150305ED

Page 32654

1 of your testimony. Mr. Gillett will now continue his cross-examination.

2 Please proceed.

3 MR. GILLETT: Thank you, Mr. President, and Your Honours.

4 WITNESS: MLADEN BLAGOJEVIC [Resumed]

5 [Witness answered through interpreter]

6 Cross-examination by Mr. Gillett: [Continued]

7 Q. Good morning, Mr. Blagojevic. Yesterday --

8 A. Good morning.

9 Q. Yesterday at the end of the day we were speaking about the events

10 at the Vuk Karadzic school in Bratunac on 14 July. Now, that day, Muslim

11 prisoners were taken out from the school and put on buses; correct?

12 A. Yes.

13 Q. As the prisoners were being taken out of the school and put on

14 the buses, some of them were beaten and abused; right?

15 A. Well, no. People were hurried to get onto the bus more quickly.

16 Q. RS police members were beating and abusing these Muslim prisoners

17 as they were getting on the buses; correct?

18 A. I'm telling you -- perhaps someone was pushed to hurry them to

19 get onto the bus, but there was civilian police and the army there.

20 Q. One of the police officers that was doing this was Sreten Micic;

21 right?

22 A. Yes.

23 Q. And Sreten Micic was participating in beating the prisoners as

24 they were being put on the buses; right?

25 A. No. He was pushing people onto the bus to hurry them up.

Page 32655

1 MR. GILLETT: Could we get 65 ter document 32111, page 20, on the

2 monitor. And this is the investigative report that I've referred to

3 several times during the cross-examination. Now, if we go to the

4 second-last paragraph, and again the B/C/S should be at the same position

5 as the English.

6 Q. It states:

7 "Blagojevic was asked if he saw any of the prisoners in the buses

8 or in the school being beaten or abused and he replied, 'yes,' that at

9 the entrance to the school, as the prisoners were being taken out of the

10 school and placed on the buses, he observed that the civilian police were

11 beating and abusing the prisoners. He identified one of the police

12 officers doing this as Sreten Micic."

13 Mr. Blagojevic, that's correct, isn't it, that prisoners were

14 being beaten and abused as they were taken from the school and put on the

15 buses?

16 A. I'm telling you again: People were pushed onto the bus because,

17 as they were coming out of the school, they were hurried to get onto the

18 bus as quickly as possible. There was shouting and there was pushing to

19 get them onto the bus.

20 Q. Mr. Blagojevic, some Muslim prisoners were killed outside the

21 Vuk Karadzic school in Bratunac on 14 July; correct?

22 A. That happened -- I mean, the shooting was behind the school.

23 Q. You saw some of the prisoners being killed, didn't you?

24 A. No.

25 MR. GILLETT: Could we get 65 ter document 32112. This is the

Page 32656

1 transcript of the videoed interview that we looked at yesterday as well.

2 And if we could go to page 82 of that.

3 Q. Now, if we look at the third intervention from the bottom, the

4 question is asked:

5 "Okay. You say the next morning that there were ... that some

6 prisoners were killed outside the school. Explain to me what happened

7 with that?"

8 MR. GILLETT: If we skip across to the next page.

9 Q. "A. They were killed behind the school towards the hangar."

10 "Q. What happened?

11 "A. I don't know.

12 "Q. How do you know they were killed? Did you see it or ...?

13 "A. I saw some people being taken off the bus and being killed.

14 "Q. Who were they taken off the bus by?

15 "A. I don't know the people. I don't know these people."

16 So, sir, in fact, you did see Muslim prisoners being taken off

17 the bus and killed at the Vuk Karadzic school; correct?

18 A. I'm telling you again, I saw they took them out of the bus and

19 behind the school. Since I was in front of the school, and behind the

20 school there is also a hangar, it was behind the school where I couldn't

21 see it and that's what I said in my statement. I heard shots but I

22 didn't see the killing.

23 JUDGE ORIE: Mr. Blagojevic, could we clarify to which statement

24 did you refer now, your statement given in the United States or your

25 statement given to the Mladic Defence?

Page 32657

1 THE WITNESS: [Interpretation] It's the statement about which the

2 gentleman is questioning me. I told you I didn't see the killing. I saw

3 them being taken behind the school.

4 JUDGE ORIE: One second, please. The statement as recorded says:

5 "I saw some people being taken off the bus and being killed," which, as

6 far as my knowledge of the English language, is that you saw them being

7 killed. So therefore, if you say, I say again, again, and again, you

8 said something different at the time, and I think Mr. Gillett is trying

9 to understand why you said that you saw them being killed at the time and

10 why you now say that you only saw them disappearing behind the school.

11 Mr. Lukic.

12 MR. LUKIC: Thank you, Your Honour. On the previous page it is

13 explained, Your Honour.

14 JUDGE ORIE: Well, no. There is nothing. This is what the

15 witness says after. He may have initially said something else. But this

16 is what he says and I read it literally.

17 And, Mr. Lukic, it's inappropriate to tell us that what the

18 witness said before explains how we have to understand this. That is

19 argument. I put some questions to the witness.

20 That's our problem -- or Mr. Gillett's problem at this moment,

21 Mr. Blagojevic.

22 THE WITNESS: [Interpretation] I am telling you I didn't see the

23 killing, but I saw a couple of Muslims taken out of the bus and taken

24 behind, but I didn't see it physically.

25 JUDGE ORIE: And then the next question is: Do you have any

Page 32658

1 explanation why you told at the time that you saw them being killed?

2 THE WITNESS: [Interpretation] Perhaps I did not understand the

3 question right, but I simply said that I saw them taken out, but I could

4 not see through the school. It was behind the school.

5 JUDGE FLUEGGE: Can this page be scrolled up a little bit so that

6 we can see the B/C/S answer. Thank you.

7 JUDGE ORIE: Mr. Gillett, in view of the testimony of the witness

8 this would be good -- this is not a CLSS translation. It is a transcript

9 of an interview in which others have interpreted the words used by the

10 witness. Perhaps it would be good and wise to have it verified whether

11 this is an accurate interpretation of what was said.

12 MR. GILLETT: We will have that verified. Thank you,

13 Mr. President.

14 JUDGE ORIE: Please proceed.

15 MR. GILLETT:

16 Q. Mr. Blagojevic, the people that were taking the prisoners behind

17 the school and killing them, were they wearing uniforms?

18 A. Yes.

19 Q. What type of uniforms?

20 A. Now I can't remember what kind of uniforms, but I believe they

21 were in uniforms.

22 Q. Were they military uniforms?

23 A. I don't know whether they were military uniforms or police

24 uniforms, blue ones. I can't remember.

25 Q. So to clarify they were either police uniforms or military

Page 32659

1 uniforms; correct?

2 A. Yes.

3 Q. Now, you and the military police present still had the Browning

4 gun at this stage outside the school; right?

5 A. Yes.

6 Q. So you were armed and guarding the Muslim prisoners, but you

7 didn't attempt to stop these people taking them from the buses and

8 killing them, did you?

9 A. Yes.

10 Q. "Yes" as in you agree that you did not attempt to stop these

11 people; correct?

12 A. I didn't dare.

13 Q. On that same day, you accompanied a column of buses with the

14 Muslims prisoners from Bratunac up to Rocevic; correct?

15 A. Yes.

16 Q. And Mile Janjic was in the same vehicle as you accompanied them;

17 right?

18 A. Possibly, but I'm not sure.

19 Q. At Rocevic, the Muslim prisoners were handed over to personnel

20 from the Zvornik military brigade; right?

21 A. Whether it was the military police or somebody from the

22 Zvornik Brigade, I don't know, because I was at the back of the column.

23 Now who did the handing over? I was at the back of the column.

24 MR. GILLETT: Can we get 65 ter document 32111, again, the

25 investigative report. And if we go to page 4 of this.

Page 32660

1 Q. And if we look at the second-last sentence or it may be the

2 fourth-last sentence, starting: "Later that morning ..." It states:

3 "Later that morning, Blagojevic and the other eight military

4 policemen were ordered to provide security and follow the column of buses

5 that departed Bratunac. The column travelled through Kravica and then to

6 Rocevic where the prisoners were transferred into the custody of the

7 Zvornik military personnel. The prisoners were unloaded at a school and

8 held in the school's gymnasium. Blagojevic and the other eight military

9 police officers returned to Bratunac, and the next morning they were

10 assigned routine military police duties such as guard duty on the bridge

11 and check-points."

12 It's correct that the prisoners were handed to Zvornik military

13 personnel in Rocevic; right?

14 A. Yes.

15 Q. So when you just said that you weren't sure about that a few

16 moments ago, that was not the truth, was it?

17 MR. LUKIC: Yeah --

18 THE WITNESS: [Interpretation] You asked me whether -- whether we

19 had handed them over to the military police of the Zvornik Brigade, and I

20 told you that I was at the back of the column. Now, who was at the head

21 of the column and who did the hand-over, I couldn't see that. Now, who

22 did the talking around that hand-over, I don't know. But we handed them

23 over to the Zvornik Brigade.

24 MR. GILLETT:

25 Q. Sir, who ordered you to hand over the prisoners?

Page 32661

1 A. I don't know. My group was only told to escort them, to go

2 behind the convoy to prevent any attack along the way. Now, who ordered

3 it, I don't know.

4 Q. Who ordered you to escort the column?

5 A. I don't remember that.

6 MR. GILLETT: Your Honours, at this point I'd tender 32111, which

7 is the set of investigative reports we've been referring to during the

8 testimony.

