, it describes him as

14 head of the information office in the cabinet of the minister of the

15 interior. That's you, correct?

16 A. Simo Drljaca was appointed advisor on proposal from the CSB in

17 Banja Luka. He was not proposed to act as commission president. I am

18 not aware of it and I also see that the signature on the document is

19 illegible.

20 Q. Sir, you would agree as minister of the interior this is an area

21 under your control, isn't it? Or your authority.

22 A. In the sense of the functioning of the ministry, yes. But at

23 that time I had only arrived and started acquainting myself with the

24 situation. At that moment, I had no information related to any events

25 wherever in our territory save for the territory of Ilijas municipality.

Page 24802

1 I only had information about that.

2 Q. Sir, when you were appointed minister of the interior, you're

3 saying your only base of information was your personal observations from

4 Ilijas?

5 A. Anything that happened before the 20th of January is limited to

6 the information I received in Ilijas. I was there all the time. There

7 was no possibility for me to communicate, and it was not within my

8 competence to be interested in any other part of Republika Srpska. When

9 I assumed my position as minister of the interior, I only began

10 acquainting myself with the situation in the rest of Republika Srpska.

11 Q. Weren't you also a member of the SDS Main Board starting in 1991

12 which had much broader authority than Ilijas?

13 A. The Main Board was a political body. By a decision of the SDS

14 president, Mr. Karadzic, in April the work of the SDS in political terms

15 was frozen. In the political sense, it continued working only in 1993.

16 It was because of the war. So that there would be no political rifts and

17 arguments. The Main Board did not even meet, let alone discuss any

18 issues during that period.

19 JUDGE FLUEGGE: Mr. Adzic, we are talking about 1993. The

20 document on the screen before you is dated 15 May 1993. At that point in

21 time, you were almost four months minister of the interior. It was not

22 just the situation when you acquainted yourself with the situation. It

23 was four months later. Could you consider your answer if that was

24 correct.

25 THE WITNESS: [Interpretation] My answer stands. My position in

Page 24803

1 the ministry and the situation that prevailed in the ministry was such

2 that simply didn't know what I can do, and I could not receive

3 information that was not forwarded to me through lower levels where some

4 of the decisions were made. I was simply unable to receive such

5 information. It rested with the CSBs.

6 JUDGE FLUEGGE: Mr. Adzic, Ms. Bibles asked you - and that was

7 the beginning of the line of questioning - if Mr. Simo Drljaca was head

8 of the information office in your cabinet as minister of the MUP. Can

9 you please now answer the question.

10 THE WITNESS: [Interpretation] He was appointed, and I believe

11 that the decision was issued in the course of May, but he actually never

12 assumed the position. He stayed in Prijedor.

13 JUDGE FLUEGGE: But what position are you talking, member of the

14 commission for investigating crimes of genocide or head of the

15 information office in the cabinet of the minister?

16 THE WITNESS: [Interpretation] His official position was in the

17 information service. As for all the other activities of his, I'm not

18 familiar with any of them.

19 JUDGE FLUEGGE: Mr. Adzic, that exactly was the question of

20 Ms. Bibles at the beginning of this line of questioning. It could have

21 been very easy to answer that question just to say "yes."

22 MS. BIBLES: Your Honour, at this time I tender 31103.

23 JUDGE ORIE: Madam Registrar.

24 THE REGISTRAR: Document 31103 receives number P6699, Your

25 Honours.

Page 24804

1 JUDGE ORIE: And is admitted into evidence.

2 Ms. Bibles, I have, in relation to this, you showed the witness

3 documents, but the first names of Mr. Drljaca are not the same in the one

4 we see now, the Simo, and in the previous one, which was a different

5 first name. Stevo. Not Simo. Could you please have a look at it and

6 perhaps later explain why you nevertheless, as you suggested, them to be

7 the same persons, that's one.

8 Second, in the document, the list which was not in the right

9 order, we see that there are duplicates in the numbers. There is one

10 part which apparently has been torn apart and perhaps put together again.

11 But that seems at least not to be the same list. Therefore, the Chamber

12 would seriously be informed about what makes you present to a witness

13 something that looks as one list but where under the same numbers we find

14 different names and to further clarify that issue.

15 MS. BIBLES: Yes, Your Honour. Absolutely. I'll be right --

16 I'll chase that information down and report it back to you.

17 JUDGE ORIE: Yes, we'd like to. And if that has -- well, the

18 witness said he hadn't seen that list anyhow, so therefore he may not

19 have been confused by it. But let's keep in mind that if you present

20 something in this way that witnesses may be confused by it.

21 Please proceed.

22 MS. BIBLES:

23 Q. Sir, your tenure as minister of the RS MUP was somewhere between

24 six and nine months. Would you agree with that?

25 A. From the 20th of January up until the 12th of July 1993. Yes,

Page 24805

1 six months, I would say.

2 Q. Isn't it true that your resignation was not accepted until

3 September of 1993?

4 A. It is true. My resignation was accepted at the session presided

5 by President Karadzic. However, the Assembly of Republika Srpska

6 subsequently held its session and ratified that decision and appointed a

7 deputy minister. I myself resigned on the 12th of June. I'm not sure

8 about the date, but it was in early July and as of that date I stopped

9 holding that office.

