100914ED

Page 14548

1 minutes from now because we have a meeting with the Office of the

2 Prosecutor concerning the exhumations.

3 JUDGE HALL: Yes.

4 MR. ZECEVIC: Thank you very much.

5 JUDGE HARHOFF: By all means.

6 [The witness takes the stand]

7 JUDGE HALL: Mr. Rodic, good afternoon to you, sir. You may

8 resume your seat.

9 Before I invite Mr. Krgovic to continue his cross-examination, I

10 remind you, you're still on your oath.

11 Yes, Mr. Krgovic.

12 MR. KRGOVIC: Thank you, Your Honours.

13 WITNESS: RADOMIR RODIC [Resumed]

14 [Witness answered through interpreter]

15 Cross-examination by Mr. Krgovic: [Continued]

16 Q. [Interpretation] Mr. Rodic, let us continue where we left off

17 yesterday. My last question had to do with a document, so now I would

18 like us to look at Exhibit P602.

19 Mr. Rodic, this is the report that we looked at yesterday, and

20 you also had an opportunity to look at it during your interview with the

21 Prosecution.

22 MR. KRGOVIC: [Interpretation] So I would like the witness to be

23 shown page 3 of this document, in the Serbian version.

24 Q. Mr. Rodic, in the first paragraph here, we have a description of

25 the premises in Keraterm, and it is said that these are -- this is the

Page 14549

1 administration building with the restaurant, offices, halls, and the

2 toilets and bathrooms. And you will agree with me that there is no

3 mention of any bad conditions that you were able to observe here?

4 A. Well, approximately, yes, that's how it is.

5 MR. KRGOVIC: [Interpretation] Now I would like the witness to

6 look at page 4 in the Serbian version of this document.

7 Q. Look at paragraph 2 here. You said that you spent a few days in

8 Omarska too; is that correct?

9 A. Yes. A day or two at the beginning. I can't really recall, but

10 it was in that period.

11 Q. Paragraph 2 describes the conditions, and it says here that this

12 is a relatively new facility which has all the necessary facilities for

13 life and accommodation of a large number of persons: Offices, halls,

14 toilets and washrooms, kitchen and dining-room, constant supply of

15 drinking water, a large number of showers, constant supply of

16 electricity. No alterations were made to the facility, but the existing

17 premises were used for the accommodation of and work with the prisoners.

18 And then it goes on to say there is no barbed wire around the

19 facility, and it is quite a long way from the settlements of Omarska and

20 Maricka. Basic health care was provided -- is provided for the prisoners

21 in the investigation centre. Food is prepared in the Omarska iron/ore

22 mine kitchen, and it is served in the centre restaurant on a self-service

23 line.

24 Mr. Rodic, having read this report, this part of the report, one

25 could conclude that the conditions in Omarska were good?

Page 14550

1 A. As far as I can recall, both facilities had been used before, and

2 they were, indeed, relatively new. So this description of facts

3 corresponds to the actual state of affairs.

4 Q. But you don't know to what extent -- or, rather, which prisoners

5 were allowed to use those premises and the conveniences listed here.

6 A. Yes, precisely. I don't know what and to what extent they were

7 able and allowed to use here.

8 Q. Mr. Rodic, look at page 5 of this document. Please look at

9 paragraph 3 here. In the Serbian version, that's the third

10 paragraph from the top; and in the English version, that would be the

11 first paragraph that we have here.

12 It says here that of the total of persons brought into the

13 investigation centre, two Muslims died of natural causes and 49 persons

14 left the investigation centre in an unknown manner.

15 Do you see this information?

16 A. Yes, I do.

17 Q. As far as I was able to gather from this report, Keraterm is

18 described as a transfer centre from which people were then transferred to

19 Omarska or to Trnopolje or then further on to Manjaca; is that correct?

20 A. As regards Keraterm, it is true, in a way. Quite a few people

21 came in, a certain number of people were released while it was possible,

22 and a certain number of people were then transferred on to Omarska and

23 Trnopolje.

24 Q. And this information about the number of people who died in the

25 centre, it does not correspond to the truth?

Page 14551

1 A. Well, I cannot comment on this information because I was in the

2 that area, so I don't really know that.

3 Q. And you will agree with me that this report does not contain any

4 information about the killing of those persons in room number 3 that the

5 Prosecutor asked you about yesterday?

6 A. I didn't notice anything of the sort in this report.

7 Q. Mr. Rodic, let us go back to page 2 of this document.

8 MR. KRGOVIC: [Interpretation] In the Serbian version, please.

9 Q. Mr. Rodic, in paragraph 2 on this page, we have a description of

10 Trnopolje. And here we see the description of the conditions there, and

11 it is stated there that the open reception centre Trnopolje is located in

12 the Trnopolje settlement, inhabited area, and it is used as an

13 accommodation facility for the persons staying there. And these are the

14 premises of the elementary school, the hall, the warehouse, and the

15 private homes near those facilities as well as the open-air area in the

16 yard.

17 From the 24th of May, 1992, a relatively large number of citizens

18 of Muslim ethnicity of both genders and all ages have sought refuge in

19 the centre. Then we see the number of persons stated here. And then the

20 report goes on to say the number of persons in this centre changes every

21 day, and no special record are kept since the citizens are allowed to

22 leave the camp as they see fit and to go wherever they like.

