Tribunal Criminal Tribunal for the Former Yugoslavia

Page 9128

 1                           Tuesday, 8 April 2014

 2                           [Open session]

 3                           [The accused entered court]

 4                           --- Upon commencing at 10.02 a.m.

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

 6     courtroom.  Good to see all of you apparently in good health.

 7             Good morning, Mr. Lukic.

 8             Madam Registrar, could you call the case.  Please.

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

10     IT-04-75-T, the Prosecutor versus Goran Hadzic.

11             JUDGE DELVOIE:  Thank you.

12             Can we have the appearances, please, starting with the

13     Prosecution.

14             MR. STRINGER:  Good morning, Mr. President, Your Honours.  For

15     the Prosecution Douglas Stringer, Lisa Biersay, Case Manager

16     Thomas Laugel, and interns Nicolas Hoban and Marija Knezevic.

17             JUDGE DELVOIE:  Thank you.

18             For the Defence.

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

20     Goran Hadzic, Zoran Zivanovic and Christopher Gosnell with legal intern

21     Paul Stokes.

22             JUDGE DELVOIE:  Thank you very much.

23             MR. LUKIC:  Good morning, Your Honours.  Branko Lukic on behalf

24     of the witness who should testify today.  I don't know if he's protected

25     or not.


Page 9129

 1             JUDGE DELVOIE:  Thank you very much.  He is not protected.

 2             MR. LUKIC:  So on behalf of Mr. Borislav Bogunovic.

 3             JUDGE DELVOIE:  Thank you.

 4             First of all, one administrative matter.  Due to the late start

 5     we will take one break at 11.45, a 30-minute break.  And then there are

 6     two very short oral rulings.

 7             First one.  On 21st of March, 2014, the Prosecution filed its

 8     15th motion for leave to amend its Rule 65 ter exhibit list.  On

 9     31 March 2014, the Defence filed a response in which it opposed the

10     motion.  On the 1st of April, 2014, the Prosecution filed a request for

11     leave to reply and a reply in which it withdrew the motion.  The Chamber

12     hereby grants the request for leave to reply and notes the withdrawal of

13     the motion.

14             Second one is as follows.  The Trial Chamber is seized of the

15     Prosecution motion for the substitution of Rule 65 ter admitted

16     Exhibits P1964 and P3038, filed on 14 March.  The Defence did not

17     respond.  The motion is hereby granted.  The registry will take necessary

18     measures to implement this decision by the 22nd of April, 2014, and

19     update the Chamber and parties of its implementation.

20             Could the witness be brought in, please.

21                           [The witness entered court]

22             JUDGE DELVOIE:  Good morning, Mr. Bogunovic.  Thank you for

23     coming to The Hague.  Could I please ask you to state your name and date

24     of birth for the record.

25             And I first should ask you, do you hear me in a language you


Page 9130

 1     understand?

 2             THE WITNESS: [Interpretation] Yes.

 3             JUDGE DELVOIE:  Thank you.  Your name and date of birth, please.

 4             THE WITNESS: [Interpretation] Borislav Bogunovic, born on the

 5     25th of March, 1950.

 6             JUDGE DELVOIE:  Thank you.

 7             Mr. Bogunovic, you are to make the solemn declaration by which

 8     witnesses commit themselves to tell the truth.  I must point out to you

 9     that by doing so you expose yourself to the penalties of perjury should

10     you give false or untruthful information.

11             Can I now ask you to make the solemn declaration the usher will

12     give to you.

13             THE WITNESS: [Interpretation] I solemnly declare that I will

14     speak the truth, the whole truth, and nothing but the truth.

15                           WITNESS:  BORISLAV BOGUNOVIC

16                           [Witness answered through interpreter]

17             JUDGE DELVOIE:  Thank you very much.  You may be seated.

18             THE WITNESS: [Interpretation] Thank you.

19             Ms. Biersay, your witness.

20             MS. BIERSAY:  Thank you, Your Honour.

21                           Examination by Lisa Biersay:

22        Q.   Good morning, Mr. Bogunovic.

23        A.   Good morning.

24        Q.   Are you comfortably seated where you are?

25        A.   Yes.

Page 9131

 1        Q.   Could I ask you just to move a little bit closer to the

 2     microphone, please, if you can.

 3        A.   [In English] Okay.

 4        Q.   And are you able to see the screen in front of you?

 5        A.   [Interpretation] Yes.

 6        Q.   And I see you're reaching for your glasses; is that right?

 7        A.   Yes.

 8        Q.   Before we start looking at any documents, Mr. Bogunovic, could

 9     you describe what positions you held in the SAO SBWS government in 1991?

10        A.   In 1991, I was minister of the interior, from 1991, and then I

11     was deputy prime minister in 1992.  And later on, I was vice speaker of

12     the Assembly of the Serbian Krajina.

13        Q.   Is it true that you provided several statements to

14     representatives of the OTP, the Office of the Prosecutor?

15        A.   Yes.

16        Q.   You've also provided statements in local proceedings as well in

17     Belgrade; is that correct?

18        A.   Yes.

19        Q.   I'd like to direct your attention to 2012.  Did you provide a

20     statement to the representatives of the OTP in September of 2012?

21        A.   Yes.

22        Q.   Were you able to review that statement?

23        A.   Yes.

24        Q.   In what language did you review it?

25        A.   In Serbian.

Page 9132

 1        Q.   You signed that statement in September 2012; is that correct?

 2        A.   Yes.

 3        Q.   And you reviewed it again in 2013, September 2013; is that

 4     correct?

 5        A.   It is.

 6        Q.   And again, you reviewed that statement in March of this year; is

 7     that right?

 8        A.   Right.

 9             MS. BIERSAY:  If I could now turn to tab 15, if I may ask the

10     registry to display 65 ter number 5962.  And may I have some assistance

11     in giving Mr. Bogunovic a hard copy of this document.  I've already

12     conferred with the Defence.  Thank you.

13        Q.   Now, Mr. Bogunovic, you have a hard copy of it and we are trying

14     to find an electronic version so that it will come up on the screen, but

15     it thought it would be helpful for you to have it in your hands as well.

16     Now, I don't know which is better for you to see, the screen or the hard

17     copy that's in front of you.  Do you have a preference?

18        A.   Hard copy.

19        Q.   Now directing your attention to the hard copy in front of you on

20     the first page, do you recognise this?

21        A.   Yes.  This is a document that I signed.  It contains my details,

22     my name, surname, date and place of birth, and everything else.

23        Q.   Now you said that you recognised your name -- you recognised your

24     signature on that page?

25        A.   That's right.

Page 9133

 1        Q.   And is this the September 2012 statement that you signed?

 2        A.   Yes, yes.

 3             MS. BIERSAY:  If we could simply go to the next page.

 4        Q.   And just directing -- I won't go through all the pages, but

 5     directing your attention to the bottom of that page, do you recognise

 6     anything?

 7        A.   Do you mean the bottom of the first page?

 8        Q.   Of -- the page that you're looking at now, do you see your

 9     initials on that page?

10        A.   Yes.

11        Q.   Now, upon your review, the two times, of this document, you had

12     some corrections that you wanted to be made; is that correct?

13        A.   Yes, yes.

14        Q.   Let me direct your attention to paragraph 5, which is on the page

15     you're looking at, page 2, at the very bottom.  Do you see it?

16        A.   Yes.

17        Q.   Now, in that paragraph it describes that you had been convicted

18     to 32 years of imprisonment for murder.  Has that number changed?

19        A.   Yes.  Now, at this moment, the sentence is 20 years of

20     imprisonment.

21        Q.   And now I'd like to direct your attention to paragraph 16, which

22     is page 4 of the document that you're holding.  And specifically, it

23     reads:

24             "After 2 May, the SNC held two or three meetings on the subject

25     at Ljubija Novakovic's home in Baca Palanka."

Page 9134

 1             Is the word "home" correct?

 2        A.   No, no.  We did that at the office, the office where

 3     Ljubo Novakovic worked.

 4        Q.   Now directing your attention to, I think it will be page 18 for

 5     the hard copy that you're holding, Mr. Bogunovic, if you could go to

 6     paragraph 89.  So it's on page 18.

 7        A.   Yes.

 8        Q.   Could you look at the bottom of the page that you're looking at

 9     and tell me what page number it has written?

10        A.   I have 18.

11        Q.   Now if I could direct your attention to that last sentence right

12     before paragraph 90.  And it says:

13             "We received the same blue uniforms and equipment that the MUP

14     police of Serbia wore, trousers, jackets, short-barrelled weapons, which

15     were red Zastava pistols calibre 65."

16             Is the number of the calibre correct?  Sir, right above

17     paragraph 90, the last sentence.

18        A.   Yes, all of this is correct except for the calibre.  It should be

19     7.65.

20        Q.   And now if you could go to page 27, specifically paragraph 143

21     once you get there.  Are you on page 27?

22        A.   Yes.

23        Q.   And paragraph 143.  If you could look five lines down you'll see

24     the word "vojsku," and my question to you is whether or not that's the

25     correct word.

Page 9135

 1        A.   Well, it should rather say "the Ministry of Justice," to my mind,

 2     instead of "vojska," "the army."  So the Ministry of Justice along with

 3     the Ministry of the Interior, the police that had been established at the

 4     time and that could try the persons who were supposed to be tried.

 5        Q.   Let me --

 6        A.   That is to say the word "vojska," "army," should not be here.

 7        Q.   And if I could read the English, that sentence reads:

 8             "That is what Susa was referring to when he said we had the

 9     police and we had judiciary ..."

10             Is that consistent with the correction that you just made?

11        A.   Yes, yes.

12        Q.   Now, Mr. Bogunovic, with the corrections you just made, is the

13     information contained in your statement, is that information accurate and

14     truthful?

15        A.   Yes.

16        Q.   If you were asked the same questions today about the information

17     you provided in that statement, would your answers - in substance - be

18     the same?

19        A.   Yes.

20             MS. BIERSAY:  At this time the Prosecution would move for the

21     admission of the statement, which is 65 ter number 5962.

22             JUDGE DELVOIE:  Admitted and marked.

23             THE REGISTRAR:  Exhibit P3204.

24             JUDGE DELVOIE:  Thank you.

25             MS. BIERSAY:  And, Your Honours, at this time that would conclude


Page 9136

 1     my direct.

 2             JUDGE DELVOIE:  Thank you.

 3             Mr. Zivanovic.

 4             MR. ZIVANOVIC:  Thank you, Your Honours.

 5                           Cross-examination by Mr. Zivanovic:

 6        Q.   [Interpretation] Mr. Bogunovic, although we have met on two

 7     occasions already, for the transcript I have to introduce myself to you.

 8     My name is Zoran Zivanovic and I am Defence counsel for Goran Hadzic in

 9     these proceedings.

10             First of all, I would like you to clarify a few of the answers

11     that you gave to the Prosecutor now and that are contained in the

12     transcript.  First of all, can you tell me when were you minister of the

13     interior and until when, in the government of Slavonia, Baranja, and

14     Western Srem, in which period?

15        A.   In the period of the establishment of our ministry, our

16     government, that was sometime in August until the end of 1991.

17        Q.   And in which period were you the deputy prime minister?

18        A.   I was deputy prime minister when I was replaced as minister of

19     the interior, when I was transferred to the position of deputy

20     prime minister.

21        Q.   Can you remember which period this was when you were deputy

22     prime minister?

23        A.   Deputy prime minister?  I think I started carrying out those

24     duties in 1991, as far as I can remember.

25        Q.   Until when?

Page 9137

 1        A.   Well, I don't know.  Say until 1992, I don't know what month.

 2     Towards the end of 1992.  I don't know exactly.

 3        Q.   And in which period were you the vice-president of the Assembly

 4     of the Republic of the Serb Krajina?

 5        A.   I held that position from the establishment of -- actually from

 6     the first multiparty elections in the Krajina.

 7        Q.   Do you remember when these multiparty elections were held?

 8        A.   Well, now was it 1993 or 1994?  Sometime around then.

 9        Q.   You said to the Prosecutor today that you reviewed the statement

10     before you in 2012 and then 2013 and now in March 2014.

