Tribunal Criminal Tribunal for the Former Yugoslavia

Page 13226

 1                           Wednesday, 17 August 2011

 2                           [Open session]

 3                           [The accused entered court]

 4                           --- Upon commencing at 9.05 a.m.

 5             JUDGE ORIE:  Good morning to everyone.

 6             Madam Registrar, would you please call the case.

 7             THE REGISTRAR:  Good morning, Your Honours.

 8             This is the case IT-03-69-T, the Prosecutor versus

 9     Jovica Stanisic and Franko Simatovic.

10             JUDGE ORIE:  Thank you, Madam Registrar.

11             If there are no procedural matters to be raised, we'll move --

12     and it appears that there are none, we'll move into closed session.

13     [Closed session]  [Confidentiality partially lifted by order of the Chamber]

14             THE REGISTRAR:  We're in closed session, Your Honours.

15             JUDGE ORIE:  Thank you, Madam Registrar.

16             Could the witness be brought into the courtroom.

17                           [The witness takes the stand]

18                           [Trial Chamber and Registrar confer]

19             JUDGE ORIE:  Good morning, Witness DST-074.

20             THE WITNESS: [Interpretation] Good morning.

21             JUDGE ORIE:  I would like to remind you that the solemn

22     declaration you've given yesterday is still binding upon you.  That is,

23     that you should speak the truth, the whole truth, and nothing but the

24     truth.

25             Mr. Bakrac will now continue his cross-examination.

Page 13227

 1             Mr. Bakrac.

 2             MR. BAKRAC: [Interpretation] Thank you, Your Honour.

 3                           WITNESS:  DST-074[Resumed]

 4                           [Witness answered through interpreter]

 5                           Cross-examination by Mr. Bakrac: [Continued]

 6        Q.   [Interpretation] Good morning to everyone in the courtroom and

 7     around the courtroom.

 8             Good morning, Mr. DST-074.  I would like to show you another

 9     clip.  I would like to see whether you recognise anybody in the clip.  In

10     your statement you said something about the event, so let's see whether

11     the clip reflects what you stated in the statement.

12             MR. BAKRAC: [Interpretation] My assistant is going to play 2D877

13     now.

14                           [Video-clip played]

15             MR. BAKRAC: [Interpretation] Can we stop here.

16        Q.   Do you recognise the two individuals in uniforms?

17        A.   Yes, I recognise both of them.

18        Q.   Who are they?

19        A.   The first one, or the one on the left, is Stojcic, and next to

20     him in the distance is Zeljko Raznjatovic, Arkan.

21        Q.   When you say Stojcic, you mean Badza?

22        A.   Yes.

23             MR. BAKRAC: [Interpretation] Can we continue, please -- or,

24     rather, can we stop here.

25             THE INTERPRETER:  The microphone is not on.

Page 13228

 1             MR. BAKRAC:

 2        Q.   [Interpretation] This is a board that you can see in the

 3     background.  Do you recognise the board and the place?  Do you know that

 4     this is the training centre in Erdut where you say you were billeted

 5     together with the rest of your men?

 6        A.   Yes.  That's the board that was displayed at that centre.

 7             MR. FARR:  Your Honour.

 8             JUDGE ORIE:  Mr. Farr.

 9             MR. FARR:  I apologise for the interruption, but it seems to me

10     that it would be helpful to have time codes on the record so we know what

11     the witness is referring to at each point.

12             JUDGE ORIE:  Yes, Mr. Bakrac, that came to my mind as well.  When

13     you stopped for the first time, at what time code was that in this

14     exhibit?

15             MR. BAKRAC: [Interpretation] Your Honour, if I understood you

16     properly, the clip, or that episode, starts at 11:30.  11 minutes,

17     30 seconds.  I apologise, 11:20 I have just been suggested.

18             JUDGE ORIE:  Could we then briefly go back to the picture on

19     which the witness commented so that we can identify it with precision.

20             MR. BAKRAC: [Interpretation] Yes, Your Honour.  I'm going to ask

21     my colleague to do that.

22             JUDGE ORIE:  Yes.

23                           [Video-clip played]

24             JUDGE ORIE:  Yes.  The two persons you asked the witness

25     questions about, which he identified as Badza and Arkan, were shown at

Page 13229

 1     11:26 in this clip.

 2             Please proceed now to 11:31, because that's, I think, where we

 3     saw the ...

 4             MR. BAKRAC: [Interpretation]

 5        Q.   Witness, the board that --

 6             JUDGE ORIE:  Yes.  Could we now move to 11:31.  We can play it

 7     until it's there.

 8                           [Video-clip played]

 9             JUDGE ORIE:  Yes.  We are now at 11:31, and that's the board you

10     asked questions about.

11             Please proceed.

12             MR. BAKRAC: [Interpretation]

13        Q.   Witness, this is the board in front of which the two persons were

14     standing.  Does it say here that this is the training centre for

15     volunteers and the TO of the Serbian provinces of Slavonia, Baranja, Srem

16     and Erdut.

17        A.   Yes, that's what it says on the board.

18        Q.   Do you recognise the area?  Do you recognise the board?  Was the

19     clip taken in the centre where you were also billeted?

20        A.   We saw the board already there when we arrived at Erdut.

21             MR. BAKRAC: [Interpretation] I'm kindly asking the assistant to

22     proceed for another 20 or 30 seconds, and that will be the end of that

23     clip.

24                           [Video-clip played]

25             MR. BAKRAC: [Interpretation]

Page 13230

 1        Q.   Witness, I've asked you to look at the clip.  I have only two or

 2     three more questions.

 3             In the background we saw some military vehicles.  At the time

 4     when you were there, did Zeljko Raznjatovic, Arkan, have any military

 5     vehicles or tanks?

 6        A.   When I was there, there was no such thing.

 7        Q.   We also saw soldiers in training.  We saw them wearing overalls.

 8     Are those just regular overalls or NATO overalls?

 9        A.   Those were regular overalls.  However, Zeljko Raznjatovic and his

10     group of men who were billeted in Erdut when we arrived there, they wore

11     NATO uniforms, and they were two-piece uniforms, not overalls.

12        Q.   And what about their weapons, the weapons that the persons in

13     training at the centre carried, were those any special weapons?

14        A.   As far as I could notice, in most cases those were automatic

15     rifles of local-made.  And I also saw Skorpios being carried by a few

16     people, or pistols that the army used to have.  The police and the MUP

17     did not have those weapons as a standard issue.

18        Q.   Thank you, Witness.

19             MR. BAKRAC: [Interpretation] I have just two more questions,

20     Your Honours.  We said that we would provide Mr. Farr with the DVD, and

21     we will subsequently tender the video-clip for admission.

22             JUDGE ORIE:  Mr. Bakrac, I'm a bit confused by the last few

23     questions.  A comparison is made to what you see on the screen and what

24     others may have worn at any time, because the group or the members of

25     this group are not identified as such.  Now, half of the answers is that

Page 13231

 1     this is not the type of uniform, the gear, that Arkan and his people had,

 2     and in other parts of the answer a comparison is made with the MUP, the

 3     ordinary.  So I'm a bit confused.  Apparently this is not the gear that

 4     you would see when Arkan was there, which suggests - but I do not know

 5     whether you or the witness would have any further information - that this

 6     is not Arkan's Men.

 7             The second is that this is not the type of uniforms or gear

 8     that -- or the weaponry that the MUP would have.  So it's neither Arkan's

 9     people or MUP people, which have -- has not identified it.  But on the

10     basis of the weapons, it could not be MUP; on the basis of the gear, it

11     could not be Arkan.  That's at least what is suggested in the answer.

12             I'm a bit lost there.

13             MR. BAKRAC: [Interpretation] I apologise.  If I may be of

14     assistance and clarify some things.

15             JUDGE ORIE:  Please do so.

16             MR. BAKRAC: [Interpretation]

17        Q.   When it comes to the overalls and the area where those men

18     carried out their training, that is the centre in Erdut.

19        A.   This clip was taken at a time when I was not present in Erdut.

20     This could have been either in late 1991 or 1992 and further on.

21     Zeljko Raznjatovic conducted training at that centre when we left.  I

22     know that he had tanks and all the other weapons.  At one point in time,

23     the person who committed crimes in the municipality of Becej where I was

24     chief, he broke into a church and took some icons.  That person was

25     billeted at the centre.  And Zeljko Raznjatovic, Arkan -- upon my

Page 13232

 1     assistance, I came to the centre, and Zeljko Raznjatovic handed over that

 2     person.  That's why I recognise the uniforms worn by the men who were in

 3     training under him.  They were members of that anti-armour platoon or

 4     unit, as it were.

 5             JUDGE ORIE:  Did you recognise the picture where it was, the gate

 6     which was opened?  Was that the Erdut centre?

 7             THE WITNESS: [No verbal response]

 8             JUDGE ORIE:  Yes, I see you're nodding in the affirmative.

 9             THE WITNESS: [Interpretation] Yes, yes.  That's at the centre of

10     Erdut.  If you go towards the winery.

11             JUDGE ORIE: [Previous translation continues] ...

12             THE WITNESS: [Interpretation] The winery is right at the centre,

13     and in the background you see --

14             JUDGE ORIE: [Previous translation continues]... yes, it's fine.

15     You affirmed that this is -- these are pictures taken in the Erdut

16     centre.

17             Mr. Bakrac, no further questions?  Or do you have more questions

18     for the witness?

19             MR. BAKRAC: [Interpretation] No, Your Honours, just two more

20     brief questions and I'll be done.

21        Q.   Witness, you said you were present at the ceremony at Kula in

22     1997.

23        A.   Yes, I attended.

24        Q.   Did you see Arkan at Kula at that time?

25        A.   No, I did not.

Page 13233

 1        Q.   Thank you.  And one last question, witness.  In your statement,

 2     you mentioned a person known as Beli.  You said you turned him back from

 3     the check-point, from the crossing.  Who was that person with the

 4     nickname Beli?

 5        A.   I believe I said all I knew in my statement, and I repeated it

 6     several times.  I did not know Belgrade and Belgrade criminals so that

 7     not a single name meant anything to me.  Giska, Arkan, Beli; those names

 8     meant nothing to me.  They were the same to me as criminals in my own

 9     area that broke into kiosks.  The first group of armed men who came to my

10     check-point wishing to cross over were they.  I don't remember the exact

11     date, but two bus-loads of them came.  They were equipped and armed.  And

12     they had been engaged by the Serbian Revival Movement and there occurred

13     a clash.  I even put a bullet in my rifle and I was ready to fire to save

14     my own men.

15             However, Goran Hadzic came and said that they did not need

16     volunteers.  But there was a man from Trpinje, nicknamed Tasak, who

17     started making a lot of trouble.  I can't remember his actual name but if

18     somebody said it to me, I would be able to recognise it.

19             JUDGE ORIE:  Yes.  You asked who a person was with the nickname

20     Beli.  The witness tells us all kind of things which seems not to focus

21     very much on your question.

22             Could you please tell us:  Who was the person with the nickname

23     Beli?  Without describing all kind of events and whether you used your

24     weaponry, or ... just that person.

25             THE WITNESS: [Interpretation] That's the man who brought that

Page 13234

 1     group of 40 to 60 armed men.  That same evening, that gentleman was

 2     killed and I was one of the suspects in that killing.

 3             MR. BAKRAC: [Interpretation]

 4        Q.   Sir, was Beli at the head of a group that had a certain name?

 5        A.   Yes.  That's the group that the Serbian Revival Movement set up,

 6     trained, and wanted to send over the border.  I can't remember whether

 7     they were called the Serb Volunteer Guard or something.

 8     Zeljko Raznjatovic's unit and that other unit had similar names.  I think

 9     it's Serbian Volunteer Guard.  All I know is that they were members of

10     the SPO, Serbian Revival Movement.

11        Q.   If I may jog your memory, would you agree that he headed a unit,

12     a paramilitary unit that was called the Serbian Guard?

13        A.   That's correct.  That's right.  And later he was replaced by

14     Giska.

15        Q.   Thank you, Witness.

16             MR. BAKRAC: [Interpretation] Just a moment, Your Honours.

17             Thank you, Your Honours.  I have no further questions.

18        Q.   Thank you, Witness.

19             THE WITNESS: [Interpretation] Thank you.

20             JUDGE ORIE:  Thank you, Mr. Bakrac.

21             Mr. Farr, are you ready to cross-examine the witness?

22             MR. FARR:  Yes, Your Honour.

23             JUDGE ORIE:  Witness DST-074, you will now be cross-examined by

24     Mr. Farr.  Mr. Farr is counsel for the Prosecution.

25             Please proceed.

Page 13235

 1                           Cross-examination by Mr. Farr:

 2        Q.   Good afternoon -- good morning, DST-074.  Can you hear me

 3     clearly?

 4        A.   I can.  And I can see you very well.  Thank you.  Good morning.

 5        Q.   I'm glad to hear that.

 6             We have a lot of material, and I'm going to try to focus my

 7     questions as specifically as possible.  And I would ask you to listen to

 8     the question and try to focus your answer as specifically as possible as

 9     well.  Is that all right?

10        A.   I hope I have done that so far.

11        Q.   I'd like to start by asking you about the provincial SUP of

12     Vojvodina and the MUP the Serbia.  In your statement and your evidence

13     yesterday, you mentioned both of those institutions, the provincial SUP

14     of Vojvodina and the MUP the Serbia, and you indicated that they were

15     independent.  But despite this independence the SUP of Vojvodina and the

16     MUP of Serbia co-operated, didn't they?

17        A.   All the SUPs of the former Socialist Federal Republic of

18     Yugoslavia co-operated among themselves, including Vojvodina, Serbia,

19     Kosovo, Slovenia, and everyone else.

20        Q.   And there are actually some examples of that co-operation in your

21     statement, I think, and I'm going to ask you whether you agree.  The

22     deployment of your PJM unit to Belgrade during the 9 March 1991

23     demonstrations; that's an example of co-operation between the Vojvodina

24     provincial SUP and the MUP of Serbia.  Do you agree with that?

25        A.   I agree with that.  And that was always with the approval of the

Page 13236

 1     federal SUP.

 2        Q.   And related to that event:  When Jovica Stanisic met with the

 3     commander of your unit at that time; that's also an example of that kind

 4     of co-ordination between the provincial SUP and -- of Vojvodina and the

 5     Serbian MUP.  Is that correct?

 6        A.   Correct.  Because I was on assignment to provide security to the

 7     president and his residence, and Mr. Jovica Stanisic was on the same

 8     assignment, which means we were doing the same job.  Everyone in -- in

 9     his -- each in his own line of work.

