Page 13068
1 Thursday, 26 August 2010
2 [Open session]
3 [The accused entered court]
4 [The witness takes the stand]
5 --- Upon commencing at 9.02 a.m.
6 JUDGE MOLOTO: Good morning, everybody in and around the
7 courtroom.
8 Mr. Registrar, would you please call the case.
9 THE REGISTRAR: Good morning, Your Honours. Good morning to
10 everyone in and around the courtroom. This is case number IT-04-81-T,
11 the Prosecutor versus Momcilo Perisic. Thank you.
12 JUDGE MOLOTO: Thank you so much.
13 Could we have the appearances for the day, starting with the
14 Prosecution, please.
15 MR. HARMON: Good morning, Your Honours, counsel, everyone in the
16 courtroom. Mark Harmon and Salvatore Cannata for the Prosecution.
17 Ms. Javier has been delayed by the inclement weather, and she will join
18 us during the proceedings.
19 JUDGE MOLOTO: Thank you so much.
20 And for the Defence.
21 MR. LUKIC: [Interpretation] Good morning. Good morning,
22 Your Honours. Good morning to all the participants in the proceedings.
23 General Perisic is represented today by Boris Zorko and Novak Lukic.
24 JUDGE MOLOTO: Thank you very much, Mr. Lukic.
25 Good morning, Mr. Novakovic. Just to remind you that you're
Page 13069
1 still bound by the declaration you made at the beginning of your
2 testimony to tell the truth, the whole truth, and nothing else but the
3 truth. Thank you so much.
4 Mr. Lukic.
5 WITNESS: MILE NOVAKOVIC [Resumed]
6 [Witness answered through interpreter]
7 Examination by Mr. Lukic: [Continued]
8 Q. [Interpretation] Good morning, General. Now that -- actually,
9 now when you walked into the courtroom I think that you tried to tell me
10 something and I think that I understood what you were trying to say;
11 however, we are not allowed to communicate. So could you please address
12 the Court. Could you please say what it was. I think that it was due to
13 the air-conditioning that you've started coughing or something, the
14 air-conditioning in the courtroom.
15 A. Yes, I think I have a bit of a throat problem, but it's
16 meaningless really.
17 Q. [In English] Okay.
18 JUDGE MOLOTO: Nothing is meaningless, Mr. Novakovic. If you do
19 not feel well, as I indicated at the beginning of your testimony
20 yesterday, please do indicate, and let's see what we can do to help.
21 If -- I don't know whether we can switch off the air con, but we might
22 perhaps give you a break to go and get fresh air outside, if it happens.
23 THE WITNESS: [Interpretation] Thank you very much, Your Honour.
24 I think that we can consider the situation to be normal. If I cough a
25 bit every now and then, I do apologise.
Page 13070
1 JUDGE MOLOTO: Thank you very much. I understand.
2 Yes, Mr. Lukic.
3 MR. LUKIC: [Interpretation] This just reminded me of something
4 that I heard from witnesses after their testimony. I just remember that.
5 They told me that where they sat - I can't remember whether it was in
6 this courtroom though - but they had the air-conditioning blowing right
7 into them. Maybe it was in another courtroom. Never mind. They said
8 that they felt this flow of air coming right at them. I think it was
9 Witness Nikolic, but that is no reason for any objections or any kind of
10 dialogue with respect to that.
11 JUDGE MOLOTO: Thank you.
12 MR. LUKIC: [Interpretation]
13 Q. General, let us continue where we broke off yesterday. I would
14 just like to go back to a topic that I omitted yesterday because I did
15 not have the adequate translation. So we're going to go back into the
16 past again, the period of the autumn of 1991, or rather, more
17 specifically, December 1991, when you were part of the
18 1st Operations Group that was sent by the SSNO to the territory of
19 Baranja.
20 MR. LUKIC: [Interpretation] Could we have P1196 on the screen,
21 please.
22 Q. As we can see, this document is the Law on Defence and it was
23 promulgated by the government. I think that the Trial Chamber does not
24 have the first page of the document before them, but what is written on
25 the first page is that the Government of the SAO Krajina passed a
Page 13071
1 Law on Defence on the 2nd of December, 1991. The Prosecution tendered a
2 few articles of this law. This is a voluminous document. It has quite a
3 few articles, about 150 or 120. I would be interested in Article 31. I
4 think that that is one of the articles that the Prosecution tendered into
5 evidence as well.
6 MR. LUKIC: [Interpretation] B/C/S page is page 6, page 6 of the
7 document. In English it starts at the end of page 2 and continues on
8 page 3.
9 Q. General, I'm interested in the first paragraph. Please read it
10 to yourself, the first paragraph of Article 31?
11 A. I've read it.
12 Q. Yesterday we discussed this --
13 MR. LUKIC: [Interpretation] Actually, could the next page in
14 English be brought up so that the Trial Chamber can follow.
15 Q. The Territorial Defence that, on the basis of this law became -
16 if I can put it that way - part of the system of the then-Serb autonomous
17 region of the SAO Krajina on the 2nd of December, 1991. According to
18 this particular regulation and according to the contacts you had then
19 with the members of the TO staffs at the time, what do they consider
20 themselves to be? Were they part of the single system of defence and
21 armed forces of the SFRY or did they consider themselves to be something
22 separate?
23 A. The actual practice was - and that was the understanding that
24 people had in the Territorial Defence - that they were, as was the case
25 until then, on the basis of regulations, part of the single armed forces
Page 13072
1 of the Socialist Federal Republic
2 Q. Now I would like to -- now I would like to look at Article 34.
3 In the B/C/S it's the same page, and I'm going to call up the English
4 translation because that article was not admitted into evidence when the
5 Prosecution tendered it.
6 MR. LUKIC: [Interpretation] So I would like to call up Article 34
7 as ET 1D12-0969.
8 Q. This is a draft translation, may I say. General, I'm interested
9 in the first paragraph -- actually, the entire article. I would like to
10 hear your comment. In actual fact, you testified about this yesterday.
11 This has to do with control and command in this Territorial Defence. You
12 said that there were staffs and units in the Territorial Defence.
13 According to this article here, it says that command and control
14 in the Territorial Defence has to do with the fact that these staffs
15 command the TO units. What was the situation in December 1991 in
16 practice in relation to this provision of the law?
17 A. In the autumn and winter of 1991, these staffs, where they had
18 been established - and they had been established up to zone level and
19 province level in the Serb autonomous region of Krajina - they did not
20 directly command units. The units were directly commanded by the
21 commands of the Yugoslav People's Army that were in a particular area.
22 These staffs could not do that, they did not have the right conditions
23 for doing that, and they didn't do so in practice.
24 Q. These TO units, these TO units that had been established
25 according to the old system of the armed forces of the SFRY -- or
Page 13073
1 actually, are we talking about some newly established TO units?
2 A. These are units that were established according to the
3 mobilisation plan that existed before the war.
4 Q. Thank you.
5 MR. LUKIC: [Interpretation] Your Honours, since this is a draft
6 translation, once we've received an official translation of this article,
7 perhaps we could just attach that to the existing P exhibit. Otherwise,
8 in B/C/S Article 34 that I'm interested in is already part of this
9 exhibit in B/C/S. So that is what I'm primarily interested in.
10 JUDGE MOLOTO: Thank you. You're not asking for anything. We'll
11 hear you when you make your request in future.
12 MR. LUKIC: [Interpretation] Yes. Yes, once I've received an
13 official translation. Thank you. Thank you, Your Honour.
14 I don't need this document any longer.
15 Q. And now we're going to go back to what you testified yesterday.
16 Yesterday we saw a document appointing you commander of the Serb Army of
17 the Krajina general. It's October 1992. Can you tell us, General, what
18 you did, what your first tasks were when you were appointed commander of
19 the Serb Army of the Krajina?
20 A. My first task was to tour the entire area of the Serb Republic
21 the Krajina to see the situation in the Territorial Defence and also the
22 PJMs. Also, to see what kind of information existed about the enemy, to
23 talk to the leaders of the Republic of the Serb Krajina about their
24 expectations in relation to defence, and to carry out an analysis,
25 together with my co-workers, of the possible ways in which the Serb Army
Page 13074
1 of the Krajina could be organised. Several variants were involved. We
2 had to deal with the situation as it was.
3 Q. And what were the moves that followed?
4 A. First of all, all the solutions that were being offered to us as
5 the possible ones had a serious constraint, and that constraint was the
6 presence of UNPROFOR and our resolve not to go beyond the Vance Plan in
7 any way. In practical terms, that meant that at that point in time, as
8 regards the Serb Army of the Krajina, we were establishing it from an
9 administrative and organisational point of view; we are setting it up in
10 terms of personnel; we are making assessments of the possible ways in
11 which the population in the territory of the Republic of the Serb Krajina
12 could come under threat. And we did all of that in accordance with the
13 rules covering military geographic assessments on the one hand; and on
14 the other hand, we had to look at what we had available, what we had in
15 our hands at the time.
16 Q. Was the establishment of the army being set up then; and if not
17 then, when? And who did it?
18 A. The organisational order was written up then for establishing the
19 Serb Army of the Krajina. That means that for the most part we proceeded
20 from the situation that we actually found on the ground, what had already
21 come to be in certain territories of the Republic of the Serb Krajina in
22 the armed conflicts that had taken place until then. As for classical
23 formations in terms of internal regulations - I mean as the book of
24 establishment, that's where it always says what the name of the unit is,
25 what the number is, what the military post code is, then the duties
Page 13075
1 according to establishment, ranks according to establishment, and so
2 on - we didn't do any of that then. The Main Staff didn't really have
3 the resources to do that because it was undermanned itself.
4 Q. And how was the establishment organised? What was the
5 organisational structure according to which the units of the Army of the
6 Serbian Krajina were set up?
7 A. It was a corps-brigade organisational system, which was common at
8 the time in most of the armies of the world except for the US army.
9 Q. And whose decision or whose idea was it to adopt such an
10 organisational system for the Serbian Army of the Krajina?
11 A. It was myself and my associates'.
12 MR. LUKIC: [Interpretation] Can we look at D164 now, please, on
13 the screen.
14 Q. While we're waiting for the document, General, which structures
15 became part of the Army of the Serbian Krajina in relation to the
16 previous situation in the field?
17 General, what comprised the Serbian Army of the Krajina?
18 A. The Army of the Serbian Krajina comprised the staffs of the TO,
19 units -- the Posebne Jedinice Milicije, the PJMs, and the ranks were also
20 replenished by all military conscripts, regardless of the fact whether
21 they were in the TO or the PJM at the time, but were able-bodied.
22 Q. That organisation that you devised at the time, what was the
23 estimate of the strength of the Army of the Serbian Krajina?
24 A. We felt at the time that in the conditions where the people in
25 the area of the Serbian Krajina were most in danger, the Army of the
Page 13076
1 Serbian Krajina should number up to 80.000 men. But with maximum
2 efforts --
3 JUDGE MOLOTO: Mr. Novakovic, we know what your wishes may have
4 been. The question is: What was the strength? Not: What is the
5 strength that you wished for?
6 THE WITNESS: [Interpretation] Your Honour, the army as such at
7 that point in time did not exist. We were planning to form these units
8 then, in the event of the imminent and open danger. And that is why on
9 the basis of an incomplete insight into the demographic resources and the
10 official census of the population in the municipalities, we felt that we
11 could reach this number.
12 JUDGE MOLOTO: Sure. But did there come a time when you did
13 establish an army?
14 THE WITNESS: [Interpretation] Yes.
15 JUDGE MOLOTO: And when that time came, what was the strength of
16 the army?
17 THE WITNESS: [Interpretation] If we are also including the PJMs
18 and the TO staffs, that number ranged from 15- to 18.000.
19 JUDGE MOLOTO: Total army?
20 THE WITNESS: [Interpretation] Yes.
21 JUDGE MOLOTO: Does that answer your question, Mr. Lukic?
22 MR. LUKIC: [Interpretation] I don't think so because my question,
23 Your Honour, Judge Moloto -- well, if you look at this line, I was going
24 to go in order, and I was planning to put all of those questions to the
25 witness. So line 18 on page 8, my -- my question was: What was the plan
Page 13077
1 for the size of the army? And then I was going to put the questions that
2 you have just put to the witness yourself.
3 Q. But this answer that you just gave, General, 15- to 18.000 men,
4 at what point in time did the Army of the Serbian Krajina number that
5 much?
6 A. This was after the army was formed, and this number included the
7 PJMs and all the municipal and area TO staffs as well as the Main Staff.
8 Q. After that point in time, in the next phase of the existence of
9 the Army of the Serbian Krajina for as long as you were the commander of
10 that army, in relation to the planned strength of 80.000, did you have a
11 mobilisation, was there a response, were the units manned up to a larger
12 number, the units of the Army of the Serbian Krajina?
