111102ED

Page 20764

1 Wednesday, 2 November 2011

2 [Open session]

3 [The accused entered court]

4 --- Upon commencing at 9.04 a.m.

5 JUDGE KWON: Good morning, everyone. Yes, Mr. Robinson.

6 MR. ROBINSON: Yes, good morning, Mr. President.

7 Mr. President, we would request that the Chamber, if possible,

8 recess after the testimony of this current witness in order to allow

9 members of our Defence team to interview the next witness, Nenad Krejic.

10 We have been unable to accomplish that since your ruling that

11 Dr. Karadzic couldn't interview him himself, we would like to be able to

12 do that before he begins his testimony, thank you.

13 JUDGE KWON: Before I hear from the Prosecution, could you tell

14 us why the interviews were not organised earlier, i.e., yesterday

15 afternoon?

16 MR. ROBINSON: Yes, Mr. President. Yesterday afternoon we had

17 already pre-organised a videolink interview with witness KDZ532 and so

18 until 5.00 we were occupied, myself at the Detention Unit and

19 Mr. Stevanovic in the videolink room, with that previously scheduled

20 interview.

21 JUDGE KWON: One further question. Is Mr. Karadzic's

22 cross-examination of Mr. Krejic impossible without proofing him before

23 his cross-examination?

24 MR. ROBINSON: No, of course not, Mr. President. Because if a

25 witness refuses to consent to an interview, then we have to do the

Page 20765

1 cross-examination anyway, so it's not impossible, but given that the

2 witness consented, then we think that it's -- it's preferable at least

3 that we have this interview and there shouldn't be any obstacles to it.

4 JUDGE KWON: Obstacles is that we are losing time.

5 MR. ROBINSON: We requested these interviews on the 1st of

6 September and the 21st of October. The reason that they weren't

7 accomplished is because the Registry didn't decide them until 7.59 p.m.

8 on the 28th of October, and we filed an appeal first thing on Monday

9 morning, you ruled yesterday, and so here we are. Sometimes those things

10 happen.

11 JUDGE KWON: But you do still agree Mr. Karadzic can

12 cross-examine him without proofing him?

13 MR. ROBINSON: Well, we don't agree to that, but we recognise

14 that it's a physical possibility, but where a witness has consented to

15 meet with the Defence, we think that he has a right to that before the

16 witness actually testifies. But it's not physically impossible to do it

17 because witnesses refuse testify -- I mean, refuse to be interviewed and

18 we have to cross-examine them.

19 JUDGE KWON: Very well. Yes, Ms. Sutherland.

20 MS. SUTHERLAND: Good morning, Your Honours.

21 As Mr. Robinson just said, where a witness has consented to meet

22 with the Defence -- and that's quite right, the Defence could have

23 interviewed this person, as Your Honour observed, yesterday when you gave

24 your ruling, that he may have been interviewed prior to their testimonies

25 by one of the accused's legal associates or by the accused himself over

Page 20766

1 the telephone. They've had the name since the 7th of May, 2009, and

2 could have contacted and spoken to the witness before that. And in

3 relation to even seeing the witness at 5.00 p.m. last night, that could

4 have been arranged through the VWS, and it wasn't. And now we are in a

5 situation where we have to -- there's the request for the delay, which

6 the Prosecution thinks is unreasonable.

7 MR. ROBINSON: Mr. President, if I could remind you that we

8 started the week with a two-hour delay because the Prosecution wanted to

9 proof a witness who came in late, so they could have also proofed that

10 witness since May of 2009.

11 MS. SUTHERLAND: Your Honour, the witness wasn't proofed. That

12 was the [Overlapping speakers] --

13 JUDGE KWON: Let's stop here.

14 [Trial Chamber confers]

15 JUDGE KWON: The Chamber will rise for five minutes.

16 --- Break taken at 9.12 a.m.

17 --- On resuming at 9.21 a.m.

18 JUDGE KWON: Mr. Robinson, the Chamber has considered the

19 submission as well as the Prosecution 's response and have come to a

20 conclusion not to grant your request. The Chamber is not satisfied that

21 Mr. Karadzic's cross-examination would not be possible without proofing

22 the witness, not only in a general sense but also in this specific case,

23 and the Chamber does not agree that the accused has an absolute right to

24 proof a witness when the witness in question has agreed or consented to

25 being proofed.

Page 20767

1 While the Chamber finds it unfortunate that the Registry took so

2 long a time in responding to your motion, if it is really necessary to

3 proof the witness in question, i.e., Mr. Krejic, the Chamber observed

4 that it could be done during the remainder of this -- of

5 cross-examination of this incumbent witness.

6 [Trial Chamber confers]

7 JUDGE KWON: We'll leave it at that.

8 Let's bring in the next witness.

9 MR. ROBINSON: Thank you, Mr. President. I don't mean to prolong

10 the discussion, but just to note that we just simply don't have anybody

11 available to conduct that interview while the witness is -- this witness

12 is testifying. So it's an ideal but not a practicality.

13 JUDGE MORRISON: And it occurs to me that by and large matters

14 which arose - this is going back to my own experience, I must admit - by

15 and large matters which would be raised in witness proofing can be dealt

16 with in cross-examination. The advantage of witness proofing is it

17 sometimes reduces the time for cross-examination, but its subject matter

18 can be covered.

19 MR. ROBINSON: Mr. President, while we are waiting for the

20 witness, I'm noticing that the transcript is very rough this morning, and

21 hopefully someone will listen to the tape and sort it all out.

22 JUDGE MORRISON: Yes, I appear to be designated as a welsh man,

23 "Morris Morris."

24 [The witness takes the stand]

25 JUDGE KWON: Good morning, sir. Please be seated. We'll lift

Page 20768

1 the curtain.

2 THE WITNESS: [Interpretation] Good morning.

3 JUDGE KWON: We'll lift the curtain.

4 Yes, Mr. Karadzic.

5 THE ACCUSED: [Interpretation] Good morning, Your Excellencies.

6 Good morning to all.

7 WITNESS: KDZ163 [Continued]

8 [Witness answered through interpreter]

9 Cross-examination by Mr. Karadzic: [Resumed]

10 Q. [Interpretation] Good morning, Mr. Witness.

11 A. Good morning, Mr. Karadzic.

12 Q. Just two pages from the transcript before I show you some

13 documents. On pages 59 and 62, what was put to you was Kupresanin's

14 request asking for certain individuals to be pardoned. Do you agree that

15 Kupresanin was never dismissed from any particular office, he remained an

16 MP up until the very end except that the Krajina was abolished so he was

17 no longer president of the Assembly?

18 A. I said yesterday that indeed I never saw or met Mr. Kupresanin,

19 but I know from the press that he did have some particular office in the

20 R Krajina, but you know what, I was in quite a condition myself at the

21 time and I was very busy, so I wasn't really following any of that.

22 I know he was not dismissed. I never saw that in the newspapers

23 or anywhere else in the media, something like that that he had been

24 dismissed.

25 Q. Thank you. Now, on page 65, I notice some figures, 4.403

Page 20769

1 detainees went through the camp, 2.900 were handed over to the Red Cross,

2 532 were transferred to Batkovic in order to be exchanged. There is a

3 remainder of 328. Does that mean that persons were being released

4 successively so that it was not only large-scale releases that took place

5 but rather that every day a few people would be released if they met the

6 necessary requirements?

7 A. Yes, until now it never crossed my mind to add up these figures.

8 Now I see that perhaps I should have done that. According to our

9 records, not the records of the ICRC, but our records, 4.403 persons

10 passed through the camp. However, in the camp itself there were never

11 that many people at the same time. It was always 500 or 600 less than

12 that at one point in time, that is.

13 Now, this is the reason: Prisoner exchanges took place all the

14 time, two groups per week, so this was a flowing current, they were

15 coming and going. The figure that you presented when adding all of this

16 up and subtracting, it would seem that these persons were exchanged.

17 Perhaps when groups went to third countries or something like that. At

18 any rate, it has to do with an exchange of prisoners. Those who were

19 transferred to Batkovic were also exchanged ultimately. Appropriate

20 individuals and organs from the Main Staff of the Army of Republika

21 Srpska assessed that we would need someone to exchange for our own people

22 who had been taken prisoner, so that is why these individuals were

23 transferred to Batkovic. 131 individuals were handed over to the

24 Sarajevo-Romanija Corps because they also had some of their own members

25 that had been imprisoned.

Page 20770

1 Q. Thank you. This is why I'm asking this: The witnesses who were

2 prisoners say here from time to time the names of five persons were

3 called out and they never came back. This is something they state very

4 often when they say they were taken out and never returned. When these

5 groups or individuals were taken out, does that mean that they were

6 killed, or if they never returned, does that mean that they were

7 exchanged or released? Because the witnesses suggest that if they do not

8 return, they probably get killed.

9 A. I claim, and I abide by the oath that I took yesterday, that all

10 of these persons who were taken out 5, 10, 15, even up to 40 individuals,

11 that does not mean that the other prisoners would know what had happened

12 to them. In most cases, it had to do with an exchange. None of them

13 suffered or was killed, heaven forbid.

14 Q. Thank you.

15 THE ACCUSED: [Interpretation] Can we now have a look at 65 ter

16 23506. If it's already in e-court, that is. But if -- oh, it is in

17 e-court. Yes.

18 MR. KARADZIC: [Interpretation]

19 Q. Could you please take a look. There is a translation as well,

20 but could the Serbian version be zoomed in a bit.

21 Do you agree that this is already the 13th of September, 1991,

22 during the war in Croatia? This decision was taken, as it was deemed

23 necessary, to organise a camp for prisoners of war.

24 A. That's right. This is an order of the command of the 5th Corps.

25 This is the time of the JNA, the 5th Corps had its headquarters in Banja

Page 20771

1 Luka. This order was probably derived from an order from a higher

2 command. That would be the SSNO or the 1st Army from Belgrade, to have

3 the camp established, that is. This necessity was based on the fact that

4 members of the ZNG who were fleeing from the Serb forces, or should I say

5 the JNA forces, from Croatian Kostajnica. They fled across the bridge on

6 the Una river. They fled into Bosanska Kostajnica. So they were enemy

7 soldiers, at the time, if I can put it that way, they were armed, they

8 were wearing uniforms, there were about 370 of them. I'm not sure how

9 many of them there were, it's about 370 men who were taken prisoner at

10 the time in Bosanska Kostajnica. And now, what could be done with them?

