Tribunal Criminal Tribunal for the Former Yugoslavia

Page 12079

1 Tuesday, 22 October 2002

2 [Open session]

3 [The witness entered court]

4 [The accused entered court]

5 --- Upon commencing at 9.31 a.m.

6 JUDGE MAY: Yes, Mr. Milosevic.

7 WITNESS: WITNESS C-060 [Resumed]

8 [Witness answered through interpreter]

9 Cross-examined by Mr. Milosevic: [Continued]

10 Q. Witness C-060, yesterday we left off talking about the fact that

11 you were a legalist while you were explaining an answer to some of my

12 questions. Yesterday, during the examination-in-chief, when asked about

13 the conduct of the Croatian police towards the Serbs, you said that they

14 behaved inhumanely. Could you describe what you meant by that?

15 A. Well, they behaved contrary to their own rules of service and

16 their own laws, and in relation to us, the detainees, we had different

17 treatment, different from the other prisoners. When I said "inhumane," I

18 meant that they curtailed some of our basic rights that detainees are

19 accorded while investigations are under way.

20 Q. Did they abuse you physically? Did they beat you?

21 A. Not in the investigation process, during that.

22 Q. When did they beat you, then?

23 A. Well, when I was in the camp, before I was detained.

24 Q. How long did you spend in the camp before you were detained?

25 A. I spent four days there. The rest of the people spent longer.

Page 12080

1 Q. Did they beat you throughout those four days?

2 A. No.

3 Q. Did they interrogate you while they were beating you or did they

4 just beat you?

5 A. Well, I received several blows from the military investigators

6 while they interrogated me.

7 Q. And do you know the name of the chief of police in Osijek, the

8 Croatian chief of police? Kir-Reihl was his name. Does it ring a bell?

9 A. Yes.

10 Q. He was the chief of the Osijek Secretary of the Interior; right?

11 And as far as I know, he wanted to have the rules prevail and be

12 respected, and that agreements on a cease of hostilities should also be

13 respected, the ones that had been reached between the local population,

14 both Serbs and Croats. Now, do you know what happened to him?

15 A. Yes, I do.

16 Q. Well, what happened to him?

17 A. He was killed in the Tenja settlement, near Osijek.

18 Q. Do you know who killed him?

19 A. Yes. He was killed by the members of the paramilitary units of

20 Croatia, or the ZNG, the Croatian National Guard Corps. I don't know who

21 they actually belonged to. But there was a lot of publicity about that in

22 the media.

23 Q. Do you remember that immediately after he was killed, those same

24 paramilitary units attacked Borovo Selo, and once again violated the

25 agreement that had been reached about the cease of hostilities?

Page 12081

1 A. Well, I don't know whether it was these units that attacked, but I

2 do know that the police forces attacked Borovo Selo.

3 Q. Very well. On page 5, paragraph 3 of your statement, you say that

4 Ilija Sasic was the government representative of the RSK, the Republic of

5 Srpska Krajina in Belgrade. Is that correct?

6 A. No, I did not state that. I didn't say that Ilija Sasic was

7 representative of the government of Srpska Krajina, because he wasn't. He

8 was a representative of the SAO for Western Slavonia in the Western

9 Slavonia department.

10 Q. Well, he was representative of Western Slavonia in the department

11 for Western Slavonia; is that what you said?

12 A. Yes.

13 Q. Do you know that that man was never a representative of Western

14 Slavonia but that it was Vladimir Simpraga, and he's also from Podravska

15 Slatina? He was the representative.

16 A. Yes, Vladimir Simpraga was in that office, or bureau, too.

17 Q. In your statement, you go on to explain that - how shall I put

18 this? - you were forced to put on a uniform making you member of the

19 Territorial Defence of Slavonia; is that right?

20 A. Yes, that's right.

21 Q. All right. Why did you not tell us about the fact that at the

22 beginning of 1992, you were deputy commander of the operative zone of

23 Territorial Defence, Colonel Vojinovic, you were his replacement. Did

24 somebody force you to take up that position as well?

25 A. No. I was never Colonel Vojinovic's deputy.

Page 12082

1 Q. So you say that you were not his deputy in the TO operative zone;

2 right?

3 A. Yes, that's right, never.

4 Q. All right. Very well. Now, tell me: When were you involved for

5 the first time within the formation of the armed forces of the FRY?

6 A. When I had finished my military service. That was the first time

7 that I was engaged.

8 Q. All right. At the end of the 1970s, were you the deputy head of

9 Territorial Defence for Podravska Slatina?

10 A. No, never. I was never deputy head of the Territorial Defence of

11 Podravska Slatina.

12 Q. Apart from being in the army doing your military service, you were

13 not in the Territorial Defence and were not involved in any assignment?

14 A. I was in the Territorial Defence, but not the assignment that you

15 have just mentioned.

16 Q. When were you in the Territorial Defence?

17 A. From 1969 until 1971.

18 Q. After 1971, up until the war, you were no longer involved in the

19 Territorial Defence anywhere?

20 A. I was member of the reserve force of a unit that was a

21 reinforcement for the JNA.

22 Q. Was there any mention with respect to the matter you spoke about

23 yesterday, when you said that you were taken to trial without any grounds

24 for that and that you were relieved of your responsibilities because of a

25 psychological disturbance that was observed?

Page 12083

1 A. No, that's not correct.

2 Q. But were you examined by a neuropsychiatrist?

3 A. Yes.

4 Q. Why were you examined by a neuropsychiatrist, and when did this

5 take place?

6 A. I was tested to see my reactions when imbuing alcohol.

7 Q. That means that you were prescribed compulsory psychiatric

8 treatment; is that it?

9 A. No. No, Mr. Milosevic. You're asking me something about --

10 JUDGE MAY: Let the witness finish.

11 What were you going to say?

12 THE WITNESS: [Interpretation] I wanted to ask Mr. Milosevic to ask

13 me questions that are related to this -- the subject-matter, physically,

14 and psychologically, I am quite healthy, and I don't like his

15 insinuations. They are playing up to the public and have nothing to do

16 with the case in hand.

17 [Trial Chamber confers]

18 JUDGE MAY: Yes, Mr. Milosevic. We're going to stop this line of

19 questioning. It's personal, intrusive, and has no bearing on the case.

20 THE ACCUSED: [Interpretation] All right. Fine, Mr. May.

21 MR. MILOSEVIC: [Interpretation]

22 Q. After that, you were employed in a number of companies, as far as

23 my information tells me, in Frigus, in Slavonska, from Podravska Slatina,

24 then Univerzal, another firm, and then in the municipality of Podravska

25 Slatina as a clerk in the economic department?

Page 12084

1 MR. NICE: This is not appropriate material for open-session

2 examination.

3 JUDGE MAY: Yes.

4 MR. NICE: The accused should know that. I'm sure he does.

5 JUDGE MAY: We'll go into private session.

6 THE ACCUSED: [Interpretation] Well, I haven't got any questions

7 for private session, actually, Mr. May. Nothing to ask.

8 JUDGE MAY: Any personal questions into private session. Remember

9 that.

10 THE ACCUSED: [Interpretation] All right. Fine. I didn't

11 understand that this was something that we should go into private session

12 for.

13 MR. MILOSEVIC: [Interpretation]

14 Q. Now, why did you change jobs, Mr. C-060, so often?

15 A. Because my profession is a specialised one, in the sphere of

16 finance. I was head of the accounts department very frequently, and I was

17 tested on several occasions when it came to the law on incomes policy and

18 taxation, and that was applied. And in the local community, in my

19 municipality, very often people tried to sidestep the law, and it was

20 discredited and usually it was the head of the financial department that

21 was held responsible and accountable, and I didn't want to allow myself to

22 be in that position. And I did have problems because of that with my

23 comrades. If you will allow me to say so. I say this without any

24 cynicism, because that's how we addressed each other, as comrades. We

25 would say comrade to one another.

Page 12085

1 Q. You're talking about your work in [redacted]

2 [redacted]?

3 A. Well, I didn't work anywhere else.

4 Q. All right. Fine. Now, why do you say that the Territorial

5 Defence staff was responsible for these alleged crimes in Cetekovac?

6 A. Well, if I was at the head of that staff, I would have felt myself

7 to be responsible. I couldn't see it in any other light.

8 Q. So if I understand you, it is the staff who was responsible for

9 all the crimes and Veljko Dzakula who was the prime minister of SAO

10 Western Slavonia at that time is not responsible. Am I reading you

11 correctly?

12 A. Well, Veljko Dzakula was not prime minister of the SAO Western,

13 the Slavonia government at the time.

14 Q. Well, what was he?

15 A. I didn't know him at the time. The authorities hadn't been

16 established, the Assembly hadn't been established, et cetera, and you

17 ought to know that.

18 Q. When was that?

19 A. The incident in Cetekovac took place at the beginning of

20 September. The government and the Assembly were established at the end of

21 October.

22 Q. All right. Now, when did you see Mr. Dzakula for the first time?

23 When was the last time you saw him?

24 A. That's a private question. It has no bearing on the case. But I

25 can't remember. I did see him, let's say, this summer perhaps.

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Page 12087

1 Q. But at any rate, you say that the government wasn't functioning at

2 that time and that you didn't have any kind of leadership there at that

3 time.

