Tribunal Criminal Tribunal for the Former Yugoslavia

Page 21405

 1                           Friday, 27 May, 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

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

 7     The Prosecutor versus Mico Stanisic and Stojan Zupljanin.

 8             JUDGE HALL:  Thank you, Madam Registrar.  Good morning to

 9     everyone.  May we have the appearance today, please.

10             MR. HANNIS:  Thank you, Your Honours.  For the Prosecution, I'm

11     Tom Hannis along with Gerard Dobbyn, and our Case Manager today is

12     Indah Susanti.

13             MR. ZECEVIC:  Good morning, Slobodan Zecevic, Slobodan Cvijetic,

14     and Eugene O'Sullivan appearing for Stanisic Defence this morning.

15             MR. ALEKSIC: [Interpretation] Morning, Your Honours, for the

16     Defence of Mr. Stojan Zupljanin, Aleksandar Aleksic.

17             JUDGE HALL:  Thank you.  And if there are no housekeeping

18     matters, could the witness be escorted back to the stand, please.

19                           [The witness takes the stand]

20             JUDGE HALL:  Mr. Andan, good morning to you, sir.  Before

21     Mr. Zecevic resumes his examination-in-chief, I remind you you are still

22     on your oath.

23             Yes, Mr. Zecevic.

24             MR. ZECEVIC:  Thank you, Your Honours.

25                           WITNESS: DRAGOMIR ANDAN [Resumed]

Page 21406

 1                           [Witness answered through interpreter]

 2                           Examination by Mr. Zecevic:  [Continued]

 3        Q.   [Interpretation] good morning, Mr. Andan.

 4        A.   Good morning to all.

 5        Q.   Mr. Andan, what was your task when you were sent to Brcko in the

 6     beginning of June 1992?

 7        A.   To carry out an inspection, supervision and to provide the

 8     indispensable assistance for the revitalisation of the police station in

 9     Brcko.

10        Q.   When you arrived in Brcko, tell me what did you find at the

11     police station, or rather the public security station Brcko?

12        A.   As I arrived in Brcko, after all this was my first encounter with

13     that kind of an emergency, state of emergency.  I arrived at some point

14     in the afternoon.  There was quite a destruction.  Buildings were

15     damaged.  I was put up at a hotel, Brcko, to spend the night and early in

16     the morning I went to the police station.  At the police station I only

17     saw the duty policeman and some persons who were coming into this police

18     station, going out, I had no idea who these individuals were and what

19     they were doing.  I addressed the duty policeman, I introduced myself and

20     I asked him to take me to the office of the chief of the public security

21     station.

22             In the hallway of that police station, I stayed for several hours

23     until an individual came who introduced himself as the chief of the

24     public security station.  I think his name was Dragan Veselic.

25        Q.   Tell me, this Dragan Veselic, who introduced himself to you as

Page 21407

 1     the chief of the public security station, did he tell you who had

 2     appointed him to that position?

 3        A.   It's hard to answer that question given the time distance.

 4     However, it was my understanding at the time that the current authorities

 5     in Brcko had appointed him.  Whether consent and approval had been

 6     received from the MUP or not I don't know, to this day.  But it is

 7     certain that he was appointed by the then authorities of Brcko.

 8        Q.   This gentleman, Mr. Veselic, was he a member of the MUP before

 9     that point in time?

10        A.   No, he was not a member of the MUP.  As we talked it seemed to me

11     that he was basically involved in politics and it was the Serb Democratic

12     Party that had proposed him as a candidate for the chief of the public

13     security station, so he was not a professional in any way.

14             MR. ZECEVIC: [Interpretation] Let us have a look at 65 ter 182D1,

15     tab 15.

16        Q.   Mr. Andan, at the public security station of Brcko, did you

17     organise a meeting to familiarise yourself with the situation there?

18        A.   Yes.  I held my first meeting with Mr. Veselic on that very same

19     day and I expressed my interest in all the police stations that the Brcko

20     police station was facing.  He familiarised me with the situation there

21     and while I was waiting for him to receive me in his office, what I saw

22     was that it was internal order that was their main problem.  Let me

23     explain this.

24             I think that people enter that police station any way they

25     wanted, they went to different offices, they took certain documents any

Page 21408

 1     which way they wanted to, primarily driving licences and traffic

 2     licences.  So my primary objective was to overcome that situation first

 3     and foremost.

 4             Before the official meeting that we organised at the police

 5     station, I was the one who had requested that meeting, because at the

 6     time the police station, as far as I can remember, did not have a

 7     commander of the police station.  There wasn't a deputy there either.  I

 8     think there were two assistant commanders and that's how it all

 9     functioned.

10             I said to Mr. Veselic what I thought and what my proposals were,

11     namely, to focus first and foremost on getting the house in order and let

12     us try to establish a standing practice, not to say a pre-war practice,

13     not to allow persons with weapons to enter the police station.  And most

14     of them had long-barrelled weapons at that.  And that they exercised

15     their civic rights without being armed.

16             As for that task, we needed a few very brave and courageous young

17     men because our assessment was that there would be quite a few problems,

18     that the people who were used to entering the police station in that way

19     would try to go on doing so.  We selected about ten young men and I held

20     a meeting with them.  In the meantime, we made a kind of document showing

21     that weaponry had been taken away temporarily from a person, any kind of

22     weapon.

23        Q.   When you introduced this order in the house, if we can put it

24     that way, this internal order within the public security station, what

25     happened then?

Page 21409

 1        A.   A few days later we had a problem straightaway.  Some

 2     paramilitary formation, I think they were Captain Dragan's men, they were

 3     led by a certain Rade.  With their weapons and equipment, they tried to

 4     enter the building violently, these young men who were on duty there

 5     opposed that, and thankfully they emerged victorious.  Fire-arms were not

 6     used in the process.  So they emerged victorious and in a way people felt

 7     relieved after that and could work in the police station in a more normal

 8     way.

 9        Q.   Tell me, Mr. Andan, when you came to the police station of Brcko,

10     the public security station in Brcko, did they have an organised patrol

11     service?

12        A.   Well, the problem was that they only had a duty service that was

13     operating.  All the police forces that they had at that point in time

14     were at the front line.  The army had carried out mobilisation of the

15     police forces as well and took them to the front line.  At that point in

16     time apart from the duty service that had about five or six men and the

17     chief and myself and two assistants, there weren't any other policemen at

18     the police station, so they did not have a proper professional division

19     into departments which is indispensable for the proper functioning of a

20     police station.

21        Q.   Please let us have a look at the document before us.  These are

22     minutes from the professional collegium of the Serbian SJB, held on the

23     2nd of June, 1992.  Did you attend the meeting?

24        A.   Of course I attended the meeting.  I was the one who initiated

25     it.  However, before this meeting something else happened that was very

Page 21410

 1     important for the Brcko police station.  I asked Chief Veselic that we

 2     withdraw the active-duty policemen from the front line, and that withdraw

 3     some of the reserve police force so that we could properly start

 4     organising the work of the police station.  With Mr. Veselic, I went to

 5     the command, the military command in Brcko, we presented our problem, and

 6     we were promised that as soon as possible, within a day or two, we would

 7     get some feedback, or rather, that about 150 to 170 policemen would be

 8     returned from the front lines, some of them active duty, others reserve.

 9             After that we opened this working meeting, the one that I had

10     initiated.  Our first task was to establish a structure of command in the

11     police station in Brcko, before we started the official meeting, this

12     working meeting of the structures of the police station, I gave general

13     guide-lines to the chief of the police station as to how the meeting

14     should be organised.  With all due respect the man had never worked in

15     police structures before, so I had to explain to him all the segments of

16     work in a police station and to say what was the most important thing

17     that had to be done in a police station so that it would start

18     functioning.

19        Q.   When you say "start functioning" is it your view that the public

20     security station in Brcko before that moment, that is to say the

21     beginning of June when you arrived there, had not actually been

22     functioning?

23        A.   It is regular practice in the ministry that when one first

24     arrives in a police station, one observes the entire situation as it is

25     and then we send a report.  This was done in peacetime and it was also

Page 21411

 1     done in war time, wherever possible.  I think that I did that, and when I

 2     arrived in the police station, I observed the overall situation on the

 3     basis of my own information, I said that the police station in Brcko

 4     functioned until the bridges on the Sava river were destroyed.

 5        Q.   And when was that approximately, if you know?

 6        A.   If you have that particular piece of information, you will know.

 7     I think it was sometime in the beginning of April 1992.  After that all

 8     Serb, Croat and Muslim personnel had left the police station, at least to

 9     the best of my knowledge.  However, according to what I learned during

10     this inspection, the Muslims took log-books and registers from the police

11     station and all the other necessary administrative papers.  They took the

12     seals as well and --

13             MR. HANNIS:  Can I ask if there needs to be a clarification at

14     line 8, it says, "all Serb, Croat, and Muslim personnel left".  That

15     sounds like it doesn't leave anybody.

16             MR. ZECEVIC:  Yes, that's what the witness said.

17        Q.   [Interpretation] You heard this, didn't you, is that your

18     knowledge, that no one stayed behind at the police station after the

19     bridges were destroyed?

20        A.   At the Brcko police station very few Serb policemen remained.

21        Q.   Thank you.

22        A.   And if you allow me, I would like to say that that situation

23     prevailed --

24             JUDGE HALL:  Sorry, Mr. Zecevic, the clarification which the

25     witness has just offered I confess confuses me somewhat in that the broad

Page 21412

 1     statement that he made initially which Mr. Hannis invited clarification

 2     on, the way it has been clarified leads me to question whether it was

 3     only Serb policemen who remained.

 4             Do you understand, Mr. Andan?  Do you understand my question?

 5             THE WITNESS: [Interpretation] Yes, I do understand what you are

 6     saying.  I said that Serb, Croat, and Muslim policemen had left and that

 7     only a number of Serb policemen had stayed behind at the police station,

 8     so some policemen had stayed on at the police station in Brcko.  I also

 9     said that the Muslims had left and that they took along part of the

10     documentation and the registers and the seals.  I don't know if we are

11     understanding each other on this, only very few Serb policemen stayed

12     behind.

13             JUDGE HALL:  My question is whether of those who stayed behind,

14     they were only Serbs.  That's all I'm asking.

15             THE WITNESS: [Interpretation] Yes, that's the information that I

16     received when I came to the police station.

17             JUDGE HALL:  Thank you, sir.

18             JUDGE HARHOFF:  Could I put a follow-up question to the

19     information that you have just offered in response to the Presiding

20     Judge's question, namely, why would any Serb police officer leave the SJB

21     of Brcko at that time, that is to say, after the bridges were destroyed?

22             THE WITNESS: [Interpretation] I cannot give you a specific

23     answer.  I can just offer certain facts to you because of the shortage of

24     personnel when I arrived there, as assigned by Mr. Stanisic to Brcko, and

25     when we tried to constitute the ministry, or rather, the public security

Page 21413

 1     station, we did not have an adequate number of personnel who would

 2     provide the manpower for all the services required within the police

 3     station.  When I asked where Serb personnel were, the answer I was given

 4     was that they had left as well and that they were most probably at their

 5     apartments and houses.  Then I asked the chief to call each and every one

 6     of them individually to have them brought back to the police station

 7     because we needed professionals to carry out police work.  I don't know

 8     whether they all responded, but most of them did return to the police

 9     station and we assigned them to certain jobs and tasks in accordance with

10     their training, education, qualifications, and so on.

11             That is my explanation.  I really cannot say anything more

12     specific to you but I'm trying to give you an answer and I don't know

13     whether it's going to satisfy you.

14             JUDGE HARHOFF:  It certainly does provide some information, but,

15     you see, the impression that I had was that the fact that Muslim and

16     Croat policemen had left the SJB in Brcko was, at least in part, a result

17     of the take-over of the police station there, so in my understanding it

18     would be natural for the Muslim and Croat police officers to leave the

19     station, but I would then assume that the station would be manned with

20     Serb police officers and fully manned.  But if this is not a correct

21     description of the facts, then I would like you to tell us why not.

22             THE WITNESS: [Interpretation] I can't give you the answer.  I'm

23     simply presenting the factual situation.  I arrived in that police

24     station, as I said, in order to help the organisation and the structuring

25     of the police station as well as the normalisation of the police work.

Page 21414

 1     What led to the fact that after the bridges on the Sava river had been

 2     destroyed, most of the Serb personnel left the police station, I'm unable

 3     to explain.

 4             MR. HANNIS:  Your Honour, if I may, pertinent to the questions

 5     that you were just asking, I would direct your attention to adjudicated

 6     fact 1245 in this case.  It may shed some light on it or give rise to you

 7     asking other questions.

 8             JUDGE HARHOFF:  Thank you, Mr. Hannis.

 9             Back to you, Mr. Zecevic.

10             MR. ZECEVIC: [Interpretation] Thank you.

11        Q.   Mr. Andan, where did you sleep while you were in Brcko?  You said

12     that the first night you spent in a hotel.  And after that?

13        A.   After that, at the upper floor of the police station, I was given

14     a room.  They put a military bed in that room and a wardrobe for my

15     stuff.  So the time that I spent in Brcko, is the time that I spent

16     overnighting in that police station.  Maybe this is not a courageous

17     thing but it's a fact, the first night when I entered the police station,

18     I put a heavy metal safe in front of the door, in front of my door,

19     because I was afraid for my own security, having observed everything that

20     was going on in the town of Brcko and in the police station.

