Page 6944
1 Thursday, 15 May 2008
2 [Open session]
3 [The accused entered court]
4 --- Upon commencing at 2.20 p.m.
5 JUDGE ANTONETTI: [Interpretation] Madam Registrar, can you cite
6 the case.
7 THE REGISTRAR: Good afternoon, Your Honours.
8 This is case number IT-03-67-T, the Prosecutor versus
9 Vojislav Seselj.
10 JUDGE ANTONETTI: [Interpretation] Thank you, Registrar.
11 We are Thursday, 15th of May, 2008. I would like to greet the
12 members of the Prosecution, Mr. Seselj.
13 First, a few housekeeping matters, but first I would like to ask
14 for a closed session. I have a decision to communicate in closed
15 session.
16 [Private session]
17 (redacted)
18 (redacted)
19 (redacted)
20 (redacted)
21 (redacted)
22 (redacted)
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Page 6945
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23 [Open session]
24 THE REGISTRAR: Your Honours, we are back in open session.
25 JUDGE ANTONETTI: [Interpretation] So we're in open session. I
Page 6946
1 would like to inform Mr. Seselj that the internet connection is working,
2 so normally the entire world can follow this hearing.
3 Mr. Mundis, would you like to say anything?
4 MR. MUNDIS: Thank you, Mr. President.
5 Good afternoon, Your Honours, and to everyone in and around the
6 courtroom.
7 (redacted)
8 (redacted)
9 (redacted)
10 (redacted)
11 (redacted)
12 (redacted)
13 JUDGE ANTONETTI: [Interpretation] Mr. Mundis, apparently this
14 motion is confidential.
15 MR. MUNDIS: Perhaps the Chamber ordered it to be filed
16 eventually. It's certainly not indicated thus on the cover of the
17 document. Perhaps for the benefit of the doubt, we could go into private
18 session.
19 JUDGE ANTONETTI: [Interpretation] Let's move on to private
20 session, then.
21 [Private session]
22 (redacted)
23 (redacted)
24 (redacted)
25 (redacted)
Page 6947
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Page 6956
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22 [Open session]
23 THE REGISTRAR: Your Honours, we are back in open session.
24 JUDGE ANTONETTI: [Interpretation] Prosecutor, I think the witness
25 is waiting outside.
Page 6957
1 MR. DUTERTRE: [Interpretation] Yes.
2 Good afternoon, Your Honours.
3 There are two points I would like to address briefly. I would
4 like to introduce the intern who is assisting us today, who -- her name
5 is Sara Grujin. It's the first time she's with us today.
6 Also a procedural matter I would like to address. The Court
7 binder of the next witness is not quite as complete as it should be. We
8 mentioned a video. I intend showing two video clips, one clip which has
9 no sound and no transcript. The other one is very short. It's silent --
10 THE INTERPRETER: Sorry, interpreter's correction: I have handed
11 out the transcript of the second video clip.
12 MR. DUTERTRE: [Interpretation] It's not what the person is saying
13 in the video clip that I'm interested in. It's just to be able to
14 identify the person that I wish to show this video.
15 These are two matters that I wished to bring to the attention of
16 the Trial Chamber because it was not mentioned in the Court binder which
17 we prepared at the last minute given we had to replace a witness wasn't
18 able to come.
19 JUDGE ANTONETTI: [Interpretation] So you still confirm that you
20 need two and a half hours for this witness?
21 MR. DUTERTRE: I shall try and make it shorter, if I can.
22 JUDGE ANTONETTI: [Interpretation] Very well. Whatever the case
23 may be, we shall listen to all of this extremely carefully, and let's
24 bring in the witness into the courtroom, please.
25 In the meantime, Mr. Mundis, as far as next week is concerned,
Page 6958
1 the upcoming witnesses, well, there's a fair chance that this witness
2 today will have to come back on Tuesday. What happens after that?
3 MR. MUNDIS: The next scheduled witness, Professor Riedlmayer,
4 would then testify immediately upon the conclusion of the current
5 witness's testimony. Of course, in the event that the next witness is
6 not able to remain, it might be the case -- I don't know, it might be the
7 case that he has to return home and would need to return at a later date
8 to complete his testimony. I simply don't know. I haven't spoken to the
9 witness about that possibility. We would then immediately go to
10 Dr. Riedlmayer on Tuesday. But the plan would be once this witness is
11 complete, to immediately go to Dr. Riedlmayer.
12 [The witness entered court]
13 JUDGE ANTONETTI: [Interpretation] I shall put the question to him
14 directly.
15 Good afternoon, sir. I would like to check that our technical
16 equipment is working properly. If you can hear me, please let me know.
17 THE WITNESS: [Interpretation] Good afternoon. Yes, I'm able to
18 follow.
19 JUDGE ANTONETTI: [Interpretation] Very well. Sir, can you give
20 me your first name, last name, and date of birth, please.
21 THE WITNESS: [Interpretation] I am Asim Alic. I was born on the
22 8th of March, 1959.
23 JUDGE ANTONETTI: [Interpretation] Sir, do you have a job
24 currently, and if so, what is your occupation?
25 THE WITNESS: [Interpretation] I do not understand the question.
Page 6959
1 JUDGE ANTONETTI: [Interpretation] Do you have an occupation
2 currently or do you not do anything?
3 THE INTERPRETER: The interpreter could not catch it.
4 JUDGE ANTONETTI: [Interpretation] Today, are you currently
5 employed? Do you have an occupation or are you retired?
6 THE WITNESS: [Interpretation] Oh, yes, I am working. Yes, I do
7 have a job.
8 JUDGE ANTONETTI: [Interpretation] And what do you do?
9 THE WITNESS: [Interpretation] I work for the Ministry of the
10 Interior.
11 JUDGE ANTONETTI: [Interpretation] In what capacity?
12 THE WITNESS: [Interpretation] I'm a police inspector.
13 JUDGE ANTONETTI: [Interpretation] Very well.
14 Sir, have you ever before testified before a court of law on
15 questions relating to the former Yugoslavia or is it the first time you
16 testify today?
17 THE WITNESS: [Interpretation] Yes, I testified before the Special
18 Court in Belgrade two years ago.
19 JUDGE ANTONETTI: [Interpretation] So you testified before the
20 Special Court in Belgrade. Who did you testify against?
21 THE WITNESS: [Interpretation] The case which was against
22 Mr. Brano Grujic et al.
23 JUDGE ANTONETTI: [Interpretation] As far as you know, is this
24 trial still ongoing or has there been a judgement?
25 THE WITNESS: [Interpretation] I'm not quite sure. I believe that
Page 6960
1 the case is still going on.
2 JUDGE ANTONETTI: [Interpretation] Sir, please take the solemn
3 declaration.
4 THE WITNESS: [Interpretation] I solemnly declare that I will
5 speak the truth, the whole truth, and nothing but the truth.
6 WITNESS: ASIM ALIC
7 [The witness answered through interpreter]
8 JUDGE ANTONETTI: [Interpretation] Thank you, sir. You may sit
9 down.
10 THE WITNESS: [Interpretation] Thank you.
11 JUDGE ANTONETTI: [Interpretation] Sir, I have something to share
12 with you which is of a practical nature.
13 Since we are running late, there was a witness who came to
14 testify before you, and we can only hear you today. According to our
15 schedule, you will have to resume your testimony next week, i.e., on
16 Tuesday, which means that you would have to stay over until Tuesday. Is
17 that a major problem for you or not?
18 THE WITNESS: [Interpretation] It is no problem.
19 JUDGE ANTONETTI: [Interpretation] Very well. So you will spend
20 the weekend here, and I hope the weather will remain fine.
21 Sir, let me just inform you about the way in which these
22 proceedings will unfold. Since you are a police inspector, you have some
23 understanding and knowledge of what a court case is about.
24 Today, this is a special court. The Judges are not the main
25 protagonists, unfortunately, as far as I'm concerned, and this trial is
Page 6961
1 conducted by the parties, which means that it is the Prosecutor who will
2 put questions to you, first of all, and he will put questions to you and
3 show documents to you. He will show you videos, since he told us that
4 that was his intention. After that stage, Mr. Seselj, who's sitting on
5 your left, will have the same time as the Prosecution to put questions to
6 you, and that is part of what we call the cross-examination.
7 I would like you to rest assured the cross-examination has two
8 purposes; (a), test the credibility of the witness, so some questions
9 will relate to your credibility, and, (b), the second part of the
10 cross-examination is devoted to the substance of the case, based on the
11 answers you gave the Prosecutor.
12 The three Judges who form the Bench, who are in front of you,
13 fortunately have rules of procedure which have entitled us to put
14 questions also, and you will see that we will put questions to you.
15 Generally, we put our questions once each party has put its questions,
16 and our questions usually relate to the merits of the case.
17 Please try and be as accurate as you can when you answer the
18 questions, because all your answers will be recorded on the screen you
19 have before you. It's in English, unfortunately for you, and you might
20 not understand what's being said, but all of this is translated in
21 realtime and is recorded in English on your screen. This is why it is
22 most important that the questions are concise and that the answers are
23 concise.
24 If you don't understand the meaning of a question, please turn to
25 the person who has put the question to you and ask this person to
Page 6962
1 rephrase the question.
2 As a rule, we have a break every hour and a half, and we have a
3 20-minute break, sometimes a 15-minute break. Today, we shall finish at
4 6.00 p.m., so we have three hours before us, and this is an exception.
5 If at any point in time you do not feel well, do not hesitate to
6 raise your hand so that we may adjourn the hearing, and I will adjourn
7 instantly if you have such a problem. And the Bench will answer any
8 questions you may have.
9 I would also like to draw your attention to the fact that from
10 now on you are a witness of the Court, which means that you cannot have
11 any contacts with the Prosecution. You are going to stay here over the
12 weekend, and you cannot contact the Prosecution. You are prohibited and
13 banned from doing so. And the same applies to the Defence.
14 So much for the information I wish to share with you.
15 The Prosecutor, you have the floor, and the clock is beginning to
16 tick.
17 Thank you very much. It is 3.00 sharp.
18 Examination by Mr. Dutertre:
19 Q. [Interpretation] Mr. Alic, when did you join the police, on what
20 date?
21 A. I joined the police in October 1983, in Belgrade.
22 Q. You answered my second question, which was: In which town?
23 Which unit in Belgrade did you join?
24 A. In Belgrade, in the City Secretariat, I joined the Police
25 Brigade.
Page 6963
1 Q. Until when did you keep your position in Belgrade?
2 A. Until October 1991.
3 Q. Where were you posted?
4 A. After that, I started working for the Public Security Station in
5 Zvornik, in Bosnia and Herzegovina.
6 Q. Who was commander of the police forces in Zvornik when you got
7 there in October 1991?
8 A. Dragan Spasojevic. Mr. Dragan Spasojevic was the commander.
9 Q. Was there someone above him or was he the police officer with the
10 highest rank?
11 A. No, there was the chief of the Police Administration, who was
12 hierarchically above him, and his name was Osman Mustafic.
13 Q. Thank you. Could you briefly describe to us how the various
14 departments in the Zvornik police were organised when you got there in
15 1991? Was there a traffic police department, a crime investigation
16 department? Could you briefly tell us how the police was organised in
17 Zvornik?
18 A. Yes. The police was organised in this way: There was a chief of
19 the Police Administration. He was the general chief of the police. Then
20 there was the commander or the commander of the police station who had
21 three assistants. One of the assistants was for the general police. A
22 second assistant was for crime affairs. And the third assistant was for
23 the regulation and control of traffic.
24 In addition to that, there was also a section of the crime police
25 as well as an administrative and support section.
Page 6964
1 Q. Thank you. I'll get back to these various departments, but
2 before that: Do you remember how many active policemen were working in
3 Zvornik when you got there in October 1991?
4 A. It was between 110 and 120 active policemen.
5 Q. What was their ethnicity?
6 A. The complete force -- the complete police force was balanced.
7 The ratio was approximately 50 per cent Bosniaks and 50 per cent Serbs.
8 Q. Thank you. You said that there was a crime investigation
9 department. Who headed that department?