4 A. In that respect, Mr. Milosevic, I have given very specific

5 statements and observations made in my statement in that regard, and I

6 said that the authorities, both civilian and military, were in the

7 structures of the Territorial Defence, comprised therein.

8 Q. All right. Very well, let's dwell on that for a moment. You say

9 that Veljko Vukelic at the time was head of the staff of Territorial

10 Defence for Podravska Slatina and Western Slavonia; is that right?

11 A. No. What I claim is that he was at the head of the Main Staff of

12 Western Slavonia. That's all.

13 Q. All right. Very well. Now, tell me in precise terms when Vukelic

14 headed the Territorial Defence staff, in date terms.

15 A. Well, I can't give you the exact date, but it was in the summer,

16 in August, that he was elected as staff commander for Western Slavonia,

17 and in October perhaps he was replaced by somebody else, by some other

18 people, and I think I state which those people were in my statement.

19 Q. All right. Now, do you happen to know, because I have some

20 information here which differs rather, that Veljko Vukelic was never the

21 commander of the TO staff, just the charge d'affaires of the staff

22 commander, an acting staff commander from the 15th of September until the

23 15th of October, 1991.

24 A. Well, I heard that he had been appointed from my friends, who

25 worked with him at that time, and later on, quite a bit later on, I heard

Page 12088

1 about this, but I did hear it from informed sources.

2 Q. When did you hear about that?

3 A. Well, let's say in the course of 1992, or perhaps even at the end

4 of 1991, when I met the people who had been working with him and who set

5 up the staff together with him.

6 Q. All right. But in view of my facts that say that he was the

7 acting chief from the 15th of September to the 15th of October, which

8 makes it a one-month period, according to the information I have before

9 me, this event in Cetekovac took place on the 10th of September; is that

10 right?

11 A. No. The 4th of September.

12 Q. Right. The 4th of September, when the TO did not in fact have a

13 commander at all.

14 A. Well, I cannot testify about that, because according to my

15 information, the Main Staff of the TO of Western Slavonia was formed

16 earlier on. But I don't have any precise information on that score.

17 Q. All right. On page 5, paragraph 4 of your statement, you say that

18 on several occasions you were arrested by a group of men in black, led by

19 a man called Stojan Gustin from Lozane who was in the Djuro Decak

20 paramilitary unit; is that right?

21 A. Yes. His name was Stojan Gustin, and I only heard that they were

22 members of his sort of private army, who abused me in Slatina, mistreated

23 me in Slatina.

24 Q. As far as I understand it, this was a Croatian paramilitary group.

25 A. Well, it was some sort of paramilitary group, but it had no

Page 12089

1 insignia or patches to show which group it actually was.

2 Q. All right. From your statement, I gather that you were no kind of

3 Serb nationalist but that you advocated brotherhood unity of the Croatian

4 and Serbian people. Why then did the Croats arrest you on several

5 occasions?

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Page 12090

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9 Q. You claim that you did not agree with the appointment of Rajko

10 Bojcic as commander of Territorial Defence in Ceralije, and that you

11 expressed to Trbojevic your disagreement with this appointment; is that

12 right?

13 A. Yes, that's right.

14 Q. Tell me, please: What position did you hold at that time when you

15 were able to freely express your disagreement, especially since you were

16 mobilised by force?

17 A. Your Honours, all of these information can threaten my identity,

18 so I ask that you take measures to protect it.

19 JUDGE MAY: Yes. Let's go into private session and deal with all

20 these matters.

21 We'll go into private session.

22 [Private session]

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18 [Open session]

19 THE ACCUSED: [Interpretation] Mr. May, I have no wish to threaten

20 safety of this witness. It's just that the issue of what is relevant and

21 what is not relevant is quite a relative one, and I definitely will not

22 mention anything that could possibly identify this witness in an open

23 session.

24 MR. MILOSEVIC: [Interpretation]

25 Q. Mr. C-060, can you tell me, please: How long did Croatia stay

Page 12093

1 within the SFRY?

2 A. Based on the generally accepted fact, it is believed that it

3 stayed within the SFRY until it was recognised by the international

4 community, which was sometime in February of 1992. However, in Croatia it

5 is believed that the important date was the October of 1991, when Croatia

6 passed a decision on its independence.

7 Q. All right. Well, does that mean, then, that up until that time,

8 in the territory of Croatia, the laws of SFRY were in force?

9 A. Based on my belief, yes.

10 Q. Do you know that the Yugoslav People's Army, including the

11 Territorial Defence, as part of that defence system of armed forces of

12 SFRY, and their organisation, were regulated by federal law?

13 A. Yes, certainly.

14 Q. You say, on page 8, paragraph 3, that the Territorial Defence of

15 Pozega, Orahovac and Slatina were not subordinated to the JNA. Is that

16 right?

17 A. Yes, that's right.

18 Q. Now, tell me, please, since I don't quite understand this, and I'm

19 not being ironic right now: How come the Territorial Defence existed in

20 the territory of Podravska Slatina municipality? You should have known

21 this?

22 A. There was a special law in Territorial Defence in every republic

23 and at the federal level. This is well known.

24 Q. All right, then. So the Territorial Defence of Slatina was not

25 subordinated to the JNA, but based on what you say, the JNA coordinated

Page 12094

1 supply of the Territorial Defence; is that what you're saying? Or do you

2 think that that's how it was?

3 A. Yes. What I testified to is something that I knew, or something

4 that I saw or something that I heard, but I clearly stated that, if that's

5 the case.

6 Q. All right. Well, can you tell me this: Do you know how was this

7 supply implemented? You said that the JNA supplied the Territorial

8 Defence but did not have command over it.

9 A. I gave a number of examples, the ones that I knew, about how the

10 5th Corps supplied the Territorial Defence in Slatina territory. Out of

11 the funds that were used to pay members of the Territorial Defence, they

12 also supplied weapons, equipment, ammunition, and everything else that is

13 needed in order to round up the equipment of the units, and it was quite

14 clear, not only to me, who was a member of the staff, but also to others

15 who were not members.

16 Q. All right. That's what I would like to clear up. Do you know

17 that a large number of members of Territorial Defence - and I don't mean

18 only in Slatina or only in Croatia, because, as far as I know, this

19 applied to entire territory of Yugoslavia - that these people were issued

20 with uniforms and military equipment in the place where they resided, and

21 that was a long time before 1990? This was the system of the Territorial

22 Defence. They were issued certain equipment, uniforms, and so on. Do you

23 know about this or not?

24 A. Yes, I do. I was a member of that.

25 Q. So you were issued with a uniform as well as a reservist or as a

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Page 12096

1 member of the Territorial Defence; isn't that right?

2 A. Yes, while I was in the reserve forces.

3 Q. And up until what time did this apply?

4 A. Until 1986.

5 Q. So this was a general practice at that time?

6 A. Yes, that's right.

7 Q. So they didn't just start supplying them in 1990, 1991, the army

8 didn't start supplying them at that time, but rather, the people all had

9 equipment at home; isn't that right?

10 A. Yes, and those who didn't have it were supposed to be issued with

11 it.

12 Q. So did they receive all this from the JNA or from some depots of

13 Territorial Defence in their locality where Territorial Defence existed?

14 A. In my statement, I said that part of the equipment was received

15 from the depots of Territorial Defence as much as available. Since there

16 was a depot in Slatina, the Serbs didn't have it, and they obviously

17 needed to procure it from somewhere.

18 Q. All right. But in view of this, you were part of this system.

19 So is it logical, and do you know that every Croat also had this equipment

20 and the uniform, every Croat that was a member of the Territorial Defence

21 reserve forces? Isn't that right?

22 A. Yes, that's right.

23 Q. Now, tell me, please: Why is it that after these multiparty

24 elections and after the power was taken over by the HDZ there were no

25 Croats among the TO or reserve forces of the JNA?

Page 12097

1 A. Because they believed the JNA to be an occupation force, occupying

2 army, at least those were the slogans that they used.

3 Q. All right. And why did you refuse to put on a uniform of the ZNG

4 in 1991? You probably could have done this.

5 A. I never accepted wearing any uniform, if I had an opportunity to

6 declare my wishes. The only uniform I wore was the one of the JNA, and I

7 told you that was because I was a legalist.

8 Q. In 1991, the ZNG existed there in the territory of Croatia, where

9 federal laws of SFRY were still in force. Did this ZNG then represent a

10 paramilitary formation?

11 A. Within the interpretation of the federal legislation, yes, but

12 Croats believed that they had to defend their right to this. I, as a

13 legalist, obviously cannot accept this, because I did not believe this to

14 be the actual situation, and I also believe the ZNG to be a paramilitary

15 formation.

16 Q. All right.

17 THE ACCUSED: [Interpretation] Mr. May, I'm about to mention

18 somebody's name, so perhaps we should go into private session so that I'm

19 not later on accused for threatening the identity of this witness. So

20 could we please go into private session.

21 [Private session]

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11 [Open session]

12 THE REGISTRAR: We're back into open session, Your Honours.

13 MR. MILOSEVIC: [Interpretation]

14 Q. Tell me, Mr. C-060: As far as I understand it, you are living in

15 Croatia today.

16 A. Yes.

17 Q. Tell me, please: Is it by chance that you, as a former member of

18 the TO, are saying about the alleged crimes of that same TO is identical

19 to what was said about the event by the former chief of police from

20 Podravska Slatina, Dzuro Matovina, who testified here? You had occasion

21 to see him?