23 Then in paragraph number 3 it is stated that there is a water

24 supply, electricity supply in the camp, that the area is not fenced in,

25 and that citizens are not interrogated in the centre. And the army

Page 14552

1 personnel provides constant security for the facility, in case of any

2 threats to the citizens from the outside by the extremists. And then it

3 goes on to say that an outpatient clinic is there, that the

4 representatives of the Red Cross are present.

5 Mr. Rodic, you did not carry out any investigative actions or you

6 didn't make any Official Notes regarding any of the persons in Trnopolje;

7 is that correct?

8 A. Yes, that's correct. We didn't go there. We didn't take any

9 actions in Trnopolje. I did not stay in that area in that period. I am

10 familiar with the location, and I know that the description is accurate.

11 You have the school, the hall, the shops, and the private homes around

12 it.

13 Q. Do you know if the area was fenced in?

14 A. What I do know is that there was a shop nearby, and the warehouse

15 was fenced in, and the shop itself was actually in the warehouse. And

16 that was the only part of the whole facility that was fenced in, as far

17 as I know.

18 Q. Mr. Rodic, do you know that, apart from this report, report by

19 any -- by this commission, whether there were any other reports about the

20 conditions in the collection centres?

21 A. I'm not aware of any other efforts of this kind, and, in fact,

22 the first time that I saw this report was in the course of the

23 investigation, when it was shown to me by the investigator.

24 Q. And you and your colleagues from the state security or public

25 security, when you made the Official Notes, when you did your job, you

Page 14553

1 did not go into that, you did not send any reports further up about that?

2 A. No, we did not. We focussed in our reports or in our

3 Official Notes, we focussed only on that, and this was the only form of

4 communication that we had in that time-period.

5 Q. Mr. Rodic, in the team in Keraterm, was Djuro Savic there too?

6 A. I know a man by the name of Djuro Savic, but he was never there.

7 And there was no Djuro Savic in our -- in our office there at all.

8 Q. And while you were in Omarska?

9 A. I don't think -- in fact, I know that he was not there. But as

10 I've already told you, I was there just two days.

11 Q. Was Sredoje Novic in the team with you?

12 A. No. No, I said who worked in the teams on those jobs. Nobody

13 else was there, not the persons that you've just mentioned or anyone

14 else.

15 Q. And in Omarska, while you were there, he was not there?

16 A. No, no.

17 Q. Mr. Rodic, do you know that in Omarska, while you were there, or

18 did you hear of any killings of the prisoners by the guards and that it

19 was done on a wager for a crate of beer?

20 A. I don't know that. I don't know that.

21 Q. In the course of your interview, the Prosecutor showed you a

22 number of documents signed by Milos. And as far as I can recall, you

23 said that you were not familiar with those reports and that you were not

24 aware of any group called Milos operating in your area. Is that correct?

25 A. Yes, I was shown those documents, but I didn't know anything

Page 14554

1 about them, and I -- when -- I told the investigator that this was not

2 the appropriate form that we used in our daily communication for those

3 reports.

4 Q. And when you were in Keraterm and in Omarska, you did not see

5 Predrag Radulovic there, did you?

6 A. No, I did not. But, as I said, I was there for a very short

7 time, and I didn't see anyone from the outside, so to speak, anyone from

8 outside of Prijedor. I'm now talking about the people who were involved

9 in the investigative measures taking place up there.

10 THE INTERPRETER: Interpreter's note: Could the counsel be kind

11 enough to switch off the mike while the witness is speaking.

12 JUDGE HALL: [Previous translation continues] ... Mr. Krgovic, the

13 interpreters remind you to switch off your microphone while the witness

14 is answering.

15 MR. KRGOVIC: [Interpretation]

16 Q. I'm sorry, Mr. Rodic. So my question was: You never saw

17 Mr. Radulovic in Keraterm either; is that correct?

18 A. As I said, nobody else was involved in investigative measures,

19 apart from us six who were working there.

20 Q. The Prosecutor asked you in examination-in-chief about anyone

21 else coming to visit Keraterm from other areas, and in response, you

22 said, if I understood you correctly, that one of the guards mentioned a

23 delegation and that Stojan Zupljanin was there as well. Do you remember

24 saying that?

25 A. Yes, I said that. But I also said that that was conveyed by one

Page 14555

1 of the guards. Therefore, whether that was really the case or not, I

2 cannot say.

3 There was a delegation which stayed for a while there. And after

4 that, we inquired with the guards and I think that one of them said that

5 Mr. Stojan Zupljanin was there as well.

6 Q. In other words, you personally did not see Mr. Stojan Zupljanin.

7 You didn't see any member of the delegation. It was only after a while

8 that you heard that Mr. Zupljanin might have been in that delegation. Is

9 that correct?

10 A. Yes, precisely.

11 Q. Do you know that a high-level delegation visited Prijedor and

12 also paid a visit to Omarska in the summer of 1992 in which context the

13 names of Mr. Brdjanin and some other people were mentioned?

14 A. I know that there was a delegation paying a visit, but that

15 probably happened a couple of days after their visit. Whether it

16 happened in Prijedor or not, I cannot say with any degree of certainty.

17 And I also heard on that occasion that Mr. Zupljanin and Mr. Brdjanin

18 were members of that high-level delegation. I can't remember who else

19 was there.

20 Q. And probably this visit by this delegation to Omarska created

21 some kind of confusion in the sense that they visited Keraterm too; is

22 that correct?

23 A. It is possible that there was some confusion. I cannot say

24 whether it happened in my head or in the head of that man who told me

25 that because I didn't see it, and I really can't say with any degree of

Page 14556

1 certainty that Mr. Zupljanin was there.

