Tribunal Criminal Tribunal for the Former Yugoslavia

Page 14064

 1                           Wednesday, 28 April 2010

 2                           [Open session]

 3                           [The accused entered court]

 4                           --- Upon commencing at 2.17 p.m.

 5                           [The witness takes the stand]

 6             JUDGE PARKER:  Good afternoon.  Please sit down.  The affirmation

 7     you made to tell the truth still applies.  And now Ms. Kravetz has some

 8     questions for you.

 9             MS. KRAVETZ:  Thank you, Your Honours.

10                           WITNESS:  STOJAN MISIC [Resumed]

11                           [Witness answered through interpreter]

12                           Cross-examination by Ms. Kravetz:

13        Q.   Good afternoon, sir.

14        A.   Good afternoon.

15        Q.   Sir, I would like to go back to your testimony of yesterday and

16     start out by clarifying the lines of work that you had as an assistant

17     minister of the MUP in 1998 and 1999.  You told us yesterday that you

18     were in charge of alien affairs, travel documents, fire-fighting, and

19     communications; correct?  That's what you said?

20        A.   Yes, I said that.  The minister of Internal Affairs with the

21     appropriate internal regulation would entrust assistant ministers,

22     including myself, a certain professional lines of work, and these were,

23     just like you said yourself, administrative affairs, alien affairs,

24     fire-fighting police, and the communications system.

25        Q.   Sir, when you speak about administrative affairs and alien

Page 14065

 1     affairs, and yesterday you also said travel documents, are you referring

 2     to the administration that in Article 13 of the internal rules of the MUP

 3     is called the border police administration for foreigners and

 4     administrative affairs, is that the official name of the administration

 5     that you were in charge of?  Or did it have a different name?

 6        A.   The official name of the administration, according to the

 7     regulations on internal organisation, was the Administration of Border

 8     Affairs for Aliens and Travel Documents.  So the administration for

 9     border affairs, which I didn't cover, because this involved police work.

10     In my career I was always in charge of operative and administrative

11     tasks; not police tasks.  Thus, I was in charge of the duties that I

12     indicated earlier.

13        Q.   And who was the head of this administration in 1999?  Was there a

14     chief?

15        A.   Since the chief of the administration, General Mile Puzovic

16     assigned to the Federal Ministry of Internal Affairs, that post was

17     vacant and the administration was headed by the deputy administration

18     chief, Mr. Petar Dujkovic.

19        Q.   And Mr. Dujkovic, would he report directly to you in matters that

20     concerned administration or to someone else?

21        A.   Yes.  He was responsible to the extent that the minister issued

22     me assignments in the administrative area.  He was responsible to the

23     assistant minister, yes.

24        Q.   And how would this reporting take place?  Would you meet

25     regularly with Mr. Dujkovic to discuss matters concerning this

Page 14066

 1     administration, or would you work with him in another way?

 2        A.   Since I was assistant minister for Internal Affairs, I did not

 3     deal with specific cases or matters.  I was dealing most of all with

 4     systemic matters, primarily organisation and the functional aspect of

 5     those administrations for which I was responsible, and helping in the

 6     work of the minister.  Pero Dujkovic from time to time got in touch with

 7     me if we needed to agree on certain assignments, but this was first of

 8     all dealing with the organisational aspect.

 9        Q.   So in matters that did not concern the organisational aspect of

10     that administration, who did he report to?

11        A.   He was responsible to the chief of the department, and the

12     minister for those matters.

13        Q.   Okay.  You've also mentioned communications and fire-fighting.

14     Are these two separate administrations?

15        A.   Yes.  We have the fire-fighting police administration and the

16     communications administration.  These are two internal organisational

17     units at the seat of the ministry for Internal Affairs.

18        Q.   So if I understand correctly, you were, in fact, as assistant

19     minister in charge of these three different administrations to the scope

20     of -- or within the scope of work that had been assigned to you with

21     regard to the first?

22        A.   Yes, you are right.  I was in charge of these three lines that we

23     discussed for their co-ordination, organisation, proposing the adoption

24     of specific decisions to the minister on the basis of monitoring the

25     situation, and pursuant to the decisions then made by the minister, I

Page 14067

 1     would be the one to implement these decisions.

 2        Q.   And all three of these administrations fell within the RJB; no?

 3     They were within the public security sector?

 4        A.   Yes.  All three administrations fell under the RJB, yes.

 5        Q.   Now, sir, yesterday you spoke at some length about the role of

 6     assistant ministers, and I understand your evidence to be that the role

 7     was to help the minister carrying out the tasks or the mandate pertaining

 8     to the work of the ministry within the province of work that was -- that

 9     they were in charge of specifically, each one of the ministers.  Would

10     that be a fair statement of what you understood the role of assistant

11     ministers to be?

12        A.   Yesterday I talked about the function of the assistant ministers.

13     Their task primarily was to act on the basis of the minister's decisions

14     because the minister was the only one inherently empowered to organise

15     the service, and then he would task the assistant ministers for certain

16     areas of work.  We would be assisting the minister, like I said

17     yesterday, in the making of these decisions, and then later in the

18     implementation of these decisions.

19        Q.   And your evidence was that assistant ministers derived their

20     authority from the authority of the minister?

21        A.   Yes, that is correct.

22        Q.   But, sir, the fact that assistant ministers derived their

23     authority from that of the minister does not mean, does it, that

24     assistant ministers, in fact, did not have authority within the ministry,

25     does it?

Page 14068

 1        A.   They had authority to the extent that it was granted to them by

 2     the minister.  For example, let's take some matters from my ambit.  Let's

 3     say communications, I would suggest to the minister that the system be

 4     repaired by the purchase of some telephone exchange since the chief of my

 5     administration suggested that.  After that we would discuss that.  If the

 6     minister accepted that proposal, then it was up to me.  I had the

 7     authority to negotiate with the producer, the manufacturer to discuss the

 8     price, the type of equipment, and so on and so forth.  So I did have the

 9     discretion to organise the execution of that assignment and also I had to

10     report back to him on progress.

11        Q.   Would you agree with me, sir, that after the minister, assistant

12     ministers were, in fact, the most senior members within the MUP, within

13     the structure of the MUP?

14        A.   Assistant ministers in any case were of top rank because at the

15     time 1988 and 1989 [as interpreted] we didn't have deputy ministers as

16     compared to the previous period, so in that way this did affect the

17     functioning and the leadership of the ministry itself because the

18     minister Vlajko Stojiljkovic neglected the fact that a deputy minister

19     needed to be appointed.  So after the minister, we were the highest

20     ranking or the highest positioned leadership in the ministry.

21             MS. KRAVETZ:  Okay.

22             JUDGE PARKER:  Would you pause a minute.

23             Yes, Mr. Djurdjic.

24             MR. DJURDJIC: [Interpretation] I just would like for Ms. Kravetz

25     to look at line 16 of page 5 of the transcript, these two years.

Page 14069

 1             MS. KRAVETZ:

 2        Q.   Sir, the transcript records you as saying assistant ministers in

 3     any case were the top ranked, "because at the time, 1988 and

 4     1999 [sic] ..."

 5             Did you mean to refer to those years 1988 and 1999 [sic]?

 6        A.   1998 and 1999, I apologise.

 7        Q.   Thank you.

 8             MS. KRAVETZ:  If we could have D208 now up on the screen.

 9        Q.   And this is, sir, a decision setting up the collegium of

10     4th December, 1998, that you saw yesterday.  I'm just waiting for it to

11     come up.  Do you recall seeing this yesterday, sir, and going over it

12     with my learned colleague?

13        A.   I did see this decision on the setting up of a collegium of the

14     minister of the interior, and I did say that yesterday during my

15     testimony.

16        Q.   And I believe your testimony was that this was the composition of

17     the collegium at that time, and this is December 1998, it included these

18     members?

19        A.   Yes, I did confirm that.

20        Q.   So we see within this document that there are two members of the

21     DB included, this is Colonel-General Radomir Markovic, and Major-General

22     Nikola Curcic.  These were the two members of the state security sector

23     who formed part of the collegium; correct?

24        A.   Both of them were from the state security administration and were

25     members of the minister's collegium pursuant to this decision.

Page 14070

 1        Q.   The collegium also included General Obrad Stevanovic.  Do you

 2     recall what was his position in the years we are concerned with, 1998 and

 3     1999?  What was he in charge of?

 4        A.   As far as I recall, General Obrad Stevanovic was in charge of

 5     co-ordination, as we refer to it, of the police administration, and for

 6     co-ordination of the appropriate organisational units outside of the

 7     public security administration.  These were the secondary school for

 8     Internal Affairs, higher school for Internal Affairs, and the police

 9     academy.  He was the one who was co-ordinating those particular

10     professional lines of work.

11        Q.   And the police administration which General Obrad Stevanovic was

12     in charge of, that fell within the RJB, the public security sector?

13        A.   Yes, the police administration was under the public security

14     administration.  Yes.

15        Q.   And what about Petar Zekovic?  Major-General Petar Zekovic, what

16     was he in charge of?

17        A.   General Petar Zekovic was in charge of two administrations at the

18     seat of the ministry.  That was the general affairs administration and

19     the accommodation administration.  He was in charge of the co-ordination

20     of those two administrations.

21        Q.   And that was also within the ambit or scope of the public

22     security sector, these administrations that he was in charge of?

23        A.   The two administrations were also part of the public security

24     administration or department.

25        Q.   And the document also lists Major-General Dragan Ilic, the chief

Page 14071

 1     of the crime police administration.  Crime police administration, that

 2     also fell within the RJB; correct?

 3        A.   General Dragan Ilic was chief of the criminal police

 4     administration which was also under the public security department.

 5        Q.   And do you know why it is that he was included as one of the

 6     members of the collegium?

 7        A.   As this was an exceptionally important area in the public

 8     security department dealing with very important assignments, primarily

 9     crime fighting actions and discovering perpetrators of crimes, it did not

10     have an assistant and that is why in the decision on setting up the

11     collegium of the Ministry of the Interior he was assigned for that.

12     Previously that area was covered by Mr. Radomir Markovic, assistant

13     minister.  But since we didn't have an assistant minister for that

14     particular area, then, of course, Dragan Ilic was included in this

15     decision on the setting up of the collegium of the minister of

16     Internal Affairs.

17        Q.   The last member we see here mentioned is Major-General

18     Branko Djuric, and the chief of the Belgrade SUP, which of course also

19     fell within the RJB, the public security sector.

20        A.   Like I said yesterday, all the organisational units in the field,

21     the territorial organisational units, and these are the SUPs, belong to

22     the public security administration as opposed to the territorial

23     organisation of the state security administration where we had certain

24     centres covering specific territories.  And they were under the

25     jurisdiction of the state security service.  So Branko Djuric as the

Page 14072

 1     chief of the Secretariat of Interior in Belgrade was in the public

 2     security sector.

 3        Q.   And do you know why he is included as a member of the minister's

 4     collegium?

 5        A.   Well, you can see that this was something that was part of

 6     tradition.  Since I was working there from the 1970s onwards, the chief

 7     of the secretariat of Internal Affairs in Belgrade was always a member of

 8     the minister's collegium, first of all because this was a the highest

 9     internal organisational unit of the ministry with the most complex

10     problems to deal with in the Republic of Serbia, the most complex crimes

11     and public law and order issues, because it is also the most -- the

12     broadest in its duties.  It is always believed that the chief of the

13     secretariat of the interior in Belgrade should always be a member of the

14     minister's collegium.  I can say that this was true during the term of

15     office of the minister, or actually the republican secretary

16     Radmilo Bogdanovic.  When the post was referred to as ministerial post,

17     it was true during the term of office of Zoran Sokolovic, when he was at

18     that post.  And this practice was continued during the term of office of

19     minister Vlajko Stojiljkovic.

20        Q.   Do you recall, sir, who held the position of head of the Belgrade

21     SUP before Branko Djuric?

22        A.   The head of the Belgrade SUP before Branko Djuric, General

23     Branko Djuric, was General Petar Zekovic.  Petar Zekovic was appointed

24     assistant minister by the government, and Branko Djuric who was the chief

25     of the Internal Affairs department in new Belgrade was appointed as the

Page 14073

 1     chief of the Secretariat of the Interior in Belgrade.

 2        Q.   Thank you.  And we haven't mentioned Colonel-General

 3     Vlastimir Djordjevic who is listed first in this document as assistant

 4     minister and chief of the public security department.  Now, sir, would

 5     you agree with me that within the collegium of the minister, as is set

 6     out in this document, General Djordjevic was one of the highest ranking

 7     and most senior officers?

 8        A.   The chiefs of the public security and state security departments

 9     are the highest ranking officers in the ministry.  And in this collegium,

10     which is quite normal because while adopting the rules on the internal

11     organisation, the minister set up two basic organisational units, that is

12     the department of state security and the department of public security.

13     And General Djordjevic was the chief of the public security department.

14        Q.   And we see that both he and a General Markovic both hold the rank

15     of Colonel-General, that was, in fact, a highest rank an officer of the

16     MUP could have now within the structure of the MUP.

17        A.   Yes, General Vlastimir Djordjevic and General Radomir Markovic

18     held the highest ranks in the ministry at the time.

19        Q.   I want to take you now to another document you saw yesterday.

20             MS. KRAVETZ:  And this is P357.

21        Q.   And these are the rules -- internal rules and regulations of the

22     MUP.  I'm just going to wait for this to come up on the screen.  While

23     that is coming up, yesterday you discussed these rules with my learned

24     colleague and you referred to Article 13 of the rules, which establishes

25     11 organisational units or administrations at the level of the MUP

Page 14074

 1     headquarters in Belgrade.  Do you recall going over that yesterday with

 2     my learned colleague?

 3        A.   Yes, I do.

 4             MS. KRAVETZ:  I want to take you to Article 54, which is -- in

 5     the English, it's page 42; and in the B/C/S, it's page 45.

