Tribunal Criminal Tribunal for the Former Yugoslavia

Page 8553

 1                           Tuesday, 24 June 2008

 2                           [Open session]

 3                           [The accused entered court]

 4                           --- Upon commencing at 2.24 p.m.

 5             JUDGE ANTONETTI: [Interpretation] Madam Registrar, could you

 6     please call the case.

 7             THE REGISTRAR:  Good afternoon, Your Honours.  This is case

 8     number IT-03-67-T, the Prosecutor versus Vojislav Seselj.

 9             JUDGE ANTONETTI: [Interpretation] Thank you, Madam Registrar.

10             This is Tuesday, June 24th, 2008, and I greet the representatives

11     of the OTP, Mr. Seselj, as well as everyone helping us.

12             I will first ask Madam Registrar to move to closed session,

13     please, or private session.

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Page 8554











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Page 8572

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18                           [Open session]

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

20             MR. FERRARA:

21        Q.   Where were you living in 1992?

22        A.   Sarajevo.

23        Q.   What area of Sarajevo?

24        A.   Grbavica.

25             MR. FERRARA:  Madam Registrar, can we please see the map with the

Page 8573

 1     number 4265 on the screen.

 2        Q.   Mr. Witness, can you mark on this map the location of Grbavica?

 3     The usher can help you.

 4        A.   This is where Grbavica is [indicating].

 5        Q.   Can you make a big circle?

 6        A.   [Marks].  Yes, now I've done it.

 7        Q.   Can you put an "A"?

 8        A.   [Marks]

 9        Q.   When did armoured groups arrive in Grbavica?

10        A.   In April, the JNA arrived with tanks and personnel carriers.  It

11     was around the end of April, and they were there in May.

12        Q.   Did you know where these JNA members lived during the time in

13     Grbavica?

14        A.   According to my information, in May there were seven corps in

15     Bosnia-Herzegovina.  At least that's what the media reported.  Two corps

16     arrived from Croatia, one from Slovenia.  Three were from

17     Bosnia-Herzegovina, and allegedly 2 Corps, the Ulica Corps and the

18     Novi Sad Corps also arrived, so that in Bosnia-Herzegovina there was now

19     a very large presence of the JNA.

20        Q.   Did you know the name of the commanding officer of the JNA unit

21     that was in Grbavica in that period?

22        A.   Yes.  The Sarajevo Romanija Brigade was there, to the best of my

23     knowledge, and its commander was Zoran Petrovic.

24        Q.   Was there a time when another armoured group, in addition to the

25     JNA, arrived in Grbavica?

Page 8574

 1        A.   Yes.  The Territorial Defence arrived.  That's what they were

 2     called, the Territorial Defence of the Srpska Republic.  They were

 3     already beginning to mention that, and they were there with units of the

 4     JNA.

 5        Q.   Do you remember what other groups arrived in Grbavica?

 6        A.   Yes.  To the best of my knowledge, after that, Chetniks or

 7     Seselj's men arrived.  People referred to them both ways, as Seselj's men

 8     and as Chetniks.  They arrived around the end of May.

 9        Q.   Did you observe personally these new groups arriving in Grbavica?

10        A.   Yes.  Grbavica is not a large area.  It's a rather densely-packed

11     neighbourhood, so it was easy to recognise the units that arrived in

12     Grbavica.

13        Q.   How were you able to identify these additional armed groups in

14     addition to the JNA?

15        A.   Quite simply, you could see that.  It was a small area.  You

16     could see how they were dressed.  The JNA had olive-grey -- olive-drab

17     uniforms.  The Territorials wore whatever they had, and the Chetniks

18     likewise.  But afterwards, they got camouflage uniforms, and so did the

19     JNA.  But we knew who was who.

20        Q.   Can you describe any distinctive marks or insignias that they

21     were wearing?  I'm referring to the Chetniks.

22        A.   For the most part, we could tell who the Chetniks were because

23     they had long hair and beards, and at that time they wore subara hats

24     with a cockade.  The JNA was transformed into the Serbian Army.  They had

25     equipment, and everyone knew this was the so-called Army of Republika

Page 8575

 1     Srpska.

 2        Q.   Did you and your wife remain in Grbavica at the time this armed

 3     force arrived?

 4        A.   Yes.  My wife was ill, and she's still ill today.  She is an

 5     invalid, and I wasn't able to leave our flat or take us out, and I

 6     couldn't because Grbavica had already been blocked by the beginning of

 7     May.  You couldn't go across the Miljetska River.

 8        Q.   Were you visited by any members of these armed groups present in

 9     Grbavica?

10        A.   Yes.  They would come at the beginning, some sort of military

11     police, and there were tanks around there and APCs, military vehicles,

12     and they went looking for weapons in the flats.  But I have to tell you

13     the truth here.  They would first of all take a look at the flat and see

14     whether it was any good, whether the flat was nicely furnished and things

15     like that.

16        Q.   So why did they come?

17        A.   Most of the citizens were leaving Grbavica and crossed when they

18     were able to, and left their flats empty, and so what happened, quite

19     simply, was that looting took place.  People drove away everything that

20     was worth anything from the flats.

21        Q.   What does it mean, "people drove away"?  What kind of people?

22        A.   Mostly Croats, Bosniaks and others.  The Serbs didn't.  They

23     stayed at Grbavica.

24        Q.   Did you observe any looting committed by members of the JNA?

25        A.   Unfortunately -- well, at the beginning they defended this from

Page 8576

 1     happening, they prevented it from happening, but then later on, when the

 2     Army of the Srpska Republic was formed, they started taking things of

 3     value out too, anything that was worth anything.

 4        Q.   What kind of goods did they used to take away?

 5        A.   White goods, first of all, television sets, video recorders, that

 6     kind of thing, household appliances, washing machines and all the rest,

 7     any other equipment as well as furnishings, furniture too.  Anything that

 8     was worth anything.

 9        Q.   Did you observe any looting committed by members of another group

10     present in Grbavica, in addition to the JNA members?

11        A.   Well, it was difficult.  When the Army of Republika Srpska was

12     being formed, it was difficult to distinguish who was doing the looting,

13     but I have to say that mostly they were vehicles from Uzice, as well as

14     Sabac, Belgrade, [indiscernible], and Novi Sad, so that means that

15     anybody who was able to, who had facilities and had weapons, too, would

16     take the things away, drive them away.  And once they took anything that

17     was worth anything from the flats that had been left empty, left vacant,

18     then they would take the electricity meters as well from the apartment

19     blocks, and the gas appliances as well.

20        Q.   When you say "they," who are you referring to?

21        A.   The soldiers, mostly.  And I have to mention that I personally

22     saw a whole truckload of electric meters, electricity meters, and it said

23     on it that it was private property and that they could take it out,

24     export it, because the municipality was on Grbavica, too, close to where

25     I live.

Page 8577

 1        Q.   Who was stealing this electric matters -- electricity matters?

 2        A.   Well, the soldiers would do that in the evening, when nobody was

 3     allowed to go outside.  Then they would come 'round, and people who knew

 4     how to take the electricity meters off the walls would do that, and also

 5     the gas appliances.

 6             And if I might add, they took all the cars away first, all the

 7     cars out in the streets.  They drove them away.  Some of them were loaded

 8     up onto trucks and driven away.  And when there were no more cars in the

 9     streets, they would take the garage doors down and take anything that

10     might have been left in the garages.

11        Q.   Did you know what area of Grbavica the Chetniks occupied during

12     this time?

13        A.   As far as I know, the Chetniks had their sectors or areas.

14     Ljubljanska Street, for example, Radnicka Street, Beogradska Street,

15     parts of Zagrebacka Street.  That's where they were positioned mostly,

16     and by the Jewish cemetery.

17        Q.   Are these streets in the same area marked on the map?

18        A.   Yes.

19        Q.   Did you know if the Chetniks carried out any activities on the

20     street you just mentioned?

21        A.   Well, they held that general area.  They had it under their

22     control, and the citizens who were non-Serbs and who had withdrawn from

23     the area left vacant flats and houses, so probably they engaged in that

24     too.

25        Q.   Engaged in what; in looting?

Page 8578

 1        A.   Well, yes, yes.

 2        Q.   Did you observe this looting committed by the Chetniks?

 3        A.   No, I didn't have an opportunity of seeing that, because I was in

 4     a work platoon on the other side.

 5        Q.   Did you ever go to the municipal building in Novo Sarajevo around

 6     the time of this looting?

 7        A.   Well, yes.

 8        Q.   What did you see there?

 9        A.   All I saw was that permits were issued or, rather, certificates

10     that the goods that had been loaded up onto the trucks belonged to those

11     people, and these certificates were issued by the president of the

12     municipality and probably other clerks too, because for a time, I worked

13     on moving the documents of the Agricultural Faculty to another place

14     because the faculty had been set fire to.

15        Q.   Who was signing these documents?

16        A.   Mostly, the president of the Executive Board and other employees

17     who were authorised to do that.

18        Q.   Do you know his name, the name of this president of the Municipal

19     Board?

20        A.   Well, I must say that I remembered his name, but I know that they

21     killed the president of the Executive Board of the Municipality of

22     Novo Sarajevo, and a new person was appointed to replace him.  I did know

23     the surname, but I've just forgotten it.  I can't remember it just now.

24        Q.   Who was receiving the signed documents; soldiers, Chetniks, the

25     to members?

Page 8579

 1        A.   As far as I know, well, it was handed out, but I don't know

 2     whether the Chetniks obeyed Zoran Petrovic's command.  As for the other

 3     units, they did obey.  I don't know whether the Chetniks did or not and

 4     what the relationship was between the commander of the brigade, of the

 5     Sarajevo Romanija Brigade, and the Chetniks.

 6        Q.   I'm referring to the document that certificated that looted goods

 7     belonged to the soldiers, or the other people that looted these goods.

 8        A.   They were documents which were issued so that people could take

 9     the goods away, because if they were being transported to Novi Sad, for

10     example, and there was the border between Serbia and the Serbian

11     Republic, they had to have a document, and this document was issued at

12     the municipality building of Novo Sarajevo, with its seat in Grbavica.

13        Q.   And issued to who?

14        A.   The soldiers who had loaded up their trucks for transport.

15        Q.   What do you mean when you say "soldiers"?

16        A.   Well, soldiers of the Serbian Republic.

17        Q.   So you're referring only to soldiers of the former JNA or other

18     members of the army group you described before?

19        A.   Everybody who was there was within the composition of the Serbian

20     Republic, the Army of the Serbian Republic in Bosnia and Herzegovina.

21        Q.   Do you consider -- so do you consider part of the Army of the

22     Serbian Republic in Bosnia-Herzegovina also the volunteers?  According to

23     your knowledge, of course.

24        A.   Yes.

25        Q.   Did anything change in your living circumstances around --

Page 8580

 1             JUDGE ANTONETTI: [Interpretation] Mr. Ferrara, just a minute.

 2             Witness, the Prosecution is talking about volunteers, and you

 3     answer, "Yes."  But according to you, what is a volunteer?

 4             THE WITNESS: [Interpretation] Which volunteers do you mean?

 5             JUDGE ANTONETTI: [Interpretation] Yes, justly so.  That's the

 6     question.

 7             The Prosecution, Mr. Ferrara, has asked you whether they were

 8     soldiers from the Republic of Srpska and also volunteers, and you say,

 9     "Yes."  Therefore, I wonder.  If I understood you correctly, there's the

10     JNA, there's also the Territorial Defence of Republika Srpska, and there

11     are Chetniks.  And you also add "Seselj's men."  So there's a lot of

12     people on the ground, and we don't really know who does what.  But among

13     all these people on the ground, is there a category of people that can be

14     called "volunteers"?

15             THE WITNESS: [Interpretation] I think that there were many

16     volunteers.  You've asked the right question.  Now, as far as the

17     volunteers are concerned, you couldn't know who was mobilised and who was

18     not, but you had the Serbian Republic, the Serbian Republic existed, and

19     in May it already had an Army of the Serbian Republic; and all those who

20     were in Bosnia-Herzegovina, which was occupied by the JNA and other

21     units, including, therefore, the Chetniks and the JNA, at the end of May

22     they became one army.

23             JUDGE ANTONETTI: [Interpretation] Very well.  So at the end of

24     May, there was only one army; i.e., the Army of Republika Srpska?

25             THE WITNESS: [Interpretation] Yes.

Page 8581

 1             JUDGE ANTONETTI: [Interpretation] Very well.  The Chetniks and

 2     Seselj's men were then part of the VRS, in the VRS?

 3             THE WITNESS: [Interpretation] As far as I know, they should have

 4     been under the command of one commander.  Now, what it was like over

 5     there, I can't really know that, nor did I know that.

 6             JUDGE ANTONETTI: [Interpretation] What about the JNA, what did

 7     they do, the soldiers from the JNA?  What did they do?  Did they leave

 8     for Serbia?  Did they stay on the ground?  Did they change their uniform?

 9     Did they change their insignia?  To your knowledge, what happened to

10     them, to soldiers of the JNA?

11             THE WITNESS: [Interpretation] Quite simply, they turned into the

12     JNA at the beginning of May, or, rather, it had already become the Army

13     of the Serbian Republic, and so they were issued with camouflage uniforms

14     and you couldn't distinguish them anymore.  There was no JNA anymore, it

15     didn't exist as such anymore, and the Territorial Defence was united,

16     too.  And I have to say, and that can be proved, in Gornji Miletici,

17     there were Russians and Greeks and Ukrainians.  There were Russians, yes.

18     And mostly from Serbia, whether they were volunteers or whether they had

19     been mobilised, I didn't know that, nor could anybody have know that, who

20     had been mobilised and who was a volunteer.

21             JUDGE ANTONETTI: [Interpretation] Last question.  You said that

22     there were army corps, two that come back from Croatia and one from

23     Slovenia, so let's talk about this corps which came back from Slovenia.

24             I assume that the soldiers in these army corps who had been sent

25     to Slovenia included Serbs, maybe Serbs from Belgrade.  And then these

Page 8582

 1     people in Grbavica, and there's this transformation into the VRS, so did

 2     these people stay and then just put on the uniform of the VRS, or did

 3     they go back to Belgrade, if of course they came from Belgrade, or did

 4     everyone stay in Sarajevo, but with another label, if I could say so, no

 5     longer labelled "JNA" but now labelled "VRS," as far as you saw?  What

 6     did you think?

