Tribunal Criminal Tribunal for the Former Yugoslavia

Page 12446

1 Wednesday, 30 October 2002

2 [Open session]

3 [The witness entered court]

4 [The accused entered court]

5 --- Upon commencing at 9.02 a.m.

6 JUDGE ROBINSON: Judge May is indisposed today. The Chamber will

7 continue sitting under Rule 15 bis.

8 Yes, Mr. Groome.

9 WITNESS: SLOBODAN LAZAREVIC [Resumed]

10 Examined by Mr. Groome: [Continued]

11 Q. Mr. Lazarevic, yesterday we interrupted your testimony during your

12 recounting some of your work on the exchange of bodies commission. I'd

13 like to begin this morning by showing you a document, and it is

14 Prosecution Exhibit 348, tab 14. And I'm going to ask that you be shown

15 both the original B/C/S and the English translation. I'd ask you to take

16 a look at the original B/C/S document before it's placed on the overhead

17 projector, and after you've had a chance to look at it, I'd ask you to

18 tell us whether or not you recognise that document.

19 A. Yes, I do. It was handed to me personally.

20 Q. And who handed you this document?

21 A. My CO, Colonel Bulat.

22 Q. And when was it that Colonel Bulat gave you this document?

23 A. I assume that I received it on September 25th, 1994.

24 Q. And has that document been in your possession until you turned it

25 over to the Office of the Prosecutor here at the Tribunal?

Page 12447

1 A. Yes, it was.

2 Q. To save a bit of time, I'm going to ask you -- it's a short

3 letter. I'm going to ask you to take a look at the English translation

4 and read it. If there's any part of that translation that does not

5 comport with your understanding of the document, or you disagree with any

6 portion of the translation, I'd ask you to indicate that and to tell us

7 what you believe the document to say. So I'd ask you now to read this

8 translation of that document for the Chamber.

9 A. "Republic of Srpska Krajina, Main Staff of the Serbian army,

10 confirmation number 15-440 --"

11 THE INTERPRETER: Would the -- slow down.

12 THE WITNESS: I apologise.

13 "Republic of Srpska Krajina. Main Staff of the Serbian Army.

14 Confirmation number 15-440, 29th of September, 1994. Meeting of war

15 prisoner exchange commissions. To be delivered to the 21st Corps (war

16 prisoners exchange commission).

17 "Since the war prisoners exchange commission of the 1st Krajina

18 Corps made an appointment to meet with a similar commission of the

19 so-called ABiH, it is necessary that the representatives of your

20 commission attend, too, and that they tell the Turkish commission openly

21 that we, (RS and RSK), are one people, but that on the paper we are

22 divided in two states.

23 "From the intelligence service obtain a few names of the most

24 extremist members of the 5th Corps of the so-called ABiH, and convey them

25 to the Turkish commission. Tell them that we have around 3.000 of their

Page 12448

1 members that are in prison, not in a refugee camp. You have to let them

2 know that we are not in the position to beg, but that we are those who are

3 setting the conditions up.

4 "It should be checked whether there are relatives and friends of

5 the leading military and politicians from c. Krajina among the prisoners

6 and convey their names to them, too.

7 "Assistant Commander Colonel Marinko Gajic."

8 And then there's a stamp on the bottom of the original document,

9 received on the 29th of September, 1994, at 1530, processed at 1530, and

10 signed.

11 Q. Does that translation accurately reflect the contents of the

12 original Serbian document?

13 A. Yes, it does.

14 Q. I want to ask you now to assist the Chamber in placing that

15 document in context, and I want to ask you a few specific questions. The

16 reference to RS and RSK and "are one people," what did that -- can you put

17 that into context? What was the author of this letter indicating by that?

18 A. Well, indicating that the Serbs on both sides of the frontier

19 then, between the Republic of Srpska and Republic of Srpska Krajina are

20 all Serbs, serving in one army.

21 Q. The portion of the letter which indicates that the Serbs have

22 around 3.000 members in prison camps, not refugee camps, is that -- do you

23 have knowledge whether that 3.000 were simply military soldiers that had

24 been captured or were they also civilians?

25 A. I'll have to be honest and admit that I am not aware of the 3.000

Page 12449

1 being held anywhere in RSK, which I cannot claim for the RS.

2 Q. So to your knowledge, were there 3.000 soldiers anywhere within

3 the 21st command's area of responsibility?

4 A. No, not that many.

5 Q. The last paragraph, when it talks about checking whether there are

6 relatives and friends of leading military and politicians, can you

7 indicate or describe for us what that meant, place that in context for us?

8 A. It meant very simply that if we did held anybody that was

9 important to the other side, they should be used as a blackmail tool.

10 Q. And were attempts made to identify the people in custody to

11 determine if they were related to any prominent members of the opposing

12 side?

13 A. Yes. Those we held in prison have been severely questioned to

14 establish whether there are any relationships to the leading political

15 figures in B and H.

16 Q. Were there ever any attempts to identify people related or friends

17 of prominent members who were not yet in custody, to identify them and

18 place them in custody?

19 A. Not to my knowledge in RSK.

20 Q. I'd like to now draw your attention to May 1995, and ask you: Did

21 you have occasion to see an order regarding the shelling of the frontier

22 or front line near Zagreb?

23 A. Yes. Order issued by the President Martic was issued to all the

24 commands of all the corps and at one of the briefings in the morning it

25 was read to all of us.

Page 12450

1 MR. GROOME: I apologise to the usher. I'm finished with that

2 document. Thank you.

3 Q. Now, this order issued by President Martic, can you please

4 describe what you recall about it when it was read out in the morning

5 briefing.

6 A. Briefly, it stated that any case of provocation from the Croatian

7 side or any attack from the Croatian side, all the corps deployed along

8 the frontier from north to south should be burning on the other side,

9 meaning that the artillery attack would immediately begin all along the

10 frontier.

11 Q. Based on your experience and participation in that morning

12 briefing, is it your belief that Mr. Milosevic had anything to do with

13 this particular order?

14 A. Not to my knowledge.

15 Q. After -- strike that. Was this order ever implemented?

16 A. At one instance, yes.

17 Q. And was there any reaction to its implementation?

18 A. Yes. The unit that have opened the rocket fire on Zagreb was

19 immediately arrested and removed from the area.

20 Q. And do you know who arrested them?

21 A. The special police from Serbia.

22 Q. And how much time transpired between the rocket attack and the

23 arrest of the people who perpetrated the rocket attack by the special

24 police from Serbia?

25 A. I don't think it took more than six hours after.

Page 12451

1 Q. I want to now draw your attention to the period of time in the

2 Krajina in 1995. And before I ask you specific questions about that

3 period of time, I would ask you to describe generally to the Chamber what

4 life was like among the remaining Serb population in the Krajina in 1995.

5 A. One would have to say that life was very difficult at the time.

6 Suddenly the supplies have somehow become less and less regular as they

7 were before. A lot of civilians have already left the area on the pretext

8 of going to see relatives in Serbia or whatever the reason they gave. But

9 the people started trickling away very slowly. There were a lot of

10 rumours going around that a Croatian attack is imminent, that we are

11 prepared to defend every inch of the soil of the RSK. It was a war of

12 psychosis, very, very carefully built up.

13 Q. Can you describe the level of violence or crimes that were

14 non-conflict related in the Serb community at that time?

15 A. I had the opportunity to read the surveys carried on official

16 basis by the army and losses that we have suffered at that particular

17 moment in time. 80 per cent of those losses were contributed to ourselves

18 and 20 per cent to the enemy.

19 Q. That means that the official statistic on who caused these crimes,

20 who perpetrated these crimes, 80 per cent was attributed to Serbs

21 themselves?

22 A. Correct.

23 Q. I want to draw your attention now Operation Storm and ask you to

24 describe what Operation Storm was and where were you when Operation Storm

25 commenced?

Page 12452

1 A. The operation itself started on the morning August 5th, 1995.

2 However, we have been informed about a pending attack two days prior, in

3 every detail; about the time, the strength, and direction of the attack,

4 which made me believe that we have sufficient time to regroup or increase

5 the defence of the border itself.

6 Q. How did you -- sorry. How did you learn about the details of the

7 attack prior to the attack?

8 A. Through my connections with ECMM.

9 Q. And did you pass that information on to your superiors?

10 A. Within minutes of receiving it.

11 Q. And can you tell us who you passed this information on to?

12 A. Originally, first was given to Colonel Bosanac who was then in

13 charge of the 21st Corps, and then I myself personally sent a telex to

14 Knin General HQ.

15 Q. And based on your experience of having lived in this area for

16 several years, it was your opinion that there was a response that could be

17 taken to these attack plans?

18 A. My understanding, yes.

19 Q. Please continue.

20 A. On the morning of the 5th of August, there was a first attack

21 carried by the Croatian air force, actually, in the vicinity of the HQ of

22 the 21st Corps, where I was at the time. However, the rockets released by

23 these airplanes didn't come nowhere near to the actual HQ. I think they

24 were directed to the HQ of the special police in Petrova Gora. Whether

25 they hit it or not, I really don't know. At the same time, the infantry

Page 12453

1 attack came from the direction of Petrinja and from the direction of

2 Karlovac. The combat actually started on the ground itself by 8.00.

3 At the same time, I was informed to go immediately back to the HQ

4 of the UN, as if UN didn't know about the attack. I mean, I was supposed

5 to go there and file a complaint about the attack from the Croatian side.

6 I did get back to the HQ. Of course, the sector commander was aware of

7 the attack and he was trying, through his own channels, to convey a

8 message to the Croatian side via the HQ in Zagreb of the UN for the

9 immediate ceasefire which, unfortunately, did not happen.

10 Q. Now, Mr. Lazarevic, before you describe more detail about the

11 attack, I'm going to ask you to briefly describe for the Chamber the

12 location of the 21st Corps, the 15th Corps and the 39th Corps, all of the

13 ARSK army. Can you please describe their relative positions at this point

14 in time.

15 A. I think I have mentioned before how narrow that section of RSK is

16 between the B and H and Croatia. The RSK was caught kind of in the

17 middle. And the attack was carried out on the 5th of August from both

18 sides of the border, meaning we were attacked from behind by the 5th Corps

19 and up front by considerable Croatian forces. The depth of the section

20 that we defended is around 15 kilometres. The width is around 70.

21 Considering that my eastern flank was held by the 39th Corps, which is the

22 Banija Corps, and on my western flank Lika, or the 15th Corps, was

23 supposed to hold the position. However, by the 9th of the 5th, in the

24 early morning hours of the 6th, we have discovered that both of those

25 flanks have withdrawn, that actually we have been left alone in the

Page 12454

1 middle. By that time, we were already surrounded by the Croatian side.

2 There were in Glina, and on the other side, they were in Vojnic, so there

3 was no way out for us.

4 Q. Prior to the 15th Corps withdrawing, was -- was the 21st Corps

5 made aware of that fact, to your knowledge?

6 A. No. We were not being aware of any movement of the troops.

7 Q. Prior to the 39th Corps being withdrawn, was the 21st Corps made

8 aware of their withdrawal, to your knowledge?

9 A. Again, the same thing; we were not informed about it.

10 Q. I want to draw your attention now to the 7th of August, 1995.

11 Were you personally present when a series of phone calls were made from

12 the 21st Corps to Belgrade?

13 A. Yes. The meeting actually took place in the HQ of the UN. We

14 used the satellite phones in there.

15 Q. And did the UN permit you to use these satellite phones or can you

16 explain the circumstances under which you used the satellite phone?

17 A. We rented the space from the UN. We were paying 5.000

18 Deutschmarks a day to use this particular office.

19 Q. Was this an official agreement with the UN or was it a deal that

20 was worked out with an individual?

21 A. It was a deal worked out with an individual.

22 Q. Okay. Please tell us about the phone calls that you witnessed.

23 A. In the office, at the time when it was painfully obvious that we

24 were sacrificed as a corps, we tried to establish contact with the General

25 HQ in Belgrade and with the cabinet of Mr. Milosevic. In the office at

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Page 12456

1 the time, it was myself, Toso Pajic, Colonel Bulat, Djuro Skaljac, and

2 maybe one or two other persons present. The calls were made in the

3 following order: First it was placed to the General HQ of Belgrade,

4 General Perisic personally by Colonel Bulat. I have to say that the

5 public announcement system was plugged in, so actually we could all listen

6 to the telephone conversation.

7 Q. So we're clear: So the phone was on speakerphone and all people

8 in the room to hear both sides of the conversation?

9 A. Correct.

10 Q. Okay. Please continue.

11 A. Once the contact was established with the General HQ, Colonel

12 Bulat has given a report as a commanding officer from the war part of the

13 country to the General Perisic and then he asked him for advice,

14 explaining that we have been caught and encircled totally by the enemy

15 forces, which were considerably stronger than we were, and asked him what

16 does he want us to do, whether to surrender, whether to fight or what.

17 General Perisic answered with one word, and that was "Persevere", and put

18 the phone down.

19 Q. Did General Perisic offer any concrete assistance to the 21st

20 Corps?

21 A. No, except, "Persevere." That was about all that he said at the

22 end of the conversation.

23 Q. Was there another phone call made that morning or that day?

24 A. The next phone call was made to President Lilic.

25 Q. And who made that phone call?

Page 12457

1 A. Mr. Pajic made that call.

2 Q. And can you please describe the contents of that phone call.

3 A. Again, he explained the situation and asked for advice. Again we

4 received exactly the same answer, that was, "Persevere."

5 Q. Did President Lilic offer any concrete assistance to the 21st

6 Corps?

7 A. Absolutely none.

8 Q. Was there another phone call made that day?

9 A. Yes. Mr. Toso Pajic made one more call, and that was placed to

10 Jovica Stanisic.

11 Q. And can you tell us the substance of that call?

12 A. Again, explaining the situation, development over the last 24

13 hours above ground, and again we heard the same reply: "Persevere." At

14 that particular moment in time, we all looked at each other and had a

15 feeling like these three people are in the same room even though that we

16 have had three different telephone numbers that we have used, but the

17 answer was exactly identical.

18 Q. And did Mr. Stanisic offer any concrete assistance to the 21st

19 Corps?

20 A. None whatsoever.

21 JUDGE ROBINSON: Just before you continue, Mr. Groome.

22 Mr. Lazarevic, you said that they were considerably stronger than

23 you were, than your forces were. Could you put that in terms of numbers

24 for me?

25 THE WITNESS: Our estimate at the time was that we had

Page 12458

1 approximately 4.000 men under arm, and I'd like to point out that none of

2 those were professional soldiers within the RSK. Most of them actually

3 civilians just being drawn into the conflict. At the back of us, we had a

4 full 5th Corps of the B and H army which at the time numbered around

5 20.000. The both flanks, the eastern and the western flanks, the attack

6 carried by the Croatian forces would approximate the same number of 20.000

7 together. In real terms, we had about 40.000 people attacking

8 approximately 4.000.

9 JUDGE ROBINSON: Thank you.

10 Continue, Mr. Groome.

11 MR. GROOME:

12 Q. Did members of Arkan's Tigers receive concrete assistance during

13 this time period?

14 A. On the evening of the 6th of August, they have pulled out, not

15 only Arkan's, but special forces of the Ministry of Interior of Serbia

16 have pulled out from the area, from Pauk and from Petrova Gora with

17 assistance of the MP Battalion from the 21st Corps.

18 Q. And can you be more specific about the type of assistance that the

19 special forces from Republic of Serbia MUP and Arkan received when they

20 withdrew from the area?

21 A. The battalion of the MPs from the 21st Corps has served as a

22 security and led the way in withdrawal of the forces from Pauk and Petrova

23 Gora.

24 Q. Do you have any personal knowledge regarding who issued the order

25 to give them protection when they withdrew?

Page 12459

1 A. I have no idea.

2 Q. Did something happen to Luna rockets that were present in the RSK

3 at that time?

4 A. Those rockets were removed on the day when Zagreb was shelled, so

5 we had no rocket system at the time of the attack, even though I have to

6 admit the Croatian side was not aware of that.

7 Q. I'd ask you now to continue with what happened after this period,

8 and I'd ask you to maybe describe for us what, if any, media campaign

9 existed at this time regarding what was going to happen to the people in

10 the Krajina.

11 A. Obviously, at the time of this attack, I'm now specifying the

12 period of 6th and 7th of August, there were a lot of rumours running

13 around, and of course all sides used it to their own benefit. The fact of

14 the matter is that the 21st Corps left their position of Turanj and pulled

15 all the way back to the actual compound of the UN, which we have

16 surrounded and placed civilians between us and the UN.

17 What I'm trying to picture to you, gentlemen, is that in any

18 situation when aerial attack by the Croatian air force, the UN HQ would

19 suffer considerable damage as well. That was the idea for proximity of

20 our own troops there. At the time, we controlled a perimeter of around 7

21 kilometres. That was what was left of the RSK. Within this perimeter, as

22 I said before, we had 4.000 Serbs armed and approximately 20.000

23 civilians. There was no food, no water, no electricity.

24 All the other sectors had been deserted by then. Knin was taken

25 over by the Croatian forces. The Croatian forces have advanced even

Page 12460

1 further. They were approximately two kilometres away from Topusko on

2 either side of the road, meaning from the east and from the west, and the

3 5th Corps has actually stopped at the border to Croatia, so they have not

4 penetrated into the territory. If you would draw a circle around the

5 compound of the UN, it would be probably around two and a half kilometres

6 wide. That's about it.

7 We have tried many things to inform the general public about the

8 attacks of the Croatian. The information which we received from the field

9 were that atrocities have been started by the advancing enemy forces. One

10 particular information I have conveyed to the CNN via the satellite phone

11 about the attack of the Croatian air force and the members of the 5th

12 Corps on the refugee convoy which was trying to penetrate the territory

13 into Bosnia, withdrawing from RSK. That would happen on the 6th.

14 Q. Was that story covered on CNN?

15 A. Yes. Actually, I have personally, not only me, but a number of us

16 was watching TV at that time.

17 Q. Please continue.

18 A. On the morning -- the morning of the 7th, it was already obvious

19 that we cannot expect any assistance from anybody. We all firmly believed

20 that we have been sacrificed so that somebody in Belgrade would gain some

21 points after we have all met with our demise, being surrounded. Three of

22 us at the time in the office, Colonel Bulat, myself, and Mr. Toso Pajic,

23 have discussed the possibility. The least one liked by all three of us

24 was actually going and commit mass suicide by counterattacking the forces

25 which are approximately 8 to 1. Also taking into consideration that the

Page 12461

1 position of ourselves would also contribute to the considerable killing of

2 the UN personnel as well.

3 At that time we made a decision between three of us to get in

4 touch with the command in Zagreb via sector commander in Topusko and

5 suggest that if we were to surrender to the Croatian side, the condition

6 would be that we are permitted to go back to Serbia, for the convoy being

7 escorted by the UN and ECMM and military observers, and withdraw all the

8 way to Serbia.

9 Finalising of this idea came after we all disagree that would not

10 be very wise actually to travel in vicinity of the 5th Corps because the

11 5th Corps would not be a part of this agreement which we are about to make

12 with the Croatian side. So we have decided actually to travel the length

13 of Croatia with the convoy and enter Yugoslavia at Sid area.

14 Q. And that's Yugoslavia in Serbia, I mean Serbia -- the Serbian part

15 of Yugoslavia.

16 A. That is correct. On the morning of the 8th, all the details were

17 finalised. The attacks have stopped in the meantime. The deal was that

18 we first surrender the heavy weaponry - tanks, artillery pieces - and then

19 along the way to relieve ourselves from all the other weapons. So

20 approximately after about 25 kilometres on the road from Topusko, already

21 deep in Croatia, past Petrinja, we were to surrender all the rest of the

22 weaponry. Only officers were allowed to keep assigned weapons, but that

23 was a kind of part that even Croatia didn't keep, they just took all the

24 weaponry. In all fairness, I have to admit, it was a horrible convoy,

25 very long, with approximately 25.000 people in the convoy. The length of

Page 12462

1 the convoy would probably be around 30 kilometres because you had cars,

2 tractors, horse-drawn vehicles, and it was moving extremely slow.

