Tribunal Criminal Tribunal for the Former Yugoslavia

Page 14223

 1                           Tuesday, 11 October 2011

 2                           [Open session]

 3                           [The accused entered court]

 4                           --- Upon commencing at 2.27 p.m.

 5             JUDGE ORIE:  Good afternoon to everyone.

 6             Madam Registrar, would you please call the case.

 7             THE REGISTRAR:  Good afternoon, Your Honours.  This is case

 8     number IT-03-69-T, the Prosecutor versus Jovica Stanisic and

 9     Franko Simatovic.

10             JUDGE ORIE:  Thank you, Madam Registrar.

11             I would first like to put on the record that on the

12     7th of October of this year the Chamber decided to grant addition of

13     Witness DST-083 to the Stanisic Defence 65 ter list, and the Chamber has

14     informed the parties of its decision in an informal communication.  The

15     Chamber also instructed the Stanisic Defence to bring the witness to

16     The Hague if it was their only option following their current witness.

17     That's hereby put on the record.

18             Is there any procedural matter to be raised at this moment?

19             I do understand that the Prosecution would like to raise an 92

20     bis issue.  The Chamber would prefer to hear any submissions in relation

21     to 92 bis issues not before the next break.

22             Mr. Jordash.

23             MR. JORDASH:  Could I raise two issues, one relating to

24     Mr. Stanisic and one relating to the next witness.

25             Perhaps, if I may, it would be more appropriate to hear the one


Page 14224

 1     about Mr. Stanisic in the absence of the witness.

 2             JUDGE ORIE:  Is the witness -- is not yet present?

 3             MR. JORDASH:  Oh, he's not there.

 4             JUDGE ORIE:  At least we --

 5             MR. JORDASH:  No.

 6             JUDGE ORIE:  -- we have not started, as a matter of fact, the

 7     video conference.  But I see that there is a video conference.

 8             And could the representative of the Registry at the other end of

 9     the line tell us whether the witness is in the videolink room.

10             THE REGISTRAR: [Via videolink] Good afternoon, Your Honours.  No,

11     witness is in the waiting room in front of the videolink room, so only

12     the representative of the Registry is in the videolink room.

13             JUDGE ORIE:  With a technician, I take it.

14             THE REGISTRAR: [Via videolink] Yes, Your Honour.

15             JUDGE ORIE:  Thank you.

16             Mr. Jordash.

17             MR. JORDASH:  The issue, for Your Honours' information, on Friday

18     last, Mr. Stanisic fell unconscious for unspecified reasons in the

19     detention centre.

20             JUDGE ORIE:  We have -- if I -- if you do not mind, to interrupt

21     you, we have received the most recent report by the reporting medical

22     officer, which refers to at least, a double side, not feeling well, it's

23     described in a little bit more detail, and the observations of the UNDU

24     staff added to that.  You have not seen that?

25             MR. JORDASH:  No, I haven't seen.  We haven't received such a


Page 14225

 1     copy.

 2             JUDGE ORIE:  Then perhaps I read the relevant part to the extent

 3     we -- I think I've got it here.  Yes, let me read it.  It's dated the

 4     11th of October, and the apparent paragraph 2 of the report says the

 5     following:

 6             "Last Friday, Mr. Jovica Stanisic experienced problems with

 7     speech and double vision during about one hour.  This staff described his

 8     comportment resembling that of a drunk.  The medical officer examined him

 9     as soon as possible, but the symptoms had subsided and the medical

10     officer could not find no abnormalities -- could find no abnormalities.

11     The medical officer has planned further neurological examination this

12     week."

13             That is what the report says about what happened at least in this

14     respect last Friday.

15             MR. JORDASH:  And I think Mr. Stanisic experienced that as a

16     period of unconsciousness.  That's certainly how he reported it to me.

17             JUDGE ORIE:  Yes.  That's the reason why I read it, because the

18     language is slightly different.  But that there was something

19     extraordinary is clear.

20             MR. JORDASH:  Yes.  And today he's not feeling terribly well, and

21     I raise that so that Your Honours are aware of it.  And if it comes to

22     it, then I'll obviously raise it again and make the appropriate

23     application.

24             JUDGE ORIE:  Yes.  Yes, we expect you to be very alert on that.

25     And the Chamber, of course, will be alert on it as well.


Page 14226

 1             That is on the record.  There was a second issue you would like

 2     to raise.

 3             MR. JORDASH:  The second issue relates to this next witness who,

 4     I should say, I haven't met and I haven't seen or spoken to, but I'm

 5     informed by my investigator that he would like to address the Chamber to

 6     offer personal reasons concerning protective measures.  And, as I

 7     understand it, he would like to address you at the outset of his

 8     testimony personally.

 9             JUDGE ORIE:  If you say the next witness, is that the witness who

10     will testify today, or?

11             MR. JORDASH:  Today.

12             JUDGE ORIE:  Yes.  Yes.

13             MR. JORDASH:  As I understand his request, he has experienced a

14     number of anonymous calls --

15             JUDGE ORIE:  Okay.  We'll then hear from that witness first what

16     the grounds are for an application for protective measures on personal

17     grounds, rather than grounds raised by the Republic of Serbia.  And I

18     think we should do that in closed session.

19             Ms. Marcus.

20             MS. MARCUS:  Yes, Your Honour, thank you.  In addition to the

21     92 bis submissions, I have one very brief submission that I would like to

22     make.  I would say it would be about 3 minutes.  I would appreciate the

23     opportunity to make it today but any time that Your Honours see fit.

24             JUDGE ORIE:  Yes, then let's first see whether we can get started

25     with the videolink and hearing the testimony of the witness.


Page 14227

 1             I am addressing, at this moment, Madam Registrar at the other

 2     side of the videolink.  Can you hear us, can you see us?

 3             THE REGISTRAR: [Via videolink] Just a second, Your Honour.

 4             Your Honour --

 5             JUDGE ORIE:  Could we move into closed session.

 6                           [Closed session]

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Page 14228

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Page 14234

 1                           [Open session]

 2             THE REGISTRAR:  Your Honours, we're back in open session.

 3             JUDGE ORIE:  Thank you, Madam Registrar.

 4             Witness, you'll now be --

 5                           [Trial Chamber and Registrar confer]

 6             JUDGE ORIE:  Yes, Madam Registrar verified whether the witness

 7     can be shown.  There's no pseudonym, there's no protection of his

 8     identity at this moment.

 9             Witness, you'll first be examined by Mr. Jordash.  And

10     Mr. Jordash is counsel for Mr. Stanisic.

11             Mr. Jordash, you may proceed.

12                           Examination by Mr. Jordash:

13        Q.   Good afternoon, Mr. Lekovic.

14        A.   Good afternoon.

15        Q.   For the record, please give your full name and date of birth.

16        A.   My name is Milorad Lekovic.  Born on the 2nd of January, 1948.

17        Q.   Do you have, there, a copy of a document purporting to be your

18     statement arising from interviews on the 23rd and 31st of August, 2007;

19     5th of September, 2007; 7th of September, 2010; and September 2011?

20             MR. JORDASH:  And it's, Your Honours, 1D05104.

21             THE REGISTRAR: [Via videolink] Your Honours, the Registry doesn't

22     have this document.  The document was not provided [indiscernible].

23             MR. JORDASH:

24        Q.   Do you have that document, Mr. Lekovic?

25             JUDGE ORIE:  The Registrar informs us that the Registrar is not


Page 14235

 1     able to give it to the witness because it doesn't have the document.

 2             MR. JORDASH:  Um, I don't know why that is, as I stand here.  It

 3     ought to have been.

 4             THE WITNESS: [Interpretation] You didn't understand me.

 5             JUDGE ORIE:  Oh, then ...

 6             THE WITNESS: [Interpretation] The documents that you mentioned,

 7     by the dates you mentioned, based on the interviews made on those dates I

 8     made a written statement, and the corroborating documents are enumerated,

 9     and they have been provided.  I hope we understand each other now.

10             JUDGE ORIE:  Yes, there's no -- Madam Registrar, what

11     Mr. Jordash, apparently under number --

12             MR. JORDASH:  -- 1D05104 --

13             JUDGE ORIE:  -- is seeking to be given to the witness is a

14     consolidated statement, and you are telling us that you have not received

15     any such statement?

16             THE REGISTRAR: [Via videolink] That's correct, Your Honours.  I

17     have received -- I have received a set of documents provided by the

18     Defence, and they are numbers from D280 up to D290 MFI'd and one document

19     number 1D04886.  That's all the documents that I have received from the

20     Defence, Your Honours.

21             JUDGE ORIE:  Ms. Marcus.

22             MS. MARCUS:  Yes, just perhaps to be helpful, I think that the

23     witness is saying he has it in his bag.  But even if not, we are happy to

24     send something through PGP electronically to the Belgrade field office if

25     that would be of assistance.  You can have your Case Manager contact ours


Page 14236

 1     and --

 2             THE WITNESS: [Interpretation] I have them in my bag.

 3             JUDGE ORIE:  Yes, let's -- Madam Registrar, could you please

 4     assist in showing to the camera, as detailed as possible, to start with,

 5     first, the cover page of the English version of a witness statement, and

 6     I see here the number of the filing for us here in The Hague is 34219.

 7     Could that be shown to the camera.  Madam Registrar in -- I mean, at the

 8     other end of the line, yes, could the copy the witness has apparently in

 9     his possession, could you ask the witness to provide it to you.

10             THE REGISTRAR: [Via videolink] Yes, Your Honour, but the witness

11     needs to be escorted to the witness room because his documents are not in

12     the videolink room.

