1 Tuesday, 31 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 to
6 everyone in and around the courtroom.
7 This is case IT-08-91-T, the Prosecutor versus Mico Stanisic and
8 Stojan Zupljanin.
9 JUDGE HALL: Thank you, Madam Registrar. Good morning to
10 everyone. May we have the appearances today, please.
11 MR. HANNIS: Good morning, Your Honours. For the Prosecution,
12 I'm Tom Hannis along with Gerry Dobbyn and Crispian Smith.
13 MR. ZECEVIC: Good morning, Your Honours. Slobodan Zecevic,
14 Slobodan Cvijetic, Eugene O'Sullivan, and Ms. Tatjana Savic appearing for
15 Stanisic Defence this morning. Thank you.
16 MR. ALEKSIC: [Interpretation] Good morning, Your Honours.
17 Aleksandar Aleksic appearing for the Defence of Mr. Zupljanin.
18 JUDGE HALL: Thank you. Are there any preliminary matters before
19 the witness is brought back in?
20 MR. HANNIS: Your Honour, before the witness comes in, I just
21 wanted to advise the Court of one thing: The Defence has filed an
22 application for a binding order pursuant to Rule 54 bis and I wanted to
23 indicate the Prosecution did not intend to file a written response. Our
24 position is the same as it was to an earlier application to Croatia, I
25 think this one is to the Federation, and I would only note that the
1 request for information includes requests for information about unknown
2 persons, FNU, LNU, first name unknown, last name unknown. We think
3 that's unnecessary and an impossible thing to ask of the country to whom
4 a request for a binding order is made.
5 JUDGE HALL: So noted, Mr. Hannis. Thank you.
6 Would the usher please escort the witness back to the stand.
7 [The witness takes the stand]
8 JUDGE HALL: Mr. Andan, good morning to you, sir. Before I
9 invite Mr. Zecevic to continue, I remind you you're still on your oath.
10 Yes, Mr. Zecevic.
11 MR. ZECEVIC: Thank you, Your Honours.
12 WITNESS: DRAGOMIR ANDAN [Resumed]
13 [Witness answered through interpreter]
14 Examination by Mr. Zecevic: [Continued]
15 Q. [Interpretation] Good morning, Mr. Andan.
16 A. Good morning to everyone.
17 Q. Mr. Andan, yesterday, before the very end, we discussed the
18 events of late August 1992. Mr. Andan, sir, on the 28th of August, 1992,
19 did you return all items that were issued to you, all items and equipment
20 that were issued to you by the Ministry of the Interior?
21 A. Yes. And it was at my request; I wanted to have this hand-over
22 of all the items that I was -- that I had been issued, the items that
23 were necessary for my work and that were issued by the ministry.
24 Q. Thank you. My apologies. Do you know --
25 MR. ZECEVIC: [Interpretation] Could the witness please be shown
1 1D348 MFI. That's under tab 141.
2 Q. Let me ask you this, Mr. Andan --
3 MR. ZECEVIC: [Interpretation] Could the witness please be --
4 could the usher please assist with providing this binder to the witness.
5 THE INTERPRETER: Interpreters request: Could the microphones,
6 the witness's microphones, please be adjusted.
7 MR. ZECEVIC: [Interpretation]
8 Q. So for you, witness, that's tab 141.
9 THE INTERPRETER: Interpreter's note: The microphones should not
10 touch each other, could you please set them apart.
11 MR. ZECEVIC: [Interpretation]
12 Q. Sir, this is a report dated 31st of August, 1992, and it is
13 entitled "The Commission Investigating the Allegations in the Petition by
14 the Employees of the SJB Bijeljina." And then on the fourth page we can
15 see the signatures of members of the commission, the Goran Macar, Sreto,
16 and Spasojevic, Zoran. And then in paragraph 1 -- I've just lost the
17 document. And then in paragraph 1 it says the minister of the interior
18 issued a decision setting up a commission to verify the allegations in
19 the petition by employees of the Bijeljina SJB. The commission was
20 composed -- is -- shall be composed of Goran Macar, chairman of the
21 commission; Sreto Gajic; and Zoran Spasojevic.
22 Mr. Andan, were you aware that this commission was set up and
23 that they were trying to establish certain facts about -- pursuant to
24 some allegation?
25 A. Yes, I know that.
1 Q. Mention is made here of a petition by employees of the SJB of
2 Bijeljina. Petition number 653/92 of 30th August, 1992. Do you know
3 what this is about?
4 A. Yes, I do.
5 Q. And did you have occasion to see this commission report?
6 A. I think so. I think I've seen it before.
7 Q. Is this commission report in any way -- did it involve you in any
8 way and I mean did it involve you in view of the fact that there were
9 certain allegations there made against you and mention was made of
10 disciplinary proceedings?
11 A. Well, yes, among other things, yes, I'm aware of that.
12 Q. Mr. Andan, were you suspended from your post in late August 1992?
13 A. Well, I can't give you a short answer to this question. I would
14 have to clarify something in a couple of sentences.
15 Q. Please go ahead.
16 A. I was never handed an official document saying that I'm being
17 suspended nor did I ever receive a decision on disciplinary action
18 against me. I think I was in the field, perhaps this had to do with the
19 preparations for the trip to Foca, and the then assistant minister for
20 police Mr. Kovac came to Bijeljina, held a working meeting with the
21 employees of the CSB Bijeljina, ministry CSB employees, and without my
22 presence. And after that meeting I met with Mr. Kovac, and I also have
23 witnesses who can confirm that.
24 Now, having heard what -- about what this whole matter was about,
25 I understood that there would follow a decision on my suspension, a
1 decision sent by the ministry. When I met with this man, he was in the
2 company of armed men and he was very, very rude and brusque with me. And
3 I will have to quote now the words he said, and my apologies for it. He
4 addressed me saying the following: You have done your job professionally
5 and you deserve an A for it, an A plus, however, we needed you as a
6 condom for a one-time operation.
7 Now, I hope that based on the words that I've just quoted, and I
8 have witnesses, I believe that it clearly shows what the purpose and what
9 the objective of these men was, Mr. Kovac and some other people around
10 him from the Bijeljina CSB. Before the meeting, Mr. Kovac went to the
11 parking or depot where the vehicles which had been confiscated were kept.
12 There were some 150 vehicles there. He also toured the gym of the
13 Bijeljina CSB which was full of various items that had been stolen in
14 fact, stolen goods, and he inspected that.
15 So I believe that I have answered your question and that they are
16 what you wanted me to say, basically, that you're satisfied with my
18 Q. After this did you leave the Ministry of the Interior?
19 A. Yes. I said that I could be found at home in my house in
20 Bijeljina and if there was a need, they could come and ask me to come and
21 assist them while I spent there a month or so, but no one showed up to
22 talk to me, which would have been the logical course. They should have
23 taken a statement from me because of the allegations and the charges
24 against me, because basically the charge -- the basic charge was that I
25 took this poker machine without authorisation. And the second man from
1 the ministry, as it were, this was something that was done -- that should
2 have been done with his approval, because if I was -- if there were these
3 charges against me and that this was without authorisation, then I should
4 have been asked by him at least why I had done it without his approval.
5 And a month later --
6 Q. Just a minute, sir. I know that this part of your testimony is a
7 bit sensitive and emotional for you, but please try to speak slowly
8 because what we have in the transcript is quite the opposite of what you
10 You said that they were supposed to take a statement from you,
11 or, rather, you said: They were supposed to take a statement from me
12 because my greatest error was that I had taken a poker machine. And here
13 it reads without the approval of the second man from the ministry. That
14 should read: That should have been done with his approval and I should
15 have been questioned about this, why I did that without his approval.
16 However, I understood your answer to be something quite
17 different. So could you please repeat. Did you have authorisation from
18 Mr. Cedo Kljajic, the undersecretary for public security of the
19 Ministry of the Interior?
20 A. Well, I have to tell you something. I'm not emotional at all.
21 As far as I'm concerned, when that issue is at question at this point in
22 time I'm totally cool. I couldn't do anything of that sort without
23 asking my superior. At that point in time, my superior was Cedo Kljajic,
24 and I did ask him. I told him about this problem, if I can call it a
25 problem, and I already mentioned yesterday that this poker machine - and
1 that was a small machine, it was about the size of this screen - that we
2 should give it to the man who was supposed to be our insider at a certain
3 point in time. We needed him so that we could learn from him what was
4 going on in Janja and whether some Serb -- some members of Serb
5 paramilitary units were trying to put pressure on the Janja inhabitants
6 and so on and so forth.
7 So I addressed the undersecretary. I told him what the problem
8 was, and I suggested that it would be a good idea, with his approval, for
9 me to take that poker machine and give it to that person who was of
10 Muslim ethnicity.
11 Q. Well, did he approve that course of action for you?
12 A. Yes, he did. And he said, Go there, take that poker machine, and
13 do it that way. However, I did not really want to take the poker machine
14 without leaving any kind of paper trail. However, the man who issued
15 that poker machine to me, he did make an Official Note in handwriting and
16 he said -- which read, By approval, by authorisation of the
17 undersecretary Cedo Kljajic, the poker machine is being issued to the
18 following person. He signed that he had handed it over, and I signed to
19 show that I had received it.
20 Q. Very well. So after a month that no one came to take a statement
21 from you, what happened then?
22 A. Well, an ugly thing happened first, and the ugliness is in the
23 following: The local authorities headed by Mr. Vajo [phoen] Mandic
24 brought a summons or call-up papers. They -- I was supposed to report to
25 a military post, and they -- and to report as a soldier, not as a reserve
1 officer, to report there so that I could be sent to Majevica, to the
2 front line. Now, if you allow me, I would like to provide some
3 explanation here.
4 That month, without any kind of protection, I was exposed to all
5 manner of provocation and I was even physically assaulted in Bijeljina.
6 The only thing I thought at that time was that I should leave everything
7 behind me; that I should take my family, get on a bus, and head towards
8 Serbia, probably Belgrade, and then from there go on abroad. But,
9 frankly speaking now as I sit here, I think I was afraid. I was afraid
10 of the fact that I had participated directly in the arrest of
11 Vujo Vuckovic, Zuco, that I opposed the paramilitary units in Bijeljina,
12 that I stood up to them, and most of them actually came from Serbia.
13 The second fear that I had was that if I headed with my family
14 for Belgrade, that someone at the border crossing - well, there weren't
15 really border crossings but there was a check-point - so that one of the
16 local policeman would stop me, take me off the bus, arrest me, and then I
17 wouldn't know what would happen to my family. So that I was forced,
18 actually, to stay in Bijeljina.
19 Now, when this snide call-up or summons came from Bojan Andric, I
20 tried to actually disregard it. And in a couple of days I didn't respond
21 in any way. And then Predrag Salapura from the Main Staff of the VRS
22 came to me and he offered that I join the ranks of the VRS, which at that
23 time to me looked like a very attractive proposal. I told Mr. Salapura
24 the problem that I had with my family, and they promised that they would
25 protect my family, that there wouldn't be any pressure put on them.
1 However, unfortunately when I left, my wife and my two children
2 accompanied by 15 specials from the Serbian MUP were moved out from the
3 Muslim house in Bijeljina and then I was provided sleeping quarters by
4 some friends in Belgrade and that's how it transpired. And I'm under
5 oath here and I vouch to you that every word I said is true.
6 Q. Thank you.
7 MR. ZECEVIC: [Interpretation] Your Honour, if there are no
8 objections, I would move to have the MFI removed from this document, as
9 this witness actually recognised this report.
10 MR. HANNIS: No objection.
11 JUDGE HARHOFF: Right. We can de-MFI it for the reason that the
12 witness, indeed, has recognised the report, but I'm just making the
13 observation that nothing of what the witness has said so far actually
14 relates to this document. I mean, the poker machine isn't mentioned, as
15 far as I can see.
16 MR. ZECEVIC: It is, Your Honours. On page 4 of the document
17 is -- the poker machine is mentioned.
18 JUDGE HARHOFF: Okay. I accept that. It's just that we can only
19 see the page that is on the screen. Thank you.
20 JUDGE HALL: So the MFI qualification is removed.
21 MR. ZECEVIC: [Interpretation]
22 Q. Mr. Andan, after you joined the ranks of the VRS, where did you
24 A. I went to Han Pijesak.
25 Q. Just a moment, please.
1 [Trial Chamber confers]
2 THE INTERPRETER: Microphone, Your Honour.
3 MR. ZECEVIC: Thank you.
4 Q. [Interpretation] Mr. Andan, in the fall of 1992, did you see
5 Vitomir Zepinic?
6 A. Yes. I began to work in intelligence of the VRS, in an
7 intelligence department, and my task was to go to Pale. And then, on my
8 own initiative, I went to Lukavica because I heard that
9 Vitomir Popovic -- Vitomir Zepinic, my apologies, was in Lukavica, that
10 he was a VRS officer there, and I wanted to meet him, which I did.
11 Q. You say that he was a VRS officer. What type of duty was he on
12 and who was his superior officer, if you know? I mean, what was the
13 situation when you went to Lukavica?
