Tribunal Criminal Tribunal for the Former Yugoslavia

Page 669

 1                           Wednesday, 31 October 2012

 2                           [Open session]

 3                           [The accused entered court]

 4                           --- Upon commencing at 9.05 a.m.

 5             JUDGE DELVOIE:  Good morning to everyone in and around the

 6     courtroom.  We apologise for the late start due to technical problems.

 7             Mr. Registrar, would you please call the case.

 8             THE REGISTRAR:  Good morning, Your Honours.  This is case number

 9     IT-04-75-T, the Prosecutor versus Goran Hadzic.  Thank you.

10             JUDGE DELVOIE:  Thank you very much.  Could we have the

11     appearances, please, starting with the Prosecution.

12             MR. STRINGER:  Good morning, Your Honours.  Douglas Stringer

13     appearing on behalf of the Prosecution with Alexis Demirdjian,

14     Antonio Garza, and our Case Manager Thomas Laugel.

15             JUDGE DELVOIE:  Thank you.  For Defence, please.

16             MR. ZIVANOVIC:  Good morning, Your Honours.  For the Defence of

17     Goran Hadzic, Zoran Zivanovic, lead counsel; Christopher Gosnell,

18     co-counsel; and Ms. Liane Aronchick, Case Manager.

19             JUDGE DELVOIE:  Thank you.  Can we have the witness, please.

20                           [The witness takes the stand]

21                           THE WITNESS:  BORIVOJE SAVIC [Resumed]

22                           [Witness answered through interpreter]

23             JUDGE DELVOIE:  Good morning, Mr. Savic.  You were sworn in --

24             THE WITNESS: [Interpretation] Good morning.

25             JUDGE DELVOIE:  You were sworn in yesterday, and I remind you

Page 670

 1     that you are still under oath.

 2             Mr. Zivanovic.

 3             MR. ZIVANOVIC:  Thank you, Your Honour.

 4                           Cross-examination by Mr. Zivanovic:  [Continued]

 5        Q.   [Interpretation] Mr. Savic, I will play some video footage for

 6     you.  This is something that you saw yesterday, because it was played to

 7     you by the OTP.  I won't be playing the whole thing, just a section, the

 8     reason being there is a translation or interpretation error that occurred

 9     which we believe is quite relevant.  This is at page 14, line 14.  I will

10     ask you to please try and listen very closely to a particular sentence

11     that Mr. Goran Hadzic uttered, and please try and tell us, if you can,

12     what exactly it was that he said.

13             This is OTP Exhibit P53.  We'll be looking at this section that

14     starts at 4 minutes, 20 seconds into the clip, and it's a mere

15     10 seconds.  It's up until 4:30 into the video-clip.

16                           [Video-clip played]

17             MR. ZIVANOVIC:  Stop.

18        Q.   [Interpretation] I see that the words were not translated or

19     interpreted, the words spoken by Goran Hadzic.

20             Witness, this section that you just heard, what did Goran Hadzic

21     just say?  Did he not say that the Croatian people should publicly give

22     up on the Ustasha or did he say that they should publicly give up on the

23     Ustasha policies?

24        A.   He said they should publicly give up on the Ustasha.

25        Q.   Yes.  That is quite correct, because the record yesterday, the

Page 671

 1     LiveNote, reflected Goran Hadzic as saying that the Croatian people

 2     should give up on their Ustasha policies, which gives the section a

 3     wholly different meaning, because as we ascertained yesterday, the

 4     Ustasha were merely a small group of political extremists.  And what

 5     Goran Hadzic wanted in practical terms was for the Croatian people to

 6     give up on them, to renounce them.  Thank you.

 7             Yesterday, we broke after we talked about the Obrovac meeting and

 8     what happened at Plitvice, if you remember.  Something that we found

 9     slightly strange is the fact that you said that this was no arrest, but,

10     okay, you are fully entitled to see it any which way you like.

11     Nevertheless, at page 91, you say that you were prepared for the Plitvice

12     harassment, that you were mentally prepared for something that was only

13     to occur at a later stage.  Can you please explain what exactly you meant

14     by saying that?  What sort of mental preparation did you undertake?

15        A.   It's not really anything special by way of preparation.  You are

16     prepared or ready at a given point in time to adapt to a certain

17     situation depending on the circumstances, of course, as they say.  A

18     debate, is this a meeting, depending on the situation, as I said.  So

19     it's all a matter of instinct and intuition.

20        Q.   All right.  Thank you very much.  You also say at page 50 of

21     yesterday's transcript that in April 1991, you went to the Military

22     Medical Academy.  You went there because of what you had suffered at

23     Plitvice.  I want to know what exactly you got treatment for.  Which

24     specialists did you see?  Did you undergo any particular specialist

25     medical examinations at all while there?

Page 672

 1        A.   I arrived there late one evening.  A man named Dr. Nikolic was

 2     there, and another man with a Macedonian surname.  I told them I was

 3     there because there was no other hospital for me to go to.  The incident

 4     had occurred a month before, perhaps, and I'm sure that they were aware

 5     of this.  It was a regular exam, ear, throat, nose, that sort of thing.

 6     They checked my head.  I think there were some fractures or fissures that

 7     were found, something like that.  And then they just left me there lying

 8     in a bed.

 9             I can't really specify what examinations were performed, but it

10     all had to do with the head and the ear, throat, and nose sector.

11        Q.   I assume you don't know which specialists looked at you during

12     your time there at the hospital.

13        A.   Yes, that's right.

14        Q.   You also say that between the 2nd of May, 1991, and sometime in

15     November or December 1991, you spent some time in Serbia in a variety of

16     different locations which you specified.  You also explained what it was

17     that you were doing there.  What I want to know is were you actually

18     gainfully employed?  Were you contracted by anyone to be there and to

19     work there?  Is there any record of your time there, because you

20     described all the jobs that you did when you were there, organising

21     humanitarian aid, refugees, the territorial staff and so on and so forth.

22        A.   I was not remunerated for those jobs in any shape or form nor

23     indeed did I sign any contracts.  I covered my own expenses in all these

24     cases, fuel, travel, accommodation, clothing.  I covered all of that out

25     of pocket.

Page 673

 1        Q.   Could you please explain?  You had no salary.  You weren't

 2     receiving any pay at all over those six or seven months.  How on earth

 3     were you able to cover all your expenses?  You would often spend nights

 4     at hotels.  You would need to travel to get from point A to point B.

 5     Where did you get the money for all that?

 6        A.   It was my money, money that I had.  Normally it would have been a

 7     perfectly usual thing at the time given the circumstances for people to

 8     loot and then sort of compensate themselves with these gains, the goods

 9     gained looting, but that's not something that I chose to do.  I thought

10     that I was perfectly able to pay my own way.

11        Q.   Thank you very much.  I would like to go back to a particular

12     section of your statement, which is about what happened at Pakrac.

13     That's between paragraph 49 and paragraph 61.  I would like you to go

14     through this with me.  I'll be asking you a number of questions, because

15     our information of some of these events contradicts yours.  Our

16     information suggests that what happened in Pakrac was the result of

17     clashes between the reserve police who were there and the permanent

18     police force based in Pakrac.  So it wasn't a spontaneous outburst of any

19     kind -- or, rather, it was a spontaneous outburst and not the result of

20     something organised.

21             You give an entirely different account of these events in your

22     statement, so I would like to hear it from you.  You state that the

23     people from the SDS from Western Slavonia for all practical intents

24     organised that attack, do you not?

25        A.   Every time I state something it's open to debate and I'm

Page 674

 1     perfectly happy to defend something that I said.  I can do that by using

 2     documents, and I can try to argue my points.

 3             My information on Pakrac is a result of my activities at the

 4     time, the activities that I pursued in Western Slavonia specifically,

 5     Podravska Slatina, Lipik, Daruvar, Pakrac, that general area.  We would

 6     have meetings there every two or three days.  Western Slavonia was of

 7     particular interest, because this was where you first got to know about

 8     some people who simply showed up.  New things started happening.

 9             There was this one time that a friend got in touch to tell me

10     that Veljko Dzakula had left for Belgrade in order to arrange an action

11     for Pakrac.  All of the information in my possession was generated by

12     well-meaning people who simply didn't have the courage to get involved,

13     but they believed that if they passed some information on to me, perhaps

14     I would be able to do something about it.  So they meant well, in other

15     words.  They thought that I'd be able to prevent or stop something

16     untoward from happening.  So I went to Belgrade myself, straight to

17     Metropol Hotel.  I rang Veljko Dzakula's wife who lived in Belgrade.  I

18     told him where I was at the hotel, and whenever Dzakula arrived, I should

19     like to meet him there, I said.

20             He turned up at one point and said it's all been arranged.  I

21     said, What's been arranged?  And he said, The action in Pakrac will start

22     any time now.  People are ready to fight.  All they need is weapons.  And

23     this was the first I'd ever heard of anything like that, because we'd

24     been adamant about the need to pacify everyone, to pacify the people

25     there, to try and keep them calm.

Page 675

 1             Just one little detail:  Back in February 1991, they opened the

 2     building site for the elementary school in Soplje, near

 3     Podravska Slatina.  President Mesic was there for the opening ceremony,

 4     Veljko Dzakula, Ilija Sasic and I were also to meet there in order to

 5     speak to President Mesic.  I couldn't make it that day because of other

 6     commitments, but the next day we did meet.  So I said, What happened?

 7     Veljko said, Mesic said there's every chance for our problem to be

 8     resolved.  What chance and how exactly?  And he said, Slobodan Milosevic

 9     after the elections for the first time agreed to talk about us, to

10     discuss us.  And what did you say?  Would we agree for Slobodan Milosevic

11     to be the one tackling our problem, tackling our issue?  And then Mesic

12     said, And what do you expect?  Do you expect you'll be able to deal with

13     this yourselves?  And then I asked them, Did you get Mesic's message?

14     And they said, Well, we understood exactly what he said.  And I said, Do

15     you understand that they're suggesting we need political guardians?

16     We'll end up being a bargaining chip in this whole process.  Don't stir

17     up trouble with the people, because the people will be the ones paying

18     the price, and there will be hell to pay.

19             So this was the first I heard from Dzakula about this action in

20     Pakrac.  He said the army would be taking the area between the Hungarian

21     border and the main road.  So that part of Slavonia could split off, he

22     said.  What they talked about by referring it to -- by referring to it as

23     a buffer zone.  So the police would vote in favour of joining the police

24     stations in Knin municipality and then the rest would follow in Dalmatia.

25             And then he also said, We'll drive the police out like the

Page 676

 1     Home Guard soldiers back in World War I wearing nothing but their

 2     nappies.

 3             We talked until 4.00 in the morning, and I tried to dissuade him.

 4     I tried to talk him out of it, and I said, Listen, you do this at your

 5     own risk.  I told him in no uncertain terms that he would be receiving no

 6     support at all from us as a political party, and I said, You do as you

 7     see fit.

 8             Several days later, there was this action at Pakrac which was

 9     obviously co-ordinated and closely followed up, the result being what it

10     was.  The people there were given weapons.  There was nothing those

11     people could really do with their weapons.  There were some infiltrators

12     there, but there was no real fighting, nor was there supposed to be any

13     real fighting there, but there was to be an act of provocation which

14     would then trigger a police reaction.

15             I said to Veljko, When people take up arms, they can no longer

16     stay in the house.  We organised meetings that were banned.  We

17     controlled that, but there was nothing provocative about them.  That was

18     not the intention.  We were in charge of keeping order ourselves.  I

19     mean, there were some police officers there, too, but no one at all was

20     allowed to attack those police officers, and we were pretty good at

21     organising that kind of thing.  So it's the uniform that keeps a

22     policeman safe, and it also keeps the entire regime safe.  If you attack

23     a uniform, you attack the state.

24             And we all know what happened.  It was a planned operation.

25     Everything was planned, and then people started moving out of the area.

Page 677

 1        Q.   Thank you.  I'll move on to a different subject now.  You say in

 2     your statement, paragraph 91 specifically, that you advised members of

 3     the Serbian Democratic Party, Soskocanin in particular, to forward any

 4     and all requests directly to the government and not to people like Jovic,

 5     Seselj, Draskovic, et cetera.  You remember that portion of your

 6     statement?

 7        A.   Yes, I do.

 8        Q.   Nevertheless, when reading your statement, I noticed that you

 9     make several references to your contacts with Nenezic, Kokot, Pekic,

10     Kaloper.  To the best of my knowledge, these were all retired generals,

11     and I think most of them were members of the Communist League for

12     Yugoslavia.  Am I right?

13        A.   Yes.  Some, some were.  Kaloper was the party secretary.

14        Q.   Really, why were you in touch with these people while, on the

15     other hand, you were telling everybody else to steer clear of the

16     political parties and to only ever go directly to the state institutions,

17     to the government, particularly bearing in mind what you said yesterday,

18     that you were no Communist in terms of your political convictions.  You

19     had left the League of Communists long before.  So why on earth were you

20     now in touch with these people?

21        A.   It's not that I was in touch with these people.  These were

22     people who got in touch with me.  It was the other way around, and then

23     it doesn't really tally in terms of the time line.  The contacts with

24     Soskocanin were later, and these people, most of them left for Belgrade.

25     I was the first to be invited, and I refused to go.  And then since I was

Page 678

 1     quite active, everybody who was on their way to Belgrade would confer

 2     with me.  They'd ask questions and seek advice.

 3             It wasn't just Vukasin.  I kept telling everyone the same thing.

 4     If you decide to go to Belgrade, the only possibly relevant thing is any

 5     promises that you can obtain from the government, not from the

 6     politicians.  Some people favour Seselj, some people favour Vuk, and some

 7     people like somebody else, a different political party, particularly

 8     given the fact that all of these political parties were suddenly

 9     establishing volunteer brigades, Partisan brigades.  Even Paroski set up

10     a unit at the time.  So it was just about sending people to the right

11     address, as it were.

12        Q.   You said that time-wise things didn't tally, and I wanted to ask

13     you this since we were unable to establish:  Can you tell us when you

14     were in contact with Nenezic?  When did such contacts begin?

15        A.   Well, I was in Belgrade in July.  It was that period of time when

16     Kaloper was there as well.  I was invited to meet them from Slatina and

17     the generals really tried to have their finger in every pie.