2 Q. Mr. Rodic, can you tell me approximately when was it when you

3 returned, whether it was in early August or mid-August? When was it you

4 returned to your regular job?

5 A. I believe that that was sometime in mid-August or the latter half

6 of August.

7 Q. Your office was in the public security station. Which floor was

8 that; the third or the fourth?

9 A. We were on the top floor, which was actually the second floor.

10 But if you count the ground floor, then it would be the third floor.

11 Q. Was your office close to the conference room in the Prijedor SJB?

12 A. The conference room was in an auxiliary building that you could

13 reach through the yard. Therefore, it was not close to our offices.

14 Q. What about the office of Simo Drljaca? Where was his office

15 located?

16 A. It was located on the floor below and in the wing opposite to the

17 wing where we were.

18 Q. Mr. Rodic, do you know who General Bogdan Subotic is?

19 A. I have heard of him, of Mr. Subotic, but I don't know which

20 position he held at the time.

21 Q. And you had never seen him and you had never heard of him coming

22 to the Prijedor public security station?

23 A. No, I hadn't.

24 Q. And particularly in the course of 1992; is that correct?

25 A. I don't know if I ever saw Mr. Subotic in person, and that

Page 14557

1 includes that period as well.

2 Q. And you surely never heard of Mr. Zupljanin, following the period

3 when you returned to the station, coming to the public security station?

4 A. I don't know that Mr. Zupljanin came in that period. I saw

5 Mr. Zupljanin in Prijedor only much later, and I think that had to do

6 with some assembly sessions taking part in -- taking place in Prijedor,

7 and I saw him in that context. But I allow for a possibility that I

8 might be mistaken.

9 Q. Thank you, Mr. Rodic.

10 MR. KRGOVIC: [Interpretation] I have no further questions for

11 this witness.

12 MR. CVIJETIC: [Interpretation] May I, Your Honours? Thank you.

13 Cross-examination by Mr. Cvijetic:

14 Q. [Interpretation] Good afternoon, Mr. Rodic.

15 A. Good afternoon.

16 Q. I'm going to put only a few questions to you because my learned

17 friend Krgovic and I agreed to focus our cross-examination on certain

18 matters and that he would do the bulk of the job in his part of

19 cross-examination. Therefore, I'm going only to tackle a number of

20 issues that might require some clarification.

21 Let me just remind you of a document that you discussed at length

22 with the Prosecutor.

23 MR. CVIJETIC: [Interpretation] And for the benefit of the

24 Trial Chamber, that's P583.

25 Can we just enlarge the second paragraph.

Page 14558

1 Q. Let me just refresh your memory. I'm not going to dwell long on

2 this document. And this paragraph speaks about the categorisation of

3 persons that the Prosecutor asked you about. Do you remember that?

4 A. Yes, I do.

5 Q. Now, my question is a question in principle. You were a member

6 of a so-called mixed team made up of members of the State and Public

7 Security Services, and you said yesterday that there were military

8 personnel involved as well; is that correct?

9 A. Yes, it is.

10 Q. The essential purpose of your job was to establish who, among the

11 people you interrogated, might have been involved or implicated in the

12 commission of certain crimes and to what extent.

13 Now, in short, was that your task? Would you agree with me?

14 A. Well, yes, that corresponds more or less to what we were doing.

15 In these interviews, we tried to get as much information as possible

16 about the persons who might have been involved in such activities or

17 similar.

18 Q. Then you will certainly agree with me that the selection of

19 suspects, according to the type of crime and the degree of involvement in

20 the commission of certain crimes, was a lawful operative activity that

21 all organs of the interior normally conduct all over the world, including

22 our country. You would agree with me on that, wouldn't you?

23 A. It is true that, according to the law in force at the time, those

24 were the tasks that we were supposed to carry out during that pre-war and

25 war period.

Page 14559

1 Q. Thank you. Now I'm going to move to a different subject.

2 In response to the questions put to you by the Prosecutor and my

3 colleague Krgovic, you said that practically your methodology of work

4 employed by members of the State and Public Security Services and your

5 line of work was - let me put it this way - frozen at the time because

6 you became a member of the team that operated according to the

7 methodology that was employed by members of the Public Security Service;

8 am I right?

9 A. Yes, that's correct. And as I said earlier, during that period,

10 we did not have much communication with our first-instance superior, that

11 is to say, Banja Luka.

12 As for the latter part of your question, that was also true.

13 That was only part of the activities that was any way part of the job

14 description of members of the -- of the public security --

15 THE INTERPRETER: Could the witness please repeat whether he said

16 "public" or "state" security.

17 JUDGE HARHOFF: Mr. Witness, the interpreters ask that you repeat

18 your last answer to counsel's question, notably whether you said "public

19 security" or "state security." The interpreter did not catch that. So

20 please if could you repeat.

21 THE WITNESS: [Interpretation] I think I said state security.

22 That that was only part of the job that the state security had within its

23 general job description.

24 MR. CVIJETIC: [Interpretation]

25 Q. Very well. Tell me, Mr. Rodic, during that period, you did not

Page 14560

1 maintain any significant communication with your basic service in

2 Banja Luka because, as I understand, the results of your work ended in

3 the -- in the hands of Mr. Simo Drljaca, the chief of the Prijedor SJB;

4 is that correct?

