Tribunal Criminal Tribunal for the Former Yugoslavia

Page 9984

 1                           Monday, 21 July 2014

 2                           [Open session]

 3                           [The accused entered court]

 4                           [The witness entered court]

 5                           --- Upon commencing at 9.01 a.m.

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

 7     courtroom.

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

 9             THE REGISTRAR:  Good morning, Your Honours.

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

11             JUDGE DELVOIE:  Thank you.

12             May 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, Sarah Clanton, Case Manager

16     Thomas Laugel, legal intern Katherine Davis.

17             JUDGE DELVOIE:  Thank you.

18             Mr. Zivanovic, 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.  Thank you.

22             JUDGE DELVOIE:  Thank you very much.

23             Mr. Hadzic, I remind you that you're still under oath.

24             Mr. Stringer, you may proceed.

25             MR. STRINGER:  I regret to inform Your Honours that I'm not in

 


Page 9985

 1     LiveNote, at least with the live transcript.  I can start, but in the

 2     meantime, if we could perhaps request that someone from the technical

 3     side come in, because I would like to have it, if it's possible.

 4                           [Trial Chamber and Registrar confer]

 5             MR. STRINGER:  I have it now.  Thank you.

 6             JUDGE DELVOIE:  Thank you.

 7                           WITNESS:  GORAN HADZIC [Resumed]

 8                           [Witness answered through interpreter]

 9                           Examination by Mr. Stringer: [Continued]

10        Q.   Good morning, Mr. Hadzic.

11        A.   Good morning.

12        Q.   To start this morning what I'd like to do first is to go back to

13     three items that we touched on Friday, or last Thursday, I should say,

14     during the cross-examination and these relate to your -- or the

15     Prosecution position that you were accompanied by Arkan at one time or

16     another, and the Prosecution position that, in fact, he was commander of

17     the -- the training centre in Erdut.  And so the first of these items,

18     Mr. Hadzic, relates to that, whether, in fact, Arkan was the commander of

19     the training centre in Erdut.  Because on Thursday last week, at 9947 of

20     the transcript, I was asking you about that.  I asked you if you don't

21     deny that Arkan was the commander of the training centre.  You said that

22     you "neither deny it nor confirm it.  It had nothing to do with me."

23             I said:

24             "You're saying you don't know whether he was the commander of the

25     training centre or not?"


Page 9986

 1             And your answer was:

 2             "I won't say that I don't know.  I don't know what exact

 3     appointment he had."

 4             That was your testimony on Thursday; do you remember that?

 5        A.   I do remember it, yes.

 6        Q.   Is that still your testimony or are you in a position now to, in

 7     fact, affirm that Arkan was the commander of the training centre in Erdut

 8     beginning from approximately September of 1991?

 9        A.   What I said on Thursday is what I can repeat today.  When he may

10     have been at that position and at what time has got nothing to do with

11     me.

12             MR. STRINGER:  Apologies again, Mr. President.  I didn't hear

13     that.  I'm on the channel and ...

14             JUDGE DELVOIE:  Yes, Mr. Stringer.

15             MR. ZIVANOVIC:  I think that either translation or transcription

16     was not correct in the last answer of Mr. Hadzic.  So it might be good to

17     repeat this answer.

18             JUDGE DELVOIE:  Yes, Mr. Hadzic, could you please repeat your

19     answer.

20             THE WITNESS: [Interpretation] I don't know whether I can repeat

21     it verbatim, but what I said is that what I had said on Thursday is what

22     I stand by today.  Arkan was what he was but he -- it has got nothing to

23     do with me.

24             MR. STRINGER:  Could we please have 65 ter 4974.07F, as in

25     Francis.


Page 9987

 1        Q.   And what I'd like to do, Mr. Hadzic, actually, and to inform the

 2     Registrar, this is a reference to the suspect interview that you gave

 3     with the investigator, Mr. Dzuro.

 4             JUDGE DELVOIE:  Could we have a tab number, please, Mr. Stringer.

 5             MR. STRINGER:  Yes, it's tab number 1088.

 6             JUDGE DELVOIE:  Thank you.

 7             MR. STRINGER:

 8        Q.   What I'd like to do, Mr. Hadzic, is actually play a short portion

 9     of the video.  Do you recall that your entire suspect interview with

10     Mr. Dzuro was videotaped?

11        A.   Yes, it was.

12        Q.   And at the end of every day's meeting, they would give you a copy

13     of the videotape that you could then keep for yourself and review; do you

14     recall that?

15        A.   I remember that.

16             THE INTERPRETER:  Interpreter's note:  Could the witness be asked

17     to approach the microphone.  We can barely hear him.  Thank you.

18             MR. STRINGER:

19        Q.   Mr. Hadzic, the interpreters are asking if you could sit a bit

20     closer to the microphone.  They're not hearing you so well.

21             MR. STRINGER:  If we could, then, have this video-clip from the

22     suspect interview, please.  And I assume that the interpreters have it?

23             THE INTERPRETER:  We have it.

24             MR. STRINGER:  Thank you.

25                           [Video-clip played]


Page 9988

 1             MR. STRINGER:  Perhaps -- what's happening hear, Mr. President,

 2     is this interview is taking -- it's occurring in both languages, the

 3     questions are coming in English and being put to Mr. Hadzic in his

 4     language, and then they're coming back in his language and being

 5     interpreted back in English.  So it may be that we could simply listen to

 6     the video and the audio portion of it as well and that would be

 7     sufficient, rather than using interpreters here.  At least the first

 8     go-through.

 9                           [Video-clip played]

10             MR. STRINGER:

11        Q.   Now, Mr. Hadzic, you've seen your response there distinguishing

12     between being a commander of Territorial Defence versus commander of the

13     training centre.  In fact, as you informed Mr. Dzuro back in 2002, you

14     knew and you know today that Arkan was the commander of the training

15     centre in Erdut.  Isn't that correct, as you said more than ten years ago

16     to Mr. Dzuro?

17        A.   I don't think I said anything different today.  Arkan was what he

18     was, but I had nothing to do with it and I did not appoint him.

19        Q.   Well, if we could stop playing word games, Mr. Hadzic, I'm going

20     to ask if you can answer directly my question.

21             Do you know that Arkan, Zeljko Raznjatovic, was the commander of

22     the training centre in Erdut from approximately September 1991.  Do you

23     know or do you not know?

24        A.   I don't know as of what date it was precisely.  But your expert

25     witness said so too, Mr. Nilsson, he said whose centre it was.


Page 9989

 1        Q.   And do you agree with him, that it was Arkan's training centre?

 2        A.   No, he didn't say it was Arkan's centre.  He enumerated several

 3     centres and said that one of the centres was the one in Erdut.  Because

 4     it was a Serbian MUP centre.

 5        Q.   In October of 1991, was Arkan the commander of the training

 6     centre in Erdut?

 7        A.   I know that Arkan was there but not in what capacity.  No one

 8     told me anything of the sort, and I did not receive any documents to that

 9     effect.  Arkan was there in October, Arkan and his unit.

10        Q.   When you told Vladimir Dzuro here in March of 2002 that he was

11     the commander of the training centre, that was, in fact, the correct

12     statement, wasn't it?

13        A.   I'm telling the truth now and I told the truth then.

14        Q.   The next item, Mr. Hadzic, from last week and this was something

15     I failed to follow up on after His Honour Judge Delvoie permitted the

16     Prosecution to put a question to you about whether, in fact, Arkan

17     accompanied you to Velepromet in Vukovar on the 20th of November from

18     Erdut.  Do you remember me asking you those questions?

19        A.   I do remember it.

20        Q.   And I want to go back -- well, and just to recap.  Your evidence

21     in this case is that, in fact, on that day, you went with your security

22     people, Mr. Japundzic and Mr. Munduric, as well as Savo Stupar.  Is that

23     correct, that was the testimony you gave here?  That's at page 9755.

24        A.   Yes, that's correct.

25        Q.   Let's go back again to the suspect interview when you met with


Page 9990

 1     Mr. Dzuro.

 2             MR. STRINGER:  And this is 65 ter 4974.04.  And I will get the

 3     tab number for Your Honour.

 4             And on this list, just start with the -- start with the

 5     transcript, if we can.  It's tab 1085.

 6        Q.   Because Mr. Dzuro asked you about this as well, Mr. Hadzic.  This

 7     is page 51.

 8             And at the top of the page he asked:

 9             "Did Arkan and his man provide security for you?"

10             And you said:

11             "Not specifically but only in regard to those general assessments

12     when I was in the field."

13             JUDGE DELVOIE:  Mr. Stringer -- sorry, Mr. Zivanovic.

14             MR. ZIVANOVIC:  Sorry, may we have B/C/S text on the screen, on

15     the left side of the screen, please.

16             MR. STRINGER:  Is it there?  Can I continue?

17             JUDGE DELVOIE:  I think it is, Mr. Stringer.  Please continue.

18             MR. STRINGER:

19        Q.   Mr. Dzuro is asking did Arkan provide security for you.  You

20     said:

21             "Not specifically but only in regard to these general

22     assessments."

23                           [Trial Chamber and Registrar confer]

24             JUDGE DELVOIE:  Could you give us a page number, Mr. Stringer.

25     In -- in B/C/S.


Page 9991

 1             MR. STRINGER:  Perhaps it would be easier, Mr. President, to go

 2     to the video.  So if we could please have 4974.04F, as in Francis.  And

 3     again we can just listen to the audio.

 4                           [Video-clip played]

 5             THE WITNESS: [Interpretation] I can't hear anything.

 6             MR. STRINGER:  It may that be we need to turn up the volume.  I

 7     had to turn it up for myself so ...

 8             JUDGE DELVOIE:  So did I, Mr. Stringer, indeed.

 9             MR. STRINGER:  For the record, we're at pages 40 and 41 of the

10     B/C/S version.

11                           [Video-clip played]

12             MR. STRINGER:

13        Q.   Okay.  Now, Mr. Hadzic, does that refresh your memory?  Do you

14     recall telling Mr. Dzuro that Arkan provided security for you when you

15     went to Velepromet in Vukovar on the 20th of November, 1991?

16        A.   This did not jog my memory with regard to the event that took

17     place on the 20th of November in Vukovar.  I came unprepared to respond

18     to these questions, and I did not provide specific answers.  In a way,

19     the question was put twice.  When the investigator asked me whether Arkan

20     provided support, I thought he had the government in mind.  But now you

21     are tying this to me alone.  And I had to rewind every second of what

22     happened back then to try and figure out what happened in which way so as

23     to be precise.  So on this recording, I didn't think much.  There was a

24     question and an answer.  I thought he meant the government.  He provided

25     security for the government in Velepromet, but it doesn't mean that he


Page 9992

 1     accompanied me alone, as one might conclude from Mr. Prosecutor's

 2     questions.

 3        Q.   Mr. Hadzic, we're referring to this as a suspect interview, and

 4     that's because at that time you gave this interview, you were a suspect

 5     and they told that you in advance.  Isn't that true?

 6        A.   Of course.  And I said so when you asked me that here.

 7        Q.   And you had a lawyer who you brought who was also present with

 8     you in these interviews.  Isn't that also correct?

 9        A.   Yes.

10        Q.   And they told you in advance that, in fact, your answers here

11     could be used against you if today ever came.  Isn't that also true?

12        A.   Yes, that's what was said and it is now proven correct.  Yes.

13        Q.   And so, in fact, this was a serious matter, and you were trying

14     to give your best answers and your best recollection of the events.

15     Isn't that also true?

16        A.   Yes, I said the truth at the time as if I were under an oath.  I

17     did not find it necessary to keep anything back.

18        Q.   And the truth at the time is the same as the truth today on this,

19     which is you were accompanied by Arkan when you travelled from Erdut to

20     Velepromet on the 20th of November, 1991.  Can you -- can you accept that

21     now?