18        Q.   What about Pekic?

19        A.   It was an incidental encounter on the premises in

20     Cvijiceva Street where the Association of Croatian Serbs had their

21     office.  There was also an office there where Pekic received people.  I

22     was there because some of them had promised me a TV camera which had to

23     be sent in the field.  I happened to be there by chance at the door in

24     the secretary's office.  I had some time on my hands, and I was waiting

25     for the people to go away, and I heard someone call out my name, Savic.

Page 679

 1        Q.   You've already explained that in detail.

 2        A.   Well, that's it, then.  There's no need for me to explain any

 3     further.

 4        Q.   Well, I'm trying to establish this:  You only saw Pekic once?

 5        A.   Yes, on -- upon his insistence.  I did not seek contact with him.

 6     He did.

 7        Q.   Could we next have a look at a Prosecution exhibit?  It is

 8     number 81 on the Prosecutor's list.

 9             Can you see it on the screen?  We have the translation, but you

10     will see the original text shortly as well in our language.  That's the

11     right page.

12             I'm interested in the handwritten text in our language.  I am not

13     disputing the translation.  I'd rather know something else from you.

14     These were two separate sheets of paper, as far as I understood your

15     statement, paragraphs 176 through 178.  So there were two separate

16     sheets.  The upper portion of the text was written by Brana Crncevic, as

17     you stated, whereas the lower portion was create by General

18     Radojica Nenezic.

19        A.   I don't see that.

20        Q.   Well, we have it on our screens.

21        A.   I see -- I see it now.

22        Q.   Very well.  So the upper portion in our version was written by

23     Brana Crncevic, as you say, and the lower portion was written by

24     General Nenezic.

25        A.   He didn't write that.  This paper was provided to him.  He didn't

Page 680

 1     write that, someone else did.

 2        Q.   I understand your statement as you saying that you had two

 3     separate sheets of paper provided by Crncevic and Nenezic respectively,

 4     and that on one of the sheets, you actually photocopied both those sheets

 5     on one piece of paper; is that correct?

 6        A.   Yes.

 7        Q.   We can agree, I believe, that the lower portion of the text was

 8     written on a piece of paper which had horizontal lines.

 9        A.   Well, it looks like it.

10        Q.   Well, that's what I can see, if you try to zoom in.

11        A.   Yes.  It was a plain notebook-style sheet of paper.

12        Q.   Whereas the upper portion was written on a clean sheet of paper

13     without any lines.

14        A.   That is correct.

15        Q.   You see in the lower portion there is something which I believe,

16     and I stand to be corrected, that it was covered.  It was crossed out.

17     Can you see -- or basically there is -- there are lines missing, and then

18     after a while we can see the lines continuing.

19        A.   Yes.  Yes.  I have the original still.  So a photocopy was made.

20     I can't recall why some text was covered.  There was probably something

21     underneath, but it's nothing secret.  What was important was the list.

22             I'll try to be brief.  When I came to see General Nenezic, he

23     showed me the paper.  And he said, Just look at how they procure weapons.

24     Apparently it was sent to him by Ilija Kojic or they believed him to be

25     their warehouseman.  That's what he was critical about.  It had to do

Page 681

 1     with the smuggling of weapons.  So there were some alternative routes to

 2     procure weapons, and somebody simply tried their hand at obtaining

 3     weapons in that manner.

 4        Q.   Well, that's not what I was interested in.  Let's go back to what

 5     I asked you before.  You say that some text on the lower sheet of paper

 6     was covered as it was not important.

 7        A.   Correct.

 8        Q.   So you covered that piece of text before photocopying?

 9        A.   I don't remember.  There's nothing there, nothing that would --

10     well, I have the original, and I can forward it if necessary.  There was

11     nothing to be hidden.  I really can't say why I did that.

12        Q.   I saw in your statement that you handed this photocopy over to an

13     OTP investigator.

14        A.   Correct.

15        Q.   Did you show him the original?

16        A.   I did not.  When I was preparing it, I photocopied it in that

17     way.  There's nothing special about that.

18        Q.   Let's look at that covered portion.  We see three letters on the

19     right-hand side followed by the number 30 in the original text.  You see

20     it there.  It is my impression that the last three letters in the

21     Cyrillic script are VIC with the diacritic.

22        A.   Right.

23        Q.   Yes.  Is the first letter V?

24        A.   That may well be.  Perhaps like in the end letters of the last

25     name Zivanovic, but then the number may be indicative of a house address.

Page 682

 1     The street called Sanja Zivanovic is where Nenezic's house was.  I don't

 2     know whether he lived at number 30, but that could be it.

 3        Q.   But it could also be "Savic," do you agree?

 4        A.   I might as well agree, but there's no need to, because there's no

 5     need -- well, even if it is "Savic," it's still not a problem.

 6        Q.   Well, you see, I think, considering that there are weapons

 7     mentioned on this document, if there is a first and last name, I wouldn't

 8     say it's not a problem.

 9        A.   If you agree, I'm ready to bring the original to your office in

10     Belgrade where you can scan it.  There's no problem whatsoever regarding

11     this piece of paper.

12        Q.   Very well.  Mr. Savic, I'll tell you this:  What I dispute in

13     your statement and what my position is, is that as of early May 1991

14     until the end of the war in 1995, you never met Goran Hadzic.  Am I

15     correct?

16        A.   You said 1991?

17        Q.   As of May 1991.  Say around the 6th, 7th, or 8th of May, 1991,

18     until the end of 1995, you never met with Goran Hadzic.

19        A.   I said yesterday we met in Lovas, and I stand by that.  We also

20     saw each other -- now, what year was that?  In any case, when there was

21     an attempted removal of the president of the council of municipalities

22     who happened to be my friend, I asked that Goran be sent since he was in

23     Novi Sad, and he arrived in my home with two more people in the car.

24     Since he didn't dare enter the house, he wanted to go to Pacetina to talk

25     to me there and so we did.

Page 683

 1             I explained to him why I wanted him there, and I asked him to

 2     leave the person alone and not to have him removed since he worked on

 3     some organisational aspects.  He said that he held nothing against the

 4     person in question but that Milosevic had a problem with him and that

 5     that's why he was being removed.

 6             To tell you the truth, I neither kept any record of any meetings

 7     nor was there any need to do that.  And this transpired the way I just

 8     explained.

 9        Q.   Can you tell us who the person in question was?

10        A.   Well, why not?  Boro Drzajic, president of the Executive Council.

11     There was a Regional Council at the time for the area of Vukovar, Dalj,

12     Mirkovci, and other places.  That's what it's all about.

13             Oh, sorry, it wasn't 1995.  That was later.  That was just before

14     the peacekeeping forces arrived.  Until 1995, I'm not sure.  I didn't

15     really think about that much, and there was -- there wasn't any need to.

16     We didn't have any proper contact.

17        Q.   Thank you.  I'll put something to you in brief, hoping to

18     encompass everything that's in your statement regarding that.  I will put

19     to you 18 points that we assert are incorrect in your statement.  I'll

20     enumerate them, and then we'll go back to each one of them.

21             First of all, that you appointed Goran Hadzic president of the

22     SDS board in Vukovar and that later on you backed him, as you said.

23     That's paragraphs 7 and 23 of your statement.

24             Next, that you provided or issued tasks to Vukcevic and Hadzic,

25     which is what you say in paragraph 12 regarding a meeting in Knin where

Page 684

 1     Professor Raskovic was under verbal attack.

 2             Thirdly, that Goran Hadzic --

 3             THE INTERPRETER:  Interpreter's correction:  Where Mr. Raskovic

 4     was attacked.

 5             MR. ZIVANOVIC: [Interpretation]

 6        Q.   Then in paragraph 1, that Goran Hadzic had some personal interest

 7     in being in Belgrade.

 8             Number four, that Goran Hadzic, on the day when he was released

 9     from gaol in Zagreb or, rather, the hospital, called Ilija Koncarevic on

10     the phone, which is paragraph 70 of your statement.

11             Next, that Goran Hadzic provided legitimacy to those who engaged

12     in looting, which is also in paragraph 70.  And that you ever discussed

13     Arkan with him, which is also paragraph 70.

14             Next, item 7, that Lazar Sarac was ever Goran Hadzic's bodyguard

15     as you state in paragraph 78.

16             Eight, that Goran Hadzic ever received 50 side -- pieces of

17     sidearms from Trifunovic [as interpreted], whom you otherwise termed a

18     provocateur, which is in paragraph 80 of your statement.  And you

19     repeated that yesterday, page 70, line 25 of yesterday's transcript.

20             Number nine, that Hadzic told you that he was on his way to

21     Belgrade because of Milosevic.  That is paragraph 82.

22             Number ten, that he publicly advocated the creation of a Serbian

23     state in Slavonia, Baranja, and Western Srijem.  This is paragraph 85.

24             Number 11, that Dusan Pekic was his advisor.  That's

25     paragraph 131.

Page 685

 1             Number 12, that any meeting of the government of Slavonia,

 2     Baranja and Western Srijem was ever held in Belgrade.  That is also in

 3     paragraph 131.

 4             Number 13, that General Pekic supplied Hadzic with weapons.  This

 5     is paragraph 133.

 6             Number 14, that at the 30th of October, 1991, meeting, the moving

 7     of the civilian population from Lovas was discussed.  This is

 8     paragraph 150 of your statement.

 9             Number 15, that Stevo Bogic was subordinated to Goran Hadzic and

10     that he was head of the State Security Service.  This is paragraph 183.

11             Number 16, that Goran Hadzic knew about the minefield incident at

12     Lovas, that he had ever been to Lovas and that he had ever met you there.

13     This is paragraph 183.

14             Number 17, that Goran Hadzic did nothing about protecting the

15     non-Serb population of Slavonia, Baranja and Western Srijem.  This is

16     paragraph 193.

17             And number 18, that Goran Hadzic was in charge of creating

18     conflict in Slavonia, Baranja and Western Srijem.

19             THE INTERPRETER:  Could counsel please repeat the name of the

20     author of the book.  Thank you.

21             JUDGE DELVOIE:  Mr. Zivanovic, the interpreter has asked that you

22     repeat the name of the author of the book.

23             MR. ZIVANOVIC:  The name of the author is Josip Boljkovac.

24             MR. DEMIRDJIAN:  We didn't also get the paragraph number for

25     number 18.

Page 686

 1             MR. ZIVANOVIC:  It is paragraph 196.

 2             MR. DEMIRDJIAN:  Thank you.

 3             MR. ZIVANOVIC: [Interpretation]

 4        Q.   Let me start with the last thing that we spoke about.  I'd like

 5     you to look at an exhibit provided by the OTP.  This is 2786.

 6             You see the document there, don't you?  Perhaps we should zoom

 7     in, or perhaps I could read it back to you.

 8             The text is in the Croatian language.

 9        A.   No need for you to read it back to me.  I'm familiar with the

10     substance.

11        Q.   Let's first try to shed some light on this.  Up until July 1991,

12     Josip Boljkovac served as the interior minister of Croatia.  Do you agree

13     with me, sir?

14        A.   Yes, I do.

15        Q.   This piece was published in "Vecernji List" on the 30th of May,

16     2011.  "Vecernji List" is a Croatian daily published in Zagreb; right?

17        A.   Yes, that's right.

18        Q.   The headline reads -- it's a quote from Josip Boljkovac, who

19     says:

20             "Goran Hadzic was a peacemaker.  He collaborated or co-operated

21     back in 1991."

22             You saw the piece, and you read the piece, didn't you?

23        A.   Yes, yes.  I'm sorry, yes, I did.

24        Q.   You need to answer out loud.

25        A.   Yes.  Sorry, I just wasn't looking at you.

Page 687

 1        Q.   In this piece he said, among other things, just to avoid going

 2     through the whole thing, that Goran Hadzic was in charge of peacemaking.

 3     Did you know about that?

 4        A.   Yes.  This was said at one time in some context or other.

 5     Mr. Boljkovac and I are on very good terms.  I always go and see him when

 6     I have time.  And this goes back to the time when he picked us up from

 7     the Sveto Simunska hospital.  When he came to get us there.  So this was

 8     the first time we met, and we immediately hit it off.  He was a very

 9     special person in Franjo Tudjman's first government.  He was the interior

10     minister.  There were all these problems, and there were all these things

11     that needed doing, and he was adamant that everything should be done in a

12     peaceful way.

13             Back in his ministry, he even had some people there who were

14     Franjo Tudjman's Trojan horses, so to speak, including the deputy

15     minister himself.

16             I've had such interesting conversations with him over time that

17     I'm always glad, because he speaks up for the Croats, and I speak up for

18     the Serbs.  And this is just a perfect reflection of my position.  It's

19     the Croats who should be addressing the Croat issue and the Serbs who

20     should be addressing the Serb issue in turn, if we want to tackle any

21     issue at all.  So that was the situation, and I can't remember the exact

22     cause, what triggered the situation or indeed the statement that he made

23     for this daily.  He probably felt the need to say it at the time.

24        Q.   Are his words truthful?  Was he speaking the truth here?

25        A.   It really depends on the moment.  It's difficult for me to say

Page 688

 1     whether he told the truth, and it's also about how the words were

 2     conveyed by the journalists.  It's a matter of the moment.  I have no

 3     reason to doubt his good intentions.  I have no reason to doubt his

 4     judgement.  There were other statements that were made on various

 5     occasions for different reasons, you know, that sort of thing, but this

 6     got written up the way that we see it, you know, and I can do nothing

 7     else but simply to agree.

 8        Q.   But the point of my question is not the way it was written up,

 9     because we can see for ourselves, can't we?  This is something that

10     Mr. Boljkovac is quoted as saying.  Is that truthful, the substance of

11     the quote attributed to him, or not?

12        A.   Well, I hardly put myself in a position to judge any statement

13     that he may have made.

14        Q.   You just said something about him advocating a peaceful solution

15     for any conflicts.

16             JUDGE DELVOIE:  Mr. Zivanovic, I notice that you are quoting the

17     title of this document or article, whatever, but in the quote you just

18     mentioned, the quote of the person saying this, it is not only said that

19     Goran Hadzic was nothing but a peacemaker, but it's specified at the

20     beginning of the war in Croatia.  So I would like to have that in the

21     quote when you ask the question to the witness.  It might assist his

22     interpretation.

23             MR. ZIVANOVIC:  I didn't finish with this document.  I have more

24     question for him.  But the year 1991 indicates that it was at the very

25     start of the war, or the period before the beginning of the war and the

Page 689

 1     first month of the war.

