110214IT

Page 11740

1 WITNESS: SANIJA DZEVLAN

2 [Witness answered through interpreter]

3 JUDGE KWON: Please make yourself comfortable.

4 THE WITNESS: Thank you.

5 JUDGE KWON: Mr. Gaynor.

6 MR. GAYNOR: Thank you, Mr. President.

7 Examination by Mr. Gaynor:

8 Q. Witness, could you state your full name, please?

9 A. My name is Sanija Dzevlan.

10 Q. Did you previously testify at the Tribunal in the trial of

11 Stanislav Galic?

12 A. Yes.

13 Q. Did you yesterday, with the assistance of an interpreter, review

14 a transcript of your evidence in that trial?

15 A. Yes, I did.

16 Q. Now, I understand you wish to make corrections to one word which

17 appears four times in that transcript, and I'll read that correction into

18 the record.

19 The word "Treskavica" appears four times on pages -- on

20 page 3547, at lines 17 and 18, and at page 3548, at lines 1 and 2.

21 Ms. Dzevlan, I understand that in all four of those locations,

22 you wish to substitute the word "Jahorina" for "Treskavica." Is that

23 right?

24 A. Yes.

25 Q. Subject to those corrections, do you adopt that transcript as

Page 11741

1 your evidence in this trial, and if you're questioned today about the

2 same events, would you provide the same information to the Trial Chamber?

3 A. Yes.

4 MR. GAYNOR: Mr. President, the transcript of the witness's

5 evidence in English is 65 ter 22521, and I tender that.

6 JUDGE KWON: That is admitted.

7 THE REGISTRAR: As Exhibit P2291, Your Honours.

8 MR. GAYNOR: And I'll read a brief summary of the witness's

9 evidence for the benefit of the public.

10 During the conflict, Ms. Dzevlan lived in Dobrinja IIIA in

11 Sarajevo. Those living there lived in fear. They could not move around

12 freely, as it was very dangerous, and there were many casualties.

13 Barricades were put up in several locations as protection against sniper

14 fire.

15 The 6th of January, 1994, was a particularly calm day in

16 Dobrinja. As it was calm, Ms. Dzevlan, who was an unarmed civilian,

17 decided to go to a hospital to pick up some medicine to bring to her

18 mother, who was sick at home. While returning home on her bicycle,

19 Ms. Dzevlan crossed a bridge. She was the only passer-by in the area at

20 that time. Barricades extended along the length of the bridge on both

21 sides. Ms. Dzevlan was struck by a bullet, and several other bullets

22 landed on the road in front of her at the same time. She managed to

23 cycle on to where neighbours helped to take her to a hospital for

24 treatment. Ms. Dzevlan believes that she was fired upon either from an

25 Orthodox Church or from buildings next to the church in Dobrinja IV.

Page 11742

1 Both the church and the neighbouring buildings were under VRS control.

2 On the following day, a man was struck by a bullet while crossing the

3 same bridge.

4 That ends the public summary.

5 Q. Ms. Dzevlan, I'm going to go straight to the incident in

6 question, and I'd like to call up 65 ter 20571.

7 Ms. Dzevlan, is that the bridge which you were crossing when you

8 were shot?

9 A. Yes.

10 Q. Now, we see several lanes of traffic. For the sake of

11 orientation, those lanes of traffic are on the bridge itself; is that

12 right?

13 A. Yes.

14 Q. You were cycling along one of those lanes when you were struck;

15 is that right?

16 A. Yes.

17 Q. Now, we see, marked with a black marker, some Xs and lines on one

18 side of the bridge. Could you confirm what those markings represent?

19 A. A barricade erected on the bridge.

20 Q. And there was a similar barricade on the other side of the

21 bridge; is that right?

22 A. Yes.

23 Q. The building indicated with a circle is the Orthodox Church; is

24 that correct?

25 A. Yes.

Page 11743

1 Q. And the buildings to the left of the church are in Dobrinja IV;

2 is that right?

3 A. Yes.

4 Q. Now, I'd like you to tell the Court when, exactly, you were

5 struck by the bullet. Was it before you entered the bridge, while you

6 were on the bridge, or as you were exiting the bridge?

7 A. As I was exiting the bridge.

8 Q. And were you knocked off your bicycle by the shot?

9 A. No.

10 Q. Now, could you describe the visibility in the area at the moment

11 that you were shot?

12 A. Well, it was still day-time, because it was impossible to move

13 during night-time because there was no electricity and it was pitch dark.

14 So it was day-time and the visibility was good.

15 Q. Could you express -- perhaps in greater detail, when you say

16 "visibility was good," could you give Their Honours a concept of how good

17 it was?

18 A. Well, it was still day-time, as I said. One could see, I think.

19 I don't understand your question. Can you please repeat it?

20 Q. Certainly. You said earlier that visibility was good. Could you

21 express, in a little more detail, how good it was?

22 JUDGE MORRISON: It's just a suggestion, but one might be able to

23 ask the witness to look at the photograph and see that relative to the

24 degree of visibility that we can see apparent in the photograph, whether

25 it was better or worse than that.

Page 11744

1 MR. GAYNOR: Thank you, Your Honour, thank you.

2 Q. Did you understand that question, Ms. Dzevlan?

3 A. Yes, I understood the question. The visibility was more or less

4 like the one that we see here, only it was an overcast day on that day.

5 Q. The bridge that you were crossing passes over a river; is that

6 correct?

7 A. Yes.

8 Q. Was that river a source of water for people in your community at

9 that time?

10 A. Yes, the river water was used for washing, for flushing toilets,

11 and other things because we didn't have any water. That was the only

12 source that we used for washing. We couldn't use it as drinking water.

13 Q. Did people go down to the river at the location of this bridge to

14 get water?

15 A. Yes, they used to go there to fetch water and to wash their

16 laundry on the river.

17 Q. Now, are you aware of any incidents involving the people who

18 would go there to fetch water and to wash their laundry?

19 A. Yes, I know that some of them were wounded, some women were

20 wounded, and I also heard that one of the women was killed under the

21 bridge.

22 Q. How were those women wounded, and how was -- the woman who was

23 killed, how was she killed?

24 A. Probably by a sniper bullet.

25 Q. How, exactly, do you know that? How did you come to hear about

Page 11745

1 the women being wounded and the woman being killed?

2 A. Because I lived near to the bridge.

3 Q. Now, you said that -- you suggested that the woman was killed by

4 a sniper bullet. And the women who were wounded, could you clarify, how

5 were they wounded?

6 A. I suppose that they were wounded either by the sniper bullet or a

7 burst of fire. I have no knowledge of weapons, so I can't tell you

8 exactly; all I know is that the bullets were fired from rifles.

9 MR. GAYNOR: I'd like to tender the photograph, Mr. President.

10 JUDGE KWON: Yes.

11 THE REGISTRAR: Exhibit P2292, Your Honours.

12 MR. GAYNOR: I'd like to call up now Exhibit D670, please.

13 Q. While that's coming up, I want to go back to the moment at which

14 you were struck.

15 Do you believe that you were struck after you had exited the area

16 where the barricades stood?

17 A. Yes.

18 Q. On the screen in front of you, on the left, do you see a

19 statement which you made on 30th of September, 1994?

20 A. Yes.

21 Q. Now, in the opening words of the paragraph underneath the word

22 "Statement," do you see the words:

23 "On 6th of January, 1994, at around 1630 hours, I was returning

24 home on my bicycle"?

25 A. Yes.

Page 11746

1 Q. And you go on to describe the incident.

2 Do you recall that in your testimony in the Galic trial, you said

3 that the incident took place between 3.00 and 4.00?

4 A. Yes.

5 Q. Could you explain to Their Honours why you said in this statement

6 that it was 1630 hours when you were returning home on your bicycle?

7 A. Well, the statement I gave in September, I would say that it was

8 still daylight at half past 4.00. Unable, due to the shock, to find my

9 bearings around the exact time and what the hour was, I suppose that at

10 one moment I said that it was at 1630, but I couldn't have been sure

11 because I didn't have a watch. I clearly remember that we had lunch on

12 that date -- day and that at around 3.00, I left my home, went to the

13 hospital, and came back, because I knew that it was impossible to move

14 during night-time because there was no electricity and everything was

15 pitch dark. I had a little baby at the time, and I couldn't afford to

16 venture out during night-time and leave my child alone. So it is

17 possible that at the time when I gave this statement, this is what I

18 said, that it was 1630.

19 I do remember, though, that it was a bright day and that I headed

20 for the hospital after lunch.

21 Q. You mentioned in your answer that you didn't have a watch. Could

22 you clarify, were you wearing a watch at any point on the day that you

23 were struck?

24 A. No, never. When a person gets wounded, it just never crosses his

25 or her mind to look at their watch and check the time of the wounding.

Page 11747

1 Q. On the day in question, what, exactly, were you wearing?

2 A. I had brown trousers and a yellow jacket.

3 Q. Could you possibly describe the shade of yellow that your jacket

4 was?

5 A. I think it was lemony-yellow.

6 Q. Was your hair long or short at the time of the incident?

7 A. I had long hair, and that had been my style for quite a few

8 years. During wartime, there was no hairdresser available for me to do

9 my hair, so I had my hair very long.

10 Q. And were you, on the day of the incident, wearing your hair tied

11 up or was it down?

12 A. I had it down. I never tie it.

13 MR. GAYNOR: Thank you.

14 I have no further questions, Ms. Dzevlan. Thank you for that.

15 Mr. President, can I seek the admission of a couple of associated

16 exhibits?

17 There are, I believe, three exhibits which have not been

18 admitted. They are 09603, 09949, and 40058P. I seek to tender them at

19 this time.

20 JUDGE KWON: And 9536, Quick Time --

21 MR. GAYNOR: I believe that was recently admitted as P2207.

22 JUDGE KWON: Thank you.

23 Yes, they will be admitted.

24 MR. GAYNOR: Thank you, Mr. President.

25 No further questions.

Page 11748

1 JUDGE KWON: Yes. Let's give them numbers.

2 THE REGISTRAR: Yes, Your Honours.

3 They will be Exhibit P2293 to P2295 respectively.

4 JUDGE KWON: Madam, you will be asked by Mr. Karadzic further

5 questions.

6 Mr. Karadzic.

7 THE ACCUSED: [Interpretation] Thank you.

8 Good morning to all.

9 Cross-examination by Mr. Karadzic:

10 MR. KARADZIC: [Interpretation]

11 Q. Good morning, Ms. Dzevlan.

12 A. Good morning.

13 Q. You knew immediately that you had been hit by a bullet from a

14 rifle; right?

15 A. I didn't know immediately. I just felt the pain. But when I

16 came to the hospital, they told me I had been hit by a bullet.

17 JUDGE KWON: Ms. Dzevlan, if you could put a pause between the

18 question and answer, because both of your words should be interpreted

19 into English and French. Thank you.

20 Yes, Mr. Karadzic.

21 MR. KARADZIC: [Interpretation]

22 Q. Could you tell us this: You were moving from the hospital

23 towards your home when you were hit; right?

24 A. Yes.

25 Q. What were all the things you did on that day?

Page 11749

1 A. I just went to the hospital to get medicine, and nothing else. I

2 went back.

3 THE ACCUSED: [Interpretation] 1D3234, could I have that in

4 e-court, please, so that we try to mark a few locations that are

5 important, as far as this incident is concerned. 1D3234.

6 MR. KARADZIC: [Interpretation]

7 Q. You've lived in Dobrinja for a long time; right?

8 A. Yes.

9 Q. Thank you. Are you familiar with the layout of these buildings?

10 A. I'm sorry, I didn't take my glasses. I cannot see.

11 Q. May I offer you my own glasses?

12 A. No, thank you.

13 [Trial Chamber and Registrar confer]

14 JUDGE KWON: You left your glasses at the waiting room; is that

15 what you meant, Ms. Dzevlan? No problem, we'll take --

16 THE WITNESS: [Interpretation] Yes. Thank you.

17 MR. KARADZIC: [Interpretation]

18 Q. While we're waiting for that, may I ask you the following: Did

19 you take the same route from home to hospital and from the hospital to

20 your home?

21 A. Yes.

22 Q. Did you pass by any military facilities along the way?

23 A. No. That's a civilian area in Dobrinja. To this day, I mean,

24 it's only civilians who are living there, the general population.

25 Q. I see. Did you pass by a street called Branilaca Dobrinja, the

Page 11750

1 Defenders of Dobrinja nowadays?

2 A. I really don't know what the street names are in Dobrinja.

3 Q. We can look at the city map and see what the former name was.

4 Do you know that the command of the Dobrinja Brigade was on that

5 street?

6 A. I don't know that.

7 Q. Do you know that in Dobrinja, there was a brigade?

8 A. I just heard of that.

9 Q. Have you heard of Ismet Hadzic, its commander?

10 A. Yes.

11 Q. Did you know that it had between 4.500 and 6.000 soldiers?

12 A. No.

13 Q. You certainly know why it was that the Serbs didn't take all of

14 Dobrinja; right?

15 A. No.

16 Q. Was there fighting in and around Dobrinja often? I'm not talking

17 about that day specifically.

18 A. There was a great deal of shelling.

19 Thank you very much.

20 Q. This Muslim brigade, this Dobrinja Brigade, did it try to take

21 Dobrinja IV?

22 A. I don't know about that.

23 Q. Please cast a glance at this, at this Google image, aerial image.

24 Do you see the bridge where you were wounded? The street is

25 Nikola Demonja.

Page 11751

1 A. I think the answer is yes.

2 Q. Could you please mark it?

3 JUDGE KWON: Could you wait a minute until assisted by our Usher.

4 Yes.

5 THE WITNESS: [Interpretation] Just a moment, please.

6 It's hard for me to find my way. Just a minute.

7 This is the river, this is the bridge. [Marks]

8 MR. KARADZIC: [Interpretation]

9 Q. Could you please put number 1 there?

10 A. [Marks]

11 Q. And also if you could mark this more precisely; first of all, the

12 arrow depicting the direction in which you were moving?

13 A. As I was returning from the hospital?

14 Q. When you were hit.

15 A. [Marks]

16 Q. Thank you. Could you then mark -- could you then mark the next

17 bridge -- or, rather, the next street where the separation line was? You

18 know where the separation line was; right?

19 A. I don't know. I was not at the separation line, but I do know --

20 I mean, later on after the war, I found out where the separation line

21 was.

22 Q. Could you please mark that for us?

23 A. [Marks]. I assume that that's it.

24 Q. Thank you. To this day, it belongs to Republika Srpska; right?

25 A. Yes.

Page 11752

1 Q. Thank you. These buildings to the right -- actually, could you

2 put number 2 there by this line; that is, this street?

