130131ED

Page 32985

1 the duty of operative employee in Ilidza. After a while, at the end of

2 1992, he was appointed head of department of Ilidza National Security

3 Service Office.

4 The SNB become aware that the Muslims and the Croats were arming

5 en masse through the BH Territorial Defence and through -- at the

6 beginning of 1991 and, in addition, that the paramilitary units of the

7 Patriotic League and the Green Berets were established. They also

8 received informations that the BH army in Sarajevo was manufacturing

9 ammunition and weapons. The SNB received intelligence that Muslim forces

10 had many more weapons than the VRS.

11 Before the beginning of the war, the Muslims and the Croats made

12 it clear they would jointly act against the Serbs. They produced with --

13 proceeded with referenda and proclaimed independence without the

14 agreement of the Serbs. Further, a large number of foreign nationals

15 joined BH army units and some used to train Muslims to kill Serbs. The

16 SNB were also aware of criminal groups who were in the service of

17 official politics.

18 During the fighting, the Serbs were under a media blockade while

19 the networks of -- in the BH portrayed a false picture, demonising the

20 Serbs and showing the Muslims to be the victims. Anti-Serbian propaganda

21 was omnipresent in Sarajevo; the Serbs lived in constant and great fear.

22 After the killing of a Serb wedding guest in Sarajevo, it became clear to

23 Serbs that laws did not apply to Muslims. Foreign reporters were under

24 pressure from organs in Sarajevo and mainly filed rigged reports; a

25 number of the incidents which the Muslims were responsible for were

Page 32986

1 portrayed as Serb actions.

2 Reports were received daily about shelling which targeted Serb

3 settlements and civilians with many casualties. A number of countries

4 violated the arms embargo. Those countries were mainly Muslim countries.

5 The Republic of Croatia also violated the embargo despite the UN Security

6 Council Resolutions. A member of BH Presidency, Ivo Komsic, also abused

7 his office and violated the embargo.

8 Butmir airport was handed over to demonstrate good will and to

9 calm the conflict down, allowing -- the Serbs handed it over to the

10 United Nations, allowing the unimpeded supply of humanitarian aid.

11 However, humanitarian workers were under the control of Muslim state and

12 military security. They carried messages, weapons, intelligence,

13 financial information, food and other materials, and the aid would be

14 smuggled or sold on the black market and hardly ever distributed

15 correctly. Muslim forces abused their freedom of movement via Butmir

16 airport, launching offensive actions from this location. With the help

17 of the UNPROFOR, they would cross the runway unimpeded, whereas Serb

18 forces would have to take a detour even for humanitarian aid. UNPROFOR

19 forces provided the Muslim side with information regarding the condition

20 of the VRS units and the weak points which were then exploited in

21 offensive actions of the Muslim army.

22 Muslim authorities did not allow Muslim residents to leave the

23 town. In Sarajevo, Muslim forces would frequently fire from and also

24 target civilian facilities including schools and hospitals. The SNB

25 possessed extensive information about the indiscriminate fire which would

Page 32987

1 often kill and wound both children and civilians.

2 The security service, after the multi-party elections, had

3 already begun segregating people on the basis of ethnicity and Serb

4 employees had privileges removed. When Alija Izetbegovic assumed power,

5 he immediately embarked on forming his State Security Service and this is

6 how the SDA and HDZ managed to gain control of all important

7 institutions. JNA facilities and units were under constant surveillance

8 immediately following the end of the multi-party elections. Blockades

9 and attacks followed in April and May 1992.

10 The SNB were aware of Muslim plans for ethnically cleansing Serbs

11 from Ilidza and Sarajevo and passed this information on; however, this

12 could not be acted upon before the war polarised on ethnic grounds.

13 Srdjan Sehovac had information that on a number of occasions,

14 through mass media, President Karadzic ordered that non-Serbs must not be

15 abused and maltreated. There were no indications in any written document

16 or oral order from the higher command of actions being planned for the

17 permanent removal of Muslims and Croats from areas in which the RS

18 effectively exercised power. As far as Srdjan Sehovac is aware, neither

19 he nor the SNB ordered, either orally or in writing, that attacks should

20 be carried out on civilians in the Muslim-controlled part of the city.

21 And that would be the summary. Now I would like to deal with a

22 few documents. I would ask Mr. Robinson to inform about a few documents

23 that we give up --

24 MS. WEST: Pardon me.

25 JUDGE KWON: Yes, Ms. West.

Page 32988

1 MS. WEST: Good morning, Mr. President, Your Honours. I'm sorry

2 for this interruption. I make this point only because I'm not clear that

3 Mr. Karadzic was conscious of this, but as we all know, a motion was

4 filed before regarding a number of irrelevant paragraphs in this

5 statement. When Mr. Karadzic read out his summary, I noted, for example,

6 in particular page 2, line 22, he included some information that was

7 excluded by the motion. So I would only say that now because I'm unsure

8 as to whether this summary was written before the motion and we would

9 just ask Mr. Karadzic to take care next time this happens.

10 JUDGE KWON: Thank you. I didn't pay attention to that point.

11 Did you follow, Mr. Karadzic?

12 THE ACCUSED: [Interpretation] Yes. Yes, Your Excellency, but

13 this really was made before and the workload is such that we don't have

14 time to change it afterwards.

15 JUDGE KWON: So we'll deal with the associated exhibits at the

16 end of your examination-in-chief. Those -- do you have any objection to

17 the admission of those items not referred to yesterday by me, Ms. West?

18 MS. WEST: None as to the ones not referred by you.

19 JUDGE KWON: If -- but there are certain items to be given up,

20 Mr. Robinson?

21 MR. ROBINSON: Yes, Mr. President. With respect to the two

22 documents that you indicated you wanted to know the relevance of, we're

23 not going to lead any evidence on those and we will withdraw, that's

24 number 1D6132 and 1D6134. And there will be three documents that will be

25 led live and the others will be withdrawn.

Page 32989

1 JUDGE KWON: How about the intercept?

2 MR. ROBINSON: That will be one of them that will be led live,

3 6136.

4 JUDGE KWON: And I referred to three -- four documents in total.

5 MR. ROBINSON: That's correct. We will also lead live 1D0921 and

6 that -- the other documents on our list of associated exhibits will not

7 be -- they'll be withdrawn. There will also be one other document that

8 Dr. Karadzic wishes to lead live that was not part of our associated

9 exhibits. So there will be three documents that will be led live and the

10 rest we are withdrawing.

11 JUDGE KWON: Just let me be clear how about 6133 and 6167?

12 MR. ROBINSON: Yes, we are not going to -- we withdraw those.

13 JUDGE KWON: Two items.

14 MR. ROBINSON: So we'll admit all the remaining associated

15 exhibits and give numbers in due course.

16 MS. WEST: And I understand Mr. Robinson indicated there will be

17 another document that's not an associated document that will be used.

18 MR. ROBINSON: That's correct. I'm advised that 1D378 will be

19 used.

20 JUDGE KWON: Yes. Please continue, Mr. Karadzic.

21 THE ACCUSED: [Interpretation] Thank you.

22 MR. KARADZIC: [Interpretation]

23 Q. Mr. Sehovac, in what way did the SNB arrive at information?

24 A. Well, you see, in its work, the SNB used mostly well-known police

25 methods. In this war situation, the most frequent method was interviews

Page 32990

1 with refugees or defectors from the territory controlled by Muslim

2 soldiers and using operative technical measures. These measures involved

3 intercept centres and radio reconnaissance centres. We also arrived at

4 information using our people who spoke foreign languages well and were

5 deployed at certain points in the course of the war.

6 Q. Thank you.

7 THE ACCUSED: [Interpretation] May we have 1D06136. Can we have

8 pages 2 and 3.

9 MR. KARADZIC: [Interpretation]

10 Q. Do you recognise this document, first of all, and this form of

11 document?

12 A. This document was drawn up in the SNB Ilidza department.

13 Q. Thank you.

14 THE ACCUSED: [Interpretation] Can we have the next page?

15 MR. KARADZIC: [Interpretation]

16 Q. Can you tell us whether this is your signature and what is on

17 this page?

18 A. This is my signature. All the documents -- when I became chief

19 of the SNB Ilidza department, the procedure was that all documents had to

20 pass through my hands; and then, as there was a narrow circle of people

21 leading the department, we would agree on what to do with the document.

22 They were mostly for information and all things that had to do with

23 military or civilian security were passed on to the persons who had to be

24 informed at that point in time.

25 Q. Thank you.

Page 32991

1 THE ACCUSED: [Interpretation] Can we have the next page, please?

2 MR. KARADZIC: [Interpretation]

3 Q. Can you tell us, this first and second conversation that were

4 intercepted, can you tell us what this is all about?

5 A. In this conversation, Vehbija Karic, who was the commander of the

6 1st Corps of the so-called ABiH, Army of Bosnia-Herzegovina, and a

7 certain Mole [as interpreted] from Hrasnica are talking. They're

8 mentioning the kinds of weapons they have, the sort of ammunition they

9 have, how much they have, and where to use that. This is just a summary.

10 As I can't see very well, if we could zoom in a little bit.

11 Q. They're mentioning big babies here. What are those to the best

12 of your knowledge?

13 A. These are large-calibre shells for guns, howitzers, and multiple

14 rocket-launchers or we call them Plamen, flame.

15 Q. And who is saying that this has been used up, the one from

16 Hrasnica?

17 A. Yes, Vehbija Karic is asking for support and the other one is

18 saying, "We used it all up," and he's explaining about T-12 and so on.

19 Q. Thank you.

20 THE ACCUSED: [Interpretation] Can we scroll up a little? Or

21 scroll down, in fact.

22 MR. KARADZIC: [Interpretation]

23 Q. What is this other conversation on this page?

24 A. It's between Sead Rekic and Vehbija Karic, and he's checking

25 whether they have used up all the shells and how it is that there are

Page 32992

1 none left because there were 40 of them. And the other one is saying he

2 doesn't know who used them up. Fikret, the commander of the so-called

3 army, that is, the unit that was in Hrasnica at the time.

4 Q. So Karic is asking that Fikret should see how many 120 shells are

5 left?

6 A. Yes.

7 Q. Did you know that Hrasnica was supplied with large-calibre

8 weapons and that they were using the ammunition in this way?

9 A. Well, the area we were in was exposed every day. It was below

10 Hrasnica. Hrasnica had their places at Igman and they could see Ilidza.

11 It was -- they had a good view of Ilidza. So every day we could see that

12 they had a lot of ammunition, that these were very destructive shells,

13 because you could see the damage at Ilidza.

14 Q. Yes, it seems that in the transcript it doesn't say that Ilidza

15 was shelled from Hrasnica daily and you said that. So we have to make

16 breaks and speak less quickly, both of us.

17 Can you repeat what you said? You said something that they had a

18 good view?

19 A. Well, you see, the Serbian positions at Ilidza were in a valley

20 and those were the demarcation lines. They were some 50 or a hundred

21 metres different from trench to trench. The Muslims had a certain

22 advantage because they had Mount Igman behind their backs, and from

23 Mount Igman you had an excellent view of all of Ilidza. They could see

24 Vojkovici, Lukavica, Hadzici, Rajlovac, that entire part of Sarajevo with

25 the exception of the part beyond Vrace and that was already under the

Page 32993

1 control of Muslim forces.

2 Q. Thank you. Is S saying that he thinks there are quite a lot of

3 those 120-millimetre shells?

4 A. Yes --

5 MS. WEST: Objection.

6 THE WITNESS: [Interpretation] -- he's saying there are enough of

7 them, yes.

8 JUDGE KWON: Let's continue, yes.

9 THE ACCUSED: [Interpretation] Thank you.

10 Can we have the next page.

11 MR. KARADZIC: [Interpretation]

12 Q. Can you tell us who -- who is talking in this intercept, what

13 it's about. You don't have to mention every amount and calibre, but just

14 tell us who has these weapons and what this is.

15 A. Well, the conversation is between Vehbija Karic and assistant

16 Nole [phoen] from Hrasnica. It says what the frequency for contact

17 between Hrasnica and Sarajevo is, and there is a list of the shells they

18 have, for what weapon, 20 -- 220, 37-millimetres. And then there are 42

19 [as interpreted], and so on. I can read this out. 130-millimetres,

20 122 pieces; RPG, 120 pieces, and so on.

21 He says that there are no 60-millimetre shells, and that's

22 indicative because those were used every day. That was a movable mortar

23 which could be put on a vehicle and you could drive it around and they

24 frequently fired from it.

25 Q. Thank you. To the best of your knowledge, this 130-millimetre,

Page 32994

1 is that the howitzer? Are those howitzer shells?