10        Q.   Right.  And with respect to lines of work, that meeting between

11     Jovica Stanisic and your unit commander is actually an example of

12     co-ordination between the DB of the Serbian MUP and the public security

13     service of the Vojvodina provincial SUP; is that correct?

14        A.   Correct.  Since we didn't know Belgrade that well, that was an

15     assignment we had just received one or two days before.  It's normal we

16     had to get to know things before we were able to complete the assignment

17     successfully.

18        Q.   The fact that you were ordered to accept permits assigned by

19     Radmilo Bogdanovic when you were stationed at the crossing at Vajska;

20     that is also an example of co-ordination between the provincial SUP of

21     Vojvodina, you and Zavisic, and the MUP of Serbia, Bogdanovic.  Is that

22     correct?

23        A.   That's correct.  First I was told that Mr. Markov, the provincial

24     secretary, was also able to sign such permits.  And after that, I was

25     told that the permits were valid with the signature of

Page 13237

 1     Radmilo Bogdanovic, who was at the head of the federal SUP.

 2        Q.   And you were told that by your superior, Miodrag Zavisic, who,

 3     like you, was in the Vojvodina provincial SUP; correct?

 4        A.   We received that order at Odzaci, as I said yesterday, by chief

 5     of the provincial SUP, Marinko Kresoja, Momo Stojanovic, and

 6     Stanoje Milanovic.  One of these three told us this, I don't know which

 7     one.  But Zavisic was designated as man number one to whom we would

 8     report.

 9        Q.   In addition, the fact that the group that went to

10     Eastern Slavonia to set up the TO staff was composed of officers from the

11     provincial SUP of Vojvodina, as well as 16 members of the special police

12     unit from Belgrade; that's another example of co-operation between the

13     Vojvodina provincial SUP and the Serbian MUP.  Correct?

14        A.   That is not correct.  That is not co-operation.  We went over as

15     volunteers.  We all signed statements that we were volunteers.  We were

16     rallied by Stojcic, Badza, but Zavisic first.  But several times before,

17     Goran Hadzic and the others had insisted that I should transfer, and I

18     said I was not able to because I had a full-time job.  However, when

19     Zavisic asked me to join the volunteers, I agreed.  I crossed over of my

20     own will.  I signed a statement that I was a volunteer.  And I was no

21     longer a member of the force, apart from the fact that I received my

22     salary at my police station where I worked.

23        Q.   Is it correct that the members of the special police force from

24     Belgrade were normally part of the Serbian MUP, before they volunteered?

25        A.   That is correct.  Before that, they had their jobs in Belgrade.

Page 13238

 1        Q.   And at the time that you volunteered, was Badza associated with

 2     the Serbian MUP or the Vojvodina SUP?

 3        A.   Badza was linked to the SUP of Serbia, not Vojvodina.  We met up

 4     quite often in the area of Kosovo, and that's where I know him from.

 5        Q.   And the other four officers who went to Eastern Slavonia, that's

 6     yourself, Trajkovic, and two people whose names I can't remember at the

 7     moment, were associated with the Vojvodina SUP; is that correct?

 8        A.   That's not correct.  Badza, Trajkovic, and Simovic were all from

 9     Belgrade; while Zavisic and I were natives of Vojvodina.

10        Q.   So the group that went to Eastern Slavonia to set up the TO staff

11     consisted of people whose regular employment posts were with both the

12     Serbian MUP and the Vojvodina SUP?

13        A.   That's correct.  Before that, Zavisic and I worked in the MUP of

14     Vojvodina; whereas the other group used to work in Serbia.

15             The TO staff existed even before we arrived in Western Slavonia,

16     Baranja, and Srem.  We didn't set it up.  We just continued to work there

17     on assignments received from Goran Hadzic.  But the rest of the time I

18     saw very little of Goran, and we received all our further assignments

19     from Mr. Stojcic, nicknamed Badza.

20        Q.   And you all continued to be paid by the Serbian MUP or the

21     Vojvodina SUP respectively; correct?

22        A.   I don't know about them.  I know that I received my salary at the

23     OUP Becej.

24        Q.   Okay.  I would now like --

25        A.   And every month - excuse me - every month, I had to send a

Page 13239

 1     certificate in order to be able to receive the salary that Badza had to

 2     approve in the -- in the area of Erdut.

 3        Q.   Okay.  I want to make sure that I understand the dates that --

 4     that we're dealing with in your statement and evidence.

 5             You said you arrived in Vajska on approximately the

 6     15th of May, 1991, and you stayed until a few days after Dalj fell; is

 7     that correct?

 8        A.   On the 13th, if memory serves me well, I arrived at Vajska and a

 9     couple of days after the fall of Dalj and when the bridge was liberated.

10     I know Zavisic asked me and it took a couple of days of consultations

11     before I agreed and before we crossed over.

12        Q.   So you arrived at Vajska on the 13th of May, 1991; is that

13     correct?

14        A.   Correct.

15        Q.   And you left a few days after -- you went to Eastern Slavonia a

16     few days after Dalj fell, on the 1st or 2nd of August, 1991; is that

17     correct?

18        A.   Sorry, I did not hear the interpretation.

19        Q.   I'll repeat.  You went to Eastern Slavonia a few days after Dalj

20     fell, and Dalj fell on the 1st or 2nd of August, 1991; is that correct?

21        A.   Correct.

22        Q.   And you remained in Eastern Slavonia for approximately two

23     months, which by my calculation would be late September or early October;

24     is that correct?

25        A.   The date when I returned I can determine by the wounded --

Page 13240

 1     wounding of Ilija Kojic, when they moved towards Bogdanovci.  It was five

 2     or six days after he was wounded that I returned.  I don't know the exact

 3     date.  Because I had a lot of trouble getting that information because I

 4     had left the ministry.  And when I asked for my daily reports that I had

 5     written every day, were difficult to get, inaccessible to me.  So you

 6     have to excuse me if I'm off by a day or two.

 7        Q.   I now have a few questions about the procedures at Vajska

 8     crossing and your job related to preventing the illegal transport of

 9     weapons.

10             As I understand your evidence, you said that, in general, you

11     checked people for weapons, you didn't allow anyone with weapons to cross

12     unless they had a permit from Bogdanovic or Markov, you seized the

13     weapons of anyone who tried to cross the border with a weapon, and you

14     seized a lot of weapons in that process.

15             Is that an accurate summary?

16        A.   That's what I did.

17        Q.   And do you agree with me that the task of preventing illegal

18     crossings with weapons was a very difficult task for which you and the

19     other members of the PJM did not have enough men and did not have all of

20     the right equipment; is that correct?

21        A.   That is correct too.

22        Q.   And while you did your best to stop it, if someone was determined

23     to cross the Danube illegally with weapons, they probably would be able

24     to do it, not at a check-point but somewhere; is that correct?

25        A.   At the check-point, they would cross only over my dead body.  As

Page 13241

 1     for other places, to the extent that I had resources and to the extent I

 2     knew where they would be attempting to cross, I tried to cover the area

 3     24 hours/7.

 4        Q.   You did your best, but you allow for the possibility that there

 5     could have been illegal crossings, despite your best efforts; is that

 6     correct?

 7        A.   The Danube river is winding and very long, and I suppose that's a

 8     possibility.  But I tried to minimise that possibility with the men that

 9     I led and in direct co-operation with the residents of that area.  And in

10     that area there were many farms and fields, and I made contact with all

11     these people and in a way they cooperated with me because there were

12     Serbs, Croats, and Hungarians living there whose interests were the same

13     as mine, namely to minimise the number of armed men in that area, first

14     of all, for their own safety, and then for ours too.

15        Q.   When individuals were crossing at Vajska, you would check the

16     identifications of everyone except for military people because you

17     weren't authorised to request military IDs; is that correct?

18        A.   I looked at everybody's papers, including those of military

19     personnel.  A military person had to show ID, otherwise they would not be

20     able to cross.  Because anybody could have put on a military uniform.

21     Only people with proper military ID were able to cross.  Those who didn't

22     produce one were turned back.  I would call the secretariat in charge, or

23     the military police, and that person would be taken away.

24        Q.   In paragraph 45 of your statement, it says:

25             "Members of the military intelligence service were also crossing

Page 13242

 1     the check-point.  They represented themselves like that, but I did not

 2     ask them to legitimise themselves because I was not entitled to request

 3     for military ID cards."

 4             Do you have a correction to that?

 5        A.   Yes.  What I meant, they did not -- I did not search them when

 6     they produced the military ID.  It was a small number of military

 7     personnel that crossed over at that point.  Those were individual cases.

 8     They had to show ID, but I did not search them.

 9        Q.   Does that include members of the military intelligence service?

10     You would check their IDs as well?

11        A.   A group of men from the military security did come.  They were

12     very polite.  They produced their IDs of their own will.  They did not

13     ask to cross the border.  They just wanted information.  And we treated

14     them the same as employees of the state security.  Every time they would

15     arrive at the crossing, we would make an Official Note, and in most cases

16     it was I who spoke to them, and every time a report would be written

17     about it.

18        Q.   Were identifications provided by the Vojvodina provincial SUP and

19     the Serbian MUP the same or different?

20        A.   They were very similar.  They were all blue.  The writing said

21     "Official ID."  The one from Vojvodina bore the coat of arms of

22     Vojvodina.  The Serbian one bore the coat of arms of Serbia.  But the

23     Vojvodina one was multi-lingual because it was in Hungarian and Serbian.

24        Q.   Did everyone who crossed the border need a permit to cross, or

25     only people who wanted to cross with weapons?

Page 13243

 1        A.   Only people who wanted to cross with weapons.  The locals from

 2     Croatia would just have to produce their personal ID.  People who had IDs

 3     from Serbia or Vojvodina had to produce a certificate from the TO in

 4     Vajska and other places.  These TO staffs would issue permits for

 5     individual crossings by regular citizens.

 6        Q.   You talked about seizing weapons.  Would you seize the weapons

 7     only of people who wanted to cross the border, or would you seize the

 8     weapon of anyone who came to your check-point with a weapon?

 9        A.   We not only seized weapons from people who tried to cross but we

10     seized them from houses and estates in the broader area, acting on any

11     report from Backa Palanka, Vajska, Glodjane.  Any time we received a

12     report, we would write it down, and we seized all the weapons we knew

13     about, together with the local SUP.  I think I've said that in my

14     statement.

15             I forwarded one such report and Glusica kind of cheated me and I

16     lost an informant whom I had placed in that area, so I had lost an

17     important source of information about where weapons could be found.

18     Because the regular people, the local people, viewed us as a special

19     unit.  They never saw us in those uniforms of the regular force.  It was

20     a time when new uniforms were issued to the PJP.  So the people saw us as

21     a special unit who was able to do much more than we were actually able

22     to, and we enjoyed the trust of the regular citizenry.

23        Q.   Sir, I appreciate the completeness of that answer, but this is

24     actually an example of what I brought up at the beginning of my

25     examination.

Page 13244

 1             My question was:  Would you seize the weapon of anyone who came

 2     to your check-point with a weapon.  And I think you answered that, but

 3     you also provided a lot of additional information.  The problem is we

 4     have time constraints.  So if you wouldn't mind, could I ask you to focus

 5     very specifically on my questions.

 6             My next question is:  Yesterday, in your evidence, you said part

 7     of your job was to remove people who were in possession of weapons

 8     illegally and legally.  Is it correct that you would seize weapons that

 9     were legally owned as well as those that were illegally owned?

10        A.   In the former Yugoslavia, licences to carry weapons enabled

11     people to carry weapons in any republic with such licence.  After I

12     arrived in Vajska, we seized weapons even from people who had such

13     licences.  And we took such people to the SUP where they would be

14     interviewed.  And in those interviews, the people were told that the

15     licences would be taken away from them if they appeared in that area

16     carrying that weapon, licence included.

17             I'm sorry if I take too long in my answers, but if you want me to

18     really say something meaningful, I have to, to provide such answers.  I'm

19     sorry if it's taking your time.

20             JUDGE ORIE:  Leave it to Mr. Farr whether he considers short

21     answers sufficient.  And what is meaningful or not is primarily for

22     Mr. Farr to decide.  If any questions remain, we'll put them to you.  The

23     simple answer to the last question would have been:  Yes, you would seize

24     even weapons that were legally owned.

25             If Mr. Farr needs further details, he'll ask you about it.

Page 13245

 1             Please proceed.

 2             MR. FARR:

 3        Q.   In paragraph 20 of your statement, you said that Goran Hadzic and

 4     Ilija Kojic crossed the border at Vajska and you made a point of talking

 5     to them to gather information because you considered them to have more

 6     reliable information than other people.

 7             What was Goran Hadzic's position -- what did you understand

 8     Goran Hadzic's position to be at the time that you were at Vajska?

 9        A.   My arrival at -- in Vajska was a matter of some confusion because

10     within a very short period of time I received a lot of contradictory

11     information.  I did not filter it.  I would just write all that

12     information up and forward it.  With time, I realized that Ilija Kojic

13     and Goran Hadzic and some other people provided more accurate

14     information.  And every time they crossed, I would record it.  And if

15     there was time, I would talk to them.

16        Q.   [Previous translation continues] ... I apologise for the

17     interruption.  We will -- we will get to those matters.  But can we just

18     start with the question of:  What did you believe Goran Hadzic's position

19     was when you were at Vajska?

20        A.   Ilija Kojic was commander of the TO, and Goran Hadzic was the

21     president of that area.

22        Q.   How did you first meet Goran Hadzic and learn who he was?

23        A.   My first contact with him was when he crossed over by boat and

24     when I asked for his ID.

25        Q.   And at that time did he tell you what his position was?  In other

Page 13246

 1     words, did he introduce himself by his name and his position?

 2        A.   No, he did not introduce himself.  He just showed me his ID.  I

 3     recorded it.  And I didn't even know what it was because I wanted, at

 4     that time, to talk to as many people as I could when they were crossing

 5     because I was gathering information.  So we had this informal

 6     conversation.  I wrote it up later in a note.

 7             A week or two later, the picture became clearer to me, and I

 8     began to have an idea how things were operating there.

 9        Q.   So why is it that you believed that Goran Hadzic had especially

10     reliable information?

11        A.   I've already said that.  I said that happened in time.  Ten, 15

12     days into my tour at this crossing, I realized Goran Hadzic had much more

13     information than Kojic and many others, Lazic --

14             THE INTERPRETER:  The interpreter didn't hear the name of all

15     these persons.

