Tribunal Criminal Tribunal for the Former Yugoslavia

Page 16297

 1                           Tuesday, 24 January 2012

 2                           [Open session]

 3                           [The accused entered court]

 4                           --- Upon commencing at 9.06 a.m.

 5             JUDGE ORIE:  Good morning to everyone.

 6             I was informed there are a few preliminaries to deal with.  I

 7     have a few as well.

 8             The first one, however, would be that the Chamber would

 9     appreciate if the -- yes, I first -- could I invite Madam Registrar to

10     called the case.

11             THE REGISTRAR:  Good morning, Your Honours.

12             This is case IT-03-69-T, the Prosecutor versus Jovica Stanisic

13     and Franko Simatovic.

14             JUDGE ORIE:  Thank you, Madam Registrar.

15             The first one would be that if the Defence would start

16     distributing the materials at such a time in the morning that the Chamber

17     doesn't have to wait until it is done, that would be appreciated.

18     Because we can't start without an usher, and if the usher is running

19     around even after 9.00 to distribute materials, then that should have

20     started earlier.

21             Then the first issue.

22             Mr. Jordash, on the 19th of January, you have requested that

23     parts of your cross-examination of Witness Jovan Dimitrijevic on

24     18th of January would be made public, that was the parts that were in

25     private session.  You're hereby invited to give precise, from line here


Page 16298

 1     to line there, so that the Registry is better able to prepare for it once

 2     we've given an order, and for the Chamber to verify.

 3             MR. JORDASH:  Your Honour, yes.

 4             JUDGE ORIE:  Yes.

 5             Then we -- yes, and once you've done that, Mr. Jordash, of course

 6     the other parties are invited to review the references, the exact

 7     references, to the transcript so as to inform the Chamber whether they

 8     have any objection against those portions to become public.

 9             Then for the next item we move into private session.

10                           [Private session]

11   (redacted)

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Page 16299











11 Pages 16299-16307 redacted. Private session.
















Page 16308

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17   (redacted)

18                           [Open session]

19             THE REGISTRAR:  We're in open session, Your Honour.

20             JUDGE ORIE:  Thank you, Madam Registrar.

21             Before I give you an opportunity, Ms. Marcus, to address the

22     Chamber, I would like to put on the record a matter which was dealt with

23     in private session which could have been dealt with in open session.

24     That is, that the Stanisic Defence has informed the Chamber that it will

25     not call Witness DST-081.


Page 16309

 1             Ms. Marcus, please proceed.

 2             MS. MARCUS:  Thank you, Your Honour.  The Prosecution would like

 3     to note that we are still not in receipt of the Simatovic proposed

 4     military expert report in English.  We are increasingly concerned about

 5     the delays in receipt of this report, in particular in light of the

 6     length.  We'd like to emphasise that the report, when provided, should

 7     include the -- in the footnotes the references to exhibit numbers, 65 ter

 8     numbers, or other reference information so as not to delay the process of

 9     reviewing this report even further.

10             And the last issue I'd like to raise, Your Honour, is that we

11     appreciate the agreement with Simatovic Defence to provide us with the

12     documents for upcoming witnesses seven days in advance.  I'd just like it

13     to be clear that the seven day in advance is for English translations.

14     For us to receive the B/C/S documents seven days in advance and the

15     English translations 24 hours in advance is basically the same thing as

16     providing the documents at the last minute.  We had a great deal of

17     difficulty, I think, with the past two witnesses with respect to

18     translations, and we would request that that agreement apply to the

19     English translations, please.

20             Thank you.

21             JUDGE ORIE:  Any need to comment?

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

23             With regard to the first issue raised by my learned colleague, we

24     still have not yet received the translation of the expert report.  We

25     were promised to receive the report by the middle of this month.  I

Page 16310

 1     informed you of the fact we haven't yet received it.  The -- and as soon

 2     as it is available, we will provide the report.

 3             As far as the footnotes are concerned, that should accompany the

 4     report.  We are working hard to identify the documents, and we will

 5     inform the Prosecution of the results.  We are trying to tie up all the

 6     documents in the file to include them in the expert report, and this will

 7     facilitate the work for all the parties, including the Prosecution, in

 8     the proceedings.

 9             We did the same for the police expert.  We provided our

10     colleagues with the report, with the footnotes, including P, D, and

11     65 ter numbers.  Unfortunately some translations are still missing.  But

12     everything that still concerns that report has been submitted for

13     translation, and we expect these translations to be available very soon,

14     both us and for the Prosecution, of course.

15             As far as the second issue raised by my learned colleague is

16     concerned, the issue that concerns the translation of documents used with

17     witnesses, we are trying to act as diligently as possible with regard to

18     that matter too.  It is to a certain extent outside our control.

19     Unfortunately, when the proofing of the witness has been completed,

20     sometimes it proves to be necessary to produce some additional documents,

21     as a result of which concern problems are created.  But we are really

22     trying to respect the seven-day deadline.  But unfortunately certain

23     things are beyond our control.  It all depends on the capacity of the

24     translation unit.  But I believe that no one puts into dispute our

25     goodwill with regard to this issue.

Page 16311

 1             JUDGE ORIE:  I see there are a lot of good intentions.  Whether

 2     that would do is matters still to be seen.  I don't know whether that

 3     saying also exists in the English language, but in my own language there

 4     is a saying that good intentions pave the way to a place where you would

 5     rather not want to be.  Could you please keep that in mind, that the

 6     result is what counts.  And --

 7             MR. BAKRAC: [Interpretation] The same expression exists in our

 8     language, Your Honour.  But I believe that this will not be the case, as

 9     far as our efforts are concerned.

10             JUDGE ORIE:  [Previous translation continues] ... and I just

11     wanted to point at that good intentions do not always lead to the kind of

12     success we are all aware is needed.

13             Ms. Marcus, I leave it to that for the time being.  Apparently in

14     the many languages similar expressions do exist.

15             Then, if there's no -- Mr. Weber.

16             MR. WEBER:  Good morning, Your Honours.

17             We do have one additional matter that pertains to the next

18     witness, if we may proceed with that right now.

19             JUDGE ORIE:  Yes, please.

20             MR. WEBER:  With respect to the next witness, the

21     Simatovic Defence disclosed a notice to a large quantity of materials

22     this past week, materials that are not on the Defence exhibit list.

23     These materials included an extensive amount of video footage provided on

24     CDs that contain a programme which allows us to view the videos but not

25     process them in our system.  These videos also appear highly edited; at

Page 16312

 1     this time we do not know by whom.  Examples of these edits include the

 2     following:

 3             During a speech by the witness which is uploaded as

 4     65 ter 2D1016.1, and appears to be from the 11th of October, 1995, there

 5     is an edit after the witness states:

 6             "On this day five years ago."

 7             And we do not know what is said after that comment.

 8             Also, the videos include an interview with the witness and he is

 9     asked by an English-speaking reporter:

10             "What do you have to say about the allegations of ethnic

11     cleansing in Sanski Most?"

12             And the answer is cut.

13             The Prosecution finds these edits to be relevant and curious.

14             We would ask that the Simatovic Defence provide us with the

15     complete unedited videos in an acceptable format.  The Prosecution

16     further requests that if the Simatovic Defence is going to use these

17     videos and they're allowed to be added onto their exhibit list in their

18     present form, that they be marked for identification pending the receipt

19     of the unedited videos.

20             Next:  We also received notice of five documents that are to be

21     added.  These are 2D904, 2D905, 2D906, 2D1018, and 2D1019.

22             We received the translations to 2D905 and 906 this morning.

23     Based on the threshold provided and although there is significantly late

24     notice, including late notice of substance related to this witness's

25     testimony in a proofing note yesterday, we do believe that it would be

Page 16313

 1     most efficient to allow the -- the documents to be added to the Defence

 2     exhibit list at this time.  However, the Prosecution does reserve some

 3     issues with respect to the eventual admission of these documents.

 4             There were also photos that were provided to us.  These are

 5     2D1020, 2D1034, which -- it is our understanding that it was provided by

 6     the witness during proofing that past weekend.  There is unknown

 7     information about these photos, although we do recognise the individuals

 8     who are present in the photos.  For the basis of adding the photos to the

 9     Defence exhibit list, the Prosecution does not oppose it; however, we

10     will further discuss some additional information with them.

11             Thank you.

12             JUDGE ORIE:  Thank you, Mr. Weber.

13             Editing the videos, Mr. Bakrac.  Who edited the videos?

14             MR. BAKRAC: [Interpretation] Your Honour, we received these

15     videos from the witness and provided them to the Prosecution in the form

16     that we received them.  As far as I can see - I'm not certain about this,

17     however - the witness said that these videos were made 16 years ago on

18     VHS video tapes.  And they were then transferred to DVDs.  I have nothing

19     against Mr. Weber's suggestion that they should retain MFI numbers and we

20     could later try to obtain the original VHS tapes, if they exist, and we

21     could then provide the Prosecution with these VHS tapes that I assume

22     were used to make the DVDs.

23             JUDGE ORIE:  Yes.  I do not know whether the Prosecution is that

24     much interested in the original VHS if they are edited in the same way as

25     what we find on the DVDs.  If, however, the VHS copies are more extensive

Page 16314

 1     and then reduced when put on a DVD, then I can imagine that you would

 2     like to see the original material.

 3             But an answer to Mr. Weber's question is not there yet: Who

 4     edited it?  And I think if the witness provides them, then the first

 5     question should be to the witness: who edited them; where the original

 6     material is.

 7             And another matter.  When the accused is shown on the video to be

 8     speaking, then, of course, the admissibility of such evidence may relate

 9     to what kind of questions are put to the witness.  If it is just to have

10     in evidence some statements of the accused [sic], then, of course, if we

11     do not know what the source is when the accused cannot be cross-examined

12     on the statements he makes, that is a matter still to be considered

13     perhaps.

14             I also noticed that the amount of video material is considerable.

15     And the Chamber will carefully look at how it is used.  And, Mr. Bakrac,

16     since it is your witness, videos should not play a role in leading the

17     witness; so therefore, you are expected to do the same as we always

18     expect a calling party to do, that is, to first see whether the evidence

19     can be elicited without showing material.  And only if that's not

20     possible or if that does not -- or if that causes the need to further put

21     to the witness some material, then, of course, that can be done.  But

22     please be aware that this kind of material requires a very precise and

23     cautious approach, as far as eliciting evidence from a witness is

24     concerned.  It could not be to ask the witness:  Have you ever seen this

25     video?  Of course he has, because he gave it to you.  And then to say,


Page 16315

 1     "Okay, that's then the evidence," that's perhaps not the way we should

 2     proceed.

 3             Mr. Weber, I added even a few concerns to yours.  Mr. Bakrac

 4     doesn't know who edited the video.

 5             Didn't you ask, Mr. Bakrac?  Didn't you ask the witness where

 6     does it come from, who edited it?

 7             MR. BAKRAC: [Interpretation] Your Honour, the interpretation I am

 8     receiving is changed.  If I have understood the witness correctly, the

 9     video was made by someone -- in fact, could we move into private session,

10     please.

11             JUDGE ORIE:  We move into private session.

12                           [Private session]

13   (redacted)

14   (redacted)

15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

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21   (redacted)

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Page 16316











11 Pages 16316-16317 redacted. Private session.
















Page 16318

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 2   (redacted)

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 5   (redacted)

 6   (redacted)

 7                           [Open session]

 8             THE REGISTRAR:  We're in open session, Your Honour.

 9             JUDGE ORIE:  Thank you, Madam Registrar.

10             MR. BAKRAC: [Interpretation] Your Honour, with your leave, while

11     waiting for the witness, I need to apologise to you because this morning

12     the usher was busy distributing documents.  Yesterday in the course of

13     the proofing of this witness we spoke about certain photographs.  The

14     witness then called home and asked his wife to provide him with an

15     additional three photographs, and our assistant, our case manager, had to

16     upload these photographs, which is why we were late in distributing these

17     transcripts.  I do apologise if the Chamber had to wait as a result of

18     this event.  In future, we will make sure that this does not happen

19     again.

20             JUDGE ORIE:  Thank you, Mr. Bakrac.

21                           [The witness entered court]

22             JUDGE ORIE:  Good morning, Mr. Pelevic, if I'm well informed.

23     Before you give evidence, the Rules of Procedure and Evidence require

24     that you make a solemn declaration that you will speak the truth, the

25     whole truth, and nothing but the truth.


Page 16319

 1             May I invite you to make that solemn declaration.

 2             THE WITNESS: [Interpretation] I solemnly declare that I will

 3     speak the truth, the whole truth, and nothing but the truth.

 4                           WITNESS:  BORISLAV PELEVIC

 5                           [Witness answered through interpreter]

 6             JUDGE ORIE:  Please be seated, Mr. Pelevic.

 7             Mr. Pelevic, you'll first be examined by Mr. Bakrac.  Mr. Bakrac

 8     is counsel for Mr. Simatovic.

 9             Mr. Bakrac, if you're ready, please proceed.

10             MR. BAKRAC: [Interpretation] I am, Your Honour.  Thank you very

11     much.

12                           Examination by Mr. Bakrac:

13        Q.   [Interpretation] Good morning, Mr. Pelevic.

14        A.   Good morning.

15        Q.   Kindly introduce yourself for the record.  What is your name and

16     when and where were you born?

17        A.   My name is Borislav Pelevic.  I was born on the

18     22nd November, 1956, in the village of Bublje municipality, Orahovac, in

19     Kosovo and Metohija in Serbia.

20        Q.   Mr. Pelevic, kindly tell us what is your profession or what is

21     your educational background.

