Tribunal Criminal Tribunal for the Former Yugoslavia

Page 10956

 1                           Friday, 28 May 2010

 2                           [Open session]

 3                           [The accused entered court]

 4                           --- Upon commencing at 9.08 a.m.

 5             THE REGISTRAR:  Good morning, Your Honours.  Good morning to

 6     everyone in and around the courtroom.  This is case IT-08-91-T, the

 7     Prosecutor versus Mico Stanisic and Stojan Zupljanin.

 8             JUDGE HALL:  Thank you, Madam Registrar.

 9             Before I ask for the appearances, I note for the record that we

10     reconvene this morning under Rule 15 bis, Judge Delvoie being absent.

11             Yes, may have I the appearances, please.

12             MR. OLMSTED:  Good morning, Your Honours.  Matthew Olmsted,

13     Joanna Korner, and Crispian Smith for the Prosecution.

14             MR. ZECEVIC:  Good morning, Your Honours.  Slobodan Zecevic,

15     Slobodan Cvijetic, Eugene O'Sullivan, and Ms. Tatjana Savic, appearing

16     for Stanisic Defence this morning.  Thank you.

17             MR. PANTELIC:  Good morning, Your Honours.  For Zupljanin

18     Defence, Igor Pantelic and Dragan Krgovic.  Thank you.

19             JUDGE HALL:  Thank you.

20             THE INTERPRETER:  Microphone for the Judge, please.

21                           [Trial Chamber and Legal Officer confer]

22             JUDGE HALL:  Before the witness is recalled to the stand, in

23     respect of the outstanding motion by the Prosecution as to whether the

24     witness Riedlmayer, who is scheduled to testify next week, would be

25     classified as an expert witness, we have decided that we will so treat

Page 10957

 1     him, and our written reasons will follow.

 2             MS. KORNER:  I'm very grateful.  Can we say, Mr. Hannis will be

 3     leading the witness, and I understand he is going to discuss with the

 4     Defence the parameters of the testimony.

 5             We will be limiting - can I make this absolutely clear - part of

 6     the -- the opinion evidence he can give to matters that we hope will be

 7     non-contentious.

 8             JUDGE HARHOFF:  You have two hours; is that correct?

 9             MS. KORNER:  I believe we asked for two hours, yes, that's right.

10             JUDGE HALL:  Thank you.

11             THE REGISTRAR:  Your Honour, if I may I have a correction to the

12     transcript with regards to the numbers assigned yesterday on page 10953.

13             The number -- the documents tendered by the Prosecution will be

14     assigned the exhibit numbers P1386 through P1392 because two of them are

15     already admitted into evidence.

16             JUDGE HALL:  Thank you.

17                           [The witness takes the stand]

18             JUDGE HALL:  Mr. Radulovic, good morning to you.  Before

19     Mr. Olmsted --

20             THE WITNESS: [Interpretation] Good morning.

21             JUDGE HALL:  Before Mr. Olmsted winds up his

22     examination-in-chief, I remind you you're still on your oath.

23             Yes, Mr. Olmsted.  You have one thing to do.

24             MR. OLMSTED:  Thank you, Your Honour.

25                           WITNESS:  PREDRAG RADULOVIC [Resumed]

Page 10958

 1                           [Witness answered through interpreter]

 2                           Examination by Mr. Olmsted: [Continued]

 3        Q.   Good morning, Mr. Radulovic.

 4        A.   Good morning.

 5        Q.   Do you recall attending the Security Day Parade in Banja Luka in

 6     May 1992?

 7        A.   Yes.  In the capacity of an operative.

 8        Q.   During your proofing, you had an opportunity to review a -- some

 9     video footage, and I want to show that to you now.

10             MR. OLMSTED:  We're going to bring it up on Sanction, and it's 65

11     ter 3596.

12                           [Video-clip played]

13             MR. OLMSTED:

14        Q.   We are about 3 minutes -- 34 minutes and 48 seconds into this

15     video.

16             Mr. Radulovic, we're looking at a number of armoured personnel

17     carriers and tanks that are painted blue.  Do you recognise these

18     vehicles?

19                           [Video-clip played]

20        A.   Well, can I recognise them.  As far as I know, the armaments, the

21     equipment, and the logistics were those of the JNA.  It was probably

22     given to the police, and we only painted those vehicles.  These vehicles

23     were not manufactured for the police.  They were taken from the arsenals

24     of the former JNA.

25        Q.   Did you see the Banja Luka special police detachment using

Page 10959

 1     vehicles such as these?

 2        A.   Yes.

 3        Q.   And where would you see them in use, in operation?

 4        A.   I'm not sure whether there were any other special units with such

 5     vehicles, but I did see such blue vehicles in the area of Prijedor and

 6     Kotor Varos.  One of these was even in Teslic during the operation when

 7     we confronted the Mice Group.

 8             MR. OLMSTED:  Let's fast-forward to 49 minutes.

 9                           [Video-clip played]

10             MR. OLMSTED:

11        Q.   Mr. Radulovic, we're looking at three men in uniform about to

12     give a review of a number of police officers.  And I want to see if you

13     can recognise, identify the three men.  We'll pause it at a point here.

14                           [Video-clip played]

15             MR. OLMSTED:

16        Q.   Tell us if you recognise any of them.

17        A.   As far as I can tell, there's Stojan Zupljanin.  There's the late

18     Stevan Markovic.  I cannot be certain, but I think there's also Mr. Mico

19     Stanisic, the one in military uniform.

20        Q.   Thank you.  Let's move ahead to -- by the way, do you know where

21     this review is taking place?  Could you tell us where it is?

22        A.   The location is easily recognizable to anyone who was in

23     Banja Luka.  This is the square in front of the Boska department store.

24     Even today most mass rallies take place there.  Yeah, that's it.

25             MR. OLMSTED:  Let's move ahead to 52 minutes and 10 seconds.

Page 10960

 1                           [Video-clip played]

 2             MR. OLMSTED:

 3        Q.   Mr. Radulovic, can you identify who is coming out of the door

 4     here?

 5        A.   I apologise for what I'm about to say, because -- this is a kind

 6     of a funny question because everybody would recognise Mr. Radovan

 7     Karadzic and there's also Krajisnik.  But I understand that you need

 8     confirmation.

 9             In the background, I can see an employee of the former SJB.  He

10     was later director of a power station and -- but he died in the meantime

11     from a tumour.

12        Q.   We just saw a man with greyish hair and a pointy beard.  Who was

13     that?

14        A.   I apologise, but I recognise Predrag Radic.  He is turned towards

15     the camera.

16        Q.   And the man in the suit with the -- with the beard?

17        A.   Oh, him.  Yes.  It's clearer to me now.  This is Dr. Vukic.

18             MR. OLMSTED:  Let's play a little further.

19                           [Video-clip played]

20        Q.   Who else do you recognise in this lineup?

21        A.   And there's Predrag Radic next to him.

22             MR. OLMSTED:  Keep on playing.

23                           [Video-clip played]

24             MR. OLMSTED:  Let's fast-forward to 55:05 -- 55 minutes and 5

25     seconds.

Page 10961

 1                           [Video-clip played]

 2        Q.   Do you recognise the man at the far end in the camouflage?  Is

 3     that someone you can identify?

 4             MR. OLMSTED:  Maybe back a little.

 5        A.   I think that this is Mr. Mico Stanisic.  Well, I can see him here

 6     in the courtroom too.  I'm not sure that's him, because it's been a long

 7     time.  But as far as can I tell, this is Mico Stanisic.

 8             MR. OLMSTED:  Let's go to 55 minutes and 33 seconds.

 9                           [Video-clip played]

10        A.   So Mico Stanisic is the first and then Predrag Radic, then Vukic,

11     Karadzic, and Krajisnik.  These are all the people we can see in this

12     still image.

13        Q.   Thank you.  Who's -- who's that next to Mr. Stanisic, to the

14     right of him?

15        A.   This is Milan Martic.

16             MR. OLMSTED:  Okay.  Let's go to 55 minutes and 44 seconds, and

17     we're going to --

18                           [Prosecution counsel confer]

19             MR. OLMSTED:

20        Q.   Do you recognise the man to the right of Mr. Martic?

21        A.   No.  I remember seeing him, but I don't know his name.

22        Q.   And who is the man, you can see him in the second row, you just

23     see his head.  He's between Mr. Martic and Mr. Stanisic?

24        A.   This is Nedeljko Kesic, the chief of the National Security

25     Service in Banja Luka.

Page 10962

 1             MR. OLMSTED:  Let's go to 55 minutes and 44 seconds.  And we're

 2     just going to play the speech of Mr. Stanisic.  It's quite short.

 3                           [Video-clip played]

 4             MR. OLMSTED:  Let's stop it and restart it.  If the interpreters

 5     could translate it.

 6                           [Video-clip played]

 7             "[VOICEOVER]:  On St. George's Day many Serb families were rooted

 8     out in the area of Srebrenica.  The Muslims say many were breaking in

 9     houses, killing hosts together with their guests and burning down houses.

10     The situations were not rare when Serbs were used as human shields or

11     they deployed them in strategic spots for which they believed that could

12     be the target of our attacks.  There are equally numerous examples, you

13     are all aware of them on your own territories, so there's no need to

14     quote them further.  The service gathered intelligence that they are

15     trying to establish some private ... on the particular territories of the

16     Serb republic of Bosnia-Herzegovina which are targeting the Serbian

17     people and everyone living in the territory of the Serb republic of

18     Bosnia-Herzegovina.  With the arrival of freedom what expects us,

19     although we can say that outside the appearance of the situation in the

20     territory of the Serb republic of Bosnia-Herzegovina is satisfactory, we

21     have to take into conversation that the service gathered numerous facts

22     that are indicating ...

23             MR. OLMSTED:  Okay.  And now we are at 56 minutes and 57 seconds,

24     and we're not going to have this speech interpreted, but could you tell

25     us, Mr. Radulovic, who is speaking.

Page 10963

 1                           [Video-clip played]

 2             MR. OLMSTED:

 3        Q.   And just could you repeat who is the speaker.  I don't know if

 4     the record picked it up.

 5        A.   Now I can see Mr. Stojan Zupljanin.

 6        Q.   And just, very quickly, if we can go to 1 minute -- or 1 hour, 6

 7     minutes, and 5 seconds.

 8                           [Video-clip played]

 9             MR. OLMSTED:

10        Q.   And, of course, who is now giving a speech?

11        A.   Here in this still image I can see Radovan Karadzic.

12             MR. OLMSTED:  Let's go to 1 minute -- or 1 hour, 14 minutes and

13     32 seconds.

14                           [Video-clip played]

15             MR. OLMSTED:  Now what we see in front of us appears to be a

16     meeting and on the -- what is displayed on this footage is the date, 30

17     July 1992.

18             Can we skip ahead to 1 hour 5 minutes and 11 seconds?

19        Q.   And perhaps you can identify, Mr. Radulovic, who is heading this

20     meeting?

21        A.   I can see Stojan Zupljanin and Djuro Bulic, if you mean the

22     people sitting at that table, chairing the meeting.

23             MR. OLMSTED:

24        Q.   Where is this meeting taking place?

25        A.   I cannot say with certainty.  I can suppose that it -- this is in

Page 10964

 1     the CSB building of Banja Luka because I see green tablecloths that we

 2     used to use in our building in this hall on the fourth floor, or maybe on

 3     the third.  I'm not sure which floor it was.

 4        Q.   Can you tell us, do you know who is speaking right now?  If you

 5     don't know, that's fine.

 6        A.   I can't see anybody speaking; that's the problem.

 7        Q.   [Previous translation continues] ... it's --

 8        A.   Yeah, I see now.  I know him from sight, but I really don't know

 9     the man's name.

