1 Monday, 27 March 2006

2 [Open session]

3 [The accused entered court]

4 --- Upon commencing at 9.06 a.m.

5 JUDGE MOLOTO: Yes, Mr. Whiting.

6 MR. WHITING: Good morning, Your Honour.

7 JUDGE MOLOTO: Good morning.

8 MR. WHITING: We just have one procedural matter that we wanted to

9 raise before calling the witness, and it requires us to go into private

10 session.

11 JUDGE MOLOTO: May the Chamber please move into private session.

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18 [Open session]

19 THE REGISTRAR: We are in open session, Your Honours.

20 JUDGE MOLOTO: Thank you very much.

21 Ms. Richterova.

22 MS. RICHTEROVA: Good morning, Your Honours. The Prosecution

23 calls another witness, Vlado Vukovic.

24 [The witness entered court]

25 JUDGE MOLOTO: May the witness please make the declaration.

1 THE WITNESS: [Interpretation] I solemnly declare that I will speak

2 the truth, the whole truth, and nothing but the truth.

3 JUDGE MOLOTO: Thank you very much. You may be seated,

4 Mr. Vukovic.

5 WITNESS: VLADO VUKOVIC

6 [Witness answered through interpreter]

7 Examination by Ms. Richterova:

8 Q. Mr. Vukovic, are you able to follow me in the language you

9 understand?

10 A. Yes, I am.

11 Q. Can you state your full name for the record.

12 A. Vlado Vukovic.

13 Q. I am going to go through your background information just -- and

14 just ask you if you could confirm it. You were born on the 1st of August,

15 1961, in Saborsko. You graduated from secondary school in Ogulin in 1981.

16 You served your military service between 1982 and 1983. Is it correct?

17 A. Yes, it is.

18 Q. After that, you worked at the National Park at Plitvice Lakes.

19 You were there until the end of 1989, and at the end of 1990 you joined

20 police. Is it correct?

21 A. Yes, that's correct.

22 Q. You lived in Saborsko at -- at the time you joined police. Can

23 you just briefly tell us something about Saborsko. How many households

24 were in Saborsko?

25 A. In Saborsko there were about 300 households, about 300 family

1 houses.

2 Q. And how many inhabitants, approximately?

3 A. About 800 or 850, approximately.

4 MS. RICHTEROVA: Your Honours, I would like to refer you again to

5 the atlas, Exhibit 23. On page 20, grid A4, you can see Saborsko;

6 however, this time I would like to refer you to the previous page, page

7 19, because you will have a better picture of the whole area. And on the

8 page 19, you would see Saborsko in grid D3, and in this square you --

9 Saborsko is in the top right corner.

10 Q. Before you joined police, you work at the National Park at

11 Plitvice. Why did you leave your job at the national park?

12 A. To put it quite simply, it's quite evident why I left my job in

13 the national park in 1989. The epicentre of the evil started in Pakrac in

14 1991. The war started in Lipice park in the Republic of Croatia.

15 Q. But you left in 1989, so what made you leave at the end of 1989?

16 A. There were negative rumours going round. It started in 1987.

17 There was some kind of congress. Yugoslavia fell apart, and euphoria

18 emerged in the National Park of Plitvice. Some of us, a group of us,

19 four, saw that we were unwanted there. We had worked together all over

20 the former Yugoslavia, but now we were unwanted, so we left.

21 Q. You said "us four." What nationality are you and those three who

22 left at the end of 1989 the Plitvice area?

23 A. The three of us were Croats, and one was a Serb. And there was

24 one Bosniak who remained, he was a Bosniak.

25 Q. This Plitvice area, which ethnicity -- inhabitants of which

1 ethnicity prevail in this area? And I am referring to 1989/1990.

2 A. At Plitvice there was a majority of Serbs. I don't know how many

3 there were, but I know most people were Serbs and the rest of us were in

4 the minority. In the hotels, the staff -- well, everybody knew that, the

5 hotel staff and the people working in the companies.

6 Q. Later, at the end of 1990, you joined police. Why did you join

7 police?

8 A. I joined the police, quite simply, because new times had come.

9 The Republic of Croatia had been created. This was a time of democracy,

10 and I joined the police because in 1985, when I finished my primary

11 school, I was not considered suitable to be a policeman in the former

12 Yugoslavia, although I was best in gym classes. What was important at the

13 time, in communist times, was for you to be politically suitable, not for

14 you to be able. I did not succeed. I had good marks in school, and I was

15 the best in Zagreb in my gym classes, but I was told I hadn't passed.

16 When the Croatian state was created, then I was able to join the police,

17 and I am still a policeman.

18 Q. Do you still remember when exactly you joined the police?

19 A. The 15th of December, 1990.

20 Q. Did you take any initial course?

21 A. Yes. We were sent for training right away. There was symposia,

22 seminars, about the law on the police, the criminal code, the law on

23 traffic safety, the law on misdemeanours. And in the meantime, I was a

24 policeman on the beat and guarding various facilities.

25 Q. What was your assignment after the training?

1 A. Beat duty and patrol duty. And also for a while we guarded

2 crucial facilities. For example, railway stations, various buildings,

3 power-plants, and so on in the Republic of Croatia; everything that needed

4 to be secured.

5 Q. Where were you assigned? Which police station, in which town?

6 A. It was the police station in Ogulin. That's the former

7 municipality of Ogulin which had a police station.

8 Q. How long did you stay in Ogulin?

9 A. I stayed in Ogulin until the 1st of April, 1991.

10 Q. And where did you go after 1st of April?

11 A. We were transferred to Saborsko, where there was a police outpost,

12 because what happened on the 1st of April, 1991, meant that on the very

13 next day a police outpost was established in Saborsko.

14 Q. Can you tell the Judges, what was it what happened on the 1st of

15 April?

16 A. On the 1st of April -- you mean at Plitvice or --

17 Q. You said that what happened on the 1st of April, 1991, meant that

18 on the next day a police outpost was established in Saborsko. So there

19 was something which made you to move to Saborsko or made that the police

20 station was established in Saborsko. What was it?

21 A. Well, for the simple reason that at Plitvice there was the first

22 armed clash. The National Park of Plitvice and Saborsko are right next to

23 each other.

24 Q. So you left for Saborsko after 1st of April. Who left for

25 Saborsko; which policemen?

1 A. Twenty employees, and on the 2nd of April we established the

2 outpost from the police station of Ogulin.

3 Q. Those who left for Saborsko, were they of Croat ethnicity or also

4 Serb ethnicity?

5 A. The employees who lived and worked there were Croats, but our

6 superiors from Ogulin who issued the orders to us, the second-ranking man

7 in the Ogulin police station, was a Serb by ethnicity.

8 Q. Were you also aware of the situation at Plaski police station at

9 the time?

10 A. Yes, I knew about that situation. That was a Plaski police

11 outpost which was set up in 1990 before the Saborsko police outpost. I

12 knew about the situation, yes.

13 Q. Can you tell the Judges what was the situation in Plaski. Who

14 worked there and did anybody leave from Plaski police station after 1st of

15 April?

16 A. The people who worked in Plaski police outpost were policemen of

17 the Croatian police who were both Croats and Serbs. I wasn't there, but

18 in March the Croatian policemen who were Croats left the Plaski police

19 station, during March, as far as I know, but I didn't work there myself.

20 Q. When you were already in Saborsko, did any of these Plaski

21 policemen came to Saborsko?

22 A. Yes. They came to Plaski and Ogulin. Some went to work in Ogulin

23 and some went to work in Saborsko with us, those policemen of the Ministry

24 of the Interior who were of Croat ethnicity.

25 Q. When they arrived to Saborsko, did you learn from them what made

1 them to leave Plaski?

2 A. Yes, we did. They were supposed to sign some kind of

3 confirmation. They couldn't explain it well. There was one in the shift

4 who said that you had to sign that you would work for the Republic of

5 Srpska Krajina. That was it.

6 Q. Do you by any chance learn who asked them to -- to sign this

7 confirmation or declaration?

8 A. The declarations -- well, rallies were organised, allegedly, for

9 people to sign. Who it was who arrived from Knin, I don't know, but I do

10 know that people resisted and that there were policemen of Serb ethnicity

11 working for the Ministry of Interior of Croatia who didn't want to sign.

12 But those who were there would know better than me.

13 Q. You also mentioned that there were some rallies organised. Who

14 organised these rallies?

15 A. Well, it was the local leaders who wanted to create the Republic

16 of Srpska Krajina. Now we hear that they were local leaders in Plaski,

17 and who it was that came from Knin or other parts of the so-called

18 Republika Srpska Krajina, I don't know that. Who organised a rally in

19 Plasko, well I know that now because I've been talking to people in the

20 meantime.

21 Q. So what did you learn? Who organised it at that time? What did

22 you learn now?

23 A. In my conversations with people over coffee, we talk openly about

24 the events that happened at that time. It was the local people in Plasko

25 who called themselves - I don't know what - Martic's men. It's not clear

1 to me. Those were the local leaders. Later, when I was captured, I saw

2 what this was all about.

3 Q. Okay. We will talk about your -- the time when you were captured

4 later. Now, let's return to Saborsko. So after these policemen from

5 Ogulin and Plaski arrive in Saborsko, how many of them were they

6 altogether?

7 A. There were 20 of us in Saborsko. Twenty more or less; maybe 22,

8 18. We weren't always in full strength.

9 Q. Were there any reserve policemen?

10 A. Yes, later, ten reserve policemen were mobilised, about ten, I

11 think.

12 Q. What kinds of weapons did you have?

13 A. We active-duty policemen had long and short barrels, that means a

14 pistol 76.2 millimetres, and a rifle, Zastava rifles, 7.9 millimetres.

15 The reserve policemen only had long barrels.

16 Q. What were your duties in Saborsko?

17 A. In 1991 or --

18 Q. Yes, I'm referring to 1991, from April onwards.

19 A. I was the operative duty officer, the chief of the shift.

20 Q. What did you do? Did you set up any check-points? What kind of

21 work did you do, you, all policemen?

22 A. It was patrol and beat duty, and we did have check-points, yes, in

23 Borik, Kuselj, and towards Plitvice. Those were check-points.

24 Q. Were there any military facilities in the region? I'm not talking

25 exactly about Saborsko, but the whole region.

1 A. The closest military facility was the Licka Jasenica railway

2 station where there was a JNA barracks. It was not under our authority.

3 We could not approach it. There were large fuel depots there. This

4 belonged to the JNA and the Republika Srpska Krajina right until Operation

5 Storm in 1995.

6 Q. Were JNA soldiers or JNA vehicles passing Saborsko from April when

7 you were in Saborsko? Did you see any vehicles or soldiers passing

8 through Saborsko?

9 A. Yes. Every day JNA armoured vehicles passed through. They went

10 along the Korenica-Josipdol road, the D42 road: Korenica, Plitvice,

11 Saborsko, Plaski, Josipdol, two JNA armoured vehicles together.

12 Q. Did they have to go through your check-points?

13 A. Yes. Yes, they did.

14 Q. Did you cause any -- did you block them from -- did you try to

15 block them from passing through your village?

16 A. No. We were even under orders not provoke them and to have no

17 contact with them whatsoever. They simply passed by. They were armoured

18 vehicles, and we only had rifles, so what could we do to them? And the

19 command was that the -- the orders we had were not to have anything to do

20 with them and not to provoke them at all.

21 Q. You said that they were passing every day. Do you still remember

22 until when they were able to pass through your village or until when they

23 were passing through your village?

24 A. They passed through as a sort of buffer zone with, that's what

25 they said about themselves, until the 5th of August, 1991, when the first

1 open attack began with 82-millimetre shells on Saborsko. So this went on

2 right until the 5th of August, 1991.

3 Q. What about Plaski, was it a -- was it cut off by -- the road to

4 Plaski, was it cut off by Croats or were you able to -- were Serbs able to

5 go by the road?

6 A. The road to Plaski -- well, traffic was supposed to go along the

7 Plaski-Plitvice-Josipdol road, but in Plaski and Licka Jasenica, the road

8 was closed off - that was the information we heard - and this was done by

9 various groups in Plaski. As for us, as far as we were concerned, the

10 road was open.

