Tribunal Criminal Tribunal for the Former Yugoslavia

Page 15486

 1                           Thursday, 8 December 2011

 2                           [Open session]

 3                           [The accused entered court]

 4                           [The witness takes the stand]

 5                           --- Upon commencing at 9.03 a.m.

 6             JUDGE ORIE:  Good morning to everyone in and around this

 7     courtroom.

 8             Madam Registrar, would you please call the case.

 9             THE REGISTRAR:  Good morning, Your Honours.

10             This is case number IT-03-69-T, the Prosecutor versus

11     Jovica Stanisic and Franko Simatovic.

12             JUDGE ORIE:  Thank you, Madam Registrar.

13             Mr. Petrovic, you've got until 10.00.  Please proceed.

14             But before you do so, Mr. Milovanovic, I'd like to remind you

15     that you are still bound by the solemn declaration that you have given at

16     the beginning of your testimony.

17                           WITNESS:  MANOJLO MILOVANOVIC [Resumed]

18                           [Witness answered through interpreter]

19             JUDGE ORIE:  Mr. Petrovic will now continue.

20             MR. PETROVIC: [Interpretation] Thank you, Your Honour.

21                           Further Cross-examination by Mr. Petrovic:

22     [Continued]

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

24        A.   Good morning.

25             MR. PETROVIC: [Interpretation] I would like to call up

Page 15487

 1     65 ter 5604.  In B/C/S it's page 77.  In English it's page 79.  English

 2     79, B/C/S copy 77.  The handwritten version also page 77.  We have the

 3     correct English page but now we are waiting for the Serbian page to

 4     appear.  If it is my mistake, please tell me, we made a double-check

 5     yesterday to make sure that we've got the right page.  I thank you.

 6        Q.   Mr. Milovanovic, please look at the document about a meeting of

 7     the Supreme Command.  The meeting took place on the

 8     21st of January, 1993.  General, sir, here Radovan Karadzic speaks about

 9     the axis to the Drina.  It says the situation is tragic because they

10     control 60 kilometres of the Drina bank.  If you remember the events,

11     could you please tell us what part of the Drina bank is Radovan Karadzic

12     talking about?

13        A.   I don't know when I'm supposed to start talking.  I don't have

14     the transcript on the left-hand side of the screen.

15             MR. PETROVIC: [Interpretation] Can the usher be of assistance,

16     please.

17             THE WITNESS: [Interpretation] Okay.  First of all, I have some

18     doubts about the date, 21 January 1993, because the 21st January 1993,

19     Karadzic and Mladic were either in Geneva or in London; in any case, they

20     were abroad, which means that no session of the Supreme Command could

21     have taken place on that date.  Second of all, on the 21st of January,

22     Vance Owen's plan was violated in Ravni Kotari when Croatia attacked the

23     area of the Serbian Krajina.  I don't have anything against that session

24     or the contents of the words that Karadzic used but the date is wrong.

25             MR. PETROVIC: [Interpretation]

Page 15488

 1        Q.   Okay.  But could you please answer my question:  What part of the

 2     river bank did Karadzic have in mind and what event did he have in mind

 3     when he uttered those words?

 4        A.   I believe that Karadzic is referring to the central part of the

 5     Drina around Visegrad because on that date Visegrad power plant was

 6     attacked by the Muslims.

 7        Q.   Do you remember the attack on Skelani and Bajina Basta?  Did it

 8     happen in January 1993?

 9        A.   Yes.  Skelani was attacked on the 16th of January and the attack

10     lasted until the 23rd of January.

11        Q.   The attack that we are talking about, the attack on Skelani, and

12     you say that it took place on the 16th, what happened?  Were Serb

13     villages attacked, plundered and torched around Bajina Basta and its

14     environs, as much as you remember?

15        A.   I don't know whether the fire was open on the territory of

16     Serbia.  I know that during the war two shells were fired on

17     Mali Zvornik, I don't know if that was a mistake or not.  And as for

18     Skelani, about 20 Serbian villages and hamlets were attacked before the

19     Muslims reached Skelani.  And those villages were completely destroyed

20     and the population was expelled across the bridge near Bajina Basta.

21     About 20.000 people fled.  The unit that defended Skelani which was an

22     independent Skelani unit broke up.  They were crushed.  We could not deal

23     with the problem with our units from Podrinje.  I spoke to the commander

24     of the 1st Krajina Corps and ordered him to send me reinforcement.  He

25     sent two battalions, and as soon as those battalions arrived within 24

Page 15489

 1     hours the situation was resolved.

 2        Q.   It is stated here, or rather, Karadzic says we had to take

 3     decisive action.  What does he mean when he says that?

 4        A.   I don't know.  I don't know what he means.  I'm sure that I did

 5     not attend that session.  I'm looking at the list of the participants and

 6     what people said.  I wasn't there.

 7        Q.   Very well.

 8             MR. PETROVIC: [Interpretation] Can we look at the following page,

 9     please.  Page 78 in B/C/S, page 80 in English.

10        Q.   General, sir, look at Karadzic's words at the bottom of the page,

11     both in Serbian and in English.  Karadzic says somebody decided that

12     Skelani should be evacuated.  Do you know who decided that and why?

13        A.   I don't know what information Karadzic had about the evacuation

14     of Skelani.  That was not done according to any plan.  The population

15     simply fled.  I know when that was happening, that was happening on the

16     17 and the 18th of January.  I sent my deputy, Colonel Ilic, to try and

17     stop the population and the Skelani battalion.  The colonel came to the

18     bridge.  He opened fire into the air but to no avail.

19             JUDGE ORIE:  Mr. Petrovic asked you, on the basis of this text,

20     whether you could tell us who decided to evacuate Skelani.  If you know,

21     tell us.  If you say, I don't know who decided, or even if you say, No

22     one decided, please tell us, but don't give us the whole story of Skelani

23     because you are not asked to bring that story.

24             Do you know who decided to evacuate Skelani two or three days

25     before this meeting?

Page 15490

 1             THE WITNESS: [Interpretation] There was no decision to that

 2     effect.  People simply fled.

 3             MR. PETROVIC: [Interpretation] Thank you, Your Honour.

 4             And can we now look at the following page in the same document,

 5     B/C/S 79, English 81.

 6        Q.   This is about a meeting which took place in President Cosic's

 7     office.  According to the document, the date is the same,

 8     21st January 1993.

 9             MR. PETROVIC: [Interpretation] Now can we go to the following

10     page, please.

11        Q.   The following page, General Panic - at the very bottom of the

12     page - at the meeting with President Cosic, he says that the situation on

13     the Drina River is very bad.  My question to you, sir, is this:  Why was

14     the situation on the Drina River considered at the highest level in the

15     Federal Republic of Yugoslavia and President Cosic's office?  Why was

16     that situation so important to merit a discussion at such a high level?

17        A.   Because on that day preparation started for the peace conference

18     in Geneva.  The leaders of Republika Srpska, Karadzic and Mladic and some

19     other people, were also there.

20        Q.   Do you agree that the situation and the flight of some 20.000

21     people, threat to the facilities along the border, do you agree that this

22     had a rather unfavourable effect on the security situation in the

23     Republic of Serbia, i.e., the Federal Republic of Yugoslavia?

24        A.   Yes.

25        Q.   Thank you, General, sir.

Page 15491

 1             MR. PETROVIC: [Interpretation] And now can we look at

 2     65 ter 5605.  B/C/S page 336 --

 3             JUDGE ORIE:  Mr. Petrovic, before we continue, all three judges

 4     are lost as far as the relevance of the line of this questioning is --

 5     the questioning is.  If you could assist, please do so.

 6             MR. PETROVIC: [Interpretation] Your Honour, I can do that.  The

 7     events along the Drina River about which the General has testified caused

 8     an operation by the government of the Republic of Serbia and the

 9     Federal Republic of Yugoslavia, the engagement of the military and the

10     MUP of the Republic of Serbia.  The accused in this case participated in

11     that operation to a certain extent which is why we would like to explain

12     the circumstances that led to the operation at that -- a number of

13     Prosecution witnesses mentioned in their testimonies as well.

14             JUDGE ORIE:  So we are just talking about the background what

15     caused some operational activity and --

16             MR. PETROVIC: [Interpretation] Yes, Your Honour.

17             JUDGE ORIE:  -- is there dispute about what triggered, whether

18     there was concern about the situation at the Drina River, for example,

19     something we listened to in the last one or two minutes and why it should

20     be discussed at a high level?  Is there any dispute about such a worrying

21     situation at the Drina River?

22             MR. GROOME:  We haven't address this particular issue, but with

23     respect to the issue in Skelani and along the Drina, that's -- we have

24     already agreed that there were attacks against Serbs there.  There were

25     infiltrations.  That's all a matter of agreement in the course of this

Page 15492

 1     trial.

 2             JUDGE ORIE:  Therefore, Mr. Petrovic, why do we go through it

 3     again?  Let's focus on the matters which are really in dispute.  Please

 4     proceed.

 5             MR. PETROVIC: [Interpretation] Thank you, Your Honour.

 6        Q.   Witness, sir, please look at this entry of 23rd September 1993.

 7        A.   I've seen it.

 8        Q.   If I understand correctly, these are demands of the VRS from the

 9     Army of Yugoslavia?

10        A.   This is just a conversation between General Mladic and

11     General Perisic.  And, yes, you are right, General Mladic is asking for

12     something but verbally, not in writing.

13        Q.   Look at item 12 where it says "Issues of status of officers."

14     Could you explain briefly, if you know, what was General Mladic asking

15     from the Army of Yugoslavia regarding the status of officers?

16        A.   I said yesterday that the Army of Yugoslavia, that is to say, the

17     leadership of Yugoslavia, took upon themselves the obligation to pay and

18     provide housing and other benefits to the officers of the

19     Army of Yugoslavia who either remained or went to Bosnia-Herzegovina.

20     Those are issues of their status.  We did receive reserve officers but we

21     could not pay them according to their rank.  Those issues were dealt with

22     by the Army of Yugoslavia.

23        Q.   You mentioned yesterday seven and a half thousand officers and

24     NCOs that served in the VRS but were paid funded by the Army of

25     Yugoslavia, did I understand that correctly?

Page 15493

 1        A.   Yes, I said that it was an agreement with the Army of Yugoslavia

 2     that was signed by Vice-President Nikola Koljevic.

 3        Q.   Concerning those seven and a half thousand officers, what was

 4     provided except their salaries?

 5        A.   Their next salaries were paid, benefits, health and pension

 6     insurance were paid directly to their accounts in Belgrade, housing was

 7     provided to VRS personnel, just as to the personnel of the

 8     Army of Yugoslavia, and medical insurance.

 9        Q.   How many officers in total served in the

10     Army of Republika Srpska, roughly, if you know?

11        A.   How many officers?  I can't tell you the figure but I can tell

12     you that 21 per cent of professional officers and 79 per cent of reserve

13     officers served in the VRS.  The 21 per cent were paid by VJ, the 79 per

14     cent by the VRS.

15        Q.   So if I understood correctly, all professional officers were paid

16     by the Army of Yugoslavia?

17        A.   Yes.

18             THE INTERPRETER:  Could the witness and the counsel not overlap

19     and give us a pause between questions and answers, please.

20             JUDGE ORIE:  You are invited not to overlap, Mr. Petrovic.  So

21     could you please repeat your last question, Mr. Petrovic.

22             MR. PETROVIC: [Interpretation] I apologise, Your Honour.

23        Q.   General, members of the Main Staff of the VRS, corps commanders,

24     brigade commanders, commanders of lower tactical units, all those

25     officers were financed by the Federal Republic of Yugoslavia, that is,

Page 15494

 1     the VJ; right?

 2        A.   No, it's not right because we had commanders from battalion level

 3     to brigade level, and those are the 79 reserve -- 79 per cent reserve

 4     officers.  The VJ paid only professional officers who made up

 5     21 per cent.

 6        Q.   Let's make things simpler in this way.  The highest-ranking

 7     officers in the VRS and the most responsible officers in the VRS were

 8     paid by the Federal Republic of Yugoslavia, could we put it that way?

 9        A.   We would agree the most easily if we say the VJ paid officers,

10     graduates of military academies and graduates of middle military schools.

11        Q.   All right.  That's clear then.

12             JUDGE ORIE:  Mr. Groome, is there dispute about the payment of

13     the high-ranking officers?

14             MR. GROOME:  No, Your Honour.  I was actually contemplating and

15     standing up and objecting to relevance.  I am not sure what the relevance

16     is of this line of questioning.

17             JUDGE ORIE:  Mr. Petrovic, there's no dispute about it.

18     Relevance?

19             MR. PETROVIC: [Interpretation] Your Honours, the relevance lies

20     in the measure of contribution to the joint criminal enterprise charged

21     against my client.  I can elaborate on that, if necessary, but that is

22     the gist of it.

23             JUDGE ORIE:  But there's no dispute about high-ranking officers

24     being paid not by the VRS but by the JNA or what used to be the JNA.

25             MR. GROOME:  Your Honour, I would be unable to verify precise

Page 15495

 1     percentages, but in general principle there's no dispute about that.

 2             JUDGE ORIE:  Why are you spending so much time on one simple

 3     question?  Is it true, Mr. Milovanovic - you can do that even without

 4     that - a large number of high-ranking officers were paid by the VJ rather

 5     than by the VRS?  The answer will be yes and we move on to the next one.

 6     Why -- please proceed, Mr. Petrovic.

 7             MR. PETROVIC: [Interpretation] Thank you, Your Honour.

 8        Q.   Item 13 in this document we are looking at, the status of repair

 9     shops.  Orao and Kosmos what is this about?  Why is Mladic discussing

10     this with Perisic?

11        A.   The repair shops Orao or Kosmos were for military equipment; Orao

12     for aircraft, and Kosmos was a universal factory for the repair and

13     maintenance of some rocket systems for defence.  There was a problem at

14     the outset of the war:  Who was going to manage those companies, the

15     Ministry of Defence of Republika Srpska or the Main Staff?  And I know it

16     was decided that all repair shops in the territory of Republika Srpska

17     and special-purpose industries, that is, those producing ammunition,

18     should be managed by the Main Staff and that's how it was done until the

19     end of the war.

20             MR. PETROVIC: [Interpretation]  Could we now look at another

21     point in the same document.  Page 338 in the manuscript or in the copy

22     and English page 330.  Bottom of the page, please, where

23     General Novakovic is speaking.

24        Q.   Tell us, please, what is VOJIN, just in one sentence?

25        A.   Air observation notification and guidance.

Page 15496

 1        Q.   This VOJIN system in the Republic of Serbian Krajina and

 2     Republika Srpska, was it integrated with the same system in the FRY?

 3        A.   All VOJIN systems were integrated within friendly countries in

 4     one region; that is to say, the Republic of Serbian Krajina,

 5     Republika Srpska, and the FRY.

 6             MR. PETROVIC: [Interpretation]  Page 387 in the copy and 389 in

 7     English.

 8             JUDGE ORIE:  Mr. Groome.

 9             MR. GROOME:  Could I request that Mr. Petrovic read out the dates

10     of these entries, it would be much easier for us to follow where he is.

11             JUDGE ORIE:  Would you please follow this suggestion,

12     Mr. Petrovic.

13             MR. PETROVIC: [Interpretation] I will, Your Honour.  I will now

14     tell you the date.  19 October 1993.

15        Q.   May I put my question, General?

16        A.   Yes.

17        Q.   General Perisic is saying that military conscripts and officers,

18     if I understand correctly, should be directed -- he says those who don't

19     want to serve in the RS and RSK should be expelled from the army.  Should

20     be expelled full stop.  Do you know that troops who did not want to serve

21     from -- serve in the RS and the RSK were indeed expelled from the VJ?

22        A.   I know this was started just as Perisic became Chief of the

23     General Staff and he was very diligent about it.

24        Q.   Thank you, witness.

25             MR. PETROVIC: [Interpretation] The meeting of the 21st October,

Page 15497

 1     1993, page 389 in the copy, and in English it's 390.

 2        Q.   Witness, look at this meeting, please.  You can see the beginning

 3     on this page before us and then we should turn the next page.

 4             MR. PETROVIC: [Interpretation] Next page, please.

 5        Q.   General, the verification of promotions into general, you said

 6     something about it, but clarify it.  Who promotes and who confirms the

 7     promotion?  Can people be promoted without being confirmed?