10        Q.   Do you remember what municipality he is from?

11        A.   But I can see next to him Vladimir Tutus.

12        Q.   Now during your proofing --

13        A.   You asked me about the municipality.  I'm sorry, sir.  You asked

14     me if I could identify the municipality from which he was, and as far as

15     I remember, he was from Sanski Most.

16        Q.   Now, Mr. Radulovic, during your proofing you had an opportunity

17     to review the -- I don't think the whole meeting but quite a bit of it

18     and it goes for quite a length.  But, generally, who are the participants

19     at this meeting?

20        A.   Let me first say that I didn't have a position in the service by

21     virtue of which I would attend such meetings.  But I was able to

22     recognise most of the people, and, thus, I can draw the conclusions that

23     they were the chiefs of the police stations from the Banja Luka region.

24        Q.   Were any -- when you review this footage, did you see any of your

25     superiors in state security?

Page 10965

 1        A.   Yes, I can see them now in the background.  There's Vojin Bera.

 2     He's sitting next to the Prijedor chief, Vladan Vesic.

 3        Q.   The Prijedor SJB chief, is that who you said?

 4        A.   No, no, no, Vladan Vesic.  It's actually Gradiska, I misspoke.

 5     It's Gradiska.  Mr.  Vladan Vesic was the chief from Gradiska, and I can

 6     see him sitting next to Bera, Vojin Bera.

 7             JUDGE HARHOFF:  What colour of the shirt is he wearing, Mr. Bera?

 8             THE WITNESS: [Interpretation] Is he wearing a white shirt.  We

 9     can see him in profile.  And he's wearing glasses, as far as can I see.

10     So he's the chief of the police station in Gradiska.  His naming is

11     Vladan Vesic.

12             In front of him, half his face is covered but can I recognise him

13     anyway, also dressed in a white shirt, there's Vojin Bera.

14             MR. OLMSTED:  And just for the record that's at 1 hour, 16

15     minutes and 46 seconds.

16             Can we move ahead to 1 hour, 24 minutes and 30 seconds -- or I --

17     yeah, exactly.

18                           [Video-clip played]

19        Q.   Who is standing up right now, right in the front, right there?

20        A.   As far as I can tell, this is the head of Nedeljko Kesic.  And on

21     the right, I see a man whose name I think was about Brane Bukovac.  He

22     was head of the criminal investigations department.

23             Behind him there's the chief of fire security at the CSB in

24     Banja Luka.  Next to him there's Skundric, I believe.  Vaso was his first

25     name.  He had a position in the police inspectorate.  And on the left I

Page 10966

 1     just said that this man recently died, died of a tumour.  He was in the

 2     service, and later on, he was the manager of a power plant in Banja Luka.

 3             And behind him, I can't really recognise who these other people

 4     are.

 5        Q.   That's fine.  Let's go ahead to 1 hour, 26 minutes, and 12

 6     seconds.

 7                           [Video-clip played]

 8             MR. OLMSTED:  Pause.

 9        Q.   We see a man who's got his back to us wearing camouflage and his

10     head is slightly profiled.  Who is that?

11        A.   Well, the one whose face is turned toward us is the chief from

12     Jajce.  And the one we see from the back is Simo Drljaca.

13             MR. OLMSTED:  May this exhibit be tendered into evidence.  We

14     have the transcripts from the other speeches as well as the transcripts

15     from the speeches made at this meeting as well.  Of course, we're not

16     going to play those at this time.

17             JUDGE HALL:  Admitted and marked.

18             THE REGISTRAR:  As Exhibit P1393, Your Honours.

19             MR. OLMSTED:  No further questions.

20                           [Prosecution counsel confer]

21             MR. OLMSTED:  Just to clarify, both the video and the transcripts

22     are -- are admitted?  Yeah.

23             JUDGE HALL:  That's what I thought [Microphone not activated].

24                           [Trial Chamber confers]

25             JUDGE HALL:  Cross-examination.

Page 10967

 1             MR. ZECEVIC:  Thank you, Your Honours.

 2                           Cross-examination by Mr. Zecevic:

 3        Q.   [Interpretation] Good morning, Mr. Radulovic.

 4        A.   Good morning.

 5        Q.   Mr. Radulovic, you're a member -- or you have been a member of

 6     the Ministry of the Interior since 1976.

 7        A.   Since November 1976.

 8             JUDGE HALL:  Just a moment, please.  Mr. Radulovic, especially

 9     with cross-examination by counsel who speak the same language as you, it

10     is necessary to allow a pause between question and answer so the

11     interpreters can keep up and we have an accurate record.

12             Thank you, Mr. Zecevic.

13             MR. ZECEVIC:  Thank you, Your Honours.

14             THE WITNESS: [Interpretation] Thank you.  I'll do my best.

15             MR. ZECEVIC: [Interpretation]

16        Q.   If I'm not mistake you worked for the intermunicipal SUP of

17     Doboj, which is approximately like the CSB nowadays, right?

18        A.   Yes, correct.

19        Q.   Just make a pause between my question and your answer, please.

20        A.   Yes.  Thank you.

21        Q.   You worked in public security until 1981, right?

22        A.   Correct.

23        Q.   In 1981, you went from public security to state security, also at

24     the intermunicipal SUP of Doboj; correct?

25        A.   That's partly correct.  Because the State Security Service was

Page 10968

 1     not organised to be under the authority of the intermunicipal SUP.

 2     Instead, it was directly linked to the level of the republic, or directly

 3     below the level of the republic.

 4        Q.   So, as opposed to the public security, it had direct links with

 5     the republican level; correct?

 6        A.   Correct.

 7        Q.   Since 1983, I believe, you have dealt specifically with matters

 8     concerning sects, NGOs, and the like?

 9        A.   Correct.

10        Q.   Owing to your knowledge of these matters, you established

11     contacts with the federal State Security Service, the military security,

12     and the state security of Serbia; correct?

13        A.   Correct.  But also contacts with representatives of the services

14     in other republics of the then Socialist Federal Republic of Yugoslavia.

15        Q.   In 1987 you were transferred from Doboj to Banja Luka; is that

16     correct?

17        A.   Yes, that's correct.

18        Q.   Upon your arrival in Banja Luka, you remained inspector of the

19     SDB; is that correct?

20        A.   Yes.

21        Q.   Between 1987 and your transfer to Banja Luka, what matters were

22     the main focus of your work?

23        A.   Intelligence matters.

24        Q.   That -- these are the matters that are mainly dealt by the 01

25     administration of the security service, the intelligence matters; is that

Page 10969

 1     correct?

 2        A.   Yes, that's correct.

 3        Q.   Could you please tell me after the multi-party elections in 1990,

 4     certain changes, or re-shuffling of positions which followed the pattern

 5     of relations between different parties, and that happened within the SDB

 6     as well; isn't that correct?

 7        A.   Yes, that's correct.

 8        Q.   My question related practically to the entire organisation of the

 9     state, in all segments of society, including the Ministry of the

10     Interior, this re-shuffling occurred.

11        A.   As far as I know, not one single segment remained without certain

12     type of changes occurring based on this principle that you put forward;

13     namely, the national principle.

14        Q.   You told us that you're a Communist by your beliefs, and you did

15     not agree with these ethnic or national parties and their programmes, not

16     even on the idealogical level; is that correct?

17        A.   Yes, absolutely correct.  These are my views still today.  I'm

18     still a Communist.

19        Q.   There's no point in asking you whether you were a member of any

20     of the national parties.

21        A.   I was always member of the League of Communists, and at the

22     moment, I'm the president of the association of Communists in

23     Bosnia-Herzegovina, and I'm proud to say that.

24        Q.   In accordance to this coalition agreement between the parties

25     that won the elections in Bosnia-Herzegovina in 1990, appointments to

Page 10970

 1     leading positions in the MUP were, according to the law, done by the

 2     minister of the interior, Alija Delimustafic.  Is this correct?

 3        A.   Yes, that's correct.  I know about this only in general terms.

 4        Q.   It is a fact, isn't it, that, according to a decision by the

 5     minister at the time, Mr. Delimustafic, CSB Banja Luka chief, then

 6     security service chief, Nedeljko Kesic and your boss, Vojin Bera, were

 7     also appointed?

 8        A.   Yes, it should have been like that.

 9        Q.   Do you know that back in 1991, they were appointed to these

10     positions by the MUP of the Socialist Republic of Bosnia-Herzegovina?

11        A.   Yes, I'm aware of that.  That's how the procedure looked like.

12        Q.   Could you please tell me, it is a fact, isn't it, that Ljuban

13     Ecim and Zdravko Samardzija were also members of MUP back in 1991, maybe

14     even before that?

15        A.   Before that.  If you want specifically, Ecim joined public

16     security service in 1987 or 1988 or maybe even earlier, whereas,

17     Samardzija joined during the 1980s.

18        Q.   So both of them signed the contract or became part of MUP at the

19     time while it was still MUP of Bosnia and Herzegovina, Socialist Republic

20     of Bosnia-Herzegovina?

21        A.   Yes, that's correct.

22        Q.   Thank you.  Mr. Radulovic, this Milos [Realtime transcript read

23     in error "Mice"] Group, if I understood it well, it was operative

24     intelligence group; is that correct?

25        A.   Yes.

Page 10971

 1        Q.   And if I remember your testimony, this group was established on

 2     the 28th of July, 1991.  You told us that specific date.

 3        A.   Yes, that's correct.

 4        Q.   I think during the first day of your testimony you confirmed that

 5     this operative intelligence group was established in co-operation with

 6     the SDB of Serbia, and I think that, on Tuesday, in your testimony, you

 7     stressed, although it may have not been recorded in the record, that it

 8     was in direct contact with State Security Service and not with the public

 9     security service or MUP of Serbia.  Is that correct?

10        A.   Absolutely correct.

11        Q.   That was done because, I assume, there was a need to ensure

12     secrecy of your work and the matter of your contacts with Serbian

13     security service.

14        A.   Yes, that's correct.  However, that was not the only reason.

15             MR. O'SULLIVAN:  Excuse me, Your Honour, there may be a matter

16     that is not properly recorded, and Mr. Zecevic might want to clarify it.

17             I'm looking at page 15, line 20, the question is:  Thank you,

18     Mr. Radulovic.  This Mice Group.  I'm not sure Mr. Zecevic said

19     Mice Group.

20             MR. ZECEVIC:  Thank you very much, Mr. O'Sullivan.

21        Q.   [Interpretation] Yes.  Here on page 15, line 20, it is stated

22     Mice Group, and we were talking about the Milos Group.

23        A.   Yes, the Milos Group.  I would like to ask for that to be

24     immediately corrected.

25        Q.   It is already.

Page 10972

 1        A.   Yes, I can see.

 2        Q.   Sir, it is a fact, isn't, it, and I'm saying this for the purpose

 3     of showing you the context, on the 20th of July, 1991, the Republic of

 4     Slovenia and the Republic of Croatia already seceded from the Socialist

 5     Federative Republic of Yugoslavia.  Isn't that correct?

 6        A.   Yes.

 7        Q.   I assumed that may have been one of the reasons why your

 8     operative intelligence group was not linked up with the federal State

 9     Security Service but instead with the Serbian one because the federal

10     State Security Service, after the cessation of the two republics, broke

11     up along the ethnic lines.  Am I correct?

12        A.   Yes, that's correct.

13        Q.   Let us try and illustrate the situation in late 1991 and early

14     1992 on the basis of your reports.

15             I would first like to ask you to comment on the document, P1353,

16     item 25.  It is a document that was shown to one of the witnesses before

17     your turn, and we tried to help the Trial Chamber to clarify the

18     situation.  Madam Korner opposed this at the time, saying that the author

19     of the document would come as a witness, and that you would be a better

20     person to clarify the situation.  Since she didn't do it, I will do it

21     now.

22             Sir, this document is dated 13th of April, 1992.  The -- it says

23     Milos in the signature.  Do you remember the document?

24        A.   Yes, of course, I remember it excellent.

25        Q.   Could you please explain in brief what the problem was and what

Page 10973

 1     was the reason for this memo.