22        A.   I have a Ph.D.

23        Q.   Could you please tell us briefly what is your educational

24     background.

25        A.   I graduated from the school of economics in Pristina.  I obtained

Page 16320

 1     my masters in Pristina.  And I obtained my Ph.D. from the school of sport

 2     and tourism in Novi Sad.

 3        Q.   Mr. Pelevic, we have to make pauses between questions and answers

 4     since we speak the same language.  My question needs to be interpreted

 5     first before you can start giving your answer.  Therefore, I would kindly

 6     ask you to wait a little before you start replying to my questions.

 7        A.   I apologise.

 8             JUDGE ORIE:  Mr. Bakrac, I think that already for the reasons you

 9     indicated, part of the answer is not on the record.

10             You said you obtained your masters in Pristina.  And then you

11     gave additional information.  Could you please repeat that additional

12     information.  I think I heard Novi Sad being mentioned.

13             THE WITNESS: [Interpretation] Yes.  I said that I had obtained my

14     Ph.D. in Novi Sad.

15             JUDGE ORIE: [Previous translation continues] ... I think you also

16     referred to the subjects.

17             THE WITNESS: [Interpretation] I said that I had graduated from

18     the school of sports and tourism.

19             JUDGE ORIE:  Please proceed, Mr. Bakrac.

20             MR. BAKRAC: [Interpretation] Thank you.

21        Q.   Mr. Pelevic, could you please tell us where are you currently

22     employed.

23        A.   Currently I work as am MP in the Assembly of Serbia.

24        Q.   In addition to being an MP, do you have some other duties?  And

25     if that is the case, could you please tell us what duties are those.

Page 16321

 1        A.   Yes.  I teach at the school of sports and health in Belgrade.

 2     Also I'm the president of the kick-box association of Serbia.  I'm also a

 3     vice-president of the world kick-box organisation and the president of

 4     the referee committee of the kick-box organisation.

 5        Q.   You have just told us that you are the president of the referee

 6     committee of the kick-box organisation.  Which organisation is that?

 7        A.   It is the World Kickboxing Federation.

 8        Q.   Mr. Pelevic, please tell us something else.  We will skip some

 9     parts of your educational and profession background, and we'll move

10     straightly on to some very specific subjects.

11             At one point in the 1990s you joined the Serbian Volunteer

12     Guards.  When was that?

13        A.   I joined the Serbian Volunteer Guard on the

14     10th of January, 1992.

15        Q.   Could you please tell us how you joined.  What motivated you?

16     How did you join the Serbian Volunteer Guard?

17        A.   My brother was a volunteer in the JNA before me.  We had agreed

18     as a family that he would be the first one to join as a volunteer, and

19     then when he returned it was my turn.  However, when he returned from the

20     front line, he told me that he was not very satisfied with the

21     organisation of the then-JNA.  He told me that there was a visible lack

22     of discipline there, and he told me that I should join the Serbian

23     Volunteer Guard.  He saw them in action on the front line and he thought

24     that that would be something for me as a former athlete.  That they are

25     the real army.  That's how I decided to volunteer.

Page 16322

 1             I went to the recruiting office of the Serbian Volunteer Guard in

 2     Belgrade, I volunteered, and then two days later I was transported in a

 3     van to Erdut where the headquarters was, as well as the training centre

 4     of the Serbian Volunteer Guard.

 5        Q.   Were you alone in that van or was there anybody else with you?

 6        A.   There was me and two other volunteers.  They were also recruited.

 7        Q.   How were you dressed?  And where did you cross the border from

 8     Serbia to Slavonia?

 9        A.   I wore civilian clothes.  We crossed the border across the bridge

10     near Bogojevo, very close to Erdut.

11        Q.   Were you stopped at the bridge?

12        A.   I remember that there was a soldier, a JNA soldier.  He just

13     saluted the driver, and we crossed without ever being checked.

14        Q.   When you arrived in Erdut, who received you there?  And what

15     happened next?  Could you please tell us.

16        A.   We went through the gate.  A man, a tall man who came across as

17     having authority, waited for us at the entrance into the centre.  And

18     then he first asked me, Are you that master of arts or sciences?  And I

19     said yes.  And then he sent the other two to the barber because they had

20     very long hair.  I did not have to have my hair cut.  I had short hair

21     already.  And he ordered me to share a room with a sergeant from

22     Belgrade.

23        Q.   If I understood you properly, when you volunteered you had a

24     master's degree in economics.

25        A.   Yes.

Page 16323

 1        Q.   Were you employed?  And if that was the case, where?

 2        A.   I was the general manager of the Sportinvest public company based

 3     in Belgrade.  And also I was the president of the kick-box federation of

 4     Serbia.  I apologise, the kick-box federation of Yugoslavia.

 5             JUDGE ORIE: [Previous translation continues] ... I again insist

 6     on making a pause between question and answer.

 7             MR. BAKRAC: [Interpretation]

 8        Q.   Mr. Pelevic, when you arrived in Erdut, did you have to fill out

 9     a form?  And if that was the case, who asked you to do that?

10        A.   Yes, I filled out a form.  There was a clerk there who asked me

11     to it that.  Later on I learned that his name was Jovan Dimitrijevic.

12        Q.   On the day when you arrived in Erdut, were you issued with a

13     uniform?  And if that was the case, what kind of a uniform was that?

14        A.   Yes.  I was issued with a woolen olive-drab uniform that had

15     previously been worn by the soldiers of the JNA.  For the first few days,

16     all of us volunteers were issued with that kind of uniform.  And also

17     those who served a sentence, guard members, also used to wear it.  We

18     called it a partisan uniform, and that's why, when we were mocked, we

19     were also referred to as partisans.

20             MR. BAKRAC: [Interpretation] Your Honour, I would like to say for

21     the benefit of the booths that in the next couple of minutes I'm going to

22     up 2D1017.1 which is a video-clip.

23        Q.   Mr. Pelevic, when you were issued with that so-called partisan

24     uniform, were you also issued with any weapons during those first couple

25     of days?

Page 16324

 1        A.   No.

 2        Q.   What were your initial duties when you first joined the guards,

 3     when you volunteered, and when you arrived in Erdut?

 4        A.   On the following morning, I was ordered to clean the barracks

 5     perimeter from cigarette butts, and that's what I did for the first three

 6     days after my arrival in Erdut.  That's what I did the whole day.

 7        Q.   And then what happened?

 8        A.   I asked my sergeant, who was also my roommate, to arrange a

 9     meeting with my company commander.  My company commander was an officer,

10     and I told him that I had not come to Erdut to clean the perimeter from

11     cigarette butts but to fight for the freedom of my people.  If I was not

12     given a good uniform and good weapons and if I was not sent for training,

13     it was my intention to leave Erdut and to go back to Belgrade.  I told

14     him all that.

15        Q.   What happened next?  Were you issued with weapons?  Were you

16     issued with another type of uniform?

17        A.   He told me that he would have a word with Commander Arkan about

18     that, and that in the course of the day he would keep me posted.  In the

19     course of the day, I was still cleaning.  He approached me and told me

20     that the commander approved my membership, my regular membership in the

21     company, and that he agreed that I should start training.

22        Q.   Were you issued with the weapons and did your uniform change

23     after that?

24        A.   Yes.  I was issued with an olive-drab overall, a pair of boots,

25     and I was also issued with an automatic rifle, M-70.

Page 16325

 1        Q.   You said an olive-drab overall.

 2             I would like to call up a video-clip, and I would invite your


 4             MR. BAKRAC: [Interpretation] Your Honours, we can play this

 5     video-clip without sound.  For everybody's benefit, please pay attention

 6     to the events and the faces.

 7        Q.   And then after the video-clip is played, I will have some

 8     questions for you.

 9             MR. BAKRAC: [Interpretation] I would like called up 2D1017.1.

10     This is from the Prosecutor's disclosure list.

11             MR. WEBER:  If we could just have the full ERN, the VOOO number.

12             MR. BAKRAC: [Interpretation] Yes, Your Honour.  VOOO-2253.

13                           [Video-clip played]

14             MR. BAKRAC: [Interpretation]

15        Q.   Mr. Pelevic, do you recognise -- or, rather, do you know anything

16     about this event depicted in the video-clip?

17        A.   This is General Bratic's burial, who had formally been the

18     commander of the Novi Sad Corps.

19        Q.   Could you please tell us when he was the commander of the

20     Novi Sad Corps, up to then, and who succeeded him?

21        A.   I don't know exactly when he was killed.  I only know that he was

22     killed on the Trpinje road.  I learned that subsequently.  It was all

23     over the media.  But I know that he was succeeded by

24     General Andrija Biorcevic as the commander of the Novi Sad Corps.

25        Q.   Did you recognise Mr. Raznjatovic, did you recognise his uniform,

Page 16326

 1     and did you recognise the person he was standing next to during the

 2     burial?

 3        A.   Yes.  I recognised him wearing the olive-drab overall that all of

 4     us wore.  Absolutely the same kind.

 5             Next to him was the then-president of the Serbian region of

 6     Slavonia, Baranja, and Western Srem, Goran Hadzic.  I recognised a few --

 7     a couple of other highly-ranking officers.  I saw General Blagoje Adzic

 8     standing behind the flag.  He was the deputy chief of the General Staff

 9     at the time.  And the person who spoke was Goran Hadzic.  And the person

10     still on the screen is Lieutenant-General Zivota Panic.  I believe that

11     he was the chief of the General Staff of the Army of Yugoslavia at the

12     time, which means that he occupied the highest ranking position.

13             MR. BAKRAC: [No interpretation]

14             THE INTERPRETER:  Microphone for the counsel, please.

15     Microphone.

16             MR. BAKRAC: [Interpretation] Your Honours, I would like to tender

17     2D1017.1 into evidence.

18             JUDGE ORIE:  Mr. Weber.

19             MR. WEBER:  No objection if it's admitted with the transcript

20     provided, since the transcript does provide some additional information

21     as to where this funeral occurred, things like that, which I imagine is

22     not in dispute if it's being tendered.

23             JUDGE ORIE:  Yes, but it's played without audio, so therefore it

24     might be a bit difficult to introduce something into evidence the Chamber

25     hasn't seen.

Page 16327

 1             Unless the parties would agree that the comment provides the

 2     additional information as to location and time, we would then

 3     consider ...

 4                           [Trial Chamber and Registrar confer]

 5             JUDGE ORIE:  I do understand that the Registry is not provided

 6     with the videos, so therefore it's difficult to have it in the e-court

 7     system if it's only on a -- played from a DVD, or I don't know how it

 8     works, but ...

 9             We reserve a number for this clip, and then during the break,

10     Mr. Bakrac, you may explain to Madam Registrar what it is.  Meanwhile,

11     the parties are invited to see whether they can agree on either a

12     transcript -- or if you agree on when this took place and where it took

13     place, then, of course, that agreement could be put on the record.

14             MR. BAKRAC: [Interpretation] Your Honour, let me explain why we

15     played a clip without the sound.

16             I believe that we follow the common practice.  What I mean with

17     that is that the Trial Chamber tends not to like the commentary provided

18     on those video-clips.

19             JUDGE ORIE:  I'm not blaming you in any way for it.  It doesn't

20     need an explanation.  But Mr. Weber rightly points at the fact that we

21     have no information about time and location.  He suggests one way of

22     introducing that information.  There may be others as well.  I left that

23     to the parties during the break, which we'll take now.

24             And we'll resume at quarter to 11.00.

25                           --- Recess taken at 10.18 a.m.

Page 16328

 1                           --- On resuming at 10.50 a.m.

 2             JUDGE ORIE:  Any report as to the location and time of the last

 3     video we looked at?

 4             MR. WEBER: [Microphone not activated] Your Honour, I'm not sure

 5     my microphone is working.

 6             Your Honour, we're still checking the exact date of the funeral.

 7             JUDGE ORIE:  Thank you.

 8             Please proceed, Mr. Bakrac.

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

10        Q.   Mr. Pelevic, we had a look at the video.  Tell me, after

11     General Bratic was killed, who became the head of the Novi Sad Corps?

12        A.   Andrija Biorcevic, lieutenant-general, became the head of the

13     Novi Sad Corps.

14        Q.   You mentioned olive-green overalls.  And you said the ones that

15     you saw on Arkan, that you saw at the funeral, was the kind that you wore

16     too.  Do you know where these overalls were obtained, and how?

17        A.   At the time, I couldn't know.  I was just a recruit.  But later I

18     found out that we received the first uniforms from the JNA, or the

19     Army of Yugoslavia in fact.

20        Q.   Did you have any information according to which you received

21     other things from the Army of Yugoslavia apart from the uniforms?

22        A.   Yes.  We received weapons and relevant equipment: ammunition,

23     Zoljas, bombs or grenades, and Osas.

24        Q.   When you say "weapons," what do you have in mind?  What kind of

25     weapons did you in fact receive?

Page 16329

 1        A.   When I arrived at the guards, there were various types of weapons

 2     there.  There were automatic rifles, M-70 automatic rifles, and there

 3     were semi-automatic rifles as well.  There were also perhaps four or five

 4     Hecklers, small automatic weapons, Hecklers and Kochs [as interpreted],

 5     that commander Arkan had on him, as well as a few other officers.

 6        Q.   Do you know where Arkan and these officers obtained those

 7     Heckler & Koch weapons?  And what kind of weapons are they, what are they

 8     used for?