21        Q.   Could you briefly explain what is it that you saw going on in the

22     town of Brcko outside the police station?

23        A.   Well, armed people, drunk people, soldiers and whatever other

24     formations who went around shooting with open bottles.  It was a terrible

25     situation for me and that's the reason why I put that heavy metal safe in

Page 21415

 1     front of my door before I spent the first night in the police station.

 2        Q.   Did you subsequently learn what kind of individuals they were?

 3     Were they paramilitary formations, military formations, or something

 4     else?

 5        A.   They were mostly paramilitary formations.  They were not under

 6     the control of the army.  According to law, they should have been

 7     re-subordinated to the military and the military should have assigned

 8     them tasks.  They were paramilitaries.  I come back again to the

 9     Red Berets belonging to Captain Dragan and that Rade person.  In Brcko

10     they did practically whatever they wanted.

11             Besides the paramilitary formation, units from Bijeljina used to

12     come as well.  That's when I had the opportunity for the first time to

13     encounter the Panthers belonging to Ljubisa Savic, Mauzer.  There were

14     other structures, military or semi-military, that were completely

15     unfamiliar to me.  I spent a short period of time in Brcko and I couldn't

16     really find out exactly who they were.

17        Q.   While you stayed in Brcko did you receive any intelligence as to

18     what was the reason for such a strong presence of so many paramilitary

19     formations and individuals that you observed in Brcko?

20        A.   As far as I know, Brcko was one of richer municipalities in

21     Bosnia and Herzegovina.  It was prosperous, it had industry, there was a

22     harbour on the Sava river which meant that Brcko was, via the Danube,

23     connected all the way to Vienna.  So it was a prosperous municipality.

24     All the paramilitary formations concentrated first and foremost on

25     plunder.  Let me give you a piece of information that is maybe inaccurate

Page 21416

 1     but that's what I heard then.  150 trucks of Marlboro cigarettes were

 2     taken away from the harbour in Brcko.  There was the primary motive,

 3     plunder.

 4        Q.   Was there free customs export zone in Brcko before those events?

 5        A.   Yes, there was such a zone.

 6        Q.   As far as you know, apart from the cigarettes were there any

 7     goods that were on consignment in the customs warehouse?

 8        A.   Yes.  When I went to my following task in Bijeljina, and we are

 9     probably going to touch upon the topic later, so when my task was

10     establishment of check-points, we would definitely come across people

11     coming back from Brcko who in their vehicles transported alcohol,

12     electric goods which means that customs-free zone in Brcko contained also

13     that kind of goods.

14        Q.   Let us go back to record of meeting in Brcko, the meeting that

15     you had initiated.  Was a commander of the police station appointed after

16     this meeting?

17        A.   Yes, a commander was appointed.  It was Mr. Petar Djokic.  His

18     deputy and two or three assistants were also appointed.  I think that I

19     proposed that Mr. Petar Djokic to Mr. Veselic to be appointed commander.

20     I learned that he graduated from the secondary police school in Sarajevo

21     and subsequently from the law faculty in Belgrade.  He was born in Brcko,

22     which means that he was well acquainted with the general situation in

23     Brcko at the time.

24        Q.   Does that mean that on this meeting the very foundations for

25     proper functioning of the police station in Brcko were laid?

Page 21417

 1        A.   Yes.  We did not have old rule books at hand, for instance, the

 2     rule book on the proper way of functioning of the public security service

 3     and we didn't have the text of the law, however, we defined in brief

 4     outlines the tasks of all managerial positions in the police station.

 5     And it was to serve as some sort of aide-memoire for them and it defined

 6     the basic principles of work in the police station.

 7             MR. ZECEVIC: [Interpretation] if there are no objections, I

 8     tender this document.

 9             MR. HANNIS:  No objections.

10             JUDGE DELVOIE:  Mr. Stanisic -- sorry, Mr. Zecevic, the meeting

11     the witness was referring to a few minutes ago, is that the meeting in

12     the -- is that this document, the minutes?

13             MR. ZECEVIC:  Yes, he confirmed that is the minutes of the first

14     meeting --

15             JUDGE DELVOIE:  That's on the 2nd of June?

16             MR. ZECEVIC:  Yes.

17             JUDGE DELVOIE:  Thank you.  Then I have another question.

18     Mr. Andan, the blowing up of the bridges over the Sava, we have heard

19     information that that happened on the 30th of April.  You said the

20     beginning of April but you also said don't take me -- don't take my word

21     on dates, so I'm wondering, would the -- could 30 April be correct as far

22     as you know?

23             THE WITNESS: [Interpretation] Should I answer?

24             JUDGE DELVOIE:  If you can, yes.

25             THE WITNESS: [Interpretation] Well, I don't know.  As I told you,

Page 21418

 1     when it comes to dates they are not my strength.  It's quite possible

 2     that it's the 30th.  I cannot claim with any certainty that it was either

 3     on the 6th April or on the 30th of April.  I simply know that it happened

 4     around about that time.

 5             JUDGE DELVOIE:  Okay.  Thank you.

 6             JUDGE HALL:  So the document is admitted and marked.

 7             THE REGISTRAR:  Exhibit 1D546, Your Honours.  47, I apologise.

 8             MR. ZECEVIC: [Interpretation]

 9        Q.   Mr. Andan, since you slept in the public security station in

10     Brcko, after you arrived and while you stayed there did you encounter the

11     people who were imprisoned in the public security station in Brcko?

12        A.   I'm not sure what people you are referring to.  Could you be more

13     specific?

14        Q.   I'm referring to the people who had been detained in the station,

15     civilians and primarily people of non-Serb ethnicity?

16        A.   No, I did not encounter anybody like that.

17        Q.   After this meeting was there -- was a practice instituted in the

18     public security station in Brcko that certain registers should be kept?

19        A.   After the military granted our request and the policemen returned

20     from the front line, the first thing that we did was to divide the area

21     of the station in various subareas and patrol sectors.

22        Q.   Just a moment.

23             MR. ZECEVIC: [Interpretation] Can we have P153 MFI.  Tab 23.

24        Q.   Excuse me, I interrupted you.  Do go on.

25        A.   So we agreed to divide the station area in various sub-areas and

Page 21419

 1     patrol sectors.  I think that on that occasion we also appointed leaders

 2     of the patrol sectors.  We re-established the functioning of patrols.

 3     Normally when you say a patrol, you refer to two policemen.  But because

 4     of the situation that prevailed at the time in the Brcko municipality, we

 5     reinforced the patrols so our patrols were constituted of four policemen.

 6     We also agreed that important buildings such as the municipality building

 7     and the police station should be secured by the policemen while all other

 8     points should be secured by the Territorial Defence or the army.  So we

 9     tried to diminish the number of people working on security of those other

10     facilities.

11             After that we formed an intervention unit numbering around 30

12     lads.  Its purpose was if there were any problems at check-points that we

13     had established at the entrances to the town, the purpose was to be ready

14     to help the policemen working on the check-points on short notice if

15     necessary.

16        Q.   What was the main reason for establishment of the check-points at

17     the entrance to the city?

18        A.   The check-points had been established in order to prevent plunder

19     and transportation of material goods from the Brcko municipality.  That

20     was the primary purpose at the time.

21        Q.   Thank you.

22        A.   I still owe you one more reply.  When I spoke that we

23     re-established the registers and other log-books in the police station,

24     we did whatever we could at the time.  First and foremost we started with

25     the daily event log.  That's a document where all the events that occur

Page 21420

 1     within 24-hour period are registered.  After that we introduced a special

 2     list where all people working in the police station were registered, as

 3     well as their tasks and assignments.  Then we also introduced the

 4     criminal register, the KU book.  I also proposed to introduce the daily

 5     event bulletin.  It was our attempt to inform the political structures of

 6     the security situation for every 24-hour period.  We did one more thing.

 7     That daily bulletin we distributed as well to the media.  It means that

 8     every morning at 8.00 in the morning, the Brcko radio station was in a

 9     position to inform the citizens about all relevant events in the

10     territory of the Brcko municipality at the time.

11             And in the end let me mention one more thing, one more step that

12     we undertook.  We requested from the competent municipal authorities, and

13     I refer to the political authorities here, to introduce a curfew.  We

14     informed the citizens via the Brcko radio station that a curfew would be

15     introduced.  I think that it lasted from 9.30 in the evening until 5.30

16     in the morning.  I'm sure that this also functioned in the manner that I

17     described.

18        Q.   Before moving on to comment on the documents that you introduced,

19     tell me what the reason was for your suggestion to impose a curfew in

20     Brcko?

21        A.   The reason was again the looting of property, breaking and

22     entering the houses of non-Serb citizens, and moving into those houses.

23     All that would happen in the night hours in the previous period.  And we

24     wanted to protect all citizen, when I say all, whoever was in Brcko at

25     the time.  We wanted their property and their safety to be equal or to

Page 21421

 1     enjoy equal treatment to that of all other citizens of Brcko.

 2        Q.   I know that you stayed in Brcko briefly, but did these measures

 3     yield any results as far as you know?

 4        A.   They did, but the police also had some problems in that regard.

 5     The police station was attacked by paramilitaries on several occasions.

 6     Even fire-arms were used.  As a result, we brought in some 40

 7     paramilitaries in a raid and as far as I remember they had kidnapped

 8     Major Sehovac and they tried to blackmail us to release their members and

 9     they would release Major Sehovac in return.  If we failed to do that,

10     they would kill him.

11        Q.   Very well, we'll get to that detail yet.  We have a document in

12     front of us.  It reads "Information" and it's signed by Petar Djokic,

13     commander of the police station.  This is about the situation on 8 June,

14     as we see.  At that point in time we read that the strength of the police

15     station was 363 of which number 31 are active-duty members.  Is this the

16     situation after the military returned a number of MUP members from the

17     front line?

18        A.   Yes.  This is this report and I only need to add that my

19     colleagues from Brcko went to the houses and apartments of the Serbian

20     colleagues who had left the Brcko police station and did not respond to

21     calls.  I think that there were 34 active-duty police officers and

22     everybody else was a reserve police officer.

23        Q.   If I understood you correctly, these active-duty officers, that

24     is, the number mentioned here in this report, were those you found in

25     Brcko, those five or six, plus the ones they went to fetch from their

Page 21422

 1     houses or apartments to come back to the police station.  Did I

 2     understand that correctly?

 3        A.   Yes, you did.

 4        Q.   And these members of the reserve force, that is 330 odd, were

 5     sent back from the military?

 6        A.   Part of the reserve police force was present at the police

 7     station but probably they didn't have particular assignments.  However,

 8     the majority were returned from the front line and they took up their

 9     duty at the police station.

10        Q.   Thank you.

11             MR. ZECEVIC: [Interpretation] I suggest that this -- that the MFI

12     mark should be removed from this document unless Mr. Hannis is opposed.

13             MR. HANNIS:  I agree with that suggestion.

14             JUDGE HALL:  So it is, the MFI status is removed.

15             THE REGISTRAR:  Your Honours, just for the record this is

16     Exhibit P153.

17             MR. ZECEVIC: [Interpretation] The next document is 65 ter 181D1.

18     Tab 9 in your binder, Mr. Andan.

19        Q.   Sir, before we comment on this document you have listed the

20     documents -- or, rather, the types of documents that were kept at the SJB

21     of Brcko after your arrival.  That list you mentioned, were you able to

22     see it once it was established at the Brcko SJB?

23        A.   Yes, I insisted on it and that register was opened.  It was kept

24     by the deputy commander of the police station.  It was a list of duty

25     assignments.

Page 21423

 1        Q.   Did that list contain the names of police officers providing

 2     security to some facilities or manning some check-points and the like?

 3        A.   Yes.  Next to the name of the officer, there was also mention of

 4     the nature of the assignment.  For example, securing a facility.  Mostly

 5     we used abbreviations such as OB or PS or PAT for patrol service.  That

 6     is how it should have been and I think it really was.

 7        Q.   Mr. Andan, do you know that in the territory of Brcko

 8     municipality there was a collection centre or prison by the name of Luka?

 9        A.   Yes.  After the introduction of all elements for the

10     normalisation of the functioning of the police station, at some time

11     toward the end of my stay, I heard of that collection centre, which was

12     also called a camp, which was called Luka at Brcko.

13        Q.   As far as you know did the SJB or MUP members in general have

14     anything to do with that Luka camp?

15        A.   While I was there and according to some information from the

16     previous period, I can say that the SJB had no authority over Luka.

17        Q.   Thank you.  Tell me, sir, this document we see on the screens, do

18     you know it and can you tell us who drafted it?

19        A.   I did, but my signature is missing.  I suppose that this report

20     was sent to the MUP with an accompanying letter or a cover letter.  This

21     report itself is not signed but the cover letter must have been signed.

22        Q.   When you say it was sent to the MUP, does that mean it was sent

23     to the Bijeljina CSB?

24        A.   Since the MUP of the RS sent me to Brcko, the current practice

25     was that I was supposed to inform the administration, the relevant

Page 21424

 1     administration of the MUP, and that was the administration of the police,

 2     and the relevant branch of the CSB which was the Bijeljina CSB.

 3        Q.   In this report we see, I think it's the second sentence:

 4             "Shortly after the bridges were destroyed on 30 April 1992, the

 5     operation of the station has practically stopped."

 6        A.   Yes.

 7        Q.   Can you now confirm the date of the destruction of the bridges

 8     for the Trial Chamber?

 9        A.   Yes, clearly this is my report, the report I drafted, and the

10     date must be correct.  And I apologise again as regards the dates,

11     because I have already stated that I'm not good at dates.