11 Q. And what about Ogulin, were you able to travel to Ogulin?

12 A. Yes. That was -- there was a line between Ogulin and Saborsko on

13 a daily basis, a bus line, and the bus went every day.

14 Q. Did you know or did you heard from anybody whether these buses

15 could -- could go through Licka Jasenica without any problems or were they

16 stopped?

17 A. They were stopped every day and searched in Plaski or in Licka

18 Jasenica. We were always in contact with that bus driver. He was the

19 only driver who was a Serb. He was the only one who was able to drive

20 that bus, and he was the one who told us that the bus was stopped every

21 time and the passengers searched.

22 Q. Did you learn who searched the bus and -- did they search only the

23 bus or also the people on the bus?

24 A. They searched both the bus and the passengers on the bus. The bus

25 driver always reported to us about what had happened.

1 Q. And because I combined two questions in one sentence, who did the

2 searches?

3 A. Well, according to the bus driver, it was Martic's groups.

4 Q. Now I would like to focus on events of 5th of August. You said

5 that it was the first time you were openly attacked. Can you tell me,

6 where were you on 5th of August?

7 A. On the 5th of August I was on duty that night as the duty officer,

8 and we had a report by telephone that we should look out because we were

9 going to be attacked. Somebody from Plaski or Licka Jasenica called us to

10 warn us about that.

11 Q. Do you know, who was it who warned you?

12 A. Citizens in Licka Jasenica. We still talk about it today.

13 Everybody knows who these people were. They were people who wished us

14 well, and they told us: Look out, you're going to be attacked. And this

15 was during the night, but we were not attacked until 6.00 in the morning.

16 Q. Did they also tell you who is going to attack you?

17 A. No. They just said: Watch out, you're going to be shelled. I

18 was the one who received the report. Those were mortar shells.

19 Q. So when the shelling started?

20 A. My shift ended at 0600 hours on the 5th of August, 1991, and I

21 remember it well because the first shell landed about five minutes after

22 my shift ended. Then it was followed by another one, and then the attack

23 escalated and went on until 10.00.

24 Q. Which direction the shelling was coming from?

25 A. The shells were coming from Licka Jasenica and a hamlet there

1 called --

2 THE INTERPRETER: Could the witness repeat the name of the hamlet,

3 please.

4 MS. RICHTEROVA:

5 Q. Can you please repeat the name of the hamlet.

6 A. Vukelic Poljana. It's a hamlet of the village of Licka Jasenica.

7 Q. Maybe we didn't mention it at the beginning. Which -- inhabitants

8 of which ethnicity live in the village of Licka Jasenica?

9 A. Inhabitants of Licka Jasenica were 100 per cent Serbs.

10 Q. Were you able to conclude who shelled you?

11 A. Those were, in fact, mortar shells, 82 millimetres, issued by the

12 JNA. And it's well-known who it is; it's the JNA and the local leaders,

13 so-called Martic's men.

14 Q. At that time of the shelling, apart from you regular policemen

15 from Saborsko, were there any other armed forces in the village of

16 Saborsko?

17 A. Yes. We had 20 men sent to us at reinforcement from Duga Resa.

18 Q. Preceding the attack on Saborsko, were there any ultimatums or

19 demands made from any side?

20 A. No, there were no demands made.

21 Q. During the 5th of August, was there any damage done to the

22 buildings?

23 A. On the 5th of August, around 80 shells fell before 10.00 a.m.,

24 that is, between 6.00 a.m. and 10 a.m., and there was no material damage.

25 Q. Were you able to see whether they -- they targeted something

1 specifically?

2 A. We couldn't understand whether they were not aiming right or what,

3 but they were shooting to the right of the church. Maybe their target was

4 the church, but the shells hit, in the morning, the area to the right of

5 the church. However, in the evening, shells began falling in the centre

6 of the place.

7 Q. What about the civilian population of Saborsko? Did they -- on

8 5th of August, did they stay in the village or did they leave?

9 A. They left Saborsko, for the most part on the 6th, that is the

10 night of the 5th, and they went to Rakovica. Not everybody but most

11 everybody left.

12 Q. And did they stay in Rakovica or was there any time when they

13 would return back?

14 A. The next day, that is the 6th of August, 60 to 70 per cent of the

15 populace came back.

16 Q. Those who came back, were there women, children, elderly people

17 among them?

18 A. There were women and children, elderly people, all categories of

19 people; however, some women and children did not come back. They went on,

20 I don't know to which area in Croatia, possibly Crkvenica.

21 Q. Was Saborsko shelled after 5th of August?

22 A. That was the beginning. After the 5th of August Saborsko was

23 shelled every day, especially during the night.

24 Q. And after -- you said that on 5th of August no damage was done to

25 the buildings. At the later stage, were any buildings or other objects

1 damaged?

2 A. Later, shelling was on a daily basis and many buildings were

3 damaged, but the worst hit was the church of Saborsko because it was a

4 tall building, it was targeted every day, and of course there was damage.

5 Q. To your knowledge, was anybody killed or injured during the

6 shelling?

7 A. Yes. Well, there were some wounded among my colleagues during the

8 shelling. It wasn't too bad, but people were very afraid. They were

9 trying to take care of themselves, stay in shelters. But there was a lot

10 of material damage and a lot of cattle was killed.

11 Q. In September, did you receive any help in the form of manpower,

12 ammunition?

13 A. In September 1990 [as interpreted], yes, for a brief period, that

14 was when I was arrested. We received assistance from Zagreb, about 100

15 men, around the 25th of September, 1991.

16 Q. When they arrived, were you still in the village?

17 A. Yes, I was still in the village for another two or three days.

18 Q. Did they -- to your knowledge, did -- during the way to Saborsko,

19 did they made any arrests?

20 A. Yes. They arrested three persons; one civilian and two persons

21 wearing the insignia of the militia of Krajina.

22 Q. Did you see them when they brought them to the village?

23 A. No, I did not. I saw them later when I was arrested myself in

24 Plasko.

25 Q. Because you managed to see them in Plaski, so how long did these

1 people stayed in -- these arrested people stayed in Saborsko? For how

2 long?

3 A. Well, at the time when I saw them on the 25th, they had been there

4 for two or three days.

5 Q. And were they -- after they -- were they released or exchanged; do

6 you know this?

7 A. I learned that they were exchanged for an elderly person from

8 Sjetic Poljana [phoen]. That is a small place. I am not quite clear

9 about that.

10 Q. Going back to this group of 100-plus people who arrived from

11 Zagreb, who were they? Were they soldiers? Policemen? Civilians?

12 A. There were people, natives of Saborsko, who were mobilised in

13 Zagreb. They had dispersed around various places in Croatia and worked

14 there until they were mobilised, but they were originally from Saborsko.

15 Q. When they arrived, did you see what kinds of uniforms they wore?

16 A. Yes. I saw them when they arrived. They were scared. It was

17 their first mission of that kind. I was with them on the way from

18 Saborsko to Licka Jasenica, and they were wearing some sort of green

19 uniform. They did not get involved into any combat at the beginning.

20 Q. Do you know whether they called themselves -- or whether they had

21 any name?

22 A. Yes, I know that. They were called the Independent Company of

23 Saborsko.

24 Q. And do you know who was their commander?

25 A. Their commander, who was it? Was it Marko Krizmanic? I don't

1 know. The company was set up in Zagreb -- or maybe it was Luka Hodak.

2 Q. What was their purpose in Saborsko? Was it just defensive or also

3 offensive?

4 A. They were engaged in defence mostly. I don't know, in fact, what

5 kind of equipment they had, if they had any heavy weapons or not. I don't

6 know that. They didn't go there. They didn't come to attack; they came

7 to defend. I'm the first to acknowledge that had we not been arrested

8 when we were, we would have simply left. We were unable to take any more.

9 The winter was coming. We were poorly equipped. So what I'm trying to

10 say, they came there to defend the place but they did not succeed.

11 Q. You -- you were arrested shortly after they arrived. But at any

12 time between the time that Saborsko was shelled until your arrest, did you

13 -- as policemen, did you launch any attacks against other villages,

14 against other armed forces in that region?

15 A. No, we didn't take any offensive action because we had nothing to

16 attack with. And I have to say once again, our order was to avoid

17 shooting if we could. And we were the happiest during those days, which

18 were few, when we were not being attacked. And it was far from our mind

19 to provoke any shooting ourselves.

20 Q. You also -- you already mentioned that you were arrested shortly

21 after this group from Zagreb arrived. Do you know exactly the date of

22 your arrest?

23 A. I was arrested on the 29th of September, 1991, around 1300 hours.

24 Q. What were the circumstances of your arrest? What did you do at

25 the time of your arrest?

1 A. I travelled through the woods towards Rakovica, a forest road

2 called Rakovacke Uvale, in my own car.

3 Q. Was there anybody else with you?

4 A. Yes, Ivica Vukovic was with me. He had come from Zagreb, plus

5 Nijaz Poric. They were the first men from Zagreb, the first mobilised men

6 that I saw.

7 Q. Did you wear a uniform?

8 A. Yes. I was wearing a uniform and I had a side-arm and a long

9 barrel.

10 Q. On your uniform as a policeman, did you have -- did you have any

11 patch, any insignia?

12 A. Yes. I was wearing the insignia of the police right here. It was

13 a very well-worn uniform, in tatters, but I had insignia, yes.

14 Q. Can you tell the Judges what kind of insignia. How did it look

15 like?

16 A. Police. Police of the Republic of Croatia. We had the uniform of

17 Croatian police.

18 Q. Was there any --

19 JUDGE MOLOTO: Would that be a convenient time?

20 MS. RICHTEROVA: This is my last question, then we can break.

21 Q. Was there anything else on that insignia? Any picture of

22 something?

23 A. No. Our uniform was a simple grey uniform with a patch that only

24 said "Police." That's all.

25 MS. RICHTEROVA: Yeah, that's it. It's a very convenient time.

1 JUDGE MOLOTO: Thank you very much. May we take a short break and

2 come back at quarter to 11.00.

3 --- Recess taken at 10.16 a.m.

4 --- On resuming at 10.46 a.m.

5 JUDGE MOLOTO: Yes, Ms. Richterova.

6 MS. RICHTEROVA:

7 Q. Mr. Vukovic, before we continue talking about your arrest, I have

8 one more question relate -- in relation to the shelling. You testified

9 earlier this morning that two JNA armoured vehicles were passing through

10 your village almost every day or every day until the 5th of August, 1991,

11 when the shelling started. After the shelling started, what -- what

12 happened to these JNA armoured vehicles? Did they stop coming to your

13 village?

14 A. Yes. After the shelling they drove again through Saborsko once

15 more, but not again because they prevented them from driving through

16 again. The people were up in arms, and they sort of laughed sarcastically

17 and then they drove away towards Plitvice and never appeared again as long

18 as I was there.

19 Q. So now I would like to return back to the end of September when

20 you were arrested. Who arrested you?

21 A. I was ambushed while driving my car by five to six persons, one of

22 whom was wearing a JNA uniform while others wore camouflage uniform. They

23 were residents of Plasko. I didn't recognise the person wearing the JNA

24 uniform, but the others I knew, and they called themselves Martic's men.

25 Q. At the time of your arrest, did you manage to notice whether these

1 men in camouflage uniforms, whether they had any patches, any insignias?

2 A. No. No, I didn't notice that. I didn't have time because I had

3 my hands bound immediately. Maybe they wore some insignia, but I didn't

4 see them.

5 Q. Where did they take you?

6 A. They took me on foot towards the military training ground of the

7 JNA called Tobolic, near Slunj, and after that I went to Plaski. In

8 Tobolic their vehicles were waiting and they had come to -- on foot.

9 Q. In Plaski, where were you taken?

10 A. I was taken first to the police outpost in Plaski, where I was

11 detained below the staircase.

12 Q. At the police outpost, who did you see there? Were they

13 policemen? Soldiers? Who did you see there?

14 A. There were my colleagues there, people with whom I had worked

15 earlier in Ogulin and in other places, plus some people I didn't know,

16 including some wearing camouflage uniforms. But the first men I saw were

17 my colleagues with whom I had been working just a month or two earlier.