 9        A.   Since I'm quite familiar with weapons, I found it quite

10     surprising that some officers had automatic Heckler & Koch rifles with

11     them, and naturally I was curious and asked my superiors where they these

12     items were obtained from.  They said they had been seized in an operation

13     in the vicinity of Osijek, I believe.

14             But since you've asked me what the purpose of such weapons is, I

15     would say that these weapons aren't really used on the battle-field.

16     It's more the case that special units in towns used these weapons.  So

17     the war-time weapons that were used the most in this war were automatic

18     and semi-automatic rifles.  Semi-automatic rifles were later excluded

19     when we received other weapons from the JNA, or, rather, from the Army of

20     Yugoslav.

21        Q.   You said that you later tried to obtain information.  When you

22     became close to Mr. Arkan, did you find out how the Serbian Volunteer

23     Guards and how Zeljko Raznjatovic, Arkan, obtained these weapons from the

24     JNA?

25        A.   I found out about this from three sources.  From Commander Arkan,

Page 16330

 1     he was the first source.  He told me that the weapons were obtained from

 2     the Army of Yugoslavia because that was the agreement he had reached with

 3     the minister of defence today, Tomislav Simovic.  The second source was

 4     General Biorcevic.  We became fairly good friends later on, and he

 5     confirmed this.  And Ms. Dobrila Glisic was another source.  She wrote a

 6     book on the events.  She was the chef de cabinet for General Simovic, the

 7     minister of defence.  And it so happens that she's a friend of the

 8     parents of my wife.  The father of my wife was a neurosurgeon at the

 9     military medical academy, and he treated her son.  So she told me about

10     the meeting between the commander, Arkan, and General Tomislav Simovic,

11     the minister of defence of the Federal Republic of Yugoslavia.

12        Q.   Do you know who referred Arkan to General Simovic, the minister

13     of defence of the Republic of Yugoslavia?

14        A.   Yes, I know who referred him.  Radmilo Bogdanovic did, when he

15     was the Ministry of the Interior in the Federal Republic of Yugoslavia.

16     Arkan asked him for his assistance since they knew each other.

17             And Radmilo Bogdanovic was an official in the Crvena Zvijezda

18     football club.  Zeljko Raznjatovic, Arkan, was the leader for the Crvena

19     Zvijezda fans.  On that occasion they had to be in contact.  He told him

20     that some Crvena Zvijezda fans, together with himself, had decided to

21     found the Serbian Volunteer Guards and go to the Slavonia battle-field.

22     And he asked for the assistance in the form of weapons and equipment.

23     Radmilo Bogdanovic said that this was not possible, and he referred him

24     to the minister of defence, Tomislav Simovic.  And this meeting was held

25     and had the results that I have already mentioned.

Page 16331

 1        Q.   When you joined the guards in January 1992 as you said, from that

 2     point in time onwards when you were in Erdut did you receive any weapons,

 3     any additional weapons?  And if so, from whom?

 4        A.   As far as weapons themselves are concerned, large amounts did not

 5     regularly arrive.  The situation was normal.  But if there was a

 6     defective rifle or if a rifle was lost, then we would request that the TO

 7     based in Dalj provide us with weapons.  But two or three times a week we

 8     requested that they provide us with ammunition, because a lot of

 9     ammunition was used for training, when the volunteers, the Serbian

10     Volunteer Guards, were being trained.

11             In one day one combatant would use at least 60 bullets, two

12     clips.  Then we asked the TO, the Territorial Defence, for ammunition.

13     Not just ammunition, but also for Zoljas, hand-held rocket-launchers that

14     could be used once.  We also requested that they provide us with

15     grenades, hand grenades.  So this is the way in which we would obtain

16     ammunition supplies.

17        Q.   You said that you came across automatic and semi-automatic rifles

18     in Erdut.  Were the semi-automatic rifles replaced at some point in time?

19     If so, in what manner and how were they replaced?  Who did this?

20        A.   This occurred after a battle in which the Serbian Volunteer

21     Guards captured six --

22             THE INTERPRETER:  Correction: eight.

23             THE WITNESS:  -- tanks.  Six of the tanks we handed over to the

24     army immediately, and we kept two of them.  The reason for keeping those

25     two tanks is unknown to me since we didn't a tank corps or tank unit in

Page 16332

 1     the guards.  But later I understood that commander Arkan did this quite

 2     skilfully.  He wanted to exchange these two tanks for new automatic

 3     rifles so that the guards would no longer have these other weapons that

 4     weren't as good as automatic rifles.  And this is what happened in

 5     agreement with General Andrija Biorcevic and his Chief of Staff,

 6     Bore Jovancevic [phoen].  An agreement was reached according to which a

 7     large amount of automatic rifles and accompanying equipment would be

 8     provided for those two tanks.  So we gave them the PUP semi-automatic

 9     rifles, and in return we received "papovke" automatic rifles.  There were

10     no other significant changes from that point in time onwards when it

11     comes to the weapons that the guards had at their disposal.

12        Q.   Mr. Pelevic, when you mention the names of certain items, could

13     you please slow down a bit so that the interpretation booths can

14     translate what you are saying.

15             When these captured tanks were exchanged for those weapons, tell

16     me, were you already in the guards at the time or did this take place

17     prior to that?

18        A.   No, that happened before I joined the guards.  But I heard this

19     from my colleagues, other volunteers.  And later, Commander Arkan told me

20     about this, as well as General Andrija Biorcevic, about some interesting

21     situations that concerned that exchange.  So they were very happy to go

22     over that subject matter.

23        Q.   When you joined the guards -- in fact, first - I do apologise -

24     tell me, Do you know whether there was another way in which Arkan

25     obtained uniforms for his troops; and, if so, could you briefly tell us

Page 16333

 1     how he obtained them and where he obtained them from?

 2        A.   Yes.  Commander Arkan always wanted his guards to be the best

 3     equipped guards.  He wanted their units to be -- their uniforms to be

 4     better than the uniforms of those of everyone else in the battle-field.

 5     Part of the uniforms, part of the camouflage uniforms, were received from

 6     someone who donated them in Canada.  But the quantity wasn't sufficient

 7     for all the guards, so one overall was taken to Novi Sad, to

 8     Stankamenac [phoen], a man called Stankamenac, and he used that uniform

 9     to make a certain number of camouflage uniforms.  I know that some of

10     those uniforms were also sewn in the Yumco factory in Kosovo and

11     Metohija.  I think it was in Kosovo Polje, but I'm not sure about that.

12        Q.   Was there also a shop where it was possible to openly buy certain

13     equipment?  And do you know whether Arkan went there to obtain certain

14     supplies as well?

15        A.   Yes.  There was such a shop, and I believe that the shop still

16     exists.  The name of the shop is Magnum, or perhaps it's called Army Shop

17     today.  You can buy equipment and uniforms, but now weapons.  You can buy

18     hunting knives, but not other weapons.  I know that Commander Arkan

19     bought just for the officers some very nice uniforms in that shop in

20     Belgrade.  He bought some knives and officer boots, so that the officers

21     looked quite different from the ordinary soldiers, from us who were the

22     volunteers.

23        Q.   Did you have any other additional equipment obtained from that

24     private shop?

25        A.   I can't remember.

Page 16334

 1        Q.   Mr. Pelevic, tell me -- or, rather, you described the first three

 2     days for us, and then you said that you were issued with a different type

 3     of uniform, which was a green overall, and that you were issued with an

 4     M-70 automatic rifle.

 5             What happened next?  What did you do at the beginning of 1992 at

 6     the Erdut centre?

 7        A.   As soon as I became a regular member of my unit, I started

 8     training, which lasted three months.  Before completing their training,

 9     no volunteer could be sent to a front line or on a mission.  My

10     lieutenant noticed that I was in good shape.  I was a karate master and I

11     had trained other martial arts.  Fifteen days into my stay, he asked me

12     to be his assistant when it came to the physical training of not just the

13     company, but the entire guard.  Some 20 days later, therefore, I started

14     training people.

15             What I was impressed with in the guard was a high level of

16     discipline.  People were not allowed to consume alcohol.  We showed a lot

17     of respect to our superiors and vice versa; they respected us as well.

18     So the entire atmosphere in the guards was really very good.  I found it

19     really very good.

20        Q.   When you started training other people, what was the relationship

21     between Arkan and the commander of the Novi Sad Corps?  Did the latter

22     ever come to the headquarters in Erdut?  Did Arkan or perhaps you as well

23     go to their staff, to the army staff?  And if you did, why did you do so?

24        A.   Yes.  General Biorcevic came several times while I was in Erdut.

25     He paid the centre, the 101st Centre in Erdut a visit.  And whenever he

Page 16335

 1     came, Commander Arkan lined up all of the guards.  General Biorcevic

 2     saluted the volunteers as soon as he arrived in the centre.  And the

 3     first thing he told us was, Comrade, soldiers, I salute you.  That was

 4     the common salute in the former army.  And then we would respond, God be

 5     with you.  That was kind of sweet at first, but then he gave up on

 6     saluting us.

 7        Q.   Mr. Pelevic, did Arkan ever go to the Novi Corps Staff?  If he

 8     did, do you know who he visited and why?

 9        A.   General Biorcevic had some sort of a staff on a boat or on a

10     ship.  I believe that the name of that ship was either Kozara or Sutiska,

11     I'm not sure.  But it was either the name of a mountain or a river from

12     Bosnia-Herzegovina.

13             The commander would go there.  On two occasions, when we became

14     close, I went with him to that staff.  And on one occasion, we also dined

15     with Vladika, of Osijek and Dalj, Lukijan.  Because we as guards repaired

16     his church that the Croatian soldiers or volunteers had partly damaged.

17     The restoration works lasted for about two months, and after their

18     completion Vladika Lukijan invited Commander Arkan, myself,

19     General Biornevic [phoen], and General Boro Ivanovic, the Chief of Staff

20     of the Novi Sad Corps, to lunch.

21        Q.   And how my last question on that topic.

22             From the moment you arrived in Erdut, did you go on any joint

23     missions with the army?  And if that was the case, under whose command

24     did you act?

25        A.   Mr. Bakrac, I don't understand your question.  Are you referring

Page 16336

 1     to the period before the real combat started; or are you referring to

 2     some smaller-sized actions that were carried out?

 3        Q.   When you joined the guards, did you hear that the Serbian

 4     Volunteer Guard carried out some operation in late 1991?

 5        A.   Oh, yes, now I understand your question.  I didn't at first.

 6             The Serbian Volunteer Guard together with the military carried

 7     out actions almost all over Slavonia, Baranja, Western Srem.  I would

 8     like to point out the Operation Luzac, where our guards launched an

 9     infantry attack and they were supported by the Army of Yugoslavia

10     artillery and tanks, since we did not have any tanks.

11        Q.   Who was in command in those actions and operations?  What can you

12     tell us about the command function?

13        A.   We always received our orders from the corps commander of the

14     Army of Yugoslavia.  At first that was General Bratic.  He was succeeded

15     by General Biorcevic.  And their inferiors, colonels, or

16     lieutenant-colonel.  However, no operation would be undertaken without

17     the co-operation of the Army of Yugoslavia.

18        Q.   Mr. Pelevic, that's something that you learned when you arrived

19     there.  From the moment you arrived, did you carry out any actions in

20     1992 together with the Army of Yugoslavia?

21        A.   In 1992, there were just a few smaller-sized operations.  For

22     example, we received information from the army that a ship on its way

23     from Romania was carrying mercenaries for the Croatian army.  We stopped

24     that ship, we established that the allegations were true, and we ordered

25     the captain to go back to Romania.  That was an action that I

Page 16337

 1     participated in.  And there were some other smaller ones, such as

 2     countering their scouts that infiltrated in our territory.  We also sent

 3     our scouts to surveil their territory in depth.  I always participated in

 4     those smaller actions.

 5        Q.   Mr. Pelevic, your centre in Erdut, who did it belong to?  Can

 6     define that for us?  When you arrived, when you saw the situation, did

 7     you learn what the name of the centre was and who that centre belonged

 8     to?

 9        A.   When I arrived, I saw a big billboard at the very entrance into

10     the centre, and the inscription on there was the 101st Training Centre of

11     the Territorial Defence of Slavonia, Baranja, and Western Srem, which

12     means that it belonged to the Territorial Defence and its headquarters

13     was in Dalj, a town very close to Erdut.

14        Q.   Thank you, Mr. Pelevic.  Do you know who the commander of the

15     Territorial Defence was when you arrived, the Territorial Defence of the

16     autonomous region of Slavonia, Baranja, and Western Srem?

17        A.   Yes, I know that.  Because he often came to the training centre.

18     His name was Radovan Stojicic, Badza.  He was the commander of the

19     Territorial Defence.  And by virtue of that position he was our superior

20     commander, because we were a Territorial Defence unit for the region of

21     Slavonia, Baranja, and Western Srem.

22        Q.   Mr. Pelevic, in the former Yugoslavia, the Territorial Defence

23     was under whose jurisdiction?  Not just one Territorial Defence, but all

24     of the Territorial Defence forces, under whose jurisdiction were they?

25        A.   Under the jurisdictions of the military force.

Page 16338

 1        Q.   Mr. Pelevic, the camp in Erdut, did there come a time when things

 2     changed?  I apologise, I'll rephrase my question.

 3             First of all tell me, Do you know and can you define the

 4     relationship between Arkan and Radovan Stojicic, Badza?