10 JUDGE ORIE: May I take it that when you said the 12th of June,

11 that you misspoke and that you wanted to refer to the 12th of July?

12 THE WITNESS: [Interpretation] July. July. It was in July.

13 MS. BIBLES: Perhaps it would be helpful to look at 65 ter 18899.

14 Q. Sir, this is the official decision about the dismissal -- your

15 dismissal from the post.

16 All right. Sir, does this refresh your recollection, that your

17 resignation was accepted by President Karadzic on the 17th of September,

18 1993?

19 A. On the 17th of September, he appointed Tomo Kovac as the acting

20 minister. I submitted my written resignation at the beginning of July,

21 and then at a session attended by President Karadzic and other members of

22 the presidency my resignation was accepted. And now we are talking --

23 JUDGE ORIE: Witness, the simple question was: Was your

24 resignation accepted by President Karadzic on the 17th of September? The

25 answer, apparently, is yes.

Page 24806

1 THE WITNESS: [Interpretation] President Karadzic accepted my

2 resignation on the 12th of July at that session. And this is just a

3 written decision stating the fact that as of the 12th of July, I had no

4 longer acted as the minister of police.

5 JUDGE MOLOTO: But, Witness, this decision doesn't state that you

6 are dismissed as of the 12th of July. Where do you see it on this

7 document that your resignation was --

8 THE WITNESS: [Interpretation] I can't see it either.

9 JUDGE MOLOTO: [Overlapping speakers].

10 THE WITNESS: [Interpretation] However, I am referring to --

11 MS. BIBLES: Your Honour, I would tender 65 ter 18899.

12 JUDGE ORIE: Madam Registrar.

13 THE REGISTRAR: Document 18899 receives number P6700, Your

14 Honours.

15 JUDGE ORIE: And is admitted into evidence.

16 Witness, in all fairness, I have to tell you that when we asked

17 whether he accepted your resignation, when no specific reference to at

18 that time in that question to the document was made, that what you wanted

19 to tell us apparently was that he orally ordered -- a decision was made

20 on the 12th of July which was then put on paper and signed on the 17th of

21 September. That short explanation would have fitted well into the

22 question that was put to you, although you confused us a bit by the way

23 in which you started your answer.

24 Please proceed.

25 JUDGE FLUEGGE: May I put an additional question.

Page 24807

1 Who carried out the function of the Ministry of the Police

2 between the 12th of July and the 17th of September 1993?

3 THE WITNESS: [Interpretation] Mr. Tomislav Kovac, who was the

4 chief of public security when I was minister, and that was decided on the

5 17th of July. And that decision was made by President Karadzic himself.

6 JUDGE FLUEGGE: That was decided on the 17th of July, five days

7 after your resignation?

8 THE WITNESS: [Interpretation] I did not see that decision issued

9 on the 17th of July. It is possible. After my written resignation that

10 I handed in at that meeting, I no longer received any information about

11 the work of the Ministry of the Interior, nor did I receive any document

12 from them.

13 JUDGE FLUEGGE: Thank you.

14 MS. BIBLES:

15 Q. Sir, shifting to -- back to your statement. In paragraph 14, you

16 described that rumours and estimates put Serb casualties at 6.000 in

17 Sarajevo during the war. In this estimate, did you mean to include both

18 civilians and soldiers?

19 A. In Sarajevo, according to the information we heard and that the

20 witnesses conveyed to us, the first casualties were members of the

21 Serbian Democratic Party who were besieged in Sarajevo. In Sarajevo

22 itself, there were no Serbian soldiers.

23 Q. Sir, in your statement you proffer a number of casualties in

24 Sarajevo. The next question would be, when you say Sarajevo, do you mean

25 the city centre, the urban municipalities that make up the core of

Page 24808

1 Sarajevo, or some other area?

2 A. I mean the part of Sarajevo which was under the control of Muslim

3 authorities.

4 Q. Sir, do you know what the sources, specific sources of

5 information are for these estimates?

6 A. They were refugees from Sarajevo and one of the sources are the

7 Sarajevo media. In 1996, they wrote about those figures.

8 Q. So you don't -- you don't know whether these numbers, then, maybe

9 have come from the Sarajevo household survey in 1994 or the Bosnian Book

10 of the Dead or other sources that list casualties?

11 A. I read that in the Bosnian media such as Slobodna Bosna and Avaz.

12 To put it simply, people talked.

13 Q. Do you know whether this estimate includes Serbs who died

14 violently and Serbs who died of natural causes or both?

15 A. I suppose that this refers to the Serbs who died of violent

16 causes.

17 Q. Sir, the OTP has employed demographers over the years to analyse

18 various sources to determine as accurate of information as possible in an

19 objective manner. For instance, an expert demographer employed

20 statistical analysis and concluded that a minimum number of several

21 hundred Serbs had indeed been violently killed in Sarajevo between April

22 1992 and November of 1995. Would you agree that this would be a more

23 reliable source for these casualties than your estimates that you put in

24 your report?

25 MR. LUKIC: [Interpretation] Objection.

Page 24809

1 JUDGE ORIE: Based on?

2 MR. LUKIC: Those analyses should be shown to the witness. How

3 can we analyse or comment something on which he has never seen or read or

4 analysed?