18 Q. Those colleagues of you -- of yours, or former colleagues of

19 yours, what kind of -- what kinds of uniform did they wear?

20 A. The same uniform, except they had a patch on the sleeve with

21 "Militia of Krajina" written on it.

22 MS. RICHTEROVA: I would like to show the witness document with

23 ERN 0118-7457. I think we have little bit problem. I have a hard copy.

24 Maybe it would be faster -- yeah. Okay. Do you have it on your screen,

25 Your Honour? Can we place the hard copy on the ELMO and let's hope that

1 -- yeah, on the ELMO so we all can see it.

2 Q. Can you have a look at the patch and tell us whether you have seen

3 this patch.

4 A. Yes, that's the patch they wore on the sleeve.

5 Q. For the benefit of Judges, can you read what is written on that

6 patch.

7 A. In Cyrillic, "Militia of Krajina."

8 Q. Thank you. That's --

9 MS. RICHTEROVA: I would like to tender this document into

10 evidence.

11 JUDGE MOLOTO: May the -- the document is admitted into evidence.

12 May it please be given an exhibit number.

13 THE REGISTRAR: That would be Exhibit Number 266, Your Honours.

14 JUDGE MOLOTO: Thank you.

15 MS. RICHTEROVA:

16 Q. So you saw this patch on uniforms of policemen in Plaski?

17 A. Yes. Yes, that's the patch.

18 Q. In Plaski at the police station, where were you kept?

19 A. I was detained, imprisoned in a building below the staircase which

20 used to be a storage room, like a 2, 3 metres below the stairs.

21 Q. How many people were there with you in that little room?

22 A. Three: I, Ivica Vukovic, and Nijaz Poric.

23 Q. What did you sleep on? Did you have any blankets?

24 A. Something plastic was laid down, like a plastic mat on the floor,

25 and everybody had the JNA-issued blanket, the grey one.

1 Q. Did you receive a meal?

2 A. In Plasko, yes, but we couldn't eat because we were beside

3 ourselves.

4 Q. How were you treated at the police station, at your captivity?

5 A. As for treatment, of course I was expecting help from my

6 colleagues. I asked them to release me, but Dusko Jovicic told me: Look,

7 there is no law here. I'll try to do my best to release you or to protect

8 you somehow, but there is no law here. That's what my colleague Dusko

9 Jovicic told me. Because they were --

10 Q. Mr. Vukovic, I will interrupt you. My question was: How were you

11 treated during your detention?

12 A. We were beaten. I was taken to a house. They drove me around

13 Plasko, handcuffed behind the back. They gave me to drink [as

14 interpreted]. They shot. They made fun of us, ridiculed us.

15 Q. You said that you were -- you were beaten. Who did the beating?

16 A. I was beaten by those groups of men dressed in camouflage

17 uniforms, and in that group there was one man dressed in a JNA uniform.

18 Q. You said "men dressed in camouflage uniforms." Did you mention

19 that they told you who they were?

20 A. Well, they called themselves "Marticevci," meaning Martic's men.

21 Q. Were -- when you were beaten, were the regular policemen present?

22 A. No. Regular policemen were not present, and they couldn't do

23 anything anyway. I had already asked my former colleagues for help, but

24 they were helpless. I could see from the general situation when somebody

25 offered to drive me, the others would say: No, Jaksic would take him in

1 his car. It was complete lawlessness, anarchy, and these militia groups

2 had the main say. I don't know what they were doing there.

3 JUDGE NOSWORTHY: Ms. Richterova, before you go on, there's just

4 something -- two things which I would like to get clarified. The witness

5 has said: "They gave me to drink," which is what is on the record. Could

6 we have an explanation precisely what that means. And then there is

7 another statement: "They shot." Could we please get greater

8 clarification here.

9 MS. RICHTEROVA: Yes, Your Honour.

10 Q. Mr. Vukovic, to my question how you were treated you were, among

11 others, answered: "They gave me to drink." What did you refer to?

12 A. Yes. They gave me beer to drink, in a tavern, while I was

13 handcuffed behind my back. And in a coffee bar or tavern in Plasko they

14 gave me beer to drink. I had to drink it, whether I wanted it or not.

15 And all the time my hands were handcuffed behind my back.

16 Q. Did you -- did you drink? Did you [sic] make you to drink?

17 A. I had no choice. They forced me. They just poured it down my

18 throat.

19 Q. And you also said: "They shot." What they shot? What did they

20 shoot at?

21 A. While they were driving me through the centre of Plaski, in a car

22 on the side, the -- Ljuban Korajlija was driving it, one man was driving

23 and the other was shooting through the window while we were driving along

24 the street, and I was in the car.

25 MS. RICHTEROVA: Your Honour --

1 JUDGE NOSWORTHY: Thank you very much.

2 MS. RICHTEROVA:

3 Q. How long did you stay in Plaski?

4 A. I stayed in Plaski about 12 days, approximately.

5 Q. After 12 days, where were you taken?

6 A. Then they took me to Korenica, the police station in Korenica.

7 MS. RICHTEROVA: Your Honours, I would like to refer you to page

8 19 where you can see Titova Korenica, which is grid E3. It's the right

9 bottom corner, and it is in the middle of that little square.

10 Q. At the police station in Korenica, who did you see there?

11 A. I didn't know anybody there. I saw policemen with the same

12 insignia of the Krajina police and wearing uniforms, and again I saw

13 persons in camouflage uniforms, just like in Plaski.

14 Q. Talking about Plaski, do you know a person with name Nikola

15 Madakovic?

16 A. Yes. I met that person when I was captured in Plaski. He was the

17 first person who beat me. He beat me with a military belt, on my head.

18 Q. Where did you see him?

19 A. He came to the police station in Plaski to see me.

20 Q. To your knowledge, who -- who he was?

21 A. He was later the president of the municipality. He was a local

22 leader in the Republic of Krajina.

23 Q. Now, returning to Korenica. In Korenica you -- you were taken at

24 the police station. Where in the police station, where were you kept?

25 A. There were three detention cells there, and I was in cell number

1 3.

2 Q. Were there some other people detained together with you?

3 A. In my cell, cell number 3, there was Nikola Pemper and Ignjac

4 Ivanus. They were from Otocac, from Gospic. Ignjac Ivanus came from the

5 Croatian Zagorje region and he was a police station commander.

6 Q. These two other men, were they of Croat ethnicity?

7 A. Yes, both Nikola and Ignjac were of Croatian ethnicity.

8 Q. Were you able to see whether there were other people detained in

9 other cells?

10 A. No, I wasn't able to see that.

11 Q. Who was in charge in Korenica?

12 A. I don't know that. I don't know that. We were in cells, so we

13 don't know.

14 Q. And how were you treated in Korenica at that police station?

15 A. In the police station in Korenica, when I got there I was

16 handcuffed. My hands were handcuffed behind my back. I was put in the

17 cell like that, and the handcuffs were taken off only on the following

18 day. The way they handcuffed me in Plaski, that's how I was left in

19 Korenica. Apparently they couldn't find the key. Nikola Pemper gave me

20 water to drink.

21 Q. You were beaten in -- at Plaski police station. What about at

22 Korenica police station?

23 A. I was beaten even more badly there and my face was cut with a

24 knife.

25 Q. Can you tell the Judges who did the beatings?

1 A. I don't know the person. That person was naked to the waist and

2 was carrying a knife and had a black rag around his head. This was in the

3 Korenica police station.

4 Q. When you were beaten, were the other policemen present?

5 A. Yes, but they behaved as if nothing was happening. They were

6 sitting on the other side, drinking something, beer or coffee or whatever.

7 It was in the same room where he was beating me, and they were just

8 sitting there and they were completely indifferent.

9 Q. How long did you stay? Approximately how long did you stay at

10 Korenica police station?

11 A. I don't know, but I think about ten days. It was a cell, solitary

12 confinement. I could see when it was day-light, but I can't tell you the

13 exact number of days, no.

14 Q. You mentioned this beating. Were you -- was this the only

15 occasion when you were beaten or were there more than one occasion when

16 you were beaten?

17 A. I was beaten more than once but this was the worst time. In the

18 evening, when the pubs in Korenica closed, they would come to beat people,

19 to punch people or to kick them in the head. But the worst thing that

20 happened to me when I was cut with a knife.

21 Q. And whenever you were beaten, were the policemen with the sign

22 Militia Krajina, were they always present?

23 A. Yes, they were present but they didn't react. It was as if they

24 weren't there. I would look at them and they would not respond in any

25 way. In Plasko they tried but couldn't, because in Plasko we were

1 acquaintances, and here they didn't even try.

2 Q. You said that you stayed here for about ten days. Where did you

3 go after this time?

4 A. Then a JNA vehicle came to fetch us, 110, that's an all-terrain

5 vehicle. It was referred to as the "110." And we were taken to the

6 Zeljava military airport in Bihac. That's on the border between Croatia

7 and Bosnia.

8 Q. And at this airport, for how long were you -- how long did you

9 stay there?

10 A. I think I stayed there -- it was in a warehouse. There were

11 several of us there, and I was there until the end of October, maybe eight

12 days, and then I was taken to Manjaca in Bosnia and Herzegovina.

13 Q. You said that it was a military airport. Was it the JNA who was

14 in charge at that airport?

15 A. Yes, it was a JNA military airport and there were persons in blue

16 JNA uniforms there. It was a military airport, and they had blue

17 uniforms. There were also those in olive-green uniforms. There were

18 conscripts there.

19 Q. These men in blue uniforms, do you remember whether they wore any

20 belts?

21 A. That was the military police, and they wore white belts. Those

22 belonged to the military police of the then-JNA. Sometimes they would

23 wear green uniforms. It was unclear to me, because they would change

24 uniforms, but they were JNA uniforms. And there were groups of men there

25 whom I didn't know what they were and they wore camouflage uniforms.

1 Q. Were you beaten at this detention facility?

2 A. Yes. We slept in a warehouse at Palace and they beat us there.

3 They beat Nikola Pemper worst, and then me. I don't know why they beat

4 Nikola Pemper so badly.

5 Q. Again, who did the beating?

6 A. Persons with white belts. One day they would be wearing a green

7 JNA uniform, the next day a blue uniform. And then a military policeman

8 said to me that those were our colleagues from Zagreb. There were five of

9 them. They had left the Republic of Croatia and the Ministry of the

10 Interior and gone to the Zeljava airport. A military policeman said:

11 It's your colleagues who are beating you.

12 Q. And finally, you mentioned you were taken to Manjaca. Can you

13 tell the Judges where Manjaca is.

14 A. Manjaca is in Bosnia and Herzegovina.

15 Q. Do you know which is the biggest town near to Manjaca?

16 A. The biggest town near Manjaca is Banja Luka. There was a military

17 training ground there and the JNA barracks. In Manjaca, that is. And

18 it's just above Banja Luka. Banja Luka is the biggest town there.

19 Q. Did I understand correctly that Manjaca was this military training

20 ground?

21 A. Yes. There were barracks there, hangars. We were locked up in

22 hangars where they kept cattle.

23 Q. How many people were there together with you? How many people

24 were there detained?

25 A. There were three hangars in all, and I think about 200 men. I was

1 in the third one. There were wounded men there. The policemen from

2 Kostajnica who had been captured before me, they were up there. There

3 were about 200 men. I know that because when the exchange was carried

4 out, then I learned how many of us there were. I couldn't know at the

5 time how many men were imprisoned in those three hangars.

6 Q. Do you know which ethnicity were these people who were detained in

7 Manjaca?

8 A. I don't know that. I don't know that. I know it was policemen

9 from Hrvatska Kostajnica, but whether there were also people of other

10 ethnicities, I really don't know.

11 Q. At any time during your detention, either in Plaski, Korenica,

12 Bihac, or Manjaca, were you taken -- were you told why you had been

13 arrested or why were you detained?

14 A. No. We never got a specific reply. They would just say vulgar

15 words and say that the Republic of Croatia would cost us dearly. They

16 would say nothing else.

