1 Wednesday, 13 July 2011
2 [Open session]
3 [The accused entered court]
4 --- Upon commencing at 9.02 a.m.
5 JUDGE ORIE: Could the witness be brought into the courtroom.
6 Ms. Marcus.
7 MS. MARCUS: Yes, Your Honours, perhaps while the witness is
8 being brought in I can just raise one issue. We have not yet received a
9 statement or any submissions in relation to the witness after next who
10 will likely start next week. I just wanted to also point out on the
11 record: Your Honours had issued an order to the Defence to disclose all
12 witness statements. Of course, we have made extensive submissions on the
13 provisions of Rule 67(A)(ii), but even apart from that, Your Honour on
14 the 23rd of June had issued an order for them to disclose witness
15 statements. As we have seen with the last witness -- with this witness
16 the statement was completed on the 1st of June and we received it on the
17 6th of July. And with the next witness, the statement was completed on
18 the 29th of June and we received it on the 12th of July.
19 So the delay in the disclosures I just wanted to raise. Thank
21 JUDGE ORIE: Mr. Jordash, perhaps you later respond to this,
22 later today, and we would avoid that the witness has to wait.
23 [The witness entered court]
24 JUDGE ORIE: Good morning, Mr. Bosnic. I would like to remind
25 you that you are still bound by the solemn declaration you've given
1 yesterday at the beginning of your testimony, and Mr. Jordash will now
2 continue his examination.
3 Mr. Jordash.
4 MR. JORDASH: Thank you, Your Honour.
5 WITNESS: MILE BOSNIC [Resumed]
6 [Witness answered through interpreter]
7 Examination by Mr. Jordash: [Continued]
8 Q. Good morning, Mr. Bosnic.
9 A. Good morning.
10 MR. JORDASH: Please could we have on the screen 65 ter 1557.
11 Q. We were discussing, if you recall, Mr. Bosnic, the re-opening of
12 Golubic, and I just wanted you to quickly look at an exhibit and confirm
13 if it accords with your knowledge of Golubic re-opening.
14 A. This is consistent with my knowledge of Golubic, at least in
15 part, because I don't know all the individuals concerned or all the
16 activities that took place at the school.
17 Q. You confirmed yesterday that the Golubic which re-opened in and
18 around September 1992 trained ordinary police officers; is that correct?
19 A. Yes.
20 Q. Now, just looking at the front page, it notes there that the
21 session was not attended by council member Toso Paic. You see that about
22 seven lines from the top?
23 A. Yes.
24 Q. You spoke about Toso Paic yesterday; do you recall that evidence?
25 A. Yes.
1 Q. How well did you know him in 1991 and 1992?
2 A. Very well. He was one of the leaders of the police station in
3 Vojnic. Later on, at my proposal, he became Martic's assistant in charge
4 of Kordun.
5 Q. Why did you propose him in the way you testified?
6 A. Milos Pajic told me, and I knew from my conversations with him
7 that he was a highly-trained policeman who had worked with our
8 representation offices in New York and Paris, representing the then
9 socialist Yugoslavia.
10 Q. How often did you see him in 1991?
11 A. Very often because we had meetings with representatives of the
12 police who, sometime until mid-1991, refused to accept Martic as a
13 secretary and continued maintaining their contacts with Zagreb.
14 Q. This is the Vojnic police; is that correct?
15 A. Yes, yes, from Vojnic and Vrginmost.
16 Q. How often would you see him in 1992?
17 A. Quite often as well. We had meetings to co-ordinate between the
18 civilian authorities, the police, and the army. At the time I was
19 president of the municipality of Slunj and deputy in the Assembly of the
20 Republic of the Serbian Krajina.
21 Q. Did he ever mention to you having any links with the Serbian DB?
22 A. No.
23 Q. Did he ever communicate any wish or desire of the Serbian DB in
24 terms of the events in the Krajina?
25 A. No. Until mid-1991 he co-operated with Zagreb.
1 Q. Let's move to a slightly different subject. I want to ask you
2 about some Babic allegations concerning the police.
3 MR. JORDASH: And before I do that, may I tender 1557 as an
4 exhibit, please.
5 MS. MARCUS: No objections.
6 JUDGE ORIE: Madam Registrar.
7 THE REGISTRAR: This would be D317, Your Honours.
8 JUDGE ORIE: And is admitted into evidence.
9 MR. JORDASH:
10 Q. Now, I want to ask you about something Babic spoke about in the
11 Milosevic trial.
12 MR. JORDASH: P1878, e-court page 354.
13 Q. And if I can just read the allegation that Babic made and then
14 I'll ask you to --
15 JUDGE ORIE: Could I first seek to clarify a matter in relation
16 to the previous document. You asked a question about Toso Paic and then
17 the witness said that he was one the leaders of the police station in
18 Vojnic and later on he became Martic's assistant. And you said "Why did
19 you propose him?" And then he said "Milos Pajic told me, and I knew from
20 my conversations with him that he was a highly-trained ..." So then the
21 qualities of Milos Pajic are set out, at least there could be some
22 confusion. First we were talking about Toso Paic. Now we see during the
23 meeting that Milos Pajic was present. He was also a SUP Vojnic official.
24 So I'm a bit confused by the answer "Milos Pajic told me, and I knew from
25 my conversations with him," and then his qualities are mentioned, which
1 seems to be an explanation for him being appointed in a certain position.
2 Now, was it -- is it Toso or is it Milos?
3 MR. JORDASH: Well, I think yesterday the witness -- the witness
4 is itching to answer, so, perhaps, I don't know if that's the way to deal
5 with it, if the witness could answer, or I can offer my ...
6 JUDGE ORIE: Yes, well, at least question and answer here are a
7 bit confusing.
8 MR. JORDASH: Yes, yesterday the witness said that Milos Pajic
9 had recommended Toso Paic to Martic.
10 JUDGE ORIE: So the "he" now on page 3, line 8, it is -- we have
11 to read that "Milos Pajic told me, and I knew from my conversations with
12 him that 'Toso Paic' was a highly-trained policeman." That is --
13 MR. JORDASH: I think that's --
14 JUDGE ORIE: -- how we have to understand that. I see the
15 witness is nodding, so that's now clear to me. Please proceed.
16 MR. JORDASH: Thank you.
17 Q. Page 354 in e-court, and I think we've got that now. Now,
18 Mr. Bosnic, just listen to what Mr. Babic has said and then I will ask
19 you to offer any insight into its truth or otherwise.
20 Babic is asked the following question, line 10:
21 "Q. Now, you were mentioning a moment ago that there were some
22 parallel military units set up by them and led by them, and my question
23 to you is the following: Are you aware, do you know that as far as
24 Serbia is concerned - now I'm being quite specific here, Serbia - as far
25 as Serbia is concerned, paramilitary units were only set up by opposition
1 parties? Do you know that?"
2 Babic's answer:
3 "A. I am aware of the fact that Serbia or, rather, you," that's
4 Milosevic, "via Jovica Stanisic, Radmilo Bogdanovic, and Franko Simatovic
5 nicknamed Frenki, formed volunteer units, detachments, in the SAO Krajina
6 starting with April 1991, and I know that you," that's Milosevic,
7 "instructed and linked up the Secretariat of the Interior or, rather, the
8 police stations on the territory of SAO Krajina, and also that you,"
9 Milosevic, "through them, set up special units, the ones that the
10 Assembly of Krajina, on the 29th of May, 1991, called the
11 Krajina Milicija, militia."
12 And then just reading on so you get the full picture. Question
13 from Milosevic:
14 "Q. So the formation of your Krajina police force you considered
15 to be the formation of a paramilitary formation."
16 Answer, page 13507:
17 "A. It was a paramilitary formation because it was not under the
18 control of the government.
19 "Q. How can the police SAO Krajina not be under the control of
20 the government?
21 "A. Well, in the way I explained. It had the right of might and
22 was not subjected to a government that did not have sufficient might.
23 "Q. All right. And what about the Ministry of the Interior?
24 Was he at the head of the police force?"
25 And then line 12:
1 "In such a way that this was done by force, because he didn't
2 wish to hand over his authority which the DB of Serbia and he," that's
3 Martic, "himself had set up, the structure he had set up."
4 MR. JORDASH: And if I may, just to complete the picture, read
5 you another part of Babic's testimony so we know what we're talking
7 MR. JORDASH: Page 1878, e-court page 348, 26 of November, 2002.
8 Q. And again Babic is being cross-examined by Milosevic. And at
9 line 8, Babic, again with reference to this so-called parallel structure,
11 "What they were doing," that's Martic and the parallel structure,
12 "was not the structure of the institutions which were legally elected and
13 established at multiparty elections. They were structures which had
14 illegally cropped up, arbitrarily, on their own initiative, and that is
15 why I call them parallel structures to the legal institutions.
16 "And I said that Martic was elected as secretary of SUP. But the
17 Assembly of Krajina, following a proposal by the Prime Minister --"
18 JUDGE ORIE: You're reading, Mr. Jordash.
19 MR. JORDASH: Sorry.
20 Q. "... appointed him Defence Minister for SAO Krajina on the
21 29th of May. And the very next day, having been convinced by Frenki and
22 people from the DB of Serbia, he," Martic, "refused to hand over to the
23 Ministry of the Interior --"
24 JUDGE ORIE: Mr. Jordash.
25 MR. JORDASH: "... and to the newly appointed minister, to hand
1 over his office to Dusan Vjestica. And in that way, it was through the
2 force of might, because, together with the DB of Serbia, he had control
3 over the armed formations of both the police force and paramilitaries
4 which had been set up in the camp of Golubic in April."
5 Did you follow that --
6 JUDGE ORIE: The French booth is -- makes an observation that you
7 did not provide them with a copy of this document you're reading.
8 MR. JORDASH: It should be on the screen, I think.
9 JUDGE ORIE: Yes, but perhaps if there are longer portions to be
10 read it would be good to have them provided in hard copy as well.
11 MR. JORDASH: Certainly.
12 JUDGE ORIE: Please proceed.
13 MR. JORDASH:
14 Q. So, I want to speak to you, Mr. Bosnic, about Martic and the
15 police and about the allegations that Babic made. Did Martic attend
16 government session meetings?
17 A. As far as I know, yes, that was his obligation.
18 Q. Did Babic ever complain to you at the time that Martic didn't
19 attend government meetings?
20 A. No.
21 Q. For what purpose did Martic attend government meetings? What was
22 his obligation?
23 A. As any other member of the government, the obligation was to
24 attend government meetings, take part in discussions in all the items of
25 the agenda, and issue decisions that would subsequently be implemented in
1 the field or forwarded to the Assembly.
2 Q. And as minister of the interior, was his obligation to report on
3 issues relating to Golubic?
4 A. Yes.
5 Q. Would issues relating to the Ministry of Interior or the police
6 force in general be subject to any debate or voting within the Assembly
7 or the government?
8 A. Certainly. In certain periods of time reports are submitted on
9 the work of each and every minister, and eventually the Assembly is made
10 aware of it as well.
11 Q. In relation to Golubic, you've mentioned in your statement that a
12 decision was made by the Serbian National Council to set up Golubic; is
13 that correct?
14 A. Serbian National Council?
15 MR. PETROVIC: [Interpretation] Your Honours, I think that this
16 was misinterpreted to the witness. And if Mr. Jordash would repeat it,
17 then I'm sure the witness will understand.
18 JUDGE ORIE: Mr. Jordash, could you please repeat your question.
19 MR. JORDASH:
20 Q. Paragraph 40 of your statement, it states that the decision to
21 set up Golubic in April 1991 was made by the Serbian National Council of
22 which Milan Babic was the president.
23 A. Yes, the Serbian National Council - the B/C/S being "vijece" and
24 not "savjet" - yes, it was headed by Milan Babic.
25 Q. And in paragraph 41 you say:
1 "Milan Martic was not a member of the Main Board of the SDS or a
2 member of the SDS. He was the secretary of the SUP, nominated by Milan
3 Babic, and thus a member of the government?"
4 Do you know how many government sessions were held in and around
5 May and June and July and August of 1991?
6 A. Well, I don't know, but I suppose that it was frequent, given the
7 situation prevailing in the field.
8 Q. Well, you say you suppose it was frequent. Could you try and
9 give some indication, from things you saw or heard, as to whether it was
11 A. Well, I do believe that it was frequent. Some -- every seven,
12 eight, or ten days. I know that these individuals came to Knin even more
13 frequently than just to attend Assembly sessions. They had meetings and
15 Q. Did you speak to members of the government during the time we're
16 discussing, April to August of 1991, concerning the training at Golubic,
17 the setting up of the Krajina Milicija, and Martic? Did you hear any
18 conversation about that or did you have any personal discussions?
19 A. All of us took part in these discussions, and I mean the
20 political leadership, because we were looking for a way to resist the
21 National Guards Corps and special units of Croatia in view of the fact
22 that we didn't have trained personnel. We were trying to find solutions
23 to the problem. The incursion at Plitvice was the straw that broke the
24 camel's back. That's why it was decided to ask from the Ministry of the
25 Interior of Serbia and the Government of Serbia to provide assistance in
1 training young individuals, with a view to setting up a unit that would
2 be capable of successfully resisting the Croatian forces.
3 Q. You say at paragraph 41 of your statement:
4 "If Milan Babic --
5 MR. PETROVIC: [Interpretation] Your Honours, I apologise for
6 interrupting. I'd like to intervene in the transcript. The witness did
7 say who took this decision that he is referring to, but that's not
8 reflected in the transcript.
9 JUDGE ORIE: We'll have this verified. You mean the decision
10 which appears at page 10, line 17?
11 MR. PETROVIC: [Interpretation] Yes, Your Honour.
12 JUDGE ORIE: Witness, you said that a decision was taken to
13 provide assistance in training young individuals. And who took that
14 decision seeking assistance from the Ministry of the Interior of Serbia
15 and the Government of Serbia to provide assistance? Who took that
17 THE WITNESS: [Interpretation] The Serbian National Council. And
18 it was signed and forwarded to Belgrade by Milan Babic.
19 JUDGE ORIE: Thank you.
20 Please proceed.
21 MR. JORDASH:
22 Q. Do you know who it was forwarded to?
23 A. To the Government of Serbia and the Ministry of the Interior of
25 Q. Do you know who in the Ministry of Interior?
1 A. Presumably to the minister. I suppose that the president of the
2 Serbian National Council addressed the minister, and I think that it was
3 Mr. Bogdanovic at the time.
4 Q. Now, you make mention in your statement that if Milan Babic had
5 not accepted Milan Martic, he would not have gotten the post, the post of
6 the minister of interior. Was it possible -- let me just rephrase that.
7 Was the continuation of a post in the Government of the
8 SAO Krajina subject to votes within the government?
9 A. Yes. After the SAO Krajina, if that is what you mean, was
10 declared the Republic of the Serbian Krajina, the ministers were again
11 elected and so was the government, and as Babic had been proclaimed the
12 president of the Republic of the Serbian Krajina, if that is the period
13 that you're referring to.