2 A. You see, I can't say precisely. I'm not really familiar with

3 artillery weapons, but this is the document. This is what they were

4 saying. It was recorded word for word.

5 Q. How did you make these recordings? How were these conversations

6 recorded?

7 A. Well, in the -- on the premises of the SNB where our

8 reconnaissance centre was, there was a room which was equipped for

9 recording. Telephone conversations were mostly recorded on a cassette

10 player, UHER. It records only while the conversation is going on, and

11 then you could listen to the reproduction and there were employees

12 writing this down; and then it was sent on to where we thought it should

13 be sent.

14 Q. Thank you.

15 THE ACCUSED: [Interpretation] Can we briefly take a look at the

16 next page.

17 MR. KARADZIC: [Interpretation]

18 Q. Who is talking here and what are they talking about in brief?

19 A. This is a conversation between Mirso and a member of the

20 Territorial Defence staff in Hrasnica and Nisko. They're saying: Are we

21 going to talk this evening? At what time? Have you let the people rest?

22 Have you let the men rest?

23 In this second part, it's a conversation between Fikret Prevljak,

24 the commander of the Hrasnica TO, and Mehic, that's UNO 1, that was an

25 operations centre of theirs, where it says:

Page 32995

1 "You have called about those co-ordinates, the position ..." and

2 so on. "I have instructions" --

3 Q. Well, just can you tell us where it says "Rajlovac," what this

4 refers to.

5 A. Well, he says: We covered Rajlovac last night from up there with

6 105 and 155 millimetres. Well, this means, well, the night before there

7 was an attack on Rajlovac and they provided artillery support from the --

8 the elevation at Mount Igman from where you can have a good view of all

9 of Rajlovac, and above Rajlovac there's another hill which was under

10 their control where they also had weapons and fired from artillery

11 weapons and the name of the hill is Sokolj.

12 Q. Thank you.

13 THE ACCUSED: [Interpretation] I tender this into evidence.

14 JUDGE KWON: Mr. Karadzic, all the witness said about this

15 document, which seems to be the transcript of intercepted conversation,

16 was that all the documents had to pass through his hands. I'm not sure

17 that statement sufficiently authenticates the intercepts according to our

18 practice. I'd like to hear about how the intercept operators worked,

19 whether he was in charge with interception. How can we guarantee the

20 authenticity of these conversations in terms of, i.e., whether they

21 are -- they were precise or not. Do you follow, Mr. Karadzic?

22 THE ACCUSED: [Interpretation] Thank you.

23 MR. KARADZIC: [Interpretation]

24 Q. Mr. Sehovac, what was your role in the service, in your

25 department, and what was your participation in controlling what you

Page 32996

1 signed?

2 A. I was head of department, meaning that all of the services acting

3 in Ilidza were under my control.

4 Q. Thank you. What about the operative who did the recording, could

5 he sign in your stead or who was the only person authorised to sign

6 documents?

7 A. The operative recording everything noted it down in handwriting,

8 then we had a typist who would type it up and I signed them. The

9 handwritten notes were signed by the operative. They were mainly

10 attached to the typed-up document.

11 Q. How did you know that it was something for you to sign? How did

12 you know it was correct and truthful?

13 A. One of the basic tasks of the SNB was to monitor the safety and

14 security of citizens and to gather military and other kind of information

15 in order to secure regular life and the defence of an area. It was

16 particular to our area because we were in a way encircled by the enemy.

17 All information of military nature was sent to the command of the unit in

18 the area or the unit that such information pertained to concerning dates,

19 times, and places.

20 Q. Thank you. Was there any interest or possibility on the part of

21 your operatives to send you a counterfeit document?

22 A. Everything was recorded, as I said. We have audio recordings.

23 One could listen to those recordings using a headset much like the one I

24 have now and with the assistance of a simple cassette player. At the

25 time, the technology was obsolete but that's what we had. By that time

Page 32997

1 one could use more advanced surveillance equipment but we didn't have

2 that.

3 THE ACCUSED: [Interpretation] Your Honours, does this suffice in

4 terms of criteria for admitting?

5 JUDGE KWON: Ms. West.

6 MS. WEST: Thank you, Mr. President. Mr. President, I will refer

7 you to the amalgamated statement of one of the Prosecution's witnesses,

8 who was a protected witness, but that's P04634. And you will remember

9 this is a lengthy statement, it's 21 pages long, single-typed, of the

10 process by which this organisation intercepted conversations. It goes

11 into great detail as to where those conversations were intercepted,

12 specifically the type of technology that was used to do so, how the tapes

13 were used, whether they were reused, how it was transcribed, what took

14 place after the tapes were used. And further, specific detail as to the

15 actual recording.

16 What we've heard so far is, this gentleman, although the head of

17 the Ilidza SDB, only signed off on these once they were done. He's not

18 the participant, he's not the operator, he's not even the transcriber.

19 And although Mr. Karadzic has now given us a little bit more detail about

20 the method, that detail does not at all meet the standard by which this

21 Court has applied previously. I think to admit this intercept now would

22 dilute the standard that we've used.

23 JUDGE KWON: Mr. Robinson, would you like to respond?

24 (redacted)

25 (redacted)

Page 32998

1 (redacted)

2 (redacted) He just

3 testified about the procedures that they used and he gave -- also the

4 amalgamated statement. And he did give more detail but the essence is

5 the same, that an operative listened to the conversation and wrote it

6 down just as this witness has testified to. Then that information was

7 typed up by someone else, same as was done by the Bosnian Muslim side,

8 and then the information was given to the supervisor, who in this case

9 was Mr. Sehovac --

10 JUDGE KWON: But I would have expected to hear from the witness

11 about such detail --

12 MR. ROBINSON: Well, I think he's already said that everything

13 was recorded, that the operator wrote down the notes, and it was typed up

14 and it was given to him. I don't think I've given you any detail that he

15 hasn't already testified to.

16 MS. WEST: Mr. President, I just want to make sure the witness

17 whom Mr. Robinson is speaking about --

18 JUDGE KWON: Pause, pause. Yes. Please continue.

19 [Prosecution counsel confer]

20 MS. WEST: I think we have to be a little bit sensitive to the

21 information that we're talking about. It's a protected witness. I think

22 to the extent that we've now spoken about it, we practically have

23 revealed his identity. I would ask at this point that those comments be

24 redacted. But secondly, I would ask --

25 JUDGE KWON: We are talking about -- okay, I will not comment

Page 32999

1 number of the witness.

2 MS. WEST: Yeah.

3 JUDGE KWON: Let me see. How did we reveal the identity?

4 MS. WEST: If we look at line 17 --

5 MR. TIEGER: Excuse me, Mr. President.

6 JUDGE KWON: Yes.

7 MR. TIEGER: If -- I just want to say, I mean we're maybe going

8 around in circles we don't want. Maybe this should be in private session

9 if we're talking about this possibility. And also, I would imagine

10 further discussions should not -- about the details should not take place

11 in the presence of a witness who should also not be privy to any

12 confidential information of that type.

13 JUDGE KWON: Could you just give me the line numbers, Ms. West.

14 (redacted)

15 (redacted)

16 (redacted)

17 (redacted) I think if we

18 continue to have this conversation, I would ask that the witness be

19 excused and we go into private session. Or I ask that this conversation

20 end, that the Court take it under advisement and refer to P04634 for the

21 standard.

22 THE WITNESS: [Interpretation] Excuse me, excuse me. It seems you

23 have not understood some things. I said twice that we used an UHER

24 device to record the intercepts. The operative needn't necessarily be

25 present during the recording process. Once the operative realised that

Page 33000

1 the equipment was on, then he would start noting things down. So there

2 are not only transcripts but also audio recordings.

3 JUDGE KWON: We'll continue with that -- with the redaction of

4 that part of the transcript.

5 [Trial Chamber confers]

6 JUDGE KWON: Mr. Robinson, it is the Chamber's understanding that

7 Mr. Karadzic led everything he could with this witness as regards this

8 intercept.

9 MR. ROBINSON: Well, I think if there is something missing that

10 the Trial Chamber or the Prosecution thinks would make this not

11 admissible, he would be prepared to ask further questions. But as far as

12 he's concerned, he's provided the information that's sufficient to allow

13 the Chamber to make a finding that this intercept is authentic and

14 reliable.

15 JUDGE KWON: What we are going to do is to mark this intercept

16 for identification and give its ruling later on. So then he may -- if

17 not admitted, he may wish to call this witness again. So that's the

18 point of my question. If there are more details he'll wish to lead, do

19 it now.

20 MR. ROBINSON: Yes, thank you, Mr. President.

21 JUDGE KWON: Yes, we'll mark it for identification.

22 THE REGISTRAR: As MFI D2853, Your Honours.

23 MR. KARADZIC: [Interpretation]

24 Q. Mr. Sehovac, in early June, were you in Ilidza at your work post,

25 in early June 1993 -- actually, late May and early June?

Page 33001

1 A. I was never absent during the war from my work-place. It was an

2 obligation I had. I think I was there in late May as well as in early

3 June.

4 Q. Thank you. I wanted to show you a document of yours.

5 THE ACCUSED: [Interpretation] Which is 1D378. I kindly ask for

6 understanding for late notification. Unfortunately we still don't have

7 the translation. Do we? No, this is not the document, even. 1D378.

8 The one we see, I believe, is D1397 or 01397, I think that has already

9 been admitted -- no, that's not it either. We have the right document in

10 front of us, but what is in e-court doesn't seem to be the right one.

11 Let's try again. 1D378.

12 JUDGE KWON: Yeah, the document we are seeing is noted as 1D378

13 on e-court. Probably there seems to be a mistake.

14 THE ACCUSED: [Interpretation] Very well. We'll get to it later.

15 Instead, can we have 1D00921. Sorry, can we stay with this document for

16 a moment although it's been admitted.

17 MR. KARADZIC: [Interpretation]

18 Q. Mr. Sehovac -- no, you don't know about this. There is only some

19 reference to gathering information about a game played at Dobrinja and

20 your document pertained to it -- that event of the 1st of June, 1993.

21 That's why the confusion. Do you remember that?

22 A. There was a football match between the units of the Army of BH or

23 something like that. I can't recall any further details unless I see my

24 document --

25 MS. WEST: Mr. President --

Page 33002

1 THE WITNESS: [Interpretation] -- this document does refer to it

2 but I don't know anything more than that.

3 JUDGE KWON: Yes, Ms. West.

4 MS. WEST: Thank you. I do appreciate there are a number of

5 documents here. They found this document, they want to use it. If

6 there's a translation, I have no objection. However, just hearing what

7 he's said, that it refers to a football match in Dobrinja, we've had no

8 notice of this. This is a significant event in the Sarajevo fact

9 pattern. I can't possibly be fairly put in a position now to

10 cross-examine him on this particular issue. If that's what this document

11 has to do with, then I do object.

12 THE ACCUSED: [Interpretation] I believe I apologised a moment ago

13 because we were late in notifying this document. We were quite flexible

14 in that regard. This document has been known for a while, but the pace

15 of work that we have to cope with is such that we can't double-check

16 everything.

17 JUDGE KWON: No, the question is whether you are going to deal

18 with the football match in Dobrinja. That's the point Ms. West raised.

19 THE ACCUSED: [Interpretation] I will only deal with the document

20 that Mr. Sehovac sent to his headquarters and his knowledge, nothing

21 else.

22 JUDGE KWON: Why don't you come to 1D921 and deal with it and see

23 what happens or ...

24 THE ACCUSED: [Interpretation] Thank you. Can we have 1D921.

25 MR. KARADZIC: [Interpretation]

Page 33003

1 Q. Do you recognise this document, Mr. Sehovac?

2 A. Yes, I do. I signed it.

3 Q. Where does this document originate from? What is it about?

4 A. This is a report which was sent to my superiors.

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

6 please, on the screen.

7 MR. KARADZIC: [Interpretation]

8 Q. Look at this page. Could you tell us what kind of information do

9 you send to your superiors?

10 A. In the first sentence it says that:

11 "The Ilidza War Department of the National Security Service has

12 certain information which indicates that the enemy is preparing a

13 decisive attack/offensive on positions of our forces in the general area

14 of the Sarajevo battle-field, i.e., on Serbian territories in this area,"

15 and the area in question is Ilidza, "in order to unblock, first and

16 foremost, the core part of the Sarajevo area which is under their control

17 and to take control of roads which are of prime importance for the

18 Muslim-Croat coalition.

19 "Making use, above all, of the blind eye turned by individual

20 members of UNPROFOR, Muslim forces in Sarajevo are carrying on certain

21 military significant communication with their logistics base in Hrasnica

22 and Igman ."

