Tribunal Criminal Tribunal for the Former Yugoslavia

Page 27512

 1                           Wednesday, 29 October 2008

 2                           [Open session]

 3                           [The accused entered court]

 4                           [The witness entered court]

 5                           --- Upon commencing at 2.21 p.m.

 6             JUDGE AGIUS:  Good afternoon, Madam Registrar.  Could you kindly

 7     call the case, please.

 8             THE REGISTRAR:  Good morning, Your Honours.  This is the case

 9     number IT-05-88-T, The Prosecutor versus Vujadin Popovic, et al.

10             JUDGE AGIUS:  I thank you so much, ma'am, and good afternoon,

11     everybody.  All the accused are here.  Prosecution is in full force

12     today:  Mr. McCloskey, Mr. Thayer, Mr. Mitchell.

13             Amongst the Defence teams, I notice the absence of Ms. Nikolic

14     and Mr. Haynes.

15             Good afternoon to you, Mr. Simic.

16             THE WITNESS: [Interpretation] Good afternoon.

17             JUDGE AGIUS:  Welcome back.  I hope you've had time to relax.  We

18     are going to continue and hopefully finish with your testimony.

19             Mr. Lazarevic.

20             MR. LAZAREVIC:  Good afternoon, Your Honours.  Good afternoon,

21     everyone.

22                           WITNESS:  SLAVISA SIMIC [Resumed]

23                           [Witness answered through interpretation]

24                           Examination by Mr. Lazarevic: [Continued]

25        Q.   [Interpretation] Good day, Mr. Simic.

Page 27513

 1        A.   Good day.

 2        Q.   We'll now continue with your examination.  And if you remember,

 3     yesterday we were talking about the 14th of July, 1995.  That's the last

 4     subject we were talking about, and to refresh our memories --

 5             MR. LAZAREVIC: [Interpretation] -- could we see 4D620 in the

 6     e-court system, again.  Page 28, please.  And naturally, we can see the

 7     entry here for the 14th of July.  Could we perhaps zoom in a little bit,

 8     and could we scroll down a bit.  That's fine.

 9        Q.   Can you now see the entry for the 14th of July?  It says on the

10     13th, you went there -- from the 18th to 24, and that continues on the

11     14th from 00 to 06; is that correct?

12        A.   Yes.  That's the information that -- could I have the date?

13             MR. LAZAREVIC: [Interpretation] Could we scroll down a bit -- the

14     other page.  I apologise.

15        Q.   So I think we can now see from 00 to 06.  It's quite clear here

16     now.  Can you tell me, on the 14th of July, in the morning -- well, how

17     long did you stay in the police station?

18        A.   Well, look.  Upon finishing my shift in the early morning hours

19     on the 14th, I returned home to have a rest.

20        Q.   Very well.  So you had a rest at home.  Do you remember an event

21     that you witnessed on the 14th of July?

22        A.   On that day, having had a rest at home I was present at the

23     funeral of our colleague who had died.  His name was Zeljko Ninkovic.

24     According to our customs, a funeral is held at about 13 or 1400 hours, so

25     I was at the funeral.

Page 27514

 1        Q.   Very well.  Apart from yourself, can you tell me whether there

 2     were any other members of the Bratunac police station who attended Zeljko

 3     Ninkovic's funeral?

 4        A.   Yes.  As far as I can remember, a certain number of members of

 5     the Bratunac police station from the 1st company were present because

 6     they fired in honour of the deceased colleague; they fired shots.

 7        Q.   Very well.  Apart from them, were there any other members of the

 8     Bratunac police station who were perhaps there?

 9        A.   Certainly.  To the extent that they had the time to attend, there

10     were such other members.

11        Q.   Tell me, after the funeral, where did you go?

12        A.   Well, look.  After the funeral of the deceased, as a rule in our

13     country you go to the family's home to express your condolences for the

14     deceased.  So after that funeral, I spent some time in his home, and then

15     I returned to my home, put my uniform on, and returned to work, and I

16     spent that day at work too.

17        Q.   Very well.  I would like to ask you something about certain

18     events.  You have already told us about your movements on the 14th.  Can

19     you tell me whether on that day you had the opportunity to perhaps see

20     some senior MUP officials in Bratunac?

21        A.   I personally didn't see any such officials, but I heard that on

22     that day there was a high-ranking MUP official who was present, Tomo

23     Kovac.  I didn't see him myself, I heard about his presence from my

24     colleagues.  And later on when I arrived at work, they told me that he

25     had visited the Bratunac police station and that he was on the his way to

Page 27515

 1     Srebrenica.  But I personally did not see him.

 2        Q.   Very well.  Tell me, now, did you at any point in time hear

 3     anything about an incident that took place in the agricultural

 4     cooperative in Kravica?

 5        A.   I heard about an incident in that agricultural cooperative or

 6     association in Kravica, so-called Oka.  According to the information I

 7     received, according to what I was told, some Muslims had been detained in

 8     that building.  They had surrendered at the time, and there were quite a

 9     lot of them.  At one point in time, some of them attempted to escape from

10     the building, and they managed to take the rifle from a policeman.  I

11     heard that that policeman died, but I don't know which police station he

12     was from.  That's all that I heard about the event that you are

13     interested in.

14        Q.   Can you tell me who you heard this from?  If you can remember,

15     naturally.  Was this something that was discussed in Bratunac?

16        A.   Well, yes.  There were rumours, stories that circulated among the

17     population, among the citizens at the time; and on the 14th, I heard

18     about this when I attended the funeral.  They discussed the death of our

19     colleague and this event in Oka.  A number of Muslims were killed on that

20     occasion.

21        Q.   And tell me, is this all the information you have about the

22     event?

23        A.   Yes.  I have no other information about the event.

24        Q.   Tell me, on that day - we've been speaking about the 14th - on

25     that day, did you have the opportunity of seeing Mr. Borovcanin?

Page 27516

 1        A.   Not on the 14th.  Not on the 14th.  That's certain.

 2        Q.   And on the following days, on the 14th -- on the 15th, 16th, and

 3     17th, did you see him on those days, perhaps?

 4        A.   No.  No, I didn't.

 5        Q.   And tell me, during that period, during those days, as far as

 6     your work in the police station is concerned, is there anything in

 7     particular that you can remember in the police station?

 8        A.   Well, look.  Every day we had our duties.  As far as I was

 9     concerned, I went to work.  I performed my duties.  I was still working

10     for my service.  After the fall of Srebrenica, quite a few troops had

11     retreated from the lines, returned home.  There was no more tension at

12     the lines, so days passed by, you know, fairly regular men [as

13     interpreted].  I don't know what else I could add.

14        Q.   Very well.  Can you now tell me, can you remember when you

15     established contact with members of Mr. Borovcanin's Defence team?

16        A.   I think that was this year around July and September, I believe.

17     There were two occasions on which there was contact up until the time I

18     came to The Hague.

19        Q.   Very well.  I would just like a minor correction to be introduced

20     for the sake of the transcript.  It's on page 5, line 12.  In English, it

21     says "fairly regular men," whereas it should say "fairly regular days."

22             JUDGE AGIUS:  Thank you, Mr. Lazarevic.

23             MR. LAZAREVIC: [Interpretation]

24        Q.   So you had those two brief meetings in July and September and

25     then again when you had the opportunity to see Mr. Borovcanin's Defence.

Page 27517

 1     I'd just like this to be clear for the transcript.

 2        A.   As I have said, upon arriving in The Hague.  I think that was on

 3     Saturday afternoon and on Sunday, too.  So that would be the time.

 4             MR. LAZAREVIC: [Interpretation] Very well.  Thank you, Mr. Simic.

 5     I have no more questions for you.

 6             THE WITNESS: [Interpretation] Thank you.

 7             JUDGE AGIUS:  Mr. Zivanovic.

 8             MR. ZIVANOVIC:  No question for the witness.

 9             JUDGE AGIUS:  Thank you.  Mr. Ostojic.

10             MR. OSTOJIC:  No questions, Mr. President.

11             JUDGE AGIUS:  Thank you.  Mr. Bourgon.

12             MR. BOURGON:  No questions, Mr. President.

13             JUDGE AGIUS:  Thank you, Mr. Bourgon.  Madam Fauveau.

14             MS. FAUVEAU: [Interpretation] No further question, Your Honour.

15             JUDGE AGIUS:  Thank you.  Mr. Josse.

16             MR. JOSSE:  Same, Your Honour.

17             JUDGE AGIUS:  Thank you.  Mr. Sarapa.

18             MR. SARAPA: [Interpretation] No questions.

19             JUDGE AGIUS:  Thank you.  Mr. McCloskey, how long do you expect

20     your cross-examination to last?

21             MR. McCLOSKEY:  It's difficult to say.  I hope no longer than an

22     hour.

23             JUDGE AGIUS:  Okay.  Go ahead.

24             MR. McCLOSKEY:  Good afternoon, everyone.

25                           Cross-examination by Mr. McCloskey:

Page 27518

 1        Q.   Good afternoon, Witness.

 2        A.   Good day.

 3        Q.   In one of the last questions, it was suggested in the question

 4     that you first contacted the Defence counsel.  Is that correct?

 5             JUDGE AGIUS:  Mr. Lazarevic.

 6             MR. LAZAREVIC:  I never suggested that.  I mean, this is really

 7     not that --

 8             JUDGE AGIUS:  Mr. McCloskey.

 9             MR. McCLOSKEY:  You can read the transcript, and that's why I

10     asked it the way I did.

11             MR. LAZAREVIC:  Then I should, please.

12             MR. McCLOSKEY:  He's been very good at correcting the transcript,

13     so I'm kind of shocked he missed it this time.

14             JUDGE AGIUS:  Wait one moment because I heard a mobile phone

15     ringing.  Whoever it is, please switch it off.  Yes, Mr. -- "Can you now

16     tell me, can you remember when you established contacts with members of

17     the Borovcanin Defence team?"  That's how it was put, anyway.

18             Let's not make a storm in a tea cup on it or an issue on it.

19             Mr. Simic, go ahead.  Try to explain to us what happened.  Were

20     you contacted by the Defence team for Mr. Borovcanin and you then met --

21     did you ask for a meeting with the Defence team?  How was it?

22             THE WITNESS: [Interpretation] Mr. Borovcanin's Defence contacted

23     me.  I didn't have the need to contact the Defence.  They contacted me.

24             JUDGE AGIUS:  All right.  It's clear now.  So let's move ahead.

25             MR. McCLOSKEY:

Page 27519

 1        Q.   And did they tell you how they got on to you, how they were able

 2     to identify you as a person to contact?