3 The only part -- the only part that we have considered to be

4 actually threatened is when we left Glina and it was -- the convoy was

5 passing through a couple of destroyed Croatian villages at the beginning

6 of the conflict, and it was like a gauntlet of the Croatian army alongside

7 of the road; the distance between each of the soldiers probably about two

8 to three metres. And us being already disarmed but still in uniform, we

9 didn't feel very comfortable when they started checking their weapons. I

10 suppose it was just a kind of trying to install fear.

11 Q. Mr. Lazarevic, before you continue, can you give us some idea

12 about the composition of this convoy? Is it just military members of the

13 21st Corps or are there also Serb civilians taking part in this convoy?

14 A. The convoy was of a mixed nature. There were military and

15 civilians. And the civilians were not only from Topusko. Actually, there

16 were a lot of civilians coming from deeper within Krajina, like the Slunj

17 area, then further down. As they were pulling back or pulling out from

18 their own position, they would actually end up in Topusko because Topusko

19 was like, you know, the end of the road, because we were -- by then, we

20 were already surrounded from all sides. So the convoy itself would be, as

21 I said, approximately numbering 24.000 bodies, out of which 20.000 were

22 civilians; you know, elderly people, ladies, kids.

23 Q. Did there come a time when this convoy reached the border of

24 Serbia?

25 A. I was approximately a fifth car in the convoy, so I was about

Page 12463

1 among the first ones to reach the actual border between Republic of

2 Croatia and Yugoslavia. I was asked by Toso Pajic and by Colonel Bulat to

3 stay behind -- two police officers, our own police officers, and two

4 police officers from the Croatian side and just to check the number of the

5 people as they are going through, which took about eight to nine hours.

6 Q. Do you recall the approximate number of the people that passed

7 from Croatia into Serbia?

8 A. In all honesty, I have to say that we've been on the road for

9 approximately 72 hours, so that part was totally unclear to me. I know I

10 have been writing names down. I was asked to write just the first names

11 of the people, no surnames, no ranks, no whether they belonged to the army

12 or not. It was just a kind of verification that the Croatian side had

13 asked to have, at the end of the day, confirmation of all the people that

14 have gone across if our side would claim later on that the number of

15 people were taken out of the convoy and maybe taken to a prison or being

16 shot or something like that.

17 Q. Are you able to approximate that number for the Chamber?

18 A. I believe that I stood there and about 15.000 people have gone

19 through.

20 Q. And that would be 15.000 people, both civilian and military?

21 A. Correct.

22 THE INTERPRETER: Interpreter's note: Would you please observe

23 pauses between question and answer.

24 MR. GROOME:

25 Q. Mr. Lazarevic, can you now describe what you observed on the

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1 Serbian side of this border.

2 A. I have been first to get there, but I was approximately the last

3 one to leave Croatia at the end tail of the convoy. As soon as they have

4 crossed the road, I parked my car in Yugoslavia this time, and I slept in

5 the car beside the road for about four to five hours. When I woke up, I

6 decided to continue towards Belgrade. As soon as I have reached the

7 highway known as Bratstvo-Jedinstvo, or Brotherhood and Unity Highway,

8 this is when you encounter the first toll booth like set up before you

9 enter the highway. On this side, on this side facing Croatia, actually,

10 there were units of the police from Serbia stopping all the vehicles in

11 convoys and searching them thoroughly, including the persons within the

12 vehicles. Anything that resembled anything to do with the military was

13 immediately confiscated and taken away.

14 On the other side of the ramp, they had set up a little Red Cross

15 station with fresh water, milk for the kids, bread, and things like that.

16 But you can imagine the slowness of the process if each individual car or

17 vehicle or pedestrian, even, being totally searched before we actually can

18 reach the other side and have a glass of water or glass of milk. So it

19 was a very painful and slow process. Most of the people in the convoy had

20 been protesting vigorously against the Serbs because we just couldn't

21 figure out if Croatia decided not to search the convoy for 72 hours as we

22 moved through Croatia, why is it suddenly that we have to be searched so

23 thoroughly by our own police? Nevertheless we had to put up with it, and

24 after finally making it through the gate and entering the highway, we

25 started moving toward Belgrade.

Page 12466

1 I was driving a Mercedes at the time, so I had the opportunity to

2 move faster than most of the convoy, meaning that I have reached Belgrade

3 ahead of the rest of the convoy that was very slow moving.

4 Q. Can you describe what, if anything, you observed at the exit ramps

5 to the highway?

6 A. The moment we reached Belgrade, the exit ramp of the highway was

7 blocked off by the police and all the traffic was directed further south.

8 As the convoy moved further south, every other exit was also blocked off

9 by the police, so the convoy actually had to keep on moving without

10 stopping anywhere. The general direction of this movement was Kosovo.

11 Q. So if a person who had fled the Krajina had family in Belgrade and

12 wanted to stay with them, were they permitted to do that?

13 A. No, sir.

14 Q. Where were those people being forced to go?

15 A. As I said, along the highway, deeper south, general direction of

16 Kosovo.

17 Q. Were there any representations made regarding what awaited the

18 refugees down in Kosovo?

19 A. Absolutely nothing. You had just a bunch of police at every exit,

20 showing the movement of the convoy to continue down the highway.

21 Q. Did there come a time -- strike that. Did you travel on the

22 highway through Belgrade?

23 A. Yes, I have.

24 Q. Did there come a time when you were able to get off of the

25 highway?

Page 12467

1 A. As I said before, I was moving much faster than the rest of the

2 convoy, and those that have left the Croatia before I did, obviously had

3 moved even further up front. So there was a section of the road that I

4 was driving now that had no convoy in front of me or no convoy behind me,

5 and I reached vicinity of Krusevac, where I have spotted an exit which was

6 not guarded by the police, and this is when I swung off the road and left

7 the highway.

8 Q. Without telling us the name of the person you went to or their

9 relationship to you, did you go somewhere when you were able to get off of

10 the highway?

11 A. Yes. Straight to the house of this person.

12 Q. And how long did you remain at this person's house?

13 A. 24 hours before the police showed up at the front door.

14 Q. And the police that showed up, were they ordinary, uniformed

15 Republic of Serbia police?

16 A. Yes, regular police.

17 Q. And what happened?

18 A. I was asked to get dressed up and leave with them to the police

19 station. I have repeatedly asked why, and they said, "Well, we have no

20 answer for you, but the commander of the station will inform you." When I

21 was taken by these two police officers to the station, there were a number

22 of people from Krajina around the station already, mostly women and

23 children crying their eyeballs out because all the men were put on the

24 buses.

25 Q. Did you identify yourself and your position to the police?

Page 12468

1 A. Very much so. Actually, there was -- in the room which was

2 questioning every individual where is he from, there was a member of the

3 state security with the police commander, to whom I have identified

4 myself, given my military booklet, my driver's licence, my ID, to

5 establish the fact that actually I am not from Krajina, that I was born in

6 Belgrade, therefore I'm a citizen of Yugoslavia. And this gentleman from

7 the state security told me, "Okay. You turn around and you go home now."

8 I asked if I can use the phone so I can call the people to come and pick

9 me up because the police brought me down. These people turned up around

10 3.00 in the morning and took me away. Unfortunately, the very same day in

11 the early hours of the morning, around 10.00, the police turned up at the

12 gate again and took me away again.

13 Q. Where were you taken this time?

14 A. Straight to Krusevac.

15 Q. And were you taken there alone or with other people?

16 A. There was a bus load of us going to Krusevac who were there, and I

17 believe there was some kind of either school or something like that,

18 because there was a couple thousand people already. It was like a

19 gathering centre.

20 Q. And what happened at that location?

21 A. The people held in this location were all people from RSK of

22 military age, meaning from like age of 18 to about 60.

23 Q. And what is the ethnicity of these people?

24 A. They're all Serbs.

25 Q. Please continue.

Page 12469

1 A. We were loaded on the buses there. Each bus had an escort of four

2 police officers, including the driver. Each bus was full of people, only

3 sitting, nobody standing but, I mean, every seat was taken by an

4 individual. I think we left around noon, as this huge convoy of buses

5 taking us somewhere. When we tried to establish some sort of a

6 conversation with the police officers on board the bus, they simply would

7 not answer where we are being taken.

8 Q. Now, can you approximate for us the number of buses in this

9 convoy?

10 A. In the convoy that left with me was approximately 12 buses.

11 Q. And did you perceive that you were free to get off this bus if you

12 wished?

13 A. Absolutely nobody was allowed to leave the bus, not even go to the

14 rest room.

15 Q. Please continue.

16 A. We kept on driving and it was getting dark, and we still didn't

17 know which direction we are going. At one point, the lights from the bus

18 have shown a road sign which was Dalj on this road sign.

19 Q. Could you please spell that for us?

20 A. D-A-L-J.

21 Q. Please continue.

22 A. We realised - some of us that knew - that we actually are going to

23 the Arkan's camp.

24 Q. And where was Arkan's camp located at that point in time?

25 A. In Dalj.

Page 12470

1 Q. Did you -- did there come a time when you did eventually arrive at

2 Arkan's camp?

3 A. Yes. We arrived there. The whole camp was in total darkness.

4 However, there were a number of people standing and yelling the names of

5 the people on the bus, because obviously they were supplied with the names

6 by the convoy leader or whoever gave them the names. And as the people

7 were descending from the bus, they were sent to run through a gauntlet of

8 Arkan's Tigers, who were beating them at the time as they were running

9 through. At the time that somebody called my name, I stepped off the bus

10 but immediately somebody walked up to me in the dark and -- somebody who

11 recognised me or somebody who knew me -- and pulled me aside and said,

12 "No, you don't go that way. You're not one of them," meaning I'm not a

13 Croatian Serb but being a Serbian Serb, even though myself personally

14 didn't make a distinction as such. And I was taken around the gauntlet,

15 straight to the office of Colonel Pejovic and Captain Sarac, which I knew

16 from a previous encounter in the RSK, and they were aware that I am

17 originally from Belgrade, so I was kind of put aside, so I didn't go

18 through this severe beating on arrival.

19 Q. Did you come to learn the purpose of these men being brought,

20 these Serb men being brought to Arkan's camp?

21 A. Apparently somebody had an idea that these people need to be

22 retrained by Arkan, and that was like original virgins, whatever, brought

23 there. I find out later on that Arkan has been paid 100 Deutschmarks per

24 head of the Serbian brought in for retraining.

25 The situation within the camp were atrocious. People were

Page 12471

1 severely mistreated on a daily basis, property were taken away from them,

2 their IDs were taken away from them; they have become just numbers. I'll

3 give you instances: For example, there were three telegraph poles in

4 front of Arkan's HQ to which every single day there were at least three

5 Serbs chained to the post and anybody who went past can beat them.

6 Q. Can you please describe for us how it was you learnt that Arkan

7 was being paid to retrain these men.

8 A. The very same night when I arrived to -- I will freely use

9 "concentration camp," because that's what it was. Excuse me.

10 Q. Take your time.

11 A. The very same evening that I arrived to the camp, myself, I had

12 seen a JNA officer, which I have approached and identified myself and

13 asked for a location of the commander of the 21st Corp or any corps of the

14 RSK. I was told by this gentleman that a joint command has been formed in

15 Vukovar and that he will inform the necessary officers about my being held

16 in this in this concentration camp.

17 JUDGE ROBINSON: Can you explain your characterisation of this

18 place as a "concentration camp"?

19 THE WITNESS: First of all, there were no freedom of movements.

20 The whole camp was surrounded by barbed wire. It was heavily guarded by

21 the armed men. People were mistreated 24 hours a day, beaten up severely,

22 made to carry huge rocks, about the size of a human with the weight of

23 approximately 60 or 80 pounds, and at any given time if they dropped this

24 rock, they would be beaten again.

25 MR. GROOME:

Page 12472

1 Q. Did there come a time when you learnt the purpose of this

2 retraining? What was to happen to these men after they had been trained

3 by Arkan?

4 A. My understanding was they will be pushed up front to fight the

5 Croatian forces again, but this time at the back of them they would have

6 Arkan units who would shoot them in the back if they decide to withdraw.

7 Q. Mr. Lazarevic, did there come a time when you were able to secure

8 your own release from this camp, using your own contacts?

9 A. On the fifth day, a vehicle came from Vukovar joint command to

10 take me away from this camp, and I was taken there. At this time, when I

11 walked in the command, I was very, very disappointed. I just couldn't

12 believe that the Serbs can do to the Serbs what they were doing, and I

13 have asked immediate discharge from the forces. I was told to go and see

14 Colonel Karan, who was in charge of internal security KOS, and he

15 suggested, he said, "Well, I can't give you this discharge. What I can

16 give, I give you a pass to go to Belgrade, and then you don't have to come

17 back. You can go for medical check-up, just don't come back." I said,

18 "This is not the way I want to leave the army, not by deserting it," I

19 said, "I want a full discharge." I requested a vehicle from the command to

20 take me straight to the Ministry of Defence of the RSK, and I went there

21 and I raised -- I tell you, gentlemen, I did raise hell over there to get

22 a discharge, which I eventually did, and then I sat on the first bus back

23 to Yugoslavia.

24 Q. During your time at the camp, did Arkan himself address the group?

25 A. Yes. Each group -- I have to tell you that every day the buses

Page 12473

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Page 12474

1 were coming. This is not just my convoy when it came, but on a regular

2 basis, everybody morning and every evening, another bus load and another

3 bus load of these poor people would come in.

4 JUDGE ROBINSON: Of what ethnicity?

5 THE WITNESS: Serbs.

6 MR. GROOME:

7 Q. Can you approximate for us, during the time you were there, how

8 many people, how many Serbs altogether you saw?

9 A. Over a period of four days, at least two and a half thousand.

10 Q. Can you please describe for us what Arkan said to your particular

11 group.

12 A. Well, he lined up the group and then told them: "For the five

13 years [Realtime transcript read in error "five days"] we have supplied you

14 with weaponry, we have supplied you with food, with the manpower, with the

15 officers, and yet you wouldn't even fight, in the end."

16 Q. And when he used the word "you," did you take that to be a

17 reference to those people in the Krajina?

18 A. Yes, sir.

19 MR. GROOME: Your Honour, I have no further questions of

20 Mr. Lazarevic at this time.

21 JUDGE ROBINSON: Mr. Lazarevic, how long did you stay in the camp?

22 THE WITNESS: Your Honour, I stayed there for five days.

23 JUDGE ROBINSON: And what was your treatment generally?

24 THE WITNESS: It was regular treatment. I mean, nobody bothered

25 me whatsoever. I was just put aside over there, waiting for somebody to

Page 12475

1 come and pick me up from the camp.

2 JUDGE ROBINSON: You said something in the earlier part of your

3 testimony today that I'd like to ask you about. Having made three phone

4 calls to Belgrade and on each occasion you were told to persevere, your

5 assessment was that somebody wanted to sacrifice you to score points. I

6 think that was the term that you used.

7 THE WITNESS: That is correct, Your Honour.

8 JUDGE ROBINSON: Can you explain that for me?

9 THE WITNESS: Well, we believed, by the answers which we have

10 received and a silent refusal of any assistance whatsoever, whether it was

11 air force or ground troops or -- that we left there, leaving us open to

12 try and mount a counterattack and die in the process. A lot of civilians

13 would have been killed. The media could use that as pointing out that the

14 Croatian side is no different than the Serbian, or even worse than the

15 Serbian side in committing these atrocities against the civilians and the

16 unarmed population in Krajina.

17 JUDGE ROBINSON: I see. Thank you.

18 MR. GROOME: Your Honour --

19 JUDGE ROBINSON: Yes, Mr. Groome.

20 MR. GROOME: I believe there's an error in the transcript. Before

21 we get too far ahead, I'd ask that maybe the stenographers check it. It's

22 on page 25, line 17. I believe the witness said five years, and it's been

23 recorded as five days.

24 JUDGE ROBINSON: Yes. That correction will be made.

25 Mr. Milosevic, your turn for cross-examination. I ask you, when

Page 12476

1 you're cross-examining to avoid, as best you can, speeches, questions

2 which are too long. Make your questions as short as possible. Avoid

3 narratives and concentrate on asking short questions. You have about four

4 hours and 50 minutes, which you do not have to use. Please proceed.

5 THE ACCUSED: [Interpretation] Thank you, Mr. Robinson, especially

6 for this warning to take care how much time I will use up

7 Cross-examined by Mr. Milosevic:

8 [Witness answered through interpreter]

9 Q. [Interpretation] I see from your statement that you claim that as

10 a very young man you started working for the KOS.

11 A. Yes, that is correct.

12 Q. That dates back to 1968, as I understand it.

13 A. Yes.

14 Q. This activity of yours was never interrupted until the end of the

15 war --

16 A. Actually, it continued until 1999.

17 Q. 1999?

18 A. Correct.

19 Q. From 1968 to 1999?

20 A. Let me be precise: Until the 22nd December, 1998.

21 Q. All right. And all this time, from 1968, you filed your reports

22 to a person by the name of Nikola Zimonja; is that correct?

23 A. Yes, for the most part, correct.

24 Q. What do you mean, "for the most part"? Did you file reports to

25 someone else as well, but reports to him were regular?

Page 12477

1 A. Correct.

2 Q. How frequent were your reports to him in this entire period, from,

3 let's say, 1968 to 1992, when I see that you joined the army of the

4 Serbian Krajina? At the time you were a liaison officer and your activity

5 was more intensive. But how often did you submit reports to Mr. Zimonja?

6 A. A minor correction: When I put on the uniform in December 1991, I

7 put on the uniform of the JNA, not the army of the Serbian Krajina. And

8 the reports were as frequent as my assignments.

9 Q. But in terms of time, how frequent, how regular, were these

10 reports?

11 A. From 1991 to 1998, my reports were at least --

12 Q. I'm not talking about that period. I'm talking about from 1968 to

13 1992.

14 A. Once a week.

15 Q. Regularly, without interruption, throughout those years?

16 A. No. There were periods when I didn't file any reports at all.

17 Q. How long were these periods?

18 A. There were some that lasted a year, a year and a half.

19 Q. What were those years when you filed no reports?

20 A. It's very difficult to remember when precisely, but let's say in

21 1985, 1986, or in 1983 there were regular reports during the Winter

22 Olympics, and in 1979 I didn't submit any reports at all. What I'm trying

23 to say is that I drew up reports if I had anything specific to report. I

24 didn't make any contact if there was no need for that.

25 Q. I understand. You joined the army in end 1991, and later, in the

Page 12478

1 beginning of 1992, if I understood you correctly, you were already part of

2 this corps commanded by Colonel Bulat, which was, as you describe here,

3 the 21st Corps of the army of the Serbian Krajina, Republic of the Serbian

4 Krajina; is that correct?

5 A. Yes, it is.

6 Q. At the very beginning of your testimony yesterday, you explained

7 that Colonel Bulat had direct contact with Perisic, without strictly

8 adhering to his vertical chain of command with the headquarters of the

9 Serbian Krajina army; he went straight to Perisic.

10 A. What I said in my testimony was that he had direct contact with

11 Colonel Perisic along the line, which was a direct connection between the

12 21st Corps and the headquarters in Belgrade, and along another line he had

13 contacts with the headquarters of the army of the Republic of Serbian

14 Krajina.

15 Q. How do you know that?

16 A. I was at the office when he made his phone calls to Perisic.

17 Q. What were those occasions?

18 A. The one that comes to mind first was the one that related to the

19 joint attack with the 5th Corps of the Serbian army.

20 Q. When was that?

21 A. I believe it was in 1993. It is also fair to say that there were

22 several attacks of this kind, so I don't remember now what specific attack

23 it was at that time.

24 JUDGE KWON: Just a second.

25 Mr. Lazarevic --

Page 12479

1 THE WITNESS: Yes, Your Honour.

2 JUDGE KWON: Could you put a pause between question and answer.

3 THE WITNESS: I do apologise.

4 JUDGE KWON: In the transcript I note that Mr. Perisic is referred

5 to as "Colonel"; is it right?

6 THE WITNESS: No, he's a general.

7 JUDGE KWON: General Perisic. It was in line 8 of page 29.

8 Okay. Proceed.

9 MR. MILOSEVIC: [Interpretation]

10 Q. So from 1992 until 1993, you never heard Bulat speaking to

11 Perisic; right?

12 A. No, not with my own ears. I wasn't there.

13 Q. And this happened in 1993?

14 A. I sincerely believe it was.

15 Q. Wasn't it in 1994 and 1995, since you later described these events

16 as happening in these years?

