text:
1 Tuesday, 17 May 2011
6 Mr. McCloskey, is the next witness ready?
7 MR. McCLOSKEY: Yes, Mr. President.
8 Just a couple of housekeeping matters.
9 I have been meaning to and I've forgotten to offer in the revised
10 Obradovic organisation chart, which you'll remember we did some revisions
11 based on his testimony. We've discussed that with Mr. Gajic, and that
12 is -- it's now ready to go. It's 65 ter 7295. I think you had a hard
13 copy that is not quite complete and correct, so if you can throw that
14 away. We can get you another hard copy, if you'd like. We'll have a --
15 JUDGE FLUEGGE: I was assuming that you would use it with the
16 current witness.
17 MR. McCLOSKEY: We actually have a very similar org [phoen] chart
18 helped -- that was helped developed by this witness, so it will be
19 reflective of the other one. Everyone sees these things a little
20 differently, but he'll have it. So this witness will have his own that
21 will come in soon.
22 JUDGE FLUEGGE: Thank you very much. We would like to receive
23 the hard copy of it. That would assist us. And then we will decide
24 about your move to tender it.
25 The Court Usher will be so kind to -- do you have it available at
1 the moment or at a later stage?
2 MR. McCLOSKEY: I don't have the hard copy right now. It should
3 be -- it's not hard. We'll print it right out and it will come very
4 soon.
5 JUDGE FLUEGGE: Very good.
6 MR. McCLOSKEY: I don't know if he's going to give it a number or
7 not, but --
8 JUDGE FLUEGGE: We will do that at a later stage, when we have
9 seen it.
10 MR. McCLOSKEY: Okay. All right.
11 And, Mr. President, as you know, the time estimates for this
12 witness have varied. I have had a chance to speak to him now, and it is
13 my hope I can get direct done within two days. He acknowledges he is --
14 uses a lot of words, and he understands I may interrupt him a bit, but --
15 and it's very difficult to estimate these things, but I really hope to
16 get this done within two days. And I, as always, invite Your Honours to
17 ask questions. It's such a broad topic that it's hard to always judge
18 specifically your interests. So I have no problem being interrupted, and
19 that's always very helpful when you do that.
20 JUDGE FLUEGGE: You shouldn't be too optimistic in your
21 estimation, Mr. McCloskey.
22 MR. McCLOSKEY: Well, that's true. I want to leave myself some
23 room because I really -- it's so hard to tell, though.
24 And, lastly, I would request a caution for this witness.
1 The witness should be brought in, please.
2 [The witness entered court]
3 JUDGE FLUEGGE: Good morning, sir. Welcome to the courtroom.
4 Would you please read aloud the affirmation on the card which is
5 shown to you now.
6 THE WITNESS: [Interpretation] Good morning, Your Honours.
7 I solemnly declare that I will speak the truth, the whole truth,
8 and nothing but the truth.
9 WITNESS: MANOJLO MILOVANOVIC
11 JUDGE FLUEGGE: Thank you very much. Please sit down and make
12 yourself comfortable.
13 On the request of the Prosecution, I would like to give you a
14 caution.
15 In our Rules of Procedure and Evidence, we have the Rule 90(E),
16 and I would like to read it out for you. I quote:
17 "The witness may object to making any statement which might tend
18 to incriminate the witness. The Chamber may, however, compel the witness
19 to answer the question. Testimony compelled in this way shall not be
20 used as evidence in a subsequent prosecution against the witness for any
21 offence, other than false testimony."
22 Sir, did you understand what I was reading to you?
23 THE WITNESS: [Interpretation] Yes.
24 JUDGE FLUEGGE: Thank you very much.
25 Mr. McCloskey is now commencing his examination-in-chief and
1 putting questions to you.
2 Mr. McCloskey.
4 Examination by Mr. McCloskey:
5 Q. And good morning, General.
6 A. Good morning.
7 Q. Can you please state your name for us.
8 A. Manojlo Milovanovic.
9 Q. And where were you born?
10 A. I was born on the 21st of November, 1943, in the village of
11 Laminci, the municipality of Gradiska, entity of Bosnia and Herzegovina,
12 state of Bosnia.
13 Q. And can you tell us, are you currently employed or retired or
14 engaged in something?
15 A. I'm a lieutenant general retired for 10 years now. At the
16 moment, I'm a senator of Republika Srpska. That means that, in a way,
17 I'm involved in politics, and I mostly -- I'm dealing with the issues
18 relating to The Hague Tribunal.
19 Q. And can you tell us what your title of your position was
20 throughout the war in Bosnia from 1992 through 1995? Just your simple
21 title, and then we'll get into more details later.
22 A. Throughout the war, from the 11th of May, 1992, until the
23 27th of April, 1997, I was the Chief of the Main Staff of the
24 Army of Republika Srpska, and at the same time I was the deputy
25 commander.
1 Q. And now can you take just a few minutes and tell us about your
2 military career, just where you first started out, some of your
3 significant promotions, and especially when you first met General Mladic.
4 But if you could just take three, four, five minutes, perhaps, to give us
5 that run-down. I know we could spend a lot longer, and I don't mean to
6 understate your record. But if you could just take a few minutes and
7 tell us, I think that's a good way to start.
8 A. When I completed my elementary school in 1959, I applied, and it
9 was a miracle that I was accepted into the Military School in Banja Luka
10 for armoured units. I completed that school, and I was sent to the
11 Benkovac Garrison for service, where I spent 14 months as the -- as a
12 non-commissioned officer, commander of a tank platoon. Then I went to
13 the Military Academy of the Land Army --
14 Q. As you know, you're being translated, and I can tell the
15 translator is having a bit of a hard time, so if you could slow down. It
16 will be a little unnatural, but especially let's -- you and I need to get
17 a good pace, because it will get more difficult as we go.
18 A. Very well. I apologise.
19 I completed the Military Academy in September 1966, and I
20 remained in service in the Banja Luka Garrison, where I stayed until
21 1975, when I was sent for additional training to the so-called
22 Higher Military Academy or the General Staff School for Tactics, where I
23 spent two years. I completed that school in 1977, and then I was
24 transferred to duties in the Prilep Garrison in Macedonia, where I stayed
25 for slightly less than four years. Then I was --
1 Q. General, sorry for interrupting. Can you tell us what rank you
2 started out in, in Macedonia?
3 A. I went to Macedonia as captain first class. And then in Prilep,
4 I was promoted to major in September 1979. In early January 1981, I was
5 transferred to the Titov Velez Garrison. Actually, in Prilep I was
6 commander of the armoured battalion. In Velez, I became an operative in
7 the motorised brigade. I stayed in Velez for nine years, and in
8 1986/1987 I completed the Operations School or War School. I completed
9 that training, and I returned to the Velez Garrison and was appointed
10 commander of the 212th Motorised Brigade. I stayed at that post for some
11 two and a half years, and then later --
12 Q. Again, I'm sorry. Could you tell us what rank you held when you
13 were commander of that post?
14 A. As an operative, I held the rank of major until 1984, when I was
15 promoted to lieutenant-colonel. And as lieutenant-colonel, I went to
16 complete the War School training. When I returned from school, I assumed
17 duties in the already-mentioned 212th Motorised Brigade, where I remained
18 for two and a half years, approximately. And then in January 1989 I was
19 transferred to the 3rd Army Command or the 3rd Military District in
20 Skopje, where I was the chief of the operations organ or the
21 Operations Administration. In 1990 I was promoted to the rank of
22 colonel, and I stayed at that post until shortly before the withdrawal of
23 the JNA from Macedonia in 1992. Then I was tasked with organising the
24 withdrawal of the combat section of the JNA from Macedonia according to
25 the agreement between the president of the newly-created
1 Republic of Macedonia, Kiro Gligorov, and the Chief of the
2 General Staff of the JNA, General Blagoje Adzic. The condition was for
3 the JNA to withdraw without firing a single bullet, which was done.
4 Shortly before the withdrawal of the JNA, I was appointed as
5 chief of the operations and training organ as a general. I was promoted
6 to the rank of general on the 26th of April, 1992. And on the
7 8th of May of that same year, I received a degree or, rather, an order
8 for transfer to the Sarajevo Garrison to carry out the same duties that I
9 was carrying out in the 3rd Army Command in Nis.
10 Q. All right. Can you continue your description until we get up to
11 May 11th and the creation of the Main Staff of the VRS?
12 A. Well, in your previous question, there was a sub-question asking
13 me how long have I known General Ratko Mladic. I met General Mladic when
14 he held the rank of major in April 1981. He was working at the
15 3rd Army Command at the time, at the training organ, and he came to
16 inspect my brigade. I was assigned to escort him that day. Well, the
17 way we met was not all that great, actually, but later we co-operated
18 very well.
19 Together, we were transferred to the 3rd Army Command. I was
20 transferred there from the Command of the 212th Brigade, and he was
21 transferred there from the duty of the Command of the 39th Brigade in
22 Stip. I mentioned the decree by the SFR -- by the SFRY Presidency on my
23 transfer to Sarajevo. According to that decree, I was to supposed to
24 perform/carry out the same duties in the 2nd Army Command in Sarajevo
25 that I was carrying out in the 3rd Army District. The dead-line for the
1 transfer was the 11th of May, 1992.
2 Previously, I had to report to the General Staff of the JNA,
3 which existed then still, in order to receive the original documents for
4 transfer, for my promotion to the rank of general, and to receive an
5 explanation where I was going and why I was going. I reported to said
6 administration. Well, there was an agreement the previous -- for
7 Ratko Mladic and myself to meet the previous day at the JNA Command.
8 When I arrived, he wasn't there. I reported to the chief of the
9 Personnel Administration, General Gojko Krstic. He gave me these
10 documents, but he also told me about some changes.
11 In the meantime, the Dobrovoljacka incident occurred in Sarajevo
12 on the 3rd of May, when JNA soldiers were victims, and the General Staff
13 of the JNA decided to replace the then commander of the
14 2nd Military District, General Milutin Kukanjac, and his Chief of Staff.
15 The change in the transfer order was to appoint Mladic as commander of
16 the 2nd Military District, and I was appointed as the Chief of Staff. I
17 objected as to why I was going to Sarajevo when I was told at the time of
18 the decision of the Presidency of the SFRY that the JNA was withdrawing
19 from Bosnia-Herzegovina and it should be done by the 19th of May, meaning
20 that this had to be done in less than eight days. I asked him, Why am I
21 going to Bosnia if the JNA was disappearing from Bosnia? I was told that
22 a helicopter would take me where I'm supposed to go and that
23 General Mladic would explain all the details to me.
24 I flew into some forest. This was Crna Rijeka, some nine
25 kilometres north-east of Han Pijesak. I didn't meet up with Mladic or
1 Kukanjac or that Chief of Staff who I was supposed to replace. Mladic
2 flew in from Herzegovina sometime in the afternoon, towards evening.
3 Since I found out that General Perisic was withdrawing from
4 Herzegovina as part of the JNA forces - up until that time he was in
5 command of the Bileca -- the Herzegovina Corps - I thought that I would
6 probably go to replace Perisic. However, when Mladic flew in, when he
7 landed, this was some 50 metres away from the hut. We crossed this
8 within some 45 minutes or an hour, and he told me during that time what
9 all of this was about. He told me that it was correct --
10 Q. Excuse me, General. Let me stop you there and just go back a
11 little bit.
12 You had mentioned that you had worked, I believe, well with
13 General Mladic, but it wasn't clear in what context you were working.
14 Were you in the same unit, were you in neighbouring units? And can you
15 just take a minute or two just to describe for how -- what period of time
16 you worked with him and in what context, prior to the Crna Rijeka
17 helicopter.
18 A. Well, after we met in April 1981, Mladic left the army command
19 soon after that and went to Ohrid to be the commander of the infantry
20 regiment. We would meet during exercises, mostly the joint army
21 exercises. And then I can't remember exactly what year this was, Mladic
22 was transferred when there was a reorganisation of the JNA and when corps
23 were formed. Mladic was transferred to Stip to be the commander of the
24 39th Infantry Brigade. I was still an operative in the 212th Brigade.
25 Stip and Velez are some 48 kilometres apart. The AORs of our brigades
1 actually touched at Ovca [phoen] and Bregovnice [phoen], so that we had
2 frequent contacts. Mladic would always be one step ahead of me in
3 command and operative duties. However, when we applied for the
4 Operatics [as interpreted] School, the War School, we both found
5 ourselves in Belgrade, he as the brigade commander, and I was still an
6 operative in the brigade. But we did complete this school together. We
7 travelled together from Macedonia to Belgrade and back. We worked
8 together, since we were close. We did our homework together and prepared
9 our seminars for school.
10 When we came back from school, I began my duties in the
11 212th Brigade, so from that time on we were equals. We co-operated well.
12 But as far as the professional area is concerned, we always had opposite
13 views. Our objectives were the same, but the way to get to that
14 objective was different. So we would often clash on professional
15 matters, and then the chief of the army staff or the army commander would
16 have to reconcile us. Then together we came to the army command, Mladic
17 as the chief of the training organ, and I was the chief of the operations
18 organ in the same operations and training organ. That means that we
19 worked as equals and co-operated in our jobs.