 3        A.   Well, I don't know how they work, how they reached me, but I know

 4     that these people contacted me.  They probably had some reasons for which

 5     they contacted me.

 6        Q.   That's my question.  Do you know the reasons?

 7        A.   Well, I assume that the reasons can be found in the testimony I

 8     have given so far.

 9        Q.   Sir, do you know why they contacted you?  It's not in the

10     testimony, how they knew to contact you.

11        A.   The question is not clear to me.  I think I have answered that

12     question.

13             MR. McCLOSKEY:  This may be, Mr. President, longer than I

14     thought.

15             JUDGE AGIUS:  When we asked, it was not meant to restrict you,

16     Mr. McCloskey.  We'll decide what to do as you go along.

17             MR. McCLOSKEY:

18        Q.   Sir, you have told us that you were the duty officer that day.

19     Can you tell us how it was that the Borovcanin team was able to find out

20     that you were a possible witness?

21        A.   I don't know how they obtained the documents that have been

22     presented here, but these documents confirm the time-period during which

23     I acted as a duty police officer.  I assume that that's why they called

24     me to testify here.

25        Q.   Had you received any communication from Mr. Borovcanin, any

Page 27520

 1     friends or family before they contacted you?  It's perfectly normal that

 2     someone -- that a colleague of his may have called up and said, Would be

 3     willing to be a witness for your former boss?  Did that happen, anything

 4     like that, before the Defence contacted you?

 5        A.   No.  Nothing of the kind happened.  I didn't have any contact

 6     with the friends or family of Mr. Borovcanin.  I was only contacted by

 7     Mr. Lazarevic.

 8        Q.   Did you follow Mr. Borovcanin's testimony in the state court in

 9     the case against people for the Kravica murders?

10             JUDGE AGIUS:  Did you say Borovcanin's testimony?

11             MR. McCLOSKEY:  Yes.

12             JUDGE AGIUS:  All right.  Okay.

13             MR. McCLOSKEY:

14        Q.   The very recent testimony.

15        A.   No.  I didn't have the opportunity to follow the proceedings.

16        Q.   Well, did you know that there was a big trial going on in

17     Sarajevo for the Kravica incident of 13 July where Mr. Borovcanin had

18     testified?

19        A.   The trial was held in Sarajevo.  I was aware of the fact through

20     the media, but I personally did not follow the trial by watching

21     television or reading the papers, listening to the radio.

22        Q.   Well, you must have spoken about it with your friends, fellow --

23     you had fellow MUP officers on trial in that case.

24        A.   As I have said, I personally didn't follow the trial on

25     television.  I could read about it in magazines, or I could read about

Page 27521

 1     certain details that concerned the trial in magazines, but I never had

 2     occasion to comment on the entire trial with anyone because during that

 3     period of time when the trial was held in Sarajevo, I was too busy at

 4     work.  Given the fact that I no longer live in the area of Bratunac - I

 5     have to travel to work - and given the fact that I have family

 6     obligations, I don't have enough time to follow the media coverage of the

 7     trial, and that concerns the trial in The Hague and the trial in

 8     Sarajevo.

 9        Q.   You've been a police officer for many years now.  Have you ever

10     testified in any court aside from this one?

11        A.   No.  I've never testified.

12        Q.   Okay.  And before coming to testify and after you were contacted

13     by the Borovcanin Defence, did you make any effort to find any documents

14     or records that might help you make you remember or help you remember the

15     events of July 1995?

16        A.   I did not find any documents, nor do I possess any documents with

17     regard to this.  I've told you what I remember, and these were the events

18     that I witnessed; I was present.

19        Q.   And did you look for any documents that might help you?

20        A.   No.  I did not think that they would be necessary at all.

21        Q.   Well, certainly there was a duty officer notebook that you would

22     have and other duty officers would have taken notes at during the day

23     while you were on duty, wasn't there?

24        A.   I apologise, sir.  Which duty officer are you referring to in

25     your question?

Page 27522

 1        Q.   You.

 2        A.   I'm asking this because there is also a duty operations officer

 3     at the centre level, and the duty police officer operates in the police

 4     station in Bratunac.  Duty service does involve recording certain events

 5     but mostly reports filed by citizens about certain events.  But I did not

 6     think that it would be necessary for me to have any of these documents

 7     available to me for this trial.

 8        Q.   So tell us about the duty officer notes that are kept at the

 9     Bratunac SJB in July of 1995, complaints from -- you've said complaints

10     from civilians?  I would think important calls from commanders, other

11     things that you needed to remember.  All of us take notes when we pick up

12     the phone.  This went into a book, I take it?

13        A.   Yes.  Complaints, either personal complaints or complaints over

14     the phone about certain problems or incidents; for example, if somebody

15     broke into somebody else's house or somebody got drunk and opened fire

16     from a firearm, somebody had a row with their wife.  These were the kind

17     of incidents that we recorded because they mandated the police to act

18     upon them.

19        Q.   So if people got -- if you got a report of shots at the Oka

20     warehouse, the police would be mandated to act on that?

21        A.   Well, I never received such report.  There is no way for me to

22     know what was happening in Kravica.  It was only the following day at the

23     funeral that I learned about the event, and it was after my duty -- when

24     I got off work the following day, I learned about the events that had

25     taken place at Kravica.

Page 27523

 1        Q.   Well, you must have then, as soon as you learned about it, called

 2     the duty officer and reported it to him, then, something of that

 3     significance.  We have a Serb getting killed, for instance.

 4        A.   No, I didn't call him when I learned that because I fully believe

 5     that he had already been informed.

 6        Q.   And so this duty book would have had that information in it, had

 7     the system been worked properly, receiving the complaint, noting it down,

 8     and acting upon it?

 9        A.   I did not see any such thing as having been entered in the

10     logbook.

11        Q.   So you had a chance to review the logbook when you came back on

12     duty for the days that you weren't there or the days that other people

13     would have written stuff down?

14        A.   This was the logbook that we used every day, but this was not

15     recorded.  I did not read it.  I don't know whether the person working

16     before me had had any information to that effect or not.

17        Q.   What did you call this logbook?

18        A.   A diary, the logbook of daily events of the duty police service.

19        Q.   And can you tell us what it was made out of?  Was it a

20     leather-bound book?  How many pages?  How many days would it normally

21     have?

22        A.   Well, it was a book of a record of a larger size, a hard cover.

23     I don't know what colour, and I can't even remember that the pages were

24     numbered.  It was a somewhat thick notebook.  There were various things

25     to be entered:  What happened, who filed the complaint or report, show a

Page 27524

 1     description of the event or the incident, and which policeman was tasked

 2     to act upon the complaint, and that was all.

 3        Q.   Did you tell the Defence about this logbook when you spoke with

 4     them?

 5        A.   No.

 6        Q.   Did they ask you about any potential logbook or other diaries or

 7     records that -- of that time period?

 8        A.   They didn't have to ask me because the records are kept at the

 9     police stations, and the superior officers of the police stations are

10     responsible for them.

11        Q.   So they never even asked you about any records or logbooks or

12     anything like that, any reports you might have made or somebody else

13     might have made on any of these events?

14        A.   They didn't ask me about the logbook of events kept by the duty

15     police officer.

16        Q.   Any other records?  Did they ask you about any -- if there was

17     any records?

18        A.   Well, the only ones are the lists of shifts that we have seen in

19     the courtroom.  That's the only type of document that I know of that they

20     have asked me about.

21        Q.   All right.  Where should that logbook be, the diary be today for

22     July of 1995?

23        A.   I really don't know where it should be.  I know that SFOR members

24     subsequently seised certain documents.  They searched the Bratunac police

25     station, and I really don't know where the 1995 logbook might have ended

Page 27525

 1     up at.

 2        Q.   Okay, let's go to another area.  You said you, I believe,

 3     reported for duty March 1993, and you met your commander, Mr. Borovcanin,

 4     that day in March sometime, March -- I don't remember the exact day you

 5     told us, 4th, maybe.

 6        A.   Sir, I did not report for duty on the 4th of March, but on the

 7     3rd of March, 1993, I met Mr. Borovcanin for the first time.  He received

 8     me and interviewed me with regard to my application and my joining the

 9     active force of the police at the police station.

10        Q.   Okay.  Now, back in 1993, were Bratunac police officers made

11     available to be part of combat units in those days like we knew they were

12     in 1995?  In 1995 we know they were called PJP units.  Was there a

13     similar thing in 1993?

14        A.   No.

15        Q.   Did the police defend Bratunac in some way in 1993 along with the

16     army?

17        A.   At the time I was still a reservist, a reserve police officer,

18     and active members did have their tasks and duties, but I personally

19     never participated in combat.  Most of the staff patrolled the city.

20     They maintained public law and order, and they were involved in regular

21     policing duties.

22        Q.   You said you were a member of the Bratunac Brigade's Red Beret

23     unit?

24        A.   Yes.

25        Q.   You know Rade Petrovic?

Page 27526

 1        A.   Yes.

 2        Q.   You've known him all your life?

 3        A.   I've known him since July 1992.  I did not know him before that.

 4        Q.   And what was his relation, if any, with the Red Beret unit of the

 5     Bratunac Brigade?

 6        A.   What do you mean when you say "relation"?  Can you rephrase,

 7     please?  Can you put your question in some other way?

 8        Q.   Was he ever a member?  Was he a commander?

 9        A.   While our commander was still alive, he was a member, a foot

10     soldier, just like me.

11        Q.   In the Red Berets?

12        A.   Yes.

13        Q.   And later he became the commander of that unit, correct?

14        A.   I don't know what his duty was later, but I've already told you

15     that I left that unit and I joined the reserve force of the police

16     station.

17        Q.   Sir, are you telling us today that despite your service

18     throughout the war in Bratunac, you do not know Rade Petrovic's position

19     in the Red Berets?

20        A.   What I'm saying is this:  While the commander of the Red Berets

21     was still alive, Rade Petrovic was a foot soldier just like me, and I

22     really don't know what his subsequent duties in the unit were.  I've not

23     seen Rade Petrovic for four or five years.

24        Q.   Do you know a person named Miroslav Stanojevic?

25        A.   I believe I do.

Page 27527

 1        Q.   Do you or don't you?

 2        A.   I know that his nickname is Krle.  I know that he was killed in a

 3     car accident or a traffic accident, but I can't remember what year.  It

 4     happened somewhere in or around Bratunac, if we are talking about the

 5     same person.  If we are, then I know him better as -- by his nickname,

 6     Krle.

 7        Q.   Well, you knew that he was a member of the Red Berets, too,

 8     didn't you?

 9        A.   Well, I was a member of that unit.  He wasn't.  He was not a

10     member.