17 A. No. It was one of the earlier attacks.

18 Q. Earlier attacks. And it was 1993?

19 A. Yes. I'm sure it was in 1993.

20 Q. I'm only trying to establish a time frame for the events you're

21 talking about.

22 THE INTERPRETER: Interpreter's correction. The attack was on the

23 5th Corps of the Bosnian army.

24 MR. MILOSEVIC: [Interpretation]

25 Q. You started working for KOS of your own free will, didn't you?

Page 12480

1 You said that you accepted this work after your discussion with this

2 person Nikola Zimonja, in your youth, and that's how had you started your

3 work as a spy. Did that happen of your own free will?

4 A. Absolutely. In fact, I was very enthusiastic when I started

5 working. I was delighted.

6 Q. And do you imagine it was not difficult to find out that even

7 Nikola Zimonja himself, at the time when he engaged you, as you say, was a

8 student himself and had nothing at all to do with the KOS?

9 A. I didn't know that. He was introduced to me as the lieutenant of

10 the Yugoslav army.

11 Q. Who introduced him that way?

12 A. My own father did.

13 Q. And you didn't know he was a student; is that what you're saying?

14 A. Absolutely not.

15 Q. All right. Fine. So you saw Nikola Zimonja for the first time in

16 1968; right?

17 A. Yes, right.

18 Q. That's what you say.

19 A. Yes.

20 Q. You see, I have a piece of information here that tells me that you

21 met Nikola Zimonja for the first time in 1995.

22 A. That is quite an incorrect piece of information, Mr. Milosevic.

23 Q. I just want to test it, see if it's right. You explained to me a

24 moment ago that up until 1991, except for the pause you made in 1984 and

25 then one year of pause later on, you sent in your reports regularly to

Page 12481

1 Zimonja. Do you happen to know, for example, that Nikola Zimonja, from

2 1971 up until 1980, was undergoing education in the former Soviet Union?

3 Does that mean that you sent those reports to him to the Soviet Union in

4 that nine-year period, from 1971 to 1980?

5 A. No, Mr. Milosevic. I would send in my reports to the Yugoslav

6 Embassy and they were to further hand them on. The reports probably went

7 to somebody else, because I would never hand in my reports to Mr. Zimonja

8 personally. I would leave the reports in the embassy.

9 Q. All right. I asked you a very specific question. I asked you who

10 you sent your reports to, gave them to, and you said yesterday all day

11 that you gave them to Zimonja. Now you say that you sent them in to

12 Zimonja, and when I ask about that nine-year period and tell you that he

13 was doing some education in the Soviet Union, you said that you did not

14 give them to Zimonja.

15 A. Mr. Milosevic, the reports that I sent in were addressed to

16 Zimonja. Now, who was getting those reports, I don't know. I thought

17 they were going to Zimonja. Whether anybody was authorised to take the

18 reports over on behalf of Zimonja, I can't know that. I don't know.

19 Q. All right. So many things that you claimed yesterday throughout

20 the whole day in fact I suppose you base them on assumptions, like you do

21 this particular fact and point, or perhaps --

22 JUDGE ROBINSON: Yes.

23 MR. GROOME: It's a characterisation --

24 THE INTERPRETER: Microphone, please, Mr. Groome.

25 MR. GROOME: It's a characterisation of Mr. Lazarevic's evidence.

Page 12482

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13 English transcripts.

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Page 12483

1 He's certainly entitled to ask him about specific facts that he believes

2 the witness assumed, but certainly to make a broad statement that

3 everything that the witness said was based on assumptions I believe is an

4 improper question.

5 JUDGE ROBINSON: I don't think it's really a question. It was

6 more a comment.

7 Continue, Mr. Milosevic.

8 THE ACCUSED: [Interpretation] Well, I have to respond to the

9 opposite side, Mr. Robinson, because if I were to present generalised

10 statements --

11 JUDGE ROBINSON: I have dealt with it. I have told you to

12 continue. Continue.

13 THE ACCUSED: [Interpretation] Very well.

14 MR. MILOSEVIC: [Interpretation]

15 Q. You yourself say, Mr. Lazarevic, that he, and I'm thinking of

16 Zimonja here, in 1990 was nominated the military attache to

17 Czechoslovakia; is that right?

18 A. Yes. That's Mr. Zimonja you're talking about.

19 Q. Right.

20 A. Yes, according to what Mr. Zimonja told me, that he was appointed.

21 Q. As he was appointed military attache in 1990, then, how can you

22 claim that Zimonja was at a meeting with you in 1991 in Vojnic and

23 Samarica at the beginning of 1992, when he was in fact the military

24 attache at that time in Prague?

25 A. He attended those meetings, Mr. Milosevic. Whether he was still

Page 12484

1 there in capacity of military attache to Czechoslovakia, whether he had

2 been replaced by that time, I don't know and I'm not interested, but the

3 fact remains that Colonel Zimonja was present at those meetings.

4 Q. All right. Fine. Tell me this, then: Let's go back to your

5 assignments. Your first assignment, as you yourself say, was to spy on

6 your colleagues, fellow students, during the 1968 demonstrations. Is that

7 right?

8 A. Spying is an ugly word. The term we used was we infiltrated.

9 Q. Well, I agree that it's a very ugly word, but that is the contents

10 of substance, as I understand it, of your work entailed. As you were a

11 student and as your statement -- and until yesterday morning you were a

12 protected witness at that, it has been redacted and I wasn't able to see

13 what faculty you graduated from, where and when.

14 A. Philosophy, Sarajevo.

15 Q. The faculty of philosophy in Sarajevo; is that right?

16 A. Yes, that's right.

17 Q. What group?

18 A. Languages.

19 Q. Tell me: For your first assignment and from the time you began

20 your work, were you paid for it?

21 A. Yes.

22 Q. So a moment ago you said you were delighted with the work you were

23 doing, and when we make up this whole picture we now see that you were

24 paid for your work. So the basic motive -- or rather, the motive for your

25 involvement was money; right?

Page 12485

1 A. No, that's not correct, Mr. Milosevic.

2 Q. What was your motive, then?

3 A. Purely ideological.

4 Q. So how much of it was ideological, how much was it lucrative?

5 A. Well, money wasn't important for me at that time.

6 Q. All right. Yesterday we heard from you that you received a new

7 identity here, a new country of residence, and so on and so forth. I

8 assume that you were given money too. So in this situation and in this

9 particular instance, the motive wasn't a new identity and money, but it

10 was ideological; is that it?

11 A. If, Mr. Milosevic, if I were to have to say why I did what I did,

12 fully disclosing my personality as just an attempt to establish the truth

13 of the events that took place in 1991 that I was present at, and my

14 identity, where I am residing, is completely irrelevant to this trial.

15 Q. Yes, I understand that it is irrelevant, but what I'm asking you

16 is this: How far was the motive of, how shall I put it, the material

17 side, material gain, relevant, the material gain that stems from a new

18 identity, a new country of residence, I assume a new job, for you and your

19 family? Although it is irrelevant, as you yourself say, with respect to

20 your testimony, but how relevant is it as a motive?

21 A. Mr. Milosevic, at this point in my life, I am living from one

22 salary, pay cheque, to another, so if you are trying to insinuate that

23 somebody has paid me a large sum of money for me to appear here today,

24 you're quite wrong.

25 Q. All right. Fine, Mr. Lazarevic. So to all intents and purposes,

Page 12486

1 as you began doing this in your student days, this was your in early youth

2 and you spent your entire life, as you yourself claim and state, working,

3 spying on your colleagues, fellow students to begin with, then you spied

4 on your colleagues from work, I can see from the rest of the explanations

5 you gave here, and finally, you spied on your co-combatants, your fellow

6 fighters, during the war in Croatia; right?

7 A. Mr. Milosevic, there's something lacking there in your question,

8 and that is who issued the orders to me to spy. I did not work for some

9 minor service. I worked for the intelligence service of Yugoslavia,

10 working on Yugoslavia's internal and external security. So to say that I

11 was a spy is not quite logical in that sense, because I was in fact

12 working for my own country, the country that you yourself belonged to at

13 that time.

14 Q. Well, that's why I'm asking you, Mr. Lazarevic, precisely because

15 I find it strange that somebody was working in KOS and that nobody knows

16 him in KOS, nobody knows about him, including, in 1995, the man who you

17 refer to constantly.

18 You say in your statement that for a period of time you were in

19 London. Did you spend some time in Canada?

20 A. Never.

21 Q. You were never in Canada?

22 A. No.

23 Q. And while in London, you were in charge of the Serb emigres there;

24 right?

25 A. Yes.

Page 12487

1 Q. Now tell me: Your impressions at that time and your opinions now,

2 how far was the Serb emigre population nationalistic at all,

3 nationalistically disposed? How far was it a political opposition to the

4 present authorities in Yugoslavia?

5 A. To a very minimum extent.

6 Q. I see. A very minimum extent.

7 A. Yes, that's right.

8 Q. And what is your impression? How far were the Serbs anyway

9 anti-Croat disposed at all and were they ever anti-disposed against the

10 Croatians or Croats? Did you ever feel that?

11 A. Where? Where do you mean?

12 Q. Well, when you were spying on the Serb emigres.

13 A. That wasn't the object of my assignment. The object of my

14 assignment was to find who was in the leadership of those organisations

15 and what their future plans were, if they had any, and whether they had

16 any links with the emigres or other emigres or, rather, people within

17 Yugoslavia, not whether they were anti-Croat disposed. Actually, at that

18 time, they were anti-Tito.

19 Q. You mean anti-regime. They weren't anti-Croat or anti-anything

20 else, they weren't confronted on that basis with anyone; right?

21 A. Yes, you're quite right there.

22 Q. Now, was there any nationalism and nationalist confrontation in

23 what you saw with the Croatian emigres? And I'm thinking of the Ustasha

24 emigres.

25 A. Yes, that was very strong and very pronounced.

Page 12488

1 Q. I see. You say very pronounced.

2 A. Yes.

3 Q. Do you know the role played by the Croatian Ustasha emigres in the

4 events that took place before the break-up of Yugoslavia?

5 A. I'm partially aware of that, yes.

6 Q. How far was this anti-Serb feeling which otherwise burgeoned in

7 Croatia in 1989 and 1990, prior to the elections and after the elections,

8 how far was that -- did that have its influence on the Ustasha emigres and

9 how much did they wield influence on the citizens and political parties,

10 et cetera? So how far did this sentiment affect the Serbs not only in the

11 Krajina but all over Croatia?

12 A. Are we talking about any of the Croatian emblems, the chequerboard

13 emblem, radio stations, singing of songs or whatever?

14 Q. Well, I'm not only talking about those emblems and the singing of

15 nationalistic songs, although I do mean that too. I'm talking about

16 dismissals from work, placing mines and bombs in apartments and houses,

17 the killings, the fact that people were taken off, and something that the

18 Croatian press is quite freely writing about today. I'm sure you read the

19 Croatian press. And there's talk of that quite openly now and discussions

20 that are being held there now. So everything that went on along these

21 lines, did that have any affect and influence on the Serbs, not only in

22 the Krajina but throughout Croatia?

23 A. Probably it did, yes.

24 Q. And do you know, because you say you worked for KOS, so do you

25 know just how many members of the Ustasha emigres at the end of 1989 and

Page 12489

1 beginning of 1990 returned to Croatia, and how far they wielded an

2 influence on official Croatian policy and the policy towards the Serbs,

3 first and foremost?

4 A. Well, I do have some knowledge, but it would be ludicrous if you

5 thought that I knew everything. Unfortunately, I don't know everything,

6 although I would have liked to have known everything. But the fact is

7 that I did know some of the members of the Ustasha emigres who were

8 present in the areas I moved around in, and specifically, for example, the

9 leader, or rather, the commander of Karlovac. One of the Brate Brajdic

10 and two others that had come in from Sweden. They were well known people

11 in the very rigid stance they had towards Serbs and Serbs in Yugoslavia,

12 and so on and so forth.

13 Q. All right. The brothers you mentioned that had come from Sweden

14 that were rampant in those parts, you say you don't know much about them,

15 because, as far as I was able to understand, you were in Topusko and

16 Vojnic.

17 A. Velika Kladusa, Mr. Milosevic.

18 Q. Right.

19 A. Before the conflict.

20 Q. Right, before the conflict in Velika Kladusa, and after that in

21 Topusko and Vojnic. So you don't know much about the events that I'm

22 asking you about, because you weren't -- you couldn't have known and seen

23 everything from where you were.

24 A. Yes, mostly I got my information from others. At some of these

25 events I was present myself.

Page 12490

1 Q. How, then, from your positions in Velika Kladusa and Vojnic, you

2 have a whole image and picture of the state of affairs in the Republic of

3 Srpska Krajina about the alleged Serb crimes, about all kinds of, as far

4 as I was able to hear from you yesterday, crimes that were committed and

5 the casualties of those crimes. You were an interpreter, you say, and as

6 such a liaison officer with the UN, so how were you able, from that

7 position and that place, to have all these myriad information that we

8 heard about yesterday?

9 A. Well, the information I presented yesterday relates to the period

10 from February 1992 until August 1995, when I was the liaison officer,

11 which meant that I was in constant contacts with the United Nations

12 commands on the territory of the 21st Banija Corps. So most of those

13 reports were accessible to me on a daily basis.

14 Q. Well, it is from those UN reports, is it, that you draw your

15 conclusions, you deduce, if I can put it that way, and bring conclusions

16 as to the political intentions and political leadership of the Republic of

17 Srpska Krajina, of Serbia itself, of Yugoslavia, of the general political

18 state of affairs, the military state of affairs and all the rest of it?

19 Is that the basis from which you drew all this information, all your

20 explanations?

21 A. I said at no point that the groundwork and foundations of my

22 knowledge were United Nations reports. Most of the events that I describe

23 I was present at myself, personally, and the events that were talked about

24 during the briefings, early-morning briefings at my command and

25 headquarters. So it was a compilation of knowledge and information, not

Page 12491

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Page 12492

1 only from a single source, but from a number of sources, including my own

2 personal experience.

3 Q. All right, then. How come in those personal experiences of yours

4 there is nothing -- I don't wish to make a comparison, but for instance,

5 we had here a journalist. His name was Jovan Dulovic. He also knew

6 nothing about the great crimes that were perpetrated against the Serbs,

7 for example. So you too have nothing and know nothing about the crimes

8 perpetrated against the Serbs, but you explain here and give explanations

9 to the effect that Serbs were criminals, thieves, that they burnt houses,

10 tortured, that they set mines; that they didn't want anything that was

11 good. They didn't want peace, they didn't want a truce of any kind, that

12 they undermined each and every initiative to move forward. How come you

13 make that kind of --

14 JUDGE ROBINSON: Yes.

15 MR. GROOME: This is an inaccurate characterisation of what the

16 witness testified to yesterday, and I don't see a question being posed to

17 the witness at this time.

18 JUDGE ROBINSON: Mr. Milosevic, I remind you --

19 THE ACCUSED: [Interpretation] Let me reformulate that question.

20 MR. MILOSEVIC: [Interpretation]

21 Q. The thousands of Serbs that were killed, did the Serbs themselves

22 kill them? Because you say and said a moment ago they were responsible

23 for 80 per cent of their own victims in the Krajina between 1992 and 1995.

24 Or was this committed, these crimes perpetrated by the revamped Ustasha

25 movement?

Page 12493

1 A. What I said, it refers to the 21st Corps, Mr. Milosevic. They

2 were not generalised figures. I spoke about an analysis of the deaths

3 that occurred within the 21st Corps. These figures do not relate to the

4 whole of the Balkans or of the RSK or Croatia or Serbia; I'm just talking

5 about the territory that I was -- had operative assignments in.

6 Q. So the figures just relate, as you say, to where you were, whereas

7 all the other observations relate to the entirety of the events that took

8 place in Yugoslavia, in Croatia, the Republic of Srpska Krajina, the

9 Srpska Republic and Serbia proper; right?

10 A. Only what applies to Kordun. I never gave a general statement

11 here that would cover everything, the entire territory. If I gave

12 evidence, I talked about events where I was present personally.

13 Q. All right. Let us then turn to other issues. In 1984, as you

14 claim yourself, you started, again on orders of KOS, working for

15 Agrokomerc in Velika Kladusa; is that right?

16 A. Yes.

17 Q. And you say that you were in charge of foreigners and that later

18 on you switched and started working in the production area.

19 A. Yes. I was in research and development department.

20 Q. And throughout the time, based on my information, you worked there

21 as an interpreter, and your wife's name is Zorica?

22 MR. GROOME: Objection, Your Honour.

23 JUDGE ROBINSON: Yes, Mr. Groome.

24 MR. GROOME: Can Mr. Milosevic state the reason why it's necessary

25 to identify this man's wife, given the history of this witness? How is

Page 12494

1 that relevant?

2 JUDGE ROBINSON: Yes, but is he giving evidence in private session

3 or no?

4 MR. GROOME: Your Honour, this witness is in a unique situation in

5 that he has been relocated. Unless there's some relevance to mentioning

6 the wife's name, I would ask that the question be stricken, and if there

7 is some relevance, that it be taken in private session.

8 JUDGE ROBINSON: Mr. Milosevic, can you explain the relevance of

9 this?

10 THE ACCUSED: [Interpretation] Well, Mr. Robinson, I am here

11 challenging what the witness said, namely, that he went to work for

12 Agrokomerc pursuant to KOS orders, that he started working -- because he

13 started working as an interpreter there, he got that job through his own

14 contacts, whereas his wife worked as a physical education teacher.

15 JUDGE ROBINSON: Out of an abundance of caution, we'll go into

16 private session for this question.

17 [Private session]

18 [redacted]

19 [redacted]

20 [redacted]

21 [redacted]

22 [redacted]

23 [redacted]

24 [redacted]

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Page 12495

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19 [redacted]

20 [Open session]

21 MR. MILOSEVIC: [Interpretation]

22 Q. So you're claiming that Belgrade was already concerned at that

23 time regarding the safety of Agrokomerc because it was already under the

24 control of the Muslims at the time?

25 A. Yes. This is how it was portrayed to me.

Page 12498

1 Q. And when you say "Belgrade," are you referring to the federal

2 government or Republic of Serbia?

3 A. I'm referring to the Main Staff of the JNA and KOS.

4 Q. And if there was a concern, do you think that the reason for that

5 was that Agrokomerc was under the control of Bosnian Muslims, or was it

6 because of the financial scandal that broke out and started shaking this

7 huge company that was established in that area?

8 A. I didn't go into reasons for sending me there.

9 Q. You didn't go into these reasons; however, you stress the

10 nationalist aspect and not the financial one that was well known in

11 Yugoslavia at the time.

12 A. There was a large amount of foreign nationals in Velika Kladusa,

13 and that was quite an important piece of information at the time.

14 JUDGE ROBINSON: Mr. Milosevic.

15 MR. MILOSEVIC: [Interpretation]

16 Q. A high number of foreign nationals?

17 JUDGE ROBINSON: We are at the time for the break.

18 Mr. Lazarevic, we're going to take a break for half an hour.

19 [Trial Chamber confers]

20 JUDGE ROBINSON: We take the break for 20 minutes. During the

21 break you're reminded not to discuss your evidence with anybody.

22 --- Recess taken at 10.30 a.m.

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

24 JUDGE ROBINSON: Mr. Milosevic, you'll continue with your

25 cross-examination.

Page 12499

1 MR. MILOSEVIC: [Interpretation]

2 Q. Since you say yourself that you followed the activities of

3 Sulejman Ugljanin at the time in Velika Kladusa concerning the SDA, tell

4 us, please: What was that party all about?

5 A. I don't quite understand your question. What do you mean, what

6 was the party all about? What kind of a party the SDA was?

7 Q. Yes.

8 A. It was a nationalist party.

9 Q. And in addition to this nationalist character of this party, were

10 there also elements of Islamic fundamentalism?

11 A. Yes, absolutely.

12 Q. Who did Ugljanin meet with in Velika Kladusa area?

13 A. With Fikret Abdic.

14 Q. I didn't hear.

15 A. With Fikret Abdic.

16 Q. All right. And were any Serbs members of the SDA?

17 A. I didn't know about that.

18 Q. You worked in Velika Kladusa normally, legally, under your own

19 legal name?