 7             THE WITNESS: [Interpretation] Well, you couldn't know who went

 8     where.  They came to Bosnia-Herzegovina, and they were deployed wherever

 9     needed, attached to a command or the authorities of the Serbian Republic,

10     in actual fact.

11             JUDGE ANTONETTI: [Interpretation] That's all you can say.  Thank

12     you.

13             Mr. Ferrara, you have five minutes before the break.

14             MR. FERRARA:  Thank you, Your Honour.

15        Q.   Did you ever see members of the Seselj's men looting an

16     apartment?

17        A.   I did not have an opportunity -- well, I wasn't in the area at

18     all.  I was elsewhere, in another part of Grbavica.  I was digging

19     trenches and constructing bunkers for the defence, so I wasn't there

20     where they were stationed.  So I couldn't have seen any of it, but most

21     probably they, too, were incorporated into the system of taking away any

22     valuables.

23        Q.   When did you start digging trenches and constructing bunkers?

24        A.   Well, I started already in June, and I did what I was ordered to

25     do.  I did some cleaning.  I cleaned the streets, to begin with.  Then I

Page 8583

 1     took out books from the Faculty of Agriculture.  Then they said that I

 2     should dig trenches and erect bunkers in various parts where the army

 3     was, the Army of the Serbian Republic.

 4             JUDGE ANTONETTI: [Interpretation] You say "they," "they."  We

 5     would like to know who these "they" are.  That's the whole problem.  I'm

 6     sure that Mr. Ferrara was about to ask you that, but I'll give him the

 7     floor.

 8             MR. FERRARA:

 9        Q.   Who are they when you say "they"?

10        A.   I mean the Army of the Serbian Republic.  Now, who issued the

11     orders, the actual orders, well, we had -- I've forgotten the first and

12     last name.  I hope you don't mind if I ask you.  You have the names.  He

13     was, I think, Zeljko Mitrovic, the person who ordered us.  They called

14     him Dilmar, "Dilmar" with a "D."

15        Q.   When were you assigned --

16        A.   At the end of June 1992.

17        Q.   Can you describe how it happened?

18        A.   Well, a soldier came by.  Quite simply, he knocked on the door

19     and said, "Come on, go and do some digging, some trench digging along the

20     Miljetska River."

21        Q.   Could you have refuse this assignment?

22        A.   The person had a rifle.  You couldn't say you didn't want to.

23     You had to work.

24             MR. FERRARA:  Your Honours, maybe it's time for the break.

25             JUDGE ANTONETTI: [Interpretation] Very well.  We will have a

Page 8584

 1     20-minute break.

 2                           --- Recess taken at 3.45 p.m.

 3                           --- On resuming at 4.07 p.m.

 4             JUDGE ANTONETTI: [Interpretation] [No interpretation]

 5             MR. FERRARA:  Thank you, Your Honour.

 6             JUDGE ANTONETTI: [Interpretation] Proceed.

 7             MR. FERRARA:

 8        Q.   So, Mr. Witness, did this VRS soldier take you somewhere upon

 9     assigning you to a work platoon, and where?

10        A.   Yes.  He took me to where the people were already working in the

11     work platoon, Grbavicka Street by the Miljetska River, which is where the

12     trenches were being dug and the bunkers erected.

13        Q.   Who told you to work there?

14        A.   You see, you never knew the first and last names of these people.

15     They all had nicknames.  The soldier would tell you, "You're going to do

16     such-and-such work," and then he would obey that because you had no

17     choice.

18        Q.   How many people were working in this bunker on Grbavicka Street?

19        A.   It depended.  Sometimes there were four or five, sometimes three,

20     sometimes more, depending on how much work had to be done.

21        Q.   Were there only men or also women?

22        A.   Only men.  Only men did the digging of trenches and made the

23     bunkers.

24        Q.   Were there any women among the other workers, not digging trench

25     but other kind of work?

Page 8585

 1        A.   The women were used to work in farming around Trnovo.  The place

 2     is called Kijevo, actually.  But that was in 1993.

 3        Q.   Until when?  When did your experience as a forced worker end?

 4        A.   From June 1992 until November 1994.

 5        Q.   Who was in charge of organising these work platoons?

 6        A.   I think it was the Command of the Army of Serbia, the Sarajevo

 7     Romanija Brigade and their commander, and we would be deployed by

 8     Mitrovic, the man I mentioned a moment ago.  He would decide who was

 9     going to go where.  Every morning at 7.00, you had to be at a certain

10     place, and then you were sent off to work somewhere.

11        Q.   From 7.00 until when you were forced to work?

12        A.   Well, the time wasn't limited.  We would work at night, too.

13        Q.   Were you paid for the labours you made?

14        A.   We were just given breakfast -- or, no, I'm sorry, I mean lunch.

15     We weren't paid at all.  A Frenchman asked me on one occasion how much

16     they paid me for the work, and I just laughed and said, "You don't

17     understand a thing."  And then he laughed too.

18        Q.   In your estimation as a member of the work platoon, how many

19     people were engaged in forced labour during the war in Grbavica?

20        A.   Well, I don't think even Mitrovic knew how many people were

21     working, because people were working in different places so nobody knew

22     exactly who was doing what, where.

23        Q.   What was the ethnicity of these workers?

24        A.   They were mostly Bosniaks and Croats.

25        Q.   Did you ever see any Serbs working in this, digging trench, or

Page 8586

 1     building bunkers, or something like this?

 2        A.   No, no, I didn't.  I didn't see Serbs.  They were in the army,

 3     and the others who were over the age of 60 or 65, they weren't

 4     co-opted at all.  Now as far as the Bosniaks and Croats were concerned,

 5     there were people 70 years old working on the trenches and bunkers.

 6        Q.   Did you hear other Muslims from Bosnia and Herzegovina being

 7     forced to work, so not totally from Grbavica?

 8        A.   Yes.  I did meet people who were brought in from Doboj and

 9     Teslic, for example, as well as from Jajce.  They brought in Bosniaks and

10     Croats from there to do labour at Grbavica, to dig trenches and work on

11     the bunkers.

12        Q.   Do you remember what did you discuss with these people from

13     Teslic and Doboj?

14        A.   We didn't have anything to discuss.  Everybody was given an

15     assign, to go and dig trenches and to help make the bunkers.  They didn't

16     allow us to talk.  There was always a soldier present, and he kept making

17     us work as quickly and as well as possible.

18        Q.   Do you remember the name of the locations where you were forced

19     to work in this period between August 1992 and November 1994?

20        A.   Most often, I worked near the Zeljeznicar Soccer Club playing

21     field.  Another location was along the Miljetska River in Grbavicka.  I

22     also went to chop wood in the woods for firewood in the winter, and also

23     for dugouts to be constructed from the timber we brought in from Trebevic

24     and other areas.  Mostly, I went to Trebevic.  I didn't go any further.

25        Q.   For what armoured groups did you perform the forced labours, only

Page 8587

 1     for the JNA and also for the VRS and also for other groups?

 2        A.   Well, now we have to put together the JNA and the Territorial

 3     Defence.  As of the end of May 1992, they were one and the same army.  We

 4     were working for the Army of the Serbian Republic, the Srpska Republic.

 5        Q.   Were you assigned to work somewhere in May 1993, and where, if

 6     you remember?

 7        A.   It's hard to recall dates now.  I worked where I was assigned to

 8     work.  For a time, I worked in a place overlooking the Jewish cemetery.

 9     I don't know the name of the place, but I know there's a hill up there

10     overlooking the Jewish cemetery.  That was in 1994, in fact.

11        Q.   When you worked in the -- near the Jewish cemetery, did you see

12     any members of Chetniks nearby?

13        A.   No, I didn't have any contact with them, but I did see them

14     passing by.  There was a pub of sorts called "Chetnik" there, and that's

15     where we were digging this huge dugout, and we would see them sitting in

16     that pub called "Chetnik."

17        Q.   How did you know that these men were Chetniks?

18        A.   Well, that was their area of combat, and we could tell by their

19     clothes and their behaviour.  They wore the sajkaca cap or the subara

20     cap, for the most part, and they mostly gathered around that pub.  They

21     would pass by it on their way to the battle lines, and that's where we

22     would see them.

23        Q.   What was your task at this cemetery?

24        A.   It was overlooking the cemetery, not in the cemetery itself.  Our

25     task was to dig a dugout and to fortify the position there so that

Page 8588

 1     soldiers could take up positions there and they could fire from that

 2     dugout.

 3        Q.   Do you know who -- sorry.  Do you know who used this position,

 4     which group?

 5        A.   I don't know.  I don't have any information on who the dugout

 6     belonged to.  I was told we were digging it for the Chetniks, but whether

 7     there were actually Chetniks in it after we left, I really don't know.

 8        Q.   Did you see Chetniks using this position?  What kind of position

 9     were there?

10        A.   I didn't see Chetniks at that position because it was completed

11     only after I left.  It still couldn't be used while I was there.  Quite

12     simply, it had a good view of the center of Sarajevo.  From that dugout,

13     you had an excellent view of the center of Sarajevo.

14        Q.   Who was controlling that area where you [indiscernible] this

15     position?

16        A.   Well, that area belonged to the Chetniks.  It was overlooking the

17     Jewish cemetery, and that was held by the Chetniks, that line.

18        Q.   When you were working there, did you ever hear any stories about

19     activities committed by the Seselj men in these parts of Grbavica?

20        A.   Well, the non-Serbs withdrew from that area, so we had no

21     contacts, no one to talk to, so we couldn't find out what was going on

22     there.

23        Q.   I want to refresh your memory on this point, reading the

24     statement you gave to the ICTY investigator on 15/16 June 2004.  It's

25     paragraph 9, at the end of the paragraph.  You declare -- you say in this

Page 8589

 1     statement:

 2             "In the area of control of Seseljevci in Grbavica, which are the

 3     streets mentioned earlier in my statement, and also the area which is

 4     located below the Jewish cemetery, we would hear story that some people

 5     living in these parts of the town were found killed and slaughtered.

 6     This kind of killing was very characteristic of the way the Seseljevci

 7     would kill.  No investigation was ever done about these killings."

 8        A.   Please, whoever was killed, there was never any investigation,

 9     regardless of whether they were killed by Chetniks or other soldiers.  If

10     someone was killed, they would just say, "Sniper."  That's what they

11     would write down.  And all those who were killed were buried in

12     Donji Miletici.  There was no investigation, nor was any question put to

13     who killed the person and how.

14        Q.   My question was another one.  Do you remember any story that you

15     heard about the behaviour of the Seseljevci in Grbavica?

16             THE ACCUSED: [Interpretation] Objection.  The witness is being

17     asked to speculate twice, whether he heard rumours and whether he

18     remembers what rumours were going 'round.  The witness is testifying to

19     what happened to him.  That's his role in these proceedings, so he should

20     not be made to say things on the basis of hearsay.  The witness is

21     telling us his difficult and quite understandable life experience, so

22     this kind of leading question should not be put by the Prosecutor to get

23     the witness to say what he wants him to say.

24             JUDGE ANTONETTI: [Interpretation] Yes, but as far as rumours are

25     concerned or hearsay, Mr. Seselj, the Trial Chamber holds that a hearsay

Page 8590

 1     piece of evidence can be termed evidence.  In certain situations, we only

 2     have hearsay.

 3             I shall try to solve the question in the following manner:  Sir,

 4     you were asked to do forced labour.  This was in 1992.  You, yourself, at

 5     the time, did the name of Mr. Seselj ring a bell?  Had you heard of the

 6     name already then or not?  I'm not talking about today; I'm talking about

 7     at the time.

 8             THE WITNESS: [Interpretation] I never had any contacts with

 9     Seselj.  We never met, nor did we have any contacts, but I did hear about

10     Seselj, that he was organising Chetniks and that he was the chief Chetnik

11     vojvoda in the former Yugoslavia.  I did hear that.  That's nothing new.

12             JUDGE ANTONETTI: [Interpretation] So in 1992, you had heard about

13     this.  The so-called Seselj's men, these were people who told you --

14     well, some people told you that there were Seselj's men in town; is that

15     it?

16             THE WITNESS: [Interpretation] Yes, towards the end of May 1992.

17     That's when they started turning up at Grbavica.

18             JUDGE ANTONETTI: [Interpretation] You, yourself, did you see any?

19     From what I understand, you saw some with your own eyes, didn't you?

20             THE WITNESS: [Interpretation] Yes, I did, as I was passing by.

21             JUDGE ANTONETTI: [Interpretation] And as far as you remember -- I

22     know it's very difficult to remember what happened 15 years back, but as

23     far as you remember, if you can, these individuals were disciplined,

24     undisciplined, in your eyes?  What feeling did you have about this?

25             THE WITNESS: [Interpretation] I only saw them in passing.  I

Page 8591

 1     never had any contacts with them.  I didn't speak to them, and they

 2     didn't speak to me, and I think that was best for me.

 3             JUDGE ANTONETTI: [Interpretation] You can't say anything.

 4             Very well, Mr. Ferrara, please proceed.

 5             MR. FERRARA:  Thank you, Your Honour.

 6        Q.   Do you know who was the commander of the Seselj men in that part

 7     of Sarajevo?

 8        A.   Yes.  He was well known.  Aleksic, he was the commander.  We knew

 9     that he had been appointed by Seselj as the main commander of the

10     Chetniks at Grbavica, and he was the one who issued orders.

11        Q.   Did you see him?

12        A.   Yes, I did.

13        Q.   Can you describe him?

14        A.   He was of medium height, as I saw him.  He wore a very big beard,

15     and he had a lot of hair.  He wore a subara cap at the time I saw him.

16        Q.   Where did you see him during the war?

17        A.   Well, I would see him in the street, always in passing.  I would

18     be going to the work platoon, and he was the commander there, and he

19     walked around wherever he wanted.

20             THE ACCUSED: [Interpretation] Judges, I have an important

21     objection to make.

22             The Prosecutor has been jogging the witness's memory, reminding

23     him of his statement in 2004, but you know that it was the Prosecutor's

24     Office that wrote this statement after the witness interview and that the

25     witness heard it read out to him and then signed it after the interview.

Page 8592

 1     And he said it was said that they heard stories about people from that

 2     part of town who were found killed or slaughtered.  The Prosecutor

 3     insisted on that, jogging the witness's memory, because the witness

 4     didn't say that in his oral testimony.