 2        A.   This -- this is a department store that could provide weapons to

 3     people who had proper documents, and I'm talking about personal weapons

 4     and hunting rifles.  And among those who made payments were people of

 5     various ethnic groups.  As far as I can remember, most of them were even

 6     Bosniaks.

 7             Since I knew the general manager of this department store, and

 8     bearing in mind that the payments were already made, it wasn't, of

 9     course, important how we knew each other, what I did was I asked Belgrade

10     to deliver the weapons to the department store Merkur by the Promet

11     Zastava company in order to avoid already existing problems, problems

12     existing because the weapons were already paid for but were not

13     delivered.  I personally -- or, rather, the Milos Group was escorting and

14     providing security for the weapons that were brought from Belgrade to

15     Teslic.

16        Q.   It is a fact that Zastava Promet was one of the biggest

17     organisations related to the manufacturer of personal weapons.  Zastava

18     Kragujevac, which according to regulation, was authorised to trade and

19     sell hunting weapons and personal weapons, small-arms.  Is that correct?

20        A.   Yes, yes, that's correct.

21        Q.   In any case, during normal conditions in the country, in the

22     Socialist Federative Republic of Yugoslavia, transport of weapons of such

23     sort would involve some security issues; namely, there would be a

24     security escort with delivery, with the supply?

25        A.   Yes.  Mainly if larger amounts were being transported.

Page 10974

 1             MR. ZECEVIC: [Interpretation] Can we please have 1D00-2804 on the

 2     screen, tab 55.  Page 4, please.  First, first page and then fourth page.

 3     Because I would like to ask the witness to verify that he's the author of

 4     the document.

 5        Q.   Sir, this is a report.  You will see the last page.  There it is

 6     stated that the date was the 4th of June, 1992, signed by Milos.

 7             MR. ZECEVIC: [Interpretation]  Could we please have page 4 of the

 8     document in the Serbian version.

 9        Q.   Can you see it?

10        A.   Yes, can I see it.  I recognise it.

11        Q.   Is it -- is the document yours?

12        A.   Yes.  I can recognise the document as a Milos document.  But

13     evenly without Milos, I could recognise it based on the typeset of the

14     typewriter.  It's a very specific one.

15        Q.   Thank you.

16             MR. ZECEVIC: [Interpretation]  Could we now have, again, the

17     first page of the document, please.

18        Q.   In this report of yours, you report that current information

19     point out to certain facts that may have not been familiar to -- at

20     certain period of time.  You said on 10th of June, 1991 SDA held in the

21     police building in Sarajevo the -- held a meeting discussing strategy of

22     formation of independent Bosnia and Herzegovina, formed national security

23     council and started preparations for an armed conflict.

24             Is that correct?

25        A.   Yes.  However, Mr. Zecevic, these were not my first information

Page 10975

 1     about arming and paramilitary organisation of the SDA party.  I provided

 2     first information about that in 1989, when I received first information

 3     that certain armed formations were established in the area of Sasine.

 4     You must understand that this contains only information I had in relation

 5     to 1992.  This does not refer to intelligence starting in 1989.  At the

 6     time, I -- correction, 1987, when I reported about same thing in the area

 7     of Republic of Croatia.  And that's when I started reporting about it,

 8     because I realized there's a threat to my country, Socialist Federative

 9     Republic of Yugoslavia, that coming up.

10        Q.   Unfortunately, I don't have these reports of yours.  What we have

11     disclosed is only your reports signed by Milos and those reports related

12     to 1992, and this is what I'm showing to you.

13             But in any case, the report submitted by you was --

14             MR. OLMSTED:  Sorry to interrupt.  But I just want to clarify,

15     the Prosecution has disclosed everything in our possession with regard

16     to -- to the Milos reports.  It doesn't matter whether they came from

17     1988 or 2001.  I know that's an extended period, but we have disclosed

18     everything that we have.

19             MR. ZECEVIC:  It wasn't -- it wasn't meant as a criticism of OTP.

20     I was just explaining to the witness why am I show to go him the Milos

21     report.  And the Milos reports are only between 28th of July, 1991 and

22     1994, as -- as I understood the testimony of this witness.

23             So it wasn't meant as a criticism.

24             MS. KORNER: [Microphone not activated]

25             MR. ZECEVIC: [Interpretation]

Page 10976

 1        Q.   Sir, let us go back to my question.

 2             This report that is in front of you, the one that you sent, do

 3     you doubt the veracity of facts listed there?  Do you have any doubts

 4     concerning that?  Was the information about that meeting held on the 10th

 5     of June, 1991, verified when the Council for National Security of the SDA

 6     was established?

 7        A.   Yes, absolutely verified.  This information was verified.

 8             MR. ZECEVIC: [Interpretation]  Could this document be admitted

 9     into evidence, unless there's objections by the OTP.

10             JUDGE HALL:  Admitted and marked.

11             THE REGISTRAR:  As Exhibit 1D278, Your Honours.

12             MR. ZECEVIC: [Interpretation]

13        Q.   The next document is 1D03-3437, tab 92.

14             MR. ZECEVIC: [Interpretation]  Unfortunately, the CLSS has

15     informed us that due to a large volume of documents, they are unable to

16     translate this in time for today's session, but I assume that it will be

17     translated by next week.

18             MR. OLMSTED:  Your Honours, I have to object to these documents

19     that are on the list of Defence that have not been translated.

20             These documents versus been available to the Defence, I believe,

21     for about a year now.  They're not very long these Milos reports, as

22     we've seen, and it is very difficult for me to follow along when I can

23     only see a B/C/S version.

24             Perhaps my learned friend could delay showing this witness this

25     document until Monday if that -- maybe that perhaps is a solution,

Page 10977

 1     otherwise it is really difficult for myself and I assume the

 2     Trial Chamber as well to follow along.  And I think that these reports

 3     were in their possession long enough that they could have this had them

 4     translated.

 5             JUDGE HALL:  Mr. Zecevic, what practical course would you

 6     suggest?  Do you accept Mr. Olmsted's suggestion as being the way we

 7     should solve this problem?

 8             MR. ZECEVIC:  Well, Your Honours, I have to first comment on

 9     this.

10             The Defence -- it is the truth that the Defence has in possession

11     these documents for one year and a half.

12             JUDGE HALL:  You notice I was trying to avoid asking you to

13     respond to that, I don't want to get into who is responsible for what.

14     I'm looking at a practical -- the -- the handicap, which Mr. Olmsted has

15     identified, is perfectly understandable.  As he said, the Trial Chamber

16     is in the same position.  So I'm trying to find a -- [Overlapping

17     speakers] ...

18             MR. ZECEVIC:  [Overlapping speakers] ... well, Your Honours, I

19     suggest the following course.

20             I would ask the witness to confirm this document, the

21     authenticity of this document.  And I will only ask that it be admitted,

22     as Mr. Olmsted did yesterday, on a list of documents once the -- the --

23     the translations are -- are -- are available.

24                           [Trial Chamber confers]

25             MR. ZECEVIC:  Yes, I assume that that might create a problem for

Page 10978

 1     Mr. Olmsted for re-direct if we still don't have the -- the document.

 2             JUDGE HALL:  So since it isn't it English, we would admit them on

 3     the list as you suggested but marked for identification.

 4             MR. ZECEVIC:  Yes, that is correct, yes.

 5                           [Prosecution counsel confer]

 6             MR. ZECEVIC:  I -- it's up to Mr. Olmsted, if he has any --

 7             JUDGE HALL:  Sorry, how many documents are we talking about?

 8             MR. ZECEVIC:  Well, I believe, Your Honours, we are missing

 9     translations of maybe seven or eight documents, not more than that.  We

10     received a number of maybe 25 in last two, three days, but these seven,

11     eight are missing.  They might be even available today, but I cannot

12     guarantee because the CLSS complained that the deadlines were pretty

13     short for them.

14             JUDGE HALL:  And you're satisfied that all seven of these are

15     relevant, and you would wish to have all seven of them treated in the way

16     that we've described.

17             MR. ZECEVIC:  That is correct, Your Honours.

18             MR. OLMSTED:  Your Honours, that's fine with the Prosecution so

19     long as we have a chance to look at them and determine whether they're

20     actually relevant to this case and make any objections before they're

21     admitted.  Otherwise we don't mind them being marked for identification

22     at this stage at least.

23             JUDGE HALL:  Okay.  So that is the course that we will proceed --

24     that we will -- that is the course that we would adopt.  I'm sorry.

25             MR. ZECEVIC:  Thank you very much.  I appreciate Your Honours'

Page 10979

 1     indulgence.

 2        Q.   [Interpretation] Sir, this document is dated the 1st of March,

 3     1992.  This is a report by the Milos Group?

 4        A.   Yes.

 5        Q.   Do you recognise this document?

 6        A.   I certainly do.

 7        Q.   In this document, you give an overview of the situation.

 8        A.   Yes, a brief overview.  A cross-section of the situation which,

 9     unfortunately, had terrible consequences in the village of Sijekovac near

10     Bosanski Brod when a large number of Serbs were killed in a horrendous

11     manner.

12             JUDGE HALL:  [Previous translation continues] ...

13             MR. OLMSTED:  I think this was my original objection is that we

14     don't want the Defence to lead evidence on a document we don't have

15     translated and that they can mark it for identification for now but not

16     lead evidence until we see the English translation.  Without the English

17     translation, there is no way we can determine whether he is accurately

18     reflecting what's in the document, whether there's anything in there that

19     is contrary to what is being asserted.  It just makes it very impossible

20     for us given the length of these document have been in their possession

21     and their shortness, I think it's fair to the Prosecution that he

22     certainly can mark them for identification now and come back to them on

23     Monday.

24             MR. ZECEVIC:  I appreciate --  I appreciate what Mr. Olmsted

25     said, except that I would assume that the Prosecution would be diligent

Page 10980

 1     enough to -- to translate all these documents because they had it in

 2     their possession for at least seven or eight years.  But I will -- I

 3     will -- understanding the position of Mr. Olmsted, I will not ask the

 4     questions on -- on these documents.

 5        Q.   [Interpretation] Sir, please tell me, you were telling us about

 6     that tragic incident in the village of Sijekovac.  It is a fact, isn't

 7     it, that in early 1992, the Republic of Croatia wanted to transfer the

 8     conflicts from its territory into the territory of Bosnia-Herzegovina at

 9     any cost.

10        A.   Mr. Zecevic, with all due respect to you as a lawyer, you are now

11     asking me to give my opinion.

12             My opinion at this point in time is irrelevant.  What is relevant

13     is what I stated back in 1992, and that's precisely what I put back then,

14     that there was a desire to transfer the problem from the territory of

15     Croatia into the territory of Bosnia and Herzegovina.

16        Q.   Thank you.

17             MR. ZECEVIC: [Interpretation]  I ask that this document be marked

18     for identification.

19             JUDGE HALL:  Yes, so marked.

20             THE REGISTRAR:  As Exhibit D1D279, marked for identification,

21     Your Honours.

22             MR. ZECEVIC: [Interpretation] 65 ter 10185.  Could this please be

23     shown to the witness.

24        Q.   Sir, before we comment on this document, let me ask you

25     something.  You are familiar with the genesis of the problem in Bosnia

Page 10981

 1     and Herzegovina, so I would rather not spend much time on it.  Will you

 2     agree with me that in October 1991, a declaration was adopted at the

 3     Assembly, a declaration on independence and that it was done in a manner

 4     that represented a violation of the constitution?

 5        A.   Yes.

 6        Q.   And then again in -- soon thereafter, Presidency and the

 7     government of the Socialist Republic of Bosnia and Herzegovina asked the

 8     European Union to recognise the independence of Bosnia and Herzegovina.

 9             Would you please repeat your answer.

10        A.   Yes.

11        Q.   You must know that, in late 1991, and in early 1992, European

12     Union, wishing to resolve -- or, rather, to bring about a peaceful

13     resolution of the situation in Bosnia and Herzegovina established a

14     commission and started negotiations, which were popularly known -- a

15     commission and a plan, which were popularly known as the Cutileiro Plan,

16     after the then minister of foreign affairs of Portugal who was in charge

17     of those negotiations on behalf of the European Union?