 6        Q.   So just very briefly, sir the first line here, this is under the

 7     section control of organisational units, say the departments shall be

 8     controlled by chief of departments.  Now, you see that, sir?  Article 54.

 9        A.   Yes, I see that.

10        Q.   So, sir, you would agree with me that according to the rules of

11     internal organisation of the MUP, the public -- the service department

12     was controlled by the chief of the department which you've told us was

13     Mr. Djordjevic?

14        A.   Yes.  The public security department was headed by the chief of

15     the department.

16        Q.   And in the role of chief of the department, he would have been in

17     charge of the public security department and the organisational unit that

18     formed part of this department, correct, according to these rules?

19        A.   I didn't understand that.  I didn't understand the question.

20        Q.   I'll put it -- well, I think you've already answered.  What I'm

21     saying is according to these rules, the rules we are looking at, in his

22     role of chief of the department he would have been in charge of the

23     public security department, RJB, and of the organisational units that

24     formed part of that department, the organisational units, in the RJB?  Is

25     that clear, sir?

Page 14075

 1        A.   I'm getting something strange.

 2        Q.   I am sorry, are you having problems with interpretation?

 3        A.   Yes.

 4        Q.   That will be attended to in a minute, sir.  Are you hearing me

 5     now, are you getting interpretation?

 6        A.   I can hear you.  I can hear you now.  I can hear the interpreter,

 7     that is.

 8        Q.   I'll just repeat my question, it was a very simple question.  I

 9     was just asking, you've told me earlier that the public security

10     department was headed by the chief of the department, and what I'm asking

11     is based on these rules, the internal rules and regulations of the MUP,

12     the chief of the public security department was in charge of the

13     department of the RJB and of organisational units that formed the

14     department, would you agree with that, sir?

15        A.   The chief of the department or sector heads all organisational

16     units at the seat, and the organisational units in the field and the

17     territory, that is.  Those subordinated to him were the chiefs of

18     secretariats.  By virtue of the document, the minister delegated powers

19     to the chief of the sector to control and manage these organisational

20     units.  However, the minister having appointed a certain number of

21     assistant ministers at the same time narrowed the authority of the chief

22     of the sector.

23             There were four assistant ministers, including myself.  We were

24     authorised by the minister to cover our respective lines of duty.  In

25     that part of our duties assigned to us by the minister, and we've

Page 14076

 1     discussed how it was done yesterday, it was precisely that which limited

 2     the authority of the chief of the public sector.

 3             Why was that so?  Well, by virtue of our rules, the first or

 4     immediate superior to assistant ministers is the minister himself.  He is

 5     also the immediate superior to the heads of organisational units outside

 6     the sectors, such as the schools and the director of the institute.

 7        Q.   I think we got your position on that yesterday, and it wasn't my

 8     intention to repeat all of that evidence.  I was just asking a very

 9     specific question, and you've given your answer to that question.  So I'm

10     sorry, I'm going to interrupt you there just so we can move on.

11             Sir, these rule we are looking at, they apply to the work of the

12     ministry in the entire territory of Serbia; correct?

13        A.   Yes, that is correct.

14             MS. KRAVETZ:  I want to look at another document.  This is D396.

15     If we could have that up on the screen.

16        Q.   Yesterday you looked at a decision which appointed

17     General Djordjevic as acting head of the RJB.  This is the decision that

18     appoints him as head of the public security department, and it's headed

19     27th January, 1998.  I'll give you a minute to look at that.

20        A.   Yes.

21        Q.   And we see this is, well, as I've stated, dated January 1998.

22     You would agree with me, sir, based on the regulations we saw and on this

23     decision that in order for Mr. Djordjevic to cease in the exercises of

24     his functions or powers as chief of the RJB, MUP Minister Stojiljkovic

25     would have to formally divest him of his powers; correct?

Page 14077

 1        A.   The minister was authorised to issue an appropriate decision and

 2     to assign people to different positions including the chief of the

 3     sector.  So there's nothing wrong with this.  He appointed him as of the

 4     1st of February of that year to that position.  We were all surprised a

 5     bit that up until that time he was only acting chief of the public

 6     security sector, and as such could not exercise his functions properly.

 7     I spoke frequently at the minister collegium meetings, he was just an

 8     announcer at such meetings, so to say.  He would simply give the floor to

 9     speakers.  But the weight of his words and authority was not such

10     because he was only acting chief of the sector.

11        Q.   My question was more specific, sir.  You've told us yesterday

12     during the course of your evidence that Mr. Djordjevic remained in the

13     position of chief of the public security department in 1998 and 1999;

14     correct?

15        A.   Yes.  He remained in that position in both 1998 and 1999, that is

16     correct.

17        Q.   So just going back to my question, isn't it true, sir, that in

18     those years as of his appointment, he was never, and I'm talking about

19     Mr. Djordjevic, officially divested of his powers of minister?  That did

20     not happen in 1998 or in 1999?

21        A.   I am afraid I did not understand your question fully, but perhaps

22     I can answer it this way:  Of course --

23        Q.   Let me state it again.  In 1998 or in 1999, did -- at any time

24     did the minister issue a decision like the one we are seeing now

25     officially stating that Mr. Djordjevic ceased in the function of head of

Page 14078

 1     the public security department?  Did that happen in either of those two

 2     years, based on your recollection?

 3        A.   No, that did not take place during 1998 or 1999.  In other words,

 4     he remained chief of the public security sector.  There were no decisions

 5     removing him from that position of his.

 6        Q.   Thank you, sir.  I want to now go back to the collegium.  We were

 7     looking at D208.

 8             MS. KRAVETZ:  Maybe if we could have it back up on the screen.

 9        Q.   Yesterday you spoke at length about the MUP collegiums, the

10     collegiums of the minister of the MUP; do you recall answering some

11     questions from my learned colleague in relation to that?

12        A.   I remember that.

13        Q.   And you said, sir, that one of the ways in which the ministry was

14     run was through meetings of the collegium of the MUP minister; correct?

15        A.   Yes, I did say that.

16        Q.   You regularly attended those meetings?

17        A.   Yes, I did, for the most part.  Perhaps sometimes I was in the

18     field, but I attended most of those meetings.

19        Q.   And you said these meetings took place in 1998, throughout 1998?

20        A.   I did not say that they were held throughout all of 1998.  For a

21     while, the minister, as far as I recall, he was appointed after

22     General Stojicic's murder.  There was an interim period of one or two

23     months during which there were no collegium meetings of the minister of

24     the interior.  What there was, was the collegium of the chief of the

25     public security sector.  When the minister was elected to his position on

Page 14079

 1     the 4th of June, he assigned duties to the assistant ministers, and at

 2     some point in time the meetings of the collegium of minister

 3     Vlajko Stojiljkovic began taking place.

 4        Q.   And when was General Stojicic murdered; do you recall?  Was that

 5     in 1998?

 6        A.   No.  It was in 1997.  1997, on the 11th of April.

 7        Q.   And this interim period of one or two months that you are

 8     referring to when there were no collegium meetings, this would be prior

 9     to the 4th of June, 1998?

10        A.   Yes, before the 4th of June, 1998.

11        Q.   And you said in relation to 1999 that you had collegiums during

12     the war, though the circumstances were more difficult; correct?  That was

13     your evidence, that these meetings continued to be -- take place during

14     the war in 1999?

15        A.   Yes, I recall that.  During the war the meetings of the

16     minister's collegium were held in a number of locations and, of course,

17     under much more difficult circumstances.

18        Q.   And in 1998 with what frequency were these meetings held?  As of

19     the 4th of June when they were resumed, how often would the collegium of

20     the minister meet?

21        A.   Well, the minister's collegium meetings, as a rule, were held

22     every week, basically every Tuesday, or sometimes on another day

23     depending on the obligations of the minister.  Such collegium meetings

24     were basically held every week.

25        Q.   Was that also the practice in 1999?

Page 14080

 1        A.   Yes, that practice continued in 1999, but it wasn't always on the

 2     same day because we had our own obligations and issues to resolve that

 3     had to do with bombing campaign.  But for the most part, it resumed the

 4     same way -- it was resumed the same way in 1999.

 5        Q.   These meetings were generally presided by the MUP minister

 6     Stojiljkovic?  He chaired the meetings?

 7        A.   Those meetings were presided solely by the minister

 8     Vlajko Stojiljkovic.  In his absence, there were no collegium meetings.

 9        Q.   Now, yesterday you spoke about the other attendees at these

10     meetings, and at transcript page 14030 you said:

11             "In addition to the chief of the public security sector, also the

12     chief of the state security sector was to be present as well as his

13     assistant, another assistant minister, in fact, Nikola Curcic, who was

14     otherwise a director of the security institute."

15             Do you recall saying that, sir?

16        A.   Yes, I do.  That is what I said.

17        Q.   And when you were shown this document, this document dated 4th of

18     December, 1998, which we have on the screen, you were asked by my learned

19     colleague - this is the next page, 14031:

20             "Can you tell us what the minister's collegium actually looked

21     like and how it worked once this 4th of December decision was issued?"

22             And you said:

23             "Once this decision was issued, the work of the collegium, in

24     fact, continued on as before."

25             And you went on to explain:

Page 14081

 1             "At the collegium meeting, the minister asked reports to be

 2     submitted by chiefs of administration, they did so, they also proposed

 3     various measures.  Then assistant ministers and the sector chief would

 4     also take the floor, and at the end the minister would issue

 5     conclusions."

 6             Do you recall saying that, sir, yesterday?

 7        A.   Yes, that is a what I said.

 8        Q.   And you went on to say -- and this is at the bottom of 14031 and

 9     starts on the next page.  You were asked:

10             "You said that chiefs of administration attended these meetings,

11     but can you tell us which particular sector these administrations

12     belonged to?"

13             And you said:

14             "Well, you see that it is stated here that the collegium is

15     composed of nine members, in actual fact; however, the collegium never

16     met if this particular composition."

17             And then you went on to say:

18             "Rather, the previous practice was adhered to, whereby all chiefs

19     of administrations would attend."  And you said:  "Chiefs of

20     administration of state security never attended these meetings."

21             And you were asked:

22             "This was the way of proceeding at the collegium of the minister

23     following the 4th of December, 1998.  Did it prevail up to the end of the

24     war in 1999?"

25             And you said:  "Yes, that's right."

Page 14082

 1             Do you recall giving that answer, sir?

 2        A.   That is not what I said.  There must have been a mistake made.

 3     The chief of the state security sector as of the 4th of December, 1998,

 4     always attended collegium meetings.  Both the chief and his deputy.  The

 5     way I understood you now was that I said that the chief of the state

 6     security sector never attended those meetings.  As a matter of fact, I

 7     was saying that until the 4th of December when the collegium was

 8     established, there was no one from the state security sector attending

 9     those meetings because Mr. Jovica Stanisic simply did not attend those

10     collegium meetings.  After the 4th of December, after the minister issued

11     the decision, as of that moment on, Mr. Radomir Markovic, the chief of

12     the state security sector and his deputy, Mr. Nikola Curcic, did attend

13     minister's collegium meetings.

14             I also said that there were also chiefs of administrations in

15     attendance, always, representing all of the organisational units at the

16     seat of the ministry, as it had been the practice in 1998.  This decision

17     was not implemented in the sense that the nine members of the collegium

18     should meet at collegium meetings.  What actually happened was that the

19     collegium meetings were attended by the chiefs of administrations.  That

20     is to say, administrations from the public security sector.  Never were

21     there any heads of administrations from the state security sector in

22     attendance.

23        Q.   Thank you for that clarification, sir.  Now, was -- just to

24     continue on the topic of these meetings, was there an agenda set

25     beforehand regarding what a meeting would -- what you would be dealing

Page 14083

 1     with at a meeting?  Or did you just follow-up from previous staff that

 2     had been assigned at the previous meeting, or how did that work?

 3        A.   We never received the agenda.  This represented standard mode of

 4     operation.  We also knew that the chiefs of administrations were there to

 5     submit their reports having analysed the security situation in their

 6     respective areas.  Based on such analyses, they also pointed out the

 7     problems and proposed measures to overcome them.

 8             Next, the assistant ministers and the chief of the -- the chiefs

 9     of the public and state security sectors put forth appropriate proposals

10     and suggestions.  Based on all that, at the end the minister drew

11     conclusions and assigned the focal tasks for the forthcoming period.

12     Based on those focal tasks, minutes were made by the chief of the

13     analysis administration, Mr. Krstic.  Those minutes would then, in turn,

14     be distributed to all those in attendance.  And everyone had to abide by

15     those conclusions.  At the following collegium meeting, they were

16     expected to submit reports on what they had done concerning those.

17             Let us understand each other.  At collegium meetings, the

18     so-called petty issues were not paid much attention.  At that level,

19     appropriate security policies were decided upon at the level of the

20     ministry.  Thus, directing all organisational units and forces in the

21     field.  We couldn't, of course, deal with individual cases because there

22     were hundreds and thousands of them.  We could only indicate trends,

23     patterns, based on which we could draw conclusions and exercise our

24     functions by doing so and following up.

25             To conclude, there was no specific agenda before any collegium

Page 14084

 1     meetings.

 2        Q.   And when you didn't attend a collegium meeting, would you receive

 3     copies of the minutes to inform yourself of what had transpired at the

 4     previous collegium meeting, or what had been decided and which staff had

 5     been assigned?

 6        A.   Yes, we always received them irrespective of whether we attended

 7     those meetings, because after all, we had to follow it up.

 8        Q.   Do you still have a copy, sir, of the minutes of these collegiums

 9     that you attended in 1998 and 1999 in your personal archives?

10        A.   Unfortunately, I don't.  Everything I had was in the safe in the

11     ministry.  When I retired, I had to hand it all over.  It was, of course,

12     forbidden to take such minutes and documents out of the ministry.  It was

13     -- they were secret.