11        Q.   Well, that wasn't my question, sir.  My question was, did you

12     know that he was a member of the Red Berets, let's say, to make it more

13     specific, in 1995?

14        A.   I can't say anything.  I don't know.  While I was in the unit, I

15     really don't know that he was a member also.  I don't think so.

16        Q.   Surely, sir, you know that he was wounded at the Kravica

17     warehouse at 13 July, the incident you have testified about.  Surely

18     that's a part of the story that you know, correct?

19        A.   I didn't even know that he was wounded.  I never heard about

20     that.

21        Q.   So were you on duty the night of 13 July until the early morning

22     hours of 14 July?  Is that what we just saw up on the screen?

23        A.   13, 14, the night between the two.

24        Q.   Yes.  Was that you on duty, I think, from around midnight to 6.00

25     a.m.?  I just want to make sure I got that right.  There's no trick here.

Page 27528

 1        A.   In the early morning hours, from midnight to 6.00 in the morning

 2     on the 14th, yes.  You're asking me that?

 3        Q.   Okay.  So you were a duty officer at the Bratunac police station

 4     in the centre of Bratunac, then, correct?

 5        A.   Yes.

 6        Q.   Tell us what you learned was going on in the town of Bratunac

 7     that night during that 6-hour time-frame that you were there.

 8        A.   I learned about the death of our colleague, another policeman,

 9     who had been killed in the early morning hours, sometime in the morning.

10     I don't know what else to tell you.

11        Q.   That's it?  That's all you know?

12        A.   At that moment, yes.

13        Q.   You didn't have any information about any Muslims around town?

14        A.   I had information that they were on buses around the school and

15     on the road leading up to the playground, but that's what I heard.  I

16     only heard that.

17        Q.   So would you call it rumours or reports to the duty officer?

18        A.   Public stories.  There were no official reports about that.

19        Q.   So as you sit here today, you don't even know if that's true?

20        A.   I heard about that based on stories, and I also heard that the

21     Muslims in question were guarded by MPs, by members of the military

22     police.  I did not hear anything else, and I did not receive any concrete

23     reports about the same event.

24        Q.   What else did you hear?  We're getting a little bit more here.

25        A.   That's all I heard.  I don't believe there was something else.

Page 27529

 1     The -- the colleague's death was enough to -- to shake me.

 2        Q.   You didn't hear about the 50 Muslims that were murdered that

 3     night, huh?  Maybe a hundred, maybe 200, maybe more.

 4        A.   I've already told you.  I only heard that on the 14th at my

 5     colleague's funeral.  In the evening, when I was on duty as the duty

 6     police officer, I did not have the information about the Muslims having

 7     been killed.

 8        Q.   Surely you must have been aware of the sanitation going around

 9     and scraping up all the dead bodies off the different floors of the Vuk

10     Karadzic school and around the school?  This Court's heard testimony on

11     it.  It's been established in numerous trials.  Never heard anything

12     about all those dead Muslims picked up on the streets of Bratunac and the

13     school of Vuk Karadzic?

14        A.   Sir, there were no killed Muslims on the streets of Bratunac or

15     had I heard.  Whether there were any killings or not, I don't know.

16        Q.   I think we can leave that subject, but just to clarify the

17     record, a close review of the duty officer sheet shows that you were on

18     duty from 12 hours, from 6.00 p.m. on the 13th through 6 a.m. on the

19     14th.

20             Now, let me try to ask you some questions of something maybe you

21     know about because you've testified about it.  You've testified you knew

22     where -- about the -- where the 2nd company PJP went on the 12th of July,

23     right?  You remember that testimony?

24             JUDGE AGIUS:  Yes, Mr. Lazarevic.

25             MR. LAZAREVIC:  Yes, just to assist my colleague.  What I heard

Page 27530

 1     that was translated to the witness was "June."

 2             JUDGE AGIUS:  All right.  Thank you.  But it's July.

 3             THE WITNESS: [Interpretation] On the 12th of July, the 2nd

 4     company set off to Srebrenica in order to establish a police station

 5     there.  So they left Bratunac and went to Srebrenica.

 6             MR. McCLOSKEY:

 7        Q.   How do you know that they went to establish a police station

 8     there?

 9        A.   Well, on the 12th I was at work.  So this information, according

10     to which they had set off there, was conveyed to me.

11        Q.   By who?

12        A.   I arrived in the department.  I received information according to

13     which they had set off in order to establish a police station in

14     Srebrenica.

15        Q.   By who?

16        A.   It was probably from the other duty officer.  The command of the

17     police station in Bratunac set off together with the 2nd company.

18             THE INTERPRETER:  The witness is kindly asked to speak a little

19     more loudly.

20             MR. McCLOSKEY:

21        Q.   Sir, they would like it if you could speak a little more louder.

22     The interpreters have having a heard time hearing you.

23             So it was the normal practice for duty officers to share

24     information about -- important information, for example, what units are

25     going where?

Page 27531

 1        A.   Well, in any event he informed me of the fact.

 2        Q.   Sir, you need to try to answer my questions.  Did you understand

 3     the question?

 4        A.   Sir, when I arrived to do my shift at 1800 hours, I received

 5     information from the previous duty officer that the 2nd company had set

 6     off to Srebrenica, so from the officer who did the shift before mine.

 7        Q.   Okay.  But I'll try with the same question.  Was that the normal

 8     procedure whereby duty officers would share important information with

 9     each other, such as where various units or officers were stationed or

10     other important details?

11        A.   Well, in any event this information was exchanged, information

12     about what happened in the course of his duty.  He conveyed this

13     information to me.

14        Q.   Will you answer my questions about the normal practices and

15     process?  It's a perfectly okay question.  Was that the normal practice

16     and process for duty officers to exchange information?

17             JUDGE AGIUS:  Mr. Lazarevic.

18             MR. LAZAREVIC:  Maybe -- I believe that the answer of the witness

19     was misinterpreted.

20             It's here on page 20, lines 10 to 12.  He -- what --

21             MR. McCLOSKEY:  Can we get on with this?

22             JUDGE AGIUS:  If he's alleging that it was misinterpreted to the

23     witness, we need to hear about it.  Please continue, Mr. Lazarevic.

24             MR. LAZAREVIC:  What is witness said is what he conveyed -- what

25     he conveyed to me -- what he conveyed to me what my duties would be.

Page 27532

 1     That's what the witness said.

 2             MR. McCLOSKEY:  Yeah, we heard that.

 3             MR. LAZAREVIC:  But here it says: "He conveyed this information

 4     to me."  That's a bit different, I think.

 5             MR. McCLOSKEY:  Yeah.

 6             JUDGE AGIUS:  All right.  Anyway, let's take it up from there and

 7     continue, Mr. McCloskey, please.  Thank you, Mr. Lazarevic.

 8             MR. McCLOSKEY:

 9        Q.   Sir, I'm just asking you whether or not it was the normal process

10     for duty officers to exchange information, important information so the

11     new shift was aware of important information.  Is that normal practice?

12        A.   Well, naturally I would ask my colleague, the one on duty about

13     what had happened during his shift, if that's an answer.

14        Q.   Well, I think it would be kind of natural to be curious, but what

15     I'm asking you about is was it a police procedure for the duty officers

16     to exchange information with each other to find out important details of

17     what had happened on the previous shift?  Was this a practice or a policy

18     of some sort?

19        A.   Well, as I have said, he informed me of the fact.  That's usual

20     when you take over a shift.  What he conveyed to me had to do with the

21     records, with whether the vehicles were there or not, details of that

22     kind.

23        Q.   So it was a practice or a policy of the Bratunac police

24     department for the duty officers to exchange important information with

25     each other at the changeover?

Page 27533

 1        A.   Yes.

 2        Q.   And Mr. Vasic was present at the Bratunac police station during

 3     the 11th, the 12th, the 13th when you were a duty officer, right?

 4        A.   He was present at that time during those days because at the time

 5     the Crisis Staff had its headquarters in our police station.

 6        Q.   Right.  And when you learned information such as the information

 7     you just told us, that the 2nd company was sent to Srebrenica, did you

 8     provide that information to Mr. Vasic or anybody else in the police

 9     station for their reports or for police purposes?

10        A.   I assume that they themselves were aware of the fact.  I was only

11     an ordinary policemen at the time and nothing else.  I didn't have the

12     duty to convey information of any kind to them because they were my

13     superiors.  The chief of the centre and the others in the Crisis Staff, I

14     assume that they were aware of the fact that the 2nd company had set off

15     there.

16        Q.   So as the duty officer that day, no one would have ever asked you

17     about what was going on, what information you had received, what might be

18     in the duty book, what someone else might have reported to you?  You're

19     just left alone?  Nobody's talking to you or asking you information

20     within your command structure?

21        A.   Do you have the members in the Crisis Staff in mind who were at

22     the police station?

23        Q.   Anybody.  Vasic or whoever was with him, Josipovic, whoever might

24     have been a sergeant if you had such a thing at the time, Mr. Borovcanin

25     if he happened to ask you a question?  Wouldn't you be giving information

Page 27534

 1     to all these people so they could help get their reports right?  Wouldn't

 2     the duty officer be part of that information process that was so critical

 3     that would eventually have gone up to Zvornik and then from Zvornik gone

 4     up higher and eventually to Pale?  You're a pretty key man on the ground

 5     as the duty officer, weren't you?

 6             MR. LAZAREVIC:  It's a very compound question.  Maybe my

 7     colleague could split it up.

 8             JUDGE AGIUS:  I don't think it will help you much if he splits it

 9     up, Mr. Lazarevic.  Let's proceed.

10             MR. McCLOSKEY:

11        Q.   Can you just answer that, maybe yes or no.  Were you a key man?

12     Let's just leave it at that.  Wasn't the duty officer, an individual SJB

13     like Bratunac at the time, a key person in the communication network?

14        A.   No.  I was just a duty officer.  I had my superiors.

15        Q.   So you don't really know if the 2nd company went -- even went to

16     Srebrenica for real, do you?

17        A.   I am telling you about information I had, information according

18     to which the 2nd company set off on the 12th of July.  They went to

19     Srebrenica in order to establish a police station there.  My commander,

20     from Bratunac, left with members of the 2nd company.

21        Q.   Well, was it ever confirmed to you that they actually went there

22     and they just didn't stop in Potocari or do something else?

23        A.   If something concrete had happened, they wouldn't have informed

24     me of the fact.  They had their own superiors who ranked above them, were

25     superior to me.

Page 27535

 1        Q.   Did all the platoons of the 2nd company go to Srebrenica on the

 2     12th?

 3        A.   I don't know about other platoons, but I know that members of the

 4     2nd company who were from the Bratunac police station set off there.