9 JUDGE ORIE: Madam Registrar.

10 THE REGISTRAR: Your Honours, 32111 receives number P7186.

11 JUDGE ORIE: That is the report, not the transcript.

12 MR. GILLETT: Not the transcript.

13 JUDGE ORIE: Not the transcript.

14 MR. GILLETT: And --

15 JUDGE ORIE: And that report is how many pages?

16 MR. GILLETT: That is 21 pages.

17 JUDGE ORIE: P7186 is admitted into evidence.

18 MR. GILLETT: Thank you, Mr. President. And on the transcript of

19 the video, I'm suggesting, because it didn't always come through entirely

20 clearly as to when it was a question and when it was an answer when I was

21 reading from the transcript or when it was being played, that what I

22 could do is take the existing transcript and take out the portions that

23 have been read or played to the witness in court and have those made

24 available. Obviously, if the Defence is agreeable to that suggestion.

25 JUDGE ORIE: Mr. Lukic, a selection of the videoed interviews

Page 32662

1 with the witness?

2 MR. LUKIC: I was informed by my colleague Stojanovic, as he was

3 more familiar with that, that we would rather have the whole thing, not

4 the selections, but because --

5 JUDGE ORIE: But I think the usual practice is that --

6 MR. LUKIC: I know that --

7 JUDGE ORIE: -- if a selection is made by the Prosecution, that

8 the Defence may add any portions it considers relevant for context.

9 Again, Mr. Lukic, if there are specific matters which are not

10 contextual to the portions selected by the Prosecution, then, of course,

11 you would have to put them to the witness, and you can't just introduce

12 them otherwise.

13 MR. GILLETT: If --

14 JUDGE ORIE: Yes.

15 MR. GILLETT: -- it may speed things up, we wouldn't object to

16 the whole video coming in. We're also happy to take out the excerpts

17 that have been played.

18 JUDGE ORIE: Then I suggest that the Prosecution and Defence will

19 sit together, that the Prosecution explains to the Defence what selection

20 it had on its mind, and that you will add whatever you think is needed

21 even if that would be the complete video.

22 MR. GILLETT: And --

23 JUDGE ORIE: We will proceed like that, and we already reserve a

24 number for either excerpts or the entirety of the videoed interview of

25 the witness.

Page 32663

1 MR. GILLETT: Thank you.

2 JUDGE ORIE: Madam Registrar.

3 THE REGISTRAR: Your Honours, the number reserved would be P7187.

4 JUDGE ORIE: And that number stands.

5 MR. GILLETT: Thank you.

6 Q. One final topic, Mr. Blagojevic. Yesterday during your

7 testimony, you were asked by the Defence at transcript pages 32605 to

8 32606 the following:

9 "Q. When you were entering the United States and receiving an

10 immigration visa, did they ask you about your participation in the war?

11 "A. Before we left for the United States, we went to Belgrade

12 and we had a meeting with IOM. That was the name of the organisation.

13 We had to fill in an application form. But they tricked us, in fact, and

14 they told us not to report any participation in the war for purposes of

15 speeding up our immigration."

16 So you say that this IOM organisation tricked you into not

17 reporting your membership in the VRS; right?

18 A. Yes.

19 Q. Previously, you've said that you left out the information about

20 your involvement in the VRS from the immigration forms because you heard

21 from family members that that was a way of getting into the US; correct?

22 A. That organisation told us not to report participation in the war

23 in order to leave faster and to have families reunified.

24 Q. That wasn't my question. My question was whether you have

25 previously said that you left off the information because family members

Page 32664

1 told you that this was a way of speeding up the application process?

2 JUDGE ORIE: Now you're putting something different to the

3 witness as you did before. Earlier you said that the witness would have

4 stated that he heard from family members that it was "a way of getting

5 into the US," not on speeding up the proceedings.

6 MR. GILLETT: Thank you, Mr. President. I'll repeat the full

7 initial question.

8 JUDGE ORIE: Yes.

9 MR. GILLETT:

10 Q. Sir, my question initially was: Previously, you've said that you

11 left out the information about your involvement in the VRS from the

12 immigration forms because you heard from family members that that was a

13 way of getting into US; correct?

14 A. No, I didn't hear that from family members. That is what we were

15 told in the organisation of IOM in Belgrade, in order to get out faster.

16 MR. GILLETT: Could we play the video 65 ter number 32155, and

17 this clip is 00:38:00 to 00:40:35.

18 Before we start playing, I would just note again that it has all

19 the English and the B/C/S, so I suggest it's easier if we don't have

20 interpretation.

21 JUDGE ORIE: Yes, that's -- our interpreters will be surprised to

22 hear that it's easier to have no interpretation, but under the

23 circumstances I would agree that it's better to play the original without

24 further explanation.

25 MR. GILLETT: Thank you.

Page 32665

1 [Video-clip played]

2 "We've been over it a couple of times, I've showed it to you.

3 When you filled that out and you listed your military services as 1990 to

4 1992, why did you list it that way?

5 "My wife was the carrier of that -- was the person that received

6 the guarantee letter. I filled it out that way just to come here.

7 "And you're -- so why did you leave the military service -- the

8 Bratunac military service off of that form?

9 "I was afraid that I won't be allowed to come here if I mention

10 that.

11 "Did anybody tell you that? Did anybody explain that to you?

12 "The others who came earlier, they told me that.

13 "The others -- other family members, other ...?

14 "People who came here before.

15 "Such as?

16 "My wife's parents. My wife's brother.

17 "Okay. Do you know if they were specifically instructed in

18 Belgrade not to put that information in there?

19 "I don't know. I'm not sure.

20 "It was just -- it was just common knowledge or through family?

21 "That was more in the family. It goes from one person to

22 another.

23 "So when you completed your application in Belgrade, a government

24 worker or somebody didn't tell you to leave it off or anything?

25 "No.

Page 32666

1 "Okay. [Indiscernible] he's your brother-in-law" --

2 MR. GILLETT: We can stop the video there.

3 JUDGE ORIE: Yes. You started playing at 38:00. And we now stop

4 looking at it at 40:31.8.

5 MR. GILLETT: Thank you, Mr. President.

6 Q. Sir, so, in fact, you did hear from family members that you

7 should not put in the information about your VRS involvement on the

8 immigration forms; correct?

9 A. Well, it's possible that I heard. But I repeat once again,

10 perhaps I didn't remember to say this here, but I am telling you that the

11 organisation IOM told us not to report participation in the last war.

12 And it wasn't only my family and I that went there, hundreds and hundreds

13 of other families went there too and did the same thing that I did. So

14 it's this organisation that said this and I stand by that.

15 JUDGE ORIE: Could I seek further clarification there. Did they

16 tell you personally that this is the way you should do it?

17 THE WITNESS: [Interpretation] Yes, personally.

18 JUDGE ORIE: Your testimony now is squarely contradicting what we

19 hear in the videoed interview. Do you have any explanation why where

20 quite a number of questions were put especially on this issue, that you

21 give testimony today which is quite different from the answers you gave

22 when interviewed?

23 THE WITNESS: [Interpretation] I'm telling you, possibly I didn't

24 remember then. But later on, after having gone through everything and

25 after having talked to people who, just like I, had a problem, I mean,

Page 32667

1 they said that and that took me back to my memories of Belgrade and the

2 IOM. Now I'm telling you that the organisation that was in Belgrade that

3 is called IOM, they told us not to report participation in the last war.

4 During those years in America, my eight years in America, I went

5 there twice. It's not that I was hiding anything. But I'm telling you

6 that I omitted to say that in that application. However, in that

7 application, I cannot remember exactly, but I think it was something like

8 did I take part in a foreign army. I did not consider the Army of

9 Republika Srpska to be a foreign army.

10 So the people who helped us with that application to go to

11 America told us not to report participation in the last war in order to

12 leave faster and to have family reunification. I state that with full

13 responsibility.

14 JUDGE ORIE: Mr. Gillett.

15 MR. GILLETT: I've no further questions, but I would add this

16 excerpt from 65 ter 32155, which I'd also suggest I could discuss with

17 the Defence adding that to the video package.

18 JUDGE ORIE: Yes. And, of course, we could play it again and

19 then have it on the transcript. I think the best way of dealing with

20 this is that the accompanying transcript pages to the video, that they

21 should be tendered as well so that we have clearly what we just heard,

22 that we have that as an exhibit.

23 [Trial Chamber and Registrar confer]

24 MR. GILLETT: And Mr. --

25 JUDGE ORIE: I see that it's fully in the transcript. I usually

Page 32677

1 to you.

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

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

4 JUDGE ORIE: Thank you. Please be seated.

5 WITNESS: BRANKO VOLAS

6 [Witness answered through interpreter]

7 THE WITNESS: [Interpretation] Thank you.

8 JUDGE ORIE: Mr. Volas, you will first be examined by Mr. Ivetic.

9 You will find Mr. Ivetic to your left. Mr. Ivetic is a member of the

10 Defence team of Mr. Mladic.

11 Please proceed, Mr. Ivetic.

12 Examination by Mr. Ivetic:

13 Q. Good day, sir. Could you please state your full name so that it

14 correctly appears in the record.

15 A. I am Branko Volas, born in 1954, in Kljuc. Father Luka, mother

16 Rosa. I live in Zabrdje. I am father of two, retired.

17 MR. IVETIC: If we can call up 65 ter number 1D1624 in e-court.

18 Q. Sir, can you tell us whose signature appears on the first page of

19 this witness statement?

20 A. It's my signature.

21 MR. IVETIC: If we can turn to the last page of the document in

22 e-court.

23 Q. And, sir, on this page there is a signature above a date. Can

24 you tell us whose signature we see here?

25 A. It's my signature.

Page 32678

1 Q. And, sir, subsequent to signing this statement on the date

2 indicated, did you have a chance to read it over fully in the Serbian

3 language to make sure that everything is correctly recorded in the

4 statement?

5 A. Yes.

6 Q. And is everything accurately recorded in this statement?

7 A. Yes.

8 Q. If I were to ask you questions today based upon the same topics

9 as those in your written statement, would your answers today in substance

10 be the same as the information which is contained in the written

11 statement?

