Tribunal Criminal Tribunal for the Former Yugoslavia

Page 3266

 1                           Monday, 8 February 2010

 2                           [Open session]

 3                           [The accused entered court]

 4                           --- Upon commencing at 2.20 p.m.

 5             JUDGE ORIE:  Good afternoon to everyone.

 6             Madam Registrar, would you please call the case.

 7             THE REGISTRAR:  Good afternoon, Your Honours.  Good afternoon to

 8     everyone in and around the courtroom.  This is the case IT-03-69-T, The

 9     Prosecutor versus Jovica Stanisic and Franko Simatovic.

10             JUDGE ORIE:  Thank you, Madam Registrar.

11             I would like to move, only for a very short moment, into private

12     session.

13                           [Private session]

14   (redacted)

15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

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25   (redacted)

Page 3267

 1                           [Open session]

 2             THE REGISTRAR:  We're in open session, Your Honours.

 3             JUDGE ORIE:  Thank you, Madam Registrar.

 4             Before I give an opportunity to the Prosecution to call its next

 5     witness, I'd like to read an oral decision on a request for protective

 6     measures for Witness B-1459.

 7             The Chamber will now deliver an oral decision on the remainder of

 8     the Prosecution's motion for protective measures for witnesses filed on

 9     the 6th of January, 2010, and on the remainder of the Prosecution request

10     for leave to reply to the Stanisic Defence response to the Prosecution

11     motion for protective measures for witnesses filed on the

12     21st of January, 2010, in as far as they relate to Witness B-1459.

13             The Chamber recalls that, on the 25th of January, 2010, it ruled

14     on these motions in as far as they concerned Witness B-1048.

15             In its 6th of January motion, the Prosecution requests that

16     Witness B-1459 be granted a pseudonym and face distortion.  The

17     Prosecution states that this witness is a survivor of a so-called human

18     shield incident who was originally scheduled to testify as a Prosecution

19     witness about the same incident in a domestic case before the Court of

20     Bosnia and Herzegovina, to which I will now refer to as the BiH Court.

21             Witness B-1459 reported that, in 2008, he received two telephone

22     calls from an unidentified caller who warned him, inter alia, to be

23     extremely careful.  Witness B-1459 also reported that he believes that

24     these phone calls were related to his expected testimony before the

25     BiH Court.

Page 3268

 1             The Stanisic Defence, in its response of the

 2     20th of January, 2010, argues that Witness B-1459's fears are subjective

 3     that they were expressed only after being solicited by the Prosecution.

 4     In relation to the two telephone calls, the Stanisic Defence contends

 5     that there is little evidence that the calls were related to the

 6     witness's intended testimony in the BiH Court and even less that they

 7     could be related to his testimony in the present case.  The

 8     Simatovic Defence did not respond to the motion.

 9             In the 21st of January request to reply, the Prosecution states

10     that it seeks to address certain alleged inaccuracies and incorrect

11     assumptions made by the Stanisic Defence.

12             The Chamber recalls that the party seeking protective measures

13     for a witness must demonstrate an objectively grounded risk to the

14     security or welfare of the witness or the witness's family, should it

15     become known that the witness has given evidence before the Tribunal.

16     This standard may be satisfied by showing that a threat was made against

17     the witness or the witness's family.

18             In examining the request for protective measures, the Chamber has

19     therefore given particular consideration to the threats received by

20     Witness B-1459, as reported by him.  The Chamber notes that these threats

21     are of a potentially serious nature and considers that there is a

22     considerable risk that they may have been connected to Witness B-1459's

23     anticipated testimony before the BiH Court.  The Chamber further notes

24     that Witness B-1459 is scheduled to testify in the present proceedings

25     about the same incident.

Page 3269

 1             Pursuant to Article 20(1) of the Tribunal's Statute and Rule 75

 2     of the Tribunal's Rules of Procedure and Evidence, out of an abundance of

 3     caution and considering that the requested protective measures would not

 4     affect the public character of the trial, the Chamber therefore grants

 5     the protective measures requested by the Prosecution and orders that

 6     Witness B-1459 shall be referred to by his pseudonym in all public

 7     proceedings and filings and that he shall testify with the protective

 8     measures of face distortion - where I said measures, of course, I meant

 9     the protective measure of face distortion.

10             Furthermore, in light of this decision, the Chamber denies the

11     remainder of the Prosecution's request for leave to reply, in as far as

12     it concerns Witness B-1459.

13             And this concludes the Chamber's decision.

14             Is the Prosecution ready to call its next witness?  No protective

15     measures.

16             MS. MARCUS:  Yes, Your Honour, correct.

17             JUDGE ORIE:  Yes.  Only one matter which I'd like already to draw

18     your attention to is that part of the 92 ter statements are -- were given

19     in private session.  If I say 92 ter statements, I should have said

20     92 ter testimony.  And I do not know what consequences you will attach to

21     that.

22             MS. MARCUS:  Just a moment, please, Your Honour.

23                           [Prosecution counsel confer]

24             MS. MARCUS:  Your Honours, perhaps private session for one moment

25     to answer the question fully, if you will.

Page 3270

 1             JUDGE ORIE:  We move into private session.

 2                           [Private session]

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

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 3271

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5                           [Open session]

 6             THE REGISTRAR:  We're in open session, Your Honours.

 7             JUDGE ORIE:  Thank you, Madam Registrar.

 8                           [The witness entered court]

 9             JUDGE ORIE:  Good afternoon, Mr. Lazarevic.

10             THE WITNESS:  Good afternoon, sir.

11             JUDGE ORIE:  Before you give evidence in this Court, the Rules

12     require that you make a solemn declaration, the text of which is now

13     handed out to you by the Usher.

14             May I invite you to make that solemn declaration.

15             THE WITNESS:  I solemnly declare that I will speak the truth, the

16     whole truth, and nothing but the truth.

17                           WITNESS:  SLOBODAN LAZAREVIC

18             JUDGE ORIE:  Thank you.  Please be seated, Mr. Lazarevic.

19             You gave your solemn declaration in English.  Do you prefer to

20     give your testimony in English as well, Mr. Lazarevic, because we --

21             THE WITNESS:  [Overlapping speakers] ... Your Honour.

22             JUDGE ORIE:  We have interpreters here who could translate your

23     words if you would prefer to speak your own language, your native

24     language.

25             THE WITNESS:  Actually, I would rather speak in English.

Page 3272

 1             JUDGE ORIE:  You'd rather speak in English.

 2             Mr. Lazarevic, you will first be examined by Ms. Marcus.

 3     Ms. Marcus is counsel for the Prosecution.

 4             Please proceed.

 5             MS. MARCUS:  Thank you, Your Honour.

 6                           Examination by Ms. Marcus:

 7        Q.   Good afternoon, Mr. Lazarevic.

 8        A.   Good afternoon.

 9        Q.   Could you kindly state your full name, date, and place of birth

10     for the record.

11        A.   Slobodan Lazarevic, 26th of February, 1947, Belgrade.

12        Q.   Can you please tell the Court where and when -- sorry.  Where and

13     what it was that you studied?

14        A.   Languages at university of philosophy.

15        Q.   Do you recall giving evidence before this Tribunal in the case

16     against Slobodan Milosevic on 29th through 31st of October of the

17     year 2002?

18        A.   Yes, I do.

19        Q.   And have you --

20             THE INTERPRETER:  Could you make pauses, breaks between questions

21     and answers.  Thank you.

22             MS. MARCUS:  My apologies.

23             JUDGE ORIE:  Mr. Lazarevic, from reading the transcripts in the

24     Milosevic case, it's not the first time that you are reminded to -- not

25     to go into -- too high a speed.

Page 3273

 1             THE WITNESS:  My brain goes too fast.

 2             JUDGE ORIE:  Take your time.

 3             THE WITNESS:  Thank you.  I will.

 4             MS. MARCUS:

 5        Q.   Mr. Lazarevic, have you had the opportunity to review the

 6     evidence that you gave during that testimony before coming to court today

 7     in a language which you understand?

 8        A.   Yes, I have.

 9        Q.   Now that you have taken the solemn declaration, do you affirm the

10     truth and accuracy of your prior evidence?

11        A.   Yes, I do.

12        Q.   If I were to ask you the same questions today which you were

13     asked then, would you provide the very same answers?

14        A.   Absolutely.

15             MS. MARCUS:  Your Honours the Prosecution tenders Mr. Lazarevic's

16     testimony in the Slobodan Milosevic case, dated the 29th through the

17     31st of October, 2002, into evidence under seal.

18             JUDGE ORIE:  No objections.

19             Madam Registrar, the number would be?

20             THE REGISTRAR:  Exhibit P224, under seal, Your Honours.

21             JUDGE ORIE:  P224 is admitted into evidence, under seal.

22             I hereby inform the public that this evidence is admitted under

23     seal because there are smaller portions of the evidence given in private

24     session.  However, the remainder of the evidence is accessible through

25     the Internet web site of the ICTY, cases, Slobodan Milosevic case.  If

Page 3274

 1     you are looking for the transcript, you'll find them sorted by date, and

 2     it is the transcript of the 29th, the 30th, and the

 3     31st of October, 2001 [sic].

 4             This is for purposes of the public character of this trial.  I

 5     said 2001 and I meant to say 2002.

 6             Please proceed.

 7             MS. MARCUS:  Thank you, Your Honour.

 8             The Prosecution would also like to tender the associated exhibits

 9     to that prior testimony.  We have, as has become our custom, prepared a

10     list of the prior -- the associated exhibits.  We can distribute hard

11     copies to those present if that would be of assistance.  For your

12     information and for the record, there are no 65 ter exhibits which have

13     already been admitted, so there is no green row on this.  And with

14     Your Honours' leave, I would be happy to submit this around.  We're

15     tendering, with your leave, the associated exhibits to the prior

16     testimony.

17             JUDGE ORIE:  Are there any objections against admission, because

18     we have the -- I would say the administrative matter that numbers should

19     be assigned to them, but I'd first like to know whether there are any

20     objections against admission into evidence of the associated exhibits.

21             We'll any way invite Madam Registrar to assign numbers to them.

22     No decision will be taken until this has been done.  So, therefore, the

23     parties -- of course, were aware of the associated exhibits still have an

24     opportunity to express themselves on it.

25             Then, meanwhile, please proceed.

Page 3275

 1             MS. MARCUS:  Thank you, Your Honour.

 2        Q.   Mr. Lazarevic, in your prior evidence in the Milosevic case, you

 3     explained that you served in the Serbian military intelligence unit.  Can

 4     you describe briefly for the Chamber the structure of the Serbian

 5     Military Intelligence Service, KOS?

 6        A.   Very briefly, there are two strains within the KOS, and one is to

 7     deal with internal security of the country, another one is to deal with

 8     the external security of the country.  My role was in external security

 9     of the country.

10        Q.   Could you tell the Chamber the years of your service in KOS.

11        A.   Basically from 1968 to 1998.

12        Q.   And who was your direct handler?

13        A.   Colonel Nicola Zimonja.

14        Q.   Now, when were you first deployed to the region of the Krajina?

15        A.   In 1991, very early 1991.

16        Q.   Who was it who originally placed you there?

17        A.   Well, I attended a meeting late 1991, between Toso Pajic,

18     Djuro Skaljac, and Colonel Zimonja.  And it was suggested that I should

19     transfer to Samarice which then was a command post for the

20     8th Operational Group under the command of General Mrksic, and that's --

21     I went there.

22        Q.   Where precisely were you deployed then within the Krajina?

23        A.   Originally it was the HQ of the JNA in Samarice which is also

24     known as the 8th Operative Group.  And upon the formation of the corps, I

25     was transferred to the area of the 21st Corps or, as it is also known,

Page 3276

 1     Kordun Corps.

 2        Q.   Now just for clarification, when I asked you when you were first

 3     deployed to the Krajina, your answer was in very early 1991.  And then

 4     when I asked you who placed you there, you described a meeting in late

 5     1991 where it was decided that you would be transferred.

 6             Could you possibly clarify the dates for us?

 7        A.   It's a mistake, obviously a mistake that I just made.

 8             I arrived to the Krajina region late 1991.  I would say probably

 9     around 22nd or 23rd of December.  And within a week to ten days, I was

10     transferred to Samarice which is in the vicinity of Glina.  So that would

11     be the beginning of 1992.  I'm sorry.  I'm just getting too old.

12        Q.   Thank you, sir.  Now what was your sector called, the sector

13     where you were deployed?

14        A.   It was named according to the UN as Sector North, but in our own

15     naming of the sectors it was actually the sector which is AOR of the

16     21st Corps.  And that falls between the two corps and my right-hand side

17     would be Banja Corps, 39 Corps; and on my left would be Lika Corps, or

18     the 19th Corps.  So all those three --

19             THE INTERPRETER:  Could the witness slow down, please.

20     Thank you.

21             THE WITNESS:  I'm sorry.

22             All those three corps areas were under the Sector North

23     deployment.

24             MS. MARCUS:

25        Q.   Officially --

Page 3277

 1             JUDGE ORIE:  Mr. Lazarevic, if you say to your right or to your

 2     left, for us to understand --

 3             THE WITNESS:  If I'm facing Zagreb as I'm facing you, then the

 4     Banja Corps would be on my right and the Lika Corps on my left.

 5             JUDGE ORIE:  Lika to the west, the other one to the east?

 6             THE WITNESS:  Yeah.

 7             JUDGE ORIE:  Yes, thank you.

 8             MS. MARCUS:

 9        Q.   Officially, within the Krajina, what was your job, officially?

10        A.   I was liaison officer for the 21st Corps.

11        Q.   Can you define for us the role of the liaison officer.  What did

12     it mean to be the liaison officer?

13        A.   Basically organising the meetings between the command of the

14     Sector North of the UN and the HQ of the 21st Corps, and dealing with all

15     the other international bodies that would come up, like

16     International Red Cross or ECMM or even journalists.  It would go through

17     me.

18        Q.   Officially, within the Krajina, to whom did you report?

19        A.   I had two -- two lines of reporting.  One was to my CO,

20     Colonel Cedo Bulat, who was a commanding officer of the 21st --

21             THE INTERPRETER:  Can the witness slow down when he gives names.

22             JUDGE ORIE:  Mr. Lazarevic.

23             THE WITNESS:  I'm fighting for a breath that's why I'm trying to

24     squeeze too much in.

25             JUDGE ORIE:  Yes.  If you take a breath first and then continue

Page 3278

 1     speaking, then that might assist the others.

 2             THE WITNESS:  Thank you.  My apologies again.  [Overlapping

 3     speakers] ... back there were two lines of reporting as far as I was

 4     concerned:  One as a liaison officer, 21st Corps, I would report directly

 5     to Colonel Cedo Bulat.  The other line was the reporting -- virtually on

 6     a daily basis to my KOS line which was Colonel Nikola Zimonja.  In

 7     between, I also had a few times to report other requests of the KOS to

 8     report to the local police.

 9             MS. MARCUS:

10        Q.   From whom did you receive your salary?

11        A.   Again, from two different sources.  As an officer of the

12     21st Corps of the Army of the Republika Srpska Krajina, I would receive

13     my monthly salary from Knin.  But some other benefits I would receive

14     from -- from Belgrade.

15        Q.   Mr. Lazarevic, can you tell us how were the corps of the army of

16     the Republika Srpska Krajina, the ARSK, how were the corps formed?

17        A.   I can really only try to explain how it happened in the

18     Sector North.  I don't know what happened in Sector East or Sector South.

19     But in my own AOR, it was very simple.  The corps were given names in

20     accordance with the position they held on the ground.  So if the Banja

21     had their positions there, it would be a Banja Corps.  The 21st Corps

22     would cover the area of -- from Glina to Slunj and that was called

23     Kordun Corps or 21st Corps and would directly join the 19th Corps further

24     south.

25        Q.   In which -- now just to repeat and clarify, your corps, again,

Page 3279

 1     was -- tell us what the name of your corps was?

 2        A.   21st Corps.  Also known as Kordun Corps.  It was covering the

 3     area of Kordun.

 4        Q.   Thank you.  Now, in your prior evidence, you discuss the

 5     demobilisation of the Army of the Serb Republic of Krajina, the

 6     demobilisation of the ARSK, pursuant to the Vance Plan.  I'd like you to

 7     tell us, and please tell us slowly, prior to this demobilisation, from

 8     whom did the corps of the ARSK take their directives?

 9        A.   From the general HQ of JNA which was still then JNA, turns into

10     VJ later on.

11             So instructions and operational movement and everything else

12     would come straight from Belgrade.

13             After the point of us being disarmed in accordance with the

14     Vance Plan, and that meant that there was no more uniformed or military

15     dressed personnel on the ground, over night, we all transformed into

16     police force.  Not only the uniforms but also the transportation were

17     over night coloured in blue, which the militia or police colours, instead

18     of being the olive-green, as the military.

19        Q.   Okay.  We're going return to that topic in just a moment.

20             But, first, can you tell us, while the corps of the ARSK were

21     being set up, what was taking place with respect to the political

22     structures in the Krajina?

23        A.   One has to take into consideration the situation on the ground.

24     Everything was happening very fast.  Even your smallest police station,

25     for example, would have a diminished number of police officers because

Page 3280

 1     all those of Croatian origin had left the area.  The same applies to all

 2     political structures.  If you had a mayor and the mayor was a Croatian,

 3     he was no longer there so it was needed to elect another mayor for

 4     municipalities.  So all this was happening within a short space of time

 5     of approximately three month, electing the officials, placing them into

 6     positions, setting up the numbers with the police, things like that.

 7        Q.   Now, you've told us that were the liaison officer for the 21st or

 8     the Kordun Corps.  What area of responsibility did the 21st or

 9     Kordun Corps cover precisely from where to where, and what the territory

10     that was covered?

11        A.   The length of the territory which was considered to be area the

12     of 21st Corps would be approximately 70 kilometres long, between 17 to

13     20 kilometres wide.  And it was going from Glina to the right or to the

14     east, all the way to Slunj to the left, or to the west.