11 A camp was to be established in order to carry a triage and to take all

12 other security-related actions.

13 Q. Thank you. There is also reference to the 3rd Geneva convention

14 in paragraph 5.

15 THE ACCUSED: [Interpretation] Can we have the next page to see

16 who actually signed this document.

17 MR. KARADZIC: [Interpretation]

18 Q. This was signed by then Colonel Talic; isn't that right?

19 THE ACCUSED: [Interpretation] Can we have the next page in

20 English as well.

21 MR. KARADZIC: [Interpretation]

22 Q. There's a reference to Manjaca where food would be prepared and

23 so on. Everything is taken care of; right?

24 A. Yes. All of this is spelled out in very precise terms in the

25 order. All the way down to logistical details.

Page 20772

1 Q. 400 meals per day and laundry and everything else.

2 THE ACCUSED: [Interpretation] Can this be admitted.

3 JUDGE KWON: Yes.

4 THE REGISTRAR: Exhibit D1846, Your Honours.

5 THE ACCUSED: [Interpretation] Can we have a look at 65 ter 17847.

6 MR. KARADZIC: [Interpretation]

7 Q. Do you agree that this is the 7th of January, 1992? Again, it's

8 still the JNA, and it's an order that has to do with Stara Gradiska and

9 Manjaca, and yet again everything is prescribed as to what should be

10 done.

11 THE ACCUSED: [Interpretation] Can we have the next page.

12 [In English] Ah, it could be -- it should be English. Okay.

13 MR. KARADZIC: [Interpretation]

14 Q. So do you agree that it's the commander that is signing this,

15 Lieutenant-General Vladimir Vukovic who was nothing in the Army of

16 Republika Srpska but in the JNA rather; right?

17 A. That's right. This is the month of January 1992. The JNA still

18 existed at the time. For Bosnia-Herzegovina the JNA existed until the

19 20th of April, 1992. This is yet another order of the commander of the

20 5th Corps. It is still the JNA. The order has to do with the

21 organisation of life and work in the camp, what they put there,

22 Stara Gradiska. Before the war, Stara Gradiska was a prison, wasn't it.

23 So it was being used now for prisoners of war, for keeping them there,

24 interrogating them and so on.

25 THE ACCUSED: [Interpretation] Thank you. Can this be admitted.

Page 20773

1 JUDGE KWON: Yes.

2 THE REGISTRAR: Exhibit D1847, Your Honours.

3 MR. KARADZIC: [Interpretation]

4 Q. I believe it's a mistake in the transcript or perhaps you

5 misspoke. Do you agree that the JNA existed until the 20th of May, 1992,

6 not April? The JNA left Bosnia on the 19th of May? Don't you remember

7 that on the 3rd of May they were attacked and then in Tuzla on the 15th

8 of May they were attacked?

9 A. Possibly, it was a slip of the tongue. I know that it's the 19th

10 or 20th. Now, whether it's April or May, it's possible.

11 Q. Thank you.

12 THE ACCUSED: [Interpretation] D425. Can we briefly take a look

13 at that, please.

14 MR. KARADZIC: [Interpretation]

15 Q. Do you agree that in this document Stojan Zupljanin is

16 redistributing a telegram that he received from Dobro Planojevic,

17 assistant minister for crime prevention on the 8th of June, 1992, and

18 what is prescribed there is how prisoners of war should be treated, in

19 the spirit of humanitarian law and the Geneva Conventions?

20 A. Yes, yes. We also received similar orders through our own

21 military chain.

22 Q. Thank you.

23 THE ACCUSED: [Interpretation] D426, could we now have a look at

24 that, please.

25 MR. KARADZIC: [Interpretation]

Page 20774

1 Q. Do you agree that this is again the 8th of June, 1992, and SRNA

2 is carrying my appeal to the International Red Cross in relation to all

3 of these paragraphs, and do you agree that this was a well known position

4 of all the institutions there, to act in this way, that is?

5 A. Yes, I said yesterday that from several levels and in different

6 ways we received appeals and orders as regards the observance of the

7 Geneva Conventions and the treatment of prisoners and detainees.

8 THE ACCUSED: [Interpretation] 1D4724, could we have that now,

9 please.

10 THE REGISTRAR: Hasn't been released, Mr. Karadzic. It's not

11 been released in e-court.

12 THE ACCUSED: [Interpretation] We'll go back to that later, then.

13 1D294, could we have that, please. 4724 was the previous one.

14 1D4274. I thought that this had been admitted.

15 MS. SUTHERLAND: It wasn't -- Your Honour, it wasn't a document

16 that was notified either.

17 JUDGE KWON: I see it in the notification.

18 MS. SUTHERLAND: But the previous document that hasn't been

19 released, 4724, 1D4724.

20 JUDGE KWON: No, we are talking about 1D4274.

21 [Trial Chamber and Registrar confer]

22 JUDGE KWON: I was told it hasn't been released. Now we have.

23 MR. KARADZIC: [Interpretation]

24 Q. Do you agree, Witness, that on the 12th of June, the Main Staff,

25 and then it was modified to be resent from corps level, was an

Page 20775

1 instruction issued on the treatment of prisoners of war?

2 A. Yes, I agree.

3 THE ACCUSED: [Interpretation] Can we see the next page. In

4 English as well.

5 MR. KARADZIC: [Interpretation]

6 Q. It specifies to whom it is sent, chief of security of the

7 1st Krajina Corps, and then it's sent on to Manjaca, what we see in

8 handwriting, training-ground in Manjaca, the press service.

9 THE ACCUSED: [Interpretation] Next page, please.

10 MR. KARADZIC: [Interpretation]

11 Q. You know that this was the position and this was sent to -- into

12 the field?

13 A. Yes, precisely. That was the amended, or rather, adjusted order

14 from the Main Staff and retyped. All the modifications that were done in

15 hand were here neatly retyped and -- by professional typists and then --

16 Q. Thank you.

17 THE ACCUSED: [Interpretation] Can this be admitted.

18 JUDGE KWON: Yes.

19 THE REGISTRAR: Exhibit D1848, Your Honours.

20 THE ACCUSED: [Interpretation] 1D297 is the next document I would

21 like to call up.

22 MR. KARADZIC: [Interpretation]

23 Q. Do you agree this is my order on the application of the rules of

24 international laws of war that I issued as soon as I was elected on the

25 13th of May, but it was published only on the 13th of June, the day after

Page 20776

1 that order by Mladic, and it was adopted by the same session of the

2 Presidency? Do you agree this was done in keeping with the needs and

3 requirements, but do you agree that it was not strictly necessary because

4 every officer in our army was aware of this?

5 A. I was not able to see this order for objective reasons, but of

6 course I agree with the gist of it, with the contents, and I agree with

7 what you said that every soldier in our army, and especially every

8 officer, was aware of all this, even from their school textbooks, let

9 alone after this series of additional orders and instructions and appeals

10 issued before the war and during the war.

11 Q. Thank you.

12 THE ACCUSED: [Interpretation] Can this be admitted.

13 JUDGE KWON: Yes.

14 THE REGISTRAR: Exhibit D1849, Your Honours.

15 THE ACCUSED: [Interpretation] It is ordered here, or rather, the

16 minister of defence is authorised to issue instructions, et cetera.

17 Could we now see 1D298.

18 MR. KARADZIC: [Interpretation]

19 Q. Do you agree that this is the instruction that the minister of

20 defence was authorised to issue on the treatment of POWs, and here on

21 page 1 we see 10 paragraphs and there are 19 more on the next page.

22 THE ACCUSED: [Interpretation] I suppose there is a translation.

23 JUDGE KWON: Yes, Ms. Sutherland.

24 MS. SUTHERLAND: Your Honour, Mr. Reed advises that this is

25 P1134.

Page 20777

1 JUDGE KWON: Thank you. Shall we upload it.

2 THE ACCUSED: [Interpretation] Can we see the next page, please.

3 The Defence has a better copy.

4 JUDGE KWON: But this one has an English translation.

5 THE ACCUSED: [Interpretation] Very well.

6 MR. KARADZIC: [Interpretation]

7 Q. We see on page 2 here -- we now have two Serbian versions, we

8 need one in English. We see it up to item 19 and then we also see a

9 fragment of a capture card, and on the next page there is a supplement.

10 Do you remember that you had documentation and forms to keep records on

11 every captive?

12 A. Yes, we used those forms but we also received it in the form of

13 an Official Gazette, but we also had an instruction that was retyped

14 containing all these items and all these forms.

15 Q. Thank you.

16 THE ACCUSED: [Interpretation] This is already an exhibit. We'll

17 skip many documents that are already be exhibits and deal with the same

18 subject. Could we now see D103.

19 MR. KARADZIC: [Interpretation]

20 Q. This is perhaps something you did not necessarily see because it

21 was sent to Mladic, the minister of the interior, and the minister of

22 justice, where I remind them that sometime earlier I had signed an

23 official authorisation to the delegates of the ICRC and that it should be

24 complied with because there were some incidents on the ground. So do you

25 agree that the incidents on the ground were not due to the misconduct of

Page 20778

1 these people but because of certain pathologies among the people on the

2 ground and the general population?

3 A. Of course I didn't see this document. I wouldn't have been able

4 to, but I agree with what is written here because we heard the same thing

5 from the media, that pressures were great and that there were a lot of

6 complaints against many camps and collection centres, and we felt the

7 same in Manjaca.

8 Q. Thank you.

9 THE ACCUSED: [Interpretation] Could we now see 65 ter 17453.

10 MR. KARADZIC: [Interpretation].

11 Q. One of the variants has been admitted into evidence but in this

12 one the minister of health also joined in.

13 THE ACCUSED: [Interpretation] 17453.

14 MR. KARADZIC: [Interpretation]

15 Q. There's also the signature and the stamp of the minister of

16 health. Would you please look at this. This is an instruction to all

17 local civilian and police authorities without any restriction or date.

18 What I'm invoking was issued in June 1992, and it says that the ICRC

19 should be given everything they need, free access and free passage. Did

20 you in Manjaca feel the effects of this? Did the ICRC come to visit

21 pursuant to this instruction and other instructions to enable the ICRC to

22 do their job?