14 Q. Had Babic wanted to get rid of Martic in 1991, what would have
15 been the process by which he would have gone about doing that?
16 A. Well, he should have either proposed a reconstruction of the
17 government or a new cabinet.
18 Q. Sorry, I'm not -- let me repeat the question.
19 If Babic had wanted to get rid of Martic in 1991, what would have
20 been a process by which he would have gone about doing that?
21 A. He would not have proposed his remaining as member of the
22 Government of the Republic of the Serbian Krajina on the 19th of December
23 in 1991. But he was in favour of Martic's remaining, and Martic did
24 remain minister of the interior in the Republic of the Serbian Krajina.
25 Q. Sorry, what's the significance of the 19th of December, 1991?
1 A. The Republic of the Serbian Krajina was proclaimed.
2 Conditionally speaking, the SAO Krajina was abolished and the Republic of
3 the Serbian Krajina was declared in order to keep abreast of Croatia's
4 demands, and Croatia was pursuing independence.
5 Q. Were those who held government posts at the time of the
6 proclamation subject to re-election?
7 A. Not all of them.
8 Q. Was Martic?
9 A. Yes, he was, and he was re-elected.
10 Q. What was the process by which he was re-elected?
11 A. The prime minister designate, who was a representative of the
12 SDS, was given a mandate by Milan Babic to form a government, and at the
13 Main Board there were meetings, there were discussions, about the
14 composition of that government. That was accepted and was as such
15 referred to the Assembly, where it was properly -- where the proper
16 procedure was conducted and they were elected.
17 Q. Who was the prime minister designate?
18 A. Risto Matkovic was the prime minister designate, but essentially
19 it was Babic. It was Babic and we, members of the Main Board, who
20 discussed the members of the government at our session.
21 Q. Were you present at the Main Board during the discussions about
22 the re-election of Martic?
23 A. There was no discussion at all, in fact. Babic only said or,
24 rather, proposed that Milan Martic should be the minister of the
1 Q. Did Babic express any misgivings or doubts or in any way appear
2 under pressure about that decision?
3 A. No, not in a single moment. This could not be discerned at all
4 and he never said anything of the kind. So it was quite clear that there
5 had been no pressure exerted on either him or anyone else in that regard.
6 Q. Now let's return to your statement, D313, and paragraph 56, where
7 you talk about the Knindzes.
8 While that's coming up: Just to wrap up the last issue, why, as
9 far as you could see, did Babic propose unambiguously for Martic to be
10 re-elected? Do you know the reason for that?
11 A. Well, from the very beginning of these events, these people from
12 Knin who knew each other prior to the events and from before, so these
13 were people who knew each other from before, and I believe that
14 Milan Babic trusted him.
15 Q. And did you know Dusan Vj estica, the man Babic claimed Martic
16 refused to hand over his office to?
17 A. Yes.
18 Q. Are you able to cast any light on Babic's allegations in that
20 A. I was not at that Assembly session as I was not an MP at that
21 time, and Babic came up with the idea that a civilian should assume
22 control of the MUP and that Milan Martic should be the minister of
23 defence. However, when this decision reached the people in the field,
24 members of the police actually would not accept Vjestica as minister.
25 They even said that he had had a falling out with the law. I don't know
1 anything about that, mind you. But soon after that the situation was
2 restored to normal and Martic was again the minister of the interior.
3 Q. Are you able to give some names of people who were in the field
4 or members of the police who would not accept him as a minister?
5 A. I do not know the name of the secretaries of the police stations
6 in the various municipalities. That was not within my remit. But as far
7 as I know it was all the secretaries of the police stations in the areas
8 of Lika and Northern Dalmatia.
9 Q. Okay. Let's move to the Knindzes. Were you aware of -- well,
10 you clearly were aware of a group known as the Knindzes during 1991?
11 A. Yes, I was.
12 Q. Could you give the Court some assistance in relation to the size
13 of the Knindzes, how many people formed the Knindzes?
14 A. I don't know exactly. It was a small group, some 30-odd people.
15 Q. At what point did these 30-odd people become visible to you and
16 other politicians in the region?
17 A. Well, they became visible after the first actions which took
18 place in the area of the Krajina in which they participated.
19 Q. Which action or actions were those?
20 A. Well, there was the action in Glina, in Skabrnja, I believe in
21 Bruska. That's it, more or less.
22 Q. That's it, more or less. Do you know, and I want you to think
23 carefully, apart from Glina and Bruska, are you aware of any other place
24 where the Knindzes participated in combat during 1991?
25 A. Right now I cannot recall whether there had been any other ones.
1 It is quite possible.
2 Q. Now, you don't know this but I can tell you this, that in
3 Mladic's diary in 1991 the Knindzes are not mentioned. Is that a
4 surprise to you in terms of military issues and what was going on on the
5 ground militarily, the Knindzes don't warrant a mention in Mladic's
7 A. Well, it is surprising because all military operations which were
8 taking place in the area were in concert, i.e. -- concert with, i.e.,
9 under the command of, the JNA.
10 Q. Did you at the time, you and your colleagues, think of the
11 Knindzes as a significant military force?
12 A. In the moral [as interpreted] sense.
13 Q. What do you mean by that?
14 A. That a unit had appeared which was successful, which was taking
15 part in successful operations in co-ordination with units of the
16 Yugoslav People's Army, and that it was a sort of a basis for future
17 sources that would be set up throughout the SAO Krajina, which was later
18 to become the Republic of the Serbian Krajina.
19 MR. JORDASH: Could we have, please, P2659.
20 Q. Why do you use the word "moral" in this context, Mr. Witness?
21 A. Because our people were afraid. We were afraid that the
22 incursions of the special units of the Croatian police or the
23 National Guards Corps would entail crimes, because we had a negative
24 experience from the period of the Second World War when our people were
1 THE INTERPRETER: Interpreter's correction: The word was
3 JUDGE ORIE: And the correction relates to page 16, line 4, the
4 sense of morale, is that ...
5 THE INTERPRETER: Yes, Your Honour.
6 JUDGE ORIE: Thank you.
7 Mr. Jordash, please proceed.
8 MR. JORDASH: Thank you.
9 Q. This is a speech given by Captain Dragan. You've commented on it
10 at page 4 of the chart, D315, and I just want to ask you about some of
11 what Captain Dragan said.
12 If we can -- do you remember this exhibit, Mr. Bosnic?
13 A. Yes.
14 MR. JORDASH: Let's go to page 2 of the English and page 3 of the
16 Q. And at the bottom of the English page, Captain Dragan says:
17 "I'm not saying that some other units did not take part in this
18 operation." And he's referring to the operation in Glina. "After all,
19 that was a big operation, so-called stinger operation. That was a
20 continuation of wasp operation, where the aim was to clear the
21 MUP forces."
22 Do you have that, Mr. Bosnic?
23 A. Well, it is the third page actually here and you said that in
24 Serbian it was the second page.
25 Q. Oh, I beg your pardon. Do you have the section? It's two-thirds
1 of the way down the page, I think, or perhaps not. It's the section
2 where the heading should say:
3 "Journalist: Would you like to say something about officer
4 Grujica Boric?"
5 A. Could we go back to page 3. After all, I can see it in the
6 English but not in the Serbian.
7 Q. It is page 3, you're right, in the B/C/S. I can see it.
8 A. Yes, I have found it.
9 Q. Okay. Just read through that to yourself, please, and I'll then
10 ask you --
11 A. [No interpretation]
12 Q. From the point where the journalist asks a question and
13 Captain Dragan says "Just before I move to that issue."
14 A. "The journalist: Would you like to say something about officer
15 Grujica Boric?"
16 Q. Just read it to yourself, please.
17 A. I just wanted to check whether that was it.
18 Q. Yes, that's it.
19 A. I've read it.
20 Q. And if we go over the page, Captain Dragan describes the
21 operation or an operation concerning Glina, and you'll see there where he
22 talks about 21 men from Knin. Do you see that?
23 A. Yes.
24 Q. Do you know if that figure represents the -- at that time the
25 full complement of the Knindzes?
1 A. I cannot claim that with certainty. I said that there were some
2 30 of them. I never counted. And we never asked for the actual number.
3 I suppose that there were only a few of them and they were used more to
4 boost morale than for other purposes, and had they been a larger unit,
5 they would have been much more visible, that's for sure.
6 Q. Did you see them in -- moving around?
7 JUDGE ORIE: Where and when, Mr. Jordash?
8 MR. JORDASH:
9 Q. In the areas that Mr. Bosnic was active and in 1991?
10 A. Never, on no occasion did I see the mentioned unit in Kordun.
11 Never ever.
12 Q. Did you speak to Babic about the Knindzes at any stage? Did he
13 complain about the Knindzes?
14 A. Not up to the point when Captain Dragan gave a statement which
15 had to do with politics or the incompetence of the SDS or something along
16 those lines, some statement of Captain Dragan along those lines. Babic
17 interpreted that as Captain Babic's [as interpreted] attempt to interfere
18 in political events in the Krajina.
19 MR. JORDASH: Could we have, please, on the screen 03879. It's
20 another exhibit relating to Captain Dragan. In the chart it's D298. And
21 it's page 4 of the chart.
22 JUDGE ORIE: When you talked about an attempt to interfere in
23 politics in the Krajina, you were referring to Captain Dragan, were you?
24 THE WITNESS: [Interpretation] Yes, yes. Yes.
25 JUDGE ORIE: Please proceed.
1 MR. JORDASH:
2 Q. When was that, Mr. Witness? When did Captain Dragan give a
3 statement which had to do with politics?
4 A. I believe that was after these operations in Glina or
5 thereabouts. I cannot be a hundred per cent sure, however.
6 Q. When was that? When were the operations in Glina?
7 A. At the end of June or July.
8 Q. Thank you. Now, this is a portrait, as we can see, of
9 Captain Dragan. It's dated July of 1991. And the author was an
10 Aleksandra Plavevski. Do you know that person?
11 A. No.
12 MR. JORDASH: Now, just let's go to page 2 of the English and
13 stay with page 1 of the B/C/S.
14 Q. And it's noted, under the title "discipline":
15 "Now, the defenders of the SAO Krajina have highly-mobile assault
16 units ready to act in any part of the territory within only 50 minutes.
17 Special purpose units are positioned in all strategic places in the
18 Krajina, which is now defended in the outer rim areas. They have all the
19 weapons they need, including artillery. Preparations are well underway
20 for the foundation of their own navy and air force."
21 What do you think about that, Mr. Bosnic? Do you have any
22 comment on that journalism?
23 A. My comment is the same: This is just nonsense. I have no better
24 word to describe this with. What aircraft are we talking about? Come
1 Q. What about "highly-mobile assault units ready to act in any part
2 of the territory within only 50 minutes"?
3 A. I wish. Had we had such units, we would have reached Austria and
4 I would not have ended up in Pancevo as a refugee.
5 Q. Reading on:
6 "Captain Dragan says that the goal of his units is to lend
7 maximum support to the Yugoslav People's Army, whose legitimacy they
8 recognise fully and which they are ready to defend if required. The
9 function of the special unit is to support the army and the police of the
10 Krajina, and their task is to neutralise the enemy and to eliminate them
11 from the territory of the SAO Krajina if need be."
12 A. This clearly demonstrates that Captain Dragan is confirming what
13 all of us knew and what I have said here, that no military operation
14 could have been carried out without co-ordination with the
15 Yugoslav People's Army.
16 Q. Did -- sorry, were you going to say something?
17 A. And without the knowledge of the Yugoslav People's Army. There
18 was no possibility for independent military action.
19 Q. Did Captain Dragan, as is claimed here, have units, in the
20 plural, or just a unit, as far as you're concerned, as far as you were
22 A. As far as I'm aware, Captain Dragan had just this one unit which
23 was called the Knindzes and which had specific patches, the Serbian coat
24 of arms with the four Ss turned upside-down or in the other -- facing the
25 other direction from the regular one.
1 JUDGE ORIE: Mr. Jordash, could we please better explore the
2 basis of the knowledge of the witness.
3 You said you had never seen them. How do you know about their
5 THE WITNESS: [Interpretation] I never saw them in action, but
6 these men who completed their training and returned to the area of Kordun
7 wore the uniforms of the Krajina Milicija. And I saw Captain Dragan in
8 Knin and I also saw a man by the nickname of Cigo and I saw the commander
9 of the armoured train, his name was Blagoje Guska, and they wore these
10 uniforms and they had red berets.
11 JUDGE ORIE: Yes. Now, let me try to understand your testimony.
12 You said you saw these men who had completed their training and returned
13 to the area of Kordun wearing these uniforms. Now, in your written
14 statement you are talking about part of the first group that was trained
15 in Golubic stayed there to train others, and you said that was the group
16 known as the Knindzes, and they became a special unit of the police.
17 Then you described where they came from, that they participated in combat
18 on the territory of Dalmatia and Lika if necessary, and that they
19 participated in an operation in Glina, and you said they were never in
20 Kordun. Apparently describing the patches, you are talking about people
21 that were trained, not part of the first group but apparently a follow-up
22 group, who went back to Kordun. You described their patches, although
23 you say Knindzes, that was the first group that in part stayed for
24 purposes of training others, I take it that these are your volunteers,
25 and they later participated in combat actions and they never came to
1 Kordun. When I ask you how you knew about the patches of the Knindzes,
2 you tell me that you saw them at the uniforms of people who came back to
3 Kordun, but that is not the group which in your written statement is
4 described as the Knindzes. So I'm totally confused by what you are
5 telling us.
6 Mr. Jordash, if you could create any clarity in this respect.
7 And the reason why I ask for the basis of the knowledge is that of course
8 the witness says, I assume that there were little - without or what that
9 assumption was based is rather unclear at numbers. He never counted
10 them, he never got reports about the numbers, so he assumes that they
11 were smaller numbers. Why he does assume so is -- again, is also totally
12 unclear to me.
13 So it's -- this is just an example of what I find confusing at
14 this moment. And if you could clarify it, that certainly would assist me
15 and hopefully my colleagues as well.
16 MR. JORDASH: Certainly. I'll do my best.
17 Q. You followed the President's query, Mr. Bosnic? Let's try to
18 break it down.
19 A. Yes.
20 Q. Do you include within the Knindzes those who were trained at
21 Golubic who then returned to, for example, Kordun?
22 A. No. They were members of Martic's Police. That's how they were
23 called. Only those who stayed back in Knin under Captain Dragan's
24 command, in other words, the best men of those who had trained, were
25 under his command. And that's why they had, being the Knindzes,
1 different sort of uniforms.
2 Q. And those who did not stay in Knin under Captain Dragan's
3 command, where did they operate from?
4 A. They operated from the municipalities whence they had originally
5 come, and they were under the command of the MUP of the Krajina, in other
6 words, Mr. Martic.