20 The duties of the operations and training organ, among other
21 things, included the training of command superior officers. We would
22 prepare the staff wartime exercises, command staff exercises. When there
23 were problems in Kosovo, the two of us made the plans of the show of
24 force, the replacement of units in Kosovo. We co-operated there
25 together. There were always sparks between us, but we always managed to
1 find a common language.
2 When I learned that I would be Mladic's deputy during the war, I
3 was a little concerned that Mladic would have his revenge on me from
4 everything from the peacetime period. After six months, actually, he
5 explained this by saying that he asked for me to be his deputy, and he
6 literally said this: I ignite in the first gear, and you ignite in the
7 third gear, and the best driving is done in the second gear. So before
8 setting out on an assignment, I would always analyse the consequences.
9 And Mladic always made his decisions much faster, so that he felt that
10 these two temperaments would actually work well together and balance each
11 other out. During the war, we didn't have any problems between us.
12 Q. All right. And now let's go back. I believe it's May 11th when
13 you both meet in Crna Rijeka, and can you briefly tell us about that?
14 Who was there, what happened there? But briefly. We need to, as you
15 know, get to the 1995 period relatively soon.
16 A. As I've said already, I waited for him at the helio-pad. We
17 greeted each other and congratulated each other on our promotions. The
18 same decree pronounced me to major general, pronouncing him to lieutenant
19 general. Forty-five minutes later, we entered one of the two existing
20 barracks. In one room, there were some 10 people waiting for us. There
21 were four generals in total: Mladic, General Djukic, General Gvero, and
22 myself. There was seven colonels and lieutenant-colonels, and one
23 captain first class, Pecanac. Among them was the then Colonel Tolimir.
24 Mladic introduced us.
25 I had known General Gvero from before. He used to be a professor
1 in the Political School of the JNA, which I completed in 1982. I saw
2 General Djukic for the first time. He was an elderly gentleman of
3 aristocratic poise.
4 When Mladic introduced Colonel Tolimir, I may have pulled a face
5 or made an expression because I used to work with another Tolimir in
6 Banja Luka who was Slovenian, and I thought that this Tolimir was a
7 Slovenian too. But Mladic told me, Don't be afraid, he's a greater Serb
8 than you are.
9 Mladic told us that the next day, on the 12th of May, the
10 People's Assembly of the RS would hold a session in Banja Luka, during
11 which a decision was to be made to establish the
12 Army of Republika Srpska. If there were going to be additional
13 explanations as to why the Serbs were establishing their army that late
14 in the war, we can discuss that later. That evening, Mladic explained to
15 us what our respective tasks were. He told me, although these were all
16 assumptions at the time only -- well, he said that I was to -- that he
17 was to command the Main Staff and that I was going to be his
18 Chief of Staff and deputy. Gvero was supposed to be assistant commander
19 for morale and religious issues. Tolimir was to be the chief of the
20 Intelligence and Security Administration. General Djukic was to become
21 his assistant for logistics or, rather, chief of the Logistics Sector.
22 There was another colonel of artillery and rocket units by the
23 name of Krstic who was to withdraw from the JNA by the 19th of May, and
24 he was to be replaced by Colonel Jovo Maric, who was a pilot and was with
25 the Air Force Administration.
1 Q. General, let me interrupt you. This Court is, of course,
2 familiar with Radislav Krstic, the commander of the Drina Corps. Is this
3 Krstic you've just mentioned a different Krstic?
4 A. It's a different Krstic. This Krstic that you are referring to
5 was an infantryman. The one I found in the newly-formed Main Staff was
6 an artillery and rocket units colonel. He was in the Command of the
7 2nd Army, and we received him that evening, since he was well acquainted
8 with the anti-aircraft and air force defence systems. So it's not the
9 Radislav Krstic you have in mind.
10 On the list for that evening, there was also
11 Colonel Petar Salapura. Mladic told him that he was to be the chief of
12 the Intelligence Administration in the Intelligence and Security Sector.
13 However, he wasn't there that evening because he had already gone to
14 execute a task.
15 We discussed throughout the night. We didn't have the war goals.
16 None of us, save for Mladic and perhaps Tolimir, was in contact with the
17 Presidency of the RS. Therefore, we didn't know why the army was being
18 formed. We could presume, though. It was to be formed as the last armed
19 force in the territory of the former SFRY, the seventh force in a row.
20 We discussed, we made conclusions, we weighed proposals as to what the
21 army should be structured like and what it was to do. We produced
22 21 conclusions. One of them -- well, they basically laid foundations for
23 the VRS, although I don't remember them all by heart. We also decided on
24 the doctrine, and I believe there were nine goals in total as part of
25 that.
1 First of all, it was supposed to be a defensive armed force.
2 Second, its task was to protect the Serb people and territory. One of
3 the goals was also to liquidate or eliminate the existing paramilitary
4 forces as well as municipal TO units which had been formed by the party
5 in power, the SDS, mostly in the municipalities on the outskirts of our
6 territory, neighbouring majority Muslim and Croatian population
7 municipalities.
8 Crisis staffs were taken out of the system of command of army
9 units, and there was another decision which said that if any of us was to
10 be replaced during the war out of the 12 of us, everyone would leave,
11 that is, if anyone was replaced for political reasons. We decided to go,
12 all of us, in such a case and to go to the trenches to take up arms. It
13 may have been a marketing decision of sorts at the time, but it was also
14 an obligation, an oath we undertook, which kept the homogeneity of the
15 Main Staff throughout the war. It was also thanks to that that the corps
16 commands remained together, because they joined us later on in the
17 execution of those goals. Thanks to that decision, I refused on three
18 occasions to assume General Mladic's position.
19 The next morning --
20 Q. Okay. If you want to get into the next morning, but be brief.
21 Remember -- I know those were very complex and important days in 1992,
22 but go ahead and tell us what happened the next morning, but in brief.
23 A. The next morning, everyone flew to Banja Luka to attend the
24 Assembly session. I remained in the Main Staff, however, to set it up
25 and to translate our discussions of the last night into bulletins,
1 information, and orders. I was also in charge of establishing
2 communication and command links with the subordinate units and was
3 supposed to monitor events of that day in the Bosnia-Herzegovina theatre.
4 As for establishing communication links with the subordinate
5 units, I was appalled to learn that the war was already underway, that
6 there was fierce fighting, although the army had not been formed, around
7 Sarajevo, for example. There was also fighting in all municipalities on
8 the outer rim of the RS territory. So when Mladic came back that
9 evening, I told him, Man, we're already at war.
10 By the end of that day, the Main Staff was formed and functional.
11 However, we were still short of staff. In the course of the first few
12 days, we relied on officers from the 2nd Army Command who had fled
13 Sarajevo as they awaited their transfer or withdrawal to Yugoslavia. The
14 gravest problems we had were in Sarajevo, Tuzla, Zenica, because the JNA
15 units there were surrounded, especially in Sarajevo, where the
16 Military Schools Centre of the JNA was under siege.
17 Q. Let me stop you there, General.
18 A. [In English] Okay.
19 Q. And did Colonel Ljubisa Beara join the Main Staff at some point
20 that year?
21 A. [Interpretation] Ljubisa Beara, as a naval captain, he used to be
22 in the navy, but he was an equal to a colonel in the land forces. He
23 joined us in September of 1991 -- 1992, although I am not positive. In
24 any case, I think it was in early September. He was introduced to us by
25 General Mladic. The two of them were walking around the buildings there.
1 When I came, I could see that they had known each other. And Mladic told
2 me that Beara worked in Split before the war, and in the Main Staff he
3 was supposed to be chief of the Security Administration in the
4 Intelligence and Security Sector. Therefore, we met that day and agreed
5 that any security issues that I had as the Chief of Staff should be dealt
6 with through Colonel Tolimir, who was chief of the Intelligence and
7 Security Sector.
8 In other words, I was not supposed to have direct contact with
9 the chief of the Intelligence and Security Administration. However, that
10 had to be done later on because of the nature of work I performed, which
11 was planning operations, and I always needed latest information on the
12 enemy.
13 JUDGE FLUEGGE: May I interrupt you for a moment. Judge Mindua
14 would like to put a question to the witness.
15 JUDGE MINDUA: [Interpretation] Witness, before we move on
16 [indiscernible] [microphone not activated]. There's one point I would
17 like to clarify.
18 JUDGE FLUEGGE: Now it's better.
19 JUDGE MINDUA: Okay, good.
20 [Interpretation] On the transcript, page 14, line 20 to 23, you
21 say that the war had already begun. The Army of the Republika Srpska had
22 not been established yet. Since you attended the meeting in Banja Luka
23 before the establishment of the Army of the Republika Srpska, who was
24 actually waging a war in Sarajevo?
25 JUDGE FLUEGGE: I'm afraid there's still a problem with the
1 microphone, perhaps in the interpreter's booth for French. I don't think
2 that this is a problem here on the Bench for the Judges.
3 Now it seems to be better.
4 JUDGE MINDUA: Okay, I will try again.
5 [Interpretation] On the transcript, page 14, lines 20 to 23, you
6 said that the decision to establish the Army of the Republika Srpska was
7 taken at the Assembly meeting in Banja Luka on the following day, but you
8 also said that the war had already started in Sarajevo. What I would
9 like to know is: Who was fighting who in Sarajevo? Who was waging a war
10 at that time?
11 THE WITNESS: [Interpretation] Indeed, I said so, although I must
12 say I understood your question the first time around. There was no need
13 for me, at least, to have it repeated.
14 When mobilisation was proclaimed by the Muslim-Croat coalition on
15 the 4th of April, it meant that on that day the armed forces of the
16 Muslims and Croats were formed. The Presidency of the RS responded by
17 proclaiming the so-called immediate threat of war. It organised its
18 Territorial Defence units in the areas neighbouring Muslim and Croat
19 territories.
20 On the evening of the 11th of May, on the eve of the
21 Assembly session, we had between 80- and 90.000 people who had arms. At
22 least that was the information Mladic gave us. They were organised in
23 two different types of structure or organisation. The first one were TO
24 units which were formed ad hoc in the various municipalities. The second
25 structure, which was smaller in size, were the various paramilitary
1 units, which were mainly introduced from or came from Serbia and
2 Montenegro. I have already told you what we decided to do with those
3 paramilitary units.
4 As for the TO units in the municipalities, they were engaged in
5 combat whenever the population of a village or town came under attack.
6 Those brigades responded to attacks, to challenges. They were headed by
7 only a few professional officers who were mainly reserve officers and
8 also members or people from the party in power. They mainly operated
9 under the command of municipal war staffs. At the outset of my
10 testimony, I told you that one of the decisions of the Main Staff was to
11 remove that right of command from the municipal staffs.
12 Before we became engaged in the war, the war was waged
13 exclusively by these TO units which were there to protect the population.
14 JUDGE MINDUA: [Interpretation] If I have understood you
15 correctly, these TO units were, in fact, Serb units. They were
16 protecting the Serb population; is that right?
17 THE WITNESS: [Interpretation] They were predominantly Serb units
18 or units comprising Serbs.
19 JUDGE MINDUA: [Interpretation] Thank you very much.
20 JUDGE FLUEGGE: Mr. McCloskey, please continue.
22 Q. General, going back to something you said, I was not exactly
23 clear. You said that initially you were not supposed to have direct
24 contact with someone, but I'm not clear on who that was. Can you explain
25 that again to me, briefly?
1 A. You mean when we discussed Beara?
2 Q. I think you were discussing the Security and Intel Branch and
3 your position, that initially you were to have restricted contact with
4 someone, but it came out sounding a little different. So could you just
5 explain that? I'm not sure we got the translation correct.
6 A. I did think of that. I may have misspoken.
7 In principle, command and control excludes the possibility of a
8 general or an officer having direct contact or co-operation with his
9 subordinate two levels down. The only need I had was to contact with the
10 Security or Intelligence Service which were in Tolimir's sector. In
11 doing so, I didn't go through his chiefs of administration; I went
12 straight through Tolimir, who was chief of sector. And then it was up to
13 him whether he would assign a particular task to the chief of his
14 Security or Intelligence Administration.
15 The principle of command and control is that one does not issue
16 commands to his subordinate two levels down. As opposed to that, I was
17 supposed to meet Karadzic's orders, who was two steps up. This is
18 another principle. But upon receipt of such an order, I had to report it
19 to General Mladic. By the same token, the chief of the
20 Security Administration, if he had an urgent matter to communicate to me,
21 he could, but he also had to acquaint Colonel Tolimir with having done
22 so, with getting in touch with me.
23 So this is a principle of subordination so as I could not meddle
24 in Tolimir's work or he in mine. That's it. Since when, on the first
25 day, I saw Beara, I could see that he was an imposing person, so to say,
1 and under such circumstances I told him I was not going to co-operate
2 directly with him but that we would communicate through Tolimir. For the
3 most part, it was so, although we did some direct contact in relation to
4 front-line issues. Even if we did so, it always had to be with the
5 approval or knowledge of General Tolimir.
6 Q. All right. And we will get into those command and subordinated
7 relationships a bit more, but thank you for that fundamental part.