 8        A.   There is no confirmation without promotion.  Its the

 9     Supreme Command of Republika Srpska that promotes officers into generals

10     and it is verified by the Supreme Command; that is to say, the

11     General Staff of the VJ.

12        Q.   From what moment on does a prospective general of the VRS become

13     a general, really?

14        A.   I can explain this using my own example.  I was promoted into

15     lieutenant-general by decree of the president of Republika Srpska on the

16     28th of June, 1994, and my rank was verified sometime on the

17     25th December, 1995.  I received a salary in the meantime of a

18     lieutenant -- of a colonel, not lieutenant-general.

19             THE INTERPRETER:  Correction:  Of major-general, not

20     lieutenant-general.

21             MR. PETROVIC: [Interpretation]

22        Q.   Now, look at this meeting.

23             MR. PETROVIC: [Interpretation]  Page 391 in the copy and 393 in

24     English.

25        Q.   You attended this meeting too.

Page 15498

 1             MR. PETROVIC: [Interpretation] Next page, please.

 2        Q.   It says the discussion goes on at the session.  Officers are

 3     requested from the FRY for the Gatac Brigade.  What we see here, was it

 4     normal practice to request the return or the sending of officers from

 5     some VJ units?  It says lieutenant-colonels and colonels; one in Topola,

 6     one in Podgorica.

 7        A.   Yes, that was the practice.  When the initial agreements were

 8     made for officers who were natives of Republika Srpska to come back, it

 9     was agreed then that officers serving in Kosovo do not have to come to

10     Republika Srpska.  It will be recorded as service in the war and

11     similarly exempted where officers serving in some units that couldn't be

12     spared.  But as for Colonel Andzic, he was a native of Herzegovina and

13     they needed him to become commander of this Gatac Brigade and this

14     Milivoj Radovic was also requested.  This Gatac Brigade used to be a TO

15     brigade and then it was renamed into an infantry brigade.

16        Q.   Thank you, Witness.  At the same meeting, on page 394 in B/C/S

17     and 396 in the English translation, there is a reference to the

18     activities that needed to be carried out, the shortening of the front

19     line as a way to fight Dudakovic's forces, and to assist Fikret Abdic.

20     My question is this:  How is Fikret Abdic assisted by the shortening of

21     the front line?

22        A.   Let's clarify one thing.  I had the text in front of me a minute

23     ago but I don't see it anymore because it's too small.  The 2nd Corps

24     should fight Drekovic's force, not Dudakovic's forces.  Drekovic was

25     commander before Fikret Abdic.  Konjic is mentioned here.  Drekovic was

Page 15499

 1     moved from Bihac and became the commander of the Muslim

 2     Herzegovina Corps.  I believe it was the 6th Corps.  Drekovic was here

 3     and there at the same time.  However, in the first came [as interpreted]

 4     when our 2nd Corps is mentioned, the person made a mistake and used

 5     Drekovic's name.

 6        Q.   So my question is:  How is Abdic assisted by the shortening of

 7     the front line facing the corps in Cazina Krajina?

 8        A.   The shortening of the front line is a tactical operation.  By

 9     shortening the front line, you don't lose much territory but you liberate

10     some of your forces that you can use to assist Fikret Abdic.  I already

11     spoke at great length about what was the army of Fikret Abdic, or not.

12        Q.   Was this task ever implemented as it is stated here?  I remind

13     you that that was in October 1993.

14        A.   I don't know whether the operation was implemented.  I know that

15     Karadzic signed an agreement with Fikret Abdic but that was just the

16     beginning of Fikret Abdic's career and I really can't say much about

17     that.

18        Q.   Thank you.

19             MR. PETROVIC: [Interpretation] Can we now look at 65 ter 5606.

20     In B/C/S it's page 53 and the same page in English.

21        Q.   This is the front page describing the meeting which took place on

22     the 13th of December, 1993.

23             MR. PETROVIC: [Interpretation] And can we now look at the next

24     page, please.

25        Q.   General, sir, you obviously attended that meeting; right?

Page 15500

 1        A.   Yes.

 2        Q.   You say here that you wanted assistance on the right bank of the

 3     Drina.  Do you remember why you requested that?  And that request was

 4     addressed at the representatives of the FRY who were also participants in

 5     the meeting.

 6        A.   Yes.  I tried to seek assistance from the FRY in the central and

 7     upper Drina region.

 8        Q.   A few lines down, Karadzic says General Milovanovic has talked

 9     about slow moving things or side things.  Why did he say that, if you

10     know?

11        A.   He didn't say side things but slow moving things; i.e., things

12     that should follow in the future, at least that's what it says here.  I

13     don't know what he said exactly but I know that he didn't agree with my

14     words, and this is why:  He wanted to carry out an offensive around

15     Sarajevo before some peace talks that were supposed to start on the

16     21st and the 22nd in Geneva.  He made use of Mladic's absence from the

17     front line and he consulted with me, and then he said that we should take

18     Zuc, Mojmilo and Sarajevo, as well as some features and facilities in the

19     town itself, that there should be encirclement around Sarajevo to

20     liberate the Praca valley that UNPROFOR had given to Muslims as a

21     corridor between Sarajevo and Gorazde.  In that conversation which took

22     place on the 10th of December, I refused his proposals and I tried to

23     convince him that that was impossible, that our military was not prepared

24     to do that, and then he called me back again on the 12th on the eve of

25     the meeting, that is described here, he invited me to come to Pale.

Page 15501

 1     Again, he tried to persuade me to ask assistance from the FRY, the

 2     assistance in life force.  Again, I refused his proposals, and that's how

 3     I left for the meeting because Mladic and I could not both be absent from

 4     the front line, that's why I went to the meeting.  In the first part of

 5     my discussion I uttered a sentence and I said that if we wanted to comply

 6     with Karadzic's request, we had to rely only on our forces, that we

 7     should not drag the FRY into war.

 8             In my second discussion, I wanted help on the right bank of the

 9     Drina, if FRY was, indeed, willing to be engaged, and I requested

10     whatever is stated here.  I knew that in Leskovac and Vranje there were

11     two battalion -- tank battalions and I requested those tanks.  Karadzic

12     didn't like that and that's why he said what he did, that I'm talking

13     about slow moving things or Weinguard [as interpreted] things.

14             MR. PETROVIC: [Interpretation] Thank you.  Page 57 in B/C/S and

15     58 in English.

16        Q.   In the middle of that page, it says:  Badza.  The forces that are

17     request are indeed need and I support that.

18             My only question to you is this:  Who is Badza?

19        A.   Badza was the general lieutenant in the police or

20     lieutenant-general in the police.  He was killed in Belgrade.  I really

21     can't remember his name.  I believe that his family name was Stojicic.  I

22     believe that he was responsible for the Special Police Units in Serbia.

23        Q.   Thank you, Witness.

24             JUDGE ORIE:  Mr. Petrovic, are you really serious in asking this

25     witness who Badza is?  We've heard about Badza for a year now on a daily

Page 15502

 1     basis.  Do we need this witness to tell us who Badza is?  Or is there any

 2     dispute about this Badza being present at this meeting, then ask the

 3     witness whether he knows whether the Badza mentioned here was present at

 4     that meeting and who he is so that we -- and identify him.  But to say we

 5     see the name Badza, could you tell us what the name Badza, who you

 6     considered him to be, is that really after a year that -- but please

 7     explain yourself, don't take too much time for it because you have only

 8     10 minutes left.  Is it that this witness knows something about the

 9     presence of this person and if --

10             MR. PETROVIC: [Interpretation] Your Honour.

11             JUDGE ORIE:  Yes.

12             MR. PETROVIC: [Interpretation] Your Honour, I just wanted to see

13     what this witness knows about that person because I wanted to know what

14     the perception of Badza was in the eyes of this witness.  I didn't put

15     the question to him because I thought that nobody here knows who Badza is

16     but I wanted to hear from a general in the Serbian army whether he knew

17     who that person was.  I thought it was important but if Trial Chamber

18     thinks that this is not relevant at this point in time, I will not dwell

19     upon it.

20             JUDGE ORIE:  Fine.  But then ask a different question than "Do

21     you know who Badza is," because then we get the answer and no additional

22     information whatsoever, mainly that he thinks that he remembers the

23     family name which sounds rather familiar to us, unless there's any

24     dispute about this Badza.

25             MR. GROOME:  Your Honour, if I could assist Mr. Petrovic,

Page 15503

 1     General Milovanovic spoke about a meeting or an encounter he had with

 2     Badza in his direct examination.

 3             JUDGE ORIE:  Well, now we know that what Mr. Milovanovic told us

 4     on the very general question, the very general question being ...

 5             MR. PETROVIC: [Interpretation] With your leave, I have just a few

 6     more questions and that will be my cross-examination to an end.  I will

 7     not dwell upon this issue any longer.

 8             JUDGE ORIE:  Please proceed.

 9             MR. PETROVIC: [Interpretation] Thank you, Your Honour.  Can we

10     now look at page 42 in the same document, that's in B/C/S and in English.

11        Q.   The meeting was held on the 22nd of November, 1993.  General,

12     sir, you attended the meeting, if I am not mistaken, and you took the

13     floor.  You spoke about the need to launch war production.  You talked

14     about materiel and technical equipment, and the overhaul of the

15     equipment.  First of all, tell us why is this mentioned at the meeting?

16     You were the one who spoke about that so I suppose that you know?

17        A.   First of all, I'm not sure that I was present at the meeting on

18     the 22nd of November, 1993.  However, here when General Mladic is quoted,

19     he is quoted as saying General Milovanovic has just informed us about

20     this or that or the other.  It's possible that a day before on my

21     birthday I informed Mladic about that.  I was not at that meeting in

22     Belgrade and you can see that Djukic and Mladic from the Main Staff

23     attended, the assistant commander for logistics and the commander

24     himself.  I wasn't at that meeting.  I told you yesterday that I was

25     responsible for the distribution of a strategic materiel, and here I just

Page 15504

 1     suggested what the commander of the Main Staff should do and how he

 2     should do that.

 3        Q.   Just tell us, please, materiel and technical equipment, were they

 4     repaired in the FRY and what materiel and equipment was repaired?

 5        A.   Were they repaired in the FRY?

 6        Q.   Yes.

 7        A.   Sir, the Army of Republika Srpska inherited almost all the giants

 8     in terms of repairs facilities of the former JNA, save for the company in

 9     Cacak which is in Serbia.  We had Hadzici for the repairs of heavy

10     artillery.  We also had Kosmos for the repairs of rockets.  We also had a

11     facility called Orao to repair airplane engines, and we, ourselves,

12     repaired the materiel and equipment belonging to the Army of Yugoslavia.

13     They paid us for that.

14        Q.   Thank you, sir.

15             MR. PETROVIC: [Interpretation] And now can we look at just one

16     more document which is 5607, pages 34 and 35, but let's first look at

17     34 in B/C/S and 33 in English.

18        Q.   It says here "Co-ordination."  This is about a meeting which took

19     place on the 19th of January, 1994.  What kind of a meeting was that?

20     That meeting bears the name co-ordination.  What type of a meeting was

21     that, why is it called co-ordination?

22        A.   I don't know.  Because it would be General Djukic, the assistant

23     commander for logistics, that chaired this meeting, but when I look at

24     the contents, I can see that they are talking about recruits and about

25     the Republic of Serbian Krajina.


Page 15505

 1        Q.   Let's look at the following page, maybe that will help you shed

 2     some light on who co-ordinated whom, what, and why.

 3             JUDGE ORIE:  Two minutes left, Mr. Petrovic.

 4             MR. PETROVIC: [Interpretation]

 5        Q.   If you don't know, never mind, it's okay.

 6        A.   I can see that it was the co-ordination of logistics between the

 7     Army of Republika Srpska, the Army of the Republic of Serbian Krajina and

 8     Fikret Abdic's army.

 9        Q.   Thank you, General, sir.

10             MR. PETROVIC: [Interpretation] Thank you.  And I have no more

11     questions nor witness.

12             JUDGE ORIE:  Thank you, Mr. Petrovic.

13             Mr. Groome, are you ready to re-examine the witness.

14             MR. GROOME:  Yes, Your Honour.

15             JUDGE ORIE:  Mr. Milovanovic, you will now be further examined by

16     Mr. Groome who, as you know, is counsel for the Prosecution.

17             Mr. Groome, please proceed.

18             MR. GROOME:  Thank you, Your Honour.

19                           Further Re-examination by Mr. Groome:

20        Q.   Good morning, Mr. Milovanovic.  I do not have many questions for

21     you today.  I do want to clarify some of the evidence you provide in

22     response to questions by Mr. Jordash and Mr. Petrovic this week.  My

23     first question relates to a date.  I will read a portion of Tuesday's

24     transcript, and I ask you to focus on the date and tell us whether the

25     transcript has correctly he recorded your evidence about this date.  At

Page 15506

 1     transcript page 15348, Mr. Jordash asked you the following question:

 2             "Now, I appreciate from what you've told us before that you were

 3     not with him during the events in Srebrenica in 1995, during the

 4     massacres there; is that correct?"

 5             The pronoun "him" was a reference to General Mladic.  Your

 6     response was, and it begins at line 14:

 7             "Beginning with the 28th of October, 1994, until the

 8     15th of October, 1994, I was not with Mladic all the time.  I was in the

 9     west in Drvar and Banja Luka ..."

10             And it continues on.  Has the transcript correctly recorded your

11     evidence with respect to the transcript that you were in the Banja Luka

12     area?

13        A.   Yes.

14        Q.   So it seems somewhat illogical that you were somewhere from the

15     28th of October in the year 1994 until the 15th of October in the year

16     1994?

17        A.   Sorry, it was 1995.  You are right.

18        Q.   So the transcript should read that you were there until the 15th

19     of October 1995; is that correct?

20        A.   Correct.

21        Q.   Now, at transcript page 15338 and following, on Tuesday,

22     Mr. Jordash asked you a number of questions regarding the military

23     airfields used by the VRS during the conflict.  I would like to now ask

24     you some questions to clarify your evidence.  As I understood your

25     evidence, you were referring to military air facilities under the control

Page 15507

 1     of the VRS and not every air strip in Bosnia and Herzegovina; is that

 2     correct?

 3        A.   Only the airfields used by the VRS.  And speaking of airfields, I

 4     meant to ask for a correction.  When I was looking on the map, on the

 5     non-existent part of the map, an airfield near Glamoc, I marked Crni-Lug

 6     2 or 3 centimetres to the north, whereas it is actually to the south of

 7     Crni-Lug village.  I later looked and map, so it's not to the north of

 8     Crni-Lug that Glamoc Polje airfield, it's to the south of Crni-Lug.

 9        Q.   Mr. Jordash may have another opportunity to ask you questions and

10     may seek to clarify the precise location.

11             Were there other places in Bosnia-Herzegovina where small

12     aircraft or helicopters could land, apart from the airfields that you

13     identified?

14        A.   Helicopters were able to land anywhere.  We had heliports in

15     Crni Rijeka, near Han Pijesak, for the Main Staff, a heliport at Pale for

16     the Supreme Command, another heliport in Kalinovik, in all major free

17     places near barracks.  As for auxiliary airfields where aircraft could

18     take off and land, apart from these four, I don't know about any others

19     and because we didn't use them and there was no need for me to be

20     interested in them.  It was Bratunac, Zaluzani, Mahovljani, Bijeljina and

21     the one in Glamoc Polje.  Sorry, not in Bijeljina but Prijedor.

22        Q.   General Milovanovic, if a helicopter was needed in an military

23     operation, is it possible to create an improvised landing area for that

24     helicopter?

25        A.   Yes, it was only up to the pilot to choose a flat piece of land,

Page 15508

 1     not to overturn the helicopter, and at night-time you do it by crossing

 2     the headlights of four vehicles.

 3        Q.   So do I correctly understand your evidence that to create an

 4     improvised airfield at night, you simply need to arrange four vehicles

 5     with their headlights on and the intersection of the headlights indicates

 6     the place where the helicopter should land?

 7        A.   Yes, he will, in fact, be able to see where he is landing.

 8        Q.   Now, in 1997 Frenki Simatovic, one of the accused in this case,

 9     gave a speech recounting the history of the Red Beret unit in a ceremony

10     attended by senior officials of Serbia.  A transcript of that narrative

11     is in evidence as P61.  Mr. Simatovic said that the Red Berets acquired

12     helicopters in May of 1991 and landed those helicopters on a number of

13     improvised airfields in Bosnia.  Are you able to say whether or not this

14     occurred?

