100913ED

Page 14475

1 half the time that was intended originally.

2 Thank you very much.

3 JUDGE HALL: Thank you, Mr. Zecevic.

4 MR. OLMSTED: Thank you, Your Honours.

5 Examination by Mr. Olmsted:

6 Q. Good afternoon, Mr. Rodic.

7 A. Good afternoon.

8 Q. I first want to go, very briefly, over your background with the

9 State Security Service in the Ministry of the Interior, first with the

10 BiH and then with the RS MUP.

11 You first began working for state security also known as SDB in

12 1983; is that correct?

13 A. Yes, that's correct.

14 Q. Can you tell us where you were stationed?

15 A. I worked in Prijedor all the time. If you mean to

16 the geographical -- you mean the geographical location where I worked.

17 Q. And although the name has changed from SDB to SNB and then to, I

18 believe, OSA, are you still employed with, essentially, the same

19 organisation?

20 A. It was the same organisation all the time, but its name changed.

21 But it was in principle the same organisation, and we worked in Prijedor

22 all the time.

23 Q. I want to briefly talked about period between 1991 up until the

24 split of the MUP in April 1992.

25 During that period, what unit or organ within the SDB did you

Page 14476

1 work for?

2 A. There were no organs in the framework of the SDB. There was just

3 the SDB itself. But it had a detached in Prijedor, in organisational

4 terms.

5 Q. And we have already heard evidence about the various sections or

6 lines that existed in state security. But could you explain to us where

7 this Prijedor detachment fit within the structure, organisationally?

8 A. The Prijedor detachment had a certain number of people, anywhere

9 between four and seven, and it was subordinated to the centre in

10 Banja Luka, organisationally.

11 Q. And other than Prijedor, what other municipalities did the

12 Prijedor detachment cover?

13 A. The detachment covered four municipalities in that organisational

14 form: Prijedor, Bosanski Dubica, Bosanski Novi, and Sanski Most.

15 Q. And did that coverage remain the same after the conflict began in

16 1992?

17 A. Nothing changed then, nothing significant.

18 Q. Now, prior to the split of the MUP in April 1992, who was the

19 head of the Prijedor detachment?

20 A. I think that, at that time, it was Mr. Sead Besic.

21 Q. And who was his superior, organisationally?

22 A. Organisationally, I think Mr. Kesic was the head of the centre of

23 the state security or which was later called Centre of National Security.

24 Q. And can you tell us, were all three ethnic groups represented in

25 the detachment?

Page 14477

1 A. At that point in time, no; but that was a very small

2 organisational unit, too small to reflect the -- the ethnic makeup at

3 that level. But I believe that at the level of the Banja Luka CSB the

4 ethnic composition of the population was reflected in the composition of

5 staff.

6 Q. Can you tell us, were there Bosniaks and Croats working for the

7 Prijedor detachment?

8 A. In the earlier period, there was one Croat and there was one

9 Bosniak who left of their own accord. But referring to the time-period

10 in question, I can say that there was Mr. Besic.

11 Q. And could you tell us where your offices were located in

12 Prijedor?

13 A. The offices were on the premises of the SJB. There was some

14 offices there that we used for our work.

15 Q. When did you first learn that the MUP had split?

16 A. I learned from the media that it had happened and that there were

17 activities to that effect. And after that, there were activities from

18 which one could conclude that the MUP had been split.

19 Q. Do you recall in early April, at the beginning of April,

20 attending any meetings at the CSB in Banja Luka pertaining to the split

21 of the MUP?

22 A. That's what I meant when I said activities. I believe that was

23 on the 4th or 5th, when we were invited to come to Banja Luka to sign

24 some sort of solemn declaration that we will work in accordance with the

25 laws and regulations that were in effect at the moment.

Page 14478

1 Q. Now, after the split - I believe you've testified that

2 essentially it was Sead Besic who was the non-Serb working for the

3 Prijedor detachment - can you tell us what happened to him after the

4 split?

5 A. Sead Besic worked at the detachment, not for the detachment.

6 He stayed for a while. I can't really remember how long. But

7 certainly he was with us for at least a month, after that.

8 Q. Before he left, was he at all interfering with your work with the

9 SDB?

10 A. He was interfering, depending on his daily jobs. If anybody

11 asked him for advice, to give assistance, yes, he did, in order to give a

12 constructive contribution. But I haven't observed anything negative with

13 respect to that.

14 Q. After the split of the MUP, did the Prijedor detachment remain

15 organisationally under the SDB in Banja Luka?

16 A. Yes, he did -- it did. Sorry.

17 Q. And who eventually replaced Sead Besic as the head of the

18 detachment?

19 A. In that period, nobody coordinated the work of the detachment or

20 managed the detachment until August or September; I cannot remember

21 precisely. That's when the man arrived who was appointed chief of the

22 detachment, if I may call him that.

23 Q. And what was his name?

24 A. Dusko Jelisic.

25 Q. Now, after the split of the MUP, how many detachment members were

Page 14479

1 there?

2 A. At that point in time, including Sead, I think five or six. I

3 can't remember the exact number. But I think -- I think there were five.

4 Q. Were there also reserve members of the detachment?

5 A. Yes. When I said five, I meant only active-duty staff. The

6 National Security Service, apart from this detachment, also had wartime

7 squads in its organisational structure, and they covered, conditionally

8 speaking, individual municipalities.

9 Q. Can you tell us, for Prijedor, how many reserve SDB officers were

10 there?

11 A. Well, we can't really call them officers. They were reserve

12 staff. In Prijedor, I can't give you the exact number but there may have

13 been 10 to 13.

14 Q. And what about Sanski Most; if you recall.

15 A. I think that Sanski Most had two or three people less. And that

16 applies to the other municipalities as well; Bosanski Dubica and

17 Bosanski Novi, that is.

18 Q. Now, in 1992, did you ever receive orders from the SJB Prijedor

19 chief or any other members of the SJB Prijedor police leadership

20 regarding your work?

21 A. I don't quite understand what you mean when you say "orders." To

22 which period are you referring?

23 Q. Well, I'm referring to the April-through-December-1992 period.

24 Whether you received any orders from the SJB police leadership in

25 Prijedor.

Page 14480

1 A. Well, in early May or mid-May or possibly late May we got a

2 notification from a colleague of ours, informing us that we would be

3 doing some jobs that, under the law, weren't really what we were supposed

4 to do.

5 Organisationally, it was regulated this way: It -- the line of

6 command went from Banja Luka, where the CSB was, down toward the

7 detachment.

8 THE INTERPRETER: Interpreter's note: Could the witness please be

9 asked to speak closer to the microphones. Thank you very much.

10 MR. OLMSTED:

11 Q. Mr. Rodic, we just had a notice. If you could please talk closer

12 to the microphone, as they're having a little bit of trouble catching

13 everything you're saying.

14 Yes, and we're going to talk about that instruction you received

15 down the line of command in a brief moment, but before we do, I just want

16 to talk generally. Do you recall any time between April and

17 December 1992 where the SJB Prijedor police leadership attempted to

18 interfere with your work, to somehow disrupt it, prevent you from doing

19 your job?

20 A. Not by direct orders. Whether there was obstruction of our work,

21 I don't know. But we didn't receive any direct orders to that effect.

22 Q. Now, after April 1992, what means were available to the Prijedor

23 detachment to communicate with the SDB in Banja Luka?

24 A. Well, it was reduced to regular telephone lines, but that

25 communication deteriorated and became ever-less reliable.

Page 14481

1 Q. Was there also weekly courier service?

2 A. No, there was no courier service. But when we went to Banja Luka

3 on some other business, then we would also take some mail, possibly. So

4 those of us who were -- who were personnel of that unit did that too.

5 Q. Was also a secured or specijal telephone line?

6 A. Earlier, there was the so-called special telephone which was

7 protected in some way. I don't know the details. But when wartime

8 activities approached, the telephone became unreliable. The line would

9 break down. I don't know why. But it couldn't be used much anymore when

10 combat moved closer.

11 Q. Between April and the third part of May, what work were you and

12 the other detachment members performing in Prijedor? Up until the third

13 part of May.

14 A. I apologise, but I didn't quite understand the time reference.

15 Q. Yes, I'll repeat. I'm just talking about the period between

16 April and up until the third part of May of 1992. Can you tell us what

17 work you were engaged in during that period, that one-and-a-half-month

18 period?

19 A. There wasn't much activity because the conditions for work were

20 deteriorating. It was very difficult to do that kind of work. But, in

21 late May, we started doing some jobs which we were not supposed to do

22 under the law, but the situation was such that somebody had to do it, so

23 we started doing it.

24 Q. And I think that's what I'll move on to now.

25 Were you ever assigned to work at the Keraterm camp in Prijedor?

Page 14482

1 A. Yes, that's exactly when it happened, and that's what I meant,

2 actually. The investigative centres, or camps, whichever you choose to

3 call them, started functioning, and we were assigned to work there.

4 Q. And you made a reference to this earlier, but who instructed you

5 to work at the camp of Keraterm?

6 A. He came to us personally, a colleague from Banja Luka, that is,

7 Mr. Vojin Bera. He said that he was some sort of coordinator for the

8 territory covered by the detachment, that he was there in that capacity,

9 and possibly even that he was there as the representative of the chief of

10 the security service, Mr. Kesic. He had come earlier on a few occasions

11 in that role of coordinator.

12 Q. And could you tell us, as much as you can, the substance of the

13 instructions that Mr. Bera gave to you at that time?

14 A. It was simply a conversation with the persons who were detained

15 there about the circumstances of illegal arming, the organisational

16 aspects of some combat activities that they carried out, and things of

17 that nature.

18 Q. Other than this initial instruction, did you receive any other

19 instructions or orders with regard to your work at the Keraterm camp?

20 A. There were no special orders apart from this aspect. But we

21 couldn't really speak about orders. It was simply a notification or

22 instruction that we should go out there and do that kind of work.

23 Q. How frequent would Mr. Bera visit Keraterm camp?

24 A. Well, I can't really recall that. But he did come a few times.

25 I can't give you the exact figure. But did he arrive -- arrive there a

Page 14483

1 couple of times.

2 Q. And what were the purposes of his visits?

3 A. Well, he assigned us there and we were there. But his visits did

4 not involve any advice on his part or any orders or any notifications

5 regarding our work.

6 Q. Can you tell us, how long did you work at Keraterm camp?

7 A. From the beginning to the end. So that would be the second

8 half -- or, rather, after the 20th, 25th, until the closure, and that was

9 in early August, if I'm not mistaken.

10 Q. And during this period that you were working out of Keraterm

11 camp, did you have any other duties or assignments with the SDB?

12 A. No. Or, rather, we were up there all the time.

13 Q. Who was the commander of the camp?

14 A. I think that at that time it was Sikirica. I don't know his

15 first name. But he was the camp commander, or, rather, he was seen

16 there. He would show up there.

17 Q. Do you recall the names of any other persons who worked there?

18 Shift commanders or anyone else in the leadership of the Keraterm camp?

19 A. I didn't really know these people because there was a big age

20 difference. There were two or three of them who were closer to me in

21 age, and we knew each other by sight. We would see each other in town.

22 I think it was Fustar, and later on I heard some other names, but I

23 didn't really know them.

24 Q. And what was the first name of Fustar, if you recall?

25 A. I think it was Dragan.

Page 14484

1 MR. OLMSTED: Let's quickly look P662.

2 Q. What we have in front of us is a list of police employees to be

3 given special access passes to the Keraterm reception centre. And I'm

4 showing you this to see if I can refresh your memory with regard to the

5 persons you recall.

6 If you look at number 4, we see Sikirica. Is that the Sikirica

7 that you recall at Keraterm?