17 Q. You mentioned that you were exchanged. When was it?

18 A. We were exchanged at the border between Bosnia-Herzegovina and

19 Croatia in Slavonski and Bosanski Samac on the bridge on the 9th of

20 November, 1991.

21 Q. And after you were exchanged, where did you go?

22 A. To Zagreb, for treatment.

23 Q. At --

24 A. Bjelovar and then Zagreb, excuse me.

25 Q. After your exchange in 1991, did you go at any time back to

1 Saborsko?

2 A. The first time I returned to Saborsko was during Operation Storm

3 on the 6th or 7th of August, 1995.

4 Q. When you came to Saborsko in 1995, how did the village look like?

5 A. I didn't recognise it. It didn't exist. You could see just the

6 bushes. It was all overgrown and the road was overgrown. It was all

7 covered with bushes. There was nothing there. It was a ghost place, just

8 thorns and bushes.

9 Q. The houses, were they all destroyed or were there some which stay

10 intact?

11 A. It's not just that they were damaged; they didn't exist. I didn't

12 see a single house. I only recognised the church. It was a heap of

13 rubble. Because the church had been a big building, so I recognised that

14 heap of rubble as the church. But as for the rest, you couldn't tell

15 where the houses had been. I recognised just the church and the school

16 because there were heaps of stones there.

17 Q. Did you visit some other villages in that region?

18 A. No, I didn't because I was assigned to Plaski-Saborsko and I

19 didn't have time to go around and look at other places. It was only later

20 on, but for the first month or two, no.

21 Q. You say "only later on," so later on did you visit some other

22 villages?

23 A. Yes, later on, as I said, I visited Plitvice, and that was it.

24 And Rakovica, later on, but in the first month I didn't go anywhere. I

25 was on the Saborsko-Ogulin route.

1 Q. You visited Rakovica. Rakovica, was it a Serb village or a Croat

2 village?

3 A. It was a Croat village.

4 Q. And how did you find it? How did Rakovica look like?

5 A. It was partially destroyed. Half of it was destroyed. It was all

6 neglected but it didn't look like Saborsko.

7 Q. In Saborsko in 1995, did you participate in exhumations?

8 A. Yes. I was personally present. The first exhumations began on

9 the 18th of October, 1995.

10 Q. Can you tell us, was there just one site or were there more than

11 one site where you found dead people?

12 A. In Saborsko there was several sites, several exhumations and

13 several mass graves. The biggest was in Popov Sanac, where 14 bodies were

14 found.

15 Q. Can you tell the Judges approximately how many people were exhumed

16 in Saborsko?

17 A. In Saborsko, 20-something people were exhumed and seven are still

18 missing. Some were in Popov Sanac, which was the biggest mass grave, some

19 were in Borik, and there were also people who were burned in their houses.

20 Those were the sick, the elderly. They found skeletons in the houses.

21 Q. Do you know --

22 A. Not in the houses, but at the hearths.

23 Q. Do you know approximately how old these people were, those who you

24 found? Who was the oldest and who was the youngest?

25 A. The age was 70, 80, 65. There were two elderly people who were

1 100 years old. Those two people were 100 years old. They were found, one

2 in Popov Sanac, in the mass grave there, and the other one in Srjeni

3 [phoen]. The youngest was a sick woman. I think she was born in 1960.

4 It was a sick female, and she was found burned alive on her bed.

5 Q. You mentioned this one woman. Were there more than one woman who

6 was exhumed?

7 A. Yes, yes. I told you who the youngest was and who the oldest

8 were. And the other women I mentioned were about 70.

9 Q. Thank you, Mr. Vukovic. I don't have any further questions.

10 JUDGE MOLOTO: Thank you, Ms. Richterova.

11 Mr. Milovancevic.

12 MR. MILOVANCEVIC: [Interpretation] Thank you, Your Honours.

13 Cross-examination by Mr. Milovancevic:

14 Q. Witness, my name is Predrag Milovancevic. I am Defence counsel

15 for Milan Martic. This stage of your examination is called

16 cross-examination. I will put questions to you, and you will respond in

17 the way you know. As we understand each other, for the sake of the

18 interpreters, please let's make a pause between question and answer.

19 In your statement which you gave to the Office of the Prosecutor,

20 you said that until 1989 you worked in the Plitvice Lakes National Park.

21 Can you tell us what sort of work you did.

22 A. I was in the building construction department, and we put together

23 wooden houses all over the former Yugoslavia.

24 Q. Could one say that you were employed in a company called Plitvice

25 Lakes National Park?

1 A. Yes, that's correct.

2 Q. The name of the company Plitvice Lakes National Park mentions the

3 lakes that make up the national park. Do you know how many employees

4 there were in that company? Do you remember that?

5 A. I don't remember, but I think it was about a thousand people in

6 all the various departments. It was a huge company. It was over a

7 thousand people who were employed there.

8 Q. In your statement to the Office of the Prosecutor you said that in

9 1989 you and several others at one point felt unwanted in the area where

10 the Serbs were in the majority, that you felt uncomfortable, and that you

11 decided to leave although nothing specific happened. Is that what you

12 said?

13 A. Yes, yes. There was a group of people who would sing Chetnik

14 songs in the evenings. There were provocations. People would jeer at us.

15 We went to our boss; he didn't say anything. Because we had gone to have

16 a meal, not to listen to people singing Chetnik songs. It would happen in

17 the evenings.

18 Q. If I understood you correctly, all that was going on in a

19 restaurant and the staff were singing songs?

20 A. No, patrons.

21 Q. In your statement to the OTP you said that in 1989 because of that

22 situation, because of the feeling that you were unwelcome in areas where

23 Serbs were a majority, you left your job and went to Saborsko where your

24 parents lived and remained there until 1990 when you found a job with the

25 police force.

1 A. That's correct.

2 Q. Also in your statement you said that in Saborsko there was a

3 population of about 800 and only a few Serbs. Was that the population?

4 A. Around 800 residents in total, and only about four Serb houses.

5 Q. In your statement we read when you described your stay in Saborsko

6 while you were unemployed, that is, until the end of 1990, that you felt

7 that the situation was changing, although there were no particular

8 incidents in Saborsko. Is that so?

9 A. Things were happening all around, although not in Saborsko. But

10 things were happening all over the country.

11 Q. You stated that you had left Plitvice because you felt unwelcome

12 in a place where Serbs were a majority and you went to Saborsko which had

13 a majority Croat population. And again you felt something was going on.

14 Was something really going on or was it all within you?

15 A. Democracy was being introduced, things were really happening. The

16 state of Croatia was coming into being.

17 Q. Do you mean to say that this onset of democracy and the creation

18 of the Republic of Croatia was the source of your feeling of unease?

19 A. No; on the contrary. I was glad that we had democracy and freedom

20 of speech and thought.

21 Q. Was this freedom given to everyone or only to some?

22 A. To everyone. The word "democracy" is clear; we all know what its

23 meaning is.

24 Q. In your statement describing year 1990 in Saborsko, you said there

25 were no political activities in that place; however, you also stated that

1 in end-March -- in end-February or perhaps March 1990 one rally was held,

2 and another one in July, and that later yet another rally was held with

3 the participation of Jovan Opacic. Can you tell me who organised the

4 rallies in February/March and in July, and what kind of rallies were they?

5 A. Those were rallies as part of the electoral campaign in March and

6 in July. That's when the elections were being held. Those were political

7 rallies. Democracy had come and rallies could be organised. There were

8 no bans, no communism anymore. Rallies were being held by all the new

9 political parties.

10 Q. Thank you. Can you tell us what political parties organised these

11 two rallies?

12 A. Yes, I can. It was the Croatian Democratic Union, HDZ. And there

13 were more rallies. Those were not the only ones. Other political parties

14 also had their rallies.

15 Q. Are you talking about the rallies held in Saborsko or elsewhere?

16 A. In Saborsko, there were many public debates and rallies.

17 Q. And what was the topic of those public debates? It was election

18 time and what was discussed?

19 A. Democracy. New winds were blowing and the state of Croatia was

20 coming into being, whereas the state of Yugoslavia was falling apart. It

21 wasn't happening only in our country. The Berlin Wall was coming down,

22 Czechoslovakia was breaking up. It was the onset of democracy.

23 Q. Was the main purpose, main goal, of the HDZ to create an

24 independent state of Croatia?

25 A. Not only of the HDZ. There were a number of parties at the time

1 who had that as a goal. There was no more communism, no more diktat.

2 Q. You said that in the first half of 1991, elections were held for

3 the first time in Croatia. Do you mean to say the first multi-party

4 elections won by the HDZ that won a two-third majority in the parliament

5 of Croatia?

6 A. That's correct. I mean the first democratic multi-party

7 elections.

8 Q. Do you know that in the organisation of key political parties in

9 Croatia that were working for an independent state, amendments were

10 introduced to the Croatian constitution whereby the Serbs, who had until

11 then been a constituent nation, were to become a national minority?

12 A. I don't know. I think the Serbs were not a national minority in

13 the first Croatian institution -- constitution because there were more

14 than 11 per cent of them in the total population. The Serbs were not a

15 national minority according to the constitution, because it was adopted in

16 1990.

17 Q. In that year, 1990, do you know if the Serbs tried to present

18 their demands for autonomy?

19 A. Not that I know of. I don't know what that means "autonomy." If

20 you have all your rights protected by the constitution, what more is there

21 to seek? They were not even a minority.

22 Q. You said you heard it being said that in August 1990 some

23 barricades were being put up but not in Saborsko.

24 A. Could you repeat that?

25 Q. You said in your statement to the OTP that in August 1990

1 barricades were being put up in Serb-held areas of Croatia, according to

2 what you heard.

3 A. Yes, barricades already existed at that time, but not in Saborsko.

4 It was all over the media and it is documented. Let us just remember

5 that tourist season and how it developed.

6 Q. Would I be right in saying that the barricades were put up in

7 August 1990? You said yourself it was the tourist season.

8 A. Well, that's as accurately as I can put it. I don't know if it

9 was August or not.

10 Q. Do you know what was the immediate cause for putting up

11 barricades? Do you know that the Croatian government banned a referendum

12 of the Serbs in Croatia concerning their autonomy?

13 A. I don't know. I talked to many Serbs, and I never heard of that.

14 And to date we still don't know why it happened.

15 Q. You said in your statement that after the May referendum a

16 significant number of Serbs from other villages stopped coming to

17 Saborsko; however, you specified that that May referendum happened in

18 1990. My question is: Was it actually in 1991, after the first

19 multi-party elections?

20 A. Yes, it must have been a slip on my part.

21 Q. What was the question asked at that May referendum in Croatia in

22 1991 for the whole population of Croatia?

23 A. What? What?

24 Q. What did the people vote about at that referendum in May 1991?

25 Was that decision about the independence of Croatia?

1 A. Yes, it was about the Independent State of Croatia.

2 Q. You said that all residents of Saborsko voted for the HDZ at the

3 first multi-party elections, and you said that all political parties in

4 Croatia were in favour of an independent Croatian state. You also said

5 that after the May referendum in 1991 the Serbs from the surrounding

6 villages stopped coming to Saborsko.

7 A. Not all Serbs. Some of them. Not all of them. I never speak in

8 such general terms.

9 Q. Do you know why some Serbs from the surrounding villages stopped

10 coming to Saborsko?

11 A. Well, it became clear from the result, from all that we saw

12 later: The Serbs who stopped coming were those who were dreaming of

13 Greater Serbia, with the borders Karlovac, Virovitica, Karlobag. We saw

14 the creation of the Republic of Serbian Krajina and the goal expressed in

15 the memorandum coming from Belgrade that all Serbs should live in one

16 state.

17 Q. We will come back to that topic. Let us go back to the

18 chronological order of events. You said that in 1990 you became

19 unemployed. By the end of the year you found a job with the police of the

20 Republic of Croatia.

21 A. Yes, on the 15th of December.

22 Q. At the time when you found that job in the police of the Republic

23 of Croatia, had you finished some sort of police school?

24 A. First I was approved by the medical panel - you know the procedure

25 - and then I got the job. After that, I attended training courses,

1 workshops, seminars, et cetera.

2 Q. So before that job in the police, you did not have any training to

3 be a policeman; you got it only later?

4 A. I had some education. This was just retraining. I had graduated

5 from a high school, and the training I got was just retraining.