7 Q. And what uniforms did they wear?
8 A. They had blue camouflage uniforms with a large sign saying
9 Milicija Krajina, Krajina's Police.
10 Q. And did you see that? Did you see the uniform? Did you see
11 Krajina's Police wearing that uniform?
12 A. Yes, I saw Ilija Saula, Medakovic, and others.
13 Q. Now, putting that group of people aside and returning to the men
14 in Knin under Captain Dragan's command, where were they based in 1991?
15 A. They were stationed in Golubic, and Captain Dragan was in the
16 Knin fortress.
17 Q. Did you actually see that group in Golubic or outside of Golubic?
18 A. The individuals that I named I saw in town. As for those others,
19 I heard about them at the meetings where we discussed these issues. But
20 the three individuals I mentioned before were ones that I saw in town,
21 and that's why I can tell you what their uniforms were like. But I
22 didn't see them in action.
23 Q. Which three individuals did you see?
24 A. Captain Dragan; Blagoje Guska, who was the commander of the
25 armoured train which was part of the Knindze unit; and a local, a man
1 they referred to as Cigo, I forgot his last name.
2 Q. Now, you saw those three and then you said that you also
3 discussed the others at meetings. Which meetings were these men the
4 subject of discussion?
5 A. When it was said that the training at Golubic was successful in
6 churning up a small number of individuals from the general area who would
7 make up this special unit, whereas others were to remain -- to go back to
8 the areas they had originally come from for that specific training in
10 JUDGE ORIE: Mr. Jordash, would you mind to go back now to the
11 original question where it all started.
12 What patches then did these Knindzes have? Not the ones who
13 returned to their own locations, but where you said you saw three of them
14 in town.
15 THE WITNESS: [Interpretation] They had camouflage uniforms but
16 they were military uniforms, green.
17 JUDGE ORIE: I wasn't asking about uniforms. I was asking about
18 patches on the uniforms. Could you describe those?
19 THE WITNESS: [Interpretation] The Serbian coat of arms but one
20 where the Ss are facing away from each other, whereas normally they would
21 be facing one another.
22 JUDGE ORIE: Did they wear red berets?
23 THE WITNESS: [Interpretation] Yes.
24 JUDGE ORIE: On what is your knowledge based that there was only
25 one unit and not several units of these Knindzes?
1 THE WITNESS: [Interpretation] Well, at the meetings we discussed
2 only this one unit. I didn't have any information to the effect that
3 there were any in Banija and I knew that there weren't any in Kordun.
4 Had there been any other units of the sort, we would have known it. We
5 were politically active and had contacts at these meetings with
6 representatives of the police and the army. There was never any mention
7 of units other than this one.
8 JUDGE ORIE: Yes. But you have no positive knowledge, it's just
9 what you discussed and that you never discussed more than one unit, you
10 never saw more than one unit, so therefore you assume that it was one
11 single unit; is that correctly understood?
12 THE WITNESS: [Interpretation] I am certain to a great extent
13 because I travelled the area and I had never heard of another unit
14 existing. But in substance, my answer to what you just said is yes. The
15 travels I made in the area would have put me on notice of the existence
16 of another such unit.
17 JUDGE ORIE: Yes. It's at least clear from where your level of
18 certainty derives.
19 Please proceed, Mr. Jordash.
20 MR. JORDASH:
21 Q. Who were you talking to at that point in time who you might have
22 expected to hear about the existence of more than one unit? Please give
23 a selection of people who you might have expected to hear that from but
25 A. For the area of Kordun, I would certainly have heard it from
1 Milos or Toso Paic, from the commanders of TO staffs, or representatives
2 of the JNA at the meetings I attended. At times there were discussions
3 about actions that had been conducted, but there had never been any
4 mention of another special unit, hence my opinion that there could not
5 have been another one.
6 JUDGE ORIE: Your opinion was that there was not another one.
7 I'm just trying to understand. If not -- if there was no conversation
8 about a second unit, to conclude that there could not be one is quite a
9 different opinion from that there was not another one.
10 And, Mr. Jordash, I'm really concerned about mixing up opinions,
11 assumptions, facts known to the witness. Could you please try, in what
12 now follows, to always clearly distinguish between knowledge of facts,
13 personal observation, or hearsay so that it's always clear what we are
15 MR. JORDASH: But I --
16 JUDGE ORIE: If you say "I never heard talking about it, so there
17 could not have been another one," that's a kind of an opinion which
18 really doesn't assist the Chamber. But if you say I have no reasons to
19 believe that there was another one, that's fine. That's a conclusion you
20 can draw. But to say that it was never discussed so that on that is
21 based my opinion that there could not be another one is of course
22 something totally different. I take it that you're aware of that.
23 MR. JORDASH: Well, I'm --
24 JUDGE ORIE: The one excludes a possibility and the other one
25 leaves it open that there may have been or there may not have been but --
2 MR. JORDASH: Well, I think there's overlap between the two
3 depending upon where the witness received his -- what conversations the
4 witness had. There comes a point when the number of conversations the
5 witness has had about a unit reaches the point where the witness can be
6 certain there wasn't more than one unit.
7 JUDGE ORIE: It is a kind of a conclusion which is not --
8 unless -- you need a lot of factual bases before you can come to such a
9 conclusion, and not just a few conversations here and there in a
10 relatively large area where a unit apparently is 30 people, 30 to 40.
11 But let's not end up in a discussion. I tried to explain what was on my
13 MR. JORDASH: Well, the witness has described the basis for his
14 opinion, as Your Honour sees it, and I'll move on.
15 JUDGE ORIE: Yes, please do so.
16 MR. JORDASH:
17 Q. Well, perhaps I should try to clarify it since it's still on the
18 basis of opinion. Let's break it down, Mr. Bosnic. You spoke to
19 Toso Paic; why would you have expected him to mention if there was more
20 than one unit?
21 A. Well, representatives of the civilian government and the SDS
22 would have been informed of a unit appearing in the area of Kordun coming
23 from elsewhere. We attended meetings of the zone TO staff where no other
24 unit had been mentioned. After the operation Slunj, Mr. Cedo Bulat only
25 referred to TO and JNA units. The TO Vojnic, Plaski, and Korenica units,
1 as well as the JNA and police units from these areas.
2 Q. Same question: Milos Pajic; what would you expect him to have
3 said and why would you have expected him to say if there was more than
4 one unit?
5 A. Because it would have been an obligation on his part to make
6 aware us, representatives of the civilian authorities, of the appearance
7 of a unit in the territory where we were politically active. For
8 instance, I was active in the territory of the -- of Kordun.
9 Q. Same question in relation to commanders of the TO staffs; what
10 kind of discussions were you having with them where you might have
11 expected there to have been mention of more than one unit?
12 A. Because Milan Babic had appointed them to these posts. We had
13 meetings of the civilian authorities, TO, and the police discussing the
14 general situation in Kordun.
15 Q. And finally: Which meetings involved the representatives of the
16 JNA wherein you might have expected to hear about more than one unit?
17 A. In October of 1991 I became a member of the zone staff charged
18 with providing information. I became director of radio and television
19 Petrova Gora. Where military and other issues were discussed, I would
20 attend these meetings, as well as others, Mr. Paspalj and Cedo Bulat who
21 was the head of the military training-grounds Slunj. And the elements of
22 the command structure of the 5th Military District was there. So
23 Cedo Bulat and other officers, Mirko Radak, would also attend these
25 Q. And what did the meetings involve? What was the purpose of them?
1 A. To see how the TO could help man JNA units, to see what their
2 strength was, what the general situation was in the area covered by the
3 zone staff, what the situation was like for the population, and the
4 developments in the area in general. The zone staff also covered Banija
5 at the time; in other words, it was the zone staff for Kordun and Banija.
6 MR. JORDASH: Your Honour, I notice the time. I've only got
7 about 10 minutes, if Your Honour would allow that, after the break.
8 JUDGE ORIE: Yes, I'm -- of course, primarily, we take the
9 75 minutes instead of the usually 90 because of Mr. Stanisic. If
10 Mr. Stanisic would enable you to have the next ten minutes, then of
11 course it's fine as far as the Chamber is concerned.
12 MR. JORDASH: To be honest, I would rather have a break just so
13 that I can gather the material and be efficient after the break if
14 that's ...
15 JUDGE ORIE: That's -- yes, that's -- I'm not going to say it's
16 fine, but it's accepted.
17 MR. JORDASH: Thank you.
18 JUDGE ORIE: We take a break, and we resume at ten minutes to
20 --- Recess taken at 10.22 a.m.
21 --- On resuming at 10.54 a.m.
22 JUDGE ORIE: Mr. Jordash.
23 MR. JORDASH: Thank you.
24 Q. Mr. Witness, I want to just very briefly discuss a period around
25 the time of the Vance Plan negotiations.
1 MR. JORDASH: Please could we have on the screen 65 ter 1385.
2 Q. What is going to come up on the screen are minutes or a
3 stenographic record of the 188th Session of the Presidency of the
4 Socialist Federative -- Federal Republic of Yugoslavia, held on the
5 25th of February, 1992. And you can see there who attended the session.
6 And you can see there the participants included Petar Gracanin, federal
7 secretary of the interior.
8 Now, did you attend this session or were you privy to the
9 preparations for the session or the subjects that were discussed during
10 the session?
11 A. This has to do with Vance Plan. You said Vance-Owen Plan,
12 whereas it's the Vance Plan.
13 I didn't attend this Presidency session. But in the capacity of
14 the Presidency of the Assembly of the Republic of the Serbian Krajina, I
15 attended several meetings of the Presidency where the Vance Plan was
16 discussed. This is already at the stage where the Vance Plan is being
17 accepted, in preparation of the Assembly session which was to take place,
18 I believe, in Borovo Selo.
19 Q. And Mr. Babic's position was that he opposed the Vance Plan; is
20 that correct?
21 A. Yes, absolutely.
22 Q. And did you agree with that position?
23 A. I did, and I suppose that was the reason why I was chosen to be
24 part of the delegation of the RSK, one of the seven delegates taking part
25 in the negotiations in the Presidency of Yugoslavia in late 1991 and
1 early 1992.
2 MR. JORDASH: Let's go to page 8 of the English and 8 of the
3 B/C/S. And we can see there that Petar Gracanin is speaking. Now, just
4 now we've oriented ourselves with who is speaking. Let's move on to
5 page 11 of the English and 11 of the B/C/S.
6 Q. And halfway down the English page Petar Gracanin notes:
7 "As for the Internal Affairs organs in the Republic of
8 Serbian Krajina, we need to find a proper balance there, from the request
9 from these 34.000 people, and what we did on Saturday and Sunday together
10 with their organs, but these are organs that were consulted more from the
11 legal aspect, and a balance should probably be found there. We gave
12 around 4.000 for the entire --"
13 JUDGE ORIE: You are --
14 THE WITNESS: [Interpretation] Please scroll down.
15 MR. JORDASH: Sorry, Your Honour.
16 Q. "We gave around 4.000" ...
17 JUDGE ORIE: Please proceed.
18 MR. JORDASH: Thank you.
19 Q. "We gave around 4.000 for the entire area, but that is just the
20 core. We should look to find a middle way where the police force is
22 So we have the Federal Secretary of the Interior talking about
23 giving 4.000 people for the entire area of the Republic of
24 Serbian Krajina. "We should look to find a middle way where the police
25 force is needed." Are you able to cast any light on what the federal
1 secretary of interior is talking about?
2 A. This is one of the provisions of the Vance Plan, which reads that
3 in the area of the RSK or, rather, in the UN-protected area, the only
4 presence allowed is that of the police force, and now discussions are
5 taking place about the strength of the police force that should remain in
6 the area after the arrival of the United Nations peace forces.
7 Q. And Gracanin is talking about the Federal Ministry of Interior --
8 or the federal Secretary of the Interior giving 4.000. Are you aware of
10 A. It is not the federal secretariat providing the men. They are
11 charged with co-ordinating this issue with the bodies of the RSK, because
12 the RSK had asked for 34.000 men hailing from our area to be trained as
13 policemen. The co-ordinator was Petar Gracanin because the negotiations
14 around the Vance Plan were conducted on the level of Yugoslavia. In
15 other words, it was Yugoslavia negotiating with the United Nations the
16 implementation of the Vance Plan.
17 Q. Who gave 4.000 men?
18 A. We were supposed to provide them, at their proposal. In other
19 words, these were supposed to be individuals present in the RSK.
20 However, the original agreement -- or, rather, the agreement was only in
21 respect of 4.000 men, rather than 34.000 that we had requested, and I
22 suppose this was the result of the negotiations conducted between
23 Petar Gracanin and the United Nations.
24 Q. Did any of this involve the Republic of Serbia MUP?
25 A. The negotiations and meetings I attended did not include
1 representatives of the MUP of the Republic of Serbia. There were
2 representatives of the federal organs, General Staff, representatives of
3 what was at that time -- well, the Serbian part of Bosnia-Herzegovina.
4 MR. JORDASH: Let's go to page 27 of the B/C/S and 28 of the
6 Q. And to orientate yourself, the speaker here is Andjelko Maslic,
7 who was the general secretary of the Presidency of the SFRY. And he
8 notes, at page 28 of the English:
9 "They think that they will stay the day after tomorrow to hold a
10 session of the government and to adopt specific conclusions, obligations
11 that concern the arrival of the peace forces. There is a proposal that
12 Martic should explain the organisational plan of the Internal Affairs in
13 Krajina. A team working on producing the Law on Internal Affairs or,
14 rather, joining the laws that already exist in these parts, together with
15 certain amendments where they differ, adopt a single law. This has been
16 proposed for other laws too."
17 Are you able to cast any light on that remark?
18 A. After the refusal on the part of Milan Babic and some of the
19 deputies of the SDS to accept the Vance Plan, without his approval the
20 Assembly meeting in Glina accepted the Vance Plan. These were
21 preparations for a large Assembly session which was held in Borovo Selo,
22 where a new leadership of the RSK was elected. Goran Hadzic was elected
23 president, Mila Paspalj re-elected speaker of the Assembly, and I think
24 Mr. Zecevic was prime minister.
25 At that Assembly session there was no one from among Babic's
1 followers, if I can call him that, and I wasn't there either, where there
2 was the -- where there was a representation from Yugoslavia as well, as
3 we can see from these discussions.
4 Q. Did Mr. Stanisic, as far as you were aware, take part in any of
5 these meetings and negotiations and discussions?
6 A. As far as I know, no. And for the two or three Presidency
7 sessions that I attended, once there was Mr. Milosevic on behalf of
8 Serbia, once there was Mr. Bozovic, I think he was the prime minister of
9 Serbia, but also included were representatives of Montenegro,
10 Mr. Bulatovic and Momir Bulatovic, Biljana Plavsic, Radovan Karadzic from
11 Bosnia, at that last session when we were under pressure from them to
12 accept the Vance Plan and we refused. In other words, the meetings that
13 I attended did not include Mr. Stanisic. I'm sorry if I expanded in
14 answering your question.