 5        A.   I would say that their relationship was not as members of the

 6     military but as friends.  Friends.  Badza often came to our centre and

 7     the two of them forged a very sincere friendship with the common goal to

 8     defend the territory.  Their relationship was fair and friendly, I would

 9     say.

10        Q.   Mr. Pelevic, to your knowledge, did anybody come to the training

11     centre in Erdut while you were there, or before you were there, as a

12     representative of the MUP of Serbia or the state security of Serbia?

13        A.   No.  I'm sure that nobody did.

14             There was quite a great detail of animosity between the guards

15     and the MUP of Serbia and especially between the guards and the state

16     security of Serbia.

17        Q.   Mr. Pelevic, is it true that Radovan Stojicic, Badza, once he

18     stopped being the commander of the Territorial Defence of Slavonia,

19     Baranja, and Western Srem, somewhat later became an assistant minister of

20     the MUP of Serbia and the chief of the public security department?

21        A.   Yes.  It's a notorious fact.  Everybody knows that.

22        Q.   Can you explain the difference for us.  You said that Arkan was

23     close to Radovan Stojicic, Badza, who later became what he did.  And at

24     the same time you're telling me that the Serbian Volunteer Guard, all of

25     its members, and Arkan harboured quite a lot of animosity towards the MUP

Page 16339

 1     and the DB.

 2             How can you explain that?

 3        A.   I can tell you briefly.  That animosity was due to the fact that

 4     we thought that the DB, i.e., the secret police and the police in

 5     general, saw Arkan as a person with a criminal record.  That was our

 6     perception.  And I don't think that our perception was far off.  And it

 7     was sold to the media all the time.  They wanted to undermine

 8     Commander Arkan's credibility and the guards' successes.

 9             But let me explain the nature of the relationship with

10     Radovan Stojicic, Badza.  As I've already told you, that relationship was

11     created on the ground, in Slavonia.  Badza was the commander of the

12     Territorial Defence as well as the commander of the Serbian Volunteer

13     Guard that was part of the Territorial Defence.  So that friendship

14     cannot -- does not -- must not be confused with Arkan's attitude towards

15     the police and the DB.

16             This was a very personal relationship, and that continued to

17     exist all the way up to Badza's death.  I really know a lot about that,

18     and a distinction has to be made.  Badza was an assistant minister of

19     public security, not the secret police, and there's a distinction there.

20        Q.   Mr. Pelevic, you said that you -- you claim that nobody from the

21     MUP and especially not from the DB of Serbia came to our

22     camp [as interpreted].  Did you ever doubt that there was somebody in the

23     Erdut camp who could perhaps leak information to the MUP or the DB of

24     Serbia?

25        A.   All secret services everywhere in the world try to infiltrate


Page 16340

 1     their own people into those spheres of life or those units that they want

 2     to monitor, check, or discredit.  That's why we assumed that out of the

 3     250 to 300 volunteers there must have been a spy or two.  We were really

 4     not that naive not to doubt that.  We had our suspicions about a

 5     volunteer who was a very brave soldier, a very intelligent and

 6     resourceful person; however, he arose our suspicions with his behaviour.

 7     He often made telephone calls, but not from the centre in Erdut but from

 8     the centre of the village.  He often applied for leaves.  And according

 9     to a story, in Belgrade he was once seen in front of the DB building.

10     There was no way for us to confirm our suspicions, and it remains

11     unproven to this day whether he was, indeed, a DB agent or not.

12             However, out of the abundance of caution, he was expelled from

13     the guards.

14             MR. BAKRAC: [Interpretation] Your Honours, with your leave, I

15     would like the Chamber to move into private session.  I would like to ask

16     Mr. Pelevic to try and remember the name of that person that he has just

17     described for us.

18             JUDGE ORIE:  We move into private session.

19                           [Private session]

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 16341











11 Page 16341 redacted. Private session.















Page 16342

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4                           [Open session]

 5             THE REGISTRAR:  We're in open session, Your Honour.

 6             JUDGE ORIE:  Thank you, Madam Registrar.

 7             MR. BAKRAC: [Interpretation] Your Honour, could we see 2D1033 on

 8     the screen.

 9        Q.   And while waiting for that:  Mr. Pelevic, I believe that you

10     brought this photograph with you when you came to The Hague.  Be so kind

11     as to tell me whether you can recognise the place where the photograph

12     was taken.  Can you remember the occasion and the time?  And who are the

13     individuals that we can see in the foreground?

14        A.   Naturally.  The person in the uniform is

15     Commander Zeljko Raznjatovic, Arkan.  To his left, we see

16     Mr. Goran Hadzic, the president of the Autonomous Region of Slavonia,

17     Baranja, and Western Srem at the time.  And to the right, the man in the

18     black is Milan Milanovic, Mrgud, the deputy minister of defence of the

19     Republic of Serbian Krajina, the man in the black suit.

20        Q.   And can you remember when this photograph was taken, and on what

21     occasion, if you know?

22             And I do apologise, we failed to ask you where this photograph

23     was taken.

24        A.   The photograph was taken in the guards centre.  It's the -- the

25     compound itself.  It's the training centre.  And the photograph was taken


Page 16343

 1     on the occasion of the day on which the Serbian Volunteers Guard was

 2     formed, on the 10th of October, 1992.

 3             In the background you can see other individuals who were always

 4     present on that occasion.

 5             MR. BAKRAC: [Interpretation] Your Honour, could this photograph

 6     please be admitted into evidence.

 7             JUDGE ORIE:  Mr. Weber.

 8             MR. WEBER:  No objection.

 9             JUDGE ORIE:  Madam Registrar.

10             THE REGISTRAR:  Document 2D1033 will receive number D651,

11     Your Honours.

12             JUDGE ORIE:  And is admitted into evidence.

13             Please proceed.

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

15        Q.   Mr. Pelevic, concerning this camp in Erdut, what was its

16     capacity?  How many members did you have in the guards?

17        A.   Before we arrived, the camp in Erdut was a recruit centre for the

18     Osijek Military District.  So it had everything that a combat unit

19     needed.  It wasn't very big.  It had a capacity of about 250 beds, but

20     very often there were over 300 guards there, because they would use

21     mattresses or sleeping bags instead of beds.  They had a canteen,

22     training grounds -- it had a canteen and training grounds, good

23     dormitories, there was an office, a big warehouse.  So everything that a

24     large combat unit needed was there.

25        Q.   Mr. Pelevic, did you take over responsibility for training the

Page 16344

 1     recruits at any point in time; and, if so, when did you do so?

 2        A.   Yes.  To a certain extent I did assume responsibility for

 3     recruiting [as interpreted] the recruits, perhaps after two or two and a

 4     half months -- after I had been in the volunteer guards for two and two

 5     and a half months.  I was good at martial arts, I was physically fit, I

 6     knew how to prepare troops, so I assumed responsibility for physical

 7     training, for training in martial arts.  It was necessary to be very fit,

 8     because if a military unit -- if members of a military unit aren't fit,

 9     they can be very good shooters but that will serve no purpose because you

10     need to be fit.

11        Q.   Mr. Pelevic, how long did the recruits' training last?

12        A.   As I have already said, it lasted for three months.  Only after

13     they had been trained for three months was it possible for a volunteer to

14     join the combat group and to participate in the operations.

15        Q.   Were the instructors who trained the recruits just members of the

16     Serbian Volunteer Guards, or did you have instructors who came from the

17     outside too?

18        A.   When Legija arrived in the guards, that was in 1992, in

19     April 1992, he was also appointed as an instructor since he had a lot of

20     military experience.  He had been sergeant in the Foreign Legion for four

21     years, so he had such experience.  We also had a colonel, an army

22     colonel, a colonel from the JNA, and because of his rank we called him

23     Puki, which is the abbreviation for "colonel," or "pukovnik."  I don't

24     know whether he had retired or whether he was an active-duty officer, but

25     I do know that he wore a uniform that was different from the uniforms we

Page 16345

 1     had.  He wore the uniform of the Army of Yugoslavia.

 2        Q.   In order to be quite clear: Was he a member of the Serbian

 3     Volunteer Guards, or did he only appear from the outside in order to

 4     train the recruits?

 5        A.   No.  He lived with us.  He was a member of the guards.  But he

 6     probably kept some of his habits from the Army of Yugoslavia.

 7        Q.   Did you ever receive training of any kind from members of the MUP

 8     of Republika Srbija or from any other MUP or from members of the state

 9     security in the Republic of Serbia?

10        A.   No.  That would have been quite unnatural.  That never occurred.

11        Q.   Why do you say that that would have been abnormal?

12        A.   Well, the police and the stays security, given the nature of

13     their work, are not military units, and they know nothing about warfare.

14     Why should we be trained by them with regard to how to arrest someone or

15     how to spy on someone?  This is the work that is to be done by the DB or

16     the MUP.  We can only have instructors from military units; that's quite

17     natural.  So it wasn't necessary for us to have any such instructors from

18     the DB or the MUP.  And in my opinion they had no such instructors, no

19     such experts.

20        Q.   Mr. Pelevic, throughout the year 1992 did you provide training

21     from [as interpreted] recruits or did you at any point in time leave

22     Erdut; and if you did, when and for what reason?

23        A.   At one point in time, I received an order from Commander Arkan.

24     I was to select four of the best volunteers, soldiers, and to go to Knin,

25     to a place called Kistanje, near Knin, where the Krka monastery had been

Page 16346

 1     located.  It had been built in the thirteenth century by the sister of

 2     the Serbian tsar, Jelena.  This monastery is near the border with

 3     Croatia, and from the surrounding hills the Croatian soldiers would often

 4     fire on the monastery.  Since at the time Vladika Nikolaj was in the

 5     monastery, he had to flee from Sibenik, he asked Milan Martic to provide

 6     security and defend the monastery from attacks.  Milan Martic referred

 7     him to Arkan, since he didn't have enough forces.  That's what he later

 8     told me.  He didn't have enough forces to provide security, and Commander

 9     Arkan sent me and four other soldiers under my command to go and defend

10     the monastery, to arm the monks, to train them, to provide them physical

11     training and training in shooting.  I went there towards the end of

12     March to carry out that task and I stayed there for perhaps 30 days, but

13     not for more than a month.

14        Q.   When you say towards the end of March, for the sake of the

15     transcript, which year are we dealing with?

16        A.   1992.

17        Q.   Mr. Pelevic, did the Serbian Volunteer Guards carry out any

18     operations during the time that you spent in the Krka monastery?

19        A.   Yes.  The Serbian Volunteer Guards at the beginning of

20     April participated in the liberation of Bijeljina and Zvornik.  Those

21     were the two largest operations carried out by the Serbian Volunteer

22     Guards.

23        Q.   As far as I have understood, you weren't present, you didn't

24     participate in those operations.  When you returned in Erdut after

25     30 days, as you say, did you hear anything about the participation of the

Page 16347

 1     volunteer -- of the Serbian Volunteer Guards in the liberation of

 2     Bijeljina and Zvornik?

 3        A.   Naturally I heard certain things from my colleagues and from

 4     officers.  And later, naturally, from Commander Arkan as well.

 5        Q.   Do you know how it is that the Serbian Volunteer Guards and Arkan

 6     went to Bijeljina and later on to Zvornik?

 7        A.   The Serbian Volunteer Guards had been appealed to by

 8     Ms. Biljana Plavsic on behalf of the SDS, and they had been asked to

 9     prevent Muslim extremists who had already compiled a list of prominent

10     Serbs in Bijeljina -- they were asked to prevent these Muslim extremists

11     from assassinating Serbians on this list.  I know about that because I

12     had the document and there was a coded call.  Biljana Plavsic asked the

13     commander to act in such a way to defend these prominent individuals.

14        Q.   In addition to this call that the commander received, did the

15     commander receive a call from some local official of the SDG in

16     Bijeljina; and if so, from whom?

17        A.   Immediately after the call from Biljana Plavsic, there was

18     contact -- contact was established with our people in Bijeljina.  And our

19     member whose nickname is Mauzer told us that it was absolutely necessary

20     for the guards to go and liberate Bijeljina.

21        Q.   After your arrival there, did you find out from Arkan or from

22     someone else, did you find out whether the guards participated in the

23     liberation of Bijeljina on an independent basis, or were they provided

24     with support of some kind?  And if so, with what kind of support?

25        A.   The guards had two forms of support.  They were supported by our

Page 16348

 1     members led by Mauzer.  I can't remember his name right now, but the

 2     nickname, his nickname, is Mauzer.  But the main form of support was in

 3     the form of logistics, and it was provided by the army, an army garrison

 4     in Bijeljina.  Major Gavrilovic commanded that garrison and he later

 5     became the commander of the 2nd Semberija Brigade.  Our volunteers slept

 6     in the barracks and that's where they would also eat for the day or two

 7     that they spent there.  So the army provided us with logistics support,

 8     but the agreement was that the army should provide us with full combat

 9     support as well.  But since we co-operated very successfully with the

10     local patriots and groups, it wasn't necessary for the Army of Yugoslavia

11     to get involved in the conflict.  They remained in the barracks.  So in

12     one day's time Bijeljina was liberated.

13             JUDGE ORIE:  Mr. Weber.

14             MR. WEBER:  Your Honour, if we could please have a little bit

15     more foundation.  It started out with the witness not being present for

16     any of this, then went into that he subsequently heard about things, and

17     now things are coming in to the record in a conclusory fashion as if the

18     witness almost experienced these directly.

19             So if we could have please a little bit more foundation on how he

20     learned this information.

