1 Monday, 20 January 2003

2 [Open session]

3 [The accused entered court]

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

5 JUDGE SCHOMBURG: Good morning to everybody. May we hear the

6 case, please.

7 THE REGISTRAR: Good morning. This is Case Number IT-97-24-T, the

8 Prosecutor versus Milomir Stakic.

9 JUDGE SCHOMBURG: Thank you. And the appearances, please, for the

10 Prosecution.

11 MR. KOUMJIAN: Good morning, Your Honours. Nicholas Koumjian with

12 Ruth Karper for the Office of the Prosecutor.

13 MR. LUKIC: Good morning, Your Honours, Branko Lukic, John

14 Ostojic, and Danilo Cirkovic for the Defence.

15 JUDGE SCHOMBURG: Thank you. It's always difficult, a situation

16 for Trial Chamber when the Trial Chamber knows that the accused has, or in

17 this case had had -- has had birthday, and as we just learned, today it is

18 his sacred patron saint today. Dr. Stakic, please understand that it's

19 difficult because it may sound cynical to wish you a happy birthday. All

20 what we can wish you is all the best, and may you find justice, fair

21 representatives here in the Court, and hopefully a fair Trial Chamber. So

22 all the best for you.

23 We are confronted with a request by the Defence to abbreviate

24 today's session. On the other hand, we were confronted by the request by

25 the OTP to have a shorter session tomorrow. In principle, we always have

1 to live with our schedule. And therefore, there's no leeway to abbreviate

2 on purpose without due cause. I think it's absolutely necessary that

3 Dr. Stakic has the possibility to meet the Defence team today in order to

4 prepare for tomorrow. So therefore, I would ask you to contact Detention

5 Unit; if there are any impediments related to the time, please let me know

6 that I can take the necessary measures.

7 I have to tell you that tomorrow's witness wishes all protective

8 measures possible. Therefore, I should like to hear your comments on all

9 the three issues I just mentioned, very briefly, please. First, the

10 Defence.

11 MR. LUKIC: We never object to any kind of protective measures to

12 anybody -- for anybody.

13 JUDGE SCHOMBURG: Okay. And you, please, let me -- let us know in

14 case there should be difficulties with the visiting hours today. Let's

15 see how long the witness will take us. But in principle, the Defence

16 should be prepared to call a second witness also today.

17 And what about the Prosecution? Any submissions as regards the

18 protective measures and the hearing dates?

19 MR. KOUMJIAN: No, Your Honour. But we anticipate this witness

20 will not be that short, and if we do start a second witness, that witness

21 will have to be interrupted for the following Court-scheduled witness.

22 JUDGE SCHOMBURG: So let's try to decide spontaneously on the

23 basis what happens today.

24 A last formal announcement of a decision: This Trial Chamber was

25 seized with the question whether or not to take action under Rule 91

1 related to Witness Dragic, whether or not there should be a direction to

2 the Prosecutor to investigate the matter. The Trial Chamber found that it

3 would be premature to decide at this point in time whether or whether not

4 to take these measures before we have the entire evidence before us. With

5 a view to the entire evidence, we may come to a different result, and

6 therefore, we will not decide on this before the end of the case.

7 I can't see any obstacles for hearing now today's witness. We

8 received an amended proffer. Another indication that the work load for

9 all participants is too high, meeting even on Sunday when entering or

10 leaving the tram. I think there should be some restrictions as regards

11 the workload. So, as usual, the question, any new protective measures to

12 be requested for the following witness?

13 MR. LUKIC: No protective measures for this witness, Your Honour.

14 JUDGE SCHOMBURG: Thank you. May I then ask the usher to escort

15 the witness Milos Jankovic into the courtroom.

16 [The witness entered court]

17 JUDGE SCHOMBURG: Good morning, Mr. Jankovic. Can you hear me in

18 a language you understand?

19 THE WITNESS: [Interpretation] Yes. Yes, I can, sure. Shall I say

20 my name? Will this be interpreted? Yes, yes, excellent. Good morning.

21 JUDGE SCHOMBURG: You testified earlier before this Tribunal in

22 May 2001. You are a little bit acquainted with the procedure. May I

23 therefore ask you to give us now your solemn declaration in this case.

24 THE WITNESS: [Interpretation] I solemnly declare that I will speak

25 the truth, the whole truth, and nothing but the truth.

1 JUDGE SCHOMBURG: Thank you. You may be seated. And the witness

2 is for the Defence.

3 WITNESS: MILOS JANKOVIC

4 [Witness answered through interpreter]

5 Examined by Mr. Lukic:

6 Q. [Interpretation] Good morning, Mr. Jankovic.

7 A. Good morning.

8 Q. My name is Branko Lukic, and together with Mr. John Ostojic I

9 represent, as you know, Mr. Stakic before this Tribunal.

10 Will you be so kind as to state your full name for the record,

11 please.

12 A. My name is Milos Jankovic.

13 Q. What is your father's name?

14 A. My father's name is Jovo, and my mother's name is Petra.

15 Q. When were you born?

16 A. On the 30th of October, 1948, in the village of Gornji Zabar,

17 later it was re-named Pelagicevo. The municipality used to be Gradacac,

18 but now Pelagicevo belongs to Republika Srpska.

19 Q. Not that I'm unhappy with your answer, I'm just waiting for the

20 interpretation to finish. So I would like to ask you to, after my

21 question, to please pause for a while and watch on the screen when the

22 interpretation is over.

23 Where do you live today?

24 A. My permanent place of residence is Prijedor. I have my own flat

25 there. I bought it off my company. The street is Metropolita Petra

1 Zimonjica. The building is C3 and flat number 23. I work in Banja Luka,

2 so throughout the working week, I often spent my nights in Banja Luka and

3 stay with people I know, but my official address is in Prijedor, the one

4 I've just given you.

5 Q. Will you please tell us your occupation and what sort of school

6 you finished.

7 A. I have a degree in electronics and telecommunications. I

8 completed secondary school for mechanical engineering, elementary school

9 in my own village, and then secondary school for mechanical engineering in

10 Brcko. And then later on, I went to study at the electronics faculty in

11 Banja Luka. After that, my occupation has been a degree in electronics

12 and telecommunication. I'm an engineer.

13 Q. Where do you work today?

14 A. At the public security centre in Banja Luka, department for

15 communications. The official name is Communications Department. I am the

16 head of a group for maintenance of all communications equipment. There

17 are five or six technicians in the team. I lead the team. And I'm in

18 charge of maintenance and mounting the equipment, if necessary. It's the

19 technical part of the job for all communications, telecommunications

20 equipment used by the police.

21 Q. Where did you work in 1992?

22 A. Since I started working for the police in 1980, until the last

23 year, I kept working for the police, and I was also employed by the police

24 in 1992 in Prijedor. It was called Public Security Station Prijedor. I

25 was also head of that same department for telecommunications.

1 Q. Let me ask you the following: Were you ever a member of any

2 political party, or are you today a member of any political party?

3 A. In the socialist system in the former Yugoslavia, it was almost a

4 requirement to be a member of the League of Communists. And in view of

5 the position I held, I virtually had to be a member. Afterwards, when the

6 League of Communists disintegrated, and the multiparty system was in

7 place, I was never again a member of any political party. I didn't belong

8 to any political party, nor was I in the least involved with any of the

9 political parties. I just wasn't interested.

10 Q. Will you please explain the following: In 1992, what were your

11 duties as head of the communications department and cryptographic

12 protection?

13 A. Ever since I worked in that job, I've had the same duties, and I

14 had the same duties then: I must be familiar with the way the department

15 is organised, its activities, the activities of the police; and my job was

16 to adjust and organise all communications, people working for

17 communications; organise all the equipment in order to secure an efficient

18 transfer of information. We are talking about written information, we are

19 talking about telegrams, dispatches, as well as oral communication,

20 communication by telephone, radio; the sort of communication used by the

21 police. I was in charge of organising and enhancing the quality of the

22 communications service. Nothing else. This also implied working with

23 information that needed to be encoded, protected cryptographically, so

24 protection of information was also part of my business, and I'm talking

25 about such information as needed protecting.

1 Q. Now I will show you a table. So if you could please comment on

2 it. It's written in English, but I think we'll manage to deal with it

3 nevertheless.

4 MR. LUKIC: [Interpretation] So could the usher please show the

5 witness this document.

6 THE WITNESS: [Interpretation] I can't hear anything and I can't

7 really see it here. Fine.

8 MR. LUKIC: [Interpretation]

9 Q. Have you managed to have a look?

10 A. Let me just have a minute to look at this.

11 MR. KOUMJIAN: If it would be helpful, I do have a B/C/S copy of

12 that same document.

13 JUDGE SCHOMBURG: Am I correct that --

14 THE WITNESS: [Interpretation] I think I can understand this, what

15 it says here, even without the translation. This is fine. So if there's

16 no need for you to have the original, I don't really need one. I

17 understand this.

18 JUDGE SCHOMBURG: May I, nevertheless, interrupt for a moment. Is

19 there any B/C/S version, or is this a document provided later on? Because

20 the addition of the ethnicity to the persons mentioned there seems to be a

21 little bit strange. But I don't know. What is the source of this

22 document? Can you comment already on this now, or do you want to come

23 back to this later?

24 MR. LUKIC: [Interpretation] We received this document from the

25 Prosecution, and this is obvious, if you look at the number on this

1 document. So this document is part of the testimony given by one of the

2 commanders of the police station in Ljubija.

3 JUDGE SCHOMBURG: We have to come back to this issue later. There

4 are no definite objections by the Prosecution?

5 MR. KOUMJIAN: Absolutely not.

6 JUDGE SCHOMBURG: Okay. Then please proceed.

7 MR. LUKIC: [Interpretation]

8 Q. Mr. Jankovic, if you look at this diagram, can you please explain

9 to us the chain of command in your own public security station at that

10 time, starting with the Sarajevo MUP.

11 A. Yes, I can. I've had a look in the meantime, and I think there

12 are several mistakes here. I'm going to start with the MUP and try to

13 explain, because I think I can still remember exactly how it was at that

14 time. I'm going to try to insert the corrections.

15 The police, the hierarchy of the police, we were all directly or

16 indirectly subordinated to the MUP of Bosnia and Herzegovina. It says

17 here: "MUP Sarajevo, Minister Delimustafic." That was correct at the

18 time. And then Avdo Hebib, as far as I know, this MUP box here, it had

19 two different sectors, public and state security. I, as well as all the

20 other police, was public security, and state security was a different

21 sector. We were often in the same building, but state security answered

22 to their own boss in MUP. But certainly, they were indirectly

23 subordinated.

24 The uppermost box I'm pointing at, the MUP, only this line here

25 should really be there, and then it says, "Banja Luka security centre,

1 Stojan Zupljanin." That's correct. But what isn't correct is there are

2 other centres here, like Doboj, Zenica. But certainly you can't only have

3 SUP Prijedor here because the Prijedor SUP, this line here leading to the

4 Prijedor SUP, should go into this other box, State Security Section Banja

5 Luka, and not the one above. The Prijedor SUP, that was not an official

6 name at the time. It wasn't its official name. This was from the

7 socialist system. It was the Secretariat for Internal Affairs. You see,

8 it's different. Up there it says MUP, and down here it says SUP. There

9 is the Ministry of the Interior, and this is not a SUP. This should be

10 SJB Prijedor. That would be the correct way to spell it, the public

11 security station. But I know what this is referring to. It's true, there

12 was Hasan Talundzic at the time, and he was a Muslim.

13 This section here, State Security Service, and their sector was

14 directly subordinated to the central office, although it was in the same

15 building in Prijedor, but that means the connection is not this but

16 straight up and then through them, on to the MUP. If you can see what I'm

17 trying to explain. The Banja Luka centre, in addition to the SUP, there

18 were other security agencies; Dubica, Gradiska, so in other words, other

19 municipalities. And the police across those municipalities, they were

20 called the SJB, public security stations.

21 And now I will tell you about the Prijedor public security

22 station. The public security station in Prijedor had a number of

23 organisation units. Here -- this was normally considered the main one,

24 the police down here, what you can see. And they were wearing uniforms,

25 and they were officials. So they were considered to be the main office.

1 And then you have something down here, too, but that doesn't matter

2 because they were really the most important part of the station and of any

3 station. And then beside them, it says crime, but the official title was

4 Crime Prevention Unit, Fire Prevention and Foreigners. That was the full

5 name, but it's true that Ranko Mijic was the head, and that he was a Serb.

6 Then there was a small subsection, communications. We were also

7 officials of the public security station. There were usually between five

8 and seven of us, and you see my name here. I was the head of that

9 particular section, and that's also true.

10 And then this part here, general affairs, I think that's what it

11 says, Slavica. The official name, the one we used, was Section for

12 General and Administrative Affairs. They were in charge of citizens' IDs,

13 driving licenses. They would issue citizens with passports. For the

14 needs of the citizens, for the needs of the public, they were in charge of

15 that. It says Slavica, yes, that's right. Her last name was Manojlovic,

16 at this time as far as I can remember. There were changes, frequent

17 changes, I'm also sure that she was the head at the time, but they had new

18 heads of department all the time, quite frequently.

19 Now I'm talking about the police division. So it says Prijedor

20 Station, Dusan Jankovic, Serb. This was the general police station, and

21 we had the traffic police. The name was "milicija" at that time; now we

22 refer to it as "policija," so I'll just stick to "policija." We have

23 Prijedor station. Their commander was Dusan Jankovic. And that's

24 correct. And then here it says Omarska station, Milutin Bujic. There is

25 a mistake here. Omarska station was not a station that was part of a

1 formation at that time. Not at that time. It used to be once upon a

2 time, but at this time it was only a branch office, it was a department.

3 So commander did not have a deputy. And they didn't have as many people

4 working there. That's to the best of my recollection. I think I'm not

5 wrong on this one, but it was a long time ago. Milutin Bujic, partly yes,

6 he was removed at one point, but I can't remember when exactly.

7 Here it says Kozarac station. This is not correct. Kozarac was

8 also just a department. The commander was Osman Didovic, a Muslim, that

9 is also correct. And he had no deputy because this was only a police

10 department, not a station.

11 Ljubija station. Now, Ljubija was a station. And Branko Bjekic,

12 a Croat, was its commander. I can't remember who his deputy was during

13 this period. If someone reminded me, perhaps I would remember, but right

14 now I can't seem to recall who the deputy was.

15 Traffic. Fikret Kadiric. This was called Traffic Safety Police

16 Station. So those were traffic police. They were in charge of

17 controlling traffic along the roads and ensuring the safety of traffic.

18 We're talking about cars and personal vehicles, not about trains. He was

19 a Muslim. Yes, that's correct. This was also a police station, like all

20 the other stations. It had its commander. They would control and monitor

21 traffic along public roads, so that's about it.

22 Q. Let me just ask you, Mr. Jankovic --

23 JUDGE SCHOMBURG: Mr. Lukic, may I just interrupt. For technical

24 reasons, may we have a break of about 3 minutes. Thank you.

25 --- Break taken at 9.37 a.m.

1 --- On resuming at 9.39 a.m.

2 JUDGE SCHOMBURG: So please continue. Thank you. May I only ask,

3 do we know about this document from what point or what point in time this

4 document reflects?

5 MR. LUKIC: [Interpretation]

6 Q. Did you hear the question?

7 A. I don't know who is supposed to answer; me or you. Is it me who

8 is supposed to answer?

9 Q. Every question is put to you. I cannot testify.

10 A. Given the names, as far as I can remember, Minister Delimustafic,

11 SUP Prijedor; Hasan Talundzic, this must be the period after the

12 multiparty elections. Because this is when they were appointed, after

13 that, and after the end -- after the takeover, after that, Hasan Talundzic

14 and Delimustafic were not any longer, after the 30th of April, 1992. It

15 is certain that this is the period from their appointment. As far as I

16 can remember, it was in the spring of 1991. I can't give you the precise

17 date. But between the spring of 1991 until the spring, or more precise,

18 April 1992. The one who put together this table, I don't know what period

19 he meant when he put the table together, but this must be that period

20 because at that time, we were the public security station, and not a

21 centre. We were the public security station, and we didn't have -- there

22 was a restriction in our organisation. So what I said, Omarska and

23 Kozarac were not stations; they were departments or subsections. That

24 implies fewer people, and that is that.

25 Q. Thank you. In this chain of command and reporting and giving

1 orders, can there be a municipal body? Can a municipal body appear, a

2 body of the Municipal Assembly of Prijedor? Can it appear in this chain

3 of command?

4 A. Obviously it is not here. And whoever put the table together knew

5 that there wasn't. I know that there wasn't. We are police, and like the

6 army, we have our hierarchy of command. And I was just a small -- head of

7 a small department, and my boss was the chief of the public security

8 station. At this period of time, it was Hasan Talundzic. Previously

9 there were other people, later on there were other people. Hasan

10 Talundzic, he should have been -- there is a mistake here in the drawing.

11 This line is wrong. This line is correct. So Hasan Talundzic's boss was

12 the chief of the public security centre in Banja Luka, Stojan Zupljanin,

13 and he, Stojan Zupljanin, reported to the minister in Sarajevo, the

14 Minister of the Interior in Sarajevo. So this is the hierarchy. This is

15 the chain of command. If people obey it or not is a different story, but

16 this is the rule here. In my work, I knew whom I was supposed to obey;

17 that was my head. And he had to obey his head, and he had to obey the

18 minister, and the minister had to report to the government, and that is

19 the chain of command.

20 Q. Before April 1992, was the situation the same? And after the

21 September of 1992, was the situation again the same as it was between the

22 April and September of 1992?

23 A. No.

24 Q. I'm not referring to the names; I'm referring to the police,

25 whether in all the periods -- can you please listen to my question, sir.

1 Was there a rule in place in all the periods of time that the bodies of

2 the Municipal Assembly of Prijedor could not interfere with the work of

3 the police in Prijedor?

4 A. Can you please repeat the first period. What was the first period

5 that you mentioned? What period of time are you referring to, the first

6 period of time?

7 Q. From the beginning of 1991 and onwards, was it ever the case that

8 a body of the Municipal Assembly of Prijedor, that they could order

9 something to you as the head of the department?

10 A. No, they couldn't issue any orders as far as I can remember. But

11 there were influences outside the police, and that is that the parties

12 proposed heads of departments. But it was the minister who appointed

13 them. For example, the chief of the public security station and the

14 commander. But the parties, as far as I can remember, as far as I was

15 informed - I was not in the position to know that, it was not my

16 obligation to know that - but I was familiar with something, but some

17 things were arranged at the level of Bosnia and Herzegovina, and that was

18 that the chief of the police was appointed by the ruling party in the

19 municipality, and in Prijedor it was the SDA. And they appointed Hasan

20 Talundzic. And the second, by the number of votes, was the SDS, and they

21 were supposed to appoint the commander. Not appoint, but they proposed

22 the commander and the minister was the one that the commander would go for

23 talks in Sarajevo, and the minister would then issue a decision, and the

24 minister would then appoint this person, and that was, at the time, Dusan

25 Jankovic. So that is that. Everything else was done beyond the influence

1 of the parties. And I'm not aware of the fact that the Municipal Assembly

2 had any influence, and I don't know what would be the basis of their

3 influence. I don't think it is under the law.

4 As far as I was concerned, I had my head, and he had his head, and

5 the municipality was something completely different.

6 Q. Did you personally ever receive from the municipality of Prijedor

7 or its Executive Board any orders from them? Did you receive any orders

8 from them?

9 A. No, no. There were at the time people who were not experienced,

10 who were not knowledgeable, and even they were clear that they couldn't

11 issue such orders. The only orders I could receive and obey were from my

12 commanders, from my superiors.

13 Q. Thank you. For the time being, we will not need the document that

14 is in front of you.

15 MR. LUKIC: [In English] Your Honour, should this document be

16 marked provisionally as an exhibit?

17 JUDGE SCHOMBURG: If it's your intention to tender it, we can

18 immediately decide. Any objections by the side of the Prosecution?