15        Q.   In your evidence in the Milosevic case, on the

16     29th of October, 2002, at transcript page 12319, you explained that the

17     original HQ of the 21st Corps was in Topusko, opposite the UN compound,

18     and that from there the HQ moved to Petrova Gora and from Petrova Gora

19     you moved -- the headquarters moved in early 1993.  Can you explain to us

20     what prompted the move of the headquarters of the 21st Corps in early

21     1993 to Petrova Gora?

22        A.   Well, we have found ourselves to be in very close proximity of

23     the HQ of the Sector North, the UN forces.  As the crow flies, less than

24     150 metres away.  So the general idea was, This is great; we can actually

25     observe what they do.  Then we realise, at the same time, they are

Page 3281

 1     observing what we do.  So we decided we are going to remove this place,

 2     the HQ, to Petrova Gora, with me being left behind in a hotel in Topusko

 3     as an officer of the liaison office.

 4        Q.   And then what was it that prompted the move later from

 5     Petrova Gora to Vojnic?

 6        A.   That was an order issued to us simple to move from Petrova Gora

 7     to -- in the vicinity of Vojnic there was, I don't know, a villa there,

 8     and I believe that belonged to Minister Spegelj of Croatia.  We were

 9     taking that position because apparently the special police force from

10     Serbia was moving with that HQ into Petrova Gora.  From that day on, it

11     was off limits to us, the members -- or most of the members of the

12     21st Corps.  They had secured the parameter.  You could go there only by

13     invitation.

14             MS. MARCUS:  Could the Court Officer please call up 65 ter 14.

15             This is a map that was marked by the witness during his testimony

16     in the Milosevic case.  And I think it would be helpful if the

17     Court Usher wouldn't mind giving this to the witness and putting it on

18     the ELMO.  Perhaps, with a pen, the witness can indicate to us what he is

19     talking about as he describes it.

20             JUDGE ORIE:  I think you're invited -- could you put the map on

21     the ELMO, please.

22             This is a copy which you do not want the markings to be

23     tendered -- the marked version to be tendered into evidence?

24             MS. MARCUS:  The marked version, this very document, with the

25     markings on it, is an associated exhibit, Your Honour.

Page 3282

 1             JUDGE ORIE:  Yes.  But you do not want any further markings --

 2             MS. MARCUS:  I don't foresee the need for that, Your Honour.

 3             JUDGE ORIE:  Then could this be put on the ELMO so the witness,

 4     without further marking the document could, nevertheless, with a pen

 5     could explain to us what is he talking about.

 6                           [Trial Chamber and Registrar confer]

 7             JUDGE ORIE:  The ELMO is not functioning.  Therefore, I suggest

 8     that whatever the witness wants to explain to us he would do that by

 9     marking on the screen, although the markings then not to be further

10     tendered into evidence.

11             MS. MARCUS:  No, problem, Your Honour.

12             JUDGE ORIE:  Yes.

13             MS. MARCUS:

14        Q.   Mr. Lazarevic, do you see the map in front of you which you

15     marked during your Milosevic testimony?

16        A.   Yes, I do.

17        Q.   Could you please kindly identify to us what is shown on this map,

18     what were the locations that you marked.

19        A.   There are several locations on this map that I have marked.

20             So let me start with the well, Petrova Gora is right in the

21     middle.  Then you have the line going to the MUP Serbia HQ.  Right there.

22     Little red dot now.

23             MS. MARCUS:  Mr. Lazarevic, you could circle it just so that we

24     know what you're talking about.

25             JUDGE ORIE:  Well, what the witness is talking about is what he

Page 3283

 1     is reading.  It seems to be ...

 2             If he says MUP Serbia headquarters, I take it that he is

 3     referring to what we find on the screen as the MUP Serbia headquarters

 4     and nothing else.  I mean ...

 5             MS. MARCUS:  Yes.

 6             JUDGE ORIE:  -- that is clear for everyone who looks at it.

 7     There is, I see, a reference to the 21st Corps' headquarter.  And to the

 8     original 21st Corps; perhaps that is headquarters as well.  We could ask

 9     him because that is it not clear from the text itself yet.

10             THE WITNESS:  If I can be of any help.  I am pointing at the area

11     of Topusko now.  That's where the original HQ of the 21st Corps was

12     situated and the command of the Sector North of the UN.  From this

13     position, we moved to Petrova Gora, and then we got displaced by the

14     police from Serbia from Petrova Gora to Vojnic, just above on the map.

15     All the other points here, and that is Pauk HQ -- headquarters, and then

16     RSK parade ground in 1995.  That's about it that this map shows.

17             MS. MARCUS:

18        Q.   Thank you, Mr. Lazarevic.  It was precisely that progressive move

19     and to orient the Court that I wanted to -- to show the map that you had

20     previously marked.

21             MS. MARCUS:  Now, we can -- now we can leave the map.  Thank you.

22        Q.   In the Milosevic case, you mentioned -- and just earlier today

23     you also mentioned Colonel Bulat.  Can you tell us who he was, with

24     respect to the 21st Corps?

25        A.   Colonel Bulat is a career officer with the JNA.  When I met him,

Page 3284

 1     he a rank of Colonel and he was Chief of Staff to General Mrksic in

 2     Samarice, 8th Operational Group, HQ.  Upon the formation of the corps, he

 3     was promoted to a corps commander of the 21st Corps in Kordun area.

 4        Q.   In your prior evidence you describe a so-called anti-terrorist

 5     unit of the Kordun Corps.  Can you tell us, was this anti-terrorist unit

 6     present within the corps throughout the time-period that you were there?

 7        A.   Yes, they were from 1992 -- from 1992 to the fall of 1995.  When

 8     I say fall, I meant the fall of RSK.

 9        Q.   In the Milosevic case, on the 29th of October of 2002, on page

10     12323, you said that this anti-terrorist unit carried out "dirty jobs."

11             You then said of this group:

12             "They are used to scare people.  They are used to create

13     disturbances."

14             Why would there have been tasks to scare people or create

15     disturbances?

16        A.   There are a number of reasons for it.  If the things were not

17     tense enough in the area, it will affect the black market, the prices

18     will go down.  So they would create disturbance anywhere along the

19     frontier of the 21st Corps to Croatia and automatically it will close

20     down all the roads leading to these points of sale, if you like.  And the

21     prices will go up within ten days.  That was the reason on the ground.

22     But there were other reasons as well.  One was a purely political reason.

23     Because every time the situation would go little bit, let's call it

24     reasonable, Belgrade didn't like that, because immediately the

25     international organisations would start suggesting that we should start

Page 3285

 1     negotiating with Croatia the situation on the ground.

 2             Now, I don't think that Belgrade liked the idea of any

 3     negotiation.  So that would also now create the situation with a -- well,

 4     we cannot really negotiate because cease-fire agreement was broken here,

 5     and was broken there.  Things like that.

 6        Q.   To your knowledge, who provided the funding for the

 7     anti-terrorist unit of the 21st Corps?  Were they on the payroll of the

 8     21st Corps?

 9        A.   They were not on the payroll of the 21st Corps, but -- according

10     to themselves, Because I knew, I would say, 90 per cent of those boys.

11     There were all young men in their early 20s.  The only thing in common

12     that they had was an extensive police record at that young age.  And they

13     claimed they got paid by the police, Serbia.  They claim, again.  But

14     they did not pay through our -- they did not get paid through our pay

15     master of the 21st Corps.

16        Q.   Mr. Lazarevic, prior to the demobilisation under the Vance Plan,

17     can you describe the relationship between the military forces and the

18     police forces on the ground in the Krajina?

19        A.   In my former country of Yugoslavia there was always antagonism

20     between the police and the military.  Two of the biggest soccer clubs in

21     Belgrade, Partizan and Red Star, one was run by a police, Red Star, and

22     Partizan by army.  And that's just to show you what the really

23     relationship between two was.  There was always kind of a competition;

24     who was going to come up front as bigger and better than the previous

25     one.

Page 3286

 1             Now, in RSK at the time, early 1992, admittedly the army had the

 2     upper hand, simply because of the situation that developed or did not

 3     development at the time gave more importance to the army.  But they were

 4     the one to defend the population in -- in Krajina.  So the police kind of

 5     took a second stand, if you like.

 6        Q.   On page 12330, when you were asked how the Vance Plan affected

 7     the army of the RSK, you said:

 8             "The Vance Plan required total demilitarisation and demobile of

 9     all units within the RSK.  Us being co-signatories of the plan, what we

10     did, we changed the uniform overnight from military olive-green into the

11     police blue and within a very short period of time, I'd say within ten

12     hours, we have repainted all the military vehicles into the blue colour,

13     being -- representing the police."

14             Did this change affect you directly, and if so, how?

15        A.   Well, the only difference that I kind of felt directly, I guess,

16     is I was issued the police ID, I was transformed into a police officer or

17     still within the same area I had the same duties, the officers were still

18     the same, some of them were in police uniforms and some were in civilian.

19     I would attend all the meetings in the Sector North command of the UN

20     dressed as a civilian, really.  For the time being.

21        Q.   On that same page, 12330, you were asked further about the

22     relationship between the army and the police in the RSK, and you said:

23              "Well, at the very beginning, the army had the upper hand in

24     everything that was happening.  When I'm talking about the beginning, I'm

25     talking about 1992.  Later on, with the presence of the special forces

Page 3287

 1     from Serbia, that power has gone into the hands of police."

 2             Can you be more specific about what you meant when you said "with

 3     the presence of the special forces from Serbia, that power had gone into

 4     the hands of the police"?

 5        A.   From the very beginning of creating the RSK, most of the

 6     conscripts came from the population within the RSK.  So the army had

 7     advantage of selecting the best for them, not the police.  So the police,

 8     really, at the beginning, was very shorthanded.  They couldn't do

 9     virtually apart from this daily routine jobs like patrols or

10     investigation, likes that.  After demobilisation, suddenly we are now all

11     in the police.  Now the police could actually keep those who were

12     educated, who were trained, keep them in their own ranks.  After we had

13     mobilisation again, they never returned them to us.  They stayed with the

14     police.

15        Q.   Can you explain a bit more about what you were referring to here

16     when you said the special forces from Serbia?

17        A.   There so many names attributed to this unit that came across

18     that -- well, I'm using "special force."  Maybe they used another name; I

19     don't know.  But the point of the fact is we had a sudden influx of

20     uniformed personnel within the area of the 21st Corps.  They had

21     different uniforms, different shoulder insignias, different badges on

22     their soldiers.  And if you managed to speak to any one of them, you'd

23     realise very clearly that they are coming from Serbia, by the accent they

24     use.  And as I said, it was a sudden influx, at least myself, personally,

25     I was not prepared for that.  And I remember being asked by the military

Page 3288

 1     observers of the UN and the sector commander of the UN, Who are these

 2     people suddenly on ground?  And my instruction was to tell the UN general

 3     on the ground, Well, they are really only passing through.

 4             I had no idea they were going to stop or be involved in anything

 5     until we were asked to leave the Petrova Gora HQ and give it to them.

 6        Q.   How did the increased presence of the special forces from Serbia

 7     affect operations of the 21st Corps?

 8        A.   Affected it in many ways, really.  I think, suddenly, we find

 9     ourselves to have a secondary importance in the area of the 21st Corps.

10     There were areas of the 21st Corps that we were not allowed to go into

11     anymore.  There were parts of the 21st Corps that the military observers

12     wanted to go; we had to prevent them from going there.  I think that the

13     special force from police just didn't want to be known that they are

14     there for the time.

15             MR. BAKRAC: [Interpretation] Your Honours.

16             JUDGE ORIE:  Yes.

17             MR. BAKRAC: [Interpretation] I apologise.  I just waited for the

18     witness to finish.  I would like to ask my colleague and also the Chamber

19     and that would be easier for us to prepare for the cross-examination if

20     we could be told the time-period that this witness is referring to.

21     We're talking about all of this, but we don't know to which time-period

22     this refers.

23             It will be easier for us for the cross-examination, because our

24     time is also limited for -- to be able to explore exactly the time-period

25     he is thinking of.

Page 3289

 1             JUDGE ORIE:  Apparently in relation to the last answer, could you

 2     tell us when this was that you were instructed to tell that they were

 3     just passing by and when they came to the area?

 4             THE WITNESS:  Beginning of 1993.

 5             JUDGE ORIE:  Beginning of 1993.

 6             Please proceed, Ms. Marcus.

 7             MS. MARCUS:

 8        Q.   Now, was this when the 21st Corps HQ moved from Petrova Gora to

 9     Vojnic, as you said before?

10        A.   Correct.

11        Q.   Who was ultimately responsible for events on the ground at this

12     stage, so after the Vance Plan's demobilisation?

13        A.   I'm sorry, I didn't quite understand the question.

14        Q.   Let me repeat.

15             Who was ultimately, to your knowledge, responsible for events on

16     the ground after the demobilisation?

17        A.   Well, apparently it was supposed to be the Army of

18     Republika Srpska Krajina.  But basically all the supplies, the

19     ammunition, and fuel, everything came from Belgrade.  So I can suggest

20     that their needs were supplied in a written form to the HQ of the JNA to

21     Belgrade, and they would forward to us.

22             So if you want the ultimate responsibility, was the JNA.

23        Q.   And again, for time-period, are you talking about before the

24     demobilisation or after the demobilisation?

25        A.   Before and very, very brief time after.  It was taken over by

Page 3290

 1     police.  Because suddenly there was actually a police force on the

 2     ground.

 3             MS. MARCUS:  Your Honours, I'd like to ask the Court Officer to

 4     call up 65 ter 653 which is a chart that was used by the witness,

 5     prepared by the witness, to explain the relationships of different organs

 6     in the Krajina.

 7             Perhaps the B/C/S version might be put on one side for ease of

 8     reference for those who don't speak English.

 9        Q.   Mr. Lazarevic, can you tell us what time-period does this command

10     structure which you prepared, what time-period does it cover?

11        A.   I made -- I made this map in 1999.  But this would cover anything

12     from early 1992 to the -- May 1995.

13             MS. MARCUS:  Your Honours, due to the horizontal nature of the

14     chart, I can either suggest, as Your Honours wish, that we call it up

15     only in English on the screen, full screen; or, again, that we try to use

16     the ELMO for the witness to point.  I don't -- again I don't envisage any

17     marking necessary, but I'm at your disposal.

18             JUDGE ORIE:  I suggest that we use the English.

19             MS. MARCUS:

20        Q.   Can you tell the Court, please, what this chart represents?

21        A.   Basically it represents the power structure of what was happening

22     in RSK in Sector North that I know of.  If you look at it very carefully

23     you can see the squares.  And the whole squares within the scares,

24     they're all interconnected.  So really they're working as one body.  You

25     have your army structure to your right on the screen, going all the way

Page 3291

 1     down to the anti-terrorist unit.  Then have you a line that goes straight

 2     to General Momcilo Perisic at the General HQ.  And they leaned to Pauk

 3     formation of the commander Pauk right there in the middle.  And to the

 4     left you have Arkan forces.  You have SDB of Serbia there with

 5     Mr. Stanisic on top, and Simatovic below, and Colonel Bozovic.  Then you

 6     have a little corner there with Toso Pajic who was the chief of police

 7     who became minister of internal affairs in the RSK.  Next name, you have

 8     a representative of the DB of Serbia, Milos Pajic, who was originally

 9     there before the conflict.  Then you have some RSK politicians which are

10     mostly in the eye of the public at the time.

11        Q.   We're going to elaborate a little bit on some of these

12     relationships as we move forward.

13             I'm going to ask you -- I'm going to refer, again, to some of

14     your prior testimony and ask you to clarify or further explain some of

15     the things you said in -- in connection with these relationships.

16             When you were asked at page 12362 about the box marked SDB

17     Serbia, you were asked to describe the relationships depicted in that

18     part of the diagram.  And your response was:

19             "At the head of the SDB Serbia at the time was

20     Mr. Stanisic, Jovica.  His direct assistants were Frenki, also known as

21     Simatovic or Stamatovic, followed by Colonel Ulemek, Legija, and

22     Colonel Bozovic.  And then within the circle you also see Mr. Toso Pajic

23     was the chief of police and liaison officer of the RSK, and his direct

24     line goes to the SDB Serbia, Mr. Stanisic, and RSK MUP minister of the

25     Internal Affairs, also Milos Pajic, head of state security.  And all

Page 3292

 1     connected directly to Jovica Stanisic."

 2             Can you elaborate specifically on what you meant when you said

 3     that that "all connected directly to Jovica Stanisic"?

 4        A.   All and any police structure on the ground was ultimately

 5     responsible to Mr. Stanisic, including the Pauk commanders which

 6     consisted from three different sources.  I mean, if you look at it,

 7     Major-General Mile Novakovic at the head of the Pauk, and yet he was an

 8     officer of the RSK.  And you had Fikret Abidc who was leading his own

 9     western Bosnia forces.  And with them, you go the line through Arkan

10     Colonel Pejovic, Colonel Sarac, all the way to Colonel Bozovic,

11     Colonel Ulemek, and "Gospodine" Simatovic and "Gospodine" Stanisic.  So

12     they are really all kind of a package deal.

13        Q.   How did you know this to be the case?

14        A.   Well, I was there.  I was present on the ground when these things

15     were happening.

16        Q.   Who was the head of the state security division within the RSK?

17        A.   In my sector was Mr. Milos Pajic, at least he introduced himself

18     as one.

19        Q.   Now, you also described Toso Pajic whose name we see on this

20     chart as well.  What was his role as compared with the role of

21     Milos Pajic?

22        A.   In real terms, I believe that Toso Pajic had more influence than

23     Milos ever had.  Toso Pajic was to become a minister of interiors for the

24     RSK, but he was in a -- he was in constant connection with all these

25     people SDB Serbia which led me to believe that actually he worked for SDB

Page 3293

 1     Serbia before.  And I only got a confirmation when we all moved to

 2     Belgrade to find out he already had an office waiting for me within the

 3     SDB building.  And he had another office within the building which was

 4     considered to be a government in exile were to retain his position as

 5     minister of internal affairs.

 6        Q.   Can you describe what relationship you had with Toso Pajic, if

 7     any?