12 A. Yes.

13 Q. And, sir, since you have taken a solemn declaration to tell the

14 truth, does that mean that the answers as recorded in your statement are

15 truthful in nature?

16 A. Yes.

17 MR. IVETIC: Your Honours, the Defence would tender 1D1624 into

18 evidence. There are no associated exhibits with that statement.

19 JUDGE ORIE: Madam Registrar.

20 THE REGISTRAR: Your Honours, 1D1624 receives number D923.

21 JUDGE ORIE: D923 is admitted.

22 MR. IVETIC: Your Honours, I have a short summary which has been

23 explained to the witness.

24 The witness Branko Volas testifies that before the conflict broke

25 out in Kljuc, besides the police forces, mixed Serb and Muslim armed

Page 32679

1 forces set up by the Territorial Defence were present in town.

2 The first incidents in Kljuc were caused by Muslim extremists who

3 attacked buses transporting unarmed JNA soldiers demobilised from the

4 Croatian front, and ambushed and killed the deputy commander of the Kljuc

5 police station.

6 In certain villages inhabited by Muslims, check-points were set

7 up which controlled the movement of Serbs. After these incidents, chaos

8 ensued which lasted until the political authorities were in place. After

9 the civilian authorities were established, they ordered that all citizens

10 of Kljuc be protected. Everyone who did not possess illegal weapons nor

11 pose a threat to Republika Srpska could remain in Kljuc.

12 All those that had someone in third countries tried to leave

13 Kljuc and go to a place where there was no war. This was done by

14 Muslims, Croats, and Serbs alike. The corridor was closed and the

15 connection with Serbia was cut off, so there was less food and medicine

16 available. These conditions were difficult for all citizens of Kljuc.

17 It was understandable that people would want to leave.

18 And that ends the public summary.

19 Q. Now, before we turn to some matters from your statement, sir, can

20 you please tell us what position you held during the war and in what

21 formation?

22 A. Yes. I was mobilised in February 1992. It was still the JNA,

23 the 13th Krajina Brigade, and its headquarters were in Banja Luka. I was

24 an operations officer in the brigade command. And when unrests broke out

25 in Kupres plateau, our unit was deployed at the demarcation line

Page 32680

1 between the Croat, Muslim, and Serb territory. And I stayed there until

2 24 June 1992, when I was transferred to the Kljuc 17th Brigade to be

3 assistant commander for intelligence and security in the battalion that

4 was being set up then. Until 16 July, in Donja Previja, members for that

5 unit were recruited and prepared for deployment. Around the 17th of

6 August, we were transferred to the area of Grmec, towards Bihac, Grmusa

7 sector, where we stayed for about 20 days on the demarcation line, and at

8 that time I was appointed commander of the 3rd Battalion.

9 In the beginning of August, we were sent on home leave, and after

10 that we went about our duties pursuant to the orders from the command,

11 and our tasks included mainly holding the separation line between the

12 warring parties.

13 Q. Now I want to turn to page 2 of your statement, and I want to

14 look at the second paragraph of the same.

15 MR. IVETIC: So if we can call that up.

16 Q. And here you talk of mixed Serb and Muslim armed forces that had

17 been created by the Territorial Defence. First I want to ask you what

18 about the active and reserve police forces which you mention, what was

19 their composition?

20 A. At that time before the end of May, there were both Serbs and

21 Muslims in the reserve force of the police, and probably also the

22 Territorial Defence. Since I was in one of these units, I noticed when I

23 came back on leave from the Kupres plateau that in my street outside my

24 building - and you have to know that Kljuc is a small town - I noticed

25 that there were both Muslims and Serbs together in patrols. Patrols

Page 32681

1 existed at that time to secure buildings, various installations,

2 businesses, et cetera.

3 Q. Now, in relation to these mixed Serb and Muslim forces patrolling

4 the town, what happened to them when the conflict broke out in Kljuc

5 municipality?

6 A. I couldn't tell you that because at that critical moment, I just

7 arrived on leave from Kupres, and what happened later I don't know.

8 While I was away, I couldn't see whether they continued to be mixed units

9 and mixed patrols.

10 Q. Okay. Now if we could focus on the third paragraph in your

11 statement on this same page. Can you provide us a time-frame for when

12 these incidents, the attack on the bus of JNA soldiers and the ambush and

13 killing of the deputy commander of the police station, a time-frame for

14 when these incidents occurred?

15 JUDGE ORIE: Which paragraph are we --

16 MR. IVETIC: 3.

17 JUDGE ORIE: 3.

18 THE WITNESS: [Interpretation] Yes, I know that was on 27 May. At

19 that time, I was about 20 kilometres away from the scene, and I noticed

20 that in the meantime reserve policemen had been called in. I knew some

21 of them and they told me about this incident, that fire was opened at a

22 convoy of military vehicles and Mr. Stojakovic, a deputy commander of the

23 military police, was killed.

24 After that I went home to see my wife and children and see what

25 the situation was like. I saw that something was going on. I saw that

Page 32682

1 there was anxiety on both sides, and there were ambulances and other

2 emergency vehicles moving around more than usual. So it all began during

3 those days.

4 Q. Now in this same paragraph, you identify:

5 "In certain villages and settlements that were predominantly

6 inhabited by Muslims, they set up check-points and controlled the

7 movement of Serbs."

8 Can you specify for us what village or villages are at issue

9 here?

10 A. On that day, my wife's brother was visiting his father in Pec

11 village, which is between Sanski Most and Kljuc. And when he was passing

12 by bus through Krasulje, going to Sanski Most, the vehicle was stopped.

13 He knew those people. He saw that they were armed Muslims. They didn't

14 create any problems, they let the people go on. But in the same place,

15 Stojakovic was later killed. I know that from reliable sources. I don't

16 know anything else.

17 Q. In --

18 JUDGE ORIE: Mr. Ivetic --

19 MR. IVETIC: Yes.

20 JUDGE ORIE: -- if a witness says that he knows something on the

21 basis of reliable sources, then of course the reliability is for the

22 Chamber to decide. Could you further explore those sources.

23 MR. IVETIC:

24 Q. Sir, you've heard what the Judges have said. Could you provide

25 more details as to the sources of this information that you have just

Page 32683

1 referenced?

2 A. That information came from my wife's brother, who saw me that

3 very day. He told me that and I believe him, and that's the only

4 reliable information that I have.

5 JUDGE ORIE: Then, Witness, you told us that your brother-in-law

6 came across those check-points. Did you have any personal experience at

7 check-points?

8 THE WITNESS: [Interpretation] No. Between my village, Zabrdje,

9 and Kljuc, there is a settlement --

10 THE INTERPRETER: The interpreter didn't hear the name.

11 THE WITNESS: [Interpretation] -- where I passed through after all

12 these incidents. I didn't see, I didn't notice anyone armed or standing

13 unarmed on the road, nor were there any problems on the way through that

14 area.

15 JUDGE ORIE: So the only source of knowledge is your

16 brother-in-law.

17 Now, you also said that someone was killed at that same

18 check-point at a later point in time, Mr. Stojakovic. What is your

19 source of knowledge of that?

20 THE WITNESS: [Interpretation] I know that area. I passed through

21 that place many times, Krasulje village, where Stojakovic was killed.

22 You have a very good view of that area. You can see both vehicles and

23 people. It was a road under their control. It was safe for them and

24 they probably shot him.

25 JUDGE ORIE: They probably shot him. So it is -- you think that

Page 32684

1 he would have been shot there, but you are not certain about it. Is that

2 how I have to understand your testimony?

3 THE WITNESS: [Interpretation] Well, after the bus arrived in

4 Kljuc, the police was informed that there was this incident with a bus

5 and passengers, and the police came out to investigate, and that's how it

6 happened.

7 JUDGE ORIE: Yes, but what is now your specific source of

8 knowledge about Mr. Stojakovic being killed, by whom? Who told you or

9 did you see it or ...

10 THE WITNESS: [Interpretation] No, no. At that time I wasn't

11 there. I was 20 kilometres away, as I said. The people who were with

12 him told me that, members of the police who were with him in the car.

13 And I believe there was more than one car. They were all met with

14 gun-fire but they managed to pull back and escape.

15 JUDGE ORIE: Yes. Thank you.

16 Please proceed, Mr. Ivetic.

17 MR. IVETIC:

18 Q. If we can turn to page 4 in both languages of your statement, I'd

19 like to ask you a question about paragraph 13 of the same.

20 Sir, in paragraph 13 you say:

21 "The Serbs were armed legally through the army."

22 Could you please explain for us what you meant to say here? What

23 kind of Serb persons were so armed?

24 A. I can maintain that only about those Serbs who were mobilised

25 into JNA units at the time, and of course when they were mobilised they

Page 32685

1 were given weapons. Whether there was illegal arming or not, I don't

2 know that since I was already part of a unit.

3 JUDGE MOLOTO: Can I ask a question?

4 MR. IVETIC: Sure.

5 JUDGE MOLOTO: Sir, the JNA was a mixed army, wasn't it? I mean,

6 there were Croats and Muslims and Serbs in it?

7 THE WITNESS: [Interpretation] Yes.

8 JUDGE MOLOTO: And all of the members of the army would have been

9 legally armed by the JNA, isn't it so?

10 THE WITNESS: [Interpretation] Yes.

11 JUDGE MOLOTO: That would include the Muslims and the Croats?

12 THE WITNESS: [Interpretation] Yes, those who actually responded

13 to the call-up.

14 JUDGE MOLOTO: So the JNA had always had people -- we're not

15 talking about something that is created during the war, but we're talking

16 about the JNA that was existing before the war.

17 THE WITNESS: [Interpretation] Before the war, the units did not

18 arm men when they were at home. They were given weapons only when they

19 assembled at a given place, when they were mobilised, so we did not have

20 any weapons at home. You got a weapon only when you were mobilised and

21 when a unit was formed.