13             JUDGE ORIE:  Yes.  Then we wait for a second until the witness

14     returns with this written statement.

15             Could you assist the witness in getting it from the waiting room.

16             THE REGISTRAR: [Via videolink] Yes, Your Honour.

17             JUDGE ORIE:  For the record, the witness leaves the videolink

18     room accompanied by the representative of the Registry.

19             Any explanation as to why this document was not in the bundle, or

20     any challenge to whether it was?

21             MR. JORDASH:  No, I think it wasn't.  I think there's just been a

22     miscommunication between the Defence and the investigator in Belgrade.  I

23     think both thought they were providing that document.  Sorry, both

24     thought the other was providing the document.  I do apologise.

25             JUDGE ORIE:  Witness, would you please be so kind to give a copy


Page 14237

 1     of the statement to the representative of the Registry.  Could the

 2     representative of the Registry show this document as close to the camera

 3     so that we can at least gain an impression of whether it could be the

 4     same.  One second, please.  Yes, even a bit closer would assist,

 5     Madam Registrar.

 6             Yes, now I see we have apparently not the English version but the

 7     B/C/S version.  Could we move to the bottom of that.

 8             MR. JORDASH:  I think it's --

 9             JUDGE ORIE:  Let me see.  It looks very much as if the copy which

10     is at this moment shown to the camera is -- and could we move to the

11     other part of the -- other bottom part, to the right bottom part.  Yes,

12     there we see that initials are missing where we have those initials on

13     our copy.  And these are the initials of other people being present.

14             Could we have a look at page 2 of the document.  First the top,

15     then the bottom.  Bottom, please.  We see that -- and further to the

16     right bottom part, we see that on the second page all initials or

17     signatures are missing.

18             Madam Registrar, could you please have a look at the following

19     pages --

20             THE WITNESS: [Interpretation] Mr. President, if I may be of

21     assistance.  At the end, there is a sentence that reads that I read the

22     whole statement in the Serbian language and signed it.

23             JUDGE ORIE:  Yes.  Let's -- Mr. Lekovic --

24             THE WITNESS: [Interpretation] And there is a signature.

25             JUDGE ORIE:  Mr. Lekovic, if you would please leave it to me at


Page 14238

 1     this moment, the way in which I want to verify what we have in front of

 2     us.

 3             Madam Registrar, could you confirm that on the pages 3, 4, 5, 6,

 4     7, 8, 9, 10, 11, 12, and 13 whether there are any initials in handwriting

 5     or signatures.

 6             THE REGISTRAR: [Via videolink] No, Your Honour.

 7             JUDGE ORIE:  Could you --

 8             THE REGISTRAR: [Via videolink] The pages from 2 up to 13, there

 9     are no initials or signatures.

10             JUDGE ORIE:  Could the Chamber have a look at page 14.  First,

11     top.  Yes, it looks as if at least the signature of the witness appears

12     on page 14.

13             Could we have a look at page 15.  There, a date and what appears

14     to be the signature of the --

15             THE WITNESS: [Interpretation] 30th September and the signature.

16             JUDGE ORIE:  Yes.  And, Madam Registrar, could you please show us

17     the cover page in English.

18             THE REGISTRAR: [Via videolink] Your Honour, I have only a B/C/S

19     version of this document provided by the witness.

20             JUDGE ORIE:  Then we leave matters as they are at this moment.

21             It appears at first sight that the B/C/S copy the witness brought

22     to the videolink room is of the same content as the B/C/S version that

23     was filed for the 92 ter application.  I suggest to the parties that

24     Madam Registrar keeps a -- keeps the copy provided by the witness - at

25     any later stage, of course, Mr. Jordash, you can provide the witness with


Page 14239

 1     another copy if you want to - but that we keep that one because that's

 2     the one produced by the witness at this moment, that it can be compared

 3     with the uploaded copy on the basis of which we will work, and can be

 4     compared with the filed version attached to the 92 ter application, and

 5     that we in this way establish exactly whether -- if the witness would

 6     attest to his statement, whether he would attest to the same statement as

 7     we have received.

 8             Mr. Jordash, this is my suggestion.

 9             MR. JORDASH:  Yes, and I thank you.  And apologies.  And I'll

10     move forward with that in mind.

11             JUDGE ORIE:  Ms. Marcus.

12             MS. MARCUS:  I have no objections, Your Honour.

13             JUDGE ORIE:  Then we proceed in the following way:

14             Witness, Mr. Lekovic, perhaps you'll receive, later, another copy

15     of your statement.  But the one you just produced, are you willing to

16     leave that in the hands of Madam Registrar who is sitting next to you in

17     order to be taken to The Hague for comparison?

18             THE WITNESS: [Interpretation] Your Honour, Mr. President, I agree

19     that can be done.

20             JUDGE ORIE:  Then we proceed as suggested.

21             Mr. Jordash.

22             MR. JORDASH:  Thank you.

23        Q.   Mr. Lekovic, did you attend interviews on the dates which appear

24     on the front of the statement which we've just been discussing?

25        A.   Yes.  On the 23rd and 31st August, 2007; 5 September 2007;


Page 14240

 1     7 September 2010; 16 and 28 September 2011; and the text was finalised on

 2     the 30th, which I then signed.

 3        Q.   That's the 30th of September, is that?

 4        A.   So -- it's dated 30th September, 2011.

 5        Q.   Thank you.  Did you have an opportunity to review the contents of

 6     the statement and make any clarifications you wanted to make before

 7     signing it?  Sorry, let me --

 8        A.   I've read the statement in its entirety, and I participated in

 9     its drafting, and I stand firmly behind the statement I've signed.

10        Q.   Thank you.  And are the contents in accordance with the truth?

11        A.   Could you say that again?

12        Q.   Are its contents in accordance with the truth?

13        A.   Yes, this statement reflects the truth in the topic discussed,

14     the subject of the interview.

15        Q.   And if you were asked the same questions again in substance, you

16     would give the same answers?

17        A.   At the beginning of the statement, from item 1 through item 9,

18     the information is given in chronology about my career in the service.

19     And from item 10 through item 44 --

20        Q.   [Previous translation continued] ... Mr. -- go on.

21        A.   -- there are questions and answers regarding the subject of our

22     discussion, then and today, and I would give the same answers today.

23             JUDGE ORIE:  Witness DST-052, the last question, whether you

24     would give the same answers, could have been answered by a simple "yes,"

25     and that we are always under time restraints.  The content of the


Page 14241

 1     statement is clear to us, so please focus very much your answers on the

 2     questions that were put to you.

 3             Then, finally, one additional question.  You said: The statement

 4     I signed.  Did I understand you well that you recognised your signature

 5     on the statement which is in front of you now?

 6             THE WITNESS: [Interpretation] Yes, the signature is mine.  I

 7     signed the statement.

 8             JUDGE ORIE:  Yes.  Thank you for that.

 9             In order to avoid that any paperwork will be mixed up, I would

10     suggest that if you have -- want to have the statement in front of you,

11     that you remove as good as possible all other paperwork on your desk, or

12     give the statement to Madam Registrar so that she keeps it and shows it

13     to you if need be.

14             Please proceed, Mr. Jordash.

15             MR. JORDASH:

16        Q.   Mr. Witness, I want to go straight to your --

17             MR. JORDASH:  Well, before I do, may I tender the statement?

18     Perhaps it should be MFI'd until the final checks have been carried out.

19             JUDGE ORIE:  Yes, but a number could already be assigned to it.

20     It has been uploaded, Mr. Jordash?

21             MR. JORDASH:  Yes, it has.

22             JUDGE ORIE:  Yes, it has been uploaded.

23             Madam Registrar, the number for the statement would be ...

24             THE REGISTRAR:  Your Honours, the number for statement under

25     65 ter number 1D05104 will be D450, and that will be marked for


Page 14242

 1     identification.

 2             JUDGE ORIE:  It's marked for identification.

 3             Mr. Jordash, I have not specifically verified the statement on

 4     any of the protected matters.  Perhaps it would be wiser to have it

 5     marked for identification under seal for the time being.

 6             MR. JORDASH:  Yes.

 7             JUDGE ORIE:  And that both parties check whether there's any

 8     information in it protected so that -- which might need for a redacted

 9     version to be prepared.  Please proceed.

10             MR. JORDASH:  Thank you.

11             JUDGE ORIE:  And it's -- Madam Registrar, it's under seal at this

12     moment.

13             MR. JORDASH:

14        Q.   Mr. Lekovic, I want to take you to your statement.  Bear in mind

15     that your statement is now before the Court and we do not need to repeat

16     its contents.  I'd like to ask you some questions, though, to clarify

17     your statement and also clarify issues relating to the commission.  And

18     so we'll look at the statement and we'll look at the various underlying

19     documents.  Do you follow me?

20             JUDGE ORIE:  Just -- yes, before we proceed, there's one thing.

21     This witness was scheduled viva voce for two hours.  It's now a

22     92 ter witness, which is supposed to save time.  I invited the parties

23     last week to make a clear division of time.  Has that been done for the

24     two days?

25             MR. JORDASH:  I think it has.  I think we expect to finish within


Page 14243

 1     two days.  I think there's been an exchange of estimates, and we

 2     anticipate finishing tomorrow.

 3             JUDGE ORIE:  Yes.  Especially because if you would have divided

 4     the time available in its entirety for these two days, we've lost already

 5     one hour.  That's the only thing I'm a bit concerned about.  So if

 6     there's any need to review your estimates so in order to finish the

 7     testimony of this witness in the -- either today or tomorrow, then I

 8     would urge you to contact the other parties.