22 JUDGE MAY: No. I'm not going to allow this question. First of

23 all, I suspect we should be in a private session if you're going on with

24 this line of questioning, in any event. Secondly, it's not for him to

25 comment on some other evidence which has been given here.

Page 12105

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14 [Open session]

15 JUDGE MAY: Which document are you referring to?

16 THE ACCUSED: [Interpretation] The one with the number 59,

17 attachment 59. He can look at it. The witness can have a look at it.

18 MR. MILOSEVIC: [Interpretation]

19 Q. Be kind enough and tell me on what grounds are you making the

20 conclusion that this is an authentic document, even though you've never

21 seen him, as you said yourself. Did I understand what you said correctly,

22 you never saw this document?

23 A. I did not.

24 Q. But you still claim that it could be authentic?

25 A. I allow for the possibility that it could be, but I'm not claiming

Page 12107

1 that it is.

2 Q. Do you see any other elements on this document that appear to you

3 to be illogical? Do you see, for instance, that the heading of the

4 document, it says "Volunteers from Serbia, a special unit," and then, in

5 the columns, you have last name, father's name, first name, date and place

6 of birth, place of residence, occupation, qualifications, and everything,

7 all that is written in Latin script and then all the names in Cyrillic

8 script, and so on and so forth. Because you said that this was a document

9 compiled in the way in which documents were compiled, was that the

10 customary form for the heading to be written out by hand? Is it logical

11 for you, because it is handwritten, for a part to be written in Cyrillic

12 and another part in Latin script?

13 A. There is something that is very well known for the people living

14 in my part of the country, and that is how one can write in Cyrillic

15 script, and what that script looks like when somebody is trying to imitate

16 it. That is why I thought and allow for the possibility, as there are two

17 different handwritings, I write both Cyrillic and Latin scripts well, but

18 I know how the people around me do it. And it is quite possible, though

19 I'm not claiming that - that's what I said - but I do allow for the

20 possibility that this could be an original document. I'm not emphatically

21 claiming that, as you are trying to intimate.

22 Q. That is what I wanted to hear. You're not claiming that you know

23 that it is an authentic document, nor do you think that it is certainly an

24 authentic document; you're just allowing for the possibility that it might

25 be.

Page 12108

1 A. Yes.

2 Q. But not with a high degree of probability, as far as I gather. Is

3 that right?

4 A. Yes. I didn't say what degree of probability there was in my

5 judgement, but certain elements could allow both possibilities.

6 Q. Very well. How do you explain that on top it says "Special unit"

7 in the heading and, and then we can see that these are all civilians,

8 employed, unemployed, private entrepreneurs, worker, worker, entrepreneur,

9 locksmith, mechanic, welder, et cetera? From the contents, don't you

10 think it is rather illogical for somebody to have written this out in this

11 way in Latin script, this heading, "Special unit," consisting of

12 entrepreneurs, manual workers, welders and locksmiths?

13 A. In improvised conditions, all kinds of things were done,

14 Mr. Milosevic.

15 Q. Very well. Tell me, with what degree of certainty could you say

16 that this is a forgery or an authentic document?

17 A. I couldn't give you any degree of probability. I've given you

18 various elements. I said that it was possible. It is not customary in

19 this way, and few people could write Cyrillic in this kind of handwriting.

20 Q. Have you noticed that this was not a form that anyone could

21 obtain, but rather, anyone could have drawn it with a ruler? It's not a

22 printed form; it's a form made out in handwriting. Let's not dwell on

23 this, Mr. C-060.

24 Do you know -- please give me a precise answer. Do you know who

25 committed the crime that you mention in Vocin? Do you know who were the

Page 12109

1 perpetrators?

2 A. I do not.

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9 A. I'm asking Your Honours: Is this in private session, please?

10 JUDGE MAY: No.

11 Go into private session.

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7 [Open session]

8 THE REGISTRAR: We're back into open session, Your Honours.

9 MR. MILOSEVIC: [Interpretation]

10 Q. All right, Mr. C-060. You spoke about some crimes in Western

11 Slavonia. You spoke about the time when the SFRY still existed, as did

12 JNA. What has this got to do with Serbia and me, as the president of

13 Serbia? You testified here about that in order to support the indictment

14 against me and what Serbia allegedly did regarding that. What has Serbia

15 done in Western Slavonia?

16 A. I'm testifying here about the facts, events, and people, as I know

17 them and remember them from that period of time. And as to what that has

18 got to do with you, these facts, these names, and these events will

19 testify to that. And I repeat once again: Mr. Milosevic, I'm not

20 accusing here anybody. That is not my role here. I'm simply testifying

21 about things I know.

22 Q. All right. Other than the name I mentioned in private session,

23 you spoke about an arson in a house, for which you say was most probably

24 set on fire by some three people that you met half an hour prior to that,

25 and then you describe some other violent event that took place at that

Page 12124

1 time. So does this time coincide with the time when the population and

2 Territorial Defence, under pressure of Croatian forces, left that

3 territory?

4 A. Yes.

5 Q. Yesterday you said that you had to explain something regarding

6 that, and then you were told that you shouldn't explain anything but

7 simply continue. So now please be kind enough to explain that.

8 A. I can't remember now what was that all about, but I suppose it had

9 to do with the circumstances that prompted the people to leave. I guess

10 that's something that I wanted to describe then.

11 Q. All right. I took it that you explained the circumstances under

12 which the people left Western Slavonia and that it had to do with rumours

13 that circulated about the preparations taken by Croatian forces to attack

14 that area, not because of the attack. So they didn't leave because of the

15 attack. Was that the gist of your explanation of the reasons why the

16 people left that area together with the Territorial Defence, allegedly?

17 A. No. The matter is much more complex. Psychosis and fear are much

18 stronger than any enemy, and those who did not experience this cannot

19 testify about this, regardless of the instructions they received to this

20 effect. The situation then was such that not much was needed to

21 set those people in motion. I wasn't there on that day, and I can't tell

22 you which spark set this in motion, but I can tell you about what I

23 heard. One village was set in motion, and then the others followed suit.

24 Q. All right. So if there was panic and rumours, and if this is why

25 people were set in motion, and not because of the attack, then who

Page 12125

1 destroyed and set on fire all of those Serbian villages in Western

2 Slavonia? Was it the rumours that did it or was it Croatian paramilitary

3 forces and police?

4 A. Those villages around Vocin remained intact except for one part

5 that was destroyed by members of the Territorial Defence in Vocin, and the

6 rest remained intact. And it was definitely not destroyed by Serbs.

7 Q. You said it wasn't destroyed by Serbs?

8 A. Yes, it wasn't destroyed and torched by Serbs.

9 Q. Then who did it?

10 A. The Croatian state. I can't say anything else, because the state

11 of Croatia was there in that territory at that time.

12 Q. All right. If you say that those Serb villages were torched by

13 the Croatian state, which are undisputed facts, that they were torched by

14 Croatian police and its formations, is it clear, then, that those Serbs

15 who fled did not flee because of rumours but because of the attack that

16 was perpetrated in that area, in the area of Western Slavonia? Is that so

17 or isn't it, Mr. C-060?

18 A. At the time when Serbs were retreating from the Vocin area, there

19 was no such attack that would represent that type of danger, because there

20 were no wounded or people that were killed there. It wasn't the

21 situation, based on what I heard from the people who survived that. You

22 are now asking me this in the context of the event or in the context of

23 the crimes that were committed in Vocin. I testified about what I know

24 based on my conversations with people who were there, who heard it or saw

25 it personally or heard this from somebody.

Page 12126

1 Q. All right. I would remind you, and if I'm not right about this,

2 you can correct me. I asked you half an hour ago about whether you knew

3 who committed those crimes in Vocin, and you said you didn't know.

4 A. I wasn't there. I didn't see that. But I was with those people.

5 I know those people. And finally, I'm still living with those people now.

6 And regardless of the passage of time, people heard there in their place

7 about who did this and they recognised those people, regardless of their

8 masks.

9 Q. All right. You accused here people called Simic and Ivanovic.

10 A. No, that's not right. I didn't accuse anybody.

11 Q. You mentioned these people and you explained that they were

12 recognised by some locals even though they wore masks. So how could they

13 recognise them if they wore masks?

14 A. Well, these questions, Your Honours, have to do with answers that

15 could reveal my identity.

16 Q. I don't know if there is a single question that doesn't have to do

17 with your identity. You spoke about the 13th of December, 1991, when 22

18 villages, based on your testimony -- or rather, the residents of those

19 villages retreated, in panic. They fled, together with the Territorial

20 Defence, before these attacks that you qualified as acts committed by

21 Croatian state, those villages destroyed and so on. So is it possible

22 that in this huge state of commotion and chaos, in view of panic that

23 existed in those 22 villages, is it possible to know who committed what

24 crimes, who shot at whom and who was responsible for murdering somebody in

25 that territory and along that road on which the population fled?

