IT-95-5/18-T 94248 D94248 - D94220 02 November … Disclosure...Dr. Radovan Karadzic respectfully moves for a finding that the prosecution has once again violated its disclosure obligations

THE INTERNATIONAL CRIMINAL TRIBUNAL FOR THE FORMER YUGOSLAVIA

CASE No IT -95-518-T

IN TRIAL CHAMBER No3

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

Registrar Mr John Hocking

Date 2 November 2015

THE PROSECUTOR

v

RADOVAN KARADZIC

Public

104th MOTION FOR FINDING OF DISCLOSURE VIOLATION AND FOR REMEDIAL MEASURES

The Office of the Prosecutor Mr A Ian Tieger Ms Hildegard Uertz-Retzlaff

The Accused Radovan Karadzic

No IT -95-518-T 1

94248IT-95-518-TD94248 - D9422002 November 2015 SF

1 Dr Radovan Karadzic respectfully moves for a finding that the prosecution

has once again violated its disclosure obligations pursuant to Rule 68 by failing to

disclose exculpatory material and for remedial measures The material that is the subject

of this motion was not disclosed until 2 October 2015 one year after the trial concluded l

Renate Flottau statement

21tem 1 is a 1996 ICTY statement of Renate Flottau who worked as a

correspondent for Der Spiegel during the war2 In her statement Ms Flottau provided

inter alia the following information

(A) Dr Karadzic told her during an interview that crimes in the camps were committed by Serb refugees from other parts and that he could not control them He said that those responsible will be before the Court3

(8) Dr Karadzic told her that expUlsion of the Muslims was not his policy and that some Serb nationals and disappointed Serb refugees were carrying out those crimes and making the Muslims flee He said that they would be punished for these crimes in his Courts4

(C) Dr Karadzic told her that there were no civilians in the camps only f 5prIsoners 0 war

3 The exculpatory nature of this information is that it refutes the prosecutions

claims that Dr Karadzic had the mens rea required for the crimes in the municipalities

with which he is charged The contemporaneous statements of Dr Karadzic in 1992 also

corroborate the defence he offered at trial in 2012

4 Dr Karadzic was prejudiced by the prosecutions failure to disclose the

statement because he could have attempted to interview Ms Flottau and call her as a

witness for his defence

5 The prosecutions failure to disclose this statement is egregious because it

involves statements by the accused A simple word search for Karadzic in the

1 On 2 and 12 October 2015 the prosecution disclosed 11373 items totaling approximately 186915 pages of potentially exculpatory material some of which may be duplicates of material disclosed earlier Dr Karadzic has no defence team during this period and does not have the resources to review this material in toto but has selected some examples for the purpose of this motion 2 The statement is attached as Annex A 3 Annex A p 3 4 Annex A p 4 5 Annex A p 5

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prosecutions database would have revealed the statement and the exculpatory nature of

the contents of the statement is obvious

George Eykyn notes

6 Item 2 is a 1996 report of notes from OTP Trial Attorney Carolyn Edgerton of

her interview with BBC correspondent George Eykyn6 In the report Eykyn told Ms

Edgerton inter alia the following

(A) He had interviewed the Deputy President of Foca Municipality Lubo Todovic in August 1993 and Todovic told him that there had been no ethnic cleansing of Muslims in Foca and that the Muslims had wanted to leave7

(B) Major Mauser stopped lelesic from committing crimes in Brcko and that lelesic was an embarrassment to the Serbss

7 The exculpatory nature of that material is that it refutes the prosecutions case

on Count 8~forcible transfer from Foca municipality and its attribution of the crimes of

murder and assault by Goran lelesic at Luka Camp to Dr Karadzic as part of a joint

criminal enterprise

8 Dr Karadzic was prejudiced by the prosecutions failure to disclose this report

because he could have attempted to interview Mr Eykyn and Lubo Todovic and call

them as a witness for his defence

9 The prosecutions failure to disclose this statement is egregious because it was

taken by a member of the prosecution trial team in the Karadzic case

Zivko Bojic report

10 Item 3 is a 2000 report oflCTY interview with Banja Luka police officer

Zivko Bojic9 In the report Mr Bojic told the prosecution inter alia the following

(A) Police inspectors from Banja Luka went to the prison camps mainly to calm things downl0

(B) No war crimes were committed in Banja Luka 11

6 The report is attached as Annex B 7 Annex B p 3 H Annex B p 4 9 The report is attached as Annex e 10 Annex C p 4 II Annex C p 5

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(C) Zupljanin did order inquiries into war crimes In his opinion Zupljanin is not a war criminal 12

11 The exculpatory nature of the material is that it shows that the very

subordinates of Dr Karadzic who the prosecution claims were part of a joint criminal

enterprise to commit the crimes charged in the indictment were trying to prevent such

crimes


because he could have attempted to interview Mr Bojic and call him as a witness for his

defence

Conclusion

13 The three documents described above are but examples of the continuing

nature of the violation of the prosecutions disclosure obligations The prosecution

continues to violate its obligations with impunity

14 Dr Karadzic requests that the Trial Chamber make a finding that the

prosecution has again violated its disclosure obligations under Rule 68 by failing to

disclose the above items as soon as practicable

15 As a remedial measure Dr Karadzic requests that the Trial Chamber draw an

adverse inference against the prosecution for each of the subjects of the undisclosed

material (l) that President Karadzic lacked the mens rea for the crimes in the

municipalities (2) that there was no forcible transfer from Foca (3) and that Dr

Karadzic was not a member ofany joint criminal enterprise to expel Bosnian Muslims or

commit other crimes in the municipalities of Bosnia 13

16 As a sanction for the prosecutions continuing violation of its disclosure

obligations Dr Karadzic requests that any sentence imposed upon him ifhe is convicted

be reduced as a result of the wholesale violation of his right to a fair trial by the

prosecution

12 Annex C p 5 13 Dr Karadzic reserves the right to offer evidence from these persons pursuant to Rule 115 on appeal if he is convicted when he is once again provided funding for his defence However he has no resources during this period for an investigator to locate and interview these witnesses

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Word count 1107

Respectfully submitted

f~ Radovan Karadzic

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ANNEX A

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INTERNATIONAL CRIMINAL TRIBUNAL FOR THE PROSECUTION OF PERSONS RESPONSIBLE FOR SERIOUS VIOLATIONS

OF INTERNATIONAL LAW COMMITTED IN THE TERRITORY OF THE FORMER YUGOSLAVIA SINCE 1991

WITNESS STATEMENT

WITNESS INFORMATION

Last Name FLOTT AU nee JAESSL

First Name(s) Renate Fathers First Name

Nickname Gender 0 Male [gl Female

Date ofBirth 29121944 Place of BirthAue Germany

Ethnic Origin Other (C (11 AA) Religion Other

Language(s) Written (ifdifferent from spoken)

Language(s) Used in Interview English illII) SetHian

Current Occupation Journalist Fonner

Date(s) ofInterview(s) 621996

Interviewer REID amp FIETZ Interpreter Nil

Names of all persons present during interview(s) Nil

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vnTNESSSTATENUENT

I am ajoumalist employed by Der Spiegel in Hamburg Federal Republic of Germany I am employed by them as their foreign correspondent for the Balkans I am the only person working in this position however if there is too much work I am able to get assistance I am based in Belgrade Federal RepUblic of Yugoslavia I have held this position for the past seven years Prior to this I worked in Belgrade for ZDF television which is a German television station

I have covered the war in the former Yugoslavia since the beginning that is from 1991 with the war in Slovenia and Croatia As part of my work I have carried out interviews with all of the leaders These include President TUDJMAN President ITZEBEGOVIC Radovan KARADZIC General MLADIC Vojislav SESELJ Milan MARTIC and many others All these interview were done in the language that the leader spoke that is in Bosnian Serbian Croatian etc I learned these languages as a result ofmy work and having lived in the country for ten years

On this date I have supplied to the International Criminal Tribunal a copy of a tape of an interview I conducted with Radovan KARADZIC on 17 May 1995 This tape was partly published in Der Spiegel issue 21 of 1995 There is a lot more information on the tape The interview was conducted in the Serbian language and for the majority of the interview there was only he and I in the room At other times there were some of his security guards in the room but as they know me so well they left the room The interview lasted about one hour and was conducted in his headquarters in Pale

To arrange this interview I contacted Alexander BUHA who is the Minister for Foreign Affairs in the Bosnian Serb Administration I think I have interviewed KARADZIC five times Once was in the Hotel Inter Continental Belgrade just after he had returned from Russia All the others were in his headquarters in Pale I taped all the interviews with him and I will check that I still have them all He had no objections to me taping these interviews None of the interviews were censored by him or any ofhis people Sometimes I have a background conversation with the person I am interviewing and this is not recorded I used to make notes of these conversations but I do not believe that I have kept this notes however I will check this

All the interviews with KARADZIC were published in Der Spiegel I only work for Der Spiegel As part of my contract with them I am not allowed to publish in other newspapers however I am allowed to comment on television or radio programs provided that it is mentioned I am the correspondent for Der Spiegel I will check in my office for the other tapes of interviews with KARADZIC and will supply them when I locate them I do not think any of my interviews with KARADZIC were shown or heard on local television or radio

I did not conduct the interview on the radio station Deutsche Welle on 29 August 1994 My article is referred to in that broadcast Somebody else must have repeated the text from the Der Spiegel article As I mentioned I would not be allowed to

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conduct such an interview on the radio station without credit being given to Der Spiegel The first interview I ever had with KARADZIC was I think when he first set himself up in Pale as President of the Republika Srpska The last interview I had with him was the interview I had in May 1995 with him I will check my records with my office and give you the exact dates ofthe interviews