 8        A.   My relationship with Mr. Pajic as extremely cordial and I liked

 9     the man, really, as a person.  He was well educated.  I believe he was

10     studying in France at one time.  He spoke French fluently which helped us

11     to deal with the French Battalion in the Velika Kladusa area.  And I

12     found him to be a perfect gentleman, so.  And we spent a lot of time

13     together.

14        Q.   On pages 12336 and 12337, you were asked whether, during your

15     daily contacts with Toso Pajic, he told you who he works for.  You

16     stated:

17             "On numerous occasions, he stated that he actually works for

18     Jovica Stanisic who was head of the state security in Serbia proper."

19             Can you elaborate further on your knowledge of Toso Pajic's

20     relationship to Jovica Stanisic?

21        A.   As I have stated before, I had at least five times a week

22     meetings with Mr. Pajic, because simply we were coordinating our work

23     between the military and the police as far as the UN forces on the ground

24     are concerned.  So quite frequently I would be in his office and he would

25     tell me, like, you know, Daddy's on the ground; daddy's coming tomorrow;

Page 3294

 1     he will be here.

 2             And I was led to believe that Daddy is Mr. Stanisic.  And he had

 3     always this little smile on his face when he was talking about Stanisic.

 4             He never -- actually, I have to be honest about it, he never

 5     directly said, I am working for Stanisic.  But he did do all the work.

 6     It has been proven that actually he did work for Stanisic in the end.

 7        Q.   What do you mean when you say "it has been proven that he

 8     actually did work for Stanisic in the end"?

 9        A.   He was relocated to Belgrade.  He went straight to the

10     DB building and he got his office there.  I visited him there.  And in

11     his office, within the building, which was taken over by the government

12     of RSK in exile.

13        Q.   How long did the Serbian DB maintain their presence in the

14     Krajina, to your knowledge?

15        A.   DB Serbia?

16        Q.   Yes.

17        A.   Probably through the last three days of existence of the RSK;

18     they pulled out first.

19        Q.   In your prior evidence and also here today, you've been referring

20     to something called Pauk.  Your prior evidence describes a

21     Pauk Joint Command, "Pauk" meaning "spider."

22             In describing the Pauk Command's establishment, you said during

23     your testimony on page 12352:

24             "Special forces were deployed in our area prior to establishment

25     of a new HQ on the Bosnian side in the vicinity of Velika Kladusa,

Page 3295

 1     code-named Pauk, meaning spider."

 2             Could you clarify what you meant in this case, when you referred

 3     to special forces being deployed?

 4        A.   It does need a bit longer an explanation than a simple sentence

 5     or two.  At the time in 1993 most of us were distracted to revive our

 6     relationship with Fikret Abdic.  There were a few of us that were against

 7     it, but, then again, the order came from Belgrade so we went along with

 8     it.

 9             The situation developed that the forces from Serbia, the special

10     police force in Serbia, got into the area of the 21st Corps and formed a

11     Joint Command of a special forces from Serbia military personnel from the

12     21st Corps, military personnel of Zapadni Bosnia, under Mr. Fikret Abdic.

13     And also the Arkan's Tigers, they were there to.

14             So, the HQ of the Pauk was established approximately 200 yards

15     inside Bosnia.  So they are no longer in Croatia; they're inside Bosnia.

16     Then approximately 6-, to 800 metres away was the second command of the

17     Pauk which was held by Mr. Frenki Simatovic.  So there was a close

18     coordination between what was happening in Pauk and in Bosnia and Pauk in

19     Krajina.

20        Q.   Just for clarification, the second command of the Pauk which was,

21     you say, headed by Mr. Frenki Simatovic, in which territory was that

22     located?

23        A.   In Croatia, if that's easier for people to understand.  But the

24     RSK was a part of Croatia.

25        Q.   Now you were asked on this very point on page 12356 to describe

Page 3296

 1     what, if any, relationship Arkan's group, Arkan's Tigers had with the

 2     Army of the Republic of Serbian Krajina, and your answer was:

 3             "Well, Arkan's" --

 4             MR. JORDASH:  Sorry, could I object to the leading nature of this

 5     question.  This evidence is extremely contentious.  And to lead the

 6     witness to the answer he previously gave, in our submission, is not a

 7     fair way to proceed.  What my learned friend should do is ask the witness

 8     what his evidence is.

 9             JUDGE ORIE:  No.  As a matter of fact, if Ms. Marcus quotes from

10     his previous evidence, she just goes back to what is already in evidence.

11     Isn't it?  That's -- what is on page 12356, I take it that Ms. Marcus

12     wants to give -- to seek follow-up evidence or -- but that's evidence at

13     this moment.  The witness has testified that he has reviewed this and

14     that he would give the same answers, and then, when tendered, these

15     transcripts were admitted into evidence.

16             So to say you're leading the witness, you're taking the witness

17     back to what is already in evidence.

18             MR. JORDASH:  If that's the position, then I withdraw the

19     objection.

20             JUDGE ORIE:  Please proceed, Ms. Marcus.

21             MS. MARCUS:  Thank you, Your Honour.

22        Q.   So in answer to that question --

23             THE INTERPRETER:  The speakers are kindly asked to slow down for

24     the interpretation.

25             MS. MARCUS:  My apologies.

Page 3297

 1        Q.   In answer to that question of what relationship Arkan's group,

 2     Arkan's Tigers had with the Army of the Republic of Serbian Krajina, you

 3     stated:

 4             "Well, Arkan's forces were deployed in the Pauk HQ and were then

 5     put with the MUP of Serbia and the members of the 21st Corps."

 6             Can you show us on your command chart where this joint

 7     Pauk Command is reflected.

 8        A.   Do you mean on the map in front of me?

 9        Q.   Yes, the command chart in front of you.

10        A.   Okay.  Under the heading of Pauk HQ Bosnia,

11     Major-General Milo Novakovic, you have Fikret Abdic.  To the left you

12     have Captain Sarac, Colonel Pejovic, which are the officers of the

13     Arkan's Tigers.  Arkan himself, personally, maybe, I don't know, maybe

14     went once or twice.  He wasn't there throughout, but these people were.

15     And above them you have Colonel Bozovic, Colonel Ulemek, and

16     Frenki Simatovic as members of the DB.  So these are the three sides that

17     make the combined HQ.

18        Q.   Can you explain briefly who Fikret Abdic was?

19        A.   I used to work for the man.  I was employed by Agrokomerc before

20     the conflict.  And he is the man who had the vision of creating Kladusa

21     to be the food maker of the world.  And he did succeed to the one point

22     and something went bad, and he -- you know.  But it was an extremely

23     large company employed most of the people from the region there.  It was

24     a food producing plant.  It was making biscuits and chicken and I don't

25     know what not.  It was making everything; chocolates.  His idea was - if

Page 3298

 1     I can just go back to the elections in Bosnia-Herzegovina at the time -

 2     when he beat Alija Izetbegovic in elections hands down and then refused

 3     to become the first president of the Bosnia, didn't want it, he wanted to

 4     go back and deal with Agrokomerc which he considered to be his child.

 5     When they had decided to make these arrangements with Fikret Abdic to

 6     secure the position of Velika Kladusa and all the plants around it, how

 7     they came about it, I don't know.  But apparently they did make an

 8     agreement.  Hence, the people like Simatovic and Ulemek and Bozovic and

 9     everybody else that was there moved in to secure the sector which was

10     then called western Bosnia.  Basically what you had the case of Muslims

11     fighting the Muslims with aid of special police from Serbia.

12             If you could picture, I don't know if it's possible, really, the

13     21st Corps didn't really like the idea of having behind them 5th Corps.

14     They would rather have these command forces of Fikret Abdic as some of

15     other fighters there and have their lines secured.  So as a military

16     point, from the 21st Corps of getting involved in that.

17             The other one is a pure marketing.  Mr. Abdic had warehouses in

18     Rijeka.  Now, producing his -- whatever he was producing at the time in

19     Velika Kladusa had to be transported to Rijeka then to be shipped all

20     over the world.  But he can only do it going through the AOR of the

21     21st Corps, because we're in position between Croatia and them.  The

22     length of about, as I said before, maybe 17 kilometres.  So you had to

23     secure this passageway to Croatia.

24             So the whole deal was, kind of, working for all sides involved.

25        Q.   Now on page 12422, when you were asked a bit more about the Pauk

Page 3299

 1     Joint Command, and when you became aware of this Joint Command, you

 2     stated:

 3             "It was late 1993 when there was a sudden influx of these men,

 4     uniforms I had never encountered before.  Talking to them in our own

 5     language it was obvious they're not from the area.  Also, it was obvious

 6     they're not a paramilitary unit as far as we're concerned, because they

 7     were given a free passageway and also they were given our old HQ in

 8     Petrova Gora."

 9             Can you explain what you meant when you said that talking to them

10     in your own language it was obvious they were not from the area?

11        A.   There was one officially language of former Yugoslavia called

12     Serbo-Croatian which kind of split into Serbia and then in Croatia.  And

13     you can -- by just listening people speak, you can tell whether they are

14     Croatian or Serbs or which part of Serbia they would come or whether they

15     are from Montenegro.  You take a good example of Colonel Bozovic who had

16     a very thick Montenegrin accent; you cannot miss it.  If you talk to

17     Colonel Ulemek, he spoke Ekavski.  Now people from the area, they all

18     speak Ijkavski.  If they're born in Kordun and lived in Kordun or even if

19     they're Croatian were [indiscernible] behind, so you had a

20     Ekavski/Ijkavski/Chakavski/Ikavski [phoen] -- I mean, you know, there is

21     a multitude of all these little dialects that would separate same nation

22     into smaller groups where they come from.

23        Q.   So which dialect was it that was spoken?

24        A.   Ekavski in the majority of the cases.  If you were talking to the

25     members of the special police, yes, absolutely, Ekavski.  Which I speak

Page 3300

 1     myself.

 2        Q.   And, just for clarification, Ekavski come from what region?

 3        A.   Serbia.  There are probably a multitude of places that also speak

 4     Ekavski.  I mean, when I say Serbia, I'm talking about the general rule.

 5     If you speak Ekavski, you're Serbian from Serbia, end of story.  There

 6     are some situations around Banja Luka when they wanted now to sound more

 7     Serbian then they really are, they are forcing Ekavski in their schools

 8     and in public meetings and everything.  But it's not natural.  They do

 9     speak a version of Serbian which is spoken in Bosnia which is Ijkavski?

10        Q.   Now, what did you mean when you said they were given free

11     passageway?

12        A.   Well, simply they could go where I couldn't.  As a liaison

13     officer.  As I said before, for me to go to Pauk, I need a special pass

14     to go into Bosnia to the Pauk Command, and I had reasons throughout my

15     stay there and in dealing with people that I had to go there.  And

16     Colonel Bulat gave me a permanent pass for Pauk.  So I couldn't just sit

17     in my car and drive straight into Bosnia and say, Hi, boys, here I am.

18     There were check-points.  Before you enter there were check-points there

19     on both sides of the border.  And they would check your documents, and

20     they let you go if you had the pass.  If you didn't have the pass, you

21     can't go through.  You're entering another country and yet nobody asked

22     for passport.

23             MS. MARCUS:  Your Honours, if you would like to take a break,

24     perhaps this is a breaking point.

25             JUDGE ORIE:  If this would be a suitable moment for you, then we

Page 3301

 1     would take the break now.

 2             We will resume at 4.00.

 3                           --- Recess taken at 3.31 p.m.

 4                           --- On resuming at 4.05 p.m.

 5             JUDGE ORIE:  Before we continue, I'd like to briefly raise a

 6     different matter, which is we need a housekeeping session, and the

 7     Chamber is considering to have a housekeeping session either on Thursday

 8     morning or Thursday afternoon.

 9             Now, it is well known that not all accused are always interested

10     in attending housekeeping sessions which is about numbers and about all

11     kind of practicalities.  If Mr. Stanisic would want to attend, then

12     the -- we'll not change the rhythm and then we'll schedule it for the

13     afternoon.  If, however, Mr. Stanisic would waive his right to be present

14     at such a housekeeping session, then we would consider to have it in the

15     morning.  And assuming that it will not take any longer than from 9.00 to

16     12.00 - and I don't have any reason to believe that - then we could

17     schedule it for the morning.

18             I'd like to hear from the parties at a later moment what their

19     preference is.

20             I see already some body language from Mr. Stanisic.

21             MR. JORDASH:  I think Your Honour has his opinion.  He'd rather

22     not attend.  Thank you.

23             JUDGE ORIE:  Yes.  He'd rather not attend.  Yes.

24             Mr. Bakrac.

25             MR. BAKRAC: [Interpretation] My colleague Petrovic and I have

Page 3302

 1     requested from the Secretariat to be issued a ticket so that we may leave

 2     for Serbia on Wednesday in order to conduct some additional

 3     investigations.  And my request is, if that is not possible, to postpone

 4     for this a later date because we have already appointments with some

 5     witnesses that we want to meet with in order to rehash some issues, and I

 6     don't want to go into all the explanations that you are already familiar

 7     with.  But we would really appreciate it if you could move this to a

 8     later date because we already have all the arrangements made, the tickets

 9     prepared, everything arranged with the Registry, and meetings in Serbia

10     with these witnesses.

11             JUDGE ORIE:  Yes.  Would you please be so kind to -- to

12     communicate with Chamber staff days on which you are -- for days on which

13     it is not possible for you to attend due to these kind of commitments,

14     always for the morning or the afternoon of that day, so that we can

15     further consider the matter.

16             Mr. Groome, I think for the Prosecution it is a bit less of a

17     problem because usually there is one or two members of the team always

18     available here in The Hague.

19             MR. GROOME:  I will available, Your Honour, and it's at the

20     convenience of the Chamber and Defence counsel.

21             JUDGE ORIE:  Yes, we will further consider it, and we'll

22     certainly also keep in mind your commitments, Mr. Bakrac, so ...

23             Then, Ms. Marcus, are you ready to continue?

24             MS. MARCUS:  Yes, Your Honour.

25             JUDGE ORIE:  Then please proceed.

Page 3303

 1             MS. MARCUS:  Thank you.

 2        Q.   Mr. Lazarevic, I am going to return to the topic that we left

 3     off, which was the Pauk Joint Command.  I'm going to ask you for some

 4     more elaboration and clarifications in relation to some of your prior

 5     testimony.

 6             You were asked on page 12426 of your prior testimony to give more

 7     detail with respect to the numbers and composition of the different

 8     forces which made up the Pauk Joint Command.  And you replied:

 9             "I believe that the members of the 21st Corps were numbered about

10     400 strong.  I would place MUP to about 200, in Arkans to about 100.  And

11     I have no knowledge of how many of Abdic's forces were there."

12             When you mentioned MUP, to whom were you referring in this

13     portion of your prior evidence?

14        A.   MUP that came from Serbia.

15        Q.   Thank you.  Now, in relation to the MUP from Serbia, in your

16     prior evidence, on the same page, you stated:

17             "That was actually the special force of police from Serbia

18     proper, headed by Colonel Bozovic, Colonel Ulemek, also known as Legija,

19     apparently he was a former Legionnaire, and Frenki Stamatovic.

20     Frenki Stamatovic held the command in Petrova Gora while the others were

21     across the border in Bosnia."

22             Now, how did you know of the involvement of these individuals in

23     the Pauk Joint Command?

24        A.   By virtue of actually visiting the command and meeting them

25     there, I don't know whether they were aware of me being there, but I had

Page 3304

 1     an instance where I had a meeting with Colonel Bozovic in Kladusa itself.

 2     That's how I got my knowledge.

 3        Q.   What can you tell us about the type of weaponry that the

 4     Pauk Command had under its control?

 5        A.   We were actually envious of the MUP from Serbia because they had

 6     a superior weapons than we did.  Example:  Officers that I met carried

 7     Heckler & Koch automatic weapons; I don't know if people know or not.  A

 8     side-weapon was issued to them, Sig Sauer, another very superior gun to

 9     ours that we had which were produced in former Yugoslavia and stored it

10     in different places.  And then when the conflict started, we were issued

11     with that.

12             So the quality of the uniforms were better than ours.

13     Originally, when I saw them first, I thought the NATO forces are here.

14     That's how good their uniforms looked.  And we had uniforms, you know,

15     variety of styles and -- so it was the weapon.

16             JUDGE ORIE:  Could you please repeat the name of the side-arm

17     because I think --

18             THE WITNESS:  Sig Sauer.  It's a Swiss-made handgun.

19             JUDGE ORIE:  Thank you.

20             Please proceed.

21             MS. MARCUS:  Could I ask the Court Officer to call up 65 ter 406,

22     please.

23        Q.   Mr. Lazarevic, you commented at length on this document during

24     your prior evidence.  Could you, here, just briefly for us comment on the

25     significance of this order.

Page 3305

 1        A.   Well, if you -- if you look at the heading of the letter itself,

 2     it says more an order actually than a letter.  And it's done by the

 3     command of the Pauk.  And then in the third line you have all these

 4     people that it was addressed to.  And then have you a command -- a

 5     command of the 21st Corps and 29 Corps.  Tactical Group 2;

 6     Tactical Group 3; the command of Pauk; and command of the ZB which is a

 7     western Bosnia abbreviation, Zapadna Bosna.  So you have all these people

 8     who are heavily involved in information of Pauk and actively taking part

 9     in all the decisions, so whatever is happening on the ground.

10             And then, from 1 to 6, it's listed to send this information back

11     to the Pauk Command, about the number of weapons, the number of

12     ammunition, what the requirements are.  So it's that type of document.

13        Q.   So --

14        A.   And then -- I'm sorry, I was just reading through.  Then in the

15     second-last paragraph you have then this should include also the units of

16     MUP.  Well, in this case, the MUP is MUP Serbia is not -- not MUP

17     Krajina.  And also the units of the RS which is Republika Srpska in

18     Bosnia.

19             JUDGE ORIE:  Could -- could we move the document so that we can

20     follow the -- and apparently the witness was referring to the portion

21     after number 6.  Yes.

22             MS. MARCUS:

23        Q.   So, Mr. Lazarevic, based on your direct knowledge, what do we

24     learn from this order?