20 A. Yes, that's right.

21 Q. Please explain to us: How was it that you, as a Serb, were able

22 to attend those meetings of the SDA in order to be able to follow Sulejman

23 Ugljanin's activities?

24 A. I didn't attend private meetings of Sulejman Ugljanin, but I did

25 attend public meetings that were held at the local soccer field.

Page 12500

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Page 12501

1 Q. All right. Since you said yourself that you spent seven years

2 there, using your own legal name, yesterday you described an event when

3 you were in a cafe, and this was just prior to what you described as an

4 assignment when you had to eliminate the emigres from Sweden, the brothers

5 Brajdic, and then yesterday you told us that two officers entered the

6 cafe, that they were drunk, if I understood you well, and that they said

7 something about Greater Serbia, and in a way they got you involved in that

8 and compromised you. Is that right?

9 A. Everything you said was correct except for one thing: I wasn't

10 present in a cafe where the attack was supposed to be carried out, but I

11 was in another cafe.

12 Q. All right. But at any rate, was it right?

13 A. Yes.

14 Q. You said that two officers came in, they were drunk, and said

15 something about the Greater Serbia.

16 A. Those were two officers from the JNA.

17 Q. All right. From the JNA. And what did they say?

18 A. They said that this whole area where we are now will be Greater

19 Serbia soon.

20 Q. All right. That's what you said yesterday and this is what is

21 contained in your statement regarding that event. This is on page 7. You

22 said that: "I happened to be in a cafe on the 21st of December, 1991,

23 three days prior to the planned ambush, when a captain entered the bar

24 wearing a JNA uniform, completely drunk. As he entered, he started

25 yelling, 'Brother Serb.' It was clear that he was addressing me because I

Page 12502

1 was the only Serb in that establishment. I tried to ignore him, but it

2 didn't fool anyone. I immediately left the bar, went back home, and

3 through -- contacted police station in Vojnic on the radio. I told

4 Ajdinovic what had happened. He told me to go and calm down the captain

5 and that he would send someone to collect him," and so on.

6 So yesterday you said that two people came and spoke about the

7 Greater Serbia, and in your statement you say that it was the JNA captain

8 who came in, drunk, and said to you, Brother Serb, "Brate Srbine." In

9 Velika Kladusa, everyone knew that you were a Serb - you just told us that

10 you used your legal name - so how could this have compromised you when he

11 called you Brother Serb?

12 A. He didn't just call me Brother Serb. He also kissed me and then

13 he spoke how all of this will be Serbia one day. And I simply completed

14 what I said in my statement.

15 Q. All right. But isn't it clear that there is a great difference

16 between what you wrote in your statement and what you said here?

17 A. I don't see any great discrepancy here. I just see that I added

18 some details.

19 Q. Do you mean that the details are the difference between one

20 captain or two drunk officers?

21 A. I said two officers in my statement three years ago.

22 Q. Well, your statement here reflects just one person and one

23 captain, so are you saying that this is another mistake in your statement?

24 A. No. There is no mistake in my statement. I spoke about two drunk

25 officers. It is possible that later on, when the statement was

Page 12503

1 translated, there was an error made, but I don't want to go into that.

2 Q. All right, Mr. Lazarevic. Tell me, please: How did you come to

3 leave Agrokomerc?

4 A. I was accused of taking some documents from the office of Mr.

5 Fikret Abdic.

6 Q. That you took some documents from the office of Mr. Fikret Abdic?

7 A. Yes.

8 Q. And is it true that you were fired from Agrokomerc due to some

9 debts that amounted to 30.000 German marks and that when -- and that you

10 fled in 1991 to the village of Gejkovac?

11 A. That's absolutely not correct. Upon leaving Agrokomerc, I

12 remained in Velika Kladusa for that entire year, working in my own

13 company.

14 JUDGE ROBINSON: Mr. Milosevic, and Witness, I can sense that the

15 speed is working a hardship for the interpreters, so you must observe a

16 pause between question and answer, both of you.

17 THE WITNESS: I sincerely apologise, Your Honour.

18 MR. MILOSEVIC: [Interpretation]

19 Q. So you didn't spend three months in the home of the Lakic family?

20 A. The Lakic family? I never heard of them.

21 Q. And tell me, please: Is it true that you had -- you owed 2.000

22 German marks to Toso Pajic, and to Djuro Skaljac you owed 1.500, and to

23 another person 3.000 German marks?

24 A. That's all incorrect.

25 Q. All of it?

Page 12504

1 A. Yes, all of it.

2 Q. All right. In the beginning of 1990, you established your own

3 company, for which you say was financed by KOS.

4 A. Partially.

5 Q. What does "partially" mean?

6 A. "Partially" means that part of the equipment was paid by the JNA

7 money.

8 Q. You said that in 1990, beginning of 1991, KOS left you alone.

9 A. Yes, more or less they did.

10 Q. I understood that you started working on your own free will, based

11 on what you just told us, and now you're telling us that they left you

12 alone. Does that mean that prior to that they harassed you, or does this

13 "leaving alone" mean something else?

14 A. Working for KOS was no harassment at all. It was part of my

15 nature.

16 Q. All right. On page 6 you describe an alleged meeting that you had

17 in Vojnic at the police station with Zimonja, Ajdinovic, Pajic, and Lukic;

18 is that correct?

19 A. Not Lukic; Skaljac.

20 JUDGE ROBINSON: Mr. Groome, do you have the statement?

21 MR. GROOME: Yes, I do, Your Honour.

22 JUDGE ROBINSON: I think we should have copies.

23 MR. GROOME: I'd also ask that witness be provided a copy. It's a

24 lengthy statement and seems unfair for him to be asked particular

25 sentences.

Page 12505

1 JUDGE ROBINSON: Yes. Let that be done.

2 MR. GROOME: Your Honour, I have one copy here. I'll have

3 somebody photocopy -- copies for the Chamber and we should have them in

4 the next five minutes.

5 JUDGE ROBINSON: Thank you. Fine.

6 MR. GROOME: And I would ask that Mr. Milosevic please tell us is

7 it the Serbian copy or the English copy when he refers to a particular

8 page number. It will be helpful.

9 THE ACCUSED: [Interpretation] All right.

10 JUDGE ROBINSON: Yes.

11 THE ACCUSED: [Interpretation] Right.

12 MR. MILOSEVIC: [Interpretation]

13 Q. I'm asking you again: Isn't it true that at that time Zimonja was

14 a military attache in Prague?

15 A. I don't know about that. All I know is that he attended that

16 meeting.

17 Q. You say at the police station in this line of untruths that you

18 are saying here, none of these people had any status in the police force.

19 Was that the military command?

20 A. Not correct. Toso Pajic was the chief of police in Vojnic, and

21 Djuro Skaljac was his deputy.

22 Q. Answer me: Was it the military command pulled out from Karlovac

23 because they were under constant siege and attack by Croatian paramilitary

24 formation?

25 A. There was not a military command in Vojnic. It was in a different

Page 12506

1 place at the time.

2 Q. Does that mean that this Operative Group was pulled out of

3 Karlovac where it was exposed to attacks by Croatian paramilitary

4 formations?

5 A. I really don't know.

6 Q. Do you know that the task of the then command was to accept parts

7 of the JNA that had been blocked in barracks in Jastrebarsko, Karlovac,

8 and Zagreb?

9 A. All these events that you are mentioning, Mr. Milosevic, happened

10 before I moved to the Republic of Serbian Krajina.

11 Q. All right. You claim that Zimonja, who was then in

12 Czechoslovakia, said that Croatians and Muslims are working together to

13 establish paramilitary groups and that these groups are a greater threat

14 to civilians than to the JNA.

15 A. No. In the report that I made, it said lesser threat, not

16 greater. I remember that I did not attach great importance to those

17 elements in Velika Kladusa.

18 Q. Further on, you say that you felt yourself that it was your

19 patriotic duty to help the organisation of the self-defence of Serb

20 civilians. Is that true?

21 A. Yes. I always felt that.

22 Q. So what was the threat to them exactly when they needed to

23 organise self-defence?

24 A. Establishment of very nationalist parties, such as the SDA and the

25 HDZ, which did not conceal their animosity to the Serbian population.

Page 12507

1 Q. Does it mean unequivocally, then, that Serbs in Krajina and in

2 this area of Zazine were jeopardised by the rising Croatian and Muslim

3 nationalism?

4 A. Of course they were.

5 Q. You assert that at that meeting the plan of attack on Cetingrad

6 was also discussed.

7 A. Yes.

8 Q. And as you say, Ajdinovic advocated that everybody should be

9 locked up and killed by shelling. Is that correct?

10 A. Yes.

11 Q. Is it correct that in Cetingrad there were no Serbs at all?

12 A. I don't know.

13 Q. What happened to Serbs from Cetingrad? Were they expelled?

14 A. I already said that I don't know about any Serbs being in

15 Cetingrad at all at the time I'm speaking about.

16 Q. All right. You say that you got the task to form a secret group

17 at that meeting, which you say consisted of you, Mile Bosnic and a person

18 named Zeljko, who you know nothing else about.

19 A. It was not about forming a secret group. It was about organising

20 Serbs in Velika Kladusa for any contingency.

21 Q. What kind of Serb it is if you don't know anything but his name?

22 A. I'm talking about Mile Bosnic. His wife was a hairdresser. This

23 Zeljko person was a driver to Mile Bosnic and he had no major role.

24 Q. On page 7, you said that at the police station in Vojnic you were

25 issued with equipment and weapons for this secret group.

Page 12508

1 A. That's not true. The weapons were issued for a specific

2 assignment we got.

3 Q. Which specific assignment?

4 A. Elimination of Ustasha emigres and those helping them.

5 Q. Who was supposed to carry out the task?

6 A. Myself and two JNA officers.

7 Q. Is that the assignment where your cover was blown by somebody

8 telling you "Brother Serb" in a cafe?

9 A. More or less. There are more details that I didn't mention in the

10 incident when they entered the cafe.

11 Q. How could they have blown your cover if you had lived in Velika

12 Kladusa for a long time by then and everybody knew you were a Serb?

13 A. I wasn't active politically.

14 Q. And by addressing you as Brother Serb, he proclaimed you

15 politically active; is that so?

16 A. Yes, you're right.

17 Q. You say that you were supposed to distribute weapons to them and

18 see them every day. Did you do that?

19 A. The weapons I received were issued for my use, and it was stored

20 at the apartment where I lived. And who was I supposed to meet on a daily

21 basis?

22 Q. I'm asking on the basis of your statement. You got three rifles.

23 They were not all for your personal use, were they?

24 A. I got one Scorpio with a muffler, an automatic rifle with two

25 cartridges, a pistol, and four hand grenades.

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Page 12510

1 Q. These rifles mentioned in the statement, you didn't get?

2 A. Mr. Bosnic received them for other Serbs.

3 Q. All right. Look up your own statement and you will see it is not

4 correct either.

5 A. Which page, Mr. Milosevic?

6 Q. I'll find it. Give me a second. I'm sorry to waste time in this

7 way, but ...

8 Here it is, on page 7. "In this period I was invited to the

9 police station in Vojnic." The beginning of page 7. "At the police

10 station in Vojnic I was issued with weapons and other equipment; a

11 Scorpion with silencer, three automatic rifles (Yugoslav version of

12 AK-47), a pistol, four hand grenades, ammunition, and two Motorola radios.

13 All of these things were given to me in a bag by a uniformed policeman as

14 I left the station. I was told that I should notify Bosnic and Zeljko,

15 last name unknown, to be ready to go into action should I contact them. I

16 was to distribute weapons to them and I was supposed to meet with each of

17 them at least once a day to see if they had heard or seen anything

18 suspicious. If they had, I was to report it to Vojnic. Otherwise, I was

19 told to return to Velika Kladusa and await further instructions."

20 End of your quotation. Of your statement, by the way. You claim

21 it is not correct.

22 A. No, this statement is correct. But, Mr. Milosevic, two minutes

23 ago when you asked the question, you asked me: Did you meet with them

24 every day? And I was assuming that you were talking about JNA officers

25 who were supposed to carry out that assignment, because that question

Page 12511

1 seemed to refer to that statement which was actually never carried out.

2 Mr. Bosnic was a family friend and I could have seen him every day. And

3 his driver as well, because he was always with him.

4 Q. I quoted this because you said earlier that those three rifles

5 were received by you for your own personal use, and I asked what for, and

6 you said it was not correct.

7 A. I'll repeat again what I said. I said I got a pistol with a

8 muffler for my own personal use, rifles, four hand grenades, two

9 Motorolas, et cetera. The three automatic rifles mentioned in my

10 statement were given to Bosnic for other people.

11 Q. How can you read this differently? It says here, "I was invited

12 to Vojnic and at the Vojnic police station I was issued with weapons and

13 other equipment; a Skorpion with silencer, three automatic rifles, a

14 pistol, four hand grenades, ammunition, and two Motorolas."

15 A. So where is the difference between your statement and my

16 statement?

17 Q. This is not my statement. You say that you did not receive three

18 rifles.

19 A. Let's rewind a little. You say that I got it for my personal use

20 and I'm saying that they were given and intended for Mile Bosnic;

21 Motorolas, hand grenades, a pistol, yes.

22 Q. Yes, but you also got rifles.

23 A. I did, but they were given to Bosnic.

24 Q. You said a moment ago the rifles were given to someone else, not

25 you. You can look up the transcript later. I don't want to waste time

Page 12512

1 over this.

2 Tell me one other thing: What was the name of that policeman who

3 issued you with these weapons and equipment?

4 A. I don't remember.

5 Q. You don't know?

6 A. No.

7 Q. Are you sure that somebody issued these weapons and equipment at

8 all?

9 A. Of course I'm certain.

10 Q. You describe the attack on Cetingrad.

11 A. Precisely.

12 Q. Please, what date did the attack happen?

13 A. As far as I can remember, it was late October. In 1991.

14 Q. Who made or who could have made the decision to attack Cetingrad?

15 A. The JNA.

16 Q. You said it was made by Ajdinovic, Pajic, Skaljac, and Zimonja.

17 A. They made the recommendation to the General Staff of the JNA in

18 Belgrade.

19 Q. Are you aware that the decision on that attack was made by the

20 headquarters of the Territorial Defence that was in Vojnic at the time,

21 whereas Vojnic was not in the RSK at all at the time?

22 A. I don't know that the Territorial Defence had anything to do with

23 if. Did they have artillery or was the artillery in the hands of the

24 JNA? All I know is that two high-ranking officers of the JNA analysed the

25 situation on the ground, submitted their report to the General Staff in

Page 12513

1 Belgrade, and then the attack followed. That's all I know.

2 Q. All right, Mr. Lazarevic. If you had only read newspapers from

3 that time, or if you had only asked anyone, you would know now that it is

4 not true. The attack on Cetingrad was on the 28th of November, 1991.

5 A. Mr. Milosevic, we are talking about things that happened 12 years

6 ago. You can't expect me to remember the exact date, hour, minute and the

7 rest. All I know, it was cold, it was winter.

8 Q. All right, then. The fact that this piece of information you

9 quoted is incorrect has no importance, does it?

10 A. That's not quite true. I know the event happened. I was there.

11 Whether it was in late October or in November is not so important to me.

12 Q. It was on the 28th November. Anyway, why did the attack happen?

13 A. I don't know.

14 Q. Do you know that the attack was caused by the fact that

15 paramilitary formations in Cetingrad, several days before the attack,

16 killed Lieutenant Colonel Rankovic and later, out of fear, and almost

17 without a fight, left Cetingrad?

18 A. That's interesting, because the information I had was that this

19 lieutenant colonel was killed with a bullet in the back.

20 Q. In Cetingrad?

21 A. I know -- I heard that he was killed by Serbian forces.

22 Intentionally or not, I don't know.

23 Q. He was not killed in combat?

24 A. He was killed outside of Cetingrad, and the medical report said

25 that the bullets came from the back.

Page 12514

1 Q. And then Croats, after the matter of Rankovic, left Cetingrad

2 almost without a fight, because Serbs had killed him.

3 A. I don't understand.

4 Q. You claim that Rankovic was killed by Serbs.

5 A. I'm not claiming anything. Those were the rumours, the stories

6 that made the rounds. Mr. Milosevic and Your Honours, I want to state

7 very clearly once again: My testimony refers to events which I attended

8 personally and not events that happened in Cetingrad while I was in Velika

9 Kladusa. I can't give you any information on that.

10 Q. But you still speak about it. You refer to it in your statement.

11 You can't say now that you know nothing about it. You said that Zimonja's

12 plan was favoured and accepted and the corridor was left for the

13 population of Cetingrad to leave.

14 A. That's all I know.

15 Q. When was the last time you were in Cetingrad before the attack?

16 A. I never really was in Cetingrad. I was in transit towards

17 Plitvice twice.

18 Q. How can you say it was undefended except for perhaps a few men

19 with small arms? How can you say that when you have no direct knowledge,

20 as you say now?

21 A. I talk about things that I heard on the ground.

22 Q. Oh, so you heard about it. And tell me: Who were the people who

23 defended Cetingrad?

24 A. I don't know that it was defended at all. I keep saying that the

25 attack was carried out. I know I was standing on a hilltop with a group

Page 12515

1 of other people, that we were watching the explosions in the skies, and

2 that the inflow from Cetingrad into Velika Kladusa ensued after that.

3 Q. And who was this -- who were these men who ran away to Velika

4 Kladusa?

5 A. Some of them were armed, some were not.

6 Q. Do you know the extent of destruction in Cetingrad and the amount

7 of casualties? Do you have any information on that?

8 A. No, I don't.

9 Q. You didn't take part in the attack?

10 A. No, I didn't.

11 Q. Did Brajdic brothers, whom you mentioned as Croatian extremists

12 from Croatia, also flee Cetingrad?

13 A. Yes.

14 Q. And in mid-December 1991, you got the assignment to kill them; is

15 that true?

16 A. Them and anyone else who happened to be in the cafe at the time.

17 Q. How can you explain -- a very simple question here: How can you

18 explain that you, as an interpreter, a civilian, got an assignment to kill

19 someone?

20 A. I didn't think of myself only as an interpreter or a civilian in

21 those events, one; and second, the assignment I received boiled down to

22 the fact that I was on the ground at the time, that I was familiar with

23 that part of Velika Kladusa, that I was familiar with the persons in

24 question, and I was supposed to be one of a threesome.

25 Q. You mean to say that this threesome was formed and you were one of

Page 12516

1 this threesome to commit a murder?

2 A. I wouldn't put it that way. You are putting things in a different

3 context, and I can't explain it. It is a fact that the task was issued to

4 eliminate someone. It is also a fact that it never happened. Another

5 fact is that I left Velika Kladusa before anything happened, and

6 eventually the assignment was never carried out. And in any case, I would

7 have found a pretext to avoid it, whatever happened.

8 Q. So you accepted this assignment and a threesome for liquidation

9 was formed, of which you were a member.

10 A. More or less, you are right.

11 Q. And you say, on page 8, paragraph 5, that some ten days later,

12 another unknown officer, more precisely, a military policeman of the JNA,

13 drove you to Samarica, in Banija, an isolated and very safe place in a

14 national park between Petrinja and Bosanski Novi, which served as

15 headquarters, operative headquarters of the JNA.

16 A. I'm trying to find this paragraph. Please bear with me.

17 JUDGE ROBINSON: Have you found it, Mr. Groome?

18 THE WITNESS: I'm still looking. It would be of very great help

19 to me if Mr. Milosevic would actually tell me which page I'm searching

20 for.

21 JUDGE ROBINSON: Page 8, paragraph 5, but I haven't found it in my

22 text.

23 MR. GROOME: Is Mr. Milosevic referring to the Serbian version or

24 the English version? Because the pagination will differ.

25 JUDGE ROBINSON: Is it the Serbian version, Mr. Milosevic?

Page 12517

1 THE ACCUSED: [Interpretation] I'm talking about the Serbian

2 version, yes. Second paragraph from the top, page 8. "After these ten

3 days passed, a military policeman showed up and told me to go with him.

4 We drove to Samarica, in Banija, which was the headquarters of the JNA 8th

5 Operational Group."

6 JUDGE ROBINSON: It's page 9 in the English text, the beginning of

7 the second paragraph.