23 A. Yes. We did feel the effects of this, and I believe these

24 missions of the ICRC brought with them and produced this paper or a

25 similar paper and that was the beginning of regular and frequent visits

Page 20779

1 to the camp of Manjaca.

2 THE ACCUSED: [Interpretation] I'm there's no translation. I

3 believe there must be one somewhere.

4 JUDGE KWON: I think second page of this document seems to be an

5 English translation.

6 THE ACCUSED: [Interpretation] Could we see the next page, please.

7 My service has translated this. Can this be admitted?

8 JUDGE KWON: But do we have a date of this? You said it's June

9 1992, but I don't see any date on this document.

10 Yes, Ms. Sutherland.

11 MS. SUTHERLAND: Your Honour, I note that Mr. Karadzic said

12 there's he also the signature and the stamp of the minister of health.

13 JUDGE KWON: Yes, I'm a hit confused.

14 THE ACCUSED: [Interpretation] We also have the version cosigned

15 by the minister of health to strengthen this document. And as for the

16 date, we did not put the date deliberately so that there could be no

17 objections of expiry or something. Anyway, the agency SRNA on the 11th

18 of July -- or rather, no, I'll tell you which document it is that we

19 showed a moment ago. D426. We can see it was on the 8th of June, 1992.

20 If necessary we can call it up, D426.

21 JUDGE KWON: We'll take your words. We'll admit 65 ter numbers

22 17453 as Exhibit D1850.

23 THE ACCUSED: [Interpretation] Thank you. Can we see 1D304.

24 MR. KARADZIC: [Interpretation]

25 Q. I believe you were present, I don't know if we have this in

Page 20780

1 Serbian, but I will be reading in English because the interpreters will

2 do a better job than I. So on behalf of the Presidency, in fact, I was

3 already president at that time, and I'm writing to Daniel Shiffer, and

4 I'll read this in English: :

5 [In English] "Mr. Shiffer, I wish to express my pleasure with you

6 -- your and Mr. Viesel's visit to Yugoslavia and the Republika Srpska.

7 In the circumstances in which the truth is distorted, the visit of

8 persons of such a moral and humane authority as Viesel and his associates

9 are in one of those rare -- is of those blessings -- of the rare

10 blessings.

11 "You have seen that Serbs in Bosnia have prisoners of war and

12 that they are treated in accordance with the Geneva Conventions. The

13 Muslim and the Croatian side do not respect the human rights of

14 imprisoned Serbs.

15 "So far the Serbs have made many unilateral gestures, including

16 several cases of unilateral release of prisoners of war. The other side

17 has not made a single reciprocal move. In spite of that, we are ready to

18 make another move. In honour of Mr. Viesel's and his associates visit to

19 Yugoslavia and the Republika Srpska and on the occasion of our Orthodox

20 Christmas, we are willing to release all prisoners from Manjaca if the

21 international community and the International Red Cross are ready to

22 accept them and convey them to third countries.

23 "We do hope and expect that Mr. Viesel's reputation of a man of

24 high moral standards and respectability of his associates will exert

25 pressure upon the Muslim and Croatian side to release thousands of

Page 20781

1 captured Serbs."

2 Do you remember the visits of Mr. Shiffer and Mr. Viesel to

3 Manjaca?

4 A. Yes, I remember, especially Mr. Shiffer, I believe he was there

5 several times, and we even symbolically gave him the key of the Manjaca

6 camp once it was disbanded.

7 Q. Thank you. Did it ever happen, Witness, that any of the

8 prisoners of war who were released or exchanged be captured again in

9 battle and brought back to Manjaca?

10 A. Yes. We did some research into that and I was surprised myself

11 that people who had gone through what they had gone through and had the

12 chance to go to third countries rejoined units on whatever side and get

13 captured again. There were not many such cases but there were such

14 cases, namely, that people who had been in Manjaca once were captured

15 again and brought back.

16 Q. So do you believe it was reasonable on our part to request from

17 the ICRC that prisoners be taken to third countries so that we don't end

18 up reinforcing the enemy army when we release people?

19 A. Yes, I also think that is reasonable and logical.

20 Q. Thank you.

21 THE ACCUSED: [Interpretation] Can that be admitted.

22 JUDGE KWON: Yes.

23 THE REGISTRAR: Exhibit D1851, Your Honours.

24 THE ACCUSED: [Interpretation] Thank you.

25 MR. KARADZIC: [Interpretation]

Page 20782

1 Q. You said you had practically on a daily basis and sometimes at

2 regular intervals reports to the competent command; that is to say, the

3 command of the 1st Krajina Corps?

4 A. Correct.

5 THE ACCUSED: [Interpretation] 65 ter 5775, please.

6 THE REGISTRAR: Exhibit P3724, Your Honours.

7 THE ACCUSED: [Interpretation] Thank you, then we won't dwell on

8 this much.

9 MR. KARADZIC: [Interpretation]

10 Q. This is a report saying that according to plan, two crews of

11 reporters and cameramen visited and their names are listed. It's 8

12 August 1992. Do you remember the visit of these reporters?

13 A. There were many visits by reporters, but I'd like to see the

14 second page because if I wrote this then I must have been present when

15 they visited.

16 THE ACCUSED: [Interpretation] Could we see the next page. I

17 believe this document has been shown before in the examination-in-chief.

18 MR. KARADZIC: [Interpretation]

19 Q. It says here that this is signed by Radinkovic.

20 THE ACCUSED: [Interpretation] Can this be viewed in public.

21 MR. KARADZIC: [Interpretation]

22 Q. It mentions that Kupresanin had been there at my request, or on

23 my orders, and the president asked him to talk to commanders of

24 pavilions, and two prisoners were released on that day, Ago Deronjic, son

25 of Ragib, and Zuhdija Ramic, son of Dervis. Is this an instance of

Page 20783

1 successive release of prisoners that you mentioned before?

2 A. Correct, that is a reference to the same.

3 Q. Thank you. As you said earlier today, the people in the same

4 facility did not necessarily know what happened with these people?

5 A. They usually didn't. What I'm saying that the other prisoners

6 were not able to know and didn't know because there were many buildings.

7 Some people were going out to work or volunteered to work, some were

8 called out by name for labour duty, because when there were exchanges,

9 the Muslim side would ask for specific persons, and if these persons

10 happened to be in Manjaca, the names of these people would be called out

11 and they would be released.

12 THE ACCUSED: [Interpretation] 1D4556, please. But not to be

13 broadcast. 1D4556. Can the Serbian version be zoomed in just a little

14 for the benefit of the witness. This should not be broadcast.

15 MR. KARADZIC: [Interpretation]

16 Q. On the 12th of August, a team of journalists appeared and then

17 members of the government of the Serbian Republic of BH also visited to

18 see the conditions of life of the detainees. They had an approval signed

19 by the then prime minister, Mr. Djeric, and it says here that

20 Colonel Vukovic also visited, and further on it says that he looked at

21 the activities of the international committee of the Red Cross. Is this

22 an authentic document? Does it reflect the truth? Were the visits

23 indeed that frequent both by the journalists as well as the

24 representatives of the Red Cross?

25 (redacted)

Page 20786

1 about the compulsory submission of certain information about the prison,

2 about the number of detainees and so on and so forth. This was drafted

3 on the 23rd of August 1992. We were still in August in other words?

4 A. Yes, I remember that we were also requested to provide certain

5 information about the camp, about the number of detainees. I suppose

6 that this was a reaction to these orders.

7 THE ACCUSED: [Interpretation] Can this be admitted?

8 JUDGE KWON: Yes.

9 THE REGISTRAR: MFI D1853, Your Honours.

10 JUDGE KWON: Thank you.

11 THE ACCUSED: [Interpretation] I'd like to call up 1D4558.

12 MR. KARADZIC: [Interpretation]

13 Q. Two days later after Milovanovic's telegram, the command of the

14 1st Krajina Corps received something from you and forwarded it to the

15 Main Staff; right?

16 A. I can see that in this document. Actually, it was the camp

17 commander who provided the information. We prepared everything for him

18 and he provided the information to the command, i.e., he first sent it to

19 the assistant commander for logistics who sent it to the Main Staff.

20 THE ACCUSED: [Interpretation] Can we go to the following page.

21 MR. KARADZIC: [Interpretation]

22 Q. He received the telegram on the 23rd and already on the 24th he

23 sent his reply and that reply was forwarded to the Main Staff on the 25th

24 of August.

25 THE ACCUSED: [Interpretation] Go to the following page, please.

Page 20787

1 MR. KARADZIC: [Interpretation]

2 Q. And here under 1 we can see that their names, the numbers, and it

3 says here there are currently 3.659 prisoners, and we also submit the

4 lists as requested in your telegram. However, in the note, do you agree

5 that this commander denies the contents of the telegram in which he was

6 criticised for not having allowed the International Red Cross to approach

7 and that he insulted the team, the Supreme Command of the army, and so on

8 and so forth? Do you agree that very often the complaints were not

9 truthful and that I and the Main Staff at first understood them as being

10 correct and that this situation resulted in discords between the camp

11 commander and us?

12 THE ACCUSED: [Interpretation] In English there's another page.

13 MR. KARADZIC: [Interpretation]

14 Q. And he says that the Red Cross has visited the camp five times

15 already.

16 A. The fact is that before the date on the document, there had been

17 a few visits by the International Red Cross and journalists. I don't

18 have a reason to doubt the note that was drafted and signed by the camp

19 commander, Lieutenant-Colonel Popovic. Irrespective of the fact what

20 people think of him and how they perceive him, he was very co-operative

21 in terms of the visits of the Red Cross and journalists, and he wanted to

22 be in the limelight. He wanted to have his photos taken by journalists.

23 Q. Thank you.

24 THE ACCUSED: [Interpretation] Can this be admitted.

25 JUDGE KWON: Yes.

Page 20788

1 THE REGISTRAR: Exhibit D1854, Your Honours.

2 JUDGE KWON: Mr. Karadzic, I note the time. If it is convenient,

3 we'll take a break now.

4 THE ACCUSED: [Interpretation] Yes, thank you.

5 JUDGE KWON: First break will be for 20 minutes and we'll resume

6 at twenty to 11.00.

7 --- Recess taken at 10.21 a.m.

8 --- On resuming at 10.44 a.m.