 5             However, today I received the proofing notes for this witness, in

 6     which it says the following:

 7             "The witness wishes to clarify that he never used the word

 8     'slaughtered,' only 'killed.'"

 9             The witness wished to underline that these murdered had never

10     been investigated.  So please don't allow the Prosecutor to do what he's

11     doing.  He has the witness's correction from the proofing, saying that

12     these people had been killed and no investigation was carried out, and

13     the witness denied using the word "slaughtered."  If someone was killed

14     by a sniper or by a shotgun, one can say that he was killed by a sniper.

15     But if someone's throat was cut, if he was slaughtered, you can't say he

16     was killed by a sniper, and yet the Prosecutor is again insisting on

17     putting these questions to get the witness to use the word "slaughtered."

18     I think that should not be allowed.

19             JUDGE ANTONETTI: [Interpretation] Mr. Seselj, the moment you took

20     the floor, I thought I had understood that Mr. Ferrara wanted to ask the

21     witness whether he had met or seen Slavko Aleksic, and the witness was

22     answering affirmatively when you took the floor.  So maybe I'm mistaken,

23     but I don't think that the Prosecutor was talking about slaughtering or

24     the difference between being slaughtered and being killed.

25             Mr. Ferrara, did you ask a question on slitting throats?

Page 8593

 1             MR. FERRARA:  Your Honour, I didn't ask any question.  I

 2     refreshed the memory of the witness, reading exactly what he said.

 3     I think the refreshment of the memory I had to read was in the statement.

 4     I can't omit or delete something when I read.  After the witness respond,

 5     if he's confirm or not confirm what I read.

 6             JUDGE ANTONETTI: [Interpretation] Very well.  Please proceed.

 7             THE ACCUSED: [Interpretation] Mr. President, I have to intervene

 8     yet again.

 9             The Prosecutor jogged the witness's memory as if there had been

10     no proofing.  I didn't object right away.  A minute or two passed and

11     then he moved on to ask questions about Slavko Aleksic.  This has nothing

12     to do with Slavko Aleksic.  It says in the statement that people were

13     found killed or slaughtered, but the witness did not confirm this in his

14     oral testimony today.  The Prosecutor wished to jog the witness's memory,

15     but he did so as if there had been no proofing.  And yet in the proofing

16     notes, the witness stated quite clearly that he never used the word

17     "slaughtered," because "killed" and "slaughtered," they're quite two

18     different things.

19             JUDGE ANTONETTI: [Interpretation] Yes, Mr. Ferrara, now I

20     understand the objection made by Mr. Seselj.

21             You are jogging the memory very well, but you are using the 2004

22     statement to do so, whereas during the proofing you probably already

23     jogged the memory of the witness by mentioning a number of items.  So

24     maybe it's best to -- before coming to the 2004 statement, to ask him

25     whether he remembers what he said to you during the proofing, and then

Page 8594

 1     you jog his memory by talking about the proofing, because here you went

 2     directly to the 2004 statement, and setting aside what had been done

 3     during the proofing session.  And I'm sure that all these topics were

 4     mentioned during the proofing session and corrected by the witness during

 5     the proofing session.

 6             So please try and resume.

 7             MR. FERRARA:  Thank you, Your Honour.

 8        Q.   So we were discussing Slavko Aleksic.  Did you see, was

 9     Slavko Aleksic carrying any weapons when you saw him in Grbavica?

10        A.   Of course he was.  There was a war on.  Everybody had to have

11     weapons.  So did he.

12        Q.   How many weapons and what kind of weapons was he carrying when

13     you saw him?

14        A.   I believe it was a Kalashnikov or something like that.  That was

15     the sort of weapons that the soldiers carried most often, and that

16     includes Aleksic.

17        Q.   Did he have any knives?

18        A.   Yes, most of the soldiers had two knives each.

19        Q.   And -- [Previous translation continues] ...

20        A.   They had them stuck in their belts.  And he also had two knives

21     hanging from his belt.

22             THE ACCUSED: [Interpretation] Objection.  This intervention by

23     the Prosecutor is not proper.  If the witness says Slavko Aleksic had two

24     knives and most other soldiers had two knives as well, this is very

25     important.  The Prosecutor should not suppress significant information.

Page 8595

 1     If all the soldiers had knives, then that's important.  The Prosecutor

 2     shouldn't say he's not interested in that.

 3             JUDGE ANTONETTI: [Interpretation] Mr. Seselj, the Prosecutor is

 4     asking the witness whether these people had weapons, this person had

 5     knives, and he says, "Yes, like everybody else."

 6             As we all know, you know, a knife is called "steel," and on line

 7     9, page 42, he asked:  "How many weapons and what kind of weapons?"

 8             The answer is:  "I believe it was a Kalashnikov."

 9             Question then:  "Did he have knives?"

10             And the answer is:  "Yes, most of the soldiers had two knives

11     each."  End of quote.

12             The witness is saying that this person had two knives, and in his

13     written statement, he also said that he had two knives.  I mean, this is

14     very marginal.  We're not going to spend hours on finding out whether he

15     was wearing one or two knives.

16             Mr. Ferrara, please proceed.

17             MR. FERRARA:  Thank you, Your Honour.

18             Madam Registrar, can we please show to the witness a video, and

19     the video's number is the 65 ter number 6072.  I want to ask the witness

20     whether he recognises somebody in this video.

21             It is a still, Your Honour, not a video.  Sorry.

22             THE WITNESS: [Interpretation] Well, this looks more or less like

23     him.  He looked a little different with the subara hat on, but this does

24     look like Mr. Aleksic.

25             MR. FERRARA:  Your Honour, I would like to tender this still into

Page 8596

 1     evidence.

 2             JUDGE ANTONETTI: [Interpretation] Before tendering this, could

 3     you tell us where this photograph comes from, this still?

 4             MR. FERRARA:  This is a still from the video that I mentioned

 5     before.  It's the video 000-1508, the number, the ERN number.

 6             JUDGE ANTONETTI: [Interpretation] Who gave this video?  Where

 7     does it come from?

 8             MR. FERRARA:  It is an interview given by Aleksic to the -- I

 9     tell you immediately, the TV.  Is the 65 ter number --

10             JUDGE ANTONETTI: [Interpretation] Mr. Mundis, no copyright on

11     this video?

12             MR. MUNDIS:  Your Honour, this material can all be used in open

13     court like this.  What we've always been concerned about is bundling this

14     material into some kind of documentary or some other kind of commercial,

15     for some kind of improper or unlawful commercial use.  So certainly

16     there's no problem with using that material in open court.

17             MR. FERRARA:  Your Honour, this is the interview, and the

18     programme is the "Small Nighttime Talk" on SR-TV.

19             JUDGE ANTONETTI: [Interpretation] Very well.  We saw a

20     photograph, and we will give this photograph a number, since the witness

21     did recognise Mr. Aleksic.

22             Mr. Seselj.

23             THE ACCUSED: [Interpretation] It's very important for the

24     Prosecutor to tell us the date when this was taken.  As far as I'm

25     concerned, it's very important to note that on this photograph, one can

Page 8597

 1     see Slavko Aleksic is not consuming alcohol.  He is drinking fruit juice.

 2             JUDGE ANTONETTI: [Interpretation] Do you have the date of this

 3     video?

 4             MR. FERRARA:  Your Honour, I don't have it now.

 5             THE ACCUSED: [Interpretation] I can assist the Prosecutor,

 6     because I'm always kind and forthcoming, if you don't mind.

 7             JUDGE ANTONETTI: [Interpretation] Do you have the date?  Please

 8     give us the date.

 9             THE ACCUSED: [Interpretation] I'm proud of Slavko Aleksic and his

10     role in the war.  It's in 1996.  That's when he gave an interview to the

11     Serbian Television from Pale, if I remember correctly.

12             JUDGE ANTONETTI: [Interpretation] Well, thank you for your

13     cooperation.

14             Madam Registrar, could we have a number for this still.

15             THE REGISTRAR:  Your Honours, that will be Exhibit P471.

16             MR. FERRARA:

17        Q.   You say that the commander of the Serb force in Grbavica was

18     Zoran Petrovic.  Do you know if Aleksic reported to Zoran Petrovic?

19        A.   I don't have that information.  How the two of them contacted,

20     only they know.  I had no opportunity to hear them talking together, so I

21     can't comment on this.

22        Q.   I want to refresh your memory on this point, reading the

23     statement mentioned before.  It's paragraph 14, where you said:

24             "Zoran Petrovic was the commander of the Serb forces in the area.

25     According to me, Aleksic wasn't reporting to Petrovic.  Aleksic was his

Page 8598

 1     own boss, probably reporting to Seselj himself."

 2        A.   That's what people said at Grbavica, that Aleksic commanded the

 3     Chetniks and that he reported to Seselj, quite simply.  As for the

 4     relationship between Zoran Petrovic and Aleksic, believe me, I don't

 5     know, but the story going 'round was that Aleksic could make his own

 6     decisions and do what he found convenient, but that he received tasks

 7     from Mr. Seselj.

 8        Q.   Do you remember who told you, or where did you hear these

 9     stories?

10        A.   These were things said by people who knew both of them well.  I

11     didn't know either of them.  I did talk to Petrovic personally once.  I

12     asked him for assistance.  I can explain if you like.  But I never spoke

13     to Aleksic.  We didn't even say hello.  I didn't have any opportunity of

14     speaking to him.

15             JUDGE ANTONETTI: [Interpretation] Witness, you're saying people

16     were saying that.  I have no idea who these people were.  But for Judges

17     like ourselves, if this is said, you know, around a table where

18     everybody's been drinking vodka and everybody's had a bit too much to

19     drink, then people can say pretty much anything, but it's another thing

20     if it's someone very reliable saying this.  It doesn't have the same

21     weight.

22             So we would like to know exactly where you get this

23     information -- where you got this information that Aleksic was reporting

24     to Mr. Seselj and he was his boss.  You heard that, but you can't

25     remember where you heard it from?

Page 8599

 1             THE WITNESS: [Interpretation] That's what I heard when we were

 2     digging the dugouts or the trenches from the soldiers who were standing

 3     guard over us.  They would speak among themselves.  The soldiers spoke

 4     about this.  We couldn't ask them their names.  We didn't have the right

 5     to ask the soldiers what their names were.  But we heard them talking.

 6             JUDGE ANTONETTI: [Interpretation] But those soldiers next to you,

 7     did they belong to Aleksic's group or were they other soldiers?

 8             THE WITNESS: [Interpretation] They were soldiers of the Serb

 9     Army, serving at Grbavica.

10             JUDGE ANTONETTI: [Interpretation] Very well.  Proceed.

11             MR. FERRARA:

12        Q.   You described before the looting committed by all the members of

13     this army.  Did you ever hear of any conflicts among the different

14     armoured groups as they were engaged in looting?

15        A.   Yes.  There was a lot of that frequently because both would meet

16     in the flats, and then conflicts would arise between the groups that

17     came, because both sides came with the same objective; to take away

18     anything of any value from the flats.

19        Q.   It is not clear to me.  When you say "both sides," what do you

20     mean ?  On the other side, we have the VRS soldiers.  On the other

21     side -- on one side, the VRS soldier.  On the other side?

22        A.   They were soldiers, the one side and the others, but -- well,

23     they were from the Serbian Republic, Serbian Republic soldiers, but there

24     were clashes and disputes about who had the right to take things away

25     from a flat that was left vacant.  So they were all soldiers of the

Page 8600

 1     Serbian Republic.

 2        Q.   Did you ever hear of a conflict between the soldiers of the SRS,

 3     the VRS, and the Chetniks regarding the looting?

 4        A.   No, we didn't know about that.  We didn't have that kind of

 5     information, who clashed with whom.  We weren't able to come by that kind

 6     of information, but we did hear about it.  The citizens heard that

 7     conflicts arose in the flats, when they were busy looting other people's

 8     property from other people's houses.

 9        Q.   I want to jog your memory on this point.

10             In paragraph 15 of the same statement, you said:

11             "It was not a secret that every unit responsible for an area

12     would loot that area.  The unit would be in control of everything which

13     was happening in his designated area.  I heard that after an argument on

14     the split of looted goods, that a VRS soldier or a member of the

15     Seseljevci was killed."

16        A.   Well, yes, on Grbavica, in Zagrebacka Street, it was well known

17     that a conflict had broken out, that a soldier had come to take some

18     goods away.  It doesn't say who, Seselj's men or from the Serbian Army.

19     And then another one came and caught him red-handed and then killed him.

20     This first one thought that the property was his, and the other came to

21     take away the goods, so things like that did happen, when they took away

22     the cars they found and collected up the goods from the various homes.

23             JUDGE ANTONETTI: [Interpretation] Witness, you seem to be a

24     well-educated man, and I'm sure you'll understand the gist of my

25     question.

Page 8601

 1             Yourself, have you served with the JNA in your national service.

 2             THE WITNESS: [Interpretation] Yes, for three years and three

 3     months in the Yugoslav Army.

 4             JUDGE ANTONETTI: [Interpretation] Three years and three months.

 5     And what rank did you achieve then?

 6             THE WITNESS: [Interpretation] I didn't have any rank, because I

 7     worked in the Quarter-master Service, so there was no command position

 8     and nor could I advance or be promoted, because I did the kind of work

 9     that didn't merit any ranks.

10             JUDGE ANTONETTI: [Interpretation] Well, you were in logistics.

11     Did you know that during war periods, the army that is deployed on a

12     territory can requisition goods belonging to civilians?  There is a very

13     specific procedure for this.

14             THE WITNESS: [Interpretation] That's when a state of war was on,

15     so, yes, they did have the possibility of taking things from the

16     citizens.  They would just go into somebody's flat and take away the

17     goods, and you wouldn't have the right to intervene.

18             JUDGE ANTONETTI: [Interpretation] But do you know that, for

19     example, the army can requisition a vehicle for the army, subject to the

20     army giving the owner of this vehicle a receipt?  This is the law

21     applicable.  Did you know this; yes or no?

22             THE WITNESS: [Interpretation] I did know about that, that was

23     clear to me, but I have to explain here.

24             When they took away cars during the war, they didn't ask anybody,

25     nor did they give receipts out to anyone.  They would just take the cars,

Page 8602

 1     drive them away to where they thought it would be considered to be their

 2     property.  So they took all the cars away from Grbavica.  Now, where they

 3     took them to, where they drove them off to, we don't know.  I mean, the

 4     citizens don't know.