 9             Meanwhile, please proceed.

10             MR. JORDASH:

11        Q.   Mr. Lekovic, can I take you to paragraph 5 of your statement and

12     paragraph 8 and 9, and it deals with your appointment to the head of the

13     State Security Service for the city of Belgrade in November of 1988.  And

14     in paragraph 5, you note:

15             "My appointment was the second case of an appointment of a person

16     from political structures to the position of a superior officer within

17     the SDB."

18             When you say "an appointment from political structures," what

19     exactly do you mean by that?

20        A.   I meant that the Government of Serbia, or, as it was called, the

21     Republic Executive Council of the Republic of Serbia, appointed me chief

22     of the State Security Service for the city of Belgrade, and it was only

23     the second time that somebody from outside the service was appointed to

24     that position.

25        Q.   Did you have any experience --


Page 14244

 1        A.   Yes, sorry.

 2        Q.   Do you have any experience of state security business when you

 3     were appointed?

 4        A.   No.  After graduating from university, I went straight to the

 5     school for reserve officers in Bileca.  Then I was a "stagiaire."  And

 6     then I started working in the committee in Vozdovac as the senior

 7     political advisor.  Then I was --

 8        Q.   Mr. Lekovic, we have your CV in the statement.  None of the posts

 9     which are listed there, principally from 1 to 5 --

10        A.   I'm not receiving interpretation.

11        Q.   Let me try that again.  We have your CV laid out in the

12     statement.  Am I correct, then, from what you've just told us, that none

13     of those posts prior to November 1988 engaged you in any way with state

14     security business?

15        A.   Yes.  Not a single position which I occupied until then had

16     anything to do with state security, because the position was, and that

17     position was assumed after the 8th session when Ivan Stambolic was

18     replaced along with the Belgrade administration Dupar --

19             JUDGE ORIE:  Witness, Witness, Witness, I'm going to stop you.

20     Why?  Because the simple question was whether any of these functions had

21     to do anything with state security.  I think you started your answer

22     with, "Yes.  Not a single position which I occupied until then had

23     anything to do with state security," and then you started an explanation,

24     an explanation which was not asked from you.  And if Mr. Jordash would

25     like to know an explanation, he will ask for it.  So a simple "yes" would


Page 14245

 1     have done already.

 2             So, therefore, would you please careful listen to the question.

 3             THE WITNESS: [Interpretation] I understand.  I'll be more

 4     rational.

 5             JUDGE ORIE:  And more confined in your answers.

 6             Mr. Jordash.

 7             MR. JORDASH:  Thank you.

 8        Q.   Now, paragraph 8 of your statement refers to you being a member

 9     of the League of Communists of Yugoslavia up until 1990.  Did you hold a

10     function within that party at the time you became the head of the

11     State Security Service for the city of Belgrade?

12        A.   No, I did not have any position in the party.  I was president of

13     the Municipal Assembly of Vozdovac, elected on the 1st of April, 1986,

14     and from then on -- from that position I was appointed chief of the

15     State Security Service for Belgrade.

16        Q.   Who was the head of the League of Communists of Yugoslavia at the

17     time you were appointed to the DB?

18             THE INTERPRETER:  Could counsel please switch off microphone

19     whenever he's finished with a question.

20             THE WITNESS: [Interpretation] I'm not sure.  Tito died in 1980,

21     and after him, from every republic, presidents of the central committee

22     of the League of Communists of Yugoslavia were elected, rotating every

23     year.

24             MR. JORDASH:

25        Q.   Was Milosevic in the party?


Page 14246

 1        A.   You mean at the time when I was appointed chief of the state

 2     security?

 3        Q.   Yes, I'm focusing on that appointment, and I'm interested in you

 4     explaining to the Court how the party worked, inasmuch as it was able, to

 5     have you in some way appointed to the state security?  You follow my

 6     theme?

 7        A.   Yes, I understand the question now.

 8        Q.   Did Milosevic have a position within that party?

 9        A.   Let me just tell you one thing.  Because of certain things that

10     happened within the State Security Service for the city of Belgrade, the

11     stance was taken that the chief of the service should not be elected from

12     within the service but from the outside, because they had a certain

13     baggage, the State Security Service of Belgrade.  There was a famous

14     satire published in the newspapers about --

15        Q.   Mr. Lekovic, let me take you where I want you to go, please.

16             The stance -- you stay the stance was taken that the chief of the

17     service should not be from -- elect -- should not be elected from within

18     the service.  Who took that stance?

19        A.   That stance was taken at the level of the Republic of Serbia by

20     people who were charting personnel policy, as we called it then.

21        Q.   And who at the level --

22        A.   To be quite clear:  If Lekovic had not been there, somebody else

23     would have been appointed chief of the State Security Service for the

24     city of Belgrade from the political structures.

25        Q.   Who at the level of the Republic of Serbia was making these


Page 14247

 1     decisions?

 2        A.   At the level of Serbia there were certain bodies for preliminary

 3     consultations, whereas specific decisions on appointments to state

 4     authorities were made by the republic Executive Council, that is, the

 5     republic government, following those consultations.

 6        Q.   Which were the bodies for the preliminary consultations?

 7        A.   Well, in this specific case, when consultations were conducted

 8     for the appointment of the minister of the interior who was appointed in

 9     March 1988, whereas I was appointed a little later, after being

10     officially appointed by the government on the 18th of October,

11     politicians from the republic political structures conducted

12     consultations, and those consultations involved discussions about several

13     nominees for each position.  And from those shortlists one person would

14     eventually be appointed to each position.

15        Q.   And when you say "political structures," are you talking about

16     political -- a political party or political parties?  Be specific,

17     please.  What are these political structures?

18        A.   Well, at the time when the League of Communists existed, there

19     was also the Socialist Alliance of the Working People, which was an

20     umbrella organisation, the broadest one we had.  There was the

21     trade union association, the president of the Republic of Serbia, the

22     president of the Executive Council, the president of the city assembly,

23     the president of the municipal party organisation.  Those were the people

24     who took part in the debates preceding political appointments.

25        Q.   And these people who you've just mentioned, these posts,


Page 14248

 1     presidents of various entities, did they belong to one political party or

 2     did they belong to different political parties?

 3        A.   Let's be clear:  Before 1990, when the SPS was established, all

 4     officials were members of the League of Communists.

 5             On the 17 of July, 1990, there was the first congress of the SPS,

 6     the Socialist Party of Serbia was thereby established, and the League of

 7     Communists was discontinued and the socialist party was created instead.

 8     During that period, from the year 1990 up to the creation of the

 9     multi-party system, all the officials both in the republic and in the

10     city were members of the SPS.

11        Q.   Which year was the multi-party system created?

12        A.   The multi-party system, or political pluralism, as it is also

13     known, came into being in 1989 and 1990.  The first multi-party elections

14     in Serbia took place on the 24th of December, 1990.

15        Q.   Let me just clarify something.  You've said that before 1990,

16     when the SPS was established, all officials were members of the

17     League of Communists.  At the same time, you say you were the second

18     political appointment to the State Security of Serbia.  Am I summarising

19     what you've said correctly?

20        A.   Yes, but the first appointment was in 1966 after the

21     Brioni Plenum and the removal of Aleksandar Rankovic from position.

22     That's when a person from political structures was appointed into the

23     state security who was not an intelligence professional.  You can find it

24     in the statement.  You should have read my statement more carefully.  I'm

25     sure you would have found it.


Page 14249

 1        Q.   I'm not asking you about 1966.  I've read the statement.  I know

 2     it's in there.  Listen to my question, if you would, Mr. Lekovic.  What

 3     I'm trying to --

 4        A.   Go ahead.

 5        Q.   What I'm trying to reconcile or have you explain is, on the one

 6     hand you say that officials were all SPS and at the same time you say the

 7     state security were not making appointments that were political other

 8     than yours and one other at the time we are talking about, 1988.

 9        A.   Mr. Jordash, now I have been criticised again or you are putting

10     me in a situation where Mr. President might again criticise me for being

11     too verbose, but I have to expand on my answer if you want to understand

12     me properly.

13             At a meeting of the Government of Serbia on the 18th of October,

14     I was appointed.  And then on the 1st of November, 1988, I took my

15     office.  And from the position of the president of the municipality of

16     Vozdovac, I joined the state security of the city and I took my new

17     office as per the government decision.

18             We have to make a distinction here.  The League of Communists,

19     when that existed, that was a mono-party system.  When the SPS was

20     established on the 17th of July, 1990, that was the year when all the

21     political turmoil started.  And the first multi-party election - I have

22     to repeat that - took place on the 24th of December, 1990.

23             It's very -- it's rather difficult to understand, especially by

24     anybody who did not live in our circumstances.

25        Q.   Okay.


Page 14250

 1             MR. JORDASH:  Your Honour, I notice the time.  Perhaps ...

 2             JUDGE ORIE:  You suggest to take a break.

 3             MR. JORDASH:  Yes.

 4             JUDGE ORIE:  Then we'll break.  And we resume at 4.00.

 5                           --- Recess taken at 3.36 p.m.

 6                           --- On resuming at 4.10 p.m.