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

13     evidence unless there's opposition.

14             MR. HANNIS:  Your Honour, could I perhaps request that there's an

15     inquiry made as to whether this is the complete document because the

16     second page ends in the middle and I don't know if there was something

17     additional.  If the witness can verify that's the total and complete

18     report he sent.

19             MR. ZECEVIC: [Interpretation]

20        Q.   You heard the question, Mr. Andan, take a look at the document,

21     please, and then confirm that the document is complete.

22        A.   Yes, this document is complete and I've already explained the

23     procedure.  I've explained why my signature is missing on the second

24     page, because probably I signed the cover letter with which this was sent

25     to Pale and Bijeljina.  However, the cover letter hasn't been shown.

Page 21425

 1             MR. ZECEVIC: [Interpretation] Thank you.

 2             MR. HANNIS:  No objection.

 3             JUDGE HALL:  The cover letter hasn't yet been located or has it

 4     been otherwise exhibited, what is the position?

 5             MR. ZECEVIC:  I am afraid not, Your Honours.

 6             JUDGE HALL:  So the document is admitted and marked.

 7             THE REGISTRAR:  As Exhibit 1D548, Your Honours.

 8             MR. ZECEVIC: [Interpretation]

 9        Q.   Mr. Andan, tell me when and where you met Mr. Mico Davidovic for

10     the first time.

11        A.   I first met him on an afternoon as far as I remember at the Brcko

12     police station.  He arrived in uniform in a Puh vehicle and he wanted me

13     to give him information on the security situation in the Brcko and I made

14     a brief presentation about what we had done and what our plans were for

15     the coming period.  As far as I remember, he then informed me that he had

16     arrived at the Bijeljina CSB and the kind of work that we had done in

17     Brcko should also be done at other SJBs under the CSB of Bijeljina and in

18     Bijeljina itself, the town.  And he was interested in what we had done in

19     Brcko and what our intentions were.  That was my first meeting with

20     Mr. Mico Davidovic.

21        Q.   Can you remember when it was roughly, or at least which period it

22     was when he came to see you?  You have repeatedly said that you aren't

23     good at dates.

24        A.   I think it was in the first half of June.  May have been on the

25     10th or 12th or 15th, I don't know, but I think it was in the first half

Page 21426

 1     of June of 1992.

 2        Q.   Very well.  How much time did you spend in Brcko in all?

 3        A.   I think that I was there for two weeks, a day more or less, I

 4     don't know, but no longer than that.

 5        Q.   Pursuant to whose order did you leave Brcko?

 6        A.   I left Brcko pursuant to Cedo Kljajic's orders who at the time

 7     was undersecretary of public security and he was with the Bijeljina CSB.

 8        Q.   What did Cedo Kljajic order you to do?

 9        A.   We first spoke on the phone as far as I remember, and he told me

10     that my mission in Brcko was accomplished, that the basic reasons I had

11     been sent there for were met and when I arrived at Bijeljina that we

12     would discuss my future assignments.

13        Q.   Sir, how shall I put this, were you satisfied with what was done

14     in Brcko over those two weeks in terms of constituting the public

15     security station?

16        A.   Generally speaking, I think I was satisfied.  I haven't had an

17     opportunity to tell you about some of the other things that we did in

18     Brcko.  If you allow me, I'm going to say that as well.  In addition to

19     this basic police activity, we constituted a crime prevention service

20     there, we appointed the chief of the crime prevention service, and this

21     crime prevention service started operating.  As for the administrative

22     department, we constituted that as well.  We appointed a head of the

23     administrative department.  I've already said that no longer people were

24     able to walk into the police station with a rifle and to take driver's

25     licences, traffic licences, licence plates and so on when they were

Page 21427

 1     armed, so we stopped that kind of thing and citizens could go to the

 2     administrative department in a legal and legitimate way and take care of

 3     the business that they had to.

 4             Also, we established a depository.  We had these certificates

 5     about things that were temporarily taken from persons.  Also, for cars

 6     that were seized from various individuals, most of these vehicles had

 7     been stolen in the first place.  Since the Brcko police station has this

 8     wonderful area for a kitchen, we actually made this kitchen there where

 9     all the employees of the police station were able to have a hot meal

10     during the course of 24 hours.  There were other things that we were

11     supposed to do, but basically I was satisfied with what we did and I was

12     satisfied with the way people treated me and also the job that we were

13     doing at the time.

14        Q.   Sir, on page 22, line 21, or rather, 20, you said that you then

15     constituted a crime prevention service in the public security station in

16     Brcko?

17        A.   Yes.  Yes.  We did that too.  And I think that at that point in

18     time we had six or seven operatives and a chief at that.

19        Q.   Am I understanding you correctly, namely that this crime

20     prevention service, the crime police, had not been operating before that?

21        A.   It had not been operating before that.  I found a person there

22     who was chief of the department of national security and the crime

23     service.

24        Q.   I will have to take you back to tab 15.  1D547.

25             MR. ZECEVIC: [Interpretation] Page 7 in e-court, the Serbian

Page 21428

 1     version.

 2        Q.   Number 4, that's what the actual number on the page is, it says

 3     "Crime", that's the subheading and then the first sentence:

 4             "Tasks and work in the field of crime prevention function

 5     practically from the time when the division took place, that is the

 6     establishing of the Brcko Serb SJB."

 7             THE INTERPRETER:  The interpreter did not hear Mr. Zecevic's

 8     question.

 9             MR. ZECEVIC: [Interpretation]

10        Q.   Then it says that a person from the national security or rather

11     state security -- I do apologise.  What I said is that in this first

12     sentence that negation is missing, isn't it?

13        A.   I agree.

14        Q.   Is this a typo?  That's what it is most probably.

15        A.   Of course.  It's a typo, and this work was being done in most

16     substandard conditions.

17        Q.   Thank you.  Mr. Andan, just a few more questions in relation to

18     Brcko, and then we are going to move on to a new topic.

19             MR. ZECEVIC: [Interpretation] For the Trial Chamber, this is an

20     adjudicated fact.  It is 1255.

21        Q.   Does the name Goran Jelisic from Brcko ring a bell?

22        A.   I never met this person but I know the name of Goran Jelisic,

23     nicknamed Adolf.  That is the how he introduced himself in Brcko and that

24     is what the top police personnel at the public security station in Brcko

25     said to me.

Page 21429

 1        Q.   [Microphone not activated]

 2             THE INTERPRETER:  Microphone, please.

 3             MR. ZECEVIC: [Interpretation]

 4        Q.   Do you know a person by the name of Kosta Kole Simeunovic, a

 5     member of the police in Brcko?

 6        A.   No.

 7        Q.   Do you know this, that this certain Kosta Kole Simeunovic was,

 8     how shall I put this, in charge of the Luka camp sometime from May or

 9     June 1992 when you were in Brcko?

10        A.   No.

11             MR. HANNIS:  Your Honour, I had an objection.  If he doesn't know

12     the person then he can't know whether he was in charge of something.

13             MR. ZECEVIC:  I'm trying to refresh the memory of the witness if

14     he perhaps knows.  If I give him additional information, maybe he refresh

15     his memory.

16             JUDGE HALL:  Perhaps you can rephrase the question.  I understand

17     what you are trying to achieve, Mr. Zecevic.

18             MR. ZECEVIC: [Interpretation]

19        Q.   Sir, do you know that a certain Simeunovic was in May or June

20     1992 the person in charge of the Luka camp in Brcko?

21        A.   No, I'm not aware of that.

22        Q.   Oh, I've actually already asked you that.  Thank you.  Tell me,

23     sir --

24             MR. ZECEVIC: [Interpretation] For the Trial Chamber this is

25     adjudicated fact 1259.

Page 21430

 1        Q.   Do you know about this company, it's probably a forwarding

 2     company called Laser from Brcko?

 3        A.   I know about that company.  It exists in the territory of Brcko

 4     to this day.

 5        Q.   Do you know that in 1992 in the premises of that company Muslim

 6     and Croat civilians were detained?

 7        A.   No, I don't know about that.

 8        Q.   When I say know or aware of something, did you receive such

 9     information while you were in Brcko or subsequently when you worked in

10     Bijeljina?

11        A.   No, I have not received such information, although in terms of

12     our programme orientation, we were supposed to go back to Brcko with

13     fresh forces and practically to collect all this information and

14     intelligence and process it further.

15        Q.   Do you know of this place called Vestfalija, a restaurant that

16     was a collection centre or prison where Muslims were held, or rather

17     Muslim and Croat civilians?

18        A.   No, I don't know about that.

19        Q.   Do you know that at the football stadium in Brcko, actually did

20     you have any intelligence to that effect, that at the football stadium in

21     Brcko Muslim and Croat civilians were detained during the course of 1992?

22             JUDGE HARHOFF:  Mr. Zecevic, could I just ask you if this line of

23     questioning is designed to challenge adjudicated fact 1259?

24             MR. ZECEVIC:  Yes, Your Honours.

25             JUDGE HARHOFF:  I think, but I need to consult the rules and the

Page 21431

 1     guide-lines that we have adopted, but I think that there was some sort of

 2     an agreement that when you wish to challenge adjudicated facts that you

 3     let us know in advance.  Thanks.

 4             MR. HANNIS:  Your Honour, he had indicated in the proofing note

 5     that he was going to address certain adjudicated facts about Brcko and

 6     Bijeljina, and I had received a copy of that.  I don't know if

 7     Your Honours did.

 8             JUDGE HARHOFF:  Oh, thank you very much.  I was unaware of that.

 9             MR. ZECEVIC:  Your Honours, I sent according to the -- exactly --

10             JUDGE HARHOFF:  Mr. Zecevic, I apologise, I was not aware of the

11     proofing note, so please move on.

12             MR. ZECEVIC: [Interpretation]

13        Q.   Sir, to make this as short as possible, do you have any knowledge

14     to the effect that Muslim and Croat civilians, during the course of 1992,

15     were held in Brcko at the primary school in Loncari DTV Partizan and in

16     Pelagiceva [phoen], in some shop, co-operative shop or store in

17     Pelagiceva?

18        A.   No, I did not know about any of that.

19        Q.   During your stay in Brcko from the employees -- or, rather, did

20     you receive from the employees of the public security station any

21     information or intelligence about security-related incidents that they

22     had at their disposal?

23             JUDGE HALL:  Can we have a moment, Mr. Zecevic.

24                           [Trial Chamber confers]

25             JUDGE HARHOFF:  Forgive me for bringing this up again,

Page 21432

 1     Mr. Zecevic.  I do see that in your proofing notes that you are

 2     mentioning that the witness will testify about some of these facts,

 3     including 1259.  However, all information that the witness has given so

 4     far is that he doesn't know about the existence of some of the facts that

 5     are contained in that adjudicated fact, so if you have nothing more in

 6     terms of a challenge than the witness not knowing about the existence of

 7     certain buildings and so on, then I question again whether this is a

 8     useful path to proceed on.

 9             MR. ZECEVIC:  Well, if the witness can take off his earphones and

10     I will explain.

11             Your Honours, the witness is the inspector of the police from MUP

12     of Republika Srpska.  He comes to Brcko.  He is sent from the MUP to

13     investigate what is the situation, the security situation in Brcko.  If

14     he doesn't have the information that these detention centres exist at all

15     in the -- in Brcko, he said he had the information about the Luka camp

16     and he is not disputing that.  He is disputing -- he is saying that the

17     Luka camp had nothing to do with the police, but he is not disputing the

18     existence of the Luka camp.  However, he says that they had no

19     information whatsoever that the detention centre existed on these other

20     five or six locations in Brcko, as the adjudicated fact says.

21             Now, if the police doesn't know that, then obviously,

22     Your Honours, that goes for the knowledge of the MUP at its seat by all

23     means, not only to -- not only suggesting that it is very unlikely that

24     the adjudicated fact is a true fact if the police doesn't know about it.

25     Surely the police should have known about the existence of such detention

Page 21433

 1     centres.

 2             JUDGE HALL:  We understand the argument that you are placing

 3     yourself in a position to make and I suppose for practical purposes,

 4     the -- there is no other course open to you than the line of questions

 5     you've been asking and the questions you have been receiving from this

 6     witness, but the argument really is -- will have to come later.

 7             MR. ZECEVIC:  Well, Your Honours, I'm sorry, I wasn't trying to

 8     make an argument.  I was just trying to explain because I was invited by

 9     His Honour Judge Harhoff to explain.

10             JUDGE HALL:  We understand.  We understand.

11             MR. ZECEVIC:  I see the time, Your Honour, perhaps we can take a

12     break now.

13             JUDGE HALL:  Yes.  So we resume in 20 minutes.

14                           [The witness stands down]

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

16                           --- On resuming at 10.51 a.m.

17                           [The witness takes the stand]

18             MR. ZECEVIC:  Thank you, Your Honours.

19        Q.   [Interpretation] Mr. Andan, just before the break I asked you a

20     question but your answer was not recorded because of the intervention by

21     the Chamber.  Page 27, line 18.  My question went as follows:

22             "During your stay in Brcko, did you get any information or

23     intelligence from the employees of the public security station in Brcko

24     related to the security-related events?"