The normal way to obtain an interview with KARADZIC was to contact his daughter who was his press secretary and leader of his press office In my case I used my other contacts to obtain the interviews The interviews I had with KARADZIC were always alone just him and I There were no other journalists present at the time I think that most of the journalists if they were from big newspapers got interviews with KARADZIC but 1 do not know what was discussed in those interviews as I had no time to meet with them and they were not staying in Belgrade

The interviews I had with KARADZIC I always instigated however I heard that he pressed two American companies one being CNN I do not know the other one where the interviews were instigated by KARADZIC I have also heard that he would not allow one American company to leave Pale unless that company was replaced by another American company I do not recall the name ofthe company but I will find out for you

I recall that in the last interview 1 had with him he spoke to me about a proposition a group of former American generals had put forward in relation to a peace plan I gained the impression that he wanted me to let the western world know that he liked this plan and wanted to get a reaction from the west At times he would try to swing the conversation away from my questions and on many occasions I would ask the question again but it depended on the mood ofthe interview I recall that I asked him about the camps and the International Tribunal He told me it was all about the west and I pressed him about the camps He said those that are responsible will be before the Court He then blamed the Serb refugees from other parts and that he could not control them All these types ofquestions are on the tape that I am supplying to you today The tapes and material I am supplying at this stage I would only like used for you investigate purposes I will need to make inquiries with the legal advice section ofDer Spiegel to see if it is allowed to be used for court purposes I agree that the parts on the tape that have been published in Der Spiegel can be used by the Tribunal in their court process

KARADZIC was always very helpful in the interviews He never cut the interviews off like many political figures I remember on some occasions his staff would come into the office and inform him that he had other appointments but he would just cut them off He never once got angry with any of the questions I asked

At the very first interview he always referred to himselfas the voice of the people and I think he was very closely aligned with Belgrade As the interviews progressed he gained strength and by the last interview he was clearly in charge saying things like I am in charge I am the President here I am in charge of the army etc I recall he asked me if ITZEBEGOVIC ever came to Pale and I told him that I would ask him

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He then replied that he (KARADZIC) was the President of seventy percent of the territory ofBosrua and not ITZEBEGOVIC He told me on the last occasion that he thought the only solution was for total war against the Muslims if they do not agree with the peace agreements He was also saying that the Bosnian Serbs should be united with Belgrade During all the interviews he was very protective of MILOSEVIC saying that MILOSEVIC did not know what the policy was that this was not MILOSEVICs war etc

During the interviews he gave me documents but there was nothing especially important they were already known I no longer have any of these documents as I destroyed them I recall that one time I asked him what he would do after the war and he stated that he wanted to go back to his profession as a psychiatrist and that he did not want to be a politician any longer This was the second last interview I had with him but I will check my tapes I did not believe a word he said about this All the questions he answered he answered confidently except for one and that was when I asked him about MLADICs visit to Moscow He could not answer this question and asked me to skip the question which I did During my interviews I did not believe that KARADZIC was a Serb nationalist but saw it as a way of making money and used Serb nationalism to stay in power I asked him about the genocide of the Muslims He told me that they were fleeing and that they did not trust the Serbs He told me that it was not his policy but some Serb nationalists or some disappointed Serb refugees who were carrying out these crimes and making the Muslims flee He further stated that they would be punished for these crimes in his courts He also stated that there were as many Serb refugees and they obviously did not trust the Muslim government He also stated that it would be better to have formal areas for each ethnic group but he did not refer to it as a policy

At the begirwing he had no objections about the plan of Greater Serbia but he continued to change his mind as time went on I think he wanted his own Republic and ifMILOSEVIC told him that he (KARADZIC) would be President of the Republic then he would be fine The question ofGreater Serbia however was like a bouncing ball to him in that his mind was continually changing his mind about uniting with the Federal Republic of Yugoslavia

I remember in the beginning ofAugust 1992 I went with KARADZIC and a group of jownalists to Kula prison near Sarajevo There were still prisoners in the prison and they spoke with some of them I would estimate that there were about two hundred that we were shown Most of them gave me numbers to call relatives and let them know they were still alive This prison was not the worst but I was told by some of them that there were beatings The visit lasted about fifteen to twenty minutes and at the end of the visit KARADZIC told the prisoners that they would be released but they had to behave themselves because he told them he did not know what the population ofSerbs would do with them if they did not behave I took this as a serious threat to these prisoners This is also mentioned in an article I wrote for Der Spiegel and I would look for the number ofthe issue for you There were no women in the camp

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I then travelled to Banja Luka with the journalists on a bus KARADZIC did not accompany us but we were accompanied by one ofhis ministers but I do not recall which one In Banja Luka we visited Manjaca camp I cannot estimate how many prisoners were there as they were detained in large sheds similar to cow halls We had little opportunity to speak with the prisoners but we spoke with the commander of the camp who was very impolite I cannot remember his name but I will look it up for you The prisoners were very thin and they told me how much weight they had lost There were no women in the camp

We were allowed to take photographs at the camps but I cannot recall if have kept them I will check for you On the visit to Banja Luka I spoke with some of the Muslims there I later returned back to Belgrade by bus

KARADZIC stated that in the camps there were no civilians only soldiers who were prisoners of war

I learned later that a group ofjournalists who were not associated with our group had gained access to the Omarska camp where they took video and still photographs

In relation to Srebrenica KARADZIC has said very little about it He has of course denied the allegations I have not spoken to him about it as my last interview with him was in May 1995 One of the things he did say to me about Srebrenica during this last interview was that he would take Srebrenica ifUNPROFOR leaves and the Muslims are not disarmed I think a lot of the statements have been made by KRAJISNIK I have spoken mainly to the army about it particularly General GVERO MLADICs deputy I have a tape about what he has said but he did not deny there were mass graves but they were the graves ofsoldiers who had been killed in battle I will give you a copy of this tape

In relation to the taking of the UN hostages KARADZI C told me about two to three weeks before they were taken that he would take hostages ifNATO attack Serbs and ifUNPROFOR took the side of the Muslims He stated that they would then become enemies of the state I told him that he had UNPROFOR completely in his hands and that they were doing whatever he wanted He stated that this was true because it was Serb territory I do not recall him ever saying that he would taken civilian hostages He told the Serb and foreign press that ifNATO attacked the Serbs and in particular the installations where the hostages were killed then it would be NATO killing the hostages and not him

I remember an interview I conducted with General MLADIC That was on 02 11 1994 in Han Piesak That is his headquarters The interview was arranged via BUHA Officially KARADZIC was not interested that 1 would have an interview with MLADIC because there were some quarrels between KARADZIC and MLADIC at that time MLADIC was known to be very spontaneous and KARADZIC was afraid that he would have to correct that afterwards Everybody was looking for MLADIC at that time and there were rumors that he could have fled to Greece I was the only one to have an interview with MLADIC at that time

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The interview was about two and a half hours long This only covers the taped part of our conversation After that we went on talking MLADIC was very friendly during the interview but got much more relaxed afterwards during the informal part of our conversation He wanted me to stay and discuss different topics with him BURA wanted to leave several times but MLADIC wanted to go on He was interested in my opinion about the situation about TUDJMAN about IZETBEGOVIC I could even argue with him about different subjects He did not get angry about that He said that he would even go to The Hague if The Tribunal would accuse somebody else I cannot recall the name of the person he mentioned but I remember that it was connected to the Vietnam war It is mentioned in the article ofuDer Spiegel That must be in the issue after the interview around 6 November 1994 You could ask for the issue at Der Spiegel in Hamburg I will provide the tape to you also About half an hour is not taped because the tape did not work I put some of the information in the article because I could remember details The article was not that long because at that time everybody expected him to resign I could have written many more pages about everything he mentioned At that time there was also a discussion ofa putsch against KARADZIC They said MLADIC refused to do that

The time after the taped part of the interview MLADIC was eager to have a discussion I asked him if it could be possible that he prefers to loose some ofthe territories that the Serbs had lost before through fighting instead ofgiving it back by negotiations He did not conform that but also did not deny it but said something to the effect that I might be right I asked that question because at that time the Serbs were loosing territory for the first time and it was negotiated that the Serbs would have to give back 20 of the 70 of the held territory

During the interview MLADIC said before that it was not discussible to give any territory back to the Muslims He said that the Muslims might keep the part of the country we let them keep and they might do with it whatever they want Only when I asked him if that would not be the contrary of what KARADZIC had stated MLADIC said that he was not a politician but a soldier MLADIC was totally convinced ofhis mission to save the Serbs Many other people had that impression MLADIC had a good sense ofhumor although people say he is traumatized That refers to the suicide ofhis daughter He said They killed her By that he meant that Serbs from Belgrade did that He seemed to be very eager to talk and he appreciated to be shown as the greatest It seemed as if he needs a lot of recognition I am quite sure that I asked MLADIC about ethnic cleansing but I cannot recall the precise answer I can listen to the tape again and afterwards tell you

MLADIC is a very cholerical person On one occasion when the negotiations about the Vance-Owen plan took place in Pale (I think that was in March 1994) he started yelling at me He got very angry when I asked him how the decisions will be made and was cursing the Germans On another occasion later on he apologised for that

I do not remember if spoke to MLADIC about the camps because that was not a topic at the time of the interview I remember that I spoke to him about the raped women He said that that was not true I think he totally denied I could check that with the tape

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I remember that I asked MLADIC about his position in the army I think he mentioned that he was the commander in charge of the army I remember that there were some quarrels between MLADIC and KARADZIC at that time I recall that that must have been the take over of Gorazde I remember that a soldier I do not remember the name) told me that MLADIC was very angry on KARADZIC because they had nearly taken over Gorazde when KARADZIC called the army back