14 A. He worked in the command of the Sarajevo Romanija Corps in the
15 security department, and his immediate superior was
16 Colonel Marko Lugonja, and I think, or, rather, I'm certain, that at the
17 time had the rank and he bore the insignia of captain of the VRS.
18 Q. Thank you. Do you know that his family was in Nis, in Serbia?
19 A. Yes, I know that, too. And I even believe that he told me that
20 he had already visited them once, and he said he was very grateful to his
21 immediate superior Lugonja who allowed him to use his own vehicle, his
22 vehicle, to go and see his family in Nis. He told me this his family was
23 indigent there, that they had very meager means and poor living quarters,
24 and he had to go there to try and help them improve their living
1 Q. Do you know what happened after that to Mr. Zepinic?
2 A. Yes, I do. After he left, I read an information. Mr. Zepinic
3 went on a furlough. Every 40 days, officers were allowed ten days of
4 furlough. So he received an official car, he went on furlough, he went
5 to Nis to get his family. They all boarded that official car. The car
6 was found some place near Subotica, close to the Hungarian border. It
7 was found by the Serbian police. Since the registration plates belonged
8 to the VRS, they notified the Main Staff or maybe somebody else, I'm not
9 quite sure exactly, but I know that Mr. Lugonja sent some men to get the
10 car back. Later on, it transpired that he had crossed the state border
11 and left the country.
12 Q. Thank you. Mr. Andan, do you know that the government headed by
13 Prime Minister Djeric collapsed, if I may put it that way, or resigned,
14 to put it in another way, and do you maybe know when that happened? I
15 know that you are not very good with dates, but do you remember that?
16 A. I think it was in 1992. I do not know the exact date. Of
17 course, many problems had accumulated. I consider Mr. Djeric to be an
18 honest man, and at that point in time he was simply unable to deal with
19 the crime that had accumulated in the Serbian ranks. He probably wasn't
20 courageous enough and he couldn't deal with that so he resigned, and I
21 think that led to the resignation of the whole government.
22 Q. Do you remember that in 1994 Mico Stanisic was appointed once
23 again to the post of the minister of the interior?
24 A. Yes, I remember that.
25 Q. Did you have a meeting with Mico Stanisic and what was the topic
1 of that meeting?
2 MR. HANNIS: [Microphone not activated] Can we place that in time.
3 I assume you're talking about in 1994 after Mico was appointed again?
4 MR. ZECEVIC: Yes.
5 And the witness can give the answer.
6 THE WITNESS: [Interpretation] I'm not quite sure how long it was
7 after he was appointed, but sometime towards the end of 1993 in the
8 Sarajevo settlement of Grbavica I established an intelligence point.
9 That's where I performed my duties. All of a sudden I received a call
10 from Mr. Dragan Kitso [phoen]; he was head of national security at the
11 time. He asked me whether I could come and meet him and Mr. Stanisic in
12 the Kikinda facility. That's one or two kilometres away from Pale
13 towards Jahorina. I accepted that invitation the same day or the day
14 after, and I met with Mr. Stanisic and Mr. Kitso in an office.
15 After a bit of a small talk, we began with the official part of
16 the meeting. And that's when Mr. Stanisic offered me the following: He
17 told me that he wanted to speak to me about the establishment of a unit.
18 I'm not sure whether that unit was supposed to be part of the state
19 security or public security, but here I would opt for the state or
20 national security. He told me that this unit was supposed to deal with
21 war criminals. The time had come for everybody who committed war crimes
22 to be investigated and prosecuted. The time had come for the final
23 show-down with all those people who were engaged in criminal activities.
24 And I assume that Mr. Stanisic, Mr. Kijac, and their associates
25 thought about this problem and decided to speak to me first, to ask me
1 whether I would be willing to accept this duty, whether I would be
2 willing to begin a war of a different kind, so to speak.
3 I was also told that if I accept this, that within a few days I
4 would be given 150.000 German marks in order to equip the unit with all
5 the necessary equipment. I was told that the funds had already been
6 allocated for that. I was surprised by the invitation and by the
7 conversation. I told Mr. Stanisic and Mr. Kijac that I needed some time
8 to think it over, but I also told them that I had one precondition for
9 all this, and that was that I was supposed to choose the personnel.
10 Mr. Stanisic immediately accepted that. I told them that I would need
11 two squads within the unit, one squad to gather intelligence and the
12 other squad to analyse intelligence. So I wanted to have two squads,
13 operative and analytical.
14 I think that there was also a preliminary discussion about the
15 premises in Pale where this was supposed to be situated. I asked
16 Mr. Stanisic and Mr. Kijac that there should be no influence of political
17 structures of Republika Srpska over me, and they promised me that.
18 So that's how this conversation ended. And I was supposed to
19 contact them again after some time, three days, four days, seven days,
20 and we were supposed to arrange my transfer from the military to the
21 Ministry of the Interior.
22 MR. ZECEVIC: [Interpretation]
23 Q. Did it happen?
24 A. Unfortunately not. I will try to explain this. I didn't know at
25 the time but later on I heard that Mr. Stanisic and part of his team, I
1 don't know what team that was, had already began working on these issues.
2 He had already began to collect certain intelligence related to organised
3 crime. I heard that some high-ranking persons and their brothers were
4 involved in it. I heard that politics interfered again, and nothing came
5 out of this unit. Also, nothing came out of Mico Stanisic being
6 appointed again to the post of the minister. When they learned that he
7 began gathering this intelligence, he was replaced.
8 Q. Thank you very much, Mr. Andan.
9 MR. ZECEVIC: This is all [Previous translation continues] ...
10 I said that -- I see that the record doesn't record what I said.
11 I finished my direct examination of this witness.
12 JUDGE HALL: Thank you, Mr. Zecevic.
13 Mr. Aleksic.
14 MR. ALEKSIC: [Interpretation] Your Honour, we have no questions
15 for this witness. Thank you.
16 Cross-examination by Mr. Hannis:
17 Q. Good morning, witness. My name's Tom Hannis, I'm the Prosecutor
18 in this case, or one of the Prosecutors in this case.
19 I want to start by going back to the first day you were on direct
20 examination and you were talking a little bit about your background in
21 the MUP. At page 21343 you told us you were holding the position of
22 senior inspector 1st class.
23 I had a question for you: How many senior inspectors 1st class
24 were there in the BiH SUP at that time? Was there only one or were there
25 several of you?
1 A. No, not only one, several.
2 Q. And was that on the public security or the state security side of
3 the house?
4 A. It was the public security side.
5 Q. Thank you.
6 Early on you told us that you considered yourself an operative by
7 nature. Can you tell us your definition of an operative. What was an
8 operative or what did you do as an operative?
9 A. Could you be more specific? Are you referring to my operative
10 work in the state security service? Because while I was in the public
11 security service I was more of a manager and less of an operative.
12 Q. Yes. For the moment let's talk specifically about in state
14 A. I worked in the state security service. I was an operative in
15 the emigration department. More specifically, I was in charge of
16 gathering the intelligence about the Ustasha emigration in the area of
17 West Germany.
18 Q. And from when till when did you hold that position and do that
20 A. If you want to know about my whole work in the state security
21 service, I can tell you that I began working there in March 1976. I
22 worked in the surveillance service first. And if you're not quite
23 familiar, maybe you will not receive an interpretation that will be clear
24 to you immediately.
25 I spent a period of time as part of the surveillance team that
1 followed the persons of interest to the service. I would also be engaged
2 during that time with the technical part of the job, that is,
3 installation of the equipment and eavesdropping of the persons of the
4 interest to the service.
5 The third phase of my work was in the operative department for
6 emigration. I worked there until approximately the end of 1983. That's
7 when I was transferred to the public security service.
8 Q. And what work were you doing in 1991 and 1992 before the split of
9 the MUP?
10 A. I already told you that I was a senior inspector 1st class in the
11 police administration in the public security service of the Ministry of
12 the Interior of the Socialist Republic of Bosnia and Herzegovina.
13 Q. And briefly, those duties included going out into the field and
14 doing inspections; is that correct?
15 A. Yes, that was a primary task, to control the police stations. I
16 told you that we had various regions and we had to visit every police
17 station at least once a year. We had to perform the supervisory
18 inspection, we had to write the report related to that inspection, and
19 specify measures that that police station was supposed to undertake
20 within a certain dead-line.
21 Q. If, for example, you saw problems in a CSB or an SJB, did you
22 personally have the authority to compel or impose corrective actions, or
23 could you only report it up and it was for someone else to direct that
24 action be taken?
25 A. Of course, first I had to observe the problem, then I had to
1 report my -- to my superiors about that problem in writing. In that memo
2 or record, it was part of my duties to also propose to my superior the
3 measures that had to be undertaken in order to resolve the problem.
4 Q. How did that work? Did you also give a copy -- of your proposals
5 that went up to your superior, did you also give a copy of those to the
6 SJB chief or the person inspected? Do you understand my question?
7 A. In the beginning we did not have the duty to forward a copy of
8 that to the chief of the police station or chief of the centre, but then
9 there was an instructive dispatch that introduced the obligation that the
10 person who was inspected had to sign that he or she was in agreement with
11 the supervisory inspection. One copy was then left with the chief of the
12 centre or station, and the other copy I took to Sarajevo and handed over
13 to my superior. However, after this instructive dispatch, we had to
14 write our report on the spot, because we had to leave a copy in the hands
15 of the chief who had been inspected.
16 Q. And what was the practice in terms of what the superior did with
17 your recommendations? Were you informed about whether or not your
18 recommendations were accepted or whether they were rejected or modified?
19 What was the process in that regard?
20 A. The procedure was as follows: When the supervisory inspection
21 was completed, we were supposed to meet with a particular officer and
22 inform him about our findings. If there was something urgent, then my
23 superior would order me or the inspector who did the job to write a
24 dispatch, an urgent memo. The dispatch would be signed by the chief, and
25 it would contain the immediate measures that had to be undertaken.
1 Later on, in the second phase, after there was a chance to have a
2 discussion about the whole of the report, we would write a separate
3 report containing only the necessary measures. It would go something
4 like: This was observed, has to be resolved until this dead-line; that
5 was observed, has to be resolved until this dead-line.
6 So that was the usual procedure, if my memory serves me right.
7 Q. Thank you. Mr. Andan, you, I think, told us that you had been
8 interviewed by personnel from the Office of the Prosecutor on two
9 occasions, I think once in Brcko and once in Banja Luka; correct?
10 A. That's correct.
11 Q. Do you remember me being one of the persons who interviewed you
12 in Brcko, the one you described as the more friendly, less formal
14 A. Quite honestly, I don't remember. But if -- I'm quite glad that
15 I put it that way.
16 Q. Yeah, me too.
17 Do you remember the investigator from New Zealand who
18 participated in that discussion?
19 A. No. Until I see him, I'm unable to remember. I remember one
20 investigator, and that's the one who spoke to me in Banja Luka. And if
21 you want me to say something about that, I can tell you something about
22 that particular investigator.
23 Q. No, that's all right. I want to return to the inspection process
24 just for a minute.
25 Typically if you went out to an SJB to do an inspection, was
1 there a standard procedure or protocol you follow in terms of who you
2 talk to, what kinds of documents or log-books you looked at? Was there
3 some kind of routine that you followed?
4 A. Yes, there was a procedure.
5 Q. Can you briefly describe for us what that involved.
6 A. Well, there were two kinds of inspections, announced and
7 unannounced. An announced inspection would be performed only after the
8 relevant organ would be notified in advance that on a certain date two
9 inspectors - it was usually two inspectors - would come in order to
10 inspect the particular police administration or police station.
11 Unannounced supervisory inspection would be performed when the
12 crime service or the police administration service would receive
13 information about some problems in the work of a police station. That's
14 when we would usually receive an oral order to find all relevant facts.
15 So there was regular supervisory inspection; that was announced. And
16 there was also the other kind.
17 When we would arrive to the police station, we would immediately
18 contact the commander of the police station. Later on when there were
19 security centres, we had to visit the chief of the centre and notify him
20 that we were going to perform a supervisory inspection of this particular
21 or that particular police station. After we did that, we would have to
22 return to him and inform him about our findings.
23 After we spoke to a commander, we would ask him to give us all
24 the documents in the particular police station; daily event log-book,
25 other registers, KU register, and all other log-books and registers
1 stipulated by the internal regulations and by the Law on the Interior of
2 the Socialist Republic Bosnia-Herzegovina. Once this part was finished,
3 because the police and the crime service shared some of the tasks, we
4 insisted, particularly during the last ten years, that the police had to
5 take a more prominent role in resolving the crimes in their relevant
6 areas. So the police would receive every notification about every crime
8 During our inspection we would also contact chief of the crime
9 service in order to find out what percentage of crimes were resolved.
10 And in the end we would also determine the level of order and discipline
11 in the police station.
12 At the end of the supervisory inspection, there would be a
13 working meeting with all the authorised officials belonging to a certain
14 police station. We would briefly inform them about the situation as we
15 had found it, and we would give them brief instructions related to their
16 future work.
