1 Tuesday, 12 April 2011
2 [Open session]
3 [The accused entered court]
4 --- Upon commencing at 9.03 a.m.
5 THE REGISTRAR: Good morning, Your Honours. Good morning to
6 everyone in and around the courtroom.
7 This is case IT-08-91-T, the Prosecutor versus Mico Stanisic and
8 Stojan Zupljanin.
9 JUDGE HALL: Thank you, Madam Registrar.
10 Good morning to everyone. May we have the appearances, please.
11 MS. KORNER: Good morning, Your Honours. Joanna Korner,
12 Alex Demirdjian, and Crispian Smith for the Prosecution.
13 MR. ZECEVIC: Good morning, Your Honours. Slobodan Zecevic,
14 Slobodan Cvijetic, Eugene O'Sullivan, Ms. Tatjana Savic, and
15 Ms. Deirdre Montgomery appearing for the Stanisic Defence this morning.
16 Thank you.
17 MR. KRGOVIC: Good morning, Your Honours. Dragan Krgovic and
18 Aleksandar Aleksic appearing for Zupljanin Defence.
19 JUDGE HALL: Thank you.
20 And if there are no housekeeping or similar matters, could the
21 Usher please escort the witness to the stand.
22 MR. ZECEVIC: Your Honours, just one thing, if I may, before the
23 witness is -- while the witness is ushered in.
24 I failed to announce and I -- and I found out only right now, I
25 failed to announce two documents which I would like to use at the
1 beginning. Those are the charts prepared by the Office of the
2 Prosecutor. The structure of the MUP, and the -- and the map of Bosnia
3 and Herzegovina.
4 I don't know if there would be any opposition to --
5 MS. KORNER: No opposition, Your Honour, except I haven't got
6 them here. All right. We can arrange for someone to bring them down.
7 MR. ZECEVIC: Well, I can borrow you mine.
8 MS. KORNER: Or even lend it to me.
9 MR. ZECEVIC: Lend it, yes. Thank you. And I'm really sorry for
11 JUDGE HALL: Could somebody remind me as to what the status is?
12 Were they merely working documents or were they exhibits?
13 MS. KORNER: No, they're admitted as exhibits, Your Honours.
14 JUDGE HALL: Thanks.
15 [The witness entered court]
16 JUDGE HALL: Good morning to you, sir. Would you please make the
17 solemn declaration from the card the Usher is now handing to you.
18 THE WITNESS: [Interpretation] Good morning. I solemnly declare
19 that I will speak the truth, the whole truth, and nothing but the truth.
20 JUDGE HALL: Thank you. You may be seated.
21 THE WITNESS: [Interpretation] Thank you.
22 JUDGE HALL: From your responses to this point, I assume that you
23 are hearing me in a language that you understand?
24 THE WITNESS: [Interpretation] Yes.
25 JUDGE HALL: Would you tell us your name, please.
1 THE WITNESS: [Interpretation] Andrija Bjelosevic.
2 JUDGE HALL: Well, I will leave it to counsel at whose instance
3 you are being called to lead you on evidence about particulars about
4 yourself and your qualifications. I would, however, first of all,
5 welcome you to this Tribunal and thank you for coming to give evidence.
6 Have you testified previously before this Tribunal or before any
7 of the courts in any of the countries that comprise the former
9 THE WITNESS: [Interpretation] No, not in these cases.
10 JUDGE HALL: Thank you. You have been called by counsel for the
11 accused Stanisic, and counsel would begin -- the procedure is that
12 counsel -- the side -- counsel for the side calling you would begin by
13 asking you questions following which the side opposite -- well, following
14 which the side for the co-accused would have an opportunity to
15 cross-examine you. Followed by counsel for the Prosecution, the side
17 Counsel calling you would then have a right to re-examine you on
18 matters that would have arisen out of cross-examination, and usually, at
19 that stage but indeed at any stage the members of the Bench may put
20 questions to you.
21 It is estimated by counsel for the accused Stanisic that you will
22 be on the witness-stand for a total of 20 hours. Counsel for the
23 Prosecution has indicated that their cross-examination is likely to take
24 the same period of time. Counsel for the co-accused, Mr. Zupljanin, have
25 indicated that they would not be nearly as long with you, but all told,
1 it will mean that you are expected to be before the Tribunal giving
2 evidence for the remainder of this week and indeed for the next three
3 weeks, according -- if I recall the schedule correctly. But from what I
4 would have indicated in terms of the numbers of hours, you would have an
5 idea as to how long your testimony is likely to take.
6 You needn't be alarmed that you would be on the stand for
7 20 hours continuously. For technical reasons, the Tribunal's work is
8 broken up into sessions of approximately 90 minutes and there are two
9 reasons for this. One is the technical reason that the tapes that
10 memorialise and record the proceedings have to be changed at
11 approximately 90-minute intervals, and the secondary reason is that that
12 allows for the comfort and convenience of witnesses, counsel, and
13 everyone to take a break and then come back.
14 Now, notwithstanding those set times that I have indicated, if,
15 at any point in your testimony there is any reason that you would need to
16 take a break, please indicate that to us, either directly or through your
17 counsel, and it is something that we would, of course, accommodate.
18 And unless you have any questions with which I may assist, I
19 would invite counsel for Mr. Stanisic to begin their
21 MR. ZECEVIC: May I, Your Honours.
22 JUDGE HALL: Yes.
23 MR. ZECEVIC: Thank you.
24 WITNESS: ANDRIJA BJELOSEVIC
25 [Witness answered through interpreter]
1 Examination by Mr. Zecevic:
2 Q. [Interpretation] Good morning, Mr. Bjelosevic.
3 A. Good morning.
4 Q. Mr. Bjelosevic, please tell us briefly something about yourself.
5 Where you were born, what schools you graduated from and so on.
6 A. I was born in Derventa, and I have a degree in national defence
7 from Belgrade university. And in early 1990, I worked in -- in the
8 1980s, I started working in secondary schools. Thereupon I went to work
9 for the Secretariat for National Defence, and then, as of 1991, I started
10 working for the MUP, and that's where I work to this day.
11 Q. Mr. Bjelosevic, let me explain one matter to you. Since what you
12 are saying is being interpreted, please speak slowly so that the
13 interpreters have ample time to catch up with you?
14 Tell us, please, the year of your birth and the place where you
15 graduated from secondary and other schools?
16 A. I was born in 1954. I completed my primary education in my
17 native town, and the secondary school in Derventa.
18 Q. If I understood you correctly, you graduated from the Faculty of
19 National Defence in Belgrade; is that right?
20 A. Yes.
21 Q. You also told us that upon your graduation, you worked in a
22 secondary school and then in the Secretariat for National Defence; is
23 that right?
24 A. Yes. In Derventa.
25 Q. Please explain for us, what were the activities of the
1 Secretariat for National Defence at the time?
2 A. The Secretariat for National Defence was structured, let me
3 organise the hierarchy. There was the Federal Secretariat for National
4 Defence which covered the whole of Yugoslavia. Then the Republican
5 Secretariat for National Defence in each of the republics. And then at
6 municipal level, there were Municipal Secretariats for National Defence
7 which dealt with the recruitment and assignment of recruits to the JNA,
8 the manning of JNA units and Territorial Defence units, the organisation
9 of defence activities for all the other sectors of society at
10 municipality level, mobilisation schedules for all the various
11 structures, civilian protection, and engaged in certain forms of training
12 in these particular areas.
13 Q. Tell me, the military records of conscripts were kept where
14 exactly; and did they have anything to do with the secretariats for
15 national defence?
16 A. Yes, it was precisely there that all the military records were
17 kept at a certain territorial organisation unit, and it was there that at
18 the request of certain wartime units and other authorities which dealt
19 with the organisation of wartime matters that individuals were recruited.
20 This was also the place where mobilisation was worked out, the way in
21 which was to proceed, and it was already carried out, both the
22 mobilisation of personnel and of assets, as well as of members of the
23 civilian protection and all the other individuals who had specific
24 wartime assignments.
25 Furthermore, there were also emergency plans. All those were
1 developed according to a uniform methodology that was prescribed by the
2 Law on National Defence and a number of bylaws. They were to provide
3 guide-lines and instructions, and similar.
4 Q. Can we please describe it quite plastically for Their Honours the
5 issue of recruitment and how it worked. Were all conscripts, let's say,
6 males of military age in a given, let's say, municipality, were they all
7 listed as recruits; and at what point in their life would this be?
8 A. Well, these were males, as you yourself said, who, as they turned
9 18, would be listed in the military records and referred to recruitment
10 commissions where they would undergo physical and psychological
11 examinations to determine their fitness for military service.
12 This was a sort of screening process, the aim of which was
13 precisely to determine who, among those conscripts, was fit to do
14 military service, and those who were declared unfit would be listed in
15 special records, as precisely such individuals. The remainder who were
16 deemed fit for military service --
17 JUDGE HARHOFF: Excuse me. There is one little thing which is
18 not quite clear to me, Mr. Bjelosevic.
19 Counsel Zecevic asked you whether the military records of the
20 conscripts were kept where exactly and did they have to do anything with
21 Secretariat for National Defence, and then your answer was, as it was
22 recorded, that:
23 "... it was precisely there that all the military records were
24 kept ..."
25 And my question is simply, was that at the federal level in
1 Belgrade or were these records kept regionally in the various departments
2 of the secretariat?
3 Do you understand my question?
4 THE WITNESS: [Interpretation] Yes. And that's precisely what I
5 was about to talk about in my answer.
6 I said that there was this screening process which took place,
7 and once these individuals were listed in military records and these
8 military records were kept at the level of Municipal Secretariat for --
9 Secretariats for National Defence, which, through the structure of
10 Military Districts were sent on to the Republican Secretariats for
11 National Defence and the Federal Secretariat for National Defence.
12 Next, in keeping with the wartime and peacetime plans for various
13 units, a plan of war -- or, rather, a plan of assignments or posting of
14 these various recruits to the JNA would be made, and this plan, from the
15 Federal Secretariat for National Defence, via the Republican Secretariats
16 and Military Districts would be delivered to the various Municipal
17 Secretariats for National Defence, and they would be the ones who would
18 physically dispatch recruits to the destinations as determined by the
19 structures higher up.
20 JUDGE HARHOFF: Thank you very much.
21 Back to you, Mr. Zecevic.
22 MR. ZECEVIC: Thank you, Your Honour.
23 Q. [Interpretation] Mr. Bjelosevic, once the recruits completed
24 their training in the Yugoslavia People's Army, they would, on their
25 return, I assume, report again to the Secretariat for National Defence
1 when they would be assigned to the reserve force; is that right?
2 A. Their individual and unit files would be sent from the area where
3 they served to their, let's call it home Secretariat for National
4 Defence, and into these files it would be entered that they had completed
5 their compulsory military service, their speciality and specific skills
6 would also be listed in their files, and it was on that basis, and on the
7 basis of the requirements in the army, their wartime assignments would be
8 made. They would be assigned to either units or other structures, such
9 as the police, territorial units, that's to say, units of the
10 Territorial Defence, or units of the civilian protection. Alternatively,
11 it could have been a wartime assignment to a certain company or
12 institution. It all depended on the person's qualifications and
14 Q. Therefore, the Municipal Secretariat for National Defence would
15 be the body which, if I understand you correctly, made specific
16 assignments for individuals who had completed their compulsory military
17 service. Is my understanding correct?
18 A. Yes.
19 Q. And based on their files and skills acquired during their
20 training in the Yugoslav People's Army, they would be assigned to the
21 police reserve force, among others.
22 A. Yes. As I said, it is based on that that they would be assigned
23 to various structures, including the police reserve force, depending on
24 the number of police stations available and a number of other factors.
25 Q. In practical terms, would the files of these individuals in that
1 case be transferred to the Ministry of Interior or, as they were called,
2 the secretariats of the interior?
3 A. No. The master copy of their file would be kept with the
4 Municipal Secretariat for National Defence. So the individual's file
5 would be kept by the secretariat, whereas the file for the entire unit
6 would be sent to the structure receiving the individual under this
8 Q. So the master copies of these files were always kept with the
9 Secretariat for National Defence in the territory of the municipality
10 where the individual resided; is that right?
11 A. Yes.
12 Q. Thank you.
13 JUDGE DELVOIE: Mr. Bjelosevic, if I understand you well, the
14 assignments after the person has finished his -- his military service,
15 his normal military service, the assignments after that, are only wartime
16 assignments; is that correct?
17 So you were, for instance, in the -- in the reserve police only
18 for wartime. You wouldn't be bothered by it in peacetime. Is that -- do
19 I understand that correctly?
20 THE WITNESS: [Interpretation] That was wartime deployment, and
21 stations of the so-called military police were established thereby.
22 However, that composition was occasionally summoned primarily for
23 further training and, secondly, in case of some exceptional circumstances
24 or ...
25 JUDGE DELVOIE: Thank you.
1 MR. ZECEVIC:
2 Q. [Interpretation] Mr. Bjelosevic, you've told us that at the
3 Secretariat for National Defence you spent seven or nine years working
5 A. Seven years.
6 Q. After that, you joined the MUP of the Socialist Federative
7 Republic of Bosnia and Herzegovina, right?
8 A. Yes.
9 MR. ZECEVIC: Your Honours, we have prepared a binder of
10 documents to facilitate the -- for the witness so he can look at the
11 whole document once it is shown to him so if -- if Usher can ...