10 A. Mr. Fadil Mujic was the chief of the criminal police.
11 Q. Who headed the general police force?
12 A. Mr. Marinko Vasilic was.
13 Q. Who headed the traffic police department?
14 A. Mr. Slavko Eric.
15 Q. Who headed the administrative unit of the police?
16 A. Madam Sehija Taljic was the chief of that unit.
17 Q. And you, yourself, you were in charge of what unit, what
18 department? What was your position in the police station?
19 A. I was one of the assistants of the commander of the police
20 station. According to the decision assigning me to my work post at that
21 moment in time. And at the same time, I also acted as deputy commander
22 of the police station.
23 Q. Very well. And the commander of the police station was Barijovic
24 [as interpreted]. I think that's the name you mentioned, wasn't it?
25 A. Yes, that is right.
Page 6965
1 Q. Who is Marinko Vasilic?
2 A. Marinko Vasilic was one of the assistant commanders of the
3 commander of the police station.
4 Q. I shall rephrase my question. What was his ethnicity?
5 A. He was a Serb.
6 Q. At some point, did you call on reserve policemen? I don't mean
7 you, personally. I mean your police station.
8 A. Yes. In October 1991. In October 1991, we were given an order
9 by the then Republican Secretariat of the Interior of Bosnia-Herzegovina,
10 to the effect that we were to mobilise a complete reserve police force.
11 Q. Overall, this reserve police force amounted to how many men?
12 A. Their number was double that of the active policemen on the
13 active force, so it was between 110 and 120.
14 Q. Can you specify? Are you saying that there were 220 reservists
15 or are you saying there were reservists plus the active policemen
16 amounted to double the amount of active policemen?
17 A. The number of the reservists was equal to that of active
18 policemen.
19 Q. Thank you. That's perfectly clear. After the call-up, did all
20 these men remain in Zvornik or were they dispatched here and there and
21 sent to various police stations?
22 A. After mobilisation, these forces did not all remain in the town
23 of Zvornik. They were assigned to another five localities in the Zvornik
24 Municipalities; namely, five police stations or branch stations,
25 substations, were established in five different locations.
Page 6966
1 Q. Would you list us the names of these places, please?
2 A. One of the police stations remained at the seat in the town of
3 Zvornik, and it was in the same building as the Public Security Station
4 of the town of Zvornik. Then there was another police station that was
5 set up in the village of Orahovac. Another one was set up in a place
6 called Sapna, and the third one in Kozluk, another one in Pilica, and
7 another a fifth one in Drinjaca.
8 Q. Thank you. How many men were there, on average, per police
9 station? And what I mean by that is I mean this includes the active
10 policemen and the reserve policemen?
11 A. That particular moment in time, we could not assign more than 10
12 to 15 active policemen to these branch stations or 15 to 20 reserve
13 policemen, which in total was about 30 or 35 people.
14 Q. The Sapna, Orahovac and Kozluk, these police stations -- well,
15 the commanders of these police stations reported to whom?
16 A. They all reported to the police station commander in Zvornik and
17 of course to the chief who was the overall commander, the overall chief
18 of the police.
19 Q. When you talk about the overall chief, commander of the police,
20 could you give us his name again, please?
21 A. The chief of the Public Security Station was Osman Mustafic, and
22 the commander, commandeer, was Dragan Spasojevic.
23 Q. Very well. Do you remember having been proofed Monday, Tuesday
24 and Wednesday of this week?
25 A. Yes, I do.
Page 6967
1 Q. Do you remember having drawn a diagram of the police station at
2 the time you were there?
3 A. Yes.
4 MR. DUTERTRE: Your Honour, I would like to display Exhibit
5 number 65 ter 7225, please.
6 We have a translation that arrived rather late today. It's not
7 in the binder, but it is in e-court.
8 Q. Mr. Alic, do you recognise this document as being the diagram you
9 drew of the police station in Zvornik?
10 A. Yes.
11 Q. Do you recognise your signature at the bottom of this document?
12 There it is.
13 A. Yes, I do.
14 MR. DUTERTRE: Your Honour, I would like to tender this document
15 into evidence, so please.
16 JUDGE ANTONETTI: [Interpretation] Madam Registrar, could we have
17 an exhibit number, please.
18 THE REGISTRAR: Your Honours, that would be Exhibit P438.
19 MR. DUTERTRE:
20 Q. Mr. Alic, on this sketch, which -- we can see that Mustafic is
21 Mr. Spasojevic's superior. Could you tell us in what circumstances
22 Mustafic headed the SBS and that things didn't happen the other way
23 around?
24 A. After the elections in Zvornik Municipality and the victory by
25 one of the parties, the party that was victorious, that won, they had the
Page 6968
1 key posts in the municipality, and in all these organs as well.
2 Q. Could you tell us more? Could you tell us which elections you
3 are talking about? On what date did these take place?
4 A. I was working in Belgrade at the time, not in Zvornik, in the
5 1990s.
6 Q. Thank you. Could you tell us which party won the elections?
7 A. In Zvornik Municipality, it was the SDA party that won, and it
8 was at its proposal that the Osman Mustafic came to be the chief, and the
9 SDS provided the second post.
10 Q. Could you specify what SDS and SDA mean?
11 A. The SDA is the Democratic Action Party, and the SDS is the
12 Serbian Democratic Party.
13 Q. And SDA had a particular ethnicity? What part of the population
14 did they represent?
15 A. They were mostly parties that rallied exclusively a population
16 from that same ethnic group. So the SDA rallied Muslims, Bosniaks, and
17 the Serbian Democratic Party rallied Serbs.
18 Q. Thank you. What was the -- what were the ethnic groups in
19 Zvornik?
20 A. Zvornik Municipality had a population of about 80.000. Of that
21 number, 51 per cent were Muslims, 47 or 8 per cent were Serbs, and the
22 rest were others; that is to say, Croats, Romanians and so on, all the
23 other ethnicities.
24 Q. Thank you. Do you know the ethnic makeup of Mali Zvornik?
25 A. Mali Zvornik is located in Serbia, but even there the population
Page 6969
1 is mixed. I can't give you the percentages, but I do know that there
2 were many Muslims living there.
3 Q. Thank you. Now, to remain on the issue of political forces, can
4 you tell us who the mayor of Zvornik was until April 1992?
5 A. The mayor was Abdulah Pasic.
6 Q. Is what was his ethnicity?
7 A. He was a Muslim, and he was from the SDA, the Democratic Action
8 Party.
9 Q. Who is Alija Kapidzic?
10 A. Alija Kapidzic was the chief of the National Defence Department,
11 and he was a Muslim.
12 Q. Was he a member of the SDA?
13 A. Yes.
14 Q. What other names of people belonging to the SDA in Zvornik can
15 you remember at the time?
16 A. I can't remember any names now. I wouldn't want to make a
17 mistake.
18 Q. Okay. Who set up the SDS in Zvornik?
19 A. The SDS of Zvornik was a municipal organisation of the Serbian
20 Democratic Party, and Mr. Brano Grujic headed it.
21 Q. Who were the other leading members of the local branch of SDS in
22 Zvornik?
23 A. I think there was Jovo Ivanovic, who was the President of
24 Executive Power in Zvornik Municipality, and some other people whom I
25 couldn't name now, because I don't want to get it wrong.
Page 6970
1 Q. Was Dragan Spasojevic a member of the SDS in Zvornik?
2 A. Dragan Spasojevic was appointed commander of the Public Security
3 Station in Zvornik, as being a member of the SDS.
4 Q. Do you know if he had relations with Brano Grujic?
5 A. Yes. They would see each other often at the police station. I
6 would see them there, and I attended their meetings regularly.
7 Q. What did Dragan Spasojevic call Brano Grujic; do you remember?
8 A. He called him "Big Daddy or "Veliki Tata." That's what he called
9 him. For whatever reason, I can't say; that he liked him or something
10 else.
11 Q. Which brings me back a little bit. When you're saying that
12 Dragan Spasojevic headed the SDS in Zvornik, do you mean that he was the
13 chairman? What was his title, exactly, within the SDS in Zvornik?
14 A. The president of the SDS. That's how my perception of him was,
15 the president of the Serbian Democratic Party, that was his political
16 function.
17 Q. Do you know if Brano Grujic had relations with Arkan?
18 A. Yes.
19 Q. Could you describe the relations between Brano Grujic and Arkan,
20 and how do you know about that?
21 A. I happen to know that because I was present on two occasions at
22 Crisis Staff meetings that were held at the time, and Abdulah Pasic, the
23 president of the municipality, held talks exclusively with the opposite
24 side, if I can put it there, his opposite number, and that was the
25 Serbian Democratic Party. Brano Grujic did maintain contacts with Arkan,
Page 6971
1 because he called Arkan and his forces to come to Zvornik to help him out
2 in taking over power and authority, taking over control there.
3 Q. Did you see Brano Grujic and Arkan together?
4 A. [No verbal response]
5 Q. Then how do you know that Brano Grujic had contacts with Arkan?
6 A. That's what he -- what Abdulah Pasic told us. Upon returning
7 from the meeting with Arkan, he reported to us and informed us what the
8 topics of discussion were and how the discussion evolved.
9 Q. Could you be more specific? What did he tell you, exactly? Did
10 he see both men together? What was his information based on, regarding
11 relations between Arkan and Brano Grujic?
12 A. Well, I can explain it in the following way: When the meeting
13 was organised in Mali Zvornik, at the Jezero Hotel, the meeting was
14 organised with Arkan, and the mediator was Mr. Grujic. He was the
15 go-between. And they all found -- they all happened to be at Jezero
16 Hotel, Alija Kapidzic, Pasic and all the people there that were there at
17 the time. They had discussions there. They discussed the problems that
18 were looming, the ultimatum of the Serbian Democratic Party and Arkan,
19 that the Bosniaks in the town of Zvornik should lay down their arms, hand
20 over power and authority. And when Abdulah Pasic returned from the
21 meeting, he informed us about that, and so at that Staff meeting they
22 tried to make some decisions and reach some conclusions.
23 Q. Okay. I'll come back to that meeting later. But since we don't
24 have a date yet, it might be not fully clear for the Chamber, but I'll
25 come back to that later on.
Page 6972
1 Do you know if Brano Grujic had relations with Mr. Seselj?
2 A. I don't know. I really can't say. I do know, as a member of the
3 service, that Mr. Seselj was supposed to visit Bosnia-Herzegovina or,
4 rather, the town of Bratunac, and his arrival was postponed, the reason
5 being that at that time on this side, there were strong police forces and
6 they were ready to arrest him. However, the Public Security Service at
7 the time reported this, and Mr. Seselj gave up on the idea of visiting.
8 JUDGE ANTONETTI: [Interpretation] There might be a mistake in the
9 transcript, Mr. Dutertre. At line 10 of page 28, the page we have here,
10 in the English version it is said "Mali Zvornik," in the English version,
11 whereas it seems that in the French version you said "the municipality of
12 Zvornik or Prevnik [phoen]."
13 MR. DUTERTRE: In English, page 28, line 10, the witness said:
14 "When the meeting was organised in Mali Zvornik --"
15 It's not up to me to give evidence. I don't see any mistake to
16 be corrected here, but we'll come back to that at a later stage, because
17 we'll take it in chronological order. I wanted him to give information
18 about relations with the accused.
19 JUDGE ANTONETTI: [Interpretation] Mr. Witness, the Prosecution
20 asked you at some point if you were aware of relations between Grujic and
21 Mr. Seselj, inducing us to believe that Mr. Seselj was internationally
22 known. Who was Mr. Seselj for you at the time?
23 THE WITNESS: [Interpretation] Mr. Seselj was the president of the
24 Serbian Radical Party.
25 JUDGE ANTONETTI: [Interpretation] And you knew that?
Page 6973
1 THE WITNESS: [Interpretation] Yes.
2 THE ACCUSED: [Interpretation] Objection. Since the Prosecutor's
3 already forgotten about it, we should set the time period, because the
4 witness said that I was supposed to visit Bratunac. When was that?
5 MR. DUTERTRE: That was exactly the point of my next question.
6 JUDGE ANTONETTI: [Interpretation] I believe the Prosecution will
7 make everything clear.
