Tribunal Criminal Tribunal for the Former Yugoslavia

Page 2978

1 Friday, 31 March 2006

2 [Open session]

3 [The accused entered court]

4 [The witness entered court]

5 --- Upon commencing at 9.04 a.m.


7 [Witness answered through interpreter]

8 JUDGE MOLOTO: Mr. Krupic, I remind you that you are still bound

9 by the declaration you made yesterday to tell the truth, the whole truth,

10 and nothing else but the truth. Okay? Thank you.

11 THE WITNESS: [Interpretation] Yes.

12 JUDGE MOLOTO: Can somebody remind me where are we? Are you still

13 cross-examining, Mr. Milovancevic?

14 MR. MILOVANCEVIC: [Interpretation] Yes, Your Honour.

15 JUDGE MOLOTO: Thank you.

16 Cross-examination by Mr. Milovancevic: [Continued]

17 Q. Witness, in the statement you gave to the Office of the

18 Prosecutor, the statement of 1999, you say that when the war broke out in

19 Croatia, at the beginning, propaganda was spread on the radio which fanned

20 the flames. You said that questions were put in radio shows such as,

21 "What do you think about Franjo Tudjman?" And you say the shows were

22 designed to heat up the nationalistic feelings of the Serbs, is that what

23 you said?

24 A. Yes, that's what I said.

25 JUDGE MOLOTO: Mr. Milovancevic, aren't you supposed to be

Page 2979

1 cross-examining on Red Berets?

2 MR. MILOVANCEVIC: [Interpretation] Yes, Your Honour, but

3 yesterday, with leave of the Chamber, I was given leave to raise issues

4 that were mentioned by the Prosecution but were not in the statement

5 disclosed to the Defence. The entire testimony of the witness yesterday

6 contained facts that are almost absent in the statement, 90 per cent of

7 his testimony referred to new issues.

8 JUDGE MOLOTO: The question you just put is in the statement. I

9 don't remember it being canvassed yesterday by the Prosecutor but it is in

10 the statement so it couldn't be one of the questions raised by the

11 Prosecutor which are not in the statement. Can we please stay on what we

12 are supposed to do? We have got to finish this case as soon as possible.

13 MR. MILOVANCEVIC: [Interpretation] Yes, Your Honour. I'll do

14 that.

15 Q. In your statement to the Office of the Prosecutor, yesterday,

16 during the examination-in-chief, you stated that the chief of the SUP in

17 Bosanski Novi was a Serb whose last name was Umicevic and who was a just

18 man but was later killed by the Serbs. It's all in your statement. On

19 page 5 of your statement, you said that in the spring of 1992, a meeting

20 or a rally -- a meeting was held of the trade union representatives in

21 Sarajevo, that Umicevic was the chief of police, and that he strongly

22 advocated a unified police, and that several days later he was killed in

23 Bosanski Novi. Is that what you stated?

24 A. Yes.

25 MS. RICHTEROVA: Your Honour, when Mr. Krupic is asked whether it

Page 2980

1 is correct from his statement, he needs to have the statement in front of

2 him.

3 JUDGE MOLOTO: Can we have the statement in front of the witness,

4 please?

5 MR. MILOVANCEVIC: [Interpretation]

6 Q. To jog your memory, Witness, on page 3 of your statement, dating

7 from 1999, you spoke about Mr. Umicevic, the chief of the SUP, whom you

8 said was a just man, who was later killed by the Serbs, and on page 5 of

9 your statement, you say, "and he was strongly in favour of remaining a

10 unified police force," referring to the meeting in spring of 1992. A few

11 days later he was killed in Bosanski Novi. Is that correct?

12 A. Your Honours, I wish to clarify this, if possible.

13 Q. Go ahead, Witness.

14 A. It is true that I attended the meeting of the republican police

15 union because I was a shop steward from my police station in Bosanski

16 Novi. Before going to this meeting, I was sitting with the late

17 Mr. Umicevic and we were discussing the issues such as the division of the

18 police and that was to be the topic of the meeting in Sarajevo. He firmly

19 adhered to the standpoint that the police should never be divided along

20 ethnic lines. These were the positions I advocated in public at the

21 police union meeting in Sarajevo. All the police stations of the then

22 Bosnia-Herzegovina voted for a unified police force, except for Drvar and

23 Grahovo. These were the only two police stations that expressed a desire

24 to divide the police. Mr. Umicevic was a true democrat. He was not a man

25 who supported ethnic divisions. He was in favour of multi-ethnicity, and

Page 2981

1 the very fact that after his murder, on the day of his funeral, on the

2 left bank of the river Una, one could hear shooting in celebration, in

3 joy, and that in itself shows who it was that killed him. Thank you.

4 Q. Do you link the death of Mr. Umicevic to his advocating a unified

5 police force?

6 A. Certainly. Mr. Umicevic was in the way of certain lobbies. He

7 was an obstacle to them. His murder, I cannot say whether it was done on

8 purpose or out of negligence, but it is a fact that the man disappeared in

9 the given circumstances.

10 Q. In your statement, you also said that Mr. Umicevic happened to be

11 in a cafe when there was some kind of fight that broke out, that he came

12 to this cafe and was sitting with the cafe owner. As it was reservists

13 who were fighting among themselves, the military police arrived and a

14 shot -- a stray shot hit him.

15 A. It was a Wednesday. I think it was the 8th or the 10th of

16 February 1992. I'm almost sure it was the 8th. He was on his way home

17 from work and, as he lived in the same building where this cafe was, and

18 there had already been fights in that cafe between the cafe owner and the

19 reservists from the SAO Krajina, so he went into the cafe to see what was

20 going on. As he knew the cafe owner, he sat down with him in order to see

21 what was going on and what the conflict was about. In the meantime Nikola

22 Krneta, who had before that engaged in a fight with the cafe owner, went

23 to Matijevici to fetch his machine-gun and returned and fired shots into

24 the cafe from outside and hit Mr. Umicevic.

25 JUDGE MOLOTO: Mr. Milovancevic, I really don't want to interfere

Page 2982

1 with your cross-examining but I don't see how these questions relate to

2 the Red Berets, and when these questions are issues that were contained in

3 the witness's statement, a copy of which you were supplied with.

4 MR. MILOVANCEVIC: [Interpretation] Your Honour, all the matters

5 that the witness is talking about are things that the Defence wishes to

6 check, in order to see whether the killing of the police chief in Bosanski

7 Novi was linked to some kind of plan to have other forces take power in

8 Bosanski Novi, whether it was the Serb forces, whether it was the SDS,

9 whether even Serbs who opposed this were eliminated. That's what I'm

10 attempting to check. I will -- I will now finish this topic; however, I

11 have no further questions about it to the witness.

12 JUDGE MOLOTO: I don't dispute what you want to check. That is

13 what you may want to check. But the procedure is that when this witness

14 comes as a 92 bis witness, he's going to be cross-examined only on the Red

15 Berets. The only exception was to deal with issues that were raised by

16 the Prosecutor which were not contained in the witness's statement. You

17 are now dealing with issues that are in the witness's statement, which are

18 not related to Red Berets. That's all I'm saying to you.

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

20 JUDGE MOLOTO: Please keep relevant before we start having to rule

21 questions out of order.

22 MR. MILOVANCEVIC: [Interpretation]

23 Q. Witness, you spoke about how Hrvatska Kostajnica fell into Serb

24 hands when answering questions put to you by the Prosecutor yesterday.

25 You stated that you went to Bosanska Kostajnica where the Croatian members

Page 2983

1 of the Croatian MUP were crossing the bridge and handing over their

2 weapons on the Bosnian side. You said they were putting their weapons on

3 a pile and that local Serb civilians took those weapons in the presence of

4 the army and the police. Is that what you stated?

5 A. Yes.

6 Q. You said that a certain policeman from Knin called Popovic was the

7 man disarming the Croatian policemen. Is that correct?

8 A. I'm not sure whether his last name was Popovic or Ivanovic. I

9 think it was Ivanovic. His first name was Goran. He was searching those

10 men and taking them to a local community centre or cinema or something of

11 that sort and there, they robbed them.

12 Q. In your statement, on page 6, in paragraph 2, that's the statement

13 from 1999, you say that the SDS openly armed the citizens of Serb

14 ethnicity in Bosanski Novi and that the Territorial Defence of Bosanski

15 Novi had disarmed 380 Croat police. Which of these two statements is

16 correct? First, it was stated that the Serb policemen from Knin disarmed

17 these Croat policemen and here you say it was the Territorial Defence of

18 Bosanski Novi that did that.

19 A. I'll try to clarify that, Your Honours. As regards the arming of

20 the Serb people, it's an indisputable fact that it was the former JNA who

21 armed the Serb population, both in towns and in villages. I socialised

22 with Serbs. I had more Serb friends than Muslim friends, because I

23 happened to live in such an environment. And my friends told me that

24 weapons had been offered to them and even if they said they didn't want

25 weapons, they were told they would be expelled from Bosanski Novi if they

Page 2984

1 didn't take them. As for the surrender of the policemen in Bosanska

2 Kostajnica, they were crossing the bridge and on the right-hand side of

3 the bridge looking from the direction of Hrvatska Kostajnica, they took

4 off their weapons and threw them on a pile. It was already twilight,

5 dusk. Villagers, local people, approached the pile and took weapons.

6 Martic's police, under the leadership of either Ivanovic or Popovic, whom

7 I knew personally and whom I saw, and I heard from my colleagues that they

8 were practically only observers there.

9 Q. In order to be perfectly clear on what you're talking about, was

10 that the situation when after the fighting in Croatia, in the territory of

11 the Republic of Croatia, in Hrvatska Kostajnica, there was a defeat of the

12 Croat forces and then they crossed over to the Bosnian side and

13 surrendered weapons? Is that the event that you're describing?

14 A. I'm talking to -- I'm talking about what happened when there was a

15 conflict in SAO Krajina and when the members of the MUP remained under

16 siege in Hrvatska Kostajnica. Since they had no further supplies, no

17 food, nothing, they decided to surrender, and I know that one of their

18 doctors, during of the course of the day crossed over with a white flag

19 and that is when they indeed surrendered after negotiations. They

20 surrendered by the evening.

21 JUDGE MOLOTO: Could you speak slowly, please, Mr. Krupic when you

22 testify? I hear the interpreter really rattling very fast trying to keep

23 pace with you.

24 THE WITNESS: [Interpretation] Thank you.

25 MR. MILOVANCEVIC: [Interpretation]

Page 2985

1 Q. If I understood what you were saying, Mr. Krupic, what is written

2 on page 6 of your statement is not correct, that is that they were

3 disarmed by the Territorial Defence of Bosanski Novi but rather it was

4 done by these people that you're talking about, this Popovic or whatever

5 his last name may be?