22        A.   I have no problem with accepting anything or not.  I'm testifying

23     under oath and I'm supposed to say how things happened.

24             As for my recollection, it is not the same now as it was

25     ten years ago.  I have now had occasion to rewind and to remember every


Page 9993

 1     detail because every word is important.  When the investigator back then

 2     asked me if Arkan escorted me, I thought, yes, he was there at Velepromet

 3     and I thought that was the escort.  But he had arrived at Velepromet

 4     before I did.

 5             MR. ZIVANOVIC:  Sorry.

 6             JUDGE DELVOIE:  Mr. Zivanovic.

 7             MR. ZIVANOVIC:  I think it is not correct translation.  Because

 8     the witness did not say "if Arkan escorted me," but "you."

 9             It's page 10, line 1.

10             JUDGE DELVOIE:  I -- I see it, Mr. Zivanovic.

11             Please continue, Mr. Stringer.

12             MR. STRINGER:

13        Q.   Well, Mr. Hadzic, let's go back then to your testimony one last

14     time briefly in the Dokmanovic case.  Here you were under oath testifying

15     as a Defence witness.

16             MR. STRINGER:  That's 65 ter 02320.  Tab 830.

17        Q.   We talked about this last week.  I just want to come back to this

18     quickly, Mr. Hadzic, because I don't think it's productive for us to

19     spend too much more time on this.

20             At page 3100 of the transcript in that case, you were

21     specifically asked, and now this is it back even further to 1998:

22             "Isn't it a fact that he accompanied you from Erdut on that day

23     driving to Velepromet?"

24             And, again, as you did with Mr. Dzuro, four years later here you

25     testified that, in essence, yes, he did, as you said:


Page 9994

 1             "We needed that.  We didn't want any incidents to occur."

 2             So, Mr. Hadzic, we've got you saying this in Dokmanovic in 1998.

 3     You've said it again to Mr. Dzuro in your suspect interview, 2002.  Why

 4     not just admit it today that in fact that's how it happened?  Arkan

 5     accompanied you to Velepromet on the 20th of November, 1991.

 6        A.   If I were not under oath I could acknowledge that in order to

 7     satisfy you, but I can't because it's not true.  I recalled every step I

 8     made that day.  I went from Erdut to Palanka, collected Stupar, and came

 9     to Vukovar from Sotin.  That is not in dispute.  When I say Arkan

10     escorted us, I meant the entire government, and he had already awaited us

11     there at Velepromet.  That is the truth.  I did not have any intention to

12     provide false testimony in the Dokmanovic case because I testified under

13     oath.  But I simply answered the question the way I did, because it

14     wasn't clear to me.  It wasn't as clear as you are putting it now.

15             The problem was, Your Honour, that the ministers did not want to

16     attend a government session in Vukovar.  Dr. Hadzic insisted that someone

17     there should guarantee safety.  So it was an arrangement between

18     Dr. Hadzic and the government secretary to have Arkan there.  That is not

19     in dispute.  I did not deny that.  I'd rather not going into that much

20     detail and I'm not very well versed in legal matters.

21        Q.   The last item from last week, Mr. Hadzic, I was asking you about

22     what is now Exhibit P3208, which was at tab 1671 -- 1681, sorry.  And we

23     don't have to show that.  Mr. Hadzic, this was the video footage of the

24     ceremony, if you will, that occurred at the Golubic base facility in

25     1992.  Do you remember my asking you about that and showing you the


Page 9995

 1     footage of that event?

 2        A.   I remember.

 3        Q.   And I was asking you if it was Arkan who was seated behind you at

 4     that, when we showed that footage.  Do you recall that?

 5        A.   I remember that you asked me that.

 6        Q.   And in response to my questions, you said that you did not

 7     especially notice him but did you not exclude the possibility that he was

 8     there.  You said:

 9             "He may or may not have been there."

10             That's at transcript 9978.

11             So with that, Mr. Hadzic, we went back and we -- we pulled

12     another video-clip from that event that I'd like to show you now.

13             MR. STRINGER:  65 ter 04843.  Which is tab ... yeah, tab 1682,

14     which is 04982.01.  If we could start at 2 minutes, 50 seconds.  And we

15     should wait here for the interpreters to tell us they're ready.

16             THE INTERPRETER:  We are ready.

17             MR. STRINGER: [Microphone not activated] Okay.  We can start.

18                           [Video-clip played]

19             THE INTERPRETER:  Interpreter's note:  We cannot hear what is

20     being said.

21             MR. STRINGER:  I know that the interpreters have said they can't

22     hear it.  We've got it at full volume.  But perhaps, Mr. President, the

23     point can be made with the image and not the audio because the point is

24     whether he was present there.  So perhaps at this point --

25        Q.   So perhaps at this point, Mr. Hadzic, can we agree -- I know you


Page 9996

 1     said you didn't notice him, but now does this help you remember that, in

 2     fact, he spoke, Arkan spoke and gave a speech at this event in Golubic?

 3        A.   Last time, you asked me whether the person behind me was Arkan.

 4     I said that maybe yes, maybe no.  I'm -- I saw that Arkan was there,

 5     although I myself did not remember that he was.  But now I can see that

 6     he indeed was there.

 7        Q.   Do you recall in what capacity he would have been present and

 8     giving a speech at this event in 1992?

 9        A.   I don't remember that.  However, he was greeted as the commander

10     of the Serbian Volunteer Guards by the person who introduced him.

11        Q.   Can we agree that he was, in fact, the commander of the Serbian

12     Volunteer Guards?

13        A.   There is nothing for me to agree or not agree.  It's a fact.

14             MR. STRINGER:  We tender that, Mr. President, tender that

15     exhibit.

16             JUDGE DELVOIE:  Admitted and marked.

17             THE REGISTRAR:  Exhibit P3209.

18             JUDGE DELVOIE:  Thanks.

19             MR. STRINGER:

20        Q.   Now, that was 1992.  I'd like to move ahead to a couple of events

21     in 1993, Mr. Hadzic, the first of which is at tab 1051, P03135.  And

22     while that's coming up, this relates to the minutes of the RSK Assembly

23     meeting that occurred on the 9th of October, 1993, in Beli Manastir.  And

24     if you will recall, Mr. Hadzic, last Thursday, I was asking you to look

25     at some of the -- the tape-recorded minutes of that assembly session.


Page 9997

 1     That was P00999.

 2             Mr. Hadzic, do you remember my asking you about your speech that

 3     day when you actually decommissioned or fired Milan Martic as the

 4     minister of the interior and referred to a -- a personal dispute between

 5     him and Arkan in your speech?  Do you recall my asking you about that?

 6        A.   I remember.  That was on last Thursday.

 7        Q.   And so now I want to just show you some video footage of that

 8     assembly session on 9th of October, 1993.  This is again tab 1051,

 9     Exhibit P03135.  P3135.

10             MR. STRINGER:  And we'll wait for the interpreters.

11             THE INTERPRETER:  We are unable to find the correct P number.

12                           [Prosecution counsel confer]

13             MR. STRINGER:  It's at 65 ter number 4876. -- excuse me, 4896.7

14     if that assists.

15             THE INTERPRETER:  Yes, thank you.  We've found it.

16                           [Video-clip played]

17             THE INTERPRETER: [Voiceover] "MO:  Mr. President, the unit is

18     lined up in your honour.  Major Ostojic reporting.

19             "GH:  God be with you, heros.

20             "S:  God be with you too.

21             "MO:  Attention."

22             MR. STRINGER:  If we could just go back a couple of seconds.

23        Q.   I wanted to ask you, Mr. Hadzic, who was the gentleman in the

24     camouflage that you're speaking to there if you recall?

25        A.   That is General Mile Novakovic.  I remember it very well.


Page 9998

 1        Q.   And was he at the time the commander of the armed forces of the

 2     Republic of the Serbian Krajina?

 3        A.   At that time, he was the commander of the Serbian Army of

 4     Krajina.  It was interpreted as slightly different to me, but that was

 5     that.

 6        Q.   Yeah.  And in English, I would use the letters, SVK.  The Army of

 7     the Serbian Krajina.  Yeah.

 8             And when we saw you outside the meeting hall when you were

 9     inspecting the troops and you were greeted as the president, was it

10     then -- were those the troops of the Army of the Serbian Krajina that you

11     were inspecting there?

12        A.   Yes, that was a unit from Beli Manastir municipality, from the

13     Serbian Army of Krajina, from the Baranja Division.

14             MR. STRINGER:  So we can continue then.

15                           [Video-clip played]

16             MR. STRINGER:

17        Q.   Mr. Hadzic, can you identify the gentleman who was the second

18     from the left on the screen?

19        A.   That's Arkan.

20        Q.   By this time, was he a political ally of you?

21        A.   No, he was never my political ally.  But he was a Serbian

22     politician at that time.

23        Q.   Do you know precisely in what capacity he was a Serbian

24     politician?

25        A.   He was a deputy in the Assembly of Serbia.


Page 9999

 1        Q.   And at the time he was a deputy in the Assembly of Serbia, was he

 2     also continuing to command his own unit?  He was still a soldier, whether

 3     it was a Serbian Volunteer Guard or a different unit.  Was he also a

 4     soldier at this time active in military operations?

 5        A.   I don't have any direct knowledge about that.  However, from what

 6     I heard, I think that he didn't come often to Slavonia and Baranja at

 7     that time, and when he did, he appeared in civilian clothes or at least

 8     that's what I heard.

 9        Q.   Well, because in your speech that we discussed earlier, which is

10     set out in P999, which are the minutes, you referred to this incident

11     where Martic had his people withdraw from a certain feature or a location

12     and that there were bad consequences from that.

13             So that suggests to me, sir, that in fact Arkan was continuing to

14     command units that were in the field that were participating in the armed

15     conflict; correct?

16        A.   I can't proffer a comment on your conclusion because that unit,

17     as far as I know, was not under Arkan's command.  It was a small unit who

18     had its commanders.  I don't know who they were.  They were known as the

19     Tigers, and there may have been some 20 or so of them in Velebit, in the

20     area of Mali Alan.  But at that time, I couldn't conclude that they were

21     under direct Arkan's command when they were in the field.  However, if

22     you say so ...

23        Q.   Let's see if we can -- if we can get you to say so.

24             MR. STRINGER:  Let's go back to P999.  These are the minutes we

25     were looking at last week.  Page 7 of the English, page 41 of the B/C/S.


Page 10000

 1        Q.   Mr. Hadzic, this is from your speech.  The top of -- well, the

 2     second paragraph on page 7:

 3             "Because of the personal conflict between Minister Martic and the

 4     commander of the Serbian Volunteer Guards Tigers retreated from

 5     Mali Alan ..."

 6             Do you see that?

 7        A.   Yes, I can see that.  We saw it on Thursday as well.

 8        Q.   So can we agree that as of this time-period, early October 1993

 9     or so, Mr. Arkan -- Mr. Raznjatovic, Arkan, in addition to being a member

10     of the Serbian parliament or a deputy, was continuing to command units of

11     the Serbian Volunteer Guards in operations in the RSK; correct?

12        A.   It is not my intention to launch a debate on things that are

13     clear.  Arkan was the commander of the Serbian Volunteer Guard, and in

14     this case, he was not in command of that small unit when they were in the

15     field because they were in Velebit.  They were deployed there, and they

16     were under somebody else's command.  I don't know who their commander

17     was.

18             MR. STRINGER:  Could we have 65 ter 4774, tab 964, please.  And

19     we don't need audio or interpretation for this, I believe.