5 A. It is true that we didn't have any communication whatsoever with

6 Banja Luka, with the exception of the colleague who used to come to pay

7 some kind of -- visit us as a kind of courtesy, and I know that all these

8 reports ended up as you said.

9 Q. Speaking of that, I'm going to put a direct question to you: How

10 many times during that period did you go to Banja Luka? And did you use

11 any other communication channels to liaise with Banja Luka? And did you

12 have any difficulties in that respect?

13 A. As of April until the second half of September, I did not go to

14 Banja Luka, nor do I remember any of my colleagues going there. We

15 didn't have any other channels of communication. I think that even the

16 telephone was broken or at least broken for the most of the time.

17 Q. Can you give us an approximate answer to the question: When was

18 it that you first heard who the interior minister of Republika Srpska

19 was, and how did you learn that?

20 A. I heard that from the media. And I cannot give you an

21 approximate date. I think it was more or less at the time when it

22 happened, but I really can't give you the time. I can't recall the time.

23 Q. And for all intents and purposes, this was all the knowledge that

24 you had about the existence of the minister of the interior; in other

25 words, what you heard from the media?

Page 14561

1 A. Yes, that's correct. I heard this in the media, and I may have

2 heard something in that context regarding some activities or something

3 like, but I did not have any personal first-hand knowledge.

4 Q. Yesterday, my colleague Mr. Krgovic showed you documents

5 generated by the Crisis Staff indicating that it was the Crisis Staff of

6 the Prijedor municipality that actually established the collection

7 centres or whatever we can call it. And I will show you a document but

8 for another purpose.

9 MR. CVIJETIC: [Interpretation] Could we please look at 1D166.

10 The document is a bit small. Can we please zoom in on the top part of

11 the document. First two paragraphs. We won't be looking at the rest of

12 it.

13 Q. Mr. Rodic, to confirm what Mr. Krgovic has already shown you, you

14 can see in the heading of this document that in line with the decision of

15 the Crisis Staff, in order to implement this decision, collection centres

16 are set up. As can you see from paragraph 1, you will see that

17 Mr. Simo Drljaca signed this document. We will look at page 2.

18 So can you see in paragraph 1?

19 A. Yes, I can see parts of it.

20 Q. And there's a reference to the decision of the Crisis Staff.

21 That's the decision that you looked at yesterday with my colleague

22 Mr. Krgovic. You do remember that Mr. Krgovic showed you this document?

23 A. Yes, I do remember.

24 Q. Now I would like us to look at the last page of this document.

25 MR. CVIJETIC: [Interpretation] If we can go through this document

Page 14562

1 until we reach the last page, paragraph 15.

2 I think that in the English version we need to go back one page.

3 Yes, item number 15.

4 Q. Mr. Rodic, I think you may have already read it, but let's go

5 through it.

6 Mr. Drljaca strictly prohibits any provision of any information

7 whatsoever concerning the functioning of the collection centre, and all

8 official documents must be kept at the collection centre and may be taken

9 out or destroyed only with the permission of the chief of the

10 Prijedor SJB. The security staff shall be responsible for this.

11 Now, Mr. Rodic, in the context of your evidence and what you've

12 just told me, if we establish a link with this order issued by

13 Mr. Drljaca, it does appear that Mr. Drljaca, in fact, monopolized the

14 right to gathering all information about all the events in the territory

15 of the Prijedor municipality in a way by issuing this decision?

16 MR. OLMSTED: Your Honours, it's a bit of a misleading question

17 because this document pertains to Omarska camp, and this witness was at

18 Keraterm camp. So I don't know what link my learned friend is trying to

19 draw here.

20 Perhaps he wants to ask whether a similar order was issued with

21 regard to Keraterm camp. That would probably be a feasible question this

22 witness could answer.

23 MR. CVIJETIC: [Interpretation] Well, the essence of my question

24 does not pertain to the operation of any of the collection centres. It's

25 the conduct, the behaviour, of Mr. Simo Drljaca regarding an embargo on

Page 14563

1 the information in the Prijedor municipality, and I'm using it as a

2 reference for further questions. So I'm not now dealing with Omarska or

3 with Keraterm; I'm just trying to explore this issue with the witness. I

4 haven't yet embarked on it. So may I be allowed to finish?

5 JUDGE HALL: What I thought Mr. Olmsted's objection was going be

6 is that the question, as phrased, invited an argument.

7 MR. CVIJETIC: [Interpretation] Let me be quite specific.

8 Q. Mr. Rodic, to the extent to which you came to know Mr. Drljaca,

9 would you agree with me that he, as the chief of the SJB, was quite

10 autonomous in his work, in relation to the rest of the Autonomous Region

11 of Krajina and other responsible organs?

12 MR. OLMSTED: I guess -- I suppose if the witness can answer

13 that, but it does call for speculation if this witness was in Prijedor

14 during this time and did not go to other municipalities. And so how is

15 he going to be able to compare what was happening in Prijedor with other

16 places during this time-period?

17 MR. CVIJETIC: [Interpretation] Well, if the witness can give us

18 any information, then, please, let him; and, if not, we'll proceed.

19 THE WITNESS: [Interpretation] What is the question?

20 MR. CVIJETIC: [Interpretation]

21 Q. Well, you've read this order by Mr. Drljaca. Is that how he

22 acted when it came to the information he received from you? Because you

23 said that your information also went to him.

24 A. It is true that information that we produced went to the MUP, to

25 the SUP building, and this is the first time that I see this part of the

Page 14564

1 document, where he actually issues an explicit order to that effect.