6 A. The TO was there. The TO of Bosanski Novi. They were in Bosanska

7 Kostajnica, but I am talking about the search of persons and the seizure

8 of valuables, including jewellery. This was done by the group headed by

9 Ivanovic. I think Ivanovic was the name. Whereas the TO was present and

10 they organised the surrender itself.

11 Q. Please listen to what I'm asking you, Mr. Krupic. The disarming

12 of the Croatian MUP was carried out by the Territorial Defence of Bosanski

13 Novi. That's what you confirmed just now; isn't that right?

14 A. I don't know. I don't know what I should call this.

15 JUDGE MOLOTO: Mr. Krupic, the Prosecutor is on her feet.

16 MS. RICHTEROVA: I'm sorry, but when quoting that statement, it

17 says, in that paragraph, that Territorial Defence had 380 disarmed Croat

18 police on the list, not that they disarmed them.

19 JUDGE MOLOTO: Thank you, Ms. Richterova.

20 You can see that, Mr. Milovancevic?

21 MR. MILOVANCEVIC: [Interpretation] No, I don't see that because

22 that's not what's written there.

23 Q. Witness, could you please look at page 6 of your statement, the

24 one that you gave to the Prosecutor in 1999? And in the second paragraph,

25 could you read the third sentence?

Page 2986

1 A. Sorry, but these are just excerpts from my statement. I haven't

2 got my entire statement.

3 Q. These are excerpts that the OTP provided to us and then we

4 photocopied it and gave it to you.

5 A. But it's just excerpts. I haven't got my proper statement.

6 MS. RICHTEROVA: We disclosed the proper statement and yesterday

7 the witness had the statement. I think he has the statement from 2002.

8 THE WITNESS: [Interpretation] No. Yesterday, again, I had only

9 these excerpts. I didn't have it yesterday either.

10 MR. MILOVANCEVIC: [Interpretation]

11 Q. Witness, do you have a piece of paper before you that says, "The

12 International Tribunal for the Prosecution of persons," and the number

13 that you have is on that page is the last number 120?

14 A. Yes.

15 Q. That text has a stamp of the International Tribunal in the bottom

16 right-hand corner; is that right?

17 A. Yes, that's right.

18 Q. So please look at that page, or rather that text, please go up to

19 page 6. The last digits are 125. That's the B/C/S version.

20 A. I haven't got that.

21 MR. MILOVANCEVIC: [Interpretation] Could the usher kindly show me

22 the document? I gave the same statement to the witness yesterday. Could

23 I just see whether the pages are mixed up or something?

24 Your Honour, indeed, I gave the witness an incomplete text, a few

25 pages are missing. I probably got the pages mixed up while bringing them

Page 2987

1 in. I would kindly ask my learned friend of the Prosecution to help me if

2 she has a proper copy of that statement. It would be important. It would

3 be important because the witness is saying that it's not his statement.

4 MS. RICHTEROVA: Yes, I have it.

5 MR. MILOVANCEVIC: [Interpretation]

6 Q. Witness, I've asked you to look at the statement that you gave to

7 the Prosecutor on the 22nd of August 1999. Could you please look at the

8 page that has in the upper right-hand corner a number ending with digits

9 125, and also it has number 00913301 underneath that. The text reads as

10 follows. "The Territorial Defence of Bosanski Novi disarmed 380 Croatian

11 policemen, according to a list." So there should have been 380

12 short-barrelled and long-barrelled guns.

13 Then you say that this was not found in the warehouse. Is that

14 what is written in the statement you gave to the Prosecutor?

15 MS. RICHTEROVA: I'm really sorry to -- it says, in English

16 version, which was taken by the investigator, that Bosanski Novi

17 Territorial Defence had 380 disarmed Croat police on the list. So there

18 should have been 380 long- and short-barrelled weapons.

19 So the original version doesn't say that TO disarmed but the TO

20 had them on the list.

21 JUDGE MOLOTO: I can see the difference, Ms. Richterova. The

22 question is -- I don't know now whether the person who translated the

23 statement of the witness made a mistake or, I don't know. I think the

24 witness will have to explain what the difference is. You see the problem,

25 Mr. Milovancevic? What you have just read out to the witness, I'm sure in

Page 2988

1 B/C/S, is different from what is in the English version.

2 MR. MILOVANCEVIC: [Interpretation] I understand, Your Honour. I'm

3 going to put this difference to the witness and I'm going to ask him

4 whether what it says in B/C/S is what he stated to the OTP or not. I'm

5 going to remind the witness that the complete text that refers to these

6 3830 Croatian policemen reads as follows, "The termed of Bosanski Novi

7 disarmed 380 Croatian policemen according to the list, so there should

8 have been 380 pieces of long-barrelled and short-barrelled weapons. Only

9 five or six pistols and 12 or 13 rifles were handed over to the TO

10 warehouse."

11 Q. Now, the question is, is this the statement that the witness gave

12 to the OTP?

13 A. In the context of the surrender of these members of the MUP, I

14 probably did say this sentence, but in fact nobody took weapons from these

15 people. But they themselves when they crossed over the bridge they threw

16 them on a pile. So ordinary citizens of Serb ethnicity took these weapons

17 from the pile. And I know of these personal searches and when these

18 people were being brought in. That was done by the members headed by

19 Ivanovic.

20 MR. MILOVANCEVIC: [Interpretation]

21 Q. You know that because somebody told you about that; is that right?

22 A. Yes. I mentioned yesterday who it was, who said that to me, and I

23 was present myself.

24 Q. Thank you. Witness, on page 6 and yesterday when responding to

25 the Prosecutor on the basis of page 6 of your statement from 1999,

Page 2989

1 reference was made to the breakdown of the command structure of the

2 police, but on page 5 of your statement, the text starts as follows: "The

3 police split up in Bosanska Krupa and Hrvatska Kostajnica." What police

4 are you referring to and what split-up are you referring to?

5 A. I don't see how this happened in Hrvatska Kostajnica. I know that

6 there was a split in the police in Bosanska Krupa.

7 Q. Thank you.

8 A. And this is probably in context. Hrvatska Kostajnica fell on that

9 same day when the delegation of the republic trade unions was travelling

10 back so it was probably on that day.

11 Q. On this same page, 5, of your statement, when you talk about the

12 situation with the police in Bosanski Novi, you say that there was -- you

13 say that there was a breakdown in the command structure of the police.

14 Opposite orders came from the republic and from Banja Luka." Could you

15 please explain this to us when orders are coming from the republic and

16 when orders are coming from Banja Luka?

17 A. It's quite simple to explain. The dispatches that came from the

18 then-republican MUP were not binding on anyone according to Stojan

19 Zupljanin who was chief of the public security in Banja Luka. So orders

20 came from Zupljanin and later the so-called MUP of the Serb Republic of

21 Bosnia-Herzegovina was founded.

22 Q. When you talk about receiving contrary orders, did I understand

23 you properly when you say -- that you're actually saying that you got one

24 set of orders from Sarajevo and the different orders arrived from the

25 Secretariat of the Interior in Banja Luka? Is that what you said?

Page 2990

1 A. Yes, that's what I said. But in Banja Luka it was the security

2 centre which at that time was subordinated and it was also an integral

3 part of the republican MUP or SUP rather.

4 Q. You say in your statement that after the death of Mr. Umicevic,

5 Dejan Samara became chief of police and that his task was either to divide

6 the police or to force everyone to wear Serb insignia. That would be on

7 page 6 of your statement to the OTP, the third paragraph from the bottom.

8 A. After the death of Mr. Umicevic, Stojan Zupljanin, as the head of

9 the centre, appointed Dejan Samara active -- acting chief of the police

10 station and every day he would see the top people of the SDS and others

11 with whom Umicevic until then did not communicate at a personal level.

12 While Dejan Samara was acting chief of the police station, a dispatch

13 arrived. By then the MUP had officially been established of the Serb

14 republic of Bosnia-Herzegovina. That is what it said. And an offer was

15 made to all employees to sign an oath of loyalty. Authorised officials

16 and people who worked there but were not authorised officials. Also

17 insignia were supposed to be changed into tri-colours and also there was

18 some kind of oath that had to be signed. I didn't sign it, and out of us

19 Bosniaks in Bosanski Novi no one signed it and then we left that meeting

20 after the dispatch was read out because we had refused to sign this oath

21 and this solemn declaration. They said to us, "You can take your annual

22 leave and then we'll see what will happen." But ultimately we ended up

23 jobless.

24 Q. On page 7 of this same statement of yours, in paragraph 3, you say

25 that you had a meeting with Dzafer Kapetanovic, member of the main board

Page 2991

1 of the SDA. And that you were asked it sign an oath of loyalty and go

2 back to work, just to preserve the peace in town. Is that what you

3 stated?

4 A. Yes, I did state that. As we left the police station, the

5 tensions went up even further, and people of Muslim Bosniak ethnicity felt

6 even more threatened. In that sense, Mr. Dzafer Kapetanovic, who was

7 killed during the war, insisted and asked us to come back to work, saying

8 that this was in the interest of all citizens especially the Muslims to

9 have their representatives in the police. However, even if we wanted to

10 go back then, the then-chief probably had instructions from Banja Luka not

11 to readmit us. He invited me to the hotel and we had a tete-a-tete

12 meeting and discussed these matters.

13 Q. In this period of time, had the referendum already been held on

14 the independence of Bosnia-Herzegovina, on the secession of

15 Bosnia-Herzegovina from Yugoslavia? In the first third of 1993?

16 A. It's not that I think it was, I know it was, because together with

17 my colleagues, I was securing the polling stations.

18 Q. Are you aware that the government of Bosnia and Herzegovina, the

19 republic of Bosnia-Herzegovina, headed by the late Mr. Alija Izetbegovic,

20 on the 4th of April 1992, issued a conclusion about mobilising a

21 Territorial Defence units and their subordination to public security

22 stations in the municipalities in Bosnia-Herzegovina?

23 A. No. I'm not aware of that. And even if it was so, this

24 information could not have reached us.

25 JUDGE MOLOTO: Yes, Ms. Richterova?

Page 2992

1 MS. RICHTEROVA: I'm sorry, Your Honour, but yesterday during my

2 examination-in-chief, I covered only the new issue was the presence of

3 Martic's police in Bosanski Novi. This goes well beyond these new issues

4 which were raised yesterday.