25        A.   The practice before the war was as follows:  When an operative

Page 21434

 1     comes from the fields he has to type a report.  Bearing in mind that we

 2     did not have the possibility to type up reports in Brcko at the time, we

 3     agreed that at the end of each working day they should simply write out

 4     their report by pencil.  Such reports were then submitted to the

 5     commander of the police station every day.  He analysed them.  Whatever

 6     had to be sent to the crime department, he would send to the crime

 7     department.  Anything related to the public law and order and general

 8     police work, he would analyse with his associates and then issue

 9     instructions and then the following day when the police would go out, he

10     would assign new tasks or comment on the reports written the previous

11     days, tell the policemen what they should be alert to, and whatever else

12     was important.

13        Q.   I did not want to interrupt you, my question was as follows:  You

14     said that when you arrived in Brcko, you met with the then chief, that

15     there were five or six other people in the duty service.  When you had

16     the meeting with the chief, did you get any intelligence from him about

17     the situation in Brcko, about what was going on in Brcko?

18        A.   It wasn't a very extensive report but he informed me about the

19     current security situation in Brcko, whatever was relevant for the police

20     structures.

21        Q.   Thank you.  When you returned to Bijeljina, to whom did you

22     report?

23        A.   I reported to the undersecretary for public security, Mr. Rajic

24     [as interpreted], who was already in Bijeljina at the time.

25        Q.   You said that when you first arrived in Bijeljina at the end of

Page 21435

 1     May, Predrag Jesuric gave you the order, and we saw a document related to

 2     that, to go to Brcko.  Do you remember whether Mr. Jesuric was still in

 3     Bijeljina when you returned?

 4        A.   I think he was not.

 5        Q.   When describing your first arrival you said that you saw a

 6     certain Dragan Devedlaka.  When you returned from Brcko was Mr. Devedlaka

 7     still in Bijeljina?

 8        A.   No, he was not in Bijeljina.  As far as I know in May when I saw

 9     him and when he told me that I should flee from Brcko, he left, he

10     arrived to -- he arrived in Serbia, and he never returned to the

11     territory of Republika Srpska or Bosnia and Herzegovina.

12        Q.   He warned you to flee from Brcko --

13             MR. HANNIS:  I am sorry, just an intervention on the transcript

14     if I could.  I think at page 30, line 23, the last name is incorrectly

15     recorded, if we could clarify that before we move too far.

16             MR. ZECEVIC:  Thank you very much, Mr. Hannis.

17        Q.   [Interpretation] The undersecretary for public security to whom

18     you reported, we have his name recorded as Rajic.  What was exactly the

19     name as the undersecretary for public security that was already in

20     Bijeljina at that time?

21        A.   No, it's misinterpreted.  The name is Kljajic, not Rajic.

22        Q.   Thank you.  On page 31, I asked you about Dragan Devedlaka, and

23     you said, as far as I know in May when I saw him, and when he told me

24     that I should flee from Brcko, he left to Serbia and never returned to

25     the territory of Republika Srpska or Bosnia and Herzegovina.  Did

Page 21436

 1     Dragan Devedlaka told you to flee from Brcko or from Bijeljina?

 2        A.   I wouldn't like to make a mistake but I think that I said also

 3     the first time to flee from Bijeljina.  Maybe it's wrong interpretation.

 4        Q.   Thank you.  It wasn't wrong interpretation, you misspoke.

 5        A.   I apologise.

 6        Q.   What assignment were you given upon your return in Bijeljina?

 7        A.   I believe we waited for Mr. Mico Davidovic.  He was already in

 8     Bijeljina.  We had a meeting.  At that meeting we defined our further

 9     activities.

10        Q.   What was the purpose of your further activities, could you

11     explain briefly?

12        A.   The police station or the security centre in Bijeljina faced many

13     problems.  The situation had to be stabilised within the police station,

14     and our other goal, which is defined in the Law on the Interior is the

15     protection of citizens and property, prevention of plunder, expulsion of

16     persons, and other criminal offences that we are probably going to

17     discuss later.

18        Q.   According to the information you received at the meeting what is

19     your opinion -- what was the situation that you faced in Bijeljina at the

20     time, or maybe perhaps you should first tell us exactly what time-period

21     you are referring to?

22        A.   I told you that I spent two weeks at most in Brcko, so it could

23     have been the end of the first half of June 1992.  The situation in

24     Bijeljina was very difficult.  There were significant political problems.

25     There were two paramilitary formations that had not been re-subordinated

Page 21437

 1     to the military.  They attempted to dominate the government structures of

 2     Bijeljina.  I refer here to the Panthers led by Ljubisa Savic, Mauzer,

 3     and the Serb Volunteer Guard led by Vojvoda Mirko Blagojevic.  This

 4     internal conflict had consequences on the security situation in

 5     Bijeljina.  They attempted to impose their personnel in the police

 6     station and in the security centre in Bijeljina.  They wanted to control

 7     the work of the security centre in Bijeljina by that.

 8        Q.   So having learned all this, what did you do or attempt to do?

 9        A.   I don't know whether in the meantime a dispatch had arrived from

10     the Ministry of the Interior in Pale in which it was ordered explicitly

11     that all persons with criminal files who were currently in the

12     Ministry of the Interior and the policemen for whom it can be proved that

13     they took part in criminal activities had to be eliminated from the

14     Ministry of the Interior.  So I'm not quite sure whether it was before or

15     after dispatch, but we did that in accordance with the law.  We carried

16     out the so-called triage of the policemen and removed around 40 policemen

17     from the force.

18             Later it led to anger and the pressure exerted on me and other

19     employees of the police station.  I can elucidate on that later if you

20     want me to.  So this was the first step that we took in the police

21     station in Bijeljina.  We dealt with the internal order and organisation

22     again.  We established high criteria for entrance into the police station

23     that pertained to various military and paramilitary formations carrying

24     long barrels.  That is to say, we did not allow people to enter the

25     police station with long barrels.  We did the same thing that we did in

Page 21438

 1     Brcko.  They had to deposit their weapons upon entering the police

 2     station.  They would receive a certificate and then they would get it

 3     back upon leaving.

 4             After that we analysed the division of the area belonging to the

 5     public security station in Bijeljina.  We worked out an appropriate

 6     division into sub-areas and patrol sectors.  They were all preliminary

 7     tasks that had to be done before operative actions that would follow.  We

 8     did not have to introduce new documents in Bijeljina and by that I mean

 9     the daily event log, the register, the KU register, all this existed in

10     the police station in Bijeljina, however, it wasn't filled in in an

11     appropriate way until we arrived and issued strict orders in relation to

12     that.

13             So in this area as well we issued strict orders that everything

14     that happened within a 24-hour period should be recorded.  We also

15     started issuing a daily event bulletin.  Every morning at 8.00 in the

16     morning, we would distribute it to the media.  There was, if I remember

17     correctly, a radio station called Radio Semberija and Majevica.  We would

18     deliver our bulletin to them every morning so that the citizens in

19     Bijeljina municipality could be apprised of all the events that had

20     occurred within the previous 24 hours in the territory or the

21     municipality.

22        Q.   Mr. Andan, did the public security station Bijeljina and the

23     Security Services Centre Bijeljina share the same building?

24        A.   Yes, they shared the building.  The police station was on the

25     ground floor, the premises of the security centre were on the upper

Page 21439

 1     floor.

 2             MR. ZECEVIC: [Interpretation] Before we go into details with

 3     regard to the situation in Bijeljina, I would like to take a look at

 4     P338, tab 26.

 5        Q.   [Microphone not activated]

 6             THE INTERPRETER:  Microphone, please.

 7             JUDGE DELVOIE:  Microphone, please.

 8             MR. ZECEVIC:  Thank you very much.  Sorry.

 9        Q.   [Interpretation] Mr. Andan, this is a report on inspection

10     conducted and situation found at SJB Brcko, SJB Zvornik, and partially

11     the situation at SJB Bijeljina.  The date is the 17th of June, 1992, and

12     on the last page we see your name and your signature.  As well as the

13     name and signature of Danilo Vukovic.  Mr. Andan, is this your report

14     that was submitted to the Ministry of the Interior on the 17th of June,

15     1992?

16        A.   Yes.

17        Q.   Is this a joint report made by you and Mr. Vukovic?

18        A.   Yes.

19        Q.   Thank you.

20        A.   Excuse me, if you allow me -- oh, it was corrected.  First it was

21     Vukotic in the transcript and now it's Vukovic.

22        Q.   Mr. Andan, can we take a look at 65 ter 13D1, tab 27.  Let us

23     wait for the English translation of the document.

24             This is a document originating from the Ministry of the Interior

25     dated the 24 of June 1992, sent to the Bijeljina public security station.

Page 21440

 1     If you take a look at the signature, tell us whether you can recognise

 2     it, and do you know what this document is about?

 3        A.   This is a request sent to the police station in Bijeljina.  It

 4     relates to some police inspector, I don't know whether somebody came from

 5     Sarajevo or whether it was some sort of inspection, but the crux of the

 6     matter is that that person needed a vehicle.  I'm not sure about the

 7     signature, but I think that it could be the signature of Cedo Kljajic.

 8        Q.   Does this document relate to you or to Danilo or to somebody

 9     else, some other inspector?  When I say Danilo, I refer to Mr. Vukovic.

10        A.   I think that this document had nothing to do with us because in

11     the existing police station we already had had the cars that we could

12     use.

13        Q.   Thank you.

14             MR. ZECEVIC: [Interpretation] Can we have 65 ter 145D1.

15        Q.   Sir, Mr. Andan, you explained that after the meeting in

16     Bijeljina, you undertook certain measures, and what were the main

17     directions of those measures.  Did you undertake any other measures in

18     the field, and if so, which other measures?

19        A.   I must inform you that we also forwarded the information to the

20     media that a curfew was being imposed in Bijeljina from 9.30 p.m. through

21     5.30 a.m., and that it was published in the media and the objective was

22     the same, to prevent looting, illegal entering of other people's homes,

23     and many other criminal offences that were committed at night in the

24     Bijeljina municipality too.

25             We set up check-points at points of entry and exit, manned by

Page 21441

 1     police, to prevent the transportation of stolen goods from other

 2     municipalities or out of that municipality.  Brcko was the most

 3     prosperous municipality and most of the goods originated from there.  And

 4     to reach Bijeljina they had to cross either Pavlovica Most or the Raca

 5     border crossing to enter Serbia.  We set up such check-points at

 6     practically all points of entry into Bijeljina or points of exit.

 7             The staff manning those check-points had instructions to seize

 8     all stolen goods and detain persons carrying them.  Certificates for

 9     seized goods were issued and the goods themselves were placed in the

10     gymnasium of the police station.  We found a large plateau near

11     Radio Yugoslavia where we placed the stolen vehicles, whereas the small

12     items such as gold and jewellery were deposited in the strongbox at the

13     Bijeljina police station.

14        Q.   We have a document dated 28 June 1992 on our screens.  It's a

15     report of the public security service for 26 and 27 June 1992.  On page 3

16     of this document we read your name.  Can you tell us more about this

17     document, what it's about.  It's under tab 31.

18        A.   Yes, this is one of the reports that should be there in

19     accordance with the agreement and pursuant to the legislation in force,

20     we seized stolen items and goods from persons coming from other

21     municipalities to Bijeljina.  This is just an example of things that were

22     seized on that day.  The persons mentioned here were taken to the police

23     station and processed whereas the goods were deposited and appropriate

24     documents were drafted.

25        Q.   Since we see your name typed here but there is no signature, was

Page 21442

 1     it a document that was drafted pursuant to your instructions?

 2        A.   Yes, this is probably the same principle.  There must have been a

 3     cover letter because I see here that we not only sent this to the

 4     relevant department but we also copied the president of the Municipal

 5     Assembly of Bijeljina, the garrison commander of Bijeljina and other

 6     structures.

 7        Q.   That is exactly why I would like you to comment on the last

 8     paragraph of this document before the distribution list, if you can.

 9        A.   Yes.  We are stating here that we will continue the processing of

10     these suspects and submit criminal reports to the prosecutor's office.

11     We are hereby making it clear that honest people can feel safe in the

12     Bijeljina municipality.

13        Q.   When you are saying honest people, does that include non-Serbs

14     too?

15        A.   Yes, that was our duty under the law.  We couldn't discriminate

16     on racial or any other grounds.

17        Q.   Thank you.

18             MR. ZECEVIC: [Interpretation] I would like to tender this

19     document unless there's opposition.

20             MR. HANNIS:  No objection.

21             JUDGE HALL:  Admitted and marked.

22             THE REGISTRAR:  Exhibit 1D549, Your Honours.

23             MR. ZECEVIC: [Interpretation.

24        Q.   Please take a look at the following document, 65 ter 146D1.

25     That's tab 38 in your binder.  Can you tell us what this is about and

Page 21443

 1     what kind of activity preceded this?

 2        A.   We had intelligence that in the refrigeration plant, the

 3     construction of which began before the war, I forget the exact name of

 4     that location, that this refrigeration plant was used by Mauzer and his

 5     Panthers as a storage facility for stolen goods.  We checked that

 6     information and then we made a plan.  We raided the place and we expected

 7     armed resistance on the part of the Panthers who were guarding that

 8     warehouse.  Fortunately, the raid was well organised, or perhaps they

 9     were too confused, but they didn't have a chance to use their weapons, so

10     we overpowered them and locked them up in a room.  I think that we also

11     informed the prosecutor that we were about to search the place in

12     accordance with the regulations.

