IT-09-92-T 82676

D82676 - D82651
30 September 2014 MB

THE INTERNATIONAL CRIMINAL TRIBUNAL

FOR THE FORMER YUGOSLAVIA

Case No. IT-09-92-T

IN THE TRIAL CHAMBER

Before: Judge Alphons Orie, Presiding

Judge Bakone Justice Moloto
Judge Christoph Flügge

Registrar: Mr. John Hocking

Date Filed: 29 September 2014

THE PROSECUTOR

v.

RATKO MLADIĆ

PUBLIC
WITH PUBLIC ANNEX A, and PUBLIC ANNEX B

DEFENCE MOTION PURSUANT TO RULE 92TER TO ADMIT THE WRITTEN

TESTIMONY OF ŠPIRO PEREULA
___________________________________________________________________________

The Office of the Prosecutor:

Mr. Dermot Groome
Mr. Peter McCloskey

Counsel for the Accused:

Mr. Branko Lukić
Mr. Miodrag Stojanović
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THE INTERNATIONAL CRIMINAL TRIBUNAL

FOR THE FORMER YUGOSLAVIA

PROSECUTOR

v.

RATKO MLADIĆ

PUBLIC
WITH PUBLIC ANNEX A, and PUBLIC ANNEX B

DEFENCE MOTION PURSUANT TO RULE 92TER TO ADMIT THE WRITTEN

TESTIMONY OF ŠPIRO PEREULA
___________________________________________________________________________

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

I. Introduction

1. Pursuant to the Guidance previously expressed by the Trial Chamber, motions

offering written statements under Rule 92ter of the Rules of Procedure and Evidence are to
be filed at least 30 days before the anticipated testimony of a given witness. Witness Špiro
Pereula is currently scheduled to testify in the next 30 days, and thus the Defence hereby files
the instant motion in compliance with the Chamber’s guidance, and applying for the evidence
of this witness to be heard pursuant to Rule 92ter. This Motion is filed publicly, as the
witness does not require protective measures.

2. Herein this application is made to tender two written witness statement of the
witness, along with 1 associated exhibit. At this time the Defence estimates that the evidence-
in-chief of this witness will last up to 30 minutes.

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

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II. Applicable Law

4. Under Rule 92ter of the Rules of Procedure and Evidence (hereinafter

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

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

6. In addition to meeting the requirements for admission under Rule 89, these
“associated exhibits” must form an “inseparable and indispensable” part of the witness’s
written evidence. 3 A document falls into this category if the witness discusses the document
in his or her written statement or transcript and if that written statement or transcript would
become incomprehensible or have lesser probative value without its admission.4

III. Arguments and Submissions

a. The Chamber Should Admit the Witness Statement

7. The Defence seeks leave of the Chamber to call Špiro Pereula as a witness
pursuant to Rule 92ter. The Defence submits that the proffered statement, (attached hereto as
Annex A) and 1 associated exhibit meet the requirements of Rule 92ter, and thus should be
admitted under that Rule.

1
Rule 92ter of the Rules of Procedure and Evidence.
2
Prosecutor v. Karadzic, Case No. IT-95-5/18-T, “Decision on Prosecution’s Submission regarding Additional
Transcript Pages from Momcilo Mandic’s Stanisic and Zupljanin Testimony for Admission into Evidence.” 8
September 2010, para. 5
3
Id.
4
Prosecutor v. Lukic & Lukic, Case No. IT-98-32/1-T, “Decision on Prosecution Motion for Admission of
Evidence pursuant to Rule 92bis,” 22 August 2008, para. 21

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8. Witness Pereula’s statements are relevant, reliable and probative, as set forth
in greater detail herein below. A copy of said statements are both attached as Public Annex
A, with corresponding 65ter# in Public Annex B.