14        Q.   And you've told us you retired in 2000, in the year 2000?

15        A.   Correct.  I left towards the end of 2000.

16        Q.   So the copies of your minutes of these meetings would still be in

17     the ministry, if I understand you correctly?  Once you left, that's where

18     they are kept, in the archive of the ministry.

19        A.   Of course.  They should be in the ministry.  And perhaps the

20     analysis department has copies.  However, my copies remained with the

21     ministry.

22        Q.   And that would have also been the case of the copies received by

23     other assistant ministers once they'd left office, they would have had to

24     return them and hand them over to the archive of the MUP?

25        A.   Precisely.  There could be a small problem though because the

Page 14085

 1     Ministry of the Interior was bombed on the 3rd of April.  The building of

 2     the ministry was destroyed.  In all likelihood, a great many documents

 3     were thus destroyed.  For example, all of my personal documentation was

 4     destroyed.  Now I basically have no documents at all at home regarding

 5     this.

 6        Q.   Okay.  Moving on, sir, yesterday you were speaking about the

 7     topics discussed at these collegiums, and you said that at the beginning

 8     or end of the collegiums, MUP minister Stojiljkovic normally gave a brief

 9     overview of the situation of Serbia with particular -- and a security

10     situation of Serbia with particular emphasis on Kosovo.  And this was at

11     transcript page 14031.  Do you recall saying that, sir?

12        A.   Yes, I do.

13        Q.   And you also said, and this is at transcript page 14033, that the

14     security situation in Kosovo in mid-1998 was an extremely complex and

15     difficult situation; correct?

16        A.   Yes.  In mid-1998 it was exceptionally complex, the security

17     situation in Kosovo and Metohija, that is.  I also said that almost

18     50 per cent of the territory was blocked by the terrorists.  There was no

19     freedom of movement.  We had numerous incidents, such as terrorist

20     attacks on policemen, soldiers.  There were many casualties among the

21     police and army.  We had non-stop terrorist provocations.  Our buildings

22     were being attacked.  The buildings of the ministry and of the army.

23     People were building kidnapped, Serbs and Albanians.  Those Albanians

24     loyal to the state of Serbia.

25             Next there were many murders of Serbs, non-Albanians, and even

Page 14086

 1     Albanians loyal to the state of Serbia.

 2        Q.   Sir --

 3        A.   I also said that our economy, society, and the state there, was

 4     basically paralysed.

 5        Q.   I was just asking you confirm this one statement you made

 6     yesterday.  We do have your evidence you gave yesterday on this topic.

 7             So you would agree with me, sir, that given that the situation in

 8     Kosovo in mid-1998 was, as you've put it, extremely -- exceptionally

 9     complex, it was always the focus of attention at collegium meetings of

10     the MUP ministry?

11        A.   Yes.  One of the priorities at the collegium ministry sessions

12     was the situation in Kosmet.  But the situation in Kosmet, generally

13     speaking, meant that the minister was in contact with the Chief of Staff

14     in Kosmet who had information.  The minister also had information, on the

15     other hand, from politicians who also were there, and he would then give

16     a brief overview without going much into detail.  For example, that such

17     and such a road was unblocked or such and such a settlement.  Other

18     details were not discussed at the collegium.  This would always be done

19     by the minister of Internal Affairs.  He would be the one who would give

20     us these kind of brief pieces of information.

21        Q.   I didn't mean to interrupt you, sir, just to move on in my

22     question.  You would agree with me, sir, that Kosovo was, in fact, the

23     most important security-related situation in which the RJB was involved

24     in, in 1998?

25        A.   Yes, it was extremely important.  However, the collegium ministry

Page 14087

 1     -- the ministry collegium would receive requests for logistical support,

 2     for police forces that were in Kosmet.  Requests would be for vehicles,

 3     weapons, and so on.  As for the material and financial services or

 4     general services, they also had some logistical tasks.  We would receive

 5     requests for the reinforcement of certain units, the sending of

 6     additional forces, or to relieve forces that were already there.  This

 7     was done by the police administration.  These questions were constantly

 8     on the agenda because there was no other way for us to monitor the

 9     current situation in Kosmet.  We would put all of our efforts to help

10     those people and our organisational units and the police units that were

11     in Kosovo fighting terrorism.

12        Q.   Now, I had asked you about 1998.  You would agree with me, sir,

13     that Kosovo remained the most important security-related situation in

14     which the RJB was involved in 1999?

15        A.   Of course.  This was one of the urgent matters that we had to

16     deal with.  Yesterday I did say, though, that the minister in 1998 formed

17     the ministry staff for anti-terrorist actions --

18        Q.   I'll stop you there.  We will get to that in a minute, so --

19     just so we don't get ahead of ourselves.  We will turn to that in a

20     minute.

21             Sir, in 1998, the RJB had approximately 14.000 MUP personnel

22     deployed in Kosovo; correct?

23        A.   I couldn't confirm that information because I don't remember, and

24     I wasn't really involved in those matters.

25        Q.   Fair enough.  Fair enough.  Now, you've told us, sir, that at

Page 14088

 1     collegium meetings of the MUP minister, you would deal with logistical

 2     tasks that concerned organisational units deployed in Kosovo?

 3        A.   Yes.  I said that the ministry collegium primarily discussed

 4     logistical issues and ways to assist our forces in Kosmet.

 5        Q.   And you dealt with the procurement of equipment for the units

 6     that were on the ground; correct?

 7        A.   That is correct.

 8        Q.   And you also said today that you would receive requests on

 9     reinforcement of units, and that was another issue you dealt with, the

10     reinforcement of units that were on the ground?

11        A.   Yes.  We always received requests to relieve a unit or send a

12     unit to Kosmet.  These were mostly relating to the PJP units.

13        Q.   And you said just a moment ago that this was done by the police

14     administration at the meetings of the minister.  That would have been

15     General Stevanovic who was representing the police administration?  Was

16     he the one who was making these requests for relief of units and

17     procurement of equipment?

18        A.   No, I didn't say that before.  Obrad Stevanovic was assistant

19     minister because there was no chief of the police administration at the

20     time, then Colonel Aleksic was deputy chief of the police administration

21     and in that capacity attended the collegium meetings.  I forgot to say

22     that in the annex to the minister's decision forming the collegium,

23     Mr. Ljubo Aleksic is not mentioned at all.  This is why I said that it

24     was a question of what sort of a list that was.  Obrad Stevanovic did not

25     send such requests.  The requests for replenishment of units were sent by

Page 14089

 1     the staff, the Ministry of Internal Affairs in Kosovo to the

 2     administration, and then the administration in turn carried out that

 3     other, let me put it that way, logistical technical aspect of the job.

 4        Q.   And just to make sure I understand your evidence, when you say

 5     that you were dealing with these requests at the minister's collegium,

 6     you were dealing with requests that came from the MUP staff, or you were

 7     dealing with requests that were being presented by Colonel Aleksic, the

 8     deputy chief?  Or maybe neither of these two.

 9        A.   Requests were not sent directly to the minister's collegium.

10     Requests were sent by the very nature of things to the police

11     administration because the police administration deals with all the

12     uniformed persons in the ministry.  Of course, police stations and other

13     organisational units of the police.  So the police administration would

14     receive requests as to what had to be done.  They would then suggest that

15     to the minister.  The minister would then make the appropriate decision

16     on the engagement of that unit, and then they would just send those units

17     to Kosmet.  I don't know if I was clear.

18        Q.   And when you say the police administration would receive the

19     requests and then suggest that to the minister, was that done at the

20     collegium?

21        A.   Yes, they were told to the minister.  They were also made at the

22     collegium so that that would enter the minutes.  For example, that a

23     certain unit had to be sent to Kosovo so that the minister would have a

24     record of which unit would need to be sent in order to relieve units that

25     were already there, and so on and so forth.

Page 14090

 1        Q.   When you say they were told to the minister, who told the

 2     minister?  That's what I'm trying to understand about these requests at

 3     the collegium.

 4        A.   The chief or the deputy chief of the administration would make

 5     the requests or the proposals at the collegium.

 6        Q.   So you are speaking of General Stevanovic or Mr. Aleksic who

 7     you've referred to earlier?

 8        A.   At the time Mr. Stevanovic was not at the collegium sessions, as

 9     far as I recall.  This was something that Mr. Aleksic did.

10        Q.   Okay.  So you spoke about dealing with reinforcements of units

11     and relieving units in the field.  You would also discuss then -- are you

12     okay, sir?  Yes.

13        A.   Yes, I'm fine.

14        Q.   You would also discuss the rotation of units; no?  Which units

15     would be sent, which units would be brought back out of Kosovo?

16        A.   Yes, we would receive requests from the staff and then we would

17     act pursuant to those requests and assist them to receive appropriate

18     forces.

19        Q.   And you told us earlier today that another matter that was

20     discussed and that you decided at these meetings were appropriate

21     security policies with respect to Kosovo?

22        A.   I don't understand the question.  I didn't say that at all.  What

23     sort of security policies?

24        Q.   If you give me just a second, you say:

25             "Let us understand each other.  At collegium meetings the

Page 14091

 1     so-called petty issues were not paid much attention.  At that level

 2     appropriate security policies were decided upon at the level of the

 3     ministry.  Thus, directing all organisation of units and forces in the

 4     field."  And this is at page 20 starting at line 8.

 5             Do you recall saying that, sir?  This was another matter that you

 6     discussed security policies, and this was decided at the level of these

 7     collegium meetings.

 8        A.   Well, yes.  Let me give you some specific examples.

 9             Since we were under sanctions, then there was the observation

10     that goods subject to excise taxes were being smuggled.  The government

11     then put the question to the minister about what was being done in that

12     area.  Then the minister came to the collegium meeting and instructed the

13     services how and what to deal with that.  This meant that we had to

14     gather all the necessary information, we had to make a security analysis

15     and on the basis of that apply adequate or change our conduct adequately.

16             We made our own analysis from the secretariat and the information

17     on the ground.  We analysed the situation at the ministry, and then

18     together with authorised state organs, got in touch with the judicial

19     organs and suggested to the minister to launch appropriate actions.

20     Well, maybe doesn't make much sense, but I can list which actions were

21     involved.  Then once an action is initiated, then plans are made which

22     facilities and forces are needed to deal with that particular problem.

23             This is how this was done.  We didn't actually review any

24     individual cases, for example, such and such a person hit such and such a

25     person or this and that.  I'm just talking about the general occurrence

Page 14092

 1     of certain things that were happening.  This is what we were looking at

 2     because the ministry was there in order to direct overall potentials and

 3     capacities for action in the field, so I was talking more in that sense.

 4        Q.   And you would also discuss, sir, any changes in the tactics of

 5     the work of the police in Kosovo; no?

 6        A.   Changes of tactics?  This question was never put at the

 7     minister's collegium.  What change of tactics?  We never dealt with

 8     anything like that.  I'm hearing of that for the first time, changes of

 9     tactics in Kosmet.  That question was never looked at or dealt with at

10     sessions of the minister's collegium.

11        Q.   But, sir, you've told us you started meeting again as of 4th of

12     June -- or in June of 1998.  You would have discussed at the level of the

13     collegium of the ministry that the MUP was stepping up its actions in

14     Kosovo?  No?  That would have been something that would have been

15     discussed at that level, that you planned to step up.

16        A.   No.  That was never discussed.

17        Q.   Sir, are you saying that you would -- the fact that the MUP was

18     about to engage in a large-scale offensive in Kosovo against the KLA

19     together with the VJ, that was not a matter that was discussed at the

20     level of the collegium of the minister in Belgrade?

21        A.   I said a number of times which questions were tabled.  We

22     practically, other than logistics, the questions that I mentioned

23     earlier, could not discuss the actions of the police because we didn't

24     have any experts for that part of the work at the collegium.  That was on

25     the one hand.  On the other hand, we didn't have such information.

Page 14093

 1        Q.   So you are saying you did not have information during the summer

 2     of 1998 that the MUP was about to engage in a large-scale offensive

 3     against the KLA in Kosovo with the VJ?  You didn't have that information

 4     at the level of the ministry?

 5        A.   Well, this is quite a different question altogether.  The

 6     information we had was that a state plan was made or that was being

 7     prepared, that this plan was drafted by the army, that it was engaging in

 8     the fight against terrorists.  There was some global state plan.  We were

 9     told this but we never discussed that plan at the level of the ministry

10     or at the level of the minister's collegium.  I never saw that plan and I

11     was a member of the collegium, so I would have had to see or should have

12     seen this plan.  Thus, it was said that a state plan was drafted, or

13     rather, a global plan, as far as I can remember.  But we did not review

14     it, and I never saw it.  And I was a member of the collegium.

15        Q.   Sir, I started asking you whether you would discuss at the

16     collegiums any changes in the tactics of the police in Kosovo.  Now,

17     based on this answer you've just given, is it correct, sir, that, in

18     fact, at the level of the collegium in Belgrade, you were discussing the

19     fact that the MUP was about to engage in a large-scale offensive against

20     the KLA together with the VJ?  That is something the collegium at the

21     level of the ministry in Belgrade was fully aware of and you were

22     discussing?  I'm not asking whether you saw the plan; I'm asking whether

23     this was something that you were discussing at the collegium.

24        A.   Well, allow me to repeat what I said earlier.  It's not that I

25     didn't see the plan, but at the minister's collegium this was not

Page 14094

 1     discussed at all.  I think that I'm quite clear in this now.  The

 2     minister's collegium did not discuss this.

 3        Q.   Maybe we are talking at cross purposes here.  I'm asking you a

 4     very specific question.  I'm asking whether at the level of the ministry

 5     in the summer of 1998 you discussed the fact of the -- at the level of

 6     the collegium of the minister, you discussed the fact that the MUP was

 7     about to engage in a large-scale offensive against the KLA together with

 8     the VJ?  That's what I'm asking.  Was this a matter of discussion?  I'm

 9     putting to you that it was, that this was something that was discussed at

10     the level of the ministry.