8 Did that fundamental principle that you've just described remain
9 throughout the wartime period?
10 A. Yes, it did.
11 Q. Now, I know you have helped the investigation -- or the
12 investigator work out what we refer to as the VRS structure, showing the
13 commander, the units, the various positions, and I'm going to get to that
14 with you to help us understand it. I'm not going to spend a lot of
15 detail on that. The Judges have heard from other officers much of the
16 basics, but I will go into that with you some.
17 But before we get there, can you just take a couple of minutes
18 and describe how the structure worked in 1995, basically? And what I
19 mean by that is: Can you start with Karadzic, the supreme commander, and
20 what authority he had, and then go to Mladic, your position, the
21 assistant commanders, and the various corps and other units? Can you
22 just give us just a brief on how that structure worked and how the
23 authorities worked, starting with Radovan Karadzic? And this would be
24 for 1995.
25 A. Okay. As early as 1995, Radovan Karadzic became well versed in
1 his role of supreme commander because by that time he had spent some
2 three years in that position. At the outset, it wasn't quite clear to
3 him that he couldn't issue orders directly to me or to a corps commander,
4 but that all of his orders had to go through Ratko Mladic and then down
5 to his subordinates. These were some initial mistakes, which were
6 understandable because he was not a military professional. By 1995, he
7 no longer made such mistakes unless he really intended to do so.
8 There are stories/rumours about the relationship between Karadzic
9 and Mladic. I don't know whether we will touch upon that topic. It very
10 much depends on you. But in 1995, Karadzic had a circle of stable
11 military advisers around him who made proposals to him at the strategic
12 level. Unfortunately, none of the advisers was trained and educated as
13 well as the Main Staff. They did not have the breadth of military expert
14 knowledge, and frequently they suggested to Karadzic things that did not
15 play out, in military terms. There was no military logic in it.
16 For example, I received an order that the VRS in the next
17 24 hours was to occupy a town. First of all, that town was not even in
18 the RS. Second, to occupy a larger settlement in 24 hours would require
19 at least a week's preparation. In other words, their proposals were
20 unprofessional.
21 In 1994, when making such decisions, Karadzic began consulting
22 with us from the Main Staff before making a decision. Such consultations
23 were supposed to be done in the Ministry of Defence, but even the
24 Ministry of Defence lacked trained personnel for such affairs, especially
25 since the minister of defence was a civilian, unlike before. But already
1 in 1995, but one may say even as of April 1994, with the beginning of the
2 NATO air-strikes, Karadzic started thinking more deeply about military
3 decisions. And during 1995, the co-operation with him was very good, up
4 until July or August 1995 when he again started meddling with the work of
5 the Main Staff and the authorities of the commander of the Main Staff.
6 I'm sure we will come to that during your examination.
7 General Mladic -- I don't know who hasn't had this bit of comment
8 on General Mladic, and I was also one of those people who had a lot to
9 say about him. He was a commander by nature, I cannot say from birth,
10 but he had charisma, he was persistent, decisive, a man who, whenever he
11 could or, rather, whenever it was necessary, so a man who protected his
12 subordinates. He was a role model for his subordinated officers,
13 commanders of corps and brigades and so on. During the war, he would not
14 reach rash decisions, and he would not reach decisions without having
15 consulted the Main Staff, up until mid 1994, when he did reach a few
16 decisions on his own, mostly because he wanted to achieve something
17 quickly, successfully. But very often, it didn't work.
18 At the time of the end of the war, he started having kidney
19 problems. He did not, however, spend much time in hospitals. His
20 illness was something that he had to live with in command posts and on
21 the battle-fields, and we understood that and we tried to assist people,
22 and the army had unlimited confidence in him.
23 If there were any conflicts between him and Karadzic, and they
24 were never direct, of course, these conflicts were along the lines of
25 who's going to be the first man in the state, both of them very
1 charismatic, both of them had great hunger for power. And they had
2 problems in understanding each other, but it would eventually happen.
3 And Mladic was duty-bound, of course, because of the structure of the
4 army, to carry out the government's decisions.
5 And let me just add, to avoid any confusion later on: I wrote to
6 you about how the Supreme Command of the Republika Srpska was formed or
7 established. Bearing in mind its composition, one can see that it was a
8 civilian body in charge of waging the war.
9 Mr. Karadzic, President Karadzic, was the supreme commander, as
10 the Constitution provided for, and the command also included two
11 presidents, presidents of the Assembly or speaker of the Assembly and the
12 prime minister. Do you want me to tell their names?
13 Q. For 1995. Anything that's applicable for 1995, yes, please.
14 A. Yes, thank you.
15 The president of the Assembly in 1995 and throughout the war, as
16 a matter of fact, was Momcilo Krajisnik. And in 1995, the prime minister
17 was Dusan Kozic, until, in late 1995, he was replaced by Gojko Klickovic.
18 No, I apologise, first by Rajko Kasagic and then by Gojko Klickovic.
19 In 1995, we had three prime ministers, and they were immediately
20 members of the Supreme Command because of their duty. Then minister of
21 defence who was also a member, Milan Ninkovic; and the minister of the
22 interior, I think at the time it was Tomo Kovac, because the ministers of
23 interior changed very often, but I think then it was Tomo Kovac. There
24 were also two vice-presidents of the republic who were at some stage also
25 included into the Supreme Command, Koljevic and Plavsic. In the
1 Supreme Command, there was no one from --
2 Q. Let me interrupt you. Yesterday, we heard the name of, I think,
3 Koljevic as a -- can you spell that name out, the vice-president person
4 that you just mentioned?
5 A. Nikola Koljevic.
6 Q. Thank you. Now, I'd interrupted you, but had you just -- I think
7 you'd just about finished that thought.
8 A. No one from the Supreme Command, with the exception of Karadzic,
9 had the authority of -- had the order-issuing authority; only Karadzic.
10 All links between the Main Staff and the Supreme Command went through
11 Karadzic. Members of the Supreme Command could make proposals, but
12 Karadzic was the one who was making all the decisions. We never carried
13 out orders by Krajisnik, Plavsic, or Koljevic, only the directives issued
14 by Karadzic.
15 Q. And was that established by the Constitution and Law of the RS,
16 Karadzic's authority to issue the orders to you? When I say "you," I
17 mean the Main Staff, Mladic.
18 A. According to the Constitution, the president of the republic is
19 also the commander -- the supreme commander of the armed forces.
20 However, the armed forces are not only the military. They comprise of
21 military, the police, and civilian protection. In other words, Karadzic
22 was in command of all these three segments, including the military, the
23 army.
24 Within his Supreme Command, he had people who were in charge of
25 police, mainly the minister of the interior. There was also a person who
1 was in charge of civilian protection. I don't know who he was. I think
2 it may have been the minister of defence. And he was the only one,
3 according to the Constitution, who had any authority over the army, who
4 could command the army.
5 Q. All right, General. So I think that's helpful to give us a
6 primer on the political structures upon which General Mladic was required
7 to follow. Can you just, in a -- and I know this is difficult, but just
8 in one or two minutes describe General Mladic's job. Just what -- and
9 the Judges have heard quite a bit already on this, but can you just tell
10 us what his job was as the commander of the VRS?
11 A. General Mladic was the commander of the Main Staff. That was his
12 title; not the commander of the VRS, but the commander of the Main Staff.
13 Q. Thank you for correcting me on that.
14 A. That implied, because the Main Staff is the body commanding the
15 army there, for Mladic, as the commander of the Main Staff, was the
16 commander of the army. So you didn't say it -- you didn't put it
17 wrongly. He was, in fact, the commander of the VRS, but that was not his
18 title, and you couldn't find that in his personal files, for instance,
19 because in conditions of war, in a state that has not yet been recognised
20 internationally and that has not yet been fully organised and that is
21 initiating the struggle for national liberation, one cannot find a main
22 staff, a general staff, because the state has not been established yet.
23 During war, a general staff becomes the staff of the
24 Supreme Command, in fact. So since we were at the beginning, the group
25 of people in charge or leading the armed struggle is called the
1 Supreme Command.
2 Tito, during the war, had a different body, but in different
3 republics, then of course in all the republics of the former Yugoslavia,
4 he had staffs that were in charge of liberating their areas from fascism.
5 In the same manner, we had a Main staff during the war, and the idea was
6 that after the end of the war, the Main Staff would become a
7 General Staff, and that did happen, indeed, in 1996.
8 Q. Okay. And can you just, as I said, in one or two minutes,
9 describe what General Mladic's job was. And after that, I'll ask you in
10 the same context, just tell us, as you've partly done, what the job of
11 the Main Staff was, the assistants and the other -- the sectors of the
12 Main Staff, but just generally and simply, just as a primer before we get
13 into the various sectors and describe more particularly what they did.
14 That may be confusing, so let me just -- just two minutes on what
15 General Mladic's job, as commander, was.
16 A. The job of General Mladic was, in brief, to command the
17 Main Staff. The Main Staff had 12 tasks. I provided them to you
18 yesterday, starting with the mobilisation of the army, which normally
19 would have been something carried out by the Ministry of Defence. But
20 since the Ministry of Defence was short-staffed, the Supreme Command or,
21 rather, the Presidency of Republika Srpska tasked the Main Staff to carry
22 that out because we did have a Sector for Mobilisation and Replenishment.
23 Furthermore, the Main Staff was in charge of establishing units
24 at all levels, from squads to corps. It was another of our tasks.
25 Furthermore, training of officers and soldiers, in other words, preparing
1 for combat. Then we had another role that should have been the role of
2 the Ministry of Defence, and that was the logistics for the army. Then
3 planning and carrying out combat operations, reporting to the
4 Supreme Command, receipt and processing of reports received from
5 subordinated units, approving or not approving requests from subordinated
6 commands. Or, in short, we did everything in charge -- everything that
7 needs to be done when one's at war.
8 One of the tasks was also security and intelligence support for
9 the army, which was under General Tolimir. Mladic was carrying out
10 orders by the Supreme Command. All of us were carrying out his orders.
11 And that would be it.
12 Q. And when you say you were all carrying out General Mladic's
13 orders, can you just give us a practical idea of how Mladic commanded? I
14 mean, did he issue orders?
15 A. General Mladic commanded by using the system or method of
16 meetings. In the Main Staff, we had an institution, the college of
17 commander, commanders' college. The staff would meet -- or collegium.
18 The staff would meet every morning and every evening. Between 6.00 and
19 7.00, we'd be receiving reports from subordinated commanders, and based
20 on these reports, we would jointly, as the staff, review the situation.
21 We would try and see what needs to be improved, what was good, what needs
22 to be done completely from the scratch.
23 Us seven assistants were giving proposals each for his own
24 sector. The logistics officer, the last one, would brief the staff on
25 the amount of ammunition and to tell us -- and I'll make it -- I'll
1 reduce it to absurd, but how many 7.62-millimetre bullets could be used
2 that day. Then Tolimir would inform us about the security situation in
3 the republic and the intelligence information about the intentions of the
4 enemy and so forth and would give proposals how to counteract that.
5 General Gvero would talk about the morale of the troops. Or if there was
6 a specific unit to -- that was carrying out any task, he would be the one
7 to say, No, this unit can easily carry it out, or, It will have
8 difficulties.
9 The Chief of Staff listens to all the reports and then gives
10 proposals to General Mladic on how to use his troops, be it individual
11 units or the army in total. I, for instance, would tell him, Let us
12 attack this specific hill or cut this specific communication. I have to
13 also tell him what the cost of such an action would be, which was based
14 on having heard all the reports before that. I provide my assessment of
15 the potential casualties on our side, and so on and so forth.
16 And then after having heard us, the General Staff would make a
17 break, and he would keep the most necessary among us for that decision to
18 stay with him and help him in reaching the decision. And about half an
19 hour later he would inform us about his decision. He might, on one hand,
20 tell us, word by word, what needs to be done, or he could say, Well,
21 we'll do what the Chief of Staff had proposed, or someone else.
22 When we were reaching major decisions about activities on
23 operational level, namely, when a corps or more corps are involved, then
24 we would call the corps commanders to the meeting, and that would be the
25 collegium in its extended version. The Main Staff can reach a certain
1 decision, but if the commander Novica Simic of the Eastern Bosnia Corps
2 says we cannot carry it out, then we haven't gotten anywhere. The corps
3 commanders are those who know what their capacities are at the moment,
4 and he can inform the staff if that is possible or not, and then we look
5 for solutions.
6 I think it was only our army that had this feature; namely, that
7 corps-level decisions were reached with the presence of all corps
8 commanders, which had its good consequence, this system. Namely, we
9 wouldn't have to inform other corps commanders, neighbouring corps, for
10 instance, what General Simic's task was because they were there at the
11 meeting.
12 Q. All right. Can I just --
13 JUDGE FLUEGGE: Just a moment, please.
15 MR. GAJIC: [Interpretation] Mr. President, I would like to ask
16 the witness to slow down a little bit. It is very difficult to follow
17 him, especially when one does it the way I do while listening to both
19 JUDGE FLUEGGE: You want to have everything under control. I
20 understand.