13 A. After the Croatian forces carried out an offensive, an attack, in
14 the Maslenica inlet and the Ravni Kotari area and along the valley of the
15 Cetina River
16 that is when we approached that figure of 80.000, and that is when we
17 took the weapons from the UNPROFOR depots.
18 Q. We will come to that question quite soon. But now that we're on
19 this topic, I'm interested in the officer cadre of this Army of the
20 Serbian Krajina, the commissioned and non-commissioned officer cadre.
21 What was the plan, and how many men did you have at the begin? That's
22 the first question.
23 A. The officer and non-commissioned officer cadre in the Army of the
24 Serbian Krajina mostly consisted of reserve-strength officers, both
25 commissioned and non-commissioned officers from that area, and a slightly
Page 13078
1 smaller number were officers and non-commissioned officers of the
2 Yugoslav People's Army from that area.
3 Q. Here in our court documents we do have some numbers. But what
4 I'm interested in: In relation to the planned organisational structure
5 of the Army of the Serbian Krajina, what was the percentage, in the
6 beginning, of the planned number of officers and non-commissioned
7 officers pursuant to this organisational structure?
8 A. I think that now we're going into an area where I really am not
9 able to give you specific numbers, and this is why: We needed to have
10 battalion commanders of the rank of major, those who had completed
11 military academy. We just had 50 per cent of such officers as battalion
12 commanders.
13 Q. Well, just a moment. Let us be precise. When you say "who
14 completed the military academy," this is what we were talking about
15 earlier, the professional cadre of the former JNA. I don't want to
16 suggest anything to you, but that would be that, a person who completed
17 military academy is somebody who is understood to be an active-duty
18 professional military man. Is that correct?
19 A. Yes. That would be so because there was no other military
20 academy in the area of the former Yugoslavia
21 Q. Yes, yes, yes.
22 A. I cannot say now if we had the other 50 per cent of battalion
23 commanders or not. I mean, all the battalions had commanders, but we had
24 what we had. Some places, these were non-commissioned officers also who
25 had proved themselves in battle and who had gained some kind of authority
Page 13079
1 among the men.
2 Q. When you say "non-commissioned officer," do you mean active JNA
3 non-commissioned officers or those who had been given that status within
4 the Army of the Serbian Krajina?
5 A. I mean both, Mr. Lukic, both. It wasn't important to us which
6 one it was, particularly at that time, whether somebody had been in the
7 JNA or not. The main thing was whether the person was fit for such duty.
8 Q. General, we see a map now on the screen and it has some terms in
9 English. But tell us, are you able to comment on this map? I'm
10 interested in it in the sense that you were talking about in the
11 corps-brigade organisation system of the Army of the Serbian Krajina.
12 Can you tell us how the territorial organisation of those corps was, and
13 was that the same situation that was in effect from the beginning until
14 the end of the war?
15 A. When we were setting up the organisation of the Army of the
16 Serbian Krajina, certain areas of the Republic of the Serbian Krajina -
17 and you can see that on the map - we're talking about Northern Dalmatia
18 Q. Perhaps the usher can help and he can set up the marker for you
19 so that you can point things out for us on the map.
20 A. Northern Dalmatia --
21 Q. Well, let's go in order. It says something here in the English
22 language, what you wrote just now. What was that corps? What was its
23 name? And was it there throughout the whole war?
24 A. All right. I will skip a part of the answer, as you wish. So we
25 have Northern Dalmatian where we had the 7th Corps in the Lika area,
Page 13080
1 which was a topographic whole, there was the 15th Corps. In the Kordun
2 area, the 21st Corps was formed. In the Banija area there was the
3 39th Corps that was formed. And then in Western Slavonia you had the
4 18th Corps. And then you had the 11th Corps in east Slavonia, Baranja,
5 and Western Srem.
6 MR. LUKIC: [Interpretation] For the needs of the transcript, I
7 would just like to note that the witness circled the corps names --
8 numbers.
9 Q. You mentioned the term topographical. So for an army or a
10 country as a whole, what would you say was the main characteristic
11 specific to the Republic of the Serbian Krajina?
12 A. What you can see right away when you analyse the geographical
13 area is that the eastern area is completely separate and physically
14 remote from the rest of the territory. The western part is elongated and
15 very shallow, looked at from a military perspective in case of action by
16 forces along the line -- the front line between the forces of the Serbian
17 Krajina and the Croatian forces. The depth of the territory or the width
18 of the territory, if you wish, was from 30 to 50 kilometres broad. But
19 when you look from the Dinara Mountains
20 some 80 kilometres broad. All the other area was quite shallow, quite
21 elongated, and exposed to being cut off.
22 What I tried to tell you in the beginning was this: When we were
23 looking at this, we had zone staffs there. And this wasn't something
24 that was set up just like that. The Dalmatia is separated from the
25 Dinara, and that was a border there. So there was also a border between
Page 13081
1 areas of responsibility between Lika and Kordun.
2 There was also a boundary between Kordun and Banija. And
3 Western Slavonia, although there was a physical connection, there was no
4 possibility of actually reaching the area. In order to reach that area,
5 you had to go through Republika Srpska in order to reach Western Slavonia
6 or the area of responsibility of the 18th Corps, which was quite
7 unfavourable.
8 Q. Let us be precise because of the map. We don't want to be
9 confused later. So let's clarify. The territory controlled by the
10 39th Corps, in order to reach the area controlled by the 18th Corps,
11 there was no direct access. It did exist physically, but it was not
12 actually used. The way to reach it was through the territory of
13 Republika Srpska. Is this what you wanted to say?
14 JUDGE MOLOTO: Yes, Mr. Harmon.
15 MR. HARMON: Your Honour, that's a leading question and I object.
16 The witness can say what he wanted to say, not Mr. Lukic.
17 JUDGE MOLOTO: Mr. Lukic.
18 MR. LUKIC: [Interpretation] I apologise. I'm sorry. I just
19 wanted to help, but in a wrong way. And eventually I did something I am
20 not allowed to.
21 Q. General, could you please explain whether there was any physical
22 connection there; and if not, why.
23 A. In this part that I proximately marked, the territory of Banija
24 and the territory of Western Slavonia join -- are joined on the
25 Sava River
Page 13082
1 bridge there. This bridge was never operational for passenger transport,
2 and the land around it is a marsh land. Therefore, one had to go, as I
3 said, across the territory of Republika Srpska, or rather, under the
4 control of the Army of Republika Srpska.
5 Q. Thank you. While we are still looking at the map, two more
6 things. There is something that we are going to discuss at a later
7 stage, but since the Trial Chamber has the map in front of themselves, I
8 would like to discuss an area which is outside the territory of the
9 Republic of Serbian Krajina which is called Velika Kladusa. Can you
10 explain where this area was and in what way, if any, was it strategically
11 important for the territory of the Serbian Republic
12 JUDGE MOLOTO: Mr. Lukic. Mr. Lukic, you know, I know that
13 Mr. Harmon seldom stands up to object, but your questions are leading.
14 You are assuming -- you are telling us that Velika Kladusa was of
15 strategic importance. We are not being told by the witness. The way you
16 phrase your question is -- you are actually telling us that that area was
17 of strategic importance, and you are not testifying. The person who is
18 testifying is the witness. You can ask -- frame your question in such a
19 way that you don't tell him that that area was of strategic importance.
20 MR. LUKIC: [Interpretation] I honestly believe that I didn't make
21 any suggestions to the witness. I asked him whether it was of any
22 strategic importance or not. I can understand in a certain sense that I
23 may have suggested this to the witness, but I really don't believe --
24 JUDGE MOLOTO: Okay. Let's read how you have been interpreted:
25 "While we are still looking at the map, two more things. There
Page 13083
1 is something that we are going to discuss at a later stage, but since the
2 Trial Chamber has the map in front of themselves, I would like to discuss
3 an area which is outside the territory of the Republic of Serbian Krajina
4 which is called Velika Kladusa. Can you explain where this area was and
5 in what way, if any, was it strategically important for the territory of
6 the Serbian Republic
7 THE WITNESS: [Interpretation] Your Honours, if you allow me, I
8 wouldn't believe Mr. Lukic if he were to tell me whether this was
9 strategically important or not.
10 JUDGE MOLOTO: That's not important. That's not the point. The
11 point is he mustn't suggest that to you. He must ask you questions and
12 you must tell us, if you do know, whether the area was of strategic
13 importance to you; and if so, why.
14 MR. LUKIC: [Interpretation] There is perhaps a discrepancy
15 between the English interpretation of what I said, but as a schoolboy if
16 I put a question whether this was of strategic importance or not, I don't
17 think I can qualify that as a leading question because we are constantly
18 talking about the subject relating to organisation and the functioning of
19 an army. If I put a question of what importance this is, we have to
20 focus on the strategy. And if I ask if this was strategically important
21 or not, I don't believe that's a leading question. At any rate --
22 JUDGE MOLOTO: You don't believe that was a leading question. I
23 tell you, it is a leading question, Mr. Lukic. And if you can try to
24 avoid asking leading questions. Thank you.
25 MR. LUKIC: [Interpretation] Can we go back to my first
Page 13084
1 question --
2 JUDGE MOLOTO: Let him answer the question. After all, you've
3 asked the question anyway.
4 MR. LUKIC: [Interpretation]
5 Q. General.
6 A. Mr. Lukic, as a first part of my answer to your question, I will
7 tell you that in the geographical and military assessment made up in the
8 former SFRY, a conclusion was reached that there were several strategic
9 features that were crucial for the whole SFRY - and Mr. Perisic knows
10 well about that.
11 Secondly, the area between Zagreb
12 including Karlovac and Bihac, was considered to be held by someone to the
13 disadvantage -- to the advantage of them having access to the sea,
14 coastline, and other areas.
15 In our view -- in our view, in the Republic of Serb Krajina
16 particular area was exceptionally significant. Our main interest was:
17 If we cannot have friends there, to avoid at least having enemies there.
18 We were anyway outnumbered in the ratio 8:1 in comparison to the Croatian
19 forces. Now, if you add to that an enemy behind our backs with regard to
20 this front line facing the Croatian forces, then that would be a lost
21 cause in advance. This danger was enhanced by the fact that in this area
22 there was a huge number of personnel. There were many young men fit for
23 military service in that area, unlike our area which was demographically
24 very drained.
25 Q. We're going to complicate the map too much.
Page 13085
1 MR. LUKIC: [Interpretation] I don't know, Your Honours, if in
2 this manner we are going to be able to enter this map into evidence. Do
3 I have to state anything else, or is it possible for you to follow the
4 testimony by way of the transcript? We are going to look at another map
5 anyway.
6 JUDGE MOLOTO: We are in your hands, Mr. Lukic.
7 MR. LUKIC: [Interpretation] I suggest that we enter the map as it
8 is into evidence and then I will have another copy for more markings to
9 be made.
10 JUDGE MOLOTO: The document is admitted into evidence. May it
11 please be given an exhibit number.
12 THE REGISTRAR: Your Honours, this document shall be assigned
13 Exhibit D436.
14 JUDGE MOLOTO: Thank you very much.
15 MR. LUKIC: [Interpretation]
16 Q. General, did you want to say something about Korenica?
17 A. In the Socialist Federal Republic of Yugoslavia, the municipality
18 of Korenica was the least populated one. It had 18 inhabitants per
19 square kilometre. This is just for the sake of comparison with the other
20 areas that we discussed on the Bosnian side of the border.
21 Q. Under which name was this area also known in the map where we see
22 the name "Velika Kladusa"? How was it called apart from that?
23 A. The international community used to call it the Bihac pocket
24 because that was the Bihac protected area, and it was -- also used to be
25 called the autonomous province of Western Bosnia at the time when
Page 13086
1 Mr. Fikret Abdic established such an entity in this area.
2 Q. Now we'll still have the map on the screens. I'm going to ask
3 you to make another marking. You mentioned that a minute ago as
4 something that had certain importance to -- for the Army of
5 Republika Krajina. You mentioned the Maslenica bridge. Can you tell us
6 what happened and what the consequences of that attack were as you
7 mentioned.
8 A. In January of 1993, the Croatian forces launched a massive attack
9 here in the area of the Maslenica strait and in the zone of Ravni Kotari
10 and in the valley of the Cetina towards Knin. Those were the main axes
11 of their attack. There was another attack against Mount Velebit
12 Perhaps if we enter too many details into this map maybe we
13 should have a new one.
14 Q. No problem.
15 MR. LUKIC: [Interpretation] I would like Your Honours to tender
16 the map as it is into evidence.
17 JUDGE MOLOTO: The map is admitted into evidence. May it please
18 be given an exhibit number.
19 THE REGISTRAR: Your Honours, this document shall be assigned
20 Exhibit D437. Thank you.
21 JUDGE MOLOTO: Thank you.
22 MR. LUKIC: [Interpretatio.
23 Q. General, perhaps you would be sorry to hear that I am reluctant
24 to discuss this conflict any further, but I just wanted to know what the
25 consequence of that attack was with respect to the protected areas
Page 13087
1 according to the Vance Plan.