25        A.   Well, what we learn from this order is actually the -- the number

Page 3306

 1     of different units that were involved in Pauk.  You got them from Bosnia,

 2     you got them from Serbia, you got them from the Krajina, you got them

 3     from Bosnia.  It's like, I don't know, like an international unit,

 4     really.  And yet they all worked together.  And, by the way, the

 5     signature on the bottom, it is Colonel Bulat's signature, because I have

 6     seen it so many times.

 7        Q.   Thank you.  You'll find me just observing a pause.  I was

 8     reprimanded by our colleagues in the translation booth, so I'm trying to

 9     observe a pause between question and answer.

10             Now, when did you first provide the Office of the Prosecutor with

11     information in relation to the Pauk Joint Command; do you remember?

12        A.   Yes, absolutely.  In 1999.

13             MS. MARCUS:  For the record, I would like to note that

14     Mr. Lazarevic gave his first statement to the Office of the Prosecutor in

15     July of 1999.

16        Q.   Now, on pages 12351 and 12352, you described Toso Pajic showing

17     you a document from Mr. Stanisic regarding cooperation with Fikret Abdic.

18     You explained:

19             "It was a time when, for unknown reason to me, Fikret Abdic and

20     Belgrade have reconciled.  And the letter which arrived from Belgrade not

21     only through Stanisic through Toso Pajic also, through the military

22     channels, was to establish a good, neighbourly cooperation with Abdic's

23     forces, which were actually boarding with the 21st Corps area."

24             What do you know about Mr. Stanisic's role with respect to the

25     Joint Pauk Command?

Page 3307

 1        A.   Well, I don't know nothing personally about Mr. Stanisic's

 2     involvement apart from -- analysing the situation and seeing that his --

 3     the right-hand man or his number two man in command, Frenki Stanisic, is

 4     on the ground.  And also from conversation with Toso Pajic and everybody

 5     else that Mr. Stanisic does come every now and then but it is not like a

 6     24/7 as Mr. Stanisic is -- I mean, sorry, as Mr. Simatovic is.  And I

 7     can't really see that Frenki Simatovic has carried all this on his own,

 8     without really informing Mr. Stanisic or being directed by Mr. Stanisic

 9     in this instance.

10        Q.   What was your personal position on this issue of cooperation with

11     Abdic's forces?

12        A.   My personal condition was, no; adamant no.  Because after that

13     point in time in fighting the forces of Fikret Abdic, including the the

14     5th Corps, Because they were the members of the 5th Corps.  So they were

15     the enemies officially.  And my knowledge -- some other officers were

16     also against this cooperation.

17        Q.   Are you familiar with a man named Colonel Raja Bozovic?

18        A.   Yes, I think I mentioned him before.  He is a Colonel; he is,

19     obviously, of Montenegrin origin because he really, really have this

20     thick Montenegrin accent.  And I met him in -- in a huge store in --

21     where his command was or part of his command in Velika Kladusa when I

22     needed to see him about some exchange of -- of soldiers which have died

23     in combat for exchange.  And, might I add, he was very unpleasant.  If I

24     can quote him, we were asking for a dead and he said, Well, if you need

25     dead, you go and kill him yourself, find him yourself.  But he's not

Page 3308

 1     going to offer any.

 2        Q.   In relation to Colonel Bozovic on page --

 3             JUDGE ORIE:  Mr. Lazarevic, part of what you say is just lost

 4     because you speak too quickly.

 5             THE WITNESS:  I'm sorry.

 6             JUDGE ORIE:  When you said -- you quoted him that -- if you would

 7     ask for bodies that you would say, I'm not going provide them; you have

 8     to kill them yourself.  That's what I heard from you, but it does not

 9     appear on the transcript.  If you want your testimony to be reflected on

10     the transcript, I again urge you to slow down.

11             Please proceed.

12             THE WITNESS:  Thank you.

13             MS. MARCUS:

14        Q.   On page 12443 of your Milosevic testimony, you were explaining

15     about this exchange of bodies to which it seems you've just referred.

16     And you stated that at one point Colonel Mlado Karan, had asked you to go

17     to the headquarters, and you said:

18             "He directed me to go to Pauk Command and speak to

19     Colonel Bozovic and Colonel Pejovic, one was the MUP Serbia, Bozovic was

20     MUP Serbia, and Pejovic was Arkan's Tigers.  See if they can assist."

21             You have just mentioned the circumstances of this meeting.  Can

22     you elaborate briefly?  What was the circumstance of that meeting to

23     which you're referring?

24        A.   Through the international mediation, we were offered to exchange

25     the deads with the 5th corps, apparently they claim to have 100 dead

Page 3309

 1     Serbian soldiers there and they requested 100 Muslim soldiers for

 2     exchange.  At that time, the arrangement we had was one for one.  So I

 3     had a problem finding 100.  So I looked all over the place; I went to

 4     local police stations -- I don't know.  They might have a -- remembering

 5     there was one buried here and one buried there; we go and dig them out.

 6             Anyway, to make a long story short, we were short people, or

 7     short bodies.  So when I was discussing this with Colonel Mlado Karan who

 8     is in charge of the internal security of the 21st Corps, he suggested I

 9     go and see Bozovic and Pejovic, both colonels, since they had been

10     involved in heavy fighting against the 5th Corps, the Bosnian 5th Corps.

11     And that's what I did.  And, unfortunately, Colonel Bozovic didn't offer

12     any assistant in that respect.  However, Colonel Pejovic did.

13        Q.   Do you know what Colonel Bozovic's reporting line was?

14        A.   Directly to Mr. Stanisic, or through Frenki.

15        Q.   You mentioned earlier, briefly, about Arkan.  Can you elaborate?

16     Is there anything else you know about Arkan and his role in the

17     Pauk Joint Command?

18             JUDGE ORIE:  Let me -- you asked, Do you know what

19     Colonel Bozovic's reporting line was.  And I understood the answer of the

20     witness to be a request for clarification of that question.  Or have I

21     misunderstood you?

22             You said:  Directly to Mr. Stanisic or through Frenki.

23             Did you want to have more details as far as the question was

24     concerned, or did you give an answer saying that he was reporting

25     directly to Mr. Stanisic, or, as the case may have been, through

Page 3310

 1     Mr. Simatovic?

 2             THE WITNESS:  Former is correct, meaning he was reporting

 3     directly to his superior in command within Pauk, and that was referring

 4     to Simatovic.  And Frenki Simatovic continued his reporting line to

 5     Mr. Stanisic.

 6             JUDGE ORIE:  So you were not seeking further explanation, but you

 7     were answering the question?

 8             THE WITNESS:  Yes.

 9             JUDGE ORIE:  Then I misunderstood you.

10             Please proceed, Ms. Marcus.

11             MS. MARCUS:  Thank you, Your Honour.

12        Q.   Mr. Lazarevic, can you explain how you know about Bozovic's

13     reporting line.

14        A.   Well, I had opportunity to see him on both sides of the border in

15     Bosnia and in Krajina.  And I have seen him, well, not very often, but

16     I'd say maybe two, three times a month at the headquarters of the

17     21st Corps.  And he is a remarkable person when you see him.  That would

18     be the only officer I have ever seen to carry a sawn-off shotgun at the

19     waist.

20        Q.   Now, to return to the matter of Arkan, what is your direct

21     knowledge, if any, of Arkan and his involvement in the Pauk Joint

22     Command?

23        A.   To my knowledge, Arkan was just supplying the additional --

24     additional soldiers or additional fighters to the Pauk Command.  Arkan

25     wasn't there himself personally, but he had his people on the ground.

Page 3311

 1     And if I know Arkan from his previous involvements, it's got to be the

 2     money, otherwise he wouldn't be there.

 3        Q.   Do you know anything about Arkan's role in RSK before Pauk?

 4        A.   I only met him once, personally, and it was the meeting in hotel

 5     Topusko probably very early in 1992, just prior to arrival of UN forces.

 6             There were meetings of high-ranking officer of the JNA in the

 7     hotel.  And they were trying to figure out what is the best way and

 8     fastest way to somehow normalise the life in the area.  And

 9     Zeljko Raznjatovic busted in on this meeting and really abused the hell

10     out of these people there.  They were all generals who were very close to

11     retirement.  You know, they were not really, you know, a fighting unit,

12     if you like.  But -- and you can see on their faces they are really

13     afraid of him.

14        Q.   Do you know who Arkan was answerable to?

15        A.   To my knowledge, to the DB of Serbia, even before the conflict.

16     Are we talking about the same man that the half of the Interpol in Europe

17     was looking for?  And he had a safe-haven in former Yugoslavia protected

18     by the state security?  The man is a known criminal, gangster.  He was

19     charged with bank robberies, he was charged with attempted murders,

20     charged with escaping from prisons in Europe.  That is not my kind of

21     hero, I'm sorry.

22        Q.   On page 1 --

23             JUDGE ORIE:  Ms. Marcus, could we ask the witness to clearly

24     distinguish between who Arkan was answerable to, where his answer was

25     primarily focussing on by whom he was protected.  Even if I'm protected

Page 3312

 1     by someone, it doesn't necessarily mean that I'm answerable to that same

 2     person.

 3             Could you make that distinction and also explain to us what the

 4     basis of your knowledge is for -- for being answerable to, rather than

 5     being protected by.

 6             THE WITNESS:  If I may, Your Honour, I will give you a little

 7     known fact that I haven't mentioned this in this Court before.  But there

 8     was an incident when Arkan was transporting weapon.  And in the area of

 9     Bosnia, in a car.  Him and a couple of his boys had a trunk full of

10     weapons.  They were stopped by police, searched, and arrested.  This is

11     just about the beginning of the conflict in Croatia.  He was taken to

12     Zagreb.  And very shortly after, the people from Serbia state security

13     and people from Croatia state security decided they were going to release

14     him and not charge him.

15             So he was working at the time both sides of the borders, for

16     Serbian DB and the Croatian DB.

17             JUDGE ORIE:  Could you give us a time-frame for this incident.

18             THE WITNESS:  October 1991.  But that is a wild guess now,

19     really.

20             JUDGE ORIE:  Let's refrain --

21             THE WITNESS:  [Overlapping speakers] ... it was in the newspaper,

22     it was on TV.  So it is not something that I've discovered or come up by

23     chance or ...

24             JUDGE ORIE:  Please proceed, Ms. Marcus.

25             MS. MARCUS:  Thank you, Your Honour.

Page 3313

 1        Q.   On page 12359 of your Milosevic testimony, you describe a meeting

 2     you were going to attend with the RSK minister of defence in

 3     UN Sector East.  And you describe a chance meeting between a man named

 4     Stojkovic [phoen], aka Badza, and Arkan.

 5             Do you recall this event?

 6        A.   Yes, I do.  I was a part of the team that went to Sector East

 7     with Admiral Rakic who was appointed the minister of defence for RSK,

 8     even though we didn't have the navy.  I always finds that amusing.

 9     Admiral Rakic.

10             Anyway, as we were driving through Sector East --

11             MR. JORDASH:  Sorry to leap up.

12             JUDGE ORIE:  Yes.

13             MR. JORDASH:  I can see the interpreters throwing up a hand in --

14             JUDGE ORIE:  Yes.  I fully can imagine that they do --

15             Again, Mr. Lazarevic --

16             THE WITNESS:  Guilty as charged.

17             Okay.  I will try to slow down.

18             As I said, we were going to Sector East with the Admiral Rakic

19     who was the minister of defence of the RSK, and I was in the car with

20     him.  There was a driver, Minister Rakic, and myself.  The reason I

21     happened to be there was purely for make it possible for Admiral Rakic to

22     speak to the sector commander of Sector East.

23             JUDGE ORIE:  Yes.

24             THE WITNESS:  And as we were driving through, passing by the

25     petrol station which incorporated, like, a little restaurant with it,

Page 3314

 1     Rakic said, No, stop the car, stop the car.  There's Arkan over there.

 2     So we stopped the car.  I didn't get out of the car.  He went in and he

 3     hugged Arkan and he hugged another man with him.  And I was told by

 4     Minister Rakic that that was Badza, which I had no idea who he is.  Later

 5     on, when I asked, they told me he is one high-ranking police officer from

 6     Serbia there.

 7             MS. MARCUS:

 8        Q.   Mr. Lazarevic, what is your familiarity with Captain Dragan?

 9        A.   Captain Dragan, I haven't met personally, ever.  All I know is

10     what I heard about him.

11             There was this myth going around that he was a superior in

12     everything he does.  So he was engaged to train the special police of

13     RSK, and they would be wearing red berets so they can be recognised.  He

14     was, at the time, in the Sector South.  And then, within a year, he just

15     kind of dissolved in the air.  And the last time I saw him was during the

16     Saint Vitus Parade in Slunj, which is about like a three and a half years

17     later.

18             Though did I read about him, I have to admit.

19        Q.   Can you tell the Court what your knowledge is of a man named

20     Mile Novakovic?

21        A.   Mile Novakovic is a JNA colonel who became in a very short period

22     of time a two-star general.  So from lieutenant-colonel to two-star

23     general, he made a very quick progress through there.  And he was in

24     command of Pauk, officially.

25        Q.   Now, you just mentioned the Saint Vitus Day parade in Slunj, so

Page 3315

 1     were you present during that celebration of the 28th of June, 1995?

 2        A.   Yes, I have been there, during the parade.

 3             MS. MARCUS:  Now, I'm going ask our Case Manager to play a clip

 4     from the recording, the video-tape of that celebration of

 5     Saint Vitus Day.

 6             The clip is from 65 ter 267, which is a segment from the full

 7     video.  The full video being 65 ter 597, which is a related exhibit from

 8     the Milosevic case.  Now the clip in 627 is from 29 seconds to the end.

 9     And that is -- corresponds to 1 hour, 32 minutes, 35 seconds; to

10     1 hour, 34 minutes from 65 ter 597.

11             JUDGE ORIE:  Ms. Marcus, I'll just briefly jump in here because

12     Madam Registrar has assigned numbers to your list of documents.  And in

13     order to avoid that we are talking about 65 ter numbers rather than to --

14     about exhibit numbers ...

15             Madam Registrar, could you tell us, we have a list of

16     24 associated exhibits.  The numbers for those associates exhibits

17     would be?

18             THE REGISTRAR:  The numbers would be Exhibit P225 through

19     Exhibit P248.  And the 65 ter the counsel is referring to is not in the

20     92 ter package, I understand.

21             JUDGE ORIE:  I think she said it was, but I may have

22     misunderstood her.

23             MS. MARCUS:  65 -- the 65 ter 627 is a segment of the 65 ter 597,

24     which is in the -- in the exhibit list.

25             JUDGE ORIE:  Yes.  597 would -- in this system, would be 2 --

Page 3316

 1     P238.  It's an excerpt from -- if I did not make any mistake ...

 2             Yes, as far as I can see the sequence on the list, it is part of

 3     P238, video of Saint Vitus Day celebration on 28th June, 1995.

 4             Let's look at the video.

 5             MS. MARCUS:  Thank you, Your Honour.

 6        Q.   Now, Mr. Lazarevic, as we watch the video, please explain to us

 7     what you can tell us about what is taking place.  And then afterwards I

 8     will show you two stills taken from this video and ask to you identify

 9     those whom you can recognise in those stills.

10                           [Video-clip played]

11             THE WITNESS:  The day that I attended was the big parade to

12     celebrate the Saint Vitus Day which was also the day that the battle of

13     Kosovo was waged some 500 years ago.  And it's a very special moment in

14     the Serbian history which kind of beats me why would you celebrate your

15     worse defeat ever?  But something to do with the mentality, I guess.

16             Now, the [indiscernible] was set up that in the middle within the

17     military components of the parade and to the left where the guests of --

18     excuse me, the guests of the command and to the left were actually the

19     international -- members of the international community, some military

20     observers, officers from the UN Sector North, which I was leading because

21     they were called in as guests.

22             JUDGE ORIE:  One ...

23             MS. MARCUS:  Could you explain to the --

24             JUDGE ORIE:  One -- one second.

25             MS. MARCUS:  Sorry, sir.

Page 3317

 1             JUDGE ORIE:  We've -- we have now looked at this video.  There

 2     was text under it, apparently transcribing what was said.  Since the

 3     witness was speaking at the same time, this text, I understand, is of no

 4     significance for this piece of evidence, or would it have any

 5     significance?

 6             MS. MARCUS:  If I understand correctly, Your Honour, the text is

 7     a narration from a video, the recording, so it was more important to us,

 8     Your Honours, what the witness would say about it, than the text.

 9             JUDGE ORIE:  Yes, I see it is of more importance.  But since it

10     appears, I think it should be clear for reasons of transparency that we

11     have not listened, neither was the text translated to us, so, therefore,

12     what is in evidence is the video without the textual part of it, and so

13     the pictures, the footage, as we saw it, and what the witness told us

14     about it.

15             That's what is in evidence.

16             And if I say "it is in evidence," I was anticipating on the

17     decision of the Chamber, that is, that P225 up to and including P248 are

18     admitted into evidence.

19             Please proceed.

20             MS. MARCUS:  Thank you, Your Honour.

21        Q.   Now, can you explain to us, Mr. Lazarevic, what we saw as we

22     watched that video-clip?

23        A.   What we saw?  The beginning of the parade.  Which happened

24     [B/C/S spoken] or Saint Vitus Day, which was organised in the area of

25     Slunj, basically was a PR stuff.  You got a lot of guests, lot of

Page 3318

 1     officers from different countries, and we are going to show you how

 2     strong we are.  The weapons shown there from the lunar rockets was

 3     borrowed from a neighbouring Republika Srpska and it was returned to them

 4     the following day.  Nobody even tried to hide it.  But you could notice

 5     on the trucks that were going in the parade that some them would carry

 6     the number plates from our own corps, and some of them wouldn't have any

 7     number plates whatsoever, making sure that nobody really can trace them.

 8     Which, since we allowed the TV crews to be there, we wanted actually

 9     everybody to see it.

10             JUDGE ORIE:  Mr. -- Mr. --

11             Please proceed.

12             MS. MARCUS:  Your Honours --

13             JUDGE ORIE:  I'm now and then, apart from transcribers,

14     interpreters also have great difficulties in following your speed of

15     speech.