11        A.   Yes.

12        Q.   My question is whether you read it carefully?

13        A.   Well, you see, I read it.  I tried to read it as it was written,

14     but I think that I did read it properly, but it's possible that -- well,

15     I don't know.  As far as I could see all of this, perhaps I omitted a

16     sentence or two, but I don't know whether there is anything meaningful.

17        Q.   Can you tell us roughly how much time you devoted to reading this

18     statement?

19        A.   Well, about two or two and a half hours.

20        Q.   Did you come across any inconsistencies in this statement,

21     anything that was contradictory?

22        A.   Well, I could not exactly about everything.  It would have taken

23     a lot longer if I went from one part to another and looked at each and

24     every sentence, trying to see what each and every sentence meant.  I

25     didn't have all that time, and to tell you the truth, I didn't really pay

Page 9138

 1     attention to each and every word.  But on the whole, I think that the

 2     essence is there.  Now, whether there is something --

 3        Q.   Well, all right.  But when you say that you didn't have enough

 4     time, did you have other commitments at the time or, quite simply, were

 5     you not concentrated?  Were you preoccupied with other things?

 6        A.   Well, to tell you the truth, I have a big problem that I've been

 7     dealing with over the past three years, and it creates major problems for

 8     me, and I read something and a few minutes later I forget that.  It's not

 9     intentional or anything like that.  Quite simply, this case of mine, this

10     thing that I'm dealing with, it brings me to that.  I read something and

11     then I'm thinking of something else.  So I cannot tell you exactly now

12     whether somewhere -- well, perhaps there are some things that are not

13     correct.  It wouldn't be anything big, but there is that possibility.

14        Q.   In response to the Prosecutor's question here, you said that you

15     were convicted to 20 years in prison.  Could you just clarify this for

16     us?  Does it have anything to do with something that happened during the

17     war or not?

18        A.   Well, this is the way it was.  The only thing that has to do with

19     the war and things like that is that is I am not as calm as I used to be.

20     I felt that the war has taken its toll, and at certain moments I'm more

21     irritable than I was before.  I used to be reticent before, but now I see

22     that I get upset very easily.  It's a lot easier for me to change my

23     mood, and this affects my psyche and me personally.

24        Q.   I understand, but my question is:  The event on account of which

25     you were convicted, is it something that happened during the war or

Page 9139

 1     afterwards?

 2        A.   Afterwards.

 3        Q.   Mr. Bogunovic, in your statement you said -- well, it's contained

 4     in one chapter.  You spoke about the establishment of the SDS and the

 5     work of the SDS, especially in Vukovar.  Since you were a member of that

 6     party and you held high office in that party, first of all, I'd like to

 7     ask you why you actually became a member of that party in the first

 8     place?

 9        A.   Well, I joined that party because, before that, the HDZ party had

10     been established and it had been in power for some seven or eight months,

11     and in the elections they had won power together with the SDP.  I never

12     thought of going into politics, but at certain moments I was bothered by

13     this, especially at work when people were saying, "Ah, if you were not a

14     Serb, you would have really made it in life," and so on and so forth.

15     And then it was even more insulting when they would say, "Well, let's not

16     take him along.  We cannot speak openly, he's a Serb," and so on.  So

17     this is something that I could not understand at first.  I wondered why,

18     because until then I was on good terms with all of these people.  We

19     socialised.  We were friends.  We even went to one another's home.  At

20     our patron saint's day, there were always 70 per cent Croats and

21     30 per cent Serbs present.

22             So I asked myself:  Now, what is this that is happening now?  So,

23     I mean, at one moment, as everything was the way it was, I said, well, a

24     Croatian party had been established and we're going to create a Serb

25     party, and that's how I joined in the establishment of this party or,

Page 9140

 1     rather, the beginning of the establishment of the Serb Democratic Party.

 2        Q.   When you say the beginning of the establishment of the

 3     Serb Democratic Party, are you talking about this committee in Vukovar or

 4     the party in general?

 5        A.   Well, the party in general, especially in Vukovar.  The party was

 6     established, Jovan Raskovic was the founder of that party.  I was not

 7     present when he founded the party, but I was in Vukovar, at Adica, where

 8     there were 8- or 9.000 persons present, and Jovan Raskovic was present

 9     too.  And then this rally that was held there and people were selected

10     there who would represent the SDS in the future.

11        Q.   You certainly know - and I will tell you that we have information

12     here - about this referendum that was held by the Serb people in Croatia,

13     in terms of whether they would stay in Yugoslavia or whether they would

14     accept Croatia's separation from Yugoslavia.  Do you remember that

15     referendum?

16        A.   Yes, I do.

17        Q.   And what was the result of this referendum?

18        A.   Well, the referendum in the Serb villages, or, rather, where

19     there were more Serbs living, it was almost 100 per cent.  This was done

20     and it was done for the purpose of seeing how the people felt, and they

21     all wanted Yugoslavia, as it had existed until then, to continue.

22        Q.   When you say that they all wanted Yugoslavia to continue, you're

23     referring to the Serb population?

24        A.   The Serb population.

25        Q.   Was that the position of the Serb Democratic Party as well?

Page 9141

 1        A.   Yes.  We had a meeting before that and this was adopted

 2     unanimously; namely, that our wish was to remain in Yugoslavia or,

 3     rather, that Yugoslavia should remain as it was.

 4        Q.   Tell me, please, we have some information also about the

 5     organisation of village guards in Serb villages at the time.  Can you

 6     tell us what kind of guards these were and why they were organised in the

 7     first place?

 8        A.   Yes.  At that time there were village guards along the main roads

 9     along which people passed.  By then, what was noticeable was that armed

10     people were passing by and that weapons were being transported in

11     automobiles.  At the time we did not have any guards at all.  However, at

12     the meeting a decision was taken that we should have our guards there,

13     too, as the Croats already did have, and that there should be

14     check-points at entrances and exits into towns and villages.

15        Q.   The guards were organised by the inhabitants of particular

16     villages; right?

17        A.   Yes, every village held meetings and they elected their

18     Crisis Staff, and the Crisis Staff was in charge.  They decided who would

19     go on guard duty, who would procure the goods that were needed, so there

20     were people who appointed these guards.

21        Q.   You lived in Negoslavci?

22        A.   Yes.

23        Q.   According to the information I have, you were elected at a rally

24     of the citizens of Negoslavci as this commander of whatever it was, the

25     Crisis Staff, the Territorial Defence, whatever it was called, I don't

Page 9142

 1     know, but this is the duty that you performed; right?

 2        A.   Yes.  At first I was president of the Crisis Staff, and

 3     afterwards this grew into a position called the president of the

 4     Territorial Defence; that is to say, that I discharged those duties for

 5     seven or eight months.

 6        Q.   According to the information I have, you performed these duties

 7     until you were elected minister of the interior.

 8        A.   Exactly that date.

 9        Q.   That was in August?

10        A.   Yes.

11        Q.   I also have information to the effect that these organs at the

12     time, these guards, whatever we're going to call them, that they

13     communicated between and among themselves but they did not have superior

14     command; that is to say, that they operated at local level.  Is that

15     correct?

16        A.   Yes, that's correct.  Since we were separated anyway, very often

17     a village would be separated by one Croatian village or two Croatian

18     villages, so it wasn't easy to communicate, and then each village, each

19     Crisis Staff operated on its own, whatever they deemed best or, rather,

20     what mattered the most at a particular point in time in terms of the

21     defence of that village.

22        Q.   According to my information, this situation prevailed until the

23     army came in, until they took control of all these villages and placed

24     all of these villages guards and the Territorial Defence, whatever it was

25     called, all of that, these groups of people, the army placed all of these

Page 9143

 1     groups under their command; right?

 2        A.   Yes.  May I just say something?  A bit before that, before this

 3     question, may I explain how all of this happened and all the things that

 4     we went through?  I mean, I'm trying to say that in the meantime there

 5     was this visit in Vukovar.  The then-minister of interior of Croatia,

 6     Mr. Boljkovac, and also the deputy prime minister of Croatia,

 7     Mr. Slavko Degoricija, they came since Goran was arrested in Plitvice at

 8     the time.  They came and tried to do have the barricades, the roadblocks

 9     removed, and also to do away with these village guards and to go back to

10     the original situation, not to have any problems, and to continue with a

11     peaceful, regular type of life that prevailed in that area.

12             I attended that meeting, too.  I was invited.  I came there and

13     we talked as human beings, and the explanation provided was that it would

14     not be a good things to have these barricades, these village guards and

15     all of this, that all of that should be done away with.  At first I

16     accepted that, but I said that I could not decide that on my own.  And I

17     said to them, "I suggest to you that we go to Borovo Selo and I have is a

18     staff there, and if that is what we agree on there, then that is what we

19     will do and that will be done."  They accepted that.  We went to

20     Borovo Selo and we were met there in the traditional Serb way, with bread

21     and salt.  We held a meeting for about an hour and a half, and ultimately

22     we agreed that these village guards and barricades be removed.

23             However, when we went back to Vukovar, quite simply we thought

24     that this had been resolved.  However, at my request, Mr. Mercep also,

25     who was on the other side, he was the responsible person there, he was

Page 9144

 1     also invited to that meeting, and I asked whether it was possible to go

 2     to his village, too, and do the same thing, and reach agreement with

 3     them, too, to have this happen, so that the entire area of the

 4     municipality of Vukovar would observe that.  And that's where there was a

 5     problem.  He said that that would not be possible, that he could not

 6     guarantee our security, and that he is not in a position to make it

 7     possible for us to go there peacefully and safely, as they had come to

 8     Borovo Selo, which caused a disruption in our relations a bit.  However,

 9     Mr. Degoricija persuaded us to accept this.

10             There weren't any barricades until Goran, so this was Tuesday,

11     and then on Thursday they promised us that they would bring Goran to see

12     what the situation was and that's what happened.  They brought Goran and

13     there were no barricades on the Serb side.  Goran returned after that.

14     They again, for some other reasons -- well, we had exact information

15     that, at the time, about ten of the most prominent Serbs in Vukovar went

16     missing, that they were simply not there.  And then again this thing

17     happened; namely, there was a loss of mutual confidence.

18             And at the time, again, these same barricades were set up.  And

19     after all of that, what you said happened; namely, the army came to this

20     area and that then things became different.

21        Q.   Could we just clarify one point.  There, in Borovo Selo, when

22     these officials of the Croatian government came and when the removal of

23     barricades was discussed, who was it that they talked to in Borovo Selo?

24     Was it Soskocanin?

25        A.   Yes.  This is the way it was.  Borovo Selo was the biggest

Page 9145

 1     village.  It had the largest population, about 11.000.  We always tried

 2     to accept what the majority wanted.  And of course, Vukasin Soskocanin

 3     was there and Vitomir Devetak and many others who were members of the

 4     Serb Democratic Party.  To tell you the truth, it was accepted that these

 5     barricades should be removed throughout the municipality of Vukovar.

 6        Q.   In your statement, you spoke about the establishment of the

 7     government.  We'll go back to that a bit later.  As far as I understood

 8     that statement of yours, soon after the government was established and

 9     after you were appointed minister of the interior, you went to Sid?

10        A.   Yes.

11        Q.   That was already in August 1991; right?

12        A.   Yes, that's right.

13        Q.   There was this man by the name of Slobodan Grahovac there

14     according to our information?

15        A.   Yes.

16        Q.   You met him?

17        A.   Yes.

18        Q.   Do you know who he was?  Why was he there?

19        A.   Well, I saw him for the first time in Sid, and he told me that he

20     had come to help me with certain things that I was supposed to do, and

21     that he would be there as long as it was necessary.

22        Q.   Does that mean that he was a member of some leadership, some war

23     command, or under your command?

24        A.   Well, I wouldn't say he was under my command, because had it be

25     the case, I would have called him and I would have asked for him to come.

Page 9146

 1     However, since that was not the case and he didn't come there at my

 2     insistence and at my request, I understood him to be someone who was

 3     responsible to someone else to whom he reported about whatever it was

 4     that he did.

 5        Q.   Did you know, perhaps later or even at that time, what his prior

 6     engagements were, what he did before?