5 JUDGE MOLOTO: Mr. Milovancevic?

6 MR. MILOVANCEVIC: [Interpretation] Your Honour, I only tried to

7 get a response, or rather to ask the witness in order to check whether

8 what he said is correct, that this was an attempt to create a Serb police

9 or some sort of a Martic's Police under leadership of the SDS in a

10 situation where, at the same time, a Bosnian Muslim police was being

11 created from members of the Territorial Defence, in the same time period.

12 The witness is referring to a time period in March-April and even May

13 1992, when war broke out in Bosnia-Herzegovina, but his testimony, whether

14 written or oral, does not reflect that. So the picture it provides about

15 the situation on the ground is completely warped, distorted. I would like

16 a chance to ask the witness about the activity of the police in Bosnia and

17 Herzegovina in the relevant time period because this is all in the same

18 context as the activities of the so-called Martic's Police on the

19 territory of Bosnia-Herzegovina. The situation, Your Honour, by your

20 leave, just let me conclude my sentence, please, much more complex than a

21 Red Beret. It is an extremely complex subject matter and there are many

22 facts that have been glossed over here, although they do exist in the

23 documentation, in the possession of the OTP.

24 The Prosecutor has broadened his examination only to the extent

25 that was convenient to the Prosecution, but to point this out, I do have

Page 2993

1 to ask questions about the police. I have only two or three further

2 questions about that and then I will have finished my cross-examination.

3 JUDGE MOLOTO: Mr. Milovancevic, this Bench doesn't make the laws.

4 I know that the order was made that your cross-examination is limited to

5 the Red Berets. And yesterday, leave was granted to you to cross-examine

6 the witness on issues raised by the Prosecutor which were not already

7 contained in the statement of the witness that had been given to you.

8 What you are now saying is a completely new point. You are now telling

9 me, this Bench, that you want to cross-examine on issues beyond what you

10 are allowed to cross-examine because those issues had been glossed over.

11 Shouldn't that -- shouldn't that have been mentioned and raised at the

12 time before the order was made that you will be restricted to

13 cross-examining on Red Berets only? You should have made the point then

14 that you want to cross-examine on every point because things have been

15 glossed over. I do not think this is the time.

16 MR. MILOVANCEVIC: [Interpretation] Yes. I understand you,

17 Your Honour. When we were providing the agreement to this, the

18 examination had not yet taken place, which has changed the character of

19 this witness's testimony. So, because the Prosecutor has broken the

20 rules, we are now in a position where we are open to the objections

21 Your Honours can rightly raise. The Prosecutor put questions falling

22 beyond the scope of the witness statement and they alter the essence of

23 the statement, not just particular facts, but the entire context, which is

24 very important. I will, however, abide by Your Honour's ruling.

25 JUDGE MOLOTO: Thank you, Mr. Milovancevic.

Page 2994

1 MR. MILOVANCEVIC: [Interpretation]

2 Q. I have a question for you, Witness. In the time period when you

3 say the condition for remaining in the police was the signing of a

4 statement of loyalty, did the Ministry of the Interior of

5 Bosnia-Herzegovina issue a decision on the 29th of April - and this will

6 be my last question - about the blocking of all roads in Bosnia and

7 Herzegovina, all military facilities of the JNA, and preventing the JNA

8 from coming out of its barracks on the fast planning and use of combat

9 means in Bosnia-Herzegovina, and this was signed by Hasan Efendic, who was

10 the commander, the military commander, in Bosnia-Herzegovina?

11 A. I can say nothing about this decision because it was not available

12 to me. I was in Bosanski Novi until the 8th of May when I fled -- 1992,

13 when I fled Bosanski Novi with my family. After I stopped working in the

14 police force, I no longer had access to dispatches and information, but I

15 doubt that they could have reached Bosanski Novi because they had to be

16 filtered through Banja Luka. I really don't know about this. I'm not

17 aware of it.

18 Q. And my last question to you in the cross-examination is the

19 following: First, do you know who Vitomir Zepinic is? Was he the Deputy

20 Minister of Interior of Bosnia-Herzegovina. Mr. Avdo Hebib, and was he

21 the assistant Minister of the Interior of Bosnia-Herzegovina? And do you

22 know that acting on orders from the Presidency of Bosnia-Herzegovina, on

23 the 11th of July 1991, they toured the municipalities of Banja Luka,

24 Bosanska Gradiska, Bosanska Dubica, and Bosanski Novi, and compiled

25 detailed written information for the Presidency of Bosnia and Herzegovina

Page 2995

1 in which they say that the major party to blame for the situation is the

2 aggressive military action of members of the Croatian Ministry of the

3 Interior, their incursions into the territory of Bosanski Novi, the

4 crossings of small groups of members of the MUP in uniform on to Bosnian

5 territory, incursions by special-purpose policemen, disseminating fear

6 among citizens of Serb and Muslim ethnicity, and causing them to arm

7 themselves? I know my question is very long, but I'm asking you whether

8 you are aware of this information.

9 A. I know Mr. Vito Zepinic personally and Mr. Avdo Hebib also. I am

10 not aware of this information, and I doubt that this kind of information

11 existed. It's true that in Bosanski Novi or rather in the village of

12 Ravnice, two members of the MUP swam across the river Una. One of them

13 was called Landeka. That was his last name, and he was brought into the

14 police station. I was there when that happened. These two men were taken

15 away by the military police to the investigative prison, detention unit,

16 in Banja Luka. As for any large-scale crossings of any members of the MUP

17 in the territory of Bosanski Novi, I have never seen or heard that.

18 Q. And my last question to you is: Do you want to say that the

19 official information of the Presidency of the Socialist Republic of Bosnia

20 and Herzegovina of the 11th of July 1991, bearing the stamp and SAO

21 2-0639, that this information is untrue and incorrect? Is that what

22 you're trying to say?

23 A. I lived and worked in Bosanski Novi municipality, and I know for

24 certain that although there may have been shelling in parts of Bosanska

25 Kostajnica, where, on Bajo hill, on our side there were mortars, guns and

Page 2996

1 so on, it's possible that there was an exchange of fire across the river

2 Una there. But as for Bosanski Novi and the area around Bosanski Novi, I

3 assert under full liability that there were no crossings by Croatian

4 units.

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

6 have completed my cross-examination.

7 JUDGE MOLOTO: Thank you, Mr. Milovancevic. Any re-examination,

8 Ms. Richterova?

9 MS. RICHTEROVA: I have only one short question.

10 Re-examination by Ms. Richterova:

11 Q. Do you know what happened to Bosnian population, Muslim

12 population, in the municipality of Bosanski Novi in 1992? Did they stay

13 in that municipality or did they leave?

14 A. I was not in Bosanski Novi at the time because, as I said, I left

15 on the 8th of May, but I do know that during the summer of 1992, the male

16 civilian population was arrested in their homes and taken to the Mlakve

17 stadium where they were held for a few days. There was the first official

18 camp in Bosnia-Herzegovina, detention camp. After that, the population

19 was moved out under the escort of the United Nations, between 10 and 12

20 inhabitants in one day of Bosanski Novi municipality, counting, of course,

21 women and children. Part --

22 MR. MILOVANCEVIC: [Interpretation] Your Honour, I have to object.

23 This redirect has nothing to do with the cross-examination or the content

24 of the statement provided by the witness to the OTP.

25 JUDGE MOLOTO: Ms. Richterova?

Page 2997

1 MS. RICHTEROVA: During the cross-examination, the --

2 Mr. Milovancevic was asking about Serbs coming to Bosanski Novi, so I'm

3 asking what happened to people from Bosanski Novi.

4 JUDGE MOLOTO: Any reply to that, Mr. Milovancevic?

5 MR. MILOVANCEVIC: [Interpretation] Your Honour, my question was

6 about what happened to the Serbs, whether Serbs arrived from Croatia.

7 However, the Prosecutor is asking about the Muslim population and that is

8 a broadening of the topic that I raised during my cross-examination.

9 JUDGE MOLOTO: Did the Prosecutor ask about the Muslim population

10 or did she ask about the civilian population of Bosanski Novi?

11 MS. RICHTEROVA: I asked what happened to the Bosnian Muslim

12 population in Bosanski Novi.

13 JUDGE MOLOTO: I take your point, Mr. Milovancevic. Sorry.

14 MR. MILOVANCEVIC: [Interpretation] Just briefly, to respond to my

15 learned friend, during my cross-examination, I asked the witness about the

16 civilian population from the neighbouring republic of Croatia, the Serb

17 population fleeing from Croatia into Bosanski Novi. This is an entirely

18 different topic that has nothing to do with the questions I put to the

19 witness during my cross-examination.

20 MS. RICHTEROVA: My question would be where this population went,

21 and we would know where they went.

22 JUDGE MOLOTO: Which one, the population --

23 MS. RICHTEROVA: The civilian population of Bosnian ethnicity,

24 Muslim ethnicity. But if I -- I am in your hands. If you don't allow

25 this question, I won't ask any more questions.

Page 2998

1 JUDGE MOLOTO: Well, it doesn't seem like it arises from the

2 cross-examination, Ms. Richterova. Thank you very much.

3 [Trial Chamber confers]

4 Questioned by the Court:

5 JUDGE HOEPFEL: May I ask two questions, Mr. Krupic? First,

6 getting back to this issue of mobilisation in 1991, or 1990 and 1991, did

7 you say that Muslims also would show up for this call-up but were sent

8 back, in fact? Was this before Izetbegovic made this recommendation or

9 also after, if I got it right? Could you explain that a little once more?

10 A. 1991, when the war broke out in Croatia, there was a general

11 mobilisation valid for everyone, of all ethnicities. The Muslim Bosniak

12 population partially responded to this call-up. In every call-up paper,

13 there was a time and place where the conscript had to report. When they

14 reported, some of them were sent home straight away, and only a smaller

15 number were sent to the war front. After the public speech of

16 Mr. Izetbegovic, who said that there was no duty to respond to the

17 call-up, he didn't say Muslims or Serbs, he said nobody had to respond to

18 the call-up. After that, 99 per cent of the Muslims no longer responded

19 to these call-ups.

20 JUDGE HOEPFEL: Thank you. Then another question. You referred

21 to a group with the name Suha Rebra. Do you remember that? Can you

22 explain what this term means, where this expression came from?

23 A. This was a group of underage young men who broke into huts that

24 were used for curing meat in the neighbourhood, and the word suha rebra

25 means spare ribs. That's how they got their name because they used to

Page 2999

1 steal spare ribs and other cured meat from these curing huts, and they

2 were hooligans, juvenile delinquents when they were young men, and they

3 got this nickname and now they had grown up and this was a large group of

4 men, 40 or 50 strong.