 2             JUDGE DELVOIE:  I'm sorry that I intervened, Mr. Zivanovic, but I

 3     did because you specifically mentioned the quote.

 4             MR. ZIVANOVIC:  Yes.

 5             JUDGE DELVOIE:  And then the quote was not correct in -- well, I

 6     thought -- I don't say it was not correct.  It was not complete.  Because

 7     the title of an article is always different from the article itself, and

 8     the title of a quote is the same.  So I apologise for intervening.

 9             MR. ZIVANOVIC:  I do not -- I have no intent to mislead the

10     witness or anyone here, but the title says:  "Boljkovac:  Goran Hadzic

11     was peacemaker.  He co-operated in 1991."

12             JUDGE DELVOIE:  Okay.

13             MR. ZIVANOVIC: [Interpretation]

14        Q.   Before we return to this document, I just wanted to ask you one

15     thing.  You say that Mr. Boljkovac was in favour of a peaceful solution.

16     He was the interior minister at the time.  Was he one of the few in

17     Croatia's government back then who was, in fact, advocating a peaceful

18     solution?

19        A.   More like the only one.

20        Q.   If you read on, it says that Goran Hadzic attended numerous

21     meetings where a peaceful solution was being arranged, and Mr. Boljkovac

22     himself attended those as well.  Are you familiar with that, the fact

23     that these meetings were held?

24        A.   If he said so, then I'm sure they were.  As for the exact date or

25     place, I don't have access to that information, but if Boljkovac said

Page 690

 1     this, then I have no doubt that it's true.

 2        Q.   He mentioned Vukovar, Vinkovci, Obrovac, Backa Palanka, but okay,

 3     you say you know nothing about that.

 4        A.   Boljkovac was not at Obrovac, we were.  Backa Palanka, I don't

 5     believe, frankly, that any of us were there.  As for Vukovar, I think it

 6     was the day that we were driven over from the prison hospital.  They

 7     dropped me home, and they had a meeting after that.  But if -- if he's

 8     the person saying this, then I definitely agree.

 9        Q.   Just below the headline you see what it says.  When Tudjman and

10     Milosevic rejected a peaceful solution, Hadzic's line was quashed and war

11     began, says the former minister.

12        A.   Tudjman and Milosevic had great respect for their advisors.  So

13     Milosevic's advisors were all well regarded by Tudjman, and this cut both

14     ways.  Mr. Boljkovac was removed or dismissed at the request of

15     Slobodan Milosevic.  Tudjman fired him, and then Boljkovac wanted some

16     sort of reasoning to be presented for his dismissal, and Tudjman simply

17     told him, "Slobodan does not agree with you being there.  He doesn't like

18     you being there."  And this is something that Mr. Boljkovac shared with

19     me personally.  I have no reason to doubt his openness.

20             So anyone who was in Milosevic's good books automatically

21     qualified with Tudjman as well, because they really respected each other,

22     and they co-ordinated everything between Zagreb and Belgrade, which after

23     all is a well-known fact these days.  Some people know more about it,

24     some people not so much, but that's how it was.

25        Q.   Believe me, I myself had no idea that Tudjman was in a position

Page 691

 1     to affect any personnel decisions made by Milosevic or indeed vice versa.

 2     Frankly, I find the assertion slightly outlandish, especially on the eve

 3     of a major war.

 4             THE INTERPRETER:  Could the witness please repeat the answer.

 5             JUDGE DELVOIE:  Mr. Savic, the interpreter's asked would you

 6     repeat the answer, the last answer.

 7             THE WITNESS: [Interpretation] What exactly is this in reference

 8     to?

 9             MR. ZIVANOVIC: [Interpretation]

10        Q.   I said that I had no idea how Milosevic could possibly affect any

11     personnel-related decisions between Tudjman and vice versa, since we know

12     that these two were diametrically opposed and finally started fighting,

13     entered a war.

14        A.   Yes, and I said they had a great deal of respect for each other,

15     and that their associates were always well regarded on both sides of the

16     divide.  As for them fighting to any great extent, well, I think that is

17     a matter for future debate, frankly.

18        Q.   I'm sorry, sir.  What do you mean "fighting to any great extent"?

19     My impression is it was quite a fierce clash over the four years that it

20     took.

21        A.   Let's try and name a single battle where these two actually

22     clashed.  All the acts of provocation occurring across the country were

23     well organised and well under control.  Look at the footage.  Go ahead.

24     Find something where you encounter a real war atmosphere.  This is mere

25     propaganda if you look at it.  If you look at all that footage of the

Page 692

 1     Home Guard on the Croatian side, can you actually see any Croatian

 2     soldiers in that footage?  Come on.  Or Operation Storm.  Have you seen

 3     footage of that?  They're shooting bullets up into the air, and there's

 4     celebratory fire, but do you have any footage of actual fighting?  Do you

 5     have any footage of the -- the other side, the enemy?

 6             You know what I'm talking about.  So if you really apply

 7     yourself, if you analyse the whole thing closely, then we should probably

 8     give a different name to it.  Large-scale war, hmm.  Victims, yes, there

 9     were some victims, as a matter of fact, but it was all an organised

10     thing.  It was staged.  So it's -- it's not like there was any great

11     degree of hostility between Milosevic and Tudjman that erupted in the

12     form of a war.

13        Q.   I didn't have in mind their personal relationship.  They may well

14     have had one, but their political positions, even though you may not

15     agree, were diametrically opposed when it comes to resolving the crisis

16     in the then Yugoslavia.

17        A.   We were discussing their staff and the mutual respect they had

18     for each other's advisors.  Let's take Sarinic.  He went to Belgrade

19     numerous times.  He was a very close associate of President Tudjman, and

20     for a while he was his chef de cabinet.  There were many other contacts

21     that were not registered anywhere.  There was a lively communication in

22     terms of exchanging information and arranging their associates.  It just

23     wasn't discussed.

24             I'm not putting that in a negative context.  I'm simply stating

25     that.  It was normal, of course, to keep in touch, to be in contact.

Page 693

 1        Q.   I find it hard to understand that, as you say, there was a lot of

 2     footage which only served as propaganda, as PR, if you will.  I am

 3     mindful of the images of Vukovar which certainly could not be used as any

 4     kind of commercial, so to say.  That's why I'm surprised by your answer.

 5        A.   Well, it was propaganda for those who were engaged in

 6     destruction.

 7        Q.   Let's conclude with this exhibit.  In this article

 8     Goran Hadzic -- Mr. Boljkovac states that Goran Hadzic joined the

 9     Milosevic line, the Serb line, and that he took part in the conflict.  He

10     also asserts that it is correct that he was indicted before the

11     International Tribunal and that he's still on the run.  You read the

12     article, and you agree with that.  It's not that he only talked about

13     Hadzic as a -- as a man who was in favour of peace all along.

14        A.   I agree.  There's a shift of position.

15        Q.   Thank you.  In your statement, in paragraph 196 you mentioned a

16     book.  You said that Boljkovac, in that book, wrote that Goran Hadzic was

17     the kind of person who created conflict in Slavonia, Baranja and

18     Western Sirmium and that you find it to be correct.  It's paragraph 196.

19             Let me ask you this first:  Which book is it?  Can you tell us

20     where Mr. Boljkovac wrote that?

21        A.   I think the title is the "The Truth Must Out," [as interpreted]

22     where he describes all that.

23        Q.   Could we next have a look at 1D2, please.

24             MR. DEMIRDJIAN:  Your Honours.

25             JUDGE DELVOIE:  Yes.

Page 694

 1             MR. DEMIRDJIAN:  I apologise.  The previous article was

 2     introduced by Mr. Zivanovic as an exhibit, but it's actually only a

 3     65 ter.  It's only on our 65 ter list.  So it's not an exhibit.  So if

 4     Mr. Zivanovic wants to tender it, it would be the appropriate moment.

 5             MR. ZIVANOVIC:  Yes.  We will ask to tender this exhibit,

 6     although I don't know if it is on the Prosecution list of exhibits,

 7     and --

 8             MR. DEMIRDJIAN:  Yes.  It's at tab 46 of our list.

 9             JUDGE DELVOIE:  So you ask to tender it, Mr. Zivanovic?

10             MR. ZIVANOVIC:  Yes, yes, Your Honour.

11             JUDGE DELVOIE:  Admitted and marked as a Defence -- is it -- as a

12     Defence exhibit then, I suppose.

13             THE REGISTRAR:  Your Honours, this document shall be assigned

14     Exhibit Number D4.  Thank you.

15             JUDGE DELVOIE:  Thank you.

16             MR. ZIVANOVIC: [Interpretation]

17        Q.   Let us have a look at the book by Mr. Boljkovac next.  It is

18     already in e-court, but I also have it in hard copy if that would be

19     easier for you.

20             Let's try and make this exercise easier.  I presume you don't

21     know off-the-cuff where that piece of text is in the book that you

22     mentioned in your statement.  I'll try to make things easier for you.  At

23     the end of the book, I think it is the very last page of this document --

24             MR. DEMIRDJIAN:  I'm sorry, do we have a translation for this

25     book, for the excerpts you wish to show, because we haven't been provided

Page 695

 1     them.

 2             MR. ZIVANOVIC:  Just certain pages of this book are translated

 3     because the book is 200 pages long.

 4                           [Trial Chamber and Registrar confer]

 5             JUDGE DELVOIE:  Mr. Zivanovic, the Registrar tells me that the

 6     translations are not available in e-court.  Is that right?

 7             MR. ZIVANOVIC:  No.  We ...

 8                           [Defence counsel confer]

 9             MR. ZIVANOVIC:  We -- we submitted this translation, and I think

10     that we have it here.  Just a moment, sorry.

11             JUDGE DELVOIE:  Mr. Zivanovic, perhaps I could propose -- I'm

12     looking at the time.  Could you -- could you address your next item - I

13     suppose it's number 16 of your 18 points - and figure this out during the

14     break?

15             MR. ZIVANOVIC:  Yes.

16             JUDGE DELVOIE:  Would that be appropriate?

17             MR. ZIVANOVIC:  Yes.  Yes, Your Honour.

18             JUDGE DELVOIE:  Okay.  Let's do that.

19             MR. ZIVANOVIC:  It seems that the translation appear -- is it?

20             MR. DEMIRDJIAN:  That's the translation of the previous document

21     that was just --

22             MR. ZIVANOVIC:  Oh, sorry.

23             JUDGE DELVOIE:  Yes, that's right.

24             MR. ZIVANOVIC:  Sorry.

25        Q.   [Interpretation] Yesterday, you testified about going to Sid,

Page 696

 1     which is pages 84 and 85 of the transcript.  You said that before going

 2     there, you were in contact with Colonel Djokovic, I believe, from the

 3     military security service, and that he had given you a Scorpion gun.  Do

 4     state your answer clearly, please.

 5        A.   Yes.

 6        Q.   Based on evidence we have here concerning your trip, which is

 7     number 341 on the Prosecution list --

 8             THE REGISTRAR:  Which is now Exhibit P77.50.  Thank you.

 9             MR. ZIVANOVIC: [Interpretation]

10        Q.   It is stated on page 4 in our language and page 3 in the English

11     translation that upon your arrival in Sid on the 29th of September, 1991,

12     you were authorised by the TO Vukovar Chief of Staff Grahovac to assemble

13     volunteers.

14        A.   Yes.

15        Q.   One page before that in the Serbian version, which in the English

16     translation it is pages 2 and 3, it is stated that Grahovac also approved

17     that you can carry M-56, an automatic weapon, for your personal safety,

18     and we even have the number of the weapon mentioned.

19             I'm interested in why you wanted this M-56 if you had already had

20     the Scorpion provided by Colonel Djokovic.

21        A.   Because Mr. Grahovac insisted.  He said, Take this.  I don't know

22     whether I had the Scorpion with me, because I don't usually bear arms.

23     It may have been in my car, but I really don't know.  And I said, Fine.

24     Issue me -- issue a licence for me, and I'll take it.

25             There was no particular reason.  He just said, Well, this is just

Page 697

 1     in case you should be stopped.  It's better to have a weapon with you.

 2     So there was nothing special about the arrangement.

 3             I didn't carry either of the two, actually.

 4        Q.   Did you tell him that you already had an automatic weapon and

 5     that you did not need another one?

 6        A.   Yes.  I'm telling you, it's not that I wanted it.  He insisted.

 7     I think I left the Scorpion back home in Sabac.  It wasn't important to

 8     me.  He gave me the papers, and I put it in the car.  Others did not even

 9     get any papers from him.

10        Q.   According to the documents we have, I can see you were given a

11     licence to carry the Scorpion, but it happened only later, in 1992, and

12     not when you went to Sid.

13        A.   I agree with the date on the licence.  I agree fully.  You know,

14     you can't keep it all in your memory, the date, the period, but it

15     tallies with the sequence of events.  I think it is correct.

16             MR. ZIVANOVIC: [Interpretation] Can we look at the last page of

17     the document in both versions.  We can see it in the Serbian language.

18     Could we scroll up in English.

19             MR. DEMIRDJIAN:  It's the page before in English.

20             MR. ZIVANOVIC:  Yes.  Thank you very much.

21             [Interpretation] Yes.  We'll look at the previous page.

22        Q.   You see, here we see why the licence was issued.  Not just anyone

23     could receive a Scorpion gun.  It's not something a citizen could carry

24     around.

25        A.   Yes.

Page 698

 1        Q.   It says here that the licence was issued pursuant to an order of

 2     the TO commander of the Republic of Serbia and that the order was

 3     strictly confidential.

 4        A.   Yes, Mr. Djokic.

 5        Q.   It is also stated that the order was issued on the

 6     27th of August, 1991, and you were provided with the licence for the

 7     period between the 20th of February and the 20th of September, 1992.

 8        A.   Right.

 9        Q.   So that does not tally with what you told us about receiving the

10     Scorpion gun from Colonel Djokovic.

11        A.   I think this is Djokovic's signature.  Yes.  Djokovic and Djokic

12     is similar, but I think this is Djokovic's signature.

13             As regards the licence, obviously they assign me some sort of

14     higher level or rank.  I told you I didn't ask for such weapon.  I only

15     wanted a licence, and this is the only one.  I didn't even read the

16     licence.  I wasn't interested.

17             He issued it.  He signed it.  There's nothing to discuss.

18        Q.   I'm interested in this:  Did you get the weapon in September 1991

19     or in February 1992?  That's the question.