 7             MR. BAKRAC: [Interpretation] Your Honour.

 8             JUDGE ORIE:  Mr. Bakrac.

 9             MR. BAKRAC: [Interpretation] With your leave, Mr. Petrovic and

10     myself have consulted our client and we would like to voice our concerns

11     with regard to the testimony of this witness and whether his testimony

12     can finish in the course of the day today or by the end of the day

13     tomorrow.  We would like to say for the record that we will not have any

14     questions in cross-examination unless a question is prompted by the

15     Prosecution's cross-examination, in which case we will seek

16     clarification.  Otherwise, we will not have any questions for this

17     witness.

18             JUDGE ORIE:  Yes, I'm a bit surprised by the expression that you

19     voice your concerns, because you are removing any concerns all others in

20     this courtroom might have.  That seems to be the situation.  Thank you

21     very much for assisting, Mr. Bakrac.

22             Ms. Marcus.

23             MS. MARCUS:  Thank you, Your Honour.  I just wanted to mention

24     that we've sent -- after the request by the Defence, we sent through both

25     the B/C/S and English versions on a secure e-mail to the Belgrade field


Page 14251

 1     office.  And although I believe that the Registrar who's there cannot

 2     receive it directly, we have sent it to somebody in the office whom I

 3     hope will provide it, if that's of any assistance.

 4             JUDGE ORIE:  Yes, although I suggest that we do not engage in a

 5     new exercise to compare.  But as matters stand now, I think we should be

 6     able to resolve -- not to say that it's very helpful, because the -- now

 7     at least a copy is available, and we could even invite Madam Registrar at

 8     the other side already to do the comparison.

 9             Is this understood by the Registry at the other side -- at the

10     other end of the videolink?

11             THE REGISTRAR: [Via videolink] Yes, Your Honours, would you like

12     me to compare the documents?

13             JUDGE ORIE:  Yes.  If you would do so, not necessarily

14     immediately but before we start tomorrow, so that you see whether the

15     copy you received from the witness is, as far as the text is concerned,

16     of course, we have noticed already that there are differences in

17     signatures and initials on the various pages, but whether, as far as the

18     text is concerned, the two versions are identical.

19             THE REGISTRAR: [Via videolink] Yes, Your Honour.  I would just

20     like to put on the record I haven't received yet --

21             JUDGE ORIE:  No, but --

22             THE REGISTRAR: [Via videolink] -- by e-mail, anything.  But as

23     soon as I receive, I will do that.

24             JUDGE ORIE:  That's what I hinted at.  Thank you.

25             Mr. Jordash, please proceed.


Page 14252

 1             MR. JORDASH:  Thank you.

 2        Q.   Mr. Lekovic, I want to try to move quickly through this section

 3     we've been discussing concerning your appointment through political

 4     structures.  Are you familiar with the 8th session of the

 5     Communist League of Serbia in 1987?

 6        A.   Yes, I'm familiar with it, but I don't know what to say next.

 7     Shall we perhaps go into private session if you want me to answer any

 8     questions about it?  You can ask me anything you want.

 9             JUDGE ORIE:  Witness DST-052, even without your invitation

10     Mr. Jordash knows that he can ask you whatever he ... the answer,

11     therefore, is "yes."  And then you wait for the next question.  And then

12     if there's any need to go into private session, although I do not see yet

13     any of the criteria being met ...

14             Please proceed, Mr. Jordash.

15             MR. JORDASH:

16        Q.   Did Milosevic attend that session?

17        A.   Not only did he attend the session, he chaired it all the time.

18        Q.   What was -- apart from him being the chair, did he hold any other

19     function or position at that point relevant to that session?

20        A.   The most relevant position he held at the time was that of the

21     president of the League of Communists.  And he was also the president of

22     the central committee of the League of Communists.

23        Q.   Was Stambolic present at the session?

24        A.   Yes, Ivan Stambolic was also present.

25        Q.   What position did he hold at the time?


Page 14253

 1        A.   Ivan Stambolic was the president of the central committee of the

 2     League of Communists before Milosevic.  And then when Milosevic was

 3     elected the president of the central committee, then Ivan Stambolic was

 4     elected president of the Serbian Presidency.  Which means that at the

 5     time of the 8th session Buce Pavlovic [phoen], the president of the city

 6     board of the League of Communists of Belgrade, was the president of the

 7     SRS of Serbia, and Stambolic was removed at the 8th session.

 8        Q.   How was it that Stambolic was removed?  Did Milosevic play a part

 9     in that removal?

10        A.   We have to look at two different aspects here.  Milosevic chaired

11     the session.  The session lasted two days and two nights without any

12     breaks.  Zoran Sokolovic read the main speech.  There was a debate and a

13     vote, and a majority of the members of the central committee supported

14     Milosevic's concept.  And Mr. Stambolic won not more than six votes.  And

15     as a result of that, he was degraded as a member of the League of

16     Communists.

17             Immediately after that, he was removed from the state office that

18     he had held until then.

19        Q.   And what happened to Milosevic as a consequence of what happened

20     at that session or as a consequence of the removal of Stambolic?

21        A.   Nothing happened to Milosevic.  He remained in his position.  And

22     his position as a result of that became even stronger.  He became number

23     one person in both the political structures as well as in the state

24     structures.

25        Q.   What position did Sokolovic hold at the time of this session?


Page 14254

 1        A.   Zoran Sokolovic at the time was the secretary.

 2             Are you able to follow what I'm saying?

 3        Q.   I beg your pardon, Mr. Lekovic.  I was just consulting with a

 4     colleague.  Please go ahead.  Excuse my rudeness.

 5        A.   No, no, no, I just want the two of us to understand each other

 6     properly.

 7             Zoran Sokolovic, or, rather, the president of the party is the

 8     number one position in the League of Communists, and Sokolovic was number

 9     one -- number two person and he held number two position.  He was the one

10     who read the keynote address at the session when Ivan Stambolic and

11     Buce Pavlovic or Dragisa Pavlovic, also known as Guce [phoen], were both

12     removed from their positions.

13        Q.   Were you present at the session?

14        A.   No, I was not a member of the central committee.  At the time I

15     was the president of the municipality of Vozdovac.  The entire session

16     was aired on TV.  Everybody could follow.  There was a great deal of

17     interest in the session and its outcome, so I was one of those who

18     followed the session with a great deal of interest.

19        Q.   We'll come to some of these names later.  But Janackovic, was he

20     present?

21        A.   At the 8th session?  Believe me, I don't know.

22        Q.   Okay.  Fair enough.  Let's now --

23        A.   Please, please, can we go into private session just for a moment,

24     a minute or two.

25             JUDGE ORIE:  We move into private session.


Page 14255

 1            [Private session]    [Confidentiality lifted by order of the Chamber]

 2             THE REGISTRAR:  Your Honours, we are in private session.

 3             JUDGE ORIE:  Thank you, Madam Registrar.

 4             We are in private session at this moment, Mr. Lekovic,

 5     therefore --

 6             THE WITNESS: [Interpretation] Then I can answer the question or

 7     not?  I wanted to go into private session to explain why.

 8             JUDGE ORIE:  Mr. Lekovic, the question was -- let me see.  One --

 9             THE WITNESS: [Interpretation] Whether Zoran Janackovic was one of

10     the --

11             JUDGE ORIE:  One second.  The question was whether Janackovic was

12     present at the 8th session.  Your answer was "I don't know."

13             I do not know whether Mr. Jordash is seeking any further

14     explanation --

15             THE WITNESS: [Interpretation] But I wanted to say something to

16     provide you with --

17             JUDGE ORIE:  Well --

18             THE WITNESS: [Interpretation] I wanted to say something.

19             JUDGE ORIE:  Yes, but you are --

20             THE WITNESS: [Interpretation] I wanted to say that

21     Zoran Janackovic was a lawyer who was previously the secretary of the

22     Assembly of Serbia and then he was the president of the regional party

23     organisation in eastern Serbia, and he may have been present at the

24     8th session but I don't know whether he was or not.  So I can actually

25     not answer the question with either yes or no.  I can only say that he


Page 14256

 1     was not a member of the central committee or the central board.  That's

 2     as much as I know.

 3             JUDGE ORIE:  Yes, one --

 4             THE WITNESS: [Interpretation] -- because the 8th session was

 5     organised --

 6             JUDGE ORIE:  Mr. Lekovic, Mr. Lekovic --

 7             THE WITNESS: [Interpretation] Go ahead.

 8             JUDGE ORIE:  We moved into private session where you had answered

 9     the question and the further explanation seems not to be of -- why you do

10     not know is not of a primary interest.  The fact that you don't know.

11     And we accept if you don't know something, then you don't know.  That

12     doesn't need any further explanation.  If Mr. Jordash would like --

13             THE WITNESS: [Interpretation] Very well, thank you.

14             JUDGE ORIE:  -- would like any further explanation as to the

15     functions held by Mr. Janackovic, he'll ask you for it.  Most likely

16     there's no need to go into private session.

17             May I urge you again to focus your answer on the questions.  If

18     you've answered the question and if you think that you could further

19     explain, wait whether any explanation is further sought by the party that

20     did put the question to you.

21             We move into open session.

22             JUDGE ORIE:  Mr. Jordash --

23                           [Open session]

24             THE REGISTRAR:  Your Honours, we are back in open session.

25             JUDGE ORIE:  Thank you, Madam Registrar.


Page 14257

 1             Please proceed, Mr. Jordash.

 2             MR. JORDASH:

 3        Q.   Okay.  Mr. Lekovic, let's try to wrap up this particular subject

 4     because I want to spend the remainder of the time speaking about the

 5     commission.

 6             Firstly, which entity or which persons do you say were

 7     responsible for your appointment to the state security in 1988?

