IT-95-5/18-T 79125 D79125 - D78929 03 October 2013 AJ UNITED NATIONS

International Tribunal for the Case No. IT-95-5/18-T Prosecution of Persons Responsible for Serious Violations of Date: 3 October 2013

International Humanitarian Law Committed in the Territory of former Yugoslavia since 1991

IN TRIAL CHAMBER III

Before: Judge O-Gon Kwon, Presiding Judge Howard Morrison Judge Melville Baird Judge Flavia Lattanzi, Reserve Judge

Registrar: Mr John Hocking

THE PROSECUTOR

v.

RADOVAN KARAD@I]

PUBLIC WITH PARTLY CONFIDENTIAL APPENDICES

REVISED PROSECUTION’S BAR TABLE MOTION FOR THE ADMISSION OF DOCUMENTS RELATED TO THE MUNICIPALITY COMPONENT WITH PUBLIC APPENDICES A AND B AND CONFIDENTIAL APPENDIX C

The Office of the Prosecutor:

Mr Alan Tieger Ms Hildegard Uertz-Retzlaff

The Accused: Standby Counsel:

Mr Radovan Karad`i} Mr Richard Harvey

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THE INTERNATIONAL CRIMINAL TRIBUNAL FOR THE FORMER YUGOSLAVIA

Case No. IT-95-5/18-T

THE PROSECUTOR

v.

RADOVAN KARAD@I]

PUBLIC WITH PARTLY CONFIDENTIAL APPENDICES1

REVISED PROSECUTION’S BAR TABLE MOTION FOR THE ADMISSION OF DOCUMENTS RELATED TO THE MUNICIPALITY COMPONENT WITH PUBLIC APPENDICES A AND B2 AND CONFIDENTIAL APPENDIX C

I. INTRODUCTION

1. The Prosecution respectfully requests the Trial Chamber to admit, pursuant to Rule 89 (C) of the Rules of Procedure and Evidence (“Rules”), 247 items listed in Appendix A and confidential Appendix C (together “the Appendices”), which relate primarily to the Municipality component.

2. The proposed evidence consists primarily of official records from different sources, including the Serbian Democratic Party (“SDS”); the authorities of the Republika Srpska (“RS”); agencies of the United Nations; and authorities of the SFRY and the FRY. It also includes interviews of the Accused and other persons published in RS media controlled by the Bosnian Serb authorities, published in FRY publications, and in media sources in third countries. In addition, it includes video clips of interviews of the Accused or other alleged JCE members or tools.

3. In respect of each item, the Prosecution has explained in the Appendices its relevance to the Prosecution’s case and probative value, and, where it has been admitted in a previous case at the Tribunal, its previous exhibit number.3 The Prosecution has provided the Accused with an opportunity to comment on each

1 Appendix C is filed on a confidential basis because it contains references to protected witnesses. 2 Videos: 65ter#s 40136A; 40382; 40403A; 45019; 45054; 45099A; 45099B; 45238A; 45366; 45367 are attached in Appendix B. 3 Prosecutor v. Karad`i}, Case No. IT-95-5/18-T, Order on Procedure for Conduct of Trial, Appendix A, Part VII, para. R, 8 October 2009. Unless otherwise noted, all citations below are to Case No. IT-95- 5/18-T. Case No. IT-95-5/18-T - 1 - 3 October 2013

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item. The Defence response is contained in the column entitled “Opposing Party’s Response”.

4. As the Chamber has noted: “evidence does not need to be introduced through a witness in every circumstance, and there may be instances where it is appropriately admitted from the bar table.”4 The Chamber has previously indicated that documents could be admitted from “the bar table at a later stage of the proceedings should the Prosecution not be able to otherwise introduce them through a witness in the course of the trial.”5

5. As explained in greater detail in the Appendices, those items relate to various issues relevant to this case, including inter alia to the Accused’s command and control over the RS authorities; notice to him of crimes by the VRS and MUP; and the presence of paramilitaries in the municipalities.

II. OBJECTIONS BY THE DEFENCE

6. The Defence has not contested the authenticity of any item listed in the Appendices. It has objected to the admission of items, on various grounds, and the Prosecution sets forth below its position in respect of those objections.

7. In addition, the Prosecution agrees not to tender, at this stage, 19 items to which the Defence objected: 65ter#s 00293; 00721; 01142; 01501; 01550; 01661; 05436; 05520; 06506; 07818; 10826; 11919; 12050; 18899; 22802-22804, 23114 and 23484. The Prosecution has not listed those items in the attached version of the Appendices. The Prosecution has also not listed in attached Appendix A two additional items, 65ter#s 00596 and 23504.

A. ADMISSION OF ITEMS THAT WERE NOT SHOWN TO WITNESSES

8. The Accused objects to the admission of the following items on Appendix A on the basis that they should have been shown to witnesses, 65ter#s: 01110; 01582; 05364; 05367; 05372; 05374; 05377; 02559; 05545; 05557; 05558; 05570; 05588; 05645; 05669; 05670; 05777; 11229, 17808; 17868; 18374; 18528; 21603; 18946; 21839; and 22938.

9. The Trial Chamber has previously rejected this argument: there is no general rule against admitting documents from the bar table which could have been shown to

4 Decision on the Prosecution’s First Bar Table Motion, 13 April 2010 (“Decision on First Bar Table Motion”), para.9. 5 Decision on the Prosecution’s First Bar Table Motion, para.11, 13 April 2010. Case No. IT-95-5/18-T - 2 - 3 October 2013

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witnesses. The fact that the Accused did not have the opportunity to cross- examine a witness on a specific document does not prevent it from being admitted from the bar table if the requirements of Rule 89(C) and (D) are met.6 The relevant and probative value of the documents as described in the Appendices is not outweighed by the need to ensure a fair trial.

1. Admission of a document that refers to serious allegations, or a controversial issue, that were not presented through testimony

10. The Accused objects to 65ter number 00891 on the basis that it deals with a controversial issue and thus should have been presented though testimony. The “controversial issue” for the Defence is the receipt, distribution and implementation of the Variant A/B Instructions. This document, which relates to the Bosanski Petrovac municipality, was discussed by witness Dorothea Hanson in her expert report on Crisis Staffs, Exhibit P02589 at fn. 29. Further, Ms Hanson specifically mentioned Bosanski Petrovac when she testified about the nature of receipt and distribution of Variant A/B Instruction (see. T.14502:22– 14512:24, in particular T.14505).

2. Admission of documents that contain serious allegations that were not presented through testimony

11. The Accused objects to items, 65ter#s 00283 and 00851, on the basis that the items contain serious allegations which should have been put to a witness. The issues contained in these items, however, were in fact discussed with witnesses.

(a) 65ter# 00283: This is relevant to crimes against non-Serbs in these areas by Bosnian Serb forces and to the widespread knowledge of Bosnian Serb crimes at Kori{anske Stijene (Scheduled Incident B.15.6), and in Prijedor, Sanski Most, Doboj, Klju~, Tesli} and other areas, and to the involvement of the RS MUP, in particular, in those crimes. These issues were discussed with witnesses Kreji} (T.20856:19-20857:6) and Komljenovi} (P03768, page 15).

(b) 65ter# 00851: The Klju~ document is relevant to the persecutory campaign against non-Serbs and to the facilitation of the expulsion of non-Serbs via

6 Decision on Prosecution’s Motion for Admission of Evidence from the Bar Table (Hostages), 01 May 2012 (“Hostages Decision”), para.11. See also Prosecution’s Bar Table Motion for the Admission of Documents Related to the Hostages Component, 18 April 2012, para.8-9 and Prosecution’s Second Bar Table Motions for the Admission of Intercepts with Public Appendix A and Confidential Appendix B, on 20 April 2012, para.9-11. Case No. IT-95-5/18-T - 3 - 3 October 2013

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“resettlement” agencies. These issues were discussed with witnesses. See Asim Egrli} (see T.19924:23-19925:25). The Banja Luka Resettlement Agency and resettlement generally was discussed with expert witness Hanson (see P02589, para. 100 and T.14640-14643 and T.14871:17-14885, and Exhibits P02720 to P02730 and P02731-P02734).

3. Admission of a document which relates to events in an uncharged municipality and deals with acts and conduct of the Accused and was not presented through testimony

12. The Accused also objects to one item, 65ter# 01014, on the basis that the document relates to Trnovo in March 1992. This issue is dealt with in Section D. below, and additional information has been included in italics in the relevance and probative value column in Appendix A.

B. ADMISSION OF INTERVIEWS / NEWS REPORTS FROM THE BAR TABLE

13. The Accused objects to the admission of 18 items (eight documents and ten videos) on the basis that “news media reports are not admissible from the bar table.”7 The Trial Chamber has noted previously that “written media reports would not meet the reliability and probative value requirements without a witness to testify to the accuracy of the information contained therein”.8 However, for the reasons set out below, the proposed exhibits may be admitted as reliable and probative.

14. There is no blanket rule at this Tribunal precluding the admission of written media reports. To the contrary, as a general matter hearsay evidence is admissible, and Trial Chambers admit and rely upon written media reports as a matter of course.9

15. The Appeals Chamber has made clear that the admission of a document into evidence requires only some prima facie indicia of reliability.10 This prima facie assessment cannot be based solely on whether or not the document was tendered

7 65 ter#s 00699; 01126; 01218A; 05793; 11863; 12073; 13310; 15073; 40136A; 40382; 40403A; 45019; 45054; 45099A; 45099B; 45238A; 45366; 45367. 8 Decision on First Bar Table Motion, para.12. 9 See, e.g., Prosecutor v. Br|anin, IT-99-36-A, Appeals Judgment, 3 April 2007, paras.220-224 (upholding the Trial Chamber’s reliance upon a newspaper article – together with other evidence – to make certain findings); Prosecutor v. Kraji{nik, IT-00-39-A, Appeals Judgment, 17 March 2009, para.462 (also upholding the Trial Chamber’s reliance upon a newspaper article – together with other evidence – to make a certain finding). 10 See, e.g., Prosecutor v. Prli} et al., IT-04-74-AR73.16, Decision on Jadranko Prli}’s Interlocutory Appeal against the Decision on Prli} Defence Motion for Reconsideration of the Decision on Admission of Documentary Evidence, 3 November 2009, para.27. Case No. IT-95-5/18-T - 4 - 3 October 2013

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through a witness, as this is just one of many factors that may impact upon the reliability of such a document. Other factors include: the nature of the publication, the format of the document, the nature of the document’s relevance to the party’s case, and the extent to which the document is corroborated by other evidence.11 Particularly in light of the final factor – corroboration – once the prima facie threshold is established, the final determination of the reliability, probative value, and ultimate weight to be accorded to a particular document can only be assessed in light of the totality of the evidence, including other evidence which either supports – or undermines – the reliability of that document.12

16. In addition, the Trial Chamber’s consideration of these media reports should take into account the particular relevance of the Accused’s use of the media in this case. Seven of the eight written media reports tendered by the Prosecution consist of or contain statements by the Accused. The allegations against the Accused include his dissemination of propaganda intended to engender in Bosnian Serbs fear and hatred of Bosnian Muslims and Bosnian Croats or to otherwise win support for and participation in achieving the objectives of three of the alleged joint criminal enterprises in this case.13 As such, the relevance of these seven media reports lies not only in their contents, but also in the Accused’s decision to disseminate these statements through the media.

17. Similarly, the volume of such media reports, and the Accused’s use of various press and television media outlets – are relevant to the Trial Chamber’s consideration of these allegations against the Accused. Furthermore, by admitting a range of media statements by the Accused the Trial Chamber will have available a pool of similar evidentiary material, which will assist in its assessment of the weight to be attributed to each such item.

1. Video Media Reports

18. Ten of the 18 media items to which the Accused objects are video recordings.14 The Trial Chamber’s prior comments in relation to the admission of “written media reports” from the bar table do not apply to video recordings. The Accused has not explained why these items should be excluded on the basis that they

11 Ibid. It is implicit in the Appeals Chamber’s reasoning that the existence of corroborating evidence is relevant to a Trial Chamber’s assessment of the reliability and probative value of media reports. 12 See, e.g., Prosecutor v. Kraji{nik, IT-00-39-A, Appeals Judgment, 17 March 2009, para.685 (The weight given to each piece of evidence is assessed in light of the totality of the evidence). 13 Prosecution’s Third Amended Indictment, 27 February 2009, paras.14(c), 19, 24. 14 65 ter numbers 40136A; 40382; 40403A; 45019; 45054; 45099A; 45099B; 45238A; 45366; and 45367. Case No. IT-95-5/18-T - 5 - 3 October 2013

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constitute media reports. Their reliability is self-evident. There is no question that these videos reflect the words of the speakers, the images provide additional context to those words, and the relevance of each of these videos to this case is set out in Appendix A. These contemporaneous audio and video records of the Accused and other members of the Bosnian Serb leadership are a particularly valuable evidentiary source.

2. Written Media Reports

19. The eight written media reports to which the Accused objects all contain prima facie indicators of reliability that favour their admission.

20. Two of the items – 65ter#01218A and 65ter#13310 – stem from publications controlled by the Bosnian Serb leadership, Glas Srpski, and Srpska Vojska.15 In that sense, they are akin to official RS military or government documents, which are routinely admitted in this case – including from the bar table – and accepted as reliable. Moreover, because they stem from media outlets designed to publicly disseminate messages from the Bosnian Serb leadership, these items are particularly relevant to the propaganda allegations against the Accused.

21. Five of the items16 consist of questions put to the Accused and his answers to them. This question-and-answer format contains minimal journalistic intervention and places the Accused’s statements in the context of the question to which they relate, thereby heightening their reliability.

22. Moreover, the contents of these media reports are largely corroborated by similar statements by the Accused recorded in other formats such as Assembly session transcripts, videos, or intercepts, the reliability of which are not in question.

23. For example, 65ter#05793 – a 16 March 1992 Borba interview – records the Accused stating that “I am convinced that the Serbs will never makes peace until

15 See P05025, an order signed by the Accused, regarding unified editorial policy of media in closest cooperation with the RS government. It was addressed to, among others, the editors-in-chief of Srna, Javnost, Glas srpski, Oslobo|enje and Srpska Vojska. As noted in Appendix A (item 01218A), Srpska Vojska was published by the VRS Main Staff Centre for Information. See also two RS Assembly decisions: 65ter#21598 (tendered in this motion), requiring inter alia that the content, policy and distribution of Glas Sprski be in accordance with the law of public information and the needs of the RS and the RSK; and 65ter#21606 (tendered in this motion), in which the RS Assembly appoints the directors and editors-in-chief of the newspapers Oslobo|enje and Glas Srpski. See also 65ter#11276 (tendered in this motion), Transcript of the 9 January 1994 Ceremonial Session of the RS Assembly recording the bestowing of the “Njego{ recognition of the First Rank” – pursuant to a decree passed by the Accused – upon a number of media outlets including Glas Srpski (pp.16-18). 16 65ter#00699; 65ter#01126; 65ter#05793; 65ter#12073 and 65ter#15073. Case No. IT-95-5/18-T - 6 - 3 October 2013

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they achieve their age-old aspiration to live in one state;”17 predicting that a civil war would result in “…hundreds of thousands of dead and hundreds of towns destroyed;”18 and declaring that Serbs and Muslims “cannot live together but only alongside one another.”19 Similarly, in 65ter#15073 – a 24 July 1992 Budapest Nepszabadsag interview – the Accused characterized the war as “a religious and ethnic war”;20 stated that the “the Serbs are endangered because the Croat-Muslim coalition started a genocide on us;”21 and denied that the Serb side was committing crimes.22

24. More generally, these media statements by the Accused contain one or more of the Accused’s regular refrains such as the need to defend the Serbs from genocide23 or that the Bosnian Serbs cannot live together with Muslims and Croats.24

17 Compare with, e.g., 65ter#45305 (a video tendered in the Prosecution’s 3 May 2012 Sarajevo Bar Table Motion) in which the Accused stated (e-Court page 7): “The goal, ultimate goal of the Serbs is to become one state”. 18 Compare with, e.g., 65ter#30565, 22-Jan-1992 intercepted telephone conversation between Radovan KARAD@I] and Dobrica ]OSI] (tendered in the Prosecution’s 20 April 2012 Intercept Bar Table Motion) in which KARAD@I] stated, “I can sketch out what will happen. The Serbs will flee from the Muslim areas, the Muslims will flee from the Serbian areas, you'll have completely homogenous entities and you'll have the same thing you have now, but you'll also have enormous casualties and many destroyed towns and so on…." (e-Court page 6); 65ter#30423, 14-Nov-1991 intercepted telephone conversation between Bo`idar VU^UREVI] and Radovan KARAD@I] (tendered in the Prosecution’s 20 April 2012 Intercept Bar Table Motion) in which KARAD@I] forecasts that if there is a war, "it will not last long and that it will be terrible and that it really will, first of all Sarajevo and several of these Bosnian cities will be destroyed, so to speak. I think that all of that would be destroyed in three to five days." 19 Compare with, e.g., 65ter#45019 (a video tendered in this motion) in which KARAD@I] insists on ethnic separation stating we are like oil and water and pointing to a map of Bosnia containing colour markings of the ethnic groups; P1394, transcript of the 42nd RS Assembly Session, in which the Accused stated (e-court p.76) “We know for sure that we have to give something up, that is clear beyond a shadow of a doubt, if we wish to achieve our primary strategic aim, which is to get rid of the enemies in our house, the Croats and Muslims, and not to be in the same state with them anymore”; P00956 Transcript of the 16th RS Assembly Session at which the Accused stated, “separation from those who are our enemies and who have used every opportunity, especially in this century, to attack us, and who would continue with such practices if we were to stay together in the same state.” (e-Court page 9). 20 Compare with, e.g., 65ter#32175, Intercept of a 3 March 1992 conversation between Radovan KARAD@I]; Goran MILI] and Alija IZETBEGOVI] (tendered in the Prosecution’s 20 April 2012 Intercept Bar Table Motion) in which KARAD@I] stated that the country is on the threshold of an inter-religious and inter-ethnic war (e-Court page 7). 21 Compare with, e.g., 65ter#11276, Transcript of the 9 January 1994 Ceremonial Session of the RS Assembly (tendered in this motion) in which KARAD@I] referred to the Bosnian Muslims as a “toxic, all-destructive Islamic octopus” stated that “₣tğhe wars of 1914, 1941, and 1991, were and remain above all, wars for the extermination of the Orthodox population” and that “₣pğreparations for the new genocide were not a secret. Almost all Bosnia and Herzegovina newspapers, especially the new ones, with Islamic editorship, are full of proof that the plan for the destruction of Serbs is made and that it will be executed.” 22 Compare with, e.g., P3695, BBC Video footage depicting statement of Radovan KARAD@I] saying “We don't have people in the prisons that have been removed from their own homes. Those people have been captured in the battlefield and they can go home if they are weak and they are not likely to be mobilized from Muslim forces very soon.” 23 See, e.g., Okun, T.1490 (and Okun Diary for 5 March 1992, P779, p.43): “I noted a meeting with Dr. Karadzic, and at the beginning I wrote something to the effect -- it's in the journals, something to the Case No. IT-95-5/18-T - 7 - 3 October 2013

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25. Such examples of other evidence corroborating these media items are further indications of their prima facie reliability. However, as noted above, a final assessment of their reliability and the weight they ought to be accorded can only be made at the end of the case in light of the totality of the evidence.

C. ADMISSION OF ITEMS WHERE THE ACCUSED PURPORTEDLY DOES NOT HAVE THE SAME ACCESS TO DOCUMENTATION AS THE OTP

1. Admission of municipality Crisis Staff documents where the Prosecution declines to provide R66(B) disclosure for these kind of records

26. The Defence objects to five items, 65ter#s 07789, 10841, 11315, 14925 and 14934 (which relate to the Rajlovac, Fo~a and Vlasenica municipalities) on the basis that the “OTP declines to provide R66(B) disclosure for these kinds of records.” This objection appears to be related to a motion25 to compel the Prosecution to search for and disclose a relatively small quantity (particularly when balanced against the resources required) of Crisis Staff-related material related to his preparation for his defence case, to which the Prosecution has responded.26 27. This objection no merit. All of these exhibits in question were listed on the Prosecution’s list of exhibits, filed on 18 May 2009, pursuant to Rule 65 ter, which requires the filing of “the list of exhibits the Prosecution intends to offer”, and disclosed to the Accused on 25 May 2009. The Accused has therefore been on notice that these items fall within exhibits the Prosecution wishes to tender during the prosecution case. As explained in Appendix A, they are relevant and of probative value.

effect that unusually Dr. Karadzic didn't mention Bosnian -- the genocide of the Serbs for three minutes into a conversation, because it was such a constant refrain with him.” 24 See, e.g., Okun, T.4205 of P00776: explaining that the position of the Bosnian Serb throughout the whole period was that the people had to be separated, that they could not live together. Even though the populations were “thoroughly intermixed”, the Bosnian Serb leadership position was that “they had to be taken apart; Okun, T.4220 of P00776: describing how all the Bosnian Serb leaders – Karad`i}, Kraji{nik, Koljevi}, Buha, Luki} – were consistent in their position that physical separation was needed and communities could not live together. 25 “Motion to Compel Inspection of Items Material to the Municipalities Defence Case”, 10 April 2012. 26 “Prosecution Response To Motion To Compel Inspection Of Items Material To The Municipalities Defence Case”, 24 April 2012. Case No. IT-95-5/18-T - 8 - 3 October 2013

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28. In respect of access to Crisis Staff documents generally, the Accused has failed to point out that he already has access to a large quantity of Crisis Staff-related material through (a) material already disclosed to him by the Prosecution; and (b) material available on the Electronic Disclosure Suite. 29. For these reasons, there is no merit in the assertion that the Prosecution should be prevented from tendering Crisis Staff-related exhibits which have been disclosed to the Defence and which were expressly identified on 18 May 2009 as exhibits which the Prosecution intends to offer during its case.

2. Admission of public ICRC press releases

30. The Accused objects to two items, 65ter#s 07414 and 05670,27 on the basis that ICRC material is inaccessible to the defence and therefore the Prosecution should not be allowed to use such material. The two items, however, are public press releases which are accessible to the Accused. Non-public ICRC material, on the other hand, is not accessible to either the Prosecution or Defence. There is no merit in the argument that public ICRC press releases are inadmissible on the basis that the parties do not have access to ICRC material generally.

D. ADMISSION OF ITEMS WHICH RELATE TO MUNICIPALITIES NOT CHARGED IN THE INDICTMENT

1. Admission of items that relate to municipalities or regions not charged in the indictment

31. The Accused objects to 9 items on the basis that the items relate to “uncharged” municipalities.28

32. The Prosecution is permitted to present evidence concerning those crime sites, incidents and events in dropped (or uncharged municipalities) where the evidence is relevant to prove general elements of the crimes charged, including: the objective and methods of the alleged JCEs; the degree of co-ordination and co- operation of individuals and institutions that are allegedly part of the JCEs; the

27 The Accused also objects on the basis that this document should have been put to witness KDZ163. See para. 9 supra, for the Prosecution’s response in relation to that objection. 28 The following documents relate to dropped municipalities: 65ter numbers 00332 (Donja Vakuf); 00351 (Kotor Varo{); 01080 (Bosanski Petrovac); and 06692 (Bosanska Krupa). The following documents relate to uncharged municipalities, 65ter numbers: 01865 (Biha~), and 22916 and 22918 (Trebinje). There is also an objection to a Serbian Autonomous Region (SAO) document, 65ter number 22919 (from SAO Herzegovina), which relates to the documents relating to Trebinje. Case No. IT-95-5/18-T - 9 - 3 October 2013

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widespread or systemic nature of the alleged crimes and pattern; and the Accused’s role, intent, knowledge or notice.29 These items are relevant to these factors, as can be seen in the relevance and probative column of each of the exhibits in Appendix A.

E. ADMISSION OF ITEMS OBJECTED TO ON THE BASIS OF RELEVANCE AND/OR PROBATIVE, OR CUMULATIVE EVIDENCE

1. Objection concerning cumulative items has been rejected

33. The Accused objects to the admission of 6 items, 65ter#s 00814; 00830; 01336; 01500; 06481; and 11169, on the basis that each item is cumulative. The Trial Chamber has previously rejected this objection, noting that its Rule 89(C) assessment does not take into account the fact that other admitted exhibits may speak to the same or similar issues as the material before it.30

2. The relevance of certain items has been expressed more fully in the Appendices

34. The Accused objects to 28 items listed in the Appendices on the basis that they are irrelevant to the crimes charged in the Indictment.31 The Accused objects to 28 items listed in the Appendices on the basis that they are irrelevant and/or cumulative.32

35. The objection regarding the cumulative nature of these items has been previously rejected, as noted above.

29 See Prosecution Submission Pursuant To Rule 73bis (D), Filed 31 August 2009, para.12, citing: Rule93 (“Evidence of a consistent pattern of conduct relevant to serious violations of international humanitarian law under the Statutes may be admissible in the interests of justice.”); Gali} Appeal Judgement, 30 Nov. 2006, para.219 (“[E]vidence regarding additional … incidents could be introduced at trial pursuant to Rule 93 of the Rules in order to prove a consistent pattern of conduct relevant to the charges in the Indictment, including a campaign.”); [e{elj, IT-03-67-AR73.7, Decision on Appeal Against the Trial Chamber’s Oral Decision of 9January2008, 11 March 2008, para.24 (affirming Trial Chamber’s ruling that evidence of crime sites removed under Rule 73bis(D) can go towards proving the purpose and methods of the JCE, the degree of coordination and cooperation of individuals and institutions allegedly part of the JCE, communication, training and transfer of volunteers and the involvement in such of the accused, knowledge of the accused of the conduct of the volunteers and the general elements of the prosecution campaign); See also Milutinovi} et al, IT-05-87-T, Decision on Application of Rule 73bis, 11July2006, para.13b. 30 Decision on Prosecution’s Motion for the Admission of 68 Sarajevo Romanija Corps Documents from the Bar Table, 16 June 2011, para. 11. 31.65 ter#: 05070B; 05084; 05298; 05432; 05435; 05589; 07092; 09236; 09433; 09465; 10826; 10830; 10938; 10942; 13154; 14633; 15273; 17820; 20421; 21598; 21601; 21606; 21637; 21676; 21690; 22871; 22874; and 23484. 32 65 ter#s: 00611; 01661; 01901; 04033; 05262; 07982; 09073; 10712; 10831; 13417; 13351; 13438; 17257; 18434; 11364; 13555; 03847; 16207; 04070; 16558; 21538; 22825; 22826; 22830; 11220; 21990; 22805, 22809. Case No. IT-95-5/18-T - 10 - 3 October 2013

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36. As for relevance, the Prosecution has, where necessary, amplified the explanation of the relevance of each item more clearly in the Appendices. The information which was not in the version of the draft appendix sent to the Defence for its comments has been italicized in the Appendices, in the column headed “Relevance to the Prosecution’s Case and Probative Value”.