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

10. Witness Pereula was the Chief of Security of the Republic Territorial Defence
Staff of Bosnia and Herzegovina since 1980 and he performed this duty when the war started.
On the 12th of May 1992, he moved from the Ministry of Defence to the VRS Main Staff at
Han Pijesak and was engaged as clerk at the Sector for Intelligence and Security Affairs,
whose chief was General Tolimir. At the end of 1993 or at the beginning of 1994, he was
transferred to the Ministry of Defence of Republika Srpska in the capacity as the Chief of the
Security Organ and he stayed until October 1996.5

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

12. Witness Pereula’s testimony is relevant to the Defence in that it will, among
other things, establish the following:
a. Before the war, the Commander of the Republic Territorial Defence Staff
(RŠTO) was General Drago Vukosavljević and his assistant for logistics
was Šiber who became a Muslim General. Jovo Divjak was the operation
and education organ at the Staff. Sakib Mahumuljin was one of the clerks
at this organ and became the commander of the Zenica Corps. Hasan
Efendić was the Commander of the Sarajevo City ŠTO.6
b. The Chief of the Security Organ at the Staff was Colonel Dimitrije
Simonovski, a Macedonian, who cooperated with Fikret Muslimović who

5
Statement, para. 2‐15
6
Statement, para. 3

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later became the Alija Izetbegović’s advisor; this is the reason why
Dimitrije Simonovski favoured the Muslims.7
c. After the multi-party elections of 1990, the Commander of the RŠTO of
Bosnia and Herzegovina issued an order to increase the security of
depositories and warehouses of weapons and military equipment of the
Bosnia and Herzegovina Territorial Defence. The Commander ordered to
transfer weapons and military equipment to the Yugoslav People’s Army,
particularly from the Territorial Defence warehouses that were not secured,
moreover no one could use any weapons without the approval of the
Commander.8
d. Despite the order, Colonel Jovo Divjak approved the taking out of the
weapons and military equipment from the Kiseljak and Kreševo Territorial
Defence warehouses and armed the Ministry of Interior and the Territorial
Defence units; a criminal report was filed against him. The witness was
sent to examine the Serb nationalism attributed to Colonel Jovo Divjak but
he could not prove anything; Colonel Jovo Divjak was transferred from
Mostar to Sarajevo and appointed Commander of the Regional Territorial
Defence Staff in Sarajevo.9
e. In May 1992, the witness’s brother was taken by a group of soldiers of the
Army of the Republic of BiH from his apartment in Dobrinja. He was
taken to the cellar of the Sunce prison at Dobrinja with others Serb
prisoners. They tortured him and kept him blindfolded all the time on the
order of a man named Sadik Hota. They beat him with chains, hitting his
legs and head. He remained imprisoned until the 24th of May 1992, the
Muslims never honored the exchange and brought him to the line of
conflict and let him go on his own; he managed to reach the Serb territory.
His recovery lasted six months.10
f. On the 7th of April 1992, Colonel Hasan Efendić took over of duty of
commander of the BiH Territorial Defence from General Vukosavljevi
creating inter-ethnic tensions; all Serbs moved to the command of the 2nd
Military District, while Muslims and Croats remained at the RŠTO. Jovo
7
Statement, para. 4
8
Statement, para. 5‐6
9
Statement, para. 7‐8
10
Statement, para. 11 ‐ Supplemental statement, para.3

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Divjak became Efendić’s assistant or deputy and Šiber became the

assistant for logistics.11
g. On the 19th of April 1992, General Kukanjac, the Commander of the 2nd
Military District, ordered to send some officers to Pale in order to establish
a ministry of defence. Colonel Bogdan Subotić was appointed minister.12
h. On the 12th or 13th of May 1992, the witness met General Mladić who left a
strong impression on him as a capable and professional officer. He was a
fair, discipline and hard worker person. General Mladić always ordered all
senior officers to act professionally in combat and to treat prisoners in
accordance with international conventions.13
i. In late April 1992, Colonel Bogdan Subotić ordered to the witness to go to
the gymnasium at the school in Pale where there were about 300 to 400
Muslims from Bratunac. He ordered to separate the individuals incapable
of military service and to ensure that the wounded were provided medical
assistance. Later, they were taken to Visoko and they became part of the
Muslim Visoko-Zenica Brigade and it was this group who had committed
most crimes against the Serbs in the territory of Visoko.14
j. The Security Organ of the Ministry of Defence and the Security Organ of
the VRS Main Staff used to cooperate and exchange information. They
also attended meetings in order to deal with common operational problems,
as the concern about weapons industry.15

b. The Chamber Should admit the Associated Exhibit.

