150127IT

Page 30681

1 General Mladic?

2 A. I believe that is indeed the last interview he gave. It was in

3 the beginning of August at the command of the 2nd Krajina Corps at

4 Ostrelj, that's between Drvar and Bosanski Petrovac.

5 Q. Mr. Zoric, thank you very much for answering our questions on

6 behalf of the Defence team of General Mladic.

7 JUDGE ORIE: Thank you, Mr. Stojanovic.

8 JUDGE FLUEGGE: May I just put one question for clarification.

9 You just said it was in the beginning of August, but in your

10 statement it says at the end of August 1995. Which is true?

11 THE WITNESS: [Interpretation] I think we amended this statement.

12 It was the beginning of August. Together with the lawyer, I --

13 MR. STOJANOVIC: [Interpretation] With your leave, during the

14 proofing we corrected this. And thank you for your attention.

15 JUDGE FLUEGGE: Thank you very much for that clarification.

16 JUDGE ORIE: Witness, you'll now be cross-examined by Mr. Jeremy.

17 You find him to your right. Mr. Jeremy is counsel for the Prosecution.

18 Mr. Jeremy.

19 MR. JEREMY: Thank you, Your Honours, and good morning.

20 Cross-examination by Mr. Jeremy:

21 Q. Good morning, Mr. Zoric.

22 A. Good morning.

23 Q. Now I'd like to just discuss briefly your -- the units that were

24 in and your commanding officers.

25 Now, in your statement we read that after your mobilisation on

Page 30682

1 the 9th of May, 1992, you were assigned to the 15th Bihac Light Infantry

2 Brigade. Now, at this time, your brigade commander was Sveto Mrdja; is

3 that correct?

4 A. At that time, it was Colonel Matic. Sveto Mrdja came later,

5 after Matic.

6 Q. Do you know when that change in command took place?

7 A. I don't know. I wasn't interested. But in practice, soldiers do

8 know when such changes take place.

9 Q. Now we also read in your statement that in June 1992, you were

10 transferred to the press centre of the 2nd Krajina Corps. Now at this

11 time, the 2nd Krajina Corps commander was Major-General Grujo Boric;

12 correct?

13 A. Correct.

14 Q. And he was later succeeded in November 1994 by Major-General

15 Radivoje Tomanic. Is that also correct?

16 A. Tomanic, yes.

17 Q. Thank you. Now, you remained a member of the 2nd Krajina press

18 corps throughout the war from June 1992 onwards; correct?

19 A. In the 2nd Corps from June onwards, and in the VRS from

20 9 May 1992 to 31st March 1996.

21 Q. And within the 2nd Corps from June onwards, you were a member of

22 the 2nd Krajina Corps press centre until the end of the war; is that

23 correct?

24 A. Correct.

25 Q. Now, in paragraph 22 of your statement, you refer to yourself as

Page 30683

1 a journalist of Reuters. Now I understand by that, that you mean that as

2 a member of the 2nd Krajina press centre you would occasionally supply

3 material to Reuters; is that correct?

4 A. Yes, that's right. With the permission of my superiors.

5 Sometimes I didn't even ask for permission. I did whatever I thought was

6 needed, whatever I thought was right. Nobody ever had any quarrel with

7 it. Everybody even wanted to see it and they wanted the truth about

8 their work to spread.

9 As for Reuters, a team of the Reuters agency came from Belgrade

10 and spent a month with us. There was a large operation going on at that

11 time, the state of war had been declared, and they had received

12 permission from our top commander, from General Mladic and

13 General Milovanovic, to be there, and they were with me at the command of

14 the 2nd Krajina Corps, without any problem whatsoever. And in order to

15 leave, they engaged me because I was already involved in that work. They

16 hired me to work for them, and I did. But on one condition: That my

17 recordings and my stories go first to our television, the television of

18 Republika Srpska which was then called Banja Luka TV; and after these

19 recordings were broadcast on our TV, they were sent by link to Belgrade.

20 So that big TV was never competing with small TVs.

21 Q. Okay. Thank you, sir, that's an answer to my question.

22 Now I'd like to move to a different topic, and that is relating

23 to organisation and arming in Bihac during 1991 and 1992. Now in

24 paragraphs 2 to 6 of your statement, you refer to the organising and

25 arming of Muslims in Bihac during 1991 and 1992.

Page 30684

1 Now, can we agree that members of the Serb population in Bihac

2 were also organising and arming during 1991 and 1992?

3 A. As for arming, I was in Bihac. I mean, when people felt that

4 something unpleasant would happen -- we didn't believe it would actually

5 be a war. We thought it would not last very long. I often returned to

6 the press centre of the air force in Bihac, that is, at the JNA centre.

7 I felt safer there with the army. The JNA was still there then. It was

8 a guarantor for the constitution and Yugoslavia still existed. I

9 observed all of that, of course, and then I stood by them and --

10 JUDGE ORIE: Would you please answer the question. The question

11 is whether you agree that Serbs were arming as well in Bihac.

12 THE WITNESS: [Interpretation] I don't know, but probably yes,

13 both. I mean, I know about these because some officers told me that they

14 had problems with Muslims who want to attack the barracks, to seize

15 weapons, and also there was a black market.

16 MR. JEREMY:

17 Q. All right, sir. I'd like to show you a document in connection

18 with your answer and maybe we can get a little bit more clarity by

19 looking at that document.

20 MR. JEREMY: Could we please see 65 ter 31888 on our screens.

21 Q. Now, sir, on the screen before you is a report sent from the

22 public security station in Bihac to the CSB in Banja Luka and we can see

23 that it's dated the 13th of October, 1993. Now, as we see from the cover

24 page, it contains information on employees of the Bihac SJB who

25 participated in preparing and organising the Serbian people before the

Page 30685

1 war broke out. And I'd just like to briefly refer your attention to a

2 few parts of this document and then I'll have a couple of questions on

3 it.

4 MR. JEREMY: Could we go to page 2, please, in each language.

5 Q. So, sir, referring your attention to the first sentence of the

6 first paragraph, we read that:

7 "When the war broke out in the territory of Croatia or, to be

8 more precise, in Plitvice on 1 April 1991, the Serbian people in the

9 territory of Bihac municipality instinctively felt the threat posed by

10 the Ustasha and started organising themselves."

11 If we go to the second paragraph and again looking at the first

12 sentence we read:

13 "It was necessary to act in strict secrecy and illegally since

14 many Serbs had been taken in by various political parties and lived in

15 the belief that there would be no war and that the rest of the country

16 would unite in a 'new' Yugoslavia."

17 Looking at the third paragraph, sir, we read in the first

18 sentence:

19 "When the first weapons arrived in the Bihac area, they were

20 unpacked and distributed in great secrecy to civilian protection units

21 which had organised themselves illegally in the Serbian villages in Bihac

22 municipality."

23 And that paragraph goes on to discuss, a few sentences down,

24 arming during the summer of 1991 and also explains that this took place

25 away from the eyes of the public and even individual Serbs.

Page 30686

1 I'd just like to refer you to one other part of this document.

2 MR. JEREMY: Can we go to page 3 in the English, please, and

3 page 5 in the B/C/S. And in the English, it's the penultimate paragraph,

4 beginning: "The month of April 1992 ..." And in the B/C/S, it's halfway

5 down the page.

6 Q. So we read:

7 "The month of April 1992 was used to provide the Serbs with

8 additional arms and the special role of the police officers was to

9 provide transport and personally transport weapons. All the approaches

10 to the town were controlled by Muslim police officers, which made the

11 Serbs more afraid. An attempt was made to strike back at the Muslims by

12 setting up check-points manned by Serbian police officers."

13 So, Mr. Zoric, is it your position that you were not aware of the

14 organising and arming of Serbian villages in the Bihac municipality

15 during the course of 1991 and 1992, as we see described in some detail in

16 this document?

17 A. I took an oath here that I would speak the truth. This document

18 doesn't mean a thing to me. I worked as a teacher in a school in Bihac.

19 I had no idea whatsoever about any of this because I never liked weapons

20 or anything like that. The only thing that I wanted to do was to get my

21 hands on a camera so that I wouldn't have to shoot because I hate that

22 from the bottom of my heart. This is the first time I see this. I know

23 some of the people from this list. I know that they worked somewhere out

24 there, but that that was done, no, I wasn't in these circles. I spent my

25 free time in taverns, at home, in school --

Page 30687

1 JUDGE ORIE: Witness, the simple question was whether you were

2 not aware. Where you spent your time, whether you know the people in the

3 document, all that was not asked, so I do understand --

4 THE WITNESS: [Interpretation] I don't know.

5 JUDGE ORIE: Please proceed --

6 THE WITNESS: [Interpretation] I don't know.

7 JUDGE ORIE: Please proceed.

8 MR. JEREMY:

9 Q. Sir, from your answer, then, I think you'll -- well, do you allow

10 for the possibility that this organising and arming was going on but you

11 simply were not aware of it?

12 A. I allow for that possibility.

13 MR. JEREMY: Your Honours, I'd like to tender that document as a

14 Prosecution exhibit.

15 JUDGE ORIE: Madam Registrar.

16 THE REGISTRAR: Document 31888 receives Exhibit Number P7065,

17 Your Honours.

18 JUDGE ORIE: Admitted into evidence.

19 MR. JEREMY: Thank you.

20 Q. Now, sir, I'd like to move to a different topic and that's the

21 topic of population movement.

22 Now, in paragraph 12 of your statement, you refer to Serbs

23 self-organising in Serb villages around Bihac. And you state that the

24 population there relocated in an unorganised and uncontrolled manner.

25 Now I'd like to focus on another municipality bordering the Una river,

Page 30688

1 namely, Bosanska Krupa, which you also discuss in your statement.

2 Now, establishing a border on the Una river was one of the

3 strategic objectives or goals of the Bosnian Serb and political

4 leadership; correct?

5 A. Establishment of the border? I don't know. I was interested in

6 how far I could go to take pictures. I don't know anything else. I

7 wasn't interested in politics. I was just interested in recording what I

8 could report. As for borders, believe me, I had no idea whatsoever.