3. Other objections have been addressed with additional information in the Appendices

37. The Accused objects to one item, 65ter# 10937A, on the basis that the document is vague.

38. The Accused also objects to one document, 65ter#09195, on the basis that it is not relevant to any crimes charged for 1995.

39. The Accused objects to one document, 65ter#00582, on the basis that it is not relevant to crimes against civilian population.

40. The Accused objects to one document, 65ter#00435, on the basis that the document is irrelevant because it refers to combat against combatants.

41. The Accused objects to two items, 65ter#s00258 and 004427, on the basis that the Prosecution has not shown how this fits into its case.

42. The Accused objects to one item, 65ter#11511, on the basis that second hand reports are unreliable, violate the spirit of Rule 92 bis, and should not be admitted from the bar table without cross-examination.

43. In respect of each of these items, the Prosecution has amplified its explanation of its relevance, addressing, where necessary the specific objection raised. Those explanations are contained in italics in the column headed “Relevance to the Prosecution’s Case and Probative Value”.

III. CONCLUSION

44. For the reasons provided above, the Prosecution respectfully requests the Trial Chamber to admit pursuant to Rule 89 (C):

(i) all items listed in Appendix A as public exhibits;

(ii) 65ter#02559 listed in confidential Appendix C as a confidential exhibit as it relates to a protected witness; and

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(iii) the other items listed in Appendix C as public exhibits.

Word Count:33 4,668

______Alan Tieger Senior Trial Attorney

Dated this 3rd day of October 2013 At The Hague The Netherlands

33 The Trial Chamber authorized the Prosecution to exceed the word limit for this filing: T.28566. Case No. IT-95-5/18-T - 12 - 3 October 2013

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APPENDIX A to REVISED PROSECUTION’S BAR TABLE MOTION FOR THE ADMISSION OF DOCUMENTS RELATED TO THE MUNICIPALITY COMPONENT WITH PUBLIC APPENDICES A AND B AND CONFIDENTIAL APPENDIX C

IT-95-5/18-T 1 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013

65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case 65ter# 06-Jul-1992 Regular Combat Report This is relevant, inter alia, to the IT-99-36: No objection 00252 No. 44/1-220 of the 1KK nature of the military and police P1431 (1st Krajina Corps) operations in the Brdo area later in Command to the VRS July, which rounded up thousands Main Staff. of Muslim civilians and to defence allegations that these actions were The report notes that defensive in nature. More preparations are underway generally, it is relevant to show that for further mopping up of 1KK operations in the Prijedor area Kotor Varo{ and were not triggered by defensive Maslovare. Taking part imperatives and were instead are the 122 lpbr /Light aimed at the forcible removal of Infantry Brigade/, the non-Serbs from that area. ^elinac Light Brigade and Banja Luka MUP. It also notes that combat operations in the 1KK zone of responsibility are on the whole proceeding well and according to plan. Specifically, the 1KK asserts that in the broader Prijedor area there are "about 100 rebels, broken up into smaller groups of five to 10 people, hiding in basements, woods and underground shelters. 79111 IT-95-5/18-T 2 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case They are most often detected either attempting to pull out or searching for food." 65ter# 14-Jun-1992 14 June 1992 Regular This document is relevant to co- IT-99-36: Objection—no 00258 Combat Report from the operation and co-ordination P1421 showing how this 1KK Command to the between the VRS, the RS MUP and fits into OTP case VRS Main Staff. volunteers.

The document states that In pursuing the strategic goals, the the Prijedor VRS worked closely with the MUP, OTG/Operations and as well as local paramilitary Tactical Group/, including formations, many of which were the 2nd mtbr and the 343rd eventually integrated into the VRS mtbr, the 6/10pd, command structure. The VRS also volunteers and the police, received volunteers from outside secures the Bosanski Novi BiH into their units. The MUP was – Prijedor – Banja Luka, a key component of the Bosnian Prijedor – Sanski Most – Serb military forces. During Sanica and Sanski Most – combat operations, MUP units Bosanska Krupa routes were subordinate to the command and deals with the of the armed forces. Paramilitary remaining enemy troops and volunteer units were in the areas of Kozarac operationally subordinated to the village, Prijedor and police, TO and army units. (PTB, Sanksi Most. paras. 117, 119 and 133). 65ter# 26-Feb-1993 26 February 1993 Official This is relevant to crimes against IT-08-91: Objection— 00283 note by Security Services non-Serbs in these areas by P01381.01 serious allegations Centre (CSB), Banja Bosnian Serb forces and to the (RED) contained in this Luka National Security widespread knowledge of Bosnian document should 79110 IT-95-5/18-T 3 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case Service re: discussion of Serb crimes at Kori{anske Stijene have been put to a who is to blame for (Scheduled Incident B.15.6), and in witness crimes committed in Prijedor, Sanski Most, Doboj, Prijedor; Klju~; Kotor Klju~, Tesli} and other areas, and Varo{; Sanski Most; and to the involvement of the RS MUP, other areas. The document in particular, in those crimes. notes that “the Chief of the Prijedor SJB [Public Security Station] allegedly organized the murder of a large number of Muslim citizens at Korican{ke Stijene” and that the victims were robbed under his direction, before the convoy set off. It also refers to him as responsible for robbing and killing other Muslim and Croats in Prijedor. It refers to the documentation of “Serbian crimes” in various localities by the ICRC and other international organizations, “which is placing the Serbian people in an even more 79109 IT-95-5/18-T 4 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case difficult position in international terms”. The report also notes that that with regard to accusations of crimes against non- Serbs DRLJA^A is basing his defence more and more frequently on the fact that he had done everything with the full consent and approval of the Chief of the Banja Luka CSB. 65ter# 18-Oct-1991 Telegram from Radovan This document is relevant to (a) IT-99-36: Objection—not 00332 KARAD@I] to the SDS KARAD@I]'s powers and P1709 one of Municipal Board of Donji authority as SDS President; (b) the (different municipalities Vakuf, imposing a state of hierarchy of the SDS; (c) the ERNs); charged in emergency for SDS acceleration of preparations for a indictment organs, members and response to increasing concerns IT-00-39: cadres in bodies of over the declaration of an P64.A; P529 government. independent BiH. HANSON TAB 8 In this document, KARAD@I] imposes a state of emergency and states, “You will receive instructions about the state of emergency measures daily, and the first measures will be 79108 IT-95-5/18-T 5 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case daily sessions of the municipal boards, and having staff on duty in the party round the clock.” 65ter# 18-Oct-1992 Excerpts from the This document is relevant to show IT-00-39: Objection—not 00351 Minutes of the 101st the central control of the Bosnian P760; one of meeting of the War Serb leadership of municipal-level municipalities Presidency of Kotor events, and in particular, the IT-99-36: charged in Varo{ municipality held control by the Bosnian Serb P2286 indictment on 18 October 1992. leadership of the execution of the objective to achieve ethnic These minutes record as separation by forcibly removing follows: “For the action non-Serbs from targeted of surrendering weapons municipalities. and the moving of people from the territory of Kotor Varo{, the president of Crisis Staff pointed out that the drive and all activities had been conducted on the orders of the Government and the Presidency of Republika Srpska.” “They are asking 300 DM as a tax for moving out.” 65ter# 13-Jul-1992 Combat Report No. 44- This document is relevant to show IT-99-36: Objection— 00435 1/232, from 1KK to VRS the involvement of 1KK units in P1434 irrelevant, refers to Main Staff. the killing of non-Serbs in the combat against Autonmous Region of Krajina combatants 79107 IT-95-5/18-T 6 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case The 1KK Corps (ARK). Command informs the VRS main staff that there It is the Prosecution’s position that are still groups of the heading “Combat Report” does extremists in Prijedor not render the activities reported area, "which we destroy either legal or “combat.” This when we find them." report, which records and reports VRS efforts to “destroy” remaining “extremists,” is relevant to the VRS involvement in the cleansing of Prijedor’s Muslim and Croat communities, as alleged inter alia in para. 148 of the Prosecution’s Pretrial Brief. The document is further relevant to the regularity of reporting up the chain of command of the VRS. 65ter# 01-Jun-1992 1KK Command daily This document is relevant to show IT-99-36: No objection 00547 combat report No. 44- VRS involvement in the takeover P654 1/157 to VRS Main Staff. of power and the detention and killing of non-Serb civilians in the The report notes, with municipalities of Prijedor, Sanski regard to Prijedor, which Most and Klju~. was largely “under our control”, that they have many prisoners (about 7000) including many Muslim leaders. It also notes that the “mopping up” of Green Berets is 79106 IT-95-5/18-T 7 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case underway in Muslim villages in the area of Klju~. It also says that Sanski Most is under VRS control.

65ter# 16-Jun-1992 Vlasenica Serb This document, reflecting the IT-00-39: No objection 00561 Municipality (no 67/92) implementation of the Presidency P534 and appointing its War Decision on the Formation of War P64A Tab 750 Commission, by Dragan Commissioners, and forming a War DOKANOVIC (Republic Commission in Vlasenica, is Commissioner) and relevant to the municipal-level Milenko STANI] implementation of decisions by the (President of the Presidency. Vlasenica Municipal Assembly) 65ter# 07-Jun-1992 Eastern Bosnia Corps This document is relevant to the IT-00-39: Objection—not 00582 (IBK) Command order implementation of operations to P881 and relevant to crimes no. 11/2-529, defining the achieve Strategic Objective 2 and P1066 against civilian tasks of the IBK for Strategic Objective 3 and is also population operations beginning on 8 relevant to the role of the IBK in June 1992. to be the forcible transfer of non-Serbs executed by Zvornik from Eastern Bosnia. It also Brigade, Birac Brigade, relevant to joint operations and others, making between the IBK and the 1KK. repeated references to cistiti (cleansing) This item is relevant to operations in locations in implementation of operations to northern and eastern achieve Strategic Objective 2 and 3 Bosnia. In particular, the and is also relevant to the role of 79105 IT-95-5/18-T 8 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case Zvornik Brigade and the IBK in the forcible transfer of Birac Brigade are non-Serbs from Eastern Bosnia. specifically ordered to The order contains references to continue ciscenje “~istiti” (cleansing operations) in (cleansing) operations in the Drina River Valley. The order the Drina River Valley. prohibits the maltreatment of the The order also indicates civilian population but anticipates that it will be distributed the arrest of civilians. to all subordinate units. 65ter# 05-Dec-1992 Order of Radovan This document is is relevant to the IT-00-39: No objection 00596 KARAD@I] to VRS operations in late 1992 and early P1067 Main Staff to provide a 1993 to remove non-Serbs from brigade as reinforcement Cerska and Konjevi} Polje., is to the Drinski Corps in relevant to the implementation of defending the Boksit Directive 4 (P00976), and relevant aluminum ore mine in to show KARAD@I]'s direct Mili}, instructing the involvement in issuing tactical VRS Main Staff to orders in furtherance of its “Disarm the enemy in the implementation. municipalities of Cerska and Konjevi} Polje, take control of the road communications Mili}i- Drinjaca-Zvornik and Konjevi} Polje- Bratunac”. 65ter# 09-Sep-1991 Decision of the Executive This document, reflecting the IT-00-39: P36 Objection— 00611 Board of the SDS, signed republic-level personnel irrelevant and by Rajko \UKIC commission, is relevant to the SDS cumulative to concerning the hierarchical structure and in testimony of Djeric 79104 IT-95-5/18-T 9 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case assignment of the particular the centralization of Commission for personnel issues. Personnel and Organisational Issues. This is relevant especially to the coordination and cooperation This names, as members between SDS municipal and of the Personnel and central leaders, as shown for Organisational Issues example by the appointment of Commission, KARADŽIĆ, KRAJIŠNIK, as well KARAD@I], as DERONJIĆ to the commission. KRAJIŠNIK, OSTOIJI] as well as municipal-level leaders such as Miroslav DERONJIC. 65ter# 13-Sep-1992 Coded Telegram with This is relevant to KARAD@I]’s IT-00-39: No objection 00649 information about awareness of developments P889 H possibilities of regarding the moving out of negotiations with Muslim women and children and to Muslims in the region of involvement and responsibility in Birac. the operations to remove non-Serbs from targeted areas in 1992. See This states that, in co- also 65ter#00650 below. operation with the authorities of Zvornik Serb Municipality and Republican War Commissioner Jovo Mijatovi}, an appeal was sent to the Muslims in the Birac region to evacuate 79103 IT-95-5/18-T 10 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case children and unarmed people, and that KARAD@I] agreed with this.

65ter# 10-Sep-1992 Coded Telegram with This is relevant to the involvement IT-00-39: No objection 00650 information about of the Serb municipal authorities in P889.G resolving an issue of the Zvornik, the RS MUP SJB in collection Centre in Zvornik and VRS forces co- Divic, which refers to operating to remove the non-Serb Muslim civilians being population from northeastern held at a collection centre Bosnia. It should be considered in in Divic and to members conjunction with 65ter#00649 of Zvornik Serb above. Municipality and the SJB asking “to be authorized the possibility of transferring these people to” Kelesija and Kladanj “through the light infantry brigade”. 65ter# 13-Oct-1992 Order no. 701-2/92 of the This reflects subordination of Beli IT-00-39: No objection 00659 Military Post Code 7469 Orlovi (“White Eagles”) (after their P889.I for the Beli Orlovi White criminal activities in earlier 1992) Eagles paramilitary into the VRS. formation to be transferred from Zvornik Infantry Brigade to the Birac Brigade 79102 IT-95-5/18-T 11 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case 65ter# 31-Aug-1994 Interview of Radovan This is relevant to showing the Objection—news 00699 KARAD@I] broadcast on strategic objective of separation reports are not Deutsche Welle radio from the Muslims and Croats; admissible from station and later published KARAD@I]’s intent to ensure that the bar table in Der Spiegel. He states the Muslims “disappear”; and that he would not allow KARAD@I]’s willingness to take “the Muslims neither to UN peacekeepers as hostages. connect their enclaves nor will we relinquish towns” We could only cede poorly inhabited areas in order to move their population”. Asked about the consequences of an UNPROFOR withdrawal from BiH, KARAD@I] responded that “In that case, the Muslims would vanish and we would, together with the Croats, divide Bosnia”. He later says that the Serbs would give the Muslims some autonomy in the Tuzla region.” He also threatens to take “Blue Helmets” as hostages. 65ter# 06-Nov-1992 Regular Combat Report This is relevant to the participation IT-99-36: Objection— 00721 no. 44-1/463, 1KK of the 1KK, under the direction of P2305 serious allegation Command to Srpska the Main Staff, in the killings of should have been 79101 IT-95-5/18-T 12 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case Republika Army Main non-Serbs in the ARK region. put to a witness Staff. It states that the 1KK units are still looking for 20-30 extremists from Ve~i}i to "liquidate" them. 65ter# 26-May-1992 1KK Command Report The document is relevant to the IT-99-36: No objection 00797 No. 459-3 on the political control established by the Serb P379 and and security situation in forces in the ARK and to the P2152 Bosnian Krajina. The persecutory campaign against non- report is signed by the Serbs. Assistant Commander for Moral Guidance and Legal Affairs, Colonel, Milutin Vukelic.

The report mentions that the Serb forces have blocked the "Green Berets" and are controlling the areas of Klju~ and Sanski Most, that about 300 members of the opposing party have been captured in the village of Kozarac, and that the area of Banja Luka and the town of Prijedor are fully under 79100 IT-95-5/18-T 13 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case the control of the Serb forces. The report also stresses that the ARK assembly has taken 'all possible measures' to remove Muslim and Croats – who did not fulfill 'their patriotic duty' by not responding to the mobilization – from important posts. 65ter# 28-May-1992 1 Infantry Brigade The document is relevant to shows IT-99-36: No objection 00805 Command Combat Report that the attack on Klju~ was P924 No. I-121/92, to the 30 coordinated and organized in Infantry Division advance. It is also relevant to the Command. The document role of the VRS in disarming non- is stamped and signed. Serbs and in taking over power in Klju~ and to VRS participation in This regular combat expulsion of non-Serbs from the report notes that if the municipality. Muslim population of Klju~ does not surrender their weapons by 27 May 1992, Klju~ will be mopped up. 65ter# 01-Jun-1992 Combat Report No. 44- This document is relevant to show IT-99-36: Objection-- 00814 1/156 of the 1KK the involvement of the 1KK, under P655 and cumulative Command to the VRS the orders of the VRS Main Staff, P1588; Main Staff. in the takeover of power and the IT-00-39: forcible removal of the non-Serb P734; 79099 IT-95-5/18-T 14 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case The document states that population from the ARK area. IT-02-54: the areas of Prijedor, P463.22 and Sanski Most and Klju~ P463.60.1 are under control and reflects the capture of 7,000 prisoners, which is mentioned in 65ter#00547, a 1KK report of the same date, described above. 65ter# 25-Jun-1992 Order No. 01-93/92 of the This document is relevant to show IT-00-39: No objection 00828 Command of the 17th the co-ordination between the VRS P759; Light Infantry Brigade for and the RS MUP in the processing IT-99-36: Further Operations. The of detainees (p.2). P977 order is signed by Commander Lt-Colonel Drago Samardija and stamped.

This order provides for a joint VRS-MUP checkpoint and for sending detainees to the SJB Building in Klju~ for further investigation. 65ter# 27 Jun-1992 27 June 1992 SJB Klju~ This document is relevant to the IT-99-36: Objection-- 00830 List of persons detained detention of non-Serbs and to the P980 cumulative during the mopping up of coordination between forces and the terrain of the Klju~ municipalities in connection with municipality. the camp network. he persons 79098 IT-95-5/18-T 15 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case listed on these two lists are listed in Exhibit P03726 (list of persons detained in Manja~a in November 1992). 65ter# - Summary of the meetings This document is relevant to the IT-99-36: Objection— 00851 of the War Presidency (22 persecutory campaign against non- P1002 serious allegation July 1992) and the second Serbs and to the facilitation of the should have been meeting of the War expulsion of non-Serbs via introduced through Presidency (23 July “resettlement” agencies. a witnessN 1992), which reflect the municipal body dismissing Muslims from municipal positions, including the Executive Board President and the Vice-President of the Municipal Assembly. It also notes that a Committee for Resettlement and Exchange of Homes was established, to cooperate with the similar agency in Banja Luka. 65ter# 31-Jul-1992 Minutes of the 13th These minutes are relevant to show IT-99-36: No objection 00861 Session of the Klju~ the coordination of local Serb P958 Municipal Assembly held authorities and forces in the on 31 July 1992, during persecutory campaign against non- which Vinko Kondic, Serbs. chief of the SJB in Klju~, 79097 IT-95-5/18-T 16 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case reported that only Serbs worked in companies and enterprises and which also reflects several decisions taken to “relieve” certain judges of their duties. Additionally, it also reflects that Drago SAMARDZIJA, commander of the 17th Light Infantry Battalion, presented a report on the activities of his battalion.

65ter# 26-Dec-1991 Minutes of meeting of This document is relevant to show IT-00-39: Objection— 00981 Bosanski Petrovac SDS the dissemination and P90.H; controversial issue, Secretariat, No. 1/91 implementation of Variant A/B. should have been reflecting IT-99-36: presented through acknowledgement of P1819 testimony receipt of Variant A/B Instructions and states that the document needed to be typed in seven copies and every member of the Secretariat to be provided with a copy. 65ter# 21-Nov-1991 Decision on the This is relevant to the territorial No objection 00993 Territories of delineation of areas for inclusion in Municipalities, Local the future Serb state in BiH and to Communes and Populated the scope of Bosnian Serb 79096 IT-95-5/18-T 17 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case Places in Bosnia and territorial claims, including Herzegovina which are territories from which large Considered to be the numbers of non-Serbs were Territory of the Federal expelled, and is also relevant to State of Yugoslavia, KARAD@I]’s role as a principal signed by Momcilo policy-maker regarding the future KRAJISNIK. of the Serbs in Bosnia.

This decision outlines the territories which are to be considered part of Yugoslavia, on the basis of the 9-10 November 1991 Serb plebiscite. The first article defines as territory of the Federal State of Yugoslavia, all those municipalities, local communes and inhabited places where over 50% of the Serb voters voted in favour of remaining in the common state, as well as those places where non- Serbs came out in favour of remaining in Yugoslavia. It also nominates members of the Bosnian Serb leadership, with KARAD@I] listed 79095 IT-95-5/18-T 18 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case as number one, as the authorized representatives of the Serb people to negotiate on the future of the Serbs in BiH. 65ter# 24-Mar-1992 Minutes of the SDS This is relevant to show Objection— 01014 Trnovo Municipal Board KARAD@I]’s involvement in uncharged Session held on 24 March municipal level affairs, compliance municipality— 1992. These minutes at the municipal-level with his deals with alleged record that orders, the arming of the Serb acts and conduct of “R.KARAD@I] ordered” population, the persecutory accused and should a heightened state of campaign against non-Serbs, have been alert, organize duty preparations for the Serb takeover presented through services, guards to control of power at the municipal level and testimony Serbian territory, and to to ethnic separation. take the current situation seriously”. It goes on to There is no rule prohibiting the say: “Those who received admission from the bar table of weapons must use them to evidence relating to the acts and defend the Serbian conduct of the Accused. people. Quasi-Serbs should be prevented from This document bears the date 24 representing Serbs in the March 1992, and is thus the same municipality.” Vukadin day as the 24 March 1992 RS KRSTANOVI] refers to Assembly session (P00961), at the need to distribute which the Accused said: “I ask weapons. The minutes you now that following some also note: “Muslims are instructions for national defence, not to work Serbian Land information systems, etc. that will - Land not to be sold” be given here, the real and 79094 IT-95-5/18-T 19 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case sovereign authority of the Serbian Assembly and Serbian people be established on the ground as soon as possible. As soon as we are informed that we have our own separate RSMUP, which will probably follow the coming session, all the newly-established municipalities should immediately set up police stations and all policemen should be withdrawn.” 65ter# 17-Apr-1992 Decision of the SDS of This is relevant to the Accused’s IT-00-39: No objection 01028 Bosnia-Herzegovina, No: leadership role in setting up P64.A 01-1/92, dated 17 April parallel Serb-only institutions, and 1992, signed by Radovan to the preparations for the Serb KARAD@I], President. takeover of power in targeted areas of Sarajevo. It states that all employees of Serbian ethnicity in the bodies and organisations of the former Republic of Bosnia-Herzegovina and the City of Sarajevo. Employees mentioned above shall be appointed to work places in the Serbian Republic of Bosnia-Herzegovina, effective immediately. 79093 IT-95-5/18-T 20 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case 65ter# 20-Apr-1992 Letter from the SDS BiH This is relevant to the No objection 01030 Office of the President to dissemination of information from the Municipal Board in KARAD@I] to municipal level Prijedor informing the authorities; to the takeover of Board that it has been power at the municipal-level; to designated an information KARAD@I]’s access to centre. It instructs the communications networks, centre to “report regularly independent of the communications on all significant events networks of the VRS and RS MUP in” an area including to which he also had access; and to Bosanski Novi and Sanski the implementation at the Most. It also asks that a municipal level of decisions from person be designated to the leadership. disseminate “decisions, conclusions , instructions and other printed material which we shall be sending you by fax, and to convey their contents to all organs of authority and to the population in your area of responsibility”. 65ter# 09-May-1992 Decision by the Crisis The decision demonstrates the No objection 01047 Staff Banja Luka, signed hierarchy of municipal and by Radoslav BR\ANIN, regional Crisis Staffs. providing that decisions by the Crisis Staff must be followed by all municipalities of the ARK, and an appeal will 79092 IT-95-5/18-T 21 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case not prohibit the implementation of the decision. 65ter# 12-May-1992 Decision on the This is relevant to KARAD@I]’s No objection 01050 Promulgation of the Act role as Supreme Commander of the on Amending and VRS, to his authority over the Supplementing the army, to his duty to prevent and Constitutional Act for punish crimes, and to his failure to Implementing the do so. (This is also relevant to Constitution of the counter KARAD@I]’s assertion, Serbian Republic of BiH, contradicted by the witness, that he Banja Luka, signed by was only supreme commander in Mom~ilo KRAJI[NIK. wartime: T.26023.) These amendments provide that the VRS is commanded both in peacetime and in war by the President of the Republic, who also appoints, promotes and discharges officers of that army, and appoints and discharges presidents, judges and lay judges of military courts, as well as military prosecutors. 65ter# 04-Jun-1992 Minutes of the 25th This document indicates personal IT-99-36: Objection— 01080 session of the Crisis Staff contacts between KARAD@I] and P1870; uncharged of Bosanski Petrovac the President of a Municipal Crisis IT-00-39: municipality municipality no. KS- Staff, as of 3 June 1992. It is P90.U 79091 IT-95-5/18-T 22 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case 35/92 therefore relevant to his oversight of events at the municipal level. 65ter# 15-Jul-1992 Message no: 01-023-224 This message should be read and IT-00-39-T: Objection—should 01110 from President of the assessed in connection with the P843 and be put to witness Sokolac Crisis Staff telegram from KARAD@I] to P843.1 Tupajic Milan Tupaji} to Radovan which it is responding KARAD@I] dated 15 (65ter#05377, below), also July 1992 responding to tendered via the bar table. the telegram dated 14 July Together, these documents are 1992. In it, Tupaji} states relevant to KARAD@I]’s efforts to that the SJB is responsible shift the apparent responsibility for to the Ministry of Interior protecting the Muslim population and the Brigade to Municipal organs, rather than Command is responsible taking steps to ensure their to its superior command. protection through his authority Activities on security over the military and police. The issues are conducted by documents also demonstrate the SJB and the 2nd effective communication between Romanija Brigade municipal and republic-level “without my knowledge organs. and knowledge of my closest collaborators.” Note: this document was tendered The message concludes in connection with the by stating that protection Prosecution’s confidential motion of the Muslim population dated 16 April 2012, which has to be taken by the SJB remains pending. It is tendered via and the 2nd Romanija this bar table motion in the Brigade, and that, “In alternative, in the event the conditions as they are Chamber declines to admit it in now, I cannot take connection with that earlier motion. 79090 IT-95-5/18-T 23 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case responsibility for their safety.” 65ter# 28-Jul-1992 Letter from the Serbian This document is relevant to show No objection 01112 municipality of Vogo{}a the involvement and cooperation of to the War Commission paramilitary forces in establishing of Vogosca on 28 July Serb control over Sarajevo’s 1992 regarding the peripheral municipalities. remuneration of volunteers led by Jovo This document is linked with OSTOJI] for the month P2377 dated 30 July 1992, of July, signed by Rajko Stamped and signed conclusion, no KOPRIVICA, President 03-132/92 by the Vogo{}a Serb of the Executive Board of municipality War Commission the Serbian municipality regarding payment to the soldiers of Vogo{}a of the [o{o unit, under major Jovo Ostoji}’s command, for the defence of the Serbian municipality of Vogo{}a.