3 A. [Marks]

4 Q. The building to the right, that was under the control of the Army

5 of Republika Srpska; right?

6 A. To the right, yes.

7 Q. The buildings on the left were under whose control? Could you

8 please put number 3 to the west of this street?

9 A. [Marks]

10 Q. Under whose control were they?

11 A. The Bosnian Army.

12 Q. Thank you. Could you mark the building where you lived?

13 A. [Marks]

14 Q. Thank you. Could you mark the Dobrinja Hospital?

15 A. I think it was here. [Marks]

16 Q. I see. Could you then mark the direction that you were moving

17 in? Would you draw a line there?

18 A. I cannot really find my way. But if this is it, I was moving

19 this way. [Marks]

20 Q. Thank you. Could you now please mark the church in Meljine [as

21 interpreted]? Nice and slow, just take a look. The church in Veljine;

22 right?

23 A. Yes, but I cannot really find my way here.

24 Q. Can you now mark the building from which you think the shot came,

25 the one that wounded you, if it's not the church?

Page 11753

1 A. I can't do it this way.

2 Q. Thank you. You had been behind a shelter and you walked out.

3 Did you hear bullets hitting the shelter?

4 A. No.

5 Q. How much time had elapsed from the moment you left the shelter

6 until you were hit? Tell us either in terms of metres or in terms of

7 time.

8 A. I don't know. I wasn't paying attention. I was on my bicycle, I

9 was riding my bicycle. Was it half a minute or whatever, I really didn't

10 have any feeling of that kind. Time was of no significance to us during

11 the war, so I really cannot say. As soon as I left the shelter, I was

12 hit.

13 Q. Thank you. Tell us, you said at one point - I'll try to find it

14 now - that you first heard shots and then you were hit; is that right?

15 A. No.

16 THE ACCUSED: [Interpretation] Let us have a look at the first

17 statement.

18 Do we need to mark anything else here? No.

19 MR. KARADZIC: [Interpretation]

20 Q. Do you know there where it says "Google," could you please put

21 the date and could you sign it?

22 A. [Marks]

23 JUDGE KWON: Thank you. That will be admitted.

24 THE REGISTRAR: As Exhibit D1048, Your Honours.

25 THE ACCUSED: [Interpretation] Can we have the statement of

Page 11754

1 Ms. Dzevlan. D670 is what I have. It was recently admitted by the

2 Prosecution. Can we see it, please, both in English and in Serbian.

3 Oh, yes, yes. D670, that means it's already been admitted.

4 Could we please have both the English and the Serbian version.

5 MR. KARADZIC: [Interpretation]

6 Q. You first saw bullets flying around you, and then you were hit?

7 A. No, no, I was hit first. I didn't even realise that I had been

8 wounded until I saw these bullets ricochetting on the ground. Then I

9 realised that I was being shot at, and I went on riding my bicycle. I

10 assume that I would have been killed had I fallen off my bicycle.

11 Q. Thank you. How do you know that these are ricochets? Are you

12 knowledgeable about this kind of thing?

13 A. Well, I'm not knowledgeable about this kind of thing, but I have

14 heard what a ricochet is.

15 Q. Thank you. Tell me, what was the distance between and among

16 these bullets? It was your assessment that it was automatic weapons;

17 that's what you say in your statement?

18 A. That's my assumption.

19 Q. Thank you. Then you went on riding your bicycle; right?

20 A. Yes.

21 Q. This shelter on the bridge, to the best of your knowledge, was

22 used for what?

23 A. So that civilians could safely cross from one part of Dobrinja to

24 another.

25 Q. And on the other side, was there a shelter on the other side as

Page 11755

1 well? Were both sides of the bridge protected by barricades, both

2 up-stream and down-stream?

3 A. Yes.

4 Q. The one on the other side, down-stream, it was protection from

5 what?

6 A. Well, I don't know what the name is, but down there, that

7 village. I mean, there were troops there, I mean Serb troops. They were

8 firing too.

9 Q. That was Nedzarici; right?

10 A. Oh, yes, Nedzarici.

11 Q. Nedzarici is over 1.000 metres away from that bridge?

12 A. I'm not very knowledgeable about that kind of thing.

13 Q. I'm a bit puzzled by the fact that you first said that you were

14 hit at 1630 hours. Do you agree that had this statement remained as

15 such, the visibility would have been assessed quite differently, because

16 in Sarajevo, at 1630 in winter-time, it's rather dark, isn't it?

17 A. Well, yes, quite. But I did say, when I made my statement, that

18 I could not orient myself in time, because during the war, time didn't

19 mean anything to us. Day-time and the dark, that was the only kind of

20 time that we distinguished during the war; actual hours did not mean a

21 thing.

22 When I said "1630" at one point in time, it must have been just

23 totally off the cuff. It was in the afternoon; it wasn't in the morning.

24 It wasn't dark, because it was impossible for us civilians to move about

25 in the dark in Dobrinja.

Page 11756

1 THE ACCUSED: [Interpretation] I would like to wait --

2 JUDGE KWON: Just a second.

3 Yes, Mr. Gaynor.

4 MR. GAYNOR: Yes.

5 I have an objection to the assertion by Dr. Karadzic that at 1630

6 it was rather dark in Sarajevo. That is not a matter in evidence. It's

7 disputed by the Prosecution. We will accept that sunset was at 1624 and

8 that twilight extended -- civil twilight was at 1655 and astronomical

9 twilight was at 1806, but certainly we do not accept that it's an agreed

10 fact that it was dark at 1630.

11 JUDGE KWON: But is the accused not able to put his question to

12 the witness?

13 MR. GAYNOR: Well, he can, but he has -- he's assuming a matter

14 not in evidence. He's assuming it's been proven that it was dark at

15 1630, and that has not been proven.

16 JUDGE BAIRD: But, Mr. Gaynor, didn't the witness agree with that

17 suggestion?

18 MR. GAYNOR: With the suggestion that at 1630, it was dark?

19 JUDGE BAIRD: Yes. She said:

20 "Well, yes, quite, but I did say ..." and then she carried on.

21 MR. GAYNOR: Yes, I accept that the witness did say those words.

22 I'm not sure that she was agreeing as to the precise level of darkness in

23 Sarajevo at that time.

24 JUDGE BAIRD: But she said, "Well, yes."

25 MR. GAYNOR: Very well. As Your Honours please.

Page 11757

1 JUDGE BAIRD: Thank you.

2 JUDGE KWON: Let us continue, Mr. Karadzic.

3 MR. KARADZIC: [Interpretation]

4 Q. When it's cloudy in the valley of Sarajevo, it's somewhat darker,

5 isn't it?

6 A. Well, it depends on the time, on the actual hour.

7 Q. First you said it was cloudy, and today, on page 9, you said that

8 it was a bright day. Can you help us with this so that we definitely

9 decide on what kind of a day it was?

10 A. Well, it was winter-time, it was cloudy, but there was

11 visibility. I mean, there was light. I mean, what can I tell you about

12 light? I don't understand what you're trying to ask me.

13 Q. This is the interpretation that we received here. It said

14 "bright," and I think that that's exactly what you said. "Svetao," that

15 kind of day, that means a clear day, a bright day?

16 A. Well, it was visible, because I was riding my bicycle, I left

17 home after lunch, and I know that it was still day-time when I was

18 admitted into hospital. The neighbours who were in front of the

19 building, I mean, they wouldn't be standing outside. Nobody would be

20 standing outside during the night. Nobody would be standing there in the

21 dark.

22 Q. However, it remains that the day was a cloudy one; right?

23 A. Yes.

24 THE ACCUSED: [Interpretation] Thank you.

25 Could we have 65 ter 20571 for a moment, please. I believe that

Page 11758

1 this has been admitted into evidence.

2 THE REGISTRAR: Exhibit P2292, Your Honours.

3 THE ACCUSED: [Interpretation] Now, I would kindly ask the Court

4 Clerk to switch on the pen.

5 MR. KARADZIC: [Interpretation]

6 Q. Could you please indicate the exact spot where you were hit, and

7 put an X?

8 Can you please zoom out?

9 JUDGE KWON: Just wait.

10 THE WITNESS: [Marks]

11 MR. KARADZIC: [Interpretation]

12 Q. Could you indicate the direction in which you were moving?

13 A. [Marks]

14 Q. Thank you. So you were driving on the left-hand side?

15 A. Yes.

16 Q. Now, can you place the number 1 there?

17 A. [Marks]

18 Q. And can you also put the number 2 next to the church tower,

19 although it is visible?

20 A. [Marks]

21 Q. Thank you. This building that we see next to the number 2, can

22 you mark it with the number 3, please?

23 A. [Marks]

24 Q. Who controlled that building, Ms. Dzevlan?

25 A. I don't know.

Page 11759

1 Q. On which side of the street is it?

2 A. What do you mean, on which side of the street?

3 Q. Is it on this side of the separation line or from this side?

4 A. It's from this side, from the Bosnian side.

5 Q. Thank you. Can you please put your signature and date?

6 A. [Marks]

7 THE ACCUSED: [Interpretation] Can we please have this admitted

8 into evidence?

9 JUDGE KWON: Yes. Exhibit D1049.

10 THE ACCUSED: [Interpretation] Can we now have 65 ter -- it's a

11 still photo from footage, and I think the number is 20571, 65 ter.

12 Can we then have 1D23 -- sorry, 3235, from 14 to 18:40.

13 [Video-clip played]

14 THE ACCUSED: [Interpretation] Can we freeze the last frame,

15 please.

16 MR. KARADZIC: [Interpretation]

17 Q. This is where you were shot, the place that you were showing to

18 Mr. Hogan; right?

19 A. Yes.

20 Q. Would you describe your hair as long hair?

21 A. This was my hair style after the war, and it's common knowledge

22 that women often change their hair-do. As you can see, I have longer

23 hair again.

24 THE ACCUSED: [Interpretation] Can we have this still photo

25 admitted into evidence, please?

Page 11760

1 JUDGE KWON: Can you produce one? Did you say "still photo" or

2 this video?

3 THE ACCUSED: [Interpretation] Maybe we can use this still photo.

4 It's no problem.

5 [Trial Chamber and Registrar confer]

6 JUDGE KWON: Unless you produce a still photo from this, I don't

7 think it's technically possible. Why don't you admit this video-clip, if

8 it is not in evidence?

9 MR. GAYNOR: The video-clip has been admitted. It's one of the

10 associated exhibits --

11 JUDGE KWON: That's another -- yes, thank you. Can we have that

12 number? Is that --

13 MR. GAYNOR: Yes. It was 40058P. I don't have the exhibit

14 number.

15 THE REGISTRAR: It's Exhibit P2295, Your Honours.

16 JUDGE KWON: But we don't know the time-frame for this.

17 THE ACCUSED: [Interpretation] We have the time-frame. 18:14 to

18 18:40. So 18 minutes 14 seconds to 18 minutes 40 seconds --

19 JUDGE KWON: Thank you.

20 THE ACCUSED: [Interpretation] -- is what we have just seen.

21 MR. KARADZIC: [Interpretation]

22 Q. Ms. Dzevlan, how many times were you shot?

23 A. I think twice.

24 MR. GAYNOR: Sorry.

25 Mr. President, just to correct the record, Mr. Reid has just

Page 11761

1 corrected me. The excerpts tendered by the Prosecution did not include

2 this particular portion of the video, so it might be wise to give this

3 particular portion a separate exhibit number.

4 JUDGE KWON: Very well.

5 We admit this separately as a Defence exhibit, Exhibit D1050.

6 MR. KARADZIC: [Interpretation] Thank you.

7 Q. You were hit with two bullets. Where did those bullets end?

8 A. I don't know.

9 Q. Were they extracted from your body?

10 A. No, they penetrated through my body.

11 Q. Thank you. Then in that case, we have four wounds, two entry

12 wounds and two exit wounds; is that correct?

13 A. Yes.

14 Q. You were hit both on the left side and the right side?

15 A. Yes.

16 Q. Can we then say that it was the buttock muscle that you were hit

17 in?

18 A. Yes.

19 Q. Was any bone in your body damaged as a result?

20 A. No.

21 Q. Did those bullets only scratch you or did they pass through the

22 muscle tissue?

23 A. They passed through the muscle tissue.

24 Q. So in such a condition with these two torn muscles, you continued

25 riding your bicycle to your neighbour's house?

Page 11762

1 A. Yes.

2 THE ACCUSED: [Interpretation] Can we please now have P1893 so

3 that we can see what the medical doctors have to say about this.

4 MR. KARADZIC: [Interpretation]

5 Q. Can you please look at this diagnosis and the discharge form.

6 "Vulnus transsclopetarium reg glutei bill," which means entry and exit

7 wound of both gluteal region?

8 A. Yes.

9 Q. Do you agree that the doctors did not specify which wounds were

10 entry wounds and which were exit wounds?

11 A. I don't understand the question.

12 Q. Did the doctors establish the point of entry and exit of both

13 bullets?

14 A. I don't think that was that much relevant at the time.

15 Q. With all due respect, Ms. Dzevlan, being a doctor myself, I think

16 it is important to indicate the entry and exit point of a bullet.

17 How did it happen that you were hit in the left side as well?

18 Where did that bullet come from?

19 A. Probably from the same place that the first one came.

20 Q. Were they horizontal or was one higher and the other lower? Do

21 you have that information?

22 A. I don't know what you're asking me.

23 Q. If you were standing up, did one bullet enter at a higher level

24 and the other at the lower level or were they in the same line?

25 A. I have a wound along the whole length. I don't know how they

Page 11763

1 entered my body.

2 Q. Was the bicycle seat also hit by the bullets?

3 A. I don't know about that.

4 Q. So we can agree, can't we, that there is no indication here of

5 the entry and exit points? This wound, was that a horizontal one or a

6 slanted one?

7 A. It was horizontal.

8 Q. In your testimony today, you said that you think that the bullet

9 was fired either from the church or from Dobrinja IV. What makes you say

10 that?

11 A. I don't understand. This is where the Army of Republika Srpska

12 was, and the barricades were erected precisely for the protection of the

13 civilians. That's why we had those barriers, because there was sniping

14 coming from the church and from Dobrinja IV.

15 Q. So this is the criterion on the basis of which you claim that

16 because Serbs were there, this is where the bullet came from; right?

17 A. I said that the bullet came from the Serbian side.

18 Q. I appreciate that, but can you tell me on the basis of what did

19 you say that? What led you to say that it was either Dobrinja IV or the

20 church?