22 JUDGE MOLOTO: And who armed these Serbs at this point in time

23 legally?

24 THE WITNESS: [Interpretation] At that time the units that were in

25 charge; that's to say, levels above brigade. In pre-war conditions,

Page 32686

1 there were commands for the development of so-called partisan units that

2 were in charge of such tasks.

3 JUDGE MOLOTO: But my question is: What authority was arming

4 these Serb people who were legally armed?

5 THE WITNESS: [Interpretation] It's not authorities. It's the

6 official JNA that was in JNA barracks, and in those barracks, weapons and

7 equipment were held. And on the orders of a superior command, these

8 development commands would bring weapons to the assembly place. And when

9 men were mobilised, they would come to that assembly point, receive

10 weapons, and at that time it wouldn't matter whether they were Muslim,

11 Croat, or Serb.

12 JUDGE MOLOTO: But you say in that the Serbs legally armed and

13 they were armed by the JNA, so I would expect that the JNA didn't arm

14 them, the Croats and the Muslims. From what you're saying.

15 THE WITNESS: [Interpretation] We are not understanding each

16 other. I said in February 1992 there was still JNA, and within those

17 partisan units of the JNA - for instance, in our specific unit - there

18 were both Muslims and Croats. And, of course, they received weapons at

19 the time as well.

20 However, later on they kept the weapons and left the units. Some

21 stayed within the units, but a lot of people left and kept their weapons.

22 JUDGE MOLOTO: Thank you.

23 Mr. Ivetic.

24 MR. IVETIC:

25 Q. Sir, on behalf of General Mladic and the rest of the team, I

Page 32690

1 Cross-examination by Mr. Jeremy:

2 Q. Now, sir, I'd like to return to paragraph 14 of your statement,

3 which we've just been discussing. Now, charged in the indictment is an

4 incident relating to Kljuc on or about the 1st of June, 1992, and that's

5 the -- that incident is the killing of at least 77 men at Velagici

6 school.

7 Now, I understand from your testimony today that you were in

8 Kupres at this time; correct?

9 A. Yes.

10 Q. Now, the -- another incident charged in the indictment relating

11 to Kljuc is on the 10th of July, 1992, and that relates to the killing of

12 at least 144 people in Biljani. Now, I understand from your testimony

13 today that you returned from Kupres on the 24th of June, 1992, when you

14 were transferred to the 17th Brigade as assistant commander for intel and

15 security. So were you, in fact, in Kljuc on the date of this particular

16 incident, the 10th of July, 1992?

17 A. No, I was assistant commander of a battalion, and it was being

18 established in Donja Previja. That is 12 or 13 kilometres away from

19 Kljuc in the area of --

20 THE INTERPRETER: The interpreters did not hear the rest.

21 MR. JEREMY:

22 Q. Sir, could you repeat the final part of your answer? You said

23 that you were assistant commander of the battalion and -- which was

24 established in Donja Previja. "That's 12 or 13 kilometres away from

25 Kljuc in the area of ..." and we didn't hear the area. If you could

Page 32691

1 repeat that.

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

3 microphones please be switched off when the witness is speaking.

4 THE WITNESS: [Interpretation] In the area of Ribnik and Banja

5 Luka, in that direction. On one side is Biljani. On the other side -- I

6 mean, Kljuc, so then Donja Previja is out there.

7 JUDGE ORIE: Witness, could you also speak slightly louder.

8 MR. JEREMY:

9 Q. Now, sir, in relation to these incidents occurring in Kljuc in a

10 general sense, you said that people were talking about them. Now, as

11 part of this talk, did you hear that Marko Samardzija, a company

12 commander in the 2nd Battalion of the 17th Brigade, was involved in this

13 particular incident in Biljani?

14 A. No. No. I knew Marko before the war. After that I didn't see

15 him. I didn't have any contact with him. Especially because, at that

16 time, part of the unit was at the Bihac theatre of war, another one at

17 the Jajce theatre of war. There was no contact between the units. I did

18 not know who was there and what was going on.

19 Q. So, to be clear, you had no contact with Marko Samardzija during

20 the war period, is that correct, between 1992 and 1995?

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

22 witness.

23 THE WITNESS: [Interpretation] I don't know where he was.

24 MR. JEREMY:

25 Q. Sir, could you repeat your answer, please?

Page 32692

1 A. I had no contact with Samardzija, and I did not see him during

2 the war, and I don't know where he was. I never noticed him in the

3 2nd Battalion, and I did have contact with the 2nd Battalion at the end

4 of June at --

5 THE INTERPRETER: The interpreters did not hear the name of the

6 plateau.

7 THE WITNESS: [Interpretation] That is to say, 100 kilometres away

8 from Kljuc.

9 JUDGE ORIE: Witness, again, could you speak up a bit louder and

10 come a bit closer to the microphones. The interpreters have repeatedly

11 difficulties in hearing you.

12 MR. JEREMY:

13 Q. And, sir, you mentioned a particular plateau, and the

14 interpreters did not capture the name of that plateau. Could you repeat

15 it, please.

16 A. Grmusa plateau. That's the territory of the municipality of

17 Bihac. Between Bosanska Krupa and Bihac there is Grmec.

18 Q. Thank you. Now, today you were you were appointed commander of

19 the 3rd Battalion around August or September 1992. Now, you were

20 replaced as the commander of the 3rd Battalion at the end of

21 October 1994; correct?

22 A. Yes.

23 Q. And you were replaced by Bozo Davidovic; correct?

24 A. Yes.

25 Q. And you were replaced as commander of the 3rd Battalion because

Page 32693

1 there were concerns that you were making arrangements to leave your

2 battalion's position at the time; correct?

3 A. I don't think that that is what is charged in the indictment. I

4 think it was something else.

5 Q. Sir, you refer to an indictment. Could you explain what

6 indictment you're referring to?

7 A. Probably this one on account of which I'm testifying here today.

8 Q. Sir, when you said that you think something else was charged in

9 the indictment, can you explain what you meant?

10 A. Could you please repeat that question? I did not quite

11 understand it.

12 Q. Yes, sir. Well, sir, I suggested to you that you were -- the

13 reason you were replaced as commander of the 3rd Battalion was because

14 there were concerns that you were making arrangements to leave your

15 battalion's position in October 1994.

16 Now in response you said to me:

17 "I don't think that that is what is charged in the indictment. I

18 think it was something else."

19 So could you clarify what you're referring to as you think it was

20 something else?

21 A. Well, because there were no proceedings against me, disciplinary

22 or court proceedings, in relation to what happened. I was simply

23 reassigned to a different unit, to the same position.

24 Q. Okay. Let's take a quick look at an exhibit in connection with

25 this, which might be able to assist.

Page 32694

1 MR. JEREMY: Could we please see P362, and that's the notebook of

2 General Mladic. And could we go to page 115 in the English and 114 in

3 the B/C/S, please.

4 Sorry, could we go to the -- I should have said. Could we go to

5 the typed B/C/S version of the diary? My mistake.

6 Q. Now, sir - thank you - on the screen before you, we see this is

7 General Mladic's diary and we see an entry relating to the 13th of

8 October, 1994, and we see that there is a meeting with commanders of the

9 RSK. And we see a reference to the 1st and 2nd Krajina Corps and some

10 additional corps.

11 MR. JEREMY: Could we please go to page 121 in the English and

12 120 in the B/C/S.

13 Q. Now, sir, directing your attention to the bottom of the page on

14 the screen before you, we see a reference to a Mitrovic. That's a

15 reference to Colonel Mikajlo Mitrovic, the chief of intel and security in

16 the 2nd Krajina Corps; yes?

17 THE INTERPRETER: Interpreter's note: We did not understand the

18 answer.

19 JUDGE ORIE: Could you repeat your answer and speak up a little

20 bit more, because if we can't hear you, we can't ...

21 THE WITNESS: [Interpretation] I knew Colonel Mitrovic personally.

22 Now, what duty he had in the corps command, that I don't know.

23 MR. JEREMY:

24 Q. Okay. That's fine.

25 MR. JEREMY: Could we go to the next page in each language,

Page 32695

1 please. Okay. Thank you.

2 Q. So, sir, referring your attention to the second hyphenated

3 paragraph, I read as follows:

4 "- In the 3rd Battalion of the 17th Brigade - it has been proven

5 that Captain 1st Class Branko Volas was making arrangements with star

6 commanding officers and company commanders to leave the battalion

7 position."

8 Now, firstly, sir, that's a reference to yourself, correct?

9 A. Yes.

10 Q. Now this entry appears to suggest that you were indeed making

11 arrangements to leave the battalion position. Can you explain what this

12 entry actually relates to?

13 A. I think that that is the personal opinion of Colonel Mitrovic.

14 At that time, I carried out the orders issued to me by my superior

15 command of the brigade, and that meant moving the unit to reserve

16 positions which made it possible to act better. This was done on orders

17 from the brigade command.

18 Q. But it was because of this position that you were -- it was

19 because of the decision that you took that you were removed from your

20 position as battalion commander; correct?

21 A. That was not my decision. That was implementation of orders from

22 the superior command.

23 Q. And what position did you take after you were removed as

24 battalion commander?

25 A. For a while after the situation became different in the

Page 32696

1 15th Bihac Brigade, I was company commander and then battalion commander.

2 And that's where I was until the end of the war.

3 JUDGE ORIE: Mr. Jeremy, the Chamber wonders, not only in respect

4 to the cross-examination but for the entirety, perhaps, of the testimony

5 of the witness, what the relevance is.

6 We do not see anything, in his statement at least, about his

7 functions, et cetera, that was introduced today. Of course, the 65 ter

8 summary tells us that he would tell us a lot of things about all kind of

9 things where we do not find anything in his statement about most of it.

10 And now, apparently, there has once been a problem in whether or not this

11 witness was a reliable officer or not, I take it. We don't know exactly

12 what happened but -- and now we are spending a lot of time on that.