 7        A.   No.

 8        Q.   Did he have any of his own people there, some assistants, some

 9     personnel of his own?  Do you recall?

10        A.   Well, there was another man with him, his name was

11     Dusan Filipovic, who was always with him.  And this man was someone that

12     I also saw for the first time then.  I hadn't seen him ever before.  I

13     did have occasion to exchange a couple of words with him, but he never

14     told me who he was, what he was doing there, and so on.  Simply they were

15     installed there, as it were, and I didn't really mind it, but it wasn't

16     really a pleasant thing to have people around you you didn't know much

17     about.

18        Q.   Do you know whether they had any contacts with the

19     Territorial Defence from Serbia, the Serbian authorities?

20        A.   To be honest, I didn't really know much about what they did.

21     They didn't reveal a lot.  And they would go away, but then there would

22     always be one of them who would stay behind.  And then they would take

23     turns, the other would go and the first one would stay.  So, in fact, it

24     was as if they were there to watch or observe our actions, that they were

25     monitoring what we were doing, to see what we were saying and whether we

Page 9147

 1     were actually implementing what had been agreed.

 2             And as for me, I consider that there was one man that deserved

 3     respect and I had to obey his orders, that was our agreement, and that

 4     was our president, Mr. Goran Hadzic, who told me:  You will go to Sid

 5     because there are Serbian villages on that side that are surrounded.

 6     They cannot reach Sid.  They have a lot of difficulties with procuring

 7     medicines, selling the harvest that had already been completed, so do

 8     see, with the military, that they help them to pass through the area and

 9     get to Sid peacefully and also to return, to get back home on a convoy

10     that was there on that day.

11        Q.   And you did that?

12        A.   Yes.  That's exactly the way I worked.

13        Q.   And in fact, am I correct to conclude that you were in Sid, in

14     fact, just to take care of civilian affairs; in other words, to ensure

15     that the Serbian people who lived in Western Srem could satisfy their

16     basic needs, food and other necessities?

17        A.   That's correct, that was the brunt of my work.  There were also

18     problems because there were people who didn't want to wait for the convoy

19     and they would set out for Sid on their own.  They would be captured and

20     disappear.  And there was quite a number of people who disappeared at

21     that time.  We never learned anything about their fate, where they were,

22     what they were doing, or what had happened with them.  So this was one of

23     those important issues that I had to deal with, but sometimes -- and

24     sometimes we did have opportunities to react and do something about it,

25     but in most cases we didn't.

Page 9148

 1             But in effect, I was there because there were these people who

 2     were in a ghetto and they couldn't really get to Sid.  It wasn't all that

 3     close.  They would have to get through four or five Croatian villages, so

 4     getting to Sid was not an easy task.

 5        Q.   Well, just to wrap up, while you were in Sid, you didn't have any

 6     tasks that had anything to do with military issues or with, for instance,

 7     reception of volunteers or sending of military units or procurement for

 8     the military of, let's say, weapons or uniforms and so on, would you

 9     agree with me?  Is that the correct conclusion?

10        A.   Well, at the time, the army was in Sid, and all the tasks that I

11     had I would have to report to Ljubisa Petrovic [as interpreted] and

12     Subotic.  They were colonels of the army.  I had to discuss this with

13     them and tell them what my plans for the day were.  But as far as those

14     who would come from elsewhere, I didn't have any weapons.  I couldn't

15     promise that I could procure that for them.  There was a large warehouse

16     in Sid where these people actually got their uniforms and were then

17     assigned to various areas.  I had absolutely nothing to do with that

18     part.

19        Q.   When you say "I" or "we," do you mean the Ministry of the

20     Interior of Slavonia, Baranja, and Western Srem?

21        A.   Well, yes.  The entire ministry had nothing to do with it.

22        Q.   Just one final thing:  I believe that in the transcript we have

23     the name of "Ljubisa Petrovic."  Did you say "Petrovic" or "Petkovic"?

24        A.   I said Petkovic.

25        Q.   From your statement, where you talk about the arming of Serbs at

Page 9149

 1     this time, I concluded that there were three stages in all of that, and

 2     you will tell me whether I'm mistaken or not.  At the beginning, these

 3     village guards or village patrols only had their own personal weapons,

 4     perhaps one or two persons would have it.  Am I correct?

 5        A.   Yes.

 6        Q.   After the incident in Borovo Selo on the 2nd of May, a certain

 7     quantity of weapons were brought there and then it turned out that they

 8     were outdated and even out of commission; is that correct?

 9        A.   Well, yes.  I don't know, I think maybe this was given to us just

10     so that we would be appeased, that we would have some weapon in our

11     hands.  But, in fact, we were cheated because we received something that

12     couldn't be used at all.  So it was as if we hadn't received anything

13     because it was useless.  Of what we did see, 99 per cent was not working

14     and couldn't be used.

15        Q.   And the third stage was after the arrival of the Yugoslav Army,

16     when they distributed weapons according to their own criteria, they

17     distributed the weapons to people of their own choice?

18        A.   Well, you see, when the army arrived, they recruited younger more

19     capable men who were willing and ready to pick up arms, and this is how

20     the weapons were distributed.  However, we had nothing to do with that

21     and we had absolutely no influence over whatever they were doing, and it

22     was done the way it was done, without our assistance.  And I believe that

23     no one from that same government or those staffs, I don't believe that

24     any of those people had any influence on that or that they could have

25     done anything.

Page 9150

 1        Q.   And this process of weapons distribution by the JNA began

 2     sometime in June 1991; correct?

 3        A.   Yes.

 4        Q.   And the weapons were in working order?

 5        A.   Well, as far as I could learn and as far as I could see, these

 6     were almost new weapons, completely.  They were in order, they worked,

 7     and there were no problems with them.

 8             If I can just add, this would not have happened had there not

 9     been a major incident between Tovarnik village and Divaca [phoen] village

10     where the army was attacked and some five or six soldiers were killed and

11     a lot of materiel was destroyed, or, rather, a large number of vehicles

12     were disabled.  And after this, the events that we've described occurred

13     and that's how it was started.

14        Q.   I'll ask you one more thing:  At the time when the crisis was

15     already evident, when Croatia wanted to withdraw from Yugoslavia, when

16     there were people who wanted to stay in Yugoslavia or not stay in

17     Yugoslavia, so is it correct that people in general - either in Croatia

18     or Serbia - didn't really know what the reaction of the central

19     authorities would be, for instance, the army, the presidency, the

20     presidency of the Republic of Serbia and so on, if Croatia was to take

21     that action?  Or what would happen if there was an attack on Serbia; is

22     that correct?

23        A.   Well, that's correct.  And that's what actually frightened us,

24     because we realised, we knew that our lives and the lives of our families

25     were at stake and everything else, and we would just wait for the evening

Page 9151

 1     news to hear the latest, whether anything else had happened and so on.

 2     And at that point there were problems because many people had -- various

 3     people had various perspectives, and we didn't know whom we could trust

 4     and believe.  It was very difficult to wait and see what our fate would

 5     be, but we all felt that it won't be good.

 6             There were a lot of examples, especially in Vukovar, where we

 7     knew - because this had been checked - where there had been instances

 8     where a person who was released from hospital, for instance, there was a

 9     man, I believe his name was Sava, I can't remember his last name, he was

10     slaughtered in the street as if he was a chicken.  This happened to him

11     and to a couple of other people who themselves had no idea why this

12     happened but it did.  And, of course, no one was willing to go to work

13     anymore, no one felt safe walking around.  And in addition, I was afraid

14     that in Serbia, too, it wasn't clear what was wanted, what the objective

15     was, and we didn't know what would happen to us.

16        Q.   According to the information I have, people usually tried,

17     through various people, from the authorities, the police, the army, the

18     personal contacts they had somewhere, they tried to get some information,

19     but even then, if they got it, it wasn't reliable.  Do you know about

20     this?

21        A.   Yes.  It was very clear to us, and we had meetings amongst

22     ourselves and we received a lot of information that we couldn't believe,

23     because we thought everybody was just saying things that were convenient

24     to them personally.  And they often wanted to calm us down, pacify us,

25     persuade us that we could sleep soundly, but we just knew it wasn't true.

Page 9152

 1        Q.   Do you know if Goran Hadzic was also among those who were trying

 2     desperately to get some reliable information and did he have any success?

 3        A.   As far as I know, he tried in every possible way to get some

 4     reliable information, to get the truth, and I know he had a very

 5     difficult time, perhaps the hardest time of anyone, because everybody was

 6     looking at him with great expectations.  And we waited eagerly for every

 7     meeting to hear from him what was going on and ask him if we could really

 8     believe what we were hearing.  I know that he had a very hard time.  He

 9     was in a very difficult position because I think he, himself, could not

10     believe the things he was being told and he didn't know what was going to

11     happen.

12        Q.   In other words, the information he had was also not reliable and

13     you couldn't take it for granted?

14        A.   Well, I was his deputy and we shared the good and the bad for a

15     long time, but there were often moments when I didn't believe what he was

16     saying either because I thought he had been deceived and that the things

17     that he was told and that he was conveying to us were simply not true.

18     Not because I was doubting his sincerity and honesty to us but because I

19     was doubting what he had been told to tell us.

20        Q.   In other words, you were suspicious about his sources and the

21     people who provided him with that information originally?

22        A.   Yes, because there was no one we could trust, no one who was able

23     to give us reliable information and guarantee that what we were fearing

24     would not happen.

25        Q.   Considering that you were in Sid, you said it was very difficult

Page 9153

 1     to travel to Erdut to attend cabinet meetings, and this entire

 2     communication was very complicated until the easier road through Vukovar

 3     was liberated.  Tell me, how many cabinet meetings did you attend from

 4     the moment when you moved to Sid in August 1991 until the 10th or the

 5     20th November 1991?

 6        A.   It was a very long road for me to travel and not even that belt

 7     towards Erdut that we took was safe.  I would usually get in touch with

 8     the government secretary to find out about the agenda, and I always

 9     asked, "What is so important?  Do I really have to be there?"  There are

10     many meetings that I couldn't get to, and there were meetings where I had

11     to go because my report was important and everybody else wanted to hear

12     what was going on, what the situation was like, et cetera, because I was

13     the only representative of the government behind Vukovar in the direction

14     of Sid, in that area where the majority population was Croat but there

15     were also two or three encircled Serb villages.

16        Q.   Can you remember approximately how many meetings you attended?  I

17     know it was a long time ago but your answer would be valuable.

18        A.   You know, I don't know anymore how many meetings were held

19     overall, and I cannot say with certainty how many meetings I attended and

20     how many I failed to attend because I could easily get it wrong.  It was

21     just too long ago.  And in the meantime, I had major health problems and

22     I lost some memories, like I had slept through some of these periods.  So

23     I don't know how many meetings I attended, but I was active and I wanted

24     to participate in all that was going on.  But I'm really sorry, I cannot

25     answer this question.

Page 9154

 1        Q.   From your answer to the previous question, I see that when you

 2     were informed that a cabinet meeting was pending you inquired about the

 3     agenda and depending on that you would decide whether to go or not.

 4        A.   That's correct.

 5        Q.   And you said that people were most anxious to know about the

 6     situation in your area, in Western Srem, and you would go to the cabinet

 7     meeting to inform the others.

 8        A.   Yes.

 9        Q.   And speaking of the situation in Western Srem, they were

10     interested in the affairs that you were sent there to handle, the

11     civilian affairs, the supplies to the population, and the safe passage to

12     and from Sid.  Was that usually the topic of your briefing?

13        A.   Well, since we had the minister of agriculture, he was supposed

14     to cover that area, but we had an understanding that he would cover the

15     area where he was based, Eastern Slavonia; whereas I covered Srem in all

16     aspects that I could handle and tried to provide to the people with all

17     they needed and help them do whatever they had to do because we had no

18     factories, we had no corn silos to place all the corn that we had, and

19     the wheat.  We had no food processing plants.  But we had to make do

20     without it.  People had to receive their old age pensions and the workers

21     had to receive their wages.  There were many, many problems we were

22     constantly facing.  And whenever I went, of course, I would reiterate

23     these problems and present them to the session.