8 A. I think that's the person, Dusko. Well, I -- I seem to recall

9 that his name is Dusko now that I see it written here.

10 I knew Fustar, but more or less by sight. And if you want me to

11 look at the rest of the names here; I knew Knezovic, Jakovljevic, and

12 Murinic, but I didn't see them in Keraterm itself at all.

13 Q. Did you see Fustar, Dusan Fustar, at the camp?

14 A. I think so. Yes, I did.

15 Q. Now, can you tell us, these interrogations that you conducted at

16 Keraterm, these -- with the detainees, can you tell us how those were

17 conducted?

18 A. The interviews were conducted in this manner: These people were

19 brought to us one by one, and we talked to them as much as we could,

20 given the circumstances. We took their personal details, and we asked

21 them where they were from, what knowledge they had about the activities

22 in their area.

23 Q. You -- you mentioned "we." Were there teams of interrogators at

24 Keraterm; or did you, by yourself, interview them?

25 A. There were three teams, two persons each, and this -- these were

Page 14485

1 the people who work there, in Keraterm.

2 Q. And was one member of the team from the SDB? And could you tell

3 us where the other one was from?

4 A. When all of this was set up at Keraterm, people from the public

5 and the State Security Services worked side by side. There were two

6 people from the public security, two people from the state security, and

7 two people from the reserve force of the state security or

8 National Security Service, as it be -- came to be known at that time.

9 Q. Could you give us the names of the other members of these teams?

10 A. Yes, I can give you the names. One team, so to speak, was

11 composed of Brane Siljak [phoen] and Branko Bucalo. The second team was

12 Grozdan Mutic and Gostimir Modic. The third team -- well, it was

13 Marko Radisic [phoen] and myself, Radomir Rodic.

14 Q. Would a representative from the military police ever attend these

15 interrogations?

16 A. A representative of the military police was present there. At

17 the beginning, it was more often. Up until halfway into our work he was

18 there more often, and then he would come occasionally.

19 THE INTERPRETER: Interpreter's note: The witness is kindly

20 asked to speak into the microphone.

21 MR. OLMSTED:

22 Q. Mr. Rodic, again, please, maybe move -- if you could move your

23 chair up a little bit because you're a bit far from the microphone.

24 Thank you. But we did get your answer.

25 Can you tell us, this military representative, what was his name?

Page 14486

1 A. That was Pero Tadic.

2 Q. And did Tadic -- was he the representative for all three teams?

3 A. Well, he was there. Sometimes he would be with one team or the

4 second team or the third team. But for the most part he was there. I

5 don't think that he had any choice in -- or, rather, he did not select

6 the people to be interviewed. He was just supposed to be there. That

7 was his task.

8 Q. Now, you mentioned that you were instructed to talk to these

9 detainees about - I think you mentioned arming and organisation. Can you

10 tell us what information you were trying to gather from these detainees.

11 A. We tried to obtain information about who was behind some of the

12 military activities going on in their areas, to find out whether they had

13 any knowledge of the establishment, the structure, the kind of weapons

14 they had, whether any actions were conducted, any combat actions, and why

15 and how they started their activities. Things of that nature.

16 Q. Where did you conduct these interrogations at the camp?

17 A. They were conducted upstairs in the building where the offices

18 were. That -- that was in the left-hand side of that building, if you're

19 looking from the entrance, the office building.

20 Q. Did you conduct any interrogations at night?

21 A. We worked only by day, from 7.00 or 8.00 a.m. until 4.00 or

22 5.00 p.m., depending on when we'd arrive and our stamina.

23 Q. And when you were at the camp, did you spend most of your

24 times [sic] in the interview rooms or were you walking around the camp as

25 well?

Page 14487

1 A. All of us always remained in the offices that were assigned for

2 our use.

3 Q. And who brought the detainees to the room for you to interrogate

4 them?

5 A. Well, people who were downstairs, the security detail, and

6 probably the people who are here on the list. That's probably who they

7 are, the people on the list.

8 Q. Can you tell us how many interrogations you conducted during your

9 time at the camp? If you can try to estimate them for us.

10 A. Well, I can give you a figure that I arrived at by doing some

11 simple math. Between 1500 and 1700. So it's -- all of us did that.

12 MR. OLMSTED: Let's take a look at P657.

13 Q. And what we have in front of us is the SJB Prijedor report on

14 activities in the first half of 1992, and it's dated June 1992.

15 MR. OLMSTED: If we can turn to page 8 of the B/C/S, page 6 of

16 the English. And if we look towards the bottom of the page, it reports

17 that, at least as of the date of this report, 1200 persons had been

18 detained at Keraterm. And then if we continue in the B/C/S to the next

19 page, and leave where we are in the English. And that over -- that over

20 900 people had been operatively processed in this centre.

21 Since this report was written about halfway through the life of

22 the camp, are these figures fairly consistent with or perhaps maybe a

23 little bit lower than your own calculations?

24 A. Well, I don't know. I really didn't have a good look at their

25 date. But this figure is more or less in accordance with my estimates, a

Page 14488

1 bit higher or a bit lower. But that's it.

2 Q. Can you tell us, were there civilians amongst the detainees that

3 were interrogating at the camp?

4 A. Well, it's difficult to tell who was civilian and who was not

5 because there were people in civilian clothes and people who wore

6 uniforms or parts of uniforms. So it was difficult to distinguish that

7 at first sight.

8 Q. You mentioned uniforms. How many detainees did you see wearing

9 military uniforms? Was it a large number or was it just a few?

10 A. Well, a few people who had -- who were in full uniform, but the

11 number of people who wore parts of uniforms was much higher. Let's say

12 they would wear military boots or military shirts or trousers, something

13 like that.

14 Q. Were there minors and elderly among the detainees that you

15 interrogated?

16 A. At first, when the reception centre or camp was set up, whatever

17 you want to call it, there was a certain number of minors and elderly

18 people there.

19 Q. Can you tell us approximately how many that you interviewed? Was

20 it more than 50, less than 50?

21 A. Well, more than 50, definitely.

22 Q. Now, just talking about the interrogations in general that you

23 conducted, did you write an Official Note on the information that you

24 gained through the interrogation?

25 A. Yes. A record was made of each and every interview, and we would

Page 14489

1 put into the record all the information that we obtained, and then the

2 record or report was typed up.

3 Q. And after it was typed up, do you know where it was submitted to?

4 A. We did not get it back. We never had an opportunity to read it

5 after it was typed up.

6 Q. With regard to the detainee -- the detainees that you determined

7 may have been involved in arming or organisation of armed rebellion, are

8 you aware of any criminal reports filed against those individuals?

9 A. No, I'm not. But I did hear that there were some trials, but I

10 don't know how many, and I didn't have any knowledge of that at the time.

11 Q. With regard to the -- that -- these detainees, did you ever see

12 any remand decisions from either the military or civilian courts stating

13 that these persons should be detained at Keraterm?

14 A. No, we did not see that. We did our work, and nobody submitted

15 any kind of material to us, this kind of material.

16 Q. Now, what happened to the detainees that you determined were not

17 involved in arming or organising rebellion?

18 A. At the beginning of the work -- well, there were two parts:

19 First we talked to the elderly and to minors. And, at that time,

20 they were released. And this same trend continued for some time

21 afterwards. In other words, that minors and elderly people were also

22 interviewed, and that lasted maybe some ten days. All those people were

23 later on released. They were released from the detention centre.

24 Q. And what about everyone else? Did there come a point in time

25 when no more detainees were released from the camp?

Page 14490

1 A. After that initial period, and I can't give you the dates, people

2 were no longer released from the camp.

3 Q. I understand you can't give us a date, but can you tell us

4 approximately how many days after the camp was established that this

5 occurred? Was it 10 days, 15 days?

6 A. Well, maybe some 15 days. I can't be sure about that.

7 JUDGE HALL: [Microphone not activated]

8 [Trial Chamber and Registrar confer]

9 JUDGE HALL: Yes, you -- you may continue, Mr. Olmsted.

10 MR. OLMSTED: Thank you, Your Honour.

11 Q. Mr. Rodic, do you know of instances where a detainee was released

12 in these first 15 days but then they were brought back to the

13 Keraterm camp at a later date?

14 A. Well, I gave you an example of a man who was interviewed by us

15 and then, a few days later, he showed up for another interview.

16 Q. And did you interview him a second time?

17 A. No, there was no need. We simply made a record of that fact.

18 MR. OLMSTED: Let's take a look at P583.

19 Q. Now, this is a three-page memorandum from CSB Banja Luka to the

20 minister of the RS MUP. It's dated 20 July 1992.

21 MR. OLMSTED: And perhaps we could turn to the last page.

22 Q. And if we look at the bottom of this document, we see that it's

23 signed by the CSB chief; is that correct?

24 A. What do you mean? That he signed it; is that correct?

25 Q. [Previous translation continues] ... yes.

Page 14491

1 A. Well, it says here that did he, but I can't confirm that.

2 MR. OLMSTED: If we can turn back to the first page. And if we

3 start looking at the second paragraph, it states that:

4 "Detainees at detention facilities throughout the Autonomous

5 Region of Krajina were subject to operational procedure by military

6 services, service for national and public security which then carried out

7 selection of the persons detained. After the operational procedure,

8 three categories were determined. First and second category are of

9 security interest to us, and their activity has [sic] been classified as

10 legal responsibility."

11 MR. OLMSTED: And perhaps we can turn to the second page in the

12 B/C/S, because it goes into the seconds page for the B/C/S only.

13 Q. It gives a couple examples of that, and then it states:

14 "While the third category is made of adult men on which, so far,

15 the service does not have any information of security interest for us, so

16 they can be treated as hostages."

17 Mr. Rodic, were you aware that after you submitted your

18 Official Notes of the interviews with detainees that this categorisation

19 took place?

20 A. Not at the time. A little while later, we did hear about that,

21 after everything was over. But I did not see this document at the time.

22 Q. Were you aware of who was performing this categorisation, whether

23 that was done at the SJB or at some other level?

24 A. No, I didn't know where it was done.

25 MR. OLMSTED: Let's look at P805.

Page 14492

1 And if we may just hold on a second; this is not the document I

2 want.

3 [Prosecution counsel confer]

4 MR. OLMSTED: Yes -- there it is. Now we have it on the screen.

5 Thank you.

6 Q. Now, this is a report on the work of Prijedor SNB branch for the

7 period from 1 January until 31 December 1992. And it's dated, at the

8 top, 20 January 1993.

9 Now, at the -- at the top on the right side, we see handwritten

10 two names: One is Dusko and the other one - which has not been

11 translated properly - is Bera. Who is this referring to?

12 A. I think it's the detachment chief, Mr. Vojin Bera, whom we've

13 already talked about. And he was, at that time, a line chief in

14 Banja Luka. And as for the other one, I can't remember who he is.

15 Q. Do you -- could that be Dusko Jelisic, your superior or the head

16 of the detachment later on in 1992?

17 A. Superior, not commander. Yes. That was Dusko Jelisic. He was

18 appointed as the detachment chief sometime in September.

19 Q. And we see that, below that, we see 01 and 02. So are those --

20 is that referring to the two lines at the level of the CSB SDB in

21 Banja Luka?

22 A. I assume that this was the case. There were two lines. There

23 used to be more than that, but these two are specified here.

24 MR. OLMSTED: Now, if we could turn to page 2 of the B/C/S,

25 page 3 of the English.

Page 14493

1 Q. We see that the report states that:

2 "Work in investigation centres such as Omarska, Keraterm, and

3 Krings began on 25 May 1992 in cooperation with employees of the Prijedor

4 and Sanski Most SJB."

