IT-09-92-T 83444 D83444 - D83399 28 October 2014 DV

THE INTERNATIONAL CRIMINAL TRIBUNAL FOR THE FORMER YUGOSLAVIA

Case No. IT-09-92-T IN THE TRIAL CHAMBER

Before: Judge Alphons Orie, Presiding Judge Bakone Justice Moloto Judge Christoph Flügge

Registrar: Mr. John Hocking

Date Filed: 10 October 2014

THE PROSECUTOR

v.

RATKO MLADIĆ

PUBLIC WITH PUBLIC ANNEX A and PUBLIC ANNEX B

DEFENCE MOTION PURSUANT TO RULE 92TER TO ADMIT THE WRITTEN TESTIMONY OF VOJO KUPREŠANIN

The Office of the Prosecutor: Mr. Peter McCloskey Ms. Camille Bibles

Counsel for the Accused: Mr. Branko Lukić Mr. Miodrag Stojanović

IT‐09‐92‐T 28 October 2014 1 IT-09-92-T 83443

THE INTERNATIONAL CRIMINAL TRIBUNAL FOR THE FORMER YUGOSLAVIA

PROSECUTOR

v.

RATKO MLADIĆ PUBLIC

WITH PUBLIC ANNEX A and PUBLIC ANNEX B

DEFENCE MOTION PURSUANT TO RULE 92TER TO ADMIT THE WRITTEN TESTIMONY OF VOJO KUPREŠANIN ______

The Accused, RATKO MLADIĆ, by and through his counsel of record, respectfully submits the instant Motion pursuant to Rule 92ter of the Rules of Procedure and Evidence, and in support thereof states as follows:

I. INTRODUCTION

1. Pursuant to the Guidance previously expressed by the Trial Chamber, motions offering written statements under Rule 92ter of the Rules of Procedure and Evidence are to be filed at least 30 days before the anticipated testimony of a given witness. Witness VOJO KUPREŠANIN is currently scheduled to testify approximately within 30 days and thus the Defense hereby files the instant motion in compliance with the Chamber’s guidance, and applying for the evidence of this witness to be heard pursuant to Rule 92ter. This Motion is filed publicly, as the witness does not require protective measures.

IT‐09‐92‐T 28 October 2014 2 IT-09-92-T 83442

2. Herein this application is made to tender one written witness statement of the witness, with 46 associated exhibits. At this time the Defense estimates that the evidence-in-chief of this witness will last up to 30 minutes.

3. The Defense does not otherwise seek to deviate from the Chamber’s Guidelines in tendering this witness’ evidence.

II. APPLICABLE LAW

4. Under Rule 92ter of the Rules of Procedure and Evidence (hereinafter “Rules”) a Trial Chamber is permitted to admit the evidence in whole or in part in the form of a witness statement or transcripts of a proceeding before the Tribunal, under the following conditions: i) the witness is present in court; ii) the witness is available for cross-examination and any questioning by the Judges; and iii) the witness attests that the written statement or transcript accurately reflects the witness’s declaration and what the witness would say if examined.1

5. A party calling a witness pursuant to Rule 92ter may seek to admit into evidence documents that have been discussed by the witness in his or her witness statement of previous testimony.2

III. DISCUSSION OF ARGUMENTS

a) The Chamber Should Admit the Witness Statement

1 Rule 92ter of the Rules of Procedure and Evidence. 2 Prosecutor v. Karadzic, Case No. IT-95-5/18-T, “Decision on Prosecution’s Submission regarding Additional Transcript Pages from Momcilo Mandic’s Stanisic and Zupljanin Testimony for Admission into Evidence.” 8 September 2010, para.5.

IT‐09‐92‐T 28 October 2014 3 IT-09-92-T 83441

6. The Defence seeks leave of the Chamber to call Vojo Kuprešanin as a witness pursuant to Rule 92ter. The Defence submits that the proffered statement, (attached hereto as Annex A) meets the requirements of Rule 92ter, and thus should be admitted under that Rule.

7. Witness Kuprešanin’s statement is relevant, reliable and probative, as set forth in greater detail herein below.

8. The witness will be present at trial, and thus will be able to attest to the evidence and will be available to be cross-examined by the Prosecution. Thereby the requirements of Rule 92ter will be fulfilled, and fairness to the Prosecution will be observed.

9. The Defense submits that due to the nature of the Witness’s testimony 30 minutes will be necessary in order to conduct a limited and focused direct examination of the witness to clarify, expand on, and contextualize aspects of his evidence directly relevant to the Defense case.

10. Witness Kuprešanin was born on 1 June 1948 in Kukulje Srbac municipality.3 Kuprešanin is a teacher but also graduated as a Management Engineer.4 Witness Kuprešanin engaged in politics before the first municipality elections and formed the Yugoslav Democratic Party – homeland Front political party in 1990 then in 1992 his party became part of the SDS.5 Witness Kuprešanin was a deputy in the Chamber of Citizens in the BH Parliament and member of the SDS Main Board (GO).6 The first half of 1991 Kuprešanin was assigned as President of the Assembly of the Community of Municipalities of and then President of the Assembly of the Autonomous Region of Krajina in the second half of 1991.7 During the war witness Kuprešanin was

3 Statement, para.1 4 Id. 5 Id. 6 Id. 7 Id.

IT‐09‐92‐T 28 October 2014 4 IT-09-92-T 83440

the Director of the Radio and Television.8 After war, Kuprešanin returned to work to Homeland Front, opened a shop party and worked again as teacher in a Primary School until his retirement in 2013.9

11. Witness Kuprešanin’s testimony is relevant to and probative of salient and material issues pertaining to the Indictment. The Defense is confident in that it will, among other things, establish the following: a. The establishment and formation of Municipalities of Bosnia Krajina (ZOBK), its relevance to the development of the community and the treatment of , Muslims and as brothers by the President of the ZOBK.10 b. The functioning and composition of the ZOBK, the presence of Muslims and Croats in the Assembly, the adoption of the ZOBK Statute and its independence from political parties.11 c. The objectives of the ZOBK.12 d. The adoption by ZOBK of certain liberties from the Constitution which allowed them the respective monitoring of events in areas such as economy, politics, information and culture.13 e. The financing of the ZOBK, the decentralization of BH and their relationship regarding funds and the financing of central organs.14 f. The relevant interest by ZOBK to certain enterprises, organizations and institutions.15 g. The Serb aim to hold a join assembly of the two Krajinas and the further adoption of the Declaration on the unification of the two Krajinas.16

8 Id. 9 Id. 10 Statement, paras.2-3 11 Statement, para.4 12 Statement, paras.3,5,7 13 Statement, para.6 14 Statement, para.8 15 Statement, para.9 16 Statement, para.10