2 A. Yes, you now told me precisely what you want me to tell you. So
3 the Croatian forces attacked what for the United Nations was
4 Sector South, i.e., an area under the UN protection. In that area, in
5 this particular point that was under the most threat --
6 Q. There's no need for that, General. Let's not dwell on this for
7 too long. Can you just answer my question.
8 A. So a United Nations protected zone was attacked. The UNPROFOR
9 units deployed in that area did not respond in any way whatsoever. They
10 simply vanished from the face of the earth. And these units operated in
11 this area, as they did in any area where there were no UNPROFOR forces,
12 and as a consequence we lost this particular area and never managed to
13 re-capture it. That was basically what happened.
14 Q. What were the consequences with regard to this attack concerning
15 your obligations stemming from the Vance Plan? Did you continue to
16 adhere to these obligations?
17 A. On that morning, we had no other way but to take up arms from the
18 UNPROFOR depot and to defend themselves if UNPROFOR was not prepared to
19 do so. The UNPROFOR units reacted in a variety of ways: Some of them
20 disappeared as an element of the situation prevailing at the time; some
21 of them were in our way because the Croatian forces were operating from
22 their positions; and some UNPROFOR units did help us in an attempt to
23 pull out our heavy artillery to our positions as soon as possible. I can
24 say that openly because I am grateful to those people that this was done
25 by --
Page 13088
1 THE INTERPRETER: Interpreters didn't hear the name of the
2 battalion.
3 JUDGE MOLOTO: Sorry, the interpreters didn't hear the name of
4 the battalion.
5 MR. LUKIC: [Interpretation]
6 Q. Could you please repeat, General.
7 A. Nigerian Battalion.
8 Q. Did you, General, or some other representatives of the
9 authorities of the Serbian Krajina have contacts with UNPROFOR and the
10 international community concerning this incident?
11 A. We had very intensive contacts with representatives of the
12 international community. I myself didn't have so many of those contacts
13 because I was on the front line. However, representatives of the
14 government and people from the Main Staff in charge of liaising with the
15 international community did have such contacts.
16 Q. First of all, how did that incident end? Until when did combat
17 go on, if any?
18 A. That incident was never fully brought to an end. There was
19 intensive combat in January, February, March. Later on, the intensity of
20 these operations subsided and an agreement was reached to the effect that
21 the Croatian forces should withdraw to their starting positions. I can
22 say that one of the elements involved in this alleviation of the
23 situation was the presidential statement from the United Nations that
24 asked for the same thing.
25 The Croatian forces never fully withdrew from this area.
Page 13089
1 According to that agreement, I think that our milicija was supposed to
2 enter the area; however, they didn't. For me the most important matter
3 in all of this was the fact that the protection force of the UN was not
4 protecting the territory or could not protect the territory. I thought
5 that they would do that not by way of weapons but by way of the authority
6 of the United Nations.
7 Perhaps my thinking was wrong at the time. Perhaps my thinking
8 is wrong to this day. However, it seemed to me then - and I still think
9 so to this day - that Croatia
10 a UN protected area and if that area was being protected by UN forces,
11 what is this superpower that can attack the United Nations? My
12 understanding, my perception of the situation, was along those lines, and
13 that led me to very pessimistic conclusions in respect of our own
14 destiny.
15 Q. Could you explain to us -- could you explain how these
16 pessimistic conclusions of yours were reflected.
17 A. It seemed to me that foreign political conditions were created in
18 such a way because of the strong international support enjoyed by Croatia
19 at that moment, which was shown by the fact that there was no serious
20 condemnation of what they did on the one hand; and on the other hand,
21 there was the fact that we did not have that kind of international
22 support. Therefore, the balance of power would shift considerably to our
23 detriment.
24 Q. What was your forecast after March 1993 in terms of whether there
25 could be other attacks against the UNPA, attacks by Croatia, that is?
Page 13090
1 A. Our assessment was that that was possible. Through our
2 intelligence resources we tried to find out about that, namely, what was
3 the next area that could be in danger, according to this principle of
4 tacit crawling occupation. The situation was as it was in the area, and
5 we were isolated from other parts of the territory that was under our
6 control within the UNPA.
7 Q. All right. Now, what happened to that heavy weaponry that you
8 took from the depots that had previously been with a double key; were
9 they retained by your forces or not?
10 A. Both options were there. In this area that proved to be
11 particularly threatened, that is to say, Northern Dalmatia, Lika, Kordun,
12 and Banija, that weaponry remained in their respective firing positions.
13 We could not run the risk of being attacked by Croatian forces and then
14 trying to pull our weapons out of depots. However, in the zone of the
15 18th Corps in Western Dalmatia and in the area of the eastern part of the
16 Republic of the Serb Krajina, that is to say, in the area of Baranja,
17 Western Srem, and Eastern Slavonia, these weapons and our artillery
18 pieces remained under the double-key principle.
19 Q. What was the reaction of the representatives of UNPROFOR and the
20 international community in relation to these decisions of yours?
21 A. None of them put that question to me anymore, at least not to me
22 personally, why these weapons of ours were at firing positions. Part of
23 their reaction was that preparations would be underway for a cease-fire.
24 I think that that was their assessment, that that should be done next.
25 Q. A few moments ago when we discussed the structure of the
Page 13091
1 organisation of the Army of the Serb Republic
2 what happened before the incident and what the situation was afterwards.
3 In relation to what happened in the Maslenica strait, January 1993, what
4 was the organisation and the structure of the Serb Army of the Krajina
5 like then -- actually, I don't want to go into compound questions yet
6 again.
7 A. The structure was identical or almost identical, as it was stated
8 in the organisational order. However, the artillery units in the
9 18th Corps and in the 11th Corps in the eastern part were not fully
10 developed because their weaponry was in UNPROFOR depots.
11 Q. Now I'd like to go back to the personnel levels, especially in
12 terms of officers, commissioned and non-commissioned. In that period of
13 time and further on, can you tell us in your assessment what the
14 percentages of personnel levels were for officers in the Serb Republic
15 the Krajina.
16 A. The level was about 20 per cent.
17 Q. In relation to that first period, the beginning of 1993, in the
18 forthcoming period, were there increases in the number of officers? Let
19 me put a specific question: Did officers of the Army of Yugoslavia come
20 to the Serb Army of the Krajina?
21 A. Yes, officers from the Army of Yugoslavia did come to the Serb
22 Army of the Krajina.
23 Q. Can you tell us, to the best of your recollection, whether there
24 were increases then and what was the level of manning and what was the
25 situation later -- actually, I'm referring to the personnel level in the
Page 13092
1 ranks of the officers of this army.
2 A. Again you are --
3 JUDGE MOLOTO: Yes, Mr. Harmon.
4 MR. HARMON: Your Honour, perhaps we could have a very specific
5 questions because there are about two questions or three questions
6 embedded in this. The first question is whether there were increases,
7 what the level of manning was, what the situation was later, et cetera.
8 So if we could have a precise question, it would make it clearer.
9 JUDGE MOLOTO: Mr. Lukic.
10 MR. LUKIC: [Interpretation]
11 Q. General, you talked about the percentage of manning in terms of
12 the personnel levels in officers' ranks, 20 per cent. I'm talking about
13 January 1993 onwards. Was that number on the rise; and if so, until
14 when?
15 A. That number rose over the following two months and then it went
16 down. However, Mr. Lukic, if possible, let us not create any confusion
17 here. When we're talking about officers, commissioned and
18 non-commissioned, of the Serb Army of the Krajina, it's save 5.000 men.
19 Now I don't know whether you are asking me about all of those officers
20 and NCOs of the Serb Army of the Krajina, or are you just asking me about
21 the officers of the former JNA? These are two different things,
22 completely different.
23 Please, if you are asking me about officers and NCOs who are
24 reserve officers who were never members of the JNA but who were officers,
25 commissioned and non-commissioned, of the Serb Army of the Krajina, that
Page 13093
1 is one thing. I can respond as far as they are concerned. Namely, that
2 in January, February, and March, April, for as long as the intensive
3 combat operations were on, that number was at maximum level. However, at
4 the moment when combat operations between our forces and the Croatian
5 forces went down in intensity, the number went down as well. These were
6 people who had their own families, their own problems, and from time to
7 time we had to let them go so that they could provide a living to their
8 own families.
9 As for commissioned and non-commissioned officers of the former
10 Yugoslav army who at that moment had the status of officers of the Army
11 of Yugoslavia
12 of combat was reduced. There wasn't a drastic reduction because
13 individuals from the Army of Yugoslavia agreed to come as if they were
14 tourists on a tour, purportedly waging war for two or three months and
15 then going back. However, from mid-1993 that number was decreased in
16 absolute terms.
17 JUDGE MOLOTO: Would that be a convenient point?
18 MR. LUKIC: [Interpretation] Yes, Your Honour.
19 JUDGE MOLOTO: We'll take the break and come back at quarter to
20 11.00. Court adjourned.
21 --- Recess taken at 10.15 a.m.
22 --- On resuming at 10.45 a.m.
23 JUDGE MOLOTO: Mr. Lukic.
24 MR. LUKIC: [Interpretation]
25 Q. General, before the break you gave an answer that relates to the
Page 13094
1 arrival of officers from the Army of Yugoslavia to you, to the Army of
2 the Serbian Krajina. And in the English it was translated as "tourists
3 on tour." You mentioned the term in Serbian, so I don't need to quote it
4 in Serbian. In the following period, were there officers and
5 non-commissioned officers of the JNA who came to the Army of the Serbian
6 Krajina and became officers of the Army of the Serbian Krajina?
7 A. Yes, there were.
8 Q. And how long did they come for? How long were the periods? What
9 was the situation with that?
10 A. They would usually come for a period of a few months.
11 Q. And is that what you said earlier, before the break, as them
12 coming for tourism, as you said on page 26, line 4?
13 A. Yes, perhaps it was a little bit of a picturesque description,
14 but my intention was to say that they came there out of duty, not because
15 they were really motivated to come.
16 Q. And were there those who came and then stayed until the end of
17 the war or for a longer period of time in the Army of the
18 Serbian Krajina?
19 A. Yes, there were such cases too. Some of them were killed in
20 1995.
21 Q. And what was the position of the members of the Army of the
22 Serbian Krajina, the soldiers and the officers, towards those who would
23 come for brief periods -- towards those who didn't want to stay there for
24 longer?
25 A. The position was generally not favourable. It was a position of
Page 13095
1 rejection. They were not appreciated, because the people who were at the
2 front from the beginning believed -- thought that their position in terms
3 of the defence of the people was insincere, it wasn't genuine.
4 As far as we were concerned, us in the commands of the Army of
5 the Serbian Krajina, we also had problems because of the -- these people
6 who came. These were usually people of higher rank who mostly sat around
7 in the command, and there was not much use to be had from them. And
8 that's why the commands and the staffs as well lost authority among the
9 fighters.
10 Q. You mentioned earlier the command cadre at the level of the
11 battalion. What was the command cadre at the higher level, the command,
12 the corps, in terms of their origin; were they former non-commissioned
13 officers or reserve officers or were they active JNA officers?
14 A. At the higher levels of command - brigade, corps level, and the
15 Main Staff level - the cadres were trained JNA officers even though there
16 were some brigade commanders who were reserve officers who were never JNA
17 active officers or active officers of the Yugoslav Army.
18 Q. I'm going to put a number of questions to you now about the
19 financial situation of the Army of the Serbian Krajina for the period
20 from early 1993 until the arrival of General Perisic as Chief of Staff.
21 In terms of the planned organisation of the Army of the Serbian Krajina,
22 what was the situation with weapons in that period, in the period of
23 1993? And I am thinking about all types of weapons.
24 A. As far as light infantry weapons are concerned, there was enough
25 of such weaponry. However, a large number of such weapons had already
Page 13096
1 expended their combat resources. That means that a barrel of a rifle is
2 designed to fire a certain number of projectiles. After firing that
3 number of projectiles, the fighter on the front is no longer able to hit
4 his target.
5 As for artillery weapons for support and anti-armour weaponry
6 that are at the level of the battalion and the brigade, there were
7 sufficient such weapons but not enough to provide artillery fire-power to
8 cover the entire front line. And because that line of the front was very
9 long and the weapons when they're placed at the firing positions have a
10 specific area of fire and they can be moved within that area to the left
11 and right but because of their range they need to be close to the
12 front -- so without going into any more detail, let me just say that the
13 number of the artillery batteries for support was insufficient to be able
14 to provide fire support for all the sections of the front.
15 As far as artillery support -- missile and rocket weaponry for
16 support is concerned, there were plenty of these weapons because these
17 weapons can quickly change their positions.