13. The associated exhibit is directly relevant to the case, and is inseparable and
indispensable to the witness’s statement, and can be contextualized and explained most
effectively through this witness. It constitutes an essential component of the witness’
evidence, and also is of importance to the Defence case, and therefore it is submitted that it is
in the interests of justice that it be admitted.

11
Statement, para. 12‐13
12
Statement, para. 14
13
Statement, para.16‐17
14
Supplemental statement, para. 4‐5‐6‐7
15
Supplemental statement, para.8‐10

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14. There is 1 Associated Exhibit to this witness statement, as set out in the table
that is attached at Annex B.

15. This exhibit is discussed by the witness in his statement and expands upon the
matters he has identified therein.

III. CONCLUSION

WHEREFORE, for the foregoing arguments, the Defence respectfully requests that the
Chamber issue an order:
a. Granting the Defence leave to present the evidence and associated exhibit of Špiro
Pereula pursuant to Rule 92ter.

Word Count: 1,787

RESPECTFULLY SUBMITTED BY:

Branko Lukić Miodrag Stojanović

Lead Counsel for Ratko Mladić Co-Counsel for Ratko Mladić

IT-09-92-T 29 September 2014 6

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THE INTERNATIONAL CRIMINAL TRIBUNAL

FOR THE FORMER YUGOSLAVIA

Case No. IT-09-92-T

THE PROSECUTOR

v.

RATKO MLADIĆ

PUBLIC

ANNEX A
___________________________________________________________________________

IT-09-92-T 29 September 2014 7

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INTERNATIONAL TRIBUNAL FOR THE PROSECUTION OF PERSONS

RESPONSIBLE FOR SERIOUS VIOLATIONS OF INTERNATIONAL
HUMANITARIAN LAW COMMITTED IN THE TERRITORY OF THE FORMER
YUGOSLAVIA SINCE 1991

SUPPLEMENTAL WITNESS STATEMENT

WITNESS INFORMATION:

Surname: PEREULA

Name: Špiro

Father’s name: Stevo

Date of birth: 10 November 1941

Ethnicity: Serb

Date(s) of interview(s): 18 July 2014

Interview(s) conducted by: Mikajlo Mitrović

Language used during the interview: Serbian

Signature of the Witness: ______/signature/ _______________

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SUPPLEMENTAL WITNESS STATEMENT BY ŠPIRO PEREULA

1. I gave a statement to the Defence Team of General Ratko Mladić on 5 March 2014, and I
reviewed and signed it on 17 July 2014. I would like to supplement the said statement with the
following information:

THE TORTURING OF SERBS IN THE SUNCE PRISON IN SARAJEVO (THE

NEIGHBOURHOOD OF DOBRINJA)

2. I recently watched the morning programme on RTRS Television at 7:30 hours, and on
that occasion I saw a Muslim named Midhat Brica speaking about the torturing of my brother
Bogdan Pereula and other Serbs of Sarajevo in the Sunce prison in Dobrinja. The TV report was
broadcast on 29 March 2014 (recording of the TV broadcast: 65ter 1D03030).

3. Brica stated in the report that my brother had been tortured on the order of a man named
Sadik Hota, who is now an attorney-at-law in Sarajevo. Brica stated that Sadik Hota decided
who would torture whom and in what manner. There is a recording of the TV show with the
RTRS and it would probably be possible to obtain it from them, which would confirm the
information I provided here.

THE TRANSFER OF THE MUSLIMS TO VISOKO

4. I remember that sometime in late April 1992 Colonel Bogdan Subotić ordered me to go
to the gymnasium at the school in Pale, where there was a large group of Muslims from
Bratunac. He ordered me to find out whether there were individuals incapable of military service
and the wounded in that group. He ordered me to have the individuals incapable of military
service separated and to ensure that the wounded were provided medical assistance.

5. I went to the sports hall and saw that it was full. There were probably about 300 to 400
people in there. There were no women or children. All of them were able-bodied. As far as I
recall there were three injured individuals, and they were given medical attention.

6. I know that they were subsequently taken to Visoko, without exchange or any other
conditions.

7. Later, when I came to the VRS, I learned through intelligence data and in conversations
with the people that the group had become a part of the Muslim Visoko-Zenica Brigade, and that

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it was exactly that group that had committed most crimes against the Serbs in the territory of
Visoko.