11        A.   I state that this was not discussed at the level of the ministry.

12        Q.   At all?  You never spoke about the fact that operations were

13     going to be stepped up in Kosovo in the summer of 1998?  Never discussed

14     that at all?

15        A.   I said that there was no discussion about the intensification of

16     activities.  We received information that some state plan had been

17     devised which provides for the engagement of the police and the army in

18     the fight against terrorists, but nothing was worked out, discussed, or

19     planned in any way about the way in which these anti-terrorist activities

20     would be planned at our end.  We did have the appropriate staff, and that

21     staff was obliged in co-operation with the military to draft plans and to

22     work on the suppression of terrorism in Kosmet.

23        Q.   Sir, you were, you've told us already, receiving requests from

24     the ground, from the MUP staff from the police administration concerning

25     logistics, no, and the reinforcements of units?

Page 14095

 1        A.   Yes, that's correct.

 2        Q.   And I take it, sir, that this happened during the summer of 1998

 3     you received such requests?  And by you, I'm talking about the collegium.

 4        A.   Yes, yes.  In the course of the summer.  Summer of 1998.  From

 5     what I can recall, sometime in July until the end of September or October

 6     these requests for the replacement of units were quite pronounced.  Yes,

 7     during the summer.

 8        Q.   And you would have also been aware of the number of units that

 9     were being sent down based on these requests?  You knew which units and

10     the number of units that were going down to Kosovo.

11        A.   Well, we did know, but I really cannot say that now.  It's been

12     awhile since then, so I cannot really remember.  It was known, though,

13     they --

14        Q.   Yes, just finish your answer, sir.  I wasn't asking you for

15     specific numbers.  I was just asking whether at the level of the

16     collegium you would have known that.

17        A.   Yes, we knew about the requests and the number being requested,

18     and so on and so forth.

19        Q.   And so you would have also known at the level of the collegium

20     that there was an intensification of police activities and that

21     additional units were being sent down given that you were dealing with

22     these requests?

23        A.   Well, you can ask -- well, I said earlier that the minister gave

24     us brief overviews at the minister's collegium because, like I said, he

25     received those reports both from the staff and the state security,

Page 14096

 1     primarily from the staff.  And he knew more or less -- actually, not more

 2     or less, but he knew that such and such a road - what do I know - the

 3     Pec-Pristina Road was unblocked, that work was being done, that the

 4     intensity had increased.

 5             As to what extent you would understand that we knew, yes, on the

 6     basis of a brief report by the minister.  He would always give some kind

 7     of evaluation or assessment and inform us briefly, but we did not discuss

 8     anything else.

 9             MS. KRAVETZ:  Thank you.  Your Honours, it's two minutes before

10     the break, but I would prefer to interrupt now before I move onto another

11     topic.

12             JUDGE PARKER:  Very well adjourn now and resume at just after ten

13     past 4.00.

14                           [The witness stands down]

15                           --- Recess taken at 3.45 p.m.

16                           --- On resuming at 4.13 p.m.

17                           [The witness takes the stand]

18             JUDGE PARKER:  Yes, Ms. Kravetz.

19             MS. KRAVETZ:  Thank you, Your Honour.

20        Q.   Sir, yesterday and today you said that in 1998 and 1999, and I'm

21     quoting your testimony from yesterday at transcript page 14040:

22             "We never discussed planning and the conduct of anti-terrorist

23     activities at the collegium sessions, nor did we receive any reports

24     about the implemented activities."

25             That was your position yesterday, correct, which you've repeated

Page 14097

 1     today?

 2        A.   Yes, that was so.

 3        Q.   In fact, yesterday at transcript page 14054, you said:

 4             "Not once during the war did we discuss planning, organising, or

 5     implementation of anti-terrorist activities in Kosovo and Metohija."  And

 6     you also said -- repeated that you did not receive any reports on that.

 7     Do you recall saying that?

 8        A.   Yes, I can confirm that.

 9        Q.   We've been focusing so far in 1998.  Sir, in 1999, somewhere in

10     the middle February 1999, do you recall attending a meeting of the MUP

11     collegium where a plan to be developed for the eventuality of the entry

12     of NATO forces to Kosovo was discussed?

13        A.   You said in February 1999, such a collegium meeting, or rather, I

14     did not attend such a collegium meeting.  I don't know that it was ever

15     held, and I don't know that such a plan was discussed during one such

16     meeting.  Such a collegium meeting with that agenda was not held, or

17     rather, I definitely did not attend such a collegium meeting.

18        Q.   You don't recall any meeting where you discussed measures to be

19     taken by RJB units in Kosovo in preparation for a NATO attack?  You don't

20     recall that?

21        A.   I do not.  I would definitely remember such a thing because it is

22     an important topic.

23        Q.   Well, I want --

24        A.   I definitely did not attend such a collegium meeting.

25        Q.   I want to show you a document.  Maybe this refreshes your memory.

Page 14098

 1             MS. KRAVETZ:  This is P1509 MFI.  If we could have that up on the

 2     screen.  And I want page 37 in the English, and in the B/C/S this is

 3     page 27.

 4        Q.   And sir, what we are going to see on the screen is a note-book of

 5     General Obrad Stevanovic.  It's a handwritten note-book.  And it might be

 6     a bit difficult for you to read on that screen, so I'm going to go ahead

 7     and read to you some of the points that are raised at this meeting just

 8     to see if this refreshes your memory about this meeting.  The date, as

 9     indicated here in this note-book, is 14 February 1999.  It's a MUP

10     collegium meeting, and among the attendees are the minister, then it

11     says, Rodja.  Rodja was Mr. Djordjevic, correct, that's how he was known?

12        A.   Yes.

13        Q.   Rade.  That would have been Mr. Markovic?

14        A.   Probably.

15        Q.   And then there's Misic, Djuric, Ilic, someone by the name of

16     Danilo, and then it says, myself.  And under the heading "The Minister,"

17     it says:

18             "A plan should be developed for the eventuality of the entry of

19     NATO forces.  Do you see that, sir?  It's the second bullet point after

20     the heading, "The minister."  And then he goes on to say:

21             "Kosovo must not be surrendered at any cost, because no one will

22     be able to take it back."

23             Further down in the page the minister says --

24        A.   It's not here.  I don't see what you've just read out.  First of

25     all, I don't understand whose handwriting is, whose notes are these?

Page 14099

 1        Q.   Sir, this is the --

 2        A.   Who drafted this document?  What is this?  Are these minutes or

 3     what?  Could I be told that, please.

 4        Q.   Yes, I mentioned this when I called the document.  This is the

 5     note-book of handwritten notes of General Obrad Stevanovic.  And I'm

 6     putting to you simply to see if it refreshes your memory of having

 7     attended this meeting and the topics discussed.

 8             MS. KRAVETZ:  I see my learned colleague is on his feet.

 9             JUDGE PARKER:  Carry on for the moment.

10             MS. KRAVETZ:

11        Q.   Sir, so I'm reading out to you the notes General Stevanovic made

12     of this meeting.  He records you as one of the attendees, and it's a

13     meeting that was held on the 14th of February.  And as I mentioned, the

14     reason I'm reading it out is I understand that the copy, as you see it on

15     the screen, is going to be a difficult to read.  So further down the page

16     the minister says:

17             "If they start strikes, we shall have to destroy the terrorists

18     with lightening speed."

19             And turning the page in the English, he is recorded as saying:

20             "We must avoid a civil war (RPO police stations as noted)."

21             Sir, does this refresh your recollection of having attended a

22     meeting in mid-February of the minister's collegium where a plan to be

23     developed in the eventuality of an attack by NATO was discussed and where

24     these other topics was discussed?  Do you recall that, sir?

25        A.   I absolutely do not.  These things somebody wrote are absolutely

Page 14100

 1     untrue.  I can't recognise this handwriting.

 2        Q.   And sir, you maintain that at the level of the collegium of the

 3     minister, you never discussed any sort of plans involving preparations

 4     for or plans of activities to be undertaken by the RJB in preparation of

 5     the NATO offensive?  That is your position; you don't recall that?

 6        A.   It's not that I don't recall it.  Such a collegium meeting was

 7     never held.  I don't know who wrote this with these topics.  I know of no

 8     such collegium meeting.  If this is a note pad of Mr. Stevanovic, these

 9     may have been his preparatory notes for something.  In any case, there

10     was no collegium meeting with these topics, with these stories.

11        Q.   Were you aware, sir, in the middle February 1999 that the RJB was

12     preparing a plan for its units down in the field in Kosovo that would be

13     carried out or launched once the NATO attack began, or in the eventuality

14     that a NATO attack was carried out?  Were you aware that that was being

15     planned?

16        A.   I'm not aware of such a plan.  In all the meetings I attended in

17     the public security sector, such a plan was not mentioned or created.  It

18     simply did not exist at the level of the public security sector.  I

19     attended those meetings, but we did not make up any plans to prevent the

20     forces of the NATO Alliance in case of their attack on our country.  And

21     it's not a police task to deal with that.

22        Q.   Sir, are you saying that you did not even hear a reference to the

23     fact that the RJB was preparing itself for the possibility of a NATO

24     attack and was preparing its units in the field?  You didn't even hear

25     that -- a reference at meetings that there was such a plan?  I'm not

Page 14101

 1     asking if you were personally involved in preparing it.  I'm asking

 2     whether if you don't even recall hearing about this at meetings.

 3        A.   I did not hear of such a plan.  Only on one occasion I think I

 4     saw a dispatch in which the minister issued some such measures.  He

 5     frequently did so without our knowledge, but I never heard of the

 6     existence of such a plan, and I never participated in it.  Whatever this

 7     gentleman wrote has nothing to do with anything.  It's not true.  I don't

 8     even believe it is Obrad Stevanovic's diary.  However, I can't recognise

 9     the handwriting, therefore, I can't say anything with any certainty.

10             JUDGE PARKER:  I think we have gone far enough to allow the

11     witness to give his reaction.

12             Now, Mr. Djurdjic, your concern.

13             MR. DJURDJIC: [Interpretation] I have a procedural objection

14     concerning the use of this document.  It is for the third time that the

15     Prosecutor made use of it.  I was interrupted on all three occasions

16     because these references were presented without providing the author of

17     the document and what the document was about.  Finally, Ms. Kravetz for

18     the first time stated what it is.  I think it is -- this document was

19     supposed to be used for the second time when the accused Djordjevic under

20     different circumstances.  The existence of this diary was denied by the

21     witness, and the Prosecutor dropped that particular witness.  The Chamber

22     allowed the document to be used as an MFI'd document, rather than putting

23     it to any witnesses about what someone wrote in it.  I believe now

24     Ms. Kravetz is -- seems to be finished with it; otherwise, I would have

25     asked for the witness to take his headphones off.  I believe you,

Page 14102

 1     Your Honours, propose that it be MFI'd to have a clear idea of what

 2     questions were to be put to the witness concerning this document, and I

 3     believe the OTP has now gone too far.

 4             JUDGE PARKER:  The document is marked for identification.  It has

 5     been put to more than one witness.  As far as I recall, although I

 6     haven't checked, no witnesses yet identified or accepted it, so it is not

 7     an exhibit, and that's as far as it can be taken by Ms. Kravetz, unless a

 8     witness does accept the correctness of the contents of the document at

 9     some time.

10             Carry on, please, Ms. Kravetz.

11             MS. KRAVETZ:  Thank you, Your Honour.  I do have one more page I

12     want to show of this document, and I'm referring to it for the purpose of

13     trying to refresh the witness's recollection on the issues that we are

14     discussing.

15        Q.   Sir, you just said in all the meetings that you attended in the

16     public security sector, such a plan was not mentioned or created.  Sir,

17     do you recall attending a meeting where finishing touches for a plan for

18     a broad anti-terrorist operation between -- with the MUP involving the

19     MUP and the Pristina Corps was discussed?  Do you recall that?

20        A.   I never attended such a meeting.  Never.

21             MS. KRAVETZ:  This is page 40 in the English, and it's page 29.

22        Q.   And this is a collegium of -- it's dated 16th of February, and

23     it's headed collegium of the chief of the public security sector.  And we

24     see the note there that's been made in this note-book.  It says,

25     number 1:

Page 14103

 1             "In accordance with orders from earlier meetings, measures are

 2     being taken for an action in case of air-strikes or entry by force of

 3     NATO troops in KiM."  That's at the top of the page number 1.

 4             And then it says:

 5             "Together with the Pristina Corps, the finishing touches are

 6     being put to the plan for a broad anti-terrorist operation in the period

 7     between the possible air-strikes and the entry of ground forces."

 8             And then is says:

 9             "Sending all OPJP, PJP, detachments."

10             Does that refresh your recollection, sir, that these matters were

11     being discussed at the level of the collegium of the public security

12     sector?

13        A.   As far as I could understand you seem to have said a moment ago

14     that this was in February 1999.  Now you also said that there was a

15     collegium meeting of the public security sector.  I assert that there was

16     no collegium of the public security sector.  I said a number of times

17     that there was the minister's collegium.  It's a different matter than

18     that at that collegium the public security sector was mostly discussed.

19     The collegium of the public security sector would entail that the chief

20     of the public security sector presided over such a collegium.  Such

21     collegiums did not exist.  Why would there be any?  If we had the

22     minister's collegium where all assistants were present --

23        Q.   My question --

24        A.   I apologise.

25        Q.   My question was very specific.  I'm just asking you whether this

Page 14104

 1     passage that I read out to you refreshes your recollection that this

 2     matters, the fact that there was preparations made for a plan that was

 3     going to be carried out once NATO forces attacked, whether this refreshes

 4     your recollection that these matters were being discussed in -- at the

 5     level of the public security sector.  So I'm actually just looking for a

 6     yes or no, does it refresh your recollection or not?