20                           [Video-clip played]

21             MR. STRINGER:

22        Q.   Now it's a short clip, Mr. Hadzic.  Do you recognise that place?

23     We can show it again, if you'd like.

24        A.   Please do.

25                           [Video-clip played]


Page 10001

 1             THE WITNESS: [Interpretation] I believe I recognise the venue.

 2     I'm not 100 per cent sure, but I would think that it is the Sava Centre

 3     in Belgrade.

 4             MR. STRINGER:

 5        Q.   That's my information as well.  Did you recognise

 6     Zeljko Raznjatovic there?  First of all, let me ask:  What was the

 7     Sava Centre or do you recall what this event was, what was taking place

 8     there?

 9        A.   I remember the event very well.  It was a meeting of all Serb

10     assemblies which should have adopted Vance-Owen's Plan, which was the

11     peace plan for Bosnia and Herzegovina and the plan which was supported by

12     the European Union and the United Nations.

13        Q.   Now referring to the Vance-Owen Plan, it's my understanding or

14     belief that this was first released or proposed officially in early 1993,

15     January of 1993.  Would that be roughly the time-frame for the footage

16     that we've just seen, early 1993?

17        A.   I don't think so.  I think that the meeting took place later.

18     Because in 1993, I was preoccupied with Maslenica operation and

19     negotiations with the international community.  This was much later

20     because Mr. Raznjatovic came as a deputy in the Assembly of the Republic

21     of Serbia.  We hadn't seen each other for a long time, hence we greeted

22     each other cordially.  I believe that this could have happened either in

23     mid-1993, if not towards the end of that year.

24        Q.   Okay.  And you've actually anticipated my next question, then.

25     Was it Mr. Raznjatovic, Arkan, who greeted you there in the kiss or the


Page 10002

 1     embrace in the footage that we've just seen at that session?

 2        A.   The interpretation I got was "Kistanje," whereas I believe that

 3     the event took place at the Sava Centre in Belgrade.  Kistanje is

 4     Dalmatia.  There must have been a mistake in the interpretation.

 5        Q.   Okay.  I -- Mr. Hadzic, I do believe the record does indicate

 6     your testimony that it was the Sava Centre in Belgrade.  But just so that

 7     we're clear, is that in fact where this is taking place?

 8        A.   Yes, I agree.

 9        Q.   And as we saw in the video footage, it was Arkan who greeted you

10     or you had a -- a kiss or an embrace there, and that's what we saw in the

11     footage?

12        A.   Everybody saw that, we all did.  So, yes, you're right.

13             MR. STRINGER:  Mr. President, we tender 65 ter 4774.

14             JUDGE DELVOIE:  Admitted and marked.

15             THE REGISTRAR:  Exhibit P3210, Your Honours.

16             JUDGE DELVOIE:  Thank you.

17             MR. STRINGER:  Could we have tab 979, please.  P3124.  And we'll

18     go to time code 1 minute, 18 seconds.

19                           [Prosecution counsel confer]

20             THE INTERPRETER:  Interpreters are ready.

21             MR. STRINGER:  Do the interpreters have this?

22             THE INTERPRETER:  Yes, yes, we're ready.

23                           [Video-clip played]

24             MR. STRINGER:  I think we've got the wrong clip up,

25     Mr. President.  Although it appears possibly to be the same event.


Page 10003

 1        Q.   Can you tell us what we've seen so far in this clip?

 2        A.   This was seen on TV Belgrade.  It was a media -- an event which

 3     was widely covered by the media.  This was Arkan's wedding, the morning

 4     of the wedding, that is.  When they actually escorted Arkan to Zitoradja

 5     in the south of Serbia to get the girl.

 6        Q.   That was -- I have it as the 19th of February, 1995.

 7        A.   It is quite possible.  I don't remember when the wedding was, but

 8     I believe that it was in 1995.

 9        Q.   You attended the wedding; correct?

10        A.   Yes, yes.  I was there, but only in the afternoon.  I did not

11     participate in the morning ceremony.

12        Q.   You came to the wedding reception that followed?

13        A.   Yes, I came to the church wedding in Belgrade.

14        Q.   Do you recall whether Stevo Bogic also attended the reception, at

15     least, of Arkan's wedding?

16        A.   I got this CD a couple of months ago.  I reviewed it very

17     carefully, and I saw in the video-clip that Stevo Bogic was there.

18        Q.   Okay.

19             MR. STRINGER:  Let's have, please, tab 803 which is P1937.  It's

20     a document, not a video.

21        Q.   Mr. Hadzic, we're looking here at an interview that you gave in

22     March of 1995.  Do you recall this article?  Do you recall the interview?

23     This is clearly quite some time after you've stopped being president of

24     the RSK at -- at the end of 1993.

25             JUDGE DELVOIE:  Yes, Mr. Zivanovic.


Page 10004

 1             MR. ZIVANOVIC:  Your Honours, I think that the text in B/C/S

 2     could not be seen clearly.

 3             MR. STRINGER:  Yeah, I was hoping maybe the photograph might jog

 4     his memory, but I've got specific parts that I can direct Mr. Hadzic to,

 5     Mr. President.

 6             If we could just stay on the first page or so of the B/C/S and

 7     page 1 of the English, the first heading reads:

 8             "Armed cabinet of the republic's president."

 9             Then I'd like to go to the second paragraph after that.  If we

10     could just blow that up in the B/C/S at least.

11        Q.   And perhaps just to jog your memory, there's the second

12     paragraph -- second sentence says:

13             "Goran Hadzic, former first man of the Republika Srpska Krajina

14     and today's president of the Serb Democratic party of all Serb

15     countries," and it refers to your recent visit to Geneva which had

16     dragged you back into the open.  And I believe you testified about this

17     period in -- toward the end of your direct exam, where you had left

18     politics or you had left public life and then you returned in 1995 in

19     roughly the capacity that's indicated here.  Do you recall that?

20        A.   I remember everything.  You mentioned a few things here.  I said

21     on Thursday that I did go to Geneva later, when I was no longer

22     president, that I talked with all the ambassadors of the Contact Group

23     countries.  And I was also the president of the party of all Serb

24     countries for Slavonia, Baranja, and Western Srem.  It was the SDS party

25     of Slavonia, Baranja, and Western Srem.


Page 10005

 1             MR. STRINGER:  If we could go to page 6 of the English, which is

 2     page 27 of the article, on the page of the article, in the B/C/S.

 3        Q.   And --

 4             MR. ZIVANOVIC:  Sorry.  Is it possible to zoom in the B/C/S text,

 5     please.

 6             MR. STRINGER:  Well, if counsel could just give me just a second,

 7     Mr. President, I'll say what the text is I'd like to look at and then

 8     that might assist the Registrar in identifying what needs to be blown up.

 9             MR. ZIVANOVIC:  If I can say, I think that the accused is

10     entitled to see whole text before Mr. Stringer put him the question.

11             MR. STRINGER:  Well, we've not done this previously, I don't

12     think, Mr. President.  But if -- and I do -- although we've got a lot of

13     time for the cross-examination, I don't wish to really take time to

14     just --

15             JUDGE DELVOIE:  It is a long article, isn't it?  You said six

16     pages.  We are at page 6 in the English text?

17             MR. STRINGER:  Yes, yes.

18             JUDGE DELVOIE:  I think we have to --

19             MR. STRINGER:  What we could do --

20             JUDGE DELVOIE:  -- limit the reading to the parts you want to ask

21     about, Mr. Stringer.

22             MR. STRINGER:  We -- I will do that, Mr. President.  And if the

23     Chamber wishes, at the break, we could provide Mr. Hadzic with a hard

24     copy that he could read --

25             JUDGE DELVOIE:  Okay --


Page 10006

 1             MR. STRINGER:  -- and we could come back to it, if he feels it

 2     necessary.

 3             JUDGE DELVOIE:  That's okay.

 4             MR. STRINGER:

 5        Q.   Mr. Hadzic, I'd like to go to the bottom of page 6 of the

 6     English, the very bottom of that page that starts with the words:

 7             "I met Arkan on the Danube's bank three years ago ..."

 8             And that part in your version is on page -- sorry, yes, as I

 9     said, 27 of the B/C/S, starting at the bottom of the middle column and

10     then continuing to the top of the third column, and it starts with the

11     heading:

12             "People talk that you together with Zeljko Raznjatovic, Arkan,

13     smuggled Slavonian oil."

14             So that's the section or the heading that we're starting with.

15     So it's very bottom of the second column.  We could start with that and

16     then move up.

17             MR. STRINGER:  If the Registrar could perhaps blow that up a bit.

18        Q.   Can you see that, Mr. Hadzic?  The very bottom of that middle

19     column, that's the heading that I'd like to refer you to.  I'm not going

20     to ask you about smuggling, but just so we're oriented.  And then moving

21     up to the top of the third column, are you able to read that on the

22     screen?  Do you want to take a minute to read that?

23        A.   Half a minute.

24             MR. STRINGER:  And for the English, we can move to page 7.

25        Q.   Mr. Hadzic, I want to ask you a few questions about your remarks


Page 10007

 1     about Zeljko Raznjatovic here.

 2             Top of page 7 you say:

 3             "I only know that he helped the people here a lot.  He personally

 4     conducted all the operations of his Tigers.  He left this place

 5     spotless."

 6             What do you mean by "spotless" there?  I'd like to give you a

 7     chance to explain that.  I'd suggest perhaps you're indicating that he

 8     left it spotless in respect of non-Serbs.

 9        A.   My bringing up would never permit me to draw such a conclusion.

10     It's clear what was being discussed here.  Crime was mentioned and I

11     believed -- since at that time I didn't have any information that Arkan

12     was involved in any crimes, I believed that he left without any blame.

13     He didn't commit any thefts or robbery, in economic terms.  That's what I

14     meant.  At least as far as I know.  The topic of the conversation with

15     the journalist -- and I didn't authorise the interview.  We spoke at my

16     house.  She didn't even tape the interview.  We talked, then she made the

17     interview without my knowledge, without consulting with me.  The topic

18     was crime.  That was that question I was charged of -- with smuggling oil

19     and cutting down timber, which I did not do.

20        Q.   Continuing down a few lines you say that:

21             "Some people objected that Arkan attended RSK government

22     sessions.  I respected his knowledge of the military and thus he attended

23     the sessions."

24             Now, Mr. Hadzic, what this suggests here is that, in fact, Arkan

25     attended assembly sessions of the RSK because you wanted him to do so.


Page 10008

 1     Isn't that how it was?  Because of his military skill.

 2        A.   No, this is absolutely incorrect.  I did not say that, nor can

 3     that stand in any sensible way.  In my interpretation I heard "assembly,"

 4     but here it says "government of the RSK."  I was not a member of the

 5     government.  I had no influence on the agenda.  I didn't attend the

 6     meetings.  I personally attended the government meetings maybe two or

 7     three times, but when I attended Arkan was not present.  So I don't know.

 8     These are some conclusions by the journalist, and it's not anything that

 9     I myself said.

10        Q.   Well, we know that in fact he attended the assembly session on

11     the 9th of October, 1993, which is the time that you fired Mr. Martic

12     because of that operation at Mali Alan; correct?

13        A.   Yes.  But the assembly is one thing and the government is

14     another.  He attended the assembly session as a guest as a deputy from

15     the Republic of Serbia with Dr. Sava --

16             THE INTERPRETER:  The interpreter did not catch the last name.

17             THE WITNESS: [Interpretation] They were members of the assembly

18     attending from Belgrade.

19             MR. STRINGER:

20        Q.   That was a reference to Dr. Sava Stupar?

21        A.   Yes.

22        Q.   But is -- what's indicated here is true, isn't it, that people

23     objected --

24             MR. ZIVANOVIC:  Sorry, I see it is not translated, the capacity

25     of Dr. Sava Stupar, in what capacity he attended the assembly.