THE RELATIONSHIP BETWEEN THE SECURITY ORGAN OF THE MINISTRY OF

DEFENCE AND THE SECURITY ADMINISTRATION OF THE VRS MAIN STAFF

8. As regards the relationship between the Security Organ of the Ministry of Defence and
the Security Organ of the GŠ VRS /VRS Main Staff/, it was based on the principle of cooperation
and exchange of information.

9. While I performed the duty of security organ at the Ministry of Defence, I was
subordinated to the Ministry of Defence of Republika Srpska. In my work, I was not
subordinated in any respect to the Chief of Security Administration of the GŠ VRS.

10. Besides the exchange of information, I would sometimes attended meetings of the
Security Organ of the GŠ VRS, in cases which dealt with operational problems common for
both organs. Among other things, those would be problems related to the weapons industry. As
regards the weapons industry, we had overhaul facilities of Hadžići and Kosmos, and two
factories: Pretis and Čajavec.

10. I had a subordinate security organ at Kosmos, as well as at the organs of the Ministry of
Defence in Bijeljina and Banja Luka municipalities. The other municipal departments of the
Ministry of Defence in Republika Srpska were covered directly by me in terms of security work.

WITNESS CONFIRMATION

I have read this supplemental statement comprising 3 pages, and it contains all that I said to the
best of my knowledge and recollection. I have given this statement voluntarily, and I am aware
that it can be used in the proceedings before the International Tribunal for the Prosecution of
Persons Responsible for Serious Violations of International Humanitarian Law Committed in the
Territory of the Former Yugoslavia Since 1991, and that I may be called to testify publicly
before the Tribunal.

Signature: ______/signature/ _______________

Date: ________21 July 2014_________________

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INTERNATIONAL TRIBUNAL FOR THE PROSECUTION OF PERSONS

RESPONSIBLE FOR SERIOUS VIOLATIONS OF INTERNATIONAL
HUMANITARIAN LAW COMMITTED IN THE TERRITORY OF THE FORMER
YUGOSLAVIA SINCE 1991

WITNESS STATEMENT

WITNESS INFORMATION:

Surname: PEREULA

Name: Špiro

Father’s name: Stevo

Date of birth: 10 November 1941

Ethnicity: Serb

Date(s) of interview(s): 5 March 2014

Interview(s) conducted by: Branko Lukić, Mikajlo Mitrović

Language used during the interview: Serbian

Signature of the Witness: ______/signature/ _______________

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WITNESS STATEMENT BY ŠPIRO PEREULA

PERSONAL INFORMATION

1. My name is Špiro (son of Stevo) PEREULA. I am a retired Colonel. I was born on 10

November 1941 in Vražalice village, the SO /Municipality of/ Rogatica. I am a Serb by
ethnicity. I have no criminal record. I am married with two children. I completed the
Pedagogical Academy and graduated from the Faculty of National Defence. I am a pensioner
with permanent residence in Banja Luka.

2. On 1 April 1975 I was admitted to the TO /Territorial Defence/ of BiH, which was an
integral part of the Armed Forces of the SFRY /Socialist Federal Republic of Yugoslavia/ at the
time. Until 1977, I worked as an organ in charge of mobilisation affairs at the City Staff of the
Territorial Defence (ŠTO), and from 1977 I worked at the security organs. Until 1980, I was the
Chief of the Security Organ (OB) of the Regional ŠTO /Territorial Defence Staff/, and in that
same year I moved to the Republic ŠTO in the capacity as the Chief of Security of the RŠTO
/Republic Territorial Defence Staff/ of BiH. I performed this duty when the war started.

3. Immediately before the war, the commander of the Republic Territorial Defence Staff
(RŠTO) was General Drago Vukosavljević, while his assistant for logistics was Šiber, who
subsequently became a Muslim general. Jovo Divjak was the operations and education organ at
the Staff. Sakib Mahmuljin, who subsequently became the commander of the Zenica Corps, was
one of the clerks at this organ. Hasan Efendić was the commander of the Sarajevo City ŠTO.

4. At the time, the Chief of the Security Organ at the Staff was Colonel Dimitrije
Simonovski, a Macedonian, who closely cooperated with Fikret Muslimović, who later became
an advisor to Alija Izetbegović. It was because of this cooperation that Dimitrije favoured the
Muslims.