13             These documents show what we found in that warehouse that was

14     kept by Mauzer.  I needn't list the items, you can see the list yourself,

15     but both Mr. Davidovic and I were flabbergasted by something.  Since this

16     refrigeration plant was under construction and the cooling chambers were

17     already finished but there was no electricity, there was a large

18     aluminium door.  I opened one of these doors without any particular

19     intention and found three men inside.  They seemed exhausted and haggard

20     and I asked them who they were but they were probably too afraid to say

21     anything.  We took them out, we gave them some water and one of them said

22     that his name was Imsirovic and that the others were his brothers, that a

23     few days ago, a group of soldiers under the command of Mauzer had taken

24     them prisoner in the house in Bijeljina where they lived and taken them

25     to this place.  They recognised Mico Davidovic who lived in -- nearby and

Page 21444

 1     he confirmed their identity.

 2             We couldn't provide full protection for them.  We couldn't have

 3     police standing guard in front of their house, but we took them home in a

 4     patrol car.  We suggested to them that they should leave and go to live

 5     with some relatives because probably Mauzer would be back and then the

 6     result would be much worse for them.

 7             After many years while I was subject to OHR sanctions, one of the

 8     three Imsirovic brothers called me on the phone from Austria and he said

 9     that he was willing to make a statement to any prosecutor's office.  He

10     also said that his two brothers were also alive and that on that night

11     they had crossed the Sava to Serbia and moved on to Austria and Germany.

12     One of the three brothers was in Germany, the other in Austria, and the

13     third one at Zivinice.  He also called me on the phone and said that he

14     was willing to help me if necessary.

15        Q.   These Imsirovic brothers, what was their ethnicity?

16        A.   They were Muslims, and still are.

17        Q.   This document reads, it's a list of items that were stolen and

18     that were stored at the new slaughter-house in Obarska, is that the place

19     you meant?

20        A.   Yes.

21        Q.   And what did you do with these goods that you seized on that

22     occasion?

23        A.   Mauzer's unit should have been re-subordinated to the VRS

24     according to the command structure, and we gave these items to the army.

25     I see that it was confirmed here that the army -- that there was this

Page 21445

 1     hand-over to the army, and what they did with that later, I don't know.

 2             MR. ZECEVIC: [Interpretation] I would like to tender this

 3     document unless there is objection.

 4             MR. HANNIS:  No objection.

 5             JUDGE HALL:  Admitted and marked.

 6             THE REGISTRAR:  Exhibit 1D550, Your Honours.

 7             JUDGE HARHOFF:  Mr. Andan, could I, just out of curiosity, ask

 8     you what happened to the members of Mauzer's Panthers?  Did you arrest

 9     them and do you know if they were prosecuted for having stolen all these

10     things and detained illegally, I suppose, three Muslim men?

11             THE WITNESS: [Interpretation] I'm sorry that I laughed when you

12     asked this question but there is a he a good reason for that.  We

13     arrested Ljubisa Savic, also known as Mauzer, and we placed him in remand

14     custody.  We took away his side-arm which was a Heckler with a silencer.

15     And then Mauzer's entire unit attacked the police station with tanks and

16     all weapons that they had at their disposal.  Then we set up circular

17     Defence in a military fashion and defended ourselves to prevent Mauzer

18     from entering the police station.  That went on for a couple of hours

19     until the municipal authorities arrived, spoke to Mr. Kljajic,

20     Mr. Davidovic, and me, and found a Solomonic solution to release Mauzer

21     from detention and then the forces that had surrounded the police station

22     would withdraw.  That's what we did and I believe that we thus avoided an

23     armed conflict.

24             Savic was released from detention but we didn't return his

25     Heckler.  It remained at the police station.  That's how we solved the

Page 21446

 1     problem.  Don't lay me down on this, but I think that a report was made

 2     to the prosecutor's office for the criminal offences committed by Mauzer,

 3     but I don't know what happened later, you can believe me.

 4             JUDGE HARHOFF:  Thanks.

 5             MR. ZECEVIC: [Interpretation]

 6        Q.   Mr. Andan, do you know of the murder of one Salko Kukic in

 7     Bijeljina?

 8        A.   Yes, I'm familiar with that case.

 9             MR. ZECEVIC: [Interpretation] Please take a look at 65 ter 350D1.

10     That's tab 14.

11        Q.   This is an on-site investigation report dated 2 June 6 --

12             THE INTERPRETER:  Interpreter's correction:  1992.

13             MR. ZECEVIC: [Interpretation]

14        Q.   In Bijeljina.  It was drafted by the investigative magistrate, or

15     rather, the persons present for the investigative magistrate, the

16     representative of a Bijeljina prosecutor's office and two representatives

17     of the Bijeljina SJB.  I know that you weren't in Bijeljina at the time

18     but were you able to see this document later as part of a file?

19        A.   Yes, I saw this document.  This did not happen while I was in

20     Bijeljina, I was in Brcko at the time, but on the basis of this document

21     and on the basis of intelligence we took further operative measures aimed

22     at arresting the perpetrators of this heinous crime.

23        Q.   Thank you.

24             MR. ZECEVIC: [Interpretation] If there are no objections, I would

25     like to tender this document.

Page 21447

 1             MR. HANNIS:  No objection.

 2             JUDGE HALL:  Admitted and marked.

 3             THE REGISTRAR:  Exhibit 1D551, Your Honours.

 4             MR. ZECEVIC: [Interpretation] Could the witness please be shown

 5     1D -- actually, 65 ter 352D1.

 6             THE WITNESS: [Interpretation] What is the tab number?

 7             MR. ZECEVIC: [Interpretation]

 8        Q.   Tab 21.  Tell me, sir, the late Salko Kukic was an ethnic Muslim,

 9     wasn't he?

10        A.   Yes, he was.

11        Q.   Can you tell us what this document is about?

12        A.   I think that the crime service once they found out that Slavko --

13     that Salko Kukic had been murdered provided information to the then

14     prosecutor and on site they compiled photo documentation that is part of

15     the file and it shows the scene of the crime, that is to say the murder

16     of Mr. Kukic.

17        Q.   Thank you.

18             MR. ZECEVIC: [Interpretation] The next document is tab 11.

19     65 ter 351D1.

20             THE WITNESS: [Interpretation] Sorry, tab number?

21             MR. ZECEVIC: [Interpretation]

22        Q.   Tab 11.  Sir, this is an official record concerning an interview

23     with Aziza Kukic in relation to the murder of her son, Salko Kukic.  Are

24     you familiar with this official record and this lady, Mrs. Kukic?  Was

25     she an eye-witness of the crime?

Page 21448

 1        A.   I'm familiar with the official record but I have to say that this

 2     was usual practice for operatives.  They probably compiled this record

 3     although it hasn't been signed.  It has to do with the collection of all

 4     relevant data and of course Ms. Aziza was also interviewed and she speaks

 5     about how the murder took place.

 6        Q.   This Official Note, is it a document that was compiled by the

 7     members of the Ministry of the Interior?

 8        A.   Yes, that's for sure, yes.

 9             MR. ZECEVIC: [Interpretation] If there are no objections, I would

10     like to tender this document into evidence as well.

11             MR. HANNIS:  That's tab 11?

12             MR. ZECEVIC:  Yes.

13             MR. HANNIS:  Well, no objection, Your Honour, although I don't

14     see the relevance.  I don't think there's any issue here that this murder

15     was investigated.  We have several other documents in evidence already

16     that that took place.

17             MR. ZECEVIC:  Well, if you are not challenging that the police

18     was doing their proper job in this case, I'm not going to tender any more

19     evidence on this.

20             MR. HANNIS:  Well, I don't think we are challenging that there

21     was what appears to be a proper investigation into the murder of

22     Salko Kukic by the local police.

23             MR. ZECEVIC: [Interpretation] Thank you.

24        Q.   Sir, could you please look at document 65 ter 359D1.  That is

25     tab 102 in your binder.

Page 21449

 1             Sir, this is a decision dated the 3rd of August, 1992.  It is a

 2     ruling on detention and is signed by Dragan Andan, chief of public

 3     security station.  There is a signature and a stamp.  Is this a document

 4     of yours and what is it about actually, what does this decision on

 5     detention actually refer to?

 6        A.   We continued working on the case of Salko Kukic's murder and

 7     through our operative activity we came to the conclusion that four

 8     perpetrators had committed this heinous crime.  We brought these persons

 9     into the police station in Bijeljina.  We took them into custody.  They

10     were detained and you see that these are decisions on their detention.

11     That is to say, for these four persons.  There are two here, though, but

12     there should be two more.

13             Then we also filed a criminal report where we dealt with all four

14     persons, all the crimes committed, all the charges involved and I think

15     that the date was the 3rd of August, 1992.  It was sent on to the

16     prosecutor's office.  So we solved the case of this murder.  We found the

17     perpetrators, we filed a criminal report, we handed them over to the

18     prosecutor's office and this is where our authority ends.

19        Q.   Tell me, sir, as for these four individuals, Istok Pojatar is the

20     one referred to in this particular document, he is one of the suspects in

21     the murder case of the late Salko Kukic.  To the best of your knowledge

22     what is Mr. Istok Pojatar's ethnicity?

23        A.   As far as I know all four of them are Serbs.

24             MR. ZECEVIC: [Interpretation] Your Honours, I would like to

25     tender this document into evidence.  Unfortunately, the remaining three

Page 21450

 1     documents that are decisions on detention or custody for those three

 2     persons are separate exhibits.  Now, I don't know what Mr. Hannis's view

 3     is.  If he would accept that in relation to all of these suspects who

 4     were detained by the Ministry of the Interior, if he agrees, I wouldn't

 5     tender the other documents.  These are documents in tabs 100, 101, and

 6     103.

 7             JUDGE HALL:  But even in respect of this, Mr. Zecevic, I'm

 8     somewhat at a loss as to the utility of it as an exhibit.  It is an

 9     example of the witness doing his job in the ordinary course of what one

10     would expect.  What -- for what purpose do we need the exhibit?

11             MR. ZECEVIC:  Well, Your Honours --

12             JUDGE HALL:  And Mr. Hannis in his -- in respect of the previous

13     document has indicated that they take no issue with what ordinarily

14     happened.

15             MR. HANNIS:  I was about to say, Your Honour, I don't have an

16     objection to one of these as an example because this doesn't relate so

17     much to the fact that an investigation occurred but it has to do with the

18     process of the police being able to make an initial decision about

19     detention which I think is something that we are interested in having

20     evidence about.  So I don't object to this one as an example.

21             JUDGE HALL:  Very well.  Thank you, Mr. Hannis.  Admitted and

22     marked.

23             THE REGISTRAR:  Exhibit 1D552, Your Honours.

24             MR. ZECEVIC:  Well, now, I am not sure what is the position of

25     Mr. Hannis concerning the documents 65 ter 356D1, 357D1 and 358D1 which

Page 21451

 1     are tabs 101, 100 and 103.

 2             MR. HANNIS:  Well, I don't have any objection to them either.  I

 3     just don't know that they are necessary because they are simply the

 4     rulings on detention as to the other two named individuals.

 5             MR. ZECEVIC:  Other three named individuals.

 6             MR. HANNIS:  I don't object to them coming in, I just don't think

 7     they are necessary to make the point I want to make from a document like

 8     this.

 9             MR. ZECEVIC:  Thank you.

10        Q.   [Interpretation] Sir, you said that a criminal report had been

11     filed.  1D105, tab 104.  Could you please just confirm that that is the

12     document concerned?

13        A.   Yes, that's the document.

14        Q.   Who signed this document on your behalf?  Can you recognise the

15     signature?

16        A.   I think that Danilo Vukovic signed this for me.

17        Q.   Very well.  Could you please give us your comment on document 65

18     ter 355D1.  That is tab 37.  This is a report on solving the murder for

19     gain of Salko Kukic in Bijeljina in early June 1992.  It is signed by

20     Danilo Vukovic.  Are you familiar with this report?

21        A.   Yes, I am.

22        Q.   Who is this submitted to?

23        A.   I'm going back to what practice is and what is envisaged in the

24     rules and organisation of the Ministry of the Interior.  If the centre is

25     the protagonist of the activity related to certain information, then it

Page 21452

 1     it is our duty to inform the appropriate administrations within the

 2     Ministry of the Interior by way of providing such information.  It

 3     happened quite often that we sent this kind of information to the

 4     minister of the interior.  So the minister does not have any particular

 5     authority in this respect.  Of course he has authority, but as for the

 6     practical part, he can send this on to the administrations and say,

 7     Administrations, you do your job now, or he can just say thank you to

 8     whoever sent the information.  So the primary goal was to provide

 9     information to the appropriate administrations that were supposed to deal

10     with the particular case that was ultimately solved in the way this one

11     was solved.

12        Q.   Thank you.

13             MR. ZECEVIC: [Interpretation] If there are no objections I would

14     like to move that this document be admitted into evidence.

15             MR. HANNIS:  No objection.

16             JUDGE HALL:  Admitted and marked.

17             THE REGISTRAR:  Exhibit 1D553, Your Honours.

18             MR. ZECEVIC: [Interpretation]

19        Q.   Mr. Andan, we saw just now this documentation that is related to

20     this crime committed against a member of the Muslim people, the late

21     Salko Kukic.

22        A.   Salko Kukic.

23        Q.   Salko Kukic, yes.  You established during the investigation that

24     the perpetrators were four individuals of Serb ethnicity.  We saw that

25     procedure was carried out as you had explained to us.  Tell us, the way

Page 21453

 1     in which the public security station of Bijeljina acted, is that

 2     something that was applied in all other cases as well when grave crimes

 3     were committed?