 5        Q.   Well, you know Nenad Deronjic was a member of the 2nd company,

 6     right?

 7        A.   A policeman, yes.

 8        Q.   So do you know where Nenad Deronjic went on the 12th?

 9        A.   I assume that he set off with his colleagues.

10        Q.   Well, let's look at 65 ter 3040, and since you seem to have some

11     specific information on him -- or excuse me, on this unit, maybe this

12     will help you.  This is a report.  Let me give you a hard copy so you can

13     see the whole thing at once.  I'm sorry.  The last part in this hard copy

14     is not easy to read.  But this is a 12 July report to the Republika

15     Srpska Ministry of the Interior police headquarters in Bijeljina and the

16     officer of the minister in Pale.  And it's in the name of the chief of

17     the CJB, which should be Mr. Vasic.

18             And mostly I just want to ask you about paragraph 5.

19             MR. McCLOSKEY:  So if we could go to paragraph 5.  If we could

20     get that up on the English, paragraph 5.  It should be the first page --

21     yeah, if you could scroll up, and it's page 2 of the B/C/S.  And it

22     actually goes over into page 6 as well.  So -- I don't know if we can do

23     that, but -- I'll read paragraph 5 slowly just so there's no worry.

24        Q.   "Acting upon the President Karadzic's order, which was conveyed

25     to us today over the phone, the 2nd Company of the Zvornik PJP shall be

Page 27536

 1     dispatched to Srebrenica with a task to secure all facilities of vital

 2     importance in the town at all cost and protect them from looting and

 3     misappropriation.

 4             "It will carry out the task without cooperation of the military

 5     police, which is busy with other tasks.  A platoon of this company will

 6     lie in ambush at Ravni Buljim, since the Muslims groups were spotted

 7     fleeing along this axis."

 8             So you were aware that a platoon of this 2nd company was sent

 9     into the woods at Ravni Buljim, which is, as we know, just past Susnjari

10     and Jaglici up towards Konjevic Polje?

11        A.   Well, first of all, I should say that this is the first time I've

12     seen this document, and let me just clarify something, Mr. Prosecutor.

13     PJP was organised in what was then the centre in Zvornik.  As far as the

14     2nd company in particular is concerned, all the police stations that were

15     part of the Zvornik centre allocated a certain number of their members to

16     that platoon.

17             So if the entire -- as for the entire company going to this area,

18     I'm not aware of that.  Only members, as I have said, of the police

19     station from Bratunac went there to establish the Srebrenica police

20     station on the 12th of July.  I know about our men who were from the

21     police station and who went there, but I am not aware of anyone else.

22        Q.   Sir, I ask you that because a Muslim man that survived an

23     execution at the banks of the Jadar river, who was taken there by an

24     execution squad the morning of 13 July, he has testified that Nenad

25     Deronjic was part of the execution squad, and that if Nenad Deronjic was

Page 27537

 1     a member of the 2nd company, and that 2nd platoon of the 2nd company was

 2     sent to the area of Ravni Buljim on the 12th, then if they had stayed

 3     there they would have woke up in the morning near the area of Konjevic

 4     Polje right where this Muslim said he was picked up and dealt with by

 5     Nenad Deronjic.

 6             So have you heard, sir, that your colleague, Nenad Deronjic, was

 7     part of an execution squad that in the morning of the 13th of July took

 8     about 15 or 16 Muslim men in a bus from Konjevic Polje, drove a little

 9     ways up the road, went down to the bank of the Jadar river where they

10     were all shot?  Have you heard that story?  Have you heard that account?

11        A.   I am not aware of that.

12        Q.   If I could have one moment.

13                           [Prosecution Counsel Confer]

14             MR. McCLOSKEY:  Okay.  Just the last couple of questions.  I hope

15     I can finish before the break.

16        Q.   Did you assist the international community with the exhumations

17     of Muslim dead in the last few years around Bratunac?

18        A.   As far as exhumations are concerned, well, yes, I was present as

19     part of a team from the federation.  It was the commission for locating

20     missing persons from Tuzla.  I was present at a number of exhumations

21     they carried out in the past year of a Bratunac police station member.

22     At the time, I also worked as a forensic officer in the police station.

23        Q.   And those mass graves, those contain Muslims, I take it, from

24     Srebrenica from July 1995?

25        A.   I don't know whether all the bodies were from the area of

Page 27538

 1     Srebrenica.  We carried out the exhumation of the bodies that had been

 2     buried in the ground there.

 3        Q.   Did you know about the huge mass grave at Glogova where people,

 4     hundreds and hundreds of Muslim men were put after they were murdered at

 5     the Kravica warehouse or the Oka warehouse?

 6        A.   I had heard about the Glogova grave, but I wasn't present when

 7     they carried out the exhumation there.

 8        Q.   When did you first hear of the Glogova grave?

 9        A.   I can't remember when exactly, but I didn't have any information

10     until the exhumation was carried out by this team from Tuzla.

11        Q.   So you didn't know about the Glogova grave in 1995, 1996, 1997,

12     1998?

13        A.   No, I personally didn't know about it.

14        Q.   When did you first hear that your colleague Ninkovic was killed?

15        A.   Zeljko Ninkovic was killed in the morning, on the 13th in the

16     morning, in the early morning hours.  He was killed at the Sandici pass

17     as far as I can remember.

18        Q.   And when you did you first hear about that?

19        A.   I heard that he had been killed when I was performing my duties

20     in the department.

21        Q.   What time?

22        A.   Well, I don't know what time it was.  On the 13th, I left in the

23     morning.  I returned home, and I received information according to which

24     he had been killed.  In the evening [as interpreted] hours, I was resting

25     at home preparing to go to the funeral.

Page 27539

 1             MR. LAZAREVIC:  It's a mistake in the transcript.  I have to

 2     correct it.  The witness said "in the morning hours, I was resting at

 3     home preparing to go to the funeral."  This is what he said, I mean.  We

 4     heard it.

 5             JUDGE AGIUS:  Do you confirm that, Mr. Simic?

 6             THE WITNESS: [Interpretation] In the morning hours on the 13th,

 7     Zeljko Ninkovic was killed.  As to the exact time, I really don't know.

 8             JUDGE AGIUS:  But what time were you resting at home preparing to

 9     go to the funeral, and on which day?

10             THE WITNESS: [Interpretation] I left my night shift in the

11     morning on the 14th, and I went to have a rest because the funeral was on

12     the 14th.

13             THE INTERPRETER:  The interpreters apologise for any mistake and

14     would kindly ask the witness to speak a little more loudly.

15             JUDGE AGIUS:  Thank you.  Mr. Simic -- are you finished,

16     Mr. McCloskey?

17             MR. McCLOSKEY:  Yes.  Thank you, Mr. President.

18             JUDGE AGIUS:  All right.  Is there re-examination?

19             MR. LAZAREVIC:  There will be, Your Honour.

20             JUDGE AGIUS:  All right.  We'll have a break now of 25 minutes,

21     and then we'll have the redirect.

22                           --- Recess taken at 3.45 p.m.

23                           --- Upon resuming at 4.22 p.m.

24             JUDGE AGIUS:  Yes.  Sorry for the delay, but something urgent

25     came up which had to be attended to.

Page 27540

 1             Mr. Lazarevic.  Your redirect, please.

 2             MR. LAZAREVIC:  Thank you, Your Honour.  I will try to reduce it

 3     as much as possible.

 4                           Re-examination by Mr. Lazarevic:

 5        Q.   [Interpretation] Mr. Simic, I'll have a number of questions for

 6     you about some of the things that you said in answering my learned

 7     friend's questions.  If you remember, Mr. McCloskey asked you about a

 8     certain Miroslav Stanojevic and whether that person belonged to the Red

 9     Berets, and he also asked you about Rade Petrovic.

10             Let us look at two documents that have something to do with the

11     questions put to you by Mr. McCloskey.

12             MR. LAZAREVIC: [Interpretation] The first one is 4D488.

13        Q.   Do you see the document in front of you?  It actually has two

14     pages.  Let's first look at the first page.  In the left corner, you see

15     that it reads "command of the 1st Bratunac Light Infantry Brigade," and

16     the date is 8th August, 1995.

17             Further on in the document, you can read category of persons,

18     registered number, but I would like us to look at the line where it says

19     name, father's name, last name.  It says Miroslav, Andjelko Stojanovic

20     here.  The address is indicated as being Pobrdje, and also you will see

21     where it says the first time mobilised to unit, next to it the 1st

22     Bratunac Light Infantry Brigade.  Can you now move to the following page

23     of the same document, please.

24             This is actually a -- a report of death, wounding, capture or

25     disappearance.  We can see that the word "wounding" is underlined.  Am I

Page 27541

 1     correct?

 2        A.   Yes, you are.

 3        Q.   The date that you can see in the frame is 13/07/95 and the rest

 4     of the figures.  Would that stand for the 13th of July, 1995?

 5        A.   Yes.

 6        Q.   The indication of the place is Kravica, is it not?

 7        A.   Yes.

 8        Q.   And where it says description of wound event, it says "gunshot

 9     wound to the right elbow, wounded while taking captured Muslims into

10     custody.  The aforementioned person was wounded."

11        A.   Yes, you're right.

12             MR. LAZAREVIC: [Interpretation] Let's look at the following

13     document which is 4D558.

14        Q.   The document is headed by the will following words:  "Command of

15     the 1st Bratunac Light Infantry Brigade."  The date is 14th of May, 1994.

16     The title of the document is "List of the rapid reaction company

17     delivered to," and here you can see that it says Sreten Petrovic, company

18     commander, and below that the 1st rifle platoon, Neskovic, Neljko, Bosko,

19     platoon commander.  Am I reading everything correctly?

20        A.   Yes, you are.

21             MR. LAZAREVIC: [Interpretation] And now let's look at 35 on the

22     list.  These are all members of the 1st rifle platoon.

23        Q.   Under 35, you will see the name Stanojevic, Andeljko, Miroslav,

24     fighter, combatant.  Would that be the same person judging by the first

25     name, the last name, and the father's name, as the person that was named

Page 27542

 1     in the previous document?

 2        A.   Yes, this seems to transpire from this document.

 3        Q.   This is a document from 1994, and the previous one was from 1995.

 4     Does it arise from this that Stanojevic was a member of the Berets in

 5     1994 as well as in 1995?

 6        A.   Yes, he was.

 7        Q.   Thank you.  I will no longer need this document.  My learned

 8     friend Mr. McCloskey also asked you about certain exhumations that you

 9     attended, and you said that this had been part of the cooperation with

10     the commission for the search for missing persons from Tuzla; is that

11     correct?