5 So can you tell us, did this mean that Omarska camp and Krings

6 also had teams of SJB and SDB inspectors conducting interrogations

7 similar to the one you were doing in Keraterm?

8 A. I assume that that was the case because they were told that they

9 would do the same job as we were doing but at a different location at the

10 same time when we were told that.

11 MR. OLMSTED: If we can turn to page 4 of the B/C/S, page 5 of

12 the English.

13 Q. We see here statistical data collected for the work of the

14 Prijedor detachment in 1992, and you had a chance to look at this

15 document during proofing. Are these the statistics that the detachment

16 traditionally reported on in this period?

17 A. Well, these are forms that were used in the previous period,

18 maybe a year or two before this time. But the information shown here in

19 those entries are actually adapted to the existing form. So when I saw

20 this document, I realised that there were some illogical things here.

21 Because this form was no longer relevant, up to date. And then it was --

22 it continued being used and all the information was entered here, in this

23 manner.

24 Q. We see, at the bottom, it -- it lists verbal warnings. And it's

25 1790 for Prijedor, 1300 for Sanski Most.

Page 14494

1 Can you explain to us what was a verbal warning in the sense of

2 something that the SDB would issue?

3 A. As I said, this is a form which was taken over from the earlier

4 period. And this form contained some things that were possible earlier.

5 So there was this possibility of verbal warning and written warning for

6 some persons who may have been moving toward illegal activities.

7 Here, however, I suppose that the colleagues thought that they

8 had to fill in those boxes as well, because they were simply there.

9 Q. While you were at Keraterm camp, did you issue any verbal

10 warnings?

11 A. I don't know whether it would have been appropriate to issue

12 verbal warnings in wartime. To my mind, that is only applicable to

13 peacetime, that is, to the earlier period.

14 MR. OLMSTED: Let's look at page 5 of the B/C/S; page 6 of the

15 English.

16 And if we can zoom in a bit under item 9.

17 Q. And if we look at item 9, Roman numeral II, it states:

18 "KP," which I understand to mean criminal report, "filed by SJB

19 on the basis of reports from SNB."

20 Mr. Rodic, if one of the Official Notes you wrote in 1992

21 identified a potential crime which then led the SJB to file a criminal

22 report against that person, is this where it should be statistically

23 reported?

24 A. I cannot answer yes or no, but I can say that this is a -- the

25 outcome of something that was obsolete, something that was in use before.

Page 14495

1 We're talking about a wartime period here. So I don't know whether there

2 were criminal reports issued by the SNB or - what else does it say

3 here? - criminal reports filed by SJB on the basis of reports from SNB.

4 Q. And just --

5 JUDGE HALL: Mr. Olmsted, do you have many more questions in

6 respect of this document?

7 MR. OLMSTED: Just one more.

8 JUDGE HALL: Yes. The reason why I'm asking is that it is

9 necessary for us to break now. For technical reasons, we have to

10 relocate to Courtroom I. And also, it's going to take longer than the

11 usual 20 minutes, so we are going to break for a half hour.

12 So as soon as you're through with this document, we'll take the

13 break.

14 MR. OLMSTED: That sounds good, Your Honour.

15 Q. Just to clarify, do you recall, did you participate in the actual

16 creation of this particular report in early 1993?

17 A. I don't remember having participated.

18 MR. OLMSTED: That's fine, Your Honours. We could stop there, if

19 you please.

20 JUDGE HALL: Thank you.

21 So we resume in a half-hour in Courtroom I.

22 [The witness stands down]

23 --- Recess taken at 3.35 p.m.

24 --- On resuming at 4.08 p.m.

25 [The witness takes the stand]

Page 14496

1 JUDGE HALL: Yes, Mr. Olmsted, you may continue.

2 MR. OLMSTED: Thank you, Your Honours. And thank you for moving

3 us to someplace a bit cooler.

4 JUDGE HALL: I'd love to take the credit for it, but it was ...

5 MR. OLMSTED:

6 Q. Mr. Rodic, when the guards brought detainees to you for

7 interrogation, did any of the detainees appear to have been recently

8 maltreated?

9 A. Initially, there were some cases, but later it stopped.

10 Q. Can you provide us a little more detail with regard to your last

11 answer?

12 First of all, what signs of maltreatment did they have on them?

13 And then also if you could explain -- why don't you answer that one

14 first. If you could explain what kind of condition they were in.

15 A. When I speak about that, I couldn't say that they were

16 maltreated. They may have suffered a blow, or two or three, before they

17 had come to the rooms we were in. There may have been some blood in the

18 face or something of that sort.

19 Q. Now, you stated that "later it stopped." Can you explain what

20 happened, why the detainees who were brought to your interrogation room

21 no longer appeared to be recently beaten?

22 A. It simply stopped because those of us supposed to speak to those

23 people couldn't, given the circumstances. That was one of the reasons

24 when we took the position that we wouldn't speak to people in that

25 condition, and we informed the guards accordingly, and we returned some

Page 14497

1 people; that is, we didn't want to talk to them. So we let them know

2 that we wouldn't work under such circumstances.

3 Q. Did you ask the detainees who had maltreated them?

4 A. I said that I wouldn't call it real maltreatment. But they

5 seemed to have suffered blows to the face, possibly by the people who had

6 brought them to us. But I couldn't give you any names.

7 Q. Now, you don't know whether, after you interviewed detainees and

8 they were returned to the rooms where they were being detained, whether

9 they were abused at those locations?

10 A. I don't know of such cases, but under the circumstances, we

11 wanted to prevent that from happening, and we simply escorted them to a

12 staircase from which they would exit to the open.

13 Q. And if could you explain. You escorted them just to the -- the

14 staircase. Why did you just escort them to that location?

15 A. That was a location where they were left alone; that is, there

16 were only the man who brought him and the one who was to be interviewed.

17 And by acting like this, we wanted to prevent such things. And we didn't

18 want to be accused of having talked the guard into treating the people

19 like that.

20 Q. So if I understand you correctly, you didn't want the beatings to

21 be in any way attributed to you personally?

22 A. Of course. And not just personally, but also indirectly, such as

23 that we had persuaded anybody to do so or instigated or whatever.

24 Q. Now, did you include information about these beatings that you

25 could infer from the condition of the detainees you interviewed; did you

Page 14498

1 include this information in your Official Notes or your reports?

2 A. That went on very briefly. And I believe that it was more

3 efficiently taken care of this way than if we had made notes of that in

4 reports of any kind.

5 Q. When Vojin Bera visited Keraterm, did you and the other SDB

6 officers inform him about these beatings, that they had occurred?

7 A. I don't remember him coming during that period, but it soon

8 stopped. Any ways, I cannot remember with certainty whether we met him,

9 but it only went on for a couple of days and then that practice stopped.

10 Q. Other than the beatings, how were the conditions at the camp for

11 the detainees?

12 A. As I said, I didn't go to their premises. But, from what we

13 learned from the interviews, they seemed to sleep on wooden floors, that

14 they were only fed two meals a day, that there were no hygienic

15 facilities, and the like.

16 Q. And did you write reports regarding the poor conditions at the

17 camp for the detainees?

18 A. I don't think so. But the reason for that is simple. We thought

19 that it was somebody else's responsibility; that condition, I mean.

20 Those circumstances.

21 We were only involved, I won't say illegally, but it wasn't the

22 priority, our priority. It wasn't the focus of our work. And I mean --

23 when I say that, I mean both public security or state security.

24 Q. Well, when Mr. Bera would visit the Keraterm camp, did you

25 mention to him about the poor conditions that the detainees were

Page 14499

1 experiencing?

2 A. Well, I don't really remember. But that was something anybody

3 could observe. It wasn't anything that would go unnoticed, if you went

4 to that place.

5 Q. Now, other than Mr. Bera, who else from the police leadership

6 visited Keraterm camp while you were stationed there?

7 A. I cannot say with certainty who visited the camp. I told you

8 where we were. But, by chance, we heard the voice of the late

9 Simo Drljaca from the hallway. But that was only once while we were

10 there, during the period while we worked there. Whether he came there on

11 other occasions when we were not there, I don't know.

12 Q. What about the CSB chief, Zupljanin?

13 A. I don't quite understand. Chief of what?

14 Q. The CSB chief. Do you recall him coming to Keraterm camp while

15 you were there.

16 A. Well, I said in the investigation that I once heard sounds of

17 cars, a number of cars, and I could tell that there must have been a

18 delegation. I'm not sure who was there, but I remember one of the guards

19 saying that Mr. Zupljanin was one of those who had arrived. I haven't --

20 I didn't see him on that occasion though.

21 Q. Can you tell us approximately when that visit occurred?

22 A. No, I cannot remember the exact date, but it may have been

23 somewhere midway through the period when the camp was operating. But I

24 really can't be more specific than that.

25 Q. Do you recall an incident in late July in which a large number of

Page 14500

1 detainees were killed in and around one of the rooms at Keraterm camp?

2 A. I remember the event.

3 Q. In the days immediately prior to that incident, do you recall a

4 large number of civilian detainees coming to Keraterm camp?

5 A. I don't know whether a large number of civilians came. If you

6 mean the people who were detained down there ...

7 Q. That's what I mean. Detainees. Do you recall any -- a group of

8 civilian detainees coming in around the time of this -- just prior to

9 this incident?

10 A. I cannot remember whether anybody came a day or two or three

11 before that incident. But given the exact location of our premises, we

12 often even failed to notice that anybody had brought in detainees.

13 Q. In the days before this incident, did you notice anything unusual

14 at the camp?

15 A. No, I didn't notice anything. Everything seemed as usual.

16 Q. And if could you please tell us, how did you first learn about

17 this killing incident?

18 A. I learned about that incident in the morning when we set off for

19 work. We used to gather in front of the MUP building daily and then

20 drive there in one or two cars. Then one of the guards told me or a

21 group who was standing there that there had been an incident at Keraterm

22 and that people had been killed.

23 Q. You mentioned you were outside the MUP building. Is that the SJB

24 building in Prijedor?

25 A. Yes. That's the building of the SJB today, just as it was then.

Page 14501

1 And at the time, our offices were there, that is, down-town, not far from

2 the municipality building.

3 Q. And you mentioned that one of the guards told you about the

4 incident. Was that guard a member of the SJB?

5 A. He was the man who was securing the SJB building. He may have

6 given over his shift to the following guard. And I think that he was --

7 he was a police officer.

8 Q. Now, after you heard about the killings, did you go to Keraterm?

9 A. Yes. We went there, trying to do our work. We didn't know what

10 had happened.

11 MR. OLMSTED: If we could have on the screen 65 ter 3419.45. And

12 this is an aerial photograph.

13 And I'm going to ask the witness to mark a few things on this

14 photograph, so perhaps he could be instructed on how to use the -- the

15 pen.

16 Q. All right. Now, this is a fairly recent photograph, but do you

17 recognise what is depicted in this photograph as Keraterm?

18 A. Yes, I recognise the area.

19 Q. Now, when you arrived at Keraterm camp on the day following the

20 incident, what did you see?

21 A. What we could observe immediately was the large number of -- or,

22 rather, the stronger security.

23 When we moved closer to the entrance that we usually used, I

24 noticed two or three dead bodies that were in our field of sight.

25 Q. Can you mark with a letter A where you saw the corpses.

Page 14502

1 A. That would be round about -- no, I wasn't able to mark it

2 properly.

3 How do we delete this?

4 MR. ZECEVIC: I'm sorry, I believe the witness wants that this be

5 erased and -- so he can make a proper ... yeah.

6 MR. OLMSTED: Yes. Could we do that, please, just erase -- there

7 we go.