Page 12127

1 A. Your Honours, are we in private session?

2 JUDGE MAY: No. We'll go into private session and then we'll

3 adjourn. Yes, we'll go into private session and then we'll adjourn

4 [Private session]

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10 [Open session]

11 MR. MILOSEVIC: [Interpretation]

12 Q. All right. So in these events that you described, the crimes that

13 you described and the retreat of inhabitants of 22 villages who felt

14 threatened by the attack of Croatian forces and so on, did I understand

15 you well that there was in fact no JNA presence in that area?

16 A. During my testimony, I never said that there was JNA there.

17 Q. All right. It's very important to make sure that this is clear.

18 You mentioned some involvement of the Serbian Radical Party, and then

19 later in your explanations you also said that the Serbian Radical Party

20 was established, as you said, in Okucani, only as late as in 1992. Is

21 that right or not?

22 A. Yes, that's right.

23 Q. Then I suppose that it couldn't have been involved -- particularly

24 involved prior to being established in that area.

25 A. I spoke about seeing representatives of that party in Western

Page 12131

1 Slavonia.

2 Q. Yes, but based on what I saw in documents, the Serbian Radical

3 Party claimed that it supplied volunteers only for the JNA and the army of

4 Republika Srpska; therefore, that it did not have any paramilitary

5 formations of its own.

6 A. I had an opportunity, and I mentioned this in my testimony, to see

7 a document which had spoke about the fact that a group of volunteers, 17

8 of them, in fact, were mobilised to that effect and came to Western

9 Slavonia.

10 Q. All right. When you were questioned about those 17 volunteers,

11 you replied that you did not know who led them. And then you were asked

12 whether that was somebody called Novacic, and you replied that that name

13 sounded familiar, it reminded you of somebody. So does this mean that

14 these 17 volunteers, for whom you say were volunteers of the SRS, were in

15 fact led by somebody called Novacic?

16 A. I testified, and I remain by what I said previously, that it is

17 possible that that man was their leader, or rather, that the man that I

18 saw as their leader could be called Novacic. Yes, that name rings a bell.

19 I heard that name. But as to whether this is the name of that man I can't

20 claim that.

21 Q. All right. I heard your name many times, but I don't know whether

22 it referred to you. I also heard your name mentioned a number -- many

23 times, but it wasn't you. So how can you in fact claim that these people

24 were a paramilitary unit of the Serbian Radical Party when this party

25 claims that it did not have any paramilitary formations?

Page 12132

1 A. I will repeat and say that I was present when they arrived. I

2 wasn't supposed to be informed of this; however, my commander asked for

3 this, for me to be there. I guess he wanted to show off a little bit.

4 And when I asked who were these people and where they came from, he

5 produced a document, a certificate that was issued in Belgrade, in the

6 office for recruitment and so on - I can't recall all of the details now -

7 but that document confirmed, with full certainty, the identity of these

8 people.

9 Q. Very well. You were asked here whether you saw a paramilitary

10 group led by Franko Simatovic. You said that you had not ever seen a

11 paramilitary group, nor anything that could link a group to Simatovic.

12 A. Yes. I had never heard of that name, and I can't say anything

13 about it. I didn't see it and I didn't hear it. That's what I said.

14 Q. That's why I'm asking you, because this first and last name is

15 linked to one of the members of the security service of Serbia, and

16 therefore an effort was made here to link their activity with the

17 activities in Western Slavonia. So you assume that, in view of the fact

18 that you were in the area, that it is not a large area, that if anything

19 like that existed over there, I assume you should have known about it.

20 A. Possibly, but I must say that there were quite a number of people

21 in the Main Staff of Western Slavonia that I had never heard of. They

22 were remote, in a remote location.

23 Q. I gathered from the testimony here, before you there was another

24 protected witness, and you know him well, so I won't mention his name

25 anyway, and mention was made in many that testimony of people primarily

Page 12133

1 who were born in the area, regardless of whether they lived there during

2 the relevant events or not, that they had come to assist in the defence of

3 the population. So mostly they were people, natives of the area. Is that

4 your impression or not?

5 A. Yes.

6 Q. Very well. You mentioned in a part - you pointed it out on the

7 map - of a unit of the Banja Luka Corps. This was, if I'm not mistaken,

8 at a time while the JNA was still functioning in that area, and it was

9 also the area of responsibility of the Banja Luka Corps, was it not?

10 A. Yes, it was.

11 Q. Namely, is it true that various corps or the distribution of zones

12 of responsibility of military units in the SFRY did not coincide with any

13 republic borders? So when it's called the Banja Luka Corps, it doesn't

14 mean that it has to be limited to the borders of the former Bosnia and

15 Herzegovina, but it has its own territory according to the military

16 structure, and not to coincide with the administrative division of

17 Yugoslavia. Is that right?

18 A. That's right.

19 Q. You were asked here about Jovo Vezmir, and you said he was there

20 briefly and that after that he went to Serbia. Do you know that in Serbia

21 at the time, there were already about 600.000 refugees from Croatia and

22 Bosnia and Herzegovina, or rather, in 1991, there were much fewer, but

23 later on the number went up to 1 million refugees?

24 A. I do know that refugees went to Serbia. I know that. But how

25 many, what the numbers are, I don't know. But there were quite a large

Page 12134

1 number from my area as well.

2 Q. You said, in connection with certain events, that you had warned a

3 certain Bojcic, cautioned him, that you would report him to the military

4 authorities in Banja Luka. What was he doing that prompted you to make

5 such a warning, to put it mildly, that you would report him to the

6 military authorities in Banja Luka? And at the same time, let me ask you,

7 to save time: Did you report him to the military authorities and was

8 anything done in that connection?

9 A. I reported him, but whether anything was done, I don't know.

10 [redacted]

11 [redacted]

12 [redacted]

13 A. These questions, Mr. Milosevic, enter into the sphere of my

14 integrity.

15 Q. Very well. I won't ask you those questions, then, because we keep

16 going into private session. You said that his office, after the territory

17 was abandoned, was situated in the building of the command of a brigade

18 belonging to the Banja Luka Corps. He was virtually a refugee, and he set

19 up his office in a military building, not in the corps headquarters, but

20 one that was closest to him. Is that right?

21 A. The answer is the one I gave in my statement.

22 Q. Is it true, Mr. C-060, that he neither had, nor could have had,

23 any kind of authority with respect to any JNA command, even at the lowest

24 level, and that he may have been given hospitality in a certain building

25 to have his office there as the premises of the Assembly of which he was

Page 12135

1 the president?

2 A. Probably.

3 Q. So is it true that he could not have had any competence or

4 authority over any JNA unit?

5 A. It would have been strange if he had had any authority, because

6 there was a military hierarchy and a separate civilian hierarchy.

7 Q. Of course. That is why I wanted to make this quite clear, because

8 here the fact that some events coincide seems to be used as an

9 illustration of links between the JNA and other institutions.

10 A. Yes, but competence is one thing and links are another thing.

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Page 12136

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4 Q. Tell us what event you're referring to.

5 A. I wouldn't like to do that in open session.

6 Q. Not to go into private session again, do you assume that if

7 anything like that happened, as you're claiming, in that area, and he was

8 the Minister of Police, do you know with certainty that he did not

9 undertake any measures against the perpetrators of this act you are

10 referring to, or are you claiming that he didn't want to take any steps?

11 A. I don't know anything about his activities in that connection, and

12 I didn't testify about that.

13 Q. So you cannot claim that he didn't do anything as the Minister of

14 Police against the perpetrators of a crime, if such a crime happened?

15 A. I didn't claim that, and I do not claim that. But I do know that

16 in some cases, such things were not operationalised while I was there.

17 Q. You mean in Western Slavonia?

18 A. Yes, I mean in Western Slavonia.

19 Q. You know that Martic was not in Western Slavonia?

20 A. He was in the Republic of Srpska Krajina. That is quite some

21 distance away for him to know about it. But that did not prevent him from

22 arresting me.

23 Q. I'm not entering into your internal disputes and relationships

24 between the leadership that you yourself elected and yourself. I really

25 don't want to go into that.

Page 12137

1 You said that a certain Zarkovic threatened Dzakula and tried to

2 persuade some people to kill him even. How did you come to know that, and

3 did anything happen to Dzakula? Did anyone try to assassinate him?

4 A. I was present in the area, and I heard this from people who were

5 serving under the command of Mr. Zarkovic. It so happens that these

6 people are from my area, and I heard this from them. Now, whether they

7 said this lightheartedly or laconically, I don't know, but that is what

8 they said, without any doubt.

9 Q. But from what you are saying, they had no intention of doing

10 anything against Mr. Dzakula; is that so?

11 A. If one can believe what the people said, and I believed what they

12 said and I acted accordingly. I begged, threatened, tried to influence,

13 and so on.

14 Q. So you're saying that you did everything you could to explain that

15 one should not commit an act of violence against anyone; is that what

16 you're trying to say?

17 A. Yes.

18 Q. Very well?

19 JUDGE MAY: Mr. Milosevic, your time is now up. Do you want to

20 ask another question or two?

21 THE ACCUSED: [Interpretation] Well, let me then reduce it to two

22 questions.

23 MR. MILOSEVIC: [Interpretation]

24 Q. Please, you said, towards the end of your examination yesterday,

25 that Radovan Karadzic was the mentor of Hadzic. How do you know that?