17 So that was more or less what we did. I hope that I gave you an
18 appropriate answer. It would usually take two working days, two times
19 eight hours, and then that would be the end of our supervisory
21 Q. And can you tell me where in the rules we might find this
22 description of the procedure for carrying out an inspection like this?
23 Would that be in the Rules on Internal Organisation of the MUP, or is it
24 in some other rule book that I don't know about? Do you know? Do you
1 A. I think it was more of an internal document or regulation that we
2 used in the police administration. It was available to us, and that
3 regulation lists all points based on which this inspection or audit was
4 to be conducted. I don't believe that the public security service also
5 applied that because the nature of their job was different. And it
6 wasn't provided for by the Law on Internal Affairs either.
7 Q. Now, I know you're talking from your experience when you were
8 working as an inspector in public security before the split. Was the
9 same procedure applied in the RS MUP after April 1992 in terms of how
10 inspections were supposed to be conducted, if you know?
11 A. I must say that in 2000 when I returned to the MUP of the RS, my
12 first inspection or audit was the one I conducted in Visegrad, and I
13 applied all methods that I applied before the war. So I did about it the
14 same way, because nothing had changed in essence. Possibly the legal
15 procedure had changed somewhat. The greatest change was that it was no
16 longer the socialist republic, but we did the same policing jobs after
17 the war as before the war and during the war, too, whenever an audit was
19 Q. All right. I want to talk a little bit about the -- your
20 testimony beginning at page 21372 last week on Thursday. Mr. Zecevic was
21 talking to you about the personnel policy in the BiH MUP under
22 Mr. Delimustafic.
23 MR. HANNIS: And if we could show the witness Exhibit 1D347.
24 Q. Mr. Andan, this was a document you were shown before. It will be
25 up on the screen in a moment.
1 MR. HANNIS: And I think I need to go to paragraph 6 which I
2 think is on page 2. Yes.
3 Q. You recall seeing this? This is a document from Mr. Cengic in
4 the SDA. Do you remember seeing this before, last week?
5 A. Yes, I do.
6 Q. Now, you see the last sentence in paragraph 6 says:
7 "We need to persevere until the end with these changes in the SJB
8 and achieving ethnic balance."
9 Now, to me, when that says achieving ethnic balance, it sounds
10 like, at least in his view, that there was some sort of pre-existing
11 imbalance in the SJB or the SUP.
12 Do you know, in late 1991, what the relative percentages of
13 Croats, Muslims, and Serbs were in the police? Do you have any idea
14 about that?
15 A. I cannot state any percentages, but I think that the Muslims were
16 the most numerous, followed by the Serbs, and the Croats were third
17 because they were the least numerous in Bosnia-Herzegovina.
18 Q. What about in the JNA; do you know the relative percentages among
19 the three primary ethnic groups?
20 A. As far as I know, the Serbs were in first place, followed by the
21 Muslims, Croats, and finally, Slovenians. Well, I skipped the
22 Macedonians; there were some, I'm sorry. And the Montenegrins were
23 actually quite strongly represented in the JNA.
24 Q. Thank you.
25 Now, you said that you noticed that the personnel policy that was
1 being pursued was, in your words, an unprincipled one, and you gave us a
2 couple of examples of what appeared to be bad choices. You told us about
3 Mr. Jasarevic who was promoted from a sort of an assistant position, I
4 think, in the SJB all the way up to head of a task for defence
5 preparations. But I want to ask you, would you agree with me that at
6 this time in late 1991 and early 1992 that all three of the national
7 political parties, the HDZ, the SDA, and the SDS, were trying their best
8 to manipulate the appointments in the police at all levels, at the
9 republic level, at the regional level, and the local? Would you agree
10 with that as a general principle?
11 A. Let me first say that I heard you say "Pasarevic," whereas the
12 name is actually "Jasarevic," or maybe I misheard the interpretation.
13 But I do ask you to be a bit more specific. When you say
14 manipulate, what exactly do you mean?
15 Q. Well, I mean that they were more interested in getting someone
16 appointed based on that individual's political affiliation, that is, it
17 was more important to get somebody who was in the SDS, for example, or
18 friendly to the SDS, rather than someone who was a professional policeman
19 or qualified based on their experience. Same goes for HDZ and SDA.
20 A. Yes, there were such examples in abundance.
21 Q. And let me ask you, because I don't know if I've heard before,
22 before -- well, I guess it didn't come up before, right, because before
23 the national parties came into existence, there was just one party and
24 that was the communist party, and everybody in the police sort of had to
25 be a member of the communist party; is that correct?
1 A. That is correct, yes, absolutely.
2 Q. And during that time appointments, I take it, were made more on
3 merit rather than politics; somebody got appointed head of the SJB
4 because they had experience as a policeman?
5 A. Well, I must say that even then the ethnic composition of the
6 personnel was considered, at least in Bosnia-Herzegovina. It couldn't
7 happen that the chief of the -- of an SJB was a Serb, that the commander
8 was a Serb, and that the head of another organisational unit was also a
10 Let me give an example. When I was appointed commander at -- in
11 Novo Sarajevo, the chief of the police station was a Croat, his assistant
12 Kemal Sabovic was a Muslim, and the second assistant was Vitomir Zepinic.
13 I was commander of the police station, whereas the chief of the crime
14 enforcement service was a Muslim. Along with all the references that you
15 needed at the time, and I mean first and foremost the results of your
16 work, what was considered also was the ethnic composition and the
17 position to be taken by a member of -- or, rather, by a person of a
18 certain ethnic affiliation, and of course you had to be a member of the
19 communist party, which I was, too.
20 Q. Now, I want to ask you about some appointments of Serbs to
21 positions in the SUP before the war broke out in April 1992, and maybe a
22 few shortly thereafter.
23 Borislav Maksimovic was, I think, SJB chief in Vogosca, and it's
24 my information that before that, before he came to the police, he had
25 been a journalist. Did you know about that? Did you know him?
1 A. I know that Mr. Milenko Tepavcevic was in that position.
2 Maybe immediately before the war he was replaced by somebody else. But I
3 do not remember that this somebody was this man Maksimovic you have
4 mentioned. I really don't remember.
5 Q. How about Risto Perisic, chief in Visegrad who had been a school
6 teacher before being appointed to that post; did you know him?
7 A. No. I wasn't interested in that at the time. I covered
8 Eastern Herzegovina. I heard of Mr. Perisic a bit later, but I didn't
9 know that -- of this personnel change. I think that Mr. Stambolic
10 covered the area of Eastern Bosnia and he was certainly better informed.
11 Q. One more and then I'll move on. How about a Radomir Bjelanovic,
12 chief in Vlasenica until the latter half of May 1992. Prior to his
13 appointment he'd worked at the bauxite mine in Milici and didn't have any
14 prior police experience. Did you know him? He later was then, I think,
15 chief in Milici after May of 1992.
16 A. I had the opportunity to meet him during the war. He wasn't in
17 that position long because he clashed with the director of the bauxite
18 mine. I know that he didn't work in the police force before the war and
19 that he was -- he joined the police during the war.
20 Q. And the director of the bauxite mine that he clashed with, was
21 that Rajko Dukic?
22 A. Yes, Rajko Dukic.
23 Q. The same Rajko Dukic who was president of the SDS Main Board in
24 1991 and 1992?
25 A. Yes, the same Rajko Dukic who, as far as I know, was in charge of
1 Serbian personnel for a while, I mean the distribution of Serbian
2 personnel. Vitomir Zepinic was also a product of his personnel policy,
3 because he appointed him to his position because they hailed from the
4 same area.
5 Q. Thank you. And had Mr. Zepinic had any prior police experience
6 before that appointment?
7 A. Well, yes, we can say that he did have previous experience. And
8 he was the assistant of the joint forces of Bosnia-Herzegovina in Kosovo
9 at the time of the demonstrations there. He was assistant commander at
10 the time, and he did have some experience. Not necessarily enough to be
11 appointed to that position, in my modest opinion, but he did have some
12 police experience, yes.
13 Q. Thank you.
14 I want to move to the beginning of March 1992. You are well
15 familiar with the event, I think, in the 1st of March when a Serb wedding
16 guest was shot, and then shortly thereafter barricades were set up all
17 around the town. You know the event I'm talking about?
18 A. Yes, we have already discussed it.
19 Q. Yes. And when you were talking with Mr. Zecevic, you talked
20 about, I think, you and other members of the police were called in to the
21 building and sort of stood around for a long time with nothing to do; is
22 that correct?
23 A. I do not know which building you're referring to. Please be more
25 Q. Well, I understood from Mr. Zecevic's question at page 21384 that
1 it was in the MUP building of the Socialist Republic of
2 Bosnia-Herzegovina. Is that not correct? Is that the building where you
3 were all gathered?
4 A. Yes, that's the building.
5 Q. And you don't remember seeing Mr. Stanisic in that building that
6 night, do you?
7 A. I said that I had seen Mr. Kljajic. I'm not sure that I saw
8 Mr. Stanisic. I cannot confirm that or deny that. I don't remember.
9 Q. How about Momo Mandic?
10 A. Yes. I didn't see him during the night, but during the day he
11 came to his office. I have already said as much. And then my friend
12 Kemal Sabovic went to those barricades with him. That's when I saw him.
13 MR. HANNIS: Could we show the witness 65 ter 822D1. I don't
14 know if that received an exhibit number or not.
15 Q. Mr. Andan, I'll show you a document that you were shown by
16 Mr. Zecevic when discussing this event. And it's a document that has a
17 typed block at the end as the "Serb Crisis Staff."
18 Now, when was the first time you saw this document? Did you see
19 it in 1992 or did you only see it when you came to testify? Do you
21 A. In 1992 I didn't have the chance to see this document.
22 Q. And do you -- [Microphone not activated] I'm sorry. Do you know
23 who was a member or a part of this Crisis Staff for the Serbian People of
24 BiH in March 1992? Do you know any the people who might have been on
25 that Crisis Staff?
1 A. I do not know the composition of the Crisis Staff, but I heard at
2 the time that the chief of the Crisis Staff was Rajko Dukic and that
3 Mr. Mandic had direct communication with him. I do not know who the
4 other members were.
5 Q. This document is headed as "Conditions for Negotiating," and
6 there are certain demands made. Do you know to whom this document was
8 A. No, I don't.
9 Q. And how about do you know if anybody in the MUP of the
10 Socialist Republic of BiH investigated this document and this incident
11 concerning the barricades?
12 A. I think that the state security service rather than the public
13 security service conducted investigation, not triggered by this report
14 but due to the barricades. The state security service did conduct an
16 MR. HANNIS: Your Honours, I know it's a couple of minutes early,
17 but this would be a convenient point for me to break and check something
18 before I continue.
19 JUDGE HALL: So we would resume in 20 minutes.
20 [The witness stands down]
21 --- Recess taken at 10.22 a.m.
22 --- On resuming at 10.54 a.m.
23 [The witness takes the stand]
24 JUDGE HALL: Yes, Mr. Hannis.
25 MR. HANNIS: Thank you.
1 Q. Witness, before we leave this document, I just want to draw your
2 attention to two or three items and ask you to keep them in mind when I
3 move on to the next area. Among these, what I would describe as demands
4 from the Crisis Staff of the Serbian People in BiH, number one talks
5 about "all further activities in the campaign about trying to declare a
6 sovereign and independent Bosnia." Number 6 talks about a demand that
7 the TV and radio be urgently divided. And number 8 - we need to go to
8 the next page in English - but you can see your number 8 talks about the
9 resignation of the Crisis Staff and Mr. Ganic resigning from his post.
10 Do you know who Mr. Ganic was?
11 A. Before I answer your question, I must point out that there's a
12 problem with the air condition again. When I first sat down here this
13 morning, there wasn't so much draft. Could this be taken care of
14 somehow? Because it was much more pleasant when I first came here this
15 morning. Or maybe if I could get a cap or hat.
16 Yes, I know who Ganic was. No need, thanks.
17 Q. Yes, we've historically had some climate problems in this
18 courtroom, and I would join in your request. We'll see what we can do
19 about that.
20 But tell us, who was Mr. Ganic? What was his full name and who
21 was he?
22 A. Ejub Ganic after the first multi-party elections in
23 Bosnia-Herzegovina was elected to the position of a member of the
24 Presidency of Bosnia-Herzegovina as a Yugoslav. I believe, or, rather, I
25 hope I stated this accurately. He was appointed as a Yugoslav anyway.
1 Q. Okay. Thank you.
2 Now, I think you told me earlier that you understood that the
3 state security service you believe carried out some sort of investigation
4 of how the barricades came about and who was involved. I'd like to show
5 you a document now that is Exhibit P911. 911.
6 MR. HANNIS: I have a hard copy in the B/C/S, if the usher could
7 hand that to you. I think it will speed things up because it's several
9 JUDGE DELVOIE: Mr. Hannis, it would be very helpful if you could
10 give the tab number, as well, of the documents. And the binder you're
11 citing from, it is your binder or Defence binder?
12 MR. HANNIS: Yes, Your Honour, I'm sorry, Your Honour. P911 is
13 at tab 11 of the Prosecution list.