21 Please carry on, Mr. McCloskey.
22 MR. McCLOSKEY: Thank you.
23 Q. General, can we just clarify that. These morning -- you've
24 described a morning staff meeting and an evening staff meeting. Can you
25 just make clear for us: Who was at the morning staff meeting?
1 A. The morning meetings were in an expanded composition. All the
2 commanders' assistants were also present there, then chiefs of
3 administration. For instance, from Tolimir's sector, we would have three
4 people -- three persons present, Tolimir himself, and two administration
5 chiefs. From my sector, there would be the chief of
6 Training and Operations Administration, and General Miletic could also
7 bring his assistants, chief of Operational Department and the other one.
8 So the meetings involved the first and the second level of the
9 staff, including commanders' assistants and their subordinates.
10 In the evening meetings, because most of the officers would be in
11 their units and maybe last until midnight, they were held at 2.00 -- at
12 2000 hours and would last for a while. It would definitely include
13 either commander or myself and chiefs of sectors, and in their absence
14 they would have a chief of administration who would replace them; Beara
15 or Salapura, for instance, for Mr. Tolimir.
16 And at that meeting, all those who were practically in the staff
17 would be present, and a duty team which included 10 to 12 officers,
18 mainly representatives of branches and services. At that meeting we
19 would go through daily combat reports received from subordinated units,
20 and we would look for problems. This was usually the last item in their
21 reports. Mainly, it involved logistics, We need ammunition, we need
22 fuel. And then either the logistics officer or the representative of a
23 certain branch would be tasked with making sure that in the morning the
24 required materiel would be available.
25 Extraordinary meetings, there was no need, actually, to have
1 them, but there were some. There were occasions when we'd meet at 4.00
2 in the morning if the situation at the front-line was critical. The
3 Main Staff --
4 Q. Let me clarify something. Pardon me for interrupting.
5 You said the chief of sectors would meet. And when you say
6 "chief of sectors," were those the seven assistant commanders that you
7 spoke of earlier in the formation of the Main Staff?
8 A. That's correct. Chiefs of sectors were at the same time
9 commanders' assistants. Yes, I was the Chief of Staff and at the same
10 time a deputy commander.
11 JUDGE FLUEGGE: May I ask a question to clarify another issue.
12 You told us that the meetings in the evening commenced at 2000
13 hours; is that correct?
14 THE WITNESS: [Interpretation] They would commence upon the
15 arrival of daily combat reports received from subordinated units so that
16 we could read them all at once, although these documents were also
17 initially read by the chief of the operations, General Miletic or myself
18 if I were there. So it was possible that at the beginning of the meeting
19 I would tell the commander, There's no need to read everything. General,
20 the problems in the 1st Corps are such and such, in the 2nd Corps --
21 JUDGE FLUEGGE: I'm only interested in the time, because at
22 page 26, lines 24 to 25, I read:
23 "The staff would meet every morning and every evening. Between
24 6.00 and 7.00 ..." whatever that means.
25 And later on you said in the evening you met at 2000 hours.
1 Could you clarify that? What was the usual meeting time in the morning
2 and the usual meeting time in the evening?
3 THE WITNESS: [Interpretation] The usual time of the meetings held
4 in the morning was, as you said it, between 6.00 and 7.00 in the morning.
5 Usually they would start at 7.00, because at 6.00 we would only receive
6 the reports from the corps. And by 7.00 we would be able to say what was
7 happening in the corps during the night.
8 Initially, the evening meetings were starting at 1800 hours, but
9 the reports from subordinated units were never in time, and we slowly
10 pushed the beginning back. And at some point we started having these
11 meetings as of 2000 hours because by 2000 hours all the meetings -- all
12 the reports were in.
15 MR. McCLOSKEY: I think just one more question before the break.
16 Q. General, how consistent was General Mladic in having these
17 meetings? I mean, when he was there, did he always have them or was it a
18 haphazard thing?
19 A. When he was present at the staff, he would hold them on a regular
20 basis. If he was absent, if he was somewhere away from the staff, then I
21 would be chairing the meetings, but he never skipped a meeting. Even if
22 there was nothing to discuss, we would meet just to keep the habit going,
23 because you skip one meeting and then maybe we subordinates would start
24 not appearing at meetings, and God knows what, but the meetings were held
25 regularly.
1 Q. Okay. Just to clarify -- I see we still have a minute. And I
2 don't want to -- we'll get into 1995 and where you were a lot of the time
3 later. But in a situation where General Mladic isn't there and you're
4 not there, would there be someone that would normally chair the meeting?
5 A. If neither General Mladic nor myself were at the staff, the
6 meetings should have been chaired by one of the commanders' assistants;
7 Gvero if it involves issues related to morale, Tolimir if it's related to
8 security, Djukic if it's in relation to logistics. But they were mostly
9 chaired by my assistant, because Operational Sector is a place where all
10 reports come in, all data come in. And if sometimes it would happen that
11 it's necessary -- and I do know that Miletic, who was my deputy and chief
12 of Operational Administration, he was the one chairing the meeting.
13 There was no problem in hierarchy if you would have chief of one
14 sector reporting to a deputy, because he's reporting to the staff, not to
15 the person.
17 I see it's the time for the break, Mr. President.
19 We must have our first break, and we'll resume at 11.00.
22 JUDGE FLUEGGE: Yes, Mr. McCloskey, please carry on.
23 Mr. Gajic. Sorry, I didn't see you.
24 MR. GAJIC: [Interpretation] Mr. President, just a brief comment.
25 I don't think it's a contentious issue, but it didn't get entered into
1 the transcript properly.
2 Page 23, line 10, in the last part:
3 [In English] "No one from --"
4 [Interpretation] That there was nobody from the Main Staff and
5 that General Mladic was not a member of the Supreme Command.
6 JUDGE FLUEGGE: Sorry, I didn't understand. Could you please
7 repeat your comment.
8 MR. GAJIC: [Interpretation] The answer given by the witness
9 wasn't interpreted fully, because he said that not a single officer from
10 the Main Staff was a member of the Supreme Command and that
11 General Mladic also was not a member of the Supreme Command. That was
12 untranslated.
13 JUDGE FLUEGGE: I would like to invite Mr. McCloskey to clarify
14 that in the course of his examination.
16 MR. McCLOSKEY: Thank you, Mr. President.
17 Q. General, to clarify that point, is it correct that no officer
18 from the Main Staff or General Mladic was a member of the
19 Supreme Command?
20 A. Yes, that is correct. The Main Staff was against it, and the
21 corps commands were also against it, because initially the
22 Supreme Command didn't even include the vice-presidents of the republic,
23 Koljevic and Plavsic, and it was only upon the intervention by the army
24 that the vice-presidents were appointed to enter the Supreme Command, nor
25 was General Mladic in the Supreme Command. And we did not ask for
1 General Mladic to become part of the Supreme Command because of our
2 pride, but because the fact that General Mladic was not in the
3 Supreme Command was something that had caused huge problems in the
4 hierarchy of command. Because Mladic was not in the Supreme Command, the
5 Main Staff could not be the staff of Supreme Command, which is something
6 that happens in any army during wartime. The General Staff becomes the
7 Staff of Supreme Command, becomes its integral part, and then you don't
8 have the problems I told you about earlier; namely, that the
9 Supreme Command didn't have professional expertise to draft orders and
10 make decisions. It was done by the supreme commander, and he used his
11 assistants. And that was a problem throughout the entire war. The
12 conflict between the Supreme Command and the Main Staff was caused by the
13 fact that the Main Staff was not an organisational unit of the
14 Supreme Command.
15 JUDGE FLUEGGE: May I ask you, Who else, besides the president
16 and the vice-president, was a member of the Supreme Command?
17 THE WITNESS: [Interpretation] The members of the Supreme Command,
18 in addition to the president and the vice-president, were the president
19 of the National Assembly of Republika Srpska, president -- or, rather,
20 prime minister of Republika Srpska, the minister of interior of
21 Republika Srpska, and defence minister of Republika Srpska.
22 JUDGE FLUEGGE: Thank you very much. I forgot you have explained
23 that already earlier.
1 Q. And, General, going back briefly about the daily meetings, I
2 believe you said that you would -- at times, there would be a second
3 meeting with this smaller group, where the decisions were made or
4 formulated. Can you tell us, that smaller group, who was normally a
5 member of that smaller group that met with General Mladic, if I have that
6 correctly? And, again, 1995 period.
7 A. Those meetings were attended with a narrow Main Staff officers,
8 meaning the commander and his assistants.
9 Q. Okay. And since you've started discussing these sectors,
10 specifically you started talking about General Miletic as the chief of
11 operations and training, let's go to the organisational chart that you
12 have recently looked at with the investigator. And that is 65 ter 7397.
13 MR. McCLOSKEY: And, Mr. President, this is revised from the
14 original that was on the 65 ter list of 65 ter 660, so this is a recent
15 proofing note revision of what's very similar to the older one that did
16 have a proper number.
17 Q. And, General, this is always very awkward, because we try to show
18 on one page the whole -- well, the structure of the whole army.
19 And if we could provide the Court, of course, with the one that
20 General Milovanovic has reviewed, and I have a B/C/S -- a Serbian version
21 for the general because this really doesn't work. It's hard enough to
22 see on paper; you need, practically, a magnifying-glass. But we do want
23 to have one way to see it all, just so we can see it all like that.
24 JUDGE FLUEGGE: Thank you very much. Will it be on the screen or
25 do we receive a hard copy of that as well? No, we are dealing now with
1 the one we just received?
2 MR. McCLOSKEY: Yes. I hope you received the one that
3 General Milovanovic -- we have General Obradovic's, but I don't want to
4 mix you up with that one yet. That's coming a little later. And
5 General Tolimir and Mr. Gajic should have copies as well. We'd provided
6 them a little bit earlier. So --
7 JUDGE FLUEGGE: Mr. Tolimir, did you receive a copy, a hard copy,
8 of the chart?
10 I greet everyone here. May God's peace reign in this house, and
11 may God's will be done in this proceeding and not mine.
12 I want to say hello to General Milovanovic.
13 And, yes, my assistant received the chart, if that's the one that
14 had been reviewed by General Milovanovic, and I can have it, yes. Thank
17 Mr. McCloskey, please carry on.
19 Q. And, General, as I said, I don't want to go through every box and
20 every name. But, first of all, we see, of course, as the commander of
21 the Main Staff, General Mladic, and you've discussed that. We could have
22 also put on this chart President Karadzic and the Supreme Command, but
23 that's not there. But you've discussed that, so I won't go into that any
24 further.
25 But let me -- we see on this box, it goes sideways to the right,
1 the Department of Civil Affairs, and that seems to be set out from
2 everything else. Can you explain what that department is and why it
3 would be set out like this? Just briefly.
4 THE INTERPRETER: Interpreters' notes: We do not have the chart.
5 Could we please have it? It would be very useful. Thank you.
6 JUDGE FLUEGGE: Indeed, it should appear on the screen. And if
7 there are hard copies left, they should be given to the interpreters, if
8 that is possible.
9 MR. McCLOSKEY: Yes, of course, that's absolutely correct, and we
10 do have some for them. But let's see what it looks like on the chart.
11 With some fancy footwork, we'll be able to blow up the parts that we're
12 talking about. So if we could blow up that top part. But I have
13 these -- I have Serbian versions as well.
14 JUDGE FLUEGGE: I think only the top part would be sufficient at
15 the moment. Very well.
16 MR. McCLOSKEY: Perfect.
17 Q. So, General, just briefly, this department, it's listed as
18 Department for Civil Affairs, and it's got Colonel Milos Djurdjic and
19 Lieutenant-Colonel Slavko Kralj. Where does this -- how does it fit into
20 the structure?
21 A. This department was established later in the history of the
22 Main Staff. Up until 1994, decisions on movement and access of
23 humanitarian convoys into enclaves and into Sarajevo was reached by --
24 were reached by the Main Staff. I think it was General Tolimir who was
25 receiving requests from the UNPROFOR Command, and he would then forward
1 such requests either to me or to the commander in most cases, including
2 his proposal as to whether they should or should not be approved.
3 But in 1994 a commission was formed attached to the
4 Government of Republika Srpska, a commission for humanitarian aid, and it
5 was not the Main Staff who would decide whether humanitarian convoys
6 should be authorised to enter or not. I think the chair of this
7 commission was the vice-president Mr. Nikola Koljevic. He was the one
8 deciding whether a convoy would be allowed to enter Srebrenica or not.
9 If he would decide that they should be let through, he would inform us
10 about it, and the Main Staff was in charge of then stopping all combat
11 activities that were happening along the route of the convoy.
12 Milos Djurdjic entered that department. I don't know where he
13 was before, after the establishment. And Slavko Kralj worked in a
14 similar department in the 1st Corps and was just transferred to the
15 Main Staff. He spoke English really well, and that was the reason,
16 I think, that he became part of this newly-formed department.
17 The chief of the department, Colonel Djurdjic, then was present
18 at joint meetings with UNPROFOR when decisions were made about how many
19 convoys would be allowed, and it remained the duty of the army to make
20 sure that convoys have safe passage and to control whether the goods that
21 are stated in the documentation accompanying the convoy was the only
22 material carried by the convoy, so that we could avoid, for instance,
23 situations where different stuff would be smuggled in like it happened
24 during Operation Parachute.