18        A.   Yes.  I'm familiar with the plan and with the negotiations, and I

19     remember well how it all ended.

20        Q.   The essence of the plan was that Bosnia and Herzegovina was to be

21     split in three entities, with central organs of power which would remain

22     in Sarajevo for all three entities, and then each entity individually,

23     which were established on the basis of an ethnic principle, would have a

24     large degree of autonomy, even when it comes to police affairs.

25             Are you familiar with that?

Page 10982

 1        A.   Thank you for reminding me, but I am quite familiar with that.

 2     And I also know who did not accept it.  I'm just sparing you trouble if

 3     you wanted to clarify that.  I don't want you to waste time on it,

 4     because I'm quite familiar with all of the events leading up to the

 5     breakout of the conflict.

 6        Q.   It is a fact, isn't it, that representatives of all three

 7     national political parties accepted that agreement, then after some time

 8     had passed in late March, Mr. Izetbegovic withdrew his signature from

 9     that document.

10             Are you familiar with that?

11        A.   Yes.

12        Q.   Sir, your report dated 6 March 1992 speaks of the fact that there

13     is discontent among the employees of the public and state security, who

14     were of Croat and Muslim background, due to their lack of agreement to

15     work in a service that would have a --

16             THE INTERPRETER:  Could the counsel please repeat the question.

17             MR. ZECEVIC: [Interpretation] I apologise.  I apologise to the

18     interpreters.

19        Q.   So this report of yours speaks about the discontent among the

20     employees of MUP, those who worked for public security and state

21     security, and who were Croats and Muslims, because, according to your

22     information, they did not want to work for a service which would have a

23     larger degree of autonomy than the MUP of Bosnia-Herzegovina?

24        A.   Yes, correct.

25             MR. ZECEVIC: [Interpretation]  On page 27, line 14, it shouldn't

Page 10983

 1     be "than" it should be "from;" that they would have a larger degree of

 2     autonomy from MUP of Bosnia and Herzegovina.

 3        Q.   Is that what you had in mind?

 4        A.   Yes.

 5        Q.   Sir, it is a fact that back on the 6th of March, 1992, there was

 6     some discussion about how the MUP of the Socialist Republic of Bosnia and

 7     Herzegovina would split into three MUPs for each -- for each entity in

 8     accordance with this EU plan?

 9        A.   Yes.  And you have to understand that the employees of the

10     National Security Service were informed about this much better on average

11     than your regular citizen or your regular employee of the public security

12     service.

13        Q.   Thank you.

14             MR. ZECEVIC: [Interpretation]  If there are no objections, could

15     this be admitted into evidence, please.

16             JUDGE HALL:  Admitted and marked.

17             THE REGISTRAR:  As Exhibit 1D280, Your Honours.

18             MR. ZECEVIC: [Interpretation]

19        Q.   Sir, it is a fact, isn't it, that, at that time, the MUP of the

20     Socialist Republic of Bosnia and Herzegovina didn't function in a regular

21     way -- or, rather, there were some divisions along ethnic lines, right?

22        A.   Mr. Zecevic, I was there.  I walked the ground.  I was out on the

23     field.  And the situation was that of great confusion.  So, in March and

24     in April, already an employee of the public security could not freely

25     move in the territory of Gracanica, let alone Maglaj, Tesanj.  There were

Page 10984

 1     always barricades erected there already.  Everything was coloured there

 2     along ethnic lines and affiliations.  In the statement and in my evidence

 3     yesterday, I stated quite clearly, and can I repeat it now, that I gave

 4     only one, 67 --

 5             THE INTERPRETER:  Could the witness please repeat his answer.

 6             JUDGE HALL:  Sorry, the interpreter needs -- Mr. Radulovic, the

 7     interpreter requires you to repeat a portion of your answer.

 8             MR. ZECEVIC:  If I may be of assistance, because I understood,

 9     maybe I could lead the witness.

10        Q.   [Interpretation] Sir, would you please correct me:  You're trying

11     to say that back while giving evidence over the last few day, you said

12     that only one-third of your report, of your documents and information is

13     here in this case, was presented in this case which is 33 per cent;

14     whereas, 67 per cent of your work product is not represented in the

15     documents here, and that pertains to what members of other ethnic groups

16     did in the territory of Bosnia and Herzegovina in late 1991 and early

17     1992.  It also pertains to how they were organised and armed.

18        A.   Yes, correct.  You just said late 1991 and early 1992, but my

19     data goes back to 1987, and we should not overlook these three years.

20        Q.   I really don't want to underestimate it, but I explained to you,

21     that, unfortunately, we don't have these documents.

22             Tell me, sir, the State Security Service at the time, and I'm

23     referring to late 1991 and early 1992, was headed by Mr. Branko Kvesic;

24     correct?

25        A.   You mean at the level of the Republic of Bosnia-Herzegovina, yes.

Page 10985

 1     As far as I remember, yes, he did.  He was relatively briefly in that

 2     position.

 3        Q.   You as a long-standing member of state security certainly will

 4     know that the SDB, figuratively speaking, was -- had as many holes as a

 5     sieve, and confidential information would be given to the media, ethnic

 6     parties, individuals and without authorisation; correct?

 7        A.   Yes, absolutely correct.  And if I may add, the SDB was divided

 8     along ethnic lines.  The SDB members who were Bosniaks worked in the

 9     interest of the SDA; Croats, in the interest of the HDZ; and some of the

10     Serbs worked for the SDS.  But there were still shows who believed in the

11     Socialist Federal Republic of Yugoslavia and didn't signed with any of --

12     didn't side with any of these counts.

13        Q.   It's a fact, isn't it, that at the headquarters of the SDB in

14     Sarajevo, in administration 01, to which you belonged, that there were

15     only Muslims there as staff, right?

16        A.   Yes.  This transformation was observed in 1990, and there was no

17     one Serb left in the intelligence administration, which was a clear

18     indication of something.  And whoever knew the intelligence culture could

19     draw his conclusions that something was happening.

20        Q.   There's still some time, so tell me about this document that we

21     see here.  On the 7th of March, you speak about the MUP leadership

22     decided to have 100 employees retired, mostly Serbs, and hire 250 Muslims

23     and Croats.

24        A.   I can't see that document on my screen.  But I remember the

25     contents.  You have reminded me.

Page 10986

 1        Q.   I apologise.  I asked for document 1D03-3349 to be displayed.

 2             The document is dated 7 March 1992.

 3             MR. OLMSTED:  I'm sorry, which tab was that?

 4             MR. ZECEVIC:  Tab 4.

 5             JUDGE HALL:  Perhaps we should pick this up after the break.

 6             MR. ZECEVIC:  Yes, Your Honours.

 7                           [The witness stands down]

 8                           --- Recess taken at 10.25 a.m.

 9                           --- On resuming at 10.58 a.m.

10             MR. ZECEVIC:  Your Honours, a couple of things.

11             First, I would like to express my apology to the interpreters,

12     that's one thing, and I promise that I will make sure that I control

13     myself and control the witness as much as I can.  That's one thing.

14             The second thing, we have received some translations in the

15     course of -- of the trial and it's been uploaded at the moment.  However,

16     I talked to my friend, Mr. Olmsted, from the -- from the Office of the

17     Prosecutor, and we -- we basically agreed that Mr. Olmsted would not have

18     a problem if I offer some of the documents exactly the same -- the same

19     way as -- as he did yesterday, on assumption that all these documents are

20     Milos reports and that I don't need to -- to authenticate them with the

21     witness.  I think it would shorten the time considerably of my

22     cross-examination.

23             JUDGE HALL:  Thank you.

24             MR. ZECEVIC:  Maybe Mr. Olmsted can verify this.

25             MR. OLMSTED:  That's fine with the Prosecution.

Page 10987

 1             JUDGE HALL:  Thank you.

 2             MR. ZECEVIC:  Thank you, Your Honours.

 3                           [The witness takes the stand]

 4             JUDGE HALL:  Mr. Radulovic, before Mr. Zecevic continues, I would

 5     just wish to remind you that your evidence has -- your testimony has to

 6     be interpreted, so if you could remember to slow down in your answers.

 7     Thank you.

 8             THE WITNESS: [Interpretation] Thank you, too, Your Honours.  I

 9     will try.

10             MR. ZECEVIC: [Interpretation]

11        Q.   We took the break when we were dealing with this document,

12     1D03-3349.

13             My question to you was about the contents of this document, and I

14     read it to you.  Could you confirm to us the facts mentioned here so we

15     may continue?

16        A.   This is a document of the Milos Group.  The contents were

17     implemented partly later.  The motivation is also mentioned here.  And --

18     well, that would be it in a nutshell.

19        Q.   Thank you.

20             MR. ZECEVIC: [Interpretation]  I seek to tender this document.

21             JUDGE HALL:  Admitted and marked.

22             THE REGISTRAR:  Exhibit 1D281, Your Honours.

23             MR. ZECEVIC: [Interpretation]

24        Q.   Sir, could we please see 1D03-3353.

25             Is this a Milos document?

Page 10988

 1        A.   Yes.

 2        Q.   Thank you.  In accordance with what has been agreed between the

 3     OTP and the Defence, I would like to have this document marked for

 4     identification until we receive a translation.  This is tab 8.  The

 5     document is 1D03-3353.

 6             JUDGE HALL:  So marked.

 7             THE REGISTRAR:  As Exhibit 1D282, marked for identification, Your

 8     Honours.

 9             MR. ZECEVIC: [Interpretation]

10        Q.   Sir, let me ask you, you lived in Banja Luka, didn't you?

11        A.   Yes.

12        Q.   Do you know that the SDA and the HDZ in the Banja Luka territory

13     wanted that new municipalities be established in that territory?

14        A.   Yes.  And I wrote about it.

15        Q.   Among others, there were the municipalities of Stari Grad and

16     some others, or -- including parts of Banja Luka, where the majority of

17     the population was Muslim or Croatian, right?

18        A.   Yes.

19        Q.   Among others, Ivanjska, right?

20        A.   Vrbanja, Ivanjska, Stari Grad, almost all neighbourhoods where

21     Bosniaks and Croats were the majority.  And where it was possible to

22     establish new municipalities, there was such demands, such interests, and

23     attempts.

24        Q.   Thank you.

25             MR. ZECEVIC: [Interpretation] Could we please see 1D03-3363,

Page 10989

 1     tab 15.

 2        Q.   Can you see this report dated 25 March 1992?  This is also about

 3     a Milos Group report.  Correct?

 4        A.   Yes.

 5        Q.   Do you remember this report?

 6        A.   I certainly do.

 7        Q.   Here, you mention information about the intentions of the

 8     paramilitary units of the Croatian Defence Council to attack some of the

 9     municipalities of Bosnia-Herzegovina on the 25th or 26th of March, right?

10        A.   Yes.  But I must tell you, unfortunately, this report, as many

11     others, was disregarded to a great extent.

12             On the 25th, the 26th, and the 27th, HOS units attacked Sijekovac

13     and massacred the people there, which means that our report preceded the

14     events, which shows that we did good operative work.

15        Q.   You're saying that your report dated 25 March -- or, rather, that

16     what was mentioned in your report dated 25 March came true two days

17     later?

18        A.   Correct.

19             MR. ZECEVIC: [Interpretation] I seek to tender this document.

20             JUDGE HALL:  Admitted and marked.

21             THE REGISTRAR:  As Exhibit 1D283, Your Honours.

22             MR. ZECEVIC: [Interpretation]

23        Q.   Do you remember, sir, that the chief of the SDB of the CSB of

24     Banja Luka, Mr. Kesic, round about February or March 1992 went to an

25     attend a meeting in Sarajevo at Bruno Kvesic's office, the then

Page 10990

 1     subsecretary for the State Security Service, and, on that occasion,

 2     brought back a Golf vehicle for the SDB of Banja Luka?