5 JUDGE HOEPFEL: Thank you. This is what I thought that has

6 something to do with some food, and this was the origin, in fact. Thank

7 you.

8 JUDGE NOSWORTHY: Mr. Krupic, you said in your statement of the

9 22nd of August 1999, that there were check-points on the bridges between

10 Bosanska and Hrvatska Kostajnica and between Bosanski Nova and Dvor and

11 those check-points were to keep reservists coming into town carrying

12 weapons and combat equipment. What ethnicity -- what ethnic group would

13 these reserves have belonged to?

14 A. For the most part, they were of Serb ethnicity.

15 JUDGE NOSWORTHY: And you went on to -- you went on to speak about

16 reservists that came into town with weapons, wearing kokardas, and Chetnik

17 insignia. What would kokarda be now?

18 A. A kokarda is a Chetnik insignia. My former, I didn't know what it

19 was either so I asked my former colleagues. There are these insignia with

20 skulls and then there are some that go back to the days of some King

21 Petar, or whoever, I don't know. I was born after that but I know that

22 the association is the Chetniks from the Second World War. So it's metal

23 insignia worn on caps.

24 JUDGE NOSWORTHY: Are they associated with any particular group

25 or --

Page 3000

1 A. Whoever wanted to, wore them, I assume because not everybody wore

2 those kokardas either. Some people were pleased to be called Chetniks,

3 whereas others were offended if they were called Chetniks. It depended on

4 one's own personal feelings.

5 JUDGE NOSWORTHY: Thank you very much. No further questions.

6 JUDGE MOLOTO: Thank you, Judge.

7 Mr. Krupic, when were you born?

8 A. I was born on the 25th of February 1956.

9 JUDGE MOLOTO: Thank you. May I pick up from the questions of

10 Judge Nosworthy about these spare ribs? Who were they subordinated to,

11 the Suha Rebra?

12 A. Suha Rebra primarily worked for themselves and for their own

13 interest because it involved looting primarily, and I assume, and claim,

14 rather, that all the dirty work that was supposed to be done was done for

15 the SDS.

16 JUDGE MOLOTO: You have referred to the chief of the Bosanski Novi

17 police, Mr. Umicevic. Just for the sake of clarity, can you spell his

18 name? I see at two places in your two different statements, the name is

19 spelled differently.

20 A. Djuro Umicevic. I also noticed that in several places it said,

21 "Umicevic."

22 JUDGE MOLOTO: So it's a U at the beginning, not an O?

23 A. Yes, yes, yes, it's a U.

24 JUDGE MOLOTO: Now, I am very slow to understand when people are

25 talking in court here so I'm going to ask you questions which you may very

Page 3001

1 well have answered already. I'm going to ask you to bear with me.

2 How many towns or villages or communities were attacked that you

3 testified about in your evidence?

4 A. Attacked during the war in Bosanski Novi, you mean?

5 JUDGE MOLOTO: Yes. Was Bosanski Novi attacked? And if so, were

6 there also other areas outside Bosanski Novi which were attacked?

7 A. In 1992, I think the 11th of May it was, the armed attack started

8 against the Muslim Bosniak population in Bosanski Novi. On that occasion,

9 Urije and Prevosavlje and part of Vidovije were shelled, and these are

10 neighbourhoods populated by Bosniaks only. And also the so-called Dolina

11 Japra. That is Blagaj, Japra, Suhaca, Hozici, and Alici, are areas where

12 Bosniak Muslims lived and they were shelled. And on that occasion several

13 people were killed. Men, women and children. And all were expelled from

14 that area to Blagaj, and from there they were deported on trains in train

15 cars for livestock towards Ozren and they were detained at a stadium and

16 then they were moved out under the escort of the UN.

17 JUDGE MOLOTO: Now, these areas that you have mentioned are all

18 areas within the area -- within the district of Bosanski Novi?

19 A. Yes.

20 JUDGE MOLOTO: You talk of Bosniaks. What are Bosniaks?

21 A. Bosniaks are the former Muslims. As a rule nobody asked me

22 whether I wanted to be a Bosniak or not. I would be happiest to call

23 myself a Bosnian of the Islamic faith. However there was not a referendum

24 on this. A decision was passed at state level that the former Muslims

25 will be linked to the name of the state of Bosnia-Herzegovina and would be

Page 3002

1 called Bosniaks.

2 JUDGE MOLOTO: And what is meant by former Muslims? Have these

3 people stopped being Muslims?

4 A. Well, officially, they are Bosniaks of the Muslim faith or rather

5 the Islamic faith. Just like Serbs are Orthodox Christians.

6 JUDGE MOLOTO: Okay. Yesterday you also referred, when you dealt

7 with the population of Bosanski Novi, you referred to Yugoslavs. Who are

8 Yugoslavs?

9 A. Yugoslavs were people who felt that their affiliation was with the

10 state of Yugoslavia. For the most part Yugoslavs were people who had

11 mixed marriages, and when I say mixed marriages, I mean the following: If

12 the wife was a Bosniak or Muslim and the husband a Serb or a Croat, and

13 the other way around. So they were mainly --

14 THE INTERPRETER: The witness says "Muslims."

15 THE WITNESS: And, of course, people who felt that way.

16 JUDGE MOLOTO: Outside Bosanski Novi, or before we leave Bosanski

17 Novi, you said that the population was removed by the United Nations to

18 Ozren, is that it? No, no. Yes. What finally happened to this

19 population? Did it finally come back to Bosanski Novi?

20 A. That part of the population from the so-called Japra valley, Japra

21 Blagaj, Suhaca, Hozici, they were all deported in trains and cattle train

22 cars, and then when they were returned two or three days later, then a

23 convoy was organised under the escort of the UN and once they left from

24 Bosanski Novi and they were returned and the other time they managed to

25 leave in organised fashion, to get to the territory of Croatia, and then

Page 3003

1 they moved to different western countries.

2 JUDGE MOLOTO: Is it your evidence that as we speak, they are not

3 in Bosanski Novi? They have gone to different western countries?

4 A. Bosanski Novi, according to some of the pre-war estimates, had

5 between 14 and 17.000 [Realtime transcript read in error "70.000"]

6 Muslims, called Bosniaks nowadays. I claim with full responsibility that

7 in Bosanski Novi now there aren't even 5.000 left.

8 MS. RICHTEROVA: I'm sorry, I think there is a mistake in the

9 transcript. It should read 17, not 70.

10 JUDGE MOLOTO: Between 14 and 17. Okay.

11 JUDGE HOEPFEL: I understood 40 and 70.000 -- 14 and 17?

12 JUDGE MOLOTO: Can you clear that up? Can you give us that

13 population again? You say --

14 A. From 14 -- from 14 to 17.000.

15 JUDGE MOLOTO: 14 to 17.000. Thank you very much. Okay.

16 What was the extent, if you know, of the damage of property in

17 Bosanski Novi?

18 A. It is hard to talk about damage, very hard. The damage is

19 enormous. After all, the areas that were not populated, Suhaca, Hozici,

20 Alici, not a single house remained intact. They were demolished,

21 destroyed. And these people were employed abroad, in Germany,

22 Switzerland, Austria, et cetera. So these were the richest people in the

23 municipality of Bosanski Novi. Machines, tractors, remained behind,

24 trucks and so on and so forth in addition to the houses that were

25 equipped.

Page 3004

1 Now, Blagaj Rijeka, Blagaj Japra, places that were populated, that

2 is in Bosanski Novi, the facilities were mainly -- are mainly still there,

3 the houses are still there, but there is no furniture or anything else

4 that was inside the houses to be mentioned.

5 JUDGE MOLOTO: What happened to that furniture that used to be

6 inside the houses?

7 A. Well, for the most part that furniture was stolen by people.

8 People took it all for themselves, from the neighbouring Serb villages

9 they came with tractors and trucks and just took this away, and allegedly,

10 the then-army took part of it into some warehouse and then distributed it.

11 For example I know about my own apartment that remained furnished. I did

12 not even take my family photographs from the apartment. My former

13 colleagues entered my apartment and, when we spoke on the telephone, they

14 asked me whether they could take the TV set, the video, et cetera, I gave

15 up on this altogether. So I know where all these things are, but now I'm

16 not interested in this and I'm not interested in the appliances,

17 furniture, whatever.

18 JUDGE MOLOTO: I understand, Mr. Krupic, and I understand that

19 this probably evokes certain emotions in you, but we are not talking about

20 you personally here. We are talking about the entire community of

21 Bosanski Novi.

22 Are you able to tell, in numbers, the number of people who might

23 have been killed during this attack? I'm talking about civilians, not

24 soldiers.

25 A. When these Bosniak villages were attacked, I'm sure that dozens of

Page 3005

1 civilians were killed. I couldn't give you an accurate number but it

2 certainly wasn't less than 50.

3 JUDGE MOLOTO: And these 50 who would have been killed, would they

4 have been armed at the time of being killed?

5 A. No. I claim with full responsibility that none of them had been

6 armed, and in the territory of the municipality of Bosanski Novi, not a

7 single bullet was fired by the Bosniak Muslim people.

8 JUDGE MOLOTO: Outside Bosanski Novi, but in the same region, were

9 there any other areas that were similarly attacked?

10 A. Well, attacks were carried out in all areas, including Prijedor,

11 Sanski Most, Kljuc, but Bosanski Novi, I think, in relation to the other

12 municipalities, fared much better and involved less victims. Of course,

13 any victim is important, but Mr. Izet Muhamedic came to lead the SDA then,

14 and he and they asked the population not to put up any kind of resistance

15 and not to go into any kind of armed conflicts with the other side. In

16 that case, there probably would have been many, many more victims, many,

17 many more casualties, whereas in Sanski Most and Kljuc, the situation was

18 quite different.

19 JUDGE MOLOTO: Do you have any knowledge of the extent of deaths

20 in those areas, in Prijedor, Sanski Most, and Kljuc?

21 A. I could not give you any figures, but there were many, many more

22 than in Bosanski Novi. If you look at the other municipalities, Bosanski

23 Novi has much, much less.

24 JUDGE MOLOTO: In terms of property in those areas, what would you

25 say the extent of destruction was, if there was any destruction?

Page 3006

1 A. Well, I've already mentioned that complete villages were

2 destroyed, which, in fact, did not even exist any longer until 1995. That

3 is when the population started returning there and now these population --

4 these villages are populated to a certain extent, not to the extent to

5 which they were populated in 1992, though. But people are returning to

6 their houses and to their property.