IT‐09‐92‐T 28 October 2014 5 IT-09-92-T 83439

h. Karadzic’s vision regarding the territorial unification of the two Krajinas.17 i. The decisions of concern and value of the two Krajinas were made at the level of the Krajinas themselves.18 j. The idea to create a Krajina State and the organization of a referendum on unification of the two Krajinas.19 k. The general concern regarding the concentration of Croatian forces along the border with BH.20 l. The adoption of the Statute of the Autonomous Region of Krajina; the equality of the three nations and nationalities and the financing of the ARK organs.21 m. The decision regarding the declaration of the ARK as part of the SFRY. The rest of the areas in BH and were Serbian Autonomous districts and the only area established as an autonomous region.22 n. The protection of Serbs who were exposed to the most heinous crimes in .23 o. The position of Krajina regarding the war.24 p. The remaining of the state of Yugoslavia by some Serbs and Muslims; the organization of the plebiscite and the respective voting.25 q. The holding of some managerial positions by political parties and Karadzic’s position regarding this topic.26 r. The formation, creation and functioning of the Crisis staff of the ARK.27

17 Statement, paras.11, 13-14, 27 18 Statement, para.12 19 Statement, paras.13-14 20 Statement, para.15 21 Statement, paras.16, 33 22 Statement, para.17 23 Statement, para.18 24 Statement, paras.19-20 25 Statement, paras.21, 23-24 26 Statement, para.22 27 Statement, paras.25, 37, 39-40

IT‐09‐92‐T 28 October 2014 6 IT-09-92-T 83438

s. Brđanin and Vukić’s implementation of their own ideas against the party’s view.28 t. The conversations between Karadzic and Kuprešanin regarding the Cutilerio Plan and Krajina.29 u. The Krajina fraction headed by some leaders and the opposition of this fraction by others such Karadzic.30 v. The lack of contact between witness Kuprešanin with Pale and Kardzic in April 1992.31 w. The formation of National Defence Council of the ARK as a result of the attack of Serbian areas by Muslims and Croats.32 x. The decision to form a special Purpose police detachment by the ARK Assembly.33 y. The advocating by the JNA to preserve the peace in BH.34 z. The material support for the soldiers.35 aa. Witness Kuprešanin’s knowledge and speeches regarding the engaged of some army members in immoral activities and his request to be honorable and honest.36 bb. Kuprešanin actions under Karadzic request to improve the prisoners’ living conditions and to release prisoners.37 cc. The negotiations to surrender weapons in Kotor Varoš.38 dd. President of the ARK had no authority to dismiss any of the municipal presidents.39

28 Statement, para.28 29 Statement, para.29 30 Statement, paras.30-32 31 Statement, para.34 32 Statement, para.35 33 Statement, para.36 34 Statement, para.38 35 Statement, para.41 36 Statement, para.42 37 Statement, para.43-45 38 Statement, para.46 39 Statement, para.47

IT‐09‐92‐T 28 October 2014 7 IT-09-92-T 83437

ee. The fall of the municipalities of Bosnian Krajina under the onslaught of the Croatian and Muslim forces which were supported by Nato aircraft and logistics.40 ff. Witness Kuprešanin knowledge regarding the election of General Mladić as commander of the army.41

b) The Chamber Should Admit the Associated Exhibits

12. Each associated exhibit is directly relevant to the case, and is inseparable and indispensable to the witness’s statement, and can be contextualized and explained most effectively through this witness. They constitute an essential component of the witness’ evidence, and also are of importance to the Defense case, and therefore it is submitted that it is in the interests of justice that they be admitted.

13. There are a total of 46 associated exhibits to this witness statement, as set out in the table that is attached at Public Annex B.

14. The associated exhibits will help assist the Chamber in understanding the evidence of this witness, as the documents relate to: a. The establishment, formation, functioning, composition and objectives of Municipalities of Bosnia Krajina (ZOBK).42 b. The political situation of the two Krajinas.43 c. The concern regarding the concentration of Croatian forces along the border with BH.44 d. The general situation of the ARK; the adoption and financing of the ARK; the formation of National Defence Council of the ARK.45

40 Statement, para.48 41 Statement, para.49 42 Statement, paras.3-9 43 Statement, paras.10-14, 19-20, 27, 29-33 44 Statement, para.15 45 Statement, paras.16-17, 33, 35-36, 39-40, 47

IT‐09‐92‐T 28 October 2014 8 IT-09-92-T 83436

e. The protection of Serbs in Slavonia.46 f. Karadzic position regarding the two Krajinas g. The organization of the plebiscite in order to remain the state of Yugoslavia by some Serbs and Muslims.47 h. The holding of some managerial positions by political parties and Karadzic’s position regarding this topic.48 i. The material support to soldiers, the request to improve the prisoners’ living conditions and the released of some of them.49 j. The negotiations to surrender weapons in Kotor Varoš.50

46 Statement, para.18 47 Statement, paras.21, 23-24 48 Statement, para.22 49 Statement, para.41-42, 45 50 Statement, para.46

IT‐09‐92‐T 28 October 2014 9 IT-09-92-T 83435

III. CONCLUSION

WHEREFORE, for the foregoing arguments, the Defense respectfully requests that the Chamber issue an order: a. Granting the Defense leave to call Vojo Kuprešanin as a witness pursuant to Rule 92ter. b. Granting the Defense leave to admit the proffered statement, (attached hereto as Annex A) under Rule 92ter. c. Granting the Defense leave to admit the list of associated exhibits, (attached hereto as Annex B) under Rule 92ter.

Word Count: 1,718

RESPECTFULLY SUBMITTED BY:

Branko Lukić Miodrag Stojanović Lead Counsel for Ratko Mladić Co-Counsel for Ratko Mladić

IT‐09‐92‐T 28 October 2014 10 IT-09-92-T 83434

THE INTERNATIONAL CRIMINAL TRIBUNAL FOR THE FORMER YUGOSLAVIA

Case No. IT-09-92-T

THE PROSECUTOR

v.

RATKO MLADIĆ

PUBLIC

ANNEX A ______

IT‐09‐92‐T 28 October 2014 11 IT-09-92-T Translation 83433

INTERNATIONAL TRIBUNAL FOR THE PROSECUTION OF PERSONS RESPONSIBLE FOR SERIOUS VIOLATIONS OF INTERNATIONAL LAW COMMITTED IN THE TERRITORY OF THE FORMER YUGOSLAVIA SINCE 1991

WITNESS STATEMENT

WITNESS DETAILS:

Last name: KUPREŠANIN

First name: Vojo

Father’s name: Petar

Date of birth: 1 June 1948

Ethnic origin: Serbian

Date(s) of interview(s): 20 March 2014

Interviewer(s): Mikajlo MITROVI Ć and Branko LUKI Ć

Language(s) used in interview: Serbian

Signature of witness:

140624-ET Statement of KUPRESANIN Vojo AMENDED.docx /drsc 1 IT-09-92-T Translation 83432

WITNESS STATEMENT – VOJO KUPREŠANIN

PERSONAL DETAILS

1. My name is Vojislav KUPREŠANIN. I was born on 1 June 1948 in Kukulje, Srbac municipality. I graduated from a teacher training school and later from the Faculty of Management, obtaining the title of Management Engineer. In the period before the war broke out in BH, between 1985 and 1990, I ran a private shop. I became engaged in politics before the first multiparty elections. On 4 March 1990, I formed the Yugoslav Democratic Party – Homeland Front political party in Kukulje, BH. On 12 July 1992, my party became part of the SDS /Serbian Democratic Party/. After this, I served as a deputy in the Chamber of Citizens in the BH Parliament. I was also a member of the SDS Main Board (GO). In the first half of 1991, I was elected President of the Assembly of the Community of Municipalities of Bosnian Krajina (ZOBK), and in the second half of the same year I was elected President of the Assembly of the Autonomous Region of Krajina (ARK). During the war, I also occupied the post of Director of the Radio and Television. After the war, I reactivated the work of my party, the Homeland Front, and opened a shop again. Between 2004 and 1 June 2013, I worked in the Dositej Obradovi ć Primary School in Razboj. I retired on 1 June 2013.