21             JUDGE ORIE:  Mr. Bakrac, it may be -- [Overlapping speakers] ...

22             MR. BAKRAC: [Interpretation] Your Honour, I was just going to ask

23     the witness precisely that.  I was just going to ask him.

24        Q.   Mr. Pelevic, it seems to me that you had a coded letter in your

25     hands.  Could you please provide us with some more details?  Who did you

Page 16349

 1     receive the information from?  Who told you that?

 2        A.   I've already told you that.  My initial office originates from my

 3     colleagues, volunteers, as soon as I returned from the Krka monastery

 4     sometimes toward the end of April.  I had been there with four of the

 5     other volunteers in order to protect the monastery.

 6             Later on, when I became close associate of Commander Arkan, in

 7     that capacity and later on as a politician I met with Biljana Plavsic and

 8     all the other relevant people from the Republika Srpska.  Obviously I

 9     wanted to know how things had happened, and this is what I base my very

10     reliable information on, the -- the one that I share with the

11     Honourable Chamber.

12        Q.   Mr. Pelevic, did Arkan speak openly about all those details?  In

13     the media, for example.

14        A.   Yes, on many occasion, because that was most frequently a

15     journalist's questions during that period.  Later on I became

16     Major Gavrilovic's friend.  Unfortunately, he died a few months ago.

17     However, from various sources I heard what had caused our attack on

18     Bijeljina, how things evolved and what the result was, so I believe that

19     I have all the relevant information about that.

20        Q.   The transport is not -- the transcript is not clear.  It doesn't

21     reflect what you said about Major Gavrilovic.  Could you please repeat.

22        A.   When Major Gavrilovic became the commander of the 2nd Brigade, we

23     met and we became good friends, and it is only logical that I asked him

24     how things happened in Bijeljina, because there were several versions

25     about the events.  And I also spoke on several occasions with Mauzer who

Page 16350

 1     remained living in Bijeljina and established his own guard under the name

 2     of Panthers.  I collected all information from different sources, and I

 3     was able to put together the picture of what had happened in Bijeljina.

 4     It was not difficult at all.

 5        Q.   Mr. Pelevic, now I'm going to show you three photos.  And in the

 6     meantime, I would kindly ask the booths to prepare firstly the transcript

 7     for 2D1008.1.

 8             Before that, I would like to call up 2D1028, which is a photo

 9     that we received from you, Mr. Pelevic -- Mr. Pelevic, I apologise.

10             Let me ask you, Mr. Pelevic, do you know anything about the

11     circumstances under which the Serbian Volunteer Guard and

12     Zeljko Raznjatovic, Arkan, participated in the Zvornik operation in

13     April 1992?

14        A.   Again, I will have to say that I was not there.  I was not one of

15     the participants.  But I have information that came from different

16     sources.

17             During the operation in Bijeljina, the Presidency of

18     Bosnia-Herzegovina sent a delegation to investigate what had happened

19     there.  The delegation consisted of Biljana Plavsic, Fikret Abdic, and

20     General Prascevic on behalf of the military.  According to

21     Biljana Plavsic, according to what she told me later and according what

22     her statements for the media were, the situation in Bijeljina was good.

23     No shop was looted.  Wherever a shop window glass was broken,

24     Commander Arkan posted a guard there to guard such shops.

25             Commander Arkan wanted to proceed and attack Tuzla; however,

Page 16351

 1     Vladika Vasilije Kacevenda talked him out of that.  He was also present

 2     there, as well as Biljana Plavsic.

 3             General Prascevic claimed that the situation in Tuzla was under

 4     control and no attacks could ensue from there from any of the peoples

 5     residing there.  So the idea was given up on, and Biljana Plavsic

 6     insisted on proceeding towards Zvornik, where the Serbs came under the

 7     threat of the Muslim forces that had organised themselves just like they

 8     had done in Bijeljina.  And that's how a decision was made to proceed

 9     towards Zvornik.

10        Q.   Do you know, did you hear from Arkan or anybody else, who

11     participated in the Zvornik operation?

12        A.   In addition to the Serbian Volunteers Guard consisting of some

13     60 volunteers or so - because it would have been impossible for only

14     60 volunteers to take Zvornik, Zvornik is a somewhat larger town - we

15     acted in concert with the Army of Yugoslavia.  And I believe that the

16     main commander was General Sava Jankovic.  I know that for a fact.  I

17     don't know who was the operative in charge of the operation, but I know

18     that the guards enjoyed artillery and infantry support, but the artillery

19     support was decisive in the attack to liberate Zvornik.

20        Q.   Mr. Pelevic, please look at the photo 2D1028 which is before you.

21     Do you know who the photo depicts?  What was the occasion when the photo

22     was taken, and when?

23        A.   The photo was taken in 1995 on the anniversary of the MUP of

24     Serbia on the day of Archangel Mikajla," and the person at the roster is

25     Radovan Karadzic, the then-president of the Republika Srpska.

Page 16352

 1        Q.   Mr. Pelevic, there is an error in the transcript.  What MUP

 2     anniversary?

 3        A.   The MUP of the Republika Srpska, yes.

 4        Q.   And where was that?

 5        A.   It was in Zvornik.

 6             MR. BAKRAC: [Interpretation] And now can we look at another

 7     photo, which is 2D1029.

 8        Q.   Mr. Pelevic, can you tell us when this photo was taken and what

 9     it depicts?

10        A.   The photo was taken in Zvornik on the same day, on the same

11     occasion, in Zvornik.  This is Commander Arkan, and the other person is

12     an official of the MUP.  He was present -- Arkan was presented with a

13     gift.  I don't know who the official was.  But I know that this is a

14     pistol with an engraving, a dedication to Arkan as the liberator of

15     Zvornik.

16        Q.   You said that he received that gift from an official of what

17     institution?

18        A.   The MUP of the Republika Srpska.  It was their anniversary.

19        Q.   Let's look at 2D1026.

20             Could you please identify the event.  Tell us whether the photo

21     depicts the same event.  And can you please identify the four

22     individuals, starting from the right-hand side of the photo towards the

23     left.

24        A.   The first one on the right --

25        Q.   First --

Page 16353

 1        A.   The event is the same, 1995, the anniversary of the MUP of

 2     Republika Srpska.  The first person on the right is the minister of the

 3     police of the Republika Srpska, Mr. Tomislav Kovac.  Second is

 4     Radovan Karadzic, the president of the Republika Srpska.  The

 5     first [as interpreted] individual is Vladika Vasilije Kacevenda.  And the

 6     fourth person is Commander Arkan.

 7        Q.   Thank you.

 8             MR. BAKRAC: [Interpretation] Your Honours, could the three

 9     exhibits, 2D1028, 2D1029, and 2D1026, be tendered into evidence in this

10     case.

11             MR. WEBER:  Your Honour, with respect to the present photo, I see

12     the witness has identified through to Zeljko Raznjatovic but did not --

13     we do not know whether or not he also recognises the other individuals

14     along sitting in that row.

15             JUDGE ORIE:  You could ask him later on.

16             MR. WEBER:  Yes, of course.  With that being said, also we do not

17     how this witness has personal knowledge of this event.  Did he attend, is

18     this something that he saw on TV, or whatnot?  Provided that there's

19     personal knowledge established by this witness, no objection.

20             JUDGE ORIE:  Madam Registrar, the numbers would be ...

21             THE REGISTRAR:  Document 2D1028 will receive number D652.

22             Document 2D1029 will receive number D653.

23             And document 2D1026 whether receive number D654, Your Honours.

24             JUDGE ORIE:  Now, in view to them being very much related,

25     Madam Registrar, is there any specific reason why we would have them

Page 16354

 1     under three numbers rather than as three photographs from the

 2     anniversary?

 3             THE REGISTRAR:  Your Honour, they are uploaded as separated

 4     documents.  I cannot merge them without --

 5             JUDGE ORIE:  Yes.  Whether that's logic or not, I leave that

 6     apart.

 7             But D652 up to and including D654 are admitted into evidence.

 8             MR. BAKRAC: [Interpretation] Your Honours, I apologise, we

 9     received several photos and we made a selection.  We did not want to

10     encumber the file with too many of them.

11             JUDGE ORIE:  Things are as they are.

12             Please proceed.

13             MR. BAKRAC: [Interpretation] Thank you.

14        Q.   Mr. Pelevic, please be so kind and tell us where us got the

15     photos from.  Were you present at the event?  How do you know about the

16     event?

17             JUDGE ORIE:  What we know, until now, is that photographs with a

18     rather clearer explanation on a screen, what it was about, that it was

19     the MUP, the year is there.  The witness wasn't there.  He recognises the

20     persons.  I would have been able to recognise most of them as well, I

21     think, on the basis of the existing evidence.

22             What now is the line of questioning?  What are you going to

23     further establish, I wonder, Mr. Bakrac?  "How do you know about the

24     event?"  Is there is any dispute about the event taking place in view

25     of ... and what is the major relevance to know -- I see -- I take it the

Page 16355

 1     point is that Arkan is seen in the presence of Republika Srpska

 2     officials, Mr. Karadzic.  He even got a present.  That is, I take it, the

 3     purpose of all of this is, to link Mr. Arkan to Republika Srpska, as

 4     often in the Defence strategy it seems that linking Arkan to the JNA,

 5     linking Arkan to the Republika Srpska MUP, is apparently something you

 6     want to establish.

 7             Now, what will -- the questions how the witness is aware of this,

 8     if -- I don't know there's much dispute about it, but I'm really asking

 9     myself where are we going to end, and is it of such importance that we

10     should pay a lot of attention to it.

11             MR. BAKRAC: [Interpretation] Your Honours, Mr. Weber reacted and

12     suggested that we should establish how he knows about the photos is what

13     prompted me.

14             And second of all, we had a protected witness in this courtroom

15     who testified that in 1995 Arkan was not very welcome in the territory of

16     Republika Srpska, that -- that he had been chased away, as it were.

17             Now we are trying to establish what Arkan's relationship was with

18     the Republika Srpska officials, and we're trying to challenge some of the

19     allegations presented by the witnesses in this courtroom.

20             JUDGE ORIE:  I think it's clear.  I think that you can see in the

21     photographs that it was -- apparently this meeting was held in Zvornik,

22     if I'm not mistaken.  And if I remember well, 1995 appears there as the

23     date.

24             MR. WEBER:  Your Honour, we're having a longer discussion than

25     what I intended.  The reason was, the contents of the photos is not why I


Page 16356

 1     said something about the personal knowledge and foundation, it was that

 2     he was offering details beyond what the photos were.  So if it was just a

 3     matter of the content of the photos, as Your Honours have noticed, that

 4     would not been -- that would not have initiated the comment that I made

 5     in terms of the personal knowledge.

 6             JUDGE ORIE:  Okay.

 7             Keep all this in the back of your mind, Mr. Bakrac, and then

 8     please proceed.

 9             MR. BAKRAC: [Interpretation] Thank you, Your Honours.  I'm

10     looking at the clock.  I believe that we are already on the break time,

11     and maybe this would be a convenient moment, because after the break I

12     have some other video-clips to show.

13             JUDGE ORIE:  We are.  And we'll resume at 12.30.

14                           --- Recess taken at 12.02 p.m.

15                           --- On resuming at 12.33 p.m.

16             JUDGE ORIE:  Could we move into private session for a second.

17                           [Private session]

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 16357

 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                           [Open session]

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

17             JUDGE ORIE:  Thank you, Madam Registrar.

18             Mr. Bakrac, I was informed by the Registry that the video,

19     without sound, you wanted to tender still has not been received by the

20     Registry in such a form that it can be processed.  And that's the only

21     reason why I have not yet assigned not even a provisional number to it.

22     You should take care that it is received by the Registrar in such a way

23     that it can be processed in the system.

24             Then, Mr. Bakrac --

25             MR. BAKRAC: [Interpretation] I've understood, Your Honour.  Thank


Page 16358

 1     you.

 2             JUDGE ORIE:  If you are ready, you may proceed.

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

 4        Q.   Mr. Pelevic, we were speaking about a certain subject matter.  I

 5     would now like to conclude.

 6             Tell me, before -- after you returned from Krka, and after the

 7     operations in Bijeljina and Zvornik, did any officials from

 8     Republika Srpska visit your camp in Erdut?

 9        A.   Yes.  In May, I believe, Ms. Biljana Plavsic went to Erdut,

10     together with Princess Linda Karadjordjevic.

11             MR. BAKRAC: [Interpretation] Your Honour, could we now have a

12     look at 2D1020.  Could we have that document up on the screen.  It's a

13     photograph that we received from the witness.

14             Could you please zoom in a little bit.

15        Q.   Going from left to right, could you tell us who is sitting in

16     this room?  And could you tell us when and where this photograph was

17     taken?

18        A.   This photograph was taken a little time after the operation in

19     Bijeljina and Zvornik.  I think it was in May, but I'm not certain.  It

20     was taken in the headquarters of the Serbian Volunteer Guards in Erdut,

21     and it was taken in Commander Arkan's office.

22             I can't recognise the first gentleman to the left.

23     Ms. Biljana Plavsic is sitting next to him.

24     Princess Linda Karadjordjevic, who is the wife of

25     Prince Tomislav Karadjordjevic, is sitting next to Ms. Plavsic.  The

Page 16359

 1     gentleman to her left is someone I can't recognise, and the person in

 2     uniform is Commander Arkan.  The gentleman with the beard, to the extreme

 3     right, is someone I can recognise but I can't remember his name.  I know

 4     it's a politician from Slavonia, Baranja, and Western Srem, but I do not

 5     know exactly what his name is.