5 JUDGE ORIE: Of course, the witness has not given any of the

6 estimates of any of the sources, he's said to that. But if you -- the

7 simple question is whether the witness would, and then perhaps we could

8 rephrase that in general terms, whether a careful demographic statistical

9 analysis, whether that would not be a better basis for estimates of

10 numbers of people who have died. That's --

11 MR. LUKIC: One more thing, Your Honours.

12 JUDGE ORIE: Yes.

13 MR. LUKIC: Have we seen, has the Defence at all seen these

14 estimates?

15 JUDGE ORIE: Ms. Bibles.

16 MS. BIBLES: Yes. Yes, Your Honour, they have been disclosed and

17 in fact, if you look at 65 ter 11854 -- actually, 65 ter 11854 through

18 11859 would be the Sarajevo demographic reports.

19 JUDGE ORIE: Yes. Now, a totally different matter. Whether the

20 witness would consider rumours and estimates he has seen in newspapers in

21 1996 a better source than a thorough statistical demographic analysis may

22 not be --

23 MR. LUKIC: Done by the Prosecution. It is not experts who

24 are --

25 JUDGE ORIE: How do you know that? You said you didn't even

Page 24810

1 know.

2 MR. LUKIC: I don't know. But Ms. Bibles said their --

3 JUDGE ORIE: No.

4 MR. LUKIC: Their employed so-called experts.

5 JUDGE ORIE: Yes. And you say that if you're employed, for

6 example, by the Defence --

7 MR. LUKIC: Claiming that only a couple of hundred Serbs were

8 killed in Sarajevo is an insult and not only not true.

9 JUDGE ORIE: Okay.

10 MR. LUKIC: That's Muslim propaganda.

11 JUDGE ORIE: Well, whether it's propaganda or not. We will --

12 you take it very seriously. We are talking about -- are you talking

13 about civilians or -- and Sarajevo, within, and that's what the witness

14 said, we are talking about Serbs who had died from violent causes in the

15 territory which was controlled by the BiH, and the witness said it was

16 civilians. Okay.

17 If you say that this is an insult, then perhaps the parties

18 should exchange views on that and see whether that's true and otherwise

19 make submissions.

20 Because, Mr. Lukic, if this is a clear distortion of reality in

21 serious demographic reports, that would shed a light on the way in which

22 the Prosecution approaches this case and should be taken very seriously.

23 At the same time, whether the witness, who bases his number on

24 rumours and what he read in the media, whether the witness considered

25 this to be better than demographic reports, he doesn't know, seems not to

Page 24811

1 be of vital importance for the Chamber to know.

2 But, Ms. Bibles, I think there is a matter --

3 MS. BIBLES: Yes.

4 JUDGE ORIE: -- to be discussed and to be taken seriously.

5 MS. BIBLES: Very much so, Your Honour. And I would point out my

6 question. As the Court is aware, demographers work in minimums and

7 maximums and look at statistical evaluations. And that is the point I

8 was trying to make is the difference between what this witness proffered

9 to the Trial Chamber. And I a hundred per cent agree with the Trial

10 Chamber, that this is an area that the Defence and Prosecution need to

11 sit down and have a -- have a serious conversation about.

12 JUDGE ORIE: Yes. A serious conversation is needed.

13 MS. BIBLES: Yes.

14 JUDGE ORIE: And the Chamber would like to be informed about any

15 continuing -- continuing dispute about this or whether the parties would

16 come closer to each other.

17 Please proceed, Ms. Bibles.

18 MS. BIBLES: Thank you.

19 Q. And, sir, finally I want to address your perspective given in

20 your statement that you seem to portray the blockade as being a

21 Muslim-driven means of locking people out of the city. I'd like to have

22 you look at Exhibit 31107. This is a media source in which you were

23 quoted, and I'd like you to look at the quote, please.

24 MS. BIBLES: In the English, we're looking at the second

25 paragraph from the bottom.

Page 24812

1 JUDGE FLUEGGE: And in B/C/S?

2 MS. BIBLES: In B/C/S, that's -- I'm trying to find. It's the

3 top, I believe, of that second column. Thank you.

4 JUDGE ORIE: And apparently not the whole of the --

5 MS. BIBLES: Yes, of the quote.

6 JUDGE ORIE: Of the article is translated. I see as a date the

7 14th of -- it seems, is that December 1993? Perhaps the witness could

8 assist us.

9 MS. BIBLES: Yes.

10 JUDGE ORIE: Top left-hand corner, just below the word

11 "klas" [phoen] there is a date. Could you read that aloud for us?

12 THE WITNESS: [Interpretation] Tuesday, the 14th of December,

13 1993.

14 JUDGE ORIE: Yes.

15 Please proceed, Ms. Bibles.

16 MS. BIBLES: Fine. Thank you.

17 Q. Sir, first have you had an opportunity to read your quote?

18 A. Yes, I read it partly, and I can say that this was not a joint

19 session of the municipality of Ilijas and Vogosca. This was a session of

20 the assembly of Serbian Sarajevo, the city assembly of Serbian Sarajevo.

21 Q. Sir, let's try this a different way. I'm going to read the

22 English translation of at least part of your quote and ask you if it

23 accurately depicts what you said.