20        A.   The answer is this:  I received it on the date of the licence.

21        Q.   Hence I conclude that in September 1991 or October 1991, you did

22     not get a Scorpion gun from Djokovic.

23        A.   Well, if we go by the date, that is correct.

24             MR. ZIVANOVIC:  Your Honour, I think it's time for the break.

25     Thank you.

Page 699

 1             JUDGE DELVOIE:  Thank you.  Mr. Savic, we will take the first

 2     break now.  We will return at 11.00.  You will be escorted out.  Thank

 3     you.

 4                           [The witness stands down]

 5             JUDGE DELVOIE:  Court adjourned.

 6                           --- Recess taken at 10.30 a.m.

 7                           --- On resuming at 11.00 a.m.

 8                           [The witness takes the stand]

 9             JUDGE DELVOIE:  Yes, Mr. Zivanovic, please proceed.

10             MR. ZIVANOVIC:  Thank you, Your Honour.

11        Q.   [Interpretation] Mr. Savic, let us now return to that book.  We

12     ran out of time during the previous session, so I'll be showing it to you

13     now.  This is Exhibit 1D2, and that's Mr. Boljkovac's book that we were

14     talking about.  Just to say this again, you say that in that book

15     Mr. Boljkovac talks about Goran Hadzic as being a person who created

16     conflict in Slavonia, Baranja and Western Srijem, and you believe that to

17     be true.

18             Let us go back to that book.  We'll not go through all of its

19     pages and it's very difficult to pinpoint the exact spot where he talks

20     about that, but I would like us to go to page 10 in e-court, which is the

21     very final part of the book.  Why is that important?  Because we have a

22     list of names there.  It's a glossary of names mentioned in the book, and

23     we'll find there the exact reference to Goran Hadzic, the page number and

24     so on.

25             MR. ZIVANOVIC:  It's not translated, but I think it is not

Page 700

 1     necessary, because it contains only first and last names of the persons.

 2             JUDGE DELVOIE:  Is it the one we have on the screen now?  Is it

 3     that page?

 4             MR. ZIVANOVIC:  No.

 5             JUDGE DELVOIE:  That's what I thought.

 6             MR. ZIVANOVIC:  We need -- in B/C/S version it is page 10.  It is

 7     register of names.  We shall go two page -- two pages to the letter H.

 8     Next page, I think.  Yes.  I think that we are here.

 9             THE REGISTRAR:  This is page 14, for the record.  Thank you.

10             MR. ZIVANOVIC:  Sorry.

11        Q.   [Interpretation] So this is the list of names mentioned in the

12     book with the appropriate page references, and you can see where

13     Mr. Hadzic's name crops up in the book, the letter H.  His name is

14     mentioned in two places, page 230 and page 235.  Is that right?

15        A.   Yes.

16        Q.   Can we now please go to page 230 to check the reference.  In the

17     English, this is page 12.

18             JUDGE DELVOIE:  And for the record, the name of the book is "The

19     Truth Must Come Out."  I noticed that in the transcript there was another

20     name, "The Truth Must Be Told," I think, but it is "The Truth Must Come

21     Out."

22             MR. ZIVANOVIC:  That's correct.

23        Q.   [Interpretation] This is page 230, page 12 in the English

24     translation.  Do you see the context in which reference is made to your

25     name and Mr. Hadzic's name?  Mr. Boljkovac talks about the arrest of you

Page 701

 1     and Goran Hadzic.  The names are only mentioned in the heading.

 2             The next page is 235.  That's two pages on.  The English is

 3     page 23 through page 25.  I think that's correct.

 4             Mr. Boljkovac talks about Goran Hadzic here.  Perhaps we could

 5     read this portion.  It's not really that long.  He says:

 6             "The very controversial case of Goran Hadzic, a man wanted by

 7     The Hague, and at one time the leading figure in the Krajina parastate is

 8     also linked to the events in Plitvice.  The above-mentioned meeting in

 9     Obrovac was in fact attended by Hadzic, the then-member of the

10     Executive Board of the Serbian Democratic Party, and Borivoje Savic, the

11     secretary of that party's Vukovar branch.  At the time, they advocated a

12     more moderate option, which is borne out by the fact that over the course

13     of those weeks they were part of the Serbian delegation which was in

14     Zagreb for talks with Tudjman.  My deputy, Degoricija, was in contact

15     with both of them during that period and was trying to improve

16     collaboration.  My deputy even gave Hadzic an official pistol.

17     Degoricija was convinced that in this way he had succeeded in getting to

18     the very top echelons of the Serbian rebel hornets' nest with his

19     tentacles which, however, proved to be a delusion.

20             "As chance would have it, when these two men were returning from

21     Obrovac on Easter night, they actually stayed at the Plitvice hotel.

22     They were among those arrested in the morning and were badly beaten

23     because of the pistol that Hadzic had on them, since the policemen

24     treated them as rebels.  They mentioned Degoricija, but the policemen

25     took this to be an additional act of provocation.  They spent a brief

Page 702

 1     period in hospital because of their injuries.  It was only once we had

 2     been informed of the arrest that the two men were released and

 3     subsequently returned to Vukovar.

 4             "I established contact with them in April before I left for a

 5     meeting with the Serbian minister of internal affairs,

 6     Radmilo Bogdanovic, in Backa Palanka.  We also attended some meetings

 7     with representatives of the Serbian community in Vukovar and Vinkovci,

 8     where I was adamant that we should strengthen the inter-ethnic dialogue.

 9              "The denouement of Hadzic's story is well known.  Contrary to

10     Savic, who lives in Croatia to this day, the bearded warehouseman from

11     Pacetina took special care to dispel any suspicion that he had actually

12     been in contact with the Croatian MUP up until the time of the carnage in

13     Borovo Selo.  He provided proof of his suddenly resurgent radicalism in

14     1992 through 1993, when he assumed the position of president of the

15     self-proclaimed 'Serbian Republic of Krajina.'  As a war crimes suspect,

16     he was on The Hague Tribunal's wanted list, but continued to live

17     peacefully in Vojvodina for years.  He disappeared after the Serbian

18     authorities themselves informed him that he would be arrested after all,

19     so justice has not yet been done."

20             Having read this, do you notice any references by Mr. Boljkovac

21     in this portion to Goran Hadzic as being the person who stirred up

22     conflict in Slavonia, Baranja and Western Srijem?

23        A.   The text itself contains a number of imprecisions.

24        Q.   But I'd like to take you back one step.  I'd like to take you

25     back to your own statement in paragraph 196 where you say that in his

Page 703

 1     book, Boljkovac says that Goran Hadzic was the person who created

 2     conflict in Slavonia, Baranja and Western Srijem.  I showed you the

 3     relevant portions of the book where Goran Hadzic's name appears.  Have

 4     you come across any references in the relevant portions to Goran Hadzic

 5     as a person who created conflict in Slavonia, Baranja and Western Srijem?

 6        A.   But if you analyse the text itself, you can arrive at that

 7     conclusion as well, can't you, the very beginning of that portion, and

 8     then later on in the text suspicions like that might crop up.

 9        Q.   Suspicion is one thing, but what you state is that he actually

10     wrote that.  It is up to you to interpret this any way you like.

11     Nevertheless, in your statement you claim that Boljkovac in writing

12     actually described Goran Hadzic as a person who created conflict in

13     Slavonia, Baranja and Western Srijem?

14        A.   In one of the interviews in the written media and there was a TV

15     show as well where Boljkovac actually said this.  I don't remember how

16     specific I was, whether indeed I said that he wrote this in his book.

17     Nonetheless, there are published articles and pieces containing

18     statements that he made to precisely that effect.  I'm not sure I said he

19     wrote this in his book.

20             The text itself is quite imprecise.

21             THE INTERPRETER:  Microphone, please.

22             JUDGE DELVOIE:  Mr. Zivanovic, please wait for the interpreters.

23             MR. ZIVANOVIC:  I apologise.  [Microphone not activated].

24             JUDGE DELVOIE:  Please proceed.

25             MR. ZIVANOVIC: [Interpretation]

Page 704

 1        Q.   We'll read another even shorter portion from Mr. Boljkovac's

 2     book.  This is at page 238.  That's two pages on from the page we were

 3     looking at.  In the English, that is page 26.

 4             It reads:

 5             "The -- it was in fact during those months that the type of

 6     provocations carried out by the Serbian extremists in the territory of

 7     the Krajina municipalities were mirrored on the other side in the events

 8     which occurred in Slavonia.  There were frequent incidents in the field,

 9     which, according to information I had at the time, were mostly provoked

10     by the Croatian side."

11             Based on that, my impression is Mr. Boljkovac was actually quite

12     specific when he talked about the incidents in Slavonia, Baranja and

13     Western Srijem which led to the clashes that eventually erupted, and it

14     is not my impression that he mentioned Goran Hadzic as being a person who

15     created conflict, as you suggested, in Slavonia and Baranja.  Do you

16     agree?

17        A.   Was I speaking about the co-ordination between Belgrade and

18     Zagreb in relation to those incidents?  I think I actually mentioned

19     that.  Co-ordination was there.  That much is certain.

20             One act of provocation is stoked up by both of the sides involved

21     in a manner of speaking.

22        Q.   Yes, but I think you explained something to the effect that there

23     was some agreements between the two sides.

24        A.   Yes, yes.  That's where it's at.  That's where you find the

25     initiators as well as those involved, maybe not by name, but we did speak

Page 705

 1     about the co-operation between Milosevic and Tudjman, didn't we.  We

 2     spoke about the persons who worked with them.

 3        Q.   All right.  Thank you very much.  I would now like to pick up

 4     where we left off before the break.  So if we look at these documents,

 5     what follows is that on the 29th of September, you arrived in Sid.  You

 6     met Slobodan Grahovac, and you obtained from him a permit to carry

 7     firearms, and he also tasked you with something on that occasion.  This

 8     is 341, OTP Exhibit 341.

 9             MR. ZIVANOVIC:  Sorry, I would just tender this exhibit, previous

10     exhibit into evidence.  It is 1D2.

11             JUDGE DELVOIE:  Admitted and marked.

12             THE REGISTRAR:  It should be assigned Exhibit Number D5.  Thank

13     you.

14             JUDGE DELVOIE:  Thank you.

15             MR. ZIVANOVIC: [Interpretation]

16        Q.   Just to jog our memories, the 29th of September, 1991, you

17     received permission from Slobodan Grahovac to gather volunteers, and you

18     were also granted a permit to carry an M-56; right?

19        A.   Yes, that's right.

20        Q.   Do you know what was happening, for example, on the

21     29th of September in those areas, the area where you happened to be at

22     the time in Sid?  Can you remember that?  Not necessarily that same day,

23     but the next day and that general time-frame.

24        A.   The area around Sid was teeming with soldiers all the way from

25     Bacinci, which is not far from Sid, Vukojevci, and then along the road to

Page 706

 1     Bajakovo, as well as the town itself.  There were quite many volunteers

 2     in the town itself.  It was difficult to say which unit they belonged to.

 3     There were all sorts there.  The town was full.  And there were all these

 4     staff activities registering people and dispatching them to Vukovar.

 5        Q.   You probably know that it was on at that day that the

 6     1st Guards Brigade of the JNA headed towards Vukovar.

 7        A.   I don't know whether it was on that same day but the

 8     Guards Brigade did not arrive from that direction.  The Guards Brigade, I

 9     think, came across the Danube.  Actually, I'm speculating.  Actually, I

10     don't really know which direction they came from, but it is possible that

11     what you say is correct.

12        Q.   In other words, you didn't see them or you have no knowledge

13     about that?

14        A.   That is correct.

15        Q.   This authorisation to assemble volunteers was provided to you on

16     the 29th of September, 1991, and it is clear that it was to be in force

17     for a month until the 30th of October.  If you wish me to show it to you,

18     we can.

19        A.   No.  I'll take your word for it.

20        Q.   So that is Exhibit 341, page 4 in the Serbian version and 3 in

21     the English.  We have already seen that.

22             According to my information, you arrived in Lovas on the

23     23rd of October.  Is that correct?

24        A.   I believe so.

25        Q.   According to that information, and you did discuss that in

Page 707

 1     paragraphs 152 through 155, there were volunteers there already from the

 2     Dusan Silni Detachment.

 3        A.   Yes.

 4        Q.   And you got in touch with them?

 5        A.   I did.

 6        Q.   What was the nature of your communication with them?

 7        A.   A very good one.  I asked them simply to conduct properly while

 8     they were in the village irrespective of whether they had done anything

 9     previously.  I asked them to assist if there is any need and to stay near

10     their places of accommodation.  There were no particular problems with

11     them.  I asked them who had brought them there.  They said Aca Vasiljevic

12     had, without me insisting on any names.  So I asked them who brought

13     them, and they said Aleksandar Vasiljevic did.

14             Throughout my stay there, we would meet when I happened to be in

15     the village, although there were no particular tasks or duties to attend

16     to.  In any case, I met with them on a number of occasions.

17        Q.   Who did they receive their orders from, if you know?

18        A.   I can't say.  There were no particular orders.  Once Mirko Jovic

19     was there with another man.  I don't know what was the nature of their

20     communication on that occasion, but he was there once.  I didn't see him

21     afterwards.

22        Q.   Some exhibits that were shown to you, which you have as well,

23     include minutes taken by you.  In particular, it is number 498 on the

24     Prosecution list.  The minutes in question are dated the 30th of October,

25     1991.  You are designated as the person taking the minutes in the

Page 708

 1     document itself.  It means that the minutes were drafted by you; correct?

 2        A.   Yes.

 3        Q.   There is a list of attendees on behalf of the government, as you

 4     mentioned.

 5        A.   Yes.  That's how they introduced themselves.

 6        Q.   I can see here that you assigned certain positions to the

 7     attendees which were not the positions they held according to a decision

 8     that was made on the members of government for Slavonia, Baranja, and

 9     Western Sirmium, which is Prosecutor's 322.

10        A.   Can you point out the errors?

11        Q.   The first person is Vitomir Devetak.  You mention him as the

12     president of the SDS.

13        A.   Borovo Selo.

14        Q.   Well, we don't find it there, but Vitomir Devetak was a

15     government minister in charge of the war economy.  If we go back to that

16     decision number 322, we find his name under number 4.

17        A.   I can see it.  What I know is that he was the president of the

18     SDS board in Borovo Selo.  I didn't know that he was the minister of war

19     economy.  It seems to be my mistake.