16             MR. FARR:

17        Q.   Did you learn what the source of Goran Hadzic's information was?

18     Did he tell you how he knew certain things?

19             JUDGE ORIE: [Overlapping speakers] ... yes, the interpreters

20     could not hear the names mentioned by the witness.

21             You mentioned that Goran Hadzic had much more information than

22     Kojic and many others, and then you mentioned, as the first one, Lazic.

23     Who were the others you mentioned?

24             THE WITNESS: [Interpretation] Vucenovic, Marko Loncarevic, and

25     many others that I got to know later.  The more time I spent at the

Page 13247

 1     check-point, the better picture I had.

 2             JUDGE ORIE:  Mr. Farr, your next question.

 3             MR. FARR:

 4        Q.   What kind of information was -- what kind of reliable information

 5     was Goran Hadzic able to provide to you?

 6        A.   Specifically, as soon as I arrived there was an incident -- there

 7     were incidents in which 250, 300 MUP members were killed, and into my

 8     stint, the number decreased, until there were 10, 11.  So the information

 9     I got depended very much on who I got it from.

10        Q.   Did Hadzic give you information about the security situation in

11     Eastern Slavonia, for example?

12        A.   That was the main thing, whether there were unrests, whether

13     somebody was disturbing them, whether there were large crossings by

14     groups, how the people were organised, whether there were village guards,

15     et cetera.

16        Q.   Did you ever learn why he was able to gather more accurate

17     information than anyone else, or than most other people?

18        A.   Because he was the political leader there.  After the drowning of

19     Mr. Soskocanin, he is the one who took over responsibility and led those

20     people there.

21        Q.   So he had access to higher-level people than other people who

22     were crossing your border did; is that correct?

23        A.   I don't know what higher-level people you mean.  There were no

24     higher-level people there.  He was the highest level person.

25        Q.   How often did Hadzic cross into Serbia or into Vojvodina from

Page 13248

 1     Croatia during the period you were stationed at Vajska?

 2        A.   Twice a week, on average.  Sometimes it would be fewer sometimes;

 3     sometimes more times.  But, on average, twice a week.

 4        Q.   Do you know where he was going, either in Vojvodina or Serbia,

 5     when he crossed the border?

 6        A.   In most instances he met with Bosko Parasevic [phoen], the

 7     president of the municipality of Odzak, Mile Novakovic from

 8     Backa Palanka.  And they mostly discussed the transfer of humanitarian

 9     aid to the people there.  I often received news about lorries with the

10     humanitarian aid coming my way.  I would then inspect them and let them

11     cross.

12        Q.   And I assume you learned what he was doing based on what he told

13     you; is that correct?

14        A.   That's correct.  On many occasions he met with those men at the

15     crossing itself.

16        Q.   When he crossed the border, was he accompanied by body-guards?

17        A.   He had his own vehicle, or I don't know whose vehicle it was, and

18     the registration plates are in my statement.  On most occasions,

19     David Cesic and Milenko Dafinic were with him.  Their respective

20     nicknames are Ceso and Dafo, if that means anything to you.

21        Q.   Did Hadzic and Kojic cross the border together or separately?

22     You mentioned them together in your statement, but I don't know if that

23     was just because you were discussing that topic or ...

24        A.   In most cases, they crossed separately.  There were, however,

25     occasions when they crossed together.  I could say a lot more about the

Page 13249

 1     crossings and the dates if I had been provided my Official Notes that I

 2     kept every day at the crossings.  But I was never given them.  I don't

 3     know why.  The situation would be much clearer to you and you would learn

 4     a lot more from my daily reports that were extensive and provided a lot

 5     of detail.

 6        Q.   How often did Ilija Kojic cross the border during the period you

 7     were at Vajska?

 8        A.   Not as often as Mr. Goran.

 9        Q.   Can you estimate how often?  Would it be once every two weeks,

10     for example, once a week?

11        A.   If I said that Goran went across twice a week, I would say that

12     he crossed once a week, on average.

13        Q.   And you just indicated that at that time he was the commander of

14     the TO; is that correct?

15        A.   Yes.  If -- he was in charge organising the Territorial Defence

16     and the police across the border.

17        Q.   And what kind of especially reliable information was he able to

18     provide?

19        A.   In most cases, he told me how many attacks had happened at the

20     settled areas or the check-points or the barricades that they had set up,

21     whether there were any disturbances, whether fire was opened.  This is

22     the kind of information I wanted from him, and I believe that I was

23     provided that information.  I really don't know whether that information

24     was accurate and adequate.  But whatever I heard from him, I noted in my

25     reports.  Whenever he crossed, he always pleaded for weapons from me.

Page 13250

 1     However, I was in no position to help him with that.  I just couldn't.

 2        Q.   But he was eager to acquire weapons at that time?

 3        A.   He asked me for weapons.  I don't know whether he obtained them.

 4     He never carried any weapons across the border.  Even his personal

 5     weapons, he never had those on him because I wouldn't allow him to take

 6     them across.

 7        Q.   And, sir, just for the sake of clarity:  You've said "he asked me

 8     for weapons."  You're referring to Ilija Kojic; correct?

 9        A.   Yes, yes.

10        Q.   In paragraph 21 of your statement, you say that you never came

11     across Ilija Kojic being involved in supplying weapons but you can't

12     exclude the possibility that he was involved in that without your

13     knowledge.  Is that correct?

14        A.   That's correct.  At the crossings which I controlled, Ilija Kojic

15     never transported a single rifle, a single round, a single bullet,

16     anything.  He didn't even transport a part of a uniform.

17        Q.   In paragraph 29 of your statement, you mention that Seselj also

18     crossed the river at the Vajska check-point.  Approximately how often or

19     how many times did he cross during your time there?

20        A.   You will see it in the statement that it was three times.  Once,

21     he attended Soskocanin's funeral, and then once again after that.

22        Q.   On the occasions other than Soskocanin's funeral, do you know why

23     he was going to Croatia?

24        A.   The last time he crossed he contacted a man who was the president

25     of his party in that area.  He was a member of the Ministry of

Page 13251

 1     Information.  His name is in my statement.  Memory fails me at the

 2     moment.

 3             When I crossed over, he came to see me quite a number of times.

 4     He wanted me to help him, an article about the situation in the region.

 5     I know the name of the place, but I just can't remember it at the moment.

 6     He was the president of the party, and Seselj visited him to discuss the

 7     setting up of the party.

 8        Q.   Did Seselj --

 9        A.   Rade Leskovac.  I apologise, Rade Leskovac is his name.

10             I have to appreciate that everything happened quite a long time

11     ago.

12        Q.   Of course, of course.  We understand that.

13             Did Seselj provide you information in the same way that Kojic or

14     Hadzic did?

15        A.   I didn't request information from Seselj about the situation in

16     the area.

17        Q.   Did you request or receive any other kind of information from

18     Seselj?

19        A.   No, no.  He was very polite at the crossings.  He was in

20     possession of all the required documents.

21             I didn't have much time to engage in a discussion with him,

22     because at the time when he was crossing, another type of crossing had

23     been set up involving a barge.  So I really did not have much time to

24     talk to him.  The crossings were crowded.  I didn't have time.  I mostly

25     talked to the people who were there waiting to cross.

Page 13252

 1             JUDGE ORIE:  Did you request or receive any other kind of

 2     information from Seselj?  The simple answer is no.  And then you start

 3     explaining that there was no time, that there were other ways of

 4     crossing.

 5             The simple answer -- if Mr. Farr wants to know why you did, he'll

 6     ask you.

 7             Please proceed.

 8             MR. FARR:

 9        Q.   All right.  Turning to the permits to cross the border with

10     weapons.

11             In paragraph 32 of your statement, you said only people with a

12     permit from the highest level would be allowed to cross the border with a

13     weapon.  And then you clarified that that meant either a permit signed by

14     Bogdanovic or by Predrag Markov.  That means that in your view Bogdanovic

15     was someone with a high level of authority or, in fact, from the highest

16     level in July of 1991.  Is that correct?

17        A.   Yes.

18        Q.   And I think we've already clarified this, but just to make it

19     completely clear:  That means that you as a member of the Vojvodina

20     provincial SUP had been ordered to accept a permit issued by someone from

21     the MUP of the Republic of Serbia; is that correct?

22        A.   Yes.

23        Q.   And, in fact, the only two people that you're aware of who

24     crossed at your check-point with weapons, that is, Arkan and Rade Kostic,

25     both had permits issued by Bogdanovic of the Serbian MUP rather than

Page 13253

 1     Markov of the Vojvodina SUP.  That's also correct, isn't it?

 2        A.   That's correct.

 3        Q.   Okay.  Moving on to Arkan's attempts to cross the border and then

 4     subsequently crossing the border.

 5             The first time Arkan came to the border, when you turned him

 6     away, how many men and how many vehicles did he come with?

 7        A.   It was around 1900 hours in the evening.  He arrived with seven

 8     or eight men and with three or four jeeps.

 9             JUDGE ORIE:  Mr. Farr, I urged Mr. Jordash not to ask questions

10     where the answers are easily found.  I mean, we have the three jeeps in

11     paragraph 34, isn't it?

12             MR. FARR:  You're correct.  I should have limited my question to

13     the number of men.

14             JUDGE ORIE:  Yes.  Yes, then, of course, you would -- you might

15     want to know whether -- I mean, three jeeps, load them very well, you

16     have 15 to 20, and if you have less passengers then perhaps you have

17     eight to 12.  If it's of vital importance for you to know whether it was

18     8, 9, 12, 13, or 14, then of course ask your questions.  If it's not

19     really important, the picture is clear.  He arrived with a couple of

20     jeeps, people manning those jeeps, and we now even know that, I think,

21     there were Mitsubishi Pajeros, isn't it?

22             MR. FARR:  That's right.

23             JUDGE ORIE:  Yes, so we get four mules, six mules?  What do you

24     think it was?  Let's try to focus on the core.

25             MR. FARR:  Your Honour, I do believe that the information is

Page 13254

 1     relevant.

 2             JUDGE ORIE:  Okay.  I'm not saying --

 3             MR. FARR: [Overlapping speakers] ... okay.

 4             JUDGE ORIE:  But let's not ask -- let's not be repetitious.  If

 5     there is any clue in there, go to that point as quickly as you can.  I

 6     know that cross-examination is an art, but efficiency and artistic

 7     performance, you should strike a fair balance between that.  I am usually

 8     more in favour of less artistic performance, at least in the courtroom.

 9             Please proceed.

10             MR. JORDASH:  Sorry, would it be okay if we took the break now,

11     Your Honour, please?

12             JUDGE ORIE:  Yes.  It's quarter past 10.00, so that would be --

13     usually we have a break after 75 minutes, Mr. Farr.

14             We'll take a break, and we'll resume at a quarter to 11.00.

15                           --- Recess taken at 10.15 a.m.

16                           --- On resuming at 10.49 a.m.

17             JUDGE ORIE:  Mr. Farr, you may proceed.  And, as you know,

18     proceeding means moving forward.

19             MR. FARR:  Thank you, Your Honour.  I'll keep that in mind.

20             JUDGE ORIE:  Please proceed.

21             MR. FARR:

22        Q.   Sir, before the break you told us that Arkan arrived with seven

23     or eight men.  How many men did you have with you at the check-point at

24     that time?

25        A.   Three.

Page 13255

 1        Q.   Who was better armed, Arkan's eight men or your three men?

 2        A.   Arkan's Men.

 3        Q.   Did they have permits for the modern Heckler weapons that you

 4     indicate they had with them?

 5        A.   The permit listed all the weapons, we checked everything, and

 6     then they were let go.  Everything tallied with the crossing permit - the

 7     names, the family names, and the registration numbers of the vehicles

 8     that were either in the cars or on the bodies of Arkan's group.

 9        Q.   Do you recall whether their weapons permits had been issued by

10     the Serbian MUP or the Vojvodina MUP?

11        A.   That permit was issued by the MUP of Serbia.  It was signed by

12     Radmilo Bogdanovic.  That kind of weapons was not a standard issue in the

13     MUP.  Neither in the territory of Vojvodina or Serbia did I see that kind

14     of weapons in the hands of MUP members, and with that I also mean Kosovo,

15     where I did a number of tours.  Moreover, my men, the members of my

16     group, did not even know the proper name of that kind of weapon.

17        Q.   Sir, you've just mentioned the permit signed by Bogdanovic that

18     Arkan had the second day.  On the first day, when he came to the border

19     and asked to cross, did you check for weapon permits on that occasion, or

20     no?

21        A.   Well, that meeting actually bordering on a conflict breaking out

22     between me and my men, on the one hand, and him and his men, on the other

23     hand.

24        Q.   But you didn't let him cross because you were determined to carry

25     out your orders and respect the law; correct?

Page 13256

 1        A.   Correct.  I disallowed that.  However, when we left, I informed

 2     my superiors about his presence and about his conduct.

 3        Q.   At page 73 of the transcript yesterday, you said that no one was

 4     able to control Arkan.  In fact, you've just told us that you were able

 5     to stop Arkan and eight relatively heavily armed men with three of your

 6     men.  Doesn't that show that someone with sufficient determination

 7     determines to enforce the law could stop Arkan?

 8        A.   When I said that, I meant people from across the border.  Once I

 9     crossed, I tried to act in a similar way, but Radovan Stojcic would not

10     allow me to do that.  Radovan Stojcic said that whatever problems that

11     they had with him would be his responsibility, that he would deal with

12     everything.

13        Q.   In other words, it's not that Arkan couldn't be controlled; it's

14     that there was a decision taken not to control him.

15        A.   No such decision was ever taken.  For us to do anything, we had

16     to have an approval.  The 16 policemen that had crossed over, together

17     with me, on several occasions attended meetings and asked to be

18     transferred from Erdut and for Arkan to be removed.  We wanted to leave

19     the area.  And Badza always claimed that he would deal with the matter

20     and that he would make sure that Arkan behaved in accordance with the

21     rules.

22             JUDGE ORIE:  Mr. Farr, would you allow me to ask one clarifying

23     question.

24             We've heard Arkan arriving late at night with some men in the

25     possession of weapons.  You didn't know about Arkan.  He said that he was

Page 13257

 1     sent by Bogdanovic.  Now, you earlier told us that you would not allow

 2     anyone to cross without the required documents, but you also told us that

 3     anyone who was in possession of weapons, whether legally owned or not,

 4     you would seize them.  Why didn't you seize the weapons of a man you were

 5     not familiar with as being Arkan on that same evening?