Page 10009

 1             JUDGE DELVOIE:  And did -- did the witness indicate that

 2     capacity, Mr. Zivanovic?

 3             MR. ZIVANOVIC:  Yes, he did.

 4             JUDGE DELVOIE:  Okay.

 5             Could you repeat, Mr. Hadzic.

 6             THE WITNESS: [Interpretation] Sava Stupar was a deputy and

 7     vice-president of the Vojvodina Assembly, the Autonomous Province of

 8     Vojvodina.

 9             JUDGE DELVOIE:  Thank you.

10             MR. STRINGER:

11        Q.   The fact is people did object to your close association with

12     Arkan during the period that you were the president of the RSK.  Isn't

13     that true?

14        A.   No.  I was not -- I did not have a close association with him,

15     nor did anybody criticise me for that or object to that.  At least not to

16     my knowledge.

17        Q.   You said:

18             "I cannot survive because I am consistent to the policy, both

19     choice and loyalty to my friends.  I was directly suggested to renounce

20     some people in order to stay at the top, which I did not do and I am

21     still following the same policy and have the same friends."

22             So with that let me ask you again, Mr. Hadzic:  Isn't it true

23     that others around you wanted you to renounce Arkan and discontinue your

24     relationship and association with him?

25        A.   No, that is not true.  It's absolutely incorrect.


Page 10010

 1        Q.   You never heard anything negative about Zeljko Raznjatovic during

 2     the period September 1991 to the end of 1993?

 3        A.   What I heard, I told you in my testimony.  I explained how I

 4     heard it and who told me that.

 5        Q.   I'm asking you:  From September 1991 to the end of 1993, is it

 6     your evidence that you never heard anything negative about the activities

 7     of Zeljko Raznjatovic?

 8        A.   I've just said that I already told you what I had heard in

 9     relation to the incident in the village of Trpinja.

10        Q.   Well, you also know that he spoke to you and threatened to kill

11     the children of Milan Babic if he did not accept the Vance Plan.  That

12     must have suggested to you something about the quality of

13     Mr. Raznjatovic.

14        A.   I heard that from him personally, but he didn't kill Milan

15     Babic's children.  As for the qualities, well, that was clear to me when

16     I heard that, but I didn't hear anything else.  I was careful because of

17     the threats that I had received.

18        Q.   Well, you were careful in your relations with Arkan because you

19     knew he was a dangerous killer.  Isn't that how it was?

20        A.   These are your words, "a dangerous killer."  A dangerous man.  I

21     didn't know that he was a dangerous killer.

22        Q.   But what he was to you, even in March of 1995, was your friend,

23     as you say here in the article, and that you remained loyal to him and

24     did not renounce him because he was your friend throughout this entire

25     period of time.  Isn't that true?


Page 10011

 1        A.   That is not true at all.  This is completely in a different

 2     context here.  As for talking about Arkan, I finished that in the first

 3     half, in the first few lines.  As for the second half of the interview,

 4     this is something completely different.  It has nothing to do with my

 5     friendships.  I had many other friendships.

 6        Q.   I'm not saying you didn't have other friends, but it's true, sir,

 7     isn't it, that you counted Arkan as among your friends here when you gave

 8     this interview in March of 1995?  You attended his wedding just one month

 9     earlier.

10        A.   The only thing that could be true from all of this is that I

11     never said that he was my enemy.  I never said that he was my friend,

12     though.

13        Q.   Mr. Hadzic, I asked you, I believe it was last Thursday,

14     referring to your suspect interview, you described for Mr. Dzuro a

15     meeting that you attended in Belgrade - I believe you said it was in the

16     fall of 1991 - in which Arkan was also present and a gentleman named or

17     known to you as Kum.  Do you recall my asking you about that?

18        A.   Yes, I do.

19        Q.   Yeah.  And what you told Mr. Dzuro was that at this meeting,

20     there was a discussion of setting up or creating a Serb army from the

21     JNA.  Do you remember my asking you about that, your description of that

22     to Mr. Dzuro?

23        A.   Yes, I remember you asked that, but I don't know how I described

24     that to Dzuro.  But it was just an accidental thing.  It was not the --

25     the main thing at all.


Page 10012

 1        Q.   Right.  It was an accident that you and Arkan were at this

 2     meeting in Belgrade.  That's your evidence?

 3        A.   As for it being a coincidence, an accident, I didn't say that.

 4     But I was talking about what you asked me, whether the Serbian army was

 5     discussed, and I said that was a silly thing.  It was just one sentence,

 6     and I didn't get myself involved in that.

 7             As for the meeting, I can explain how this occurred.  Well, it

 8     couldn't have been a coincidence.  Somebody did schedule the meeting and

 9     somebody invited those guests who were supposed to attend.

10             MR. STRINGER:  Could we have, please, 65 ter 4974.04C, as in

11     Charlie, which is tab 1085.  Pages 23, 24 of the English; 18 and 19 of

12     the B/C/S.

13        Q.   We can take another look at this briefly, Mr. Hadzic.

14             MR. STRINGER:  We can use just the transcript for this.  We don't

15     need the video.

16        Q.   And it's just starting at the bottom of page 23 of the English.

17     You said:

18             "I was there independently from Arkan."

19             And that's as you've described in your evidence here in this

20     trial.  And then continuing to page 24 of the English.  You're -- in the

21     middle of the page you're describing, first of all, that General --

22     Lieutenant-General Simovic was there.  He was with the Serbian Ministry

23     of Defence; correct?

24        A.   Yes.

25        Q.   He was in fact the defence minister?


Page 10013

 1        A.   Yes, he was.

 2        Q.   And then you're describing this gentleman who presented himself

 3     as a colonel of the Russian army or known only to you as Kum.  And then

 4     toward the bottom of page 24 of the English, you say:

 5             "At the time, they proposed that a Serb army be made, that this

 6     is senseless, that the JNA was a Communist army, that we would never be

 7     able to win the war against the Croats without a Serbian army.  They were

 8     telling all this to Simovic ..."

 9             And then just continuing on to the next page of the English.  And

10     this is where you said, as you've said here, that -- you said:

11             "As soon as I saw what this was all about, I did not talk

12     anymore, I did not speak, did not take part in the work of this meeting."

13             Is that still your recollection of how it was at that meeting,

14     Mr. Hadzic?

15        A.   Yes.  You just omitted something when you were talking about this

16     Kum.  He introduced himself as a Russian army colonel, but I said that

17     that was a completely silly thing.  It had nothing to do with it.  It was

18     not true.  Nobody knew what his actual name was.  He was there for five

19     or six days, and then later no more was heard from him ever.

20        Q.   Did you see him on other occasions then, apart from this meeting?

21        A.   I don't remember.

22        Q.   Well, you said he was there for six or seven days.  I'm just

23     wondering how you knew that.

24        A.   He was there just for a brief period.  Perhaps ten days; perhaps

25     five or six days.  And then at least -- and then he never appeared again.


Page 10014

 1     At least I never heard of it.

 2        Q.   Were in Belgrade during this same period of six, seven, or

 3     ten days?

 4        A.   Yes.  Perhaps I was there two or three times in Serbia, in

 5     Novi Sad, to see my family.  Perhaps in Belgrade at a press conference.

 6     Things like that.

 7        Q.   Was it during this same period of this meeting that you also had

 8     the meeting at the defence ministry with General Djordjevic?  I asked you

 9     about that last week also.

10        A.   I'm not sure about that, whether it was the same day or another

11     day.  I really cannot say.

12             MR. STRINGER:  Could we have P1742, which is tab 448.

13        Q.   Mr. Hadzic, this is an article from March of 1992 Politika.  And

14     I think you said in your direct examination at some point that Politika

15     was -- you described it as something like the Serbian newspaper for at

16     least your area in Eastern Slavonia.  Would that be a correct

17     characterisation of Politika?

18             MR. ZIVANOVIC:  Sorry, just one correction.  It is another

19     newspaper called Borba but it is just news from the Politika area.

20             MR. STRINGER:  I'm looking at the top of the B/C/S and it says

21     "Politika" at the top.  But I don't know that it is -- is all that

22     important.

23             MR. ZIVANOVIC:  It is just kind of columns.  But the paper is

24     Borba and it was written on the left side of the screen.

25             MR. STRINGER:  Thank you.


Page 10015

 1        Q.   There were a couple of things in this article I wanted to direct

 2     you to, Mr. Hadzic.  One of which -- I'll just go straight to it.  There

 3     are a number of comments directed to you.  And in your version, the

 4     original language version, just at the top of the third and the fourth

 5     columns, there's a heading that says:  "Ciscenje armije," which is like

 6     clearing of the army although others are much better off or in a much

 7     better position than me to say what that means.

 8             In the English we have "clearings in the army," and here there's

 9     a statement attributed to you:

10             "In my opinion, a great part of the army is now cleared, over

11     80 per cent.  There is still a small group that could create problems but

12     it very insignificant, and I hope that the outcome will be positive and

13     that they will realise whose army they are and who they belong to."

14             Mr. Hadzic, in fact you, like Arkan in the meeting in Belgrade

15     that I asked you about, you also supported clearing the JNA and making it

16     into a Serb army.  Isn't that true?

17        A.   No, that is not correct.  These two events are not related.  This

18     is about my political convictions, and it's a problem that we had with

19     the SK movement for Yugoslavia which was very powerful in the military

20     leadership.  So I was referring to that problem of that SK movement for

21     Yugoslavia issue.  At a meeting at General Simovic's, I was invited by

22     General Simovic, he was the minister of defence of Serbia.  He invited

23     his guests, and Arkan was a part of the Serbian state and he came as part

24     of Serbia.  That is what I had to accept.  He came as a member of the

25     institution of Serbia to Slavonia and Baranja.  I was not the one who


Page 10016

 1     could decide who could attend the meeting or not.  I had the choice of

 2     talking or staying silent and I chose to remain silent at that meeting.

 3        Q.   Well, at the time of the meeting with General Simovic, though,

 4     Arkan was also based at the training centre in Erdut commanding the

 5     Serbian Volunteer Guard; correct?

 6        A.   Yes.

 7        Q.   Did you travel to Belgrade with Arkan on that occasion?

 8        A.   No.

 9        Q.   On any occasion, did you travel with Arkan to Belgrade?

10        A.   I don't recall.  I don't think so.

11             JUDGE DELVOIE:  Mr. Stringer, would this be an appropriate time?

12             MR. STRINGER:  Yes, Mr. President.

13             JUDGE DELVOIE:  Court adjourned.

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

15                           [The witness stands down]

16                           [The witness takes the stand]

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

18             JUDGE DELVOIE:  Please proceed, Mr. Stringer.

19             MR. STRINGER:  Thank you, Mr. President.  During the break I'd

20     actually inquired whether it would be possible for me to raise something

21     with the Chamber before Mr. Hadzic was brought into the courtroom.  I can

22     wait or ...

23                           [Trial Chamber and Registrar confer]

24             JUDGE DELVOIE:  It seems there has been a little

25     miscommunication, Mr. Stringer.  We can ask the security to escort

 


Page 10017

 1     Mr. Hadzic out of the courtroom for a moment.

 2             MR. STRINGER:  Apologies to Mr. Hadzic, but I think it would just

 3     be best to do it rather than later.

 4             JUDGE DELVOIE:  Okay.  Yeah.

 5             Please, Mr. Hadzic.

 6                           [The witness stands down]

 7             MR. STRINGER:  Mr. President, I just wish to ask the Chamber's

 8     guidance on something that I would hope to do during a later part of the

 9     cross-examination, perhaps during this session.