MLADIC had a very negative opinion about UNPROFOR It was more a derogatory appearance which means he did not take them serious

I remember another interview with Biljana PLA VSIC That must be about three years ago in Belgrade in the Villa Bosna I arranged that simply by calling her on the telephone The conversation was not meant as an interview however I taped it I am not sure in still have the tape I can look that up for you Biljiana PLA VSIC appeared to be a hard~liner She seemed to hate MILOSEVIC I recall her saying that he was a communist devil Another impression I got was that KARADZIC was too liberal in her opinion However she always tried to avoid to appear as somebody who hates the Muslims in general

I do not believe that she has much influence on the leading persons She obviously had good connections with Arkan She was one ofthe four at the top of the Pale administration beside KARADZIC KRAJISNIK KOLJEVIC

I think that Alexander BUHA really had some influence He was first closely connected to MILOSEVIC and he stayed in Belgrade

I think I have interviewed BUHA about three times officially On these occasions I interviewed by way oftape recording and I wiJ) supply those tapes to you I had unofficial contact with him on numerous occasions for instance if I needed contact with KARADZIC or MLADIC He also called me on some occasions and asked me to come to his office in Belgrade which was the residence of the Bosnian Serbs in Belgrade On those occasions I would attend his office and he would speak to me unofficially and informally in relation to the situation in the fonner Yugoslavia He would often solicit my opinions as to what I thought and I could be very open with him I recall that when the Bosnian Serbs took the hostages I told him they had made the biggest mistake they had made as they had now become official terrorists in the eyes ofthe whole world He told me that it was okay and that he found it to be alright

The residence of the Bosnian Serbs was known as Villa Bosna in Belgrade BUHA and PLA VSIC seemed to be always there but they had to move to Pale when MILOSEVIC cut off all ties with the Bosnian Serbs The interview I did with him in relation to the hostages was in his office in Pale I had made arrangements with him the night before by contacting at his hotel Hotel Bistrica which is in the Jahorina mountains near Pale

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I have also interviewed the Mayor of Banja Luka RADIC I think after the time I visited Manjaca camp I am not sure ifI have the tape of that interview but I will look I know I mentioned him in my article and related to the destruction of the last mosque in Banja Luka

I have also interviewed General I think he is Bozo NOVAK This was a background talk and I still may have the tape but I will check I think this was in 1992 or 1993 1993 probably I do not know ifl still have the tape from this interview but I will attempt to locate it

I have also spoken to General GVERO the deputy to MLADIC This was in October 1995 He is the one who has the most problems with KARADZIC as KARADZIC wants to expel him It is well known that he is the man ofMILOSEVIC The interview was mostly about Srebrenica and the loss of territory the Bosnian Serbs were losing in the area of Klujc and Sanski Most I have a copy of this tape which I will hand over to you

During this interview I have told investigators about a potential I have had contact with over the past three years I had my last interview with this person on 25 and 26 January 1996 An article was published in Der Spiegel on Monday 29 January 1996 and the Serbian newspapers on Tuesday 26 January 1996 On Wednesday 27 January 1996 I received four serious telephone calls at my home which is also the same telephone number for my office The first call was from a male person who introduced himself as a scientist working for an institution in Holland I told him he was a Serb and he told me that he was not but that he was just interested He asked me whether there would be a follow up article in Der Spiegel whether the witness was still in the area nominated in the article and where this persons family were I told him that the area and the name used in the article for the witness may not be true and this appeared to confuse him

The second telephone call was also from a male person but he was different from the first It was from a Serb who was speaking German He threatened me with a typical Serb saying which is similar to The night will swallow you up I took this to be a serious threat to my safety I asked him who he was but he just told me that he was close to KARADZIC and MLADIC I just listened to the call and did not say anything and he just hung up

The third telephone call was also from a male person and different from the first two I think he was speaking Serbian He told me that I had a car and I was confused He told me to be careful when I went to the garage as there are a lot of bombs put under cars He then hung up

The fourth call was also a male person and different from the first three He was speaking Gennan and told me that he was an adviser to KARADZIC and MLADIC He was a Serb He then asked me what right I had to write about Bosnian Serbs when I was sitting in Belgrade and how could I insult Mr KARADZIC He again told me I had no right to do this I asked him how did he know that I wrote the article He told me that if I did not then I should immediately explain in the newspapers and correct

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the error otherwise I could be in very big danger He also asked my why I had not interviewed KARADZIC and MLADIC I did not tell him that I had I also asked him if he could get me an interview with them and he told me just to write down my questions for KARADZIC and supply them and he could get me an interview sometime next week When I first answered the telephone to this person he asked for Mr FLOTIAU which was the way my name was printed in the Serbian newspapers

[ did not know the voices of any ofthe persons who made these telephone calls

On 6 February 1996 I have supplied to the International Criminal Tribunal a copy of four audio tapes The first relates to an interview with KARADZIC on 17 May 1995 The other three tapes are in relation to the witness I have already spoken about above All four tapes are in the Serbian language

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WITNESS ACKNOWLEDGMENT

This Statement has been read over to me in the (11lt) ~ language and is true to the best of my knowledge and recollection I have given this Statement voluntarily and am aware that it may be used in legal proceedings before the International Criminal Tribunal for the Prosecution ofPersons Responsible for Serious Violations of International Law Committed in the Territory ofthe Former Yugoslavia since 1991 and that I may be called to give evidence in public before the Tribunal

SignedHUa1lt ~~- Dated ( Ill 1C b

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06853351

Memorandum

DATE July 8 1996

TO File

FROM Carolyn Edgerton

RE Meeting Notes George Eykyn July 18 1996

Meeting began at 1100 am Eykyn and I were the only ones present

-Eykyn has done about 5 times as much radio out of Bosnia as he has TV The significant atlrdction for him in his frequent visits to the former Yugoslavia has been the extent to which hes been able to travel especially in parts of the country otherwise closed off to jOllrnalists

-Eykyn has no problem with helping the ICTY and will provide all sorts of info off the record In court he will take the stand and confirm all his reports in the public domain However he would need convincing to go in the witness box for any other matters given all the implications this might have When asked about what these implications were Eykyn replied that in Northern Ireland (which he frequently covers) the cops have recently taken to relying on reporters to adduce evidence which theyre otherwise able but too lazy to get Riot footage is a good example They subpoena the reporter covering the incident and the tape They can and have prosecuted journalists who refuse to testify The cops have also subpoenaed reporters and their material to rub their nose in it forcing them to through the court ordeal as a form of harassment

Eykyn has never met Mladit Hes seen him up close Last autumn when Mladic and Karad1ic were having their scrap everyone thought KaradZic would end up in a car crash People in Belgrade were calling Karadiic one of the walking dead

-Bykyn was first in Bosnia in September 1992 initially covering a travelling celebrity aid convoy in Croatia But that ran out of money So the 4-member BBC team that Eykyn was a part of drove to Travnik where the convoy had been destined There they did a piece on Mujahadin fundamentalists They did the pieCe in the area of TravnikZenica and a village near Tmvnic The BBC crew chaUenged them The Muj took their cameramen up to Meharic Village There they met some Saudi guys (in white suits) who were clearly bankrolling the Muj (based on adnrissions received from the Bosnians

-Eykyn was working Breakfast News at the time He was supertluous to whatever the news was doing His assignment from Breakfast News had beenjust to do the aid convoy and go to Travnik in that context This one assignment led to Bykyns substantial involvement in coverage from Bosnia BBC had a rule - that ifyou hadnt been

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previously to the fonner Yugoslavia you couldnt go during the war As a result of this Travnik piece Eykyn then chanced to be on the list of people who had been

-other correspondents covered Sarajevo and BritBatt thoroughly Eykyn would tell BBC he wanted to go to the Serb side

-Eykyn was in former Yugoslavia a total of8 months between 1992-96 His stays were mostly of 3 weeks duration He collected his money cameraman and armoured car and often hed get to pick his story locations He was in GoraMe while it was under siege Brcko when it was otherwise closed off Theyd bring their rushes back to the UK with them

-in October-November 1992 Eykyn was in Croatia and Bosnia He was trying to do a story on a group called the Flying Tigers who were bringing aid into Bosnia He only ever saw the aid being carried inon a plane Eykyns contact with the group was an Austrian who he still has contact with in the investigation of allegations of weapons trafficking Austria Germany Britain America and Turkey are all alleged to have been sending weapons to the Bosnians Eykyn is looking for confinuation as to whether Britain was sending weapons to the Bosnian Muslims while the embargo was on

-in March 1993 Eykyn was in Serbia and Bosnia It was his first time into Pale He did pSpieces from the Sarajevo airport and from the hills around Sarajevo At that time Slavko Milanovic was running the press centre The Bosnian Serbs took them to Trebevic mountain They have shots of the armys special forces which were under the command of Major Radornir Kojic Eykyn knows Kojic and has met him loads of times Kojic held a certain section of the mountain At one point he had all the locals come up arid sit manning the line plus one or two more active soldiers The special forces wore red berets these locals wore whatever they could find for their uniforms The special forces tended to be younger

-during this same trip Eykyn was in Vadikovac Zlatiste Lukavica (not much on show there at the time hangars were half a kilometre away) and Vojkovici (open exposed ground under Igman) The party line from all Bosnian Serbs which Eykyn heard was Im only defending my territory Eykyn was in Grbavica where he saw tanks in the side-streets

-Eykyn interviewed KaraMic several times (press conferences) and met with him face to face on a number of occasions On all his trips into Bosnian Serb held territory Eykyn dealt fairly closely with Karadzic Koljevic and General Gvero

-in May 1993 Eykyn went to Lipik in Croatia to cover the story of a British Colonel who was rebuilding an orphanage there