21 A. I don't know where else it could have come from.

22 Q. You don't think that there were troops and weapons and rifles in

23 the Muslim part of Dobrinja?

24 A. There were civilians living in that part of Dobrinja.

25 Q. Do you consider a defence line also to be a civilian feature?

Page 11764

1 A. [No verbal response]

2 Q. Between you and the Serbian position, was there a Muslim defence

3 line?

4 A. Yes.

5 Q. Did the Muslims control the building that you marked, and that

6 the Serbs could not capture it because it was defended?

7 A. Well, I suppose so.

8 Q. Thank you. You said that it was a calm day and that a cease-fire

9 was in force; is that right?

10 A. Yes.

11 Q. That's what you heard on the radio; right?

12 A. Yes.

13 Q. Do you know that there was fighting and that UNPROFOR was sending

14 reports about fighting taking place all over the city?

15 A. I don't know about that.

16 THE ACCUSED: [Interpretation] Can we now have 65 ter 09603.

17 MR. KARADZIC: [Interpretation]

18 Q. While we are waiting for this, Ms. Dzevlan: Do you remember that

19 during Bajram, people celebrate by firing from weapons?

20 A. I don't understand your question.

21 Q. Did people shoot into the air during Bajram?

22 A. No, they didn't.

23 Q. Very well. But it is a custom to fire from fire-arms during

24 holidays?

25 A. I don't know about other holidays, but I do know that there is no

Page 11765

1 shooting on Bajram.

2 THE ACCUSED: [Interpretation] Can we look at page 3 of this

3 document, which pertains to the 6th of January. Page 3, item 1,

4 sub-items B and C.

5 Well, there it is:

6 "Unstable throughout the reporting period."

7 And then it goes on to say that the BSA was shelling northern and

8 western areas of the city:

9 [In English] "Along with the city centre all week long. Most

10 frequent BSA targets were Stup, Zuc ... " and so on.

11 Now, look at C, where it says that the Bosnian side shelled, but

12 I have to read it in English so that you can get a translation:

13 [In English] "BiH shelling mainly confined to areas of Lukavica,

14 Grbavica and BSA side of confrontation line in Vogosca ..."

15 [Interpretation] Therefore, there was fighting all day long on

16 that date.

17 A. I don't know. All these places are so far from Dobrinja for me

18 to know that. I know that there was no shooting in Dobrinja. I don't

19 know about other parts of the town.

20 Q. Is Lukavica far away, is Kula far away?

21 A. Well, I don't know, one kilometre, two, three, four, as the crow

22 flies. I don't know. At that time, I had no need to go to Lukavica. I

23 had heard of it, but I had no need to go there. I did go to Luka [as

24 interpreted], but it is also far away, since I lived in Dobrinja.

25 When you stay in your flat, you stay indoors. You can't hear

Page 11766

1 very well any distant shooting. You can only hear close fire.

2 Q. Do we agree that Lukavica and Kula are about 2.000 metres away

3 and that the airport is about 1.000 metres away?

4 A. Well, I'm not very familiar with these distances.

5 Q. Thank you. You said in your statement -- actually, in the

6 transcript that in the beginning of the war, the JNA was firing at the

7 building that you were in from a tank and that the Patriotic League came

8 to defend the area; right?

9 A. Yes.

10 Q. Did Serbs live in that building too?

11 A. Yes.

12 Q. Do you know that a tank shell would have pierced the wall of such

13 a building?

14 A. It actually did in one apartment.

15 Q. Do you know who commanded this tank brigade in Lukavica at the

16 beginning of the war?

17 A. I assume it was the Army of Republika Srpska. Actually, the

18 army, the Yugoslav Army.

19 Q. In the Yugoslav People's Army in the beginning of the war,

20 Enver Hadzihasanovic was commander of that brigade when the war started.

21 Did you know that?

22 A. No.

23 Q. Enver Hadzihasanovic, was he a Muslim, and was he later on a

24 high-ranking officer of the Army of Bosnia-Herzegovina?

25 A. I don't know.

Page 11767

1 Q. Is he a Muslim?

2 A. I don't know that either.

3 Q. Judging by his first and last names, would you infer that he was

4 a Muslim?

5 A. Yes.

6 Q. Thank you. Is Vojnicko Polje far away from you?

7 A. Yes.

8 Q. How far?

9 A. About a kilometre.

10 Q. Thank you. Do you know that on the 3rd of January, a Serb woman

11 was killed there and other persons were wounded in Nedzarici; on the 3rd

12 of January that year?

13 A. I don't know.

14 THE ACCUSED: [Interpretation] We didn't manage to up-load this in

15 e-court, so could we please have it placed on the ELMO, the English

16 version, and then -- here it is. I'm going to read it out.

17 Could you please lower it a bit.

18 [In English] No, no, no, upper side. Thank you.

19 [Interpretation] This is a report of "Srna" for foreign

20 correspondents. It says:

21 "Muslim snipers from Vojnicko Polje killed a woman, and wounded

22 another person on Monday in Nedzarici (Western Sarajevo) ...," and so on

23 and so forth.

24 Had you heard of that, that this woman in your neighbourhood was

25 killed three days before you were wounded.

Page 11768

1 A. No. That is very far away. There were barricades towards

2 Vojnicko Polje. I had no way of knowing all this. We did not have all

3 this information during the war.

4 Q. But did you watch TV, right, and you listened to the radio?

5 A. Well, we didn't have any electricity at the time. We had this

6 small battery-operated radio, and from time to time we listened to the

7 news.

8 THE ACCUSED: [Interpretation] Can this report be admitted?

9 JUDGE KWON: No, Mr. Karadzic.

10 THE ACCUSED: [Interpretation] All right.

11 Can we see another report.

12 MR. KARADZIC: [Interpretation]

13 Q. You say that it was peaceful during that days; right?

14 A. Well, I cannot remember right now on which days it was peaceful

15 and which days it wasn't. But on that day, when I was supposed to go and

16 get this medicine because, well, my mother was afraid, she feared for my

17 life, and of course she was right. And I had to go and get that

18 medicine. Now, I cannot say exactly which day and at what time there was

19 no shooting and no shelling.

20 THE ACCUSED: [Interpretation] Can we show on the ELMO again

21 another document, too.

22 MR. KARADZIC: [Interpretation]

23 Q. This is the 5th of January. I'm going to read it in English so

24 that you can read an interpretation:

25 [In English] "Last night, on the Sarajevo front passed with

Page 11769

1 occasional Muslim small-arms provocations against Serb position on the

2 Jewish cemetery (Sarajevo centre) and upon Serb communities of Grbavica

3 (Sarajevo centre) and Dobrinja IV (Serb Sarajevo). Wednesday morning on

4 the front saw usual Muslim sniper activity.

5 "The Christmas cease-fire on the RS northern frontiers ...," and

6 so on.

7 [Interpretation] Did you hear that on the radio, that I had

8 declared a unilateral Christmas cease-fire?

9 A. No.

10 Q. So what did you hear on the radio; that there was some kind of

11 cease-fire on?

12 A. Well, probably. I can no longer remember. It's been a long

13 time. I just know that during those few hours when I was supposed to go

14 and get that medicine and come back, it was peaceful. Now, was it

15 peaceful the entire day, in the morning as well?

16 THE ACCUSED: [Interpretation] Thank you.

17 I believe that you're not going to admit this either, so then

18 let's put another report there on the ELMO.

19 MR. GAYNOR: I'd like to note, in passing, that none of these

20 three reports have been provided to the Prosecution by the Defence.

21 JUDGE KWON: Can I hear the explanation as to this, Mr. Karadzic?

22 THE ACCUSED: [Interpretation] Well, we've just received them,

23 Excellency, and I didn't have enough time -- I mean, we didn't have

24 enough time to up-load them in e-court. We're certainly going to do

25 that. Since you are not admitting them, I'm just using them to refresh

Page 11770

1 the witness's memory, nothing else.

2 MR. KARADZIC: [Interpretation]

3 Q. Now, it's the 6th of January, it's the day when you were

4 wounded --

5 JUDGE KWON: It's not an appropriate explanation. That being the

6 case, you are obliged to disclose this material to the Prosecution.

7 And having said that, let us proceed.

8 THE ACCUSED: [Interpretation] I do ask for an apology. This

9 happens rarely. But we received this only this morning, and that's why

10 we didn't have enough time.

11 MR. KARADZIC: [Interpretation]

12 Q. I'm going to read the first paragraph -- or, actually, I'm not

13 going to read the first paragraph, but then -- actually, was it Thursday

14 when you were wounded?

15 A. I don't know what day it was.

16 Q. This is what it says:

17 [In English] "Muslim forces renewed on Thursday morning at 6.45

18 a.m., an artillery infantry attack started on Wednesday upon Sarajevo,

19 Serb communities Grbavica and Raca, reported the Informative Service of

20 the Sarajevo Romanija Corps in Lukavica. Three persons were killed ...,"

21 and so on and so on.

22 [Interpretation] So on that day, there was considerable activity.

23 You didn't know about that; right?

24 A. No.

25 Q. Let us have a look at the 7th, just another piece of information,

Page 11771

1 what was going on at Dobrinja IV, and then we're going to leave this

2 particular topic.

3 Do you remember, Ms. Dzevlan, that I declared cease-fires both

4 for Muslim and Christian holidays and that I asked that no fire be opened

5 either on Muslim or Christian holidays?

6 A. I don't know. I don't remember. I had greater concerns than

7 that. I cannot really remember that. I had a young child. I had to

8 provide food, water. I had old parents. I really don't remember that at

9 all.

10 Q. Please have a look at this "Thursday." Was Friday the 7th of

11 January, 1994? And on the previous day, on Thursday, it was the 6th:

12 [In English] "On Thursday, at approximately 1000 hours, Muslim

13 artillery and infantry attempted to penetrate Serb territory in

14 Dobrinja [B/C/S spoken]."

15 It's the Dobrinja IV that you've been talking about; right?

16 A. Yes.

17 Q. Do you know from your Serb neighbours what holidays are on the

18 6th and 7th of January?

19 A. At that time, I did not know.

20 Q. Do you agree that the 6th of January is Christmas Eve, and that

21 the 7th of January is Christmas Day?

22 A. I agree, but it is irrelevant to me.

23 THE ACCUSED: [Interpretation] Thank you, Ms. Dzevlan, for having

24 come to testify. I have no further questions.

25 JUDGE KWON: Mr. Gaynor.

Page 11773

1 THE WITNESS: [Interpretation] Thank you very much.

2 [The witness withdrew]

3 JUDGE KWON: We'll have a break, about one hour, and we'll resume

4 at half past 11.00.

5 --- Recess taken at 10.23 a.m.

6 --- On resuming at 11.33 a.m.

7 [The witness entered court]

8 JUDGE KWON: Good morning, Mr. Glavas.

9 If you could kindly take the solemn declaration.

10 THE WITNESS: [Interpretation] I solemnly declare that I will

11 speak the truth, the whole truth, and nothing but the truth.

12 WITNESS: TIHOMIR GLAVAS

13 [Witness answered through interpreter]

14 JUDGE KWON: Thank you. Please be seated.

15 THE WITNESS: [Interpretation] Thank you.

16 JUDGE KWON: Ms. Edgerton.

17 MS. EDGERTON: Thank you, Your Honours.

18 Examination by Ms. Edgerton:

19 Q. Mr. Glavas, could you please tell us your full name?

20 A. Tihomir Glavas.

21 Q. Now, Mr. Glavas, on 30 March 2009, did you testify before the

22 State Court of Bosnia and Herzegovina as a Defence witness in the case of

23 Rade Veselinovic?

24 A. Yes.

25 Q. Have you, since that occasion, reviewed the transcript of your

Page 11774

1 testimony during those proceedings?

2 A. Yes, yes.

3 Q. And on February 3rd and 4th of this year, 2011, did you meet with

4 members of the Office of the Prosecutor, including me, to give a

5 statement on some additional matters relating to your observations and

6 experiences during the conflict in Bosnia and Herzegovina?

7 A. Yes.

8 Q. Was that statement read back to you in a language you understand?

9 A. Yes, in The Hague and --

10 THE INTERPRETER: Interpreters didn't hear the first part of the

11 answer.

12 MS. EDGERTON: I think I can safely move on.

13 Q. And then yesterday, did you again meet with me and other members

14 of the OTP to review and sign a further statement consolidating the

15 evidence from your testimony and your statement of February 3rd and 4th?

16 A. That's right.

17 Q. And in that further statement you signed yesterday, you made some

18 small corrections and clarifications to parts of your 4 February

19 statement; is that right?

20 A. That's right.

21 Q. Now, other than those, if I asked you the same questions yet

22 again that gave rise to that written evidence, would you give the same

23 answers?

24 A. Absolutely the same.

25 MS. EDGERTON: Then, Your Honours, could I ask that the

Page 11775

1 amalgamated statement, which was signed yesterday, 65 ter 90223, be the

2 next Prosecution exhibit, please?

3 JUDGE KWON: Yes.

4 THE REGISTRAR: Exhibit P2296, Your Honours.

5 MS. EDGERTON: Thank you.

6 I'll now read a summary of this witness's written evidence.

7 A career police officer, this witness held the post of commander

8 of the Public Security Station, or SJB, in Hadzici in the period leading

9 up to the outbreak of war. From April until August 1992, he served as

10 chief of the Public Security Station for the Serbian municipality of

11 Hadzici. In August of that year, he was transferred to Ilidza, where he

12 took up the post of deputy chief of the SJB for the Serbian municipality

13 of Ilidza. In his capacity as chief of the SJB, the witness was a member

14 of the Crisis Staff for the Serbian municipality of Hadzici. The

15 Crisis Staff was the highest organ of authority in Hadzici municipality.

16 The witness recounts an incident where, on 20 May 1992, during

17 the course of a police operation to search for weapons, three men,

18 civilians from the settlement of Musici, were killed. The decision to

19 carry out this operation to recover weapons emanated from the

20 Crisis Staff. Men from the settlement were arrested and detained in the

21 local sports and recreation centre. Additionally, it was the

22 Crisis Staff's decision that men of military age from other settlements

23 in the area should be arrested and detained. Some women and children

24 were also detained, but not as a rule. The decision as to the

25 establishment of a detention facility within the sports centre was made

Page 11776

1 by the Crisis Staff. It was also their decision that it should be

2 guarded by the Territorial Defence. The intention was that detainees

3 should be kept for exchange. In June 1992, the majority of the detainees

4 were transferred to Kula Prison.