12 Q. [Interpretation] Mr. Bjelosevic, you started working at the
13 Ministry of the Interior of the Socialist Republic of Bosnia and
14 Herzegovina when exactly?
15 A. I believe that that was in early May or perhaps the end of
16 April 1991.
17 Q. Did you apply for a job? Was there a vacancy announced? How did
18 you get the job?
19 A. The procedure that was in place for such appointments was a bit
20 complicated, I would say. And I mean by that that there were supposed to
21 be at least -- at least -- at least three candidates, or, rather,
22 proposals for at least three candidates had to be submitted. After that,
23 all the applicants were invited to undergo a physical examination, or,
24 rather, their physical and mental abilities were tested. After the
25 results came out, one of the three or more candidates were selected for
1 the job in question.
2 One of the conditions that a candidate had to meet was for the
3 political parties that formed a coalition at that time endorsed the
4 appointment of any such candidate. And those arrangements were usually
5 made between the personnel commission of the MUP and a representative of
6 the party.
7 Q. Mr. Bjelosevic, was there also security check for each candidate?
8 A. Yes, absolutely. That was a must.
9 Let me just digress a little and tell you that if somebody was
10 deployed into the police, they would be vetted. And for management
11 staff, there were very detailed security checks. And, of course, that
12 included checking references from a previous time.
13 Q. When you said, on page 12, point 1, that if somebody was
14 transferred to the police force, you meant your job in the Secretariat
15 for National Defence, and you meant when somebody was transferred to the
16 police reserve, even then, there had to be security checks for such
17 people, right?
18 A. Yes. This is precisely what I meant.
19 Q. Mr. Bjelosevic, in late April or early May, you became the chief
20 of the Security Services Centre of Doboj, right?
21 A. Yes.
22 Q. I'm now going to show you a document.
23 MR. ZECEVIC: [Interpretation] Could we please call it up in
24 e-court. It's 65 ter -- the Prosecutor's 65 ter 10137, paragraph 3, or
25 item 3, which is a map of Bosnia and Herzegovina.
1 65 ter 10137.3, which is a map of Bosnia and Herzegovina.
2 I apologise, this is not the map that I had in mind. Strike
3 that. I don't need this document. The number must have been wrong or --
5 Q. Sir, in terms of the position of Doboj municipality, could you
6 please provide us some detail about its geographical position, its
7 placement in Bosnia and Herzegovina.
8 A. Doboj is in the northern or central northern part of Bosnia and
9 Herzegovina on the axis from Sarajevo to Slavonski Brod, on the river
11 Q. Sir, could you please tell us how many municipal secretariats or
12 public security stations at the moment when you were appointed the chief
13 of the Security Services Centre in Doboj were there, and could you tell
14 us which stations those were.
15 A. Under the Doboj centre, there were the following.
16 Q. Could you please do it slowly.
17 A. The public security station Brod; Derventa; Odzak; Samac;
18 Modrica; Doboj; Tesanj; Teslic; and Maglaj.
19 Q. So if I understood you properly, there were nine public security
20 stations within the framework of the Security Services Centre of Doboj.
21 A. Yes, that was the case in 1991.
22 Q. At that time, in 1991, who were the persons that were chiefs of
23 those public security stations? Can you give us their names? Who were
24 there in 1991? Who was appointed in 1991? Could you please do it slowly
25 again. It is rather difficult to record the names.
1 A. It was a long time ago, but I'll try and remember all of their
3 In the Brod station, the person in charge was Slavko Pranjic.
4 Later on, there was a shake-up, and he was replaced by Zvonko Nedanovic,
5 I believe.
6 In Odzak, it was Stjepan Mikic.
7 In Samac, Vinko Dragicevic.
8 In Modrica, the person's last name was Ibel and I'm not sure
9 about his first name. I think it was Zvonko.
10 In Doboj, Obren Petrovic.
11 In Derventa, I found Novak Novic there, but he was soon removed
12 and replaced by Ivan Duspara.
13 In Maglaj, Osman Rahmanovic. I believe that that was the
14 person's name.
15 In Tesanj, Semsudin Mehmedovic.
16 And in Teslic, Dusan Ismanovic [as interpreted].
17 I believe that I gave you all of their names correctly.
18 Q. Thank you. Just for the transcript, Obren Petrovic, page 14,
19 line 1, he was chief of the police station in Doboj, right?
20 A. Yes.
21 Q. And in Tesanj, the person's name was Semsudin Mehmedovic, right?
22 A. Yes.
23 Q. And in Teslic, 14, 5, the person's name is Dusan Kuzmanovic.
24 Sir, let's look at a document at tab 1; 752, document D1.
25 65 ter 00752D1. That's a Defence 65 ter, tab number 1.
1 A. Yes, I can see the document.
2 Q. Can you please describe the document for us. Just briefly. What
3 is it?
4 A. This is the regulation on internal organisation and the list of
5 positions in the Secretariat of the Interior, as it was still known, in
6 1990. That regulation was in force in 1991 when I joined as the chief of
7 the Security Services Centre.
8 Q. In other words, that was the regulation on the internal
9 organisation of the republican SUP of the Socialist Republic of
10 Bosnia-Herzegovina which was still valid, and it was still in effect at
11 the time when you were appointed the chief of the Security Services
12 Centre in Doboj, right?
13 A. Yes. And this document also provides a description of the entire
14 structure. For example, on page 59 you can see it. You see what the
15 centre is made up of, what elements went into it, and it also gives you
16 job descriptions of each of the organisational elements.
17 MR. ZECEVIC: [Interpretation] Can we please look at page 2? This
18 the page that the gentleman was referring to. I'm interested in
19 Article 59 on the following page of the same document.
20 JUDGE DELVOIE: Mr. Zecevic.
21 MR. ZECEVIC: Yeah.
22 JUDGE DELVOIE: Is this -- what strikes me in the first page is
23 that it is a proposal. It is said to be a proposal.
24 MR. ZECEVIC: Yes.
25 JUDGE DELVOIE: So shouldn't we have the final text of it? I
1 mean, is this the final text? How do we know? If it's a proposal, it
2 means that it still can be subject to changes before it becomes -- before
3 it gets into force.
4 MR. ZECEVIC: Well, Your Honours, I agree entirely with you. But
5 this is the -- the only document, unfortunately, that we have. And this
6 is dated 8th of January, 1990.
7 The witness became a chief of the CSB in April or May 1991. So
8 by that time, this -- while we were proofing the witness, he recognised
9 this -- this is just concerning the organisational structure of the CSB.
10 And that is the only reason that I'm showing this to the witness, and the
11 witness recognised during the proofing and he will testify to that, that
12 this is the situation in the organisational sense that he found when he
13 became the chief of the CSB.
14 So, therefore, we can assume that this -- in this part, this
15 proposal was accepted somewhere in the meantime between 1990 and 1991.
16 JUDGE HALL: I was about to say I am surprised that counsel for
17 the other side wasn't on their feet. Because you -- it appeared to me
18 that you were crossing the line into giving evidence, Mr. Zecevic.
19 MS. KORNER: It wasn't so much that. I don't think this is a
20 particularly important point, Your Honour. But for future reference, to
21 say with the witness with his headphones on listening to us, This is what
22 the witness will say, is not, in my judgement, a very good way of going
23 about things.
24 MR. ZECEVIC: Well, I'm sorry. I understand. I was trying to be
25 helpful. I didn't thought that this was in the point of contest between
2 MS. KORNER: It isn't, Your Honours. But nonetheless, just for
3 future reference, this is not a proper way to do it.
4 MR. ZECEVIC: I understand, and I'm sorry. [Microphone not
6 May I continue?
7 JUDGE DELVOIE: Please do.
8 MR. ZECEVIC:
9 Q. [Interpretation] Mr. Bjelosevic, what can you tell us about the
10 content of this document, in terms of the organisational scheme and
11 structure of the Security Services Centre, as you found it when you
12 joined in 1991?
13 A. When it comes to the organisational structure, this is what it
14 was. There was the public -- public security centre, which had its
15 departments. The first one was the department for the detection and
16 prevention of crime; the police department; the administrative legal and
17 personnel department; there was an anti-arson department; the department
18 for finances; and there was also the state security sector with its own
19 departments; and there was a common -- communications centre.
20 And here you can see all the elements and who was doing what. If
21 we are talking about individual departments, you see that their job
22 descriptions are also given in here.
23 Q. Mr. Bjelosevic, when you are talking about the lines of work and
24 when you listed them for us, along a certain hierarchy, did they go from
25 the lowest structure, and when I mention the lowest structure I mean
1 public security stations, up to the republican MUP. Yes or no?
2 A. Yes. And in that, the police department in the centre had the
3 role to organise and direct the work of police stations. They were not
4 order issues [as interpreted]. However, the police administration in the
5 ministry issued orders to the police in the centre. Their role was also
6 instructive and supervisory.
7 Q. Thank you. If I understood your comment properly, this document
8 which is the proposal for the regulation on internal organisation
9 reflects the organisational situation that you found upon becoming chief
10 of CSB in April and May of 1991?
11 A. Yes.
12 MR. ZECEVIC: [Interpretation] If there's no objection, I tender
13 this into evidence.
14 [Trial Chamber confers]
15 JUDGE HALL: Mr. Zecevic, there are a number of questions --
16 MR. ZECEVIC: Well --
17 JUDGE HALL: -- that --
18 MR. ZECEVIC: If I may, Your Honours, I just checked.
19 I withdraw my proposal because we actually have the -- in our law
20 library, we have the whole ... it's P850. Sorry. I'm sorry,
21 Your Honours, I interrupted you.
22 JUDGE HALL: That was the second question I was about to ask.
23 The first question is coming back to the question Judge Delvoie asked.
24 And I heard after the exchange what the witness said, but I'm still not
25 clear as to the -- what is termed a proposal, on the one hand, and what
1 he saw when he came in, on the other.
2 Could you clarify that for us, please.
3 MR. ZECEVIC:
4 Q. [Interpretation] Mr. Bjelosevic, just very briefly, please,
5 explain to us the structure that existed at the Doboj CSB at the time
6 when you became chief. If I may assist you further, please give us the
7 description of how it was divided, both within public and state security
8 lines of work and what were joined services.
9 A. As I have already said, there was the department for public
10 security and the department for state security. Each department was
11 headed by a chief.
12 The public security had the following structure: A crime
13 detection and prevention section, within which --
14 JUDGE HALL: If I might interrupt, I think I got that when the
15 witness said it initially.
16 My question is a much simpler one, and it is whether -- despite
17 the fact that we don't have, I suppose, a final version, whether,
18 although called a proposal, this is it. That's -- that's all I'm asking.
19 MR. ZECEVIC: I'm sorry, it's obviously entirely my fault.
20 The thing is that I -- I consulted -- we do have the final
21 version and it's P850. It is -- it is a document which contains the
22 actual -- the whole rule-book of the -- which was -- which was in force
23 at the time. And that is why I withdrew this -- my proposal to admit
24 this document.
25 I'm sorry, I mis -- I misinterpreted Your Honours' wish.
1 JUDGE HALL: Thank you.
2 JUDGE DELVOIE: And then a last question just to understand it.
3 It's not specifically -- but shouldn't this be an L number then, law
4 library? It's a P number.
5 [Trial Chamber and Registrar confer]
6 JUDGE DELVOIE: Okay. Thank you.
7 MR. ZECEVIC: I am -- over the break, I can provide this answer
8 because I ... I don't know at this point what is the explanation, why it
9 not L but P number.
10 JUDGE DELVOIE: The explanation seems to be that this was
11 tendered before we made an L category.
12 MR. ZECEVIC: Thank you very much.
13 Q. [Interpretation] Mr. Bjelosevic, you just enumerated public
14 security stations which were branch stations of the CSB, and you gave us
15 the names of their chiefs at the time. The only other remaining item
16 that could be relevant would be ethnic background of the chiefs.
17 So if you know this information, could you please tell us,
18 listing each SJB and the ethnic background of their chief at the time.
19 A. In Brod, Samac, Derventa, and Modrica, the chiefs were Croats, of
20 Croat background.
21 In Doboj and Teslic, the chiefs were Serbs.
22 In Tesanj, Maglaj, the chiefs were of Muslim or Bosniak ethnic
24 Q. Thank you. Mr. Bjelosevic, at the time, in 1991, how did local
25 policy-makers view your appointment as chief of the Doboj CSB?
1 A. As far as the politicians were concerned, from the very
2 beginning, I faced a sort of obstruction and disagreement with my
3 appointment to that position due to the fact that I was apolitical at the
4 time. I did not belong to any of the political parties which took part
5 in the coalition government.
6 Q. Perhaps it would be best to illustrate this by way of a document.
7 MR. ZECEVIC: [Interpretation] 65 ter of the Defence, 749D1,
8 tab 1A, please. Dated 29th of May, 1991.