 5             JUDGE ANTONETTI: [Interpretation] When you say "they took them,"

 6     the people doing this, were they doing this individually, like regular

 7     looting, or according to you was it an organisation?  I'm sure you

 8     remember when Iraq invaded a neighbouring country, they stole cars,

 9     refrigerators, television sets, and took everything home.  That was

10     organised.  So according to you, was this organised or not, or was it

11     just soldiers who took advantage of the opportunity to improve their

12     pay-cheque, if I could say so?

13             THE WITNESS: [Interpretation] Mostly, it was first come, first

14     served.  First to come by the valuables took them away, an object or a

15     car.  Individuals did that.  I don't know it was organised or not, but

16     mostly it was individuals who looted.

17             JUDGE ANTONETTI: [Interpretation] One last question.  You

18     mentioned flats which were looted, where people took washing machines

19     away, for example.  Listening to you, I was wondering what would a looter

20     do with a washing machine?  I mean, what's the point?  Do you have any

21     idea?

22             THE WITNESS: [Interpretation] Yes, I do, certainly.  Well,

23     they're not going to wash clothes at Grbavica.  They're going to drive

24     them away to where they could sell them.  They would load them up onto

25     trucks, all refrigerators and washing machines.  They weren't going to do

Page 8603

 1     any washing - and carpets and everything else - and drive them off

 2     somewhere.  And mostly the license plates, as far as I could see, were

 3     Belgrade ones or from Sabac, Uzice, Novi Sad license plates, so they

 4     would load up, and I saw this myself.  Each soldier would write what

 5     belonged to him on the vehicle, and they would drive the goods off and

 6     sell them.  They weren't going to wash any clothes in the washing

 7     machines on Grbavica.

 8             JUDGE ANTONETTI: [Interpretation] Sir, unless it's total chaos,

 9     and I don't know whether it was or not, but I assume that the VRS had

10     military police units and there was at least some controls done at the

11     check-points; and I'm sure they were checking the traffic, checking the

12     IDs and so forth.  So when you had a trailer with TVs, washing machines,

13     all this could go through the check-points, through -- you know, and with

14     the military police just acquiescing?  Everybody was an accomplice to

15     this?

16             THE WITNESS: [Interpretation] Yes, and the military police that

17     existed, they stole too, and they would be issued receipts in the

18     municipality building, saying that the goods belonged to them, because

19     nobody had the right to say that they weren't the owners of the goods

20     they'd taken.

21             JUDGE ANTONETTI: [Interpretation] How about yourself, your own

22     flat; was it looted, was anything stolen from it?

23             THE WITNESS: [Interpretation] No, they didn't loot my flat.  They

24     came several times, unfortunately -- or luckily, if I can say that,

25     because my wife was ill.  So whichever way you'd like to put it.  So only

Page 8604

 1     three out of twenty-five flats were full.  People resided in only three

 2     of those flats.  All the rest were soldiers, and so they took all the

 3     goods away from those other flats, who knows where.

 4             JUDGE ANTONETTI: [Interpretation] Nothing was taken from your

 5     flat?

 6             THE WITNESS: [Interpretation] No, they did not.

 7             JUDGE ANTONETTI: [Interpretation] Mr. Ferrara.

 8             MR. FERRARA:

 9        Q.   Answering to a question of Your Honour, you say that the looting

10     was individuals.  You don't know it was organised or not, but mostly it

11     was individuals who looted.  How do you explain that they received a

12     certificate from the municipality regarding the goods that they looted,

13     if there was any sort of individual initiative?

14        A.   Well, the fashion was to take the best goods away and drive them

15     away.  As far as I know, it wasn't organised, but individuals did that,

16     and the person coming by the goods first would just take them away, drive

17     them off.  Now, what they did after that, we don't know.

18        Q.   You already said that you knew what they did after that, because

19     you said that they went to the municipality and they received a

20     certificate signed by the president of the municipality in Novo Sarajevo.

21     When they were certified, the goods were -- they how?  So I don't

22     understand how supposedly they were individual initiative and they went

23     to the municipality and they received some sort of a property

24     certificate?

25        A.   Nobody asked who the goods belonged to, but the truth of it is

Page 8605

 1     that they were given certificates to be able to take the goods they had

 2     loaded up onto their vehicles away.

 3             JUDGE ANTONETTI: [Interpretation] Witness, the Prosecutor is

 4     raising a very important issue, and he has put his finger on something

 5     which we find difficult to comprehend.

 6             According to what you've said, it seems that those people who

 7     looted went to pick up a certificate in the municipality.  Is it that the

 8     municipality, which probably had a crisis staff or a war staff, and

 9     stated that they needed ten fridges and twenty cars, and then the

10     municipality handed over to those soldiers that brought in these fridges

11     and cars this kind of certificate?

12             THE WITNESS: [Interpretation] I don't have that information, that

13     the municipality organised a certain amount of goods and that they would

14     do that.  It was on an individual basis.  When somebody picked up some

15     goods, they came and asked for a certificate to be able to export them.

16     So I don't know when the municipality organised this, but the fact

17     remains that they did issue the certificates.

18             JUDGE LATTANZI: [Interpretation] Witness, have I misunderstood

19     you or did you tell us a while ago that they requested these certificates

20     because they needed these certificates to cross the border?

21             THE INTERPRETER:  Could the Prosecutor kindly switch his

22     microphone off, please?  Thank you.

23             THE WITNESS: [Interpretation] Yes, that is true, and I confirm

24     that because I saw it with my very own eyes, and I heard people saying

25     that they needed a certificate to export the goods, to take them across

Page 8606

 1     the border.  So that was no secret.

 2             JUDGE LATTANZI: [Interpretation] Thank you.

 3             JUDGE ANTONETTI: [Interpretation] Mr. Ferrara.

 4             MR. FERRARA:  Thank you, Your Honour.

 5        Q.   Let's move back to May 1993.  Do you remember where you were sent

 6     to work in that period?

 7        A.   My assignments were different.  They would say what I had to do

 8     on a daily basis.  They would send me out to work.  Now, in 1993, well,

 9     it was a long period -- a long time ago, and I don't really remember

10     where I worked, when.

11        Q.   Do you remember whether you were assigned to work at the

12     Zeljeznicar Football Club in Grbavica?

13        A.   Yes.  I worked there frequently and for a long time.  I would be

14     sent to the Zeljeznicar Football Club, yes.

15        Q.   Do you remember or [indiscernible] at this football club was the

16     man in charge?

17        A.   There was somebody on duty -- one of the soldiers on duty every

18     day, and he would issue orders about the work assignment.  So we don't

19     really know who the main person was, but it was the soldiers on duty, who

20     were stationed there, who would say, and it was a different person every

21     day.  They would tell us what to do and where to go.

22        Q.   Do you remember a man named Aleksandar Trivkovic?

23        A.   Yes.  That man instilled fear in everybody working in the work

24     platoon.  He was a young man, arrogant, and he didn't find it hard to use

25     means of coercion.  So he was one of the men who ordered us -- assigned

Page 8607

 1     what we were going to do, but he wasn't the only one.  There were others

 2     who issued orders too.

 3        Q.   Do you remember if he has sent you to do some job, and what job

 4     exactly?

 5        A.   Yes.  We would erect protective walls frequently to allow the

 6     soldiers to pass along these walls in safety.  So sometimes he would send

 7     someone to get some bricks, or bags of cement, or whatever to build those

 8     walls, and some other things that had to be erected to protect the people

 9     passing by from sniper fire.

10        Q.   You were assigned alone or you were with something -- with

11     somebody else?

12        A.   No, there were always several of us doing the work, or at least

13     two men.  If there was work for two, then two men did the work, but there

14     were usually more of us engaged in this kind of work.

15             JUDGE ANTONETTI: [Interpretation] Witness, you have just given us

16     a piece of detail.  You said that there were snipers.  They belonged to

17     which side and who were they shooting at?

18             THE WITNESS: [Interpretation] The snipers were allegedly -- I

19     have to use the word "allegedly."  According to what I know, it was known

20     they were shooting from the right bank of the Miljetska River and that

21     the BH Army was doing the shooting, was using snipers to shoot.  So

22     that's why we had to engage in this kind of construction work.

23             JUDGE ANTONETTI: [Interpretation] Mr. Ferrara.

24             MR. FERRARA:

25        Q.   Do you remember when you were working with a man named

Page 8608

 1     Enes Hadziahmetovic?

 2        A.   Ah, I see.  Hadzihasanovic, Enes.  He worked together with me.

 3     Aleksandar Trivkovic assigned us to build a wall, and when we started

 4     working, sometime later he went to a building that was opposite us, and

 5     then two bullets were fired from that side, and Enes Hadziahmetovic was

 6     killed.

 7        Q.   Who killed him?

 8        A.   I felt the two bullets were for him and for me.  Those were my

 9     feelings, and the conclusion was that Aleksic had killed him, because

10     after some time went by, he returned from that area and said, "It doesn't

11     matter.  Just carry on working."  And then he asked that he be taken away

12     and dug -- buried.  There was no investigation into who had killed

13     Hadziahmetovic, but this is something we knew.  We knew how he was

14     killed.  And he forced me to lie down and build a wall that way, to make

15     a wall that way, and he gave me another man.  But these two bullets that

16     were fired, one hit him and the other -- well, we can say that it missed.

17             THE ACCUSED: [Interpretation] Judges, I didn't hear what the

18     witness said.  Could he repeat who he said he thought killed

19     Enes Hadziahmetovic?

20             THE WITNESS: [Interpretation] Aleksandar Trivkovic, nicknamed

21     Sasa.

22             THE ACCUSED: [Interpretation] Thank you very much.

23             MR. FERRARA:  Your Honour, I believe we should also correct in

24     line 22 the name is "Enver Hadzihasanovic," in line 22, and

25     "Hadziahmetovic" in line 7.

Page 8609

 1        Q.   So what exactly is the name of this man?

 2        A.   Just the way it was translated, Enes Hadziahmetovic.

 3        Q.   Was this Aleksandar Trivkovic a member of what group, what armed

 4     group?

 5        A.   He was a soldier of the Serbian Republic, and he belonged to the

 6     Command at Grbavica.  I don't know who his commander was, immediate

 7     commanding officer, but the brigade commander of the Sarajevo Romanija

 8     was Zoran Petrovic.

 9        Q.   Regarding the looted goods, you say that you heard that these

10     goods were exported abroad or out of the borders with this certificate.

11     How did you learn it?

12        A.   For a time, I was carrying books from the Agricultural Faculty in

13     Sarajevo to the municipality building, as I said earlier on, and those

14     books were stored and later driven away somewhere, so I saw all this with

15     my own eyes.  I saw the soldiers coming in with the request for a

16     certificate to be issued to them for them to be able to export the goods.

17        Q.   Why do you say "export"?  How do you know that they were

18     exporting these goods?

19        A.   Well, they had a truck, and they had loaded the goods onto the

20     truck, and they were driving the goods away.  Now, where they were

21     driving them, they knew that.  We couldn't know where they were taking

22     the goods.

23        Q.   Do you remember the plates of these trucks?

24        A.   Yes.  Let me repeat that.  I saw the license plates, and they

25     were from Novi Sad, Belgrade, Sabac, Uzice, and maybe some other places,

Page 8610

 1     but I remember those four towns.  The license plates were from those

 2     towns.  Whether they were trucks or trailer-trucks or whatever, well,

 3     there were trailer-trucks, too, for that matter.

 4        Q.   Regarding the forced labours you did near the Jewish cemetery,

 5     can you repeat, please, what kind of work were you doing there?

 6        A.   Well, the task was to make a large bunker which would have a good

 7     position, with an overview of the center of town.  So that was the

 8     assignment, to construct this bunker.  We went to Trebevic, cut down the

 9     wood from the forest there, bring it in to construct this bunker, and we

10     cut down the trees from the forest and then made bunkers on the left bank

11     of the Miljetska River.

12        Q.   Who was going to use this bunker?

13        A.   That was for the needs of -- the requirements of the Army of the

14     Serbian Republic.

15        Q.   To jog your memory, I want to read paragraph 9 of the statement I

16     mentioned before, in the middle of the paragraph, where you say:

17             "Our task on the hill above the Jewish cemetery was to build

18     bunkers for the Seseljevci volunteers, because they were in charge of

19     that area."

20        A.   Yes, we built that bunker, and the area was the defence area of

21     Seselj's men.  Now, whether they -- well, I left, and the bunker hadn't

22     been completed.  Now, whether they used it or not, I can't say.  I don't

23     know, because I left before the bunker was completed.

24        Q.   Did you ever perform any of these forced labour in favour of the

25     Chetniks?

Page 8611

 1        A.   There was probably another group of men who worked all the time

 2     for the Chetniks.  I did not.  I did not work for them, except for this

 3     bunker, if the bunker was being built for their purposes.

 4        Q.   To jog your memory, I want to read paragraph 12 of the same

 5     statement, where you said:

 6             "During our forced labour tasks, we worked for the Serb forces of

 7     Sarajevo Romanija Corps and for the Chetniks."

 8        A.   Well, yes, they belonged to that corps.  The Chetniks also

 9     belonged to that corps.  We had to work.  We had to do what the person

10     assigning us tasks told us to do.  There was nothing else we could do but

11     to obey orders.  There was the Sarajevo Romanija Brigade commanded by

12     Zoran Petrovic.

13        Q.   The last question:  Was you ever beaten during this forced

14     labour, you or your fellow men?

15        A.   I wasn't beaten except by Sasa Trivkovic, who hit me in the face

16     once and kicked me in the behind another time because allegedly I wasn't

17     doing a good job, but -- it wasn't that bad, but he did hit me.

18             I did see others beaten and hit.  Sasa Trivkovic -- how can I put

19     this -- beat up Mr. Hadziahmetovic.  He was all black and blue in his

20     face and on his head.  And when they asked him why he had beaten him, he

21     said it wouldn't show after a while.  And then a few days later,

22     Hadziahmetovic was killed.

23        Q.   On this point, I want to refresh your memory.  It's paragraph 10

24     of the statement, where you said:

25             "During this two months, my 'work platoon' was working directly

Page 8612

 1     for the Seseljevci because, like mentioned earlier, they were responsible

 2     of this area of Grbavica.  During that period, we were beaten (punching

 3     and kicking) and so on almost every day by the soldiers guarding us.  I

 4     have to tell you that I was never beaten myself by Chetnik soldiers

 5     there, but my friends were."