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Page 12139

1 A. You will allow me to have my convictions about people I lived with

2 and on whom my destiny depended. So allow me to have that right, to have

3 a position about that.

4 Q. Yes. You have a definite position about it. And then you went on

5 to say that the Serbian Democratic Party of Krajina and the Serbian

6 Democratic Party of Republika Srpska joined to form the Serbian Democratic

7 Party of Serbian lands. Is that what you said?

8 A. But you know that too.

9 Q. Of course I do. But do you remember well that it was precisely

10 that Serbian Democratic Party of Serbian lands that was in opposition in

11 Serbia and that it participated in the elections in Serbia as an

12 opposition party?

13 A. I know that.

14 THE ACCUSED: [Interpretation] I've asked the two questions you

15 allowed me to do, Mr. May. Thank you very much.

16 JUDGE MAY: Mr. Kay.

17 MR. KAY: No questions, Your Honour.

18 MR. NICE: A few matters arising, I think most of them in private

19 session.

20 [Private session]

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17 [Open session]

18 THE REGISTRAR: We're back into open session, Your Honours.

19 JUDGE MAY: Thank you. Witness C-060, that concludes your

20 evidence. Thank you for coming to the International Tribunal to give it.

21 You are free to go.

22 THE WITNESS: [Interpretation] Thank you.

23 JUDGE MAY: Mr. Nice, while the witness is going, there are one or

24 two administrative matters, it may be, we can deal with, when you've

25 rearranged your --

Page 12145

1 MR. NICE: I'm ready.

2 JUDGE MAY: The first is the next witness is C-020. I may have

3 recollected this wrong. I thought you said he was here for a limited

4 time. Is that right?

5 MR. NICE: That's right. He -- well, we must get him done by

6 tomorrow.

7 JUDGE MAY: Yes. In that case, we will have to clearly have -

8 allow time for cross-examination, and would you have that in mind, in

9 general terms, there will be a division of the time.

10 MR. NICE: I will have that in mind.

11 [The witness withdrew]

12 JUDGE MAY: Yes.

13 Just one moment.

14 THE ACCUSED: [Interpretation] I really don't understand. This

15 next one seems to be a witness that has been introduced on the list

16 subsequently. According to my information, he's an ordinary criminal, a

17 murderer, a looter. How can you --

18 JUDGE MAY: Mr. Milosevic, this is all general comment. You can

19 cross-examine him in due course about these matters.

20 The explanation of how he has been brought forward in the list has

21 been given, and there has been notification of it.

22 Just two other matters. He's being fetched, I take it. Yes. Two

23 matters I want to raise. First of all, Witness C-036 and the application

24 in relation to Rule 92 bis, we should hear argument on that, possibly at

25 the end of today would be a convenient time to hear argument about it.

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Page 12147

1 MR. KAY: We were actually preparing a paper on that, having only

2 recently got it, which I was hoping to finish off this afternoon.

3 JUDGE MAY: Would you -- very well. If you would finish it this

4 afternoon. Can you let us have a copy? It may be through the usual

5 channels rather than filing it. File it, of course, but also let us have

6 a copy so we can have it tonight. Because we need to resolve the matter

7 tomorrow, if at all possible.

8 MR. KAY: Absolutely. It won't be a along paper, but it's

9 probably of benefit to the Court to have it in paper form.

10 JUDGE MAY: Very well. Thank you. While you're on your feet,

11 Mr. Kay, we've been handed a document which is called "Croatia, a

12 document." It seems to be lines of defence, but it's rather equivocal as

13 to what it is.

14 MR. KAY: The Trial Chamber mentioned that the Kosovo document

15 that was filed was helpful, and it's in similar form to that. It was a

16 strategy document. I can't say that I did the title of it, so what it's

17 been called is slightly different from what I had written in London. But

18 that was meant to be a helpful aid to the Court in relation to defence

19 issues.

20 JUDGE MAY: Thank you.

21 MR. NICE: May the witness come in, in those circumstances.

22 JUDGE MAY: Yes. We'll have the witness, please.

23 MR. NICE: As Your Honour will know from the explanation I gave

24 yesterday, it will be our application to move into private session at a

25 comparatively early stage in this witness's evidence, and then for a

Page 12148

1 significant part of it to be in private session, for fear of his

2 identification otherwise being known, identity otherwise being known.

3 [The witness entered court]

4 MR. NICE: Page 23 of the atlas may be helpful, Exhibit 336.

5 JUDGE MAY: Yes. Let the witness take the declaration.

6 WITNESS: WITNESS C-020

7 [Witness answered through interpreter]

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

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

10 JUDGE MAY: If you'd like to take a seat.

11 Examined by Mr. Nice:

12 Q. You will be known in these proceedings as "C-020." Would you be

13 good enough, please, to look at a peace of paper that's going to be shown

14 to you, and just tell us, please, by the answer yes or no, if the details

15 on this piece of paper before you are correct.

16 A. Yes, they are correct.

17 THE REGISTRAR: Your Honours, it will be marked Prosecutor's

18 Exhibit 346, under seal, confidential.

19 MR. NICE: May we have a couple of minutes of private session

20 before going into open session?

21 THE REGISTRAR: We're in private session, Your Honours.

22 [Private session]

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Page 12149

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11 [Open session]

12 MR. NICE:

13 Q. C-020, did you find yourself drafted and deployed into the Borovo

14 Selo Territorial Defence unit?

15 A. After I had completed the JNA, yes.

16 Q. The word -- or the title "Borovo Selo," is that for our purposes

17 the same place as marked as Borovo on the map?

18 MR. NICE: Perhaps the witness could have a version of the atlas

19 open at page 23 and on view for those looking at -- perhaps it could go on

20 the overhead projector, please.

21 A. Yes.

22 MR. NICE: Place it on the overhead projector. Thank you.

23 Perfect.

24 Q. First a few things about Borovo Selo and the regime there. Was

25 there a prison at Borovo Selo; if so, did you go there, see the prisoners,

Page 12150

1 and what was their condition? And what period are we talking about, just

2 to be precise?

3 A. The prison existed between September, perhaps, until October, that

4 period of time, 1991.

5 Q. Did you visit it; if so, what condition did you see the prisoners

6 to be in?

7 A. Well, it wasn't actually a visit, because the prison was in a

8 compound where the kitchen was and all the other facilities, so I saw the

9 prison like anybody else who could see it while being on the premises

10 there.

11 Q. The condition of the prisoners?

12 A. The prisoners had all been beaten up.

13 Q. Your Territorial Defence unit, did you learn how it had been

14 equipped and armed?

15 A. In the first stage, we didn't have any uniforms and you wore what

16 you had at home. Some people had uniforms which they had made themselves,

17 and the weapons differed, the types of weapons differed.

18 Q. After that first stage, did further supplies arrive; if so, where

19 from?

20 A. After the first stage, we -- most of us had automatic weapons,

21 automatic rifles and semi-automatic rifles, which were considered to be

22 more modern than the type of weapons we had during the first stage.

23 Q. Where did they come from? Who provided them?

24 A. The weapons came to us mostly from Serbia. Who from, I really

25 can't say. I think they were from the stockpiles that the Territorial

Page 12151

1 Defence had, or the JNA.

2 Q. And physically, how did they reach you? Did they come across the

3 river?

4 A. The equipment was taken across the Danube in boats. That was the

5 only passage from Borovo Selo to Serbia.

6 Q. Did you hear, and if so, where from, who it was brought the

7 weapons across the Danube?

8 A. Rumours had it that we were receiving the weapons from the special

9 police in Novi Sad and the state security in Serbia.

10 Q. Had you, in April 1991, when still in the JNA but on leave, heard

11 speeches given at the local community centre building in Borovo?

12 A. I was present during a speech like that.

13 Q. Who did you hear speaking?

14 A. At the time, Milan Paroski came, and so did Mirko Jovovic. They

15 were lower-level politicians in Serbia, weren't too well known. And

16 Vojislav Seselj did come at one point. He came to Baranja.

17 Q. Did you get yourself involved in the security arrangements for

18 those meetings or rallies?

19 A. I joined the security for the very day the rally took place.

20 MR. NICE: Paragraph 5, page 3.

21 Q. Starting in about August of 1991, did you become aware of

22 volunteers in your town or village?

23 A. Yes, there were people who came in from outside.

24 Q. Identify them if you can, either by their group or by their

25 appearance, or both.

Page 12152

1 A. Most of them were people who were from around Vukovar. The Serbs

2 who had left the villages where the local population was Croatian, and

3 there were about 20 people, a group of about 20-odd people that belonged

4 to a group by Mirko Jovic, and they were led by Ostojic, a man called Jovo

5 Ostojic, from Prigrevica.

6 Q. Was there another unit connected with Nova Pazova?

7 A. No. Mostly they were the locals from Nova Pazova, but they were

8 led by Jovo Ostojic, from Prigrevica, and they belonged to the Mirko Jovic

9 group.

10 Q. Very well. Symbols used by these volunteers?

11 A. At that time they didn't have any uniforms. They wore what we

12 wore, what they found. So they had a sort of flag with White Eagles on

13 it, not on their uniforms but on the clothes they were wearing.