15 Q. And finally, in relation to this Presidency session, you can see
16 at page 27 of the B/C/S and 27 of -- sorry, 28 of the English, the
17 continuation of that speech wherein it says:
18 "Just before going to the session, comrades from the federal SUP
19 informed me that when Martic comes today, they will try to co-ordinate
20 this again, but that there is an inclination to increase this number,
21 possibly by one battalion. I do not think that it should go beyond
22 10.000 or 12.000."
23 Can you cast any light on this and the discussions between the
24 federal SUP and Martic?
25 A. I didn't attend these discussions, so I wouldn't know about it.
1 It was only natural for Martic to be present there, in view of the fact
2 that a new government had not been elected yet. And the federal
3 government and its organs were a guarantor for our side in the
4 Vance Plan. That's why they co-ordinated their activities with Martic,
5 because the 4.000 men we asked for were supposed to constitute the local
6 police force.
7 Q. Thank you.
8 MR. JORDASH: May I tender this as an exhibit, Your Honours,
10 MS. MARCUS: No objection.
11 JUDGE ORIE: Madam Registrar.
12 THE REGISTRAR: This will be D318, Your Honours.
13 JUDGE ORIE: D318 is admitted into evidence.
14 Please proceed.
15 MR. JORDASH:
16 Q. So this is the final questions, Mr. Bosnic. You mentioned you
17 first met Mr. Stanisic in 1994; correct?
18 A. Yes.
19 Q. Did you ever meet him after that point?
20 A. No, not until I was called to testify to the events happening in
21 the Krajina and Croatia for the Defence.
22 Q. Did you speak to him during 1994 and afterwards until the point
23 where you were called to testify? Did you have any personal contact
25 A. No.
1 Q. Now, you spoke yesterday about speaking to Babic before he came
2 to The Hague, and are you able to just shed a little light on what you
3 perceived of his mental state at that point?
4 MS. MARCUS: Objection, Your Honour. I don't know that the
5 witness is a psychologist or can comment on someone's mental state.
6 JUDGE ORIE: Mr. Jordash.
7 MR. JORDASH: Well, I think the witness has said he was one of
8 his closest friends. He can indicate whether he felt --
9 JUDGE ORIE: He can make factual observations in relation to what
10 he considers may be in relation with the mental state of Mr. Babic. And
11 he should limit himself to that. Please proceed.
12 MR. JORDASH:
13 Q. Did you follow that, Mr. Bosnic? Could you limit yourself to
14 what you observed about Mr. Babic's mental state before he left to
15 The Hague?
16 A. The madam was right in saying that I am not a psychologist, but
17 we did know each other for a long time. What I experienced was first
18 great disappointment and then rage because nobody in Serbia would respond
19 to his requests to advise him on his subsequent steps and to help him
20 with his family. He was disappointed and angry. That's how I would
21 characterise him, in layman's terms.
22 Q. And you never saw him again before his sad and unfortunate
23 suicide; is that correct?
24 A. No, the last time I saw him was when he said that he would drag
25 into the mud everyone else along with himself. I saw him in person on
1 that occasion for the last time, and then I saw him while he was in
2 The Hague and I was shocked by his statements and demeanour. How shocked
3 I was you could tell from the opening remarks I made where I said, as the
4 saying goes in our people, that it is better for a man to lose his life
5 than his honour and honesty.
6 JUDGE ORIE: Mr. Jordash, I think we asked for factual
7 observations in relation to the mental state of Mr. Babic. What we get
8 in an answer to that is the apparent -- what this witness thinks about
9 Mr. Babic's behaviour. And I don't think that that's what we were asking
10 him for, because he is implicitly saying that Mr. Babic was not a man
11 honour, that's at least how I understand that, and that's not something
12 that I would expect as an answer to your question.
13 MR. JORDASH: Your Honour, if that's Your Honour's view, I accept
15 JUDGE ORIE: Yes. Let's proceed.
16 MR. JORDASH:
17 Q. So finally, Mr. Bosnic, having not known Mr. Stanisic but known
18 Mr. Babic very well, why did you decide to give evidence for the
19 Stanisic Defence?
20 A. Because Mr. Babic was not telling the truth, even though he was a
21 friend of mine and I still regard him as one. The Milan Babic I knew
22 between 1991 and 1995 and 1996 is not the same Babic who appeared before
23 this Tribunal.
24 MR. JORDASH: I've got nothing further.
25 Thank you, Mr. Bosnic. Thank you, Your Honours.
1 JUDGE ORIE: Thank you, Mr. Jordash.
2 Mr. Petrovic, are you ready to cross-examine the witness?
3 MR. PETROVIC: [Interpretation] I am, Your Honour.
4 JUDGE ORIE: Mr. Bosnic, you will now be cross-examined by
5 Mr. Petrovic. Mr. Petrovic is counsel for Mr. Simatovic.
6 MR. PETROVIC: [Interpretation] Thank you, Your Honours.
7 Cross-examination by Mr. Petrovic:
8 Q. [Interpretation] Good morning, Mr. Bosnic.
9 A. Good morning.
10 Q. I should like to follow up with a couple of questions, the topic
11 that you just discussed with my colleague, Mr. Jordash. Did you know
12 Mr. Babic's wife?
13 A. Yes, I do know her.
14 Q. Do you know whether Mr. Babic's wife addressed the public after
15 the demise of her husband? Do you know anything about it?
16 A. After coming to Belgrade she talked to the public, after actually
17 returning to Belgrade.
18 Q. Do you know anything about the content of her public address?
19 A. I read something about it. It was published in the "Politika,"
20 but I cannot recall the exact text.
21 Q. Thank you. Let us go through the questions which were raised
22 awhile ago while it is still fresh in our memories.
23 We looked at these minutes of the session of the SFRY Presidency
24 and a question was raised regarding the 4.000 policemen mentioned by
25 Petar Gracanin. My question to you is: Do you know that the federal
1 Secretariat of the Interior with Petar Gracanin at the helm at the time
2 was only proposing the structure of the MUP of the Republic of
3 Serbian Krajina; it actually only proposed how under the circumstances
4 that the ministry should look?
5 A. Yes, how it should look and what strength it should have when the
6 United Nations representatives came, because according to Vance Plan only
7 the police could carry arms.
8 Q. And the personnel and the command structure of the ministry would
9 remain as envisaged under the the laws of the Serbian Krajina at the
10 time; right?
11 A. Absolutely, that is correct. I cannot say in respect of every
12 individual, but to the best of my knowledge all the chiefs of the SUPs,
13 all the komandirs, all the chiefs remained working as policemen but only
14 had a larger complement of people assigned to them.
15 Q. Please, Mr. Bosnic, let us pause between question and answer
16 because we speak the same language and it is difficult for the
17 interpreters to keep abreast of us.
18 Tell me, let us briefly touch upon the question of the Vance
19 Plan. Perhaps it was not quite clear to me what capacity you
20 participated in the negotiations regarding the Vance Plan Assembly?
21 A. The Assembly actually elected 7 MPs who represented the Assembly
22 of the Serbian Krajina in these negotiations in the Presidency of
24 Q. So you were one these seven elected representatives?
25 A. Yes.
1 Q. The seven-member delegation that we are talking about negotiated
2 with whom; who was the second or the third negotiating side in the
4 A. These meetings in the Presidency were actually pressure exerted
5 on the leadership of the Republic of the Serbian Krajina to accept the
6 Vance Plan. In addition to ourselves, to us seven, there were four
7 members of the Presidency: Yugoslav Kostic, Branko Kostic,
8 Sejdo Bajramovic, and a fourth one whose name I cannot recall at this
9 point. So representatives of the federal government, the minister of the
10 interior, the federal one, Petar Gracanin, the Chief of General Staff
11 Blagoje Adzic, representatives of Montenegro, Milo Djukanovic,
12 Momir Bulatovic, et cetera.
13 Q. Thank you. Mr. Bosnic, were you familiar with the draft of that
14 agreement which was to be signed on behalf of both the Republic of the
15 Serbian Krajina and the Socialist Federal Republic of Yugoslavia at the
16 time? Do you know what the basic content of the agreement was?
17 A. Yes, of course.
18 Q. Can you tell us: What was in the proposed draft agreement that
19 posed the greatest problem to you from the Republic of the
20 Serbian Krajina for you to accept the offered text of the agreement?
21 A. Well, the basic thing was that in the preamble of the Vance Plan
22 it was written that it was Croatian territory under the protection of the
23 United Nations, whereas we thought that they were coming to conditionally
24 return us to the Republic of Croatia. Secondly, we asked in the military
25 section to apply the system of dividing the warring parties and not an
1 ink-blot system. And thirdly, we were not sure how much -- we were not
2 certain how secure we would be if the JNA left the territory, and we
3 wanted the Serbian areas which did not belong to the Serbian
4 municipalities in the area of the Republic of Serbian Krajina to be also
5 covered by the Vance Plan.
6 Q. As far as I understood your answer now, these are the sticking
7 points between you and what the positions of the Socialist Federal
8 Republic of Yugoslavia were at the time; is that correct?
9 A. Yes.
10 Q. Tell us, was this agreement finally accepted and how was it
12 A. Well, eventually it was accepted with opposition on the part of
13 Milan Babic, myself, and some other people. It was accepted on behalf of
14 the Assembly of the Republic of the Serbian Krajina by the president of
15 the Assembly and a member of our delegation, Mile Paspalj, who, like
16 ourselves, up to the last minute of that meeting which lasted about
17 50 minutes was opposed to the Vance Plan.
18 Q. On the basis of -- on what basis did Mile Paspalj accept that
19 agreement on behalf of the Republic of the Serbian Krajina?
20 A. It was actually a trick. Although Milan Babic was in Belgrade,
21 he was not in the Presidency then. The explanation was that Milan Babic
22 could not attend the session and being absent and he was deputised for by
23 the speaker, by the president of the Assembly.
24 Q. Just a second. In listing the present members of the SFRY
25 Presidency, Borislav Jovic was not mentioned. Did he participate in
1 these negotiations?
2 A. Yes, he did participate. And sometimes he chaired the sessions
3 and sometimes it was Branko Kostic, the representative of Montenegro, who
4 presided over these sessions.
5 Q. Thank you. After the signing of this agreement in the way that
6 you have described, did the peace forces of the United Nations deploy --
7 start to deploy in the field in the territory of the Republic of Croatia,
8 i.e., the Republic of the Serbian Krajina?
9 A. Yes. Because we could do nothing through our organs of
10 authority, in agreement with Serbia we opted to accept the United Nations
11 forces. But according to the Vance Plan, they communicated with, as they
12 put it, the local authorities and the local leaders, including myself.
13 Q. By the signing of this agreement and the deployment of their
14 forces, did the UN -- of the UN, after that did the war stop in the area?
15 A. In that stage, yes, it did.
16 Q. What were the relations like between Milan Babic and the
17 representatives of the SFRY, later the FRY, after the events that we are
18 talking about, namely the signing and acceptance of the Vance Plan?
19 A. The relations cooled and Milan Babic practically remained without
20 any levers of power, but he managed to remain the mayor of Knin
22 Q. Did Milan Babic try to form some sort of a new military
23 organisation after the signing of the Vance agreement?
24 A. I don't know, unless you mean the "Garda King Peter,"
25 King Peter's Guard.
1 Q. Well, I should ask you specifically. First let me ask you this,
2 although you have already said so: So the Vance Plan prohibited the
3 existence of military units in the territory of the Republic of the
4 Serbian Krajina; right?
5 A. Right.
6 Q. Are you aware of the fact that in April 1992 Babic gathered some
7 members of the territory in the defence of the MUP of the Krajina and
8 tried to establish the so-called Serbian army? This was in the village
9 of Kosevo, not far from Knin.
10 A. I did not participate in that, but I had heard about it.
11 MR. PETROVIC: [Interpretation] Will the witness be shown
12 Exhibit P1999.
13 Q. Mr. Witness, please take a look at the first paragraph of this
14 document of the Prosecutor and tell me whether what is in the first
15 paragraph is consistent with your memory of the events that we have just
16 discussed. Just the first paragraph.
17 A. I know the people who are referred to here. They are from the
18 SDS leadership, so that they probably attended this gathering, but I
19 myself did not, so --
20 Q. All right. Please just tell us, if you know, who Mirko Jovic is,
21 who is mentioned as one of the people attending this gathering.
22 A. Mirko Jovic was the president of one right-wing party in Serbia,
23 and I believe that he had some sort of a paramilitary unit. Whether they
24 were some White Eagles or something like that, I'm not quite certain
25 about that.
1 Q. Do you know anything about the political options of Mirko Jovic?
2 A. No, nothing in particular, except that he was of the
3 right-wing hue and that he did not represent any relevant force in Serbia
4 and that he had this unit. This paramilitary unit which I believe
5 participated in fighting in Western Slavonia and Bosnia, but don't take
6 my word for it.
7 JUDGE ORIE: Mr. Petrovic, I hear that you're encouraging the
8 witness to make a pause. I encourage you to do the same.
9 MR. PETROVIC: [Interpretation] I apologise, Your Honours. I
10 should do my best.
11 Can we have page 3 shown to the witness in the B/C/S. I believe
12 that it is also the third page in the English version.
13 Q. Mr. Witness, please take a look at the first paragraph on page 3.
14 MR. PETROVIC: [Interpretation] And for Your Honours, I believe
15 that we shall -- I hope that we shall soon have the English-language
16 version on the screen. Yes, it is the second paragraph in the English.
17 Q. Mr. Witness, have you taken a look at it?
18 A. Yes.
19 Q. My question to you is this: Did the Vance Plan foresee that all
20 weapons of the former Army of the Republic of the Serbian Krajina would
21 be stored and would be kept under key, practically that the army would be
23 A. Yes, according to the double-key system. The keys to the
24 storehouse would be held by a representative of the United Nations and a
25 representative of the Territorial Defence after the disarming.
1 Q. The call, which we can see in this paragraph, to the effect that
2 weapons should not be returned, which was actually made by Mirko Jovic,
3 is a call to violate the Vance agreement which had been accepted a couple
4 of months before that?
5 A. Yes.
6 Q. This attempt at creating a Serbian army, had it been successful,
7 would have been a violation of the provisions of the Vance agreement; is
8 that not correct?
9 A. Yes, it would. It would have been that.
10 Q. Mr. Witness, yesterday you referred to the fact that the policy
11 of the SDS was to actually pre-empt every step of the Croatian status by
12 an adequate move on the part of the Republic of the Serbian Krajina?
13 A. Yes, that was the general concept in principle how we functioned.
14 Q. And if I understood you correctly, that meant that if Croatia
15 organized a referendum, the Serbian Krajina would organise a referendum
16 also. And, in fact, before, if Croatia was to amend its constitution,
17 the Serbs would also adopt their constitution.