8 MR. DUTERTRE: Mr. Seselj, it's exactly the point of my next
9 question, but you're leading me to it. Thank you for that.
10 Q. Yes. It was still unclear in the chronology, but what time
11 period was that visit by Mr. Seselj to Bratunac planned?
12 A. I can't be precise as to the date, but I do know with certainty
13 that the visit by Mr. Seselj was announced and that, from Tuzla, the
14 Public Security Centre there sent a special unit, and they were present
15 in the police station throughout the time and waited for his visit to
16 Bratunac.
17 Q. Maybe so we can clarify matters, were you already in your
18 position in Zvornik or weren't you in your position? Is it before or
19 after October 1991?
20 A. Afterwards, after October. I think it was in 1992, in the first
21 few months of 1992.
22 Q. Understood. So to wrap up on the political forces and the
23 political composition of the municipality, do you know the ethnic makeup
24 of Zvornik today?
25 A. Today, there are very few Muslims there; exclusively a Serb
Page 6974
1 population. I don't think there are even 10 per cent of Muslims there
2 now.
3 Q. Good. Now, let's move on to military forces. Do you know if JNA
4 forces were stationed in the Zvornik area between October 1991 and April
5 1992?
6 A. Yes, I do know. In a place called Celopek, there was a complete
7 armoured battalion that was withdrawn from Jastrebarsko, from Croatia, so
8 it was stationed there in Celopek.
9 Q. What time did the battalion arrive in Celopek, if you remember?
10 A. That was during their withdrawal from Croatia, that period, and
11 they were located in this place called Celopek. And after that, at the
12 bridge in Karakaj, they set up the tanks, they positioned the tanks
13 there, and also at Divic, on the hydroelectric power plant there; dam, in
14 fact.
15 Q. Let's try and be more accurate. Could you indicate a month
16 during which they arrived? Was it in November, December? Could you give
17 us more detail to shed like on the subject?
18 A. The end of 1991. I think it was November or December 1991, when
19 they returned. Perhaps earlier, but certainly then.
20 Q. Who was the commander of this JNA military unit?
21 A. You mean the unit that was in Celopek, their commander?
22 Q. Yes.
23 A. I don't know the man's name.
24 Q. Who is Colonel Tacic?
25 A. He was an officer of the Yugoslav People's Army, and he had his
Page 6975
1 seat in the barracks in Tuzla. That's where his headquarters were.
2 Q. Understood. Were there members of the TO in Zvornik over that
3 period between October 1991 and April 1992?
4 A. Yes, there were.
5 Q. Apart from the Territorial Defence and the JNA, did you notice
6 whether any volunteers arrived between October 1991 and April 1992?
7 A. I apologise, but could you explain what you mean, please?
8 Q. Do you know if paramilitary volunteers arrived in the area of
9 Zvornik between October 1991 and April 1992?
10 A. Yes, I do know that.
11 JUDGE ANTONETTI: [Interpretation] Prosecution, in the question
12 there are "paramilitary volunteers." The question is somewhat
13 complicated.
14 The Prosecution asked you about volunteers, saying "paramilitary
15 volunteers." Were there paramilitary units? You know what are
16 paramilitary units, do you, and what is a volunteer for you?
17 THE WITNESS: [Interpretation] Yes, I do know that. The
18 volunteers were the people who were outside the system, outside the
19 system. The system was the regular army and the regular police force,
20 and also regular was the Territorial Defence. Everybody else was outside
21 that system, and that's where the volunteers belonged to, outside, those
22 who nobody could engage according to the law and pursuant to the law, but
23 they came in of their own will, voluntarily, or they were persuaded to
24 report.
25 JUDGE ANTONETTI: [Interpretation] Mr. Witness, you're a police
Page 6976
1 inspector. You're well educated and well informed. According to the law
2 at the time on defence matters, weren't volunteers taken into account,
3 people who would volunteer to be joining regular units? Wasn't that a
4 possibility legally provided for?
5 THE WITNESS: [Interpretation] During that period of time, the
6 system that we had was as follows: In case of imminent danger of war,
7 the Secretariat for National Defence had a reserve force, and he would
8 call that reserve force up in writing. The Ministry of the Interior had
9 its reserve force, and they would be called up in writing. These were
10 institutions regulated by law.
11 Then there was the regular Yugoslav People's Army, so that way
12 everybody knew where the reserve force was and had his reserve post.
13 Everything that happened within that system was according to the system
14 and governed by law. Everything else was irregular and outside the law.
15 JUDGE LATTANZI: [Interpretation] Mr. Witness, when you're saying
16 that it was irregular and outside the law, are you saying that on the
17 basis of Bosnian law or do you take into account the law still prevailing
18 in former Yugoslavia? Because if I understood what you said correctly,
19 here you're talking about volunteers or paramilitary people who are in
20 the fighting fields, but the non-Bosnian fighting fields?
21 THE WITNESS: [Interpretation] At that time, the laws that were in
22 force were Yugoslav laws. They were in force for everyone, and that
23 included us in Bosnia. So we all acted pursuant to the laws.
24 JUDGE LATTANZI: [Interpretation] You're saying "at that time."
25 What year was it?
Page 6977
1 THE WITNESS: [Interpretation] I'm thinking of all the time up
2 until -- at least as far as Zvornik is concerned, April of 1992, and I'm
3 speaking for Zvornik. After that period, for a time the laws were still
4 applied, but then new laws were in force because the states became
5 independent, they proclaimed their own constitutions. New constitutions
6 and new laws were made.
7 JUDGE ANTONETTI: [Interpretation] Your country,
8 Bosnia-Herzegovina, became independent at which date, exactly?
9 THE WITNESS: [Interpretation] I'm ashamed to say it, but I really
10 don't know the answer to that question.
11 JUDGE ANTONETTI: [Interpretation] Okay. But when the volunteers
12 arrived, was it still Yugoslavia, or Bosnia-Herzegovina already existed
13 with a president, Izetbegovic, so --
14 THE WITNESS: [Interpretation] I see. Before the arrival of the
15 volunteers in Zvornik, Bosnia-Herzegovina was a sovereign and independent
16 state, independently recognised, before the arrival, before their
17 arrival. So all volunteers that came in arrived to a state that was
18 internationally recognised and independent, sovereign.
19 JUDGE ANTONETTI: [Interpretation] Are you certain of that?
20 THE WITNESS: [Interpretation] 100 per cent.
21 JUDGE ANTONETTI: [Interpretation] Mr. Dutertre, you can move on.
22 MR. DUTERTRE: [Interpretation]
23 Q. Mr. Alic, you said you knew something about those volunteers.
24 Can you tell us what you knew about them?
25 A. As a member of the service at that time in Zvornik, I worked as
Page 6978
1 assistant commander of the police station, and all the work that that
2 entailed. After April 1992, four volunteers who had arrived from Serbia
3 were arrested at one of the barricades that was erected by the citizens
4 of Zvornik. They were stopped there, taken into custody, and handed over
5 to us at the police station.
6 Q. I will come back to that incident at a later stage. To stick to
7 the chronological order once again, and it might clarify a question I've
8 just asked.
9 What day did the attack on Zvornik take place?
10 A. The attack on Zvornik took place on the 8th of April, 1992.
11 Q. Understood. Okay, I will now try to go over the period between
12 October 1991 and April 1992, in a chronological manner, so as to point to
13 some salient events.
14 The first question: What were the relations like between Serbs
15 and Bosnian when you arrived in Zvornik in October 1991?
16 A. Relations were good, proper. At least my service, working in the
17 field, we had contacts with lots of people, and the relationships weren't
18 bad. They were good.
19 Q. You explained that official positions were allocated on the basis
20 of electoral results. When you arrived in October 1991, what were the
21 SDS claims on position allocation and administration? Did the SDS
22 accepting of the allocation? Did they object to the allocation or was
23 their position neutral on that?
24 A. Well, what I can say is this: When I arrived in Zvornik and was
25 sent to the Public Security Station, I came across the situation as it
Page 6979
1 was. However, the Serbian Democratic Party at the time was not satisfied
2 with its positions in the distribution of power and authority, and it
3 demanded that it be changed to its advantage. There were negotiations
4 that went on for days. The leaders of the SDA and SDS held consultations
5 about the different posts and adjustments that were supposed to be made,
6 and when the Serbian Democratic Party didn't like something, they decided
7 to reach those posts by force.
8 Q. Do you know whether crisis staffs were set up within the local
9 branches of SDS and SDA at Zvornik, and at what period of time?
10 A. I know for a fact that the crisis staffs existed at the time both
11 in the Serbian Democratic Party and in the Party of Democratic Action. I
12 know that for a fact, that is, that they existed. When they were
13 founded, I don't know. I cannot confirm that. I do know that they
14 convened and met, and the Crisis Staff of the Party of Democratic Action
15 met on two occasions at the police station, where I, as a present
16 officer, wanted to hear what was going on and was present at that
17 meeting.
18 Q. Very well. When you say you don't know exactly when these were
19 set up, could you tell us this: At the time you arrived in Zvornik in
20 1991, whether these crisis staffs in the SDA and SDS existed already or
21 not?
22 A. I believe that they did. The task of the crisis staffs at the
23 time was as follows, and this is what our police sources tell us and the
24 other information that we had at the time: The crisis staffs had the
25 task of homogenizing each one, its own ethnic structure, and to arm them
Page 6980
1 and prepare them for war.
2 Q. Very well. You anticipated my next question. Did you
3 notice - this is something you mentioned - that they were wearing weapons
4 or were arming each --
5 A. Yes.
6 Q. Getting weapons?
7 A. Armed. The Serbs were being armed by the army, and we know that
8 for a fact because military lorries actually brought in weapons and
9 distributed it to the Serbs. The Bosniaks, on the other hand, bought
10 weapons and they also armed themselves, but the Serbs had a much better
11 supply and much more pieces of weapons, because they received them, and
12 the Bosniaks bought their armaments. That is the difference. But both
13 peoples were arming.
14 Q. According to you, according to what you know, when did the
15 Serbian and Bosniak people start?
16 A. When I arrived in Zvornik, the situation was like that already.
17 Q. Very well. Did you notice any incidents while you were in
18 Zvornik, between October 1991 and April 1992, incidents which could have
19 been ethnic in nature?
20 A. Yes. Incidents of an ethnic nature started happening, and we, as
21 the police, were confronted with huge problems, trying to prevent such
22 incidents from happening, and to simply calm tensions and to see to the
23 establishment of some normal order in order to prevent any further
24 escalations of the situation.
25 Q. How many incidents do you remember?
Page 6981
1 A. There were many minor incidents, but there are two incidents
2 which merit attention, and I'm going to elaborate on these two on this
3 occasion.
4 When I arrived in Zvornik, one of these incidents had already
5 happened in a place which is also in Zvornik Municipality, in a place
6 called Kiseljak. A taxi driver was killed there brutally. His throat
7 was slit. And this was a citizen -- a Serbian -- a Serb citizen of
8 Zvornik. This incident created enormous problems for us, and we sought
9 to shed light on it in every possible way. But we never managed to do
10 so, because we were prevented because the war. I believe that this was
11 orchestrated incident at the time in order to, indeed, create an incident
12 situation between the Bosniaks and the Serbs, to raise tensions and to
13 give -- and to provoke the erection of barricades and all the other
14 things that attended the situation.
15 The second incident was in Sapna. There was a column of soldiers
16 of the Yugoslav People's Army approaching. Whenever they passed through
17 these places, they would also have reservists with them, and they would
18 shoot from the columns at the settlements that they were passing through,
19 at the mosques and different buildings, and the locals returned fire.
20 The locals of the village of Sapna returned fire, and one military
21 officer, who I believe was a warrant officer, was killed. And that is
22 the second incident which happened and which was also used as calls
23 for -- also brought about a tumultuous situation and the heightening of
24 tensions. Although we had the Tuzla police from their centre actually
25 undertaking the investigation, and the investigation was conducted by an
Page 6982
1 investigative judge, with Mr. Marinko Vasilic also from our station as
2 representing the Serbs, and Mr. Fadil Mujic representing the Muslims, we
3 composed a team intentionally in such a way for them to see to the
4 observance of the regularity of procedure, because we didn't want anyone
5 to tell us that we didn't act according to proper procedure.