14 JUDGE DELVOIE: Thank you.
15 MR. HANNIS:
16 Q. Take your time to look through that, Mr. Andan. And when you're
17 ready to, let me know by telling me whether or not you've seen this
18 document before today.
19 MR. HANNIS: Your Honours, I apologise, I didn't think to give it
20 to him before he went out on the break. I'll try to do that the next
22 Q. Thank you, Mr. Andan. I take it, by your careful read of that
23 document, you had not seen it before today; is that correct?
24 A. That's correct, I haven't seen it before.
25 Q. You see, it's described as a security information in relation to
1 the events of 1, 2, 3, and 4 of March in Sarajevo. Given that you were
2 present in Sarajevo at the time of these events, and having read it, can
3 you tell us, based on the parts in the report that describe events that
4 you may have personal knowledge of, is it consistent with what you saw
5 and heard at the time?
6 A. I cannot speak about things that I haven't had personal
7 involvement in, but there were two events when we were called up to come
8 to the MUP and we learned that night that the Serbs were setting up
9 barricades, that they wanted to separate Sarajevo or divide it into two
10 parts. And the second event was when I went with Mr. Music, my
11 colleague, to his house, where I saw a lot of armed men, but at that
12 point in time and not even later, I have to say, did I realise that they
13 were actually erecting barricades. I did see armed men. They were
14 leaving their homes with long-barrelled weapons. But at that point in
15 time I wasn't aware that they were setting up barricades.
16 So I can confirm that basically the intelligence that is set out
17 here, and based on my experience with those two events, incidents that I
18 mentioned, I can confirm that this is probably correct. Now, I didn't
19 have any information about Ilidza or Ilijas or Vares or any of the other
20 places that are mentioned in this report.
21 Q. Thank you.
22 MR. HANNIS: Let me show you another document related to this
23 event. This is P643. This is a shorter document. And I'd like to hand
24 you a hard copy of this one as well. It's tab number 12 in the
25 Prosecution's list. Thank you.
1 Q. Mr. Andan, this is -- well, the cover letter is dated the
2 13th of March, 1992, to the minister of the Internal Affairs from the
3 subsecretary in charge of SDB. Before you look at the contents, can I
4 ask you, do you know who the subsecretary in charge of SDB was at that
5 time? Can you recognise the name or signature?
6 A. Yes, that was Branko Kvesic. He was the undersecretary for state
7 security and he was of Croat ethnicity. I don't know if this is actually
8 his signature, but I do know that he was the undersecretary for the SDB.
9 Q. And if you could, could you just take a quick look at it, not
10 necessarily reading the entire thing at the moment, to tell me whether or
11 not you've seen it before?
12 A. No, I haven't seen it before.
13 Q. You'll see on the second page it is a list of MUP employees who
14 took part in the activities related to the barricades in early March. I
15 see number 1 is Momcilo Mandic. Were you aware that Mr. Mandic had taken
16 part in those events?
17 A. Yes, I was aware of that.
18 Q. And how did you know about his participation?
19 A. Well, that night, as we were sitting in our offices, one of our
20 colleagues mentioned that Momo had organised those barricades, but I have
21 to say, he didn't even try to hide his activities. He wasn't going to
22 hide it. He was one of the leaders on those barricades, in fact.
23 Q. On your page 4, and it's English page 3, number 13 is listed as
24 Malko Koroman. Did you have any knowledge or information about his
25 participation in the barricades?
1 A. Well, again, obviously this -- there is an error in the
2 translation; it's not "Malko" Koroman but "Marko" Koroman. But I don't
3 know anything about his activities during the barricade events.
4 Q. Thank you for that. And if you could go to the last page. And
5 there's a paragraph that says:
6 "In the Crisis Staff of the SDS, among others, the following
7 persons were engaged: Mr. Mandic; 2. Mico Stanisic; 3. Dragan Kijac;
8 4. Dragan Devedlaka; and 5. Cedo Kljajic."
9 Were you aware about the participation of those last four in the
10 events involving the barricades in early March 1992?
11 A. Well, I have to say again, I did see Cedo Kljajic that night on
12 the premises of the Ministry of the Interior. It is possible that he
13 went and met with these other men at some point during the night, but for
14 Cedo I can claim here with certainty that he was not a member of the
15 staff. For Momcilo Mandic, I know that he was there. But about the
16 other men, the Kijac and Devedlaka, I don't know anything about that. As
17 for Cedo Kljajic, I was there that night in the office, and I did see him
18 there. I can say that.
19 Q. But I take it from your answer you didn't see him there all
20 night, you saw him there for some shorter period of time; is that
22 A. Well, I saw him on several occasions actually, and I believe that
23 even in the morning when we brought this fresh bread, still warm, from
24 Bascarsija that he was with us there. He partook in our breakfast.
25 Later on, I went -- well, you know, it is possible that someone might
1 even say that they saw me on the barricades, because at one point in time
2 I went home during that night, but I actually did not go there. So as I
3 said, Mandic didn't -- was there; he didn't even hide that fact. But as
4 for Cedo and Devedlaka and Kijac, I don't know anything about that.
5 MR. ZECEVIC: Sorry, could you speak slower because a number of
6 the things that -- words was not recorded.
7 In 32/25, the witness -- the witness, I think, said something
8 different than it is -- it is recorded.
9 "He partook in our breakfast. Later on, I went -- well, you
10 know, it is possible that someone might" - might have seen me,
11 I believe - "that they saw me on the barricades, because at one point in
12 time I went home during that night, but I actually didn't go there."
13 I believe the witness gave a quite different answer, I mean, with
14 a different meaning of the answer.
15 MR. HANNIS: Well, Your Honour, I would prefer that there's an
16 opportunity that this be dealt with when the transcript is listened to
17 and before its finalised. Otherwise, I would request my learned friend
18 to make a note and it's something he can address in re-direct, if it
19 hasn't been taken care of after the audio has been listened to.
20 JUDGE HALL: Except, Mr. Hannis, if it is something which
21 significantly changes the meaning of what the witness intended to convey,
22 it should be dealt with as early as possible. I would suggest that the
23 witness be referred to what is recorded, and if you could phrase the
24 question again.
25 And, Mr. Andan, one of the difficulties that -- one of the
1 problems that should be avoided is you're speaking so quickly that the
2 interpreters are unable to accurately interpret what you're saying so as
3 to convey what you intend to tell us.
4 So, Mr. Hannis, if you could ask the question again and invite
5 the witness to repeat that account.
6 MR. HANNIS:
7 Q. My question was - and, Mr. Andan, you've heard the discussion.
8 Let me ask you again, and please try and recall your answer and tell it
9 to us again but slowly so the interpreters can follow.
10 My question was: "I take it from your answer you didn't see
11 him," meaning Cedo Kljajic, "there all night, you saw him there for some
12 shorter period of time; is that correct?"
13 A. No, that is not what was said. I said that when we received this
14 call, when the phone call came telling us to come to the offices of the
15 republican Ministry of the Interior, I found Mr. Cedo Kljajic in his
16 office then. A little later, sometime in the morning hours when
17 Mr. Teufik Music and I went to Bascarsija, and as I said we also went by
18 Vratnik from where we brought warm flatbread and somuns, we found
19 Cedo Kljajic in the office and he ate those somuns with us, together.
20 I little later that morning, I said that I went to the barricade,
21 and I described that a little earlier, and based on that one could claim
22 that I, too, had participated in organising the setting up of those
23 barricades, which I did not. You can see that there's -- from the
24 Official Notes there's nothing that would put me in connection with
25 setting up the barricades. But as for Cedo Kljajic, I did say that I saw
1 him in the morning hours in his office.
2 Q. I guess what I was trying to establish was, were there periods of
3 time during that night when you did not see Mr. Kljajic?
4 A. Yes, there were such periods. We were mobilised in the evening,
5 sometime around midnight. We spent the whole time on the same floor. We
6 were not all the time with him. But I mentioned two moments when I saw
7 him, the first time when we greeted him and when we asked him what was
8 going on and why we had been called up. He didn't have any specific
9 answer to that. And then the second time that I saw him was when we
10 returned from Bascarsija with the somuns. Whether he left his office,
11 whether he met anybody, I cannot speak about that. But I did see him on
12 those two occasions during the night.
13 Q. Thank you, Mr. Andan.
14 MR. HANNIS: I next want to show you Exhibit P1110, which is at
15 tab 6 of the Prosecution list.
16 Q. Mr. Andan, I can hand you a hard copy of this as well. I will
17 tell you, this is a document that's in evidence already in this case.
18 It's an intercepted telephone conversation that is listed as having
19 occurred on the 2nd of March, 1992, between Jovo Jovanovic,
20 Radovan Karadzic, and Radovan Karadzic and Mico Stanisic.
21 While you're looking through that, let me ask you, Do you know
22 who Jovo Jovanovic was?
23 A. I don't know Jovo Jovanovic.
24 Q. You will see in the conversation Mr. Jovanovic is talking to
25 Mr. Karadzic and at one point in time, I'm not sure which page it is in
1 the B/C/S, but Mr. Jovanovic says: "We want to remove barricades. We
2 reached an agreement and that's all. Rajko just passed the information."
3 Do you find that?
4 A. Which page is that?
5 Q. I think it's on your page 2.
6 A. Yes, I saw it.
7 Q. So it appears to be a discussion about the barricades. If you
8 could go on, about the middle of that page, and Mr. Jovanovic says:
9 "Just what we wanted, there won't be any negotiations with Europe
10 about either sovereign or non-sovereign Bosnia and Herzegovina until the
11 parties agree on that one."
12 You remember that Crisis Staff of the Serbian People document we
13 looked at earlier and the demands. Do you recall that was one of the
14 demands? Do you remember that?
15 A. Yes, if I remember right.
16 Q. And just a few lines down below that you see Jovanovic reports:
17 "They agreed to dismiss Ganic's staff."
18 Do you remember that was number 8 in the Crisis Staff document
19 list of demands, was having Ganic resign or be removed? Do you recall
21 A. Yes.
22 Q. Thank you.
23 MR. HANNIS: And then if we could go to page 6 of the English.
24 Q. And for you I think it begins at the bottom of page 4. You see
25 Mico Stanisic is coming on to the phone and speaking with Mr. Karadzic.
1 And I think on your page 5 you're seeing they're talking about removing
2 the barricades. You see that? And there's a mention of Pofalici. Do
3 you know where that was and whether there was a barricade in that area?
4 A. I don't know -- oh, I found it. Yes, I know where Pofalicis are.
5 Q. And do you recall if there was a barricade in that area on the
6 2nd of March?
7 A. I think yes.
8 Q. Thank you.
9 Next I'd like to have you take a look at another one.
10 MR. HANNIS: This is Exhibit P910, Your Honours. That's at
11 tab 8. It's a short one, but I can hand the witness a hard copy of that
12 with the usher's assistance.
13 Q. Mr. Andan, this is another one from the 2nd of March. This is an
14 intercepted telephone conversation between Mico Stanisic and Rajko Dukic.
15 Regarding the Serb Crisis Staff and the barricades, did you know
16 or did you ever hear or learn any information about where they were
17 physically located at that time? Do you know where they were set up?
18 A. Excuse me, I didn't hear your question. There was an
20 Q. I apologise. Do you know, did you have any information at the
21 time or subsequently, did you learn about where the Serb Crisis Staff was
22 set up on the 2nd of March during the barricades event?
23 A. No, I did not know that.
24 Q. Have you had a look at this brief conversation between
25 Mr. Stanisic and Rajko Dukic?
1 A. I haven't read all of it. I'll try to read it now.
2 Q. Just let me know when you're done.
3 On your page 1, page 2 of the English, Mr. Dukic is saying:
4 "I just talked with Cengic, and Biljana talked with
5 Alija Izetbegovic."
6 In this context, would you agree with me that Cengic must mean
7 Hasan Cengic from the SDA? I think it's on your page 1 near the bottom.
8 A. I assume it's Hasan Cengic because he was in the power then.
9 Q. And Biljana in this context would mean, I assume, Mrs. Plavsic?
10 A. Obviously.
11 Q. And would you agree with me that the general -- the rest of the
12 general discussion is Mr. Stanisic and Mr. Dukic congratulating
13 themselves on the success of the barricades?
14 A. That is not my understanding. Not congratulating. What I can
15 see is that that's a conversation Stanisic is having, a professional
16 conversation with Dukic in order to analyse the whole situation and avoid
17 possible future omissions related to barricades. And I think that Dukic
18 said that a big thing had been achieved. I wouldn't understand that as a
19 congratulation; I would, rather, say what I just explained.
20 Q. Okay. Well, English page 3 and your B/C/S page 2, Mr. Stanisic
21 says that he had visited all the check-points, Mr. Dukic said "yes," and
22 then Mr. Stanisic said "Sarajevo is ours." Isn't that some sort of
23 congratulations or report of an achievement?
24 He goes on to say "a hundred per cent." And Mr. Dukic says
25 "we've done a big thing." You don't agree with my interpretation?