24 "'I am convinced that the war will end when we take Sarajevo.

25 Unless they are defeated militarily, there will be no life for us here,'

Page 24813

1 emphasized President Adzic, adding that the Serbian people was aware that

2 'if they cordoned off Sarajevo the Serbs would get a state of their

3 own.'"

4 Sir, is that quote from you accurate?

5 A. Yes.

6 Q. Sir, isn't it true that it was Serb forces who closed Sarajevo?

7 A. It is not true. First, the Muslim forces closed Sarajevo from

8 the inside, and then to defend the Serbian areas around Sarajevo we

9 established our own defence line.

10 MS. BIBLES: Your Honours, I have no further questions for this

11 witness.

12 JUDGE ORIE: Thank you, Ms. Bibles.

13 Are you tendering the document or it has been read into the -- we

14 have the date, we have the literal quote, and the answer of the witness.

15 MS. BIBLES: Yes, Your Honour.

16 JUDGE ORIE: Mr. Lukic, any need to re-examine the witness?

17 MR. LUKIC: Your Honour, I have probably 10 to 15 minutes. Maybe

18 20.

19 JUDGE ORIE: Then perhaps we could do that -- 10 minutes would

20 fit into the next session, more or less. If you'd prefer to take the

21 break first, then the Chamber would not oppose that.

22 [Trial Chamber confers]

23 JUDGE ORIE: My math is very bad today, Mr. Lukic. Until the

24 break, we have 15 minutes left, so please proceed.

25 MR. LUKIC: Thank you.

Page 24814

1 If we can see P --

2 [Trial Chamber and registrar confer]

3 JUDGE ORIE: We'll take the break first because not my math is

4 only bad but that of my colleagues is not accurate either. So the

5 Chamber is in a bad mathematical state. I deplore that.

6 Witness, we'll continue in 20 minutes from now. You may follow

7 the usher.

8 [The witness stands down]

9 THE ACCUSED: [Interpretation] [Microphone not activated]

10 JUDGE ORIE: No loud speaking, not even about mathematics.

11 We take a break and will resume at 20 minutes past 1.00.

12 --- Recess taken at 1.02 p.m.

13 --- On resuming at 1.23 p.m.

14 JUDGE ORIE: While we are waiting for the witness to be escorted

15 into the courtroom.

16 Mr. Lukic, if there is any way in re-examination you could pay

17 attention to or otherwise inform the Chamber about the assembly decision

18 on which basis in December 1991 the Crisis Staff in Ilijas was

19 established, which was not a secret matter but an open matter. I don't

20 know whether you have any clue as to what decision the witness was

21 referring to.

22 One of my problems was that we hardly find anything of the kind

23 in his statement. There is even more in your summary than there is in

24 the statement, which is, by the way, not the way -- the 65 ter summary,

25 that -- I think there is even more in it than in the statement itself

Page 24815

1 which, of course, is not ...

2 MR. LUKIC: When I read the statement, Your Honours, I also

3 noticed that there is no -- nothing clear about the Crisis Staff. That's

4 why I tried to clarify it --

5 JUDGE ORIE: Yes.

6 MR. LUKIC: -- with the witness.

7 JUDGE ORIE: And if the basis for the establishment of the

8 Crisis Staff which, I think the witness said, was a decision taken by the

9 assembly and it was in December 1991, then, of course, other things have

10 happened in December 1991 as well which are also related, to some extent,

11 to further developments. At least that's evidence the Chamber has

12 received.

13 Then I would like to clearly be able to make a distinction

14 between the two.

15 MR. LUKIC: Do you want me to clarify it with the witness or do

16 you want us to provide the document.

17 JUDGE ORIE: Well, if you have the document. But perhaps you put

18 it to the witness and say, "Is this the document you're referring to the

19 about the decision?"

20 MR. LUKIC: I don't have it with me now.

21 JUDGE ORIE: But you have it?

22 MR. LUKIC: I don't know. We have to check.

23 [The witness takes the stand]

24 JUDGE ORIE: But if you lead this evidence, then I take it that

25 you have some thoughts about what the witness was referring to rather

Page 24816

1 than --

2 MR. LUKIC: I tried to find it. I was not able to find it when I

3 was preparing the witness.

4 JUDGE ORIE: Okay. Then let's see then to what extent we can

5 explore it with the witness.

6 Please proceed.

7 MR. LUKIC: Thank you.

8 JUDGE ORIE: Mr. Adzic, you'll now be re-examined by Mr. Lukic.

9 MR. LUKIC: But this will then take a bit more than 15 minutes.

10 JUDGE ORIE: Well, depending on what answers we get.

11 Re-examination by Mr. Lukic:

12 Q. [Interpretation] Good day to you, Mr. Adzic, one more time. As

13 you were entering, we were discussing something that you probably were

14 not able to hear. The Chamber is interested in whether you could be more

15 accurate in terms of what document was used to establish your

16 Crisis Staff. As you said, it was in December 1991.

17 A. Based on a dispatch signed by the RS president, Mr. Karadzic. I

18 apologise. It was based on a dispatch that I received as the president

19 of the municipality from President Karadzic.