6 MR. DUTERTRE: Thank you. It might be time to have a break.
7 JUDGE ANTONETTI: [Interpretation] Well, please, now, because
8 we'll only have one break today.
9 MR. DUTERTRE: [Interpretation]
10 Q. The simplest question to begin with: The second incident, what
11 date did that occur on, please?
12 A. I couldn't say with precision, but I do know that at the time I
13 was one of the commanding officers in the police station in Zvornik. So
14 it was in 1992.
15 Q. Very well. You mentioned that the first incident had been
16 orchestrated. Could you explain this to us? Who had orchestrated this
17 first incident, according to you?
18 A. I couldn't confirm that, but according to our information, the
19 information available to the police and the sources available to the
20 police from our intelligence sources on the ground, actually told us that
21 this was done -- had been done deliberately, that it was done in order to
22 heighten inter-ethnic tensions and to have the situation in the area
23 deteriorate.
24 MR. DUTERTRE: Thank you. If this is the right time to have a
25 break, well --
Page 6983
1 JUDGE ANTONETTI: [Interpretation] We shall have the break now and
2 resume at a quarter past 4.00, and then we will run on until 6.00 without
3 having a break.
4 MR. DUTERTRE: [Interpretation] Could you please let me know how
5 much time I have left?
6 JUDGE ANTONETTI: [Interpretation] You still have a lot of time
7 left. Madam Registrar, could you give us the countdown, please.
8 THE REGISTRAR: Your Honours, the Prosecution used 47 minutes so
9 far.
10 MR. DUTERTRE: [Interpretation] Thank you.
11 --- Recess taken at 3.55 p.m.
12 --- On resuming at 4.18 p.m.
13 JUDGE ANTONETTI: [Interpretation] Mr. Dutertre, you have the
14 floor.
15 MR. DUTERTRE: [Interpretation] Thank you.
16 Q. Mr. Alic, what happened in Celopek with members of the Serb
17 police in 1992?
18 A. At the time, a review was conducted of what they called the Serb
19 militia, the Serb police. These were policemen who also were part of the
20 Public Security Station in Zvornik, and they were on the active force.
21 This lineup and review of that unit was carried out by Spasojevic, the
22 then commander of the unit.
23 Q. Were there only Serbian policemen or also Bosnian police
24 officers, and if not, why?
25 A. There were no Bosniak policemen among them. It was only Serb
Page 6984
1 policemen who attended the -- this event, which was some sort of a dress
2 rehearsal of the Serbian police force in the town of Zvornik. This was
3 the last preparation, as it were, that took place.
4 Q. How did you find out about the event? What was your source of
5 information?
6 A. My source of information was the intelligence available to the
7 police, which was present there, and they wrote official records,
8 official notes, which were submitted to us, and we discussed them on the
9 next day at the meeting of the Staff Collegium in the police station.
10 Q. Can you tell us what was discussed at that meeting, what were the
11 conclusions of the meeting?
12 A. The staff meeting at the police station met very often and
13 convened on a daily basis, if necessary, and on the agenda were different
14 problems about the situation -- concerning the situation on the ground,
15 et cetera. On that occasion, I asked Mr. Dragan Spasojevic, in
16 connection with this problem, I said, "Dragan, please tell us, what kind
17 of a review was this that you undertook, what does it signify? Who was
18 obliged to attend?" Dragan just laughed, and he told me, "Well, this is
19 the police of the future Republika Srpska."
20 Q. Could you clarify at what point in time the incident in Celopek
21 took place; what month, what year?
22 A. I believe it was the end of February or the beginning of March,
23 1992.
24 MR. DUTERTRE: [Interpretation] Thank you.
25 JUDGE ANTONETTI: [Interpretation] Witness, a few dates. Just so
Page 6985
1 you know where you are, these are dates in the Prosecution's document on
2 the 27th [Realtime transcript read in error "28th"] of March, 1992,
3 Republika Srpska was officially proclaimed in Pale. On the 27th of
4 March, not the 28th. And on the 6th of April, 1992, the United States of
5 America and the European Community officially recognised
6 Bosnia-Herzegovina as an independent state. So these are two dates which
7 might be helpful to you and us.
8 MR. DUTERTRE: [Interpretation] Thank you, Presiding Judge. This
9 is extremely precious information.
10 Q. What happened in April, April 1st, 1992?
11 THE ACCUSED: [Interpretation] [Previous translation continues]
12 ... the United States of America and the European Community recognised
13 independence of Bosnia-Herzegovina means absolutely nothing. I insist
14 that you give the witness the date of the admission of Bosnia-Herzegovina
15 to the United Nations. That can be, in a certain sense, legally
16 relevant. The fact that the Americans and the European Community
17 actually recognised it is something that you can really discard as
18 totally immaterial.
19 JUDGE LATTANZI: [Interpretation] Mr. Seselj, to be part of the
20 United States, you need to be an independent state, so not even that date
21 would be helpful to us.
22 JUDGE ANTONETTI: [Interpretation] We also recall the issue of the
23 United Nations, but that comes at a later stage. Before you become a
24 member of the United States -- the United Nations, sorry, you first need
25 to become a state, and for that you need to be recognised.
Page 6986
1 Mr. Dutertre.
2 MR. DUTERTRE: [Interpretation] Thank you. I repeat my
3 question --
4 THE ACCUSED: [Interpretation] I have an additional objection.
5 Why did it not occur to you to say on which date Russia
6 recognised it, and China and India, on what day did China recognise? Why
7 do you always give precedence to America and the European Community,
8 which to me are hostile states?
9 JUDGE ANTONETTI: [Interpretation] If you have the dates, you can
10 provide them to us. I've read the Prosecution document which is attached
11 to the document. It's attachment 1. So I referred to the aforesaid
12 document. Now, if you have any other known date, the dates at which
13 Russia and China and India recognised, we will acknowledge those dates
14 quite willingly. But so far, I don't have these dates in the Prosecution
15 documents.
16 Okay, let's move on.
17 THE ACCUSED: [Interpretation] Mr. President, I'm not going to
18 interfere in the examination-in-chief, and I'm not going to provide you
19 with this information. I'm just stating my objection. The one who gave
20 you the previous information should supply you with the rest of the
21 information. This is the examination-in-chief, and I'm not going to
22 interfere.
23 JUDGE ANTONETTI: [Interpretation] Very well.
24 MR. DUTERTRE: [Interpretation] Thank you, Mr. Seselj.
25 Bosnia was admitted in the United Nations in May 1992.
Page 6987
1 THE INTERPRETER: The interpreter did not get the day.
2 MR. DUTERTRE: [Interpretation]
3 Q. Do you remember what happened on the 1st of April, 1992, in
4 Sarajevo, Mr. Alic?
5 A. On the 1st of April in Sarajevo, we had a scheduled meeting of
6 all members of the police. We all had to be present up there, and by our
7 presence, to show our shared commitment to having a united police force
8 remain as such in Bosnia-Herzegovina. So we were against any divisions
9 on an ethnic basis or any other sorts of divisions.
10 Q. What ethnic members of the police were present at that meeting on
11 the 1st of April?
12 A. No one was present of the Serb policemen at that meeting.
13 Q. Thank you. Did you notice whether Serbs or people of their
14 family left Zvornik at the beginning of April 1992?
15 A. Yes. They did so on a number of occasions, and I believe
16 personally observed that. This took place during the weekends. They
17 would leave in the afternoons. They would pack and put whatever they
18 could into their cars, and they would then cross the Drina River.
19 Q. And exactly how long before the attack on Zvornik did they start
20 leaving the town?
21 A. Almost a month or a bit more than that before that.
22 Q. Now I'll come back to the second incident mentioned by two
23 witnesses. You will remember that the witnesses mentioned two incidents,
24 one with a Serb taxi driver and others with shots in Sapna, so I'd like
25 to jog your memory, Mr. Witness, regarding the date of the incident.
Page 6988
1 Mr. Alic, do you remember testifying or providing evidence on the
2 13th of July, 1993, before an investigator of the Tribunal? It's a
3 written statement.
4 A. Yes.
5 Q. I will read part of paragraph 4, page 2, of that statement, and
6 I'll start reading:
7 [In English] "Ever since the war in the former Yugoslavia
8 started, JNA troops went through the Zvornik area and on their way to the
9 battlefields in Croatia on a regular basis."
10 THE ACCUSED: [Interpretation] Objection. There's absolutely no
11 reason for the Prosecutor to read out this portion of the statement. He
12 didn't ask any questions referring to that at all, so now he has to
13 remind the witness of a detail, so he has to ask the witness questions.
14 And if the witness can't remember a detail, then he can go and say,
15 "Well, this is what you said. Do you stand by that?" So it's, in fact,
16 refreshing his memory on the basis of the statement. So that's very
17 leading.
18 There were leading questions before this as well, but I didn't
19 decide to react because I didn't think it was too important. But this
20 has gone too far now.
21 JUDGE ANTONETTI: [Interpretation] Mr. Dutertre, Mr. Seselj is
22 voicing an objection I need to deal with. You're jogging the witness's
23 memory by reading a paragraph from a statement. This statement was
24 drafted over ten years ago, about twelve years ago, and understandably
25 it's possible to forget about things that you've written and find twelve
Page 6989
1 years before. I would be unable to remember that sort of thing. That is
2 why you've read to him this paragraph, because you felt that there were
3 uncertainties in his previous answers; is that the issue?
4 MR. DUTERTRE: [Interpretation] Your Honour, the witness mentioned
5 two incidents. He mentioned the date of the first one, approximately.
6 He didn't indicate the date for the second incident. Regarding the
7 second incident and the statement, a date is mentioned on the fourth line
8 of the paragraph which I started quoting. This is why I wanted to ask
9 the witness if that's what he remembers.
10 JUDGE ANTONETTI: [Interpretation] Go on, then.
11 Mr. Seselj, the Trial Chamber has decided that the Prosecution
12 can read the paragraph. Objection overruled. You don't have to comment
13 on this issue.
14 We understood that on the second incident, he was not able to
15 give accurate dates. This is why we are reading the paragraph to him, to
16 jog his memory.
17 What do you, yourself, do? When you have your own statements,
18 you read them to a witness. What is valid for you should be also valid
19 for the Prosecution.
20 Now, regarding whether it is a leading question or not, and the
21 dangers in that, this is only a question to have a more accurate date. I
22 don't see where the danger of a leading question would be. What do you
23 mean?
24 THE ACCUSED: [Interpretation] What I want to say is this: You
25 cannot say that what holds true for me holds true for the Prosecutor.
Page 6990
1 There are a set of rules for the examination-in-chief and other rules for
2 the cross-examination. The Prosecutor could have asked the witness
3 whether he remembers having said this in the statement, that the event in
4 Sapna happened on the 5th of April, 1992, on such-and-such a page, and
5 not reading an entire paragraph from the statement. That is not
6 refreshing his memory, in the sense of the Appeals Chamber ruling. What
7 he can do is say, "You said here that it was the 5th of April. What do
8 you have to say to that?" Because it's in my interest to hear when the
9 exact date was, and it was in fact three days before the final clash in
10 Zvornik took place. So it's in my interests for that to be stated. But
11 in principle, the way in which the witness's memory is refreshed and by
12 reading out this whole passage is not the right way to go about it.
13 JUDGE ANTONETTI: [Interpretation] As Mr. Seselj was speaking, I
14 was looking at the paragraph. The date is on the fourth line of that
15 paragraph, so read up until the fourth line, until the comma, the full
16 stop.
17 MR. DUTERTRE: [Interpretation] I would have said the date myself.
18 Maybe I would have been blamed for not reading the paragraph. If I read
19 the paragraph, I'm now being blamed for not giving the date. But
20 Mr. Seselj has given the date, the 5th of April, 1992. Now I can ask the
21 question directly to the witness.
22 Thank you, Mr. Seselj.
23 Q. Do you remember, Mr. Alic, that the second incident you mentioned
24 before took place on the 5th of April, 1992?
25 A. I said a moment ago that I cannot confirm the exact date. But
Page 6991
1 now I've heard what the date was, so I do believe that that is correct,
2 that it was, indeed, that date.