Jovo Ostoji} is further described in 65ter#10765, 65ter#01414 and 65ter#45105 (referred to in the Sarajevo Siege Bar Table Motion).

65ter# 11-Aug-1992 Interview with Radovan This is relevant to the IT-00-39: Objection—news 01126 KARAD@I] by Der KARAD@I]’s knowledge of P583 – media reports not Spiegel on 10 Aug 92. conditions at Omarska camp, and TRBOJEVI] admissible from Among the questions: Der to his command and control over TAB 61 the bar table Spiegel: “Were you the network of detention facilities 79089 IT-95-5/18-T 24 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case surprised when you saw in which non-Serbs were held in the pictures of the brutal conditions. It is also relevant concentration camp in to his engagement in efforts to Omarska?” Radovan mislead the international KARAD@I]: “Frankly, community in relation to crimes yes. I did not know that committed against non-Serbs, conditions were so bad thereby facilitating the commission there. But they are normal of further crimes. prisons.” Der Spiegel: “The prisoners are starved to their bones.” Radovan KARAD@I]: “There is no food left in Bosnia; Serbia has not sent anything since the sanctions were imposed...We have about 8,000 prisoners of war in 13 prisons... We have one single camp that is bad; all the others are okay.” 65ter# 26-Nov-1992 Cable from VANCE to This document is relevant to No objection 01172 NAMBIAR regarding KARAD@I]’s awareness of crimes reports of ethnic cleansing being committed by Bosnian Serb in the Banja Luka region forces, to his failure to prevent and and the possibility of a punish those responsible for those VRS attack on Biha}, and crimes, and to his failure to take a letter to Radovan adequate steps to ensure that KARAD@I] protesting authorities under his control would both points. The letter protect Muslims and Croats. 79088 IT-95-5/18-T 25 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case dated 26 November 1992 signed by VANCE and OWEN states they have “received credible reports about renewed ethnic cleansing being conducted by Bosnian Serb authorities in and around Banja Luka. Muslims and Croats are reportedly being expelled from their homes. In addition, there are reports that young Muslim men are being forcibly sent to join your forces... We appeal to you in the strongest terms to issue orders immediately to your military and civilian authorities to cease and desist from any continuation of these activities. Any individuals involved in these practices will be held strictly accountable for their conduct and can be prosecuted for their breaches of humanitarian 79087 IT-95-5/18-T 26 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case law.” 65ter# 21-Apr-93 Speeches by MLADI] This document is relevant to Objection—news 01218 and KARAD@I] relating command and control, to the use by media reports are A to the military campaign the Bosnian Serb leadership of not admissible of 1992, reproduced in "genocide of the Serbs" as a pretext from the bar table Vojska, the magazine of for military action, to the military the VRS, issued under the implementation of the strategic control of the VRS Main objectives, to coordination with Staff (The complete issue and support by the FRY, to is at 01218. At page 3 in Bosnian Serb military superiority BCS, there is information that enabled takeover and noting that Vojska is expulsions. published by the Centre for Information of the Main Staff of the Army of Republika Srpska).

MLADI] discusses the VRS campaign of 1992 and the reasons for that campaign, acknowledging that the conflict had "claimed many lives, in particular in the cities and villages with a majority Muslim or Croat population,"that the JNA units which formed the VRS were "made up of members of the Serbian 79086 IT-95-5/18-T 27 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case people from the territory of the former BiH, that the six strategic objectives were military goals, FRY/Serbian support to the Bosnian Serbs, and to the "utmost unity of command and control" during VRS operations in 1992, which were carried out by the VRS and the MUP in a manner "characterised by a high level of synchronisation and expertise in the planning and execution of combat activities".

In his speech (page 4 of the English version), KARAD@I] uses the genocide-against-Serbs argument as a justification for the use of force; he also refers to "the honour of creating the Serbian state".

65ter# 08-May-1994 Code cable from Yasushi This is relevant to the strategic No objection 01277 AKASHI, UNPROFOR, objective to divide Sarajevo; to 79085 IT-95-5/18-T 28 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case Zagreb to Kofi ANNAN, KARAD@I]’s command and UNHQ regarding DE control over Bosnian Serb forces, MELLO’s meetings with in particular the VRS. KARAD@I], Izetbegovi} and Silad`i}. (De Mello was Akashi’s representative).

KARAD@I] “referred several times to the importance of the Supreme Command gathering on 8 May 1994, and that the main objective, he said, was to ensure complete loyalty of the armed forces, their unrestricted obedience and their timely execution of orders (“I want to avoid bureaucracy and unnecessary delays in future.”)” The document states, at paragraph 23: “It may also be interesting to note that during this discussion, Karadžić indicated on the map present thinking on what 79084 IT-95-5/18-T 29 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case Sarajevo should look like in the future: The present inner city would remain Muslim, which would be linked by a wide corridor to Central Bosnia (including possibly Ilija{ and the western part of Vogo{}a), with the Serbs creating their Sarajevo from Ilid`a to Lukavica, including the airport, which would be urbanized, and Butmir (new airports could be built in Visoko and Sokolac). Two cities, side by side, communicating and cooperating, he said.”

65ter# 20-Sep-1994 Code cable from Yasushi This document is relevant to No objection 01295 AKASHI, UNPROFOR, continued crimes and to Zagreb to Kofi ANNAN, KARAD@I]’s continuing notice of UNHQ entitled Letter to crimes. Dr. KARAD@I]. In this, KARAD@I] is told by AKASKI: “I wish to convey to you my utter dismay at the fact that, in 79083 IT-95-5/18-T 30 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case the past few days alone, over 2,500 Muslim civilians have been forcefully expelled from the area of Bijeljina and Janja... You assured me again on 20 August that such forceful expulsions of non-Serb population are not in accordance with the policies of the Bosnian Serb authorities. In our telephone conversation on 6 September, you informed me that you had taken measures to identify, arrest and prosecute those responsible for such inhumane and criminal expulsions of non-Serb civilians. You also gave the same assurance to Mr. DE MELLO on 8 September in Pale, when you recognized that such practices reflected adversely on the Serb image and interest. He indicated to you that 79082 IT-95-5/18-T 31 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case unless immediate corrective action was taken, there would soon be nobody left to forcibly uproot. I fail to understand how such a deplorable situation can continue and even accelerate, despite all the commitments you have repeatedly made to me to stop the forceful expulsions and to improve conditions for non-Serb populations. Furthermore, you should be aware that those responsible for such continuing criminal acts will, of course, be subject to investigation and prosecution by the ICTY.” 65ter# 23-Sep-1994 Security Council This document is relevant to IT-02-54: No objection 01298 Resolution 941. On the continued crimes and to P547.27 23 September 1994, by KARAD@I]’s continuing notice of resolution 941 (1994), the crimes. Council reaffirmed that all parties to the conflict are bound to comply with 79081 IT-95-5/18-T 32 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case their obligations under international humanitarian law and in particular the Geneva Conventions of 12 August 1949; strongly condemned all violations of international humanitarian law, including in particular the unacceptable practice of ethnic cleansing perpetrated in Banja Luka, Bijeljina and other areas of the Republic of Bosnia and Herzegovina under the control of Bosnian Serb forces; and reaffirmed that those who have committed or have ordered the commission of such acts will be held individually responsible in respect of such acts; and demanded that the Bosnian Serb authorities immediately cease their campaign of ethnic cleansing. 65ter# 03-Jun-1992 SRBiH, MUP, Romanija- This document is relevant as No objection 01445 Birac CSB, Sarajevo daily evidence of the involvement of 79080 IT-95-5/18-T 33 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case report no. 101 including organised Serb forces in the attack details concerning events and subsequent crimes related to in the Sarajevo area. the takeover and cleansing of the Muslim settlement of Ahatovi}i in Among other things, this Novi grad municipality, Sarajevo. report confirms the Serb It relates to Scheduled Incident B military takeover of 12.1 and B12.2 as well as Ahatovi}i, that there were Scheduled Detention Facility many “enemy” C17.1. This document is casualties,” some 50 non- corroborated by the evidence of Serbs were captured and KDZ041 and Ramiz Mujki} as well “being interrogated” in as their Amalgamated Statements the Rajlovac barracks and at P2310 and P2314. that Muslim women and children were being “temporarily sheltered” in the Gavrilo Princip primary school. 65ter# 21-Feb-1992 Proclamation by the Main The document is relevant to the IT-00-39: No objection 01486 Board of the SDS, signed SDS and KARAD@I]'s views P64.A by Radovan KARAD@I] regarding the threat presented by regarding the referendum, Bosnian independence and reminding the Serbian response to that asserted threat people, inter alia, of their through “all available means” and historical struggles to to the widespread dissemination of throw off the “yoke of those views to the Serbian people slavery,” that the act of of Bosnia and Herzegovina. calling a referendum is a first step toward establishing an Islamic 79079 IT-95-5/18-T 34 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case state and that the Serbs will defend with “all available means” its historical rights. 65ter# 06-Apr-1992 Report from the 2nd This document is relevant as IT-00-39: Objection-- 01500 Military District Reserve evidence of the military role of P529 cumulative Command Post to the Crisis Staffs and their contacts and HANSON Tab Operation Centre, coordination with the JNA. 263 stamped and typesigned by Branko FILIPOVI]. The context within which this Inter alia, this document document was issued is found in states: “The overall P733, Amalagamated Statement of activity of this part of the Sulejman ^rn~alo. He refers to the command has focussed establishment of the Pale Crisis primarily on monitoring Staff at para. 42. This document is the situation and the also cited in P2589 FN 110. course of combat operations around Sarajevo. In addition, we have continued to work on troop deployments and we have organised communications… We have maintained constant contact and coordination of operations with the Pale Crisis Staff. 65ter# 25-Jun-1992 Confirmation from The document shows the IT-00-39: No objection 01575 Radovan KARAD@I] Accused’s authority in relation to P64.A and 79078 IT-95-5/18-T 35 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case concerning the local War Commissions and shows P529 appointment of the the involvement of members of the HANSON Tab members of the War Bosnian Serb leadership in events 196 Commission for Pale on the local level, in this case Pale municipality, signed and municipality. stamped. The context within which this According to the document was issued is found in conclusion of the the Amalgamated Statement of Municipal Board of the Sulejman ^rn~alo, P.733, as well Serbian Democratic Party as P973 pp.24-27. Pale and a member of the Presidency of the Serbian Republic of Bosnia and Herzegovina, Dr. Biljana Plav{i}, and in accordance with article 4 of the Decision on the Establishment of War Commissions in the Municipalities in a time of war or immediate threat of war, the Presidency of the Serbian Republic of Bosnia and Herzegovina,confirms the appointment of members of the Pale War Commission, naming Biljana Plav{i} as a 79077 IT-95-5/18-T 36 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case member, referring to her as Republic Commissioner. 65ter# 27-Jun-1992 Handwritten request for This document is relevant to the IT-00-39: Objection— 01576 change of residence sent removal of non-Serbs from the Pale D203.A and cumulative— to Pale Municipal municipality and is associated with D203.A.1 should have been Assembly, stamped and the previous items 65ter#11227 introduced through signed. and 65ter#11228 and shows that Crncalo the decision taken were executed This request indicates that and non-Serbs exchanged houses. the ten signatories and their family members, 34 The context within which this in total, all Muslims, document was issued is found in have signed contracts for the Amalgamated Statement of the exchange of their Sulejman ^rn~alo, P.733, as well houses. as P973 pp.24-27. 65ter# 06-Jul-1992 Report of the Pale MUP This document is relevant to the IT-00-39: Objection— 01582 regarding the place of removal of non-Serbs from the Pale D209 and cumulative— residence of Muslim and municipality and is associated with D209.1 should have been Croat citizens. the previous items 65ter#11227 introduced through and 65ter#11228 and shows that Crncalo Pursuant to 65ter#11228 the decision taken were executed. and the “wish expressed by Muslims and Croats,” this document confirms The context within which this that on 30 June, and from document was issued is found in 1-3 July the Pale SJB the Amalgamated Statement of carried out an organised Sulejman ^rn~alo, P.733, as well change of the place of as P973 pp.24-27. residence from Pale to 79076 IT-95-5/18-T 37 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case Stari Grad of over 1000 citizens, who were bussed to Stari Grad. 65ter# 30-Sep-1992 Decision on the This document is relevant as IT-00-39: No objection 01630 appointment of Jovan evidence of the Accused’s close P1139 and TINTOR as advisor to the association with Serbian P1139.1 Presidency, No. 01- municipality leaders in the 584/92, signed by Sarajevo area, in this case Jovan Radovan KARAD@I]. Tintor.

At its meeting held on 23 August 1992, the Republika Srpska Presidency passed this decision. Article 1: Jovan Tintor is hereby appointed advisor to the Presidency of the Serbian Republic for issues to reconstruction and the accommodation and return of refugees. 65ter# 31-Aug-1992 Report strictly This document is relevant to the IT-02-54: 387 No objection 01711 confidential no. 18-168/1, distribution of weapons by the JNA Tab 5, P463.6, from 1KK to the Main to support the Bosnian Serbs. IT-99-36: Staff of the VRS P1572 concerning an inventory of weapons and equipment issued to structures outside the 79075 IT-95-5/18-T 38 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case Armed Forces since the beginning of “activities aimed at protecting Serbs from genocide in Croatia and the Serbian Republic.” Attached to this report is the survey of the weapons and equipment issued to TO staffs and units of the 5th JNA Corps. 65ter# 24-Apr-1992 A stamped request by the This document is relevant to the IT-02-54: 387 No objection 01713 2nd Military District cooperation between the JNA and Tab 7 Milutin KUKANJAC by the Bosnian Serb authorities and which he asks the Federal the arming of the Bosnian Serb Secretariat for National forces. Defence Technical Dept to provide the Special Task Police Unit of the Banja Luka CSB with the listed arms, vehicles aircrafts and equipment 65ter# 00-Feb-1993 Document of the This report is relevant to VRS IT-02-54: No objection 01797 Command of the 1KK, control over Manja~a camp, to co- P427 Tab 50; Analysis of the Activities operation between the SDS and the concerning combat VRS during 1992, and to 1KK IT-99-36: readiness in 1992, signed participation in the operations in P2514 by General Momir the ARK area which resulted in the TALI]. This provides detention of non-Serb civilians in details of the brutal conditions and the killing 79074 IT-95-5/18-T 39 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case transformation from the and forcible transfer of thousands JNA (former 5th Corps) of non-Serbs in 1992. units into VRS units, the strength, equipment and tasking of the 1KK; it refers to mobilisation efforts, responded to mostly by Serbs, to the so-called Serbian Defence Forces (SOS) as paramilitary forces that committed crimes, and to the involvement of SDS individuals and authorities in military matters. In respect of 1KK participation in detention of civilians, the report notes that the 1KK achieved "significant results" in activities related to prisoner of war exchanges. Over 9,200 "prisoners" were exchanged, "of which 2,300 were military personnel from the former BH..." which indicates that the other 7,000 were civilians. See also 65 ter 79073 IT-95-5/18-T 40 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case 00547, 65ter#00814 which are 1KK reports referring to the detention of civilians. The document also addresses the cooperation with, inter alia. the CSB Banja Luka. The document is stamped and signed by TALI]. 65ter# 02-Jul-1994 GS VRS combat order to This document is relevant to show IT-02-54: Objection—relates 01865 1KK, 2KK and SVK co-operation between VJ, VRS and P643 Tab 15 to uncharged regarding operation UNA- SVK, and reliance on logistical municipalities 94. support/supply from VJ, in relation to Biha} enclave based on Based on the agreement Directive 6. between Yugoslav Army (VJ), VRS, SVK and AP The document reflects the ZB (Autonomous continuing existence of the Province Western Bosnia) overarching JCE and shows that in (reference is made to joint military operations the VRS is Directive No. 6 issued by in command, here the 2nd Krajina the Supreme Command of Corps. the Republika Srpska on 11 November 1993 and the agreement concluded in Vojni} on 24 June 1994 between the representatives of the VJ, VRS and SVK), VRS is 79072 IT-95-5/18-T 41 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case to start offensive actions towards the Una on 10 July 1994 (Operation UNA 94). 65ter# 30-May-1992 Payroll for members of This document is relevant to show Objection-- 02555 the Territorial Defence of the presence and operation of the cumulative the Serbian Municipality White Eagles paramilitary group in of Zvornik for the month Zvornik during May 1992, and of May 1992, Zvornik their incorporation into the Territorial Defence. Although the document does not refer explicitly to the "White Eagles" the names overlap with the names listed in 65 ter 02556 (below), and both documents contain the same signature of the Commander Borisav Mihajlovi}. 65ter# 16-Jun-1992 Listing of members of the This document is relevant to show Objection-- 02556 White Eagles/Beli Orvi the membership of the White cumulative Unit, signed by Eagles, and, together with 65 ter commander Major 02555, reflects the presence of the MIHAJLOVIC Borisav White Eagles in Zvornik in May 1992 and their incorporation into the Territorial Defence. 65ter# 01-Aug-1995 VRS Main Staff situation This document, which reflects Objection— 04033 report (03/3-213), to the detailed information on the irrelevant, RS President, dated 01 situation and the activities of cumulative August 1995, typesigned forces, VRS Corps, as well as Gen Maj Radivoje UNPROFOR and NATO in all 79071 IT-95-5/18-T 42 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case MILETIC, Standing in for disputed parts of BiH (i.e. for the the Chief of Staff. zone of responsibility of each VRS Corps) is relevant to communications to the Supreme Commander (KARAD@I]) and to his situational awareness.

This is also relevant to show the Accused’s command and control, and to show that he must have been aware of crimes at Srebrenica. 65ter# 22-Aug-1992 1st Krajina Corps report The document is relevant to crimes No objection 04213 No. 397-366/1-92 to the against the non-Serb population, Prijedor Operative Group detention facilities (Scheduled Command, dated 22 Incidents C.20.2 and C.20.4.) and August 1992, contemporaneous reporting of summarizing the crimes same within the police and military committed against the structures. local population in Prijedor, including the killings in camps, and the units involved. The document further indicates that this situation is reported within the VRS chain of command. 65ter# 22-Sep-1992 2nd Romanija Motorised This document is relevant to the IT-00-39: No objection 04217 Brigade combat report involvement of the 2nd Romanija P1160 No. 980/4-92, type-signed Brigade, under the command of 79070 IT-95-5/18-T 43 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case Radislav KRSTIC, dated General Krsti}, in expelling the 22 September 1992, women, children and elderly, and reporting, inter alia, that killing the men of Novoseoci. (see the village of Novoseoci evidence of Munira was “ciscinje” (cleansed SELMANOVI] (KDZ500) or mopped up) 65ter# 23-Aug-1995 Banja Luka Srpska TV on This document is relevant to the No objection 04232 23 August 1995. military implementation of the Strategic Objectives. KARAD@I] talks about the "vital interest" represented by the Una and Sava, "that the Drina be ours, for it is ours, it had been ours for centuries," Sarajevo, part of the Neretva Valley and access to the sea. "These are the six strategic goals that our Assembly adopted already in 1992. They were revealed later on, it was no longer a secret. These are our goals and our nation is fighting to realise them, to realise such a state, and it has realised such a state." 65ter# 28-May-1995 28 May 1995 Presidential The document is relevant to show No objection 04266 Order No. 07/22-55 from KARAD@I]'s role in appointing 79069 IT-95-5/18-T 44 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case President Radovan the staff of the military court KARAD@I] appointing system. Document is certified and Col. Milenko LAZI] stamped. President Judge of Military Court 65ter# 13-Mar-2002 RS Ministry of Defence The document is relevant to Counts Objection—no 04427 correspondence attaching 3 and 7 and Scheduled Detention showing of how list of persons [Muslims] Facility C.2.2.1. this fits into OTP exchanged at the end of case 1995 from the Batkovi}i The closure of some camps was Collection Centre, dated prompted by an international 13 March 2002. outcry in early August 1992 and detainees were transferred to locations including Batkovi} camp and Kamenica. Batkovi} camp operated at least between 1 June 1992 and 31 December 1995. Non- Serbs detained in the Srebrenica area in July 1995 were taken to Batkovi} camp and from thereon exchanged between September and December 1995 (see PTB, para. 156). 65ter# 31-May-1992 31 May 1992 Combat This document is relevant to show No objection 04926 Report from the 1KK the length of the fighting in Command to the VRS Prijedor in connection with the 30 Main Staff. May 1992 incident and also relevant to contemporaneous Document states: reporting. “The mop-up of the 79068 IT-95-5/18-T 45 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case terrain and seizing of arms are being conducted in the municipalities of Prijedor, Sanski Most and Klju~.” “In operations in the Prijedor area on 30 and 31 May 1992” 8 members of the VRS and 8 members of the Prijedor SJB were killed. Regard the situation on the ground, the document states that “[t]he situation is relatively calm, but with occasional provocations, in the area of Prijedor, Sanski Most, Klju~ and Jajce.”

65ter# 23-May-1992 Crisis Staff of the Serbian This document is relevant to crimes Objection-- 05070 Municipality of Sanski against the non-Serb population, irrelevant B Most Decision, No. K- detention facilities, and 27/92. contemporaneous reporting of same within the police and military Decision states that burial structures. It is also relevant to lots for the burial of Scheduled Incident B.17.1 and persons killed in the Exhibit P04853. Victims exhumed Sanski Most municipality at that location were killed in have been allotted at the Kriva Cesta. 79067 IT-95-5/18-T 46 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case Greda Muslim cemetery and that the dead shall be This document is also relevant to buried in a common grave show the the Crisis Staff’s without regular burial knowledge of crimes and control ceremony (no family and coordination within the members etc. present). municipal authorities 65ter# 02-Jun-1992 Order to clear the war This document is relevant to the Objection-- 05084 area of Vrhpolje and scale of the crimes and specifically irrelevant Hrustovo of war damage, the number of killings (which execute the urgent finding required additional manpower and identification of from the TO to deal with) corpses and their committed against the non-Serb interment in the nearby population and is specifically cemetery. Order No. 80- related to Scheduled Incidents 13/92, signed by Milenko A.12.1 and 12.2 and the STOJINOVI], involvement of the local Commander of Sanski authorities. Most Civilian Protection Staff. It is also particularly relevant to co-ordination between the Crisis The Order issued pursuant Staff and the Serb TO. to an order of Sanski Most Crisis Staff, No. K[-28/92 and provides that “manpower to carry out these jobs will be supplied by members of the Territorial Defence Staff”s 65ter# 8-Jun-1992 Conclusions of the Crisis This document is relevant to the No objection 79066 IT-95-5/18-T 47 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case 05096 Staff of the Serbian persecutory campaign and crimes Municipality of Sanski against the non-Serb population. It Most, No. K[-31/92, is also relevant to the authority of regarding the local the Crisis Staff and its cooperation civilian defence to and coordination with the VRS. undertake a clearing up of The document also relates to the Vrhpolje-Hrustovo Scheduled Incidents A.12.1. and theatre of operations, 12.2. and Scheduled Detention together with the 6th Facility C.22.3. Brigade Command. The 6th Brigade is requested to immediately organize and carry out the mop-up of the Vrhpolje-Hrustovo area of any remaining groups or forces. Another conclusion is that the detainees at the Sports hall are to be screened, and elder persons, persons from mixed marriages, and persons in poor health and persons who have fought on the front with the JNA are to be released. 65ter# 17-Jun-1992 Conclusions of the Crisis This document is relevant to the No objection 05105 Staff of the Serb Crisis Staff’s authority and Municipality of Sanski involvement in the detention of Most, No. K[-38/92. detainees (Scheduled Detention 79065 IT-95-5/18-T 48 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case Facility C.22.3.) The document states that This document is associated with “On the issue of the 65ter#04830 and 65ter#05103 detainees in the Sports (below). Hall, a selection should be made and some of them should be let go.” Tasked: RA[ULA, VRKE[, ANI^I], Njunja, Vinko, DO[ENOVI]. 65ter# 22-08-1992 Combat Report 44-1/314 This document is relevant to No objection 05142 from the 1st Krajina command and control and notice. Corps Command to the It shows that massacres are VRS Main Staff reported up the VRS chain of The 1KK reports to the command. VRS Main Staff the Scheduled Incident B.15.6. stating that the perpetrators were members of the police of Prijedor and Sanski Most. 65ter# 23-Aug-1992 Certificate from SJB The document is relevant to show No objection 05143 Sanski Most, to the the cooperation between the police Military-Investigative and the military organs in the Organ, Manja~a. transfer of detainees. Document also confirms Scheduled Detention Certificate relates to the Facilities C. 22.1-22.5. Document Sanski Most SJB hand- is signed and stamped. over of 684 detainees 79064 IT-95-5/18-T 49 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case from Sanski Most area to the military authorities on 23 August 1992. 65ter# 28-Aug-1992 Dispatch No. 11-14/S1 of This document is relevant to show No objection 05146 Sanski Most SJB to the cooperation between the police Manja~a Camp and the military organs in the Investigation Organs transfer of detainees. The delivering a list of document is similar to 65ter#05143 persons and others, signed (listed above). In combination, by Mirko VRU^INI]. these documents show a standing practice in relation to such Dispatch relates to 49 detainees transfers. Document is individuals transferred signed and stamped from Sanski Most to Manja~a detention facility on 28 August 1992 65ter# 01-Feb-1995 Overview of data on the This is relevant to show the change IT-99-36: P58 Objection— 05193 number and ethnic in the non-Serb population between cumulative to structure of the population the 1991 census and February 1995 evidence of Dr. according to in relation to municipalities within Tabeau—should municipalities in the area the ARK. This is relevant to have been used of the Banja Luka Counts 1 and 3-8. with her Department of the State Security Centre for 1991 and 1995 65ter# 30-Sep-1995 Dispatch No. 01-1775/95 The document is relevant to show Objection— 05262 from Deputy Minister KARAD@I]’s continued authority irrelevant Tomislav KOVA^ over military and civilian organs considering date-- forwarding to the Main and continuing existence of the cumulative 79063 IT-95-5/18-T 50 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case Staff of the Army, the overarching JCE. Ministry of Interior, Ministry of Defence, all The objection regarding the date Secretariats of the has no merit. The document is Ministry of Defence and relevant to the Accused’s command all Presidents of the War and control of the VRS before, Presidencies an order during and after the Srebrenica stamped and signed by crimes, and to his failure to punish the President of the those responsible. Republic and Supreme Commander Radovan KARAD@I] concerning the mobilization of men fit for military service in the Republika Srpska 65ter# 13-Jul-1995 13 July 1995 Letter from The document is relevant to show Objection-- 05298 Tomislav KOVA^ to the degree to which KARAD@I] irrelevant Radovan KARAD@I] gets informed and makes decision - even in a minor matter such as an issue related to conscripts. It also shows that the overarching JCE is still functioning in summer 1995. Document is registered and signed.