6 Q. That training course, was it in Zagreb, in Simunska Street?

7 A. No, it was called education seminars and advanced training, in

8 Ogulin and in Karlovac. We had theoretical and practical training,

9 alternating. We learned about the law on criminal procedure, the criminal

10 code, the law on the police force, et cetera. Our group had 20 persons in

11 it.

12 Q. When you found that employment in December 1990, with which police

13 station was it, in Ogulin or in Karlovac?

14 A. The police station was in Ogulin, but it belonged to the police

15 administration of Karlovac. You have the Ministry of Interior at the top

16 of the pyramid; below it, you have police administrations; and the level

17 below are police stations.

18 Q. Among the 20 persons who were employed together with you, were

19 there any men who had been policemen prior to that, who had graduated

20 already from police schools?

21 A. No.

22 Q. Do you know if the HDZ had any say in the selection of trainees,

23 cadets, for that police corps?

24 A. No. But I know why you're asking. Even Serbs were admitted at

25 that time. Damir Vorkapic and another man, a Serb, were in my group.

1 Q. You explained that after being admitted to the police force and

2 after your training in Ogulin you worked as a regular policeman and got

3 training on the job. How long did that last?

4 A. From December until Easter, the end of March, actually, 1991.

5 Immediately after getting a contract, we started the training.

6 Q. What kind of uniforms were worn by the police that belonged to the

7 MUP of Croatia at the time?

8 A. Normal uniforms, and I had normal insignia. The patch on the

9 sleeve said "militia" which was the former name for the police in

10 Yugoslavia. It hadn't yet changed to the police.

11 Q. Can you describe it?

12 A. In 1990, while the former Yugoslavia still existed, the sleeve

13 patch said "Milicija" and a five-pointed star on it.

14 Q. When did the new police force of Croatia come into being?

15 A. It wasn't called "Milicija" anymore. It became "Policija,"

16 police.

17 Q. Was it with a chequer-board flag?

18 A. It's not the chequer-board emblem. It's the historic Croatian

19 coat of arms, and the five-pointed star was replaced by the -- that

20 historic Croatian coat of arms in January 1991. I absolutely reject the

21 term "chequer-board" flag.

22 Q. At that time were all members of the police asked to sign a

23 declaration of loyalty to the government of the Republic of Croatia in

24 1991?

25 A. No, no. Those who were already in the police remained in the

1 police. We who were new took an oath, as happens in every system.

2 Q. You say that on the 1st of April, 1991, you were deployed as a

3 policeman in Saborsko. Had there been a police substation in Saborsko

4 until then?

5 A. No, it was the first time it was established.

6 Q. Was Marko Vukovic also deployed there as a policeman, together

7 with you?

8 A. Yes.

9 Q. You said that the police substation in Saborsko had about 20

10 active-duty policemen. Your colleague said there were 26 or 28, plus four

11 to five reserve policemen; a total of 32.

12 A. Well, that's the approximate number. There were about ten

13 reservists and 20-plus active-duty policemen.

14 Q. Could one say then that the number of policemen in Saborsko in the

15 police outpost was 32?

16 A. No, I don't believe that. A lot of time has elapsed, but there

17 are lists. I don't want to give you any numbers off the top of my head.

18 You can look it up in the records, the records of the payroll. I cannot

19 give you precise numbers; it was 15 or 16 years ago.

20 Q. Thank you. You said that all the policemen had automatic rifles

21 and that the active-duty policemen also had side-arms, pistols.

22 A. Yes. Yes, pistols, side-arms.

23 Q. When the Serb police outpost was established in Saborsko on the

24 1st of April, 1991, you linked its establishment to what you called the

25 epicentre of evil, referring to the events in Plitvice on the 1st of

1 April, 1991. Are you referring to the events that happened on the

2 Catholic Easter 1991?

3 A. I don't want to confuse the Catholic Easter with the first

4 incident that occurred at Plitvice. Catholic Easter is celebrated all

5 over the world. What has it got to do with the Plitvice Lakes? It just

6 happened to coincide. What has it got to do with Easter?

7 Q. I'm asking you because there is information that the Catholic

8 Easter took place on the 31st of March, 1991, and the 1st of April is the

9 next day. So is that what you're referring to when you refer to the

10 epicentre of evil?

11 A. I know what happened at Plitvice on the 1st of April, 1991; it has

12 nothing to do with the Catholic holiday of Easter.

13 Q. Do you know that on Catholic Easter the Croatian police carried

14 out an armed attack on Plitvice?

15 A. That's not correct. Who attacked whom, everybody knows that.

16 Q. Were you at Plitvice at the time?

17 A. No, I was in Ogulin. I arrived in Saborsko in the late afternoon.

18 Q. Were you in command of units of the Croatian police at Plitvice on

19 that day when there was a clash?

20 A. No. I became a commander only in 1995, during Operation Storm.

21 Up to that time, I was not a commander; as I said, I was the operations

22 duty officer. My command duties began during Operation Storm.

23 Q. If that's correct, then how do you know what happened at Plitvice

24 and who attacked whom?

25 A. Well, of course I know; it was nearby. What kind of policeman

1 would I be if I didn't know what was happening at Plitvice?

2 Q. On that day at Plitvice when there was an armed conflict, were two

3 men killed?

4 A. I don't know.

5 Q. Do you know if anybody was killed?

6 A. I know that one was killed; that's what I learned in the media,

7 because I wasn't actually there.

8 Q. And that one person who was killed, what ethnicity was he, do you

9 know?

10 A. He was a Croatian policeman, an employee of the Ministry of the

11 Interior.

12 Q. And you don't know that a Serb was killed on that day?

13 A. No, I don't know that. In what capacity was he killed?

14 Q. Is anyone's capacity a reason not to consider a person a victim if

15 he's a victim?

16 A. I don't know. I don't know what this was about, and I don't know

17 who was killed and in what capacity. As I say, I don't know.

18 Q. Do you know that pursuant to a decision by the Presidency of the

19 country, the JNA intervened at Plitvice and prevent an escalation of the

20 conflict on the 1st of April, 1991, or the evening of the 31st of March,

21 1991?

22 A. The JNA did not prevent the conflict; it fanned the flames. That

23 was the problem, because to arrive in tanks into a national park against

24 some 20 policemen ... They damaged the water barriers, and the ecological

25 association and the greens are still dealing with it.

1 Q. In 1991 were the Plitvice Lakes part of Yugoslavia?

2 A. No, they were in Croatia that year.

3 Q. Was Croatia in April or the 31st of March still in Yugoslavia?

4 A. No. The elections had been held a year before, the multi-party

5 elections, and democracy was already in force and the Croatian state had

6 already been created.

7 Q. Do you wish to say that your understanding of Croatian democracy

8 meant that the federal state no longer existed, that Yugoslavia no longer

9 existed, and that the JNA had no right to intervene there?

10 A. I cannot give you an answer to those questions. I don't know why

11 one should fear democracy anywhere in the world, the right of people to

12 think, to speak. Otherwise, where there is no democracy we would only

13 have diktat, like the one we had for 40 years.

14 Q. When the police station was established in Saborsko, substation,

15 you said there was some 30 policemen there of the Ministry of the Interior

16 of the Republic of Croatia. Where were they deployed and what duties did

17 they perform?

18 A. Regular daily police work, that's what they did. Check-points,

19 beat duty, patrol duty, keeping public law and order, providing public

20 security. Because the Zagreb-Split railway had already been blown up, a

21 para-revolution was underway, there were barricades, and the task was to

22 keep the traffic flowing.

23 MR. MILOVANCEVIC: [Interpretation] Just another brief question,

24 Your Honours.

25 Q. You said that there were no barricades in Saborsko but in other

1 areas. You're speaking of some kind of railways being blown up somewhere

2 else. Are you trying to tell us what the task of the police in Saborsko

3 was?

4 A. The Zagreb-Split railway was under our authority. It was we who

5 went to carry out an on-site investigation. The D road, we were active

6 there, too. That was also part of our duty.

7 Q. Thank you.

8 MR. MILOVANCEVIC: [Interpretation] Your Honours, now is the time

9 for a break, if Your Honours agree.

10 JUDGE MOLOTO: Thank you, Mr. Milovancevic, Your Honours do agree.

11 Shall we take a short break and come back at half past 12.00. Court

12 adjourned.

13 --- Recess taken at 12.02 p.m.

14 --- On resuming at 12.33 p.m.

15 JUDGE MOLOTO: Yes, Mr. Milovancevic.

16 MR. MILOVANCEVIC: [Interpretation] Thank you, Your Honour.

17 Q. You said that the Saborsko police substation was established on

18 the 1st of April, 1991, and that some 30 policemen carried out the normal

19 police jobs, taking care of public law and order, and that you also had

20 some kind of check-points. Where were they?

21 A. They were in Borik and in Kuselj.

22 Q. In your statement with the Office of the Prosecutor, you mentioned

23 the special policemen from Duga Resa. How many of them were there and

24 when did they arrive in Saborsko?

25 A. About 20 of them.

1 Q. Do you recall when they first arrived in Saborsko?

2 A. I think it was in late July, towards the end of July.

3 Q. And where were they deployed?

4 A. In our police station and also in the Saborsko primary school.

5 Q. In what part of the village was the primary school in Saborsko?

6 A. In the centre.

7 Q. So the special-purpose policemen from Duga Resa were in the

8 primary school. Where was your police station or substation? Was it in a

9 different location?

10 A. Well, I wouldn't call them special-purpose policemen; they were

11 colleagues, and they had side-arms and long barrels. Our station was 2

12 kilometres away from them in the direction of Plitvice.

13 Q. It wasn't I who called these policemen from Duga Resa

14 special-purpose policemen; it was a witness who testified in these

15 proceedings. Members of a special police unit from Duga Resa of the

16 Ministry of the Interior. Were they a special-purpose police unit or not?

17 A. No, these were not special units.

18 Q. These policemen from Duga Resa, did they spend the day in the

19 school or at the check-points?

20 A. They were in the school.

21 Q. Were they in the school all day?

22 A. Yes.

23 Q. They arrived, as you said, in July and left on the 5th of August,

24 1991, during the first shelling, and they spent this entire period in the

25 school?

1 A. No. They arrived towards the end, the 29th or the 30th of July,

2 1991.

3 Q. Is it correct that these policemen from Duga Resa left on the 5th

4 of August, 1991, in the evening, and that on the following day, instead of

5 them, reinforcements arrived from Slunj?

6 A. Yes, that's correct. They left because it was the first time they

7 had come across something like that and they were not psychologically

8 prepared, and they left. It was the first time they had experienced an

9 open attack, that is, shelling.

10 Q. These policemen from Slunj, how many of them were there? How many

11 of them arrived in Saborsko?

12 A. Well, whether it was 20 or less, I don't know, but thereabouts,

13 around 20.

14 Q. And how many days did they stay in Saborsko?

15 A. Only a few days, two or three days. I can't tell you the exact

16 number of days.

17 Q. After their departure, did a police unit from Drezni Grad arrive

18 in Saborsko to help?

19 A. Well, the policemen from Slunj and Drezni Grad, that's all the

20 same. It all belongs to the Slunj police station, and in Drezni Grad

21 there's just an outpost. So it's one and the same police station,

22 actually.

23 Q. On that day, the 5th of August, 1991, you mentioned shelling and

24 you said that in the morning the shells landed mainly next to the church.

25 Did they land next to the cemetery?

1 A. Yes, that's right. They landed by the church because the

2 cemetery's on the right-hand side and also next to the cemetery. That's

3 on the right-hand side of Saborski next to the cemetery and next to the

4 church. The cemetery is even closer.

5 Q. On that evening, the 5th of August, 1991, when the group of

6 policemen from Duga Resa left Saborsko, you said that women, children, and

7 elderly people went with them. How many people left Saborsko that evening

8 with those policemen?

9 A. Well, a large percentage left. I don't know what the number was,

10 but people were afraid, so they left the village.

11 Q. As you cannot tell us what the percentage is, did all the women,

12 children, and elderly people leave Saborsko that evening?