COMMUNITY OF MUNICIPALITIES OF BOSNIAN KRAJINA

2. The Community of Municipalities of Bosnian Krajina (ZOBK) was established primarily for economic reasons. After the Second World War, was economically the second most powerful city after Sarajevo, only to find itself in the 22 nd place in 1990. We found a legal basis for the formation of the ZOBK in Article 4 of the BH Constitution, which provides that municipalities may make associations on economic grounds. The ZOBK included 17 municipalities which gravitated towards Banja Luka, except for , which did not join the ZOBK. The pro-Yugoslav bloc from Bosnian Krajina came together with the objective of preserving Yugoslavia, and experts in the sphere of the economy and trade and industry came to our assistance, especially from the Banja Luka Economics Institute. Our region had a trade surplus of several hundred million dollars, and all this money went to the Central Bank in Sarajevo and we received crumbs in return. For example, the Šipad firm for the exploitation of all the forests of BH had its central office in Sarajevo, and not in Baja Luka, even though 70% of the woodland was in Bosnian Krajina. These were the reasons why we leaders from Krajina launched an initiative for the formation of the ZOBK.

140624-ET Statement of KUPRESANIN Vojo AMENDED.docx /drsc 2 IT-09-92-T Translation 83431

3. I have been shown document 65ter 16256 - This is a newspaper article citing my speech following my election as President of the ZOBK Assembly. At this session, I addressed not only the Serbs, but also the Muslims and the Croats, referring to them as brothers and thanking them for electing me. I explained the reasons for the formation of the ZOBK and stressed that the people of Bosnian Krajina had been on the margins and that we were politically and economically completely undeveloped. I emphasised especially that by forming the ZOBK we were not destroying Bosnia’s borders and that its formation was in accordance with the law and the Constitution. In other words, a cultural, economic and information community had been formed. I also advocated the spiritual renaissance of the Serbian people, because communism had set the Serbian people back so much that in BH in 1990 there was not a single typewriter with the Cyrillic alphabet.

4. I have been shown document 65ter 07197 – I have already said that I was elected President of the ZOBK Assembly. Each member municipality delegated seven deputies to the Assembly, which in turn appointed the Government of Krajina and its ministers and formed the Krajina institutions. The Assembly also adopted the ZOBK Statute (the Little Constitution). The ZOBK did not function as a branch of the SDS but as an independent body that acted independently and without regard to the political parties. There were also members of other political parties in the ZOBK and we all worked towards one single idea: to live from our work and ensure that the natural resources in these parts were ours. There were also Muslims and Croats in our Assembly; they were delegated by municipalities in which they were deputies for the SDA /Party of Democratic Action/ and the HDZ /Croatian Democratic Union/, but they eventually they stopped coming to the sessions at the instruction of the SDA and HDZ central offices. During this period, we did not have contacts with Dr KARADŽI Ć, KRAJIŠNIK, KOLJEVI Ć or PLAVŠI Ć concerning the implementation of this ZOBK project. They did not help us, but they did not hinder us either.

5. I have been shown document 65ter 1D02036 , which confirms on pages 52-53 that the objective of the ZOBK was not to destroy the borders of Bosnia and that the ZOBK region was formed in compliance with federal and republican laws.

6. I have been shown document 65ter 16868 – By means of these Rules of Procedure we took certain liberties from the BH Constitution and transferred them to ourselves. The basic aim was to monitor the events in the spheres of the economy, politics, culture and so on, since these had been alienated from this region. In the sphere of information, Banja Luka and its region had the IT Centre of Sarajevo Television and all the events in the sphere of information was more or less given in doses by the central Sarajevo Television. Our region did not even exist on the media sky in BH. YUTEL TV was also founded at this time (Goran MILI Ć was its boss) and,

140624-ET Statement of KUPRESANIN Vojo AMENDED.docx /drsc 3 IT-09-92-T Translation 83430

together with BH TV and Croatian TV, it strove to demonise the Serbs. TV Belgrade broadcasts were cut off at the same time.

7. I have been shown document 65 ter 16255 – This concerns a press conference that I attended in my capacity as President of the ZOBK Assembly, at which we expressed a wish for , Biha ć, Velika Kladuša, Bosanski Novi, , Prijedor, , Gornji Vakuf, and to join the ZOBK. We asked them to join in order to show that the ZOBK’s objective was not to create a Serbian community of municipalities. I sent a letter to Fikret ABDI Ć in Velika Kladuša and attempted to contact him on several occasions with a view to us all engaging in the economic sphere for the good of all the peoples of Bosnian Krajina. I wanted the food company, whose director was Fikret ABDI Ć, to buy raw materials as much as possible from this area (Lijev če Polje and ) in order to avoid imports from other states and republics and to ensure that the farmers from this area had a guaranteed buyer, thereby ensuring maximum employment for the people of Bosnian Krajina. Regrettably, I never received a reply from Mr ABDI Ć, although I always found him and pleasant and friendly.

8. I have been shown document 65ter 16110 – This concerns a session of the ZOBK Assembly. To begin with, the ZOBK organs were financed by member municipalities which sent meagre contributions, a pittance, until eventually even this dried out. On the other hand, we could not get funds from the Republic because the republican laws did not favour us because the political parties that had won the elections and were active in the BH Parliament did not busy themselves with the economy at the time but with politics, so they did not do what was needed with regard to the decentralisation of BH. BH should have been decentralised then so that the biggest part of the funds would return to where it came from, because no one from the regions tried to avoid financing the central organs. I personally received a salary for only a few months while I performed the duty of President of the Assembly of ZOBK and later of the ARK. Nor as a deputy in the BH Parliament did I receive a salary or even a single dinar during the year and a half that I worked in Parliament. When I became a deputy of the Assembly of the Serbian People in BH, my salary was 10 German marks a month, and only professionals received salaries and I was one of them. At the session described in this document, it was proposed the following entities operate at the ZOBK level: public enterprises, information, chamber of commerce, regional SUP /Secretariat of the Interior/, judiciary, office of the prosecutor, KMC /Clinical Medical Centre/, SDK /Public Auditing Service/, PTT /post, telegraph, telephone/, university, forestry, agriculture and electric power company. We wanted to take control of the segments of society that were of significance to the Krajina, and in all this we did not coordinate at all with the republican organs which were busy exclusively with politics, as if they did not want to create a functional state to suit both individuals and the people. The basic objective and task of the SDA and HDZ

140624-ET Statement of KUPRESANIN Vojo AMENDED.docx /drsc 4 IT-09-92-T Translation 83429

was to take control over others and command them against their will. It was also proposed that the ZOBK Assembly cancel the subscription to RTV Sarajevo, which did not broadcast our support for Yugoslavia, and to build a TV Krajina. The Banja Luka IT Centre eventually grew into TV AR Krajina. Events moved on so quickly that we were unable to put anything into operation in the true sense of the word. Events like those in Slovenia and Croatia pushed our wishes to the side, and Serbian refugees from Croatia were already arriving in Krajina.