9 JUDGE KWON: Yes, Mr. Karadzic.

10 THE ACCUSED: [Interpretation] Thank you.

11 MR. KARADZIC: [Interpretation]

12 Q. Witness, I believe that you had very prompt and good

13 communication with the command of the 1st Krajina Corps. What about the

14 telephone and fax lines with Banja Luka, were they up and running at the

15 time? There were no outages at the time, were there?

16 A. We used a military telephone line. The telephone line was up and

17 running. We could communicate with Banja Luka.

18 Q. Thank you. And what about your communication with the eastern

19 part of the Republika Srpska, Sarajevo and Pale, were those communication

20 lines up and running or not? Were they compromised?

21 A. I did not need to use any such communications, but I know for a

22 fact that those communications did not exist. There was a corridor

23 between us so the lines were not up and running. I had a problem

24 arriving from (redacted)

25 (redacted)

Page 20789

1 THE ACCUSED: [Interpretation] I'd like to call up 1D4559.

2 MR. KARADZIC: [Interpretation]

3 Q. Do you agree that the detainees did not willingly accept that

4 they had participated in combat, i.e., that they were guilty of

5 something?

6 JUDGE KWON: Before you answer, Mr. Witness.

7 Yes, Ms. Sutherland.

8 MS. SUTHERLAND: Sorry to interrupt, I'm wondering about a

9 redaction, page 25, line 14 and 15.

10 JUDGE KWON: Yes.

11 MS. SUTHERLAND: From the words "from."

12 JUDGE KWON: Thank you.

13 Now, can you answer, Mr. Witness.

14 THE WITNESS: [Interpretation] Could you please repeat the

15 question, if that's not a problem.

16 MR. KARADZIC: [Interpretation]

17 Q. Yes, I will. Do you agree that the detainees were not willingly

18 admitting that they had participated in combat and do you agree that

19 during our civil war, people were in combat in civilian clothes for a

20 long time?

21 A. As far as the first part of your question goes, it is in human

22 nature to resort to all means to defend themselves, one of those means

23 obviously is lying. They would say that they did not participate in

24 combat, they did not carry arms, that they did not wear uniforms or that

25 there were indicia to the contrary. And what was the second part of your

Page 20790

1 question? I apologise.

2 Q. Do you agree that in our civil war people wore civilian clothes

3 for a long time, that neighbours were fighting neighbours and they did

4 not have uniforms? Also some people who were not combatants were

5 sometimes seen wearing parts of military uniforms for various reasons,

6 one of them being poverty? In other words, civilian clothes or a

7 military coat did not actually identify a person as a soldier or a

8 civilian, do you agree?

9 A. Let's be economical. At the time, I agree fully that was indeed

10 the case. Uniforms and civilian clothes did not mean much in our area in

11 the last war. It was even perpetuous to wear civilian clothes, a track

12 suit, or tennis shoes.

13 Q. Please look at the document. This document was issued at

14 Manjaca. I believe that it can be broadcast. It doesn't really matter.

15 This is a letter from Manjaca to the 1st Krajina Corps intelligence and

16 security branch. It says we hereby inform you that according to a

17 record, we have 1.353 prisoners of war. Ramiz Grapkic was captured in

18 Grapska. We interviewed 15 persons, statements were taken from 13

19 persons, and interviews are relative Kljuc. There is also reference to

20 the attack on a military convoy which was planned and organised by

21 Omar Filipovic, and it is also stated that 19 persons participated in

22 that attack. Is that all correct? And you can also see their names;

23 right?

24 A. Yes, this is the very beginning of Manjaca, an active officer or

25 a commissioned officer was captured, and there were eight members of the

Page 20791

1 JNA among them. There was the notorious Colonel Zarko among them. And

2 as far as the convoy is concerned, after I arrived in Manjaca I learned

3 about that attack on the convoy and the killing of five or perhaps six

4 soldiers. Those soldiers were on their way back. They were still

5 members of the JNA because the JNA still officially existed. I don't see

6 what date this is. The soldiers were returning from Krajina or from Knin

7 on buses. They came under attack, and I believe that the leader of that

8 attack was the notorious Amir Avdic. He was an officer. He now holds an

9 office in the Federation. He is still alive.

10 Q. Thank you.

11 THE ACCUSED: [Interpretation] Can we go to the following page,

12 please. Can we have the following page in English as well.

13 MR. KARADZIC: [Interpretation]

14 Q. At the top of this page, which you can see that

15 Lieutenant Amir Avdic organised about 80 persons, of whom about 70 per

16 cent were armed. They set out for Bihac, and it is estimated that in the

17 territory of Kljuc municipality he was still hiding armed individuals,

18 some of whom were on their way to Bihac. Would that be a customary

19 report about the situation in the Manjaca detainee camp? There were

20 daily reports and there were also collective reports, as it were; is that

21 right? (redacted)

22 A. Yes, you were right, there were daily reports that were drafted

23 at the end of every day and then there were also periodical reports, and

24 as needed at the request of a superior, there was also an overview of

25 events that were previously reported. (redacted)

Page 20794

1 war and that new information was obtained about the participation of

2 those names that are referred to herein in crimes, in attacks. There is

3 a reference to Omer Filipovic, Asim Egerlic. There's also a reference to

4 a "zolja" attack on a bus, that you will find this in the last paragraph.

5 Do you agree that this provided enough grounds for those people to be

6 captured, detained, and tried because they did whatever they did in the

7 depth of the territory rather than on the front line?

8 A. Not to go into too much detail, not to jeopardise my

9 confidentiality as a witness, I can say that my answer is yes.

10 THE ACCUSED: [Interpretation] Can this be admitted.

11 JUDGE KWON: Yes.

12 THE REGISTRAR: Exhibit D1856, Your Honours.

13 THE ACCUSED: [Interpretation] 1D4561, please.

14 MR. KARADZIC: [Interpretation]

15 Q. While we are waiting, Witness, let me tell you why I'm asking you

16 this. I would like to establish what were grounds for somebody's

17 detention. Did you ever come across a situation where a person was

18 detained because they were of a different ethnicity? Was that of the

19 sole reason for their detention, or alternatively was there a suspicion

20 that they had participated in a crime?

21 A. At that time I did not think very much about religion or

22 ethnicity. This was a less important thing in Manjaca. In Manjaca,

23 there were a lot of Muslims, over 95 per cent of the detainees were

24 Muslims. There were about 152 or 150 Croats, and there were five Serbs

25 as well. Religion or ethnicity was not the decisive factor in the

Page 20795

1 treatment, detention, or arrival at Manjaca. I don't know whether I have

2 managed to answer your question.

3 Q. Yes, you did. I want to establish the grounds for detention.

4 Whether it was justified or not. A pure suspicion that a crime was

5 committed or that the crime was indeed committed or some other reason

6 because in those municipalities from which the detainees hailed, 90 per

7 cent of Muslims still remained living and were never brought to Manjaca;

8 right? To be very clear, if there were 18.000 Muslims in Kljuc and only

9 1.100 or 1.200 were brought in, then I wouldn't say that religion was the

10 main criterion based on which they were brought in, do you agree with

11 that?

12 A. I agree in principle but I cannot confirm the data that you've

13 presented, and these are facts that are probably being taken into

14 account. I don't know the pre-war population of Kljuc, and I also don't

15 know which percentage came to Manjaca. For the sake of the truth, I have

16 to say this.

17 THE ACCUSED: [Interpretation] Thank you. Could you please take a

18 look at this document.

19 MR. KARADZIC: [Interpretation]

20 Q. This is a daily report. Yet again what is being reported on is

21 the processing of a certain number of prisoners, and then information is

22 provided about new things that have been learned that either confirmed

23 that someone did participate or refute that. So Azdemovic, Senad took

24 part. Look, Jasminko [phoen], so on. Was that the purpose of this

25 regular processing, to establish whether a crime had been committed or

Page 20796

1 not, and did you provide information on a daily basis about the

2 interviews conducted on that day? The processing of prisoners on a

3 particular day, that is?

4 A. That is evident from this report. What was focused on, if I can

5 put it that way, during those days, was to capture the perpetrators of

6 the attack against military column who killed a few young conscripts who

7 were just doing their military service.

8 Q. Who were going back home and who did not constitute any kind of

9 threat; right?

10 A. Precisely.

11 Q. Thank you.

12 THE ACCUSED: [Interpretation] Can this be admitted.

13 JUDGE KWON: Yes.

14 THE REGISTRAR: Exhibit D1857, Your Honours.

15 THE ACCUSED: [Interpretation] 1D4562, could we have that, please.

16 MR. KARADZIC: [Interpretation]

17 Q. This is a daily report, again dated the 18th of June, and it says

18 that Merhamet, the representatives of the Muslim charity organisation

19 Merhamet visited Manjaca, and then what is described here is the

20 information obtained, who illegally transported weapons to Kljuc and then

21 the names of the perpetrators are listed here. And it says these

22 individuals confirmed our knowledge from earlier on that Arif Hukanovic

23 from Vrhpolje, municipality of Sanski Most provided weapons in organised

24 manner to Muslims in villages in Kljuc. And then further down it says:

25 In connection with the visiting POWs, we would like to point out that

Page 20797

1 between 10.45 and 12.45 the POWs were visited by Adil Mehic; Esad Bajric,

2 imam; - so that is an imam, right? - Hajro Halilovic; and the lawyer Amir

3 Djonlic, all of them from Banja Luka. They visited on behalf of

4 Merhamet. Can we move on to the next page now. It doesn't really have

5 to be broadcast.

6 Do you remember that in addition to the Red Cross, the Muslim

7 organisation Merhamet also came? See, it says that here, they visited

8 all the pavilions, they personally got to see how they lived and worked

9 there, and on page 2 you can see who all the persons that received them

10 were. Do you remember all of this?

11 A. Yes, Merhamet was among the first organisations, if I can put it

12 that way, to come and visit the prisoners in camp. They brought them

13 some aid, some food, that is, and clothing and medicine. As a matter of

14 fact, we even handed over some prisoners to them. For example, persons

15 who were younger than 18 and who had not been charged with anything else.

16 There were several visits. I think that they no longer took place once

17 the ICRC visited.

18 Q. Thank you. What it says here is that prisoners freely presented

19 their problems and they said that food was not good. Do you remember

20 that Merhamet was allowed to bring in extra food? Did they actually do

21 that?

22 A. Yes, the actual situation was presented to Merhamet. They

23 established what the situation really was like as they talked to the

24 detainees, and I cannot remember exactly the food that they brought in,

25 but at any rate then allowed to bring food.