8 THE WITNESS: I've got it, Your Honour. I'm reading it now.

9 MR. MILOSEVIC: [Interpretation]

10 Q. And then you go on to say that it was very secure and it was a

11 place between Petrinja and Bosanski Novi. "It was very secure and served

12 as the JNA's operational headquarters for the northern part of Croatia,"

13 and so on and so forth.

14 Now, the headquarters of the operational group -- have you found

15 it, Mr. Lazarevic? Have you found the passage?

16 A. Yes, I have. I found your version and now I'm looking at the

17 English version that I have before me here. [In English] So what is the

18 question? [Interpretation] So what is the question?

19 Q. The question is the following, Mr. Lazarevic: Once again you are

20 thinking things up, because the headquarters of the 8th Operational Group

21 was not at Samarica but at Petrova Gora. So why are you speaking

22 untruths?

23 A. In February, March, 1992?

24 Q. Precisely when you say that the headquarters of the 8th

25 Operational Group was at Petrova Gora and not at Samarica, and there are

Page 12518

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Page 12519

1 documents to bear that up.

2 A. Mr. Milosevic, I was told that it was at Samarica.

3 Q. All right. Quite obviously you have very characteristic answers

4 when you're not telling the truth. You go on to say the following: Thanks

5 to Zimonja at the time, you suddenly became a lieutenant colonel,

6 got that rank. Is that what it says, "suddenly," in my report?

7 A. No.

8 Q. No, it doesn't. I'm asking you: Suddenly you were accorded a

9 rank, and it was lieutenant colonel of the JNA --

10 JUDGE ROBINSON: Now, Mr. Milosevic, let us know the page to which

11 you refer in the statement so that we can follow it.

12 THE ACCUSED: [Interpretation] I'm talking about that same

13 paragraph, Mr. Robinson, and this is what he says: "I was given a uniform

14 with a JNA's lieutenant colonel's rank," and in brackets, "As later to

15 become the RSK army." "And given a room in a house at the headquarters.

16 Zimonja was not present but it was obvious that he was responsible for my

17 preferential treatment."

18 MR. MILOSEVIC: [Interpretation]

19 Q. Mr. Lazarevic, you know that two civilian persons with a

20 university degree, whether they be doctors or interpreters, engineers or

21 whatever, professionals in their field, they're always given some military

22 rank by way of status, to denote their status, even interpreters, who went

23 as civilians sometimes to the United Nations detachments, they would get

24 ranks too, the rank of lieutenant or whatever, to give them some sort of

25 status. So they weren't actually soldiers, the rank and file, but

Page 12520

1 officers. So you, as an interpreter, were given this rank as a

2 designation and not as an actual position and rank in the headquarters.

3 You performed the function of an interpreter for English because you spoke

4 English.

5 A. Yes. I didn't have any command functions at the headquarters.

6 Q. So you were a liaison officer - that was your function - with

7 people who speak the same language as you do yourself; is that right?

8 A. Yes.

9 Q. Now, at that time -- let me first ask you: Was Bulat the

10 commander there and then?

11 A. No, he wasn't.

12 Q. But did you hear him talk to Perisic on that occasion?

13 A. No.

14 Q. Do you claim that the army of Republika Srpska was formed from the

15 JNA, or rather, that the JNA became the RS army?

16 A. Part of the equipment and manpower, yes.

17 Q. All right. When the JNA withdrew from Croatia, JNA members stayed

18 on there who were from the region; is that right?

19 A. Yes.

20 Q. You were from Belgrade and you were an interpreter; right?

21 A. No. I was a liaison officer.

22 Q. All right. A liaison officer with the United Nations?

23 A. And the ECMM, and the Red Cross, et cetera.

24 Q. So with international organisations.

25 A. Quite right, Mr. Milosevic. That's what I was doing.

Page 12521

1 Q. So what I'm saying is the officers that were from the Krajina

2 stayed on in Krajina to form the army of the Republic of Serbian Krajina;

3 right?

4 A. Right.

5 Q. How, then, do you claim that the army of Republika Srpska Krajina

6 was part of the army of Yugoslavia?

7 A. By virtue of its formation, by virtue of the orders it received,

8 by virtue of the fact that it had brought in the convoy, equipped it with

9 weapons, fuel, food, et cetera.

10 Q. Let's distinguish here between some sort of assistance from actual

11 command, the function of command. Do you claim that the General Staff of

12 the army of Yugoslavia was in command of the army of the Republic of

13 Serbian Krajina?

14 A. I'm saying that the General Staff of the JNA was in command of the

15 officers who were serving their time in the Krajina region and in the

16 army.

17 Q. How can you claim that?

18 A. Because there was a constant link between the General Staff of the

19 army in Belgrade and the headquarters of the Krajina army, and Belgrade

20 paid the officers directly from Belgrade.

21 Q. Let's leave aside material assistance and remuneration. Do you

22 claim - and please give me a very precise answer - that the army of

23 Republika Srpska Krajina was part of the Yugoslav army, the army of

24 Yugoslavia, and that the General Staff of the JNA commanded the army of

25 Srpska Krajina?

Page 12522

1 A. Yes, that is what I'm saying.

2 Q. You know that that is a lie, don't you?

3 A. No. I consider that to be a greater truth than the truth of you

4 and me sitting here, Mr. Milosevic.

5 MR. GROOME: [Microphone not activated].

6 THE INTERPRETER: Microphone, please, Mr. Groome.

7 MR. GROOME: This characterisation of this witness's testimony as

8 a lie is improper comment and is not a question posed to this witness. He

9 asked the witness his opinion regarding a matter, and the witness replied.

10 JUDGE ROBINSON: I think he's entitled to put it to him that he's

11 telling a lie. It's for the witness to answer.

12 Continue, Mr. Milosevic.

13 MR. MILOSEVIC: [Interpretation]

14 Q. Do you know that the army of the Republic of Srpska Krajina had

15 its headquarters, its main staff?

16 A. Yes.

17 Q. Do you know that the Republic of Srpska Krajina had its supreme

18 defence council?

19 A. Yes, I know that too.

20 Q. So what connection did the supreme defence council of the army of

21 the Republic of Srpska Krajina have with the General Staff of the JNA or

22 the supreme defence council of Yugoslavia?

23 A. Through the chain of command, Mr. Milosevic.

24 Q. Mr. Lazarevic, never were you able to see this kind of chain of

25 command and identify it because it simply didn't exist. How are you able

Page 12523

1 to make that conclusion?

2 A. I have to repeat to this Tribunal every -- it was in contact with

3 the JNA and headquarters from Belgrade, the officers that came from

4 Belgrade on a daily basis practically, and the ones that left the Krajina

5 went to Belgrade and the new contingent coming from Belgrade was a

6 constant supply.

7 Q. You even said yesterday that officers were coming to replace each

8 other on a six-month basis.

9 A. Yes.

10 Q. Is it true that the officers who were members of the JNA remained

11 there and became part of the structure of the army of the Republic of

12 Srpska Krajina? They were there throughout the war, they remained there,

13 and nobody went to and fro, from Belgrade and the Krajina, or replaced

14 each other after six-month term of office, and the people you mentioned

15 didn't leave after six months, they were there all the time, because they

16 were people from the Krajina originally; is that right or not?

17 A. You're not correct there. You're partially right but not right in

18 all things because you know full well, just like I do, that the General

19 Staff of the JNA would send officers regularly to do a six-month term of

20 office by virtue of the place they were born in and then they would be

21 returned to their own commands regardless of where they were. You know

22 that and I know that.

23 Q. Mr. Lazarevic, what I know is something that is quite contrary to

24 what you know, and that is what I'm saying that I'm saying and asking you

25 the questions I'm asking you. Of course, we will have every opportunity

Page 12524

1 to clarify the matter fully in due course.

2 So is it not true that just a part of the officer corps of the

3 JNA, that is to say those who were from the region originally, after the

4 withdrawal of the JNA from Croatia remained on in the Krajina and became

5 active members of the army of the RSK?

6 A. The command component of the army of the RSK was made up by active

7 officers of the JNA.

8 [Technical difficulty]

9 Active officers. They continued wearing a uniform upon their

10 return to Belgrade in the month of August.

11 [Technical difficulty]

12 JUDGE ROBINSON: We are getting French. Can it be resolved?

13 JUDGE KWON: Yes. Go on, Mr. Milosevic. Let's try.

14 MR. MILOSEVIC: [Interpretation] Very well.

15 Q. You claim, on page 8, paragraph 6, that at the beginning of 1992,

16 Samarica was visited by Zimonja and said that the JNA said -- would

17 withdraw from Croatia to Bosnia and that Belgrade had approved for the

18 European Community Monitoring Mission, the ECMM, to enter into the area

19 from Sisak and Karlovac; is that right?

20 A. Yes, that's right.

21 Q. When you say "Belgrade," I assume you mean the presidency of the

22 SFRY.

23 A. Mr. Zimonja used the word "Belgrade" and I always assumed that he

24 meant the Main Staff, the General Staff, and not the political structures.

25 Q. Well, I assume you know that the civilian structures at that time,

Page 12525

1 the Presidency of the SFRY, as it was called, was in command of the army

2 and was the collective supreme commander.

3 A. I do not assume anything, Mr. Milosevic. I'm just saying with

4 great certainty what I know.

5 Q. Now, what you state, the withdrawal of the JNA and all rest of it,

6 all the other things you state, does that mean that the peace plan was

7 respected, both in the military and political sense, and that the SFRY and

8 the JNA demonstrated that there were no aggressive intentions vis-a-vis

9 Croatia, and that was all according to the Vance plan?

10 A. Mr. Milosevic, part of the JNA did withdraw. It is an

11 indisputable fact that that same army, the JNA, left its officers behind

12 to form the army of the RSK and that it left its heavy weaponry there for

13 that army to use; therefore, yes, the plan was partially fulfilled, Mr.

14 Milosevic, but not completely.

15 Q. All right. Tell me this, Mr. Lazarevic: As the JNA was composed

16 of - while Yugoslavia existed I'm talking about - of the citizens from all

17 the republics, when the crisis started and the Federal Republic of

18 Yugoslavia established, its citizens or, rather, the citizens of Serbia

19 and Montenegro returned to the territory of that same Yugoslavia.

20 Similarly, the citizens of Serb ethnicity in the Republika Srpska Krajina

21 stayed on on their territory, so also did the citizens of Croatian

22 nationality stay on and formed the command cadres of their armed forces,

23 so Muslim officers that had once been in the JNA remained in their own

24 locality and became commanders of the Muslim army. All right. Let's not

25 mention the Mujahedin now and anybody else from outside. I'm just talking

Page 12526

1 about the internal elements and factors. Does that mean that the JNA

2 formed --

3 JUDGE ROBINSON: Mr. Milosevic, you're speaking too --

4 THE INTERPRETER: Microphone, please.

5 JUDGE ROBINSON: Rule of thumb: Any time you exceed three or four

6 sentences, it's going to be difficult for the witness to answer.

7 Formulate a question.

8 MR. MILOSEVIC: [Interpretation]

9 Q. All right. Very well. Did the same thing happen with the

10 Croatian officers who remained officers in the armed forces of Croatia, or

11 the officers who remained in the armed forces of the Bosnian Croats or the

12 remaining officers who stayed on in Alija Izetbegovic's army, did the JNA

13 form all those armies, establish them all?

14 A. There is an essential, substantial difference once again, and Mr.

15 Milosevic, you're only partially right. It is true that the

16 redistribution of the JNA meant that the Croatian officers joined the

17 Croatian army, the Bosnian officers joined the Bosnian army. However, in

18 none of these cases did the JNA of its own free will leave its weaponry

19 and officers, for example, in Croatia, nor after the dismemberment were

20 there any contacts between those armies and the General Staff in Belgrade,

21 whereas there were daily contacts between the officers of the RSK army

22 with Belgrade. That is why I say you're partially right.

23 Q. You have absolutely no possibility of knowing about any type of

24 daily contact that was held between officers and the General Staff in

25 Belgrade. I assume that they must have had daily contact with the Supreme

Page 12527

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13 English transcripts.

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Page 12528

1 Command of the army of RSK and not with the General Staff in Belgrade.

2 And even if were such a vertical chain of command and line to be

3 organised, it had to go through the main headquarters of the ARSK because,

4 otherwise, it couldn't have happened and wouldn't have happened in any

5 other army.

6 A. Mr. Milosevic, it happened in this particular army.

7 THE INTERPRETER: Microphone, please, Judge Robinson.

8 JUDGE ROBINSON: Are you able to say how many JNA officers were

9 left behind to form the RSK?

10 THE WITNESS: Your Honour, I would place it at a hundred per cent

11 for the high-ranking officers.

12 JUDGE ROBINSON: All of the high-ranking --

13 THE WITNESS: Yes; all the generals and all the colonels.

14 JUDGE ROBINSON: Continue, Mr. Milosevic.

15 MR. MILOSEVIC: [Interpretation]

16 Q. All right. Now, were all these officers who stayed behind, who

17 remained, were they all from that region originally?

18 A. I assume that they were, yes.

19 Q. So they stayed on in their own territory, on their own land, in

20 their own towns and villages where they had come from, in the areas they

21 were born and lived their whole life, their fathers and grandfathers lived

22 in that locality; is that right?

23 A. Mr. Milosevic, it is illusory for you to try to claim that I met

24 all the officers on the territory of Srpska Krajina. I just spoke about

25 the ones that I had known. Whether they were all born and bred there, I

Page 12529

1 really can't say. The ones that I knew, yes, they were. The ones that I

2 knew were born there, they left the region, might not have been there for

3 40 or 50 years and then came back on assignment when the conflict broke

4 out.

5 Q. Do you think they were given an assignment to go back or did they

6 feel the need to go back, just like you said that you felt it to be your

7 patriotic duty to defend and protect this area, just like the officers who

8 had gone through an officer's training course, felt that same duty just

9 the kind of duty that you felt yourself, or were they ordered by somebody

10 else?

11 A. Unfortunately, Mr. Milosevic, not everybody was a patriot. Some

12 people came for very selfish reasons, for example.

13 Q. What did you say?

14 A. I said for selfish reasons.

15 Q. Let's not go into those selfish reasons now. I haven't got time

16 for that. But tell me this: Zimonja, on that occasion when he said that

17 the JNA was withdrawing from Croatia, et cetera, et cetera, he said to you

18 that you would be following Mile Mrksic, accompanying him, who, as you

19 say, was the commander of the 8th Operative Group at the time, when you

20 went to meetings with the observers; right? So how many meetings did you

21 attend of that kind with Mr. Mrksic?

22 A. Probably about 20, at least.

23 Q. And in what capacity did you attend those meetings?

24 A. As an interpreter to General Mrksic, because the liaison officer

25 at that time was Colonel Momcilo Krstic. I was his assistant, his deputy.

Page 12530

1 Q. Right. Precisely so. So at those meetings you were not

2 accompanying Mile Mrksic actually but you were accompanying the liaison

3 officer who, from time to time, would invite you to attend meetings of

4 that kind in your capacity of interpreter; is that right?

5 A. Mr. -- or rather, General Krstic didn't speak a single language

6 except Serbian, and neither did General Mrksic. So when the liaison

7 officer attended meetings that were attended by General Mrksic, I would

8 also be there as an assistant to help out as an interpreter to the general

9 and not to Mr. Krstic.

10 Q. In your capacity as interpreter.

11 A. Yes.

12 Q. Mr. Lazarevic, in a large portion of your statement, on page 9,

13 10, 11 -- you can find it there. Anyway, in those pages you describe how

14 you allegedly fooled the representatives of the UN and the observers, how

15 you tried to recruit them to -- tried to do business with them, get them

16 drunk, you supplied women to them, extracted information from them, and so

17 on. So tell me, please: Since everything that we heard yesterday is

18 completely untrue, how can we at all verify -- how is it possible at all

19 to verify any one of your allegations that can be found throughout these

20 pages of your statement, except for the story of yours -- once you sift

21 through the story, the only fact that remains is that you were an

22 interpreter, and you have a very eloquently told story. So you are coming

23 up with big items here, that you used to get the UN representatives drunk,

24 that you used to do business with them, supply them with women, extract

25 information from them. So how is it possible to come up with some

Page 12531

1 allegations which are quite large?

2 THE WITNESS: Your Honour, would it be possible to go into the

3 closed session where I can actually name the names of the people that I

4 worked with on the part of the UN?

5 JUDGE ROBINSON: Yes. Closed session.

6 THE ACCUSED: [Interpretation] Mr. Robinson, he is not testifying

7 in a closed session. I don't see the reason for a closed session.

8 JUDGE ROBINSON: I have made that judgement.

9 Closed session.

10 THE REGISTRAR: Your Honours, we're in private session.

11 [Private session]

12 [redacted]

13 [redacted]

14 [redacted]

15 [redacted]

16 [redacted]

17 [redacted]

18 [redacted]

19 [redacted]

20 [redacted]

21 [redacted]

22 [redacted]

23 [redacted]

24 [redacted]

25 [redacted]

Page 12532

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Page 12533

1 [redacted]

2 [redacted]

3 [Open session]

4 THE REGISTRAR: Your Honours, we're back in open session.

5 MR. MILOSEVIC: [Interpretation]

6 Q. In addition to you saying how you recruited them, got them drunk,

7 bribed them, did business with them, supplied them with women and so on,

8 in another part you say that some representatives of the UN and monitoring

9 mission after a while started cooperating not out of those low-based

10 motives but because they became convinced of the valid cause of the Serb

11 struggle.

12 A. Yes. That was done out of their convictions.

13 Q. Since you said how you deceived them, did you in fact deceive them

14 regarding the valid cause of the Serb struggle?

15 A. Mr. Milosevic, I never lectured officers of the UN in order to

16 make them believe this or that. Those who made conclusions based on their

17 own convictions did so on their own free will, without any influence of

18 mine. You are suggesting that I in fact had a much greater power than I

19 did.

20 Q. No. I'm claiming something completely contrary to that, because

21 based on what you're saying, it seems that you know everything about the

22 war in Croatia, about the policy of Yugoslavia, Serbia, my own role, the

23 role of the Main Staff, and everything else, when in fact you know nothing

24 about this because you were an interpreter in the command where you worked

25 as a liaison officer. You in fact fabricated all this. So, Mr.

Page 12534

1 Lazarevic, I'm claiming something completely opposite of what you are

2 saying. I'm not saying that you know everything, no.

3 JUDGE ROBINSON: Let the witness comment on that. It has been

4 said that this is an entire fabrication.

5 THE WITNESS: I will repeat again, Your Honour, for the benefit of

6 the Court here: Everything I have stated in my statements is absolute

7 truth.

8 MR. MILOSEVIC: [Interpretation]

9 Q. Mr. Lazarevic, on page 9, last paragraph, you say that Mrksic,

10 while he was still in the Krajina, told you about his impressions from the

11 Vukovar battlefield, and he confided in you regarding all of that.

12 A. No. I never claimed that, Mr. Milosevic. I simply said that I

13 was present when he spoke about that.

14 Q. And what did he in fact say there about doing there?

15 A. His conviction at the time was that he had accomplished a very

16 important military victory.

17 Q. Since you say that he boasted about this - this is the term that

18 you used - he boasted about something that was dishonourable; he boasted

19 about killing a civilian - is that what he did? - about ordering a crime

20 to be carried out or something similar?

21 A. No. He boasted about having accomplished what he wanted in his

22 attack on the hospital.

23 Q. Were you perhaps tempted to ask him how many Croatian extremists,

24 Ustashas, members of the ZNG, and other organisations, withdrew after the

25 surrender of Vukovar and dressed into medical staff clothing in order to

Page 12535

1 portray themselves as the medical staff and the wounded? Did you then ask

2 him how many Serbs these Ustasha groups killed at the time in Vukovar?

3 Did you have information regarding that?

4 A. Mr. Milosevic, I was not in a position to put questions to General

5 Mrksic. I was there, the dinner was going on, members of the command were

6 there, officers talked amongst themselves. I was sitting nearby and I was

7 able to hear, however, I did not actually participate in the conversation

8 and I don't know everything that went on in Vukovar.

9 Q. You don't know what went on in Vukovar, but this is what you're

10 giving evidence about. Do you know that it is exactly Mile Mrksic -- were

11 you able to eavesdrop about this while they were talking at the table?