-in August 1993 Eykyn went to Serbia and Bosma again He flew in to Budapest picked up a hire car there then went to Belgrade (Reuters there was well set up They should have good pictures) Then he was in Pale Foea Brcko and Doboj Eykyn had been conducting research monitoring the combat situations He wanted to go to the hottest place During his first trip into Pale he had already asked to go to Skelani but had been refused The fighting around Broko had been escalating in the period prior to his going out inlo the field He thinks he asked Slavko (in the press office) or Btanko (the minder) for access Branko appeared to have his own Bosnian Serb army contacts

2

94230IT-95-518-T

06853353

-in Brcko Branko put them in touch with Pero Simic at Radio Bijelina He knows Major Mauser Eykyn hasnt heard anything that might suggest the Panthers were comparable with the White Eagles etc in terms of their activities They were quite well-funded with money from outside pe()ple who had fled Bijelina Eykyn heard the Panthers were shunted from one front line to another Hasnt seen Dr heard anything that indicated criminality

-Eykyn went to FoeB before Brcko The drive took 2 112 hours on a winding road Eykyn named Jasmina Fisovic and mother Vasvija (from his October-November 1992 trip) He said they walked to Tarcin where he found them Contacted Kalshoeven about their information regarding atrocities in Foea When in Foea Eykyn was taken to the town hall He was introduced to the Deputy Mayor or Deputy President of the Municipality Libo Todovic Todovic asserted there had been no ethnic cleansing the Muslims has wanted to leave they had supplied the buses Took shots of Foeafrom up on the hillside In those Spictures can see the destroyed mosques Eykyn was told the only Muslim left inFoea was a jeweller He was told the jeweller refused to be interviewed Eykyn was taken to the hospital the graveyard (to show off the graves of people killed at Josanica) Eykyn asked to go to Jelec but they said it was a combat zone Eykyn was allowed to go to Josanica valley There were 10 hamlets around which were all piles of rubble Obviously troops of both sides had wandered through Eykyn supplied all the details regarding Josanica to Kalshoeven

-in Foe8 Eykyn was also taken to KP Dam Hes not sure whether Jasmina was held there or at the Partizan hall Later he found out about the Partizan He and his crew were not offered or al10wed ac~ess to it Eykyn and his crew did some illicit filming of KP Dam They did a long interview of Saban Kurtevic a night watchman there The

interview almost filled two rushes tapes which are 30 minutes long Eykyn questioned Kurtevic about events at KP Dom Theindividual who appeared to be in charge at KP Dom during their visit appears on a TV piece they cut They dont know his name He wore a blue uniform They met the security chief (may also be on film) He was in camo uniform His hair was grey at the sides

-from Foca Eykyn went to Bijeljina then Brcko Met up with man who used to be 3 in the Panthers Dusan Tuzlancic (Captain) Eykyn has heard hes had a breakdown and has been booted out of the Panthers But when they met him he was a war hero They interviewed the Mayor of Brcko Djordje Discussion was regarding the OwenshyStoltenburg plan flyover The Serbs wanted an integral corridor The crew did some filming at Kolomea near the railway line Then Dusko took them to the front line at Brka The crew could fee] how close it aU was There was plenty of shooting Then they dld more fihning in town On the way from Brcko to BijeJjina Eykyn was trying to milk Dusko regarding the details of war crimes in Brcko The crews interpreter at the time was Sinisa - from the Reuters office in Pale

-Dusko said that people were taken to BrckolLuka The killing was (he thought) 600 not 3000 people He took the team to the port He wouldnt let them go to the hangars They looked in through a crackin the door to the first one and saw a couple of wrecked cars inside Did an on-camera interview Off camera he said the floating down the river stories werent true He said there were obvious places to dispose of people He led Eykyn to believe there were one or two mass graves in open ground in the centre of

3

94229IT-95-518-T

06853354

Breko He described driving to the front with Major Mauser and seeing piles of bodies He said that Mauser apparently stopped Ielesic The crew didnt go to the dog food factory Jeiesic apparently has ajob processing food in Bijeljina Hes an embarrassment to the Serbs Pero Simic might know where to find Dusko You could approach Simic On the basis of finding out who the important people during the war were in Breko and

where they are living Eykyn cant remember if Tuzlancic was shown on camera He might have been injured during the war Eykyns opinion was that we need to get lelesic for the ICTY to have better credibility Dusko can tell us about lelesic and an old hotel Dusko says that Ielesic had people brought to the old hotel He lined them up in groups of 5 slapped them with a pistol interrogated them then shot them in groups of 5 The bodies were piled in front of the old hotel

-Eykyn heard that in Luka people were raped in front of their families

-Eykyn went to Brcko where they met up with Pare Simic THEN met Dusectko He took the crew to the Panthers base not far from the middle of Bijeljina The base had an airstrip It was a modern building which could at one time have been a school

-after Brcko Eykyn had to go Banja Luka to get pennission to travel to Doboj The Bosnitn Serb Army had a sophisticated press centre there Milutinovic ran it Eykyn spent one night in Banja Luka

-Eykyn wanted to go to the Maglaj finger the Serb forward base at Teslic They travelled to Doboj to see what they could do (mouth of the Ozran pocket) Doboj was being shelled at night and was firing shells Met the Serb corrunander went to a hillside not far from Doboj Serbs were on the lower slopes of the hill The Croats were fighting alongside the Serbs against the Muslims The HVO Brigade had their families let through Eykyn has some film of the hospital in Doboj It was Serb-run there were Croats in the beds The piece was on cooperation between the two factions

-in February 1994 Eykyn was still with the morning news He travelled to Serbia Bosnia and Pale He was planning to get into GordZele He had to get written permission from the Bosnian Serb anny to go to Gomde It was waiting for them when the crew arrived in ale Also Dragan Bulajic a member of the prisoner exchange commission

was there in Pale He had recently been to Goraifde and said he would take us there Then the marketplace massacre happened in Sarajevo and Eykyn was sent to cover the atrocity Afterwards he was allowed to stay on to try and get access into GoraZde Delays started and BBC pulled the news crew as they were not getting anywhere Eykyn remained Finally when he did get permission to travel to Goraide he was forced to use the Reuters camera team from Pale They were both Serbs They were taken in by Dragan Bulaji6 Ibey travelled towards GoraZde They went through the lines at Usti Prace They planned to have 2 112 hours on the ground in GoraZde They were to be out by nightfall Coming back out of GOraZde the two Reu~rs cameramen insisted they try to head directly for Pale and not check in with Dragan Eykyn believes that when Dragan learned he had been stood up he got angry and nlade sure the crew was stopped at Rogatica checkpoint They were detained for 5-6 hours The conten ts of their vehicle were strewn out onto the road I think Eykyn said that he was told they were detained at Dragans instruction by Major RaJko Kucic They were taken up to the barracks Captain Zoran was in charge of the Rogatica checkpoint

4

94228IT-95-518-T

-------------------~-- -~---

06853355

-Eykyn was forced to surrender tapes the crew had taken in Gorafde Col Sokanovi~ was the media liaison officer at HQ who insisted on the tapes Eykyn says that cvery time after that when he interviewed General Gvero his last question was Can I have my tape back which Gvero always refused In GoraZde that day there were no shells It was the quiet day Eykyn was the first reporter in a year to have access to the city In GoraZde they were not allowed to mm anything military nor did they see anything military They did interview the Muslim deputy commander in GoraZde whos name was Himso Eykyn saw a prisoner exchange deal engineered by Dragan in no-man s land Rimso represented the Muslim side Dragan was there with other Serbs The deal was that the Serbs were offering electricity in exchange for prisoners After Eykyn Jeft GoraZde the attack began

-in December 1994 Eykyn returned to Pale nominally to get into Bihac He spent two weeks in Pale very frustrated and was not allowed to travel outside of the town Everyone was very sensitive

-in February 1995 Eykyn was in Croatia He did a couple of pieces for Newsnight (he had left Breakfast News in April 1994) in Benkovac and RodaHce The pieces were about the UN mandate in Croatia- will there or wont there be another war Went to army HQ Zadar Followed Galbraith arms orchestration

-Eykyn was in Pale in June 1995 during the hostage-taking crisis He said that one or two of them were held in Pale possibly at the house just up from the press centre He thinks (from what he heard) the Brits were held in Visegrad

several times Karaampic told me I had permission to go to GoraZde Then whether or not Sonja Karadfic might have changed the position the next day the final decision as to my access rested with Mladic It was the anny who said yes or no often Mladic personally

-I was in Pale for voting over Owen-Stoltenberg Karadzic was persuading his parliament The Serbs weren t happy about the prospect of having to give up land He lost face Acceptance of peace plans Karadzic lost face again Also suffered a loss of face when Roses air strike ultimatum worked Military cultivating Kasagic to be stooge Banja Luka-Pale tension

~last fall Sonja Karadfic banned Eykyn from Pale after he wrote an article about her wedding calling it grotesque He got a message about his being barred from Pale pound0

Mladic via a Belgrade stringer The reply that came back from Mladi~ was Fuck Sonja he can come when he wants

-Eykyn gave copies of his notes regarding what Karadzic said during the course of his interviews to Tej Thapa

-Eykynknows Zametica well He describes him as intelligent enough but a total denialist who kept falling in and out of favour with Karadlic Eykyn and Zametica used to have lots of late-night briefings

-Eykyn interviewed Gvero two or three times Sue Hein interviewed Major Rajko Kusic from Rogatica

-to get access to militarily restricted areas the minder would have to call Han Pijesak Eykyn assumes that petmission would have come from there via Sokanovic or