18 Tell me, what was the position vis-à-vis secession; what was the
19 position of the Serbian Democratic Party with Milan Babic at the helm
20 regarding the question of secession?
21 A. We were absolutely against Croatia leaving Yugoslavia. We as a
22 constituent people were absolutely against it. And if it remained in
23 Yugoslavia, we wanted to have a certain form of territorial autonomy.
24 But if they wanted to leave Yugoslavia by force, we also wanted to
25 exercise our right as the second constituent people and remain within
2 Q. If my understanding is correct, the SDS policy under the
3 leadership of Milan Babic was as follows: If Croatia were to secede from
4 Yugoslavia, the next step would be the secession of Krajina from Croatia?
5 A. Absolutely. Because the Serbs and Croats had formed the Croatia
6 of AVNOJ, A-V-N-O-J, together; and if we are parting ways, then this was
7 the way it was going to unfold.
8 Q. Thank you, witness.
9 MR. PETROVIC: [Interpretation] I would like you to look at 2D874
10 now. Your Honours, this is a document we received as part of disclosures
11 from the Prosecution. Unfortunately, we don't have a translation of the
12 document, so I won't be tendering it at this stage. I would only like
13 the witness to look at the document, tell us if he knows anything about
14 it, and to comment on the signature.
15 JUDGE ORIE: If Ms. Marcus sent you an e-mail, Mr. Petrovic, I
16 would certainly read that next time. The Chamber was copied on it.
17 "Dear," and then one of your team members, "please note that the
18 Prosecution has identified 2D0874 as contained within P1884, pages 4
19 to 8."
20 Ms. Marcus, this was your message, wasn't it?
21 MS. MARCUS: Yes, Your Honour.
22 JUDGE ORIE: So therefore, Mr. Petrovic, never forget to open
23 your inbox. Please proceed.
24 MR. PETROVIC: [Interpretation] Thank you, Your Honour. I spoke
25 to my learned friend just before the start of the session but I didn't
1 realise that she was so prompt and managed to send an e-mail. Thank you,
2 Your Honour, for correcting my mistake.
3 Q. Witness, let's look at P1884 then, pages 4 in English -- or 4 in
4 B/C/S, sorry, and 3 in English. Let's look at the last page as well.
5 Witness, were you able to look through the document and do you know what
6 this is about? Are you familiar with the letter?
7 A. Yes.
8 Q. It was sent on the 11th of January, 1992. Do you know what this
9 is all about?
10 A. Yes, I do.
11 Q. Can you tell us briefly what sort of document this is, and what
12 circumstances was it drafted and sent out?
13 A. This is a letter that Milan Babic sent out in response to
14 Mr. Milosevic's letter. In that letter, Milosevic criticised Babic's
15 position and our position in respect of the Vance Plan, and this is where
16 Babic responds to that criticism.
17 Q. Rather than reading the contents of the document, can you tell
18 us, from your memory, what sort of response Babic wrote?
19 A. From what I remember, Babic laid out the reasons for our
20 objections to the Vance Plan.
21 Q. Their Honours will have an opportunity to read through and
22 examine the letter. I would not wish to dwell upon it.
23 Mr. Witness, I'd like to put several questions to you now
24 concerning your statement. I will be looking to clarify certain issues
25 that I believe important. In paragraph 4 of your statement, which is
1 D313, reference is made to the arming of the reserve police. Can you
2 tell us where these weapons were kept, what their intended purpose was,
3 and how the weapons were stored in the pre-war period.
4 A. The weapons were kept in the police station under key and would
5 be distributed only in times of war or imminent threat of war to the
6 reserve force. These were individuals who went about doing their day
7 jobs and would only under these circumstances become part of the reserve
9 Q. These members of the reserve force, where would they report to
10 duty and pick up these weapons that were intended for them?
11 A. This would take place in the municipalities where they resided.
12 Q. Thank you. In paragraph 5 of your statement, mention is made of
13 a joint commission for night guards. Can you tell us who was in charge
14 of the night guards you mentioned in paragraph 5?
15 A. I was speaking about Kordun, and the SDS was in charge of the
16 night guards.
17 Q. Thank you. In paragraph 11 of your statement, the events of the
18 17th and the 18th are discussed.
19 MR. PETROVIC: [Interpretation] Your Honours, can the witness be
20 shown D313, please, paragraph 11, so that the witness may know exactly
21 what I'm referring to. Paragraph 11, please. Page 4 in B/C/S and page 4
22 in English.
23 Q. Witness, the events of August 1990 are related here. You say the
24 Croatians who had come to take their weapons were thrown out. Which
25 Croatians does this refer to?
1 A. They were not allowed to come over and take the weapons, the
2 Croatian police from Split, Sibenik, or Zadar; they were supposed to take
3 over the weapons of the reserve force. They were not allowed to do so.
4 They were stopped on their way by the roadblocks.
5 Q. That's clear. Thank you. Let's look at paragraph 14, page 5 in
6 both versions. A host of individuals are mentioned here, Mile Martic in
7 Knin, David Rastovic in Lapac, Sergej Veselinovic in Obrovac, and
8 Zdravko Zecevic in Benkovac. Can you tell us, what were the elections at
9 which these individuals were elected to the posts you relate in
10 paragraph 14?
11 A. At the multi-party elections in the Socialist Republic of Croatia
12 in 1990.
13 Q. The legality of their activity in occupying these posts was
14 achieved through the multi-party elections held across Croatia; is that
16 A. Yes.
17 Q. Witness, I have several questions which concern your town.
18 First, your statement mentions General Pekic and Admiral Branko Mamula as
19 individuals who took part in the procurement of weapons of the JNA for
20 the members of the TO and other formations of what was SAO Krajina at the
21 time. Can you tell us who these two individuals, Pekic and Mamula, were?
22 A. One of them is a retired general and the other a retired Admiral
23 who had for a while been the Chief of the General Staff of the JNA who
24 hailed from the area of Kordun, specifically Vojnic and Vrginmost.
25 Q. Unless I'm mistaken, Mamula was also a federal minister of
1 defence for a long period of time in the former SFRY?
2 A. Yes. Yes, I must have mistaken it for the Chief of
3 General Staff. I knew that he had the highest-ranking position in the
4 Army of the SFRY.
5 Q. Witness, what was the ethnic makeup of the population in Slunj
6 before the outbreak of hostilities?
7 A. Before the outbreak of hostilities, the majority population of
8 the municipality were Croats. And this was the consequence of the Serbs
9 who up until the Second World War were a majority there but had perished
10 during the war.
11 Q. So we will agree that in the municipality of Slunj the majority
12 population was Croat?
13 A. Yes.
14 Q. Where was the location of the JNA unit closest to the town of
16 A. The closest JNA unit was the one stationed at the Slunj
17 training-grounds, but it was a very small unit. In fact, it was just a
18 technical maintenance service.
19 Q. Did there come a time in the autumn of 1991 that the command of
20 the 5th JNA district was relocated to the Slunj training-grounds?
21 A. Yes. I don't know if it was just elements of the command or the
22 entire command. There was a Macedonian who was commander, and the chief
23 was Cedomir Bulat, an individual who hailed from the area and who we were
24 in communication with.
25 Q. Very well. When did you leave Slunj, when did you leave town?
1 A. I never lived in Slunj, but you probably meant the Serbian -- the
2 Serb population.
3 Q. Yes, the Serb population.
4 A. In late July and early August.
5 Q. And at that point in time there only remained the Croat
6 population in Slunj; right? For the most part.
7 A. The great majority of the Serbs left Slunj, I think 90 per cent
8 of them.
9 Q. Can you tell us, at which point did the JNA get involved in the
10 combat activities in the area of Slunj?
11 A. In the second half of November 1991.
12 Q. Can you tell us, how did the JNA come to be involved in the
13 fighting in the area of the municipality of Slunj?
14 A. What I know is from what Mr. Cedo Bulat told me. He asked the
15 Croatian authorities to lay their weapons down, to discontinue the siege
16 of the training-grounds and to stop firing on them, because they did, and
17 told them that if they did so, they would be able to remain to live in
18 the area.
19 Q. Did at some point Mr. Cedo Bulat issue an ultimatum to the
20 authorities in Slunj?
21 A. I think that it happened on the 15th of November, 1991.
22 Q. What was the ultimatum exactly and what was the response to it?
23 A. As I said a moment ago, the Croats did not respond to the
24 ultimatum. However, during the night, the better part of the civilian
25 population, members of the Croatian National Guard, and the Croatian
1 forces withdrew from Slunj in the direction of Velika Kladusa and then on
2 to the Republic of Croatia.
3 Q. How many Croats remained in Slunj after the departure you
4 referred to?
5 A. Very few. 100, 200. I can't tell you exactly.
6 Q. So practically the entire population of Slunj moved out on this
7 particular occasion?
8 A. Those who stayed behind were mostly elderly people or people who
9 refused to leave their homes.
10 Q. But can you give me an assessment of their numbers? I don't mean
11 absolute numbers, I mean percentages. In other words, what percentage of
12 the Croat population stayed in the town of Slunj after this particular
14 A. Several. Five per cent.
15 Q. Thank you.
16 MR. PETROVIC: [Interpretation] Your Honours, can we now play a
17 video-clip for the witness. This is an exhibit marked 2D872.1. It's a
18 video that was disclosed to us by the Prosecution. The interpreters were
19 given transcripts. Can we look at the clip that starts at 10 minutes,
20 51 seconds, until 12:35, with your leave.
21 JUDGE ORIE: Please.
22 [Video-clip played]
23 THE INTERPRETER: [Voiceover] "Look, I have come here as the
24 so-called Milorad Pupovac from, as you say, the so-called Croatia, here
25 to the so-called Krajina, as they say there where I come from ... and I
1 came not to tell you how everything around us is so-called in various ...
2 Because things have gotten serious a long time ago.
3 "Presenter: This sensible message was simply laughed at by the
4 assembled Serbian people of Knin. Milan Babic, accompanied by the Knin
5 political elite, walked out of the hall insolently.
6 "Milorad Pupovac: None of you will say, I'm certain, that you're
7 against peace, and none of you, I'm certain, will say that they are
8 against a national agreement, because if they were to do that, they would
9 be condemning something that it certainly neither in the interest of the
10 individual, nor of the Serbian people on the whole, nor of the Serbian
11 people in Croatia, and neither of those with whom you live side by side
12 here who are a majority, and that is the Croats.
13 "Zoran Pusic: There are many of you in the large hall, where I
14 and my colleagues and my friends have come to talk with you.
15 "Unidentified voice: And you are cowards, Ustashas, criminals,
16 cowards, wretches, vampires.
17 "Presenter: The colours of Croatia and the city of Zagreb were
18 also defended at this peace forum in Knin by Messrs. Palasek, Viskovic,
19 and Pusic. For all those who had assembled, they were just Ustashas and
21 Q. Witness, I have several questions concerning this clip. First
22 off, do you -- did you recognise the first speaker whom we just saw?
23 A. Milorad Pupovac, a Serbian intellectual from Benkovac who lives
24 in Zagreb.
25 Q. Mr. Witness, to the best of your knowledge, today is
1 Milorad Pupovac the vice-president of the Autonomous Serbian Democratic
2 Party, which is part of the ruling coalition in the Republic of Croatia?
3 A. Yes.
4 Q. Do you know about this meeting or about any other meetings that
5 Pupovac and his -- those of the same ilk as Pupovac tried to organise in
6 the territory of the Republic of the Serbian Krajina in the spring of
8 A. There were a number of such attempts, one was in Karlovac, for
9 Serbian intellectuals to issue a communique in which they are invited to
10 talks. The second was this by Pupovac. We from Banija and Kordun also
11 had a talk with Pupovac in Petrinje but not as a panel meeting but only a
12 couple of representatives.
13 Q. Do you know about this event when Milan Babic demonstratively
14 walked out of this gathering with his associates?
15 A. I only know from what people said that they demonstratively left
16 the meeting because Milan Babic [as interpreted] had come to pull the
17 wool over their eyes from Zagreb, as it were.
18 THE INTERPRETER: Interpreter's correction: Milorad Pupovac, not
19 Milan Babic.
20 MR. PETROVIC: [Interpretation]
21 Q. I should like to tender this document as a Defence exhibit.
22 JUDGE ORIE: Ms. Marcus.
23 MS. MARCUS: Yes, Your Honour, we're trying to look into
24 information. It's true that this came from our archives. We're trying
25 to look into the origin of it. So I can't provide my response until we
1 find out what the origin is. So it if could be MFI'd for now.
2 MR. PETROVIC: [Interpretation] Perhaps I could be of assistance.
3 That is V00425-1-A. That is your number. I believe that that can be of
4 assistance in locating the actual cassette.
5 MS. MARCUS: Thank you.
6 JUDGE ORIE: Yes, the video will be MFI'd. Have you upload the
7 transcript as well, Mr. Petrovic?
8 MR. PETROVIC: [Interpretation] Your Honours, it is in the B/C/S,
9 uploaded in the B/C/S, and we got the English translation only prior to
10 this session, so it will be uploaded in the shortest time possible.
11 JUDGE ORIE: Thank you for that.
12 Madam Registrar, the number would be ...
13 THE REGISTRAR: The number would be D319 MFI'd, Your Honours.
14 JUDGE ORIE: D319 keeps that status until we have further heard
15 from Ms. Marcus.
16 Mr. Petrovic, the Chamber is wondering how far we are away from
17 the case which is before us with these questions. The relevance of quite
18 a lot of details is rather unclear to us. Please proceed.
19 MR. PETROVIC: [Interpretation] Thank you, Your Honours. I shall
20 try to focus on other questions.
21 JUDGE ORIE: And how long do you think you would need?
22 MR. PETROVIC: [Interpretation] Your Honours, I believe
23 25 minutes, half an hour at most.
24 JUDGE ORIE: Yes. So I'm just asking myself whether that would
25 be possible to conclude before the next break if we would take the break
1 slightly later.
2 But, Mr. Jordash, I also leave it to some extent to the
3 Stanisic Defence. Often it's good to finish before the break a portion
4 of the examination. If that would be possible, it would be appreciated.
5 Mr. Petrovic, could you please be very focused. We'll see how
6 matters develop. Please proceed.
7 MR. PETROVIC: [Interpretation] I shall do my best, Your Honours.
8 The break is at 12.20; am I correct?
9 JUDGE ORIE: Yes, that's usually the time where we take a break,
10 even a bit earlier, 75 minutes. I think we restarted at 5 minutes to
11 11.00 approximately, and so 75 minutes is the usual time. If it would be
12 five or ten minutes more and if you could conclude, we could consider
13 that. If not, we would give you a certain portion of time after the
14 break. Please proceed.
15 MR. PETROVIC: [Interpretation] Thank you, Your Honours. I shall
16 do my very best.