15             MR. JORDASH:  Sorry, I object to that.  I think that the speech

16     aspects of what Mr. Simatovic actually said should be put to the witness.

17     Mr. Groome has actually, I think, mis-characterised it.

18             JUDGE ORIE:  Okay.  If there is any I dispute about what was said

19     [overlapping speakers] ... please.

20             MR. GROOME:  I will quote, Your Honour.

21        Q.   I'm going to read you the quote from that portion of the speech:

22             "In May 1991, an air helicopter squadron was formed which

23     transported tonnes of special shipments, equipment, troops, and machinery

24     from the improvised airfields of Medin Polje, Petrovac, Velika Popina,

25     Srb and Udbina and carried out numerous complex tasks while war

Page 15509

 1     operations were ongoing."

 2             Again, my question to you is:  Are you able to say from your own

 3     knowledge whether what Mr. Simatovic says about improvised airfields is

 4     true or is not true?

 5        A.   I don't know.  I was in Macedonia at the time.  There was no war

 6     at the time.  It was 1991.  The SFRY was at its full strength.  Wherever

 7     helicopters flew, it was legal.

 8             THE INTERPRETER:  And the interpreter didn't hear the last

 9     sentence.

10             JUDGE ORIE:  Could the -- the question has been answered by the

11     first four words, I don't know --

12             MR. GROOME:  Yes, Your Honour.

13             JUDGE ORIE:  Yes.  Nevertheless, we need a full transcript,

14     unfortunately, so we'll have to ask the witness to repeat what he said,

15     although the answer is clear already.  Could you please repeat the last

16     part after you said:  "The SFRY was at its full strength.  Wherever

17     helicopters flew, it was legal."

18             And what did you say after that?

19             THE WITNESS: [Interpretation] After that, I said I know that

20     Medin Polje World War II used to be a partisan airfield.

21             JUDGE ORIE:  Please proceed, Mr. Groome.

22             MR. GROOME:

23        Q.   General Milovanovic, Mr. Simatovic goes further in the speech to

24     say that the Red Berets' use of aircraft remained undetected by NATO.

25     Are you able to tell us how a helicopter might be used in a way that

Page 15510

 1     evaded detection by a sophisticated military organisation such as NATO?

 2     Is that possible?

 3        A.   It's possible.  I also flew by helicopter and I was never

 4     detected until General Morillon complained about it.  It's called a

 5     swiping type of flying where the helicopter flies according to the lay of

 6     the land.

 7             MR. GROOME:  Now, could I ask that P2933 be brought to our

 8     screen.  It is a one-page entry from General Mladic's notebook.  It is

 9     dated 16th of December, 1991.  And this is J000-3714.

10        Q.   Now, General, yesterday at transcript page 15436, Mr. Jordash put

11     to you that there was no mention of Stanisic prior to the

12     2nd of July, 1993.  I would like to show you an entry in the diary

13     related to when references can be found to the State Security of Serbia.

14     General, I ask you to look at the entry that's now on the screen before

15     you, again from the 16th of December, 1991.  In it we see Mladic

16     recording information provided by a person he refers to as Rade Siptar

17     and records his -- that's information as:

18             "Dule Orlovic, Filipovic - Fica and Frenki," and after Frenki's

19     name in parentheses is the word "Serbian DB."  "They want to give some

20     3.000 barrels to the Muslims in Bihac."

21             Now, my first question to you regarding this entry, General, is:

22     Based on your experience with General Mladic, when he wrote "3.000

23     barrels," what was that a reference to?

24        A.   In the army when you say barrel, it means infantry weapons, it

25     could be a pistol, rifle, anything up to the 12.7 millimetres

Page 15511

 1     machine-gun.

 2        Q.   Am I correct that the B/C/S word that Mladic used was "cevi,"

 3     c-e-v-i?  Is that the word that is used in the original of the diary?

 4        A.   I don't understand the question.  That's what is written, "3.000

 5     cevi," and I'm making my comment as an expert that it is -- that it means

 6     infantry weapons.

 7             MR. PETROVIC: [Interpretation] Your Honour.

 8             JUDGE ORIE:  Mr. Petrovic.

 9             MR. PETROVIC: [Interpretation] Your Honours, I don't know where

10     further questions by my learned friend are going, but I'm concerned

11     because I don't know from which part of my examination or Mr. Jordash's

12     examination these questions follow concerning this part of the report.

13     If my learned friend is now leading new evidence, I don't think it's

14     right -- it's the right time and that should have been done a year ago,

15     not today.

16             JUDGE ORIE:  Mr. Groome.

17             MR. GROOME:  Your Honour, as I said, or as I prefaced my

18     question, on Tuesday at transcript 15436, I am sorry, it was yesterday,

19     Mr. Jordash put to the witness that there was no mention of Mr. Stanisic

20     in his diary until the 23rd of July, 1993.  This is a clear reference to

21     the Serbian State Security Service much earlier than that date and

22     predates the commencement of the war.

23             MR. JORDASH:  It's a reference to Frenki of the Serbian state

24     security.  It's not a reference to Stanisic.  And they are not the same.

25                      [Trial Chamber confers]

Page 15512

 1             JUDGE ORIE:  The objection is denied.

 2             Please proceed.

 3             MR. GROOME:

 4        Q.   General Milovanovic, the word "barrel" in English can mean the

 5     barrel of a gun, it can also mean a container to contain oil or some

 6     other liquid.  Is there any interpretation of the word "cevi" as used in

 7     this sentence that can mean something other than the barrel of a gun or

 8     an infantry weapon?

 9        A.   Serbian language is not very clear.  It could be a tube, a pipe,

10     like a drain pipe or a smoke pipe or something in the middle of a sheet,

11     but Mladic wouldn't be talking about sewage or water-supply pipes,

12     something as -- as something in which the DB of Serbia would be involved.

13     It's barrels of a gun.

14        Q.   Now, General, this is three and a half months before the outbreak

15     of the conflict in Bosnia, and Bihac is in Bosnia.  Any idea why Frenki

16     would want to give 3.000 infantry weapons to the Muslims of Bihac?

17        A.   I don't see that Frenki is providing "cevi" barrels.  I can

18     understand it in two ways.  Perhaps Frenki is providing barrels or maybe

19     Frenki discovered that somebody else is providing barrels.  I believe

20     it's the seconds because political parties had started to arm the

21     citizens, the SDS is arming Serbs and the SDA is arming Muslims.  I

22     cannot really be sure whether Frenki is providing guns or he discovered

23     somebody else was providing guns.

24             MR. GROOME:  Your Honour, would that be a convenient place to

25     take the morning break?

Page 15513

 1             JUDGE ORIE:  That is a convenient moment.  We'll take a break and

 2     we resume at quarter to 11.00.

 3             THE INTERPRETER:  Just one correction from the interpreters.  At

 4     page 24, line 21, the proper translation of the type of flying is low

 5     flying or hedge hopping.

 6             JUDGE ORIE:  Yes, I was just wondering whether following the

 7     scape of the land, whether that would be at low altitude.

 8             We resume at quarter to 11.00

 9                           --- Recess taken at 10.18 a.m.

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

11             JUDGE ORIE:  Mr. Groome, are you ready to proceed?

12             MR. GROOME:  Yes, Your Honour.

13             JUDGE ORIE:  Please do so.

14             MR. GROOME:

15        Q.   General Milovanovic, I'd like to move to a different topic now.

16     On Tuesday Mr. Jordash asked you about establishing effective

17     communication with subordinate units of the VRS and you said at

18     transcript page 15342:

19             "I was told to organise communications with our subordinated

20     units that we had at the time and to start receiving reports from the

21     field effectively on the 12th of May."

22             Do I take from this that beginning on the 12th of May, 1992, you

23     began the process of building effective communications between the VRS

24     Main Staff and the military structures subordinate to it?

25        A.   Yes.

Page 15514

 1        Q.   How long did it take before you established what you believed to

 2     be effective communication with subordinate units?

 3        A.   I established the communications in the course of the 12th

 4     because I had inherited the war time command posts of the former JNA

 5     corps so I didn't have many technical issues to solve.

 6        Q.   Now, the VRS, like other military organisations, had several

 7     levels from the Main Staff down to the commander of a company or tank

 8     unit.  When you said that you were able to establish effective

 9     communications on the 12th, is it your evidence that you were able to

10     establish such communications between the Main Staff and all subordinate

11     VRS units?

12        A.   Only between the Main Staff corps commands and the command of the

13     air force and air defence.

14        Q.   Did it take longer to establish effective communication with all

15     the subordinate units?

16        A.   Yes.  That took around a month and a half.

17        Q.   Now, when you use the word "communication," do you mean to

18     include both reports coming into the Main Staff and directives or orders

19     going out to the Main Staff to subordinate units?

20        A.   There are several types of communications, radio communications,

21     wire communications, signals communications and courier communications.

22     Radio and wire communications were set up in the course of that day so we

23     were able, both verbally and in writing, to communicate with corps

24     commands using teletype.

25        Q.   And how long before you had the full plethora of communications

Page 15515

 1     up and running?

 2        A.   Concerning the first two type of communications, radio and wire,

 3     that was done on the 12th, and the rest gradually.  I can't tell you

 4     exactly how long it takes to provide courier communications.  Depends on

 5     the distance between the correspondence.  From the Main Staff to the

 6     Drina Corps it took two hours, from the Main Staff to the 1st

 7     Krajina Corps six hours, to another corps 12 hours, depending on how long

 8     the courier takes to get there.

 9        Q.   Now, also in answer to Mr. Jordash's questions, you spoke about

10     the daily briefing, and you said:

11             "Every morning between 6.00 and 7.00, the Main Staff received

12     reports from subordinates.  It would be either General Mladic or myself

13     who received them."

14             I will ask you in a few minutes about one of these particular

15     briefings but can I ask that you tell us now how it was decided whether

16     you would receive the briefing or whether Mladic would receive that

17     briefing?

18        A.   The reports were supposed to be received by General Mladic.  In

19     his absence, I would receive them as his deputy.  I told you we shared an

20     office and it was not hard to see whether he was there or not.

21        Q.   And if he was absent, would you take any steps to brief him about

22     what was the information you received at the morning briefing?

23        A.   I did not have the obligation to call him.  He had the obligation

24     to call me and inquire if there was anything new.

25        Q.   And was it his practice do so?

Page 15516

 1        A.   Yes.

 2        Q.   And do you know approximately what time of the morning or the day

 3     he would call to receive a briefing or an update about the morning

 4     briefing of the Main Staff?

 5        A.   Depends on his location.  If he was on the front line, that would

 6     usually be in the morning and he would call me from one of the corps

 7     commands.  If he was outside Bosnia-Herzegovina, he would usually call in

 8     the evening when all the conditions for communicating with me were there,

 9     especially if he was outside of Serbia even.

10        Q.   Now, I'd like to address a number of exhibits that Mr. Jordash

11     worked with over the course of the last two days.  Yesterday at

12     transcript page T15409 Mr. Jordash showed you 65 ter 5602, pages 40 and

13     51, corresponding to ERN numbers J000-1170 and J000-1181 of the original

14     notebook.  Both of these entries are from a meeting on the 15th of

15     September, 1992.  I want to return to page 40.

16             MR. GROOME:  And if I could ask that 65 ter 5602, e-court page 40

17     in the English be brought to our screens.  I believe it's also page 40 in

18     the B/C/S.  And it's J000-1170.

19        Q.   Now, when Mr. Jordash showed you this yesterday, he referred you

20     to a portion where the commander of the Eastern Bosnia Corps is talking

21     about Mauzer.  And I'll wait till we have that on the screen.  Can you

22     see it now on the screen before you?

23        A.   I see it.

24        Q.   Now, Mr. Jordash didn't work with the continuation of the report,

25     particularly with respect to Mauzer.

Page 15517

 1             MR. GROOME:  Could I ask that we turn to the next page in both of

 2     these versions, the translation and the original.

 3        Q.   I'd like you to read what the commander continued to say with

 4     respect to point number 2, Ljubisa Savic.  He says:

 5             "The morale of our unit has been weakened from the moment of

 6     engagement of the MUP of Serbia."

 7             My question to you is based on your experience and work with

 8     General Mladic, can you help us to understand what is meant by this

 9     entry?

10        A.   I don't know what he meant.  I don't know where the MUP of Serbia

11     was engaged and why.  Yesterday Mr. Jordash only asked me whether on the

12     previous page a reference to Ljubisa Savic was also a reference to Mauzer

13     to which I said yes.

14        Q.   Would the fact that General Mladic wrote this comment under the

15     heading, point 2, "Ljubisa Savic," indicate whether he believed Mauzer or

16     Ljubisa Savic had some relationship to the MUP of Serbia?

17        A.   I can only answer that by saying probably, but I'm not sure.

18             MR. GROOME:  Could I ask that we go to e-court page 55 in English

19     and the same page in the original, and the J number is J000-1185.

20        Q.   A bit later in the same entry on the page I believe you now see

21     before you, Branko Grujic, president of the Zvornik municipality, speaks.

22     He says:

23             "Under the command of Marko Pavlovic we did everything."

24             A few lines later he speaks about someone named Dzokanovic.  And

25     that's D-z-o-k-a-n-o-v-i-c.  And he says, "Dzokanovic is causing lots of

Page 15518

 1     problems around Zvornik."  You've given evidence about Zvornik over the

 2     last couple of days.  Are you familiar with this person Dzokanovic and

 3     who he might be.

 4        A.   First of all, I don't have the handwritten B/C/S version which

 5     exists in English.  Now I have it.  I don't know who that Dzokanovic or

 6     Dukanovic was, and I also don't know who Marko Pavlovic was.

 7             MR. GROOME:  I've finished with that exhibit.  Can I ask now that

 8     P2543, another entry from Mladic's notebook, be brought to the screen.

 9     It's date the November 22nd 1995.  It appears to be a record of a

10     briefing meeting.  Could I ask that General Milovanovic be shown the

11     first page so that he can orient himself to the date and the meeting.

12     The ERN of this page is J000-0195.

13        Q.   General, if you let us know when you have finished reading that

14     page, I've few questions before I take you to a specific portion.

15        A.   Does it start with General Tomic?

16        Q.   The translators or the people who have transcribed it recorded

17     that as General Talic.  Could it be General Talic?

18        A.   Yes, yes, yes, you are right.  Sorry.

19        Q.   When you've read it if you indicate that and I'll ask you a

20     question before I turn the page.

21        A.   Yes, I've read the page.

22        Q.   General Milovanovic, just above the name of General Talic is the

23     text "briefing by the officers."  Would this indicate that this entry is

24     a record of the Main Staff briefing of the 22nd of September, 1995?

25        A.   Yes, but not at the Main Staff but at the forward command post of

Page 15519

 1     the Main Staff which means that the briefing took place in Banja Luka.

 2        Q.   And is this the same daily meeting that you've referred to

 3     earlier in your evidence?

 4        A.   No.  It was something else but only the commanders of the Krajina

 5     units were involved, the first and the 2nd Krajina Corps, the training

 6     centre, the anti-aircraft defence and the air force.  All those commands

 7     were based in Banja Luka at that time.

 8             MR. GROOME:  Could I ask that we advance to e-court page 4 in the

 9     original in English and the ERN is J000-0918.

10        Q.   Now, in the intervening pages after the notes under Talic's name

11     we can see similar brief notes under the names of General Tomanic,

12     General Ninkovic, General Gvero, Colonel Djurdjevic, Colonel Kukobat, and

13     then your name, General Milovanovic, appears.  Are we correct to conclude

14     that the text appearing under each name is the information that that

15     particular officer provided on that day?

16        A.   I don't see my own name.  The last name I see is

17     General Ninkovic.  I am sorry, yes, General Milovanovic.  I can see that.

18     General Mladic actually recorded what we said to him.

19        Q.   Now, can I ask you to read what he recorded you as having said

20     that day, and it goes on to the next page, so when you've read this page,

21     please indicate that and I'll ask that we advance to the next page.

22             MR. JORDASH:  Sorry, could I just inquire as to how this arises

23     during re-examination?  Or from the cross-examination, I should say.

24             MR. GROOME:  Could we ask perhaps the witness to take off the

25     earphones, I think is best.

Page 15520

 1             JUDGE ORIE:  Yes.  Mr. Milovanovic, I don't know whether I ever

 2     asked you, so you speak -- do you understand English?

 3             THE WITNESS: [Interpretation] No.

 4             JUDGE ORIE:  Then could you take off your earphones.  I might

 5     have asked it before, but -- Mr. Groome.