It is also relevant to the Accused’s command and control over the VRS on 13 July 1995. 65ter# 15-May-1992 Minutes of the 15 May These minutes are relevant to the IT-00-39-T: Objection—should 05364 1992 Session of the Sokolac SDS Municipal Board’s P836 be put to witness Sokolac Crisis Staff. The authority over the Sokolac Crisis Tupajic 79062 IT-95-5/18-T 51 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case minutes state that the SDS Staff, indicating the extent to municipal board verified which the Crisis Staff was a party the mandates of the organ. It is also relevant to the members of the Crisis involvement of the Sokolac Crisis Staff, and determined the Staff in the municipal TO matters composition of the Staff, and in disarmament operations. which accordingly met in reduced composition. Note: this document was tendered The Crisis Staff also in connection with the deferred to policies of the Prosecution’s confidential motion SDS municipal board, dated 16 April 2012, which including on the issue of remains pending. It is tendered via the employment of this bar table motion in the Muslims. alternative, in the event the In addition, the Crisis Chamber declines to admit it in Staff made decisions on connection with that earlier motion. TO matters (Item 3), and one Crisis Staff member (Drago Ma¬ar) informed the others that plans for the disarmament of certain villages had been made (Item 11). 65ter# 29-May-1992 Decision on mobilisation This decision is relevant to the role IT-00-39-T: Objection—should 05367 status of members of the of Crisis Staffs in the RS state, i.e., P828 be put to witness Sokolac Crisis Staff functioning of authority, economic Tupajic stating that members of and social life in the municipality, the Crisis Staff are to be and working with the VRS and the counted as mobilized, RS Government “on all vital since “they have as their issues.” 79061 IT-95-5/18-T 52 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case duty securing the functioning of authority, the economic and social life on the level of the municipality and working with the appropriate commands of the Serbian army and the Government of the Serbian Republic of BiH on all vital issues.” 65ter# 22-Jun-1992 22 June 1992 Sokolac These minutes are relevant to crisis IT-00-39-T: Objection—should 05372 Crisis Staff meeting staff communication with, and P841 be put to witness minutes. At this meeting, reporting, to republic-level organs. Tupajic Milan Tupaji} proposed It is also relevant to the Sokolac informing the Presidency SDS Municipal Board’s authority and the Government over the Sokolac Crisis Staff, about problems with the indicating the extent to which the police in order to obtain a Crisis Staff was a party organ. resolution to the problems, and the Crisis Note: this document was tendered Staff expresses its in connection with the readiness to defer to the Prosecution’s confidential motion SDS municipal board and dated 16 April 2012, which have it name new people remains pending. It is tendered via if the Crisis Staff could this bar table motion in the not work effectively (Item alternative, in the event the 2). Chamber declines to admit it in connection with that earlier motion. 65ter# 23-Jun-1992 23 June 1992 Presidency This document is relevant to show Objection—should 05374 decision 01-137/92, the degree to which KARAD@I] is be put to witness 79060 IT-95-5/18-T 53 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case signed by Radovan involved in matters in the Tupajic KARAD@I] as President municipalities, in this case of the Presidency, Sokolac. It refutes his claim that appointing members of the local level acted rather the War Commission for independently. the municipality of Sokolac 65ter# 14-Jul-1992 Telegram signed by This telegram should be read and IT-00-39 –T: Objection—should 05377 Radovan KARAD@I] to assessed in connection with the P842 and be put to witness the President of the reply from Milan Tupaji} P842.1 Tupajic Serbian Municipality of (65ter#01110), also tendered via Sokolac, stating that the bar table. This telegram is also villages in which the related to D00095, which contains Muslim population the same message and indicates surrenders their arms and that it is to be distributed to a does not intend to fight number of municipalities in the against us must have the Gora`de area, including Sokolac. support of the Serbian Together, these documents are Republic of BiH, and relevant to KARAD@I]’s efforts to declaring that “Presidents shift apparent responsibility for of the Municipalities are protecting the Muslim population responsible for the to Municipal organs, rather than above.” taking steps to ensure their protection through his authority over the military and police. The documents also demonstrate effective communication between municipal and republic-level organs.

79059 IT-95-5/18-T 54 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case Note: this document was tendered in connection with the Prosecution’s confidential motion dated 16 April 2012, which remains pending. It is tendered via this bar table motion in the alternative, in the event the Chamber declines to admit it in connection with that earlier motion. 65ter# 29-Feb-1992 Extract from minutes of This document is relevant to show No objection 05417 14th session of the ARK that the day after the 28 February Assembly. 1992 SDS Deputies Club (P00938), Karadzic takes part in ARK KARAD@I]’s report on meeting to successfully ensure the political and security implementation of his position. It situation on the ground also corroborates R92 quater was accepted in full. evidence of Witness Milan Babi} Discussion about the (KDZ172). territory, after which conclusions passed, one was to “Establish immediately strict control of the territory of the Autonomous Region of Krajina.” 65ter# 23-Apr-1992 Letter No. 11 from Chief This document is relevant to show Objection-- 05432 of CSB Banja Luka, the cooperation of the police and irrelevant Stojan @UPLJANIN, to military organs in relation to General KUKANJAC, arming, and the existence of a Commander, 2nd Military special purpose police unit in CSB 79058 IT-95-5/18-T 55 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case District, requesting the Banja Luka. It is associated with a handing over of material 65ter#05435 (listed below). assets This is relevant to RS MUP/JNA co-operation in arming the Serb population in the ARK. CSB Banja Luka was the regional headquarters for the RS MUP in the entire ARK, and not only Banja Luka municipality. 65ter# 27-Apr-1992 ARK Assembly Decision This document is associated with IT-99-36: Objection-- 05435 on the Formation of a item 65ter#05432 (listed above) P159 irrelevant Special Purpose Police and identifies details of the special Detachment (with a purpose police unit. Statement of Reasons attached) The two documents are also relevant to cooperation between civilian and military authorities in respect of the Serb takeover of power in ARK municipalities and the subsequent expulsion of the non-Serb population, and in particular the involvement of the ARK Assembly in military matters. 65ter# 06-Jun-1992 6 June 1992 Sanski Most This document is relevant to the No objection 05475 Crisis Staff Conclusions. network of detention facilities No. K[-31/92. spanning the municipalities and to the collaboration of the municipal The document states that authorities, police and army in “The Public Security transferring prisoners from facility 79057 IT-95-5/18-T 56 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case Station is hereby to facility. Also specifically instructed to evacuate 150 relevant to Count 3 and Scheduled prisoners /and take them/ Detention Facilities C.1.2. and to Manja~a. Schedule C.22. 65ter# 30-Jun-1992 30th Krajina Division This document is relevant to show IT-99-36: No objection 05509 Notification No. 174-326 VRS interaction with and P390 to 19th Krajina Brigade facilitation of Serb paramilitary regarding passage of a units. convoy with White Eagles from Banja Luka to Turbe, signed by Colonel Stanislav GALI]. 65ter# RS Official Gazette, No. This document is relevant as it No objection 05528 11, Decision signed by refutes Karadzi}’s claim that Radovan KARAD@I] Judges were appointed independent appointing District Court of ethnicity. judges for Banja Luka (pages BCS 16; ENG 43- 44). 65ter# 27-Jul-1992 Order of the 1KK (Scheduled Detention Facility IT-99-36: Objection---should 05545 Command, confidential C.1.2.). The document is relevant P399 have been operative no. 574-2, to to the operation of the camp by the presented with Manja~a camp command the VRS and details the units KDZ163 on stepping up security involved. The document also notes measures and defence of that the Ministry of Interior of the the prisoner of war camp Serbian Republic of Bosnia and Manja~a. The order is Herzegovina police are part of the signed and stamped. security apparatus of the camp and is thus also relevant to coordination 79056 IT-95-5/18-T 57 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case The 1KK Command between the police and military in orders the commander of the maintenance of the detention the camp to take facility network. intensified measures of internal and external security of the camp; to continue to engage the military police and the police forces for internal security as before; to make the necessary number of foxholes for the personnel on the camp grounds for several variants of defence and increase the number of minefields; to take measures to organise and secure communication between the camp commander and all subordinated security forces; and to take other measures in order to provide complete security of the camp and forward requests for necessary technical and material assistance to command 79055 IT-95-5/18-T 58 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case organs. 65ter# 02-Aug-1992 1KK Command regular This document is relevant to the IT-99-36: No objection 05556 combat report, strictly forced displacement of Muslim and P402 confidential no. 44-1/272, Croat population and to reporting to VRS Main Staff about and awareness of crimes up the the situation in the area of VRS chain of command. responsibility. The report is signed and stamped.

With regard to the situation on the ground, the reports to VRS Main Staff note that methods of exercising pressure are increasing, as are organised expulsions of the Muslim and Croat population from the area of Bosnian Krajina and further afield.. 65ter# 03-Aug-1992 Letter No. 565-3 of 1KK This document is relevant to IT-99-36: Objection—should 05557 Command to the Scheduled Detention Facility P405; have been Command of the 43rd C.1.2. and shows the concerted IT-97-24 presented with Motorized Brigade re efforts to mislead the international (Staki}): S426 KDZ163 Approval for visit of the visitors regarding the detention International Committee conditions. It also shows that the to the detention camps at VRS is fully aware of the Manja~a, Trnopolje, insufficient detention conditions. Omarska and Prijedor. 79054 IT-95-5/18-T 59 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case The 1 KK orders the Manja~a camp command to prepare the camp for a visit of internationals. Measures are directed to improve the situation ahead of the visit. 65ter# 03-Aug-1992 VRS Main Staff This document is associated with Objection—should 05558 confidential urgent order 65ter#05557 and is relevant to have been sent from the Main Staff demonstrate VRS Main Staff presented with Commander Ratko control of access to prisoners-of- KDZ163 MLADIC to the war camps. It is also relevant to the Commanders personally, preparation of Manja~a and other no. 03/5-91/?/. The order detention facilities for visits of bears a delivery stamp. internationals and journalists. It is related to Scheduled Detention Pursuant to the agreement Facilities C.1.2, C.18.1, C.20.2 and of political leadership of 20.4. three BiH peoples reached at the negotiations in London, Ratko MLADIC orders to immediately undertake measures through the MUP and authorities to arrange POW camps in zones of responsibility and prepare them for visits by foreign journalists and International Red cross. 79053 IT-95-5/18-T 60 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case The order refers that the plan is to visit the following camps: Omarska, Trnopolje and Manja~a in the zone of 1st Krajina Corps but it also orders to “prepare all other POW camps in your zone of responsibility”. The tour started on 3 August 1992 in the zone of responsibility of the Sarajevo-Romanija Corps. MLADIC orders to, together with MUP, provide accommodation and escort for the journalists; and to prepare material evidence regarding the crimes done by the enemy and present it in appropriate manner to those teams. 65ter# 07-Aug-1992 There are two related This document is relevant to IT99-36: P405 Objection—should 05570 document in this 65 ter Scheduled Detention Facility C.1.2 have been exhibit number. (Manja~a camp), including the size IT-97-24 presented with of the camp, contemporaneous (Staki}): S426 KDZ163 The first one is a request reporting about the camp within the of the 1KK Corps VRS structure and coordination Command to the between the VRS and municipal 79052 IT-95-5/18-T 61 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case President of Prijedor authorities in connection with the Municipal Assembly use and maintenance of the camp. asking for a 3.5-ton truck to meet the needs of the Manja~a camp. It states that the Manja~a camp has increased and food needs to be provided for about 4000 people; from the territory of Kozarac, Prijedor and Sanski Most.

The second document in this 65 ter exhibit number is a certificate of the Manja~a camp confirming that on 10 August 1992, the Prijedor Public Security Station handed over a truck to the Manja~a camp for use. 65ter# 11-Aug-1992 Decision of RS Assembly This document is relevant to No objection 05583 appointing Deputy Basic persecution count and is associated Prosecutors in Banja Luka with 65ter#05528 (above). It shows persecution through employment discrimination as list shows names of persons of Serb ethnicity only. 65ter# 13-Aug-1992 Daily report of Manja~a This document is relevant to Objection—should 05588 Camp Operational Team Scheduled Incident B.1.1.4, have been 79051 IT-95-5/18-T 62 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case to 1KK Command of the including contemporaneous presented with Security-Intelligence reporting about the camp within the KDZ163 Department, strictly VRS structure, concerns about the confidential. No. 1-41. ICRC and crimes in the camp.

The team leader of the Manja~a camp reported to his superiors about the daily activity in the Manja~a camp on 13 August 1992. He reported on the number of prisoners that were processed on that day; about the visit of the Red Cross to the camp; about the possibility that the Red Cross received information from the camp inmates that two prisoners were physically maltreated, following which they died (Omer FILIPOVI] and Esad BENDER); and about the written messages that were brought by the ICRC. 65ter# 14-Aug-1992 Information of CSB Banja This document is relevant to show IT-00-39: Objection-- 05589 Luka on disbandment of the Accused's and the Republic P64.A irrelevant 79050 IT-95-5/18-T 63 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case the CSB Special Police level authority over the local IT-99-36: Banja Luka authorities. It also shows that P306 despite criminal activities of certain members of the special purpose police unit, decision taken to transfer these individuals into VRS units.

The document description failed to note that the document was issued by the Chief of the Banja Luka CSB to all Chiefs of SJB’s (public security stations), as well as the command of the 1st Krajina Corps (1KK), ordering that the special police detachment “is disbanded” and the troops and materiel to be re-attached to the commander of the 1KK “on the basis of the order issued by the President of the Presidency.” Accordingly, the document is relevant to Karadzic’s commanding role over the MUP and the VRS. 65ter# 05-Nov-1992 Daily report of Manja~a This document is relevant to show Objection—should 05645 Detention Facility that as of November 1992 the have been Operational Team to 1KK authorities were still detaining presented with Command Security- under-aged and elderly civilians. KDZ163 Intelligence Department. 65ter# 18-Dec-1992 1KK Command combat This document is relevant to show IT-99-36: Objection—should 79049 IT-95-5/18-T 64 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case 05669 report no. 44/1-548 to that information about the facility P443 have been VRS Main Staff, is being reported up the VRS chain presented with reporting that the release of command. Document is signed KDZ163 of the remaining detainees and stamped. from Scheduled Detention Facility C.1.2. (Manja~a) was completed on 18 December and the closure of the camp. 65ter# 18-Dec-1992 ICRC Press Release No. This document is relevant to Objection—should 05670 92/37: Manjaca Camp Scheduled Detention Facility have been Closed Down C.1.2. (Manja~a). It shows the presented with release of detainees and thus KDZ163—also use confirms the duration of the camp’s of ICRC existence. In addition, the documents is document refers to the conditions unfair given lack in the camp and the fact that some of access by of the detainees were transferred to defence Batkovi} camp (Scheduled Detention Facility C.2.1.) without knowledge of the ICRC. Finally the document refers to the number of detainees in Batkovi} camp. 65ter# 09-Jun-1992 Order (strictly This document is relevant to the IT-97-24 No objection 05759 confidential number 488- ethnic composition of the VRS and (Staki}): S393; 3 of the 9th of June, 1992) the pressures on the limited number from the commander of of Muslim and Croat officers. IT-02-54 VRS Colonel General P463.17; Ratko MLADI] sent to the command of the 1st IT-99-36: 79048 IT-95-5/18-T 65 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case Krajina Corps regarding P1583 sending officers of Muslim and Croat nationality on leave to the VJ to resolve their status. 65ter# 10-Jun-1992 Prijedor Crisis Staff This document, in conjunction with No objection 05760 issues copy of Extracts of witness testimonies about actions Conclusions of ARK directed against non-Serbs, is Crisis Staff of 13 May relevant to discrimination against 1992 to all socially and non-Serbs. privately owned companies that all management/executive positions to be occupied by persons who are loyal to SeRBiH. 65ter# 04-Aug-1992 Report No. no. 11-12-38 This document is relevant to show No objection 05774 re Information and Data, the level of co-operation and co- from Simo DRLJA^A, ordination between JCE members, Chief of Prijedor SJB to the VRS and RS MUP and also Banja Luka CSB. The relevant to Scheduled Incidents document makes A.10 and Scheduled Detention reference to cohesion and Facilities C.20. synchronization between the military and police in attacks on towns named in the indictment and scheduled detention facilities in Prijedor in Scheduled Incidents A.10 79047 IT-95-5/18-T 66 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case and Scheduled Detention Facilities C.20. It also states that information is exchanged daily between the military and police. 65ter# 18 to 20-Aug-1992 Daily report of prisoner- This document is relevant to the Objection—should 05777 of-war camp Manja~a Manja~a detention facility have been operational team for 18- (Scheduled Detention Facility C presented with 20 August 1992, sent to 1.2) and command and control over KDZ163 the Command of the 1st the detention camp through the Krajina Corps, VRS Main Staff. intelligence-security department, strictly confidential no.1-43. The report is signed for the Operative Group by RADINKOVI] Radomir, staff sergeant.

This report notes that operatives are mainly engaged in completing the lists of prisoners under 18 and over 60 years old, describes the visit of the ICRS and foreign journalists, and the order received form the Main Staff of the VRS. 65ter# 16-Mar-1992 Interview with Radovan This interview is relevant to Objection—news 79046 IT-95-5/18-T 67 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case 05793 KARAD@I], Borba, Bosnian Serb objectives and intent. media reports are regarding, inter alia, Serb not admissible aspirations (“I am through bar table convinced that the Serbs will never makes peace until they achieve their age-old aspiration to live in one state.”); the nature of a civil war that might ensue (“…hundreds of thousands of dead and hundreds of towns destroyed..”); the status of Cutileiro discussions (Serbs, Muslims and Croats all have “their own maps,” which have not been put up for adoption); and need for ethnic division (although Serbs and Muslims intermixed over time, today “they cannot live together but only alongside one another.”) 65ter# 28-Oct-1991 Instructions on This document is relevant to SDS No objection 05795 Implementation of hierarchy and communications, and plebiscite of Serbian to the implementation of the People in BH issued to plebiscite, an important municipal commissions “milestone” (T:14027) which 79045 IT-95-5/18-T 68 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case by the republic level SDS would serve one justification for Commission. vast Bosnian Serb territorial claims (see P02536, para. 172). In addition, the format of the document resembles P00960 (Variant A/B), thus corroborating it as an SDS document. 65ter# 19-Feb-1992 Letter from Executive This document is relevant to the No objection 05879 Board of SDS BiH to hierarchical nature of the SDS and Municipal and Regional to the ability of the republic level Boards of SDS BiH, No. to reach and instruct municipal and 490-02/9, obliging them local boards. to hold an expanded meeting and draw up a plan of action to ensure that every Serb refrains from participating in the referendum; with attached Conclusions of Bosnian Serb Assembly of 26 January 1992 65ter# 01-Oct-1992 Conf. No. 711 Report by This document is relevant to show Objection-- 05928 1KK Command, that the utterances of the BSL are irrelevant regarding “Some of our reported from the VRS Main Staff delegation’s views and to the Corps and obviously assessments about the prepared for further distribution. negotiations in Geneva" stemming from a phone- The document is relevant to in programme with communication chains within the Radovan KARAD@I], a VRS and between the political 79044 IT-95-5/18-T 69 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case joint news conference authorities and the VRS and is with Mom~ilo further relevant to the territorial KRAJI[NIK and a objectives of the Bosnian Serb number of statements. leadership, including in areas This report provides some where non-Serbs constituted a excerpts. majority.

One of the excerpts is KARAD@I] stating that at the Assembly session in Banja Luka they adopted a constitutional amendment whereby the RS became a unified state without autonomous areas and regions.

In another part of the same paragraph KARAD@I] is asked whether the territory of the RS should be defined and he says, "our eastern border is the border with Serbia and Montenegro, that is the Yugoslav border [see Strategic Objective # 3]. The norther border is the river Sava, the western border 79043 IT-95-5/18-T 70 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case is the river Una, and he goes on to describe what is theirs in Central Bosnia, the Sava and Neretva Valleys..."These are the areas in which the Serbs were in the majority. They may not be a majority in the Neretva valley now, but they were in majority there before the genocide." KARAD@I] also emphasises the great aspiration of the Serbian people to unite in one state but won't announce unification for the time being for political reasons. 65ter# 06-May-1995 Meeting, which President This document is relevant to No objection 06110 Radovan KARAD@I] KARAD@I]’s command and chaired, with Command control over the VRS, including his of Eastern Bosnia Corps, authority to deal directly with Krajisnik, Subotic, subordinate units. concerning KARAD@I]’s criticism of General MLADI]’s previous briefing on 26 April 1995. 79042 IT-95-5/18-T 71 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case 65ter# 06-May-1992 Advisement to various This document is relevant to the Objection-- 06481 commands and corps by cooperation and support of the VJ cumulative General Adzi} of the and FRY to the Bosnian Serbs and Regulation of Status of also to the establishment and Active Military and maintenance of Serb military Civilian Personnel, superiority that enabled the forcible SSNO, Personnel takeover of of large portions of Administration, Strictly BiH territory. Conf. No. 01/49-1, with explanation that it has been ensured that the JNA members who remain in the territory of BiH will retain all rights as other members of the JNA. 65ter# 21-Aug-1992 Decision of Serbian This document is relevant to the Objection— 06692 Municipality of forcible transfer of Muslims from uncharged BosanskaKrupa, 21 territories controlled by SDS and municipality August 1992, signed RS authorities, and to crimes KLI^KOVI], that, inter committed against perceived alia, all members of the members of the Muslim leadership. SDA on the territory of the Serbian municipality of Bosanska Krupa are declared war criminals and banned from returning to the territory. 65ter# 12-Sep-1992 VRS Main Staff This document is relevant to the No objection 07011 instruction, 12 September cooperation and support of the VJ 1992, to 1st Krajina Corps and FRY for the Bosnian Serbs and 79041 IT-95-5/18-T 72 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case Command regarding the to Bosnian Serb military agreement (plan code- superiority which enabled them to named Izvor )with the forcibly take and control large Main Staff of the FRY areas of BiH territory. army for large amounts of ammunition (approximately 450 tons). It is also noted that the Main Staff has taken measures to procure raw material for the production of higher- calibre ammunition. 65ter# 17-Jun-1992 Appointment of members This document is relevant to IT-00-39: No objection 07063 of the War Commission KARAD@I]’s linkage to and P64A Tab 734 in Zvornik by Radovan authority over local authorities. KARAD@I], President of the Presidency. 65ter# 26-Sep-1992 26 September 1992 This document, which was issued a No objection 07064 authorisation from few days after the 2nd Romanija Commander Radislav Brigade had expelled the women, KRSTIC to a member of children and elderly and killed the the 2nd Romanija Brigade men of Novoseoci, a Muslim to transport furniture and village (see Schedule A, incident appliances from 13 of the indictment) is relevant to Novoseoci to Sokolac, the organized plundering of the until the soldier’s “final village and the intention to moving” into a house in permanently remove its Muslim Novoseoci which he has inhabitants. The issue noted in this chosen. document was raised during the 79040 IT-95-5/18-T 73 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case evidence of Munira SELMANOVIC and 65ter# 07064.

65ter# 04-Apr-1992 04 April 1992 Strictly This document is relevant to SDS IT-00-39: No objection 07068 Confidential Nr. 20/27- cooperation with paramilitaries and P590 96/1 Daily Operations to the SDS takeover of Bijeljina, Report by Major General one of the Scheduled Savo JANKOVIC, 17th municipalities from the indictment. Corps Commander, to the Command of the 2nd Military District reporting, inter alia, that “the town of Bijeljina is controlled by the SDS and Arkan’s men…” 65ter# 17-Mar-1992 17 March 1992 request This document is relevant to the IT-97-25: Objection-- 07092 from the President of the Bosnian Serb cooperation with the P24a irrelevant Serbian Municipal JNA and to preparations for the Assembly of Fo~a to takeover of Fo~a municipality. Colonel General Adzic to station a garrison in Fo~a. This is relevant to the close Stationing a Garrison in relationship between the JNA and Fo~a, the Bosnian Serbs which existed before the JNA withdrew and that played an important role in the takeover of territory claimed by the Bosnian Serbs, as alleged inter alia at paras. 127-131 of the Prosecution PTB, as well as to the existence of Bosnian Serb military 79039 IT-95-5/18-T 74 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case superiority that enabled the takeover of 70% of the territory of Bosnia and Herzegovina. 65ter# 26-Mar-1995 26 March 1995 order by This document is associated with No objection 07095 President of the Republic Exhibit P02248. This is s signed Dr. Radovan KARAD@I] copy of P02248. This document is (No. 01-538-2/95) to all relevant to command and control. state organs, The document relates to Exhibit municipalities, firms, P02249, which transmits this order commands and units of to VRS units. the Military Forces and Internal Affairs to mobilize all resources in order to finally crush and defeat the enemy. 65ter# 30-Aug-1994 ICRC Press release This document is relevant to the IT-02-54: Objection—ICRC 07414 reporting the continuation forced transfer of civilians and to P470.27-4 documents not of forcible transfers of notice to the Bosnian Serb accessible to both Muslims from the authorities. parties Bijeljina area, bringing to over one thousand the number of Muslim civilians driven out of the ares since mid-July. The ICRC reports that it has been making repeated representations at all levels, thus far in vain, to remind the Bosnian Serb authorities of their 79038 IT-95-5/18-T 75 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case obligation to respect international humanitarian law and to put an end to forced transfers of civilians. 65ter# 21-Apr-1993 VRS publication, no. 7 This VRS document is relevant, No objection 07707 (April 1993). Yearly inter alia, to the implementation of Analysis of Defence the Strategic Objectives. Combat Operations of the VRS.