7 JUDGE MOLOTO: You referred yesterday to the fall of Hrvatska

8 Kostajnica. Do you remember that?

9 A. Yes.

10 JUDGE MOLOTO: Can you tell us the extent of the damage in that

11 area?

12 A. Together with my colleague --

13 THE INTERPRETER: The interpreter did not catch the name.

14 A. One evening I went to carry out an on-site inspection --

15 investigation in Hrvatska Kostajnica, where there was a classic murder,

16 because after these wartime events, Hrvatska Kostajnica was in bad shape.

17 It was night, to be sure, but I could see that it was very badly damaged.

18 JUDGE MOLOTO: Are you able to -- would you say the entire city

19 was flattened or just give us an estimation of the extent of the damage?

20 A. Well, there had been shelling. You can't say that the entire town

21 was destroyed but there was damage in many places in town.

22 JUDGE MOLOTO: Do you have any idea of the number of deaths in

23 Hrvatska Kostajnica?

24 A. I wouldn't know because it's in another state, so I don't know.

25 JUDGE MOLOTO: Okay. You also referred yesterday to the looting

Page 3007

1 of Bosanska Kostajnica. Remember that? At the time when Bosanska

2 Kostajnica surrendered, if I remember your evidence correctly. Remember

3 that?

4 A. Yes, I do. For a time I was present. When I was talking about

5 the robbery, I was referring to watches, jewellery and so on, by Martic's

6 unit, which was assigned to search those men who had surrendered.

7 JUDGE MOLOTO: I see. So it was the search of individuals, it was

8 not the area that was being attacked?

9 Sorry, we've gone far beyond time for break off. We should have

10 broken off at 20 past ten. I didn't realise that. This may be a

11 convenient time to stop. We'll come back at 10 to 11.

12 --- Recess taken at 10.24 a.m.

13 --- On resuming at 10.51 a.m.

14 JUDGE MOLOTO: Mr. Krupic, let me just get clarity on this last

15 point that we were dealing with before we went out for the break. You say

16 Bosanska Kostajnica was looted. Am I right that you said that?

17 A. I didn't say that Bosanska Kostajnica was looted but that the

18 people who surrendered there, and they were policemen of the Republic of

19 Croatia, that they were robbed.

20 JUDGE MOLOTO: So there was no attack on it.

21 A. During the war, there probably was, but it's about 30 kilometres

22 away from Bosanski Novi, so I didn't have that information.

23 JUDGE MOLOTO: Okay. I think I have no further questions for you.

24 Thank you very much.

25 Any questions arising, Ms. Richterova?

Page 3008

1 MS. RICHTEROVA: Thank you, Your Honour. I don't have any

2 questions.

3 JUDGE MOLOTO: Mr. Milovancevic?

4 MR. MILOVANCEVIC: [Interpretation] Yes, Your Honour.

5 Further cross-examination by Mr. Milovancevic:

6 Q. In connection with the question put to you about the meaning of

7 the word kokarda and who wore it, you gave an explanation. The question

8 is as follows: Do you know that the kokarda was the insignia worn on the

9 caps of members of the army of the Kingdom of Yugoslavia and that this

10 kokarda was worn by those members of the royal army who did not recognise

11 the German occupation, who were monarchists and anticommunists, and who,

12 through most of the period of World War II, enjoyed the support of London

13 and Washington? Do you know that?

14 A. I spoke to a former colleague of mine about the kokarda. He knew

15 more about it than I did. He was a Serb and he was older than me. There

16 were two kinds of kokardas worn during the previous war in Bosnia and

17 Herzegovina. There was the kokarda associated with the kingdom, the

18 former kingdom and the insignia of that army, and there was another kind

19 of kokarda with a skull. That was the so-called Chetnik kokarda.

20 Q. The colleague you spoke to, how old was he?

21 A. He was born in 1950. His father and his mother had participated

22 in World War II and he was a work colleague of mine.

23 Q. Thank you. Answering His Honour's questions, you said, speaking

24 of the victims among the civilian population on the territory of Bosanski

25 Novi, that you assert with full responsibility that not a single bullet

Page 3009

1 was fired by the Bosniak people. Can you tell us what happened to the

2 weapons carried by SDA units, the red fezzes and the weapons that Hasim

3 Valjevac and others distributed?

4 A. I repeat once again: I assert with full responsibility that on

5 the territory of Bosanski Novi municipality, not a single bullet was fired

6 during the war by the Bosniak side. As for some sort of red fezzes, there

7 is the first time I've heard of them. It's true that fezzes are red in

8 colour but that there were groups wearing red fezzes, I don't know that.

9 And as for Valjevac, I don't know what you said his name was, this man who

10 allegedly distributed weapons. Could you repeat his last name, please.

11 Q. Hasim Valjevac?

12 A. Hasim Valjevac is from Bosanska Kostajnica, he was employed in the

13 Bosanski Novi municipality. I think he now works in the Kostajnica

14 municipality. And about Hasim Valjevac having some sort of red fezzes,

15 well, those are just tales for small children, I think.

16 Q. Are the Green Berets tales for small children?

17 A. Yes. You could buy any colour beret, green, red, but --

18 Q. Thank you. When answering the Benches questions about the

19 situation in Hrvatska Kostajnica, you said that one night you saw what the

20 situation there was because you were carrying out an on-site

21 investigation, and this was a different state, as you say, so how did this

22 come about?

23 A. My colleague, Esad Brkic, who was a crime technician, a forensic

24 technician, was asked to go there and photograph the crime scene of a

25 murder that had taken place in a private apartment, and I went there with

Page 3010

1 him. I accompanied him. They did not have a forensic technician there in

2 Hrvatska Kostajnica, when the Serb forces took over there.

3 Q. Well, who was it, then, who invited you to go and help, the Serb

4 forces?

5 A. The Serbian police from Hrvatska Kostajnica.

6 Q. And you cooperated with them normally?

7 A. With the active police from Dvor Na Uni and Hrvatska Kostajnica,

8 yes.

9 Q. Answering the Bench's questions as to the kind of damage there was

10 in Hrvatska Kostajnica, you said that you were there at night-time, that

11 you did see some damage, as it was night-time, how was it possible for you

12 to tell which house belonged to whom, which houses were Serb, which were

13 Croat or Muslim?

14 A. In my response, I mentioned neither Croat nor Serb nor Muslim

15 houses. All I said was that there was damage from shelling, and that's

16 true.

17 Q. Were there Serb, Croat and Muslim houses in Kostajnica?

18 A. Yes.

19 Q. I have another question for you. When answering the questions

20 from the Bench about the damage that happened during the war, you

21 mentioned Bosanski Novi and other places. From the information you gave,

22 answering the questions by the Prosecutor, you said you hadn't been in

23 Bosanski Novi. I assume you hadn't been in all those other places during

24 the war. Did you talk to the people from those places and did you get

25 your information about the damage from them? And everything else that

Page 3011

1 happened?

2 A. As I said.

3 MS. RICHTEROVA: Your Honour, it's not exactly because what he

4 said he was there after the war, and it was in his statement. It's not

5 what he answered to me.

6 JUDGE MOLOTO: Mr. Milovancevic?

7 MR. MILOVANCEVIC: [Interpretation] Your Honour, I put to the

8 witness that he himself said that in May 1992, he left Bosanski Novi, so

9 he was not in Bosanski Novi, he was somewhere else. As he spoke of a

10 number of other villages, I asked him where he got his information. The

11 essence of my question was: Did he talk about the casualties and the

12 damage that occurred during the war with people from those places.

13 THE WITNESS: [Interpretation] Sir, if you want to know, I will

14 tell you. Towards the end of 1995, and in 1996, every month or every

15 fortnight after the end of the war, I did go to Bosanski Novi. I still

16 visit Bosanski Novi often. I have friends there, colleagues.

17 Furthermore, if you want to know where I got this information, I won't

18 keep silent about the following. During the war I was the chief of the

19 crime police of the Banja Luka police centre in exile in Travnik. We took

20 statements about genocide, about crimes, and delivered all this to the

21 Ministry of the Interior of the republic.

22 Q. I have another question for you. You said you took statements

23 from people and you mentioned the damage that occurred. In your statement

24 to the Prosecution, did you say, "On one occasion, after the beginning of

25 the war, I happened to meet some people from Bosanski Novi. They were all

Page 3012

1 of the same opinion, that their problems had been caused by their own

2 politicians and the West? Ordinary people had to take sides in the first

3 few days, either to take the side of the party or to be considered

4 opponents and therefore enemies." Did you say that on page 7 of your

5 statement to the OTP?

6 A. Yes, I did. And there is a --

7 Q. Thank you. That's sufficient.

8 MR. MILOVANCEVIC: [Interpretation] Your Honour, I have no other

9 questions.

10 JUDGE MOLOTO: Thank you very much, Mr. Milovancevic.

11 Mr. Krupic, thank you so much for coming to testify. We are

12 finished with your testimony. You are now excused. You may stand down.

13 MS. RICHTEROVA: Your Honour, I'm sorry, but the witness started

14 answering the question, and he was not allowed to finish the question. He

15 was just -- "Yes, I did. And there is --" and Mr. Milovancevic just

16 interrupted him so we don't know what he wanted to say.

17 JUDGE MOLOTO: Would you like to finish, complete that sentence?

18 MR. MILOVANCEVIC: [Interpretation] Your Honour, excuse me. Your

19 Honour, my question, which I put to the witness, was whether he had spoken

20 to people, and whether he said in his statement is what he was told by

21 those people. His answer was "yes."

22 THE WITNESS: [Interpretation] I wanted to continue but you

23 interrupted me.

24 MR. MILOVANCEVIC: [Interpretation] But this answer is sufficient

25 for me.

Page 3013

1 JUDGE MOLOTO: Will you please finish your answer, Mr. Krupic?

2 THE WITNESS: [Interpretation] I did say that, and I only wish to

3 add that those who were not following the party line were immediately --

4 was immediately branded a traitor of the Serb people. There is a

5 saying, "He who is not with us is against us." But it doesn't have to be

6 that way.

7 JUDGE MOLOTO: Thank you, Mr. Krupic.

8 MR. MILOVANCEVIC: [Interpretation] Thank you, Your Honour. No

9 further questions.

10 JUDGE MOLOTO: Mr. Krupic, once again, thank you so much. I'm

11 sorry about that little misunderstanding. You are excused, as I said.

12 You may stand down.

13 [The witness withdrew]

14 JUDGE MOLOTO: Before calling the next witness, just one little

15 point I want to raise with -- can we please move into private session for

16 purposes of what I want to raise?

17 MS. RICHTEROVA: Your Honour, may I be excused?

18 JUDGE MOLOTO: You don't want to hear what we are going to say in

19 private?