 6             MR. GROOME:  Your Honour, yesterday, I think it was the day

 7     before, Mr. Jordash spent a considerable amount of time eliciting that

 8     there was an order in June of 1992 prohibiting paramilitaries from being

 9     present on the territory under the control of the VRS.  And if you look

10     in this particular entry, the entry that he is reading now and that I

11     will ask him about refers to a delegation of members of State Security

12     Service and the word paramilitary is even used to describe them.  So I'm

13     using this to counter Mr. Jordash's suggestion that the order of

14     June 1992 prevented or did not permit members of the -- of Arkan's unit,

15     of Bozovic and others to be on the territory of the Republika Srpska.

16             MR. JORDASH:  Well, the first thing is that the word

17     "paramilitary" is not used to describe them.  I don't accept this arises

18     during -- from the cross-examination, but I withdraw the objection

19     because I think Mr. Groome having made that assertion, Mr. Milovanovic

20     might be able to deal with it.

21             JUDGE ORIE:  Yes, then could you please put on your earphones

22     again, Mr. Milovanovic.

23             You may proceed, Mr. Groome.

24             MR. GROOME:

25        Q.   Perhaps while we were speaking, you have already completed

Page 15521

 1     reading the notes under your name.  Have you done that?

 2        A.   Yes, I have read the page that is in front of me.  I don't know

 3     whether there is anything else.

 4        Q.   There is some.  It continues on to the next page.

 5             MR. GROOME:  So if we could please advance to the next page.

 6        Q.   Indicate when you have completed reading the entry and then I'll

 7     ask my question.

 8             MR. GROOME:  With respect to our conversation or our discussion

 9     out of the hearing of the witness, it is the first line of this page that

10     I was referring to.

11             THE WITNESS: [Interpretation] I've read the page.  It was quite

12     easy to read the first half of the page.  The bottom part, however, is

13     somewhat less legible, so I'm not sure whether my understanding of it is

14     correct.

15             MR. GROOME:  Your Honour, this is an important matter, and I have

16     a printed copy.  If there's no objection, could we provide the witness

17     with a printed copy of this and perhaps ...

18             JUDGE ORIE:  I hear of no objections, so please proceed as

19     suggested.

20             MR. GROOME:

21        Q.   General Milovanovic, there's now a printed copy of that exhibit

22     before you.  Perhaps you can advise us whether that's more legible than

23     the television screen?

24        A.   This is not a printed copy.  This is again handwriting, a

25     handwritten copy.

Page 15522

 1        Q.   I misunderstood you.  So you would prefer to have what, a typed,

 2     what a transcriber read from it?

 3        A.   Yes.

 4        Q.   That will take a few moments for us to locate.  Perhaps I can ask

 5     you some questions and if you are -- you may be able to answer them with

 6     the portion that you are able to read, and if you think you would like to

 7     read the other one, still, at the end of my question, we'll do our best

 8     to get that as quickly as possible.

 9             Now, my first question relates to the information that you

10     provide General Mladic that a team from the State Security of Serbia

11     appeared here.  When you said they appeared here, did you mean that they

12     appeared at the forward command post in Banja Luka?

13        A.   A day or two before that President Karadzic, who was in

14     Banja Luka as well to discuss the defence of Banja Luka, told me that

15     some people would arrive from the MUP of Serbia.  He didn't say DB.  He

16     told me that I should receive those units that would arrive from Serbia.

17     Those would be the Special Police Units that would help us to defend

18     Banja Luka.  I know only too well that that Filipovic arrived as well as

19     the colonel whom I met near Kladusa.  He was in the company of

20     Mr. Frenki.  His name was Bozovic and he spoke with a Montenegrin accent.

21             They told me that they would arrive and they mentioned different

22     figures.  First they mentioned three brigades and then the number was

23     reduced down to some 900 men.  And they were looking for a place where

24     they would be billeted.  Since they were police officers, I thought that

25     that was part of co-operation between the two MUPs, the MUP of

Page 15523

 1     Republika Srpska and the MUP of Serbia.  That's why I suggested that they

 2     should contact our MUP.  The MUP had some premises near Banja Luka.  The

 3     name of that facility was Rakovacke Bare.  My suggestion was that they

 4     should be billeted there.  I don't know anything else about those police

 5     officers.  I don't think that they ever arrived, but as it says here,

 6     Arkan appeared on the front line with 300 Tigers.  He was chased away in

 7     1992 and then he returned in 1995.  I discovered his presence when I

 8     learned that he had beaten up some Serbian officers.  I asked for

 9     Karadzic for a meeting to ask him who had approved Arkan's arrival

10     because I was firm in claiming that Arkan had entered my area of

11     responsibility without my approval.  Karadzic finally after my ultimatum

12     organised a meeting with Arkan in Banja Luka in the temporary office of

13     the president of the state.

14        Q.   General --

15        A.   This is all I can tell you about this.

16        Q.   There's a few very precise questions I'd like to ask you about

17     this entry.  Do you know how they came, whether this delegation from the

18     State Security Service of Serbia came by road or by helicopter or some

19     other means of transportation?

20        A.   I don't know.  I never bothered to ask them.  They appeared in my

21     office in the command of the 1st Corps.  I used at the office of the

22     chief of the corps staff, General Lekovic.  Our military police escorted

23     them to the building and since I knew that people from the MUP of Serbia

24     were supposed to arrive, I received them and I talked to them about the

25     topic that I just covered.

Page 15524

 1        Q.   General --

 2        A.   Filipovic was there and perhaps Bozovic was there as well, I

 3     don't remember.

 4        Q.   Perhaps if we work through my questions one at a time, we'll be

 5     able to understand your evidence a bit more clearly.

 6             In this entry, you not only talk about the visit of this

 7     delegation but you also, as you've just told us, you refer to the arrival

 8     of 300 of Arkan's volunteers.  My question to you is simply:  Does the

 9     fact that both of these --

10             MR. JORDASH:  Sorry to jump up.  Could Mr. Groome be careful

11     about leading on these issues, please.

12             JUDGE ORIE:  Mr. Groome.

13             MR. GROOME:

14        Q.   Does the -- does the fact that both of these entries are in the

15     same -- both of these -- both of this information, or all of this

16     information, is in the same entry indicate anything about the time

17     relationship between those two events?

18        A.   Yes.

19        Q.   Can you please explain?

20        A.   First the two police colonels arrived, Filipovic and Bozovic.

21     Arkan did not arrive at that time.  He simply appeared somewhere in the

22     vicinity of Kljuc and Prijedor.  But that happened a few days later, or

23     perhaps even a month later.

24        Q.   So am I correct in understanding from what you've just told us

25     that you reported the information about Bozovic and Filipovic

Page 15525

 1     approximately a month after it occurred?

 2        A.   No.  I reported the information about Rakovacke Bare to those men

 3     immediately because they left and I never saw them again after that.  And

 4     as for Arkan, as I've already told you, he appeared somewhat later.

 5     Perhaps even a months later he appeared on the frontline.

 6        Q.   Then can you explain to us how that would appear in this

 7     particular entry, this entry of the 22nd of September?

 8             JUDGE ORIE:  Mr. Milovanovic, the text reads "300 Arkan's

 9     volunteers arrived and were put into the RS MUP," which suggests that

10     when this was written that they had arrived already and that they were

11     already put into the RS MUP.  That's what Mr. Groome's question is

12     focusing upon, Mr. Groome, if I understood you well?

13             MR. GROOME:  That's correct, Your Honour.

14             THE WITNESS: [Interpretation] That was on the day when the

15     briefing took place and I suppose that I related to Mladic the history of

16     the events.  I'm not saying that they appeared on the day when the

17     briefing took place.  They had appeared earlier than that and the

18     briefing took place on the 22nd of September.  I can't remember when

19     exactly they appeared, but, in any case, they appeared before the

20     briefing and Arkan also appeared before the briefing and I can claim that

21     in view of the fact that I was in a position to brief the commander about

22     the strength of his unit.

23             Arkan appeared on the 16th of September or a day or two later.  I

24     know that because on the 16th of September we lost Kljuc.  Kljuc fell

25     into Muslim hands and the first place where Arkan appeared was around

Page 15526

 1     Kljuc, somewhere near Kljuc.

 2             MR. GROOME:

 3        Q.   Now, General, how did you know that Bozovic and the others that

 4     represented themselves to be members of the State Security Service of

 5     Serbia, how did you know that they were, in fact, who they were

 6     representing themselves to be?

 7             MR. PETROVIC: [Interpretation] Your Honour.

 8             JUDGE ORIE:  Mr. Petrovic.

 9             MR. PETROVIC: [Interpretation] I may be mistaken but I believe

10     that they introduced themselves -- according to the witness, the witness

11     said that they had introduced themselves as representatives of the MUP of

12     Serbia.  That's the way I understood the witness.

13             JUDGE ORIE:  At the same time we see in the document a team from

14     the Serbian DB state security appeared.  So we have two versions of the

15     way in which they introduced themselves, one written and one as just

16     explained per the witness.  I think everyone keeps that in its mind.

17     What seems to be the gist of the question put to the witness is that how

18     would he know that they were who they claimed they were, isn't it,

19     Mr. Groome?

20             MR. GROOME:  Yes, Your Honour.  Perhaps I can be a little more

21     precise in my question, if I can take another try at it.

22             JUDGE ORIE:  Please do.

23             MR. GROOME:

24        Q.   You've given us evidence that Mr. Karadzic had foretold of the

25     arrival of some people from the Serbian MUP.  Now, can I take it that by

Page 15527

 1     the time these men arrived at your office they would have had to have

 2     gone through some security --

 3             MR. JORDASH:  Can we -- objection to the leading nature of the

 4     question.

 5             JUDGE ORIE:  Let me see.  Mr. Groome, you wanted to ask the

 6     witness whether they had to go through any kind of security.

 7             MR. GROOME:

 8        Q.   Yes, prior to arriving in your office, would this delegation have

 9     had to have identified themselves to gain access to the compound where

10     you were, the forward command post?

11        A.   The policeman from the centre post called me to tell me that

12     people from the MUP of Serbia had arrived.  And since Karadzic had told

13     me only a few days before that that they would arrive, I received them.

14     It was not up to me to take their IDs.  They introduced themselves as

15     Filipovic and Bozovic.  I knew that they were supposed to arrive, and

16     they immediately started discussing the issue of billeting, those men,

17     that they were supposed to follow them.  I did not check their identity.

18        Q.   Do you know how you learned and in turn conveyed to

19     General Mladic that they were from the state security of the Serbian MUP?

20        A.   Believe me, I really don't know how I conveyed that to

21     General Mladic.  However, those men spoke about Special Police Units.  I

22     knew intuitively that they were talking about the DB of Serbia.  I really

23     don't know why it occurred to me to tie them to the state security, but I

24     did.

25        Q.   Now, Mr. Jordash asked you a series of questions with respect to

Page 15528

 1     the decision by the VRS Main Staff to expel paramilitaries in June of

 2     1992.  Were members of the Serbian MUP who were present in Bosnia engaged

 3     in official work considered paramilitaries for the purpose of that

 4     decision of June of 1992?

 5        A.   As far as I know, Serbian MUP was not engaged in that.  As I told

 6     you yesterday, the commander had talked to the commanders of those

 7     militaries.  The process lasted from the 12th of May to the 28th of June.

 8     Then it was finalised by General Mladic's order on chasing the

 9     paramilitaries away from the area.

10        Q.   Now, what I'm asking you now is:  Did that order include members

11     of the Serbian MUP who were present in Bosnia-Herzegovina on official

12     business?

13        A.   No.  Those were military organisations that were not part of the

14     Republika Srpska army.

15        Q.   Now, my next question is:  How would members of the VRS be able

16     to distinguish between people that came from Serbia who were Serbian MUP

17     officials on official business, and paramilitaries that had come from

18     Serbia and were to be expelled?

19        A.   First of all, those who arrived on official business from Serbia

20     did not have to hide.  Their ID was checked at border crossings.  Their

21     arrival was announced.  And as for the others, and I told you what

22     paramilitary units those were which were not within the system of the

23     VRS, they were Mauzer's Panthers, Arkan's Tigers, Zuca and Crni, and

24     several groups around Sarajevo.  We knew very well who paramilitaries

25     were.

Page 15529

 1        Q.   Now, when you use the word "their IDs were checked," are you

 2     speaking about a national identification card or a Serbian MUP

 3     identification card?

 4        A.   Sir, it was only on the 27th of July, 1992 that we agreed how

 5     border crossings would be controlled with the MUP of Serbia.  Until then

 6     it was the police of Republika Srpska that controlled border crossings.

 7     As Chief of Staff, I was not duty-bound which of the politicians entered

 8     the territory of Republika Srpska.  It was the police of Republika Srpska

 9     who had to control that.  It was only after the 27th of July that we and

10     the then minister of the interior, Mico Stanisic, and the deputy prime

11     minister, Milan Trbojevic, agreed that at some border crossings there

12     would be mixed patrol, military and civilian police patrols, that is.

13        Q.   If someone had a Serbian MUP identification cart on their person,

14     did that permit them to move freely in the area controlled by the VRS?

15        A.   No.  Nobody was able to move in the combat zone, and the person

16     coming was certainly not coming to inspect the army.  He was coming for

17     negotiations with MUP or politicians, not the army.

18             MR. GROOME:  Could I ask that we now see P2544.  This is an entry

19     a week later from the 29th of September, 1995, and records a meeting

20     between Mladic and Karadzic.  It is a single page that's been put on

21     e-court and it bears the number J000-0938.

22        Q.   General, in this relatively brief entry there is a reference to

23     Jovica Stanisic which says:

24             "Jovica Stanisic is angry about something.  (He gave 300 of his

25     men and the US is begrudging us for having advertised Arkan)."

Page 15530

 1             As I said, this occurs one week after your briefing to General

 2     Mladic that Arkan had arrived in the area.  Can you help us understand

 3     this entry?

 4        A.   I don't understand what you are asking.

 5        Q.   Well, let me ask you, the 300 that is recorded here, he gave 300

 6     of his men, is this a reference to the Serbian MUP personnel that was

 7     discussed a week earlier with you?

 8        A.   I said I don't know whether these policemen, promised me by

 9     Filipovic and Bozovic, came at all, but I said that Arkan arrived with

10     300 of his men and I don't know who organised it.  I don't know that to

11     this day, and I don't mind telling you that I look forward to testifying

12     in Karadzic so I can have it out with him.  I still don't know who

13     approved Arkan's arrival.  Karadzic doesn't admit it.  Arkan said he came

14     at the written invitation of Karadzic, but when we expelled him from

15     Bosnia-Herzegovina, two days later he was given a sending-off ceremony by

16     the president, by the supreme commander with various decorations and

17     commendation, et cetera.  The same president who never found the time to

18     inspect a single one of our brigades.

19        Q.   General, you perhaps more than any other person in this courtroom

20     is familiar with General Mladic's writing and his way of conveying

21     information.  Can you help us, when he says he gave 300 of his men, are

22     you able to tell us who is the "he" that Mladic is referring to?

23        A.   This says literally Jovica ST, must be Stanisic, is a bit angry.

24     In brackets, he provided 300 men, and now there's a grudge against us

25     that we had advertised Arkan.  I cannot draw any conclusion from this

Page 15531

 1     sentence.  This seems to mean that those 300 men were provided by

 2     Jovica Stanisic and that Arkan showed up and he commanded those people

 3     and we are giving high profile to Arkan instead of Jovica Stanisic.  I

 4     don't know that any policeman had come.  I'm telling you again, but I

 5     know that Arkan came with 300 men.

 6             MR. GROOME:  Can I ask that we look at just one other entry.

 7     It's from the very next day, and it's P2545.  And it's a meeting of the

 8     30th of September, 1995.  And the J number is J000-0939.

 9        Q.   And again could I ask you to read this entry before I ask you any

10     questions.  In this -- in this -- this entry from the notebook it records

11     General Perisic as saying:

12             "Come on, Jovica, let's see what steps can be taken to have some

13     more crossover and to burn that thing."

14             Can you assist us given your knowledge about the time and what

15     was taking place at that time, what is "burn that thing" a reference to,

16     if you know?  If you are unable to assist, just please indicate that.

17        A.   I can't assist either you or myself.  How can I know what Perisic

18     meant?