 4        A.   We treated all cases in the same way.  However, due to imminent

 5     threat of war, we sometimes intervened ad hoc.  Actually, I'm going to

 6     give you an example.  A person of Muslim ethnicity, a vet, came to the

 7     police station to report that the members of Mauzer's unit in the town of

 8     Bijeljina stopped him right in town and took away his car, which was a

 9     Golf.  We intervened by sending an intervention team into town to find

10     the car on the basis of its licence plates.  They found the car, they

11     brought it to the police station, then they called the gentleman.  I

12     really don't know his name but he spent the entire war in Bijeljina, and

13     he came to pick up his car.  So this was this kind of ad hoc protection,

14     if I can put it that way.

15        Q.   My question was about grave crimes, murder, against life and limb

16     and so on.

17        A.   If I understand you correctly, I have already given you an answer

18     that we treated them all the same way.  All crimes were treated in a

19     highly professional manner.

20        Q.   Did the ethnicity of the victim or the perpetrator have any

21     influence on you or any consequences?

22        A.   If I understood the question properly, you are asking me whether

23     we treated all the ethnicities in the same manner.  Of course, we treated

24     all the ethnicities in Bijeljina in the same manner throughout the period

25     that Mr. Davidovic and I spent in Bijeljina.

Page 21454

 1        Q.   During your stay in Bijeljina, while you were the chief of the

 2     public security station, were there any cases in which the police did not

 3     investigate an offence and undertake appropriate measure because the

 4     injured party was a non-Serb or the assumed perpetrator was a Serb?  Were

 5     there any cases like that?

 6        A.   I'm testifying under oath here and I claim under full

 7     responsibility that in that period there was not a single case that you

 8     describe.

 9        Q.   When we discussed the action in the slaughter-house, you told us

10     that Mr. Mico Davidovic was with you.  This unit of Mico Davidovic, how

11     many men were in the unit and where did they hail from?

12        A.   There were about 25 to 30 men in the unit, that is a platoon

13     strength.  They came from the federal SUP in Belgrade.  It was called

14     Yugoslavia then and not Serbia and Montenegro.  They came pursuant to a

15     request by government or the minister of the interior in order to assist

16     in the security centre in Bijeljina in order to prevent all forms of

17     crime, in order to prevent -- to guarantee the right to property and life

18     of all the citizens and all other things stipulated by the law.

19        Q.   Mr. Andan, do you remember that you received an order from the

20     Ministry of the Interior on the decrease of the number of the reserve

21     policemen while you were the chief of the public security station in

22     Bijeljina?

23        A.   Yes.  I believe that, in accordance with the dispatch that had

24     arrived from the Ministry of the Interior, we acted upon it and agreed

25     that we should first of all remove all persons with a criminal file.

Page 21455

 1     However, this was a very difficult process in the police station in

 2     Bijeljina.  And if you would allow me, I'd like to explain exactly how we

 3     did that.

 4        Q.   Go on.

 5        A.   As far as we knew there were more than 1.000 members of the

 6     reserve police force.  We analysed the membership and concluded that

 7     various mama's and papa's boys sought shelter there, as well as other

 8     persons whose intention was not to be sent to the front line.  So we

 9     reached an internal agreement.  I think Mr. Kljajic, Mr. Davidovic, and I

10     agreed that on a certain day, I don't remember the date anymore, we would

11     call up the complete reserve police force.  We agreed to draft a false

12     document which would then be read out before the reserve police.  That

13     is, when they gather, a policeman would arrive and read out a dispatch

14     which would contain, inter alia, the following:  That the front line had

15     had been breached in the area of Teocak and that additional forces from

16     Bijeljina were needed to reinforce that part of the line urgently in

17     order to stabilise the whole front line.

18             So I read out this document.  I told them that nobody had an

19     obligation to respond, but those who wanted to join me and march towards

20     Teocak should stand on my right side and all of them on the left side.

21     Approximately two-thirds of them stood on the left side.  And then I

22     immediately ordered that all the weapons and equipment should be taken

23     away from all those who stood on the left.  I told them that this was a

24     false alert.  Then I ordered the active force of the police to escort

25     them through the town all the way to the barracks and hand them over to

Page 21456

 1     the VRS.  The remainder of the reserve police force we checked against

 2     the crime files.  There were some people who had crime files and we

 3     simply told them to go away and that is how we managed to form the core

 4     of the new police force.

 5             MR. ZECEVIC:  Perhaps as I'm moving to another field, maybe it's

 6     a proper time to take the break now.

 7             JUDGE HALL:  Yes.  So we resume in 20 minutes.

 8                           [The witness stands down]

 9                           --- Recess taken at 12:03 p.m.

10                           --- On resuming at 12.29 p.m.

11                           [The witness takes the stand]

12             JUDGE HALL:  Yes, you may continue, Mr. Zecevic.

13             MR. ZECEVIC:  Thank you very much, Your Honours.

14        Q.   [Interpretation] Mr. Andan, during July 1992, did you return to

15     Brcko at any point in time or did you carry out any action in Brcko?

16        A.   Yes, it wasn't only me.  The Mico Davidovic's unit, reinforced

17     with some forces that had arrived in the meantime in agreement with Cedo

18     Kljajic and the minister, carried out an action.  The reason for that was

19     the fact that the integrity of the police station had again been breached

20     and we simply had to intervene in Brcko.

21             MR. ZECEVIC: [Interpretation] Can we have 154D1, tab 57.  That's

22     the 65 ter number.

23        Q.   This is your memo, or at least your name is typed.  The date is

24     the 20th of July, 1992.  It was sent to the Ministry of the Interior.

25     Can you tell us something about the two last paragraphs.  They are

Page 21457

 1     related to the action in Brcko and I'd like you to explain briefly what

 2     it was all about.

 3        A.   After I left Brcko, a number of attacks were carried out against

 4     the police station in Brcko.  Members of the Red Berets were dissatisfied

 5     with the situation and with the lawful work of the police station in

 6     Brcko.  They were Captain Dragan's Red Berets and they carried out a

 7     number of attacks in order to take over the police station Brcko so that

 8     they could again have free access to registration plates, identification

 9     cards, passports, and other similar stuff.  So this is the information

10     that we received.

11             We agreed that we should carry out an action in Brcko in order to

12     stop their activities once and for all.  Our goal was to arrest them,

13     disarm them, and to transport them in a bus to the border crossing, the

14     border with Serbia, and to hand them over to the competent organs of

15     Serbia.

16             During that action in Brcko more than 30 persons were arrested.

17     The remaining part of this paramilitary formation undertook an unlawful

18     arrest or kidnapping of the representatives of the Brcko authorities,

19     including the Chief of Staff of a brigade belonging to the VRS.  His name

20     was Mr. Sehovac.  Negotiations ensued.  They managed to gain access to

21     our communications system and requested the release of all their arrested

22     members.  In exchange they offered the persons that they detained or

23     arrested.  In the beginning we did not release any of the members of the

24     paramilitary formation but we managed to get the release of the

25     representatives of the Brcko authorities; the only person who remained in

Page 21458

 1     their hands was Major Sehovac.  Then through our communications channels,

 2     they got in contact with me and requested that Major Sehovac be released

 3     in exchange for their people.  I was told that if we did not do that,

 4     that they would kill Major Sehovac.

 5             I replied in a rather laconic way.  I told them go ahead, do it.

 6     Go ahead and kill him because if we Serbs have something in abundance,

 7     it's officers.  Indeed we have a surplus of them.  A wait ensued for more

 8     than two hours and after two hours they agreed to release Major Sehovac.

 9             A part of the unit managed to escape towards Ugljevik.  The

10     remainder surrendered.  We disarmed them, as I told you, and at that

11     point in time their only request was to be permitted to take their

12     side-arms with them to Serbia.  I'm referring here to their pistols.

13     However, we did not allow that.  We drew up a list of them and they were

14     escorted by the police to the border crossing of Raca where they were

15     handed over to the competent authorities belonging to the Ministry of the

16     Interior of Serbia.

17             Among other things, we searched their premises where we

18     discovered a lot of loot.  It was their warehouse for various technical

19     equipment and duty-free goods that they had plundered before.  All this

20     we kept in the police station in Brcko.  So, that was the end of the

21     police action in Brcko which resulted in the continuation of normal

22     functioning and work of the police station in Brcko.

23             MR. ZECEVIC:  [Interpretation] Thank you.  If there are no

24     objections, I would like to tender this document into evidence.

25             MR. HANNIS:  No objections.

Page 21459

 1             JUDGE HALL:  Admitted and marked.

 2             THE REGISTRAR:  Exhibit 1D554, Your Honours.

 3             MR. ZECEVIC: [Interpretation]

 4        Q.   Sir, at the beginning of this answer, page 53, you said:  "Yes,

 5     but it wasn't only me.  It was Mico Davidovic's unit reinforced with the

 6     forces that had arrived in the meantime pursuant to an agreement between

 7     Cedo Kljajic and minister and they carried out this action.  The reason

 8     for that was the integrity of the police station in Brcko" and so on and

 9     so forth.  When you said that those forces arrived in accordance with an

10     agreement between Cedo Kljajic and the minister, what forces were you

11     referring to?

12        A.   First of all, I would like to say that it all happened very

13     quickly, all those events in the area of Semberija and Majevica.  You

14     know, the security situation in one municipality would be improved and

15     then it would immediately deteriorate in some other municipality, so we

16     simply could not intervene with only 30 people in the whole area of

17     Semberija and Majevica.  This is the problem that we presented to

18     Mr. Kljajic.  We asked him that he should take, if possible, a part of

19     the special unit from Pale or some other special unit and bring it to

20     Bijeljina in order for them to help us in carrying out our tasks.

21     Mr. Kljajic agreed and members of such a unit arrived in Bijeljina, I

22     don't know on which day, and they were led by Mr. Malovic, his first name

23     may be Dusko.

24             So in accordance with this agreement, he was re-subordinated to

25     the command of myself and Mr. Davidovic.  He took part in several actions

Page 21460

 1     that we carried out in the area of Semberija and Majevica.

 2        Q.   Mr. Andan, if you remember how many members were in this unit led

 3     by Dusko Malovic, approximately?

 4        A.   My estimate is not more than 20.

 5        Q.   Where was this unit billeted upon their arrival in Bijeljina?

 6        A.   There was no available accommodation.  The military was not in a

 7     position to give them part of the barracks.  We decided to accommodate

 8     the unit on the premises of the security centre in Bijeljina in our

 9     attic.  We brought some cots in the attic and since there was a kitchen

10     that functioned practically around the clock on the premises of the

11     security centre, and since there were showers available in the gym, we

12     simply agreed that the unit should be accommodated on the premises of the

13     security centre in Bijeljina.

14        Q.   You said on page 56, line 2 and 3 that they took part in a number

15     of actions in the territory of Semberija and Majevica.  Tell us which

16     actions were you referring to?

17        A.   Well, first of all, that was the action carried out in Brcko, the

18     disarming of the paramilitary formations belonging to Captain Dragan.

19     After that there was a kidnap case in Brcko.  It was again some

20     Red Berets, and I wouldn't be able to tell you exactly which Red Berets.

21     Mirko Blagojevic, member of the Serbian Radical Party was kidnapped.

22     Those lads wearing red berets came in two Land Rovers.  They took

23     Mirko Blagojevic in one of the Land Rovers with the intention to

24     transport him out of the area.  Later on we heard that Mirko was supposed

25     to be executed.  However, at the time we did not know that.  We

Page 21461

 1     intervened by intercepting the vehicles, surrounding them and the members

 2     of the Red Berets pointed their long barrels at us and there was a

 3     stand-off.  We were very, very close to an armed conflict.

 4             I proposed to Mr. Davidovic that I should drop my side-arm, raise

 5     my arms in the air, and approach the members of the Red Berets in order

 6     to negotiate with them.  And that's what I did.  They accepted me as

 7     such.  I requested them to release Blagojevic.  Then he -- then they told

 8     me, well, if we release Blagojevic, you are going to kill us all here.

 9     The discussion went on for a number of hours.  I promised them that they

10     would be unharmed.  We arrived in the police station in Bijeljina.  We

11     released Mr. Blagojevic, and then after that we gave the police escort, I

12     think it was Mr. Malovic's unit, we gave the police escort to the

13     Red Berets and handed them over at the border crossing.  So was that the

14     second action.

15             And the third action in which they directly took part was the

16     elimination of the paramilitary formation of Yellow Wasps in Zvornik.

17     They weren't literally liquidated, they were just arrested and

18     proceedings were instituted against them.

19        Q.   You have just said while you were speaking about Mauzer and the

20     situation when his unit was going to attack the Bijeljina SJB with tanks.

21     Do you remember whether Malovic's unit was in Bijeljina at the time and

22     whether it took part in the defence of the CSB building?

23        A.   Ljubisa Savic, also known as Mauzer, that is, his unit attacked

24     the police station three times.  Mr. Malovic and his unit took part in

25     the defence of the police station twice, or the defence of the CSB.

Page 21462

 1     There was a memorable instance, the second or third attack, I think,

 2     doesn't matter really.  We put up a circular defence of the building,

 3     military style, and since the building has a flat roof, some members of

 4     his unit went up there and at one moment we heard a strong explosion.

 5     Everybody lay down, ducked.  They thought that a grenade fired from a

 6     tank had hit the building.  Then a few moments later, I went out of the

 7     police station and that things were the same as before.  One of Malovic's

 8     men had accidently activated a hand-held rocket-launcher and it had

 9     pierced a reinforced concrete wall which was 50 to 60 centimetres thick.