 7        A.   The answer is no.  If you want me to be brief, then the answer is

 8     no.  And I've just tried to explain some of the reasons.

 9        Q.   I would like to show you another document, sir.

10             MS. KRAVETZ:  This is P85.  If we could have that up on the

11     screen.

12        Q.   And this, sir, the document we'll have up on the screen are the

13     minutes of the meeting of the Pristina MUP staff which you've referred

14     to.  And I just want to read out a passage.  This is the -- these are the

15     minutes of a meeting held on the 17th of February, 1999, and we see among

16     the attendees are Minister Vlajko Stojiljkovic; the public security

17     department chief, Colonel Vlastimir Djordjevic; we also have the RDB head

18     there, General Markovic; and then General Stevanovic and other members of

19     the staff; and the heads of SUPs and of units down in Kosovo.  Do you see

20     that, sir, that these persons are there among the attendees?

21        A.   Yes, I can see it.

22        Q.   And I would like to direct your attention to somewhere towards

23     the bottom off the page.  It's General Sreten Lukic who is speaking here,

24     and he says -- and this is a sentence starting by, "a plan of the RJB."

25     He says:

Page 14105

 1             "A plan of the RJB has been worked out to prevent and thwart the

 2     entry of NATO troops into our territory.  The staff plans when it is

 3     ordered to carry out three mopping up operations in the Podujevo,

 4     Dragobilja, and Drenica areas, and has allotted around 4.000 policemen,

 5     around 70 policemen of the operative group, and around 900 police

 6     reservists.  On Saturday, 20 February of 1999, a meeting of the staff

 7     will be held with police detachment unit commanders for further

 8     consultations about their engagement."

 9             Do you see that, sir, that passage that I just read out?

10        A.   I read it.

11        Q.   And did you, sir, at the time, we are talking mid-February, 1999,

12     know about this plan of the RJB to launch these actions which are being

13     referred to here in this meeting that involves all senior members of the

14     RJB and also the RDB for that matter?  Did you know about this?

15        A.   As far as I understood, this meeting was supposed to be held in

16     Kosovo at the staff in Pristina.  In any case, I did not hear of it, and

17     I did not see any minutes such as these.  I absolutely knew of no plan of

18     the public security sector to prevent the entry of NATO troops into our

19     country.  It is stated here a plan of the public security sector, but

20     this needn't necessarily mean that the plan was discussed at the level of

21     the minister's collegium, and that we talked about it.  I don't know of

22     such a plan.

23        Q.   Sir, we see from the minutes here that other members of the

24     collegium -- we've gone through all the list of members who were in

25     attendance, General Djordjevic and Markovic, also the minister and

Page 14106

 1     General Stevanovic.  Were you not aware, sir, that all these senior

 2     members of the ministry had travelled down to Pristina at the time and

 3     attended this meeting where this plan that was going to be launched was

 4     discussed?  This was not something that you knew about?

 5        A.   I can't recall it after this many years, but I don't think I was

 6     aware of it.  It was not the first time that the minister with a number

 7     of his assistants attended some meetings, but that didn't necessarily

 8     mean that I was aware of them going there discussing any issues.  I

 9     wasn't aware of this meeting, and I wasn't aware of the plan.  Finally, I

10     had my own tasks on which I worked.

11        Q.   And you've told us, sir, that the minister at the start of these

12     collegium minutes, he would update other members about the security

13     situation in Kosovo and events there.  Are you saying, sir, that after

14     the minister and other members of the collegium returned from this

15     meeting in Pristina, there was no mention or reference made at the

16     collegium about the fact that this meeting had taken place and the

17     matters discussed there?

18        A.   He didn't necessarily need to advise us of that meeting and of

19     his presence in Kosovo.

20        Q.   So you are saying you heard nothing about it?

21        A.   I did not.

22        Q.   Sir, I would like to draw your attention to page 3 of this

23     document.

24             MS. KRAVETZ:  If we could see that both in the English and the

25     B/C/S.  I believe in the Serbian, it's somewhere towards the bottom.

Page 14107

 1        Q.   This is the same document, we are still within the minutes of

 2     this meeting, and this is minister Stojiljkovic who is speaking here.

 3             THE INTERPRETER:  Kindly read slowly, thank you.

 4             MS. KRAVETZ:  Yes, my apologies to the interpreters.

 5        Q.   We see somewhere, it's the eighth bullet point, we see the

 6     minister saying:

 7             "Tell the RPO and the people that a civil war must be avoided at

 8     all cost, but that in case of a conflict, not women and children should

 9     be killed, only the aggressor."

10             Do you see that entry, sir?  I think it's somewhere towards the

11     bottom of your page from what I'm seeing in the Serbian.

12        A.   Is this indicate to the RPO and the citizens?  Because I don't

13     see here it being under item 8.  I just see bullet points here.  You said

14     item 8; I don't see it.

15        Q.   No, I said -- maybe it's just a problem of the translation.

16     Eighth bullet point is what I was referring to.  So I take it you've

17     found the one I'm referring to.

18        A.   Yes.  If that is "tell the RPO and the people that a civil war

19     must be avoided at all costs."  Is that what you are referring to?  I can

20     see that.

21        Q.   And in the note-book I had shown you earlier of notes taken by

22     General Stevanovic at the meeting of 14th of February --

23        A.   Please just, just --

24        Q.   Let me finish my question.  In that note-book we saw where we saw

25     the notes of a meeting on the 14th of February, we saw that under the

Page 14108

 1     topics that Minister Stojiljkovic had raised was also the fact where it

 2     said, "we must avoid a civilian war (RPO)."  Do you remember I showed you

 3     that?

 4        A.   I really cannot recall that now, but I would kindly ask to be

 5     told what the RPO is.  RPO.  There were no such organisational forms at

 6     the ministry.  I don't know what it is.  Tell the RPO and the citizens

 7     that a civil war must be avoided at all costs.  Could you please make it

 8     a little bit more accessible to me.

 9        Q.   Mm-hmm.  Based on the evidence we've heard here in this trial,

10     RPO is an acronym that was used for reserve police squads.  Do you have

11     any knowledge of that?  Have you heard about that before, or is this the

12     first time that you see that?

13        A.   I don't understand what that means, the reserve police squads.

14     We, Madam Prosecutor, did not have such reserve police squads.  If I

15     understood correctly what you've said, reserve police squads.  We did

16     have the reserve forces in the detachments of the PJP, but detachments or

17     squads as independent squads of reserve police, we didn't have that.

18             JUDGE PARKER:  Yes, Mr. Djurdjic.

19             MR. DJURDJIC: [Interpretation] I don't have an objection to what

20     Ms. Kravetz said because she said that the way it's being used here.  I

21     have an objection to the interpretation.  RPO are not reserve police

22     squads, but they are reserve police sections or squads.  I don't know how

23     the interpreters are going to translate that.  Well, section.  Now, I

24     think we are having a problem as far as that is concerned.  I'm not going

25     to continue with that.

Page 14109

 1             MS. KRAVETZ:  Your Honour --

 2             JUDGE PARKER:  Thank you for your assistance, Mr. Djurdjic.

 3             MS. KRAVETZ:  Your Honour, I'm going to move on, from that.

 4             JUDGE PARKER:  I was going to say, Ms. Kravetz, I think that

 5     we've allowed you a little more than usual liberty about the questioning

 6     about this item.

 7             MS. KRAVETZ:  Yes.

 8             JUDGE PARKER:  And it would be better if you did move on.

 9             MS. KRAVETZ:  Yes, Your Honour.

10        Q.   Just last point on this document.  I wanted to draw your

11     attention to the bullet point that says:

12             "Approach and engage volunteers carefully, linking their

13     engagement through the reserve police force when assessed necessary."

14             Do you see that bullet point, sir?

15        A.   Yes, I see that.

16             THE INTERPRETER:  Interpreter's note:  The term "odeljenje" as a

17     JNA unit is interpreted as squad in English.

18             MS. KRAVETZ:  Thank you for that.

19        Q.   I want to go to a document that you looked at yesterday.  This is

20     P356.  And this is dispatch number 312 dated 18th February, 1999, and it

21     is a dispatch that was issued by the public security chief,

22     Mr. Djordjevic.  And you told us yesterday -- do you recall seeing this

23     document, sir?  Yesterday, you went through with my learned colleague.

24        A.   Yes, yes, I remember that document.

25        Q.   And you said you participated in the drafting?

Page 14110

 1        A.   I did.

 2        Q.   You also told us that it was signed by Mr. Djordjevic because

 3     various structures within the public security sector were involved in

 4     drafting it.  So you said it was natural for the chief of the sector to

 5     sign one such dispatch and send it prior approval of the minister?

 6     That's what you said?  Do you recall saying that?

 7        A.   I do, yes.  That is right.  This dispatch had to have been signed

 8     by the chief of the public security department because several lines of

 9     work were participating in its drafting.  I took part with the other

10     assistants in the finalisation of the drafting of this document.

11        Q.   And this, just for reference, was at transcript page 14061.

12             Now, you were asked some questions about item 7 of this document.

13             MS. KRAVETZ:  If we could turn to that.  It's on page 3 in the

14     English.

15        Q.   And this is an item that refers to:

16             "Intensifying intelligence and other measures and actions, carry

17     out necessary checks, compile lists, and establish complete control over

18     volunteers and paramilitary units and their members."

19             Do you see that, sir?

20        A.   It doesn't say that in the way you translated it, if article or

21     paragraph 7 is being talked about.  May I read it?

22        Q.   You may read it, yes.

23        A.   "Through intensified intelligence and other measures and actions,

24     carry out the necessary checks, compiling lists, and establish complete

25     control over volunteer and paramilitary units and their members."

Page 14111

 1     Probably you don't see that.  Yes, I saw that.  And I understand it.

 2        Q.   Thank you, sir.  Sir, you would agree with me that this dispatch

 3     reflected what we saw Minister Stojiljkovic had said at the MUP staff

 4     meeting the day before on the 17th of February?

 5        A.   Should I answer that?  May I answer?

 6        Q.   Yes, I was looking for your answer.  I'm asking whether you would

 7     agree that --

 8        A.   Well, earlier you showed me a document or minutes which were made

 9     the day before the dispatch was sent to the field.  You cannot draft a

10     dispatch like this in one day; it takes a few days to draft one like

11     this.  We took several days to draft this detachment, that is one thing.

12             Second, we are talking about operational control here and

13     possibly of volunteers and paramilitary units.  Operations control is

14     something quite different from what was written and what the minister

15     stated at the staff session, because we had the relevant information that

16     organisation, preparation, and possible training and arming of certain

17     people were being carried out in order to organise volunteer and

18     paramilitary units.  So the objective of this dispatch is actually to

19     prevent such conduct.  According to this dispatch, and this speaks a lot

20     about the minister and about what is being noted, and that is that

21     volunteers could possibly be accepted into our force, but volunteers

22     could not be admitted into the MUP forces.  They can do that as

23     individuals if they meet all the requirements, and if they are not

24     military conscripts, and if they were not criminal charged and so on.

25     They can be admitted to the reserve forces, but quite the contrary,

Page 14112

 1     volunteers and paramilitary units, their admission would be illegal.  So

 2     what is the thrust of this dispatch is quite the opposite.  To use

 3     intelligence work to establish who is trying to organise and in what way

 4     they are trying to organise people, training, arming, and so on and so

 5     forth.  The intention here is to prevent such occurrences.  That is why

 6     we have this item 7, because we drafted that.  And what the minister

 7     says, if it was recorded correctly, is something different.  Although he

 8     also says, be cautious and so on.  But in my personal view, the idea is

 9     that such persons can be admitted only if they meet the requirements to

10     be admitted into the reserve forces of the MUP.

11        Q.   Sir, we what saw that the minister had said the day before, in

12     fact, was, "approach and engage volunteers carefully, linking their

13     engagement through the reserve police force when assessed necessary."  So

14     the minister was actually speaking at this MUP staff about the engagement

15     of volunteers in the reserve force of the MUP.  He was not speaking about

16     preventing volunteers from joining the MUP, was he, sir?

17        A.   Yes, you quoted correctly what he said, but what I'm telling you

18     is that has to do with paragraph 7 from this dispatch, which is quite the

19     opposite, which instructs, calls for, and requires something quite

20     different.  I don't really have the right now to interpret the words of

21     my minister and his opinions, and I don't know how what he said was

22     actually taken down, but I did explain that there is a major difference

23     that we are seeing here.

24        Q.   I want to show you another document.

25             MS. KRAVETZ:  This is P702.  If we could have that up on the

Page 14113

 1     screen.

 2        Q.   And I should point out, sir, that the Serbian copy, the original,

 3     the way it appears in the system is quite difficult to read, so I'm going

 4     to just take you through this document and ask you to bear with me.

 5             So this is a dispatch, number 631, dated the 24th of March, 1999.

 6     So this is the eve of the NATO intervention.  And you will see from the

 7     heading that it is, in fact, sent to almost all senior police in the

 8     country, we see the headquarters of the public security department,

 9     organisational unit.  It says, to the chief, all of the secretariats of

10     interior, 1 through 33, the MUP staff, and then also traffic police

11     stations.  Those are the addressees.  And we see from the first paragraph

12     of this document that it refers to -- it says:

13             "It is necessary to intensify the enforcement of measures that

14     were ordered as per our dispatch number 312 of the 18th day of February,

15     1999."

16             This is in fact, sir, the dispatch we just looked at; no?  It's

17     dispatch number 312 from the 18th of February.

18        A.   I don't see that, but it must be so if you say that.

19        Q.   Yes, I apologise for the quality of the document.  So number 5 of

20     this document has the following instruction from the minister.  And I

21     should point out this is a document signed by minister

22     Vlajko Stojiljkovic.  It says, number 5:

23             "You should register all volunteer and paramilitary units and

24     their members and keep them under control in case that you might you need

25     to engage them."