24             For instance, if we had a problem with that road which was our

25     connection with Serbia, that had to be dealt with because after two days

Page 9155

 1     it turned into a major problem.  Also sick people had to go see a doctor,

 2     and they would have to stay in a hospital in Serbia because they couldn't

 3     get back.

 4             We were the government for the Slavonia and Baranja region and we

 5     had to take care of all these things and report back as to what needed to

 6     be done and what we were able to do.  We couldn't just take part of one

 7     area and give it preferences.  We had to cover the entire region and I

 8     believe we were successful, in a large measure, in providing to the

 9     people what they needed.  Also at these meetings I could hear what was

10     going on in other areas and what our plans were.

11        Q.   When the Ministry of the Interior of Slavonia, Baranja, and

12     Western Srem was established, some police stations were set up as well;

13     correct?

14        A.   Yes.

15        Q.   Where were these police stations?  I know about Dalj and

16     Borovo -- sorry -- yes, yes, Dalj and Borovo.

17        A.   Dalj and Borovo were the first stations to be set up because that

18     was the first area to be liberated.  And it was very important to have

19     this police station, for the police to be active also in the villages

20     because there was always the possibility of looting and robberies.  It

21     doesn't matter by whom, Serbs or Croats or Hungarians.  It's the same

22     thing as in peacetime.  People would take advantage of the circumstances

23     and their positions to perpetrate such things, so this had to be

24     prevented.  Also people came with complaints against individuals who were

25     bent on crime, and of course the police had to get involved and do their

Page 9156

 1     job properly.  Very soon, the Ministry of Justice became operative and

 2     the courts began doing their work in co-operation with the police.

 3        Q.   Let me ask you something else.  Since you were in Sid, what kind

 4     of communication did you have with, for example, the police station in

 5     Dalj?

 6        A.   I was there for the opening of the police station in Dalj and the

 7     police station in Borovo Selo.  But later on when I was in Sid, I

 8     received reports from the people from the ministry who were stationed in

 9     Dalj or Borovo Selo, and I heard information about the latest

10     developments or incidents.  I did not communicate directly with the

11     commanders of these stations, but I had my own people who worked at the

12     recently formed ministry.

13        Q.   And these people you are referring to had communication with the

14     commanders of the police stations, is that what you're saying?

15        A.   Yes.  Their job was to visit them regularly and keep themselves

16     informed.  I also had very experienced career police officers I was in

17     touch with who knew their job perfectly well.

18        Q.   You know that the SUP of Vukovar was also based in Dalj?

19        A.   Yes.

20        Q.   Did you also have contact with the chief of SUP in Vukovar?

21        A.   Not for a long time because with the fall of Vukovar it all moved

22     to Vukovar.  It was no longer in Dalj.  But I did have contact because a

23     large part of Vukovar was liberated precisely on my side, on the side

24     where I was based, with the majority Serb population.  And there also I

25     had a couple of men who went into the field and who informed me

Page 9157

 1     regularly, on a daily basis, about what was going on.

 2        Q.   I'd like to know about this SUP Vukovar that was based in Dalj

 3     before Vukovar fell.  I mean that part of the city that was majority

 4     Serb.  If I understood you correctly, your ministry received reports from

 5     the police stations in Dalj and Borovo Selo; is that right?

 6        A.   No, I received reports from men employed in the ministry in Dalj,

 7     Boro Zemunic [phoen] and Mr. Drzajic who worked in the Ministry of the

 8     Interior, and if anything happened, they would call me and say, We have a

 9     problem in such and such a place.  Their assignment was to go on working

10     as if I were with them and to call me urgently if I was needed and then I

11     would come.

12        Q.   I was interested in something else.  The ministry, not you

13     personally, but the Ministry of the Interior had its men in Dalj and they

14     received regular reports from the SUP Vukovar; correct?

15        A.   Yes, that's correct.

16        Q.   And they also received reports from the police stations in

17     Borovo Selo in Dalj; right?

18        A.   Yes.

19        Q.   And you had a good contact with your people from the MUP in Dalj?

20        A.   Yes.

21        Q.   In your statement you spoke quite a lot about Radovan Stojicic,

22     Badza?

23        A.   Yes.

24        Q.   When he came did you know what position he occupied in Serbia, in

25     Yugoslavia?

Page 9158

 1        A.   At the beginning I didn't.  In fact, it was quite a while before

 2     we first met because I was already in Sid.  But we did meet.  I believe

 3     it was at a government session in Erdut which he attended to.  And before

 4     that, there had been a meeting where we had decided that not a single

 5     member of the government would enter a cabinet session armed.  There were

 6     no formal introductions.  I was just told:  This is Badza.  And when we

 7     were already sitting there at the meeting, all the ministers were seated,

 8     when Badza came in in armour, armed, and when the meeting was about to

 9     begin, I asked:  "What is this all about?  I was told that nobody could

10     bring in a weapon to the meeting.  I see that you are armed.  You are

11     supposed to leave your weapon outside.  There are men who will keep it

12     for you because you are not in danger here.  You don't need a weapon."

13     To which he said, "I can come in with a weapon.  I don't have to leave it

14     outside.  You just don't know who I am."  And I answered:  "I've heard

15     who you are, but whoever you are, you have to leave your weapon outside."

16     And this exchange took a few minutes, and then the other members of the

17     government got involved.  And when he realised that what he had done was

18     improper, he left and he didn't come back to this session.

19        Q.   Was that your first encounter?

20        A.   Yes, that was our first encounter.  And after that we were

21     formally introduced, because I had been told that I had to keep in touch

22     with him because he was from the MUP of Serbia and he had come to help us

23     out with handling all that we had to handle and set up our police and

24     defence and everything.  And I said okay, it's not a problem, but I had a

25     feeling right away that he and I would not be able to have a good

Page 9159

 1     co-operation because he was not a local.  He was not one of us.  He

 2     didn't understand the situation we were in.  And the way he saw it, he

 3     was a man from Belgrade, a very important person, and he thought that

 4     with his move to our district he lost some of his authority and

 5     importance because he was no longer just giving orders.  That's not the

 6     way we worked.  We made decisions together as a government as to what we

 7     were going to do, and he probably didn't like that.

 8             We had our first talk and from that talk I came away thinking

 9     that we would have a hard time working together.  And indeed it was not

10     long before he asked for my resignation, and he asked it from Goran

11     personally.

12        Q.   When he arrived, do you know if he took over the police or the

13     police stations?  Did he place them under his control and command?

14        A.   No, no.  It couldn't have been done that way because when we

15     formed the government, every minister was given a portfolio, a clear set

16     of tasks, and a clear reporting line.  We had to be all accountable to

17     Goran.  We couldn't make any important moves without him.  But neither I

18     nor the other ministers believed that he was able to do whatever he

19     pleased.

20             And let me tell you, that meeting where he asked for my

21     resignation, he didn't manage because all the other ministers wanted me

22     to stay in my place.  That happened at the first meeting.

23             At the second meeting, yes, I did talk to President Hadzic.  He

24     said that it would be a good idea for me to take a different portfolio,

25     such as trade or something, to resolve the problem.  I didn't agree.  And

Page 9160

 1     then we had many more meetings.  It was very, very unpleasant.  And

 2     finally I said, "No problem.  I'll withdraw.  Let my job be taken over by

 3     whoever is willing," because I was by that time very resentful.  And even

 4     another minister, Boro Milenkovic, left that government, saying, "I don't

 5     want to work in a cabinet where others give orders and do as they

 6     please."

 7        Q.   Sorry, you said something here.  You said that all members of the

 8     government were responsible to Hadzic?

 9        A.   Yes.

10        Q.   Do you agree that you and all the ministers and Hadzic were

11     elected by the National Assembly?

12        A.   Yes, we were all elected by the National Assembly, but

13     Goran Hadzic was the first one to be elected, the prime minister.  So

14     according to this hierarchy we were supposed to report to him and he was

15     the one that we communicated with.  Not everybody can complain to the

16     National Assembly.  It was Goran who --

17        Q.   I'm asking you this because according to my information, none of

18     the ministers reported to Goran Hadzic or submitted any kind of reports

19     to Goran Hadzic at all.  That's why I'm asking you.  If I understood you

20     correctly, everybody said what they had to say at government sessions but

21     they did not submit reports to Hadzic and they did not report to him for

22     their work, according to my information.  Are you claiming that ministers

23     reported to him in terms of what it was that they were doing?

24        A.   Well, you see, every government meeting was, of course, opened by

25     Mr. Hadzic.  That is to say, he would open the meeting and also he had

Page 9161

 1     the right to ask what was going on in my department.  Also, I was

 2     duty-bound to say either that everything was all right or if there was

 3     something wrong to say that, too.  That's the way it was for me.  I

 4     respected the hierarchy involved.  If the National Assembly had elected

 5     him as prime minister, and I know that the prime minister can replace a

 6     minister or present a proposal to have him dismissed or whatever, I don't

 7     understand -- I mean, well, does that mean that all the ministers would

 8     just be working on their own?  I mean, did they not report to him?  That

 9     was my understanding.

10        Q.   In other words, at government meetings ministers would present

11     their problems, the problems that they had - if I understand you

12     correctly - and then that was discussed there, whether something should

13     be done or not be done, whether it was being done properly or not?  Did I

14     understand you correctly?

15        A.   Yes, yes.  Correct.

16        Q.   And in that sense you believe that this means reporting to

17     Hadzic; right?

18        A.   Yes, that's right.

19        Q.   Do you know that Radovan Stojicic, Badza, was commander of the

20     Territorial Defence of Slavonia, Baranja, and Western Srem?

21        A.   Well, you see, I heard all of that sort of in passing, and people

22     said to me that Badza was in charge of the Ministry of the Interior,

23     Badza is the one who has the main say in the Ministry of Defence.  I

24     wasn't surprised about the Ministry of Defence because Ilija Kojic was

25     appointed there and he was with the Vukovar police, and I mean, well -

Page 9162

 1     how do I put this? - he had quite a bit in common with Badza.  I did not.

 2             But I found this strange, that a person who had come and who was

 3     out there in the field, that he should be minister of defence without

 4     knowing the people there, which is particularly important; that is to

 5     say, the local people, the local population, irrespective of ethnicity.

 6     There were people there, say, Ruthenians, who did not know who they

 7     should join, so they were split up.  Then there were also some other

 8     people who were not in favour of what the Croatian authorities were doing

 9     although they were ethnic Croats.  But that was not their objective and

10     they were not in favour of that.  So a man who cannot decide at a given

11     point in time whether that was good or not.  So that is something that

12     bothered me quite a bit because, as I said, quite simply if I know, well,

13     not only the people there but each and every foot of the land there, I

14     grew up there, I lived there for 45 years, and you arrive there as

15     someone who is there for the first very first time, you don't know

16     anyone, you don't know anything, and you're taking over?  For me that was

17     a very bad thing, but that's the way it was and that is what was done.

18        Q.   In other words, you heard that he was commander --

19        A.   Yes, yes, I heard about that.

20        Q.   -- of the Territorial Defence?  I beg your pardon.

21        A.   Yes.

22        Q.   Of Slavonia, Baranja, and Western Srem?

23             Let me ask you something:  When speaking to the Office of the

24     Prosecutor - and I see that there were quite a few of these

25     conversations - did you ever say that to them, that you had heard that

Page 9163

 1     Radovan Stojicic, Badza, was commander of the Territorial Defence of

 2     Slavonia, Baranja, and Western Srem?

 3        A.   I don't remember all the conversations that took place, but I

 4     know that he was the one and that is probably something that was well

 5     known, that he was the person who was in command and who actually

 6     commanded the operations that were carried out in the area of Slavonia

 7     and Baranja -- well, again, you see, I find this a bit strange.

 8             The commander of the Territorial Defence at that time -- you see,

 9     when we established that government, the army was there, as you know, and

10     on several occasions we had the opportunity of hearing that for as long

11     as the army was there, there was no civilian defence or protection and we

12     can only have those things that the army agrees to done.  And now,

13     appointing a Badza commander of the defence, that is something that I

14     found sort of unclear.  Do you see what I'm saying?