13 Could you either come to your point quickly or explain to us what

14 the relevance of this is? And perhaps we should have asked the question

15 for the whole of this testimony to the Defence as well.

16 MR. JEREMY: Yes, Your Honours. I simply wanted to explore this

17 entry[ relating to the witness departing from his position as battalion

18 commander. It's not something that's mentioned in his statement. But if

19 it's not of -- I see it's not of assistance to the Chamber, so I'll move

20 on.

21 JUDGE ORIE: Well, I do not know. Apparently someone has had,

22 and perhaps the accused may have had, at some time a concern about this

23 witness perhaps leaving with his battalion. And then he says, Well, that

24 was not the case and I've never been prosecuted for that.

25 So we are dealing with a totally isolated incident which

Page 32697

1 apparently has got nothing to do with the indictment, at least as far as

2 we understand from the evidence as presented until now. And are we going

3 to listen to those details for another hour?

4 MR. JEREMY: Well, Your Honours, the position of the Prosecution

5 would be that this is a clear example of command and control being

6 exercised by the accused. Concerns about this witness as a battalion

7 commander are expressed in the diary entry of Mr. Mladic. Shortly after

8 that, the witness is removed from his position.

9 JUDGE ORIE: Okay. I see your point. And I can also imagine

10 that in view of what was announced in the 65 ter summary, that you would

11 expect evidence of this kind, and it was introduced only today.

12 Let's then briefly deal with that. You've now explained what the

13 relevance is, and I think we could deal with that easily in ten, perhaps

14 15 minutes, isn't it? If it's just that issue.

15 MR. JEREMY: Yes, Your Honours. And I'm satisfied the issue has

16 been sufficiently dealt with now.

17 JUDGE ORIE: Mr. Ivetic.

18 MR. IVETIC: Well, if the Prosecution is going to stand up and

19 give their position, I think it's only fair that the Defence stands up

20 and gives their position on this evidence.

21 JUDGE ORIE: That's the reason, first of all, I intervened during

22 cross-examination and I addressed the cross-examiner. And I was about to

23 give you an opportunity to make any submissions you think would be

24 important at this moment. Perhaps one of them, if you could clarify, why

25 there is such a huge difference between the 65 ter summary and what we

Page 32698

1 find in the statement of the witness. That would certainly be

2 appreciated. If you can do it in a few words.

3 MR. IVETIC: With respect to the 65 ter summary, I don't know who

4 prepared it for this witness. It was not myself. But I think that the

5 information was not yet available to us fully as to what the witness

6 would testify about. I believe the statement is dated after the date

7 that the 65 ter would have been submitted.

8 JUDGE ORIE: Mr. Ivetic, if you say the witness will testify

9 about the composition of his battalion and its activities, well, whether

10 the evidence is there depends on what you present. You -- there is no

11 way that you could say, "Well, we didn't know yet what the witness would

12 testify about," because he'll testify about what you ask him. He'll

13 testify about what you put in his statement. Apparently, you have

14 changed your mind in this respect.

15 But please proceed.

16 MR. IVETIC: And -- proceed to whom?

17 JUDGE ORIE: No, to you, Mr. Ivetic --

18 MR. IVETIC: Okay.

19 JUDGE ORIE: -- because you were -- I interrupted you.

20 MR. IVETIC: That is correct.

21 Now, in relation to this that has just been shown to the witness,

22 it would be the Defence's position that this demonstrates that there was

23 oftentimes questions about the veracity of information that was coming up

24 through the reporting. And that given the evidence of this witness that

25 he's just now given, that has demonstrated that what was reported in this

Page 32699

1 meeting is not in accord with what the witness presents or the factual

2 scenario at the time.

3 And that would be the position of the Defence. And I thank you

4 for that and apologise for taking up this much time.

5 JUDGE ORIE: Please proceed, Mr. Jeremy.

6 MR. JEREMY: Thank you, Your Honours. And I will move on from

7 this area.

8 Q. Could we -- and we'll go back, sir, to Kljuc in 1992 and focus on

9 paragraph 3 of your statement. Now in this paragraph 3, you refer to

10 preparations that were being made for war by "Muslim extremists." The

11 Serb leadership in Kljuc were also organising militarily in the months

12 leading up to the conflict; correct?

13 A. Since I was in a JNA unit at the time, what the Serb leadership

14 in the municipality of Kljuc was doing then, I don't know. I don't know

15 what you consider to be the Serbian leadership. Is that the

16 Territorial Defence or is it politics?

17 Q. Well, sir, I'd like to show you an exhibit in connection with

18 that and I think that will answer your question.

19 MR. JEREMY: Your Honours, I know we're close to the break time.

20 This area will probably take me five minutes or so.

21 JUDGE ORIE: Then how much time would you then need after the

22 break?

23 MR. JEREMY: I think I've probably taken around 20 minutes or so.

24 I'll -- I will finish in the next session after the break, comfortably.

25 JUDGE ORIE: We'll take a break. But could you please consider

Page 32700

1 to see -- a witness who has testified that he doesn't know anything about

2 A and knows everything about B but gives hardly any sources of knowledge,

3 and the sources of knowledge he testified about, well, may require

4 reassessment of the importance and of the accuracy of the whole of the

5 testimony.

6 Could you please consider all that and see how much time you

7 would need after the break after you've thought this over.

8 MR. JEREMY: Yes, Your Honours.

9 JUDGE ORIE: We take a break, Witness. We'd like to see you back

10 in 20 minutes. And we'll then continue. You may follow the usher.

11 [The witness stands down]

12 JUDGE ORIE: We resume at ten minutes past 12.00.

13 --- Recess taken at 11.51 a.m.

14 --- On resuming at 12.12 p.m.

15 JUDGE ORIE: We're waiting for the witness to be escorted into

16 the courtroom.

17 [The witness takes the stand]

18 JUDGE ORIE: Mr. Jeremy, please proceed.

19 MR. JEREMY: Thank you, Your Honours.

20 Q. Now, sir, at the end of the last session we were discussing the

21 Serb leadership in Kljuc. Now, that's something that I will come back

22 to, but now I'd like to switch topics. And I'd like to focus on

23 paragraph 7 of your statement where you refer to Muslims being part of

24 the police in Kljuc, and that's something that you discussed earlier

25 today.

Page 32701

1 So in paragraph 7 of your statement, you state:

2 "There were many instances of persons of Muslim ethnicity

3 remaining in the VRS and in the civilian police. Whoever wanted could

4 continue to work at the police."

5 Now, sir, just to clarify this paragraph in your statement in the

6 context of what you have told us this morning, I understand your position

7 to be that up until the point of the outbreak of the conflict in Kljuc,

8 the police was mixed, but after that point, you're not in a position to

9 say whether or not the police was indeed mixed; is that correct?

10 A. After that, I know about only one case, where a Croat person

11 remained on the police force all the way up until the end of war. He

12 continued to work in the police of Republika Srpska.

13 Q. Thank you. Now, I'd like to change topic again, and I'd like to

14 discuss the topic of the dismissal of people from work, which is referred

15 to in paragraph 10 of your statement. Now in that paragraph 10, you say

16 that only representatives of the SDA and the HDZ were replaced by Serbs,

17 and that all other citizens who observed the constitution and the laws of

18 RS, Republika Srpska, could remain in the municipality of Kljuc and work.

19 Now, sir, in fact in July 1992, the War Presidency of the Kljuc

20 municipality decided that only officials of Serbian nationality could

21 occupy those posts that were considered to be the most important in

22 Kljuc. That's correct, isn't it?

23 A. Well, as far as I can see, my statement does not refer to

24 officials but workers, employees.

25 Q. Well, sir, so is it your position that when you say that "all

Page 32702

1 other citizens who observed the constitution and the laws of

2 Republika Srpska could remain in the municipality of Kljuc and work," you

3 were excluding from that sentence persons who held the most important

4 positions in the Kljuc municipality? Is that correct? So that's an

5 additional category to representatives of the SDA and the HDZ who were

6 removed from their posts.

7 A. I think the officials and managers are a type of employees. I

8 didn't make a distinction between these two categories, nor do I know

9 about any decisions banning anyone from work in that area.

10 Q. Let's look at an exhibit in connection with this.

11 MR. JEREMY: Could we please see 65 ter 03070.

12 Q. And, sir, I'm not disputing that officials and managers are a

13 type of employee, so that's clear to you. Now, we see that this is a

14 decision of the War Presidency of the Assembly of the Kljuc municipality.

15 It was taken on the 21st of July, 1992. We see the name at the bottom,

16 president of the War Presidency, Jovo Banjac. Was this -- did you know

17 Jovo Banjac, sir?

18 A. Yes.

19 Q. And how did you know him?

20 A. Mr. Banjac was for a while the director of the construction

21 company where I worked at before the war.

22 Q. And did you know him during the war in his capacity as president

23 of the War Presidency?

24 A. I knew him as president of the assembly, the speaker. As for the

25 War Presidency, it was some sort of civilian structure, while I was part

Page 32703

1 of a military unit and I had no contact with that agency.

2 Q. So you didn't attend any meetings yourself with Jovo Banjac;

3 correct?

4 A. I don't recall any official meetings. Perhaps we had coffee once

5 or twice together.

6 Q. Okay. Let's focus in this decision and in particular

7 paragraph 1, where we read:

8 "Only officials of Serbian nationality can occupy managerial

9 posts, posts which may provide access to information or involve the

10 protection of public property, and posts which are important for the

11 functioning of the economy."

12 So, sir, you would agree that this decision focuses on the type

13 of posts that are being occupied, and it says nothing about whether the

14 occupants of those posts have an affiliation to the SDA or the HDZ?