9 Q. Just a minute. We're waiting for the English translation of the
11 Yes, please go ahead now.
12 A. This document was sent out to the field. As you can see in the
13 heading, it says "Regional Board," or actually, that's at the bottom of
14 the document. The Regional Board of the SDS. This document was sent to
15 a number of addressees in all municipalities within the jurisdiction of
16 the Doboj CSB.
17 Q. Tell me, please, this document was also sent to the MUP
18 headquarters and also to the Main Board of the SDS in Sarajevo, as well
19 as to the SJBs in the Doboj region?
20 A. Yes. You can see exactly to whom it was addressed in the top of
21 the document. I had some problems regarding this because -- where it
22 says here that I was not their representative and did not have their
23 support, and they were entitled to have their man in that position.
24 Q. Would you please explain this to us in a bit more detail. Who
25 was their man? Why did they formulate it in this manner?
1 Would you please give us some background information and also
2 explain the second page which is part of this document.
3 MR. ZECEVIC: [Interpretation] Could we see the second page of
4 this document in e-court, please.
5 THE WITNESS: [Interpretation] It is clear here that, among three
6 of us, three candidates for this post, the SDS had its favourite, which
7 was Milan Ninkovic. After all of the procedures were completed, and once
8 I was appointed to the post, they were displeased that their man was not
9 appointed. At the SDS meeting, they adopted this decision, and they sent
10 it to all of the addressees listed on the first page.
11 However, the minister and the others who were together with
12 Minister Delimustafic abided by their original decision. They did not
13 want to amend it. However, in my work, in my further work, I faced
14 constant problems with respect to these political structures.
15 MR. ZECEVIC:
16 Q. [Interpretation] So if I understood you well, despite this
17 intervention of the regional board of the SDS, which was sent to the
18 Ministry of the Interior of the Socialist Republic of Bosnia-Herzegovina,
19 to its headquarters, it was therefore sent to the ministry which was
20 headed at the time by Minister Alija Delimustafic, the ministry did not
21 want to amend its initial decision to appoint you as chief of the CSB,
23 A. Yes, that's correct.
24 JUDGE DELVOIE: If I may, Mr. Bjelosevic, this, let's say,
25 opposition against your appointment, was this normal procedure? Was this
1 done by the rules? Was it in the rule, the possibility that the -- that
2 this board could oppose and that the minister had -- had to reassess and
3 eventually change his appointment or keep it as it was?
4 So was it in the rules, or was this something extraordinary? Was
5 this an unusual intervention of this board?
6 THE WITNESS: [Interpretation] I think that something of this
7 nature was not set forth in the rules. However, there was a sort of a
8 political agreement among the political parties which did not have a
9 force of law or any other mandatory regulation.
10 JUDGE DELVOIE: Thank you.
11 MR. ZECEVIC:
12 Q. [Interpretation] To clarify this, Mr. Bjelosevic, is it true that
13 among national coalition parties, that is to say, the SDS, the SDA, and
14 HDZ, there was a coalition agreement reached?
15 A. Yes.
16 Q. Are you aware that there was also agreement on allocation of
17 senior positions in all state agencies and structures, including the
18 Ministry of the Interior?
19 A. Yes.
20 Q. Are you aware that this agreement also entailed the duty on the
21 part of the proposing party which was entitled, in accordance with the
22 coalition agreement, to propose a candidate, a duty to propose three
23 candidates so that the other two coalition parties would then be able to
24 give their consent to appointment of one among these three candidates?
25 A. Yes. As I have already told you, there was an inter-party
1 coalition agreement, and none of us could have been proposed for a post
2 without there being a prior political agreement regarding this, without
3 there being a prior consent for these candidates.
4 However, the parties usually had their favourite among the
5 three candidates. Mr. Ninkovic was the favourite of the party, although
6 they did consent to my candidacy and that of the third candidate.
7 However, they preferred that Milan Ninkovic be appointed. This is why
8 they sent this letter.
9 However --
10 Q. Just a moment, Mr. Bjelosevic. Let's clarify.
11 You have to be clear in your answers. When you say "the party,"
12 are you referring to the SDS? If I understood you well, the SDS, which,
13 according to the coalition agreement, was entitled to appoint the chief
14 of the Doboj CSB, they proposed three candidates. That was their
15 proposal. Was that right?
16 A. Yes, that's precisely how it was.
17 MS. KORNER: Your Honours, again, I haven't objected so far, but
18 each and every one of these questions was leading. There is not a lot of
19 dispute about this. But I would ask that Mr. Zecevic is quite careful
20 because he is actually literally putting words into the mouth of the
21 witness. It's not what the witness said at all. Mr. Zecevic said that.
22 MR. ZECEVIC: I'm sorry, I'm trying to save the time and sort of
23 direct the witness. Because the witness is obviously inexperienced in
24 giving a testimony, so that's why I'm crossing the line a bit and I'm
25 fully aware of that, but I didn't thought that this was an issue that is
2 Q. [Interpretation] Sir, as you see, we have objections from the
3 Prosecutor. So in order to avoid that, would you please explain in
4 detail how that looked in practice in the case of Doboj. How come this
5 document came about? How come you were the person appointed by the
6 minister and not the person who was the SDS favourite?
7 A. In respect of each and every post that was deemed to be
8 important, an agreement had to be reached first among the coalition
9 parties. And in this specific case, since there had been an agreement
10 reached that the right of choice for the chief in this instance lay with
11 the SDS, three candidates were put forth. Once the proposal is made, the
12 party making the choice can choose any of the three. However, the case
13 of the matter was that whenever any of the parties nominated their three
14 candidates, they would have their favourite.
15 In this particular instance, their favourite or, rather, their
16 candidate number one wasn't the one that was chosen. Rather, it was me,
17 and it was in this way that the party expressed their dissatisfaction
18 with it. You see that they sent this memo to the presidents of the
19 municipal assemblies present in the region, presidents of
20 Executive Boards, the MUP of Sarajevo, and even to the chiefs of
21 stations. In other words, individuals who were within the hierarchy
22 below the chief of CSB and the Main Board of the SDS, they were the
23 addressees. Still, the minister and whomever it was who made the choice
24 with him stuck to me as being the one from among the three candidates.
25 JUDGE DELVOIE: I'm still not clear about one detail. It all
1 starts with the inter-party agreement, and that means that the parties
2 agree upon the affiliation of the person to be appointed. It will be an
3 SDS candidate or a candidate of the Muslim party or a candidate of the
4 Croat party.
5 Is that right?
6 THE WITNESS: [Interpretation] It wasn't based on party
7 affiliations but on ethnicity.
8 JUDGE DELVOIE: On ethnicity, okay. Okay. And then the three
9 names within the ethnicity that had been chosen, were those three
10 names -- was this list made upon the agreement between the parties? Was
11 that a party agreement as well?
12 THE WITNESS: [Interpretation] What remained was the right to
13 challenge any of the candidates, if there was an underlying reason. For
14 instance, in respect of some of the functions --
15 JUDGE DELVOIE: The three -- the -- the parties had to agree on
16 the candidates, on the three persons proposed by, in this case, the SDS.
17 Is that right?
18 So what -- what I wasn't sure about was whether the three parties
19 had to be -- had to -- whether the parties had to agree on the three
20 candidates, or that it was the right of the SDS to -- to propose three
22 THE WITNESS: [Interpretation] Let me explain this more broadly.
23 Let's stick to the Security Services Centre. It was agreed
24 amongst the parties that the chief of the centre would be a Serb.
25 Specifically, the chief of the public security service in Doboj would be
1 a Muslim, and the chief of the State Security Service would be a Croat.
2 And that was the result of an inter-party agreement.
3 Now, since every party basically clung to ethnicity itself, they
4 each had the right to nominate three candidates, and they didn't have to
5 seek the agreement of the other two parties for the three candidates.
6 For instance, the SDS didn't have to seek the approval of the HDZ and the
7 SDA in respect of its three candidates.
8 JUDGE DELVOIE: So it was, in this specific case, the SDS who
9 appointed three candidates. The other parties had nothing to say about
10 that. But, still, within the three candidates, the SDS had a preference,
11 which I can understand. But then they had the right to say, We want that
12 candidate and not one of the other two. Why did they have to propose
13 three candidates then? Why not just say, That's the one.
14 THE WITNESS: [Interpretation] There was the obligation to
15 nominate at least three candidates. And there were many reasons why this
16 was insisted on.
17 JUDGE DELVOIE: Thank you.
18 MR. ZECEVIC:
19 Q. [Interpretation] Mr. Bjelosevic, did the other coalition parties
20 have the right to challenge the candidates put forth by one of the
21 coalition parties?
22 A. I don't think that they did at this level. Or for this level.
23 Q. Let me phrase the question this way.
24 Mr. Bjelosevic, when you were nominated for the post of chief of
25 CSB Doboj, did you enjoy the support of the Party of Democratic Action
1 and the HDZ?
2 A. I don't know what you -- what you mean, if I enjoyed their
4 Q. Let me clarify this. Did Alija Delimustafic, the then-minister,
5 represent the Party for Democratic Action?
6 A. Yes.
7 Q. Did Alija Delimustafic sign your candidacy?
8 A. Yes.
9 Q. Did Alija Delimustafic -- or, rather, tell me, who was in charge
10 of personnel issues within the MUP of the Socialist Republic of Bosnia
11 and Herzegovina?
12 A. Yes, there was an administration for personnel. Hilmo Selimovic
13 was the head. Later on there was a change.
14 Q. And who replaced him?
15 A. Srebrenikovic. I can't recall his first name.
16 Q. Was it Mirsad?
17 A. Possibly. An individual, at any rate, who had not been living in
18 Bosnia-Herzegovina before that point.
19 Q. Let's take it slowly, Mr. Bjelosevic.
20 Hilmo Selimovic, who was the chief of the personnel
21 administration within the MUP of the Socialist Republic of
22 Bosnia-Herzegovina, and the individual who replaced him subsequently,
23 Srebrenikovic, were both of them SDA cadres?
24 A. Yes.
25 Q. Mr. Bjelosevic, the SDS Doboj --
1 JUDGE DELVOIE: Mr. Zecevic, I'm sorry, but I am a little bit
2 confused here. Or rather, aren't you confusing political parties and
3 state authorities? The authority that has the power to nominate?
4 Because you're talking about the minister and the head of the -- the head
5 of the personnel service in the administration. And you -- you --
6 Could the witness remove his -- his headphones, please.
7 And you -- if I understand you well, you're trying to suggest
8 that this is a party challenge to the candidates proposed by the SDS. Is
9 that a party challenge?
10 MR. ZECEVIC: Your Honours --
11 JUDGE DELVOIE: That's -- that's the normal consequence of three
12 candidates proposed to the government and the government taking a
13 position, whether that government -- whether the minister is of this
14 ethnicity or that ethnicity or the head of personnel is of this ethnicity
15 or that ethnicity.
16 So I'm confused.
17 MR. ZECEVIC: But that -- that's precisely the point,
18 Your Honours, I'm trying to establish.
19 The -- according to the coalition agreement between the parties,
20 they have -- they have designated a certain system, or how it was
21 understood which party is having the right to name its own candidates for
22 a certain position within the government structures. For example, like
23 this example, the chief of the CSB of Doboj.
24 So according to the coalition agreement, it was the right of the
25 SDS. And the witness explained that -- that the system existed.
1 JUDGE DELVOIE: But the right of the SDS was to -- to nominate
2 three candidates.
3 MR. ZECEVIC: That is correct.
4 JUDGE DELVOIE: So where's the problem? It leaves a -- even in
5 that -- in that coalition agreement, it leaves -- it leaves room for
6 appreciation for the minister who has to nominate. It -- there are three
7 SDS candidates.
8 MR. ZECEVIC: Yes. Yes, there are three SDS candidates, and that
9 is sent -- the -- the system with the three was that -- the system was
10 designated with the three so as that the other parties or the -- the
11 actual minister or the -- the government authorities have the right to
12 choose. But it is -- it is also understood, at least it is my
13 understanding, that if the minister or the people who are choosing are of
14 the -- of the certain -- are the representatives of the certain party,
15 they do have, in their mind, the position of that particular party. And
16 that's what I'm trying to establish with the witness. When taking the
18 MS. KORNER: Your Honour, may I say we're taking an awful long
19 time over what seems to be a fairly simple point.
20 But I do really want to reiterate my objection. Whatever
21 Mr. Zecevic may believe is the case is not relevant. He can ask
22 non-leading questions of the witness to establish what the witness's
23 knowledge of this is, and then if he wants to call further evidence or
24 point us to what evidence there is about it, that's something different.
25 MR. ZECEVIC: Well, I'm sorry, but I was invited by Their Honours
1 to explain my position, and that is what I was doing.
2 MS. KORNER: Every question has been a leading one to the
3 witness. As it turns out, the witness isn't actually agreeing with you,
4 and it may well be that the witness doesn't have the faintest idea. And
5 if you ask it in a non-leading form, you may get an answer.
6 JUDGE DELVOIE: My impression, Mr. Zecevic, was that the witness
7 clearly said that there was no possibility to challenge the -- the --
8 within the three names, possibility for the other parties to challenge
9 the candidates.
10 MR. ZECEVIC: Well, I will -- I will give my explanation at the
11 end, I guess. Otherwise, it would be -- it would be -- there would be an
12 opposition from the Office of the Prosecutor. But there is a very clear
13 answer to that, Your Honour.