25 And, now, why is this separately placed here and linked up with
1 General Mladic directly? I think it's because it was added later and
2 they didn't know how to graphically put it in differently. Many of the
3 requests would come to me directly, and I would then send them back to
4 Tolimir, who would then maybe include his proposals and send them back to
5 me, or to the commander, who would then reach the final decision.
6 Q. All right, General. And we'll get to this in a little more
7 detail later, but you'll recall that you have been shown many of these
8 convoy requests for 1995, and you've identified the initials and
9 signatures of various members of the Main Staff; General Mladic,
10 General Tolimir, General Gvero. So given that -- can you explain to
11 us -- in 1995, yes, we know about this civilian commission, but did the
12 Main Staff remain involved in this process, from what you've seen
13 regarding the initials and the various things that you have identified
14 that we'll get to later?
15 A. By using the documents, the request, and the approvals or
16 non-approvals, I reached the conclusion that the commission was
17 functioning throughout 1995, especially when I was in the Main Staff.
18 Q. And what was the Main Staff involvement with that? Because, as
19 I think you'll agree, you noticed Mladic is making proposals, and
20 Tolimir's initials, Gvero's initials on these requests that were made
21 during the time of the commission, so can you describe what involvement
22 the Main Staff still had in this process, based on what you've reviewed,
23 and your knowledge, of course?
24 A. First of all, one correction. General Mladic wasn't the one
25 making proposals. He was the one reaching decisions. And the documents
1 show that he very often would return a request either by the UNPROFOR or
2 the commission to Tolimir and Gvero, asking them for their opinion. In
3 several instances, I could see that Tolimir would say, Yes, and Gvero,
4 No, on the request, or the other way around, and then after that you
5 would see Mladic's initials with his decision. So he would either
6 approve Tolimir's or Gvero's proposal, but Mladic was the one who would
7 have the final say. He would never issue proposals to his subordinates,
8 but he was asking them for opinions. But the commission was functioning
9 throughout 1995, yes.
10 Q. All right. So who had final control, the commission or Mladic?
11 A. The final control was in the hands of the army, Mladic, at
12 check-points.
13 Q. All right. So now we can -- let's look at the bigger picture.
14 And you've always talked about seven assistants, and so if we look at the
15 next series of boxes and count from -- well, if we -- let's go backwards
16 from right to left, starting with the Administration of the Air Force.
17 We have, one, two, three, four, five, six, seven, ending with you, as the
18 Chief of the Main Staff, and all your staff administrations under you.
19 So are those the seven assistants that you spoke of?
20 A. Let me explain.
21 The Main Staff, as an entity, had five sectors and two
22 administrations. The five sectors had assistant commanders at its head.
23 One was the staff sector, my sector. Then Sector for Moral Guidance,
24 Religious, and Legal Affairs; that was General Gvero's sector. Then I
25 can see here the next one is Logistics, General Djukic. The following
1 one is Sector for Organisation, mobilisation, and Personnel Affairs. In
2 1995, it was General Petar Skrbic. Sector for Intelligence and Security
3 Affairs, General Tolimir, throughout the war.
4 And we have two administrations that are directly linked up with
5 the commander. One is the Administration for Planning -- Development and
6 Planning, headed by General-Major Evo Tomic; and Administration for Air
7 Force and Air Defence, headed by Major-General Jovo Maric [Realtime
8 translation read in error "Mladic"].
9 So the five sectors and two administrations, they were directly
10 linked up to the commander, and the chiefs of these sectors and
11 administrations were commanders' assistants. Other administrations were
12 linked up with their chiefs of sectors. For instance, the
13 1st Administration for Operations and Planning, that's General Miletic's
14 administration, they're linked up to me. For General Tolimir, there were
15 two, also, administrations; namely, Intelligence and Security. That was
16 Beara.
17 Do you want to hear about any other administrations or sectors?
18 JUDGE FLUEGGE: I would like to make one correction for the
19 transcript.
20 Page 41, line 7, I read there the name headed by General Mladic,
21 but in fact it was General Maric, the chief of the Administration for
22 Air Force and Air Defence.
25 JUDGE FLUEGGE: One moment, please. Judge Nyambe has a question.
2 At page 38, lines 23 through to 25, you have referred to
3 Operation Parachute. Can you just explain what that operation involved?
4 Thank you.
5 THE WITNESS: [Interpretation] Operation Parachute was supply of
6 humanitarian aid into enclaves by air-lifts or, rather, by parachuting
7 the materiel in the planes that I think were sent on the basis of a
8 decision reached by the Security Council. The idea was to provide
9 humanitarian aid in a secure way, but I later started thinking that the
10 idea also included parachuting in materiel that was not allowed, because
11 the materiels were thrown out of the planes at a very high altitude, at
12 10.000 metres. Some of the cases fell into the territory of
13 Republika Srpska, in two or three cases. And were we opened each one of
14 those crates, we found, for instance, in one occasion, in the area
15 between Srebrenica and Milici, we found ammunition for machine-guns,
16 7. -- and -- 12.7 millimetres that was packed in bags that allegedly
17 contained flour. But the person who found it said, Well, flour cannot be
18 that heavy.
19 The only thing we could do about it was inform UNPROFOR of such
20 instances. We couldn't order anyone who was packing this not to do that
21 anymore because it was -- the bags were packed somewhere in Germany, but
22 we could inform UNPROFOR about such instances. I'm not sure whether they
23 managed to correct the situation. The operation went on for several
24 months, but I guess because we kept complaining about enclaves being
25 supplied with ammunition, and so on and so forth, they suspended the
1 operation, saying that it was not an efficient way of supplying
2 humanitarian aid, though.
5 MR. McCLOSKEY: Thank you.
6 Q. General, I seem to recall you saying that the assistant
7 commanders would make proposals through you to -- that you would present
8 to General Mladic. Would those assistant commanders be able to make
9 proposals directly to General Mladic if they so chose, even if you were
10 present?
11 A. I think that we didn't understand each other. The other
12 assistant commanders submitted proposals to the commander. I listened to
13 those proposals and I would take what I believed I would need when I
14 submit my final proposal on the combat use of units. So each one of them
15 would make their proposals directly to the commander. It was another
16 matter that I was listening and that that would help me formulate my own
17 proposals, because proposals were being formulated during the actual
19 Sometimes, exceptionally, I would prepare them myself, but during
20 the reporting, I would change them. I'm not a bigger expert in security
21 or intelligence than Tolimir, so I would modify my own suggestions
22 according to what he said, for example, in providing support in combat
23 operations. I would not be making up my own proposals. I would be
24 formulating what Tolimir, for example, would bring to the table.
25 So assistant commanders did not make their proposals to me. They
1 made them directly to the commander. I would only listen to that and
2 take them into account or not take them into account when formulating my
3 own proposal.
4 Q. Thank you for that clarification. And what would happen to the
5 proposals? Just to finish the loop on that.
6 A. I mentioned that as well. When the proposals were all made, then
7 the commander would usually give a break. I say "usually," but it
8 wouldn't necessarily have to be like that. Perhaps he could be
9 monitoring the proposals right away and formulating the decisions right
10 away. Then he would say, I decided, and then he would dictate the
11 decision. That was one option. But he could also give a break and take
12 the time for himself to reach his decision, and then he would call us
13 again and announce his decisions.
14 In the decision-making system, each one of us assistants would
15 fight for their own proposal; I would, Tolimir, Gvero, all of us would do
16 that. However, when the commander says, I decided, all seven of us would
17 then fervently go about executing that decision, regardless of whether
18 that was in the spirit of our own proposal or not. This was in the
19 spirit of subordination. We had corps commands where the Chief of Staff
20 would propose something, the commander would decide otherwise, but the
21 Chief of Staff would continue to do what he wanted. And then in that
22 case we would abandon/regroup such persons. The Chief of Staff would
23 have to be along the same line as the commander. They would have to
24 respect these rules of subordination.
25 Q. Okay. And in the event -- let's take the situation where
1 General Tolimir makes a proposal that is adopted by General Mladic, and
2 General Mladic makes an order that's consistent with the proposal and has
3 something to do with the security and intel function. What, if any,
4 responsibility would General Tolimir have in the execution of or
5 monitoring of that order, as I say, if any?
6 A. If Tolimir's proposal was not in line with Mladic's decision,
7 Tolimir would carry out Mladic's decision no matter what it was.
8 Q. Well, in a situation where they were both on the same
9 page - Tolimir makes a proposal, Mladic issues an order - how does
10 Tolimir carry it out? What's his responsibility, as the chief of the
11 sector at the Main Staff, for something that would involve the corps, for
12 example?
13 A. He would carry out the commander's decision regardless of whether
14 that was something that corresponded with his proposal or not.
15 Q. I understand. And how would he carry it out? Give us just an
16 idea of just what his responsibilities would be generally. I'm just
17 trying to get a general feeling for the responsibility of any assistant
18 commander whose proposal gets turned into an order.
19 A. It states: "Order to the subordinate unit," and it would be -- he
20 would write it in the spirit of the commander's decision, and then he
21 would monitor the execution.
22 I don't know if I was clear enough. If the commander did not
23 accept my proposal, I would execute his decision regardless of the fact
24 that I disagree with it, for example. If he does accept the proposal,
25 then the job is easier for both sides.
1 Q. That's the situation I want to -- I'm asking you about. And you
2 said he, the assistant commander, in this case Tolimir, would monitor the
3 decision. What does that mean, militarily? What's it mean to monitor
4 something?
5 A. To monitor the execution of a decision means seeing if the
6 subordinate unit that was issued the decision was implementing it in the
7 way the commander had decided. If the unit or the subordinate commander
8 was doing something else, it was Tolimir's duty to direct him back to
9 work in the spirit of the commander's decision, with addition orders,
10 explanations, by personally going and telling the commander, You're not
11 doing this in the spirit of the commander's decision, you're making up
12 something of your own. So it is to keep him in the direction or in the
13 course of the commander's decision.
14 Q. And how long will the execution of that order be monitored by the
15 assistant commander, in this case Tolimir?
16 A. Until the assignment is completed.
17 Q. All right. Now, I just want you to provide just a little bit of
18 your knowledge and experience on some of these sectors or
19 administrations. The Trial Chamber has heard some information and
20 evidence on some of them, but I just want to get your succinct and
21 brief testimony on these and some information on the chief of the various
22 sectors or administrations I'll be asking you about.
23 So let's, first of all, start with your side, on the left.
24 There, we have it. And you've already spoken a bit about General Miletic
25 as the -- he was the chief of the Administration for Operations and
1 Training; is that correct?
3 Q. And you have already spoken about that he was your deputy and
4 would sometimes replace you, when you weren't there, to chair some of
5 these meetings, but can you basically describe, simply, just in two or
6 three minutes, what his responsibilities were as the chief of operations
7 and training, aside from those that you've already told us?
8 A. His daily duties, as the chief of the administration, were -- and
9 now I'm not speaking about the duties as my deputy -- were to compile and
10 analyse reports from subordinate commands. At the evening meeting, he
11 would state the main problems from the reports by the subordinate
12 commands, and he would give his view as how to resolve each of those
13 problems. He would draft reports and send them to the Supreme Command.
14 He would draft all combat orders, information, notifications relating to
15 the decision of the commander of the previous morning. He would author
16 all the combat documents.
17 In my absence, besides these jobs, he would also carry out the
18 Chief of Staff's daily duties, which were to control the orders being
19 drafted by his administration, signing reports to the Supreme Command,
20 directly address the commander in relation to some problems in the staff
21 or the staff sector. He would be carrying out the day-to-day duties
22 usually conducted by the Chief of Staff when he was there. This was his
23 additional duty because, by establishment, he was standing in for the
24 Chief of Staff. This could last up to a period of 30 days. If the Chief
25 of Staff does not return to the Main Staff, there would usually be a way
1 for me to appear at least once a month at the Main Staff in order that we
2 would not have to make any personnel changes in the staff.
3 Q. All right. And can you tell -- how important was that job, the
4 job of the operations officer? You may recall how you described it in
5 the last trial, in the Popovic case.
6 A. I said then that an operative in a command or a staff was the
7 soul of that command. All the information comes to him from the
8 subordinate unit, and all the information is dispatched from him to
9 subordinate and superior commands. So this person, in brief, would be
10 like a traffic cop at an intersection where a whole bunch of information
11 was arriving, and he is the one who would be directing this flow of
12 information. He's a person who, at a given command, would know
13 everything or should know everything, including what the commander is
14 doing, what the last soldier in that army is doing, as the person who is
15 carrying out tasks.
16 Q. All right. And I think this is a good time, because you have
17 stated several times that in your absence he would have various other
18 important duties, where were you during most of 1995?
19 A. From the 1st of January, 1995, until the end of February, I was
20 in the West, in Drvar. Actually, from the 30th of October, 1994, until
21 the end of February 1995 I was in the West. In early March, I appeared
22 at the Main Staff in order to prepare the annual analysis of the war or
23 the combat readiness of the Army of Republika Srpska. And then from the
24 6th to the 12th of March I went west again because I was still
25 responsible for that part of the front, following the Bihac operation.