13 A. Well, essentially yes, because on the 6th of August I didn't see

14 anyone in Saborsko. They only came back at around 10.00 on the 6th of

15 August.

16 Q. We've heard testimony here to the effect that after it was left by

17 women, children, and elderly people, only able-bodied adults came back,

18 not women and children.

19 A. That's not true. There were women among those who returned.

20 Saborsko fell on the 12th of November, and there is evidence as to where

21 women and children were located, so they were there.

22 Q. Were you in Saborsko when it fell?

23 A. No.

24 Q. How many bus-loads of women, children, and the elderly went to

25 Crkvenica from Rakovica?

1 A. I don't know; I was in Saborsko.

2 Q. Do you know who organised the departure of women, children, and

3 the elderly from Rakovica by buses to Crkvenica?

4 A. I don't know, maybe the Red Cross, because the Red Cross came back

5 to collect the sick and the infirm with ambulances several days later.

6 Q. Witness Marko Vukovic, who testified in these proceedings, gave

7 evidence that you, members of the police station of Saborsko, and your

8 reinforcements from Duga Resa, Drezni Grad, and elsewhere were deployed on

9 a number of positions inside and around Saborsko.

10 A. Yes, because after that first attack we got deployed in Sivnik and

11 Brdine positions.

12 Q. Is there a hamlet of Tuk, Funtana village, Alan feature or Tuk

13 feature? Did you also have positions there?

14 A. No, Funtana village is where the police outpost is. It's not a

15 hamlet, it's like a street, but there is a hamlet called "Tuk," and Alan

16 Hill also exists.

17 Q. In the statement you gave to the police you said that after the

18 5th of August, 1991, nobody could enter or leave Saborsko, it was

19 practically a closed village. Did you say that?

20 A. Yes. Plaski-Jasenica-Plaski was an axis that was not accessible

21 anymore. We couldn't use the road to go to Plaski.

22 Q. You stated that sometime in the second half of September a group

23 of about 100 men, former natives of Saborsko, arrived. They had been

24 mobilised in Zagreb and came to Saborsko bearing arms. Is that what you

25 stated?

1 A. Yes.

2 Q. We had different evidence as to the number of these men. In some

3 written witness statements we have the number of 150. We had oral

4 evidence there were 120. You say "100." Do you know the exact number?

5 A. I had no occasion to talk to those people or get close to them

6 because I was arrested soon afterwards.

7 Q. Those people who came from Zagreb, they came as a combat unit

8 Saborsko, a company, and their commander was Krizmanic, who also came from

9 Zagreb. They came in a convoy that brought weapons, ammunition, and food.

10 Is that correct?

11 A. Yes. That were rumours, stories that circulated. At the time I

12 didn't know exactly, but I learnt later.

13 Q. What vehicles -- what kind of vehicles were in this convoy?

14 A. Freight vehicles normally used for supply.

15 Q. How many trucks?

16 A. Seven, eight, ten; I don't know. All I know is that it was a

17 convoy.

18 Q. Were all the people in the convoy armed? And if so, what kind of

19 weapons did they have?

20 A. They were armed with long barrels.

21 Q. Did they have automatic rifles?

22 A. Yes, that's the kind of long barrel I mean.

23 Q. Did you hear maybe that they brought anti-aircraft weapons and

24 mortars with them?

25 A. I heard about one or two mortars; whether they were actually

1 operational, I don't know, because I had no chance to find out.

2 Q. That combat unit called Saborsko Company came from Zagreb with a

3 commander appointed in Zagreb, Marko Krizmanic. They bring mortars, other

4 weapons, side-arms. They're wearing uniforms. They have trucks. Who

5 equipped them in Zagreb? The Ministry of the Interior? The Ministry of

6 Defence? The Government of Croatia? Who?

7 A. I don't know.

8 Q. You stated that in addition to Marko Krizmanic, Luka Hodak also

9 arrived. He was president of the Crisis Staff. Whose Crisis Staff?

10 A. He was president of the Crisis Staff in Saborsko, I suppose. I

11 don't know. I wasn't there at the time.

12 Q. What was the purpose of that Crisis Staff? Did it mean the unity

13 of civilian and military authorities?

14 A. I'm not quite clear about that. I don't know whether it was a

15 mixed organ. The name "Crisis Staff" speaks for itself. They had to take

16 care of local affairs. What they had to do with Krizmanic and Luka Hodak,

17 I don't know.

18 Q. That convoy, that company, arrived in Zagreb -- from Zagreb on the

19 23rd or around that date. You were the duty officer. Every day you drive

20 those policemen to their positions. Where were they deployed?

21 A. That's not correct. I was operations duty officer until the 5th

22 of August, and later we all got deployed in our positions. We didn't do

23 the regular police work any longer. Everybody got their assignment and

24 got assigned to Sivnik, Alan Hill, Brdine, and other positions. We didn't

25 do regular police work anymore.

1 Q. So from the 5th of August onwards you were in combat position.

2 Could we put it that way? In addition to your unit that consisted of the

3 members of the police station in Saborsko, this additional company

4 arrived. Where were they deployed? Did they have their own positions or

5 were they just acting as your reinforcement?

6 A. For as long as I was up there, they were not deployed anywhere.

7 We were alone in our positions. I had the impression that they were

8 scared out of their wits, and I could see that from the two men whom I

9 later found in detention with me. But it would have been quite logical

10 for them to be deployed in our positions as reinforcements.

11 Q. You said that after the 5th of August JNA vehicles no longer drove

12 through Saborsko.

13 A. Yes. From the 5th of August onwards, JNA vehicles no longer drove

14 through.

15 Q. You said that four of you left the company of the National Park of

16 Plitvice that employed more than a thousand people in 1989 because you

17 were feeling uncomfortable among Serbs. You said the epicentre of the

18 evil was in Plitvice. You said the JNA intervened in Plitvice, and for

19 the time of the intervention Plitvice were no longer part of Yugoslavia

20 because Croatia was independent by then. In 1991, when this police

21 station operated in Saborsko, was it a part of Yugoslavia or not?

22 A. As far as I know, on the 1st of April, 1991, the Independent State

23 of Croatia was proclaimed and the constitution was adopted later.

24 Q. Does that mean that you, as the police station in Saborsko, and

25 the men who arrived as reinforcement from Duga Resa and Dreznik, for

1 instance, plus this company from Zagreb, does that mean that all of you

2 were not in the territory of Yugoslavia, that it was the territory of

3 Croatia and you represented its armed forces?

4 A. Yes, that's correct. We were in the territory of Croatia. We

5 were not in Bosnia, we were not in Slovenia or in Serbia. We were in

6 Croatia.

7 Q. You said that armed with the weapons you had, you were in your

8 combat positions. Is it the case that during World War II there were

9 Ustashas in Saborsko?

10 A. I don't know and I will not be answering any questions of that

11 kind because I see them as provocation. I was born in 1961, and I regard

12 this as a provocation.

13 Q. You said that Serbs stopped coming to Saborsko because they

14 aspired to Greater Serbia, and you said that you were in Saborsko, armed

15 as you were, as the armed forces of the new Croatian state. Were the

16 Serbs afraid of you? That's why I asked the previous question, not in

17 order to provoke you or to tease you.

18 A. How could they fear us if they were together with us? We were

19 working together as colleagues, and we are still working together to date.

20 I don't understand how they could have been afraid. We were work

21 colleagues, employees of the Ministry of the Interior. I -- we never

22 cared about each other's ethnicity.

23 Q. But you did say you left your previous job in 1989 because you

24 were feeling uncomfortable among Serbs, and Serbs were not coming to

25 Saborsko from some point onwards, so ethnicity did mean something to you,

1 didn't it?

2 A. Now I'm talking about an institution, the Ministry of the

3 Interior. It's completely different from sentiments. We are all

4 receiving our salaries from the same Ministry of the Interior. That is

5 different to what is being sung in taverns and in the streets.

6 Q. Thank you. You said you were admitted to the Ministry of the

7 Interior in December 1990, and in January/February 1991, new insignia was

8 introduced. You called it the historical Croatian coat of arms. Is that

9 correct?

10 A. Yes.

11 Q. Did it coincide with massive dismissals of policemen of Serb

12 ethnicity from the Ministry of the Interior of Croatia?

13 A. No, nothing like that happened. One number of men left, but 70

14 per cent of Serbs in Ogulin stayed. As for Croatian Serbs, policemen,

15 there are many of them who are retired and who are still working today.

16 Q. Does that mean that there were no dismissals of Serbs, Serb

17 policemen, in Croatia on the basis of ethnicity?

18 A. That's correct, because I now have the chance to talk to these

19 people.

20 Q. Thank you. We are talking about 1991, not about these days.

21 A. They were not dismissed. How could we have been working together

22 if they had been dismissed?

23 Q. You said that the company of Saborsko arrived on the 25th of

24 September from Zagreb, under the command of Marko Krizmanic. And on that

25 occasion, several persons were arrested. Can you tell us how many? Nine,

1 or was it a different number, and were they wearing uniforms?

2 A. I know about the arrest of two persons, and I knew those two, they

3 used to be my colleagues, and they were wearing the Militia of Krajina

4 insignia. Those were the only two I saw during my detention; Dusko

5 Jovicic and Drazen Vorkapic.

6 Q. Dusko Jovicic and Drazen Vorkapic were policemen who served

7 together with you in Ogulin just after you got that job. Were they

8 together with you?

9 A. One of them.

10 Q. You said that there were no dismissals of Serb policemen. How

11 come they did not remain on the Croatian police force if they were not

12 dismissed?

13 A. You are confusing things now. We are talking about the police

14 outpost of Plaski.

15 Q. Does that mean that at the time when the police outpost in

16 Saborsko was established a division occurred within the Ministry of the

17 Interior of Croatia between Serb policemen and Croatian policemen?

18 A. That's not true, and the latest developments confirm that.

19 Q. You say those two policemen were in Plasko and remained in Plasko.

20 You were together with them. Were you together with them in Plasko?

21 A. No, in Ogulin. Later I went to Saborsko and they went to Plaski.

22 They worked both in Plaski and in Ogulin.

23 Q. After you left Ogulin, do you know if they continued to work in

24 the police station of Ogulin or they stopped going there?

25 A. I know that they continued to go to Ogulin and to Plaski. Even

1 after all those efforts were made to separate us, we continued to keep in

2 touch.

3 Q. If you continued to keep in touch, can you tell us why they were

4 arrested on that day, on the 24th or the 25th September, 1991, by the

5 independent company of Saborsko?

6 A. They simply happened to be in the wrong place at the wrong time,

7 in those woods, and they were almost immediately released.

8 Q. You said earlier they were exchanged?

9 A. Yes, for an elderly man. I don't know precisely. I wasn't there.

10 Q. You said that out of that group that was arrested on the 25th of

11 September, 1991, by the independent company of Saborsko, two wore the

12 uniforms of the independent Militia of Krajina. What were they wearing?

13 A. This patch that I have on the screen in front of me.

14 Q. That emblem, the Militia of Krajina, was on their uniform, you

15 say. Which part of the uniform?

16 A. It was a sleeve patch.

17 Q. You mean to say just below the shoulder on the sleeve?

18 A. That's correct.

19 Q. That uniform they wore, what colour was it? Assorted or blue?

20 A. The blue uniform that was worn by policemen even before.

21 Q. What kind of trousers?

22 A. Grey with a blue stripe.

23 Q. Do you mean to say that it was the traditional police uniform from

24 earlier times, the blue one?

25 A. Correct, the traditional police uniform from earlier times.

1 Q. We had another witness, Marko Vukovic, before you. He's stated

2 that they were wearing assorted-colour shirts and they had a sleeve patch

3 with a picture of an eagle, not this one. And Witness Vukovic explained

4 that their trousers were civilian, not part of a uniform. So which of the

5 two is true?

6 JUDGE MOLOTO: Sorry, Mr. Milovancevic, before we get an answer.

7 Did Marko Vukovic say they wore assorted-colour shirts or did he say they

8 wore camouflaged shirts?

9 MR. MILOVANCEVIC: [Interpretation] Your Honour, my question was

10 whether the shirt was assorted colour, and by that I meant camouflage --

11 JUDGE MOLOTO: Do say "camouflage."

12 MR. MILOVANCEVIC: [Interpretation] In my mind that's --

13 JUDGE MOLOTO: Do say "camouflage" so that the witness knows

14 exactly what you're talking about. "Assorted colour" could be any

15 assortment of colours. Thank you.