2 As far as Mr. Drljaca is concerned, as a superior officer, I

3 can't really say much because I did not have that much contact with him.

4 And it was mostly common courtesy; we would meet on the staircase, things

5 like that. But if -- I can tell you this: I did know him to a degree

6 before the war from sports activities and recreation activities, where he

7 always wanted to be the dominant figure. He was rather brazen, and I

8 thought this was not acceptable for everyone.

9 Now I cannot say whether he behaved in the same way in his work

10 in this period because I don't know him all that well. He was not my

11 immediate superior.

12 Q. Well, I will not dwell on that.

13 Yesterday, Mr. Krgovic showed you a document --

14 JUDGE DELVOIE: [Previous translation continues] ...

15 Mr. Zecevic [sic] for the previous document, that is, 1D166, you said

16 that the witness looked at it yesterday "with my colleague Mr. Krgovic.

17 Do you remember that Mr. Krgovic showed you this document?"

18 And the witness answers: "Yes, I do remember."

19 I'm sorry, but I don't remember, and I don't see that in -- in

20 the -- in the transcript. I don't think 166 has been showed. 167 has

21 been showed.

22 Just -- I don't know whether it's important, but this shows how

23 easy one can mislead a witness, if I'm right.

24 MR. CVIJETIC: [Interpretation] No, Your Honour, that was not my

25 intention. And I didn't mean to say that this document was shown to him.

Page 14565

1 That's not what I said. If you recall, I showed him just the heading,

2 the letterhead of this document, or, rather, the preamble where the

3 decision on -- of the Crisis Staff to establish those collection centres

4 is referred to.

5 Mr. Krgovic spoke about that and showed another document, and I

6 just reminded the witness that he had discussed this topic with

7 Mr. Krgovic, but not that this document was shown to him by Mr. Krgovic.

8 And I fully agree with you. Mr. Krgovic did not show him this document.

9 JUDGE DELVOIE: [Previous translation continues] ... thank you,

10 and I apologise.

11 MR. CVIJETIC: [Interpretation] Let me just try and remember.

12 Q. You remember that Mr. Krgovic showed you this decision on the

13 release of persons from detention. It was a decision of the

14 Crisis Staff. And you said that the Crisis Staff decided who would be

15 released from those collection centres. Do you recall that? Do you

16 recall having seen that?

17 MR. OLMSTED: That misstates his evidence. He did not say that

18 the Crisis Staff released persons. He said he didn't know.

19 Can you maybe point to us where in the transcript he made that

20 assertion, that the Crisis Staff decided who was released?

21 MR. CVIJETIC: [Interpretation] Yes, yes, well the gist of my

22 question is merely to ask him whether he recalls discussing this topic

23 with Mr. Krgovic and whether Mr. Krgovic actually showed him this

24 document. I didn't want to comment on his answer.

25 Q. So you remember that Mr. Krgovic showed you the decision to

Page 14566

1 release some persons from the collection centres. Do you remember? And

2 I can give you the reference. That's 1D167. And can you look at the

3 document, if you wish, to refresh your memory.

4 A. I'm sorry, I consider this document as a follow-up on the

5 document issued by the Crisis Staff, the one that was shown. I think

6 this was yet another document that spoke about the establishment of

7 detention centres or camps. And the previous document I considered to be

8 the follow-up on the other one; in a way, Mr. Simo Drljaca's response to

9 it, when he reported.

10 Q. Yes. You can see the document that I mean on the screen. And do

11 you remember having seen this document yesterday?

12 A. Yes.

13 Q. So Mr. Krgovic showed you this document, and you commented on

14 this document.

15 Let me now show you another document.

16 MR. CVIJETIC: [Interpretation] That's P663.

17 Q. I will give you some time for you to read some parts of this

18 document.

19 Have you been able to read it?

20 A. Well, parts of it.

21 Q. Mr. Rodic, if you look at this document really closely,

22 Mr. Simo Drljaca - we will see the last page, and we will see that he

23 signed it - is reporting to the Crisis Staff of the Prijedor municipality

24 on the implementations of the conclusions of the Crisis Staff.

25 So let us look at the kind of conclusions we're talking about.

Page 14567

1 Look at the conclusion that pertains to the procurement of uniforms for

2 the police. I think it's the second conclusion.

3 A. I think that we're now on page 2 and we need --

4 Q. Yes. I will now check what you're looking at, that we're now at

5 page 2 so that you can see that Mr. Simo Drljaca signed it.

6 MR. CVIJETIC: [Interpretation] Can we go back to page 1, please.

7 Q. Yes, well, now you can see it.

8 So you see the conclusion, number 1, Simo Drljaca reports to the

9 Crisis Staff that the conclusion that the release of prisoners is

10 prohibited is fully observed.

11 You told us yesterday who was -- who had the right to decide on

12 the fate of the prisoners. And you can see conclusion number 2, that the

13 Crisis Staff is dealing even with the procurement of police uniforms.

14 Mr. Rodic, let me just ask you: This is something that the state

15 should be dealing with. The state should be in charge of procuring

16 uniforms for the police; right?

17 A. Well, as far as I know, supplying the police and the army was

18 always done not at the municipal level but at the level of the republic

19 or of the state.

20 Q. And then you can look at the conclusion about the police staff

21 payroll. I think that's conclusion number 5.

22 You see this conclusion. It says LD. That would be the salary

23 of the police staff -- force. Force.