 6             THE ACCUSED: [Interpretation] Objection.  The Prosecutor has to

 7     be correct.

 8             The witness was very correct when he made this statement.  The

 9     witness corrected the Prosecutor here, and he said soldiers of the VRS

10     beat them.  Nowhere does he say that Chetniks beat anyone.  The

11     Prosecutor is deliberately skipping over this next sentence, where the

12     witness is correcting the investigator.  A proper reading would be as

13     follows:

14             "Over those two months, my work platoon worked directly for the

15     Seseljevci, for Seselj's men," because as I've already said, they were

16     holding that part of Grbavica.  So the platoon was working for the line

17     where Seselj's men were.  "Throughout this time, the guards beat us," and

18     we can see from the entire statement that Seselj's men were not guarding

19     these people and that the witness never had direct contact with Seselj's

20     men.  It was others who were guarding them.  And he said, "They punched

21     and kicked us daily.  I can say the Chetniks never beat me, but they did

22     beat my friends."  But this was put in by the investigator.  The witness,

23     however, corrected the investigator and said it was the VRS soldiers who

24     beat them.

25             So the witness is quite clear here, but the Prosecutor is trying

Page 8613

 1     to impose on the witness something that isn't there in the statement and

 2     something that the witness cannot recollect because it didn't happen.

 3     The Prosecutor is harassing the witness, and that is impermissible even

 4     during the examination-in-chief.

 5             MR. FERRARA:  Your Honour, I will --

 6             JUDGE ANTONETTI: [Interpretation] Witness --

 7             MR. FERRARA:  [Previous translation continues] ... what

 8     Mr. Seselj said in the same sentence.

 9             THE ACCUSED: [Interpretation] No, because you didn't read the

10     last sentence.  It was the VRS soldiers who beat them.  You omitted that

11     deliberately.

12             JUDGE ANTONETTI: [Interpretation] Rest assured, I had seen this.

13             Witness, the beatings and mis-treatment, according to you, was

14     done by the Chetniks, the VRS soldiers, or Seselj's men?

15             THE WITNESS: [Interpretation] Well, there's a mis-translation

16     here.  Seselj's men are Chetniks.  That's one and the same army.  Among

17     the people, some people referred to them as "Chetniks," others as

18     "Seselj's men."  Therefore, that's another question.

19             The VRS Army included the Chetniks.  They were also under the

20     command of the Srpska Army.

21             JUDGE ANTONETTI: [Interpretation] So when you say that you were

22     told about Seselj's men, those people who told you that thought that

23     these men were Chetniks, perhaps.  When these people spoke, did they not

24     speak in an approximate manner?

25             THE WITNESS: [Interpretation] Well, it did happen, one shouldn't

Page 8614

 1     forget, that soldiers, and probably the Chetniks, mistreated people, but

 2     I didn't see the Chetniks beating people up.  I can't say that, because I

 3     wasn't working in areas where there were Chetniks.  There were soldiers

 4     of the Republika Srpska.

 5             MR. FERRARA:  Your Honour, I don't have any further question.

 6     I'd like to tender into evidence the map marked by the witness, and I

 7     want to confirm that the pseudonym sheet was admitted under seal.

 8             JUDGE ANTONETTI: [Interpretation] Yes.  Registrar, please, the

 9     pseudonym sheet has been admitted under seal, and can we have an exhibit

10     number for the annotated map, please.

11             THE REGISTRAR:  Yes, Your Honours, the pseudonym sheet is

12     admitted under seal, and the map will become Exhibit P472.

13             JUDGE ANTONETTI: [Interpretation] It is approximately 25 past

14     5.00, so we should have a 20-minute break before we start the

15     cross-examination.

16             Let's resume in 20 minutes' time.

17                           --- Recess taken at 5.24 p.m.

18                           --- On resuming at 5.46 p.m.

19             JUDGE ANTONETTI: [Interpretation] Very well.  The hearing may

20     resume.

21             The Trial Chamber would like to tell one thing for the

22     Prosecution regarding jogging memory.  This procedure, which is provided

23     for by the jurisprudence of the case law of the Appeals Chamber, is the

24     following:

25             When a witness seems to have forgotten something, the Prosecutor

Page 8615

 1     can jog his memory by reading part of his or her written statement.  As

 2     an example, let's assume that we have a situation where the Prosecutor is

 3     asking the witness, "How many cars were there in such place," and he

 4     says, "Well, there were three buses, two cars, and three bikes, three

 5     bicycles."  Then the Prosecutor notices that there's an error in the

 6     figures, and he can jog the witness's memory by saying, "Just a minute.

 7     Let me read back your written statement to you, because in this written

 8     statement you gave us different numbers."  This is how memories can be

 9     jogged, according to our Rules.

10             This being said, Mr. Seselj, you have the floor, and you may

11     proceed with your cross-examination.

12                           Cross-examination by Mr. Seselj:

13        Q.   [Interpretation] Mr. VS-1060, right at the outset I have to tell

14     you that it's my impression that your testimony was correct.  I have to

15     express my gratitude to you for not permitting the Prosecutor to

16     manipulate your statements.

17             You can think whatever you like of me, but I respect what you

18     have done in this courtroom.

19        A.   Thank you.

20        Q.   When you say "Seseljevci," you are always referring to soldiers

21     from Slavko Aleksic's unit; is that right?

22        A.   Well, in general, "Seselj's men" in general.  Excuse me, may I?

23        Q.   Yes, please answer.  Now the two of us have entered into a

24     dialogue here.  Unless we mess something up, the Judges will not

25     intervene.

Page 8616

 1        A.   Among the people, mention was always either of "Seselj's men" or

 2     "the Chetniks," referring to one and the same thing.

 3        Q.   It's all the same; do you agree?

 4        A.   Of course I do, but in Grbavica itself you always considered

 5     soldiers from Slavko Aleksic's unit to be Seselj's men or Chetniks, and

 6     they were the only such men in Grbavica?

 7        A.   Yes.

 8             THE INTERPRETER:  Could there be a pause between question and

 9     answer, please, the interpreters request.

10             MR. SESELJ: [Interpretation]

11        Q.   You know that the Muslims in Bosnia-Herzegovina generally refer

12     to all Serbian soldiers as Chetniks?

13             JUDGE HARHOFF:  The Judges will intervene, because again we have

14     the same difficulty in that the witness and the accused speak the same

15     language, and you need to observe a pause between question and answer.

16     So please, Mr. Witness, do not forget to look at us, or count to 5, or in

17     some other way remind yourself that you cannot just jump to your answer

18     as soon as you have heard the question.

19             Thank you.

20             MR. SESELJ: [Interpretation]

21        Q.   You know that when you came to the territory under Muslim

22     control, that often the Muslim media referred to all soldiers of

23     Republika Srpska as Chetniks; that was the usual practice, wasn't it?

24        A.   Yes, correct.

25        Q.   So if we make an exception of you, very often the public was

Page 8617

 1     confused when Chetniks were referred to.  They needn't be Seselj's men;

 2     there were various sorts of Chetniks.  But in Grbavica, you identified as

 3     Chetniks the people you knew as Seselj's men; am I right?

 4        A.   Yes.

 5        Q.   Unlike the Prosecutor, I have the right to put more leading

 6     questions, but I think we will move along faster that way because I'm

 7     leading up to something.

 8             Do you know that Slavko Aleksic is a man from Grbavica?

 9        A.   I don't know that.

10        Q.   He used to work in the Post Office Administration as a clerk, and

11     before 1991 do you know that he was in the leadership of the Serb

12     Democratic Party in Grbavica, the Novi Sad Municipal Council Board; are

13     you aware of that?

14        A.   I don't have that information.

15        Q.   Well, I have his statement here, and he says some interesting

16     things here, but can you draw a distinction between the soldiers under

17     Slavko Aleksic's command, where there were many local people from

18     Grbavica and other parts of Sarajevo; is that right?

19        A.   Yes.

20        Q.   But there were also Russians, Greeks, Ukrainians, Bulgarians,

21     even Japanese; is that correct?

22        A.   I don't have that information.

23        Q.   You don't know about the man from Japan or the others?

24        A.   Well, about the man from Japan.

25        Q.   But you know about the others?

Page 8618

 1        A.   Yes, I do.

 2        Q.   Can you distinguish among these soldiers who are considered to be

 3     Seselj's men and who declared themselves to be Chetniks and, on the other

 4     hand, volunteers of the Serb Radical Party who were sent to the

 5     frontlines from Serbia in some areas of Bosnia-Herzegovina?  Is my

 6     question sufficiently clear?

 7        A.   Yes, your question is clear, but I didn't know about these

 8     radical people, whether they were Chetniks or soldiers from Serbia.  I

 9     don't have that information.

10        Q.   Well, I'll give you some information that the OTP knows about.

11             The OTP has document 0324-97340.  I hope that they will be able

12     to find this, as they find it easy to manage e-court.  And this document

13     shows that a large group of volunteers of the Serb Radical Party

14     participated in these first battles for Grbavica, because you know that

15     there was fighting for Grbavica 2 and Hrasno as early as April of 1992;

16     have you heard about this fighting?

17        A.   I don't have that information, nor did I read about it.

18        Q.   You live in Grbavica 1; right?

19        A.   Yes.

20        Q.   You know that I used to live in Grbavica 2 for more than ten

21     years; are you aware of that?

22        A.   No, I am not.

23        Q.   Well, maybe I was not so well known at the time.  In April

24     1992 - the OTP has this information and they can show you that,

25     Judges - they have a recording of my telephone conversation in which I

Page 8619

 1     asked for assistance for a group of volunteers of the Serbian Radical

 2     Party who are encircled in Hrasno.  I asked for Karadzic or Krajisnik,

 3     and I left a message, "If that group which is surrounded does not get

 4     help, I will withdraw all the volunteers from all the frontlines."  The

 5     OTP has this document, and I assume they will show it to you now.  If did

 6     they don't, we will not discuss it.

 7             You are aware that the JNA withdrew from Bosnia-Herzegovina in

 8     May?

 9             JUDGE ANTONETTI: [Interpretation] Mr. Seselj, we have the

10     document here on the screen.  It's on the screen.  Thank you, Madam

11     Registrar, for having done such a --

12             THE ACCUSED: [Interpretation] But as the witness doesn't know

13     about this fighting in Hrasno in April, maybe we can use this for your

14     information only.  This was conducted in April 1992, and this is a

15     transcript of an intercepted conversation, intercepted by the Muslim

16     authorities.  It's my conversation with Branislav Gavrilovic and later on

17     with some other people in Pale.  The OTP has all this.

18        Q.   You know that the JNA withdrew from Grbavica and all of

19     Bosnia-Herzegovina in May 1992.  It had to withdraw by the 19th of May,

20     based on an ultimatum from the West.  As an intellectual, you should be

21     aware of that.

22        A.   A large number of soldiers simply changed uniforms.  They were

23     JNA soldiers and then they became soldiers of the Army of Republika

24     Srpska.

25        Q.   Yes, but that's because they had been born in Bosnia-Herzegovina.

Page 8620

 1     They came from Bosnia-Herzegovina; right?

 2        A.   If I may say so, there were many among them from Serbia.

 3        Q.   Those who were from Serbia, they were volunteers, weren't they?

 4        A.   I don't know that.

 5        Q.   Are you aware that JNA officers, professional officers, who were

 6     not from Bosnia-Herzegovina, all had to withdraw by the 19th of May?

 7        A.   But you have to admit that a large number of these officers came

 8     back to Bosnia-Herzegovina.

 9        Q.   Can you give me an example?

10        A.   I came across them, but I didn't know their names.  I didn't need

11     to know their names.

12        Q.   Very well.  Did you ever see Slavko Aleksic's men, whom you refer

13     to as Seselj's men and who identify themselves as Chetniks, looting,

14     stealing things from people's homes in Grbavica?  Did you see that with

15     your own eyes, and can you be absolutely sure they were Slavko Aleksic's

16     men?

17        A.   I have to admit I did not have an opportunity to work for

18     Seselj's men or Chetniks, nor was I able to see them looting anything,

19     because I didn't work in that area.  I worked near the playing field and

20     in Ozrenska Street.

21        Q.   You said more than once here that this unit of Slavko Aleksic's,

22     which was Seselj's unit or Chetnik unit was part of the Army of Republika

23     Srpska?

24        A.   We considered them to be one and the same army.

25        Q.   Very well.  Do you have any information to the effect that I

Page 8621

 1     issued orders to Slavko Aleksic from Belgrade or that Slavko Aleksic

 2     submitted reports about his activities directly to me?

 3        A.   That's what people said, that he received orders from you, but I

 4     don't have that information, nor could I have access to such information.

 5        Q.   Can you identify the soldiers who said this or were they purely

 6     rumours?

 7        A.   Well, it was things people spoke about in the street.

 8        Q.   Tell me, did you ever see people belonging to Slavko Aleksic's

 9     unit, Seselj's men or Chetniks, in other words, killing a civilian in

10     Grbavica?

11        A.   I didn't have an opportunity to see that.  It wasn't possible for

12     me to see it.

13        Q.   Very well.  Were you ever able to see these very men,

14     Slavko Aleksic's men, beating a civilian?

15        A.   I wasn't able to see that because I wasn't that close to them.

16        Q.   Thank you, sir.  You're a very useful witness.  I expect you to

17     tell the truth, and that's what you're doing.

18             For the sake of Their Honours, please let's have the following

19     document:  It's a request based on 92 bis instead of viva voce testimony,

20     and this document is confidential, so we won't read it or show it in

21     public.  We know what it refers to.  It's a request, and we are

22     interested in pages 32 and 33.  This should not be made public.  It's for

23     Their Honours to follow, what kind of summary the OTP made of this

24     witness's testimony from 2004.  That's pages 32 and 33.  So only to be

25     used in the courtroom, internally, and I'm going to quote what there is

Page 8622

 1     in the document and I'm not going to violate the principle of

 2     confidentiality in any way by doing so.

 3             Can we have that, pages 32 and 33.

 4             That's not the same document.  The document's date is the 24th of

 5     January.  It is Annex B.

 6             If you can't find it, then let's not waste time.  I can quote

 7     what it says in the summary, and then I'll hand my copy over to the Trial

 8     Chamber so that they can see for themselves.

 9             Do you agree, Judges, that we make short issue of this?

10             In that document, on page 32, under the name of this witness and

11     with his pseudonym, it says the following: that he will be testifying

12     about the looting of flats by Seselj's volunteers, about daily beatings,

13     killings, and that Slavko Aleksic directly reported to Seselj.  This is

14     in Serbian, of course, but hand that over to the Trial Chamber and I'm

15     sure you'll be able to find it in the English version.