10             During his direct examination, Mr. Hadzic gave evidence about

11     when he first met Arkan and Badza, Radovan Stojicic, together in Dalj in

12     early August of 1991, and he goes on to describe that or to give evidence

13     about it.  And in his direct examination, he gave the names of two other

14     individuals who had accompanied Badza, Stojicic, or who were accompanying

15     him when they met there in Dalj in early August of 1991.  (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

19                           [Private session]

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)


Page 10018

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 2

 3

 4

 5

 6

 7

 8

 9

10

11 Pages 10018-10027 redacted. Private session.

12

13

14

15

16

17

18

19

20

21

22

23

24

25

 


Page 10028

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11                           [Open session]

12             THE REGISTRAR:  We're in open session, Your Honours.

13             JUDGE DELVOIE:  We are in open session.

14             Could you perhaps, Mr. Stringer, go back to that part of the

15     answer.

16             MR. STRINGER:  Maybe it's just best to start again.

17        Q.   Mr. Hadzic, I'd referred you to the section of this article which

18     refers to Seselj, Jovic, Paroski.  You've now read that.  And my question

19     then was to suggest that all three of these gentlemen were leaders of

20     personnel who were outside the JNA who did come and support the cause of

21     establishing the Serbian Autonomous Region of SBWS in late 1991.  And

22     perhaps I should expand that as well to other autonomous regions, either

23     Western Slavonia or the Knin Krajina.

24        A.   I don't know what Seselj, Jovic's, and Paroski's roles were in

25     other parts, in the eastern part.  In Slavonia, Baranja, and Western

 


Page 10029

 1     Srem, they didn't play a political role.  They only organised volunteers

 2     in Serbia and they sent them to Slavonia and Baranja via the JNA.

 3     Volunteers were not able to come or be deployed in that territory if they

 4     were not JNA members.

 5        Q.   Well, you had personal communications with Jovic and Paroski

 6     during the early period, I would say, spring, mid-1991.  Isn't that true?

 7     You were dealing with them, you were personally in contact with them and

 8     discussing with them or dealing with them on issues related to support.

 9     True?

10        A.   I had communication with Paroski before the war, before I even

11     knew that there would be a war.  He appeared at the first conference of

12     the SDS in Vukovar on 10th of June, that's when I met him.  And then I

13     met him again only once, in Novi Sad.  As for Mr. Jovic, I saw him only

14     later in Stara Pazova where he resided.  We met at a lunch.  And then he

15     visited Slavonia and Baranja and that's where I met him again, in Erdut.

16     He supported Milan Babic which means that he supported a policy totally

17     different from mine.

18             MR. STRINGER:  Could we please have tab 1052, which is

19     Exhibit P00240.  This is video.  We do want the audio and so if the

20     interpreters could indicate when they've found that.

21                           [Video-clip played]

22             THE INTERPRETER:  Could we also have the 65 ter number because we

23     don't have P numbers on the materials that we have received.

24             JUDGE DELVOIE:  It's 04904.1.

25             MR. STRINGER:  04904.1.


Page 10030

 1             Let me come back to this, Mr. President.  Let's skip it for the

 2     time being.  I don't know that we've got it ready.

 3        Q.   What we can do instead, Mr. Hadzic, is move to a different video

 4     that relates to this article, I'd suggest.

 5             MR. STRINGER:  Tab 1010, which is P0117.111.  Do the interpreters

 6     need the 65 ter number for that?

 7             THE INTERPRETER:  No, thank you.  We have found the document.

 8             MR. STRINGER:  Okay.  We can play this, then.

 9                           [Video-clip played]

10             THE INTERPRETER: [Voiceover] "... and he spoke with Mile Mrksic

11     and members of his staff.

12             "... 3 kilometres south of Vukovar."

13             MR. STRINGER:  Okay.  And what we can do now is to scroll ahead

14     to time code 4 minutes, 40 seconds.

15             Apologies, Mr. President.  We've got it.  Okay.  We should be

16     ready.

17                           [Video-clip played]

18             THE INTERPRETER: [Voiceover] "And of our own initiative we did

19     what we did, and we wouldn't have destroyed it to the extent that we did

20     had they decided to surrender, but they didn't want to surrender.  And

21     secondly, the men did not want to charge, you know.  You can go about

22     attacking using equipment to no end, but if you don't have a man who will

23     seize it ... that's the greatest merit of Arkan's volunteers.  Some are

24     imputing, however, that I am acting in collusion with paramilitary

25     formations.  Those are not paramilitary formations here.  Those are men


Page 10031

 1     who have come voluntarily to fight for the Serb people.  We encircle a

 2     village, he storms in, and whoever doesn't want to surrender he kills

 3     off, and we move on.

 4             "And we are here to defend these people, to help, together with

 5     the Yugoslav Army.  Actually, for me, this is the Serbian army because

 6     I -- it is known, the Army of Yugoslavia was deployed from Djevdjelija,

 7     from Sezana to Djevdjelija.  This is no more, so this a Serbian army, and

 8     it's the nucleus of the future Serbian army that we're only going to

 9     cleanse.  Meaning that we throw out these 80 per cent of generals who

10     have been passive and who haven't been fighting, who have been betraying

11     the people.  And naturally that the real people - these generals who are

12     here, and others who are war-time generals, who have distinguished

13     themselves, and officers who have distinguished themselves in this war -

14     take over and just transfer the Yugoslav Army into a Serbian army.

15     Therefore, I think we all have a common goal and that is united Serbian

16     states, which would consist of Serbia, Montenegro, the Serb Republic of

17     Krajina, and a Serb republic in Bosnia, that we create the united Serbian

18     states ..."

19             MR. STRINGER:

20        Q.   Mr. Hadzic, what was interesting here is that Mr. Raznjatovic,

21     Arkan, refers to 80 per cent as being the number of generals who have to

22     be expelled in order to make the JNA into a Serbian army, which is

23     coincidentally the same percentage that you use in this article.  You're

24     referring to a great part of the army is now cleared over 80 per cent.

25     So I'm going to put it to you, sir, that in fact what you're talking


Page 10032

 1     about here is the same thing that Arkan is talking about in the video we

 2     saw which is what he also talking about in the meeting that you attended

 3     in Belgrade with General Simovic, and what that was about was in fact, as

 4     you described, removing JNA generals who were not thought, by you and

 5     Arkan, to be sufficiently together and to be sufficiently willing to

 6     deploy the JNA as a Serb army to take part in the creation of a Serbian

 7     state.

 8             So isn't that how it was?  You and Arkan shared this view, the

 9     views he has just expressed?

10        A.   First of all, I didn't say that Arkan and I shared political

11     opinions and it is clear from that text.  Why are you misinterpreting

12     things now, given that we should both in favour of the truth?  I said

13     that over 80 per cent of the matter had been resolved [Realtime

14     transcript read in error "resoft"] and Arkan said just the opposite.  I

15     don't know when he said it.  I wasn't there.  He said that over 80

16     per cent of those officers had to be removed.  So the whole matter is

17     exactly the opposite to the way you have just portrayed it.  I never

18     heard Arkan say this.  I was not there.  I didn't even see this clip on

19     television, if it was ever aired at all.

20        Q.   Well, you heard Arkan say this in Belgrade.  True?  Or words to

21     this effect?

22             JUDGE DELVOIE:  Mr. Zivanovic.

23             MR. ZIVANOVIC:  I noted the word "resoft" in the -- at the

24     page 48, line 12.  I think it should be "resolved."

25             JUDGE DELVOIE:  I would -- I would think that these kind of small


Page 10033

 1     errors would be corrected automatically with the second reading of the

 2     record, but okay.

 3             Move on, Mr. Stringer.

 4             MR. STRINGER:

 5        Q.   Mr. Hadzic, can we at least agree that you and Arkan both shared

 6     the view that Communist generals of the JNA should be removed?

 7        A.   This has nothing whatsoever to do with each other.

 8        Q.   Let me just ask you separately.  Independent of what we've seen

 9     and of what we read in the article, just telling us today, isn't it true

10     that you and Arkan both advocated and supported removing the communist

11     generals from the JNA?

12        A.   I expressed my political views and it was not my impression that

13     I was removing any generals.  I believe that the politics pursued by

14     certain heads, not only generals, who were working from the perspective

15     of Communism was detrimental for the peoples of Yugoslavia including

16     Serbs.  Arkan, on the other hand, had his own views and I never consulted

17     him on those, nor he ever shared his views with me.

18        Q.   Let's go back now to Mr. Paroski.

19             MR. STRINGER:  This is P240.  The 65 ter is 4904.1.  This is

20     video footage.  We'll wait for the interpreters.

21             JUDGE DELVOIE:  And the tab number being, Mr. Stringer?

22             THE INTERPRETER:  We are ready.

23             MR. STRINGER:  Tab number is 448.

24             JUDGE DELVOIE:  Thanks --

25             MR. STRINGER:  -- no, I apologise.  1052.  1052.


Page 10034

 1             THE INTERPRETER:  The interpreters are ready to start.

 2                           [Video-clip played]

 3             THE INTERPRETER: [Voiceover] "On this occasion I want to point

 4     out one historical fact.  Croats who live here came to your fields and to

 5     your homes.  Pavelic colonised them here because they were good butchers.

 6     They still live here.  The Hungarians here don't wish to be the same as

 7     those in Backa because they primarily serve Tudjman.  This is Serbian

 8     land and they must realise that they are the intruders, and it will be

 9     highway for them if it is not our way.  They are perpetually trying to

10     put us down, to destroy our borders and our graveyards.  Hungarians fear

11     to dig up medieval archeological finds because all they will find are

12     Serbs.  This is the truth.  Whoever tells you that this is his land is an

13     usurper, and you have the right to kill him like a dog because he has

14     come to a foreign land.

15             "Seselj:  As far as we are concerned, Croats can leave Yugoslavia

16     whenever they please.  But they will not take one foot of the Serbian

17     land with them.  Not one foot that holds Serbian villages, destroyed

18     churches, Serbian death pits, death camps, Serbian Jasenovac.  If we

19     allowed that, we would be unworthy of our glorious ancestors and we

20     should feel ashamed before our descendants.  Croats are free to create

21     their own state but only west of the Karlobag-Ogulin-Karlovac-Virovitica

22     line.  Anything east of that line belongs to Serbs.  We will not

23     allow ..."

24             MR. STRINGER:  That's -- that's enough.

25        Q.   Mr. Hadzic, do you know when this rally occurred, where?


Page 10035

 1        A.   I don't know when it occurred.  However, I see that it was in

 2     Jagodnjak, in a village in Baranja.  I saw that on the clip.

 3        Q.   Were you present at this rally?

 4        A.   No, I wasn't.

 5        Q.   You told us that Mr. Paroski spoke in Vukovar in June of 1990 at

 6     the rally there that you also spoke at; is that correct?

 7        A.   That was the first rally of the SDS.  He was a guest.  I don't

 8     know who had invited him.

 9        Q.   And did he express the views that he's expressed here at this

10     rally in Jagodnjak?

11        A.   Really, I don't remember his words.  I was elected the president

12     of the committee.  That was my first public appearance.  I had stage

13     fright.  I focussed on what I was going to say.  So, honestly, I don't

14     remember what other people said on that occasion.

15        Q.   Would you agree with me, sir, that language like that coming from

16     the SDS leadership could have a profoundly negative impact on the

17     listening audience?  Perhaps inciting them --

18             JUDGE DELVOIE:  Mr. Zivanovic.

19             MR. ZIVANOVIC:  Sorry, may we see reference about the SDS

20     leadership mentioned in line 9 of this page, of the current page.

21             MR. STRINGER:  I'm looking at page 50, line 25.  The question:

22             "You told us that Mr. Paroski spoke in Vukovar in June of 1990 at

23     the rally there ... is that correct?"

24             The answer:

25             "That was the first rally of the SDS.  He was a guest."