12 A. Mr. Milosevic, I wasn't eavesdropping, I was sitting there in an

13 official capacity while the dinner was going on. I was not eavesdropping.

14 I was sitting there and I was able to hear something that was said quite

15 loudly. I wasn't there, listening to something that I wasn't supposed to

16 hear. Mr. Mrksic loud and clearly said about his impressions from

17 Vukovar, so I wasn't eavesdropping.

18 Q. Well, the waiter who waited there was also there in an official

19 capacity, and let's say he was serving soup, and since he has ears, he was

20 able to hear.

21 A. The waiter was a military personnel person, just like I was, and

22 was present there in that capacity.

23 Q. Well, do you know that Mile Mrksic, regarding not only Serbs but

24 Croats who remained to live in the Krajina area, organised medical health

25 care services for them, that in fact he took care of the health of

Page 12536

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Page 12537

1 population living there? Are you aware of that?

2 A. No, I'm not.

3 Q. However, you said in your statement, and also in your evidence,

4 that Serbs, the TO of Krajina, the police of Krajina, all of those people

5 who were armed and those who were not armed, worked actively on expelling

6 all Croats from that area. That's what you say.

7 A. Yes. That was the impression I got upon arriving in Krajina, and

8 I put that in my statement. I said that when I came to Krajina there was

9 a very small number of Croats living there.

10 Q. Let me just take a look at my notes. Just a minute, please.

11 Therefore, in view of the fact that everyone was supposed to be

12 expelled from there, tell me, please: Do you know of a village called

13 Bijeljina, which is some ten kilometres from Topusko?

14 A. No, I don't remember that name.

15 Q. Do you know that 37 Croatian families remained to live in that

16 village, that they spent the entire war on their property, and only those

17 who set on fire Serb houses fled from there?

18 A. I know about only one village near Topusko. I think that I

19 mentioned this in my statement that there were Croats in Topusko who put

20 white sheets on their windows, and they remained living in Topusko. I

21 don't know if it's the same village that you're talking about.

22 Q. It might not have been the same village. There were many villages

23 like that. Do you know in fact that Croats lived in Knin, in Knin itself,

24 and according to a protected witness, a very important one whose name I

25 don't want to mention now, this witness personally saw them and believed

Page 12538

1 that they were given equal treatment in every respect, even though this

2 witness testified against me, just like you. So there were Croats in Knin

3 itself. All right. You don't know about this village, but do you know

4 how many Croatian families remain in the village of Gredjani?

5 A. Yes. I know that village because the members of the ECMM visited

6 this area very frequently. I believe that this is a village on the Kupa

7 River.

8 Q. Do you know the Muza family, Slavko and Kata, from Topusko, since

9 you visited Topusko? And I'm asking you now about Topusko.

10 A. No. I can't remember them now.

11 Q. Do you know that the soldiers of the RSK, who tried to provoke

12 them because their son, Ivica Muza, also known as Svabo, that was his

13 nickname, set fire to Serb houses, so therefore the Serb soldiers provoked

14 the parents of this arsonist, and pursuant to the order of Ajdinovic, whom

15 you accuse of commanding a unit in charge of dirty jobs, that these

16 soldiers were arrested because they harassed this Croatian family? Do you

17 know about this event?

18 A. No.

19 Q. Are you saying that Ajdinovic commanded this unit that did dirty

20 jobs?

21 A. Yes, that's what I'm saying.

22 Q. Do you know of Croatian villages called Lukinic, Buncici?

23 A. Mr. Milosevic, you are now mentioning villages that probably exist

24 in that area. I'm not a person from that area. I did spend a part of my

25 life in that area; however, I didn't study geography. I don't know about

Page 12539

1 all of these villages. I didn't record these villages and their

2 population. I don't know what the ethnic composition of these villages

3 is. This was not part of my job.

4 Q. All right. But part of your job is quite clear to us, based on

5 what you're saying. I am now giving you names of a number of villages

6 from the area where you claim to know everything that went on, and it

7 seems that you know nothing of what went on except for things that

8 corroborate this false accusation.

9 A. Mr. Milosevic, you are saying now that I'm lying and you are

10 saying the truth. I can turn it around and say that it's vice versa. I'm

11 quite sincerely telling you that I don't know. I've never heard of these

12 villages that you are mentioning.

13 Q. So you are claiming that what I say to you about Lukinic, Buncici,

14 residents of those villages who lived throughout the war there peacefully,

15 I also mentioned Bjeljevina, Gredjani, and these villages, and you're

16 claiming that that's a lie?

17 A. Mr. Milosevic, I'm claiming that there were no Croats living

18 peacefully at that time in RSK.

19 Q. Mr. Lazarevic, there was nobody living peacefully in Krajina

20 during the war. You're not going to deny that.

21 A. I'm not going to deny that. It is true that nobody lived

22 peacefully, especially not Croats during that time.

23 Q. And as regards the truth, the only advantage I have is that I'm

24 telling the truth.

25 A. Mr. Milosevic, we will leave it to the Court to decided who is

Page 12540

1 telling the truth.

2 Q. What I am saying is something that a lot of people know a lot

3 about.

4 A. I can say the same about what I'm saying.

5 Q. Mr. Lazarevic, when I say a lot of people, I mean millions.

6 On page 12, paragraph 5, you say that after demilitarisation, and

7 nothing changed, and that the KOS and DB remained active in RSK. Is that

8 right?

9 A. What I'm saying is that the army, overnight --

10 THE INTERPRETER: Could the witness please repeat the answer.

11 MR. MILOSEVIC: [Interpretation]

12 Q. I took you to say that KOS was part of the JNA army, and the DB

13 from Serbia, that they remained there and continued working in RSK.

14 A. Yes.

15 Q. So that's what you're claiming?

16 A. Yes.

17 Q. Do you know that the army of RSK had its own intelligence and

18 counter-intelligence service, even before the war?

19 A. Yes, that's right. Every republic had that.

20 Q. Are you aware that at the level of RSK there was their own state

21 security service?

22 A. Yes, but it was directly subordinated to the state security of

23 Yugoslavia.

24 Q. How can you claim that?

25 A. They submitted their reports to them, they asked for advice.

Page 12541

1 Q. Did you see any report of that nature?

2 A. I did not see any reports, but I had an opportunity to talk to the

3 people who worked in the state security of RSK and had direct connection

4 with Mr. Stanisic, or Stamatovic, and so on.

5 Q. How do you know that? Did you ever attend a meeting? Have you

6 ever seen Jovica Stanisic in your life?

7 A. Yes, I did in Knin.

8 Q. And who did he meet with there? Did you see?

9 A. Mr. Babic, Mr. Martic; a number of people. I attended dinners,

10 not official conversation --

11 Q. So what if he came for a visit and had dinner? What are you

12 testifying about that?

13 A. You only asked whether he was there or not.

14 Q. What is your testimony when I ask did you ever attend a meeting

15 between them? Because you're saying something about reporting as the

16 grounds for your testimony.

17 A. I'm saying that I was in the presence of Mr. Toso Pajic, in his

18 office, many times when he spoke to Jovica Stanisic.

19 Q. Was he giving him a report?

20 A. Yes.

21 Q. So you attended a telephone conversation between Toso Pajic and

22 Stanisic?

23 A. I wasn't the only one.

24 Q. But Pajic, Surla, and the others were working for the DB in the

25 RSK, in the Yugoslav army?

Page 12542

1 A. Yes.

2 Q. But from that area, they are locals of that area?

3 A. Correct, but they were still officers of the JNA.

4 Q. The JNA had ceased to exist when the Federal Republic of

5 Yugoslavia came into existence and when the army of Yugoslavia was

6 established, consisting of citizens of Montenegro and Serbia. I suppose

7 that you are well informed about that as well, since you know a lot about

8 things that you couldn't really know about.

9 What is the presence of the Yugoslav army in the RSK you are

10 talking about?

11 A. I'm talking about the presence of units in the MUP of Serbia.

12 What secret units are you talking about?

13 Q. Do you mean that the secret services of the MUP of Serbian Krajina

14 cooperated?

15 A. Yes.

16 Q. What is odd about that cooperation? So what if they cooperated?

17 You should know, since you work in that area, that secret services of the

18 USA and Russia also have cooperation. There is cooperation between secret

19 services of various states, even between Yugoslavia and the United States.

20 So what if there is cooperation between such services?

21 A. It all depends to what level this cooperation reaches.

22 Q. So it's all about level; right? And I suppose you know the level

23 of that cooperation as well.

24 A. I suppose so.

25 Q. And you know the substance of that cooperation?

Page 12543

1 A. I'm saying all the things I know about that. I know that Mr. Toso

2 Pajic talked to Stanisic. I know that upon return to Belgrade, Toso Pajic

3 continued to work in the DB.

4 Q. Mr. Lazarevic, after these events that you described towards the

5 end of examination-in-chief, do you know that in Serbia there were a

6 million refugees? Out of those million refugees, do you know how many

7 thousands upon thousands found employment? Those who were policemen found

8 work in the police force, doctors found work in health centres, teachers

9 found employment in schools, depending on vacancies available. So what if

10 a policeman who was at the same time a refugee after the events you

11 described, found employment in the only line of work he knows anything

12 about?

13 A. You seem to forget, Mr. Milosevic, that at that time, people who

14 came as refugees to the territory of Yugoslavia had no right to be issued

15 with an ID, had no right to employment because they were considered as

16 aliens, they could not enrol their children in schools because they had no

17 official status in our country. So please don't tell me what rights they

18 did and didn't have. I know that they were denied all the rights normally

19 enjoyed by Yugoslav citizens.

20 Q. Mr. Lazarevic, do you know that many people who were driven out -

21 and that was the general feeling in Serbia, beginning with the early

22 1990s - were in many ways privileged, as far as employment is concerned,

23 compared to Yugoslav citizens? I know that Sadako Ogata told me that the

24 status of refugees is very good in Serbia. Now you're telling me that

25 these people were disenfranchised in Serbia, based on a single incident

Page 12544

1 you mentioned here, and even that, I would say, is doubtful.

2 A. Mr. Milosevic, I'm speaking about the years I spent in Belgrade,

3 from 1995, 1997, 1998, and 1999. The people I spoke to at the office of

4 the exiled government of Serbian Krajina in Belgrade, I know from speaking

5 to them that they had no rights at all. They were unable to register

6 their vehicles they drove to Serbia. For years they were unable to be

7 issued with IDs, because an ID would mean that they got Yugoslav

8 citizenship. They couldn't do that. You cannot deny the fact that in

9 1995 those people were arrested and taken back to the war zone and

10 battlefields outside of Serbia. You know, and you should tell the Court,

11 that some of these people sued your government because you made those

12 refugees go back to the front line.

13 Q. Mr. Lazarevic, that is not true at all. There were all kinds of

14 excesses there. There probably were. Whenever hundreds, thousands of

15 people are involved, injustice and excess is a common occurrence. But it

16 was not official policy. You can't claim that.

17 A. Unfortunately, it was.

18 Q. It could only have happened in individual cases. But please tell

19 me this: Since you say that services were cooperating between them, did

20 you attend a single meeting, for instance, between Surla and Vasiljevic?

21 A. No.

22 Q. You didn't attend a meeting between Stanisic and Pajic either?

23 A. No.

24 Q. You didn't attend a single meeting between those people who were

25 supposed to be cooperating?

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Page 12546

1 A. I attended some meetings, but not meetings between any of the

2 people you just mentioned.

3 Q. Okay. Stanisic and Pajic you were able to recognise; right?

4 A. Pajic I saw every day.

5 Q. But you didn't attend a single of their meetings?

6 A. I wasn't supposed to. They worked for the police.

7 Q. How do you know these meetings ever happened?

8 A. They probably happened during visits by Mr. Stanisic.

9 Q. Let me get this correctly. When you say "probably," does that

10 mean it is an assumption of yours? Are you basing your claims on any sort

11 of fact?

12 A. It is a fact that Mr. Bozovic and Mr. Simatovic had regular

13 meetings at the 21st Corps, and I doubt very much that they held those

14 meetings of their own free will, by their own decision, without

15 instructions and decisions from their superiors.

16 Q. You are talking about a time when the Republic of Serbian Krajina

17 cooperated with the autonomous province of Western Bosnia, Fikret Abdic,

18 and Serbia; is that what you're talking about?

19 A. I'm talking about an intense presence of units of the MUP of

20 Serbia.

21 Q. Do you know that another protected witness and participant said

22 that those were exclusively volunteers and mercenaries who helped out the

23 army of the autonomous province of Western Bosnia, as instructors, and

24 this area was in peaceful relations with both Krajina and Serbia? Do you

25 know about that?

Page 12547

1 A. I know something different, Mr. Milosevic.

2 Q. All right. You know something different. Yesterday an exhibit

3 was produced here, namely, an excerpt from a videotape of a military

4 parade in Slunj. Is it true that this military parade was broadcast on

5 television?

6 A. Yes.

7 Q. Is it true that it was no secret?

8 A. Correct.

9 Q. Is it correct that when such festivities take place - St. Vitus

10 Day is a great holiday - guests are invited?

11 A. Correct.

12 Q. So what is odd about it, odd enough to produce it as an exhibit,

13 to see that there are guests from Serbia, police officers from Serbia,

14 guests from the autonomous province of Western Bosnia, also officers from

15 Abdic's army, Muslims, in addition to officers from Republika Srpska --

16 JUDGE ROBINSON: It's not for the witness to comment on the

17 evidence in that way. He can't say whether it was odd to have the exhibit

18 produced. It was produced by the Prosecution. That's not a proper

19 question for him.

20 THE ACCUSED: [Interpretation] All right. It is an appropriate

21 question, Mr. Robinson, whether it was a public event. It was a public

22 event, and the witness confirmed it. Is St. Vitus Day a great holiday?

23 Yes. Do you invite guests for holidays? Yes, you do. Do you invite

24 guests from Serbian autonomous province of Western Bosnia, Republika

25 Srpska? Yes, you do. They were there. And whether it is odd or not, I

Page 12548

1 don't even have to ask, because it was an ordinary event, and I don't see

2 its relevance to the purpose for which it was used here.

3 MR. MILOSEVIC: And what I said, as you well know, is correct,

4 Mr. Lazarevic.

5 Q. On page 13, paragraph 2, you claim that I had my own envoys in the

6 Republic of Serbian Krajina who made sure that all of my wishes are

7 fulfilled. Tell me, please, who were these envoys of mine in Republic of

8 Serbian Krajina? Name them, please.

9 A. People who came frequently from Belgrade, people who were present

10 on the ground, anyone who was in the Republic of Serbian Krajina, Mr.

11 Milosevic, was accountable and responsible to you.

12 Q. Is that what you think?

13 A. Oh, yes.

14 Q. Do you think that people who came to the Republic of Serbian

15 Krajina of their own accord, in order to help, to contribute in some way,

16 to assist in combat, in industries, and anywhere else, do you think they

17 were all responsible to a centre in Belgrade?

18 A. Of course.

19 Q. What is bad about that? How could those people have survived

20 without assistance from Serbia? What is bad about Serbia helping them?

21 A. I don't understand what you're driving at.

22 Q. What would they eat?

23 A. Better to ask what they would shoot with.

24 Q. Since you ask that question and you deal with military issues, as

25 I see, do you know that even in the doctrine of the former SFRY, and in

Page 12549

1 the actual disposition, an enormous quantity of weaponry was deployed in

2 Croatia and the BH, which was a central republic, and after 1948, military

3 industries were withdrawn from other areas and concentrated in the

4 Bosnia-Herzegovina? Their military stocks were much higher than those in

5 Serbia.

6 A. In small depots of the Territorial Defence, yes. I don't know

7 about any large depots.

8 Q. Do you know for how long this Croatian general drove in a jeep

9 through a warehouse through the depot in Knin, after the fall of Knin? Do

10 you have any idea how large the depot was?

11 A. No, I don't.

12 Q. That's exactly what I'm putting to you. You don't know. Tell me,

13 on the basis of what do you claim, as you explained here yesterday, that

14 you were there somewhere in the vicinity of Knin when the so-called log

15 revolution was carried out, that you saw 80 per cent of people who were

16 not locals, and you described, very graphically here, what it all looked

17 like. You talked about that yesterday, didn't you?

18 A. What is the question?

19 Q. Did you say that yesterday, that you personally saw that?

20 A. I don't know if I used the words you used, graphic or not graphic.

21 All I know is I said that I went there personally, out of curiosity more

22 than anything else.

23 Q. You were explaining that you saw that with your own eyes; is that

24 correct?

25 A. Yes, correct.

Page 12550

1 Q. I will tell you now what it says on page 13 of your statement

2 since you are not telling the truth again. Look at page 13, please.

3 First of all, you were never there at all, and you spent a lot of time

4 yesterday explaining that.

5 THE ACCUSED: [Interpretation] Page 13 of 38, paragraph 2, starting

6 with the third sentence. First comes the part I already quoted:

7 "Milosevic had his own envoys in Knin who made sure that all his wishes

8 were fulfilled. His representatives were almost always SDB agents. They

9 had been in the Krajina from the beginning and the supposedly spontaneous

10 revolt against Croatian authorities in 1990 was orchestrated from

11 Belgrade."

12 Then you go on to say: "Zimonja told me at one point that when,

13 in August 1990, log barricades were put up around Knin, they were largely

14 manned by members of paramilitary units and from Serbia. Many of the men

15 were actually from Belgrade, and according to Zimonja, they were paid

16 1.000 Deutschmark to block the roads.

17 "This was the first step towards establishing the Serb autonomous

18 region around Knin, and although it was portrayed in the Belgrade press as

19 a spontaneous action of the local Serbs to defend themselves, in reality

20 it was planned and initiated by Belgrade. The SDB was far ahead of the

21 local population in making these things happen. Their agents created the

22 incidents and then the press used them to stir up the civilian population

23 and to create a climate of fear that was so necessary in order to make the

24 war happen."

25 From this we see that what you are claiming here, you are claiming

Page 12551

1 that Zimonja said, not that you saw it yourself. That's one thing. And

2 second, let me ask you, Mr. Lazarevic: What paramilitary formations

3 existed in 1990 in Serbia anyway? At that time, in Serbia, there was no

4 one who had the faintest idea that the conflict would happen at all. What

5 kind of paramilitary formations are you talking about in 1990? Do you

6 know of a single paramilitary formation in Serbia that was in existence in

7 1990.

8 JUDGE ROBINSON: Before the witness answers, after the witness

9 answers we'll have to take the break.

10 Go ahead, Mr. Lazarevic.

11 A. The establishment of paramilitary formations in Serbia, when it

12 began, who was in charge, and the rest, I don't know. I wasn't in Serbia

13 then. It is a fact that very early on in the area of Knin, White Eagles

14 appeared, Seselj's volunteers, Dragan's volunteers. There were all sorts

15 of jokes about that: If you ask a Serbian guard when to open fire, he

16 says, When I see more than two men in the same uniform. If they are in

17 different uniforms, everything is okay.

18 MR. MILOSEVIC: [Interpretation]

19 Q. Mr. Lazarevic, I asked you a serious question.

20 A. I gave you a serious answer. I wasn't in Serbia at the time to

21 know how and when it was established.

22 Q. You are now saying in public for everyone to hear that this log

23 revolution in August 1990 was organised by paramilitary formations from

24 Serbia.

25 A. I said it was organised by the state security service. I didn't

Page 12552

1 talk about paramilitary units organising it. I only said that the

2 barricades were probably manned by paramilitary members from Serbia.

3 JUDGE ROBINSON: I remind the witness not to discuss his evidence

4 with anybody during the break. We break for 20 minutes.

5 --- Recess taken at 12.19 p.m.

6 --- On resuming at 12.42 p.m.

7 JUDGE ROBINSON: Before you continue, Mr. Milosevic and

8 Mr. Lazarevic, I have a special request from the interpreters to ask that

9 you observe a pause between question and answer. They have been having

10 immense difficulty in keeping up with the speed at which you're both

11 speaking, since you speak the same language. So in the interests of the

12 health of the interpreters, and indeed their own human rights, I'm going

13 to ask that you make a very special effort to observe a pause between

14 question and answer.

15 THE WITNESS: Your Honour, I promise I will be very careful from

16 now on.