16 MR. MILOVANCEVIC: [Interpretation] Thank you, Your Honour.

17 Q. So this witness, Marko Vukovic, explained they had camouflage

18 shirts and those two men who were captured wore civilian trousers. And on

19 the sleeves of their camouflage shirts they had patches with an eagle, not

20 this emblem that is on your monitor. Which of the two is true?

21 A. I no longer know what they were wearing when they were in the

22 wooded area of Kapela when they were captured, but I saw them in Plaski

23 with this emblem. I talked to those people. I have nothing against them.

24 It's all fine, but they were precisely the people who told me: There is

25 no law here. It's complete lawlessness. I don't know -- we don't know

1 how we are going to get you released. And at that time in Plasko when I

2 was detained, I saw them wearing this emblem, Militia of Krajina.

3 Q. Thank you. Precisely in connection to these insignia and these

4 men, you said in your statement to the OTP that sometime in June 1991 the

5 Serb police changed its insignia and replaced their earlier patches with

6 Militia of Krajina emblems. Do you mean this one that you indicated when

7 you were questioned by the Prosecution?

8 A. I first saw this type of insignia when I was captured and brought

9 to Plaski.

10 Q. On what basis do you claim that persons who wore these insignia in

11 Plaski were members of the Militia of Krajina? Did they say that?

12 A. Well, I talked to them myself while I was detained and -- because

13 there were two former colleagues among them with whom I was on good terms.

14 We had worked together earlier. And at that point when I met them again,

15 they were wearing this type of insignia. I couldn't talk to the other

16 ones, to the riffraff, but I could talk to my former colleagues, and they

17 told me they were unable to help me.

18 Q. Can you tell me how many of these policemen, whom we shall refer

19 to as the Militia of Krajina now, wearing this insignia, the tri-colour

20 flag, and the words "Militia of Krajina," how many of them were in the

21 police station in Plasko when you ended up there as a captive?

22 A. A couple who were working there at the police outpost in Plaski.

23 There was the duty officer downstairs and the commander. I know a couple

24 of them. I don't know what they wore in the streets. I saw only the ones

25 in the building.

1 Q. You said there were a couple of them, or several. Can we conclude

2 there were less than ten? Would that be an approximate number?

3 A. They were -- they were there just for show. The real power in --

4 the real power was in somebody else's hands. They were just puppets.

5 They were not doing anything. We are still discussing back home today

6 what they were doing there because they had no real powers.

7 Q. In your statement to the Prosecution, after you said that the

8 insignia changed in January 1991 and they started wearing the tri-colour

9 flag emblem, you said some new people appeared called Martic's men. Are

10 they the ones whom you saw in the streets of Plaski, the people who were

11 out of control, who did as they pleased?

12 A. That's correct, that's correct. It was those men in

13 multi-coloured uniforms, JNA uniforms, who publicly introduced themselves

14 as such and who had the real power. And they got drunk, they drove JNA

15 vehicles around Plaski, fired shots. They drove me around Plasko. Yes,

16 it was those men, Martic's group. They themselves called themselves

17 Martic's men.

18 Q. Let's clarify another matter, if possible. These men who you say

19 called themselves Martic's men who wore camouflage uniforms, you said

20 these were JNA uniforms. Were they JNA camouflage uniforms on those men

21 who called themselves Martic's police or Martic's men?

22 A. What is the difference between Martic's groups and the JNA? They

23 drank together, they walked around together. They were driving JNA

24 vehicles around. So what's all this about? One day you would see a

25 person in a JNA uniform, the next day in a camouflage uniform like the one

1 worn by Martic's men. They were all one and the same. They were driving

2 around in JNA vehicles. Ljubo Korajlija, he was a man of Martic's. He's

3 the one who captured me, and then there he was, driving a JNA vehicle. So

4 what's the difference?

5 Q. Witness, thank you for this description. Let me ask you

6 something. These men whom you call Martic's men, and you've just

7 described them, it was they themselves who introduced themselves as

8 Martic's men, which is why you refer to them as such. Is that correct?

9 A. Yes. They introduced themselves as such. That was the name they

10 gave themselves, but there were men in JNA uniforms who said they were

11 Martic's men. It was all mixed up. You didn't know who was who. There

12 was someone who was a man of Martic's and he was driving a civilian

13 vehicle one day and a JNA vehicle another day. So what was the

14 difference? It was all one and the same.

15 Q. In order for us to understand this situation I'll ask you the

16 following: These men who wore one uniform one day, you say olive-green,

17 and then camouflage uniform the next day, did you know that they belonged

18 to the police or that they were active military personnel, or were they

19 people from the area who put on those clothes and acted the way they did?

20 A. I don't understand what you mean by "active military personnel."

21 I served in the JNA, and there was a major and a captain first class, and

22 they were all there together. Martic's group drove JNA vehicles around

23 Plasko, and in my view it was all one and the same. There was no

24 difference. I couldn't tell the difference between the JNA and Martic's

25 men. One day they would be wearing one uniform and then the next day the

1 other uniform. I couldn't tell the difference anymore.

2 Q. Just one more question. When you say one day they would be

3 wearing one uniform and the next day the other uniform, are you speaking

4 of one and the same man who would be wearing one uniform one day and

5 another the other day and who introduced himself as a man of Martic's or

6 was it you who called him Martic's man?

7 A. One and the same person, I noticed, would be wearing a camouflage

8 uniform one day, and on the second or third day he would put on a JNA

9 uniform.

10 Q. Thank you. As you were close to Plasko and you were a resident in

11 the area, was there a JNA garrison in Plaski in 1990 and 1991?

12 A. Yes, there was a JNA barracks, yes.

13 Q. What uniforms did the JNA soldiers in the JNA barracks in Plaski

14 wear; a solid colour or camouflage?

15 A. As far as I can remember, they wore olive-grey or olive-green

16 uniforms before. And that was the kind of uniform I myself wore in

17 Macedonia when I was doing my military service.

18 Q. When you were referring to Martic's groups, as you described them,

19 you said that these were men who wore one kind of uniform one day and the

20 other kind of uniform the other day. Were these men different from the

21 ones who were in the JNA barracks in Plaski? Can you say that?

22 A. No. No, I can't say. In my view, it was all the same.

23 Q. You have explained that you were a local man, that you got a job

24 in the police, together with these two other policemen who were imprisoned

25 by the Saborsko company in 1991, and when you were brought in you appealed

1 to them for help. And you said that they tried to do everything in their

2 power. Is that correct?

3 A. Yes.

4 Q. Does this mean that they did not wish to maltreat you or kill you

5 or hurt you in any way? They wanted to help you but it was not physically

6 possible because there were too few of them?

7 A. They couldn't help me because nobody respected their authority.

8 It was the groups of Martic's men and the JNA who were in power. They

9 were just there for show. They were nothing. They counted for nothing.

10 My colleague Dusko Jovicic said to me: There's lawlessness here. I saw

11 men driving JNA vehicles around, firing shots, drinking, changing

12 uniforms, and they were there just for show and nobody respected their

13 authority.

14 Q. Just one more question about the situation in Plaski. These men

15 of whom there were few and who were the real Martic's police, you say they

16 wore Milicija Krajina patches on their sleeves, they wanted to help you

17 but they couldn't; there were few of them, they were unable to keep law

18 and order because of the situation prevailing in the village. Is that

19 correct?

20 A. Yes.

21 Q. And one more question. When you speak of Martic's groups, is that

22 the term you used to describe all those other people who wore one uniform

23 one day and a different uniform on another day and who drove vehicles

24 through the village, one would be driving and the other would be firing

25 through the window from an automatic rifle? Are those the groups you are

1 referring to?

2 A. Yes, yes.

3 Q. Why do you think those people were Martic's group if it was

4 Martic's policemen who were trying to help you but couldn't,

5 unfortunately?

6 A. They were my colleagues. They were not Martic's policemen. They

7 just happened to be where they were. Don't mix up Martic's groups with

8 those few lads who were my colleagues. I am on good terms with them

9 today, and as for Martic's groups and the JNA, they were hooligans. They

10 were people of the streets, and these were my colleagues who were forced

11 to be there. And they were my colleagues, they tried to help me. You

12 keep trying to --

13 Q. I understand you, Witness. Did the Ministry of the Interior of

14 Croatia in September 1991 in relation to these men who you call Martic's

15 police who wore Cyrillic insignia, was it the Ministry of the Interior of

16 Croatia that gave them those uniforms?

17 A. No, no. Everybody knows where those insignia came from.

18 Q. Where?

19 A. The Republic of Serbian Krajina, the militia of the Krajina.

20 Q. Thank you.

21 You mentioned that when you were captured, this was on the 29th of

22 September, 1991, and that you were in your own vehicle, in your own car

23 with two other men and that you were going towards Rakovica through a

24 forest road -- by a forest road. Did I understand you correctly?

25 A. Yes.

1 Q. You were in uniform, as were the other two. Is that correct?

2 A. Yes, that's correct.

3 Q. Were all three of you armed?

4 A. Yes, we were. I had my side weapon and my long barrel, and they

5 only had their long barrels.

6 Q. Who was it who stopped you and arrested you and captured you?

7 A. It was an ambush on the Rakovacke Uvale forest road. Five or six

8 men in camouflage uniforms ambushed us, and there was one among them in

9 the olive-grey uniform of the JNA. They were all local people from Plaski

10 whom I knew from before.

11 Q. When you say that there were five or six men there, one of them in

12 an olive-grey uniform and the others in camouflage uniforms, did the

13 camouflage uniforms also belong to the JNA? Were they the kind of

14 uniforms that the JNA was using?

15 A. I don't know what kind of combat uniforms or camouflage uniforms

16 the JNA had. What I know is that the JNA had olive-grey uniforms. I

17 don't know about any other uniforms the JNA may have had, but there was

18 one such uniform, one JNA uniform there, and the others were all in

19 camouflage. And it was the one in the olive-grey uniform who was the

20 leader because he was the one who knew the ground.

21 Q. You say that the men were wearing these uniforms. Do you know

22 whether they were reservists mobilised into the JNA, whether they were

23 territorial -- members of the TO, or were they active-duty JNA soldiers?

24 A. They were my acquaintances from Plasko, Ljubo Korajlija among

25 them. They were idle people, loafers, and he was wearing a camouflage

1 uniform. The only one whom I don't know is the one in the JNA uniform.

2 He was leading them towards the military training ground. They were local

3 people from Plaski.

4 Q. One more question. The one who arrested you and the others you

5 recognised as residents of Plaski, were they the people who you say wore

6 one uniform one day and a different uniform the other day?

7 A. Yes, yes, it was those people.

8 Q. Saborsko is a village along the road, and it's the road leading

9 towards Ogulin via Plaski. Is that correct?

10 A. Yes.

11 Q. Can you tell me where the road goes on after Ogulin? Does it go

12 towards Karlovac?

13 A. Karlovac-Ogulin-Zagreb.

14 Q. Is Saborsko a village stretching a few kilometres on both sides of

15 this road which buses through it?

16 A. Yes. The road goes down the middle of the village and there are

17 houses on the left and right side of the road.

18 Q. You said that near Saborsko there was a barracks in Licka

19 Jasenica. Was there a railway line running through Licka Jasenica?

20 A. Yes.

21 Q. You said that in Licka Jasenica the former JNA also had a fuel

22 depot. Is that correct?

23 A. Yes, that's correct.

24 Q. You mentioned the JNA vehicles passing through Saborsko. On the

25 other end of Saborsko and in the vicinity of Saborsko, was there a big

1 military training ground, the Slunj training ground?

2 A. Yes. The JNA training ground. It was called Tobolic at the time.

3 Q. Was this a large JNA training ground where the army practiced

4 shooting and manoeuvres and was there a reserve command post there of the

5 5th Military District of the then-JNA; do you know that?

6 A. I don't know that. All I know is there was a large training

7 ground of the former JNA there, between Slunj and Saborsko.