MLADI] points out at the yearly analysis conference that they successfully and patriotically defended against the Ustasha and their accessories "which came as a result of the clearly defined goals of our struggle at the Assembly session of RS held on the 12th May 1992..." (MLADI] goes on to discuss various operations "in the realisation of our political goals in this war which has been thrust on us.") 65ter# 15-Jun-1992 Regular combat report This report is relevant to the No objection 79037 IT-95-5/18-T 76 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case 07917 No. 102-92 sent by the involvement of the Rogatica Rogatica Brigade (signed Brigade in Scheduled Incident for the commander Rajko C21.1 and to the Rogatica KUSI]) to the SRK. It Brigade’s incorporation into the reports that “large SRK/VRS structure. numbers of Muslims, mostly women and children, are arriving in the town every day. The people are being moved into the premises of the Secondary School Centre.” 65ter# 17-Jun-1992 Radovan KARAD@I]'s This document is relevant to the IT-00-39: No objection 07936 confirmation of RS Presidency’s selection of P64A Tab 735 Appointment of War municipal leaders, the identity of Commission in Vlasenica those municipal leaders, KARAD@I]’s links to the local leadership of Vlasencia and to the implementation of his Decision on the Formation of War Commissions. 65ter# 26-Apr-1992 Strictly Confidential This order is relevant to the JNA’s Objection— 07982 Order Nr. 11/2-89, from involvement in the conflict in irrelevant and the JNA 17th Corps support of the Bosnian Serbs, and cumulative Command, signed by JNA cooperation with Serbian TO Major General Milan and police forces in combat NEDELJKOVI] operations in the Bosanska including instructions to Posavina region. subordinate units of the 79036 IT-95-5/18-T 77 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case JNA 17th Corps to Such “combat activities,” the cooperate with Serbian decision provides, includes TO and police units. “offensive” activities in coordination with the Serbian TO and the police. The Prosecution has alleged, as detailed inter alia in paras. 127-131 of the Pretrial Brief, that a close relationship between the JNA and the Bosnian Serbs existed before the JNA withdrew, which played an important role in the takeover of territory claimed by the Bosnian Serbs. This document is relevant to the existence of that relationship and to the conduct of “offensive” combat activities in support of the Bosnian Serb takeover of territory. 65ter# 07-Apr-1992 Sitrep from the HQ of the This report is relevant to the JNA’s No objection 08023 JNA Second Military involvement in the conflict in District to the General support of the Bosnian Serbs. Staff in Belgrade describing the Kupres, Bosanski Brod, Bijeljina and Sarajevo fronts. It describes the “enemy forces” in Bijeljina as 400 SDA members, “most of them disarmed now”. 65ter# 19-May 1992 Letter to Ministry of the This report is relevant to the issue IT-00-39: No objection 79035 IT-95-5/18-T 78 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case 08200 Interior, Attention: of effective communications from P727 Minister (STANI[I]) Bijeljina, Br~ko and Zvornik to the including reports on the Republican authorities in May situation in Bijeljina, 1992. It is also relevant to the Ugljevik, Lopare, establishment and functioning of Zvornik, and Br~ko. Bosnian Serb authorities in Bijeljina and Zvornik municipalities at this time. 65ter# 16-Apr-1992 Bijeljina CSB report to This report is relevant to the issue IT-02-54: No objection 08230 Minister STANI[I], of effective communications from P420.6 including reports on the Bijeljina and Zvornik to security situation in Republican authorities in mid- Zvornik and Br~ko stating April. It is also relevant to the that Zvornik was under Bosnian Serb takeover of Bijeljina the control of the Serbian and Zvornik and to control over police and TO and there those areas at that time. was no shooting at the time. 65ter# 17-Jun-1992 Confirmation of the This document is relevant to the IT-00-39: No objection 08396 appointment of members RS Presidency’s selection of P64A Tab 736 to the War Commission in municipal leaders, the identity of the Serbian municipality those municipal leaders (including of Bratunac, signed by Miroslav DERONJI]), Radovan KARAD@I] KARAD@I]’s links to the local (No.01-79/92 ) leadership of Bratunac and to the implementation of his Decision on the Formation of War Commissions. 65ter# 11-Jan-1994 Record of the speech of This document is relevant to the No objection 79034 IT-95-5/18-T 79 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case 08440 Radovan KARAD@I] at dissemination of KARAD@I]’s the Ceremonial Session of anti-Muslim views to members of the RS Assembly the VRS, and specifically his views forwarded by the Drina on the existential threat that Corps Command to its Bosnian Muslims posed to Bosnian units. The Drina Corps Serbs. The document is also Commander stated that relevant to the alignment of the decision to KARAD@I]’s political views with “familiarize all members his and the VRS’s military of the Corps … with the objectives. speech delivered by … KARAD@I]” “was Note that the Ceremonial motivated by the Assembly Session, of which this Command’s wish to let all speech forms a part, is separately members of the Corps tendered under 65ter#11276. learn, hear and understand the significance, character and results of the struggle of the Serbian people so far, its objective and the chance of accomplishing it.” (See also 65ter#11276) 65ter# 13-Feb-1993 Regular Combat Report, This report is relevant to the IT-05-88: No objection 08972 Zvornik Light Infantry implementation of Directive 4 P04235 Brigade Command (P00976). Document No. 109-1, dated 13 February 1993, sent by Commander Major Vinko 79033 IT-95-5/18-T 80 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case PANDUREVI]. The Zvornik Brigade reported to the Drina Corps command that, in the region of Nezuk, artillery opened fire on two groups of civilians and soldiers. 65ter# 01-Feb-1993 Regular Combat Report, This report is relevant to the No objection 09048 Drina Corp Command implementation of Directive 4 Document No. 01/4-67, (P00976) by the Drina Corps, as dated 1 February 1993, well as the reporting of this sent by Commander information to the VRS Main Staff. Milenko Zivanovic. In this report, the Drina This report relates to, and should Corps reports that an be read in conjunction with, the arrested Muslim was sent Drina Corps report from the to Kamenica to tell the previous day, 65ter#09215, also Muslims that women, tendered via the bar table. children and the elderly could leave. The report also notes that several hundred women children and elderly had passed through the corridor. 65ter# 14-Jul-1992 1KK Command, Security Much of the contents of this 14 Objection— 09073 and Intelligence July 1992 report to the Main Staff irrelevant and Department, document is incorporated into the subsequent cumulative No. 22-188 by Zdravko Main Staff report on paramilitaries DJURI] in response to (P02855), indicating the reporting the VRS telegram, strictly of information on paramilitaries up 79032 IT-95-5/18-T 81 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case confidential no: 31/15- the VRS chain of command. The 233 of 12 July 1992. The report also shows that despite the report states that three acknowledgment of the extremist listed paramilitary groups behaviour of and criminal active in the Prijedor area activities by some paramilitary “became part of the 343rd formations, these remained within Motorized Brigade and the VRS structure. In addition, this are carrying out tasks in report contains additional an organized fashion.” information relevant to The report also contains a paramilitary groups incorporated section on “crime and into the 343rd Motorized Brigade in abuse of office” which Prijedor (a unit involved in the discusses only the commission of crimes). The report, problems of removal of which fails to identify crimes foreign currency from the against the non-Serb population as ARK, and members of a problem in its discussion of special police units crimes, is also relevant to the stealing equipment. No discriminatory and persecutory mention is made of the policy toward Muslims. commission of crimes against the non-Serb population. 65ter# 05-Feb-1993 Drina Corp Command This order is relevant to the No objection 09106 Order No. 03/5-81, dated implementation of Directive 4 5 February 1993, sent by (P00976). Commander Milenko @IVANOVI} to the Zvornik Brigade, which describes VRS efforts to ensure that the Muslim 79031 IT-95-5/18-T 82 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case population leaving Kamenica does not head to Serb-held territory (Zvornik) but departs to Muslim-held territory (Kalesija), and orders that the population should be treated like the enemy if they head towards Serb- held territory. 65ter# 31-Jan-1993 Regular combat report This report is relevant to the IT-05-88: No objection 09147 No. 82-3 sent by the implementation of Directive 4 P04229 Zvornik brigade to the (P00976). Drina Corps. The report The report reflects efforts to have the Muslim people of Cerska and Kamenica leave the territory, noting that Zvornik radio announced to the Muslim people of Cerska and Kamenica that they can leave the territory of combat operations and that a corridor will be opened on 2 February 1993 from 0700 to 1700 hours. The report also reveals that the Muslim population were 79030 IT-95-5/18-T 83 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case departing the area in spite of terrible conditions in that it observes that women and children who had left from the direction of Crni Vrh had frozen to death. 65ter# 11-Oct-1995 Order of the RS MUP This document is relevant to show Objection— 09195 Minister referring to that, as of October 1995, Arkan's irrelevant to any Arkan's unit as a “Special unit was integrated into the MUP crimes charged for Purposes Unit” structure, and that the RS 1995 (“Tigrovi”) of the MUP. authorities were still using Arkan in furtherance of their objectives.

This document is relevant to show that although the Bosnian Serb Leadership was aware of the crimes committed by the paramilitary units, especially ARKAN who was notorious for crimes against the non-Serbs, paramilitary units were operationally subordinated to the police, TO and army from 1992 throughout October 1995. (PTB, paras. 133 to 136) 65ter# 24-Feb-1993 Regular Combat Report, This report is relevant to show the No objection 09212 Drina Corp Command implementation of Directive 4 Document No. 03/4-112, (P00976). dated 24 February 1993, 79029 IT-95-5/18-T 84 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case sent by Commander Milenko @IVANOVI} reflecting that that Drina Corps Commander @ivanovi} ordered artillery against “areas” including villages listed in Directive : “At 14:30 all artillery units were ordered to open fire in a duration of 30 minutes against the areas of Cerska, Konjevi} Polje, Potocari, Srebrenica and @epa.” 65ter# 31-Jan-1993 Regular Combat Report, This report is relevant to the No objection 09215 Drina Corp Command implementation of Directive 4 Document No. 4/66, dated (P00976) and the Drina Corps 31 January 1993, sent for efforts to ensure the departure of Commander Milenko the Muslim population from @IVANOVI}. The Drina Cerska and Kamenica, as well as Corps reported to the the reporting of this information to Main Staff that around the VRS Main Staff. 200 women and children were leaving Cerska and This report relates to, and should Kamenica, and that an be read in conjunction with, the announcement on Zvornik Drina Corps report of the following Radio encouraged “the day (65ter#09048) also tendered Muslim people (women via the bar table. and children)” to leave 79028 IT-95-5/18-T 85 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case Cerska and Kamenica and that the Zvornik Brigade would open a corridor to facilitate their exit. 65ter# 10-Apr-1993 Regular Combat Report, This report is relevant to the Objection-- 09236 Zvornik Light Infantry positive views of KARAD@I] and irrelevant Brigade Command other members of the RS Document No. 225-1, leadership towards the 9 April dated 10 April 1993, sent 1992 takeover of Zvornik by Commander Major municipality and its aftermath and Vinko PANDUREVI]. thus relevant to the forcible transfer The report states that and crimes against non-Serbs in KARAD@I] and Koljevic Zvornik. were present in Zvornik on 9 April 1993 to This is also relevant to celebrate “the day of the understanding the context of the liberation of Zvornik”. Accused’s words to the RS Assembly on 24 March 1992, shortly before the Serb takeover of Zvornik:. “We have a legal basis in the Law on Internal Affairs and we also have the insignia and at a desired moment, and this will be very soon, we can form whatever we want. There are reasons why this could happen in two or three days. Such are the forecasts but I cannot tell you the reasons now. At that moment, all the Serbian municipalities, both the old ones and the newly established ones, would 79027 IT-95-5/18-T 86 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case literally assume control of the entire territory of the municipality concerned. The Zvornik municipality takes control over everything that constitutes the Serbian Municipality of Zvornik. Then, at a given moment, in the next three or four days, there will be a single method used and you will be able to apply it in the municipalities you represent, including both things that must be done as well as how to do them. How to separate the police force, take the resources that belong to the Serbian people and take command.”. 65ter# 08-Mar-1993 Instruction for further This order is relevant to show the No objection 09242 activities, Drina Corp incorporation of the Panthers Command Document No. volunteer/paramilitary unit under 01/05-139, dated 08 the command of Mauzer (earlier March 1993, sent by involved in crimes in Bijeljina and Commander Milenko Br~ko – see AF 2238, 2239, 2262, @IVANOVI}. The Drina 2341, 2347, 2350) into the VRS Corps tasks the Drina Corps and their participation “Panthers” under the in implementing Directive 4 command of Mauzer. (P00976) in early 1993. 65ter# 17-Nov-1992 Zvornik Brigade Combat This report is relevant to the No objection 09389 Report No. 771-2/92, targeting and persecution of signed by Milutin Muslim civilians by the VRS. BOSANCI], dated 17 November 1992. The 79026 IT-95-5/18-T 87 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case Zvornik Brigade reports that it opened fire on a group of 13 Muslim civilians trying to move from Snagovo to Kalesija. Seven got through, while six were captured, all of whom were unarmed and one of whom was a women. The report also states that "another two Muslims were arrested at the Karakaj railway bridge in an attempt to cross into the Federal Republic of Yugoslavia... Their final destination was Belgrade, where they had worked.” 65ter# 13-Jul-1992 (rec’d Government of the This order is relevant to the central Objection-- 09433 by the 1KK on 11- Serbian Republic of BH RS authorities’ regulation and irrelevant Oct-1992 instruction on the collection of the results of plunder implementation of the in the municipalities. Decree on the obligatory hand-over of war and other booty to the republican commodity reserves passed to units of the 1KK in October 1992. The document defines 79025 IT-95-5/18-T 88 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case “war booty” as “war and other booty” and the contents make clear that the definition encompasses, among other things, “gold and valuables” which are to be handed over to the RS National Bank Treasury. 65ter# 18-Jul-1992 Message from the This document is relevant to No objection 09452 Prijedor SJB to the Banja knowledge of and control over Luka CSB dated 18 July detention facilities. 1992 describing how RS MUP and VRS authorities will cooperate in escorting five busloads of women and children from Prijedor Municipality from Trnopolje camp to Skender Vakuf. 65ter# 3-Aug-1992 Report entitled Analysis This report is relevant to the No objection 09455 of Unit Morale issued by organized expulsion of non-Serbs the 11th Battalion by military and civilian authorities Command, signed by Ilija in furtherance of their objectives. RAJLI] (Assistant Commander for Morale). Note that the 11th Battalion of the The Assistant 6th Partisan Brigade of the 1KK Commander for Morale operated in Sanski Most (see and Religious Affairs of Brown Report (P03914), para. the 11th Battalion of the 2.140 fn. 537) 79024 IT-95-5/18-T 89 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case 6th Partisan Brigade notes the involvement of unit members in “resettling the population of other nationalities” but complains that there are “very poor or non-existent criteria for the resettlement of the population of other nationalities” and recommends that “the civil authorities should set strict criteria for the continued stay of population of other nationalities...”. 65ter# 05-Apr-1992 Serbian Municipality of This order is relevant to SDS and Objection-- 09465 Zvornik Crisis Staff Order Crisis Staff control over the TO irrelevant for the Mobilization of (which would later commit crimes the TO dated 05 April under the command of Marko 1992, ordering a test- PAVLOVI]) and to preparations mobilization of the TO, for war. Branko GRUJI] and signed by Branko identified himself as the Crisis Grujic as Crisis Staff Staff “Commander” in Zvornik. commander. This document also assists in understanding the implementation on the ground of the Accused’s intention to take over Zvornik and 79023 IT-95-5/18-T 90 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case other targeted municipalities. At the 24 March 1992 session of the RS Assembly, the Accused said: "At a desired moment, and this will be very soon, we can form whatever we want. There are reasons why this could happen in two or three days, such are the forecasts, but I cannot tell you the reasons now. At that moment, all the Serbian municipalities, both the old ones and the newly established ones, would literally assume control of the entire territory of the municipality concerned. The Zvornik municipality takes control over everything that constitutes the Serbian municipality of Zvornik. Then, at a given moment, in the next three or four days, there will be a single method used, and you will be able to apply it in the municipalities you represent, including both things that must be done 79022 IT-95-5/18-T 91 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case as well as how to do them; how to separate the police force, take the resources that belong to the Serbian people, and take command.”(P961, p.21 English). See also Adjudicated Facts 2740- 2742. 65ter# 25-Sep-1992 Fax transmitted from the This document is relevant to the IT-00-39: No objection 10531 RS Presidency to the focus of the RS leadership on P200 Tab 22 SAOs, the VRS Main crimes committed against ethnic (under seal) Staff and the SRK on 29 Serbs in the conflict, in contrast to September 1992, crimes against non-Serbs. . requesting the formation of the commissions for gathering information on crimes committed against the Serbs by the Croatian- Muslim coalition 65ter# 27-Jun-1993 Report from the 1KK This document is relevant to the IT-00-39: No objection 10533 Military Prosecutor’s focus of the VRS Main Staff and P200 Tab 24 Office to the Military the 1KK on military prosecutions (under seal) Prosecutor of the Main for “war crimes committed against Staff signed by Srboljub the Serbian population” as well as JOVI^INAC. This 1KK the functioning military justice report is responding to a system at the time. Main Staff request to send all documentation and evidence of war crimes committed against the Serbian population in the 79021 IT-95-5/18-T 92 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case former BiH , and lists a number of such cases. 65ter# 01-Aug-1992 List no 08-132-1/92 from This document is relevant to No objection 10556 SJB Vi{egrad to CSB Scheduled Incident A.14.2. Trebinje re workers for Witness Ferid Spahi} (KDZ210) in salary payments for June his evidence provided names of and July 1992 policemen from the SJB Vi{egrad who escorted a convoy of Muslim people from Vi{egrad to Olovo and took part in the execution of men from the convoy in Sokolac (Scheduled Incident A.14.2). Mr Spahi} was present in the convoy and at the execution site. Policemen named by the witness appear in the payment lists, i.e Predrag Milisavljevi}, Bori{a ]eho, @eljko Tasi}, Nenad Tanaskovi}, and the chief of police, Risto Peri{i}, whom the witness saw in the main square in Vi{egrad as the convoy was leaving. 65ter# 01-Jul-1992 VRS Tribute to the 1KK This document is relevant to IT-00-39: Objection— 10712 and East Bosnia Corps for illustrate the military P1235 irrelevant and breaking through the implementation of the Strategic cumulative corridor by Ratko Objectives, in this case, Objective MLADI] 2, establishing a corridor between Semberija and Krajina. The document is also relevant to show physical communication 79020 IT-95-5/18-T 93 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case among Serb-controlled territories prior to the establishment of the corridor: “…in time when the corridor didn't even exist, our Air Force realised internal communication, delivery and evacuation between all of the regions in SR BiH…”

The air force aspect is particularly relevant to the Accused’s assertion that the SAO Krajina and the SAO Herzegovina were “cut off” and had “no contact” with the government. See T.27936. In tandem with a stream of communications from the ARK region to the VRS Main Staff and to Pale in the April-July 1992 period, this document goes to show that there was constant communication between the VRS Main Staff, and the Bosnian Serb leadership, with the Krajina during that period. 65ter# 16-Jun-1992 Decision on the This document relates to the No objection 10758 Establishment of the detention facility C. 18.2 and is Butmir-Ilid`a Penal and relevant to show KARAD@I]’s Correctional Facility, 16 involvement in the operation of Jun 92, signed by detention facilities in the area of KARAD@I] as President Sarajevo. 79019 IT-95-5/18-T 94 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case of the Presidency. Ref. No. 01-66/92. This document can be cross- referenced with P1127, dated 28 Presidential Decree from October 1994, Letter concerning the Official Gazette of the the accommodation of Muslim Serbian people in BiH on civilians in the KPD Butmir signed the Establishment of Kula by Captain 1st Class Dragan prison as a correctional Bulaji}, head of the Republika facility. Srpska prisoner exchange commission, addressed to the Republika Srpska Refugee Commissariat (along others). 65ter# 14-Nov-1992 Minutes of the 3rd This document is relevant as it No objection 10765 meeting of the Vogo{}a shows the Bosnian Serb leadership Serbian Municipal was aware that non-Serbs had been Assembly, on 14 forcibly removed from Vogo{}a, November 1992, that non-Serbs had been murdered handwritten and signed by and that paramilitary forces were CRNOGORAC and brought in to take part in STANI]. operations within the municipality at the direction of municipal Kraji{nik is present authorities. during this meeting says inter alia: “There are no The document also shows the Muslims around so one continued involvement of members should look for an of the Bosnian Serb leadership in Albanian to prevent that events on the local level. the Serbs quarrel with each other. …SDS This document should be cross- organised everything and referenced with 65ter#01112 79018 IT-95-5/18-T 95 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case the Army must co-operate (above) and with with P2377 dated with the party and 30 July 1992 regarding payment to authorities.” Svetozar the soldiers of the [o{o unit, under Stani} says that (Nikola) major Jovo Ostoji}’s command, for Popla{en directed him to the defence of the Serbian go get the volunteers. In municipality of Vogo{}a. September he went to bring Jovo Ostoji}. Jovo Ostoji} is further described in Zdravko Radi~i} notes 65ter#10765, 65ter#01414 and that murder of persons of 65ter#45105 (referred to in the other ethnicity happened. Sarajevo Siege Bar Table Motion). 65ter# 17-Jul-1992 Extract from the Minutes This document is relevant to Objection-- 10830 of the 18th Session of the communication and hierarchy irrelevant ARK Assembly. The between the republican authorities document reflects the and the regional authorities. attendance of ministers of the republican This is directly relevant to co- government at a meeting ordination and communication of the ARK Assembly. between the members of the Among the participants Bosnian Serb leadership (including were Velibor OSTOJI], Suboti} and Ostoji}), and minister of information of members of the ARK leadership, the Serb Republic of BiH, (including 1KK Commander and Bogdan SUBOTI], ARK Crisis Staff member Momir minister of defence of the Tali}), at a time when non-Serb Serb Republic of BiH, as were being expelled from their well as Goran HAD@I], homes, detained in brutal president of the Serb conditions, and killed in great Republic of Krajina in numbers in the ARK region. Croatia, and Milan 79017 IT-95-5/18-T 96 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case MARTI], minister of interior of the president of the Serb Republic of Krajina in Croatia. Velibor OSTOJI] and Bogdan SUBOTI] informed the Assembly members of the political and security situation in the RS. 65ter# 26-Jun-1992 Letter no. 07-240-1478, This document is relevant, inter Objection— 10831 dated 26 June 1992, alia, to the implementation of the irrelevant and stamped and signed, from order of the ARK Crisis Staff, cumulative Banja Luka prison to P00007, to remove Muslims and Banja Luka Crisis Staff Croats from all leading positions, regarding completion of and therefore to the persecutory tasks given by decision campaign against non-Serbs. no. 03-531/92, dated 22 June 1992. Source This is relevant to implementation Reference:07-240-1478. on the ground of orders issued by Banja Luka Prison the ARK Crisis Straff of orders reported to the Banja relating to the persecution of the Luka municipal Crisis non-Serb population in the ARK Staff on the region. implementation of the ARK Crisis Staff order. 65ter# 02-Mar-1992 SDS Municipal Board of This letter is relevant to the Objection—OTP 10841 Fo~a sent a letter to the hierarchical relationship between declines to disclose SDS Crisis Staff in the municipality crisis staffs and such documents Sarajevo informing about the SDS republic level, to under Rule 79016 IT-95-5/18-T 97 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case the situation in Fo~a. It is communication between the 66(B)—should not addressed to the SDS municipal and republican SDS pick those to be Crisis Staff and was organs, and central SDS control admitted received in the Office of over SDS organs in municipalities. the President, i.e., KARAD@I]. The Fo~a SDS Municipal Board states that it is “ready to carry out any order you issue.” 65ter# 17-Feb-1992 17 February 1992 This document is relevant to the IT-97-24 Objection—vague 10937 Minutes of meeting of the dissemination and implementation (Staki}): and therefore of no A Prijedor SDS Municipal of Variant A/B. SK12a/b probative value Board reflecting acknowledgement and This exhibit is relevant to the implementation of the implementation of the second stage second level by of Variant A/B. The document KARAD@I] at the 14 reflects the President of the SDS February 1992 Deputies Municipal Board briefing on the Club meeting. meeting held in Sarajevo (see P00012, the transcript of the 14th February 1992 meeting at the Holiday Inn in Sarajevo at which Karad`i} activates the second level. “That is why we called you today, to intensify, to introduce the “second level” and to intensify the functioning of the Government at any cost and on every single millimetre of our territory.”, p. 24) 79015 IT-95-5/18-T 98 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case including that President Karad`i} was the main speaker and that it was necessary to activate the second stage of the position stated by the SDS BiH Main Board, i.e. Variant A/B.