9. I have been shown document 65 ter 17222 – Item 1 of this documents concerns the issuing of a decision on the status of public and socially-owned enterprises and organisations and institutions of special interest to the ZOBK. As far as I recall, this refers to health and education funds, as well as other funds of public interest in these parts. In the Krajina we wanted to emulate the German regions.

10. I have been shown document 65ter 1D02433 – A telephone conversation between Dr KARADŽI Ć and VUKI Ć. Since it was already clear that Yugoslavia was falling apart, we in the Krajina wanted to protect the few Serbs in Croatia, and this was also the heart’s desire of all the Serbs of whose existence we were not aware in Tito’s Yugoslavia and who suffered and were decimated in the Second World War, so we wanted to them to join us and unite with them, which was also their heart’s objective, i.e. the union of the two Krajinas (the SAO /Serbian Autonomous District/ and the Bosnian Krajina). For this reason we held a joint assembly of the two Krajinas, composed of the deputies of both Krajinas (the AR Krajina and the Republic of Serbian Krajina) and on 28 June 1991 we adopted a Declaration on the unification of the two Krajinas, which pronounced that, by the will of the deputies, the Republic of Serbian Krajina was joining the rest of Yugoslavia.

11. I have been shown document 65ter 20099 – A telephone conversation between Dr KARADŽI Ć and me. At that time I sought to protect the Serbian people from a potential pogrom, and this conversation shows that Dr KARADŽI Ć was not on the same wavelength as us from Krajina because he was against the territorial unification of the two Krajinas. Dr KARADŽI Ć advocated the preservation of the AVNOJ /Anti-Fascist Council of the People's Liberation of Yugoslavia/ borders, which was in my opinion fatal for the Serbian people, because the AVNOJ borders were drawn up during the Second World War by a few Communists who had overturned the constitutional and legal order of the Kingdom of Yugoslavia.

12. I have been shown document P04174 – A contract on cooperation between the SAO Krajina and the ZOBK, which says in Item 4 that all legal documents governing cooperation would be issued by the institutions, organs and entities affected by these decisions, while decisions relevant to the development of these two Krajinas would be taken at the level of the Government and the Executive Council and the assemblies of

140624-ET Statement of KUPRESANIN Vojo AMENDED.docx /drsc 5 IT-09-92-T Translation 83428

the SAO Krajina and the ZOBK. In other words, all decisions of interest and importance to the two Krajinas were supposed to be made at the level of the Krajinas themselves.

13. I have been shown document 65ter 20153 – A telephone conversation between Dr KARADŽI Ć and me. As far as I recall, VUKI Ć and BR ĐANIN held a meeting with Milan BABI Ć from the SAO Krajina concerning the organisation of a referendum on unification of the two Krajinas. This conversation shows that the leaders from the Krajina took steps on their own initiative and in good faith in order to realise the eternal ambitions of the Serbian people in these parts who were divided by the AVNOJ borders. Dr KARADŽI Ć considered that these decisions had not been authorised by the SDS GO. The idea of unification of the two Krajinas was stronger than the party policy and Radovan KARADŽI Ć’s opinion, although we were aware that SDS GO decisions were binding.

14. I have been shown document 65 ter 21323 – A telephone conversation of Dr KARADŽI Ć. The idea that existed in Krajina was to create a Krajina state on the territory of both Krajinas, from Grahovo to Derventa, as a sovereign state or federal unit within the framework of Yugoslavia. This project was headed by RADI Ć, VUKI Ć, BR ĐANIN and LAZAREVI Ć, and the idea simply got into people’s heads. The process of preparing a constitutive assembly of the Republic of Krajina took place later in March 1992. I invited to the assembly both Dr KARADŽI Ć and Mr KRAJIŠNIK, who were absolutely against the creation of this Krajina state. The goal of the Krajina leaders was to dismiss KARADŽI Ć and KRAJIŠNIK, because they were against the project, but what was actually taking place was the trend towards splitting up the Serbian nation. Some even physically attacked Dr KARADŽI Ć on two separate occasions. I believe it was RADI Ć who was the most vociferous in the project of creating a Krajina federal unit. The idea of unification of the Krajinas was stronger than the party policy because even the people shouted “Bandits! Bandits!” at the SDS leaders who were against the project. All this was at VUKI Ć's initiative. The people of Krajina were with BR ĐANIN and VUKI Ć at the time.

15. I have been shown document 65 ter 16121 and document 65ter 20255 – These concern a statement of the ZOBK Assembly and a telephone conversation between Dr KARADŽI Ć and me. The situation was becoming dramatic and concern was great because of the concentration of Croatian forces along the border with BH. This is why I discussed this with Dr KARADŽI Ć and the ZOBK Assembly issued a press statement.

140624-ET Statement of KUPRESANIN Vojo AMENDED.docx /drsc 6 IT-09-92-T Translation 83427

AUTONOMOUS REGION OF KRAJINA

16. I have been shown document 65 ter 06875 – In September 1991, the Statute of the Autonomous Region of Krajina (ARK) was adopted. Article 3 of the Statute shows that the nations, that is to say, all three nations, decided which matters were in the jurisdiction of the ARK, and Article 4 shows that all the nations and nationalities were equal. Article 10 enabled other municipalities with a non-Serbian majority population to join the ARK, and to this end we established contacts with Tuzla and Biha ć with the goal that they would act as we had done in Krajina and prevent the drainage of capital from their areas to Sarajevo. Both the Assembly President and the Executive Council of the ARK were answerable for their work to the ARK Assembly. Articles 36 and 37 show that the municipalities financed the work of the ARK organs. The associated municipalities later stopped sending money to the ARK organs; as time went on, one by one, the municipalities stopped paying in funds.

17. I have been shown document EXH P06485 – The decision to declare the ARK an inseparable part of the SFRY /Socialist Federative Republic of Yugoslavia/. All the other areas in BH and Croatia were Serbian autonomous districts: only our area was an autonomous region, without the adjective “Serbian”. We wanted to satisfy the other nations that lived in these areas of Krajina. Pursuant to Article 7, the ARK Assembly was responsible for separating inhabited areas from one municipality and joining them to another in accordance with the expressed will of the citizens. It can also be seen that this was done in accordance with the BH Constitution, to which Dr KARADŽI Ć also drew attention in a telephone conversation ( EXH P02645 ) when he said that we were the legal representatives of the Assembly, that we were doing our duties in keeping with the Constitution and that everything we had done up to that time was in keeping with the Constitution. Nevertheless, even though the BH Constitution allowed this option, there were no instances in which one or more villages joined another municipality.

18. I have been shown document 65ter 20268 – A telephone conversation between Dr KARADŽI Ć and me. The Commander of the JNA /Yugoslav People’s Army/ in our district was General UZELAC and we asked him to protect the Serbian people who were exposed to the most heinous crimes in Slavonia (Republic of Croatia). We asked UZELAC to act in the practical sense of the word, but he said that he would not make a single move, because his brother lived in Zagreb and the Croats would kill him if he so much as lifted a finger. When I left one of the meetings, General UZELAC said about me, “This man should be killed as soon as possible.” The Serbs in Krajina did not have a paramilitary force like the Croats in Croatia did, but only the Yugoslav Army, which we supported because it was the only legal military force in Yugoslavia.