23 And furthermore it says --

24 Q. The last paragraph, could you please tell us what it contains.

25 A. It says here:

Page 33004

1 "In this respect we have information that they are

2 psychologically preparing the members of their units and emphasizing to

3 them that there will be a considerable number of casualties in the coming

4 action. Also, it is more frequently reaching their ears and also being

5 heard in the city that they can seize the territory of the Ilidza Serbian

6 municipality in just one hour, but that they haven't done this -- that

7 they have not done this so far so that there would be no artillery

8 reprisal from the Serbian side ..."

9 Q. Where are they expecting that reprisal, on Hrasnica and in the

10 city?

11 A. I suppose so, but I can comment upon their erroneous assessments.

12 If they were to cut off Ilidza, Ilidza would have nowhere to go. It

13 would be totally encircled. And in such a case, no retaliation would be

14 possible.

15 Q. Thank you.

16 THE ACCUSED: [Interpretation] Can we take a look at the following

17 page.

18 THE WITNESS: [Interpretation] Again, at the beginning it says

19 that an offensive will be preceded by artillery fire from Igman and that

20 artillery fire will be carried out like never before and then there will

21 be infantry breaches. It says here that the Kosevo hospital is being

22 prepared, i.e., they are relocating the eye clinic from its current

23 building to a smaller one. In the current location of this health care

24 institution, it is possible, according to some estimates, to accommodate

25 up to 1.000 wounded. There are also some of their assessments here as to

Page 33005

1 how many casualties could result from that operation.

2 MR. KARADZIC: [Interpretation]

3 Q. Can you go on reading about Jezero?

4 A. There is certain information indicating -- I apologise, where is

5 Jezero? Okay.

6 Q. The third paragraph from the bottom. It's very short.

7 A. "It is indicative that they are digging or have already prepared

8 four rows of trenches in the direction of the Jezero hospital, facing our

9 positions held by units from the Vogosca area."

10 Q. Since we are familiar with these localities, could you please

11 tell the Trial Chamber what the Jezero hospital is. Is a maternity ward

12 there?

13 A. The Jezero hospital is a maternity ward, the maternity ward of

14 Sarajevo.

15 Q. Can you please read the paragraph mentioning UNPROFOR, where it

16 says that they limited their airplane flight.

17 A. "In this context, also indicative is the information that a full

18 (one hundred per cent) mobilisation into HVO units has been conducted in

19 Kiseljak. Further, three days ago UNPROFOR unexpectedly limited airplane

20 flight times so that they do not fly in the first evening hours, but

21 pilots are switching off all the lights on their aircraft which is highly

22 indicative and shows that they are informed about 'events to come.'"

23 Q. Thank you.

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

25 Your Excellency?

Page 33006

1 JUDGE KWON: Yes.

2 THE REGISTRAR: Exhibit D2854, Your Honours.

3 THE ACCUSED: [Interpretation] The document that I requested has

4 already been admitted into evidence. The document that I requested to

5 see before has already been admitted, it's 378, so I won't waste any more

6 time on that.

7 Thank you, Excellencies. I have no further questions of this

8 witness today. If this document may be admitted, I have no further

9 questions.

10 JUDGE KWON: Very well.

11 Mr. Sehovac, as you have noted, your evidence in chief in this

12 case has been admitted in most part in writing, i.e., through your

13 statement. And you will now be cross-examined by the representative of

14 the Office of the Prosecutor, Ms. West.

15 MS. WEST: Thank you, Mr. President.

16 Cross-examination by Ms. West:

17 Q. Good morning, Mr. Sehovac.

18 A. Good morning, Prosecutor.

19 Q. I understand that you joined the service in 1977 and it was your

20 first job out of university. When did you leave?

21 A. You mean the State Security Service or the service in general?

22 Until the beginning of the war, I was a member of the SDB. When the war

23 started and when the Serbian service was set up, I joined that service

24 and I left that service in late 1999.

25 Q. What do you do now?

Page 33007

1 A. I'm retired.

2 Q. How many people were in your unit at the Ilidza national security

3 service in 1992?

4 A. The operatives that interviewed people worked in a team of 15 to

5 20. There were 15 to 20 lads in the surveillance service and there were

6 about 20 girls in the technical service, including translators,

7 interpreters, as well as other professionals of technical areas of

8 expertise. We hired those that we needed for our work.

9 Q. So let's focus first on the operatives who interviewed people.

10 You say there was about 15 to 20 of those. Now, these people all worked

11 directly for you; correct?

12 A. They worked for the service. I co-ordinated their work. There

13 were mostly lads that graduated from various universities, well-educated

14 people. Since we did not have enough previous experience, I was a

15 co-ordinator. As a more experienced person, I instructed them how to

16 obtain information that might be of interest for the service in

17 conditions of war particularly.

18 Q. You've indicated that you became the chief by the end of 1992.

19 How long did you remain the chief?

20 A. I remained in that position up to sometime in 1994, and then I

21 was transferred to the administration, to the main administration of the

22 SDB. We tried to set up a department that I could run as an expert;

23 however, that department never really took off the ground while I was a

24 member of that service.

25 Q. Okay. Let's go back to your period of time at the end of 1992

Page 33008

1 through --

2 JUDGE KWON: Sorry to interrupt you, Ms. West.

3 Could I be clear again as to the SDB and the SNB. Before the war

4 it was SNB or SDB? Because of a couple of --

5 THE WITNESS: [Interpretation] Before the war it was the

6 State Security Service, or SDB; and during the war it was the

7 National Security Service, but that only referred to the Serbian part of

8 the service. When one says "SNB," or the National Security Service, one

9 refers to the service that the Serbian side had during the war.

10 JUDGE KWON: But in your previous answer to the question that --

11 question how long you remained the chief, you answered this way:

12 "I remained in that position up to sometime in 1994, and then I

13 was transferred to the administration, to the main administration of the

14 SDB."

15 THE WITNESS: [Interpretation] It would have been SNB. I

16 apologise. I misspoke just like I did when my statement was being

17 admitted. It is something that one does automatically. It's a simple

18 mistake.

19 JUDGE KWON: Thank you.

20 MS. WEST: Thank you.

21 THE ACCUSED: [Interpretation] Transcript, transcript. In the

22 previous answer the witness said that he was transferred in 1994 to the

23 main administration to be the head of a department, to be part of the

24 management staff.

25 JUDGE KWON: Do you confirm that?

Page 33009

1 THE WITNESS: [Interpretation] Yes.

2 JUDGE KWON: Yes, Ms. West, please continue.

3 MS. WEST: Thank you.

4 Q. So let's focus on your time when you were the chief of the SNB

5 from the end of 1992 up till 1994, and you said you had 15 to

6 20 operatives working for you. Was one of those operatives a man named

7 Miladin Bajagic?

8 A. Not Miladin Bajagic but Mladen Bajagic, and, yes, he was indeed

9 one of the operatives.

10 Q. Thank you. In your direct examination you talked about the tasks

11 that the SNB did under you, and you said that they used well-known police

12 methods, they gave interviews, and they used operative technical

13 measures. Tell us what you meant by "well-known police methods."

14 A. Well, you see, I'm sure that you may have noticed from my CV that

15 I joined the police school from elementary school. When we're talking

16 about well-known police methods and measures, I mean the golden questions

17 of crime investigation which need to be answered about any act, be it a

18 crime or a joyous event. I believe that all police forces and courts in

19 the world function along the same lines. I'm sure that you adhere to the

20 same principles and apply the same measures.

21 Q. Of course. And so what you're saying is that these were typical

22 guide-lines you used in your interviews; is that right?

23 A. Yes. Those were the guide-lines, the basis of any interview. We

24 obtained information that we were interested in in that way. And as for

25 other police methods, if, for example, during interview we obtained

Page 33010

1 information about a crime that was committed, then we would refer such

2 individuals to the services that continued interviewing them about such

3 things. We were only interested in information and intelligence about

4 security in our territory, security in the enemy territory. We were

5 interested in their weaknesses and strengths as well as our weaknesses

6 and strengths. And based on that information we could plan our reactions

7 towards anybody who may have abused those weaknesses.

8 Q. Thank you for that, and we'll talk about that a little bit

9 further later. But if we can back up here. As regards to these

10 interviews and guide-lines, you said earlier that you signed off on any

11 document that left your service. By signing off on those documents, was

12 that a process by which you ensured that the interviews that were

13 conducted were conducted according to the guide-lines or, in other words,

14 were acceptable to the security service?

15 A. Well, you see, the interviews that were conducted by our

16 operatives, the operatives had to record the course of the interviews in

17 writing and those records were signed by the operatives. If those

18 interviews were organised ad hoc, where guide-lines could not be fully

19 followed, such interviews would also be taken into account. And if the

20 intelligence obtained through such interviews required urgent action,

21 such information would be typed up; and then that report would be

22 couriered to wherever necessary, since we sometimes did not have any

23 other means of communication available to us.

24 Q. Thank you. I understand.

25 MS. WEST: May we have 1D06108, please.

Page 33011

1 Q. Sir, I've looked through your various reports and in the original

2 statement we had far more, we had close to 80 of the reports, the bulk of

3 which you have signed. And in reviewing those, there appear to be two

4 different types of reports. There's a set of interview reports and they

5 mostly appear to be entitled "official notes." But then there's another

6 set which appear to be analysis, much like one of the documents

7 Mr. Karadzic showed you, 1D0921, and that appears to be based on

8 information that is not from one specific person but an analysis you did.

9 Would you agree that there are two types of reports? Is your answer

10 "yes"? We overlapped.

11 A. Well, you see, whatever you may call these reports, whether you

12 call them official notes, dispatches, reports, whatever jargon you want

13 to use, they looked like bulletins. In any case, they were our means of

14 information, our means of informing certain people of the things that

15 they needed to know, that we touched upon in our interviews. In this

16 case we had so-called reports, official notes, and dispatches. Those

17 were our forms of drafting written documents.

18 Q. All right. Let's first speak about the official notes when they

19 referred to actual interviews and we see one of those in front of us now.

20 Earlier you mentioned that sometimes when the reports had to do with

21 military security, on page 7 today you said you passed that on to the

22 people who should be informed. Was that part of your process, where the

23 reports that you would give would end up going on to your own superiors

24 or going on to the military?

25 A. Yes.

Page 33012

1 Q. And after the interview before they were sent up, I understand

2 there was a process by which it involved analysing the information,

3 cross-referencing the information, and then checking the accuracy of the

4 information before it was sent up. Is that right? Is that exactly what

5 happened?

6 A. Well, you see, since our operatives most commonly drafted their

7 reports in writing after having verbally reported to me or somebody

8 appointed by me if I was not present, that report was typed up and I then

9 signed the typed-up report. Those things which were considered important

10 were sent to the superiors. If not, the reports would be filed and the

11 operative would be instructed to continue working on the matter, either

12 checking some information or something of the kind. If the matter was

13 urgent - and most of our situations were urgent - then the part of

14 military intelligence would be referred to military bodies.

15 We did not send everything that was written to military bodies

16 because not everything had to be sent. If during our interview we

17 learned that crimes were committed, and you will see that most often

18 those were people who defected from the areas controlled by the Muslim

19 forces, so if we learned about crimes and some other similar things, then

20 that person would be handed over to the crime prevention police who would

21 take their statement according to their rules and regulations.

22 These were just preparatory interviews and there were

23 instructions as to how to obtain the full picture of the opposing side,

24 the full picture of where we are, and -- so as to end up with objective

25 piece of information portraying the right picture of the whole situation.

Page 33013

1 Q. Thank you. I think we have a full understanding of that now. If

2 we can go to the last page of this document before you. This is one of

3 the reports that was provided. It's an interview which you signed off

4 on. And if we look at the last page, we see your signature and we also

5 see at the end it says:

6 "Source: T. G. currently being checked.

7 "Data: Partly verified."

8 And then: "SNB: Data concerning military issues to be referred

9 to the VRS."

10 So should I understand that what this is, is a -- your notation

11 of the verification of the information that was taken in the interview.

12 A. Most often, most often it would be either myself or two other

13 persons in my department. I had two retired officials who were

14 experienced, they had experience from working previously in the SDB

15 before the war. And when it comes to verified or partly verified

16 intelligence, this means that if the intelligence was not verified that's

17 how it was denoted.

18 You will understand another thing, military issues, whether they

19 were verified or non-verified, owing to the circumstances, we had to

20 refer such indicia to military organs and that's how we presented this

21 intelligence to them. The territory, I'm sure you will agree, did not

22 allow any glitches or errors because Ilidza was only 500 metres wide from

23 the Muslim side on the one hand and the other side on the other hand.