14 May I continue --
15 JUDGE HALL: Mr. Zecevic, is this a convenient point to take the
17 MR. ZECEVIC: Yes. Thank you very much.
18 JUDGE HALL: We will continue afterwards.
19 We would resume in 20 minutes.
20 [The witness stands down]
21 --- Recess taken at 10.26 a.m.
22 --- On resuming at 10.57 a.m.
23 [The witness takes the stand]
24 JUDGE HALL: Yes, Mr. Zecevic, you may continue.
25 MR. ZECEVIC: Thank you very much, Your Honours.
1 Q. [Interpretation] Mr. Bjelosevic, who was it who ultimately signed
2 your appointment to the chief of CSB Doboj?
3 A. The then-minister, Alija Delimustafic.
4 Q. Thank you.
5 MR. ZECEVIC: [Interpretation] If there are no objections, I wish
6 to tender the document into evidence.
7 MS. KORNER: No objections, Your Honours. But could I just ask,
8 is this a document that was provided by Mr. Bjelosevic to the Defence?
9 MR. ZECEVIC: Yes.
10 MS. KORNER: Thank you.
11 JUDGE HALL: Admitted and marked.
12 THE REGISTRAR: Exhibit 1D435, Your Honours.
13 MR. ZECEVIC:
14 Q. [Interpretation] Mr. Bjelosevic, we touched upon the structure of
15 the MUP of the Socialist Republic of Bosnia-Herzegovina only briefly, and
16 that at the time when you became the chief of CSB Doboj.
17 MR. ZECEVIC: [Interpretation] Can we have P875?
18 Q. And I'll ask you to give us your comments.
19 MR. ZECEVIC: [Interpretation] Could the Usher please assist me in
20 giving the witness my folder to have a look.
21 Can we please see it on the monitor, the whole breadth of it.
22 Q. Mr. Bjelosevic, can you give us your comments on this organigram
23 of the MUP of the Socialist Republic of Bosnia-Herzegovina in the period
24 between January 1991 and March 1992 that you have before you?
25 A. I see this organigram from the minister down to assistant
1 ministers to the various territorial units, including public security
2 stations within the centres.
3 Q. Can you see the names of assistant ministers who are divided up
4 by their line of work? And can you confirm that this was, indeed, the
5 case at the time, that these were the individuals who held these posts?
6 A. Yes. Alija Delimustafic was minister at the time. His assistant
7 was Zepinic, as is reflected here, indeed. And then -- or, rather, his
8 deputy was Zepinic. And then from assistants, yes, I do recognise these
9 names, and I would say that this was, indeed, the case.
10 Q. Thank you. Mr. Bjelosevic, can you explain to us what sort of
11 situation existed on the ground when, in late April/early May, you took
12 up the position of chief of the CSB Doboj?
13 A. In terms of organisation, the situation reflected this
14 organigram. That's what it looked like. There was some change in the
15 personnel at the time, but this was the result of previous agreements.
16 However, as early as in 1991, there was a very complex security
17 situation in the then-Yugoslavia, primarily because of the war in Croatia
18 which began in early May, and with that conflict spreading. There
19 emerged a wave of refugees in Croatia who were moving to our region, and
20 when I say "to our region," I mean the Bijeljina [as interpreted] area.
21 There were quite a few refugees arriving from Western Slavonia,
22 specifically Grubisno Polje. Some of the refugees stayed in the region
23 and others headed onto Serbia or, rather, Yugoslavia. Well, it was all
24 Yugoslavia at the time.
25 Q. Here, at page 33, line 9, it says: "When I say 'our region,' I
1 mean the Bijeljina region."
2 A. I said Doboj.
3 Q. Yes, that's what I wanted to correct on the transcript.
4 Can you tell us what was the ethnicity of the refugees you were
5 referring to?
6 A. The refugees arriving in the Doboj area were Serbs. There were
7 some Croats among them, but most of them were Serbs.
8 Q. Go ahead, please.
9 A. Another issue that was typical for that period of time was that
10 quite a few individuals went from Bosnia-Herzegovina to the Croatian
11 front line. This was also a cause of interethnic mistrust. Quite often
12 it would so happen that members of all sorts of formations would come
13 back from Croatia to their home areas in the Doboj region. They would
14 come wearing uniforms, and they would often carry weapons as well.
15 Fear was widespread among the population. In some places, there
16 were instances of sabotage taking place. In particular, the bridge on
17 the Vijaka river, between Derventa and Prnjavor, was blown up. This took
18 place in September, sometime in September. It was a long time ago; I
19 can't remember exactly. But I do believe it was in September.
20 Q. When say September, what year do have you in mind?
21 A. 1991. This caused some distress among the citizens in the area.
22 And I know that very soon after that, the first guards appeared on the
23 bridge across the Ukrina river because people feared for the safety of
24 that bridge. They feared that it might be blown up as well, and that's
25 why they guarded it at night.
1 The position of that bridge is between the villages of Strpci and
2 Detlak, near the fish pond.
3 Q. When you say guards, what guards do you mean?
4 A. I mean village guards. People who simply organised themselves,
5 they took weapons that they had to hand, and they stood guard on both
6 sides of the bridge.
7 Q. Sir, Mr. Bjelosevic, at that time, and I mean September 1991,
8 were there any onslaughts by armed forces from the territory of Croatia?
9 A. In September, if my memory serves me well, I believe it was on
10 the 15th of September, 1991, an attack was launched at the barracks in
11 Slavonski Brod, and that is across the river Sava from -- across
12 Bosanski Brod, and during the state of Yugoslavia, Slavonski and
13 Bosanski Brod functioned as one whole, as one unity.
14 In the evening hours, that clash escalated into a proper armed
15 combat. From the Slavonian side, fire was opened across the river
16 towards the right bank, towards Bosanski Brod, primarily an engineering
17 point of the Yugoslav People's Army that was there. And after that,
18 there was mortar fire of a higher calibre, targeting the villages of
19 Gisca [phoen], Klakar, both of them in the territory of Bosanski Brod
20 municipality. At the Klakar brick-works we also had a victim, if I
21 remember it properly. That person was an engineer. His name was
22 Goranovic; I can't remember his first name, though. He was killed on
23 that occasion.
24 Q. Sir, you have to explain what you said on page 35.
25 THE INTERPRETER: And the microphone is not on.
1 MR. ZECEVIC:
2 Q. [Interpretation] On page 35, 1 and 2, can you explain what you
3 said on that page? And I mean the situation involving Slavonski and
4 Bosanski Brod settlements. You said that in the former Yugoslavia those
5 two settlements functioned as one whole. Can you please explained
6 geographical location of those two places, and what did you mean when you
7 say that? It is not very clear in the transcript.
8 A. When I said that they functioned as one whole, I mean the
9 organisation of health care in these two cities, I mean the education
10 system, as well as the economy, of course.
11 To this very day, this is an oil refinery in Bosanski Brod. Back
12 then, about 800 people who worked in the refinery were from
13 Slavonski Brod. In Slavonski Brod, there was a large factory whose name
14 was Djuro Djakovic. It was a large industrial complex. A lot of people
15 from Bosanski Brod commuted to Slavonski Brod and worked in that
16 industrial complex.
17 The hospital and all other health care institutions are funded --
18 were funded jointly by Bosanski and Slavonski Brod. Bosanski Brod didn't
19 even have a maternity ward. That's what I meant when I said that the two
20 cities functioned as one whole.
21 Q. In fact, those were two cities in two different republics
22 separated by a river, right?
23 A. Yes, right.
24 Q. Sir, could you please look at document 117 -- or, rather, that's
25 tab 117. 65 ter 758D1.
1 JUDGE DELVOIE: Mr. Zecevic, before we go to that one.
2 Mr. Bjelosevic, a few minutes ago you said that it would happen that
3 members of all sorts of formations would come back from the -- from
4 Croatia, the Croatian front, I suppose, to their homes, to their home
5 areas in the Doboj region. They would come wearing uniforms and they
6 would often carry weapons. They would come wearing uniforms and all
7 different sort of formations, you said. Am I correct by the taking that,
8 generally, the uniforms were JNA uniforms? Or would that be other
9 uniforms as well?
10 THE WITNESS: [Interpretation] Of course, some wore JNA uniforms,
11 those who belonged to JNA units. However, what I meant here were
12 primarily members of the Croatian National Guards, the HOS units from
13 Croatia, and other units that had been established there. People from
14 Doboj region went and joined those units as volunteers. Therefore, the
15 situation was such that we had members of the JNA as the regular military
16 of Yugoslavia at the time, and, other hand, there are also members of
17 those paramilitary units from Croatia who had returned in uniforms, often
18 carrying weapons, and they would come back to our region. And that had
19 quite a strong impact on creating distrust among ethnic groups and
20 instilling fear among people. There were armed components from Croatia
21 which clashed with the JNA in our immediate vicinity. Fear was rife and
22 there was a lot of mistrust as a result of that.
23 JUDGE DELVOIE: That's an important clarification. I understand
24 now that there were people from both sides fighting at the Croatian front
25 in the same area in Doboj. Thank you.
1 MR. ZECEVIC: Thank you, Your Honour.
2 Q. [Interpretation] Mr. Bjelosevic, before we look at the document
3 that I have just called up, and before I invite your comments, let me ask
4 you this: Which of the municipalities in your region bordered on the
5 Republic of Croatia?
6 A. Bosanski Brod, Odzak, Samac, and Derventa, partially.
7 Q. So it was just the river Sava that separated those municipalities
8 from the Republic of Croatia?
9 A. Yes.
10 Q. Thank you.
11 MR. ZECEVIC: [Interpretation] 758D1 is the document that I would
12 like to call up now.
13 Q. Sir, could you please comment on this document. The title is
14 report. The date is 14 September 1991, issued by the public security
15 station in Bosanski Samac. The signatory is a certain Djordje Tesic. Do
16 you know him?
17 A. Yes.
18 MR. ZECEVIC: I'm sorry, I said tab number 117.
19 Q. [Interpretation] Can you tell us something about this document,
20 please, and about this case as well.
21 A. Yes. I remember the incident. That was precisely one of those
22 events that involved members of those formations who had arrived in
23 Bosanski Samac. The police went to the place of the incident. As you
24 can see from the document, they brought those armed men in. However, no
25 criminal reports were ever filed. There was no prosecution against those
2 As you can see in the document, the reason was that the chief of
3 the police station in Bosanski Samac, Vinko Dragicevic, ordered that the
4 individuals had their weapons returned and that they were released.
5 Later on, that incident kept on being commented in town. It also
6 instilled a certain degree of fear and mistrust, even among the members
7 of the public security station.
8 Q. Thank you very much. We will come back to that situation in
9 Samac. We will revisit that.
10 MR. ZECEVIC: [Interpretation] If there are no objections, I would
11 like to tender this document. It is 65 ter -- it has been misrecorded.
12 65 ter 758D1. I would like to tender this document into evidence,
14 MS. KORNER: Can I just ask, is this a document given by the
16 MR. ZECEVIC: [Interpretation] Yes.
17 MS. KORNER: Thank you.
18 JUDGE HALL: Although I heard what the witness -- if I understood
19 him correctly, that this incident formed the background to later comments
20 that were made, I'm still not sure that I see how it assists,
21 Mr. Zecevic. Could you assist me, please.
22 MR. ZECEVIC: Well, this is precisely in relation to the -- to
23 the answer that the witness gave to His Honour Judge Delvoie's question,
24 about the -- the incidents created by people -- the members of the units
25 from Croatia who came to the territory of -- of the region of Doboj and
1 the CSB of Doboj, and the problems that that fact caused in the -- in the
2 territory. That is precisely the document that confirms that situation.
3 [Trial Chamber confers]
4 JUDGE HALL: Admitted and marked.
5 THE REGISTRAR: Exhibit 1D436, Your Honours.
6 MR. ZECEVIC: Thank you.
7 [Interpretation] Can we look at the document under tab 2. 1D253,
8 tab 2.
9 Q. Mr. Bjelosevic, this is a dispatch already in evidence. You
10 signed this dispatch, and you sent it out on the 16th of September, 1991.
11 It was delivered to the Ministry of the Interior of the Socialist
12 Republic of to Bosnia-Herzegovina to the minister and deputy minister.
13 What do you remember about the dispatch and its contents?
14 A. Well, this is information about that armed incident. Or, rather,
15 about the armed conflict that had taken place on the 15th of September.
16 On the following day, we set up an investigation team. They went
17 to inspect the place. They carried out an on-site inspection. They
18 found mortar shell craters around the water works in Bosanski Brod, in
19 Lijesce and around the Klakar brick-works.
20 In the evening, on the day when the incident had taken place, and
21 the incident was a major event, I spent some time in Bosanski Brod
22 myself. I experienced the incident first-hand. I experienced fire being
23 opened from all sorts of weapons. I dare say that that was already an
24 attempt to transfer the armed conflict that had been taking place in
25 Croatia into the territory of Bosnia and Herzegovina.
1 Q. Tell me, please, this conflict that erupted on the
2 15th of September, 1991, was it the first such serious conflict in your
3 area or not?