9 Q. Okay. Now, this Chamber has received evidence that six strategic

10 goals or objectives were presented by Radovan Karadzic to delegates at

11 the 16th Assembly in Sanski Most on the 12th of May, 1992. Now, was this

12 one of the assembly sessions that you were there recording?

13 A. I recorded that assembly. We cameramen were allowed to go in,

14 take pictures, see who was there, and finally to wait for the end to see

15 if somebody wanted to give statements to us. Only General Ninkovic

16 wanted to. We stopped General Mladic as well. He was visibly angry. He

17 said: I'm not saying anything. Ask the politicians, they know

18 everything.

19 Then General Ninkovic made a statement. I can't remember it.

20 There's no need for me to remember it, actually. There's a recording of

21 that, so it's there.

22 Q. Well, sir, at this session - and the Trial Chamber has received

23 this evidence - a representative of Bosanska Krupa declared that on the

24 right bank of the Una, there were no more Muslims in the Serbian

25 municipality of Bosanska Krupa. And he went on to state that it was

Page 30689

1 unlikely that those Muslims would have a place to return to now that

2 President Karadzic had told the assembly the happy news that the right

3 bank of the Una is the border of the Serbian Republic of

4 Bosnia-Herzegovina.

5 Do you recall that particular speech?

6 A. I've already told you, I was not present during the assembly

7 meeting. We were waiting outside, waiting for it to finish. This is the

8 first time I hear of this. I have no idea about this.

9 Q. Now -- but you were in Bosanska Krupa, however, and, in fact, you

10 recorded in the SDA premises there; correct?

11 A. SDS premises, no. I just took pictures of the positions of

12 combatants along the lines.

13 Q. Sir, my question --

14 JUDGE ORIE: Mr. Jeremy, yes, you're recorded as having asked for

15 SDA premises. I don't know why the responded as he did.

16 THE WITNESS: [Interpretation] Oh, I know what you mean. I

17 misheard what you said. SDS premises, yes. I got there with my

18 colleagues from the Krupa radio and then they showed us what they had

19 seized from Muslims. We found knives there that they called Serb

20 cutters. Then lists of persons who were supposed to be arrested or

21 killed or whatever. I cannot say. I don't know. And then other small

22 things, equipment for ...

23 MR. JEREMY:

24 Q. Sir, so just to confirm, you were present at the SDA premises

25 making these recordings and -- that you've just referred to.

Page 30690

1 A. I assumed that it was the SDA before that. I was never on the

2 Muslim side once the war started. I couldn't go. Didn't dare to.

3 Q. What date was this that you -- that you made this film?

4 A. It was sometime in the summer 1992. Now was it June or something

5 like that ... I don't remember the date. After all, it's been more than

6 20 years now.

7 Q. Sir, this -- this Chamber has received evidence that on the

8 22nd of May, 1992, there was an order from the president of the

9 War Presidency in the Serbian municipality of Bosanska Krupa to evacuate

10 the remaining Muslim population from that municipality. And that's P7385

11 [sic]. Is this evacuation of Muslims something that you witnessed?

12 A. The 22nd of May, 1992? I was in Bihac. I mean, I didn't go

13 anywhere. Actually, I didn't even believe that there was conflict in

14 Krupa. I don't know. I wasn't recording anything then either.

15 Q. Okay.

16 MR. JEREMY: Now, Your Honours, I'm going to move to another

17 document in connection with this. I wonder if I should do that now

18 or ...

19 JUDGE ORIE: I don't know how much time you would need for it.

20 MR. JEREMY: Probably more than three minutes, but not more than

21 five or six.

22 JUDGE ORIE: Then we'll just go over the 10.30 moment. Please

23 start already.

24 MR. JEREMY: Okay.

25 Q. Now, sir, this decision by the Assembly of the Serbian Republic

Page 30691

1 of Bosnia-Herzegovina that I referred to, that the Una river is an

2 indisputable border of Republika Srpska, that was communicated to

3 soldiers of the 2nd Krajina Corps, wasn't it?

4 A. I don't know. I don't think so.

5 Q. Okay. Let's just take a look at a document in connection with

6 that, that you might be able to help us with.

7 MR. JEREMY: Could we please see 65 ter 31864.

8 Q. Now, sir, on your screen you is a war bulletin by the VRS,

9 2nd Krajina Corps, and it's dated August 1992. Is that a document that

10 you recognise?

11 A. We did issue a war bulletin, but I don't remember this particular

12 issue or something. We received communication from all brigades of the

13 corps and then we just put it all together, compiled it, edited it.

14 Actually, I didn't do any of that. It was the journalists who did.

15 MR. JEREMY: Can we go to page 25 in the English, please, and

16 15 in the B/C/S.

17 Q. And, sir, we see at the bottom of the page that the document is

18 being -- or we see a reference to the 2nd Krajina Corps Information

19 Service. Now, I take from -- from that it was the 2nd Krajina Corps

20 Information Service responsible for the preparation of this document,

21 yes?

22 A. That's right.

23 MR. JEREMY: Could we please go to page 22 in the English and

24 13 in the B/C/S. And in the B/C/S I'd like to focus on the text on the

25 right-hand side of the page in -- in the middle, referring to the

Page 30692

1 SRBiH Assembly.

2 Q. So, sir, just very quickly, we see a reference to the

3 SRBiH Assembly and we read that the SRBiH has unanimously reached a

4 decision on disputable and indisputable borders of its country, and we

5 see that indisputable borders are -- and we see a reference there to the

6 Una river.

7 Now, sir, this is an example of the 2nd Krajina Corps informing

8 its soldiers about the war aims of the Serbian Republic of

9 Bosnia-Herzegovina; correct?

10 A. Well, let me tell you, maybe, but I don't remember that. I

11 wasn't really interested. I had my own work and that's what I did. As

12 for writing, I wasn't really very interested in that. Wasn't interested

13 in politics either.

14 Q. That's understood.

15 MR. JEREMY: Your Honours, I would like to tender an excerpt of

16 this document. What I'll suggest is that I create an excerpt of the

17 first page, the last page that we looked at, and this page.

18 JUDGE ORIE: Yes. Then we should reserve a number for it.

19 THE REGISTRAR: The excerpt receives number P7066, Your Honours.

20 JUDGE ORIE: And would you let us know as soon as you've uploaded

21 the excerpt --

22 MR. JEREMY: Yes, Your Honours. I'll do that this afternoon.

23 JUDGE ORIE: And would there be any objection, Mr. Stojanovic?

24 No objection. Therefore, the -- P7066 is admitted into evidence.

25 Although immediately I add to this, that instruction is given to

Page 30693

1 Madam Registrar to upload the excerpt -- to replace the text presently in

2 e-court by the excerpt still to be uploaded, and would you then provide

3 the number once you have uploaded it.

4 MR. JEREMY: Yes, Your Honour.

5 JUDGE ORIE: Then we take a break.

6 Witness, we'd like to see you back in 20 minutes from now.

7 MR. JEREMY: And, Your Honour, for planning purposes, I expect to

8 conclude within five to ten minutes after the break.

9 JUDGE ORIE: That's understood.

10 [The witness stands down]

11 JUDGE ORIE: We take a break, and we'll resume at five minutes to

12 11.00.

13 --- Recess taken at 10.33 a.m.

14 --- On resuming at 10.58 a.m.

15 JUDGE ORIE: We'll wait for the witness to be escorted into the

16 courtroom.

17 Mr. Lukic, as far as the Chamber is aware, no motion was filed

18 this morning in relation to Witness Tutoric.

19 [The witness takes the stand]

20 JUDGE ORIE: Mr. Zoric, Mr. Jeremy will now continue his

21 cross-examination.

22 Please proceed.

23 MR. JEREMY: Thank you, Your Honours.

24 Q. Now, Mr. Zoric, I'd like to conclude today by discussing Bihac

25 and the Bihac safe area.

Page 30694

1 Now, you discuss Bihac in your statement and you refer to your

2 leaving Bihac in May 1992. Now, even at that time there was a shortage

3 of food and medicine in Bihac; correct?

4 A. Correct, exactly. Shops were empty.

5 Q. Now, the next year, in 1993, in May, the United Nations Security

6 Council declared Bihac a safe area; correct?

7 A. Yes, that's correct.

8 Q. Now, in your statement, paragraphs 38 through to 45, you make a

9 series of observations in respect to General Mladic. You mention that he

10 would say the civilian population and especially the weak should be

11 protected, and you conclude the section by saying that he was especially

12 sensitive to old people and children.

13 Now, in respect to Bihac, this Chamber has received evidence that

14 during the course of 1994 and 1995, General Mladic was personally warned

15 by UNPROFOR Generals Cot, de Lapresle, and Smith to stop large-scale

16 attacks on the Bihac safe area. And that's P5186, P5193, and P792.

17 So were you aware of these attacks against the Bihac safe area in

18 1994 and 1995?

19 A. Well, I had no way of knowing. I wasn't planning attacks or

20 organising anything. I just wanted to have footage that was as

21 attractive as possible and I wanted to record the actual situation as it

22 was. I've already told you, I don't know anything about politics and I

23 was not part of those circles.

24 Q. Sir, my question doesn't relate to politics. My question relates

25 to military actions against the safe area of Bihac in 1994 and 1995 and

Page 30695

1 whether you were aware of those.

2 A. I knew partly that Bihac was a safe area but I also have some

3 convincing footage. I mean, I took pictures of weapons, cannons, barrels

4 that are lowered, cows that are grazing around these cannons, so

5 obviously they were not operating for a while. I have all of that.

6 JUDGE ORIE: Witness, the question was whether you were aware of

7 attacks, not on whether you drew any conclusions on the basis of cows

8 grazing there, but whether you knew anything about the attacks. If not,

9 please say no; if you do have, please tell us what --

10 THE WITNESS: [Interpretation] I didn't know. I didn't know

11 anything about that, no.