24 50 metres away from --

25 Q. Thank you, Mr. Sehovac --

Page 33014

1 A. -- a Muslim trench I had two of my children living at that time.

2 Q. My apologies for interrupting, but I just want to move on with

3 this same information. You just mentioned that there were occasions --

4 military issues, whether they were verified or non-verified, owing to the

5 circumstances you had referred them up. So are you telling us that there

6 are a period -- or there are particular interviews that you sent on to

7 the military organs that were not verified?

8 A. No. We sent intelligence to the units that were on the ground

9 directly. For example, the Nedzarici separation line was held by a

10 battalion. The intelligence would be sent to the battalion command for

11 their attention or somebody in the military police, the person who would

12 be in charge of that part. The intelligence would be referred to the

13 higher instances, the staffs of the brigades of the Army of

14 Republika Srpska. Our reports would be sent to them and our reports were

15 based on the intelligence gathered from all over the area. Ilidza was

16 just one of the departments within the SNB of Republika Srpska.

17 Q. Okay. Thank you. You just said:

18 "We sent the intelligence to the units that were on the ground

19 directly."

20 So I have to assume that when you received the intelligence and

21 you thought it was important, you sent it directly, you didn't have any

22 time to do any verifying. Would that be the case?

23 A. No. The intelligence that was put on paper was mostly supported

24 by facts. When it says "partly verified," that refers to some of the

25 segments of the intelligence. The word at the end, "partly verified,"

Page 33015

1 does not need to pertain to some concrete intelligence but just some of

2 its segments that concern the military segment or some other segment of

3 the war situation.

4 Q. Sir, that's exactly what I want to talk about is the information

5 that was put on the paper. Because when I looked through all the

6 documents that you had originally in your statement, you had over 80, and

7 about 40 of them were interviews just like this. And this one that I've

8 shown you plus two others are the only ones that I could find that had

9 any sort of verification information on the end. And I stand to be

10 corrected if you can show me others, but my question to you is: Should

11 we understand this to mean that those approximately 37 other interview

12 reports were never verified?

13 A. No, this is absurd. I don't know why you see it that way. The

14 interviews that were conducted are mostly conducted with the individuals

15 who had arrived from the enemy territory, and you will admit that we

16 could not take their statements for granted, we could not take for

17 granted everything that those people told us. But if you talk to 10, 20,

18 or 50 people, and when we have non-verified information in the first

19 interview and then it is confirmed by another interview, then it is

20 denoted that "partly verified" and after that "verified."

21 Again, there may be non-verified information, but we were not in

22 a position to play with the destiny of those individuals who had

23 undergone torture and terror. We expected to hear from them things that

24 didn't make sense sometimes. So we did not take everything that they

25 said for granted. You will allow me to say that even if you took

Page 33021

1 that had been done in this case.

2 As to any further notifications, we're happy to make those or to

3 ensure that they've already been made in whatever form that the Chamber

4 and the Prosecution feel is appropriate. And I had planned to actually

5 discuss that with Mr. Tieger so that we can understand what they think is

6 best in terms of the protected witness. Sometimes calling attention to

7 somebody as a protected witness on -- in some form could actually

8 aggravate the situation. So I just want to make sure that whatever steps

9 we do take are the ones that are the most consonant with the protective

10 measures and the view of the Prosecution on that.

11 JUDGE KWON: Mr. Robinson, could you kindly remind of the exact

12 term the Court ruling used to -- when it issued that the Defence can

13 disclose protected information when it's necessary for its defence.

14 MR. ROBINSON: Actually for that, Mr. President, I would have to

15 go back and look at the protective orders. I'm not in a position to do

16 that, and I know there have been protective orders for different

17 witnesses from different cases, so I would have to do some research on

18 that.

19 JUDGE KWON: Very well.

20 Mr. Tieger.

21 MR. TIEGER: Thank you, Mr. President. With respect to the last

22 point that was raised by the Court, it is one of the issues that I

23 discussed with Mr. Robinson. There may be a kind of lacuna or gap in the

24 specific conditions under which reference may be made to protected

25 witnesses between the earlier generic confidentiality applied to

Page 33022

1 disclosures. I'm fairly confident there was such a provision there for

2 forensic purposes. I do not recall the reiteration of that provision

3 with respect to specific protective measures imposed. So while it may be

4 the case that the general spirit of what the Court had in mind was

5 consistent, I -- neither one of us at the moment are able to cite the

6 Court to that provision. And I raised that point with Mr. Robinson and

7 suggested that that was something he may wish to raise with the Court.

8 With respect to the circumstances under which there is a forensic

9 purpose, generally speaking, I think we can break those down into two

10 kinds of categories. One is, for example -- and we have those broad

11 examples in the two circumstances we were addressing in private session.

12 One is the circumstance where generic reference is made or some reference

13 is made by a witness to events that are relevant to this case and the

14 identity of the witness who provided that information is not critical to

15 the information provided, it doesn't change the nature of the information

16 provided. So certainly inquiry can be made by the Defence about their

17 witness's position on that matter without any reference whatsoever to the

18 witness who earlier provided that information and about which they wish

19 to check. And a reference to or the disclosure of the witness's identity

20 is quite gratuitous under those circumstances.

21 Going to the other extreme, there may be a circumstance where a

22 specific witness talks about an interaction he had with another witness.

23 So that specific event may involve the protected witness. Nevertheless,

24 there seem to be ways to address that issue and elicit the necessary

25 information without specifically disclosing the -- the fact that a

Page 33023

1 witness is protected, a witness testified, a witness provided a

2 confidential statement. The question can simply be asked, for example:

3 Do you know about, did you ever go to this event, did you ever have a

4 discussion, you can ask the question without providing the additional

5 information that the -- that a witness testified.

6 Now, under those circumstances it is conceivable that the person

7 being asked the question might make some kind of linkage and begin to

8 suspect that information was provided to the Prosecutor's office or to

9 the Trial Chamber by the other person involved in the event, but then

10 that raises the question of forensic purpose and how the Court will

11 strike that balance, given the orders that have been issued before. But

12 it is difficult to imagine many, indeed at the moment any, circumstances

13 in which it's necessary to say: This witness testified that, this

14 witness appeared in this particular Trial Chamber and said that. We

15 consider - and I advised Mr. Robinson of this with various

16 examples - that the information can be elicited in other ways.

17 JUDGE KWON: Mr. Robinson, would you like to add anything?

18 MR. ROBINSON: Yes, Mr. President. I think basically we're

19 willing to work with the Prosecution and the Chamber to do whatever is

20 necessary to maintain the protective measures and to continue to obey

21 them. And I think that this case overall has been remarkable for the

22 lack of problems that the protected witnesses or any witnesses have

23 encountered in the case. So it's in that spirit that we're prepared to

24 take whatever measures are reasonable to allow us to prepare our defence

25 and at the same time fully respect the protective measures of witnesses.

Page 33024

1 JUDGE KWON: Yes, Mr. Tieger.

2 MR. TIEGER: I want to say that I found Mr. Robinson was

3 receptive to our raising the point. I think we can work co-operatively

4 and successfully in this regard. I think we -- his point, for example,

5 regarding what specific steps we want to take is a useful one. It's

6 better to be a little bit cautious about considering the implications of

7 doing one thing than making a dogmatic statement initially in court and

8 then coming to realise there may be more nuanced ways to approach it, and

9 I would make the same caveat about the comments I just made. I think we

10 appreciate the fact that, indeed, in court we've sometimes found

11 ourselves in circumstances where there have been confrontations between

12 examiner and witness that implicated confidential information but the

13 Court was aware that that was an appropriate way to proceed under the

14 circumstance. And we have been working our way through this thicket

15 carefully and I think we can continue to do so. But it is clearly a

16 matter that needs close attention and that we cannot be lax about at any

17 point, whether it's in the investigative process or afterwards.

18 JUDGE BAIRD: Mr. Robinson, Mr. Tieger, we find your comments

19 very reassuring, very much so. Thank you, both.

20 JUDGE KWON: I rather find this issue important if not serious

21 and the Chamber will leave the matter there and we'll come back to the

22 issue after considering some further elements.

23 Shall we bring in the witness?

24 For planning purposes, how long would you need for your

25 cross-examination, Ms. West?

Page 33025

1 MS. WEST: I would suspect another half an hour or 35 minutes.

2 JUDGE KWON: Thank you. Thank you.

3 [The witness takes the stand]

4 JUDGE KWON: Thank you. Apology for your inconvenience. There

5 was a matter the Chamber wanted to discuss in your absence.

6 THE WITNESS: [Interpretation] I understand.

7 JUDGE KWON: Please continue, Ms. West.

8 MS. WEST: Thank you, Mr. President.

9 May we have P02305, please.

10 Q. Sir, in 1992 and 1993, were you aware of a person named

11 Branislav Gavrilovic?

12 A. Yes, I knew Branislav Gavrilovic by sight. I did have occasion

13 to speak to him. He didn't know who I was but I knew who he was.

14 Q. We're looking at a document now that's on your screen and this is

15 one that's dated February 12th, 1993, and this is a document the

16 Trial Chamber has seen before. And in it, you report on Mr. Gavrilovic's

17 reception of the new commander of the brigade who took the place of

18 Major Dunjic after Major Dunjic's exit. In this report you talk about

19 the threat that Mr. Gavrilovic made on the new commander's life and, in

20 your opinion, it was made because Gavrilovic felt that it would not have

21 the privileges it had had until that time and that it would have to place

22 itself under the brigade's command. Do you remember writing this?

23 A. I didn't write this note myself. It was the operative whom you

24 mentioned a little while ago who wrote it, Mladen Bajagic was his name.

25 But I do remember this document, and when I look at it now, I can clarify

Page 33026

1 that Gavrilovic was the leader of a paramilitary unit. I can

2 additionally explain that when the VRS was established there was an order

3 coming from the Main Staff and the Presidency that all paramilitary units

4 should be put under the auspices of the army. As you can see here,

5 Mr. Gavrilovic tried in various ways to avoid this, but you can also see

6 to what extent he succeeded in this. So I think any further comment

7 concerning this gentleman would be superfluous. He describes here how he

8 went to see the commander, how he could have killed him, and so on and so

9 forth. And as for his strength and the strength of his unit, I can only

10 tell you what I know.

11 Q. This is dated February of 1993. To your knowledge, did he

12 continue to be involved with the military and the police in the Ilidza

13 area subsequent to this?

14 A. Well, you see, throughout the time he was there, Gavrilovic

15 continued to be under the command of the VRS. Maybe he considered

16 himself to be a vojvoda. He was made a vojvoda by Vojislav Seselj. His

17 army was what it was. There were good men there but about 30 per cent of

18 his men were drug addicts, person prone to drink and to committing

19 crimes. The lads who were good lads, so to say, put themselves under

20 command and could be used in combat activities for defence; whereas these

21 other lads, who when there was combat were mainly concerned with avoiding

22 the fighting and getting some loot, they would conceal themselves in

23 trenches, waiting for an opportunity to do what their main purpose for

24 being in the unit was.

25 Q. Sir, did your unit, the 15 to 20 operative workers that you spoke

Page 33027

1 about earlier, ever work with Gavrilovic?

2 A. No, not with him directly, but there were operative workers of

3 mine who were good friends with his men and even with him. And I had

4 occasion to go to Gavrilovic's staff with one of the men simply to see

5 whether he would obey the military command or not. This was Dunjic,

6 Velimir Dunjic at that time. He was the previous commander of the

7 Igman Brigade.

8 Q. Sir, most of the documents that we saw initially with your

9 statement, the 80-plus documents, looking through them, most of them are

10 from 1992 up until about the middle of 1993 and there are only about six

11 or so that are subsequent to the middle of 1993. Can you tell us the

12 reason for that?

13 A. Well, you see, the beginning of the war and the course of the

14 war-time events influenced the frustration of the population. There were

15 many refugees arriving. Not all the lines were closed yet and this made

16 it necessary for us to be more active, to interview these people, receive

17 these people, and do other things. At that point, most of the

18 preparations were being made and in the subsequent period. If you are

19 referring to the documents, that there were fewer documents concerning

20 interviews, because there were fewer people arriving and subsequently --

21 or consequently there were fewer interviews.

22 Q. During the period of time when you were actively -- your unit was

23 actively engaged in interviewing, how many would you typically do in one

24 week? So now I'm talking about 1992/early 1993.

25 A. Well, at that time, a lot of refugee Serbs were arriving who had

Page 33028

1 fled from their homes in various ways and their homes were destroyed.