15             For example, the Territorials, the volunteers, everybody, they

16     were all within the JNA, except for Arkan, who was in his own place and

17     he did not answer to anyone.  But everybody else, as far as I know, had

18     to be subordinated to the army; that is to say, the commander in that

19     area.

20        Q.   Just one question:  Did you know what the relationship was

21     between Radovan Stojicic, Badza, and the JNA?  Was he subordinated to the

22     JNA like others?

23        A.   No.

24        Q.   When you say "no," did you not know or was he not subordinated?

25        A.   I'm certain that he was not subordinated to them because his

Page 9164

 1     co-ordination and the co-ordination of the army was very poor; that is to

 2     say, on this side where I was, that is to say, Western Srem, I mean, he

 3     didn't even come there.  He didn't know what was being done or how it was

 4     being done.  That is one thing.

 5             Secondly, let me say this straight away, in order to have this

 6     known here, the side that Radovan Stojicic was on, the population is

 7     80 per cent Serb, and I believe that it wasn't really necessary at all to

 8     have any kind of major war operations or something like that.  However,

 9     nothing had still happened in Vukovar.  But where the army had arrived,

10     there were four Serb villages and some villages that had about

11     30 per cent Serb population, all the rest were Croats.  So that was it.

12     The commanders in Brsadin, Bobota, Trpinja, Vera, Pacetin, Klisa, and the

13     rest, I don't know that were purely Serb.  I don't know what that meant.

14     So this is really what mattered.

15             JUDGE DELVOIE:  Mr. Zivanovic, just one moment.  Judge Mindua has

16     a question for the witness.

17             JUDGE MINDUA: [Interpretation] Yes, Mr. Zivanovic, sorry for

18     that.  I have a small question to ask to the witness before moving to

19     another topic.

20             Witness, paragraph 36, you said that Arkan didn't obey anyone.

21     What does that mean?  Who did he get his orders from?  What was he doing

22     there?  You said that he obeyed anyone [as interpreted], what do you mean

23     by that?

24             THE WITNESS: [Interpretation] You see, this is the way it was.

25     Arkan arrived in Erdut.  I know that the prime minister, Goran Hadzic,

Page 9165

 1     and we and the ministers did not decide about him coming there, but he

 2     did show up in Erdut.  And let me tell you this:  He was not with the

 3     army.  He was not with us.  He was the one who operated as he wished.  As

 4     far as I know, he did not answer to any one of us.  Also, he didn't

 5     answer to anyone in Belgrade.  He was a man who just worked on his own

 6     and that's how he behaved.

 7             JUDGE MINDUA: [Interpretation] So he did not report to Belgrade.

 8     Is this what you said?

 9             THE WITNESS: [Interpretation] Yes.

10             JUDGE MINDUA: [Interpretation] Then no one was able to stop him

11     or to do anything because he did not report to you or to Belgrade; is

12     that right?

13             THE WITNESS: [Interpretation] Well, you see, Arkan had his own

14     unit in Erdut consisting of about 300 men.  He went into action on his

15     own, without agreeing with the army, without agreeing with us or anybody

16     else.  He did it on his own.  And most often, most often, these

17     operations were you carried out according to his own scenario, as he had

18     envisaged things.  That's the way he did them.

19             JUDGE MINDUA:  [Interpretation] Thank you very much.  Thank you.

20             JUDGE DELVOIE:  Mr. Zivanovic, would this be an appropriate

21     moment for the break --

22             MR. ZIVANOVIC:  Yes.

23             JUDGE DELVOIE:  -- for you?

24             MR. ZIVANOVIC:  Yes, Your Honour.

25             JUDGE DELVOIE:  Thank you.  We'll be back at 12.15.

Page 9166

 1                           --- Recess taken at 11.46 a.m.

 2                           [The witness stands down]

 3                           [The witness takes the stand]

 4                           --- On resuming at 12.15 p.m.

 5             JUDGE DELVOIE:  Please continue, Mr. Zivanovic.

 6             MR. ZIVANOVIC:  Thank you, Mr. President.

 7        Q.   [Interpretation] Mr. Bogunovic, you've said that you know that

 8     Radovan Stojicic, Badza, was not under the command of the Yugoslav

 9     Peoples' Army.  However, I would like to clear up one thing with you

10     because I had the impression you meant that part of the

11     Yugoslav People's Army that operated south of Vukovar, in that area where

12     you were.  Am I right?

13        A.   Yes.

14        Q.   You don't know if he might have had a relationship or

15     communication with the units that were north of Vukovar in that area, as

16     they called it, Operative Group North?

17        A.   I don't know about that.

18        Q.   Do you know that Radovan Stojicic, Badza, when he arrived in

19     Slavonia, Baranja, and Western Srem, brought a unit with him?

20        A.   I knew about four or five men who arrived with him.  I did not

21     know the others.  I didn't know who they were, what they were, and I

22     never had occasion to meet them.

23        Q.   You see my information is slightly different.

24             MR. ZIVANOVIC:  If we can see 1D2337, please, but it should not

25     be emitted to the public and to the witness.  The number is 1D2337.

Page 9167

 1        Q.   [Interpretation] According to the rules we have here, I can't

 2     show you that document, but I will put to you the main points that are of

 3     interest to us.  Namely, from this document, paragraph 7, one unit made

 4     up of 30 men arrived at Dalj on 24 September 1991.  Did you know that?

 5        A.   No.

 6        Q.   And they took over police affairs in Dalj.  It's written in

 7     paragraph 9 of this same statement.

 8             JUDGE DELVOIE:  Ms. Biersay.

 9             MS. BIERSAY:  Thank you, Your Honour.  I am standing because I

10     believe the witness said he didn't know anything about these men

11     arriving, and so the follow-up question seems to have been answered.  The

12     witness says he doesn't know.

13             JUDGE DELVOIE:  Mr. Zivanovic.

14             MR. ZIVANOVIC:  He didn't say -- I'm asking him about the Dalj

15     police station and the overtaking of the work of this specific police

16     station in Dalj.  It is in period when he was minister of interior.

17             JUDGE DELVOIE:  Let's see what the answer is, yes.

18             MR. ZIVANOVIC: [Interpretation]

19        Q.   As I was saying, do you know that Radovan Stojicic, Badza, and

20     his men took over police business in Dalj?

21        A.   No, I didn't know that.

22        Q.   Do you know that they stayed there and organised police stations

23     in Bijelo Brdo, Erdut, Borovo Selo, as we see in paragraph 11?

24        A.   I know about Borovo Selo.  I was involved in the establishment of

25     that station.  As for Bijelo Brdo and the others, I don't know that.

Page 9168

 1             JUDGE DELVOIE:  Mr. Zivanovic --

 2             MR. ZIVANOVIC:  Sorry.

 3             JUDGE DELVOIE:  -- are you continuing this line of question?

 4             MR. ZIVANOVIC:  No, no, no.  I --

 5             JUDGE DELVOIE:  Then I would like to ask the witness.  You said:

 6     "I know about Borovo Selo."  What do you know about Borovo Selo?  The

 7     question was:  Was it taken over by - what is the name again? -

 8     Stojicic's -- Badza -- Stojicic's men?

 9             THE WITNESS: [Interpretation] Mr. President, the police stations

10     in Dalj and Borovo Selo were the first ones to be set up, and they had

11     already been established when Mr. Stojicic arrived, so I don't see what

12     he would be establishing there upon his arrival.

13             JUDGE DELVOIE:  The question was whether you know that

14     Borovo Selo police station was taken over by Badza's men.

15             THE WITNESS: [Interpretation] No, no, I didn't.

16             JUDGE DELVOIE:  Thank you.

17             Please continue, Mr. Zivanovic.

18             MR. ZIVANOVIC:  Thank you.

19        Q.   [Interpretation] In one of your statements I read - and if you

20     want me to refresh your memory, I'll find it and read it - you said that

21     the government of Slavonia, Baranja, and Western Srem was a virtual

22     government.  Do you remember saying that?

23        A.   Yes.

24        Q.   Could you clear that up a little.  Did you mean that it did not

25     have such authority as to be respected by those who should have respected

Page 9169

 1     it or what did you mean?

 2        A.   Well, the people expected from us certain things.  For them, we

 3     were the people whom they knew and believed, and that's what we tried to

 4     do.  First of all, the army appeared in the Srem and Baranja region,

 5     especially Western Srem, and they always said:  We do not recognise

 6     civilian authorities.  As long as we are here, there will be military

 7     authority.  So we could not do anything without them, without their

 8     approval and knowledge.  We just couldn't do anything without first

 9     asking their permission.  So we did have a government but that government

10     was not able to decide in very important matters that concerned the

11     people and everything that happened in that region because the army was

12     there.

13             Second, there was Arkan and Arkan had his own vision.  There was

14     Badza, and now I hear before this honourable Tribunal that Badza changed

15     police stations, established police stations, that he was a war

16     commander, that he was involved in combat, so I believe that we were

17     squeezed out of our own jobs.

18             I went to my own village where my family lives and where

19     Mr. Sljivancanin was the commander, and every time I went there I had to

20     report to him first before going to my house because that's the rule that

21     he had introduced.  So I practically didn't even have freedom of movement

22     as a native of that area, as a local resident.  And that's what I meant.

23     The government that had been appointed did not, in fact, decide anything.

24        Q.   I have one piece of information that is slightly different about

25     the work of that government.  According to that piece of information, the

Page 9170

 1     government was able to decide, but it couldn't put anything into

 2     practice.

 3        A.   We were not able to do much and we were supposed to work in the

 4     best interests of the people, but the people could not count on us for

 5     that.  For instance, we had a minister of agriculture, who was very

 6     important, and he couldn't secure for the commodities produced in

 7     Slavonia and Baranja to be exported to Serbia.  We had cornmeal and sugar

 8     beet, and we needed to be paid for that in order to be able to pay out

 9     the wages and the old age pensions because that was a very long period,

10     and we did not have savings or money accumulated for people to go on

11     working without being paid for two years.  So we were supposed to be

12     taking care of the population.  They were supposed to feel that

13     somebody's taking care about them.

14        Q.   I just wanted to know if my information is correct:  That the

15     government was able to make decisions but it could not implement them on

16     the ground because it didn't have the agencies, the authorities who would

17     do that?

18        A.   That's correct.

19        Q.   You said, among other things, something about the context that

20     members of the government and Mr. Hadzic had in Serbia.  You said they

21     discussed various matters with various people in Vojvodina, in Serbia,

22     and that you know about that.  So would you tell me:  What were these

23     issues that they normally discussed with people from Serbia, and what did

24     Hadzic himself discuss?  What do you know about that?

25        A.   Well, we would usually go to President Hadzic, because he had the

Page 9171

 1     largest circle of contacts, asking for his help.  I'll give you my

 2     example:  For instance, the Ministry of the Interior established two

 3     police stations and then continued to set up others, and I didn't know

 4     anyone in Novi Sad, so I asked him to accompany me when I was going there

 5     to ask for weapons and uniforms and vehicles, everything that a police

 6     force needs.  So we went to Novi Sad together, we had discussions there,

 7     and I received a batch of 200 uniforms that I took to Krajina to

 8     distribute to the employees of the police so that they be properly

 9     dressed, that they could be distinguished as policemen, and that people

10     should recognise them as the men who are responsible for law enforcement.

11        Q.   When you said you were taking these uniforms to Krajina, you mean

12     Slavonia, Baranja, and Western Srem or that later Krajina?

13        A.   No, I'm talking only about the Slavonia, Baranja area.

14        Q.   In addition to that, what were other major problems that made

15     your government contact the government of Serbia?  What were the most

16     important problems?

17        A.   We had meetings in Erdut and in Novi Sad with them.  We focused

18     on contacts in Vojvodina because they were easier to reach.  So the

19     ministers of finance met first, then the ministers of agriculture, then

20     the ministers of trade, those were the ministries that were important in

21     terms of our trade co-operation between the Slavonia, Baranja area and

22     Serbia.  And our job was to collect payment for our exports.  And we

23     needed people like the minister of energy because many villages did not

24     have electricity and people couldn't live normally, so they worked

25     together on getting the electrical supply repaired and installed in every

Page 9172

 1     village so that people could go on with their normal life.