20        Q.   The next person is Stevo Bogic, aka Jajo, deputy prime minister

21     and state security chief according to your minutes.

22        A.   Yes.

23        Q.   In the decision published in the Official Gazette of the Serbian

24     district we read that Stevo Bogic was the minister with that portfolio.

25        A.   When was the decision issued?

Page 709

 1        Q.   On the 25th of September.  So a month before this document.

 2        A.   Yes.  It seems, then, that I assigned him a more senior position

 3     than he actually held, but in any case, I agree.  I don't think it's a

 4     major mistake or omission, though.  The fact is that he was in

 5     attendance.

 6        Q.   As far as I can see, this is the cover page of the minutes.  Did

 7     you keep minutes for the entire session?

 8        A.   Yes, I did.  I noted each and every contribution, but here at the

 9     beginning I simply wanted to list those in attendance and the agenda as

10     well.  The agenda was under number 1, political and security situation,

11     et cetera.

12        Q.   We can see that.  There's no need to read it out.

13        A.   Excuse me.  Yesterday, I did touch upon this.  The key item was

14     number 2, economical, agricultural problems.  Members or presidents of

15     municipalities and local communes were consulted in terms of the autumn

16     season and production of raw materials.  That was the key issue.

17        Q.   When you spoke to the investigators of the OTP, did you tell them

18     that the minutes contained -- contain more than one page?  You actually

19     kept notes of the entire meeting.  This is only the first page.

20        A.   Yes, I did explain that, and I explained how the meeting was

21     called, as well as the topics discussed.  You see, this was typed on a

22     computer.  We did not have a typewriter.  Actually, at the time, I did it

23     all in handwriting, and instead of copying it all because there wasn't --

24     there were things that were not so important, I explained it the way I

25     did.

Page 710

 1        Q.   And where are the other pages of the minutes?  Why did you not

 2     provide them?

 3        A.   I have them.  I can send them, no problem.  I can send them to

 4     your office.

 5        Q.   Weren't you asked then to provide the entire minutes rather than

 6     just the first page?

 7        A.   Well, no, I wasn't.  And there didn't seem to be a problem.

 8        Q.   Mr. Savic, we got hold of another version of minutes from the

 9     same meeting.

10        A.   That was produced by the army, wasn't it?  There was someone from

11     the armed forces or actually a local commune employee who did it on their

12     behalf; am I correct?

13        Q.   Well, I was about to show it to you, so you can tell us whether

14     that is the case.  It is 1D8.

15        A.   Yes.  Yes.  If I may be allowed to comment upon both minutes.

16     The first set of minutes accuses no one.  Any of the notes that I took

17     down.  This is how minutes were kept, but there were also secret minutes

18     kept by those who were in charge of operations.  That may be the only

19     difference.

20             In any case, all those in attendance were free to take their own

21     notes or minutes.  It was not prohibited.  People did the way they chose

22     to in that session.  The one I produced -- actually, these minutes here

23     were made for a certain purpose, and I know how it happened.

24        Q.   When you say that the first set of minutes accuses no one, what

25     do you mean?

Page 711

 1        A.   I had in mind the first set of minutes which I delivered.  It was

 2     simply a way to note down that there was a meeting, and I explained it,

 3     and there's nothing to discuss any further.  This set of minutes or any

 4     other that may be in existence, that's another thing.

 5        Q.   But you did not forward the entire minutes, only the first page,

 6     as you say.

 7        A.   I showed them the document.  If anyone needs anything on top of

 8     that, I'm free -- I'm willing to have it delivered, no problem.  I simply

 9     wanted to register that there was a meeting.  If anything else is

10     necessary, I will gladly provide it.

11        Q.   You say you showed it to them.  You mean the Prosecutor's office

12     when they interviewed you, or someone else?

13        A.   I showed it to them?  What do you mean?

14        Q.   You said, "I showed them the document."  That's in the record.

15        A.   Could I have that interpreted, please?

16        Q.   I believe they will interpret that for you.

17        A.   I still did not hear it.  I'm not receiving anything.

18             MR. ZIVANOVIC:  There's some technical problem.  To repeat my

19     question.  Sorry.

20        Q.   [Interpretation] You said that the first document accused no one,

21     and that was the basis for my question.  You said you forwarded the

22     minutes, but I simply noted that it was only the first page, and then you

23     said you showed it to them.  Who is "them," the Prosecutor?

24        A.   I showed them the minutes.  That's what I meant.

25        Q.   I'm asking you who did you show it to?

Page 712

 1        A.   The Prosecutor's office, because you received it from them.

 2        Q.   So you say you only handed over that one page; right?

 3        A.   Yes.

 4        Q.   Which means that we couldn't get the transcript of the minutes in

 5     its entirety; right?

 6        A.   I never handed over a handwritten set of minutes.  I was only

 7     referring to the one page that I did hand over.

 8        Q.   All right.  I understand that.  You suggest that the minutes you

 9     were shown were kept by the military; right?

10        A.   For the purposes of the military, by one of the officials of the

11     Lovas local community.

12        Q.   So there are these minutes and the fact that the minutes were

13     kept by military, yet you make absolutely no reference to this in your

14     statement; right?

15        A.   No one asked.  We just never ended up discussing that.

16        Q.   These are handwritten minutes, which makes it -- the document

17     very difficult to read.  Nevertheless, the Translation Unit appears to

18     have done a very good job.  They even provide a translation.  We'll go

19     through it to check for errors.  Nevertheless, I won't be asking you

20     about the substance of the minutes.  I'll be asking you to look at the

21     penultimate page of the minutes.

22             The English reference is page 13.  I'm looking at the English

23     translation.  Near the top I can see that some text is missing.  Now I'm

24     looking at the Serbian and it reads:  "A meeting of representatives of

25     the villages and government at Lovas," followed by the date.  Do you

Page 713

 1     agree, sir?

 2        A.   Yes, I do.

 3        Q.   You see what is quite noteworthy for our purposes is the Serbian

 4     text.  I see all these handwritten entries, the names of those attending

 5     the meeting.  That's the column on the left-hand side followed by another

 6     column, the place they hail from; right?

 7        A.   Yes.

 8        Q.   Followed by yet another column containing their official

 9     capacity, position; right?

10        A.   Yes, that's right.

11        Q.   There's no need to go through each and every one of these

12     individual names.  Rather, I'd like us to go to the next page, which I

13     think is the final page of the English translation.

14        A.   Yes, I can see that.

15        Q.   Number 25.  That's your name; right?  Borivoje Savic.  Place,

16     Lovas.  And then it reads "Member of the TO staff."  The Territorial

17     Defence Staff; right?  Is that what it says?

18        A.   Yes, indeed.  That's what it says.

19        Q.   Based on what I've seen here, I can infer that each of these

20     persons just put their own names on this list in their own handwriting;

21     right?

22        A.   Yes.  And my signature is there too.

23        Q.   It says "Lovas," and it says "TO staff member."  I think you

24     wrote that, didn't you?

25        A.   Truth to tell, I can't be absolutely certain whether I was the

Page 714

 1     one who wrote those words there.  Nonetheless, I wasn't trying to appear

 2     to hold an office of greater importance rather than just being a member

 3     of the TO staff.  So I can hardly believe this.  Who wrote this?  Why did

 4     they write it like this?  But I don't see a thorny issue here.  I was no

 5     staff member.  That much is certain.  Nor did I ever describe myself as

 6     one.

 7             I'm trying to think back.  There was a contact person, but I

 8     myself was not involved in the staff's work or indeed linked to the staff

 9     at all.  Not that the staff was necessarily involved in the specific

10     activities apart from making occasional appointments.  I'm not really

11     aware of any hands-on activities that they pursued at all.

12             In the Lovas area, there were no actions and no movement.

13        Q.   If I understand you correctly, you are not in a position to

14     confirm that the portion of text that follows your name, meaning the

15     place and the title or official capacity, where it says "Lovas," and then

16     it says "TO staff member," you cannot confirm that you wrote that?

17        A.   No.  Where it says "TO staff member," that's not my handwriting.

18     I'm sure about that.

19        Q.   But you see, I'm no handwriting expert.  If at any point that is

20     indeed required, we can enlist the assistance of one.  But I'm looking at

21     all the other persons -- the names signed in this document.  For example,

22     number 23.  My impression is that the handwriting is the same where the

23     name is written, where the place is written, and where the official

24     capacity or position is written.  Same handwriting throughout, in other

25     words.  Likewise number 24.  But now you are trying to tell us that it is

Page 715

 1     not the case with your own number.  Yet again, if we move on to

 2     number 26, the same pattern emerges, the same handwriting throughout

 3     across the three columns.  27, 28, and so on and so forth.

 4        A.   This is tendentious, the way you're putting it.  It has nothing

 5     to do with it.  It's not that I was afraid of anything or indeed trying

 6     to hide anything.  It wouldn't be a problem for me to own up if that

 7     indeed were the case, but it's not, you know.  If that is the greatest

 8     problem that we have here, I might as well say yes, you're right, but

 9     it's not necessarily that I consider this to be a major wrongdoing or a

10     major sin.  It might be a instance of manipulation, yes.  But what is

11     this?  It is set of minutes.  They were kept just like that.  I signed

12     this because it was put in front of me.  TO staff member, nothing to do

13     with anything at all.  I would never have agreed to become a staff member

14     of any kind.  Although even that, even that, what would have been wrong

15     with that if you just stop a minute to ponder the possibility?  What?

16             So that's why.  You see what I'm trying to say.  How was this

17     used?  You know, that arouses my suspicion.  It's not about me.  I'm not

18     the problem here.  Will you choose to believe that I was a staff member

19     or not, well, that's up to each of us individually; right?  But it's not

20     something that bears any relevance at all to this.

21        Q.   All right.  I think it's up to the Trial Chamber to judge the

22     relevance, but if we link this up with the other document showing you to

23     be in the Territorial Defence Staff in Sid, this might after all prove to

24     be interconnected, you see.

25        A.   Oh, yes.  Well, I don't know.  I can't say, can I.  I don't think

Page 716

 1     there's anything about this that can be challenged.

 2             This is an area with paramilitary activity, and there were no

 3     official positions, really.  So if you're talking about the posting

 4     itself, okay, you can have it.  I don't care.  It's not that I'm bothered

 5     by this.  There is someone who believes that I was a member of this

 6     staff.  I can provide an additional explanation if you think this is

 7     something that is cumbersome, but the one thing that I'm telling you is

 8     that the handwriting here is not mine.

 9        Q.   You say you were communicating with these people, the members of

10     the Dusan Silni Detachment in Lovas; right?

11        A.   Yes.

12        Q.   This is paragraph -- just a minute, please.  Paragraph 152

13     through 155 of your statement.

14             I think you also suggest that you warned them.  You said

15     something about not having any of it, them causing an incident.  They

16     were to behave, something like that; right?  Did they actually follow

17     your instructions?

18        A.   Yes, yes.  Well, this is only about the period of time they spent

19     with me.  Aside from that, when they were outside my purview, so to

20     speak, how was I to be responsible for anybody's actions, you see?

21        Q.   What was the exact time period that they were with you?

22        A.   From the time I arrived and then the following 20 days until I

23     left, but they were there throughout, and they stayed after I'd left.

24        Q.   Just tell me one thing, please.  Did you have any information

25     suggesting that they were not behaving properly?

Page 717

 1        A.   There were complaints about a man named Kosta.  I'm not sure

 2     about his surname.  People were complaining about him.  I think he even

 3     killed someone.  I'm not sure who, whether it was a man or a woman, but

 4     it -- he was trouble.  The other lads there were quite fair.  They were

 5     all right.

 6        Q.   Based on my information, you gave evidence at the Higher Court in

 7     Belgrade in the Lovas case, did you not?

 8        A.   Yes, that's true.

 9             MR. ZIVANOVIC:  May we have 1D6, please.

10             Sorry, Your Honours, I have forgot again to ask admitting into

11     evidence the previous document.  It is 1D8.

12             JUDGE DELVOIE:  Admitted and marked.

13             THE REGISTRAR:  It shall be assigned Exhibit Number D6.  Thank

14     you.

15             MR. ZIVANOVIC:  Thanks.

16                           [Trial Chamber and Registrar confer]

17             JUDGE DELVOIE:  Please proceed, Mr. Zivanovic.

18             MR. ZIVANOVIC:  Thank you.

19        Q.   [Interpretation] In that trial, you appeared as a Defence witness

20     for the two accused; right?

21        A.   Yes.

22        Q.   You say that you arrived in Lovas on the 23rd of October, that

23     evening, that is.  The reference is pages 3 through 7 in the Serbian and

24     pages 3 through 9 in the English.

25             Ten days previously, you had gone to see General Simic.  The

Page 718

 1     Serbian reference is page 7, and page 9 in the English.  He refused to

 2     talk to you.  Djordje Ivkovic came with you, who was for a while the SUP

 3     head in Vukovar.  That's page 8 in the Serbian and page 10 in the

 4     English.  When he came there, you found some volunteers.  You showed them

 5     into your office.

 6                           [Trial Chamber and Registrar confer]

 7             JUDGE DELVOIE:  Yes, Mr. Zivanovic.

 8             MR. ZIVANOVIC:  Thank you.

 9        Q.   [Interpretation] Among them was a man named Zoran Obrenovic, also

10     known as Azdaja.

11        A.   Yes.

12        Q.   That's page 10 in the Serbian and page 13 for the English.  You

13     say there were soldiers all over Lovas.  Page 12 in the Serbian and

14     page 15 in the English.  You say you had a permit from Belgrade.  Again,

15     page 12, Serbian; page 16, English.  The day before the meeting took

16     place on the 30th of September, you saw Arkan.  That's page 13 Serbian,

17     and page 17, English.  The 30th of September.  You also drew up an agenda

18     for the meeting, and you kept your own minutes.  You were then told that

19     the minutes were kept by Pavle Klisuric, a local from Lovas; right?

20        A.   Yes.

21        Q.   You also said that the staff at Sid was set up in October.

22     That's page 15 Serbian, page 19 English.  The staff commander was

23     Dusan Filipovic.  15 Serbian, 20 English.  The staff was headed by

24     Slobodan Grahovac.  Grahovac was assigned as jureske [phoen] for a while

25     in 1992.  That's also what you said.  You said you were there because you

Page 719

 1     were making a sacrifice.  16 Serbian, 21 English.  You say you were given

 2     a permanent permit at the Central Committee building and this was

 3     arranged for you by an acquaintance from Osijek, Nikola Kaloper.  Page 17

 4     in the Serbian and page 23 in the English.