4 A. It was the first serious conflict.
5 MR. ZECEVIC: [Interpretation] Could the witness be shown
6 65 ter 760D1, tab 4, please.
7 Q. Mr. Bjelosevic, what was the impact of this conflict of
8 15th September in Bosanski Brod and in the entire region?
9 A. The Croatian side, from that time on, blocked the bridge. The
10 bridge was mined and a check-point was established on the Croatian side
11 in Slavonia. It wasn't allowed to have anybody cross from Bosanski Brod
12 into Slavonski Brod, anybody without their passes. When I say "their,"
13 I'm referring to those from Slavonski Brod. This meant that people from
14 Bosanski Brod could not go to Slavonski Brod to work there. However, the
15 people from Slavonski Brod could cross over and come into Bosanski Brod.
16 They could go to the refinery, to their work there.
17 As a result of this ban on crossing from Bosanski Brod to
18 Slavonski Brod, a lot of people were fired from their jobs, and
19 consequently a protest was organised. The demands that people voiced
20 during that protest meeting were quite clear. They wanted reciprocal
21 measures to be introduced; that is to say, they either wanted that
22 everybody be allowed to use the bridge, all citizens of Bosanski Brod and
23 Slavonski Brod, or that the bridge be closed off for everyone. This is
24 why I sent a dispatch regarding this to the prime minister of Bosnia and
25 Herzegovina, as well as to the deputy prime minister for internal policy,
1 as well as to the minister and deputy minister. I believe this to be an
2 important incident with serious consequences for the citizens of Bosnia
3 and Herzegovina and the citizens of Bosanski Brod, and I also thought
4 that I needed to provide first-hand information to the government of
5 Bosnia and Herzegovina as well.
6 Q. Sir, this is what this dispatch of yours is about. The dispatch
7 of the 30th of September, 1991, that we can see on the screens now,
9 A. Yes.
10 MR. ZECEVIC: [Interpretation] If there are no objections, I
11 tender this into evidence.
12 MS. KORNER: I'm assuming, Your Honours, unless otherwise stated,
13 that all of these documents come from the witness; is that right?
14 MR. ZECEVIC: Well, not all of them, but this one does.
15 MS. KORNER: Yes. Thank you.
16 JUDGE HALL: Admitted and marked.
17 THE REGISTRAR: Exhibit 1D437, Your Honours.
18 MR. ZECEVIC:
19 Q. [Interpretation] Sir, I will now show you 65 ter 759D1, tab 3.
20 And I would like you to comment on it.
21 Could you please explain this document to us and tell us, if you
22 remember, what prompted Minister Delimustafic to send this dispatch.
23 What was the event?
24 A. I remember this dispatch. I think that it was written, inter
25 alia, due to the conduct of the chief of the station in Brod, in
1 Bosanski Brod. There was some information indicating that when it came
2 to this incident, it was first the Crisis Staff and the police
3 administration in Slavonski Brod that were informed about it, and only
4 subsequently and in a limited volume was the information sent to the MUP
5 in Sarajevo and to the centre.
6 Q. Let's clarify this. When you say "information," are you
7 referring to the information from the Bosanski Brod SJB, from the Bosnian
8 side which was subordinated to you, the Doboj centre. Is that -- is that
9 what you're referring to?
10 A. Yes. And, later on, I learned that there was a special telephone
11 line set up, of which we knew nothing at the time. The telephone line
12 between the police administration in Slavonski Brod and the SJB station
13 in Bosanski Brod.
14 JUDGE DELVOIE: Mr. Zecevic, just one moment.
15 Your previous question - let's clarify this - and the answer, is
16 that to say that the transcript of the previous answer is wrong, where it
17 is referred to Slavonski Brod and not to Bosanski Brod?
18 MR. ZECEVIC: Well, that is precisely why I wanted to clarify
19 that, because I see that there is some --
20 JUDGE DELVOIE: There was some -- something illogical --
21 MR. ZECEVIC: -- some problems in understanding.
22 JUDGE DELVOIE: So the reference to Slavonski Brod is not
23 correct. It was not that this information was first sent to the -- to
24 the Crisis Staff and the police administration in Slavonski Brod.
25 That's --
1 MR. ZECEVIC: No, that is correct. Sorry --
2 JUDGE DELVOIE: That's not correct, Mr. Witness, if I understand
3 the next answer correctly.
4 THE WITNESS: [Interpretation] That is correct. I said and I will
5 repeat, that the chief of the public security station in Bosanski Brod
6 first got in touch and sent information to Slavonski Brod, to the police
7 administration in Slavonski Brod.
8 MS. KORNER: [Microphone not activated] ... demonstration, I
9 think, of please, please, let the witness answer the questions and not
11 MR. ZECEVIC: I'm sorry, when I said "correct," I meant that the
12 witness's answer was correctly recorded.
13 JUDGE DELVOIE: Okay. Thank you.
14 MR. ZECEVIC:
15 Q. [Interpretation] Mr. Bjelosevic, please, you have to understand
16 that we, including myself, are not very familiar with the situation you
17 are describing.
18 Is it true that Slavonski Brod is in the Republic of Croatia?
19 A. Yes.
20 Q. And Bosanski Brod is a town in the Republic of Bosnia and
22 A. Yes.
23 Q. Was your reply that the chief of police in Bosanski Brod - that
24 is to say, a town in Bosnia - first informed the Crisis Staff of the town
25 in Croatia and their police administration before informing the MUP of
1 Bosnia and Herzegovina? Was that what you said?
2 A. Yes, that was my answer.
3 JUDGE HARHOFF: What was the purpose of this call to
4 Slavonski Brod?
5 THE WITNESS: [Interpretation] The chief of the police station
6 relied on Slavonski Brod outside of the rules and contrary to the
7 hierarchy, outside of the hierarchy. Simply speaking, he slowly was
8 turning himself in the direction of Slavonski Brod.
9 JUDGE HARHOFF: But if I understand it correctly, the attack came
10 from the Croatian side.
11 THE WITNESS: [Interpretation] Yes.
12 JUDGE HARHOFF: So when the chief of SJB in Bosanski Brod called
13 his colleague on the other side, was that to stop the attack or ...
14 why -- what was the purpose of the call?
15 THE WITNESS: [Interpretation] At that time, there already existed
16 a certain amount of co-ordination, and there were plans between certain
17 people in the Bosanski Brod police station and the police administration
18 in Slavonski Brod. That is to say, there was a parallel structure.
19 JUDGE HARHOFF: And what were these plans about?
20 THE WITNESS: [Interpretation] Well, later on, it will be
21 implemented, in a way. That is to say, that Croatian forces, with the
22 assistance of certain paramilitary forces from Bosanski Brod, would
23 occupy the SJB in Bosanski Brod, all key positions in Bosanski Brod, and,
24 later on, the wider area of the territory of Bosnian Posavina.
25 JUDGE HARHOFF: So am I right to conclude that -- that the
1 communication between the two SJBs on each side of the river was really
2 designed to have the chief of the SJB on the Bosnian side in
3 Bosanski Brod, to facilitate the attack and the possible subsequent
4 takeover of Bosanski Brod by forces from Croatia. Is that how it was?
5 THE WITNESS: [Interpretation] That's correct, Your Honour.
6 JUDGE HARHOFF: Thank you. This wasn't at all clear to me,
7 but ... thank you.
8 MS. KORNER: Your Honours, may I just raise something about this
9 whole line of -- and perhaps the witness should take off his earphones
10 for a moment.
11 JUDGE HALL: Yes, please ...
12 MS. KORNER: Thank you.
13 Your Honours, I haven't stopped this so far, but at the moment
14 I'm not clear at all how -- how this is relevant to the issues which
15 Your Honours have to deal with.
16 Your Honours, I don't certainly want to have spend any time
17 dealing with this area of the conflict which is not part of our
18 indictment, and, of course, what you're getting, not surprisingly, is one
19 side of it. And I could spend, clearly, if I wanted to, and I fully
20 appreciate that, in cross-examination, time dealing with the other aspect
21 of this part of the conflict. But it seems to me at the moment I'm not
22 clear how that is going to assist Your Honours in any way in arriving at
23 a decision on the events which are related to this indictment.
24 I merely raise it at this stage. If Your Honours feel that, you
25 know, this is helpful, then I will sit down. But, at the moment, I'm
1 saying the relevance to the issues which Your Honours have to deal with
2 is not clear to me.
3 MR. ZECEVIC: May I?
4 [Interpretation] Your Honours ...
5 MS. KORNER: [Microphone not activated]
6 MR. ZECEVIC: [Interpretation] Well, yes.
7 [In English] Okay. I will speak in English.
8 MS. KORNER: It is obviously -- and I'm afraid I forgot about
9 that. His microphone -- he can hear through the earphones even when
10 they're like that. They're turned up quite loud. I'd forgotten that.
11 MR. ZECEVIC: Your Honours, I --
12 Your Honours, I didn't -- I didn't plan to use this much time
13 before on -- on this. I think this is significant because this is the
14 first really serious armed conflict that happened in the territory of the
15 CSB where -- where our witness was chief of the CSB, and this is the last
16 document I have on that, and I don't have any more questions. Because
17 this is how I'm bringing you to the context of what is happening and what
18 repercussions this incident had on the -- on the structure of the CSB
19 which is, of course, very relevant for the -- for the case.
20 JUDGE HALL: I think I follow that, Mr. Zecevic. Thank you.
21 MR. ZECEVIC: Thank you very much.
22 Q. [Interpretation] Can you hear interpretation? Fine.
23 You've explained to us that the order which we have before us is
24 the response from the Ministry of the Interior of the Socialist Republic
25 of Bosnia-Herzegovina to what happened; is that right?
1 A. Yes.
2 MR. ZECEVIC: [Interpretation] Well, if there is no objection to
3 the document, I would like to have it admitted.
4 JUDGE HALL: Admitted and marked.
5 THE REGISTRAR: Exhibit 1D438, Your Honours.
6 MR. ZECEVIC:
7 Q. [Interpretation] Mr. Bjelosevic, following these events in
8 September 1991, what sort of bearing did these events and the general
9 atmosphere have on the workings of the CSB Doboj, in terms of their
10 dealings with public security stations?
11 A. It was already at this time that the system began collapsing, if
12 I may say so; the system of management and the hierarchy itself within
13 the MUP. Certain paramilitary formations came into being already at this
14 time in our regions, and, as a result, there was fear, there was growing
15 fear, and there was also a growing mistrust between the various
17 There was a sort of differentiation which was occurring on the
18 ground and becoming ever more serious. In retrospect, it seems to me
19 that the state of Bosnia-Herzegovina failed to respond properly to this
21 Q. What I'd like to know is: What sort of consequences, if any, the
22 situation had for the functioning of CSB Doboj? And I mean in
23 professional terms.
24 A. Well, negative consequences, by all means. The subordination
25 system, the reporting system that existed within it began to collapse.
1 It was disrupted.
2 Q. When you say "negative consequences," and the information or
3 reporting system that you mention, was this the only aspect of it that
4 you could experience within the CSB or was there more to it than that?
5 A. Well, if we look at the situation as it existed in the field,
6 that was the extent of it. But if we look at it more broadly, and if we
7 look at what sort of relations there existed between the ministry and the
8 centre, as well as the stations that were present within the centre,
9 that's where things get even more complicated.
10 Some of the stations would establish direct communication with
11 the personnel administration where it came to personnel issues. Some of
12 the chiefs of stations were appointed in violation of some of the
13 regulations envisaged under the state administration law. Gradually, it
14 all gained the hallmarks of a shadow, parallel, system which caused the
15 entire system to be undermined.
16 Q. Let me ask you specifically: You, as the chief of CSB, were you,
17 under the rules of service and under the law, supposed to be informed of
18 the appointments made to the various posts within the stations in your
20 A. Yes. That's what the standard procedure was like.
21 Q. Were you informed and consulted of these issues; and, if so, can
22 you give us specific examples?
23 A. No, I wasn't consulted on these issues. And I can give you an
24 example of that.
25 Q. Please go ahead.
1 A. The appointment of the chief of public security station in
2 Derventa, for instance, where Ivan Duspara was appointed chief, an
3 individual who did not meet the requirements under the -- prescribed
4 under the state administration law where it came to his educational
5 background and the requisite qualifications. At a later stage, he would
6 directly apply to the personnel administration, visit there, and bring
7 along the decisions on the assignment of policemen to various areas
8 without applying the standard procedure which was that the administration
9 was supposed to be contacted via the CSB. He would, instead, go directly
10 to the personnel administration with all the relevant documentation.
11 Q. Tell me, did you inform the Ministry of the Interior of the
12 Socialist Republic of Bosnia and Herzegovina of such occurrences? Did
13 you intervene in that sense?
14 A. Of course I did. I even asked for Mr. Duspara to step down after
15 he was appointed, precisely by stating all these underlying reasons. But
16 there were other examples, such as the one involving the deputy chief of
17 state administration in Doboj, where, again, the standard procedure was
18 not applied. So I drew their attention to this as well.