THE SITUATION AFTER THE ELECTIONS HELD IN 1990

5. After the multi-party elections of 1990, and especially during 1991, the inter-ethnic
tensions increased at the TO Staff as well. As a result of the fear and the estimation that the
weapons would come into the hands of extremists of any nation, and in order to prevent this, the

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Commander of the RŠTO /Republic Territorial Defence Staff/ of BiH issued an order to increase
the security of depositories and warehouses of weapons and military equipment of the BiH TO
/Territorial Defence/.

6. Since at the time the JNA /Yugoslav People’s Army/ had the best secured military
equipment warehouses, the Commander of the BiH TO gave instructions in his order that the
weapons and military equipment of the TO be transferred to the JNA warehouses, particularly
and primarily from the TO warehouses that were not adequately secured. The order also stated
that no one was to issue or approve the use of any weapons and military equipment without the
approval of the Commander of the Republic Territorial Defence Staff of BiH (RŠTO BiH).

7. Despite the above order, the then Colonel Jovo Divjak approved, on his own initiative,
the taking out of the weapons and military equipment from the Kiseljak and Kreševo TO
warehouses, and armed the MUP /Ministry of Interior/ and the TO units in Kiseljak and
Kreševo. A criminal report was filed against him because of this to the military prosecution,
which was not followed up. Besides, Jovo Divjak was accused by the Croats and the Muslims of
voicing Serb nationalism even at the time when he had been the commander of the Regional
Staff of the Mostar TO in 1990.

8. On that occasion, I was sent to examine what it was all about and I did not manage to
observe or prove the Serb nationalism attributed to Divjak. After this, Divjak was transferred
from Mostar to Sarajevo and appointed Commander of the Regional TO Staff in Sarajevo.

THE SITUATION IN SARAJEVO IMMEDIATELY BEFORE THE WAR

9. Just before the war, I lived with my family in Sarajevo. The situation was deteriorating
daily. At the end of March and the beginning of April the whole city was under barricades.

10. I used a rally that was held on 6 April 1992 at Marin Dvor as an opportunity to leave
with my family as the barricades were removed because of this rally and managed to cross from
Pofalići to Dobrinja where my brother Bogdan lived. I left my family at my brother’s place,
while I went to the command of the 2nd VO /Military District/.

11. I need to note that my late brother was a construction engineer and a director at the
Energoinvest enterprise. He lived with his family at Dobrinja, in Sarajevo. Until 9 May 1992 he

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regularly went to work together with his colleague Heleta. On one occasion, when he was
returning from his colleague Heleta’s apartment to his place, a group of soldiers of the A RBiH
/Army of the Republic of BiH/ awaited him in front of the entrance to his apartment building. On
that occasion they searched his apartment and since they did not find any weapons they asked
for his car keys, requested him to take them to the garage and took the car. They blindfolded him
and took him in an unknown direction. I later heard that they had taken him to the cellar of a
coffee shop called Sunce at Dobrinja, where there had been other Serb prisoners. In prison, they
tortured him and kept him blindfolded all the time. They beat him with chains, hitting his legs
and head. They even forced one of the Serb prisoners to beat him too. He remained imprisoned
until 24 May 1992, when he was supposed to be exchanged. The Muslims never honoured the
exchange and instead brought him to the line of conflict, to the no man’s land, and let him go on
his own. Since he knew Dobrinja well, he managed to reach the Serb territory. He was in the
hospital at Pale, where he was checked; because of the injuries he sustained he had to be
transferred to the VMA /Military Medical Academy/ in Belgrade, where he was provided
medical assistance. After the treatment he was released home. His recovery lasted for a total of
six months, during which time he was in Kruševac at his mother-in-law’s home. He lived until
25 September 2013, when he died because of the consequences of the beating. He felt the
consequences of the beating throughout this time and he always complained about the pain in his
legs and head.

ILLEGAL TAKEOVER OF THE COMMAND OVER THE REPUBLIC TERRITORIAL

DEFENCE STAFF (RŠTO)

12. The inter-ethnic tensions at the Republic Staff of the Territorial Defence escalated on 7
April 1992, when Hasan Efendić mounted a coup with the likes of him and took over the duty of
commander of the BiH TO from General Vukosavljević. I was not physically present at the Staff
at that time as I was being treated at the military hospital in Sarajevo.