17 JUDGE ROBINSON: Yes, Mr. Milosevic. Continue.

18 MR. MILOSEVIC: [Interpretation]

19 Q. So to round off the question we were discussing and to conclude:

20 You say and claim that all the events in 1990, in 1989 as well, and all

21 the nationalistic hysteria in Croatia and the persecution of the Serbs,

22 the pressures brought to bear on them, the fact that they were thrown out

23 of the constitution, that the Serbs weren't bothered by that at all but

24 the SDB people came in and organised the log revolution. Is that

25 what you're saying in fact?

Page 12553

1 A. No, that is not what I'm claiming. I never mentioned what you

2 said in the first part of your question. But in the second part of the

3 question, yes, it was organised by the DB; or to put it in simpler terms,

4 it was organised in Belgrade.

5 Q. I see. Now, how do you explain the fact that yesterday here in

6 this courtroom you discussed at length what you had seen, you described

7 what you had seen, and then you say you had heard it from Zimonja, you

8 heard that some people in the SDB were there?

9 A. In my original statement, I said that I had seen it myself.

10 Q. So this isn't your real statement, then. This is not the original

11 statement, the one that I received.

12 A. Well, I don't know what you have received. I know what I said,

13 what I stated.

14 Q. All right. Let's move on as we've spent quite enough time on that

15 question.

16 On page 13, paragraphs 3, 4, and 5, you describe how I kept the

17 JNA under my control through the mediation of KOS. Is that right, Mr.

18 Lazarevic?

19 A. Mr. Milosevic, which paragraph are you referring to?

20 Q. I'll tell you in just a minute -- right away. Page 13, paragraphs

21 3, 4, and 5 --

22 JUDGE ROBINSON: Mr. Milosevic, just read one excerpt from it so

23 that I can know exactly where you are speaking.

24 THE ACCUSED: [Interpretation] Well, all right, Mr. Robinson. I

25 will read it out. Paragraph 3, page --

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Page 12555

1 JUDGE ROBINSON: Just read one sentence so I can -- I'm having

2 difficulty finding it.

3 THE ACCUSED: [Interpretation] "Milosevic's relationship with the

4 JNA was different than with the SDB. In some ways it was obvious that

5 there was some strain there. But the army nevertheless cooperated with

6 him and also carried out his wishes."

7 JUDGE ROBINSON: Thank you. Thank you.

8 MR. MILOSEVIC: [Interpretation]

9 Q. And the paragraph ends -- I just want to read this out loud:

10 "Those who did not agree with him were excommunicated, and they were

11 replaced by ambitious younger officers, such as Mile Novakovic, Mile

12 Mrksic, Ratko Mladic, who saw linking themselves to Milosevic as a way of

13 getting ahead quickly," and so on and so forth.

14 Mr. Lazarevic, do you know what post I held at that time, the time

15 that you're describing?

16 A. If I remember correctly, you were President of Serbia at that

17 time.

18 Q. Yes, that's right. And do you know that the presidents of the

19 republics in the former Yugoslavia had absolutely no competence in the

20 army?

21 A. Mr. Milosevic, you were at the head of the army at that time and

22 you know that full well.

23 Q. That's what you claim, and you're claiming that in order to, how

24 shall I put it, support this false indictment. But Mr. Lazarevic, do you

25 know that I never even knew any of these people at that time? I knew the

Page 12556

1 military chief, General Veljko Kadijevic, I knew the head of the General

2 Staff, Blagoje Adzic, and that was all. Those were all the people that I

3 knew in the army at the time, when we're talking about individuals. Of

4 course, somebody from the various receptions and celebrations that were

5 held I might have known, but where do you get the idea from? Did you read

6 it in the indictment and then interpret it in your own way or do you have

7 any actual knowledge about that?

8 A. I did not read the indictment against you, nor is it my intention

9 to read it. I am here today to present the facts that I know about. And

10 the fact remains, Mr. Milosevic, that even I - let me recognise this in

11 front of the Tribunal and say it loud and clear - that I was delighted

12 with you back in the days of 1988 and 1990. I looked up to you. But

13 unfortunately, things changed since then.

14 JUDGE ROBINSON: [Previous translation continues]... answer the

15 specific question put by Mr. Milosevic, which was at that time --

16 THE WITNESS: I apologise, Your Honour. I don't even know what

17 the question is any more.

18 JUDGE ROBINSON: The question is that Mr. Milosevic is saying that

19 at that time he did not know any of those people.

20 THE WITNESS: That's what he claims. I believe he did.

21 JUDGE ROBINSON: You believe he did.

22 THE WITNESS: Yes, sir.

23 JUDGE ROBINSON: Thank you.

24 MR. MILOSEVIC: [Interpretation]

25 Q. All right. Of the ones that you mention here, I really didn't

Page 12557

1 know any of them, the ones you stipulate. And you go on to say the

2 following: That I gained the support of KOS early on. This made it

3 easier for me to control the army, for two reasons: "The first was that

4 KOS was responsible for making recommendations on postings and promotions

5 of officers. It was impossible for an officer to advance if KOS opposed

6 him. In this way, Milosevic," you state, "could control assignments and

7 command positions by making his desires known to KOS."

8 Tell me this, now: Who was the chief of KOS at that time, so that

9 I can know who it is that I informed of my desires?

10 A. I really can't remember.

11 Q. Well, I can't remember either.

12 A. Well, then we're in the same position, Mr. Milosevic, aren't we?

13 Q. We're not in the same position, Mr. Lazarevic, because you claim

14 that you know something and then you just seem not to remember. You even

15 claim that I exercised my control because the families of the military

16 officers lived in Serbia. Imagine that, if you will. What you want to

17 say is, I suppose, that I issued threats to the families of the military

18 and held the JNA under control in that way, by blackmailing them.

19 A. What I said was that the officers that appeared in Krajina did

20 have their families in Serbia. They did not have their families with them

21 in Srpska Krajina. So what?

22 Q. So what if the families weren't with them? What has that got to

23 do with my alleged control of the officers? Tell me of a single military

24 man, because his family was in Serbia, did something that I wished them to

25 do. Give me a name, one name, that you know of me telling him to do

Page 12558

1 something and then threatening him with his family being in Serbia, et

2 cetera, et cetera.

3 A. I never said that.

4 Q. You never said that?

5 A. No, Mr. Milosevic, I didn't. What I did state was that you had a

6 regular influence on the army, an extraordinary influence on the army.

7 Q. I can't find the families that we mentioned, unfortunately. But

8 as I have some time tomorrow, I have an hour and 50 minutes, as far as I

9 understand it, or one and a half hours, we'll see how the balance stands,

10 what Mr. Robinson is going to tell us about my time, the time I have left,

11 not to waste time now.

12 But to go back to the question that I have already quoted several

13 examples of -- I'm not going to give you any more examples, but tell me

14 this: On page 18, paragraph 6, you claim that in the RSK there was a

15 constant policy of expelling the Croats, following orders from Belgrade.

16 That's what you say, words to that effect.

17 A. Yes.

18 Q. And do you believe that? Did they really have this policy of

19 expelling the Croats?

20 A. Events on the ground prove that that was so, yes.

21 Q. So tell me something about those orders. Who issued the orders to

22 expel the Croats from the Republic of Serbian Krajina?

23 A. You, Mr. Milosevic.

24 Q. Oh, I see. Me. Well, give me an inkling of how you came to learn

25 of those orders of mine that never existed. How did you come by that

Page 12559

1 idea? Did anybody tell you that I had issued orders to expel the Croats

2 from the RSK at all?

3 A. Mr. Milosevic, you are the creator of the policy and politics in

4 Serbian Krajina. You pulled the strings of the events that took place

5 there.

6 Q. Mr. Lazarevic, apart from the fact that the opposite side is

7 claiming that, do you have any arguments to bear that out? Give me an

8 argument to bear it out. Let me ask you in quite concrete terms: How

9 come, if that was indeed my policy, throughout the ten years of the

10 Yugoslav crisis it was only Serbia that retained its national structure,

11 and during the war in Croatia it was not the Croats that were expelled,

12 during the war in Bosnia the Muslims were not expelled; therefore, how

13 come that during that ten-year period, if there was a policy of ethnic

14 cleansing, the kind that these people here have fabricated and are

15 accusing me of, in certain parts outside Serbia while I was the president

16 of Serbia, in Serbia none of that happened? How do you explain that?

17 A. Mr. Milosevic, I have not come here today to hold political

18 analyses of the events. What I know as being facts is that you stood

19 behind everything. You were at the back of it all. Now, whether you wish

20 to accept that or not, that's not my problem, and I state that once again.

21 Q. All right. But I'm asking you quite specifically. You say that

22 the orders came from Belgrade. When I asked you what orders from

23 Belgrade, you said my orders. So go on, then. Give me some basic proof

24 of any kind of order of that kind existing, to the effect that the Croats

25 should be expelled from the territory of the Republic of Srpska Krajina.

Page 12560

1 And I have quoted several examples of villages in your own particular

2 region, in which you claim you knew everything that went on, where the

3 Croats lived quite peacefully throughout that time. So how can you claim

4 and explain that now? I am talking about material facts; you are talking

5 about some kind of verbal assertions made.

6 A. Which material facts do you possess, Mr. Milosevic? You weren't

7 there. I was. The fact is that while I was there, and let me repeat this

8 again, you orchestrated the policy over there, in talking to high-ranking

9 officials with the offices of the state security service, in my talks with

10 people who had come from the territory of Serbia, briefings in Belgrade

11 before we went to the international meetings and exchanges, it was always

12 Mr. Slobodan Milosevic who was the key factor.

13 Q. We'll come to that. We'll come to those briefings, Mr. Lazarevic,

14 and we'll clear that matter up as well. There's no problem along those

15 lines. But you haven't answered my question yet. Did you yourself talk

16 to anyone? You have just enumerated some high-ranking JNA officers, high

17 representatives of the state security service, et cetera. Did any of them

18 ever tell you that they had talked to me personally and received any

19 similar orders, any orders of that kind? Did anyone actually ever tell

20 you that?

21 A. Directly, no.

22 Q. They didn't tell you.

23 A. Not directly.

24 Q. How did they tell you? Indirectly?

25 A. They would say Belgrade wants that or Belgrade wishes that.

Page 12561

1 Q. You mean that Belgrade wishes to expel the Croats from their

2 homes?

3 A. "Belgrade" was synonymous with you, Mr. Milosevic. "Belgrade"

4 meant you.

5 Q. Oh, I see. That's rather a large synonym and lots of them to

6 replace me. But all right. Now, how were these orders issued that

7 allegedly Belgrade issued and you listened to this in the talks that you

8 had? How did you learn of them? How were they announced? How were these

9 orders issued, announced, and put into practice? Give me an example of

10 that.

11 A. I think I've already quoted an example. During my testimony

12 yesterday in my response to the Court about what happened when 75

13 civilians were dislocated to the hospital in Karlovac and they never

14 returned.

15 Q. Oh, come on, Mr. Lazarevic. Yesterday you described, for example,

16 the fact that 75 elderly men and women, for whom you said, if I remember

17 correctly, that nobody was under the age of 70, they were all over 70

18 years old, and that it was through the mediation of the International Red

19 Cross and the United Nations that they were transferred to the hospital

20 for their own health, for their own good. And you turned something like

21 that into saying that it was tantamount to deportation.

22 A. It was deportation, Mr. Milosevic.

23 Q. Mr. Lazarevic, do you know that for any movement of the

24 population, any displacement of the population, in which the International

25 Red Cross mediated, or the UN, there had to have been a statement on the

Page 12562

1 part of people who wished to move somewhere else, to go somewhere else,

2 saying that they wanted to leave. Nobody could coerce them into that.

3 And documents of that kind exist in the Red Cross.

4 A. Yes, those documents, Mr. Milosevic, show that they went to

5 hospital to have a medical examination. They thought they would go back

6 to their own houses the next day. However, they did not go back.

7 Q. Did anyone forbid them to go back?

8 A. Yes.

9 Q. Who forbid them to go back?

10 A. People in the Republic of Srpska Krajina. We did.

11 Q. When you say "we did," who do you mean "we"? Who could have

12 prevented these people from going back? You said that it was through the

13 mediation of the International Red Cross and the United Nations that they

14 were taken away for recuperation to hospital and that they were then

15 forbidden to return. This first point probably did take place and this

16 was a humane act towards elderly people, people who were all over the age

17 of 70. And now as to whether somebody came back or wished to come back or

18 came back later or didn't come back at all or died in that hospital or

19 went further on to stay with the family, how can you possibly know about

20 this?

21 A. Because I was present there.

22 Q. You were present when they were forbidden to come back?

23 A. I was present when the requests were made for them to return,

24 through the UN, and the ways that we avoided them from returning.

25 Q. How did you do that?

Page 12563

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Page 12564

1 A. We would create an incident at the border crossing.

2 Q. So you would create an incident and not let them come back?

3 A. No. We would say it was impossible for them to come back because

4 of the situation on the ground.

5 JUDGE KWON: Slow down, please.

6 MR. MILOSEVIC: [Interpretation]

7 Q. I'm very sorry that you are turning a humanitarian action into a

8 deportation. However, that is probably your purpose. You said at one

9 point here -- I don't know if I'll be able to find this portion. And I

10 remember that you stated that in your statement.

11 Yes. On page 9, you say, page 9 out of 38, you say:

12 "We did everything in order to prevent them from discovering the

13 truth, and we would always, on several occasions, serve misinformation to

14 them. It was amazing to us how often they believed what we were saying,

15 but --" and this is the key of what I want to read to you -- "but if you

16 keep repeating the same lies again and again, it seems as if anyone would

17 eventually conclude that it must be true."

18 Mr. Lazarevic, is that the method you recognised in this

19 institution here, with this false indictment against me; that if you keep

20 repeating the same lies all over again that in the end you would

21 eventually convince people that it's true?

22 JUDGE ROBINSON: Don't answer that question.

23 Next question.

24 MR. MILOSEVIC: [Interpretation]

25 Q. In that same paragraph, you say that within the 21st Corps --

Page 12565

1 actually, it doesn't matter which paragraph it was. You talked about this

2 yesterday. Therefore, that within that corps, there was a unit that, as

3 you say, was tasked with performing dirty jobs, as you call them, and that

4 Ajdinovic was in command of that unit and that it had an official name of

5 a unit for anti-terrorist activities within the 21st Corps.

6 A. Yes, that's right.

7 Q. Can you tell me how many people that unit numbered?

8 A. I think it was 40 to 45 people.

9 Q. 40 to 45?

10 A. Yes, approximately.

11 Q. And at what period of time did Ajdinovic command -- was in command

12 of that office?

13 A. Beginning of 1992.

14 Q. Beginning of 1992. Do you know that at that time in Rijeka -- he

15 was in Rijeka at that time and left Rijeka with the 13th Corps?

16 A. Who did that?

17 Q. Ajdinovic.

18 A. I wasn't aware of that.

19 Q. Are you saying -- but you're saying that he was in command of that

20 unit. And do you know his rank?

21 A. Colonel.

22 Q. And colonel would be in charge of a unit that had only 45 people.

23 That was a platoon.

24 A. Mr. Milosevic, you are forgetting that that was a special unit.

25 Q. I'm not forgetting anything, but I know that special platoons are

Page 12566

1 not commanded by colonels. So you don't know that at the time Ajdinovic

2 was in Rijeka and left Rijeka together with the 13th Corps. Now, tell me,

3 please: What premises did that unit use?

4 A. The last ones I remember were located in a building on the road

5 between Vojnic and Vrginmost. It was in a separate house. They had their

6 own security, personnel there, and they stayed there.

7 Q. All right. Can you give me the name of at least one member of

8 that unit?

9 A. The leader, the commander of that unit, was somebody called --

10 with a nickname Paraga.

11 Q. What was his name?

12 A. If I remember well, Sinisa Martic.

13 Q. So was he in charge of that command or was it Ajdinovic? You say

14 that leader. I don't know what that means in a military sense. Does that

15 mean he was commander of that unit?

16 A. Yes, but the commander of the unit takes orders from his

17 superiors, and his superior was Colonel Ajdinovic.

18 Q. And what was the position held by Ajdinovic, according to you?

19 THE WITNESS: I'm sorry, Your Honour. It appears that I don't get

20 the questions any more in my headphones.

21 [Technical difficulty]

22 JUDGE ROBINSON: Would the registrar have that checked out.

23 Yes. Proceed. Ask the question again, Mr. Milosevic.

24 MR. MILOSEVIC: [Interpretation]

25 Q. What was the position held by Ajdinovic? You told us that he was

Page 12567

1 in command of that unit, and now you're saying that another person,

2 nicknamed Paraga, was the commander but he took orders from Ajdinovic. So

3 in that staff where you served as an interpreter, what position was held

4 by Ajdinovic?

5 A. In the staff itself, he had no position, as far as I remember. He

6 came and left.

7 Q. So out of all the members of that unit, you only know that

8 commander nicknamed Paraga, nobody else?

9 A. Jovica Vojinovic, and I only know nicknames of the rest, not their

10 full names.

11 Q. Very well. We'll get to that later too.

12 On page 18, paragraph 6, you speak about placing mines on the

13 soccer field, assassination of the mayor of Vrginmost, placing of

14 explosives on the railway between Vrginmost and Glina. Can you tell me

15 who issued orders and when, for this?

16 A. I can only give you my assumptions concerning these events,

17 because I was informed of these events after they took place. When I went

18 to the staff of the 21st Corps in order to lodge an official protest to

19 the UN forces.

20 Q. Let's take it easy, please. As far as I understand this, the Serb

21 side protested with the UN because Croatia in fact carried out this

22 sabotage operations.

23 A. That was the official version, Mr. Milosevic.

24 Q. Now, how do you know that this official version was not true?

25 A. Based on the investigation that was carried out.

Page 12568

1 Q. And did you have in your hands a finding of that investigation, or

2 did you learn of this subsequently; learned, heard, and didn't in fact

3 have any direct information regarding this?

4 A. Mr. Milosevic, every event, a negative one, in the area covered by

5 the 21st Corps, the command of the 21st Corps, through its liaison

6 officer, which -- who was me, would lodge a protest regarding that with

7 the UN. As far as the investigation is concerned, there was the

8 international police on the ground at the time that carried out its own

9 investigation. There were also military observers of the UN. There were

10 four battalions of them. And in the end, we also had there the 21st

11 Corps. Now, how I came to know who the perpetrators were, from the

12 perpetrators themselves.

13 Q. Now, who were the perpetrators? You said from the perpetrators

14 themselves you learned about who did that. Who were these perpetrators?

15 A. The special anti-terrorist unit.

16 Q. And they informed you about that, and you just told us a minute

17 ago that you only knew Paraga out of all of them. Did Paraga inform you

18 of this?

19 A. In the talks that took place in cafes, in their headquarters, in

20 their command post and so on.

21 Q. So you heard that in your talks with them; however, you can't name

22 any of them except for Paraga?

23 A. I gave you another name of a gentleman who became a close friend

24 at the time; Mr. Jovica Vojinovic. There were a number of those young

25 people that moved about and were only known by their nicknames. They

Page 12569

1 didn't have their names written on their uniforms so that one could tell

2 who is who.

3 Q. All right, Mr. Lazarevic. It is clear here that you are only

4 talking about things that you heard in various conversations and talks in

5 cafes, as you called them. However, you did not attend or were not

6 present during any official investigation, you were not present where any

7 official order was issued or when anything was carried out officially.

8 Isn't that right?

9 A. No, that's not right.

10 Q. So what functions did you attend? Why are you talking to us about

11 cafes? Can you tell us what official functions did you attend, what

12 official reports have you received? Why are you bringing up cafes and

13 informal talks here?

14 A. I told you how I came to the conclusion. I told you that I did so

15 based on my conversations with them. But I also told you that I was

16 present as an interpreter, as a liaison officer, whichever way you want to

17 call me. I was present when investigations were carried out by the UN,

18 because at the time, the UN personnel were not able to move about freely

19 as they wanted. They always had to have either military or police escort

20 with them.

21 Q. So I don't understand. This is not an answer to my question. So

22 what is it that you learned through an official function? Was there a

23 report by the UN stating that this was carried out by Serbs?

24 A. In a way, yes.

25 Q. Well, tell us: Was there such a report or not?

Page 12570

1 A. I told you: In a way, there was. And please allow me to give you

2 a more detailed answer.