18 As for armoured combat vehicles, it was our estimate that we did
19 have a sufficient number of them, but they also had expended their combat
20 resources and were already in the stage that because they had already
21 fired a specific number of projectiles and the engine had been working
22 for a specific number of hours they needed maintenance. And so because
23 of all these things, as we saw before, I would always ask - and we never
24 had enough of those, and these were actually the transport vehicles --
25 modern warfare had indicated that armoured units, in case of need, would
Page 13097
1 have to be transferred 200, 300 kilometres further along; and for that we
2 needed vehicles in order to be able to move the weaponry. So we were not
3 able to do this because there was a shortage of these vehicles.
4 As for anti-aircraft fire, we lacked artillery and rocket systems
5 in a sufficient number to be able to defend the skies above our
6 territory.
7 As for planes --
8 Q. Are you talking about the PVO system? When you're saying "in
9 order to defend our skies," are you thinking about the PVO systems?
10 A. Yes, these are the PVO systems, anti-aircraft defence systems,
11 yes.
12 As for planes, their number was also reduced to just a few
13 fighter bombers. And planes that would be able to deal with other
14 fighter planes attacking our territory, we didn't actually have any of
15 those planes. This is a brief description of the situation.
16 Q. Thank you. Just one more question: All these items that you
17 said that you had, how did you acquire them? Was that something that you
18 already had? Was it given to you from -- by somebody? Did you procure
19 them?
20 MR. HARMON: Your Honour, I'm going to object. The question that
21 was asked is: How did you acquire them? That is sufficient. Mr. Lukic
22 is now suggesting a number of possibilities, and I think it's up to the
23 witness to answer the first question.
24 JUDGE MOLOTO: Mr. Lukic.
25 MR. LUKIC: [Interpretation] I accept the objection. I'm going to
Page 13098
1 rephrase my question if I did create a problem.
2 Q. So how did the Army of the Serbian Krajina obtain all of these
3 weapons? How did it come to have them?
4 A. In response to this question, I can state only what is true. And
5 the truth is that this was weaponry that had remained after or behind the
6 Yugoslav People's Army.
7 Q. And what was the situation with ammunition in that period, in the
8 course of 1993?
9 A. Ammunition expenditure was enormous, and this was so on all
10 sides. In war we always had a problem with ammunition. The least
11 problem was rifle ammunition, and this is where we could count on the
12 help of the Army of Yugoslavia. But as far as artillery ammunition, tank
13 projectiles, rockets were concerned, that was always a major problem, and
14 we never had enough of such ammunition. In answering this question, I
15 also have to say that the Republic of the Serbian Krajina did not have
16 its own facilities for the production of ammunition.
17 Q. And what was the situation in the beginning? I would like to
18 know. And later? Perhaps I didn't get a precise answer about that
19 regarding ammunition. Was there enough ammunition from the beginning, or
20 was this shortage something that occurred right from the start?
21 A. In the beginning, there was enough ammunition. But during
22 intense combat, during the Croatian offensive around the Maslenica inlet
23 and the Ravni Kotari and the Cetina River
24 ammunition was spent very intensively, and then we were in a situation
25 when we had insufficient amounts of the types of ammunition that I had
Page 13099
1 spoken about before.
2 Q. Did the Serbian army of the Krajina have an established system of
3 communications?
4 A. Yes.
5 Q. Can you please tell us how this was set up, based on what?
6 A. The communications system of the Army of the Serbian Krajina was
7 set up using means of communication, the communication facilities which
8 had remained behind after the Yugoslav People's Army. Operators of those
9 communications devices were members of the Army of the Serbian Krajina,
10 i.e., there was a small number of professional officers from the
11 Yugoslav People's Army and later the Army of Yugoslavia; and the majority
12 of others were from the reserve force who were trained in their capacity
13 as non-commissioned officers, officers, and reserve officers in the JNA
14 to use these communications devices.
15 Q. Can you please tell us, In an army, what should this signals or
16 communications system be like?
17 A. All military documents state that the communications system
18 should be such as to satisfy the requirements of command.
19 Q. And did this system of communications satisfy the requirements of
20 command that you were using on the basis of this infrastructure?
21 A. This system of communications in essence did make command
22 activities possible. However, it was not at the level required. And if
23 you would like me to, I can explain why it wasn't.
24 Q. Yes, please, go ahead.
25 A. Pursuant to the principles of the tactics of the signals or
Page 13100
1 communication service, it has to be such a system as to meet the
2 requirements of command. The first one is that it should be
3 uninterrupted. The system of communications should be such that in the
4 event of enemy action when one source of communication is cut off, one
5 type of communication is interrupted, another kind of communication is
6 activated. And the communications for command and other types of
7 communication continue to work without interruption.
8 Because of a limited number of resources that we had, this
9 principle could not be secured. And later this became evident in combat.
10 Then there has to be a sufficient number of protected channels of
11 communication. We found a small number of encryption communication
12 devices in order to be able to have secure communications only for some
13 basic communications channels that were covering the command. Then the
14 system has to be such that it is protected from radio surveillance, what
15 in these documents is being treated as an intercepted conversation.
16 Because of a small number of communication devices for such type of
17 communication, we were unable to have this facility at the required
18 level.
19 So these would be the main things. I don't need to go into this
20 any further.
21 Q. In the period when you were a commander and later, are you aware
22 if the Army of the Serbian Krajina kept perfecting this system that it
23 had available from the beginning?
24 A. I told you that I -- that we were relying on existing devices and
25 facilities that were previously used by the Yugoslav People's Army in
Page 13101
1 that area. However, our requirements and the deployment of our units and
2 our commands was quite different from that one of the Yugoslav People's
3 Army in that area. The command before the war, the command of the
4 north-western theatre of operations that commanded the bulk of the forces
5 in Croatia
6 course, all those communications lines were then directed at that area
7 and also connected to the General Staff that was located in Belgrade
8 So, now, what did we have to do? These communications facilities
9 with those devices for the operative levels of communication were
10 something that we now took; let's say there was a facility in Petrova
11 Gora and there were many other radio nodes. For example, there were
12 25 devices, 15 directed towards Belgrade
13 would then have to connect those devices to antennas that were facing our
14 corps commands, let's say 95 per cent of them. And then 5 per cent of
15 those devices or even less would still be turned towards the areas
16 controlled by the Army of Republika Srpska and which could then, if
17 needed, be used and directed for communications with Belgrade.
18 Q. Could the system function independently?
19 A. It did function completely independently for our purposes, for
20 communications in our area, that is to say, with the eastern part, the
21 11th Corps in Slavonia
22 go through the territory of Republika Srpska, or rather, the Federal
23 Republic of Yugoslavia
24 have to go through the territory of the Federal Republic of Yugoslavia
25 From Mount Majevica
Page 13102
1 JUDGE MOLOTO: Slow down, slow down. The interpreter is
2 struggling to keep pace.
3 THE WITNESS: [Interpretation] I apologise, Your Honours. I seem
4 to be carried away.
5 JUDGE MOLOTO: That's fine.
6 MR. LUKIC: [Interpretation]
7 Q. Yes, please continue.
8 A. This is a technical detail. I cannot say right now whether our
9 communications channel vis-à-vis the 11th Corps went from Mount Majevica
10 I think it was that way according to the schematic in Eastern Bosnia and
11 Semberija straight towards our 11th Corps. Technically that would have
12 been fine. Or it went via Mount Avala
13 it was the first variant, but I'm not sure.
14 Q. No problem whatsoever. General, after you became commander of
15 the Serb Republic
16 commanders of some other armies?
17 A. Yes, yes. But not with all immediately. I established contact
18 with the Chief of Staff of the Army of Yugoslavia General Panic. I did
19 not see General Mladic - I know that very well - up until the summer or
20 spring, spring or the beginning of the summer of 1993.
21 Q. Can you give us a general picture as to how often you saw
22 General Panic while he was Chief of General Staff?
23 A. It was perhaps once or twice during 1992, then -- actually, up
24 until mid-January 1993 when the Croatian offensive started in
25 Northern Dalmatia
Page 13103
1 After that, while he still held that position, it was at least once or
2 twice a month.
3 Q. Briefly, what was the objective of these meetings with
4 General Panic?
5 A. First of all, I wished to inform the then-Chief of General Staff
6 of the Army of Yugoslavia directly about the elements involved in our
7 assessment of the situation in our area. Secondly, it was my effort to
8 resolve the basic problems I had in the army. The way we understood
9 things, the main problems were of a materiel nature and personnel nature.
10 Q. In simple words, did you ask him for some help?
11 A. Yes, I did ask for help. First of all, I asked for assistance in
12 terms of officers. I saw that the level of training of the reserve
13 commissioned and non-commissioned officers was insufficient if you look
14 at the requirements of modern technology and equipment. Through my
15 officers in the Krajina who were in the General Staff of the Army of
16 Yugoslavia
17 surnames of -- age included, type of professional training of officers
18 and NCOs, and the garrisons where they were serving in the Army of
19 Yugoslavia
20 Q. Just a moment, please. You said that your officers gave it to
21 you. They were originally from Krajina, right, these 6.000 that you
22 referred to? Are they all officers of the Army of Yugoslavia or are they
23 your group?
24 A. No, no, they were natives of the Krajina, but they were officers
25 of the Army of Yugoslavia at the time.
Page 13104
1 Q. That's what I was asking about in more specific terms. So
2 originally they came from where?
3 A. In terms of their place of birth, they came from the Krajina;
4 however, at that moment they were serving in different garrisons in the
5 Army of Yugoslavia
6 Q. Thank you. Can you please go on. What did you do with this
7 computer list once you received it?
8 A. Together with my associates, I compiled a list -- we compiled a
9 list, trying primarily to get people who would change the quality of our
10 units, that is to say, people for command positions; say platoon
11 commanders, company commanders, battalion commanders, even brigade
12 commanders, even corps commanders. That was a very specific list,
13 including specific names. I took that list and went to see
14 General Panic.
15 Q. And what happened at General Panic's in relation to that list?
16 A. General Panic said that if he were to give me these 750 men in
17 total that I had asked for that he might as well disband the Army of
18 Yugoslavia
19 people headed the best-trained units that the Army of Yugoslavia had.
20 However, I was not satisfied with that answer of his.
21 Q. Let us look at a document first. Prosecution Exhibit P1132.
22 MR. LUKIC: [Interpretation] Could we have that on the screen,
23 please.
24 Q. I think that it is in the context of what you're testifying about
25 now. This is a document that you signed; isn't that right, General?
Page 13105
1 A. Yes.
2 Q. The date is the 20th of June, 1993. Who was Chief of
3 General Staff of the Army of Yugoslavia at the time?
4 A. General Panic.
5 Q. Please have a look at the document, and I would just like to ask
6 you for a brief comment in relation to that document.
7 A. I told you that I had asked for 750 officers for command
8 positions, at that. Now, you can see here that it says that what had
9 been agreed upon was to send 300 officers and non-commissioned officers.
10 I don't know -- if necessary, I can explain how that happened that I
11 asked for 750 and that ultimately it was decided it would be 300.
12 Q. Please go ahead.
13 A. After I was dissatisfied with General Panic's answer when he said
14 that he might as well disband the army if he were to give me these
15 750 commissioned and non-commissioned officers, I went to see
16 President Milosevic with the very same request. He organised a meeting
17 then between General Panic and myself in his presence. Now, that looked
18 like bargaining to me. I presented my arguments; General Panic presented
19 his arguments why he could not give me this personnel; I saw that I did
20 not really have much support from Mr. Milosevic; and then the agreement
21 was that it would be 300 commissioned and non-commissioned officers,
22 however, those that were essential to me for the quality of command and
23 control.
24 You see here, on the 20th of June I state on the basis of reports
25 and records in the Main Staff of the Serb Army of the Krajina that
Page 13106
1 instead of the 750 agreed upon, it was -- or rather, 300 officers agreed
2 upon, only 78 had arrived ultimately. I got officers, commissioned and
3 non-commissioned, who belonged to the navy and technical services. We
4 had no navy at the time. I got an expert for computers, and thereby I
5 was in a position to establish a computer centre that would have been at
6 European level. I got a pharmacist and I did not have a pharmaceutical
7 industry at all; we don't have one in the territory of the Serb Krajina.
8 I also got a few commissioned and non-commissioned officers from the air
9 force and its technical service, and I didn't really need them either.
10 Now, that is the reason why I am going back to what I had asked for in
11 the previous period.
12 Q. General, a question that stems from your answer, and I believe
13 that the others in court will be interested in that: Why did you address
14 President Milosevic after that first conversation with Panic?
15 A. Well, because it was generally known that he was the main
16 political authority in Serbia
17 If he could not resolve that, then there was no one who could have
18 resolved it.
19 Q. Very well. Let us now look at another document, and we'll
20 discuss these personnel issues later as well. However, I would like to
21 deal with the general subject now.
22 MR. LUKIC: [Interpretation] P1617, could we have that on our
23 screens now, please.
24 Q. This is a document of the General Staff of the Army of Yugoslavia
25 from February 1993. Again, I'm going to ask you who the Chief of
Page 13107
1 General Staff of the Army of Yugoslavia was at the time, although I
2 believe that the question is superfluous now.