16             Please proceed, slowly.

17             MS. MARCUS:  Thank you, Your Honour.

18             With your leave, Your Honour, in light of the Chamber's comment

19     and the witness's comment, with your leave we could replay that without

20     the witness's commentary.  I think the questioning will be more fluid

21     thereafter.  With your leave, Your Honour.

22             JUDGE ORIE:  And would you like to us pay attention to the text

23     as well?

24             MS. MARCUS:  I that I would be of assistance, yes.  Thank you.

25             JUDGE ORIE:  Yes.  Then we'll replay the video, and we'll receive

Page 3319

 1     the text transcribed and translated to us.  And Mr. Lazarevic, therefore

 2     you are supposed not to say a word about it at this moment.

 3             Take a breath.

 4             Let's, again, listen to the video and look at the video.

 5             Have you provided the transcript to the booth?

 6             MS. MARCUS:  Yes, Your Honour.

 7             JUDGE ORIE:  Yes.

 8             Please proceed.

 9                           [Video-clip played]

10             THE INTERPRETER: [Voiceover] "This is how the ceremonial Vidovdan

11     parade of troops, which had been prepared for several days, was over in

12     the best way possible.  We had the opportunity to see our mainstays, the

13     mainstays of our children's serene sleep, the mainstays of our future and

14     our perspective.  We had the opportunity to see that we have something

15     more to hope for, even more than we had so far.  We also have a modernly

16     equipped, well-trained unit, which is composed of hardened and

17     experienced soldiers.  And all those who are here today at Slunj, and all

18     of our honoured spectators who had the opportunity to follow our direct

19     TV coverage from the Slunj parade ground, I'm convinced that

20     you will ..."

21             MS. MARCUS:

22        Q.   Mr. Lazarevic, we saw a line-up and an introduction of

23     individuals.  Can you describe, in that particular clip, what we were

24     looking at?

25        A.   Are we going to see the clip again, or you just want me to tell

Page 3320

 1     what happened?

 2             Well, in the clip itself, actually, you see just prior to the

 3     beginning of parade, you have president at the time Mr. Milan Martic

 4     being introduced by General Mrksic and by General Novakovic, the people

 5     in front of him on the parade ground there.

 6             If you look at it again, you could see General Mrksic,

 7     President Martic, and General Novakovic getting introduced to the people

 8     of the Pauk Command.  First, on the left, would be Colonel Bozovic.  Next

 9     to him was Colonel Ulemek, Legija, and there's a number of officers from

10     western Bosnia that I'm not familiar with.

11             MS. MARCUS:  Could I ask the Court Officer, please, to call up a

12     still from this video, which is 65 ter 3223, which is taken from the

13     48-second mark of that particular clip.

14             And if the Court Usher could provide Mr. Lazarevic with a pen to

15     mark the clip, the still, that would be helpful.

16             I'm sorry, I'm advised it's 5223, not 3223.  Sorry.

17        A.   Right there in the middle, you can see President Martic.  Shall I

18     put Martic on the screen?

19        Q.   Before you mark --

20             JUDGE ORIE:  One second.  One second.  I see on other screens

21     what I'm supposed to see on my screen as well, but which is not on my

22     screen.  And there it is.

23             Please proceed.  Could you please repeat your question so the

24     witness can answer it.

25             MS. MARCUS:  Yes.  Before the witness -- before I ask the witness

Page 3321

 1     a question, I wanted to seek your leave to tender this still into

 2     evidence unmarked so that other witnesses might also mark it separately.

 3             JUDGE ORIE:  Madam Registrar, a number for this still, still

 4     unmarked.

 5             THE REGISTRAR:  Exhibit P249, Your Honours.

 6             JUDGE ORIE:  May I take it that there's no objection against it,

 7     because that wouldn't make much sense, as a matter of fact.

 8             P249 is admitted into evidence.

 9             Please proceed.

10             MS. MARCUS:  Thank you, Your Honour.

11        Q.   Now, Mr. Lazarevic, could you tell us whom we see in this still,

12     and we'll mark them one by one.

13             You said, just before, you can see President Martic.  Can you

14     take your pen and write Martic, where you see Martic, please.

15        A.   Right there in the middle.  That is Martic with his hand

16     extended.  To the left on your screen you see the silhouette there, but

17     in actual footage of the video, you can see this is a General Novakovic

18     there.  I put just G and N.

19             Right there on the top of Mr. Martic is General Mrksic.

20     General Mrksic.

21             The gentleman right there, this is --

22        Q.   Just to interrupt you, sir.

23             MS. MARCUS:  For the record, the General Novakovic has been

24     marked with GN, for Novakovic; and General Mrksic has been marked General

25     with GM for Mrksic.

Page 3322

 1             Continue, please, sir.

 2             THE WITNESS:  To the right, this young gentleman here, that's

 3     Colonel Ulemek.  So I'll just put Colonel U.  Behind him, you can only

 4     see the part of the face, that would be Colonel Bozovic.  I'll put

 5     Colonel B.

 6             Now, this gentleman here, I have no idea who he is.  Down there.

 7        Q.   For the record, when you said have you no idea who he is, you're

 8     talking about the gentleman to the far extreme right on the photo.  Is

 9     that correct?

10        A.   Right.  The one with the mustache and the beret.

11        Q.   Could you please now sign your name on the bottom of the photo.

12             MS. MARCUS:  And with that, Your Honours, we would like to tender

13     this marked photograph into evidence, with your leave.

14             JUDGE ORIE:  Madam Registrar, the number would be ...

15             THE REGISTRAR:  Exhibit P250 Your Honours.

16             JUDGE ORIE:  P250, no objections.

17             Therefore, P250 is admitted into evidence.

18             Please proceed.

19             MS. MARCUS:  Could the Court Officer please call up 65 ter 53,

20     which is a still taken from later on in this video which is now admitted

21     as Exhibit P238.

22        Q.   Sir, can you confirm that that is your handwriting on this photo?

23        A.   Yes, it is.

24        Q.   Now I'm going to ask our Case Manager, Mr. Laugel, to play a clip

25     from Exhibit P61 -- sorry, yes, Exhibit 61 - from minutes 43:15 to 43:51.

Page 3323

 1     And after we watch this very brief clip, Mr. Lazarevic, I will ask you to

 2     tell us if you recognise anyone in the clip.

 3             JUDGE ORIE:  Any text on the clip, Ms. Marcus?

 4             MS. MARCUS:  Yes, I believe, there is, Your Honour.

 5             JUDGE ORIE:  And are we supposed to hear the translation?

 6     Is that ...

 7             MS. MARCUS:  Yes, please, Your Honour.

 8             JUDGE ORIE:  Yes.

 9             Let's look at and listen to the video.

10                           [Video-clip played]

11             THE INTERPRETER: [Voiceover] "I'm proud to present you with ...

12     I'm proud to present you with this award."

13             MS. MARCUS:

14        Q.   Mr. Lazarevic, did you recognise anyone in that video-clip?

15        A.   Yes, I have.  Mr. Stanisic giving an award to Captain Dragan, a

16     civilian.  I mean, he's dressed as a civilian, not in uniform.

17        Q.   I'm going to ask you just a few more clarifications and

18     elaborations in relation to your prior evidence.

19             On page 12350, you were asked whether you became aware that

20     Mr. Jovica Stanisic was present in the RSK when you were there.  In

21     answer, you stated:

22             "Yes, I think I had the opportunity to meet the gentleman on two

23     or three rather informal occasions in Knin."

24             You were then asked if you were aware that he was present in

25     relation to a dispute between Mr. Babic and Mr. Martic, and you replied:

Page 3324

 1             "Yes, indeed.  And I believe that particular meeting with

 2     Mr. Stanisic came from Belgrade carrying a specific message from

 3     Mr. Slobodan Milosevic to Mr. Babic."

 4             Can you explain how you became aware of that event?

 5        A.   The first time I met Mr. Stanisic was during the -- or after the

 6     Assembly session of declaring the RSK.  We had a joint dinner.  So this

 7     is the first time I met him.

 8             Admittedly, I have seen him before, I knew about him, but I have

 9     never met him.  There was a bit of a turmoil going on, on political scene

10     in the RSK at the time.  Belgrade or Milosevic, if you like, did not like

11     the idea of Babic remaining a president of the RSK.  Apparently Babic did

12     not follow to the fullest the ideas of Mr. Milosevic how things should be

13     run.  Somehow he believed that Krajina is his, he can do whatever he

14     wants, he is the president.  So he had to be replaced.  And he got

15     replaced by Milan Martic, a police officer.  And since he refused to step

16     down, in the end, he was forced to step down.  And Mr. Stanisic came to

17     tell him that.

18        Q.   Can you tell us who invited to you that event?

19        A.   I think the minister of information of RSK with

20     Colonel Kosta Novakovic.

21        Q.   You were then asked, on page 12350, whether you were aware of

22     other times that Mr. Stanisic was present in the Krajina from your

23     conversations with other officers.

24             To that question, you replied that Toso Pajic would tell you that

25     Stanisic had been --

Page 3325

 1             THE INTERPRETER:  Thank you for slowing down.

 2             MS. MARCUS:  Sorry.

 3        Q.   To that question, you replied that Toso Pajic would tell you that

 4     Stanisic had been there or was coming.  Although you were not in the

 5     police and thus you were not present at those other meetings, you said:

 6             "I'm pretty certain that Mr. Stanisic did come reasonably

 7     frequently to Krajina."

 8             Can you elaborate on what you meant when you said that you were

 9     "pretty certain that Mr. Stanisic came reasonably frequently to Krajina"?

10        A.   My relationship with Mr. Toso Pajic was a very close one.  We met

11     at least five times a week.  If not more, five times at least.  And

12     sometimes he would offer me information which I didn't even ask for.  But

13     that's how close we were.  I don't know, he believed that I should know,

14     maybe, even though I was a member of the police force.

15             So if I would happen to be in his office and he would say that he

16     has to take a call from Belgrade from Mr. Stanisic about something, and

17     then I would ask him, Do you want me to leave the office?  No, no, it's

18     okay.  Stay.  And then he would address him as daddy -- which, kind of --

19     I find it rather unusual that your superior is called daddy.  I don't

20     know.

21             Any way, those situations were quite a few in three half years.

22     So if he wasn't on the ground, I'm pretty sure he had a constant contact

23     with the people on the ground, whether it is Pauk Command or whether it

24     is Toso Pajic in area of the 21st Corps.

25        Q.   In relation --

Page 3326

 1             JUDGE ORIE:  One ...

 2             MS. MARCUS:

 3        Q.   In relation to Mr. Stanisic's presence on the ground in the RSK

 4     in your area of responsibility, you stated in your prior evidence on page

 5     12351:

 6             "I know at the beginning those visits were more frequent.  I

 7     think probably due to organisational problems than anything else.  At a

 8     later stage, Mr. Stanisic had his deputies or his right hands, or

 9     whatever you want to call them, who were actually present on a daily

10     basis within the RSK."

11             Who were these deputies or right hands to whom you were referring

12     who were present on a daily basis within the RSK?

13        A.   Mr. Frenki Simatovic would be one and Rajo Bozovic would be the

14     other.  Rajo Bozovic is Colonel.

15        Q.   With the -- with respect to the second accused, Frenki Simatovic,

16     you referred in your prior evidence to the name Stamatovic or Simatovic

17     alternatively.  Is this in fact the same person or is it two different

18     people?

19        A.   Well, 90 per cent of population in -- in Krajina knew him as

20     Frenki.  But some of the people would pronounce his surname as Simatovic

21     and some would say Stamatovic.  But it is referring to the same person.

22        Q.   When asked if you had personal knowledge of him, you stated, on

23     page 12352:

24             "He was actually in possession of our former HQ in Petrova Gora.

25     That's when he formed his own HQ with the special forces of the police

Page 3327

 1     from Serbia."

 2             What did you mean when you said "his own HQ"?

 3        A.   I meant -- I meant Pauk.

 4        Q.   And how did you know that he had formed his own HQ with the

 5     special forces of the police from Serbia?

 6        A.   You have to understand that if you live in an area of

 7     responsibility which is only about 70 kilometres long and 15 kilometres

 8     wide not many things can happen that are you not aware of, especially if

 9     you are in a position to be -- I'm sorry, it says 730 kilometres; it's

10     70 kilometres.  I'm looking at the screen here.

11             Not many things can happen that are you not aware of or you

12     haven't been told by others.  And yet we are talking, here, maybe about,

13     I don't know, five square miles.

14             So first, as the 21st Corps, we were told to move out, that the

15     MUP Serbia is coming to take over that command post officially.  Later

16     on, we discovered that a part of the command is going across the border

17     into Bosnia to complete the HQ of Pauk.  So if you look at the map or --

18     you will see that HQ which is -- the HQ of Pauk ...

19             HQ of Pauk in Bosnia is only about 200 metres inside Bosnia, and

20     the rest of the Pauk Command is in Petrova Gora which is in Krajina,

21     about let's say 700 metres away.  So between two commands, there's only

22     about 800 to 900 metres in two countries.

23        Q.   Was there a particular insignia worn by these special forces from

24     Serbia?

25        A.   They had a shoulder patch which depicted a drawn upside down

Page 3328

 1     sword with a Serbian flag on it.

 2        Q.   Did you have occasion to see that emblem with your own eyes?

 3        A.   Frequently.

 4             MS. MARCUS:  Could the Court Officer please call up 65 --

 5             JUDGE ORIE:  No, no.

 6             Please proceed.

 7             MS. MARCUS:  Could the Court Officer please call up 65 ter 49.

 8             I'm sorry, I'm waiting for it on my screen.  Does everyone else,

 9     see it?

10        Q.   Can you identify what we see in this photo?

11        A.   Actually, if you look at the side, you see it better than if you

12     like directly at it.  There is that drawn sword, you got those inverted

13     SSS on the side of it, and on the top is the Serbian flag.

14        Q.   Is this the patch to which you previously referred as the emblem

15     worn by the special forces from Serbia in RSK?

16        A.   Yes.

17             MS. MARCUS:  Thank you, Your Honours.  I have no further

18     questions.

19             JUDGE ORIE:  Thank you, Ms. Marcus.

20             Will it be the Stanisic Defence or the Simatovic Defence who will

21     cross-examine the witness first?

22             MR. JORDASH:  The Stanisic Defence, Your Honour.

23             JUDGE ORIE:  Mr. Jordash, I would like to continue for another

24     12 minutes, approximately, until the break.

25             Mr. Lazarevic, you will now be cross-examined by Mr. Jordash.

Page 3329

 1     Mr. Jordash is counsel for Mr. Stanisic.

 2             Mr. Jordash is also making some pauses between questions and

 3     answers, as you will do as well.

 4             THE WITNESS:  I will try to.

 5                           Cross-examination by Mr. Jordash:

 6             MR. JORDASH:  Sorry.

 7             THE INTERPRETER:  Could counsel use the microphone with the long

 8     stem, to the right of him?  Thank you.

 9             MR. JORDASH:

10        Q.   Good afternoon, Mr. Witness.

11        A.   Good afternoon, sir.

12        Q.   You spoke earlier today about the special police force in Serbia

13     getting into the area of the 21st Corps.  They came into that area at the

14     time, is this right, when the 21st Corps moved from Petrova Gora.  Were

15     those two events simultaneous?

16        A.   No, I wouldn't call it simultaneous.  Most of the -- or some of

17     the members of the MUP Serbia came earlier on.

18        Q.   Who came earlier on and how many of them --

19        A.   Some of the members.  To understand the situation, on the roads

20     straight through the area of the 21st Corps, there were check-points,

21     roads blocks.  And at one stage, I can't pin-point the date, we were told

22     they will be coming, the trucks with supplies and manpower, that we are

23     not to stop as they come to the check-points.

24        Q.   So members of the MUP Serbia came and started manning

25     check-points in preparation -- no.

Page 3330

 1        A.   No, misunderstanding.  We, as the RSK, had the check-points, some

 2     held by police.  But to go to Petrova Gora from whatever direction you're

 3     coming in, you have to go through the check-points along the roads

 4     somewhere.  And we were told there will be members of the MUP Serbia

 5     coming through and to let them go without stopping or checking what they

 6     carry.

 7        Q.   So the members were coming through on the way to Petrova Gora; is

 8     that correct?

 9        A.   Probably.

10        Q.   Well, do you know, or do you not?

11        A.   I wasn't present when the very first one showed up.  I'm aware of

12     them moving into the HQ on Petrova Gora, setting it up.  I am aware the

13     members of the MUP Serbia coming for supplies in Topusko where I was,

14     because the store where would they come is about 50 yards away from me.

15     So I recognised the uniform.

16        Q.   So their presence was, as you saw it, or heard about it, in

17     preparation for the takeover of the Petrova Gora site?

18        A.   More than likely, yes.

19        Q.   And are we talking days or weeks or months before they actually

20     moved into that site?

21        A.   Between the times when we moved out and dislocated -- dislocated.

22     Displaced the HQ of the 21st Corps, and the time they took over, I don't

23     think it is more than a month, in total.

24        Q.   So approximately -- should we say approximately a month?

25        A.   Yeah.

Page 3331

 1        Q.   Before you moved from Petrova Gora, the special forces of the MUP

 2     of Serbia moved into the Krajina, Republika Srpska Krajina district?

 3        A.   Okay.  Let's try to sort this out.  We moved out of the

 4     Petrova Gora compound which is the old military compound.  We moved out

 5     into new HQ.  MUP Serbia started moving in.  The moment they started

 6     moving in, the whole area was off limits to us.  I couldn't go there or

 7     military observers or anybody.

 8        Q.   We're talking about a month from when the members of the MUP

 9     Serbia coming into the district?

10        A.   Yes.

11        Q.   And then slowly moving into Petrova Gora, and you, 21st Corps,

12     moving out?

13             JUDGE ORIE:  Let me see whether there is any confusion.

14             One month.  Is that one month after you moved out until they

15     moved in; or did they move in and did you move out only a month later?

16     Which of the two?

17             THE WITNESS:  We moved out.  Within the month, they were in.

18             JUDGE ORIE:  Yes, Mr. Jordash, from your questions it seems that

19     you had understood perhaps the previous answer in a different way than I

20     did.