1 Then from the 12th of March until the 3rd of May, I was at the
2 Main Staff. However, I was responsible from the Main Staff to the front
3 around the Sava towards Western Slavonia. And then on the 3rd of May, I
4 transferred to Gradiska in order to organise the defence of
5 Republika Srpska from the direction of the Croatian territory. We're
6 talking about the well-known Croatian Operation Flash. I think that I
7 stayed in the West until the 18th of March.
8 On the 18th of March, I appeared in the Main Staff again, and I
9 was there continuously until the 29th of May. In the meantime, I was
10 conducting defence operations from the aggression of the NATO pact
11 against Republika Srpska. This is the 24th, the 25th, and the
12 26th of May.
13 And then at repeated intervention of General Tomanic, on the
14 29th of May I was sent again to the West, to Drvar, because the Muslims
15 had violated the well-known four-month Carter truce, and they crossed
16 again and violated the area of Republika Srpska across the Una River.
17 And the Croats began their offensive against Republika Srpska and the
18 Republic of the Serbian Krajina, which was known by the name of Storm.
19 When we're talking about Storm, I think it's incorrect. I tried
20 several times also before this Tribunal and in the media to deny the
21 Croatian assertion that Storm began on the 4th of August, 1995, and was
22 completed on the 5th of August, 1995. Storm began on the
23 4th of June, 1995, and was completed sometime on October 15th, 1995. It
24 was completed not under the name of Storm, but under the name of
25 Juzni Potez, Southern Flank, but it was the same armed forces formation.
1 From the 29th of May and then until the 15th of October I spent
2 in the West. I arrived a few days before the signing of the
3 Dayton Accords.
4 JUDGE FLUEGGE: Let me ask you: You say, again, you spent the
5 time between May and October in the West. Could you specify what you
6 mean by that again?
7 THE WITNESS: [Interpretation] I was conducting combat actions of
8 the Army of Republika Srpska on the front in the Bosnian Krajina, on the
9 River Una, the Dinara Mountain. That was it. I was conducting the
10 defence actions from Muslims from the Bihac Security Zone and defence
11 from the Croatian Army from the Livanjsko Polje and the
12 Golije-Staretina-Sator-Cincar-Vitorog Mountains. Perhaps I skipped over
13 a hill or a mountain, maybe.
14 JUDGE FLUEGGE: I would like to come back to an issue we
15 discussed earlier, about the meetings of the Main Staff in the morning
16 and in the evening. Where did these meetings take place during that
17 time-period?
18 THE WITNESS: [Interpretation] The meetings were held at the
19 Operations Centre of the Main Staff. This was the largest room in the
20 prefabricated huts where we were located. As I said, the meetings were
21 attended by the assistant commanders, if they were there. If any of them
22 was not there, their deputy would be there. And the leading leadership
23 team would also attend these meetings.
24 JUDGE FLUEGGE: And where were these prefabricated huts located?
25 THE WITNESS: [Interpretation] These prefabricated huts were in
1 Crna Rijeka, some nine kilometres north-east of Han Pijesak. At a slope,
2 we found two such huts on the 19th of May, when we got there. During the
3 war, we built another one, the third one. It was a small area, because
4 we worked and slept in these huts. And just to show how small a space it
5 was, suffice it to say that General Mladic and I shared an office. If
6 Mladic was there, I wasn't, and if I was there, he wasn't. Usually
7 that's how it worked. But we shared an office in order to save space or
8 make best use of the space.
9 Other than the huts, we also had an underground command post
10 which was 1 kilometre away from the huts. It was dug out. I think it
11 was 471 metres underground, under Veliki Zejg [phoen], where we would go
12 in case of threats of NATO strikes or during NATO strikes. The entire
13 Main Staff would move to this underground command post, which would be
14 able to function for six months, with a number of persons there being
15 500. It was completely self-sufficient. It was like a small
16 subterranean town.
18 Judge Mindua has a question.
19 JUDGE MINDUA: [Interpretation] Witness, General Milovanovic, I
20 see here that from May 1995 until October, the 15th of October, 1995, you
21 left and went east. You were in charge of the battle against the Croats,
22 which was fighting against the Republika Srpska and the Krajina Republic.
23 The battle or the fighting had actually started in June of 1995. And at
24 the same time, if I look at the organisation chart of the Main Staff of
25 the VRS in July of 1995, you are the deputy commander of the Main Staff.
1 How are you able to reconcile your two jobs, i.e., as
2 deputy Chief of Staff and in charge of the military operation against the
3 Croats to the east of the country in 1995?
4 THE WITNESS: [Interpretation] First of all, it's the west of the
5 territory, not the east.
6 I was deputy commander for military operations, translated into
7 NATO terminology. My duty was to plan operations and, if the commander
8 ordered so, to carry out operations. In practice, this is how it was. I
9 would plan or my sector would plan an operation, and the commander
10 usually would allocate me, as the main planner, to begin the execution of
11 the operation because I had the right to change things if something was
12 not going right.
13 It's not easy to predict the course of combat. So if something
14 does not proceed according to plan initially, the plan that I drafted and
15 that the commander or the supreme commander approved, then I can change
16 things immediately. On the ground, I'm not going to send one brigade,
17 but two; instead of two, perhaps three. So I was the person who could
18 change the initial plan as the operations went along. If the operation,
19 in the beginning, proceeded quite well, then the commander would leave me
20 there to complete it.
21 But the command principle in the Main Staff was this: If, in an
22 operation, there are two or more corps taking part, the operation is
23 under the command of the commander of the Main Staff. However, if a
24 sector of the front, because the front of Republika Srpska was about
25 700 kilometres long and 150 kilometres wide, if operations at corps level
1 are being executed in another place, then the commander usually stays
2 where the bulk of the fighting is and then he would assign me or some
3 other assistant of his to that other sector of the front in order to
4 conduct the operation. And this time, this was in the West.
5 First of all, I spent late 1994 and early 1995 in the West,
6 executing that initial strike towards Bihac. I said that the
7 5th Muslim Corps violated Carter's truce, and beginning from the
8 13th of January, 1995, they started slowly eating away at our territory.
9 They crossed the Una River, violated the truce, and by the
10 12th of February had taken up part of the territory on Grmec Mountain.
11 They had retaken that part of the territory. I made a new counter-strike
12 plan towards Bihac. The plan was approved by the Supreme Command.
13 The commander of the 2nd Krajina Corps asked twice that I
14 personally get to that part of the front. I don't know what the corps
15 commander's motivation was for that. I refused to do it the first time.
16 This was in early May, when I was in Gradiska fighting against -- Flash.
17 When I returned to the staff, on the 25th of May the corps
18 commander sent an ultimatum -- a request to the Main Staff that I would
19 have to come to that sector of the front. Otherwise, he would leave
20 Bijecevica [phoen] Mountain. And so I had made some reinforcements at
21 Krupa Na Uni before that. Before that, I had told General Mladic and
22 Supreme Commander Karadzic that I didn't want to do this because I did
23 not want to be tied down, as the Chief of Staff, to one sector of the
24 front of Republika Srpska.
25 But General Tolimir, who is present here, convinced me to accept
1 and to agree to that summons because I knew the corps the best and I
2 understood the Serbian Army of the Krajina, which was acting in
3 co-ordination very well, and I also was very familiar with that
4 particular area. And seeing that it was no longer a joke and that this
5 commander was being very persistent, I accepted the summons and I went on
6 the 29th of May.
7 On the 4th of June, I initiated the counter-strike, the second
8 one towards Bihac. On the Croatian side, there was no threat from that
9 direction. I even took some artillery weapons from the Glamoc front,
10 transferred them to the Bihac front. In the morning, we began, on the
11 4th, on Sunday at 4.00 a.m., and in about two hours we had broken through
12 the Muslim front towards Bihac.
13 JUDGE MINDUA: [Interpretation] Thank you very much, Witness, for
14 having specified what your military action to the West involved.
15 But you remember a while ago we discussed the collegium of
16 commanders. Whilst you were in the West, did that mean that you were not
17 taking part or were not a member of the collegium of commanders at that
18 time? Is that right?
19 THE WITNESS: [Interpretation] I couldn't attend their meetings
20 and did not. There was no need for it because I had received my task at
21 the Western Front. It was a long-term task to repel the
22 Croatian Operation Storm. Therefore, no needs were required on my end.
23 The only thing that happened was when I asked for reinforcements by
24 telegram or telephone. I simply wasn't present at the meetings and there
25 was no need for me to. I was only present there when I was particularly
1 called by the commander, when analyses of combat readiness for the
2 previous year were done.
3 I was also at the Main Staff once when we saw General Zivanovic,
4 commander of the Drina Corps, off because he retired. The custom was
5 that all generals got together on such occasions. I arrived on the
6 19th of July. We saw him off on the 20th. And on the 22nd, I was
7 already back in Drvar. So this was the only exception. Yes. So
8 basically there were only two interruptions in the whole period.
9 JUDGE MINDUA: [Interpretation] Thank you very much.
10 My last question now. When you were not present, was someone
11 appointed to act on your behalf when you were not on the spot where the
12 operation was taking place? Was a deputy commander, an acting deputy
13 commander, ever appointed?
14 THE WITNESS: [Interpretation] I was replaced by General Miletic,
15 per establishment. My absence from the Main Staff up to 30 days did not
16 require any new orders for Miletic. He would simply pick up where I left
17 it off in the Main Staff.
18 JUDGE MINDUA: [Interpretation] All right. Thank you very much.
20 MR. McCLOSKEY: Thank you, Your Honours.
21 Q. Can you tell us, did you receive a specific order from
22 General Mladic authorising you to command that -- the operation you've
23 described from May 29th in the West?
24 A. Yes, I did. I received an order from General Mladic to go
25 westward to execute that counter-strike against Bihac. I began doing so,
1 but on the same day the Croats attacked the VRS from Livanjsko Polje
2 through the villages of Peulje. Their aim, and that is something I did
3 not learn in the course of that day, but in the next following days, was
4 not the RS. Their goal was to occupy Knin. They were unable to do that
5 from the direction of Dalmacija, perhaps because of the lie of the land,
6 so they came up with this idea of engaging in a comprehensive manoeuvre
7 through the territory of Bosnia and Herzegovina.
8 Q. General, thank you. Thank you. And I just wanted to clarify
9 that you had been given a command position for the Western Front.
10 JUDGE FLUEGGE: Mr. McCloskey, I have to interrupt you. We have
11 a problem with the transcript in e-court again. It's not working at the
12 moment. I hope it's working in LiveNote. Yes, it is.
14 JUDGE FLUEGGE: The Registrar makes the proposal that we have our
15 break now because we have so many problems now with the microphone, with
16 the e-court, the e-court record, and some other problems. I think we
17 should have our break now, and during the break everything should be
18 resolved.
19 If this is convenient for everybody, we should have our break now
20 and resume 20 minutes before 1.00.
22 --- On resuming at 12.44 p.m.
23 JUDGE FLUEGGE: Yes, Mr. McCloskey, please go ahead.
25 Q. General, we had left off and I think you'd clarified that
1 General Mladic had actually given you a command position on the
2 Western Front on the end of May 1995. And you have explained this a bit,
3 and the policy of sending out a general from the Main Staff if there was
4 two corps involved, and other things on that same topic, but,
5 practically, throughout the war, were you and other assistants from the
6 Main Staff sent out to take command positions or important positions in
7 the various battle-fronts of the war?
8 A. It was standard practice of the commander to dispatch his
9 assistants, be it as commanders or monitors, to control. On one
10 occasion, he sent General Gvero to the Olovo front, between Sarajevo and
11 Olovo, where Operation Ring was being executed, and that ought to be
12 distinguished from Operation Ring 2. Gvero was in command then, and it
13 included parts of the Sarajevo Romanija Corps and some headquarters
14 support units, such as the 65th Protection Regiment. It means that there
15 were more units than one single corps, and Gvero was in command.
16 I can't recall, off the cuff, anyone else being in command of
17 operations. Sorry, yes, he also sent the then artillery chief,
18 Colonel Masala, to Gornji Podrinje. He commanded the temporary
19 formations of the operations and tactical group. The commander
20 authorised him to command those units.
21 Q. All right. And the Trial Chamber has learned, as we all have,
22 that the assistant commanders, well, at all levels, brigades, corps, and
23 the main staffs, have -- are experts in their field, be it artillery, as
24 you've just mentioned, or General Gvero in morale, legal, religious; or
25 General Tolimir in intel and security. Can you explain, as a general,
1 how it could be that a person that's an expert in a particular field
2 would be effective in command or in monitoring a significant
3 battle-front?
4 A. I'm afraid I didn't understand which expert you had in mind,
5 because in the army there are two types of experts. There are those who
6 are versed in general military matters, that is, commanders; and then
7 there are specialists, such as Tolimir, who was a specialist for
8 intelligence and security, or Gvero for morale issues. Some people are
9 both. By virtue of becoming general, irrespective of one's specialty,
10 the person is capable of exercising general military command. A
11 colonel -- a quarter-master officer can also be in charge of commands
12 pursuant to orders. He can also deal with general military issues.