19        Q.   The meeting --

20             JUDGE ORIE:  Mr. Groome, I'm looking at this document, also

21     looking at the translation.  Now, I remember that there was once an issue

22     about had embedded himself or was embedded.  Now, my recollection doesn't

23     go so far that whether it was this portion or not.  If it was this

24     portion, then, of course, we should use the new agreed translation, I

25     would think.  That's one.  And if it's a different portion, then I think

Page 15532

 1     there would be a reason to carefully verify the translation here.  That

 2     came to my mind.

 3             MR. GROOME:  Your Honour, your memory is very accurate.  A note

 4     has just been handed to me that this is the old translation, not the

 5     corrected one.  I will not ask about that and I will see that the correct

 6     version ...[overlapping speakers]

 7             JUDGE ORIE:  [Overlapping speakers] I saw that it was on our

 8     screen and, therefore, I'm very much inclined to seek the highest level

 9     of precision.  Please proceed.

10             MR. GROOME:

11        Q.   Now, the entry goes on and records a Jovica as saying:

12             "There is no command there, political conflicts, cities are

13     falling...," and it continues.

14             Can you assist us with the following:  What location is a person

15     by the name of Jovica referring to as having no command and where cities

16     are falling, again based on your understanding of what was taking place

17     at the time?

18             MR. JORDASH:  Sorry, that is just an invitation to speculate.  I

19     mean, how could the witness possibly know?

20             JUDGE ORIE:  Let's ask him whether he knows, and if he says he

21     knows what the source of his knowledge is.

22             Any clue, Mr. Milovanovic, that if Jovica says there's no command

23     there that you would know to what location or area he referred to?

24             THE WITNESS: [Interpretation] If it is Jovica Stanisic, in fact,

25     it doesn't matter which Jovica it is, this man is right.  The period

Page 15533

 1     concerned is the time of the defence operation of Republika Srpska

 2     against the Croatian Operation Storm.  After the fall of Glamoc and Knin,

 3     cities continue falling one after another, Drvar, Kljuc, Petrovac,

 4     Sanski Most.  Fighting is going on for Novi Grad which is mentioned here.

 5     There's fighting close to Manjaca and the Ugar River.  The command of the

 6     1st Krajina Corps is practically out of operation.  Whoever said this is

 7     completely right.  The command of operative levels from corps down is

 8     devastated.

 9             JUDGE ORIE:  Whether he is right or not wasn't the question.  The

10     question was whether you could shed any light on what the their would

11     have been, and what you've told us now is that on the basis of your

12     knowledge on what happened in late September 1995, that an absence of any

13     command you knew that there was in the area that you described, and that

14     for that reason you consider it a possibility that the person, reported

15     to be speaking here, referred to that same area, that's more or less what

16     I understand your testimony to be; is that correctly understood?

17             THE WITNESS: [Interpretation] Yes.  Briefly it's the area of

18     Novi Grad and Sanski Most.

19             JUDGE ORIE:  Thank you.  And we have the basis now, Mr. Jordash,

20     because you were concerned about speculation.  I think we have the basis

21     for --

22             MR. JORDASH:  Yes.

23             JUDGE ORIE:  -- what the witness doesn't exclude as being

24     referred to.

25             Mr. Groome.

Page 15534

 1             MR. GROOME:  Could I now ask the Court Officer to call up to our

 2     screens --

 3             JUDGE ORIE:  Before we do so, I would have one additional

 4     question.

 5             Mr. Milovanovic, looking at the time-frame and looking at the

 6     text, Jovica saying we sent 400 people.  Now, you earlier said what the

 7     MUP people offered, that was an offer which never materialised, do you

 8     have any explanation because it seems here, as Jovica is saying, that

 9     they sent 400 people and that it helped at Sanski Most and in Novi Grad.

10     You said this offer from the Serbian MUP officials, well, that was the

11     last thing you heard about it and then we have other information about

12     300 of Arkan's Men arriving.  But here Jovica says:  We sent 400 people

13     and the comment is such that it could be interpreted as they were really

14     sent and had arrived because otherwise you would not say that it helped

15     at Sanski Most and Novi Grad.

16             Could you shed any further light on an offer without any

17     follow-up and now a report of an arrival of 400 men by a person Jovica?

18             THE WITNESS: [Interpretation] First of all, I believe I said I

19     don't know that they ever arrived.  I never saw them.  And these 400 men

20     mentioned by this Jovica, I never saw them.  But he, himself, mentions

21     the areas of Sanski Most and Novi Grad.  Nobody was able to help

22     Sanski Most.  It fell.  But we managed to keep Novi Grad.  Twelve days

23     before this Kozarska Dubica was attacked by the regular Croatian army,

24     and the whole conglomerate was made in the Western Krajina and the whole

25     purpose of the Croats was to take Banja Luka.

Page 15535

 1             JUDGE ORIE:  Please proceed.  I'm re-reading your answer on

 2     previous questions, but please proceed meanwhile, Mr. Groome.

 3             MR. GROOME:  Your Honour, I'm moving to a different area but I'm

 4     happy to return to it if the Chamber would like any assistance in

 5     exploring it further.

 6             Can I now ask that 65 ter 5603 be brought to our screens.  If we

 7     could go to e-court page 256 in the original and the English, and it is

 8     J000-4671.

 9        Q.   Now, General, yesterday at transcript page 15416, you were shown

10     an entry from this notebook at e-court pages 253 and 254.  The original

11     pages being J000-4672 and J000-4673.  This was an entry from a meeting on

12     the 7th of December 1992 with the leadership of Bosanski Samac.  I would

13     like to show you a page not shown to you by Mr. Jordash from the same

14     entry, the same meeting.  On the page before you Stevan Todorovic states,

15     quote -- Sorry, I don't believe we have it yet, do we?

16             THE REGISTRAR:  We need the e-court page, please.

17             MR. GROOME:  My records indicate e-court page 256.  And we are

18     looking at it on our internal systems on that e-court page.

19             JUDGE ORIE:  I could just take the witness back.  Earlier you

20     said, Mr. Milovanovic, you thought these were all MUP people and that

21     they should get in touch with the MUP, although the notebook says that

22     they should be incorporated not in the MUP but in a -- forgive me what

23     unit was mentioned, but clearly military unit, and then you say:

24             "I don't know anything else about those police officers.  I don't

25     think that they ever arrived."

Page 15536

 1             And then you moved on discussing Arkan.

 2             That thought, that they never arrived, was that based on anything

 3     specific?

 4             THE WITNESS: [Interpretation] I said that before I saw this

 5     transcript and the words of this Jovica.  I said I don't know whether

 6     they ever came.  Now, I see this Jovica claims they did and I have no

 7     reason to disbelieve it.

 8             JUDGE ORIE:  Mr. Milovanovic, that's not what you said.  You are

 9     now rephrasing your previous answer:  "I said I don't know whether they

10     ever came."  What you said is "I don't think that they ever arrived,"

11     which is not the same, and you are aware of that, I take it?  The one is

12     a thought that something did not happen; the other is a thought that you

13     do not know whether something happened.  Are you aware of the difference?

14             THE WITNESS: [Interpretation] I am.  When I was talking a moment

15     ago, I said, according to your version, that I think they never arrived.

16     But a couple of minutes later, I saw on the screen a confirmation by some

17     Jovica that they did arrive, so I have to change my opinion.  A few

18     minutes ago I thought that they had never arrived but now when I see this

19     on paper I have to change my view, and I believe that they did, they must

20     have.

21             JUDGE ORIE:  Yes.  And could you give us, then, perhaps -- at

22     this second entry, Jovica also says that I think there were -- let me try

23     to find that again.  Yes, that it helped at Sanski Most and Novi Grad.

24     What happened in Sanski Most and Novi Grad where the 400 people sent

25     could have helped at that point in time?  Was that combat?  Was that --

Page 15537

 1             THE WITNESS: [Interpretation] Yes, yes.  Sanski Most and

 2     Novi Grad were attacked.  Novi Grad was preserved.  The attacked was

 3     repelled, but Sanski Most fell.  We lost it.

 4             JUDGE ORIE:  Yes.  And in view of the fact that the offer was to

 5     incorporate them in a certain unit of the army, do you understand the

 6     reference to Sanski Most and Novi Grad as having been helpful in the

 7     military operations in those areas?

 8             THE WITNESS: [Interpretation] Precisely.  Those 400 men were

 9     probably meant to reinforce one of the VRS units.

10             JUDGE ORIE:  Please proceed, Mr. Groome.

11             MR. GROOME:  I have one follow-up question with respect to your

12     answers to the Judge Orie's questions.  But while I'm asking that

13     question, could I ask the two documents on the screen, could we reverse

14     one page on each one.  Could we go to the page before the ones that we

15     see on the screen.  The entry begins at the bottom -- or the portion I

16     want to work with begins at the bottom of the screen.

17             JUDGE ORIE:  Mr. Groome, if you would then allow me already one

18     additional question.  The operations in relation to Sanski Most and

19     Novi Grad, was the 1st Krajina Corps involved in those operations?

20             THE WITNESS: [Interpretation] Yes, the 1st Krajina Corps with one

21     staff unit, that is the protection regiment, because after Sanski Most

22     the 1st Krajina Corps ceased to exist.

23             JUDGE ORIE:  Thank you.

24             Please proceed, Mr. Groome.

25             MR. GROOME:

Page 15538

 1        Q.   General, having listened to you answer the questions of

 2     Judge Orie, can we take from this that it is possible that at this time

 3     you were not fully aware of the full involvement of Serbian MUP personnel

 4     in Bosnia-Herzegovina?

 5        A.   I've already said I wasn't aware of it at the time.

 6             MR. GROOME:  Now, if we could now turn our attention to

 7     65 ter 5603, and I apologise to the Court Officer for some of the

 8     confusion.  The B/C/S, the original, was correct that just disappeared

 9     from our screen.  If we could return that.  And with respect to the

10     English, it's e-court page 256.  So it's B/C/S e-court page 264 and

11     English e-court 256.

12        Q.   And, General, I want to focus on the entry beginning with Mladic

13     recording what Stevan Todorovic, the police chief of Bosanski Samac,

14     said.  If you could read that short bit.  When you have, indicate so and

15     I will advance to the next page.  Now, on this page we are now looking at

16     e-court in the original 265 and in the English 257.  Stevan Todorovic is

17     recorded as having said:

18             "Sent 18 men to Ilok for training, and on 18 April 1992, they

19     were transferred in three helicopters together with 30 volunteers from

20     Kragujevac, among them two members of the Serbian MUP, Dragan Djordjevic,

21     aka Crni, and Aleksandar Vukovic."

22             Do you have any direct knowledge about the transfer of

23     Dragan Djordjevic and Aleksandar Vukovic in three helicopters around this

24     time-period?

25        A.   No, I don't.

Page 15539

 1        Q.   Would you be able to assist us in identifying what helicopters

 2     might have been used?  Would VRS helicopters have been used or possibly

 3     used for such a task?

 4        A.   Could you just tell me the date.  I forgot.

 5        Q.   This is -- talking about the 18th of April, 1992, so mid-April

 6     1992, the transport of 30 volunteers and several others in three

 7     helicopters?

 8        A.   No, they could not have been helicopters of the VRS because at

 9     that time we had neither an army nor helicopters.  JNA were still ruling

10     in Bosnia-Herzegovina.

11             MR. GROOME:  Now, Your Honour, before -- this is the last

12     unadmitted Mladic notebook entry that I'm going to work with today.

13     Mr. -- or both Defence teams have tendered the entire series of

14     notebooks.  I know that is a matter we'll discuss later, but I do want to

15     note that the Prosecution is interested in tendering this particular

16     excerpt and we'll raise it when we discuss the matter in full.

17             Could I ask that we go now to P2533 [Realtime transcript read in

18     error "P2433"].  It's a notebook entry, the 19th of December, 1993.

19             JUDGE ORIE:  Mr. Petrovic.

20             MR. PETROVIC: [Interpretation] Your Honour, I apologise.  Perhaps

21     I am a bit late with this.  In the previous document there's reference to

22     General Bojic, but I believe that is a translation error.  I think it's

23     General Bajic, but we can check that later.  It's the previous document

24     we looked at.  Page 1, it says "General Bojic," I think it's in fact a

25     reference to General Bajic.

Page 15540

 1             JUDGE ORIE:  I don't know exactly what the impact would be but if

 2     the parties could agree on what person a reference to made to, then of

 3     course the Chamber would consider that, and it might lead to a correction

 4     of the transcript and the translation.

 5             MR. GROOME:  Can I just inquire whether Mr. Petrovic thinks it

 6     would be helpful to have a person who is familiar with General Mladic's

 7     handwriting look at and see -- look at the particular page and see

 8     whether he can decipher it, or is it simple a matter of translation?

 9             MR. PETROVIC: [Interpretation] I think it could be helpful.  The

10     suggestion of my learned friend Mr. Groome is very constructive.

11             MR. GROOME:  Could I ask that we return to 65 ter 5603.  I

12     understood from Mr. Petrovic's intervention that it was on the first

13     page, if that's correct.

14        Q.   General, you've been listening to Mr. Petrovic question the name

15     of one of the generals, perhaps it's a general that you know.  Can you

16     see, can you find it on the first page of 65 ter 5603 and tell us what

17     the correct version of this person's name is, if you can tell.  Sorry

18     that's the first page that I called up which is B/C/S -- e-court 264.

19        A.   Am I supposed to be looking under Stevan Todorovic or a bit

20     further up?

21             MR. PETROVIC: [Interpretation] At the bottom of the page in B/C/S

22     under the name Stevan Todorovic.

23             THE WITNESS: [Interpretation] I believe that he was an air force

24     general.  His name was Bajic, Ljubomir Bajic.  This has to do with

25     helicopters and aircraft.  As far as I know, Bajic was the commander of

Page 15541

 1     the air force corps in Banja Luka and then after the war he was

 2     commander, no, he wasn't the air force commander.  In any case, he was

 3     connected with the air force.  I used to know a General Bojic who served

 4     in Kosovo and he became general just before retirement.  He was an

 5     infantry man, therefore he didn't have --

 6             MR. GROOME:

 7        Q.   General, can I take it, based on your experience, the name Bojic,

 8     which we see on e-court page 256 in the English and 264 in the original,

 9     you believe it to be Bajic, B-a-j-i-c; is that correct?

10        A.   Yes.  Yes.

11             JUDGE ORIE:  Mr. Groome, I'm looking at the clock.  Time for a

12     break unless ...

13             MR. GROOME:  No, Your Honour, I'm very near -- I'm at the very

14     end, but I do have a two-minute audiotape to play and another document to

15     bring up.  So I think.

16             JUDGE ORIE:  That's it --

17             MR. GROOME:  It probably makes sense, I think I will be finished

18     within the first ten minutes of the next session.

19             JUDGE ORIE:  Yes.  Then we take a break.  We resume at 25 minutes

20     to 1.00, and then we expect you then to finish within the 15 minutes

21     after that.

22                           --- Recess taken at 12.05 a.m.

23                           --- On resuming at 12.39 p.m.

24             JUDGE ORIE:  Mr. Groome, are you ready to proceed?

25             MR. GROOME:  Yes, Your Honour, thank you.

Page 15542

 1        Q.   General Milovanovic, over the break I was reviewing your evidence

 2     this morning, and there was one question that I had posed that you hadn't

 3     given a complete answer to.  I'd like to pose the question to you again.

 4     It was at transcript 29 today.  It was when we were talking about

 5     communications of the Main Staff.  And my question was:  When you use the

 6     word communication, do you mean to include both reports coming into the

 7     Main Staff and directives or orders going out of the Main Staff to

 8     subordinate units?  In your answer you began to describe some of the

 9     technical means for disseminating information or communications.  Can I

10     ask you to focus on the part of the question, when you use the word

11     "communication," do you mean both reports coming in and directives and

12     orders going out or one or the other?

13        A.   Both.  It was two-way communication.  Our subordinates reported

14     to us and we communicated with them.

15        Q.   Thank you for clarifying that.

16             MR. GROOME:  Could I ask that we go to P2533.  It's the last

17     notebook entry that I will work with you during your evidence.  It's an

18     entry dated the 19 of December, 1993.

19        Q.   While that's being called up, yesterday at transcript 15369,

20     Mr. Jordash asked you about where Mauzer might have gotten supplies from,

21     and you did not have information about that, didn't know.  I want to show

22     you this entry and see whether it refreshes your recollection about

23     Mauzer and his relationship with other organisations.

24             MR. GROOME:  Could I ask that we focus on the bottom of the first

25     page.