17 Q. Mr. Witness, today you mentioned, and that is on page 19, that in
18 June or July 1991, as you said, some events happened in Glina.
19 MR. PETROVIC: [Interpretation] Can we look at 2D873. This is a
20 document that the Prosecution received from the Republic of Croatia. Can
21 we please have page 3 on the screen, that is, in the B/C/S. And also
22 the -- and just a minute. And also the third page in the English
24 Q. Mr. Witness, this is a decision on conducting an investigation
25 against Dragan Vasiljkovic, Captain Dragan, which was adopted by the
1 county court in Osijek. Please, I refer you to this part under 3. It is
2 stated there that on the 26th of July, 1991, in Glina during an armed
3 conflicts, Captain Dragan, in agreement with JNA Captain Rapajic,
4 perpetrated the criminal offence that they are charged with, which is not
5 what we are right now interested in. Do you accept that this event in
6 Glina took place as described here in the decision on conducting an
7 investigation of the 26th of July, 1991?
8 A. It is correct. This took place in July. I was not certain of
9 the exact date.
10 Q. Mr. Witness, it is stated here that Captain Dragan, in
11 co-ordination with a tank unit of the JNA, participated in that attack.
12 Is that consistent with what you know about events in Glina in the period
14 A. Not only in Glina but generally speaking all military actions and
15 operations were carried out in co-ordination with and under the command
16 of the JNA.
17 Q. As regards this particular action in Glina in which
18 Captain Dragan also participated, was there perhaps special media
19 coverage of that action? Was it widely covered by the media and
21 A. This action was very widely covered by the media. It was in the
23 Q. Mr. Witness, you state in your statement --
24 MR. PETROVIC: [Interpretation] But, Your Honours, may I first
25 tender 2D873 as a Defence exhibit.
1 MS. MARCUS: No objection.
2 JUDGE ORIE: Madam Registrar.
3 THE REGISTRAR: That would be D320, Your Honours.
4 JUDGE ORIE: D320 is admitted into evidence. Please proceed.
5 MR. PETROVIC: [Interpretation] Thank you, Your Honours.
6 Q. Mr. Witness, in your statement you say in paragraph 58 that
7 Captain Dragan started interfering in politics. This interfering of his
8 in politics, was that -- did that start after this action, after this
9 publicity that Captain Dragan had acquired after this action in Glina?
10 A. It was immediately after that action that he became, as they
11 said, a media star.
12 Q. To the best of your knowledge did Captain Dragan actually
13 believe, come to believe, that he could play some sort of a political
14 role in the SAO Krajina?
15 A. Well, he did make statements along those lines. The parties were
16 not good, the people in charge of the parties were not good, in the JNA
17 there were quite a few incompetent officers, but he was competent as he
18 had demonstrated by that action. He was ready, able, and willing to lead
19 and to make decisions.
20 Q. Mr. Witness, immediately after this action, as I understand your
21 statement, there was a total falling out between Captain Dragan and
22 Milan Babic?
23 A. Yes. Because the stance was that by such statements and his
24 analysis of the work of the SDS, by that Captain Dragan actually sought
25 to interfere in political life and the functioning of the political
1 system in the Republic of the Serbian Krajina, generally speaking, which
2 then was the SAO Krajina.
3 Q. After this parting, did Captain Dragan immediately leave the
4 territory of SAO Krajina?
5 A. I don't know exactly how much time had passed, but, yes, after
6 that conflict Captain Dragan did leave the territory of Krajina. And at
7 a certain point Vojislav Seselj came to Benkovac, there was a gathering,
8 and he asked Captain Dragan to respect the civilian authorities and to
9 comply with the decisions of the civilian authorities with Milan Babic at
10 the helm whether he agreed with him or not.
11 Q. In your statement you say that Milan Babic felt threatened by
12 Captain Dragan. Can we conclude from that that Milan Babic actually
13 solved this conflict very efficiently to his advantage because
14 Captain Dragan left?
15 A. Yes, this conflict was resolved in Babic's favour.
16 Q. And Captain Dragan did not reappear in the Krajina until 1993,
17 until the camp in Bruska was established?
18 A. As far as I know, no, he did not. I never saw him nor was there
19 any information published about his coming in the media. He was already
20 referred to for the first time after that when the so-called Alfa camp
21 was set up in Bruska. I believe that that was what it was called.
22 Q. Thank you. Can you tell us - and now I will move on to a
23 different topic, trying to keep within my allotted time-limits - on the
24 31st of March, 1991, what happened at Plitvice? Briefly.
25 A. There was an incursion by special Croatian units. There were
1 skirmishes, there were shootings. The first victims fell and the
2 Croatian police actually took a feature at Plitvice lakes.
3 Q. Thank you.
4 MR. PETROVIC: [Interpretation] We shall now see a video, a very
5 short one. It is only one minute. It is 2D872.2. It is from the same
6 collection of the Prosecution as the video which I showed awhile ago.
7 Let us see a very short piece of footage.
8 [Video-clip played]
9 MR. PETROVIC: [Interpretation] And I refer the witness to the
10 equipment and to the armaments of the people that we can see.
11 [Video-clip played]
12 MR. PETROVIC: [Interpretation] Thank you. I believe that that is
14 Q. Mr. Witness, can you recognise, although my question is senseless
15 in a way because it is written on the video, but was this filmed in
16 Korenica? Do you recognise that this is Korenica?
17 A. Well, I cannot recognise it from this angle. I came to meetings
18 in my car, and if it were in Plitvice, I would probably recognise it but
19 not in this way.
20 Q. I wish to ask you this: You mentioned village guards armed with
21 hunting weapons in your statement. Did those guards look like the people
22 that we see in these -- in this footage?
23 A. Exactly. And this person who -- this man who told me about the
24 ripping of the flag is carrying a hunting rifle used to hunt pheasant and
25 hare, rabbits.
1 Q. Thank you, witness.
2 MR. PETROVIC: [Interpretation] Your Honours, I should like to
3 tender this video as a Defence exhibit if there are no objections, of
5 MS. MARCUS: Same objection as before, Your Honour.
6 JUDGE ORIE: Yes, you would like to have it marked for
8 Mr. Petrovic, did I hear any sound? Or ...
9 MR. PETROVIC: [Interpretation] Your Honours, there should have
10 been sound, but I don't know whether there was. The transcripts exist.
11 It was the same situation as with the previous video. But I'm not sure
12 what the situation was on your channel. In the B/C/S channel there was
13 no sound. But there should be sound, there must be sound. Shall we play
14 it again?
15 JUDGE ORIE: Well, you may do so, but since the witness
16 apparently is referring to the words spoken, then before we accept it as
17 evidence I'd like to hear what was said.
18 Yes, now, one thing: If it is just about hunting rifles and if
19 it's just about that the witness doesn't know where it is, then you could
20 even ask yourself what -- the Prosecution might agree with you - that the
21 people shown on this video, wherever it may come from, having hunting
22 rifles and are not in uniforms. That's the most I think I can make of
23 it. Is that what you want to establish?
24 MR. PETROVIC: [Interpretation] Yes, Your Honours.
25 JUDGE ORIE: Let's see whether the Prosecution would agree with
1 you that a video exists which says that it is from Korenica and the date
2 you mentioned, that it refers to Plitvice and the date the witness
3 mentioned, and that we see on that video several persons not in uniform
4 apparently having hunting rifles on their shoulders. If that is -- if
5 the Prosecution could agree on that.
6 MS. MARCUS: Yes, Your Honour. On that limited statement that
7 Your Honour just put, yes, we agree.
8 JUDGE ORIE: What is there anything more, Mr. Petrovic?
9 MR. PETROVIC: [Interpretation] Your Honours, nothing more. I
10 thought that the witness would recognise the video. Perhaps if I had
11 played a longer portion he would have recognised it, but I'm satisfied
12 with this --
13 JUDGE ORIE: There seems to be full agreement between the parties
14 on what I just mentioned. So therefore there's no need to replay, and I
15 take it that there's also no need further to tender this video.
16 Please proceed, Mr. Petrovic.
17 MR. PETROVIC: [Interpretation] Thank you, Your Honours.
18 Q. Mr. Witness, in your statement you refer to Slobodan Lazarevic.
19 That is in paragraph 84 of your statement. Do you know whether
20 Lazarevic, at the time that you speak about, namely from 1991 to --
21 rather, from 1992 to 1995 was stationed in Topusko?
22 A. Yes, from 1992 to 1992 --
23 THE INTERPRETER: As the witness said.
24 THE WITNESS: [Interpretation] -- he lived and worked in
25 Velika Kladusa.
1 Q. Perhaps I didn't understand you correctly. So it was during the
2 war. From 1992 where was he? Was he in Topusko or in Kladusa?
3 A. Up to 1992 he was in Velika Kladusa, up to the point when the
4 conflict broke up in Bosnia-Herzegovina, and then he moved to Topusko.
5 Q. Did you ever visit him in his offices in Topusko?
6 A. No, not in his offices. But I would see him in Topusko and Slunj
7 because we became acquaintances in 1986 and we were on visiting terms as
8 well, since I used to work in Velika Kladusa.
9 Q. Did he ever tell you that in the building housing his offices in
10 Topusko also housed representatives of certain forces from Serbia? Did
11 he make any statements to that effect?
12 A. No, he never told me that.
13 Q. Do you happen to know if after the war Lazarevic was in real
14 estate business in Belgrade, in Serbia?
15 A. We would come across each other in Belgrade, and I also came to
16 visit him in his flat in Belgrade with my wife. He told me that he had a
17 company which was registered in the Hotel Serbia in Belgrade, and I think
18 he told me that his company was selling caravans, something to that
19 effect, in Spain. Not the real estate.
20 Q. Do you know under what circumstances Lazarevic left Belgrade and
22 A. I didn't hear it from him but I heard it from our common
23 acquaintance that he was forced to leave because of the debts and
24 financial embezzlement in his company.
25 Q. Thank you. Let's kindly clarify one other point. We agreed a
1 moment ago that Captain Dragan left in August of 1991; is that right?
2 A. I don't know the precise date. That's roughly the period.
3 Q. In the course of your testimony today you mentioned a place
4 called Skabrnja. Did you participate in any events connected to
6 A. No. I only have indirect knowledge from Ranko Lazaric, who was a
7 party colleague and president of the executive body in Benkovac.
8 Q. Will you agree with me that the events in Skabrnja happened in
9 the second half of November 1991?
10 A. I suppose so. I don't know the exact date.
11 Q. You mentioned an armoured train today. Do you know who made it?
12 A. It was manufactured in Knin in order to show that we had a
13 running train, and the only operational railway check was between
14 Benkovac and Knin.
15 Q. And did it have any defence significance?
16 A. No, it was more of a support to boost the morale of the local
17 population. I don't know that it was used in any operation.
18 Q. Do you know who paid for its manufacture?
19 A. As far as I know, the municipality of Knin or all of the
20 municipalities of Lika and Dalmatia. But I know that it was the workers
21 in Knin working for the Tvik factory, I believe, who produced it. I'm
22 not sure.
23 Q. Thank you, witness.
24 MR. PETROVIC: [Interpretation] Thank you, Your Honours, I have no
25 further questions for the witness.
1 JUDGE ORIE: Thank you, Mr. Petrovic.
2 We'll now take a break. Ms. Marcus, are you ready to start your
3 cross-examination after the break?
4 MS. MARCUS: Yes, Your Honour.
5 JUDGE ORIE: Mr. Jordash, I haven't heard a summary, and you know
6 what we usually did if the Prosecution had no summary ready to be read --
7 oh, you have one ready, because otherwise I would invite you to file it.
8 MR. JORDASH: I'm happy whichever way you want to proceed.
9 JUDGE ORIE: Yes, of course it is usually in order to inform the
10 public at the beginning so that they better understand the -- that they
11 better understand the evidence. Would you please consider over the break
12 whether you would prefer to file it or to read it.
13 MR. JORDASH: Your Honour, yes.
14 JUDGE ORIE: And we'll resume at a quarter to 1.00
15 --- Recess taken at 12.20 p.m.
16 --- On resuming at 12.49 p.m.
17 JUDGE ORIE: Ms. Marcus, you are ready --
18 Yes, Mr. --
19 MR. JORDASH: Sorry to interrupt. Could I just indicate that
20 we'll file the summary, if that's okay with Your Honours.
21 JUDGE ORIE: That's as matters stand now. Of course, we prefer
22 it to be read but then at the beginning of the testimony.
23 Mr. Bosnic, you'll now be cross-examine by Ms. Marcus.
24 Ms. Marcus is counsel for the Prosecution.
25 Please proceed.
1 MS. MARCUS: Thank you, Your Honour.
2 Cross-examination by Ms. Marcus:
3 Q. Good afternoon, Mr. Bosnic.
4 A. Good afternoon.
5 MS. MARCUS: Your Honours, before I commence the cross
6 examination, I wanted to first of all request again that before we
7 adjourn today, if possible, we receive some kind of a response from the
8 Stanisic Defence with respect to the statements. For DST-074, who is the
9 witness after DST-043, we have received nothing, no applications, no
10 statement, no motions, et cetera.
11 JUDGE ORIE: We'll reserve the last five minutes so that you have
12 an opportunity to respond, Mr. Jordash.
13 Please proceed.
14 MS. MARCUS: Thank you. I have one more point I wanted to put on
15 the record with respect to the RFAs. The quantity actually turned out to
16 be about 400 pages of materials that we received from the Government of
17 Croatia. That said, we are doing our absolute utmost to identify those
18 documents within that response that we may need to use and even to try to
19 get urgent translations of those selections. We have identified some
20 duplications of documents that we may already of have. I'm cautiously
21 optimistic that we might be able to go through that, but I would still
22 like to observe the option possibly needing to either re-call the witness
23 or keep him somehow for cross-examination on matters that arose in that
24 response. We are doing our best, Your Honour.
25 JUDGE ORIE: That's on the record.
1 MS. MARCUS:
2 Q. Mr. Bosnic, in paragraph 3 of your statement, you say that the
3 SDS was not regarded as an extremist party. A bit later, in
4 paragraphs 14 to 16, you describe the events leading up to the final
5 split, as you called it, which resulted in Martic and Babic being the
6 leaders of the SDS. Would you agree with me that Raskovic and Soskocanin
7 were moderates within the SDS?
8 A. Well, I wouldn't agree.
9 Q. How would you have viewed them, their positions, then?
10 A. Our views coincided until Professor Raskovic and Zelenbaba and
11 that third individual suggested that we embark on the adventure of
12 participating in the elections in the Republic of Serbia.
13 Q. Would you agree, then, that Raskovic was gradually marginalised
14 over time, as the party became more extreme?
15 A. The party did not become more extreme, but I would agree
16 absolutely with the rest. Professor Raskovic was marginalised, but this
17 was due to his own will, in part, and he left for the United States.
18 Q. Can you recall which month and year it was when this final split,
19 as you called it, occurred, leaving Martic and Babic as the SDS leaders?