24 A. Yes I do apologise.

25 Q. Can you see it?

Page 14568

1 A. Yes, I can. Well, I wasn't able to see it because you gave me

2 the wrong reference.

3 Q. I think that your comment regarding the uniforms would apply also

4 to the salaries. Salaries should be paid from -- by the state, not by

5 the municipality; right?

6 A. That's how it had been until the war broke out, and I think that

7 the municipalities have nothing to do with it now. This is not done at

8 the municipal level.

9 Q. And now look at the last paragraph on this page where Mr. Drljaca

10 refers to an order of the Crisis Staff to establish an intervention

11 platoon, a joint intervention platoon, that would also include members of

12 the military police. Can you see it?

13 A. Yes, it's the last one here.

14 MR. CVIJETIC: [Interpretation] In the English version, that would

15 be on the next page.

16 Q. You see that conclusion?

17 A. Yes, yes, I see. The one that pertains to the establishment of

18 this unit.

19 Q. Now my question is very brief: Were you aware of the existence

20 of such a unit; and, if so, who had established it?

21 A. I would see people from that unit from time to time, but I did

22 not know who had established it and on whose orders.

23 Q. Very well. Perhaps this is a good opportunity for me to show you

24 the document on the establishment of this unit.

25 MR. CVIJETIC: [Interpretation] Therefore, can we please have

Page 14569

1 Exhibit P803.

2 Q. Mr. Rodic, you can see the date. And it says the Crisis Staff.

3 Can you please read the order that Mr. Drljaca had referred to in the

4 previous document. Can you please have a look at it.

5 Did you manage to read it?

6 A. Yes, I did.

7 Q. Very briefly, to the extent that you are aware of, the

8 establishment of special police units, according to the Law on Internal

9 Affairs, is exclusively under the jurisdiction of the minister of the

10 interior; is that right? Or, rather, do you know that?

11 A. I think I agree with you. Usually it would be

12 higher-level organs, i.e., the ministry, would take care of personnel

13 issues, recruitment, provision of uniforms, and salaries, et cetera. So

14 this was a whole series of jobs that should have done by the ministry.

15 Q. But obviously in Prijedor this was done by the Crisis Staff; is

16 that right?

17 A. According to what I see in front of me, yes, that is correct.

18 Q. Let me just show you one more document issued by the

19 Crisis Staff.

20 MR. CVIJETIC: [Interpretation] Can we please have 1D00-0924.

21 JUDGE DELVOIE: Mr. Witness, did you know about this? Did you

22 know that it was the municipality who paid for and bought uniforms and

23 created a platoon?

24 THE WITNESS: [Interpretation] No, I didn't know exactly that

25 these kind of decisions had been taken. I didn't know that. But I did

Page 14570

1 notice that this unit had been established, but I don't know on whose

2 orders.

3 JUDGE DELVOIE: Mr. Cvijetic, then the next obvious question is:

4 What's the purpose of this line of questions? It concerns documents that

5 are already admitted. What's the purpose of learning this witness things

6 he doesn't know? Shouldn't you try to learn the Court things -- tell the

7 Court things we don't know?

8 MR. CVIJETIC: [Interpretation] No, Your Honours. I am pursuing

9 this line of questioning in an attempt to elicit from witness for -- what

10 he perhaps know. But it turns out that the witness is not aware of

11 search facts, and I cannot know in advance what he was or wasn't aware

12 of. So the next document, I think, was not admitted into evidence. But

13 I wanted to ask him about the blockade of the town that is mentioned in

14 this document, and I wanted to ask him if he knew anything about that.

15 Q. Mr. Rodic, have you read this document?

16 A. Yes, I have.

17 I don't know what was undertaken in this respect, but I know that

18 there were check-points around the town on the main roads. But whether

19 there were any activities involved, I don't know.

20 Q. Was that felt, or did it affect the freedom of movement and the

21 possibility for people to leave Prijedor? Can you tell us anything about

22 that?

23 A. I couldn't tell you anything about that because during that

24 period, I moved very little around the town. And, besides, I don't know

25 how these check-points operated.

Page 14571

1 Q. Mr. Rodic, I have no further questions for you. I have finished

2 my cross-examination.

3 MR. CVIJETIC: [Interpretation] Your Honours, I have no questions

4 for this witness.

5 JUDGE HALL: Mr. Olmsted.

6 MR. OLMSTED: Thank you, Your Honours.

7 Re-examination by Mr. Olmsted:

8 Mr. Rodic, I want to return one more time to this delegation

9 visit to Keraterm camp.

10 How soon after this delegation visited Keraterm did the guard

11 tell you that Mr. Zupljanin was part of that delegation?

12 A. I told you yesterday that I wasn't able to pin-point the date.

13 Therefore, I honestly cannot tell you how soon it happened after the

14 visit. I don't know if it happened concurrently. I cannot tell you more

15 than what I already told you, and that is what the guard told me. And I

16 cannot make any further comments on that.

17 Q. Well, you testified that you recall hearing sounds of cars coming

18 that day and arriving at Keraterm. Is that what prompted you to go down

19 and ask the guards what was going on, was there a delegation here, who

20 was in it?

21 MR. KRGOVIC: Can I have a reference when the witness said that

22 about the car?

23 MR. OLMSTED: Yes. If you look at transcript page 14499.

24 JUDGE HALL: Mr. Olmsted, unless I am wholly missing the thrust

25 of your questions, it seems to me that you're on an impossible quest, if

Page 14572

1 you're trying to establish the fact of -- of the -- who was present from

2 this witness's testimony, because he's explained that he didn't know. He

3 heard, and he heard this from the guards. And can -- can -- can you

4 go -- can you take the witness further?