2 Parts of their families stayed behind for good because they were killed

3 in various ways. So depending on the numbers, who and what they were,

4 you will see in some official notes that 50 persons are referred to and

5 there is only one official note. In that case, they would all be persons

6 from a single village, for example, Visoko. They would most be members

7 of a single family. There were would be one, two, or three families

8 concerned or an entire family would be there. And looking at that and

9 the contents of those notes, you would see that that's what the data

10 mostly refers to. And we were hard-pressed to complete everything, so

11 that's why a single operative would interview an entire family.

12 Q. But do I understand correctly that there are occasions where more

13 than one operative was present for an interrogation or an interview?

14 A. Yes.

15 Q. Okay --

16 A. If there was one person and we didn't have any others, then one

17 of the new operatives would be there in order to gain experience. For

18 the most part, these were Serbs who could hardly wait to reach Serb

19 territory and they would kiss the ground --

20 Q. Okay --

21 A. -- if they managed to get there alive --

22 Q. Thank you.

23 A. -- so it was easier with them.

24 Q. And I understand earlier from your testimony that as regards

25 methodology you used well-known police methods. Would these police

Page 33029

1 methods include, for lack of a better expression, a good guy/bad guy

2 interviewing technique?

3 A. If you are referring to the attitude towards the people being

4 interviewed, we treated them all the same. If you are referring to the

5 operatives conducting the interview, if there were two, it would be one

6 experienced operative who would be helping train the inexperienced one.

7 And in these interviews it was not normally necessary to prove something

8 or convince someone of something. People would be happy that they had

9 managed to leave and they would be open in their responses.

10 Q. I want to show you an example of what I mean.

11 MS. WEST: Can I have 65 ter 24498.

12 Q. This is a lengthy document and it's a statement of a man who

13 recounts his interview with your service in July of 1993.

14 MS. WEST: And if we can go to page 10 of the English and page 10

15 of the B/C/S.

16 Q. There's a certain part I want to focus on, it's the actual

17 interview. In the first ten pages he just talks about the circumstances

18 of his arrest, which has nothing to do with the interview. But when we

19 get to page 10, he speaks about that interview. And at the top he

20 indicates -- this man's name is Perica Koblar. At the top he talks about

21 having been arrested. And he says that Brne, the officer and two of

22 Brne's men then left the room. He had been arrested by that group. And

23 then when you go down to the second full paragraph he begins to speak

24 about the first interview.

25 And in this interview he speaks about several men who come into

Page 33030

1 the room and one is behind a desk and this is the one who actually gives

2 the interview. And the one who sat behind the desk -- I'm reading from

3 the second full paragraph in the middle:

4 "The one who sat at the desk told me that I shouldn't be afraid

5 but warned me that I should answer every question because they could

6 check everything, they had all the information, and this way I would

7 avoid being beaten."

8 Hold on, I have a question for you. Is a physical assault, a

9 physical assault of these people, part of the well-known police method

10 that you described earlier?

11 A. No, excuse me. I think that this piece of paper you are showing

12 me, it was not something conducted by my operatives. Can you show me the

13 signature to -- for me to see who conducted the interview? I think it

14 may have been a military service --

15 Q. Thank you, sir --

16 A. -- or another one.

17 Q. You're right. You're right. This was not one of your

18 operatives. As I mentioned, this is the recounting of that person --

19 hold on a second. This is the recounting of the person about the

20 interview. So it is not one of yours. I will agree with you. There is

21 no signature on this. What I'm talking about, though, is what you

22 brought up, which is the methodology, and how it was that the operatives

23 in your unit would interview people.

24 If we go a little bit further down this paragraph --

25 JUDGE KWON: But, however, I think it's fair enough --

Page 33031

1 MS. WEST: Yes.

2 JUDGE KWON: -- to show what statement it is. So shall we show

3 the first page first to the witness --

4 MS. WEST: Thank you, Mr. President.

5 JUDGE KWON: -- and the last page. Yes, and the last page. I

6 think that's now enough. What page was it, Ms. West?

7 MS. WEST: Page 10 on both languages, please.

8 JUDGE KWON: Please continue.

9 MS. WEST: Thank you.

10 Q. And in the middle of page 10 the interview continues, and towards

11 the bottom of the big paragraph, the individual who was interviewed says:

12 "One of the individuals jumped from the bed, hit me on the head

13 below the left eye with a truncheon. Then he hit me a few more times in

14 the face. I covered myself with my hands and bent down and he continued

15 to hit me."

16 It goes on. He said he felt "the curly-haired young man,"

17 another person, "was also punching me. I did not hear the investigator

18 tell them to stop but he must have indicated that they should stop. Then

19 the investigator asked me again if I had fired a weapon. I replied," and

20 at the end of this paragraph, "the grey-haired man who was sitting on the

21 bed offered me a handkerchief."

22 So my question for you, sir, is back to the good guy/bad guy

23 routine. This is something I asked you about earlier. I don't think you

24 responded. Was that a method, was that part of the normal police methods

25 that you spoke about earlier, something we see illustrated here?

Page 33032

1 A. You see, it's not clear to me who took this statement, which

2 organ did it. I assert it was not done by the SNB and that the SNB did

3 not use such methods. The service was an eye and an ear and nothing

4 else. It did not have any repressive measures. They could be linked

5 only to a piece of evidence and how a person was convinced that something

6 was correct or incorrect in order to get at true information. So I

7 cannot comment on this. This is completely unknown to me. I don't

8 know --

9 Q. Thank you --

10 A. -- where this could have been created or in what part or what was

11 done.

12 MS. WEST: May we go to page 12.

13 Q. I just want to show you one more part of this. As I mentioned,

14 this is a series of interviews over the course of a couple of days, and

15 on page 12, it's the second paragraph in English. It's also on page 12,

16 I believe, in the B/C/S. This is where the gentleman goes back and he's

17 interviewed by Mladen Bajagic. So this is the person you spoke of

18 earlier as being one of your operatives and also as the author of the

19 report that we saw about Brne Gavrilovic. He said he recognised Bajagic

20 and that Bajagic started questioning him. And he goes on talking about

21 that. And when we get to the bottom of page 12 he says that, again, he

22 was hit with a truncheon.

23 "I was hit in the back with a truncheon which winded," and we're

24 moving on to 13 in the English, "hit me and fell down." Then the

25 officer," and he's speaking about a short, stocky, with receding hair,

Page 33033

1 about 55 years old, with glasses, "came and asked me if I was hurt. I

2 said it did not. And then he told me, 'Let's go to my office and talk a

3 little.'"

4 Tell me this, sir: The description of an officer, short, stocky,

5 receding hair, about 55 years old, with glasses, is that somebody who was

6 one of your operatives? Does that description sound familiar to you?

7 A. No. Now that you've explained briefly what this is about, when

8 the military security was established at Ilidza, that is, the military

9 police, we received a request from persons in the military police that we

10 should give them a person who is literate and who could explain to them

11 how to interview people. So it's evident that the ones interviewing

12 people before that, conducting themselves in the way described, and

13 Mladen Bajagic was in the military police for some ten days or so helping

14 them to conduct interviews. But I don't see what person is referred to

15 here because I don't know whether this is a prisoner of war or someone

16 who had defected for some reason. And the person who hit him with a

17 truncheon, I don't think that was Mladen Bajagic because he's not the

18 sort of person who would have done that. And I don't know who was

19 working in the military police at the time.

20 Q. Okay.

21 JUDGE KWON: Just a second.

22 Yes?

23 THE ACCUSED: [Interpretation] Can we please have the following

24 information: To whom was this statement made so that the witness can be

25 more reliable.

Page 33034

1 JUDGE KWON: Mr. Karadzic, then you may take up that issue in

2 your re-examination.

3 Please continue, Ms. West.

4 MR. ROBINSON: Excuse me, Mr. President. One concern that I

5 had -- and this is a very lengthy statement and I think it's somewhat

6 unfair to the witness to be asked -- just giving him bits and pieces.

7 For example, if you look yourself on page 12, the second full paragraph,

8 maybe the second sentence of that paragraph, you could see that is a

9 piece of information that's actually quite interesting and consistent

10 with this -- what this witness said. And he hasn't had the opportunity

11 to review. He's just being shown bits and pieces of a document and being

12 asked to comment on it and I don't think it's fair to the witness. I

13 think this should be printed out for him, he should be given at least a

14 few minutes to study it so that his answers can be more fair.

15 MS. WEST: Mr. President. I agree as to that sentence and the

16 witness himself has explained that very circumstance, that Mr. Bajagic

17 was with the military police at the time. I only have one more question

18 for him regarding this document and it's not my intention to admit it.

19 JUDGE KWON: Yes, let's proceed.

20 MS. WEST:

21 Q. If we can go to the next big paragraph that begins with:

22 "The officer and I were leaving the room and Bajagic came right

23 behind us. He stopped me and asked me if I had recognised him. I said

24 that I had but I was not a hundred per cent sure. He apologised for not

25 recognising me because I would have been beaten less."

Page 33035

1 Now, sir, you've said that Mr. Bajagic was on a ten-day leave of

2 absence with the military police to show -- as I understand it, to

3 explain to them interviewing techniques. Yes, you said to explain to

4 them how to interview people -- hold on a second. Was beating people

5 part of the method by which the SNB interviewed people?

6 A. No. You misunderstood Mr. Bajagic being in the military police.

7 He didn't explain to them what to do and they -- he did not notice them

8 beating people and I don't know that anyone beat people in any context.

9 Q. Were you ever present for an interview when physical force was

10 used on the person interviewed?

11 A. I think only on one occasion. I was there when a lad slapped the

12 person who was interviewing because he didn't respond or he provoked him

13 and the question was just an ordinary question, and he was warned about

14 that. He was told not to do that again.

15 Q. Sir, I want to move on to another -- to a part of your statement

16 in which you make some comments regarding an alliance between the Muslims

17 and Croats. And in answer to question number 10 you said:

18 "Even before the beginning of the conflict, by tying their flags

19 together, the Muslims and the Croats had made it clear they would act

20 jointly against the Serbs."

21 And then also in answer to 36(a) you said:

22 "When the Muslims and Croats tied their flags together, it became

23 clear to all that living together was no longer an option."

24 What is the basis of your opinion?

25 A. You see, the very tying of flags between Muslims and Croats

Page 33036

1 coincided with the decision to hold a referendum where -- in the absence

2 of the third party, because the Serbs were left out. Indeed, a

3 referendum was held on the independence of Bosnia and Herzegovina. They

4 indicated loud and clear that they no longer wished to live in the same

5 state which had unified police force and the military and where they all

6 worked together.

7 When you look at Bosnia-Herzegovina today, if you look at the

8 map, you will see that there are divisions between the villages. For

9 example, at Stup, near Sarajevo, there are only Croats. On the other

10 side, only Muslims. In Ilidza and Osijek, only the Serbs. At Butmir,

11 only Muslims. In Hrasnica, Muslims only. In urban environments where

12 there are apartment blocks, there were people living together, though.

13 Q. Thank you.

14 A. By virtue of that alone --

15 Q. I'm sorry to interrupt, but we'll talk a little bit more about

16 this. When you say "the referendum," that was rather early on. Did your

17 opinion as to their alliance continue on? Did you hold this opinion

18 throughout the war?

19 A. You see, I explained well what kind of work I did for the

20 service, at least in written form. The department I worked for didn't

21 change much. There were very few newcomers. Before and after the

22 multi-party elections, a lot of people arrived, though, whom we didn't

23 know, mainly Muslims. My older colleagues --

24 Q. I'm sorry -- I'm sorry to interrupt you again. But my question

25 is whether you continued to hold that opinion that they were aligned

Page 33037

1 throughout the rest of the war. Maybe some way you're going to get

2 there, but if you can just answer my question: Did you continue to hold

3 the opinion? Yes or no?

4 A. No.

5 Q. And so your opinion as to this alliance, when is this true for

6 you, 1992? 1993?

7 A. You see, at such times when there was no alliance between Croats

8 and Muslims, when they fired at each other, others had to force them, for

9 example, as part of the Washington Agreement, to join their forces again

10 and turn against the Serbian people.

11 I'm not clear on your question, though. Do you mean what my

12 personal opinion was of Muslims and Croats or what my position was

13 concerning their flags? Throughout the war their flags were on the same

14 side, acting jointly.

15 Q. I will show you some documents and so we can understand -- make

16 sure that we understand each other.

17 MS. WEST: May I have P01479. This is a document from

18 August 18th, 1992, and it is an excerpt from the Mladic diaries about a

19 meeting at the SR Presidency. And if we go, please, to page -- e-court

20 page 76 and it will be the same in both.