15 A. I don't know what I'm supposed to answer, specifically.

16 Q. Well, sir, in your statement, you have said that the only persons

17 who could not stay in their positions were representatives of the SDA or

18 the HDZ. Here we see a decision indicating that persons who occupy

19 particular types of positions can only be Serbian persons. And I'm

20 clarifying with you that there is no reference here to the fact that such

21 persons may be affiliated to the SDA or the HDZ, which is in square

22 contravention to what you say in your statement.

23 A. It's a decision by an authority that I am seeing for the first

24 time today.

25 MR. JEREMY: Your Honours, I'd tender that document as the next

Page 32704

1 Prosecution exhibit.

2 JUDGE ORIE: Madam Registrar -- Mr. Ivetic.

3 MR. IVETIC: Mr. Lukic advise that he believes another version of

4 this may already be in evidence. I seem to remember that it was raised

5 with another witness.

6 JUDGE ORIE: It may well be.

7 Madam Registrar, before we further address the matter, could you

8 perhaps check in the e-court system whether this document under its known

9 65 ter number is already in evidence.

10 THE REGISTRAR: Your Honours, the document currently used bearing

11 number 03070 is not admitted.

12 JUDGE ORIE: Is not. Then, Mr. Jeremy, could you please verify

13 whether perhaps under another 65 ter number it is in evidence.

14 MR. JEREMY: Yes, Your Honours. We will verify that.

15 JUDGE ORIE: Yes. When do you think you could do that?

16 MR. JEREMY: In the next 30 minutes I would expect.

17 JUDGE ORIE: Okay. Then we'll leave it for a moment, and then

18 you'll remind us that you tendered it later after those 30 minutes.

19 Please proceed -- or not remind us.

20 MR. JEREMY: Thank you, Your Honours.

21 Q. Now, sir, I'd like to move now to a different topic that you

22 discuss in your statement in -- and that's in paragraph 6, and it's the

23 departure of the population from Kljuc.

24 Now in that paragraph, you state:

25 "I solemnly claim that the political leadership of Kljuc urged

Page 32705

1 all citizens of Kljuc, regardless of their affiliation, to live in peace

2 with one another."

3 Now, I want to explore the basis of your knowledge about the

4 political leadership of Kljuc and their intentions. Now, were you

5 familiar with Veljko Kondic, the president of the Municipal Board of the

6 SDS?

7 A. Yes. That gentleman was the director of the company I worked for

8 a certain time.

9 Q. And did you attend meetings with him?

10 A. Officially, no. Until perhaps -- I don't remember exactly.

11 Perhaps the end of 1993 when there were some differences of opinion

12 within the municipality and so there were meetings. I don't know whether

13 it can be treated as a meeting, but I did attend one session of the

14 Municipal Board of the SDS in Kljuc. But that was already the second

15 half of 1993, I think.

16 Q. So did you -- were you yourself a member of this Municipal Board

17 of Kljuc?

18 A. I was a member of the SDS, but not a member of the board. At

19 least not at the time when it was established. But there were some

20 sessions that co-opted extra personnel. Maybe they didn't have enough

21 people. For whatever reason, I attended only one session of the

22 Municipal Board.

23 Q. And were you a member of this board at any time during the war

24 period?

25 A. Only at that one session. I was a member. I know that I was

Page 32706

1 there. I don't remember participating in the discussion. As far as I

2 remember, there were some other forms of political organisation. I don't

3 know for what reason they invited me, but I attended only that one

4 session.

5 Q. And were you also a member of the Kljuc local board?

6 A. No. At the stage of establishment, it's possible that they

7 needed someone else on the local board. Maybe they needed some people at

8 that time, but I don't remember attending sessions of the local board.

9 Q. Let's move on. Now, sir, at the end of this paragraph 6, you

10 say:

11 "I can say with certainty that the policy led by the SDS in Kljuc

12 did not envisage any ethnic cleansing of non-Serb population."

13 Now, in the same paragraph you also refer to panic and chaos in

14 Kljuc, and you say that not only the Muslims and the Croats left but the

15 Serbs did, too, and that everyone could choose whether to go or to stay.

16 Now, focusing on those Muslims that did leave Kljuc, there is evidence in

17 this case that on the 4th of November, 1992, Vinko Kondic informed

18 General Mladic that about 2.000 Muslims were living in Kljuc municipality

19 at the time and that there used to be 17-and-a-half thousand. And that's

20 P356, page 124.

21 Now, sir, you were aware that such large numbers of non-Serbs, of

22 Muslims were leaving Kljuc during 1992; correct?

23 A. Yes. I would notice that only when I would come on home leave.

24 I don't know for what reason, but everyone could see and find out talking

25 to friends that people were leaving. There were also Muslims, my former

Page 32707

1 schoolmates, who stayed there throughout the war, and I would inquire

2 about our common friends. They would say they left to Czechoslovakia or

3 Slovenia. In any case, many people I used to know were no longer there.

4 Q. Now, focusing on those persons that left Kljuc, it was the policy

5 of the Kljuc Municipal Assembly that if you wanted to leave Kljuc, then

6 you could only do so on the basis that you would agree never to come

7 back; correct?

8 A. I was not aware of such a policy.

9 Q. Well, I'd like to look at a document in connection with this.

10 MR. JEREMY: Could we please see 65 ter 31892.

11 And while this is coming up on the screens, I will tell the

12 Chamber that this is another version of document D430, tendered by

13 Defence, which we recently looked at in connection with GRM014.

14 Q. And, sir, we see on the front page that this is a decision made

15 at a session held on the 30th of July, 1992, of the War Presidency of the

16 Kljuc municipality.

17 MR. JEREMY: If we could go to the second page, please. Sorry,

18 and the third page. The last page, please.

19 Q. And we see that the document has a document number and this is

20 dated, unlike Exhibit D430. And, sir, we see that it's signed or the

21 type signature of the War Presidency president, Jovo Banjac.

22 MR. JEREMY: Could we go back to the first page, please.

23 Q. So, sir, directing your attention to article 1 of this decision,

24 we see a reference to voluntary departure of the territory being allowed

25 under certain conditions as determined in this decision. Now focusing

Page 32708

1 your attention on article 2, we see that permanent departure with

2 families shall be allowed to persons who exchanged their real estate with

3 persons from the areas to which they are moving. We see the exchange of

4 real estate must be carried out previously or not later than 3 months

5 after the move, otherwise Kljuc municipality shall take over the real

6 estate.

7 Now, Mr. Volas, would you agree with me that despite the fact

8 that this decision refers to voluntary departure, if you are only

9 permitted to depart a place if you agree never to come back to and never

10 to return to your real estate, then such departure cannot be accurately

11 described as voluntary? Would you agree with that position I'm putting

12 to you?

13 A. I don't know much about these legal principles. And I know

14 absolutely nothing about the work of this authority, this War Presidency.

15 My involvement was in military units. I cannot give you an opinion of

16 whether this is proper or not. I don't know what to say to this

17 question.

18 JUDGE ORIE: Mr. Jeremy, the witness told us that he has no

19 knowledge about a certain policy. Now you take him to a document on

20 which apparently this policy is subject of a decision, and you start

21 asking him whether the wording here, "voluntary departure," is

22 appropriate in this context. What ...

23 MR. JEREMY: Your Honours, in the witness's statement, in

24 paragraph 6, he states:

25 "As I have already said, everyone could choose whether to go or

Page 32709

1 to stay."

2 This document directly impeaches that point, which is why I have

3 put it to the witness.

4 JUDGE ORIE: Yes. Well, the witness saying that he isn't aware

5 of such a policy, of course, undermines what he says in paragraph 6. I

6 mean, where there is no source of knowledge in whatever way, it's a

7 sweeping statement. That's it. And now to analyse with him the language

8 of the text of the decisions doesn't assist the Chamber.

9 Please move on.

10 MR. JEREMY: Thank you, Your Honours. I tender that document as

11 the next Prosecution exhibit, and I have no further questions for the

12 witness. Thank you, Your Honours.

13 JUDGE ORIE: Madam Registrar.

14 THE REGISTRAR: Your Honours, 31892 receives number P7188.

15 JUDGE ORIE: And is admitted into evidence.

16 Mr. Jeremy, the 30 minutes are not over yet, I think. But if you

17 could give us a clue.

18 MR. JEREMY: Your Honours, I have finished my cross-examination.

19 I have no further questions. I will --

20 JUDGE ORIE: The 30 minutes -- you said within 30 minutes you

21 would tell us whether a certain document --

22 MR. JEREMY: Yes.

23 JUDGE ORIE: -- was already in evidence.

24 MR. JEREMY: I can give you what I hope is more than a clue. We

25 have not been able to find another version of this document in evidence.

Page 32713

1 parties, questions put to you by the Bench. I wish you a safe return

2 home again and you may now follow the usher.

3 THE WITNESS: [Interpretation] Thank you.

4 [The witness withdrew]

5 JUDGE ORIE: My question to the Defence is whether the Defence is

6 ready to call its next witness?

7 MR. LUKIC: We are just discussing it, Your Honour.

8 JUDGE ORIE: Yes. Would the Defence be ready to call its next

9 witness after a break?

10 MR. LUKIC: This witness came only yesterday, late afternoon, so

11 I did see him for a quite period of time. And as you know, he's seeking

12 a protective measures, so mostly we spoke about that. But maybe if I see

13 him, if he would be brought here, and if I see him maybe we can discuss

14 his testimony today but after the break then.

15 JUDGE ORIE: Yes. And would you then need a bit of a longer

16 break so that -- well, let's say, that one hour would remain? We could

17 then take a break of half an hour.

18 MR. LUKIC: It would be appreciated it.

19 JUDGE ORIE: We would then resume at quarter past 1.00 and

20 continue until quarter past 2.00.

21 MR. LUKIC: That would be appreciated, Your Honour.

22 JUDGE ORIE: Then I can -- I nevertheless use the time. But,

23 Mr. Lukic -- well, of course, you're the only one -- only counsel being

24 present, I'll try to do it. Or unless under special circumstances, the

25 Chamber would allow you to leave and I then read two decisions which will

Page 32714

1 be then on the record.