 


Page 10036

 1             I will re-clarify or re-ask the question, Mr. President.

 2             JUDGE DELVOIE: [Microphone not activated]

 3             MR. STRINGER:

 4        Q.   The question, Mr. Hadzic, then, is if Paroski or anyone speaking

 5     at an SDS rally were to express the views that we've just heard, isn't it

 6     likely that would have a profoundly strong impact and could in fact

 7     incite the Serbian population to take action against non-Serbs in their

 8     areas?

 9        A.   Mr. Paroski and I were not members of the same political party.

10     He was a member of some people's party in Serbia and he was a deputy in

11     Serbia; whereas Vojislav Seselj was a member of the Serbian Radical

12     Party.  They both hailed from Serbia.  They were not SDS members.  Just

13     the contrary.  They were its political opponents.  I can't say anything

14     about their political views.  I don't know about this rally in Jagodnjak.

15     I don't know who organised it.  In any case, I was never invited to

16     attend it.

17             MR. STRINGER:  Mr. President, I believe we need to go into

18     private session.

19             JUDGE DELVOIE:  Private session, please.

20                           [Private session]

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)


Page 10037

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11 Pages 10037-10039 redacted. Private session.

12

13

14

15

16

17

18

19

20

21

22

23

24

25

 


Page 10040

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4                           [Open session]

 5             THE REGISTRAR:  We're in open session, Your Honours.

 6             MR. STRINGER:

 7        Q.   Mr. Hadzic, during your direct examination, you were shown a

 8     couple of remarks made Mr. Zivota Panic concerning yourself and Arkan; do

 9     you recall that?

10        A.   I do.

11             MR. STRINGER:  Could we have tab 459, please; Exhibit P01845.

12     Page 68 of the English.  Page 62, 63 of the B/C/S.

13        Q.   Mr. Hadzic, this is the record of the SFRY Presidency held in

14     April of 1992, the 16th.  Do you recall what Mr. Panic's position was at

15     that time?

16        A.   I think that he was the commander of the 1st Military District,

17     but I'm not 100 per cent sure about it.

18        Q.   We can go back to -- page 2 of this indicates that at that time

19     of this meeting he was the acting chief of the General Staff or chief of

20     the Main Staff of the JNA.  Would you disagree with that?

21        A.   I agree.  I'm just a bit confused.  I knew that he was appointed

22     the commander of the 1st Military District but I didn't know that he was

23     appointed commander.

24        Q.   Now moving to page 68 of the English, I'll ask you just one or

25     two questions before the break.

 


Page 10041

 1             Top of page 68, Mr. Hadzic, there's a reference here, and for the

 2     record, this is Zivota Panic speaking.  We can see that starting at

 3     page 66.  He's talking at page 67 and then on to 68.

 4             He is saying that:  Even today there are cases of people being

 5     expelled by force from Lovas village and from Vukovar, attempts to do the

 6     same with Ruthenians, Czechs, et cetera, but we put a stop to that in an

 7     effective way in Ilok.  However, Lovas is constantly being watched by

 8     Jovic's Chetniks.  They go there and frighten them.

 9             My first question, Mr. Hadzic, is:  Here Mr. -- Commander Panic

10     in Belgrade, chief of the Main Staff --

11             MR. ZIVANOVIC:  It seems that B/C/S text doesn't match to the

12     English text.

13             MR. STRINGER:  Mr. President, if it's time for the break, I can

14     sort it out over the break.

15             JUDGE DELVOIE:  It's a little bit early, but -- oh.  No.  It is

16     exactly the time for the break.  Sorry about that.

17             Court adjourned.

18                           --- Recess taken at 12.15 p.m.

19                           --- On resuming at 12.45 p.m.

20             JUDGE DELVOIE:  Please proceed, Mr. Stringer.

21             MR. STRINGER:  Thank you, Mr. President.

22        Q.   Mr. Hadzic, before the break, we were looking at P01845.

23             MR. STRINGER:  And indeed the page of the B/C/S that we wanted is

24     page 62 of the document in B/C/S, which is -- ends with the ERN number

25     4965.  And toward the bottom -- that's it.  Thank you.


Page 10042

 1        Q.   Toward the bottom -- I should say the bottom third, Panic is

 2     talking here about the expulsions in Lovas and that Lovas is constantly

 3     being watched by Jovic's Chetniks, the White Eagles.

 4             Now, Mr. Hadzic, Zivota Panic knew about this.  It's your

 5     evidence that you didn't know anything about Mr. Jovic's activities and

 6     those of his White Eagles in Lovas during this period?

 7        A.   Yes, that's what I said, that I didn't know anything about it.

 8        Q.   Well, in April of 1992 when this is happening, it was possible

 9     for you to go to this area, isn't it?  You were able to move down through

10     Western Srem?

11        A.   Yes, it was the Republic of Serbian Krajina at the time, and it

12     was all free.

13        Q.   And then in the next paragraph, he says that we must have a

14     serious showdown with Arkan and the White Eagles.  He says:

15             "Arkan is led by Hadzic."

16             Now, Mr. Hadzic, again, my question is, I think you've commented

17     on this already, why would -- if you know, why would Zivota Panic have

18     this mistaken view about you and Hadzic [sic]?

19             JUDGE DELVOIE:  Yes, Mr. Zivanovic.

20             MR. ZIVANOVIC:  Sorry, may we move to the next page of B/C/S?  I

21     think that it corresponds to the English text on the screen.

22             JUDGE DELVOIE:  Okay.

23             MR. STRINGER:

24        Q.   The question was whether you know what would be the basis for the

25     chief of the JNA Main Staff to have a mistaken view about you and Arkan


Page 10043

 1     in April of 1992.

 2        A.   I can just assume that Zivota Panic did not want to tell the

 3     truth and that it was not all in keeping with the responsibilities of the

 4     Yugoslav People's Army.  Because he said that all units that were under

 5     the JNA.  And then about two months ago when I received the documents,

 6     both from the Defence and the Prosecution, in order to prepare, there

 7     were at least four places where Panic decisively said that anybody who

 8     was there armed but not under the jurisdiction of the army will be thrown

 9     out of Baranja and Western Srem.  So if we carefully read the minutes of

10     the meeting that we are discussing, you can see who is issuing orders and

11     controlling the actions of Zeljko Raznjatovic and definitely that was not

12     Goran Hadzic.

13        Q.   I'm not asking about that, Mr. Hadzic.  I'm simply asking you,

14     I'm suggesting to you, in fact, that Zivota Panic's statement here is in

15     fact the accurate one.  That you were led by -- that Arkan was led by you

16     and that you've brought Arkan with you as some sort of body-guard.  In

17     fact, you were closely associated with Arkan during this period in early

18     1992 when you had become president of the RSK.  Isn't that true?

19        A.   That is not true.  He is making that assumption and manipulating

20     with the fact that Arkan was there during our visit to Velepromet and

21     that he was leading the security in Velepromet.  And that's why he wanted

22     to actually defend himself and say that he was led by Hadzic.  I didn't

23     know what Arkan was doing, and I wasn't in charge of that at all.

24        Q.   Well, in April of 1992, around the -- the date of this meeting,

25     in fact, as we have seen, you, Arkan and others were all together down in


Page 10044

 1     Bijeljina in Bosnia-Herzegovina.  That occurred about the same time as

 2     this meeting.  Isn't that true?

 3        A.   I don't know that date.  I explained why I was in Bijeljina and

 4     who had invited me.  And Arkan was already there before I arrived.  I was

 5     invited by Fikret Abdic and Biljana Plavsic so that we could agree on

 6     some problems that we had regarding free passage from Serbia to Knin,

 7     because the so-called corridor was problematic.

 8        Q.   And so it's like, then, the meeting you described in Belgrade

 9     where General Simovic invited you to come to the meeting, and then when

10     you arrived, it turned out that Arkan was there as well.  Is it sort of a

11     similar situation?

12        A.   Obviously it was Simovic who had invited Arkan.  Because Arkan

13     was already there with Biljana Plavsic.  I heard later that he was in the

14     area for five, six, or ten days.  I don't know exactly for how long.

15        Q.   Okay.  Let's clarify that.  I was asking you -- I was referring

16     to the Belgrade meeting that you've talked about earlier in the fall of

17     1991.  You said earlier today that General Simovic invited you to that

18     meeting and then when you arrived, it turned out that Arkan was there,

19     along with this gentleman Kum.  Do you remember that?

20        A.   I do, yes.

21        Q.   Now, are you saying that it was General Simovic who also invited

22     you to attend the meeting in Bijeljina that Ms. Plavsic was present at?

23        A.   No, no, I didn't say that.  These are two completely different

24     things.  It's only that you are trying to put them together.  But,

25     actually, no, it's a -- it's a mistake.


Page 10045

 1        Q.   Actually, Mr. Hadzic, there may be indeed be a mistake.  I'm just

 2     looking at page 60, line 5, and what we're given is your words:

 3     "Obviously it was Simovic who had invited Arkan.  Because Arkan was

 4     already there with Biljana Plavsic."

 5             So the question -- my question is or should have been:  Do you

 6     know that in fact Simovic invited Arkan to the meeting at Bijeljina?

 7        A.   No, no.  That's not that.  I can see page 60, line 2, that

 8     Simovic invited Arkan.  I was thinking about the meeting in Belgrade in

 9     1991.  But this is a new sentence, where Arkan was

10     already with Biljana Plavsic in Bijeljina, but those two things are not

11     related.  Perhaps I made a mistake and I didn't speak precisely enough,

12     but I think now it's clear.

13        Q.   Who invited you to Bijeljina?

14        A.   I came to there -- at the invitation of Fikret Abdic and

15     Biljana Plavsic or, actually, the former government secretary, Pejakovic

16     said that they were asking for me in Erdut.  I wasn't in Knin.  My chef

17     de cabinet was in Knin and passed on the message that they wanted me to

18     come to a meeting in Knin.  I don't remember the time and the date

19     anymore.  But Pejakovic wasn't the government secretary anymore but they

20     were looking for me there.  They thought perhaps that I was there.

21             MR. STRINGER:  Well, Mr. President, just for the record, and

22     maybe I should clarify this.

23        Q.   Mr. Hadzic, again, just to be clear on this, at the bottom of

24     line -- top of 61, you said:  "I was thinking about the meeting in

25     Belgrade in 1992 ..."


Page 10046

 1             Just to clarify this, we've been talking about the Simovic-Arkan

 2     meeting you were present with Kum.  Is it correct that that occurred

 3     sometime in the fall of 1991?

 4        A.   Yes, yes, that's correct.  It should say 1991, not 1992.

 5        Q.   And then if I were to suggest to you that the Bijeljina meeting

 6     in which you were present with Plavsic and Arkan and Fikret Abdic, that

 7     occurred in approximately April of 1992?

 8        A.   April or May possibly.  I'm not sure.

 9             MR. STRINGER:  Could we have, please, P01878, tab 531.

10        Q.   Mr. Hadzic, while it's coming up, this is the Supreme Defence

11     Council of the FRY in July of 1992, about three months after the meeting,

12     the Presidency meeting we were just talking about.  Zivota Panic present

13     there.  And I would direct your attention to page 14 of the English,

14     16 of the B/C/S.

15             And here now in July of 1992, Panic is saying:

16             "Many things had been said about Arkan, measures had been taken.

17     However, you should look for Goran Hadzic to find out what Arkan is

18     doing; he keeps him around as a body-guard and he leads him."

19             And then in the next passage, Momir Bulatovic says essentially

20     that Arkan is getting stronger again:

21             "That means someone is behind these people."

22             The question now, Mr. Hadzic, is again here in July of 1992, it's

23     Zivota Panic who is correct, isn't it, that in fact if somebody wanted to

24     know where Arkan was and what he was doing, they just should find you

25     because Arkan was close to you as a body-guard?