21 Q. You, of course, were not at this meeting, but I want to read

22 something here and get a comment from you. As I said, this is

23 August 1992. This is Mr. Karadzic speaking. And at this meeting,

24 according to these notes, he says:

25 "We will draft a constitution in co-operation with the Croats.

Page 33038

1 "It can happen to us that we must stop at Jajce in the Posavina,

2 but it would be good if a separate peace could be signed with the Croats

3 and a mutual recognition."

4 Does it appear to you that, in August of 1992, Mr. Karadzic was

5 suggesting that an effort should be made for the Serbs and the Croats to

6 align, not the Croats and the Muslims?

7 A. I really cannot comment upon this. I can tell you something

8 else, though, which could refer to this. In my immediate environment in

9 Kiseljak, where I lived, only Croats resided there, and throughout the

10 war there was no conflict. Quite the other way around. Croats moved to

11 the other side and Serbs came there. There were sporadic individual

12 attempts to disturb that kind of peace that was in place at the time, if

13 I may call it that.

14 I think at this point in time in the document, there had already

15 been a conflict between the Muslims and the Croats, but you will have to

16 put the question to Mr. President himself because I really don't know

17 what was in his mind.

18 Q. And you're right, at this particular time there certainly was

19 some tension between the Muslims and Croats in Herceg-Bosna. But then I

20 wonder why it is in your statement in two separate places, and

21 Mr. Karadzic included this in his summary, you made efforts to indicate

22 that you felt that the Serbs and the Croats were aligning themselves

23 against -- excuse me, the Croats and the Muslims were aligning themselves

24 against the Serbs.

25 A. I repeated what you can see in many a document and there were

Page 33039

1 many events in the field which testified to that. From this point of

2 view I don't really know -- well, perhaps I can be specific. There was

3 an example that I can use to counter that argument which is that the

4 Croats in Kiseljak disobeyed the policy and did not wage war on the

5 Serbs. But, for example, from Kiseljak, the very same people went to

6 Jajce, fighting Serbs there and being killed there. So in that kind of

7 war it all depended on one's point of view. There were things that one

8 would believe possible and then there were those that were not so

9 possible.

10 Q. But I'm specifically looking at what you wrote in your statement

11 and it very clearly gives your opinion on this particular alliance.

12 MS. WEST: May I have 65 ter 24454, please.

13 Q. I want to look at what you said in June 1993 about this very same

14 subject matter. This is an information report signed by you and this is

15 an information report all about Zenica. It's several pages long. We are

16 going to go specifically to English page 5 and B/C/S page 4, but I'll

17 just tell you it talks about the ABiH command coming to Zenica, that

18 there's three types of Muslims in Zenica. It's about Serb houses burning

19 in Zenica. And then it talks about the Muslims and Croats there. And

20 particularly on page 5 of the English --

21 MS. WEST: And it's B/C/S page 4 and it's the next page in

22 English. Or maybe it's page 6, pardon me. E-court page 6. So I have

23 page 5 of the English, page 5 of the e-court, and I'm sure we'll get to

24 there -- there shortly.

25 Q. But perhaps if I read this, you might remember. Towards the

Page 33040

1 bottom of this page it says:

2 "Please note that the SNB, within special warfare, to a great

3 extent contributed to the outbreak of the conflict between the Croats and

4 the Muslims and to its deepening."

5 Sir, do you remember this report passing by your desk and you

6 signing off?

7 A. I did sign this report. The text is not literally the way you

8 read it out.

9 "The SNB," it says, "while waging special warfare," which is our

10 local service parlance, "contributed to the escalation of conflict

11 between the Croats and Muslims ..."

12 Let me explain, if you want to know what special warfare is --

13 Q. No, what I would like to know is what you meant by "contributed."

14 A. That things would further escalate, or rather, to prolong the

15 conflict between them. During that time while they fought each other, we

16 could breathe more easily because we no longer had to go through all the

17 attacks that were aimed at our territory.

18 Q. That's exactly right. And in a war with three parties, there's

19 certainly some strategy to be recognised when you align two parties

20 against one, isn't there?

21 A. If you may, you will understand that I am not a military expert.

22 I simply explained the things the way they were and it could only be done

23 through friendship or different sorts of ties. For example, a Serb could

24 tell a Croat in Kiseljak: Look, they are preparing themselves to attack

25 you, the Muslims. And perhaps we could pick up that information with the

Page 33041

1 assistance of our equipment. And it was that kind of assistance that was

2 provided to the benefit of one side and the detriment of another.

3 Indeed, that particular attack took place and the Croats managed to

4 defend that part of their territory.

5 Q. I'd like to look at one more sentence in this document. It's the

6 last page of both documents, it's the last paragraph. And it says:

7 "In the forthcoming period, the SNB shall monitor the relations

8 between the Croats and the Muslims and shall endeavour to deepen and fan

9 their conflicts even more, and we shall inform you timely about further

10 developments."

11 What did you mean "endeavour to deepen and fan their conflict

12 even more"?

13 A. You see, it was a phrase I used. I think I have just answered

14 your question a moment ago in full.

15 Q. Well, would you agree with me --

16 A. It was our piece of information that in the end saved Kiseljak,

17 and that there was no massacre there or at Ilidza or at any other side as

18 regards these two warring factions. Now -- well, there were some

19 massacres in Visoko committed by the Muslims over Serbs or Croats who

20 committed crimes against Serbs. In another area, that's a different

21 matter. Now it's all coming back. The information about the massacre of

22 Croats over Muslims in Stupni Do, CNN portrayed that as a new incident of

23 Serbs slaughtering Muslims. Isn't that also a kind of propaganda, trying

24 to divert the attention --

25 Q. Sir, I think we're --

Page 33042

1 A. -- from the conflict raging on one side to a point the light on

2 to another side.

3 Q. I think we're going far afield of the subject matter here. But

4 my question for you is: If we take this information in this report and

5 those two particular paragraphs I read out to you, aren't those

6 completely in contradiction of what you wrote in your statement?

7 A. I don't think so. You have to realise there was a particular

8 dimension of living in that area. Also, parlance is important and the

9 way language was used. It was about people's lives. As for the term

10 "special warfare" and by what means, as for certain things not really

11 taking place in the end, that's an entirely different matter that can be

12 discussed separately. You, as a professional in these proceedings,

13 should also take into account all relevant factors. A moment ago you

14 said --

15 Q. Thank you, sir.

16 A. -- yourself that there were two or three sides, and then you will

17 allow that this sentence alone means nothing unless put in the context of

18 the full report and the overall situation.

19 Q. Thank you, sir. You answered my question.

20 MS. WEST: I would ask for the admission of the full report,

21 please.

22 MR. ROBINSON: No objection.

23 JUDGE KWON: Yes, we'll receive it.

24 THE REGISTRAR: As Exhibit P6095, Your Honours.

25 MS. WEST: Thank you, Mr. President. I have no more questions.

Page 33043

1 JUDGE KWON: Thank you.

2 Mr. Karadzic, do you have any re-examination?

3 THE ACCUSED: [Interpretation] Yes, Your Excellency, a few. While

4 we are on this document, I wanted to ask the witness this.

5 Re-examination by Mr. Karadzic:

6 Q. [Interpretation] Mr. Sehovac, the waging of special warfare and

7 fanning the conflict which includes one's enemy, are these legitimate

8 activities?

9 A. I think it is legitimate when trying to save lives, no matter

10 whose lives, but this is strictly my opinion.

11 Q. Perhaps I'd like to repeat the question. Yes, I'd like to have

12 it reinterpreted. I asked the following.

13 Can one side legitimately cause rifts among two of its enemies

14 which had previously joined forces?

15 JUDGE KWON: Mr. Karadzic, it's not an issue whether it was

16 legitimate or not. Ms. West raised it to raise the issue of consistency

17 in his statement. We can move on.

18 THE ACCUSED: [Interpretation] Thank you.

19 MR. KARADZIC: [Interpretation]

20 Q. Mr. Sehovac, you mentioned the Washington Agreement and the

21 alliance of Croats and Muslims against Serbs for most part of war. What

22 was included in the Washington Agreement or what did it establish?

23 MS. WEST: Objection.

24 JUDGE KWON: Mr. Karadzic, it's not relevant, it's not the issue

25 raised in Ms. West's cross-examination.

Page 33044

1 THE ACCUSED: [Interpretation] Page 53, line 1, the witness was

2 put in a position to explain why it was good for Serbs to make peace with

3 Croats and that it was interrupted by way of the Washington Agreement.

4 There were three parties to the conflict and the witness said that most

5 of the time two sides were against the third, the Serbs. And he had to

6 recall the Washington Agreement.

7 JUDGE KWON: Just -- no, no, just a second.

8 Can I hear from you, Mr. Robinson.

9 MR. ROBINSON: Well, I understand the Chamber's position and I

10 think he could be given a little leeway even if this is not the exact

11 point that she was driving at. Nevertheless, she did open up that

12 subject.

13 JUDGE KWON: Ms. West.

14 MS. WEST: Mr. President, I agree with you entirely. My issue

15 had to do with impeachment of his statement. He said one thing, I was

16 showing another. When I asked that question he wasn't responsive. I

17 asked him to pin-point a time and that's when he went into the Washington

18 Agreement. So it wasn't even responsive to my question.

19 JUDGE KWON: I agree with you, Ms. West.

20 Please move on to your next point, Mr. Karadzic.

21 MR. KARADZIC: [Interpretation]

22 Q. Mr. Sehovac, we are still on the same topic and please do caution

23 me if you deem it appropriate. Did you know -- did you know what was

24 their relationship and what were the difficulties in their unification

25 against the Serbs?

Page 33045

1 THE ACCUSED: [Interpretation] I would like to have 1D129, please.

2 MS. WEST: Mr. President, I --

3 JUDGE KWON: Yes.

4 MS. WEST: This is going to be a question that invites an answer

5 that is well beyond the scope of what I was talking about during the

6 cross-examination. He -- he appears to get -- to try to be getting into

7 the history, as might be relevant to the Washington Agreement, but this

8 witness is not the right witness for this type of discussion.

9 JUDGE KWON: Mr. Karadzic or Mr. Robinson, please move on. I

10 agree with Ms. West.

11 THE ACCUSED: [Interpretation] Very well.

12 Can we see 24498 again, 65 ter.

13 MR. KARADZIC: [Interpretation]

14 Q. While we're waiting for the document, Mr. Sehovac, such

15 information that would be arrived at by beating people up, would you

16 consider them reliable?

17 A. Well, if people presented some information under duress, one can

18 always look at it from two points of view. They can be fully reliable

19 and yet they can be fully unreliable. It very much depends on what is

20 being asked for or what is being asked of that person. I really can't

21 answer that because we didn't beat people up.

22 Q. Thank you. Was it your goal to provide reliable or unreliable

23 information to your service and your superiors?

24 A. That's what I tried to explain a moment ago. Depending on their

25 nature, information went to the service. Unreliable service [as

Page 33046

1 interpreted] was not sent to them. They were perhaps checked and

2 verified by further activities. Once checked, official notes and the

3 extracts of official notes containing such unreliable information would

4 then be amended and separate documents drafted which would then in turn

5 include accurate and verified information.

6 Q. Thank you. Mr. Sehovac, do you make a difference between

7 arresting someone and detaining someone or taking prisoner someone?

8 A. Arresting someone in police terms means arresting someone who had

9 done something unlawful. Taking prisoner would be in the military

10 domain. The difference is that of terminology. Capturing or taking

11 prisoner is different than arresting someone. Someone could be brought

12 in or arrested as part of an investigation, whereas a captured person

13 depended on the situation, whether it was in military conditions,

14 war-time conditions, or perhaps it could have been someone who had fled

15 to the other side, someone who had been an enemy soldier, and such people

16 would be then captured.

17 I have an example like that of such a defected person who had

18 fled -- actually, who was a Serb. He had been given a Molotov cocktail

19 to throw into a Serbian trench but he managed to flee. He crossed over

20 to Serbian territory and he could provide information because he said

21 that there would be other such Serbs who would be forced to do that

22 unless they managed to flee or they would be killed by snipers.

23 Q. My learned Ms. -- colleague Ms. West at page 45, line 17, said

24 that this Perica discussed the circumstances of his arrest. Kindly read

25 the preamble at the beginning of the statement. Was he a civilian or a

Page 33047

1 member of armed forces who was captured and then fled from the enemy and

2 provided the statement to the enemy side once he had escaped?

3 A. It says very nicely here that he was a member of the armed forces

4 from 16 April 1992 to 17 July 1993, and he provided a statement in

5 relation to his escape from the aggressor prison to the free territory on

6 19 February 1994.