19 MR. KOUMJIAN: No, Your Honour.

20 JUDGE SCHOMBURG: Then may I ask the next exhibit number for

21 Defence exhibit.

22 THE REGISTRAR: D46A, Your Honour.

23 JUDGE SCHOMBURG: Admitted into evidence, D46A. Thank you.

24 MR. LUKIC: [Interpretation]

25 Q. Before the takeover in Prijedor, what happened with the

1 transmitter on Kozara? What do you know about that?

2 A. A transmitter on Kozara carried the programmes on two channels.

3 There were two channels of Sarajevo TV. And I don't remember when it was,

4 but I believe it was at the beginning of 1991 that that transmitter on

5 Kozara -- I won't claim that for a fact. I believe that one channel was

6 adjusted to carry programmes from TV Belgrade. I can't claim this for a

7 fact, but I believe that one of the channels was still dedicated for TV

8 Sarajevo, and the other one was adjusted for TV Belgrade.

9 Q. How did that happen? Why was the transmitter adjusted to receive

10 Belgrade, programmes from Belgrade?

11 A. Those who do that, the technicians and all those who make

12 decisions and technicians who are supposed to carry out the decisions,

13 they are all in Banja Luka because television Sarajevo had in Banja Luka a

14 branch office so to say, and they were the ones who were deciding on the

15 policies, on the programmes, on the transmitters. And for us in Prijedor,

16 the only thing that happened was that shows were different, programmes

17 were different. Some people liked it. Some not. I don't watch

18 television much, but I noticed that -- this change, that that was that. I

19 was not very much interested in what had happened, but I don't know if

20 anybody from Prijedor had any influence on that.

21 Q. Can you please explain to us whether you could also receive

22 Croatian programmes after the transmitter was adjusted to receive

23 programmes from Belgrade?

24 A. Since I am an expert in electrical engineering, I can tell you

25 that in the area of the town of Prijedor, my acquaintances very often will

1 ask me for help when they want to receive some programmes from Zagreb.

2 And since I'm an expert on that, and this is my particular field of

3 interest, I can tell you with a high degree of expertise, I am familiar

4 with the situation. The town of Prijedor and its general area belong, in

5 rough outlines, to the area covered by the transmitters of Croatian

6 television.

7 Q. You are talking about the Croatian television which -- where are

8 they based?

9 A. They are based all over Croatia, and the most powerful one is on

10 the mountain Pljesivica, above Bihac. That facility is on the border. I

11 don't know exactly where, but it is on the border between the Republic of

12 Bosnia and Herzegovina and the Republic of Croatia. It is the mountain of

13 Pljesivica above Bihac. There are some other transmitters. There are the

14 ones that are closer in the north of Croatia, but they are limited in

15 their outreach by the Kozara mountain. And because of what I have just

16 said, citizens of Prijedor, some of them could receive programmes from

17 Croatia. They had the picture, they had the turn. Maybe not of the

18 highest possible quality, but they could receive it. And there were, on

19 the other hand, some other citizens who couldn't receive those programmes.

20 And those areas, due to the laws of physics, all of these areas are very

21 close. So, for example, I have a case of my friend, a Croat. He asked me

22 to help him receive a programme from Zagreb, but I couldn't do it, whereas

23 his neighbour, whose house is only 60 metres away across the road, could

24 receive it. I tried to help the former one, but I couldn't. So some

25 people could receive these programmes; others couldn't. And it all

1 depended on where their TV receiver was actually placed.

2 Q. Was the situation the same during 1992?

3 A. Yes. Yes, it was. There are such areas, because this is an

4 uneven ground. For example, I can give you an example of my in-laws'

5 house. Their antennas are in such a position that they could not receive

6 the programmes from Kozara, which is only 5 or 6 kilometres away. And

7 they could receive programmes from Zagreb, which is hundreds of kilometres

8 away, because there is a different optical visibility to Pljesivica, and

9 between them and Kozara, there was another very high hill. So there are

10 even such cases.

11 Q. And now I would like to move from these technical issues to the

12 9th of April.

13 MR. LUKIC: [Interpretation] I'm going to ask the usher to show you

14 a document. I don't know whether --

15 Q. Can you please explain what this is about, and do you still have

16 the original of this document?

17 A. Can I start?

18 Q. Please, go ahead.

19 A. This is a photocopy of a paper whose original I still have to this

20 very day. Why have I kept such papers? This may be due to my occupation.

21 I collect all the papers and then I discard some, because there are many

22 papers at my home which are not important. This is one of those papers

23 which I have kept. The day, the 9th of April, I couldn't remember the

24 date. I know that this is certainly the 9th of April, because this is my

25 handwriting, and I can remember this very well. And this is what it was

1 all about.

2 On the 9th of April, I had to maintain some facilities in Novi

3 Grad, which was then called Bosanski Novi. And I went there with one of

4 my technicians, and we repaired some facilities there. And around 2.00,

5 we returned to Prijedor, to the public security station. And I had only

6 heard before that, and I didn't find that important, but I heard it, and I

7 remembered it, that the chief of the public security centre in Banja Luka,

8 Mr. Stojan Zupljanin, was supposed to come to the municipality of

9 Prijedor, and that he was supposed to negotiate or agree on the -- I

10 believe actually we belong, this public security station belonged to the

11 central public security centre in Banja Luka, and there were some

12 intentions to separate us from the centre. And this is what I assume.

13 Nobody actually told me. Nobody had to tell me. I didn't ask anybody.

14 But that's what I felt, because that was a topical issue at the time. And

15 I suppose that's why he came there to talk to the municipal bodies. I

16 don't mean municipal, but that's what also was always said. These

17 authorities, those authorities, he was supposed to talk to Mirza Mujadzic

18 and people around him. And Mirza Mujadzic was the head of the SDA for

19 Prijedor, so he had to talk to the parties. That was my conclusion. And

20 I cannot be certain about that. And it wasn't important at the time. But

21 that's what I heard, that he was supposed to arrive there.

22 And what I deemed important at the time was that he was my

23 superior, and I didn't want him to notice that anything was not in order.

24 And that's what I was concerned with. But as I said, I went to Novi Grad,

25 I had some facilities to maintain there, and then we came back. The

1 technician, whose name was Mladen Raus, and myself, we returned at 2.00.

2 Working hours were until 3.00. It was 1400 hours, and my working hours

3 were until 1500 hours.

4 When we got in front of the SUP building, and when we drove the

5 car into the courtyard and parked it there, we approached the SUP building

6 -- that's what I refer to this building as although it was the public

7 security station -- I noticed in the whole area, as far as I could see

8 around the building of the public security station, the municipal building

9 in front of the park, as far as I could see up to the park and around it,

10 I saw very many groups of younger people with -- wearing jackets with

11 their hands in their pockets. And each group consisted of between three

12 and five people, and there were some ten -- they were some 10 or 20 metres

13 from each other. And the distances between them were not the same. I

14 entered the SJB building, and the communications centre where I worked is

15 on the top of the building. There is the ground floor, the first floor,

16 and the second floor. I am on the second floor, at the end of the

17 corridor, together with the rest of my department, the rest of my section.

18 When I entered the building, there were exceptionally few people moving

19 around the corridors. Usually there are citizens, there are employees of

20 the public security station. There was nobody there.

21 I approached the door of my department, which is always locked,

22 and the only ones who are allowed to enter are the employees of that

23 particular department. On the right-hand side, some metre, 1 metre from

24 my door, there's the door of the office where Mr. Muharem Seric worked.

25 As far as I can remember, at the time he was the official in charge of the

1 reserve police, which was then called milicija. And I could see his door

2 opening, and three or four people coming out of the office, middle-aged

3 people, very quiet, leaving the office in a single file. One of them was

4 a bit older, maybe my age, and he told the others: "Okay, single file,

5 just slowly." To my mind, that was a very unusual scene, almost

6 unrealistic. Something was obviously not right there. I entered my

7 office and then I approached the window, and I could see through the

8 window that there were a lot of people there. I couldn't see any noise,

9 but I could see them talking. And those that I had just seen coming out

10 of that office, the four or five people that I had just seen, I now saw

11 them leaving our building, and each of them approaching a different group,

12 telling them something, and then moving on. I found that very suspicious.

13 And then in the same corridor on the same floor, on the other side

14 of the corridor, there was my wife's office. She worked in the crime

15 police at the time. And the official title of that department was the

16 Crime Prevention Department, as I've already said. So I went there, and I

17 asked her what this was all about. She didn't know. That's the kind of

18 person that she is; she doesn't have a clue, she just does her job. She

19 doesn't notice anything, and she didn't notice anything on that day. Then

20 I asked her to leave her office then and walk with me. I was concerned.

21 Why was I concerned? Because there were tensions, and the tensions

22 increased. I hoped that they would diminish, but they kept on increasing.

23 That's why I asked her to leave her office and to walk with me in front of

24 the SUP building. And that's what we did. We passed by -- in front of

25 the municipal building. We walked around the park. We made a circle

1 around that area and a circle in the diameter of some hundred metres. And

2 in rough outlines -- I didn't count them precisely, but I could tell that

3 there were some 50 or 60 groups of people in that large area in that huge

4 park in front of the museum, in front of the mine, in front of the

5 municipality building.

6 Q. Can you please make your explanation a bit shorter, and can we

7 come to that meeting when Zupljanin arrived in the public security

8 station.

9 A. Fair enough. So according to my estimate, there were perhaps

10 about 300 people in that huge area, assembling in groups. When I

11 returned, I went to see the secretary. She was the secretary of the -- of

12 our chief, Hasan Talundzic. To the right of her, there was Ranko Mijic's

13 office. He was chief of crime prevention. So I had a conversation with

14 him. I asked him if he knew what was going on, and he didn't know either.

15 And then the two of us were addressed by Mira, the chief's secretary. And

16 she told us: "Don't go anywhere far. The chief said there would be a

17 meeting in his office. We should call all the others to come to the

18 meeting." That was in perhaps 20 minutes, she said; not too

19 long, but not right away. So we came to the meeting. Actually, that's

20 what I wrote down here. Stojan Zupljanin and together with him, his

21 assistant for public security, Bajazit -- this is slightly illegible, but

22 I think the man's last name was Jahic or Jehic. I think Jahic. He only

23 held that position very briefly so I may not have memorised his name

24 exactly. His first name was Bajazit, and his second name, I think, was

25 Jahic.

1 So there was supposed to be a meeting with them. We came in.

2 Later I only heard in my conversations with other people that he could not

3 have this meeting he was supposed to have at the municipality because

4 Mirza Mujadzic, the president of the SDA, would not see him. And they

5 were objecting about weapons. The driver did wear a uniform, and he did

6 carry a weapon. Stojan Zupljanin and his assistant for public security

7 were not armed -- were not wearing uniform. Whether they had weapons, I

8 don't know.

9 Q. May I just interrupt you. Stojan Zupljanin's assistant, do you

10 know what his name was and what his nationality was?

11 A. First name Bajazit. That much I'm sure of. I scribbled this

12 down, so I'm not sure what the last name is. I think it's Jahic.

13 Q. And what is his nationality?

14 A. As the name itself says, he is a Muslim. And after the elections,

15 there were Serbs and Muslims and Croats. This is a position within the

16 internal organisation of the centre. You have the head, and then two

17 assistants, one for public security and another for state security. So he

18 has two assistants, two deputies. So Jahic was the assistant in charge of

19 public security, so he was our superior before Zupljanin, who was like our

20 top superior.

21 Q. Can you please tell us, who else attended this meeting?

22 A. I wrote it down here so it's clear for all to see. I was using

23 abbreviations but I know who I was referring to. Here it says Stole --

24 those were nicknames that they used. "Stole" Stojan Zupljanin; "Hasan"

25 Hasan Talundzic; "Dule" Dusan Jankovic, commander of our station; "Kecan"

1 Radovan Kecan, assistant commander; "Ziko" Ziko was another assistant,

2 another assistant commander. His name was Zijad Basic. "Fikret," Fikret

3 was Fikret Kadiric, the commander of traffic police. "Djuro," I can't

4 remember what he was at this time but he was a member of the police, too,

5 Djuro Prpos. "Mijic," Ranko Mijic, chief of the crime squad. Myself,

6 chief of communications and cryptographic protection. And then chief of

7 public security, Bajazit Jahic. This is what I wrote down back then as I

8 was in the meeting, when the meeting began.

9 Q. What was discussed at that meeting, if you could just provide a

10 brief explanation, and why was that noteworthy?

11 A. Otherwise, throughout that period, there were tendencies and one

12 -- different tendencies, and one of the groups was striving, one of the

13 many groups, because in terms of organisation, the public security station

14 was part of the public security centre in Banja Luka. And then the public

15 security centre was part of the MUP in Sarajevo. Some people strove to

16 keep things this way, and other people wanted us to become an independent

17 centre with equal rights as the Banja Luka centre. So they wanted us to

18 split off from the Banja Luka centre. Those were supposed to be the

19 municipalities that we had while we were the centre. Sometimes we were

20 the centre, sometimes we weren't. I mean Prijedor. And now again, we

21 weren't. So those four municipalities were supposed to split off; Sanski

22 Most, Bosanski Novi, Bosanska Dubica, and Prijedor. The seat was supposed

23 to be the headquarters in Prijedor, and we were supposed to be directly

24 subordinated to the MUP in Sarajevo, just like Banja Luka.

25 So that was the idea. And both strove emphatically to achieve

1 their aims, both groups, so we tried to reach a compromise, an agreement,

2 to keep everyone happy. Now here, what I wrote, it's a bit difficult to

3 read. It is my own handwriting. But it's slightly illegible. It says:

4 "Stole said, for the JRM, Hasan tells me everything is as best as could

5 be." JRM is short for units of the reserve police, units of the reserve

6 police across the villages because every village had its own unit.

7 And Stojan said that this was supposed to be our plan for

8 preparations and how to secure the service. Hasan said our situation is

9 smooth. Hasan is here speaking about the reserve forces. He wants

10 weapons. Stole says this is militarisation. That's what I jotted down.

11 These were just my own personal notes, not very accurate. But I know, and

12 I remember on the basis of this, exactly what they spoke about. Hasan was

13 saying, "We are well organised, sufficiently organised. Our personnel is

14 very good, but we don't have enough weapons."

15 I had attended several of those meetings before because I was part

16 of this committee, so chiefs would meet, and I did hear them on several

17 occasions talk about it. As far as I can remember, the reserve forces in

18 Prijedor Municipality, we had 700 reserve police. And for the reserve

19 forces, there were about 450 rifles, that means an insufficient amount of

20 rifles. So Hasan was saying we need more weapons. And Stojan Zupljanin

21 was saying, this is no good. If we focus all our activities on arming

22 those people, then what we have on our hands is militarisation, he says.

23 Then we practically take over the authority of the army, the functions of

24 the army, and that's not our purpose. We're supposed to keep law and

25 order in our own territory, and that's what we should focus on as opposed

1 to providing weapons. The rifles that we have, I think, are enough for

2 the work that needs to be done. That means Hasan wanted more weapons or

3 turn the whole thing into an army. At least, that's what I heard at the

4 meeting. So he wanted to focus on the military work and not on the police

5 work.

6 And now here it reads: "The transformation of the MUP, setting up

7 of a CSB. Hasan and sometimes Fikret would join in the discussion, the

8 commander, they were talking about the MUP being transformed. And what

9 they meant was we, the Prijedor municipality with the three other

10 municipalities I referred to, were not to be public security stations

11 under Banja Luka, but that we ourselves should be an independent centre

12 and directly to answer to the MUP in Sarajevo. So we would receive orders

13 from the MUP in Sarajevo directly and this way they were channelled

14 through Banja Luka. So here it says the transformation of the MUP, and he

15 says I'm not in favour of carving the service up. That's what Stojan

16 Zupljanin was saying, roughly.

17 The point of his contribution was there's no need to carve the

18 whole service up. This is not really essential to us. We, as the police,

19 if we belong to the centre, we shall just look after our own work as the

20 police. And then Hasan and Fikret don't want the badges. And then Fikret

21 and Hasan replied to what he said, that they couldn't deal with Banja

22 Luka, because in Banja Luka, certain policemen had started already - maybe

23 all of them, I wasn't there at this time, but I know that something

24 started happening. They began to -- because, you know, they were still

25 wearing the five-star -- the five-point star insignia from socialism,

1 which had gone out of use by that time. So by inertia, they were still

2 using the same insignia as in the former Yugoslavia. And then in Banja

3 Luka, they started using different insignia. They started wearing the

4 badge that was in the form of a Serbian flag; red, blue, and white, a

5 small beret with a badge on it. Hasan and Fikret, the commander, were

6 saying that they couldn't agree to that, to wear Serb flags on their caps.

7 And now here, I said that we should be unified and reach an

8 agreement. I kept silent up to that point, but then I came forward and I

9 said that first and foremost we needed to be united, to reach an agreement

10 and to respect this agreement. We needed to be unified as the police.

11 That's the way it used to be and that's the way it should stay. In the

12 socialist system, we didn't look at people's ethnic backgrounds. We

13 needed to say unified to alleviate the tensions and to try in every way to

14 avert the danger of war and anything that was dangerous. So that's what I

15 said. Let's reach an agreement and stick to that agreement. That was my

16 contribution.

17 Q. Mr. Jankovic, did Mr. Talundzic order the secretary not to let

18 anyone into the meeting, and did she still let someone else into the

19 meeting? Did she not?

20 A. Yes. When we entered the room in which the meeting was taking

21 place, that was Talundzic's office, when we entered, the secretary stayed

22 outside. Mira Topic, his secretary. He told her: "Mira, please, should

23 anyone come calling, tell them I'm not here. Please don't interrupt us

24 for anyone." And really, the discussion that I've recounted for you now,

25 this may have lasted -- well, roughly speaking, it has been a long time --

1 one hour perhaps or a bit more. And then Mira came in at one point, and

2 she said -- she spoke to Hasan, and she said: "Boss, Osme is looking for

3 you." Osme was the only person with that name. She was speaking about

4 Osme Didovic who was the commander of the Kozarac police department.

5 Hasan stood up, left the room. He spoke to Osme. I didn't even see Osme,

6 so they were speaking outside the office. He was back in a couple of

7 minutes, but without Osme. He addressed us, and I could tell by just

8 looking at his face that he was worried. He told us, "Well, look folks,

9 things are getting really serious. There could be a war any moment now."

10 And we asked, Well, what's the matter? And he said, Osme had come to tell

11 him that. In Kozarac, their people now, whether they were mobilised or --

12 I'm talking about the police, but the police were not that many, maybe

13 between 10 and 15 members of the police, I forgot exactly how many, but

14 not too many, so their numerical strength was not great anyway. They were

15 trying to raise a major number of people, and there was danger that they

16 had head for Prijedor at any moment now. And there was word that they

17 wanted to have their own government in Kozarac at that time. That sort of

18 thing.

19 And I said -- and then Hasan said, well, we must do something

20 urgently to keep this from happening, to keep unrest from breaking out.

21 And they decided very quickly to call, and within 10 to 15 minutes, they

22 were there, two journalists. One was from the local paper, Kozarski

23 Vjesnik, and the other journalist was from the local radio station, Radio

24 Prijedor. I used to know one of them because we were neighbours. The

25 journalist's name was Nezirevic. He was a Muslim. I can't remember his

1 first name now. And the other journalist, I didn't know him at all, but I

2 remember that he was a Serb because when we spoke to them, they were

3 telling him he had a big head and curly hair. That's all I remember. But

4 it was deliberately done that they invited two different journalists with

5 two different ethnic backgrounds. And they told them about the situation,

6 and they told them that they had to come up with some sort of announcement

7 urgently in order to allay the tensions. The journalists got the idea

8 very quickly, so they went back to their work. The meeting ended. I

9 didn't listen to the radio and I didn't read the papers, but I did hear

10 from my wife and from a number of neighbours that that was from 6.00 in

11 the afternoon, the Radio Prijedor kept broadcasting this announcement for

12 the people to stay calm, that the police had everything under control,

13 that there would be no riot by any of the sides involved, any of the

14 ethnic groups. They said everything was under control and they played

15 soothing music to back their statements up. That's what I was told, that

16 it was obvious that this was the case.