12 JUDGE ORIE: Please proceed, Mr. Jeremy.

13 MR. JEREMY: Thank you, Your Honours.

14 Q. Sir, you also say in your statement that you recorded meetings

15 between General Mladic and UNPROFOR officials and you say that

16 General Mladic would request that these meetings be videotaped. That's

17 paragraph 20.

18 Now, this Chamber has received evidence that at one such meeting

19 between General Mladic and UNPROFOR General Rupert Smith in Vlasenica on

20 7th of March, 1995, when General Mladic was warned that an attack on an

21 UN safe area would risk a response by NATO, he responded with a tirade of

22 threats of counteraction to Mr. Smith -- to General Smith. Now, did you

23 ever record General Mladic threatening UNPROFOR officials in this way?

24 A. My area of movement was the area of the 2nd Krajina Corps, and I

25 never recorded anything like that.

Page 30707

1 MS. EDGERTON: Thank you.

2 Cross-examination by Ms. Edgerton:

3 Q. Mr. Karac, good morning.

4 A. Good morning.

5 Q. Is it Karac or Karac?

6 A. It's a ch at the end.

7 Q. Thank you. I don't want to mispronounce your name. That's why.

8 I'd like to begin your cross-examination by getting you to

9 confirm a couple of things about the role and the function of an

10 intelligence officer. All right? And I'm going to do that by showing

11 you an excerpt from a document.

12 MS. EDGERTON: It's 65 ter number 4643. It's an excerpt from the

13 JNA manual on intelligence support to the armed forces. And we can go

14 over in English to page 16 and B/C/S to page 21, and we're looking for

15 paragraph 11 in both languages. Right. Thank you.

16 Q. So, Mr. Karac, this paragraph lists - if you can see it okay -

17 the basic intelligence support tasks in war time. And this is

18 specifically relating to brigade-level intel operations because this is

19 excerpted from the JNA brigade rules. All right? So just have a look at

20 some of those tasks. Like 11a talks about -- it says your tasks included

21 the prompt discovering of the actions and intentions of the enemy in the

22 front, in the temporarily occupied territory, and in his rear.

23 And then if in English we could go over to the next page, and

24 have a look at d, you -- part of your job is to collect intel on the

25 combat capability of your enemy.

Page 30708

1 And then in B/C/S over to the next page. E, their movement. F,

2 fire systems -- pardon me, communications, and a couple ones down is fire

3 systems. K, logistics. And go all the way down to n, data about the

4 population and material resources in enemy territory.

5 Now I know this is it at speed, but this isn't a trick question

6 at all. I just want you to confirm that these were among your basic

7 tasks as an intelligence officer; right?

8 A. Yes. But let me just explain. You said that I was a security

9 officer. That's what you said in your initial remarks. However, at the

10 time, I was assistant commander -- assistant Chief of Staff for

11 intelligence affairs. There's a difference.

12 Q. I think there might have a might misinterpretation because my

13 words specifically spoke about intelligence, and I'm well aware of the

14 divisions between the different branches, so if we could just focus on

15 intel.

16 So can you confirm that these things that we've just listed that

17 you see in paragraph 11 were among your basic tasks as an intel officer?

18 A. Yes, that can be confirmed. Those were the rules of the former

19 Yugoslav People's Army.

20 MS. EDGERTON: And so if we could have that as a Prosecution

21 Exhibit, please, Your Honours, I'd appreciate that.

22 JUDGE ORIE: It is a very long document, if I -- isn't it?

23 MS. EDGERTON: Yes. Only paragraph 11 on pages 16 and 17 in

24 English, and pages 21 and 22 in B/C/S --

25 JUDGE ORIE: Yes. And have you made --

Page 30709

1 MS. EDGERTON: -- please.

2 JUDGE ORIE: Have you uploaded an excerpt which covers those

3 pages?

4 MS. EDGERTON: Not yet but we can do it forthwith.

5 JUDGE ORIE: Then we will reserve a number for an excerpt still

6 to be uploaded. Madam Registrar, that would be number ...?

7 THE REGISTRAR: P7067, Your Honours.

8 JUDGE ORIE: Is reserved and we'll wait for the upload to be

9 reported to the Chamber.

10 Please proceed.

11 JUDGE FLUEGGE: It would be appreciated if you also could upload

12 the cover page so that we know what it is about.

13 MS. EDGERTON: Of course, thank you.

14 JUDGE ORIE: Please proceed.

15 MS. EDGERTON:

16 Q. So as an intel officer, your job, your core function really, is

17 to ensure intelligence support for your brigade's combat actions; right?

18 A. Yes, my role was to collect intelligence about the enemy of my

19 army. Of my units, I'm sorry.

20 Q. And that involves not only continually monitoring the enemy but

21 also continually assessing the information and continually reporting on

22 it to the people who need to know; right?

23 A. Yes.

24 Q. Thank you. And the people who need to know would be particularly

25 the command personnel, the Commander-in-Chief, or Chief of Staff, the

Page 30710

1 operations units, the operations officer, the security officer, among

2 others. Is that a fair comment?

3 A. For the most part, what I knew, as far as intelligence was

4 concerned, is what I presented to the Chief of Staff and the brigade

5 commander.

6 Q. Thank you. Now, something else I'd like you just to confirm, and

7 it's about the combat record of your unit and for the moment I just want

8 to focus on the 6th Brigade. And I'll show you a document that reports

9 on your unit's combat records so you can follow along with me as I read

10 it. It's P7015 MFI. And it's a paper from Sanski Most called the

11 "Informator." It's an SDS newspaper and it was published on Petrov Dan,

12 Saint Peter's Day, in 1992. P7015.

13 So that's the first page. And if we go over to pages 38 in

14 English and page 25 in your language?

15 JUDGE ORIE: Witness, could you refresh our memory what day is

16 Saint Peter's Day, so that we also know it, from a calendar point of

17 view?

18 THE WITNESS: [Interpretation] It's a saint, the Serbs celebrate

19 that saint, and that day is on the 12th of July.

20 JUDGE ORIE: Thank you.

21 MS. EDGERTON:

22 Q. Now, in B/C/S, I think you need to have a look at the third

23 paragraph from the bottom, if I'm not mistaken, on page 25. And when we

24 begin to read, tell me if I --

25 MS. EDGERTON: Yes, that's correct. And almost the penultimate

Page 30711

1 paragraph in English.

2 Q. Now, Mr. Karac, referring to the 6th Infantry Brigade --

3 MS. EDGERTON: Could you make the third paragraph from the

4 bottom, please, a bit bigger for Mr. Karac.

5 Q. This says that your brigade took part in the liberation of

6 Bosanska Krupa; the liberation and mopping up of Hambarine, Kozarusa, and

7 Kozarac; creating conditions for the take-over in Kljuc; confiscation of

8 weapons across the municipality; military defeat of the Muslim extremists

9 in Vrhpolje and Hrustovo; involvement in mopping up all areas on the left

10 bank of Una; involvement in mopping up the areas of Sanica, Krasulje,

11 Hrustovo, and Vrhpolje.

12 Now, up until July 1992, that's right, isn't it, that's an

13 accurate record of your brigade's actions?

14 A. As for this information about the activities of the brigade, I

15 know that, but as for the rest, this is the first time I see this SDS

16 bulletin report.

17 Q. But you don't disagree with the accuracy of the passage I've read

18 to you in terms of it being an accurate record of your brigade's combat

19 activities up till that point?

20 A. Yes, the brigade - parts of the brigade, not the entire brigade -

21 took part in disarming paramilitary units of the Muslims in these areas

22 that you mentioned.

23 JUDGE ORIE: Witness, more was read to you. It was specific

24 areas, specific activities. Do you disagree with that more detailed

25 description of the operations the brigade had been involved in?

Page 30712

1 THE WITNESS: [Interpretation] I can just confirm this part that

2 has to do with the activities of the brigade, Your Honour.

3 JUDGE ORIE: It's all about the brigade.

4 Could a printout be made -- no, we don't have -- could you read

5 it again. Could you read it again, Ms. Edgerton, so -- and take it step

6 by step to see whether the witness has any reason to disagree.

7 MS. EDGERTON: No problem.

8 Q. This document says:

9 "The brigade has participated in the following operations: The

10 liberation of Bosanska Krupa."

11 Is that correct, Mr. Karac?

12 A. That is not correct.

13 Q. Are you saying that your brigade didn't take part in the

14 liberation of Bosanska Krupa?

15 A. Yes, my brigade did not take part in the liberation of

16 Bosanska Krupa. That was this so-called take-over of power.

17 Q. Right. We'll come back to that. I'll continue:

18 "The liberation and cleansing of Hambarine, Kozarusa and

19 Kozarac."

20 JUDGE FLUEGGE: Ms. Edgerton, it says in the English translation

21 "mopping up" instead of --

22 THE WITNESS: [Interpretation] Yes.

23 JUDGE FLUEGGE: -- "cleansing."

24 MS. EDGERTON: Pardon me. Yes, "the liberation and mopping up,"

25 yes, correct. I apologise, Your Honour.

Page 30713

1 Q. Can you confirm that your brigade took part in the liberation and

2 mopping up of Hambarine, Kozarusa, and Kozarac?

3 A. I know of Hambarine, and I think it was Kozarac, near Prijedor.

4 Q. And I assume you take no issue, because you spoke about it in

5 your written evidence, that your brigade took part in the creation of

6 conditions for the take-over in Kljuc?

7 A. Yes.

8 Q. And, again, since you spoke of it in your written evidence, you

9 can confirm that your brigade took part in the military defeat of Muslim

10 extremists in Vrhpolje and Hrustovo?

11 A. Yes, the brigade took part in the fighting -- actually, parts of

12 the 6th Brigade took part in the battles for Hrustovo and Vrhpolje, in

13 the disarming of Muslim extremists.

14 Q. The next sentence reads:

15 "Involving [sic] in mopping up all the areas on the left bank of

16 the Una."

17 Correct?

18 A. I don't know about that. I am not aware of that.

19 Q. "Involvement in mopping up areas of Sanica, Krasulje, Hrustovo,

20 and Vrhpolje."