20 MS. RICHTEROVA: I'm sorry, I will wait.

21 JUDGE MOLOTO: You are excused.

22 MS. RICHTEROVA: Thank you.

23 JUDGE MOLOTO: Thank you.

24 [Private session]

25 (redacted)

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22 (redacted)

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24 (redacted)

25 [Open session]

Page 3018

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

2 JUDGE MOLOTO: Thank you very much.

3 MR. WHITING: Thank you, Your Honour.

4 Q. Witness, before we begin, I want to explain to you various

5 protective measures which have been granted to you for purposes of your

6 testimony in this proceeding. You have been granted face distortion,

7 which means that your face will be distorted in any broadcast of public

8 portions of this proceeding. You've been granted a pseudonym, which means

9 that you will be referred to only by your pseudonym and not by your true

10 name. You've also been granted voice distortion which means that your

11 voice will be distorted during any broadcasts of public portions of this

12 proceeding. Do you understand that?

13 A. Yes.

14 Q. In addition, in order to protect your identity, whenever we

15 discuss topics which could tend to disclose your identity, could identify

16 you, we will do those in private session. Do you understand?

17 A. Yes.

18 Q. That means that when we are in public session, I'm going to ask

19 you to please take care to avoid -- I've been leaving my microphone on --

20 to avoid using your name or referring to anything that could identify you.

21 Do you understand that?

22 A. Yes.

23 Q. With the assistance of the usher, I'm going to show you what we

24 refer to as a pseudonym sheet.

25 MR. WHITING: Your Honour, is there a matter that --

Page 3019

1 JUDGE MOLOTO: Witness, you are being asked to speak a little up.

2 They can't pick your voice up, those who have to interpret what you're

3 saying. Speak a bit louder. Thank you, Mr. Whiting. You may proceed.

4 MR. WHITING: Thank you, Your Honour.

5 THE WITNESS: [Interpretation] I will try to. Thank you.


7 Q. Witness, please look at this document and do not read out what it

8 says out loud but please tell me if that is your name that appears on the

9 document? And having just seen this moments before you came in, I'm a

10 little concerned that maybe your name is misspelled, and if it is, could

11 you take a pen and write the correct spelling above your name, please?

12 MR. WHITING: Could the usher show the document, please?

13 THE WITNESS: [Interpretation] Should I say it out loud or should I

14 just write out what is correct here?


16 Q. You should write out what is correct. Please do not say it out

17 loud.

18 A. [Marks]

19 MR. WHITING: If the usher could bring it back to me and then I'll

20 ask that it be shown to the Defence and to the Judges.

21 Q. I apologise for misspelling your name.

22 A. It's all right. It's just a question of spelling. It's all

23 right. It's just a question of spelling. That's the only mistake that

24 was made.

25 MR. WHITING: Your Honour, could that document be admitted into

Page 3020

1 evidence and placed under seal, please?

2 JUDGE MOLOTO: The document showing the witness's correct name is

3 admitted into evidence. May it please be given an exhibit number and be

4 kept under seal.

5 THE REGISTRAR: That will be Exhibit number 281, Your Honours,

6 under seal.

7 JUDGE MOLOTO: Thank you very much.


9 Q. Just for the record, Witness, you will be referred to in these

10 proceedings by your pseudonym, MM-079, or alternatively as just,

11 "Witness." Do you understand?

12 A. Yes.

13 Q. I think what His Honour Judge Moloto was about to tell you is that

14 the microphone won't pick up you nodding your head or shaking your head.

15 You always have to answer the question verbally. Do you understand that?

16 A. I'll do my best and try to take care.

17 Q. I'll also remind you again that you're going to have to, I think,

18 speak a little bit louder because it's very difficult for the

19 interpreters. A the voice distortion is very good and you won't -- if you

20 speak louder, you won't break through the voice distortion. There is

21 nothing to be concerned about. Do you understand?

22 A. It's not that I tried to distort my voice in any way. It's just

23 the way I speak naturally.

24 Q. I understand. If you could just try to remember to speak up a

25 little bit it would be of great assistance to all of us, particularly the

Page 3021

1 interpreters.

2 MR. WHITING: Your Honour, could we move into private session,

3 please?

4 JUDGE MOLOTO: May the Chamber please move into private session?

5 [Private session]

6 (redacted)

7 (redacted)

8 (redacted)

9 (redacted)

10 (redacted)

11 (redacted)

12 (redacted)

13 (redacted)

14 (redacted)

15 (redacted)

16 (redacted)

17 (redacted)

18 (redacted)

19 (redacted)

20 (redacted)

21 (redacted)

22 (redacted)

23 (redacted)

24 (redacted)

25 (redacted)

Page 3022











11 Pages 3022-3028 redacted. Private session.















Page 3029

1 (redacted)

2 (redacted)

3 (redacted)

4 (redacted)

5 (redacted)

6 [Open session]

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

8 JUDGE MOLOTO: Thank you very much.

9 MR. WHITING: Thank you, Your Honour.

10 Q. Witness, I want to ask you for some background questions about the

11 federal Ministry of the Interior. Could you tell us first of all the two

12 parts of the federal Ministry of the Interior?

13 A. There were -- well, I wouldn't call it two parts. Two departments

14 or two sections. The public security and the state security sector.

15 These sectors existed at every level in the republics, and lower level

16 municipal and regional organisations of the Ministry of the Interior.

17 Q. Now, the -- can you tell us what -- by what abbreviation the

18 public security sector was known and what -- and by what abbreviation the

19 state security sector was known?

20 A. The abbreviations were used as follows: SDB for the State

21 Security Service, and SJB for the Public Security Service. This may have

22 differed from republic to republic. However, the first letter of every

23 word was taken.

24 Q. I'm not sure I understood the last sentence of your answer. Maybe

25 it's a translation issue. You said, "However, the first letter of every

Page 3030

1 word was taken." Oh, I understand. It's an abbreviation.

2 A. Yes.

3 Q. Sorry, a little slow.

4 Now, the -- I was just going to ask you if there was a similar

5 organisation in the republic ministries of Interior and you started to

6 answer that. Could you explain for example by giving -- by referring to

7 the Republic of Serbia, was it organised in the same way with the same two

8 sectors, the SJB and the SDB?

9 A. Yes. In almost every republic or rather in every republic, there

10 were two services at the Ministry of Interior, the Public Security Service

11 and the State Security Service. Their organisation within these services,

12 depending on each republic, had administrations. For example, the first

13 administration of the SDB, if it existed in Serbia, for example, would be

14 called the third or the second administration in another republic. It

15 would all depend on the difficulty of the work that the republic in

16 question felt was at issue for that republic.

17 Q. Thank you. Staying at the level of the two different sectors, the

18 Public Security Service and the State Security Service, can you tell us,

19 in general terms, and briefly, what the different roles were of the State

20 Security Service and the Public Security Service?

21 A. Well, as the name itself shows, the State Security Service had the

22 task of protecting the legal and social order in the country. It dealt

23 with political crime, terrorism, extremism, and intelligence work.

24 Whereas the Public Security Service dealt with ordinary crime. For

25 example, traffic, drugs, economic crime, theft, robbery and so on. Those

Page 3031

1 were their duties. This was general crime, such as exists in every

2 country in the world and has organisations to deal with it.

3 Q. And I think this is clear but just to be absolutely clear, there

4 was existed a federal Ministry of Interior with these two sectors, Public

5 Security Service and State Security Service, and in each republic there

6 existed a republican Ministry of Interior and -- with these two sectors,

7 the Public Security Service and the State Security Service; is that

8 right?

9 A. Yes, it is.

10 Q. Now, can you tell us, up until 1988, what was the relationship

11 between the federal State Security Service or the federal DB and the DBs

12 or state security services of the various republics?

13 A. Until 1988, the federal service controlled the republican

14 services, so there was subordinate-superior relationship with all the six

15 republics and the two autonomous provinces.

16 Q. Would employees of the federal -- I'm sorry, of the republican

17 services ever go to work for the federal service?

18 A. I wouldn't put it that way, whether they were working for the

19 federal services. They were working for the services of their own

20 republics. But they were duty bound to coordinate their work with the of

21 the federal service, to ask for guidelines and instructions from the

22 federal service. Every contact among the republics or the ministries of

23 the various republics, took place either in cooperation with or through

24 the federal ministry. We were the coordinators between the republics and

25 a link between the services in the republics.

Page 3032

1 Q. Would there be -- before 1988 would there be sharing of

2 information between the federal service and the republican services?

3 A. Yes. This was quite usual and it was according to the rules of

4 the service.

5 Q. Now, I've been asking about the time period before 1988. Did

6 something happen in 1988 that changed this?

7 A. Yes. There was a difference in the period before 1988 and after

8 1988, or 1989. Until the political conflicts that occurred on the

9 territory of the former Yugoslavia, both at the head of the League of

10 Communists, which fell apart, as did the Communist Parties of Yugoslavia,

11 and this was immediately reflected in the work of the services of the

12 various republics. In their attitude toward the federal organs, I can

13 only refer to my own service. The various republics began to withhold

14 information. Coordination and work with the federal Ministry of the

15 Interior and the federal State Security Service, well, this started in

16 Slovenia and Croatia, and all this was reflected on the work of the

17 service.

18 Q. Did changes occur in the federal ministry, in particular in the

19 State Security Service, at this time?

20 A. Yes. As I said, individual republics, Slovenia, Croatia, later on

21 Bosnia, then Macedonia, began withholding certain information and rather

22 than asking us for assistance, guidelines, coordination, instructions,

23 well, this was later, also transferred to other republics, this did not

24 happen all of a sudden. It went on until 1992. It progressed, this

25 separation of the republics. It depended on each republic and the time it

Page 3033

1 separated in. But you could feel this in the way work was coordinated, in

2 the correspondence and also as regarded personnel because various

3 republics stopped sending staff to work in the federal services, at least

4 as far as operations went. It was only in formal terms that cooperation

5 continued. The presence of Slovenia or Croatia was only formal. It was

6 different than it had been before.

7 Q. When these republics started -- stopped sending staff to work in

8 the federal services, who took their places?

9 A. We in the federal ministry started becoming scattered from that

10 year onwards. The people left. The only people who remained were those

11 who had family ties or other ties to Belgrade. Those whose links to

12 Belgrade were purely professional went back to their own republics. Staff

13 members from Serbia, of course, remained. There were some employees from

14 other republics who remained working there until 1992, and then they had

15 to leave too because they lost their jobs. Of course, due to this staff

16 shortage, the ministry of the Republic of Serbia sent us people to fill

17 the vacancies, but it was really a formality because we had staff members

18 but we didn't have any work, because the other republics stopped sending

19 us information and without their information we couldn't do our jobs.