5

--- _----------------------------shy

94227IT-95-518-T

i

06853356 MHutinovic Eykyn interviewed Kovacevic regarding the airstrikes ultimatum andmiddot Gveros Chief of Staff Gen Miluvanovi6 on whether they would pull the weapons back

-Eykyn interviewed Karadfic regarding the obstruction of relief top the enclaves and the plight of people in the enclaves Hes also interviewed Zametica Koljevic Lukic Slavisa Rakovic and Toholj

-Eykyn went to Kula in March 1993 He saw 50-60 prisoners there no women Most were Moslems but one or two were Serbs held on ordinary charges Most of the prisoners were going out on work details AU seemed to have been fed

-Eykyn was in Sarajevo for a total of only approximately 1 112 months throughout the war February 94 - 4 days December 94 - 1 day October 95 - 1 montb April 96 - 2 weeks He has been to Grbavica comments that there was similar sniping on that side as there was on the other side Saw a Serb command post there 2-3 tanks in the neighbourhood While in Grbavica their escort was named Drazen Eykyn describes him as being the editor of the Serb version of Os lobodenj e Filming was restricted in Grbavica (Eykyn describes it as their message our piece) Eykyn was taken to a building tIlat he believes was a sniper position - close to the river (less than 100 metres away) from which you could see the Marshal Tito Barracks and had a good view of the Holiday Inn

-Eykyn never did the British Army tour The commander of Travnik was Dzoko Dzukj Andric

-regarding hostage-taking Nikola Waite (RibiC) was the English-speaking Serb who threatened the UNMOs over the airwaves to General Smith He told me he was a member of the Bell Vukovi and reported directly to General Milosevic He wore a red beret as did the people often seen with him (he went around with two sidekicks) They also tended to be better anned and carry better quality weapons Eykyn first saw him at the Hotel Bistrica (in May 1995) He made contact with him to find out information regarding the Muslim offensive Waite said he could get Eykyn anywhere but it had to be in Serb uniform Eykyn then refused They had pbone contact a few days after that Waite had quarters Eykyn believes in the same building as SRNA

-Eykyn provided contact numbers for the Mayor of Breko which can be obtained through mc

6

94226IT-95-518-T

ANNEX C

No IT-95-518-T 8

94225IT-95-518-T

CONFIDENTIAL WORK PRODUCT OF TEAM 1 INVESTIGATORS NOTES 06 488549

NOT A SIGNED STATEMENT NOT ADOPTED BY THE WITNESS NOT FOR DISCLOSURFJUSE IN TRIAL IN THlS FORM

SENSITIVE HANDLING REQUIRED CONTACT TEAM BEtORE USlNG

Name Zivko Boiic Screened by Mazhar Inayat Others present Joanna Komer Zijad Ibric and interpreter Date of screening 2 June 2000

Investigators notes

During the conflict in Bosnia tillko Bojic a police officer serving in Banja Luka was arrested by the Federation forces During his detention he recorded a written statemelll The statement was subsequently turned over to the OTP In his statement Bojit alleges to atrocities committed by Serbs After reading the statement it was decided to approach Bojic to confirm if what he had alleged in his statement was voluntarily expressed by him Whereabouts of Bojic were confirmed by the AID officials in Sanski Most who also assisted in setting up a meeting with Bojic in Banja poundUka The meeting took place on 2 June 2000 in the Kastle restaurant in Banja Luka It was attended by investigator Mazhar Inayat STA Joanna Korner AID official Zijad Ibric tivko Bojic and an interpreter Following are the screening notes emanating from the screening ofBojit

Screening Notes

Bojic pointed out that he has lived in Banja Luka all his life He joined the police force in 1973 After joining the force he attended the police academy in Sarajevo

Bojic claims to have spoken to international organisations on 5-6 occasions He also claims that on 1-2 occasions he was approached and spoken to by staff members of the OTP The contact by OTP staff happened after the car bombing of jownalist Kopanja Bojic believes that this contact happened around 3 months ago According to Bojic the staff members did not gjve him their names nor showed him their identity cards Bojic further stated that the staff members included a male a female and an interpreter The questions put to him were focused on the journalist He was not asked anything pertaining to the 1992 contlict in Bosnia

When asked if he would be prepared to give a statement which could take two days to complete Bojic indicated his willingness to do so However he added that he would require three days notice before the interview Bojic requested that he is faxed on the following number to set up an appointment for his interview 051 217093

On the question of his statement given to the Federation forces after his arrest in 1995 Bojic stated that he would first need to read the text to confirm whether he stands behind what he stated However Bojic went on to add that he believes that 80 of what he said would probably be correct and he should be able to endorse that Bojic recalled that his statement to the federation forces was relevant to the 1991-1995 period

CONFIDENTIAL WORK PRODUCT

94224IT-95-518-T

CONFIDENTIAL WORK PRODUCT OF TEAM 1 06488550INVESTIGATORS NOTES NOT A SIGNED STATEMENT NOT ADOPTED BY THE WITNESS

NOT FOR DISCLOSURFJUSE IN TRIAL IN TIllS FORM SENSITIVE HANDLING REQUlRED CONTACT TEAM BEFORE USING

When asked to explain what was the police structure under the CSB and how it worked Bojic recommended that to understand the police structure that existed in Banja Luka one needs to go through the CSB document that was seized by the SFOR in July-August 1997 from the CSB headquarters (Investigators notes I believe Bojit is probably referring to the OTP search and seizure mission in Banja LuIw that happened on 27 Februnry 1998) Bojic however indicated that in his formal interview he should be able to talk at length about it Bojic stated that in 1992 the CSB Banja Luka controlled a large region including Banja Lub Prijedor and the region included Jajce and Sipovo

Bojic claims that he is quite aware of the activities that happened within the CSB headquarters in 1992 He knows all those who were attending meetings there He claims that within the CSB there were two structures One was the official structure and command The other one was CSBs relationship with new structures that had been set up and which were unofficial Bojic believes that he is in a position to talk extensively on this in his fonnal interview Bojic claims that he was part of the official structure and did not approve of CSBs relations with unofficial structures and it was due to this reason that he left the police in July 1992 Most of his information on the activities of the CSB would be relevant to the period leading up to July 1992 After July 1992 what he knows of the CSB activities is what he learnt from his sources Bojic pointed out that in March 1994 he rejoined the police and went back to theCSB

Before leaving the police in July 1992 Bojit was the chief of the criminal department He took over this position in January 1992 During the six months period he had the opportUnity to meet the CSB commander every second day He wasnt considered being close to the high-ups because he had the reputation of being the black sheep in the department His wife not being a Serb added to his problems Although he attended CSB meetings where official decisions were being considered but when the Crisis Staff took the decision he was not present Bojic believes that most of what is relevant to the OTP for the 1992 period Bojic was not involved in it

Bojie believes that the CSB Chief was a member of the ARK crisis staff and stated that other members included Brdanin Talit Kupresanin and some others He stated that the CSB chief attended the crisis staff meetings but does not know how often He doesnt believe that the ARK crisis staff mectings were announced However some crisis staff decisions were made public and the police too were informed about them Bojic stated that after attending the crisi s staff meetings the CSB chief would call his own meetings which were attended by the commanders of the police stations In such meetings the chief would give infonnation relevant to the commanders I believe the chief also held meetings within the CSB with officers considered being in the chiefs inner circle Bojic pointed out that he was not considered to be part of the inner circle of the chief Bojic stated that those who were considered close to the CSB chief were Nedeljko Kesic Dure Bullc and Steven Markovic Bojic indicated that Duro Bulie was his immediate boss and died recently Bojic also stated that Stevan Markovic died in Kotor Varos in 1992

2


94223IT-95-518-T

CONFIDENTIAL WORK PRODUCT OF TEAM 1 06488551 INVESTIGATORS NOTES

NOT A SIGNED STATEMENT NOT ADOPfED BY THE WITNESS NOT FOR DISCLOSURFlUSE IN TRIAL IN TInS FORM

SENSITIVE HANDLING REQUIRED CONTACT TEAM BEFORE USING

Bojic infonned that there were meetings between the CSB chief and the Corps headquarters Bojic is certain that the CSB chief went to the Corps Headquarters for meetings but doesnt knows how often He pointed out that officers from the Corps Headquarters also visited the CSB for meetings One such officer who visited the CSB was general Subotic Bojic stated that security officers of the military also visited the eSB One such officer who often carne was Milan Stevilovic who was the chief of security in the 1st Krajina Corps Bojic indicated that Stevilovic along with Bojics colleague Markovic was killed in Kotor Varos in a car explosion in 1992

On the question whether Brdanin or Kupresanin visited the CSB Bojic stated that he was not certain about their visits however the two often spoke to the CSB chief on telephone

Bojic indicated that the ARK crisis staff meetings would be held in the municipal building in Banja Luka The ARK held the meetings in offices that were in their use These offices probably were on the second floor of the building Once again Bojic pointed out that last year the SFOR removed documents from the rooms that were in the use of the ARK Bojic is not certain if it was Brdanin or Kupresanin that headed the ARK crisis staff Bojic claims that he was not present in the ARK crisis staff meetings but that he would learn about them from television news or from their press conferences reported in the media Bojic pointed out that once Brdanin SUbotic and Milan Trhojevit attended a public meeting The discussions were about Muslims serving in the government Bojic recalled that both Brdanin and Subotic were making stupid comments and appeared to be extreme nationalists However Trbojevic appeared normal Bojic did not tape the proceedings

Bojic stated that he has been to Kotor Varas only once and that was when his colleague Steven Markovic was killed in the car bombing He believes that the attack on Kotor Varos wai carried out by the special units that were sent from Banja Luka He recalls seeing the preparations of the special uni[S when they paraded through Banja Luka At the time the city was full of policemen and the anny