3 Q. Thank you, Mr. Alic. You indicated that Mr. Mujic and
4 Mr. Vasilic took part in the investigation. Could you tell us what
5 happened to them on the 5th of April, 1992, during their investigation?
6 A. This investigation was conducted by the investigating judge from
7 Tuzla. It was under his leadership, and the crime police from Tuzla, the
8 Security Centre, carried out an on-site examination, and we were included
9 in the team, and Fadil Mujic, the chief of the crime police, and Vasilic,
10 Marinko, supervised it, the assistant commander of the police station,
11 they supervised it. But the investigation was never completed, because
12 three days later in the town of Zvornik, everything had already escalated
13 and everyone went their own way.
14 Q. Did anything happen to Mr. Vasilic and Mr. Mujic on that day, on
15 the 5th of April, 1992, in the course of their investigation, which we
16 now know didn't --
17 A. Yes, at one of the barracks that was located between Karakaj and
18 Sapna.
19 Q. Who controlled the road blockage?
20 A. The locals, the citizens, the Serbs who were from the village.
21 Q. And what happened to Mr. Mujic and Vasilic at the roadblock
22 controlled by the Serbian inhabitants in the village?
23 A. They -- to all intents and purposes, they were arrested there,
24 and Mr. Mujic and him could not identify the people who had arrested
25 them, but they underwent great unpleasantness, and then even told that
Page 6992
1 the town of Zvornik could be attacked and razed to the ground.
2 Q. How did you find out about this? Did they tell you about it or
3 other people did?
4 A. Well, that story was told at the professional staff meeting, and
5 I was present there, and it was held the very next day.
6 Q. Who told that story?
7 A. Mr. Mujic and Mr. Vasilic. Both of them were members of the
8 Collegium, the staff.
9 Q. In the night between 5th and 6th of April, 1992, what happened in
10 Zvornik and the surrounding area?
11 A. In Zvornik, what happened was this: When the policemen, Serb
12 policemen, left the legal, regular Public Security Station, taking with
13 them a certain quantity of weapons and equipment, they went to Karakaj,
14 to the Standard building, where they set up a new police station.
15 Q. And during that night, did something happen regarding access to
16 the city of Zvornik?
17 A. Yes. On all the approach roads, barricades were set up, which
18 quite literally cut off the town of Zvornik from all the other places and
19 prevented exit and entrance.
20 Q. Who set up the roadblocks in the night between the 5th and 6th of
21 April, 1992, on the road to Zvornik?
22 A. They were set up by the citizens of Zvornik of Serb ethnicity.
23 Q. Do you remember drawing a map during your written statement to
24 the OTP investigator in 1997, showing the location of these roadblocks?
25 A. I did give statements, and I did make some sketches, but I can't
Page 6993
1 be precise.
2 THE ACCUSED: [Interpretation] Objection. I want to see this 1997
3 statement. All I have is the 1996 statement.
4 MR. DUTERTRE: [Interpretation] The 1997 statement was
5 communicated -- disclosed to the accused, so he should have it. But we
6 might be able to print it out again, but he received it.
7 THE ACCUSED: [Interpretation] Perhaps I did receive it at some
8 point, but I have no trace of it. I just have the 1996 statement in
9 front of me now.
10 MR. DUTERTRE: [Interpretation] It was communicated to the
11 accused. I'm formal on that. But we'll try to print it as soon as
12 possible.
13 I'd like to display Exhibit 65 ter 7223, please.
14 Q. Mr. Alic, is this drawing the one you did yourself at the time in
15 1997? That's the English version appearing. Do you recognise your
16 signature at the bottom of the drawing?
17 A. Yes.
18 Q. The various stations set up after the reserve policemen were
19 mobilised, you talked about Pilica, Orahovac. Do these various stations
20 appear on the drawing?
21 A. Yes, yes, they do.
22 Q. Could you show us, on the sketch, what the double lines in read
23 show? They appear on what seems to represent a road.
24 A. Those red lines, double lines, denote the place where barricades
25 had been erected.
Page 6994
1 MR. DUTERTRE: [Interpretation] Your Honours, I'd like to tender
2 the sketch into evidence.
3 JUDGE ANTONETTI: [Interpretation] An exhibit number, please.
4 THE REGISTRAR: Your Honours, that will be Exhibit P439.
5 MR. DUTERTRE: [Interpretation]
6 Q. Mr. Alic, what was the Bosnian inhabitants' in Zvornik reaction
7 when the aforesaid barricades were set up?
8 A. Well, you can well imagine what the reaction was when the
9 barricades suddenly crop up and stop all traffic.
10 Q. You indicated that during the night, the Serbian policemen left.
11 Could you tell us the names of some of these Serbian policemen who left
12 Zvornik?
13 A. Yes, the then commander Dragan Spasojevic was the commander up
14 there, and his assistants were Slavko Tadic and Marinko Vasilic, and they
15 were assistants in this other Zvornik Public Security Station, and all
16 the other Serb policemen.
17 Q. Very well. I'd like to move on now to the 7th of April, 1992, in
18 Zvornik. What happened in the morning of the 7th of April, 1992?
19 A. The 7th of April, 1992, that was a -- well, just prior to the
20 war, a state of siege, and a crisis staff meeting was held. I was
21 present to see what was being done there, and also present were
22 Abdulah Pasic, the mayor, Alija Kapidzic, and various other people, and
23 they said at that staff meeting that they had to go to Mali Zvornik
24 because they were called there, because Arkan was waiting for them there,
25 and that they were to conduct certain negotiations over there.
Page 6995
1 Q. You mentioned that Arkan was waiting for them there,
2 Abdulah Pasic and Alija Kapidzic. How had they been informed, through
3 what means?
4 A. They were called -- well, the liaison was Mr. Brano Grujic.
5 Mr. Brano Grujic attended the meeting, himself, in Mali Zvornik, at the
6 meeting in the Jezero Hotel.
7 Q. When you -- well, what happened at this meeting?
8 A. At the meeting, they failed to reach any agreement. And after
9 returning back from the meeting, they informed us what had happened over
10 there, and Mr. Pasic and Mr. Kapidzic said that they had many unpleasant
11 situations there and that Arkan sort of slapped them, and that they had
12 to compile a written report to the effect that there were 7.000 Green
13 Berets in the town of Zvornik and that this was some kind of a Muslim
14 army that was a threat to the Serbs and instilled fear in them. However,
15 that was not true, not correct.
16 Q. Very well. On the 7th of April, 1992, did you see Colonel Tacic?
17 A. Yes. Yes. Colonel Tacic said that he was going to come to the
18 municipal building from Tuzla, and the chief gave me orders that I should
19 go there and escort Colonel Tacic from the first barricade, from the
20 Karakaj direction. I forget the name of the place, Tereze [phoen] or
21 something. Anyway, I escorted him to the municipal building, and then I
22 waited for the meeting to be over to escort him back to Tuzla. Now, in
23 -- well, I talked to Colonel Tacic while escorting him, and he asked me
24 what was going on. And I said, "Well, Colonel, I ought to ask you what
25 was going on, because I see that all the military equipment is here, all
Page 6996
1 the military weapons, so I assume you should know what's going on." But
2 he never answered my question.
3 Q. Just a point of detail. You told us that you took him to the
4 mayor. We mentioned Mali Zvornik a few moments ago. Do you mean the
5 mayor of Mali Zvornik or Zvornik?
6 A. Zvornik Municipality, headquarters in Zvornik, not Mali Zvornik.
7 Q. Very well. What time was it, approximately?
8 A. It was about, well, between 12.00 and 2.00 p.m. That's when he
9 arrived.
10 JUDGE ANTONETTI: [Interpretation] A point of detail that could be
11 important. You escorted Colonel Tacic, and after that you take him back
12 because he has to attend a meeting at the town hall or municipality.
13 When he tells you, "What is happening here," was it on the outbound
14 journey or when you went back?
15 THE WITNESS: [Interpretation] While we were arriving, because he,
16 himself, could not pass through that barricade, to begin with.
17 JUDGE ANTONETTI: [Interpretation] Right. So when he is saying,
18 "What is happening," did you have the feeling that he had no idea of what
19 was going on, or did he say that by the by and you felt that he was fully
20 informed? What was your feeling about this at that time? I mean, one
21 doesn't escort a colonel every day, so this is something which you
22 certainly remember.
23 THE WITNESS: [Interpretation] I think that he was having me on
24 that day. I think that he was in complete control of the situation, that
25 he had all the information, firsthand information, about what was going
Page 6997
1 on.
2 JUDGE ANTONETTI: [Interpretation] Well, let's assume that he
3 wanted to mislead or abuse you. Why do you think he wanted to do that?
4 Do you have any explanation for that?
5 THE WITNESS: [Interpretation] Perhaps he was afraid, he was
6 afraid. He certainly knew -- he knew the date of the attack, and the
7 organisation, and now he was coming to the center of town which was only
8 populated by the Muslims and police members at that point in time. So he
9 was coming into a centre where the Muslims were.
10 JUDGE ANTONETTI: [Interpretation] If what you say is true, if you
11 were moving into an area which was controlled by the Muslims, he might
12 have been risking his life. So what was the point of going there? Can
13 you tell us?
14 THE WITNESS: [Interpretation] I wasn't present at that meeting
15 held in the municipal building. It was the party presidents and
16 Abdulah Pasic and Brano Grujic who were there and the rest, from the
17 leadership of both sides, both political parties. Colonel Tacic had
18 already positioned his tanks at the bridge at Karakaj a long time ago,
19 and at the dam, Divic, so that he had all the information at his
20 disposal, and nothing could have happened without his knowing about it.
21 And before that, I set up patrols of our police force at the time and
22 members of the army so that together we could perform our duties and
23 provide security for vital facilities. So the army was included in all
24 that to a maximum degree and disposed of all the information.
25 JUDGE ANTONETTI: [Interpretation] Very well. Please proceed,
Page 6998
1 Mr. Dutertre.
2 MR. DUTERTRE: [Interpretation]
3 Q. Have I understood you correctly? You were there to ensure his
4 safety while he was in the Zvornik area, where only the Muslims were
5 left, the Bosnian were left?
6 A. [Previous translation continues] ... and I escorted him from the
7 barricade to the municipal building. Then I waited in front of the
8 municipal building after the meeting to take him back in the direction he
9 wanted to go. Of course, before the barricade. I wasn't able to go
10 through the barricade itself, because I would have run the risk of
11 danger, whereas it wasn't dangerous for him.
12 Q. Very well. Do you know who attended the meeting on the Bosnian
13 side at the town hall in the presence of Colonel Tacic?
14 A. Abdulah Pasic, the mayor; Alija Kapidzic was there. He was in
15 the Secretariat for National Defence. Brano Grujic was the president of
16 the Serbian Democratic Party, and Jovo Mijatovic, yes, Mijatovic, he was
17 the president of the executive powers of the Zvornik Municipality, the
18 Executive Council, and some other people on both sides whose names I
19 don't know, and there was my chief of my police station, Osman Mustafic.
20 JUDGE ANTONETTI: [Interpretation] Do we have a problem?
21 [Technical difficulties]
22 MR. DUTERTRE: [Interpretation] Very well. It's working again.
23 Thank you.
24 Q. I don't know if this was a translation issue. Did you say
25 "Mijatovic" or "Jovo Ivanovic?"
Page 6999
1 A. Ivanovic, Ivanovic.
2 Q. Very well. Did you discover what the outcome of this meeting
3 was? Did you discover what had been decided there?
4 A. The result of the meeting was nil. The meeting was expected to
5 reach an agreement, and to provide protection -- for the JNA to provide
6 protection, but since at that time there was strong pressure and
7 propaganda for the Serbian Democratic Party to be handed over power, and
8 that weapons be laid down and the town handed over, those were conditions
9 that were completely unacceptable at the time, and that's how the whole
10 thing ended, without any major decisions and results.
11 Q. What happened in the afternoon between Arkan and the negotiators
12 Pasic and Kapidzic?
13 A. At that meeting - that's what they called it - they told us, both
14 Pasic and Kapidzic, that Arkan on the occasion had slapped them around a
15 few times and placed a knife under their throats and provided a piece of
16 paper so they could write down certain statements, which they in fact did
17 do. And upon their return to the police station, they informed us about
18 this and said, "We did what we did under pressure."