20 Q. In that last answer, you said that "Staff members who were from

21 Serbia, of course, remained." Why is that "of course"? Why did they

22 remain?

23 A. I said that those who had families in Belgrade or came from Serbia

24 had to stay in Serbia, but those who had only been sent from various

25 republics to do a job, they lost their jobs and then they went back to

Page 3034

1 their home republics, whereas staff members from Serbia had not only

2 professional but also family links in Belgrade and that's why they stayed.

3 Well, one might say that Serbia was gradually taking over certain

4 functions, and when the functions of the autonomous provinces ceased to

5 exist, Serbia gradually began taking over the work of the federal

6 institutions, especially the Ministry of the Interior.

7 Q. In 1989, who became the federal Minister of the Interior?

8 A. In 1989, after the departure of Culafic, we were left without a

9 minister for a time, and then Petar Gracanin a retired general of the

10 Yugoslav army arrived.

11 Q. Do you recall what year he arrived? Was it in 1989 or was it

12 later?

13 A. I think it was in 1989, but please don't hold me to it, because

14 quite a long time has elapsed. I think it was maybe in September 1989.

15 Q. Do you recall until when he served, what year he stopped serving

16 as the federal Minister of the Interior?

17 A. He was the federal minister until 1992. Whether it was February

18 or March, I'm not sure, 1992, but, again, please don't hold me to the

19 precise date. It could have been a month before or after.

20 Q. I appreciate that. For this purpose, the precise date is not

21 important.

22 Can you tell us, if you know, how did he become the federal

23 Minister of Interior? That is, was he promoted by anybody or --

24 A. He could not be promoted any higher because he was a general and a

25 national hero. It was more a duty and a task that he had to do. It

Page 3035

1 wasn't a promotion for him, because you can't get higher than a general,

2 or you couldn't in the then-Yugoslavia.

3 Q. Witness, I was using the word in a different sense to mean -- did

4 anybody advocate him becoming, to your knowledge, advocate him becoming

5 the Minister of Interior? Did anybody support him or how did he become

6 the Minister of Interior, if you know?

7 A. After he was appointed, my colleagues and I commented on it. We

8 commented on his arrival as Minister of the Interior because we felt that

9 he was too old. He had been in a war where he had been wounded more than

10 once, and that he was not up to the challenges of the job he had taken up.

11 Those were the comments we made among ourselves. And we thought he had

12 been appointed by Serbia, that he had been appointed Minister of the

13 Interior in order to carry out a certain task. I can give you an example.

14 Almost all the previous ministers starting from Herljevic who was a

15 military man before he became Minister of the Interior, Culafic was the

16 only civilian the only one who had been a politician actually, but it was

17 the practice in earlier periods to appoint generals as ministers of the

18 Interior.

19 Q. We are about to take a break but before we take the break, let me

20 ask you this question. When you say you thought he was appointed by

21 Serbia, did you think he was appointed or advocated by any particular

22 person in Serbia?

23 A. As he was a Serb cadre, he was an ethnic Serb, he came from

24 Serbia, he lived in Belgrade, probably he was involved in political life,

25 the political life of Serbia, that is, and two Macedonians had been

Page 3036

1 nominated and one from Slovenia, but as they didn't want to send them to

2 Serbia, Serbia came in to fill the gap because most probably it was the

3 Serb leaders who were in power at the time who appointed him as Minister

4 of the Interior. He was appointed not elected, because I think that had

5 he been elected in the -- according to the proper procedure, he would have

6 had to be someone from Macedonia. That was the kind of rota system there

7 was. But Macedonia was beginning to withhold its staff members from the

8 federal services, although there were still some staff members from

9 Macedonia and other republics. But when Gracanin was appointed, this was

10 an attempt to solve that problem because the Ministry of the Interior was

11 in Serbia and that activity was felt there more than in other republics.

12 So most probably Gracanin was appointed by the top leadership. There was

13 already political turbulence within Serbia and in the League of

14 Communists. Gracanin was probably close to the leading people, those

15 headed by the late Mr. Milosevic, and the choice fell on him, and he

16 appointed Gracanin.

17 Q. Thank you, Witness.

18 MR. WHITING: I think, Your Honour, that this would be a

19 convenient time for a break.

20 JUDGE MOLOTO: Thank you very much. We will take a break and come

21 back at 20 to 1. Please be back at 20 to 1. Court adjourned.

22 --- Recess taken at 12.13 p.m.

23 --- On resuming at 12.41 p.m.

24 JUDGE MOLOTO: Yes, Mr. Whiting.

25 MR. WHITING: Thank you, Your Honour. Could we go into private

Page 3037

1 session, please?

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

3 [Private session]

4 (redacted)

5 (redacted)

6 (redacted)

7 (redacted)

8 (redacted)

9 (redacted)

10 (redacted)

11 (redacted)

12 (redacted)

13 (redacted)

14 (redacted)

15 (redacted)

16 (redacted)

17 (redacted)

18 (redacted)

19 (redacted)

20 (redacted)

21 (redacted)

22 (redacted)

23 (redacted)

24 (redacted)

25 (redacted)

Page 3038











11 Pages 3038-3046 redacted. Private session.















Page 3047

1 (redacted)

2 (redacted)

3 (redacted)

4 (redacted)

5 (redacted)

6 [Open session]

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

8 JUDGE MOLOTO: Thank you very much.

9 MR. WHITING: Thank you, Your Honour.

10 Q. Witness, did the Croatian authorities tell you anything about what

11 was happening at that time in Knin and in the SAO Krajina?

12 A. The Deputy Minister of the Interior of Croatia said that the

13 biggest problem in Croatia was in the Krajina area, around Knin, Benkovac

14 and Obrovac, the so-called SAO Krajina.

15 JUDGE MOLOTO: Now, can I ask a question? When we are in open

16 session, don't we lift the blind?

17 MR. WHITING: No, Your Honour, because for one thing there is

18 actually nobody back there. It's as a precaution, but if there was a

19 public -- the public was there, then if we lifted the blind they would be

20 able to see the witness and he would be identified. In other courtrooms,

21 and I think you'll see this next week, the public sits behind the witness

22 and the way it's done is there is a screen put around the witness so that

23 there can be a public there and watching the session without seeing who

24 the witness is. But the way this courtroom is configured --

25 JUDGE MOLOTO: I'm convinced.

Page 3048

1 MR. WHITING: Thank you, Your Honour.

2 Q. Witness, you said that the Croatian authorities said that the

3 biggest problem in Croatia was the Krajina area, the so-called SAO

4 Krajina. Did they tell you what kind of problems they were having, what

5 the issues were?

6 A. The then assistant Minister of Croatia said that in their terms

7 the OUP in Knin, that is to say the police in Knin, had separated, that it

8 was no longer under the jurisdiction of the Croatian state and Croatian

9 law, that it carried out some kind of organisation or reorganisation of

10 its own in the area of Knin, Benkovac, and Obrovac.

11 Q. Was -- did they say who had initiated or caused this

12 reorganisation that they were talking about?

13 A. He mentioned Milan Martic then as one of the protagonists of all

14 of these actions, which -- who had declared himself as, as he put it then,

15 secretary of the Secretariat of the SUP in Knin, who placed the entire

16 police under his own control, his own authority, that part of the police

17 that consisted of members of the Croatian ethnic group were dismissed, as

18 they said, from the ranks of the police of the Secretariat in Knin, that

19 he admitted quite a few of his own people into the police, with Serb

20 ethnic backgrounds, and that he was operating under some laws that were

21 not in force in the territory of the Republic of Croatia. Then there was

22 also reference to the putting up of roadblocks and the participation of

23 the police from SAO Krajina under Martic's leadership in this. The

24 roadblocks were placed as protection for Serb villages.

25 Q. Did the Croatian authorities say anything about Milan Martic's

Page 3049

1 relationship, if any, to Belgrade?

2 A. They said then, or rather the assistant minister said then, that

3 several times they tried to establish contact with Milan Martic.

4 Q. Did they say why they were trying to establish contact with Milan

5 Martic?

6 A. In order to recommend to him to abide by Croatian law and the

7 rules and regulations of the Croatian Ministry of the Interior. In

8 return, they said that they had offered him the top job in the police in

9 Knin. However, as the assistant minister said then, Martic did not accept

10 that. His only wish was for him to establish a Secretariat of the

11 Interior in the territory of Knin and other organs in the territory of

12 Benkovac and Obrovac, in order to keep all power in SAO Krajina in the

13 hands of the then-government or the then-leadership of the SAO Krajina in

14 that area and all control over the work of the Ministry of the Interior,

15 to keep it under his own control. The assistant Minister of Croatia also

16 said that Martic was doing all of that as persuaded by Belgrade, that that

17 was not his own doing, but that he fell under the influence of Belgrade

18 and the Belgrade structure.

19 Q. You said that they told you that Milan Martic was admitting quite

20 a few of his own people into the police with Serb ethnic backgrounds. Did

21 they tell you anything about how or where these people were trained?

22 A. The minister or rather the assistant Minister of Croatia in the

23 Ministry of the Interior said nothing about that, because that meeting was

24 practically a preliminary meeting. Everything was being said in general

25 terms. Nothing was said in concrete terms. It was left for us to clarify

Page 3050

1 it through our future work. That is to say manning the services, the

2 organisation of jurisdiction, and the rest.

3 Q. Did you learn anything about the training of people who were being

4 admitted into the police with Serb ethnic backgrounds later on, in other

5 meetings or through other means?

6 A. Well, later on we found out in contacts with the other members of

7 the Ministry of the Interior in the area of the SAO Krajina, and in

8 contact with ordinary citizens of either ethnic background, that these new

9 personnel who were admitted into the police, were being trained in a place

10 called Golubic, not far away from Knin, that that is where there is this

11 kind of training centre for members of the police of the SAO Krajina.

12 Q. Did you learn anything about who did the training there?

13 A. Since this information was not accessible to the ordinary citizens

14 with whom we were in contact every day, it was mostly personnel from the

15 Ministry of the Interior of Serbia. We unofficially talked to members of

16 the police of Krajina. These were unofficial operative contacts so that

17 we could learn something. Later on, the group itself established that

18 these were cadres from the Republic of Serbia.

19 Q. And did you learn what Milan Martic's role was with respect to the

20 training camp at Golubic?