20 A. This was on the eve of the elections in Serbia. I don't know
21 which month exactly it was. It was perhaps December. At any rate, in
22 late 1990.
23 Q. Now, you mentioned someone named Jovo Opacic along with
24 Zelenbaba. Can you tell us what you know of Opacic.
25 A. I know that he was one of the vice-presidents of the
1 Serbian Democratic Party and one of its founders.
2 Q. Thank you. Now, in paragraph 10 of your statement, you say that
3 information had arrived that the Croatian forces sent their people to the
4 police station in Knin and Northern Dalmatia to take weapons. Then in
5 paragraph 11 you state that the Croatians who had come to Knin to take
6 the weapons were thrown out. Earlier Mr. Petrovic asked you, his
7 question was:
8 "Witness, the events of August 1990 are related here. You say
9 the Croatians who had come to take the weapons were thrown out. Which
10 Croatians does this refer to?"
11 Your answer was:
12 "They were not allowed to come over and talk the weapons, the
13 Croatian police from Split, Sibenik, or Zadar; they were supposed to take
14 over the weapons of the reserve force. They were not allowed to do so.
15 They were stopped on their way by the roadblocks."
16 My question to you is: Are you thus confirming that when you
17 said they were thrown out that was actually not the case because they
18 never actually made it in?
19 A. Yes, they never made it to take the weapons over. News reached
20 the people of their arrival, people got organised, and they never managed
21 to take the weapons.
22 Q. When you say "news reached the people," this also is kind of what
23 you said in paragraph 10 of your statement where you said information
24 arrived that Croatian forces had sent their people. So my question to
25 you is: Where did that information arrive from? Or, rather, more
1 specifically: From whom did you hear that information?
2 A. The information reached us through the early-warning information
3 centre, the sort of centre which exists in every municipality. I suppose
4 that the information had originally come from the JNA, but I'm not sure
5 who the source of information was.
6 Q. And where were you when you received this information?
7 A. I was in Vojnic. The meeting of our board was summoned, and we
8 received information from Knin of the attempts by the Croatian forces to
9 advance towards Knin and these municipalities.
10 Q. So just to clarify: You were not in Knin at that time?
11 A. No, not on the 16th and the 17th. We were in Knin on the 18th
12 when we attended a rally in Benkovac held by Mr. Raskovic and which had
13 to do with the opposition to these actions taken by the Croatian police.
14 Q. Thank you. In paragraph 12 of your statement you say, and I
16 "I did not see any police from Serbia or heard anything about
17 their presence."
18 You say you were certain that this would have been communicated
19 to the Main Board. By this you mean the main SDS board; is that correct?
20 A. Yes.
21 Q. Can you explain to us what makes you so certain that the SDS
22 board would have been informed of the presence or involvement of the
23 Serbian police?
24 A. I think that after all we were the core leadership of the people,
25 and it was our duty to convey that sort of information to the general
1 public as to what was going on and who was assisting us, et cetera.
2 Q. You were the core political civilian leadership; is that correct?
3 A. Yes.
4 Q. How often would you say you were in Knin in 1991?
5 A. Quite often. Every seven or 15 days, depending on the situation,
6 Babic would come to visit us along with his associates and we would
7 organise meetings with other leaders in the field, but these meetings
8 were quite frequent.
9 Q. The meetings --
10 JUDGE ORIE: Could I try to understand the answer and also the
11 previous answer.
12 You were asked - previous question - how you could be so certain
13 that the information would have reached you. And then you said you were
14 core leadership; that's understood. And then you said it was our duty to
15 convey that sort of information, which means that if you receive it, that
16 you have to pass it on. But it is not in any way -- at least I do not
17 understand that to be a reason, that you would receive it because you
18 have to pass it on.
19 Now, here we have the last question. The question was:
20 "How often were you in Knin?"
21 And you said:
22 "Quite often. Every 7 or 15 days, depending on the situation,
23 Babic would come to visit us along with his associates and we would
24 organise meetings with other leaders in the field."
25 It's, for me, difficult to understand that if Babic comes to you
1 that that explains why you were in Knin. I always thought if Mr. Babic
2 was in Knin, Babic would go from Knin to your place. So therefore
3 it's -- I have great difficulties in understanding, now and then, your
5 So could you please focus very much on the question, try to
6 answer that question rather in a factual way than in explanations and the
7 type of logic which apparently is difficult for me to understand.
8 Please proceed, Ms. Marcus.
9 MS. MARCUS: Thank you, Your Honour.
10 Q. Yes, Mr. Bosnic, let's go back to the first question that
11 His Honour just asked you about. The question I put was:
12 "Can you explain to us what makes you so certain that the SDS
13 board would have been informed of the presence or involvement of the
14 Serbian police?"
15 You then spoke about your duty to convey that sort of information
16 to the public.
17 Can you explain to us what -- again, the question is: What makes
18 you certain that you would have been informed of the presence or
19 involvement of the Serbian police?
20 A. The SDS Main Board was the biggest and most significant body
21 representing the Serbian people in Krajina. We attended meetings of the
22 Main Board which adopted guide-lines for our future work in the field.
23 We would convey these guide-lines to our associates in the lines of work
24 we were directly engaged in. We would frequently schedule meetings to
25 which we would invite Milan Babic to describe the political situation and
1 the steps that the SDS would take with a view to setting up and
2 consolidating power and resistance against the Serbian forces --
3 THE INTERPRETER: Interpreter's correction: Against the Croatian
5 THE WITNESS: [Interpretation] -- as well as the setting up of the
6 reserve force.
7 MS. MARCUS:
8 Q. Do we understand your answer to mean that pursuant to an
9 invitation, Babic would attend these meetings, give you a briefing on the
10 political situation and the steps that the SDS would be taking, and
11 through that information you would assume that you would have been
12 informed of Croatian -- of Serbian police involvement? Is that how we
13 understand your answer? And if not, please clarify.
14 A. That's how the Main Board worked. However, Babic would also come
15 out into the field, specifically in Kordun, to explain to the lower
16 levels what the situation was like. So I attended meetings of the
17 Main Board as well as meetings held locally, which Milan Babic attended,
18 explaining the situation in Krajina and the relations between Krajina and
19 Croatia. So we are speaking about two different levels at which
20 discussions took place, and it was only natural and normal for
21 Milan Babic to speak about the police force or anything else that had to
22 do with the RSK, or initially SAO Krajina, at both these levels. And in
23 Kordun I was in contact with the existing police force and they never
24 mentioned to me that there was a police force from Serbia in my
25 communication with them.
1 Q. Thank you. Okay, I'm going to ask you a few questions about the
2 meetings again and then we'll return a little bit to this subject.
3 So I go back again: Of these meetings that you described, which
4 you attended, you said, every 7 to 15 days, if I'm not mistaken - you
5 also describe these meetings in paragraphs 15 to 20 of your
6 statement - are those meetings that took place in Knin or are you
7 including also the meetings that you had locally on the ground?
8 A. Meetings were held mostly in Knin. However, at times meetings of
9 the Main Board would take place in Benkovac, Lapac, and elsewhere. Not
10 always were the meetings of the Main Board held in Knin, though for the
11 most part they were. And when I was referring to meetings, I also
12 included my own activities that I had in the field as a member of the
13 Main Board, when I was referring to the overall number of meetings as
14 well as the frequency thereof.
15 Q. The meetings of the Main Board, did Babic necessarily attend
16 those meetings or only periodically upon your invitation?
17 A. No, Babic always attended meetings. There may have been an
18 exception that I don't recall at this time, but he would attend meetings
19 as a rule.
20 Q. And the meetings that you had in the field, as you say, as a
21 member of the Main Board, which you included in the number of meetings,
22 did Babic necessarily attend those?
23 A. No.
24 Q. At the Main Board meetings, were there police officials and
25 military officials, operational people, et cetera, or was it exclusively
1 political, civilian officials who attended those meetings?
2 A. Political leaders. Some of them also held positions in the TO.
3 I'm not sure about the police.
4 Q. You're not sure whether -- just to understand what you're not
5 sure about: You're not sure whether some of the political leaders also
6 played a role in the police, or you are not sure whether the police
8 A. No, they didn't attend meetings. But I'm not sure if any of the
9 members of the Main Board also played a role in the police. That, I
10 don't know. In other words, there were no senior members of the police
11 represented at the meeting. It was for the most part the political
12 leaderships. It was just that I was saying that I don't know what other
13 roles these political leaders may have played in the municipality. I
14 didn't know them all.
15 Q. So you were not necessarily informed of all of the activities of
16 those involved in these meetings; is that -- do I understand you
18 A. Yes.
19 Q. What was the role of the SDS Main Board with respect to the
21 A. It didn't have any direct influence over the police. It could
22 issue guide-lines as to how the civilian authorities should operate and
23 the ways in which their work would be organised, meaning the work of the
24 police force, health care, and all the other elements of power.
25 Q. I'm not sure I understood your answer. My question was the role
1 of the SDS Main Board with respect to the police, and you said:
2 "It didn't have any direct influence over the police. It could
3 issue guide-lines as to how the civilian authorities should operate and
4 the ways in which their work would be organised, meaning the work of the
5 police force ..."
6 So are you saying that the SDS Main Board could issue guide-lines
7 with respect to the work of the police force? Or did I misunderstand
8 your answer?
9 A. The Main Board issued guide-lines to the Serbian National Council
10 because it had become apparent that there was a lack of unity in the
11 activity of the police forces. Our intention was to unify these
12 activities. Milan Babic agreed and proposed that Milan Martic be the
13 secretary of the overall police force as well as a member of the
14 National Council, meaning the government. So the political idea came out
15 of the Main Board, Babic was the one who pushed for the idea and
16 suggested that Martic be the secretary in charge of all the political
17 stations, primarily -- or initially in the areas of Lika and
18 Northern Dalmatia, and later on Krajina.
19 Q. Was there a system put in place for reporting between the police
20 and the SDS Main Board? In other words, were the police providing
21 regular reports pursuant to some guide-lines to the SDS Main Board?
22 A. No, they did not send any reports to the Main Board of the SDS.
23 It did so through the national -- Serbian National Council via which it
24 was referred to the Assembly. And through the Assembly it also came to
25 the Municipal Assemblies where they discussed the work of the local
1 police forces.
2 Q. And the information, this reporting that you're talking about,
3 who reported this to the public?
4 A. The public was informed by the Serbian National Council and the
5 Assembly, which discussed and adopted work reports. So the
6 Serbian National Council reported to the Assembly, informed the Assembly,
7 and the Assembly would either adopt or refuse the report. So the
8 minister or the secretary would submit a report to the Serbian National
9 Council, the Serbian National Council either accepted it or not. If it
10 was accepted, it would then be referred to the Assembly. And the final
11 discussion on the work would have been conducted by the Assembly.
12 Q. Now, all this information that's being shared and assembled, did
13 that tend to contain details of police activities on the ground, or was
14 it more about political events and matters that effect the public at
16 A. These reports principally were on the work of the police, what
17 the police was doing on the ground, without any political qualifications.
18 Q. Were you systematically informed of the details of training
19 activities? You, as in a member of the SDS Main Board.
20 A. If you are referring to the training in Golubic, no, I was not.
21 If that is what you mean.
22 Q. What about intelligence activities?
23 A. What I learned from Babic at the Main Board meeting was that
24 there also existed a State Security Service of the Krajina at the helm of
25 which was Orlovic. These were mainly personnel who used to work in the
1 State Security Service but that of Croatia, but they were of Serb
2 ethnicity and they remained with us in our area, the area of the Krajina.
3 Q. Which Orlovic are you talking about?
4 A. The Orlovic who was the chief of the State Security Service of
5 the Krajina.
6 Q. Do you know his first name?
7 A. I know the man in person. I believe that his first name was
8 Dusko, but I can't be sure.
9 MR. JORDASH: There's no dispute on that issue.
10 JUDGE ORIE: Please proceed.
11 MS. MARCUS: Thank you.
12 Q. Now, you said you learned this form Babic. My question was about
13 systematically being informed of these kinds of activities. Are you
14 saying that Babic systematically informed the Main Board of state
15 security activities or are you saying that he informally gave you that
17 A. I'm saying that he gave this information informally to me. We
18 did not discuss the work of the State Security Service at the Main Board
19 session. He told me this because I knew Orlovic from before, I suppose.
20 He did not inform the Main Board in the sense of a report or any other
21 formal communication.
22 Q. Was the SDS Main Board generally informed of covert operations?
23 A. I don't know what covert operations you are referring to. I
24 really don't know what operation you mean. If you ask me a specific
25 question, perhaps I can then answer yes I have or I have not heard about
1 that specific operation.
2 Q. I'm asking generally whether the Main Board was systematically,
3 routinely informed of covert operations by the state security.
4 A. I don't know of any covert operations, and we were told nothing
5 about any such operations. I what not aware of their existence and
6 nobody told us anything about any such operations.
7 Q. Were you informed of the movement and distribution of weapons?
8 You, meaning the SDS Main Board.
9 A. No. These things did not take place equally in all areas, and
10 there was not much discussion about these things. According to what I
11 know, it was until July or August we did not even get any weapons. What
12 existed were just personal weapons owned by members of the village guards
13 and the weapons that were under key in the TO and in the police. And I
14 don't know about any other weapons.
15 Q. You talked quite a lot about the Golubic training centre. Were
16 you informed of the particular training activities that were carried out
18 A. Only in principle, not the specifics. Not in detail.
19 Q. And how did you receive that information; was it formally through
20 a reporting process or informally through conversations?
21 A. In conversations conducted at the Main Board sessions. The
22 initiative for the establishment of such a centre actually was launched
23 at a session of the Main Board. And after the attack on Plitvice, the
24 Serbian National Council actually formulated in a request addressed to
25 the Ministry of the Interior of Serbia and the Government of Serbia.
1 Q. You are talking about the Golubic centre?
2 A. Yes. We did not say at the time that it would be a centre at
3 Golubic. We asked for assistance, for help, and the result of this
4 request of Babic's, i.e., of the decision of the National Serbian Council
5 and Babic's request, was the setting up of the Golubic centre.
6 Q. Did you receive -- as a political leader, did you receive
7 information regarding high-level visits to Knin? So if Knin was visited
8 by certain high-level leaders, did you receive information about that if
9 they were visiting but not attending your meetings?
10 A. Well, as a rule we received information as to with whom they had
11 talked, who came to Knin, with whom they had talked in Belgrade, what was
12 being planned, and such.
13 Q. You say "as a rule," so was there a system of reporting,
14 briefing, in place for this kind of information?
15 A. Well, we were more or less informed about what transpired between
16 the two meetings of the Main Board.
17 Q. Did you have an influence over how much information you received?
18 So you say you were more or less informed; did you have an opportunity to
19 put questions and receive answers or were you just informally informed?
20 A. No, one could ask questions, one could make proposals, one could
21 seek clarifications and explanations.