7 Q. Military security service, is that it?

8 A. Yes. He provided his statement voluntarily of sane mind.

9 Q. What brigade is this, the military security service of what

10 brigade is this?

11 A. The 101st Motorised Brigade.

12 Q. Thank you. In other words, what can you tell us about this

13 statement? What can you say about the accuracy of this statement?

14 A. As far as I know, the 101st Motorised Brigade was in Sarajevo.

15 Q. Thank you. We will leave this topic. It suffices that we

16 identified who that was. A.

17 And now, sir, I would like to call up P2305.

18 Do you know where Brne hails from, where is he from?

19 A. As far as I know, Mr. Brne was born somewhere in Vucja Luka,

20 Mokro, or in that area over there, that's where he was born.

21 Q. And that's in the vicinity of which town?

22 A. The closest settlement is Pale and that place is between Sokolac

23 and Pale, i.e., it is in the direction of Sarajevo.

24 Q. Thank you. Can you please tell us whether he arrived as a

25 paramilitary or as a volunteer? How did these two categories move about

Page 33048

1 and what distinguished them?

2 A. During that time Brne's unit was a paramilitary unit because it

3 was founded by the radical movement. It was a Chetnik unit and he was a

4 Vojvoda. Volunteers, on the other hand, volunteered and placed

5 themselves under the command of the army in the relevant area.

6 Paramilitary units tried to maintain their independence. In certain

7 cases, they even tried to take over the command in order to exert as much

8 influence among the civilians and among the military and the police.

9 Q. Thank you. Were there any attempts to place them under anybody's

10 command? Did they formally accept that they were parts of some units?

11 Did they pay lip service to that?

12 A. Yes, we issued some documents trying to place them under

13 somebody's command and that depended on the resourcefulness of a

14 particular commander. I believe that I answered that question. His lads

15 were as they were. There were some good lads among them and there were

16 some others prone to drugs, alcohol. There were thieves and burglars who

17 managed to avoid being placed under anybody's command. Those good lads

18 would take people's advice and would place themselves under somebody's

19 command. Brne, I don't know how he ended up. It really largely depended

20 on the command. It differed from one command to the other. Those who

21 could not be placed under anybody's command fled our territory and went

22 elsewhere because he realised that he could not push his agenda, i.e.,

23 most of his bad guys left, one after another, because they could not make

24 any profit from the situation. They could not make the most of the

25 opportunities to plunder and steal.

Page 33049

1 Q. Thank you. What was the attitude of the commands and civilian

2 authorities towards the renegades among Brne's guys?

3 A. As far as I know, civilian authorities tried talking to the

4 command of the army, i.e., to the military -- to the police leadership in

5 order to devise the most acceptable way in order to avoid the escalation

6 of the security situation on the ground. They tried to see how they

7 could place them under somebody's command and they did it with some

8 success, and most conflicts within those units were avoided. The

9 civilian authorities were against those paramilitary units and they tried

10 as best as they could, as much as they could, given their influence with

11 the military and the police, to try and place those paramilitaries under

12 the control of the army.

13 Q. Thank you. This is a document issued by your service and it

14 speaks about the intolerance of that group of the new commander of the

15 Igman Brigade. What was the attitude of that group towards the civilian

16 authorities?

17 A. They behaved the same with everybody. They tried to find ways to

18 get a share in the civilian authorities, their share of influence and

19 clout. They were successful at places, perhaps, but as far as I know, at

20 the end of the day they did not exert much influence.

21 THE ACCUSED: [Interpretation] Can we have the second page in

22 English.

23 MR. KARADZIC: [Interpretation]

24 Q. And as for the Serbian version, I would kindly ask you to look at

25 the end of the second paragraph where it says -- where it says: "He

Page 33050

1 stated, inter alia," and can you then go on reading until the end of the

2 page, and you can do it aloud.

3 A. Please bear with me. I don't know what I'm supposed to read.

4 Q. The tenth line from the bottom, where it says "Brne."

5 A. He said that he could lead half of the Igman Brigade and turn

6 them towards the Chetnik Movement.

7 "It has to be emphasized that they are also bothered by the

8 civilian authorities as well as MUP workers about whom they tell

9 falsehoods and slander them, saying that they are thieves, criminals,"

10 and so on and so forth.

11 All of this corroborates my previous explanation. In this

12 specific case, Brne tried to influence the civilian authorities and the

13 command in order to get his cut, to get his share.

14 Q. Would these authorities or the MUP have covered a crime that this

15 group may have committed? Did they ever commit any crimes?

16 A. I can't speak about any crimes committed by this group because I

17 don't have any information. If we obtained such information, even in a

18 written form, we would immediately forward that to the crime prevention

19 service, i.e., the police organs who shared the premises with us. We

20 asked them to pay attention to that. If we couldn't do it in writing, we

21 did it verbally because we lived and worked very close to each other. So

22 we did not stand up on formalities. The most important thing was for the

23 information to be purposeful and to do its job.

24 Q. And one more question, Mr. Sehovac, we saw that you qualify

25 intelligence as verified, non-verified, partly verified. What is the

Page 33051

1 meaning of partly verified, which part is verified and which part is not?

2 A. Partly verified intelligence is the intelligence that we already

3 had from before and we have some segments of it. For example, let me say

4 that, for example, you don't find something in any of the documents but

5 we obtain information that on a certain day, on the 11th of November, a

6 certain unit would attack a certain area and within that context a trench

7 is being dug out below the road. Or perhaps even more specifically, a

8 partly verified piece of intelligence was the digging of a trench under

9 the runway at Sarajevo airport. At the moment when we learned that that

10 was completed, that intelligence was verified. Or, for example, in

11 another case that Mrs. or Ms. Prosecutor mentioned, I did not see what

12 the gist of the document was, but in any case it was about Lujic and

13 other people, Serbian representatives in the Muslim area. And we saw

14 that intelligence was partly verified. We had some information but we

15 were not sure that it was correct, and some of it was verified, some was

16 not.

17 Q. And now just one more question, my last question: How did you

18 qualify your sources? You now explained how you qualified your

19 intelligence and how did you qualify your sources?

20 A. Well, in our documents we qualified sources in different ways.

21 Until we could verify the intelligence provided by a source, that source

22 was under scrutiny, i.e., it was reliable until it was not reliable.

23 Q. What do you mean reliable or not reliable?

24 A. In these documents you will see that there are two or three

25 reliable sources of information. There are two or three people and there

Page 33061

1 population during war time and these were respected. He was also aware

2 that the superior commands abided by the agreed cease-fires and

3 agreements with the international peace forces.

4 Milan Mandic is engaged in the Alliance of Associations of

5 Families of Detained and Missing Persons who attempted to trace persons

6 who disappeared during the war. There are still a number of active

7 cases, but process of tracing them is slow due to the obstructions placed

8 in the way by representatives of other organisations.

9 Mr. Amor Masovic presented an untruth during his testimony, since

10 the association and Milan Mandic do not support the work of Mr. Masovic

11 for several reasons. The impartiality of the work of the institute led

12 by Masovic is debatable. This is the case because the institute is

13 headed by a politically active person, which is in contravention of the

14 Law on Missing Persons in BH. In addition, Amor Masovic participated in

15 the dislocating and concealing of secondary graves of killed Serbs;

16 therefore, he consequently participated in the concealing of war crimes.

17 MR. KARADZIC: [Interpretation]

18 Q. Mr. Mandic, I wish to put a few more questions to you in

19 connection with the work of the institute and the commission searching

20 for missing persons and imprisoned persons, especially in view of the

21 fact that Mr. Masovic testified here. Could you please tell us what kind

22 of activity you are in charge of and what are your assessments of these

23 cases?

24 A. First of all, Mr. President, let me tell you that in addition to

25 being the president of the association of families of the missing in the

Page 33062

1 Sarajevo Romanija region, and we cover seven municipalities, I can tell

2 you that I'm also the president of the association of associations or the

3 federation of associations of families of the missing, so we cover all of

4 Republika Srpska and we are all volunteers. We are an NGO. And in July

5 last year, I became a member of the advisory committee of the institute.

6 As regards the work of the institute in charge of searching for

7 the missing in Bosnia-Herzegovina, there is total anarchy, total chaos

8 there. The institute started working on the 1st of January, 2008, that's

9 when it was fully staffed. And pursuant to the law adopted in

10 December 2004 at the level of Bosnia-Herzegovina concerning missing

11 persons and it was established by the ministerial council of

12 Bosnia-Herzegovina and the international commission, ISB, in charge of

13 searching for -- ICMP, that is, they had to make a list, make records of

14 all the missing in Bosnia-Herzegovina. So from the 1st of January, 2008,

15 to the beginning of 2009. However, this -- these central records have

16 not been completed and have not even been started according to the Law on

17 Missing Persons because in the Missing Persons Act, it says that the

18 first central records or list of missing persons had to comprise active

19 cases, that is, cases where the persons had not been found yet. And only

20 after that, for purposes of historical research and to hand down a

21 legacy, only after that could one enter those missing persons who have

22 been identified because everything is known about them.

23 And secondly, one of the investigators of the institute, when he

24 visits the municipality he is in charge of to look for someone, he does

25 not know, he cannot get from his chief, Mr. Dusan Pavovic, a list of

Page 33063

1 people who have gone missing on that territory.

2 Another thing, Mr. Masovic, who used to be the president of the

3 commission -- mission of the -- at the level of the Federation of

4 Bosnia-Herzegovina and he was the president of the so-called state

5 commission searching for missing persons of Bosnia-Herzegovina, where

6 95 per cent of the Serbs didn't even know that this commission existed,

7 and later on I was able to confirm that it had been registered. So the

8 office for searching for missing people of Republika Srpska, the Federal

9 Commission of Bosnia-Herzegovina, and the so-called state commission of

10 Bosnia-Herzegovina were all merged into the institute for searching for

11 missing people of Bosnia-Herzegovina. And to this day, Mr. Masovic --

12 because the institute has its seat in Pofalici, in the former building of

13 the Energoinvest directors' building, it has a separate department in the

14 building of the Presidency at Skenderija with four offices and there they

15 keep certain documents, and for this reason, it is impossible to get to

16 the central records because he refuses to hand-over his archives to the

17 institute for searching for missing persons.

18 Q. Thank you. Can you tell the Chamber who Jovo Rosic was?

19 A. In 2000 Jovo Rosic was the president of the commission for

20 searching for missing persons and he used to be a judge, but

21 unfortunately he died.

22 Q. Of what court was he a judge?

23 A. Jovo Rosic was active in Banja Luka. I don't know which court

24 precisely, but I do know that later on he became a judge.

25 Q. Do you know what he did during the war?

Page 33064

1 A. I don't know.

2 Q. Very well. Can we -- oh, thank you for the documents you handed

3 over to the Defence.

4 THE ACCUSED: [Interpretation] Let's look at 1D07057, please.

5 1D07057.

6 MR. KARADZIC: [Interpretation]

7 Q. It is Jovo Rosic's document. He was also the minister of justice

8 and the Supreme Court judge if you recall.

9 A. I don't recall that, but I believe you.

10 Q. Can you tell me what Mr. Rosic is asking here and what he is

11 complaining about to the office of the high representative for human

12 rights in Sarajevo? Just tell us what is said on the first page, then on

13 the second, just tell us what he is complaining about and what he is

14 asking for.

15 A. Well, I can tell you that this document goes back to 2000, when

16 the late Jovo Rosic sent this document to the OHR, where the president of

17 the Bosnian commission, Amor Masovic, told him orally that he had handed

18 over two mortal remains of Serb ethnicity to the family and it was not

19 known what the names of those persons were, to whom they had been handed

20 over. There were no written records or anything. So he asked for the

21 records and for the first and last names of those people so that we could

22 take them off the list of missing persons, so that we can put them on the

23 list of those who had been found.

24 Q. Which families, if any, received unidentified bodies or mortal

25 remains?

Page 33065

1 A. Unfortunately unidentified person cannot be handed over to any

2 family.

3 Q. Can you tell us what is asked for in item 2? That is on page 2,

4 please. Perhaps you can tell us briefly what Mr. Rosic wanted to get

5 from the Bosnian commission. What was done in Dobrinja?

6 A. He wanted to receive photographs and material evidence of what

7 they did. However, the Federal Commission headed by Mr. Masovic never

8 handed that material over. There is mention of the Simon Bolivar school

9 at Dobrinja, which is some 300 metres away from the place where I used to

10 live. They entered the location right away, immediately following the

11 Dayton Accords. They collected all the mortal remains found there.

12 Allegedly, there were also Muslim people who died of natural causes who

13 were buried there as well as those Serbs who were killed around Dobrinja.