21 Correct?

22 A. Yes, it took part in these operations.

23 Q. Thank you.

24 MS. EDGERTON: Now, Your Honour, I realise -- I see that this

25 document, P7015, is marked for identification and I don't believe that

Page 30714

1 this page that I've read this excerpt from is included in that exhibit

2 yet. I wonder if it can be added, and then we'll address Your Honours

3 eventually more fully on the complete number of pages we might want to

4 add.

5 JUDGE ORIE: Yes, I do not know whether under that number we have

6 at this moment have an extract or if it's the whole document. Because if

7 it is the whole document, then of course this is part of it as well. But

8 I do understand that you want to make a further selection and that the

9 Defence will be in a position to add whatever they think we would need

10 for contextualising the portions selected by the Prosecution.

11 Therefore, we'll -- it remains to be MFI'd and this then will be

12 part of your selection.

13 Please proceed.

14 MS. EDGERTON: Perfect. Thank you.

15 Q. Now, Mr. Karac, you mentioned you actually took issue with the

16 assertion in this document that your brigade had participated in the

17 liberation of Bosanska Krupa. I just want to take this document away and

18 show you another one, then, P3916 [Realtime transcript read in error

19 "P3196"].

20 JUDGE MOLOTO: Can you say the number again, please.

21 MS. EDGERTON: P3916.

22 JUDGE MOLOTO: Thank you.

23 MS. EDGERTON: It's a document dated --

24 JUDGE MOLOTO: Please say it again.

25 MS. EDGERTON: P3916.

Page 30715

1 JUDGE MOLOTO: Thank you. Please say it again.

2 JUDGE ORIE: Well, let's -- apparently there is a -- I don't know

3 what explains it but apparently there's some problem in having "3916" on

4 the record.

5 JUDGE MOLOTO: Thank you so much.

6 JUDGE ORIE: It is on the record now, page 43, line 25, we have

7 it correctly there.

8 Please proceed.

9 MS. EDGERTON:

10 Q. So, Mr. Karac, you've had a chance to have a look at this

11 document. Just go down to the very last paragraph of this document which

12 is dated 11 May 1992 and it's a response to a request and it's directed

13 to the commander of your brigade. So if your brigade, as you say, didn't

14 take part in the liberation of Bosanska Krupa, what's General Talic doing

15 taking this opportunity to pay tribute to and congratulate all the

16 soldiers of your brigade, and the commander personally, for the

17 successfully completed task of liberating the town of Bosanska Krupa?

18 A. I've already told you that the brigade participated in this

19 so-called take-over of power. That is probably considered to be

20 liberation. I'm not aware of anything else but that.

21 Now, I mean, whether there was something else as well, I cannot

22 confirm that for you. Indeed, this is the first time I'm seeing this

23 document.

24 Q. Thank you. We'll move on. Just a couple of other details I want

25 to get you to confirm or to maybe augment a little bit your written

Page 30716

1 evidence.

2 You talk about your brigade's arrival in Sanski Most in

3 April 1992. Can you confirm you arrived there with about a thousand men

4 in the brigade?

5 A. I cannot confirm that for you. I don't think that there were a

6 thousand men in the brigade then when returning from Jasenovac.

7 Q. Well, how many do you think there were?

8 A. I know that approximately -- I mean, the number was growing every

9 day, so the information changed. It's possible that there were a

10 thousand. I don't know. I really don't know. I cannot give you an

11 accurate figure.

12 JUDGE ORIE: Ms. Edgerton, I'm looking at the clock.

13 MS. EDGERTON: It's time for the morning break. I apologise for

14 not noticing that, Your Honours.

15 JUDGE ORIE: Oh, we'll keep an eye on the clock.

16 Witness, we'd like to see you back in 20 minutes when we'll

17 continue. You may follow the usher.

18 [The witness stands down]

19 JUDGE ORIE: We'll resume at quarter past 12.00.

20 --- Recess taken at 11.56 a.m.

21 --- On resuming at 12.18 p.m.

22 JUDGE ORIE: While we're waiting for the witness to be brought

23 in, two short matters. I think the documents I referred to earlier, that

24 is, 65 ter 30976, no number has been assigned yet.

25 Madam Registrar.

Page 30717

1 THE REGISTRAR: Document 30976 receives Exhibit Number P7068,

2 Your Honours.

3 JUDGE ORIE: Yes, if there no objection against it being a

4 P number, admitted into evidence.

5 30977.

6 THE REGISTRAR: Receives Exhibit Number P7069, Your Honours.

7 JUDGE ORIE: P7069 is admitted. Now I'm -- let me just see ...

8 [Trial Chamber confers]

9 JUDGE ORIE: Yes. Ms. Edgerton.

10 MS. EDGERTON: Similarly, Your Honours, can I just advise that

11 the excerpts from 65 ter number 4643 have now been uploaded as 4643a.

12 JUDGE ORIE: Yes. And I think that we reserved a number already.

13 MS. EDGERTON: Correct.

14 JUDGE ORIE: Madam Registrar, that number was?

15 THE REGISTRAR: P7067, Your Honours.

16 JUDGE ORIE: P7067 is admitted into evidence. Please proceed.

17 MS. EDGERTON: And just on behalf of my colleague Mr. Jeremy,

18 similarly the excerpts from 65 ter number 31864 have now been uploaded as

19 31864a, and a provisional number for those was assigned as P7066.

20 JUDGE ORIE: I think we admitted it already and we instructed

21 Madam Registrar to replace the new -- the old uploaded document by the

22 new one. Therefore there's no need to further decide on the matter and

23 this instruction still stands.

24 MS. EDGERTON: Thank you.

25 JUDGE ORIE: We are now informed that it has been uploaded.

Page 30718

1 Ms. Edgerton, you may proceed.

2 MS. EDGERTON: Thank you.

3 Q. Just to start up again, Mr. Karac, I'd just like to ask you:

4 Have you ever met General Mladic before?

5 A. Yes, I did meet several -- General Mladic several times.

6 Q. And when was the first time you met General Mladic?

7 A. I think that the first time I met General Mladic was at the Bihac

8 front in 1994.

9 Q. Okay. So you've never met with General Mladic before 1994; is

10 that correct?

11 A. Yes, that's correct.

12 Q. Perfect, thank you. Now just to go back to your statement. You

13 said at paragraph 4 on B/C/S page 2 --

14 MS. EDGERTON: Perhaps if we could show Mr. Karac D880 again.

15 B/C/S page 3. English page 2, pardon me.

16 Q. What you said there was -- you talked about the establishment of

17 the Sanski Most Municipal Assembly and when the SDS took power in the

18 town. You mentioned some fighting between Serbian representatives and

19 the government. And then you said:

20 "The Muslims were dissatisfied because they had lost the

21 elections, so they took over the municipal building by force, using

22 weapons and renegade forces composed of Muslims and Green Berets."

23 So when you refer to the Muslims losing the elections, are you --

24 do we understand you right that you're talking about the multi-party

25 elections in November 1990?

Page 30719

1 A. Yes, that's when the SDS had a majority, at those elections.

2 Q. So your evidence is that because the SDS won the elections

3 about -- more than a year earlier, the Muslims took over the municipality

4 building in April 1992; right? Because that's what your statement says.

5 A. Yes. I mean, they took the municipality building and that's

6 where they stayed and they didn't want to leave. The Serb

7 representatives of government could not enter the building, the

8 municipality building.

9 JUDGE ORIE: Yes, you missed the gist of the question. The

10 question was whether it was because they had lost the elections, that

11 that is what is explains that more than one and a half year later they

12 took control of the municipality building.

13 THE WITNESS: [Interpretation] Your Honour, I really wouldn't know

14 what the motives were of the Muslim representatives, why they were in the

15 building of the municipal assembly then, and why they didn't allow the

16 Serb representatives to enter the municipality building. I really

17 wouldn't know.

18 JUDGE ORIE: Yes, at the same time, your statement suggests that

19 it was because they had lost the elections, where it reads:

20 "The Muslims were dissatisfied because they had lost the

21 elections, so they took over the municipal building by force ..."

22 That suggests that that's the reason why.

23 Listen carefully to the next question that Ms. Edgerton will put

24 to you.

25 MS. EDGERTON:

Page 30720

1 Q. So the fact that the non-Serb police had been dispossessed of the

2 SUP on the order of the municipality president, Nedeljko Rasula, had

3 nothing do with the Muslim move into the municipality building. Is that

4 what you're saying?

5 A. I really can't confirm. I just don't have any relevant facts to

6 explain it. I don't know.

7 Q. Well, were you -- were you there in the town of Sanski Most at

8 the time that this happened?

9 A. No, I was not in Sanski Most. The command of my brigade was in

10 Luska Palanka.

11 Q. So when you say that Muslims took over the municipal building by

12 force, that's not because you saw any of it at all; right?

13 A. I didn't see it, really. That's something I heard.

14 Q. And when you said in paragraph 5 of your written evidence that:

15 "The members of my brigade did not participate in occupying the

16 municipal building," is that also something you didn't see but you only

17 heard?

18 A. I know, and I heard, where different parts of my brigade were

19 located. I know for a fact they did not take part in this.

20 Q. Well, then you would know for a fact that what they did do was

21 secure the area all around the municipality building and other local

22 institutions to allow for other forces, Serb forces, to take them over.

23 A. I don't know about that, Your Honours.

24 Q. Well, I want to show you another document. It's P3294. It's the

25 diary of Mr. Rasula, who I just spoke about. And in this diary he has

Page 30721

1 noted a lot of discussions and minutes and decisions that were taken by

2 members of the Crisis Staff that he was a member of around this time.

3 MS. EDGERTON: If we could go to English page 19 and B/C/S

4 page 16.