 2        Q.   If I understood you correctly, the topic of these meetings

 3     between people from Vojvodina - that is to say, Serbia - and your people

 4     were civilian affairs, such as energy, trade, et cetera?

 5        A.   Only civilian affairs.

 6        Q.   In your estimate - although I believe you've already said it in

 7     your statement, but let us reiterate it - do you think that any one of

 8     you from the government, beginning with Hadzic down, was able to give any

 9     instructions or orders to Radovan Stojicic?

10        A.   No.  I am sure that nobody was able to give orders to him.  The

11     people who were close to him, who were around him, had to obey.  And I

12     mean specifically President Hadzic, who would often receive visits from

13     Stojicic who barged into his office whenever he liked, and I could see on

14     Hadzic that he didn't like what he had been told and that he wasn't

15     willing to do that, especially since it often ran counter to what we

16     wanted to do and what we had agreed to do.

17             Our life was easier, much easier, when there were no Badzas and

18     no Arkans.  We were able to talk together normally, we knew very well

19     what was going in every corner of our region, and we could agree easily.

20     When they arrived, we made one decision, it's vetoed by Badza.  We make

21     another decision, it's refused by Arkan or the army.  And to be quite

22     honest, there were threats as well, threats of physical violence.  Those

23     were not people with whom you could play games or with whom you can have

24     a normal discussion.  If you failed to do as they said, your fate was

25     pretty much sealed.  And to be frank, we had to worry about saving our

Page 9173

 1     own skins because our people needed us, and that's what we did.

 2        Q.   Can you tell us everything, since you said that there were some

 3     orders there or, rather, decisions that Badza didn't like or Arkan?  What

 4     kind of decisions were they?  What was it that you decided that they

 5     didn't like?  If you cannot remember a specific decision -- of course, it

 6     would be a good thing if you could remember, but if not, could you tell

 7     us what they were like?  In what field?  Did they have to do with trade,

 8     finance, I don't know, police affairs or I don't know what?

 9        A.   Well, you see, I'll start with the police.  The police had to do

10     what Badza had thought.  We knew the people who worked in the police.  We

11     knew people, irrespective of faith, ethnicity, regardless of what they

12     were like or what they were not like.  There were some Croats who were

13     oriented towards Yugoslavia, also there were such Hungarians and

14     Ruthenians.  However, these people did not see it that way.  So our

15     people were bothered by orders like that and this kind of treatment of

16     other people.  So first the police could not work as they were supposed

17     to work, as we were used to.  Or, for example, they'd bring in a man who

18     was certainly not guilty.  This was a serious man who knew what he was

19     doing.  However, we could not exercise any influence.

20             Also, as for this finance and everything else, it wasn't always

21     like why things are going here, why they are going there, why are you

22     doing this, or why are you doing that, although we tried to have contact

23     with important people in the government of Vojvodina so that they could

24     decide what suited us, but that did not always work out.  Also this

25     finance and also the military -- well, there were a lot of things,

Page 9174

 1     actually, that did not suit us and were not very convenient for us and

 2     things did not go as we had planned.

 3        Q.   Could we please try to be a bit more succinct.  I see from your

 4     answer that part of it had to do with certain pre-trial proceedings or

 5     some other proceedings against certain persons that were arrested by

 6     Badza and his men and you thought that these people should not have been

 7     arrested.  Did I understand what you were trying to say?

 8        A.   Yes, yes.

 9        Q.   And then this other situation that has to do with purely

10     financial transactions.  You wanted to sell goods.  For instance, you

11     wanted to deal with one particular company in Serbia and they thought

12     that you should have been doing business with somebody else.  Is that

13     correct?

14        A.   Yes, correct.

15        Q.   Now I'd like to hear more about this first thing that we

16     discussed, these arrests.  Can you tell us, if I understood you

17     correctly, did they do that without asking any one of you, without

18     consulting any one of you?  I mean, they did not ask you first whether

19     somebody should be arrested or not?  Or did they not simply ask anyone in

20     the government?

21        A.   Unfortunately, I have to tell you that things happened and they

22     did not suit any one of us except for the person who thought that that's

23     the way things should be done.  Let me give you an example.  Arkan,

24     without asking anyone, although President Hadzic was not far away from

25     there, he did not consult him at all.  He did not consult anyone else.

Page 9175

 1     He took three or four men out of the police station in Dalj, they never

 2     returned, and nobody knew what happened to them.  For us, that was --

 3     well, we could not understand that something like that could be done.

 4             And finally, you know what?  What made us go on?  We thought what

 5     would happen if others did everything that they wanted them to do,

 6     whereas we wanted to work for the benefit of all, so that things would go

 7     well for us and all of those around us.

 8        Q.   When you're speaking about this concrete case, did that happen --

 9     I mean, do you know when that happened?  More specifically, what the

10     month was or something like that?

11        A.   Well, you know, it's been a while.  It was August or September

12     when I received a letter from a commander of a police station who had

13     been dismissed by Badza.  Badza said to him, "You're wrong for that," and

14     that's it.  You know, that's how it was.  That's when it happened.  In my

15     view, everyone who did not think along the same lines as Badza and Arkan

16     had to be dismissed, and then Badza, Arkan, and the others would appoint

17     people to these positions themselves.

18        Q.   Do you remember what the name of this police station commander

19     was?

20        A.   Cizmic, if I remember correctly.  I may be right, but please

21     don't take my word for this with 100 per cent certainty.  This is what I

22     seem to remember, that that was him.

23        Q.   I'd like to show you a document now.

24             MR. ZIVANOVIC: [Interpretation] It is P115.111.  [In English] I

25     don't know if it is confidential.

Page 9176

 1             JUDGE DELVOIE:  It is, Mr. Zivanovic.

 2             MR. ZIVANOVIC:  It is.  It should not be shown to the public.

 3        Q.   [Interpretation] Do you see it on the screen?  This document is

 4     dated the 18th of October, 1991.  I would now like to ask you to read it

 5     to yourself, and then once you're done, please tell us.

 6             THE INTERPRETER:  Interpreter's note:  Could Mr. Zivanovic please

 7     turn on his other microphone that is close to the screen?  Thank you.

 8             THE WITNESS: [Interpretation] Yes.

 9             MR. ZIVANOVIC: [Interpretation]

10        Q.   Do you remember what happened?  Are you familiar with this thing

11     that happened?

12        A.   Yes.

13        Q.   Do you perhaps remember that right after that, I think that

14     literally on the following day the chief of SUP was replaced, the chief

15     of SUP of Vukovar with his headquarters in Dalj?

16        A.   Yes.

17        Q.   I mean, did you make this decision to have him replaced?

18        A.   No, I didn't even know that he would be replaced.  I didn't know

19     about this that happened.  But later on I heard what had happened.

20        Q.   Do you know whether anything was done there?  Have you read the

21     whole document -- oh, yes, it's just one page.  Yes.  What happened after

22     that?

23        A.   Well, ultimately nothing happened.

24        Q.   Sorry, there is another page so I'd like to ask you to read that

25     as well.

Page 9177

 1        A.   All right.

 2        Q.   Could you please read the next page as well.

 3        A.   Yes.  All right.

 4        Q.   Now I'd like to ask you the following:  First of all, did you see

 5     from this report that some offices were demolished during this protest?

 6        A.   I heard about that, yes.

 7        Q.   And do you know, do you remember -- or, rather, do you know what

 8     the reason was, why, immediately after this protest, the chief of SUP of

 9     Vukovar with headquarters in Dalj was dismissed?

10        A.   Well, somebody had to be dismissed after that and this man was

11     the casualty or the scapegoat, and that was it.  Although he did the

12     least of all.  It didn't happen in the station.  It happened in the area

13     where Arkan operated and where Badza was or, rather, where -- you see

14     where these tank units were, where all this happened.  And that's it.

15        Q.   In your statement you spoke about a crime at a brick factory.  Do

16     you remember that?

17        A.   Yes.

18        Q.   Is that the crime or is it something different?

19        A.   I see here that it has to do with 40 men.  These are people from

20     Serbia, Sonta.  These are people -- these were people who were farming

21     near Beli Manastir and they were transported there, about 15 of them.

22     Among these 15 there was a man with the same surname as mine.  He was

23     executed there and he also went missing there.  His father kept trying to

24     find out what happened.  I didn't know either, but later on I found out

25     that that is what happened.

Page 9178

 1        Q.   In other words, you spoke about the group from Beli Manastir in

 2     your statement?

 3        A.   Yes, yes.  This is the first time I hear of the other one.

 4        Q.   I'd like to ask you now about Zeljko Raznatovic, Arkan.  You've

 5     already said that apparently he did not answer to anyone either in

 6     Slavonia, Baranja, and Western Srem or in Serbia.  In your statement I've

 7     noticed you said that technically he was under the control of the MUP,

 8     under Badza's command.

 9        A.   He wasn't under Badza's command.  As far as I was able to see,

10     they did have understandings, they did talk, but Badza couldn't do

11     anything about Arkan.  Arkan was there with 3- or 400 men and at that

12     time he wasn't listening to anyone.  Badza might have tried.  Maybe they

13     even had an agreement at some point.  But Badza's orders were not to work

14     with Arkan.  That much is certain.  His job was different.  I'm sure it

15     was not on the orders of his superiors in Serbia.  Arkan was unto

16     himself.  He didn't acknowledge Badza or the government or anyone else.

17     He did exactly as he wished.

18        Q.   How is something like that possible?  How is it possible to have

19     3-, 400 men under your command and not be controlled by anyone, the

20     authorities in Serbia or the regional authorities, the army, or the

21     police?

22        A.   Arkan certainly had protection from somebody in Belgrade.  That's

23     indisputable.  And he did what he did as he pleased, and I wouldn't

24     accept that the police would let him do these things without consulting

25     anyone.  What he did in Erdut and what he did later, he did all that at

Page 9179

 1     his own initiative.  I am quite sure that he was a freelancer.  He didn't

 2     accept Badza's suggestions or anybody else's advice.  And I believe that

 3     nobody was able to control that man at that time.  He did exactly as he

 4     pleased.

 5        Q.   In other words, you believe that even the army was unable to rein

 6     him in?

 7        A.   I know that.  I witnessed a couple of encounters where he spoke

 8     very insolently and even insulted military officers.  Let me not repeat

 9     the words he used here when speaking to majors, captains, colonels, but

10     he told them in so many words that he was not going to share anything

11     with them or listen to their orders.

12        Q.   I don't know if we need to go back to this document that I showed

13     you a moment ago, this report about the incident in Dalj.  You've seen --

14             MR. ZIVANOVIC:  May we have -- sorry, may we have P115.111.  It's

15     on the screen, sorry.

16        Q.   [Interpretation] You see that document in front of you, page 1?

17     As far as I can see, these about 300 members of TO Dalj, brought

18     Zeljko Raznatovic, Arkan, to that meeting and required various

19     explanations, and then he said what he said.

20             THE INTERPRETER:  Mr. Zivanovic is speaking so far away from the

21     microphone that we really have a hard time.

22             MR. ZIVANOVIC: [Interpretation]

23        Q.   I really don't understand your explanation, your explanation that

24     nobody was able to rein him in; whereas here we see that members of a

25     local territorial force persuaded him, convincingly enough, to come to

Page 9180

 1     their meeting and make himself accountable.

 2        A.   I accept that he came to that meeting and told them what they

 3     wanted to hear.  I'm quite sure that he didn't give them any

 4     explanations, but I'm also sure that the very next day he continued doing

 5     exactly as before.

 6        Q.   I can see that he accepted their invitation, if we can put it

 7     that way, and it says they ushered him out at gunpoint.  That's what we

 8     see in the last paragraph.

 9        A.   I cannot believe that because you can only carry him out feet

10     first if he didn't want to go somewhere.  You could only kill him and

11     nothing else.  That's the kind of man he was.  And from the little I knew

12     him, that's the way he was and that's the way he stayed until the end of

13     his life.