17 So much for that particular meeting. I'm not sure if I've omitted

18 anything of essence.

19 Q. Let me just ask you. We forgot about the year. You said it was

20 on 9th of April. Could you just tell us the year, please.

21 A. It was on the 9th of April, 1992. Here it reads, "9th of April,

22 1992."

23 MR. LUKIC: [In English] Your Honour, is it necessary to have this

24 in the evidence?

25 JUDGE SCHOMBURG: It is tendered by you. I can't see any

1 objections.

2 MR. KOUMJIAN: Your Honour, I think it would be helpful to

3 everyone if the witness would read it word for word for the record. Some

4 of it he has read or interpreted. We don't really know what's written

5 here, and even if we submit it for translation, they may have trouble with

6 the handwriting.

7 JUDGE SCHOMBURG: Yes, I think it's a good idea.

8 Could you please be so kind that we have access to that what you

9 in fact had written at that time, the 9th of April, 1992, just to read

10 consecutively what we can see on this piece of paper that shall be, then,

11 D47B. And then we don't need any translation into English. It follows

12 from today's pages 22 through 30 what is the content of the document.

13 Could you please read it. Thank you.

14 THE WITNESS: [Interpretation] Gladly. The date, the 9th of April.

15 That's clear. "Chief of centre and the rest." That's --

16 MR. LUKIC: [Interpretation]

17 Q. Please don't elucidate, just read what it says on the paper.

18 A. Chief of centre and the rest. GL agreement. That means the main

19 agreement. That's what I think it says. This is my personal shorthand.

20 Present: Stole, Hasan, Dule, Kecan, Ziko, Fikret, Djuro -- you can't see

21 it here but it should be here -- Mijic, myself, and chief of public

22 security Bajazit Jahic. Please, I'm sure it's Jahic, so write "Jahic."

23 Number 1, Stole said -- this is a Z, for JRM. This is unit of the

24 reserve police. Comma, and Hasa, Hasan says that our situation is the

25 best. Hasan speaks about reserve -- this refers to the reserve force, the

1 reserve police force. That's what this means. Comma, he wants weapons.

2 Stole -- that is Zupljanin -- Stole says this is militarisation.

3 Number 2, this is item 2 on the agenda. Transformation of the MUP

4 - setting up of the CSB. This is Item 2. Stole speaks about

5 transformation of the MUP - I am not in favour of carving up the service.

6 That's him speaking, not me. And here, dash, Hasan and Fikret don't want

7 badges. This is nothing. This was just me scribbling and jotting down my

8 own name and some lines. This arrow here, that means I was speaking

9 myself. I spoke about specific agreement to stay unified. I meant all

10 the workers, all the employees of the police, regardless of our ethnic

11 backgrounds. That's that.

12 This is my personal -- these are my personal notes, and this is

13 the first time they are being used.

14 JUDGE SCHOMBURG: Thank you. Once again, admitted into evidence,

15 D47B.

16 MR. LUKIC: Would it be a convenient time, Your Honour, for the

17 break?

18 JUDGE SCHOMBURG: The trial stays adjourned until 10 minutes to

19 11.00.

20 --- Recess taken at 10.30 a.m.

21 --- On resuming at 10.56 a.m.

22 JUDGE SCHOMBURG: Please be seated.

23 Mr. Lukic, if you want to continue, please.

24 MR. LUKIC: Thank you, Your Honour.

25 I would like the usher to give the witness the document marked as

1 D6, to give the witness the B/C/S version. Would you be so kind and turn

2 the B/C/S version.

3 JUDGE SCHOMBURG: It's on purpose that we all should have the

4 B/C/S version? I think we are improving, but not that good.

5 MR. LUKIC: Or if the usher could put the English version on the

6 ELMO, and present the witness with the B/C/S version, please.

7 JUDGE SCHOMBURG: Thank you.

8 MR. LUKIC: [Interpretation]

9 Q. Mr. Jankovic, you've told us that in 1992, including the April of

10 1992, you worked in the Prijedor public security station.

11 A. Yes.

12 Q. When and on what date towards the end of April was a meeting

13 organised in the building of the public security station in Prijedor?

14 A. Yes, it was organised. A meeting was organised. There was no

15 written notification. There was no advance notice. As far as I knew, it

16 was only a few hours before the meeting. I was not in the office on that

17 day. I was somewhere making rounds, and when I came back, one of my

18 employees told me about the meeting which was supposed to take place at

19 1400 hours, and that all the authorised personnel should be present at the

20 meeting. I took that seriously. I informed all the other employees who

21 reported to me in my department. I didn't even -- I didn't have the time

22 to inform everybody, but most of them were there, and I was at that

23 meeting myself.

24 Q. Was the agenda known in advance?

25 A. No. When I arrived at the meeting, I didn't know what the meeting

1 was all about.

2 Q. Can you please tell us what you saw; who was chairing the meeting?

3 A. The meeting was held in our conference room. When I say "our

4 conference room," I mean the conference room of the public security

5 station, where meetings are normally held. That is, the town hall

6 meetings attended by all the employees. And the conference hall was full.

7 All the chairs were occupied. Some of the people were even standing.

8 Some people were even standing at the door, and they spilled over into the

9 corridor. But they could listen what was going on in the conference room.

10 There was the desk for the chairpersons. Maybe that is not the correct

11 word to use, but those were the people who presided over the meeting. I

12 wasn't sitting down. I was standing up, leaning on a column in the

13 conference hall, so I was leaning against that column, and I was some 3 or

14 4 metres away from them. And these people were present from the left to

15 the right, those people I had known already. I knew them already.

16 So from the left, there was the president of the municipality,

17 Cehajic. Muhamed or Muharem, I'm not sure about his first name. But I

18 know him. He's an elderly man. His name is Cehajic, and he was the

19 president of the municipality. And next to him was Mirza Mujadzic, the

20 president of the SDA. In the middle -- there were five of them. In the

21 middle, Hasan Talundzic, our chief of the station. Next to him, on his

22 left, Fikret Kadiric, who was then the commander of the traffic police

23 department, and then he was the chief of the police. And finally, Simo

24 Miskovic. If I'm not mistaken, he was at the time the president of the

25 SDS. So there were party members. A little bit further was the person

1 who was taking the minutes, Radovan Kecan, the assistant commander of the

2 public security station.

3 Q. Did anybody speak at the meeting?

4 A. Yes. The meeting was opened by Mr. Hasan Talundzic. And then

5 there were other speakers. He spoke most of the time. But there were

6 other individuals at the chair who took the floor. And in the latter part

7 of the meeting, there was a debate, so those people who attended a meeting

8 voiced their opinions, asked questions, and the people and the chairperson

9 answered those questions.

10 Q. What was the debate about?

11 A. When the meeting was opened, it was said, but I can't quote the

12 exact words, but it was clear, it transpired from those words that what

13 was asked of the employees was the support of the police. And just like I

14 said a little while ago, that we, as the public security station, would

15 separate from the public security centre in Banja Luka and that we should

16 join direct with Sarajevo. When I say "Sarajevo," I can't give you the

17 details whether that was the Sarajevo MUP or maybe that we should be the

18 centre, as we had been before, so that we could report directly to

19 Sarajevo. And this was explained by the following: It was said that we

20 would benefit from being directly subordinated to Sarajevo. Salaries did

21 not arrive on time. We had already not received two salaries, and they

22 told us that the salaries would arrive within one or two -- the first one

23 would arrive within one or two days, and the second one would arrive a

24 little after that. So people asked the floor. Some were in favour. Some

25 were against. I can't really remember any of the names of those who asked

1 the floor and who participated in the debate. So I can't tell you with

2 any degree of certainty who said that. But by and large, some were

3 against, some were for.

4 And then the chairpersons provided additional explanations, tried

5 to persuade people to accept the proposal and for the Prijedor public

6 security station to be separated from Banja Luka. And as the meeting

7 evolved, they became more and more successful in persuading the employees

8 to agree for the public security station to become the centre. In that,

9 the salaries were the strongest argument. That was what won the majority

10 of people over.

11 Q. Did somebody call your names during the debate?

12 A. In hindsight, I believe that that debate lasted for an hour.

13 There were a lot of people. There were a lot of participants. And all

14 the employees were there, at least those who were at the time in the

15 building of the public security station in Prijedor. Only those on-duty

16 officers were in their workplaces. The on-duty officer at the door and

17 the on-duty communications officer, whoever was at the door, called me by

18 the name and told me that my employee, the duty officer in my service,

19 wanted to see me. He could not have called me on the phone because there

20 was no telephone in the conference room. When my name was called, I knew

21 that there must have been a technical problem. I left the meeting. I

22 went upstairs. The duty officer at the time was Dusko Sarac. The duty

23 communications officer told me that he had problems, he had received a

24 dispatch. And judging by the urgency sign, he had to forward it very

25 urgently, and he was supposed to forward it to Hasan Talundzic, our chief,

1 but also to three public security stations which were in Sanski Most,

2 Bosanski Novi, and Bosanska Dubica.

3 Some technical problems arose, and for those -- for that reason,

4 he could not forward this dispatch as urgently as was required, and that's

5 why he wanted my advice.

6 Q. Excuse me. Let me interrupt you just for a moment. The question

7 is why did your duty officer have to send this dispatch to the three

8 municipalities that you have mentioned?

9 A. Because a communications duty officer has to scrutinize the title

10 of the dispatch. This has "CSB to all." That means that he is supposed

11 to send this dispatch to all the public security stations in Bosnia and

12 Herzegovina and their respective chiefs. And then "SJB to all" public

13 security stations to all in Bosnia and Herzegovina. Since we in the

14 technical organisation of communications, are organised in such a way that

15 a dispatch that arrives in Prijedor - the one, for example, in Sarajevo -

16 is sent to the centres, centres then in turn send them to public security

17 stations. So according to the "SJB to all," that meant that he was

18 supposed to forward this dispatch to the three public security stations

19 that I've just mentioned; Novi Grad or Bosanski Novi, Bosanska Dubica, and

20 Sanski Most. And this is where the technical problem arose.

21 Q. Can you please continue with your explanation, where you left it

22 off.

23 A. When I saw what the technical problem was all about, I knew what

24 it was, and that problem could have been handled in several ways and the

25 transmission could be done in different ways. In addition to very urgent,

1 there is also the word -- the letter S, the dispatch was coded. That

2 means that this dispatch had to be encrypted before sending. And since he

3 couldn't send it according to the same system, he had to use a different

4 system. There are different systems with different degrees of reliability

5 and the different time that needs to be invested in order to carry out the

6 task. And this duty officer was afraid that he would make a mistake, and

7 that's why we called me, as his superior officer.

8 And in order for me to understand the degree of urgency of that

9 dispatch, I had to skim through it. Me and all my other employees have

10 the right to read a dispatch if need may be to do so, but we are not

11 allowed to communicate the contents of that -- of any of such dispatches.

12 So I looked at the dispatch in order to decide what the encoding system I

13 should use. However, when I skimmed through the dispatch and when I saw

14 its contents, and when I saw all the bullet points, they all came as a

15 shock, and especially the last one, the beginning of combat activities and

16 where the army is mentioned. And that meant something terrible for me.

17 That was, for me, the beginning of war. Us against people from the same

18 body of people, sometimes against brother, other people in the police, in

19 the army, our comrades, our colleagues. We are too small to be considered

20 a real army. The police force is a small force. This was something

21 terrible for me. It was shocking. At the same time, I knew the rules,

22 the rule for us to carry out our tasks. "Very urgent" means that

23 something has to be forwarded really very urgently.

24 There are other codes for the dispatches. The slowest dispatch is

25 8 hours, and the most urgent dispatch is something that is marked as "SJB

1 to all," in other words, to Hasan Talundzic in this specific case. So

2 this was -- this required a great degree of urgency. I had to go back to

3 the meeting, and my communications duty officer could not leave his

4 workplace. And I told him exactly which system to use to forward this

5 dispatch. And because of the urgency of the dispatch, I took the

6 so-called book of dispatches, and that is the record of all the telegrams

7 that have been received and that have been forwarded with all the details;

8 who it was received from, who it was forwarded to, and finally the

9 signature of the person who received the dispatch. I didn't have the time

10 to enter this dispatch, and I was not in the position to do that. There

11 was the duty officer who was supposed to do that. However, I took that

12 book and that dispatch, and together with that book, I took it down to the

13 meeting. There are my employees sitting in the front row, and I called

14 one of them. I told Mirsad Sahuric, he was the closest to me, I told him

15 can you enter this dispatch in the book, and can you hand it over to the

16 chief. These are very short operations. It can be done by a skillful

17 worker in two minutes.

18 Q. Excuse me, can I just interrupt you for a minute here. What is

19 the ethnic background of the employee to whom you gave the dispatch to

20 give it to the chief?

21 A. Mirsad Sahuric, and it is clear from the name that he is a

22 Muslim. At that moment, it was not important for me whether he was a

23 Muslim or a Serb. He was the closest to me, and that's why I gave the

24 dispatch to him. I could have given it to anybody else, but he was the

25 closest to me sitting, and he was a Muslim in any case.

1 Q. Can you please continue.

2 A. This is what Sahuric did. It took him a minute or two minutes or

3 three minutes: He gave the dispatch to the chief, and he signed the

4 receipt, but the meeting I could sense was drawing to an end, and I could

5 tell that a conclusion had been reached and people were very happy that

6 they would receive their salaries. That was the bottom line. But I was

7 under the influence of that dispatch, and I was one of the authorised,

8 among other, authorised officials. There were no lay citizens. This was

9 one of our internal meetings, and we could discuss any of our internal

10 business matters there. So I thought it was -- I had the right to ask the

11 floor. I had not asked the floor before, I was just listening. And what

12 I told was the following. I can't really quote my words, but I can

13 remember the meaning of my words, exactly what I meant. I said what

14 people were talking about, that is the chairperson, the way they promised

15 salaries and what they -- all the good things that they promised is in

16 contradiction with other things, and that is the same Sarajevo for which

17 they said would send us salaries is now giving us tasks that, to my mind,

18 look like a war, a real war, war with the army, us amongst ourselves.

19 When I say "us amongst ourselves," I meant people in Prijedor

20 Municipality. I never went any further because Prijedor is what I know.

21 That's my home turf. And what I read from that dispatch was that we were

22 supposed to either fight amongst ourselves or with the army in Prijedor.

23 And I found that to be atrocious, to be terrible. And that's exactly what

24 I said. This is horrible. This is something we cannot accept. And most

25 probably what these people are saying, what they are promising to us has

1 no grounds because the situation is totally different.

2 And then they started asking me, "Where did you get this idea

3 from?" "How can you say a thing like that?" And then I said, well, this

4 is what the chief has just received, this dispatch, shows it clearly. The

5 police -- so the policemen were there, and there were some people from the

6 criminal police. They started shouting, "Read us the dispatch. Read

7 where it says that." And then the chairpersons took the dispatch. They

8 read it, and they debated amongst themselves silently, and only -- even

9 though they were only 3 or 4 metres away from me, I couldn't hear what

10 they were saying. A couple minutes later, they decided that the dispatch

11 should be read, and they gave the dispatch back to Mr. Kecan, who was

12 taking the minutes, for him to read the dispatch. He stood up. And he

13 started reading the dispatch. As he went on reading, the noise increased

14 in the conference room. There were no physical incidents, but there was a

15 commotion in the conference room. And then at the end, when the dispatch

16 had been read, people started leaving the room.

17 Then the president of the municipality rose to his feet, that is

18 Mr. Cehajic, and he said, "This is just a fabrication, this can't be true,

19 and I'm leaving this meeting," and he went. But Mirza Mujadzic acted

20 totally differently. He said, Hold on, people, we will agree. This is

21 not -- you haven't understood this. This is not what you think it is.

22 It's something totally different, so his reaction was totally different.

23 He tried to keep the people in the room and continue the debate, but he

24 failed. People scattered. People left the room.

25 And after some time, I arrived home. And later on, I didn't hear

1 anything about this dispatch or anything in connection with this dispatch.

2 I only know that on that same evening, I was asked to, by somebody, I

3 don't know who, to come back because my police needed assistance. So

4 whenever they needed me, they would tell my duty officer to find me, and

5 I, as head of the department, I had to be on call for 24 hours, around the

6 clock. Wherever I went, I had to inform my duty officer where I was

7 because if there was a need for to find me, they could find me. So that

8 happened on that same evening. They invited me and I went there. On the

9 following morning -- during that night, people gathered, and on the

10 following morning, there was a takeover without a single bullet fired as

11 far as I could hear.

12 Some two days later, maybe, Prijedor had already been taken over.

13 Simo Drljaca replaced Hasan Talundzic. He was now the chief. And he

14 asked me to come to his office, and I went there. And he told me -- there

15 were two or three other people present there. I didn't know them. I

16 didn't know any of them. And he told me, "These are journalists from the

17 local newspaper Kozarski Vjesnik" and he asked me -- I don't know what

18 they were talking about before that, but he asked me whether I had a copy

19 of that dispatch. And I told him that no, I didn't have it, because I

20 only make one copy and I forward it to the addressee. But since there is

21 a tape on which the dispatch is received, that's a part of the encoding

22 system, and that is usually put into a sack, and that sack, when that sack

23 is full, some -- within seven or ten days, then this sack is burned by my

24 employees. So I told him, this happened some two or three days ago. The

25 sack must still be there. It hasn't been burned. The contents of the

1 sack have not been burned and that tape is probably still there. So he

2 told me, okay, see if it's there. If the tape is there, make a copy and

3 bring it to me. I gave this task to my employees, they found the tape of

4 the dispatch, and that dispatch I brought to Simo and handed it over to

5 him.

6 Let me just make a remark. This machine has the following

7 technical characteristic: If it receives a dispatch from a participant in

8 the communication, then the letters are vertical. When somebody sends a

9 dispatch to a different participant, then the letters are leaning towards

10 the right. And when I or somebody else takes the tape and makes a new

11 copy in the room, that copy will have letters leaning to the left. The

12 copy that I have here in front of me has letters leaning to the left, so

13 this must be a copy -- I don't know how you came by it, but I believe that

14 this is a copy that -- the copy that I made and handed over to Simo

15 Drljaca.

16 But the paper that I see on the ELMO here, I can see that these

17 letters are vertical, so these are not two identical copies. But I don't

18 know. This is just my technical observation. This may not even be

19 important, but this is just my observation, something that I've observed.

20 And that's how this dispatch, from what I could see later on...

21 MR. KOUMJIAN: Your Honour, perhaps so the transcript is clear,

22 the record should reflect that the document on the ELMO that the witness

23 referred to is an English translation.

24 JUDGE SCHOMBURG: So to be quite clear, on the ELMO we can see a

25 document only in part reflecting the order, paragraphs 1 through 3,

1 whereas the document in B/C/S, maybe it's the English page number 2, has

2 an additional paragraph number 4.

3 But to be honest, I did not really understand. How is it possible

4 that you told us that in the beginning, when you send a message, the

5 letters are leaning to the right-hand side, and then making a copy, they

6 are leaning to the left-hand side, or is it in-built into the machine as

7 such?

8 THE WITNESS: [Interpretation] Yes, this is the machine TX 200,

9 produced by the Electroindustrija Nis. So that is TX 200 made by Nis. It

10 is a copy of an original French machine. This text here, this text here,

11 I apologise, maybe my eyesight is deceiving me, but as far as I can tell,

12 the letters are leaning to the left. This looks like a paper from the

13 original sender, and I don't know where you got it from.

14 And the one in front of me here, and the letters are on the left.

15 JUDGE SCHOMBURG: If Defence counsel could be kind enough to

16 assist us in a better understanding of this.