5 On one occasion, the witness learned that paramilitaries had

6 entered the sports centre and abused the detainees. They attempted to do

7 the same thing at the garage under the municipality building, where

8 Bosniaks were also held. The witness confronted the members of this

9 paramilitary group, who withdrew.

10 The witness also gives evidence of the presence and operation of

11 Seseljevci and other paramilitary units in the Ilidza municipality, and

12 the combined efforts of the police and military to remove these units

13 because of their criminal behaviour.

14 That's the summary of his written evidence, Your Honours.

15 Q. Now, Mr. Glavas, I'd like to ask you some questions based on some

16 of this written evidence, but, first of all: Do you recall, during our

17 meeting yesterday, reviewing some additional photos and documentation?

18 A. Yes.

19 Q. Now, in your amalgamated statement, your written evidence, at

20 paragraph 6 you talked about the founding session of the Serbian

21 municipality of Hadzici in the first part of April 1992. Do you remember

22 that?

23 A. Yes, I do.

24 MS. EDGERTON: Could we please see 65 ter 01503, minutes of a

25 meeting dated 11 April 1992.

Page 11777

1 Q. Mr. Glavas, is this one of the documents you saw yesterday?

2 A. Yes, it is.

3 Q. Do you see your name at number 19, on the bottom right-hand

4 corner of this document, as a member of the advisory organ --

5 A. Yes, I do. Yes, I can see it.

6 Q. -- of Hadzici Serb municipality?

7 A. Yes, I see my name.

8 Q. Can you tell us what this document relates to?

9 A. I think that this is a sort of -- I would call it a working body,

10 since you had already said that I had stated that on that date, the

11 so-called All Serbian Assembly or rally was held, which involved all the

12 Serb residents of Hadzici. And at this Assembly, the Serbian

13 municipality of Hadzici was constituted. Certain legitimate authority

14 organs were elected on that occasion, and the list shown here, I think,

15 contains the name of the people who were members of this so-called

16 working body. And I can tell you that on that occasion, in addition to

17 the decision to set up the Serbian municipality of Hadzici, other organs

18 of authority were elected, such as the president of the municipality and

19 the chairman of the Executive Board, and I think that the Assembly at the

20 same time endorsed my appointment to the position of the chief of the

21 police station or the SJB Hadzici.

22 MS. EDGERTON: Thank you.

23 Could this be a Prosecution exhibit, please, Your Honours?

24 JUDGE KWON: Yes.

25 THE REGISTRAR: P2297, Your Honours.

Page 11778

1 MS. EDGERTON:

2 Q. Mr. Glavas, do you recall the function of this working body?

3 What did it do?

4 A. Well, their function was similar to any other body, so somebody

5 had to preside over this assembly, and they chaired over this meeting as

6 a sort of working body.

7 Q. Where were the municipality offices located?

8 A. In the municipal building, which is in down-town Hadzici.

9 Q. And in answering that question, are you referring to the offices

10 of the Assembly of the Serbian Municipality of Hadzici or pre-war?

11 A. No. No, that's not what I meant. If we're still talking about

12 the All-Serbian Assembly, then the premises were in -- on the ground

13 floor of the sports centre in Hadzici where this meeting took place, not

14 in the municipal building.

15 Q. Did they remain in that location?

16 A. Yes.

17 Q. And did they remain in that location throughout your time working

18 in Hadzici?

19 A. I did not understand your question.

20 Q. Did they remain in that location between April and August of

21 1992?

22 A. Oh, yes, yes.

23 Q. Now, just relating to premises: In your written evidence, at

24 paragraph 7, you refer to the establishment of the police force and

25 indicate that you went to some provisional premises in the cultural

Page 11779

1 centre.

2 And in that regard, I'd like to look at 65 ter 01439.

3 Now, Mr. Glavas, do you recognise the image on the screen in

4 front of you?

5 A. Yes, I do, only you did not put your question correctly. You

6 said "cultural centre." That was the workers' club that was owned by the

7 former maintenance and repair centre of Hadzici. So it's on the

8 right-hand side of the picture, this building here [indicates]. This is

9 the building where the -- where the Security Centre was. Do I need to do

10 it now again?

11 MS. EDGERTON: No, I think that's fine. Thank you.

12 If this could be a Prosecution exhibit, please.

13 JUDGE KWON: Yes.

14 THE REGISTRAR: Exhibit P2298, Your Honours.

15 MS. EDGERTON:

16 Q. Did the police forces remain in this location between April and

17 August of 1992 or did they relocate during this period?

18 A. No, they did not remain until August. They stayed there for a

19 while. I cannot remember exactly when was it that we moved to other

20 premises in Hadzici.

21 Q. What other premises did you move to?

22 A. This was mainly the ground floor in the municipal building of

23 Hadzici.

24 Q. Thank you.

25 A. You're welcome.

Page 11780

1 Q. Now, I'd like to move on to another area relating to your

2 testimony in the Veselinovic case, and that's the Crisis Staff. You

3 discussed the Crisis Staff in a number of areas, and in the Veselinovic

4 case you describe the Crisis Staff as the highest organ of authority in

5 the Hadzici municipality. Do you recall that?

6 A. Yes, I remember that clearly.

7 Q. What did you understand, then, to be its competencies or its

8 authority? What's the basis of your answer in that regard?

9 A. Well, under such circumstances during wartime or during an

10 immediate threat of war, a crisis staff is formed, and it has all the

11 powers relating to civilian police and other affairs. So, practically,

12 they assumed the role of both the executive and legislative organ.

13 Q. Do you recall when the Crisis Staff in Hadzici municipality was

14 formed?

15 A. In April of 1992.

16 Q. Who were its members?

17 A. Members of the staff were people who were elected to certain

18 positions, such as the president of the municipality, the chairman of the

19 Executive Board, the representative of the police, which was yours truly

20 because I was the chief of police at the time, there was a military

21 representative as well, and in this particular case such as Hadzici, we

22 had representatives of the management of the military facility, which is

23 maintenance and repair centre, because that institution played a

24 significant role before the war and also during the war. For that

25 reason, their presence on the Crisis Staff was required as well.

Page 11781

1 Q. Was there -- how was it -- how was it established? Was there an

2 initiative that you recall?

3 A. Well, I think that it happened immediately after the All-Serbian

4 Assembly that I mentioned earlier and as a result of the overall complex

5 security and political situation in the area. It was a well-known fact

6 that co-operation between representatives of the Serbian-Bosniak

7 authorities was not very good, so the Serbian people stated at the

8 Assembly that they should organise themselves, and which was followed by

9 the initiative to set up the Crisis Staff by the people who I mentioned

10 in my previous answer.

11 Q. Did it have any premises that it kept to itself? Where was it

12 located?

13 A. Yes. In the municipal building, there was a conference room

14 where we met on most occasions and took decisions related to certain

15 situations in the municipality of Hadzici.

16 Q. How often did it meet?

17 A. Well, you know, every morning, a meeting would be held, but I

18 wouldn't call these official meetings. This was, more or less, briefing

19 sessions. People who were in charge of certain areas would provide

20 feedback information to the Crisis Staff. However, if there was a need

21 prompted by the information gathered on the ground, then we would meet

22 officially. So, basically, we met every day, but the decisions that were

23 relevant for the military and civilian, or other affairs, we would

24 discuss such decisions before taking them.

25 Q. Did you attend these meetings?

Page 11782

1 A. Yes, I did.

2 Q. You've just said that the meetings were daily. Did you attend

3 every day?

4 A. No, I did not attend every day, because at the time I had a

5 commander of the police station who, by virtue of his position, could

6 replace me. So, actually, the commander was the one who went to most

7 meetings, but I am not exonerating myself from whatever was said at the

8 Crisis Staff. And there was a way for me to find out what was being

9 discussed.

10 Q. And what was that?

11 A. When I was at the SJB while he attended the Crisis Staff

12 meetings, he would come back and he would regularly inform me about the

13 topics that were discussed on the Crisis Staff.

14 Q. And what was his name?

15 A. His name was Brane Mijatovic.

16 Q. What about the decision-making process? Did the Crisis Staff

17 require your presence, as police chief, to take decisions?

18 A. Of course, but I said that the commander could stand in by virtue

19 of his position. So it was irrelevant who of the two of us would attend.

20 However, the decisions by the Crisis Staff were taken through the

21 following procedure: We would obtain certain information of interest for

22 the Security Service as well as intelligence that was of interest for the

23 military, and depending on the content of this information, if it

24 affected public security, which means domestic issues and the rear of the

25 territory, this decision was usually taken by the police chief's station,

Page 11783

1 that is, me, whereas all the other military aspects were taken care of by

2 the army. The decisions were taken and would be given to me at the

3 Crisis Staff meeting.

4 In my testimony in the Veselinovic case, I outlined the

5 organisational structure of the SJB, which consisted of a number of

6 organisational units, and one of the most important ones was the police

7 station that had a crime prevention and investigation unit. As the

8 chief, based on the decision I received, I decided which of my employees

9 would implement this decision. If it had to do with crime, I would give

10 it to that particular unit. If it had to do something with regular

11 police work, I would put my initials on the decision and pass it on to

12 either the commander or any other head of any other organisational unit.

13 So that was the organisational structure, more or less.

14 Q. What form were these decisions -- Crisis Staff decisions made in?

15 Were they in writing or were they orally? How were they communicated?

16 A. For the most part, they were in writing, because the Crisis Staff

17 was in a position to make very important decisions at the time. You know

18 what the situation was. It was very complex, from the point of view of

19 the safety and security of citizens. So, in principle, such decisions

20 were made in writing, and they were submitted in the way that I've

21 already described.

22 Q. I'd like to talk now about the implementation of some of these

23 decisions and refer to parts of your written evidence in that regard.

24 For example, at paragraph 26 of your written evidence, you said

25 that you didn't know for a fact who made the order to collect

Page 11784

1 military-aged Bosniaks in the sports hall, but you assume, like other

2 decisions, it came from the Crisis Staff, as no other body had the

3 authority to make that decision. Do you remember that?

4 A. That's right, I do remember that very well.

5 Q. So who implemented this decision, then? Who carried out this

6 decision?

7 A. If you are referring specifically to taking people into

8 detention, it was done by the regular police and Territorial Defence.

9 Q. Now, also in your written evidence, you said that it was the

10 Crisis Staff's decision that the detention facility at the sports centre

11 should be under the military or the Territorial Defence. Do you remember

12 that?

13 A. I do, and I stand by that.

14 Q. So was that, then, the case? Did the military or the

15 Territorial Defence control the sports centre?

16 A. Yes. I'll try to explain certain things as briefly as possible

17 now.

18 For certain reasons for which citizens were being taken in,

19 primarily citizens of Bosnian ethnicity, was the reason that we had

20 reliable information to the effect that they had long rifles. First,

21 these people would be interviewed by the Crime Prevention Service. After

22 these interviews, these persons would be transferred to the cultural and

23 sports centre. From this point of view, I really cannot explain why it

24 was under the military, the cultural and sports centre, but I'm going to

25 tell you what I've already said to you in Sarajevo.

Page 11785

1 I remember exactly the names and surnames of the people who were

2 guarding this sports facility, and I remember Trifko Ignjatovic; Milovic,

3 Rade; Milovic, Momo; Duka, Radovan; and others. All of them were members

4 of the Territorial Defence, and I claim that in this way, the sports

5 centre was practically never under the Security Service or, rather, the

6 station that I was at the time, at least for as long as I was in Hadzici.

7 Q. These people you just named, do you recall who they were

8 subordinate to? Who was their commander at that time?

9 A. Someone from these formations, but I don't know the exact name or

10 surname.

11 Q. Your written evidence, you also said that on 22 June 1992, the

12 majority of detainees at the sports centre were transferred to Kula, and

13 you thought that this was on the order of the Crisis Staff. And I'd like

14 to know on what basis you think that.

15 A. Well, because I was aware that decisions at the level of the

16 municipality of Hadzici, including such a decision, could -- couldn't

17 have been made by anyone but the Crisis Staff.

18 Q. Do you know how the prisoners were moved?

19 A. I don't know exactly, and I'll explain why.

20 It just so happened that sometime from the 18th until the 20

21 something of June, I was away. I went to visit my family in Serbia. And

22 when I contacted my commander by telephone, of course, I asked him what

23 was going on at the station that he and I headed together, and he told

24 me, inter alia, that the entire Bosniak population that had been detained

25 at the sports centre was transferred to Kula. To tell you the truth, my

Page 11786

1 reaction was that I was not in favour of that kind of thing. Quite

2 simply, I knew that if these people left, if they were no longer under

3 the Serb authorities in Hadzici, then somebody else will be deciding on

4 their exchange. And that is basically what happened. Some of these

5 people were exchanged, but that was not the situation in each and every

6 case. They were exchanged for the Serb population that was detained in

7 Tarcin or, rather, the silo. After that, we had some terrible problems.

8 We were under enormous pressure by citizens of Serb ethnicity who

9 were aware at the time that they would be in a very, very difficult

10 position, that it would be very hard for them to get their own people out

11 of the silo and the elementary school in Pazaric. That is where they

12 were detained. And, indeed, it was very hard to get people out of these

13 collection centres where they were detained.

14 Q. When you were briefed by your commander as to what happened, did

15 he tell you -- when you were briefed by your commander about the

16 transfer, did he tell you who had authorised the transfer?

17 A. Yes. Yes, I remember that I asked him specifically who gave this

18 order, and he said, Ratko Radic, commander of the Crisis Staff.

19 Q. When you say the majority of the people in the sports centre were

20 transferred, in fact, you just said the entire population that had been

21 detained in the sports centre was transferred, do you have any idea what

22 number of people that represents? How many were transferred to Kula?

23 A. Well, I'm not sure. I think it may be between 180 and 200

24 persons. I'm not sure of that particular bit of information, that it is

25 unequivocally correct.

Page 11787

1 Q. Thank you. Just to move on, but still on the theme of the

2 decision-making or the implementation of decisions: You described, at

3 length in your testimony in the Veselinovic case, the operation by police

4 forces in Musici settlement for the seizure of weapons, and I'd like to

5 know under whose decision that operation was carried out.

6 A. Absolutely, it was the decision of the Crisis Staff.

7 Q. And how do you know?

8 A. Well, quite simply, I know what the practice was at the time. I,

9 as the chief of the station at the time, I quite simply could not have --

10 although I had certain knowledge, I could not have organised any action

11 that was of interest from the point of view of the service I headed if I

12 did not have an appropriate decision of the Crisis Staff. That is one

13 thing. And, secondly, the situation was very difficult at the time, it

14 was a time of great uncertainty, and people were very reluctant to take

15 upon any kind of responsibility.