 3        A.   I really don't remember.  But I think his first name was not

 4     Bruno, it was Branko.  I don't remember that detail.  But I know that at

 5     that time, the first half, that is, Mr. Kvesic went to meetings -- to

 6     attend meetings in Sarajevo.  I do know that.

 7        Q.   Do you remember whether Mr. Kesic, your chief of SDB in

 8     Banja Luka, complained to you that in Brane Kvesic's office, that is the

 9     office of the subsecretary of the SDB in Sarajevo, he saw a Croatian

10     flag, or the rather, the flag of the HDZ rather than the flag of

11     Bosnia-Herzegovina.  Do you remember?

12        A.   I remember such stories which I heard from Mr. Kesic.  He was on

13     good terms with us, and I remember not only these details but also other

14     details which he found extremely surprising.  And he said that the

15     situation in the SDB was total chaos.  That is more or less what I

16     remember from those conversations.

17             MR. ZECEVIC: [Interpretation]  On page 34, line 19, the name

18     should be Kesic, rather than Kvesic.  That's the gentleman from

19     Banja Luka who went to attend meetings at Kvesic's office in Sarajevo.

20     The surnames are very similar so that's probably why.

21        Q.   Sir, do you remember another detail concerning this meeting that

22     Kesic attended in Sarajevo and which he may have related to you; namely,

23     that on that occasion, Brano Kvesic said to him that the SDB of BiH is

24     falling apart and that he would go to Mostar to work for the MUP of

25     Herceg-Bosna, and he said to Kesic, You go back to Banja Luka and take

Page 10991

 1     this Golf.

 2             Do you remember the detail?

 3        A.   I remember all of it except for the Golf.  I could have continued

 4     to say the same thing that you said.  I remember him saying that Branko

 5     Kvesic was very open with regard to the security situation in

 6     Bosnia-Herzegovina, and, actually, this frankness of his was surprising.

 7        Q.   Mr. Kesic, your chief of the SDB in Banja Luka, related that to

 8     you in early 1992, right?

 9        A.   Correct.

10        Q.   Thank you.  Let me ask you about a document, sir, which was shown

11     to you two days ago, I believe.  It's document P1366.  It's another

12     report of the Milos Group.  You commented on it with my learned friend

13     from the Prosecution.

14             I have some additional questions.

15             It refers to the documentation on the war organisation of the

16     Banja Luka CSB.  You remember discussing this document?

17        A.   Yes.

18        Q.   It's a fact, Mr. Radulovic, isn't it, that these defence plans of

19     the MUP and its organisational units, that is, SJBs, and CSBs, that these

20     plans were made in accordance with the Law on All People's Defence and

21     social self-protection.  Isn't that right?

22        A.   Yeah.

23        Q.   On the basis of the said law, you will agree with me, each of the

24     institutions of the former Socialist Federative Republic of Yugoslavia

25     was duty-bound to adopt or prepare a so-called defence plan for

Page 10992

 1     situations of wartime or immediate threat of war.  Am I correct?

 2        A.   Yes.  These facts are well known.

 3        Q.   When I speak of all institution, I refer also to schools,

 4     universities, hospitals, companies.  Do you agree?

 5        A.   Not only will I agree with you, these are facts, well-known

 6     facts.

 7        Q.   Thank you.  Sir, I think it was the day before yesterday, but I'm

 8     not sure, you discussed with my friend from the Prosecution events of the

 9     3rd of April, 1992, when members of the SOS group blockaded the city of

10     Banja Luka.

11             Do you remember this discussion?

12        A.   Yes, of course, I remember the discussion.

13        Q.   Sir, it is a fact that on that day, the 3rd of April, 1992, the

14     VRS, the Army of the Republika Srpska, did not exist, that at the time

15     that the federal army, JNA, was still present in the territory of

16     Bosnia-Herzegovina?

17        A.   Yes, that's correct.

18        Q.   Do you remember that events that triggered this blockade of

19     Banja Luka was a statement made by the minister of Defence of

20     Bosnia-Herzegovina, Jerko Doko.  Do you remember that?

21        A.   I cannot remember the statement made by Jerko Doko, but I do

22     remember that it was something related to preparing resistance for the

23     events that was supposed to come.

24             Shall I continue?

25        Q.   Can you elaborate a bit.  Yes, please.

Page 10993

 1        A.   At the time, institutions and organs in the area of Bosnia and

 2     Herzegovina failed.  It was a state of chaos.  Without such a state,

 3     there wouldn't have been paramilitary and other formations, and if I may

 4     add, the crucial part in the chaos was played by the members of the JNA

 5     who were, so to speak, nowhere between heaven and earth.  They were in

 6     the territory but they were not under the authority of the executive

 7     organs of the relevant republics.  They didn't know how to handle the

 8     situation.  Had they known, Yugoslavia wouldn't have fallen apart.

 9        Q.   I would like to try and remind you, Mr. Jerko Doko, who was at

10     the time minister of Defence of Bosnia-Herzegovina on the 2nd of April,

11     stated for the TV and other media that all conscripts and reserve troops

12     who should take part in the units of JNA and who are citizens of Bosnia

13     and Herzegovina, and if they are involved in the fighting in the Republic

14     of Croatia, are actually conducting a private war and that they will be

15     asked to show whether they are responsible for that.

16             Do you remember that?

17        A.   I do not remember when this was broadcast, but I do remember

18     reactions to these statements of his, namely, parents, especially mothers

19     of mobilised soldiers or soldiers who were, at the time, in the JNA and

20     were members of either Croat or Bosniak people organised rallies in front

21     of basic offices of Secretariats of National Defence in municipalities,

22     asking for their children to be withdrawn, to be demobilized.  There were

23     even some situations that were dangerous.  There was -- there were

24     involvement of some active soldiers there to try and prevent that because

25     mothers tried to use force and enter the archives of the secretariat and

Page 10994

 1     burn all the documents related to mobilisation.

 2             I remember that the regional centres and some military commands

 3     took out the documentation.  It was taken out by the relevant authorities

 4     to prevent them from being destroyed.

 5             I know a lot about these events, so I'm elaborating.  I hope that

 6     everyone in the courtroom knows about the events.

 7        Q.   The crux of my question had to do with the following:  Do you

 8     remember that this statement by Jerko Doko was one of the reasons which

 9     SOS gave as their explanation for the blockade of Banja Luka?

10        A.   Well, you asked me about my opinion.  If you're asking me to give

11     you my opinion, I can tell you that in the context of all the other

12     events, this also had a part.  Now whether it had a -- the most important

13     part or the secondary level importance, well, I cannot tell you.

14        Q.   Thank you.  Do you remember that in the course of your

15     conversation with the Prosecution you were told that there is an linkage

16     between the events in Sarajevo, namely, setting up of barricades in

17     Sarajevo on the 1st of March, 1991, and -- correction, 1992, and blockade

18     of Banja Luka on the 30th of June -- on 3rd of April, 1992?

19        A.   I must say that all your questions I read as something that is

20     part of your interest, but you cannot put to me anything that I would not

21     agree with and then that I agree with that.  That would be silly.

22        Q.   It is a fact that the two events were caused by completely

23     different sets of events?

24        A.   Yes.  I would agree with you.

25        Q.   Thank you.  Sir, since you were a member of the service and since

Page 10995

 1     you -- your field of expertise was intelligence, you were shown at the

 2     very beginning of our today's session a video recording of the parade

 3     that took place on the 13th of May.  It is a -- it is true, isn't it,

 4     that the day of security services, 13th of May, was something that was

 5     celebrated for years before 1992 and that the celebrations were similar.

 6     There was a programme, a parade, people would gather.  Am I right in

 7     saying that?

 8        A.   Well, yes.  That's the day when these services were formed in

 9     1994 [as interpreted], when OSNA was formed, and since 1944, celebrations

10     were held until 1992.  It was a holiday.  People would gather together,

11     enjoy themselves.

12             THE INTERPRETER:  Correction to the transcript, it wasn't in

13     1994, it was in 1944.

14             MR. ZECEVIC: [Interpretation]

15        Q.   It is a fact that, on that day, the 13th of May, the Assembly of

16     the Serbian people was also -- its session was held in Banja Luka -- or,

17     rather, of the Serbian Republic of Bosnia-Herzegovina, on that very day?

18        A.   I don't remember that, I'm sorry.  I'm not trying to evade

19     answering your question, but there were so many events taking place, I

20     can't remember whether it was held on the same day or not.

21        Q.   OTP said that you had an opportunity to review the footage, and

22     part of the broadcast included mention of the Assembly session being held

23     in Banja Luka.  Do you remember that?

24        A.   Yes, of course.  But when you ask me about whether I remember

25     that, I don't remember it.  I do remember having seen it on the video,

Page 10996

 1     but I cannot confirm that I remember the events from 1992.

 2        Q.   You were shown one part of the introductory speech made by the

 3     minister at the time, Mico Stanisic, which included a report on the

 4     security situation in the territory of the republic -- Serbian Republic

 5     of Bosnia-Herzegovina; do you remember that?

 6        A.   Yes, yes, of course.

 7        Q.   Since the video material included only one segment of this

 8     address of his, let me ask you whether you remember that at the time or

 9     immediately prior to that the incident did take place on the St. George's

10     Day in Srebrenica when the Muslim armed forces attacked and killed some

11     of the Serbian inhabitants there.  Do you know that on the basis of your

12     operative information?

13        A.   Mr. Zecevic, I knew much more about that at the time than the

14     minister, Mico Stanisic, told the address -- told the people gathered

15     there, and it is what -- what he said was absolutely true.  In this

16     shortened version of his address were correct, but the events in the area

17     of Srebrenica were much more tragic than what Mr. Stanisic said about

18     them.

19        Q.   You can confirm, then, the part of his statement where he had

20     said that service has information according to which members of Serbian

21     people are used as human shields around certain facilities?

22        A.   Yes, that's correct.  I can even tell you in which areas and to

23     what degree -- or, rather, how many of people were used as human shields.

24     But, of course, Mico Stanisic - and I hope he won't take it against me if

25     I say this - didn't know about all of that.

Page 10997

 1        Q.   Do you remember a part of his address -- I'm saying this because

 2     the sound of the video-clip was not very good.  But do you remember the

 3     part of his address where Mr. Mico Stanisic criticises or points out that

 4     there is trend of establishing so-called private armies, threatening not

 5     only the Serbian people but members of all ethnicities living in the area

 6     of Serbian Republic of Bosnia and Herzegovina.

 7             Do you remember that?

 8        A.   Yes, I do remember.  But I'm afraid that this sentence that was

 9     uttered by Mr. Mico Stanisic is something that could be found in one of

10     our reports, one of the Milos Group reports.  And that's a reason why I

11     would want to say that we, intelligence group Milos, contributed to

12     informing Mr. Mico Stanisic in a proper way.  It is impossible that it

13     was just a coincidence that the same sentence was used.

14        Q.   Sir, when we discussed your reports, you told us that the

15     Milos Group reports were submitted in two different forms.

16        A.   No, to two addresses.

17        Q.   When I said "in two different forms," I referred to a shorter

18     dispatch form and a longer detailed form, which was a report.

19        A.   Yes, you are right.  I apologise.  I started answering before

20     having heard you completely.

21             Yes, there were two forms, which deferred by the extent of the

22     information.

23             MR. ZECEVIC: [Interpretation] Can we please have 1D03-3391 on the

24     screen.

25        Q.   This is your report dated the 23rd of May, 1992?

Page 10998

 1        A.   Yes, correct.

 2        Q.   And this would be the dispatch form, a shorter report.

 3        A.   Yes.

 4        Q.   Earlier on, you said that it was sent to two recipients.  The

 5     first recipient was the SDB of Serbia; and the second one was your

 6     immediate superior, Vojin Bera, the chief of department number 01 within

 7     the Banja Luka CSB.