17 MR. LUKIC: [In English] We have in our list different listings,

18 because in the list it says that D6 is a paper from public security

19 station. And on the ELMO, we have a different paper. It's a paper from

20 Territorial Defence in Sarajevo.

21 MR. OSTOJIC: If I just may add, I think the Court registrar gave

22 the Court a different document than the document that the witness has. So

23 we would like at least a couple minutes to clarify that so that our

24 exhibit list is consistent with what the witness was testifying to and the

25 dispatch that he received. So if we can see what the witness is looking

1 at, it might assist us in clarifying this issue, both on the ELMO and that

2 which is in front of him.

3 JUDGE SCHOMBURG: So I think we have to attach new numbers, D6-1,

4 D6-2, and so on. But let us proceed step by step.

5 We can see now a document on the ELMO. And my first question

6 would be, do you believe this is now a document leaning to the left or to

7 leaning to the right?

8 THE WITNESS: [Interpretation] Who are you asking, Your Honour?

9 JUDGE SCHOMBURG: The document we have on the ELMO, on the machine

10 on your side. Yes, this one.

11 THE WITNESS: [Interpretation] This one. I think these letters are

12 leaning to the right.

13 JUDGE SCHOMBURG: So this would mean that it's sent or received by

14 you?

15 THE WITNESS: [Interpretation] This dispatch, this copy here, this

16 was certainly not sent anywhere. I think this is the original which may

17 have come in. The chief, Hasan, after the meeting, when he went back to

18 his office, he probably left it where he leaves his other documents, and

19 then at some later stage, the document came. And I'm not sure where this

20 document went through. It's outside my purview. I think this is an

21 original, this is not a copy. And the other one, I think, is a copy from

22 the tape we use. Not a photocopy but a tape we use in cryptographic

23 protection.

24 JUDGE SCHOMBURG: May I ask you, Mr. Usher, to come back to the

25 previous document.

1 So when we look at the top of this document, is it usual or

2 unusual that in a document in B/C/S, you can find at the top of the page

3 the English line "Very Urgent"?

4 THE WITNESS: [Interpretation] Yes. We have this as a rule. All

5 communications officers take an exam. And I've said this, and I'll

6 specify: Every dispatch, here in this area -- a little bit to the right

7 would be better but in the middle is also okay. It has two marks, grade

8 of urgency and grade of secrecy. Urgency is up to who's sending to decide

9 and the communications officer only checks it. So marks of urgency can be

10 OB, DD, DX, and Very Urgent. These are very common things. And when a

11 communications officer receives a dispatch like this, he must, within

12 eight hours, that's within four hours, forward it to whoever it's

13 addressed to. "DX," according to content, "DX" are urgent operational

14 matters. Criminals, matters related to criminals, questioning, that sort

15 of thing. "Very Urgent" is the most urgent dispatch there is. Sometimes

16 they use the expression "Very Urgent," we use the expression "Very

17 Urgent." So this is state-related information and must be forwarded as

18 quickly as possible, even outside working hours. The police officer must

19 go as a courier, look for the chief, and forward this to the chief. And

20 this is a standard thing we use, Very Urgent. Every communications

21 officer will tell you it's very common. The other mark will say O or S.

22 That means open or coded. Now whose communication officer drafted this

23 and why they left it out, they must have been mistaken to leave out the

24 other marks.

25 JUDGE SCHOMBURG: Once again to repeat, I understand from your

1 testimony that it was usual that a document in B/C/S was headed by an

2 English text indicating the degree of urgency, so it would be usual that

3 you can read two English words in front of text in B/C/S. Correct? That

4 was my question.

5 THE WITNESS: [Interpretation] Yes, that's perfectly correct. Many

6 communications officers who don't know the language don't know the meaning

7 of this phrase, literally. But they know full well that these words mean

8 this must be forwarded as urgently as possible to the chief, and if the

9 chief is not actually physically present in the station, then there's a

10 courier who runs it and brings it to the chief.

11 MR. LUKIC: [Interpretation]

12 Q. Mr. Jankovic, let us please continue with the analysis of this

13 document. So please use the pointer on the ELMO. The first line, where

14 it says "MUP, RBH," what does that mean, the very top of the page?

15 A. We in the police have a rule, and all those who have taken their

16 exams know this rule. I'm referring to the communication officers. How

17 do you write a dispatch? How did you put a telegram together? It must

18 have a heading in the upper left corner containing the sender. And this

19 is different from the headings of official documents typed and sent by

20 official mail and not through communications. So there's a difference

21 there. And I'm speaking about this, now. There is this heading in the

22 left upper corner "sender," and who the document is addressed to. This is

23 something that the communication officer looks at, and these are his

24 guidelines. He's not supposed to read the text, and if he does by

25 accident, he is not supposed to use the information contained therein. So

1 the first thing you get is "sender." And then who is he sending the

2 document -- and you can read the MUP of the Republic of Bosnia and

3 Herzegovina. Number 10-70. This number here is sometimes larger, or

4 longer. This is the code for the sender. So when a minister sends this,

5 then there's only number 10. So if it was the chief of police or the

6 chief of crime squad, 10-1, 10-2. If it's only the minister, then just

7 10. 70 is the ordinal number in one of the minister's books, records.

8 Then something has been omitted here. I don't know why. Sometimes

9 -- always you had a dash here, and then 92, for example, because we are

10 talking about the year 1992. But this was probably a mistake. And then

11 you have a date underneath, the 29th of April. You can see that here.

12 The 29th of April, 1992. So it's clear who the sender is. The

13 communications officers and all the other professionals dealing with this

14 know it, who the document is coming from, who the sender is, from the

15 whole of the MUP. So the police station has its own number, 3, Banja Luka

16 centre. You knew exactly which number each of the stations had, so you

17 could tell who the sender was. This small number here, that means sender

18 was the minister.

19 Now who this is being sent to. CSB, to all and to the chief. So

20 the MUP is sending this to the Security Services Centre and to all. Those

21 were all the security centres across Bosnia; Prijedor, Banja Luka, Doboj.

22 There were ten all together. SUP Sarajevo, special dispatch to the SUP of

23 Sarajevo, and then the SJB, public security stations, all of them,

24 depending on where they were exactly. But when the MUP, the Ministry of

25 the Interior of the -- Ministry of Internal Affairs sent something, they

1 only sent the documents to the centres, and then the centres forwarded it

2 on to their stations. So my communications officer reads this CSB, and he

3 knows then that he is supposed to forward this to everyone. And I'm

4 talking about three different public security stations; Dubica, Novi, and

5 Sanski Most. So that's that. This means very urgent.

6 He wasn't supposed to write dispatch, because this has been a

7 coded message. So sometimes they neglect, they don't write that, so we

8 the bosses insist that they do. And now you have this mark here in the

9 upper right corner. But you know how it got there. Doesn't matter what

10 the machine was that was used exactly.

11 So then the actual content of the document --

12 JUDGE SCHOMBURG: Sorry. I apologise. I didn't get the context

13 in the upper right corner, where it reads "11 May, 1992." What's the

14 meaning of this, please? Was it added later or...?

15 THE WITNESS: [Interpretation] This handwriting, I seem to be

16 familiar with this handwriting. I'm almost certain that this was the

17 chief's secretary. This is her handwriting. But again, I'm afraid I

18 might be making a mistake, but I think it's Mira Topic, the secretary.

19 This must be her handwriting. When the chief receives a dispatch, his

20 secretary puts it, records it, in his books, in his files. So this is a

21 dispatch that he received. So then he can sort of monitor which

22 dispatches he has received and which he has replied to. So the secretary

23 is in charge of keeping records. She takes it down, and she informs him.

24 So this is the date, and this number here, 11/12, I think this is a number

25 that refers to one of his -- to the chief's books. I'm not sure if the

1 book is still around. And then it says 11th of May, 1992. So my

2 assumption is on the basis of what used to be common practice over there

3 in those offices, but I can't know for sure. But here is my assumption.

4 I think Hasan Talundzic, the chief, probably took this dispatch, bought it

5 back to his office after the meeting, left it there, and that evening

6 where he went and what he did, I have no idea. But Mira, his secretary,

7 was there outside working hours, too. But she wasn't there at that time,

8 so she didn't record it. So probably it was just left in his office along

9 with all the other documents. And then several days after, this is 10 or

10 11 days after the takeover, as you can see, probably Simo was already

11 chief at this point. So he didn't think that this should be destroyed,

12 this dispatch. He gave it to Mira, and he said get it on to the books and

13 leave it there. As far as I can remember, this is Mira Topic's signature,

14 the chief's secretary. She was Hasan's secretary but then also Simo's

15 secretary later on. So I think that's that. It's handwriting, it has

16 been ten years, you know, so I may have forgotten, but this handwriting is

17 familiar, and I am 99 per cent certain that this is Mira's handwriting.

18 But I may be wrong. I'm certainly very familiar with this handwriting.

19 So I think that's what happened with this dispatch, this

20 original. This is a copy of this and what I have in front of me. This

21 was drafted by my communications officer -- officers, at Simo's request.

22 MR. LUKIC: [Interpretation]

23 Q. I think the interpretation was wrong. Correct me if I'm wrong,

24 please. The interpretation was that this dispatch was drafted by your

25 communications officers. Was it drafted by your communication officers,

1 the one you have in front of you with letters leaning to the left, or did

2 your communication officers merely take it out of the machine from the

3 coded tape?

4 A. Not drafted. They didn't write this. They found the tape in the

5 bag which contained used tapes. And then they would wait for a sufficient

6 number of tapes to be there so they could burn them. Such was the fate of

7 all encrypted material. That was the MO. So only those who were in

8 charge, who were authorised to deal with cryptographic protection, once

9 the amount was sufficient, they could have the documents burned. That was

10 the rule. But it happened by accident that there was not a large amount

11 when this tape was tossed into that bag, this yellow tape. So the tape

12 would be left behind if it was coded. So they found the tape, and

13 probably there were many tapes there. They found this particular one.

14 They searched, and they found this.

15 THE INTERPRETER: May the witness please be asked to repeat the

16 last part of the sentence.

17 THE WITNESS: [Interpretation] Have I been clear?

18 MR. LUKIC: [Interpretation]

19 Q. I think he has clarified it. Can you just put this in front of

20 you. Yes, put it over the other copy.

21 JUDGE SCHOMBURG: I'm afraid the interpreter didn't get the last

22 part of the last sentence of the answer.

23 MR. LUKIC: [In English] The witness just said, "Is that clear,

24 whether I was clear." So we have it in the transcript afterwards.

25 JUDGE SCHOMBURG: I can see nodding from the booth. Please

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1 continue.

2 MR. LUKIC: [Interpretation]

3 Q. On the ELMO, now we have a document with letters leaning to the

4 left. Is this the copy that was found later from the tape? It was

5 recorded from the tape that was found in that bag by your communications

6 officers?

7 A. Yes, yes, this is the one.

8 Q. Is it due to that that, on the right-hand side, we can't see any

9 marks in handwriting about this being recorded?

10 A. Yes, this document was not used later on. It had no official use.

11 This was given to a journalist. Now who made copies of it and who looked

12 at it, I really don't know. And it doesn't matter. The chief wanted to

13 use it for something, and he was entitled to use it for anything he liked.

14 He was my senior.

15 Q. Very well. Can you please now remove this copy.

16 MR. KOUMJIAN: I just would suggest that, so the record is clear,

17 that they both be marked. I think we previously marked the document with

18 the handwriting in the upper right as D6, and that bears the ERN stamp,

19 because it was used in another trial, 0063, it looks like 3909, although

20 it's difficult to read. The copy with the letters leaning left perhaps

21 should receive a different designation.

22 JUDGE SCHOMBURG: This then should receive D6B-1. As such,

23 admitted into evidence.

24 MR. LUKIC: [In English] Thank you, Your Honour. May I proceed?

25 JUDGE SCHOMBURG: Please.

1 MR. LUKIC: [Interpretation]

2 Q. Mr. Jankovic, will you please now take the document from the ELMO,

3 or if you can read from the ELMO directly. So can you please turn right,

4 and you can read from the document itself, the one displayed on the ELMO.

5 Can you read the document out to us and try to remember whether this is

6 the same document that we discussed here today when we spoke about the

7 meeting at the public security station in Prijedor on the 29th of April,

8 1992.

9 A. Should I read this out loud?

10 Q. Yes, please.

11 A. I've already read out this part. "All security services centres,

12 all public security stations, and the Sarajevo SUP must take all necessary

13 measures and actions within their purview to secure implementation of the

14 order by the commander of the Territorial Defence staff of the Republic of

15 Bosnia and Herzegovina." This is a bit confusing.

16 "Within their own purview to secure implementation of the order by

17 the commander of the Territorial Defence staff of the Republic of Bosnia

18 and Herzegovina number 02/145-1, dated the 29th of April, 1992. We hereby

19 forward to you the original text.

20 "Order. On the implementation of the order by the Presidency of

21 the Republic of Bosnia and Herzegovina number 02-11-327/92. Pursuant to

22 the decision of the Presidency of the Republic of Bosnia and Herzegovina

23 number 02-11-327/92, dated 27th of April, 1992, on the withdrawal of JNA

24 units from the Republic of Bosnia and Herzegovina territory, and due to a

25 violation of this decision by the Presidency and the looting -- and the

1 incipient looting and plundering of the Republic of Bosnia and Herzegovina

2 by the former JNA, I hereby order:

3 "1. Carry out complete and massive blocking of all roads

4 throughout the Republic of Bosnia and Herzegovina where the units of the

5 former JNA are beginning to evacuate technical equipment and materiel in

6 direct coordination with the MUP."

7 Page 2: "2. Block the general region and the military facilities

8 in the general region." I think there's a mistake here. It should be

9 military. Because here, this reads combat facilities. Because B and V

10 are next to each other on the keyboard of the machine. So this may be a

11 mistake. I think it's probably a mistake. It should read military.

12 "Military facilities from which technical equipment and materiel is being

13 evacuated. The blockade is to be set up with different kinds of

14 formational and natural obstacles, and these should be secured for the

15 units of Territorial Defence of the Republic of Bosnia and Herzegovina and

16 the MUP.

17 "3. Unannounced columns of units of the former JNA and those

18 unescorted by the MUP must not be allowed to leave their barracks or to

19 travel in the territory of the Republic of Bosnia and Herzegovina.

20 "4. Speed up planning and start combat operations --" this is

21 what struck me the most -- "throughout the territory of the Republic of

22 Bosnia and Herzegovina. These are to be coordinated with the Territorial

23 Defence staff of the region, district, and the Republic of Bosnia and

24 Herzegovina. When planning combat operations, plan also comprehensive

25 measures to protect the population and the property and goods owned by

1 citizens of Bosnia and Herzegovina.

2 "Signed by Minister for the Interior, Alija Delimustafic." Here

3 you have the initials of the communications officer who typed this up in

4 Sarajevo. I knew him, but I forgot now. I think his name was Dzanko

5 Mirsad, Mirsad Dzanko. That's the reason I recognise this, it says DZZ.

6 This is "dz." We have a special rule in telecommunications. The typing

7 machine doesn't have the letter "dz", it only has the classical alphabet,

8 international. So "dz" is written as "DZZ," so this DZZ means Mirsad

9 Dzanko.

10 Some people ask sometimes why there are no stamps on these

11 dispatches. We have a rule not to put any stamps on this, because the

12 communications officer is in charge of this, and when he does this, he

13 guarantees for it. So this is a document, and the person in charge must

14 guarantee for the document's authenticity.

15 MR. LUKIC: [In English] Would the usher be so kind and show the

16 witness another document.

17 Q. [Interpretation] This document is not a document that came out of

18 your own service. And in this document again, we can see this mark "Very

19 Urgent" but this time in B/C/S as opposed to the one we had before when

20 the mark was in English, "Very Urgent." Will you please tell us, can you

21 tell where this document originated, who it came from?

22 A. Yes, yes, it's all clear. On the basis of my experience, of my

23 long experience with communications, I could -- I've laid eyes on

24 documents sent by National Defence. I didn't learn their rules, but I'm

25 able to recognise their documents. They use -- they use different

1 expressions from us. They don't use "very urgent," but like the army,

2 they use the same expressions in B/C/S; "urgent," "very urgent," with

3 different degrees. So this is very urgent. This is the most urgent

4 degree. According to their book of rules, they were supposed to use the

5 B/C/S version, so that's why it says [B/C/S phrase] or"very urgent."

6 Q. Can you just please read out the number and the date.

7 A. This is sender, the Republic of Bosnia and Herzegovina, Ministry

8 for National Defence, Territorial Defence Staff Sarajevo, number 02/145-1,

9 Sarajevo. Dated 29th of April, 1992.

10 Q. The previous document that you have read out in its entirety, the

11 heading reads: "All security services centres, public security stations,

12 and the SUP in Sarajevo must take all necessary measures and actions from

13 their purview to secure implementation of the order by the commander of

14 the Territorial Defence staff of the Republic of Bosnia and Herzegovina

15 number 02/145-1 dated 29th of April, 1992. We hereby forward to you the

16 original text."

17 JUDGE SCHOMBURG: May it be that we have different documents?

18 Because on my document, the registration number reads 02-11-327/92. And

19 not 145, as you mentioned.

20 MR. LUKIC: [Interpretation] The sender's number, the number in the

21 upper corner, that's the number I've just read.

22 JUDGE SCHOMBURG: So your intention is now to read out the entire

23 document once again, from the beginning. I thought the witness has

24 already explained this upper left-hand side part of the document.

25 MR. LUKIC: [In English] He explained the previous document which

1 referred to this one I just pointed out to the witness.

2 JUDGE SCHOMBURG: Just to know, this document is available in

3 English translation in the moment as well? If not --

4 MR. LUKIC: We submitted this document for the translation, but

5 unfortunately, it hasn't been finalised yet.

6 JUDGE SCHOMBURG: May we therefore ask the witness also to be kind

7 enough to read this document in its entirety.

8 THE WITNESS: [Interpretation] No problem.

9 JUDGE SCHOMBURG: Thank you.

10 MR. LUKIC: [Interpretation]

11 Q. Kindly --

12 A. Before that, let me tell you that there is nothing unclear about

13 numbers here. The number that I am now showing, that I am pointing to,

14 and the number that I am pointing to now, and that is the number that His

15 Honour has just mentioned now, that is the number of the document by which

16 the Presidency of Bosnia and Herzegovina addresses the Ministry of the

17 Defence and the Ministry of the Interior, and then the Ministry of the

18 Interior use the other number to address their subordinates, and the

19 Ministry of Defence using this number address their subordinates, and the

20 Ministry of the Defence, using this number, addresses its subordinates, so

21 this is the number of the Ministry of Defence, the other is the Ministry

22 of the Interior, and the number that they refer to is the number under

23 which they receive the order. I believe this is clear now.

24 Q. Can you please read the second document in its entirety, please.

25 A. I've read the heading already. "Pursuant to the decision of the

1 president of the Republic of Bosnia and Herzegovina number 02-11-327/92,

2 dated 27 April 1992, on the withdrawal of JNA units from the territory of

3 Bosnia and Herzegovina, due to the fact that this decision of the

4 Presidency has been violated, and that the looting of the property of the

5 Republic of Bosnia-Herzegovina has started by the former JNA, I hereby

6 order the following:

7 "1. Carry out the complete and large-scale blocking of all the

8 roads in the territory of Bosnia and Herzegovina by way of which the units

9 of the former JNA have started pulling out technical equipment and

10 materiel in direct coordination with the Ministry of the Interior.

11 "2. Block the general sector of military facilities from which an

12 attempt is being made to pull out technical equipment and materiel. Do

13 this by various sorts of formation of natural obstacles which are to be

14 provided to the units of the Territorial Defence of the Republic of

15 Bosnia-Herzegovina and the Ministry of the Interior.

16 "3. Prevent the exit from the barracks to the unannounced

17 columns of units of the former JNA unaccompanied by the MUP and prevent

18 their travel through the territory of the Republic of Bosnia-Herzegovina.

19 "4. Speed up the planning and begin combat operations in the

20 entire territory of the Republic of Bosnia-Herzegovina and do this in

21 coordination with the staff of the Territorial Defence of the region, the

22 district, and the Republic of Bosnia-Herzegovina. Within the planning of

23 combat operations, also plan the measures to protect the population and

24 property of the citizens of the Republic of Bosnia and Herzegovina.