12        A.   Yes.

13        Q.   And when these exhumations were carried out, did anybody from

14     that tell you, you personally, what the ethnicity of the bodies was or --

15     did they tell you anything about bodies, which side they belonged to or

16     any such thing?

17        A.   Nobody from the commission ever told me that those bodies

18     belonged to the people that had been killed in Srebrenica or hailed from

19     Srebrenica.  They assumed that they hailed from Srebrenica, and they also

20     assumed that they were Muslims.  In any case, it was not their duty to

21     tell me anything about what they knew about the bodies.

22        Q.   In answering my learned friend McCloskey's questions, you said

23     that the duty officers were supposed to take complaints, that people

24     could call in, phone in, or come to the police station in person.  Do you

25     remember whether at that time, and we are talking about the time before

Page 27543

 1     the fall of Srebrenica, a few days before that and a few days after that,

 2     were the telephone lines in Bratunac operating?  Were they up?

 3        A.   As far as I can remember, there was a time when they were down.

 4     Even my private telephone line was switched home -- switched off at home.

 5        Q.   And what about the public security station in Bratunac?  Was

 6     there a telephone that was still operational or that could be used that

 7     was not switched off?

 8        A.   As far as the police station is concerned, we had just one

 9     telephone number, but that telephone number was upstairs on the first

10     floor, and it was the chief who used that telephone line.  That was the

11     only operational number that the police station had.

12        Q.   Well, thank you very much.  And while you were on duty in

13     Bratunac, were you allowed to leave your post as the duty officer?  Were

14     you allowed to leave the building of the police station?

15        A.   No.  That particular post is tied to the room of the duty officer

16     within the building of the police station.

17        Q.   Well, yes.  I understand.  I'm clear.

18        A.   I couldn't leave the building.

19        Q.   Yes, that's obvious.  And Mr. McCloskey also asked you a certain

20     number of questions, and if I understood him well, and I believe I did,

21     the questions were about the logbook -- logbook that served to record all

22     the changes during a shift.  It's the logbook of events in the police

23     station, and he asked you a certain number of questions with regard to

24     this logbook.  Do you remember the questions that he asked you about

25     that?

Page 27544

 1        A.   Yes, he did ask me questions about that.

 2        Q.   He obviously asked you whether the Defence team had shown you the

 3     document or if they had told you anything about that document, and you

 4     said that the Defence team never showed you or told you anything about

 5     the document.  My question to you is this:  Do you know anything about

 6     the attempts on the part of the Borovcanin Defence team to get hold of

 7     this document, either in the police station in Bratunac or elsewhere?  Do

 8     you know that the team tried that?  Do you know anything about that?

 9        A.   I personally don't have any information to that effect.  I can

10     only suppose that they have made attempts to get hold of that document.

11        Q.   Obviously, what you don't know you can't tell us.

12        A.   I can just assume or suppose.

13        Q.   You've also been asked certain questions about the establishment

14     of the police station in Srebrenica.  My first question with this regard

15     is the following:  During the examination-in-chief and during the

16     cross-examination by my learned friend, you were shown a number of

17     documents to -- about that.  There was first an order by the president to

18     the minister and then from the minister to the chief of the security

19     centre, and further down, orders issued by the chief of public security

20     centre.

21        A.   I remember the documents.

22        Q.   And finally, who was it who finally selected those persons that

23     would be appointed to work at the new public security station in

24     Srebrenica?

25        A.   Somebody from the superior bodies, from the Main Staff of the

Page 27545

 1     police station in Bratunac or the Main Staff that was at the time at the

 2     police station in Bratunac.

 3        Q.   Very well.  So did that superior, whoever it was, have any

 4     obligation?  Was he duty-bound to inform you about that?

 5        A.   Of course not.  I was a mere policeman, a police officer.

 6        Q.   Just one thing.  You use the term "Main Staff."  Are you

 7     referring to the Main Staff of the police forces?  Is that what you're

 8     referring to?

 9        A.   Yes.  They called it, also, the Crisis Staff.  That was the staff

10     that was headquartered in Zvornik and then was moved to the police

11     station in Bratunac.

12        Q.   And although there are no suggestions on the part of the

13     Prosecutor - at least I was not aware of any - did Mr. Borovcanin have

14     anything to do with the 2nd company of the PJP that you would be familiar

15     with?

16        A.   No, I don't know any such thing.

17        Q.   And you were also asked about your colleague, Mr. Nenad Deronjic,

18     and the Prosecutor presented a -- certain suggestions with this regard.

19     I would like to show you another document.

20             MR. LAZAREVIC: [Interpretation] May the Court please produce

21     4D560.

22        Q.   You have not seen this document before.  I didn't know whether to

23     use it before Mr. McCloskey's cross-examination.  Unfortunately, the

24     document has not been translated, but maybe you will be able to help us

25     to understand.  This is the title page.  Could you please read the title?

Page 27546

 1        A.   It says "Duty shift of the SJB Srebrenica from 12 July 1995," and

 2     I can't see the little --

 3             MR. LAZAREVIC: [Interpretation] Can we below up a little?

 4        A.   Yes, the bottom part.

 5        Q.   As far as I can read, it says D. Nenad [Realtime transcript read

 6     in error, "DNA"].

 7        A.   Yes, it does say Nenad.

 8        Q.   Very well.  And now, let's look at the fourth page of this

 9     document.

10             MR. LAZAREVIC:  Just to clarify the transcript, on page 35, line

11     5, it does -- I didn't say "DNA."  I said "D. Nenad."

12             JUDGE AGIUS:  All right.  Slightly different.  Let's proceed.

13             MR. LAZAREVIC: [Interpretation]

14        Q.   We have identified the document first, and here we can see the

15     date:  12th of July, 1995.  Am I correct?

16        A.   Yes.

17        Q.   And could we please now -- and we can see that this is actually

18     the first entry, but let's first look at the first couple of pages so as

19     to be totally convinced that the page that we have in front of us now

20     actually depicts the first entry for the day.

21             Under 1, it says "Slavoljub Mladjenovic."  Is that the commander

22     of the Bratunac station or your commander who, according to your

23     knowledge, went to Srebrenica on the 12th?

24        A.   Yes, that was my superior commander at the time.  My superior --

25     immediate superior.

Page 27547

 1             MR. LAZAREVIC: [Interpretation] Can we scroll down a little,

 2     staying on the same page.  Let's go all the way to the bottom of the

 3     page, please.  Very well.

 4        Q.   And here we can see where it says Sector 1, there are four names

 5     there, and among them under number 2, Deronjic, M.  Am I correct?

 6        A.   Yes, you are.

 7        Q.   And it says here Sector 1, 19 to 24.  Is that correct?

 8        A.   Yes, it is.

 9             MR. LAZAREVIC:  [Interpretation]  Very well.  And now we have a

10     little problem with this document.  The document is what it is, and

11     that's how it has been found in the general collection of the

12     Prosecutor's office, i.e., the Tribunal.  And since one of the pages was

13     upside down, could we please put the page that I'm holding my hand on the

14     ELMO.  That page is missing in e-court, but my learned friends have been

15     informed about the document that I'm just going to put on the ELMO.  It's

16     a document that we have found on their collection.

17             This should be page 6 in the e-court system.  That's what I was

18     told, but it's missing.

19        Q.   Can we have a look at the date up at the top?  Can you see it?

20        A.   The 13th of July, 1995.

21        Q.   Very well.

22        A.   It's not very clear.

23        Q.   That's right.  It might be easier for you to have a look at the

24     document on the ELMO.  It's right next to you.

25        A.   Yes, it's clearer.

Page 27548

 1        Q.   You can see that it says duty department, duty service.  Can you

 2     see the name Deronjic, N?

 3        A.   Yes.  Under number 2, a shift from 19 to 07, if I've read it

 4     correctly.

 5             MR. LAZAREVIC: [Interpretation] Let's now have a look at page 6

 6     in the e-court system.  You'll see page 6 on the screen now.  This is the

 7     page that follows the one that we have just had a look at on the ELMO.

 8     Let's see whether it's page 6 in the e-court system -- I apologise.

 9     Let's have a look at the following page.  Yes.

10        Q.   In the top part, it says Domavia Drina security.  Can you see the

11     name Deronjic, N.  It says 07 to 19.  I agree that it's a bit smudged,

12     but I think we can see it?

13        A.   Yes, that's what it says.

14        Q.   And now let's have a look at the next page for the sake of the

15     date.

16             JUDGE KWON:  Was Deronjic on page 6?

17             MR. LAZAREVIC:  He's not on page 6.  It was my mistake, Your

18     Honour.  It was actually page 7.

19             MR. McCLOSKEY:  I'm sorry.  I can't see what we're talking about

20     here, so if we could make that clear.

21             JUDGE AGIUS:  Yes, Mr. Lazarevic.  Back to you now.  I can see

22     Nenad or N. Deronjic.  But what page it is?  I take your word for it that

23     it is page 7.

24             MR. LAZAREVIC:  Yes.  Can we return at previous page?

25             JUDGE AGIUS:  Uh-huh.

Page 27549

 1             MR. LAZAREVIC: [Interpretation] In the top part, it says

 2     "security Domavia Drina", and number 1 -- under number 1, it says

 3     Deronjic N, 07 until 19.  It's the 13th of July.

 4             JUDGE AGIUS:  Mr. McCloskey.

 5             MR. McCLOSKEY:  Can I state for the record that it's a very clear

 6     alteration on this document given that I won't be cross-examining on it.

 7             JUDGE AGIUS:  Thank you.

 8             MR. McCLOSKEY:  On -- next to Nenad Deronjic's name.

 9             JUDGE AGIUS:  Yes.  Thank you.

10             MR. LAZAREVIC:  In response to my colleague, I already said that

11     there are some alteration obviously here, but I didn't try to hide

12     anything from him.  This is what I said to the witness already.

13             JUDGE AGIUS:  All right.  Okay.  Go ahead.

14             MR. LAZAREVIC:  That's the way we found this document on the DS.

15        Q.   [Interpretation] So it seems that these are entries for the 13th

16     of July.  When we had a look at the following page, it was obvious that

17     that was for the 14th of July.  So the documents that you have seen, did

18     they say anything about the presence of Deronjic in the police station

19     and in the area of the town of Srebrenica itself?

20             MR. McCLOSKEY:  Objection.  The document speaks for itself.  This

21     witness clearly has nothing to add or subtract to this, and I will have

22     no objection to it coming into evidence.

23             JUDGE AGIUS:  Will you then proceed with your next question,

24     Mr. Lazarevic, because, indeed, it does say exactly what you were --

25             MR. LAZAREVIC:  No, Your Honours.  I don't think I will have any

Page 27550

 1     further question for the witness.