Page 14114

 1             Sir, this dispatch, as we see from the document itself, follows

 2     from the instructions that were issued on 18th February, and for that

 3     matter, also the day before 17th February by the minister; no?

 4        A.   No, that does not necessarily mean that.  Because, first of all,

 5     he referred to the intensification of all the measures from the

 6     dispatch 312, I think that you mentioned that before, if that relates to

 7     that.  Intensification of all measures from dispatch 312 where these

 8     measures are laid down.  And then besides that, he is now giving some

 9     more concrete assignments.  Have we understood each other?  He is

10     speaking about the intensification and the implementation of measures

11     from that dispatch, and now again instructs.  I cannot see that very

12     well, but he is saying in the case of aerial attack and so on and so

13     forth, which was not said in the previous dispatch.  What was written

14     here, that cannot stand.  That is counter to the law, please, to have

15     paramilitary or any other kind of unit engaged in the ministry.  As far

16     as I can see, I think they are primarily thinking of the registering and

17     engagement of these people through the reserve force if they are meeting

18     the requirements to be admitted into the reserve force and for that

19     reserve force, due to increasing problems, to be expanded and manned by

20     appropriate units.  I cannot comment that in any other way.

21             Thus, he is saying that this needs to be done carefully.  That

22     does not mean that all possible volunteers who would apply would

23     necessarily be admitted into the reserve forces.  It is well known who

24     can be admitted into the reserve forces; that could be a person meeting

25     the requirements, just like any employee who is being admitted or

Page 14115

 1     accepted for employment at the ministry.  This would be my answer.

 2        Q.   Sir, based on these three documents we've seen, would you agree

 3     with me that far from seeking to prevent the entry of volunteers and

 4     paramilitary units into the MUP in the event of a NATO attack, what MUP

 5     minister Stojiljkovic and the public security chief General Djordjevic in

 6     his previous dispatch are saying, is that they are trying to make use of

 7     volunteers and paramilitary units, and they are ordering for the ministry

 8     to exert control over them.

 9        A.   No, that is not correct.  That would be your conclusion.  I told

10     you earlier what it was about, especially in terms of dispatch 312 where

11     it is clearly said -- well, look, must be placed under control in order

12     for them not to be organised, trained, armed, and in order that they

13     don't go to some area.  Therefore, that dispatch is absolutely contrary

14     to these other two documents, this dispatch by the minister and what he

15     said at some meeting of the ministry staff.

16             This does not necessarily mean that they would be admitted.  I

17     mean, I would just like to note that this would be an illegal order for a

18     paramilitary unit to be admitted to the ministry.  Eventually or possibly

19     individuals can be accepted to serve, but only those who meet the

20     requirements for admission into the reserve force.

21        Q.   Sir, but you would agree with me that what minister Stojiljkovic

22     is saying in this dispatch we are seeing here, and this is the last part

23     of point 5, is that -- is says:  "Keep them under control in case that

24     you might need to engage them."  So he is speaking about the engagement

25     of volunteer and paramilitary units, isn't he, sir?

Page 14116

 1        A.   You are correct when you read that this is what it states, that

 2     this is what is written.  But the question is actually the actual

 3     interpretation.  I'm saying that volunteers and paramilitary units cannot

 4     be admitted to serve in the ministry.  This is one thing.  The second

 5     thing is volunteers have to meet the general requirements if they wish to

 6     be admitted to the reserve force.  And these conditions are quite clear.

 7     You need to absolutely meet the requirements in the same way that you

 8     would immediate to meet the requirements in order to be eligible for

 9     employment in the ministry.  This is also a little bit --

10        Q.   And you noted just now that it would -- you said I would like --

11     just like to note that this would be an illegal order.  Were you aware,

12     sir, of the intention of General Djordjevic to engage a paramilitary unit

13     or volunteers within the ranks of the MUP or in the MUP?  Were you aware

14     of that intention?

15        A.   No, I was not aware of that.  I'm hearing this for the first time

16     now, this that you are saying.  I think that I would have known if

17     something like that was happening.

18        Q.   And how would you have known that, sir?  Was this something that

19     you would have heard about at the meetings of the collegium that you

20     attended, or how would you have found out about it?

21        A.   Only in that way.

22        Q.   Sir, you told us yesterday - and I'm moving away from this

23     document now - that -- and please correct me if I'm stating your position

24     wrong, that during the conflict in 1999, you were in the same building as

25     Mr. Djordjevic.  Your office was in the same building as his.

Page 14117

 1        A.   Yes, I did say that we were at the locations, minister as a rule,

 2     Djordjevic, myself.  At some locations there were other senior officers.

 3     Specifically here I was thinking at the commercial bank where I was

 4     together with them, with the cabinet and so on.  But there were other

 5     senior officers at some other locations together with us.

 6        Q.   And during the war in 1999, how often would you see

 7     General Djordjevic?

 8        A.   During the war in 1999, I would see him quite often.  I would see

 9     him quite often for the simple reason that we had to co-operate because

10     there was an enormous number of events taking place, so if we needed to

11     consult, to make decisions, to inform the minister, the government and so

12     on, this had to be done.  Unfortunately, we functioned as the best

13     ministry, in a way, and managed to achieve what others did not.  We were

14     practically together on daily basis.

15        Q.   And, sir, you said that you have to consult with him and you

16     would see him on a regular basis.  But other than meeting with him on

17     matters that concern your lines of work, you wouldn't attend meetings

18     that General Djordjevic had with other members of the MUP unless the

19     topic discussed concerned the lines of work that you had; correct?

20        A.   I'm sorry, I don't understand the question.

21        Q.   I'll put it in a simpler way.  Maybe that was a rather

22     complicated fashion.  You've told us that you had regular contact with

23     General Djordjevic in 1999, correct, that's what you've said?

24        A.   Yes.  Yes.

25        Q.   What I'm putting to you is that you wouldn't be present at

Page 14118

 1     meetings General Djordjevic had with other senior MUP officers when the

 2     purpose of the meeting fell outside the scope of your lines of work?

 3     Those wouldn't be meetings that you would have attended?  I'm leaving

 4     aside collegium meetings that we've spoken about already.

 5        A.   Probably.  I don't know how to answer that question.  There were

 6     always some meetings, some agreements.  I did not necessarily have to

 7     attend each such meeting myself.  I don't know how to answer that

 8     question.

 9        Q.   You met with him for matters that concerned your lines of

10     administration, your lines of work; correct?

11        A.   Yes.  First of all, I was accountable to the minister because he

12     constantly required me to contact government members and get in touch

13     with the ministries, the various ministries because we were in great

14     danger.  And very frequently I would be given assignments by the

15     minister.  Of course, it was natural for me to see and to meet with

16     General Djordjevic.  I don't know if he ever had any agreements with

17     others.  I am sure he did meet with those who were dealing with other

18     professional lines of work.  And I attended some meetings like that, even

19     though these were different lines of professional work, but see the

20     situation was such that it was necessary to take an interdisciplinary

21     approach, and you constantly had a number of professional lines of work

22     involved.  If a building was bombed, you had to immediately engage

23     the police to secure the site.  The fire-fighting unit had to be

24     there immediately to deal with fires.  The appropriate machinery of

25     public utilities had to be sent immediately to clear up the site. 

Page 14119

 1     Medical emergency services had to be sent out in order to rescue people

 2     and provide first aid.  So we constantly had to be in touch.  I don't

 3     know if I answered this question well.  I mean, I don't know, this is how

 4     I understood the question.

 5        Q.   You were not present at each and every meeting that

 6     General Djordjevic had with senior officers of -- officials of the MUP?

 7        A.   Probably.  I don't know what to say.  Could you tell me which

 8     senior officials of the MUP?

 9        Q.   If General Djordjevic met, for example, with Obrad Stevanovic or

10     with the minister or with other members of the collegium or any other

11     senior -- [overlapping speakers]

12             You weren't present --

13        A.   Well, it wasn't necessary for me to be present during every such

14     meeting.

15        Q.   You were also not privy to the telephone conversations

16     General Djordjevic had with other members of the MUP, be that at the

17     level of Belgrade or Kosovo.  You were not privy to the telephone

18     conversations he had?

19        A.   I was not.  No, I was not.  I wasn't privy to it.  I don't know

20     of it.

21        Q.   And if General Djordjevic and minister Stojiljkovic met with

22     other members of the senior Serbian leadership at the time, for example,

23     President Milosevic outside of the premises of the MUP, these would not

24     have been meetings that you would have attended; no?

25        A.   No, I never attended such meetings.  I went to see

Page 14120

 1     President Milosevic a few times having do with certain ceremonies, but

 2     other than that I never attended any such meetings.

 3        Q.   And, sir, you were never in Kosovo in 1999; no?

 4        A.   No.  In 1999 I was not in Kosovo and Metohija.

 5        Q.   You were, in fact, never in Kosovo in 1998 either, were you?

 6        A.   That is true.  I wasn't in Kosovo in 1998 either.

 7        Q.   Now, sir, so can we agree that your contacts with

 8     General Djordjevic were limited to the matters that concern your areas of

 9     work, that is, when you had dealings with him?

10        A.   Yes, we can.

11        Q.   Now, sir, I want to show you a document that you spoke about

12     yesterday.

13             MS. KRAVETZ:  This is P57.  If we could have that up on the

14     screen.

15        Q.   And this, sir, I think you'll recognise the document, because you

16     went through it in quite some detail yesterday.  It's a decision dated

17     16th of June, 1998, establishing an expanded MUP staff of Kosovo, and

18     it's signed by Minister Stojiljkovic.  Do you recall going over this

19     document yesterday with my learned colleague?

20        A.   Yes, I recall that.

21        Q.   And you told us yesterday that you were acquainted with this

22     document by the minister at one of the minister collegium meetings.  He

23     spoke about it at one of the meetings?

24        A.   Can I answer now?

25        Q.   Yes.

Page 14121

 1        A.   I apologise.  Yes, I remember that.  That is correct.

 2        Q.   And yesterday you explained the document; no?  You went over it

 3     and you read the different sections out and spoke about the -- what you

 4     understood the tasks of the staff to be pursuant to this order; correct?

 5        A.   Yes.  This is what I did.

 6        Q.   Now, when you were going over the document yesterday, my learned

 7     colleague drew your attention to number 3, Roman numeral III.

 8             MS. KRAVETZ:  Maybe we could have that back up on the screen just

 9     so the witness could see it.  It's on the next page.

10        Q.   And you said -- I'm just going to wait for it to come up in the

11     Serbian as well.  And you said - and this is at transcript page 14039 -

12     with regard to this number 3 Roman numeral III:

13             "That deals with the fact that the head of the staff shall report

14     to the minister about his own actions, actions of the staff, and the

15     aspects of the security situation under the remits of the staff and also

16     about informing the minister about security related developments,

17     measures taken, and the effects of the measures."

18             Do you recall saying that, sir?

19        A.   Yes, I recall it.  This is what item 3 says.

20        Q.   And you also told us in connection with this, that you, yourself,

21     personally never received any reports about the work of the staff, nor

22     did you see any such reports.

23        A.   I said as follows:  That I never saw any plan ever concerning the

24     organisation of anti-terrorist activities.  I also said that I never saw

25     or received a report on the implementation of such activities.  What I

Page 14122

 1     did say was that I received daily reports, the so-called daily summaries

 2     of events and incidents from certain areas.  From among others,

 3     Secretariats of Internal Affairs, these arrived in the ministry through

 4     the operations centre and then the officials would be acquainted with it.

 5     There were also daily bulletins, daily information from the staff on

 6     security-related events and incidents in Kosovo and Metohija.  I did say

 7     that I received such daily reviews and that I was acquainted with them.

 8        Q.   Sir, you were among the recipients of these daily reviews, no, up

 9     to the commencement of the NATO bombing campaign; no?

10        A.   I can't recall.  Perhaps you could remind me.  I received such

11     daily reports all the time.  Since the minister decided who was to

12     receive such staff reports, it was clearly indicated, and that was the

13     way they were distributed.  I was one of the addressees.  If my name is

14     missing, then I received such reviews from the minister or his cabinet.

15     Throughout 1998 and 1999, I was informed of such daily reviews of

16     incidents and events from Kosovo and Metohija from the staff.

17        Q.   Is there a reason, sir, why your name was taken off the list of

18     recipients once the war started and that you only got these daily reports

19     through the cabinet of the minister?

20        A.   There was no reason.  I was always close by where the minister

21     was, and I was always informed of it.  The intention was probably to

22     shorten the list because of the war.  There was no reason why they should

23     not inform me of such events and incidents.  It's not as if they stopped

24     trusting me all of a sudden.

25        Q.   And I wasn't suggesting that, sir, at all, I was just being --

Page 14123

 1     asking why that was the case.

 2             Sir, you just said that you never saw any plan concerning the

 3     organisation of anti-terrorist activities and you also say that you never

 4     saw or received a report on the implementation of such activities.  Isn't

 5     it true, sir, that the reason that you didn't see any plans about these

 6     activities and you also did not receive any reports about the

 7     implementation of these activities was because this actually fell outside

 8     of the realm or the scope of your lines of work?  You were dealing with

 9     fire-fighting, communications, and travel documents and alien affairs, so

10     this fell outside the scope of your line of work, no, sir?

11        A.   Well, one could interpret it that way, too, although I was held

12     in high regard among the assistant ministers and there was no particular

13     reason why the minister would not inform me.  It is true, though, that I

14     was mostly busy with the lines of work you've just specified, and that

15     these were not the truly operational lines of duty.  Irrespective of

16     that, however, I believe I was always fair in terms of my conduct and

17     that I enjoyed sufficient trust.

18        Q.   Sir, I'm not suggesting here -- and please don't misunderstand me

19     that this was due to a matter of lack of trust from the minister.  What

20     I'm suggesting to you is that the planning of anti-terrorist operations

21     and -- was something outside the scope of your work.  You were dealing

22     with fire-fighting, communications, and foreigners and travel documents.