 8        A.   Correct.

 9        Q.   Sir, earlier on you told us that you recognised the typewriter,

10     because of its special features, the typewriter used to type these

11     reports.

12        A.   Yes.

13        Q.   And this is precisely how your report, the one submitted to Vojin

14     Bera, looked like?

15        A.   Correct.

16        Q.   And this pertains to all of the reports you -- that were put to

17     you here?

18        A.   Correct.

19        Q.   These reports were typed up on a sheet of paper, and then, in

20     that form, they were submitted to your immediate superior, Mr. Bera?

21        A.   Yes.  Mr. Zecevic, please don't say sheet of paper, because I

22     don't know how else one can type up a report.  There's no other way.

23        Q.   And you submitted your reports on a daily basis, and sometimes

24     several times a day.

25        A.   Yes, Mr. Zecevic.  Sometimes there were a dozen of such reports

Page 10999

 1     or pieces of information provided in one shape or another, be it as a

 2     dispatch or something else.

 3        Q.   When you say "in one shape or another," either as a dispatch or

 4     as a report, you are still referring to a typed-up document?

 5        A.   Yes, correct.

 6        Q.   If I remember well the conversation that you and I had, you said

 7     that you kept your records of the Milos reports - and we can see that

 8     each of them is numbered, at least far as I could see - and that you kept

 9     this record in a special log that was in your safe box?

10        A.   Yes, correct.  We had an internal log-book.  How else would these

11     reports emerge had they not been left and kept in the safe deposit box?

12     We always submitted one copy and then kept one copy for us, because our

13     numbers, our registration numbers, did not correspond with the

14     registration numbers in the main log-book which was kept within the head

15     office of the department.

16        Q.   So your internal records, your internal log-book that was kept in

17     your safe deposit box was not shown to you.  You don't even know whether

18     it exists?

19        A.   I don't know what happened with that log-book.  But what nobody

20     has managed to find was the dossiers of our collaborators and friendly

21     contacts because I put it in a safe place.

22        Q.   It is a fact, isn't it, that Mr. Bera did not keep a separate

23     log-book for the reports he received from you.

24        A.   I know for a fact that he did not have a separate log-book,

25     separate records for that.  Rather, he registered our information on the

Page 11000

 1     time of their arrival.  And then prior to that number, there would be

 2     number 10 or 20, depending on how many reports were sent on that

 3     particular day.

 4        Q.   Did you ever see that general log-book, as you call it, after

 5     leaving the Banja Luka State Security Service?

 6        A.   I did not see that log-book after I left, and I also never saw it

 7     even while I worked for the State Security Service.

 8        Q.   So if I understood you well, your claim that it was registered in

 9     the log-book is your assumption.  You said this, assuming that this is

10     how all reports were registered, but you don't know that for a fact, but

11     you did not see that general log-book either while you still worked

12     there, or afterwards.

13        A.   Correct.  Absolutely correct.

14        Q.   Please tell me, since the reports of the Milos Group, which had

15     been established in July of 1991, were sent, do you know whether the

16     chief of your administration, and also the chief of State Security

17     Service, Mr. Kesic, ever sent your reports to the seat of the State

18     Security Service in Sarajevo?

19        A.   I don't know.  I don't know whether they sent all reports and to

20     what extent or whether they made a selection.  I have no idea how my

21     superiors treated my reports, whether they forwarded them or not, and how

22     many.

23        Q.   You don't know whether they re-worked your reports and included

24     them in some other reports.  You have no idea what they did with your

25     reports.

Page 11001

 1        A.   I have no knowledge about that.

 2        Q.   In your evidence here, you said several times -- I apologise.  I

 3     will get back to that later.  In the meantime, we still have the document

 4     on our screens.

 5             You saw this document and you confirmed it was yours?

 6        A.   Yes.

 7        Q.   I notice something that was quite interesting to me.  In the

 8     third sentence of the document, you say:  "Based on our previous

 9     experience and according to what we know, these departures were observed

10     as a rule, immediately prior to armed operations by Ustasha units and

11     Green Berets."

12             In the previous text you say that a large number of citizens was

13     moving out of the Teslic municipality and then you go on to say that this

14     type of departures en masse were typical on the eve of armed attacks of

15     the enemy?

16        A.   Yes, correct.

17        Q.   Please clarify this.

18        A.   For example, from one part of the Teslic or Doboj municipality

19     there would come requests for moving out from the area, and immediately

20     thereafter, or immediately after allowing Bosniaks and Croats to leave

21     the area, there would ensue bombing of that area by those to whom I

22     referred to as the Ustasha formations and Green Berets in my report.  I

23     didn't want to refer to them in any other way, any differently than what

24     they called themselves.  By doing so, we wanted to show that there was a

25     certain link between some parts of municipalities, that there was some

Page 11002

 1     contact between them and the enemy side in the sense that they were

 2     exchanging information between themselves, and this is why we wanted to

 3     inform about this in our reports.

 4        Q.   To summarise your position and the information you conveyed in

 5     your report is that this moving out had been coordinated with certain

 6     military operations that would typically ensue after the population had

 7     moved out.

 8        A.   Correct.

 9        Q.   In the very beginning of your answer, you said that there was a

10     request coming from civilians to move out.

11        A.   Yes, certainly.  There were even centres established to process

12     and forward such requests.  Most often those requests were approved so

13     that people could leave the area, literally speaking, whenever they

14     wanted.  At one time, whoever wanted to leave could.

15        Q.   So if I understood you well, despite the circumstances that

16     existed at the time, that it was wartime and so on, according to your

17     information, there was a co-ordinated strategy in place, whereby the

18     population would first ask to move out, following which, there would be

19     an attack, either by Ustasha forces or the Green Berets, as you referred

20     to them.

21        A.   Yes.  And this happened very frequently.

22        Q.   Tell me, please, sir, it is a fact, isn't it, that this report of

23     yours pertains to Teslic municipality.

24        A.   And Doboj as well, I think.  Yes, Doboj.  In the wider area of

25     Doboj municipality.

Page 11003

 1        Q.   So if I understood you well, and what is written in your report,

 2     this was not an isolated incident typical for this particular

 3     municipality.  Rather, everywhere, throughout the area there were similar

 4     scenarios taking place.  By saying this, I'm referring to this request by

 5     civilians to move out, following which, there would be an attack by

 6     Ustashas or Green Berets.

 7        A.   As far as I am aware, none of the municipalities in the

 8     Banja Luka area, Doboj area experienced anything different than what I

 9     described.  Mostly there would be transports, buses organised so that

10     people could go where they wanted to go.  People mostly went to the

11     territory of the nowadays Federation, and there were certain crossing

12     points agreed between authorities where these convoys would be let

13     through.  Bosniaks and Croats, a large number of them, went towards

14     Croatia.  In the same way they submitted a request to move out and then a

15     schedule was determined, the date, the hour, the items they could take

16     with them, and what they needed to do before they moved out.  So the

17     situation was identical in all of these areas.

18             The fiercest bombing came from Ustashas and Green Berets in

19     Teslic, Doboj -- Doboj, Samac area and so on.  There were cases where

20     3.000 shells were fired in some areas in a single day.  I'm just giving

21     you this example as an illustration of what was going on.

22        Q.   So if I understood your position well, this departure of

23     civilians was voluntary within that scenario.  The civilians withdrew,

24     following which there would be an artillery attack.

25             Did I understand you well?

Page 11004

 1        A.   Yes, you did.  But I want to give another observation,

 2     Mr. Zecevic.  When you say "voluntary," yes, it was voluntary, but you

 3     have to bear in mind that the fact that there was a war going on

 4     certainly had its affect.

 5        Q.   At the very beginning of my question, if you remember, I stated

 6     that there were wartime conditions in place?

 7             JUDGE HARHOFF:  Just for clarification, when you proposed to the

 8     witness that the civilians population left the areas in which they had

 9     lived, following which there would be a bombardment or an artillery

10     attack of the area, which populations are we talking about?

11             MR. ZECEVIC:  I'm pretty sure that the witness was talking about

12     the Bosniaks and Croats and they would pull out of the certain -- certain

13     part of the territory, where, after their -- their departure, the

14     artillery of the Bosniak and Croatian forces will attack that particular

15     part of the territory.

16             That is my understanding and we can ask the witness [Overlapping

17     speakers] ...

18             JUDGE HARHOFF:  And that's also the understanding that I got.

19     But I was just surprised to discover -- I was surprised about this

20     because I would wish to discover the reasons why the Croat and Muslim

21     forces would attack the areas where their own population had lived.

22             MR. ZECEVIC: [Interpretation]

23        Q.   Sir, you heard the Honourable Judge's question.  Let me not

24     repeat it.  Perhaps you can just reply.

25        A.   Of course, I can.  This referred to the territories and areas of

Page 11005

 1     those municipalities where there were mixed populations.  There were both

 2     Bosniaks and Croats and Serbs.  And, of course, this did not relate to

 3     Stenjak and Teslic, where Bosniaks lived in a vast majority.  Some 99

 4     per cent of the population was Bosniak.  But this related to certain

 5     areas of the town where the ethnic groups were approximately equally

 6     present, all of them, Bosniaks, Serbs, and Croats.  And, in my view,

 7     that's quite logical, and that it is logical what was my position in 1992

 8     as well, because this report is not based on one single event, but,

 9     rather, a number of incidents of the same type.

10             JUDGE HARHOFF:  Mr. Radulovic, just to be sure, would you be good

11     enough to explain the logic to us.

12             THE WITNESS: [Interpretation] Certainly.

13             In a large number of municipalities that were not single -- that

14     were not inhabited by predominantly one ethnic group, the populations

15     were mixed or the ethnic groups lived very close to one another.

16             For instance, in my town, my home town, Teslic, in the town

17     itself, you could not really tell which ethnic group was in the majority,

18     but the villages surrounding Teslic could be actually -- you could

19     actually determine whether they were Bosniak or Serb or Croatian, and

20     such villages were the ones that were shelled at least.  Whereas, the

21     greatest number of shells actually landed on the town of Teslic itself

22     and you could see exactly the areas where these shells would land because

23     in these areas where there was a mixed population, Bosniak, Muslim --

24     Bosniak, Croatian, and Serb, as a rule, they would -- Bosniaks and Croats

25     would move out a few days prior to the event, and then a few days later,

Page 11006

 1     the shelling would start from those areas where Bosniaks and Croats were

 2     active and operating.

 3             And, again, I have to repeat, that they referred to themselves as

 4     Ustashas and Green Berets than was the terms that -- that was the term

 5     that I used as well.

 6             So as a rule, in those shellings, Serbs were victims.

 7             JUDGE HARHOFF:  So the idea was that once the Muslims and Croats

 8     had moved out, the shelling by the Muslim or Croat forces was meant to

 9     drive out the remaining Serbs who lived there.

10             Is that how we should understand it?

11             THE WITNESS: [Interpretation] Yes, you've understood me

12     correctly, Your Honour.  But I would like to add something.

13             It wasn't their objective to drive them out, but, rather, to

14     destroy them, to kill them.

15             JUDGE HARHOFF:  Thank you.

16             MR. ZECEVIC: [Interpretation]

17        Q.   Thank you, sir.

18             MR. ZECEVIC: [Interpretation]  We would like to tender this

19     document, please.

20             JUDGE HALL:  Admitted and marked.

21             THE REGISTRAR:  As Exhibit 1D284, Your Honours.

22             MR. ZECEVIC: [Interpretation] Could the witness now please be

23     shown, by way of illustration -- actually, a sample of your extended

24     report information, document 2D02-1314, tab 49.

25        Q.   Can you see this document, sir?

Page 11007

 1        A.   Yes.

 2        Q.   Can you remember it, or would you like me to show you the last

 3     page were your signature appears as well as the date?

 4        A.   Well, I've already said that I recognised the typewriter used.

 5     This was the typewriter that we used, and I do believe when you say that

 6     it's my signature.

 7        Q.   Very well.

 8             MR. ZECEVIC: [Interpretation] Could the witness now be shown page

 9     2, please.