2 Under those circumstances, you are excused.

3 I see that Mr. Mladic is represented by two members of the

4 Defence team, Mr. Ivetic and Mr. Sasa Lukic. And I promise you the only

5 thing I'll do is to read two decisions.

6 Yes, I'll start with a decision on the remaining issues with

7 regard to document D759.

8 The Chamber will now deal with some remaining issues with regard

9 to documents D759 tendered during the testimony of Witness Puhalic on the

10 10th of November of last year and currently marked for identification.

11 But first I'd like to note on the record that the transcript of

12 29th of January, 2015, states that the Defence referred to document D758

13 instead of D759. And the decision is about D759. This can be found at

14 transcript page 30885.

15 Secondly, on the 10th of February, the Chamber was informed via

16 an e-mail by the Defence that the translations of the two versions of

17 document D759 are now available and have been uploaded into e-court. The

18 translation of the typewritten version of the statement received

19 doc ID 1D19-1256, and the translation of the handwritten version received

20 doc ID 1D19-1259.

21 The Prosecution replied on the same day via e-mail that it did

22 not have any objections to the translations.

23 And Madam Registrar is hereby instructed to replace the old

24 translations with the two new ones in e-court.

25 In that same e-mail, the Prosecution reiterated its objections to

Page 32715

1 D759; namely, that the Defence had failed to lay a sufficient foundation

2 through the witness or otherwise and that the document lacks any stamp,

3 official mark, and signature.

4 At the outset, the Chamber considers that the lack of any stamp

5 or signature does not necessarily bar admission of a document. In

6 paragraph 7 of his witness statement, Witness Puhalic mentions, and I

7 quote:

8 "A confession statement by Senahid Memic, one of the players in

9 the illegal import of weapons into BH or the needs of the Muslim side

10 whose trucks loaded with weapons was intercepted by the police in

11 Hrasnica."

12 The witness was not able to provide the Chamber with any further

13 information regarding the statement-taking process, such as how it was

14 collected or who conducted the interview. In fact, when pressed by the

15 Prosecution on these matters, the witness contradicted himself and gave

16 unclear answers.

17 Further, upon questioning by the Chamber where the document

18 originated from, the Defence merely answered that it was, and I quote,

19 "an exhibit in the Karadzic proceedings."

20 Finally, the Chamber notes that both the handwritten and the

21 typed versions of the document lack any indicia which could corroborate

22 the witness's testimony that it is, in fact, Mr. Memic's confession.

23 Under these circumstances, the Chamber considers that there is

24 not sufficient information before it regarding the provenance of the

25 statement and therefore denies admission of D759 without prejudice. And

Page 32716

1 this concludes the Chamber's decision on this matter.

2 I'll now briefly deal with remaining associated exhibits which

3 were tendered through Witness Veljko Maric, and we'll deliver the

4 Chamber's decision on those exhibits.

5 On the 5th of September, 2014, the Defence filed a motion to

6 admit the written evidence of Veljko Maric, tendering one witness

7 statement and three associated exhibits. In its response of the

8 19th of September, 2014, the Prosecution objected to the admission of all

9 associated exhibits as it does not consider them to be essential to

10 understand the witness's evidence. The associated exhibits are

11 Rule 65 ter numbers 1D4415, 1D4416, and 1D4417.

12 The Chamber admitted the statement into evidence on the

13 29th of September, 2014, as Exhibit D730. The Chamber will now consider

14 the admission of the associated exhibits.

15 The Chamber recalls that the case law with regard to the

16 admission of associated exhibits pursuant to Rules 92 bis, 92 ter, and

17 92 quater, establishes that documents can be admitted if they form an

18 inseparable and indispensable part of the witness's written testimony.

19 In order to satisfy this test, the tendering party must demonstrate that

20 the witness's statement would be incomprehensible or of a less probative

21 value without the admission into evidence of the associated exhibits in

22 question.

23 The Chamber finds that none of the three associated exhibits meet

24 the above test. In fact, paragraphs 12 to 14 and 21 to 22 of the

25 witness's statement are fully comprehensible and probative without

Page 32717

1 reference to the two associated exhibits bearing 65 ter numbers 1D4415

2 and 1D4416.

3 Similarly, the Chamber considers paragraph 23 to be

4 comprehensible and probative without the admission of the associated

5 exhibit bearing 65 ter number 1D4417.

6 The Chamber therefore denies the admission of all three

7 aforementioned associated exhibits. And this concludes the Chamber's

8 decision on this matter.

9 We take the break and will resume at quarter past 1.00.

10 --- Recess taken at 12.56 p.m.

11 --- On resuming at 1.16 p.m.

12 JUDGE ORIE: Mr. Lukic, the Chamber was informed that you would

13 like to raise the issue of protective measures again.

14 MR. LUKIC: You said "again"?

15 JUDGE ORIE: Yes. We have decided on it, isn't it?

16 MR. LUKIC: I have our motions. I don't have the decision.

17 JUDGE ORIE: Well, I have a look at the decision. The motion is

18 denied. So -- and that decision is of the 24th of February, so you

19 couldn't claim that you did not have sufficient time. Therefore, we

20 would like to move on.

21 MR. LUKIC: Your Honour, then I misinformed the witness.

22 JUDGE ORIE: Then we'll inform him. And perhaps we should do

23 that in private session. But, again, we have decided on the motion.

24 MR. LUKIC: Then ...

25 [Trial Chamber confers]

Page 32728

1 Ms. Penny Marshall made the footage of detainees in Trnopolje, filming

2 from the enclosed area people who were in the open.

3 And that would be a short statement summary, Your Honours. And

4 we do not, as I mentioned, have questions for this witness.

5 I did not provide copies of this to the booth because I did not

6 expect to start in this way.

7 JUDGE ORIE: Copies of your summary, you mean?

8 MR. LUKIC: Yes, Your Honour.

9 JUDGE ORIE: Yes. That is understood.

10 Mr. Traldi, are you ready to cross-examine the witness?

11 MR. TRALDI: I am, Mr. President.

12 JUDGE ORIE: Mr. Solaja, you'll now be cross-examined by

13 Mr. Traldi. You find him to your right. Mr. Traldi is counsel for the

14 Prosecution.

15 MR. LUKIC: Sorry for interrupting, only if we could give the

16 statement to the witness in hard copy. First to be shown to the

17 Prosecution, please.

18 JUDGE ORIE: Yes.

19 THE WITNESS: [Interpretation] Thank you.

20 Cross-examination by Mr. Traldi:

21 Q. Good afternoon, sir.

22 A. Good afternoon, esteemed Prosecutor.

23 Q. Sir, I wanted to start by clarifying one matter that Mr. Lukic

24 mentioned in the summary of your evidence. My understanding of your

25 statement is that you were not present at Trnopolje on the visit when

Page 32729

1 prisoners were filmed behind barbed wire, but that you were present on

2 another visit two days later. Have I correctly understood your evidence?

3 A. Yes, correct.

4 Q. And on that visit on the 7th of August, 1992, you went to Omarska

5 as well as Trnopolje; correct?

6 A. Yes.

7 Q. You mentioned Keraterm in your statement. Is it your evidence

8 that you personally went to Keraterm on that date?

9 A. Yes, with a group of foreign journalists. Mainly British and

10 German.

11 Q. Now, is that the only date when you visited any of those

12 facilities?

13 A. Yes.

14 Q. So your comments about the facilities in terms of your personal

15 knowledge are based on the knowledge you acquired during those visits;

16 right?

17 A. Correct.

18 Q. Sir, I'm going to turn now for the moment to your evidence about

19 the 1st Krajina Corps Press Centre. Now, the press centre was part of

20 the corps' organ for legal, morale, and religious affairs; right?

21 A. That's correct. That was the official name.

22 Q. When you served in the press centre, who was your superior

23 officer?

24 A. Throughout the time, it was Major, later

25 Lieutenant-Colonel Milovan Milutinovic.

Page 32730

1 Q. And who was his superior?

2 A. His superior was Colonel Milutin Vukelic.

3 Q. And the press centre was based in the same building as the

4 1st Krajina Corps command; right?

5 A. No. That press centre was in the building next door, the former

6 house of the JNA, later hall of the Army of Republika Srpska. Today, it

7 is being put to civilian use as the national house of Republika Srpska.

8 Q. In your role in the press centre, you worked with foreign

9 journalists. Now you also made an effort to monitor foreign media,

10 particularly, foreign media coverage of events in the 1st Krajina Corps'

11 area of responsibility; right?

12 A. Correct.

13 Q. And the press centre had an analytical group, including you and

14 Major Milutinovic, who worked on monitoring foreign media; right?

15 A. I was not in the analytical group. I followed foreign media

16 strictly for professional reasons, to follow political movements on the

17 international arena.

18 Q. Now, you say you were not in the analytical group. Who was?

19 A. That group varied in composition. We didn't have systematic

20 monitoring of all information but only political implications of various

21 reports in international media. We did not put out any information for

22 further use except for our own professional use, at least as far as I

23 know.

24 Q. Sir, I appreciate that detail, but you haven't precisely answered

25 the question. Who was a member of that analytical group, if you recall?

Page 32731

1 A. I think it was my colleague, Mr. Radmanovic.

2 Q. And Mr. Radmanovic, was he also an officer in the 1st Krajina

3 Corps in the press centre?

4 A. Yes, like all the rest. I mean, not all of them were officers,

5 but they were mobilised, recruited according to their war assignments

6 into the press centre. Some of them used to be in different units

7 before, but they joined this group later.

8 Q. And when you say this information was for your professional use,

9 one of the professional uses it was put to was that the superior

10 officers, Major Milutinovic and Colonel Vukelic, were kept apprised of

11 relevant foreign media; right?