8 Q. There, Mr. Rodic, give it another try. Put in a letter A.

9 A. It was round about here. Well, the A isn't -- hasn't really

10 turned out right.

11 Q. Yes. Mr. Rodic, you're not the first witness to have trouble

12 with this device. But I think that's -- I think we see -- well, now it's

13 becoming a scribble.

14 Let's try it one more time. Make a large A and that way there's

15 no question.

16 A. [Marks]

17 Q. There we go. Perfect.

18 A. Yes, I've tried again.

19 Q. Now we can see a road running alongside Keraterm camp. Were the

20 bodies visible from that road?

21 A. I don't know if you mean the main road, the highway, whether it

22 could be seen from the main road, which is here in the immediate

23 vicinity.

24 Q. Yes, we see a road that comes quite close to the camp. It looks

25 like a main road.

Page 14503

1 A. Yes. But, at that time, some of these buildings, the blue ones,

2 weren't there. And -- well, they were -- those that were there, they

3 were about some 30 metres away or so.

4 Q. Now, you mentioned that this was increased security that morning

5 that you arrived. Can you tell us, who did you see there? Was it

6 police? Was it military?

7 A. Well, I think that I did see some policemen. I wasn't clear at

8 the time whether these were the police who had been there or whether this

9 was something else. I didn't know that.

10 Q. And what did you see the police doing at that time? What kind of

11 activities were they undertaking?

12 A. Well, nothing of note. They were standing there individually or

13 in small groups, heading -- well, at the road, or near the road, and near

14 the gate itself.

15 Q. And once you arrived at the camp, where did you go?

16 A. We went to the office where we worked.

17 Q. And can you put a -- a letter B where your offices were located.

18 A. Well, it's difficult to mark them with just one letter, because

19 you could see the police here in this area, where this letter A ends.

20 They were in smaller groups. Some were standing apart from the others.

21 But this is where they were standing.

22 Q. That's fine. Actually, could you put a B, a letter B, where your

23 offices are located because you've mentioned that you conducted

24 interrogations there. If you could just tell us -- just show with us a

25 letter B where approximately those would be located.

Page 14504

1 A. Well, I'll try.

2 Q. Very good. And how long did you stay in your office that day?

3 A. Well, I don't know. An hour, an hour and a half at the most.

4 Q. And then what -- what did you do after that?

5 A. We went back home because we considered that we did not even have

6 the minimal working conditions there.

7 MR. OLMSTED: May this be admitted into evidence, Your Honours.

8 JUDGE HALL: Admitted and marked.

9 THE REGISTRAR: As Exhibit P1582, Your Honours.

10 MR. OLMSTED:

11 Q. Now, Mr. Rodic, when was the next time that you returned to the

12 camp after the morning following the incident?

13 A. I think that it was on the third day. We went there on that day,

14 when -- we went back, and then the day after that we didn't go, so I

15 think it was the third day.

16 Q. And when you returned to the camp on that third day, did you see

17 any remains of the killings that occurred on that night of the -- in

18 July, either blood or anything else like that?

19 A. No, we didn't see anything because we took the same route, and

20 you couldn't see anything from there. And I can see that the two or

21 three bodies that I had seen before were no longer there, and I think

22 that a number of police officers went down to what it was before, the

23 usual number.

24 Q. In the days that followed this incident, did you ask the

25 detainees about what had happened that night?

Page 14505

1 A. The first working day after that, we tried to talk to the people

2 to ascertain what had happened and how and why it had happened.

3 Q. And why did you do that? Was this an assignment given to you, or

4 were you just curious?

5 A. I don't think that anyone asked us to do that. We just wanted to

6 know for ourselves. We wanted to see what had happened.

7 Q. Did any of the detainees mention anything about smoke to you, on

8 the night of that incident?

9 A. Well, that's what's interesting. We talked to a large number of

10 people, and their statements differed. Some said that they hadn't seen

11 or heard anything; some said that there had been some shouting and some

12 shooting.

13 THE INTERPRETER: Interpreter's note: The witness is kindly

14 asked to repeat the last few words of his answer.

15 MR. OLMSTED:

16 Q. Could you repeated the last few words of your answer. The

17 interpreters missed it.

18 A. My apologies.

19 We tried to talk to those people, and their statements differed.

20 Some said that they had not heard or seen anything. Some said that there

21 had been some racket inside a room. Some said that there had been some

22 racket outside. And, among other statements, one of the people said that

23 there had been some smoke. I don't know who that person was who said

24 that.

25 Q. And with regard to the person who mentioned the smoke, did he say

Page 14506

1 anything about how the smoke affected them? Could you tell us what kind

2 of smoke it was?

3 A. Well, I think that he said there was some smoke and that it

4 irritated their eyes. That's how he described it.

5 Q. According to the information you received, approximately how many

6 detainees were killed that night?

7 A. Later on, the number was approximately more or less as it turned

8 out to be. But, at that time, the figures, the estimates, varied between

9 dozens to hundreds. And then we received information from our colleagues

10 that it was about 150 to 170 people.

11 Q. And did you write any reports about this incident?

12 A. No. We did not write any reports because it was not a part of

13 our job. And we also considered that we were not responsible for the

14 security of the facility and that those who were in charge of that

15 segment should do it.

16 Q. In the days and weeks that followed this incident, did you see

17 any activity at the camp that suggested to you that a criminal

18 investigation was taking place?

19 A. I didn't see anything of the sort, anything that might indicate

20 that there was an investigation going on, and none of my colleagues did

21 either. And, now, whether there was an investigation or not, I can't

22 really tell you.

23 Q. Now, did Mr. Bera, Vojin Bera, visit Keraterm any time following

24 this killing incident?

25 A. I think that he came there a few times, over a few days. And

Page 14507

1 when he came, he knew what had happened.

2 Q. And how do you know that he knew what happened?

3 A. Well, as I've already said, it was impossible not to see it.

4 Everybody in Prijedor knew that, perhaps even in the broader area. So I

5 knew that when he came there he knew it, because there had been talk

6 about that, so he must have known.

7 Now, I don't think that he knew how it happened, but he was aware

8 of the incident.

9 Q. And you mentioned that there was talk about the incident around

10 Prijedor. Do you recall hearing talk about the incident around

11 SJB Prijedor?

12 A. Well, I don't know if I spoke to him about that, but something to

13 the effect that it happened there. But this was not based on any

14 knowledge of somebody who was there and who saw it; it was based more or

15 less or hearsay, rumours.

16 Q. I understand that. And I want to move past Mr. Bera.

17 In the days that followed this incident, when you were at

18 SJB Prijedor, either in -- first thing in the morning or otherwise, did

19 you hear talk about this particular incident within the SJB building?

20 A. In that period, I did not enter the station. We stayed in front

21 of the station for a very short time, until all of us who were supposed

22 to go up there gathered. So I wasn't in a position to see or hear

23 anything of the sort.

24 Q. Now I want to talk more generally about what you observed had

25 happened at Keraterm, whether it's the -- this particular incident or

Page 14508

1 more in general the beatings that you learned about that had occurred

2 there, as well as the conditions.

3 In 1992 or the years that followed, did the CSB ever interview

4 you concerning any crimes committed against the detainees at Keraterm

5 camp?

6 A. Nobody talked about that with me, and my knowledge at the time is

7 the same as my knowledge now.

8 JUDGE DELVOIE: Mr. Olmsted, before you proceed, do we have --

9 it's about this -- this killing incident we talked about. Do we have a

10 date for that, a specific date? Did the witness give a specific date for

11 that incident, or do we have that, do we have a name for that incident?

12 MR. OLMSTED: Well, let's -- yes, we do. Let me ask the witness

13 first. And then we do have some adjudicated facts on this incident.

14 Q. Sir, do you recall the date that this killing incident occurred

15 on?

16 A. I can't recall the exact date, but I think it was in the second

17 half of June.

18 Q. Do you mean --

19 JUDGE DELVOIE: [Overlapping speakers] ... June?

20 MR. OLMSTED:

21 Q. Do you mean June or July? Just to clarify that.

22 A. June. I think it was June.

23 Q. Well, I know it's been a while, but is it possible -- how soon

24 after that incident did the camp close? Was it within a few weeks of the

25 camp closure or was it significantly before it?

Page 14509

1 A. Maybe a month or slightly more than a month. I really can't

2 recall the exact date, but I know there was this incident. I don't know

3 if I have the right time-line for the incident and all that.

4 Q. Do you recall -- the victims of this crime, this -- these

5 killings, do you recall which room at Keraterm they were detained at? I

6 believe there was four rooms at Keraterm. 1, 2, 3, and 4. Do you

7 remember which room?

8 A. I didn't know that. Later on I heard about room number 3, and

9 people spoke about room number 3, and I didn't know which one it was.

10 MR. OLMSTED: And, Your Honours, that's just a reference to the

11 particular incident which is charged in our indictment. And also we do

12 have adjudicated facts on the date of it.

13 Q. I want to now ask a few questions, more generally, about what was

14 happening to the non-Serb population in Prijedor outside of the camps.

15 In the period from May through August - and we know in that

16 period you were exclusively at Keraterm camp - but what did you hear

17 about what was happening to the non-Serb population in Prijedor? In

18 other words, what kind of crimes were being committed against them?

19 A. Well, I said that I couldn't be more specific about that. I said

20 that I had heard some of the things or -- from the family, or friends,

21 and even from the people who were down there in the detention centre,

22 that there had been some killings, things like that. But that's what I

23 heard in this context. And from people like that, from this kind of

24 people.

25 Q. And how frequently would you hear such things from either your

Page 14510

1 friend, your neighbours, or the detainees at the detention centre?

2 A. Well, it's difficult to estimate. There were those rumours.

3 Some were authentic; some had been just rumours, nothing more than that.

4 So I can't really tell you how often it happened. Sometimes I wouldn't

5 hear anything for two or three days, and then I would hear one and the

6 same story over and over again in a single day.

7 MR. OLMSTED: Let's take a look at P688.

8 Q. Now, what we have in front of us is a security assessment for

9 Prijedor municipality by SNB Banja Luka -- well, we don't have the right

10 English on the screen, so we'll wait for that. There we go.

11 And we see it's by operative Dusko Jelisic, and it's dated

12 23 October 1993.

13 Mr. Rodic, in the preparation of these kinds of reports, these

14 assessments, were you typically consulted by Mr. Jelisic?

15 A. Well, in some segments, probably, yes, in some elements where I

16 worked. But I don't really know to what extent, to what degree. I can't

17 really recall.

18 MR. OLMSTED: Let's turn to page 2 of the B/C/S and the English.

19 Q. And I want to draw your attention to the -- it looks like the

20 third paragraph. And it states that:

21 "As a result of armed conflicts between the Serbian People, which

22 had taken power, and the non-Serbs, dozens of villages have been almost

23 completely destroyed and left uninhabited."

24 It then lists a number of villages in Prijedor. Can you tell us,

25 these villages that are listed, are they non-Serb villages?

Page 14511

1 A. The villages listed in the first set of brackets, I think these

2 are, for the most part, villages inhabited by Muslim and Croat

3 majorities.

4 Q. And then it lists a number of villages which were partly

5 destroyed, and it puts them in a parenthetical. Can you tell us whether

6 the parts of these villages that -- which were destroyed, were they

7 non-Serb parts or Serb parts that were destroyed?

8 A. I think this was a mixed population, and the ratio varied from

9 village to village.

10 Q. Yes, I -- we understand that those would be mixed villages, but

11 it says they were partially destroyed. And can you tell us, were -- the

12 parts that were destroyed, were they Serb parts or non-Serb parts?

13 A. Well, the assumption is that this is a reference to parts that

14 were not Serb property, that did not belong to Serbs.