20 Q. Do you happen to have that dispatch in your possession?

21 A. No. It remained in the archives of the municipality.

22 Q. So you presume that we would be able to find it?

23 A. Provided the archives are still in existence.

24 Q. Can you approximate in terms of date? Was it at the beginning or

25 end of December?

Page 24817

1 A. It may have been around the 20th or the 21st of December.

2 Q. Thank you. That ends that particular topic.

3 JUDGE ORIE: Mr. Lukic, perhaps if you would not mind, I would

4 follow-up on the answers.

5 There is evidence before this Chamber about a document dated the

6 19th of December, which was distributed to the various municipalities, at

7 least the Serb leadership in those municipalities. A document which was

8 not signed by Mr. Karadzic but a document which set out, as it's often

9 referred to, Variant A and Variant B; that is, how to prepare in the near

10 future your Serb institutions within municipalities. Variant A and B

11 distinguishing between municipalities which were of a Serb majority, as

12 far as population is concerned, and a Serb minority and then in two

13 different stages. And earlier a first stage, and then a second stage.

14 That is what this Chamber is aware of and is familiar with.

15 Now, if I have described this document in the way I did, is that

16 the type of document you are referring to or is it something really

17 different?

18 THE WITNESS: [Interpretation] I think it would be document A.

19 JUDGE ORIE: Well, in the same document Variant A and Variant B

20 are described, the one to be adopted in - and forgive me if it was the

21 Serb majority or minority municipalities - but the one Variant A

22 applicable in a -- some of the municipalities, either majority or

23 minority, I don't remember; and the other one to be applied in --

24 THE WITNESS: [Interpretation] That would be A.

25 JUDGE ORIE: Yes. Are you referring to a document when you said,

Page 24818

1 "We established a Crisis Staff upon the instruction of the assembly ...,"

2 signed by Mr. Karadzic? Are you referring to a document in which

3 Variants A and B were described, where you said A would apply for Ilijas?

4 THE WITNESS: [Interpretation] I cannot recall exactly. I can

5 only try to recall the instructions we received. Since the Serbs were in

6 the majority in our municipality, I suppose that it would entail document

7 A as you interpret it.

8 JUDGE ORIE: Well, I told you that I was talking about a document

9 in which both the A variant and the B variant were described. One

10 document, Variant A, to do this and this and this in two different

11 stages; Variant B, to do this and this and this in two stages. Is that

12 the type of document you are referring to? Because the -- there is no

13 other document known to either the Defence at this moment nor to the

14 Prosecution; whereas, the parties and the Bench are quite familiar with

15 the document as I described it.

16 THE WITNESS: [Interpretation] I think it could be the document,

17 and Variant A would be applicable to our situation.

18 JUDGE ORIE: Now, that document, how did you receive that?

19 THE WITNESS: [Interpretation] I think it was by telegram, by

20 telex via electronic communication.

21 JUDGE ORIE: Now the document I described and with which many in

22 this courtroom are very familiar was not a public document. To the

23 contrary, it was strictly confidential. Therefore, I'm asking you again

24 whether the instructions you received really were public and adopted in

25 an assembly session, I think you said the Assembly of the Republika

Page 24819

1 Srpska, or whether it could have been a document which was confidential

2 rather than public and not adopted in a -- in an assembly session?

3 THE WITNESS: [Interpretation] The document arrived by telex. It

4 was signed, although I cannot say with any certainty whether it was

5 signed by President Karadzic or the speaker of the assembly. It

6 contained instructions on how to establish the Crisis Staff. As for any

7 further details or the template that was used, that is something I cannot

8 recall. It could be that it was signed. I just remember that it arrived

9 by telex. It was a kind of dispatch. And I followed the instructions

10 received.

11 JUDGE ORIE: Yes. I leave it to that and I invite the parties to

12 search for whatever other document around the same date which would be of

13 guidance in establishing Crisis Staffs publicly adopted in any assembly

14 session.

15 Mr. Lukic.

16 MR. LUKIC: Thank you, Your Honour. [Interpretation] I have to

17 stress the following: When I was told that it was a dispatch, I tried to

18 find a short document containing several lines. I wasn't paying

19 attention to any variants A or B. But I will continue with my questions.

20 First, I would like to see P3797.

21 Q. Mr. Adzic, once we have the document on the screen, you will see

22 that it comes from the Sarajevo Romanija Corps dated the 27th of May,

23 1992. In item 2, which is in the last third of your page, you were asked

24 about the establishment of the MAD. You said that at the time, it had

25 not been established. I wanted to draw your attention to the following.

Page 24820

1 We have a percentage stated --

2 JUDGE ORIE: Mr. Lukic, we have -- number 2 is only on the next

3 page.

4 MR. LUKIC: Yes, it's on the English version in the next page.

5 Sorry, I apologise.

6 JUDGE ORIE: We are there now.

7 MR. LUKIC: [Interpretation].

8 Q. For example, the brigade armoured levels were only up to 30

9 per cent of what was necessary and only 20 per cent in terms of

10 60-millimetre mortars and so on and so forth. Were you familiar with

11 that at all in terms of the number of assets the brigade had at the

12 moment of establishment?

13 A. I was familiar because I had been informed about it by the

14 brigade command. I knew that the brigade was poorly equipped in that

15 regard. Of course, I did have that information.