 5             General Nenezic told you that the army had kicked up a shit storm

 6     in Lovas.  That's 18 in the Serbian and 23 in the English.

 7             Zoran Obrenovic, aka Azdaja, was particularly attached to you and

 8     he followed you all over.  Page 21 in the Serbian and page 27 in the

 9     English.  You don't know what the volunteers were doing in Lovas.

10     Page 22 in both versions of the text.  You said you carried a Scorpio.

11     Page 23 in the Serbian and page 29 in the English.  You said the

12     volunteers were from the Dusan Silni Detachment.  Page 23 in the English

13     and page 31 -- page 23 in the Serbian and page 31 in the English.  You

14     also said that you were given a TT weapon by Nikola Kaloper.  Page 29 in

15     the one version and page 30 in the other.  And you admitted that you

16     signed the minutes that you were shown.

17             I quoted this in a bid to avoid reading the minutes in their

18     entirety, but is my rendition accurate, sir?

19        A.   I have one addition to make.  We did not go to see Arkan.  The

20     day before our departure for Erdut, we were on our way to Novi Sad to see

21     Mr. Hadzic at his place.  Ljuban went there to pick him up, but he had

22     taken cover because he wasn't willing to travel to Erdut.  That at least

23     was our inference, because we had agreed for him to wait up there.  And

24     then we pressed on for Erdut.  We were there in a government office.  I

25     can't remember who was there, what specific government members.  I

Page 720

 1     recommend that Gogic was there.  And then at one point in time, Ljuban

 2     told me that they were on their way to the kitchen downstairs because

 3     Arkan was there.  It's actually a room outside the government building,

 4     and he said, You stay here and talk to Jajo.  So they left and Jajo and I

 5     were now alone in the office.  And then he goes, Okay, so you're one of

 6     us; right?  And I say, Is this supposed to be some sort of conversation

 7     between us?  And he said, Yeah, and what were you thinking?  And I said,

 8     You stupid git.  Don't you know that nothing has changed between us, and

 9     I left the room.

10             Outside there were two of Arkan's Men waiting, and they saw me

11     over to the kitchen where Arkan was with a friend of mine who exerted

12     quite some influence on Arkan, but it was nothing to do with the meeting,

13     because everything had been agreed upstairs at the meeting.  So Arkan was

14     there and it was a matter of protocol of some kind to go there and see

15     him since they were there.

16        Q.   You just mentioned Goran Hadzic.  So you went there to see him,

17     but you didn't actually end up seeing him.  Are you trying to suggest

18     that he avoided seeing you?

19        A.   It was Ljuban Devetak who arranged the whole thing.  We arrived

20     in Novi Sad.  We got to his flat.  Ljuban had 15.000 dinars for him.  He

21     went up to his flat.  He left the money there, but he said, He's out.

22     He's probably run away.  So there you go.

23             MR. ZIVANOVIC:  Can I ask 1D6 to be admitted into evidence,

24     please.

25             JUDGE DELVOIE:  Admitted and marked.  Mr. Demirdjian.

Page 721

 1             MR. DEMIRDJIAN:  Yes.  Just -- does counsel want to enter the

 2     entire testimony of Mr. Savic in evidence?

 3             MR. ZIVANOVIC:  Yes, that's correct.

 4             MR. DEMIRDJIAN:  All right.  Your Honours, I'm not entirely sure

 5     how this works.  We already have the witness's 92 ter statement in

 6     evidence, and counsel did elicit a number of questions out of the

 7     testimony.  I don't know if we're circumventing some of the rules by

 8     tendering the entire testimony of the witness before another court.  I

 9     think the answers are in the transcript.  I don't know whether the whole

10     testimony needs to go in.

11                           [Trial Chamber confers]

12             JUDGE DELVOIE:  Mr. Zivanovic, this testimony is much longer than

13     the parts you were discussing with the witness; is that right?

14             MR. ZIVANOVIC:  That's correct, Your Honours.  I went through

15     whole relevant issues with him during this cross-examination, but I think

16     that it would be good for the Trial Chamber to have entirety of this

17     testimony, to see it.  It would be -- it would be useful in my -- in my

18     view, and it is used for the purpose of impeachment also so that --

19             MR. DEMIRDJIAN:  Your Honours, may I just add one more thing?

20             JUDGE DELVOIE:  Yes.

21             MR. DEMIRDJIAN:  The witness has not been given the chance to

22     review this transcript and to verify the accuracy, and the transcript

23     that we have is 38 pages.  My learned friend has read maybe about

24     ten excerpts out of it, so we don't know what else there is in there,

25     whether the witness actually confirms that everything in there is

Page 722

 1     accurately transcribed.

 2             JUDGE HALL:  Mr. Zivanovic, I have another concern.  If I

 3     understand your answer to the -- your last answer to the President

 4     correctly, when you were talking about the entirety of that transcript,

 5     portions of which you have put to the witness, being useful for the

 6     possibility of impeaching him, the implication of that is that over and

 7     apart from such items as you would have identified by putting questions

 8     to him and eliciting answers, the implication is that the Chamber would

 9     itself go into portions of the document and, to add to what

10     Mr. Demirdjian has -- to what Mr. Demirdjian has said, it's a document

11     which the rest of it the witness hasn't necessarily taken on board and

12     then the Chamber itself would use it to challenge the credibility of the

13     witness.  I have a problem with that.  Did I misunderstand your

14     suggestion?

15             MR. ZIVANOVIC:  Very simply, I think that entirety of this

16     particular testimony of the witness before War Chamber of the Belgrade

17     court may assist the Chamber in assessment of credibility of the

18     testimony of the witness before this Chamber.  It was only purpose,

19     because for my -- for my proposal to admit this document into evidence.

20             JUDGE DELVOIE:  The Trial Chamber -- yes, Mr. Stringer.

21             MR. STRINGER:  I apologise for intervening, Mr. President.  It's

22     just to add, not with respect to this specific transcript, but the

23     Trial Chamber's probably going to learn that there are proceedings that

24     occurred in Belgrade and in Osijek involving various events that are part

25     of -- in -- that are charged in the indictment in this case, and so I

Page 723

 1     just wanted to mention, I think it's -- whatever approach the Chamber

 2     decides to take on this issue, it's probably one that could recur,

 3     because there is actually a lot of overlap between this trial and

 4     proceedings that have already occurred either in Belgrade or in Osijek.

 5             JUDGE DELVOIE:  The Trial Chamber is of the view that it cannot

 6     admit the entirety of this testimony into evidence, and we will stick to

 7     what is on the record.

 8             MR. ZIVANOVIC:  May I proceed, Your Honour?

 9             JUDGE DELVOIE:  Yes, of course.

10             MR. ZIVANOVIC:  Thank you.

11        Q.   [Interpretation] Mr. Savic, I will now take you back to your

12     statement, paragraph 70.  There, among other things, you say that you

13     broke off your relationship with Hadzic the day you left the prison

14     hospital in Zagreb and when you heard that allegedly he spoke on the

15     phone with Ilija Koncarevic.  Among other things, you asked him why he

16     was around people like Arkan.  My question is this:  Did you ask him that

17     question then, why he was around people like Arkan en route back from

18     Zagreb?

19        A.   Pardon me.

20                           [Trial Chamber and Legal Officer confer ]

21             JUDGE DELVOIE:  Please proceed, Mr. Zivanovic.  I'll come back to

22     the previous issue when you --

23             THE INTERPRETER:  Microphone, please.

24             JUDGE DELVOIE:  Sorry.  Just one moment.  I'm pushing the -- I'm

25     pushing the wrong button.  Sorry about that.

Page 724

 1             Mr. Zivanovic, what I said was, so now it's on the record, that

 2     you may proceed, and that I'll come back to the previous issue in between

 3     two questions.

 4             MR. ZIVANOVIC: [Interpretation]

 5        Q.   So my question was --

 6             MR. ZIVANOVIC:  It seems it is time for -- okay.  I'll put this

 7     question after the break.  Thank you.

 8             JUDGE DELVOIE:  Yes.  But then perhaps -- the witness may be

 9     escorted out.  There is some procedural matter that we will pursue.

10                           [The witness stands down]

11                           [Trial Chamber and Legal Officer confer]

12             JUDGE DELVOIE:  So we decided that we don't need to come back to

13     the previous issue, and we take the adjournment now.

14                           --- Recess taken at 12.18 p.m.

15                           --- On resuming at 12.45 p.m.

16             JUDGE DELVOIE:  We have been told that there is an issue that we

17     should take care of before the witness comes in.

18             MR. DEMIRDJIAN:  Yes, Your Honours.  It is in relation to the

19     next witness.  We're looking at the time that is left.  I think that

20     counsel for the Defence has about 22 minutes left.  I expect to have

21     perhaps about 20 minutes of re-examination.  So that would take us a

22     little bit past 1.30 roughly.  Considering that the next witness is a

23     protected witness and that he must not see the current witness, we were

24     wondering if it would be more practical to begin the next witness

25     tomorrow.

Page 725

 1             JUDGE DELVOIE:  Yes.  Considering the time it would take to make

 2     sure that they don't cross in the -- in the building.  Do you have a view

 3     on that, Mr. Zivanovic?

 4             MR. ZIVANOVIC:  Your Honour, I just wanted to ask the

 5     Trial Chamber to permit me, for example, 10 or 15 minutes more than I

 6     estimated.

 7             JUDGE DELVOIE:  That now adds to the problem, and I think then,

 8     Mr. Demirdjian, that we will do as you propose, and we will schedule the

 9     next witness for tomorrow morning, 9.00.  So the witness can be released

10     for the day.

11             MR. DEMIRDJIAN:  Thank you, Your Honour.

12             JUDGE DELVOIE:  Thanks.  Can the witness be escorted in,

13     Mr. Savic.

14                           [The witness takes the stand]

15             JUDGE DELVOIE:  Please proceed, Mr. Zivanovic.

16             MR. ZIVANOVIC:  Thank you, Your Honour.

17        Q.   [Interpretation] Mr. Savic, I will repeat the question I put to

18     you before the break.  It concerns paragraph 70 of your statement where

19     you say that following your release from prison and Zagreb, you broke off

20     relations with Hadzic.  You heard he called Ilija Koncarevic on the

21     phone, and, among other things, you asked him why he was around people

22     like Arkan.

23             My question is:  Did you ask him then or before that or when,

24     really?

25        A.   I will answer, but could we briefly go to the previous document

Page 726

 1     before that.  I just wanted to check something.  My name appears in the

 2     document as Borislav Savic, whereas my first name is Borivoje.

 3        Q.   Does it mean that you did not testify on that day or that the

 4     record does not state your name correctly?

 5        A.   I did testify, but this record speaks of the accuracy of this

 6     document.  I'd rather not go into detail about the nature of documents

 7     that appear there, but this very fact is an illustration of how trials

 8     are conducted before the War Crimes Chamber in Belgrade.  If they can't

 9     get the name of the witness correctly, and to have that wrong name

10     through the entire transcript speaks volumes.

11             MR. ZIVANOVIC:  Can we look again at 1D6.  It is first page.

12        Q.   [Interpretation] What is your name as it appears here?

13        A.   I see it on the first page.  Let's move on.

14        Q.   Can we go to the next page, then.  The third page.  On the fourth

15     and fifth pages there are no names.  Can we go to page 6.  Page 7.

16             Thus far, is your name correctly entered?

17        A.   Yes, but we'll get near the end.

18        Q.   Page 8.  Page 9.  Page 10.  Eleven.  Twelve.  Thirteen.

19     Fourteen.  Fifteen.  Sixteen.  "Borislav" appears on page 16.

20        A.   Yes, and on all following pages.

21        Q.   Yes.  There seems to be a mistake, indeed.  In any case, do you

22     assert that what you said then is incorrect since we see the name

23     "Borislav"?

24        A.   No.  No, it's got nothing to do with that.  I told you I was

25     there, although I had not had occasion to read the transcript, but it's

Page 727

 1     just a feeling of how the trial developed and how it was conducted.  As

 2     for the transcript itself, I see it for the first time.

 3        Q.   It is not customary to forward transcripts to witnesses, which is

 4     standard practice before our courts, and I believe elsewhere as well.  In

 5     any case, there is an audio recording, and should there be any doubt as

 6     to the contents, we can always go back to that.

 7             Let us now go back to the question I put to you initially.  In

 8     paragraph 70, you said that you were no longer in any kind of

 9     relationship with Goran Hadzic as of the day of your release from

10     detention in Zagreb or the prison hospital because he called

11     Ilija Koncarevic.  You also said that you asked him why he was around

12     people like Arkan.

13             I'd like to know the following:  Did you ask him that question

14     then, the day you were returning to Slavonia and Vukovar, or at some

15     other time?

16        A.   I will answer.  In the prison hospital, when we had arranged with

17     the minister and his deputy to pick us up to take us home, we put our

18     clothes on and went to the prison warden's office.  I asked him if I

19     could use his phone to call home.

20        Q.   Let me ask you this.  Since I'm limited in terms of time, could

21     you please focus on my question.  I didn't ask you about you phoning.  I

22     wanted to know when you asked Goran Hadzic why he was around people like

23     Arkan.

24        A.   At that moment, he called Koncarevic right after me.  From time

25     to time, depending on who he saw, the best of intentions, because I was

Page 728

 1     neither his tutor nor mentor, but I asked him about Milosevic.  I asked

 2     him about Arkan.  Why do you walk around with Arkan?  What right do you

 3     have?  And he said, He's a good Serb.  He's fighting for the Serb thing.

 4     So these were his general answers.  I did not offer any comment on my

 5     part.  It was up to him.

 6             Let me remind you of one thing.  The area of his activity as the

 7     Vukovar board president was limited.  Once he was out of the area of his

 8     activity, whatever he did was of his own accord and in his own name.

 9        Q.   Let's stop here, Mr. Savic.  So you provided us with an answer.

10     It was on that day when you asked him why he was around people like

11     Arkan.

12             My next question is:  How do you know he socialised with Arkan?

13     Where did you get that information?

14        A.   It was on TV, in the media.  Arkan boasted it about it himself,

15     saying that the president assigned Erdut to him.  The president of what

16     assigned Erdut to him?  Erdut was in Croatia, whereas his activities were

17     in Vojvodina.