8 Q. Thank you. You said that there was a change of insignia on the

9 uniform of the Croatian police, the police of the Republic of Croatia, in

10 January or February 1991. Do you know when the ZNG was established, the

11 National Guard Corps of Croatia?

12 A. You mean the Croatian army?

13 Q. Am I to understand your question as meaning that the ZNG is the

14 Croatian army?

15 A. Yes, the National Guard Corps was being created, and to this very

16 day it has been transformed into the Croatian army.

17 Q. Do you know when the ZNG was created as the Croatian army, and was

18 it in Saborsko? Was it there?

19 A. No, not in Saborsko. There wasn't any ZNG in Saborsko at the

20 time, or any Croatian army.

21 Q. And do you know when the first units were formed and when they

22 were deployed in the larger towns and villages?

23 A. I don't know because we were surrounded. We had no electricity in

24 Saborsko up to the time I was arrested, so we were very poorly informed

25 because we didn't have access to the media. What was happening in Zagreb,

1 Karlovac, Rijeka, Split, and so on, we didn't get this information because

2 we were isolated, we were surrounded.

3 Q. As the crow flies, how far is Licka Jasenica from Saborsko? Do

4 you know the approximate distance?

5 A. Well, as the crow flies -- well, you can see that. It was JNA

6 barracks there.

7 Q. The armed forces from Saborsko, did they fire on the barracks in

8 Licka Jasenica in the summer and autumn of 1991?

9 A. What with? It was too far to be able to fire shots from a rifle

10 there.

11 Q. Were mortars used? That's what I meant.

12 A. We didn't have one, so how could we?

13 Q. On the 25th of September, 1991, the Saborsko company arrived and

14 there's information to the effect that mortars also arrived. If you don't

15 know that they brought mortars, then I won't put any questions to you. Do

16 you know about the mortars or not?

17 A. Well, you're asking me questions about things I didn't see because

18 I wasn't there. I had already been arrested so I saw what was going on in

19 the Krajina more than I saw what was going on up there.

20 Q. You mentioned your arrest. From Plaski you were taken to Titova

21 Korenica, and after that somewhere else. The attitude of those who were

22 not Milicija Krajina towards you, was it the same as in Plasko? In other

23 words, were you maltreated by people who were not members of the police?

24 A. Well, of course I was. It was people in camouflage uniforms and

25 the JNA in olive-drab uniforms who maltreated me, both of them. And again

1 they called themselves Martic's men, those people who I didn't know.

2 Q. Are you trying to say that these were again people who did

3 whatever they wanted?

4 A. It was the same in Plaski as it had been in Korenica; there was

5 lawlessness there.

6 Q. Thank you. You said that when you were admitted to the Croatian

7 police you didn't hear of dismissals of Serb policemen. Did you hear of

8 dismissals of Serbs from their jobs at those -- at that time when the

9 referendum was held and the elections?

10 A. We have information about people who are still in high-ranking

11 positions, who have been doing those jobs for 10, 20, 30 years, and they

12 are still there. I don't know anything about what you're saying. I have

13 an example in Ogulin where I live, in the forestry, in the health care

14 centre. People are still doing their jobs. Nobody did anything to them.

15 I don't know where these insinuations come from. You can go there and

16 check for yourself in the area where I lived and worked. All this is not

17 true.

18 Q. Not true. So nobody lacked anything on the Serb side. Is that

19 what you're trying to say?

20 A. People are still doing their jobs, to this day.

21 Q. Thank you, Witness. That's enough. You said that on the 29th of

22 September, 1991, you were arrested. You described your movements, and you

23 said that you returned to Saborsko in 1995 after Operation Storm and you

24 explained that you found Saborsko razed to the ground. Is that correct?

25 A. Yes.

1 Q. You said that in one house you found an elderly woman or a young

2 woman on her bed and she had been burned. Is that correct?

3 A. Not one elderly woman, but more than one. Burned in their homes.

4 We found their bodies and their bones.

5 Q. In a village that has been razed to the ground where there are no

6 houses, how could you find a body on a bed?

7 A. What I said was on the charred remains of the house.

8 Q. You're saying that these people were burned. Do you draw a

9 distinction between a situation where somebody burns in a house which has

10 been set on fire or someone who is set alight in a conflagration?

11 A. I don't know what you're talking about. People were found -- or

12 rather, their skeletons were found on the charred remains of their homes.

13 And you would find only their glasses because the glass didn't melt. We

14 didn't even find any clothes, only bones.

15 Q. Do you know that there was fighting for Saborsko?

16 A. When?

17 Q. In November 1991 -- excuse me. That's the time I'm referring to.

18 You said you heard in hospital in November 1991 that Saborsko had fallen.

19 Do you know that there was fighting in November 1991 in Saborsko?

20 A. That there was fighting for Saborsko?

21 Q. Yes.

22 A. Saborsko was burnt in November 1991. On the 12th of November, it

23 was all burnt.

24 Q. How do you know that when you weren't there?

25 A. I saw it in 1995 when I got back, and there were eye-witnesses. I

1 didn't want to talk about this, but you're asking me about it, because I

2 wasn't there.

3 Q. I'm simply putting questions to you and checking what you said.

4 I'm not trying to get you to say something. At the time of the fighting

5 in Saborsko, were you in Saborsko, and you said you weren't. You say that

6 in 1995 you found the village razed to the ground and that you found some

7 bodies. My next question to you is: Did you say that you attended

8 exhumations and that there were three burial sites where you attended

9 exhumation?

10 A. I didn't say that. I said that we found some bodies. After 1995

11 the identity of the persons was established. Seven people are still

12 listed as missing. As for the ones we exhumed, their identity was

13 established at the forensic institute in Zagreb.

14 Q. In those three burial sites, had those persons been buried before

15 you found them in the mass graves? Had they been buried there?

16 A. A very good question. They were thrown into a pit. It wasn't a

17 proper burial. It was a pit where there was rubbish, trash. They were

18 simply thrown into a pit.

19 Q. As you were not there in 1991, do you know who did this?

20 A. Well, it wasn't an alien from outer space. People know who did

21 those things.

22 Q. Do you know who did it?

23 A. Of course. Who did it. Who was the one who had planes, tanks,

24 mortars, rocket launchers? The people I saw in Plaski and Korenica, they

25 were the ones who did that.

1 Q. That's your conclusion because they were there at the time and had

2 all those weapons. Is that correct?

3 A. Yes, of course.

4 Q. Do you know how many people from the armed company of Saborsko

5 were killed in the fighting for Saborsko?

6 A. The independent armed company?

7 Q. Yes.

8 A. I don't know. I don't know who was killed. I only know about my

9 colleagues who were killed. I wouldn't know about the company. I don't

10 think they were killed, but I don't -- I wouldn't really know. I only

11 know about my colleagues.

12 Q. Can you tell us how many colleagues of yours were killed as

13 fighters in Saborsko in November 1991?

14 A. Eleven.

15 Q. You said that -- you said that after returning to Saborsko you

16 kept on the Saborsko-Plaski line. The Prosecutor asked you about the

17 houses in Saborsko and their condition. What about the houses in Plasko?

18 A. I -- here's where I take responsibility. 219 civilians remained

19 there; all of them are safe and sound. We still drink coffee together.

20 After the crime, there were no crimes committed. If there was any burning

21 of houses, that was punished. We found perpetrators, and immediately

22 after it was done, we performed on-site investigation.

23 Q. Who was it?

24 A. Individuals, but all the post offices, churches, school buildings

25 there remained intact. There was no crime after the crime.

1 Q. Which time period are you talking about? You're talking about the

2 Operation Storm 1995. Is that what you're talking about?

3 A. That's what you asked me.

4 Q. How many houses were burned in Licka Jasenica?

5 A. I don't know exactly how many, but in all cases almost we found

6 perpetrators. There are some unelucidated cases but there were no

7 killings, thank God.

8 Q. Did you take part in operations during the Operation Storm, such

9 as when Licka Jasenica was taken control of by the armed forces?

10 A. No. We took over Plaski and Licka Jasenica the day after in order

11 to maintain law and order.

12 Q. Do you know what happened to other places in the area, Krajina,

13 during Operation Storm?

14 A. No, I don't know because I didn't live or work there. I know only

15 about those places where I spent any time.

16 Q. Do you know that in the southern part of Krajina 22.000 Serb

17 houses were burned down during Operation Storm?

18 A. I don't know. I don't know how much was burned in that area. I

19 don't have such information. Let us concentrate on the areas of which I

20 have some experience. Plaski and Licka Jasenica contain about 4.000

21 houses. That's a large number. I just want to say that I'm proud that

22 there were no additional crimes committed after the crime in 1995.

23 Q. How many houses did you say there were in Plaski?

24 A. The population was 4.000.

25 Q. You said after the Operation Storm, around 200 or 300 remained?

1 A. With the surrounding area, because the surrounding area is big.

2 Q. How many people remained?

3 A. 219.

4 Q. Out of 4.000?

5 A. No, not 4.000. 4.000 was with the surrounding area. Plus some

6 people are returning now.

7 Q. What about the surrounding areas that had a Serb population after

8 the Operation Storm, was there any burning of houses? Were there any

9 casualties?

10 A. Which places? Name them.

11 Q. What about the surrounding villages of Saborsko? Are there any

12 Serb populated places, do you know?

13 A. Where we were, where we lived, or further afield?

14 Q. Name some Serbian villages.

15 THE INTERPRETER: Could the witness please name these places more

16 slowly. The interpreters ask the witness to repeat the places. This is

17 not possible to interpret.

18 JUDGE MOLOTO: Can we interrupt? The interpreters are saying:

19 Will the witness please name the places. However, when I look at the

20 transcript, the interpreter was asking counsel to name the places because

21 she seemed not to know what places counsel was talking about. If you look

22 at line 22 at page 81, he says: Which places? Name them. And then the

23 next question was: What about the surrounding villages of Saborsko? They

24 were not named. So it doesn't look like there was any name that the

25 witness was able to give.

1 THE INTERPRETER: The witness gave a rapid enumeration of many,

2 many places, very fast. That's what we would like him to repeat.

3 JUDGE MOLOTO: Okay. I'm told the witness, you named a number of

4 places very fast that would like -- the interpreters would like you to

5 repeat those names.

6 THE WITNESS: [Interpretation] Licka Jasenica is the next place to

7 Saborsko. Let me go on. Begovac, Vezmari, Ogrizovici, Blata, Plavca

8 Draga. All these are hamlets. Plavski, Latin, Vojniva [phoen] --

9 JUDGE MOLOTO: Are these all Serb villages?

10 THE WITNESS: [Interpretation] Yes, all of them are Serb villages.

11 JUDGE MOLOTO: You may proceed, Mr. Milovancevic. I'm sorry about

12 that.

13 MR. MILOVANCEVIC: [Interpretation]

14 Q. You mentioned Blata also in addition to Ogrizovici, it's also a

15 Serb village, isn't it?

16 A. Yes.

17 Q. All these Serb places, is it the case that they are mainly vacant

18 now, devoid of Serb population or any population at all?

19 A. That's not quite true. Many people returned and live there now.

20 Q. I'll ask you a very brief question. We are close to adjournment.

21 I didn't ask if any returned. I asked: Is it the case that these places

22 were vacated, emptied, during Operation Storm?

23 A. I don't know what you mean when you say "emptied, vacated."

24 Q. The Prosecutor knows what I mean. It is contained in his

25 allegations.

1 MR. MILOVANCEVIC: [Interpretation] Thank you, Your Honour. I have

2 finished my questioning.

3 JUDGE MOLOTO: Have you finished your cross-examination of the

4 witness?

5 MR. MILOVANCEVIC: [Interpretation] Yes, Your Honour. Thank you.

6 JUDGE MOLOTO: Thank you very much.

7 Mr. Vukovic, you will still have to come back tomorrow because you

8 must still be re-examined by the Prosecution and there may be questions

9 from the Bench. Court is going to adjourn now, now until 9.00 tomorrow

10 morning. Court adjourned.

11 --- Whereupon the hearing adjourned at 1.49 p.m.,

12 to be reconvened on Tuesday, the 28th day of

13 March, 2006, at 9.00 a.m.

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