15 Q. Now it states in the next paragraph that:

16 "According to estimates, roughly 38.000 Muslim and Croat citizens

17 have left the municipality of Prijedor so far."

18 So as of October 1992, the date of this report, that many

19 non-Serbs had left the municipality. Do you go with that estimate?

20 A. Well, this is an estimate, and I can't really argue whether it is

21 correct or not. I can't really confirm it. I don't know what

22 methodology was used to produce this estimate. But I think it's more or

23 less accurate.

24 Q. By the end of 1992, how many non-Serbs remained in Prijedor

25 municipality?

Page 14512

1 A. I couldn't give you that figure. Only estimates can be produced,

2 but I didn't really look into that. A certain number remained. Now, I

3 can't tell how many.

4 Q. Mr. Rodic, in 1992, did you hear about an incident where

5 non-Serbs were killed outside of Manjaca camp?

6 A. Yes. On one occasion, I heard about an incident a few days after

7 it actually occurred. I heard that a certain number of people from

8 Prijedor had been killed outside of the Manjaca camp.

9 Q. And where did you hear this from?

10 A. Well, I don't know. There were rumours to that effect in town.

11 I really can't tell you where, from whom. But this was after the event.

12 Well, there might have been some reports in the media. Maybe there was

13 some response by the politicians, the leadership, the police leadership.

14 I don't know, really. I can't really say. But I do know that I heard

15 about it.

16 Q. And according to what you heard, who was responsible or who

17 committed -- who committed these killings?

18 A. Well, allegedly, it was the police from Prijedor who had been

19 escorting a convoy heading from Manjaca.

20 Q. I just have one more document to show you.

21 MR. OLMSTED: If we could have on the screen P685.

22 This is a dispatch from CSB Banja Luka to all SJBs, dated

23 9 October 1992. If we look at the handwriting in the upper right of this

24 dispatch, we see the names Mijic and Jelisic. Can you tell us who this

25 Mijic was?

Page 14513

1 A. Ranko Mijic. I assume that that would be him. I can't see --

2 yeah, Dusko Jelisic. I suppose that it's all about the two of them.

3 Q. And do you recall, was -- Ranko Mijic, was he employed by the

4 SJB Prijedor in 1992?

5 A. Ranko Mijic worked in the public security department -- service.

6 I don't know where, whether he was the chief of the crime police. At one

7 point, he was the chief. I think that this was the period while he was

8 the chief of the crime police.

9 Q. Now, this dispatch requests the collection of information

10 regarding war crimes. Do you recall receiving these instructions either

11 in writing or through Jelisic in 1992?

12 A. Well, I can't rule out the possibility because this is the period

13 when we stopped working in Keraterm and we were back in our offices.

14 It's possible that something like that happened, but I can't really be

15 specific in my recollection. If something was done, probably I may have

16 done something. But I can't really say because it was a long time ago.

17 MR. OLMSTED: No further questions, Your Honour.

18 MR. KRGOVIC: I will start, Your Honour.

19 Cross-examination by Mr. Krgovic:

20 Q. [Interpretation] Good afternoon, Mr. Rodic. I am Dragan Krgovic,

21 representing Stojan Zupljanin's Defence, and I will be asking you some

22 questions relating to your evidence today.

23 We speak the same language. I would kindly ask you to wait for a

24 while before answering my question for the interpreters to be able to

25 interpret both my question and your answer properly.

Page 14514

1 Mr. Rodic, you were in the State Security Service, as it was

2 known in peacetime, before the war events in Prijedor. And, at that

3 time, the service had its own chain of reporting, and you reported up

4 this chain to the State Security Service, along the state security line,

5 so to speak, the professional line. Is that correct?

6 Your answer was not recorded.

7 A. No, I was making a pause.

8 Yes, yes.

9 Q. You can see the little cursor in front of you on the screen.

10 When it's stopped, can you start your answer.

11 A. Yes. Okay. I can see it now.

12 Q. And this chain of command and chain of reporting followed the

13 line of work, as we used to call it, in the former Yugoslavia?

14 A. Yes, precisely. You reported up the line of work, and this

15 included the centre itself, the state securities -- the State Security

16 Services Centre.

17 Q. When you started doing some investigative work at the Keraterm

18 reception centre, with regard to the kind of work that you had done until

19 then, the notes and reports that you made, you didn't send up the line of

20 work?

21 A. No, we didn't. And the teams were mixed teams.

22 Q. And, effectively, that's how the chain of reporting was severed.

23 And you were actually directly subordinate to the SJB of Prijedor and

24 worked under their authority.

25 A. We reported that way. The closer the war drew --

Page 14515

1 THE INTERPRETER: Could the witness please repeat. We didn't get

2 that.

3 MR. KRGOVIC: [Interpretation]

4 Q. I apologise, but you will have to repeat your entire answer

5 because the interpreters didn't hear you.

6 A. During that period, the lines of communication at Banja Luka

7 were -- didn't function properly, and the ...

8 THE INTERPRETER: The interpreter didn't understand the second

9 sentence.

10 MR. KRGOVIC: [Interpretation]

11 Q. My question was complex and so was your answer, so I'll break

12 down my question.

13 The statements that you took and the notes you made, you left

14 them with that team with whom you worked, and that's where your

15 connection to the further flow of information ended; right?

16 A. Yes.

17 Q. The Prosecutor also asked you whether you know that criminal

18 reports were filed, and he showed you the statistical report.

19 I will show you a document; namely, Exhibit 2D03-1193.

20 MR. KRGOVIC: [Interpretation] I'll repeat: 2D03-1193.

21 Q. Mr. Rodic, this is a criminal report which was filed by the

22 Prijedor SJB against a number of persons, and it was filed with the

23 first-instance public prosecutor's office.

24 Now take a look at this first page. There are 13 names.

25 MR. KRGOVIC: [Interpretation] And can we please see the following

Page 14516

1 page.

2 Q. You see the persons mentioned here.

3 MR. KRGOVIC: [Interpretation] And let us please see the following

4 page, which is at page 3 in the Serbian version.

5 Q. Mr. Rodic, this is a criminal report filed against 39 persons,

6 all in the same report. And if you look at the qualification of their

7 crimes, it -- it is armed rebellion and, later on, attack on an official

8 on duty.

9 Basically it was your task to take statements from these persons

10 to find out what kind of role they played in the armed rebellion or

11 whether they took part in the incidents in Kozarac and Hambarine which

12 triggered all this avalanche; right?

13 A. We didn't really take written statements here, but we only

14 drafted Official Notes. Whether or not later on somebody did that, I

15 don't know. I heard that some criminal reports were filed, but I didn't

16 know that it was like this, nor was I aware of its scope.

17 Q. If I understood you correctly, it wasn't your job to take these

18 persons' statements, but to interview them and make a note. Now, you

19 didn't ask those persons to sign it; right?

20 A. Where I was, we only worked with Official Notes, and that's where

21 our contact with those written materials ended.

22 Q. That means that the persons who came to you didn't sign

23 statements but you only made an Official Note of the interview?

24 A. Yes. And it was only transmitted in this form, the form of an

25 Official Note.

Page 14517

1 MR. KRGOVIC: [Interpretation] Could we now please see the last

2 page of this document, which is page 6.

3 Q. Take a look at the last paragraph, where we see that

4 Official Notes were made. Just as you said.

5 So statements weren't taken from these persons, but, rather,

6 Official Notes were attached.

7 A. That is possible. I haven't seen this before.

8 MR. KRGOVIC: [Interpretation] Could we please see page 3 again.

9 Q. Take a look at the paragraph. Above "the reasoning," it says

10 that:

11 On 24 May 1992, around 1430 at Jakupovici, on the main road

12 Banja Luka-Prijedor, these persons carried out an armed attack on a

13 military column when Jova Zgonjanin, a soldier, was killed.

14 Do you remember that this was a matter of interest to you to see

15 who took part in that attack?

16 A. Yes, I think that this column was also discussed, that some of

17 the detainees were interviewed about that. But I cannot say with

18 certainty what person this was about. But, certainly, this incident was

19 also of interest.

20 Q. You remember that while taking the statements you also received

21 information about armed units and their activities?

22 A. Yes. We did get such information about units and possibly some

23 activities of theirs and such.

24 Q. And you certainly put that down in your Official Notes.

25 A. Yes, we did. Information about persons, their weapons, their

Page 14518

1 organisation, and anything that related to that unconstitutional or

2 illegal activity.

3 Q. If you take a look at page 4 --

4 MR. KRGOVIC: [Interpretation] Could we please see it.

5 Q. Down by the bottom of the page. The members of public security

6 were offered to sign a declaration of loyalty to the MUP.

7 MR. KRGOVIC: [Interpretation] And could we then please see

8 page 5.

9 Q. Now I'm reading:

10 "Staff of Muslim ethnicity from the police department of Kozarac

11 was subject to pressure -- or, rather, pressurised not to sign the

12 loyalty declaration."

13 Do you remember that?

14 A. I don't remember this specific instance, but we focussed on --

15 our -- we focussed our attention on any person of Serb or Muslim

16 ethnicity who seemed to exert negative influence.

17 Q. This incident which happened on 25 April was a prelude to the

18 events in the Prijedor municipality; right?

19 A. I think that was one of the events that triggered some those

20 activities. There were more, but this would have been the culmination.

21 MR. KRGOVIC: [Interpretation] Your Honours, I seek to tender this

22 document into evidence. Given my line of questioning, I will tender only

23 one criminal report as an example. I will not tender all others. It

24 will serve as an example of the way they worked at the time and the

25 Official Notes which are included in this criminal report.

Page 14519

1 MR. OLMSTED: Well, Your Honours there seems to be a lack of

2 foundation here. There's no evidence here that these persons listed in

3 this criminal report were detained at Keraterm, whether they were

4 interviewed by this witness or one of the teams at Keraterm. And we have

5 to recall that the issue that I believe was at the start of Mr. Krgovic's

6 questions was whether the information they were obtaining at Keraterm

7 somehow made it into or resulted into a criminal report, and that has --

8 that link hasn't been established in this document. The Prosecution is

9 not contending that -- that non-Serbs were arrested and criminal reports

10 were filed against them in 1992, and that's really all this shows.

11 And with regard to the last line of questions, this witness has

12 said that doesn't require the incident -- he doesn't recall the incident

13 that Mr. Krgovic is referring him to.

14 So I don't think the foundation is established for this document.

15 MR. KRGOVIC: [Interpretation] Your Honours, I don't want to go

16 into details now. I can show this document to the witness again and ask

17 him, Do you remember this person, or that person, but that would be a

18 waste of time.

19 My line of questioning was why the witness took part in these

20 activity, what the purpose was, and what happened to these

21 Official Notes. And now we see that the Official Notes are included in

22 this part. That's in line with what the witness said, that they didn't

23 take statement, only made notes. At least his part of the team. And he

24 remembers the events and the testimonies of the people who participated

25 in these events. Maybe not specifically, but he remembers on a -- at a

Page 14520

1 general level.

2 So I believe that there is a -- a link.

3 MR. OLMSTED: Yes. But. Your Honours, he hasn't shown one part

4 of this document that mentions Keraterm or that any persons in here was

5 detained at Keraterm. So -- and this witness had very little additional

6 information to add with regard to this document other than maybe he

7 recalls a few of the events that it reports on. And those events I

8 believe are already in evidence.

9 JUDGE HALL: Mr. Krgovic, doesn't it appear that this document

10 is, as it were, just there, in relation to this witness's testimony?

11 There's no nexus, is there, apart from his general awareness of the

12 events to which it speaks?