13 As it happened in our army, we had six brigade commanders who
14 were traffic specialists. We also had four of them from the
15 Financial Branch, and yet they were in charge of brigades. We also had
16 six communications men who were in commanding positions. They had
17 nothing to do with infantry or artillery, and yet they were successful
18 brigade commanders.
19 Q. All right. And you've outlined the basic time-periods where you
20 were away from the Main Staff. And in preparation of the last trial, did
21 you have an opportunity to review the reports from the Main Staff to the
22 Presidency and see whose name they went to the president in?
23 A. I think I reviewed all the reports sent in 1995. They were sent
24 from the Main Staff to the supreme commander, Mr. Karadzic.
25 Q. And whose names did those go out under?
1 A. Most of them were signed by General Miletic, as my deputy, but he
2 signed them incorrectly as standing for the Chief of Staff. However, he
3 did not stand for me. It is a strictly legal category. He replaced me
4 instead. So he should have signed it differently, as "on behalf of the
5 Chief of Staff." However, he automatically just put down "standing in
6 for." When I followed some testimony here, I realised that
7 Colonel Trkulja, who was the author of those reports, recognised his
8 mistake. He said he did so because he wasn't attentive enough.
9 Q. Did your review of all of those reports for 1995, and noticing
10 your name or General Miletic's name, did that help you at all in putting
11 together what days you were in the Main Staff and what days you weren't?
12 A. When I returned to the Main Staff, I did not read such documents
13 that were of limited, temporal value. I had no time to go back and study
14 everything. I'm referring to those reports that I was expected to sign
15 at those times when I was in the Main Staff.
16 The things which expired is something I didn't bother with. The
17 most important things were told me by Miletic himself. There was simply
18 no time for me to leaf through the archives. It's a different matter
19 that I read them later on here in this building. However, that was a
20 number of years later.
21 Q. And that's my question. When you were able to review them in
22 this building, does the fact that your name was on some of them
23 throughout 1995 and Miletic's was on most of them, did that help give you
24 any indication of when you might have -- or when you were in the
25 Main Staff and when you were not? I'm talking after the fact now.
1 A. For the most part, yes, because I was unable to recollect all
2 those individual segments as to when I took him to the Main Staff. But
3 if I went by my signatures, then most of the time I could tell at what
4 times I was at the Main Staff.
5 Q. All right. And can you very briefly explain to us: You've said
6 that this term "standing in" is, I think, an official or formal term and
7 that it was not used correctly by Trkulja, so can you tell us, very
8 briefly, what the formal "standing in" means and how it comes about?
9 A. The easiest way for me to explain would be by using an example of
10 a command role.
11 Say a brigade commander falls ill and abandons the unit. Up to
12 30 days, he is replaced by his establishment deputy, that is to say, his
13 Chief of Staff. If the commander's absence is longer than 30 days, the
14 superior officer to the brigade, that is to say, the corps commander,
15 appoints a person to stand in for him by virtue of an order. The person
16 so appointed has all of the authority the brigade commander enjoyed.
17 Standing in, under the then law, could last for a maximum period of six
18 months. Following that, there is either a new order on standing in or a
19 new person is appointed to act as brigade commander or another order is
20 issued to appoint the person standing in thus far as brigade commander.
21 So "standing in" is a legal category. It also entails a change
22 of salary. And one simply takes on all the responsibilities of a
23 commander. If simply acting on behalf of someone, one would not have
24 such duties and obligations, and this was mainly done parallel to one's
25 own duties.
1 Perhaps it is strange why Miletic was not accorded this status
2 when I was absent for more than six months, but that was because I was at
3 the front-lines. I was not outside the VRS. Irrespective of where I was
4 at the front-line, I maintain my position of Chief of Staff, and Miletic
5 only stood in. I wasn't incapacitated, I wasn't ill, but I was engaged
6 in another staff task.
7 Q. Okay. Thank you. And I think that is all I want to ask you
8 about for the operations and training part.
9 JUDGE FLUEGGE: Mr. McCloskey, Judge Nyambe has a question.
11 JUDGE NYAMBE: Yes, thank you.
12 You've just now explained what happens 30 days and onwards.
13 What -- how is it described or called before the 30 days lapses? What is
14 the person who acts or who stands in, in that position described?
15 THE WITNESS: [Interpretation] I believe I explained the term
16 "standing in for." Due to the physical inability of someone to perform
17 his or her duties, a person is appointed to stand in for that person. If
18 someone is attending another task as part of the same armed forces, then
19 that person is replaced by his next most superior person in his organ.
20 Miletic was the most senior person in the staff sector, and he
21 replaced me. He was supposed to sign by stating "for." So "Chief of
22 Staff Manojlo Milovanovic," that would be in the signature block, and
23 then Miletic was supposed to sign "for," and then he put his own name
24 under it.
25 JUDGE NYAMBE: I think I was not clear in my question, and this
1 is because I can't highlight where I'm trying to focus.
2 In your explanation, in the explanation that you've given just
3 now, in my understanding it relates to somebody who stands in for you
4 after 30 days. My question is: What is the person standing in for you
5 up to 30 days described as? Is it the same? Say, for example, somebody
6 is standing in for you for two weeks or three weeks or 25 days. Thank
7 you.
8 THE WITNESS: [Interpretation] It is not the same. "Standing in
9 for" is a legal category which requires an order. Replacing someone for
10 a limited period of time requires no written order, but things simply
11 continue as it were.
12 JUDGE NYAMBE: Thank you.
13 [French interpretation on English channel]
14 JUDGE FLUEGGE: May I --
16 JUDGE FLUEGGE: No, we have not the -- there is now French
17 interpretation on the English channel.
18 Now it's working.
19 In this period of 30 days, the deputy just is in the position of
20 the person of the commander for whom he is the deputy, without a specific
21 term you are using? He's just the deputy, is that correct, in this
22 period of 30 days?
23 THE WITNESS: [Interpretation] Mr. President, to put it in the
24 briefest way possible, he acts on behalf of the person who is absent.
25 Miletic performed my duties in the staff in my absence, such as reviewing
1 correspondence, drafting reports, receiving subordinate reports, and all
2 the other daily tasks. If key decisions need to be made, he had no right
3 to propose anything to the commander. He could always get in touch with
4 me. And if the commander needed me personally, he could always summon me
5 to the Main Staff.
9 Q. Just one more thing to help clarify it in my mind.
10 You've described that Miletic was replacing you or acting on your
11 behalf, but those words don't need to be placed in the signature block,
12 is that what you're saying, just as long as the "for" word is mentioned,
13 the "za" word?
14 A. Precisely.
15 Q. And those terms that I just mentioned are not formal, legal
16 military terms, they just describe the situation; is that right?
17 A. It seems I have to repeat. If someone is standing in for
18 another, he or she has the same rights as the person he is acting for, or
19 standing in for, excuse me. If Miletic stood in for me, then he could
20 exercise my powers. However, if he was only replacing me, if the word
21 "for" was to be affixed to his signature, he did not enjoy the same right
22 as I did. He could only deal with the daily routine tasks so to avoid
23 the staff coming at a standstill.
24 Q. All right. I think we understand. And so let's move on from
25 that part to the next sector, which is the Sector for Moral Guidance,
1 Religious, and Legal Affairs, headed by General Gvero.
2 And can you very briefly describe what General Gvero's job was in
3 the Main Staff, especially in 1995?
4 A. Throughout the war, including 1995, General Gvero was tasked with
5 raising the morale of the VRS, maintaining it, that is to say, preventing
6 the morale from deteriorating among the ranks. That was one thing.
7 Another thing that he was also in charge were religious affairs. That is
8 to say, he was there to provide conditions for the troops to attend
9 religious ceremonies, et cetera. He was also to liaise with the church
10 institutions. Perhaps Mr. Tolimir would be better placed to explain
11 that. In any case, he was supposed to make it possible for the officers
12 and soldiers to perform their religious rites, et cetera.
13 He was also an assistant commander for legal affairs, which means
14 that he had to keep an eye on the lawfulness of the work of the military
15 courts, and he was also in charge of establishing them. This lasted
16 until sometime in 1994, when the military courts were no longer under the
17 competence of the Main Staff and the army. They were returned to their
18 proper place, which is under the authority of the Ministry of Defence.
19 However, Gvero continued monitoring the work of the military courts,
20 although he no longer had to under the law. He was in charge of
21 controlling their work, and he was responsible to the commander for the
22 work of the military judiciary.
23 Q. And, personally, did he exhibit any religious affinity or did he
24 have any religious position in any religion, General Gvero, that is?
25 A. I don't know anything about his religious affiliation, but I do
1 know that in our political school he taught Marxism, which is a theory
2 completely opposite to religion. I have not noticed any changes in his
3 views during the war, although it was his duty to provide conditions for
4 the army members to do their religious things. I don't think he was an
5 atheist, but I've never seen him pray.
6 There is a story that I can recount. The archbishop of the
7 Serbian Orthodox Church visited the Main Staff, Mr. Paulin [phoen]. I
8 was not present in the Main Staff. And in the underground command post
9 there was an office of the Chief of Staff where the Chief of Staff would
10 work, but where also meetings were being held. And when I joined them in
11 the afternoon, while the archbishop was still there, I found in my room a
12 religious painting and a candle, and I asked General Mladic who was it
13 who placed this here. And he responded, Well, it was the archbishop, and
14 the proposal came from General Gvero, who was in charge on religious
15 issues. And this office, this room actually, is a very busy room.
16 People yell, make phone calls, and I told General Mladic, Well, since the
17 candle is here in my room, let General Gvero properly light it up. But
18 he didn't know how, so I would say that General Gvero was not a person
19 who was well versed in religious things.
20 Q. How about General Tolimir; did you ever see him exhibit religious
21 beliefs or religious practices?
22 A. No, I haven't seen him. And as far as his knowledge about
23 religion, well, on one occasion when I was about to enter a church in
24 Vlasenica where something was going on, there was a procession about to
25 start, and we needed to discuss something, and the bishop told us, If you
1 want, you can find a quiet corner in the church. And then he made a
2 joke, If the general wants to enter the church. And I returned the joke
3 by saying, I will go with the commander wherever he tells me. But upon
4 entering the church, we saw General Tolimir at the entrance, and he told
5 me, You're not supposed to bring in any weapons. I had a Hekler on me.
6 I didn't know anything about these things, and I handed over the Hekler.
7 But I also had four bombs in my uniform. So, in effect, I did bring
8 weapons into the church. But I never saw Tolimir praying to God, and he
9 cursed as much as everyone else in the Main Staff. So, no, during the
10 war, in the time we almost lived together, I did not notice any special
11 religious proclivities on his part.
12 Q. All right. Going back to General Gvero, can you describe his
13 influence with General Mladic?
14 A. I spoke about this during my last testimony in 2007. Gvero did
15 not have any special influence on General Mladic. On the contrary,
16 General Mladic, up until the time I went to the Western Front, often --
17 well, you see, the two of us would often have conversations privately,
18 outside of the staff. We would walk around the huts, and he would always
19 tell me, Let Gvero be; he's a politician. I also said just a moment ago
20 that Gvero was the officer in charge of the Operation Ring in Olovo or at
21 the Olovo Front-Line, and they were having a hard time. It was
22 winter-time, and Mladic sent me on one occasion there, and I was escorted
23 by one of Gvero's officers, Vidoje Magazin, his name was, and he was a
24 colonel, I think. And he told me, Go and see what Gvero is doing, and if
25 what he is doing is not efficient, suspend all the activities until the
1 end of the winter. And I got there, I found Gvero there at the forward
2 command post. He briefed me on the situation. It was too much snow for
3 any movement. And I ordered Gvero to change the status to defence
4 status, to take his forces in, and I don't think the operation was ever
5 resumed.
6 So, no, General Mladic was not under influence of General Gvero.
7 Only after my arrival from the West Front, which was in second half of
8 October, whenever we were not really busy in the staff, Mladic would go
9 for walks, usually with me, around the Main Staff deployment area or he
10 would go to General Tolimir. They knew each other from Knin, so I wasn't
11 paying that much attention to that. But after my return, Mladic would
12 not choose me as his walking companion, but Gvero and Beara. And I was
13 at first a little bit sore about that, but that was after Dayton, so it
14 wasn't very important anymore.
15 I don't know whether Gvero had some influence on Mladic at the
16 time. I know that Gvero, on one occasion, told me -- after the
17 Dayton Accords and after a minor stroke that General Mladic had suffered,
18 Gvero told me, when we were on our own, the two of us, he said, I had a
19 stroke, and I'm not sure sometimes whether two plus two makes four.
20 Tolimir also had one, so you should not rely on him too much.
21 And I apologise to Mr. Tolimir now.
22 He added, You're probably the only one who's unaffected. And he
23 told me about Gvero the following thing, Well, it's the end of the war,
24 so he's looking for some place where he can fit in into the political
25 structures.
1 And Mladic at the time started insulting and cursing the members
2 of staff. He told me, Well, if you see me doing something like that,
3 you're always next to me at the table, then just kick me under the table.