Page 10047

 1        A.   Panic was defending himself.  I explained that before, because

 2     it's the same meeting perhaps or the one before.  There were two

 3     meetings.  But he is saying the same thing in order to conceal his own

 4     responsibility.

 5        Q.   And it's your view that he would be making these false statements

 6     at a meeting of the Supreme Defence Council?  This is not a public

 7     statement.  This is a private meeting of the Serbian -- or the FRY

 8     Supreme Defence Council.  So, in fact, this is a forum in which he would

 9     be speaking freely and candidly.  Isn't that true?

10        A.   You have anticipated what I wanted to say, that this was no

11     debate.  It was a very senior place where people who could make decisions

12     sat in order to deal with Arkan.  That is why he avoided telling the

13     truth and avoided dealing with it.  Because he continues to say - perhaps

14     in this text or the previous one - he said that Arkan is good, that he

15     carried out tasks, and that the people who sent him there should be

16     contacted to have him withdrawn.  It has nothing to do with Goran Hadzic,

17     as you can see from the rest of the text.

18             MR. STRINGER:  Could we have P1908, tab number 656.  English

19     page 61, B/C/S page 52.

20                           [Trial Chamber and Registrar confer]

21             JUDGE DELVOIE:  This seems to be a confidential document,

22     Mr. Stringer.  Should we go into private session or --

23             MR. STRINGER:  Yes, Your Honours.

24             JUDGE DELVOIE:  Private session?

25             MR. STRINGER:  Thank you.

 


Page 10048

 1             JUDGE DELVOIE:  Private session, please.

 2                           [Private session]

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

19   (redacted)

20   (redacted)

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22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)


Page 10049

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15                           [Open session]

16             THE REGISTRAR:  We're in open session, Your Honours.

17             JUDGE DELVOIE:  Thank you.

18             MR. STRINGER:

19        Q.   On the 9th of July, and I'm looking at transcript page 9584,

20     Mr. Hadzic, you were asked about when you actually went to Dalj in early

21     August 1991, after it was taken by Serb forces.  You said that:

22             "In the beginning of August, maybe seven or six days after the

23     1st of August, I came to Dalj ..."

24             And that's when you began to set up your office.  Do you recall

25     that?

 


Page 10050

 1        A.   I do.

 2        Q.   You were asked when did you first meet Radovan Stojicic, Badza.

 3     And this is the same page of the transcript, 9584.  You said:

 4             "Quite soon after my move to Dalj while I was on those large

 5     premises.  Perhaps on the third day after I moved there, maybe the

 6     seventh day, but it was, in any case, in the first half of August."

 7             Is that your evidence?

 8        A.   Yes, I think I said it was up to mid-August at the latest.

 9        Q.   And he arrived at your office, introduced himself, and he said he

10     was a high-ranking official of the MUP Serbia and that he came to take

11     over the Territorial Defence.

12        A.   Yes.  He said that he was a senior official of the Serbian MUP

13     and that he was going to be the commander of the SBWS Territorial

14     Defence.

15        Q.   And that you also indicated last week, Mr. Hadzic, that Badza was

16     accompanied by two individuals, one named Zavisic and the other named

17     Bogunovic; do you recall that?

18        A.   I do.  I think later on I also said that Zika Trajkovic was there

19     as well.  I saw him there for the first time.  I knew Zavisic and

20     Bogunovic from the Danube because they used to be there.

21        Q.   You had dealings with Zavisic and Bogunovic.  When you say on the

22     Danube, this was when you and your TO commander Mr. Kojic were working to

23     bring volunteers across into the SBWS.  Isn't -- isn't that how it was?

24        A.   I don't recall having said that I ever organised volunteer

25     transport.  I've never done that.


Page 10051

 1        Q.   You were present on the Serbia side of the Danube, and this is

 2     when you encountered Zavisic and Bogunovic.  Isn't it true that this was

 3     related to either bringing personnel or equipment into the SBWS?

 4        A.   No.  No, you misunderstood.  Nebojsa Bogunovic was a Serb

 5     policeman who was on duty and at the helm of a police group which was

 6     permanently stationed at the Danube.  No one could cross over without

 7     their permission.  Zavisic was his boss who came there every now and then

 8     but it only had to do with civilians crossing.  That is what they

 9     controlled.  I don't know anything about any equipment or volunteers.

10        Q.   Okay.  And then you have also indicated in your direct

11     examination that at the same time, the same meeting, Badza was

12     accompanied by Zeljko Raznjatovic, Arkan.  Is that your evidence?

13        A.   Yes, it is, and that is true.  Arkan was equipped the same way

14     they were.  Only his uniform was different.

15        Q.   And then just to continue on, I wanted to clarify this,

16     page 9588, you were asked about when Stojicic, Badza, and Arkan, and

17     their men were accommodated in Erdut.

18             And then in your direct evidence you were talking about when you

19     first went there and found accommodation for yourself.  And then you

20     indicated that you'd spent a few nights there and then within about 15 or

21     20 days, Arkan and Badza showed up.

22        A.   Yes, that is how it happened, more or less, as far as I recall.

23        Q.   So just to clarify, is it your evidence that they came together -

24     this is Badza and Arkan - came together to meet you in Dalj in August

25     sometime, by mid-August, and that they also then came together when they


Page 10052

 1     took over the training centre facility in Erdut?

 2        A.   The first part of your question is correct.  They did coming

 3     together.  They showed up in Dalj.  Badza introduced himself and

 4     introduced his associates.  I don't know, though, whether they arrived on

 5     the same day.  I wasn't in Erdut when they came.  I wasn't in Erdut at

 6     that moment.  I don't know whether they came together or separately, but

 7     I do know they were in contact there and that they were found

 8     accommodation there at the same time.

 9             MR. STRINGER:  Okay.  Could I please ask for 65 ter 4974.02E, and

10     we can put the -- perhaps we could run the video.  This is from the

11     suspect interview.  It's got a couple of points I wanted to ask

12     Mr. Hadzic about.

13             And, again, we don't need interpretation.  I think we can just

14     led the video run.  It may be necessary to turn up the -- the volume on

15     Mr. Hadzic's headset, however.  I think this was one where it was kind of

16     low.

17                           [Video-clip played]

18             MR. STRINGER:

19        Q.   Mr. Hadzic, is it true, as you indicated in your suspect

20     interview with Mr. Dzuro, that Stojicic's appearance at your government

21     sessions provided you and your government the opportunity to raise

22     civilian issues with him and to get assistance from him, as commander of

23     the TO, concerning communications, transport, permits for travelling,

24     et cetera.  Did he provide this assistance to you as you've indicated?

25        A.   Sometimes with regards to technical matters.  But generally


Page 10053

 1     speaking, we had that problem with the JNA.

 2        Q.   And, really, what's happening when Badza, Stojicic, comes to a

 3     government session, a session of the SBWS government, is you're all

 4     essentially acting within the parameters of the SFRY law as concerns

 5     civilian authorities and the Territorial Defence.

 6             I can give a more precise clarification.  Let me put it to you

 7     this way.  In the SBWS during this period, in late 1991, you were wanting

 8     to be a part of Yugoslavia and so you were essentially applying

 9     Yugoslavia law, SFRY law in respect of the armed forces, the Law on Armed

10     Forces, the role of the TO, et cetera.  Isn't that how it was?

11        A.   You have to take into account that the government was still being

12     established.  Throughout 1991, that government did not become fully

13     operational.  Throughout the period we had one phone line, two cars, and

14     no resources.  So we did want to be part of the SFRY, that is correct.

15     But I was not versed in matters of law and regulations, hence, I did not

16     tackle that issue per se.

17        Q.   Well, you knew how the SFRY Law on Armed Forces operated in

18     general terms.  You knew that Yugoslavia armed forces consisted of the

19     JNA, on one side, and the TO, the Territorial Defence, on the other.  You

20     knew that; correct?

21        A.   I knew that things were such in peacetime, but I also knew that

22     in war time it was all the JNA.  I wasn't aware of any divisions.  And I

23     think nothing was divided in that regard.  The unity of command principle

24     was in place.

25        Q.   And you knew that under the SFRY Law on Armed Forces, the TO


Page 10054

 1     did -- I'll say the SBWS TO, did fall within the chain of command or was

 2     subordinated to the JNA for its military operations.  That's how it

 3     worked under the law.  Did you know that?

 4        A.   I did know that.  But not only in military operations.  For me,

 5     it meant it was completely subordinated to the JNA in every respect, even

 6     when there were military operations under way, as well as when there

 7     weren't any.

 8        Q.   You know that under the SFRY law, there was a JNA and then there

 9     were individual republican TOs; correct?

10        A.   Yes.  It was a matter of general knowledge.  It was so before

11     1991.

12        Q.   And then, of course, in Croatia, the situation was much more

13     complicated because the Croatian TO obviously was not going to be

14     participating in armed conflict against its own National Guard forces.

15     And so what happened was the SBWS TO actually then stepped into the role

16     of what would have been the republican TO under the Law on Armed Forces;

17     correct?

18        A.   Well, I would not agree, since we are touching upon both a legal

19     and military matter.  In the SBWS, the former Croatian TO structures were

20     not in place.  It's not as if the Croats separated.  It was just an

21     unorganised group of people that under the constitution had the

22     obligation to defend the constitutional order of that state, and this

23     went as far as to include chess clubs and sport clubs.  At first they

24     were called local defence staffs for village defence, and later, it was

25     renamed, once Badza came as TO commander.  However, it was still all


Page 10055

 1     under the JNA.

 2        Q.   And the role that the SBWS TO played was essentially the role of

 3     a republican TO.

 4        A.   No, it wasn't the case.  No republican structures were left in

 5     place including municipal ones.  At least not in any organised way.  I

 6     just said that village staffs were set up that were completely

 7     independent of each other in order to organise guard duty in villages to

 8     defend them, and one cannot refer to it as the Croatian TO.  We simply

 9     took upon ourselves this constitutional obligation to defend our state

10     that was under attack and it was part of the SFRY.

11        Q.   We may be misunderstanding each other, Mr. Hadzic.  I'm not

12     asking you about the Croatian TO.  And I know it's a complicated subject.

13     I'm asking you about the TO of the SBWS that was under the command of

14     Ilija Kojic and then, later, Radovan Stojicic.  That body essentially

15     stepped into the shoes of a republican TO because in Croatia at the time,

16     it was absurd to even think about the concept of a Croatian TO that was

17     going to fight in order to uphold the constitution of the SFRY.  Can we

18     agree on that?

19        A.   As regards this part about Croatia, we can agree.  But I cannot

20     comprehend it fully because the situation was not such in the field, at

21     least not in the Serbian part.  We did not continue working on the basis

22     of the Croatian TO, which was then only to be found in

23     Croatian-controlled areas.  We did not have a single body of that TO that

24     would have moved to our side.  I don't know a single person who had been

25     employed by the Croatian TO who joined our side.  I wasn't aware of any.


Page 10056

 1        Q.   No, and I'm not suggesting that there was.  I'll move on.  If we

 2     could back to the video footage that we just saw of your interview with

 3     Mr. Dzuro, perhaps you noticed, Mr. Hadzic, that in the video, you

 4     indicated that Badza arrived, Stojicic arrived in September, as you say:

 5             "As far as I can remember it can be somewhere around the 15th of

 6     September, maybe before that."

 7             Now, recognising that you've indicated here you weren't certain

 8     of the date, you do put it, though, about a month earlier than what

 9     you've told us in the trial just the other day.  It seems quite a large

10     shift from what you said before to what you are saying now.