10        Q.   And I would like you to tell us a few words about your report.

11             You see in paragraph 2 -- or, rather, this report relates to the

12     Prijedor municipality; correct?

13        A.   Well, to be more specific, Kozarica in Prijedor municipality.

14        Q.   And you note here that with the help of the democratic action

15     party, Muslim people in the area were issued 1.000 rifles.  Here it says

16     long barrels, but I assume that you are referring to rifles and similar

17     weapons.  Correct?

18        A.   Yes, military weapons.

19        Q.   You also learned apparently that that number was far larger but

20     it was your assessment that the -- this figure, 1.000, is about right;

21     correct?

22        A.   Yes.  We received this information from several different

23     sources.  They were reliable sources, sources who had been SDB sources

24     for many years and individuals of Bosniak ethnicity, and we considered

25     this information reliable, especially because our collaborators of

Page 11008

 1     Bosniak ethnicity -- especially because of the fact that they were of

 2     Bosniak ethnicity, so we did not doubt that their information was

 3     correct.

 4        Q.   Further on, in this information you point out the problem that

 5     you have already discussed here - let's not go back to that - where

 6     attention should be given to some individuals in smaller groups,

 7     Territorial Defence members, from the Republika Srpska area who cruelly

 8     treated citizens of Muslim ethnicity and so on and so forth.

 9             Can you see that?

10        A.   Yes, I can.

11        Q.   What I would like to ask you about here is something that you

12     mentioned in the last paragraph.

13             MR. ZECEVIC: [Interpretation]  In English, that will be on the

14     next page.

15        Q.   Where you say that it was your impression - that's in the second

16     paragraph in English - "we are under the impression that the regular

17     units and commanding officers of the Army of Serbian Bosnia and

18     Herzegovina are impotent to deal with these individuals and informal

19     groups which are fighting on the side of the Serbian people for their own

20     personal gain."

21             Do you recall that?

22        A.   Yes, of course.  You keep asking me whether I recall, do I

23     remember, and I'm getting the impression that you think that I can't

24     recall anything.

25             I remember all this very well.

Page 11009

 1        Q.   I apologise.  You go on to say:  "There is the serious danger

 2     that extremist individuals from one side may seize power and thus prevent

 3     the legal establishment of government."

 4             Now tell us, when you drafted this report did you have

 5     confirmation for this information that you set out here?

 6        A.   Certainly.

 7        Q.   When you say here that you're under the impression that the

 8     regular units and commanding officers are unable put a stop to these

 9     individuals or informal groups, could you please just elaborate a little?

10     What did you mean by that exactly?

11        A.   Well, you see, I had good contacts with military security and

12     active officers, active-duty officers of the former Yugoslav People's

13     Army.  I had good contacts with my colleagues from the public and state

14     security in the Prijedor area, and through contacts with these people, I

15     gained the impression that paramilitary units and groups at one point

16     outnumbered the regular troops of the Republika Srpska Army and even some

17     segments of the public -- public security service that was active in

18     Prijedor and operating in Prijedor.

19             Simply put, it was my understanding that the Republika Srpska

20     Army, which was deployed in the area, did not do everything that it could

21     because I always found it strange that if you had under your control a

22     company-strong unit that you were unable to overwhelm a platoon, and

23     especially so if you have under your control a brigade or a division,

24     that you cannot arrest a small number, in percentage points that's a

25     small number, of killers and criminals, and bring them to justice and in

Page 11010

 1     this way show that the greatest number of Serbian people, both those in

 2     uniforms and civilians, did not approve of such activities, and that is

 3     why I blame the army for this as well, if I am the one who can lay blame

 4     at anyone's door.

 5        Q.   Well, the reason I asked you about this is because you said that

 6     they were impotent --

 7             JUDGE HALL:  [Previous translation continues] ... sorry, I was

 8     wondering if you were -- if you could finish this off --

 9             MR. ZECEVIC:  No, I think we can take the break now.  Thank you

10     very much, Your Honours.

11                           [The witness stands down]

12                           --- Recess taken at 12.09 p.m.

13                           --- On resuming at 12.34 p.m.

14             MR. ZECEVIC:  Your Honours, before the witness is ushered in,

15     there was -- we had a short discussion about the -- the schedule for next

16     week.  Well, I informed Mr. Olmsted and Ms. Korner that it is my

17     assumption that I would be, like, 30 per cent less than the time that I

18     anticipated, so I believe -- I used 1 hour 40 minutes, plus this session,

19     and I believe the first session in the morning on Monday, and I will

20     finish my cross-examination, on assumption that I will tender these

21     documents, as we agreed with the Prosecution.

22             And it is my understanding that -- that the Zupljanin Defence

23     required three sessions for cross-examination of this witness, which

24     would enable us to have Mr. Riedlmayer on Wednesday, and we can guarantee

25     that we will finish by Thursday, end of the working hours, with the

Page 11011

 1     Witness Riedlmayer.

 2             So the -- for this reason, we don't believe that the extra

 3     session is needed on Monday.  That is --

 4             JUDGE HALL:  [Microphone not activated]

 5             MR. ZECEVIC:  Yes.

 6                           [Trial Chamber and Registrar confer]

 7                           [The witness takes the stand]

 8             MR. ZECEVIC:  May I continue, Your Honours?

 9             JUDGE HALL:  Yes, Mr. Zecevic.

10             MR. ZECEVIC:  Thank you very much.

11        Q.   [Interpretation] Mr. Radulovic, you have before you document

12     1D03-3398.  You can see it now on the screen before you.  It is dated 5

13     June 1992 and signed Milos.  Can you see that?

14        A.   Yes.

15        Q.   Do you recall this report of yours?

16        A.   Yes.

17        Q.   You talk here about the personnel in the district prison, and you

18     mention that out of eight employees, only one is a Serb while five are

19     Muslims and two are Croats.

20             This is on 5 June, 1992.  Which district prison is this a

21     reference to?

22        A.   Well, let me just try to bring it up.  I think this is in Doboj.

23             Yes, this is the Doboj District Prison, because I never used the

24     term correctional facility in Banja Luka.  I did not use the term

25     district prison for that prison, so this must refer to Doboj.

Page 11012

 1        Q.   When you say eight employee, what do you mean by that?  Do -- are

 2     you referring to guards there?

 3        A.   Yes.  This is in the investigative department.  I don't -- this

 4     is not a reference to the entire district prison but just to its

 5     investigative department.

 6        Q.   So, according to this report, on 5 June, which is the date of the

 7     report, in the investigations department of the district prison in Doboj

 8     there were eight guards, five of whom Muslim, two Croats, and one Serb;

 9     correct?

10        A.   Yes.  But I would like to point out that this is a reference to

11     the investigations department.

12        Q.   Well, that's what I said in my question.

13             MR. ZECEVIC: [Interpretation]  I would like to tender this

14     document.

15             JUDGE HALL:  Admitted and marked.

16             THE REGISTRAR:  As Exhibit 1D285.

17             MR. ZECEVIC: [Interpretation] Can we please see 65 ter 10192.

18        Q.   Sir, can you see this report of yours dated 19 May 1992?

19        A.   Yes.

20        Q.   Do you remember it?

21        A.   I remember the events.

22        Q.   Here you speak about Muslims and Croats leaving the area of

23     Bosanska Krajina due to some propaganda, some false information; correct?

24        A.   Yes.  It was especially present in the areas of Prijedor, Kljuc,

25     and Sanski Most.

Page 11013

 1        Q.   That false information, who spread it?  Where did it originate

 2     from; do you remember?

 3        A.   Of course, I do.  The Bosniak side.

 4        Q.   Thank you.

 5             MR. ZECEVIC: [Interpretation]  I seek to tender this document,

 6     unless there are objections.

 7             JUDGE HALL:  Admitted and marked.

 8             JUDGE HARHOFF:  Mr. Radulovic, again, a small question just to be

 9     sure that I have understood this correctly.

10             Why would the Bosnian and Croat side spread deliberately

11     misinformation about a planned attack against them?  What's the big idea?

12             THE WITNESS: [Interpretation] I can give my comment.

13             Your Honour, at the time when I wrote this, I did not make

14     comments, or I didn't venture into assessments.  After this much time,

15     after all these years, I can state my opinion.

16             JUDGE HARHOFF:  Yes, if you would be so good.  Briefly.

17             THE WITNESS: [Interpretation] The desire was to depict the

18     situation in the territories controlled by the Serb authorities in -- in

19     the media as unbearable for survival.  And then various misinformation

20     reached Bosniaks and Croats about the Serbs allegedly planning extensive

21     military and other operations in those areas and that all Bosniaks and

22     Croats would be killed.

23             The objective was for these Bosniaks and Croats leave the areas

24     they inhabited in Serb-controlled territory and cross over to the Muslim

25     or Croatian-controlled areas with the overall aim of using it for

Page 11014

 1     propaganda purposes, and I can only repeat that the role of the mass

 2     media was very important at the time.

 3             JUDGE HARHOFF:  Thank you.

 4             THE REGISTRAR:  I apologise to the counsel.  65 ter number 10192

 5     will become Exhibit 1D286.

 6             MR. ZECEVIC:  Thank you, Ms. Registrar.

 7        Q.   [Interpretation] Sir, it's also a fact, apart from the propaganda

 8     value, that this enabled Croat or Bosniak forces to get possible

 9     reenforcements from the ranks of these newly arrived individuals,

10     reenforcements for their military units, right?

11        A.   Mr. Zecevic, you are now eliciting information which is not part

12     of this report; however, the Milos Group did inform the relevant

13     structures about that.  These groups leaving for Croatia or for the

14     Federation were a source of manpower for military units, so that your

15     conclusion or assumption is, indeed, in line with the reality on the

16     ground.

17             And if I may add, the Bosniaks who went to Croatia created one of

18     the strongest military units called the the Honorary Berber Platoon, who

19     carried out offensive activities in the Gradiska municipality, which is

20     part of the RS, and there have been instances of mass killings, both of

21     members of the military and police units and civilians too.

22        Q.   Thank you.  On Tuesday, you gave evidence here, and yesterday,

23     too, you testified that Mr. Kesic, who was chief of state security in

24     Banja Luka, with regard to these reports of yours, as well as to the

25     information you passed on to him orally, had a rather negative attitude.

Page 11015

 1     His opinion was that this information was not interesting for the

 2     service, that it is not significant, that the service shouldn't do

 3     anything about it, et cetera.

 4        A.   Yes.  Let me just point out something extremely stupid.

 5             On the list of the documents in possession of the OTP, there's

 6     also a report of the Milos Group from 1993, which is a report that we

 7     received from a high-ranking expert in the NATO forces that, namely,

 8     there would be a bombing of Serbia and Yugoslavia by NATO forces at a

 9     later -- at a certain point in time.  However, this report was stuck in a

10     drawer of Mr. Bera, who was constantly trying to devaluate my work and

11     that of my group, and if you are siding with this Mr. Bera you are

12     humiliating me because I have never been narcicisstic nor have I been a

13     fool. .

14        Q.   Sir, that is not my intention at all.  I would just like us to

15     know what you know, and I hope that you will help us to achieve that.

16             Such important information submitted by you in 1993 to your

17     immediate superior as well as some previous information was not

18     forwarded -- was not passed on; correct?

19        A.   Unfortunately, I found out about that only later, that much of my

20     information never made it to the people that should have received it.

21     They never went further than the National Security Service in Banja Luka.

22     And I can provide -- or I can corroborate this statement with facts

23     because there is somebody in this very courtroom who can be a witness to

24     what I have just said.

25        Q.   Go on.

Page 11016

 1        A.   I spoke to Mr. Mico Stanisic for the first time in 1999.  We met

 2     at the Intercontinental Hotel immediately after Arkan was killed.  We

 3     wanted to sit exactly where he was killed.  Somebody made a joke about

 4     that so we chose a different place to sit.  And we spoke about the fact

 5     that my -- or, rather, I learned that much of my information that I had

 6     submitted never made its way to him.