10     And later we discussed how that weapon was uncarefully used at that

11     moment.  It could have been -- it could have prompted an attack against a

12     police station by Mauzer and his men.

13        Q.   You said that when Malovic's unit came to Brcko and reported to

14     Undersecretary Cedo Kljajic that it was agreed then that they should be

15     re-subordinated to Mico Davidovic and you.

16             MR. HANNIS:  I am sorry, can I confirm it was to Brcko or to

17     Bijeljina?

18             MR. ZECEVIC: [Interpretation]

19        Q.   Please tell us where that unit came?

20        A.   They came to Bijeljina.  I have said that already.  And they were

21     re-subordinated to our unit.  First they took part in the operation in

22     Brcko and returned to Bijeljina with us.  And in Bijeljina we continued

23     our activities and they were also billeted in Bijeljina.

24        Q.   Since that unit took part in a number of operations and they

25     were -- they were there all the time, they were billeted at the Bijeljina

Page 21463

 1     CSB, what was their professional attitude in your opinion?

 2        A.   The discipline in that unit was surprising, and that discipline

 3     was imposed by Mr. Malovic.  I remember an incident when one of his

 4     subordinates returned from town intoxicated and Malovic first gave him a

 5     good dressing down and then he slapped him on the face which was

 6     surprising to all of us.  I told him that this was the last time he aced

 7     that way and if he should do that again he would be removed from the unit

 8     and returned to Pale.

 9        Q.   While you were there and that unit was re-subordinated to

10     Mico Davidovic's unit, were there any complaints about their conduct as

11     MUP members?

12             MR. HANNIS:  I'm not sure that accurately states the evidence.  I

13     believe the witness has testified it was re-subordinated to

14     Mico Davidovic and the witness.  If I'm wrong about that, I stand

15     corrected, but now he is only talking about Mico Davidovic.

16             MR. ZECEVIC: [Interpretation] My mistake.

17        Q.   You did say to Mico Davidovic's unit and me, but do answer my

18     question.

19        A.   Yes, I represented the MUP of the RS, Mico Davidovic was helping

20     out and the two of us co-ordinated all activities.  That unit was

21     re-subordinated to the two of us.

22        Q.   My question was did you have any complaints about their conduct

23     as MUP members?

24        A.   While carrying out any operations at Majevica and Semberija, I

25     had no complaints.  They went about their job very professionally.  Since

Page 21464

 1     we patrolled the territory during the curfew, I had the opportunity to

 2     patrol with some members of that unit and even then I had no objections

 3     to their work.  Whether anything happened later, I don't know, but I'm

 4     sure that it would have been reported.

 5        Q.   Sir, do you know that this unit was sometimes referred to as

 6     Mico Stanisic's unit?

 7        A.   Yes.  A number of MUP members and commanding officers called it

 8     that.

 9        Q.   Do you know why they called it Mico Stanisic's unit, as far as

10     you know?

11        A.   The composition of the unit, or rather, the unit was composed of

12     people from the same municipality as that from which Mr. Stanisic hailed,

13     and that's Sokolac.  Nobody said that he was from Pale or Bijeljina.  And

14     that's why they called it Mico Stanisic's unit because they were all from

15     the Sokolac area.

16        Q.   Thank you.  Tell me, sir, you have just spoken about the

17     situation in the Majevica and Semberija area.  You said that when the

18     situation improved in one municipality it deteriorated in another.  When

19     I say situation, I mean security.  Did you and the members of that unit

20     which was in Bijeljina go to other municipalities in the

21     Semberija-Majevica area too?

22        A.   Yes, we did, because we were receiving information from other

23     municipalities as well.  And I think that the basic reason for any

24     instance of deteriorated security situation in Semberija and Majevica and

25     from experience I can add, in many other parts of the RS were

Page 21465

 1     paramilitaries.  They were disrupting the usual practice.  Certainly in

 2     accordance with the circumstances at the time.

 3        Q.   Talking about these other municipalities, did you go to Lopare

 4     and Ugljevik?

 5        A.   I can say with certainty that we were experienced police officers

 6     and depending on the nature of the situation, we tried to get information

 7     about other municipalities in different ways.  And when we did get

 8     information, we tried to check it through our members by sending them

 9     there to stay for a couple of days, gather intelligence, and then we

10     would consider the situation at that mini-collegium.  We went to Lopare,

11     Ugljevik, Zvornik, and eventually we were supposed to go to

12     Bosanski Samac where there were problems with one Lugar and one Crni, but

13     for some reasons we never went there.

14        Q.   When you say for some reason, what exactly do you mean?

15        A.   I'll be specific.  We didn't go because in the latter half of

16     August 1992 Mico Davidovic's unit was withdrawn from Semberija and

17     Majevica and I was prohibited to continue working for the MUP.

18        Q.   Thank you, sir.  Tell me, what was the situation in the Lopare

19     and Ugljevik municipalities?  You have already spoken about Samac.

20        A.   It was like a carbon copy.  That is the situation was always the

21     same with paramilitaries.  As far as I remember in Ugljevik there were

22     problems with some paramilitary unit I don't quite remember, and in

23     Ugljevik there were some problems with the manning of the reserve forces

24     of both the police and the military.  There were many problems in both

25     these municipalities and the cause of these problems were always

Page 21466

 1     paramilitaries that were refusing to resubordinate to the military.  And

 2     of course it was impossible for them to be re-subordinated to the police.

 3        Q.   Sir, do you remember that at one point in early July, your unit

 4     arrested some members of the VRS?  Actually, you took them in and

 5     detained them?

 6             THE INTERPRETER:  Interpreter's correction:  Brought them in.

 7             THE WITNESS: [Interpretation] Yes.  I remember that case without

 8     looking at documents.  An active duty major of the VRS was stopped at a

 9     check-point, I think it was Jovan Micic, I'm not sure about his first

10     name but the last name is correct.  On his truck and it was a large

11     military truck, a 150 type as we called them, a lot of stolen goods were

12     found, and they were brought to the Bijeljina police station.  The goods

13     were seized, a certificate was issued, and the goods were stored at the

14     Bijeljina police station.

15             That night we could not communicate with the military police and

16     that is why Mr. Micic was detained at the police station in the Detention

17     Unit.  After that problems ensued.

18             MR. ZECEVIC: [Interpretation] Just a moment, let me show you a

19     document.  P79/41 [as interpreted].  Or rather, that's -- 41 is the tab

20     number.

21        Q.   You began talking about problems so I just wanted to give an

22     illustration.  You can continue, sir.

23             MR. ZECEVIC: [Interpretation] P579.  This is not the document I

24     need.  65 ter 169 of the Prosecution.  This is it, thank you.

25        Q.   Go ahead, Mr. Andan.

Page 21467

 1        A.   In a lawful police action, we brought in the major and kept him

 2     in custody until the morning when we handed him over to the military

 3     police.  Some of the military structures did not like what we did and

 4     they protested primarily because the major was detained and this is what

 5     this dispatch says.  Actually, the minister at the time, Mr. Stanisic,

 6     asked for some additional information with regard to the detention of

 7     Mr. Micic and this is yet further proof of the fact that we did act

 8     lawfully at the time.

 9             MR. ZECEVIC: [Interpretation] For the Trial Chamber, it is P580

10     and P581.  That is what the witness is referring to.

11        Q.   Could I please have your comment with regard to 65 ter 149D1.

12     That is tab 48.  This is information from the 7th of July.  This

13     information is from the 7th of July, 1992, and it says:  "Report on the

14     taking into custody and detention of Major Jovan Micic and a group of

15     soldiers."

16        A.   Yes, and attached to this report is the list of goods that we had

17     taken on that occasion, or rather, seized.  This report is a result of

18     our activity and this is the report that was sent to the Ministry of the

19     Interior by way of information, so that we could, inter alia, justify

20     everything we did in terms of bringing into custody Mr. Micic.  Again I'm

21     saying that the accompanying document is missing, but in terms of

22     hierarchy, we were duty-bound to provide information to the proper line

23     of work within the Ministry of the Interior.

24             MR. ZECEVIC: [Interpretation] If there are no objections, I would

25     like to tender this document into evidence.

Page 21468

 1             MR. HANNIS:  No objection.

 2             JUDGE HALL:  Admitted and marked.

 3             THE REGISTRAR:  Exhibit 1D555, Your Honours.

 4             MR. ZECEVIC: [Interpretation]

 5        Q.   [Microphone not activated]

 6             THE INTERPRETER:  Microphone, please.

 7             MR. ZECEVIC: [Interpretation] 147.  Could you please be shown

 8     65 ter 147D1, tab 49.

 9        Q.   [Microphone not activated]

10             THE INTERPRETER:  Microphone, please.

11             JUDGE DELVOIE:  Microphone, please.

12             MR. ZECEVIC: [Interpretation] I do apologise.

13        Q.   In the previous answer you mentioned a list as part of that

14     report.  This is some list of items found in a TAM E-1948 vehicle.  Can

15     you tell us what this list is all about?

16        A.   At the end of that report, the one that we've already admitted,

17     it says attachment 12.  If we have already seen that.  I think that that

18     attachment is a list of the things that were found that night with

19     Major Micic and the soldiers that we brought into custody, who was

20     remanded in custody until the morning, that is.

21        Q.   Is that the list that we see in front of us, the list of things

22     that were seized?

23        A.   Yes, this is the assortment of goods that they took along with

24     them.

25             MR. ZECEVIC: [Interpretation] Thank you.  If there are no

Page 21469

 1     objections, I would like to tender this document as well.

 2             MR. HANNIS:  I just have a question about the relevance but I

 3     don't oppose to --

 4             THE INTERPRETER:  Microphone, please.

 5             MR. HANNIS:  I don't oppose it on authenticity grounds.  I'm not

 6     sure how relevant it is.  It's a list of a lot of household goods.

 7             JUDGE HALL:  I was going to say that I appreciate that from the

 8     witness's answer that this is an annex to the document as previously

 9     admitted, but by -- but what does it add?

10             MR. ZECEVIC:  Well, Your Honours, this is a list of the goods

11     that were taken from this Micic, Officer Micic's unit within the army

12     truck, and by looking at the list of the goods, it's obvious that this

13     confirms that there was a looting going on a big scale going on in this

14     case, and since this is the annex of the previous document, I think it's

15     relevant that we see what the goods were found in the truck.

16             JUDGE HALL:  Very well.  Admitted and marked.  I suppose there is

17     some utility to the breadth of items which are contained in this list.

18             THE REGISTRAR:  Exhibit 1D556, Your Honours.

19             MR. ZECEVIC:  Thank you, Your Honours.

20        Q.   [Interpretation] Mr. Andan, I have a few questions in relation to

21     adjudicated facts in this case.

22             MR. ZECEVIC: [Interpretation] For the Trial Chamber, it is 1434

23     actually.

24        Q.   Mr. Andan, were you aware of the existence of a camp in Batkovici

25     near Bijeljina?

Page 21470

 1        A.   Yes.

 2        Q.   When did you hear of the existence of this camp for the first

 3     time?

 4        A.   As I stayed in Brcko, I asked the then chief of national

 5     security, Mr. Gavrilovic, about a friends of mine from Sarajevo, a

 6     certain Anto Vidovic who was a football player in Jedinstvo from Brcko.

 7     When I first asked him he just shrugged his shoulders.  I persisted in

 8     asking what had happened to Anto, quite simply he had told me he had been

 9     taken to the camp in Batkovic, I asked him where that camp was and he

10     said the camp is in the territory of the municipality of Bijeljina.  That

11     is the first time that I heard of the Batkovic camp.

12             Since we had co-operation with the command of the Eastern Bosnian

13     corps whose commander was Colonel Ilic, during an evening briefing, that

14     is to say, from time to time we went to see them and to exchange

15     information, I availed myself of that opportunity.  Since the Batkovic

16     camp was under the command of the military, I availed myself of that

17     opportunity and asked Mr. Ilic to do me a favour by releasing

18     Mr. Anto Vidovic from that camp, of course, unless he had committed a

19     crime like murder or something else.

20             A few days later, in the evening, I received a call from the

21     police station and I was told that a certain individual was waiting for

22     me at the police station all day, and when I got there, I found

23     Mr. Anto Vidovic at the police station.  Of course, this was a scene that

24     one cannot ever forget.  I went -- I went home with him, we had dinner,

25     the next day I took him to Brcko.  We went to the police station in

Page 21471

 1     Brcko.  I said that this was a friend of mine.  Since he was a car

 2     electrician by vocation, I told him -- I said that they could use him

 3     either in the army or in the police for repairing trucks, and I said that

 4     I would hold them responsible for Anto Vidovic.  The war was over and

 5     Anto Vidovic survived and the first thing he did when the war was over

 6     was to go to Sarajevo to see my mother to thank her for what I had done.

 7     So this is what I had to say in relation to your question about the

 8     Batkovic camp.

 9        Q.   Mr. Andan, do you know that in Bijeljina, that to say in the

10     territory of the municipality of Bijeljina, in addition to the camp in

11     Batkovic, there were six other collection centres in the territory of the

12     municipality including the building of the SUP in Bijeljina where Croat

13     and Muslim civilians were detained --

14             MR. HANNIS:  Just for the record, the adjudicated fact my English

15     says six detention centres shall rather than collection centres.  I don't

16     know if it's a significant difference, but ...