11        A.   What I'm saying now is true.  It was corroborated by some

12     witness, your witnesses, who said so themselves here.  There, I was

13     wrong.  I said September instead of August.  So the question took me by

14     surprise and I didn't think carefully.  I tried to link things as the

15     question came on and tried to remember when I was in Dalj, but I wasn't

16     in Dalj any longer in mid-September.  He couldn't have come there at the

17     time.  I was in Dalj in August.  That is obvious.  However, I obviously

18     made a mistake.  I went off by a month when I provided my answer to

19     Mr. Dzuro.

20        Q.   Also, Mr. Hadzic, here you haven't indicated at all that when he

21     did arrive, Stojicic was accompanied at that moment by

22     Zeljko Raznjatovic, Arkan.  And I'm going to put to you, sir, that the

23     reason didn't mention that, either here or anywhere else in your suspect

24     interview, is because they did not arrive together on that day in

25     August or September.  In fact, they came separately and you met them both


Page 10057

 1     at different times.  Isn't that true?

 2        A.   That is not true.  I think it can easily be proven.

 3        Q.   Now, just a little while ago you said, the bottom of page 67,

 4     line 23, you don't know whether they came separately -- sorry, you don't

 5     know whether they came together or separately.  And this is in -- in

 6     regard to the accommodation in Erdut.  You said:

 7             "I don't know whether they arrived on the same day.  I wasn't in

 8     Erdut when they came.  I wasn't in Erdut at that moment.  I don't know

 9     whether they came together or separately, but I do know they were in

10     contact there and that they were found accommodation there at the same

11     time."

12             Now, here I'd like to direct you to another part of your

13     interview with Mr. Dzuro.

14             MR. STRINGER:  And this is tab 1083, 65 ter 0497 -- sorry.

15     04974.03.  Perhaps we can just go with the transcript on this one.  It's

16     page 86, 89.  Actually, page 89.

17                           [Prosecution counsel confer]

18             MR. STRINGER:  Actually, maybe English 28 and B/C/S 22.

19     Tab 1084.

20        Q.   Mr. Hadzic, what we're looking at in middle of the page of the

21     English, I think farther down to the bottom of the B/C/S, you're

22     mentioning Lastavica Dragomir stayed there, supplier of the kitchen.  And

23     then you say:

24             "... and then Badza came totally independently from Arkan and he

25     took a whole floor because there was a building ... with two floors."


Page 10058

 1             And then you go on to indicate when you arrived in Erdut as

 2     opposed to Arkan and Badza.

 3             So again, Mr. Hadzic, what we're seeing here is a significant

 4     inconsistency with what you have said in this trial.  Just a few minutes

 5     ago, you weren't in Erdut.  You weren't present.  You don't if they came

 6     together or separately.  Although in the suspect interview in 2002, you

 7     quite clearly indicate that they came totally -- that Badza came totally

 8     independently from Arkan.

 9             So do you remember it better today, Mr. Hadzic, than you did back

10     in 2002, or is it quite possible that what you said to Mr. Dzuro is

11     correct, they came independently?

12        A.   I did not say even today that I remembered whether they came

13     together or separately.  However, if they came separately, that was

14     within the space of one or two days.  I was not in Erdut all the time.  I

15     just spent the night and then I left.  So after the first time I

16     returned, I saw that they were both there.  I didn't see them arriving

17     either together or separately.

18             Now, whether I was more precise in my interview with the

19     investigator, I don't know.  I'm not sure whether they came together or

20     separately because I did not see them arriving either together or

21     separately.

22             Could you please tell me the date of the interview that we saw

23     just a while ago, precisely this video-clip?  What -- what's the date of

24     that interview?

25        Q.   It would have been in early March 2002.  It's part of the suspect


Page 10059

 1     interview.  I can give you the precise date if you want to look at that

 2     portion again.  I don't have it with me at the moment.

 3             As you recall, Mr. Hadzic, the interview occurred over several

 4     days.

 5        A.   Yes, yes, I remember.  However, all I need to know whether that

 6     was before the break or after the break that we made.

 7        Q.   I'd like to take you to page 9589 of the transcript.  Your

 8     counsel was asking you about Arkan and Badza at the training centre

 9     facility.  And you said:

10             "During the day, they were not there.  At least not by the time I

11     got up.  But when I came at night to spend the night there, I saw them

12     sitting together because the stairs that I used to go upstairs to my room

13     overlooked that large mess room.  I didn't spend nights there often, but

14     I did see them once or twice."

15             MR. STRINGER:  If we could please have 65 ter 6254, which is

16     tab 1524.

17        Q.   Mr. Hadzic, you've seen this aerial before.  It's been used

18     throughout the trial as an aerial image obviously from above of the area

19     of the government offices and the training centre.  In looking at it, are

20     you able to orientate yourself?

21        A.   No, I -- I'm not able to do that.  I don't see the road.  I can't

22     say where the main entrance is.  There's nothing to tell me that.

23        Q.   Are you able to indicate or to see what would have been the

24     location of your office?

25        A.   I'm not even sure where the winery is, where the TO centre is, or


Page 10060

 1     where the manor is.  I really can't recognise any of those buildings.  If

 2     I were sure about just one of those buildings, then I would be able to

 3     recognise the others as well and tell you what -- what happened or what

 4     was going on in any of them.

 5             MR. STRINGER:  Could we have P01046.  Tab 1652.  It's possible

 6     this came in in closed session, although I don't know that showing it

 7     publicly would identify the witness.

 8                           [Trial Chamber and Registrar confer]

 9             JUDGE DELVOIE: [Microphone not activated]

10             MR. STRINGER:  I don't know if it's possible to blow it up at all

11     so that we can see it a bit better.

12        Q.   Mr. Hadzic, this is one of the ones, a photo that one of the

13     witnesses marked on.  And he's indicated that the area with the letter

14     A -- well, let me try it this way.

15             Do you see, Mr. Hadzic, toward the upper right, there's a section

16     that's got a circle around it that has an X covering it?

17        A.   I can see that.

18        Q.   And then moving down, there's another circle or half of that

19     circle that has a letter A in it; do you see that?

20        A.   Yes.

21        Q.   Would it appear to you, sir, that that would correspond roughly

22     to the area of the training centre where Arkan was based?

23        A.   It is possible, yes, it is.

24        Q.   And then moving up and to the left, you see there's a letter G

25     that corresponds to a circle and also letter F -- F.  Would that


Page 10061

 1     correspond to the location of your office and the government offices of

 2     the SBWS government?

 3        A.   Yes.  If A denotes the TO centre, then G could be the manor, and

 4     F could be the apartment where I slept.

 5        Q.   Can you tell us approximately how many metres it was between the

 6     training centre and the apartment where you slept.

 7        A.   Around 150 metres.

 8        Q.   Now, in your testimony last week, you said that you saw "Badza

 9     and Arkan sitting together because the stairs that I used to go upstairs

10     to my room overlooked that large mess room."

11             And I wonder whether you can describe for us the location of the

12     mess room that you referred to in your testimony.

13             MR. STRINGER:  I don't know if it's possible for us to mark on

14     this, but if it is --

15        Q.   Perhaps you could do it, Mr. Hadzic, if you're able.

16        A.   I apologise.  I don't remember that I used the word "mess room."

17             If that's how it was interpreted, then it's a mistake.  It was

18     not a mess room because a mess room was in a separate building.  It was

19     like a restaurant.  When I said that I climbed those stairs and that I

20     saw them sitting together, they were sitting in a meeting room on the

21     ground floor of the building where bedrooms were.  It was not a mess

22     room.  It was a meeting room.  It was a small room whose size was

23     approximately 3 by 5 metres.  It was an open-plan room.  There was no

24     partition wall between that room and the staircase, so as I walked up the

25     stairs, I could see them sitting together.


Page 10062

 1        Q.   Could you indicate for us with the pen, Mr. Hadzic, the -- the

 2     stairs that you've just mentioned.  The stairs -- where's the location of

 3     the stairs that you would go up and see them?  The staircase.

 4        A.   The TO centre was quite a large area that consisted of several

 5     buildings.  The building where I slept would be at the top of that circle

 6     denoted by letter C.  We can't see the building here, however, but it

 7     would be somewhere here or thereabouts.  At the very top.  To the left.

 8             The pen doesn't seem to be working properly.  I did not mark

 9     where I wanted to mark.

10             MR. STRINGER:  I'm going ask if Mr. Hadzic can mark the location

11     he's just described.  The building where he slept at the top of the

12     circle denoted by the letter C.

13             JUDGE DELVOIE:  It seems the pen doesn't work so we will have to

14     assist Mr. Hadzic.

15             MR. STRINGER:  Perhaps with the ...

16             THE WITNESS: [Interpretation] Yes.  The blue mark should be about

17     half a centimetre further towards the top of that circle.

18                           [Trial Chamber and Registrar confer]

19             MR. STRINGER:

20        Q.   Okay.  Is it possible now with the same blue pen you could just

21     indicate how you would walk from your office in the government building

22     over to this location you've just marked where you slept?

23        A.   You mean where I slept later or when I was in the centre?

24        Q.   Right.  When you were in the centre.  We'll talk about the other

25     one later.


Page 10063

 1        A.   Well, the first bit would be the same.  I had to pass by that

 2     apartment.  And this would be more or less the way I had to walk.

 3        Q.   And then when you said that you would see Arkan and Badza sitting

 4     and talking, that was at the location down next to the letter A at the

 5     bottom?

 6        A.   No.  The entire area encircled and denoted by the letter C is

 7     very large.  At least 100 metres by 100 metres.  According to what I

 8     remember, there were at least four buildings, and I saw them there only

 9     once or perhaps twice.  I did not see them there often.  Perhaps I only

10     saw them once, actually.

11        Q.   And just a moment ago you indicated -- you made a reference to

12     where you slept later.  And just to be clear, what you've indicated for

13     us so far is the place where you would sleep at the beginning, during the

14     early period?

15        A.   Yes.  I indicated where I slept when I arrived there for the

16     first time in early September.  There were some other ministers who also

17     slept there.

18        Q.   And, again, this is the spot that you've marked that is sitting

19     next to the -- the red letter A?

20        A.   Yes.

21        Q.   And then how long did you use that place to sleep?

22        A.   I don't know for how long I stayed, but I arrived and slept there

23     on perhaps five or six occasions all together.  Throughout the month of

24     October, I did not spend a single night in the territory, as far as I can

25     remember.

 


Page 10064

 1        Q.   And then in your testimony from last week, you said:

 2             "But then I moved to a flat.  I moved to a flat which was next to

 3     the building that was used by the government for its sessions.  It was a

 4     manor building."

 5             And so now is that a reference to a different place where you

 6     would sleep when you stayed there?

 7        A.   Yes.

 8        Q.   Can you indicate with a letter X approximately the location for

 9     that.

10        A.   [Marks]

11        Q.   Thank you.

12             MR. STRINGER:  Mr. President, we tender that into evidence.

13             JUDGE DELVOIE:  Admitted and marked.

14             THE REGISTRAR:  Exhibit P3212.

15             JUDGE DELVOIE:  Thank you.

16             MR. STRINGER:  Mr. President, may we move into private session.

17             JUDGE DELVOIE:  Private session, please.

18                           [Private session]

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)


Page 10065

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11 Pages 10065-10067 redacted. Private session.

12

13

14

15

16

17

18

19

20

21

22

23

24

25

 


Page 10068

 1                           [Open session] 2             THE REGISTRAR:  We're in open session, Your Honours.

 3             JUDGE DELVOIE:  Okay.  This is as far as we go for the day.

 4     Mr. Hadzic, you're still under oath.

 5                           [Trial Chamber and Legal Officer confer]

 6             JUDGE DELVOIE:  Madam Registrar, the document D127 should be

 7     under seal.

 8             And that's all for the day.  Court adjourned.

 9                            --- Whereupon the hearing adjourned at 2.00 p.m.,

10                           to be reconvened on Tuesday, the 22nd day of July,

11                           2014, at 9.00 a.m.

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