16 At the time, as a person, on a personal level, I wanted to have

17 it black on white, as our people say. I wanted to have a decision in

18 writing before I went out and did anything.

19 Q. And, finally, in paragraph 41 of your written evidence, still

20 relating to the incident at Musici, you said that you were informed that

21 the weapons seized during the course of that operation were divided, on

22 the decision of the Crisis Staff, and redistributed to members of the

23 police or the military. How do you know that this was done on the basis

24 of a decision by the Crisis Staff?

25 A. We couldn't have done it just like that. It had to be a decision

Page 11788

1 of the Crisis Staff.

2 MS. EDGERTON: Thank you. I'd like to move on now to a couple

3 more photographs, the first being 65 ter 01436.

4 Q. Mr. Glavas, did you see this photograph yesterday in preparation

5 for your testimony here today?

6 A. Yes.

7 Q. Do you recognise it?

8 A. I do. I don't know if you can see it here on your monitors, but

9 this is the sports centre [indicates], and on the left we see the

10 elementary school in Hadzici [indicates].

11 Q. Is it similar to how it appeared, to your recollection, in 1992?

12 A. Well, I think so. I think that's about it. That's what the

13 sports centre looked like.

14 MS. EDGERTON: Could that be the next Prosecution exhibit,

15 please?

16 JUDGE KWON: Yes.

17 THE REGISTRAR: Exhibit P2299, Your Honours.

18 MS. EDGERTON: Now, could we move on to 65 ter 01437, please.

19 Q. Mr. Glavas, did you see this photograph in preparation for your

20 testimony here today?

21 A. Yes, yes.

22 Q. What does it represent, then? Do you recognise what's depicted

23 in this photograph?

24 A. Well, I said yesterday that this is roughly the left wing of the

25 municipality building. What you see down there are the garages. Sorry,

Page 11789

1 this is what I meant [indicates]. That's the garages.

2 MS. EDGERTON: The witness is indicating, with the cursor, the

3 three doors at the bottom of the photograph when he describes the

4 garages.

5 Q. Now, Mr. Glavas, you've said this is the left wing of the

6 municipality building, and I'm wondering if you could tell us where, in

7 this building, the conference room that you described earlier is located.

8 A. I can't. I cannot orient myself on the basis of this photograph.

9 Do you think you could zoom out a bit, and then if I see the entire

10 building --

11 MS. EDGERTON: If I could have this marked as a Prosecution

12 exhibit, we could go, probably, to a better photograph.

13 JUDGE KWON: Yes.

14 THE REGISTRAR: Exhibit P2300, Your Honours.

15 MS. EDGERTON: Thank you.

16 Could we try 65 ter 01438, please. Thank you.

17 Q. Mr. Glavas, do you recognise what's depicted on this photograph?

18 A. Yes. This is the municipality building, and this part

19 here [indicates] is what I saw on the first photograph. This was the

20 main part [indicates], and this is where the entrance was. And the hall

21 that we talked about a few minutes ago should have been somewhere around

22 here [indicates].

23 Q. I'm sorry. If I could just get you to slow up for a minute.

24 When the witness indicated the main part, he pointed, with the

25 cursor, to an entryway above a white car that was shown in the photo.

Page 11790

1 And I didn't see, Mr. Glavas, where you went with the cursor when

2 you mentioned the hall we talked about a few minutes ago.

3 A. I've already said that it should be somewhere around

4 here [indicates].

5 MS. EDGERTON: Indicating a set of three windows on the second

6 floor above the garages on the bottom.

7 Q. Now, while we have this photo on the screen in front of us: You

8 mentioned also that eventually the police services were relocated to the

9 ground floor of the municipality building. And where, please, were the

10 police services located? Could you show us on this photograph?

11 A. That's right. I indicated a moment ago that this was the

12 entrance [indicates]. And this on the left here, these two windows,

13 that's where our duty offices were [indicates], if I can put it that way.

14 That's where our duty police officer was, the one who checked people

15 coming in and out of the building. You cannot see the rest of the ground

16 floor of this building where our offices were. We did not have very many

17 offices, but they were basically there on the ground floor.

18 MS. EDGERTON: I wonder, would it help Your Honours, for the

19 witness to circle these locations so we could be abundantly clear?

20 JUDGE KWON: Yes.

21 MS. EDGERTON: And perhaps he could have some help.

22 Q. So, then, Mr. Glavas, could you mark, with a circle and a

23 number 1, the location of your police services and the duty officer's

24 post that you've just indicated?

25 A. Very well. Well, I don't know if it's necessary for me to mark

Page 11791

1 this. Well, let it be number 1 [marks]. So this is the entrance to the

2 building. Then the window here on the left-hand side, number 2 [marks],

3 that was the window of the room that was relatively small, and basically

4 that was the room where our duty police officers were who were checking

5 people coming in and out of the building. And now number 3 [marks], you

6 cannot see the interior, but basically on the ground floor, that is where

7 the offices of the Public Security Station of Hadzici were.

8 Q. And can you mark with the number 4 the location of the conference

9 room where you recall the Crisis Staff holding their meetings?

10 A. [Marks]. That's it.

11 Q. Thank you. Now, does this building resemble -- to the best of

12 your recollection, does this building on the photograph appear as it was

13 in 1992?

14 A. Yes [as interpreted].

15 Q. I believe you said, No, rather than, Yes. Isn't that correct?

16 A. I said that this is not what it looked like in 1992.

17 Q. And what's different?

18 A. Well, it wasn't devastated, which is what it looks like now.

19 Q. Other than the damage that you've seen, are -- no, I think that's

20 fine.

21 Could that be the next Prosecution exhibit, please, Your Honours?

22 JUDGE KWON: Yes.

23 [Trial Chamber and Registrar confer]

24 JUDGE KWON: While we are admitting it: Mr. Glavas, could you

25 kindly put the date and your signature on this picture, on the right

Page 11792

1 bottom? Today is the 14th of February, 2011.

2 THE WITNESS: [Marks]

3 JUDGE KWON: Thank you.

4 THE REGISTRAR: Exhibit P2301, Your Honours.

5 MS. EDGERTON: Thank you.

6 Before we remove that from the screen, just one more question

7 about these garages, Mr. Glavas.

8 Q. In your written evidence, at paragraphs 53 and 54, you referred

9 to people of Bosniak ethnicity being held in the garage below the

10 municipality building. Does this photograph depict the garage that you

11 refer to?

12 A. Yes.

13 JUDGE KWON: You would like to mark that garage on the previous

14 photo? Yes. Why don't you up-load P2301.

15 MS. EDGERTON:

16 Q. Perhaps you can mark that garage with the number 5.

17 A. [Marks]. That's it.

18 MS. EDGERTON: Now, can that still be P2301?

19 JUDGE KWON: Yes, that will be kept as it is.

20 MS. EDGERTON: Thank you.

21 Q. Mr. Glavas, how many people were held in this garage at the time

22 you referred to?

23 A. I think that it would be about 30 people. I have to say that as

24 for the people who were in this garage, if you remember, I mentioned

25 persons of Bosnian ethnicity who were brought in and interviewed. It's

Page 11793

1 that category of people who had been interviewed. People like that were

2 detained in these garages - how should I put this? - because it was

3 nearby. Our premises were in the municipality building. Then after the

4 interviews, such persons would be transferred to the sports centre, and

5 practically, then, they would be kept there by the Territorial Defence

6 or, later on, the army.

7 Q. Do you know where these 30 people came from?

8 A. I think that it was mostly people from Muslic and Visasoci

9 [phoen], and then some from Binjezevo [Realtime transcript read in error

10 "Bicevo"] and some from Kuciste. That's a hamlet near Hadzici.

11 Q. On the transcript, it says "Bicevo." Do you mean Bicevo or do

12 you mean Binjezevo?

13 A. Binjezevo.

14 Q. Thank you. Now, just to move on to another area: In

15 paragraph 19 of your written evidence, you referred to your conflicts

16 with the political leadership in Hadzici and, to a certain extent, the

17 military, saying that the political leadership didn't want to follow

18 correct police procedures at that time. And you also mentioned something

19 similar during your testimony in the Veselinovic case, which appears at

20 paragraph 20 of your written evidence. You said you had certain

21 disagreements with the people who governed the politics of both the

22 police and army personnel back then. Do you remember that?

23 A. Yes, I do.

24 Q. Who do you mean to refer to when you refer to these people?

25 A. Well, I was primarily referring to the political leadership,

Page 11794

1 headed by Mr. Ratko Radic.

2 Q. What was the nature of your disagreements?

3 A. Well, when I testified in the Veselinovic case, I said that I am

4 your classical professional; that is to say, that I completed the regular

5 School For the Interior, in the meantime I studied part-time while

6 working, and I learned everything I knew in that area in that way.

7 Everything I did on the basis -- I did on the basis of rules and

8 regulations. However, that met with resistance, and some people at the

9 time were calling me names. They said I was a formalist.

10 You know, these were very complex times, very complex, from the

11 point of view of security and politics in that area. They thought that

12 certain things had to be done in haste. However, people were well aware

13 that I spent a lot of time out in the field with my policemen, because,

14 as I said, the situation was extremely difficult. We spent a lot of time

15 at the defence lines initially. We did that more than our regular police

16 work. I would stay out until 2.00 or 3.00 or 4.00 at night, and I mainly

17 went to spend the night at my aunt's place because I didn't dare go to my

18 own apartment in Hadzici.

19 At the beginning of the war, they opened fire at my apartment, so

20 I didn't really want to go there. They criticised me, why I did not go

21 to Crisis Staff meeting, and practically at the time these Crisis Staff

22 meetings boiled down to some formalities, if I can put it that way, and

23 that is basically why I clashed with them. I simply thought that there

24 was no need for me to attend every day, especially because I spent a lot

25 of time on the ground with the police.

Page 11795

1 At the time, my position, and I must say of all the police and

2 part of the military, was that the priority was to defend the area of

3 Hadzici and preserve it. How can I attend Crisis Staff meetings if we

4 lose our positions in the field? There was ongoing activity, day in, day

5 out, and we were under threat. We almost lost our positions. And that

6 is why I clashed with them.

7 So I worked out a compromise with Mr. Kovac. I agreed to leave.

8 And, as I've already said, sometime around the 6th of August, I went to

9 Ilidza.

10 MS. EDGERTON: Your Honours, I realise we were sitting on a bit

11 of a different schedule today, but I was just looking at the time and I

12 wondered -- I hadn't heard Your Honours say anything about when we might

13 break, and I thought I might raise it at this moment.

14 JUDGE KWON: I was waiting for a go from the Registry.

15 [Trial Chamber and Registrar confer]

16 JUDGE KWON: We'll have a 20-minute break at 10 to 1.00. That

17 means we will have two 80-minute sessions. Thank you. Let's go on until

18 10 to.

19 MS. EDGERTON: Certainly. Thank you.

20 Q. You talked about Mr. Radic a few minutes ago, and I'd like to ask

21 you a few questions about him now.

22 In his capacity as Crisis Staff head and head of the Serbian

23 municipality of Ilidza, was he subordinate to any organ or individual?

24 A. What do you mean?

25 Q. Did Mr. Radic, in his function, have someone that he needed to

Page 11796

1 report to?

2 A. I think that the Crisis Staff in every municipality, including

3 Hadzici, acted independently, and I said earlier that it was authorised

4 to take all the decisions relating to the area of their responsibility,

5 so to speak.

6 Q. In the course of -- did Mr. Radic have any contact, to your

7 knowledge, with any members of the Bosnian Serb political leadership?

8 A. Yes.

9 Q. With anyone in particular?

10 A. Well, he often told us that he met President Karadzic.

11 Q. And did he say why?

12 A. I cannot remember at the moment. But, on the other hand, I

13 clearly remember that if it was necessary for him to put some of his

14 ideas into practice, he would often refer to Dr. Karadzic and claim that

15 he had agreed with him on certain things.

16 After a while, I gained an expression [as interpreted] that he

17 was misinforming us or, rather, abusing his contacts with Dr. Karadzic.

18 However, due to the fact that he was so keen to implement his ideas, he

19 would say that he had discussed and agreed to those things with

20 Dr. Karadzic.

21 MS. EDGERTON: Thank you.

22 Your indulgence for a moment.

23 Q. When you say he was misinforming you, what do you mean?

24 A. Well, if you recall, in my statement that I gave in Sarajevo,

25 I think that I mentioned a rather unpopular expression attached to the

Page 11797

1 president of the municipality. I called him a person who was prone to

2 manipulations. So I think that he was capable of presenting the

3 situation in Hadzici to Mr. Karadzic in such a way that was untruthful.

4 He would say one thing to us, and he would be doing something completely

5 different.

6 Q. Can you give us an example?

7 A. An example of what?

8 Q. You've just said you think he was capable of presenting the

9 situation in Hadzici to Mr. Karadzic in such a way that was untruthful.

10 He would say one thing, and he would be doing something completely

11 different. What do you mean by that?

12 A. I think that in one of my statements, I said, inter alia, that he

13 would portray one situation to us, believing that we would receive

14 assistance from outside, but then the next moment, when the situation was

15 at its worst in Hadzici, when everything was on fire, Mr. Ratko Radic was

16 nowhere to be seen, he was absent from this area. And I'm telling you

17 the truth, and the entire public shares this opinion with me, the public

18 of Hadzici. He was away, either with his family in Belgrade or at Pale,

19 as he later said.

20 Q. Thank you. Now, you indicated that you moved to Ilidza in August

21 of 1992. Did you hold a similar position in the Crisis Staff, when you

22 transferred to Ilidza, to the one you had occupied in Hadzici?

23 A. Yes.

24 Q. Who was a member of the Crisis Staff in Ilidza?

25 A. It also involved functions; only different people were involved.

Page 11798

1 The president of the Crisis Staff was a man whose name I cannot remember.

2 There was a man called Lalovic, who was the chairman of the

3 Executive Board. There was a representative of the police and a

4 representative of the military as well.

5 Q. Who was the municipality head in Ilidza at the time you served

6 there?

7 A. Nedjeljko Prstojevic.

8 Q. Did he occupy a function on the Crisis Staff?

9 A. I said he was the Crisis Staff commander or Crisis Staff

10 president.

11 Q. Oh, I'm sorry. The transcript, Mr. Glavas, read:

12 "The president of the crisis staff was a man whose name I could

13 not remember."

14 That's why I asked you that question.

15 Did you attend meetings of this Crisis Staff?

16 A. Are you referring to the Ilidza Crisis Staff?

17 Q. Yes.

18 A. Very seldom, and I will try and explain why.

19 I came there in August, and up until October, to be precise, by

20 the 21st of October, 1991, I did not discharge the duties of the chief.