13 [Defence counsel confer]

14 MR. KRGOVIC: [Interpretation] Your Honours, the Defence submits

15 that the purpose of these Official Notes and the events that the witness

16 remembers were used to produce these -- this criminal report, and that

17 was the -- the work of the state security and the public security. The

18 people who were brought in for investigation were brought in for a

19 reason, namely, participation in armed rebellion. And that's what I want

20 to prove through this document. I can go through this document and show

21 the witness some names to hear whether he remembers the people or the

22 events, but I was trying to save time.

23 MR. OLMSTED: Well, Your Honours, this is precisely it because

24 this witness has given evidence that he doesn't have any recollection of

25 any of his -- any of the information contained in his Official Notes

Page 14521

1 making it into a criminal report or resulting in a criminal report filed

2 against any of the detainees. He said that heard that down the road

3 maybe there was some, but that's all he knew.

4 This document doesn't get us any further to where the Defence

5 wants to go because there's nothing in here that mentions that these

6 persons were detained at Keraterm or that this witness was the one who

7 interviewed them.

8 [Trial Chamber confers]

9 JUDGE HALL: Mr. Krgovic, you may succeed in persuading us that

10 this document should be admitted, but the link is not yet established,

11 not through this witness at this point.

12 MR. KRGOVIC: [Interpretation]

13 Q. Mr. Rodic, let me just ask you the following: The purpose of

14 your stay in Prijedor was -- sorry, at Keraterm, was that you, as a part

15 of a team, collect information about armed rebellion and the organisation

16 and structure of what was then called paramilitary units of the Muslim

17 and Croat side?

18 A. Yes.

19 Q. And, as part of your work, you made Official Notes, precisely

20 about those circumstances, arming and some incidents involving fire-arms?

21 A. Yes, arming, procurements, and armed incidents --

22 THE INTERPRETER: Interpreter's note: The witnesses is kindly

23 asked to speak into the microphone.

24 JUDGE HALL: Mr. Rodic, again, the interpreters need you to speak

25 into the microphone.

Page 14522

1 THE WITNESS: [Interpretation] I do apologise.

2 MR. KRGOVIC: [Interpretation]

3 Q. And you took statements about the military organisation in the

4 Kozarac area?

5 A. Yes. In Kozarac, among other areas.

6 Q. And in this context, you also investigated the activities of

7 Sead Cirkin from Kozarusa and the group that was organised in Kozarusa;

8 is that correct?

9 A. I remember Cirkin from this list because he was a leader of this

10 whole effort and the master mind. I remember him. I don't remember the

11 others. And I remember that even Bosniaks said that this was a person

12 with a murky past who threatened them too. So this is all I remember.

13 If, perhaps -- no, I'm sorry, I think that Cirkin was, in fact, a

14 serviceman in the army, and the other one was Kusuran.

15 Q. Could you please look at page 1 of this document. I think we are

16 talking about the person listed under number 2 here.

17 Suljo Kusuran.

18 A. Yes, yes, he had this murky past, and he acted in a brazen

19 manner. And I think that Cirkin was, in fact, a military serviceman and

20 that he dealt with the military organisation. I don't remember any of

21 the others, given that a long time has passed.

22 Q. So in the notes that you took, those two persons were identified

23 as the master minds of this group?

24 A. Yes. I think that the Bosniaks, mostly Bosniaks, spoke of them

25 in those terms, saying that they took part in the logistical effort and

Page 14523

1 the other one perhaps in the military part. Perhaps I don't recall

2 exactly, but it was mostly in that sense; that's how they were

3 characterised.

4 Q. And this information, you wrote them down in your notes?

5 A. Yes, if we obtained this information, we recorded it.

6 MR. KRGOVIC: [Interpretation] Your Honours, I believe that we

7 have established a basis for the tendering of this document because

8 the -- the witness spoke about the investigation carried out regarding

9 these two persons who are mentioned here.

10 MR. OLMSTED: Your Honour, we're no closer to the link that needs

11 to be established here. We seem to be going in circles, in fact.

12 If the Defence is interested in what happened in Kozarac in 1992,

13 he certainly can ask the witness what happened and what information he

14 obtained from detainees at Keraterm. That's completely fair questioning.

15 But here is a document, again, a criminal report, that should show no

16 connection between the work that this witness did and the result of this

17 report because there's no link that says that this report was filed based

18 upon interviews conducted at Keraterm.

19 JUDGE HALL: Anyway, it's time for the break. We would rule on

20 the application to admit it when we return in 20 minutes.

21 [The witness stands down]

22 --- Recess taken at 5.26 p.m.

23 [The witness takes the stand]

24 --- On resuming at 5.55 p.m.

25 JUDGE HALL: I should preface the promised ruling by saying that,

Page 14524

1 reluctantly, we are persuaded, Mr. Krgovic, that the document may be

2 admitted and marked at this stage.

3 THE REGISTRAR: As Exhibit 2D108, Your Honours.

4 MR. KRGOVIC: [Interpretation] Your Honour, I apologise, I have

5 some computer problems here, so I don't have LiveNote on my screen, but

6 we'll be using the main screen.

7 Q. Mr. Rodic, the Prosecutor asked you about the number of

8 statements taken -- or, rather, I apologise, the number of persons that

9 you interviewed over a certain period of time. And now I will show you

10 this document again.

11 MR. KRGOVIC: [Interpretation] Could the witness please be shown

12 Exhibit P657. I need page 8 in the Serbian version.

13 Q. And here, it is stated that over 200 -- or, rather, 900 persons

14 were processed, operatively, and I think that based on your testimony

15 that's what you said, that this is the number of persons -- the

16 approximate number of persons that were interviewed?

17 A. When I said that, I meant exclusively the Keraterm area. So if

18 this document was dated sometime in the middle of that period the -- the

19 total figure was a bit higher.

20 Q. To the best of your recollection, could you give us an estimate

21 for the overall period?

22 A. Well, I told you that I couldn't give you the exact number. We

23 didn't have any statistics. But the number was about 20 to 25 interviews

24 a day, three teams, over a period of maybe 65 days or so. So this was

25 the methodology that I used, pure mathematics. But I can't give you the

Page 14525

1 exact figure because we didn't keep accurate records.

2 Q. Mr. Rodic, the Prosecutor asked you about the situation in

3 Prijedor on the eve of the war and all the other activities there. My

4 question is: From the 13th [as interpreted] of April when Prijedor was

5 declared a Serb municipality, when the military and other forces took

6 over some of the positions there, until the incidents in Hambarine and

7 Kozarac and the attack on Prijedor, there were no clashes, no conflicts

8 in the area of the municipality of Prijedor?

9 A. I cannot recall any significant clashes. There may have been

10 some incidents but no conflicts, no clashes.

11 MR. OLMSTED: I just note for the record that it says the

12 takeover was on the "13th of April." I think he meant to say the

13 "30th of April."

14 MR. KRGOVIC: [Interpretation] Unfortunately, I don't have

15 LiveNote, so I cannot follow the transcript. But, yes, the

16 30th of April.

17 Q. And when these people were brought in for questioning in the

18 reception centres, this was the result of the combat operations in those

19 areas from which those people were?

20 A. Well, some of the activities pertaining to the bringing of these

21 people into custody started after those events and with those events.

22 But the establishment of the centres, well, this tells you everything you

23 need to know. They were established on the 25th of May, if I got it

24 right.

25 Q. And before that date, there was no fighting. So before those

Page 14526

1 attacks in Hambarine and Kozarac and the attack on Prijedor on the

2 30th of May, there were no clashes between the Serb army and the military

3 in the area where there were Muslim villages?

4 A. I don't think that there were any such activities in that period,

5 as far as I can recall.

6 Q. And you do know that sometime in late May there was an attack on

7 Prijedor by a Muslim unit commanded by Slavko Ecimovic?

8 A. Yes. I don't recall the date, but I do know that in that period

9 the reception centres, the camps, were already in existence.

10 Q. And do you remember that there were some initial successes in

11 this attack and that the Muslim-Croat units reached the town centre close

12 to the police station and the municipality building?

13 A. I know that because that morning we were unable to go to our job

14 as usual because there were some -- there was some fighting and it was

15 dangerous to move for individuals or small groups because there was some

16 shooting around the SUP building. That was the reason why I was unable

17 to go to work on the day, and none of my colleagues was able to get to

18 work. I spent that day at home.

19 Q. Mr. Rodic, now I will show you a document.

20 MR. KRGOVIC: [Interpretation] Could the witness please be shown

21 2D03-1189.

22 Q. That speaks about the event, the attack on Prijedor, to see

23 whether you know anything about the persons and events described therein.

24 MR. KRGOVIC: [Interpretation] 2D03-1189. Yes, it's correct.

25 Q. Now, you mentioned earlier that military security was involved in

Page 14527

1 taking those statements.

2 A. Yes. There was a representative, a member, there. Now, I don't

3 know whether you can characterise what he did as working on it. He was

4 present there. That much I can tell you.

5 Q. And when you made those Official Notes, later on, after the

6 attack on Prijedor, one of the topics that you discussed with these

7 people was the attack and the formations that took part in the attack?

8 A. Yes. Well, similar to the initial part. We tried to talk to the

9 people about this, and they told us what they knew about the event.

10 Q. Now I would like you to look at this criminal report, page 1.

11 It's a criminal report against Asim Muhic, Kemal Alagic, and two other

12 people who are on this list.

13 A. Yes, I can see that.

14 Q. Suad Karagic, a man named as Big Ed, and then another man

15 nicknamed Politicki.

16 A. Yes, I can see that.

17 Q. Do you perhaps recall making Official Notes with any of these

18 people?

19 A. I can't recall anything about the persons listed under number 3,

20 but I do know that it happened with persons listed under 1 and 3 -- 1 and

21 2 because they were leaders, in a way. In the first case, the situation

22 was somewhat similar. I think that Asim Muhic was an active -- a

23 military person, but then he left the army. And Kemal Alagic was a

24 criminal. He had a criminal record.

25 Q. Could you please look at page 2 of this document.

Page 14528

1 JUDGE DELVOIE: Mr. Krgovic, do we have the English version of

2 what you're discussing with the witness in front of us? I don't think

3 so.

4 MR. KRGOVIC: [Interpretation] Yes, Your Honour -- I'm sorry --

5 JUDGE DELVOIE: Now we have. Perhaps. The first page I didn't

6 see.

7 MR. KRGOVIC: [Interpretation] Could we please go back to page 1.

8 I'm sorry, I don't have the e-court and I don't have LiveNote on my

9 screen, so I'm unable to follow what's going on.

10 THE INTERPRETER: Interpreter's note: Could the witness be, once

11 again, asked to make a short pause before answering each of Mr. Krgovic's

12 questions.

13 MR. KRGOVIC: [Interpretation] [Previous translation continues]

14 ... page 2 of this document.

15 Q. Mr. Rodic, this describes in detail the attack, how the attack

16 proceeded.

17 MR. KRGOVIC: [Interpretation] Could we please look at page 2 of

18 this document, so how the attack progressed.

19 Q. And here it says that this person, Asim Muhic, and Kemal Alagic,

20 together with Slavko Ecimovic ...

21 That's the second paragraph from the top.

22 A. Yes, yes.

23 Q. As the platoon commander and --

24 THE INTERPRETER: Interpreter's note: The counsel is kindly

25 asked to slow down when reading.

Page 14529

1 MR. KRGOVIC: [Interpretation] ... and then --

2 JUDGE HALL: Mr. Krgovic, the interpreters are asking to you slow

3 down when reading.

4 And, Mr. Rodic, the interpreters remind you to allow a pause

5 between the question and your attempt to answer. Thank you.