 6        Q.   Were you present on the occasion of this visit?

 7        A.   I was the person who took the photograph with the authorisation

 8     of the guards' commander.

 9        Q.   On that occasion were any previous operations were discussed;

10     and, if so, which ones?

11        A.   I don't know.  Because at the time I was just a junior officer

12     and I could not attend the meeting.  And, therefore, I do not know what

13     was discussed at the meeting.

14        Q.   Thank you, Mr. Pelevic.

15             MR. BAKRAC: [Interpretation] Your Honour, could this photograph,

16     2D1020, please be admitted into evidence.

17             MR. WEBER:  No objection.

18             JUDGE ORIE:  Madam Registrar, the number would be ...

19             THE REGISTRAR:  Document 2D1020 will receive number D655,

20     Your Honours.

21             JUDGE ORIE:  And is admitted into evidence.

22             MR. BAKRAC: [Interpretation] May I proceed, Your Honour?

23             JUDGE ORIE:  Please do so.

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

25        Q.   Mr. Pelevic, upon returning from Krajina, from the Krka

Page 16360

 1     monastery, you said you returned to Erdut and that this was towards the

 2     end of April 1992.

 3             Tell us, very briefly, what you continued to do and where you

 4     stayed until the end of 1992.

 5        A.   I continued to train the guards.  On the whole, I was involved in

 6     my own activities.  I was in an office, I had premises there.  In the

 7     meantime, I was conferred the rank officer and I had my own room.  In the

 8     morning I trained the Serbian Volunteer Guards.  I trained them to be

 9     physically fit.  I trained them in the martial arts.  And in the

10     afternoon I trained the troops how to use Zoljas, hand-held

11     rocket-launchers.

12        Q.   Mr. Pelevic, at some point in time did you cease to provide

13     training for the volunteers; and if that was the case, what was the

14     reason?  And when did you cease providing such training?

15        A.   Since I was noticed as an officer by Commander Arkan, in the

16     meantime I was promoted.  And as a co-driver, he wanted me to be with him

17     all the time when he was in the jeep.  He didn't have a driver and he

18     drove himself, so I would sit by his side.  Sometime in November, when we

19     had a brief break and were in Belgrade, he called me to his office, at

20     his exchange office that he in the centre of Belgrade, and he showed me a

21     list with about 20.000 signatures of the citizens of Serbian nationality,

22     citizens from Kosovo and Metohija, and these citizens had asked him to

23     present himself as a candidate, as a national deputy from Kosovo and

24     Metohija.  He asked me what I thought about that.  I tried to dissuade

25     him.  I said it wasn't difficult to be a national representative, a

Page 16361

 1     member of parliament.  I said that it was a far greater honour to be a

 2     commander within the Serbian Volunteer Guards.

 3             Since I didn't have any interest in politics up until then, I

 4     wanted to persuade him not to get involved in politics.  He said that he

 5     had already taken his decision and that he wanted me to be the second

 6     person on his list when presenting himself for that position.  I refused

 7     to comply with the request.  I said I was an economist and that I was not

 8     interested in politics.  He was angry, but he had a -- a special

 9     relationship with me, and he would never raise his voice, nor would he do

10     anything that I would hold against him.  I left.

11             On the following day, the secretary called me, his secretary

12     Snezana Kalinic called me.  She asked for my identity card so that she

13     could register me on the -- in the files of the Serbian Volunteer Guards.

14     I provided my identity card to the courier who came to my house, and

15     15 days later my name appeared in the newspapers in the mid-section and I

16     was the second person on the list of the group of citizens that

17     Zeljko Raznjatovic, Arkan, the group of citizens from Kosovo and

18     Metohija --

19        Q.   I do apologise for interrupting you, Mr. Pelevic.  We have a

20     limited amount of time.  I would like to confine myself to what we are

21     interested in, in the courtroom.  I do have to interrupt you in order to

22     focus on what we are interested in.

23             As far as I have understood, you became a candidate for the group

24     of citizens led by Zeljko Raznjatovic, Arkan, and you were the second

25     person on his list.  What did you do up until that point in time?  How

Page 16362

 1     long did that campaign take?

 2        A.   For the sake of continuity, I will briefly say that I was angry

 3     when I read this in the newspaper, but later he persuaded me that this

 4     was for the best.  I accepted that as a fact.

 5             We started our campaign in the towns of Kosovo and Metohija.  I

 6     was practically in charge of the campaign.  And we did very well in the

 7     elections.  We received a lot of votes and obtained five seats in the

 8     parliament of Serbia.

 9        Q.   Be so kind as to tell me who financed that campaign.

10        A.   It wasn't an expensive campaign, since only a few towns were

11     concerned.  There were meetings that were held in sports halls.  Usually

12     these halls would be provided to us by the directors for free.

13     Zeljko Raznjatovic, Arkan, financed all the expenses incurred by the

14     campaign, but the expenses were not that significant.

15        Q.   I do apologise.  I was waiting for the interpretation to avoid

16     overlapping speakers.

17             When were the elections held?  And out of those -- amongst those

18     five members of parliament, were you one of them?

19        A.   I think the elections were concluded in December 1992.  I became

20     a member of parliament.  Since we had five seats, we could have our own

21     group.  Mr. Raznjatovic was the president of the parliamentary group, and

22     I was his deputy.

23        Q.   Before we move on, Mr. Pelevic, we were speaking about the

24     financing of the campaign.  Could you briefly explain the following for

25     me:  How did the Serbian Volunteer Guards finance itself?

Page 16363

 1        A.   Well, as far as supplies were concerned, we would receive

 2     everything from the TO for free and also from companies in Slavonia,

 3     Baranja, and Western Srem.  There were factories and companies that

 4     provided supplies for us.  But there were also companies, some companies,

 5     from Vojvodina, from Serbia, that were in the vicinity of the border of

 6     Slavonia, Baranja, and Western Srem, so that wasn't a problem.  I've

 7     already told you how we obtained weapons and ammunition.

 8             So these were the financial sources for the Serbian Volunteer

 9     Guard.

10        Q.   Did members of the Serbian Volunteer Guard receive salaries?

11        A.   No, they didn't, with the exception of a few officials who worked

12     in Belgrade, who worked in the recruitment office in Belgrade.

13        Q.   We'll return to that issue later on.

14             So, in December you became a member of parliament in the Assembly

15     of Serbia.

16             MR. BAKRAC: [Interpretation] Your Honour, could we now please see

17     the following video-clip:  2D1001.1.  It's a 65 ter document, V000-0268,

18     it's a Prosecution number.  The Prosecution has already shown a part of

19     the speech given by Mr. Raznjatovic.  The speech lasts five minutes.  I

20     want to see the end of the speech, too, because I have a few questions

21     about that.

22             The Prosecution has already shown this speech about uniting

23     Serbian territories, so I would like to have a look at the entire

24     video-clip, which will take five minutes, and then I will have a few

25     questions for the witness.

Page 16364

 1                           [Video-clip played]

 2             THE INTERPRETER: [Voiceover] "How do Serbs greet each other?

 3     Americans have their American dream, the French have a French dream, the

 4     Italians have an Italian dream.  We, the Serbs, also have the right to

 5     dream.  So do I.  I have my own dream and you have your own Serbian

 6     dream, and that relates to the united Serbian territory.

 7             "You have seen that Germany has united, although it inflicted an

 8     incredible evil of the population of the entire world and on us Serbs in

 9     particular.  They united.  No one objected to that.  So why do they

10     object to us uniting in one -- within one state?  Because we are one

11     people, we speak one language, and we have the right to the united states

12     of Serbia.

13             "I returned from Kosovo this morning.  Last night I was in

14     Djakovica where I had a promotion in front of 1.200 Serbs.  Those were

15     all the Serbs who remained in Djakovica and they gathered in that hall.

16     Half of the hall was crying when I gave my speech because those people

17     down there have no hope.  Albanian mercenaries cross the border there and

18     loot and rape Serbian women, and the police force there is unable to

19     protect them.  So they are seeking the protection of the Serbian

20     volunteers.

21             "In the Serbian Republic of Krajina, you know where Jovanovac is,

22     Ustasha forces are amassing there.  There are Leopard armoured tank

23     units, but they can't cross the border there because of the special

24     police units in Krajina but also because of the Serbian Tigers who won't

25     allow the perpetration of another genocide against the Serbian people.

Page 16365

 1     The children should sleep peacefully.  The working people should continue

 2     to work, because we are watching over them and we will be the first to

 3     intervene and close the gaps should the enemy make a move from any

 4     direction.  We won't allow the Ustasha and fascist monsters to swallow

 5     our children again, to devour our children again.  In Bosnia we prevented

 6     there being a border on the Drina river.  The force of the Jihad had

 7     already occupied Bijeljina.  Everything was already in their hands when

 8     we arrived and got rid of the Jihad.  We are afraid of no one.

 9             "The only thing we fear is a lack of unity among the Serbs.  For

10     this reason, my brothers, I want to appeal to Serbian unity at this

11     honourable and honest gathering.  Let's not tarnish our image.  We don't

12     need that.  We know that among the Serbs there have always been people,

13     but there have been others who didn't deserve such a name.  But we know

14     how to deal with such animals.  That might be harsh on my part.  Perhaps

15     I'm not yet politically correct, and I do apologise, I am not yet a

16     member of the parliament.  But I do have to tell you one thing.  And that

17     is that there can be no mention of trade with Serbian lands or Serbian

18     people.  I'm saying this here and now.

19             "Nobody can play games with the Serbian 'inteligencija,' with

20     Serbian intelligence, no one can offer you thousands of German marks.

21     Where does that money come from?  Let me tell you.  They wish to sell

22     Kosovo.  They wish to sell the Krajinas.  Well, we won't allow it.  We

23     won't give them Krajina or Kosovo.

24             "Kosovo and the Krajinas and all the Serbian lands are sacred,

25     because our churches are located there.  Our homesteads are there, our

Page 16366

 1     graves are there, and we won't give up a single inch of that territory.

 2             "The politicians can remain involved in politics, but they need

 3     to know that we will not be trading with Serbian lands or Serbian people.

 4     The Serbian people will not allow it.  They have to know that.  So I

 5     greet you from this stand, here today, my brothers.

 6             "Thank you very much."

 7             MR. BAKRAC: [Interpretation]

 8        Q.   Mr. Pelevic, this was a somewhat longer clip, but I wanted to

 9     hear the entire speech.

10             We heard Mr. Raznjatovic mentioning a discord among the Serbs.

11     At one point he said they want to sell Serbian Krajinas and the Serbian

12     Kosovo.  Can you tell us, if you know, since you participated in the

13     campaign, who did Zeljko Raznjatovic, Arkan, refer to when he has says --

14     he said "they want to sell the Serbian Krajinas"?

15        A.   It is very clear that he meant the politicians in power, because

16     there was nobody else who was in a position to trade in Serbian Krajinas

17     and Serbian Kosovo and Metohija but the powers that be.  It was a direct

18     attack on Slobodan Milosevic and his policies.

19        Q.   Did the then-official politicians and institution support Arkan's

20     public efforts in the sense of uniting all Serbian lands?

21        A.   No.  The powers that be did not want the unification of all Serb

22     lands.  As Mr. Raznjatovic said, we dreamt about that.  We had the right

23     to dream.  But it was only a dream.  And later on it turned out that he

24     was right when it came to the sale of Krajina, and with that I mean the

25     Eastern Slavonia, Baranja, and Western Srem.  The -- and the -- today's

Page 16367

 1     power is doing the same thing with Kosovo.

 2        Q.   Mr. Pelevic, can you please tell us about the gathering that we

 3     saw.  When did that take place?  Who was present?  Were you there?

 4        A.   That gathering was part of the election campaign.  It was at the

 5     Sava conference hall, possibly November, perhaps December; it doesn't

 6     really matter.  I was there as the only one representing our party, and

 7     both him and I spoke at that rally.

 8        Q.   You said November or December.  What year?  And what was the

 9     official title of that rally?  Were there any other officials there?  Was

10     there anybody there from any of the Serbian Krajinas?  And if that was

11     the case, who were they?

12        A.   I said that it was either in November or December, I'm not sure,

13     but it was 20 years ago, and you really can't expect me to remember

14     everything really precisely.  That was at the Sava centre conference

15     hall.  It was a Serbian rally of sorts.  Officials came from the

16     Republika Srpska, from the republic of --

17             JUDGE ORIE: [Previous translation continues] ... could I stop you

18     there.  The first question was:  "What year?"

19             THE WITNESS: [Interpretation] November or December 1992.

20             JUDGE ORIE:  Thank you.

21             Please proceed.

22             MR. BAKRAC: [Interpretation]

23        Q.   You said that officials came from the Republika Srpska, and you

24     wanted to continue.

25        A.   Yes.  The Republic of Serbian Krajina, Montenegro, and Serbia.

Page 16368

 1        Q.   Can you remember who represented the Republika Srpska, who

 2     represented the Republic of Serbian Krajina, perhaps?

 3        A.   I really can't remember any of the names.

 4        Q.   Thank you, Mr. Pelevic.

 5             When you became an MP, were you in coalition with Milosevic's

 6     party, or were you a member of the opposition?

 7        A.   After Zeljko Raznjatovic's speak [as interpreted] at that Serbian

 8     rally, all we could expect were attacks from the government.  We could

 9     not expect them to invite us to form a coalition.  In the parliament we

10     were opposition to the Socialist Party of Serbia headed by

11     Slobodan Milosevic.

12        Q.   Did you enjoy support from the Republika Srpska and the

13     Republic of Serbian Krajina?  And if there was support, what kind of

14     support was that?