Page 15543

 1        Q.   And right next to the number 1 is roughly where I would ask you

 2     to begin reading.  Now, here we see in this entry of the 19th of

 3     December, 1993, Mladic list the names of four people, Predrag Jesuric,

 4     Savo Kojic, Mauzer, and Dragan Micic.  And immediately afterwards he

 5     makes the observation:

 6             "They have had strong contacts with Serbia's SDB until very

 7     recently."

 8             Based on your knowledge and work with General Mladic, can you

 9     assist us in understanding what he means by this sentence?

10        A.   I don't know what General Mladic meant.  General Mladic arrived

11     from Knin long before me, I, myself, arrived only on the 11th of May,

12     when everything was already over.

13        Q.   Having read this entry does it refresh your recollection to any

14     additional evidence you may possess with respect to who Mauzer may have

15     had relationships with?

16        A.   Unfortunate I can't.

17        Q.   Thank you, General.  The last thing I want to ask you about in

18     your evidence today is about the tape that you are asked to listen to

19     last evening.  Now, the government of Serbia provided the Office of the

20     Prosecutor not only with notebooks but with audiotapes recovered from the

21     Mladic home.  The ERN of the number of the tape that you listened to

22     yesterday was T001-2432.

23             MR. GROOME:  I see Mr. Jordash has an objection.

24             MR. JORDASH:  Yes, I have an objection to the use of the fresh

25     evidence.  Number one, it is new evidence.  Number two, it doesn't arise

Page 15544

 1     through re-examination.  Dealing with the first point, it's new evidence

 2     which the Prosecution should have led during their case.  It will

 3     require -- will prejudice the Defence and will require investigation.

 4     And the investigation that it will require will be close examination of

 5     this tape, and at the moment the transcript says the speakers are

 6     unidentified.  I know Mr. Groome wants to ask Mr. Milovanovic to identify

 7     the speakers which will then give rise to all manner of investigations

 8     which include tracking down those who allegedly are speaking on the tape

 9     and ascertaining exactly who they are and trying to meet whatever point

10     my learned friend wants to make about this tape.  This at the end of the

11     Stanisic Defence case.  In relation to not arising during re-examination

12     did not touch upon anything to do with supplies of Pauk.

13             JUDGE ORIE:  Mr. Groome, but first perhaps, Mr. Petrovic, do you

14     take the same position as Mr. Jordash or would you like to add ...

15             MR. PETROVIC: [Interpretation] Yes, Your Honour.

16             JUDGE ORIE:  Mr. Groome.

17             MR. GROOME:  Your Honour, just before I deal with the objection,

18     can I just note for the record at page 57.4 it lists the previous exhibit

19     that I worked with as "2433."  It is "P2533."  So in order to avoid

20     confusion.

21             Your Honour, during Mr. Jordash's examination of this witness he

22     spent some substantial time on pointing out that there was no entry in

23     the diaries of Mr. Stanisic until the 2nd of July, 1993, and then he

24     asked questions about was he -- was it a topic -- was Mr. Stanisic a

25     topic that was discussed at the Main Staff.

Page 15545

 1             So I don't prejudice the witness's evidence but perhaps it might

 2     be more prudent to ask the witness to remove his head set.

 3             JUDGE ORIE:  Could I invite you to take off your earphones for a

 4     moment, Mr. Milovanovic.

 5             MR. GROOME:  I selected this particular audiotape of the many

 6     audiotapes recovered from the home for the following reason, and I would

 7     note that this audiotape was on our 65 ter list:  In it we hear a

 8     conversation between Mladic and other people, and it is true that we --

 9     there are -- they have not been fully identified.  But throughout that

10     conversation that are several references to Jovica Stanisic.  There is a

11     discussion between Mr. General Mladic and others about Jovica Stanisic.

12     This directly contravenes the assertion put to the witness by Mr. Jordash

13     that he was not a topic of discussion with General Mladic.  I also note

14     that there are several references to Manojlo, and as the Chamber knows

15     that is the witness's first name.  It's perhaps likely that the witness

16     will recognise that this is a conversation that he is aware of.  He

17     possibly could be one of the speakers, but certainly for the simple

18     reason that Mr. Stanisic is mentioned by name several times in a

19     discussion held by General Mladic and tape recorded by General Mladic is

20     a basis for asking the witness questions about it.  I would also point

21     out, Your Honour, it's on the Defence 65 ter list as well.

22             JUDGE ORIE:  Mr. Jordash.

23             MR. JORDASH:  I would only add if it was on the Prosecution's

24     65 ter list then they had it in their possession and ought to have used

25     it at the appropriate time.

Page 15546

 1             JUDGE ORIE:  Yes, which is not an answer to that the questions

 2     are triggered by what you addressed during your further

 3     cross-examination.

 4             MR. JORDASH:  Well, my learned friends has rightly put it that I

 5     suggested that Mr. Stanisic wasn't a subject of conversation in the years

 6     before his first appearance with Mladic on the 2nd of July, 1993.  This

 7     transcript isn't dated but I'm pretty sure it's 1994.

 8             JUDGE ORIE:  Mr. Groome, any answer to that.

 9             MR. GROOME:  Your Honour, I believe it's still -- we don't know

10     the date.  The witness may be able to assist us.  I believe it's still

11     relevant for the reasons that I have stated.  I do want to correct some

12     misinformation I provided.  The audiotape is not on our 65 ter list, it

13     is on the Stanisic Defence 65 ter list.

14             JUDGE ORIE:  And why was it not on your 65 ter list, is that to

15     do anything with the availability of the material when you drafted your

16     65 ter list.

17             MR. GROOME:  I suspect that it has something to do with it,

18     Your Honour, but when the Chamber sees the contents of the audio, there's

19     not all that much relevant information in it.  So it's not that the

20     substance is what is relevant or what is being advanced, it's simply the

21     fact that Mr. Stanisic is being discussed by General Mladic and possibly

22     other members of the Main Staff.

23             JUDGE ORIE:  Let me just have a look.  One second, Mr. ... so you

24     would say it's not primarily the -- until the 2nd of July but rather

25     whether Mr. Stanisic was a topic that was discussed irrespective of

Page 15547

 1     whether it was before or after the first entry in the written notebooks

 2     on the 2nd of July, 1993?

 3             MR. GROOME:  Well, Your Honour, I'd have to go back and check

 4     exactly the question that Mr. Jordash put to the witness but I have a

 5     distinct memory of the witness being rather emphatic that Mr. Stanisic

 6     was not someone who was discussed among members of the Main Staff and I

 7     understood his answer to be rather broad in temporal scope.

 8             JUDGE ORIE:  Could you give us some guidances.  What is the

 9     portion of -- was it the 6th or the 7th?

10             MR. GROOME:  I believe -- one second, Your Honour.  I have it in

11     reference to another question.  It's at transcript 15436, which I believe

12     was yesterday, Your Honour.

13             JUDGE ORIE:  The problem is that in e-court my 6th of December

14     transcript has not been replaced by the definitely one.  Do you have one

15     or two words which would allow me to find the relevant place.

16             MR. GROOME:  [Microphone not activated] ... Your Honour, uses --

17     I'll read the passage.  It was the question that you had asked, actually.

18     It said:

19             "Judge Orie:  The question was whether Mr. Stanisic and

20     Mr. Stanisic's co-operation with the VRS, whether that was something

21     discussed at meetings of the Main Staff.  That was the question or was it

22     not."

23             And the answer was:

24             "There was never any discussion about Jovica Stanisic as chief of

25     the State Security of Serbia."

Page 15548

 1             JUDGE ORIE:  Now, the problem is if I try to find "co-operation"

 2     in my WordWheel, it doesn't work.

 3             MR. GROOME:  Your Honour, if you WordWheel "irregularly," that's

 4     three lines above it.

 5             JUDGE ORIE:  We are still talking about the 6th or about the 7th?

 6             MR. GROOME:  This is the 7th, Your Honour.

 7             JUDGE ORIE:  The 7th, yeah, then it's not a surprise that I don't

 8     find anything on the 6th.

 9             MR. GROOME:  So i-r-r-e-g should bring this up, Your Honour.

10             JUDGE ORIE:  Yes.  Let me first get the transcript of the 7th on

11     my screen.  Yes.  It's at page 33 of the old version.

12             The objection is denied.  The basis in the answers of the witness

13     gave in cross-examination is sufficient to allow the Prosecution to

14     proceed.

15             Please proceed, Mr. Groome.

16             MR. GROOME:

17        Q.   General, can you hear me?

18        A.   I can.

19        Q.   General, last evening you were asked to listen to an audio

20     recording.  It was ERN number T001-2432.  A portion of that audio

21     recording has already been introduced into evidence as P2956.  My first

22     question to you regarding that audio is:  Did you have an opportunity to

23     listen to it before today?

24        A.   No, I didn't hear it before.

25        Q.   I'm inquiring now is whether the technical equipment worked and

Page 15549

 1     were you able to listen to it yesterday evening?

 2        A.   I listened to it, but I would like to know from you whether the

 3     contents of the tape are the same as the contents of the transcript that

 4     you provided me with.

 5        Q.   A transcriber has listened to the tape and done what they believe

 6     to be their best job at recording what was said.  Do you ask that because

 7     you notice that there were some important differences, or important

 8     omissions?

 9        A.   No, no, I simply noticed that my name was mentioned in a

10     different number of times.  At place it was mentioned 17 times and at

11     other places more times.  However, the contents of the conversation

12     between Mladic and the person, the unknown person, what I could hear and

13     what was described is pretty much the same.

14        Q.   Are you saying now that your name was -- appeared in the

15     transcript at a time when you could not hear it on the audiotape?

16        A.   Precisely.  It seems that the person who transcribed the

17     conversation had better listening conditions available to him so he could

18     hear the tape much better than I did.  And that's why I asked you whether

19     the contents are the same.

20             JUDGE ORIE:  Let's be very practical.  Mr. Groome, do you want to

21     deal with the whole of the audio or with specific portions?

22             MR. GROOME:  Going to ask some general questions about the time

23     and the participants and then I just have a 2 minute 30 second portion I

24     want to ask specific questions about.

25             JUDGE ORIE:  Then we've heard from the witness that, here and

Page 15550

 1     there, the transcript, as far as his own name is concerned, might not

 2     be -- might even be more complete as he was able to verify in the audio.

 3     If this affects in any way your answer to one of the questions that will

 4     be put to you by Mr. Groome, Mr. Milovanovic, please don't hesitate to

 5     address that matter.

 6             Please proceed.

 7             MR. GROOME:  Your Honour, can I just inform the court that the

 8     transcriber would have used professional equipment and the that copy

 9     Mr. Milovanovic listened to was on a Dictaphone, obviously of less

10     quality.  That may account for --

11             JUDGE ORIE:  If there's any continuing disputes about this, I

12     take it that the parties will address that.  Again, if it affects one of

13     your answers, please let us know, otherwise just answer the questions.

14             MR. GROOME:

15        Q.   General, despite the diminished quality of the audio, were you

16     able to recognise the speakers on the tape?

17        A.   From the tape I recognised Mladic's voice at the end because it

18     seems Mladic was recording and he was aware he was recording, so he was

19     talking in a whisper and only in the end he must have lost it and started

20     speaking more loudly, so I recognised his voice.  The other person,

21     however, the other speaker, I couldn't recognise the voice but his speech

22     is characterised by volubility and plenty of profanity.  The man doesn't

23     take a breath, talks all the time, and there's something in what he says

24     that makes me think it was the time of the counter-strike against Bihac,

25     and there are several indices that indicates it might be a person who was

Page 15551

 1     in the government of Vojvodina who might have been deputy speaker of the

 2     Assembly or vice-deputy prime minister.  I think his last name is Stupar.

 3     He came to see me twice in the area of Grmec.  And I inferred that from

 4     the fact that he tells Mladic is he a native of Bosanski Petrovac.  He

 5     talks about oil.  Now, I don't know whether he was donating oil or

 6     trading in oil but proof of that is that he says to Mladic that

 7     Milovanovic is taking one-third -- sorry, not Milovanovic, but Manojlo,

 8     out of 12 cisterns 4 go to Manojlo, and he will distribute 5.000 to

 9     municipalities each.  I don't know whether it's 5.000 Deutschemark or

10     5.000 litres of fuel.

11        Q.   It's a rather long tape and if I could just focus on just a

12     couple of portions and ask your comment on.  The references to a Manojlo,

13     do you believe them to be actually references to you or another person

14     with the same name?

15        A.   I'm sure it concerns me because he is praising me to Mladic

16     saying that I'm a genius, that the troops love me, they obey me and he

17     asks Mladic at the end:  How long till you get into Bihac, will it be

18     just a day or two?  And that's how I inferred it must be the Bihac

19     operation.

20        Q.   Now, you've referred or you have placed it in the time-period of

21     the Bihac operation.  So the record is clear, can you give us the

22     approximate months and years that you are referring to?

23        A.   It's the counter-attack at Bihac from 31st October, 1994, until

24     Carter's truce in -- on 24th December, 1994.

25             MR. GROOME:  Could I ask now that Mr. Laugel play -- first of

Page 15552

 1     all, can we maybe bring to the screens the transcript.  It's

 2     65 ter 06330.1.  Copy of this 2 minute 30 second portion has been

 3     provided to the booths.

 4             General, I'm going to play just a short portion of that and then

 5     ask you a question afterwards.

 6                           [Audio-clip played]

 7             MR. GROOME:

 8        Q.   Now --

 9             JUDGE ORIE:  Mr. Groome, we have not -- we've not followed the

10     usual procedure which is that we receive an English translation.

11     Therefore, at the English transcript nothing now appears.  At the same

12     time, of course, we have on the -- we have a transcript as part of the --

13     of what I take it you'll tender as an exhibit.

14             MR. GROOME:  That's correct, Your Honour.

15             JUDGE ORIE:  Now, can the parties live with that, that we have a

16     written -- the problem is that not all parts are well audible.  I noticed

17     that there is a French translation, so the French transcript is complete.

18     That's why we had to wait for awhile to have it finished.  At this moment

19     also looking at the clock, could the parties agree that we work on the

20     basis of the transcript which then should be also in written form and not

21     only as part of the video be filed as an annex to what may become an

22     exhibit.

23             MR. GROOME:  Yes, Your Honour.

24             JUDGE ORIE:  I'm looking at the other parties.  No one disagrees,

25     although I usually prefer to have a full English transcript.  I see that

Page 15553

 1     we can live with it for the time being.  Please proceed, Mr. Groome.

 2             MR. GROOME:

 3        Q.   General, the reference in there about you getting four of

 4     something and Jovica Stanisic getting eight of something, is that a

 5     reference to the cisterns of fuel that you've referred to just a moment

 6     ago?

 7        A.   As far as I'm concerned, these are cisterns of fuel.  I don't

 8     know about Jovica, I didn't even notice that.  I believe I should explain

 9     what that means.

10        Q.   It's not all that important to us at the moment about whether

11     what those cisterns were.  My question actually was going to be something

12     else.  Near the beginning of that excerpt we hear one of the speaker say

13     "Jovica will come with his men," and my question is:  Do you know what

14     that is a reference to?

15        A.   I don't know what is meant.  Jovica never came to see me at

16     Grmec.  I found Jovica on the 8th of November at Slunj, that's the

17     Republic of Serbian Krajina.

18        Q.   And the audio also records a comment about coming from Mirkovci.

19     Does that sound familiar to you, do you recognise that name, and, if so,

20     what can you tell us about Mirkovci?

21        A.   Mirkovci is a village near Eastern Slavonia, if I remember

22     correctly.

23        Q.   And can you tell us how far it is from another village by the

24     name of Djeletovci, if you know?

25        A.   I can't.  I don't know where either is but I know they are in


Page 15554

 1     Slavonia.

 2             MR. GROOME:  Thank you, General.  I have no further questions at

 3     this time, Your Honour.  There are two things that I would -- three

 4     things.  One is the Prosecution would tender that excerpt, that's

 5     65 ter 6330.1, and, again, I note that another excerpt is in evidence as

 6     P2956.

 7             JUDGE ORIE:  Any objections in addition to what was said already

 8     to the use of the document?

 9             MR. JORDASH:  Same objections, Your Honour.

10             JUDGE ORIE:  Yes.  Then I think the ruling on the Prosecution

11     being allowed to use the document also answers the question about

12     admission.