19 MR. ZECEVIC: [Interpretation] Can we have a look at 65 ter 764D1.
20 JUDGE DELVOIE: Mr. Zecevic.
21 MR. ZECEVIC: Yes.
22 JUDGE DELVOIE: Mr. Bjelosevic, Mr. Zecevic's question was, a few
23 minutes ago:
24 "Let me ask you specifically: You, as the chief of CSB, were
25 you, under the rule of service and under the law, supposed to be informed
1 of the appointments made to the various posts within the stations in your
3 The question was informed. You said yes.
4 And then the discussion went on, not only to the point to know
5 whether you were informed but also to the point to know whether you were
7 So my question is: Under the rule of law, was there an
8 obligation to consult you or only to inform you after appointment? To
9 consult you before the appointment; or to inform you after appointment?
10 Or both.
11 THE WITNESS: [Interpretation] Under the Law on State
12 Administration, the degree and profile of professional qualifications for
13 each and every post was provided. This was further explored through
14 various rule-books, which set out the procedure under which, for
15 instance, the chief of CSB was to be appointed, or the chief of public or
16 state security sectors.
17 In these two cases that I referred to, both the Law on State
18 Administration was broken and -- or, rather, because the requirement for
19 the post of chief of CSB was that of post-secondary school degree. This
20 wasn't met. And this was also a violation of the procedure that was in
21 place which made it incumbent on them to consult --
22 JUDGE DELVOIE: To consult. Go on.
23 THE WITNESS: [Interpretation] To consult and to send the proposal
24 or the candidacy once it's been agreed upon, to be sent to the ministry
25 from the CSB, and this wasn't done.
1 JUDGE DELVOIE: My very specific question was: According to the
2 rules, did you, as CSB chief, have to be consulted before a chief of SJB
3 was appointed in your area?
4 THE WITNESS: [Interpretation] I was supposed to be consulted, and
5 under the rule-book, it was the CSB that was supposed to send out the
6 proposal to the personnel administration of the Ministry of the Interior.
7 JUDGE DELVOIE: Thank you.
8 MR. ZECEVIC: Just for the record, I said "consulted" in the
9 first place but it was -- it was -- it was translated -- interpreted as
10 "informed." But never mind.
11 Q. [Interpretation] Mr. Bjelosevic, let us clarify this. Did you,
12 or did the chief of CSB submit the official proposal to the ministry for
13 appointments to chiefs -- to the posts of chiefs of SJBs as provided for
14 under the rules and regulations of the former Socialist Republic of
15 Bosnia and Herzegovina?
16 A. Well, in these instant cases, that's not how it happened and it
17 should have, indeed, happened in such way that these proposals would go
18 out -- would be submitted from the centre.
19 Q. So, under the rules, it should have been done this way; but, in
20 reality, it wasn't.
21 A. Yes.
22 Q. Was this the reason why you intervened?
23 A. Yes.
24 MR. ZECEVIC: I see the time, Your Honours. Maybe this is the
25 proper time to break.
1 JUDGE HALL: Yes. We would return in 20 minutes.
2 [The witness stands down]
3 --- Recess taken at 12.05 p.m.
4 --- On resuming at 12.28 p.m.
5 [The witness takes the stand]
6 JUDGE HALL: Please continue, Mr. Zecevic.
7 MR. ZECEVIC: Thank you, Your Honours.
8 I requested a document, 764D1. It's tab 7.
9 Q. [Interpretation] Mr. Bjelosevic, before you is a document dated
10 the 24th of October, 1991. And I think that you signed it. Can we have
11 your comments on the document? What's it about?
12 It's behind tab 7 of your binder.
13 A. This is precisely my response to the violation of regulations and
14 procedures where change in personnel was concerned. That's precisely
15 what we were discussing a moment ago. These are the issues that
16 undermined the very system of work. You see that there are instances of
17 direct communication contrary to the laws and procedures in place, as
18 well as appointments, et cetera. And the consequences are clear.
19 Q. Is this your memo?
20 A. Yes.
21 Q. And who was it sent to, who was it addressed to?
22 A. To the minister of the interior and his deputy.
23 Q. Thank you.
24 MR. ZECEVIC: [Interpretation] If there no objections, I would
25 like to have this document admitted, please.
1 JUDGE HALL: Mr. Zecevic, how does this assist?
2 MR. ZECEVIC: Well, Your Honour, the witness -- the last
3 15 minutes of the previous session we were talking about the situation in
4 the SJB and the actual non-compliance with the laws at the time on
5 appointments of the chiefs of the SJB.
6 The witness said he informed and was protesting that with the MUP
7 of SRBiH and here is the document that confirms that.
8 JUDGE HALL: So this supports the fact that he complained.
9 MR. ZECEVIC: Yes.
10 JUDGE HALL: That's your purpose.
11 MR. ZECEVIC: Yes, that's what the witness said: I filed a
12 complaint and this is the actual document.
13 JUDGE HALL: Yes. Admitted and marked.
14 THE REGISTRAR: Exhibit 1D439, Your Honours.
15 MR. ZECEVIC: Thank you.
16 Q. [Interpretation] Mr. Bjelosevic, what was the security-related
17 situation like in the area covered by the centre in the course of
18 autumn 1991, if you can tell us briefly.
19 A. It was very complex. As of roughly the month of September,
20 things grew gradually worse, due to the events we discussed; various
21 instances of sabotage, the bridge being destroyed, conflicts between the
22 forces of the National Guard Corps and the army, and the spilling over of
23 these conflicts to the territory of Bosnia-Herzegovina, the emergence of
24 paramilitary forces in our area as well, the arming and organising of
25 paramilitary structures.
1 Naturally, all this made up for a very complex security
2 situation. To confirm that this was, indeed, the case, we have the
3 statement by Sefer Halilovic, who was the first commander of the staff of
4 the BH army, who confirmed, in one of the interviews he gave for the
5 BH TV, that as of September, October, and by early November, around
6 60 per cent of the work surrounding the formation of these units had
7 already been completed. We took notice of that, and the MUP, both along
8 its public and state lines, was being notified of it, but the situation
9 grew increasingly complicated.
10 Q. When you say the statement given for the television, was this
11 something that you yourself saw or heard?
12 A. Yes.
13 Q. When was it?
14 A. Sometime in June 2009, I believe. He was explaining how things
15 were happening, what the objective was, how they frequently changed the
16 location of their staff, precisely in order to maintain the secrecy of
17 the exercise, and we -- those of us who were out in the field were aware
18 of these events.
19 However, we had -- we didn't have the power to confront it,
20 because by then it had gained momentum.
21 Q. When you say, Mr. Bjelosevic, "we were aware," does it mean that
22 you were aware of the situation back in 1992?
23 A. Yes. We knew back then, thanks to the information we had from
24 the state security sector, and we also had some information that we
25 received from the JNA. We exchanged information. And what happened next
1 confirmed that these sentiments were more or less true.
2 MS. KORNER: Your Honours, I'm sorry to interrupt, but I'm
3 getting slightly confused about the dates. I think there's an error,
4 certainly, in line 25 of page 54, which reads: "Sometime in June 2009."
5 And Mr. Zecevic has just asked: "Were you aware of the situation back in
6 1992?" I thought it was 1991 we were talking about. But, in any event
7 that line 25 must clearly not -- is clearly not right.
8 MR. ZECEVIC: Well, I can ask the witness again.
9 Q. [Interpretation] Sir, when did you hear Sefer Halilovic's
10 statement on BH television, as you put it, and which period did it refer
12 A. It was on the 2nd of June, 2009, that Sefer Halilovic made the
13 statement in a TV show.
14 Q. Very well. So that was in 2009. But it referred to the
15 situation as it prevailed in 1991; is that right?
16 A. Yes.
17 Q. Thank you. Tell us, Mr. Bjelosevic, what sort of measures did
18 the MUP and CSB take in the course of 1991, in view of the highly complex
19 security situation? And were any measures taken at all?
20 A. In view of the complex situation and developments at the time, we
21 were under the obligation to inform the ministry headquarters of all
22 these events, and we did as much. So it went beyond the usual reporting
23 of crime which follow falls under the purview of either a station or a
25 Q. Mr. Bjelosevic, did you take any specific measures; and, if so,
2 A. We informed the ministry of everything.
3 Q. Mr. Bjelosevic, in autumn of 1991, did you set up check-points at
5 A. This was an activity that had been agreed with the
6 Federal Secretariat for National Defence of Yugoslavia and the
7 Ministry of the Interior of Bosnia-Herzegovina. Certain check-points
8 were set up at key intersections and on the points of entry into
9 Bosnia-Herzegovina. The check-points were manned by mixed personnel,
10 meaning civilian and military police.
11 Q. Can you tell us what sort of activity was going on at these
12 check-points? What were their duties?
13 A. Well, the task was precisely to heighten the control of movement
14 of paramilitary formations, of arms smuggling, illegal arming, foreign
15 currency smuggling, and any activities that had the hallmarks of
16 subversive activities or sabotage.
17 Q. Can you tell us which specific measures did members of the
18 Ministry of the Interior of the Socialist Republic of Bosnia-Herzegovina
19 apply at these check-points?
20 A. Their activity was regulated by instructions, and the military
21 police had the control over military and paramilitary personnel; whereas,
22 members of the MUP controlled vehicles, whether they were stolen vehicles
23 or not, and did all the other policing duties within the MUP purview.
24 Q. Mr. Bjelosevic, I'm asking you very specifically what measures
25 were taken. Do you know or do you not know what measures were taken?
1 A. Illegal cars were confiscated, people were brought in and so on
2 and so forth.
3 Q. Mr. Bjelosevic, did you check the IDs of people who passed
4 through those check-points?
5 A. Yes. We controlled car papers, and we checked people's IDs when
6 we deemed necessary.
7 Q. Did you search the vehicles?
8 A. Yes.
9 Q. Were such activities taking place in the entire territory of
10 Bosnia-Herzegovina, if you know?
11 A. Yes. In the entire territory. On main roads, cross-roads, and
12 at the entry points into Bosnia-Herzegovina.
13 Q. Do you know if that action had its name, as it were, or a title?
14 A. I believe that the name of the action was Check-point 91, or
15 Point 91, if I remember it well.
16 Q. And can you please repeat about that action, Point 91, which
17 members and of which services and organs participated in that action
18 known as Point 91?
19 A. The Federal Secretariat for Internal Affairs of Yugoslavia, the
20 Ministry of Interior of Bosnia and Herzegovina, and JNA members.
21 If I may add, that we, on the ground, received a letter from the
22 Ministry of the Interior of Bosnia and Herzegovina. That letter was
23 signed by the minister, and in that letter, he informed us that that
24 action or that activity would be taking place, and he also told us that
25 we should provide assistance and information to the inspectors from the
1 federal SUP.
2 Q. And now can you please look at a document 65 ter D766, or D1,
3 that's under tab 9. 766D1. Tab 9.
4 A. Yes, this is information drafted by the Ministry of the Interior
5 of Bosnia and Herzegovina, reporting the results that were achieved in
6 the Point 91 operation. In the introduction, there is reference to the
7 goals. The information was drafted on the 15th of November, 1991.
8 And here you can see a list of all the results, as well as
9 certain problems which were encountered on the ground.
10 Q. Thank you.
11 MR. ZECEVIC: [Interpretation] If there are no objections, I would
12 like to tender the document into evidence.
13 JUDGE HARHOFF: We can only see the front page.
14 How long is this document?
15 MR. ZECEVIC: Four pages.
16 JUDGE HARHOFF: Thank you.
17 JUDGE HALL: Admitted and marked.
18 THE REGISTRAR: Exhibit 1D450 [sic], Your Honours.
19 MR. ZECEVIC: [Interpretation] Thank you.
20 Q. Mr. Bjelosevic, in autumn 1991, were MUP reservists mobilised;
21 and, if they were, on whose orders?
22 A. Yes. The reserve force was mobilised. I can't remember exactly
23 on what date. And it was done on the order of the minister of the
24 interior, Mr. Alija Delimustafic.
25 Q. As we have heard, you worked at the Secretariat for
1 National Defence, and previously you were the chief of the
2 Security Services Centre. Could you give us some technical details of
3 mobilisation. When you wanted to mobilise the reserve force of the
4 police, how did you do that?
5 A. We had defence plans for every public security station which
6 defined the number of people and the number of police stations in every
7 specific municipality.
8 A request was sent for a certain number of people to replenish
9 wartime units. In the centres, there was a division for wartime
10 preparations, and in the public security stations, there was a desk
11 officer in each of the stations that dealt in those things. And in
12 keeping with the plans, we mobilised a certain number of units to
13 bring -- a certain number of men to bring units up to the strength.
14 There was a mobilisation plan, a plan according to which men were
16 Reserve policemen would be issued with uniforms in a timely
17 manner. They would take those uniforms home.
18 In every wartime police station, there was a certain number of
19 official IDs, exactly the number that was needed by the wartime police
20 station for all its men. Those IDs, however, did not contain any
21 personal data because the personnel changed all the time. The numerical
22 strength remained the same, however. In case reserve police stations
23 were activated, those IDs would have been issued to those men that were
24 at the stations at that time.
25 Q. When the reserve police were mobilised, did the mobilised police
1 reserve officers also get weapons? Were they issued with weapons?