 2             JUDGE AGIUS:  All right.  Thank you.  So Judge Kwon.

 3             JUDGE KWON:  Just one minor point.  Do you by any chance know

 4     whether that Nenad Deronjic was related to the late Miroslav Deronjic?

 5             THE WITNESS: [Interpretation] I don't know if they were related.

 6     I personally know Nenad Deronjic, but as to whether he was related to

 7     this person, I really don't know.

 8             JUDGE KWON:  Very well.  Thank you.

 9             JUDGE AGIUS:  Thank you, Judge Kwon.  Judge Prost?  Judge Stole?

10             All right.  Mr. Simic, we are finished with your testimony.  You

11     are free to go.  You will receive assistance from our staff.  On behalf

12     of the Trial Chamber, I thank you for having come over and also wish you

13     a safe journey back home.

14             THE WITNESS: [Interpretation] Thank you.  Thank you to all of

15     you.

16             JUDGE AGIUS:  Thank you.

17                           [The witness withdrew]

18             JUDGE AGIUS:  Mr. Lazarevic, documents.

19             MR. LAZAREVIC:  Yes, Your Honour.  We have two documents.  One is

20     4D244.  The other one is 4D333.  I am not quite sure whether this one is

21     already admitted.  I just -- through our expert witness, Mladen Bajagic,

22     and there are three other documents which I used in redirect of this

23     witness.  It's 4D488 [Realtime transcript read in error, "4D388"], 4D558,

24     and 4D560.

25             JUDGE AGIUS:  Any objections, Mr. McCloskey?

Page 27551

 1             MR. McCLOSKEY:  Mr. President, regarding the last document, the

 2     Srebrenica book that had the various police officers, the one with the

 3     alteration, that document was retrieved by the OTP, but there are some

 4     circumstances that I think the Court should be aware of in the retrieving

 5     of that document, what the police department knew before we retrieved it,

 6     that may help put the context of possible alterations on it.  And so

 7     I'm -- I will talk to my friends, and perhaps we can reach a short

 8     stipulation on that, and then it will come in, you know, in a more

 9     complete way so you understand this document.

10             JUDGE AGIUS:  All right.

11             MR. McCLOSKEY:  And in addition, I believe the -- and I don't

12     object to the document that indicates the -- I think the wounding of

13     Mr. Stanojevic, which is 4D488.  However, I would like to note that the

14     health centre log that I believe is already in evidence, which we --

15     01892, which we do have the original of, indicates the time of wounding

16     to be different than that of the one on the document.  And it's right

17     before the wounding of Rade Cuturic, and it appears to be 1730 hours,

18     just so that you can have that in mind for that other document that is

19     coming in through the witness.

20             JUDGE AGIUS:  All right.  And also for the record, we need to get

21     the numbers correct because, for example, you referred to 4D488, but on

22     line 19 of the previous page, Mr. Lazarevic, was referring to 4D388 and

23     4D558, and so we need, also, to have clear which is the last document

24     that you are moving towards a stipulation.  We need to have on the record

25     a clear indication of that document.  The last one should be 4D560, but

Page 27552

 1     I --

 2             MR. McCLOSKEY:  That's my understanding, Mr. President.

 3             JUDGE AGIUS:  Okay.  But at least we have it on the record

 4     that --

 5             MR. LAZAREVIC:  I can confirm that it's 560.  5D560.  4D.  It

 6     says here 5D.  It's 4D560.

 7             JUDGE AGIUS:  And is the other one -- is the other one 4D388 or

 8     4D488?

 9             MR. LAZAREVIC:  The other one 488, 4D488.

10             JUDGE AGIUS:  4D488.  So the transcript on line 19, in line 19 of

11     the previous page, page 39, is wrong.  Okay.

12             JUDGE KWON:  But only those pages shown to the witness will be

13     tendered, not entire 76 pages.

14             MR. LAZAREVIC:  Well, Your Honour, I don't believe that

15     everything is relevant but only the pages that were shown to the witness,

16     but I already draw the attention of the Trial Chamber that this little

17     problem that we have in the e-court system that we simply couldn't open,

18     so we'll try to organise it in a way to put this missing page in and have

19     the entire document in order.

20             JUDGE AGIUS:  Yes, Mr. McCloskey.  Thank you, Mr. Lazarevic.

21             MR. McCLOSKEY:  It may be helpful just to have the 11th through

22     the 16th just so it's -- context, but yeah, we certainly don't need the

23     whole thing.

24             JUDGE AGIUS:  Okay.  I think you can reach an agreement on that.

25     Do you have any documents to tender, Mr. McCloskey?

Page 27553

 1             MR. McCLOSKEY:  No, Mr. President.

 2             JUDGE AGIUS:  All right.  Thank you.  That concludes the Simic

 3     testimony.

 4             Now, the next witness, we still have to decide the issue on

 5     protective measures.

 6                           [Trial Chamber confers]

 7             JUDGE AGIUS:  So, as I said, we have the next witness that we

 8     need to decide the protective measures issue.  However, before that we

 9     have an important communication, which is in itself a directive that we

10     are giving, and this relates to the Prosecution motion regarding the

11     Hotel Fontana documents, a motion that arose in the wake of the use by

12     you, Mr. Zivanovic, in the course of these proceedings of some documents

13     allegedly from -- retrieved from the Fontana Hotel.

14             Now, in relation to the pending motion from the Prosecution,

15     which I just have referred to, we would like you, Mr. Zivanovic, to make

16     arrangements for the recalling of witness Pero Mijatovic.  The Trial

17     Chamber wishes to clarify the testimony of this gentleman as to the

18     documents he obtained from the Hotel Fontana; and thus, when he comes

19     over, this witness should come prepared to testify very specifically on

20     that.  We also require him to bring with him a detailed list of these

21     documents.

22             You will need, of course, to discuss the scheduling of the

23     witness with the Borovcanin and Miletic Defence teams, as we would like

24     to have this witness here to answer questions as soon as possible.  So,

25     Mr. Lazarevic, if you are still involved, and Ms. Fauveau, kindly

Page 27554

 1     cooperate as much as you can with Mr. Zivanovic.  All right?

 2             MR. ZIVANOVIC:  Yes.  I will, Your Honour.

 3             JUDGE AGIUS:  Okay.  Thank you.

 4             Now, the next witness.  The next witness, you will recall that

 5     there is a motion by the Borovcanin Defence team for protective measures

 6     of pseudonym, facial, and voice distortion.  We have discussed at length

 7     about this motion, and we have decided in the first place by majority to

 8     interview him shortly, briefly in private session.

 9             Before we do so, have you by any chance discussed the issue again

10     with him, Mr. Lazarevic?  Is he still of the opinion that he wishes to

11     have protective measures?

12             MR. LAZAREVIC:  Yes, Your Honour.  I had the opportunity to

13     discuss this issue with the witness, and he still requires -- he's still

14     asking for protective measures as required in our motion.

15             JUDGE AGIUS:  And you still oppose, Mr. Thayer?

16             MR. THAYER:  Mr. President, based on the filing, we do.  As we

17     stated in the motion, subject to the Court's interview with the witness,

18     we may withdraw our opposition.

19             JUDGE AGIUS:  Okay.  Thank you.  So the members of the public in

20     the gallery will have to be patient with us.  We are going to draw the

21     curtains down while this gentleman enters the courtroom, and we will be

22     interviewing him for a few minutes to decide whether to give him

23     anonymity or not.  Then we will proceed the sitting in a normal fashion.

24     Yes, please.

25             Let's go into closed session now, for a while, and bring in the

Page 27555

 1     witness.

 2                           [Closed session]

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 27556











11 Pages 27556-27563 redacted. Closed session.















Page 27564

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16   (redacted)

17   (redacted)

18                           [Open session]

19                           --- Recess taken at 5.26 p.m.

20                           --- On resuming at 5.56 p.m.

21             JUDGE AGIUS:  One moment.  Witness, now we are going to proceed

22     with your testimony.  You have already been sworn in.  The procedure is

23     as follows.

24             Mr. Lazarevic will ask you some questions, and he will then be

25     followed by others on cross-examination, and when we conclude, you can

Page 27565

 1     did home.  I don't think that is going to happen today.  We will proceed

 2     tomorrow, continue tomorrow, and I am sure we will finish with you

 3     tomorrow.

 4             Mr. Lazarevic.

 5             MR. LAZAREVIC:  Thank you, Your Honour.

 6                           Examination by Mr. Lazarevic:

 7        Q.   [Interpretation] Good afternoon, sir.  As I have already said it,

 8     I am going to avoid using your names, especially when we are in open

 9     session as we are now.  However, according to the procedure I am going to

10     introduce myself first, although we have already seen each other.  My

11     name is Aleksandar Lazarevic, and together with my colleagues I represent

12     Mr. Ljubomir Borovcanin before this Tribunal.

13             And before we proceed, I would like to draw your attention to the

14     fact that the two of us speak the same language; therefore, I would

15     kindly ask you to wait for me to finish my question before you start

16     answering.  If you follow the record on the screen in front, you will see

17     at what speed the words are being recorded, and you will be able to see

18     more or less when you can safely start to avoid overlapping.

19             And as the Presiding Judge has explained, you have been granted a

20     protective measure, which is facial distortion.  Irrespective of that, I

21     am going to be very attentive.  I am not going to address you by your

22     name, and if any of the information may divulge your identity, I will go

23     into private session.  Did you understand my words so far?

24        A.   Yes, I did.

25             MR. LAZAREVIC:  Your Honours.  Can we move into private session?

Page 27566

 1     I would prefer to have this line of questions in private session.

 2             JUDGE AGIUS:  Yes, by all means, Mr. Lazarevic.  Let's go into

 3     private session, please.

 4                           [Private session]

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 27567











11 Pages 27567-27569 redacted. Private session.















Page 27570

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9                           [Open session]

10             JUDGE AGIUS:  We are in open session.

11             MR. LAZAREVIC: [Interpretation]

12        Q.   Could you now tell me, sir, whether at one point in time your

13     wife and daughter left Bosnia and Herzegovina?

14        A.   The second thing I did was to send them off in the direction of

15     Serbia, to be more precise, in the direction of Krusevac as I had a

16     brother who lived in Krusevac with his family, and I hoped that he would

17     put them up.

18        Q.   Very well.  And tell me, did you at some point in time return to

19     Bosnia and Herzegovina?

20        A.   I didn't even leave Bosnia and Herzegovina.  I only escorted my

21     wife and daughter, and then as it was clear to me that I had to become

22     engaged, I sought out part of the special unit that I had previously

23     worked in, and I joined the educational centre of the MUP in the Sarajevo

24     settlement of Vraca.