140624-ET Statement of KUPRESANIN Vojo AMENDED.docx /drsc 7 IT-09-92-T Translation 83426

19. I have been shown document 65 ter 1D02283 – This is my interview to the Borba newspaper. Political events in other republics, but also in BH itself, had forced us in Krajina to reciprocate and react to the actions of others. The SDA and the HDZ were already attempting to impose the Declaration on the Sovereignty of BH, for which reason we asked for protection through the ARK, but the objective was to preserve Yugoslavia. Thus, in addition to economic reasons, the ARK acquired a political dimension. In the end, the ARK was open to other peoples who wished to join it.

20. I have been shown document 65ter 20421 – A telephone conversation between Dr KARADŽI Ć and General UZELAC. General UZELAC misinformed Dr KARADŽI Ć that I had declared a state of war.

21. I have been shown document 65ter 1D02026 – A telephone conversation between Dr KARADŽI Ć and me. The conversation concerns the organisation of the plebiscite of citizens on remaining in the joint state of Yugoslavia, and it can be seen from the conversation that even citizens of Muslim ethnicity called me to ask about the voting, which made Dr KARADŽI Ć and me personally happy because we wanted all the peoples to live together.

22. I have been shown document 65ter 16846 – A record of a session of the ARK Assembly which says that representatives of the SDP /Social Democratic Party/, SDA and HDZ political parties were in managerial positions in public and socially-owned companies in almost all municipalities and the SDS leadership demonstrated very little ability to change this state of affairs. In municipalities where the SDS had won, the posts of directors of companies, institutions and the like were occupied by the same people as in socialist Yugoslavia. I insisted that they be replaced and that SDS representatives be appointed, but Dr KARADŽI Ć was against this and made references to harmony and unity to justify his actions and insisted that the old managers should remain in their old positions. In addition to this, we advocated that a state of war be declared because the SFRY had been attacked and we wanted to create a more serious situation in which deserters would be sanctioned.

23. I have been shown document 65ter 20435 – A telephone conversation between Dr KARADŽI Ć and me. The conversation is about voting in the plebiscite. VUKI Ć asked for a concession to be made for people who lived and worked abroad to vote a day earlier, because there was a large number of them. However, Dr KARADŽI Ć called for compliance with the decision of the Assembly that had determined the date of the plebiscite. It is evident from this conversation that KARADŽI Ć saw the Assembly as the supreme organ of the Serbian people and no one, himself included, could change its decisions.

140624-ET Statement of KUPRESANIN Vojo AMENDED.docx /drsc 8 IT-09-92-T Translation 83425

24. I have been shown document 65ter 1D02027 – A telephone conversation between Dr KARADŽI Ć and me. I believe that BR ĐANIN wanted to change the timing of the plebiscite, which would have been contrary to the decision of the Assembly of the Serbian People. The conflict between Dr KARADŽI Ć and BR ĐANIN smouldered continuously and varied in intensity.

25. When the Crisis Staff (KŠ) of the ARK was later established, the members of the KŠ and presidents of the municipalities asked me to get the ARK Assembly to verify the decisions of the ARK KŠ, but I disagreed and refused to do that. The RS // Government had ordered that crisis staffs be established in municipalities and not in regions, which is why I did not want to be President of the ARK KŠ. The ARK KŠ was formed by its members on their own initiative. Banja Luka, which should have had KŠ, according to the Government’s order, did not have a functioning KŠ. No one in the Krajina respected the Government’s decision.

26. I have been shown document 65ter 20520 – A telephone conversation between Dr KARADŽI Ć and me. It is evident from the conversation that Dr KARADŽI Ć was on very bad terms with Milan BABI Ć.

27. I have been shown document 65ter 17208 – Item 3 of this document shows that we advocated that Bosnian Krajina become a federal unit. The assemblymen were given a copy of a report entitled The Bosnian Krajina as a Constitutive Factor of the New Yugoslav Federation . Dr KARADŽI Ć was vehemently against Krajina becoming a federal unit or a republic, as can be seen from the telephone conversation between Dr KARADŽI Ć and STEVANDI Ć ( 65ter 20559 ), which has been shown to me. In other words, this was a conflict between two concepts or two approaches to the problem – one was for regionalisation and the other was centralist. Dr KARADŽI Ć popularised the power of Sarajevo, both in terms of the party and the Sarajevo government in general.

28. I have been shown document 65ter 20604 – A telephone conversation between Dr KARADŽI Ć and me. The conversation shows that BR ĐANIN and VUKI Ć did not think about the party’s views and just implemented their own ideas. They thought they were not bound by the general policy and were caught in the euphoria of the moment.

29. I have been shown document 65ter 20628 – A telephone conversation between Dr KARADŽI Ć and me. The conversation concerns the Cutileiro Plan, which envisaged the independence of BH without joining parts of BH to either Serbia or Croatia, but on condition that there would be a Serbian entity at the level of BH, which would have all the organs established in the Serbian Republic of BH. I agreed with all this because it preserved peace in BH. The proposals of the other Krajina

140624-ET Statement of KUPRESANIN Vojo AMENDED.docx /drsc 9 IT-09-92-T Translation 83424

option involved the creation of a Krajina state, with which neither Dr KARADŽI Ć nor I agreed.

30. I have been shown document 65ter 07202 – At the 13 th session of the ARK Assembly, the Krajina faction headed by LAZAREVI Ć continued to implement its idea of a Krajina state, contrary to the positions of Dr KARADŽI Ć, and in this they managed to take in even the people of Krajina.

31. I have been shown document P03900 – A meeting of the SDS Deputies Club. On page 31, I addressed those present, saying that the separatist Krajina faction was planning to declare the Republic of Krajina the following day and I had convened the assembly in order to pre-empt this move. I managed to prevent this separatist faction, headed by LAZAREVI Ć, BR ĐANIN, RADI Ć and others, which was working to achieve the idea of a Republic of Krajina. This group of people had called a constitutive session at which they planned to declare a Republic of Krajina stretching from Grahovo to Derventa, thereby breaking with the official SDS policy. This same group of people pursued the policy of the ARK throughout the war.

32. I have been shown document 65ter 06884 – A session of the ARK Assembly, which Dr KARADŽI Ć attended as a guest. At this session he emphasised that it would be a big mistake to declare Krajina a republic and that such ideas were infantile and caused problems for the Serbian people. The question at this session was “to be or not to be” for the creation of the Krajina state. At this session I managed to prevent the option of the Krajina separatists from being accepted. Dr KARADŽI Ć was even physically assaulted by members of the group, and I have already mentioned that people shouted “Bandits! Bandits!” The Krajina faction wanted to banish Dr KARADŽI Ć and the republican leadership from the Krajina, but we eventually managed to calm the situation down.

33. I have been shown document 65ter 16132 – This decision on the establishment of ARK funds is an essential decision of Krajina’s autonomy. The ARK was effectively the first state, the nucleus of the future Republika Srpska, but also a state within the RS state.