Page 20798

1 Q. Thank you. Who cooked the food in Manjaca? Who prepared it?

2 A. From an organisational point of view, Manjaca was officially

3 called a POW camp and that is what it said at the entrance and that is

4 what the stamp also said. POW camp Manjaca. It was an organisational

5 unit of the 1st Krajina Corps and since it was an organisational unit of

6 the 1st Krajina Corps, that means that from the point of view of

7 logistics, it was part of that corps as well. Just like any other unit

8 or any other brigade, our quartermasters would go to the Kozara barracks

9 in Banja Luka every day to get provisions. So they would receive food

10 rations, that is to say bread, meat, vegetables and so on, depending on

11 the number of POWs there. Whether that was enough is a different matter

12 altogether. Perhaps other questions will deal with that. At any rate,

13 they shared the fate of the people and the army at that point in time.

14 In that situation, when there was a blockade, when there was a lack of

15 communication with the rest of Republika Srpska, they shared their fate.

16 Q. Thank you.

17 THE ACCUSED: [Interpretation] Can this be admitted.

18 JUDGE KWON: Yes.

19 THE REGISTRAR: Exhibit D1858, Your Honours.

20 THE ACCUSED: [Interpretation] 1D4563, please.

21 MR. KARADZIC: [Interpretation]

22 Q. Do you agree that this is also a daily report dated the 20th of

23 June and that 51 prisoners of war from Kljuc and Sanski Most were dealt

24 with either fully or partially, and you say or rather what is stated here

25 is that more or less well known information was received, information

Page 20801

1 please.

2 MR. KARADZIC: [Interpretation]

3 Q. What is stated here is that important things were realised in

4 connection with the attack against the military column, and it says new

5 information was obtained as to who the participants were and it was

6 confirmed that this attack had been planned in advance, and that

7 Amir Avdic and others carried out that attack. So there is no doubt

8 about that. All of these prisoners independently confirmed the

9 information you already had or expanded on the information that their

10 interviewers already had; right?

11 A. Precisely.

12 Q. Thank you.

13 THE ACCUSED: [Interpretation] Can this be admitted.

14 JUDGE KWON: Yes.

15 THE REGISTRAR: Exhibit D1860, Your Honours.

16 THE ACCUSED: [Interpretation] Thank you. 1D4565, can we have

17 that, please.

18 MR. KARADZIC: [Interpretation]

19 Q. This is the following day and it says that Merhamet visited

20 again - the representatives of Merhamet, rather - and that they brought

21 in a certain amount of food, medicine, footwear, clothing, and so on, and

22 further on it says that they asked for a list of prisoners and then they

23 were told to communicate with the corps command, and then it says that

24 10 POWs were interviewed and previous knowledge was confirmed. So when

25 they talked to this man Salif [phoen], they came to realise that

Page 20802

1 Salihovic was commander, company commander in the village of Velagici.

2 The company had three what?

3 A. Platoons.

4 Q. Platoons. The first platoon commander was

5 Momin Derisevic [phoen], the second platoon commander was Telfik [phoen]

6 Draganovic, and the third platoon commander was Ramiz Tecevic [phoen].

7 Do you remember that Velagici is close to Kljuc, deep into our territory,

8 far away from any front line, and that there was fighting there and that

9 even crimes were committed on both sides?

10 A. Yes, I remember.

11 MS. SUTHERLAND: Your Honour, what part of the three questions is

12 the answer yes to?

13 JUDGE KWON: Yes.

14 MR. KARADZIC: [Interpretation]

15 Q. This is what I'd like to say: Is it correct that within such a

16 short span of time, Merhamet visited yet again and brought in 1.500

17 kilograms of food and medicine and clothing and so on?

18 A. That is what the report says and, yes, it's true.

19 Q. Thank you. Is it correct that it was established through

20 interviews with these prisoners that there was a company in Velagici

21 consisting of three platoons and the names of the platoon commanders are

22 listed here?

23 A. That is what the report says and that is also correct.

24 Q. Do you agree that this is the same village of Velagici where that

25 crime was committed by the Serbs, the one that was investigated and

Page 20803

1 punished?

2 A. Yes.

3 Q. Thank you.

4 THE ACCUSED: [Interpretation] Can we see the next page. There's

5 another report.

6 MR. KARADZIC: [Interpretation]

7 Q. 25th June, it concerns an exchange of 61 prisoners of war, 16

8 from Kljuc. That means you released 16 prisoners on this day, over 60

9 and under 18; correct?

10 A. Correct.

11 Q. Thank you. There's also a reference to the death of a person

12 called Zlatan. Is it one of the three natural deaths, deaths of natural

13 causes?

14 A. Yes, that's one of the cases of death of natural causes.

15 Q. I believe that's part of the same exhibit. Yes, it is. Can it

16 be admitted?

17 JUDGE KWON: Yes.

18 THE REGISTRAR: Exhibit D1861, Your Honours.

19 JUDGE KWON: Just a query for Mr. Robinson. Was this witness

20 proofed by the accused before he gives evidence?

21 MR. ROBINSON: Yes, Mr. President.

22 JUDGE KWON: I'm just wondering, speaking for myself, whether

23 there could be a more summary way of tendering these kinds of reports.

24 You could ask the witness to examine each of these documents and then

25 could put a more general question and then tender them altogether. I

Page 20804

1 wonder, there would be opposition to such treatment or tendering in such

2 a manner.

3 Yes, Mr. Tieger.

4 MR. TIEGER: Mr. President, we have fairly consistently explored

5 with the Defence various avenues for rendering the process more efficient

6 and particularly in connection with admission of documents. At the

7 moment, I don't see a problem with that. We're happy to look at it

8 carefully, but I think it's something well worth considering and we take

9 the -- we'll take the Trial Chamber's suggestion very seriously.

10 JUDGE KWON: Thank you.

11 MR. ROBINSON: Yes, Mr. President. We would also join in that,

12 and I would say that the session with this witness was entirely devoted

13 to looking at documents, so we did our best on that score, but if there's

14 some way to expedite their admission, it would be a good idea.

15 JUDGE KWON: Yes, Mr. Karadzic, please continue.

16 THE ACCUSED: [Interpretation] Thank you. Then I would be ready

17 now to give papers to the witness while we wait to see them in e-court so

18 that he can confirm the authenticity of the documents, whereas the

19 contents is self-explanatory. If that saves us some time, I agree. Did

20 you mean that the witness should look through the documents during the

21 break or now?

22 JUDGE KWON: I meant during the proofing. And then you can ask a

23 question that would cover all the documents, and if necessary you can

24 touch-up on specific details, if you so wish. Please consult

25 Mr. Robinson as to the appropriate manner in which you tender your

Page 20805

1 evidence.

2 Let's proceed.

3 THE ACCUSED: [Interpretation] Thank you. Then I will try to

4 speed it up until Mr. Robinson formulates his suggestion. Can we see

5 1D773.

6 JUDGE KWON: Mr. Karadzic, I was told that it hasn't been yet

7 released.

8 THE ACCUSED: [Interpretation] 65 ter 832 then.

9 MR. KARADZIC: [Interpretation]

10 Q. Would you please look at the fifth line from the top where it

11 says that through this work and interviews new persons have been

12 identified as involved. So did this kind of work constitute a basis for

13 new arrests of perpetrators?

14 A. When an interview yields information indicating that some

15 specific persons were involved or perpetrated crimes, of course their

16 arrest is the next step. That's my answer.

17 Q. Thank you.

18 THE ACCUSED: [Interpretation] Can this be admitted.

19 JUDGE KWON: I think this has already been admitted as

20 Exhibit P3736 under seal.

21 THE ACCUSED: [Interpretation] Thank you. Is 1D4566 also an

22 exhibit? Can we see it.

23 MR. KARADZIC: [Interpretation]

24 Q. Do you agree that this report says in the first paragraph that

25 indications have been confirmed and there is one wounded person who had

Page 20808

1 Q. Please look at this. Is this the usual accompanying document

2 sent when people are sent for further processing to Manjaca? It lists

3 the charges against them.

4 A. Yes, this is the standard document but it's insufficient for

5 further detention, so we asked the station to provide also Official Notes

6 which are a longer document with more details about the acts charged.

7 But, yes, this is a standard document that accompanied persons sent to

8 us.

9 Q. Could you see the last paragraph, perhaps it would help you be

10 more specific.

11 THE ACCUSED: [Interpretation] Next page, please. In Serbian too.

12 MR. KARADZIC: [Interpretation]

13 Q. It says they are asking you to receive them and they will

14 continue the operative work themselves. Was it standard procedure for

15 policemen from the police station concerned to come to the camp and

16 continue the investigation?

17 A. Yes. This makes things clearer. Their men come to continue

18 their work and to draft new documents concerning persons investigated.

19 THE ACCUSED: [Interpretation] Can this be admitted.

20 JUDGE KWON: Yes.

21 THE REGISTRAR: Exhibit D1863, Your Honours.

22 THE ACCUSED: [Interpretation] I'll skip everything that's already

23 been admitted. 65 ter 5566. Although perhaps this is already an

24 exhibit. No, it is an exhibit so we don't need it. Can we look at 65

25 ter 17840.

Page 20809

1 MR. KARADZIC: [Interpretation]

2 Q. Please look at this telegram dated 19 August. It says:

3 "On the orders of the highest authorities of Republika Srpska,

4 all public security stations that have transported prisoners of war to

5 the Manjaca military camp shall immediately create a file on each

6 prisoner ..." et cetera, et cetera.

7 (redacted)

8 (redacted)

9 (redacted)

10 (redacted)

11 (redacted)

12 (redacted)

13 (redacted)

14 (redacted)

15 JUDGE KWON: Yes.

16 [Private session]

17 (redacted)

18 (redacted)

19 (redacted)

20 (redacted)

21 (redacted)

22 (redacted)

23 (redacted)

24 (redacted)

25 (redacted)

Page 20810

1 (redacted)

2 (redacted)

3 (redacted)

4 (redacted)

5 (redacted)

6 (redacted)

7 [Open session]

8 JUDGE KWON: Mr. Karadzic, would it assist you if we were to take

9 an early break now, in terms of preparing your documents?