16             MR. FERRARA:  What document is this?

17             THE ACCUSED: [Interpretation] It's the Prosecution document dated

18     the 24th of January, 2006.  You submitted the document.  It is an annex

19     to your document of the 24th of January, a supplement to that.

20             MR. FERRARA:  [Previous translation continues] ... on the screen,

21     it is on the screen.

22             THE ACCUSED: [Interpretation] Now you have it, but the pages

23     don't seem to coincide in English, but I can't follow because I don't

24     know English.

25             Judges, you can find the portion that I read out.  Perhaps this

Page 8623

 1     is another document from a different period.

 2             JUDGE ANTONETTI: [Interpretation] I have the text in B/C/S, and

 3     this is the translation of English.  But the best, I think, is for you,

 4     Mr. Seselj, to read out this summary, and then everything will be much

 5     simpler that way.

 6             THE ACCUSED: [Interpretation] I have just told you, you have it

 7     in English on the first page.  It says that:

 8             [In English] "The looting of apartments by Seselj's volunteers."

 9             [Interpretation] There you have it on page 1, that Seselj's

10     volunteers looted apartments, if I got that right, because I don't know

11     English.  And then you have the killing and the beatings, where it says

12     that this witness was beaten on a daily basis.  And then on the following

13     page, it says that Slavko Aleksic directly reported to me about his

14     activities.  You have that in English there as well, and I've interpreted

15     the gist of it, but you can read the whole text.

16             As far as I'm concerned, this is a very important point, because

17     I wish to draw your attention to how the Prosecutor is interpreting

18     witness -- Prosecution witness statements, and had this been accepted

19     under 92 bis, that would have been introduced into evidence and that

20     would have appeared to be the truth.  You would have thought that the

21     witness really said that, whereas the witness is very precise and can

22     distinguish between what he saw, what he heard from others about what

23     happened, and so on.  He is able to make the distinction.

24             JUDGE ANTONETTI: [Interpretation] Mr. Ferrara, what do you want

25     to say?

Page 8624

 1             MR. FERRARA:  Yes, it is an objection using the 65 ter summary

 2     during the cross-examination of the witness.  I believe it is not a very

 3     appropriate way to conduct a cross-examination.

 4             JUDGE ANTONETTI: [Interpretation] Mr. Seselj, during

 5     cross-examination you're supposed to ask a question.  You can use this

 6     document as a basis, as a foundation, but you must recall what was said

 7     in the document and then ask the witness about his opinion.

 8             THE ACCUSED: [Interpretation] Mr. President, I asked the question

 9     first.  The witness answered.  And then I drew your attention, as the

10     Trial Chamber, to this document.  The witness said that he'd never -- he

11     never saw Seselj's men looting apartments.  He said he never saw them

12     killing civilians.  He said he never saw them beating civilians.  He

13     never said that they beat civilians.  So we're talking about these people

14     whom he identifies as Seselj's men.

15             And he also said that he does not know that something was

16     rumoured and talked about, but he does not know that Slavko Aleksic

17     directed -- directly reported to me about his activities.  And from that

18     summary, you see a completely different interpretation by the Prosecutor,

19     and this is more important for me than the entire cross-examination,

20     because I'm showing you once again how unacceptable it is that statements

21     prepared by the Prosecution you accept as being the truth under 92 bis

22     and 92 quater.  This is a catastrophe against the interests of justice,

23     if you accept statements prepared by the OTP in that way.

24             And I'd like to continue now.

25             JUDGE ANTONETTI: [Interpretation] Mr. Ferrara, this is the

Page 8625

 1     problem.  I had noticed it in the summary in English.  You say "Seselj's

 2     volunteers."  In the written statement, however, the witness never

 3     mentioned Seselj's volunteers, he mentioned Seselj's men.  But when

 4     saying "volunteers," you're giving a special connection to all this

 5     notably when you add later on that Aleksic reported to Mr. Seselj.

 6     Intellectually, there's a construction, a logical construction behind all

 7     this.

 8             MR. FERRARA:  Your Honours, we quoted exactly what the witness

 9     said in the statement, when he said:

10             "Aleksic was his own boss probably reporting to Vojislav Seselj

11     himself."

12             And also regarding the Seselj volunteers or Seselj's men, he says

13     "Seseljevci."  It is in B/C/S I think it can be translated -- of course,

14     I don't know B/C/S, but can be translated as "Seselj's men," but I don't

15     see any difference with "Seselj's volunteers."

16             In any case, I don't understand.  Mr. Seselj is struggling every

17     day to listen to witnesses as viva voce witnesses, and now we are

18     discussing what, 92 ter witness?  We have the witness.  We can ask him

19     everything we want.

20             JUDGE ANTONETTI: [Interpretation] Well, as I understood what

21     Mr. Seselj said, it seems that you made a summary regarding Witness 1060.

22     This could have been the summary of a Rule 92 ter procedure or a written

23     statement written under Rule 92 bis.  Fine, but this is not the problem.

24             This is the problem:  When reading the summary, as it is written,

25     we see that the Prosecution is making different statements, saying

Page 8626

 1     "Seselj's volunteers," whereas the witness himself is talking about

 2     Seselj's men, and when the witness is saying "Seselj's men," it's because

 3     he heard this through hearsay, then the Prosecution is also adding the

 4     fact that Aleksic was reporting to Mr. Seselj.  Therefore, when reading

 5     the summary, anyone would infer directly that Seselj's volunteers were on

 6     the ground in the area and that their boss, Aleksic, only reported to

 7     Mr. Seselj.  Intellectually, this is how you construe this.

 8             MR. FERRARA:  Your Honours, maybe I was not very clear.

 9             We reported exactly what the witness said in the paragraph 13 of

10     his statement, where he say -- 14, I'm sorry:

11             "Aleksic was his own boss, probably reporting to Vojislav Seselj

12     himself."

13             It's what the witness said in paragraph 14 of his statement.

14             Regarding this issue of Seselj volunteers, in paragraph 9 of the

15     same statement, the witness says exactly:

16             "Our task at the hill above the Jewish cemetery was to build the

17     bunkers for the Seseljevci volunteers."

18             So he refers to Seseljevci or volunteers in the same way, so it's

19     not -- in the same sentence, he says "Seseljevci volunteers," so it means

20     volunteers of Seselj's men.

21             So I don't see any indiscrepancy [sic] or inconsistency among the

22     statement and the summary that we draft.

23             JUDGE ANTONETTI: [Interpretation] Very well.

24             Mr. Seselj, proceed.

25             THE ACCUSED: [Interpretation] Judges, the difference is great,

Page 8627

 1     and I understood it that you understood just how great the difference is.

 2             But the Prosecutor is trying to mask over something here, so

 3     "Seselj's volunteers" is one thing, volunteers of the Serbian Radical

 4     Party, that is, which the party from Serbia sent in organised fashion as

 5     volunteers to the fronts, and it's also another matter altogether when a

 6     group of locals forms a unit and then they declare themselves as being

 7     Seseljevci or Seselj's men, whereas we're talking about locals from the

 8     area of Grbavica and other parts of Sarajevo, because the Serbian Radical

 9     Party never sent volunteers in organised fashion to the Jewish cemetery,

10     and the Prosecutor does not have a single shred of evidence that it did

11     do that.

12             And may I continue now with my cross-examination, with your

13     permission?

14             JUDGE ANTONETTI: [Interpretation] Proceed.

15             MR. SESELJ: [Interpretation]

16        Q.   Mr. VS-1060, you mentioned here the war events at Grbavica, and

17     then you said that on several occasions, you saw how goods from certain

18     flats were being loaded up into trucks with license plates from Serbia;

19     Belgrade, Novi Sad and other places.  Right?

20        A.   Correct.

21        Q.   Now, do you know that before the war, at Grbavica 1 and Grbavica

22     2, there were large numbers of active-duty and retired officers and

23     non-commissioned officers of the JNA, that they lived there?

24        A.   One of the larger garrisons was in Sarajevo, so quite possibly

25     such people did exist.  But I'd like to warn you or draw your attention

Page 8628

 1     to the following:  They were not officers, taking away their own

 2     property.  It was soldiers of the Serbian Republic doing that, loading up

 3     other people's property from other people's flats who had been expelled

 4     or where the tenants had fled, themselves.  So my question to you is

 5     this:  I never said and never knew, and I hear this for the first time

 6     now, that they were volunteers, Seselj's men or Chetniks.  I never said

 7     that.  I didn't know that they were volunteers.  I knew that Chetniks

 8     existed or Seselj's men existed.

 9        Q.   All right, fine.  Now I'm asking you this question not because I

10     doubt that there was a lot of looting going on.  I know that there was

11     looting going on, and there was looting in all other areas as well.  So

12     I'm not challenging that fact, I'm not challenging that many flats were

13     looted, if their owners had left and went elsewhere or left Bosnia and

14     Herzegovina.  That's not what I'm challenging.  But in order to assess

15     the magnitude of the looting that went on, I would like to draw your

16     attention to the fact that there was a large exodus of the population, of

17     active-duty officers and non-commissioned officers, JNA officers living

18     in Grbavica, who were moving to Serbia because they were from Serbia

19     originally, and that the army organised trucks to carry their goods to

20     Serbia.  Do you know anything about that?

21        A.   I don't have that information.  I do know that there were

22     officers who lived on the territory of Grbavica, but I have to tell you

23     that there was looting of homes and flats by people who'd been expelled

24     and that they were being looted by the soldiers of the Serbian Republic,

25     and that's what I claim, and you claim that too.

Page 8629

 1        Q.   Well, I know that there was looting, and that's not what I'm

 2     challenging.  You said that individuals engaged in the looting and that

 3     the municipality issued certificates to them.  Do you exclude the

 4     possibility, for instance, that there was a corrupt official in the

 5     municipality who, for some little money, would issue these certificates

 6     so that people who had looted other people's property received

 7     certificates saying that they were taking their own property out of

 8     Bosnia-Herzegovina?

 9        A.   I don't have that information, but I do have information that

10     people came in who had looted other people's property and received

11     certificates for that property.  Now, whether they were compromised, or

12     corrupt, or whether -- how they came by those certificates, I don't know.

13        Q.   But you do allow for the possibility that during the war, there

14     was corruption when salaries were negligible and when life was difficult,

15     clerks would write out certificates in return for a sum of money?  That

16     is possible; right?

17        A.   Yes, it is a possibility.

18        Q.   I don't know that that was the case, but I'm just trying to look

19     into all the possibilities.  Right, you say "yes."

20             Now, do you know that two check-points of the military police

21     existed as you went towards Trebevic from Grbavica; do you know that to

22     be a fact?

23        A.   I didn't see them.  I went to Trebevic, but I never saw any ramps

24     or check-points.

25        Q.   At Raca, for example?

Page 8630

 1        A.   No.

 2        Q.   You didn't see a check-point there, a ramp?

 3        A.   No.

 4        Q.   My information tells me that those check-points were there.  Now,

 5     when you were engaged in the work platoon, you said that you did not

 6     receive a salary or were not remunerated for your work in any way.  I'm

 7     asking you, it's a serious question, because I have documents from

 8     Vogosca that those who worked in work platoon did receive a salary which

 9     was 20 per cent lower than a soldier's salary.  Now, for the very first

10     time, I'm hearing from you that civilians working at Grbavica working in

11     a work platoon did not receive a salary.

12        A.   No civilian working in the work platoon received any

13     remuneration, not one single dinar from the Serbian Republic, and I state

14     that and I can bring in a lot of witnesses to testify to that effect,

15     because a French soldier asked me, for example, when I was unloading

16     humanitarian aid, he asked me, "How much do they pay you?"  And I just

17     laughed and said nothing, and he laughed too because he actually knew

18     that we weren't remunerated.

19        Q.   Now, in addition to the lunch that you were given while at work,

20     as you said, did you receive any food stuffs that you could take home,

21     for example?

22        A.   That never happened, nor did we have the right to anything like

23     that.

24        Q.   How come, then -- how did the civilian population manage to

25     survive for those three or actually four years of war?

Page 8631

 1        A.   Humanitarian aid arrived, and they received something from that

 2     or we went to market and bought those -- that humanitarian aid which the

 3     soldiers received and sold it at market.

 4        Q.   At Grbavica 2, I lived by the shopping centre on Darijankovic

 5     Street, and I happened to be there in 1993 and 1994, and I saw with my

 6     own eyes when loaves of bread were brought in by the army for the whole

 7     settlement.  Civilians gathered and formed lines, women mostly, and all

 8     received loaves of bread on the basis of a list.  There were quite a lot

 9     of Muslims and I recognised them.  They were my neighbours and I talked

10     to them.  Do you say that that is not true?

11        A.   I did not see or hear about it, and in Grbavica, please believe

12     me when I say there was nothing like that.

13        Q.   Was there any bread during the war?

14        A.   There was flour, and we baked bread.

15        Q.   Do you mean to say there was no bread at Grbavica at all?

16        A.   No, there wasn't.

17        Q.   All right.  I saw this with my very own eyes in Grbavica.  But,

18     anyway, very well, Witness 1060.

19             You mentioned a man here who was a terror to the work platoon,

20     Aleksandar Trivkovic.  Now, I did my best to find out who the man was,

21     but nobody seems to have heard of him.  Perhaps you mixed up some names

22     there.  Did you get the name wrong?  This man, Aleksandar Trivkovic,

23     nobody's heard of him.

24        A.   Many people didn't know what his name was, but they knew the

25     nickname "Sasa," and everybody would know the name "Sasa," everybody

Page 8632

 1     working at the Zeljeznicar Football Club Stadium.  Everybody would know

 2     the name "Sasa."  I'm quite sure of that.

 3        Q.   You said that Zoran Petkovic was the commander of the Sarajevo

 4     Romanija Brigade; right?

 5        A.   Yes.

 6        Q.   Nobody's ever heard of this man, Zoran Petkovic or Petrovic, but

 7     there was Aleksandar Petrovic, for example, and he, as a reserve officer,

 8     was the commander of the 2nd Battalion of the 1st Sarajevo

 9     Mechanised Brigade.  So is it possible that you meant him instead of

10     Zoran Petrovic, that it was Aleksandar Petrovic, perhaps?

11        A.   I have to correct you.  (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16   (redacted)

17   (redacted)

18     (redacted) and that you

19     signed the document.  This might be a public document.  If that is the

20     case, you might be identified.