21 A. Well, specifically we did not learn anything, but according to the

22 hierarchy, Milan Martic had to take all initiatives in terms of the number

23 of cadres, how many people would be taken in, how they would be trained,

24 and what their function would be later in the territory of the SAO

25 Krajina.

Page 3051

1 Q. Now, you made some references to the organisation of the police,

2 and you made a reference to -- you used the term OUP and you -- at another

3 time you used the term SUP or SUP. Can you explain how the police was

4 organised, if you know, if this is something you learned? How was the

5 police organised in Croatia, in the Republic of Croatia, and how did --

6 how was it changed by Milan Martic in the SAO Krajina? Do you understand

7 my question?

8 A. Yes.

9 Q. And if it would be easier for you to make a diagram, we could do

10 that. I could give you a piece of paper.

11 A. No problem whatsoever either, because this is a generally known

12 thing. At least for us who lived down there. This structure was well

13 known. The federal Ministry of the Interior was at the head of all these

14 services. Then one step lower was the republican Ministry of the

15 Interior. As for Serbia, there were two provincial ministries as well of

16 the interior, of Kosovo and Vojvodina respectively, and then as for the

17 other lines, it depended. Sometimes there would be slight variations in

18 different republics because every republic had an organisation of its own

19 but about 90 per cent would be similar or the same. In larger cities or

20 larger towns, that covered a larger territory, there were Secretariats of

21 the Interior. The lower level was the municipality and also smaller towns

22 or villages, MUP, OUP, and in terms of all the duties they had to perform,

23 their authority was less than at the higher level. And then there was the

24 station of the police, the police station, as such. I'm talking about the

25 level where I was present. Sometimes for example there would be a police

Page 3052

1 station with a single policeman only. I don't know how clear I was.

2 Q. Well, I think maybe it would be helpful if you could draw this in

3 a diagram form, and if you could do it with respect to the area that we

4 are talking about, that is Knin, Benkovac, Sibenik, and so forth, if you

5 could draw the different levels at the time n the Republic of Croatia, and

6 then if -- and then you could show us on the diagram how Milan Martic

7 changed it?

8 MR. WHITING: And if it could be put on the ELMO? And I suppose

9 we have to switch to the ELMO.

10 THE WITNESS: [Interpretation] Could I have a ballpoint pen,

11 please?


13 Q. And if you could start at the top with the republic SUP in the

14 Republic of Croatia, and then show -- do the diagram from there. So the

15 top should be the republic Ministry of the Interior.

16 A. [Marks]

17 Q. Okay. Can you read for us what it is you've written, starting

18 from the top, on this piece of paper? I can see "RSUP"? What have you

19 put --

20 A. That's the republican Secretariat of the Interior of a particular

21 republic, in this case Croatia. Its headquarters was in Zagreb. At the

22 lower level is the Secretariat of the Interior and those existed in every

23 larger municipality in Croatia. For example, Sibenik and Zadar each had

24 their own Secretariat, whereas Knin did not have one at the time. The

25 Secretariats had a higher level of authority and obligation. For example,

Page 3053

1 a Secretariat could issue a passport, a driving licence, a traffic

2 licence, and so on.

3 The lower level organ was the organ of the interior, and these

4 were in smaller municipalities. They encompassed a smaller territory and

5 had fewer personnel. They, in some places -- I can't be sure about

6 Croatia -- but for the most part these organs could not issue passports,

7 driving licences, traffic licences, and so on. There was within the

8 competence of the Secretariat. However, the organ to issue a public -- an

9 identity card and other documents valid for the citizens.

10 Then there was a police department underneath that. They did not

11 deal with general jobs such as could be done by the organ or the

12 Secretariat. These were simply policemen covering a municipality or a

13 local commune. Don't take my word for it, I don't know whether there were

14 five, 10 or 20 people there, depending on the area they covered.

15 And at the lowest level was a police station, which would be in a

16 certain town or village. For example, if a train passed through a certain

17 village or town, then there would also be a police station close to the

18 railway station. And it was just a room basically, where policemen had a

19 key and they could go there if necessary. It was more a place to go than

20 an office. There would be two or three policemen patrolling the area.

21 I'm not very familiar with it because I didn't work for that

22 service, but I did initially, of course, but later on I was transferred,

23 so I don't know how clear I have been.

24 Q. I want to just go through what the abbreviations are at each

25 level. The top obviously, you've written R SUP, republic SUP. The next

Page 3054

1 level, what is the abbreviation, what's the abbreviation for the next

2 level?

3 A. It would be SUP.

4 Q. And I believe you -- yeah, go ahead, why don't you write the

5 abbreviations at each level?

6 A. And OUP. Then OM. And SM.

7 Q. Now, I think you said that the -- at the SUP level was Sibenik and

8 Zadar but not Knin. What level -- could you write "Sibenik and Zadar"

9 just at that level, underneath the SUP there?

10 A. [Marks]

11 Q. And are there any examples of OMs that you can give us?

12 A. I can't be sure about OMs, whether Benkovac and Obrovac had OMs, I

13 think, according to what there was on the ground. I'm not sure. Because

14 when we arrived there, they already had organs, but I visited Benkovac and

15 Obrovac two or three times, and as far as I was able to see what the

16 buildings looked like, most probably they were just police -- I apologise

17 for sometime using the word Milicija and sometimes Policija, they both

18 refer -- when I use them I'm referring to the same thing. I think that in

19 Pakrac - I may be wrong - there may have been a police station there. I'm

20 not sure.

21 Q. But from what you could observe when you visited Benkovac and

22 Obrovac, did they appear to you to be at the level of the OUP or the OM or

23 can you explain?

24 A. They, when I was there, were at the level of the OUP. Before

25 that, they had very small premises, and judging by those premises, they

Page 3055

1 couldn't have done all the work that falls within the competence of an

2 OUP. It looked more like a police station, the SM. If there was a

3 reorganisation internally and they wanted to do various kinds of work in

4 one and the same room, one and the same office, I don't know. I didn't go

5 into all those details.

6 Q. Now, you've just made reference to the structure as it was when

7 you were there, and you observed it and how it had been before. You've

8 told us that Knin was an OUP. Was that how it was before or how it was in

9 the SAO Krajina?

10 A. When we got there, it was the Secretariat of the Interior of the

11 SAO Krajina. Before that, as we had been informed by Mr. Vukosic and the

12 assistant Minister of Croatia, Knin had been an OUP.

13 Q. So if I understand your testimony correctly, within the structure

14 in the Republic of Croatia, it's how you have drawn it. Sibenik and Zadar

15 were SUPs and Knin was an OUP but when the SAO Krajina was created, Knin

16 became -- Knin became a SUP?

17 A. Yes. It went a rung up the ladder so from being an organ it

18 became a Secretariat of the Interior.

19 Q. And did the same thing happen with Benkovac and Obrovac? Did they

20 move up the ladder whether the SAO Krajina was created?

21 A. When the SAO Krajina was formed, and the Knin OUP became the Knin

22 SUP, then automatically the Benkovac and Obrovac OUPs also increased their

23 authority and competences.

24 Q. And earlier --

25 JUDGE NOSWORTHY: I'm sorry, just one minute, should that be the

Page 3056

1 OMs instead of OUPs, in relation to Benkovac and Obrovac?

2 THE WITNESS: [Interpretation] Benkovac and Obrovac, before the SAO

3 Krajina was formed, were OMs. After the SAO Krajina was formed, they

4 became OUPs.

5 MR. WHITING: Thank you, Your Honour.

6 Q. Now, finally on this chart, you testified earlier that the

7 Croatian authorities told -- said that they had offered to make Milan

8 Martic -- put him in charge of a SUP in Knin. Am I understanding your

9 prior testimony correctly?

10 A. Yes, yes. The minister told us they wanted to promote or, rather,

11 strengthen the competencies of the OUP in Knin and to create a SUP there,

12 because in the OUP he could have only been the chief of the OUP, not the

13 secretary of the SUP. So that's a higher level post. That's what the

14 deputy minister said, that they offered Martic, that they would organise a

15 SUP in Knin and offer him the post of secretary of the Secretariat of the

16 Interior.

17 Q. But the condition of that was that he would have to accept

18 Croatian laws and Croatian jurisdiction?

19 A. Yes. That's correct. Without that, they would not do it. The

20 condition was for him to accept the legislation and laws of Croatia.

21 There were also the procedures, the rules of procedure of the organ of the

22 interior and he would have to accept the rules of procedure that were in

23 force throughout Croatia.

24 Q. And just while we are on this topic, could you tell us again what

25 did they tell you his response was to this offer that they were making to

Page 3057

1 him?

2 A. They said very decidedly that Martic refused to receive them,

3 although they tried in various ways to establish contact with him,

4 directly and indirectly, they tried to get him, to persuade him somehow,

5 to accept the post of secretary of the Secretariat, and allegedly, he

6 decidedly refused this, giving certain reasons for that.

7 Q. Did they tell you what the reasons were?

8 A. The first time the assistant minister spoke, he told us that

9 Martic had fallen under the influence of Serbia and Serbian official

10 policy, that allegedly he wanted to form a special, separate - I remember

11 his words very well - autonomous unit for the Serb people living in

12 Croatia, an autonomous unit within Croatia, as he said, which would

13 probably later become a province or a republic, and he said very decidedly

14 that Croatia would by no means accept this, that it would not allow the

15 parceling up of Croatia and the establishment of regional republican

16 structures on the territory of the Republic of Croatia.

17 MR. WHITING: Your Honour, could the chart that the witness has

18 drawn be given an exhibit number? And I think out of prudence it should

19 be placed under seal.

20 JUDGE MOLOTO: The chart that the witness drew is admitted into

21 evidence under seal. May it please be given an exhibit number.

22 THE REGISTRAR: That will be Exhibit number 283, Your Honours,

23 under seal.

24 JUDGE MOLOTO: Thank you very much.

25 MR. WHITING: Your Honour, I see there is about two minutes left

Page 3058

1 in the session. I'm about to start an entirely new topic so I wonder if

2 it would be a convenient time to break, just a couple of minutes early.

3 JUDGE MOLOTO: Okay. Very well, then.

4 Witness, we are going to break for the day today. You must come

5 back on Monday at --

6 MR. WHITING: It's 9 a.m., Your Honour.

7 JUDGE MOLOTO: 9 a.m.

8 MR. WHITING: In Courtroom III, a different courtroom.

9 JUDGE MOLOTO: In Courtroom III. I guess somebody will take you

10 there.

11 Court adjourned.

12 --- Whereupon the hearing adjourned at 1.44 p.m.,

13 to be reconvened on Monday, the 3rd day of April,

14 2006, at 9.00 a.m.