10 MR. ROBINSON: Mr. President, I was thinking about how we would

11 manage to do that. I think without meeting the witness again it wouldn't

12 be possible but in the future we could possibly prepare some kind of 92

13 ter summary of our own and use it with the witness.

14 JUDGE KWON: Thank you.

15 THE ACCUSED: [Interpretation] Shall we then continue?

16 JUDGE KWON: Until 12.00.

17 THE ACCUSED: [Interpretation] Thank you. 65 ter 5600, please.

18 5600.

19 MR. KARADZIC: [Interpretation]

20 Q. We are waiting for the Serbian version. On the 22nd of August

21 there were daily activities, day in, day out. On the 22nd of August, the

22 chief of the public security station Prijedor, Drljaca reports that on

23 the 20th of August they acted on the request and that they carried out a

24 selection of detainees; whereas, on the 20th of August, they replaced

25 those who could leave Manjaca in Trnopolje. Do you agree that that was

Page 20811

1 indeed the case and that was just one of the activities in the series of

2 activities?

3 A. This is what I can see in the document. I don't have any reason

4 to doubt the veracity of the document.

5 THE ACCUSED: [Interpretation] Can it be admitted.

6 JUDGE KWON: Yes.

7 THE REGISTRAR: Exhibit D1865, Your Honours.

8 THE ACCUSED: [Interpretation] Thank you. 65 ter 5603, please.

9 MR. KARADZIC: [Interpretation]

10 Q. Please pay attention. On the 23rd of August, the following day

11 that is, Drljaca writes as follows:

12 "We are hereby informing you that the required documentation

13 concerning the prisoners of war who have been transferred from the

14 Omarska investigation centre to the Manjaca prisoner of war camp was

15 forwarded to the commander of the Manjaca prisoner of car camp today."

16 This means that there was intense activity. Do you agree that

17 Omarska was considered an investigation centre rather than a prisoner of

18 war camp?

19 A. I can't confirm that but I know that there were different names

20 used for Omarska and Keraterm such as collection centre or investigation

21 centre, but I don't know what those words mean, nor was I ever there.

22 Q. However, you do agree that this is just part of the activities

23 that were launched by the administration of the detention camp and was

24 supported by the state leadership, the corps command, and Zupljanin?

25 A. As far as this document is concerned, I understand it, and I

Page 20812

1 believe that the papers did arrive after that date at Manjaca in

2 reference to certain people.

3 THE ACCUSED: [Interpretation] Can this be admitted.

4 JUDGE KWON: Yes.

5 THE REGISTRAR: Exhibit D1866, Your Honours.

6 THE ACCUSED: [Interpretation] Thank you. Let me just see how

7 many more documents I have left on this subject. There are just two

8 more. Let's just go through them quickly. 65 ter 5145, please.

9 MR. KARADZIC: [Interpretation]

10 Q. Do you agree that was drafted on the 27th of August and it is

11 about the hand-over of documents, i.e., supplemented lists? The

12 hand-over took place between various police officers? The public

13 security station sent this to the military investigation organs at

14 Manjaca. Is this a proper description of those organs? Did military

15 investigation organs really exist at Manjaca?

16 A. I believe that -- I believe that they used the term very

17 liberally. It doesn't reflect the reality of the situation, if they had

18 in mind what existed up there. Let's not go into private session. I

19 believe that this is a rather arbitrary term.

20 Q. However, they may have considered the processing of prisoners of

21 war investigation; right?

22 A. I believe so.

23 Q. Thank you.

24 THE ACCUSED: [Interpretation] Can this be admitted.

25 JUDGE KWON: Yes.

Page 20813

1 THE REGISTRAR: Exhibit D1867, Your Honours.

2 THE ACCUSED: [Interpretation] Another document on the subject,

3 1D4567.

4 MR. KARADZIC: [Interpretation]

5 Q. Do you remember the crisis in Vecici? Unlike Siparoga [phoen],

6 Vecici would not calm down. They wanted their civilians to be released,

7 they wanted to continue fighting, and now in December people from Vecici,

8 11 people from Vecici were arrested and sent to the camp. Do you

9 remember that?

10 A. I remember that.

11 THE ACCUSED: [Interpretation] Thank you. Can this be admitted?

12 JUDGE KWON: Yes.

13 THE REGISTRAR: Exhibit D1868, Your Honours.

14 THE ACCUSED: [Interpretation] And now let's go back to the

15 conditions that prevailed in the camp. The next document I would like to

16 call up is 1D4568.

17 JUDGE KWON: Ms. Sutherland.

18 MS. SUTHERLAND: Your Honour, I'm sorry to interrupt again, but

19 the witness answered "I remember that," but what's he answering "I

20 remember that" to?

21 "Vecici would not calm down. They wanted their civilians to be

22 released, they wanted to be -- continued fighting, and now in December

23 people from Vecici, 11 people from Vecici were arrested and sent to the

24 camp."

25 JUDGE KWON: Having heard the intervention by Ms. Sutherland, can

Page 20814

1 you help us, Mr. Witness? Would you like to see the document again?

2 THE WITNESS: [Interpretation] There's no need for that. The

3 document was not drafted by me. It speaks about the arrest of 12 people

4 and their bringing in from Vecici to the camp. I remember their arrival

5 and that's what I meant when I said that I remember. As for Vecici,

6 Vecici was one of the strongholds where people put up resistance and

7 inflicted quite a lot of losses to us. The villagers of that village, I

8 (redacted)

9 (redacted)

10 (redacted)

11 (redacted)

12 (redacted)

13 (redacted)

14 (redacted) went to negotiate and after the negotiations he was

15 ambushed and killed; right?

16 A. Yes, that would be the essence of the matter.

17 Colonel Stevilovic, Inspector Markovic, and two chance passengers were in

18 the car, and just outside of Kotor Varos as you are looking down the road

19 from Vecici, they were ambushed by some barricades, they slowed down,

20 three of them were killed and one of them survived and he still lives

21 today. He survived and was imprisoned.

22 THE ACCUSED: [Interpretation] Is this enough for the document to

23 be admitted?

24 JUDGE KWON: Yes, I take it, Ms. Sutherland is now satisfied.

25 Let's proceed with this document.

Page 20815

1 THE ACCUSED: [Interpretation] Can we go to the following page and

2 then to the last page.

3 MR. KARADZIC: [Interpretation]

4 Q. Can you explain for the benefit of the Trial Chamber whether this

5 is true, that the detainees were examined? The first medical examination

6 was carried out on the 11th of June, and the 3.964th patient was examined

7 on the 23rd of August 1992. This means from the 11th of June to the 23rd

8 of August there were 3.964 medical examinations carried out; would that

9 be right?

10 A. That's right. This is a protocol which was maintained by the

11 medical bodies. This describes the examinations of the detainees, they

12 were registered, and this log-book was set up at the moment when the camp

13 was set up and existed until its very end. To this very day, you can

14 find this -- these log-books in our archives.

15 Q. Thank you.

16 THE ACCUSED: [Interpretation] Can this be admitted.

17 JUDGE KWON: This will be marked for identification.

18 THE REGISTRAR: As MFI D1869, Your Honours.

19 THE ACCUSED: [Interpretation] Thank you. I would like to call up

20 1D4562.

21 MR. KARADZIC: [Interpretation]

22 Q. Now we are dealing with the conditions that prevailed in the

23 Manjaca prisoner of -- prisoner of war camp, and we are dealing with the

24 reports on the conditions that prevailed in the camp. Those are daily

25 and periodical reports. This was drafted on the 18th of June, and again

Page 20816

1 you can see that Merhamet arrived to visit. I believe that this has been

2 admitted, that we have seen it already.

3 JUDGE KWON: Yes, [Microphone not activated] today.

4 THE ACCUSED: [Interpretation] I believe that the following one,

5 1D4565 has also been admitted. Can you please confirm that?

6 JUDGE KWON: Exhibit D1861.

7 THE ACCUSED: [Interpretation] Thank you. Can we look at 1D4569.

8 MR. KARADZIC: [Interpretation]

9 Q. Is this a record of the hand-over of medical equipment and

10 medicines that Merhamet brought to the camp on the 24th of June?

11 Everything is registered.

12 THE ACCUSED: [Interpretation] Can we go to the following page.

13 And then the third page.

14 MR. KARADZIC: [Interpretation]

15 Q. Let's see who received the medical supplies and medicines. Could

16 you please look at the page.

17 THE ACCUSED: [Interpretation] Can the page be rotated.

18 MR. KARADZIC: [Interpretation]

19 Q. Does it say here that the record of the medical supply was taken

20 by Dr. Mehmed Derviskadic and nurse Bozana Pavljanin. Was Bozana

21 Pavljanin an employee and was Dr. Mehmed Derviskadic a detainee who

22 worked as a doctor in the camp? Can you tell us that?

23 A. Mehmed Derviskadic was a physician by profession, and he was used

24 up there as a general practitioner in the camp. There was also Enes

25 Sabanovic who was a physician. They were both professionals. They had

Page 20817

1 good bedside manners, they were very humane, and they applied everything

2 that they had learned at medical school and when they took the

3 hypocrit's [as interpreted] oath. Nurse Bozana Pavljanin was up there at

4 the time. The camp administration changed the -- there was also

5 Aleksandra Bijelic who replaced Bozana Pavljanin from time to time. In

6 any case the two doctors were there throughout the existence of the camp.

7 Q. Since the other participants in this trial don't know much about

8 the names in the former Yugoslavia, can you confirm that the two

9 physicians were Muslims?

10 A. The two physicians were detainees of Muslim ethnicity. In the

11 text I can see the name Aleksic. If it means anything -- or rather in

12 the transcript, I can see the name "Aleksic" but it was

13 Aleksandra Bijelic. I don't know if that means anything.

14 Q. In the transcript it says that Aleksandra Bijelic would replace

15 Bozana Pavljanin from time to time; is that correct?

16 A. Yes, that's correct.

17 THE ACCUSED: [Interpretation] Could this be admitted.

18 JUDGE KWON: This would be admitted as Exhibit D1870. And we'll

19 take a break now for half an hour and resume at half past 12.00.

20 --- Recess taken at 12.01 p.m.

21 --- On resuming at 12.31 p.m.

22 JUDGE KWON: Yes, Mr. Karadzic.

23 THE ACCUSED: [In English] Thank you, Your Excellency.

24 [Interpretation] May I have 1D45775 [as interpreted] briefly, and

25 we can add it to the document that has already been admitted.