3 A. All right. General Panic.
4 Q. General, what do you know in relation to this document? As we
5 can see, it was sent to you as well, that is to say, to your Main Staff.
6 A. You see that this document is being sent by the operations centre
7 of the General Staff of the Army of Yugoslavia
8 the kind of organisational unit that any army has. It follows the
9 situation on a daily basis, both on the territory of its own state and
10 the territory in the surrounding area and even beyond that. As regards
11 armed forces and their activities that are of interest for that
12 particular army.
13 In this particular case, information is requested about the most
14 important activities in the areas engulfed by war. This is the area that
15 this administration believes it should follow and record on a daily basis
16 what was going on there; they should record it in their own operations
17 centre. You see, that's what they say here themselves: To facilitate
18 timely and more complete information, the assessment of and the
19 monitoring of -- it is the paragraph above item number 1. They say
20 please. In military terms, there is a clear distinction. They are
21 asking us to inform them, not to report to them. They cannot issue an
22 order like that to us. If you look at the activities that followed after
23 this document, that would probably be of interest, then you would see how
24 things developed in relation to this request of theirs. I think that
25 this is a normal, professional attempt to follow the situation in the
Page 13108
1 surrounding area.
2 Q. This information that is being requested specifically from
3 numbers 1 through 4, why do you think that they are important for the
4 General Staff of the Army of Yugoslavia
5 this?
6 A. Because these are elements that are the basic elements of the
7 situation as it is. You can see that here. You can see here the
8 composition, deployment, and strength of the enemy and probably the
9 directions in which their activity could take place and also on our side
10 what it is that we intend to do and whether there is anything else.
11 Basically, they want to have insight into the situation in the war zone.
12 What was selected here was selected for that reason, because these are
13 elements that are essential for assessing the situation.
14 Q. And why was it important for them to have this insight?
15 A. It is important because the operations centre must monitor the
16 situation in the surrounding areas. For the requirements of command of
17 the VJ, there is no such centre that can afford to be such a laid-back
18 institution and fail to follow the situation. There is no such centre in
19 the world.
20 Q. Thank you. Do you remember back in February 1993 and this
21 request, did you provide them with this information that they asked for?
22 A. I believe that for a certain period of time we did provide this
23 information; however, the Main Staff was extremely understaffed and the
24 existing members of the Main Staff worked around the clock. Quite
25 simply, we were unable and we didn't have the capacity to do whatever was
Page 13109
1 not a top priority in the operation of the Main Staff.
2 Q. Thank you. A while ago when you asked about the purpose of your
3 meeting with General Panic, you highlighted two problems: personnel and
4 financial resources. We talked about the personnel. Let's move now to
5 this second topic. Did you ask General Panic for resources to replenish
6 the Serbian Army of Krajina, and what was the situation in that sphere?
7 A. In that period, our main concern was ammunition. And I know that
8 I asked General Panic to try and solve at least some of our problems. I
9 believe that we did receive a certain amount of ammunition from
10 General Panic at that point.
11 Q. Thank you.
12 MR. LUKIC: [Interpretation] Can we please have 65 ter document of
13 the Defence 01006-D.
14 Q. General, can you please look at this document. And it says here
15 that it was drafted by you. Can you please comment on it.
16 A. This is an order of the Main Staff of the Serbian Army of Krajina
17 issued to the command of the 18th and 11th Corps of the Army of the
18 Republic of Serbian Krajina asking them or requesting them to participate
19 in carrying out certain obligations with regard to making a solemn
20 pledge. That was a procedure that had been applied previously by the
21 JNA. However, in the Serbian Army of Krajina we now had a different
22 wording of the pledge to be given by the troops from the one that had
23 been in use by the Yugoslav Army at the time. According to the protocol
24 for such occasions that we ourselves set up at the Main Staff of Krajina,
25 this ceremony was participated by a priest as well, and the wording ended
Page 13110
1 with the phrase "so help me God."
2 Therefore, it was a different phrasing that was used by the VJ,
3 and the protocol itself was different. That is why the corps command
4 were obligated in this respect to make sure that these recruits make this
5 solemn pledge.
6 Q. Just a moment, please. When you say that these recruits were
7 there, for the benefit of the Trial Chamber, it says "Subotica
8 on the occasion of taking a solemn oath in Subotica. We are talking
9 about April 1993 and the personnel of the RSK. So first tell me where
10 Subotica
11 A. Subotica
12 close to the Hungarian border. This is where at the time an armoured
13 brigade of the VJ was deployed. According to an agreement with the
14 General Staff of the VJ, we sent recruits for training to the Subotica
15 garrisons for such military specialties for which we in the Republic of
16 Serbian Krajina did not have conditions to provide training for. As far
17 as I can remember, those were such duties that were carried out by tank
18 crews or by anti-armour launch-rocket weapon operators.
19 Q. Why was it important for you that those recruits take this solemn
20 pledge there according to the rules of the Serbian Army of Krajina?
21 A. Well, Mr. Lukic, I find this question a little bit odd. Whose
22 else solemn pledge would they take other than the one that was in force
23 in the Serbian Army of the Krajina?
24 Q. I am satisfied with your answer, although you're not happy with
25 my question.
Page 13111
1 MR. LUKIC: [Interpretation] Your Honours, can we have a number
2 for this document.
3 JUDGE MOLOTO: The document is admitted into evidence. May it
4 please be given an exhibit number.
5 THE REGISTRAR: Your Honours, this document shall be assigned
6 Exhibit D438. Thank you.
7 JUDGE MOLOTO: Thank you.
8 Yes, Mr. Lukic.
9 MR. LUKIC: [Interpretation] On this same subject, can we have a
10 Prosecution exhibit, P940, please.
11 Q. This is now February 1994. You are still the commander of the
12 Serbian Army of Krajina. Can you briefly comment on this document,
13 General.
14 A. This is again to do with making a solemn oath by the recruits in
15 the Army of Yugoslavia
16 and the office of the Chief of the General Staff of VJ that for this
17 ceremony of giving a solemn pledge we were going to drive these recruits
18 and soldiers to the territory of the Serbian Republic
19 village of Vojnic in Kordun and that that would be the place where they
20 would take their solemn oath. Therefore, there was no question raised
21 again about whether co-operation was going to be good, whether somebody
22 else should be helping us with this. We took full responsibility for
23 this ceremony of giving a solemn pledge, of course with allowing for a
24 possibility, as the tradition goes, for this ceremony to be attended by
25 family members and friends as well as the tradition in the former
Page 13112
1 Yugoslav People's Army. Because this kind of ceremony had always been a
2 solemn one and always attended by family members.
3 MR. LUKIC: [Interpretation] Can I have a moment, please.
4 [Defence counsel confer]
5 MR. LUKIC: [Interpretation] I have an intervention in the
6 transcript. Probably there is some misunderstanding.
7 Q. It reads here that you stated that this again refers to giving a
8 solemn oath by the recruits in the Yugoslav Army. I suppose that's not
9 what you said, so can you please be more specific. Whose recruits are we
10 talking about here?
11 A. If necessary, we can read the document. But it is obvious that
12 this refers to the recruits of the Serbian Army of Krajina who at this
13 juncture when this order was being written --
14 Q. It's clear now. That was all we wanted to clarify. General, one
15 question relating to this topic and the stay of these recruits from the
16 Republic of Serbian Krajina in the Army of Yugoslavia and their training
17 there. What kind of information did you receive as a feedback regarding
18 their relationship with members of the VJ [sic] and officers of the VJ at
19 the time?
20 A. The information we received indicated that there were problems in
21 that area. There were conflicts between the trainees and the VJ officers
22 who were instructors. To put it simply, they did not want to recognise
23 them as their own officers. They did not wear the same insignia on their
24 caps. They did not believe to be, themselves, part of one and the same
25 army, and therefore they could not be commanded by members of another
Page 13113
1 army.
2 Q. Thank you.
3 JUDGE MOLOTO: Sorry, Mr. Lukic. I guess you might need an
4 intervention again here at page 44, line 23: "... relationship with
5 members of the VJ and ..." -- "... members of the SVK and officers of
6 the VJ ..." I think is what you wanted to say. Can you see it?
7 MR. LUKIC: [Interpretation] Well, I expanded my question and I
8 put my question --
9 JUDGE MOLOTO: That's the answer -- look at line 23. It says
10 "members of the VJ and officers of the VJ at the time." Is it not
11 supposed to be members of the SVK and officers of the VJ?
12 MR. LUKIC: [Interpretation] Yes, yes, that's right. You're
13 absolutely right. So on page 44, line 23, I asked about the relationship
14 between the recruits from the Serbian Army of Krajina who were undergoing
15 training there, and I thank Your Honour for this.
16 JUDGE MOLOTO: You're welcome.
17 MR. LUKIC: [Interpretation]
18 Q. General, let's move to another topic now. I'm interested now in
19 your contacts with General Perisic starting from August 1993. We have
20 information that General Perisic was appointed to the position of the
21 Chief of General Staff of the VJ. Can you remember when you first met
22 him in your capacity, and can you recall anything about this meeting?
23 A. Of course I cannot give you the exact date, but I do know that it
24 might have taken place some ten days after he had been appointed to that
25 post. I wanted to meet Mr. Perisic because from our previous meetings I
Page 13114
1 got the impression that he was a smart man and a capable officer and my
2 expectations were that he would demonstrate at least some professional
3 understanding of the situation in which the army of which I was the
4 commander found itself.
5 During this first meeting that we had, I informed him about the
6 basic elements pertaining to the situation. This was done more or less
7 on the principle of the document that was shown here in which the
8 operations centre of the General Staff asked information from us about
9 four subjects or items. So those were basically these elements of the
10 situation relating to the enemy and what was known about the situation
11 relating to our forces about what we thought we could and should do in
12 the forthcoming period and about the influence of the external factors
13 involved in the situation, starting from UNPROFOR to those at the
14 political and diplomatic levels.
15 Q. And did you speak about the topics that you discussed with
16 General Panic -- if not then, when was the first time that you discussed
17 those topics? This is your cadre problem and the problem of the
18 financial situation with the army.
19 A. We talked about that as well, of course, because that was part of
20 that item 2 that was on the document, own forces. If you want, I can
21 tell you what I told General Perisic about the situation of our own
22 forces, the forces of the Army of the Serbian Krajina. I began by
23 describing its strategic position, operations position at certain sectors
24 of the front, combat morale, and the situation with materiel and
25 equipment, logistics, including also the medical aspect of it. I did
Page 13115
1 this to the extent that I believed necessary at the level of the Chief of
2 the General Staff, which was the position of General Perisic at the time.
3 Q. And on that occasion or later, did you ask him for assistance?
4 I'm primarily thinking about materiel, equipment, and so on. What was
5 his position about that?
6 A. Of course. Just as was the case with General Panic before him, I
7 asked for material assistance from him, personnel, and also in certain
8 kinds of materiel and equipment. I felt that General Perisic understood
9 the situation in terms of these being realistic requirements.
10 Unfortunately, however, I did not encounter - and I can begin like that
11 and I can end in the same way as well - his actual ability to resolve
12 these problems, either the materiel and equipment or the personnel
13 matters.
14 Q. Do you remember what he specifically told you about the request
15 for funds or material assistance?
16 A. Since we knew each other from before, at one point he opened his
17 cash box, his safe, that was in his office, and it was full of -- it was
18 full of secrets, just like the ones that we're looking at now. And he
19 said, Here, take a look for yourself. And the things that
20 General Perisic showed me then, it was enough to make a grown man cry - I
21 mean we could put it like that in Serbian. That Army of Yugoslavia and
22 in relation to the things that I needed the most, ammunition was in a
23 very, very sorry state indeed.
24 If you have a tank, for example, and the -- a tank -- each tank
25 has to have 50 projectiles, 50 shells. This is part of the combat kit.
Page 13116
1 It's a requirement. And then you have three times as much in a brigade
2 and then seven times as much up to the level of the Supreme Command.
3 This means that a regular army would require 4- or 500 projectiles per
4 tank. And what the Army of Yugoslavia had at the time was just enough to
5 supply the requirements of -- at the level of a unit. This was from 100
6 to 150 projectiles [as interpreted].
7 If we're talking about rockets; for example, each launcher should
8 have six rockets. I remember that the best for anti-armour rockets. I
9 can still see that number now. A combat kit is six rockets. At that
10 point in time, he had 0.3 of that combat kit. That means less than two
11 rockets per projectile.
12 THE INTERPRETER: Interpreter's correction: Before, it was
13 supposed to be "from 150 to 180 projectiles."
14 MR. LUKIC: [Interpretation]
15 Q. All right. What you have just said now -- I apologise to the
16 interpreters.
17 What was your conclusion, General, from this information that you
18 were able to find out, read, at that time?
19 A. It was possible to draw a number of conclusions; the main one
20 being that the Army of Yugoslavia really without endangering the basic
21 purpose for its existence could not provide us with ammunition.