 8        A.   Responsible?

 9        Q.   Yes.  You were appointed, as you've told us, by the political

10     structures.  Can you put a name on the entity or a name on the

11     individuals who you say were most responsible for that appointment?

12        A.   There were interviews with potential candidates.  There were a

13     number of candidates running for the State Security Service of the city

14     of Belgrade.  I was among the interviewees.  And then there were

15     consultations of sorts.  I asked my comrades or the gentlemen who

16     participated in that interview not to be mentioned as a candidate before

17     the bodies who were supposed to make that decision because that was not

18     my area of interest, and I had different plans for the future --

19             JUDGE ORIE:  Mr. Lekovic --

20             THE WITNESS: [Interpretation] -- based on what I had been doing

21     until then.

22             JUDGE ORIE:  Mr. Lekovic, the question was not what plans you had

23     for the future.  The question simply was whether you could name

24     institutions or persons who were responsible, that is, who decided or

25     were directly involved in a decision to appoint you.  That was the


Page 14258

 1     question.  And could you please answer that question.

 2             THE WITNESS: [Interpretation] Okay.  The shortest answer would be

 3     this:  Dr. Rados Smiljkovic, the then-president of the city board of the

 4     League of Communists of Belgrade, interviewed me.  He assumed the

 5     position after the 8th session.  He was the one who discussed things with

 6     me.  And then I was interviewed by the new republican secretary

 7     Mr. Radmilo Bogdanovic, who replaced Lalovic, who was removed from the

 8     position as secretary after the 8th session.

 9             After that, there was a board composed of certain persons, and I

10     have to say their names now.  That interview did not concern only my

11     position but also other issues.  One of them was the appointment of the

12     secretary of the state security of the city of Belgrade.  So the persons

13     who were present at that interview were --

14             JUDGE ORIE:  Mr. Lekovic, I again invite you not to tell us for

15     what other appointments persons may have been responsible.  Let's keep

16     matters short.  You were interviewed by Mr. Mirkovic [phoen] --

17             THE WITNESS: [Interpretation] But this is about me.  You're

18     asking me a direct question.  I'm talking about myself.

19             JUDGE ORIE:  The question --

20             THE WITNESS: [Interpretation] What Mirkovic?

21             JUDGE ORIE:  The question was --

22             THE WITNESS: [Interpretation] Dr. Rados Smiljkovic.

23             JUDGE ORIE:  Yes.  The question was:  Who was directly involved

24     or responsible for your appointment.  You told us that you were

25     interviewed by Mirkovic.  You were interviewed by -- the other person was


Page 14259

 1     --

 2             THE WITNESS: [Interpretation] And he asked me whether I -- I

 3     accepted.  And then there was a session of the Government of Serbia, the

 4     Executive Board of Serbia, where a decision was made on the

 5     18 of October, and my CV was read out and it was said that Mr. Lekovic

 6     would thereby be appointed the chief of the state security of Belgrade

 7     and the assistant minister of the interior of Serbia, and that

 8     development closed the circle.

 9             JUDGE ORIE:  That's an answer to the question.

10             Please proceed.

11             MR. JORDASH:  Thank you.

12        Q.   You mentioned a board with certain persons on it, the Executive

13     Board of Serbia where a decision was made.  Who was on the

14     Executive Board of Serbia?

15        A.   It's not an executive committee; it was the co-ordinating body

16     for personnel issues that conducted consultations.

17        Q.   Who was on it?

18        A.   I've just said the people who occupied positions at that moment,

19     and I can name those who were there at that time.

20        Q.   Would you please.  Yes, please.

21        A.   President of the Presidency of Serbia.

22        Q.   Name?

23        A.   President of the Assembly of Serbia, president of the

24     government --

25        Q.   [Previous translation continued] ... Mr. Lekovic --


Page 14260

 1        A.   -- president of the central committee, president of the --

 2        Q.   Mr. Lekovic, could you give some names, not the positions, the

 3     names, please.

 4        A.   I had started.  Those present, before it was put to the executive

 5     committee for a final decision:  Petar Gracanin; Slobodan Milosevic;

 6     (redacted)

 7     Dr. Bogdan Trifunovic; the republic secretary at that time,

 8     Radmilo Bogdanovic; and Aleksandar Bakocevic, president of the city

 9     government; and Rados Smiljkovic.  Those people made the final decision

10     in those consultations, and then that would be passed on to formalise the

11     appointment.

12        Q.   Thank you.  Why was it, Mr. Lekovic, that those who made the

13     decision to place a political appointee within the DB, why was it that

14     they wanted to do that?

15        A.   Well, an assessment was made, but certain disruptions had

16     occurred in the work of the service for Belgrade, because the head of the

17     State Security Service of the city is my number one.  Then there was the

18     assistant republic secretary, then the member of the collegium, chief of

19     the State Security Service of Serbia, member of the administration for

20     Belgrade --

21             THE INTERPRETER:  And another person the interpreter didn't hear.

22             THE WITNESS: [Interpretation] The assessment was made that the

23     service had certain bad baggage because of disruptions and certain bad

24     methods used.  And there was that satire published --

25        Q.   [Previous translation continued] ... no, Mr. Lekovic.


Page 14261

 1     Mr. Lekovic, please, please --

 2        A.   -- in the media concerning the academician --

 3        Q.   Mr. Lekovic, could you be concrete about the bad baggage that was

 4     perceived by these political structures?

 5        A.   About whom or about what?

 6        Q.   You mentioned bad baggage.  I'm trying to work out -- I'm trying

 7     to have you explain in concrete terms, and briefly, if you would, why the

 8     political structures perceived it was important to have a political man

 9     in such an important position as the chief of the Belgrade centre.

10             Would you like to explain that in two or three sentences, please.

11        A.   Well, there was that baggage, as I said.  Anyway, I explained

12     that the head of the service for Belgrade was also a member of various

13     other bodies and had various other duties, and the stance was taken that

14     it should be a person from outside the service.  And if it hadn't been

15     me, it would be somebody else.  But, again, an outsider to the service.

16        Q.   Why?  Why, Mr. Lekovic?  Why?

17        A.   What?  Well, I did not apply for an open vacancy.  I was

18     proposed, and the Government of Serbia appointed me.  I did not apply for

19     the position.

20        Q.   What were you told to do within the service?  Were you expected

21     by these political structures to do something?

22        A.   I don't know what you mean.  But if you mean that I was supposed

23     to do something on behalf of the political structures, they did not need

24     that.  But it was said during the consultations that it should be a

25     newcomer to the service, a younger person, but with a certain experience,


Page 14262

 1     that has some renown in Belgrade, that they know the organisation and the

 2     structure of the authorities and how the system works, that this person

 3     should be able to establish -- to set up a team, to be able to manage it,

 4     and to be able to gather around him capable people.  But nothing specific

 5     was asked of me during the consultations, nor was it politically

 6     conditioned upon doing something that I should become a nominee.

 7        Q.   You tell us at paragraph 11 of your statement that Stanisic,

 8     Jovica Stanisic, had been envisaged for the post that you took.  Why was

 9     he passed over in favour of you?

10        A.   You did not understand item 10.  I explain, in item 10, when

11     Mr. Stanisic and I first met and on what occasion and why.  And in

12     item 12 --

13        Q.   Please, I'm looking at paragraph 11 where you say --

14        A.   I'm coming to that.

15        Q.   Yeah, well, I want to go straight there.  Please listen to my

16     question, if you would.

17        A.   Yes, please.

18        Q.   You say, based on a conversation with a member of the service,

19     you knew that Stanisic had been envisaged for the post that you took.

20     The question I'm asking is:  Why was it you were the preferred appointee

21     or appointment rather than Stanisic?

22        A.   This is not well phrased.  The thing is --

23             JUDGE ORIE:  Mr. Lekovic, Mr. Lekovic, would you first answer the

24     question before you --

25             THE WITNESS: [No interpretation]


Page 14263

 1             JUDGE ORIE:  But, Mr. Lekovic, would you first try to answer the

 2     question before criticising it.

 3             THE WITNESS: [Interpretation] Well, please, Mr. President, I'm

 4     not criticizing the question.  I just want to give the necessary

 5     explanation to understand my answer.  And the answer is as follows:  I

 6     had information that Jovica Stanisic, as one of the most prominent people

 7     in the service and one of the best professionals, had been envisaged to

 8     become chief of the service for the city of Belgrade after the

 9     8th session.  And if the post was to be filled by a man from the service,

10     I was told that it was going to be Jovica Stanisic because he was

11     designed to take that place.  But I did not threaten him in any way --

12             JUDGE ORIE:  Mr. Lekovic --

13             THE WITNESS: [Interpretation] -- by occupying the position,

14     because it was not a vacancy openly announced.

15             JUDGE ORIE:  Mr. Lekovic, I'm again going stop you.  The question

16     was not whether Mr. Stanisic would have appointed if someone of the

17     service would have been appointed.  The question is why you were

18     appointed rather than Mr. Stanisic, who, as I -- as we read in your

19     statement, had been envisaged for the post as well.  That's the question.

20     Could you please answer that question.

21             THE WITNESS: [Interpretation] Well, I could answer your question

22     with a question.  I did not come instead of Stanisic, because all this

23     took place at the same time.  Stanisic was not appointed to that place,

24     to that post, and then removed so that I could come.  There were

25     discussions about various nominees and various arrangements for that


Page 14264

 1     post, both inside and outside the service.  And, again, I'm saying,

 2     because it was decided it should be a man from outside the service, if it

 3     hadn't been me, it would have been someone else, because there had been

 4     other candidates.