 7             It seems to me that Mico Stanisic only changed his mind in 1999

 8     because he seems to -- seems to have received information about me

 9     depicting me in a very negative light, but that is something that I heard

10     not only from him but also from others; but these others don't matter

11     because they have no connection with these proceedings.

12             MR. ZECEVIC: [Interpretation]  A moment of leave.

13        Q.   Just a moment.  It would seem that your answer has not been

14     recorded in its entirety.  If I remember well, you said it is only then

15     that I understood that a large number of my reports never made it to him.

16     Actually, not one did.

17             Is that what you said?

18        A.   Yes, exactly.  I am referring to these most important reports and

19     the most complex information.

20        Q.   Thank you.

21        A.   Do you want a full answer?  So -- because for my sake I would

22     like to give you a complete answer.

23             I understood after the end of the war many of my reports were

24     edited and changed to suit the expectations of their consumers.

25     Sometimes they were toned down, sometimes they were amplified, and the

Page 11017

 1     key roles in that process were those of Vojin Bera and Nedeljko Kesic.

 2     I'm taking about the reports that were made for the RS.  But this sort of

 3     editing couldn't be applied to the reports that went to Belgrade.

 4        Q.   It couldn't because you submitted such information directly to

 5     Belgrade, right?

 6        A.   Yes.

 7        Q.   And the facts that you have related to us just now were something

 8     that you learned about only after the war, right?

 9        A.   Yes.  Among others, in the conversation with Mico Stanisic.  But

10     that was only one of the conversations with one of the persons after the

11     war.  I also learned about that in the conversation with Gojko Glickovic

12     [phoen] toward the very end of the war or after the war.  The man was

13     surprised when we spoke, and he admitted to me that I was some sort of an

14     idiot, a fool, that's the way I was presented to him while he was in a

15     high position.

16             So what I'm saying, this wasn't meant -- this wasn't done -- or,

17     rather, it wasn't targeted at me.  The purpose was to devalue the

18     information that I passed on, not only about the crimes committed by

19     Serbs because somebody didn't consider that suitable and they were

20     covering it up.  And that's the attitude they had to all security-related

21     information, and everything was under a veil of secrecy or something.

22             THE INTERPRETER:  Microphone.

23             MR. ZECEVIC: [Interpretation]

24        Q.   Mr. Radulovic, the assistant minister for the SDB of the Serbian

25     Republic of Bosnia-Herzegovina, in the first four months, from April to

Page 11018

 1     mid-August, that was a position filled by Slobo Skipina.  It is a fact,

 2     isn't it, that you had no professional contact with Slobo Skipina

 3     throughout that period?

 4        A.   Correct.  That was surprising to me, and I was also disappointed

 5     because Skipina and I had worked together in the SDB, and we did have

 6     contact previously, and I would have thought that he should have either

 7     accepted the information that I passed on or take steps against me if he

 8     believed that the information I submitted was a heap of rubbish.

 9        Q.   However, he didn't do either of the two things because he didn't

10     receive your information.

11        A.   Well, Mr. Zecevic, that's the only justification of his actions.

12        Q.   Could you please tell us, sir, on page 10796 and further of our

13     transcript here, you spoke about a report of yours dated 17th of May,

14     1992.  In your testimony you said that the report was a result of your

15     first information related to crimes committed by Serbian forces in Doboj

16     by mid-May.  Is that correct?

17        A.   Yes.

18        Q.   I'm not seeking confirmation, really, I just wanted to make sure

19     that your answer was recorded properly in the transcript.  It didn't

20     occur originally, and I have about ten more examples, and I will just go

21     through them to ask for your confirmation.

22             On page 10814 of the transcript, you stated that some people had

23     ID cards of the SNB or police without even knowing what kind of service

24     that was.

25        A.   Yes, that's correct.

Page 11019

 1        Q.   You stated that, unfortunately, the times were such, on page

 2     10907, you spoke about paramilitary and para-police groups in Doboj

 3     having such ID cards.  Do you remember stating that?

 4        A.   Yes, I do remember, but as I was saying before and I will repeat

 5     it, I described these groups as criminal organisations that weren't

 6     involved -- involved in the war for the interests of the Serbian people

 7     but for the purpose of looting, and to achieve that, they needed to kill

 8     people who possessed what they wanted from whom they wanted to take items

 9     and then they wanted to kill witnesses of their acts.

10        Q.   So you mean just to get rid of the witnesses?

11        A.   Yes.  I admit I -- my terminology was a bit confused.  The way

12     you put it is much better.  To get rid of a witness.  A live witness is

13     the worst witness.

14        Q.   When these paramilitary and para-police groups were discussed,

15     these groups that you described as criminal organisations, you told the

16     Prosecutor in response to his question when he asked you to enumerate

17     them, but I presume because of the time-limits, you were interrupted, and

18     I would like to ask you to now list paramilitary and para-police group

19     that existed in Doboj in 1992.

20        A.   There's something that can I ask you to ask the Trial Chamber for

21     us to go into closed session.

22             MR. ZECEVIC: [Interpretation] Could we have a private session,

23     please.

24             JUDGE HALL:  Yes, we go into private session.

25                           [Private session]

Page 11020











11 Pages 11020-11027 redacted. Private session.















Page 11028

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 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25                           [Open session]

Page 11029

 1             THE REGISTRAR:  We're in open session, Your Honours.

 2             MR. ZECEVIC:  May I continue, Your Honours.

 3             JUDGE HALL:  Yes, please.

 4             THE INTERPRETER:  Could the counsel please repeat the transcript

 5     page number.

 6             MR. ZECEVIC: [Interpretation]  I apologise.  On page 10942 of the

 7     transcript, you said that some of the leaders in Teslic knew what the

 8     Mices had done and the crimes they had committed before even you were

 9     informed, and you mentioned, among others, the president of the court and

10     the then public prosecutor in Teslic.  The public prosecutor, for whom

11     you claim that he knew what was going on in Teslic, was Mr. Peric;

12     correct?

13        A.   Yes, Mr. Branko Peric.

14        Q.   On the next page of the transcript, 10943, do you remember, you

15     were then shown an article from Slobodna Bosna, and you were asked to

16     comment on it, and the Prosecutor suggested then that -- put it to you

17     that your action followed only after the Mice Group began to commit

18     crimes against Serbs as well, and that you -- or, rather, the group that

19     you led only intervened because of that and not because they had

20     committed the crimes against Muslims.

21        A.   Well, I would rather not say anything about this.  This is

22     absolutely untrue.  It's a red herring, let me put it mildly.  We

23     intervened even earlier to protect Bosniaks and Croats.  We intervened

24     after those event, in order to protect Bosniaks and Croats.  We

25     intervened also, I mentioned the incident with the 600 Romas on that

Page 11030

 1     cross-roads, so this is very offensive to me and to my sense, my ethical

 2     beliefs, so nothing of that sort should be put to me.  No one in this

 3     courtroom should put anything like that to me because I managed to keep

 4     my dignity in far worse situations than this.

 5             And if you allow me, I would like to take this opportunity to say

 6     something here.  Somebody suggested here that I may feel uncomfortable

 7     testifying as a Serb against Serbs.  I would just like to stress this:

 8     I'm not testifying against Serbs.  I'm testifying about the events that I

 9     was a witness to and that I heard about, and I consider that those who

10     committed those crimes were in no way related to me in any way, and that

11     had nothing to do with them being Serbs, and that would not characterise

12     Serbs.  And if I were to make a choice between a human being and a Serb,

13     I would always choose a human being.

14        Q.   Thank you.  You've actually pre-empted one of my questions.

15             On the next page of the transcript, 10944, you testified about

16     the situation immediately following the arrest of the Mices and the --

17     and you also talked about the group that you led in this operation.  And

18     you said that, at that time, the chief of the security services in Doboj,

19     Mr. Bjelosevic and you, were on bad terms.  And you said in the end that,

20     according to you, he was not well-informed and did not know fully what

21     these people had done.

22             You concluded that based on a conversation with him; correct?

23        A.   Yes.

24        Q.   Do you know that Mr. Bjelosevic, as the chief of the CSB, from

25     early May was resubordinated as a commander of a police unit to the army

Page 11031

 1     in the battle-field.  Do you know that?

 2        A.   Yes.  And I can tell you where exactly on the front line he was.

 3     He was in the operation zone that was fighting in order to try and break

 4     through the corridor, open up the corridor.  And literally, he was, on a

 5     daily basis at the operations centre.

 6             THE INTERPRETER:  The interpreter did not hear the last words.

 7             MR. ZECEVIC: [Interpretation]

 8        Q.   You said, in -- at the operations centre.  Could you just tell us

 9     slowly what was the name of that operations centre or the place where it

10     was?

11        A.   Well, it was the command, the operation centre at Duge Njive.

12        Q.   You said Duge Njive?

13        A.   Yes, that's what it was called.

14        Q.   Please tell us, the command centre at Duge Njive, was that the

15     operative group command centre?

16        A.   That's correct.

17        Q.   When I say "Operational Group," I'm referring to the Army of the

18     Republika Srpska.

19        A.   Correct.

20        Q.   Please tell me, this location, the place where the operations

21     centre was at Duge Njive, how far was that from Doboj or from Teslic?

22     Can give us an idea?

23        A.   It's about 70 kilometres from Teslic and about 30 kilometres from

24     Doboj.  Depends on the road you took.  That, too, would make a

25     difference.

Page 11032

 1        Q.   Very well.  The operation to break through the corridor, open up

 2     a corridor, were conducted in the course of the summer 1992; correct?

 3        A.   Well, it took quite a while, so please don't ask me specifically

 4     at what point.

 5        Q.   Even after the corridor was established, road communication was

 6     very difficult all the way through August up until September.

 7        A.   Even later.  The road was often shelled from Orasje and Gradacac

 8     so you had to drive carefully and -- even after the corridor,

 9     conditionally speaking, had been established.

10        Q.   Thank you, sir.  I have finished for today.

11             MR. ZECEVIC:  Your Honour, I'm pretty well near the end of my

12     cross-examination, but I would like to stop here at three minutes so I

13     can consult overnight and be able to focus my cross for tomorrow morning,

14     in order to -- to save as much time as possible -- on Monday.

15             JUDGE HALL:  We understand what you mean, yes.

16             MR. ZECEVIC:  I'm sorry, thank you.

17                           [Trial Chamber and Legal Officer confer]

18             MS. KORNER:  Your Honours, I was going to ask whether given

19     there's a minute or so whether Your Honours had prepared to rule on the

20     reconsideration application in respect of the articles.  Which is either

21     a yes or no.

22             JUDGE HALL:  [Microphone not activated] ... well, not at this

23     moment.

24             THE INTERPRETER:  Microphone for the Judge, please.

25             JUDGE HALL:  [Microphone not activated]

Page 11033

 1             MS. KORNER:  Well --

 2             JUDGE HARHOFF:  Does it make any difference at this moment?

 3             MS. KORNER:  No, it doesn't, Your Honour, but I know this is my

 4     pet thing, but we're building up again a lot of very compendious amount

 5     of -- of requests and motions and whatever that are unanswered.

 6             JUDGE HARHOFF:  We are painfully aware of it.

 7             MS. KORNER:  I know.  So I was just wondering if something that

 8     was relatively simple could be dealt with, and could be dealt with by way

 9     of an oral ruling.  But if Your Honours feel not, then I'm not pressing

10     it.

11             JUDGE HARHOFF:  We had prepared a ruling, but we still need to

12     consider it one more time.

13             JUDGE HALL:  So we will take the adjournment for the weekend and

14     reconvene in Courtroom III on Monday morning.

15             And I wish everyone a safe weekend.  Thank you.

16                           [The witness withdrew]

17                            --- Whereupon the hearing adjourned at 1.43 p.m.,

18                           to be reconvened on Monday, the 31st day of May,

19                           2010, at 9.00 a.m.