25 "Signed by the commander Colonel Hasan Efendic." And here, this

1 is not our communications centre. This has been done by an officer whom I

2 don't know. I don't know whose initials are these.

3 JUDGE SCHOMBURG: The trial stays adjourned until half past 1.00.

4 --- Luncheon recess taken at 12.10 p.m.

5 --- On resuming at 1.36 p.m.

6 JUDGE SCHOMBURG: Please be seated.

7 In the meantime -- may I ask you to bring in the witness. In the

8 meantime, we received the Document D46 in B/C/S. Any objections to admit

9 this document as D46B into evidence?

10 MR. LUKIC: No objections, Your Honour.

11 MR. KOUMJIAN: No, Your Honour.

12 JUDGE SCHOMBURG: Admitted into evidence, D46B.

13 May I ask the Defence to continue.

14 MR. LUKIC: [Interpretation]

15 Q. Mr. Jankovic, are you ready to continue?

16 A. Yes, I am.

17 Q. Now, I would kindly ask you, since we have quite a few questions

18 to go through, can you please speed up a little and give us a bit shorter

19 answers. That doesn't mean you don't have to explain things, but try to

20 be shorter in your responses.

21 A. I understand.

22 Q. Is there a prison in Prijedor?

23 A. No. In the public security station, even before the war, there

24 was a detention room. That's a room which meets the legal requirements

25 for such purposes; its shape, the things that are inside. Its size is 3

1 by 4 metres. It may be more, may be less. I don't know.

2 Q. Has a prison been subsequently built and is there a prison today

3 in Prijedor?

4 A. No.

5 Q. After the takeover of Prijedor, up to the attack on Hambarine, did

6 the number of people brought into the public security station in Prijedor

7 go up?

8 A. Yes. There was one of average number before the 30th of April,

9 1992, and a somewhat higher number was between the 30th of April and the

10 30th of May, the date of the attack on Prijedor. And then it went up

11 dramatically. In this middle period, the number did go up, but not

12 significantly.

13 Q. And after the attack on Hambarine, did it go up?

14 A. Yes, it did, dramatically, because the ones who were detained were

15 primarily the participants in the attack.

16 Q. Was an investigation centre set up because of the increased number

17 of detainees, that is Omarska and Keraterm?

18 A. Yes, I know that they were set up. I didn't participate in that.

19 I don't know who set them up and how, but yes, at that time, they were set

20 up. Personally, I didn't believe that that was the reason for setting

21 them up, but I can't tell you.

22 Q. Up to the takeover of Prijedor, you had meetings, so-called

23 collegians [as interpreted], at which department heads met. When Simo

24 Drljaca was appointed the chief of the public security station, did

25 something change?

1 A. Yes, it did. Very much so. Ever since I joined the police in

2 1980, up to the date that you have mentioned, and that is when Simo

3 Drljaca came, there were weekly meetings chaired by the chief of the

4 station, formerly the secretary of the station. And the members of that

5 meeting or the collegian were all the heads of departments, and one of

6 them -- I was one of them, one of the heads. I was the head of the

7 communications department.

8 When Simo came, that body ceased to exist and meet. At least,

9 they didn't meet at regular intervals. He would, for example, call me if

10 there was something to do, a job to do, or if he needed me to report to

11 him on something. And sometimes he also called all the heads if there was

12 an action envisaged for which we were all to take part in. So these were

13 not so regular meetings of a regular body consisting of all the department

14 heads.

15 Q. How many times a day would you enter Simo Drljaca's office on

16 average?

17 A. Since Simo Drljaca was my direct superior, my immediate superior

18 from whom I took orders, he gave me tasks, and I reported to him for the

19 discharge of my duties, whenever I had to see him, I would enter his

20 office. I would stay there for as long as needed in order to discuss the

21 issue that I wanted to discuss. Sometimes it didn't happen at all during

22 one day, and sometimes it would happen as many times in three days,

23 whether it was on his invitation or I had to see him.

24 Q. Were you ever sent to do something in the investigation centres

25 Omarska and Keraterm? And can you tell us briefly about the things that

1 you were asked to do.

2 A. Before those times, and at the beginning of these events, I only

3 did those things that were under my authority, and that is the maintenance

4 of communication facilities and their regular use in the transmission of

5 information. That is why throughout all that period, that is, in 1992, I

6 was in Omarska three times, and once I was in the investigation centre

7 Keraterm. I was never in Trnopolje during that period of time.

8 I did go on a private business. I took a woman to see her sister,

9 and that's when I went through that in my private vehicle, and I had that

10 that woman in the vehicle. I saw the area from that vehicle, but I didn't

11 pay too much attention to what was going on.

12 Q. Who provided security of these investigation centres? Could you

13 see that?

14 A. Let me first say something about Omarska. It is my opinion that

15 the physical security was provided by active policemen who belonged to the

16 police station in Omarska. And there were also many more other people

17 whom I didn't know. I knew the former ones, but I didn't know the latter

18 ones. The latter ones wore the reserve -- the uniforms of the reserve

19 police. That's why I knew that they were reserve policemen. Sometimes

20 reserve policemen didn't even have those blue uniforms, but they wore

21 camouflage uniforms. And for that reason, I didn't know whether they were

22 really military or maybe they were the police who wore camouflage uniforms

23 because they didn't have any other uniforms. So that's for the Omarska

24 investigation centre.

25 I was in Keraterm only once, and the investigation centre

1 Keraterm, the building itself is in such shape that both the detainees and

2 the guards are separated from each other. Because the inspector who

3 interrogated them and who had in their possession the communications

4 means, they were in those rooms that used to house offices for that

5 company. So there I couldn't see much. I saw police members, some of

6 whom I knew personally. In any case, they wore uniforms, some of them.

7 But not all of them. They were our employees. They were taking

8 statements in these offices, but since I walked through the corridor, I

9 didn't enter any of the offices but the one where the telephone was, I

10 repaired it, and then I left that room.

11 I heard that on that day, an international commission or group of

12 international representatives were supposed to arrive on that day, and

13 that is why everybody was well, sort of, dressed, and they were sort of

14 better groomed. They were expecting that delegation, and they had cleaned

15 a little. I actually can't compare how the whole thing looked like before

16 because I was only there that one time, but there was something in the air

17 showing that they were expecting guests.

18 And during that period of time, I was never in Trnopolje.

19 Q. Who carried out investigations in these investigation centres? Do

20 you know?

21 A. I've already told you - again I'm only talking about Omarska - I

22 saw in Omarska our inspectors. And when I say "our," I mean the employees

23 of the public security station in Prijedor. My task did not take me to

24 all the offices where they worked, but those whom I saw were employees,

25 inspectors, of the public security station. There were some employees

1 belonging to the state security, and that is the detachment of the Banja

2 Luka centre. And there were some unknown people, people for whom I didn't

3 know who they were. Maybe they were the military security or some reserve

4 forces, I don't know, or the state security. But in any case, there were

5 people whom I didn't know. In Omarska, that is.

6 In Keraterm now likewise, but fewer of them altogether, a fewer

7 number of them.

8 In Trnopolje, I don't know.

9 Q. Let me ask you, the inspectors, who did they report to? Do you

10 know, the inspectors who carried out investigations in these investigation

11 centres, who did they report to?

12 A. Again, I will tell you about Omarska. I don't know that much

13 about Trnopolje. I was there for only half an hour. I went through a

14 corridor, entered a room, and left. And as for Omarska, I stayed there

15 for an hour or so.

16 Q. You said that you went through a corridor in Trnopolje. Are you

17 referring to Trnopolje or Keraterm?

18 A. I'm sorry. This is my mistake. I was never in Trnopolje. I

19 meant Keraterm. I'm sorry. I apologise. So in Keraterm, that used to be

20 a ceramics factory, so the machinery used to be on the ground floor, and

21 the inspectors were interrogating on the first floor, in the offices, and

22 that's where I entered one of the offices.

23 Q. Let's go back to my question. To your mind and to your knowledge,

24 since you are an employee of the public security station in Prijedor, who

25 did the inspectors report to? That is, the public security station

1 inspectors. And what about the state security inspectors? And if you

2 know, who did the military security inspectors report to? If you don't

3 know, just say so, say you don't know.

4 A. I believe -- I actually assume that that was the case, because

5 that used to be the situation before these events. An inspector gets a

6 task from his superior and reports to the superior about the results of

7 his work. The boss to all of these inspectors - so that is, of the

8 criminal police - was Ranko Mijic, and I suppose, I expect that they

9 reported to him. And that he was the one who then reported to the chief

10 of the police station, and that is Simo Drljaca. I never witnessed the

11 reporting chain. I didn't need to. But on several occasions, I had an

12 opportunity -- I could see Ranko Mijic entering Simo's office. Sometimes

13 I couldn't enter Simo's office because Ranko was already there, so I had

14 to go back and return later on if I needed to talk to him.

15 As for the state security, they had their own boss, their own

16 superior. And according to the rules, they reported to their own boss who

17 also had a boss in Banja Luka. And as for the others, I believe that they

18 also had their own boss. I don't know who that was. I don't know who

19 they were, where they came from. I never observed their work. They were

20 completely unknown to me.

21 Q. Thank you. Do you know anything about conversations with people

22 in Kozarac prior to the outbreak of the conflict, and who led those

23 conversations through your communications?

24 A. Yes. It's difficult to specify the date. I don't remember, but I

25 think it may have been the third decade [as interpreted] of the month of

1 May. Our police department participated in the activities of the people

2 of Kozarac. The department was led by the former head of the department

3 Osme Didovic. The phone connections were in a bad state. Many of the

4 phone lines were down, so they used the police shortwave frequency, and

5 the communications centre where I work, the conversations were being

6 monitored all the time, so I was in a position to, just in passing -- you

7 know, I wasn't sitting there all the time, listening in, but in passing I

8 did overhear a number of conversations.

9 During the period I'm referring to, that's between the 20th and

10 the 30th of May, there were attempts by the army. I know several times I

11 heard him on the line. I couldn't quite recognise his name, but he said

12 his name, Captain Zeljaja. And he tried to have -- to reach an agreement

13 with the other side, a nonviolent agreement with no fighting and no one

14 getting hurt, to reach a peaceful agreement and avoid conflict. Osmet

15 Didovic, the commander of the department, would always talk back to him.

16 And whenever Zeljaja wanted something or asked for something, Didovic

17 would always tell him: "You know, I'm talking to you from a vehicle and

18 I'll pass the message on to our superiors." And I think the highest

19 ranking superiors was the head of the military sector -- section,

20 Medunjanin. I think that was his name. And he always told Zeljaja that

21 he would see about this with Medunjanin, and then he would get back to

22 him.

23 In our communications centre at my command table, I had a special

24 device which identified the number calling, and I could tell that he

25 wasn't calling from a moving vehicle, but rather from a station. I

1 suppose he was lying because he was trying to buy some more time. After a

2 while, he would call and say that's what was said and this was not what

3 was said and whether they agreed or not, I didn't really feel the need to

4 -- I didn't really belong to the military communications. I was in the

5 police communications. I didn't feel I should be part of that.

6 I'm just saying that's what this commander was saying, and that

7 wasn't right. And then afterwards, what ensued was the fighting in that

8 particular area. I was not there during this period. I don't know any

9 details, but you could see later on.

10 Q. Did you have an opportunity to meet Dr. Stakic? And if so, can

11 you tell us when, on what occasion, and what it was about.

12 A. Yes, I did meet him, but I didn't get to know him very well. I

13 remember the first time I saw him. I didn't really have to cross the

14 street to the other building, the Municipal Assembly building officially

15 very often. And I was not a member of any party, as I've already said. I

16 remember distinctly it was outside the Municipal Assembly building. He

17 wanted me to fix Mico Kovacevic's TV since I was an electronic engineer.

18 So I met Mico Kovacevic outside the Municipal Assembly. He was walking

19 with Dr. Stakic, and that's the first time I saw him. Mico and I started

20 talking, and he asked me when I would fix the TV. Dr. Stakic didn't say a

21 single word. He was just standing there.

22 I don't remember if we were formally introduced, but I noticed

23 Dr. Stakic then on that occasion. He wouldn't have stuck in my mind

24 really for anything. I wouldn't be able to tell him from Adam were it not

25 for the fact that he was quite young and bald at the same time. He was

1 quite silent, and he looked at me and he looked at Mico and he didn't say

2 anything. As far as his last name, I don't have a good mind for last

3 names, those that don't matter to me. The only reason I remember is that

4 my mother's maiden name is Stakic, although it's not the same family. I'm

5 from East Bosnia, from around Brcko, that's 2 kilometres to the east, and

6 he's from that area, but that was my mother's maiden name so that's why I

7 memorised it. So the only thing I remember was that his last name was

8 Stakic and that that was the man. I remember he was wearing a yellow

9 jacket with some white fur. That's all I remember. I may have seen him

10 two or three times later on, but he was not important to me. So we'd just

11 say hello sometimes, but apart from that, we never formally met

12 afterwards. He didn't ask me anything, and I didn't ask him anything.

13 Q. Can you remember if you had ever met Dr. Stakic prior to the

14 takeover, the time you met him with Dr. Kovacevic?

15 A. Yes, I think that was prior to the takeover.

16 Q. Did you ever see Dr. Stakic in Simo Drljaca's office, Simo Drljaca

17 whom you met every day in his office?

18 A. No, never. I didn't see him in Simo's office. I never stayed in

19 Simo's office for a long time. But I would enter the police building, and

20 I would go out always on my own private -- on my own business officially.

21 I never met him there.

22 Q. You never met him in the public security station in Prijedor?

23 A. No. No, I don't remember ever having met him there inside the

24 building.

25 Q. Did you ever hear about the existence of the Crisis Staff of the

1 Prijedor Municipal Assembly?

2 A. Yes.

3 Q. Did you know at this time who its members were?

4 A. No, I didn't. We, employees of the police, we stick to our job.

5 We know the hierarchy, we know the chain of command, we know who we are

6 supposed to report to and what we are supposed to do. It is not even

7 desirable to maybe look around myself too much. I never felt the need. I

8 wasn't interested in finding out who the Crisis Staff were, who was on the

9 Crisis Staff, and what they were doing. Experience teaches, even in the

10 socialist system, that even for minor things they'd immediately set up

11 staffs, Crisis Staffs and other kinds of staffs. I had the feeling that

12 officials were doing this kind of thing just to make minor things seem

13 more important than they actually were. I never attached much importance

14 to these various staffs. I was never really interested nor did I know who

15 were members of the staff. You know, it's like you have a Crisis Staff

16 somewhere far away in a different town. That's what it was like for me.

17 Q. I've asked you already and you've told me that you never received

18 orders from the Municipal Assembly or the Executive Board. Now, let me

19 just ask you, did you ever receive any orders from the Crisis Staff of the

20 Prijedor Municipal Assembly between April and September 1992?

21 A. No.

22 Q. In 1993, at the beginning of 1993, Simo Drljaca left the Prijedor

23 public security station. Is that correct?

24 A. He went to Bijeljina for a while, and then after that, he was

25 back. I know that he did leave but I wouldn't know about the dates.

1 Q. Can you remember who replaced him?

2 A. Bogdan Delic did. When he left, Bogdan Delic became chief.

3 Q. On that occasion, was Simo Drljaca demoted or promoted, in case

4 you know where he had gone to?

5 A. I don't know what he did exactly. He went to Bijeljina, and the

6 MUP was in Bijeljina at this point. What he was doing over there, I

7 really don't know.

8 Q. When you say the MUP, you mean the ministry, the headquarters of

9 the Ministry of the Interior?

10 A. Yes, precisely. They had their headquarters for Republika Srpska

11 in Bijeljina. I even can't remember -- you know, ministers kept changing.

12 I can't even remember who was occupying the position during that

13 particular period, and I can't remember who it was. Whether he was in

14 that group or what he was doing, I don't know and no one ever told me. It

15 wasn't really important.

16 Q. How long did you work in the public security station in Prijedor

17 in 1993, and what happened then?

18 A. One of the reasons that I wasn't really interested so much in what

19 was going on is that my illness kept deteriorating in those months.

20 That's the second half of --

21 Q. You mean 1993 and 1994?

22 A. Yes, yes, that was a mistake. That was towards the end of 1993

23 and the beginning of 1994, my illness deteriorated. And then in March

24 1994, I left for Belgrade to neurology, and I was undergoing examinations,

25 medical examinations for about 40 days, and then in June an operation was

1 performed on one of my eyes that was giving me trouble. And then I was on

2 sick leave, and I didn't come back until the end of the war. It was only

3 at the end of 1997 that I came back to my work.

4 MR. LUKIC: [Previous interpretation continues]... [In English]

5 another exhibit. It's not marked yet. It's a detailed plan of Prijedor

6 city with the MUP building and Municipal Assembly building.

7 JUDGE SCHOMBURG: May I come back to the last document you

8 tendered. This was the one 145, signed by Mr. Hasan Efendic. My

9 understanding is that you tendered this document. This would then be

10 D48B. Any objections by the Prosecution?

11 MR. KOUMJIAN: No, Your Honour.

12 JUDGE SCHOMBURG: Then admitted into evidence. And in the list of

13 evidence, please make reference to the transcript that we know that we

14 have the translation in the transcript.

15 This document following now would be D49. I can see no

16 objections, therefore, admitted into evidence. Please continue.

17 MR. LUKIC: [Interpretation]

18 Q. On this sketch of the town of Prijedor, it's blown up, you have

19 two buildings marked in green. Can you please explain which two buildings

20 are these, and can you point to exactly where the entrance is to these

21 buildings.

22 A. Yes. This is part of an official town plan by the land surveyor's

23 office, and it's very accurate. I think aberrations are extremely small.

24 This building I'm pointing at right now, that's the municipality building.

25 You can see the stairs here, the entrance and the exit to the municipal

1 building. This is the front of the municipality, and this here is a park.

2 And now there's a street running between the municipality building and the

3 public security station, and this is the public security station. That's

4 one section of the public security station because there's another section

5 which you can't see here. Now we can see it.

6 So one part of the station is here. These -- the garage. And the

7 entrance to the station is right here. And this green patch, green area

8 outside the station, this is the pavement. This is the street. This is

9 the other side of the street and the pavement, and this is the

10 municipality building. And this here is a green area, and this is a

11 street.

12 Q. Thank you very much, Mr. Jankovic.

13 JUDGE SCHOMBURG: Just before we leave this document, may I ask

14 you, have there ever been cells or arrest cells or provisional cells

15 behind or close to the building of the security building?

16 THE WITNESS: [Interpretation] Are you asking me, Your Honour?

17 JUDGE SCHOMBURG: Yes.

18 THE WITNESS: [Interpretation] The building itself, this one here

19 that I pointed out, you can't see it here, unfortunately. This is where

20 the map ends. But the public security building, it's here. And then

21 behind is the garage. And here there's another garage. So it's parallel

22 to the SUP building. Now, this is an official courtyard where vehicles

23 belonging to the police are parked. And the only detention room in this

24 building here behind the garage, and then on the first floor, but not on

25 the first floor, they couldn't, but there was a room where they had

1 meetings. So here maybe they could detain someone just for an hour or

2 two. But I can't say this for sure.

3 So the only detention room was the one that was the official

4 detention room, according to the rules that had to be satisfied. That was

5 the only thing. But here, around here, officially, there was no space for

6 detention. Officially, certainly, there was nothing in the surroundings

7 here. The municipality building, the park, this is the museum. This is

8 the museum. Here is the court next to the SUP building. This is the

9 building where the mine management was located. This, again, is a green

10 area.

11 And then this last building, which also belongs to the public

12 security station, that's the last building I'm talking about, and that's

13 where the room was that I've referred to, the detention room. Three by

14 four metres perhaps.

15 JUDGE SCHOMBURG: May I ask you why you emphasise that officially

16 there was nothing in the surroundings for the purposes of detention? Was

17 there something unofficially or is it really your testimony that all the

18 time all over 1992, there was only one room for detention?