23     That's what I'm suggesting to you, sir; isn't that correct?

24        A.   That is correct.  That is correct, that is these were the lines

25     of duty I was occupied with.  It wasn't necessary for me to know

Page 14124

 1     everything or to be informed of everything, but I discussed the collegium

 2     as a method and means of work, where as a rule, everything that was of

 3     importance was discussed at its meetings.

 4             I learned of information mostly through such channels and for

 5     those reasons; otherwise, no one was under any obligation to send any

 6     plans or reports to me.  Finally, one can see in the decision who was

 7     supposed to be held accountable to whom and for what.

 8        Q.   Sir, based on what you told us earlier when I was asking you

 9     about your contacts with General Djordjevic, you wouldn't have known,

10     sir, would you, if Mr. Djordjevic received any kind of reports from

11     Mr. Lukic, the head of the MUP staff, concerning these operations?  That

12     was not something you would have known about.

13        A.   It wasn't necessary that I knew about it, but in all likelihood,

14     I would have because we were in the same area, very frequently we talked,

15    agreed on things, and I would have learned of some reports or plans of his

16    if we had any.  He didn't have to report to me what he was doing, though.

17        Q.   And you've told us --

18        A.   But I didn't know.  Please go ahead.

19        Q.   Yes.  In fact, you did not know if that was going on.  You did

20     not know if Mr. Lukic, in fact, was reporting to General Djordjevic about

21     anti-terrorist operations that were taking place in Kosovo.  That is

22     something you would not have known, sir; no?

23        A.   Having in mind the decision issued by the minister --

24        Q.   Sir, sir, sir, I'm asking you about your knowledge.  You told us

25     that you were not privy to his -- the telephone conversations that

Page 14125

 1     Mr. Djordjevic had, that you only attended meetings that concerned your

 2     lines of work, so if -- and you were not present at other meetings

 3     General Djordjevic -- or at every meeting General Djordjevic had with

 4     senior officials of the MUP.  So based on that, sir, you wouldn't know if

 5     General Lukic from the MUP staff was, in fact, sending reports and

 6     informing General Djordjevic about anti-terrorist operations that were

 7     being conducted in Kosovo.  You would not know that, sir; no?

 8        A.   Well, you see, I explained a moment ago concerning the meetings.

 9     It did not only have to do with my line of duty.  I frequently attended

10     those meetings in the company of other officials in the ministry, and I

11     said that I did not attend any meetings outside the ministry when the

12     minister decided on who among the assistant ministers would accompany him

13     to such meetings.  And the ministry, I was predominantly busy with my

14     line of work.  However, I was present there.  Certainly I wasn't privy to

15     all of his telephone conversations, and I could not have been present

16     everywhere at all times.

17        Q.   Sir, you told us that -- I asked you, Can we agree that your

18     contacts with General Djordjevic were limited to the matters that

19     concerned your areas of work; that is, when you were dealing with him?

20     And you said, Yes, we can.

21             So, sir, what I'm putting to you is that your knowledge -- that

22     you would not have known if General Lukic was, in fact, contacting

23     General Djordjevic and communicating with General Djordjevic and

24     reporting about matters concerning anti-terrorist operations taking place

25     in Kosovo?  That's what I'm putting to you, sir.  You would not have

Page 14126

 1     known that, if that was happening.

 2        A.   I think I would have definitely known something at least.  Not

 3     everything, but I would have heard or seen things.  Of course, however, I

 4     could not have been present during his telephone conversations with

 5     people.  I don't really know how to answer this question.

 6        Q.   Sir, earlier I put to you the minutes of a meeting of the MUP

 7     staff on 17th of February, which was attended by Minister Stojiljkovic,

 8     General Djordjevic, General Markovic, Stevanovic, and other high-ranking

 9     officers, where discussion took place about a plan of the RJB that was

10     going to take place, and you told me you had never heard about it

11     essentially.  That was the first news you had that the RJB was making

12     these plans to carry out these actions in the eventuality of a NATO

13     attack.  So, in fact, your knowledge of the contacts that

14     General Djordjevic was having with the MUP staff and the work he was

15     conducting with the MUP staff are very limited, sir, aren't they?  In

16     fact, you didn't know what it was that was happening in this respect and

17     what concerned planning of anti-terrorist operations.  Isn't that

18     correct, sir?

19        A.   I didn't know of such terrorist [as interpreted] operations, but

20     at collegium meetings, given that in 1999 I was with Djordjevic all the

21     time, I would have known whether he had received any reports and whether

22     any plans had been drawn up and what those plans were.  We were together

23     all time and there were collegium meetings.  I was not outside the

24     ministry building with him.  But inside, we were together all the time.

25        Q.   So, sir, despite being together with him all the time, it is

Page 14127

 1     quite surprising, I put to you, that you had no knowledge of this plan

 2     that was discussed at the MUP staff meeting of the 17th of February where

 3     all other senior members of the MUP were there, including senior members

 4     ever the RJB.  The truth is, sir, that you did not know about what sort

 5     of involvement General Djordjevic had in the planning of any

 6     anti-terrorist operations that involved the RJB in Kosovo.  You did not

 7     know that.

 8        A.   I absolutely didn't know that Djordjevic in any way participated

 9     in the planning and execution of anti-terrorist activities in Kosovo and

10     Metohija.  I absolutely did not know of him receiving any reports on the

11     implementation of such anti-terrorist operations.

12             MS. KRAVETZ:  Your Honour, I see my learned colleague is on his

13     feet.

14             JUDGE PARKER:  Yes, Mr. Djurdjic.

15             MR. DJURDJIC: [Interpretation] Maybe a prosaic note, but on

16     line 19, page 62, it should have been anti-terrorist instead of

17     terrorist.

18             JUDGE PARKER:  Thank you.

19             MS. KRAVETZ:  Your Honour, I see we've past the time for the

20     break, so ...

21             JUDGE PARKER:  We will have the second break now and resume at

22     five minutes past 6.00.

23                           [The witness stands down]

24                           --- Recess taken at 5.36 p.m.

25                           --- On resuming at 6.07 p.m.

Page 14128

 1                           [The witness takes the stand]

 2             JUDGE PARKER:  Yes, Ms. Kravetz.

 3             MS. KRAVETZ:  Thank you, Your Honour.

 4        Q.   Sir, I just want to finish off on this topic we were just

 5     discussing.  Right before the break you told me that you absolutely did

 6     not know that Djordjevic in any way participated in the planning and

 7     execution of anti-terrorist activities in Kosovo and Metohija, and you

 8     also said you did not know of him receiving any reports on the

 9     implementation of such anti-terrorist operations.

10             Sir, are you aware that during the summer of 1998 while this

11     large-scale offensive we spoke about earlier was being carried out by the

12     MUP and the VJ, General Djordjevic was in Kosovo practically on a

13     permanent basis?  Are you aware of that?

14  A.  Yes, I am aware of that, and this is something that the minister told us

15   as well, that sometime in mid-July, as far as I can recall, he was assigned

16   together with General Obrad to go to Kosmet.  And he spent, as far as I can

17   remember, some period there until the end of September or beginning of

18   October.  So I am aware that Chief Djordjevic spend sometime in Kosmet.

19        Q.   And, sir, General Djordjevic testified in these proceedings, and

20     at transcript page 9791, he explained his role, down there, to the Court,

21     and he says:

22             "When I was in Kosovo, I was not merely an observer.  On the

23     order of the minister, it was my task to get involved and to provide

24     assistance in the activities being carried out down there and to give my

25     contribution to the success of the anti-terrorist activities, so I was

Page 14129

 1     not merely an observer down there.  Were you aware that was his role,

 2     that's why he was sent down there to Kosovo?

 3        A.   As far as I know and in the way the minister explained it, since

 4     this is an exceptionally complex situation we are talking about with an

 5     extremely large number of policemen participating there in the

 6     suppression of terrorism, he said that he sent General Djordjevic and

 7     General Stevanovic to assist the staff in the suppression of terrorism.

 8     I'm not familiar in more detail about what they were doing there and how

 9     they were doing it.  I know that there was a staff and that the staff was

10     responsible for the suppression and combat against terrorism, and that

11     they, in some way, were helping for this assignment to be carried out.

12        Q.   So what you know about his role in 1998 when he was in Kosovo, is

13     just based on what the minister told you.

14        A.   Yes.  For the most part.  I mean, not for the most part but based

15     on what the minister said that their role was there.  They were in touch

16     with the minister, the minister would be issuing them instructions and so

17     on and so forth.  Therefore, I did not specifically go there, and I did

18     not have the possibility of acquiring information in another way, but

19     what I do know is that the staff there planned, organised, and led

20     anti-terrorist actions, and that they were there to encourage, to help

21     those forces as they were executing that assignment.  Because, as I

22     remember, there were also some politicians there and they were supposed

23     to maintain contacts with them as well, and to be in the function of the

24     execution of the assignment.

25             MS. KRAVETZ:  My learned colleague is on his feet.

Page 14130

 1             JUDGE PARKER:  Mr. Djurdjic.

 2             MR. DJURDJIC: [Interpretation] If we can just get a reference for

 3     the things quoted by Ms. Kravetz about what the accused, Mr. Djordjevic,

 4     said in his testimony, please.

 5             MS. KRAVETZ:  I see that the reference is not indicated in the

 6     transcript.  It's 9791, and this answer starts at line 11 of that page.

 7        Q.   Sir, so just to be clear, your knowledge of Mr. Djordjevic's

 8     involvement during the conduct of these anti-terrorist operations in the

 9     summer of 1998 [realtime transcript read in error "1999"] you said were

10     based on what the minister told you, and you did not have any details as

11     to what he was actually doing there?  You do not have the details of what

12     tasks he was performing.

13        A.   Of course I know what the minister instructed us to do.  In our

14     conversations when we he would see each other we would discuss some

15     things, but nothing specific.  He would talk about the situation, that it

16     was difficult and so on and so forth, but in our conversations, he never

17     specifically said that he actually planned or organised anything there,

18     just that he was monitoring and that there was some major problems about

19     the of confiscation of weapons, and so on and so forth.  He actually

20     didn't tell me anything specific about the matters that you are asking me

21     about.

22        Q.   And, sir, isn't it fair to say that the reason that you stated

23     earlier that you absolutely did not know that Djordjevic in any way

24     participated in planning and execution of anti-terrorist activities or

25     that he received reports, the reason you stated that was because, in

Page 14131

 1     fact, you did not have more information than that which was provided to

 2     you by the minister?  You did not know the details of the job that

 3     Mr. Djordjevic was carrying out on the ground.

 4        A.   I'm just talking about what the minister said to us.  I am

 5     talking about what was at the collegiums because these are my main

 6     sources of information.  I have no other way to know things because I was

 7     not in KiM, and I cannot really talk about things that I don't know

 8     about.  My information also comes from reports.  Actually, these are not

 9     reports, but just daily bulletins about daily events.  No one spoke about

10     the chief of the department being in command and control of anything

11     there, not even the minister said anything like that.  What he did say

12     was that he was in contact with him and Obrad in the sense of assistance

13     to the staff so that the assignments would be carried out.  This is all I

14     can talk about because I was not in Kosmet and cannot really say anything

15     in particular in detail.

16        Q.   Thank you for that.

17             JUDGE PARKER:  Before we lose sight of it, page 66, line 7, it

18     should be summer of 1998, not summer of 1999.

19             MS. KRAVETZ:  Yes, I see, it's been incorrectly recorded.

20        Q.   Sir, I want to move away from this topic and ask you about

21     another aspect of your testimony you gave yesterday.  Yesterday when you

22     were speaking about receiving dispatches from the MUP staff, these daily

23     dispatches that of we've already spoken about today, you said, and this

24     is at transcript page 14043:

25             "When the NATO aggression against our country began, we were

Page 14132

 1     faced with a situation in which many Albanian citizens as well as Serbian

 2     citizens and other non-Serbs began leaving Kosovo and Metohija en masse."

 3             And then you went on to say, "it was of great concern for us."

 4             And you said:

 5             "We were able to verify that a large number of people were

 6     leaving the country.  And the minister stated that first and foremost it

 7     came about as a result of the bombing, in fear of the bombing."

 8             A second reason you gave was fear of being caught in a clash

 9     between security forces and terrorists.

10             And then the third reason you gave was as a result of propaganda

11     activity undertaken in order to put an image of a humanitarian disaster.

12             Do you recall speaking about this, sir, yesterday, giving that

13     evidence?

14        A.   Yes, I do recall speaking about that.

15        Q.   And your basis for stating that these were the reasons that the

16     population, and I specifically have in mind the Kosovo Albanian

17     population, was leaving Kosovo was based on information that you received

18     from the minister.

19        A.   Yes, that's correct.

20        Q.   You did not have any first-hand knowledge of why Kosovo Albanians

21     were fleeing Kosovo in great numbers, as you said, in 1999?  You did not

22     know that?

23        A.   See, we knew that the minister was absolutely informed about the

24     events in Kosmet because he was constantly receiving reports, on the one

25     hand.  On the other hand --

Page 14133

 1        Q.   Sir, I'm just going to stop you there.  I'm asking whether you

 2     had first-hand knowledge, whether you had personal knowledge of why

 3     Kosovo Albanians were fleeing Kosovo in great numbers in 1999.

 4        A.   I would have first-hand information about that had I been staying

 5     there.  I did not go there, but that is why we had our forces, our men,

 6     organisational units, which were informing us about what was going on in

 7     the field.  Practically we, in my view, had very good information because

 8     we, as leaders, cannot be in all parts of the field in order to know what

 9     was happening.  We had, thus, responsible people who were obliged to

10     inform us.  Thus, besides the minister, you also had the daily reviews,

11     overviews from the chief of the secretariat.  There was information from

12     the staff.  All of these were sources of information.  We had chiefs of

13     the administrations who were in contact with those people down there, so

14     this was in -- information in different ways.  You can cannot just speak

15     about the minister.  The minister would actually be at the place where

16     all this information would flow, like a central place.  So basically I

17     referred to this yesterday.  We are simplifying things.  And were I down

18     there, then I would know what the situation was like close up, that it

19     was exceptional, then this would be something else.  But you must

20     understand that we had in front of us a state organ, very organised one,

21     very capable one, and responsible persons whose duty it was to report

22     back and register all the events in the field and inform the ministry

23     about them.  These are the reasons --

24        Q.   Sir, yes, I didn't mean to interrupt your answer.  You can

25     complete it.