21 Consequently, I was not a member of the Crisis Staff. At the time, I was

22 the assistant chief rather than the deputy chief.

23 On the 21st, I was appointed chief of the station, and I have to

24 say that at that time already, we very seldom attended Crisis Staff

25 meetings for a simple reason: that at the time, we were already organised

Page 11799

1 in such a way that we were more connected with the Ministry of the

2 Interior, which involved receiving instructions and orders from them

3 rather than from the local level.

4 Q. Where was the Crisis Staff in Ilidza located?

5 A. It was a separate room for meetings in the municipal building,

6 and that is where the meetings were held.

7 Q. And how often did they meet?

8 A. I cannot tell you now. I know that initially there were much

9 more meetings in Hadzici. I cannot remember clearly. I think I attended

10 a couple of meetings in Ilidza only, because at that time certain things

11 started to fall into place with respect to politics, army and police. A

12 sort of rule of law started to be introduced. So we, as members of the

13 Public Security Department, who were in charge of maintaining public law

14 and order, did not have any particular need to meet quite often with the

15 municipal authorities. Moreover, the Security Department was structured

16 in such a way that we had stronger ties with the minister of the interior

17 than with the local communities. The leaderships of local communities

18 could only give an opinion or a suggestion, for example, concerning my

19 appointment. However, the minister of the interior was not obliged to

20 take that opinion into account, and it was up to him to appoint the chief

21 of police as his discretionary right.

22 As members of the Security Department, our duty was to keep the

23 local authorities abreast of the things that were security-related, but

24 only in the area that we covered.

25 Q. Now, in your written evidence, at paragraph 69, you describe your

Page 11800

1 relationship with Mr. Prstojevic, and you noted that he was quite

2 arrogant, and you had an argument on the phone with him and told him that

3 you were responsible for security in Ilidza and he was in charge of

4 politics, and that after that conversation, Prstojevic started asking you

5 advice, rather than giving you orders. Do you remember that?

6 A. Yes, I do.

7 Q. You said he asked you if you could send police officers for this

8 and that, but before, he used to order you to do this; not only to send

9 police to military operations being conducted, but trying to assign

10 police officers in the military for his own uses?

11 A. That's correct.

12 Q. Was that not a function, though, of his position as head of the

13 Crisis Staff, as you've described him?

14 A. Well, yes, that was his position, but I am talking about the

15 initial period when the service was organised in a different way, as

16 opposed to the one that I just described. We were more and more in the

17 position that when it involves affairs relating to public security, we

18 would follow the instructions of our management from the Ministry of the

19 Interior. So, practically, I was not duty-bound, even under the law, to

20 inform him about certain things, with the exception of the things that

21 explicitly related to the municipality of Ilidza.

22 Q. Just one more point of clarification. Where you said you're

23 talking about the initial period when the service was organised in a

24 different way, how was it organised, how was it different?

25 A. What I meant was that there was no link between the top

Page 11801

1 leadership in the Ministry of the Interior and the grassroot level, such

2 as police station, in Hadzici and elsewhere. So under such

3 circumstances, both the citizens and the leadership, and we, as well,

4 thought that we were left to our own devices entirely, and we had, by the

5 nature of things, to deal more with the Crisis Staff during that period

6 than was the situation at a later stage.

7 MS. EDGERTON: Your Honours, I think that covers the 20 minutes

8 that you had indicated.

9 JUDGE KWON: Very well.

10 We'll have a break for 20 minutes and resume at 1.10.

11 --- Recess taken at 12.48 p.m.

12 --- On resuming at 1.12 p.m.

13 JUDGE KWON: Yes, Ms. Edgerton.

14 MS. EDGERTON: Thank you.

15 Q. Mr. Glavas, before we move on, I'd actually like just to go back

16 to the discussion that we were having about the transfer of prisoners

17 from the sports centre to Kula on June 22nd.

18 Now, that journey from Hadzici to Kula would have been a journey

19 of many kilometres; correct?

20 A. Yes.

21 Q. And that journey crossed the boundaries of more than one

22 municipality; correct?

23 A. That's correct.

24 Q. And I'm willing to bet it would have involved crossing any number

25 of check-points as well. Correct?

Page 11802

1 A. Correct.

2 Q. So what I'd like to know, given all that, is: What level of

3 co-ordination between what organs and authorities would have been

4 required for the detainees to make that journey?

5 A. There could be co-ordination at the level of the municipalities

6 between which the transport of these detainees took place.

7 Q. Would the military authorities not have been involved, given that

8 check-points would have had to have been crossed?

9 A. Of course. That that was mainly done by the military

10 authorities.

11 Q. So what organs would have involved in ensuring that journey came

12 to an end? What organs would have been involved to make sure that

13 journey took place as planned?

14 A. The situation was such that due to some other reasons and

15 security-related issues, and the ties between the area in the Serbian

16 Sarajevo, presidents of the municipalities, who at the time were actually

17 presidents of Crisis Staff, communicated very frequently in order to

18 carry out certain operations. I assume that on this occasion, too, an

19 agreement was reached between the competent presidents of the crisis

20 staffs, which finally led to the transportation of these detainees. But

21 please bear in mind that I'm giving you general descriptions. I said

22 before that I was not there when these detainees were transferred to

23 Kula, and I kindly ask you to take this into account.

24 Q. Thank you. We'll move on to one final area, and it's a decision

25 about paramilitaries in Ilidza, which begins at paragraph 71 of your

Page 11803

1 written evidence.

2 First, to your knowledge, was Mr. Prstojevic aware of the

3 presence of paramilitaries in Ilidza?

4 A. Yes.

5 Q. And how do you know that?

6 A. Well, I know that he knew about the existence of those

7 paramilitary formations. When I moved to Ilidza, the commander of the

8 police station, Vlatko Knezevic, was on extremely good terms with

9 Mr. Prstojevic, and I received a lot of information from him. That's how

10 I know that he knew about the paramilitary. But that was common

11 knowledge at the time. It was no secret that there were paramilitary

12 groups.

13 Q. Now, you also said that with respect to the unit of

14 Branislav Gavrilovic, that they fought at the airport settlement, Doglodi

15 and Otes. Do you remember that?

16 A. Yes.

17 Q. Can you date, approximately, these operations at the airport

18 settlement, Doglodi and Otes?

19 A. Doglodi and Otes could have happened sometime in August of 1992.

20 I remember that because that was about the time when I went to Ilidza,

21 when this action was carried out, so that would be approximately the

22 month and the year.

23 Q. Could the operation in Otes you're referring to have taken place

24 as late as December of 1992?

25 A. It is possible, it is possible, but I do know and I am personally

Page 11804

1 familiar with that action because I was in Ilidza at the time. As I

2 said, I was there from the 6th of August until I was appointed chief in

3 October, so it's possible that this action took place in the month that

4 you mentioned.

5 Q. How did you know that they took part in these operations? And I

6 notice you haven't given us a date for the airport settlement.

7 A. The operation of --

8 THE INTERPRETER: Interpreter's note: Could the witness please

9 start the answer from the beginning.

10 JUDGE KWON: Mr. Glavas, the interpreters couldn't hear you, so

11 could you repeat your answer.

12 THE WITNESS: [Interpretation] I will do so.

13 So the operation relating to the airport settlement would --

14 definitely took place before the operation in Otes, and I remember that

15 because at the time when the airport settlement operation was in

16 progress, Mr. Tomislav Kovac was in Ilidza, and I succeeded him, and

17 that's the reason why I know that this operation took place earlier.

18 Q. In your written evidence, you said that this unit had private

19 political connections to go into these areas, that they were not on

20 police or military orders. What do you mean by that?

21 A. What I wanted to say was that the manner in which paramilitary

22 formations could have come to a certain area, including the area of

23 Hadzici, was such that it was based on friendship and other forms of

24 relationships, so there was no need for any subordination or co-operation

25 with state leaderships or organs. So that is the way in which certain

Page 11805

1 paramilitary formations were brought to certain municipalities, based on

2 friendship.

3 Q. When we talk about the airport settlement, Doglodi and Otes,

4 would you agree with me that those were front-line operations?

5 A. I didn't understand completely. What did you ask me about the

6 actions?

7 Q. The airport settlement, Doglodi and Otes were combat operations

8 on the front-line, were they not?

9 A. That's right.

10 Q. What kind of political connections would have -- would these

11 units have had to go into these areas, areas of military control?

12 A. They didn't need to have any other ties or relations, other than

13 those based on personal friendships, for them to come to a certain area.

14 Q. What municipal area or what municipality were Doglodi and Otes

15 found in?

16 A. It's in the area of Ilidza.

17 Q. Do you infer anything about the personal friendships or political

18 connections, then, that they would have had to go into these combat

19 areas?

20 A. Yes, it was possible, based on personal connections. In one of

21 my introductory notes either here or in Sarajevo, I describe the general

22 situation in which it was considered that those people were welcomed

23 under the circumstances. However, very soon we realised that we don't

24 have much use of these men, so as the service and as the political

25 leadership, we came into conflict with these formations due to some of

Page 11806

1 their activities. And as I said before, they practically never wanted to

2 go to separation lines that were located in forests or places like that.

3 They preferred to go to residential areas.

4 Q. In fact, in your written evidence, at paragraph 74 of your

5 amalgamated statement, you said the reason they went into those areas was

6 so that they could steal and loot, and you referred specifically to Otes,

7 Doglodi and the airport settlement. So how do you know that they were

8 stealing and looting in those areas?

9 A. Well, we know that because at the time it was a generally-known

10 thing. At the time, it was a show of force on their part. We had

11 terrible problems. We, as the Security Service, objectively speaking,

12 could not oppose them because they threatened us with weapons.

13 Q. What happened to the loot that they acquired?

14 A. Well, it was basically used for their own purposes. It wasn't a

15 political thing, it wasn't defined in any way. They had these private

16 laws of their own; relationships, too.

17 MS. EDGERTON: Thank you. I'll just -- I'd like to move to one

18 final document, 65 ter 11576, please?

19 Q. Now, Mr. Glavas, in your written evidence you commented

20 extensively on the local group of Seseljevci, led by

21 Branislav Gavrilovic, and the document I'd like to show you now is a

22 letter of approval, dated 9 July 1992, signed by Mr. Prstojevic, allowing

23 Gavrilovic to use the motel facility in Gladno Polje and deserted summer

24 houses in the vicinity for the needs of Serbian volunteer units from the

25 front-lines of the Ilidza MUP.

Page 11807

1 A. Yes.

2 Q. Now, you've already referred in your written evidence to

3 Gavrilovic being headquartered in the Vila Vocnjak in an orchard towards

4 Rakovica. Is this the same -- does this document describe the same

5 location?

6 A. Yes. Gladno Polje is a settlement in the area of Rakovica.

7 Q. And can you explain to us or interpret the reference in this

8 document to the Serbian volunteer units being from the lines of the

9 Serbian municipality of Ilidza MUP?

10 A. I think that I told you yesterday what my comment would be in

11 relation to this document. I'm not contesting its authenticity. I see

12 the name and surname, "Nedeljko Prstojevic," I even see that it's his

13 signature. However, I will never understand the content of this

14 document, because I know with certainty that the ministry never had any

15 paramilitary formations within their establishment. And the date here is

16 the 9th of July, 1992; that is to say, it's the time before I arrived in

17 Ilidza. Perhaps a better explanation would be provided by

18 Mr. Tomislav Kovac, the then chief of police in Ilidza. I really do not

19 know how -- actually, I'm telling you, I'm not contesting the

20 authenticity of the text, of the signature, of the name. But, indeed, I

21 find the content of the document quite unclear.

22 MS. EDGERTON: Your Honours, given the witness's comments with

23 respect to the authenticity of the document, and his confirmation that

24 the location of the headquarters approved for Mr. Gavrilovic corresponds

25 with what he had reported in his written evidence, I'd ask that this be

Page 11808

1 the next Prosecution exhibit, please.

2 JUDGE KWON: Any objection?

3 MR. ROBINSON: No, Mr. President.

4 JUDGE KWON: Thank you. That will be admitted.

5 THE REGISTRAR: Exhibit P2302, Your Honours.

6 MS. EDGERTON: That concludes the examination-in-chief,

7 Your Honours.

8 JUDGE KWON: Thank you.

9 Shall we deal with associated exhibits?

10 So you will be tendering all of them?

11 MS. EDGERTON: Not quite, Your Honours. The ones I -- of course,

12 the ones that have already been admitted, we're not, but I've indicated a

13 number of -- with some comments in this notification, that there are a

14 number of documents we're not seeking to tender.

15 JUDGE KWON: I'm not sure I have the recent notification, so

16 could you name the 65 ter numbers you are tendering?

17 MS. EDGERTON: Yes, I can.

18 65 ter 01638, 11573, 01658, 01642, 01635 -- am I going too fast?

19 01230.

20 JUDGE KWON: Any objections?

21 They will all be admitted and given a number in due course.

22 Yes, we have about an hour. Yes, Mr. Karadzic.

23 Just before you start: Tomorrow morning, we'll begin with

24 another witness, won't we?

25 MR. TIEGER: I wasn't sure exactly how the timing was going to

Page 11809

1 work, Your Honour, but you're right, there is another witness scheduled

2 for tomorrow who, I think, given the allotted time, wouldn't consume the

3 entirety of the day.

4 JUDGE KWON: Thank you.

5 Yes, Mr. Karadzic.

6 THE ACCUSED: [Interpretation] Good afternoon to all.

7 Good afternoon, Mr. Glavas.

8 THE WITNESS: [Interpretation] Good afternoon, Mr. President.

9 THE ACCUSED: [Interpretation] Thank you for having met up with my

10 advisers and with myself briefly. Had we had more time, I'm sure we

11 would have clarified some of the things that remain unclear so that we

12 could move on faster.

13 Cross-examination by Mr. Karadzic:

14 MR. KARADZIC: [Interpretation]

15 Q. I looked at your amalgamated statement only this morning.

16 However, I shall try to put as many questions as possible that require

17 only yes-or-no answers.

18 Do we agree that you were a policeman during the days of the

19 socialist system as well?

20 A. Yes.

21 Q. Do we agree that even in the socialist system, there was this

22 good practice and custom for the commander of the police and for the

23 chief of the police station, as the political boss, do not belong to the

24 same ethnic group; they would invariably be from different ethnic groups?

25 A. Yes, that is absolutely correct. I know, in the former Communist

Page 11810

1 system, there was this parity principal. So if a Bosniak was the

2 number-one man, the number-two man should be a Serb, for instance.