2 A. In the autumn of 1991, they were issued with weapons.
3 JUDGE DELVOIE: Mr. Zecevic --
4 MR. ZECEVIC: Yes.
5 JUDGE DELVOIE: -- just one moment.
6 Mr. Bjelosevic, this is a mobilisation order by the
7 Minister Delimustafic. Was this mobilisation order specific to the Doboj
8 CSB area; or was it a nation-wide mobilisation order?
9 THE WITNESS: [Interpretation] I believe that that mobilisation
10 applied to the entire territory of Bosnia-Herzegovina. That it was
11 carried out across the entire territory.
12 JUDGE DELVOIE: Thank you.
13 MR. ZECEVIC:
14 Q. [Interpretation] Mr. Bjelosevic, in autumn 1991, were there any
15 visits to your Security Services Centre by anybody from the federal SUP,
16 from their inspectors?
17 A. Yes, they did come. Before the check-points were set up, in
18 keeping with the minister's order, we informed federal inspectors about
19 the current security and safety situation. Later on, they occasionally
20 paid us visits when they wanted to analyse some things together with us.
21 Q. Could you please look at 763D1, tab 6.
22 Can you comment?
23 A. Yes. This is the dispatch in question that was sent by the
24 Ministry of the Interior of Bosnia and Herzegovina announcing the arrival
25 of federal inspectors.
1 MS. KORNER: Sorry, Your Honours, our LiveNote seems to have
2 stopped working.
3 THE WITNESS: [Interpretation] May I proceed, please?
4 JUDGE HALL: [Microphone not activated] Has it come up yet?
5 [Trial Chamber and Registrar confer]
6 JUDGE HALL: It's in progress.
7 MS. KORNER: Your Honours, I don't know if that means it's going
8 to come back at some stage or ... or what exactly?
9 JUDGE HALL: Are you so handicapped as Mr. Zecevic ought not to
10 proceed. That is the question.
11 MS. KORNER: The trouble is I've lost -- if he could repeat for
12 me the document tab number because that didn't come out.
13 MR. ZECEVIC: It's tab number 6.
14 MS. KORNER: All right.
15 MR. ZECEVIC: Well, Your Honours, I can proceed because we have
16 the LiveNote on the monitor. It's on our computers we don't have it.
17 [Trial Chamber and Registrar confer]
18 JUDGE HALL: Can you see the transcript, though, Ms. --
19 MS. KORNER: Your Honours, I can. Yes.
20 JUDGE HALL: [Microphone not activated] So we can proceed, I
22 MR. ZECEVIC: Thank you very much, Your Honours.
23 Q. [Interpretation] Sir, you started talking about the document.
24 Can you finish, please.
25 A. Yes. We, as chiefs of Security Services Centres, were given some
1 tasks and obligations. We were asked to brief the federal inspectors
2 about the security situation in the -- in the area and to put in place
3 conditions for the functioning of those check-points in our territory.
4 Q. Thank you.
5 MR. ZECEVIC: [Interpretation] If there are no objections, I would
6 like to tender this document into evidence.
7 JUDGE HALL: Admitted and marked.
8 THE REGISTRAR: Exhibit 1D441, Your Honours. And page 59,
9 line 1, exhibit number is 1D440. I misspoke; I apologise.
10 MR. ZECEVIC:
11 Q. [Interpretation] Sir, could you please look at 765D1, tab 8.
12 I would like to invite you to comment upon this order. Who
13 signed it, first of all?
14 Could we please look at the second page of the document.
15 A. The document was signed by the minister of the interior,
16 Alija Delimustafic.
17 Q. Could you please explain this dispatch for us.
18 A. This is an order for us to prepare, and it also gives us all the
19 elements that we should include into our briefing session with the
20 federal inspectors.
21 There are bullet points for us to prepare ourselves, and that's
22 what we followed.
23 Q. Is this order connected with the previous order that we have just
25 A. Yes.
1 Q. Does this order elaborate your obligations with regard to the
2 visit of those inspectors from the federal SUP?
3 A. Yes. It provides a lot more detail than the previous one. It
4 actually gives a list of all the things that we needed to prepare in
5 advance and how we should brief the inspectors.
6 MR. ZECEVIC: [Interpretation] If there are no objections, I would
7 like to tender this document into evidence.
8 JUDGE HALL: Admitted and marked.
9 THE REGISTRAR: Exhibit 1D442, Your Honours.
10 MR. ZECEVIC: [Interpretation] Your Honours, I have just been
11 informed by my colleagues that they still don't have LiveNote. I don't
12 know whether that presents any problems for Ms. Korner or the
14 Shall I continue?
15 JUDGE HALL: I think she's indicated that she doesn't have a
17 MR. ZECEVIC: [Interpretation] I thank you.
18 Q. Mr. Bjelosevic, what measures did the Ministry of the Interior of
19 the Socialist Republic of Bosnia and Herzegovina take or put in place in
20 the course of 1991, with regard to the situation? More specifically, in
21 your CSB and probably across Bosnia and Herzegovina.
22 A. Are we talking about the check-points or the overall situation?
23 Q. The overall situation. We have already discussed the
25 A. Unfortunately, I have to say that the Ministry of the Interior of
1 Bosnia and Herzegovina did not undertake adequate measures, measures that
2 would be adequate with respect to the problems that arose in the area at
3 the time. I even had a feeling - and I also have some arguments to
4 support this - that Operation Check-point 1991, which had given good
5 results, is something that they did not like, and very soon they started
6 obstructing that operation.
7 I would especially like to highlight the arrival of inspectors
8 from the MUP headquarters in Sarajevo. They had been sent by the
9 headquarters to the area of the CSB Doboj. Contrary to some rules, these
10 inspectors were sent to public security stations; first and foremost,
11 Bosanski Brod and Bosanski Samac. The inspectors moved some
12 check-points, as well as the personnel, policemen who manned the
13 check-points. We provided policemen from the level of the Doboj CSB, and
14 once these inspectors from the police administration arrived, as well as
15 from other centres, those who had been sent, these police forces were
16 sent back; whereas, they selected policemen from some other centres and
17 brought them to Samac, and later on, to Bosanski Brod as well.
18 Q. Could you please clarify your answer. Who sent the inspectors
19 from the MUP of the Socialist Republic of Bosnia and Herzegovina; when
20 did they arrive?
21 And you also mentioned that it was contrary to some rules. Would
22 you elaborate on that, please.
23 A. Normally, when the inspectors from the administration come to the
24 centre, or to a station, they are typically announced, and they come
25 either to conduct supervisory inspection of the work of the centre or the
1 station, or they come in order to provide certain instructions.
2 In this particular case, first of all, they were not announced.
3 They did not bring them any kind of an order, be it from the minister,
4 from assistant minister, or deputy minister. They simply came and said
5 they came to conduct some co-ordination activities, as they termed it
6 initially. As the time passed, I asked that they either produce an order
7 on sending them to us, or a plan of work that they were supposed to
9 THE INTERPRETER: Interpreter's note: Could Mr. Zecevic's
10 microphone be switched off.
11 THE WITNESS: [Interpretation] I did not receive it from them, and
12 then, later on --
13 JUDGE HALL: Mr. Zecevic, the interpreters need you to switch off
14 your microphone.
15 THE WITNESS: [Interpretation] They did not produce either of the
16 two documents that I asked for, and this is when I asked from the
17 ministry that an explanation be given for their visit. It took several
18 written interventions of mine --
19 MR. ZECEVIC:
20 Q. [Interpretation] Let us show the documents and you can continue
21 with your answer.
22 MR. ZECEVIC: [Interpretation] 65 ter 768D1, tab 10.
23 THE WITNESS: [Interpretation] Jusuf Pusina sent a dispatch at
24 that point.
25 MR. ZECEVIC:
1 Q. [Interpretation] Sir, we have a document on our screens. Would
2 you please comment and tell us whose document it is and explain the
3 background of the document.
4 A. I sent this document to the minister, to the deputy minister, and
5 to the then-Executive Council, to the deputy prime minister for internal
6 policy, and to the president of the Assembly.
7 In this memo I describe the problem, the one that I have just
8 told you about, because the visit of the inspectors meant an introduction
9 of a parallel system in the territory under the jurisdiction of the
10 Doboj CSB. They directly interfered in the work of the centre, in the
11 management of the centre. They took over the SJBs and sent separate
12 reports bypassing the centre which, in a way, meant that the centre was
13 almost suspended in all of its work and it meant that a parallel system
14 was established.
15 There is another matter that I wish to bring to your attention;
16 namely, that all of these inspectors who had come, and there were a total
17 of six of them staying there, were of Muslim ethnicity and that this
18 produced a reaction, both in the SJBs that they visited, as well as among
19 the population in the area. Because it disturbed further an already bad
20 ethnic composition among the senior management and senior levels.
21 Q. When you say "bad ethnic composition in the senior management,"
22 what are you referring to?
23 A. There was a rule that if a chief of SJB was of one ethnicity,
24 then the commander of that SJB was supposed to be of a different
25 ethnicity. And depending on what the composition of the population was,
1 whether there were two ethnic communities or three ethnic communities, if
2 it was a multi-ethnic community, then the third senior position was
3 supposed to be given to a member of the third ethnic community. And the
4 inspectors, with their arrival, disturbed this agreement. And especially
5 once the police forces were brought in from elsewhere. That further
6 disturbed it.
7 Q. Tell me, please, the problems that you just spoke about, the fact
8 that the agreement, the structure was disturbed, that a parallel system
9 was introduced, that the command and hierarchy in MUP was suspended and
10 that basically the CSB became powerless. All of these things that you
11 just described to us, were those the reasons why you sent this memo or
12 were there other reasons?
13 A. Well, precisely those reasons, the ones that I have described to
14 you. This is what prompted me to send this memo.
15 Q. And to whom was this memo sent?
16 A. I believed that the problem was quite a major one, and this is
17 why I sent this memo to the minister of the interior, to his deputy, and
18 to the Executive Council of Bosnia and Herzegovina, to the deputy
19 prime minister who was in charge of internal policy, and this was a
20 problem from that domain, and I also sent the memo to the president of
21 the Assembly of the Socialist Republic of Bosnia and Herzegovina.
22 Q. Thank you.
23 MR. ZECEVIC: [Interpretation] Unless there are objections, I
24 would like to tender this into evidence.
25 JUDGE HALL: Admitted and marked.
1 THE REGISTRAR: Exhibit 1D443, Your Honours.
2 MR. ZECEVIC:
3 Q. [Interpretation] This memo of yours that was just introduced into
4 evidence, did it produce a response?
5 A. I did not receive a response, either from the minister or from
6 his deputy. Rather, I received a reply from Mr. Jusuf Pusina. And to
7 this day, I have a dilemma whether Mr. Pusina was able to intercept these
8 memos before they reached the minister and the deputy, or whether the
9 minister and the deputy allowed him, on purpose, to correspond with me so
10 as to avoid any responsibility on their part for such a major problem.
11 And I thought this was a major problem. This had long-ranging
12 consequences for further work in the Ministry of Interior.
13 MR. ZECEVIC: [Interpretation] Could we see 769D1, tab 11, please.
14 Q. Sir, could you please comment on this document.
15 A. This is a reply, signed by Mr. Jusuf Pusina, a reply to my
16 questions, to the questions I raised. As I have said, I did not receive
17 a reply either from the minister or his deputy.
18 In this reply, there is no information on who decided to send
19 inspectors to Bosanski Samac and Bosanski Brod. Rather, this reply says
20 that it was the ministry as an institution that did it. And this is why
21 I had this dilemma; that is to say, it wasn't either the minister or the
22 deputy that made this decision. Nor does he say that he, Jusuf Pusina,
23 as assistant, made that decision. Rather, the document speaks of the
24 ministry as a whole that made the decision.
25 Q. Did you receive, via this document or via contacts with
1 Mr. Jusuf Pusina, any other obligations? Were you informed of any other
2 obligations you had in relation to the inspectors who had come from the
4 A. They asked for a car to be placed at the disposal of
5 Omer Stambolic as well as a policeman who would be his security detail.
6 Q. Thank you.
7 MR. ZECEVIC: [Interpretation] I tender this into evidence.
8 JUDGE HALL: Admitted and marked.
9 THE INTERPRETER: Interpreter's note: Could Mr. Zecevic's
10 microphone be switched off when not in use, please.
11 THE REGISTRAR: Thank you. This will be Exhibit 1D444,
12 Your Honours.
13 MR. ZECEVIC:
14 Q. [Interpretation] Sir, could you please comment on the next
15 document. 65 ter 770D1, tab 12.
16 JUDGE HARHOFF: Mr. Zecevic, I -- I can't help just making the
17 comments that I think the Chamber is, by now, well-informed through the
18 witness of the situation and the various attempts from the witness to the
19 ministry to control the situation that evolved slowly by the end of 1991.
20 So I don't know for how much longer you wish to pursue this -- this
21 matter, but I think it's -- it's pretty clear the picture that emerges
22 from what we have heard so far and what we have seen.
23 MR. ZECEVIC: [Interpretation] Well, Your Honours, I believe that
24 during our Defence case, we need to show -- I don't know whether I should
25 switch into English and have the witness take off the headphones so as to
1 avoid any perception that I'm giving instructions to him.