19 THE WITNESS: [Interpretation] That's why I said "officially." I

20 want to tell you the truth, so I'm trying to limit myself to the area that

21 really is related to. That's throughout the ten years of my work there,

22 that's what I can talk about. There was that one room which had that

23 purpose, and that was that. Maybe they may have used one of the other

24 rooms or the hall for that at some point, but all the other rooms were

25 occupied, the warehouses, the garage. So there was no space inside any of

1 those rooms to detain anyone. Those were very small rooms. Maybe only

2 the hall, but then again the hall, but you can't keep it shut for a long

3 time because there were glass windows which would be easy to shatter if

4 someone was trying to get. So there were no such facilities available

5 really.

6 I'm trying to be very cautious here because someone may have

7 detained someone without me knowing about it, obviously. But those were

8 private things. I'm telling you what there was in official terms. Not

9 that I know of anything unofficial that was happening, but this is the

10 only thing I know for sure. That's why I'm saying "official."

11 JUDGE SCHOMBURG: Mr. Lukic, you have further questions?

12 MR. LUKIC: [In English] No, Your Honour. We have finished our

13 direct examination.

14 [Interpretation] Mr. Jankovic, you will now answer questions by my

15 learned colleague from the Prosecution and after that also by the Chamber.

16 JUDGE SCHOMBURG: As to the fact that during a period of time of

17 two hours hearing, there is mandatory break for the change of the

18 videotapes, I think it's appropriate, in order not to interrupt the

19 cross-examination and the following questions and the re-examination, that

20 we have a short break of about five minutes just in order to give the

21 possibility to the video unit to exchange the tape now, if there is no

22 other order by the video unit. It's okay?

23 MR. KOUMJIAN: I would say I think I have a couple of hours of

24 cross-examination. About two hours would be my estimate, if that's

25 permissible.

1 JUDGE SCHOMBURG: Yes, but nevertheless we have to make a break,

2 and it's better to start with a break.

3 --- Break taken at 2.17 p.m.

4 --- On resuming at 2.20 p.m.

5 JUDGE SCHOMBURG: Please be seated. And may the Prosecution start

6 with the cross-examination, but may I ask to be as brief as possible, that

7 we have, to a certain extent, a balance between the parties also during

8 the Defence case. Please.

9 Cross-examined by Mr. Koumjian:

10 Q. Good afternoon, sir. You said that "we stick to our job,"

11 discussing the police, and that "we had our own chain of command."

12 Perhaps you could explain something to me. On the 29th of April, I

13 gathered from your testimony, you recognised your boss as Mr. Hasan

14 Talundzic. On the 30th of April of 1992, the next day, I gather that you

15 recognised as your boss Simo Drljaca and you no longer followed the orders

16 of Mr. Talundzic. Is that correct?

17 A. Yes.

18 Q. Well, sir, since Mr. Talundzic was the police chief that had been

19 elected by the Municipal Assembly of Prijedor, that was elected in the

20 1990 elections consisting of all nationalities, who was it that told you

21 -- or under whose orders, whose orders were you following --

22 MR. LUKIC: Objection, Your Honour. It is wrongly stated that

23 Mr. Talundzic was elected by the Municipal Assembly of Prijedor.

24 JUDGE SCHOMBURG: I think it can be appropriate to rephrase the

25 question.

1 MR. KOUMJIAN: Thank you.

2 Q. Mr. Talundzic was nominated by the party that had won the most

3 seats - thank you; Mr. Lukic is absolutely correct - and that was the SDA

4 party. And under the agreement among the parties, his name was forwarded

5 to the Ministry of the Interior and he was named the chief of police of

6 Prijedor. Is that correct, sir? I see you nodding, but you have to

7 answer out loud so that the record includes your answer.

8 A. Yes, I will. I understand your question. Yes, in our service,

9 all the heads, higher heads, are appointed by the minister, and that was

10 also the case with Mr. Talundzic. And whose proposal that was upon, that

11 really doesn't matter. Obviously, it was on the proposal of a party.

12 I report to my superior, and I obey my superior. My superior was

13 Talundzic. On the day when the dispatch arrived, I gave it to Talundzic,

14 who signed it and took it from me. On the following day, at 7.00 in the

15 morning, the -- Prijedor was taken over. I was not into politics. I did

16 not participate in the takeover. How that happened, I don't know. But

17 physically, Talundzic was no longer there. There was another man whom I

18 had seen for the first time the day before and on that day for the second

19 time. And he told me, "I am the chief." And what else was I supposed to

20 do? I saw everybody else reporting to him and taking his orders. What

21 was I supposed to do? Everybody else did it, I did it as well. What do

22 you think, that I could do differently than everybody else? I am a person

23 with a degree in electrical engineering. I worked for the police. What

24 am I supposed to do?

25 Q. Thank you, sir. And you're not an trial here. I'm not accusing

1 you of anything, and I appreciate you just --

2 A. I am trying to defend my case, if you know what I mean.

3 Q. Sir, so this man who introduced himself as the new chief of police

4 was Simo Drljaca. Correct?

5 A. Yes, correct.

6 Q. And you knew that Simo Drljaca was not a professional policeman;

7 he had been an administrator in the schools prior to that. Is that

8 correct?

9 A. I told you then, on the eve of the takeover was when I saw him for

10 the first time. I didn't know who he was, what he was. He only told me

11 "I am Simo Drljaca." That's what I knew. Then later on, I heard that he

12 worked in education, that he was a lawyer for the education system or

13 something. But I didn't need to know anything more about that. It was

14 not up to me to know anything more of him.

15 Q. Thank you. But obviously, this must have a very memorable event;

16 you come to work one day and the chief has been replaced, all the top

17 officials in the municipality have been replaced. Didn't you talk about

18 this with your fellow employees as to who it was that had ordered this

19 takeover?

20 A. The first part is correct, what you have said. Obviously, it is a

21 memorable day when my chief changes, and that I remember. However, the

22 municipality building being so close is still very far. I never asked any

23 questions as to who ordered it, what was ordered. I just assumed there

24 were people there. What people those were, I don't know. I really don't

25 know who these people were, but I believe that there must have been an

1 organisation because this person appeared in front of all of us, all the

2 employees of the police. I was just one of the two hundred and something

3 employees of the police.

4 Q. Thank you. And I don't want to waste your time or my limited time

5 asking you about things you don't know. Would it be correct, then, you

6 don't know who Mr. Drljaca was receiving his orders from? You never

7 attended any meetings of the Crisis Staff or meetings in which the

8 military was present. Is that correct? And you do not know who set up

9 the Omarska, Keraterm, and Trnopolje camps?

10 A. You've asked me a lot of things at a time. First, answer --

11 Q. You're right.

12 A. Please, if I forget a question, can you please repeat it. So the

13 first question was this: Did I know who appointed Simo? Answer, no. He

14 appeared on that evening for the first time, and he said, "I am your

15 chief." He said that in a very authoritative voice. And who was any of

16 us to ask him, "Okay, who appointed you? How come you're now our

17 chief?"

18 JUDGE SCHOMBURG: Could you please be so kind and slow down a

19 little bit in order to allow the interpreters to follow your testimony.

20 THE WITNESS: [Interpretation] I apologise. I'm doing my best, but

21 sometimes I forget myself.

22 MR. KOUMJIAN:

23 Q. Thank you. Perhaps to assist, I'll break down my question.

24 You're correct, I asked you several questions together. Did you ever

25 attend any meetings of the Crisis Staff in Prijedor?

1 A. No.

2 Q. Did you ever -- do you know who was giving orders? Did you read

3 or were you present in meetings in which orders were given to Simo

4 Drljaca?

5 A. At that time, like before that time, orders did not come via

6 written telegrams, mostly not. But I never came across any of them.

7 There may have been such telegrams, but I never came across any. If there

8 were any, I usually don't read those telegrams without a need for me to

9 read them. I never saw any orders issued to Simo, but I believe that

10 there were orders, and I believe that they came from his superior and his

11 superior is in the centre, in Banja Luka. His superior is the chief of

12 the security centre in Banja Luka. We were just a branch office, so to

13 say. So it was my assumption, and I didn't go anywhere else, anywhere

14 further to corroborate my assumptions. I did not need to do that.

15 Q. Thank you. But right now I'm not asking you about what you

16 assumed but what you actually saw or witnessed or read. Did you ever --

17 A. I didn't see them. I didn't read them. I never experienced

18 anything like that.

19 Q. Did you ever read any reports written by Simo Drljaca to the

20 Crisis Staff or to the Municipal Assembly of Prijedor?

21 A. No.

22 Q. Did you ever attend any meetings in which Mr. Drljaca coordinated

23 with military counterparts?

24 A. No.

25 Q. And I believe you told us you've never been in the Municipal

1 Assembly -- let me rephrase that. You never were in Dr. Stakic's office

2 and never attended any meetings with Dr. Stakic. Is that correct?

3 A. I don't want to make a mistake here. I don't know where his

4 office was. I don't know where his position was. But I was once in a

5 room, but that was long before, immediately after the first multiparty

6 elections, and I was called by Dr. Mico Kovacevic. There were other

7 people there whom I didn't know. I don't know. I believe that this was

8 his party. I don't know whose room it was. Now, if you ask me whether

9 that was a meeting of some sort, an organised meeting, I don't know. I

10 just can tell you that I was invited, I went there, and left. And the SDS

11 was supposed to propose three candidates for the commander of the public

12 security station because the SDA proposed the chief, Talundzic. And since

13 these people didn't understand much about the police, they didn't know the

14 people, they only asked me about my opinion. If I was in the position to

15 propose somebody, who would I propose? And then I proposed -- there were

16 some candidates, a lawyer from the health centre who was an alcoholic, or

17 at least looked like an alcoholic to me; the second one was Simo Drljaca,

18 I remembered his name, I didn't know him; and there is also Dusan

19 Jankovic, the assistant commander in our station. I proposed Dusan

20 Jankovic for one and only reason; he was the only professional among the

21 three and it was in the interest of the service. And I thought as a

22 professional, he would do the best job, unlike the other two whom I didn't

23 know and who were not professionals. That was my only reason for

24 proposing him.

25 Whether Dr. Stakic was there at the time or not, I don't know. If

1 he was there, I assure you I didn't see him. Maybe he was there, but in

2 any case, I didn't see him. And that is throughout the entire period,

3 that is the only time when I entered the premises of the Municipal

4 Assembly.

5 Q. Do you know, sir, who took power on the 30th of April? Who was in

6 charge of Prijedor that day?

7 A. I can just give you my impressions. I wouldn't go in depth

8 because I may make a mistake. On the 29th, I told you what happened with

9 that dispatch. After that, I went home. In the evening, my subordinates

10 called me, and I've already explained what the system was when they needed

11 to call me. The duty officer had to be aware of my whereabouts 24 hours a

12 day. And those who wanted to get in touch with me, my superior or

13 somebody else, they would get in touch with the duty operations officer

14 who would then call me.

15 And that's what happened on that day. Somebody called me. I

16 don't remember who that was, because the duty operations officer changed

17 all the time. There was somebody else on duty at different times. So I

18 went to the communications centre, and I was told that an order had

19 arrived to go to Cirkin Polje at the entrance to Prijedor, and to go there

20 to the local commune premises.

21 Q. Okay. Sir --

22 A. I left two communications officers behind, and the rest of us went

23 there, all of us, because somebody had to be left behind. Somebody has to

24 be in the communications centre all the time. On that night, we all

25 stayed there, and then on the following morning, when Prijedor had been

1 taken over, we returned, and we came to the SUP building.

2 Q. Sir, it's a very simple question: Do you know who took power on

3 the 30th of April? Can you give us the names of the individuals or the

4 organisation who took power?

5 A. I can't tell you who the organiser was, because there were a lot

6 of people gathered there. All those people who were gathered there were

7 employees of the public security station, and there were some other people

8 unknown to me. But there were also reserve policemen whom I also didn't

9 know. I didn't know them. So there were lots of unfamiliar people. It

10 was night. I didn't have anything whatsoever to do directly with any of

11 them. There were a lot of people.

12 And as for the organisation, nobody said anything about that. And

13 I was not interested in that. I just was one among that huge mass of

14 people. I saw all of my bosses there, and I just joined them. I just

15 went with them.

16 Q. Well, in fact, you didn't see all of your bosses there. You

17 didn't see Mr. Talundzic, for example, there. You only saw Serbian police

18 officers there in Cirkin Polje. Isn't that correct?

19 A. Yes, that is correct.

20 Q. And in Cirkin Polje, there was a house where the leaders were at.

21 Is that true? Were you invited into a house where the leaders were

22 staying?

23 A. Can you be more precise? The leaders of what? Are you referring

24 to the public security station or maybe wider?

25 Q. In Cirkin Polje, did you see Slobodan Kuruzovic that night, the

1 early morning hours of the 30th of April?

2 A. I don't know whether I would recognise Slobodan Kuruzovic even

3 today. He may have been there. Why? Because there were people wearing

4 military uniforms, people with ranks. But I didn't know them. A major

5 approached me and asked for the radio set. I refused to give it to him

6 because he didn't belong to the police station. I told him, You're not on

7 my list, on the list of the police station. And I don't know which major

8 that was.

9 Q. Did you see Dr. Stakic in Cirkin Polje that night?

10 A. No.

11 Q. Were you asked to remain outside or did you go into a residence

12 there?

13 A. I entered the building, but as a communications officer, I did not

14 have any concrete tasks in these activities. Then one of the superiors --

15 when I say "superiors," I always refer to the superiors or the heads of

16 the public security stations. That is one of my colleagues, in other

17 words. He gave me a small package, sir. You don't see me, sir. I'm

18 showing the size of the package. So he gave me this kind of package and

19 told me these are the forms for the new official IDs, that is the IDs that

20 every policeman needs to carry on their body. So he told me these are new

21 forms, and if there's nothing else for you to do, please fill out these

22 forms. So I took a pencil, and they came to me, the old policemen, the

23 new policemen. There was a lack of professionalism there because there

24 was no photo. I just asked them what their names were; when they told me

25 their names, I would enter their name on the ID, and God knows how many

1 names I entered on that night. When they approached me, told me their

2 names, I would just enter them on the forms.

3 Q. Believe me, sir, I do find everything you say interesting, but

4 because we're limited in time, try to answer the question accurately in as

5 short a manner as you can do and still be accurate.

6 So you entered the building briefly. Would that be correct? My

7 question originally was Did you go inside the building? and I believe your

8 answer was yes, you did, but just briefly to fill out these forms, to get

9 these forms.

10 A. Yes, yes. But there were lots of rooms there, and I was sitting

11 in one of them, and believe me it could happen if did happen. I didn't

12 know what was going on in the other rooms, and I was filling out these

13 forms for quite a long time.

14 Q. Thank you, that explains things. And I won't ask you further

15 questions on this subject in the interest of time.

16 I want to go back to talk about the visits of Stojan Zupljanin

17 first in April. At that time, were you aware that an Autonomous Region of

18 Krajina had been set up, based in Banja Luka, prior to the time that

19 Stojan Zupljanin came to Prijedor?

20 A. All these political terms, Autonomous Region, independent, not

21 independent, I really never found that interesting. I never watched any

22 TV programmes. I didn't read newspapers. And it was something that

23 looked to me like it really didn't happen. And I have the same attitude

24 to the current political events. I knew Stojan Zupljanin from the

25 university days. For me, he was the chief of the Security Services Centre

1 in Banja Luka, and that's how I know him and that's why he matters to me.

2 Everything else doesn't matter a thing to me.

3 Q. When Mr. Zupljanin came to Prijedor, he wanted the officers in

4 Prijedor to change the emblems that they wore and to sign a loyalty oath

5 to the Serbian Republic. Is that correct? Or please correct me if I'm

6 wrong.

7 A. Well, maybe in some other sense it means that, because the centre

8 in Banja Luka covered - I don't want to be wrong on the number of

9 municipalities - but it did cover a certain number of municipalities. And

10 this entire area covered by the Banja Luka centre, in all of these

11 municipalities, there were -- there was the SDS was the party in power,

12 which appointed a chief, and only in four municipalities it was the SDA.

13 And the objective was for the centre to remain unique because these four

14 municipalities did not all belong to Prijedor. They were scattered all

15 over the area. And if they remained there, and if the centre accepted

16 those insignia, then obviously it was assumed that we would also wear

17 these insignia. But that's what I believe was done.

18 Q. Okay. Can you just very briefly describe the insignia that they

19 wanted you to wear.

20 A. Yes. A three-coloured flag; red, blue, and white. And not a

21 square but a wavy sort of line, as if that flag was sort of in the wind,

22 and the size of it was of a stamp, 2 times 3 centimetres, as far as I can

23 remember. I saw it then. Very few people wore those insignia for a very

24 short period of time, so...

25 Q. On the 29th of May, the meeting that you talked about, all the

1 employees were there. And is it correct that the debate at that time was

2 whether Prijedor would answer only to Banja Luka, which was controlled at

3 that time by the SDS party, or would answer to Sarajevo and to the

4 interior minister, who at that time was a member of the SDA party, or how

5 Prijedor police would resolve this dilemma that they were getting orders

6 from two parties who were in opposition to each other?

7 A. Very complicated question. Firstly, I believe that you made a

8 mistake; you said 29th of May but I believe you meant the 29th of April.

9 Q. Correct. You're right.

10 A. Okay, let's move on then. I think that the debate was still on,

11 and the situation was still the following: What is being said and what is

12 being meant between the lines was, Why should we be with Banja Luka if

13 Banja Luka doesn't send us salaries? Why should we be used by Banja Luka?

14 We would be better off by being with Sarajevo. This is what the

15 chairpersons were saying, and they said we would receive the first salary

16 on the following day, and the second one, the back payment would follow

17 within a few days. That's what they were saying. But the motive among

18 these top people was not to be concerned about our salaries, but there

19 were other people who understood it that way. So let me put it this way:

20 One thing was said, and what was meant was something else. That was the

21 situation at that meeting.

22 Q. In the middle of that meeting to resolve this problem, you say you

23 received the telegram that we looked at earlier today. And this was a

24 telegram that was addressed to all the security services centres, to all

25 the public security stations throughout Bosnia. Is that correct?

1 A. Yes.

2 Q. You said that when you read this, although it's normally not your

3 practice to read telegrams, you had to comment on it at the meeting

4 because of its importance and what you felt what it meant, that it would

5 mean war. Is that correct?

6 A. As a communications officer, I am not forbidden to read such

7 documents. We can do them in -- that in justified cases. But if I do

8 read the contents of such a telegram, I am not to abuse my knowledge. So

9 I had the right to read the telegram, and I thought I had to read it

10 because of the urgency.

11 So that's the first part of your question. And now, can you

12 please repeat the second part of your question.

13 Q. When you read the telegram, you felt that it was of great

14 importance; you needed to tell others about it because it would mean war,

15 such an order. Is that correct?

16 A. Yes. Because of the very short period of time that could be

17 measured in minutes only. I really didn't have the time to think about

18 the consequences of me saying something or of me not saying anything. I

19 wanted to keep the level head, but I really didn't have the time. I still

20 don't think that I made a mistake by speaking out. But as for the

21 consequences, what they were -- but it was my feeling that I had to ask

22 the floor and contribute to the discussion, to the debate, because it was

23 an internal meeting, the people there were only members of the police. So

24 I didn't speak before the public at large. I didn't release anything to

25 the public. I spoke in front of my fellow policemen.

1 Q. And is it correct, as you mentioned, there are two different ways

2 in which telegrams are classified, if I understood you correctly. One is

3 the urgency of the telegram, and second is secrecy, and this telegram was

4 not marked secret. Correct?

5 A. Correct; no, it wasn't marked as secret. And ever since I have

6 been in this position, I have experienced this mark being omitted. And

7 all the time bosses punish their subordinates if they omit this mark of

8 secrecy. Each today, you can go to the service, you can still see

9 telegrams without the mark of secrecy although there should be one. You

10 can see that even today in Banja Luka security centre. That is something

11 that people tend to omit. That is a misdemeanour or breach of discipline

12 that happens very often.