34. I have been shown document P02720 – A telephone conversation between General KUKANJAC and me. First of all, the conversation shows that at this time (April 1992) we did not have contact with Pale and Dr KARADŽI Ć. It also shows that, in contrast to the other Krajina faction, I respect Dr KARADŽI Ć because I have no choice. It can also be seen from the conversation that the Croats had attacked Grahovo, Kupres and Glamo č, and the Muslims had attacked , Krupa, Prijedor and Klju č. This was my first and, I believe, last conversation with

140624-ET Statement of KUPRESANIN Vojo AMENDED.docx /drsc 10 IT-09-92-T Translation 83423

KUKANJAC, and it was also obvious that coordination between the authorities and the JNA was poor.

35. I have been shown document 65 ter 16135 – Given that all the Serbian areas were attacked by the Muslims and Croats, as can be seen from the conversation with KUKANJAC, the ARK Assembly took the decision to form a National Defence Council of the ARK, as a working body of the ARK Assembly. One of the deputies from the threatened border areas had proposed this item for the agenda and the deputies adopted it. This decision has nothing to do with the decisions or positions taken by Pale or Dr KARADŽI Ć. We from the ARK operated independently as a state within a state.

36. I have been shown document P03863 – After voting, the ARK Assembly independently made the decision to form a special purpose police detachment. I do not recall whose initiative this was.

37. My understanding was that the reason for the formation of the crisis staffs was the tense and worrying situation in BH, and the Government, I think, explained this in the instruction. At any rate, the crisis staffs were not formed in order to expel the non- Serbian population. The municipal crisis staffs were independent from the Krajina Crisis Staff, especially because the functioning of the ARK before the war was dependent on the funds provided by the municipalities. The ARK Assembly could not dismiss any of the municipal presidents, and this issue was not regulated by the statute or law. The influence on the municipalities was nonexistent. In the end, the municipalities stopped earmarking funds for the work of the ARK. When the Government of the SRBH /Serbian Republic of Bosnia and / made the decision to form crisis staffs, my powers as President of the ARK Assembly effectively ceased to exist. I have no information that the ARK Crisis Staff contacted or received instructions from the leadership in Pale, but in my opinion and bearing in mind the bad relations between BR ĐANIN and other Krajina leaders on the one hand and Dr KARADŽI Ć on the other from before the war, I believe that there were no such contacts.

38. I have been shown document 65ter 03016 – This is a letter which the Command of the 5 th Corps of the JNA sent to me as the President of the ARK Assembly. The JNA advocated the preservation of peace in BH, and consequently in the ARK, and asked me to exert influence on the leadership in Klju č to prevent measures that jeopardised peace. Unfortunately, I had no control over or impact on the leadership of Klju č municipality, and I think that the leadership of Klju č municipality could not itself control events in the municipality and the activities of the paramilitary formations.

140624-ET Statement of KUPRESANIN Vojo AMENDED.docx /drsc 11 IT-09-92-T Translation 83422

39. I have been shown document 65 ter 1D02867 – This concerns an inter- municipal agreement between the municipalities of the - area. I see from the document that it was proposed that I should become President of the ARK Crisis Staff because I held the post of President of the ARK Assembly. Although the proposal was logical, I was not aware of being nominated for President of the ARK Crisis Staff, and in any event I never held that post. It can be seen from the rest of the document that the functioning of the Crisis Staff was unsatisfactory because its work was restricted to the Banja Luka local interest and it did not represent the interests of all the municipalities that made up the ARK. Basically, the ARK operated more like a crisis staff of Banja Luka municipality than the crisis staff of the ARK.

40. I have been shown document P03787 – This concerns a meeting of the Sanski Most Crisis Staff. The Sanski Most Crisis staff proposed that each municipality from the ARK territory appoint a representative for questions of relocation and exchange of population and prisoners and telefax the names to Vojo KUPREŠANIN, that is, to me. This is the first time I have seen this proposal and I have no information that people had been appointed in the municipalities to deal with the issue of population relocation, let alone that I had any contact with them. This is obviously just a proposal of the Sanski Most Crisis Staff, and I doubt that it ever came to fruition. Nor do I see or know whether this proposal was ever sent to anyone.

41. I have been shown document 65 ter 16598 – This is a document of the 1 st Krajina Corps regarding material support for the soldiers. Although I do not remember this document, I know that the municipalities fed and clothed soldiers and provided them with other logistical support. Given that the central state was not functioning, someone had to provide logistical support, so the burden fell on the municipalities.

42. I have been shown document 65ter 1D02284 – This is a letter sent to me by members of the Doboj Operations Group. There had been a political debate at the Cultural Centre in Gradiška to which all the politicians from Krajina had been invited. I had responded to the invitation because the others did not attend. The hall was full. Based on the anomalies that I had noticed in the army, I said as a patriot that there had been an erosion of morale in the Serbian army and that this army did not resemble the army that the Serbs were used to or what it ought to be. I added that a small number of army members were engaged in immoral activities, stressing that the state grows or loses itself depending on the moral actions of its army. I said that Rome had fallen because of thievery. I added that the Serbian army had to be honourable and honest, and the actions of the Serbian army in previous wars should be our heritage. I said that the Serbian soldier had to be brave when fighting the enemy and merciful towards Muslim and Croatian old people, women and children, and that the Geneva

140624-ET Statement of KUPRESANIN Vojo AMENDED.docx /drsc 12 IT-09-92-T Translation 83421

Conventions must be respected. However, newspapers incorrectly reported that I had said that 70% of the soldiers were engaged in crime, which I denied on television.

43. In August 1992, I visited the Manja ča prisoner-of-war camp (LZR). The following events led to my visiting Manja ča: not long before of the and Keraterm investigation centres were closed, Dr KARADŽI Ć called me and said the following: “Mr KUPREŠANIN, you have the authority and you can influence the leadership in Prijedor to close down the investigation centres,” which I heard had been formed after the Muslims attacked the Prijedor police station and killed 19 policemen. The local authorities in Prijedor also acted on their own initiative. I asked the civilian authorities of Omarska and Keraterm to close them down and to improve the prisoners’ living conditions in the meantime. After that I visited the Manja ča prisoner-of-war camp in order to see for myself the living conditions and the implementation of the Geneva Conventions in the Manja ča LZR. I spoke to the officers and held speeches in the halls where the prisoners of war were. I told them that I had been sent by the RS Assembly, which had promised that all those who had not commited a crime would be summarily released and the others would be tried by law . I asked for an outpatient clinic to be set up and for the conditions, which I found to be good, to be improved further. After my speech, I received loud applause from the prisoners.

44. I sent a request for the release of prisoners of war to Radovan KARADŽI Ć. I first sent a request that 20 or 30 Muslims be released from Manja ča. They were released from Manja ča not long afterwards.

45. I have been shown document 65 ter 11512 – A record of the release of a person called Nedim BIŠ ČEVI Ć from the Manja ča LZR, whom I took over. This man’s relatives begged me to go to Manja ča and ask the Manja ča LZR authorities to release him, which I did. I took over the custody of this man and escorted him to his aunt, who lived in Banja Luka.