5 MR. OLMSTED: Well, the only place I want to go further is -- is

6 when he had this conversation with the guards. And he's having trouble

7 remembering that. And I'm trying to associate with him finding out

8 that -- or hearing that a bunch of cars were coming and whether that's

9 what prompted him to go speak to the guards about this event. If he

10 can't answer it, then that's fine.

11 Q. So, Mr. Rodic -- I'm sorry.

12 JUDGE HALL: I don't know if it makes a difference, but go ahead.

13 MR. OLMSTED: Yes.

14 Q. Just very quickly, Mr. Rodic. You testified during the

15 examination that you heard sounds of cars arriving that day. And my

16 question to you: Is that what prompted you to go down and speak to the

17 guards about this delegation?

18 MR. KRGOVIC: First of all, it's leading. First you ask him: Did

19 he go to ask guard or not. And when. If he was there.

20 MR. OLMSTED: I don't believe it's leading, Your Honours. It's a

21 question, whether him hearing these vehicles arriving that day, that's

22 what prompted him to go and speak to the guards about this delegation

23 that he has talked about, that he has testified about.

24 JUDGE HALL: Whether it is leading, Mr. Olmsted, I would have

25 thought that you would have taken the hint from the Bench that whatever

Page 14573

1 the answer is, it doesn't matter.

2 MR. OLMSTED: Then I'm just going to move on.

3 Q. Mr. Rodic, you testified during the examination that once you

4 submitted your Official Notes from Keraterm to the typist, that was the

5 last you saw of them. Today Mr. Cvijetic suggested to you that these

6 Official Notes ended up in the hands of Simo Drljaca, and I think you may

7 have agreed with that.

8 Can you tell us, do you know whether, in fact, your

9 Official Notes they were actually given to Simo Drljaca?

10 A. I did say that the Official Notes were sent to the SUP. I didn't

11 tell Mr. Cvijetic that it was Mr. Simo Drljaca who received them. I just

12 said that they were sent to the SUP, and that is what I said.

13 MR. OLMSTED: Let's take a look at 1D166.

14 Q. And you'll recall this. A few minutes ago you were shown this by

15 Mr. Cvijetic. This is an order regarding Omarska camp by the CS -- or

16 the SJB chief from Prijedor.

17 MR. OLMSTED: And if we could just turn to the last page of it.

18 Q. Now, we can see that there are a list of seven organs to which

19 copies of this order were submitted. And we see under number 3 the

20 Security Service Centre in Banja Luka.

21 Mr. Rodic, given the system of subordination that existed in

22 1992, was this an appropriate action for the SJB chief to submit an order

23 he issued to the CSB?

24 A. Well, some documents definitely had to be sent to the chief of

25 the CSB, and I see that one of the recipients is the Banja Luka CSB.

Page 14574

1 Q. Now, Mr. Krgovic asked you some questions about police roadblocks

2 or check-points that were near Keraterm, or possibly near Keraterm, on

3 the morning following the room 3 killings.

4 I want to show you P1009.

5 Now, this is a dispatch from SJB Prijedor to CSB Banja Luka dated

6 24 July 1992. And we see it reports that due to well-known events in

7 Prijedor, the police and military police have established mixed

8 check-points at all entrances to and exits from the town of Prijedor,

9 traversed by main roads.

10 Now, you testified that you didn't encounter any check-points

11 between Prijedor town and Keraterm camp that day, the day following the

12 killings in room 3. But can you tell us whether there were any

13 check-points that existed past Keraterm; in other words, further along

14 the way to Banja Luka?

15 A. When we spoke about that day and I said that on our way in and

16 out, or, rather, that there were no roadblock -- check-points on the day

17 we came close to Keraterm. If that was the question.

18 There were some check-points, as I said earlier today, but I

19 myself didn't pass through them, and I don't know for what purpose they

20 had been set up.

21 MR. OLMSTED: Your Honours, this was marked for identification.

22 May it be admitted into evidence?

23 MR. KRGOVIC: No, Your Honour, there is -- I object to that.

24 There is no nexus between -- because the witness never passed through the

25 check-points. And, first of all, this line of question doesn't appear

Page 14575

1 from my cross-examination. I asked precisely about the on-site

2 investigation blocking the road nearby Keraterm.

3 JUDGE HALL: I'm not sure I follow, Mr. Olmsted, how you're

4 seeking to tender this document through this witness.

5 MR. OLMSTED: Yes, this witness has now established there were

6 check-points. He didn't have to pass through them that day, but there

7 were check-points, and he doesn't know why they existed. And this

8 document does establish that these -- these check-points existed as well.

9 And so it corroborates his testimony.

10 It has already been marked for identification, and so we're

11 simply seeking now to admit it into evidence.

12 [Trial Chamber confers]

13 JUDGE DELVOIE: Mr. Olmsted, the witness says there were some

14 check-points. But this document obviously he doesn't know about. Why --

15 why should we take it in? We have the statement of the witness in. Why

16 would we take it in with this witness?

17 MR. OLMSTED: Well, Your Honours, I mean, other than calling the

18 person who signed this, I don't think we're going to have another option

19 as to a witness who can speak about check-points in and around the

20 Prijedor area. And so this is really corroborating that issue as well as

21 addressing the issue that Mr. Krgovic is trying to raise that there

22 weren't such check-points existing around this time-period.