18        Q.   So it was based on TV information that you reached that

19     conclusion, then.  That is why you put that question to him.

20        A.   Yes.  All those people got in touch with me first, but I refused

21     them.  I did not want to go hand-in-hand with their activities.

22        Q.   Very well.  You told us -- you said that on the 15th of May, when

23     Vukasin Soskocanin drowned, you were in the Serbian Assembly building.

24        A.   Yes.

25        Q.   You also said in paragraph 159 of your statement, and you repeat

Page 729

 1     that in the Stanisic and Simatovic case - if needed I can provide you

 2     with an exact reference - you said that you talked to Radmilo Bogdanovic.

 3        A.   Yes.

 4        Q.   Tell us, please, what was Radmilo Bogdanovic's position?

 5        A.   I think he was the security board president in the Assembly, or

 6     security committee.

 7        Q.   And you heard from him that a decision had been made that, as you

 8     put it in your statement, Arkan would be assigned to you, and you

 9     objected to it emphatically.  Can you convey that dialogue between you

10     and Bogdanovic briefly?

11        A.   I can.  I went to the Assembly building because I was invited by

12     Pavic and Obradovic.  The Assembly had a session that day.  They usually

13     sat until 5.00 p.m.  The day before that, we were together on the

14     riverbank across from Borovo Selo.  I told him what had happened with

15     Vukasin, and he told him -- he told me to come to the Assembly building

16     once the session was over.  I did so, and at 5.00, in Pavic's office,

17     there was also Radmilo Bogdanovic.  We greeted each other, and I was

18     quite upset and tired after the whole day, and we moved from the office

19     to a meeting room where there were other SPS members.

20             I spoke to Radmilo briefly.  I put forth my proposal on how to

21     resolve the situation, and they agreed to it.  After that, since I spoke

22     quite openly and brusquely, he said, Calm down.  And he said, You will

23     now have Arkan as commander, and you will have Martic as the interior

24     minister.  So it wasn't that someone decided something.  It was not an

25     Assembly decision.  The whole thing had to do with the premises where we

Page 730

 1     discussed it.

 2             Radmilo was supposed to know how things were to develop, and he

 3     conveyed that information to me, and then I asked him to explain what it

 4     meant to send thieves and criminals to us.  And he asked me, Do you think

 5     I will be held accountable for what I'm doing someday?  I told him I was

 6     fully prepared to be called to task five years down the road to be held

 7     accountable for what I did.  And he said, Well, I'll send him

 8     nevertheless.

 9             The next day, Janjackovic came, who I believe was a secretary in

10     the Foreign Ministry, and when the meeting was over with the SUP chiefs

11     from a number of towns along the Danube, he told me that Radmilo had said

12     that we needed to talk so that you have an opportunity to say what you

13     want.  I responded that he should thank Radmilo for keeping his promise,

14     but that in terms of such activities, I was -- I no longer wanted to be

15     involved with that.

16        Q.   Soon after, you met Arkan, did you not?  In the Stanisic and

17     Simatovic case, you said it happened the next day, after you had

18     conversed with Radmilo Bogdanovic in the Assembly.  So that was on the

19     15th of May.  Then what I'm talking about occurred on the 16th; right?

20     The transcript reference is -- actually, it's OTP exhibit 4558.  The page

21     is 1810.

22        A.   Yes.  The meeting materialised.  I was with Brane at the Matica

23     building, and then a man came to pick me up, and right across the way

24     from that building is a cafe, a pub called the Trident.  Apparently it

25     was owned by Arkan and a relative of his was in charge of running the

Page 731

 1     place, but nobody went inside to sit down.  Most of the guests were

 2     sitting outside because there was a garden out there.

 3        Q.   I'm not asking you about the details of that conversation,

 4     because you described that in great detail.

 5        A.   Yes, and I stand by my previous account.

 6        Q.   I'll just read for your benefit 1810, line 10:

 7             "[In English] Q.   How many days after your conversation on the

 8     15th of May with Mr. Bogdanovic did this meeting with Arkan occur?

 9             "A. On the following day."

10             [Interpretation] That's all I want to know.  Is that what you

11     said at the time?

12        A.   Yes, that's what I said.

13        Q.   You said that again the next day on cross-examination, but

14     there's no need for me to go into that.  As far as I've been able to tell

15     based on your conversation with Arkan, you were quite brusque there.  You

16     told him a number of things that people would have found quite difficult

17     to cope with in terms of being told straight to their face.  Do you agree

18     with me?

19        A.   Yes, I agree fully.

20        Q.   So that occurred right after your conversation with Bogdanovic;

21     right?

22        A.   Yes, because I was taken aback by the fact that it happened so

23     quickly and that he got it.  But I never said anything specific against

24     him.  I stated what the situation was and that was that.  It's not like

25     he complained about it.  It was a bit rough maybe, but there was nothing

Page 732

 1     hostile about the tone of that conversation.  You know, that's what I'm

 2     talking about.

 3        Q.   You see, Mr. Savic, we have information suggesting that at the

 4     time you claim you spoke to Radmilo Bogdanovic and when he told you that

 5     Arkan would become commander, and at the time when you allegedly met

 6     Arkan at the Trident, at the time Arkan was not in Belgrade.  He was

 7     away.  He wasn't even there.

 8        A.   I stand by my statement.

 9        Q.   I'll be showing you a document, 1D10.  You see, this is a

10     judgement of the Zagreb District Court on the 14th of June, 1991.  Page 2

11     of the Serbian version shows you that this was a judgement passed.  You

12     see, if you look at page 1, page 1 has three names on it.  And then the

13     next page has the fourth name, the fourth accused.  Zeljko Raznjatovic,

14     aka Arkan.  The remaining pages give us an account of what they stand

15     accused of.

16             At this point in time, we're not really interested in the

17     substance of these charges, but we might go to what I think is page 10.

18     The Serbian reference is -- it's the second-to-last page, I think.

19     Page 5 in the Serbian.  Page 4 in the English.

20             If you look at this -- let me just check if we've got the right

21     page of the English.  It's the next page, please, in e-court.  That's it.

22     Thank you.

23             So what we can see here is that on the 14th of June, 1991, the

24     court sentenced Zeljko Raznjatovic and others to a prison sentence of one

25     year and eight months.  Time spent in detention will be taken into

Page 733

 1     account, starting on the 29th of November to the 14th of June, 1991.

 2     This will become even more obvious based on 1D9.

 3             A letter written by the presiding judge of that particular

 4     Chamber of the Zagreb District Court.  The letter was sent to the Zagreb

 5     District Prison, informing the prison that at the main hearing on the

 6     14th of June, 1991, a ruling was made to terminate custody in relation to

 7     the accused named there, name number four on that list being

 8     Zeljko Raznjatovic.  "A copy of the decision shall be submitted to you

 9     shortly," it reads.

10             Finally, it says:  "This order is to be executed immediately once

11     it is received."  Meaning, on the 14th of June, these men must be

12     released.

13             MR. ZIVANOVIC:  I would ask to tender these two documents, 1D10

14     and 1D9.

15             JUDGE DELVOIE:  Admitted and marked.

16             THE REGISTRAR:  Your Honours, 65 ter document 1D10 shall be

17     assigned Exhibit Number D7.

18             And 65 ter document 1D9 shall be assigned Exhibit Number D8.

19     Thank you.

20             JUDGE DELVOIE:  Thank you.

21             MR. ZIVANOVIC: [Interpretation]

22        Q.   You see, Mr. Savic, I'm looking at these two documents that I've

23     just shown you, and they lead me to conclude that you were not telling

24     the truth about your meeting and communication with Radmilo Bogdanovic on

25     the 15th of May, 1990 [as interpreted], if indeed such a meeting ever

Page 734

 1     materialised.  And particularly, you weren't telling the truth about your

 2     communication with Zeljko Raznjatovic, nicknamed Arkan, which you claimed

 3     occurred at the time that he was in detention.

 4        A.   Yes, and then a government plane was dispatched to Zagreb to get

 5     those men.  What I said about the Assembly, I stand by that.  The

 6     conversation must then be moved in terms of the time line.  Oversights

 7     are possible, of course.  It's a fact, nevertheless, that I was told he

 8     would be the commander, and that's why he was dispatched to Zagreb, to

 9     become a hero, and that's why he was released.  But that's a matter for

10     another time.

11             I did have this conversation with him, and I know that we were

12     commenting on his time in prison in Croatia.  We had both spent time in

13     prison, so, you know, we talked about it.  I was really surprised by how

14     soon he got to know about this.  So that's what the sense of priority was

15     about, and that's why I said it is quite obvious that there was some

16     communication going on behind them.

17             The short time that it took, it couldn't be the next day, if

18     indeed this is the case, but the conversation did take place.  The

19     communication did take place.  So we can change the date, but what reason

20     would I have to come up with a totally fictitious story about something

21     that never happened?

22             I think it's possible to go back to the municipal records, the

23     Assembly records, showing what happened and when exactly, and there must

24     be some information there about the date.  At any rate, I also have

25     witnesses, people who were with me.  The person who drove me there to

Page 735

 1     that meeting and another friend of mine from Odzaci, those men were with

 2     me.

 3             JUDGE DELVOIE:  Mr. Zivanovic, at 64, 15, the transcript says

 4     that the meeting with -- is on the 15th of May, 1990.

 5             MR. ZIVANOVIC:  Yeah, yeah, yeah.

 6             JUDGE DELVOIE:  Is that correct?

 7             MR. ZIVANOVIC:  No, no.  I'll ask the witness.

 8        Q.   [Interpretation] The meeting that you were talking about, it

 9     appears to have been misrecorded.  It was on the 15th of May, 1990, the

10     transcript says.  But are we talking about 1990 or about 1991, the

11     meeting at the Serbian Assembly, the day Soskocanin came to grief?

12        A.   1991.  We're talking about 1991.

13             MR. ZIVANOVIC:  Thank you, Your Honour.

14        Q.   [Interpretation] Mr. Savic, you gave your first statement, and

15     you said this in very categorical terms.  That was back in 2002.  You

16     reiterated this in your evidence in the Stanisic and Simatovic trial

17     under oath twice, as a matter of fact.  You gave the same statement to

18     the OTP, which is the one that has now been tendered and admitted,

19     claiming that it is a truthful statement.  And then again you took an

20     oath when you came here, and you are now telling us that we can shift the

21     dates a little bit.  Nonetheless, that would be very difficult to

22     exercise, if not actually impossible, wouldn't it, based on this?  I'm

23     not trying to challenge the possibility that you were at the

24     Serbian Assembly, but I do challenge the theory that you discussed Arkan

25     there, and I particularly challenge the theory that you met up with Arkan

Page 736

 1     and spoke to him the way you have just described.

 2        A.   The Assembly is true.  The conversation is true.  I may have been

 3     wrong about the date the conversation took place, but the conversation

 4     itself did materialise.  That is true.  This is nothing that is

 5     fabricated.  There is no ill intention behind it, and I certainly added

 6     nothing to the substance of what actually transpired.

 7        Q.   But you associate this conversation with a very peculiar event,

 8     the drowning, or as you suggest, the killing of Soskocanin, which you

 9     suggest -- or who you suggest was a close friend of yours.  So

10     establishing a link between these two facts, I can see that you needed a

11     date, a specific date to get your bearings on that.  On the other hand,

12     you tell us you were surprised by how soon Arkan had found out about the

13     substance of your conversation with Radmilo Bogdanovic.  So a month after

14     you talked to Radmilo Bogdanovic, Arkan was in fact in gaol.  So how soon

15     could this have possibly been, unless obviously Radmilo Bogdanovic talked

16     to him the very first day he got out of gaol to tell him what he had been

17     speaking to you about?

18        A.   Arkan was flown on a government plane from Zagreb.  I expect that

19     he was welcomed in an appropriate way once he got there.  So let us not

20     speculate.

21             I talked to him in the way I described.  The date was obviously a

22     different one from the one that I had asserted.

23             MR. ZIVANOVIC: [Interpretation] Thank you very much, Mr. Savic.

24     I have no more questions for you.

25             JUDGE DELVOIE:  Thank you.  Redirect.

Page 737

 1             MR. DEMIRDJIAN:  Yes, Your Honours.

 2                           Re-examination by Mr. Demirdjian:

 3        Q.   Good afternoon, Mr. Savic.

 4        A.   Good afternoon.

 5        Q.   Let me start with a few questions that were put to you by my

 6     learned friend yesterday, and for everyone in the courtroom, this was at

 7     page 620.  It was put to you that there are 74 references to

 8     Slobodan Milosevic in your statement and that you had never met with him.

 9             MR. DEMIRDJIAN:  Could we pull up the witness's statement which

10     is admitted as P50, and in both versions could we go to page 5, please.

11     Thank you.  If we could scroll down to the bottom of paragraph 13.  Yes.

12     And the same in the B/C/S version.

13        Q.   At the end of paragraph 13, Mr. Savic, do you see where you

14     say -- well, you describe this exchange that Professor Raskovic had with

15     Slobodan Milosevic.  Do you see that part of the -- it's at the end of

16     the paragraph.  Do you see that?

17        A.   Yes.

18        Q.   And what was your source for this information?

19        A.   After appearing in Zagreb and in Croatia, professor would often

20     go back to Belgrade, and that would often mean meeting Milosevic, who was

21     then president.  And then we'd always talk whenever he was back, what

22     direction their reasoning and their thoughts were taking.  So it was

23     directly through talking to Professor Raskovic.  And then we'd talk and

24     I'd tell him to ask this question or that question when he was there but

25     there was no need for me to go telling him, because his information was

Page 738

 1     much more reliable and more extensive than mine.  But your question about

 2     the source, the answer is directly from talking to him.

 3        Q.   Can we go to page 11 in both versions, please, and I would like

 4     to direct your attention to paragraph 35.  And here you discuss the issue

 5     of the offer that was made by Tudjman to Professor Raskovic, and again

 6     here you explain what Raskovic told you about a conversation he had with

 7     Slobodan Milosevic.  And again I'd like to ask you, very simply, what was

 8     the source of your information there?

 9        A.   I told you about the situation and the position of the Serbs

10     before and after the election.  Professor Raskovic appeared as someone

11     who was able to allay the tensions and give people hope.  He was very

12     much in the public eye at the time.  He would appear on TV quite often.