3 JUDGE ROBINSON: [Previous translation continues]... the accused

4 reminded to observe the pause. I can sense the stress in the

5 interpretation. These interpreters are under immense stress by carrying

6 on at that speed. You must observe a pause.

7 THE WITNESS: I sincerely apologise, Your Honour, but sometimes

8 replying to Mr. Milosevic takes immediate reaction.

9 JUDGE ROBINSON: But you speak the same language, so it's there's

10 a natural inclination to reply immediately. I think you have to exercise

11 some discipline.

12 Yes, continue. Who was to speak? You had asked the question

13 and ...

14 THE ACCUSED: [Interpretation] Mr. Lazarevic said that he wanted to

15 explain what I asked him about, and if he has forgotten in the meantime, I

16 can continue, if you feel no need to explain.

17 A. I don't feel a need to explain, but if you wish, I can explain for

18 your sake.

19 MR. MILOSEVIC: [Interpretation]

20 Q. There is no need to explain anything for my sake. You mentioned

21 the UN and I asked you whether there was a report of the UN claiming that

22 this had been done by Serbs. You said in a way, yes. And then I asked

23 you: Yes or no.

24 A. I said in a way, yes, and I will now explain my answer. The

25 reports showed the places where these incidents took place were deep

Page 12571

1 enough in the RSK territory to make it technically impossible for Croatian

2 forces to penetrate the border along the Kupa River, which was heavily

3 mined. There were many designated and not designated minefields. And

4 after the incidents, the investigation was launched immediately. The army

5 of the RSK went on the ground. They looked through the forest to see

6 whether they can find enemy forces. They never established where they had

7 come from and where they had gone, so that the final finding of the UN

8 investigation was that there was not enough evidence to prove that the

9 Croatian side had carried out what we're claiming they have, but there

10 were many clues pointing to the fact that we carried this out ourselves.

11 Q. So the insufficiency of evidence, the lack of sufficient evidence

12 that this had been carried out by the Croat side is interpreted by you as

13 the confirmation of the fact that this has been carried out by the Serb

14 side. Now, please tell me: Which soccer station was mined? Can you tell

15 me, which one was it?

16 A. In Glina.

17 Q. In Glina?

18 A. Yes.

19 Q. On page 18, paragraph 6, you say the same thing, that that unit in

20 charge of dirty jobs placed mine on soccer stadium, or on the soccer

21 field. Now, please tell me: Why is it that on the very next page, in

22 paragraph 2, you say that these mines had been placed in a football

23 stadium, a football field, in Topusko? So it's a completely different

24 location. Mr. Lazarevic, is it a fact that amidst a number of

25 fabrications, you have forgotten what you said on the previous page?

Page 12572

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Page 12573

1 A. I'm sorry, but this is not something that I stated. Please allow

2 me to find this in the original. I only described one incident of placing

3 mines, and that pertained to Glina. I never said that the soccer field in

4 Topusko was mined as well.

5 Q. You say, on page 19: "A football match in Topusko was planned.

6 Night before that pate mines were placed on the field and then they were

7 accidentally discovered immediately prior to the match and then the match

8 was cancelled." So are you saying that you didn't state that?

9 A. Mr. Milosevic, I gave one statement, and that pertained to the

10 football field in Glina. How Topusko came into picture, I have no idea.

11 Q. All right. I'm very glad that we found something that you claim

12 you had not stated in your statement, and this is not a lonely example of

13 that.

14 Do you know that Dmitar Obradovic, the mayor of Vrginmost, and an

15 honourable man, wore, until the very last day, the uniform of the TO of

16 Krajina?

17 A. No. I met him when he wore civilian clothes.

18 Q. All right. You met him, but do you know that other than when you

19 met him and he wore civilian clothes, he wore the uniform of the TO

20 Krajina until the very last day?

21 A. No, that's not true. He wore civilian clothes until the last day.

22 Q. All right. Do you know that, together with his fellow citizens,

23 he participated in liberating Serb villages from blockades?

24 A. No, I'm not aware of that.

25 Q. You're not aware of that. All right. Now, why are you claiming

Page 12574

1 that this unquestionably honourable man was killed by Serbs? Why do you

2 claim that?

3 A. Based on information from the ground.

4 Q. What kind of information do you have?

5 A. Conversations with perpetrators and Colonel Ajdinovic was pointed

6 to as the organiser. There were plannings of several murders that I

7 attended personally. The murder happened 250 metres away from the command

8 of the 21st Corps, a very short distance from the headquarters of the

9 United Nations in a section of the road which is very busy and which links

10 Topusko with the main road towards Glina. And it happened at 9.00 a.m.

11 The forces of the 21st Corps went out the very moment they learned about

12 the murder, five minutes after, they combed the surrounding area and they

13 didn't find any of the two men who committed the attack, because

14 investigation showed later that the man had been shot at from two

15 different places. The shooting was directed at the vehicle driven by

16 Obradovic.

17 Q. So it was an ambush?

18 A. Yes.

19 Q. And this ambush was the work of this platoon, this detachment that

20 you speak about?

21 A. Yes.

22 Q. But you have no proof of that.

23 A. I told you about the proof I have.

24 Q. Well, if that sort of proof was acceptable, prisons would be full.

25 Explain, please: This mining of the area, the planting of mines

Page 12575

1 around the water tower, the story is incredible. It's preposterous.

2 People are planting mines to their own detriment and killing themselves;

3 is that it?

4 A. No.

5 Q. Again you mention Ajdinovic and you say that Serb peasant would

6 take his cows or goats there, and one of them would step on the mine, or

7 even the person himself would step on the mine. The story would spread

8 around quickly and the government would blame Croatian terrorists. Is

9 that correct?

10 A. Yes.

11 Q. Don't you think it is preposterously cheap and simply criminal --

12 A. No.

13 Q. -- to kill your own people, innocent people in every respect, just

14 in order to achieve what? To blame who? Accusations against Croatian

15 authorities were much more serious than the planting of mines that would

16 kill one single person. Tell me: What could be the possible purpose of

17 such an action? What could possibly justify it?

18 A. Creating the psychosis of fear that would eventually result in

19 stopping the negotiations with the Croatian side.

20 Q. And what was the purpose for that? What would they achieve?

21 A. Demilitarisation, separation of forces, to a distance of ten

22 kilometres in depth, et cetera.

23 Q. So you claim that this unit was killing its own civilians to

24 maintain the tension and the atmosphere of fear, to prevent reaching an

25 agreement?

Page 12576

1 A. Yes. You put it very well.

2 Q. Couldn't they avoid the reaching of an agreement even without

3 killing peasants?

4 A. As far as I can remember, an agreement was never reached.

5 Q. Well, they could have failed to reach it even without killing

6 innocent peasants.

7 A. You seem to be making a connection between two unrelated

8 incidents.

9 Q. You are describing this event wherein this peasant took his sheep

10 -- took his cows or goats to graze there and one of them would step on

11 it. Anyway, I can't understand why you are telling these things. Do you

12 know at all who these terrorists - and I have information that it was

13 Croatian terrorists - who it was that they killed at this water tower?

14 A. I don't know. I know that a minefield was laid, I know a civilian

15 was killed, I know a Serb civilian stepped on one of the mines.

16 Q. Do you know that at the water tower it was a guard that was killed

17 by stepping on a mine, and Velibor Matijasevic, president of the Socialist

18 Party of Glina -- do you remember a socialist party was formed there in

19 Banija, in Kordun? Bora Mikelic was the president at that time, in 1990,

20 at the beginning of 1991.

21 A. I wasn't involved in politics. I don't know about that.

22 Q. Very well. You are not aware of that. You don't know who was

23 killed, you don't know that it was the president of the socialist party

24 who was killed there, but you do know that it was done by the people who

25 you claim did it.

Page 12577

1 A. Precisely.

2 Q. All right. On page 19, you say that Jovo Vojinovic, to whom you

3 referred yesterday as a friend of yours, killed an elderly couple. You

4 don't have to look for it. It's on page 19, paragraph 3. You said

5 yesterday the man was a friend of yours. You said that Jovo Vojinovic

6 threw him into a well and bragged about it.

7 A. Yes.

8 Q. According to the information I have, a similar incident did

9 happen, but you are misrepresenting it, just as you are misrepresenting

10 everything else, and you are groundlessly and falsely accusing this friend

11 of yours, Jovo Vojinovic. Why are you doing that?

12 A. It is not groundless. Mr. Vojinovic told me personally that he

13 had done it, so it's not groundless. It is based on the statement of the

14 man who did it.

15 Q. All right. Where did it happen?

16 A. In one of the villages along the banks of the Kupa River.

17 Q. Do you know that a similar incident happened involving not an

18 elderly couple, but two women; two women, not a couple?

19 A. Somewhere else? What's the question?

20 Q. Do you know about this incident?

21 A. That's not the case.

22 Q. Yes, that was precisely the case. Two women were thrown into a

23 well, as you said, according to the information I have gathered, and it

24 was in the village of Brodja [phoen].

25 A. I don't understand the question. What are you asking me?

Page 12578

1 JUDGE ROBINSON: Mr. Groome is on his feet.

2 MR. GROOME: In fairness to the witness, can we either have a

3 place and date identified or can the witness be shown a copy of this

4 information? It seems rather vague information to expect the witness to

5 be able to answer, and it's regarding two women.

6 JUDGE ROBINSON: Yes, Mr. Milosevic. Can you be a little more

7 specific?

8 THE ACCUSED: [Interpretation] I can be more specific. Since I'm

9 not in a position here to defend anyone, or accuse, I'm only defending the

10 truth, I can say that according to the information available to me --

11 MR. MILOSEVIC: [Interpretation]

12 Q. Do you know that the Prosecution authorities conducted an

13 investigation and found out that this crime was perpetrated by a

14 conscript, also a Serb, Branko Miljkovic, not Jovo Vojinovic, your friend.

15 He was a member of the anti-terrorist units, and it was done for purposes

16 of gain, not as part of anti-terrorist activity. And it was qualified as

17 murder out of base motives. That is the most serious type of crime. And

18 the man spent the rest of the time until the fall of Krajina in prison.

19 A. Do you allow for the possibility, Mr. Milosevic, that there were

20 more than one incidents of the kind, that we are talking about two

21 different incidents? I am claiming that the incident mentioned in my

22 statement is something I learned about from the horse's mouth, from the

23 mouth of the man who did it and who said that he had killed an elderly

24 couple who had been accused of making signals to the Croatian side using

25 candlelight from their window. About these two women you're talking

Page 12579

1 about, I know nothing about that. I know only about the incident that I

2 refer to.

3 Q. This information that I'm quoting is something I received in

4 response to your claims, and it seems to be a similar event, and the man

5 involved was accused, convicted, and sent to prison.

6 A. You said it yourself. A similar incident. That means there was

7 more than one.

8 Q. No. I'm saying that I'm talking about something similar to what

9 you made up.

10 JUDGE ROBINSON: Mr. Milosevic, I think you have taken this as far

11 as you can. The witness has given his answer. He says that he was

12 speaking of another incident. I think you must move now to another area.

13 THE ACCUSED: [Interpretation] All right. You are right, Mr.

14 Robinson. There's no point in dwelling on this.

15 MR. MILOSEVIC: [Interpretation]

16 Q. Have you heard of Croatian Minister Zulic who was captured during

17 fighting around the village of Losinj?

18 A. No.

19 Q. So you are not aware that it was precisely Ajdinovic who took him

20 over and handed him over to Croatian authorities immediately afterwards?

21 A. There is an incident that comes to mind, a similar one, that is,

22 the arrest of a Croatian colonel who had, by mistake, crossed over to our

23 sided, near Turanj, was taken into custody by the military police and was

24 later exchanged for a colonel of ours. That is an incident that seems to

25 be similar to the one you are talking about.

Page 12580

1 Q. All right. I named a line of -- a number of villages, Lukinici,

2 Buncici, and a number of other villages in the same area, villages

3 populated by Croats who lived peacefully throughout the war. So if there

4 had been a unit which was supposed to expel Croats from this area, would

5 all the Croats from these villages have been expelled or not?

6 A. No. I just gave you a number of reasons why they were not.

7 Q. So when they are expelled, they are expelled on orders from

8 Belgrade, for purposes of ethnic cleansing?

9 A. Yes.

10 Q. When they are not expelled, they are not expelled on orders from

11 Belgrade to make Belgrade seem good, look good?

12 A. Yes.

13 Q. Whatever the Serbs do, they commit a crime. They simply have no

14 choice, whether you expel them or not expel them, you are always the one

15 at fault. Do you know that on the 4th of July, 1991, in Topusko, 250

16 members of the ZNG, the Corps of the National Guard, arrived on buses, and

17 Serbs, although forming a majority, had to leave the place?

18 A. On the 4th of July, 1991, I was not in Topusko.

19 Q. You were in Kladusa?

20 A. Yes.

21 Q. Tell me, please, Mr. Lazarevic, how far it is from Topusko to

22 Kladusa.

23 A. 17 kilometres, thereabouts.

24 Q. 17?

25 A. Maybe I'm mistaken. 15 or 17.

Page 12581

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Page 12582

1 Q. You, who are an intellectual, following events, living in Kladusa,

2 you don't know of an event which happened only 17 kilometres away from

3 you?

4 A. I'm saying I cannot comment because I wasn't there.

5 Q. You were not there when all these other events you spoke about

6 happened. You speak from the words of others.

7 A. You are wrong, Mr. Milosevic. What you are talking about was

8 shown on television. Everybody in Bosnia and Herzegovina had the occasion

9 to watch the arrival of Martic's special units. All of that was shown on

10 television. I just don't want to comment on something about which I had

11 no official information, nor was I present when it happened.

12 Q. I already asked one of the previous witnesses, but he didn't take

13 my point. Maybe you will. Do you know that famous saying that the

14 greatest lying is done during elections and after hunting and fishing?

15 A. I don't know about it.

16 Q. Otto von Bismarck said that people lie the most during elections,

17 after hunting, and during the war.

18 JUDGE ROBINSON: We heard that one before.

19 MR. MILOSEVIC: [Interpretation]

20 Q. Does it seem true to you that most -- the greatest lies are told

21 during the war?

22 A. That seems very probable.

23 Q. Regarding this event in Topusko - you didn't hear about because it

24 was on the 4th of July - do you know that not a single Serb house was left

25 intact in Topusko?

Page 12583

1 A. I know that when I entered Topusko, most of the buildings were

2 torched. Were they were Serb or Croatian, I don't know.

3 Q. Do you know that the majority population of Topusko was Serb?

4 A. Yes. I was there before the conflict once.

5 Q. And do you know that the majority population was Serb?

6 A. I wasn't interested in the ethnic make-up of Topusko.

7 Q. Do you know about the Serb village of Miljevici? Do you know

8 where it is? Do you know that it was razed to the ground, destroyed, and

9 looted in the same way?

10 A. No, I don't.

11 MR. GROOME: Your Honour, Mr. Milosevic, throughout the course of

12 the morning, has referred to villages. Prosecution Exhibit 336 is a

13 commercially available map. May I suggest -- and I've made -- taken the

14 liberty of making some photocopies for Mr. Milosevic so that he can use

15 with the witness. I think, in fairness to the witness, he should be

16 presented with a map. On the single page that I have, there are at least

17 a hundred villages. Perhaps if Mr. Milosevic could indicate on the map

18 the village that he is asking the witness about, it will facilitate the

19 witness's ability to answer his question. And I have some photocopies

20 here, if Mr. Milosevic or the Chamber wishes.

21 THE ACCUSED: [Interpretation] I don't believe --

22 JUDGE ROBINSON: Would you be facilitated by the maps?

23 THE ACCUSED: [Interpretation] I don't believe Mr. Lazarevic needs

24 a map to find his way around Topusko, Vojnic, and Kladusa. He lived there

25 for such a long time that he surely doesn't need a map.

Page 12584

1 MR. MILOSEVIC: [Interpretation]

2 Q. Tell me, please: Do you know that while the ZNG was occupying

3 Topusko, 11 Serbs were killed?

4 JUDGE KWON: The witness hasn't answered the question.

5 You need the map, don't you?

6 THE WITNESS: I would prefer, Your Honour, to have a map to

7 actually try to locate these places that Mr. Milosevic is talking about.

8 He relies on my geographical knowledge of the area, which is very poor.

9 JUDGE ROBINSON: Let the witness have the map.

10 MR. MILOSEVIC: [Interpretation]

11 Q. All right. Can you find Topusko, or shall I show it to you? Do

12 you need to find it on the map for this question? So go 17 kilometres

13 from Kladusa and find it.

14 A. Yes. And what's the question?

15 Q. The question is: Do you know that 11 Serbs were killed in a short

16 interval, when Topusko was occupied by the Croatian National Guard, a

17 well-known paramilitary formation?

18 A. No, I don't know of that detail.

19 Q. Fine. And do you know -- it is a related question. You don't

20 know, is your answer to the first question. Do you know that not a single

21 Croat was killed or wounded when the town was taken over by the police and

22 army of the Republic of Serbian Krajina?

23 A. I don't know about that either.

24 Q. So you are not aware that the Croatian National Guard killed 11

25 Serbs when they occupied Topusko; and later, when the army and police of

Page 12585

1 Serbian Krajina entered Topusko, not a single Croat suffered from it?

2 A. Look, Mr. Milosevic, nobody sent reports to me from the ground

3 about what was going on in Topusko at the time. I could only see what the

4 television reported, and that's all.

5 Q. All right, Mr. Lazarevic. Do you know of a single crime committed

6 by Ustasha and paramilitary Croatian forces in that territory?

7 A. Yes.

8 Q. On page 15, you say that you don't know of a single incident when

9 Croatian terrorists made incursions into the territory of Krajina.

10 A. That much is true. I'm not talking about attacks of the Croatian

11 army.

12 Q. Operation Flash, Storm, et cetera.

13 A. That will be subject-matter for other trials. I don't want to go

14 into that.

15 Q. So what do you know? You said that you were aware of crimes

16 committed by Croatian and Ustasha forces on the territory of Serbian

17 Krajina. What exactly do you know about it?

18 A. The Medoc pocket was an example that hit me very hard, for

19 instance. It was an attack that was aimed at scorched earth, and I know

20 about it. I was there at the time. I also know about it from reports.

21 Q. Do you know, in addition to what I cited yesterday, in the

22 neighbouring area to Topusko, do you know about the murder of eight

23 civilians, elderly and children, in a canyon in Slunj, in June 1992?

24 A. June 1992? I don't know. But you can be certain that if that had

25 happened then, I would certainly have been informed by my command.

Page 12586

1 Q. As you see, you were not informed, and you think of yourself as a

2 well-informed man.

3 A. It couldn't have been.

4 Q. Do you know about the murder and massacre of 13 members of

5 Territorial Defence on a bridge in September 1991?

6 A. I know about that. I talked to one of the survivors.

7 Q. How about 11 members of Territorial Defence that happened in

8 October between Sturlic and Cetingrad? They were murdered in October of

9 that year.

10 A. I heard you very well. My answer is no.

11 Q. That was in your immediate vicinity.

12 A. In October 1991?

13 Q. As far as time is concerned, it was not very close to you, but

14 between Cetingrad and Sturlici, that area was close to where you were.

15 A. Provided that I was in Kladusa, it's 11, not 12, kilometres.

16 Q. Yes. About ten kilometres. And in October 1991 you were in

17 Kladusa.

18 JUDGE ROBINSON: We are coming to the time for the break. We'll

19 take the break now and we'll resume tomorrow at 9.30.

20 Mr. Milosevic will have one and three-quarter hours of

21 cross-examination.

22 Do you have a witness after?

23 MR. GROOME: Yes, Your Honour. The Prosecution does have a

24 witness afterwards. I neglected, before I finished my questioning, just

25 to do that stock-taking exercise that Judge May had suggested. I'm

Page 12587

1 prepared to do it now or tomorrow morning, whichever pleases the Chamber.

2 JUDGE ROBINSON: I think tomorrow morning.

3 We'll take the adjournment, and I remind the witness that he is

4 not to speak to anybody about his evidence during the break.

5 --- Whereupon the hearing adjourned at 1.46 p.m.

6 to be reconvened on Thursday, the 31st day of

7 October 2002, at 9.30 a.m.

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