The document should be read in conjunction with the two documents which show that the first stage of Variant A/B implemented. See Exhibit P02595 (Minutes of the Meeting of the Prijedor Municipal Board of the SDS on 27 December 1991) which notes that instructions had been forwarded to the Prijedor SDS Municipal Board by the Assembly of the Serbian People of Bosnia and Herzegovina, that two versions exist and that only the second one is relevant to Prijedor Municipality. P02595 further notes that “all the items in sections A and B of version II” have been read and Simo MI[KOVI], President of the Prijedor SDS Municipal Board, has explained what had been done so far with respect to the instructions. See 79014 IT-95-5/18-T 99 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case also, 65ter#10938 (Meeting of the Representatives of the Prijedor Municipality Sector /?or Sectors/ for Military Matters) (below), for an more detailed explication of the Instructions received from the RS Assembly. 65ter# Undated Meeting of the This document is relevant to show Objection— 10938 Representatives of the the acknowledgement and irrelevant due to Prijedor Municipality implementation of Variant A/B lack of date Sector /?or Sectors/ for Instructions in Prijedor Military Matters. municipality. This detailed explication of the Instructions is In the introductory part of also related to Exhibit P02595. the minutes it states that Simo MI[KOVI], The absence of a date is a matter of President of the Prijedor weight, not admissibility. The SDS Municipal Board document is clearly relevant to the “opened the meeting with implementation of the Variant A a presentation of the and B instructions. The references Instruction which had in the document noted in the come from the Assembly column to the left, as well as the of the Serbian People in reference to the first stage of Bosnia and Herzegovina”. preparations and to the second It also states that “though stage, which would involve there were so many other activating the first stage, leave organisational matters to little doubt that this document is address, organizing the referring to Variant A and B. defence was very important; and that the 79013 IT-95-5/18-T 100 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case establishment of a Crisis Staff and a Defence Secretariat were the purpose of this meeting”. The agenda of the meeting included items such as introduction of around-the-clock duty and uninterrupted communication to create conditions for daily contacts with local boards; establish daily meetings of the SDS Secretariat to monitor the developments on the ground; the Municipal Boards to appoint a Crisis Staff; and other activities. 65ter# 30-Apr-1992 Dispatch from the This dispatch is relevant to RS No objection 10940 Prijedor SJB to the Banja MUP participation in the take over Luka CSB signed by of Prijedor and coordination Simo DRLJA^A. Drlja~a, between Serb municipal authorities chief of the SJB Prijedor, and the RS MUP in the takeover. informed his superiors in the Security Service Centre in Banja Luka that, among other things, “In accordance with the conclusions of the 79012 IT-95-5/18-T 101 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case Executive Board of the Serbian Assembly of Prijedor municipality, at 0400 hours in the municipality control was seized over SJBs and all major facilities.” 65ter# 21-Jun-1992 List of workers providing This document is relevant to RS IT-97-24 Objection— 10942 security to the Omarska MUP/VRS cooperation in the (Staki}): S379 irrelevant and Collection Centre who functioning of Omarska detention cumulative need to be issued special facility (Schedule C.20.2). passes, stating that police of the “war-time police This document, signed by @eljko station Omarska”, Mejaki} (See P. 3528; T19859 for provided security for the evidence of his authority at Omarska detention Omarka and Trnopolje) is relevant facility and that members to RS MUP control of access to of the Army assisted Omarska, and to RS MUP/VRS co- them. operation in the functioning of Omarska, at at time when non-Serb were detained in Omarska in brutal conditions, and many were killed there. 65ter# 28-Jul-1992 List related to the This document is relevant to the No objection 10944 Omarska collection killing of Omarska detainees Centre with 176 names of (Scheduled Incident B.15.2) A persons in the “1st number of the names of the people category.” listed in this document as being in Omarska as persons of the first category appear in the list of 79011 IT-95-5/18-T 102 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case exhumed and identified persons (Exhibit P04853) among those victims who have been exhumed from mass graves in Prijedor area. The names under item 3, 4, 6, 44, 45, 46, 48, 49, 57, 58, 61, 62, 63, 64, 65, 66, 67, 68, 70, 71, 72, 73, 74, 76, 84, 98, 99, 110, 120, 121, 123, 130, 131, 133, 134, 137, 139, 142, 155, 163, 165, 169, 170, and 174 in this document appear in Exhibit P04853 as person who have been exhumed and identified. 65ter# 19-May-1993 Classified No. 15/93. This document is relevant to the No objection 11046 Memo from Slobodan scale of the forcible removal and DAKI], the Assistant other crimes against non-Serbs in Commander for Civilian Klju~, as well as the Affairs of Military Post contemporaneous collection and 7286 on the current and reporting of this information situation in Klju~ by military authorities. municipality sent to the 1KK Command, Military Post 7235, and the President of the Klju~ Municipal Assembly. The report includes a section titled “On the Number and Location of Muslims” which states, among other things: “it should be noted 79010 IT-95-5/18-T 103 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case that 16,204 out of the total population of 17,714 residents of Muslim religion moved out of the area of the Municipality of Klju~” and “In five out of ten local communities in the area of Klju there are no Muslims or non- Serb residents left”. 65ter# 02-Jul-1993 Communication of the This document is relevant to Objection-- 11169 Drina Corps Command KARAD@I]'s role as Supreme cumulative dated 02/07/1993 for Commander, and his close contacts military commanders to with VRS officers in the field. convene for a meeting chaired by President KARAD@I]. Milenko @ivanovi}, ordered his subordinate commanders to come to the Corps command post for a meeting “without fail” as the meeting would be personally chaired by KARAD@I]. 65ter# Undated Analysis of the execution The document is relevant to the No objection 11220 of combat operations in implementation and results of the operation encoded operations of the Drina Corps in Udar /Strike/ Eastern Bosnia by April 1993 in summarizing the results furtherance of Directive 4 79009 IT-95-5/18-T 104 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case of the operation: “With (P00976). Operation Udar, the liberation of the Serbian territories in the central Podrinje area was completed, while the enemy was squeezed into enclaves whose dimensions were determined with the engagement of UN forces”. “The enclaves remained relatively far away from the front line and completely separated from each other (the enclaves of Srebrenica, @epa and Gora`de).” 65ter# 18-Jun-1992 Minutes of a meeting of This document shows the No objection 11227 the Pale Municipal cooperation of the civilian and Assembly of the Serbian military organs. It is also relevant Republic of Bosnia and to the removal of non-Serbs from Herzegovina, typesigned the Pale municipality. by STAR^EVI]. The context within which this The agenda for this document was issued is found in meeting includes: the the Amalgamated Statement of security situation on the Sulejman ^rn~alo, P.733, as well territory of Pale as P973 pp.24-27. municipality (with 79008 IT-95-5/18-T 105 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case briefings by Lt. Col Radislav Krsti} and Chief Malko Koroman); the issue of Muslims moving out of the territory of the municipality and activities involved; a reshuffling of the municipality executive committee. A working group tasked with formulating a draft decision on the moving out of Muslims and Croat is referred to. One attendee of the meeting expressed the view that all those who had found and signed exchange contracts should be allowed to leave. 65ter# 19-Jun-1992 Decision of the Pale This document is relevant to the No objection 11228 Assembly, stamped and removal of non-Serbs from the Pale signed by STAR^EVI]. municipality. It implements the decisions taken during the Referring to 65ter#11227, Assembly meeting depicted in item this document is a 65ter#11227 and shows that the Decision on the Change transfer is being organised and of residents of Muslim controlled by the Pale SJB. and Croat citizens, noting 79007 IT-95-5/18-T 106 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case that non-Serbs may The context within which this change their residence document was issued is found in with the agreement and the Amalgamated Statement of permission of the SJB. Sulejman ^rn~alo, P.733, as well The SJB is put in charge as P973 pp.24-27. of compiling a list of all persons wishing to change their place of residence, certifying it with the Municipal Assembly and compiling a list of property owned by those persons. The SJB is charged with the security of the transfer. 65ter# 22-Jun-1992 Skupstina opstina Pale, This document is relevant to the Objection—should 11229 Handwritten list of removal of non-Serbs from the Pale have been names, signed. municipality and is associated with presented with the the previous items 65ter#11227 evidence of This document bears the and 65ter#11228 and shows that Crnjalo stamp of the Municipality the decision taken were executed. of Pale, Socialist Republic of BiH. It is The context within which this described as a request document was issued is found in made by twenty-five the Amalgamated Statement of Muslims to be able to Sulejman ^rn~alo, P.733, as well move temporarily from as P973 pp.24-27. Pale to Sarajevo. 65ter# 09-Jan-1994 Transcript of the 9 This document is relevant to the No objection 11276 January 1994 Ceremonial dissemination of KARAD@I]’s 79006 IT-95-5/18-T 107 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case Session of the RS anti-Muslim views, especially his Assembly. This session views on the existential threat that includes a KARAD@I] Bosnian Muslims posed to Bosnian speech, in which he Serbs. referred to the existential It is also relevant to KARAD@I]’s threat that Bosnian rewarding of individuals involved Muslims posed to in crimes, and shows the alignment Bosnian Serbs. For of the news organizations Glas example: Srpski and SNRA with the • “…ancient danger Bosnian Serb leadership. posed by the toxic, all-destructive Islamic This record was inadvertently octopus”; omitted from appendix A to the • “Allegations … “Prosecution Bar Table Motion for that this war is not a the Admission of Bosnian Serb religious one, are not Assembly Records”, filed on 12 true. The wars of July 2010. On 16 July 2010, the 1914, 1941, and 1991, Accused filed the “Joinder in were and remain Prosecution Bar Table Motion – above all, wars for the Assembly Sessions”, in which he extermination of the joined in that motion and requested Orthodox the admission into evidence of the population. …₣Musli documents listed in Appendix A to ms still participated in the motion. The Prosecution has the genocide against discussed this matter with the the Serbs, lead Defence, which agrees that this exclusively by assembly session should have been religious reasons.”; one of those records listed in that • “Preparations for appendix, whose admission was requested by both parties. 79005 IT-95-5/18-T 108 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case the new genocide were not a secret. Almost all Bosnia and Herzegovina newspapers, especially the new ones, with Islamic editorship, are full of proof that the plan for the destruction of Serbs is made and that it will be executed.”

The Session also records the distribution of awards to individuals selected by KARAD@I], a number of whom were involved in events and crimes relevant to the Indictment, including: Jovan Tintor, Miroslav Deronji}, Branko Gruji}, Stanislav Gali}, Dragomir Milo{evic, Milenko @ivanovi}, and the “Panthers” of Bijeljina. The news organizations Glas Srpski and SRNA also receive awards. 79004 IT-95-5/18-T 109 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case 65ter# 07-Jul-1992 Certificate issued by the This document is relevant to the IT-00-39: Objection— 11315 Serb Crisis Staff of Fo~a Fo~a Crisis Staff’s power and P823 Tab 3 Refusal to disclose releasing an individual authority to release prisoners, and such documents detained in KP DOM (24 coordinate with the police in pursuant to Rule May to 7 July 1992) and connection, inter alia, with 66(B) indicating that he is to detentions. report to the police on a daily basis after release, dated 07 July 1992 65ter# Decision by the This document is relevant to the IT-00-39: No objection 11316 Presidency of SRBH to RS Presidency’s and KARAD@I]'s P823 Tab 5 establish Fo~a Penal and authority over prison facilities. Correctional Facility. 65ter# Analysis of combat This analysis is relevant, inter alia, No objection 11432 activities carried out to VRS activities in furtherance of under the code name of efforts to fulfil Strategic Objective Proljece-93 /Spring-93/. It #3. explains that such combat activities were carries out with the aim of liberating @epa and Gora`de (and cutting off the Kladanj- @ivinice communication). 65ter# 27-Oct-1992 Report on the situation of This document is relevant to notice IT-00-39: Objection—such 11511 human rights in the of widespread crimes by Bosnian P296 secondhand reports territory of the former Serb forces reported by the UN are unreliable, Yugoslavia, submitted by Special Rapporteur Tadeusz violate the spirit of Mr. Tadeusz MAZOWIECKI, and the pattern of Rule 92 bis, and MAZOWIECKI. It states ethnic cleansing he observed. This should not be 79003 IT-95-5/18-T 110 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case (at Eng page 3): should be read in conjunction with admitted from the “Ethnic cleansing does P01367, p. 80; P3929 and bar table without not appear to be the 65ter#13310, reflecting awareness cross examination consequence of the war of the Mazowiecki reports among but rather its goal. This the Bosnian Serb political and goal, to a large extent, has military leadership. already been achieved through killings, beatings, The relevance and probative value rape, destruction of of this exhibit is principally one of houses and threats… notice. The fact that the evidence Recent events observed in will not be subject to cross- the region of Prijedor, examination is a matter which goes Doboj and Kotor to its weight not admissibility. Varo{ prove that Serbian leaders in Bosnia and Herzegovina are not ready to desist in their plans. The Muslim and Croatian population, in the territory controlled by Serbian authorities, live under enormous pressure and terror. Hundreds of thousands of people being forced to leave their homes and to abandon their belongings in order to save their lives.” 65ter# June-1992 Report by Simo This document is relevant to SJB IT-00-39: No objection 11526 DRLJA^A Chief of Prijedor participation in the take P763.C Tab 34 79002 IT-95-5/18-T 111 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case Prijedor SJB on over of Prijedor and the detention performance in the first of Muslim and Croats. It relates to half of 1992. At Eng Scheduled Detention Facilities pages 4-5, it states that C.20.1 and 20.2. during the preparations for military operations the SJB Prijedor improved their communications system and assisted the Serb police in Slavonia. It also states that during the military operation in BiH, the SJB Prijedor took part in the interrogation of prisoners, and, (Eng page 5) that about 3000 persons passed through Omarska and 1200 through Keraterm during this reporting period. The SJB Prijedor provided “round the clock” security for the Omarska and Keraterm prisons (see Eng page 7 of the report). 65ter# 15-Jul-1992 1KK COMMAND This document is relevant to the IT-00-39: Objection-- 11539 Operational confidential implementation of the 2nd strategic P1033 cumulative number 497-4 15 July objective and to the 1KK 1992. It reports that the Command’s possession of Posavina corridor was information of large numbers of 79001 IT-95-5/18-T 112 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case completed and says that detainees in its area of “there are more than 2500 responsibility. prisoners in the POW camp of the 1KK, but the number of detainees in Omarska, Prijedor, and Trnopolje is much higher”. 65ter# 27-Jun-1992 Press Report from This article is relevant to Objection—news 11863 TANJUG recording a KARAD@I]’s approval of the reports are not message from conduct of VRS soldiers and admissible from KARAD@I] stating, officers, the dissemination of his the bar table “You are that glorious assertions that Muslims intended army that's realizing genocide against the Serbs, his Serbian national dreams view that the army was engaging in by defending the people acts to defend the Serb people from from genocide, defending genocide, and his position that his the Serbian territories, forceswere acting to protect Europe defending our physical against an Islamic incursion. and spiritual survival. (...) I want you to continue guarding our borders, and by doing so you are guarding the borders of Christianity and peace in Europe.” 65ter# 22-May-1995 Der Spiegel Interview This interview is relevant to ethnic Objection—news 12073 with KARAD@I] in separation and the removal of reports are not which he explained that Muslims from territories claimed admissible from the Serbs do not want any by the Bosnian Serbs that the bar table 79000 IT-95-5/18-T 113 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case more territory than they previously contained sizeable already have (70%) numbers of Muslims. because “we don't want to enlarge our state only to have a Muslim minority in it. This would again cause unrest, in five years we would have the next war.” 65ter# 15-Dec-1992 East-Bosnian Corps letter This document shows the transfer Objection-- 13154 No.14-12/92 to the of prisoners through the various irrelevant “Kula” Prison, Sarajevo, detention facilities run by the regarding the dispatch of Bosnian Serb military and the prisoners, stamped and involvement of the top military signed. leadership in such matters.

This letter from the Chief The document also relates to the of Staff of the East Bosnia detention faciliaties B.1.2, B.2.1 Corps informs the “Kula” and B.18.2. Prison that pursuant to an order of the VRS Main This document can be linked with Staff they will be the testimony of Masovi} at dispatching 132 prisoners T.27281, where he refers to 500 who arrived in Batkovi} inmates who were transferred from from Manja~a on Manja~a to Batkovi}, when December 1992. Manja~a was closed, and ultimately went to Kula.

This is clearly relevant to the operational control of the VRS 78999 IT-95-5/18-T 114 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case Main Staff over detention facilities where thousands of non-Serbs were detained in brutal conditions and mistreated, in this case Batkovi}, Manja~a and Kula prison in Sarajevo. 65ter# 8-Dec-1992 Glas Srpski article This is relevant to the BSL’s Objection—news 13310 interview with Momcilo awareness of the Mazowiecki reports are not Krajisnik entitled report cited above. admissible from “European “No” to the bar table Islam,” in which Krajisnik is asked about the Mazowiecki report and states that he would not have expected a former Prime Minister to be so partial and that Elie Wiesel, unlike Mazowiecki, would not allow himself to be “bribed,” and that Mazowiecki wrote a report that was ordered by someone and was not honest. 65ter# 20-Feb-1992 SDS Executive This proclamation is relevant to the No objection 13317 Committee Proclamation dissemination of republic level No.502-02/02 to the SDS instructions to municipal SDS Serbian People delivered bodies. It also reflects SDS to Municipal Boards dissemination of material intended 78998 IT-95-5/18-T 115 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case to engender fear of Muslims among Serbs. 65ter# 26-Jul-1993 RS Presidential Decree This decree is relevant to Objection— 13351 01-188/93 on promotion KARAD@I]'s command and cumulative and of Col Milenko control and his exercise of his irrelevant ZIVANOVIC to the rank authority as Supreme Commander of Maj Gen, type-signed to promote VRS officers, and his Dr Radovan KARAD@I], promotion and commendation of verified by Lt Col Milenko @ivanovi}, commander of Radenko JOVICIC. the Drina Corps., involved in the implementation of Directive 4. 65ter# 28-Jun-1994 RS Presidential Decree This decree is relevant to Objection— 13360 01-1275/94 on promotion KARAD@I]'s command and cumulative and of MILOVANOVIC, control and exercise of his irrelevant Milan GVERO, Zdravko authority as Supreme Commander TOLIMIR and others, to promote VRS officers. type-signed Dr Radovan KARAD@I] and verified by Lt Col Dane MARIC. 65ter# 24-Jul-1992 RS Presidential decision This decision is relevant to the No objection 13373 01-355/92 on existence of a functioning system appointment of VRS of military discipline and the Main Staff military ability to punish crimes committed disciplinary courts judges during the conflict. and prosecutors, signed by Dr Radovan KARAD@I], President of the Presidency. 65ter# 12-Nov-1994 1KK dispatch No.14/47-1 This document is relevant to No objection 78997 IT-95-5/18-T 116 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case 13457 forwarding order by command and control and to the Radovan KARAD@I] communication network available and Ratko MLADI] on to and used by the leadership. introducing state of war and that, inter alia, war presidencies in the zone of responsibility are to carry out instructions from the president and government, and report to them at least once per week. 65ter# 14-Jul-1992 Session of the War This decision is relevant to the IT-02-54: No objection 13818 Presidency of Sanski discriminatory and persecutory P434.6 Most, Decision: Croatian campaign against non-Serbs and Muslim pensioners who do not have a certificate from the competent organ confirming their permanent residence in Sanski Most will not receive their pensions until further notice. 65ter# Letter from Velibor This document is relevant to links No objection 13975 OSTIJI] to Radovan between the Bosnian Serb and KARAD@I] informing Serbian leadership, planning, him about his talks with communications and propaganda. Serbian officials (Radomir Bozovic and 78996 IT-95-5/18-T 117 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case Stanko Cvijan) with aim of securing communication and information equipment and outlining proposals to set up better communication. The letter is undated, but relates to a meeting between OSTIJI] and the Republic of Serbia Prime Minister, Information Minister and Minister for Liaison with the Serbs on 3 September 1991. OSTIJI] informed KARAD@I] that he had communicated to the Serbian Prime Minister that they urgently needed military equipment for the Sarajevo areas and Samac: 80 radio sets, one transmitter for the Krajina (TV Banja Luka) and another for Javnost TV, and mobile television equipment for municipal radio stations, with the result that it was 78995 IT-95-5/18-T 118 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case concluded that the equipment woud be released with the assistance of the Republic of Serbia MUP. 65ter# 23-May-1992 Monologue of Radovan This statement by KARAD@I] is No objection 13983 KARAD@I] Titled relevant to KARAD@I]’s anti "There is no more Muslim and Croat views and Bosnia" published in the dissemination of such positions, the magazine "Duga" on 23 division of Sarajevo, and the May 1992 recorded by creation of the Serbian Republic of Miroslav To{i}. BiH. KARAD@I] claimed that Serbs, Croats and Muslims lived together either under occupation or dictatorship, but never under free will. He claimed that BiH did not exist anymore, and that the only mechanism that works on the territory of BiH is the Serbian Republic of BiH. KARAD@I] stated that he is based in Pale but visits Vraca, Ilidza and Vogosca. KARAD@I] presented the Serbs as the victims of Croats and 78994 IT-95-5/18-T 119 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case Muslims since the time of the Turkish and later Austria-Hungarian empires occupation, through WWI and WWII and also during the Communist Yugoslavia. KARAD@I] also stated that Sarajevo should be divided into Serbian and Muslim parts. 65ter# 15-Feb-1993 RS signed and stamped This decree is relevant to failure ot No objection 14221 Presidential Decree 01- punish and instead promote or 21-48 on promotion of reward those involved in crimes Rajko KUSIC to the rank (Rajko KUSIC earlier involved in of Capt 1st Class, signed crimes in Rogatica – see, e.g., AF by Dr Radovan 2506-2511). KARAD@I], verified by Col Stojan MALCIC. 65ter# 27-Aug-1992 Prijedor Municipal In this document the Prijedor IT-97-24 Objection-- 14633 Assembly, at its session Municipal Assembly ratified all (Staki}): S181 irrelevant held on 27 August 1992, acts (decisions, orders, rulings and adopted a Decision to conclusions) adopted by the Ratify Acts Adopted by Prijedor Crisis Staff or War the Crisis Staff of the Presidency between 29 May and 24 Municipality or the War July 1992. This document, Presidency between 29 ratifying all acts (including the May and 24 July 1992 establishment and maintenance of (no. 01-023-72/92), No. Omarska camp) is relevant to the 120 in Official Gazette of existence of a discriminatory and 78993 IT-95-5/18-T 120 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case the Municipality of persecutory policy against non- Prijedor, No. 3/92 Serbs underlying these acts. published on 31 August 1992. This edition of the Gazette of Prijedor municipality shows co- operation between the Crisis Staff, RS MUP and VRS, in relation to municipal level events in Prijedor municipality during a period that non-Serbs were being expelled from the municipality, and held in detention facilities in brutal conditions. It is also relevant to control over Omarska (P02460). 65ter# 21-May-1992 Discharge letter dated 21 This document is relevant to Fo~a Objection— 14925 May 1992 and issued by Crisis Staff involvement in Refusal to disclose Crisis Staff of Serbian detentions in KP Dom Fo~a. such documents Municipality Fo~a to Enes under Rule 66(B) ZUKO who was taken prisoner during the war operations by Serbian units of Fo~a TO and detained in Fo~a KPD /Penal and correctional facility/ 65ter# 07-May-1992 Discharge letter dated 7 This document is relevant to Fo~a Objection— 14934 May 1992 and issued by Crisis Staff involvement in Refusal to disclose Crisis Staff of Serbian detentions in KP Dom Fo~a. such documents Municipality Fo~a to under Rule 66(B) Dzevad DEDOVIC who 78992 IT-95-5/18-T 121 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case was taken prisoner during the war operations by Serbian units of Fo~a TO and detained in Fo~a KPD /Penal and correctional facility/ 65ter# 24-Jul-1992 Budapest Nepszabadsag This interview is relevant to Objection---news 15073 interview dated 24 July KARAD@I]’s anti-Muslim and reports are 1992, titled “KARAD@I] Croat views and his dissemination inadmissible from Views Serbian Position.” of propaganda. the bar table KARAD@I] characterized the war as “a religious and ethnic war” and stated that the Bosnian Serbs have to defend their territory because “The Serbs are endangered because the Croat-Muslim coalition started a genocide on us” and the Muslims “want to banish all Serbs from Bosnia so that they can rule.” KARAD@I] also denied that the Serb side was committing crimes, including denying that the Serb side was maintaining any prisoner camps. He claimed that the Muslims 78991 IT-95-5/18-T 122 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case and Croats are feeding Serbian children to lions, and that Serbs in Gorazde had been tortured raped and murdered. 65ter# 31-Oct-1992 Prijedor Declaration on This declaration is relevant to the Objection— 15273 the Unification of the close relationship between RS and irrelevant RSK and RS type signed RSK leaders, their cooperation and by RS Assembly similarity of goals, and their joint President Momcilo objective of uniting territories KRAJISNIK and Mile controlled by ethnic Serbs. The PASPALJ. goal of reunification of “Serb” territories was seen as necessitating territorial contiguity and compactness and was reflected in strategic objectives number two and three, for example.