21             MR. JORDASH:  Your Honour, yes.

22        Q.   So the whole process from the first Serbian MUP members coming

23     into the Republika Srpska Krajina to them occupying Petrova Gora,

24     approximately a month or two months?

25        A.   A month.

Page 3332

 1        Q.   A month, thank you.

 2             And you, the 21st Corps, moved to Vojnjik; is that right?

 3        A.   Vojnic.

 4        Q.   Vojnic.  I think you may have to correct me several times.  My

 5     pronunciation is quite bad, but I'm getting there.

 6             So you moved to Vojnic and that was, am I correct, 1994?

 7        A.   No, I believe it is in 1993.

 8        Q.   Whenabouts in 1993?

 9        A.   Let's speculate now.  We moved -- we move from -- from -- above

10     hotel Topusko, late 1992, moved to Petrova Gora ... let's say May 1993.

11        Q.   Could I suggest that it was more like 1994.  Could that be right?

12        A.   No.  Unless we look at my previous statement, then we can both be

13     corrected.

14        Q.   Well, your previous statement in the Milosevic trial, page 12320,

15     suggests - let me just turn it up, so I don't misquote it.  Now, if I

16     actually turn to 12319, where you state, at line 20:

17             "A.  We have moved that HQ to Petrova Gora, used to be a JNA

18     installation, and then from Petrova Gora to vicinity of Vojnic was the

19     third and last displacement of the HQ.

20             "Q.  Can you approximate for us when the headquarters was moved

21     to Petrova Gora?

22             "A.  It would be earlier 1993.

23             Over the page:

24             "Q.  And can you approximate for us when you moved to Vojnic?

25             "A.  It was in the same year, at a later stage, when the Serbian

Page 3333

 1     MUP moved into Petrova Gora."

 2             So were you trying to say that it was later in 1993?

 3        A.   Yes.

 4        Q.   Could it have been at the end of 1993/1994?  I suggest that the

 5     Serbian MUP did move into Petrova Gora but in November of 1994.

 6        A.   No, absolutely incorrect.  But May of 1995, we're done.  And they

 7     were much longer there than just the six months.

 8        Q.   Now, I want to ...

 9             MR. JORDASH:  Would you like me to continue, Your Honour?

10             JUDGE ORIE:  Well, it depends.  As I said before, we'll have a

11     break soon, a couple of minutes from now.  If you would find this a more

12     suitable moment, then we will have the break now before you start a new

13     area.

14             MR. JORDASH:  Okay.

15             JUDGE ORIE:  Then we have a break and we resume at quarter to

16     6.00.

17                           --- Recess taken at 5.15 p.m.

18                           --- On resuming at 5.49 p.m.

19             JUDGE ORIE:  Mr. Jordash, you may proceed.

20             And, Mr. Lazarevic, breaks between question and answer, and

21     between answer and question.

22             Please proceed.

23             MR. JORDASH:  Thank you, Your Honour.  I'm sorry I'm going have

24     to return to the subject before the break.

25        Q.   Could I refer to your previous testimony page 12422, and line 4

Page 3334

 1     where you state:

 2             "It was late 1993 when there was a sudden influx of these

 3     uniformed men, uniforms I had never encountered before.  Talking to them

 4     in our own language, it was obvious they were not from the area.  Also it

 5     was obvious they were not a paramilitary unit, as far as we're concerned,

 6     because they were given a free passageway and also they were given our

 7     old HQ in Petrova Gora."

 8             So, please, would you think again whether you're suggesting that

 9     it was May 1993 or late 1993.

10        A.   It was in 1993, I'm absolutely convinced.

11             MR. JORDASH:  Could I also then ask for Exhibit 405, please, the

12     Pauk diary, to --

13        Q.   But, before that comes, could I ask you this:  Am I correct that

14     the Serbian MUP arrived at the same time as other groups which you say

15     were involved in Pauk?

16             Let me put that differently:  When the Serbian MUP arrived, Pauk

17     started almost immediately?

18        A.   We have to make one thing clear first.  I belonged to the

19     military personnel.  The movement of police within the RSK was not my

20     focus.  It wasn't my interest.  This is just my observation.  So if I'm

21     saying late 1993, I believe it's late 1993.

22        Q.   Well, Mr. --

23        A.   Whether the other units belonging to the Pauk Command came at the

24     same time, at a different times, then I don't know.

25        Q.   Well, let me ask you this:  You obviously noted, as you've said

Page 3335

 1     in your evidence, that the arrival of the Serbian MUP was a significant

 2     affair.  Was their arrival -- did their arrival coincide with the

 3     beginning of the Pauk operations?

 4        A.   Yes, I think so.

 5             MR. JORDASH:  Could I please have Exhibit 405 on the screen,

 6     please.

 7             JUDGE ORIE:  Your reference is to --

 8             MR. JORDASH:  Sorry --

 9             JUDGE ORIE:  -- a 65 ter number or?

10             MR. JORDASH:  Sorry, Milosevic -- yeah, the 65 ter number,

11     Your Honour.  This is the -- exactly this.  This is the exhibit I wanted.

12             JUDGE ORIE:  Yes.  Segment of Pauk diary.

13             MR. JORDASH:  It's P00235.

14             JUDGE ORIE:  Meanwhile, it is P235.

15             MR. JORDASH:

16        Q.   Now, have you seen this --

17             JUDGE ORIE:  Yes, I see it.

18             MR. JORDASH:

19        Q.   Have you seen this diary before, or this log-book?

20        A.   Yes I have.

21        Q.   And have you confirmed, as far as you're concerned, it was

22     accurate?

23        A.   That is difficult for me to say.  I saw it for the first time

24     only a couple days ago.  I haven't seen it before.

25        Q.   So you can't confirm the contents of it are accurate?

Page 3336

 1        A.   I read it.  I find it amusing.  There is a mention of me in there

 2     as well, so I thought, well ...

 3        Q.   Can you have a look at the first page, there, operations log-book

 4     number 1 and then the date --

 5             JUDGE ORIE:  Could I ask a question.  We're talking about years.

 6     The one thing apparently is not translated is the year on the title page.

 7             MR. JORDASH:  The --

 8             JUDGE ORIE:  I don't know who is responsible for this

 9     translation, but ...

10             MR. JORDASH:  Yeah, could the first page be raised a little.

11             JUDGE ORIE:  You see, I read in the original 16th/11/1994, G.

12     Whereas I see there:  16 November 1990, which leaves open 1993, 1994,

13     1995.

14             MR. JORDASH:  If we can have the bottom of the left-hand screen,

15     please, I think that might assist Your Honour.

16             JUDGE ORIE:  Yes, it certainly does -- I'm primarily focussing on

17     accuracy in whatever I see on paper.  And perhaps we could -- this first

18     page could be ... could be corrected.

19             MR. JORDASH:

20        Q.   I'm not going to labour the point, Mr. Lazarevic.  But if that

21     front page of the diary doesn't trigger your memory that the Serbian MUP

22     arrived in November of 1994, then I'll move on.

23        A.   I do not agree with you.  And I tell you why:  This is a front

24     page of operational diary.  Somebody was writing down what was happening

25     from day to day.  Might be accurate.  It doesn't necessary mean that the

Page 3337

 1     front page is accurate.

 2             Secondly, that is when already the combat situation according to

 3     this diary has started.  Now, I'm referring to late 1993 when the first

 4     MUP units started arriving, so this is where we disagree.  This is a time

 5     of operation, the combat.

 6        Q.   Well, I'm not going to labour the point, but did you make the

 7     point, didn't you, that the arrival of the Serbian MUP had --

 8        A.   Late 1993.

 9        Q.    -- had occurred at around the same time as the Pauk operations

10     had commenced?  If you made that -- you accept you made that point?  We

11     can move on, if you don't want to accept it, it's okay.

12        A.   No.

13        Q.   Okay.

14        A.   I'm still -- I'm still absolutely convinced it happened in late

15     1993 that the MUP made it to the Petrova Gora compound.

16        Q.   And before that time, before the arrival of the Serbian MUP at

17     Petrova Gora, you hadn't heard of them in the Republika Srpska Krajina as

18     a group, had you?

19        A.   No.

20        Q.   And am I correct that you are unable to assist the Court with the

21     training of the special police of the RSK in Knin, that you don't really

22     know much about that?

23        A.   Not really.  I can't help you there.

24        Q.   All you know about that from what you heard at the time, what you

25     saw at the time, was that Dragan, Captain Dragan was training special

Page 3338

 1     police --

 2        A.   I never said I saw him training the special police.  I heard

 3     about it.

 4        Q.   You heard about it?

 5        A.   Yes.

 6        Q.   You heard he was training the special police on behalf of Martic?

 7        A.   Yes.  And it was called Martic's police.

 8        Q.   Exactly.  And some of those men who had been trained at Dragan's

 9     camp wore red berets; is that correct?

10        A.   So I heard, yes.

11        Q.   And answered to Martic.  Is that what you heard?

12        A.   Well, they were called Martic's police; it is natural to assume

13     they are responsible to Martic.

14        Q.   Yeah.  And you, at that time, had a good knowledge, would you

15     say, of what was going on in the Republika Srpska Krajina?

16        A.   No.  I never claimed I had a good knowledge.

17        Q.   Well, I think you said that if events that were occurring in a

18     70 kilometres by 50 kilometres there were not many things that would

19     happen that you wouldn't be aware of.  Is that fair?

20        A.   All the population living in that area would be aware what is

21     going on, including myself.

22        Q.   Exactly.  And the news coming out of Knin and Golubic was that

23     Martic is training a special force?

24        A.   More or less, yes.

25        Q.   Called the Martic's police?

Page 3339

 1        A.   Yeah.

 2        Q.   On behalf of Babic?

 3        A.   On whose behalf, I don't know.

 4        Q.   Okay.  Now you yourself wore a red beret; didn't you?

 5        A.   On occasion.

 6        Q.   Why was that?

 7        A.   I thought I looked better.

 8        Q.   Were you trying to associate yourself with Martic's police?

 9        A.   Absolutely not.

10        Q.   Did Martic's police, wearing red berets, have a particular

11     reputation at that time?

12        A.   No, I don't think so.

13        Q.   Let me ask you about a different subject.  I just want to make

14     sure I understand your bibliography, your work bibliography, correctly.

15     In 1991 you joined the JNA?

16        A.   Late 1991.

17        Q.   Late 1991.

18        A.   Probably December 1991.

19        Q.   And in early 1992, you were a liaison officer to the 21st Corps?

20        A.   Originally I was assistant liaison officer to General Mrksic of

21     the 8th Operational Group in Samarice.

22        Q.   Okay.  And at that time you started -- and this is your evidence,

23     I think, that you started at around that time working with various

24     translators?

25        A.   That come much later.

Page 3340

 1        Q.   When did that happen?

 2        A.   The UN was deployed on the ground.  They started looking for

 3     local people to work for them.  So I'd say probably May/June 1992.

 4        Q.   May/June 1992, you're employed by KOS to --

 5        A.   No, I was deployed by KOS in 1968.

 6        Q.   Yes, sir, if you would just let me finish.

 7        A.   Sure.

 8        Q.   You were employed by KOS in May or June 1992 in order to take -

 9     let me put that differently - to covertly obtain information from the UN

10     and various international organisations, and you did that through taking

11     information from the various translators involved in the international

12     mission?

13        A.   What was the date again?

14        Q.   May/June 1992, when you started --

15        A.   Yes.  But you said in there that I was engaged in KOS by that

16     time to gather the information through the translators in local --

17        Q.   Mm-hm.

18        A.   -- workforce.

19        Q.   Were you not?

20        A.   That was much earlier than that.

21        Q.   When did you start working as an interpreter, taking --

22     organising other translators, and using that work in order to obtain

23     information on behalf of others [Overlapping speakers] ...

24        A.   [Overlapping speakers] ... I never worked as interpreter.  I was

25     a liaison officer of the 21st Corps.  I was assisting the situation on

Page 3341

 1     the ground.  But, obviously, you couldn't be everywhere at the same time,

 2     so they needed to employ more people.  And everyone did employ their own

 3     translators, obviously.

 4        Q.   Okay.  Let me try to be a bit more specific.

 5        A.   Sure.

 6        Q.   Let me just move backwards a bit.

 7             Is it your evidence that Stanisic received his information in

 8     1991 and 1992, 1993, from the Republika Srpska Krajina mainly through

 9     Toso Pajic?

10        A.   Yeah, I believe it to be the case, yes.

11        Q.   Were you aware of anyone else giving him information?

12        A.   Milos Pajic.

13        Q.   Anyone else?

14        A.   Not that I know of.

15        Q.   Toso Pajic, though, was his, according to you, main information

16     source?

17        A.   Well, he was my information source as much as we exchanged ideas

18     and thoughts and what is going on.

19        Q.   Okay.  Now, let's return to the issue of the translation and

20     translators.

21             When did you start organising translators to provide information

22     through your work as a KOS agent?

23        A.   Well, as soon as they started giving them the jobs on the ground.

24     It was the question of getting those informations which they attend to

25     across to us.

Page 3342

 1        Q.   When?

 2        A.   Mid-1992.

 3        Q.   And how long did that job last?

 4        A.   To the very end.

 5        Q.   Date, please.

 6        A.   5th of August, 1995.

 7        Q.   And is this correct:  Your job involved organising and briefing

 8     translators who were heading to various international or national

 9     meetings with the UN and so on?

10             Please, you describe the job to me.

11        A.   The idea was, is they are, within the sector of the 21st Corps,

12     they're going have a bunch of these interpreters to work for them on a

13     local level.  We're not talking about the international conferences and

14     stuff like that.  I never had to deal with those people.  I'm talk about

15     the local populace there.

16             If -- if either of the general wanted to have his own interpreter

17     to take him to Bihac when he goes over there, I wanted to know, or,

18     rather, we wanted do know what was discussed on that particular meeting.

19     So that that was the idea of getting them together, talking about the

20     local interpreters.

21        Q.   And this was your main work for KOS from --

22        A.   No, it was not.

23        Q.   What was your main work for KOS during this time-period?

24        A.   If I was given a task -- well, I'll give you an example:  During

25     one of the international meetings, my only reason being there is to

Page 3343

 1     observe General -- Admiral Rakic because he was security risk to us.  And

 2     that was not my -- that I made up that.  I was told that he has got two

 3     sons living in Croatia who were of military age and they would -- and he

 4     is a military risk to us.  But that is, for example, one of the tasks.

 5        Q.   How often did you arrange translators between 1992 to 1995 to

 6     provide information?

 7        A.   Every time there was any meeting that we had put some relevance

 8     do it, yes, I would ask for information.

 9        Q.   How often would that occur between 1992 and 1995?  Was it a

10     weekly, a monthly, a daily affair?

11        A.   No.  It happened as it happened.

12        Q.   Well, give us --

13             JUDGE ORIE:  Everyone is going to make a break.

14             I take you back at page -- because I was a bit confused.  You

15     asked earlier, Mr. Jordash, what the main source of information for

16     Mr. Stanisic was.  You suggested to the witness that it was mainly

17     Toso Pajic.  He said that he believed that that was case.  You ask about

18     another source of information.  He mentioned Milos Pajic.  And then, in

19     the follow-up of that question, the explanation was that it was a source

20     apparently for this witness, not primarily for Mr. Stanisic.  I was a bit

21     confused about whether Milos Pajic, where the witness said - and part of

22     it is lost in the transcript at this moment:

23             As much as we exchanged ideas and thoughts of what was going on.

24             So, apparently, the conversation moved from the source of

25     information for Mr. Stanisic to your source of information.  I'm a bit

Page 3344

 1     confused by that.  I just wanted to let you know that.

 2             And since we had to intervene anyhow, I do it at this moment.

 3             MR. JORDASH:

 4        Q.   Could we just clarify that quickly, Mr. Lazarevic.

 5             Milos Pajic was not your main source of information.  He was

 6     Mr. Stanisic's, according to you?

 7        A.   No.  I never said that.  Officially, Mr. Milos Pajic was the

 8     member of the SDB.

 9        Q.   Go on.

10        A.   Right.  Toso Pajic I consider to be my personal friend, and along

11     the line of him being a liaison officer for the police in the area of

12     21st Corps and I was a military liaison officer, that we should meet and

13     exchange what is going on, on the ground.

14             So I wouldn't even call him my personal source of information

15     about anybody.  I want to make clear I didn't go and --

16        Q.   Mr. Witness, we get the point.  Thank you.

17        A.   Okay.

18        Q.   Now, one of your principal jobs was to organise the translators;

19     is that correct?

20        A.   Yes, I would test them.

21        Q.   Right.  And one of the ways in which you obtained information was

22     directly from the translators who obtained it from the various meetings

23     they attended; is that correct?

24        A.   Correct.

25        Q.   Now could you explain exactly how it worked, how it worked that

Page 3345

 1     the information came to you, and how it was it was passed on from you.

 2        A.   It's very simple.  If I, for example, heard that the, I don't

 3     know, Red Cross of Krnjak [phoen] needed to be -- International Red Cross

 4     in the presence of the UN, and we would have an interpreter there to

 5     translate.  When it is done, I would ask him to write a very brief

 6     information what was discussed, what was the point of the meeting.  And

 7     it was begin to me.

 8             Now, if I would get through the day three or four different

 9     information about the meetings, then I would compile them and try to make

10     some sort of an overview of the informations, make my own conclusions, or

11     try to draw what is going on from what I have got.  And then I would pass

12     that along to Nikola Zimonja or anybody in that sector.

13        Q.   What did you pass on?  The original report or your composite

14     report?

15        A.   I would give a composite.  I would give -- it was original

16     report.  I mean, if the person attended a meeting in a capacity of

17     translator, I would ask him, What did you discuss?  Do you remember what

18     the points of the meetings?  And things like that.  In the information I

19     got, I could get it either in writing or being told to me.  This is what

20     we talked about.  There is a Croatian family needs, requests --

21        Q.   Mr. Witness, can I just try to -- I'm going to be limited with

22     time, so if we can just focus on the question.

23             Did you write a composite report from the reports that were given

24     to you?

25        A.   Depending how important it was.  And it was my decision how

Page 3346

 1     important it was or wasn't.

 2        Q.   If it wasn't important, what would happen?  Would you send the

 3     original report from the translator?