22 Q. Just one more question and then we'll go on a break. We don't
23 have to discuss this very first meeting, this specific meeting. But on
24 the basis of your meetings with General Perisic, what was the conclusion
25 you drew -- actually, we heard yesterday that the Yugoslav People's Army
Page 13117
1 took an active part in the combat; you said that yesterday. What was his
2 position in relation to any kind of active participation of the
3 Yugoslav Army in the war?
4 A. We absolutely did not discuss that during that conversation.
5 Q. What about subsequent conversation; did you get the impression
6 that he had some sort of position in relation to that matter?
7 A. From what he said, you could draw the conclusion -- I mean, you
8 could draw the conclusion - I don't think he could have said it openly at
9 the time - the Army of Yugoslavia did not have the basic prerequisites
10 for waging war. And this did not apply only to the materiel situation
11 either.
12 Q. Thank you.
13 MR. LUKIC: [Interpretation] Your Honours, I suggest that we go on
14 our second break for today.
15 JUDGE MOLOTO: We will take a break and come back at half past
16 12.00. Court adjourned.
17 --- Recess taken at 12.00 p.m.
18 --- On resuming at 12.31 p.m.
19 JUDGE MOLOTO: Yes, Mr. Lukic.
20 MR. LUKIC: [Interpretation]
21 Q. General, can you tell us whether in the autumn of 1993 there were
22 some new incidents in the territory of the Republic of the Serb Krajina;
23 and if so, where and what happened?
24 A. Yes. In the beginning of September 1993, the Croatian forces
25 attacked a zone in Lika, which was later known as the Medak pocket.
Page 13118
1 Q. Let's be practical. While you continue speaking, let us have
2 D164 on the screen, that's a map, so that we have it there while you're
3 speaking.
4 A. That is an area that is between the very high mountain of Velebit
5 and the town of Gospic
6 mean the part of the area that was under our control, was in the shape of
7 a triangle vis-à-vis the area that was held by Croatian forces, and it
8 was below a part of Mount Velebit
9 Visocica is the elevation there where, according to our information,
10 there was the staff or headquarters of the special Croatian police. If
11 necessary, I can indicate that.
12 Q. Yes, please.
13 MR. LUKIC: [Interpretation] Could the General actually mark that,
14 could he mark that area on the map.
15 THE WITNESS: [Marks]
16 MR. LUKIC: [Interpretation]
17 Q. Could you please go on.
18 A. The Croatian forces started grouping their forces for this attack
19 a few days in advance. There was a strong unit of the Croatian special
20 police that our intelligence people discovered as they were moving from
21 their headquarters in Zagreb
22 towards the area of Lika. However, we did not know specifically which
23 part of the front they were heading to.
24 Also, they discovered some unusual activity on their part on
25 Mount Velebit
Page 13119
1 MR. HARMON: Excuse me, Your Honour.
2 JUDGE MOLOTO: Yes, Mr. Harmon.
3 MR. HARMON: The question that was asked is essentially to tell
4 us what happened, and we are going into extraordinary detail that I think
5 is unnecessary for purposes of the question that was asked by Mr. Lukic.
6 So I would ask the Court to instruct the witness to answer the question
7 that he was asked.
8 JUDGE MOLOTO: Mr. Lukic.
9 MR. LUKIC: [Interpretation] I will accept the objection,
10 Your Honour.
11 Q. Because, General, we have a great many topics that we have to
12 discuss that are quite important for this trial, I believe that you would
13 like to tell us a lot about this action and you could indeed, however, I
14 would like you to focus and to be as specific as possible. In your view,
15 what was the objective of this operation? Please give us the briefest
16 possible answer, and let's move on to other topics.
17 A. It's quite clear. It's unequivocal. And I can give further
18 explanation if necessary, but I don't really think it's needed. The only
19 objective of this Croatian operation was to demonstrate to us, Serbs, the
20 method of scorched earth.
21 Q. Are you trying -- could you please tell us what "scorched earth"
22 means?
23 A. On the basis of this exemplary example, as it were, this
24 exemplary case, the scorched earth method means kill all living
25 creatures, persons and animals included, in a given area and destroy
Page 13120
1 everything that was created by human hands.
2 Q. Who did you hear this term from, scorched earth?
3 A. I heard this term several times earlier on in different -- on
4 different occasions, but in this particular case I heard this term from
5 General Jean Cot, UNPROFOR commander. He's the one who used the term.
6 Q. On which occasion did he use that term?
7 A. When he first met me, after he personally toured the area.
8 General Cot was an officer who wanted to see this personally and indeed
9 he did so.
10 Q. What was it that he conveyed to you then, which information did
11 he come across on that occasion?
12 A. Let me try to be as brief as possible again. General Cot stated
13 in the briefest possible terms that he was totally astounded by what he
14 had seen.
15 Q. In view of the position that you had then as the commander of the
16 Army of the Serb Krajina, did you see General Cot again, and did you see
17 any representatives of the international community in relation to this
18 incident?
19 A. Yes. I saw General Cot several times in relation to this
20 incident. As far as I can remember, General Bo Pellnas was always with
21 him.
22 MR. LUKIC: [Interpretation] I see now that what the general drew
23 simply disappeared. Would that be right? Oh no.
24 Q. General, I'm sorry, I made a mistake. This is a technical
25 problem. Could you please draw the area of the Medak pocket again on
Page 13121
1 this map.
2 A. [Marks]
3 Q. In your view, General, is this territory strategically important
4 for the Croatian army, the Croatian armed forces?
5 A. Absolutely not. As a matter of fact, it's not even important
6 from the point of view of the explanation that the Croats, the official
7 Croatian authorities, gave, namely, that that was their response to the
8 shelling of Gospic. If you look at this part of the front line that is
9 jutting out, as it were, there was nothing of the kind. They could see
10 that from the dominant elevations that they held.
11 MR. LUKIC: [Interpretation] Can we please admit this into
12 evidence now, Your Honours, before we actually lose this image.
13 JUDGE MOLOTO: It's admitted into evidence. May it please be
14 given an exhibit number.
15 THE REGISTRAR: Your Honours, this document shall be assigned
16 Exhibit D439. Thank you.
17 JUDGE MOLOTO: Thank you.
18 MR. LUKIC: [Interpretation]
19 Q. Was this attack halted? Did it stop in any way? What happened
20 after that aggression?
21 A. The attack of the Croatian forces was stopped at the line of the
22 village of Medak and the road that goes through the village of Medak
23 This is a continuation of this straight line from Gospic and then further
24 down south. That is to say that they only entered this area that is
25 jutting out; however, operations continued nevertheless. General Cot
Page 13122
1 and, as far as I know, the international representatives in Zagreb
2 to reach some kind of agreement in order to end the hostilities. I was
3 told that the Croatian side is refusing to discuss anything with anyone
4 from the international community with regard to this case.
5 Q. Who said that to you?
6 A. That's what I was told by General Cot and General Pellnas.
7 Q. What happened then?
8 A. At the same time, as for those who were withdrawing from the
9 area, I heard the same thing from them that I heard from General Pellnas,
10 namely, that the civilian population was being massacred and that all
11 living creatures were being destroyed in the said area. Because of that,
12 I decided to threaten the Croatian side in order to force them to stop
13 doing such terrible things.
14 For a few days, all the media that were under our control stated
15 publicly and persistently repeated the list of military objectives in the
16 territory of Croatia
17 be targeted by the Serb side unless what is happening in the area that
18 they had taken is brought to a halt. At the same time, the civilian
19 population was asked to move away from these military objectives. These
20 military objectives or targets were exclusively of a military nature,
21 namely, the basis of the special Croatian police that we knew was
22 participating in this action, the bases and the command posts of the
23 Croatian army.
24 After there was no change in the situation, as a matter of fact,
25 their activity continued unabated, we did target some military facilities
Page 13123
1 of this kind. The first facility that we targeted was the base of the
2 special police at the former airfield with a grass runway, Lucko it was
3 called. It is to the west of Zagreb
4 Jastrebarsko which is between Zagreb
5 the barracks of the communications unit of the Croatian Main Staff in the
6 Samo barracks.
7 Q. To the best of your knowledge, were there any civilian casualties
8 during these attacks?
9 A. I did not have any reports stating that there were civilian
10 casualties sustained during these attacks. This base of the special
11 police in Lucko that is outside built-up areas, it was not hit. Also,
12 the barracks in Jastrebarsko were not hit, and the town of Jastrebarsko
13 wasn't hit either. This Luna rocket fell closer to the highway, fell
14 onto an empty space there. That is what I know about these targets of
15 ours and civilian casualties.
16 Q. I want the transcript to reflect this: What were the rockets
17 that you used for carrying out these operations?
18 A. When the firing positions were being changed at the time, we
19 temporarily had a battery of Luna M -- or, rather, R-65 missiles.
20 According to the NATO marking, it is --
21 THE INTERPRETER: The interpreter did not hear the word.
22 THE WITNESS: [Interpretation] -- number 7.
23 JUDGE MOLOTO: The interpreter didn't hear the word.
24 THE WITNESS: [Interpretation] FROG-7. Frog, as in the animal,
25 frog.
Page 13124
1 MR. LUKIC: [Interpretation]
2 Q. General, and what was the reaction, if there was any, of the
3 UNPROFOR to this action of yours?
4 A. Shortly afterwards, General Cot reported that the Croats had
5 agreed, the Croatian authorities, President Tudjman primarily and the
6 chief of their Main Staff General Bobetko, agreed to speak with them.
7 General Pellnas told me that he was glad - I repeat - that he was glad
8 when he heard that our FROG was flying towards Belgrade -- towards
9 Zagreb
10 THE INTERPRETER: Correction: Towards Zagreb.
11 THE WITNESS: [Interpretation] Because up until then, they were
12 completely ignored in their requests to be received by both the Croatian
13 civilian and military authorities.
14 MR. LUKIC: [Interpretation]
15 Q. Thank you. In relation to this incident, what was the impression
16 this incident made on you - I asked you this about Maslenica earlier - in
17 terms of further possible attacks against the Krajina and the position of
18 the Croatian authorities on that?
19 A. It was our assessment that the Croatian side would continue with
20 merciless armed actions in order to establish complete control over the
21 territory and areas under the protection of the UN, namely, the territory
22 of Republika Srpska. The second conclusion was that the population in
23 the territory under our control was of no interest to them; rather, they
24 were interested in an empty territory only.
25 Q. Thank you, General. We're going to move to a different topic
Page 13125
1 now.
2 In preparations for this testimony, I was able to show you some
3 documents that we referred to as the notebooks or notes of General Mladic
4 in the courtroom. My question was: Did I show you any documents like
5 that?
6 A. Yes, that is correct.
7 MR. LUKIC: [Interpretation] I think in view of the decision of
8 the Trial Chamber we can remain in public session, and I would like to go
9 through some of these documents from batch 410 with the witness.
10 Q. General, these documents, did they refresh your recollection
11 about some event and meetings that you had?
12 A. Yes, that is correct.
13 Q. The first document that I would like to look at with the General
14 is a document --
15 MR. LUKIC: [Interpretation] Now, Your Honour, we are going to
16 follow this procedure that we had earlier, and that is primarily I'm
17 going to ask the -- your agreement to introduce into our 65 ter list of
18 exhibits of the Defence this document, that is, a document that I'm
19 marking with the mark 65 ter 03382D, which in the B/C/S starts from
20 0668-2627 - that is the ERN page - until 2637 -- actually, in the e-court
21 it goes up to 2640.
22 This is notes from a meeting with President Milosevic of the 24th
23 of September, 1993. So let me first hear the position of the Prosecution
24 before we are able to use the document.
25 MR. HARMON: I have no objection to this document being added to
Page 13126
1 the Defence 65 ter list, Your Honour.
2 JUDGE MOLOTO: Thank you.
3 Yes, Mr. Lukic, it's so added.
4 MR. LUKIC: [Interpretation] Before I start going through the
5 document with the witness - and there will be a number of them - I just
6 wanted to inform the Trial Chamber that what you see before you is an
7 official translation we received from the translation service. However,
8 when we were going through the document of this official translation, we
9 encountered certain translations which we find are inadequate. Some of
10 them are not so important, but there are a few that we do consider
11 important. I've informed Mr. Harmon about it, and I marked the parts
12 which we believe are in dispute, and his suggestion was to ask the
13 translation service to retranslate this document and then we can tender
14 this new translation into evidence.
15 So when I'm going through the documents with the witness, I'm
16 going to ask the witness to read certain parts or I can read them and the
17 witness can confirm that that is what is said in the translation. We
18 have also provided copies to the interpreters in the booths. And we have
19 marked those parts that we believe are inaccurate, and we've asked them
20 to pay special attention to those parts.