When questioned on the events of 3n1 April 1992 in Banja Luka Bojic stated that on that day there was widespread criminal activity in the city Bojic doesnt know who was directing the activity or who was responsible for it However around this time the SOS was fonned The SOS consisted of approximately 1000 men who were mainly criminals Officially they were not under the control of the eSB but it is possible that the SOS was under the control of the SDS He remembers that that day there were roadblocks set up by the SOS who had stolen anns from the JNA annoury These criminals then started to rob the people Non-Serbs were dismissed and this continued for many days Bojic pointed out that on 3rd April 1992 the 80S hanned even Serbs Bojic believes that 3r April 1992 was understood to be the official day when war started in the region Bojic stated that the reason given for starting the war was that a fax sent by lzetbegovic to block army barracks in 70 cities was seized by the Serb forces Bojic believes that such a fax did not exist and it was merely a mmour that was spread to justify the events that followed

3


94222IT-95-518-T

CONFIDENTIAL WORK PRODUCT OF TEAM 1 0 6 4 8 8 5 52 INVESTIGATORS NOTES

NOT A SIGNED STATEMENT NOT ADOPTED BY THE WITNESS NOT FOR DISCLOSURElUSE IN TRIAL IN TIllS FORM


On the question as to what role the CSB played in setting up detention camps Bojic pointed out that he honestly believes that the CSB had no role in setting up camps Boji$ insisted that his opinion was based on facts He believes that the SDS and the army against the will of the CSB set up the camps in Prijedor Bojic claims to be present with Zupljanin Kesic and Vladimir Tutus in the CSB building when they heard about the setting up of camps All the above reacted strongly against such a step Bojic claims that he separately also spoke to the above and again they reacted by saying that they were against such a thing Bojic alleged that Simo Drljaca was the main culprit because he involved the Prijedor police in setting up the camps Although Drlja~a officially reported to the CSB but he was not complying with CSB instructions and stopped obeying it

Bojic stated tbat according to his knowledge some police inspectors from Banja Luka were visiting Omarska camp but they went there mainly to calm things down Bojic does not recall the names of the police inspectors from Banja Luka who visited Omarska camp

On the question of dismissals of non-Serb police officers Boji$ stated that an police officers were instructed to sign loyalty to the government and to put on the new police insignias Bojic stated that those non-Serbs who refused to comply with the instructions were dismissed On the question of what he knew on the destruction of religious and cultural property Bojic stated that he has not made any enquiries into the matter personally because in the summer of 1992 he left the police After he left the police he spent one month in hospital due to some infection

On the question of the massacre on Vlasic mountain Bojic stated that although he was not privy to the enquiries that were conducted after the incident however he believes that the crime actually did occur and that at the time he bad heard about it He believes that the Prijedor police was responsible for the massacre Bojic also recalled that after the incident there was a conflict between the military and the civilian police on this issue Bojic believes that since the massacre happened in the war rone it was the responsibility of the army to conduct an enquiry Bojic indicated that the enquiry report of Jevto Jankovic into the massacre should be available in the courthouse

Bojic believes that although Zupljanin knew about the existence of camps but that Zupljanin couldnt do anything about it At that time small Napoleons had become gods and did not listen to anybody Bojic claims that Zupljanin could not officially dismiss Drljaea Bojic further added that formally if Zupljanin had dismissed Drljaca the decision would not have had any effect Bojic went on to add that even the ARK crisis staff could not dismiss Drljaca without the help of the local Prijedor crisis staff

On the question of distribution of weapons Bojic stated that once a Serb called Danilo Narancic who had gone to school with him came to his apartment and told Bojic that he was offered an automatic gun and 150 rounds of bullets Narancic refused to accept the weapon and left for Belgrade Bojic further added that the person most responsible for distributing the weapons was a doctor called Bilbia Bojic couldnt

4


94221IT-95-518-T


NOT A SIGNED STATEMENT NOT ADOPTED BY THE WITNF8S NOT FOR DlSCLOSURFJUSE IN TRIAL IN TIllS FORM

SENSITIVE HANDLING REQUIRED CONTAC1 TEAM BEFORE USING

recall the first name ofBilbia Bojic indicated that Bilbia was a top class surgeon and that Bojic s son worked Wlder Bilbia Narancic was offered the weapon by Bilbia

Bojic pointed out that although war crimes were committed in the area of the ARK region but that those were confined to Prijedor municipality and to Vlasic massacre Bojic insisted that no war crimes were committed in Banja Luka Bojic claims that the ARK crisis staff can be held only responsible for not ordering enquiries into war crimes He believes that Zupljanin did order enquiries into war crimes On the question whether Zupljanin would be prepared to meet with the OTP to explain his part Bojic stated that he last saw Zupljanin 6 months ago He believes that Zupljanin is scared that Zupljanin would be arrested for indictment Bojic further indicated that he personally cannot help in arranging a meeting between Zupljanin and the OTP but believes that Nedeljko Kesic could arrange such a meeting Bojic also added that in his opinion Zupljanin is not a war criminal

END OF SCREENING

5


94220IT-95-518-T

1 Dr Radovan Karadzic respectfully moves for a finding that the prosecution

has once again violated its disclosure obligations pursuant to Rule 68 by failing to

disclose exculpatory material and for remedial measures The material that is the subject

of this motion was not disclosed until 2 October 2015 one year after the trial concluded l

Renate Flottau statement

21tem 1 is a 1996 ICTY statement of Renate Flottau who worked as a

correspondent for Der Spiegel during the war2 In her statement Ms Flottau provided

inter alia the following information

(A) Dr Karadzic told her during an interview that crimes in the camps were committed by Serb refugees from other parts and that he could not control them He said that those responsible will be before the Court3

(8) Dr Karadzic told her that expUlsion of the Muslims was not his policy and that some Serb nationals and disappointed Serb refugees were carrying out those crimes and making the Muslims flee He said that they would be punished for these crimes in his Courts4

(C) Dr Karadzic told her that there were no civilians in the camps only f 5prIsoners 0 war

3 The exculpatory nature of this information is that it refutes the prosecutions

claims that Dr Karadzic had the mens rea required for the crimes in the municipalities

with which he is charged The contemporaneous statements of Dr Karadzic in 1992 also

corroborate the defence he offered at trial in 2012

4 Dr Karadzic was prejudiced by the prosecutions failure to disclose the

statement because he could have attempted to interview Ms Flottau and call her as a

witness for his defence

5 The prosecutions failure to disclose this statement is egregious because it

involves statements by the accused A simple word search for Karadzic in the

1 On 2 and 12 October 2015 the prosecution disclosed 11373 items totaling approximately 186915 pages of potentially exculpatory material some of which may be duplicates of material disclosed earlier Dr Karadzic has no defence team during this period and does not have the resources to review this material in toto but has selected some examples for the purpose of this motion 2 The statement is attached as Annex A 3 Annex A p 3 4 Annex A p 4 5 Annex A p 5