14 Unfortunately, my wife's brother was in the work detail there. When

15 sharpshooters were being trained, he was killed in Dobrinja 5 where he

16 had an apartment. He was buried after the Dayton Accords since he had an

17 uncle in Hrasno, which is also in Sarajevo.

18 Q. Thank you. Mr. Mandic, so as to be able to move forward more

19 quickly, can you tell us what was done at Dobrinja in item 2? Perhaps

20 you can read it out loud starting with Dobrinja 1.

21 A. Dobrinja 1, the bus station and the park, in 1996 and 1997,

22 individual graves were excavated by the members of this commission, most

23 likely according to the order issued by the cantonal court in Sarajevo.

24 THE ACCUSED: [Interpretation] Can we go to item 4 at the bottom

25 of the page. It should read "the Bosniak commission." It seems I'm

Page 33066

1 rushing again, whereas I shouldn't.

2 MR. KARADZIC: [Interpretation]

3 Q. Can you tell us what is the objection or request in item 4?

4 A. Item 4 reads: Location, the old Lukavica road. Demining

5 personnel reported the skeletal remains of two bodies at the

6 aforementioned location and this commission presupposes that one of the

7 people involved is Rajko Mandic.

8 Rajko Mandic was never considered a missing person. That is one

9 thing. Another thing, the old Lukavica road and that general location

10 was where my late father had been buried. Once the Dayton Accords were

11 signed, his mortal remains were dug out and placed somewhere else. He

12 has never been found.

13 Q. What about the end of the sentence, the sanitation and hygiene

14 measures were taken -- well, can you read that sentence out loud.

15 A. The Bosniak commission, without notifying the commission of the

16 Republika Srpska, carried out hygiene and sanitation measures in the

17 location and on orders of the cantonal court took the bodies to an

18 unknown location.

19 THE INTERPRETER: Could the witness please repeat the end of his

20 answer. Could there please be no overlapping. Thank you.

21 JUDGE KWON: Just a second.

22 THE ACCUSED: [Interpretation] What is missing -- that apparently

23 was done all around Sarajevo.

24 THE WITNESS: [Interpretation] Yes, it was done all around

25 Sarajevo.

Page 33067

1 JUDGE KWON: Please put a pause between the questions and

2 answers.

3 Yes.

4 MR. KARADZIC: [Interpretation]

5 Q. Under whose approval and authority, with the exception of the

6 court's, was this done? That is to say, the digging out and displacing

7 mortal remains.

8 A. Sanitation and hygiene measures in the field were done basically

9 by everyone, the civilian protection, the MUP, the hygiene inspection,

10 and everyone else. At the time, the two investigating judges who worked

11 in the area of Sarajevo, one of them, in 2006, during some excavation

12 attempts at the location, told me that they were not allowed even to

13 use -- to remove any dirt or any earth without the presence of

14 Mr. Masovic.

15 Q. Thank you.

16 THE ACCUSED: [Interpretation] Can we see the last page so as to

17 know who sent the document.

18 MR. KARADZIC: [Interpretation]

19 Q. Well, can you tell us what was this letter of yours to the

20 Bosnia-Herzegovina prosecution -- prosecutor's office?

21 A. Let me remind myself.

22 THE INTERPRETER: The witness is reading to himself.

23 THE WITNESS: [Interpretation] I always sent copies of letters I

24 received to the prosecutor's office of Bosnia-Herzegovina. At this time,

25 the prosecutor was Munir Halilovic. Three prosecutors changed working on

Page 33068

1 the case file of my late father alone.

2 MR. KARADZIC: [Interpretation]

3 Q. Thank you. What about the penultimate page, who sent this

4 document on behalf of the RS commission? Since it is in the Cyrillic

5 script can you read out the name?

6 A. Commission president, Jovo Rosic.

7 Q. Thank you.

8 THE ACCUSED: [Interpretation] Can this be admitted,

9 Your Excellency?

10 JUDGE KWON: Shall we mark it for identification.

11 MS. PELIC: [Microphone not activated]

12 JUDGE KWON: Microphone, please.

13 MS. PELIC: Excuse me. We basically don't have objections, but I

14 would like note that we think that this document has marginal relevance

15 to the case. And also I would like to note that in addition we were

16 notified about this document and additional four untranslated documents

17 yesterday, although the witness was proofed on Sunday. And we repeatedly

18 expressed our concern about the pattern of the untimely notifications by

19 the Defence and they are affecting the Prosecution's ability to prepare

20 the cross-examinations. We, although, recognise that the parties have

21 generally been accommodating on this issue, but the frequency and the

22 extent in which this goes raises the -- raises our concerns. We will, of

23 course, try to be accommodating and will not object in this case to the

24 admission of the document but being marked for identification. Thank

25 you.

Page 33069

1 JUDGE KWON: Thank you, Ms. Pelic.

2 Shall we give the number.

3 THE REGISTRAR: MFI D2896, Your Honours.

4 Yes, Mr. Karadzic.

5 THE ACCUSED: [Interpretation] Thank you.

6 Can we have 1D07058, and can we have page 2 first and then go

7 back to the first page.

8 Perhaps the Prosecution need to turn their microphone off.

9 MR. KARADZIC: [Interpretation]

10 Q. Mr. Mandic, this Marko Jurisic as the presiding of the collegium

11 of directors of the institute is asking or seeking from the cantonal

12 inspectorate or administration.

13 A. The hygiene and health inspections carried out sanitation and

14 hygiene measures in this case and he wanted to receive documentation

15 about what they did, when, where, and how.

16 Q. Thank you. Can we see the date, it is the 29th of March, 2012,

17 is it not?

18 A. Yes.

19 THE ACCUSED: [Interpretation] Page 1, please.

20 MR. KARADZIC: [Microphone not activated]

21 THE INTERPRETER: Microphone.

22 MR. KARADZIC: [Interpretation]

23 Q. While waiting for the document let me ask you this: Were these

24 exhumed graves in any way connected with war crimes?

25 A. Do you mean what was done by the Federal Commission, their health

Page 33070

1 inspection, et cetera?

2 Q. No, I had in mind the way these people died.

3 A. People were killed for two reasons in Sarajevo. In Sarajevo

4 there were no armed Serb soldiers. Everyone knows that. That's one

5 matter. Another one, a man was killed in Sarajevo for being a Serb and

6 because he had property, an apartment at a good location, and that's why

7 he was killed. Everyone was killed so that their property would stay on

8 that side and so that people would get rich overnight.

9 JUDGE KWON: Just a second.

10 MS. PELIC: Your Honour, this is going beyond the scope of the

11 witness's evidence.

12 JUDGE KWON: Yes, thank you. Ms. Pelic indicated already, but

13 I'd like to raise the problem of dealing with untranslated documents.

14 Not knowing the language is very extremely difficult to follow the line

15 of questions at all. And I can't see whether it can assist, whether it's

16 relevant or not at all. Please bear that in mind, that we do not -- I'm

17 sorry. Bear in mind that we do not understand the language and then try

18 to introduce the crux of the document first if you are to deal with

19 untranslated documents.

20 THE ACCUSED: [Interpretation] Thank you, Your Excellency. You

21 are completely right. However, we received this document only recently.

22 And even those we have sent for translation quite a while ago have still

23 not been completed.

24 MR. KARADZIC: [Interpretation]

25 Q. Mr. Mandic, can you tell us what this document is?

Page 33071

1 JUDGE KWON: And I want to hear from you in response to

2 Ms. Pelic's objection that it was beyond the subject matter that was

3 disclosed to her.

4 THE ACCUSED: [Interpretation] The witness said a moment ago that

5 the courts and exhumation commissions could not remove any amount of

6 earth without the presence and approval of Mr. Masovic. They couldn't

7 remove even a spoonful. And you are just about to see how they -- cases

8 which are two years old exceed their statute of limitation in that

9 country, which speaks volumes about the status of Mr. Masovic and a

10 number of other witnesses.

11 [Trial Chamber confers]

12 JUDGE KWON: The Chamber will allow the question. Please

13 continue.

14 MR. KARADZIC: [Interpretation]

15 Q. Mr. Mandic, can you tell us what this reply sent to Jurisic is

16 and what is their explanation as to why they cannot deliver the

17 documentation sought?

18 A. Well, the document reads that the dead-line to keep archives is

19 five years. That dead-line has expired and your request to forward such

20 information cannot be met. I asked a team of lawyers to comb through the

21 law pertaining to the city of Sarajevo, the canton of Sarajevo, and the

22 Federation of Bosnia-Herzegovina to establish how long documents should

23 be kept and who can destroy them. In the law of the Federation of

24 Bosnia-Herzegovina and in the cantonal law in Sarajevo one finds that

25 unimportant documents are kept between two and five years and that they

Page 33072

1 can only be destroyed in the presence of representatives of the

2 historical archives. In other words, the archives had to make a list of

3 unimportant documents for destruction but they need to have a clear

4 record of what was being destroyed. The law states that such documents

5 originating from the period between 1992 and 1995 may not be destroyed by

6 anyone and that they have to be kept permanently.

7 Q. Thank you. Since we do not have a translation, having in mind

8 the second page and the reference provided in terms of the 29th of March,

9 please tell us what this is. Is it a reply to the request? And perhaps

10 you can read it out starting with the dead-line for keeping documents.

11 A. On this document?

12 Q. The 9th of April, 2012.

13 A. This seemed to have been submitted on the 29th of March, 2012,

14 that's what I see before me. Yes, just above that there is the

15 9th of April.

16 Q. Can you read out the highlighted part?

17 A. "The dead-line for keeping archival material five years has been

18 expired and we cannot meet your request to forward such information. The

19 municipal civil protection staff of Novi Grad municipality is the

20 institution to provide such information given that collective exhumation

21 was undertaken according to their request. Individual requests by

22 families to exhume the mortal remains of their deceased members cannot be

23 forwarded due to the archival regulations. The dead-line for keeping

24 such case files has expired and the archives as such no longer exist."

25 THE INTERPRETER: Interpreter's note: Could Mr. Karadzic kindly

Page 33073

1 repeat his question.

2 JUDGE KWON: Mr. Karadzic, could you repeat your question.

3 THE ACCUSED: [Interpretation] Thank you.

4 MR. KARADZIC: [Interpretation]

5 Q. Mr. Mandic, which institution and who personally in

6 Bosnia-Herzegovina was duty-bound to make sure that the documents on the

7 missing persons be not -- not be destroyed?

8 A. At that point in time it was supposed to be the president of the

9 Federation Commission for Missing Persons and the president of the

10 so-called state commission of Bosnia-Herzegovina.

11 Q. And that was?

12 A. That was Mr. Masovic.

13 Q. Thank you.

14 THE ACCUSED: [Interpretation] May this document be marked for

15 identification?

16 JUDGE KWON: Do you have further documents, Mr. Karadzic,

17 untranslated?

18 THE ACCUSED: [Interpretation] Only one. Only one through this

19 witness.

20 JUDGE KWON: We'll mark it for identification.

21 THE REGISTRAR: As MFI D2897, Your Honours.

22 THE ACCUSED: [Interpretation] Thank you. May we now have

23 1D07060.

24 MR. KARADZIC: [Interpretation]

25 Q. Please tell us who wrote this letter, to whom it was addressed,

Page 33074

1 and what they are requesting in the letter. 07060.

2 A. This is the Institute for Missing Persons. The address is

3 Hamdije Cemerlica 2/15, Sarajevo. I wrote this letter. Do you want me

4 to read it? It gives the reference.

5 Can you zoom in a little bit, please? Well, what is

6 characteristic here, if I don't have to read the entire document, is this

7 is actually a reply. Here I am asking from Masovic who had replied to

8 me, so now I am responding to his letter. I know nothing about law but I

9 also -- but I found this.

10 "Also in your letter there is frequent mention of active

11 cemeteries in the Sarajevo canton and wider. In connection with this, I

12 would like to know what you mean by the word 'wider.'" This could refer

13 to a cemetery anywhere in Bosnia-Herzegovina. So a Serb who was missing

14 might have been transferred to Bihac or to Cazin. We had already

15 discovered that Andjelko Simanic, who had gone missing in Sarajevo, was

16 found in Zenica. So that was not news to us. I have been dealing with

17 this for several years.

18 And finally, in the letter it says that the bodies were

19 transferred based on certified agreement of close family members of the

20 missing persons, but I wanted to know who had approved the transfer of

21 bodies that were unidentified. That's why I asked him whether a missing

22 person who is not identified can have a family. No.

23 Q. Well, this dated is in December last year?

24 A. I think so until I see the date. Mr. Karadzic, may we scroll up

25 a bit, or down? Yes, the 19th of December, 2012, and it was handed over