1 A. Well, that's simply a declaration of facts. They said that a big
2 thing had been done, and that's a fact. You can interpret that as a
3 congratulation, as a success, but that was simply a fact at that
4 particular point in time.
5 Q. Okay. Thank you. One more -- or, I'm sorry, two more, and then
6 we'll move on to another topic.
7 MR. HANNIS: If you could show the witness P1112. This is tab 9
8 of the Prosecution list.
9 Q. Mr. Andan, I have another hard copy for you of this one.
10 Again, it's a conversation on the 2nd of March. And the
11 participants in this one are Mico Stanisic and Miroslav Toholj.
12 A. Can I read first and then comment on it?
13 Q. Yes, please. Before you do, can I ask you, Do you know who
14 Mr. Toholj was and what his job was at that time?
15 A. I'm not sure, but I think he was member of the government,
16 probably minister for religious communities, I think, in the
17 Government of Republika Srpska.
18 Q. Did he have any involvement with information or media?
19 A. Yes, yes, yes, religious communities and information, you're
21 Q. Thank you. Go ahead and have a quick read of that before I ask
22 you any more questions.
23 Thank you. Would you agree that Mr. Toholj seems to be calling
24 Mr. Stanisic to get some information about what's happening because he's
25 wanting to be able to tell about that, to report that to the people? You
1 see in your bottom of your page 1 - English, middle of page 2 - he says:
2 "Well, tell me the general idea so I can tell the people ..."
3 A. Yes.
4 Q. Okay. Going on --
5 A. Yes, I saw that part. And I see that Mr. Stanisic tells him to
6 go to Rajko Dukic, who is the chief of the Crisis Staff, in order to
7 obtain answers. Stanisic is either avoiding to give him the answers or
8 maybe he didn't know the answers.
9 Q. Yeah, if you could go to the top of your page 2 - again, English,
10 middle of page 2 - Mr. Toholj said:
11 "What are our standpoints?"
12 And Mico Stanisic says -- according to my English translation, he
14 "Well, they should be advised to address the Crisis Staff here
15 and Rajko."
16 Now, to me that sounds like Mico Stanisic is at this point in
17 time at the Crisis Staff. Would you agree with that?
18 A. Well, I couldn't agree entirely with you. Maybe the Crisis Staff
19 was located close to the location where Mr. Stanisic was. They say "the
20 Crisis Staff here"; maybe the premises were close or maybe in the same
21 town. I have no idea where they were.
22 And Rajko's name is mentioned explicitly here. From this I
23 cannot conclude that Mr. Stanisic is a member of the Crisis Staff.
24 Q. I wasn't suggesting that. I was just suggesting that his
25 physical presence at that moment was at the Crisis Staff.
1 MR. ZECEVIC: Your Honours, I have to object. First all, the
2 witness was not a party to any of these conversations. Mr. Hannis is
3 reading the intercepts to him and asking him to draw the conclusions
4 which I think amounts to speculations simply, nothing else than that,
5 because the documents talk for themselves. And perhaps, perhaps the
6 Office of the Prosecutor -- in my opinion, the Office of the Prosecutor
7 should have brought the witnesses who were party to the conversation to
8 explain what they meant and what was the gist of the conversation, and
9 not to ask the witness to speculate what the other parties - who were not
10 talking to him, he wasn't present - wanted to say and were thinking about
11 while they were talking. Thank you.
12 JUDGE HALL: Mr. Hannis, I had -- I was going to intervene
13 earlier in terms of these transcripts, and the -- because I wondered for
14 a moment why it was that whatever your interpretation, whatever
15 inferences you were drawing from the transcript, whereas that's one
16 thing, and you were inviting the witness to accept, or not, your own
17 views as to what it meant. This is similar to the intervention
18 Mr. Zecevic has just made.
19 But I refrained from doing that because I thought that perhaps
20 you were trying to elicit from the witness a sense of what the
21 transcripts meant with a view to asking another question. But if, in
22 fact, that is not your ultimate intention, in other words, if this is not
23 an intermediary stage or preliminary stage to something else you're about
24 to ask, it seems that Mr. Zecevic has a point. Why pursue the angle of
25 what this witness, who happens to be on the stand, makes of these
1 transcripts? He wasn't a party to it. He has a -- if it's left at that,
2 it's a matter of inference and argument.
3 MR. HANNIS: I think I understand what you're saying,
4 Your Honour. I am asking these questions regarding the intercepts and
5 the two documents prior to that, the reports about the events, to lead up
6 to ask a question related to an answer that the witness gave on direct
7 examination at page 21385 when he was asked if he had any information or
8 any intelligence. He said "at the time" -- this is Mr. Zecevic:
9 "At the time did you and [sic] the police administration have any
10 intelligence that Mico Stanisic had any role whatsoever in the barricades
11 on the 2nd of March, 1992, in Sarajevo?"
12 "I did not have any such information."
13 Now, I'm trying to show him that there was information that the
14 security service had and relate this to some other aspects of this
15 witness's situation in the MUP at that time and subsequently.
16 JUDGE HALL: As I said, as I thought you might have been aiming
17 at, but it would be -- if you could bring it together more rapidly,
18 Mr. Hannis.
19 MR. ZECEVIC: Your Honours, I believe the proper question should
20 have been that Mr. Hannis establishes that, in fact, the security
21 services had that information. We don't know when these intercepts were
22 made. We don't know. We just believe that they were made on the
23 2nd of March. That is why -- that's the point, you see, Your Honours.
24 THE WITNESS: [Interpretation] May I also intervene?
25 MR. HANNIS: That's up to the Judges.
1 THE WITNESS: [Interpretation] Simply professional intervention.
2 The transcripts of these conversations here, I assume, or,
3 rather, I'm sure that those transcripts originate from the state security
4 service. We in the public security service did not receive any
5 information whatsoever from the state security. This situation related
6 to the barricades. It is possible that my superiors had this
7 information, but this information did not go anywhere below.
8 So if you take the information drafted by the state security
9 service and if you take a look at the addressees, you will see that not
10 even the undersecretary of the public security or the chief of the police
11 administration will be found on the list of addressees. Maybe if
12 somebody sent it down, maybe. But normally we never had that
13 information. Normally in our service every single person who reads a
14 particular information is duty-bound to sign or initial the information
15 signifying that he had read it. We don't have anything like that here.
16 So we don't know whether these transcripts were sent to the minister or
17 other government structures in Bosnia-Herzegovina.
18 I apologise for this intervention. I hope that it was not in
20 JUDGE HALL: Thank you, Mr. Andan.
21 Yes, Mr. Hannis.
22 JUDGE HARHOFF: Hold on a minute.
23 Mr. Andan, could you please remove your headphones. Thank you.
24 Now, I'm really brought to the point of confusion by this series
25 of interventions. I thought, and please correct me if I'm wrong, but the
1 picture that I had was that in the document P643, which was the
2 13th March report, that report seemed to include the information at the
3 end that the following members of the Crisis Staff had taken part in the
4 erection of the barricades, and among these members was Mico Stanisic.
5 The subsequent documents that we saw were the transcripts of the
6 intercepts, and there, as far as I could pick it up, but I'm not sure
7 about it because they went very fast, in one conversation Mico Stanisic
8 seemed to -- seemed to accept that the barricades had been established
9 and had no intention of taking them down. In another intercept, the one
10 with Karadzic, I thought that Stanisic said the opposite; namely, that he
11 agreed with Karadzic that these barricades should be removed immediately.
12 So this is where the confusion comes in. And in any case, the
13 witness declared right from the beginning that he had no information
14 about Stanisic's involvement. So I don't know where we're going with all
15 of this, but I would like some clarification, if that is possible, from
16 the witness.
17 MR. HANNIS: If I may, Your Honour, the first thing you said, at
18 page 43, line 10, referring to Exhibit P643, you said the "report seemed
19 to include the information at the end that the following members of the
20 Crisis Staff had taken part in the erection of the barricades, and among
21 these members was Mico Stanisic." And that's not my understanding.
22 643 is a report -- page 2 of the English says the subject is the
23 list of MUP employees who took part in the activities related to the
24 setting of barricades in the region of Sarajevo in early March 1992. And
25 then on the last page, where Mico Stanisic is listed, it says "in
1 Crisis Staff of SDS, among others, the following persons were engaged,"
2 which I take it to mean that Mico Stanisic, an employee of the MUP, was
3 engaged in activities regarding the barricades in the Crisis Staff of the
4 SDS, wherever that was located at the time.
5 And I gather that his involvement is described as contacts and
6 instructions to the people in the field. I think if you read the
7 intercepts, when you have more time to read the whole thing, I think
8 you'll see there's discussion between Mr. Stanisic and Mr. Karadzic about
9 talking down the barricades, starting, perhaps, a midnight, because they
10 have gotten some of the concessions that they wanted, and Mr. Ganic
11 resigning, et cetera, et cetera. And in the discussion with Mr. Dukic,
12 he's also discussing taking down the barricades, and they're talking
13 about the need to do that carefully so that their men don't get shot at
14 by the other ethnic parties who have set up their own barricades,
15 et cetera, so it needs to be co-ordinated and done carefully. That's
16 what I read from it, Your Honour, and I don't know if that's answering
17 your question.
18 But all of this was initially brought up to address the
19 suggestion raised by the question on direct exam that Mico Stanisic had
20 nothing to do with the barricades. Now, this witness, I think it's
21 clear, didn't know that about that, didn't have that information,
22 because, as he said, this is a report from state security; he was on the
23 public security side, so he wouldn't have seen it. But I want to
24 establish that there is ample evidence that Mr. Stanisic indeed was
25 involved. And part of what I'm trying to show is that this witness was
1 out of the loop for certain things, which is an important argument to
2 make about the totality of his evidence later on.
3 JUDGE HARHOFF: Could I hear your opinion, Mr. Zecevic.
4 MR. ZECEVIC: Well, we simply -- Your Honours, we simply do not
5 accept the theory which Mr. Hannis just explained.
6 First of all, Your Honours, the question which I posed to the
7 witness was, Had he had the information in the MUP with the operatives,
8 the chief operatives of the public security, did they have the
9 information about any involvement of Mico Stanisic in the barricades. He
10 said that they had information that behind the barricades are Rajko Dukic
11 and Momo Mandic, and that is the all information that they had at that
12 point. And he explained that Momo Mandic was not even hiding that. He
13 came to his office and he took Kemal Sabovic with him and went to through
14 barricades, and then Kemal Sabovic had problems with the Muslim
15 leadership of the MUP because he went with Momo Mandic through the
16 barricades. So what I tried to establish is the public -- the knowledge
17 of this witness.
18 Now Mr. Hannis is trying to speculate, basically, because the
19 witness doesn't have any information. He says, I didn't have the
20 information as a public security. Now he's showing him some alleged
21 information, which I will at the end explain why I say alleged
22 information, from the state security that Mico Stanisic had any
23 involvement in that. And I -- that is why -- that was the gist of my
24 objection. Because this witness cannot help in any case. And it wasn't
25 the direct -- the question which I posed on direct, so it doesn't come
1 from the direct examination of the witness.
2 JUDGE HARHOFF: I think this is as far as we can take it, unless
3 you have some --
4 MR. HANNIS: May I make a reply?
5 JUDGE HARHOFF: Very briefly.
6 MR. HANNIS: Two points I need to address. One was the
7 suggestion before that I, rather than asking this witness to comment, I
8 needed to call witnesses who know about the conversation or participated
9 in the conversation. One witness I can't call.
10 The other point is: Mr. Zecevic needs to go to the transcript to
11 see what question he asked and see why I'm trying to follow up.
12 Transcript page 21385, line 12:
13 "Q. Mr. Andan, at that time did you and [sic] the police
14 administration have any intelligence that Mico Stanisic had any role
15 whatsoever in the barricades on the 2nd of March ... in Sarajevo?"
16 To me, in English, "did you" could mean "you personally" or "you
17 guys" in police administration. And police administration could mean
18 just generally police administration, or it could mean a specific
19 department. But the way it's phrased, it's not clear. And then, when he
20 said "I did not have any ... information," the next question from
21 Mr. Zecevic is:
22 "Have you heard from any of your colleagues subsequently that any
23 of them had any such information?"
24 Colleagues in that context could be anybody else in the police,
25 state security, public security, et cetera.
1 That's why I felt I was entitled to go into what I've been going
3 JUDGE HARHOFF: Thank you. It's time for the break, so let's --
4 JUDGE HALL: Yes.
5 JUDGE HARHOFF: -- resume in 20 minutes.
6 JUDGE HALL: So we would resume in 20 minutes.
7 [The witness stands down]
8 --- Recess taken at 12.05 p.m.
9 --- On resuming at 12.26 p.m.
10 [The witness takes the stand]
11 JUDGE HALL: Yes, Mr. Hannis.
12 MR. HANNIS: Thank you.
13 Q. Mr. Andan, I have one more to show you, one more intercept to
14 show you on this topic, but before I do, let me ask you a couple of
15 general questions.
16 Are you familiar with the principle "the need to know" in terms
17 of security work? Do you know what I mean when I use that term?