25        Q.   Very well.  Now, tell me, after that were you assigned a position

Page 27571

 1     of some kind in that unit?

 2        A.   Yes, I was.  I was still in my tracksuit and in training shoes,

 3     but I was assigned as a -- an operative duty commander in the unit.

 4        Q.   Did that unit remain in Vraca in the subsequent period after you

 5     had returned?

 6        A.   As far as I can remember, towards the end of May we were moved --

 7     or rather, we moved the command of the special unit to Brdo, to a hill

 8     above Vraca.  It was at the top.  It was Moravska Street, perhaps, and

 9     our lines were -- or positions stretched along the hill that is called

10     the Hrasno Hill.

11        Q.   Tell me, afterwards did the unit move somewhere else?

12        A.   About the 6th or 7th of June, because the people were exhausted,

13     we withdrew the unit to rest in the premises of the Sarajevo factory

14     Envergoinvest, which is located in the Lukavica settlement.

15        Q.   Very well.  And then did you get some other position with your

16     unit?

17        A.   The men briefly stayed in the presence of the Envergoinvest

18     factory, and then some were selected to rest in the Jahorina Moharina

19     [phoen], in the Kosuta Hotel.

20        Q.   Very well.  If you can remember, do you remember whether the unit

21     then moved to some other place?  Did it have its headquarters somewhere

22     else?

23        A.   We left Jahorina to perform tasks in the Sarajevo settlement of

24     Vraca.  And then I, in fact, towards the end of July - I can't remember

25     the exact date - was granted a brief leave to visit my family.  They were

Page 27572

 1     staying with my brother in Krusevac, my son and daughter and my entire

 2     family, in fact, was there.  I stayed there for four or five days.  When

 3     I returned, when I moved from Serbia into Bosnia and Herzegovina or to

 4     Zvornik, to be more precise, I met members of my special unit at

 5     checkpoints in the direction of Sekovici.  I was surprised.  I asked what

 6     they were doing there.  They told me they had been there for three or

 7     four days already.  Later, I found out they had been assigned a task, the

 8     task of neutralizing some paramilitary formation in Zvornik known as Zuta

 9     Osa or the Yellow Wasp.  I know that the mission was accomplished

10     successfully.

11        Q.   Very well.  Tell me, did the headquarters of the unit remain

12     there for a while, or was the location changed, and if so, when?

13        A.   Having accomplished the mission and having neutralized the

14     paramilitary formations, the unit was provided with accomodation in the

15     Drina hotel in Zvornik, and then some were selected to move from Jahorina

16     to Zvornik.  But part of the unit, a small part of the unit remained on

17     Jahorina.

18        Q.   Very well.  Now, tell me, how much time did the unit stay in

19     Zvornik?  How long did it stay there, and did it then move to some other

20     location?

21        A.   We stayed in the Drina hotel in Zvornik until the winter of 1993,

22     1994, up until February or March.  That's when changes were introduced in

23     the brigade command; the structure of the command was changed.  The head

24     of the brigade was changed.

25        Q.   Where did the brigade -- where did the unit move from Zvornik,

Page 27573

 1     and then I'll continue with other questions.

 2        A.   In the early spring, in February or March, 1994, the unit was

 3     moved the Janja settlement, to the premises where we already had a police

 4     detachment of ours.

 5        Q.   Very well.  And now tell me, as far as you can remember, when was

 6     the special police brigade established?  That's what it was called, later

 7     became the special police brigade.  When did this happen?  Can you

 8     remember?

 9        A.   Well, I was involved in those tasks, and I think that when the

10     special police brigade was formed -- well, I think they had already

11     started forming it in the autumn of 1992.  I think it was in October.

12        Q.   Tell me, now, during this period of time that we have been

13     discussing, what sort of duties did you have to perform in the unit?

14        A.   Well, initially I had the following tasks in Zvornik.  I had to

15     deal with personnel issues, all personnel issues that related to the

16     unit.  I took care of seriously -- of the seriously wounded, of the

17     families of those who had been seriously wounded or killed.  I also dealt

18     with administrative issues.

19        Q.   Tell me, in 1995, where were the brigade headquarters located?

20        A.   The same place where we were moved to in 1994, in Janja.

21        Q.   And can you now tell me, to the best of your recollection, what

22     was the structure of the command of the special police brigade in 1995?

23     What was the command structure like?

24        A.   At the head of the brigade, there was the commander, Goran Saric;

25     the deputy commander, Ljubomir Borovcanin; the assistant commander for

Page 27574

 1     logistics, Milutin Ratkovic; the assistant for training, Dusko Jevic; the

 2     assistant for personnel affairs, Obrad Savic; the assistant for logistics

 3     support, Vitomir Kapuran and so on.

 4             At that time, I had a decision according to which I was an

 5     official for information.

 6        Q.   Very well.  I would now like to put a few questions to you that

 7     have to do with the special police brigade, and it relates to 1995, the

 8     year 1995.  Do you remember whether at the time in 1995 there were any

 9     ranks in the police, and were there any ranks in the special police

10     brigade as well?

11        A.   I think that in the second half of 1995, something was done to

12     assign ranks, and ranks actually came to life or started being used on

13     the 21st of November, let's say, 21st of November, 1995.

14        Q.   Very well.  And now I would like to move on to a different

15     subject.  It concerns the training centre in Jahorina and the police

16     forces staffs.  Tell me, do you remember when the police forces staff was

17     established on Jahorina?

18        A.   I think that was February or March 1995.

19        Q.   To the best of your recollection, tell me, what was the reason

20     for establishing this staff on Jahorina?

21        A.   Well, the reason for establishing the staff was to obtain

22     operative information for the police services; and on the other hand,

23     from the direction of Sarajevo we wanted to prepare for a spring

24     offensive.

25        Q.   I would now like to have a look at a number of documents that

Page 27575

 1     have to do with the police forces staff on Jahorina.

 2             MR. LAZAREVIC: [Interpretation] The first one I would like to

 3     have a look at is 4D622.

 4        Q.   You'll see it on the screen.  Unfortunately, we don't have a

 5     translation, so I'll go through it with you.

 6             MR. LAZAREVIC: [Interpretation] Could we just show the entire

 7     document on the screen --

 8        Q.   -- so that you can follow.

 9             MR. LAZAREVIC: [Interpretation] Maybe we can enlarge it a bit.

10        Q.   This is the first page.  It's a dispatch from the command of the

11     special police brigade, Goran Saric.  It's dated the 15th of March, 1995.

12     In this document, he informs a number of levels in the MUP, in a number

13     of departments about the activities taken to establish a staff for the

14     police forces.

15             And now let's have a look at the first paragraph in the document.

16     Can you see it?

17        A.   "On the basis of a written order from the deputy minister of

18     internal affairs and the leader of the RJB on establishing police forces

19     staff for the needs of control and command in the upcoming combat

20     operations on the Sarajevo battlefield.

21             "In addition to the activities mentioned in the dispatch, we have

22     undertaken the following" --

23        Q.     Very well, I don't want to go through the entire document, to

24     read through the entire document.  I would just like to gain a picture of

25     what is at stake in the document, and therefore, I'd like to have a look

Page 27576

 1     at the next page.

 2        A.   All this corresponds to what I actually witnessed on Jahorina.

 3        Q.   And on this page, we see what they say about efficient operations

 4     of the staff, how it should achieve efficiency.  It mentions the measures

 5     that should be taken to make sure that the staff functions properly.

 6             Tell me, this document shows that we're dealing with a written

 7     order from the deputy of the -- deputy minister of the MUP, a written

 8     order on establishing the staff.

 9        A.   Yes.  This is already the implementation of this oral order.

10     It's an oral order.

11             MR. LAZAREVIC: [Interpretation] Let's have a look at 4D391.

12        Q.   Very well.  We can go through the document a little more rapidly

13     because we have a translation into English.  It's an order from the

14     Ministry of the Interior Zivko Rakic.  It is dated the 16th of March,

15     1995.  It is an order on forming a command and control staff of the

16     police forces in the Sarajevo battlefield, and we see the date at the top

17     of the document, the 16th of March, 1995, and we can see who the

18     addressees are.

19             We have the public security department, the state security

20     department, the police forces staff, and so on and so forth.  Have a look

21     at the order.  Who, according to this order, should become part of the

22     staff?

23        A.   Yes.  There is a number of segments of the police, of special

24     police units, logistics material and financial assistance.  All I can do

25     is confirm that this was implemented.  I witnessed that.

Page 27577

 1        Q.   Very well.  And according to this order, who was designated as

 2     the commander of the staff?

 3        A.   Well, here it says Saric, Goran.

 4        Q.   Let's look at item 5 of the order where it says that "Continuous

 5     functioning of the staff should be issued as of the 20th of March."

 6        A.   Yes, the 20th of March, 1995.

 7        Q.   I would kindly ask you to bear in mind the break between the

 8     question and the answer.  Please wait a little before you start giving

 9     your answer, and I'll try to bear in mind the same.  Thank you.

10             MR. LAZAREVIC: [Interpretation] Very well.  Let's now move to the

11     following document, which is 4D -- I apologise.  [In English] [previous

12     translation continues]... to page 65, line 15.  It should read: "The 20th

13     of March."  This is what the witness said.

14        Q.   [Interpretation] It seemed that this hasn't been recorded.  In

15     any case, the document that I wanted to show you next is 4D623.

16             Very well.  If we look at the document now, we will see that this

17     is information by Dusko Jevic, the command of the special police brigade,

18     and the date is 28th of March, 1995.  And we see that he informs the

19     command of the special police brigade about the concrete steps that were

20     taken with a view to establishing the staff.

21             I would like to show you, first of all, the written version of

22     this version -- the handwritten version for identification.

23             MR. LAZAREVIC: [Interpretation] The document is the same.  Can we

24     please look at page -- at the following page.  Let's just look at the

25     number, please.

Page 27578

 1        Q.   If we look at this document, in handwriting the number is 1/95,

 2     is it not?

 3        A.   Yes, that's the beginning.

 4        Q.   Very well.  According to your best knowledge, what was the reason

 5     for the establishment of the education and training centre of the

 6     Ministry of the Interior Republika Srpska?

 7        A.   From the very beginning of the war, we trained police officers

 8     for simple tasks in the police; and three years into the war, because of

 9     the casualties, people being wounded, there was a constant shortage of

10     men, so the units were replenished with military conscripts who had not

11     undergone police training.  That is why periodically police training

12     courses were organised for police apprentices to provide them with the

13     necessary skills and knowledge.

14        Q.   In the centre for training of the Republika Srpska MUP, did you

15     have a position, a function?  Did you have to do anything with the staff?