 5             If they had decided to put in a man from the service --

 6             JUDGE ORIE:  Mr. Lekovic --

 7             THE WITNESS: [Interpretation] -- then I think, and I was told, it

 8     would be Stanisic.

 9             JUDGE ORIE:  Mr. Lekovic --

10             THE WITNESS: [Interpretation] Or perhaps you don't understand

11     what I'm trying to say.

12             JUDGE ORIE:  I think I fully understand what you're trying to

13     say.  My problem is not that I do not understand it, but my problem is

14     that you're saying far more than what you're asked.

15             I do understand that whatever may have --

16             THE WITNESS: [No interpretation]

17             JUDGE ORIE:  Could you please -- could you please let me

18     finish. -- whatever may have been decisive in appointing you, that you

19     say it's for certain that someone had to be appointed outside the

20     service, and that was the reason why Mr. Stanisic was not appointed,

21     because he was from inside the service.  Is that your answer?

22             THE WITNESS: [Interpretation] Is that my what?

23             JUDGE ORIE:  Whether that is your answer to the question.  But I

24     put it a bit short.

25             THE WITNESS: [Interpretation] Is the question finished?


Page 14265

 1             JUDGE ORIE:  Mr. Jordash, put your next question to the witness,

 2     please.

 3             MR. JORDASH:  Certainly.

 4        Q.   Let me ask a question then:  Why was it that the political

 5     structures wanted somebody from outside the service, rather than inside

 6     the service, to take that post?

 7        A.   I don't know how to explain that.  That's the shortest answer.

 8        Q.   Okay.  Let's move on then.  Let's try a different question.  Try

 9     to assist the Court, if you would, Mr. Lekovic.  Paragraph 12 of your

10     statement notes:

11             "When Zoran Janackovic became the head of the service,

12     Jovica Stanisic was bypassed whenever that was possible."

13             Why was that?

14        A.   It was not only my impression.  It was an impression shared by

15     others in the service.  Because I had been already in the service when

16     Zoran Janackovic became the head of the service for Serbia.

17        Q.   Why was that?  Answer the question directly if you would, please.

18        A.   You know who is best place to answer that question?

19     Zoran Janackovic.  But from what I know and from what I could see,

20     Jovica was an assistant.  There is the chief of the service, assistant

21     chief, and two deputies.  Jovica was in charge of counter-intelligence,

22     and those were people both in the head office at the Serbian level and

23     Belgrade who had the impression that Janackovic was passing

24     Jovica Stanisic over because he was in awe, in a way, of his high

25     professionalism.  He wanted at the same time to use him as a professional


Page 14266

 1     but also to play down, somehow, his abilities.

 2        Q.   Let's move -- thank you for the answer.  Let's move to the

 3     commission.

 4             Why was it that Janackovic wanted to remove Stanisic from the

 5     service?

 6        A.   Janackovic was appointed chief of the service in a very turbulent

 7     time, when a number of parties were founded on the political scene of

 8     Serbia.  He was feeling a bit inferior to the post he was occupying and

 9     the duties involved, and we all noticed that he wanted to marginalise

10     Jovica Stanisic and to dominate, which he couldn't do because he was not

11     up to that post.  And Jovica Stanisic was a better man than both him and

12     the other deputies.  And I and other people in the service noticed that.

13     That's why Janackovic first tried to sideline and then to remove Stanisic

14     altogether.

15        Q.   Did Janackovic come from within the service or from outside the

16     service?

17        A.   We've been through this before, but Janackovic was appointed by

18     the government as a man from outside the service.  He came to that post

19     from another political position, so he was also an outsider to the

20     service.

21        Q.   Now, briefly, Mr. Lekovic, what powers did the commission have?

22             THE REGISTRAR: [Via videolink] [No interpretation]

23             THE WITNESS: [Interpretation] The formal decision to set up the

24     commission adopted --

25             JUDGE ORIE:  Madam Registrar at the other side of the videolink,


Page 14267

 1     you apparently intervened in a language which was not translated to us,

 2     but may I take it that you kept the witness off from consulting any piece

 3     of paper, is that ...

 4             THE REGISTRAR: [Via videolink] Yes, Your Honour.

 5             JUDGE ORIE:  Yes.

 6             THE REGISTRAR: [Via videolink] Witness wanted to consult another

 7     piece of paper.  I just advised him that if he wants to consult another

 8     piece of paper, he needs to ask for permission from the Chamber.

 9             JUDGE ORIE:  Yes.  And that's the right instruction.

10             Mr. Lekovic, if you want to consult any piece of paper, you

11     should address the Court, ask for permission, and then under those

12     circumstances tell us --

13             THE WITNESS: [No interpretation] ...

14             JUDGE ORIE:  Would you -- Mr. Lekovic, what about waiting until

15     I've finished what I wanted --

16             THE WITNESS: [Interpretation] Sorry, I didn't know that.

17             JUDGE ORIE:  Yes.  The instruction therefore is as you were told

18     by the representative of the Registry.

19             Please proceed.

20             MR. JORDASH:

21        Q.   Mr. Lekovic, what is it you wanted to look at just a moment ago?

22     So we can be clear.

23        A.   Could you let me just look at the formal decision to set up that

24     commission, to be able to better answer your question?

25        Q.   Please, have a look at the decision.


Page 14268

 1             MR. JORDASH:  And this, I think, is D00280 [Realtime translation

 2     read in error "D0028 T"] MFI.

 3             JUDGE ORIE:  Madam Registrar, Mr. Jordash has meanwhile invited

 4     the witness to look at what appears to be the formal decision which did

 5     set up that commission.  You can take that document, and it is D28 MFI'd.

 6             Mr. Lekovic, you can consult that decision.

 7             THE REGISTRAR: [Via videolink] I apologise, Your Honour.  D280

 8     MFI'd?  Was it correct number?

 9             JUDGE ORIE:  No, I think it was on the transcript D0028.

10             THE REGISTRAR: [Via videolink] I apologise, Your Honour, I only

11     have --

12             MR. JORDASH: [Overlapping speakers] ... Your Honour was right,

13     it's 280.

14             THE REGISTRAR: [Via videolink] -- 00 --

15             JUDGE ORIE:  280.  D280 is the document the witness will now

16     consult.

17             You see, Mr. Lekovic, any document to be consulted will be

18     provided to you primarily by the representative of the Registry.

19             MR. JORDASH:

20        Q.   So let's ask some questions, Mr. Witness.  Are you familiar with

21     Article 58 of the Rules of the Organisation and Work of the

22     State Security Service of Serbia?  A simple "yes" or "no" will suffice,

23     in the first instance.  Are you familiar with that rule or not?

24             Mr. Lekovic, are you familiar with that rule or not?

25        A.   Sorry, I didn't understand you were asking me [as interpreted].


Page 14269

 1     First of all, I wanted to see the decision adopted on the

 2     2nd of April, 1991.  Just briefly, to answer the question by Mr. Wayne,

 3     that commission was set up for the purpose of establishing whether an

 4     authorised officer communicated in an unauthorised way or conveyed or

 5     made available to another person information --

 6             JUDGE ORIE:  Is this what you -- you asked the witness something

 7     different.

 8             MR. JORDASH:  Yes.

 9             MR. Lekovic, we --

10             JUDGE ORIE:  And could we -- at the same time, could we have on

11     our screens the English version as well.

12             THE WITNESS: [Interpretation] The previous question regarding the

13     decision --

14             MR. JORDASH:

15        Q.   Mr. Lekovic, let me, as I said before, point you to the

16     information that I hope will assist the Court.  We are going to run out

17     of time else, okay?

18             MR. JORDASH:  Okay.  Apparently in order to have the B/C/S

19     version on the screen -- sorry, the English version, we will need to call

20     up 1D04871.

21        Q.   Now, Mr. Lekovic, the question I asked is:  What powers did the

22     commission have?  Now, we can see from the documentation, page 2, certain

23     powers that the commission had, such as inspecting all available --

24     sorry, the B/C/S page 1, English page 2.  Inspect all available and

25     necessary documents, interview employees of the service, provide all


Page 14270

 1     material evidence, and so on.  In order to achieve those requirements,

 2     what powers did the commission have?  For example, powers of summonsing,

 3     things like that.

 4        A.   Since these purposes listed in the decision about the

 5     establishment of the commission and its composition were rather general

 6     and vague, the commission adopted the conclusion at its first meeting

 7     that we should talk to the republic secretary and give him a list of

 8     questions that need to be clarified and that were controversial.  We

 9     agreed on those questions at the commission meeting and talked to the

10     republic secretary for three hours.  That discussion was audio recorded

11     and the tape is available, with minutes that are attached.

12        Q.   Mr. Lekovic, did the commission have powers to summons documents

13     or summons people in order to clarify the circumstances that the

14     commission was investigating?

15        A.   The first meeting of the commission was held --

16        Q.   Mr. Lekovic, please.  Did the commission -- and answer the

17     question directly, please.  Did the commission have powers to summons

18     people or documents?

19        A.   It had powers to require documents from the administration for

20     analysis, both from the service for Belgrade and the head office of the

21     service.

22        Q.   Did it have powers to --

23        A.   Yes, the commission had those powers.

24        Q.   Did it have powers to place intercepts or to instigate the

25     placing of intercepts to gather further evidence?


Page 14271

 1        A.   Under 3 of the decision, the tasks were not elaborated.  The

 2     commission did not engage in the application of those measures.  We did

 3     not intercept conversations therefore.  As a commission, we did not

 4     resort to those means.