19 Now, if you consider that they should be prosecuted, go ahead.
20 JUDGE ANTONETTI: [Interpretation] Witness, you mentioned Arkan.
21 Who was Arkan, in your eyes?
22 THE WITNESS: [Interpretation] Arkan was a man from amongst the
23 ranks of the Serb people who had proclaimed himself some kind of military
24 leader over there. He had a group of volunteers, and he went to various
25 battle fronts with them. And those who belonged to him were known as
Page 7000
1 Arkan's Tigers, his men were known as Arkan's Tigers.
2 JUDGE ANTONETTI: [Interpretation] Very well, thank you.
3 MR. DUTERTRE: [Interpretation]
4 Q. Could you clarify one point for us, please. Between Arkan and
5 the two negotiators, there was one meeting in the morning, one meeting in
6 the afternoon, is that right, or was there just one meeting? Could you
7 specify, please? We're still talking about the 7th of April, 1992.
8 A. I believe that there was just one meeting held, and that was the
9 first and the last one.
10 Q. Very well. How did the town mayor react to this meeting between
11 Arkan and the two negotiators; did he take any decision?
12 A. Upon returning from that meeting, the Crisis Staff met hastily in
13 order to inform us what transpired at the meeting. In view of the fact
14 that no conclusion or a decision could be taken that could actually
15 redress the situation and bring some sort of a solution, but only
16 featured pressures and ultimatums, it was these ultimatums that were
17 discussed at the Crisis Staff meeting.
18 One of the ultimatums was that by 10.00 on the next day, all arms
19 were to be laid down, that meaning the police had legal weapons and that
20 which had been collected by the Territorial Defence, and that authority
21 was to be handed over or that there would be war. Simply, the town had
22 to be abandoned. That was the option that we were confronted with, or
23 war.
24 Q. What option did the Crisis Staff take?
25 A. The Crisis Staff decided not to give in to the ultimatum, that
Page 7001
1 they would not lay down their arms, that we would defend the citizens,
2 the people and their property.
3 JUDGE ANTONETTI: [Interpretation] Witness, there was an ultimatum
4 on the 7th of April to disarm. This we understand. If I reminded you of
5 a date a few moments ago, this date was that of the 6th of April, when
6 Bosnia-Herzegovina had been recognised at that time, was this all
7 factored in by the Crisis Staff or not?
8 THE WITNESS: [Interpretation] He had in mind -- I have in mind
9 that Bosnia-Herzegovina had been recognised. Everybody knew this, but
10 one of the sides did not recognise that fact, nor does so today.
11 MR. DUTERTRE: [Interpretation] Thank you, Your Honour.
12 Q. Mr. Alic, I would like to address another issue now.
13 What happened on the 8th of April at 8.00 in the morning, please?
14 A. Yes. During -- for several days, I was in Zvornik all the time,
15 in the city of Zvornik, because I was unable to go home on account of the
16 barricades. I was literally cut off from my place of residence. I did
17 not live in Zvornik, so I was put up with my friends and spent nights in
18 different houses. Between the 7th and 8th, I slept at the house of the
19 mother-in-law of Mr. Mujic. It was only the police, the officer on duty,
20 who knew where we were spending the night. And sometime around 0100
21 hours on the 8th of April, 1992, they called us on the phone and told us,
22 "You should come to the police station immediately, as soon as possible,
23 because we have here four armed persons whom we have stopped and
24 arrested, deprived of liberty, at one of the barricades erected in the
25 city of Zvornik." They explained who it was -- I explained who it was,
Page 7002
1 and I explained what they should do in the police; namely, that all of
2 these people who had been deprived of liberty should be held in custody
3 separately in different offices in the presence of police guards, and
4 that they should wait for the morning hours until we came.
5 Q. Just a -- yes, fine. Let me take it one step at a time. What
6 was the ethnicity of these four men?
7 A. These four men were Serbs.
8 Q. In what car were they driving around in?
9 A. They were in a Mercedes passenger car.
10 Q. Where had this Mercedes been registered?
11 A. In Belgrade.
12 Q. I understand that they were all, the four of them, in the same
13 car. Is that right?
14 A. Yes, that's right.
15 Q. Where exactly were they arrested, if you know?
16 A. They were arrested at one of the barricades. The spot is called
17 Meterize. This is between the iron bridge on the Drina in Zvornik and
18 the bridge in Karakaj.
19 Q. Who was controlling this barricade?
20 A. This barricade was manned by citizens of Zvornik, Muslims by
21 ethnicity.
22 MR. DUTERTRE: [Interpretation] Your Honour, I would like to
23 display Exhibit number 7224, which is on the 65 ter list. This is a map.
24 Q. Mr. Alic, can you tell me whether you can see the location where
25 these four men were arrested on the map?
Page 7003
1 Perhaps Madam Usher can come and help the witness with the
2 pencil, if need be.
3 A. Well, all these little dots mark the city of Zvornik, so we would
4 have to actually identify the position of the iron bridge across the
5 Drina. That is in the city of Zvornik. And then from that, point back
6 in the direction of Karakaj. This is not a very precise map, in fact.
7 THE ACCUSED: [Interpretation] Objection. Judges, this is not a
8 sufficiently-large-scale map. It does not encompass all the points that
9 the Prosecutor asked about. We need a map that would cover a broader
10 area. One cannot see Karakaj on this map at all, nor can one see the
11 bridge in Karakaj, nor is the place marked where the Muslim barricade
12 was. Perhaps there are some dots, but it can't be seen, obviously.
13 MR. DUTERTRE: [Interpretation] Well, if it's not on the map, then
14 I'll move on to something else.
15 Q. What were these four men doing at this barricade where they were
16 arrested?
17 A. They had this task, and they proceeded with the intention of
18 meeting with some contact persons at the Jezero Hotel in Mali Zvornik.
19 But since they were did not -- were not familiar with the route, they
20 made a mistake and crossed at a previous crossing or made a previous
21 turn, so they crossed from the territory of Serbia into Bosnia, and
22 actually as they were looking around for a -- to find their bearings,
23 they actually came across -- ran across this barricade.
24 Q. Very well. And how do you know that; who told you?
25 A. In the early-morning hours, we arrived at the station, and I
Page 7004
1 personally talked to these people, and this they stated to me personally.
2 Q. What time did you reach the Zvornik police station?
3 A. This was sometime around 4.00 a.m., in the morning.
4 Q. And when you got there, had these men been searched?
5 A. Yes, they had been searched, and they were handcuffed with
6 regulation handcuffs.
7 Q. What objects had been taken off them after the search?
8 A. When I arrived at the station, everything that had been found on
9 them had been put on a table, on a desk in my office, and I saw the
10 weapons which they had. They had automatic rifles. They all had rounds
11 of ammunition; a combat kit, as it's called. They had short-barrelled
12 weapons, i.e., pistols. They had their IDs. They had strangulation
13 garrots. They had fingerless gloves, they had balaclavas, and this kind
14 of equipment which actually -- actually pointed to the conclusion that
15 they were headed for the front.
16 Q. You mentioned that you interrogated them. How much time did you
17 have to interrogate them ?
18 A. I interrogated them throughout the day, so I had other
19 businesses -- business to attend to. So actually I interrogated them on
20 a number of occasions, not just on one occasion.
21 Q. Until what time, approximately, during that day?
22 A. Until the afternoon hours, around 4.00 or 5.00 p.m.
23 Q. During these interrogations, did you gather them all together or
24 were they interrogated separately? Did you get any answers out of them
25 when you interrogated them?
Page 7005
1 A. Initially, I got different responses, different answers which did
2 not fit into my picture of the real truth. But as I said, I had several
3 interviews on several occasions, and when I put it all together, I got
4 the story that was expected and that was truthful, in fact.
5 Q. Very well. Out of these four people, were any of them relatives?
6 A. Yes. Of these four, two were brothers.
7 Q. I'd like to start with one of the two, the elder brother. How
8 old was he, approximately?
9 A. These two brothers, whose surname, I believe, was Vuckovic --
10 yes, it was Vuckovic, they were from the vicinity of Belgrade, or more
11 precisely Obrenovac, which is a suburb of Belgrade. Or more precisely
12 the place is called Umka. And the other brother was about 30 years old,
13 and the younger brother was around 26 or 27 years of age.
14 Q. Very well. For the time being, I would like to focus on the
15 elder brother. Do you remember that an ICTY investigator showed you some
16 photo boards in 1997?
17 A. Yes, I do remember.
18 MR. DUTERTRE: [Interpretation] Your Honour, I wish to display
19 number 65 ter 2524, page 2, please. Page 2. I would like to show page 2
20 of this document, please. This is in the court binder.
21 Perhaps we could place it on the ELMO to save time. Madam Usher,
22 could you perhaps try, please.
23 THE ACCUSED: [Interpretation] Judges, what is now shown on the
24 screen is something which cannot be shown to the witness for the
25 Prosecution. Photographs can be shown. If the witness does have any
Page 7006
1 problems with identification, well, then, remove this from the screen,
2 take it off.
3 JUDGE ANTONETTI: [Interpretation] I fully agree with that.
4 Mr. Dutertre, could you tell us where the photo spreads come
5 from.
6 MR. DUTERTRE: [Interpretation] Page 1, I didn't want it
7 displayed, and I can only agree with Mr. Seselj. As to the second page,
8 which I asked to be displayed, it's from a photo spread established by
9 the Tribunal and looked at by the witness during his second hearing in
10 1997.
11 Q. Mr. Alic, what you see here on the ELMO, is that part of the
12 photo spreads?
13 Can you narrow it down? Thank you.
14 Was it a photo spread shown to you?
15 A. Yes, it does -- it is.
16 Q. Your signature, bottom right?
17 A. Yes, I do recognise it.
18 Q. Did you recognise from the photo spread if anybody --
19 A. On the spread, I recognise the person under number 8.
20 Q. Who is that person?
21 A. That is one of the two men who had been arrested in the Zvornik
22 police station, and they are brothers. This is the older of the two
23 brothers, of the two Vuckovic brothers. I do not think but I claim, I
24 assilerate [as interpreted], that he had a nickname, Zuti.
25 Q. Very well. Circle number 08, and I'll come back to that.
Page 7007
1 A. [Marks]
2 MR. DUTERTRE: [Interpretation] I'd like to tender the photo
3 spread.
4 JUDGE ANTONETTI: [Interpretation] Registrar, a number.
5 THE REGISTRAR: Your Honours, that will be Exhibit P440.
6 MR. DUTERTRE: [Interpretation] Thank you.
7 I would now like to display a video clip from 65 ter 6059, clip
8 B, coming from the documentary film "Anatomy of a War Crime." Part of it
9 was tendered into evidence, but not that clip.
10 THE INTERPRETER: "Anatomy of a Crime by the Yellow Wasps."
11 Interpreter's correction.
12 THE ACCUSED: [Interpretation] I cannot hear a thing.
13 MR. DUTERTRE: [Interpretation] It's not what is said which I'm
14 interested in, but maybe you can show the clip again, the video again.
15 [Videotape played]
16 THE INTERPRETER: [Voiceover] "So that at first Slavonia was an
17 experience of pure defence of the place. It did not have an aggressive
18 character or anything like that. It was simply pure defence, setting up
19 the lines of defence."
20 MR. DUTERTRE: [Interpretation]
21 Q. Mr. Alic, who is the person speaking on the video?
22 A. This is the person that I circled, whose image I circled a minute
23 ago.
24 Q. Very well. What does "duty" mean?
25 JUDGE ANTONETTI: [Interpretation] Do you want to tender the
Page 7008
1 exhibit?
2 Registrar, a number for the video clip.
3 THE REGISTRAR: Your Honours, that will be Exhibit P441.
4 MR. DUTERTRE: [Interpretation]
5 Q. Mr. Alic, what does the term "Zuti" mean?
6 A. Zuti was his nickname.
7 Q. Is it the same thing as Zuco; is it two different ways of
8 pronouncing the same term?