12 A. Of course. That's customary. It's about political analysis.

13 It's public information available to everyone. We just summarised it.

14 Q. Now, the press centre of the 1st Krajina Corps also published

15 bulletins; right?

16 A. In fact, there was a bulletin of the 5th Banja Luka Corps of the

17 JNA, then it became the bulletin of the 1st Krajina Corps of the Army of

18 Republika Srpska. And beginning with issue number 11, it was called

19 "The Soldier of Krajina," and these were public media, public

20 information. It was distributed across the units of the 1st Krajina

21 Corps.

22 Q. In that bulletin, the press centre published articles asserting,

23 for instance, that the Serbian people had to organise militarily to

24 protect its ethnic identity; right?

25 A. Well, there was that kind of thinking, too. But it falls in

Page 32732

1 under an absolute debate about the future of ethnic identity. There were

2 different ideas also published by "The Soldier of Krajina," because we

3 were -- I mean, there were intellectuals from that area who also

4 publicised their views which didn't always coincide with the prevailing

5 political views and all that has been proved.

6 MR. TRALDI: Can we have 65 ter 32142.

7 THE REGISTRAR: I kindly ask counsel to release the document in

8 e-court.

9 MR. TRALDI: I'll be relying on my colleague, of course, for

10 which we're probably all better off.

11 Q. Now, what we see on the screen, this is the 1st Krajina Corps

12 bulletin from 28 June 1992. We see an article entitled: "Defending

13 Krajina." And in the first paragraph of the text, we read:

14 "The decision of the FRY to pull the JNA out of Bosnia and

15 Herzegovina and the many failures in the organisation and execution of

16 the combat operations in the Serbian Republic of Krajina, forced the

17 Serbian people to organise themselves for defence and thus to protect

18 their own ethnic identity."

19 So this is an example of the bulletin publishing an article

20 asserting that the Serbian people had to organise militarily to protect

21 their ethnic identity; right?

22 A. I don't understand the question. Could you be more precise?

23 Should I comment on the content of the bulletin and this article or the

24 fact that it was published? I'm asking this question because I came to

25 the press centre of the 1st Krajina Corps 17 days later.

Page 32733

1 Q. Sir, you understand this to be a publication of the 1st Krajina

2 Corps press centre, the 1st Krajina Corps bulletin; right?

3 A. Yes, of course.

4 Q. And in this issue of a publication by the 1st Krajina Corps press

5 centre, it is publishing the assertion that the Serbian people have to

6 organise militarily to protect their ethnic identity; right?

7 A. Well, that claim was published. I cannot deny that. I did not

8 write this.

9 Q. And we will look at, I expect, an article or two that you have

10 written yourself, but we may look at other articles from the press

11 centre. If I'm asserting that you wrote an article yourself, I'll

12 identify that at the beginning of my questions about that article so that

13 you're aware. But otherwise, you can take it that we're not asserting

14 you wrote it yourself.

15 While this is on the screen, the press centre co-operated closely

16 with the civilian press including, for instance, Glas and Banja Luka

17 Television; right?

18 A. Right.

19 Q. And part of the press centre's mission was to gather and document

20 evidence of crimes against Serbs; right?

21 A. We did not have that mission officially. Only that information

22 that became available to us within the framework of our normal

23 journalistic work. For that kind of analysis and gathering of

24 documentation, there were other institutions. But as journalists, we

25 certainly did come by some information.

Page 32734

1 MR. TRALDI: If we could have page 2 in the English in the middle

2 of the page, and the top of the fourth column in page 1 in the B/C/S.

3 Q. We read that, in pertinent part:

4 "According to the changes that have taken place in the

5 1st Krajina Corps, co-operation with the Press Centre of the 1st Krajina

6 Corps is going on. Its basic task is to gather important news about the

7 life, work, and combat operations of the Corps and to present it to the

8 local and world public ..."

9 And it explains that this will create conditions for objective

10 monitoring of the activities of the Army of the Serbian Republic of

11 Bosnia and Herzegovina. It then says:

12 "During the last year of the war, almost 300 reporters, cameramen

13 and photojournalists from 52 local and 53 world agencies passed through

14 the Press Centre, speaking of the genocide against the Serbian people and

15 showing a very different picture about the causes of the war and its

16 consequences ..."

17 And at the end of the next paragraph, we read that:

18 "The centre has turned into the centre for the gathering of

19 appropriate testimonies about the genocide against the Serbian people,

20 which is presented in a proper way to the domestic and world public ..."

21 That was part of the centre's mission, wasn't it?

22 A. As I said, at that time I wasn't there and I did not participate

23 in writing this text. Although I agree with the professional part, where

24 the press centre served as a service for communicating with the public,

25 and in that role, it enabled both domestic and professional media to do

Page 32735

1 their job as professionally as possible. And I did not take part at all

2 in defining the role of the press centre as I said. I joined later.

3 Q. Sir, I'm not accusing you of defining the role of the press

4 centre, to whatever extent that would be an accusation. What I'm asking

5 you is: You're aware, weren't you, that part of the press centre's job

6 was to record information about crimes against Serbs and communicate that

7 information to the international media, among others; right?

8 A. Of course.

9 MR. TRALDI: Your Honours, I'd tender 65 ter 32142.

10 JUDGE ORIE: Madam Registrar.

11 THE REGISTRAR: Your Honours, the document receives number P7190.

12 JUDGE ORIE: And is admitted into evidence.

13 Please proceed.

14 MR. TRALDI: Can we have 65 ter 32144.

15 Q. As it comes up, this is an article from Krajiski Vojnik dated

16 June 1993. And this one will reflect that it's authored by you.

17 A. Could we make it a bit larger?

18 JUDGE ORIE: Any specific portion, Mr. Traldi, you would like to

19 focus on?

20 MR. TRALDI: I would. If we could have page 2 in the English and

21 right-most column of page 1 in the B/C/S. And as we turn in the English,

22 this will be an interview with General Talic, the corps commander,

23 entitled: "Serbs are the noblest people."

24 Q. And we see that you are asking him about Operation Corridor.

25 First, in your question --

Page 32736

1 JUDGE ORIE: Could the part in B/C/S be still further enlarged.

2 MR. TRALDI: It's in the middle of the last -- of the right-most

3 column in the B/C/S.

4 JUDGE ORIE: And we just should zoom in only on the middle part

5 of the most-right column and perhaps enlarge that even more. Yes. This

6 is what you --

7 MR. TRALDI: That's what my notes reflect, so hopefully ...

8 JUDGE ORIE: Yes, well ...

9 MR. TRALDI: It may actually -- I may actually have one question

10 after the one that I meant to have. I see the reference to Operation

11 Corridor but I think it's the previous question about Operation Corridor

12 and I apologise.

13 So if we could move one column to the left. And scroll down.

14 I'll return to the topic when my notes are a little bit more precise on

15 this.

16 Q. And I'll return, in our brief time remaining today, sir, to your

17 visit to Prijedor. To get from Banja Luka to Prijedor you went through

18 the Kozarac area; right?

19 A. Correct.

20 Q. What did you see when you passed through there?

21 A. We saw destroyed houses.

22 Q. And destroyed and damaged mosques; right?

23 A. Those were ruins. I did not distinguish between the two.

24 Q. And Ostoja Barasin, one of your colleagues, he went on the same

25 visit you did, right?

Page 32737

1 A. Barasin.

2 Q. I appreciate you correcting my pronunciation. Sorry, go ahead,

3 sir.

4 A. I mean, no, we never went together.

5 Q. Now, you mentioned -- or -- you mentioned you also went to

6 Omarska. Were you aware that reporters had previously been denied access

7 to Omarska by the press centre?

8 A. No.

9 MR. TRALDI: Can P2890 be brought to the screen.

10 Q. This is an article by Roy Gutman, who you discuss in your

11 statement, entitled: "There is No Food, There is No Air."

12 MR. TRALDI: If we could turn to page 2 in both languages.

13 Q. We read in the third paragraph from the bottom in both languages:

14 "Military authorities and the local Red Cross acknowledged the

15 existence of a camp at Omarska but rebuffed requests to visit it. 'There

16 are places where Muslim extremists have been gathered,' said

17 Major Milovan Milutinovic," who it describes as "the spokesman for the

18 former Yugoslav Army, which has renamed itself the Serbian Army of

19 Bosnia."

20 And then it quotes him as saying:

21 "'But I think they have already been moved.'"

22 Now, this is dated the 19th of July, 1992. You're aware, as you

23 sit there today, that there were still a large number of prisoners at

24 Omarska on the 19th of July; right?

25 A. I don't know whether there were many. I saw some when I visited

Page 32738

1 on the 7th of August.

2 Q. And does this refresh your recollection as to whether before your

3 visit, officers from the 1st Krajina Corps Press Centre had rebuffed

4 journalists' requests to visit Omarska camp?

5 A. I don't know about that because I was not directly involved in

6 issuing permits for their movement in the area of responsibility of the

7 1st Krajina Corps. Because my profession as journalist, I worked

8 strictly in that job.

9 Q. But you certainly --

10 JUDGE ORIE: Mr. Traldi, could I seek clarification of one of the

11 previous answers.

12 You said you saw some prisoners in Omarska on the 7th of August.

13 Do you have any knowledge about, well, let's say, ten days before that

14 date or -- about numbers of prisoners in Omarska?

15 THE WITNESS: [Interpretation] No.

16 JUDGE ORIE: Please proceed.

17 MR. TRALDI:

18 Q. You said you weren't directly involved in issuing permits.

19 Certainly having accompanied journalists on visits to camps, you were

20 aware journalists required permits from the press centre; right?

21 A. That's right.

22 MR. TRALDI: Your Honours, I see the time.

23 JUDGE ORIE: Yes, so do I.

24 Mr. Solaja, we will adjourn for the day. And since we never sit

25 on Friday, we'll only recommence on next Monday, 9.30 in the morning. We