14             He certainly didn't accept it at gunpoint, because I don't know

15     how many men were there, but if there had been any, even the smallest

16     skirmish, none of them would have gotten out of their alive.  So they

17     probably came to some sort of understanding that he would go there and

18     talk to those people, but he certainly didn't promise anyone that he

19     would change his ways, and he continued doing exactly the same things.

20     If not in Dalj, then he continued doing them in other places.  And that's

21     the way it was until the very end.  And I'm sure that those people who

22     saw that he was building something and organising something, nobody even

23     thought of trying to stop him because that's the way he was.

24             MR. ZIVANOVIC: [Microphone not activated].

25             THE INTERPRETER:  Could Mr. Zivanovic turn on the microphone he's

Page 9181

 1     speaking into.

 2             MR. ZIVANOVIC: [Interpretation]

 3        Q.   Concerning this answer you've just given, it's based on your

 4     assumptions and your conclusions?  You actually don't know what happened?

 5        A.   Well, let me tell you just one thing:  Our government did the

 6     best it could to help those people there, but we noticed that even Badza

 7     was interfering, not to mention Arkan.  All of us who went there, and

 8     especially those who had offices there, had to watch their every word and

 9     every step and had to be very, very careful not to offend those men.

10             We had information that somebody was supposed to intercept

11     Slavko Dokmanovic when he travelled to his own village and kill him.  You

12     can simply not imagine now the kinds of things we went through every day

13     in that time.  We never knew if we would get back home alive.

14        Q.   Let's just see if this is a mistake in the interpretation or in

15     the transcript.  It was said that Goran -- you mentioned Goran, but I

16     think that was not recorded.  You said that he had to watch his every

17     step.  Could you just repeat that passage?

18        A.   He had to watch every step he made.

19        Q.   When you say "he," you mean Goran Hadzic?

20        A.   Yes.

21        Q.   Well, from this I infer that he was somehow followed, watched by

22     Arkan and Badza and their men, is that what you meant?

23        A.   Well, he knows these things better than I.  But it's not only

24     him.  All of us were aware that his every word and his every step were

25     monitored, were closely followed.  There were men around him who watched

Page 9182

 1     from up close and reported to whom they had to report.

 2        Q.   When you say that he and the other members of the government were

 3     watched and followed, I conclude from that that these people had no trust

 4     in either him or the government.  Am I right?

 5        A.   To them we were all suspicious, and almost no one was free in

 6     their actions.  There were perhaps certain things that we worked on that

 7     were not very interesting to them, but if they were interested in

 8     something, we had to be very careful what we did.

 9        Q.   In your statement you also spoke about Jovica Stanisic.

10        A.   Yes.

11        Q.   According to my information, and I saw this in your statement,

12     according to my information, Goran Hadzic and Jovica Stanisic did not

13     know each other in 1991.  Am I right?

14        A.   Whether they knew each other, I'm not sure, but I don't see why

15     they would have to know each other at that time.  I saw Jovica Stanisic a

16     couple of times, but I know that that man never came our way, to our

17     area, and I never heard him talk about us and I didn't have the

18     impression he was interested in us.  I cannot be 100 per cent sure that

19     they didn't know each other, but it's possible.

20        Q.   You also spoke in your statement about Vojislav Seselj and his

21     visit to Vukovar.  You remember?

22        A.   Yes.

23        Q.   I wanted to ask you:  You were there when he visited once?

24        A.   Correct.

25        Q.   At that time did you talk to him about anything?

Page 9183

 1        A.   Yes.  I met him in Negoslavci, and my orders were to take him to

 2     Vukovar so that he could inspect the situation there.  And at that

 3     moment, the people with howitzers were around Vukovar and everybody

 4     around them wanted them to leave.  Nothing was happening.  People were

 5     standing there, waiting.  Morale was very low.  And he had been sent

 6     there to change something, to get things moving.

 7        Q.   If I'm not mistaken, he was sent to boost the morale of soldiers?

 8        A.   Yes.

 9        Q.   Had the army been given notice of his arrival?

10        A.   I believe so.

11        Q.   Were any officers around when he came?

12        A.   At the moment when he reached those first soldiers who were

13     working on the maintenance of the howitzers, he stopped to talk to them,

14     he said, "How are things going?"  They said things were bad.  They said

15     they didn't know why they were there, what's going on, and he tried to

16     explain that they were needed.  And he went from left to right, from the

17     first howitzer to the last, saying that things would change and that they

18     need to stay there because things were what they were but they were

19     needed.  And he promised them that things would change, and he said that

20     he would come and visit at least another five times.

21        Q.   Do you know whether previously, before he came to these

22     positions, whether he had been in Negoslavci where the command was?

23        A.   No.  That visit to Negoslavci and this arrival and then that

24     departure to Vukovar, I mean, that was at the very front line.

25        Q.   In other words, on that day he was in both Negoslavci and in

Page 9184

 1     Vukovar?

 2        A.   Yes, yes.

 3        Q.   And do you know whether in Negoslavci he saw any JNA officers?

 4     Did they know that he had come at all?

 5        A.   They must have known.  It would be impossible for him to come

 6     without any of the officers knowing.  Now, whether they wanted to talk to

 7     him or not, that's a different matter.  But I did not notice anyone

 8     talking to him then, anyone well known engaging in dialogue with him.

 9        Q.   Do you remember whether he had come with a security detail?

10        A.   No.  Only two of his pals, whatever, came with him.  He did not

11     have a security detail at all.  He got a security detail only in

12     Negoslavci and then they accompanied him to Vukovar and back.

13        Q.   These were soldiers?

14        A.   These were soldiers and the TO.  Actually, mostly TO, mostly TO.

15        Q.   At the time the TO was under the command of the JNA?

16        A.   Yes.

17        Q.   Among other things, you said in your statement that there was

18     security provided to the government -- rather, there were persons who

19     guarded government buildings in Erdut.  And then if the members of the

20     government travelled somewhere, they travelled with them as body-guards

21     of sorts.  Do you remember having said that?

22        A.   Yes.

23        Q.   I think that you said that Stevo Bogic was in charge of that

24     security for the government?

25        A.   [No interpretation]

Page 9185

 1        Q.   According to the information that I have -- actually, Stevo Bogic

 2     was the deputy prime minister.  You remember that, don't you?

 3        A.   I think so.

 4        Q.   According to the information that I have, this security of the

 5     government was there round-the-clock.  They took turns.  They worked in

 6     shifts.  They worked there, slept there.  They worked in shifts.  Can you

 7     confirm that?

 8        A.   Yes, yes.

 9        Q.   Also according to my information, there were about ten of them,

10     although often they would change.  Some left and others came, but there

11     were about ten of them?

12        A.   About ten of them.

13        Q.   Tell me, Stevo Bogic was also elected deputy prime minister by

14     the Assembly; right?

15        A.   That's right.

16        Q.   And he could have been dismissed like all of you if the Assembly

17     decided to do that?

18        A.   Of course.

19        Q.   Tell me, please, you spoke about the Serb National Security?

20        A.   Yes.

21        Q.   When you speak about the Serb National Security, is it precisely

22     these people who provided security for the government?

23        A.   Well, I believe that primarily they were supposed to provide

24     security for the buildings and rooms where the government was and where

25     Goran was at the time, but also it wasn't really some kind of national

Page 9186

 1     security that could not move around.  The army was there and, of course,

 2     the things were the way they were but they were supposed to hear about

 3     things being done.  They were supposed to inform the prime minister about

 4     that kind of thing, at least to a certain degree.  They weren't really

 5     security people the way they exist nowadays.  They were there for that

 6     kind of thing.

 7        Q.   In a word, they could not carry out the work that the state

 8     security would have been doing?  Is that what you mean?  Is that what

 9     you're trying to say?

10        A.   No, they certainly could not.  In times like that, in a situation

11     like that, no.

12        Q.   Let us try to clarify this.  I understand that they were securing

13     the government premises and also providing security for government

14     members when they travelled.  But this information, what did you mean

15     when they received information?  What kind of information would this be,

16     of what nature?  What was this supposed to be?

17        A.   It was supposed to be what was happening in other parts of the

18     Slavonia, Baranja region.  Whether something was happening somewhere,

19     whether something was wrong, or whether other things were happening, say,

20     things that the president was supposed to know about.  That's what I

21     meant.

22        Q.   You know why I find this unclear?  These were people who would

23     work in, say, two-hour shifts, providing security for the government day

24     and night, round-the-clock.  Of course they would spend certain intervals

25     sleeping as well.  So they were in the Erdut all the time.  How could

Page 9187

 1     they get information about what was happening throughout the region when

 2     they were not moving about, unless they had some special kind of people

 3     who were sending information to them?  As far as I understood your

 4     answer, it wasn't that kind of service.  It wasn't like state security.

 5        A.   Well, it wasn't, but somebody had to be told about what was going

 6     on in some place where, I mean, the army was or Arkan or the police or I

 7     don't know.  People had to know, at least to a degree, so that the

 8     prime minister would know what was going on.

 9        Q.   So if they received some information about Arkan's movements or

10     the army's movements, they were supposed to inform their superior?  I

11     suppose Bogic, Stevo, who would convey that to Hadzic; is that what you

12     mean?

13        A.   That's what I mean.

14        Q.   Well, I can understand some of this, but why was that

15     interesting, where the army was moving at the time?

16        A.   No, not the army but just what was happening out in the field.

17     You see, that was very important.  For instance, what happened, say,

18     where Arkan was and other people who did something that was not supposed

19     to be done.  We thought that the president should know that and that he

20     should not be the last person to hear about this.  After all, he should

21     know.  He should have the situation under his control.

22             Let me say that I knew this, and I stand by this to this day,

23     namely that people on the ground, when the president went somewhere, they

24     were not thrilled if they would see Arkan and others with him.  That's

25     because people were enraged by things that happened where Arkan was.

Page 9188

 1     That's why this was not right.  That's why we wanted our own people to

 2     escort our president, people we knew would do everything to save him and

 3     to spare him from something that was not good.

 4        Q.   Do you know who Ljuba Mudrinic was?

 5        A.   Yes.

 6        Q.   Do you agree with me that during the war he was the body-guard of

 7     Goran Hadzic?

 8        A.   Well, let me tell you, he was, but Goran knows best of all.  To

 9     tell you quite frankly, I believe that he was nearby, but that he was his

10     direct body-guard, I'm not sure.  I don't know.

11        Q.   Do you know who Milenko Japundic [phoen] was?

12        A.   I know who Milenko Japundic is and I know that he was devoted to

13     the president and I know that he was on his security detail and that he

14     was there with him.

15        Q.   Do you agree with me that Mudrinic and Milenko Japundic were not

16     in Arkan's Serb Volunteer Guard?

17        A.   I agree.

18        Q.   They were from the local -- I mean, from Slavonia, Baranja, and

19     Western Srem.  They had not come from elsewhere?

20        A.   I know that Milenko is from Osijek, but that's all the same as

21     far as we're concerned.  For us what mattered was that he was not with

22     Arkan, in that unit, that kind of thing.  Then things would be viewed

23     differently.

24        Q.   Tell me, you know these two, Mudrinic, Japundic, do you agree

25     that they were not involved in any kind of criminal activity along the

Page 9189

 1     lines of what you've been saying?

 2        A.   I'm sure that these are people who had to leave the places where

 3     they lived, and I'm sure that they were proper, that they did not have

 4     any kind of criminal record.  They did what they did out of patriotism,

 5     and they wanted to be there for the president whom they protected.

 6     Honestly, I'm sure, and they would have done anything to protect him.

 7        Q.   In your statement you said, among other things, that there was

 8     state security.  Now I wanted us to clarify the matter.  First of all,

 9     what period were you referring to when you said that there was a state

10     security?

11        A.   Well, state security was mentioned even while I was minister.

12     But at the time, that did not start functioning because most of the

13     territory was under the Croat control, so it was impossible to do things

14     that way.  After that, I believe that that was established.  Couldn't be

15     done any differently.  People had to know that there was a state security

16     that took care of what was going on, what people were saying, what was

17     being done, and so on and so forth.  And at that moment, they certainly

18     conveyed to the president what they knew and what was heard.

19        Q.   As far as I remember from some things I've seen, you were

20     dismissed from your job first as minister and then as deputy prime

21     minister of SBWS on the 21st December 1991.  There seems to be a mistake.