9 A. Zuti or Zuco, it has the same meaning.
10 Q. What does it mean?
11 A. I don't know how he got his nickname, whether it was by the unit
12 that he belonged to, but when I saw him, he had long, lanky, greasy hair.
13 Whether it was blonde or not, maybe he got his nickname by his hair.
14 Q. Very well. Did he have a card of a member --
15 JUDGE ANTONETTI: [Interpretation] One detail. You've just said
16 he had long hair, but from the video or the picture, my feeling is he had
17 short hair. On picture number 8, the hair is extremely short, and on the
18 video it's short hair. So was it the unit members who had very long
19 hair? Why do you say that?
20 THE WITNESS: [Interpretation] I can speak concretely about these
21 two persons who were at the station. I wouldn't venture to say anything
22 about the rest of these individuals.
23 MR. DUTERTRE: [Interpretation]
24 Q. Did he have a card showing that he was a member of an
25 organisation whatsoever?
Page 7009
1 A. Yes. When we searched -- inspected the people, all the
2 documentation which they had on them was seized, and these two members
3 had identity cards, and I remember well they had double identity cards;
4 that is to say, in addition to identity cards which they had, they also
5 had other identification papers. First of all, they had the IDs of the
6 Serbian Chetnik Movement, that is, the Vuckovic brothers, and then they
7 also had IDs of the Serbian Radical Party. So both had both badges with
8 their particulars indicated in them, their photographs on them, and they
9 were duly stamped.
10 Q. Let's deal with the card -- membership card of the Serbian
11 Radical Party. Was it the first time you saw that card?
12 A. This is the first time I saw their newer identity cards, but the
13 older ones, which were marked on the front left side, there was written
14 "SCP," which meant the Serbian Chetnik Movement, and I believe they had
15 these IDs initially, and then later they changed the name for reasons
16 known to them.
17 Q. We'll come back to the explanation you've just provided.
18 Later on, did you have the opportunity to see other SRS
19 membership cards?
20 A. Later, I did have occasion to see that on soldiers that had been
21 taken prisoner. When they were taken prisoners, their IDs would be
22 seized, so I had occasion to see such identification papers.
23 Q. Was Zuco's SRS membership card identical, similar or different
24 from the other membership cards you saw later on?
25 A. I have underlined that these two brothers had double identity
Page 7010
1 cards. This second identity card which I saw was identical to the
2 identity cards that I had occasion to see later.
3 Q. For the purpose of clarity, the Zuco membership card was
4 identical to other SRS membership cards that you saw later on; did I
5 understand what you said correctly?
6 A. That's right.
7 Q. Line 8, page 12, I talked about the membership card of Zuco. It
8 doesn't appear on the transcript. Did you ask Zuco if it was his card,
9 membership card?
10 A. Yes, I did ask him, and as their photographs were inside, I
11 personally asked them whether they were the holders of these identity
12 cards, and they confirmed that, yes, they were.
13 Q. When you say "them," is it the two brothers?
14 A. Yes, that's right.
15 Q. Did you ask, to Zuco and his brother, whether they were members
16 of the SRSS?
17 A. Yes, I did ask them that.
18 JUDGE ANTONETTI: [Interpretation] The Judges scrutinize
19 everything, and we've just realised one thing, Mr. Dutertre. In the
20 written statement dating back to 1996 -- I'm checking whether it's the
21 right year. Yes, it is 1996. Page 5, English version, first paragraph,
22 top, these two brothers had identity cards from the Chetnik Movement.
23 The SRS is not mentioned. Why is it appearing now?
24 Look at the paragraph I'm mentioning.
25 MR. DUTERTRE: [Interpretation] I can only say the same thing
Page 7011
1 you're saying, Your Honour. Maybe you should ask the witness.
2 JUDGE ANTONETTI: [Interpretation] Mr. Witness, we're going to try
3 and jog your memory.
4 Back in 1996, a few years after the events, you mentioned those
5 two identity cards, but you said that they mentioned the Chetnik
6 Movement. Now it seems all of a sudden there's one card of the Chetnik
7 Movement and one card of the SRS.
8 MR. DUTERTRE: [Interpretation] Your Honour, page 4, 1, 2, 3, 4,
9 5 [indiscernible].
10 JUDGE ANTONETTI: [Interpretation] Do you have an explanation for
11 that? Are you sure that there was a card of the SRS?
12 THE WITNESS: [Interpretation] Absolutely certain.
13 THE ACCUSED: [Interpretation] Objection. Mr. President, I didn't
14 force you to notice this inter-react [as interpreted] but now don't allow
15 the Prosecutor to mislead you. It says here that they had an
16 identification of the Serbian Chetnik Movement, and then in brackets
17 "Seselj's Serbian Radical Party," which means they had one ID card of the
18 Serbian Chetnik Movement, and then the explanation is given, or
19 interpretation given, that it is the Serbian radical movement. That's
20 what it says here, so don't allow the Prosecution lead you astray. It is
21 obvious it is one ID card here, not two.
22 JUDGE ANTONETTI: [Interpretation] It would take a lot to mislead
23 me, but I'll check on what you've just said.
24 Mr. Dutertre, you were talking about page 4, paragraph 4 or 5?
25 No, page 4, paragraph 4.
Page 7012
1 MR. DUTERTRE: [Interpretation] So I read it out loud.
2 JUDGE ANTONETTI: [Interpretation] Very interesting, very
3 interesting.
4 Do you read English, Mr. Witness?
5 Well, in the English version, what is mentioned is cards from the
6 Serbian Chetnik Movement, and then between brackets "Seselj's Radical
7 Serbian Party." So I would need to check what appears in the B/C/S
8 version, which I do not have, to see whether the brackets were there as
9 well.
10 THE ACCUSED: [Interpretation] It's the same in Serbian,
11 Mr. President.
12 JUDGE ANTONETTI: [Interpretation] So who put that between
13 brackets? Did you tell the investigator, "Whenever it's the Chetnik
14 Movement, you have to say that it's Seselj's Serbian Radical Party," or
15 did you do that? Since you carried out crime investigation, you know
16 better than I do how things occur when you write out minutes. So who put
17 that mention in brackets? Was it your instructions or is it the
18 investigator's doing?
19 THE WITNESS: [Interpretation] In my statement, I said that two ID
20 cards existed, and that's the truth of it, that's correct. One ID said
21 "SCP" for "Serbian Chetnik Movement." That was one ID and that was
22 separate. The other ID card was of the Serbian Radical Party. That's
23 another type of ID. So it is true that they had double IDs.
24 Now, what it says there and how it was translated, I don't know.
25 I was answering questions just the way I am now.
Page 7013
1 THE ACCUSED: [Interpretation] Mr. President, take a look at the
2 statement that was given in 1997. Over there, this same witness says
3 that they carried ID cards which were issued by Seselj's paramilitaries,
4 so there's no Chetnik Movement or Serbian Radical Party. But once again
5 it is just one ID card, or membership card, rather, and you'll find that
6 on page 6 of the 1997 statement.
7 JUDGE ANTONETTI: [Interpretation] Very well. I do not have the
8 1997 statement. It wasn't provided to us by the Prosecution. But it
9 seems that there's still another version. You add the map -- the card,
10 sorry, by paramilitaries, whereas in the 1997, it wasn't indicated. So
11 it seems that a year later, you add the paramilitaries. How can you
12 account for that?
13 THE WITNESS: [Interpretation] Well, the paramilitaries -- of
14 course it was the paramilitary. The regular army was only the Yugoslav
15 Army. All the rest were paramilitaries.
16 JUDGE ANTONETTI: [Interpretation] Very well.
17 Move on, Mr. Dutertre. I was trying to clarify the matter. I'm
18 not sure I've succeeded, but I've tried.
19 MR. DUTERTRE: [Interpretation] Thank you, Your Honour.
20 Q. Did you ask Zuco whether he was a member of the SRS?
21 A. Yes, I did ask him, and he answered in the affirmative.
22 Q. Did you ask him whether he had an ideological leader?
23 A. Yes, I did ask him. And with those gentlemen -- I talked to
24 those gentlemen several times that day, and I asked them many questions,
25 but I didn't receive answers to them. And among other things, I asked
Page 7014
1 them, "Who is your main leader? Who is equipping you? Who provides the
2 logistics, the logistical support? Who is your liaison? How did you set
3 out? What was your objective? What did you have in mind?" I asked them
4 many of those questions, and they answered the way it says in my
5 statement.
6 THE ACCUSED: [Interpretation] Objection. I insist the witness
7 says what they answered, because there's none of that in his statement.
8 So all answers to all those questions, who their leader was, who equipped
9 them, and all the rest.
10 JUDGE ANTONETTI: [Interpretation] [Previous translation
11 continues] ... constantly interrupted. I believe the Prosecutor was
12 going to do that.
13 MR. DUTERTRE: [Interpretation] That's what I'm trying to do,
14 Your Honour, but I'll do it in the planned order, follow your order.
15 Q. So did you ask him who sent them to Zvornik?
16 A. Yes, I did, I asked them that. When I talked to them, I asked
17 them, "What is the reason for coming to Zvornik?" And they said that on
18 television, they had seen such news and footage according to which the
19 Serbs were jeopardized by the Muslims, and that they had their
20 organisations in several places, they had their headquarters, and were
21 sent by their superiors to contact the contact person who would meet
22 them. And I asked them, "Who is your leader," and they said,
23 "Mr. Seselj, the chief, the party chief." And I asked them, "Who
24 supplied logistic support, because you all have military equipment and
25 weapons." And they said they got it from the Yugoslav People's Army.
Page 7015
1 And I asked them how, and they said, "Well, our chiefs, our leaders, made
2 arrangements with some officers from the Yugoslav People's Army."
3 Q. I believe the answer actually answers all the questions I've
4 asked previously. Did you say with whom the agreement was signed with
5 the Yugoslav People's Army? You said "Our leaders, our chiefs." Did
6 they tell you who they were?
7 A. The main responsible person or leader was Mr. Seselj. Nobody
8 could have made any arrangements without him, without him giving his --
9 without him acquiescing, agreeing.
10 Q. Is did you ask Zuco whether the card from the Serbian Chetnik
11 Movement was his?
12 A. Yes, I did ask him, and he confirmed that by showing the
13 photograph that was inside the ID.
14 Q. I think you already answered that, but had you the opportunity to
15 see other membership cards of the Chetnik Serbian Movement?
16 A. Before that, I did see them.
17 Q. But Zuco's card, was it identical, similar, or different from
18 other Chetnik Movement cards you saw before?
19 A. The same.
20 JUDGE ANTONETTI: [Interpretation] Mr. Witness, we've already had
21 the opportunity to see investigation proceedings by the police, either in
22 Serbia, in Bosnia-Herzegovina, or Serbia, and based on my observations,
23 such investigations are not much different from investigations in my own
24 country. Therefore, when you interviewed those four people, did you
25 register or record the interviews on minutes, and were the objects seized
Page 7016
1 from them put under seal? How did that happen? Was it just a friendly
2 conversation for a few hours with four individuals?
3 THE WITNESS: [Interpretation] It was a proper official meeting,
4 and everything that we found on those people was taken away. And it was
5 my intention to compile a written report, although I'd already reported
6 the Tuzla Security Centre with our dispatch system, and the Ministry of
7 the Interior in Sarajevo, and the Republican SUP, I sent a telegram to
8 them, and I sought concrete instructions as to what I should do, because
9 at the time I was cut off from everybody, nobody could come and give me
10 assistance. And all the barricades around Zvornik, they were manned by
11 armed members belonging to different paramilitaries; and in fact the
12 conversation I had with them, I taped it, I recorded it, and it was my
13 intention to send the videotape to the then Republican television station
14 so that it could be shown on television and the news bulletin, so that
15 they could see what was going on, because in their statements they said
16 they had been duped, misled, tricked, that they had such-and-such an
17 agreement and set out with the intention of protecting the Serbs. But
18 when they saw everything, they said that they'd been tricked.
19 Now -- well, that's it. So all those membership cards, IDs,
20 permits that they carried on them -- they had different permits for
21 carrying weapons and moving around in the war zones unhindered, they had
22 in the station, and I had to leave the station under strong shelling, I
23 had to withdraw, and all that stayed there.