18 A. No.
19 Q. In my brief job in my army doing some kind of security work, we
20 were instructed to follow the principle of "the need to know," meaning
21 that I was not to share information that I received in trying to collect
22 information, or review intercepted conversations, et cetera. I was not
23 to share that with someone unless they had a need to know; the principle
24 being you don't want to give out sensitive security information to just
25 anybody. Now, maybe you're familiar with that idea under a different
1 name, but I assume that's how you worked in the state security service
2 during your time there. Would you agree?
3 A. Yes, I agree. Once intelligence is received, it must be
4 forwarded to the superior officer in writing and cannot be discussed, not
5 even with colleagues.
6 Q. Okay. And one of the reasons or the logic behind that is you
7 want to be able to be certain about controlling that information so that
8 it doesn't get to inappropriate places; correct?
9 A. Yes, that is correct, and it musn't be commented publicly.
10 Q. So in the context of these -- the state security report about the
11 incidents surrounding the barricades in early March, it's not unusual
12 that you wouldn't be aware of these intercepted conversations or that
13 report we saw in Exhibit P643 because you were on the public security
14 side and didn't have a reason or a need to know about that; right?
15 A. Yes, but sometimes the state security service did release some
16 information downward and we would get acquainted with it. I've already
17 explained as much. And each one of us had to sign to confirm that we
18 were privy to that information. We were duty-bound not to spread that
20 Q. I understand. But in this case you never received any
21 information about this state security report or these intercepted
22 conversations concerning the barricades events; right?
23 A. That is right. We received no intelligence about that event from
24 the state security service, or, indeed, these intercepted conversations.
25 Q. Thank you. With that, I want to show you one last one related to
1 this, however.
2 MR. HANNIS: It's P981. If the usher could hand you a hard copy.
3 Q. And again, sir, this is --
4 JUDGE DELVOIE: Tab number, please?
5 MR. HANNIS: Oh, I'm sorry, Judge Delvoie, it's tab 5.
6 JUDGE DELVOIE: Thank you.
7 MR. HANNIS: And I see Mr. Aleksic on his feet.
8 MR. ALEKSIC: [Interpretation] Your Honours, I apologise to my
9 learned friend for complaining before he even asked his question, but I
10 must follow up on the objections put forward by Mr. Zecevic.
11 The previous intercepted conversations had to do with document
12 P643, which referred to the report about barricades in the territory of
13 Sarajevo. The document Mr. Hannis is now about to show and ask questions
14 about is unrelated to Sarajevo and the events surrounding the barricades.
15 The witness did not take part in the conversations, and in his previous
16 answers he said that he had no information about the barricades in
17 Sarajevo. Therefore, in my submission, this document has nothing to do
18 with the witness. Mr. Hannis can read it to him and the witness could
19 possibly only state his opinion, but I do not believe that is
20 appropriate. Thank you.
21 JUDGE HALL: We may agree with you, Mr. Aleksic, but perhaps we
22 should hear the question first and then take it from there.
23 MR. HANNIS: And I did want to indicate to Your Honours, I agree
24 it's not particularly about Sarajevo. But Exhibit P911, which is the
25 first information report I showed the witness, the one dated the
1 6th of March, 1992, which is sent to the BiH president, the Assembly
2 chairman, the prime minister, et cetera, is a more broad report not
3 focussing specifically on employees of the MUP but about everyone
4 involved. And part of the reason I'm offering this is because it offers
5 some corroboration of that report to the extent that that report talks
6 about barricades being set up or planned in areas outside Sarajevo
8 And with that I'll ask the question and we'll see how far I get.
9 Q. Mr. Andan, have you had a chance to read that intercept?
10 A. No, I haven't.
11 Q. Okay. You want to take a second to read those two pages to
12 yourself, and then I'll ask you a question.
13 A. Yes.
14 MR. ZECEVIC: Your Honours, while the witness is reading the
15 document, I would appreciate if Mr. Hannis would be so kind to give us
16 the reference in the Exhibit P911 where in that document does it talk
17 about Banja Luka or Mr. Stojan Zupljanin. Can we have the reference?
18 MR. HANNIS: I didn't say Banja Luka. I said outside of
19 Sarajevo. I would refer you to page 2 of the English, it's footnote 3,
20 which says:
21 "A large number of barricades were set up on the territory of
22 Ilijas, Olovo, Soko, Breza, Pale, Trnovo, Vares, and Rogatica."
23 MR. ZECEVIC: Well, that is precisely why I'm asking you,
24 Mr. Hannis, because it precisely deals with the municipalities around
25 Sarajevo and doesn't deal with any municipalities outside that territory
1 of Sarajevo.
2 All those municipalities that are listed are the municipalities
3 in the immediate vicinity of the Sarajevo. So, therefore, I just made
4 this observation because I don't see that this document relates in any
5 way with the intercept that you are showing to the witness.
6 MR. HANNIS: The introductory paragraph says that "the service
7 learned that the extremists were planning to block the city from both
8 outside and inside." And I think this intercept shows that there were
9 preparations to stand by for a further, wider blockade, if it was decided
10 to be necessary. That's why I'm offering it or trying to show it at this
12 Q. Mr. Andan, my question relates to something said at the bottom of
13 page 2 in the B/C/S, and Mr. Stanisic -- I'm sorry.
14 Mr. Zupljanin says: "All right. For the most part everything is
15 ready on our side."
16 Mr. Stanisic says: "Yes."
17 Mr. Zupljanin says: "We are waiting for the sign. If a total
18 blockade is needed or the rest, it will be done."
19 Mr. Stanisic: "Agreed."
20 Were you aware or did you hear that there had been preparations
21 for possible extension of the blockade beyond the immediate area of
23 A. Mr. Prosecutor, with all due respect, I must say it's difficult
24 for me to comment on documents in which I play no role. I am a man who
25 does not like to give partial answers.
1 At any rate, I can say that I was in Sarajevo at the time and
2 doing my work and I did have some information concerning the city of
3 Sarajevo, because during that time-period, since March 1992 or ever since
4 new year, we weren't even tasked to do audits elsewhere in
5 Bosnia-Herzegovina. It was difficult for me to give a comment on
6 something in which I did not take part or possibly only was mentioned by
8 So if you had a particular or specific question, that would be
9 good then -- because then I could provide a clear answer.
10 Q. I understand that and I appreciate that. I take it, then, that
11 your answer to my question was that you don't have any information about
12 that, you didn't hear anything about it at the time or from anyone since
13 then about whether or not there were plans for the possibility of
14 extending blockades beyond the immediate area of Sarajevo?
15 A. I will try to explain. You may not believe me, but that's up to
17 I received more information by watching the news at 7.30 than I
18 would get when I came to work in the morning. We were basically isolated
19 from all the events. We wondered why we were coming to work and what we
20 were getting paid for.
21 Let me tell you one thing: I was brought up by my parents in such
22 a way that they instilled a sense of discipline in me, but I -- in spite
23 of that, I quit going to work at my regular time in the morning, I would
24 get up at 10.00 and then leisurely stroll to work, and nobody, no
25 superior officer of mine, ever bothered to ask me why.
1 I and a few colleagues, at least, had the sense that we were
2 something like outcasts. I don't know whether other colleagues who had
3 party ties were in a different position.
4 Q. Thank you. That takes me to the next thing I wanted to ask you
5 about. At page 21395, you were asked by Mr. Zecevic about whether you
6 had continued working in early April after the MUP was divided. And you
7 gave part of what you've just said now.
8 I want to show you Exhibit P353.
9 MR. HANNIS: This is at tab 16 of the Prosecution list.
10 Q. I think you may have seen this before.
11 A. [No interpretation]
12 Q. This is the memo sent by Mr. Mandic about separating.
13 Do you recall when that memo came out? It's date the
14 31st of March; were you aware of it that day or the next day?
15 A. There must be a mistake in the interpretation. This document
16 wasn't sent by Mr. Memic but by Mr. Mandic. In my earphones the name I
17 heard was "Memic."
18 Whether I was acquainted with the contents of this document on
19 the same day or on the following day, well, I said to you at the outset
20 that I'm not so good when it comes to dates. But I remember this
21 dispatch very well.
22 I was one of those who were against doing things this way. And I
23 can say to this Trial Chamber that I took this dispatch to Sarajevo TV
24 and gave it to news moderator Puljic [phoen], who told me, yes, I know,
25 I've received a copy from the ministry already, thank you.
1 Q. And can I ask you, Why did you take it to the television guy?
2 A. That was a sort of resistance of mine against this division. I
3 wanted the wider public to learn about these things. I was unwilling to
4 accept the division of the MUP at the time.
5 Q. And my main reason for showing you that document was to help you
6 out with dates, because I know you've told us you have a hard time with
7 dates. If that dispatch came out on the 31st of March, can you -- can
8 you use that date to help you remember when, for example, Bruno Stojic
9 and the Croats left the MUP? Was it before or after that dispatch came
10 out? Do you recall?
11 A. I don't remember, but I can say what I -- what occurred to me
12 just now, what -- it came back to me how I got this dispatch in the first
14 At the traffic police station there was a working meeting at
15 which Slavko Draskovic informed all staff present what the contents of
16 this dispatch. My wife worked there at the time. There was an
17 accounting department where she had a job. And she called me on the
18 phone to tell me about the dispatch. It was then that I asked for the
19 dispatch for my superiors at the MUP. I wanted to read it. I xerox
20 copied it and took it to the television.
21 I would gladly answer a question whether Mr. Stojic left before
22 or after, but I really don't remember. I don't want to say anything
23 wrong, so I can't give you a precise answer. I do know that he left, and
24 I've already described that.
25 Q. You just mentioned Slavko Draskovic there. Could you remind us
1 who he was and what position he held at the time?
2 A. I know him as a telex operator and encoder. Cedo Kljajic had
3 graduated from law school, and up until the multi-party elections he had
4 some sort of job, I don't know what exactly, and then he was appointed
5 co-ordinator at the police administration. Or possibly he was even chief
6 of department, which job he did for a while, and later on he moved on to
7 the city secretariat of the interior. I don't know what exactly he did
8 there. Once the war broke out in Bosnia-Herzegovina, he went to Trebinje
9 where he became chief of national security and stayed in that position
10 till the end of the war. That's the person I have in mind. Maybe you
11 know another man by the name of Slavko Draskovic, but that's the one I'm
12 talking about.
13 Q. My memory may be letting me down. I thought there was a
14 Slavko Draskovic who did eventually go to Trebinje, as you said, but
15 earlier in 1992 I understood he had some position, I think, as an
16 assistant minister in the RS MUP and then for a short time was moved to
17 the position of advisor to the minister; do you know of such a person, or
18 am I getting my names mixed up?
19 A. Well, I was thinking of the period of the socialist federal --
20 the Socialist Republic of Yugoslavia, and I know that he was not in any
21 higher position. I don't know at the time that he was assistant minister
22 or advisor. I don't know anything about that. But I know for a fact
23 that when I had a problem in Trebinje, he was already at that time the
24 chief for national security.
25 Q. All right. Thank you.
1 Now, on the -- after Mandic's dispatch on the 31st of March, did
2 you notice whether he or any of the other ethnic Serbs continued to come
3 to work at your building in Sarajevo? Or were you the only one still
4 coming in?
5 A. Well, that was what was confusing for all of us at the
6 ministry [Realtime transcript read in error "military police military"]
7 because Mandic continued coming to the ministry not regularly. Now,
8 Vitomir Zepinic, who was the deputy minister, he came to work regularly.
9 And there were several other employees of Serb ethnicity in my
10 administration, Vojo Gavrilovic and two other colleagues, who came to
11 work as I did.
12 To be honest, you know, I went there 10.00, was there till about
13 12.00, and then I went back home. So it was totally chaotic. We didn't
14 really have any direction, as it were. There wasn't even a regular
15 command, to put it that way. So there were colleagues who kept on coming
16 to work, but there were others that I didn't see anymore.
17 MR. ZECEVIC: I'm sorry, the page 55/15. It says "military
18 police military." And it says "police ministry," I believe that was what
19 the witness said.
20 MR. HANNIS:
21 Q. Did you hear that, Mr. Andan? That makes sense. The transcript
22 says you said it was "confusing for all of us in the 'military police
23 military,'" and we're assuming you said "police ministry."
24 A. Yes, the police ministry.
25 Q. So I take it from your previous answer that some of your Serb
1 colleagues had left after Mr. Mandic's memo or dispatch. Did any of
2 those colleagues who had left get in touch with you and try to encourage
3 you to leave and join them in their newly-created ministry?
4 A. Yes, there were such attempts. There were some phone calls. One
5 of them was rather unpleasant; it came in the middle of the night when
6 they were checking my ethnicity, what my Slava was, and my background.
7 And in the end they said something to the effect, You're a traitor of
8 your own people, and so on.
9 But there were also honourable discussions and conversations
10 where people were telling me that perhaps I wasn't aware of the whole
11 picture, that as a Serb employee and as a Serb, a Serb person, I should
12 rethink the whole thing and join the ministry that was established
13 pursuant to the will of the Serb people there and that I should join the
14 police and so on. So there were various attempts. But there was also
15 this one that was rather provocative.