13             Madam Registrar the number would be?

14             THE REGISTRAR:  The number would be P3052, Your Honours.

15             JUDGE ORIE:  And is admitted into evidence.

16             Mr. Groome, would you take care that there is a written -- that

17     is not part of the video, but a written transcript as part of --

18             MR. GROOME:  Yes, Your Honour.  I believe it may already be

19     uploaded, but I will check with Mr. Laugel to verify that.  And the

20     second matter, Your Honour, is, if I could ask Madam Registrar --

21             MR. JORDASH:  Sorry, the witness has got his hand up.

22             JUDGE ORIE:  One second.

23             Yes, before I proceed with that, Mr. Milovanovic, is there a

24     matter you would like to raise?

25             THE WITNESS: [Interpretation] Yes, Mr. President.  I don't want

Page 15555

 1     the record to remain as it is because I don't know whether this man was

 2     smuggling or trading in oil, and I don't want to appear on the record as

 3     his accomplice.  I had authorisation from the Supreme Command to approve

 4     exemptions from customs tax to private oil dealers with the proviso that

 5     the army keeps one-third.  So out of these 12 cisterns of fuel, four

 6     remained for the VRS, not for myself.  That's the correction I wanted to

 7     make and I don't know if this is the end of my testimony, but I have a

 8     question to the Defence teams.

 9             JUDGE ORIE:  This is not the end yet of your examination.

10     Witnesses usually are not supposed to ask questions, but we'll later hear

11     from you because the examination of a witness is, as a matter of

12     principle, is a one-way traffic, but we'll see what you'd like to ask to

13     the Defence and then we'll decide whether this is a question

14     appropriately be put to the Defence.

15             Mr. Groome, I think first we should -- yes, admission into

16     evidence has been decided.  There was a second matter you would like to I

17     raise.

18             MR. GROOME:  Yes, Your Honour, also to make clear in light of the

19     witness's comment, the Prosecution has not presented that tape as any --

20     with any suggestion that General Milovanovic has done anything incorrect

21     and is in possession of no evidence that anything in that tape was

22     incorrect.

23             Now, with respect to the second matter, Your Honour, the there

24     have been many references to notebook entries over the course of the past

25     three days.  If I could ask Madam Registrar to pass up to the Chamber the


Page 15556

 1     printed sheet that I provided earlier.

 2             MR. JORDASH:  I am sorry to leap to my feet, it's just that I'm

 3     noticing the time and I think --

 4             JUDGE ORIE:  If it is a matter which can wait until we have

 5     excused the witness, Mr. Groome, then I would prefer to do that.

 6             MR. GROOME:  It can, Your Honour, I'm wait.

 7             JUDGE ORIE:  Then any further questions, it will be you first,

 8     Mr. Jordash.

 9             MR. JORDASH:  Your Honour, yes, and I fear that I may not finish

10     because Mr. Groome has opened up the whole of the Sanski Most crime base

11     which I need to deal with.  In effect, it's a de facto opening of the

12     Prosecution case on this issue, so I would like a little time to deal

13     with that.  In addition, I would --

14             JUDGE ORIE:  You should try to finish.  I don't know whether

15     Mr. Petrovic has any specific matters?

16             MR. PETROVIC: [Interpretation] Your Honour, not at this moment

17     but I'm trying to locate a reference, and if I do I may have a few

18     questions to put to the witness with your leave.

19             JUDGE ORIE:  Mr. Jordash, try to finish within the time

20     available.  And be focused.  I have commented quite a couple of times,

21     both Defence teams, on being focused on matters in dispute that took

22     altogether six hours.  Let's try to see where we can come.

23             MR. JORDASH:  Could we have on the screen please P2546.

24                           Further Cross-examination by Mr. Jordash:

25        Q.   I want to return to the issue of Sanski Most, Mr. Milovanovic.

Page 15557

 1     It's a Mladic notebook dated the 3rd of October, 1995.

 2             MR. JORDASH:  And I want English page 1 and English page --

 3     B/C/S -- sorry, B/C/S page 1.

 4        Q.   Now, we went through -- or you went through with Mr. Groome a

 5     number of entries in Sanski Most, but you didn't go through perhaps one

 6     that might have assisted you.  In fact, there's two or three which I want

 7     to remind you of to see if it helps with your recollection of events in

 8     Sanski Most.  First of all, this one which appears to be a meeting with

 9     Filipovic, aka Fica, and Bozovic.  Please take a moment to read.

10        A.   I've read the page.

11        Q.   Did you know that Filipovic was suggesting that Arkan was under

12     the control of Pecanac at the beginning of October 1995?

13        A.   I knew that they were close to each other.  I saw it on TV.

14        Q.   What did you see to indicate that they were close?

15        A.   I saw them together at an observation post near Kljuc.

16        Q.   Thank you.  Now, in relation to the comment which seems to be

17     attributed to Bozovic, or the comments that he was from General Bozovic's

18     house and they had been given a task to replace the RS police who would

19     then go to the forward defence line and its suggested by Mladic there

20     that this was agreed with Karadzic and yourself.  Do you know anything

21     about that?  Does that trigger your memory about what Bozovic and the

22     Serbian MUP were supposed to be doing?

23        A.   Bozovic and Filipovic came to see me together, and that was my

24     only meeting with Bozovic.  As I have already told you, I don't know.  I

25     was not even sure that they ever came back.  I never saw Bozovic again at

Page 15558

 1     the command of the 1st Corps.

 2        Q.   So you don't know whether there was an agreement between Karadzic

 3     and Bozovic that the Serbian MUP would replace the RS MUP so that the RS

 4     MUP could go into combat?

 5        A.   Before the first break I said that Karadzic told me that people

 6     would arrive from the MUP of Serbia, and indeed Filipovic and Bozovic did

 7     arrive.

 8        Q.   Now, when you were being questioned by Mr. Groome and the learned

 9     Judge, you indicated that you thought that probably the Serbian MUP had

10     been in combat in a couple of towns.  Am I correct though that you don't

11     recall them forming part of the 1st Krajina Corps?  You didn't issue any

12     instructions or orders in relation to them or see them in combat?

13             JUDGE ORIE:  I think that question has been clearly answered

14     already by the witness, isn't it, Mr. Jordash.

15             MR. JORDASH:  I'll move on.

16             JUDGE ORIE:  Please proceed.

17             MR. JORDASH:  Let's go to 65 ter 5611, please.  It's page 91 of

18     the English, 100 of the original scanned version.

19        Q.   And we are moving forward from the beginning of October to the

20     15th of October, 1995, and a meeting with security organs at 12.30.  This

21     was not shown to you, so take a moment to read it.  You there?

22        A.   The only thing that I can actually discern is Pero Jakovljevic.

23     I see a reference to Arkan, but I really can't make out head or tail of

24     the whole thing.  I'm maybe tired.

25             MR. JORDASH:  I think let's have the typed copy, if we can,

Page 15559

 1     please, of the B/C/S which I think is page 91.

 2             THE WITNESS: [Interpretation] Let's not waste time.  I can read

 3     some things.  Yes, but can this be zoomed in, please.

 4             MR. JORDASH:

 5        Q.   Do you have it?

 6        A.   Yes.

 7        Q.   Did you know this Colonel Jakovljevic?

 8        A.   Yes, I knew him.  He was the head of the 410th Security Centre

 9     and the security organ.  He died a few years ago.

10        Q.   Did you know that he as a security organ was querying along with

11     others who had brought Arkan in the middle of October?

12        A.   I already said that early this morning.  Everybody in the

13     military wondered that and I'm still wondering to this very day.

14        Q.   Yes, and you said you wanted to take that up with Karadzic.  So

15     am I correct then it follows, doesn't it, that --

16        A.   Yes.

17        Q.   It follows, doesn't it that no one in the military was connecting

18     Arkan with the Serbian DB, everyone was querying, and for you, you want

19     to take up the issue with Karadzic?

20        A.   Yes.  I requested those meetings that I already spoke about when

21     the meeting did take place he -- Arkan said that he had an order from the

22     Supreme Command.  I asked him to fetch that order but then he changed his

23     mind and he said that he did not have any orders, and then I asked

24     Karadzic before the entire Supreme Command:  Plavsic, Koljevic,

25     Krajisnik.  And there were three generals:  Talic, Koljevic and myself.

Page 15560

 1     And Karadzic didn't say a word.  And then two days later I saw him being

 2     escorted from Bijeljina.  I still have my doubts about Karadzic having

 3     invited him.  He did not engage immediately but he started being violent

 4     towards the officers of the Army of Republika Srpska, and then I

 5     concluded and I said that to Karadzic that Arkan came to discipline the

 6     Army of Republika Srpska.  They were after the former soldiers of the

 7     Republic of Serbian Krajina who were fleeing across our territory and

 8     when they caught them they would detain them at Manjaca.

 9        Q.   Looking at the entry:

10             "At the Assembly that they will demand that you are replaced,

11     that Talic take over the Main Staff and Arkan or Lisica take over the

12     1st Krajina Corps."

13             Were you aware of this news or these rumours that --

14             JUDGE ORIE:  Could we first ask who "you" is in this context.

15             MR. JORDASH:

16        Q.   Who do you think "you" is in this context?

17        A.   Colonel Jakovljevic reported to Mladic, so it is Mladic who was

18     supposed to be replaced.  All that came to a head once on the 4th of

19     August, 1995, after the fall of Knin.  All the generals of the

20     Army of Republika Srpska wrote to the Assembly to overturn that decision.

21     According to that decision, I was supposed to take over the leadership of

22     the army and Mladic was supposed to be appointed as a special advisor,

23     but the generals rejected the decision of the Supreme Command, and the

24     Assembly was in favour of the generals and Mladic was not replaced.  Here

25     a security officer reports to Mladic there's something brewing again

Page 15561

 1     about his replacement.  Talic was supposed to be the head of the

 2     General Staff.  General Lisica was supposed to be appointed as chief of

 3     the 1st Krajina Corps but he was then pensioned off in 1994.  I would say

 4     that this is a bit far-fetched on the part of the security organ.  Talic

 5     was my senior in terms of rank, the senior -- than me, so it would only

 6     have been logical for him to replace Mladic, not me.

 7        Q.   Thank you.  Certainly at this point in time there was open

 8     conflicts between Karadzic and Mladic with Karadzic wanting to get rid of

 9     Mladic; is that right?

10        A.   There were never open conflicts between Karadzic and Mladic.

11     Nothing was displayed at meetings.  I don't know what happened behind

12     closed doors.  However, there was a conflicts between the views of the

13     military and the representatives of politicians.  Karadzic represented

14     politicians, Mladic represented the military, and there were conflicts in

15     terms of how to wage that war in the future.

16             MR. JORDASH:  Thank you.  Let's go to 65 ter 5611.  Page 111.

17     Page 120.  And we are moving forward to the 25th of October, Banja Luka,

18     a meeting of the inner circle of the General Staff of the VRS and the

19     commanders on the western part of the front line.

20        Q.   I'm interested in the entry which is the first item and what you

21     are purported to have said.

22             THE INTERPRETER:  Could the counsel please switch off his

23     microphone, thank you.

24             THE WITNESS: [Interpretation] I don't know, my concentration

25     fails me here.  I can't read the handwriting.  The only thing I can see

Page 15562

 1     here is that I'm complaining that nothing has arrived from Serbia but

 2     that's it.

 3             MR. JORDASH:  Can we have on the screen, please, the typed copy,

 4     which is 111.

 5        Q.   I think it's important that you see it and read it to remind

 6     yourself since it's a long time ago.

 7        A.   I've read it.

 8        Q.   Did you say that the Serbian MUP has probably put the border

 9     under its control after Arkan was chased away?

10        A.   Yes.  You can see here that for four days there have been no

11     flows of people and goods across the border.  This made me conclude that

12     the Serbian MUP closed the border because we had chased Arkan away.  But

13     that was not the biggest problem.  The biggest problem was our own

14     police, the police of Republika Srpska, after Arkan was chased away.

15     Tomo Kovac did not accept our order on the use of the military police

16     there.  We wanted to use the military police on border crossings and

17     there was a deterioration after an RS delegation visited Milosevic which

18     means that somebody from the sphere of politics went to see Milosevic to

19     talk to him about something because Mladic and I were the ones who were

20     behind the decision to chase Arkan away.

21             That night when I had the meeting with Arkan and it was agreed

22     that I would chase him away from Manjaca and Mladic would chase him away

23     from Kotorsko village near Doboj.

24        Q.   Were you presuming the Serbian MUP had put the border under

25     control to keep Arkan out of the region, out of Banja Luka?  Is that what

Page 15563

 1     you were saying there?

 2        A.   No, I realised then and there at that meeting that the Serbian

 3     MUP closed the border for the traffic of people and goods, which means

 4     that we couldn't receive anything from them and send anything to them.  I

 5     know that the generals and politicians could not move across the borders.

 6     There was a ban on their travels.

 7        Q.   Okay.  And Tomo Kovac was not pleased about Arkan being chased

 8     away, is that what we should take from this?

 9        A.   Tomo Kovac was angry with the army for having chased the army

10     away which means that Arkan was under the patronage of the MUP of

11     Republika Srpska, and it was well known who was in command of the

12     Republika Srpska MUP.

13        Q.   If there had been Serbian police officers in towns carrying out

14     crime prevention activities, would you necessarily have known that?

15        A.   No, I would not have known.  All I cared about was warfare and

16     those were not just ordinary policemen but special police officers, those

17     who could be and were engaged in combat.  I was not interested in public

18     law and order.

19        Q.   Was it ever reported to you that Stanisic had said that Arkan had

20     embedded himself in Banja Luka?

21        A.   Nobody ever told me that.  The only thing I found out was that

22     Arkan had a room at the hotel Bosna, whereas his mob was scattered all

23     over Bosnian Krajina.

24             MR. JORDASH:  Thank you.  I'd like to refer to P61 now.

25        Q.   It's a different subject.  It's the subject of airfields and

Page 15564

 1     combat flights.

 2             MR. JORDASH:  And could we have, please, page 11 of the English

 3     and page 8 of the B/C/S.

 4        Q.   Now, while that is coming up, Mr. Milovanovic, this is a speech

 5     that Mr. Groome referred to, a speech by Mr. Simatovic, and I want to

 6     make sure that you understand what was actually being suggested by

 7     Simatovic and ask you to comment on it, please.  I want to focus on the

 8     section which begins, I think, actually, we need to go to the B/C/S

 9     page 9 because I'm going to deal with the airfields point first.  And I

10     want to deal with the claim that in 1992 they, i.e., the Serbian DB,

11     began building and securing a network of small airfields in

12     Bosnia-Herzegovina and also forming a combat squadron.  If you would read

13     that, please.  And if you would read down to the sentence just before the

14     sentence dealing with the Captain Dragan's Fund.

15        A.   I don't have that page in front of me in B/C/S.  Stop.  No, no.

16     I can see that, actually, but the counsel mentioned the year 1991, so

17     shall I read the portion starting with the year 1992?

18        Q.   "Also in 1992," start with that, please.

19             JUDGE ORIE:  While the witness is reading, how much time would

20     you still need, Mr. ...

21             MR. JORDASH:  I could -- well, I don't know what the witness is

22     going to -- I want to take him through just some small sections on this

23     speech which will take about 10 minutes, and then the problem is I would

24     also like to take him into the subject of this audiotape and I don't know

25     what he is going to say because I have no idea what it all means.  So I

Page 15565

 1     think maybe 30 --

 2             JUDGE ORIE:  Mr. Petrovic, how much time would you still need?

 3             MR. PETROVIC: [Interpretation] Your Honour, five minutes, let's

 4     say.

 5             JUDGE ORIE:  As matter stands now, Mr. Groome?

 6             MR. GROOME:  Nothing, Your Honour.

 7                           [Trial Chamber and Registrar confer]

 8             THE WITNESS: [Interpretation] I've read the entire text.

 9             JUDGE ORIE:  The total of the time still needed would amount to

10     approximately 20 to 25 minutes, and where otherwise would have to keep

11     the witness here until Tuesday afternoon, I am just looking at the

12     possibility and I first have to confer with my colleagues whether we

13     could extend this session with some 20 to 25 minutes, and then I would be

14     very strict on timing and I add to this that if the time used during the

15     first six hours of examination would have been used more focused then we

16     would have avoided this problem.

17                           [Trial Chamber confers]

18             JUDGE ORIE:  Mr. Jordash, if we get the approval of all those

19     assisting us, and I'm not the master of their time, then you would have

20     from now on exactly 17 minutes which brings us to three minutes past

21     2.00, then five minutes for Mr. Petrovic and that would be it.