4 And I was pleased to hear that, because his behaviour started causing
5 problems in the staff. And after this conversation, we went out. And
6 there was a table there, and quite a few officers used to sit there, and
7 there was a sheep that came that was lame, and there was a veterinarian
8 colonel there who Mladic asked about, Why is this sheep lame? And the
9 officer said, Well, this is a sheep from Kalinovik, and the climate here
10 is different from there, and they're having difficulties. And Mladic,
11 who was from the area of Kalinovik, started cursing the colonel, and I
12 kicked him with my boot. But then he said, What I told you earlier is
13 not really in effect anymore.
14 But I don't think, to come back to your question, that Gvero had
15 any special influence on Mladic. I don't think he had that.
16 Q. General, I didn't -- I'm sorry, I wasn't, perhaps, clear. I
17 didn't mean special influence. But you may remember, when you were asked
18 questions in the last trial and describing your -- in providing proposals
19 and guidance and advice to General Mladic, you described yourself as the
20 first among equals and something about all the assistants had influence.
21 Do you remember that?
22 A. Yes, I remember saying that I was the first among equals. And
23 the question was put to me by Mr. Krgovic, the Defence lawyer, and he
24 asked me whether Gvero had been Mladic's right hand, and my response was
25 that according to establishment I was General Mladic's right hand. If he
1 had additional right hands, that was his thing, not mine.
2 Q. All right. So my question about influence really has to do with
3 advice, proposals, whether Mladic listened to you and acted on you in
4 that kind of a context. So if -- can you describe what you meant? When
5 you said "first among equals," that all the assistant commanders had
6 influence, what did you mean by that? Could you explain that a little
7 more fully, but as briefly as you can?
8 A. "First among equals" means that I, in addition to being assistant
9 commander for staff affairs, I'm also deputy commander. In other words,
10 I have a title that other assistant commanders don't have. That's the
11 issue. They were all part of the Main Staff, but I was in charge of the
12 staff itself. That means first among equals. I didn't mean first among
13 equals that Mladic would listen to most.
14 Mladic appreciated my proposals, but my role was to summarise all
15 the proposals of other assistant commanders. And, of course, Mladic was
16 listening also to the proposals of all of his assistant commanders,
17 including the Chief of Financial Administration Colonel Tomic.
18 General Mladic devoted due attention to all of us when we were making
19 proposals.
20 Q. Did you and the assistant commanders and General Mladic work as a
21 team?
22 A. Yes. Mladic treated his entire staff as one team. All seven
23 assistant commanders were a part of a team. But he would also do that on
24 an individual basis, one on one. Especially when issues relating to our
25 specialties were at stake, it would be one-on-one discussions. For
1 instance, with me when combat operations were in charge; with Tolimir
2 when security and intelligence affairs were at stake; with Gvero about
3 morale and legal affairs. He didn't care much about religious parts.
4 With Djukic in relation to logistics, and so on and so forth. He didn't
5 make any distinctions, at least to my knowledge, between us in that
6 sense.
7 Q. Let me go over now to the Sector for Security and Intelligence.
8 And the Trial Chamber has heard a lot about that from the brigade level,
9 the corps level, even the Main Staff level, but can you tell us, briefly,
10 what General Tolimir's job practically consisted of? What was his job
11 throughout the war, and especially in 1995?
12 A. The task of Tolimir's sector, the Intelligence and Security
13 Sector, and therefore of Tolimir himself, because he was chief of the
14 sector, was Intelligence and Counter-Intelligence Service activities;
15 namely, gathering information about the enemy and prevention of any leaks
16 of information. He had two assistants. One would collect information,
17 that was Intelligence Administration, headed by Colonel Salapura. So it
18 was Salapura's task to gather information by analysing daily reports,
19 media, by getting reports from his subordinated intelligence officers
20 from lower units like corps and brigades. He also had to organise
21 so-called forcible gathering of information by moving combat deployment
22 and similar activities. In other words, there are two types of gathering
23 of information, active and passive.
24 The other administration under Tolimir's administration or
25 command was the Security Administration headed by Colonel Beara, and
1 their task was to make sure that military information at the disposal of
2 Republika Srpska and about the Republika Srpska Army would not leak to
3 the enemy. This was something done in the passive manner, so to speak.
4 That's, at least, how I understood it. But part of the active part of
5 these duties, interrogating prisoners of war, securing them by using
6 military police and the such.
7 So Tolimir's sector was in charge of intelligence and
8 counter-intelligence affairs; in other words, gathering information and
9 making sure that information about us does not leak to the enemy.
10 Q. All right. You just said that:
11 "The other administration under Tolimir's administration or
12 command ..."
13 So is it fair to say that General Tolimir was in command of the
14 Intelligence Administration and the Security Administration?
16 Q. All right. Can you describe General Tolimir's relationship with
17 General Mladic? And, first of all, on a professional basis. For
18 example, did they -- like you've described yours with General Mladic, how
19 you saw things differently, but your temperaments fit, how would you
20 describe the professional relationship that you saw during the war years
21 between Generals Mladic and Tolimir, and, again, especially in 1995, if
22 there were any changes?
23 A. I can't speak about the relationship between Mladic and Tolimir
24 for the duration of the entire war. I cannot speak specifically about
25 1995 because I did not spend all of the year with them there. But upon
1 my return, I did not notice there had been any major changes.
2 I already told you that I made a mistake on the occasion when
3 Tolimir was introduced to us by Mladic, when I showed that I believed
4 Tolimir was a Slovene, but they were together in Knin and they had maybe
5 nine months or up to a year of joint combat experience together. They
6 knew more about war than those among us who joined in on the 12th of May.
7 I know that they would consult with each other often. For instance, I
8 make a proposal, or something like that, and before making a decision,
9 Mladic would say, I'll go and talk to Toso, as we used to call Tolimir,
10 and see what he thinks.
11 Whenever Mladic had to do something, he would always ask the
12 assistant commanders to analyse the matter and to, in a way, give a green
13 light to him in relation to his intentions. And on one occasion we got a
14 letter General Mladic wrote to General Wahlgren, who was the commander of
15 the UNPROFOR forces for former Yugoslavia, who had his headquarters in
16 Zagreb. So Mladic read this letter out to us from his manuscript, asking
17 for our input, whether something needs to be removed or put in, and the
18 letter was drafted in a manner of a commander, without nice turns of
19 phrase or political balancing. It was rather arrogant and sounded like
20 an ultimatum, Unless you do this, I will do that, and so on and so forth.
21 And I remember Gvero and Tolimir making comments about, Why didn't you
22 phrase it like this or like that? As I was listening to that, I was
23 getting more and more agitated. I don't know whether Tolimir remembers
24 that. We were sitting around those tables between the huts, and I told
25 everyone, You are telling the commander this is not right, instead of
1 giving a proposal as how it should be drafted.
2 I don't know what happened next with the letter, whether Mladic
3 changed it or not. I can't remember that anymore. But what I'm trying
4 to say is that both Tolimir and Gvero had the courage to criticise
5 Mladic. In other words, General Mladic, although he was the commander,
6 he viewed things democratically and would listen to proposals by others.
7 We in the Main Staff knew that General Mladic trusted
8 General Tolimir a lot, and I didn't mind that at all. And that's the
9 reason why I told the Trial Chamber in the previous trial about if there
10 were any other right hands, it's his thing. He had trust in -- he
11 trusted Tolimir and he trusted Beara, and I never understood why Beara.
12 Q. You stated that a part of the responsibility of the Intel and
13 Security Sector, General Tolimir, would be the prevent of any leaks of
14 information. Can you tell us what that means?
15 A. For instance, if we're preparing an operation, Tolimir's task or
16 his sector's task, not objective, was to make sure that the enemy would
17 not find out about the operation before we start with the operation
18 itself. In other words, to cover up the intentions of the VRS, to make
19 the enemy believe or to make the enemy reach wrong conclusions. In
20 accordance to what Napoleon had said, If you see the enemy making
21 mistakes, assist him in making mistakes.
22 And I think the sector was rather successful in its task until,
23 of course, the Logistics Service got involved, because then they would
24 start making requisitions or getting the materiel, and then, of course,
25 it would come out, Oh, yes, because the VRS is planning an attack against
1 Zuc. But, in any case, their main task was to hide the intentions and
2 all elements involving the functioning of the army. The enemy should not
3 have found out anything our intentions before we hit them.
4 There was one thing that they failed to uncover. The
5 Intelligence Service did not inform me about preparations of the
6 Croatian Army for their Operation Storm. They informed me about
7 Operation Flash, but I didn't know anything about Operation Storm until
8 it started. And it is impossible; they couldn't have linked things up,
9 because Croats were bringing their forces from Rijeka, Bjelovar, and
10 Varazdin, and Osijek, Omis, Split, bringing them all to the area of
11 Glamoc. They had 75.000 troops there, and it's impossible for the
12 Intelligence Service not to have noticed that, and they should have told
13 me about it. Instead, they let me attack the Muslim forces in the area
14 of Bihac, and that is one thing that will remain on their souls forever.
15 Q. Do you recall how you, just in a few words, described
16 General Tolimir's job in the Popovic trial?
17 A. I did review the transcript before coming here and partially
18 listened to the CD recording, but I'm not sure what context you are
19 referring to, in terms of me describing Tolimir. I think I said more or
20 less the same thing; perhaps not in so many words, though.
21 Q. I recall some -- one of us - it may have been a Defence
22 attorney - asking you if someone was General Mladic's eyes and ears. Do
23 you remember that?
24 A. Yes, I think that was Counsel Zivanovic's question. He asked me
25 whether Tolimir was Mladic's eyes and ears, and I said that this was
1 precisely Tolimir's duty. He was in charge of gathering intelligence.
2 Those would be Mladic's ears. He also prevented any leaks of information
3 from the VRS, meaning he was there to open Mladic's eyes. Tolimir, being
4 an intelligence officer, was supposed to act as the ears and eyes of the
5 commander.
6 Q. And aside from this failure for you to get good intelligence on
7 the Western Front, how good was Tolimir -- General Tolimir at his job?
8 A. Yes, he was.
9 Q. We've just got five more minutes. Could you briefly explain how
10 effective General Tolimir was at accomplishing the tasks that you've
11 described and how intelligent he was in going about that work?
12 A. General Tolimir, in his own sector, did not hire his assistants,
13 the chief of the Intelligence Administration and the
14 Security Administration, to the --
15 THE INTERPRETER: Interpreter's correction: He did not involve
16 them.
17 THE WITNESS: [Interpretation] ... in his work to the extent he
18 should have, I believe, because he always knew more than the two of them
19 did.
20 However, throughout the war, General Tolimir worked on the
21 relationship of the VRS and foreign militaries, such as UNPROFOR, since
22 we did not have separate bodies to deal with it. He accompanied
23 General Mladic at all negotiations and talks, be it at home or abroad.
24 I think he became exhausted in liaising with UNPROFOR generals, albeit it
25 was justified. All contact with other armed forces went through
1 General Tolimir. I think he was quite successful in doing so, and this
2 relieved Mladic and myself to a great extent. He had a feel for
3 diplomacy.
4 Another thing: General Tolimir wrote down everything. I don't
5 think I'll exaggerate if I told you that he had his note-book even at
6 lunchtime, and we always teased him, asking him, Why do you write so
7 much? And he would always say, It's for posterity; it should remain for
8 history's sake.
10 Q. Did his responsible for the prevention of leaks of important
11 military information extend to preventing leaks to the international
12 community and the public media?
13 A. I couldn't know what it was he was doing vis-à-vis the
14 international community. He was in charge of preventing any leaks,
15 including anyone, not just the enemy, but anyone else who wasn't supposed
16 to now. That is what "prevention of leaks" means. Information must not
17 leave the organisation.
18 If the enemy, the Muslims or Croats, are not supposed to receive
19 a certain piece of information, it meant that the foreigners were not
20 there to receive it either, because then they would pass it on to our
21 enemy. I don't know whether they ever passed information on our enemy to
22 us. To the extent of my contact with them, that was not my experience.
23 But I do know that the information I gave them they regularly conveyed to
24 the Muslims and Croats.
25 When Mladic or I spoke on the phone, Tolimir was always there
1 tugging at our sleeves, mostly Mladic's, saying, They're eavesdropping;
2 they're intercepting; don't say that.
3 I had occasion to listen to a tape including a conversation
4 between Mladic and a Colonel Vukovic, telling him to fire at the
5 Presidency building and to hit the Muslims hard, and then Mladic also
6 says, All right, all right, Tolimir, just let me be. So he was probably
7 there, telling him not to say such things.
8 Later on, you could hear that particular conversation. At
9 Radio Sarajevo, for half a year they would regularly start their
10 broadcast of the day with that.
11 MR. McCLOSKEY: Thank you, General. It's break time.
12 JUDGE FLUEGGE: Indeed. We have to adjourn for the day, and we
13 will resume tomorrow morning at 9.00 in this courtroom.
14 Please be reminded that there is no permission for you to have
15 contact with either party about the content of your testimony here in
16 this trial.
20 to be reconvened on Wednesday, the 18th day
21 of May, 2011, at 9.00 a.m.