21             I'll ask the Registrar to hand down an order for redaction from

22     line 3 onwards until line 9 of page 90.

23             Please proceed.

24             THE WITNESS: [Interpretation] Thank you very much.

25             I agree that this be redacted, but I was sent to see

Page 8633

 1     Zoran Petrovic.  I was supposed to be protected.  I was supposed to be

 2     under the protection of the United Nations.  I went to speak to him, as

 3     the commander, and he said to me, "This is a state of war.  Sir, go and

 4     do what you are ordered to do."  So I had the right to go and ask for

 5     protection, but I didn't dare ask for it.

 6             What the gentleman here, the accused, is saying might be a

 7     mistake, but I was told to go to see this man, and I was in his office.

 8     He simply said to me, "There's a war on."  I was over 65, so they should

 9     not have recruited me.  It might be a mistake.  His name might be

10     something else.

11             THE ACCUSED: [Interpretation] Very well.

12        Q.   Did you hear what the official title was of the unit commanded by

13     Slavko Aleksic?

14        A.   I don't have that information.

15        Q.   You never heard that this was the Anti-Armour Company of the 2nd

16     Battalion of the 1st Sarajevo Mechanised Brigade of the Army of Republika

17     Srpska?

18        A.   I didn't have a chance to talk to anyone about the names of these

19     units.

20        Q.   Very well.  From these documents, I gave a translation in

21     December.  Please turn to page 498 and prepare page 499.  We'll only look

22     at these two pages today.  It's also been translated into English.  These

23     are some pages from the military booklet of Slavko Aleksic.

24             Mr. VS-1060, did you know that Slavko Aleksic was a captain of

25     the Army of Republika Srpska, that that was his official rank, apart from

Page 8634

 1     the fact that I proclaimed him to be a Chetnik vojvoda?

 2        A.   No, I don't know about that.

 3             MR. SESELJ: [Interpretation] Can this be shown for your sake and

 4     the sake of the Chamber?  This is an order dated the 24th of September,

 5     1993.  Have you found it, pages 498 and 499?

 6        Q.   Is that a military booklet or have I introduced some confusion

 7     into the proceedings?  498, you haven't found 498?

 8             It's 472 and 473.  Those are different numbers here now.

 9             Do we have that now?

10             First we see here that his rank is that of captain, pursuant to

11     order number such-and-such, of a commander of the Army of Republika

12     Srpska, and that's General Mladic, and we see the military post number on

13     the stamp, 7512.  Do you see the military post number?  That's Lukavica?

14     That was the military post to which Slavko Aleksic belonged.  Do you see

15     that, sir?

16        A.   Yes, but I'm not interested in that.

17        Q.   Well, I'm not putting this forward here because it's interesting

18     for you.  It's interesting for me and the Chamber.  But you don't have

19     any evidence to deny this or to challenge this, do you?  I'm telling you

20     here that he was a captain of the Army of Republika Srpska, promoted by

21     order such-and-such, and you do not challenge this?

22        A.   Well, I've heard this for the first time now.

23        Q.   Very well.  Let's turn to the next page.  Here we see

24     Slavko Aleksic's participation in the war.  He was in military post

25     1536/4, Han Pijesak, and the date is the 4th of April, 1992, to the 31st

Page 8635

 1     of May, 1993.  That's his military post, the Command at Han Pijesak.

 2             You know about that, don't you?

 3        A.   No, I don't.

 4        Q.   And here we have another military post, as of the 1st of June,

 5     1993, up to the 31st of March 1996.  That's military post 1512/7.  I'm

 6     don't know whether I saw the first number correctly, but it might be a 7,

 7     7512/7 Lukavica."  Do you see that?

 8        A.   Yes, I do, but I don't know why -- what this is for.

 9        Q.   Well, it confirms your statement that Slavko Aleksic was all the

10     time an officer of the Army of Republika Srpska.  There's nothing to

11     challenge that, is there?

12        A.   Well, how could I know about this?

13        Q.   Well, you said he was part of the forces of the Army of Republika

14     Srpska.

15        A.   I said that I assumed he was part of the Serbian Army.

16        Q.   Well, now I'm confirming your supposition.  May we continue this

17     conversation without tension?  I'm not showing you anything dangerous.

18     I'm showing you this because it's in my interests to do so.

19             JUDGE ANTONETTI: [Interpretation] Witness, we have a document

20     before us, like you have, which testifies to the fact that Aleksic is,

21     from the 4th of April, 1992, onwards until the 31st of May, 1993, belongs

22     to the military unit 1536-4.  So if this document is a true document,

23     nothing entitles us to claim that it is not the case, if this is a true

24     document, this Slavko Aleksic was at the time a military -- he was

25     entirely a military man.

Page 8636

 1             In your statement, in paragraph 11, you say that the vojvoda,

 2     that's Aleksic, was heading Seselj's men in Grbavica, and you even add

 3     after that that he had a black uniform.  I don't know whether, in this

 4     unit 1536-4, what kind of uniform they were wearing, but I'm a little bit

 5     upset about what you are saying and what the document states, and I

 6     wonder about this.

 7             When you made your written statement, did you tell this to the

 8     investigator or is it the investigator who drafted this paragraph on the

 9     basis of the various information you gave him?  Witness, please.

10             THE WITNESS: [Interpretation] I saw Slavko Aleksic wearing a

11     black uniform and a subara hat.  This is the first time I have heard that

12     he was a soldier and that he was promoted to the rank of captain.  How

13     and where this happened, I don't know.  All I can say is that he

14     commanded the Chetniks at the Jewish cemetery.

15             JUDGE ANTONETTI: [Interpretation] Mr. Seselj.

16             MR. SESELJ: [Interpretation] Very well.

17        Q.   You are telling us what you know, and I don't hold it against you

18     that there are things you don't know.  This is quite natural.  You

19     weren't involved in everything.  You know only what you experienced

20     yourself.

21             I have a statement here signed by Slavko Aleksic, and he had his

22     signature notarised in Bileca Municipality in Republika Srpska.

23             Could we look at this statement marked with a Roman number I.  I

24     wish to go through it with the witness.

25             JUDGE ANTONETTI: [Interpretation] Mr. Ferrara, you are going to

Page 8637

 1     say that you don't have the translation, I assume, in English.

 2             MR. FERRARA:  Yes, but I have my case manager who can translate

 3     it.  But we received the statement only during the second break.

 4     Mr. Seselj received the statement at 1.00 this afternoon, so I think they

 5     could give us before starting the hearing today, at least.

 6             JUDGE ANTONETTI: [Interpretation] I believe that Mr. Seselj must

 7     have given the documents to the Registry at the beginning of the hearing,

 8     because when we arrived, we were given these documents.  I believe that

 9     he must have given them as soon as he had them, since when we arrived at

10     a quarter past 2.00, we had these documents on our table.

11             Mr. Seselj, please proceed.

12             THE ACCUSED: [Interpretation] Judges, I don't know why it says

13     here at 1.04.  I really did not receive it at 1.04 p.m. I received it at

14     2.00 p.m.  I received 28 pages of documents, and I selected only two

15     statements to use, and in the meantime I had to read them.  I can't use

16     something here without having read what it says beforehand.  Maybe the

17     Prosecutor can do that, but I can't.

18             So this is a statement made by Slavko Aleksic, where he describes

19     his war path, and I would like to go through the text and see whether you

20     have any comments to make or something to say about it.

21             He says that the beginning of the civil war found him in Sarajevo

22     in Gornji Kovacici.  Do you know where that neighbourhood is?

23        A.   Yes.

24        Q.   It's between Grbavica 1 and Skenderija near the hill?

25        A.   Yes, underneath Trebevic.

Page 8638

 1        Q.   Yes, where he was a sub-tenant at Trebevicka 73, which belonged

 2     to the Novo Sarajevo municipality, which numbered 120.000 inhabitants, of

 3     whom 60 per cent were of Serb ethnicity.  Do you know anything about

 4     that?

 5        A.   No, I don't.

 6        Q.   Do you know in Sarajevo overall what the ethnic breakup was

 7     before the war?

 8        A.   Yes, I do.

 9        Q.   Please tell us.

10        A.   In the entire canton --

11        Q.   Well, let's stick to the Sarajevo municipalities.

12        A.   There were 158.000 Serbs living in Sarajevo.  I know that.

13        Q.   In the entire city?

14        A.   Yes.

15        Q.   In full municipality or the suburbs as well?

16        A.   In the suburbs as well.

17             THE INTERPRETER:  Could the speakers kindly slow down.

18             MR. SESELJ: [Interpretation]

19        Q.   But the highest concentration of Muslims was in Centar and

20     Stari Grad municipalities; is that correct?

21        A.   Yes.

22        Q.   And the highest concentration of Serbs was in the Novo Sarajevo

23     municipality, leaving aside the municipalities in the suburbs?

24        A.   Yes.

25        Q.   So this could be correct, but neither you nor I have the entire

Page 8639

 1     data.  So he says he arrived in Sarajevo in 1975 to study law and that he

 2     worked as a clerk in the main post office as of 1980.  In early 1992, he

 3     says:

 4             "I and my neighbours, on our own initiative, organised ourselves

 5     because at night armed members of the Patriotic League and the Green

 6     Berets patrol the streets of our neighbourhood, by night.  They would

 7     come there from other parts of Sarajevo, inhabited mostly by Muslims."

 8             Do you know about this?

 9        A.   No, I don't have this information.  I was not organised in this

10     way at all, nor did anyone tell me this.

11        Q.   Well, did you know that Grbavica 2, for example, at the beginning

12     of the war, changed hands two or three times between the Serb and Muslim

13     forces?

14        A.   I don't have that information.

15        Q.   Do you know anything of what happened in Grbavica 2?

16        A.   No, I don't.

17        Q.   Very well.  He goes on to say:

18             "During the war, I was the commander of the Novo Sarajevo Chetnik

19     Detachment, initially composed exclusively of local people, local men."

20             He says -- well, now I'm interpreting what he says, that this

21     detachment called itself "The new Sarajevo Chetnik Detachment."  This was

22     before the army of Republika Srpska was established; is that right?

23        A.   Yes.

24        Q.   Very well.  He goes on to say in late 1992 and early 1993,

25     volunteers started arriving, first Russians, then Bulgarians,

Page 8640

 1     Macedonians, Greeks, Serbs from America, and even a man from Japan.  Did

 2     you hear that there were Russians in his unit?

 3        A.   I saw them myself.  I saw the Greeks, too, and the Belorussian,

 4     because I spoke Russian, so I could communicate with them; and I know

 5     that they arrived there.  But I didn't know about the Japanese.

 6        Q.   Did you know about the Bulgarians, Macedonians and Greeks?

 7        A.   I know that various people came, but I didn't know how many there

 8     were and I wasn't really interested in that.

 9        Q.   Very well.  He goes on to say there were very few volunteers from

10     Serbia and they were isolated cases:

11             "I assert with full liability that there was no organised arrival

12     of volunteers organised by the Serbian Radical Party."

13             Did you hear that the Serbian Radical Party sent volunteers to

14     this unit in an organised manner?

15             JUDGE ANTONETTI: [Interpretation] Just a minute, Mr. Seselj.

16     Please allow me to interrupt you.

17             If what Mr. Aleksic is saying is true, well, you had said that

18     also, as a matter of fact, when you answered Mr. Ferrara's questions.  It

19     seems that in Mr. Aleksic's unit, there were Bulgarians, Russians,

20     Macedonians, and so on and so forth.  I think there was even a Japanese

21     person.  So how is it that -- and you seem to confirm this, since as you

22     spoke Russian, you spoke Russian with Russians and Belorussian, so you

23     knew that in this new unit, there were people who came from other

24     countries, who did not come from Serbia, so how is it that you, before

25     the OTP investigators, you said that these were Seselj's men, whereas a

Page 8641

 1     Russian -- what would enable you to infer that a Russian, or Bulgarian,

 2     or Japanese is one of Seselj's men?  So why did you refer to Seselj's men

 3     when you talked about Slavko Aleksic's unit, when we have information

 4     that would lead us to believe that this unit comprised a number of

 5     foreigners?

 6             THE WITNESS: [Interpretation] I have to say that I didn't know to

 7     whom these foreigners belonged, but I did see them at Grbavica, and I

 8     talked to them too.  I know that cars that were, well, Volvos and

 9     Lada-type cars that were out of order, they took spare parts from those

10     cars.  Now, which unit they belonged to, I don't know.  I didn't know

11     whether they belonged to any of the units of the Serbian Republic.

12             MR. SESELJ: [Interpretation]

13        Q.   You should know which parties were active in Sarajevo before the

14     war.  There was the Serbian Democratic Party, the Party of Democratic

15     Action, the Croatian Democratic Union, and some others; right?

16        A.   Yes.

17        Q.   Those were the parties that incorporated the Serbs, the Muslims,

18     the Croats.  Then there was the former Communist Party and some others.

19     Did you ever hear of the existence of the Serbian Radical Party in

20     Sarajevo before the war?

21        A.   No, I never heard about that.

22        Q.   Did you ever hear that during the war, its board was established

23     for the Novo Sarajevo municipality, precisely at Grbavica?

24        A.   No, I'm not aware of that.

25        Q.   If I tell you at sometime toward the end of 1992, Slavko Aleksic

Page 8642

 1     transferred from the Serbian Democratic Party to the Serbian Radical

 2     Party and formed a board of the Serbian Radical Party at Grbavica for the

 3     whole of the Novo Sarajevo municipality, do you believe me if I tell you

 4     that?

 5        A.   Well, I can't claim either way, I can't say I believe you or

 6     don't believe you, because I wasn't involved in any of that.  I didn't

 7     know what was going on in the parties at all.

 8        Q.   All right.  But you didn't hear of the existence of the Serbian

 9     Radical Party before the war at all, did you?

10        A.   No, I did not.

11        Q.   Let's see what Slavko Aleksic says in continuation, in addition

12     to the fact that he says that there was no organised arrival of the

13     volunteers of the Serbian Radical Party to his unit.  He goes on to say

14     the following:

15             "The detachment fought within the composition of the Army of

16     Republika Srpska and it was in the composition of the 3rd Infantry

17     Battalion under the command of Major Blagoje Kovacevic, under the name of

18     the Anti-Armoured Company or the 5th Company, and the 3rd Infantry

19     Battalion belonged to the 1st Sarajevo Mechanised Brigade under the

20     command of Colonel Veljko Stojanovic.