 5        Q.   Let me take you to paragraph 28 of your statement.  The statement

 6     begins -- this is 1D05104:

 7             "When the decision was issued, the commission members were

 8     appointed and a task was set.  Jovica Stanisic was not suspended,

 9     although chief of the SDB, Zoran Janackovic, had already marginalised

10     him.  This meant that he would not be given any current or special tasks

11     and that Jovica Stanisic was not in a position to issue tasks and

12     assignments to operatives."

13             First of all, when you mentioned current tasks, what precisely

14     did you mean?

15        A.   Well, Jovica was assistant for counter-intelligence.  Before the

16     commission was set up, he was fully engaged and he had a lot of room to

17     talk to chiefs of administrations and to chiefs of units and to give them

18     certain tasks and assignments.  When the commission was set up and when

19     Janackovic held the first meeting with us, after that a vacuum happened

20     in communication between Jovica's assistant for counter-intelligence and

21     the rest of the team, and we realised that the communication between the

22     two men was interrupted, which was not logical at all.

23        Q.   What do you mean when you say, Mr. Lekovic, that the

24     communication was interrupted?  Did Mr. Stanisic, after the commencement

25     of the commission, attend meetings with Janackovic?


Page 14272

 1        A.   When the commission was officially set up and when it started

 2     operating, we noted that Janackovic avoided normal conversation with

 3     Mr. Stanisic at the working meetings and collegium meetings chaired by

 4     him.  They didn't even greet each other as they had before.  He

 5     marginalised Jovica both at meetings, in discussions, and at the moments

 6     when conclusions had to be finalised.

 7        Q.   What kind of conclusions was Mr. Stanisic marginalised from?

 8        A.   Well, when -- every collegium meeting held in the office of the

 9     republican secretary or the city administration obviously deals with a

10     certain number of issues, and all those who were invited or who were

11     members of the relevant body had the right to take part in the debate and

12     propose conclusions.  However, from the moment the commission was set up

13     and started operating, Janackovic closed the doors to Jovica.  He didn't

14     even give him any chance to propose anything at the meetings of the

15     collegium.  And we all had the impression that the intention was to

16     demonstrate that the commission had been set up precisely because of

17     Jovica.

18             The other members who were very familiar with the matter found

19     that simply ridiculous and quite unacceptable.

20        Q.   Returning to paragraph 28.  When you say, "Jovica Stanisic was

21     not in a position to issue tasks and assignments to operatives," what

22     kind of tasks and assignments did you have in mind?

23        A.   Well, the impression was -- the overall impression was that the

24     chief simply wanted to get rid of Jovica.  He didn't want him to be

25     there.  He didn't want him to communicate with other chiefs of


Page 14273

 1     administrations and operatives.  And with that, he was prevented from

 2     assigning every-day tasks to operatives and participate in consultations.

 3     Operatives and some chiefs of administrations even stopped coming to

 4     Jovica's office for advice, suggestions, or to share a problem which had

 5     been normal until then.  Stanisic was an experienced person and everybody

 6     had sought his opinion before that, and in that sense Stanisic was cut

 7     off.  He was blocked, as it were, in the performance of his duties.

 8        Q.   And, Mr. Lekovic, how do you know this?  What's your source of

 9     knowledge for these comments?

10        A.   The chief of the administration of the city of Belgrade was a

11     member of the collegium of the chiefs of services of Serbia.  By virtue

12     of my offices, I went to the headquarters of the service and I observed

13     that the atmosphere changed as soon as the commission was set up.  I

14     spotted certain trends in the behaviour of the people, and especially

15     Janackovic's conduct as the chief of service.  People found his conduct

16     quite odd and especially his insistence on speeding up the work of the

17     commission.  All the things were done within a week, which was close to a

18     miracle because of the complexity of the problem, the overall issues, and

19     the methods of the work employed by the commission.

20        Q.   How long did the situation last wherein Janackovic marginalised

21     Stanisic in the way you describe?

22        A.   To a certain extent, he tried to push him away even before the

23     commission was set up.  That's why he insisted on the republican

24     secretary issuing the decision on the setting up of the commission,

25     because that would have had a different weight and different


Page 14274

 1     implications, as it were.

 2             He didn't want to set up the commission as the chief of the

 3     service if the information was leaked only from his service.  And nobody

 4     from the public security sector was a member of the commission, only the

 5     five of us who were members of the service.  The commission was set up at

 6     the level of the minister of the interior, and the republican secretary

 7     issued decision on the setting up of the commission upon Janackovic's

 8     insistence.

 9             MR. JORDASH:  Can I just take instructions.  Would you wait a

10     moment, Mr. Lekovic.

11                           [Defence counsel and Accused Stanisic confer]

12             MR. JORDASH:  Thank you, Your Honour.

13        Q.   Mr. Lekovic, how long did the situation last wherein Janackovic

14     marginalised Stanisic in the way you describe?  That's the question.

15        A.   Yes, yes, yes.  I didn't fully answer your question, but,

16     Mr. Wayne, look, this started even before the commission was set up.  And

17     then the secretary took some convincing to set up the commission.  And

18     when the secretary accepted to issue a decision on the setting up of the

19     commission and its tasks, then he rushed in to holding meetings of the

20     commission himself instead of the secretary of state.  He briefed us, he

21     issued us orders, and he insisted on everything being done as fast as

22     possible, and the results be issued in a written form --

23        Q.   How long?

24        A.   -- so it started even before the commission was set --

25        Q.   How long, Mr. Lekovic?  We know when it started.  We know what


Page 14275

 1     you say happened.  We don't know how long.

 2             THE INTERPRETER:  Could the speakers please be asked not to

 3     overlap.  Could the witness please be asked not to speak while somebody

 4     else in the courtroom is speaking.

 5             THE WITNESS: [Interpretation] From the 2nd of April when the

 6     decision was issued on the setting up of the commission, throughout

 7     April, May, June, July, August, September, sometime until the beginning

 8     of the month of October.

 9             MR. JORDASH:

10        Q.   Thank you.  Are you aware, during that time, of any state

11     security task that Stanisic did perform?

12        A.   Could you please repeat your question?

13        Q.   You've told us that Mr. Stanisic was marginalised, that he

14     didn't -- he wasn't given jobs by Janackovic, and so on.  Do you know if

15     he did any state security task during the time from April until October,

16     the beginning of October?

17        A.   I have to provide you with some detail.  A piece of news was

18     heard that there were rumours that Janackovic wanted Jovica Stanisic to

19     take a leave of absence while the commission was in operation.  We saw

20     that Janackovic did not give any assignments to Jovica Stanisic because

21     there were no communication channels between the two of them.

22     Jovica Stanisic, as far as he was concerned, did not even have to turn up

23     for work.  We were all there.  The Belgrade administration shares the

24     same building with the headquarters of the service, and we could see

25     every day where people were and how people behaved both in the


Page 14276

 1     headquarters as well as in the administration.  And as far as Janackovic

 2     was concerned, Jovica Stanisic did not even have to turn up for work.

 3        Q.   Thank you.  Now, we can see from your statement and the

 4     underlying documents that the commission investigated whether Stanisic

 5     had divulged state security secrets to a journalist.  Did Janackovic give

 6     any instructions or did anyone from within the service give instructions

 7     concerning what information Stanisic was permitted to know during the

 8     course of the commission?

 9        A.   There was a lot of pressure on the commission members and the

10     commission itself, the speed of its work, and to concentrate on

11     Jovica Stanisic as if the commission had been set up solely for him.  The

12     chief of service, Mr. Janackovic, mentioned two objects, Lari and Paloma.

13     And according to what he said, they were elements for the commission to

14     define that in its work and to look at Jovica's responsibility and

15     culpability and to apply certain measures and sanctions on Jovica, which

16     is what Janackovic had always wanted.

17        Q.   Okay.  We'll come to those two objects shortly.  But was there

18     any position taken during the course of the commission concerning whether

19     Stanisic was entitled to receive state security secrets?

20        A.   From whom?  What do you mean, Mr. Wayne?  From whom was he

21     supposed to receive state secrets?

22             JUDGE ORIE:  Mr. Jordash --

23             MR. JORDASH:  Perhaps --

24             JUDGE ORIE:  -- I'll give it a try.

25             Mr. Lekovic, was Mr. Stanisic, when the commission was working,


Page 14277

 1     entitled to have access to the same information as he had before the

 2     commission started its work?

 3             And when I'm talking about information, I'm talking about state

 4     security information which was part and parcel of the job he did.

 5             THE WITNESS: [Interpretation] We have to note that

 6     Jovica Stanisic, from the moment the commission was set up and it started

 7     working and in the course of its work and even when the commission issued

 8     its report, still held his office and he was never moved or suspended

 9     from that office, from that position.  He came to work from time to time,

10     he had the same powers that he always had, but his room for manoeuvre was

11     somehow limited, and his powers were limited.  According -- on the order

12     of the chief of service, certain information and intelligence was given

13     to him and not to Jovica Stanisic as the assistant chief for that area.

14        Q.   Thank you.

15             MR. JORDASH:  I've had a note passed to me saying a break.

16             JUDGE ORIE:  Yes, then we'll take a break.  We have been informed

17     by Mr. Bakrac that he has no questions if nothing will be triggered by

18     the Prosecution.  Ms.

19             Marcus, how much time would you need?

20             MS. MARCUS:  Your Honour, for the moment I'll have to stick by my

21     original estimate, which was between two to two and a half hours.  I

22     would say two sessions.