22 Q. Now, you talked about your role in the Main Board. You also
23 talked about your role locally on the ground. How many different
24 municipalities were represented in the Main Board meetings?
25 A. All the municipalities were represented at the Main Board
1 meetings, all the municipalities, what used to be SAO Krajina, I believe
2 there were 13 of them. Then Pakrac, Podravska Slatina, Daruvar,
3 Grubisno Polje, and some other municipalities of Western Slavonia were
4 also represented. And there were representatives from Eastern Slavonia,
5 Vukovar, and some other places. I cannot recall all of them at this
6 point. So from all areas where Serbs lived and where chapters of the SDS
7 had been set up. Later when the situation became more critical and with
8 a split in the SDS, it was only members from areas where the Serbs
9 accounted for a majority, where they wished to create a compact
10 territory, that is, members of the Krajina SDS.
11 Q. And you were representing Slunj municipality; is that accurate?
12 A. I was representing Vojnic municipality because it was in the
13 municipality of Vojnic that the SDS was formed first.
14 Q. Were you also informed of activities in other municipalities?
15 A. Yes, as far as Kordun is concerned. And I also took part in
16 them. And of these, I would be informed occasionally if I was interested
17 in some specific issues or if something was of importance to the Krajina.
18 Q. Yesterday you said that you were aware of those who were trained
19 in Golubic from Kordun but you were not aware of those who were trained
20 in Golubic from other municipalities. Can you tell us about the
21 information that you received on the matter of training. Was there a
22 system of reporting on training activities from the different
24 A. There was a difference between Dalmatia and [indiscernible] on
25 the one hand and Kordun and Banija on the other hand. Mainly, the police
1 units, the existing police units, still failed to accept Martic as their
2 secretary in Vojnic and Vrginmost, et cetera. And because of that, the
3 selection of the trainees was conducted through the parties. And in
4 municipalities where the police had already accepted Martic as the
5 secretary and had accepted the statute and what have you, as everything
6 as -- which was [indiscernible] by a unified territory, they proposed
7 their candidates.
8 Q. Now, if you were not specifically aware of those who were trained
9 from other municipalities, wouldn't it flow from that that you were in
10 fact not aware of events in relation to other municipalities unless it
11 reached the RSK political agenda?
12 A. It was lads from all the municipalities in the Krajina area that
13 went for training to Golubic. The task was that lads should be trained
14 from all municipalities. It was just that they were selected in one way
15 in one part of the area and in another way in another part, but the
16 general stance was that people from all areas should be sent for training
18 Q. So when you said before that you were not aware of people sent
19 for training from other municipalities, you actually are aware of people
20 sent from other municipalities? In other words, that wasn't accurate
21 what you said yesterday.
22 A. I did not know the people. I did not know those people. And I
23 did know those hailing from Kordun and those who were trained. That is
24 what I meant. That is what I said. From the area of Kordun, I knew the
25 people who went there for training and I did not know the others who went
1 there from other areas, so I was talking about concrete people.
2 Q. Thank you for the clarification.
3 Can you give us the names of the individuals from Kordun who were
4 sent for training in Golubic?
5 A. I can give you some names that I can recall. Zlatko Dmitrovic, a
6 lad whose nickname was Oroz, then Topic, Ilija Saula, and I cannot
7 remember any other names now. It would take me some time to go back.
8 These are the ones I could recall at this moment.
9 Q. We'll have an opportunity to talk again tomorrow. I'd like to
10 ask you, if you could, to try to turn your mind to that and think of some
11 other names.
12 Now, while we do that, these individuals whose names you
13 mentioned, or nicknames, were they in the first group at Kordun or the
14 second group? The first group from Kordun, sorry.
15 A. I cannot remember now exactly who was in what group exactly. I
16 believe that Mitrovic and Saula were in the first group, but I'm not sure
17 of that. It is Dmitrovic. Dmitrovic, not Mitrovic. D-m-i.
18 Q. Do you know if any of those individuals were among the ones who
19 stayed at Golubic for on-going training, to provide the training?
20 A. Not as far as I know. Not the people that I just named.
21 Q. Can you name for us any of the individuals from Kordun whom you
22 knew to have remained behind and continued on-going training at Golubic?
23 A. No, I cannot.
24 Q. At the time were you provided with a list of those names? Did
25 you receive a report, detailed reports, about those who were sent from
1 Kordun to Golubic?
2 A. No.
3 Q. Your statement in paragraph 12 about never having heard that
4 Jovica Stanisic had anything to do with Knin or Golubic is in contrast to
5 your words in paragraph 70 in which you state categorically that Stanisic
6 did not order the setting up of police stations. If you had not heard
7 that Jovica Stanisic had anything to do with Knin, then how are you able
8 to state categorically what he did or did not do?
9 A. I was asked whether he did that. I categorically said that he
10 didn't do it, that we did it, and that it had nothing whatsoever to do
11 with Jovica Stanisic.
12 Q. Surely all you can say is what you knew of based on what you were
13 informed of; isn't that accurate?
14 A. Well, absolutely. It was me who negotiated with representatives
15 of the police in Kordun to accept Martic's secretary. It was me, myself,
16 and some other activists of the SDS. We had meetings with the police
17 representatives until the 31st of June -- who were until the 31st of July
18 in contact with Zagreb. And that is when their relationship with the MUP
19 of Croatia was severed. Jovica Stanisic has nothing whatsoever to do
20 with that story. I was the one who exerted pressure on them at meetings
21 to join the police of the Krajina, pursuant to our position that all
22 municipalities in the area of the SAO Krajina should accept the statute
23 of the SAO Krajina and join the SAO Krajina.
24 This did not happen all at once. This was a process. The
25 process of the inclusion of the joining of the municipalities of Kordun
1 and Banija to the SAO Krajina and their adoption of the statute of the
2 SAO Krajina was a process which took some time. It wasn't something that
3 happened at one fell swoop. The assemblies of the local governments had
4 to adopt a decision to the effect that they were accepting the statute of
5 the SAO Krajina and that they accepted and they were an integral part of
6 the SAO Krajina.
7 After that we exerted pressure on the existing police force to
8 sever its relationship with Zagreb and to accept Martic as secretary. So
9 this was done by the SDS activists at meetings with representatives of
10 the local police. I specifically with representatives of the Kordun
12 Q. Thank you. Now, my question was about your comments in your
13 statement about Stanisic's involvement in Knin or Golubic, whereas your
14 answer was in relation to Kordun and Banija.
15 MR. JORDASH: Well --
16 THE WITNESS: [Interpretation] You asked me about the involvement
17 of the police. His involvement in the establishment of the police. He
18 was not involved in the establishment of the police; the police already
20 MS. MARCUS:
21 Q. And you're talking about in Kordun and Banija; is that correct?
22 A. I was talking about the concrete way in which we asked for the
23 Kordun and Banija police to accept joining the SAO Krajina and to accept
24 Martic as the secretary of the Secretariat of the Interior of the
25 SAO Krajina.
1 Q. I have to ask you a clarification about paragraph 18 of your
2 statement, where you say that Milan Martic had no influence in Kordun and
3 Banija at this time. That's what I wanted to clarify with you.
4 In the next sentence you say that Martic's influence was accepted
5 as of August 1991.
6 Can you just clarify for us what time-period it was that you were
7 referring to when you said Martic had no influence in Kordun and Banija?
8 Do you mean prior to August 1991?
9 A. Yes, yes, prior to August. Definitely. The process of the
10 establishment of the entire system in the SAO Krajina, including Kordun
11 and Banija, ended at the end of July, sometime after these events in
12 Glina. That's about the time when this process was completed, the
13 process of the institutionalised consolidation of the Serbian Autonomous
14 District of Krajina.
15 JUDGE ORIE: Ms. Marcus, I'm looking at the clock. I promised
16 Mr. Jordash five minutes, although it was also in your own interest that
17 he would use those five minutes. Therefore I would -- if this would be a
18 suitable moment, we would adjourn for the day.
19 MS. MARCUS: Yes, Your Honour, I was just going to suggest that.
20 JUDGE ORIE: Yes.
21 Mr. Bosnic, we adjourn for the day. We'll continue tomorrow
22 morning at 9.00 in the morning in this same courtroom. I again instruct
23 you that you should not speak or communicate -- yes, if you just let me
24 finish then I give you an opportunity to say something.
25 That you should not speak or communicate in any other way with
1 whomever about your testimony.
2 You would -- you wanted to ask or say something? Please.
3 THE WITNESS: [Interpretation] Yes. I should like to know
4 approximately when my examination will be generally concluded because I
5 have a private problem which I would have to deal with on Monday. So I
6 would appreciate knowing this as soon as possible because my presence is
7 required there. I hope to be able to deal with that problem personally,
8 but if I am unable to do that, I hope to be able to do that through the
9 services here.
10 JUDGE ORIE: A short question to Ms. Marcus: How much time would
11 you think you would need?
12 MS. MARCUS: I think I would use two sessions, tomorrow,
13 Your Honour.
14 JUDGE ORIE: Two sessions. That would -- of course you do not
15 know yet, Mr. Jordash, what Ms. Marcus is going to ask about, but is
16 there a fair chance that we would finish tomorrow?
17 MR. JORDASH: I think a very good chance.
18 JUDGE ORIE: In view -- Mr. Petrovic, I'm also looking at you, I
19 therefore -- the parties have an expectation, Mr. Bosnic, that we might
20 conclude tomorrow. Now, I have been disappointed now and then in my
21 life, but I hope that it's not going to happen tomorrow. Could you
22 please follow the usher.
23 THE WITNESS: [Interpretation] I also hope so. Thank you.
24 [The witness stands down]
25 JUDGE ORIE: Mr. Jordash.
1 MR. JORDASH: As I understand the Prosecution complaint, they
2 suggest, one, that we are in position of a statement for the next
3 witness, DST-043, sorry, the next-but-one witness, and the witness after
4 that, DST-074, and they'd like that disclosed. And, in short, we are not
5 in possession of a statement for those two witnesses. And perhaps it's
6 our fault for the way in which the previous statements have been drafted,
7 which perhaps hasn't made clear the process.
8 But if I can use the present witness as an example, DST-031. His
9 statement details the interview dates 21st of September, 2006; 17 and
10 20th of May, 2011; and the 1st of June, 2011. A statement was then
11 served on the Prosecution on the 5th of July -- 6th of July. It was
12 completed on the 5th of July inasmuch as the witness -- it was compiled
13 between -- the notes were used to compile the statement between the
14 1st of June and the 5th of July, the witness then checked the statement,
15 it was translated in -- before the witness checked, into B/C/S so that
16 the witness could check it. It was signed on the 5th and served on the
18 JUDGE ORIE: Yes, it's clear that you say the difference in time
19 is explained by the way in which we process these statements.
20 MR. JORDASH: I can assure the Court 100 per cent that as soon as
21 a statement has been completed - and what I mean "completed," I mean put
22 into a form which reads like a statement, not just signed by the
23 witness - it is served upon the Prosecution.
24 JUDGE ORIE: Yes. Okay. That is -- that is as far as the
25 critical words are concerned about what happened in the past. Now, you
1 say for the next two witnesses there are no statements.
2 MR. JORDASH: There are no statements.
3 JUDGE ORIE: So a 65 ter summary should be the basis for the
4 Prosecution to prepare? Is that ...
5 MR. JORDASH: Yes, we are -- I mean, we appreciate that we are
6 disclosing statements pursuant to 92 ter later than the rule suggests.
7 We are trying to assist the process. We didn't have the opportunity to
8 complete those statements before the Defence started.
9 JUDGE ORIE: But do you expect for the next witnesses that
10 statements will be there, that you will tender them under Rule 92 ter?
11 MR. JORDASH: Well, with the next witness, DST-074, we -- it
12 depends upon Your Honours, and this is a matter we wanted to address with
13 Your Honours, that the next witness may well start tomorrow. If he
14 doesn't start tomorrow, he starts next week. We anticipate he will take
15 probably two to two and a half sessions, depending upon the length of
16 cross-examination. So we are at this moment in a quandary as to whether
17 we ask the witness after that to come to The Hague. If he is coming to
18 The Hague next week, then we will not have the time to complete a 92 ter
19 statement. If he's not coming until after the summer, we will certainly
20 produce that statement and disclose it over the summer.
21 JUDGE ORIE: Yes. Now, from the estimates given, I take it that
22 we'll need tomorrow for this witness. And so there's -- it might not
23 make much sense to start for three or five minutes with the next witness.
24 Ms. Marcus, you have at least received an answer. Whether you
25 are happy with it, of course, is a different matter.
1 MS. MARCUS: Thank you, Your Honour. Yes, I'm not going to go
2 into the position on what is a witness statement. We are litigating that
3 in writing, as Your Honours know. The only thing I would mention is that
4 the Defence did provide to us a statement for Mr. Bosnic which was in
5 draft form. So I just wonder -- it was not signed, it had a heading on
6 the top that said "draft, to be reviewed, not confirmed by the witness,"
7 et cetera. Now, so it appears to me, then, that the time between the
8 1st of June and that -- and the 6th of July was used to type it up. It
9 certainly wasn't used to confirm it with the witness, or I don't know if
10 it was or wasn't, but that's quite a long time. And if it's simply about
11 form, it seems to me that the form, again, is over the substance in terms
12 of the notice requirements.
13 The last thing I would say, Your Honours, is that the 92 ter
14 statement for DST-043 was received, I think, yesterday with the witness
15 anticipating starting his testimony -- we all anticipated that he might
16 start tomorrow, so the -- it's somewhat of an understatement that my
17 colleague has said with respect to the lateness of the 92 ter filings.
18 JUDGE ORIE: Yes. Mr. Jordash, any need to respond to this?
19 MR. JORDASH: Only that I think -- if I may, just briefly. We
20 did serve a draft upon the Prosecution because it was in a format we felt
21 was sufficient for --
22 JUDGE ORIE: Yes, you don't have to explain to us why you did
23 that. It was apparently appreciated. If there's any opportunity to do
24 it again, I think Ms. Marcus would be happy.
25 MR. JORDASH: And we would do that for sure. We certainly would
1 do that.
2 In relation to the next witness, we did serve the statement
3 yesterday. But with the anticipated length of cross-examination
4 indicated by my learned friend and by the Simatovic team, we did not
5 anticipate the witness would start tomorrow, hence we wanted to give the
6 Prosecution a week to review that statement.
7 JUDGE ORIE: You say we may have been late but not as late as
8 perceived by those who thought that the testimony would start tomorrow.
9 MR. JORDASH: Yes.
10 JUDGE ORIE: Yes. Let's keep matters short. We adjourn for the
11 day. And we'll resume tomorrow, Thursday, the 14th of July, at 9.00 in
12 this same Courtroom II.
13 --- Whereupon the hearing adjourned at 1.50 p.m.,
14 to be reconvened on Thursday, the 14th day of
15 July, 2011, at 9.00 a.m.