21 JUDGE MOLOTO: Mr. Harmon.
22 MR. HARMON: Yes. Mr. Lukic and his team provided me with copies
23 of these documents and the portions that they assert need to be
24 retranslated. I've looked at them with my language assistants. I agree
25 with some of the suggestions; I don't agree with other suggestions. When
Page 13127
1 matters are read into the record, I would like to make it perfectly clear
2 that I -- on disputed areas, I'm not accepting the - with all deference
3 to the language booth - the interpreter's reading as the correct and
4 definitive translation. I think if these are submitted to CLSS, these
5 portions that are in dispute, that we should be guided by CLSS's
6 translation of these and not the oral reading and the quick
7 interpretation of what's on these documents.
8 So insofar as the procedure that Mr. Lukic has identified, if he
9 will identify those portions to where we have a dispute, and then we can
10 have CLSS regulate that matter for us as the official document that would
11 be guiding the Court and the parties in their work.
12 JUDGE MOLOTO: Is that acceptable to you, Mr. Lukic?
13 MR. LUKIC: [Interpretation] Yes, yes. That is what I said. That
14 can be a final version. We can send it to the translation section, and
15 then their version would be the final one.
16 JUDGE MOLOTO: Sure. Okay. You may proceed then. We'll do
17 that.
18 Q. General, we see in front of us the first page of several that
19 will follow, and it says:
20 "Meeting with President Milosevic" of the
21 24th of September, 1993.
22 A. Yes, that is correct, the 24th of September, 1993.
23 Q. Yes, that is correct, the 24th of September, 1993. We're going
24 to go page by page. But what we see from the document is that the
25 participants in this conversation are General Perisic, General Mladic --
Page 13128
1 actually, this is General Mladic's notebook so I'm drawing the conclusion
2 on the basis of that. And you are also mentioned. So I'm just asking
3 you if you remember that this meeting was held at that time in Belgrade
4 A. Yes, I remember.
5 Q. And do you perhaps recall whether, other than those persons
6 mentioned as being present here, anyone else was present also, or were
7 they only the persons that are actually referred to that attended this
8 meeting?
9 A. I think that the meeting was only between the persons that you
10 mentioned.
11 Q. We're now going to go section by section, and I will ask you to
12 comment based on your recollection of that conversation whether what is
13 written down here adequately reflects what that person, that participant,
14 said in the conversation. General Perisic is mentioned first. I am not
15 going to read the first two sentences. Are you able to read, or should I
16 read?
17 A. Yes.
18 Q. Does this reflect General Perisic's words adequately? According
19 to your recollection, is that what he said at the time?
20 A. According to my best recollection, it does absolutely reflect
21 what was said because that was what his assessments -- that's what his
22 assessments were and his view about the situation. I especially want to
23 mention the third point; they are very strong, logistical support,
24 logistics.
25 Q. Yes, that is where my first remark was.
Page 13129
1 MR. LUKIC: [Interpretation] As you can see, Your Honours, in the
2 English version and the B/C/S version, this is my objection to the
3 translation service: They're placing something in parenthesis,
4 interpreting what is being written there.
5 Q. General, please, what it says here is:
6 "They are very strong PO
7 What does that mean? What do you think that means?
8 A. According to the standard abbreviations used by General Mladic,
9 and they were commonly used in the schools that we completed, this can
10 only mean the term that we used and that is "logistics support."
11 "Pozadinsko obezbedjenje." This is a term that is practically identical
12 to the term "logistics." It's not entirely the same, "pozadinsko
13 obezbedjenje," "rear support," but more or less those two terms mean the
14 same thing.
15 Q. Very well. When he says "they," who did he refer to,
16 General Perisic?
17 A. He meant Croatia
18 Q. And in relation to the incident that we mentioned before, when we
19 look at the date here, can you please tell us the date of the Medak
20 incident in relation to this meeting here?
21 A. The incident began on the 9th of September, and this is the
22 period immediately after General Stipetic and I signed some kind of an
23 agreement on the cessation of hostilities, and the Canadian Battalion
24 from UNPROFOR pushed the Croatians out of that area.
25 Q. Now, General, I'm going to read the next paragraph, and you can
Page 13130
1 just confirm to me whether I've read it adequately because of the
2 translation.
3 "Help in manpower (senior officers) everything is on a voluntary
4 basis ... to go for a more radical position, that everyone who was born
5 there should go."
6 MR. LUKIC: [Interpretation] And I'm particularly reading the
7 following sentence because of the translation, Your Honours.
8 "To persuade them as much as we can to go there."
9 For example, if I can comment now. I'm quite satisfied with the
10 translation from the booth, but in any case --
11 JUDGE MOLOTO: Mr. Harmon --
12 MR. LUKIC: [Interpretation] No, no. No. I agree. I agree.
13 JUDGE MOLOTO: Mr. Harmon.
14 MR. HARMON: Mr. Lukic may be satisfied with the translation from
15 the booth. This is a portion that we have an issue with, and this is the
16 area where I think we should be guided by the official CLSS translation
17 and not the translation from the booth.
18 JUDGE MOLOTO: If you say so, Mr. --
19 MR. LUKIC: [Interpretation] Absolutely. I just commented. I
20 just wanted to draw your attention to what it was that we saw as the
21 discrepancy between the official translation and what we were pointing
22 to. We don't want to go into details or we don't want to burden the
23 translation service in any event.
24 JUDGE MOLOTO: Thank you. We will send --
25 MR. LUKIC: [Interpretation]
Page 13131
1 Q. General, did I read this correctly, what I have just read to you?
2 And I'm going to ask you, Can you please confirm?
3 A. Yes.
4 Q. Can you give us your comment on the position of General Perisic
5 in relation to the departure of officers and which officers. What does
6 this exactly refer to?
7 JUDGE MOLOTO: Just a second, Mr. Lukic. Doesn't the document
8 speak for itself on that point, provided that we get a correct
9 translation from CLSS?
10 MR. LUKIC: [Interpretation] I didn't understand you very well
11 now.
12 JUDGE MOLOTO: Well, I have a problem with your question. You're
13 saying:
14 "Can you give us your comment on the position of General Perisic
15 in relation to the departure of officers and which officers. What does
16 this exactly refer to."
17 Now, there is a minute here written by General Mladic about which
18 there is a dispute between the parties on the interpretation.
19 Okay? We are going to get CLSS to re-look at that translation and tell
20 us whether they stand by what's written here or whether they are prepared
21 to change. And once we've got that, that will be the position of
22 General Perisic, which the witness's comment on that position doesn't --
23 MR. LUKIC: [Interpretation] Well, now I have to give you my
24 comment. When we get this translation, that will be a position being
25 recorded in this document as being the position of General Perisic. So
Page 13132
1 what I'm going to ask Mr. Novakovic is, Does he recollect that, or What
2 does he recollect was General Perisic's position on the basis of this
3 document on this topic.
4 JUDGE MOLOTO: You're not asking for a comment; you're asking for
5 his recollection?
6 MR. LUKIC: [No interpretation]
7 JUDGE MOLOTO: Okay. The first question was "comment."
8 MR. LUKIC: [Interpretation]
9 Q. General, we've understood each other. Yes, you can go ahead and
10 answer the question.
11 A. This entry --
12 JUDGE MOLOTO: Your recollection, General.
13 THE WITNESS: [Interpretation] -- which --
14 JUDGE MOLOTO: [Previous translation continues] ... no, your
15 recollection, Mr. Novakovic, sorry.
16 Forget about the entry. What is your recollection of General Perisic's
17 position on the departure of officers?
18 THE WITNESS: [Interpretation] Your Honour, all I wanted to say is
19 that this reminds me of the position --
20 JUDGE MOLOTO: Now that you remember the position -- [Previous
21 translation continues] ...
22 THE WITNESS: [Interpretation] -- because if I were honest, I
23 really couldn't say whether that was the position or not.
24 JUDGE MOLOTO: I understand perfectly. Now that you remember,
25 tell us, What is your recollection of that position?
Page 13133
1 THE WITNESS: [Interpretation] The gist of the position of
2 General Perisic on this matter on sending officers and non-commissioned
3 officers who were born in our area who were at that time in the
4 Federal Republic of Yugoslavia was that he didn't have a legal basis to
5 send them there, that the dispatch up until that moment was on the
6 principle of voluntarity, voluntariness, and that it did not depend on
7 him, basically whether those people would go there or not. And that was
8 the practice as well at the time, Your Honour.
9 JUDGE MOLOTO: Thank you so much.
10 Yes, Mr. Lukic.
11 MR. LUKIC: [Interpretation]
12 Q. Let us move on to the next page. We're still dealing with the
13 words of General Perisic. Now I would like to comment on the second and
14 third sentence.
15 "Issuing OB equipment (weapons, ammunition, fuel) ..."
16 What does the abbreviation "OB" mean? Do you recall what it was
17 that Perisic was saying in respect of this entry?
18 MR. HARMON: Objection, Your Honour. There's two questions. The
19 first is: What does the abbreviation OB mean? That's the first
20 question. The second question is: Do you recall what he was saying in
21 respect of this entry. So if we could have the answer to the first
22 question, we could proceed to the second question. But I object because
23 the question is compound.
24 JUDGE MOLOTO: Mr. Lukic.
25 MR. LUKIC: [Interpretation] I don't think that that question was
Page 13134
1 that complex that the witness cannot be in a position to answer it. In
2 order to speed things up --
3 Q. Okay, General, what do you believe "OB" means?
4 A. For me - and General Perisic completed the same school that I
5 did - OB means "organ bezbednosti," "security organ." However, what I
6 find illogical is how come it is followed by "weapons, ammunition, fuel."
7 So at this point in time I cannot confirm anything. I cannot remember
8 now what this exactly pertained to.
9 Q. Thank you. The next entry that says:
10 "Regulating the status of officers (from retirement issues to
11 purchasing uniforms) ..."
12 Does this jog your memory in any way in terms of the words of
13 General Perisic at the time?
14 A. Yes. This is an answer to our constant requests to resolve the
15 questions of the status of professional officers who are still being
16 registered as serving in the Army of Yugoslavia but are actually in the
17 Army of Republika Srpska and the Serb Army of the Krajina.
18 Status-related questions are not resolved for them as they are
19 for those professional military personnel who are serving in the
20 garrisons of the Army of Yugoslavia, starting with the matter of not
21 having their years of service recorded properly, therefore they do not
22 have the necessary number of years of service as the administration
23 personnel put it but they actually do have a sufficient number of
24 service. Then also their medical insurance for them and for their family
25 members so that they can receive medical treatment in military medical
Page 13135
1 institutions. Then the basic problem, the very ordinary problem of
2 purchasing uniforms. I was glad at that point in time to see
3 General Perisic stating these problems for starters.
4 Q. What was your problem in terms of medical services being provided
5 and uniforms being purchased? I'm referring to the Army of Yugoslavia
6 now.
7 JUDGE MOLOTO: Sorry, this witness was in the Army of the Serbian
8 Krajina. Would he know the problems within the VJ?
9 MR. LUKIC: [Interpretation] I am asking him about his problem as
10 an officer of the SVK. How did he get medical treatment --
11 JUDGE MOLOTO: Look at --
12 MR. LUKIC: [Interpretation] I mean --
13 JUDGE MOLOTO: -- look at line 18 there, page 66:
14 "I'm referring to the Army of Yugoslavia now."
15 And that is preceded by a question --
16 MR. LUKIC: [Overlapping speakers] ...
17 JUDGE MOLOTO: -- which was:
18 "What was your problem in terms of medical services being
19 provided and uniforms being purchased?"
20 Now, his problem is a problem of the SVK, not of the Army of
21 Yugoslavia.
22 MR. LUKIC: [Interpretation] I do apologise. I'm going to
23 rephrase the question now.
24 Q. General, as a member of the SVK, could you purchase uniforms from
25 the depots of the Army of Yugoslavia just like officers of the Army of
Page 13136
1 Yugoslavia could?
2 A. No.
3 Q. What was the problem?
4 A. The problem was because in my military ID there was not a
5 military post code number or a military unit number from the Army of
6 Yugoslavia. If I have that kind of number in my military ID, I could
7 have purchased a uniform.
8 Q. What was the problem with the medical insurance cards that you
9 had for using medical services of the Army of Yugoslavia?
10 A. A military medical insurance card of a military medical insuree
11 of -- that is to say, of a military officer of the Army of Yugoslavia and
12 family members of such military personnel who had the same rights on the
13 basis of that person's employment with the Army of Yugoslavia, namely, to
14 be treated in military medical hospitals, that depended at the time and
15 depends to this day in Serbia on the following: Whether the medical
16 insurance card has been stamped, whether it has been verified, by way of
17 a stamp, that the military insuree is serving in a specific military post
18 in the Army of Yugoslavia, that is on the list of the military post of
19 the Army of Yugoslavia.
20 Q. Now the next entry; does that jog your memory? What were these
21 words that were uttered by General Perisic? It says:
22 "Material financial support."
23 A. Yes. This is a continuation -- I mean this notebook is not
24 stenographic notes. I remember this part. It's not that I don't
25 remember it. General Perisic was talking about insufficient material
Page 13137
1 financial support. First of all, the Army of Yugoslavia didn't have
2 that, and he said that that was the main reason why he cannot meet our
3 requests for material resources.