16 Q. Thank you.

17 MR. LUKIC: [Interpretation] Can we next have 3714, 65 ter. I

18 don't know what is the P number.

19 THE REGISTRAR: Your Honour, this is document P6695, MFI'd.

20 JUDGE ORIE: And the document -- yes, we have it.

21 Could I ask the witness. You say there was only a certain

22 percentage of the mortars which you would need, and I'm still talking

23 about the previous document, could you tell us how many 60-millimetre

24 mortars the Ilijas Brigade had?

25 THE WITNESS: [Interpretation] I can't say. I really don't know.

Page 24821

1 That information was shared with me at a session, but only the command

2 and the people who were in command had that information available.

3 JUDGE ORIE: So whether they were poorly equipped, yes or no, you

4 have no numbers for that?

5 THE WITNESS: [Interpretation] Of course I did not go into

6 analysing that. I only relied on the information presented to me by the

7 command. They presented the facts and of course I trusted my command.

8 JUDGE ORIE: They presented their conclusions and not the facts

9 because you didn't know how many mortars of 60-millimetres they had,

10 isn't it?

11 THE WITNESS: [Interpretation] It was summary data based on

12 individual units analyses. The units were not considered individually at

13 such kind of meetings.

14 JUDGE ORIE: Please proceed, Mr. Lukic.

15 MR. LUKIC: Thank you.

16 Q. [Interpretation] I showed you the document on the screen to tell

17 you what I'm going to be talking about. This is about you asking for

18 three to five tanks. And then after that, we saw P353. I can't see what

19 page was used. I have not made a note of that. Just a moment please,

20 bear with me.

21 JUDGE ORIE: Perhaps Ms. Bibles could assist.

22 JUDGE FLUEGGE: It should be page 155 in English and 154 in the

23 original.

24 MR. LUKIC: If we can have the pages Judge Fluegge just

25 mentioned, please.

Page 24822

1 Q. [Interpretation] It says here and this is a document which says

2 that on Saturday the 13th of June - i.e., a day after the letter by which

3 you addressed President Karadzic - it says that a meeting was held with

4 the presidency. On the 13th of June, did you attend a meeting with

5 General Mladic?

6 A. No, not on that day.

7 Q. You don't know who presented this?

8 A. I suppose that it was Mr. Karadzic.

9 Q. But you don't know, do you? You just assume.

10 A. I don't know.

11 Q. Thank you.

12 MR. LUKIC: [Interpretation] And now just briefly, P6697.

13 Q. We have discussed this document at great length already. Just

14 for the record, it should be noted that the abbreviation SIBr at the top

15 of the document was very often interpreted as the Sarajevo-Ilijas

16 Brigade; however, we can see in the stamp that it was the 1st Serbian

17 Ilijas Brigade. So I would like this to be corrected everywhere in the

18 transcript.

19 JUDGE ORIE: One second. Let me just.

20 MR. LUKIC: On the stamp, you can see in the inner circle.

21 JUDGE ORIE: Yes. Now we can't change the transcript. If the

22 words are spoken, then they should be transcribed as spoken.

23 MR. LUKIC: Yeah, but --

24 JUDGE ORIE: The --

25 MR. LUKIC: I just wanted it to be noted.

Page 24823

1 JUDGE ORIE: It should be noted. Then you said in the stamp we

2 could that -- could we enlarge the stamp in detail? The original. What

3 we see is the Srpska Republika Bosnia Herzegovina, that's the outline.

4 Then we have the "Srpska Obstina" --

5 [Trial Chamber confers]

6 JUDGE ORIE: Yes. I think the middle circle is the

7 "Srpska Obstina Ilijas." Yes.

8 Now, Witness, could you read the most inner circle of this stamp.

9 THE WITNESS: [Interpretation] Me?

10 JUDGE ORIE: Yes.

11 THE WITNESS: [Interpretation] The 1st Serbian Ilijas Brigade.

12 That was a stamp of the brigade command.

13 JUDGE ORIE: Let me just have a look now, Mr. Lukic. Yes. That

14 is -- now could we ...

15 [Trial Chamber confers]

16 JUDGE ORIE: Witness, could you have a look at the original at

17 the left top corner. Could we move to that. There you see the command

18 of what exactly? Could you tell us what it stands for?

19 THE WITNESS: [Interpretation] The command of the 1st Serbian

20 Ilijas Brigade in Ilijas.

21 JUDGE ORIE: Yes. So I -- Ms. Bibles, I'm looking at you as

22 well. Would you agree that the reference is -- the abbreviation,

23 although from the letters you could make anything out of the S you want

24 to but that it's the most logical explanation that it would be the 1st

25 Serb Ilijas Brigade?

Page 24824

1 MS. BIBLES: I think that's obviously out of my area of

2 expertise, but, yes, I agree with the conclusion, Your Honour.

3 JUDGE ORIE: So we have corrected that on the record.

4 Please proceed, Mr. Lukic.

5 MR. LUKIC: Thank you.

6 Q. [Interpretation] Mr. Adzic, it was my impression that you wanted

7 to add something to your explanation of this document. Can you remember

8 now what it was? What was it that you wanted to add to your explanation?