14 Q. Were there JNA units present in Borovo Selo in the summer or late

15 summer of 1991?

16 A. Which period do you have in mind?

17 Q. Do you remember the fall of the town or village of Dalj?

18 A. After the fall of Dalj, yes.

19 Q. And that's the period of time. What JNA units, if any, were you

20 aware of then?

21 A. The Pancevo unit that forced the bridge at Erdut, and then there

22 were others along the Dalj-Erdut road.

23 Q. We've now dealt, then, with volunteer groups and with Territorial

24 Defence, of which you were able to help us, and also the JNA. What was

25 the chain of command? Who was subordinated to who, in your judgement and

Page 12153

1 experience?

2 A. Which period do you have in mind again?

3 Q. Again after the fall of Dalj?

4 A. JNA, or rather the offices of the JNA, under them was the

5 Territorial Defence and then the other groups and units.

6 Q. Thank you. In this same period of time after the fall of Dalj,

7 what purpose did the JNA units and their officers appear to be serving:

8 Protection of Croats and Serbs, one from the other, or something else?

9 A. After the fall of Dalj, there was a consolidated action together

10 with the JNA. That means they were on our side.

11 Q. Thank you.

12 MR. NICE: Your Honour, we come to page 4, paragraph 7. With the

13 Court's leave, this is a topic, and it's a substantial topic, that we

14 would ask to be dealt with in private session. And if the Court grants

15 private session, I think it would be safe to say that this would take us

16 until the normal time for rising for the midday adjournment, or the lunch

17 adjournment, in any event.

18 JUDGE MAY: Very well.

19 [Private session]

20 [redacted]

21 [redacted]

22 [redacted]

23 [redacted]

24 [redacted]

25 [redacted]

Page 12154

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Page 12184

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6 [redacted]

7 [Open session]

8 THE REGISTRAR: We're back into open session, Your Honours.

9 MR. NICE:

10 Q. Witness C-020, in Ozren, and we can see this on page 40, I think,

11 or 28 --

12 [Prosecution counsel confer]

13 MR. NICE:

14 Q. While in Ozren, did you learn of training that one group had

15 received from the Red Berets?

16 A. Yes.

17 Q. Who was identified as doing this training, and which group was

18 getting it from the Red Berets?

19 THE INTERPRETER: The microphone is not switched on.

20 A. The specification of the theatre of war in Bosnia, as well as in

21 our area, that small combat groups conducted main operations. This was

22 reconnoitring, reconnaissance, and breakthroughs of certain enemy lines.

23 And the same applied to Ozren. There were these groups. There were two

24 groups, two elite groups, and a platoon of military police. And they were

25 trained by the Red Berets and given some of their equipment. They were

Page 12185

1 better equipped than the local population. I joined one of those groups.

2 MR. NICE:

3 Q. In due course, did you get injured in September 1992 and taken to

4 Doboj hospital?

5 A. Yes.

6 Q. Released from -- discharged from hospital, where did you go?

7 A. Back home to Borovo Selo.

8 Q. In January 1993, did you learn of -- or did you come to be

9 involved with Arkan again?

10 A. With Arkan, after I returned, no. I was sent back to Erdut.

11 Q. If you were sent to Erdut, did you learn of Arkan's forming a

12 particular unit?

13 A. That was after Maslenica fell in Knin Krajina. His unit was

14 engaged to go to that theatre of war, and I joined.

15 Q. Very well. The details of how you joined, did you find yourself

16 at Arkan's unit's gate when he came by in a jeep?

17 A. When I got there, the vehicles were ready to leave. I came at the

18 last minute. And he was in the centre, right by his own car. He sent a

19 soldier to me, and we went to Benkovac, to the village.

20 Q. Yes. And who did you travel with?

21 A. Besides him, there were several other people in the car. I think

22 they were all officers. I can't say whether there were five of us or four

23 of us plus him.

24 Q. When you got to Knin, did Arkan go to a meeting?

25 A. Yes, of course. He went to the meeting in the barracks to see

Page 12186

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Page 12187

1 what operations would be in future and where we would be put up.

2 Q. What was said about anybody, any politician who was present at

3 that meeting?

4 A. The stories that went round among the officers later on, the

5 president of our state at that time was present, Milan Martic.

6 Q. Did you stay active on this particular battlefield until late

7 March of 1993?

8 A. Yes.

9 Q. Operating in various locations that are listed in the summary.

10 The structure of the unit in the Knin battlefield, Arkan in charge. Who

11 else was at the top of the command chain?

12 A. Every officer had an officer under him, and several groups and

13 units. So platoons, groups, reconnaissance groups, sabotage units, et

14 cetera. So after Arkan, there was Legija. After Legija, a series of

15 high-ranking officers.

16 Q. Legija's full name was --?

17 A. Milorad Ulemek.

18 MR. NICE: I needn't trouble the Chamber at the moment with the

19 details of the other names, I don't think.

20 Q. Your unit, did it also collaborate with a Bosnian special unit?

21 If so, what was the name of that unit and by whom was it led?

22 A. We collaborated with the Wolves from Manjaca. It was indirect

23 cooperation and they were led by Veljko Milankovic. And they operated in

24 the same direction as us, so in order to cover the territory, to cover our

25 flanks, whatever, we had indirect collaboration.

Page 12188

1 Q. Were Arkan and Milankovic equals or apparent equals?

2 A. I don't understand. To what objective, what goal, in what sense?

3 Q. You described these two units working together in the cooperative,

4 indirect cooperative way you've spoken of. Were they themselves

5 subordinated to some other person or to some other body?

6 A. Well, every operation that took place there was done in

7 conjunction with the officers of the army of Srpska Krajina, and we would

8 be given our assignments from them. I don't know who gave Arkan his

9 assignments, but Arkan was in command of our unit and our officers.

10 Veljko's unit was commanded by Veljko and his officers. And the operation

11 was received from the headquarters and staff of Srpska Krajina, but who

12 there issued the orders, I really don't know.

13 Q. Do you know whether there was a single person, and if so, of what

14 rank, who was instructing both of these units, commanding both of these

15 units?

16 A. The rank was that of general. Now, what general, I don't know,

17 but I think it was General Mile Mrksic and General Novakovic who were in

18 command, but the rank was that of general.

19 Q. In March of 1993, I think you had some difficulties with a wound

20 you had. And then your unit returned to Erdut and a special unit was then

21 formed. What was the name of that special unit?

22 A. I have a correction to make to what you said. I returned two

23 months before that, before my unit. My unit stayed on for a further two

24 months down there.

25 Q. Thank you. The special unit, what was its name and when

Page 12189

1 approximately was it formed?

2 A. It was formed not long after we returned from the Benkovac

3 battlefield, and it was known as the Super Tigers, Super Tigrovi.

4 Q. Who was the commander of the Super Tigers?

5 A. Legija was.

6 Q. The commander subordinate to him was called what, or was named

7 what?

8 A. Veliki Rambo, big Rambo.

9 Q. His full name was --?

10 A. Bujosevic Nenad.

11 Q. For how long did the Super Tigers train?

12 A. The training lasted until the centre was closed down.

13 Q. Did they in the course of training go out on operations?

14 A. At that time, there were no operations; but if there were, yes,

15 they were conducted.

16 Q. Tell us about their clothing and appearance.

17 A. Their equipment was like the equipment of any elite unit in the

18 world. Most of our equipment was a copy of the foreign legion equipment

19 and NATO uniforms. The weapons were automatic rifles, exclusively with a

20 wooden butt, and we painted them black. And the combat sets, we had the

21 flak jackets. And it was all first-class equipment, state of the art,

22 like any other elite unit in the world is issued.

23 Q. What berets were worn, what colour, and did the colour change at

24 any time?

25 A. We had a number of berets. The young members who were

Page 12190

1 recruited -- do you mean the Super Tigers unit or all of us?

2 Q. Yes. Super Tigers.

3 A. Super Tigers had black berets, black caps, like baseball caps,

4 something like that, and woolen caps as well, combat ones.

5 Q. Did the colour of the caps change at some stage?

6 A. While the Super Tigers existed and the centre was in operation,

7 no, they didn't.

8 Q. Can you help at all with anybody wearing red berets at about this

9 time, and if so, who?

10 A. The Red Berets were worn by the unit that we referred to as Red

11 Berets, and they weren't stationed in our area at that time.

12 Q. Very well. What happened to the Super Tigers? Were they

13 disbanded later that year or at the end of that year?

14 A. The entire centre of the Serbian national guard was disbanded.

15 Some people were called to Belgrade. Whoever wanted to could go to

16 Belgrade to work. I'm referring to the officers, high-ranking and

17 lower-ranking. And they could also work in the field of security, to

18 provide security details for important personages. The people who were

19 from Bosnia were sent home, and the barracks were completely disbanded.

20 MR. NICE: Your Honour, there's an exhibit which comes in a

21 redacted and unredacted form. The fully redacted version may go on the

22 overhead projector.

23 JUDGE MAY: Is this a new exhibit or --

24 MR. NICE: No. It's tab 4 --

25 JUDGE MAY: Tab 4.

Page 12191

1 MR. NICE: Of Exhibit 347. If you would be good enough to place

2 the original version on the overhead projector first so that it can be

3 seen and then show it to the witness. The document with all the

4 identifying material removed. If that can now be handed to the witness,

5 the English version placed on the overhead projector.