21             So he identifies the commander of this brigade as being

22     Colonel Veljko Stojanovic, and you gave us another name.  So could it be

23     that this was just be an an error on your part, or what do you say to

24     that?  Leave it on our screens, please, the document.

25        A.   It's the first time that I hear of this name and surname like

Page 8643

 1     that.

 2        Q.   Slavko Aleksic goes on to say the chief of staff was

 3     Lieutenant-Colonel Pero Sajlovic [phoen]:

 4             "By virtue of the order from the command of the Main Staff of the

 5     army of Republika Srpska, I was given the rank of captain and demobilised

 6     as captain on the 31st of March, 1996."

 7             Now, do you know that Slavko Aleksic was not an active officer

 8     before the war?  We've already seen that, haven't we?

 9        A.   Well, I didn't know about him.

10        Q.   He was an ordinary soldier, private, and he reached the rank of

11     captain based on his war merits; right?

12        A.   Yes, that would roughly be it.

13        Q.   All right, fine.  Now, Slavko Aleksic goes on to say, Grbavica

14     was defended by just one army, the Army of Republika Srpska, with its

15     united command.  Do you agree with that?

16        A.   Well, one can assume that that was the case, and I think that's

17     what I said too.

18        Q.   All right.  Now turn to page 2, please.  It says:

19             "As there were no uniforms, the soldiers were dressed in

20     different ways.  Usually, they were wearing civilian clothes or combined

21     with certain parts of a military uniform."

22             And this corresponds to what you said, that people were dressed

23     differently at the beginning of the war?

24        A.   Yes, that's right.

25        Q.   Now, the officers, he says, paid great care and attention that no

Page 8644

 1     parts of the uniform should be black or entirely black, because we knew

 2     that this could cause negative emotions among the non-Serb population

 3     that lived in Grbavica.

 4             And for a long time throughout 1992, in fact, there were no

 5     insignia of the cockade type because we couldn't come by them anywhere.

 6     And this brings us to a collision between what you say and what Aleksic

 7     says, because he claims that black uniforms quite simply did not exist,

 8     nor were they permitted, whereas you say you saw him wearing a black

 9     uniform.  Perhaps you were misled by a black -- his black beard.  That's

10     a black beard, sir.  You showed us Slavko Aleksic's photograph, just

11     showing his face and a black beard, and the Prosecution has

12     Slavko Aleksic's photograph showing him always wearing a camouflage

13     uniform, but the Prosecution is hiding those photographs now because it

14     suits the Prosecution for you to think that he was wearing a black

15     uniform.

16             You saw Slavko Aleksic earlier on, Judges, wearing a camouflage

17     uniform, and I can't keep collecting all those photographs.  I find it

18     difficult to find my way in all the material and documents, anyway.

19             But, anyway, that's not an essential point, and discrepancies

20     like that are normal.  I don't hold it against you, I really don't hold

21     anything against you, because I think you testified to the best of your

22     memory, and I respect that.  But we'll go through these different things

23     because various people remember various things, different things.  You're

24     an intellectual, so every man has his own vision of things; right?

25             Now, the company that I was in command goes on to say:

Page 8645

 1             "Defended positions from the top of the Jewish cemetery."

 2             That's the old Jewish cemetery, isn't is it, that hasn't been in

 3     use for a long time.  Do you agree with that?

 4        A.   Yes.

 5        Q.   Nobody's been buried there for decades.  It dates back to who

 6     knows what times?

 7        A.   From the arrival of the Jews in Sarajevo.

 8        Q.   But the whole area is known under the name of Jewish cemetery.

 9     Up until [indiscernible] 1 to feature 942, Debelo Brdo, where it touched

10     upon the 2nd Company of the 3rd Infantry Battalion so that we never had

11     any control over the Beogradska, Ljubljanska, Radnicka, or any other

12     street, settlement, or part of a settlement.  That's what he says.  That

13     these streets, the ones you mentioned, they did not control.  They had a

14     line right from the Jewish cemetery, the top of the Jewish cemetery, up

15     to feature 945 and Debelo Brdo.  Do you know where Debelo Brdo was, where

16     the observation post of the United Nations was later on; do you remember

17     that?

18        A.   Yes.

19        Q.   So that's the area held by his unit, that's what he says, and he

20     says that in the streets mentioned here, they had nothing to do with

21     them.  They could go down there, but they were not in control of that

22     area?

23        A.   I have to put you right, because behind their backs here, behind

24     the backs -- well, they passed by those streets to reach the Jewish

25     cemetery.

Page 8646

 1        Q.   All right.  So we agree on that point.  Now, all responsibility

 2     for the safety and security of civilians within the settlement was borne

 3     by the civilian police, he says, whose police station was located in

 4     General Draza Mihajlovic Street.  Do you know what name was renamed --

 5     what street was renamed into General Draza Mihajlovic Street later on?

 6        A.   Zagrebacka.

 7        Q.   That's the longest street in Grbavica.  Is that right?

 8        A.   Yes.

 9        Q.   Do you know that there was a police station there?

10        A.   Yes, I do.

11        Q.   That police station was in charge of providing security and

12     safety for the citizens; right?  Now, how it did that is another matter

13     altogether.

14        A.   It would have been better had that police not existed at all.

15        Q.   Let's move on.  That's not the subject of our discussion here.

16             Slavko Aleksic goes on to say the distance from the enemy

17     positions was measured by the width of a street or the length of a house,

18     so that it was physically impossible for somebody to find themselves in a

19     crossfire on what was called no man's land, because the enemy, by precise

20     targets, would thwart any attempt to emerge from a shelter.

21             Is it true that the lines that he held were very close to the

22     Muslim lines; is that correct?

23        A.   How would I know that?  How do I know what the distance between

24     the two frontlines was?  I couldn't know that.

25        Q.   But you worked in the area of the Jewish cemetery and you had to

Page 8647

 1     defend yourself from the fire from your own compatriots who didn't know

 2     who they were shooting at or who was doing the shooting?

 3        A.   I just worked on a hill above the Jewish cemetery.

 4        Q.   All right, fine.  He goes on did say Grbavica was under

 5     continuous enemy sniper fire and many civilians were killed, about 904 or

 6     940, I'm not quite sure, mostly Serbs.  The number of civilians from

 7     other ethnic groups that were killed by the sniper fire was proportionate

 8     to their representation in the population of Grbavica, that is to say,

 9     far less.

10             So do you know of the people killed by sniper fire on the Muslim

11     side, these large figures?

12        A.   Well, I didn't keep records.  I couldn't know about that.  I was

13     in the work platoon.  Now, when they were killed, whether that was during

14     the day or during the night, I really don't know.

15        Q.   All right.  But there is information telling us that over 900

16     people were killed by sniper fire and that these were mostly Serbs,

17     although Muslims and others were killed too.  I know for a fact that a

18     lot of children were killed by sniper fire.  Did you ever hear of a child

19     being killed by sniper fire on Grbavica?

20        A.   Well, I don't have that information or records.  There were just

21     rumours.  How would I know about that?

22        Q.   All right, fine.  Well, he says -- Slavko Aleksic also says that

23     the name Aleksandar Trivkovic, Sasa, is quite unknown to him, and he

24     stresses that there was never a soldier under his command by that name.

25     So do you agree that even if he does exist, he wasn't under

Page 8648

 1     Slavko Aleksic's unit?

 2        A.   No, I didn't claim that he belonged to Aleksic, but that he was a

 3     soldier of the Serbian Republic and that he was up at the positions

 4     around the football pitch, the Zeljeznicar Football Club's pitch.

 5        Q.   All right, fine.  Now, he goes on to speak about the use of the

 6     work platoons:

 7             "My unit determined the defence line, and this was done by

 8     90 per cent of the soldiers whom I commanded, and the work platoon

 9     together with the soldiers, they provided the defence."

10             Now, as far as I know, on the basis of the laws -- is it true

11     that the civilian authorities organised the work platoons and managed

12     them?

13        A.   This man, Dilmar whom I mentioned, was a soldier, so he decided

14     who was going to work where.

15        Q.   As an intellectual, you must know there was a law governing the

16     total national defence before the war?

17        A.   Correct.

18        Q.   So do you know that he was in charge -- that that law prescribed

19     for all types of rights and duties, military and work obligations?

20        A.   I don't know.

21        Q.   Slavko Aleksic says he never went into a cafe named "Chetnik,"

22     and that no such cafe existed in Grbavica, but that the following cafes

23     existed; Kokarda, Krune, Apollo and Neretva.  Is that a mistake?  Perhaps

24     you thought that Kokarda or Cockade Cafe was called the Chetnik Cafe?

25        A.   It was in Radnicka Street.  I don't know the number but there was

Page 8649

 1     a cafe that was Chetnik.  I didn't claim that Aleksic went there.  All I

 2     said was I saw him passing by, but I didn't claim that he was in the cafe

 3     itself, that there were Chetniks there.

 4        Q.   This is what he says:

 5             "The fighters of the 5th Anti-Armoured Fighting Company were

 6     prohibited alcoholic drinks, and even in special -- on special occasions.

 7     Sanctioning alcoholism was very strict in the VRS, and particular

 8     attention was made to that on Grbavica because the multi-ethnicity of the

 9     population, because they are exposed to enemy fire all the time."

10             Turn the page, please.

11             THE INTERPRETER:  Interpreters note this is much too fast for

12     interpretation.  Thank you.

13             MR. SESELJ: [Interpretation] There is not a single army in the

14     world --

15             JUDGE HARHOFF:  The interpreters ask you to slow down because

16     you're reading out too fast.

17             THE ACCUSED: [Interpretation] Well, I wanted to get through the

18     document by 7.00, but it doesn't appear that I'm going to be able to do

19     that.

20        Q.   Did you see soldiers from Slavko Aleksic's units drunk ever or

21     see him drunk?

22        A.   No.  I didn't say that he was sitting and drinking anywhere.

23        Q.   Did you hear that I came to Grbavica during the war?

24        A.   That was rumoured, but I never saw you.  I didn't see you come,

25     nor did I know whether you were there, but people said that you were

Page 8650

 1     there.

 2        Q.   I was at Grbavica 1.  I went up to the frontline at Ljubljana

 3     Most, and I was at the marketplace in Grbavica 1 and 2.  And whenever I

 4     went to visit Slavko Aleksic's unit, there was only fruit juice served

 5     there, ordinary water, nothing more than that, that there was not a

 6     single drop of alcoholic beverage in that unit ever.

 7        A.   How could I know that?  How do you expect me to know that?

 8        Q.   Well, do you have reason to doubt it?

 9        A.   I have no reason to doubt what you say.

10        Q.   Do you know that I'm an anti-alcoholic, just like Slavko Aleksic?

11        A.   Well, I don't really know.  I've never had an opportunity of

12     discussing your behaviour or your habits.

13        Q.   All right.  Now he goes on to say that in his unit, there were

14     volunteers from different countries.  He repeats that, and he says that

15     there were no men sent by the Serbian Radical Party, but does say there

16     were soldiers who had different affiliations, members of the Serbian

17     Radical Party, that is to say locals, the Serbian Democratic Party, the

18     Serbian National Renewal, but all those soldiers were from Sarajevo, he

19     says.  Is that correct?

20        A.   I don't have that information, nor could I have it, nor did I

21     need it.

22        Q.   All right.  Let's look at these last two paragraphs, if we manage

23     to do so in the three minutes we have left:

24             "As soon as the unit was formed, I read out the Geneva

25     Conventions to all the soldiers and drew their attention to the fact that

Page 8651

 1     they must be particularly careful in their conduct towards Muslim

 2     civilians and Croats, so I say with full responsibility that not I, nor

 3     any soldiers under my command, ever inflicted any injustice to Muslim or

 4     Croat, let alone a single crime throughout the war being committed."

 5             He says that and refers to his own unit.  So we don't exclude the

 6     fact that there were crimes committed, but he guarantees that nobody from

 7     his particular unit committed any crime whatsoever.

 8        A.   I don't have any of these cases, what the conduct and behaviour

 9     was of individual units.  That wasn't something that I could know about.

10        Q.   All right.  He goes on to say, with respect to all these names,

11     he says:

12             "I'm sure that in Grbavica there was not a single officer named

13     Zoran Petkovic.  I knew Aleksandar Petrovic, and I was on friendly terms

14     with him.  Aleksandar Petrovic was a reserve captain by rank, the

15     commander of the 2nd Infantry Battalion.  However, he was never a

16     superior officer to me.  Establishment-wise, we had no points in common.

17     He was the command of the 2nd Battalion, and my company belonged to the

18     3rd Battalion, so that I was under the direct command of the commander of

19     the battalion, that is to say major Blagoje Kovacevic.  He was

20     establishment-wise under the command of the Command of the brigade, that

21     is to say, Colonel Veljko Stojanovic."

22             So that is the cadre structure and hierarchical chain of command

23     that Slavko Aleksic was in.  Do you believe him when he says all this?

24        A.   Well, I don't have the possibility of establishing whether he's

25     telling the truth or not.  I made my statement.  I said that there were

Page 8652

 1     Russians, Ukrainians, Belorussians, Greeks, even Bulgarians.  We all knew

 2     that.  Now, who these men belonged to, I really didn't know that.

 3             THE ACCUSED: [Interpretation] I hope I have more time tomorrow,

 4     Judges, a bit more time tomorrow.

 5             JUDGE ANTONETTI: [Interpretation] You have a bit more time left

 6     for tomorrow.  I believe that you have 27 or 28 minutes left.

 7             Witness, unfortunately your hearing couldn't be completely

 8     finished today.  We will have to resume tomorrow, so at 2.15 p.m.,

 9     because we're sitting in the afternoon.

10             You made the solemn declaration earlier, so you are now in the

11     hands of justice.  You're not supposed to have any contact with

12     Mr. Ferrara, and I wanted to remind you of this.

13             I will now adjourn the hearing, and wish everyone a good evening.

14                           --- Whereupon the hearing adjourned at 7.01 p.m.,

15                           to be reconvened on Wednesday, the 25th day of

16                           June, 2008, at 2.15 p.m.