6 MR. KRGOVIC: [Interpretation]

7 Q. Okay, Mr. Rodic. Now take a look at the second paragraph, which

8 reads:

9 In the attack on Prijedor, there was this first platoon led by

10 Kemal Alagic had a difficult task, the attack on the -- on the

11 municipality and the police, and then the members of the groups are

12 listed and their weapons. And then there is Slavko Ecimovic's group,

13 whose task was to take the reserve officers' hall, the Prijedor hotel,

14 the bridge over the Sana, and the radio station.

15 The second group was supposed to reach the management buildings

16 of the Ljubija mines.

17 And the third group was supposed to cut the road leading to the

18 barracks where the army was.

19 There was also a fourth group that was supposed to secure the

20 buildings taken, that is, the Sana bridge and the Prijedor hotel.

21 Do you remember that this hotel was burnt during one of those

22 attacks?

23 A. I did not pass by the hotel at that time. But later, I saw that

24 it was burning, and I heard that it happened at that time.

25 Q. Do you know where the attack had come from, geographically

Page 14530

1 speaking, from which direction the Muslim forces had come?

2 A. If I remember correctly, they had crossed the Sana, which means

3 that they had come from the villages of Hambarine, Biscani. I don't

4 remember exactly. Anyway, they crossed the Sana, and that's how they

5 reached these buildings.

6 MR. KRGOVIC: [Interpretation] Your Honours, with your indulgence,

7 I will try to log on LiveNote because I cannot follow the transcript or

8 the exhibits.

9 [Microphone not activated]

10 THE INTERPRETER: Microphone for counsel, please.

11 MR. KRGOVIC: [Interpretation]

12 Q. We have done part of the job, but it still isn't functioning

13 properly.

14 MR. KRGOVIC: [Interpretation] Could we please see

15 Exhibit 65 ter 3111. It's a map which is, at the same time,

16 Exhibit P1216.

17 Q. Now, this is a map of Prijedor. We have seen the locations. Can

18 you tell us or mark on the map from which direction they crossed the Sana

19 and reached the centre of Prijedor? If you can.

20 Or, actually, I'm afraid that this is the wrong map.

21 Is this map sufficient for you to indicate from which direction

22 they came?

23 A. Well, we got some information through the interviews, and some

24 information from the -- from those involved. So I cannot be precise as

25 to what I heard from who. But, if I may, I'll mark this village here,

Page 14531

1 Rizvanovici. From this direction, they may have crossed the Sana at one

2 place. And then they deployed to toward the hotel here. And then in

3 this direction. I don't know how clear this is.

4 Q. And the third group which was mentioned and advanced along the

5 banks?

6 A. I don't know exactly. I can't quite remember. But I think they

7 crossed the Sana, and they came here, and then they went upstream toward

8 the hotel. The other went to the officers' hall. And the third one took

9 a roundabout way and went to the Puharska neighbourhood, and they tried

10 to cut the road between the Urija neighbourhood and the town centre.

11 Q. Could you please mark these groups, one, two, and three?

12 A. Well, I don't know which was which. One was here. Another was

13 here. And up there, there was a third.

14 Q. Do you know whether there were any casualties on the Serb side

15 then?

16 A. I know that there were casualties. Conditionally speaking, there

17 were colleagues from the MUP, outside the MUP building. There were was

18 acquaintances of mine from my school days, at secondary school. I think

19 I knew somebody who got killed in front of the hotel, but I couldn't say

20 how many people exactly got killed.

21 Q. What about the rest of the group? Once the attack ended, where

22 did that group return to? Was there street fighting on that day?

23 A. What I'm about to say originates from some interviews and some

24 information I observed personally, and probably heard the stories of some

25 people who were on the other side. Namely, that these locations were

Page 14532

1 taken until the army arrived - or the police; don't take my word for it -

2 from the direction of Urija. That's when the combat began. And then

3 they started to retreat to their initial positions; that is, they went

4 through the Stari Grad neighbourhood. There they offered some

5 resistance, but they were pushed back over the Sana again.

6 Q. Could you indicate where -- the whereabouts of Stari Grad?

7 A. It would be roughly where the crossing over the Sana is. I will

8 mark it more boldly. This is where the Sana is.

9 Q. Could you please indicated it with a number 4.

10 A. Yes, here you here. I'm afraid it isn't all too clear.

11 Q. Do you know that on that day when this fighting took place there

12 was also fighting inside Stari Grad itself and that a large number of

13 houses was damaged during the fighting?

14 A. Yes, I know that from direct experience because I live very

15 nearby. I couldn't see the fighting itself, but I heard it because it's

16 only some 700 or 800 metres away from where I live, as the crow flies.

17 Q. Some of these people who pulled out crossed the Sana, went to the

18 surrounding villages, and mingled with the local population; are you

19 aware of that?

20 A. We got some of the that information from the people we

21 interviewed, that they had crossed and spent some time there, after that

22 fighting. But not as a group, but they scattered and stayed there as

23 individuals or in small groups.

24 MR. KRGOVIC: [Interpretation] I would like to tender this

25 document, Your Honours.

Page 14533

1 JUDGE HALL: Admitted and marked.

2 THE REGISTRAR: As Exhibit 2D109, Your Honours.

3 MR. KRGOVIC: [Interpretation] Could we please show

4 Exhibit 2D03-1189 again, please.

5 Let's turn to page 3, please.

6 Q. Here, on page 3, it says that on the occasion of the attack on

7 Prijedor armed groups killed 16 and wounded 16 police and army members.

8 Those were the figures people spoke about in town; right?

9 A. I don't remember the exact number, but I remember three persons

10 that I knew who got killed then. But I really cannot be certain about

11 the total number.

12 Q. It goes on to say that Asim Muhic was in the hamlet of Kadirici

13 and as civilians they mingled with the population in the villages of

14 Asirici [phoen] and Biscani.

15 Then it goes on to say -- to speak about their weapons. Do

16 you -- are you familiar with the events when the army conducted an

17 operation in these villages and found some weapons, and that among the

18 persons taken prisoner then there was some of these persons?

19 A. No, I'm not familiar with these details.

20 Q. Do you know who Mr. Zeljaja is? Was he the commander of one of

21 these units?

22 A. If I remember well, then he was commander of the 43rd, or

23 possibly he was in charge of operative affairs. I'm not sure. But he

24 was one of the commanders in the 43rd Motorised Brigade.

25 Q. Please look at the last page, page 4 of this document.

Page 14534

1 You can see the signature that the criminal report against these

2 persons was filed by Lieutenant-Colonel Milo Zeljaja. It's that person;

3 right?

4 A. I cannot be certain, but I see that that's what it says.

5 Q. Do you know that the military court in Banja Luka tried some of

6 these persons for armed rebellion?

7 A. I know that there was a military court in Banja Luka, but I'm not

8 familiar with their specific activities.

9 Q. Mr. Rodic, today you were answering the Prosecutor's questions

10 about the -- that event, the killing of those prisoners at Keraterm in

11 the summer of 1992. Do you remember: When you came there, was the road

12 leading to Keraterm blocked by the police, or were you able to reach the

13 entrance freely?

14 A. On the day when we got there, we -- there were no obstacles from

15 the direction of Prijedor.

16 Q. Did you arrive at your usual time in the morning?

17 A. Yes, at the usual time, at 7.00 or 8.00. I'm not sure. We

18 arrived at the place without hindrance. And after an hour, hour and a

19 half, we left unhindered. But I don't know what happened afterward.

20 Q. There was no police roadblock on the road leading to Keraterm?

21 A. No, there was no roadblock, apart from the guards who were at the

22 entrance, at the gate. There were guards there, but that was the regular

23 state of affairs. I cannot be sure whether they may -- there may have

24 been more of them, but certainly not significantly more.

25 Q. You didn't see members of the intervention platoon while you were

Page 14535

1 travelling down that road?

2 A. While we were travelling on that road, there was no one there.

3 Q. And vehicles were not being stopped; right?

4 A. I cannot say for certain whether it was possible to pass freely.

5 We didn't pay attention to these details. I don't know. I'm really not

6 sure.

7 Q. Mr. Rodic, the Prosecutor asked you about the release of certain

8 persons from Keraterm and what the procedure was. I'm about to show you

9 a document. You said that this was done elsewhere and that you're not

10 familiar with it.

11 MR. KRGOVIC: [Interpretation] I would like to show the witness

12 Exhibit 1D167. That's tab 5 in Mr. Stanisic's Defence binder.

13 Let's wait for the English translation to appear.

14 Q. Mr. Rodic, this is a decision of the Crisis Staff dated 2 June -

15 the Crisis Staff of the Prijedor municipality - about the release of

16 imprisoned persons.

17 And let me start this way: It was explained to you that the

18 persons who had been brought to Keraterm were persons suspected of having

19 taken part in combat activities or aided and abetted or took part in some

20 way or other?

21 A. I was told that these were persons who are in some way related to

22 combat activities, the arming, or the organisation, or such, that's what

23 we understood them to be, these persons.

24 Q. And here they are called prisoners.

25 A. Yes, it says "prisoners" here.

Page 14536

1 Q. Look at Article 4. All persons over 60 years of age for whom an

2 investigation has confirmed that they did not commit an offence are

3 released.

4 This is basically what you were speaking about when you would

5 find out that somebody was 60. There was nothing left for you to do. It

6 was up to other people to decide about their fate. There was one period

7 when they were being released flat, and later there were problems?

8 A. Yes, that's what I said, that there were some older persons and

9 minors. And in the early stage, there was -- we interviewed them. And

10 once we learned what their age was, they were simply released.

11 Q. And there's Article 5. It says:

12 "Other prisoners who may be found not guilty in legal proceedings

13 conducted by competent bodies shall be released ..."

14 A. After this screening by age, we would interview the remaining

15 persons. And if it was our assessment - because we didn't really know -

16 that they took part in anything, they were released because there were no

17 grounds for us to keep them in detention.

18 Q. And here, basically, is the Crisis Staff that defines the

19 criteria for release. They are the ones who decide about that; right?

20 A. At that time, I did not know this document. Only later did I

21 learn that there was something. And during the proofing, I believe that

22 I saw it.

23 Q. But, basically, you weren't the ones who decided whether a person

24 would be released or kept, and what they would be -- how they would be

25 treated?

Page 14537

1 A. We would only forward the information that we had about their

2 activities. In a word, what we knew about them.

3 Q. Then the Prosecutor asked you about your knowledge of the

4 conditions at Keraterm. But outside the small area in which you moved

5 from the entrance to your office, you didn't go to the places where the

6 prisoners were kept; right?

7 A. No. I didn't go there ever. When I said that the conditions

8 were the way they were, I said that that was the information I got from

9 them and -- and what I concluded from the general condition and aspect.

10 They were in a hygienically neglected state, they had beards, and so on.

11 Q. And if I understand you correctly, the Official Notes that you

12 drafted did not include this kind of information, and this was not your

13 job, so to speak?

14 A. We simply focussed on what I told you I -- we had been doing, and

15 we thought that somebody else was in charge of that, whoever had

16 established the camp and whoever was in charge of it.

17 Q. And when you drafted those Official Notes, you and members of

18 your team did not use coercion or force?

19 A. No coercive measures were used. This was just an interview.

20 Q. Answering the Prosecutor's questions about the arrival, you

21 mentioned that Mr. Bera visited Keraterm on several occasions.

22 A. Yes.

23 Q. Let me now show you an exhibit.

24 MR. KRGOVIC: [Interpretation] P601.

25 Q. Mr. Rodic, please look at this document carefully. It's a

Page 14538

1 decision by centre chief Stojan Zupljanin to establish a commission to

2 visit the municipalities of Prijedor, Bosanski Novi, and Sanski Most.