No IT -95-518-T 2

94247IT-95-518-T



George Eykyn notes









criminal enterprise






Zivko Bojic report






No JT-9S-SI18-T 3

94246IT-95-518-T





crimes



defence

Conclusion
















prosecution


No IT -95-518-T 4

94245IT-95-518-T

Word count 1107


f~ Radovan Karadzic

No IT-9S-SI18-T S

94244IT-95-518-T

ANNEX A

No IT-95-518-T 6

94243IT-95-518-T



WITNESS STATEMENT

WITNESS INFORMATION












oori3760

94242IT-95-518-T

vnTNESSSTATENUENT







00373761 (~

94241IT-95-518-T

2







00373762 2 ~ L (1A 4

94240IT-95-518-T

3





00373763 I)l ~

94239IT-95-518-T

4








00373764

94238IT-95-518-T

5






5

94237IT-95-518-T

6








ijO~73706

94236IT-95-518-T

7








94235IT-95-518-T

8




tHiti37a8

8

94234IT-95-518-T




OOit73739

94233IT-95-518-T

ANNEX B

No IT -95~5118-T 7

94232IT-95-518-T

r-----------------------~~-----

06853351

Memorandum

DATE July 8 1996

TO File









94231IT-95-518-T

06853352










2

94230IT-95-518-T

06853353







3

94229IT-95-518-T

06853354









4

94228IT-95-518-T

-------------------~-- -~---

06853355













5

--- _----------------------------shy

94227IT-95-518-T

i








6

94226IT-95-518-T

ANNEX C

No IT-95-518-T 8

94225IT-95-518-T





Investigators notes


Screening Notes






94224IT-95-518-T







2


94223IT-95-518-T









3


94222IT-95-518-T










4


94221IT-95-518-T






END OF SCREENING

5


94220IT-95-518-T



George Eykyn notes









criminal enterprise






Zivko Bojic report






No JT-9S-SI18-T 3

94246IT-95-518-T





crimes



defence

Conclusion
















prosecution


No IT -95-518-T 4

94245IT-95-518-T

Word count 1107


f~ Radovan Karadzic

No IT-9S-SI18-T S

94244IT-95-518-T

ANNEX A

No IT-95-518-T 6

94243IT-95-518-T



WITNESS STATEMENT

WITNESS INFORMATION












oori3760

94242IT-95-518-T

vnTNESSSTATENUENT







00373761 (~

94241IT-95-518-T

2







00373762 2 ~ L (1A 4

94240IT-95-518-T

3





00373763 I)l ~

94239IT-95-518-T

4








00373764

94238IT-95-518-T

5






5

94237IT-95-518-T

6








ijO~73706

94236IT-95-518-T

7








94235IT-95-518-T

8




tHiti37a8

8

94234IT-95-518-T




OOit73739

94233IT-95-518-T

ANNEX B

No IT -95~5118-T 7

94232IT-95-518-T

r-----------------------~~-----

06853351

Memorandum

DATE July 8 1996

TO File









94231IT-95-518-T

06853352










2

94230IT-95-518-T

06853353







3

94229IT-95-518-T

06853354









4

94228IT-95-518-T

-------------------~-- -~---

06853355













5

--- _----------------------------shy

94227IT-95-518-T

i








6

94226IT-95-518-T

ANNEX C

No IT-95-518-T 8

94225IT-95-518-T





Investigators notes


Screening Notes






94224IT-95-518-T







2


94223IT-95-518-T









3


94222IT-95-518-T










4


94221IT-95-518-T






END OF SCREENING

5


94220IT-95-518-T





crimes



defence

Conclusion
















prosecution


No IT -95-518-T 4

94245IT-95-518-T

Word count 1107


f~ Radovan Karadzic

No IT-9S-SI18-T S

94244IT-95-518-T

ANNEX A

No IT-95-518-T 6

94243IT-95-518-T



WITNESS STATEMENT

WITNESS INFORMATION












oori3760

94242IT-95-518-T

vnTNESSSTATENUENT







00373761 (~

94241IT-95-518-T

2







00373762 2 ~ L (1A 4

94240IT-95-518-T

3





00373763 I)l ~

94239IT-95-518-T

4








00373764

94238IT-95-518-T

5






5

94237IT-95-518-T

6








ijO~73706

94236IT-95-518-T

7








94235IT-95-518-T

8




tHiti37a8

8

94234IT-95-518-T




OOit73739

94233IT-95-518-T

ANNEX B

No IT -95~5118-T 7

94232IT-95-518-T

r-----------------------~~-----

06853351

Memorandum

DATE July 8 1996

TO File









94231IT-95-518-T

06853352










2

94230IT-95-518-T

06853353







3

94229IT-95-518-T

06853354









4

94228IT-95-518-T

-------------------~-- -~---

06853355













5

--- _----------------------------shy

94227IT-95-518-T

i








6

94226IT-95-518-T

ANNEX C

No IT-95-518-T 8

94225IT-95-518-T





Investigators notes


Screening Notes






94224IT-95-518-T







2


94223IT-95-518-T









3


94222IT-95-518-T










4


94221IT-95-518-T






END OF SCREENING

5


94220IT-95-518-T

Word count 1107


f~ Radovan Karadzic

No IT-9S-SI18-T S

94244IT-95-518-T

ANNEX A

No IT-95-518-T 6

94243IT-95-518-T



WITNESS STATEMENT

WITNESS INFORMATION












oori3760

94242IT-95-518-T

vnTNESSSTATENUENT







00373761 (~

94241IT-95-518-T

2







00373762 2 ~ L (1A 4

94240IT-95-518-T

3





00373763 I)l ~

94239IT-95-518-T

4








00373764

94238IT-95-518-T

5






5

94237IT-95-518-T

6








ijO~73706

94236IT-95-518-T

7








94235IT-95-518-T

8




tHiti37a8

8

94234IT-95-518-T




OOit73739

94233IT-95-518-T

ANNEX B

No IT -95~5118-T 7

94232IT-95-518-T

r-----------------------~~-----

06853351

Memorandum

DATE July 8 1996

TO File









94231IT-95-518-T

06853352










2

94230IT-95-518-T

06853353







3

94229IT-95-518-T

06853354









4

94228IT-95-518-T

-------------------~-- -~---

06853355













5

--- _----------------------------shy

94227IT-95-518-T

i








6

94226IT-95-518-T

ANNEX C

No IT-95-518-T 8

94225IT-95-518-T





Investigators notes


Screening Notes






94224IT-95-518-T







2


94223IT-95-518-T









3


94222IT-95-518-T










4


94221IT-95-518-T






END OF SCREENING

5


94220IT-95-518-T

ANNEX A

No IT-95-518-T 6

94243IT-95-518-T



WITNESS STATEMENT

WITNESS INFORMATION












oori3760

94242IT-95-518-T

vnTNESSSTATENUENT







00373761 (~

94241IT-95-518-T

2







00373762 2 ~ L (1A 4

94240IT-95-518-T

3





00373763 I)l ~

94239IT-95-518-T

4








00373764

94238IT-95-518-T

5






5

94237IT-95-518-T

6








ijO~73706

94236IT-95-518-T

7








94235IT-95-518-T

8




tHiti37a8

8

94234IT-95-518-T




OOit73739

94233IT-95-518-T

ANNEX B

No IT -95~5118-T 7

94232IT-95-518-T

r-----------------------~~-----

06853351

Memorandum

DATE July 8 1996

TO File









94231IT-95-518-T

06853352










2

94230IT-95-518-T

06853353







3

94229IT-95-518-T

06853354









4

94228IT-95-518-T

-------------------~-- -~---

06853355













5

--- _----------------------------shy

94227IT-95-518-T

i








6

94226IT-95-518-T

ANNEX C

No IT-95-518-T 8

94225IT-95-518-T





Investigators notes


Screening Notes






94224IT-95-518-T







2


94223IT-95-518-T









3


94222IT-95-518-T










4


94221IT-95-518-T






END OF SCREENING

5


94220IT-95-518-T



WITNESS STATEMENT

WITNESS INFORMATION












oori3760

94242IT-95-518-T

vnTNESSSTATENUENT







00373761 (~

94241IT-95-518-T

2







00373762 2 ~ L (1A 4

94240IT-95-518-T

3





00373763 I)l ~

94239IT-95-518-T

4








00373764

94238IT-95-518-T

5






5

94237IT-95-518-T

6








ijO~73706

94236IT-95-518-T

7








94235IT-95-518-T

8




tHiti37a8

8

94234IT-95-518-T




OOit73739

94233IT-95-518-T

ANNEX B

No IT -95~5118-T 7

94232IT-95-518-T

r-----------------------~~-----

06853351

Memorandum

DATE July 8 1996

TO File









94231IT-95-518-T

06853352










2

94230IT-95-518-T

06853353







3

94229IT-95-518-T

06853354









4

94228IT-95-518-T

-------------------~-- -~---

06853355













5

--- _----------------------------shy

94227IT-95-518-T

i








6

94226IT-95-518-T

ANNEX C

No IT-95-518-T 8

94225IT-95-518-T





Investigators notes


Screening Notes






94224IT-95-518-T







2


94223IT-95-518-T









3


94222IT-95-518-T










4


94221IT-95-518-T






END OF SCREENING

5


94220IT-95-518-T

vnTNESSSTATENUENT







00373761 (~

94241IT-95-518-T

2







00373762 2 ~ L (1A 4

94240IT-95-518-T

3





00373763 I)l ~

94239IT-95-518-T

4








00373764

94238IT-95-518-T

5






5

94237IT-95-518-T

6








ijO~73706

94236IT-95-518-T

7








94235IT-95-518-T

8




tHiti37a8

8

94234IT-95-518-T




OOit73739

94233IT-95-518-T

ANNEX B

No IT -95~5118-T 7

94232IT-95-518-T

r-----------------------~~-----

06853351

Memorandum

DATE July 8 1996

TO File









94231IT-95-518-T

06853352










2

94230IT-95-518-T

06853353







3

94229IT-95-518-T

06853354









4

94228IT-95-518-T

-------------------~-- -~---

06853355













5

--- _----------------------------shy

94227IT-95-518-T

i








6

94226IT-95-518-T

ANNEX C

No IT-95-518-T 8

94225IT-95-518-T





Investigators notes


Screening Notes






94224IT-95-518-T







2


94223IT-95-518-T









3


94222IT-95-518-T










4


94221IT-95-518-T






END OF SCREENING

5


94220IT-95-518-T

2







00373762 2 ~ L (1A 4

94240IT-95-518-T

3





00373763 I)l ~

94239IT-95-518-T

4








00373764

94238IT-95-518-T

5






5

94237IT-95-518-T

6








ijO~73706

94236IT-95-518-T

7








94235IT-95-518-T

8




tHiti37a8

8

94234IT-95-518-T




OOit73739

94233IT-95-518-T

ANNEX B

No IT -95~5118-T 7

94232IT-95-518-T

r-----------------------~~-----

06853351

Memorandum

DATE July 8 1996

TO File









94231IT-95-518-T

06853352










2

94230IT-95-518-T

06853353







3

94229IT-95-518-T

06853354









4

94228IT-95-518-T

-------------------~-- -~---

06853355













5

--- _----------------------------shy

94227IT-95-518-T

i








6

94226IT-95-518-T

ANNEX C

No IT-95-518-T 8

94225IT-95-518-T





Investigators notes


Screening Notes






94224IT-95-518-T







2


94223IT-95-518-T









3


94222IT-95-518-T










4


94221IT-95-518-T






END OF SCREENING

5


94220IT-95-518-T

3





00373763 I)l ~

94239IT-95-518-T

4








00373764

94238IT-95-518-T

5






5

94237IT-95-518-T

6








ijO~73706

94236IT-95-518-T

7








94235IT-95-518-T

8




tHiti37a8

8

94234IT-95-518-T




