Case No. IT-09-92-PT 12 April 2012
II. Applicable Law
The Prosecution incorporates by reference its summary of the applicable lawset forth in paragraphs 5 to 8 of Prosecution 92
III. The Chamber Should Admit Witness RM321’s
Testimony andAssociated Exhibits Pursuant to Rule 92
Testimony and the associated exhibits satisfy all of the admissibility requirements of Rules 89 and 92
They should, therefore, beadmitted.5.
Col. Obradovi} was the head of the Operations and Training Organ of theVRS Main Staff in 1995. He was directly subordinated to the Chief of theAdministration for Operations and Training Gen. Radivoje Mileti}, as his deputy. Asset out in his Rule 65
, Col. Obradovi}’s evidence deals withseveral structural, procedural and functional elements of the VRS Main Staff and itssubordinate units. More particularly, Obradovi} provides important evidence on:
Key command personnel, including Gen. Mladi}, VRS Main Staff Assistant Commanders and members of the Staff Sector of the MainStaff;
The responsibilities of various VRS Main Staff Sectors andAdministrations, including Operations and Training, and the sectorsfor Security and Intelligence, and Civilian Affairs;
Lines of reporting, including and superior/subordinate relationshipswithin the VRS Main Staff;
The process followed by the VRS Main Staff in drafting Directives,including Directives 7 and 7.1;
The regulation of humanitarian aid and UNPROFOR convoys withinthe VRS Main Staff and the personnel involved in this process,including Generals Mladi}, Tolimir, and Mileti};
Units attached to the VRS Main Staff, including 10
SabotageDetachment and 65
Motorised Protection Regiment, and its MilitaryPolice Battalion; and
Communication and reporting requirements and practices within theVRS.6.
This evidence is highly relevant to and probative of salient and material issuesarising under the Indictment concerning the Srebrenica events. Further, to the extentthat Col. Obradovi}’s
Testimony concerns the structural, procedural and
Prosecutor v. Mladi},
Case No.IT-09-92-PT, Prosecution 92
Motion: RM505, 2 April 2012.
Prosecution Witness List, 10 February 2012, p.337.