 6             Why didn't you seize the weapons?

 7             THE WITNESS: [Interpretation] I had in mind the security of my

 8     people and my own security and safety.  People who had arrived with him

 9     had already taken favourable positions, so both me and my men would have

10     come under threat.  Having known Arkan as he was -- actually, I only

11     learned it subsequently.  At that moment, I did not know who Arkan was.

12     He was just an ordinary Joe like anyone else.  However, if I had been in

13     a position to do that, I would have done it, you -- you rest assured.  I

14     think that my move was smarter because I spared the lives of my men and

15     my own life.  I faltered a little when I heard him say that he had been

16     sent by Mr. Bogdanovic.  I hesitated but still did what I did.

17             JUDGE ORIE:  You say people who had arrived with him had already

18     taken favourable positions.  What do you mean exactly by that?

19             THE WITNESS: [Interpretation] When he arrived and when he told me

20     who he was and that he was there to cross, our conversation started

21     calmly.  However, when he realized that I was determined not to let him

22     go, his men got out of the vehicles and took positions on the ground from

23     which they could shoot.  I did put a rifle -- a bullet in -- in -- in the

24     barrel so I would have fought and I would have taken one of them with me,

25     but I didn't think that that was necessary.  I thought that there were

Page 13258

 1     ways to disarm him and his men.  However, when he came back with the

 2     permit, there was no reason for me not to let him cross the river.

 3             JUDGE ORIE:  If I understand your story well, you would not have

 4     stopped him if he would have wanted to cross.  Sending him back was

 5     because he consented to that, rather than that you forced him to go back.

 6     Because you say:  We couldn't take the weapons.  They were ...

 7             THE WITNESS: [Interpretation] He couldn't cross.  In order to

 8     cross the Danube, he should have had a vehicle.  I had already

 9     transferred the vehicle to the other bank.  The person who was in charge

10     of driving that, when things came to a head, I said to the men to cross

11     the Danube.  The only thing that could have happened was an incident and

12     we would have killed each other.  But you have to rest assured that he

13     would not have crossed, even if that had taken my life.

14             JUDGE ORIE:  But you were unable to seize his weapons.  He had

15     better weapons.  They were in the majority.  That was the situation,

16     wasn't it?

17             THE WITNESS: [Interpretation] Yes, yes, that's it.  And after his

18     voluntary action, he rallied his men back into the vehicle and returned,

19     seeing that he couldn't accomplish his objective.

20             The next day he was a different man, very courteous.  He even

21     apologised.

22             JUDGE ORIE:  Mr. Farr, please proceed.

23             MR. FARR:

24        Q.   You said that there was no way Arkan was going to cross without a

25     permit.  You've also said yesterday that Arkan couldn't be controlled.

Page 13259

 1             Isn't it correct that senior members of the MUP, and, in

 2     particular, Bogdanovic, could have prevented Arkan from crossing the

 3     border simply by not giving him a permit?

 4        A.   I cannot comment on people above me.  All I know is what I did.

 5     I don't know what Radmilo Bogdanovic did.  He did not account to me.  I

 6     was passing on my information to Markov, my first superior, that is,

 7     Zavisic.

 8        Q.   But as far as you're concerned, you would never have let Arkan

 9     across the border without a permit from Bogdanovic or Markov?

10        A.   I agree.  Either I or he.  He couldn't cross with me on that

11     check-point.  But, rest assured that he wouldn't have crossed anyway

12     without an appropriate permit.

13        Q.   Now, on the second occasion, the next morning, as we've been

14     discussing, he had a permit signed by Bogdanovic.  Do you know why he got

15     a permit from Bogdanovic, who I assume was in Belgrade, rather than from

16     Markov, who I assume was in Novi Sad?  Isn't Novi Sad closer to where you

17     are -- where you were than Belgrade is?

18        A.   I'm sorry, you mean Arkan?

19        Q.   Yes, I'm talking about Arkan, the next morning.

20        A.   I suppose.  I can't be sure.  But I believe that Arkan lived in

21     Belgrade, and it was easier for him to get a permit there.  Secondly, I

22     believe that Markov didn't know Arkan either, and he wouldn't have given

23     him one.

24        Q.   So your assumption is that Arkan was closer to the Serbian MUP

25     leadership than to the Vojvodina SUP leadership?

Page 13260

 1        A.   I can only guess based on the permit he brought, but I really

 2     don't know.

 3             JUDGE ORIE:  Let's refrain from guessing or invitations to guess.

 4             Please proceed.

 5             MR. FARR:

 6        Q.   The permit that Arkan showed you was the first permit you had

 7     seen for someone to cross the border with weapons.  This was an

 8     extraordinary situation.  You must have reviewed the permit very

 9     carefully; correct?

10        A.   He took it, compared everything, kept it, and forwarded it

11     through me to Zavisic.  Where he got it, I don't know.

12        Q.   You personally saw the permit that Arkan had at the border,

13     didn't you?

14        A.   Correct.

15        Q.   And you personally reviewed it?

16        A.   I personally searched the men, the jeeps, after they left the

17     jeeps.  Every serial number of every weapon was checked against licences,

18     against the permit, and only then were they allowed to cross.  And it was

19     in the presence of another two of my men.

20        Q.   In your opinion, is there any possibility that the permit was a

21     forgery?

22        A.   I don't know.  No.

23        Q.   Did the permit indicate that Arkan was a member of the JNA, the

24     TO, or the MUP of Serbia?

25        A.   No.  There was just the letterhead of the MUP of Serbia, and in

Page 13261

 1     the signature it said "approved by" such and such.  If you want me to, I

 2     can try to remember before the end of the day and write what this permit

 3     looked like.

 4             I took that permit away and attached it to my daily reports that

 5     I wrote every day and passed it on together with my report.  They wanted

 6     it as an attachment.  I really don't understand why I wasn't given access

 7     to the documents I had written before.

 8        Q.   Did the permit identify Arkan's position in any way, or did it

 9     just have his name and the names of his men?

10        A.   Number one, Zeljko Raznjatovic, Arkan; number of the pistol and

11     number of the Heckler that he carried.  Below that are the names.  There

12     was no position indicated.

13        Q.   Did you call anyone to verify the authenticity of the permit?

14        A.   Since I had written in my previous report about the clash, the

15     incident, whatever you want to call it, I also forwarded this report,

16     indicating the exact time and what transpired.  And after they left, my

17     superior Zavisic was informed that this person had arrived and he was

18     allowed to cross with such and such a permit.

19        Q.   Are you aware of any provision of applicable law aside from the

20     permit -- I know you acted on the basis of the permit, but are you aware

21     of any provision of applicable law that would allow a person who was not

22     a member of the army, the Territorial Defence, or the MUP to cross the

23     border between Vojvodina and Croatia in a group of men armed with modern

24     military weapons?

25        A.   I don't know of any law enacted on the matter.  At that time,

Page 13262

 1     there existed federal republic and provincial legislation about

 2     procurement and carrying of fire-arms.  They were in effect as long as I

 3     worked in the MUP, but in that time they changed at least three times.

 4        Q.   Do you agree that this is something that wouldn't have happened

 5     in peacetime under normal circumstances?

 6        A.   I agree.

 7        Q.   I'd now like to move on to the incident in which Rade Kostic

 8     crossed the border.

 9             First of all, just to get the date, you said Arkan crossed the

10     border in July of 1991.  Rade Kostic crossed before you left for

11     Eastern Slavonia, obviously, which was in early August.  So this was

12     sometime in July or very early August of 1991; is that correct?

13        A.   Yes.  After Arkan, came Kostic.  I don't know the exact time.

14     That's sometime between me and Arkan.

15        Q.   In paragraph 38 of your statement, you said the permit was for

16     Radoslav Kostic and his group.  How many people were in the group?

17        A.   Twenty to 30.  Again, everything was checked.  Everything was on

18     the permit, all the serial numbers of weapons, just as with the first

19     permit.

20             JUDGE ORIE:  The question was:  "How many people were in the

21     group?"  You said:  "Twenty to 30."  And then we can wait for the next

22     question.

23             Please proceed.

24             MR. FARR:

25        Q.   Now we know that -- again, you received the permit, and you acted

Page 13263

 1     on the basis of the permit.  Were you ever told why Kostic needed to

 2     cross the border with a group of 20 to 30 armed men?

 3        A.   No.

 4        Q.   Did you ever learn who these men were?

 5        A.   From their IDs, I learned that they were from Bosnia-Herzegovina,

 6     the area of Ozren, who had family in Borovo Selo.  More exactly, in

 7     Srepolje [phoen].  Sorry, not Srepolje, Savulja, which is part of

 8     Borovo Selo.

 9        Q.   Did this permit say that these individuals were members of the

10     January, the TO, or any MUP?

11        A.   No.

12        Q.   So, again, am I correct that this situation of a group of 20 to

13     30 armed men with no affiliation to the JNA, to the TO, or to any MUP is

14     something that not -- would not have happened in peacetime under ordinary

15     circumstances?

16        A.   I don't see why a group of armed men would appear in peacetime

17     anywhere.

18        Q.   In your testimony yesterday, you indicated that you attended the

19     awards ceremony at the Kula camp.  Do you know that that camp was named

20     after Rade Kostic?

21        A.   Yes, I know that.

22        Q.   Did you see Jovica Stanisic laying a wreath at the memorial to

23     Kostic during the course of the Kula camp celebration?

24        A.   I was not there during the laying of the wreath, but I was at

25     Kula.  I saw it on the video shown me a couple of days ago.

Page 13264

 1        Q.   Sir, there's other evidence in this case that indicates that

 2     Rade Kostic was a member of the Serbian State Security Service as of the

 3     1st of December, 1990, and that he was deployed to complete different

 4     tasks within the State Security Service by Jovica Stanisic on the

 5     21st of June, 1991.

 6             Do you have any reason to dispute that information?

 7        A.   I was not a member of the State Security Service.  I can only

 8     talk about my three contacts with Mr. Kostic.  And I don't know that he

 9     was a member of the state security.  That's not how he was introduced to

10     me.

11        Q.   But you don't have any reason to dispute that information; is

12     that correct?

13        A.   I can say neither yes or no.  I can only guess.  I can only tell

14     you about the occasions where I was present and say what I heard.  As for

15     the rest, I can neither confirm nor deny.

16        Q.   How was Rade Kostic introduced to you?

17        A.   As a friend of Ilija Kojic and a man who had worked in the MUP of

18     Croatia.

19        Q.   As a close friend of Ilija Kojic?

20        A.   Yes.  Because he attended the funeral of Ilija Kojic's brother

21     and nephew.

22        Q.   Did Kojic and Kostic work together, as far as you know?

23        A.   To the best of my knowledge, in Croatia, yes.

24        Q.   What --

25        A.   They knew each other from before the outbreak of the conflict in

Page 13265

 1     Croatia.

 2        Q.   What kind of work did they do together in Croatia?

 3        A.   Both were members of the ministry; one in public, the other in

 4     state security.  This is all my speculation.  If you want me to lie, I

 5     can, but I gave an oath not to.

 6        Q.   Sir, we definitely don't want you to speculate.

 7             Which part of that is speculation, though?  You know that they

 8     worked together.  That's not speculation; correct?

 9        A.   My contacts with Kostic were very short.  The first time was when

10     he brought that group; the second was at the funeral; and the third and

11     fourth time, again, at funerals.  So I really know very little about

12     Mr. Kostic.  I can talk for five days about Ilija Kojic.  But I don't

13     know anything about Kostic, really.

14        Q.   You said that you don't know one way or the other whether Kostic

15     was a member of the Serbian State Security Service.  Assuming for a

16     moment that the other evidence in this case is correct and that he was,

17     do you know why one of only two people who was allowed to legally cross

18     at your check-point with weapons would be someone associated with the

19     Serbian State Security Service?

20             JUDGE ORIE:  We start with an assumption and then we ask for an

21     explanation, where the witness said that --

22             Can you answer that question?  Do you have any knowledge?

23             MR. FARR:  Perhaps I can ask it in more general terms,

24     Your Honour.  I take your point.

25             JUDGE ORIE:  Please proceed.

Page 13266

 1             MR. FARR:

 2        Q.   Do you know of any reason that individuals associated with the

 3     Serbian State Security Service should have special treatment in terms of

 4     being able to cross the border between Vojvodina and Croatia with weapons

 5     during the period you were at Vajska?

 6        A.   Not a single member of the ministry, either in public or state

 7     security, received a permit.  Arkan did and Kostic did.  Neither of them

 8     was a member of the Ministry of the Interior.  That was not even written

 9     in their permits.  If they had been members, I would have been ashamed to

10     be one.

11     (redacted)

12     (redacted)

13     (redacted)

14     (redacted)

15     (redacted)

16     (redacted)

17     (redacted)

18     (redacted)

19     (redacted)

20     (redacted)

21     (redacted)

22     (redacted)

23     (redacted)

24     (redacted)

25     (redacted)

Page 13267

 1     (redacted)

 2     (redacted)

 3     (redacted)

 4     (redacted)

 5     (redacted)

 6     (redacted)

 7     (redacted)

 8     (redacted)

 9     (redacted)

10     (redacted)

11     (redacted)

12     (redacted)

13     (redacted)

14     (redacted)

15     (redacted)

16     (redacted)

17     (redacted)

18     (redacted)

19     (redacted)

20     (redacted)

21     (redacted)

22        Q.   -- you say that you didn't see any members of the DB of Serbia at

23     the crossings.  Does this document cause you to revise that evidence in

24     any way?

25        A.   There were no members of the DB of Serbia in the area while I was

Page 13268

 1     there.  Not a single person introduced themselves that way, nor have I

 2     ever seen an ID of such a person.

 3        Q.   So your conclusion is based on the way people introduced

 4     themselves and the IDs that you saw; is that correct?

 5        A.   Correct.  Nobody has it written on their forehead that they were

 6     an employee of this and that.  I reviewed all IDs.  I put that on record.

 7     I cannot make things up and say that somebody was an employee or not

 8     unless they introduced themselves that way or produced an ID showing

 9     that.

10        Q.   All right.  I'm going to move on to your service in

11     Eastern Slavonia.

12             In paragraph 47 of your statement, you said that you had several

13     conversations with Hadzic and Kojic in which they tried to recruit you to

14     participate in the defence of Eastern Slavonia.

15             As briefly as possible, what did they say to you; what did they

16     want you to do; and why did they want -- well, why was it necessary for

17     you to come?