5 Q. And the page in your language, Mr. Karac, I want you to go on the

6 right-hand side and just have a look at the top of the page on the

7 right-hand side. There's a heading there that says: "Course of action

8 in taking over power and establishing the Serbian municipality of

9 Sanski Most." And right below it, there's a date, and it says 14 April.

10 And --

11 JUDGE MOLOTO: 1992.

12 MS. EDGERTON: 1992.

13 Q. And it refers after that to a session of the Municipal Board of

14 the Serbian Democratic Party being held on that day, and a number of

15 things being decided. And the decisions are on the page that are in --

16 that's in front of you in your language but we'll need to go over to the

17 next page to look at those decisions.

18 So, in English, they're at the top of the page, numbers 1 to 4.

19 And you see them, too. The decisions are to conclude negotiations with

20 the SDA about the division of the municipality, that police forces

21 declare their loyalty to the Serb republic and acceptance of Serbian

22 symbols and insignia, and that any possibility of opposition or

23 intervention on behalf of the adversary be thwarted.

24 If we go to the bottom of the page that your language --

25 MS. EDGERTON: Sorry, I think we need to go to the top of the

Page 30722

1 page 17 in B/C/S and on to page 21 in -- sorry, no, stay on page -- the

2 present page in English.

3 Q. You see that -- the notation that: Security measures to

4 forestall any resistance by the opposite side are given below. And then

5 if we go over to point number 2 in English - next page - the security

6 measures are set out. A platoon of reservists from the 6th Krajina

7 Brigade are going to secure and control the bridge, the square, the park,

8 the municipal building, and the post office. And then further, at b

9 there's some tasks for the police that are set out, and at c, some tasks

10 fort Territorial Defence units.

11 Now, you agreed that your job as an intel officer was to keep

12 your command organs constantly updated on the situation. Now, three days

13 before the Muslims even entered the Sanski Most building, five days

14 before the forces that you don't know anything about attacked it, here's

15 a detailed plan for the Serb take-over of Sanski Most involving forces of

16 your brigade. So you must have been a very bad intelligence officer if

17 you didn't know anything about this plan for action.

18 MR. LUKIC: Objection.

19 JUDGE ORIE: Mr. --

20 MR. LUKIC: Where it says that this was enforced, and is it the

21 position of the Prosecution that the Crisis Staff was commanding by JNA

22 units at that time.

23 JUDGE ORIE: Well, it is a mixed objection and comment.

24 If there's any problem with putting a text to the witness,

25 Ms. Edgerton, if there's any dispute about that, please read to him

Page 30723

1 exactly what you wanted to draw his attention to.

2 MS. EDGERTON: I think I have done that, with respect,

3 Your Honours. I've read everything that I've wanted the witness to have

4 a look at.

5 [Trial Chamber confers]

6 JUDGE ORIE: Yes. So, then, one second.

7 MR. LUKIC: If I may clarify. My objection was: Is there any

8 proof that this was enforced or this is only on the paper of the Crisis

9 Staff.

10 JUDGE ORIE: Well, that's a question. That's a question which,

11 of course, does not need to appear from the document. It is -- if you

12 say you write a book, the question is did you sell it, that means that,

13 of course, the book itself wouldn't tell you that it was sold. It's just

14 a question. There's no reason to object.

15 JUDGE FLUEGGE: Mr. Lukic, the question is about the knowledge

16 about this plan for action, about this plan, not about enforcement.

17 JUDGE ORIE: Yes, and then --

18 MR. LUKIC: Ms. Edgerton asked whether this gentleman agrees that

19 it was his job as intelligence officer to keep his command organs

20 constantly updated on the situation.

21 JUDGE FLUEGGE: This is not the question. Look at the last two

22 lines of her question:

23 "So you must have been very bad intelligence officer if you

24 didn't know anything about this plan for action."

25 JUDGE ORIE: Yes, the objection is denied. May that be clear.

Page 30724

1 Ms. Edgerton, you may proceed.

2 MS. EDGERTON: Thank you. I'd just like to -- I'm trying to find

3 the cite on the transcript where the gentleman, Mr. Karac, discussed his

4 basic tasks in war time. If I could just have a moment, just to make

5 things perhaps a bit easier, Your Honours.

6 Q. Mr. Karac, you confirmed at temporary transcript page 39 that

7 your role was to collect intelligence about the enemy of your army, of

8 your units. And then my question was:

9 "And that involves not only continually monitoring the enemy but

10 also continually assessing the information and continually reporting on

11 it to people who need to know; right?"

12 And you said: "Yes."

13 So given that answer, I'd like you to have a think about the

14 question I asked about this plan of action. If this was your job, how

15 can you claim you didn't know?

16 MR. LUKIC: Objection. It should be established first whether

17 his job was to monitor Crisis Staff. Was it an enemy? I don't

18 understand at all how --

19 JUDGE ORIE: Yes, but we're not --

20 MR. LUKIC: -- those two could be connected.

21 JUDGE ORIE: We're not -- we're not discussing at this moment the

22 questions, neither are we discussing the meaning of those words. You can

23 do that in re-examination. The objection is denied.

24 MR. LUKIC: Your Honour, this gentleman was intelligence officer,

25 not security officer.

Page 30725

1 JUDGE ORIE: Mr. -- I said the objection is denied, Mr. Lukic.

2 That's a ruling.

3 Please proceed.

4 MS. EDGERTON:

5 Q. Can you answer my question, Mr. Karac, please.

6 A. Excuse me. I really don't know about these tasks of the

7 Crisis Staff. How would I? Now, whether a platoon of reservists of the

8 6th Krajina Brigade protected and controlled the bridge on the

9 Sana river, I don't know. The commander probably decided to protect the

10 safety of his unit. Because it was quite to be expected at the time that

11 the enemy would try to destroy the bridge. I don't know whether it was

12 really in the context of the Crisis Staff as the text says.

13 Q. Well, let's just flip over to page 22 in English. A meeting

14 started on 20 April 1992, and I'll try to find the B/C/S page.

15 MS. EDGERTON: Your indulgence for a moment. I think it's

16 page 18 -- no, 22 in B/C/S, I think. 21. Please go one page back to the

17 page bearing the number R1091614.

18 Now, if it takes too long, I'll come back to it after our break,

19 Your Honour, so we can move on and take advantage of the time, but I will

20 come back to that.

21 Q. I want to move on, Mr. Karac, to talk about the disarming

22 operations you -- you discuss in your written evidence. You talked about

23 two locations, Mahala and Hrustovo. First of all, you would agree with

24 me that Mahala is a Muslim suburb of the town of Sanski Most; right?

25 A. Yes.

Page 30726

1 Q. And it's a residential area. People lived there before the war;

2 right?

3 A. That's correct.

4 Q. Right. Now, in your statement, in your written evidence, at

5 paragraph 11, you talked about -- you talked in more detail about Mahala

6 and you said you weren't present when Mahala was disarmed. Where were

7 you in May 1992 during the course of the operation against Mahala?

8 A. I don't know exactly where I was at that time. But when I was

9 talking about that and saying that I was not present during the mopping

10 up of Mahala, I meant that I was not physically there. Now where I was,

11 I really can't remember now. Maybe I was in a different part of the

12 front line or something. I really don't know.

13 Q. Well, if you weren't physically there, how do you know that the

14 army issued a call to surrender weapons?

15 A. More than once the brigade command issued appeals for people to

16 surrender their weapons, and they set deadlines. A number of Muslims

17 surrendered their weapons; others didn't. And then the disarming

18 operation began.

19 Q. Okay. But you didn't quite answer my question. I asked how you

20 knew.

21 A. I knew because there was talk about it in the brigade command.

22 Every time an operation was finished, people discussed how it had

23 developed and what had been going on that day in the unit.

24 Q. Have you heard those radio announcements that you specifically

25 referred to?

Page 30727

1 A. Yes, I did.

2 Q. So you would know that those -- there wasn't just one, there

3 wasn't just two, but the call to surrender by the army was continuous.

4 It was going on all the time. You would know that; right?

5 A. I don't know how many times the announcement was made at

6 Radio Sanski Most. But, yes, they were made. I heard them several

7 times.

8 Q. Well --

9 JUDGE MOLOTO: Can I get some clarification from the witness.

10 Witness, you just said that you heard about this call to

11 surrender because it was being discussed after the operation; people were

12 talking about it in the brigades. Now, you say you heard the

13 announcements being made. Which of the two is actually correct? Did you

14 hear the announcements, or did you hear from discussions after the

15 operation?

16 THE WITNESS: [Interpretation] Your Honour, both are true. I

17 heard announcements on the radio, on the one hand; and on other hand, I

18 got more information in the brigade command after operations were

19 completed.

20 JUDGE MOLOTO: [Microphone not activated] All right. Thank you.

21 MS. EDGERTON:

22 Q. So having heard some of those radio announcements, you would have

23 heard the broadcasts that Sanski Most was a Serbian town --

24 JUDGE ORIE: Apparently the witness does not receive

25 interpretation. Could you --

Page 30728

1 MR. LUKIC: The translator cannot turn on his microphone, I can

2 see.

3 JUDGE ORIE: Yes. Yes, it seems that the -- I see from the red

4 light that the microphone is functional again. I'll switch off my

5 microphone.

6 Please proceed.

7 [Trial Chamber confers]

8 MS. EDGERTON:

9 Q. So you would --

10 JUDGE ORIE: One second. Still the microphone of the

11 interpreters' booth is not functioning properly.

12 [Trial Chamber and Registrar confer]

13 JUDGE ORIE: We'll wait for a technician to resolve the problem

14 and we should have some patience.

15 THE INTERPRETER: I have it now again.

16 JUDGE ORIE: Ms. Edgerton.

17 MS. EDGERTON:

18 Q. So had you -- if you'd heard those broadcasts -- oh, still

19 nothing.

20 JUDGE FLUEGGE: It's again not working.

21 MS. EDGERTON: How frustrating for our colleagues.

22 JUDGE ORIE: I checked already but I think there are no

23 unnecessary microphones open.

24 MS. EDGERTON: Unfortunate that no technicians have arrived

25 yet -- oh, wonderful.

Page 30729

1 JUDGE ORIE: I saw that a technician was at the door-step of the

2 booth.