This notes that citizens of the RS and RSK “shall have Serbian citizenship” and refers to Serbian symbols and the Serbian people. It sets out an extensive programme of co-operation in economic, educational, cultural and other areas between the RS and RSK, and notes that “All these forms of co-operation will be offered to other Serbian states”. It says that an initiative will be launched for 78990 IT-95-5/18-T 123 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case an “All-Serbian” assembly, consisting of the assemblies of the RS, RSK, and the Republics of Serbia and Montenegro. It proclaims the determination of the Serbian people in the RS and RSK to unify their state. It is relevant to show that the RS was created to be a territory for Serbs. 65ter# Plan of moral and This document is relevant to the No objection 15413 psychological activities scope of VRS propaganda and information work of activities and the cooperation in the VRS, approved by those efforts between the VRS, the Commander Lieutenant RS leadership, Serbian Orthodox General Ratko MLADI] Church and journalists. (signed and stamped). The plan sets out six objectives to be achieved through propaganda activities to be carried out by the VRS, the top RS leadership, the Serbian Orthodox Church and journalists. 65ter# 10-Jun-1992 Permission, Nr. 04- The document is relevant to the No objection 15660 638/92, Serbian assistance provided by the Zvornik Municipality of Zvornik, Serb Municipal authorities to the Branko GRUJIC, 10 Jun White Eagles, and the presence of 92 granting permission to the White Eagles in Zvornik. the White Eagles, to 78989 IT-95-5/18-T 124 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case receive fuel for a vehicle without charge. 65ter# 21-Jul-1992 KARAD@I] Decision This document is relevant to the No objection 16057 appointing a War RS Presidency’s selection of Commission in Novo municipal leaders, the identity of Sarajevo those municipal leaders, KARAD@I]’s links to the local leadership of Novo Sarajevo and to the implementation of his Decision on the Formation of War Commissions. 65ter# 23-Feb-1993 Slobodan Avlijas This document is relevant to No objection 16259 Instructions on Detention. central control by the Bosnian Serb This document, is from leadership over detention facilities the RS Assistant Minister where non-Serbs were detained. of Justice and is In particular, two of the five named addressed to five prison prison facilities are included in facilities. The document Schedule C of the indictment: KP notes that prisoners have Dom Fo~a and KP Dom Kula been held at those prison Butmir. facilities without authorization. It also notes that, at the request of the VRS, penal and correctional facilities were given to the army for detention purposes. He orders the release of persons for whom there are no detention orders. 78988 IT-95-5/18-T 125 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case 65ter# 11-Jul-1992 Milorad KRNOJELAC This document is relevant to No objection 16260 report regarding Fo~a central control by the Bosnian Serb prison, sent to Momcilo leadership over detention facilities Mandic. This document where non-Serbs were detained, in shows that in July 1992, particular KP Dom Fo~a. KPD Fo~a (Schedule B.8) held in detention 459 Muslim persons, 10 Serbs, and 47 prisoners who had been convicted and sentenced earlier (presumably pre-war.) 65ter# 01-Jul-1992 Order of 1KK Command, This is relevant to command and Objection— 17257 no. 560-1, 1 July 1992. control structures within the VRS irrelevant— This provides details of 1KK, during a time period when cumulative to the chain of command 1KK was involved in the forcible Ewan Brown within the 1KK, and removal of non-Serbs from the evidence identifies the zones of ARK region. responsibility of commanders within the The objection that this is 1KK’s AOR. cumulative is addressed in the body of the motion. This is relevant, in particular to show that the 1KK Command exercised control over its subordinate units, including the 343rd Motorized Brigade, which was active in Bosanski Novi. This brigade is also known as the 43rd Motorised Brigade and was the main unit involved in the 1992 78987 IT-95-5/18-T 126 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case attacks on Hambarine, and Kozarac and Prijedor, which involved widespread crimes against non-Serbs. Further, the references in the document to 1KK operations on the right bank of the Una is relevant to military implementation of the fourth strategic objective. 65ter# 30-Jul-1995 Obligations of The document is relevant to show No objection 17621 Commands, Units and KARAD@I]'s command and Institutions of VRS in control over the VRS. Conditions of Proclaimed State of War in RS -- Order, Main Staff of VRS Conf. No. 03/4-1826, 30 July 1995. The document references the Decision of the RS President on Declaration of the State of War No.01-1473/95 dated 28 July 1995, and RS President order strictly confidential No. 03-4- 1799 dated 29 July 1995 on mobilization of all militarily capable population. The document provides instructions to corps commands, state 78986 IT-95-5/18-T 127 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case authorities to immediately commence mobilization activities, raise combat readiness, cancel leaves, ban movement of civilian population and evacuation of materials out of war zones, ban entry of media and journalists into war zones without special agreement of the VRS Press Centre, prevent dissemination of rumors and profiteering, civilians must surrender weapons, etc. Criminal charges will be raised against those who violate this order. 65ter# 07-AUG-1992 1KK regular combat This is relevant to 1KK Objection—should 17808 report to the VRS Main participation in the transport and have been used Staff noting the transport detention of non-Serb detainees with KDZ163 of 1,460 POWs from detained in brutal conditions in the Omarska to Manja~a. Omarska camp and in Manja~a camp, to reporting from the Corps command level to the VRS Main Staff on matters relating to the detention of non-Serb detainees, to Bosnian Serb leadership control over the camp system, and to the use of “prisoners of war” as a term 78985 IT-95-5/18-T 128 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case to refer to non-Serb civilians detained in camps. 65ter# 07-Aug-1992 1KK regular combat This is relevant to co-ordination Objection—should 17808 report dated 07 August between the 1KK and the camp have been used 1992 which states that administration at Omarska and with KDZ163 "1,460 war prisoners have Manja~a and to the detention of been transferred from non-Serb civilians. Omarska to Manja~a". 65ter# 29-May-1992 Prijedor Crisis Staff This document is relevant to the IT-99-36: Objection— 17820 Decision No. 02-111- transformation of the Serb TO P1601/S113, irrelevant and 110/92 of 29-May-92 units, formed by Crisis Staffs, into IT-97-24 cumulative which incorporated the the VRS. (Staki}): S113 Prijedor Serbian TO into the Regional Command This decision, issued by Staki}, not only clearly illustrates that the Serb TO units became VRS units, but is also relevant to Crisis Staff/VRS co-operation at the municipal level. 65ter# 24-Sep-1992 1KK communication to This is relevant to VRS control Objection—should 17868 Manja~a camp for the over Manja~a camp, and to the use have been used engagement of 114 of non-Serb civilian detainees for with KDZ163 prisoners for labor in forced labour. various Corps Companies. 65ter# 24-Feb-1993 Duties of SDS BiH This is relevant to the role of the Objection— 17976 Members and Bodies, 04- SDS in organizing and irrelevant and 1/93, 24 February 1993. indoctrinating the Serb people for cumulative This document notes, the campaign of ethnic separation, inter alia, that the SDS and convincing the Serb population had, united, revived and that ethnic separation was 78984 IT-95-5/18-T 129 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case prepared Serbs for necessary for the Serbs’ survival. defense and foundation of a Serb state. 65ter# 06-Nov-1991 Extract from the minutes This is relevant to KARAD@I]’s No objection 18225 of the 9th session of the command and control over his ARK Assembly held at subordinates in the ARK, and his the Banja Luka Cultural control over events taken at the Centre at 1600 hours on 6 municipal level. See also P03581, November 1991. This the 26 October 1991 Sarajevo SDS states that a decision has order. been made for Radislav Brdanin, the Vice President of the ARK to notify Radovan KARAD@I] of the implementation of the conclusions adopted at the session of the assembly of the ARK. 65ter# 21-Sep-1991 Letter of instruction This is relevant to show the No objection 18244 addressed on all hierarchical nature of the SDS with municipal boards of SDS KARAD@I] on top as well as regarding the monitoring capacity to communicate with SDS of mobilization of the war at all levels police forces. KARAD@I] issued instructions to all BiH SDS Municipal Boards stating that Serbs need to respond to mobilisation as 78983 IT-95-5/18-T 130 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case if not it will lead to Muslim police and to circumstances for a civil war. 65ter# 02-Mar-1992 Crisis Staff of the Serb This document is relevant to the Objection—should 18258 People in BiH Conditions role of the SDS ,leadership in have been put to for negotiations set by the connection with the March Momcilo Mandic Crisis Staff of the Serb barricades which preceded the People in BiH 2 Mar 92. imposition of the siege of Sarajevo. It is relevant to the fifth strategic objective: to divide Sarajevo. 65ter# 23-Mar-1992 Memo signed by Karadžic This is relevant to KARAD@I]’s No objection 18268 with official seal of the contact with municipal-level SDS party and Karadžic's bodies during the period signature as President of immediately prior to the Serb SDS. KARAD@I] takeover of power in the targeted informs all municipal and municipalities. regional committees of the SDS BH to use telephone codes as much as possible and the caller should identify himself first 65ter# 21-May-1992 Order issued pursuant to This is relevant to communications Objection—should 18374 the decision of the within the RS MUP, to the have been used Presidency of the Serb implementation of decisions taken with Djeric. Republic of BiH by the RS presidency at the regarding mobilization. municipal level, to RS Signed by RS prime MUP/VRS/Crisis Staffs co- 78982 IT-95-5/18-T 131 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case minister Branko Djeric ordination at a time when non- and stamped. It prohibits Serbs were being detained and men liable for military killed in municipalities which had service from leaving the been taken over by the Bosnian Serb Republic, and Serb authorities. It is also relevant provides that the military to the use of failure to comply with police, the army and the the call-up as a pretext for the RS MUP will take detention and mistreatment of non- measures against all men Serb men. liable for military service who fail to comply. It also requires the municipal crisis staffs to forward the order to “competent organs in the local communes”, and the MUP to forward it to all SJBs in the municipalities. 65ter# 29-Sep-1992 Report on activities of This is relevant to RS MUP/VRS IT-97-24 Objection— 18434 Prijedor SJB in third co-ordination during a ordination at (Staki}): S266 irrelevant and trimester of 1992, i.e. a time when non-Serbs were being cumulative from 01 July through 30 detained, forcibly transferred and September 1992. It notes killed in Prijedor in great numbers. the disbanding of the It is also relevant to control over Keraterm and Omarska Keraterm and Omarska camps. camps, deployment of police to the front lines, In particular, this document’s mopping up the terrain observation that “the disbanding of together with members of the Keraterm and Omarska 78981 IT-95-5/18-T 132 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case the Serbian army, as well reception centres decreased the as giving specific volume of police tasks”, and that accounts of activities they that 187 police officers secured participated in during this Omarska and Keraterm, are period. relevant to RS MUP control over those locations. It also notes that Trnopolje remains in operation, and that it holds “women and children” and “large groups of Muslims” of military-age previously detained at Omarska and Keraterm. It further notes that police officers participated as escorts for “several convoys” of these detainees to Skender Vakuf and Bugonjo; this is directly relevant to RS MUP participation in expelling Muslims from Prijedor municipality and to the role of Omarska, Keraterm and Trnopolje as detention facilities for non-Serbs pending the forcible transfer out of Serb-claimed territory of those who survived. 65ter# 30-Apr-1993 Report on activities of This document is relevant to the No objection 18455 National Security Service continuous exchange of within the period from information between different 01-Apr-92 to 31-Dec-92, Bosnian Serb organs, in particular signed by Dragan KIJAC within the RS MUP, from the RS and stamped. This is a MUP to VRS (1085 reports sent to 78980 IT-95-5/18-T 133 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case report sent to the RS the VRS), and from RS MUP to MUP headquarters, which the Bosnian Serb leadership and to was then in Bijeljina, the Serb authorities at the summarizing the work of municipal level (it notes that 200 the RS MUP national reports sent to republican and security branch during the municipal state organs). It is also period 1 April to 31 relevant to RS MUP participation December 1992. It in the detention and interrogation records that RS MUP of large numbers non-Serb national security civilians, and to co-operation personnel conducted between the RS MUP and the MUP “around 15,200” of Serbia. interviews and that “more than 6,000 people were cautioned due to various forms of activity contrary to the interests of the Serbian people and Republika Srpska”. It also notes that “continuous exchanges of information with the intelligence and security organs of the VRS were especially fruitful, with, among other things, 1,085 written reports sent to them. A significant quantity of information was exchanged with the SDB 78979 IT-95-5/18-T 134 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case of the Ministries of the Interior of the Republics of Serbia and Montenegro”. 65ter# 11-Dec-1991 Request from the This is relevant to the role of the No objection 18683 Assembly of the Serb JNA as a Serb army aimed at People in Bosnia and defending the interests of the Serbs Herzegovina signed by of BiH. It is also relevant to co- the President of the ordination between the Bosnian Assembly, Momcilo Serb leadership and the JNA in the KRAJISNIK, and period following the Serb stamped. This is a request plebiscite and prior to the Serb to the JNA for defense of takeover of power in targeted the territory of Bosnia and municipalities. Herzegovina as a constituent part of Yugoslavia 65ter# 07-Sep-1992 Official Gazette of the This is relevant to the use of the No objection 18700 Bosnian Serb republic, concept of territories where A Volume I (1992), Issue genocide occurred in the Second 14. “Declaration on the World War as ethnically Serb, thus Constitutional and justifying the Serbs’ vast territorial Political Arrangement of claims. It is also relevant to the use the State", adopted by the of the threat of further genocide Assembly of the Serbian against the Serbs as a propaganda Republic of BiH on 12 mechanism. August 1992.

Declaration about 78978 IT-95-5/18-T 135 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case establishment of RS which would include the areas populated by the Serbs as well as the areas where the Serbs were subjected to genocide. 65ter# 24-Oct-1992 Report from RS MUP This is relevant to organized No objection 18835 SJB Klju~ on exodus of expulsion of Muslims and Croats people from Klju~ from Klju~ municipality by Municipality, signed and Bosnian Serb authorities and to the stamped. It refers to an determination of the authorities to inspection of Red Cross ensure that all non-Serbs are lists of “organized removed. It is specifically relevant convoys transporting to RS MUP involvement in that citizens of Muslim and forcible transfer. Croatian ethnicities” and says that, on the basis of It is also relevant to detention those lists, 3,472 citizens facility 15.1, the SJB facility in “have left Municipality of Klju~. Klju~”. It goes on to say that these lists are not The reference to the security at the quite up to date, and, on primary school is relevant to RS the basis of further lists MUP control over detention held by transport facility C.15.2, a primary school in companies to which the Klju~. Red Cross did not have access, “it can be said with certainty that a total of around 8,893 citizens of Muslim and Croatian 78977 IT-95-5/18-T 136 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case ethnicities have left this Municipality”. The report then identifies, with specificity, the areas where Muslims and Croats still reside in the municipality, identifying precisely where they live, and how many remain: 2,033 Muslims and 19 Croats, excluding one settlement “where there are also some military-age citizens who haven’t left our Municipality”. In its final paragraph it sates that “as far as refreshing security at the Primary School is concerned, this assignment has been taken over by the commander of this police station”. 65ter# 30-Jul-1992 Conclusion of the This is relevant to the expulsion of No objection 18921 Executive Committee of non-Serbs from Sanski Most; to the the Assembly of Sanski use in documents issued by Most Municipality with Bosnian Serb authorities of terms regard to the security such as “activist” and “enemy” to situation in the Sanski refer to non-Serb civilians; to the Most Municipality and policy of explusion of non-Serbs 78976 IT-95-5/18-T 137 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case further reorganisation and from Sanski Most; to co-ordination restructuring. Signed and between Bosnian Serb regional, stamped. It states that “the municipal and local bodies in enemy has been disarmed respect of the detention of non- in about 60% (sic) while Serbs and their expulsion; to co- there still remain several ordination between municipal large and small groups of bodies, the RS MUP and the VRS unarmed activists in” and in securing the removal of non- goes on to name the areas. Serbs from areas targeted for It notes: “About 18,000 inclusion in the Bosnian Serb state. Muslims and Croats still remain on the territory of the municipality of Sanski Most and it is necessary to organize their voluntary move in order to avoid danger to the Serb population”. The Executive Committee recommends that they make a strong request to the ARK government that prisons be set up. It also makes several observations intended to improve co-ordination at checkpoints between police and military police and refers to the need to set up local authorities in 78975 IT-95-5/18-T 138 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case local communes and in villages. 65ter# 21-Oct-1992 Conclusion of the This is relevant to the involvement No objection 18923 Executive Committee of of municipal executive committees the Assembly of Sanski and assemblies in respect of the Most Municipality with expulsion of non-Serbs, in this regard to adoption of the instance in Sanski Most. report on relocation, migration and settling down of the population in Sanski Most. Signed. 65ter# 26-Nov-1992 Conclusion of the This is relevant to the involvement No objection 18924 Executive Committee of of municipal executive committees the Assembly of Sanski and assemblies in respect of the Most Municipality on expulsion of non-Serbs, in this making the lists of Croats instance in Sanski Most. It is also and Muslims who are not relevant to the practice of depriving able to pay fees when non-Serbs of their property prior to leaving the municipality their expulsion. so that they would be exempt from it. 65ter# 30-Oct-1995 VRS Main Staff Internal This is relevant to KARAD@I]'s Objection—should 18946 Memo no 06/40-26 to 1st command and control over the have been put to and 2nd KK, SRK, IBK, VRS and to his control over General HK, V, PVO; signed by detention facilities on Bosnian Serb Milovanovic Maj Gen Manojlo territory. MILOVANOVI]; pursuant to instructions (enclosed) of the RS 78974 IT-95-5/18-T 139 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case Presidency, no. 01- 1250/92 dated 22-Oct-95. The VRS Main Staff instructs the Corps Commands to allow ICRC members who have written authorization of KARAD@I] free access to prisons and prisoners. The order is based on the Republika Srpska Presidency's document no. 01-1250/912 dated 22 October 1995 65ter# 01-Aug-1994 Letter from KARADŽIC This is relevant to KARAD@I]’s No objection 18963 to RS MUP, No. 01- command and control over the 1530/94, dated 1 August VRS and over the RS MUP. It is 1994. In this order, also relevant to RS MUP/VRS co- KARAD@I] states that ordination. It also shows his due to increasingly determination and material ability frequent raids on to take steps to ensure the Republika Srpska protection of Serb civilians, and territory by sabotage - not non-Serb civilians. groups from Srebrenica, Žepa and Goražde, he orders that specific steps be taken with VRS units. He also emphasizes that must do all we can to protect the “Serbian 78973 IT-95-5/18-T 140 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case civilians” in villages and cities as well as traffic throughout our territory. It is therefore necessary for the MUP to also submit a plan of measures and actions with particular focus on forming special patrols for setting ambushes and encountering STG groups on likely routes they would take. These actions will be co-ordinated with organs of the VRS Main Staff. It is signed by KARAD@I] and stamped. 65ter# 27-Apr-92 Request for personnel for This document is relevant to the IT-02-54: Objection— 20421 the Headquarters of alignment between the JNA and the P464.6 irrelevant and Territorial Defence, to the Bosnian Serbs and the assistance – cumulative Command of the Second in this case personnel assistance – Military District, signed provided by the JNA to the by Bogdan Suboti}. Bosnian Serbs. In this request, the RS Defence Minister Bogdan As the objection notes, there has Suboti} requested the been other evidence introduced JNA 2nd Military District regarding this issue, which alone to replenish “the most attests to its relevance. Evidence vital personnel in the TO which reflects the JNA and FRY 78972 IT-95-5/18-T 141 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case of the Serbian Republic of alignment with the Bosnian Serbs BiH” referring to “a is relevant, inter alia, to: (a) the reached agreement and strength of the Bosnian Serb forces the promise from at the outset of the conflict and Belgrade” their ability to conduct forcible takeovers and the willingness of the leadership to undertake such actions;and (b) actions taken by the Bosnian Serb leadership in support of and consistent with their determination to ensure ethnic separation. This document is further relevant to the relationship and links between the Bosnian Serb leadership and the TO of the Serbian Republic of BiH, i.e. local Bosnian Serb forces. 65ter# 26-Mar-92 Shortened minutes of the These minutes are relevant to the IT-99-36: No objection 21288 4th Assembly of the hierarchical structure of the SDS P1601/S100 Serbian people of Prijedor and RS and to the dissemination of and P1551; municipality. The agenda information from the central SDS items included a report by and RS organs to Serb municipal IT-97-24 the SDS Municipal Board organs both generally (in relation (Staki}): S100 President on the SDS to the meeting between the SDS Main Board meeting and Main Board and presidents of SDS a report on the session of municipal boards) and specifically the RS Assembly. The to municipal organs in Prijedor. minutes state that Milomir Staki} reported on the meeting between the SDS 78971 IT-95-5/18-T 142 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case Main Board and presidents of the SDS municipal boards. 65ter# 15-May-94 Official letter No. 01- This letter is relevant to the No objection 21309 936/94 addressed to relationship between the Bosnian General Momcilo Serb military leadership (including PERI[I] personally, Karad`i} personally) and the VJ signed by Radovan leadership. It is also relevant to Radovan KARAD@I]. In Karad`i}’s knowledge of, and this letter, Karad`i} involvement, in military matters described the difficult such as logistical issues, as well as situation faced by the to Karad`i}’s attitude toward the VRS in light of the Bosnian Muslims, whom he cessation of hostilities claimed posed a dire theat to the between the Muslims and Bosnian Serbs. Croats. He described VRS shortages of ammunition and fuel and stated that it was the goal of the Muslims to expel the Serbs from Bosnia and then “move on to Sand`ak.” 65ter# 30-Dec-1993 RS Official Gazette, No. This item illustrates the control Objection-- 21598 27, p. 1120. Decision on over the media by the Bosnian Serb irrelevant Proclaiming the Daily leadership. The document is Newspaper Glas Srpski relevant to the participation of the the Daily Newspaper of Bosnian Serb leadership in the the RS and the RSK. This dissemination of propaganda. is Republika Srpska 78970 IT-95-5/18-T 143 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case Assembly decision, 30 December 1993. The This document is relevant publisher is obliged to specifically to control of the adjust the contents, Bosnian Serb leadership over the editorial policy and daily newspaper Glas Srpski, one distribution to the needs of several media organs under the of the Republika Srpska control of the Bosnian Serb and RSK. leadership. With other evidence of propaganda, this is relevant to show that the Bosnian Serb leadership promoted and implemented a propaganda campaign. The leadership instilled in the Serb population of Bosnia- Herzegovina ethnic hatred and fear of annihilation at the hands of Muslims and Croats. Concepts of brotherhood, unity and interethnic tolerance were deliberately debased and discredited. Muslims and Croats were vilified and dehumanized. See par. 14 (c) of the Indictment. 65ter# 13-Jun-1994 RS Official Gazette, Nr. This item illustrates the control Objection-- 21601 11, pp. 419-420. Five over the media by the Bosnian Serb irrelevant Decisions by the RS leadership. The document is National Assembly, relevant to the participation of the signed by Momcilo Bosnian Serb leadership in the KRAJISNIK, appointing dissemination of propaganda. Directors and Editors-In- 78969 IT-95-5/18-T 144 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case Chief of Serb television This document is relevant and radio. specifically to control of the Bosnian Serb leadership over Srpska televizija (Serb television), Srpski radijo (Serb radio) and Srpska radijo televizija (Serb radio and television). These were among the media organs under the control of the Bosnian Serb leadership. See comments regarding 65ter#21598 above. 65ter# 18-Apr-1992 Request for registration of This item illustrates the control IT-00-39: Objection— 21603 news agency SRNA, over the media by the Bosnian Serb P01165 irrelevant, should signed by Prime Minister leadership. The document is have been put to Branko \eri} relevant to the participation of the Djeric Bosnian Serb leadership in the dissemination of propaganda.

This document is relevant specifically to control of the Bosnian Serb leadership over SRNA, the official Bosnian Serb news agency, one of several media organs under the control of the Bosnian Serb leadership. With other evidence of propaganda, this is relevant to show that the Bosnian Serb leadership promoted and implemented a propaganda campaign. The leadership instilled 78968 IT-95-5/18-T 145 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case in the Serb population of Bosnia- Herzegovina ethnic hatred and fear of annihilation at the hands of Muslims and Croats. Concepts of brotherhood, unity and interethnic tolerance were deliberately debased and discredited. Muslims and Croats were vilified and dehumanized. See par. 14 c of the Indictment. FG 65ter# RS Official Gazette, Nr. This item illustrates the control Objection-- 21606 29, pp. 807-808. Four over the media by the Bosnian Serb irrelevant Decisions of the RS leadership. The document is National Assembly, relevant to the participation of the signed by Momcilo Bosnian Serb leadership in the KRAJISNIK, appointing dissemination of propaganda. the directors and editors- in-chief of the newspapers This document is relevant Oslobodjenje and Glas specifically to control of the srpski /Serbian Voice/. Bosnian Serb leadership over the daily newspapers Glas Srpski and No. 569: Republika Oslobodjenje, two of several Srpska Official Gazette, media organs under the control of Nr. 29, p. 807. Decision the Bosnian Serb leadership. With on Appointing the other evidence of propaganda, this General Director of NISP is relevant to show that the Oslobo|enje (Odluka o Bosnian Serb leadership promoted imenovanju generalnog and implemented a propaganda direktora NISP campaign. The leadership instilled Oslobo|enje Sarajevo). in the Serb population of Bosnia- 78967 IT-95-5/18-T 146 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case Republika Srpska Herzegovina ethnic hatred and fear Assembly decision, 24 of annihilation at the hands of November 1994, in effect Muslims and Croats. Concepts of on that day, to appoint brotherhood, unity and interethnic Predrag NIKOLIC. Legal tolerance were deliberately basis - Law on Public debased and discredited. Muslims Services. and Croats were vilified and dehumanized. See par. 14 c of the No. 570: Republika Indictment. FG Srpska Official Gazette, Nr. 29, p. 807. Decision on Appointing the Editor- In-Chief of NISP Oslobo|enje Sarajevo (Odluka o imenovanju glavnog i odgovornog urednika NISP Oslobo|enje Sarajevo). Republika Srpska Assembly decision, 24 November 1994, in effect on that day, to appoint Drazenko DJUKANOVIC. Legal basis - Law on Public Service.

No. 571: Republika Srpska Official Gazette, Nr. 29, p. 808. Decision 78966 IT-95-5/18-T 147 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case on Appointing the Acting General Director of Public Company for Information, Publishing and Graphic Activity Glas srpski Banja Luka (Odluka o imenovanju v.d. generalnog direktora Javnog preduze}a za informativnu, izdavacku i graficku delatnost Glas srpski Banja Luka). Republika Srpska Assembly decision, 24 November 1994, in effect on that day, to appoint Nenad NOVAKOVIC.