18        A.   Considering they knew I was a graduate of the Military Academy,

19     and I graduated five years before we met, of course, we discussed one

20     another, and that's why I said I could say a lot about Ilija, but as for

21     me personally, I had already met a great number of people who had crossed

22     by that time.  I acted in such a way that inspired confidence, and those

23     people in Western Slavonia viewed us as members of the special forces,

24     and in any case, they had a lot of trust in me and my men.  And that's

25     why he asked me, I suppose, to cross over.  But I didn't do it until my

Page 13269

 1     superior contacted me and invited me to cross over together with him.  It

 2     was only then that I accepted.

 3        Q.   Did you find it strange that they were trying to recruit active

 4     policemen, active members, of the MUP to go set up what was fundamentally

 5     a military organisation in an area completely outside the jurisdiction of

 6     that MUP?

 7        A.   Certainly.  However, knowing the circumstances, and after talking

 8     to my family, my parents, brother, sister, and uncles in Obrovac and

 9     Benkovac, I reacted quite differently.  I wanted to protect my family.

10        Q.   Do you know whether --

11        A.   It's because of my family that I finally left, to protect my

12     sons.  I'm a bit emotional when I talk about my family.  I hope you don't

13     hold it against me.

14        Q.   Do you know whether there were any existing laws and regulations

15     that would provide for members of the Vojvodina SUP and the Serbian MUP

16     to serve in a newly constituted Territorial Defence of a newly

17     constituted autonomous region in Croatia?

18        A.   I don't know of any laws or regulations.  All I know is that

19     every tour of ours in the territory of another republic was organised by

20     the federal MUP, federal SUP, be it in Macedonia or anywhere else.

21        Q.   To your knowledge, did the federal MUP organise your tour in the

22     Territorial Defence of SBWS?

23        A.   I've said this a number of times.  Nobody organised my tour.  I

24     went as a volunteer on my own initiative.  And if I am to be held

25     accountable for that, I'm ready.

Page 13270

 1             No state institution has anything to do with my crossing over to

 2     that territory.

 3        Q.   Well, presumably the Vojvodina SUP had to at least approve it;

 4     correct?

 5        A.   I did not call or say good-bye to anyone when I was leaving,

 6     apart from my superior Zavisic at the time, who crossed over together

 7     with me.  Except that I brought certificates where I was every month, and

 8     I received my salary.

 9        Q.   So the Vojvodina SUP clearly approved of your deployment to the

10     SBWS to the extent that they knew that you were there and they continued

11     to pay your salary.  In that sense, they accepted and endorsed that

12     deployment; is that correct?

13        A.   They did not deploy me.  I crossed over of my own will.  I

14     received my salary.

15             JUDGE ORIE:  That wasn't the question.  The question was whether

16     they accepted by -- and endorsed any deployment, not necessarily by them,

17     but whomever would have sent you there, by continuing to pay your salary

18     and to accept your absence from duty in your normal position.

19             That was the question.

20             THE WITNESS: [Interpretation] I've said it already.  I don't know

21     whether they approved.  But I did continue to receive my salary.  If

22     the -- the fact that my salary continued to be paid constitutes

23     endorsement, then I agree.

24             JUDGE ORIE:  Please proceed, Mr. Farr.

25             MR. FARR:  Thank you, Your Honour.

Page 13271

 1        Q.   You also indicated you were paid a per diem during your time in

 2     Eastern Slavonia.  Who paid your per diem?

 3        A.   We received per diem from Mr. Badza, where a list was made of all

 4     of us, 21 of us, if I'm not mistaken, and we all signed for the money we

 5     received.

 6        Q.   Do you know where the money came from?

 7        A.   I don't know, really don't know.

 8        Q.   All right.  We've said that you arrived in Eastern Slavonia in

 9     early August and stayed for approximately two months.  Were you based in

10     Erdut this whole time?

11        A.   I was not there the whole time.  At the insistence of 16 of us

12     and my insistence and some commanding officers, we were transferred away

13     from Erdut.

14        Q.   When did that happen?  How long after you arrived?  Obviously an

15     approximation.

16        A.   Couple of days before I left Erdut.

17        Q.   Sorry, I didn't quite understand that.  You arrived Erdut in

18     early August.  How long did you remain in Erdut?

19        A.   About two months.  And a couple of days before I left

20     Western Slavonia, Baranja, and Srem, we were transferred away from Erdut.

21     I didn't even manage to move all my things because I was told that my

22     children were alone.  I left my things behind and went to rejoin my

23     children.

24             JUDGE ORIE:  Mr. Farr, could I seek clarification on one matter.

25             Earlier you testified - I'm quoting from page 13 - "every month I

Page 13272

 1     had to send a certificate in order to be able to receive the salary that

 2     Badza had to approve in the -- in the area of Erdut."

 3             That suggests that if you could not have shown such a certificate

 4     that you might not have received your salary.

 5             THE WITNESS: [Interpretation] Correct.

 6             JUDGE ORIE:  Which - and please tell me whether you agree with

 7     that - which means that the services you rendered as a volunteer, if you

 8     would have not rendered those services, they would have stopped paying

 9     you.

10             THE WITNESS: [Interpretation] After the liberation of Dalj, all

11     those volunteers who had worked in Serbia or in the autonomous province

12     in any company could --

13             JUDGE ORIE:  I'm not asking about anyone else.  I'm asking about

14     your position.  If you would not have rendered those services, that they

15     would have stopped paying you, because that was a requirement for

16     receiving your salary.

17             THE WITNESS: [Interpretation] I'm not sure what you mean when you

18     say "rendering services."

19             What services was I rendering?  I don't understand the term.

20             JUDGE ORIE:  Your activities as a volunteer.

21             THE WITNESS: [Interpretation] I just said, all the volunteers who

22     had worked in Serbia and Vojvodina and who had come across with that

23     certificate, we received salary.  Which means that without that

24     certificate I would not have been able to receive my salary.  And having

25     said that, what I mean to say is that I did not differ in any way from

Page 13273

 1     any other volunteer.

 2             JUDGE ORIE:  I'm not interested in whether your position differed

 3     that much from others.  It's good to know.  But I would like to focus on

 4     that apparently if you would not have deployed your activities as a

 5     volunteer, you would not have been paid by your boss.

 6             THE WITNESS: [Interpretation] Correct.

 7             JUDGE ORIE:  Which means that your boss, or the institution you

 8     worked for, made payment dependant on your being active as a volunteer.

 9             THE WITNESS: [Interpretation] That's correct.

10             JUDGE ORIE:  Please proceed, Mr. Farr.

11             MR. FARR:

12        Q.   A moment ago you told us that a few days before you left the SBWS

13     you were redeployed from Erdut to some other location.  What was that

14     other location?

15        A.   Saponia, very close to the centre.

16        Q.   And why did that happen?  Was this related to the dispute between

17     Arkan and some of the men you were with?

18        A.   I and the other 16 members who had arrived insisted, because we

19     didn't want to be close to Arkan or his men.  They were not the kind of

20     men we could work with.  Not before, not then.

21        Q.   In paragraph 50 of your statement, you say that Goran Hadzic

22     appointed Badza, you, and the other members of your group to positions in

23     the Territorial Defence.  If you know - and you may not - what was

24     Hadzic's legal authority to create a TO and appoint its leadership?

25        A.   I don't know.  The information about the appointment was conveyed

Page 13274

 1     to us by Badza.  We received blue IDs containing our names and the title,

 2     the function, what we did.

 3        Q.   Were those signed by Goran Hadzic?

 4        A.   Yes.

 5        Q.   After Hadzic appointed him, do you know whether Badza then

 6     reported to Hadzic; or did he continue to report to MUP Serbia; or did he

 7     report to both?

 8        A.   The only times I saw Badza was in the room at meetings.  He never

 9     reported to me on what he did and where he went.  I had two main tasks

10     that I had to accomplish before I went back.

11        Q.   I'm just going to rephrase my question.  I'm not positive you

12     understood it.

13             After Hadzic appointed Badza, was Hadzic then Badza's superior;

14     did Bogdanovic continue to be Badza's superior; or were both Hadzic and

15     Bogdanovic Badza's superior?  Or was there some other situation?

16        A.   As far as I saw things and as far as I understood things, Goran

17     was above Badza.  That's the way I perceived things.

18        Q.   Was your understanding that Badza also continued to be

19     subordinated to Bogdanovic at the time?

20        A.   I was not aware of any contacts between him and Bogdanovic.  I

21     don't know to this very day whether they took place.

22        Q.   In paragraph 52, you said that your task was to record the

23     locations and strength of all forces in the SBWS.  I assume that you're

24     referring to Serb forces rather than Croat forces; correct?

25        A.   Whatever information I had, I put it on the map.  In military

Page 13275

 1     terms, I used blue and red colours.  I marked check-points, barricades.

 2     Whatever I was able to locate, I recorded that on the map.  From both

 3     sides.

 4        Q.   What was the approximate strength of the SBWS TO at that time?

 5     Numerical strength.

 6        A.   In numerical terms, 2- to 3.000.  But only 300 to 400 were

 7     actually carrying arms.

 8        Q.   What other forces were present on the Serb side?

 9        A.   The military, the TO, and perhaps some locals who were nowhere.

10     They were civilian protection or something of the sort.  That's how I saw

11     them.

12        Q.   And what was the approximate strength of the military that you've

13     just referred to, at that time?

14        A.   The military was in Vukovar and in the barracks.  And I believe

15     that their strength was of a battalion.  I could be more precise if I

16     were given the map that I drafted and that stayed behind.

17        Q.   And what's the approximate numerical strength of a battalion?

18        A.   Six hundred to 700.

19        Q.   How did the geographical area under the control of Serb forces

20     change during your time in the SBWS?

21        A.   Please repeat your question.  I don't know what you mean when you

22     say "the geographical area."

23        Q.   On the day you left the SBWS, did Serb forces control more

24     territory or less territory than on the day you arrived?

25        A.   Not a single settled area was taken while I was there.  There was

Page 13276

 1     an attempt to take Bogdanovci.  Ilija was wounded on that occasion.  And

 2     after that I returned.

 3        Q.   In paragraph 58, you said that 40 police officers came to

 4     Eastern Slavonia and that they had been tasked by the minister of the

 5     interior of the Krajina to set up police stations.

 6             When you say "the minister of the interior of the Krajina," are

 7     you referring to Milan Martic?

 8        A.   Milan Martic and Boro Bogunovic.

 9        Q.   You also said that those police officers then co-ordinated with

10     Zavisic in setting up police stations.  So tell me if this is accurate:

11     Milan Martic, as the minister of the interior of the SAO Krajina, along

12     with Boro Bogunovic, sent police officers to the SBWS, where they

13     co-ordinated with Miodrag Zavisic, who was paid by MUP Serbia and

14     appointed by Goran Hadzic to the SBWS TO.

15             I know that's complicated, but can you say whether that's correct

16     or not?

17        A.   Zavisic was tasked on behalf of the staff to set up police

18     stations in the area.

19             MR. FARR:  All right.  Can we now please have document P2452 on

20     the screen.  And if this evidence is ever made public, this document

21     should remain confidential, this portion should remain confidential.

22             This is a report dated 9 December 1991 from Jovica Stanisic, as

23     the assistant minister of the interior of Serbia, to the minister of

24     defence of Serbia.

25        Q.   Sir, please take a moment to read this document, and let me know

Page 13277

1     when you've finished reading it and then I'll ask you some questions.

 2        A.   Go ahead.

 3        Q.   Are you able to explain why information from the TO and police of

 4     Western Slavonia would go through Jovica Stanisic on its way to the

 5     minister of defence of Serbia?

 6        A.   I can't say anything about the organisation of the state

 7     security.  I wasn't there, and I am not familiar with the workings of the

 8     state security.  The only thing I could share with you would be my school

 9     knowledge.  I've never seen this before, and I will probably not see it

10     again.  Since this is going to be confidential, I have not bothered to

11     read this.

12             JUDGE ORIE:  You were asked to read it.  A simple question was

13     put to you.  I do understand that you have no explanation for why and how

14     the reporting took place as it appears in this letter.  And I would

15     invite you not to consider matters which are exclusively for our court

16     system, to consider them when reading matters, yes or no.

17             Please proceed.

18             MR. FARR:

19        Q.   Can I ask you, in general terms --

20        A.   I'll do my best.

21        Q.   In general, do you agree that the TO would report directly to a

22     Ministry of Defence rather than to a Ministry of the Interior under

23     normal circumstances; is that correct?

24        A.   The Territorial Defence was duty-bound to report to somebody.

25     Yugoslavia still existed.  And certainly we collected information and

Page 13278

 1     intelligence everywhere.  In all the territories of Yugoslavia, every

 2     intelligence I received about Slavonia, Croatia, or anywhere else, I

 3     recorded, and that intelligence would be conveyed through the federal MUP

 4     to wherever necessary.  In many cases, I wrote --

 5        Q.   I apologise for interrupting you.  I just want us to get through

 6     this as quickly as possible.  I'm not asking about your experience.  This

 7     is a general question based on your knowledge and having lived in the

 8     former Yugoslavia.

 9             In general terms, normally a TO would report to the Ministry of

10     Defence rather than to the Ministry of Interior; is that correct?

11        A.   That is correct.

12        Q.   When you --

13             THE INTERPRETER:  Could the witness kindly speak into the

14     microphone, please.

15             JUDGE ORIE:  You're invited to come a bit closer to the

16     microphone so that the interprets can better hear you.

17             Please proceed, Mr. Farr.

18             MR. FARR:

19        Q.   During your time in the SBWS TO, did you or anyone else in the TO

20     staff send reports to any of the ministries in Serbia?

21        A.   I did not draft any reports.

22        Q.   To your knowledge, did any of the other four officers who went

23     with you - Badza, Zavisic, Trajkovic, and the others - draft and send

24     reports to any ministry in Serbia or Vojvodina?

25        A.   While I was there, since I was chief, obviously I would have had

Page 13279

 1     to have seen reports.  So I can tell you that no reports were either

 2     drafted or dispatched.

 3             Badza spoke to Goran Hadzic and conveyed his messages.  That is

 4     all I know.

 5        Q.   Okay.  I've finished with this document now.

 6             You were asked yesterday about training in Eastern Slavonia.  And

 7     one of the things you mentioned was that there had been some attempts to

 8     train the local population prior to your arrival there.  At page 50 of

 9     the transcript, you said:

10             "The first time something like that was organised it involved a

11     person who had been training in Golubic training the famous ..." and then

12     there is a word missing from the written transcript.  I think I heard you

13     say "Knindze."  Is that what you said?

14        A.   That person who arrived at the crossing in a camouflage uniform

15     introduced that way to us.