Page 20818

1 THE REGISTRAR: Mr. Karadzic, could you repeat the number,

2 please.

3 THE ACCUSED: [Interpretation] 1D4575.

4 MR. KARADZIC: [Interpretation]

5 Q. Do you agree, Mr. Witness, that this is a sequel to that protocol

6 of systematic health examinations in Manjaca?

7 THE ACCUSED: [Interpretation] Can we have the next page, please.

8 MR. KARADZIC: [Interpretation]

9 Q. Does this include each and every diagnosis, and did those two

10 Muslim doctors who were prisoners sign this document? You can see that,

11 can you not?

12 A. Yes, that's right. This is a continuation. Lest there be any

13 confusion regarding the number 8.000 something, some prisoners reported

14 for medical examinations several times whereas others never asked for a

15 medical examination. So this is the number of medical examinations that

16 were carried out by the doctor, and the signatures are basically the

17 signatures of the two doctors.

18 Q. Thank you.

19 THE ACCUSED: [Interpretation] Can we have the last page. Can we

20 have a look at the last number.

21 MR. KARADZIC: [Interpretation]

22 Q. So what is written here is 8064 -- no, 34. That's the last

23 digit; right? You would be able to see it if we could zoom in. 8.033

24 and 8.034. That's right. So there were 8.034 medical examinations, and

25 as you said a few moment ago, some persons were examined several times;

Page 20819

1 right?

2 A. That's right.

3 Q. Thank you.

4 THE ACCUSED: [Interpretation] Excellencies, D869 as MFI'd, should

5 this be added to that, or should a new number be assigned altogether?

6 There is a translation. Actually, we don't need an MFI, we have a

7 translation.

8 JUDGE KWON: I don't think I followed. MFI D869.

9 Yes, Ms. Sutherland.

10 MS. SUTHERLAND: Your Honour, Mr. Karadzic put to the witness an

11 earlier protocol and because that didn't have an English translation that

12 was MFI'd, and Mr. Karadzic wants to know whether we can -- whether he

13 can add this to that exhibit or this gets a new exhibit number and it

14 doesn't --

15 JUDGE KWON: I take it this is a separate document?

16 MS. SUTHERLAND: Yes, it is, and I think it should have a

17 separate exhibit number.

18 JUDGE KWON: Yes, we'll give a new number.

19 THE REGISTRAR: Exhibit D1871, Your Honours.

20 THE ACCUSED: [Interpretation] Thank you. Can we have a look at

21 65 ter 5612.

22 MR. KARADZIC: [Interpretation]

23 Q. Please focus your attention on this. Do you agree that this is a

24 report on a discussion with the ICRC, that is to say between the

25 representatives of the ICRC and the representatives of the 1st Krajina

Page 20820

1 Corps command? Mr. Kalinic was there, he was health minister of the

2 government Republika Srpska, then the prime minister of the autonomous

3 Republic of Krajina, Erceg. Please take a look at this document. Then

4 it says here that Mr. Germont insisted on the unambiguous implementation

5 of the London agreement, and then it says what was discussed, and the

6 Serbs asked for lists of detained Serbs in Tomislavgrad, Bugojno,

7 et cetera. Can you see this document? And also what was discussed then

8 was the disbanding of Manjaca, Trnopolje, and this is what was agreed

9 upon and then that is actually what is written there, what was agreed

10 upon. Actually, can we scroll down on the English side a bit.

11 A. Yes, I see that. Throughout the existence of the camp for months

12 there was mention of a disbanding of the camp in exchange of all for all.

13 I remember this and that would be it.

14 Q. Thank you.

15 THE ACCUSED: [Interpretation] Can we have the next page.

16 MR. KARADZIC: [Interpretation]

17 Q. What does this say in paragraphs 5 and 6, that Kalinic, Minister

18 Kalinic submitted a list of prisoners in the camp and number 6 says:

19 "During the day, at his explicit wish, the chief monitor of

20 implementation of the London Conference visited the Manjaca prisoner of

21 war camp accompanied by Colonel Milutin Vukelic" who signed this.

22 And then on the next page it says that a person was seriously

23 wounded by his father before the war operations started and you took care

24 of this person; right? Actually, it's the medical service that took care

25 of this person; right?

Page 20821

1 A. That's right.

2 THE ACCUSED: [Interpretation] Thank you. Can this be admitted.

3 JUDGE KWON: Yes.

4 THE REGISTRAR: Exhibit D1872.

5 THE ACCUSED: [Interpretation] Thank you. 65 ter 5625. Could we

6 please have a look at that.

7 MR. KARADZIC: [Interpretation]

8 Q. You mentioned the work conducted by the prisoners and you

9 mentioned today that some of them volunteered. Did they like going out?

10 Did they volunteer? Did they realise that they would get extra benefits

11 on account of that?

12 A. Yes, prisoners were used for farm work basically, digging

13 potatoes, chopping firewood, actually, for heating the camps so for

14 themselves. (redacted)

15 because there was no central heating. When people were assigned to leave

16 camp in order to work, it was basically done by seeing who would

17 volunteer. Usually, many more people would volunteer than were actually

18 needed. Actually, being in confined quarters all day was not pleasant

19 and people were relatively young and healthy and they wanted to get out.

20 So basically it was people who volunteered.

21 Q. Thank you. It says here that Colonel Vukelic says that this is

22 in accordance with the Geneva Conventions because what they would be

23 doing has nothing to do with combat whatsoever; right? The second

24 paragraph, not for purposes of war and the conduct of combat operations.

25 You see what it says here:

Page 20822

1 "The use of prisoners of war does not run counter to the

2 provisions," et cetera?

3 A. I'm just waiting for the transcript to finish. That's why I'm

4 waiting. Of course I have an answer. Vukelic was assistant commander

5 for moral guidance in the corps, and he's the one who would usually give

6 his approval for this kind of thing. It would seem that somebody else

7 had asked for this approval to have these persons used for some physical

8 labour and then Vukelic approved of it. He would sign this kind of

9 document. That is the way things worked.

10 THE ACCUSED: [Interpretation] Thank you. Can this be admitted.

11 JUDGE KWON: Yes.

12 THE REGISTRAR: Exhibit D1873, Your Honours.

13 THE ACCUSED: [Interpretation] Thank you. Can we have 1D4576.

14 MR. KARADZIC: [Interpretation]

15 Q. Please take a look at this. It's a report of the Red Cross.

16 They are saying that in accordance with the agreement reached on the

17 6th of June, 1992, that was signed by Mr. Kalinic on my behalf, so

18 delegates of the Red Cross were allowed access to POWs in Manjaca for the

19 seventh time already. And it says here the ICRC avails itself of this

20 opportunity to extend their thanks for the full co-operation extended to

21 them during their visit. Is that what they said to you? Did they say

22 when they saw you how grateful they were for this co-operation?

23 A. Yes, they came six times by this point in time. Every time -- or

24 actually, not exactly every time. They wrote these work reports and

25 sometimes they would submit copies even to us, to the corps command,

Page 20823

1 probably more often. And they described the situation, as they say here,

2 sometimes as a matter of courtesy and sometimes they extended their

3 sincere thanks for this co-operation and so on. I usually did not attend

4 these meetings. For the most part, was it the camp commander who would

5 receive representatives of the International Red Cross Committee.

6 Q. Thank you. Please focus on paragraph 2.

7 THE INTERPRETER: Interpreter's note: Could we please have the

8 appropriate page in English.

9 MR. KARADZIC: [Interpretation]

10 Q. The next one where it says they would be informed about transfers

11 and so and so forth. And then it says:

12 "The ICRC welcomed this move as a confirmation of future

13 readiness by top authorities in Banja Luka and the camp administration in

14 Manjaca to fully abide by the 3rd and 4th Geneva Conventions."

15 Is this an indication of the readiness of the authorities in

16 Banja Luka because the AR Krajina was very strong at that point in time

17 and also because Krajina had not had any contacts with Pale -- rather,

18 there weren't any good communications, there weren't any proper

19 communications running at the time?

20 A. This happened precisely at the time when there was this

21 interruption in our communications, rather the corridor was sealed off so

22 decisions had to be made at these local levels; in this case, at corps

23 level. Also the local authorities had to make decisions. There were

24 some telephone communications, but I cannot say anything about that. So

25 what is written here is reality as it was at the time.

Page 20824

1 Q. Thank you.

2 THE ACCUSED: [Interpretation] Can we have the last page, please.

3 Number 7 in paragraph 7, so we need page 7 in the English original as

4 well. Then it's the penultimate page in English, actually.

5 MR. KARADZIC: [Interpretation]

6 Q. Do you agree that what is stated here, that 44 sick prisoners

7 were evacuated from the Manjaca camp to Banja Luka airport under ICRC

8 supervision, and then it says the ICRC would like to thank

9 Commander Popovic and his associates for their excellent co-operation and

10 help during the whole operation. And then further on it says -- it says

11 that the situation has been stabilised to a certain extent and that

12 Dr. Emir Kapitanovic [phoen], one of the physicians involved in the

13 examinations, was released on the 16th of September, and then there are

14 other references to health related needs. Does this correspond to things

15 as they actually were?

16 A. Yes, this corresponds to the truth. Or rather, what happened at

17 the time.

18 Q. Thank you.

19 THE ACCUSED: [Interpretation] Can this be admitted.

20 JUDGE KWON: Yes.

21 THE REGISTRAR: Exhibit D1874, Your Honours.

22 THE ACCUSED: [Interpretation] Then may I ask for your approval --

23 JUDGE KWON: Ms. Sutherland.

24 MS. SUTHERLAND: Your Honour, I would ask for a redaction on page

25 57, line 13 at least on my LiveNote. There's a few words after the word

Page 20825

1 "themselves."

2 JUDGE KWON: Very well.

3 Yes, Mr. Karadzic.

4 THE ACCUSED: [Interpretation] I have a similar document. 1D4577.

5 If the witness could look at it so we don't have to offer it as a bar

6 table motion. Another visit and another extension of thanks. 1D4577.

7 MR. KARADZIC: [Interpretation]

8 Q. Another report. It says again that the visits are made based on

9 the agreement of 6 June signed by Dr. Kalinic in my name.

10 THE ACCUSED: [Interpretation] Can we see page 6. Or rather, the

11 last page.