3 Q. Thank you. Do you agree that at the first multi-party elections

4 in 1990, there was not only a change of regime, but also a change of

5 system?

6 A. That's right.

7 Q. You were not a member of any one of these newly-established

8 parties; right?

9 A. I was never a member of any political party from that day onwards

10 until the present. I was only a member of the League of Communists of

11 Yugoslavia.

12 Q. I have to ask you and to remind myself that we should make

13 shorter breaks between our questions and answers so that we do not make

14 life too difficult for the interpreters. So between our questions and

15 answers, short breaks.

16 A. I understand.

17 Q. Do you agree that when the system was changed, people who came to

18 power, especially at local level, were people who had never been in any

19 position of authority before?

20 A. Well, yes, that's the case, for the most part.

21 Q. You said that at some point in one of your statements; for

22 example, that Ratko Radic had been a mechanic, and that later on you came

23 to realise that these people who were in power, even if they wanted to,

24 could not have done any better?

25 A. Yes, that's right. He was a car repairman, that's right.

Page 11811

1 Q. Thank you. After the elections, the Serb Democratic Party left

2 policemen from the previous system at various posts in the police system,

3 although practically none of them were members of the SDS; isn't that

4 right?

5 A. That is the case, absolutely.

6 Q. Do we agree that it's not only that you were not a member of the

7 SDS, but, rather, you were critical towards the new system, you

8 criticised it, but nevertheless you remained in the position that you had

9 held?

10 A. That's right. Already then, I had clashed with the powers that

11 be.

12 Q. Do you remember that the Party of Democratic Action,

13 nevertheless, brought new people to hold these positions, people who had

14 never worked for the police before?

15 A. Yes.

16 Q. Do we agree, and you confirmed that in your interview as well,

17 that towards the end of 1991, there were certain abuses on the part of

18 the Muslims, in terms of staffing within the police force?

19 A. Yes.

20 Q. Is it correct that, for example, in this joint MUP, among 40

21 policemen, there were only a few Serbs?

22 A. Yes. Just a small correction. There were 45 members of the

23 Public Security Station. Out of them, eight were Serbs, also there were

24 three Croats, and all the rests were Bosniaks.

25 Q. Thank you. At the level of the city, at the level of other

Page 11812

1 municipalities in the city, were you aware of even more drastic examples,

2 especially as far as the reserve force was concerned? For example, in

3 the municipality of Stari Grad, they took in about 1.000 reserve

4 policemen, out of which only 30 were Serbs? Not 30 per cent, but 30, so

5 that would be 3 per cent .

6 A. Yes. At the time, I was aware of the situation precisely in

7 Stari Grad. That was the most drastic of all.

8 Q. Was that a source of great trepidation and uncertainty among the

9 Serbs?

10 A. Yes.

11 Q. At your local level and also throughout Bosnia-Herzegovina,

12 although you did not work for the State Security but for the Public

13 Security, rather, did you have any information about other kinds of

14 abuse, about the transport of weapons, about illegal arming, and so on?

15 A. Yes.

16 Q. Do you know the name Senaid Memic?

17 A. Yes, I know the name, because in Hadzici, already in January and

18 February, we had absolutely accurate information about the distribution

19 of weapons by parts of the SDA headed by Hasan Cengic. The gentleman you

20 are referring to was in charge of procuring and distributing weapons for

21 the municipalities within the city; among others, primarily the

22 municipality of Hadzici, where I was first the commander and then the

23 chief of the station.

24 Q. Thank you for that response. I think that in all these

25 statements so far, no one asked you about Cengic, Memic, the

Page 11813

1 Green Berets, the Patriotic League and so on.

2 As a policeman, did you hear from your colleagues that the

3 Patriotic League was being established with its headquarters in each and

4 every municipality, and also with units of their own that had a command

5 structure?

6 A. Yes, we knew that, absolutely, and we knew that one of the ways

7 in which weapons were being procured was precisely through this so-called

8 military wing of the Party of Democratic Action. The Patriotic League

9 grew out of that later. We knew that, absolutely.

10 THE ACCUSED: [Interpretation] Thank you.

11 1D52, can I ask for that, please. That's an exhibit, and we'd

12 like to call it up in e-court. 1D52.

13 MR. KARADZIC: [Interpretation]

14 Q. Do you know or do you agree that Hasan Cengic was a clergyman?

15 A. Yes, I know that.

16 THE ACCUSED: [Interpretation] Could all the participants please

17 cast a glance at this document. Actually, can we have the English

18 version removed for now so that the witness can have a better look at the

19 Serbian version.

20 MR. KARADZIC: [Interpretation]

21 Q. Did you hear in the police that Hasan Cengic, though a cleric,

22 had an important role --

23 JUDGE KWON: Unfortunately, we can't read B/C/S.

24 THE ACCUSED: [Interpretation] I understand. We'll try to remove

25 the Serbian version from e-court and to provide the witness with a hard

Page 11814

1 copy in Serbian.

2 MR. KARADZIC: [Interpretation]

3 Q. Did you find out in the police force that this Hasan Cengic

4 played a very important role among the police, although he was not a

5 policeman, in a very strange way; for instance, that he sent policemen to

6 Croatia for training, Muslim policemen to Croatia, surreptitiously?

7 A. Yes, and not only that. We know, with full reliability, that it

8 was precisely that gentleman, with many of his co-workers, abused

9 official IDs of the former Ministry of the Interior. This was classical

10 abuse, and in that way they procured and distributed weapons.

11 Q. Could you now please have a look at this statement of

12 Senaid Memic from Hrasnica. This statement was given on the 14th of

13 April, 1992, after he was arrested, in proceedings related to the illegal

14 transportation of weapons.

15 I would like to ask all the participants to have a look at this

16 document.

17 Does this correspond with your own knowledge about the activities

18 of this group, especially this man who was arrested and who gave this

19 statement to the state authorities?

20 A. Yes. Just one small addition to this.

21 I don't see a signature here on this document, but I'm sure --

22 judging by the style, I'm more than sure that it must have been someone

23 from State Security in Ilidza. However, I've already said that as for

24 this information that is contained in this document, we already knew

25 about that in Hadzici. I have very, very concrete things that I know

Page 11815

1 that can be linked to this information.

2 Q. Can you give us a few facts that were well known to the police,

3 if not generally known?

4 A. Well, we knew that large-scale arming was already taking place

5 amongst the Muslim Bosniak population in several ways, and one of the

6 ways is the way that is being referred to in this document. Then there

7 was this other way. At the time, they considered that to be legal; that

8 is to say, they increased the number of members of the reserve force.

9 They rapidly increased their numbers, especially in Tarcin. And towards

10 the end of May 1992, these two stations had over 600 members. According

11 to peacetime establishment, these two stations were supposed to have

12 about 100 members, so the increase was six-fold.

13 As for this specific knowledge, we had certain territories in the

14 municipality of Hadzici. However, in view of the fact that the ethnic

15 make-up of that station was as I had already described, I had a

16 relatively small number of policemen, so we could not cover all of that.

17 One day in February 1992, we were chasing each other, literally,

18 all over Hadzici. With the representatives of the Bosniak police and the

19 Bosniak municipal authorities of Hadzici, we had information that lots of

20 weapons were being brought in from the direction of Mostar. We tried to

21 stop that vehicle, and we were obstructed very seriously by our

22 colleagues, so this vehicle escaped in the direction of Mokrin. Mokrin

23 is outside Hadzici, and its population was predominantly Bosniak. Of

24 course, as the then police commander, I informed certain authorities in

25 writing about all of this. So within a day or two, an appropriate

Page 11816

1 commission came to Hadzici of the then City Secretariat of the Interior

2 of Sarajevo, headed by Goran Macar, who at the time was the head of the

3 Police Department, and I know that Mr. Simo Tusevljak [phoen] also came.

4 At the time, he was one of the top operatives in the territory of the

5 city. They interviewed some policemen who were ethnic Bosniaks, and,

6 inter alia, they directly linked my then deputy commander with this;

7 namely, the distribution of that particular contingent.

8 What I'm saying now must be contained in some of the archives of

9 the City Secretariat, and there is a possibility of some traces being

10 even in the archives of the Hadzic Police Station.

11 THE ACCUSED: [Interpretation] Can this document be admitted?

12 JUDGE KWON: Ms. Edgerton?

13 MS. EDGERTON: I think Your Honours have already ruled in

14 previous instances when Dr. Karadzic has endeavoured to tender

15 statements, and I think that this is no different.

16 JUDGE KWON: Even if approved by the witness?

17 MS. EDGERTON: That approval was so vague as to not be of any

18 assistance to anyone. The witness's comment was, if I recall it

19 correctly, one of the methods described in this document, which is a

20 four-page document full of detailed information, so, frankly, we don't

21 know what the witness is referring to or talking about.

22 JUDGE KWON: Yes, Mr. Robinson.

23 MR. ROBINSON: Yes, Mr. President.

24 We disagree. Given this is a 14 April 1992 statement taken

25 during the course of a police investigation, it stands on the same

Page 11817

1 footing as many of the Prosecution exhibits which have been admitted

2 concerning shelling incidents, sniping incidents, which contain accounts

3 from witnesses interviewed during the course of that immediate

4 investigation, and we do think that the witness has more than agreed with

5 the contents of this document and said that it accords with his

6 information and he has additional information. So we think that it falls

7 within your guide-lines and should be admitted, to be given whatever

8 weight you believe it's entitled to.

9 JUDGE KWON: How are we to be satisfied as to the authenticity of

10 this document, Mr. Robinson?

11 MR. ROBINSON: I believe the witness, when he first saw the

12 document, expressed that he could tell from the format of this document

13 that this is exactly material coming from the State Security Bureau, so I

14 believe he's given some weight to its authenticity. And if the

15 Prosecution has any objection to its authenticity or concerns about it,

16 then perhaps that would be more of an issue.

17 [Trial Chamber confers]

18 JUDGE KWON: For the time being, we'll mark this for

19 identification, and we'll come back to this issue very soon in due

20 course.

21 THE REGISTRAR: Your Honour, that will be MFI D1051.

22 MR. KARADZIC: [Interpretation]

23 Q. Mr. Glavas, in order to make it clear for the participants: You

24 mentioned Tarcin, Binjezevo, Pazarici and other places, and the place

25 where this truck loaded with fire-arms escaped. Is it correct that

Page 11818

1 Tarcin, Binjezevo, Pazarici and other places were large neighbourhoods

2 that were parts of Hadzici municipality?

3 A. That's correct, and that applies to all the places that you

4 mentioned. Tarcin, Pazarici, Binjezevo were large settlements, and each

5 such settlement was exposed of a number of villages.

6 Q. Did Tarcin and Pazaric have reserve police stations that grew up

7 to 600 reserve policemen?

8 A. Yes, that's what I said a while ago.

9 Q. Thank you. I just wanted the participants to know that this was

10 happening in your municipality.

11 Is it true that the Serbian part of the police realised that that

12 was a way towards creating a single entity republican army?

13 THE INTERPRETER: Interpreter's correction: Single ethnicity?

14 THE WITNESS: [Interpretation] It was absolutely clear. If I may

15 elaborate.

16 MR. KARADZIC: [Interpretation]

17 Q. Please go ahead.

18 A. In that community, as well as elsewhere in Bosnia and

19 Herzegovina, the Serbs were a minority, so everybody knew that the

20 Bosniak authorities tried to increase the number of reserve police

21 officers as much as possible because, as I said, they perceived it as one

22 of the ways to effect additional arming of their population. On the

23 other hand, through the reserve police force, a comprehensive strategy

24 was implemented, in terms of indoctrinating the reserve policemen, with a

25 view to imparting on them that the only way for the Muslims to remain in

Page 11819

1 a single Bosnia-Herzegovina as a majority, for them to be in a privileged

2 position, but that the main obstacle on the road to that goal would be

3 the Serbs. So they applied this kind of education of the reserve force,

4 and at a later stage they used them as a kind of infrastructure for

5 additional indoctrination of the entire Muslim population and, of course,

6 for procuring additional fire-arms. So this is my interpretation as the

7 root cause of violent conflicts between the Serbian population and the

8 Muslim population, which sparked virtually overnight, and that was due to

9 the indoctrination that I just spoke about.

10 THE ACCUSED: [Interpretation] Thank you very much.

11 JUDGE KWON: Mr. Robinson, going back to the previous document,

12 which is Senaid Memic's statement which we marked for identification -

13 I'm just speaking and asking for myself - if such a statement, a third

14 person's statement, is to be admitted, then will the Prosecution be at

15 liberty to tender hundreds of third-person statements when the witness

16 confirms the content of those statements?

17 MR. ROBINSON: I'm wondering if the Chamber is reading my mind,

18 because I was thinking, myself, that this is a slippery slope that we're

19 going down. On the other hand, the Prosecution has already included, in

20 its exhibits, and already been allowed to admit contemporaneous

21 statements of investigations conducted at the time which relate to the

22 events which are part of this trial, so I think that it has to be

23 decided, perhaps, on an individual basis. But you're correct that it

24 potentially can be damaging to the Defence, as well as beneficial to us.

25 JUDGE KWON: Can you remind me of examples of admitting

Page 11820

1 contemporaneous statement of investigation conducted at the time?

2 MR. ROBINSON: One thing that comes to mind right now is the

3 shelling in Dobrinja of the 1st of June, 1993, when people were

4 interviewed about what kind of shells fell and what calibre they were. I

5 remember an individual named Dinko Bakal [phoen] saying that he found

6 60-millimetre shells at the scene of that Dobrinja incident, and that was

7 contained in the police reports. So that's one that comes to mind

8 immediately, and I think in other shelling incidents, in particular, and

9 perhaps sniping incidents, they are contained in those police reports,

10 interviews of witnesses.

11 JUDGE KWON: Ms. Edgerton.

12 MS. EDGERTON: I'll be able to give Your Honours the exhibit

13 number for that very quickly, but that was contained within an UNPROFOR

14 report investigating the incident and part of the index of supporting

15 material to the ultimate final report.

16 JUDGE KWON: Thank you. We'll come back to that issue.

17 Yes, Mr. Karadzic, please continue.

18 THE ACCUSED: [Interpretation] If I may add, this is not a

19 statement. This document is part of the police investigation process.

20 That would be all.

21 MR. KARADZIC: [Interpretation]

22 Q. Now, sir, is it true --

23 JUDGE KWON: Mr. Karadzic, you are not giving your evidence, so

24 you can call a witness who is able to give what the document is about.