16             JUDGE ORIE:  The question was, because it was illegible, whether

17     you said Knindzes.  That's my recollection as well.

18             Is that what you said yesterday?

19             THE WITNESS: [Interpretation] Yes, yes, I did mention that.

20             JUDGE ORIE: [Previous translation continues] ... yes.

21             MR. FARR:

22        Q.   You had already heard of Golubic and of the Knindze at that time;

23     is that correct?

24        A.   I had not heard of Golubic, but I did hear of Knindze.

25        Q.   And what had you heard about the Knindze in August and

Page 13280

 1     September of 1991?

 2        A.   That those were men who had helped the Serbian people around Knin

 3     and in the settled areas there, and that owing the -- to them, the

 4     Serbian people had survived in that area.

 5        Q.   Who did you learn that from or how did you learn that?

 6        A.   I heard that from Ilija Kojic and from my relatives.

 7        Q.   And why did you describe the Knindze as famous yesterday?  Is it

 8     for the reason you've just said, that they had saved the Serb -- the

 9     Serbian people around Knin?

10        A.   Well, yes.  That's how I know them.  Owing to them, the

11     population of Knin, Benkovac, Obrovac, and Plitvice remained living in

12     that area.  And I also know that those were units that operated under

13     Milan Martic.

14        Q.   Was it from Ilija Kojic that you learned that the units operated

15     under Milan Martic?

16        A.   Yes.

17        Q.   Yesterday you were also asked about three training centres that

18     Mr. Simatovic mentioned in his Kula speech.  With respect to Lezimir, you

19     said:  "Not a single trainee came to our area, nor do I know that there

20     were any training centres there."  You're speaking about the time that

21     you were in Eastern Slavonia; correct?

22        A.   Not in the centre, and not at the crossings where I was.

23        Q.   Right, exactly.  So in the places you were, between May and, say,

24     early October of 1991, that was the basis of your knowledge, that period

25     and those places; correct?

Page 13281

 1        A.   I don't know anything about those centres.  I only know where

 2     Lezimir is, its location.  Otherwise, I was never there, and I really

 3     don't know that anything was set up there.

 4        Q.   But you can't exclude the possibility that it happened without

 5     your knowledge; correct?

 6        A.   I can't speculate, nor do I want to.

 7        Q.   And the same would apply to your conclusions with respect to

 8     training in Ilok and Pajzos; correct?

 9        A.   As far as Pajzos is concerned, I still don't know anything about

10     that.  I'm here to tell the truth, and that's what I'm doing.

11             As far as Ilok is concerned, I also said that only one person who

12     was with me and mentioned something with this regard was Milovac.  I

13     stated that yesterday.  I really don't know anything else about those

14     centres.  If I knew anything, rest assured that I would tell you, because

15     I'm here to tell the truth.

16        Q.   Sir, I'm not in any way questioning your honesty.  I'm simply

17     attempting to determine what the basis of your knowledge is.  I want to

18     be clear about that.  And what the limits of your knowledge are.

19             The same with respect to Vukovar.  You mentioned one training

20     centre.  You said that's the only one you were aware of.  But similarly,

21     you can't exclude the possibility that other training occurred at Vukovar

22     either while you were there or at some later time without your knowledge;

23     is that correct?

24        A.   I can say that when I collected information about the deployment

25     of the JNA, the TO, the reservists of the JNA, and the police.  In

Page 13282

 1     Vukovar, I marked just one place where Serbs were deployed and where they

 2     controlled the area.  That's the place where Captain Kostic was, if I'm

 3     not mistaken.  The counsel gave me his name, and I agreed that that was

 4     him.  As for the rest, I really don't know anything.

 5             I'm not excluding any possibilities.  Things could have been

 6     done.  But I'm not a person who knows everything.  I'm just telling you

 7     what I know, even if it costs me.

 8             MR. FARR:  Your Honour, is this an appropriate time for the

 9     break?

10             JUDGE ORIE:  It is.

11             Mr. Farr, could you give us an indication as to the time you'd

12     still need?

13             MR. FARR:  If I could know how much time I've used, that might

14     help me make an estimate.

15             JUDGE ORIE:  That --

16             MR. FARR:  Not --

17             JUDGE ORIE:  -- seems to --

18             MR. FARR: -- not because I'm going to --

19             JUDGE ORIE:  If you have used little time and you would need only

20     little time to conclude, then I wouldn't expect you to take any more

21     time.  If you had taken --

22             MR. FARR:  Your Honour, the reason I ask is because I know

23     approximately how I'm getting through my outline, and that will help me

24     know, based what the pace is.

25             JUDGE ORIE: [Overlapping speakers] ... two -- two --

Page 13283

 1             MR. FARR:  It's not that I'm determined to use every possible

 2     moment.

 3             JUDGE ORIE:  Two hours and 10 minutes.

 4             MR. FARR:  Two hours and 10 minutes.  I think it will be less

 5     than another hour and a half.

 6             JUDGE ORIE:  Could you -- the last session will be 75 minutes.

 7     If it would be possible to conclude your cross-examination in that time,

 8     then we could, tomorrow, start with the re-examination.

 9             MR. FARR:  I will certainly do my best, Your Honour.

10             JUDGE ORIE:  We take a break, and we resume at 12.30.

11                           --- Recess taken at 12.04 p.m.

12                           --- On resuming at 12.35 p.m.

13             JUDGE ORIE:  Mr. Farr, you may proceed.

14             MR. FARR:  Thank you, Your Honour.

15        Q.   Sir, I'd like to go back to the Kula camp awards ceremony.

16             Were you actually present in the room when Mr. Simatovic made his

17     speech?

18        A.   This ceremony took place in several rooms.  When Franko Simatovic

19     was delivering his speech, I was there part of the time.  I did not

20     attend the whole ceremony.

21        Q.   Sorry, I didn't -- I didn't quite understand your answer.

22             During Mr. Simatovic's speech, were you present in that room?

23        A.   Yes.

24        Q.   Now, I think this is clear from what you said yesterday.  But

25     your assumption that he was bragging was based on your knowledge of the

Page 13284

 1     Kula camp itself and when that was constructed.  It was that, that led

 2     you to believe that the unit was only a year old; is that correct?

 3        A.   That's correct.  And I know because I have classmates who were in

 4     that unit.

 5        Q.   What are the names of your classmates who were in that unit?

 6        A.   Kersmanovic.

 7        Q.   What's the first name?

 8        A.   His nickname is Krsman, but I'm hard put to remember the first

 9     name.  If I remember it later, I'll tell you, but right now I'm drawing a

10     blank.

11        Q.   When did he join that unit?

12        A.   When it was established.  In 1995.

13        Q.   Where -- had he fought in the wars in Croatia and Bosnia; and, if

14     so, where?

15        A.   I don't know.  All I know is that he, too, was at one of the

16     check-points from which we controlled the border.  But he never mentioned

17     that he was involved anywhere.

18        Q.   Which check-point was he present at?

19        A.   Closer to Ilok, closer to Western Srem.

20        Q.   But, again, that's a border crossing between Slavonia and

21     Vojvodina; correct?

22        A.   Correct.

23        Q.   And did he have approximately the same responsibilities as you

24     when he was at that border crossing?

25        A.   Exactly the same.

Page 13285

 1        Q.   How long did he serve at that border crossing?

 2        A.   I think less long than I.  I think I'm one of the people who did

 3     the longest tour in that border belt.

 4        Q.   How did he come to move from the public security service of

 5     Vojvodina, I assume, to the State Security Service of Serbia?

 6        A.   A vacancy was announced.  I know there were people from Backo,

 7     Petrovo Selo, and I know a couple of men who were in that unit.

 8        Q.   Okay.  Other than this Kersmanovic, who else do you know who was

 9     in that unit?

10        A.   There was Branko Curcic and quite a few other people, but I can't

11     remember many of them now.  There was a person nicknamed Dzo [phoen] from

12     Backa Palanka.

13        Q.   And what did they tell you about when this unit was founded?

14        A.   We attended this anniversary celebration.  That means one year

15     before.  That's what I know about the unit and its establishment.  It's

16     certain that they had not been established before at Kula; I guarantee

17     that with my life, because those used to be premises for accommodating

18     refugees.

19        Q.   Okay.  So you know personally that the unit had not been at Kula

20     before that camp was established.  All the rest of your information about

21     the unit comes from these people who you know who were in the unit; is

22     that correct?

23        A.   Correct.

24        Q.   Okay.  So going back to your time in Eastern Slavonia, in

25     paragraph 60 of your statement, you discuss the first attack on

Page 13286

 1     Bogdanovci in which Ilija Kojic was wounded and in which Arkan also

 2     participated.  Am I right that this was a combined operation of the TO

 3     and Arkan's Men?

 4        A.   No.  The TO did not participate, apart from Arkan and one tank

 5     from the JNA.

 6        Q.   Why was Ilija Kojic present?

 7        A.   He obviously came to see how it was going on.  He found himself

 8     in cross-fire.  And after that, there was an attempt to rescue him.

 9        Q.   Did he still have a position with the TO at that point?  You said

10     that he had been commander earlier, before Badza.

11        A.   Yes.  He still played that role.  He and Badza handled all this.

12     And after he was wounded, Badza took over the whole thing.  That's how I

13     see it.  Although Badza had this order from Goran Hadzic, I believe the

14     two of them led that, this thing, on their own.

15             JUDGE ORIE:  Mr. Farr, I have some difficulties understanding the

16     answer as it appears on page 60, line 6.  If it's clear to you as an

17     answer to your question, then I will further think about it; but if it's

18     as unclear to me as it is to you, then perhaps we should seek

19     clarification.

20             MR. FARR:  I'll address that, Your Honour.

21        Q.   Sir, the answer that Judge Orie was referring to, you were asked:

22             "Am I right that this was a combined operation of the TO and

23     Arkan's Men?"

24             And you said:

25             "No.  The TO did not participate, apart from Arkan and one tank

Page 13287

 1     from the JNA."

 2             Maybe the best way to ask it is:  Who participated in the attack

 3     on Bogdanovci?

 4        A.   Arkan and one tank that was somehow resubordinated or given them.

 5     Those were the people who were involved in that activity.

 6        Q.   Okay.  So it was Arkan, his men, one tank that was resubordinated

 7     to Arkan by the JNA, and Ilija Kojic, who had a position with the TO, was

 8     present; is that correct?

 9        A.   Ilija Kojic was not involved in the operation.  He came after a

10     while to see what was going on.  If he had been involved, he wouldn't

11     have ended up as he did.  He would have known where everyone was.  The

12     way it was, he walked into a cross-fire.

13             MR. FARR:  Your Honour, if that's clear now, yes.

14        Q.   At paragraph 62 of your statement, you describe an incident

15     involving Rajo Bozovic.  In essence, it sounds to me like the story you

16     recount in that paragraph is one of Bozovic's group attempting to

17     interfere with the administration of justice for personal reasons.

18             Is that a fair summary of that incident?

19        A.   Sorry, which paragraph?

20             MR. JORDASH:  Perhaps in this instance my learned friend could

21     show him the paragraph, which hasn't been referred to before.

22             MR. FARR:  Sure.  Yeah, that's a --

23             JUDGE ORIE:  Yes, perhaps we could have it on the screen.

24             MR. FARR:  Yeah, it's D34.  And the paragraph number is --

25             MR. JORDASH:  It's 66, not 62.

Page 13288

 1             MR. FARR:  Ah, yes.  My apologies.

 2        Q.   Sir, if you -- if you feel like you need to take a moment to read

 3     the paragraph, do so; otherwise, I can ask my question.

 4        A.   You can ask your question, because I wrote this, and I'm only

 5     telling the truth in this statement as in my evidence.

 6             JUDGE ORIE:  Mr. Farr, you may ask the question.  If there's no

 7     need, if you say "I'm ready, I've read it," then Mr. Farr will put his

 8     question to you.

 9             MR. FARR:

10        Q.   Okay.  I'm not interested in the specific details of what

11     happened, but it seems to me that this is essentially a story of

12     Bozovic's group trying to interfere with the administration of justice

13     for personal reasons.

14             Is that a fair summary of this incident, in your opinion?

15        A.   They thought they would take the law in their own hands, but I

16     didn't let them.

17        Q.   And they tried to take the law into their own hands in a violent

18     and threatening way; correct?

19        A.   Yes.

20        Q.   What is your personal impression of Bozovic?

21        A.   That was my first encounter with him, and the result was that I

22     enforced the law according to the current legislation.  What kind of

23     impression could I have of a man who takes law into his own hands?

24        Q.   Right.  The answer is obvious, and it's that you had a very bad

25     impression of him; is that correct?

Page 13289

 1        A.   Yes.

 2        Q.   You said that after you'd disarmed Rajo Bozovic and six people

 3     you sent them back to Croatia, either to Erdut or some other place.

 4             Now, Bozovic is from Montenegro.  Why did you send him to Croatia

 5     rather than to Montenegro?

 6        A.   I did not send him either to Croatia or to Montenegro.  I

 7     disarmed him and turned the weapons over to Srbobran, because that not my

 8     SUP.  Colleagues from Novi Sad called me.  I did that job and then turned

 9     him over to the competent SUP, the one in Srbobran, to the officers who

10     were in charge, who had authority to conduct further investigation.  I'm

11     only the one who enabled them to do so, because they had not been able to

12     do it themselves.

13        Q.   Is it your belief or do you have information that he, after this

14     incident, went to Croatia, either to Erdut or some other place?

15        A.   That's the information I was given by the commander of that

16     station, in Srbobran.  It was my job to disarm them, arrest them.  And I

17     did that and handed them over.  He later told me that he had written up a

18     criminal report against all of them, listing all the charges according to

19     the current legislation, and then he released them after consultations

20     with the prosecutor.

21        Q.   And did that commander of the station in Srbobran tell you that

22     Bozovic had gone to Croatia, to Erdut?

23        A.   That's the basis on which I wrote this passage in my statement.

24        Q.   Did he tell you why Bozovic was going to Erdut?

25        A.   No, no.

Page 13290

 1        Q.   Now at the time this incident happened, what was your

 2     understanding of why Rajo Bozovic was in Vojvodina in the first place?

 3        A.   That's the reason why all of that happened in the first place,

 4     that one of his colleagues had a criminal report filed against him for

 5     attack against an authorised official.

 6        Q.   Sorry, I didn't quite understand that.

 7             Before this incident that you describe in paragraph 66, did

 8     Rajo Bozovic come from Croatia to Vojvodina and then the incident

 9     happened and then he returned to Croatia?  Is that the correct

10     chronology?