23 MR. KRGOVIC: [Interpretation] Your Honours, I directly asked the

24 witness about a previous testimony, that is to say, whether there was any

25 roadblock before Keraterm and that traffic was stopped. And that was the

Page 14576

1 only focus of my question. I didn't ask him about any other check-points

2 in or out of Prijedor.

3 And now we are talking at length here about some check-points

4 that the witness had never gone through. So it has nothing to do with

5 either my cross-examination or the response given by the witness.

6 MR. CVIJETIC: [Interpretation] Your Honours, just one sentence in

7 support of Mr. Krgovic's objection:

8 We have been repeatedly hearing from the OTP that they have no

9 other witness through whom they can introduce this document. This is not

10 a sufficient argument for introducing the document through any witness.

11 They can be -- that can be done in a different way. We just shouldn't

12 try and force the issue and admit this document into evidence through

13 this witness. And I don't think that, what the Prosecutor says, that he

14 doesn't have a proper witness, will suffice.

15 JUDGE HALL: With respect, Mr. Cvijetic, I agree entirely with

16 what you have just said.

17 Mr. Olmsted, in our view, this document is not admissible.

18 And it is time for the break, so we will adjourn and resume in

19 20 minutes.

20 [The witness stands down]

21 --- Recess taken at 3.45 p.m.

22 --- On resuming at 4.14 p.m.

23 [The witness takes the stand]

24 MR. OLMSTED: And if I may begin, could we have Exhibit P601 on

25 the screen.

Page 14577

1 Q. Mr. Rodic, yesterday you had a chance to look at this document

2 and answer some questions about it with -- from Mr. Krgovic. And it's a

3 decision by the CSB chief establishing a commission. And as Mr. Krgovic

4 explained and as we can see from the document itself, the commission had

5 a significant number of tasks assigned to it, including visiting three

6 municipalities, Prijedor, Sanski Most, Bosanski Novi; establishing the

7 existence of detention facilities in these three municipalities;

8 determining why they were created, how they functioned; determining who

9 was detained there and what conditions; and establishing whether the

10 persons were leaving these three municipality, either voluntarily or by

11 force.

12 Now, we can see that the document is dated the

13 14th of August, 1992.

14 MR. OLMSTED: And if we can turn to the next page in the English

15 but stay where we are in the B/C/S.

16 Q. We see that, towards the end of this document, that this -- that

17 the commission's given until 1200 hours on 17 August 1992 to submit a

18 report on these various issues.

19 Mr. Rodic, based on your experience as a SDB officer, as well as

20 your knowledge of the situation that existed in mid-August 1992, was

21 three days sufficient time for a commission to interview everyone they

22 needed to interview in order to provide a thorough analysis of all these

23 issues?

24 A. Well, I don't know what the commission members used to gain this

25 information, so I cannot be more specific about it. There are two or

Page 14578

1 three days here; I don't know whether it was sufficient for them or not.

2 I really cannot make any comments. And now as for what they used in

3 order to put together this report, I don't know that.

4 Q. During this time-period, August 1992, do you recall whether --

5 well, let me ask you this: Given the conditions of the roads and

6 restrictions on travel in August 1992, how much time would it take to

7 travel between Prijedor, Bosanski Novi, and Sanski Most? Could you do

8 that in a day?

9 A. Well, it -- it can -- it takes you half an hour to travel that

10 distance. I don't know why it would take you a whole day. It's

11 30 kilometres or so.

12 Q. And just to clarify, transportation was free between those

13 various locations at this time, August 1992? In other words, there was

14 no reason to delay travelling between those municipalities?

15 A. Well, I can't see any reason for any delays in that period. I

16 don't see any reason why it would take a long time to travel from one

17 point to another.

18 Q. In this time-period, mid-August 1992, do you recall whether there

19 was a lot of international media attention concerning the detention camps

20 in Prijedor?

21 A. Well, I can't say anything about media attention. But there were

22 some reports in our media, and I had no opportunity to follow any other

23 media, to watch or to read any other media.

24 Q. Now, in response to a couple of Mr. Krgovic's questions yesterday

25 and today, you mentioned that you were at Omarska camp for a couple of

Page 14579

1 days towards the end of May of 1992. Can you tell us, what did you do

2 while you were at Omarska camp during those couple of days?

3 A. Well, I said that I spent a day or two up there from the time

4 when the investigation centre opened. We started performing some

5 investigative measures. But this was a very short time-period, and I

6 think that they went on doing that, up there.

7 Q. And just to clarify, were you interviewing detainees while you

8 were at Omarska?

9 A. Well, in a day or two, I performed just a few interviews, minor

10 stuff, because the work was just starting at the time.

11 Q. And I believe it was suggested in your previous answer but it

12 appears you didn't go alone. Did you go with other members of SDB and

13 SJB to Omarska?

14 A. Yes. I didn't go there on my own. The colleagues who were with

15 me in Keraterm and a number of colleagues who remained up there, working

16 up there, they all went with me.

17 Q. Was Goran Novic amongst those that went with you to perform these

18 interrogations?

19 A. I think he was.

20 Q. And was he one of the individuals who stayed at Omarska to

21 continue on with interrogations after you returned to Keraterm?

22 A. Yes, he was.

23 Q. Thank you, Mr. Rodic.

24 MR. OLMSTED: Your Honours, I have no further questions.

25 JUDGE HALL: Mr. Rodic, we thank you for your assistance to the