12 MR. KARADZIC: [Interpretation]

13 Q. Would you agree that they are thanking the commander and the

14 military administration for their co-operation, and they say it's agreed

15 that the visits would be made twice a month in future. And then we see a

16 table of all that the ICRC had brought, food, shoes, et cetera. Is this

17 correct?

18 A. Yes, this is authentic and it is consistent with the truth.

19 Q. Thank you.

20 THE ACCUSED: [Interpretation] Can this be admitted.

21 JUDGE KWON: Yes.

22 THE REGISTRAR: Exhibit D1875, Your Honours.

23 THE ACCUSED: [Interpretation] 1D4578 is the next document I would

24 like to look at dated 18 November, another report from the ICRC, just the

25 first and the last pages.

Page 20826

1 MR. KARADZIC: [Interpretation]

2 Q. This is --

3 THE ACCUSED: [Interpretation] May I ask for the second page,

4 please.

5 Q. This is a report on the visit from the 5th to the 18th November,

6 so they stayed for 13 days on this occasion; right? Look at this, the

7 highlighted passage: Commander Popovic described his difficulties. One

8 of his men died at Manjaca because he could not be transported to the

9 hospital on time. Colonel Djikic, chief of the medical unit, should, in

10 co-operation with the military command in Banja Luka, be contacted in

11 order to find solutions. There's also a shortage of fuel. Winter is

12 approaching fast. Do you know about this case when one employee died

13 because he could not be taken to hospital on time?

14 A. Yes, these problems described by Popovic were real problems,

15 existential problems, and that's why he was trying, also through the

16 ICRC, to get some assistance, and that death really happened. I wasn't

17 there but it was an NCO serving in the logistics. He had a stroke or

18 perhaps a heart attack, and if he could have been transported to the

19 hospital on time, maybe he would have lived. That's true.

20 Q. The last page refers to the evacuation of 700 prisoners, food

21 supplies would be adjusted. There's a reference to the tonnes of food

22 handed over. That's the last page.

23 THE ACCUSED: [Interpretation] And then I would kindly ask that

24 this be admitted. Here we have a list of tonnes provided, and it says

25 after the evacuation of 700 prisoners the quantity of food will be

Page 20827

1 provided accordingly.

2 JUDGE KWON: Exhibit D1876.

3 Mr. Karadzic, you will have about less than 15 minutes to

4 conclude your cross-examination.

5 THE ACCUSED: [Interpretation] Very well then. I have to move to

6 another subject. And with your leave, 1D4579 briefly, please.

7 MR. KARADZIC: [Interpretation]

8 Q. Daily report at the time of the visit by Mr. Viesel. Do you

9 recall that Mr. Viesel was free to speak to anyone he wished in the

10 absence of the guards and that he could stay as long as he wished? And

11 he did stay as long as he wanted to. He wanted to tour one of the

12 facilities and he did. It was decided that it would be the third

13 pavilion and that's the one he toured. Do you remember that?

14 A. Yes, he was accommodated and he was free to contact the prisoners

15 that he wished to interview and speak to.

16 JUDGE KWON: Yes, Ms. Sutherland.

17 MS. SUTHERLAND: Does Mr. Karadzic have the complete document?

18 THE ACCUSED: [Interpretation] Unfortunately no, I don't have the

19 page with the signature. Page 2.

20 JUDGE KWON: Very well.

21 THE ACCUSED: [Interpretation] Can this be admitted.

22 JUDGE KWON: Yes.

23 THE REGISTRAR: Exhibit D1877, Your Honours.

24 THE ACCUSED: [Interpretation] Thank you.

25 MR. KARADZIC: [Interpretation]

Page 20830

1 it did. I don't know to what extent it was deliberate.

2 Q. On the previous page it says "report on the events in Banja Luka

3 from 11 to 19th September -- 10 to 19 September." Let's find the line

4 which begins with 10 September.

5 "In the morning of 10 September, individuals wearing uniforms

6 occupied the main cross-roads..."

7 THE INTERPRETER: The interpreters have lost the page now.

8 JUDGE KWON: Why did we change the English page? Probably next

9 page.

10 THE ACCUSED: [Interpretation] Yes. From the top.

11 MR. KARADZIC: [Interpretation]

12 Q. "In the morning of 10 September ..." Please read the Serbian

13 version. Do you need it enlarged?

14 A. I believe we have now the wrong page in Serbian too.

15 THE ACCUSED: [Interpretation] Yes, we should go one page back, to

16 the previous one. No, the first thing that was shown, the top beginning

17 with 10 September. This is not it. Page 4. This is it.

18 MR. KARADZIC: [Interpretation]

19 Q. Is it true that they did all this, they arrested everyone from

20 the building of the corps command, disarmed them, occupied the Security

21 Services Centre, took into custody the president of the municipality, the

22 president of the SDS, other public officials, tried to take over the TV

23 relay at Kozara, and the Crisis Staff of the 1st Krajina Corps appeared

24 in public and soon afterwards changed its name to the Crisis Staff of the

25 Army of Republika Srpska, which had its own seal. It was named the

Page 20831

1 Operation September 93. Do you agree it was a major crisis that

2 threatened us with complete destruction?

3 A. I remember this. Everything happened as described here, and I

4 was wondering to myself whether at this time of major crisis we really

5 needed the added complication of internal conflicts within the army or

6 the state leadership. Yes, it's exactly as written here.

7 Q. Could you please look at this passage:

8 "Operation September 93 ended on 17 September..."

9 It also says that I, myself, led the action to put an end to this

10 along with the highest representatives of the army, the Ministry of the

11 Interior, the national security.

12 A. That's correct. But I have to stress that Banja Luka was blocked

13 at the time and General Mladic was the first to come in. I don't know

14 about your activities, but I was there very close to General Mladic when

15 he managed to get the men to stop all that and go back to their combat

16 assignments.

17 THE ACCUSED: [Interpretation] Can this document 17763 be

18 admitted.

19 JUDGE KWON: Yes.

20 THE REGISTRAR: Exhibit D1878, Your Honours.

21 THE ACCUSED: [Interpretation] I would like to call up 65 ter

22 13352.

23 MR. KARADZIC: [Interpretation]

24 Q. While we are waiting, do you agree that this called for my

25 engagement in those military matters in view of the danger that

Page 20832

1 threatened to escalate?

2 A. I agree, Mr. Karadzic. I know that you were at the forward

3 command post in Prnjavor, that was a forward command post of the

4 1st Krajina Corps. I know that you came to a facility near Banja Luka

5 and that you tried to deal with the situation. I don't remember what

6 facility that was.

7 Q. Thank you. Please pay attention to my order to set up the staff.

8 I say here that I will personally command the staff and the staff will

9 comprise of the following: Myself, Milovanovic [as interpreted], Mladic,

10 all the way up to Zupljanin, and then I also ordered to raise combat

11 capabilities of police and military units. I ordered that I would be the

12 only one to be able to order movements, that reports should be sent, and

13 so on and so forth. Do you agree that that was necessary in order for

14 the crisis to be brought to an end peacefully without any bloodshed?

15 A. Yes. Fortunately enough, no blood was shed. If blood had been

16 shed, there would be no end to the whole crisis. Obviously you got

17 involved to deal with the situation and the situation was dealt with as

18 it was luckily enough.

19 Q. Thank you. Do you remember that ever again, save for those seven

20 or ten days, I took it upon myself to be in command at the tactical and

21 operative level? Was that the one and only time, according to what you

22 know, that I got involved in command duties?

23 A. I can't remember that that was the one and only time that that

24 happened, but in my view it was only logical that the superior person

25 which is the supreme commander, if there was a problem or an incident in

Page 20833

1 lower units, could jump in and deal with the situation, so I don't deem

2 this to have been a big mistake, but that's just me.

3 Q. Thank you.

4 THE ACCUSED: [Interpretation] Can this be admitted.

5 JUDGE KWON: Yes, we'll admit at Exhibit D1879. And,

6 Mr. Karadzic, it's time for you to wrap up.

7 MS. SUTHERLAND: Your Honour, I note that there's two documents

8 that are contained in the B/C/S version that was uploaded in e-court.

9 The document that's been shown to the witness, but there's also on page 2

10 and 3 in e-court another document which a different date on it, so I

11 suggest that only this first page is tendered -- is admitted into

12 evidence.

13 JUDGE KWON: I agree. We'll do that.

14 THE ACCUSED: [Interpretation] I will now show you 65 ter 32300.

15 MR. KARADZIC: [Interpretation]

16 Q. The date of the document is 15 September 1993. 15 September

17 1993. Could you please look at the document and tell me whether you

18 agree that it says here that there was a conversation between myself and

19 General Milovanovic. I was probably in Geneva attending negotiations.

20 There was a reference to here that a similar thing happened on the 14th

21 of September at Pale. That soldiers were shooting, that they were saying

22 this is Banja Luka, and so on and so forth. Do you agree that that event

23 indicated that the flame of rebellion could spread?

24 A. I can't answer positively to your question because I'm not

25 familiar with the event. I'm also not familiar with the document so I

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1 can't say yes to your question.

2 Q. Thank you.

3 JUDGE KWON: I'm not sure whether if this witness is a proper

4 witness to deal with that matter. It's time for you to conclude.

5 THE ACCUSED: [Interpretation] Thank you.

6 MR. KARADZIC: [Interpretation]

7 Q. Witness, instead of putting a question to you, I would like to

8 express my gratitude to you for having been very strict and very

9 consistent in your activities. You should be proud of that but the

10 Republika Srpska should also be proud of what you did. Did you have a

11 feeling at the time that your attitude which was precise, strict, and

12 consistent was in favour of the Republika Srpska and that that was in

13 keeping with the policies of the Republika Srpska?

14 A. I didn't do anything for my own sake. I did everything for the

15 people, for the Republika Srpska. If a similar situation arose again, I

16 believe that I would -- did everything in the same way. I don't think I

17 was particularly heroic in what I did. I don't think that other people

18 wouldn't do the same. But let me tell you this: Whatever I learned

19 throughout life and at school, I tried to apply all of my knowledge in

20 such specific circumstances.

21 THE ACCUSED: [Interpretation] Your Excellency, I have a few more

22 documents left, but I will try to tender them in a different way.

23 MR. KARADZIC: [Interpretation]

24 Q. Just one more question, did you suffer any pressure? Was any

25 pressure put to you on the part of the state leadership or the military