16 Q. Was this from an anonymous caller or from someone you knew?
17 A. Well, later on I learned who was behind this phone call. It was
18 Mr. Dutina. Before the war, this man was a journalist, I believe, in
19 "Oslobodjenje Daily" or perhaps on Sarajevo TV. I just know he was a
20 media person. And whether at that time he was with the Government of
21 Republika Srpska or not, I'm not sure, but I did learn eventually that
22 this night-time call came from him.
23 Q. And the others who were trying to encourage you to join, can you
24 recall by name who any of those were?
25 A. Yes, I can. Two friends of mine actually. The first was
1 Vlastimir --
2 THE INTERPRETER: The interpreter did not hear the last name.
3 THE WITNESS: [Interpretation] -- aka Vlasto, and the conversation
4 he had with me was almost of military type. The other one was Slobodan
5 Skipina, who was a very moderate man and very thoughtful, and he just
6 sort of tried to tell me that I should try and see the whole picture,
7 perhaps think it through, and then leave, together with my family, leave
8 Sarajevo and join the forces of the Serbian people.
9 MR. HANNIS:
10 Q. Is the interpreter says they didn't catch the last name of
11 Vlastimir. Could you tell us that person's last name.
12 A. Vlastimir Kusmuk, aka Vlasto.
13 Q. Thank you. And Mr. Kusmuk was in the early days of the RS MUP, I
14 think, the assistant minister heading up police administration; is that
16 A. I believe you're right.
17 Q. And then, I think, in August he was moved to be an advisor to the
18 minister; did you know about that?
19 A. That was at the time when I had this black hole, you know, that
20 was the time when I left the ministry, and at the time I didn't want to
21 have anything to do with the Ministry of the Interior, so I can't really
22 tell you with certainty that I was aware of it.
23 Q. Okay. Thanks.
24 You told us last Thursday at page 21396 that there came a point
25 in time where you were not allowed into the MUP building in Sarajevo
1 where you'd been working. Do you remember approximately how long after
2 Mandic's dispatch was it that this happened? Was it a couple of days,
3 was it a week, was it two weeks?
4 A. All I know is that the war had broken out and it was getting more
5 and more difficult to leave Sarajevo, but certainly it was after the
6 dispatch sent by Mr. Mandic, not before.
7 Q. And I think you mentioned before that after you had taken your
8 family out, you had either, I can't remember, is it on the way out you
9 went through Trebinje or on the way coming back you went through Trebinje
10 and had some problems because they seized your rental car?
11 A. Well, Mr. Sabovic, Kemal, a friend, he suggested, and I followed
12 his suggestion, and I took my two sons and my sister-in-law -- or
13 daughter-in-law and his wife and their children, we rented a car from the
14 Hertz rental agency at the Holiday Inn, we -- I took them to Trebinje
15 where we spent the night at a football referee of the former Yugoslavia,
16 Enver Saric, he was a referee in the former Yugoslavia, and he found
17 accommodation for us in Herceg-Novi, in a studio apartment, I believe it
18 was his brother's or another relative's, and I took -- when I took my
19 children out, together with my mother-in-law, out of Sarajevo, that's
20 where I took them. If you need me to go into more detail, I'm prepared
21 to do so.
22 Q. No, that's enough. I want to ask you about that. When did you
23 leave Trebinje to go back to the Sarajevo area, approximately?
24 A. Well, this would have had to be the first half of April, possibly
25 around the 14th or 15th up to the 17th at the latest. I had a problem
1 down there because members of the police station in Trebinje stopped my
2 car. They asked for all the papers, the vehicle papers, everything. I
3 had a contract, a rental contract. They confiscated the vehicle. And
4 then a friend of mine let me use his own car, a Jetta Volkswagon, and I
5 went to Sarajevo. And first I went through Serb barricades, then I
6 entered Trnovo, then I went through Muslim barricades. And then on the
7 approaches to Sarajevo, I, again, had to go to Serb barricades, and
8 somehow I managed to get through. But this was sometime in mid-April,
9 and that's what I can recall.
10 Q. I think we have some documents in evidence about Trebinje and
11 maybe some phone conversations that relate to that that can help us date
12 it around mid-April.
13 But where did you go precisely when you returned to Sarajevo
14 then, after having taken your family to Trebinje?
15 A. I didn't take my family to Trebinje; I took them to Herceg-Novi.
16 And I went back to my own apartment. In other words, I went back to the
17 part of Sarajevo that was, let's put it that way, under the control of
18 the Muslim forces.
19 Q. And precisely what part of town was that?
20 A. Well, I don't know how well you know Sarajevo. That was in the
21 part some one and a half kilometre to the south of the centre towards
23 Q. And what police station boundary would that have been within?
24 A. That was the Novo Sarajevo Police Station where I was the
25 commander, komandir.
1 Q. Okay. And how long did you stay there and what were you doing?
2 It must have been a difficult situation being a Serb and being in that
3 area at that time.
4 A. Yes, it was a very difficult period. And not to repeat myself,
5 but as I've already said, I spent most of my time in the apartment. And
6 when I did go out, I would go out with a friend that I mentioned earlier,
7 Kemal Sabovic. There was a cafe nearby and also Monik [phoen] Hotel, the
8 owner of which was Alija Delimustafic, the then minister. So on two or
9 three occasions I tried to get to the building. I've described that one
11 Then on the second time, as I was passing by Hotel Zagreb, I was
12 intercepted by a criminal from Bascarsija who wore some kind of uniform
13 and had a weapon. It wasn't a very hostile meeting, but he did suggest
14 that I leave Sarajevo, and he told me that if I could not manage to do
15 that, that he would help me get out of the city. And he said, You know,
16 there are many people in this town who would be glad to soak in your
18 And then I tried -- the third occasion was when I tried to return
19 the car to my friend Dragan Djurovic. The vehicle was taken be --
20 confiscated by Jusuf Razina [phoen] it was a new Peugeot vehicle parked
21 outside the police club in Sarajevo. So this was a very unpleasant
22 situation because none of these people - there were a couple of people
23 there that I knew - none of them were willing to talk to me at all.
24 Q. I understand from your earlier testimony that there came a point
25 in time, then, when you left that part of town and you went to Ilidza.
1 Pardon my pronunciation. When was that approximately? How many days had
2 you been back before you went to Ilidza?
3 A. As I've said, I really can't recall the date exactly or when it
4 was that I went to Ilidza. But I recall there was a convoy of children
5 that was -- that headed from Sarajevo to -- toward the coast or somewhere
6 inland, and it was stopped. I recall that very well because I was
7 stopped and a member of Arkan's unit asked me for my papers. I remember
8 that I had to get out of the car. But I can't recall the exact date, but
9 it must have been around May already.
10 Q. When -- I'm sorry, why did you decide to go to Ilidza? What was
11 your reason for going there, what was your plan?
12 A. Well, I've already mentioned that perhaps a day before I left
13 there was a very unpleasant search that was carried out by a paramilitary
14 unit headed by a certain Rus [phoen]. This was a very unpleasant search.
15 It was brutal, even vulgar. And that night, I believe, I received a
16 phone call from an honourable man, and I think I've mentioned that his
17 name was Dr. Nakes [phoen], and he told me that the best option for me,
18 because he had learned some information from someone, would be to leave
19 Sarajevo as soon as I could.
20 Q. I certainly understand your reasons for leaving. My question is
21 more to: Why was Ilidza the place you decided to go? Why there instead
22 of Trebinje or Herceg-Novi or somewhere else? Why Ilidza?
23 A. Well, because most of my friends were in Ilidza. That's where I
24 had grown up. My sister also lived there, she had an apartment there, so
25 I decided to go to Ilidza.
1 Q. And you told us that when you got there you had some contact with
2 Mr. Tomo Kovac. Did you know him before this?
3 A. Yes. I went to the police station at Ilidza. I'm not certain
4 anymore whether in a conversation with Kusmuk or Skipina, but one of them
5 probably mentioned a name who it was that I should go and see if I were
6 to leave Sarajevo, so I did. I went to Ilidza and I reported to
7 Mr. Kovac, who was at the station, and I knew that man. I had known him
8 from before.
9 Q. And what was your nature of knowing him from before? How long
10 had you known him and what was the nature of your acquaintance?
11 A. I think that a little later, perhaps in 1978, he too started
12 working with the state security service. And there was a special
13 department there that only did background checks for individuals, and he
14 was employed, he worked there, in that department. I don't know how long
15 he stayed there. We were never very close, but we were colleagues. We
16 were co-workers. What I'm trying to say is we never socialised
17 privately. But I know that when I was appointed commander of the police
18 station in Novo Sarajevo, Jozo Leotar was the commander of the
19 Novi Grad Police Station, and I believe that at this time Mr. Kovac was
20 his deputy in Novi Grad. I can't recall whether that was before or after
21 the Olympic Games, but what I do know for a fact is that he was the
22 deputy to Mr. Jozo Leotar.
23 Q. Now, on Thursday, at page 21399, you told us while there in
24 Ilidza that Mr. Kovac made you an offer that you stay there and work as
25 his deputy but that you refused "because before the war, during the war,
1 and after the war, I did not agree with some of his ideas and thoughts."
2 My question, Mr. Andan, is, What ideas and thoughts of Tomo Kovac
3 did you not agree with that caused you to decline his offer?
4 A. Well, there are many causes there, and I'll try to be brief and
5 tell you what my main reason was and why it was that I declined his offer
6 to be his deputy at Ilidza.
7 First of all, based on my background and my career, I was always
8 his superior. And to be honest with you, I felt it was humiliating to be
9 his subordinate now, especially so because he said that I would be his
10 deputy and on those days they were preparing an operation on Stup. And
11 the Stup was the place where my parents were living at the time, and I
12 told him, You know, I don't think that's right, I don't think -- my
13 parents are living there, and I don't think it would be fair because if
14 anything should go wrong, if anything should happen, I would be left
15 without my parents.
16 Now, the main bone of contention, as it were, with him was an
17 investigation that was conducted while he was the deputy commander in
18 Novi Grad, where in Ilijas he bought from Mr. Ibro Muslic. There was a
19 company there that dealt in rented vehicles, the sales of rented
20 vehicles, and I know that there was something untoward happening there.
21 He was involved in some kind of under-the-table deal. And I went there,
22 I tried to help him. And I asked Mr. Ibro Muslic to return the vehicle
23 so that we don't have to -- so that we don't have to initiate
24 disciplinary proceedings. And when I came back, I told him that
25 Mr. Muslic had agreed to return this vehicle. It was a Kadett Opel
1 vehicle. But at first he was very indignant. He said, you know, Who
2 gave you the right to do this? And so on. But later on he was --
3 actually, some friends of his actually agreed with my position. They
4 told him, you know, he was right in doing this. This was the right
5 course of action.
6 And because of these dealings of his and that kind of conduct, I
7 did not even want to be in the same building where he was. And as I've
8 already said, there were Kijac and Mandic and all these other men that I
9 mentioned earlier, they were in his office when I got there, so that's
10 the reason why I didn't even want to go there and see him.
11 Now, later on, as Mr. Kovac was a very vengeful man and a
12 careerist, he thought that I would be a threat to his further promotion
13 in service, and he tried, even after the war, to sort of eliminate me by
14 even filing some false complaints charging me with things that I had even
15 ordered his execution and so on.
16 So in brief, this is the person that Mr. Kovac was. And I really
17 don't even want to talk about him because I dislike even the thought or
18 the name when I hear it.
19 Q. Well, I'm sorry, I do want to ask you one more question about
20 him, then, though. Didn't he, after the war, at some point in time, go
21 so far as to make a written complaint about you and allege that you and
22 Mico Davidovic had tried to kill him?
23 A. Yes, yes, he filed a complaint to the lower prosecutor's office
24 in Bijeljina that allegedly I had ordered his execution through the Zemun
25 clan, a clan, a criminal clan, and of course I just decline to even talk
1 about that, refuse to even discuss this.
2 Q. And I take it that there's no truth to that, that you and
3 Mico Davidovic did anything like that?
4 MR. ZECEVIC: I'm sorry, Mr. Hannis, the part of the answer of
5 the witness was not recorded, and I believe it will be helpful for your
6 next question. Because he explained what was done with that complaint,
7 that it went to court, and so on and so forth. So maybe he can repeat
8 his answer.
9 MR. HANNIS: Thank you, Mr. Zecevic.
10 Q. Mr. Andan, you heard what was said just then. Can you elaborate
11 for us a little; there actually was a complaint filed in criminal court
12 and what happened with those proceedings?
13 A. Well, what happened before the criminal complaint, based on what
14 I learned, I can tell you about that, too.
15 At the time, I was the director of police of Republika Srpska,
16 and at the time we were beginning to deal with the crimes that had been
17 committed during the war. In other words, we began dealing with war
18 profiteers. And Mr. Kovac was frightened that he might become the focus
19 of the police investigation, so he tried to pre-empt our investigation by
20 submitting a criminal complaint to the lower prosecutor's office in
21 Bijeljina in which he charged me with attempting, with the assistance of
22 some criminals from the Zemun clan, of trying to organise his execution.