3 MS. EDGERTON: Wonderful.

4 JUDGE ORIE: It seems that the functioning of the microphone is

5 on and off. I now see that it is functioning. I'll switch off my

6 microphone. If after that you would switch on yours, Ms. Edgerton, then

7 we perhaps have a chance of success.

8 MS. EDGERTON: All right.

9 JUDGE ORIE: Ms. Edgerton, is there any way you could use another

10 socket or other microphone? Because it may -- your microphone may

11 interfere with the other one.

12 JUDGE FLUEGGE: The technician should stay in the booth until the

13 problem is resolved fully.

14 THE INTERPRETER: It's not, I believe, in our booth. It's

15 somewhere else. So we will have to see where exactly it is, and the

16 technician needs to go and see that. Thank you.

17 MS. EDGERTON:

18 Q. Having heard these radio announcements -- my --

19 MS. EDGERTON: Mr. Karac still can't hear me speak in his own

20 language.

21 THE WITNESS: [Interpretation] I can hear you now.

22 MS. EDGERTON:

23 Q. So you would have heard then that Sanski Most was a Serbian town

24 and people were being called on to hand over their weapons or face

25 destruction. You would have heard that; right?

Page 30730

1 A. I didn't hear that. I knew that Sanski Most was not a Serbian

2 place. I knew that Muslims lived in Sanski Most. In what percentage, I

3 don't know.

4 Q. Well, did you hear that people were being called on to hand over

5 their weapons voluntarily or face destruction?

6 A. I never heard appeals to kill or destroy people. I heard about

7 surrendering weapons.

8 Q. Do you exclude the possibility that it happened?

9 A. I can't rule out that possibility, Your Honours. It might have

10 happened, but if it did, it was only individual cases.

11 JUDGE ORIE: Well, there may be some confusion.

12 You were asked about whether you heard the announcement on the

13 radio. Then you were asked whether you then also heard that it was

14 broadcasted that people were called on to hand over their weapons

15 voluntarily or face destruction. You said you never heard appeals of

16 this kind. And then when you answered the question about whether you

17 could exclude the possibility that it happened, "it" not being very

18 clear, but apparently Ms. Edgerton referring to the use of this language

19 in the calls made by the radio, you answered:

20 "It might have happened, but if it did, it was only individual

21 cases."

22 The question simply is: When listening to these call-ups, did

23 you hear the threatening language as was put to you by Ms. Edgerton?

24 That's the first question.

25 THE WITNESS: [Interpretation] Your Honours, after the appeal by

Page 30731

1 the brigade command, one part of the population left the area. So one

2 part of the weaponry --

3 JUDGE ORIE: That's not what -- no, that's not what I'm asking.

4 I'm asking whether you heard this language that they would face

5 destruction if they would not hand over their weapons. Did you hear that

6 language being broadcasted?

7 THE WITNESS: [Interpretation] Yes, I heard that members of the

8 Army of Republika Srpska would disarm these units.

9 JUDGE ORIE: Now, apparently for one reason or another, you don't

10 want to address the question I put to you. Did you hear that when people

11 were called up to hand over their weapons, that it was added that if they

12 would not voluntarily do so, that they would face destruction. Did you

13 hear that as part of the announcement?

14 THE WITNESS: [Interpretation] All those who did not hand in their

15 weapons were a legitimate target.

16 JUDGE ORIE: Yes, apparently the witness is not answering my

17 question, for one reason or another. Therefore, this will affect, of

18 course, the probative value of his evidence.

19 Last time: Did you hear, when you listened to the broadcast,

20 that where they were invited to hand over their weapons, that if they

21 would not voluntarily do so, that they would have to face - what was

22 it? - destruction? Did you hear that to be said on the radio?

23 THE WITNESS: [Interpretation] I cannot now give you the exact

24 quotation of the radio announcement, but I can confirm from the military

25 point of view that armed people for us were legitimate targets to

Page 30732

1 destroy.

2 JUDGE ORIE: Witness, we're not talking about targets. We are

3 talking about what was broadcasted.

4 Now, you said you don't remember exactly. Can you exclude that

5 such language was used over the radio when people were called upon to

6 hand over their weapons?

7 THE WITNESS: [Interpretation] It's possible.

8 JUDGE ORIE: Please proceed --

9 THE WITNESS: [Interpretation] I really couldn't say any more.

10 JUDGE ORIE: Please proceed, Ms. Edgerton.

11 MS. EDGERTON: Thank you.

12 Q. I noticed, Mr. Karac, in your statement that when you talked

13 about Mahala, you omitted to mention that units of your brigade shelled

14 Mahala after the radio announcements that we're talking about, didn't

15 you?

16 A. Could you please repeat that question.

17 Q. You omitted to mention, when talking about Mahala, that units of

18 your brigade shelled it after the radio announcements we're talking

19 about. You omitted it; right?

20 A. As far as I know, I know there was shelling, and from what I

21 heard from my colleagues at the command, the shells did not land on the

22 inhabited area.

23 Q. So you're confirming now that units of the 6th Brigade, your

24 brigade, shelled Mahala; right?

25 MR. LUKIC: Objection.

Page 30733

1 JUDGE ORIE: Mr. Lukic.

2 MR. LUKIC: It's exactly the opposite what the witness already

3 said.

4 JUDGE ORIE: No, the witness only said that they did not land on

5 the inhabited area. Now, that's -- again, you can further explore that

6 matter in re-examination. The objection is denied.

7 MS. EDGERTON:

8 Q. I just want to be precise. It's -- we're talking about units of

9 the 6th Brigade that shelled; right?

10 A. Yes, there were a couple of shells that fell, but I repeat: The

11 shells did not land on the inhabited area. They did not fall on

12 buildings. It was more of a warning to people to hand in their weapons,

13 to disarm paramilitary formations.

14 Q. So you have no knowledge of the fact that civilians were killed

15 in Mahala as a result of this shelling, do you?

16 A. I don't have such information. Or, rather, I don't know about

17 anything like that.

18 Q. You know, however, that your brigade, units of your brigade,

19 entered Mahala after this shelling; right?

20 A. Yes, units entered Mahala after that shelling, yes.

21 Q. So -- and as intel officer you would also know that once your

22 units entered Mahala, they arrested people in huge numbers; right? You

23 know that.

24 A. As far as I know, some of these people were arrested, and that

25 was done by the security organs.

Page 30734

1 Q. In fact, the numbers arrested were extraordinary. There was

2 around 2.000 civilians who were taken out of Mahala once units of your

3 brigade had entered; right?

4 A. I know that before the operation -- well, I don't know what the

5 exact number is, but I know that before the operation, a certain number,

6 and there were several hundreds civilians that had left the area, I mean,

7 Mahala ...

8 Q. But you're the intel officer, so your job is to get intelligence

9 on enemy activities for your units, and one of the ways you do that is by

10 interrogating people that your forces had detained. So you -- you can't

11 tell us how many people were arrested following the take-over of Mahala?

12 A. I really don't know, Your Honours. I really don't know.

13 Q. But I put the number to you of around 2.000 people. That's a

14 huge logistical concern. You would have had to mobilise resources to

15 conduct the interrogations you needed to do to brief your commander, and

16 you now don't know how many people came into your custody?

17 MR. LUKIC: Objection. Again there is mixing between

18 intelligence and security.

19 JUDGE ORIE: There's no mixing --

20 MR. LUKIC: Ms. Edgerton said "you" -- she should first ask this

21 gentleman whether he interrogated anybody and whether it was his job,

22 whether it was his duty.

23 JUDGE ORIE: It's suggested and that is permissible in

24 cross-examination. You may suggest these kind of things. That's what we

25 call leading questions. And if you disagree, then you can re-visit the

Page 30735

1 matter in re-examination.

2 MR. LUKIC: This was without foundation, Your Honour.

3 JUDGE ORIE: Yes. And that is what is allowed in

4 cross-examination. Please try to understand the difference. Of course,

5 there's no basis for it. You suggest something to a witness and then you

6 ask the witness to confirm or not, and that's exactly the difference.

7 But we may have noticed that earlier that you're not fully aware of what

8 the difference is between examination-in-chief in which leading questions

9 are not allowed, where a basis has to be laid, compared to leading

10 questions in cross-examination.

11 Please proceed, Ms. Edgerton.

12 MS. EDGERTON:

13 Q. Do you want me to repeat my question?

14 A. I think I've answered that question.

15 JUDGE ORIE: Is your answer that you were not aware of this huge

16 number of people being arrested?

17 THE WITNESS: [Interpretation] I don't know about the number, but

18 I know that people had been arrested, yes.

19 JUDGE ORIE: And did you have no idea whether it was 2, or 500,

20 or 10.000? You had no idea about how many had been arrested?

21 THE WITNESS: [Interpretation] I've already said, Your Honour,

22 that I don't know the exact number, whether it was 50, 100, 150, I really

23 don't know.

24 JUDGE ORIE: Then give us the approximate number.

25 THE WITNESS: [Interpretation] I really wouldn't want to say

Page 30736

1 anything that was not true. Believe me, I don't know exactly what number

2 it might be.

3 JUDGE ORIE: Thank you --

4 THE WITNESS: [Interpretation] If I were to say anything --

5 JUDGE ORIE: Well, the problem is that Ms. Edgerton has

6 difficulties in understanding that you, in your position, had no

7 knowledge whatsoever about numbers, where, as she suggests to you, it

8 would have had perhaps quite an impact on the job you were doing. That's

9 the issue.

10 Ms. Edgerton, please proceed.

11 MS. EDGERTON:

12 Q. Just to finish up with Mahala, Mr. Karac, in fact, the operation

13 to mop up, to disarm the settlement of Mahala was a planned and

14 co-ordinated operation that didn't only touch on that area but a number

15 of non-Serb areas. That's the truth of the matter, isn't it?

16 A. Yes, that's what the situation was. And as for all of these

17 activities that were being carried out, they had all been planned.