9 A. Are you talking --

10 Q. When we were discussing this document, you wanted to say

11 something but there was no question to prompt you to do that. Do you

12 know what you wanted to say?

13 A. I wanted to say that when the Ilijas Brigade was set up, the

14 brigade was given its stamp. And I, as the president of the

15 municipality, had my own stamp. So this is a document that was drafted

16 in situations which were not within the purview of the brigade command.

17 I can explain.

18 There was a pressure of people and the Red Cross not to allow

19 exit to some Muslims whose families remained in Visoko and elsewhere, and

20 they made their exit conditional. I opposed that and I said that no

21 conditions should be set. And since the command could not resolve those

22 issues and at the check-points only the decisions of the command was

23 valid, the command issued this document and then I used my authority to

24 act and to help them go through. It would take a lot of time for me to

25 explain how much pressure was present at the time. I didn't want to. I

Page 24825

1 could not prevent people from going where they wanted to go, and only in

2 exceptional cases I had to react in this way.

3 Q. And now -- and let's look at another document.

4 JUDGE ORIE: Mr. Lukic, if you would not mind, I would have some

5 follow-up questions in this respect as well.

6 MR. LUKIC: Yeah.

7 JUDGE ORIE: Who gave instructions to the check-points, who to

8 let go through and where there were doubts as whether people should be

9 stopped?

10 THE WITNESS: [Interpretation] The check-points were manned by

11 army members sometimes working together with the police, and only people

12 with valid passes were let through. That was a guarantee that that

13 movement had been approved and that it was controlled.

14 JUDGE ORIE: Now, who gave those instructions? You told us what

15 happened, but who had instructed them to only allow people through with

16 valid passes?

17 THE WITNESS: [Interpretation] Civilian passes were issued by the

18 Red Cross and that was not in dispute. You saw that there were

19 agreements between the Muslim side and the Red Cross. I said there was

20 never a problem with that.

21 JUDGE ORIE: You're not answering my question.

22 Who told the check-points only to allow civilians through with

23 valid Red Cross documents?

24 THE WITNESS: [Interpretation] It was a decision of the

25 appropriate security organs, and it was intended for the control of

Page 24826

1 everybody's movement. So nobody could move without a valid pass within a

2 certain area.

3 JUDGE ORIE: Who were the appropriate security organs you're

4 referring to?

5 THE WITNESS: [Interpretation] At the separation line, it was the

6 security organs of the brigade commander and the security organs of the

7 police.

8 JUDGE ORIE: And as we have seen in many documents, you were

9 presented as the command of the brigade, as even the commander of the

10 brigade. So was it under your responsibility that these instructions

11 were given?

12 THE WITNESS: [Interpretation] No, this is an exceptional case. I

13 already explained that to Mr. Lukic. It was beyond the scope of the

14 brigade command. They couldn't do with civilian affairs. The situation

15 was difficult and I used my authority to help those people who wanted to

16 leave. My authority was of such a nature that the command could issue a

17 document, I then cosigned or signed and confirmed the validity of that

18 document with my stamp and signature, and then those people would no

19 longer have any problems with leaving the territory.

20 JUDGE ORIE: Why didn't you send an order as commander of the 1st

21 Serbian Ilijas Brigade to any check-points, that they should not stop

22 elderly ladies or very young children of 7 years old at check-points?

23 Why didn't you do that instead of upkeeping a system in which apparently

24 you had instructed that people should be accompanied by Red Cross

25 documents even if they are 59-year-old ladies or 7-year-old children?

Page 24827

1 Why didn't you take such measures rather than to use your authority to

2 lead these people through?

3 THE WITNESS: [Interpretation] I could undertake measures only

4 based on the situation as it was. The checkpoints were in the combat

5 zones on the separation lines. Only in exceptional cases when pressure

6 was put even on me to prohibit exit to some Muslims whose families had

7 remained living in Visoko and Breza did they ask me to use my authority

8 and request for them to be exchanged. And when some people, like, for

9 example, these four citizens came to me, I used my authority. Pressure

10 was put even on the Red Cross to forbid them to leave the territory, and

11 in those exceptional situations, I used my authority to help such people.

12 But those were original exceptional cases.

13 JUDGE ORIE: What was exceptional in the circumstances here with

14 this family?

15 THE WITNESS: [Interpretation] The exceptional circumstance was as

16 follows: A lot of Serbs who had fled from Visoko and Breza knew that a

17 lot of the families were blocked in those municipalities and they were

18 not allowed to cross over to Ilijas. And then the members of those

19 families put pressure on me and on the Red Cross, on the president of the

20 Red Cross. At one point, the president of the Red Cross even wanted to

21 resign as a result of these pressures. I asked him, telling him that he

22 was the only capable person to deal with humanitarian issues, regardless

23 of the pressures and the burden. I asked him to try and stick it out.

24 And if situations were difficult, I told him to come and ask me for

25 assistance. So in such situations, he indeed came to me and asked me to

Page 24828

1 use my authority, which is what I did.

2 JUDGE ORIE: If I carefully listen to your answer, you're

3 referring to families, Serb families, that were blocked in Visoko and

4 Breza. Now, do I have to understand this that pressure was put upon you

5 that Muslims could only leave if they - these families - would be allowed

6 to come to Ilijas?