No. 572: Republika Srpska Official Gazette, Nr. 29, p. 808. Decision on Appointing the Acting Editor-In-Chief of Public Company for Information, Publishing and Graphic Activity Glas srpski Banja Luka (Odluka o imenovanju v.d. glavnog i odgovornog urednika Javnog preduze}a za 78965 IT-95-5/18-T 148 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case informativnu, izdavaku i grafiku delatnost Glas srpski Banja Luka). Republika Srpska Assembly decision, 24 November 1994, in effect on that day, to appoint Gordan MATRAK. 65ter# 30-Dec-1993 RS Official Gazette, Nr. This item illustrates the control Objection-- 21637 26, pp. 1028-1029. over the media by the Bosnian Serb irrelevant Decision of RS Assembly leadership. The document is on Founding the Public relevant to the participation of the Company Serbian Radio- Bosnian Serb leadership in the Television. This RS dissemination of propaganda. Assembly decision regulates the matters such This document is relevant as the structure, specifically to control of the competencies of Serb Bosnian Serb leadership over Serb radio and television. The Radio and Television, which was Government appoints among the media organs under the directors and editors-in- control of the Bosnian Serb chief. leadership. With other evidence of propaganda, this is relevant to show that the Bosnian Serb leadership promoted and implemented a propaganda campaign. The leadership instilled in the Serb population of Bosnia- Herzegovina ethnic hatred and fear of annihilation at the hands of 78964 IT-95-5/18-T 149 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case Muslims and Croats. Concepts of brotherhood, unity and interethnic tolerance were deliberately debased and discredited. Muslims and Croats were vilified and dehumanized. See par. 14 c of the Indictment. FG 65ter# 11-Jul-1994 RS Official Gazette, Nr. This item illustrates the control Objection-- 21676 15, p. 597. Three over the media by the Bosnian Serb irrelevant Decisions appointing (1) leadership. The document is Sonja KARAD@I] relevant to the participation of the Acting Director of the RS Bosnian Serb leadership in the International Press dissemination of propaganda. Centre; (2) Goran MIJATOVIC Acting This document is relevant to Director of Srpski glas control of the Bosnian Serb Banja Luka; and (3) leadership over the daily Predrag NIKOLIC Acting newspapers Glas Srpski and Director of NISRO Oslobodjenje, in both Sarajevo and Oslobodjenje Sarajevo in Banja Luka. This also shows that the Accused’s daughter, Sonja, was the acting president of the RS international press centre. See par. 14 c of the Indictment. FG 65ter# 20-Feb-1995 RS Official Gazette, Nr. This item illustrates the control Objection-- 21690 2, p. 12. Decision on over the media by the Bosnian Serb irrelevant Appointing Members and leadership. The document is the President of the relevant to the participation of the Committee for Program Bosnian Serb leadership in the Orientation and Editorial dissemination of propaganda. 78963 IT-95-5/18-T 150 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case Policy of Public Media in the Information Field. In This document is relevant this decision, the RS specifically to the alignment of Assembly appoints as editorial policy by the Bosnian members of this Serb leadership and editorial co- committee: ordination over the organs Glas Srpski, Oslobodjenje, Javnost, Serb 1.Aleksa BUHA, MP and Television and SRNA which were gov. minister; among the media organs under the 2.Dragan DAVIDOVIC, control of the Bosnian Serb gov. leadership. See par. 14 c of the minister; Indictment. FG 3. Ljubomir ZUKOVIC, gov, minister; 4. Miroslav TOHOLJ, gov. minister; 5. Momilo GOLIJANIN, MP; 6. Savo KNEZEVIC, MP; 7. Vojo KUPRE[ANIN, MP; 8. Slobodan BIJELIC, MP; 9. Velibor OSTOJI], president of the SDS Executive Board; 10. Milan GVERO; 11. Milan ZORIC, general director of Serbian TV; 12. Nenad 78962 IT-95-5/18-T 151 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case NOVAKOVIC, acting general director of Glas srpski; 13. Branislav ILIC, general director and editor-in-chief of SRNA News Agency; 14. Drazenko DJUKANOVIC, editor- in-chief of the newspaper Oslobo|enje; 15. Jovan JANJIC, editor -in- chief of weekly Javnost. 65ter# Aug-1991 KARAD@I] to (SDS) This document is relevant to the No objection 21778 municipal presidents SDS hierarchical structure, to Karadzic's pre-eminent position In this document, and to the dissemination of KARAD@I] gives instructions. detailed instructions on communications within the SDS. 65ter# 06-Jul-1992 Letter by KARAD@I] to The item is relevant to No objection 21810 Lord CARRINGTON /in KARAD@I]’s command and English/. control. In this letter KARAD@I] says that he gave "firm orders" to army commanders around Gora`de. KARAD@I] 78961 IT-95-5/18-T 152 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case signs as "leader of Bosnian Serbs". 65ter# 31-Aug-1992 Cable sent to CSB Banja The document is relevant to Objection—should 21839 Luka, RSMUP and KARAD@I]'s control over have been used President KARAD@I] detention facilities by virtue of his with KDZ163 reporting completion of control over the MUP and VRS in CSCE visit to Manja~a this instance. It is also relevant to Camp and Trnopolje. In his command and control over RS this document, CSB MUP forces in the Krajina region. Banja Luka reports directly to KARAD@I] that the CSCE delegation was in a position to visit Trnopolje and Manja~a and has since left the area 65ter# 17-Dec-1992 Amended Text of the This is the text of the amended No objection 21866 Constitution of the constitution of the RS, as of 17 Republika Srpska, Nr 02- December 1992. It is relevant as it 3012/92 sets up the competencies of the State organs and governs their political interplay. It is further relevant to command and control of KARAD@I]. 65ter# 21-Oct-1995 Report on the work of the This is relevant to command and No objection 21883 Zvornik Municipality control by KARAD@I] over War Presidency for the events taking place in period from 29 September municipalities. to 20 October 1995, Nr 01-826/95, Jovan 78960 IT-95-5/18-T 153 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case MITROVIC, President of the Zvornik Municipality War Presidency. This report on the work of the Zvornik Municipality War Presidency is addressed to the RS MOD. Reference is made to the adoption of a conclusion of the war presidency based on a previous order of KARAD@I]. It also refers to a decision of the Supreme Command which has now been implemented. It also states that a letter of support was sent to KARAD@I] pledging him support. 65ter# 23-Jun-1992 Regular Combat report This item is relevant to the No objection 21901 No.01/2-779 submitted by expulsion of Bosnian Muslims and the Eastern Bosnia Corps Bosnian Croats from Bosnian Serb- to the VRS Main Staff claimed territory in eastern Bosnia. about the situation in their It shows that information of non- area of responsibility. It Serbs moving out of the area of informs inter alia that the responsibility of the East Bosnia buses carrying civilians of Corps was reported regularly up Muslim nationality were the chain of command. This report 78959 IT-95-5/18-T 154 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case moving out. is in line with the order issued by Svetozar ANDRI] on 28-05-1992 (P03055). 65ter# 08-Jul-1994 Copy of a VRS Main The document is relevant to No objection 21906 Staff Order 03/4-575, KARAD@I]'s role as Supreme dated 20 April 1994, re Commander and his direct Complex Military and participation in approval and Political Situation and issuance of orders, and to his Achieving Certain Goals command and control over the in the Battlefield. The VRS. document references RS President's order strictly confidential 01-73/94 dated 20 April 1994.The order provides instructions to the effect that VRS corps can be deployed and used for combat only after the RS President's personal approval. The order also bans any changes of adopted decisions as to use of the units in combat engagements without prior approval by RS President. 65ter# Concluding speech by This document is relevant to No objection 21995 president KARADZI] at republic level communication with a consultation in municipalities, to awareness of 78958 IT-95-5/18-T 155 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case Vlasenica, dated killings and expulsions of non- 29.01.1994, 4 pages. In Serbs, to SDS preparations for the this speech KARAD@I] conflict and to Bosnian Serb addressed the situation in military superiority. BiH in retrospective, including preparations This document was seized from made before the war and premises related to Ratko the BSL's goals. MLADI] on 4 December 2008.

“This is different from the break up of Yugoslavia, nobody guarded it then /sic/. For us to conquer the entire territory in which there is probably about a million or a million and a two hundred thousand Muslims, if there are still so many out there /as written/. Here I mean not only those who were killed but also those who fled; in order that we achieve and realize it /as written/. It is very hard to imagine. And, it is hard to imagine such a complete defeat of Muslim forces; that they will not stay in some corner and pretend 78957 IT-95-5/18-T 156 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case to be a state or a government as well as to have independence and legitimacy in a sense that they continue to infuriate us till the end /sic/. What can we do? We must defeat them everywhere we can and keep the territory.

I can assure you that although the Muslims seem more organized than us, but you see, I will go on defending the Serbian Democratic Party /Serbian Democratic Party/ administration. We prepared ourselves better during the time of peace than they. We knew what they are doing but they did not know what we are doing. They were astonished by the way we organized defense of the municipalities. We were organized; general KOVA^EVI] knows 78956 IT-95-5/18-T 157 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case that, because we were supported by general ADŽI]. He worked on distribution of ammunition, he knew about it. General SUBOTI] also knew about it. We were better. When we do maps, we are more studious and better. We know exactly where which mine or a village is, they do not know that.” 65ter# 04-Jun-1992 Draft UNPROFOR This document is relevant to Objection— 22871 Outgoing Crypto Fax awareness of detention facilities irrelevant, from Nambiar, and corroborates testimony that the unreliable UNPROFOR Sarajevo to RS leadership was hearing Nambiar UNPROFOR allegations regarding detention Belgrade. Draft records a facilities from all parts of the discussion held between international community. See e.g. DCMO and BiH Minister Wilson (T.3927-3928) and \eri} of the Interior HEBIB and (T.27982; 28012). LO SU[I] on 4 June 1992. Attached to the The RS leadership’s awareness of document is a list of the detention facilities is relevant to locations of detention this case and the Chamber has facilities (referred to in heard evidence that the leadership document as was aware of and had notice of "concentration camps") detention facilities, in particular in on territory held by the the transcript examples cited by 78955 IT-95-5/18-T 158 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case Bosnian Serbs as at 4 late May or early June. This June 1992. document is consistent with, contextualized by and corroborates such testimony, insofar as it reflects that members of the international community received allegations concerning the existence of such facilities. The Prosecution accepts, of course, that the allegation that a particular camp exists is not sufficiently reliable, on its own, to establish the existence of that camp, but must be measured against other evidence in the case but in any event, that is not the primary basis for the relevance of this document. 65ter# 14-May-1992 Report on meeting of This is relevant to the flow of Objection-- 22874 SAO Birac Government information from Serb authorities irrelevant in Sekovici. This appears at the municipal level to the to have been signed in Bosnian Serb leadership. It is also Vlasenica on 14.05.1992, relevant to the Bosnian Serb this document contains a leadership’s oversight of events in stamp indicating it was Vlasenica municipality, and to co- received in Sarajevo on operation between the VRS, RS the same date. The stamp MUP and the regional SAO Birac is in the same format as government and thus to logistical other stamps of the “Serb co-ordination among those bodies Republic of Bosnia and during a period of massive forcible Herzegovina”. It is an transfer of non-Serbs from the area. 78954 IT-95-5/18-T 159 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case update of operations by Serb forces in the area Even if the document simply and notes that “Serb conveyed different information, it Army and SJB Cmdrs would be probative of the existence participated in a SAO of lines of communication between Birac Govt meeting that the local authorities and the took place on 14-May-92” republic authorities. Beyond that, however, the document reflects reporting from the local level to republic authorities (in the Sarajevo area) regarding operations by Bosnian Serb forces and meetings involving the Bosnian Serb army and police with the regional authorities, thus rendering the content relevant (to the hierarchical structure and reporting), as well as the fact of the communication. 65ter# 13-May-1995 Speech delivered by the This document is relevant to No objection 22913 President KARAD@I] at KARAD@I]'s control over the the Command of the VRS, RS MUP and municipal Herzegovina Corps on 13- authorities, as well as the logistical May-95. co-ordination between these In this speech and bodies. meeting, attended by MLADI] and Gvero, KARAD@I] discusses the relationship of the VRS with and support 78953 IT-95-5/18-T 160 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case received from the JNA, the integrated relationship between the VRS, the MUP and Bosnian Serb government, and the importance of control over municipal authorities by the Bosnian Serb government.. KARAD@I] emphasizes his personal role as Supreme Army Commander and the importance of his control over army commanders in the field and his command over Mladi} in particular. KARAD@I] further emphasizes the importance of central Bosnian Serb government control over troop operations. KARAD@I] received a military briefing from Gen. Grubac on the military situation at the fronts. 65ter# 24-Jun-1992 Decision of Trebinje This document, citing a Decision Objection— 22916 Municipal War Staff no. by the RS Presidency, is relevant to uncharged 09-012-60-27/92, 24 June the relationship between the VRS municipality 78952 IT-95-5/18-T 161 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case 1992, requiring all and municipal organs, to the paramilitary formations implementation of RS Presidency be placed under the single decisions and in particular those command of the VRS, regarding the army, to the receipt orders the members of the by paramilitaries of food and volunteer detachment payment prior to their placement Dragi Lazarevi} to place under the single command of the themselves under the VRS, and to the Accused's single command of the command and control over Herzegovina Corps under municipal organs, local pain of being taken off the paramilitary and the VRS. The records for payment of document is relevant to the salaries and losing their overarching JCE, and demonstrates eligibility for military KARAD@I]'s command and recruit food. control over municipal organs, local paramilitary and the VRS. 65ter# 04-May-1992 SAO Herzegovina War This document must be read in Objection— 22918 Staff Order no. 21, 4 May conjunction with the Decision of uncharged 1992. Trebinje War Staff, no. 09-12- municipality 28/92 (65ter#22919 below), which This “Order Nr. 21”, implemented this regional order in issued by the SAO Trebinje. This document is Herzegovina War Staff, relevant to the relationship between directs that all military regional and municipal conscripts who have not governmental organs and the complied with the order implementation of regional war on mobilisation or who staff orders. SAO War Staff orders have left their military are directly implemented by units, be declared war municipal War Staff organs. fugitives or military 78951 IT-95-5/18-T 162 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case deserters. 65ter# 14-May-1992 Decision of Trebinje War The War Staff of Trebinje Objection— 22919 Staff, no. 09-012-28/92, municipality issued a decision uncharged 14 May 1992. pursuant to Order Nr. 21 of the municipality SAO Herzegovina War Staff (see 65ter#22918 above) ordering all companies, organisations and institutions to take away the apartments and terminate employment of all men under military obligation who have left the territory of the municipality and are not serving in the TO SAO Herzegovina. Read in conjunction with 65ter#22918, this document is relevant to the relationship between regional and municipal governmental organs and the implementation of regional war staff orders. Municipal War Staffs directly implemented orders from the SAO War Staff. 65ter# 13-Jul-1992 Decision on Cessation of This document is relevant to No objection 22920 Work of Government of KARAD@I]’s power over regional SAO Herzegovina, no. authorities. This document 09-012-60-56/92, 13 July clarifies the governmental structure 1992. in the region after July 1992, reflecting a strengthening of ties On 13 July 1992, the between the municipal and Assembly of SAO republican levels of government. 78950 IT-95-5/18-T 163 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case Herzegovina voted to dissolve itself and cease operation as a government entity, to be replaced by various councils composed of municipal representatives. Such action was taken pursuant to (1) Article 4 of the Decision on the Establishment of War Presidencies in Municipalities during the State of War or Imminent Threat of War, and (2) the recommendation of the RS Presidency, which included KARAD@I]. 65ter# 24-Jun-1992 Decisions 02-946/92 and This is relevant to the show that Objection—should 22938 02-947/92 (items 552 and non-Serb judges appointed by the have been used 553) from the Official Bosnian Serb leadership were when Mandic, Gazette of Republika dismissed in July 1992, a month Minister of Justice, Srpska dated 30/09/1992, after their appointment. testified signed by Momcilo Kraji{nik, to dismiss The Accused addressed the recently appointed judges appointment of non-Serb judges during his cross-examination of Momcilo MANDI]. The Witness agreed with the Accused's suggestion that “we always 78949 IT-95-5/18-T 164 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case counted on Muslims and Croats living among us, and they would be proportionately represented in our government bodies and in our authorities (T.5018)”.

To support this, the Accused tendered D417, a document dated 5 June 1992 concerning nominations for judicial appointments. The Witness confirmed that non-Serb persons were nominated, including Alma Salihbegovi}, Alida Nadj- Madjarac, Muhamed Gruohnjic, Cviko Adamovic, Vinka Musladin and Smail Salihbegovic. Exhibit D418, part of the Official Gazette of the Republika Srpska, shows that a decision was taken on 30 June 1992 appointing the above- nominated non-Serb persons (T.5018-5024).

Subsequently, the Witness confirmed the Accused's statement that judges who had been appointed left eventually for different reasons; tensions, general anxiety, and so on... (T.5085).

78948 IT-95-5/18-T 165 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case 65ter22938 represents a decision made at the 17th Assembly Session of 24-26 July 1992, to dismiss recently appointed judges. The decision was taken after Rajko Duki} complained to the 17th Assembly specifically about the appointments of non-Serb judges listed in the Gazette that the Accused tendered as Exhibit D418:

One day Muslims will rule Bijeljina. And when I look at the Official Gazette a moment ago I realised that we ourselves are on the road to establishing such authorities very soon. There, it says that judges have been appointed to the Bijeljina Court: Smajil Salihbegovi}, Muhamed Gluhonji}, Alida Ma|ar, Alija Zvizdi} and I do not know, I also found a fifth one - Alma Halibegovi}. So I am asking you gentlemen why we expelled all Muslim judges from Vlasenica, Bratunac and Zvornik. We'll we be accused then, I hope we will not, but will these others be better there working like this? I would be ashamed and I would 78947 IT-95-5/18-T 166 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case regret all the victims if I lived in a state in which Muslims and Muslim ideology would judge and where their justice was done. We all know what sort of justice that is, come on gentlemen MPs, please do not allow for a single judge, not a single judge or prosecutor to mete out justice in our municipalities in the future or now. (Exhibit D92, pp.72-73)

65ter22938 is relevant because it demonstrates that the non-Serb judges who were appointed, including those appointees specifically discussed in Mr MANDI]'s cross-examination - and specifically identified by Rajko Duki} in his speech at the 17th Assembly Session - did not depart for different reasons but were dismissed in July 1992, a month after their appointment. 65ter# 2-Apr-1992 This video clip depicts This video clip is relevant to Objection—news 40136 statements of Radovan Radovan KARAD@I]’s awareness reports not A KARAD@I], Muhamed of the presence of Arkan's unit in admissible from ^ENGI], Milutin Bijeljina. bar table KUKANJAC and others while waiting in the lobby 78946 IT-95-5/18-T 167 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case of the Holiday Inn hotel in Sarajevo. Demonstrations were taking place outside on the streets and KARAD@I] was surrounded by men in camouflage uniforms.

Muhamed ^ENGI] stated that it must be determined under whose command @eljko RA@NATOVI] (Arkan) came and destroyed Bijeljina. KARAD@I] answered that they are there because of Sarajevo and the call for mobilization caused everything.

V000-0436 (02:10:40- 02:15:30) 65ter# 17-Feb-1995 Video of SRT report This video-clip is inter alia to Objection—news 40382 about Radovan show the role of the SDS party at reports not KARAD@I]’s speech at the beginning of the war. admissible from the SDS Municipal Board bar table in Gradi{ka.

78945 IT-95-5/18-T 168 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case KARAD@I] praised the role of the 1KK (formerly JNA Banja Luka Corps) and stated that the SDS established most of the state borders in the first 45 days of war.

V000-3453 (02:21:51- 02:23:16) 65ter# Excerpt from a SRT TV This video clip is relevant to the Objection—news 40403 Talk Show with Radovan Bosnian Serb leadership’s reports not A KARAD@I], Mom~ilo objectives of permanent ethnic admissible from KRAJI[NIK and Milan separation. bar table MARTI].

V000-3453 (02:51:00- 02:52:06)

Mom~ilo KRAJI[NIK is depicted saying that there is a new development. Serbs moved out of certain places, so when Serbs return to Zenica, Croats will return to Derventa and Brod and that will never happen, same as it is with Zvornik. This is the time 78944 IT-95-5/18-T 169 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case of separation. 65ter# Dec-1992 Video clip depicting an This video clip is relevant to the Objection—news 45019 interview with Radovan objective of ethnic separation. reports not KARAD@I] by a CNN admissible from journalist. Radovan bar table KARAD@I] speaks in English (with narrator’s translation to BCS) saying that Serbs and Muslims cannot live together.

V000-0271-1 (00:31:25- 00:34:25)

KARAD@I] insists on ethnical separation saying we are like oil and water. He points to a map of BiH with colour markings of the ethnic groups in BiH. He also denied crimes being committed. BCS ERN:

V000-0271-1-V000- 0271-1 (00:31:25- 00:34:21) 65ter# 1995 Video clip of an interview This video clip is relevant to Objection—news 45054 of Radovan KARAD@I] Radovan KARAD@I]’s command reports not by CNN journalist. and control. admissible from 78943 IT-95-5/18-T 170 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case bar table V000-2023 (00:26:44- 00:27:29)

KARAD@I] speaks in English about his relationship with Ratko MLADI] saying there is no division between them and the orders were carried out. 65ter# 2-4-Apr-1992 Excerpt of video The video clip is relevant to the use Objection—news 45099 depicting meetings of paramilitary figures of the reports not A between @eljko Bosnian Serb Leadership, and also admissible from RA@NATOVI] (Arkan), to an awareness of events in bar table Biljana PLAV[I], Goran Bijeljina in early April 1992. HADI@I] and others in the premises of the Bijeljina Crisis Staff, prior to the arrival of Fikret ABDI] and JNA officials.

Biljana PLAV[I] stated that she wanted to come first and contact the Crisis Staff directly and later talk with the rest "now we are expecting them to come." She then says, "it 78942 IT-95-5/18-T 171 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case was my choice to first visit the local Serbian people's Crisis Staff, and meet here with Mr Arkan and his associates here, we are fortunate to have met here, even Mr Goran Ad`i} and so I knew that it would be better to have such a close encounter without the others that we'll talk to later".

V000-1462 (01:48:30- 01:52:40)

The video was shown in a TV programme about the events in Bijeljina in early April 1992. The video was broadcasted on TV in Serbia. 65ter# 2-4-Apr-1992 Excerpt of video The video clip is relevant to the use IT-03-69: Objection—news 45099 depicting meetings in of paramilitary figures of the P01622 reports not B Bijeljina with @eljko Bosnian Serb Leadership, and also admissible from RA@NATOVI] (Arkan), to an awareness of events in bar table Biljana PLAV[I], Fikret Bijeljina in early April 1992. ABDI] and others at the Bijeljina Crisis Staff premises. 78941 IT-95-5/18-T 172 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case V000-1462 (01:54:00- 01:59:50) The video was shown in a TV programme about the events in Bijeljina in early April 1992. The video was broadcast on TV in Serbia. It is a continuation of the video clip 65ter#45099A. 65ter# Sep-1991 Excerpt from video V000- This video clip demonstrates the IT-02-54: Objection—news 45238 1274 footage depicting a character and general reputation of P568 Tab 6; reports not A documentary on @eljko Arkan's men, and in particular admissible from RA@NATOVI] aka Arkan’s willingness and intent to IT-03-69: bar table Arkan and his unit, kill captured soldiers.. P00326 Arkan’s Tigers.

The video depicts the statement of @eljko RA@NATOVI] in Belgrade in September 1991. Arkan, who is dressed in a camouflage uniform states, "We don't take any more prisoners. We're going to kill every fascist soldier we catch. They have to know that".

V000-1274 (00:00:36 - 78940 IT-95-5/18-T 173 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case 00:00:48)

65ter# 1993 Excerpt from a video of This is relevant to the Bosnian Serb Objection—news 45366 SRT talk show with leadership determination to reports not Radovan KARAD@I] maintain the demographics and admissible from and Mom~ilo control over territories that had bar table KRAJI[NIK. been the subject of the violent campaign against non-Serbs. It is V000-3157 (00:54:25- also relevant to the Bosnian Serb 00:55:55) leadership's awareness of the factual situation and to their Radovan KARAD@I] strategy of creating a new factual and Momcilo situation and then justifying KRAJI[NIK discussed retention of territories on the basis the peace negotiations of that new factual situation. with Vance and Owen in Geneva. KARAD@I] agrees that the Vance- Owen plan is a step back comparing to the Carrington-Cutileiro proposals. He said that there is a new development on the ground and that it is a illusion to believe that the Zenica Serbs will ever leave Zvornik.

V000-3157 (00:54:25- 78939 IT-95-5/18-T 174 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case 00:55:55) 65ter# 00-Jun-1993 Video of S TV (TV BL) This video clip is relevant to ethnic Objection—news 45367 footage depicting an separation, awareness of Serb reports not interview in which military superiority and intent admissible from Radovan KARAD@I] toward Muslims. bar table discusses the Geneva negotiations.

V000-3159 (00:46:00- 00:47:49)

Radovan KARAD@I] states that the best possible moment for Muslims has come to save themselves from disappearance and create their living area. They could have their state in central Bosnia and Cazin Krajina if their leadership accept that. 65ter# 15-Jan-1994 Excerpt from a video of This is relevant to the military No objection 45409 the VRS military implementation of the six strategic economical conference. objectives and to show that the The conference was objectives were to be achieved by chaired by Ratko military force, rather than, as MLADI]. Among those asserted by the Accused, present were Radovan exclusively through peaceful KARAD@I], Milan negotiations. 78938 IT-95-5/18-T 175 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case GVERO, Gen. \or|e DJUKI]; and other VRS officers. Radovan KARAD@I] delivers a speech in which he discusses the strategic objectives and their implementation. He states, "You remember that I was an optimist on so many occasions. And, Thank God, everything we were predicting had been realized. I can say that when we formulated the strategic goals, they had been formulated with the greatest possible defiance. At the very beginning of the war, we have formulated the six Strategic Goals: the first one was to secede from our enemies, that is to create our state, the second was to have a territorial connection in Posavina, the third was that Drina should not be the border, the fourth was 78937 IT-95-5/18-T 176 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 65ter Date Description of Item Relevance to the Prosecution’s Exh# Prev Opposing Party’s # Case and Probative Value Case to get a part of the Neretva valley, that is to have the Neretva as the border, the fifth was to achieve a Serb Sarajevo, and the sixth was to achieve an access to the sea. According to the current situation, except that the Neretva is the border along its complete flow, the upper part is in our territory, we have achieved the remaining goals".

V000-8192 00:12:00- 00:14:07

78936 IT-95-5/18-T 177 Appendix A to Revised Municipalities Bar Table Motion 3 October 2013 78935

APPENDIX B to REVISED PROSECUTION’S BAR TABLE MOTION FOR THE ADMISSION OF DOCUMENTS RELATED TO THE MUNICIPALITY COMPONENT WITH PUBLIC APPENDICES A AND B AND CONFIDENTIAL APPENDIX C

Case No. IT-95-5/18-T 3 October 2013