13 Q. Try to just answer the question, just so that we can finish on

14 time today. It was not marked secret. Correct?

15 A. Yes, that's correct.

16 Q. And you mentioned that just in the Banja Luka region, there were

17 municipalities that were controlled by -- not by the SDA but by the SDS,

18 that the majority of municipalities were not controlled by Muslims, and

19 the chief of police in these places were Serbs. Correct?

20 A. Yeah, well, I could enumerate all the municipalities. I do know

21 this because I still work with those municipalities. But --

22 Q. Just to shorten the list a little bit, because I believe you would

23 have about 17, the three municipalities that you mentioned you would have

24 to forward it to, Sanski Most, Bosanski Novi, and Bosanska Dubica, all

25 three of those on the 29th of April, 1992, had Serbian chiefs of police.

1 Correct?

2 A. Yes, that's correct. No, no, excuse me. Novi Grad, Bosanski

3 Novi, and Bosanska Dubica I think had Serb chiefs. And Sanski Most, I'm

4 not sure really about Sanski Most. I don't know.

5 Q. Okay, thank you.

6 Now given what was written in this telegram, in point number 4

7 that you read, it basically says to accelerate the planning and launching

8 of combat activities. Did you find it surprising that this would be sent

9 to chiefs of police openly including many, the majority, who were members

10 of Serbian nationality and many of the SDS party?

11 A. I believe this was -- I have given it some thought. I believe

12 this was poor quality work in terms of delivery of information. Starting

13 from Sarajevo, because that was the source of information, and I'm

14 referring here to the Ministry of the Interior, when you organise the

15 delivery of information, it's about the technical makeup of the whole

16 channel. From Sarajevo, from the MUP, information is being sent out to

17 ten different centres, these dispatches. And then each of these centres

18 in their turn forwards this information to public security station, to

19 public security stations. Only Prijedor had three, and Banja Luka I think

20 must have had 10 or 11 at the time.

21 And then due to the poor quality of their work, they know that

22 they have the SDA in Prijedor. And they send it over there. So now why

23 didn't they pay attention, these other three municipalities, I really

24 don't know. A communications officer has a limited job, after all. He

25 looks at the heading, CSB to all, SJB to all, he just looks at it, and he

1 does what it says. And then there is a discrepancy between that and the

2 real situation on the ground in Prijedor, between how something is

3 technically implemented and how information is delivered and what actually

4 happens. So there you have it.

5 Q. Let me ask you a very specific question: The first line, the

6 first addressee is to "Chief, all security services centres." For the

7 Banja Luka region, that would have been Stojan Zupljanin. Correct?

8 A. Yes.

9 Q. Now, when you were going over the addressing of this telegram and

10 the numbering system, at one point you said something is omitted,

11 something that is supposed to be there. What was that? What is omitted

12 from the addressing?

13 A. The dispatch number was omitted. You have MUP of Bosnia and

14 Herzegovina, and then you have 10-70, and then nothing following. 10

15 means minister. 70 is the number of entry in the minister's book of

16 records, the ordinal number of the dispatch that was sent. And then

17 there's a slash, and the slash is supposed to be followed by the year the

18 dispatch refers to. So the number 92 is missing, if you ask me. And as a

19 rule, it should be there.

20 Q. Okay. Thank you.

21 Now, this order also instructs the recipients to stop the JNA from

22 pulling out its materiel and equipment from Bosnia. I know you've said

23 you don't follow political events, but the 29th of April, correct me if

24 I'm wrong, was after the recognition of Bosnia by the European Union and

25 the United States. And at this time, isn't it true that it was the SDS

1 party that did not want the JNA to remove its equipment from Bosnia and it

2 was the Muslim and Croat parties that did want the JNA to leave Bosnia?

3 A. This is a really complicated political issue. Too complicated for

4 me, I think. Last time I testified - that was a year and a half ago -

5 believe me, a colleague of yours asked me when exactly Bosnia and

6 Herzegovina became an independent sovereign state. Frankly, I didn't know

7 the date. Later, I asked around and they told me that it was, I think,

8 the 6th of April or thereabouts. So being a technical person, an

9 engineer, I really know precious little about all these things. I feel a

10 certain amount of commotion surrounding certain events, but there are too

11 many technical things, and my hard disk in my head has an overload of

12 information, I'm afraid.

13 Q. Thank you. I can understand that.

14 Sir, based upon what you did with the telegram you received, would

15 there be any way for what you received to have been in the hands of

16 Vladimir Arsic on the night of the 29th of April?

17 A. I believe the telegram could not have been, but that someone who

18 was there may have overheard something and then passed the information on

19 to him. That seems possible. Why? Hasan was the chief. I suppose he

20 took it, but I don't think he passed it on to anyone who might have given

21 it to Arsic. I don't know what he did with it, but on that particular day

22 I suppose he was there. But I really don't know because he took the

23 document -- he took it over in front of 500 people, I suppose, or

24 thereabouts, 500 people present there.

25 Q. Okay. Thank you. Later, someone - Mr. Drljaca - asked you for a

1 copy of this, and later you saw it, am I correct, it was published in

2 Kozarski Vjesnik. Is that correct?

3 A. Yes.

4 Q. Sir, did you hear the demands for the surrender of weapons from

5 the Muslim communities, places like Brdo, like Hambarine, and places like

6 Kozarac and the surrounding villages? Did you ever hear public demands

7 for them to surrender weapons?

8 A. I believe I did. When I say "I believe I did," I mean lately I've

9 heard stories about those things happening back then. When I think back,

10 I seem to remember that there was something like that, but there were so

11 many events happening almost simultaneously, you know, weapons and my own

12 job with communications and this and that. I can't remember and I can't

13 be sure, but yes, I think there was something like that. Recently I heard

14 someone talk about it, so that sort of rang a bell, but I'm not sure.

15 Q. Sir, did you hear announcements made in Prijedor on any subject in

16 the name of the Crisis Staff of the Municipality of Prijedor?

17 A. No. At this time, I spent most of my time, including my spare

18 time, doing my job. And when I wasn't doing my job, I was trying to get

19 food for my family and for myself and look after number one, but I wasn't

20 actively involved in the town's life or public activities. And I do not

21 know that there was ever any such announcement. I don't want to say that

22 there wasn't one, but I certainly don't know of it. That's after the one

23 I told you about, the one I heard on the radio where a plea was made to

24 prevent war.

25 Q. You mentioned -- when you say the radio, you're now talking about

1 a communication radio and not public radio that would play music, that

2 type of radio station. You're talking about --

3 A. No, diffusion radio, that's what I talked about, on the 10th of

4 April when the two journalists came and when there was the announcement

5 that everything was under control and there would be no war. That's the

6 announcement I was talking about.

7 Q. Okay. And you also talked about communications with Osme Didovic,

8 who was head of the security station in Kozarac. You said about

9 10 or 15 police were stationed there. Is that correct?

10 A. Osme Didovic was not chief. We called him commander of the

11 department, and chief would have been higher up the pecking order. This

12 department, in peacetime, had between 10 and 12 active-duty policemen. As

13 things were getting worse, they started mobilising reserve police forces,

14 so the reserve police forces joined in. The police work in shifts, you

15 know, so when I go there, I can't see all of them at a single time. And I

16 didn't ask him about how many people he had. But probably at this time,

17 as the situation was getting ever more complicated, the number of

18 mobilised reservists kept growing, too. It was on the rise, but how many

19 exactly at this point I really don't know.

20 Q. I'm particularly interested, and I want you to concentrate now on

21 the 24th of May, 1992, the day of the attack on Kozarac. Did you monitor,

22 did you hear any of the radio communications between Mr. Didovic and

23 authorities in Prijedor such as Major Zeljaja?

24 A. Yes, I did say that. This was not a diffusion radio. It was our

25 own police radio, the same kind of radio that the police use when

1 patrolling the streets.

2 Q. In fact, did you hear Mr. Didovic -- not the 24th, but I believe

3 it would have been the next day, the 25th or the 26th, offer to surrender?

4 A. First of all, I would like to ask you to please -- because I told

5 you in my testimony, I don't remember the date. Don't ask me the 25th,

6 did you do something on the 25th, and then I can tell you that yes I did,

7 and then I'm not sure. So I don't want to be tied down to any dates. I

8 think that was during the last ten days of May. Whether it was the 25th

9 or the 26th, I really don't know. I can't say that I remember a single

10 sentence of that, but I remember the overall picture. I remember the more

11 global context. I remember that Zeljaja was endeavouring to keep conflict

12 from breaking out, to deal with this in a peaceful, nonviolent way, and

13 then they talked back to him and they gave him their conditions, their

14 terms. And you know, it was part of my work. I would be in the room, and

15 then the next meeting I would be out of the room, so I wasn't there --

16 sitting there, really listening very attentively. My communications

17 officer at one point told me, they still haven't reached an agreement, so

18 that was all I knew at that time and that's what I took it to mean, they

19 are still working on it. I can't say that I heard anything personally

20 over the radio, but I cannot completely rule this out.

21 Q. Do you know what happened to your colleague Mr. Didovic?

22 A. I heard that he had been killed. Now, the person I heard this

23 from could not have been taken as a reliable source, I think. I remember

24 his face, but where did he come from? He was wearing a huge hat, civilian

25 clothes. But he had stars and some -- some stars on a shoulder strap. But

1 you know, as we usually say, he's not from our village. So this person

2 told me once, but he didn't belong to any of the units and he was just

3 wearing civilian clothes and a huge black hat. He had the stars and the

4 epaulets. I think he was probably crazy. He said he'd seen something.

5 So I wouldn't take that for an official piece of information from a person

6 like that.

7 Q. Could you share with us what this person told you happened to Mr.

8 Didovic?

9 A. I remember as if through a dream. They were headed somewhere, and

10 then there was a bridge, and then the police came. Some sections of the

11 police, some active-duty policemen from Kozarac were on their way

12 somewhere. I can't remember the details, but there was a clash and they

13 were killed, and they remained there lying on the ground next to the river

14 and that bridge. That's all I can tell you. But you know, I'm pervaded

15 by this feeling of unease if I see a corpse. I'm horrified. So I don't

16 really remember the story.

17 JUDGE SCHOMBURG: Unfortunately, I have to break because I learned

18 that, once again, the tapes have to be changed. Therefore, the trial

19 stays adjourned until half past 3.00.

20 --- Recess taken at 3.08 p.m.

21 --- On resuming at 3.31 p.m.

22 JUDGE SCHOMBURG: Please be seated.

23 May I ask Mr. Koumjian, please, to proceed.

24 MR. KOUMJIAN: If the usher could just move the ELMO back a bit.

25 Q. Sir, you mentioned that Mr. Didovic in Kozarac also was speaking

1 to a Mr. Medunjanin. Is it correct that that was Becir Medunjanin, who

2 was a school teacher by profession?

3 A. As far as I remember from that period - I'm talking about

4 Medunjanin - I forgot his name, but I think I know which man you're

5 referring to. Is that the person who was the president or the secretary -

6 I no longer remember what the official name was - of the former

7 Secretariat for National Defence which went to the SDA after the

8 multiparty elections. So they appointed their own man, that was him,

9 wasn't it? The name escapes me. It's an uncommon name for me, so that's

10 exactly the kind of name I find very difficult to recall.

11 Osme Didovic, his name is Osme Didovic, I know that because he

12 worked with me, the same company, so to speak.

13 Q. Yes, we're talking about the same individual. Were you aware that

14 Mr. Medunjanin was a school teacher?

15 A. They were SDA people. I'd never seen him before he was appointed.

16 And when he was appointed, I only heard about the -- about him because of

17 the events that were happening. But then I had no contact whatsoever with

18 his department, his service. I didn't need to have any official contacts.

19 I never heard from him. I never saw him. I know that the person you're

20 talking about may have him, but I can't even remember his face. I never

21 saw the man, actually.

22 Q. Sir, you testified that you visited Omarska three times, and there

23 you saw some of your colleagues from the Prijedor police station and from

24 the state security station in Prijedor, which shared the same building

25 with you. Did you discuss with them events taking place in Omarska and

1 the killing of people like Mr. Becir Medunjanin and Mr. Cehajic?

2 A. Long before the war, that's if I decide to call it "war," I mean

3 those events, one of the basic features in my line of work is that I never

4 asked any workmate of mine what they were doing exactly because that would

5 cast dubious light on my reasons for asking the question. I did spend

6 time with my workmates, yes, and long before the events, my wife was an

7 inspector in the same public security station, but she never told me

8 anything about her work, what she worked on on a particular day. All the

9 time we spent together, we talked about the weather, we would talk about

10 salaries, we would discuss sports. If, for example, I asked my best

11 friend what happened to so and so, because in my work, I really had

12 no reason to ask, so I would give the impression that I had a reason, a

13 hidden agenda, a reason to ask when really there was none on my part. So

14 it was completely superfluous.

15 I was just doing my work, and I would always just stick to my

16 work. I wasn't asking my colleagues questions of this kind, these young

17 ladies helping us. And one of the ladies who were helping us here around

18 the Tribunal asked the witness about their name. And that was really --

19 that seemed very unpleasant, because she was supposed to just be doing her

20 job and not supposed to know anything more than that. And that was always

21 my line of reasoning, and that's how I treated my colleagues, too.

22 I was there. I met Vukacin Pesic, one of the inspectors. He

23 asked me, you had lunch already? I haven't grabbed any lunch so far, so

24 let's go and grab some lunch together. So we would sit in their

25 restaurant. We would share some food, we would talk about completely

1 different things. I didn't know what he had been doing on that day or

2 what he would be doing the next day. So that was my own policy in my job.

3 I never wanted to give anyone any reason to believe that I had said

4 anything to anyone that I shouldn't have said.

5 Q. Is your answer, then, that you never discussed, or no one from

6 your workplace ever talked to you about killings in the Omarska camp,

7 including killings of prominent, well-known people in Prijedor?

8 A. There were a number of situations where I would notice -- I could

9 see it on my colleagues' face that, how should I put it, this person, the

10 workmate of mine, had a burden upon his back somehow, that he was

11 preoccupied, worried about something that was happening. But especially

12 as concerns the two persons you were asking about, those people were not

13 really close to me. They are a different generation, and their jobs were

14 very far, not related to mine. So the gentleman you've just mentioned,

15 president of municipality, Cehajic, I mean, I hardly knew him. I had no

16 reason to ask him anything, to put him any questions.

17 Not my own colleagues, not even common people out in the street,

18 although I kept hearing many things about people getting killed when I

19 talked to people in the street. But you know, stuff I heard from common

20 folks, it was, you know, unimportant. Some people talked about people

21 getting killed, and then I heard that some people had been killed, but

22 then I would see these very same people somewhere about town later on. So

23 I don't know how reliable the whole thing was.

24 Q. You mentioned that you went to Keraterm one time. Do you remember

25 the month that you visited the Keraterm camp?

1 A. I can't remember, not even roughly.

2 Q. Okay.

3 A. No, I'm sorry. I can't. I remember the image, the -- what I saw

4 there, but I didn't see any of the inmates at all because I just didn't go

5 that far into the facility. And those who had occasion to learn what the

6 facility looked like know what I'm talking about. There are halls there

7 with industrial -- with machines used for industrial production, and then

8 there were some offices for administration. And that's where the

9 inspectors were, that's where the phone was and that's where I was, too.

10 There was a special entrance to that part.

11 Q. You indicated that the staff appeared to you to be getting ready

12 for a visit of internationals. And I gather that you recall hearing

13 something about some foreigners who might be visiting that day. Is that

14 correct?

15 A. Yes, yes, that's correct. A man told me, I think it was Zivko

16 Jovic, who was an inspector, he said we have visitors today, so hurry up.

17 I don't want to loiter about. They are coming. So I did my job and I

18 left. And I noticed that they had this attitude as though they were

19 expecting visitors.

20 Q. Okay. It would be correct that it was visitors, not necessarily

21 internationals, but some type of delegation, some kind of prominent

22 persons were expected to visit, according to the information you had?

23 A. I don't know who was coming, but throughout that period, I know

24 that it was either foreign journalists or humanitarian organisations with

25 white UN vehicles. That's what I often saw, so I should suppose that they

1 were expecting humanitarian organisation or maybe a delegation from

2 several humanitarian organisations, journalists, perhaps. But I don't

3 remember any military units. I think those were journalists, humanitarian

4 aid workers, that sort of thing. But no one told me explicitly, so I just

5 assumed.

6 Q. Let me ask you, and if you don't know the answer, you can tell me;

7 isn't it true that Keraterm was closed before, in fact, the day that the

8 foreign journalists were coming to Prijedor? The Keraterm camp was

9 closed, and there were no international visits to Keraterm?

10 A. I really don't know. I didn't go there officially for my work,

11 and there's no way for me to know that. Now, I don't have any information

12 on this that I may have received through friends and acquaintances. I

13 only know about that day, I was told that someone was arriving. That's

14 all I know.

15 Q. Do you remember Mr. Zupljanin coming back in the summer of 1992

16 with Radoslav Brdjanin to visit Prijedor?

17 A. I know nothing about that visit. I only know about the day I told

18 you about, the 9th of April, that he came and that he was not able to take

19 the main road back, the Prijedor/Banja Luka main road. He had to pass

20 through Kozarac, and then on through Bosanska Dubica and Bosanska

21 Gradiska. I think that's, the distance is between 110 and 120 kilometres.

22 Q. Is it correct that Mr. Drljaca was replaced in January of 1993 -

23 if you don't know the dates, just tell us - and then eventually came back

24 to Prijedor near the end of the war as the chief of police again?

25 A. One thing is for sure; I don't remember the date. But I know that

1 Drljaca was my chief only for a very short time. I went on sick leave in

2 March 1994. He may have been in that position for three, four, or five

3 months, but it may have been around that time but I really can't tell you

4 the date. I can't remember.

5 Q. When did you come back to work in the Prijedor Police Station

6 after your sick leave?

7 A. Nearly four years. And the operation, I was operated in July

8 1994. The operation was a serious one. It was an eye operation.

9 Q. So you came back sometime in 1998, would that be correct, after

10 the arrest of Mr. Drljaca -- arrest or attempted arrest of Mr. Drljaca?

11 A. Drljaca was never my superior again. Formally and legally, yes,

12 but he wasn't giving me any tasks because while he was there, I was on

13 sick leave. So briefly, when I came back, Ranko Mijic was my supervisor.

14 Q. Who was the chief of police when you came back?

15 A. Ranko Mijic, who, up to that point, used to be the chief of the

16 crime squad.

17 Q. And did he take over, according to the information you had, from

18 Simo Drljaca after Mr. Drljaca was killed?

19 A. I think that wasn't when Simo Drljaca was killed. I think first

20 he was removed - I don't know the reason - and he was still around but he

21 was not working there. I think he was only killed at a later date.

22 Q. Okay. Thank you. Before I move on, just one brief question, I

23 hope. You had a lot of experience during the communist period of time.

24 Was it common during that period of time that when local leaders were

25 removed, they were often given some type of soft landing and brought to

1 the ministry or to the capital with another job?

2 A. Unfortunately, yes. That was always the case in our country.

3 There's a lot of bribery and corruption, and many of those who should have

4 been punished -- for example, a police officer makes a mistake, he should

5 be suspended from active service, but then this is taken with a lot of

6 latitude, you know, so the police officer is allowed to retire, and

7 sometimes pensions used to be higher than the actual salaries, so this

8 police officer would be given more money than before, and quit work. So

9 that used to be the case. This was a false kind of humanitarian

10 treatment.

11 And this applied to all the different levels, you know. There was

12 a lot of bribery, a lot of corruption. So there was favoritism, too.

13 Q. Thank you. You've kind of introduced my next subject or my next

14 question. Sir, during 1992, specifically between the takeover and the end

15 of September, were you aware of any efforts to investigate or arrest

16 Serbian police or army officers for crimes against Muslims or Croats in

17 Prijedor?

18 A. Can you please just try to rephrase your question, but make it a

19 bit shorter if you can, because it's slightly too long and slightly too

20 complicated. I'm afraid I might get the answer wrong.