3 And here we have the members of the commission. And Mr. Bera is the

4 commission chairman. You can see that?

5 A. Yes.

6 Q. Did you hear about the commission that was set up to investigate

7 the conditions?

8 A. Well, in the course of the drafting of this decision and a little

9 while later, I was not aware of it, and I didn't know about it. And

10 later on I heard that there was a commission that made a report. And I

11 think that in the course of an interview I was shown this report.

12 Q. And here you mentioned some persons who are in the commission,

13 and now I want to ask you: Do you know Vaso Skondric?

14 A. Well, I knew Vaso but more or less by sight. And later on we did

15 not keep in touch in any way.

16 Q. Mr. Ranko Mihic?

17 A. I knew Ranko Mihic because he worked in the public security

18 station before the war.

19 Q. You mean the Prijedor Public Security Station?

20 A. Yes, the Prijedor Public Security Station. And I think that

21 Mr. Skondric worked somewhere in Banja Luka.

22 Q. What about Mr. Jugoslav Rodic?

23 A. Jugoslav Rodic was a colleague from the State or National

24 Security Service.

25 Q. And he worked in Prijedor?

Page 14539

1 A. Yes, in the Prijedor detachment.

2 Q. Now, Mr. Rodic, you can see here that the task of the commission

3 is to establish whether, in those municipalities, including Prijedor,

4 there were any prisoner of war centres, investigation centres, reception

5 centres, or any other forms in which persons, citizens, are brought in

6 and accommodated; the reason why they were set up; the number of persons

7 brought in, processed, and released; and the ethnic gender and age

8 breakdown of the persons; and the conditions in which they live.

9 Mr. Rodic, did anyone ask you any questions in this part, and do

10 you know that these people actually came there at the time when

11 you were ...

12 A. Let me see what's written here. I really cannot recall whether

13 they came. But Vojin Bera did come. Now whether, during those visits of

14 his, there were any talks about that, I really can't remember. But maybe

15 he didn't speak about that with me. I simply cannot ...

16 Q. And then further down it says that it is necessary to establish

17 whether any citizens moved out from those municipalities, their ethnic

18 background and number, and whether they moved out voluntarily or were

19 forced to move out.

20 Do you remember that there were some activities pertaining to

21 this issue?

22 A. Well, if you mean the activities of the commission members, I

23 really cannot recall. What I can recall I've already told you, and I

24 don't know anything else, given the place where I was and what I was

25 doing.

Page 14540

1 MR. KRGOVIC: [Interpretation] Now I would like the witness to be

2 shown Exhibit P602.

3 JUDGE DELVOIE: Mr. Krgovic, can we -- can we see - because we

4 don't see it here on the English version - who signed this decision?

5 MR. KRGOVIC: [Interpretation] The previous document, Your Honour?

6 JUDGE DELVOIE: [Previous translation continues] ... yes.

7 MR. KRGOVIC: [Interpretation] Could we go back to P601.

8 I would like the witness to look at the original so that he can

9 confirm.

10 Q. Sir, could you please look at the last paragraph here. And then,

11 below, it says chief of the centre, Stojan Zupljanin.

12 A. Yes. You can see the stamp of the centre and the signature.

13 JUDGE DELVOIE: [Previous translation continues] ... thank you.

14 MR. KRGOVIC: [Interpretation] Now I would like us to go back to

15 P602.

16 Q. Mr. Rodic, this is a report on the situation found and issues

17 pertaining to the prisoners or collection centres, the resettlement, and

18 the role of the SJB in relation to these activities.

19 I think that the Prosecutor showed you this document in the

20 course of your interview.

21 A. That was the first time that I saw this document. I think it was

22 in 2003, when I was interviewed by the Prosecution.

23 Q. And it says here, Pursuant to a decision of the decision of the

24 chief of the Security Services Centre, number 11-141/2, and so on.

25 A. Yes. Well, that's -- it's -- it is -- it follows up on the

Page 14541

1 previous document.

2 MR. KRGOVIC: [Interpretation] Now I would like us to look at the

3 last page of this document. That's page 16 in the Serbian version.

4 Q. You can see here that this document is signed by the commission

5 members, Mr. Vojin Bera.

6 A. Yes, I can see.

7 Q. Do you perhaps recognise any of the signatures of the colleagues

8 that you worked with?

9 A. Well, I might be able to actually recognise Jugoslav Rodic's

10 signature; and perhaps, to an extent, Vojin Bera's. The other two, no.

11 MR. KRGOVIC: [Interpretation] Now I would like us to go back to

12 page 1 of this document.

13 Q. Mr. Rodic, here it says, in the preamble - I will now go through

14 the part that's relevant for the Prijedor municipality - it says here

15 that the armed conflicts in the Prijedor municipality started on the 24th

16 in the Kozarac area and then spread to other areas.

17 So this corresponds to what you knew of the events?

18 A. Well, I've told you -- well, I've told you that this is where --

19 when the action started and that the reception investigative centres of

20 various shapes and forms were established then, a day or two after that.

21 Q. And in paragraph 2, it says that in the course of the clashes the

22 Army of the Serbian Republic captured a large number of the members of

23 hostile formations and other persons who were found to be in the areas

24 where armed conflicts went on, and a number of citizens leaving homes and

25 flats sought help and protection.

Page 14542

1 MR. KRGOVIC: [Interpretation] Can we please move on to the next

2 page in the Serbian version.

3 Q. Where it says that the Crisis Staff of the Prijedor municipality

4 decided to organise reception and accommodation in the settlement of

5 Trnopolje for persons seeking protection and that prisoners of war should

6 be held for processing in the building of the Keraterm company in

7 Prijedor or in the administrative building and work-shop of the RZR in

8 Omarska. I think it's the mine. It's the iron-ore mine. That's what

9 the acronym stands for.

10 Mr. Rodic, this is more or less what you knew at the time, if you

11 know, from this document, it turns out that the Crisis Staff of the

12 Prijedor municipality set up those centres, Keraterm, Omarska, and

13 Trnopolje alike. Is that correct?

14 A. Well, on the basis of this, the picture is a bit fuller. But I

15 did not know that at the time when all of this was going on.

16 Q. Now, I would like to read out a part of this document that

17 pertains to the situation in Keraterm, the way they describe it.

18 MR. KRGOVIC: [Interpretation] That's page 3 of this document.

19 And in the English version, that would be page 2.

20 Q. And here we have a description of the facility: The facility of

21 the Keraterm lies along the main Prijedor-Banja Luka road. The facility

22 consists of the rooms of the administration building, offices, halls,

23 restaurants, toilets, and washrooms, and facilities meant for the storage

24 of finished products. The courtyard area is fenced in the way, usual,

25 for work organisations. The entrance is at the main gate on the east

Page 14543

1 side. And on the western side of the facility are auxiliary work

2 premises that have been used since the beginning of the armed conflicts

3 for the accommodation of the Prijedor military police companies --

4 company.

5 Mr. Rodic, do you know that in Keraterm itself, in the fenced-in

6 area, there was a military police company which also participated in

7 securing the facility?

8 A. I know that. I know that there were military police there. I

9 don't know what formation. And I don't know to what extent they

10 participated in securing the facility, if they did at all, but it is a

11 fact that a military police unit was stationed there. I don't know what

12 the composition was.

13 Q. And it says here:

14 "Pursuant to a decision of the Prijedor municipality Crisis

15 Staff, the army brought prisoners of war to this facility and the public

16 security station was given the task of securing the facility with

17 employees of the police?"

18 Mr. Rodic, do you know that the police -- or, rather, that

19 pursuant to a decision of the Crisis Staff, the army brought prisoners of

20 war into this part and that the Crisis Staff ordered the police to take

21 part in securing the detention or collection centres, whatever you want

22 to call them?

23 A. I didn't know what the basis was for what they did. But based on

24 what I saw there, that the police were mostly stationed around the

25 facility, I did see that, and I think that I saw on some occasions that

Page 14544

1 the military brought in a certain number of persons from the crisis areas

2 by bus, the hot-spots or -- of the activities that they were involved in.

3 Q. And then, further down, it says that the conflicts escalated.

4 And I quote:

5 "At the same time, the Crisis Staff of the Prijedor municipality

6 assessed that it would be advisable for security reasons to transfer the

7 prisoners to another place and decided on the facilities of the

8 administrative building and work-shops of the Omarska RZR."

9 The same decision, the decision of the Crisis Staff, determined

10 that the Keraterm facility in Prijedor should be used exclusively for

11 transit, that people who had been brought in should be received there

12 solely for the purpose of their transportation to the facilities in

13 Omarska.

14 And then it reads that, on the 27th of May, pursuant to a

15 decision of the Crisis Staff of the Prijedor municipality, all the

16 prisoners from the Keraterm facility in Prijedor were transferred to the

17 facility in Omarska.

18 And now there are some things here that are not logical, so

19 please help us out.

20 Did the things that are described in this document really come to

21 pass? Or, in other words, were the prisoners transferred the way it is

22 described in this document?

23 A. What I do know is that after a few days, when we were in

24 Keraterm, there was a transfer to the Omarska area, and I think that I

25 said in the investigative proceedings that I was in the Omarska area for

Page 14545

1 a day or two. But then an order -- or, rather, I can't call it an order,

2 it was a notice for us that the three teams should return to the Keraterm

3 area, where we would engage in investigative activities.

4 Q. And it says here that - well, it's in the second paragraph; let

5 us go back - that combined investigative teams were set up from the

6 members of national, public, and military security services to

7 operatively process all the prisoners and to determine the degree of

8 their personal responsibility in the fighting.

9 Does that more or less correspond to what you told us about how

10 the combined teams were set up, the joint teams that worked on gathering

11 information about all this?

12 A. Well, in the course of this interview and the proofing procedure,

13 I mentioned a couple of times that there were - I'm now talking about

14 Keraterm - the three teams that consisted of the people that they

15 consisted of, the public and national security services, and that, at the

16 beginning, the member -- the representative of the military security was

17 also there, at first a bit more often and later on more seldom.

18 Q. And the task, as indicated here, was to determine the operative

19 processing of all the prisoners and to determine the degree of their

20 personal responsibility in armed combat?

21 A. Well, what we were doing was we are gathering information about

22 their involvement. That's what we were doing, and that's what I've

23 repeated several times.

24 MR. KRGOVIC: [Interpretation] Your Honours, I believe that this

25 is the right time for our break because I'm about to embark on a new line

Page 14546

1 of questioning.

2 JUDGE HALL: Thank you, Mr. Krgovic.

3 MR. PANTELIC: And I do apologise, Your Honour, just less than

4 one minute, I have to put on the record: We were informed by our learned

5 friend Ms. Paula Lynch that -- and I will quote what he wrote to us:

6 As today's 365th day of our trial, drinks are required, whether

7 they will be in the name of celebration or drowning of sorrows, take your

8 pick.

9 And I wish, also, to express my gratitude to all of our friends

10 from the Interpretation Unit, Technical Unit, as well as the security

11 officers for the last one year of work in this trial. Thank you.

12 JUDGE HALL: Thank you, Mr. Pantelic. And you speak for all of

13 us.

14 We take the adjournment to tomorrow. I believe we're back in

15 this courtroom at 2.15.

16 Mr. Rodic, having been sworn as a witness, you cannot have any

17 communication with counsel from either side. And in such meetings and

18 conversations that you have with persons outside of the courtroom, you

19 cannot discuss your testimony.

20 So we resume tomorrow morning at -- tomorrow afternoon at 2.15.

21 [The witness stands down]

22 --- Whereupon the hearing adjourned at 7.02 p.m.,

23 to be reconvened on Tuesday, the 14th day

24 of September, 2010, at 2.15 p.m.