23             JUDGE ORIE:  Mr. Jordash, I do not know how much more time you

24     need at this moment.  We come close to the point where we are in

25     dangerous waters, that is, running out of time, unless you say, No, those


Page 14278

 1     two sessions are fully available for Ms. Marcus tomorrow or even later

 2     today, part of it.

 3             MR. JORDASH:  I would hope to finish almost all of it today, with

 4     maybe just a slight slip-over until tomorrow, maybe of 20 minutes.

 5             JUDGE ORIE:  But then we are -- I mean, that is hardly any time

 6     for the Chamber --

 7             MR. JORDASH:  I'll finish today, Your Honour.

 8             JUDGE ORIE:  You'll finish today.  And we'll then immediately

 9     take a break in order to -- we are -- we resume at ten minutes to 6.00.

10                           [Witness stands down]

11                           --- Recess taken at 5.23 p.m.

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

13             JUDGE ORIE:  Ms. Marcus, you asked for -- to address the Court.

14     If it would be because you are seeking an extension of time for

15     responding to the 92 bis motion of DST-071, please tell me.

16             MS. MARCUS:  It's also, Your Honour, because I wanted to seek

17     leave to make an oral response with respect to DST-070 and DST-072.

18     Those are also 92 bis witnesses.

19             JUDGE ORIE:  Yes.  An extension of time for 71?

20             MS. MARCUS:  One week after the filing of a corrigendum, which

21     the Defence asserts would be by the 13th of October.

22             JUDGE ORIE:  Mr. Jordash, any objection against an extension of

23     time for the response to DST-071?

24             MR. JORDASH:  No, Your Honour.

25             JUDGE ORIE:  Mr. Bakrac?  You're wisely -- yes, yes, Mr. Bakrac,


Page 14279

 1     I wondered whether you would --

 2             MR. BAKRAC: [Interpretation] No, Your Honour.

 3             JUDGE ORIE:  That request is granted.  You have one week on from

 4     the filing of the corrigendum.

 5             Oral submissions, how much time would you need?

 6             MS. MARCUS:  Maybe ten minutes or so.  Maybe a little bit more.

 7     I mean, with your leave, I can make the submission tomorrow.  But today

 8     is the dead-line.  But if the Chamber so orders, of course, I can make

 9     that submission tomorrow.

10             JUDGE ORIE:  We give an extension of time of one day to

11     Ms. Marcus so that we first try to conclude the evidence of this witness.

12     I would, at this point in time, Ms. Marcus, I would really prefer that.

13     Yes, extension of time of one day is granted, and we'll see further

14     tomorrow whether it needs two days.

15             MS. MARCUS:  Thank you, Your Honour.

16             JUDGE ORIE:  Thank you very much.  And my apologies for perhaps

17     putting a lot of pressure on these matters.

18             Could the witness please be escorted into the courtroom.

19             Ms. Marcus, again, without the pressure, I would have given you

20     an hour.

21             MS. MARCUS:  Understood, Your Honour.

22                           [The witness takes the stand]

23             MR. JORDASH:

24        Q.   Mr. Lekovic, can you hear me?

25        A.   Yes.


Page 14280

 1        Q.   Would you please have a look at D00283, and the 65 ter number is

 2     1D04874.  This is -- looks as though it's a letter which went to various

 3     services requesting that they as part of this investigation also conduct

 4     their own investigations; is that right?

 5             JUDGE ORIE:  This document is not to be shown to the public,

 6     Mr. Jordash.

 7             MR. JORDASH:  Your Honour, thank you.

 8             JUDGE ORIE:  Yes, if it has already been shown, we need a

 9     redaction.  It has not yet been shown.

10             Please proceed.

11             If you ask specific questions about it, should we move into

12     private session?

13             MR. JORDASH:  Yes, although I think we can avoid mentioning

14     names, I hope.  Names of individuals.

15             JUDGE ORIE:  But if the document in itself is under seal, I don't

16     have a clear recollection of what reasons it exactly was.

17             MR. JORDASH:  Neither do I, so perhaps --

18             JUDGE ORIE:  Yes, perhaps out of an abundance of caution we move

19     into private session, and what you've said until now seems not to be of a

20     kind to require a redaction.  But it's your exhibit, Mr. Jordash.

21             MR. JORDASH:  I think that Your Honour is right.  I don't think

22     so far any redaction is required.

23             JUDGE ORIE:  I leave it in your hands as matters stand now, and

24     we move into private session.

25                           [Private session]


Page 14281

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Page 14293

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21                           [Open session]

22             THE REGISTRAR:  Your Honours, we are back in open session.

23             JUDGE ORIE:  Thank you, Madam Registrar.

24             MR. JORDASH:

25        Q.   Mr. Lekovic, you -- I want to return to the issue of


Page 14294

 1     depoliticization of the service.  How did Stanisic go about that process?

 2        A.   Firstly, SPS cells were not set up within the state service

 3     either in the organisational units either -- or in the administration for

 4     Belgrade or in the headquarters of the service.  Secondly, even if

 5     somebody was in favour of the SPS, or even a member of the SPS or some

 6     other party, they were not supposed to demonstrate that openly at work.

 7     And thirdly, the same criteria were to be applied in the work,

 8     irrespective of what political party was being investigated or which

 9     official thereof.

10        Q.   When you speak of SPS cells, what are you describing?

11             THE INTERPRETER:  Could the witness sit closer to the microphone

12     or could the microphone be brought closer to the witness.  The

13     interpreters have a problem hearing him.

14             THE WITNESS: [Interpretation] Every political party has its

15     platform, has its bodies, elected bodies, as well as local organisations

16     at lower levels.  The method of the party's work is regulated by the

17     statute of the party.  These would be local cells or boards of the SPS in

18     local communes, in companies, and institutions.  There were people who

19     were civil servants, but they were not allowed to display their party

20     loyalty at work.  They could only do that at their place of residence.

21     They could set up their boards and assist board meetings at their place

22     of residence.  They were not supposed to openly display their loyalty or

23     affiliation to a political party at work.

24             JUDGE ORIE:  I did not see any action taken upon the request of

25     the interpreters to have the microphone be closer to the witness.  I


Page 14295

 1     don't know whether this was ... I now see that action is taken.

 2             THE WITNESS: [Interpretation] Do you want me to repeat my answer?

 3             JUDGE ORIE:  No, I don't think there's any need for that, but

 4     there was request for you to come closer to the microphone or the

 5     microphone come closer to you.

 6             THE REGISTRAR: [Via videolink] It was done, Your Honour.

 7             JUDGE ORIE:  Yes, thank you.

 8             Please proceed.

 9             MR. JORDASH:

10        Q.   Mr. Lekovic, when you speak of Mr. Stanisic fighting to

11     depoliticize the State Security Service, which period are you referring

12     to?

13        A.   I'm referring to a period towards the end of 1990.  On the

14     17 of July, 1990, there was the founding congress of the SPS.  And then

15     in September there were last meetings of the League of Communists.  It

16     was then said that the party organisations of the League of Communists

17     were being disbanded, that people could go to local party offices to get

18     hold of their documents, and from then on there would be the SPS instead

19     of the League of Communists.  This was the watershed moment when the

20     wheels were put in motion in order to depoliticize the State Security

21     Service.

22        Q.   Could you say the year again when you say Mr. Stanisic was

23     fighting to depoliticize the party -- the State Security Service.

24        A.   We are talking about the three or four last months of 1990.  And

25     then in the upcoming period when things had to be proven to the general


Page 14296

 1     public, and to the citizens to show that the service was finally

 2     depoliticized, that people who were in the service were not politically

 3     engaged in any of the political parties, and also that the State Security

 4     Service put a ban on setting up a local party board.

 5        Q.   Do you know what Mr. Stanisic's position was when he took over as

 6     chief of the state security in relation to these issues?

 7        A.   I beg your pardon, what issues?

 8        Q.   Depoliticization of the State Security Service.

 9        A.   He did not have a political role to play.

10        Q.   And what about his position in relation to politics within the

11     DB?

12        A.   What position do you have in mind?  I find your question a bit

13     odd.  His position was for the service to do its work, to be a

14     professional service and to only do those things for which it was

15     originally set up and for which it existed.  Nothing more than that.

16        Q.   Were there any SPS units or cells within the DB after Stanisic

17     took over as chief?

18        A.   As far as I know, there were no cells or boards or units or

19     branches of the SPS.

20        Q.   Now, two quick subjects or quick issues in relation to your

21     Official Note.  Could you turn, please, to page 6 of the English and

22     page 6 of the B/C/S.

23             JUDGE ORIE:  Is that not to be shown --

24             MR. JORDASH:  Not to the shown to the public, please.

25             JUDGE ORIE:  Not to be shown to the public.  Do we need to move


Page 14297

 1     into private session?

 2             MR. JORDASH:  It's probably best, Your Honour, yes, please.

 3             JUDGE ORIE:  We move into private session.

 4                           [Private session]

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13                           [Open session]

14             THE REGISTRAR:  Your Honours, we are back in open session.

15             JUDGE ORIE:  Thank you, Madam Registrar.

16             Mr. Lekovic, we would like to see you back tomorrow morning, the

17     12th of October, at 9.00 in the morning, and then we'll further hear your

18     testimony through a videolink from this Courtroom II.

19             We stand adjourned.

20                           [The witness stands down]

21                           --- Whereupon the hearing adjourned at 7.05 p.m.,

22                           to be reconvened on Wednesday, the 12th day of

23                           October, 2011 at 9.00 a.m.

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