13. The persons that were present in this meeting told me that, on the occasion of the
takeover of duty of commander of the BiH TO, Colonel Hasan Efendić said that those who did
not wish to stay at the Staff under his command could freely go to the JNA. This was followed
by a complete division of the TO Republic Staff (RŠTO) on an ethnic basis so all the Serbs
moved to the command of the 2nd Military District (VO), while the Muslims and Croats
remained at the RŠTO. Jovo Divjak then became Efendić’s assistant or deputy, while Šiber
became the assistant for logistics.

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14. Eight Serb officers, including me, joined the 2nd Military District (VO). On 19 April
1992, General Kukanjac, the Commander of the 2nd VO, ordered that these officers be sent to
Pale in order to establish a ministry of defence. Colonel Bogdan Subotić was then appointed
minister.

MY JOINING THE VRS

15. When the VRS /Army of Republika Srpska/ was established on 12 May 1992, I moved
from the Ministry of Defence (MO) to the VRS Main Staff at Han Pijesak and was engaged as a
clerk at the Sector for Intelligence and Security Affairs, whose Chief was General Tolimir. At
the end of 1993 or the beginning of 1994, I was transferred to the Ministry of Defence of
Republika Srpska (RS) in the capacity as the Chief of the Security Organ (NOB), where I stayed
until October 1996. I retired in 2000.

16. On 12 or 13 May 1992, upon my arrival at the VRS Main Staff, I met General Mladić,
who left a very strong impression on me as a capable officer and a professional. I especially
emphasise his humanness, fairness, discipline and work. He did not allow any separation of
soldiers from officers on any basis.

17. I need to emphasise in particular that General Mladić always ordered all senior officers
to act professionally in combat and to treat prisoners in accordance with international
conventions.
WITNESS CONFIRMATION

I have read this statement comprising 5 pages, and it contains all that I said to the best of my
knowledge and recollection. I have given this statement voluntarily, and I am aware that it can
be used in the proceedings before the International Tribunal for the Prosecution of Persons
Responsible for Serious Violations of International Humanitarian Law Committed in the
Territory of the Former Yugoslavia Since 1991, and that I may be called to testify publicly
before the Tribunal.

Signature: ______/signature/ _______________

Date: ________15 July 2014_________________

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MEDUNARODNI SUD ZA KRIVICNO GONJENJE OSOBA ODGOVORNIH ZA

TESKA KRSENJA MEDUNARODNOG PRAVA NA TERITORIJI BIVSE
JUGOSLAVIJE OD 1991

IZJAVA SVEDOKA-DOPUNA IZJAVE

PODACI 0 SVEDOKU:

Prezime: PEREULA

Ime: Spiro

Ime oca: Stevo

Datum rodenja: 10.11.1941.

Nacionalnost: Srbin

Datum(i) razgovora: 18.07.2014.

Razgovor(e) vodili: Mikajlo Mitrovic

Jezici korisceni u toku razgovora: Srpski

Potpis svedoka: R~
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IZJAVA SVEDOKA - DO PUNA IZJAVE - SPIRO PEREULA

1. Ja sam odbrani generaia Ratka Miadica dao izjavu 05.03.2014., a istu sam pregiedao i
potpisao 15.07.2014. godine. Tu izjavu zelim da dopunim sa siedecim saznanjima.

MUCENJE SRBA U ZATVORU SUNCE U SARAJEVU {NASELJE DOBRINJA)

2. Nedavno sam giedao jutarnji program RTRS-a u 07.30 casova i tom priiikom sam video
izvesnog Musiimana Midhata Bricu kako govori o mucenju mog brata Bogdana Pereuie i drugih
Srba iz Sarajeva u zatvoru Sunce u Dobrinji. Ta je emisija biia 29.03.2014. godine. (snimak
emisije 65ter 1D03030).

3. U njoj je Brica naveo kako je moj brat mucen po naiogu izvesnog Sadika Hote, koji je
sada advokat u Sarajevu. Brica je naveo, kako je Sadik Hota odredivao koga ce i kako muciti.
Snimak te emisije se nalazi u RTRS-u i verovatno postoji mogucnost da se on od njih i dobije,
Cime bi se potvrdiia ova moja informacija.