18 Q. Right. And the operation was so effective and the devastation in

19 Mahala was so serious that the situation was actually used as -- as a

20 threat for remaining Muslim-held areas, wasn't it? People were given the

21 choice: Surrender or face the same situation that Mahala did.

22 A. I don't know. I mean, I don't know how Muslims understood it at

23 that point. Probably that way, but I really don't know. I mean, whether

24 they understood our action then as some kind of a threat so that others

25 would do -- well, later on, it turned out that it wasn't that way.

Page 30737

1 According to some information, part of these people from Mahala

2 withdrew towards Hrustovo and Vrhpolje. Now what the number was, I

3 really don't know. However, people were saying that between 150 and

4 200 people returned to Vrhpolje and Golaja.

5 Q. Well, you know, Mr. Karac, this Chamber has received the

6 recordings of the radio broadcasts we've been discussing, and, in fact,

7 the -- there was nothing unclear about the message to the Muslims, and I

8 want to have a look at one of them.

9 MS. EDGERTON: It's P3301, please. Now, I want to go to B/C/S

10 page 3 and English page 3, in fact. And in -- hmm. Your indulgence for

11 a moment. Apologies. Could we go to 3302.

12 JUDGE FLUEGGE: I have the feeling that you were looking at the

13 English part. It's on top of the page which is currently on the screen,

14 aren't you?

15 MS. EDGERTON: For another purpose. And I'm not able to find the

16 B/C/S immediately. But perhaps we could go to 3302 and I have the --

17 mm-hm. And, again, your indulgence for a moment.

18 Let's go to English page 7 and B/C/S page 11. Thank you.

19 Q. Now, I want to direct you to the commentary by the female voice

20 which begins on page 7 and runs over to page 8. But what this woman says

21 to the people who are listening to the broadcast is that:

22 "Your resistance will force us to destroy and devastate your

23 villages which means that you will not be able to live with us in these

24 territories. And if you" --

25 MS. EDGERTON: Have to go over to the next page in B/C/S.

Page 30738

1 Q. "If you do want to go on living with us in these territories,

2 accept co-operation and hand over all the weapons and military equipment

3 and surrender to the Serbian authorities all the extremists who force to

4 you fight."

5 And then there's a list of villages a little bit further down the

6 page who are called to surrender their weapons. And -- among them

7 Vrhpolje and Hrustovo. But at the very sentence following that list of

8 names, there's one more reminder to the non-Serbs:

9 "Again, we call on you to be sensible and ask the inhabitants to

10 respond to this call. If not, we will be forced to act as we did with

11 Mahala."

12 So, Mr. Karac, the message was very clear: The choice was to

13 surrender and pledge allegiance to a mono-ethnic Serbian authority or

14 face destruction. That was the choice the non-Serbs at Sanski Most had

15 to make, wasn't it?

16 A. The Muslim population kept part of the -- actually, part of the

17 paramilitary formations kept their weapons and uniforms, and they had

18 clashed with the Army of Republika Srpska. The Army of Republika Srpska

19 responded to this provocation or, rather, disarmed these paramilitary

20 formations.

21 Now, I mean, whether they had a choice. Well, probably. I mean,

22 to hand over their weapons and to leave as free citizens or to clash. We

23 all know what an armed clash entails and what the consequences of an

24 armed clash are.

25 JUDGE ORIE: Well, is an armed clash automatically that villages

Page 30739

1 will be destroyed and devastated?

2 THE WITNESS: [Interpretation] Well, it depends, Your Honour, on

3 the intensity of combat and what kind of enemy is there. So if the enemy

4 is better fortified, then targets will be selected. So it's not the same

5 when one uses heavy weaponry and artillery or just side-arms. That's the

6 intensity that I'm talking about.

7 JUDGE ORIE: Yes, that's not what the broadcast says.

8 Please proceed.

9 MS. EDGERTON: It's time for the next break, I think,

10 Your Honours.

11 JUDGE ORIE: It is.

12 Witness, we'd like to see you back in 20 minutes. You may follow

13 the usher.

14 [The witness stands down]

15 JUDGE ORIE: We will resume at 25 minutes to 2.00.

16 --- Recess taken at 1.16 p.m.

17 --- On resuming at 1.37 p.m.

18 JUDGE ORIE: We're waiting for the witness to be escorted in the

19 courtroom.

20 Mr. Lukic, the Chamber takes it when you said that this morning

21 you complained when you were at the Registry that it was not a complaint

22 against the Registry. Not them to blame for --

23 MR. LUKIC: No, no, it's not complaint about --

24 JUDGE ORIE: No, that's how --

25 MR. LUKIC: -- the Registry. It's about our database, about our

Page 30740

1 records.

2 JUDGE ORIE: Yes --

3 MR. LUKIC: No, it's not complaint --

4 JUDGE ORIE: No, that's well understood. That's hereby on the

5 record. And then rather than to express your problems to the Registry

6 perhaps --

7 MR. LUKIC: I'm sorry if I created any confusion.

8 JUDGE ORIE: Well, if you have organised your team well, then

9 even you don't have to inform the Registry about your concerns. We leave

10 it to that.

11 There was one other matter. You intervened when Ms. Edgerton was

12 asking questions about what was ordered and you said, well, he is an

13 intelligence officer not a security officer, which suggests that the

14 logic and the formal definitions are always guiding. Again, you can

15 explore that in re-examination. But if I see that the Municipal Board of

16 a party decides on how to instruct the army, then perhaps the formal

17 lines are not always as clear as in practice.

18 Therefore, again, no problem with examining the witness on that

19 but it was not a reason to intervene in this specific context.

20 Let's proceed.

21 [The witness takes the stand]

22 MS. EDGERTON:

23 Q. Mr. Karac, just to finish up with Mahala. Just before we broke,

24 you were explaining to Judge Orie about the intensity of combat and what

25 kind of enemy is there, and made the observation that if the enemy is

Page 30741

1 better fortified, then targets would be selected. But just bringing that

2 whole discussion back to Mahala, in fact, any forces that might have

3 been, any Bosnian forces that might have been in Mahala were completely

4 outmatched by the strength of your unit and their weaponry. Isn't that

5 the case?

6 A. Yes, that's correct.

7 JUDGE MOLOTO: Is it the position of the Prosecution that there

8 were Bosnian army soldiers in Mahala at the time? Or is it just a

9 supposition, a hypothetical question?

10 MS. EDGERTON: I'm not able to give Your Honours an immediate

11 answer on this, but I'll be able to do that forthwith.

12 JUDGE MOLOTO: Thank you.

13 MS. EDGERTON: And if could you indulge me for a moment, I seem

14 to have plugged into some non-working microphones in here and I would

15 like to be able to just take full part in this.

16 Q. What I'd like to do is move on to another area you talked about

17 in your written evidence and that's about the disarming, because that's

18 what you called it, of Hrustovo. Now Hrustovo is another Muslim area of

19 Sanski Most; right?

20 A. Yes, that's right.

21 Q. And now, once again, when you refer to "the army," like you did

22 at paragraph 13 of your written evidence, and I'll read you exactly what

23 you said. You said:

24 "When the army approached Hrustovo in combat formation just

25 before it entered Hrustovo, the army came under fire, and when the army

Page 30742

1 was attacked there was an exchange of fire," and so forth.

2 So here when you refer to "the army," do you mean again to refer

3 to units of your brigade, the 6th?

4 A. Yes, precisely, I meant that, precisely.

5 Q. Now, when you discussed Hrustovo, what I also noticed was you

6 omitted to mention -- you omitted to mention that 1st -- soldiers of your

7 brigade, 1st Infantry Brigade soldiers, went in and killed women and

8 children who had taken refuge inside a garage in Hrustovo. You omitted

9 that, didn't you?

10 A. I don't know about that. Had I known, I would have said that.

11 Q. So you have no knowledge about the fact that soldiers of your

12 unit stood in front of the garage and opened up with automatic

13 machine-guns and threw hand-grenades into the garage and killed

14 civilians. Is that what you're telling us?

15 MR. LUKIC: Objection. Asked and answered.

16 JUDGE ORIE: The witness may answer the question again. In

17 cross-examination you can sometimes put a question twice.

18 Please proceed. Did you -- did you -- your evidence is that you

19 had no knowledge about what was described by Ms. Edgerton?

20 THE WITNESS: [Interpretation] Yes, but I don't know, I mean, but

21 I don't rule out the possibility that that did happen.

22 JUDGE ORIE: You also never learned later that that may have

23 happened?

24 THE WITNESS: [Interpretation] No, I wasn't interested in that. I

25 was involved in a different unit so that stayed that way, unresolved.

Page 30743

1 MS. EDGERTON:

2 Q. And Hrustovo is the one place where you were actually personally

3 on scene, right? Because that's what we can understand from your written

4 evidence.

5 A. I was not on the actual front line with the soldiers. I was part

6 of the brigade command. Because, at that time, as far as I can remember,

7 I was in Tomina, in the village of Tomina.

8 Q. All right. I'd look to move to another area and it's actually

9 the final area. And I want to do that, I want to start telling you about

10 an event on 14 May 1992. Now, on that day in Kljuc, there was a big

11 political military meeting. And General Galic was there, your commander,

12 Basara was there, and there were municipal heads from all the

13 municipalities covered by a larger area that represented the area of

14 responsibility of the 30th Infantry Division.

15 Now, at that meeting, all the participants were briefed about the

16 strategic objectives that had been announced by President Karadzic at the

17 Bosnian Serb Assembly two days previously. And you know about that

18 meeting, don't you?

19 A. Yes, I know about that meeting.

20 Q. And that's because you were there; right?

21 A. Yes, that's right.

22 Q. And so since you were there, you can confirm that -- actually,

23 I'll do this another way.

24 MS. EDGERTON: Let's have a look, then, at 65 ter number 31874.

25 Q. How big was the meeting? And where was it held?

Page 30744

1 A. I think it was held in the building of the Municipal Assembly of

2 Kljuc where I was present, myself, for a while. Part of that meeting,

3 that is. Since Colonel Basara took me along, since I am from Kljuc, so

4 that I could see my family at the same time. So that is the reason why I

5 was in Kljuc.