17             MR. ZECEVIC: [Interpretation]

18        Q.   I think I said six detention centres.

19        A.   While we were in Bijeljina, that is to say from mid-June until

20     the second half of August, I claim with full responsibility that at the

21     police station and on the premises of the Bijeljina CSB there was not a

22     single individual, at least we did not find anyone there who had been

23     detained on any grounds whatsoever.

24             As for other collection centres or camps as the Prosecutor said,

25     I did not learn of any except for the one, the camp in Batkovic.

Page 21472

 1        Q.   For a while you were acting chief of the public security station

 2     in Bijeljina, weren't you?

 3        A.   Yes.  I was acting chief of the public security station and the

 4     CSB, depending on what was needed.

 5        Q.   The territory that was covered by the public security station of

 6     Bijeljina is the territory of the municipality of Bijeljina; right?  Does

 7     it cover the territory of the municipality of Bijeljina?

 8        A.   The public security station does cover the territory of the

 9     municipality of Bijeljina and the security centre covers several

10     municipalities in the area of Semberija.

11        Q.   Do you allow for the possibility that in the territory of the

12     municipality there were six collection centres, or rather, detention

13     centres for detaining Croat and Muslim civilians without you knowing

14     about that?

15        A.   I'm going back to the period in which we operated in the area and

16     I claim with full responsibility that at the time these collection

17     centres or camps that you refer to did not exist.

18        Q.   Thank you.  Sir, the concept on the basis of which you worked in

19     Bijeljina together with Mico Davidovic's unit and these reinforcements

20     that were there, was it actually your concept to deal with the

21     paramilitaries in the territory of the CSB Bijeljina?

22        A.   Yes, that was our concept.  Practically we first materialised

23     this concept in the area of Brcko, and then we planned to continue with

24     this concept in Ugljevik and Lopare.  There was a dilemma there as to who

25     Zvornik belonged to, whether it belonged to the CSB of Bijeljina or the

Page 21473

 1     CSB of the Sarajevo Romanija region, I don't know what their name was.

 2     At the time in Bijeljina we believed that Zvornik was ours, whereas the

 3     people from Sarajevo thought it was theirs.  One dispatch was sent by the

 4     minister of the interior in which it was stated that this centre belonged

 5     to the Sarajevo Romanija region.  However, in spite of that, we did plan

 6     and carry out a major operation of neutralising the paramilitary unit

 7     called Yellow Wasps in Zvornik.

 8        Q.   Tell me, if you remember, when was this operation in Zvornik

 9     against the Yellow Wasps carried out?

10        A.   Again I'm going to apologise because of the dates.  Dates are not

11     all that relevant to me and I don't remember them, but I remember details

12     that are probably relevant for this Court as well.  We received a series

13     of information about the behaviour, behaviour under quotation marks, of

14     that paramilitary unit and we weren't sure whether all this information

15     that we had obtained was all that reliable.  At one of these collegium

16     meetings in the morning, I was given a task to change into civilian

17     clothing, to take a few operatives with me, and to infiltrate myself, as

18     we say in professional terms, into Zvornik and try to obtain the

19     information that we needed.

20             As I arrived in Zvornik, I organised a meeting with the chief of

21     national security, Goran Zugic, and we held this meeting in Mali Zvornik.

22     Because our information said that the members of the Yellow Wasps

23     paramilitary unit were following all important persons who were holders

24     of important offices in Zvornik.  In the territory of Zvornik, I stayed

25     for about three or four days and I established exactly all the locations

Page 21474

 1     where Zuco, Pivarski, and another group were stationed, but because the

 2     Zuce were so numerous and because they had committed such terrible

 3     crimes, we went after the Yellow Wasps first.  That's when I presented my

 4     report.

 5             What followed was a planned activity that we embarked upon.  Of

 6     course before any operation one has to plan.  We made a comprehensive

 7     plan that we verified at one of these morning meetings of ours, not to

 8     call them a collegium.  I don't know the exact date, but I know that it

 9     was in the early morning hours that we set out to implement that

10     operation.

11             MR. ZECEVIC: [Interpretation] P317, item 22, tab 58.

12        Q.   Mr. Andan, this document is dated the 20th of July, 1992.  Your

13     name and position, chief of Bijeljina CSB is typed in the signature

14     block, it says that it was delivered to the minister and the

15     undersecretary for public security.  The subject is "information on

16     security situation in the region of Serbia municipality Zvornik."  Is

17     this your document and is this the information that you drafted and sent

18     it to the addressees listed in the document?

19        A.   Yes, this is my information.  This information was sent to the

20     addressees mentioned.  I think that here we also don't have the cover

21     letter, the accompanying memo saying, Hereby we submit information under

22     such and such number also carrying my signature.  However, I accept that

23     this is my information and that it was sent to the listed recipients.

24        Q.   Thank you.  Mr. Andan --

25             MR. ZECEVIC: [Interpretation] Could the witness please be shown

Page 21475

 1     65 ter 831D1, which is tab 59.

 2        Q.   Mr. Andan, in 1992, were you in the habit of writing notes in

 3     some sort of a diary?

 4        A.   I wouldn't really call it a diary, but, yes, I was writing down

 5     notes.

 6        Q.   This document bears the letters AN-6.  It's in the upper

 7     left-hand corner and underlined on the first page.  Could you tell me

 8     when was this document marked with those letters?

 9        A.   You can probably check this, I believe that during one of the two

10     interviews that I had with The Hague investigators in Banja Luka and I

11     think it was during the second interview that I gave them this document.

12        Q.   And do you remember whether it was marked AN-6 on that occasion?

13        A.   To be honest, I don't remember that.

14        Q.   But in any case, Mr. Andan, these notes that you wrote pertain to

15     the period from the end of July until the end of August, or September

16     1992.  Could you tell me what happened to the remainder of your notes?

17        A.   As far as I can remember, I don't know whether it was the first

18     or the second interview, but I offered them whatever they asked me to

19     give them.  I gave my diary in its entirety to Mr. Raffi Gregorian, the

20     deputy high representative in Sarajevo for a number of years.  I gave the

21     diary and some other documents which were never returned to me.  I was

22     promised that all the documents that I submitted would be checked for

23     authenticity, however, I never went back to Mr. Raffi and I never

24     received any feedback from him.

25        Q.   Do you remember when you handed this diary of yours to

Page 21476

 1     Mr. Raffi Gregorian from the Office of the High Representative in

 2     Sarajevo?

 3        A.   I spoke to him on a number of occasions.  I wanted to regulate my

 4     status.  Also once we spoke about an offer that Mr. Gregorian made to me

 5     on that occasion which was more or less as follows:  I was supposed to

 6     find the mortal remains of Colonel Avdo Palic, and if I do that all

 7     sanctions pertaining to me would be terminated and there would be a

 8     possibly for me to return to work in the Ministry of the Interior.  So it

 9     was either on that occasion or slightly before that but the crux of the

10     matter is that I handed over my diary to him as well as some other

11     documents.  If I remember well, I also gave him a letter written by my

12     stepfather.

13             MR. HANNIS:  Your Honour, may I interject here.  I'm not sure

14     this seems to beyond the scope of what is relevant to us.  I note in the

15     proofing note that at item 14 the Defence did say they were going to have

16     information from the witness regarding comments in relation to his diary.

17     However, I took that to mean it was going to be comments about the

18     content of the diary, not about some transactions or dealings with

19     somebody of the Office of the High Representative.  So I don't know where

20     we are going here and I don't know if this is something that should be

21     done in open session or not, but absent some further showing of how this

22     is relevant to the issues in our case, I would ask that we not continue

23     until that's proven to your satisfaction.

24             MR. ZECEVIC:  Your Honours, the document which I'm going to go

25     into the content, of course that's my intention, has been received as

Page 21477

 1     part of the documentation which the witness provided to the Office of the

 2     Prosecutor during the interview conducted with him by the investigators

 3     of the Office of the Prosecutor.  However, it is apparent from the

 4     document that it is not a complete document, and I'm just establishing

 5     where is the complete document because I have never seen it, and the

 6     witness is giving the explanation where is that document.

 7             MR. HANNIS:  And I think he has already said where it is.  I

 8     don't know that we need any further.

 9             MR. ZECEVIC:  Well, I don't, but I didn't just want to stop the

10     witness in his answer, but I'm satisfied with the answer as it is.

11             JUDGE HALL:  Yes, I think we all are.

12             MR. ZECEVIC: [Interpretation]

13        Q.   Mr. Andan, could you please take a look at page 3 of this

14     document, your notes --

15             JUDGE DELVOIE:  Mr. Zecevic, before we go to another page, can I

16     just ask something to the witness for my information.

17             Mr. Andan, there are three names there you that are mentioned

18     also in the previous document, Pivarski, Niski, and Zuco, and if I

19     understood you well, these are leaders of a group, groups of

20     paramilitary?  Are they leaders of different groups, and if so, can you

21     give the name of the groups they were a head of?

22             THE WITNESS: [Interpretation] Your Honour, we are dealing here

23     with three different paramilitary groups.  The three persons mentioned

24     here are the respective leaders.  Apart from Zuco, I cannot remember the

25     full name of Pivarski and Niski.  This here is my operative notebook.

Page 21478

 1     And I know that I entered information related to the presence of the

 2     paramilitary formations in Zvornik into this notebook.  So besides

 3     Pivarski there are other names mentioned here, a guy named Splico and

 4     some other people.  But apart from Vojin Vuckovic, because of my

 5     engagement in that particular case, I wouldn't know any other names.  I

 6     only remember this one full name.

 7             JUDGE DELVOIE:  Mr. Andan, I think you misunderstood me, I wanted

 8     to know Pivarski, he was a leader of which group?  What was the name of

 9     the group?  Same for Niski and same for Zuco, what was the name of the

10     group they were head of?

11             THE WITNESS: [Interpretation] I can't give you a correct answer.

12     I see from the notebook that Pivarski had 20 men at his disposal and he

13     was stationed at Drinjaca, that's the Zvornik municipality.  Niski had,

14     if I can read it correctly, 30 people in the Kiseljak municipality.

15     However, the names of the groups is something that I don't know right

16     now.  I only know that Zuco's group was called Yellow Wasps.

17             JUDGE DELVOIE:  Okay.  Thank you.

18             MR. ZECEVIC: [Interpretation]

19        Q.   Sir, if I understood His Honour correctly, the question was: Was

20     Pivarski's group a separate and distinct unit as opposed to Yellow Wasps?

21        A.   Yes, I said that, they were not part of the Yellow Wasps.  There

22     are three different paramilitary formations here.

23        Q.   Did all those three paramilitary formations, or maybe even more

24     than three, operate, to put it that way, in the territory of the Zvornik

25     municipality?

Page 21479

 1        A.   You can see from my notebook that they separated among

 2     themselves, divided the territory into their zones of responsibility, if

 3     I can put it that way.  Zuco took the town of Zvornik; Pivarski, the

 4     settlement of Drinjaca; while Niski held Kiseljak, the settlement of

 5     Kiseljak.

 6        Q.   The settlement of Drinjaca and the settlement of Kiseljak, are

 7     they also part of the town of Zvornik?

 8        A.   Yes, that all belongs to the town of Zvornik.

 9        Q.   Sir, I'm looking at your notebook and I can see the entry saying

10     Simo Chetnik, it's the fourth line, could you please read out what it

11     says for Simo Chetnik and could you explain it.

12        A.   That's the fourth paramilitary formation led by one Simo Chetnik.

13     He had 30 men and he was controlling the Malesevic area.  That's what it

14     says in my notebook, and that is also a part of Zvornik.

15        Q.   Thank you.  The last entry on this page, can you read that out

16     loud?

17        A.   This is where I noted the disposition of Zuco's forces.  Part of

18     the forces belonging to the Zuco's unit was in a skyscraper called

19     Soliter, on the sixth floor.  They had taken over the whole of the sixth

20     floor.  Then, after that, it's a private house across the street from the

21     hotel, that's where they used to get together.  Then the third line, this

22     is my observation, that they monitor and control the whole town.  I

23     already told you that they monitored not only simple civilians but also

24     local dignitaries, people who were part of the local authorities at the

25     time and not only them but also some of our operatives who were tasked

Page 21480

 1     with their surveillance.

 2             MR. ZECEVIC: [Interpretation] Can we have the next page in

 3     Serbian, we have the correct page in English.

 4        Q.   I would like you to explain the following entry.  Is it something

 5     to do with the weaponry that the Yellow Wasps had at the time according

 6     to your information?

 7        A.   I and a number of other operatives during our stay in Zvornik

 8     learned that the part of the unit was accommodated in Zvornik in the

 9     Glinica factory.  We learned that they were building some sort of an

10     armoured train.  They invested a fantastic 1 million euros into equipping

11     of this train in order to use the train for a break-through towards

12     Kalesija so that the town of Kalesija could be taken over.  At the time

13     Kalesija was under the control of the BiH army.

14             So this is just a short list of what was in that train and the

15     equipment that was there.  You can see towards the end that they

16     attempted an action with the train between Caparde and Celopek, that

17     those are two points in Zvornik.

18        Q.   Thank you.

19             MR. ZECEVIC: [Interpretation] I think it's the time.

20             JUDGE HALL:  Yes, it is the time we take the adjournment for the

21     week.  We resume at 9.00 on Monday morning.  I believe we are in

22     Courtroom I.  So I trust everyone has a safe weekend.

23                           [The witness stands down]

24                           --- Whereupon the hearing adjourned at 1.45 p.m.

25                           to be reconvened on Monday, the 30th day of May,

Page 21481

 1                           2011, at 9.00 a.m.