7 THE WITNESS: [Interpretation] Yes. Accordingly to the principle

8 of reciprocity, Serbs were supposed to leave Breza and Visoko, and then

9 we in our turn should let these people go. That was the pressure that

10 was put on me. I couldn't do that. I didn't think that there should be

11 any conditions and that's why I intervened. I thought that people should

12 be allowed to move freely irrespective of the fact whether any of the

13 Serbs would be allowed to leave the territories where they were staying

14 at that time.

15 JUDGE ORIE: Which, in my view, then perhaps should have resulted

16 in an order: Never stop elderly women and children, for the reasons you

17 used until now, that is, that it should only be on the basis of

18 reciprocity because there should no reciprocity. That's what one should

19 expect under those circumstances. Do you have any comment on giving this

20 permission rather than to issue instructions as I suggested?

21 THE WITNESS: [Interpretation] I could issue such an instruction.

22 However, neither the elderly women nor any of the civilians would ever

23 come closer to the separation line without the previous guarantees issued

24 by the organs that would send them there, because those should be

25 previous negotiations about a cease-fire, the safety of crossing, and so

Page 24829

1 on and so forth, and we could never do that without a co-operation with

2 the Muslim side. No civilian ever did that spontaneously because they

3 would have found themselves in a combat zone if they had.

4 JUDGE ORIE: Thank you.

5 Mr. Lukic.

6 MR. LUKIC: [Interpretation] [Microphone not activated].

7 THE INTERPRETER: Microphone for Mr. Lukic, please.

8 JUDGE FLUEGGE: Your microphone.

9 MR. LUKIC: [Interpretation] And now can we please look at P6698.

10 [In English] We should probably have another page in English version

11 since it's not -- no, no, no. I need that page in B/C/S and then the

12 corresponding page in English.

13 JUDGE ORIE: Mr. Lukic, at the same time we asked the Prosecution

14 to clarify some of the issues. I do not know whether you want to deal

15 with those or with other matters. If you are dealing with other matters,

16 then please proceed. If, however, you are addressing the same issues I

17 raised with the Prosecution, then perhaps we could consider --

18 MR. LUKIC: Or maybe without bothering the witness I can just ask

19 how come that on this page there is a signature, alleged signature, of

20 this gentleman, or at least his name, in the middle of the document when

21 we can see the continuation of the names underneath?

22 JUDGE ORIE: Yes. It has got something to do with the -- the

23 witness doesn't know the document.

24 MR. LUKIC: He does not know.

25 JUDGE ORIE: So he --

Page 24830

1 MR. LUKIC: I --

2 JUDGE ORIE: -- let's first listen to Ms. Bibles --

3 MR. LUKIC: I accept.

4 JUDGE ORIE: -- what explanations she has for this cut and glued

5 together document.

6 MS. BIBLES: Thank you, Your Honour. This is a document from our

7 rules of the road collection. It was an original document that had been

8 torn up and pieced back together. I can say in terms of the translations

9 to address your concerns. On the first B/C/S page, which is this one, it

10 corresponds to the English page 3 in e-court. The second page in B/C/S

11 corresponds to the English page 1 and 2. And then the third page in

12 B/C/S corresponds to the English on page 5. So they're -- they're not

13 matched in terms of the way that they come. But in terms of the history

14 of the document, that's where -- where this one came from.

15 JUDGE ORIE: What surprises me -- and apparently the witness has

16 no knowledge of the document. What surprises me that if this is torn in

17 two pieces and then reconstructed, then at least the sequence of numbers

18 comes as a surprise unless you would have created a document where after

19 129 you continue with most likely 29 or 31 and then after 144 you restart

20 with 56 and then -- I mean, it's --

21 [Trial Chamber confers]

22 JUDGE ORIE: My colleague draws my attention to the fact at a

23 left column on this page ends with 129, and then the next column starts

24 with 130. But it's still -- it's a huge puzzle and what especially is of

25 concern to me is that if you look at the numbers, then the numbers here

Page 24831

1 and the numbers on the other pages give different names.

2 Let's have a look at. That's what I tried to explain earlier as

3 well. Oh, let me see.

4 MS. BIBLES: Your Honour, is that between the translations? Is

5 that the concern? I think these are different lists --

6 JUDGE ORIE: There are two lists.

7 MS. BIBLES: -- of individuals. Yes.

8 JUDGE ORIE: They are two lists.

9 [Trial Chamber confers]

10 JUDGE ORIE: If the witness can't assist us, perhaps we should

11 deal with the matter alert.

12 Mr. Lukic, if you have any further questions, then please

13 proceed.

14 MR. LUKIC: Thank you, Your Honour. I don't have any further

15 questions for this witness.

16 JUDGE ORIE: A very quick way of proceeding.

17 MR. LUKIC: [Interpretation] Mr. Adzic, thank you again for

18 having answered our questions.

19 JUDGE ORIE: Have the questions in re-examination triggered any

20 need for further questions?

21 MS. BIBLES: No.

22 JUDGE ORIE: No.

23 [Trial Chamber confers]

24 JUDGE ORIE: Then this concludes your evidence, Mr. Adzic. I'd

25 like to thank you very much for coming to The Hague and for having