6 Q. C-020, is this a document -- you've seen the original with the

7 identifying features included, but it's signed by Milorad [Realtime

8 transcript read in error "Mihajlo"] Ulemek on the 21st of February, 1994,

9 being a certificate in respect of yourself, saying that you served the

10 military post of Erdut on the Serbian -- of the Serbian army of the

11 Republic of Serbian Krajina from a date until the end of December,

12 participating in the war at the Benkovac battlefield. Is that a

13 certificate that was issued to you?

14 A. Yes, that is the certificate that I asked to be given, because I

15 needed to get some documents and I needed a certificate of that kind. And

16 if the signature is that of Milorad Ulemek and not Mihajlo Ulemek, as you

17 said.

18 Q. I'm sorry if I did say Mihajlo. It's my mistake entirely. Very

19 well. You subsequently went to work for a private business. We won't

20 give the detail of that, for obvious reasons. Until in mid-August 1994

21 you were called for in order to report to Belgrade. Is that correct?

22 A. It wasn't an order. It was an invitation. I didn't have to

23 accept if I didn't want to. So it was an invitation to go to work again

24 and to go to the battlefield, the theatre of war again.

25 Q. I think it will probably save time if we do this by your giving

Page 12192

1 the account yourself, and we'll put the other map, the general map, the

2 Times atlas map on the overhead projector. Thank you very much. Exhibit

3 326, tab 1. Now, I know that this map is of a scale that's not entirely

4 easy to use, but I think it's probably better to use a single plan, Your

5 Honour, a single map, and to get the overall geography from the witness.

6 C-020, can you tell us, please, when you responded to the

7 invitation to go to Belgrade, what happened there? And then tell us about

8 the movements that you made, using the map, using the pointer, and moving

9 at a speed that will not be either too fast or too slow for us.

10 A. After I was invited, a vehicle arrived from Belgrade, belonging to

11 our unit, I was transported to our headquarters in Belgrade, and we

12 received instructions there. They told us that if we had any documents,

13 they should be left behind for our own personal safety, our driving

14 licence and everything else that could disclose our identity, that was to

15 be left in the office of the headquarters. After that, as we arrived at

16 different times, as soon as a group had been formed, they told us to go

17 and have a walk around town so as to avoid having a crowd of people in

18 front of the building itself. I don't know how much time within the by,

19 but we gathered together again, and a sort of lecture -- we were given a

20 lecture about morale and so on. And we were told that we would be going

21 to the theatre of war, to Bosnia. We weren't told which part of Bosnia or

22 the objectives of the operation. But after that, the buses arrived. We

23 were taken by bus to --

24 Q. Can I interrupt you for one moment? Who was it who was giving you

25 this talk, and were the people that you were joining up with any of them

Page 12193

1 people you had known from the Super Tigers?

2 A. All the Super Tigers responded. I can't say we all did, but we

3 did in large numbers. Then there were members of other units from the

4 support and reinforcement units, and this morale boosting talk was held by

5 Legija and Arkan himself.

6 Q. Thank you. And back to the buses, and use the map as you need to.

7 A. After that, we were taken to a place called Lipovacka Suma, which

8 is close by Belgrade, which is where the barracks were belonging to the

9 special police, and they were waiting for us there because people from

10 other buses were turning up, not only our people, but buses with others

11 too. We stayed there for a very brief period of time. I can't tell you

12 how long exactly. But after that we were sent to Petrova Gora. No. It

13 was to Mount Tara, Mount Tara, where we stayed for several days so that we

14 could organise ourselves to go to the theatre of war. And to prevent us

15 from getting bored, although we were wearing civilians clothes as we

16 arrived, we would have a theoretical brush-up course on mines, infantry

17 training and so on and so forth, and we would move around the territory,

18 but we were in civilian clothes, so we couldn't move around too much. It

19 would have been silly to move around the forest area and so on.

20 Then we returned from Mount Tara, back to Lipovacka Suma, where we

21 went to the barracks and were given -- we were issued weapons very

22 quickly. They just handed out the rifles and smaller weapons. There was

23 no record of this, not to use it, but to put it in the buses so they could

24 be transported further afield. And a column was organised there, except

25 for the buses, there were trailers there too with the different military

Page 12194

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Page 12195

1 equipment and materiel, trailer trucks. And we started out towards

2 Bosnia, the border with Bosnia. Where we crossed the border, actually, I

3 can't say, but I do know that the border crossing was somewhere nearby

4 Bijeljina. Whether it was Zeljeznicki Most, the railway bridge or

5 Pavlovica Cuprija I don't know, but we had to wait --

6 Q. Pause there. Looking at the map and using the pointer, can you

7 just indicate in general where the Tara place was where you went first?

8 MR. NICE: The Court can also find it on the atlas at page 33, in

9 the north-west corner.

10 A. I can't see anything on this small map.

11 Q. Well, can you just give us the rough -- if you can't, it doesn't

12 matter, but if you can give us the rough area of the Tara mountain on the

13 map, we'd be grateful.

14 MR. NICE: Meanwhile, while that's happening, Your Honour --

15 A. Found it.

16 MR. NICE: Your Honours see he pointed -- that's the shape that he

17 points there is reflected in the top right-hand corner of page 33 of the

18 atlas, which of course shows the western boundary of Serbia and the

19 eastern boundary of Bosnia.

20 Q. So that's where you went first. And staying with this map, can

21 you just -- I'm sure the Judges know, but for others viewing, can you just

22 give a rough indication of where it was you crossed into Bosnia?

23 A. We crossed Bosnia -- into Bosnia around the Bijeljina area.

24 Q. I imagine the Judges will all know where that is. And then where

25 did you go after that?

Page 12196

1 A. After Bijeljina, we set off through the corridor towards Bosnia.

2 We didn't know the exact location until we actually arrived there. We

3 didn't know the direction we were going in. But the next day we ended up

4 the Petrova Gora itself.

5 Q. Very well. Can you point that out on the map for us?

6 A. [Marks]

7 Q. And just, having found it -- there we are. Thank you. So you

8 went through the corridor on the north of Bosnia, passing into Bosnia

9 somewhere in the region of Bijeljina, that is, on the north-east of

10 Bosnia, and then emerged into Petrova Gora in Croatia?

11 A. Yes.

12 Q. Petrova Gora can be found in the atlas at page 20, in square B3.

13 It's quite well marked, just to the north or north-west of Velika

14 Kladusa.

15 While in Petrova Gora, what happened?

16 A. At Petra Gora we stopped off for about one, two, or three days. I

17 can't say exactly now. We were waiting for everything to be organised and

18 to receive orders as to where we were to head for. We were given

19 equipment, and the rifles were issued, not like they were beforehand, when

20 we were just handed them out for transport purposes. We were issued

21 weapons and we were divided up into combat units, so that each combat unit

22 was issued the equipment and weapons they needed. And then we were send

23 off to the area and a place called Katinovac.

24 Q. Before we come to that, the place where you were -- and where you

25 were given your equipment, did you discover that it was a headquarters of

Page 12197

1 some kind?

2 A. It was a logistics base. I would call it that, because there were

3 stockpiles of fuel and weapons, and a landing strip, takeoff strip for

4 helicopters, and a hospital, and the staff was there, too the

5 headquarters.

6 Q. The man Frenki, did he feature as having any significance at this

7 base or not?

8 A. That was not -- he was not directly our commander, but he was the

9 commander to our commander, so he was a leading personage there. I don't

10 know whether to call him the main commander or something else.

11 Q. Included in the equipment you were provided and clothing you were

12 provided, were there berets; if so, of what colour and with what badge or

13 other insignia?

14 A. Of course we were issued berets so that we could be like the other

15 units stationed there, and there was a sword with the three Cs in

16 Cyrillic, with our flag. That was the insignia.

17 THE INTERPRETER: Four Cs, Sorry. Interpreter's mistake. Ss.

18 MR. NICE:

19 Q. And the colour of the berets?

20 A. Red.

21 Q. One last detail. You effectively covered it, but I'd like you to

22 be clear, paragraph 56. When you were first driven from Belgrade to

23 Lipovacka Suma, who was driving the buses and how were they dressed?

24 A. Some of the drivers were policemen, and the buses, some of them

25 belonged to the police and the rest had civilian number plates. They were

Page 12198

1 Belgrade buses.

2 Q. Equipped in the way you had been in Petrova Gora and you say that

3 the rifles were issued, does that mean they were issued with unique

4 numbers against individual soldiers? Is that right?

5 A. Yes. There were serial numbers, but I can't say whether each

6 soldier -- the names weren't stated. It was just so-and-so, one weapon or

7 20, 30, or however many were issued, for one platoon.

8 Q. Then your first order, once you were properly equipped, was given

9 by who, and it was to do what? Paragraph 62, page 25.

10 A. The first order -- or rather, the order we received was in the

11 form of instructions, that it was our job to train the army of National

12 Defence from Western Bosnia. Because at that time there was a clash in

13 Bosnia between Fikret Abdic and the 5th Corps. The army of Fikret Abdic

14 was the Army of Defence of Western Bosnia, and we were supposed to train

15 them in combat action, which would follow in the next couple of days. It

16 wasn't any major training. It was just three or four days of training to

17 explain to the men how they should move in formation, et cetera.