22             Mr. Groome, as matters stand now, of course then --

23             MR. GROOME:  Can I just ask that we go briefly into private

24     session.

25             JUDGE ORIE:  We briefly move into private session.


Page 15566

 1                           [Private session]

 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   (redacted)

19                           [Open session]

20             THE REGISTRAR:  We are in open session, Your Honours.

21             JUDGE ORIE:  Thank you, Madam Registrar.  And may I take it that

22     you have verified with support staff and officials.  We provisionally

23     proceed on this basis and if there are major -- if there's major

24     opposition we would hear that.

25             Mr. Jordash.


Page 15567

 1             MR. JORDASH:  Thank you, and I'm very grateful to everyone.

 2             JUDGE ORIE:  Please proceed.

 3             MR. JORDASH:

 4        Q.   You, in response to questions from Mr. Groome, who put to you a

 5     part of what Mr. Simatovic had said, you said "as for auxiliary airfields

 6     where airfields can take off and land," apart from the four that you

 7     mentioned in your testimony," I don't know any others because we didn't

 8     use them and there was no need for me to be interested in them."  And I

 9     want to ask you, therefore, about what Mr. Simatovic said.  Did you

10     observe at any point a network of small airfields being run by the

11     Serbian DB in VRS territory during the conflict?

12        A.   No, I didn't notice that.

13        Q.   Given the equipment and surveillance units you had under your

14     subordination, do you think you would have noticed a network of small

15     airfields and the DB running thousands, or hundreds even, combat,

16     humanitarian, reconnaissance, and transport flights?

17  A. It would have been impossible for anybody to be flying apart from or next

18  to the air force of Republika Srpska because those airports - Sokolac,

19  Rogatica - simply did not exist.  The airport I'm talking about, we just

20  marked the air strip, and it has not changed to this day, it is not

21  operational.  And in Bratunac, the air strip was a bit longer but it was a

22  macadam air strip so only propellor aircraft could land.  We had one of

23  those transport planes -- we had a pet name of it -- for it, Old Vujadin,

24  and that was the only thing that landed.  I think it was the AN2 type plane. 

25  And as for the other air forces, there were none in Republika Srpska because

Page 15568

 1  on the 31st of March, 1993, the no-fly zone resolution of the Security

 2  Council was imposed and I'm sure that people from Yugoslavia had not been

 3  so crazy as to send their aircraft our way, into the jaws of NATO.

 4             MR. PETROVIC: [Interpretation] Your Honour, I apologise on

 5     page 81, line 18 and 19, the witness mentioned another two airfields

 6     which did not exist and still they are mentioned in this entry.

 7             JUDGE ORIE:  Could you please, where you referred to the Bratunac

 8     air strip, did you make reference to any other air strips?

 9     THE WITNESS: [Interpretation] I mentioned the airfield at Bratunac or

10     in brackets -- Skelani.  That's the airport between Bratunac and

11     Skelani.  Before the war there was only two municipalities, Bratunac and

12     Srebrenica.  Skelani as a municipality did not exist before the war.

13             JUDGE ORIE:  Mr. Milovanovic, you are not invited to repeat your

14     evidence but just say what other air strips you mentioned.  Mr. Petrovic,

15     the matter has been -- otherwise you can ask for a correction of the

16     transcript on the basis of --

17             MR. PETROVIC: [Interpretation] [Overlapping speakers] ... no

18     Your Honour, no.

19             JUDGE ORIE:  Please proceed, Mr. Jordash.

20             MR. JORDASH:  Thank you, Your Honour.

21        Q.   Mr. Simatovic said that in mid-spring of last year, which would

22     have been 1995, the DB retreated from these parts with complete equipment

23     and machinery, helicopters, and aircraft.  Did you observe the Serbian DB

24     doing that, and would you have, if they had?

25        A.   Sir, I'm totally confused now.  What year are we talking about?

Page 15569

 1     What speech are you talking about?  You are talking about Simatovic's

 2     speech from the year 1991 and you put before me some events that took

 3     place in 1992.

 4        Q.   No, I'm asking you about a speech which was made in 1996.  This

 5     speech was made in 1996.  And, I beg your pardon, 1997.  And I'm asking

 6     you whether you saw the DB in -- well, 1996 or 1995 or any year, removing

 7     equipment detailed, helicopters and aircraft, and so on, the type of

 8     equipment that would be used in an airfield?  Did you see that?

 9        A.   No.

10        Q.   What a -- you gave evidence about your helicopter being detected

11     by General Morillon.  How often were you using that helicopter before he

12     detected you?

13        A.   What?  What happened to my helicopter?

14        Q.   You testified, when Mr. Groome was asking you questions, about

15     flying your helicopter and you were never detected until General Morillon

16     complained about it.  Do you recall that?

17        A.   Yes.  I used the helicopter whenever I needed.  NATO radars could

18     not detect me.  Morillon, however, did detect me.  I was supposed to meet

19     him between Srebrenica and Bratunac when he had been captured by

20     Naser Oric.  I was supposed to be involved in negotiations.  I used a

21     helicopter.  He asked me how I had arrived.  I said I used the helicopter

22     to fly into Bratunac, and then a few days later, he complained before the

23     Security Council that I had used the helicopter and that I violated the

24     no-fly zone agreement.

25             JUDGE ORIE:  I take it that this answers your question.

Page 15570

 1             MR. JORDASH:  Yes, thank you.

 2             JUDGE ORIE:  Please proceed.

 3             MR. JORDASH:

 4        Q.   Did Morillon or any other international authority from NATO, or

 5     otherwise, complain to you about the DB flying with helicopters or

 6     aircraft?

 7        A.   No.

 8        Q.   Did any of your security organs report that to you?

 9        A.   No.  Yugoslav helicopters did not fly over the territory of

10     Bosnia-Herzegovina.  It was only once that General Perisic flew over the

11     Drina River near the village of whose name I forget now.  He entered the

12     Serbian territory in the depth of 50 metres.  Milosevic sent him to talk

13     to me and to butter him up so I would be prepared to accept the

14     Contact Group plan.

15        Q.   Thank you.  If your security organs had observed that, would you

16     expect them to have put that into written reports?

17        A.   I can't answer the question.  I don't know.

18        Q.   Let me try again.  If a entity other than the VRS was flying

19     hundreds of flights in VRS territory, supplying military organisations,

20     wouldn't you expect your security organs to record that in one report at

21     least?

22        A.   No.  The commander of the air force and anti-aircraft defence of

23     the Army of Republika Srpska informed me about that.  He would have been

24     the one to brief me about that.

25        Q.   And they didn't, did they?

Page 15571

 1        A.   They informed me regularly about the number of sorties, the type

 2     of aircraft when NATO aircraft flew over Bosnia-Herzegovina and

 3     especially when they bombarded us.  They informed me about all sorts of

 4     flights, reconnaissance flights, combat flights and all types of flights.

 5        Q.   Belonging to NATO, but no other entity?

 6        A.   Nobody else flew over Bosnia-Herzegovina.

 7        Q.   Thank you.  Let me now just take you to another part of the

 8     speech.

 9             MR. JORDASH:  If we can go to page 8 of the B/C/S and page 11.

10        Q.   Let me deal with this more swiftly.  Simatovic also claimed that

11     there was -- the DB ran training camps in Banja Luka, Doboj, Samac,

12     Brcko, Bijeljina, Trebinje, Visegrad, Ozren, and Mrkonjic Grad.  Did you

13     see them, would you have seen them if they existed?

14        A.   I didn't see them.  I was in no position to see them from Skopje.

15        Q.   I'm talking about training camps allegedly in existence in --

16     well, it's unclear, we haven't been given dates, but let's just say 1992

17     to 1995?

18        A.   This speech was delivered in May 1991.  And it says that the -- I

19     did not.

20             JUDGE ORIE:  The speech was not delivered in May 1991.  Did you

21     ever hear of training camps Mr. Simatovic in the speech claimed to exist

22     in Banja Luka, yes or no?

23             THE WITNESS: [Interpretation] No.

24             JUDGE ORIE:  Doboj?  Any in Doboj?  Any of the DB-ran training

25     camps in Banja Luka, Doboj, Samac, Brcko, Bijeljina, Trebinje, Visegrad,

Page 15572

 1     Ozren and Mrkonjic Grad.  Did you ever hear about DB-run training camps

 2     between 1992 and 1995 in these places?

 3             THE WITNESS: [Interpretation] You mean the State Security of

 4     Serbia?

 5             JUDGE ORIE:  Yes, I mean that.

 6             THE WITNESS: [Interpretation] I heard about a training camp in

 7     Doboj.  I heard that in -- from somebody's testimony, but I don't know

 8     when and I didn't see it.

 9             JUDGE ORIE:  Do you have any additional knowledge about this

10     training camp apart from what you heard in someone else's testimony?

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

12             JUDGE ORIE:  Please proceed, Mr. Jordash.

13             MR. JORDASH:  Thank you, Your Honour.

14        Q.   Given the resources that would be needed to set up a training

15     base, would you have expected to have seen some trace, the delivery of

16     supplies, the movement of men, and so on, if those training bases had

17     existed and been under the supervision of the DB?

18        A.   Well, only if I had ventured into the area by chance to see some

19     traces of what, boots or something else?  No, I didn't see anything like

20     that.

21             JUDGE ORIE:  Mr. Jordash, last minute.

22             MR. JORDASH:

23        Q.   Let's just deal very quickly with the section of the tape that

24     you listened to.  Did you understand what this tape was saying?  Did it

25     make sense to you?  Did it trigger off any recollections, the tape you

Page 15573

 1     listened to overnight?

 2        A.   That was an insignificant document for me.  It may be of some

 3     interest for you because one of those men hailed from outside of Serbia.

 4     He lives in Novi Sad, to be more specific.  He mentions Zeleni, I don't

 5     know in what context, I didn't understand that.  He was born in Petrovac.

 6     I don't know what his purpose was, whether he came back to his -- to the

 7     place where he was born, how he was involved in the trade of fuel, I

 8     don't know.  For me that tape and that document was totally

 9     insignificant.

10        Q.   Did you ever, as far as you know, share supplies with Stanisic?

11        A.   No.

12        Q.   Supplies of oil or any other supplies of military type logistics?

13        A.   No.  I did not have enough to distribute among my men let alone

14     some to Stanisic.

15             JUDGE ORIE:  Mr. Jordash, the answer to the first question was

16     clear:  You never shared supplies with Mr. Stanisic.  Then to say:  Did

17     you never share oil, did you never share vehicles, I mean no supplies and

18     then you start continuing.  Okay, that's -- I gave you 17 minutes.

19     You've had them.

20             MR. JORDASH:  Yes, I can't in the time go through this tape, so

21     I'll leave it at that.

22             JUDGE ORIE:  I think Mr. Groome said he was not primarily

23     interested in the contents of the conversation.

24             Mr. Groome, is that correctly understood.

25             MR. GROOME:  That's correct, Your Honour.


Page 15574

 1             JUDGE ORIE:  Mr. Petrovic.

 2             MR. JORDASH:  But I'm not sure that means what that means

 3     legally, I mean, not primarily means he will use the contents but it may

 4     not be his primary concern.

 5             JUDGE ORIE:  Mr. Petrovic now has an opportunity to put further

 6     questions to the witness.

 7             MR. PETROVIC: [Interpretation] Your Honour, two or three

 8     questions.

 9             JUDGE ORIE:  Please proceed.

10                           Further Cross-examination by Mr. Petrovic:

11        Q.   [Interpretation] Witness, just awhile ago you said that it is

12     well known who was in charge of the MUP of Republika Srpska.  You didn't

13     give us any names.  Who did you mean?

14        A.   At what time?

15        Q.   In the autumn of 1995.

16        A.   Tomo Kovac.

17        Q.   Thank you.  Earlier today you answered questions about the

18     establishment of a communication system within the

19     Army of Republika Srpska after the 12th of May, 1992.  Up to that time

20     was there a communication system established by the Yugoslav People's

21     Army in the territory of Bosnia-Herzegovina?

22        A.   Yes, it existed and there were 13 hubs that remained in the

23     territory of Republika Srpska.  I said earlier today that I inherited all

24     those communication hubs from the war command post from the former JNA.

25        Q.   Thank you.  One more question, sir.  We all spoke at length about

Page 15575

 1     those police officers from Serbia who either arrived or did not arrive in

 2     Republika Srpska in the autumn of 1995.  Let's leave that aside, do you

 3     know anything about possible policemen from Serbia possibly be -- having

 4     been engaged in combat in Republika Srpska?  I'm talking about autumn

 5     1995.

 6        A.   I didn't know anything about that at the time.

 7             MR. PETROVIC: [Interpretation] Thank you very much.

 8             Your Honours, I have no further questions for this witness.

 9             JUDGE ORIE:  Thank you, Mr. Petrovic, for staying within the

10     time-limit.  The first question could have easily answered by an

11     agreement.  The second question you put to the witness, at least the

12     answer he gave, he gave already earlier.  And on the third question we

13     now know that he didn't know anything about it.

14             Mr. Groome.

15             MR. GROOME:  No questions, Your Honour.

16             JUDGE ORIE:  No questions.  Which means...

17                           [Trial Chamber confers]

18             JUDGE ORIE:  This means that this concludes your evidence,

19     Mr. Milovanovic.  I'd like to thank you very much for not only coming

20     once but even coming a second time.  We'll not keep you here until the

21     20th of December.  Instead, we wish you a safe return home again.  You

22     may follow the usher.  There was a matter you said at the end you would

23     like to raise, if you can briefly do that, if there's still need.  You

24     said you wanted to ask something to the Defence, but first address me.

25             THE WITNESS: [Interpretation] I need to ask the Defence what to


Page 15576

 1     do with the materials that tormented me for three nights?  I would love

 2     to keep those materials because I'm working on a project and I could use

 3     them.

 4             JUDGE ORIE:  You'll receive instructions given by the Defence to

 5     the -- on a request of the Defence to the Victims and Witness Section

 6     what to do with that material.  I'm specifically addressing Mr. Jordash.

 7             Any confidentiality matter which may be involved?

 8             MR. JORDASH:  Yes.

 9             JUDGE ORIE:  You'll take care of that, I take it.

10             MR. JORDASH:  Yes.

11             JUDGE ORIE:  Then you'll receive further information about that,

12     Mr. Milovanovic.

13             Could you please follow the usher.

14             THE WITNESS: [Interpretation] Thank you.

15                           [The witness withdrew]

16             JUDGE ORIE:  Mr. Groome, I'm wondering whether there's any way to

17     either sit together or deal with the matter of scheduling of next week's

18     witnesses because we have received the Simatovic Defence e-mail of the

19     6th of December stating that Simatovic Defence witness DFS-001 will be

20     replaced by DFS-014.  Is there any way we can deal with that perhaps out

21     side of this setting because the interpreters, technicians, but me,

22     myself, as well we have other hearings this afternoon.

23             MR. GROOME:  Your Honour, I'll send an e-mail informing the

24     Chamber and Defence counsel my position and perhaps we can then formally

25     deal with it first thing Tuesday.

Page 15577

 1             JUDGE ORIE:  Yes.  Does that mean that you would oppose

 2     replacement because it has a, of course, a very ...

 3             MR. GROOME:  I can state my position in about 30 seconds,

 4     Your Honour.

 5             JUDGE ORIE:  30 seconds would be good.

 6             MR. GROOME:  The Prosecution is opposing -- does not oppose the

 7     rescheduling of the witness, does oppose the Prosecution be required to

 8     begin its cross-examination.  The witness testified in over nine days, in

 9     two cases, over 750 pages of transcript.  We don't have any of the

10     exhibits documents translated and the lawyer scheduled to do this

11     cross-examination leaves tomorrow on annual leave.  We don't oppose the

12     witness to come begin direct examination.  But we will be unable to begin

13     our cross-examination next week.

14             JUDGE ORIE:  That was 31 seconds, Mr. Groome, but nevertheless

15     very close to the target.  We will adjourn, and I'll apologise to all

16     those who are assisting us giving you perhaps far too heavy burden on

17     your shoulders, but we'll resume Tuesday, the 13th of December, 2011,

18     quarter past 2.00 in this same Courtroom II.

19                           --- Whereupon the hearing adjourned at 2.14 p.m.

20                           to be reconvened on Tuesday, the 13th day of

21                           December, 2011 at 2.15 p.m.