24 THE ACCUSED: [Interpretation] Mr. President, the Prosecution
25 never provided us with a copy of the dispatch which this person sent
Page 7017
1 allegedly to the Tuzla Security Service. It is possible that in Zvornik,
2 all the documentation was destroyed, but certainly not in Tuzla. So if
3 that dispatch was sent and if he told the Prosecution of all that, they
4 had to -- they must have found a copy of it.
5 THE WITNESS: [Interpretation] All the documentation is stored for
6 a period of ten years. After ten years, everything is destroyed. So
7 even if it did exist, it's been more than ten years, and all the
8 documents have since been destroyed.
9 JUDGE ANTONETTI: [Interpretation] So you're saying that you were
10 in Tuzla, the Ministry of Interior in Sarajevo, the SUP, and you've
11 recorded a videotape. Were you given any instruction or were you not
12 told anything?
13 THE WITNESS: [Interpretation] Yes, by phone, what I was able to
14 do by phone.
15 JUDGE ANTONETTI: [Interpretation] [Previous translation
16 continues] ... telephone?
17 THE WITNESS: [Interpretation] To investigate as much as possible
18 to see who these people were, because at first we didn't know who these
19 people were, we didn't know their intentions. And during the
20 interrogation during the day, we would learn new things, new information,
21 and after that certain people from Serbia were very interested and called
22 up and demanded that these people must be returned. We said that
23 these -- that they were important people, and they -- or, rather, they
24 said they were important people, and they said, "If you don't send us
25 those four people back to us, we'll kill the Muslims -- 20 Muslims that
Page 7018
1 we have in detention."
2 JUDGE ANTONETTI: [Interpretation] We're now being flooded with
3 information. Generally, when Judges start asking questions, we find out
4 quite a lot.
5 So you're saying that you received telephone calls from Serbia,
6 bringing some pressure to bear so that they would be released. Who was
7 calling from Serbia?
8 THE WITNESS: [Interpretation] Nobody talked to me, but they
9 talked to my colleague, Fuad Mujic. A man called Major Marko Pavlovic
10 rang up. That's how he introduced himself over the phone and he exerted
11 pressure. He talked to him. I didn't want to talk to this person,
12 Marko, and I didn't really don't know the man.
13 JUDGE ANTONETTI: [Interpretation] Just one last point of detail
14 before giving the floor back to Mr. Dutertre.
15 You said a number of things. Maybe I got this wrong, but you
16 said that these four individuals came for whatever reason and then
17 realised that they had been misled or that they hadn't been given the
18 right information. What did you mean by that?
19 THE WITNESS: [Interpretation] That's what they said, that
20 somebody had tricked them and that they set out with the intention of
21 assisting the Serb people, helping them, because they had information
22 saying that Serb people in Zvornik were under threat, that the Muslims
23 were setting fire to houses, raping and so on. And so in solidarity with
24 the Serb people, they set out to protect them, but when they arrived
25 there, they saw that this was not the case and they said that they were
Page 7019
1 tricked. And we said, "Who tricked you?" And they said, "Well, they
2 sent us from up there." They had their staffs or headquarters or
3 whatever in various locations from which they received those directives.
4 JUDGE ANTONETTI: [Interpretation] Mr. Dutertre.
5 MR. DUTERTRE: [Interpretation] Thank you, Your Honour.
6 Q. I would now like to move on to the second brother, Vuckovic. You
7 mentioned his name a few moments ago. He is a younger brother, and you
8 gave us his age, in approximate terms.
9 I would like to display Exhibit number 65 ter 2525, on page 2,
10 please. It's page 2 I would like to see and not page 1.
11 Mr. Alic, do you remember whether you were shown this photo
12 spread in 1997, when you gave a written statement? Do you recognise your
13 signature at the bottom of this document?
14 A. Yes, certainly.
15 THE ACCUSED: [Interpretation] Just a moment, please. Judges,
16 let's see that signature that Mr. Alic recognised. I didn't see it.
17 It's not here in front of me. I don't see it.
18 MR. DUTERTRE: [Interpretation] I think it's fairly easy to see,
19 but maybe --
20 THE ACCUSED: [Interpretation] I can see it.
21 MR. DUTERTRE: [Interpretation]
22 Q. Did you recognise anyone on this photo spread?
23 A. Yes, I did recognise number 6. He's one of the two men -- the
24 two brothers who were at the police station that day, and I think --
25 well, I don't think, I claim that this was the younger brother of the
Page 7020
1 Vuckovic brothers.
2 Q. Could you take the electronic pen and circle this person, draw a
3 circle around this person's picture?
4 A. [Marks]
5 JUDGE ANTONETTI: [Interpretation] Registrar, could we have a
6 number, please.
7 THE REGISTRAR: Your Honours, that will be Exhibit P442.
8 JUDGE ANTONETTI: [Interpretation] Madam Registrar, can I have the
9 countdown, please?
10 MR. DUTERTRE: [Interpretation] I would like to show 65 ter
11 number 6059. It's an excerpt from the same video clip, but has not been
12 tendered into evidence yet.
13 [Videotape played]
14 MR. DUTERTRE: [Interpretation] Can we show it again, please.
15 [Videotape played]
16 MR. DUTERTRE: [Interpretation]
17 Q. Mr. Alic, do you recognise the person who's standing in the
18 middle of the picture here, dressed in civilian clothes?
19 A. Yes, I do recognise him. That's the individual that I circled
20 the number 6.
21 MR. DUTERTRE: [Interpretation] Thank you.
22 I would like to tender this video clip into evidence, please,
23 Your Honours.
24 JUDGE ANTONETTI: [Interpretation] Mr. Dutertre, where does this
25 video clip come from?
Page 7021
1 MR. DUTERTRE: [Interpretation] As I told you, it's the
2 documentary called "The Yellow Wasps."
3 JUDGE ANTONETTI: [Interpretation] On this picture, Witness, which
4 you're discovering at the same time as we are - I don't know - but we
5 have the feeling that this gentleman is being handcuffed or somebody is
6 holding him by the arm. Who are the people wearing beret bearing an
7 insignia? Who are these people?
8 THE WITNESS: [Interpretation] I assume that they are the officers
9 of -- well, either members of the security service of the Detention Unit,
10 the prison, the police or whatever. We did not have that kind of thing
11 in --
12 JUDGE ANTONETTI: [Interpretation] From what prison, in what
13 country?
14 Mr. Dutertre, you've had one hour and 52 minutes.
15 MR. DUTERTRE: [Interpretation] Thank you, Your Honour.
16 Could I have an exhibit number for the video clip, please.
17 JUDGE ANTONETTI: [Interpretation] A number, please.
18 THE REGISTRAR: Your Honours, the video will become Exhibit P443.
19 JUDGE ANTONETTI: [Interpretation] Just a minute. I'm going to
20 put the question again, because my colleague has just told me that the
21 name of the country has not been recorded on the transcript, the name of
22 the country where this person seems to have been detained by some civil
23 servants.
24 Could you tell me which country this is?
25 THE WITNESS: [Interpretation] Are you asking me?
Page 7022
1 JUDGE ANTONETTI: [Interpretation] Yes.
2 THE WITNESS: [Interpretation] It's Serbia, the state of Serbia.
3 JUDGE ANTONETTI: [Interpretation] Very well.
4 MR. DUTERTRE: [Interpretation]
5 Q. Mr. Alic, did this person have a nickname, and if so, what was
6 it?
7 A. Both of the Vuckovic brothers had nicknames. The elder one had
8 the nickname of "Zuti," and the younger Vuckovic brother, and one we've
9 just seen, was "Repic," his nickname was "Repic."
10 Q. You anticipated my question. When did you find out that they
11 went by those nicknames?
12 A. When I talked to them, they did not tell me their nicknames.
13 However, on the 8th of April, late in the afternoon, they were exchanged.
14 They were taken back to Serbia. However, during that period, there
15 were -- well, the Muslim people would rally together in certain places,
16 locations, and those people appeared where the people were abused, they
17 took it out on the people, they would beat them up, and so these people
18 would refer to them as "Zuti" and "Repic." And I was told this by the
19 people who were exchanged from the camps and with whom I had official
20 interviews and sent them further on.
21 JUDGE ANTONETTI: [Interpretation] If you say that these were
22 exchanged, had you been given an order for them to be exchange?
23 THE WITNESS: [Interpretation] No, we didn't receive any
24 instructions or orders. The shelling of Zvornik began around 11.00, and
25 as time passed, there was more and more -- there was a fiercer -- the
Page 7023
1 attack became fiercer and fiercer. So at that point in time, as a police
2 officer, I remained alone in the station, and I tried, in all ways
3 possible, to protect the people, to protect the patients in hospital,
4 because the doctor had called me and asked for my assistance, and the
5 citizens called upon me, businessmen. People from the bank asked for my
6 assistance. They said, "They're coming in, they're looting, they're
7 destroying things." I couldn't do anything. However, my colleague, the
8 man who worked with me, he conducted an interview with Marko Pavlovic all
9 the time and reached an agreement without my knowledge or without
10 anybody's permission to escort those people across the Drinjaca dam, and
11 to hand them over, over there, and in return they would enable him to
12 have free passage through Serbia and into Germany and further on.
13 JUDGE ANTONETTI: [Interpretation] Very well. Mr. Dutertre.
14 MR. DUTERTRE: [Interpretation]
15 Q. You mentioned that some people who had been gathered in certain
16 locations mentioned "Zuti" and "Repic" to you. Could you tell me where
17 these people had been detained? Where had they been regrouped? Where
18 had these people come from?
19 A. They were the citizens of Zvornik who were Muslims, mostly, and
20 there was several locations, several venues where they would gather, and
21 those places were camps. One of those places was in the Municipal Court
22 in Zvornik, that building. Another was in the Standard factory. Another
23 was in an educational centre, another in Pilica, and many other places
24 where these camps existed, and where Bosniaks were, and where they were
25 mistreated in various ways, beaten, raped and so on.
Page 7024
1 Q. Could you make an effort and remember those other locations where
2 there were camps, as you say, and could you provide us as comprehensive
3 an answer as possible, please?
4 A. I've already said, at a number of locations in Zvornik. These
5 camps existed in several places. One of those places was in Liplje as
6 well, and subsequently I had an opportunity of talking to people from
7 Liplje because they were allowed to leave and exchanged, all of them.
8 And we took down their statements, we on free territory, of course. We
9 would talk to them and send them on further to certain other addresses.
10 Q. Do you remember any other names of camps which were given to you
11 by these people whom you interviewed?
12 A. They said that there was a camp in the Standard building in
13 Karakaj and the secondary school centre, that building, and in Drinjaca,
14 in Pilica, and many other places as well.
15 JUDGE ANTONETTI: [Interpretation] We will stop for now. You will
16 have 30 minutes left. So you will resume your examination-in-chief on
17 Tuesday. For the remaining 30 minutes, Mr. Seselj will have two and a
18 half hours for his cross-examination.
19 MR. DUTERTRE: [Interpretation] Would you allow me to put one last
20 question, which is connected to the previous one?
21 JUDGE ANTONETTI: [Interpretation] Well, yes, all right, put your
22 last question.
23 MR. DUTERTRE: [Interpretation]
24 Q. Mr. Alic, you mentioned having heard about these people called
25 "Repic" and "Zuco" by the people released. How did you establish a
Page 7025
1 connection between them and the people whom you had interrogated? How
2 did you find out that these were the two men you had interrogated?
3 A. [Previous translation continues] ... people who witnessed the
4 executions and who were subjected to torture described them in such great
5 detail that I realised straight away that that's who they were, because I
6 had spent whole days in the police building with them.
7 MR. DUTERTRE: [Interpretation] Thank you, Your Honour.
8 JUDGE ANTONETTI: [Interpretation] We shall resume the
9 examination-in-chief on Tuesday at 8.30, and the Witness Section will
10 escort you back into the courtroom on Tuesday.
11 --- Whereupon the hearing adjourned at 6.00 p.m.,
12 to be reconvened on Tuesday, the 20th day of
13 May, 2008, at 8.30 a.m.
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