4 Q. Now an entry that pertains to you, so I'll just ask you what this
5 means, what it says here, "min snage vojin." Do you remember what this
6 means? Could you tell us briefly what the term "vojin" is?
7 A. Yes, I have an excellent recollection of that because that was a
8 big problem for me. This correctly reflects what I had asked for. It
9 means minimal forces for air surveillance, reporting, and guidance.
10 Minimum forces for air surveillance, reporting, and guidance. That is a
11 system that controls the situation in the air-space. That exists in
12 every army of the world, that is to say, above one's territory and on the
13 approaches to your territory by way of radar, visual equipment, and other
14 equipment; you monitor and observe everything that is in the air-space.
15 You identify enemy targets. And also what it says here at the end,
16 "guiding," as for your own anti-aircraft equipment, you guide it so as to
17 destroy enemy targets.
18 Also, a clear distinction is being made here in terms of
19 identifications, what is an enemy target, and what are other aircraft in
20 the air-space.
21 Q. General, at the time, did the SVK have a developed "vojin"
22 system?
23 A. No, no. At the time, we did not have a developed "vojin" system.
24 Q. Up until the end of the war, did you manage to develop a "vojin"
25 system?
Page 13138
1 A. No, no. We never managed to develop a "vojin" system for our
2 territory.
3 Q. Thank you. Let us move on. I don't have to read. Could you
4 just give me your comment about the next entries. What is the meaning of
5 what you were saying then?
6 A. The next entry has to do with air-space control above our
7 territory. Because if your observation system detects an enemy target in
8 the air-space and if you do not have an air force to down such aircraft,
9 well then you don't really need observation equipment in the first place.
10 Q. Let us move on a bit faster. We had a bit of a problem here.
11 Can you explain to us this so that the translators can translate it
12 there. It says here at the end:
13 "Six heavy-duty haulage vehicles to transport T."
14 Do you remember what "T" meant at the time? We have a problem
15 with the translation there. Could you just tell us that.
16 A. During the course of my remarks today, I mentioned to this -- I
17 mentioned this problem of towing vehicles. These are vehicles that have
18 a platform for loading tanks. So "T" means "tanks" in this context.
19 Q. Thank you. The translation service correctly interpreted this in
20 this case.
21 MR. LUKIC: [Interpretation] So could we please see the next page.
22 Q. Again, the entry says that this is what you had said. So could
23 you give us your comments, briefly. To the best of your recollection,
24 what was it that you were talking about at that point? And this is what
25 it says: "Joint 'vojin.'"
Page 13139
1 A. There is one before that too.
2 Q. Yes, please. Do explain what this previous entry means. What is
3 "BROM"? And what does this mean: "For operations ZZ."
4 A. The first entry -- well, I'm saying this not because it is
5 written here. I'm saying it in that context because I remember this
6 perfectly. The Army of Yugoslavia had quite a few batteries. "BROM"
7 means "baterija raketa, obala, more," "battery of rockets, coast, sea."
8 That's about 80 kilometres away. And they were taken out when the navy
9 of the Yugoslav People's Army of the JNA was being withdrawn from its
10 garrisons, from the military naval sector. That was the territory of the
11 former Socialist Republic of Croatia. These rockets were not being used
12 and were there, so we thought that we could perhaps use them, if
13 necessary, as surface-to-surface rockets, they have the same kind of
14 charge. And we were saying, If you don't have what we need, give us what
15 you have. We will improvise.
16 THE INTERPRETER: The interpreters did not hear the last
17 sentence.
18 MR. LUKIC: [Interpretation] Do you remember what --
19 JUDGE MOLOTO: The interpreters did not hear the last sentence of
20 the answer.
21 THE INTERPRETER: Interpreter's note: Could all microphones
22 please be switched off when the witness is speaking.
23 MR. LUKIC: [Interpretation]
24 Q. I think that everything has been recorded, I think.
25 A. Yes, yes.
Page 13140
1 Q. You said that everything --
2 A. This is what I said --
3 THE INTERPRETER: Interpreter's note: Could all microphones
4 please be switched off.
5 THE WITNESS: [Interpretation] If they do not --
6 JUDGE MOLOTO: Mr. Lukic --
7 Just hold, ma'am, now that you have asked us to do something.
8 Could all microphones please be switched off while the witness is
9 speaking.
10 You may proceed, Mr. Novakovic.
11 THE WITNESS: [Interpretation] What I said was that if they did
12 not have what it was that we were asking for, let them give us at least
13 this and we will improvise on that basis.
14 JUDGE MOLOTO: Thank you so much.
15 Yes, Mr. Lukic.
16 MR. LUKIC: [Interpretation]
17 Q. Did you get anything as far as these rockets were concerned?
18 A. As far as I can remember, we did not.
19 Q. Next entry says:
20 "Joint 'vojin.'"
21 General, do you remember, does that reflect some of your words at
22 that meeting?
23 A. This accurately reflects my words at that meeting and at other
24 meetings as well. I repeated that very often. The actual entry here --
25 or, I mean, even if it hadn't been written up. "Vojin" means what I
Page 13141
1 said. Its main characteristic is that as a system for securing the
2 air-space, it can only be efficient if organised in a larger area. What
3 have you -- what business do you have detecting aircraft that have
4 already entered a very limited air-space? You should try to observe that
5 as far away as possible so that your own units can be on the ready in a
6 state of full combat-readiness to react. That is why I said to
7 General Perisic and to all other participants that from the Adriatic to
8 Romania a joint system should be set up. Technically that was feasible,
9 and that could have been efficient, and it could have improved things. I
10 was hoping that they would understand that, that that improved the
11 capacity of fighting enemy targets in the air-space of the Army of
12 Yugoslavia as well.
13 Q. And was a joint "vojin" system set up?
14 A. No, it never was.
15 Q. And the next point in this list was:
16 "Joint PED and EI ..."
17 What were you talking about there?
18 A. I remember this very well because this is not the first time that
19 I talked about this. I spoke about this at other meetings as well. My
20 war-time experience confirmed exactly what I knew from theory, and that
21 was that the use of electronic means and counter-electronic warfare
22 against the enemy meant just as much as the use of what we could describe
23 as hardware, meaning tanks, infantry, and other types of resources of
24 that kind.
25 And I have to say that it was strange to me and incomprehensible.
Page 13142
1 And I had an objection about this in terms of General Perisic for as long
2 as I was on duty and that was: Why didn't he make sure as a professional
3 military man to have this system organised jointly and to have all joint
4 systems that could be of interest either to the Army of Yugoslavia, the
5 JNA [as interpreted], or to our army.
6 I knew, for example, of cases when people in the electronic
7 surveillance battalion in the area of Prokuplje were monitoring on a
8 monthly basis one to two foreign communications in the area of
9 neighbouring states. But when combat started in my area, suddenly
10 700 networks would be activated, 700 radio networks would be activated.
11 And I kept telling General Perisic, If you don't want a joint system, at
12 least send these people of yours so that they can see how things look as
13 far as electronic surveillance is concerned in war time. You will
14 increase the value of those units in that way, and you will be of help to
15 us there.
16 The same thing applied to this PED. These are counter-electronic
17 activities, and that means defence measures against the enemy electronic
18 warfare, meaning electronic surveillance. I don't need to go into
19 details. Jamming, ruses, and all these other techniques that are used.
20 And I can speak quite openly here and say that at the time I was
21 trying to explain both to Mr. Perisic and to Mr. Milosevic that this
22 would be useful for the Army of Yugoslavia also if they wanted to monitor
23 what was happening around them. And for us it could help us without any
24 kind of participation in the war outside of the Federal Republic of
25 Yugoslavia that would be massive or of a compromising nature. And I have
Page 13143
1 to say, today even, that it was unclear to me why this was never done.
2 Q. You've already answered my next question with this, so I'm just
3 going to ask: Is it that this didn't happen for as long as you were the
4 commander of the Army of the Serbian Krajina, or did this not happen all
5 the way until the end of the war?
6 A. While I was the commander of the Serbian Army of the Krajina,
7 this did not happen; and it did not happen, as far as I know and which I
8 absolutely believed is accurate, it did not happen until the end of the
9 existence of the Army of the Serbian Krajina.
10 Q. And the next entry is:
11 "To send officers to K."
12 Is this accurately reflecting what you said at the time?
13 A. Yes, yes. Officers should be sent to the corps units, to the
14 Serbian Army of the Krajina. I think that this text -- well, these are
15 not minutes. When you translate it officially, you will see that these
16 are notes made by one man. If I happened to have my notebook handy here,
17 it would have been different. Evidently, if these are entries made by
18 General Mladic, this is actually not everything that I said. I actually
19 said, Send officers to corps units of the Serbian army of the Krajina.
20 But we only have three dots here after that entry.
21 Q. And then after the text that follows, we have the name of
22 President Milosevic. It's a longer section, but we can begin, at least,
23 to go through it, even if we don't have too much time left for today.
24 Well, I don't need to read the first three sentences, and there's nothing
25 here to be disputed regarding the translation. I'm asking you:
Page 13144
1 According to your recollection does this accurately reflect the words of
2 President Milosevic? First answer that.
3 A. Yes.
4 Q. Yes, go ahead.
5 A. I actually remember exactly what this refers to because besides
6 what is written here there was also a request made of me. Mr. Milosevic
7 here is dealing with the internal political situation in Serbia, and as
8 you can see there were internal enemies and 5th column elements in Serbia
9 which were being programmed, as he put it, by the foreign factor,
10 external factor. What is interesting is that in that period - and I know
11 this perfectly well, and this is also something that can be seen in this
12 entry here - the most dangerous opponent in the internal plan was viewed
13 to be Mr. Seselj and the Serbian Radical Party because it was on the
14 ascent and in that part of the political arena which Mr. Milosevic felt
15 belonged to him.
16 I remember that at one point in time I, as the commander of the
17 Army of the Serbian Krajina and immediately after this, which affirms
18 what I'm saying here and what is said here, was asked to blacken the
19 reputation of volunteers of the Serbian Radical Party who were coming to
20 fight in the area of the Republic of the Serbian Krajina in a public
21 statement.
22 So I read a public announcement at a session of the Assembly,
23 which happened to be very tumultuous. I was asked to do that. Of
24 course, I didn't do that because I felt and I said that the volunteers
25 who were coming to the Republic of the Serbian Krajina to help in its
Page 13145
1 defence we did not judge by their party affiliation; we saw them all as
2 being equal, who were coming to fight.
3 Q. And who asked you to read this public announcement?
4 A. I don't remember, but I think it was the then-president of the
5 Assembly of Serbia.
6 Q. Thank you.
7 MR. LUKIC: [Interpretation] I would like to continue with this
8 document, but I think it would be good to stop here, Your Honours,
9 because we're about to change to another topic but remain on this
10 document.
11 Just one moment. Perhaps I have one intervention to the
12 transcript. Just give me a minute, Your Honours, please.
13 [Defence counsel confer]
14 MR. LUKIC: [Interpretation] I didn't wish to interrupt the
15 General, but Mr. Zorko is indicating to me now that on page 73,
16 Your Honours -- page 73, line 8, when the witness was talking about the
17 AE and the PED system, he said it was in the interest of the Army of
18 Yugoslavia, the VRS, and my army, and what is said there is the JNA. So
19 I just assume that it's a mistake in the transcript because the JNA was
20 not actually mentioned in that context.
21 JUDGE MOLOTO: I don't see PED at line 8.
22 MR. LUKIC: [Interpretation] He's talking about that topic. You
23 can see the question on line 20 in the previous page. He's talking about
24 this system, EI and the PED; and then in his reply, page 73, line 8, what
25 is written is the JNA, but he actually referred to the VRS.
Page 13146
1 JUDGE MOLOTO: Do you confirm that, Mr. Novakovic?
2 THE WITNESS: [Interpretation] Yes, yes, absolutely. The JNA
3 didn't exist at the time, Your Honour.
4 JUDGE MOLOTO: Thank you.
5 Is that the end for the day -- end of the day?
6 MR. LUKIC: [Interpretation] Yes, yes. I would like to suggest.
7 JUDGE MOLOTO: Mr. Novakovic, unfortunately we are not going to
8 be sitting tomorrow for logistical reasons within the Tribunal. We will
9 sit on Monday in the afternoon at 2.00 in the same courtroom. Once
10 again, I remind you that you may not discuss the case with anybody and in
11 particular not with your Defence counsel. And if you do have anything
12 outside the case that you would like to talk to him about, try to get in
13 touch with one of the Court Officers and arrange that. Okay? And they
14 will tell you whether you may or may not talk to him.
15 The Court stands adjourned to Monday, quarter past 2.00 in the
16 afternoon, Courtroom II. Court adjourned.
17 --- Whereupon the hearing adjourned at 1.45 p.m.,
18 to be reconvened on Monday, the 30th day
19 of August, 2010, at 2.15 p.m.
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