22     It was 19 December, not 21st.  And I believe around that time that

23     constitution of the Republic of Serbian Krajina was adopted and with it

24     all these three regions were united into one republic, Serbian Krajina.

25        A.   Yes.

Page 9190

 1        Q.   When you were talking about the state security, did you mean that

 2     period which began with the establishment of the Republic of

 3     Serbian Krajina and the establishment of the MUP with both its sectors,

 4     the public security and the state security, did you mean that period?

 5        A.   Yes.

 6        Q.   Do you remember, maybe, that the MUP was then under the minister

 7     of the interior and it had these two branches:  Public security and state

 8     security?  And practically the boss of both was the minister of the

 9     interior?

10        A.   Yes, yes.

11        Q.   Do you remember who the minister of the interior was in the

12     republic Serbian Krajina?

13        A.   It was Milan Martic.

14        Q.   Let me ask you one more thing because you were in Sid.  I have

15     information that at that time when fighting began, anyone who wanted to

16     go to the area of Vukovar, Negoslavci, et cetera, had to have a permit

17     from the authorities?

18        A.   They had to have a pass.

19        Q.   Who issued these passes?  First let me ask you, did you do that?

20        A.   They were first issued by the army and then they handed it over

21     to us.

22        Q.   When did they hand it over to you, when the Vukovar operation was

23     already completed or when?

24        A.   No, the operation Vukovar was not yet finished.  It was handed

25     over to me before that.

Page 9191

 1        Q.   What do you mean before the Vukovar operation?

 2        A.   Before the operation in Vukovar.

 3        Q.   Could you be more precise?

 4        A.   Well, it was towards the end of September, early October.  That's

 5     when we began issuing passes.

 6        Q.   Early October.  When you say "we," you mean --

 7        A.   I mean the MUP.

 8        Q.   And the army no longer did that?

 9        A.   They stopped issuing passes at that time.

10        Q.   Are you sure?  Because you are the only man who says that.

11     Everyone else says exactly the opposite.

12        A.   Well, maybe they issued some passes to people who came directly

13     to see them, but they handed over this work to us regarding people who

14     were travelling back and forth to the Krajina.

15        Q.   Maybe I was not clear enough in my question.  You were talking

16     about those people who were living in villages in Western Srem, and when

17     they came to Sid you gave them these passes so they could go back home?

18        A.   Yes, yes.

19        Q.   So that's what you meant?  That was your responsibility?

20        A.   Yes.  And the army issued passes to those people who went into

21     the reserve force at --

22             JUDGE DELVOIE:  Gentlemen, you're overlapping and putting the

23     interpreters in difficulty.

24             MR. ZIVANOVIC: [Interpretation].

25        Q.   In other words, if somebody else wanted to travel to Vukovar at

Page 9192

 1     that time, a civilian, he would have to go to the army for a pass?

 2        A.   Yes.

 3        Q.   Let's clear up one more thing concerning the incident at Lovas.

 4     You mentioned it in your statement.  I can show you that document, in

 5     fact.  Let me just find it.

 6             You said, among other things, that you found out later about that

 7     incident, and I wanted to ask you:  Did you know that the army had

 8     carried out an inquiry there?  They sized up the situation, they sent a

 9     report to the competent authorities within the military hierarchy, the

10     military prosecutor, et cetera?

11        A.   That's what I heard at the briefing when he went to see

12     Colonel Petkovic and Colonel Subotic.  I didn't know that thing had

13     happened in Lovas, but I heard from them that they had sent a commission

14     over there to inquire and the resulting material had been sent to the

15     proper place in Belgrade.

16        Q.   I wanted to ask you, considering that you were a minister of the

17     interior, does this indicate that at that time it was the army that was

18     responsible for investigating and prosecuting that case?

19        A.   I could not even come near that location at the time.  Nobody

20     cared that I was minister of the interior.  Without the army's

21     permission, I could not even come near.

22        Q.   You said here for the record earlier today that every morning you

23     reported to this Colonel Petkovic?

24        A.   Yes, yes, I did.

25        Q.   Tell me, how did it look?  Did you get any instructions from him

Page 9193

 1     as to what you should do that day, or did you get any approvals or what?

 2        A.   Well, they would tell me whether there would be an escort to the

 3     convoy from Negoslavci, Banovci, to Sid and back, and if anything else

 4     needed to be done, they would give me my assignment.

 5        Q.   You also said that the JNA and the Territorial Defence liberated

 6     certain places or occupied certain places, and as they did so, they would

 7     establish military authority.

 8        A.   Yes.

 9        Q.   Did that mean that after that the civilian authorities had no

10     longer any jurisdiction?

11        A.   No, we couldn't do anything anymore, and they wouldn't even let

12     us organise a local commune or something else that would be civilian.

13     When we suggested it, they would say:  No, you can't do anything there.

14        Q.   In your statement you also said that you tried hard to stop

15     people from leaving those villages where the Territorial Defence and JNA

16     had taken over.

17        A.   That's right.

18        Q.   Tell me, why did people want to leave their villages as soon as

19     the JNA and the TO arrived?

20        A.   It was not enough to liberate a village and for the army and TO

21     to arrive.  It was also necessary for people to enable to sell their

22     goods, to buy what they needed, to go out into the fields and do their

23     farm work, and at that moment it was not possible any longer.  When they

24     would be told that they are no longer allowed to leave their houses and

25     go work on their farms, then people saw no other way out than to leave.

Page 9194

 1        Q.   And I suppose it would be the military authorities who were to

 2     give them this permission?

 3        A.   Yes.  We needed people to stay in their homes.  Those were not

 4     people who were any threat to the army.  They simply had their farms,

 5     their houses, their livestock, the land, and they needed to work.  Our

 6     problem was that we needed to keep those people from evacuating.

 7        Q.   In December 1991, as far as I'm able to see, you moved to Ilok.

 8        A.   Yes.

 9        Q.   That was your assignment given you by the government of Slavonia,

10     Baranja, and Western Srem?

11        A.   Yes.  That decision was made at a cabinet session and it was

12     suggested by President Hadzic.  He said that somebody from the government

13     should be in Ilok because 60- or 70.000 people were waiting to be

14     accommodated there, and somebody from the government should take care of

15     that and assign houses to family depending on the size of the house and

16     the size of the family.  And I as deputy prime minister and Vojno Susa as

17     minister of justice and Mr. Vojnovic as minister of finance were

18     designated to go to Ilok, and we stayed there for I don't know exactly

19     how long but rather a long time until we had completed all this business

20     with accommodating these people.

21             In Ilok we also had about 2.000 Slovaks and we had to keep an eye

22     on them too, to avoid any problems.  Mr. Jan Kisgeci [phoen], who was

23     minister of agriculture in Slobodan Milosevic's government, was

24     particularly concerned about these people.  He called every day to ask us

25     if there were any problems, what was going on, et cetera, but we managed

Page 9195

 1     for all these Slovaks to stay put all the way until peaceful

 2     reintegration which happened in late 1990s.

 3        Q.   When you arrived, were there any empty houses?

 4        A.   Yes.

 5        Q.   Those were houses abandoned by the Croats who had lived earlier

 6     in Ilok?

 7        A.   Yes.

 8        Q.   According to some information we have, they left on the

 9     17th October or the 18th, I'm not sure?

10        A.   Yes.

11        Q.   In these talks and negotiations about the departure of Croats

12     from Ilok, did the government of SBWS play any role in these talks?

13        A.   No.  At that time nobody asked us anything.  The negotiations

14     were led by the army and they agreed with the Croat population of Ilok.

15     The Croats from Ilok said they wanted to leave Ilok, go to Croatia using

16     the motorway that passes by Batkovici.  Although it was not without

17     problems.  They were told that it was not a good idea, et cetera, that

18     they should stay put.  But they were adamant that they wanted to leave

19     Serbia and go live in Croatia, except those 2.000 Slovaks who remained to

20     live in Ilok along with a number of Croats and Hungarians in other

21     villages around Ilok who also stayed.

22             And we were facing another problem.  By that time there were

23     already 4.000 refugees from Backa Slavonia who were temporarily

24     accommodated in the sports hall in Backa Palanka, and we were trying to

25     come to an agreement with the army to make a swap so that these people

Page 9196

 1     could exchange their houses.  And these people who were put up in the

 2     sports hall had been living there without a bathroom for eight days.

 3     Four thousand is a huge number of people.  They were starting to smell.

 4     And we stayed there for another few days, but the army was unable to make

 5     a decision.

 6             And then I called up our government, explained the situation, and

 7     I said that we should move those people.  And then a meeting was held in

 8     Backa Palanka and the meeting was attended by President Hadzic and by

 9     myself, and that's when I first saw Mr. Stanisic.  He was also there but

10     he didn't participate.  He was just taking notes.  And that's how it came

11     about, that we moved those people to Ilok and then we set up a

12     headquarters that handled distribution of empty houses, according to the

13     size of the house and the size of families.

14        Q.   What you've just described, that was in the end of 1991 and early

15     1992; right?

16        A.   Yes.

17        Q.   Were you there?  Did you witness the departure of those people

18     from Ilok?

19        A.   No, nobody could be there except the army.

20        Q.   I'll show you one letter that was sent to the army.

21             MR. ZIVANOVIC: [Interpretation] It's D30.  If we could see it in

22     e-court.

23        Q.   I'd kindly ask you to read this letter to yourself, and then I'm

24     going to put a few questions to you in relation to the letter.  And

25     please tell us once you're done.

Page 9197

 1             JUDGE DELVOIE:  Could we go over the page in English, please.

 2             MR. ZIVANOVIC:  Yes, we have the second page, too.  In B/C/S and

 3     English we have three pages, as far as I know.  We have five pages in

 4     English, actually.  [Interpretation] Yes, there is one more page.

 5             JUDGE DELVOIE:  Can we have -- thank you.  Next page in English,

 6     please.

 7             THE WITNESS: [Interpretation] Very well.

 8             MR. ZIVANOVIC: [Interpretation]

 9        Q.   Can you tell us now.  You've read the letter.  Did it reflect

10     reality, the reality of what was going on then; that is to say, the

11     23rd of December, 1991?

12        A.   Well, yes.

13        Q.   At the time there was military administration in Ilok?

14        A.   Yes.

15        Q.   As I can see, there was not a strict separation of these powers.

16     This letter actually asks for that, to see what the authority that you

17     could possibly have in that situation would be.  Would you agree with

18     that?

19        A.   Yes.

20        Q.   And I see that you did not even know about the criteria on the

21     basis of which people moved into these abandoned houses and how the

22     refugees from Western Slavonia got into these houses in the first place?

23        A.   Let me tell you that during the first days we didn't have access

24     to anything.  We simply sat there, watched, and waited to see what

25     happened.

Page 9198

 1        Q.   I'm talking about the time when this letter was written?

 2        A.   Yes, yes, I understand you full well.

 3        Q.   Among other things, I see that this letter asks that the

 4     Ministry of the Interior should be informed about the activity of the

 5     Ilok police station.  It says here, of course, if these are civilian

 6     rather than military police forces; in other words, the government did

 7     not know of the police station that was functioning there at all.  They

 8     didn't know what kind of police station it was in the first place.  Am I

 9     right?

10        A.   Yes.

11             MR. ZIVANOVIC:  I see the time, Your Honours.

12             JUDGE DELVOIE:  I didn't get a translation of what you said,

13     Mr. Zivanovic, but I can imagine what it was and I thank you for it.

14             Mr. Bogunovic, your cross-examination has not yet been completed

15     and therefore you have to come back tomorrow morning at 9.00.  Now

16     because you are sworn as a witness, you cannot speak to the attorneys of

17     either party nor discuss your testimony with anybody else.  Any

18     conversation you have with persons other than the attorneys cannot relate

19     to the testimony that you have given here so far.  So we are taking the

20     adjournment until tomorrow.  9.00.  Court adjourned.

21                           [The witness stands down]

22                           --- Whereupon the hearing adjourned at 2.02 p.m.,

23                           to be reconvened on Wednesday, the 9th day

24                           of April, 2014, at 9.00 a.m.