46. I have been shown document 65ter 02667 – Minutes of the meetings of the Kotor Varoš War Presidency. Since there was fighting in Kotor Varoš and people were being killed in the area, I suggested to the Catholic Bishop KOMARICA that we go together to Kotor Varoš to calm down the situation and put an end to the fighting. In agreement with the Commander of the VRS /Army of Republika Srpska/ Operations Group, PEULI Ć, and the Chief of the CSB /Security Services Centre/, ŽUPLJANIN, we addressed representatives of the other side and the population and asked them to surrender weapons, saying that the Serbian authorities would create conditions for their normal life. After several days of negotiations, the representatives of the other side accepted our proposal and surrendered the weapons, but they requested that we enable them to move out, although we had offered them conditions

140624-ET Statement of KUPRESANIN Vojo AMENDED.docx /drsc 13 IT-09-92-T Translation 83420

in which they could live under the rule of law. Catholic priests, one Islamic hodža and their civilian leaders took part in all the negotiations. However, the Serbian population exerted pressure on us because we were letting people go who had committed crimes against the Serbian people, but our position was that the war would end and people would answer for the crimes. I fulfilled my promise and escorted the column of people who were leaving as far as Paklarevo, where they crossed the line of disengagement in accordance with their wish.

47. The presidents of the municipalities were in a very strong position and, as President of the ARK, I could not dismiss any of the municipal presidents, which is why my authority was very limited with respect to the local leaders in municipalities. The republican leadership had the same problem, as can be seen from the speech of Professor KOLJEVI Ć in document 65ter 1D02462 , where on page 35 he refers to the municipalities as states within states.

48. When the municipalities of the Bosnian Krajina started falling one after another the under the onslaught of the Croatian and Muslim forces, which were supported by NATO aircraft and logistics, we deputies from Krajina were caught by surprise and concerned for the fate of our people. We convened an extraordinary sitting of the Assembly with a view to compelling Dr KARADŽI Ć to explain to us what was going on. Dr KARADŽI Ć was in another building across the road (in the Cultural Centre) at the time. At one point during the sitting, Arkan barged in. He was armed and cursed and criticised us for holding a meeting while the Serbian people were being killed and municipalities were falling one after another. We asked him what he was doing in Banja Luka, and he said he had come with 300 of his volunteers and explicitly demanded that we to force the republican authorities to allow him to defend the falling municipalities, seeing that the VRS had not managed to defend these areas. I do not know what happened after that, but I do know that Arkan’s units successfully protected civilians against Muslim attacks in the areas of Prijedor and Bosanski Novi.

GENERAL MLADI Ć

49. Interestingly, I also played a part in selecting General Ratko MLADI Ć for the post of Chief of Staff of the VRS. On the instructions of Radovan KARADŽI Ć, I asked General VUKOVI Ć whom he would propose as commander of the army. He told me that two officers were potential commanders, but he would always choose General Ratko MLADI Ć. I passed on his opinion to Radovan KARADŽI Ć.

140624-ET Statement of KUPRESANIN Vojo AMENDED.docx /drsc 14 IT-09-92-T Translation 83419

WITNESS ACKNOWLEDGEMENT

I have read this statement consisting of 16 pages and it contains everything I said to the best of my knowledge and recollection. I have given this statement voluntarily and am aware that it may be used in legal proceedings before the International Tribunal for the Prosecution of Persons Responsible for Serious Violations of International Law Committed in the Territory of the Former Yugoslavia since 1991 and that I may be called to testify publicly before the Tribunal.

Signature:

Date:

140624-ET Statement of KUPRESANIN Vojo AMENDED.docx /drsc 15 IT-09-92-T 83418 IT-09-92-T 83417 IT-09-92-T 83416 IT-09-92-T 83415 IT-09-92-T 83414 IT-09-92-T 83413 IT-09-92-T 83412 IT-09-92-T 83411 IT-09-92-T 83410 IT-09-92-T 83409 IT-09-92-T 83408 IT-09-92-T 83407 IT-09-92-T 83406 IT-09-92-T 83405 IT-09-92-T 83404 IT-09-92-T 83403

THE INTERNATIONAL CRIMINAL TRIBUNAL FOR THE FORMER YUGOSLAVIA

Case No. IT-09-92-T

THE PROSECUTOR

v.

RATKO MLADIĆ

PUBLIC

ANNEX B ______

IT‐09‐92‐T 28 October 2014 12 IT-09-92-T 83402

KUPREŠANIN Vojo GRM145 Witness Statement to be admited pursuant Rule 92ter Statement Date 65ter Number Closed Session/Under seal Witness Statement of KUPREŠANIN Vojo 18 June 2014 RM 65ter 1D01621 - Associated Exhibits wich the Defence seeks to tender pursuant to Rule 92ter Description Paragraph 65ter Number Doc ID (BCS/ENG) Number/page in Statement Constituting Session of the Assembly of the Community of the Municipalities of the Bosnian 3/3 RM 65ter 16256 0219-2659 Krajina: A Step towards (Karadži ć EXH D04019) 0219-2659-ET Autonomy?, Glas, 27/28 April 1991, p. 6. Collection of decisions relating to the election of officials to the 4/3 RM 65ter 07197 0040-3791 Community of Municipalities, (Karadži ć 65ter 18630) 0300-1751 Bosanska Krajina. Transcript of AV00-4354 5/3 RM 65ter 1D02036 1D08-2463 (Karadži ć EXH D01890) 1D08-2503 One copy of 194 documents from the Autonomous Region of Krajina, including documents on 6/3 RM 65ter 16868 0040-3580 the establishment of the Region, (Karadži ć EXH D04020) 0040-3580-ET its member-municipalities, financial activities etc. Number 14 Session of the Assembly of the Municipality of Banja Luka: Agreement on the Formation of a Bosnian Krajina Community of 7/4 RM 65ter 16255 0219-2658 Municipalities Adopted, (Karadži ć EXH D04018) 0219-2658-ET Agreement Without a Partner, Glas, 30 April/1-2 May 1991, p. 5. Excerpt from the Minutes of the 2nd session of the ZOBK 8/4 RM 65ter 16110 0040-3806 Assembly held on 14 May 1991, (Karadži ć EXH D04016) 0190-1017 Item 2. One copy of 194 documents from the Autonomous Region of Krajina, including documents on 9/5 RM 65ter 17222 0040-3821 the establishment of the Region, (Karadži ć EXH D04022) 0300-5142 its member-municipalities, financial activities etc. Number 60 Intercepted telephone conversation between Radovan KARADZIC 10/5 RM 65ter 1D02433 1D11-0209 and VUKIC, Dr. (Includes Audio (Karadži ć EXH D00271) 1D11-0217 of Intercept) Intercepted conversation between Radovan KARADZIC, Jovan RM 65ter 20099 0681-5215 TINTOR and Momcilo 11/5 (Karadži ć 65ter 30661) 0681-5215-ET KRAJISNIK (Includes Audio of Intercept) Agreement on Co-operation 12/5 RM EXH P04174 0216-2239 (Karadži ć EXH P00747) L006-2895 Intercepted telephone conversation between KUPRESANIN, Vojo 13/6 RM 65ter 20153 0322-6272 and KARADZICRadovan (Karadži ć EXH P01084) 0322-6272 IT-09-92-T 83401