6 MS. EDGERTON: Now, let's go over in the B/C/S which happens to

7 be on the left-hand side, although what you see is in English, over to, I

8 think, page 3, please.

9 Q. So what you see in front of you is a JNA military notebook. And

10 you're familiar with these, aren't you? Every officer had one of these;

11 right?

12 A. Correct.

13 Q. And they're --

14 A. Yes, that's right.

15 Q. They're official books; right?

16 A. Yes. Official books that every officer had and the number of

17 pages was certified on the last page, and then these notebooks were

18 returned to the organ that they had originally been received from. When

19 it is completed, then the notebook has to be returned.

20 MS. EDGERTON: Can we go over to the next page in B/C/S, please.

21 Q. This is your notebook, isn't it? That's your name in your

22 handwriting.

23 A. Yes.

24 MS. EDGERTON: So let's go over in this B/C/S book to pages --

25 page 66. And we don't actually need to move at all in English. But

Page 30745

1 perhaps you can enlarge the right-hand side of page 66 so Mr. Karac can

2 see his own notes.

3 Q. So, Mr. Karac, here's your notes of the meeting that you were at.

4 Actually, you have it noted as being the 13th of July, 1995, and not the

5 14th. And you listed the persons present, including Colonel Galic,

6 Colonel Basara, and representatives of the municipalities of Kljuc and

7 Mrkonjic Grad and Jajce. Now --

8 A. Sipovo.

9 Q. And I missed Sipovo. So just because you haven't seen this, I

10 would imagine, in quite a few years, I'd actually like to give you a

11 moment to have a look at your own handwriting.

12 A. Yes, that's my handwriting.

13 Q. All right.

14 MS. EDGERTON: Could we go over to the next page, please, in both

15 languages.

16 Q. And I'd like Mr. Karac to have a look at both sides, again, just

17 so that can he see what his notes say on the first page, and then go over

18 to the right-hand side.

19 A. Could you please make it larger? I can't see.

20 Q. So here's the military giving some briefings on the situation,

21 including your Colonel Basara. And you could just tell us when you get

22 to the bottom of your page that you've got presently displayed in front

23 of you.

24 A. We can turn the page.

25 Q. Okay. So here you've got notes of seven strategic goals. These

Page 30746

1 were the goals that you were told had been announced at the meeting in

2 Banja Luka, weren't they?

3 A. Yes, those are the goals that were notified to us then.

4 Q. And these are ... these were your war goals, weren't they?

5 A. Those were not my war goals. Those were the goals set by the

6 state leadership.

7 Q. All right.

8 MS. EDGERTON: Now, could we just go quickly over to another

9 document and then we'll come back to this one. P2867.

10 Q. So here we've got some minutes of that same meeting that you took

11 such good notes of, listing the same participants. And if you go over to

12 page 3 in both languages, setting out at points 1 to 6, almost the same

13 strategic goals.

14 Now, I know it's going fast, but if we can hop over to page 4 in

15 both languages, I want to draw your attention to something General Galic

16 said.

17 And if you need to, I can go back to the immediately preceding

18 page so you can see, you can confirm for yourself that it is attributed

19 to General Galic; but if not, I want to draw your attention to the first

20 bullet point -- I'm speaking about the English version. I want to draw

21 your attention to the first bullet point underneath General Galic's

22 proposal for a conclusion. General Galic says:

23 "Implement the decisions from the meeting in Banja Luka but

24 submit them to the commands of units and municipalities."

25 So here's my question that I'd like you to confirm: In the area

Page 30747

1 of responsibility of your brigade, this is how co-operation as between

2 the different arms of authority happened, isn't it?

3 A. Yes.

4 Q. So the strategic goals that were set in Banja Luka were shared

5 goals that guided your military operations. That's what this document

6 shows, doesn't it?

7 A. They were not shared goals. They came down from the state

8 leadership, and the army was supposed to implement them.

9 Q. So, in fact, when you said -- can we just go back to the

10 preceding page and we can look at the first goal again, which you also

11 have noted in your notebook. So when you said in your written evidence

12 that the role of your brigade wasn't -- was to keep the peace between the

13 opposing sides, that's actually incorrect, isn't it, because the first

14 overarching goal of your brigade and the military forces was to ensure a

15 state separation of three national communities; right?

16 MR. LUKIC: Objection.

17 JUDGE ORIE: Yes.

18 MR. LUKIC: My learned friend is misrepresenting the evidence she

19 just pulled up. On the screen, we don't have it, but the last page we

20 had a moment ago, and we should see what Galic - Mr. Galic at the time,

21 probably not General yet - said.

22 JUDGE ORIE: I think what Madam Edgerton is quoting at this

23 moment is number one on the page that is before us. Is there anything

24 wrong with that quote?

25 MR. LUKIC: The question is in contradiction with this document.

Page 30748

1 JUDGE ORIE: Let me then re-read the question. One second,

2 please.

3 MR. LUKIC: Because it says --

4 JUDGE ORIE: One -- I asked you to ... the objection is denied.

5 I will give you in detail the reasons why.

6 Please proceed, Ms. Edgerton.

7 MR. LUKIC: Can you give it to me now?

8 JUDGE ORIE: I will give it at a -- before you have an

9 opportunity to re-examine the witness.

10 MR. LUKIC: Can I not object when somebody is misrepresenting the

11 evidence that it's addressing --

12 JUDGE ORIE: Mr. Lukic, this is not the beginning of a debate.

13 This is a ruling.

14 MR. LUKIC: [Overlapping speakers] ...

15 JUDGE ORIE: And I said that the reasons will follow soon in more

16 detail but I'm not inclined to do that in the presence of the witness at

17 this moment.

18 Please proceed, Ms. Edgerton.

19 MS. EDGERTON: What I'm going to do is actually maybe to help

20 Mr. Karac and go back to his diary for a second at 65 ter number 31874,

21 having seen this document.

22 And in B/C/S, I want to go to page 68, I think, and English

23 page 3. Make it English page 4, please.

24 Q. So what happened, Mr. Karac, after this meeting was that you and

25 the staff held a meeting --

Page 30749

1 MS. EDGERTON: We could go -- we should go and enlarge the

2 right-hand side of the B/C/S page of Mr. Karac's notebook. Thanks.

3 Q. So on the 14th of May in 1992, so the next day after this

4 meeting, there was a brigade command meeting. And do you see the

5 citation that says "General Mladic" and then lists a number of points

6 below that: To close geographic latitudes so that borders can be

7 defended successfully. It has been envisaged that those territories are

8 compact.

9 And then you might be able to read the next passage better for us

10 because it's in your handwriting and I think the translator has missed a

11 word. "Europe," with a question mark, "has envisaged relocation also,"

12 and then it goes on. Point number 1.

13 So I asked you at the beginning -- here's my question. I asked

14 about -- at the beginning of the second session you were here whether you

15 had met General Mladic before and you said only in 1994. So

16 General Mladic wasn't here at this meeting, was he?

17 A. I don't see that before me. I don't know which document you're

18 talking about.

19 Q. Okay. Have a look, the screen in front of you, underneath the

20 title that you've underlined where it says:

21 "Meeting of the brigade command and the battalion commander."

22 There's a small notation, just at the top on the left-hand side,

23 and it says "General Mladic."

24 If you don't see that, you can still answer the question.

25 General Mladic wasn't at this meeting, was he?

Page 30750

1 A. General Mladic was not present at that meeting. Why I wrote

2 "General Mladic," I really can't remember now. Maybe somebody talked

3 about General Mladic or something, but I maintain that General Mladic was

4 not present at that meeting.

5 Q. No, I didn't think so, but let me put this to you. Here's what I

6 think is happening at this meeting. So four days after the strategic

7 objectives are announced by Dr. Karadzic in Banja Luka, they're briefed

8 to the political -- the Serbian political and military leaders in your

9 area, and then the following day, here you were receiving even more

10 detailed instructions from Mladic's subordinates about different aspects

11 of those war goals. That's what was going on; right?

12 A. I don't understand your question. Could you maybe put it

13 differently?

14 Q. Sure. You heard the war goals. You were at the meeting where

15 they were discussed. The next day, the whole brigade command had a

16 meeting with their battalion commanders about those war goals and how

17 they should be implemented, and that's what you noted on the 14th of May,

18 isn't it?

19 A. Yes.

20 Q. Okay. So I asked you a little while ago about the first

21 objective, and we can go back to that page in your notebook so you

22 yourself can have a look at it.

23 MS. EDGERTON: It's page 66, so it's the page immediately

24 preceding. 67, pardon me. And I think it's page 2 in the translated

25 version.

Page 30751

1 Q. So have a look again at goal number 1 that you noted down. Goal

2 number 1 is:

3 "State separation from the other two communities."

4 So I want to put to you is: Based on what you said, your

5 brigade's task had nothing -- based on what you said and what happened in

6 Sanski Most, your brigade's task had nothing to do with keeping the peace

7 between the factions. It was to ensure their separation pursuant to the

8 war goals articulated by the Bosnian Serb leadership; right?

9 A. I said the brigade had arrived in the area of Sanski Most to keep

10 peace in the municipality, and that was indeed done until the moment when

11 attacks began against members of the army of what was then the Republic

12 of Bosnia-Herzegovina. Until then, they were keeping the peace.

13 However, when the members of the army were attacked, the army

14 responded, and then these orders followed and we received well-defined,

15 strategic goals.

16 Q. And in places -- just going to the two places you spoke about in

17 your written evidence, Mahala and Hrustovo, by the 30th of May, 1992,

18 there were no non-Serbs left, were there?

19 A. I think that was so. I believe the majority of the population

20 had already left.

21 Q. Thank you.

22 MS. EDGERTON: I'll have nothing further, Your Honours. And what

23 I'm going to ask is for the selected pages that we discussed about

24 65 ter 31874 to be admitted and as a Prosecution Exhibit, and we'll

25 upload those excerpts forthwith.