Tribunal Criminal Tribunal for the Former Yugoslavia

Page 21556

 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

Page 21557

 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

Page 21558

 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.

Page 21559

 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

Page 21560

 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

17     answer.

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

Page 21561

 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

 9     said.

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

Page 21562

 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

Page 21563

 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.

Page 21564

 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

23     go?

24        A.   I went to Han Pijesak.

25        Q.   Just a moment, please.

Page 21565

 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

25     quarters.

Page 21566

 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

Page 21567

 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

Page 21568

 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

Page 21569

 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?

Page 21570

 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

13     security.

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

19     work?

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

Page 21571

 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

Page 21572

 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.

Page 21573

 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

13     interview?

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

Page 21574

 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

Page 21575

 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

 7     committed.

 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

20     inspection.

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

25     remember?

Page 21576

 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

18     conducted.

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.

Page 21577

 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

Page 21578

 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?

Page 21579

 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

 9     Serb.

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?

Page 21580

 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

Page 21581

 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

24     specific.

25        Q.   Well, I understood from Mr. Zecevic's question at page 21384 that

Page 21582

 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

20     recall?

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?

Page 21583

 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

 7     sent?

 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

15     investigation.

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.

Page 21584

 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.

Page 21585

 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

 8     pages.

 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

21     time.

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

Page 21586

 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.

Page 21587

 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?

Page 21588

 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

21     correct?

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

Page 21589

 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

Page 21590

 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

Page 21591

 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

Page 21592

 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

20     that?

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.

Page 21593

 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

19     interruption.

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?

Page 21594

 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?

Page 21595

 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

20     right.

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

Page 21596

 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

13     says:

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.

Page 21597

 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

Page 21598

 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.

Page 21599

 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

19     vein.

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

Page 21600

 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

Page 21601

 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

Page 21602

 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

Page 21603

 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.

Page 21604

 1             That's why I felt I was entitled to go into what I've been going

 2     into.

 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

Page 21605

 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

19     information.

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

Page 21606

 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

Page 21607

 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

 7     proper.

 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

Page 21608

 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

11     time.

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

22     Sarajevo?

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.

Page 21609

 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

 7     somebody.

 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

16     you.

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.

Page 21610

 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.

Page 21611

 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

13     place.

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

Page 21612

 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.

Page 21613

 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

Page 21614

 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

Page 21615

 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

15     correct?

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

Page 21616

 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

Page 21617

 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

22     Mostar.

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.

Page 21618

 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

10     occasion.

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

17     blood.

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.

Page 21619

 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.

Page 21620

 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,

Page 21621

 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

Page 21622

 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

Page 21623

 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

Page 21624

 1     dismissed.

 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

Page 21625

 1     the time.  And that's when I finally ended up in Vraca in the police

 2     school.

 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

Page 21626

 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.

Page 21627

 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

22     correct?

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?

Page 21628

 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

Page 21629

 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

21     job?

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

Page 21630

 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

Page 21631

 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

19     him.

20        Q.   My question was:  Do you know who he was, where he was from, his

21     name?

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

Page 21632

 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.

Page 21633

 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.