Intercept of Telephone Conversation between Radovan RM 65ter 21323 0304-0910 KARADZIC and 14/6 (Karadži ć 65ter 31700) 0306-9238 STEVANDICNenad (Includes Audio of Intercept) Announcement - of the ZOBK 15/6 RM 65ter 16121 0040-3852 Presidency, 6 September 1991. (Karadži ć 65ter 31700) Intercepted telephone conversation between KUPRESANIN, Vojo 15/6 RM EXH P02645 0681-5260 and Radovan KARADZIC 17/7 RM 65ter 20255 0681-5260-ET (Includes Audio of Intercept) (Karadži ć EXH P04024) Statute of the Autonomous Region 16/7 RM 65ter 06875 0040-3585 of Krajina, Articles 1 through 42 (Karadži ć EXH P04014) 0092-6804 Decision on Proclamation of Autonomous District of Krajina as Inseparable Part of Federal State 17/7 RM EXH P06485 0034-9516 of Federative Yugoslavia and (Karadži ć EXH D01288) 0034-9516-ET Integral Part of Federal Unit BH, 16 September 1991 Intercepted telephone conversation between KUPRESANIN, Vojo 18/7 RM 65ter 20268 0322-0076 and KARADZIC Radovan (Karadži ć EXH D00278) 0322-0076-ET Inteview with Vojislav 19/8 RM 65ter 1D02283 1D08-1344 KUPRESANIN (Karadži ć EXH D04012) 1D08-1345 Intercepted telephone conversation between Radovan KARADZIC 20/8 RM 65ter 20421 0681-5354 and Gen. UZELAC (Includes (Karadži ć EXH P05824) 0681-5354-ET Audio of Intercept) ECMM Weekly Summary RM 65ter 1D02026 21/8 (Karadži ć EXH D01283) 1D08-0157 Extract from the minutes of the 9th session of the Assembly of the Autonomous Region of Krajina RM 65ter 16846 0040-3858 held at the Banja Luka Cultural 22/8 (Karadži ć EXH P05551) 0190-1021 Centre at 1600 hours on 6 November 1991 Intercepted conversation between KUPRESANIN, Vojo and 23/8 RM 65ter 20435 0323-6512 KARADZIC Radovan (Karadži ć EXH D00423) 0323-6512-ET Intercepted telephone conversation between KUPRESANIN, Vojo 24/9 RM 65ter 1D02027 1D08-0158 and KARADZIC Radovan (Karadži ć EXH D00280) 1D08-0164 ntercepted telephone conversation between KUPRESANIN, Vojo 26/9 RM 65ter 20520 0206-6127 and KARADZIC, Radovan (also (Karadži ć EXH P05784) 0308-6790 includes audio of Intercept) Agenda (03-05/01) of the 11th Session of the Assembly of the 27/9 RM 65ter 17208 0040-3872 ARK, dated 06/01/1992. (Karadži ć EXH D04021) 0047-4971 Intercepted conversation between KARADZIC, Radovan and RM 65ter 20559 0324-4792 STEVANDIC, Nenad on 11-Jan- 27/9 (Karadži ć EXH D04021) 0324-4792-ET 1992 (also includes audio of Intercept) Intercepted telephone conversation between KUPRESANIN, Vojo 28/9 RM 65ter 20604 0324-5370 and KARADZIC Radovan (Karadži ć EXH D00424) 0681-5491 Intercepted conversation between Radovan KARADZIC and 29/9 RM 65ter 20628 0681-5529 KUPRESANIN, Vojo (Includes (Karadži ć EXH P05745) 0324-5589 Audio of Intercept) Excerpt from minutes of 13th Session of Autonomous Region of 30/10 RM 65ter 07202 0040-3902 Krajina Assembly held on 24 (Karadži ć EXH D04015) 0300-5257 February 1992 Shorthand transcript of Serbian IT-09-92-T 83400

Democratic Party Bosnia and 31/10 RM EXH P03900 SA02-5559 Herzegovina Deputies Club (Karadži ć EXH P00938) 0096-8086 session, 28 February 19920 Extract from minutes of 14th session of the Autonomous 32/10 RM 65ter 06884 0040-3934 Region of Krajina Assembly. (Karadži ć EXH P05452) 0190-4580 Agenda for the 15th Session of the RM 65ter 16132 0040-3937 Autonomous Region of Krajina 33/10 (Karadži ć 65ter 17377) 0040-3937-ET Assembly, 2 March 1992. One copy of 194 documents from the Autonomous Region of Krajina, including documents on 35/10 RM 65ter 09690 0040-3941 the establishment of the Region, (Karadži ć 65ter 09201) 0190-4583 its member-municipalities, financial activities etc. One copy of 194 documents from the Autonomous Region of Krajina, including documents on the establishment of the Region, 35/10 RM 65ter 17221 0040-3951 its member-municipalities, (Karadži ć 65ter 18629) 0047-5014 financial activities etc. Number 139 Decision on the Organization of Social Funds in the AR Krajina, 4 36/10 RM 65ter 16132 0040-3945 March 1992. (Karadži ć 65ter 18652) 0047-5012 Intercepted conversation between T000-5823 KUKANJAC, Milutin and 34/10 RM EXH P02720 0322-0076 KUPRESANIN, Vojo. (also (Karadžić EXH P00987) 0322-0076-ET includes audio of Intercept) Agenda for the 16th Session of the Autonomous Region of Krajina 35/11 RM 65ter 16135 0040-3982 Assembly, 10 April 1992. (Karadži ć 65ter 17381) 0300-9998 Autonomous Region of Krajina Assembly Decision on the Formation of a Special Purpose 36/11 RM EXH P03863 0040-3999 Police Detachment (with a (Karadži ć EXH P05454) 0190-4639 Statement of Reasons attached) Information No. 420-1 from the command of Banja Luka Corps Command to the Autonomous 38/11 RM 65ter 03016 0102-9855 Region Krajina Assembly on the (Karadži ć EXH P03440) 0102-9855-ET situation in the Kljuc SO Inter-Municipality Agreement:held with representatives from Srpska 39/12 RM 65ter 1D02867 1D11-3037 Krupa, Bosanski Novi, Bosanski (Karadži ć 65ter 06710) 1D11-3041 Petrovac, Bosanski Dubica, Prijedor and Sanski Most. Conclusions no. KS-39/92 of the RM EXH P03787 0043-1771 Sanski Most Crisis Staff 40/12 (Karadži ć EXH P02732) 0043-1771-ET 1st Krajina Corps request to the Autonomous Region of Krajina RM 65ter 16598 0124-1972 Assembly and Government for 41/12 (Karadži ć 65ter 17980) 0300-8680 material and financial assistance for conscripts Letter from members of OG Doboj to KUPRESANIN 42/12 RM 65ter 1D02284 1D08-1349 (Karadži ć 65ter 1D09272) 1D08-1350 Record of release from the 45/13 RM 65ter 11512 0132-9897 Manjaca Prisoner of War Camp (Karadži ć 65ter 1D09273) 0132-9897-ET Extract from the Minutes of 94th Session of the War Presidency of 46/13 RM 65ter 02667 0041-5689 Kotor Varos Municipality held on (Karadži ć EXH D01320) 0089-0555 10 October 1992 RS, Government - Stenographic 47/14 RM 65ter 1D02462 1D11-0812 notes of the 64th session (Karadži ć EXH D03568) 1D11-0830 IT-09-92-T 83399