18 Q. And Velika Kladusa, which I've already drawn to the Judges'

19 attention on page 20 of the atlas, was that the place to which you went,

20 or to that area?

21 A. The area around Velika Kladusa, because Velika Kladusa was still

22 under the corps's control.

23 Q. And at this stage of events, by whom was Fikret Abdic's army being

24 equipped in part?

25 A. The weapons themselves and the clothing, they probably had to fend

Page 12199

1 for themselves. The weapons, however, had mostly come from us, because

2 they had already been expelled out of that territory. They did have some

3 weapons, but some older trophy weapons, automatics from World War II,

4 things like that. That belonged to them, or they had got it from

5 somewhere. I can't really say. But the better type of equipment,

6 automatic rifles, et cetera, they got from us.

7 Q. Did you participate in battles for some time there?

8 A. Yes.

9 Q. Indeed, until the liberation, as described, of Velika Kladusa, and

10 also in the same square of the map.

11 MR. NICE: Perhaps we can just place this on the overhead

12 projector at page 20, bottom right-hand part of the page, Vrnograc.

13 A. I didn't participate until the liberation of Velika Kladusa,

14 because prior to the liberation of Velika Kladusa I was wounded.

15 Q. We can see on the map Velika Kladusa and, east of that, Vrnograc.

16 And were the units you described deployed, at any event, in battles in

17 these areas?

18 A. Which units do you have in mind?

19 Q. We're speaking of yourself, your own unit.

20 A. Yes, our units did participate, my unit specifically, and other

21 units who came with us, who also wore red berets.

22 Q. Did there come a time, however, when the Red Berets - paragraph

23 64 - had sustained some losses?

24 A. Our group did. Within three or four days, we had three

25 casualties, and more than half of us were wounded.

Page 12200

1 Q. And were there actual losses, and were those losses associated

2 with a stopping of direct involvement of the Red Berets in these

3 operations?

4 A. Initially, as far as I know, we did not fully uphold the orders we

5 were given, because we were not supposed to participate directly in

6 operations, only in coordination of actions. However, initially we did

7 participate in operations themselves. We suffered losses. And then later

8 on, we were split into groups that were in charge of training,

9 observation, and further coordination of new operations.

10 Q. Was there a lieutenant with the first name Jugoslav, known as

11 Jugo? What happened to him in your unit? What happened to him?

12 A. During the Rajnovac operation he was killed by the mosque.

13 [redacted]

14 [redacted]

15 [redacted]

16 Q. Was there another DB officer, whose name you're unable to recall,

17 who fell on the field?

18 A. I can't tell you exactly whether he was an officer of the DB. He

19 was a commander of the special police unit, which at the time was

20 stationed in our barracks in Erdut. And then after the withdrawal of the

21 Serb volunteer guards, special police were sent into those barracks, and

22 he led it, and I think his nickname was Kole. I believe he was a colonel.

23 After he died, his picture was printed among the death notices in Belgrade

24 daily Vecernje Novosti, and it was said that he died defending his

25 homeland.

Page 12201

1 MR. NICE: Can we go briefly, or fairly briefly, into private

2 session for the next page and a half, and then back into public session at

3 the end.

4 [Private session]

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23 [Open session]

24 THE REGISTRAR: We're back into open session, Your Honours.

25 MR. NICE:

Page 12208

1 Q. C-020, with units deployed in the area under Frenki's command,

2 were there instructions as to how you were or were not allowed to have

3 yourselves identified? What, if anything, were you to do about your

4 having come from Serbia?

5 A. We received instructions from Legija prior to setting out. We

6 were told that we were not allowed to say what unit we actually belonged

7 to. Instead of our insignia, we did not use any insignia, and we were not

8 allowed to reveal that we were members of our actual unit. We were told

9 that if we came into a situation where we had to say, and only in front of

10 our personnel, our people, we were to say that we were members of special

11 police from Serbia. And if we fell into enemies' hands, then we were not

12 allowed to say anything.

13 Q. As to your red berets, did you wear those on combat operations or

14 not?

15 A. As far as the first two operations are concerned, after them we

16 saw that the terrain wasn't in accordance with that. And after that, we

17 had woolen hats and camouflage hats. That's what we wore afterwards.

18 Q. Were you allowed to reveal yourself as, in any way, Arkan's men?

19 A. It wasn't directly banned, but we were told it wasn't a good idea

20 because there was Muslim population there, and even though this was

21 Western Bosnia, they still didn't have a good opinion about Arkan's men.

22 Q. How were you paid, and where?

23 A. We received part of the money right there, in the field; and then

24 the other part was sent to the headquarters. And when we went home, since

25 after a certain number of battles we would go home for a brief while in

Page 12209

1 groups, then the second part of the money we would receive in headquarters

2 itself.

3 Q. Fikret Abdic's part of Bosnia was divided into how many

4 operational zones?

5 A. As far as I know, into two tactical groups.

6 Q. One commanded by --

7 A. One Tactical Group was under the command of us, that is, Legija,

8 and the other one -- our group was called Tactical Group 2, and the

9 commander of Tactical Group 1 was Rajo Bozovic.

10 MR. NICE: Your Honour, there's a video which is going to be

11 produced by the next witness, and I think it's four minutes long. I have

12 extracted from it, or there have been extracted from it two stills. I

13 think the purpose to which we would put that video to this witness is

14 better served by showing him the two stills, and you can then associate

15 the stills with the video when it's played with the next witness. How we

16 deal with that in terms of exhibit formalities, I'm not sure, but it will

17 save time and I think will be more efficient. Please put them on the

18 ELMO. Apparently the video is cued for -- it's a one-minute clip so we

19 might play it as well, but--

20 Q. Can you tell us, please, who in this picture you can identify?

21 A. This is a picture from the parade at Slunj, and I can identify on

22 the left -- shall I show you?

23 Q. Yes, please.

24 A. That is Rajo Bozovic, and on the right is Legija. And with his

25 back turned here -- you can't see, but I know this picture from Slunj,

Page 12210

1 that is President Martic.

2 Q. Perhaps as the video has been cued and it's only a minute, perhaps

3 we can play it. I'd ask the booth to do that, in which case may the

4 video, this part of it, be marked for identification only and then it can

5 be properly produced in due course. So this is the parade in Slunj.

6 Held on what day, please, C-020?

7 [Videotape played]

8 A. This was called the Vidovdan parade. It was held on the 28th of

9 June, on St. Vitus Day.

10 MR. NICE: Thank you very much. I think, Your Honour, the speed

11 at which identification by video is to be done is asking the impossible

12 sometimes. It may be preferable if we mark the video for identification.

13 And if I arrange to have further copies of those two other photographs

14 produced and, with your leave, make them the seventh tab of this exhibit,

15 and they can be provided later.

16 JUDGE MAY: Yes. We'll do that.

17 MR. NICE: Then there's just paragraph 71 and 72 to deal with.

18 THE REGISTRAR: The stills will be marked under Exhibit P347, tab

19 7.1 and .2.

20 MR. NICE:

21 Q. Did you have one occasion to go and introduce yourself to Frenki,

22 paragraph 72, or to try to introduce yourself to Frenki?

23 A. Only once.

24 Q. Where was that?

25 A. I was given an order by Legija during the night to go to Petrova

Page 12211

1 Gora to collect some maps that we needed for the next day for our

2 operation, and at the headquarters where I picked up the maps, the order

3 was that I address myself to Frenki. I had never seen that man in my

4 life, and so Legija told me that once I entered, I was to introduce myself

5 and to ask for Frenki.

6 Q. Did you do that, and did the man Frenki appear?

7 A. Yes. He was sitting in the room where the maps were when I

8 introduced myself. The maps were already waiting for me, packed, so it

9 was only a couple of minutes that I was there. And so he just asked me,

10 "So you're the one?" And he mentioned my name.

11 Q. And Frenki's height, approximately, and appearance?

12 A. In those couple of minutes that one can measure a man, he was

13 about 1 metre, 80; therefore, a tall man, of athletic build. He wore

14 glasses, ordinary glasses; thin hair, brown in colour. I can't be more

15 detailed in my description.

16 Q. And what did you know or come to know of the frequency of meetings

17 between Milorad Ulemek and Frenki?

18 A. I know that Legija, after every operation, went for coordination

19 purposes, and prior to any operation for coordination purposes, to Petrova

20 Gora. So the story was that he was going to a meeting with Frenki. Now,

21 whether he actually met with Frenki himself or someone from his staff, I

22 can't say.

23 MR. NICE: That concludes the examination-in-chief. And as I

24 think I forecast, the evidence did not last as long as the size of the

25 summary might have led us to believe.

Page 12212

1 JUDGE MAY: Cross-examination in the morning. I'm reminded we're

2 sitting tomorrow between 9.00 and 1.00.

3 Witness C-020, could you be back, please, 9.00 tomorrow morning to

4 conclude your evidence.

5 We'll rise now.

6 --- Whereupon the hearing adjourned at 4.13 p.m., to

7 be reconvened on Wednesday, the 23rd day of

8 October 2002, at 9.00 a.m.

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