13     His visit to President Tudjman was shown on TV, and he congratulated

14     Tudjman on his electoral victory.  President Tudjman then told him, By

15     tradition, you, the Serbs, should have the vice-president of the

16     parliament.  That was published in the press and in the public media at

17     the time, and it was confirmed to me by Professor Raskovic himself.

18     Nevertheless, when I asked him, Why did you not accept, and he said

19     Milosevic did not agree.  And then instead of Professor Raskovic, they

20     decided to appoint Jovo Opacic but then Tudjman turned him down.  The

21     parliament was constituted and everything just went on in a totally

22     different direction and they didn't talk about this anymore.

23     Nevertheless, there was a real offer on the table, and even the media

24     recorded the fact.

25        Q.   I'm not going to go through each of the 74 examples.  Let's take

Page 739

 1     one last example at page 22, please, in both versions.  And I would like

 2     to direct your attention to paragraph 79.  And here you describe the

 3     position that was held by Hadzic vis-a-vis Mr. Milosevic.  Now, this

 4     information you provide in your statement here about Milosevic, who gave

 5     you that information?

 6        A.   I heard that from Ilija Koncarevic.  Before the Serbian National

 7     Council was established, he came to see me at my home and he said,

 8     Tomorrow we'll be going -- the next day we'll be going to Belgrade to see

 9     the president.  Which route shall we take?  We'll pick up Jugoslav Kostic

10     on the way there and then we'll go to Belgrade to set up the

11     National Council.

12             So it was a real offer that was made.  I said I'd have no part in

13     that, that I wouldn't be involved, and that I wouldn't be going.  That

14     was the first time.

15        Q.   Very well.  Mr. Savic, I was pointing to paragraph 79, and

16     specifically the question -- the sentence where it says:

17             "Goran would also tell me how good Milosevic was and that

18     Milosevic was not interested in power," et cetera, et cetera.

19             Where did you get that information?

20        A.   I asked him during one of the rides when we were together.  One

21     had to travel ten hours to get to Knin.  It all added up.  I asked him,

22     Please explain your relationship with Milosevic to me.  He said, He's a

23     good man, and it was something along the lines as noted in the statement.

24     However, my question was not in terms of making a suggestion.  I had the

25     best intention in mind, and he just provided information.  In any case,

Page 740

 1     he's aware of it.

 2        Q.   Very well.  I'll move away from this topic.  Yesterday, at

 3     page 631 and 632, my learned friend put to you questions about the

 4     concept of Ustasha.  And when you were asked about it, I believe that you

 5     were interrupted and you were in the midst of saying that this is a

 6     concept that was abused, and could you please expand on that now, because

 7     the question to you was about the use of the word "Ustasha" in

 8     World War II, and please, could you expand on that now.

 9        A.   The concept of the Ustasha movement needs not be explained any

10     further as a movement, but you're interested in the term, I understand.

11        Q.   I'm interested at the moment where you were interrupted.  You

12     were talking about the fact that the concept was being abused, and this

13     was when you were talking about the conflict in 1990, 1991.

14        A.   Well, yes.  It was used to irritate, to create negative energy,

15     negative feelings.  On one side it could have a positive effect, while on

16     the other it had a negative effect.  It a means to manipulate people.

17        Q.   And could you tell us what was the consequence of the use of the

18     term "Ustasha"?  What impact did it have at the time?

19        A.   Among Serbs, it reminded them of the crimes of the Ustasha in

20     Second World War, and one you had -- one had this constant reiteration of

21     the locations of people being killed and all the crimes committed during

22     the time of the Independent State of Croatia back then.  It was justified

23     in a way because it evoked certain memories.  There were people who had

24     lost their entire families and only individuals survived by chance.  Such

25     Ustasha crimes happened during the Second World War.

Page 741

 1             When I used the term that it was abused, I had in mind that there

 2     was no necessity to increase fear and anxiety even further in such

 3     turbulent times.  That's why I said that it was abused.

 4        Q.   Moving on to another topic, you told the Court at page 649 that

 5     at one point government members told you that you were banned from

 6     communicating with them, and you heard this from Bogdan Vorkapic, and you

 7     also mentioned the name of Milos Vojnovic.  Did any of them tell you who

 8     did not allow you -- or did not allow them to speak to you?

 9        A.   The sequence of events was quite logical.  The first offers to

10     create the National Council and get engaged in such activities was made

11     to me during the initial months, but I refused.  I also didn't want to

12     burden anyone or raise tensions by opening up unnecessary topics.  And

13     then things took a different direction, and other people became involved,

14     and all the events surrounding the establishment of government and the

15     National Council was the result of fabrications.  There was never an act

16     of establishment or anything.

17             JUDGE DELVOIE:  Mr. Savic, I think we would all be assisted, and

18     you as well, if you would listen carefully to the question.

19             THE WITNESS:  Sorry.

20             JUDGE DELVOIE:  The question is who told you?  Did anyone of

21     those people who were banned to communicate with you, did anyone of these

22     people tell you so?  So that's the question.

23             THE WITNESS: [Interpretation] Thank you.  The people are

24     mentioned, Bogdan Vorkapic.  So there are people by name who said that.

25             JUDGE DELVOIE:  Now --

Page 742

 1             MR. DEMIRDJIAN:  In this specific --

 2             JUDGE DELVOIE:  Sorry.  Now, I wandered a little bit off.  It's

 3     not who told you, but the question was:  Did they tell you who ordered

 4     them not to communicate with you?

 5             That was your question, wasn't it?

 6             MR. DEMIRDJIAN:  That was the question.  Thank you, Your Honours.

 7             THE WITNESS: [Interpretation] Who established it.  I didn't ask.

 8     I didn't insist to know.  Well, banned, so what?  But who established the

 9     government?  That's what you can't see anywhere.  That's what it's about.

10     I don't think it was done by our people who were made part of the

11     government.  Those who established it should say.  Someone had to

12     establish it.

13             MR. DEMIRDJIAN:

14        Q.   They didn't tell you the name of the person or the institution.

15        A.   No.  No.

16        Q.   You were asked several questions about your concerns about being

17     liquidated at the time, and you repeated on a few occasions that you

18     don't suffer from paranoia.  Let me ask you, Mr. Savic, when was

19     Vukasin Soskocanin killed?

20        A.   On the 15th of May, 1991.

21        Q.   And you mentioned in your statement at paragraphs 137 to 139 the

22     killing of Josip Reihl-Kir and you explained that he was the chief of

23     police in Osijek.  Do you remember that?

24        A.   Josip Reihl-Kir.  He was the chief of police in Osijek.  He was

25     an exceptionally brave man, full of energy, and he worked in an

Page 743

 1     exceedingly dangerous environment when people like Seks and Glavas were

 2     in power.  Seks even publicly called on the population not to turn to the

 3     police any longer but to the HDZ.

 4             He participated in all peace meetings and attempts in the area.

 5     He even came to Borovo Selo, which was part of the Vukovar municipality.

 6     It was a neighbouring municipality.  Dalj and Bijelo Brdo were in the

 7     Osijek municipality, whereas he came to Borovo Selo as well.

 8        Q.   And his killing, I believe you mentioned in your statement was --

 9     let me see if you mentioned a date here.  Can we go to the next page,

10     paragraph 139.  I don't believe it said.  Do you recall when he was

11     killed?

12        A.   I can't recall the date, but I founded the association of victims

13     of the Croatian regime in 1991 in Krajina.  All those who were victims

14     became members, and one of the members was Mirko Tubic, who was the

15     president of the local commune in Tenja who survived it.  He put forth

16     all the details surrounding that.

17        Q.   Yes.  I believe we have documents which will support this at a

18     later stage, but would it be roughly correct to say that he was killed

19     around June or July of 1991?

20        A.   June or July, yes.  I don't know a precise date, but around that

21     time.  I even think it was in July.

22        Q.   And was this the same time period that you had concerned for --

23     that you had concerns about your own safety?

24        A.   Well, fighting political opponents in our part of the world may

25     well mean having them liquidated.  It's not a secret.  In any case,

Page 744

 1     someone who doesn't go hand-in-hand with the ideas of those in power is

 2     in the sphere of danger, and one better watch his back at such times.

 3        Q.   Let me finish off with the questions that were put to you about

 4     Lovas.  You were shown --

 5             MR. DEMIRDJIAN:  First of all, can we pull up Exhibit P79.50.

 6        Q.   These are -- this is the agenda or the minutes that you typed up.

 7     And you were asked about the positions of the various individuals listed

 8     here.

 9             Now, just to be clear, this is the retyped format of notes you

10     had taken; is that right.

11        A.   Yes.

12        Q.   When did you take the notes, the original ones?

13        A.   Yes, yes.

14        Q.   Sorry.  When did you take the original notes?

15        A.   During that meeting.

16        Q.   You were asked about Stevo Bogic, and it says here "Deputy Prime

17     Minister and State Security Chief."  Can you tell the Court based on what

18     information you wrote that?

19        A.   I took the notes on the spot.  The chief of the state service was

20     there, but there was also a lower-level official, I believe.  But they

21     all said he was the vice-president of something or other.  I'd be hard

22     put to say.  Municipal vice-president, or candidate for municipal

23     vice-president in Vukovar.

24        Q.   Now, another set of notes were shown to you.  This is Exhibit D6.

25     We can pull that up too.  And before we look at the document -- well,

Page 745

 1     let's pull it up in the meantime.

 2             Mr. Savic, did you ever present yourself as Borivoje Savic from

 3     Lovas?

 4        A.   No.  I never presented myself like that, but I was, as a matter

 5     of fact, in Lovas at the time, so I may have recorded "Lovas."  But Lovas

 6     was not a part of my personal information.

 7             MR. DEMIRDJIAN:  Yes.  Can we go to the page before last in both

 8     versions.  In English it's one page before that.  Yes.  Can we scroll

 9     down a bit.  Thank you.

10        Q.   Now, under number 12 you see "Borislav Bogunovic"; is that right?

11        A.   Yes.

12        Q.   Now, which town is written next to his name?

13        A.   Negoslavci.

14        Q.   Now, this is the 30th of October, 1991.  Do you happen to know

15     where Mr. Bogunovic was in October 1991?  Was he in Negoslavci?

16        A.   No.  He was in Sid.

17        Q.   Very well.  I cannot see your name on this.  It's probably on the

18     next page in the English version.

19        A.   It's on the next page, yes.

20             MR. DEMIRDJIAN:  So in the English it's one more page.  Yes.  The

21     next page in English.  Very well.

22        Q.   Now, you told the Court that this was not your handwriting; is

23     that right?

24        A.   No, not the word "Lovas," and not the part where it says

25     "TO member."  Those two bits were added.  If you can actually zoom in,

Page 746

 1     you can compare the letters that I wrote.

 2        Q.   Very well.  We can put this document away now.  And in relation

 3     to Lovas, Mr. Savic, you were asked about -- you were shown excerpts from

 4     your testimony, and you were asked when you heard from General Nenezic

 5     that the army, and these are the words used in the document, that the

 6     army had screwed up in Lovas?  Do you remember that?

 7        A.   It's difficult to say the date when all these people were coming

 8     and going and all of this was going on.  The report from the field would

 9     be submitted to the KOS in Belgrade, and all those who were in charge of

10     that were in a position to find out.  I'm not sure which term to use, but

11     it was after this happened.

12        Q.   And at the time, you're telling us that General Nenezic was a

13     retired general from the KOS; is that right?

14        A.   Yes, that's right.

15             MR. DEMIRDJIAN:  Just for the sake of completeness, can we pull

16     up 65 ter 1D00006.  In the B/C/S version we can go to page 18, and in the

17     English version we can go to page 23.

18        Q.   Now, this excerpt was shown to you by my learned friend, and at

19     least in the English version, somewhere in the middle of the page you

20     were asked when did you hear that the army had screwed up?  And is that

21     your answer there:  "Sometime before my arrival in Lovas"?  Is that

22     right?

23        A.   Yes.

24        Q.   Now, General Nenezic was a retired general.  How would he have

25     access to this information?

Page 747

 1        A.   The KOS never dies.  When people retire, they still have their

 2     communication channels.  They still have sources.  It's just for

 3     curiosity's sake.  People still continue to talk to each other on a daily

 4     basis.  You know, they just talk.

 5             MR. DEMIRDJIAN:  Thank you, Mr. Savic.  These are all the

 6     questions that I have.

 7             JUDGE DELVOIE:  Thank you.  Mr. Savic, this brings your testimony

 8     to an end.  We thank you for coming to The Hague to assist the Tribunal,

 9     and we wish you a safe journey home.  The usher will now escort you out

10     of court.  Thank you.

11             THE WITNESS: [Interpretation] Thank you.

12                           [The witness withdrew]

13             JUDGE DELVOIE:  Mr. Stringer.

14             MR. STRINGER:  Thank you, Mr. President.  If I could just raise a

15     small procedural matter for tomorrow's witness it might make things go

16     more smoothly tomorrow.

17             There are currently three exhibits that the Prosecution would

18     like to use with the next witness.  They are 65 ter 6331, 6334, and

19     6338.1, and those are all exhibits that were included in the most recent

20     Prosecution motion to add things to its 65 ter list, the fourth 65 ter

21     motion, and in the motion the Prosecution had indicated that it wished to

22     use those exhibits with -- with tomorrow's witness.  There's a fourth

23     exhibit which is 65 ter 6237, which the Chamber does not have.  We've

24     been in communication with the Defence about it.  It is one of the

25     Google Map satellite images that actually has been accepted, but what we

Page 748

 1     found was we wanted to sort of zoom out just a little bit to include a

 2     wider area on that image, and it was -- we've asked the Defence,

 3     actually, a couple times whether they would agree to our substituting

 4     this -- this one for the previous one that is a bit more narrow, and so

 5     we're not asking for any rulings.  It would be nice to know what the

 6     Defence position is in respect of these four exhibits before we start

 7     with the witness tomorrow.

 8             JUDGE DELVOIE:  Mr. Zivanovic, could I ask you about the last

 9     one.  That seems to be an easy answer.

10             MR. GOSNELL:  Your Honours, there are no objections to any of the

11     four documents.

12             JUDGE DELVOIE:  No objections to any of them.  Thank you very

13     much.

14             So we reconvene tomorrow at 9.00 in this courtroom.  Court

15     adjourned.

16                           --- Whereupon the hearing adjourned at 1.54 p.m.,

17                           to be reconvened on Thursday, the 1st day

18                           of November, 2012, at 9.00 a.m.