25 Let's proceed. Refrain from making a statement.

Page 11821

1 THE ACCUSED: [Interpretation] Thank you. All I wanted was to be

2 of assistance.

3 MR. KARADZIC: [Interpretation]

4 Q. Is it true that there was another way of arming people? In other

5 words, is it true that in your municipality, the Muslim part of the

6 police force appropriated joint weapons even by resorting to breaking

7 into the depots where these common weapons were kept?

8 A. Yes, that's correct. In late March of 1992, while we were still

9 operating as a single public security station, in which I was the

10 commander, Fado Covic was the chief, and, as I said, in late March of

11 1992, we provided physical security for the central depot of the former

12 Ministry of the Interior in Rakovica, which means that it was within the

13 area of responsibility of my station. The then deputy of mine prepared a

14 rota in which he included only Bosniaks, and this infamous breaking in

15 or, rather, an assault of Rakovica took place that night. The

16 Green Berets came and transported everything that could have been found

17 in that depot, including weapons and police equipment, vehicles, combat

18 vehicles, police cars -- everything was transported across Mount Igman.

19 Since I said that I had a relatively small number of officers at my

20 disposal, was exposed to severe criticism from the people who were in

21 charge of the CSB and the politicians in charge of Hadzici and Ilidza,

22 unfortunately objected. Simply speaking, I could not have done more than

23 I did.

24 Q. Thank you. Is it true that you were the only one -- the only

25 Serb who attended senior staff meetings?

Page 11822

1 A. Yes. Speaking about the inner circle of the senior staff, I

2 attended, but if it was a wider circle, Branislav Mijatovic attended as

3 well. But on most occasions, I was the only one.

4 Q. Is it true that before the police was divided and before the

5 Serbian MUP was formed, the police executives in Hadzici would come

6 alongside, and they were wearing green berets on their head, and you

7 asked them that whilst they were still in the police, they should follow

8 the dress code and dress properly?

9 A. Yes. At the time when the police station was still functioning

10 as a joint institution, I was the commander of that police station. And

11 by virtue of my position, I commanded the entire police force in Hadzici.

12 That refers to members of active-duty policemen and reserve policemen as

13 well.

14 I had the misfortune at the time that all reserve policemen were

15 Bosniaks, and this was particularly prominent with the heads of Tarcin

16 and Pazaric police stations, who, during those turbulent times, came to

17 meetings with green berets on their heads. At one of these meetings, I

18 was very vocal, and I told them that I would not allow them to come to

19 meetings with green berets for as long as I was the commander of the

20 station.

21 Q. Can you confirm for the transcript that the commanders of the

22 reserve force were Bosniaks?

23 A. That's correct.

24 JUDGE KWON: Yes, Ms. Edgerton.

25 MS. EDGERTON: It's all going very fast, Your Honour, and

Page 11823

1 Dr. Karadzic is speaking before the witness's answers are concluded, let

2 alone translated. So I wonder if everybody could be cautioned to slow

3 their pace a bit.

4 JUDGE KWON: Thank you. I'm only amazed by the talents of our

5 excellent interpreters.

6 MS. EDGERTON: Absolutely.

7 JUDGE KWON: Yes. Please put a pause between the question and

8 answers, and please slow down.

9 THE ACCUSED: [Interpretation] Thank you. We owe a lot to our

10 interpreters.

11 MR. KARADZIC: [Interpretation]

12 Q. Is it true that before the depot was robbed, the depot was run by

13 a Serb named Boro who was dismissed from this position before the

14 robbery, i.e., towards the end of 1991?

15 A. Yes, but I have to correct you. When I spoke about the breaking

16 in to the central depot in Rakovica, I have to say that we also had our

17 own internal depot at the level of the police station. It is true that

18 Mr. Boro Suvajlo [phoen] was in charge of all the materiel and equipment.

19 When Mr. Fadil Covic and I took our positions, we found him already

20 there. After these events, the Bosniak police officers started

21 protesting and telling me that they resent the fact that he was a Serb,

22 and that they were afraid that he would be impartial. I offered a

23 solution, and we decided to replace Boro with a Croat. So since they had

24 an objection to this, I tacitly accepted their protest, and we appointed

25 this Croat. However, this was followed by infamous events related to the

Page 11824

1 division of the police force.

2 Q. Thank you. It seems to me that the joint depot was in Hadzici,

3 and the one in Rakovica was at republican level. Actually, it was for

4 the entire MUP of the republic. Right?

5 A. That's right.

6 Q. Thank you. I would now like us to deal with the few things that

7 were, indeed, of a political nature. However, you must have followed

8 them too, and they did affect the police as well.

9 Is it correct that Muslims and Croats were political allies, in

10 view of having Bosnia separated from Yugoslavia?

11 A. You really have to repeat that question.

12 Q. Do you agree that, politically speaking, before the war both

13 Muslims and Croats, or, rather, their leading political parties, were in

14 favour of secession, the secession of Bosnia from Yugoslavia?

15 A. Ah, yes, that is the case.

16 Q. This attempt to establish republican armies through the MUP, and

17 increasing the reserve force, and so on and so forth, did that remind you

18 of the establishment of republican armies in Slovenia and Croatia? Was

19 that the same path that had been taken?

20 A. Yes, the very same scenario, but in a different way, though.

21 Q. But President Tudjman could say, at an early stage, This was the

22 National Guards Corps, right, so that was a type of police as well;

23 right?

24 A. That's right.

25 JUDGE KWON: Ms. Edgerton.

Page 11825

1 MS. EDGERTON: Your Honour, I really think that this is

2 irrelevant.

3 JUDGE KWON: Yes.

4 MR. KARADZIC: [Interpretation]

5 Q. Do you remember that the Serb side accepted, with great

6 difficulty and involving great pains, that Bosnia be separated from

7 Yugoslavia and reorganised?

8 A. Yes.

9 Q. Do you remember that in many municipalities in which conditions

10 were right for that, there were negotiations underway on the

11 reorganisation of municipalities into two; namely, Serb neighbourhoods

12 and Serb parts of that particular town would be a Serb municipality,

13 whereas Muslim neighbourhoods and Muslim parts of town would be a Muslim

14 municipality?

15 A. Yes, I know that, and I can try to demonstrate that using the

16 example of the environment that I functioned in.

17 As for Hadzici, there were several attempts to have agreement

18 reached between the two sides, along the lines that you refer to just

19 now, to carry out a division of the territory - perhaps I could put it

20 that way - as follows: The Serbs would be in charge of the area that had

21 a predominantly Serb population, whereas the areas where there was a

22 predominantly Muslim population would be under their authority.

23 As for Ilidza and the security service there, I know about that.

24 I know that the then head, Edim Livic, and Mr. Tomislav Kovac, who was

25 the police commander, they had agreed that policemen of Bosniak ethnicity

Page 11826

1 carry out work from the domain of our service in the area of Hrasnica and

2 in other predominantly Muslim-populated areas, whereas ethnic Serb

3 policemen carried out the same kind of work in the area of Ilidza, where

4 the population was predominantly Serb.

5 Q. Thank you. Do you remember that on the 18th of March, an

6 agreement was reached, and it is well known as the Lisbon Agreement or,

7 rather, the Cutileiro Plan?

8 A. Yes. But, Mr. Karadzic, I'd like to ask you something. If

9 possible, please don't put questions like that to me, because these

10 questions, more or less, have to do with high-level politics. I was

11 never a politician. I was just an ordinary policeman. I don't know

12 whether I can give answers to such questions. If you put questions to me

13 in a certain context, I can give answers about what I know about, but

14 please do not ask me about high-level politics.

15 Q. I do apologise. You are quite right. But I wanted to ask you:

16 When the police was divided, did you realise that the essence of the

17 Lisbon paper was that we would have our own police? If you don't know

18 about that, never mind.

19 A. Well, I knew that. It was a generally-known thing, the Lisbon

20 Agreement, and then the denial of that Lisbon Agreement. That's

21 something everyone knows about, more or less.

22 Q. Thank you. Does that mean that when two municipalities are

23 established, two police stations are established as well?

24 A. That's right.

25 Q. Does that mean that not necessarily all of them, but that most

Page 11827

1 Muslim policemen would go to their own police station and most of the

2 Serb policemen to their own police station?

3 A. That's the way it was supposed to be, but, unfortunately, that is

4 not what actually happened.

5 Q. Thank you. Although this is an assumption, but had there not

6 been a war, would Hadzici ever have two municipalities within its

7 structure, like many other towns do?

8 A. I believe that would be the case.

9 Q. Thank you. What about the Serb side? Was there a consolidation

10 of sorts that happened, and were weapons obtained as well?

11 A. Yes.

12 Q. Is it correct that the Yugoslav People's Army was in Bosnia until

13 the 20th of May?

14 A. Yes.

15 Q. Was the JNA particularly interested in its own infrastructure in

16 Hadzici, that is, the Technical Institute, and the Zunovnica depot, and

17 other military facilities there?

18 MS. EDGERTON: Your Honour.

19 JUDGE KWON: Yes, Ms. Edgerton.

20 MS. EDGERTON: There's quite a few questions here that are

21 calling for speculation, and I think that's another one. How on earth is

22 this witness to know?

23 JUDGE KWON: If he knows.

24 Can you answer the question, Mr. Glavas?

25 THE WITNESS: [Interpretation] Oh, yes, I did understand

Page 11828

1 Mr. Karadzic's question, and I do agree. These were areas that the JNA

2 aspired for, and they had reason to try to keep that.

3 MR. KARADZIC: [Interpretation]

4 Q. Is it correct that the local population, the local structures,

5 were not happy with the fact that the army was focusing only on its own

6 facilities and were not guarding the municipality as a whole?

7 A. They were absolutely unsatisfied.

8 Q. Is it correct that the army had a shortage of manpower because

9 Muslims and Croats did not respond to mobilisation or call-up?

10 A. That's right, and that is a generally-known thing.

11 Q. Is it correct that the army believed that the Serbs would

12 respond, if necessary, and that, in return, they did provide some -- they

13 did take some measures to ensure the safety of the Serb neighbourhoods in

14 the municipality?

15 A. Yes.

16 Q. Is it correct that in the previous system, reservists could take

17 their equipment home, weapons included?

18 A. In the previous system, that was not possible.

19 Q. Those who were asked to come to military exercises, didn't they

20 take their uniforms home, and some even took their automatic weapons

21 home?

22 A. You were not clear enough. Are you referring to the reservists

23 of the former JNA or are you referring to the reservists of the police

24 force?

25 Q. The JNA reservists.

Page 11829

1 A. Well, that's a different matter, and that possibility did exist.

2 Q. Thank you. Seeing and knowing what was happening within the

3 Muslim community, did you try to do something about providing weapons to

4 the Serb community through reserve policemen or in some other way?

5 A. I could do very little. And, specifically, I was never involved

6 in this distribution of weapons. However, as for part of the police

7 reserve force, I armed them with an additional supply from the former

8 Zunovnica Barracks.

9 Q. Thank you. Can one say that the police divided peacefully in

10 many municipalities and, by way of agreement, also the basic equipment

11 and weapons were divided, as well as vehicles, and that you, as the

12 minority community in Hadzici, fared rather poorly, in terms of this

13 division of equipment?

14 A. Yes, we fared catastrophically, because we had far fewer members

15 because of that ethnic balance and due to the fact that, objectively

16 speaking, I could not keep the headquarters of the Public Security

17 Station at the location where it was. I had to go to various improvised

18 locations. So, of course, I could not get any of those weapons, except

19 for a few members of the reserve police force who had taken their weapons

20 with them and who were Serbs, I mean. As for vehicles, I only had one

21 single vehicle, the one that I drove as the then police commander. I

22 took that vehicle and perhaps a few of those radios that were used for

23 communication, and that is what we had at that point in time at the

24 police station.

25 JUDGE KWON: Yes, Ms. Edgerton.

Page 11830

1 MS. EDGERTON: Just noting that that was a compound question, and

2 the witness has confined his answer to the second part of the compound

3 question.

4 MR. KARADZIC: [Interpretation]

5 Q. Did you reach an agreement to separate, after talks that were

6 held, in accordance with the divisions of the police in other

7 municipalities?

8 A. I could not agree that we had had some kind of agreement, but I

9 remember full well that this was sometime in the first half of April

10 1992. When the then chief of the Public Security Station,

11 Mr. Fadil Colic [as interpreted], called me to the police station, I came

12 with eight other members of the police force who were ethnic Serbs. The

13 subject discussed at that meeting was the relations among the police

14 force at the Public Security Station in Hadzici. Of course, Mr. Fadil

15 Colic, in view of the post that he held, made certain introductory

16 remarks, saying that we were moving on, as was the case before, that they

17 were the legal representatives of the police authorities in that area,

18 and all of this took a normal course until I asked for the floor. Of

19 course, what I said irritated everyone there, because this is what I

20 said: Gentlemen, do you see what happened in all neighbouring

21 municipalities, I said, in Stari Grad, in Novo Sarajevo, in the centre,

22 in Pale, Sokolac, Vogosca, Ilijas? There were splits along ethnic lines,

23 and the police was divided in all of these locations that I refer to.

24 That same thing would have to happen here, where we are, and now it is a

25 question of common sense and wisdom as to how this should be carried out.

Page 11831

1 My intention was to do things in a civilised manner, if I can put

2 it that way, for us to go our separate ways in a civilised way, if it can

3 be put that way. However, there is nothing I could do at that meeting,

4 because my remarks caused a vociferous reaction among the Muslim Bosniak

5 police. One of the policemen got up, and I'm telling you literally what

6 happened. He went to the door of the room where we were meeting. He

7 took a hand-grenade from his pocket, and he stood in front of me, having

8 taken the fuse out, and he said, You cannot leave this room until we

9 resolve these problems. Dragan Krstic, a policeman who was with me, and

10 who was very brave in such situations invariably, he took out a

11 hand-grenade as well and did the same thing. Since he was good friends

12 with this other policeman, who was an ethnic Bosniak, he said, No

13 problem, friend. If necessary, we are all going to die. Only thanks to

14 the composure of some of the policemen who were there, Bosniaks, I have

15 to say, who respected me, who held me in high regard even in that

16 situation, they -- one of them got up, grabbed him by the chest, took him

17 from the door, and said, What on earth are you doing? Are we all

18 supposed to be killed here?

19 So it was a most unfortunate situation. I left the joint

20 premises then, and this was practically the definite separation between

21 the two police forces.

22 Q. Thank you. The killing of --

23 JUDGE KWON: We'll stop here for today. It's time.

24 There are, briefly, two matters to deal with before we rise

25 today.