11        A.   One man out of the six or seven who were with Rajo Bozovic had

12     been in Srbobran six or seven days prior.  That man was a native of

13     Srbobran.  And when he came there, he found that his mother had a

14     relationship with a certain man.  He beat up that man.  The police wrote

15     up a criminal report against that young man.  The young man complained to

16     Rajo Bozovic.  And after that, they came and did what they did.  And

17     after that, I did my job as I was required, professionally.

18        Q.   Okay.  So if you know, how had Rajo Bozovic come to be in

19     Vojvodina at that time in the first place?  In other words, why was he

20     there on the day of that incident?

21        A.   He had come intending to create an incident, to have a settlement

22     of accounts with an operative policeman who had only done his job.

23             JUDGE ORIE:  Let's --

24             THE WITNESS: [Interpretation] There is --

25             JUDGE ORIE:  Mr. Bozovic is around with a group.  Now, that group

Page 13291

 1     was, at least that is what Mr. Farr thinks, was not formed to deal with

 2     all these matters.

 3             Why was Mr. Bozovic in the area at all with a group?

 4             THE WITNESS: [Interpretation] He had not been in Srbobran in the

 5     days before.  He just arrived in Srbobran that day.

 6             JUDGE ORIE:  Where had he been the days before?

 7             THE WITNESS: [Interpretation] I don't know, really don't know.

 8             JUDGE ORIE:  Why was he with a group arriving in Srbobran?

 9             THE WITNESS: [Interpretation] To settle accounts with an

10     operative who had filed a criminal complaint against a member of his

11     group.

12             JUDGE ORIE:  Okay.  That was a criminal complaint on the basis of

13     the incident where one of the members of the group had attacked the man

14     who had a relationship with his mother; is that correct?

15             THE WITNESS: [Interpretation] Yes.

16             JUDGE ORIE:  Okay.  That had happened how much time before he

17     came to settle the account?

18             THE WITNESS: [Interpretation] Two or three days before.  Perhaps

19     a day before.

20             JUDGE ORIE:  Now, why was Mr. Bozovic in the area with a group of

21     men at the moment when one of the members of that group attacked a man

22     who he thought had a relationship with his mother?  Why was he there

23     three days before?  Why was Mr. Bozovic around with the group?  Because

24     you don't need a group nor a leader to -- to attack someone who has a

25     relationship with your mother.

Page 13292

 1             Why was he there?

 2             THE WITNESS: [Interpretation] Your Honours, there's obviously a

 3     misunderstanding.

 4             The incident created by one individual from his group was a

 5     native of Srbobran.  He was staying with his mother in his own house.

 6     The mother had personal reasons to see that man.  Her son, who was in

 7     Rajo's group, objected to that and beat up that man.  The man complained

 8     to the police.  The police did their job and took into custody the son.

 9             JUDGE ORIE:  What was the purpose of the existence of the group?

10     That man was a member of, as you said, Rajo's group.  What was that group

11     doing?  What was the activity of that group?

12             I think, Mr. Farr, that that's what you'd like to know.

13             THE WITNESS: [Interpretation] That was the first time I had any

14     contact with that group.  I really don't know where he had come from or

15     who he was.  I was just told that there was an armed group who had barged

16     into the police station and attacked an operative policeman.  I took my

17     men to Srbobran and did my job, as I described.

18             JUDGE ORIE:  If I understand you well, you only have knowledge

19     about what followed on from the attack on this man having a relationship

20     with one of the group member's mother and that you have no knowledge

21     whatsoever about the armed group led by Mr. Bozovic, their activities,

22     whereabouts.

23             Mr. Farr.

24             THE WITNESS: [Interpretation] I really don't know that.  I was

25     given a specific task which I carried out, and I recorded everything,

Page 13293

 1     including the criminal report that I filed.

 2             JUDGE ORIE:  You've answered the question.

 3             Mr. Farr.

 4             MR. FARR:  Thank you.  Thank you.

 5        Q.   Are you aware that Rajo Bozovic was at the Kula awards ceremony

 6     in 1997?

 7        A.   I saw that.

 8        Q.   Did you see him shake hands with Slobodan Milosevic?

 9        A.   No, I didn't see that.

10        Q.   Then I take it you didn't hear Milosevic tell Bozovic that he had

11     read Bozovic's reports.

12        A.   Only in a video-clip.  I wasn't there, so obviously I couldn't

13     hear that.

14        Q.   In preparation for your testimony, did you just read the

15     transcripts of the video or did you actually look at the video itself?

16        A.   Both.  I read the transcripts and I watched the clips.

17             MR. FARR:  Your Honours, I'd now like to play a portion of P61

18     which is the video of the Kula reach.  This is going to be the portion

19     from 13 minutes and 4 seconds to 13 minutes and 42 seconds.

20        Q.   Sir --

21             MR. FARR:  And we won't start just yet.

22             JUDGE ORIE:  Transcripts have been provided to the booth?

23             MR. FARR:  We'll doing it without sound, Your Honour.  It's

24     just --

25             JUDGE ORIE:  Without -- just -- so they're without sound.

Page 13294

 1             MR. FARR:  Yes.

 2        Q.   And, sir --

 3             JUDGE ORIE:  And, at the same time, does that mean that the

 4     witness doesn't hear anything, or should he take his earphones off?

 5             MR. FARR:  He should take his earphones off, Your Honour.

 6             JUDGE ORIE:  Yes.  Could you please take your earphones off and

 7     only look at the screen, what you see there.

 8             MR. FARR:  I apologise, but there is one instruction I'd like to

 9     give him before he takes his earphones off, so ...

10             JUDGE ORIE:  Please to so.

11             MR. FARR:

12        Q.   Sir, what I'm going to ask you to do is watch this video.  The

13     video shows people listening to Frenki's speech.  And I want you to try

14     to see whether you see yourself in this video.  If you do, please note

15     the time code which will be at the bottom of the screen, and then when

16     the clip finishes playing, you can tell us whether you saw yourself and,

17     if so, at which time code.

18             Is that all right?

19        A.   Yes, that is all right.

20        Q.   All right.

21             MR. FARR:  So then, Mr. Laugel, could you please begin.

22                           [Video-clip played]

23             MR. FARR:

24        Q.   Sir, did you see yourself in that video-clip?

25        A.   No, no.  I wasn't present when Franko was speaking there.  There

Page 13295

 1     were several places where decorations were awarded.  I was not in this

 2     particular place that you showed me.

 3        Q.   Okay.  Thank you for that clarification.

 4             All right.  At paragraph 60 of your statement, you say that Arkan

 5     and Goran Hadzic had a close and friendly relationship.

 6             Can you describe this relationship in more detail, if you're able

 7     to?

 8        A.   While I was billeted in Erdut, Goran Hadzic, every time when he

 9     came to the centre, he would go to the upper floor where Arkan was and he

10     spent time with him.  He would not spend a lot of time with us.

11        Q.   So how often would Goran Hadzic and Arkan see each other during

12     the time you were at the Erdut centre?

13        A.   Again, I could say two to three times a week.  But let's say it

14     was two times a week, on average.  I'm talking about the centre itself.

15     I don't know if they met anywhere else.

16        Q.   All right.  That was going to be my next question.

17             You also said that Arkan provided security for Hadzic.  Can you

18     tell us about this?  Was Arkan personally involved in Hadzic's security?

19     Did he assign his men to secure Hadzic?  Did both of those things happen?

20     What was that arrangement?

21        A.   He had men as part of Goran's security detail.  People who served

22     as Goran's body-guard were supplied with weapons.

23        Q.   Did Arkan ever personally serve as Hadzic's body-guard, as far as

24     you know?

25        A.   As far as I know, he didn't.  Knowing Arkan and his mentality, it

Page 13296

 1     would have been a sheer humiliation for Arkan.

 2        Q.   And why do you say -- did you say that it would be a humiliation

 3     for Arkan?

 4        A.   Yes.  He had a very high opinion of himself.  At least that's how

 5     I saw Arkan.

 6        Q.   So being a body-guard would be too lowly a position for him.

 7        A.   Of course.

 8        Q.   Do you agree with me that the fact that Arkan provided Hadzic's

 9     security people shows that there was a significant amount of trust

10     between Hadzic and Arkan?

11        A.   Trust or fear.

12        Q.   I would now like to look at document 1D1630.  This is a document

13     from the Stanisic Defence exhibit list.  I'm not sure whether it needs to

14     be kept under seal if this evidence becomes public later.  This was one

15     of the documents on the chart, so it's one that would be included in that

16     range of reserved MFI numbers.

17             JUDGE ORIE:  Mr. Jordash?

18             MR. JORDASH:  Can I just have a moment, please, while I find it.

19             JUDGE ORIE:  Yes, we'll have a look at it and then we'll put on

20     the record, and let's not forget about it, whether it needs, under all

21     circumstances, to be under seal or whether it could ever become public.

22             Please proceed.

23             MR. FARR:  So in the meantime, if we could have it on e-court,

24     please.

25             And just for the Chamber's reference, this document purports to

Page 13297

 1     be an order signed by Goran Hadzic appointing Arkan as the commander of

 2     the TO training centre at Erdut, not of the TO itself but of the training

 3     centre.

 4        Q.   Sir, I know that the Defence showed you this document during your

 5     proofing and you said that you didn't know that Hadzic had appointed

 6     Arkan to this position.  I'd like to draw your attention to the signature

 7     at the bottom of this document.  Are you able to recognise that

 8     signature?

 9        A.   This is Goran Hadzic's signature.  I came across Goran's

10     signature quite often, and I can claim with 90 per cent certainty that

11     this is also his signature.

12             MR. FARR:  And if we could zoom out and look at the document as a

13     whole again.

14        Q.   Does this document appear to be authentic to you?

15        A.   Yes.  It looks authentic.  It was drafted at the time when we

16     were about to leave the centre.

17        Q.   Am I correct that the number 1/91 at the upper left-hand corner

18     of the document means that this is the first decision rendered by Goran

19     Hadzic after officially becoming president of the government of the AO of

20     SBWS?

21        A.   I suppose so, given the number 1.  It would be only logical to

22     assume that that was the first document he ever issued.

23        Q.   Do you know why appointing Arkan to this position would be so

24     important as to be Hadzic's first decision in this position?

25        A.   In my view, in order to protect himself.  And when I say

Page 13298

 1     "himself," I mean Goran Hadzic.

 2        Q.   All right.

 3             MR. FARR:  Your Honours, I don't know what the best approach with

 4     this document is.  It's within the range of MFI documents that's on the

 5     chart.  I suppose I can say the Prosecution doesn't oppose admission of

 6     it if it's tendered.

 7             JUDGE ORIE:  Yes.  Madam Registrar, could you tell us already

 8     which pre-assigned number this document has received on your list or will

 9     receive on your list?

10             THE REGISTRAR:  This document has pre-assigned number D339,

11     Your Honours.

12             JUDGE ORIE:  It's on the record that D339, a pre-assigned number,

13     meets no objection for admission by the Prosecution.

14             Please proceed.

15             Or perhaps we -- it's easier to just admit it into evidence,

16     unless the Simatovic Defence would have any ... no.

17             Mr. Jordash, therefore, D339 as pre-assigned --

18             MR. BAKRAC: [Interpretation] No objection.

19             JUDGE ORIE:  -- is admitted into evidence.

20             Mr. Farr, please proceed.

21             MR. FARR:

22        Q.   Sir, in reviewing another document that the Defence showed you,

23     you said, quote --

24             MR. FARR:  And for the Chamber's reference, this is page 2 of the

25     chart regarding Exhibit P329.

Page 13299

 1        Q.   You said:  "I do not know that Arkan was taking some people away

 2     and killing them.  I assume it's true since there are a lot of people who

 3     mention that."

 4             I think that's a relatively clear statement, but I just want to

 5     confirm that you don't have any reason to doubt that Arkan killed people

 6     while he was present in Eastern Slavonia, including prisoners?

 7        A.   I heard stories while I was in Erdut.  If I had known it at the

 8     time, rest assured, I would have taken it up with him.

 9        Q.   When did you hear those stories?

10        A.   Subsequently at various celebrations.  It was hearsay.  At the

11     moment when I was there in the area, I didn't know.  Because if I had

12     known, I would have done what was best for the Serbian people.  Rest

13     assured of that.

14        Q.   What did you hear about Arkan killing prisoners at these various

15     celebrations after you left Eastern Slavonia?

16        A.   I've told you.  There were stories about him being very brutal in

17     combat, about taking prisoners.  Those were all stories, rumours.  Nobody

18     ever mentioned any names.  But as those stories circulated, some of them

19     reached me as well.

20             I can't be any more specific.  I knew a lot of people because I

21     had spent nearly six months in the area.  I still had contact with a lot

22     of people from the area.  And the stories still circulate and are being

23     listened to and recorded.

24        Q.   Okay.  In paragraph 62 of your statement, you say that you know,

25     from what Badza told you after meetings, that the TO staff had contact

Page 13300

 1     with Goran Hadzic.  Am I correct that this means that Badza met with

 2     Hadzic?

 3        A.   Yes, yes.  The two of them did meet.

 4        Q.   How often did they meet?

 5        A.   I can't tell you that with any degree of certainty.  In any case,

 6     there were briefings every evening when we reported of what we had done

 7     and what our -- our plan was for the following day.  But Badza often

 8     reported about meeting with Hadzic, and we talked about the setting up of

 9     police stations and the rest of the three or four basic tasks that we had

10     been given before we crossed over.

11        Q.   Okay.  You said Badza often talked about -- often reported about

12     meeting with Hadzic.

13             In those reports, did he tell you what they had discussed, what

14     Badza and Hadzic had discussed?

15        A.   Badza is not a man of many words.  He mostly told us what to do.

16     As to what he did and with whom, he would only tell us, I had a

17     discussion with Goran and we have to do this and that, based on which I

18     concluded that Goran was above Badza or that Goran backed up Badza, in a

19     way.

20        Q.   Okay.

21             MR. FARR:  Could we now please have document 1D253.  And, once

22     again, I don't know whether this would need to be kept confidential if

23     this evidence becomes public.

24             This document purports to be an award from

25     Major-General Andrija Biorcevic of the JNA 12th Corps to Radovan Stojcic,

Page 13301

 1     Badza; Zivko Trajkovic; and Zeljko Raznjatovic, Arkan.  It's dated 23rd

 2     November 1991.

 3             JUDGE ORIE:  Mr. Jordash, would you include this document in your

 4     list on which we expect you to say whether it should be kept

 5     confidential?