23 And I tried -- I was actually questioned and interviewed at the lower
24 prosecutor's office in Bijeljina, and after a while I learned that the
25 criminal complaint that Mr. Tomislav Kovac had filed against me was
2 JUDGE HARHOFF: Mr. Hannis.
3 MR. HANNIS: Yes, sir.
4 JUDGE HARHOFF: We do understand that there were attempts made to
5 have investigations made into the commission of war crimes, but I think
6 you should sharpen your focus and speed up.
7 MR. HANNIS: Thank you, Your Honour. I am going to move on to
8 another one now.
9 Q. You -- at page 21399, line 24, on Thursday you told us that after
10 declining the offer in Ilidza, that you went to Vraca. How did you come
11 to go there? Did somebody send you there? Or did somebody request you
12 to go there?
13 A. After the initial interview with Mr. Kovac in the police station
14 in Ilidza, after my offer was refused, he asked me where I was
15 accommodated. I told him that I was staying with my sister at Ilidza.
16 He told me to come again in several days. He said that he would contact
17 the ministry, which was at Pale at the time, and they would probably
18 decide where to send me.
19 Q. So then what happened? How did you get to Vraca?
20 A. I kept reporting to Mr. Kovac. I spent seven or maybe even ten
21 days in Ilidza. One day when I arrived there, he told me that his
22 vehicle or a MUP vehicle from Ilidza was going to go to Vraca and that
23 they were going to transfer me to the police school in Vraca. After
24 that, I was supposed to receive instructions about what to do next. And
25 that's what happened. We went to the airport. The airport was closed at
1 the time. And that's when I finally ended up in Vraca in the police
3 Q. And who did you report to when you got there and what were you
4 told to do?
5 A. I believe Milos Zuban was there. The way I understood it at the
6 time, he was chief of the police administration, maybe even chief of a
7 department. I know that I reported to him. He told me that I could
8 reside in a room where Mr. Mihajlo Bajic was. He told me that he would
9 inform the ministry at Pale that I was there and that they would see
10 where I was going to be assigned later. So I spent the period of time at
11 Vraca. I'm unable to tell you exactly how long. I simply went to
12 breakfast, lunch, and dinner every day, I spent the rest of the time in
13 the room, and I had no assignments whatsoever.
14 Q. You told us on Thursday right at the end of the day that you'd
15 had some problem with the Serbs even before arriving in Vraca, but I
16 guess also upon arriving there, because they had questions about why did
17 you stay so long in Sarajevo in the old MUP, why did you leave so late.
18 Some of them were concerned that you might be a spy for the Muslims. Is
19 that part of the reason that you weren't getting any assignment for a
20 while after you arrived in Vraca?
21 A. I was attacked, under quotation marks, by those who went first to
22 fight among the Serbs, by those who did not use their head to think with
23 it. I have to go back now and mention the thoughts of some people who
24 tried to figure out whether they needed me or not. I definitely was
25 needed to perform some police duties, while other people thought that I
1 would be promoted very soon and they would end up being my inferiors.
2 Yes, there were provocations. People kept asking whether I was there --
3 why I was there for such a long time; whether I was infiltrated by
4 Alija's services; whether I was a Serb at all or not, and if was, what
5 kind of a Serb I was. So I managed to sail through all that and I really
6 tried during that period of time to spend most of the time with
7 Mijhalo Bajic. He was about ten years older than I was, and we played
8 chess and discussed various topics.
9 JUDGE HARHOFF: Mr. Hannis, where are we going with all of this?
10 MR. HANNIS: Your Honours, I'm trying to get through the
11 chronology that was presented the Defence case, and I have other
12 arguments that will relate to this chronology. I ask your patience for a
13 little bit longer.
14 JUDGE HARHOFF: Unless you have an urgent point relating to the
15 indictment, I think you should move on.
16 MR. HANNIS: Okay. I understand, Your Honour, but, at the same
17 time, at the end of the case I have to make submissions, Prosecution has
18 to make submissions, about the evidence, about the credibility of the
19 witnesses, about the weight to give testimony of witnesses and the
20 physical evidence, and some of this is important for that because this
21 witness will be an important witness for both sides, and that's why I ask
22 your indulgence. But my next question will be --
23 JUDGE HARHOFF: But, Mr. Hannis, let me just make it clear to you
24 that I don't find any of your questions going to the credibility of the
25 witness, nor do I see the relevance to any point in the indictment.
1 MR. HANNIS: Your Honours, I don't think this is an appropriate
2 time for me to make my arguments about how this relates to his
3 credibility, but I promise you that I have a plan and an intention and a
4 reason for asking these questions that I'm asking and the order in which
5 I'm asking that will go to the argument at the end. And if you want me
6 to have the witness leave the room and explain to you in further detail,
7 I'm willing to do that, but my next question is:
8 Q. When did you get an assignment? Who gave it to you? And where
9 did you go?
10 A. I already said, I think Mr. Skipina told me, that there were
11 discussions about my future engagements and that Mr. Stanisic cut the
12 chase and said that I'm a person which could be used by the ministry at
13 the time. And then he asked what was the most difficult assignment in
14 the territory of Republika Srpska at the time, somebody said Brcko, and a
15 proposal was made for me to be sent to Brcko so that I could solve the
16 problems there and thereby show that I know how to do my job.
17 So my assignment was to go to Pale, where I received further
18 instructions, and after that I went towards Bijeljina with
19 Danilo Vukovic. I think I described that in some detail.
20 Q. And that remark by Mr. Stanisic was not something you heard
21 directly from him but was reported to you by Mr. Skipina; is that
23 A. Yes, yes. Slobo told me.
24 Q. Thank you. And even though you've gotten this important job in
25 Brcko, were you provided a car to get there?
1 A. No, I was not given a car. I told you already that I was told to
2 go to the police station in Kula and to get a car from Mr Tepavcevic. He
3 was not prepared to give me a vehicle at that moment, so we were
4 transported by a series of police cars from police station to police
5 station, from Pale to Sokolac, from Sokolac to Han Pijesak, and so on
6 until Bijeljina.
7 Q. And you told us about your arrival in Bijeljina encounter with
8 Mr. Devedlaka who told you you should flee, as he apparently was doing
9 the same, and then you reported I think a day or two later to
10 Mr. Jesuric, Predrag Jesuric. What was his position at the time in
11 Bijeljina, do you know?
12 A. This must be a problem in interpretation; it wasn't
13 Mr. Jasarevic.
14 Let me tell you straightaway, Mr. Devedlaka didn't suggest, he
15 urged us to flee from Bijeljina. That's what he said. After one or two
16 days, we called -- we were called to the police station in Bijeljina, a
17 vehicle came to pick us up, that vehicle transported us to Bijeljina, and
18 we reported to Mr. Predrag Jesuric. He was the chief there, and we
19 reported to him.
20 Q. You say he was the chief. Was he the chief of the SJB or the CSB
21 or both? Do you know?
22 A. I think he was the chief of the CSB.
23 Q. And what task or assignment did he give you?
24 A. As I have already stated, before the war there would always be
25 two policemen who perform supervisory inspection. My assignment that I
1 received in Pale was to go and perform supervisory inspection and provide
2 professional and other assistance in police stations. He separated us.
3 He said that Danilo Vukovic was supposed to go to Zvornik and that I
4 should go to Brcko. So in addition to the basic work that I had to do,
5 because it was part of my job, I was also supposed to assist in the
6 establishment of the police station in Brcko. That was the context of
7 the dispatch of Mr. Jesuric.
8 Q. Okay. Thank you.
9 MR. HANNIS: Could we show the witness Exhibit 1D547.
10 Q. Mr. Andan, while's that's coming up --
11 MR. ZECEVIC: Can we have a tab number?
12 MR. HANNIS: I'm sorry, this was a Defence exhibit dated
13 1st or 2nd June. Yeah, it's tab 83 in the Prosecution list, tab 15 in
14 the Defence list.
15 MR. HANNIS:
16 Q. In your testimony about this document and what you were doing on
17 your first days in Brcko, a few times you said "we," as in the plural,
18 and were -- and I had the impression that you were with Danilo Vukovic,
19 but I understand he was given a different task. So were you the only
20 inspector there, or was there someone else helping you do that inspection
22 A. I said quite clearly that Danilo Vukovic went to Zvornik while I
23 went to Brcko. I was the only inspector in Brcko. However, when I say
24 "we," I refer to the management of the police station. I was not
25 superior to the chief of the police station. My task there was to
1 perform supervisory inspection and provide all assistance required from
2 me. So I could propose to the chief various measures that he could
3 introduce in order to consolidate the station.
4 Q. When you first got there, to Brcko, did you have a one-on-one
5 meeting with the chief before this meeting with the specialist board?
6 A. I'm not quite sure what you mean by "specialist board," but of
7 course I had to carry out an informative conversation with the chief,
8 because, you know, when you come into somebody's house, first you talk to
9 the host of the house.
10 Q. That makes sense. That's why I ask. And I assume that's what
11 you did. When I said "specialist board," I'm just reading from this
12 document which says "minutes of the meeting of the specialist board of
13 the Serb SJB." So that's where I picked up the term. It's on the
14 document in my English translation. Do you have it on your screen?
15 A. We are talking about the management of the police station. A
16 fully complemented police station has commander, his deputy, and his
17 assistants, and they comprise the collegium of the police station. There
18 is also a chief of the crime prevention service and, if necessary, the
19 chief of the civilian affairs. So this is the collegium of the
20 management of a police station.
21 Q. Thank you. Now, you told us that Mr. Veselic, who was the chief
22 at this time, had been appointed, I guess, after the bridges on the
23 Sava River were blown up in Brcko. And we established, I think, that
24 that happened on the 30th of April, 1992.
25 Do you know or do you remember who had been the chief of the SJB
1 in Brcko before the bridges were blown up?
2 A. I'm not sure, even about what you just said, that is, that he had
3 been appointed -- that he was appointed chief after the bridges were
4 blown up. So I'm not sure. He may have been appointed before that
5 event. I don't know. And I also don't know who was the chief of the
6 police station in Brcko before the bridges were blown up.
7 Q. Okay. Thank you. You mentioned that a few days after you were
8 there you had some problems with some of Captain Dragan's men led by a
9 certain Rane. Can you tell the Judges what you know about
10 Captain Dragan; who was he and who were his men that were in the Brcko
11 area at this time?
12 A. There must be some problem in interpretation again. It was
13 wasn't "Rane"; it was a "Rade." They were members of a paramilitary
14 formation that was trained and sent to the territory of Republika Srpska
15 by Captain Dragan. That's what I know. They weren't part of any armed
16 forces of Yugoslavia or police forces of Serbia and Montenegro. To my
17 mind, it was a paramilitary formation, and he was a person who trained
18 and sent paramilitary formations. So this trail went from Brcko towards
20 Q. My question was: Do you know who he was, where he was from, his
22 A. Right now I can't remember, although I do know his first and last
23 name. He is from Serbia, of course. As far as I know, when the war
24 began in the former Yugoslavia, he arrived in Serbia from Australia.
25 Then I think he was in Knin, where he also organised some sort of
1 paramilitary formations, Red Berets, and then as the war spread, he also
2 began operating in the territory of Bosnia and Herzegovina. His first
3 name is Dragan and I can't remember his last name.
4 Q. Now, before this meeting that's reflected in the document on the
5 screen in front of you, in your meeting with Chief Veselic, had he
6 briefed you about the situation in Brcko and what had happened since the
7 bridges were blown at the end of April? What had he told you about the
8 security situation?
9 A. It was difficult to talk to a person who did not belong to the
10 same profession. His first job in the Ministry of the Interior was the
11 job that he had in Brcko. Then, at the time, he tried to explain to me
12 various positions of units around Brcko, and he almost did not talk about
13 the problems in the police station, which, as I told you, was not
14 functioning at the time.
15 I posed the questions that are normal when somebody arrives in
16 the police station for the first time. I wanted to know the level of the
17 manpower, their qualifications, and similar things. Well, he did not
18 know the answers to those questions. He made no effort to prepare for
19 the meeting. He said that they had problems, that they did not have
20 policemen, that the military took all the policemen and used them at the
21 front line. He also said that they had the problem with the paramilitary
22 formations and that they did not know what to do about it. He said that
23 this was a pronounced problem. It is quite clear that at the time he did
24 not have enough courage to re-organise the station in order to resolve
25 the problem on their own.
1 Q. Thank you.
2 MR. HANNIS: I note the time, Your Honours.
3 I think we'll stop here for the day, Mr. Andan.
4 JUDGE HALL: So we take the adjournment to resume -- [Microphone
5 not activated]
6 We resume in this courtroom tomorrow morning at 9.00. Thank you.
7 [The witness stands down]
8 --- Whereupon the hearing adjourned at 1.44 p.m.,
9 to be reconvened on Wednesday, the 1st day
10 of June, 2011, at 9.00 a.m.