 4        A.   Yeah, I would never receive the report.

 5        Q.   You would never [Overlapping speakers] ...

 6        A.   When you say "report," I have the idea somebody is handing me a

 7     minutes from the meeting written by hand.  And this is it, this is your

 8     copy, do whatever you want with it.  This is it not the case.  It was

 9     done -- a report can be by mouth, a report can be written down.  But it

10     is not an original document.

11        Q.   No.  Did the translators give you a written report?

12        A.   From time to time, yes.

13        Q.   Did the translators most of the time give you an oral report?

14        A.   From time to time.

15        Q.   Was there any other way the translators gave you a report?

16        A.   [Overlapping speakers] ... no, there is only two possibilities.

17        Q.   Thank you.

18             JUDGE ORIE:  Overlapping speakers.

19             MR. JORDASH:  Sorry.

20             JUDGE ORIE:  Since the subject matter is translators, I thought

21     you would think about it.

22             MR. JORDASH:  Sorry.

23             JUDGE ORIE:  I think what the witness said is that -- no, let's

24     try to get that evidence again, because overlapping speakers even cause

25     great problems at a later stage.

Page 3347

 1             The question was whether there was any other way the translators

 2     gave you a report.

 3             Your answer was?  Two possibilities only:  oral or written?

 4             THE WITNESS:  Or written, yes.

 5             JUDGE ORIE:  Yes.  That apparently was it.

 6             Please proceed.

 7             MR. JORDASH:  Thank you.

 8        Q.   If the -- if you considered the information you'd received

 9     important, you would write your own report about that information; is

10     that correct?

11        A.   Correct.

12        Q.   And what would you do with that report?

13        A.   First I would try to get it to whatever connection I had with

14     Colonel Zimonja.  If he was on the ground, give it directly to him.  If

15     not, find out who is the next one going to Belgrade so he can take it

16     with him.

17        Q.   And is that a process you followed from 1992 to 1995?

18        A.   Yes, sometimes I was called in Belgrade to give a report in

19     person.

20        Q.   To who?

21        A.   Colonel Zimonja.

22        Q.   Did you give anyone else a report?

23        A.   I think I worked one -- one task for -- now I'll give you the

24     name; I'm not sure whether it is a real name or not.  He was introduced

25     to me as Medo, and he was a member of state security.

Page 3348

 1        Q.   We'll come do that in a minute.

 2        A.   Sure.

 3             JUDGE ORIE:  One --

 4             MR. JORDASH:  Thank you.

 5        Q.   So written report by you if information is it important enough,

 6     passed directly to Zimonja.  That was the process.

 7        A.   Yes.

 8        Q.   So you cannot say, can you, what Zimonja did with that

 9     information?

10        A.   I have no idea.  For all I know, he picked it up and throw it in

11     the trash.  I don't know.

12        Q.   So you cannot confirm or deny the suggestion that that

13     information did not go to Mr. Stanisic?

14        A.   Mr. Stanisic?

15        Q.   Yes.

16        A.   I never sent any report to Mr. Stanisic.

17        Q.   And you don't know what Zimonja did with the reports?

18        A.   No, no.

19        Q.   And you never sent any report to Stanisic?

20        A.   No.

21        Q.   And you never gave any reports to anyone other than Zimonja, did

22     you?

23        A.   I did --

24        Q.   Expect -- sorry?

25        A.   I gave to Toso Pajic.  If I would -- if I would get a certain

Page 3349

 1     information, I'll give you an example:  A battalion which was leaving the

 2     sector, an UN battalion, got in touch with me and said -- interested to

 3     sell all equipment they have, everything is, including those -- little

 4     listening devices, I don't know, part of weaponry, including even the

 5     mattresses for their beds, they were ready to sell everything.  Now that

 6     information was given to Zimonja.  Zimonja suggested I should get in

 7     touch with Pajic because the VJ was not interested in it.  But,

 8     Zimonja -- Pajic might be interested in it.

 9        Q.   So did you -- you gave the report to Pajic -- sorry.  You gave

10     the report to Pajic if Zimonja suggested that you do so.

11        A.   If he told me, yes, implicitly, You take this, you give it to

12     Pajic, yes.

13        Q.   Otherwise, you just gave it to Zimonja?

14        A.   Yes.

15        Q.   Yeah.  Could I suggest you never had this role of passing

16     information to Zimonja and, in fact, you were not a regular KOS agent.

17        A.   You can suggest whatever you want.

18        Q.   Let's now look at what your previous testimony was.

19             MR. JORDASH:  12386.

20        Q.   Let me read it to you, Mr. Witness.

21             Referring to page -- to line 17 and the issue of the

22     interpreters:

23             "So I with have them go and come back and report to me about what

24     was discussed at the meeting, what decisions were made, if any was made.

25     And then I would compile all these reports in one major report which

Page 3350

 1     would -- was sent to my HQ.  I would do those in triplicate, really,

 2     because one was going to Colonel Zimonja; one was going to the HQ,

 3     Colonel Bulat; and one was going do Toso Pajic."

 4             Isn't that quite different to what you just told the Court?

 5        A.   No it isn't quite different.

 6        Q.   It isn't?

 7        A.   No.

 8        Q.   No.  Okay.  How is it not different?

 9        A.   It is not different in that respect that I would give my report

10     to Zimonja.  If Zimonja suggested I should give a copy to Toso Pajic, I

11     would give it to Toso Pajic.

12        Q.   But in the Milosevic case you appeared to be saying that you did

13     your report in triplicate, that each was going to Zimonja, Bulat, and

14     Pajic, as a matter of course?

15        A.   Can I have a look at that, please?

16        Q.   Sure.

17             MR. JORDASH:  Please could we have 12386 on the screen.  I think

18     it's P224.

19             JUDGE ORIE:  The document is under seal.  Would it be limited it

20     to the -- if limited to the page and nothing else to be shown to the

21     public, that is public on the Internet as well.  So, therefore ...

22             MR. JORDASH:

23        Q.   Have you read that, Mr. Lazarevic?

24        A.   Yeah.  Line 20, 21, 22.

25        Q.   Yeah.  Any explanation?  Or do you maintain that it is consistent

Page 3351

 1     with your account of earlier today?

 2        A.   Well, apparently it was different here.

 3        Q.   Yeah.

 4        A.   That's obvious.  I either place it on not remembering, seing that

 5     the passage of time is 15 years.  But I have an additional explanation

 6     for that as well.

 7        Q.   [Previous translation continues] ...

 8        A.   There was -- there were situations where I was required to do a

 9     single report and only to Zimonja and nobody else.  There were situations

10     when I was told to do them in triplicate or in duplicate.  But not on a

11     regular basis.

12        Q.   Let me ask you, please, to turn to --

13             MR. JORDASH:  Can we turn to the witness's first statement at --

14     made in 1999.  I have forgotten whether this has been given a P number.

15     I don't think it has.  It is ERN 0205-3036.

16             JUDGE ORIE:  Mr. Jordash, have you verified whether, on the basis

17     of the limited portions of the testimony to be in private session,

18     whether there is any reason for this statement to be kept

19     confidential or ...

20             MR. JORDASH:  The statement I'm now trying to refer to,

21     Your Honours?

22             JUDGE ORIE:  Yes.

23             MR. JORDASH:  Yes, I think it should be --

24             JUDGE ORIE:  It should be confidential.

25             MR. JORDASH:  Yes, I think so.

Page 3352

 1             JUDGE ORIE:  Then, therefore, it should then not been shown to

 2     the public.

 3             Please proceed.

 4             MR. JORDASH:

 5        Q.   Who told you, Mr. Witness, that you should do reports in

 6     triplicate or duplicate?

 7        A.   Zimonja.

 8        Q.   Zimonja?

 9        A.   Yes.

10        Q.   Let me ask you to turn to the statement you made in 1999.  You do

11     recall making the statement?  You've been through it on a number of

12     occasions.  I imagine --

13        A.   I sincerely hope so.

14        Q.   Yes.

15             MR. JORDASH:  Let's turn directly to the eleventh page of the

16     English version, and it is page 0205-3046 on the right-hand corner.  In

17     the B/C/S, perhaps I can be helped out by ...

18             I'm looking for -- at the paragraph, Mr. Lazarevic, which begins

19     with:  "In early 1992, local and other Serbs interviewing for

20     interpreters with the UN" and so on.

21             I'm not sure what page it is.  10, in the B/C/S, thank you.  10.

22     Thank you.

23        Q.   And if you read that paragraph, and I'm interested in the second

24     part of the paragraph where it says:

25             "All of the interpreters were required to submit frequent reports

Page 3353

 1     back to me, and I forwarded these reports along with my own to Zimonja

 2     and Pajic."

 3              So "I forwarded these reports along with my own to Zimonja and

 4     Pajic."

 5             Isn't that -- did you find that?

 6        A.   Yeah, I'm looking at it.  What about it?

 7        Q.   Well, isn't that quite different to what you've told us?

 8        A.   Why is it different?

 9        Q.   Well --

10        A.   I'm telling you that I have been sending reports in accordance

11     with the importance of the report --

12        Q.   Why are you suggesting there, in 1999, that you forwarded the

13     reports of the interpreters along with your own report and you forwarded

14     them on a routine basis to both Zimonja and Pajic?

15        A.   Only if Zimonja was insisting for me to send the report to Pajic.

16             MS. MARCUS:  Your Honours, I waited a while to see where counsel

17     was going with this.  The witness has testified that he had two -- he had

18     a dual role in the region.

19             His testimony is that he had an official role within the

20     21st Corps and that he had a somewhat unofficial role with KOS.  Which

21     in -- which he says he had two lines of reporting.  That's on --

22             JUDGE ORIE:  But let's not comment on the testimony of the

23     witness.  I mean, if you have any objection against the question --

24             MS. MARCUS:  Yes, sir.

25             JUDGE ORIE: -- that's fine.  If you have the --

Page 3354

 1             MS. MARCUS:  Yes, the objection --

 2             JUDGE ORIE:  Yes.  What's the objection?

 3             MS. MARCUS:  Sorry -- I'm sorry, Your Honour.  The objection is

 4     that the question should be clear to witness which exactly role he is

 5     asking about in terms of reporting line.  And that the two may be

 6     confused in the manner of questioning.

 7             JUDGE ORIE:  Yes.

 8             Mr. Jordash, I leave it to you at this moment.  In general,

 9     questions that confuse are not to -- put to a witness.  At the same time,

10     the fact that the Prosecution thinks that something may confuse the

11     witness is not decisive of whether or not the question is confusing or

12     not.

13             I leave it into your hands so --

14             MR. JORDASH:  Thank you.

15             JUDGE ORIE:  So know -- if you would be, yourself, convinced that

16     it's mixing up matters, then you should refrain.  But if you have good

17     reasons to put it in the way you do it, please proceed.

18             MR. JORDASH:  The whole paragraph -- just to be clear, the whole

19     paragraph is quite clearly dealing with the KOS role, the whole

20     paragraph.

21             JUDGE ORIE:  So you are putting your questions in that context?

22             MR. JORDASH:  Yes.

23        Q.   And I can read the second sentence -- sorry, the sentence below

24     what I have just read because this will bring the context:

25             "The result was that every interpreter working with the UN and

Page 3355

 1     the ECMM in the Krajina was reporting back to the SDB and was on our

 2     payroll."

 3             That's what the statement says, Mr. Lazarevic.

 4        A.   I would like to have a look at that one, too.  Because I'm pretty

 5     sure never said that all -- what are you suggesting is the report from

 6     all over Krajina coming to me, and I'm just sending them forward?

 7        Q.   Well, I'm just looking at your statement.  I'm asking you about

 8     it.  So would you have a look at that paragraph?

 9        A.   Yeah, please.

10        Q.   It's same paragraph we just looked at.

11             "All of these interpreters were required to submit frequent

12     reports back to me, and I forwarded these reports along with my own to

13     Zimonja and Pajic.  The result was that every interpreter working with

14     the UN and the ECMM in the Krajina was reporting back to the SDB and was

15     on our payroll."

16             Are you not -- in 1999, suggesting that all the interpreters

17     were, by virtue of this surveillance scheme, let's call it that,

18     reporting to Pajic and Pajic was reporting to the Serbian DB?

19        A.   On the area of the 21st Corps, yes.

20        Q.   But is --

21        A.   Not all over Krajina.  There's got to be some misunderstanding

22     along the line somewhere.

23        Q.   Well, the misunderstanding is that in 1999 you said that you were

24     reporting directly to Zimonja and Pajic; now you're saying that you're

25     reporting only to Zimonja except when told by Zimonja to report do Pajic.

Page 3356

 1     And in the Milosevic trial you said something different again.  That is

 2     the confusion I'm trying to get to.

 3        A.   Go ahead.

 4        Q.   Well, could you explain it?

 5        A.   What was the difference that I said during the trial in 2002?

 6        Q.   Well, in the Milosevic trial, you said triplicate reports; in

 7     1999 you said duplicate reports.

 8        A.   And now I'm saying nobody?  What you're suggesting --

 9        Q.   [Overlapping speakers] ... trying to work out what you are saying

10     now.

11        A.   I'm going to try to be as clear as I possibly can.

12             To understand the situation at the time, there were a lot of

13     people involved in there from a different services; from a State Security

14     Service, from the military intelligence, from a local police, and

15     everybody else wanted to know what was going on.

16             Now, my first response was to Colonel Zimonja.  If, for example,

17     you knew in advance where the meeting is going to be held and who is

18     going to attend the meeting, then Zimonja might say, Well, this could be

19     of interest to Pajic as well, so make a report to him.  And I would do

20     that.

21             I don't see nothing strange.

22        Q.   If that's your answer, we can move on.  Thank you.

23        A.   You're welcome.

24        Q.   Well, actually, before we do move on --

25             JUDGE ORIE:  I'm slightly concerned about what is then shown to

Page 3357

 1     the witness.  Do I -- the portion you were reading was apparently the top

 2     of page 11 in the English.  And that was not -- the relevant portion

 3     apparently was not on the screen for the witness.  And I'm always -- or

 4     am I wrong?  In his own language?

 5             MR. JORDASH:  I hoped it was because we did say page 10.  So I'm

 6     not sure if --

 7        Q.   Did you, Mr. Lazarevic, see the section of the statement I was

 8     reading from?

 9        A.   Now you got me lost because we've seen so many

10     things [Overlapping speakers] ...

11             JUDGE ORIE:  let's try to be very precise on that.  It can be

12     that it is somewhere, but.

13             MR. JORDASH:  Perhaps it would have been better if I just refer

14     to the English version since, Mr. Lazarevic ...

15             JUDGE ORIE:  Well, there are more people who want to follow the

16     proceedings.  So, therefore, it's -- of course, the witness is the most

17     important one to be able to follow.  But the others, like the accused,

18     and those who are observing these proceedings.

19             I just want always that we verify whether what we see in English

20     is visible for the ...

21             I haven't found it in the B/C/S version, but ...

22             THE INTERPRETER:  Interpreter's note:  In the B/C/S version it is

23     the central paragraph -- no, on the page that was shown earlier.  Begin

24     where the near 1992 appears.  Except it's only the last portion of that

25     paragraph that we see in English, on top of the English page.

Page 3358

 1             JUDGE ORIE:  I see it now.  It's ...

 2             MR. JORDASH:  Page 10.

 3             JUDGE ORIE:  Yes, it's in the middle of page 10.

 4             MR. JORDASH:

 5        Q.   Have you got that, Mr. Lazarevic?

 6        A.   Yes, "In early 1992, the local and other ..."

 7             Is that the one that you're referring to?

 8             JUDGE ORIE:  Yes.  And then later in this paragraph, close to the

 9     end well, let's say the last ten lines approximately, that's where you

10     talk about the -- apparently about the interpreters being on the payroll.

11             You found it?  Where it says:

12             "The result was that every interpreter working..." [B/C/S spoken]

13     That's where you're supposed to read.

14             You found it?

15             THE WITNESS:  No, unfortunately, I haven't.

16             JUDGE ORIE:  Page 10 in the B/C/S.

17             THE WITNESS:  Those translators had our strict ...

18             JUDGE ORIE:  Yes, it's the line above that, I think, at least in

19     the sentence before that.

20             THE WITNESS:  Well, in that case you have to go all the way up

21     there and you see there was an agreement between Toso Pajic and

22     Zimonja --

23             JUDGE ORIE:  No, no, I'm just asking whether you found what was

24     put to you as your statement which apparently is the the line starting

25     with the result was that every interpreter ...

Page 3359

 1             THE WITNESS:  [Overlapping speakers] ...

 2             JUDGE ORIE:  Yes?

 3             THE WITNESS:  Yeah, have I got it.

 4             JUDGE ORIE:  Let's always be certain that if we put a statement

 5     or whatever to a witness, that he is able to read it and that everyone is

 6     able to follow what we are talking about.

 7             MR. JORDASH:  Yes.  Thank you.  Sorry about that.

 8             JUDGE ORIE:  Please proceed.

 9             MR. JORDASH:

10        Q.   Have you read it, Mr. Lazarevic?

11        A.   Yes.

12        Q.   Any further comments to make?

13        A.   Yes, if you go back a few lines, you will find out there was an

14     agreement between Mr. Pajic and Mr. Zimonja about the reporting line

15     there, engaging the interpreters.

16        Q.   Sorry, I don't follow your answer.  Could you explain that a bit

17     further, please?

18        A.   Okay.  Let me just find the English version of it now.

19             There's a line that goes:  Those translators I have evaluated in

20     Topusko in accordance with instructions from Pajic and Zimonja.

21        Q.   Yeah.

22        A.   So they were aware of each other trying to get the information.

23     But Zimonja was -- who would be in advance decide who gets the

24     information first.

25        Q.   Why would --

Page 3360

 1             JUDGE ORIE:  And this is now found, apparently, on page 10 in the

 2     English, if I ...

 3             MR. HOFFMANN: [Previous translation continues] ... in the last

 4     paragraph.

 5             JUDGE ORIE:  Yes.

 6             MR. JORDASH:

 7        Q.   So you were suggesting in 1999 it was a joint operation between

 8     Zimonja and Pajic, a joint operation to work - let's put it like that -

 9     work the translators to obtain information for both of them?