PREBACIVANJE MUSLIMANA U VISOKO

4. Sjecam se da mi je negdje krajem apriia 1992. godine pukovnik Bogdan Subotic naredio
da odem u fiskulturnu saiu skoie u Palama, gdje se nalaziia veca grupa Musiimana iz Bratunca.
Naredio mi je da utvrdim da Ii ima vojno nesposobnih i ranjenih u toj grupi. Naredio mi je da se
vojno nesposobni odvoje, a ranjenima prufi medicinska pomoc.

5. Ja sam otisao u tu saiu i video da je sala biia puna. Biio je najvjerovatnije oko 300-400
ljudi. Nije biio zena, ni dece. Svi su biii vojno-sposobni. Koiiko se ja sada sjecam, tri Iica su biia
povrijedena, i njimaje prufena medicinska pomoc.

6. Poznato mi je da su oni kasnije prebaceni u Visoko bez razmene iii biio kakvih drugih
usiovljavanja.

7. Kasnije sam preiaskom u VRS, kroz obavjestajne informacije i kroz razgovor sa Ijudima,
dosao do saznanja da je ta grupa usia u sastav muslimanske visocko-zenicke brigade, te da su
oni biii upravo ona grupa kojaje najvise cinila ziocine nad Srbima na teritoriji Visokog.

~
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ODNOS ORGANA BEZBEDNOSTI MINISTARSTVA ODBRANE I UPRAVE

BEZBEDNOSTIGSVRS

8. Kada se govori o odnosu organa bezbednosti Ministarstva odbrane i organa bezbednosti

GS VRS, oni su bili zasnovani na principu uzajamne saradnje i razmjene informacija.
9. Dok sam obavljao funkciju organa bezbjednosti u Ministarstvu odbrane, bio sam
potcinjen i odgovoran Ministru odbrane Republike Srpske. Nisam za svoj rad ni po kakvom
osnovu bio potCinjen Nacelniku Uprave bezbednosti GS VRS.

10. Pored razmene informacija ponekad sam prisustvovao sastancima organa bezbjednosti
GS VRS, u onim slucajevima kada se radilo o zajednickim operativnim problemima koje smo
imali. To se izmedu ostalog odnosilo na bezbjednosne problem koji su se javljali u namjenskoj
industriji. Od namjenske industrije imali smo remontne zavode Hadzice i Kosmos, te dvije
namjenske fabrike Pretis i Cajavec.

10. U Kosmosu sam imao potcinjenog organa bezbjednosti, kao i u organima ministarstva
odbrane u opstinama Bijeljina i Banja Luka. Druga opstinska ministarstva odbrane na teritoriji
Republike Srpske neposredno sam be'~krivao.

POTVRDASVEDOKA

ProCitao sam ovu dopunu svoje izjave od _Q__ strana i ona sadcii sve sto sam rekao, po svom
znanju i secanju. Izjavu sam dao dobrovoljno i svestan sam da se moze upotrebiti u sudskom
postupku pred Medunarodnim sudom za krivicno gonjenje osoba odgovornih za teska krsenja
medunarodnog prava pocinjena na teritoriji bivse Jugoslavije od 1991 , kao i da mogu biti pozvan
da javno svedocim pred Sudom.

Potpis: tJ!~ _
Datum: .9/ (J j 20/k . LOP.
(]
 82652

THE INTERNATIONAL CRIMINAL TRIBUNAL

FOR THE FORMER YUGOSLAVIA

Case No. IT-09-92-T

THE PROSECUTOR

v.

RATKO MLADIĆ

PUBLIC

ANNEX B
___________________________________________________________________________

IT-09-92-T 29 September 2014 8

 82651

PEREULA Spiro
Witness Statement to be admited pursuant Rule 92ter
Closed Session /
Statement Date 65ter Number Under seal
Witness Statement of PEREULA Spiro 15 July 2014 1D01474 /
Associated Exhibits wich the Defence seeks to tender pursuant to Rule 92ter
Paragraph
Description Number1 65ter/EXH Number Doc ID (BCS/ENG)
RTRS - ''PECAT'' 27 March 2014 - Interview with
Midhat Brico (Source - RTRS official site: 2 1D03030
http://www.rtrs.tv/av/pusti.php?id=36297 )

1
65ter 1D01747a - Supplemental Witness Statement of PEREULA Spiro