 6             MR. JORDASH:  Neither this or the document we looked at before

 7     should be or need to be confidential.

 8             JUDGE ORIE:  If -- therefore, it should not be exempted if the

 9     testimony would ever become public.

10             Please proceed.

11             MR. FARR:

12        Q.   Sir, could you please take a moment to read this brief document

13     and focus in particular on the positions listed for the three men, and

14     just let me know when you've finished reading.

15        A.   Okay.  Go on.

16        Q.   The post that is listed for Badza in this document, that's

17     consistent with your knowledge of the position that Badza actually held

18     at the time you were in Eastern Slavonia; correct?

19        A.   Yes.  That was the post, as far as I know.

20        Q.   And the same is true for Zivko Trajkovic.

21        A.   Yes, yes.

22        Q.   Now, this document seems to indicate that the TO of the SBWS and

23     Arkan fought together with the 12th Corps of the JNA in the fight to

24     liberate Borovo.  Did you ever hear anything about that?

25        A.   I was no longer there at the time.  I have not seen this before.

Page 13302

 1     I don't know what to say.  I've told you what I know.  I've never seen

 2     Zeljko's post spelled out before, so I really don't know what to tell

 3     you.

 4             If you think that there may be something I know, ask me.  I'll be

 5     very sincere and honest and I'll tell you what I know.

 6        Q.   Sure.  This kind of goes back to what you had said a few moments

 7     ago about how you still, even today, have a lot of contacts in this

 8     region.  I realize this is after you left, but did you ever hear anything

 9     about the combat to liberate Borovo that's consistent with this document,

10     which indicates that the 12th Corps of the JNA fought along with the

11     SBWS TO and Arkan?  Have you ever heard anything about that?

12        A.   When I returned from Erdut, I was quite involved with my family.

13     I had other commitments, so I was really not very much interested in all

14     that.

15             JUDGE ORIE:  We're not asking what else you did.  We ask you

16     whether you have any knowledge of combined operational action between the

17     JNA, the TO, and Arkan.

18             Do you have any knowledge about that?  Tell us.  If not, you have

19     no knowledge.

20             THE WITNESS: [Interpretation] We never conducted any such actions

21     while I was there.  I don't know anything about this.

22             JUDGE ORIE:  Please proceed, Mr. Farr.

23             MR. FARR:  Thank you.

24             Could we zoom in on the signature of this document, please.

25        Q.   Sir, do you have any way of recognising the signature or the

Page 13303

 1     stamp on this document?

 2        A.   No, no.  I never received any documents from this gentleman

 3     Biorcevic.

 4        Q.   Do you know whether Andrija Biorcevic was, in fact, the commander

 5     of the JNA 12th Corps during your time in Eastern Slavonia?

 6        A.   I really don't know.

 7             MR. FARR:  Your Honours, I would tender this as a Prosecution

 8     exhibit.

 9             JUDGE ORIE:  Let me see.  This is not on the -- I think we asked

10     the Stanisic Defence whether there was any reason to ... was it on your

11     list?  Was any number pre-assigned?  It was not.  Then it receives a

12     Prosecution exhibit number.

13             Madam Registrar, that would be ...

14             THE REGISTRAR:  That would be Exhibit P3010, Your Honours.

15             JUDGE ORIE:  Any objection against admission?  If not, P3010 is

16     admitted into evidence.

17             MR. FARR:

18        Q.   In paragraph 61 of your statement, you indicated that the members

19     of the TO staff worked and slept in the same building where Arkan was

20     located but in a different section.  I think a moment ago you said

21     something about the second floor.

22             Can you describe where the TO was in that building and where

23     Arkan and his men were in that building.

24        A.   We had one part of the lower floor.  That's where our rooms were.

25     And there was also an office, a corner room served as an office.

Page 13304

 1             Well, Arkan was a bit further away -- actually, his men were a

 2     bit further away, and Arkan himself was on the upper floor above us.

 3        Q.   So Arkan was in the same building as you.  Were his men also in

 4     the same building as you?

 5        A.   Only a few.  The others occupied some other premises.

 6        Q.   But Arkan's Men provided security for the entire building; is

 7     that correct?

 8        A.   Correct.

 9        Q.   Do you agree with me that this indicates that there was at least

10     some degree of trust between Arkan and Badza, the fact that Badza was

11     happy to have this building secured by Arkan's Men?

12        A.   I can say that Badza maybe trusted him; and as for the rest of

13     us, we didn't.  And that's why we wanted to be relocated.

14             Badza always claimed that he could handle the situation and that

15     that was his responsibility.

16        Q.   So while there was tension between part of the TO staff and

17     Arkan, Badza and Arkan, at least, got on better than the rest of you did

18     with Arkan; is that correct?

19        A.   I've already said that's correct.

20        Q.   In paragraph 65 of your statement, and just now, you've indicated

21     that all of you complained to Badza that you weren't happy being in the

22     same place as Arkan.  Why did you think Badza would be able to do

23     something about that situation?

24        A.   He was the commander.  He was the one who had to deal with the

25     problem.  We informed him that there was a problem, and he was the one

Page 13305

 1     who was supposed to tell us what to do, and we would have done it.

 2             However, we insisted that we did not want to be there.  I knew

 3     very little about Arkan, but the group of 16 policemen knew a lot more,

 4     and that's why we insisted, because they knew who he was.

 5        Q.   Is it true that Badza was best placed to deal with Arkan not just

 6     as a commander but also because he had a better relationship with Arkan

 7     than the rest of you did?

 8        A.   Yes, yes.  Very few of us, and only rarely, had anything to do

 9     with him.  And when I say "him," I mean Arkan.

10        Q.   Okay.

11             MR. FARR:  Can we please have D31 on the screen now.  Page 1 in

12     both languages.

13             And could I also ask that this comment chart, which is the

14     witness's comment chart that's been admitted as D336, be handed to the

15     witness so he's able to look at the document and at his comment about it

16     at the same time.

17             And we're interested specifically in the bottom paragraph in the

18     English, which is the second paragraph in the B/C/S.

19             THE WITNESS: [Interpretation] Could you repeat which number is

20     this?

21             MR. FARR:  This is the first document on the chart.

22        Q.   And since you've looked at this document before, I'll just quote

23     from it.

24             It says that Arkan stated that:

25             "Weaponry, ammunition, and MES," which stands for mines and

Page 13306

 1     explosives, "had been supplied by the MUP and the Ministry of Defence of

 2     the Republic of Serbia and that he had been distributing them to the TO

 3     staffs in Erdut, Sarvas, and Borovo Selo ..."

 4             Your comment was that:

 5             "This was impossible because the MUP did not have the mentioned

 6     supplies in its warehouse."

 7             You went on to say that the MUP had only "pistols,

 8     automatic/semi-automatic rifles, and rifles."

 9             Now I take it you'll agree with me that pistols, automatic

10     rifles, semi-automatic rifles are all weapons; correct?

11             My point is that you intended to refer only to the last item, the

12     mines and explosives, when you said that the MUP did not have those

13     items.

14        A.   Yes, we did not have mines and explosives in our police force.

15     The police only had automatic/semi-automatic rifles and pistols.  That's

16     the weapons our police still has.  I know, as a member of the staff, that

17     in order to equip and train this one unit, we had asked Badza to let us

18     have this equipment but we were not able to get equipment, weapons, or

19     uniforms.  Anything.  While I was there, not a single rifle, not a single

20     uniform, was delivered to that staff.  I mean the staff where I was.

21        Q.   [Previous translation continues] ...

22        A.   Zeljko Raznjatovic I exclude from this, because I was in conflict

23     with him.

24        Q.   Okay.  I just wanted to clarify that your comment, where you say

25     "this cannot be true because the MUP didn't have the mentioned supplies,"

Page 13307

 1     you were referring only to mines and explosives; is that correct?

 2        A.   You're right.  But I suppose that Badza would have found it

 3     easier to get this than Arkan.

 4        Q.   Okay.

 5             MR. FARR:  Can we now have, please, P334 on the screen, page 1 in

 6     both languages.

 7        Q.   And, sir, for your reference, this is the second document that

 8     you commented on in your chart.

 9             MR. FARR:  And here we're interested in numbered paragraph 1 in

10     both languages.

11        Q.   Now, this document describes several incidents in which Arkan

12     killed prisoners.  As I read it, it describes four incidents.  In the

13     first two, they were both taken from the Dalj Police Station.  And one

14     group of those was killed at the Danube; one group was killed at the

15     Dalj Police Station.  And then it describes two other killing incidents

16     in which the location is not specified.

17             Your comment on this document was:

18             "This also relates to the fact that Arkan was in Erdut and to the

19     allegation that he was taking away and killing detainees.  That could not

20     happen while I was in the centre because there were too many people at

21     the centre and there were no shootings at the centre."

22             Sir, I just want to confirm that your evidence is that all you

23     can say with certainty is that Arkan didn't kill people at the Erdut

24     centre during the period you were there.

25        A.   The centre of Erdut is a very small area.  Every time, I would

Page 13308

 1     sound the alert and we would go out.  If I had known that Arkan was doing

 2     this, I would have reacted.  At the centre I was, nobody did anything.

 3             JUDGE ORIE:  That wasn't the question.

 4             You said it could not have happened because I would have known.

 5             Now, paragraph 1, at least, describes what happened in Dalj,

 6     where people were detained and killed.  Your comment focuses on what

 7     could have happened, according to your knowledge, in the Erdut centre.

 8     Whereas what is described here did not happen in the Erdut centre.

 9             That is what Mr. Farr is interested to know, that your comment is

10     not relevant for the events described, because your explanation and your

11     comment is about what you should have been aware of if it would have

12     happened in the camp, but what is described did not happen in the camp;

13     and, therefore, the two do not match.

14             Would you agree with that?

15             THE WITNESS: [Interpretation] I agree --

16             JUDGE ORIE: [Previous translation continues] ... okay --

17             THE WITNESS: [Interpretation] I was not aware of that information

18     about Zeljko doing something.

19             JUDGE ORIE:  Please proceed, Mr. Farr.

20             MR. FARR:  Thank you, Your Honour.

21             Can we now have P1078 on the screen, the top half of page 2 in

22     B/C/S and the bottom of page 3 in English.

23             THE WITNESS: [Interpretation] It's not really legible.  It's very

24     hard to make out.  But I think I've read this document before.  In fact,

25     I read it a couple of days ago.  And it relates to what

Page 13309

 1     Zeljko Raznjatovic brought to the centre or had received from someone.  I

 2     can't make out this text.

 3             MR. FARR:

 4        Q.   Sir, I'm not sure we're on the right page, and maybe -- maybe we

 5     don't even need to look at the document.  I can just quote it to you.

 6             The document catalogues some of the weapons that Arkan and his

 7     men had.

 8             It says:

 9             "In addition to automatic rifles the, the detachment has two

10     tanks, two triple-barrelled 20-millimetre anti-aircraft guns, Zoljas, and

11     sniper rifles with night sights and silencers."

12             Your comment on this was - and, again, this is it page 1 of the

13     chart:

14             "It is true, aside from the allegation that the MUP was providing

15     weapons, because we did not have lorries or the mentioned weapons."

16             The only point I want to make is that your comment should be

17     limited to weapons other than automatic rifles because, as you've just

18     confirmed, the MUP did have automatic rifles.  Is that correct?

19        A.   I did not say that he guarded the MUP.  That's certainly not my

20     evidence.  The MUP did not have lorries or cannons or jeeps or planes.

21     It might be a mistake here.  But if it is, I correct it now, and I'm

22     saying, none of this correct [as interpreted].  The MUP did not provide

23     whatsoever to Zeljko.  If it had been up to me, I wouldn't have given him

24     bread.

25             MR. FARR:  I apologise, it should actually be the bottom of

Page 13310

 1     page 2 in English.  That's my fault.

 2        Q.   Sir, the point was different.  It -- it concerns just your

 3     comment on this document.  And your comment was the MUP does not have the

 4     kind of weapons listed.  One of the kinds of weapons listed is automatic

 5     rifles, which you have said that the MUP does have.

 6             My question is:  Is your comment, therefore, limited?  What you

 7     intended to say was that the MUP could not have supplied tanks,

 8     anti-aircraft guns, Zoljas, and sniper rifles.  Is that correct?

 9        A.   I can give only what I have.  I can't give what I don't have.

10     The MUP did not have that among its assets.

11        Q.   Right.  Whereas the MUP did have automatic rifle among its

12     assets; is that correct?

13        A.   Yes.  Yes, I emphasised several times and enumerated what kind of

14     weapons we have, today.

15        Q.   Sir, thank you very much for your patience with my questions

16     today.

17             MR. FARR:  Your Honour, I've finished.  Thank you.

18             JUDGE ORIE:  Thank you, Mr. Farr.

19             I suggest to the parties that we continue tomorrow.

20             Witness DST-074, we'll continue tomorrow, when you'll be

21     re-examined and perhaps further cross-examined.

22             Mr. Jordash, could you give us any indication as how much time

23     you would need for re-examination?

24             MR. JORDASH:  Thirty minutes, please.

25             JUDGE ORIE:  Thirty minutes.

Page 13311

 1             Mr. Bakrac.

 2             MR. BAKRAC: [Interpretation] Your Honours, for the time being I

 3     have only one question or, rather, one topic I want to clarify.

 4             JUDGE ORIE:  Then I expect that we could conclude the evidence of

 5     this evidence, because I still have to consult with my colleagues,

 6     somewhere during the first session.  Yes.

 7             Witness DST-074, we'll continue tomorrow, 9.00, in this same

 8     Courtroom II.  I again instruct you that you should not speak or

 9     communicate in any other way with anyone about your testimony, whether

10     that's testimony given yesterday and today or testimony still to be given

11     tomorrow.  And we expect that it will not take much more than one hour

12     tomorrow morning.

13             Could you please follow the usher before we adjourn.

14             THE WITNESS: [Interpretation] All right.

15                           [The witness stands down]

16             JUDGE ORIE:  We move into open session.

17                           [Open session]

18             THE REGISTRAR:  We are in open session, Your Honours.

19             JUDGE ORIE:  Thank you, Madam Registrar.

20             We'll adjourn for the day.  And we'll resume tomorrow, Thursday,

21     the 18th of August, 9.00 in the morning in this same Courtroom II.

22             We stand adjourned.

23                            --- Whereupon the hearing adjourned at 1.47 p.m.,

24                           to be reconvened on Thursday, the 18th day of

25                           August, 2011, at 9.00 a.m.