10        A.   I wouldn't call it a joint operation.  That's suggesting two of

11     them decided it's going to be like that.

12        Q.   Well you said --

13        A.   What I'm suggesting is that information which was interested to

14     the police and there are information which are of interest to the

15     military.  They are not always one and the same.

16        Q.   Mr. Witness, Mr. Lazarevic, you said in 1999, according to your

17     statement:

18             "I screened these translators into Topusko under instruction from

19     Pajic and Zimonja, yes."

20             So you were suggesting it was direct and joint operation, those

21     two instructing you.

22        A.   Now you are reading something that I never said.

23        Q.   So you didn't say that it was under instruction?

24        A.   No, no, I did say.  But I'm not -- I have never mentioned that as

25     a joint operation between the two of them.  You have to realise that -- I

Page 3361

 1     was working basically two jobs there.

 2        Q.   Mr. Witness, let me ask you a question.

 3        A.   Sure.

 4        Q.   Did you say, as the paragraph states, they wanted to be in a

 5     position to control all of the interpreters?

 6        A.   I don't see any conflict there.

 7        Q.   Did you say that?  I'm just asking.

 8        A.   Yes.

 9        Q.   Thank you.  Did you say:  I forwarded these reports, along with

10     my own to Zimonja and Pajic?

11        A.   Yes, I have.

12        Q.   Thank you.  Did you say that as a consequence of that or the

13     interpreters who were on the payroll of the SDB?

14        A.   Yes.

15        Q.   And now what you say is, in fact, I gave the reports to Zimonja,

16     and Zimonja made a decision about whether he gave any of the reports

17     to Pajic.

18        A.   Yes, if it is relevant to Mr. Pajic.

19        Q.   Okay.  Let's leave it at that.  I think we might have exhausted

20     the subject.

21             Was there any other KOS agent that you gave information to in the

22     years between 1991 and 1995?

23        A.   Yes.

24        Q.   Who?

25        A.   I don't remember the names anymore, but there would be people

Page 3362

 1     coming in uniform, JNA uniform, from Belgrade asking for me and telling

 2     me Zimonja sent him.  And I had no reason to doubt.

 3        Q.   Did you ...

 4             JUDGE ORIE:  Please proceed.

 5             MR. JORDASH:

 6        Q.   Did you see the same KOS agents more than once, when Zimonja

 7     wasn't there to receive the reports?

 8        A.   Not that I remember.

 9        Q.   So you always got a new KOS agent picking up the reports when

10     Zimonja wasn't around?

11        A.   More or less, yes.

12        Q.   So, according to you, then, only Zimonja would be able to confirm

13     your important work for KOS.  Is that the sum total of what you're

14     saying?  Could anyone else?

15        A.   There were a lot of people who knew me there, what I'm doing, and

16     how I'm doing, and everything else.  I don't quite understand

17     [Overlapping speakers] ...

18        Q.   [Overlapping speakers] ...  would Toso Pajic know that you were a

19     KOS agent?

20        A.   I don't think so.

21        Q.   How would he not know, given that you were acting on his and

22     Zimonja's behalf?

23        A.   Because I was a liaison officer for the 21st Corps, and they both

24     needed me at the time.

25             JUDGE ORIE:  Yes.  If we continue this way, then I have to

Page 3363

 1     introduce a different regime, that is, I'll tell you you can now put a

 2     question; then I will give a sign that can you answer the question.  But

 3     this is an impossible way of proceeding.

 4             Now, I give you a last chance to do it without my assistance as a

 5     traffic agent, or conductor, whatever you want to call it.  Last chance.

 6     Otherwise, we really are going do split it up, because part of your

 7     testimony will be lost.  Overlapping speakers just doesn't work.

 8             MR. JORDASH:

 9        Q.   When I asked you, Mr. Witness, how would Pajic not know, you

10     answered:

11             "Because I was a liaison officer for the 21st Corps, and they

12     both needed me at the time?"

13             Could you explain that, please?

14        A.   At the time, police did not have their own liaison officer.

15     Toso Pajic got given this task much later as a liaison officer for the

16     police.  So most of the time Toso Pajic relied on me to let him know what

17     is going on, in relations to international community.  So ...

18        Q.   But is this what you're suggesting to the Court, that, despite

19     being instructed by Pajic to take information from the interpreters,

20     despite seeing Pajic, I think you said five times a week, despite being

21     in the office when Pajic speaks to Stanisic, Pajic would not know you

22     were working for KOS?

23        A.   No I didn't --

24             JUDGE ORIE:  No, no, one ...

25             If you look at me, I'll give you a sign.

Page 3364

 1             Please answer the question.

 2        A.   No.  There was no need what he should know.  Officially, I was --

 3     I was a liaison officer for the 21st Corps.  My work concentrated on the

 4     war for KOS, and this is something you don't go around advertising.

 5     Toso, you know, I'm working for KOS and for you at the same time.  This

 6     is simply not done.

 7             MR. JORDASH:

 8        Q.   What about Colonel Kosta Novakovic?  Would he know?  Wasn't he

 9     also working for the KOS internal security?

10        A.   He worked for external [sic] security.

11        Q.   I know.  That's what you're saying --

12             JUDGE ORIE:  Whoa ...

13             MR. JORDASH:  Sorry.

14        Q.   But Novakovic worked for internal security, yes?

15        A.   That was my understanding.

16        Q.   And Novakovic was Zimonja's superior?

17        A.   Not that I knew of.  That is news to me.  If you claim that

18     Kosta Novakovic was a superior to Zimonja, no.

19        Q.   So despite Novakovic working for the KOS, he wouldn't know about

20     you either?

21        A.   No.  I was not part of the internal security.  You have to make a

22     difference there.

23        Q.   Well, Colonel Milos --

24        A.   My life I have spent outside of Yugoslavia working.  So people on

25     the ground in Yugoslavia, when I showed up eventually, had no clue who I

Page 3365

 1     am except those who I work with.

 2        Q.   Colonel -- you've given this diagram which we looked at earlier,

 3     which I think is Exhibit 653, and you also named Colonel Petar Surla as

 4     working for KOS.  Is that correct?

 5        A.   Correct.

 6        Q.   And Colonel Mlado Karan?

 7        A.   Mlado Karan.  Correct.

 8        Q.   How was it that you knew about them working for KOS if they

 9     didn't know about you?

10        A.   I don't -- I don't get your question, really.

11        Q.   Well --

12        A.   Why they didn't know what I do and I knew what they do?  Because

13     they were in position within the corps in a position of the -- of the

14     internal security for the military.  That was their corps.

15     [B/C/S spoken].

16             THE INTERPRETER:  Security officer.

17             THE WITNESS:  Thank you.

18        Q.   So the sum total then, is this a fair summary that no one can

19     confirm, other than you, that you worked for KOS?

20        A.   Probably some people who are aware of that.

21        Q.   Could you consist the Court so that we might then, from the

22     Defence, investigate?

23        A.   I don't know.  People who dealt with me.

24        Q.   Can you give us some names to assist our investigation?

25        A.   No, I can't remember any.

Page 3366

 1        Q.   Can't remember any?

 2        A.   Really, why don't you get in touch with Colonel Zimonja and ask

 3     him.

 4        Q.   So from 1968 until 1995 the only name you can give who might

 5     assist is Zimonja?

 6        A.   Yes.

 7        Q.   Okay, fair enough.  Let me ask you this about Mr. Pajic.  You

 8     said today, earlier - and I will try to quote you - at page 27 of the

 9     draft transcript:

10             "As I have stated before, I had at least five times a week

11     meetings with Mr. Pajic because," something, "our work between the

12     military and police, as far as UN forces on the ground are concerned.  So

13     quite frequently I would be in his office and I -- and he would tell me

14     like, you know," something, "will be here.  And I was led to believe that

15     Daddy is Mr. Stanisic.  He never actually, I have to be honest, he never

16     said directly, I am working for Stanisic.  But he did do all the work.

17     It has been proven that he actually did work for Stanisic in the end."

18             Right?  So Pajic never confirmed to you that he worked for

19     Stanisic.  Am I correct?

20        A.   Not in as many words.

21        Q.   So in the -- well, how long were you working with Pajic?

22        A.   Early 1991 -- I mean, late 1991 to 1995, the last person getting

23     out of Krajina at the time.

24        Q.   So not once during that period did Pajic say to you he worked for

25     Stanisic?

Page 3367

 1        A.   Never.

 2        Q.   No.  And your confirmation of -- sorry, let me put that

 3     differently.

 4             What you said to the Court earlier today was that it was proven

 5     that he actually did work for Stanisic because he ended up with an office

 6     in the DB headquarters in Belgrade, after 1995.  Is that a fair summary?

 7        A.   Correct.

 8        Q.   And that's your evidence, that he worked for Stanisic?

 9        A.   Now?

10        Q.   What's your evidence?

11        A.   Well, my evidence is that what is happening on the ground, who

12     was reporting to, who was he talking to, who was he being visited by, who

13     we went -- who he went to see in Belgrade at the time, several occasions.

14        Q.   Well, at some point, he was a minister of the interior.

15        A.   That's very late.

16        Q.   Yeah.  But he was, according to you, a member of the -- he was

17     the chief the police in -- in Vojnic; is that right?

18        A.   Yes, I think so.

19        Q.   Right.  So you don't know what was discussed, if and when he went

20     to Belgrade to see Stanisic?

21        A.   No.

22        Q.   And what did he discuss when you were present during telephone

23     calls to Stanisic?

24        A.   I wasn't really sitting there and spying on Mr. Toso Pajic.  It

25     would just happen that he would have a telephone call.

Page 3368

 1        Q.   Mm-hm.

 2        A.   And he would have very brief answers on the phone.  So I don't

 3     know what the other side is saying to him.  If the first side says, Yes,

 4     yes, I understand, thank you, see you, bye, that's about it, that I can

 5     convey to you from the content of conversation.

 6        Q.   So basically you cannot confirm the contents of the conversation

 7     between Stanisic and Pajic, even though you were present?

 8        A.   No, you can only hear one side of it.

 9        Q.   Can you recall any of that conversation from the one side?

10     Sorry.

11        A.   No, I can't.

12        Q.   Okay.  Thank you.  You mentioned earlier today, I think after the

13     last break, that, on one occasion - is this right - you took a tape to

14     someone called Medo who, you say, worked for the DB?

15        A.   Other way around.  I was given a tape by Medo and returned it to

16     him after the meeting was done.

17        Q.   Could you explain a little more?  Where did you meet Medo, and

18     what was the tape he gave you?

19        A.   In the office of the DB, in Belgrade.  I was given a folder

20     consisting of a tape which would be initiated by the sound, start

21     working.  To take it to -- I believe it was Vukovar to a meeting with the

22     former German ambassador and to record the full conversation that I had

23     with him.

24        Q.   So you attended the DB office in Belgrade and was given a blank

25     tape?

Page 3369

 1        A.   I was given the whole unit.

 2        Q.   The tape recorder?

 3        A.   Yeah.  Which was built into a folder.

 4        Q.   And the instruction was to take that to Vukovar to record the --

 5        A.   To a meeting.

 6        Q.   To record the former German ambassador?  In a meeting.

 7        A.   Yes.

 8        Q.   And what did you -- did you do that?

 9        A.   Yes.

10        Q.   What did you do with the tape afterwards?

11        A.   Brought it back to this person called Medo.

12        Q.   And who instructed you to go to pick up the tape from Medo in the

13     first instance?

14        A.   Zimonja.

15        Q.   And how do you know that Medo worked for the DB?

16        A.   That's what he said.

17        Q.   What did he say then?  Can you recall the words?

18        A.   Yeah, I don't remember the words.  But I was led to believe that

19     he represents the Sluzba Drzavne Bezbednosti, state security.

20        Q.   What was recorded from the German ambassador?  What was contents

21     of the tape?

22        A.   I'm trying to think of it.  I think the original, the whole idea

23     was to get in touch with him and talk about his liaison with the

24     journalist from "Duga" newspaper in Belgrade.  That it was apparently his

25     girlfriend or something like that, to get as much as I can out of this

Page 3370

 1     discussion.

 2        Q.   Did you ever do that again for Medo?

 3        A.   No.

 4        Q.   Or the state security?

 5        A.   Not that I'm aware of.  Now you got me doubting myself that Medo

 6     was from the state security.  I believe he was.  I was taken to a

 7     building which everybody knew was a state security building.  With

 8     somebody from military going in there, how the hell do I know?

 9        Q.   Did you ever do it again for the state security?

10        A.   Not that I was aware of, no.

11        Q.   Could I ask you please to turn to your --

12             MR. JORDASH:  Can we have on the screen, please, the witness's

13     1999 statement, page 13 of the English version, and it's paragraph 4 of

14     page 13.  I'm going need to some help with getting the B/C/S.

15             It's the -- sorry, it's not the diagram.  It's the statement,

16     which is P -- sorry, it's not P anything.  It's -- that's the one.

17             Now I want to have the B/C/S version too so that the witness can

18     follow it clearly.  It's the paragraph beginning:  "I was being paid by

19     both the RSK police/military and by KOS."

20        A.   I got the passage there.

21        Q.   Right.  There's a number of things which arise from this passage,

22     Mr. Lazarevic.

23             First, the first three sentences, or two sentences, three

24     sentences:  "I was being paid by both the RSK police/military and by KOS.

25     I was required to submit my reports to Petar Surla throughout 1992 and

Page 3371

 1     1993.  In 1993, he was replaced by Mlado Karan, who remained in charge of

 2     KOS in Sector North until August 1995."

 3             Do you see that?

 4        A.   Yeah, I'm reading, sir, but I have no idea what is happening

 5     here.  Petar Surla left in 1992.

 6        Q.   Well, if -- did you -- this contradicts what you said earlier,

 7     didn't it, about Surla and Karan not knowing that you worked for KOS?

 8        A.   No, they didn't.

 9        Q.   So you didn't say this to the Prosecution in 1999?

10        A.   I'm looking at it.  I don't remember saying it.  In all honesty.

11             Looking at it, why would I say in 1999 that Surla was there in

12     1993 and in 1993 was replaced by Mlado Karan, which is totally incorrect?

13        Q.   Well, if that's -- if you cannot explain, then, how it got into

14     your statement or why it hasn't been corrected in the very many

15     interviews you've had with the Prosecution since --

16        A.   Nobody ever paid any attention to it.  I haven't.

17        Q.   Okay.  Let's move on.

18        A.   We're talking about 40-odd pages of very important material.

19        Q.   Thank you.  Let move on, Mr. Witness:  "Surla and Karan sent all

20     of my reports to Zimonja in Belgrade, and the tapes that I made of

21     meetings were forwarded to a subordinate of Stanisic, who I knew only as

22     Medo.  He would take the tapes directly to Belgrade."

23        A.   -- surprise to you as much as it is a surprise to me.  I do not

24     remember making this statement.

25        Q.   Okay.  Fair enough.

Page 3372

 1        A.   I'm looking at that time.  There are so many inconsistencies in

 2     that that I remember.  First be, Mlado Karan and Petar Surla didn't work

 3     together.  They replaced each other in the 21st Corps.  Secondly, I never

 4     gave them anything to carry for me in Belgrade.

 5        Q.   Okay.  If that's your -- you didn't say that to the Prosecution

 6     then?

 7        A.   No.  You can squeeze my thumbs, but I don't remember saying it.

 8        Q.   Okay.  Fair enough.  Let's move on.  And the point, then, about

 9     "tapes of meetings being forwarded to a subordinate of Stanisic, who I

10     knew only as Medo," do you know how that got into your statement?

11        A.   I remember one tape that I did for this person called Medo.  I

12     don't remember a multitude of tapes been sent.

13        Q.   Do you know how it got into your statement?

14        A.   No, I don't.

15        Q.   And then:

16             "He would take the tapes directly to Belgrade."

17             To -- from what you've told us, you went to Belgrade to give the

18     one tape to Medo?

19        A.   Yes.  This is it not happened in 1993.

20        Q.   Yeah.

21        A.   This particular case happen after the Krajina has fallen.  I was

22     in Belgrade by then, when I was asked to do this German ambassador.

23        Q.   "It was Surla and Karan's decision what they would send to Knin."

24             Do you know how that got into your report --

25        A.   No.

Page 3373

 1        Q.   No.

 2             JUDGE ORIE:  Mr. Jordash, I'm looking at the clock.  We're close

 3     to where we have to conclude for the day.

 4             Could I inquire with you how much more time you would need?

 5             MR. JORDASH:  I would like an hour, if that's possible.

 6             JUDGE ORIE:  How much time would the Simatovic Defence need, as

 7     matters stand now?

 8             MR. BAKRAC: [Interpretation] Your Honours, at least two hours.

 9     We have a large number of documents that we would like to present to this

10     witness, so we will not just chat here.  We will have specific documents

11     to confront this witness with.

12             So we need at least two hours.

13             JUDGE ORIE:  Mr. Groome, I've already three hours on the list of

14     wishes.  What does that mean for the next witness to be called?

15             MR. GROOME:  Your Honour, by our calculation, we're not going to

16     get to that witness so that we haven't brought that witness to The Hague,

17     but they are readily available, if necessary.

18             JUDGE ORIE:  No, it's -- my concern was the other way around, as

19     a matter of fact, that the witness would be here.

20             Under those circumstances, I think we -- we should endeavour to

21     conclude the testimony of this witness tomorrow.  Three hours is a little

22     bit over two sessions.  Let's -- let's try to -- to be as efficient as

23     possible and to see where we come.

24             Mr. Lazarevic, before we adjourn, I would like to instruct you

25     that you should not speak to anyone or communicate in any other way with

Page 3374

 1     anyone about your testimony, whether that is what you have told us today,

 2     or what you'll tell us tomorrow.  Refrain from any communication or

 3     conversation on your testimony.

 4             We adjourn, and we'll resume tomorrow, the 9th of February,

 5     quarter past 2.00 in this same courtroom, II.

 6                            --- Whereupon the hearing adjourned at 7.03 p.m.,

 7                           to be reconvened on Tuesday, the 9th day of

 8                           February, 2010, at 2.15 p.m.