16        A.   At the time, I was in charge of the logistics support.  The

17     offices had to be equipped.  Office supplies had to be provided with

18     basic -- basic equipment had to be procured, and that's what was

19     happening at the time.

20        Q.   One more thing I would like to ask you.  According to your best

21     recollection, did Mr. Borovcanin have a position?  Did he have a function

22     to perform at the training centre?

23        A.   No, not at the training centre.

24             MR. LAZAREVIC: [Interpretation] Let's look at the following

25     document.  This is 4D400.

Page 27579

 1        Q.   Very well.  Since we have it in front of us, on the right-hand

 2     side is the document in Serbian.  Again, this is a report of the police

 3     forces commander Jahorina Trnovo, Dusko Jevic.  The date of 1st of April,

 4     1995.

 5        A.   Yes.

 6        Q.   Let's look at the number this document bears in the right-hand

 7     side corner.  The number is 3/92, is it not?

 8        A.   Yes.

 9        Q.   And the commander of the Jahorina Trnovo police forces informs

10     the Ministry of the Interior that the trainees started arriving at the

11     Jahorina Hotel.  We can see this in the first paragraph of this document.

12        A.   Yes.

13        Q.   Further on, we can see that the commander of the police staff

14     forces is requesting that officers who have been selected for command and

15     control should be sent -- sent urgently to prevent any possible problems.

16        A.   Yes.

17        Q.   Now that we have seen the document and we have seen the list of

18     addressees - which is the public security department, the police

19     administration, the special police brigade - what training course is

20     referred to in this document?

21        A.   Again, this training course was organised for members of our

22     detachments who had not been trained despite the fact that they were

23     still involved in combat.  However, they had not undergone previous

24     police training.

25        Q.   Was that a course for policemen?

Page 27580

 1        A.   Yes.

 2        Q.   And it arises from this document that there is a possible problem

 3     with officers who were supposed to be in charge of the training course.

 4     Could you please tell me, which officers were supposed to manage the

 5     course?  Who were the lecturers?  Where were they supposed to arrive

 6     from?

 7        A.   Those were teachers, i.e., professors from the school of the

 8     interior who were trained to educate future policemen.

 9        Q.   Were there also lecturers from the special brigade?

10        A.   Only for special physical training they could be instructors, for

11     special training, the use of chemicals and similar things.  And the

12     theory of policing was something that was lectured by full-time

13     professors.  They were the only ones with the degree that enabled them to

14     do that.

15        Q.   I apologise.  I'm just waiting for the -- for your answer to be

16     recorded properly.  Tell me, please, according to the best of your

17     recollection, did the course take off the ground in that period?

18        A.   I've already told you that they -- those courses were organised

19     periodically, even before.  So I am fully convinced that the training

20     courses continued.

21        Q.   Did you personally participate in the training?

22        A.   No, I didn't.

23             MR. LAZAREVIC: [Interpretation] Very well.  I would like us to

24     look at the following document, which is 4D251.  I would kindly ask the

25     Court to produce the document in e-court.

Page 27581

 1        Q.   Again, this is a dispatch by the Jahorina commander.  The number

 2     is 5/95, and the date is 6 April 1995.  The dispatch was sent to a number

 3     of addresses in the MUP of Republika Srpska.  Could we please look at the

 4     second page to inspect the signature on the document?

 5        A.   The same person.

 6             MR. LAZAREVIC: [Interpretation]  Let's look at the second page,

 7     please.  Can the next page be produced in e-court, please?

 8        Q.   Very well.  Again, the dispatch was sent from the police forces

 9     command Jahorina Trnovo, and it was co-signed by Dusko Jevic and Cedo

10     Tosic.

11        A.   I know the people, and I can confirm the credibility of the

12     signatures.  I worked with both of them for a number of years.

13             MR. LAZAREVIC: [Interpretation] Can we now go to the first page

14     in order to remove an ambiguity.

15        Q.   In the first paragraph, it says:  "In the evening of 5 February

16     1995, a group of trainees arrived from the CJB Zvornik (8 trainees) so

17     that the total number of trainees now is 142."

18             In view of the date when this dispatch was sent and the date that

19     is mentioned herein as the date of the arrival of the trainees from

20     Zvornik, is this really the 5th of February, 1995, or is this a typo?

21        A.   This is a typo, obviously.  It should be the 6th of April, and

22     the information applies to that course.  It's obvious that it was very

23     difficult to set up a course of that nature and to implement it.

24        Q.   And now, if we look at what we have already read in the first

25     paragraph of this document, does the number of 142 trainees tell you

Page 27582

 1     something about the implementation of this training course?

 2        A.   It is obvious that those were members of the special police

 3     brigade and public security centres.  A reference is made here to eight

 4     trainees from Zvornik, but I'm sure that there were others from other

 5     public security centres.

 6        Q.   Now, if we look at the bottom part of the document where it says

 7     "It has been agreed with the deputy commander of the special police

 8     brigade," and here a reference made to a certain number of names:  Nedo

 9     Sevo on behalf of the school of internal affairs, and Aco Milic, a

10     psychologist from the school.  What does this tell us about the

11     lecturers?

12        A.   It says that the lecturers were full-time professors from the

13     school of the -- of internal affairs and that special police training was

14     carried out by the instructors from our brigade.

15             MR. LAZAREVIC: [Interpretation] Very well.  Let's move on to the

16     next document, which is 4D252.

17        Q.   Again, this is a dispatch by the commander of the staff of the

18     police forces Jahorina Trnovo, Dusko Jevic.  The number is 11/95, and the

19     date is 8 April 1995.  We see that this is a request to send Tomo

20     Mirosavic to work with the trainees.  Do you know where Tomo Mirosavic

21     came from?

22        A.   I believe that he was the Chief of Staff of a department at the

23     school of internal affairs; in any case, he was a full-time professor.

24     It's obvious that a lecture was missing for one of the modules of the

25     course, and it the commander believes that Tomo Mirosavic would be the

Page 27583

 1     best-suited person to fill the position.  I wouldn't be able to tell you

 2     what his specialty was.

 3        Q.   Very well.  And now, can you remember modules of the course?

 4     What kind of training was provided to the trainees during the course?

 5        A.   It was a very special -- a very simple training course for

 6     beginners.  The trainees were informed about the law on internal affairs.

 7     They were familiarized with policing procedures, patrolling, and they

 8     were provided some special physical training.  They were familiarized

 9     with weapons, chemical agents and similar things.

10        Q.   And now, could you please tell me if you remember, how long did

11     the course last?

12        A.   Well, as a rule the courses would normally last three weeks,

13     about 20 days.

14        Q.   And do you know on the base of what a programme was this course

15     the policemen conducted?

16        A.   Well, usually there was a -- an officer who would prepare for the

17     main courses.  He'd assess the conditions and take into consideration the

18     time-period concerned.  But it varied.  It was on the basis of experience

19     and varied from course to course.

20        Q.   Very well.  Let's now have a look at the following document.

21     Unfortunately, we don't have a translation --

22             MR. LAZAREVIC: [Interpretation] 4D624 is the document.

23        Q.   I'll just put a few questions to you about this document, since

24     it's one you have already seen.  Could we just have a look at it?

25             Can you tell us what the title of the document is?

Page 27584

 1        A.   "Republika Srpska, the ministry of internal affairs, special

 2     police brigade, police force staff, Jahorina Trnovo."  That's the

 3     title -- or rather, the title is "The programme for professional training

 4     for the police course."  I'm familiar with this handwriting.

 5        Q.   It's not very clear here.  Perhaps we could scroll down a bit to

 6     see the date.

 7        A.   That's the very same course.  The date is the 10th of April,

 8     1995.

 9        Q.   And tell me, you said that you recognized the handwriting.  Whose

10     handwriting is this?

11        A.   It's Dusko Jevic's handwriting, the deputy commander of the

12     special police brigade.

13        Q.   You've already seen this document.  Can you just tell us

14     something about the contents of the document, especially with regard to

15     the programme for professional training?

16        A.   Well, the programme consists of various subjects that have to be

17     dealt with during the course and on a day-by-day basis.  You start off on

18     Monday.  Then you have Tuesday, Wednesday.  The subjects change.  Some of

19     the subjects can be modified, can be changed.  If there is inclement

20     weather, one subject can be taught instead of another.  But on the whole,

21     it's physical preparation, training, shooting, and learning about

22     chemical agents, et cetera.  I've already mentioned this.

23        Q.   Very well.  I would now like to put a few more questions to you

24     before we adjourn for the day.

25             Do you remember, perhaps, that at one point in time some of the

Page 27585

 1     beginners at the police course were moved to Konjevic Polje?

 2        A.   Yes, I am familiar with that.  I don't understand why this was

 3     done.  Perhaps it was to bring some unit up to strength in order to

 4     secure a road - at the time, Konjevic Polje was a checkpoint -- or there

 5     was a checkpoint in Konjevic Polje; there wasn't combat of any kind - or

 6     perhaps to gain experience in the course -- of the course itself.

 7             MR. LAZAREVIC:  [Interpretation]  And let's just have a look at

 8     the following document, 4D625.

 9        Q.   It's a dispatch dated the 11th of April, 1995.  And if we have a

10     look at the signature at the bottom, it says the commander of the 8th

11     special police detachment, Branislav Okuka.  And if we have a look at the

12     first paragraph of the document, it says, "Having visited the course

13     attendees who are presently in Konjevic Polje, it has been established

14     that the following attendees joined the course later..." and then you

15     have the names of the individuals concerned.

16             Can you tell me whether this document, and in relation to what we

17     have just discussed, in relation to sending some of the beginners to

18     Konjevic Polje, has it got anything to do with that?

19        A.   Yes, I assume that this commander was working on behalf one of

20     the -- was working as one of the officers on the course, perhaps a

21     company commander.

22        Q.   Very well.

23             MR. LAZAREVIC:  [Previous translation continues]...  maybe we can

24     adjourn just right now.

25             JUDGE AGIUS:  Thank you, Mr. Lazarevic.

Page 27586

 1             Witness, we are going to stop here today.  We will continue

 2     tomorrow in the afternoon at 2.15.  Between now and tomorrow, it's

 3     important that you do not communicate or you let anyone communicate with

 4     you on the subject matter of your testimony.  It's an obligation that you

 5     have.  Have you understood me?  All right.

 6             THE WITNESS: [Interpretation] I have.

 7             JUDGE AGIUS:  Thank you.

 8                           --- Whereupon the hearing adjourned at 6.57 p.m.,

 9                           to be reconvened on Thursday, the 30th day of

10                           October, 2008, at 2.15 p.m.