15        A.   This was just a campaign.  We still didn't know whether we would

16     make it to the parliament when we did.  We established very good

17     political connections with the officials of both the Republika Srpska and

18     the Republic of Serbian Krajina.  Not because they respected our

19     political work, we were novices in that, but they respected our fight for

20     the liberation of the Serbian territories in both Republika Srpska and

21     the Republic of Serbian Krajina, and that's what we based our good

22     relationship with the then-politicians of those two regions.

23        Q.   Mr. Pelevic, you started engaging in politics when you became an

24     MP.  Was there another mobilisation drive of the Serbian Volunteer

25     Guards?  And if that was the case, when and where?

Page 16369

 1        A.   The Serbian Volunteer Guards were never disbanded.  However, the

 2     two of us started dedicating our time to political world.  Towards the

 3     end of January, the Croatian forces started attacking Maslenica and

 4     numerous crimes were committed against innocent population.

 5     Unfortunately, this was happening in front of the peacekeeping forces of

 6     the United Nations.

 7             And then we departed for Erdut.  Commander Arkan and myself went

 8     to Erdut.  We put on our uniforms once again and joined the Serbian

 9     Volunteer Guard on a campaign towards the Knin-Krajina.

10        Q.   Mr. Pelevic, when you were supposed to cross the border from

11     Erdut, you said that you joined the guards.  I suppose that you're

12     talking about a large number of people.  How did you organise that?  How

13     did you do that?  How did you go about doing that?

14        A.   From before, there was agreement in place between Commander Arkan

15     and minister of defence of the Army of the Republic of Serbia,

16     Mr. Tomislav Simovic, according to which we were allowed to use military

17     trucks and according to which we would not be crossing the border at the

18     official border crossing, but, rather, that we would use some military

19     routes.  That's how we crossed the border from Slavonia, Baranja, and

20     Western Srem onto the territory of the Republika Srpska and into the

21     Knin-Krajina.  It would have not been possible any other way.

22        Q.   Mr. Pelevic, I would like us to --

23             JUDGE ORIE:  When you said, Mr. Pelevic, "towards the end of

24     January," may I take it that you were referring to January 1993?

25             THE WITNESS: [Interpretation] Yes, Your Honour.

Page 16370

 1             JUDGE ORIE:  Thank you.

 2             Please proceed.

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

 4             I would like to call up 2D1036.

 5        Q.   Mr. Pelevic, while we're waiting for the document, let me tell

 6     you that this seems to be an intercept that the Croatian side intercepted

 7     on the 4th of May, 1995.

 8             You say that with a large number of soldiers you left Erdut to go

 9     to the Knin-Krajina.  I would be interested whether the principle that we

10     see here functioned even before this time.

11             We can look at the document where we can see that around

12     2210 hours Major Vrudin [phoen], commander of the 35th Brigade, who, on

13     the meeting with General Loncar, ordered to Captain Cedo Jovic, chief of

14     the security of the 35th Brigade, to close all the border crossings at

15     the 24 hours on the 4th of May, 2005, between the so-called SRY and the

16     so-called RSK and that he could only allow the passage of one Arkan's

17     unit of an unknown strength which had already been announced to us

18     before.

19             Your Honour, can I see Mr. Weber on his feet.

20             JUDGE ORIE:  Mr. Weber.

21             MR. WEBER:  There's an objection to the characterisation of this

22     document that's been posed to the witness.

23             It's the Prosecutor's understanding that these documents are

24     summaries that were provided by the Croatian government of intercepts

25     that are in their possession, so it doesn't reflect the actual content of

Page 16371

 1     the --

 2             JUDGE ORIE:  Well, we do not know whether it reflects the actual

 3     content.  It is a summary which is either accurate or inaccurate, but it

 4     certainly does not reflect all the words spoken by the interlocutors.

 5             MR. WEBER:  Your Honour, I'm just providing to the Chamber the

 6     information that we have.

 7                           [Defence counsel confer]

 8             MR. BAKRAC: [Interpretation] Your Honour, I just wanted to check

 9     with the witness whether this procedure or a similar procedure was well

10     established when the Serbian Volunteer Guard had to move from Erdut to go

11     to a theatre of war.  2D1035 is proof that the intercept was provided by

12     the Croatian authorities to the OTP pursuant to a Request for Assistance.

13             JUDGE ORIE:  Why not ask a question to the witness, Mr. Bakrac?

14             MR. WEBER:  Your Honours --

15             JUDGE ORIE:  Mr. Weber, whatever -- this apparently is a

16     contemporaneous document provided by the Croatians, at least it's

17     presented as such.  Is there any problem in using it?  Apart from that it

18     is a summary of what apparently was either intercepted -- what was

19     intercepted most likely.

20             MR. WEBER:  Yes, we do object to it.  This is a form of leading.

21     This information as for what Mr. Bakrac has said it was used for could

22     have been lead without even the use of a document.

23             Secondly, Mr. Bakrac said that the Croatian authorities provided

24     the OTP, pursuant to a Request for Assistance, the intercept.  We do not

25     have that.

Page 16372

 1             JUDGE ORIE:  Yes.  Now we have various matters.

 2             First, Mr. Bakrac, Mr. Weber says that you should have tried to

 3     elicit this, the answers from the witness, without first showing him what

 4     was said during this intercept.  And I think that would be in accordance

 5     with -- with the instructions, certainly if it is a witness have you

 6     called yourself.

 7             The other questions, the other issues raised; one is that you did

 8     not adequately present the document, and third, that the Prosecution has

 9     no access to the original transcript.

10             Would that make this document inadmissible under all

11     circumstances?

12             MR. WEBER:  In the context that it's being offered today, we

13     would object.  I mean, that's not to say that further investigations

14     couldn't be done and such information couldn't be admissible in other

15     forms, but the way it's being used today with this witness, yes, we would

16     object.

17             JUDGE ORIE:  Let's first hear the answers of the witness.

18             MR. BAKRAC: [Interpretation] Your Honour, if I may be allowed, I

19     did not even mean to tender it through this witness.  I simply want --

20             JUDGE ORIE: [Previous translation continues] ... earlier I said:

21     "Why not ask a question to the witness."  Let's do that.

22             MR. BAKRAC: [Interpretation]

23        Q.   Witness, sir, before we looked at the document, I asked you how

24     you crossed, and you told us that there was an agreement between Simovic

25     and Arkan about military trucks and so on and so forth.  And you said

Page 16373

 1     that you crossed the border somewhere else and not across the official

 2     crossings.

 3             What I've just read out, does it reflect the way the Serbian

 4     Volunteer Guards crossed the border to go from Erdut to other theatres of

 5     war?

 6        A.   There was an agreement in principle between Arkan and the

 7     minister of defence of Serbia according to which we crossed in this way.

 8     However, the implementation of this agreement was in the hands of the

 9     authorised organs of the Army of Republic of Serbian Krajina and the

10     Army of Yugoslavia.  And this was precisely in order to avoid police

11     checks, because our people could not travel through the Republic of

12     Serbia or they could not cross where there were police checks.  That's

13     why we wanted to avoid police controls.  We used military routes while

14     all the other crossings were closed so that we could pass.

15        Q.   Thank you, Mr. Pelevic.

16             When you arrived in the Knin-Krajina in January 1993, where were

17     you billeted?  Did you participate in any of the operations there?

18        A.   We were billeted in Benkovac, in Aseria [phoen] hotel, which had

19     been completely empty.  There was no food to be had.  We had problem with

20     food -- food supplies.  We participated in some operations around

21     Benkovac, on the Paljuv plateau, where there are several Serbian villages

22     that had been plundered and torched.  Islam Grcki and Islam Latinski and

23     some other villages where the population had suffered terribly, and there

24     is UN documentation to prove that.  Later on there was struggle to

25     liberate Maslenica and the Serbian volunteers actively participated in

Page 16374

 1     that fighting.

 2        Q.   When you say that the Serbian Volunteer Guards actively

 3     participated in those military operations, could you please tell us,

 4     Under whose command did the Serbian volunteers operate at the time?

 5        A.   Since the Serbian Volunteer Guards from the very outset was under

 6     the Territorial Defence of Slavonia, Baranja, and Western Srem, and then

 7     when the Army of the Republic of Serbian Krajina was established, it

 8     became part of that Army of the Republic of Serbian Krajina.  It was only

 9     all normal for them to be under the command of the commander of the

10     Army of the Republic of Serbian Krajina, that was Mile Novakovic, and we

11     did that when we fought in the Knin and Benkovac theatre of war.

12        Q.   You said that from the very outset you were under the command of

13     the TEO [as interpreted] and that later on at the beginning of 1993 you

14     were members of the Army of the Republic of Serbian Krajina.  In the

15     meantime between 1991 and 1993, January 1993, were there any changes with

16     regard to your affiliation?  And if such changes did take place, when was

17     that?

18        A.   Yes.  There was a change in 1992 after the adoption of

19     Cyrus Vance's peace plan according to which both warring parties should

20     be without militaries.  Pursuant to an order that we received from the

21     Army of the Republic of Serbian Krajina, we were transformed into the

22     police of the Republic of Serbian Krajina, and we operated in that way up

23     to the attack on Maslenica in late January 1993.

24        Q.   When we're talking about these operations around Maslenica in

25     January 1993, you said you were under the command of Mile Novakovic.  In

Page 16375

 1     addition to your forces, were there any other forces from the MUP of the

 2     Republic of Serbia or the DB of the Republic of Serbia?

 3        A.   No.  There were only Wolves from Vucjak from the Republika Srpska

 4     under the command of the late Veljko Milankovic and some other units from

 5     the Army of Republika Srpska with us.  But the bulk of the forces were

 6     from the Republic of Serbian Krajina, including the Serbian Volunteer

 7     Guards, as its integral element.

 8        Q.   Were you wounded at that time?  And if that was the case, could

 9     you please describe what happened?  How were you wounded and what

10     happened next.

11        A.   According to a plan that was drafted by the command, the Army of

12     the Republic of Serbian Krajina, the Serbian Volunteer Guards were

13     designated to pave the road across Velebit and come to Srebrenica.  On

14     our flank were several units from the Republika Srpska and the Army of

15     the Republic of Serbian Krajina.  I was the commander of that company

16     that launched a frontal attack.  After two attacks, I was wounded by a --

17     a bullet that was -- that is banned by the Geneva Conventions.  I was

18     wounded in the shoulder.

19             JUDGE ORIE:  Mr. Bakrac, if I could just take you and perhaps the

20     witness back a tinny little bit.

21             You read the content of the summary of the intercept.  You read,

22     at least that is how it's reflected in the transcript, that all the

23     border crossings would be closed between the so-called, as it reads in

24     our transcript, "SFRY," and the so-called RSK.

25             Now, the original, at least the translation, also, I think, in

Page 16376

 1     B/C/S says "SRJ," which is not the same as the SFRY.

 2             First of all, could you perhaps read "SRJ" but then not using the

 3     acronym.  SRJ stands for ...

 4             MR. BAKRAC: [Interpretation] Yes, Your Honour.  I apologise if I

 5     made a mistake when reading it out.  The original says the Federal

 6     Republic of Yugoslavia, and then we have an acronym, and the so-called

 7     Republic of Serbian Krajina.

 8             JUDGE ORIE:  Yes.  But SRJ, if it's not the federal republic, is

 9     it the -- what is it, that, in full?  The so-called SRJ stands for ...

10             MR. BAKRAC: [Interpretation] Your Honour, at the time in 1995,

11     and somewhat earlier, when the republics of Slavonia, Croatia, Bosnia and

12     Herzegovina were recognised, as well as the republic of Macedonia, Serbia

13     and Montenegro remained, and these two entities were called the

14     Federal Republic of Yugoslavia, and it consisted of the Republic of

15     Serbia and the Republic of Montenegro.

16             JUDGE ORIE:  That brings me exactly to my point where I'm totally

17     confused about the evidence given by this witness.

18             The witness explained to us, and please listen carefully, that

19     the -- you explained that you came from Belgrade, went to Erdut.  From

20     Erdut you had to finally reach the Republic of Serbian Krajina.  May I

21     take it that that was the Republic of Serbia Krajina which was on --

22     well, let's say, on Croatian territory, or at least what used to be

23     Croatia.  Is that correct?

24             THE WITNESS: [Interpretation] No, it was the Republic of Serbian

25     Krajina.

Page 16377

 1             JUDGE ORIE:  Yes.  Now, the Republic of Serbia Krajina, but

 2     correct me when I'm wrong, was partly found in what used to be Croatian

 3     territory.  That is, Serbian Krajina, Knin area, that area.  Are you

 4     referring to that, or are you referring to any other part of the

 5     Republic of Serbia Krajina.  You are referring to the Knin area?

 6             THE WITNESS: [Interpretation] Yes, yes.

 7             JUDGE ORIE:  So you explained to us that there was a special

 8     arrangement with the -- for crossing borders with the ... and that was a

 9     agreement between Commander Arkan and the minister of defence of the army

10     of the Republic of Serbia.

11             You also explained that you would take a route through

12     Republika Srpska and then go to the Republika Srpska Krajina.  Would that

13     mean crossing the border from Erdut first into Republika Srpska and then

14     into the Republic of Serbian Krajina?  Is that ...