2 Would you please switch off your mikes?
3 [In English] The point, Your Honours, is the following. The
4 allegation which was presenting during the Office of the Prosecutor's
5 case is that -- that there was a joint criminal enterprise existing in --
6 starting to exist in October 1991, and one of the aspects of it was
7 the -- was the meeting in the -- on the 11th of February in Banja Luka.
8 The witness was present on that meeting in Banja Luka.
9 Now, I'm trying to establish now why, what were the reasons why
10 the witness and other people of Serbian ethnicity went to that meeting in
11 Banja Luka on the 11th of February and try to establish that this was
12 actually the only way they could cope with the -- with problems that they
13 have experienced in their work in the ministry of the Socialist Republic
14 of Bosnia and Herzegovina and that the level of inconsistencies of -- of
15 misuse of the -- of the police force and the -- and the work, not in
16 accordance with the laws and the regulations, was such that it justified
17 the meeting and the topics that were discussed at that meeting.
18 That is the aim. And since we have the original documents from
19 that time, I -- I think only -- only proper way that would be that I
20 introduce these documents with a comment of the person who received these
21 comments [sic] and went, ultimately, to that meeting on the 11th of
23 Thank you.
24 [Trial Chamber confers]
25 MS. KORNER: Your Honour, the only thing I have to say is can I
1 just confirm that all of these documents, again, are ones provided by
2 Mr. Bjelosevic.
3 MR. ZECEVIC: Well, some were disclosed to us by the Office of
4 the Prosecutor [Overlapping speakers] ...
5 MS. KORNER: Well, I can see --
6 MR. ZECEVIC: When Ms. Korner says "all of them," I'm not sure --
7 MS. KORNER: I can see ones with ERNs which are clearly from us.
8 But ones without ERNs, I'm taking it are produced by this witness.
9 MR. ZECEVIC: Well, yes.
10 MS. KORNER: Thank you.
11 MR. ZECEVIC: Let me consult, please.
12 [Defence counsel confer]
13 MR. ZECEVIC: I was just informed by my assistant that there are
14 a number of documents which we uploaded and then they were given the
15 ERN numbers afterwards and then returned to us from the Office of the
16 Prosecutor side. But, Ms. Korner, Ms. Savic will give you the
17 explanation to the detail, why she claims this is the situation.
18 JUDGE HALL: In any event, I think everything we've seen so far,
19 either documents that the witness generated or received by him whether --
20 or otherwise that he could speak to authoritatively. So I don't -- the
21 apprehension that is implicit in Ms. Korner's question --
22 MS. KORNER: [Overlapping speakers] ... no, no, can I explain why
23 I'm asking this each time.
24 This, as you all know -- I'd ask the witness to take his
25 earphones off.
1 As Your Honours know because it has been uploaded, this
2 interview -- this witness was interviewed in 2004. I would think about
3 1/20th of the documents which are now emerging from him were actually
4 provided to us in that interview.
5 MR. ZECEVIC: With all due respect, the witness was interviewed
6 on both occasions as a suspect.
7 MS. KORNER: Yes. But his lawyer turned up, who was present, as
8 Mr. Zecevic knows, with a selected handful of documents. That's why I'm
9 asking on each occasion to confirm that this is what he has now provided.
10 JUDGE HALL: Let's proceed. Thank you.
11 MR. ZECEVIC: Thank you, Your Honours.
12 Q. [Interpretation] Can you hear me, sir?
13 A. Yes.
14 Q. Sir, my question was that you should clarify this document behind
15 tab 12, 770D1. Can we have your comments on it.
16 A. This is yet another document drafted by Mr. Pusina following a
17 number of interventions insisting on receiving answers to the question as
18 to why the inspectors were sent, who, upon their arrival there, took
19 charge of what was happening in these stations and in -- in a way, in the
20 centre as well.
21 THE INTERPRETER: Can Mr. Zecevic please switch his microphone
23 THE WITNESS: [Interpretation] The suggestion was that he should
24 assign a technical secretary to work with me, although there was a civil
25 servant who had been working there previously but she was on maternity
2 In this letter, Mr. Pusina said that what was done was done under
3 the instructions from the minister. I had asked on several occasions
4 that I get in touch with Minister Delimustafic because I wanted to talk
5 to him about this issue. I wanted to have a direct contact with him. No
6 answer was forthcoming. Let me emphasise that throughout that time,
7 which was almost a year, Minister Delimustafic did not hold a single
8 meeting of the collegium to which he would invite all the chiefs of
9 centres and which would have enabled us to discuss the problem together
10 and which would have enabled us to report on the events taking place on
11 the ground directly.
12 Q. Thank you.
13 MR. ZECEVIC: [Interpretation] Can we have the document admitted,
15 JUDGE HALL: Yes, admitted and marked.
16 THE REGISTRAR: Exhibit 1D445, Your Honours.
17 MR. ZECEVIC:
18 Q. [Interpretation] Sir, please have a look at document 771D1, which
19 is tab 13. It has to do with the same issue, so can you please explain
20 what it was about.
21 A. Yes. This is my dispatch which I sent to the minister and his
22 office, to his deputy, to Assistant Jusuf Pusina and to Assistant
23 Momcilo Mandic. The purpose of the letter was to provide them with
24 information, since the situation in the two municipalities, namely, Samac
25 and Bosanski Brod, were quite dramatic by that time. I drew their
1 attention to -- or, rather, alerted them to what might follow. There
2 might be unrest, protests, et cetera.
3 I asked that they withdraw Mr. Stambolic from Doboj because he
4 was suspended at the time as there was a disciplinary procedure pending
5 against him, and here I state, yet again, my dilemma as to whether
6 Minister Delimustafic was aware of it all or not. I tried to repeatedly
7 to notify him of these problems directly.
8 Q. Tell me, Mr. Bjelosevic, if my understanding is correct. The
9 inspector who was sent out from the MUP headquarters, Stambolic, this one
10 Omer Stambolic, your impression was that at the time he was in the area
11 of your CSB, there was a disciplinary procedure pending against him and
12 that he was, in fact, suspended?
13 A. Precisely so.
14 MR. ZECEVIC: [Interpretation] Can this document be admitted,
16 JUDGE DELVOIE: Just one moment, Mr. Zecevic. I would like to
17 ask the witness to read, in Serbian, the sentence:
18 "For the above reasons, the police officers sent to
19 Bosanski Samac," and so forth, and so on.
20 Could you read that in Serbian, please?
21 "For the above reasons the police officers sent to the
22 Bosanski Samac SJB," and to the end of the sentence so that we'll get a
23 translation of what you are reading?
24 THE WITNESS: [Interpretation] "For the above-mentioned reasons,
25 the policemen who were posted or sent to the SJB Bosanski Samac will be
1 withdrawn from their service in the SJB Bosanski Samac."
2 JUDGE DELVOIE: Thank you.
3 [Trial Chamber confers]
4 JUDGE DELVOIE: I -- Mr. Bjelosevic, I have a -- pardon?
5 [Trial Chamber confers]
6 JUDGE HALL: Admitted and marked.
7 THE REGISTRAR: Exhibit 1D446, Your Honours.
8 JUDGE DELVOIE: My question is this: When it says, "For the
9 above reasons the police officers will be withdrawn," are you asking the
10 minister to withdraw them, or are you -- or is this your decision to
11 withdraw them? It's a little bit confusing in -- in the context of the
13 What do you mean by "they will be withdrawn"?
14 THE WITNESS: [Interpretation] The composition of the police
15 personnel that arrived from other areas included policemen from the
16 stations under the Doboj centre. While those mixed check-points were
17 still in effect, in other words, while the Punkt 91 or Check-point 91
18 operation was still ongoing, the situation was brought under control.
19 The tensions eased and the security situation in general took a turn for
20 the better significantly.
21 JUDGE DELVOIE: Let me --
22 THE WITNESS: [Interpretation] And then --
23 JUDGE DELVOIE: Let me interrupt you for just one moment. The
24 police officers sent to Bosanski Samac is not referring to Hodzic and
25 Panjek? It is referring to the other police officers that they brought
1 to Bosanski Samac; is that right? So that's where my misunderstanding
2 was. Those police officers that -- this is not referring to Hodzic and
4 THE WITNESS: [Interpretation] Yes.
5 JUDGE DELVOIE: And this is your decision to withdraw those extra
6 policemen who did not come from Bosanski Samac. It is your decision to
7 withdraw them; is that right?
8 THE WITNESS: [Interpretation] Yes. To avert the protests that
9 were announced. We wanted to avoid having mass-scale unrest.
10 JUDGE DELVOIE: Okay. So that's clarified. Thank you.
11 MR. ZECEVIC:
12 Q. [Interpretation] We'll look at one other document before we stop
13 for today. 779D1, behind tab 15. Tab 15.
14 This is another document by Mr. Pusina. Can we have your
15 comments on it.
16 A. This letter did not change the situation substantially or solve
17 it. Yet again, Mr. Pusina sends out inspectors in their stead. As you
18 can see Jusuf Vatres from the Sarajevo CSB is going do come; whereas, we
19 do have inspectors within the police service of the CSB Doboj. Obviously
20 there was something that they wanted to achieve with this, which only he
21 and his associates were privy to, although it wasn't difficult to draw
22 conclusions. Panjeta would be leaving, therefore, and he would be
23 replaced by Inspector Jusuf Vatres. So they would change, but the ethnic
24 structure, the ethnic makeup would remain roughly the same as would the
1 Q. Thank you.
2 MR. ZECEVIC: [Interpretation] If there are no objections, I'd ask
3 that the document be admitted. And I would stop here for today.
4 JUDGE HALL: Yes, admitted and marked.
5 THE REGISTRAR: As Exhibit 1D447, Your Honours.
6 JUDGE HALL: Mr. Bjelosevic, you, having been sworn -- we're
7 about to take the adjournment for today and we'll resume in this
8 courtroom at 9.00 tomorrow morning. Having been sworn as a witness in
9 this matter, you cannot have any communication with counsel from either
10 side, the side that's calling you or the side that is examining you,
11 until after you would have been released by the Chamber. Furthermore, in
12 such communication as you may have with persons -- anybody outside of the
13 Chamber apart from counsel, you cannot discuss your testimony.
14 Do you understand what I just said?
15 So you're now excused to return tomorrow morning at 9.00.
16 We take the adjournment for the day.
17 MS. KORNER: Your Honour, may I just raise one technical
18 administrative matter. Ms. Savic has very kindly --
19 JUDGE HALL: I'm sorry, may the witness be escorted out.
20 MS. KORNER: Oh, yes, the witness can go
21 [overlapping speakers] ...
22 JUDGE HALL: Usher, yes. Yes, please continue.
23 [The witness stands down]
24 MS. KORNER: Ms. Savic has kindly pointed out that some of the
25 documents we've notified to use for cross-examination are already on
1 their list. We attempted to do a check. Theirs don't have ERN numbers
2 in the same -- so we can't check against ERN numbers unless, quite by
3 chance, they have them and there are many copies of the same document.
4 But their spreadsheet does not have the date. We put the date on all of
5 ours, and the -- and apparently the reason is because that wasn't a
6 requirement, but it makes it easier when we're looking at their list to
7 prevent us trying to put in the same documents and, therefore, having
8 double exhibits if the column -- there's a column added to their
9 spreadsheet which has the date. It's still not perfect, but it will make
10 it easier for us to try and check against the two, because, otherwise, we
11 are going to have -- end up with us trying to exhibit the same document
12 that's already been a Defence exhibit.
13 JUDGE DELVOIE: So the document's date is --
14 MS. KORNER: Yes, there's a -- at the moment --
15 JUDGE DELVOIE: -- in the document's description is in the
16 wrong -- in the wrong column.
17 MS. KORNER: Yes. It makes it more difficult to search. Where
18 if you've got a date, you can just simply search and see if the dates are
19 the same. I mean, as I say, I don't think it's going to be perfect, but
20 it'll help. And the reason I'm raising it with you is because I
21 understand your only order was that it should be -- the 65 ter number, or
22 whatever, so I'd ask that it simply includes the date. It may not even
23 need an order.
24 JUDGE HALL: So this is something we could leave to the attorneys
25 to sort out outside the court.
1 MS. KORNER: Yes. But I -- the reply came [indiscernible] I'm
2 raising it. And, Your Honours, there's one other thing and I raise it --
3 simply, Your Honours, may recall that each and every one of our
4 witnesses, before they started their evidence, was given a warning about
5 the consequences of perjury, as it so happens, wherever this witness
6 is -- our witnesses came from. That warning wasn't given, and I
7 merely --
8 JUDGE HALL: The oversight is entirely mine. Thanks for the
9 reminder, Ms. Korner.
10 MS. KORNER: Thank you.
11 JUDGE HALL: And I would see that whether, practically speaking,
12 it is something that I can correct or patch tomorrow morning before the
13 witness resumes.
14 MS. KORNER: Yes. Well, Your Honours, I only raised it because
15 we just noted it this morning.
16 JUDGE HALL: Thank you.
17 --- Whereupon the hearing adjourned at 1.50 p.m.,
18 to be reconvened on Wednesday, the 13th day of
19 April, 2011, at 9.00 a.m.