21 Q. Sure. Did you ever hear of any police or army, Serbian police or

22 Serbian army, being arrested for killing Muslims or Croats in 1992?

23 A. Yes.

24 Q. Can you tell us about that.

25 A. For example, our own forces, one person who was arrested, and I

1 think he's here now in detention, Zoran Zigic. He was one of those. I

2 didn't personally witness this, but the things I heard were so convincing

3 that I think, yes, he had been killing people. So he was arrested, and

4 then I don't know what charges were pressed against him in Banja Luka, but

5 I know that he was in prison there. I don't know what the actual

6 indictment was. He was in prison in Banja Luka. I know this because once

7 I was on my way back from Banja Luka in my private vehicle, I was stopped

8 at a checkpoint, and a police officer asked me to take with me a woman and

9 two children. It was very cold. And then this woman told me that she was

10 Zoran Zigic's wife and that she had gone to Banja Luka to visit him in

11 prison. I can't remember if it was before or after Dayton, but it was

12 about that time.

13 And there was - what's his name? He was killing people in

14 Trnopolje. He was also in prison. I can't remember what his name was.

15 So I hear things from people, but officially, it's not part of my job, and

16 I'm not interested.

17 Q. Well, let me ask this question -- if you don't know the answer,

18 you can tell us -- isn't it correct that Mr. Zigic was arrested for

19 killing a Serb girl and that arrest did not take place during the period

20 between April and September 1992?

21 A. As I said, I really don't know what the counts against him were,

22 what the indictment was, why he was being investigated. I have no idea

23 what it was about. But I know that he had been killing people, and I know

24 that he was in prison. Why officially, I really don't know, whether for

25 the murder of that girl or for everyone he had killed. But you can check

1 this with the Banja Luka Court, I'm sure.

2 Q. Thank you. Sir, it was common knowledge in Prijedor that in July,

3 there was a massacre at the Keraterm camp. Isn't that correct?

4 A. I heard that it had happened. That's what I heard. I didn't

5 witness anything, nor did I go there at this time. Who I heard it from, I

6 don't remember. But the way people talked about those things -- you know,

7 at work, no one talked about this. Everyone just sort of kept silent, but

8 there was a general sense of horror. And then whenever someone brought

9 the subject up, they would just say, "Yeah, it happened," and then people

10 would just be very worried, concerned. No one was enthusiastic about

11 this.

12 I heard so, and I believe that these things indeed had happened,

13 but how it all happened, I really don't know.

14 Q. Do you remember in the summer of 1992, there were lines of women

15 waiting outside the police station in Prijedor in the morning hours?

16 A. During the whole day, from the early morning hours.

17 MR. KOUMJIAN: Could we briefly have that map of the town put back

18 on the ELMO, please. Sorry, the number is...

19 JUDGE SCHOMBURG: D49.

20 MR. KOUMJIAN: Thank you, Your Honour.

21 Q. Sir, if the area is depicted on this diagram, can you show us

22 where the women would line up.

23 A. Please, if I may, you're talking about people leaving Prijedor,

24 and then coming for their documents? Is that what you're asking me about?

25 Q. Well, I'm specifically talking about the lines of women, and you

1 can explain the purpose that they were there for. But the lines that you

2 saw that you just referred to that were there all day, can you show us

3 where they were.

4 A. It was like this. This here is the police building. This is the

5 main entrance. And this entrance here, this is a green area. This area

6 here is surfaced, and it's perhaps between 7 and 8 metres wide. And

7 here's the pavement. It's about 4 metres wide. Here you can see the

8 trees, and here there was grass. A grass area. The length, so the line

9 was here. It started here. Then down the pavement, and it was quite long

10 in the morning. And then it grew longer and longer. And then up to here,

11 there were poplar trees here in this place. So this is the museum

12 building. I would say the line stretched as far as the museum building.

13 Q. Okay, thank you. And for the record, I'll try to describe what

14 the -- how the witness pointed to the line.

15 He indicated a line going first perpendicular from the SUP

16 building, and then going out to the pavement, and then, looking at the

17 diagram, then going to the left until the museum.

18 Is that correct, sir?

19 A. Yes, yes.

20 Q. Thank you.

21 A. Just here where you said perpendicular, this is a very narrow

22 patch here.

23 Q. Thank you. Then you're referring to the short part of the line

24 going perpendicular to the building, and then the line went parallel to

25 the building.

1 Sir, can you tell us about the intervention squad. Who commanded

2 the intervention squad in Prijedor in the summer of 1992?

3 A. This intervention squad, we used to have drills of the reserve

4 police forces in peacetime. And I knew the drills and the units very

5 well. We didn't have any kind of intervention squad or platoon. And then

6 suddenly this intervention squad turned up, it was just there suddenly.

7 Who brought them there, who organised them, I haven't managed to

8 understand this to this very day. But yes, they were there. They didn't

9 have any sort of military hierarchy so you could tell who the commander

10 was, and the soldiers lined up. They were more of a jumble really, and in

11 motion when they were there, but sometimes only part of them was there. So

12 I could have attempted to conclude that's the man, but then I may have

13 been wrong. If they had a proper military unit and the commander came to

14 meetings, the commander of this intervention squad, this never happened.

15 I never knew the commander the way I knew the commander of the police

16 station or the commander of the crime squad. But he was not officially

17 part of any larger unit. But I did not know that they were part of any

18 larger unit officially, so there was no way for me to know their

19 commander.

20 It still seems like an unofficial group to me. Who brought them

21 there? Who was the commander? I'm afraid I might go wrong if I say

22 anything. Everything would be just my assumption.

23 Q. Is it correct that they would bring detained persons to the SUP

24 building?

25 A. Yes.

1 MR. KOUMJIAN: Your Honour --

2 Q. Do you want to add something? I want to move on to another topic.

3 But if you would like to add something --

4 A. Just briefly, just briefly, if I may add: A lot of work was done

5 by professional police officers and professional inspectors. The whole

6 behaviour and the whole work was very much like it had been before the

7 war. So every person suspected of having committed a crime or a violation

8 of any of the laws would be brought in. And then the investigating judge

9 would give a signal for the investigation to be stopped or to go ahead.

10 But at this time, you had a huge number of such people, and the room

11 became very small for all the suspects. It would have taken an enormous

12 amount of investigating judges to deal with all of them. So some of them

13 were dealt with in a regular way and some of them were dealt with poorly

14 in terms of procedure. So it's difficult to know, because there were many

15 people coming in and very few people to process them. So I think that's

16 what the poor quality of work was due to, and that's why other things

17 happened later on.

18 MR. KOUMJIAN: Okay, I'd like to move on to another subject. And I

19 request, if there's no objection from anyone, to do it in private session

20 just for the protection of the witness.

21 MR. LUKIC: No objections, Your Honour.

22 JUDGE SCHOMBURG: Let's move into private session, please.

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18 [Open session]

19 A. Before the setting up of the Omarska investigation centre, there

20 was a station of the police Omarska. It existed even before I joined the

21 police. And there was a radio, a fixed radio station, so not a mobile

22 radio station, so a radio set in the room, and it also had a direct

23 telephone line. Actually, it had two telephones; there was a public PTT

24 connection, and there was our internal police line. And that was in the

25 peacetime. When these unrests started, somebody, I don't know who,

1 damaged -- I believe that there is about 20 kilometres between Prijedor

2 and Omarska, so somebody damaged the telephone line, and for a while, we

3 were without a telephone connection, so the only thing we used was the

4 radio connection.

5 When the collection centre Omarska was set up, actually, it was

6 the first time when I heard about that, it was in the late afternoon,

7 about an hour before the sunset, Simo Drljaca called me and told me, asked

8 me: "Do you have a radio set on your stock? You have to go immediately.

9 You don't have much time. Before dark, you have to go to Omarska and

10 mount it up there. You will find our people there and they will tell you

11 where to mount that radio station." And that's what he told me. And I

12 asked the technician to accompany me. We took our official car, and we

13 took the radio set, the cable, the antenna, and the whole set. We went

14 there. I don't remember whom I found there, but whoever I found there, I

15 knew all of them. They were all our policemen. And then they told me:

16 "Put it there. Go upstairs and go to the first office on the right-hand

17 side." It may have been the second right, but it certainly isn't the

18 fifth on the right. So immediately on the right, they told me put it

19 there, and the two of us mounted the radio station there in that place

20 that they indicated to us.

21 Later on, in order to establish a telephone line, I don't know how

22 much longer after that, I engaged some postal workers who repaired their

23 cable, the Omarska/Prijedor cable, telephone line, that is, and then they

24 established the telephone line. And they gave the Omarska camp yet

25 another number for the telephone. But that was much later, and I can't

1 remember the date.

2 JUDGE SCHOMBURG: Was there also a telegram line between Omarska

3 and Prijedor?

4 A. No.

5 JUDGE SCHOMBURG: Thank you. What about the connection between

6 the Prijedor police office and Keraterm? Was it also necessary to set up

7 a similar connection as you just told us?

8 A. Yes. We didn't have a radio connection to put it there. And for

9 practical reasons, it was not possible because it is easy to listen in to.

10 And again, there was a town, so there were a lot more lines. It was easy

11 to set up a connection between us and the postal building. And that's --

12 postal office building. That's why we established a telephone line, and I

13 believe that up to the very end, nothing else was set up there but just

14 that one telephone line. But they could use the mobile radio sets, the

15 ones such as used by the policemen, by the policemen who do the patrols.

16 That's what they used. But there was no affixed radio -- no fixed radio

17 station.

18 JUDGE SCHOMBURG: Did you have a similar connection from Prijedor

19 Police Station to Ljubija football stadium?

20 A. The Ljubija stadium, I don't know what you mean when you say. Why

21 the stadium? Maybe there is a problem with the interpretation. What

22 would we have to do with the football stadium? I don't understand.

23 JUDGE SCHOMBURG: Maybe it was a separate unit, but the question

24 would be, first, were there colleagues of yours stationed at Ljubija

25 football stadium?

1 A. These are the -- I know that we had a connection that we had

2 inherited from the times before that, and that was the telephone

3 connection and the radio connection in the facility or in the building of

4 the police station in Ljubija. And later on, I know that some of our

5 colleagues, Muslim colleagues, had taken that and kept it for a while, and

6 then the others took that over. I don't remember the dates for any of

7 these events. And I don't have any information that would put this

8 stadium into the context of my knowledge. So I don't have any knowledge

9 whether anybody was there, whether they were or whether they were not. I

10 only know that there was no other connection but that one with the police

11 station in Ljubija, that is, in the building of the police station in

12 Ljubija.

13 JUDGE SCHOMBURG: Thank you for this clear answer.

14 We learned that in the evening of the 29th of April, 1992, you

15 were engaged in filling out some documents in order to prepare new IDs.

16 A. Yes, that's what I said.

17 JUDGE SCHOMBURG: You mentioned already several names, and you

18 told us that for this reason, you were not -- it was not possible for you

19 to have an overview of what happened in the entire building. But may I

20 ask you, in this room or on another occasion in Cirkin Polje at that

21 evening, did you meet one of the following persons: Dusan Baltic?

22 A. I don't know this person. He didn't work in the SUP. Dusan

23 Baltic, he may have been there, but that is a person I don't know and the

24 name doesn't ring a bell. I'm sure that he was not a professional working

25 in the SUP. I know all the colleagues there except for the younger ones.

1 JUDGE SCHOMBURG: Nada Markovska.

2 A. I know her well. She is a typist. She works in the crime

3 prevention police. I didn't notice her. She may have been there, but I

4 didn't see her. I didn't move about a lot. But it seems to me that there

5 were no women there. I don't remember seeing any woman there on that

6 evening. She may have been there, but I don't remember a single woman

7 there, that is, of our employees. There were certainly none in the room

8 where I was.

9 JUDGE SCHOMBURG: So it doesn't make sense to ask you whether you

10 met Madam Nada Balaban?

11 A. Balaban, Mrs. Balaban; do you mean the English teacher? Balaban,

12 Mrs. Balaban, she is a teacher of English. I'm not sure if that's the

13 person.

14 JUDGE SCHOMBURG: A person working sometimes - we'll learn about

15 this - as interpreter and, yes, maybe you're more acquainted with the name

16 Nadja.

17 A. No, Nada. I know this lady because she gave English lessons in

18 the same kindergarten that my son went to, so that's the only reason I

19 remember her. That was before the war. Excuse me, I never met her

20 personally. Not in our section. I did see a tape from a German TV

21 station. She was interpreting and Simo Drljaca and some foreign people,

22 foreign delegation, were standing there, and she was acting as their

23 interpreter. I saw this footage filmed, but I never witnessed this

24 myself.

25 JUDGE SCHOMBURG: Finally, the last name, did you meet there in

1 Cirkin Polje Mr. Milovan Dragic?

2 A. Milovan Dragic, if you mean Dragic, believe it or not, I met this

3 person here at The Hague. We met here. That's the first time I saw the

4 person, and he told me what his name was. And it was slightly unpleasant,

5 because he knew me and I didn't know him.

6 JUDGE SCHOMBURG: Thank you for this, once again, extremely

7 concrete answer. But to come back to this evening of the 29th of April, I

8 understood that you worked in one single room. What I did not understand,

9 maybe I didn't take care enough, could you assist us: You spoke about a

10 meeting of about 500 people. Was it at the same time, was it previous to

11 your working in this single room? Was it later? And where did it happen;

12 inside the building, outside the building?

13 A. I did say this. I may have not been very clear. I'll try to put

14 this very briefly. The meeting with 500 people that I talked about, that

15 was in our meeting hall that -- when I talked about the detention room,

16 you go through the courtyard, and on the opposite side of the courtyard

17 that's where the meeting hall was. And the meeting was over at about half

18 past 3.00 in the evening. I went home. They gave me a call around 8.00

19 in the afternoon, and then I was on my way to Cirkin Polje. It's about 4

20 kilometres. That would have been half past 8.00 or 9.00. It was already

21 dark. And then due to low electricity levels in that area, the light, the

22 street lighting wasn't very good. But the facility itself has many small

23 rooms. And now I was in one of those rooms. And there were people

24 milling around all the rooms and around the facility, too. Around the

25 building outside.

1 JUDGE SCHOMBURG: Sorry to interrupt. Because we have to be

2 extremely brief now due to time concerns, may I ask who chaired this

3 meeting of these 500 people?

4 A. I'll repeat this. From left to right, sitting there, Muhamed or

5 Muharem Cehajic. So he was there for sure. President of municipality and

6 secondary school teacher. So I'm looking from left to right from my

7 position. Mirza Mujadzic, head of the SDA or president of the SDA. In

8 the middle, the chief of the station, Hasan Talundzic. Next to him,

9 Fikret, then commander of the traffic police. And the last person to the

10 right, Simo Miskovic. And then an empty space, and there was a rostrum

11 there, and Radovan Krkan was standing there and he was keeping the

12 minutes.

13 JUDGE SCHOMBURG: Thank you for this precise answer. This really

14 gives us the impression of what happened there.

15 The final question would be one related to Document D6B-1, this

16 very urgent telegram. Is it correct that this meant that when it was very

17 urgent, maybe it had to be -- one had to work on this within 4 hours, or

18 urgent 8 hours, correct? It was linked to a certain time limit?

19 A. "Very urgent" does not refer to the actions that you've just

20 referred to. This is 8.00, or 8 hours. And that's only to check if a

21 certain citizen was to be processed urgently or not. An operational

22 activity would be marked as DX, and that had to be dealt with within two

23 hours. And even more urgent matters would have had to be dealt with

24 faster. "Very urgent" is state concern. That's what they usually refer

25 to. And it had to be dispatched with extreme urgency, and by any means

1 available, to the addressee.

2 JUDGE SCHOMBURG: So didn't you identify the exact hour and even

3 minute when such a document arrived?

4 A. I didn't memorise, but the minute and the hour have to be there in

5 the records kept by Mirsad Sahuric and the records he handed over to the

6 chief. So he must have recorded this. Now where is this book of records

7 I really don't know. They are usually kept for a time period of five

8 years.

9 JUDGE SCHOMBURG: Thank you. Judge Vassylenko.

10 JUDGE VASSYLENKO: I have actually one or two questions. Please,

11 can you tell us, when did you receive the order to go to the Cirkin Polje,

12 and from whom?

13 A. I already said this. I'm going to repeat it for you now. All

14 tasks, all calls, everything else outside my working hours, which means

15 when I was not physically in the police building, ever since I first

16 started working for the police, the usual way to go about this was that my

17 superior would always tell my duty operations officer, and they had three

18 shifts around the clock. And as I was the head of that particular

19 section, even if I just went over to see a friend for a coffee, I was

20 supposed to let them know where they could find me. And every call

21 outside my working hours -- and there were many such calls, equipment

22 would get out of order, and then there would be some extraordinary tasks,

23 and this belonged to the same category of events. So they called me. You

24 know, I would receive at least three or four calls like that every single

25 week, and then for a number of years, and it's very difficult for me to

1 remember who exactly it was who called me on that particular occasion.

2 JUDGE VASSYLENKO: What sort of meeting was taking place in Cirkin

3 Polje and how long did you stay in Cirkin Polje?

4 A. It was not a standard meeting with us sitting there and someone

5 giving a talk. People were assembling, were gathering. Those who were

6 active in our service, some of the leaders, department heads, mostly -- I

7 can't say I don't know anything about that, because I was there. But I

8 can be in a room far from there and I'm just writing, so I don't see

9 anything but hear something. According to the best of my knowledge, what

10 I remember now, there were five groups, each containing 20 persons. Now,

11 whether those were the reserve forces or -- I think there were a number of

12 military there. There may have been many of them, I didn't notice, but

13 there were all sorts of uniforms. Not everyone had blue uniforms. So

14 sometimes you couldn't tell whether a person was a military or a police

15 member. Anyway, there were five groups, each containing 20 people, as far

16 as I know, and each of the groups was led by one person, not -- with no

17 particular striking feature so that I could remember them.

18 I'm talking about group leaders. And they went there with the

19 task of taking over power. As far as I know, one group was for the

20 municipality. One group was for the SUP building. One group was headed

21 for the court. Five groups, and I think one group was supposed to go to

22 the bank, and the last group was supposed to take the post office. So

23 once they had taken over all these facilities, they let us know. They

24 came to the SUP building and it was about 7.00 in the evening. And

25 Muslims were coming to work, so whoever accepted work in that service,

1 because initially some of the Muslims did accept to stay, such people

2 stayed. And those who refused to go on, they just take the official

3 weapon off the person, as well as the official ID. But those who opted to

4 stay on, they would just sign and they would stay. So a number of Muslims

5 did accept at the beginning, but then they were pressed by their fellow

6 Muslims to leave their jobs, so then they would start gradually leaving.

7 A Muslim communications officer I referred to, Sahuric, he stayed

8 on for a month or two after that. And then he left.

9 JUDGE VASSYLENKO: Thank you. I have no more questions.

10 JUDGE SCHOMBURG: Any further questions by the Defence?

11 MR. LUKIC: I'm sorry for trying to interrupt Judge Vassylenko, but

12 the witness said on page 120, line 8, "Whenever my superiors or somebody

13 else called me," and it's entered only as "When my superior called me."

14 It's not only superior, because superiors changed that night. So it might

15 be somebody else. And the witness can clarify this, if you need it.

16 JUDGE SCHOMBURG: I think it's good.

17 I can't see any further questions. Then, it's for me to thank you

18 for coming once again to this Tribunal and to enlighten us on that what

19 you experienced in 1992. And I wish you a safe trip home to your home

20 country and your home town. Thank you very much for your assistance.

21 The trial stays adjourned until tomorrow, 9.00.

22 [The witness withdrew]

23 --- Whereupon the hearing adjourned

24 at 4.45 p.m., to be reconvened on Tuesday

25 the 21st day of January, 2003, at 9.00 a.m.