15             THE WITNESS: [Interpretation] No, Your Honour.

16             We had to travel for a brief period through the republic -- the

17     Federal Republic of Yugoslavia.  And this agreement concerned that

18     stretch, and not the trip from Republika Srpska to the Republic of

19     Serbian Krajina, which was never a problem.

20             JUDGE ORIE:  Yes.  And now the document you've shown to the

21     witness is about border crossings between the Socialist Republic of

22     Yugoslavia and the so-called Republic of Serb Krajina.  Which border are

23     we now -- who is moving from where to where exactly?  And what --

24     [Overlapping speakers] ...

25             MR. BAKRAC: [Interpretation] Your Honour, with your leave, I know

Page 16378

 1     what the situation was like, and if I may interpret what the witness has

 2     just said, because of the front line -- well, I do apologise.  To avoid

 3     any mistakes, I'll ask the witness.

 4        Q.   Was it possible to go from Erdut to the Republic of

 5     Serbian Krajina to Knin without passing through the Federal Republic of

 6     Yugoslavia, or, rather, through Serbia, through part of that federal

 7     entity?

 8        A.   No, it wasn't possible because it would have required passing

 9     through Croatian territory, which is where the Croatian forces were

10     present, and that was impossible.

11             JUDGE ORIE:  So I do understand that that agreement was to go

12     from Erdut back into Serbia and then from Serbia into the

13     Republika Srpska and from the Republika Srpska into the Republika Srpska

14     Krajina.

15             That is what that agreement is about, isn't it?  Well, at least

16     the first stretch -- [Overlapping speakers] ...

17             MR. BAKRAC: [Interpretation] Yes, yes, Your Honour.  Going from

18     Erdut to Serbia and then Serbia to Republika Srpska was the problem.  But

19     the witness said that it wasn't a problem to go from Republika Srpska to

20     the Republic of Serbian Krajina.

21             JUDGE ORIE:  And now, the document shown related to the telephone

22     intercept is crossings between the Socialist Republic of Yugoslavia and

23     the so-called Republika Srpska Krajina.

24             Now, from what I understood is that from Erdut you'd go to the

25     Republic of Serbia, then you would cross the border with the

Page 16379

 1     Republika Srpska, and from the Republika Srpska, then to Republika Srpska

 2     Krajina.

 3             So I'm wondering where do I find border crossings between the SRJ

 4     and the RSK?  Where do I find them?  Because I understand that it was

 5     Erdut, crossing the border to Serbia, from Serbia to Republika Srpska,

 6     from Republika Srpska to the Republika of Srpska Krajina.

 7             So I'm -- I have border crossings between two states which are

 8     not neighbouring each other.  SRJ and the RSK.  In between there is the

 9     Republika Srpska.  So I'm asking myself how to understand this document

10     at all.  I'm just trying to understand the geography, and that's the

11     reason why I -- although I had -- of course, I -- I expected that where

12     you -- you misread or it was missed -- where it was not accurately put on

13     the transcript, the SRJ, because I wanted that to be clarified first

14     before I could put this question to you.

15             MR. BAKRAC: [Interpretation] Your Honour, the northern part of

16     the Federal Republic of Yugoslavia, that northern part which shares a

17     border with the Republic of Serbian Krajina, is Serbia.  To the south we

18     have Montenegro, which didn't share a border with the Republic of

19     Serbian Krajina.  And then these crossings were crossings between the

20     Republic of Serbian Krajina and the Federal Republic of Yugoslavia, but

21     it was in the territory of Serbia.  As far as I have understood the

22     witness's testimony, they weren't border crossings but military

23     crossings.  These were military routes that they used, but they passed

24     through the territory of Serbia to a certain extent.  And the territory

25     of Serbia was an integral part of the state that was known as the

Page 16380

 1     Federal Republic of Yugoslavia at the time.

 2             JUDGE ORIE:  So when you say in the northern part there is a

 3     border between the Socialist Republic of Yugoslavia, it being Serbia

 4     there, and the Serbian Krajina, you are referring to, could I say, the

 5     eastern part of the Republika Srpska Krajina?

 6             MR. BAKRAC: [Interpretation] Yes, Your Honour, the eastern part.

 7     And the west and part of Serbia or, rather, of the SRJ.

 8             JUDGE ORIE:  What you are actually -- what, then, the evidence

 9     is, and now I think I understand it better, that moving from the eastern

10     part, Western Slavonia, Srem, that area, to the other part of the

11     Republika Srpska Krajina, you would have to cross through Croatian-held

12     territory, and that was the reason why from the Republika Srpska Krajina,

13     although the eastern part, you would move to Serbia, then to the Republic

14     of -- Republika Srpska, and then -- so -- and then finally to the western

15     part of the Republika Srpska Krajina.

16             So when we are looking this document, it is the border crossing

17     between Serbia proper and the eastern part of the social republic -- of

18     the Serbian Republic Krajina -- Republika Srpska Krajina, I'm sorry.

19             What confused me, of course, is that often we are referring to

20     "We go to Erdut," but Erdut was Republika Srpska Krajina but only the

21     eastern part.  So to say to go from Erdut and reach the Republika Srpska

22     Krajina is, to that extent, nonsense, that it is already part of the

23     Republika Srpska Krajina, although we are talking about going to another

24     sector or another part of the Republika Srpska Krajina.

25             I think it's now all perfectly clear to me.

Page 16381

 1             But could we please -- if we use those words, "we go to Erdut" or

 2     "we go to the -- from Erdut to the RSK," is, of course, if Erdut is

 3     already part of the RSK, what the exact wording should have been is: "We

 4     go from Erdut to the western part of the Republika Srpska Krajina and in

 5     order to reach that western part, we would have to go through Serbia,

 6     Republika Srpska, and then cross that border."

 7             The language used is not consistent.  And I would -- in order not

 8     to be confused, apart from small inaccuracies in the transcript, again, I

 9     do not know what you read.  I think, as a matter of fact, that you did

10     read "SRJ," but I leave that alone.

11             It's now perfectly clear to me again.  And could we always, if we

12     are referring to places, then we are referring to places.  If we are

13     referring to geographical entities, that we give them the proper name.

14     That is, in this case, going to Republika Srpska Krajina, to the western

15     part of that.

16             Please proceed.

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

18     understand, and I will make an effort to put precise questions so that we

19     don't get confused about these stretches of territory.

20        Q.   Mr. Pelevic, very briefly.  You said you were seriously wounded

21     in the battle-field.  Where were you transported to and how long were you

22     treated for?

23        A.   From the top of Velebit I was taken to Mali Alan.  There was an

24     HQ there.  And then I was taken to the hospital in Gracac, they couldn't

25     intervene there.  And then I was taken to the Sveti Save hospital in

Page 16382

 1     Knin, from Knin by helicopter to Banja Luka, and from Banja Luka after

 2     two days I was transported in an ambulance to the VM -- the military

 3     medical academy in Belgrade, since there were no flights between

 4     Republika Srpska and the Federal Republic of Yugoslavia as a result of an

 5     order issued by the UN.

 6        Q.   Why were you transported to the VMU -- VMA in Belgrade in order

 7     to be treated there, the military and medical academy?

 8        A.   That was agreement between Arkan and the minister of defence of

 9     the Army of Yugoslavia.  The agreement was that our wounded should be

10     taken to the VMA where they would be treated.  Or sometimes, because the

11     VMA didn't have the capacity, some soldiers would be taken elsewhere.

12     But most of the soldiers, and that included myself, were provided with

13     treatment at the military and medical academy, the VMA.

14        Q.   Did members of the SDG -- were the welfare certificates taken to

15     the MUP in Serbia in order to be checked?  Did you have any such

16     information?

17        A.   I don't understand the question.

18        Q.   Did the Serbian MUP or DB ever certify the welfare certificates

19     of your soldiers in order to provide them with treatment?

20        A.   No.  Why?  That was not necessary.

21        Q.   Thank you, Mr. Pelevic.

22             Mr. Pelevic, when your treatment had been completed, where did

23     you return to and what did you do after you returned there?

24        A.   My treatment still hasn't been completed, but three months later

25     I was already capable of continuing to work.  I returned to the Serbian

Page 16383

 1     parliament as a national member of parliament, of course.

 2        Q.   And throughout the year 1993 you were involved in politics in

 3     parliament; is that correct?

 4        A.   Yes.

 5        Q.   Towards the end of 1993 were new elections held?  And if that was

 6     the case, did you participate in them?  And in what capacity?

 7        A.   Yes.  President Milosevic called an election that was held, I

 8     believe, towards the end of the year.  In December 1993, I believe.  We

 9     participated in the election.  We first founded a political party called

10     the Party for Serbian Unity, and this was done in accordance with what

11     the president of the party, Zeljko Raznjatovic, Arkan, stated in a

12     video-clip.  We continue to be involved in policies and as a party we

13     participated in those parliamentary elections.  These were preliminary

14     parliamentary elections.

15        Q.   Could you tell us at that time towards the end of 1993 what

16     results did you obtain at the elections?  Did you manage to enter

17     parliament?

18        A.   No.  Unfortunately, that was not the case, and we believe that we

19     were the subject of deception at those elections.  The votes had been

20     stolen from us.

21        Q.   Did you reach the threshold at all that was necessary to enter

22     parliament?

23        A.   No.  Because the leading party didn't want the

24     Party of Serbian Unity to enter parliament.  There are indications that

25     many of our votes had been stolen at those elections by the leading party

Page 16384

 1     that was led by Slobodan Milosevic.

 2        Q.   Let me ask you this:  Did you and Mr. Raznjatovic talk about

 3     being close to the MUP, the DB?  And if had you been close to them, would

 4     you have passed threshold?  Did you ever talk about that?

 5        A.   No, not in that way.  But we realized that we were in the way of

 6     the ruling party and Slobodan Milosevic and that's why we didn't make it

 7     to the parliament.  If we teamed up with his party, if we subscribed to

 8     his policies, we would have certainly made it to the parliament.  Not

 9     only that, we would have probably won many more votes than we did during

10     the first elections.

11        Q.   During the pre-election campaigns in 1993, did Arkan talk to

12     Badza?  Was he in contact with Badza?  What was their relationship?  What

13     kind of contacts did they have?

14        A.   His connections with Badza were still friendly but Badza was

15     never involved in politics.  So whatever conversations they had, they

16     were not political conversations they were not -- they didn't deal with

17     the campaign.  Those were military conversations dealing with the status

18     of Slavonia, Baranja, and Western Srem.  That was all.

19        Q.   Having lost in the elections in December 1993, having not made it

20     to the parliament, in early 1994 did you participate in any war

21     activities?  Were there any such activities at all?

22        A.   You're talking about the beginning of that year?  No.  There were

23     no important war activities at the time.  We continued pursuing our

24     political work.  We were determined to improve our political rating.

25     However, at the rallies that we held all over Serbia, we realized that

Page 16385

 1     our popularity was already very strong and we were even more deeply

 2     concerned after that that we had lost in the elections unjustly, because

 3     the votes had been stolen from us.

 4        Q.   Mr. Pelevic, the territorial centre in Erdut, did it continue to

 5     operate in 1994?  And if that was the case, until when did it operate?

 6        A.   It continued to operate in the beginning of that year up to the

 7     end of March or the beginning of April.  And then we were moved from

 8     there.

 9             The guards had not been disbanded as such, but they were all on a

10     long furlough.  However, each guard member was obliged to respond to the

11     commander's call.

12        Q.   When you say that the guard members were on a long furlough, can

13     you tell us when was that?  From when to when?

14        A.   The guards became passive.  The whole organisation became

15     passive.  And that passivity lasted for a few months.

16        Q.   My colleague is signalling to me that something is not clear in

17     the transcript.  Let's finish with that.  We have two more minutes.

18             If I understood you properly, the camp in Erdut remained open

19     sometime until the end of March and the beginning of April 1994; right?

20        A.   Yes.

21        Q.   And then you said that the organisation became passive and the

22     members of the guards were on a long furlough.  Until when?  How long did

23     that last for?

24        A.   A few months.  I can't tell you exactly how long.  It was a long

25     time ago, so I can't be sure of any of the dates.

Page 16386

 1        Q.   Are we talking about 1994 still?

 2        A.   Yes.

 3             MR. BAKRAC: [Interpretation] Your Honours, I'm looking at the

 4     clock.

 5             JUDGE ORIE:  So am I, Mr. Bakrac.

 6             Mr. Pelevic, we will adjourn for the day.  And we'll continue

 7     tomorrow morning at 9.00 in the same courtroom.

 8             But before we adjourn, I would like to instruct you that you

 9     should not speak with anyone about your testimony or communicate in any

10     other way, written or oral, about your testimony, whether that is it

11     testimony you've given today or testimony still to be given tomorrow.

12             Another question I would raise:  Mr. Bakrac, could you give us an

13     indication as to how much time you would still need tomorrow?

14             MR. BAKRAC: [Interpretation] Your Honours, I had not make the

15     same mistake again.  Last time I had an old estimate.  I know that we

16     envisaged four hours for this witness.  I don't know how much I spent,

17     but, with your leave, I would ask for another hour and a half tomorrow.

18             JUDGE ORIE:  Yes.  I think that would fit within your original

19     estimate.  So shortly after the first break you would conclude your

20     examination-in-chief.

21             We adjourn.  And we resume tomorrow, Wednesday, the

22     25th of January, at 9.00 in this same courtroom, II.

23                            --- Whereupon the hearing adjourned at 1.46 p.m.,

24                           to be reconvened on Wednesday, the 25th day of

25                           January, 2012, at 9.00 a.m.