OOit73739

94233IT-95-518-T

ANNEX B

No IT -95~5118-T 7

94232IT-95-518-T

r-----------------------~~-----

06853351

Memorandum

DATE July 8 1996

TO File









94231IT-95-518-T

06853352










2

94230IT-95-518-T

06853353







3

94229IT-95-518-T

06853354









4

94228IT-95-518-T

-------------------~-- -~---

06853355













5

--- _----------------------------shy

94227IT-95-518-T

i








6

94226IT-95-518-T

ANNEX C

No IT-95-518-T 8

94225IT-95-518-T





Investigators notes


Screening Notes






94224IT-95-518-T







2


94223IT-95-518-T









3


94222IT-95-518-T










4


94221IT-95-518-T






END OF SCREENING

5


94220IT-95-518-T

4








00373764

94238IT-95-518-T

5






5

94237IT-95-518-T

6








ijO~73706

94236IT-95-518-T

7








94235IT-95-518-T

8




tHiti37a8

8

94234IT-95-518-T




OOit73739

94233IT-95-518-T

ANNEX B

No IT -95~5118-T 7

94232IT-95-518-T

r-----------------------~~-----

06853351

Memorandum

DATE July 8 1996

TO File









94231IT-95-518-T

06853352










2

94230IT-95-518-T

06853353







3

94229IT-95-518-T

06853354









4

94228IT-95-518-T

-------------------~-- -~---

06853355













5

--- _----------------------------shy

94227IT-95-518-T

i








6

94226IT-95-518-T

ANNEX C

No IT-95-518-T 8

94225IT-95-518-T





Investigators notes


Screening Notes






94224IT-95-518-T







2


94223IT-95-518-T









3


94222IT-95-518-T










4


94221IT-95-518-T






END OF SCREENING

5


94220IT-95-518-T

5






5

94237IT-95-518-T

6








ijO~73706

94236IT-95-518-T

7








94235IT-95-518-T

8




tHiti37a8

8

94234IT-95-518-T




OOit73739

94233IT-95-518-T

ANNEX B

No IT -95~5118-T 7

94232IT-95-518-T

r-----------------------~~-----

06853351

Memorandum

DATE July 8 1996

TO File









94231IT-95-518-T

06853352










2

94230IT-95-518-T

06853353







3

94229IT-95-518-T

06853354









4

94228IT-95-518-T

-------------------~-- -~---

06853355













5

--- _----------------------------shy

94227IT-95-518-T

i








6

94226IT-95-518-T

ANNEX C

No IT-95-518-T 8

94225IT-95-518-T





Investigators notes


Screening Notes






94224IT-95-518-T







2


94223IT-95-518-T









3


94222IT-95-518-T










4


94221IT-95-518-T






END OF SCREENING

5


94220IT-95-518-T

6








ijO~73706

94236IT-95-518-T

7








94235IT-95-518-T

8




tHiti37a8

8

94234IT-95-518-T




OOit73739

94233IT-95-518-T

ANNEX B

No IT -95~5118-T 7

94232IT-95-518-T

r-----------------------~~-----

06853351

Memorandum

DATE July 8 1996

TO File









94231IT-95-518-T

06853352










2

94230IT-95-518-T

06853353







3

94229IT-95-518-T

06853354









4

94228IT-95-518-T

-------------------~-- -~---

06853355













5

--- _----------------------------shy

94227IT-95-518-T

i








6

94226IT-95-518-T

ANNEX C

No IT-95-518-T 8

94225IT-95-518-T





Investigators notes


Screening Notes






94224IT-95-518-T







2


94223IT-95-518-T









3


94222IT-95-518-T










4


94221IT-95-518-T






END OF SCREENING

5


94220IT-95-518-T

7








94235IT-95-518-T

8




tHiti37a8

8

94234IT-95-518-T




OOit73739

94233IT-95-518-T

ANNEX B

No IT -95~5118-T 7

94232IT-95-518-T

r-----------------------~~-----

06853351

Memorandum

DATE July 8 1996

TO File









94231IT-95-518-T

06853352










2

94230IT-95-518-T

06853353







3

94229IT-95-518-T

06853354









4

94228IT-95-518-T

-------------------~-- -~---

06853355













5

--- _----------------------------shy

94227IT-95-518-T

i








6

94226IT-95-518-T

ANNEX C

No IT-95-518-T 8

94225IT-95-518-T





Investigators notes


Screening Notes






94224IT-95-518-T







2


94223IT-95-518-T









3


94222IT-95-518-T










4


94221IT-95-518-T






END OF SCREENING

5


94220IT-95-518-T

8




tHiti37a8

8

94234IT-95-518-T




OOit73739

94233IT-95-518-T

ANNEX B

No IT -95~5118-T 7

94232IT-95-518-T

r-----------------------~~-----

06853351

Memorandum

DATE July 8 1996

TO File









94231IT-95-518-T

06853352










2

94230IT-95-518-T

06853353







3

94229IT-95-518-T

06853354









4

94228IT-95-518-T

-------------------~-- -~---

06853355













5

--- _----------------------------shy

94227IT-95-518-T

i








6

94226IT-95-518-T

ANNEX C

No IT-95-518-T 8

94225IT-95-518-T





Investigators notes


Screening Notes






94224IT-95-518-T







2


94223IT-95-518-T









3


94222IT-95-518-T










4


94221IT-95-518-T






END OF SCREENING

5


94220IT-95-518-T




OOit73739

94233IT-95-518-T

ANNEX B

No IT -95~5118-T 7

94232IT-95-518-T

r-----------------------~~-----

06853351

Memorandum

DATE July 8 1996

TO File









94231IT-95-518-T

06853352










2

94230IT-95-518-T

06853353







3

94229IT-95-518-T

06853354









4

94228IT-95-518-T

-------------------~-- -~---

06853355













5

--- _----------------------------shy

94227IT-95-518-T

i








6

94226IT-95-518-T

ANNEX C

No IT-95-518-T 8

94225IT-95-518-T





Investigators notes


Screening Notes






94224IT-95-518-T







2


94223IT-95-518-T









3


94222IT-95-518-T










4


94221IT-95-518-T






END OF SCREENING

5


94220IT-95-518-T

ANNEX B

No IT -95~5118-T 7

94232IT-95-518-T

r-----------------------~~-----

06853351

Memorandum

DATE July 8 1996

TO File









94231IT-95-518-T

06853352










2

94230IT-95-518-T

06853353







3

94229IT-95-518-T

06853354









4

94228IT-95-518-T

-------------------~-- -~---

06853355













5

--- _----------------------------shy

94227IT-95-518-T

i








6

94226IT-95-518-T

ANNEX C

No IT-95-518-T 8

94225IT-95-518-T





Investigators notes


Screening Notes






94224IT-95-518-T







2


94223IT-95-518-T









3


94222IT-95-518-T










4


94221IT-95-518-T






END OF SCREENING

5


94220IT-95-518-T

r-----------------------~~-----

06853351

Memorandum

DATE July 8 1996

TO File









94231IT-95-518-T

06853352










2

94230IT-95-518-T

06853353







3

94229IT-95-518-T

06853354









4

94228IT-95-518-T

-------------------~-- -~---

06853355













5

--- _----------------------------shy

94227IT-95-518-T

i








6

94226IT-95-518-T

ANNEX C

No IT-95-518-T 8

94225IT-95-518-T





Investigators notes


Screening Notes






94224IT-95-518-T







2


94223IT-95-518-T









3


94222IT-95-518-T










4


94221IT-95-518-T






END OF SCREENING

5


94220IT-95-518-T

06853352










2

94230IT-95-518-T

06853353







3

94229IT-95-518-T

06853354









4

94228IT-95-518-T

-------------------~-- -~---

06853355













5

--- _----------------------------shy

94227IT-95-518-T

i








6

94226IT-95-518-T

ANNEX C

No IT-95-518-T 8

94225IT-95-518-T





Investigators notes


Screening Notes






94224IT-95-518-T







2


94223IT-95-518-T









3


94222IT-95-518-T










4


94221IT-95-518-T






END OF SCREENING

5


94220IT-95-518-T

06853353







3

94229IT-95-518-T

06853354









4

94228IT-95-518-T

-------------------~-- -~---

06853355













5

--- _----------------------------shy

94227IT-95-518-T

i








6

94226IT-95-518-T

ANNEX C

No IT-95-518-T 8

94225IT-95-518-T





Investigators notes


Screening Notes






94224IT-95-518-T







2


94223IT-95-518-T









3


94222IT-95-518-T










4


94221IT-95-518-T






END OF SCREENING

5


94220IT-95-518-T

06853354









4

94228IT-95-518-T

-------------------~-- -~---

06853355













5

--- _----------------------------shy

94227IT-95-518-T

i








6

94226IT-95-518-T

ANNEX C

No IT-95-518-T 8

94225IT-95-518-T





Investigators notes


Screening Notes






94224IT-95-518-T







2


94223IT-95-518-T









3


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END OF SCREENING

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94220IT-95-518-T

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06853355













5

--- _----------------------------shy

94227IT-95-518-T

i








6

94226IT-95-518-T

ANNEX C

No IT-95-518-T 8

94225IT-95-518-T





Investigators notes


Screening Notes






94224IT-95-518-T







2


94223IT-95-518-T









3


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4


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END OF SCREENING

5


94220IT-95-518-T

i








6

94226IT-95-518-T

ANNEX C

No IT-95-518-T 8

94225IT-95-518-T





Investigators notes


Screening Notes






94224IT-95-518-T







2


94223IT-95-518-T









3


94222IT-95-518-T










4


94221IT-95-518-T






END OF SCREENING

5


94220IT-95-518-T

ANNEX C

No IT-95-518-T 8

94225IT-95-518-T





Investigators notes


Screening Notes






94224IT-95-518-T







2


94223IT-95-518-T









3


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END OF SCREENING

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Investigators notes


Screening Notes






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2


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3


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4


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END OF SCREENING

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END OF SCREENING

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END OF SCREENING

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END OF SCREENING

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Documents

IT-95-5/18-T 94248 D94248 - D94220 02 November … Disclosure...Dr. Radovan Karadzic respectfully moves for a finding that the prosecution has once again violated its disclosure obligations