Page 14134

 1             You were saying that these are the reasons ...

 2             JUDGE PARKER:  The Chamber would comment that the answer to the

 3     last question was obviously, No.  But so far there are 18 lines of

 4     transcript in answer to the question, and you are just being invited to

 5     say more.  The question was simple:  Did you have first-hand knowledge?

 6     And the answer, from everything you say, is, No.  We are conscious of

 7     time, trying to ensure that your evidence finishes today.  It would

 8     assist if you could try and respond briefly and accurately to the

 9     question that's put to you.  Thank you.

10             THE WITNESS: [Interpretation] Your Honour, allow me just to say I

11     know what direct means.  Immediate.  First-hand.  If first-hand means

12     that I was there and that I saw that, then the answer is no.  If it means

13     that I was receiving information from the service, then the answer would

14     be different.

15             MS. KRAVETZ:

16        Q.   Sir, just to follow-up on part of your earlier answer, you said

17     that you were receiving daily dispatches or overviews from the MUP staff

18     and these dispatches contained information about the daily number of

19     persons crossing the border, heading outside of Kosovo; no?  It was a

20     daily count in these dispatches.

21        A.   Yes.

22        Q.   So based on your review of these dispatches at the time, you

23     would have been aware that by the end of April 1999, the MUP staff was

24     reporting that over 700.000 Kosovo Albanians had left the area of Kosovo;

25     no, sir?

Page 14135

 1        A.   Yes.

 2        Q.   Now, sir, in this court we heard the testimony of numerous

 3     Kosovo Albanians who were in the province during this period, and these

 4     are persons from all walks of life within that community.  And they have

 5     told the Court that the reason they fled the province during the period

 6     we are speaking about in 1999 was not for any of the reasons that you

 7     have given, but it was because they were forced to leave their home by

 8     members of the MUP and the VJ.  Had you heard about that, sir?

 9        A.   Yes, I did hear of that, but on the other hand, one can ask the

10     question why a large number of people also fled from different areas of

11     Serbia.  They fled abroad.  On the other hand, one can ask the question

12     why the families of our workers were fleeing Kosovo.  And we were

13     actually insisting, the leadership was insisting for them to stay down

14     there so that the people would not feel threatened.  If members of their

15     families fled, then the others would flee too.  People were fleeing from

16     the central parts of Serbia as well, fleeing from the bombing.  That is

17     definitely one of the reasons.

18             I am not disputing that perhaps things that you mention also

19     happened, because there's testimony to that effect.  I'm just saying what

20     I know and what I was informed about.  If I was informed wrongly about

21     these things, then that's quite a different matter.

22        Q.   You said in answer to my question, Yes, did I hear that.  When

23     did you hear that for the first time, that members of the MUP and VJ were

24     forcing Kosovo Albanians out of their home and out of Kosovo in 1999?

25        A.   I heard that after the war in 1999.  I think primarily from the

Page 14136

 1     press.

 2        Q.   And before that during the war you are saying you never heard

 3     about any allegations involving the MUP and the VJ forcibly expelling the

 4     Kosovo Albanian population from Kosovo?

 5        A.   I didn't hear that during the war, and I didn't know of that, no.

 6        Q.   I would like to bring up P42.  And this is, sir, an indictment

 7     that was issued by this Tribunal on the 22nd of May, 1999, and I believe

 8     it became public some days after that in May.  And among the indictees

 9     are President Milosevic; Minister Stojiljkovic; Mr. Ojdanic, the head of

10     the VJ General of staff; and Mr. Sainovic, who was -- I don't --

11     prime minister at the time.  When did you become aware, sir, or did you

12     become aware that these persons were indicted by this Tribunal?

13        A.   I cannot remember exactly when, but I did hear that in the press.

14     And later, on one occasion, the minister said that he had been indicted.

15        Q.   So the minister mentioned to you that he had been indicted by

16     this Tribunal?

17        A.   Yes.  On one occasion he said that an indictment was issued

18     against him, but he made light of it, let's put it that way.  He said

19     that it was a matter of propaganda, pressure by NATO forces, and so and

20     so forth.

21        Q.   Was this during a collegium meeting that the minister informed

22     you of this, or was it a personal conversation you had with him?

23        A.   I think this was a kind of informal conversation, and he did not

24     show it or attach any importance whatsoever to the indictment.

25        Q.   And did the minister tell you anything about the charges included

Page 14137

 1     in this indictment against him?

 2        A.   He did not offer any further comment.  He only said that it was

 3     all a matter of propaganda and pressure on him, and the state leadership

 4     by NATO forces.

 5        Q.   Did you try to obtain a copy of this indictment and have a look

 6     at it to see what sort of charges were being raised against your boss,

 7     the minister?

 8        A.   No, I did not try to do that, and I could not have obtained it.

 9        Q.   Sir, are you aware that that indictment included charges for

10     crimes committed by forces of the MUP in Kosovo during the war in 1999?

11        A.   At that time I presumed it to be so, but I truly wasn't familiar

12     with it until the trials actually began here.

13        Q.   And why is it, sir, that you presumed it to be so?

14        A.   What?

15        Q.   I asked you if you were aware that the indictment included

16     charges for crimes committed by the forces of the MUP in Kosovo during

17     the war in 1999, and you said, At that time I presumed it to be so.  And

18     I'm asking you why it is that at the time when the indictment was issued

19     you presumed it to be so, that these were the charges in the indictment?

20        A.   Because the foreign press and media speculated about that, and

21     they reported about that.  I did not see the indictment to see what was

22     what.

23        Q.   Sir, just explain something to me.  So your boss, the minister,

24     with whom you have told us you worked so closely together and to whom you

25     reported, gets indicted by an international tribunal, and you are telling

Page 14138

 1     us that you were not even interested in finding out what these charges

 2     really were that were being raised against him and what this indictment

 3     was about?  Really, is that what you are telling the Court?

 4        A.   What you've just said is not true.  You turned my words around.

 5     I didn't say that it wasn't that I wasn't interested, but I did not have

 6     such information and indictment readily at hand.  He had the indictment.

 7     As I said, first of all, he did not discuss the indictment.  And

 8     secondly, he said that it was all pressure and propaganda.  Even if I had

 9     been interested, how could I have obtained that indictment, other than

10     taking it from his office?

11        Q.   And you didn't think of asking him for a copy or even asking him

12     what the charges were about?  That didn't cross your mind?

13        A.   Of course it did, very much so.  We discussed it two or three

14     times, and we said that we should deal with it in a timely fashion.

15     However, I repeat, he tried to trivialise it.  I did not work on such

16     specific tasks, and, of course, I couldn't make him let me see the

17     indictment.  I was merely his assistant.

18        Q.   And you didn't ask any other senior officers of the MUP what this

19     indictment was about and what sort of charges were included in that

20     indictment?

21        A.   How could I have asked them when none of them knew what the

22     contents of the indictment were.  He had it.

23        Q.   But you are saying the press was reporting about it.  So it seems

24     the press was informed about this what indictment was about.

25        A.   Well, journalists write all sorts of things.  They speculate.

Page 14139

 1     But one must look at a specific document, at the original indictment.

 2        Q.   Mm-hmm.  So you had a general idea of what this was about from

 3     the press, but you are saying you never saw the original document.

 4        A.   No, never.

 5        Q.   Sir, moving on from that topic, have you yourself ever been

 6     accused of abusing official position as an assistant minister?

 7        A.   Yes, I have.  I was accused of abuse of office.  It was a

 8     fabrication which took place during my long career.  However, I was never

 9     held responsible for anything, nor were there ever any questions raised

10     about my work.  It was completely fabricated.  If you had been able to

11     see the charges, you would have realised what sort of evidence they had,

12     that is why the indictment had been delayed for so long and not acted

13     upon.  I do not feel guilty and I will prove that, and then I hope to

14     forward a copy to you.  To repeat, I do not feel guilty.  And this is

15     well known to all those who know me.  I replaced a police inspector who

16     was then used to level charges against me without any physical evidence,

17     but that’s a completely different story.  In any case, the proceedings

18     are still underway, I’m innocent, and I intend to prove it.

19        MS. KRAVETZ:  If we could -- sir, if we could see 65 ter 06106,

20     please.

21             And I would point out, Your Honours, that we only have a partial

22     English translation of this document.  We are trying to procure a full

23     translation, so that will be uploaded once it's available.

24        Q.   Sir, I take it you are familiar with this document?  You just

25     said I was never indicted and nothing was left of it, but isn't it true,

Page 14140

 1     sir, that this is in fact an indictment that was issued against you in

 2     2007 by the district court of Belgrade, the special department in

 3     prevention of organised crimes, and that it alleges that you, along with

 4     another eight officials, including senior officials of the MUP, were

 5     involved in a network of cigarette smuggling into Serbia in the period of

 6     1996 to 1998?  Isn't that the case, sir, that you've actually been

 7     indicted by that court for these charges?

 8        A.   Madam Prosecutor, let me tell you first that it is not true that

 9     I said that I was never indicted.  What I said was that during my career

10     I was never disciplined; I was never convicted on any criminal or

11     misdemeanour charges.  What I said was that I was indicted in this case,

12     please para-phrase my words exactly, that the indictment was issued in

13     2007, as you can see.  These are long proceedings, and I guarantee that I

14     am absolutely innocent and that I will prove it in court.  I don't know

15     whether you read this indictment carefully.  If you did, you must know

16     what sort of evidence there is.  What I said --

17        Q.   Sir, I'm going to stop you there.  The document is before the

18     Court, and we will get a full translation.  But I have read this

19     document, in fact, and I saw that it alleges that there was a cigarette

20     smuggling group of -- which was involved in buying cigarettes of foreign

21     production and organising the transport of the cigarettes into Serbia,

22     and that this was done with false custom certificates through a company

23     called R5.  And it alleges that you were involved in this group.  And the

24     specific charges that are raised here against you is that you prevented

25     officials from imposing any control of the work of this company and that

Page 14141

 1     you ordered that the cigarettes found in vehicles of this company which

 2     belonged to Sinisa Stojicic, the brother of late General Stojicic from

 3     the police, you ordered that these vehicles be returned to him.  And you

 4     were charged for abusing your authority as an assistant minister of the

 5     MUP because of your involvement in this network of cigarette smuggling,

 6     sir.  Isn't that correct that these are the charges?  And just a very

 7     brief answer, yes or no, to confirm that these are the charges.

 8        A.   Yes, these are the charges, which have nothing to do with any

 9     facts.  Do you want me to elaborate?

10        Q.   No, sir.  I'm just asking you to confirm the document that's

11     before the Chamber.  Isn't it true, sir, that this case is still pending

12     in Serbia against you?  These charges have not been dropped.  These

13     charges of abuse of your official position of assistant minister, these

14     are still pending against you, and the trial is still underway; isn't

15     that correct, sir?

16        A.   Is it correct that the charges were not dropped, that there are

17     still proceedings underway instituted against me before the county court

18     in Belgrade.  However, you need to wait --

19        Q.   Thank you --

20        A.   [Previous translation continues] ... to see the outcome.

21        Q.   Thank you for that answer, sir.  I was just asking a very precise

22     question.

23             MS. KRAVETZ:  Your Honour, I have completed my cross-examination.

24     Thank you.

25             JUDGE PARKER:  Thank you, Ms. Kravetz.

Page 14142

 1             Mr. Djurdjic.

 2             MS. KRAVETZ:  Your Honour, I did forget, I did mean to tender

 3     that document.  We are waiting for a full translation, so at this stage I

 4     would ask for it to be marked for identification.  And it's 65 ter 06106.

 5             JUDGE PARKER:  It will be marked.

 6             Mr. Djurdjic.

 7             MR. DJURDJIC: [Interpretation] Your Honour, objection.  I object

 8     to admitting this document into evidence.  I believe it is irrelevant

 9     because it has no probative value and no links to the case dealt with

10     here.  If one wants to challenge the credibility of this witness, that

11     can be done through a final judgement.  In our legal system… let me say

12     this and then you can decide -

13        JUDGE PARKER:  Mr. Djurdjic, all that is happening is that it's being

14  marked.  I don't know whether you are going to use it or some other witness,

15  and -- okay.  You can relax.  It's not going to be an exhibit at the moment.

16             MR. DJURDJIC: [Interpretation] Thank you.  It was my

17     understanding that pending translation, it will have become a full

18     exhibit.  Otherwise I have no objection.

19             JUDGE PARKER:  Ms. Kravetz may have anticipated that, but I

20     hadn't.

21             THE REGISTRAR:  Your Honours, that will be Exhibit P01602, marked

22     for identification

23                           Re-examination by Mr. Djurdjic:

24        Q.   General, sir, let's start from the end.  You said that the

25     indictment issued by this Tribunal against, among others, the minister of

Page 14143

 1     the interior, Mr. Stojiljkovic, is something you have not seen.  Were you

 2     made familiar with any particular charge of that indictment?

 3        A.   No, I was never specifically informed of the specific charges and

 4     crimes.

 5        Q.   Thank you.  You told us that the minister issued the decision on

 6     the setting up of the staff for the suppression of terrorism on the 16th

 7     of June, 1998.  Was that decision implemented and put into practice?

 8        A.   Yes.

 9        Q.   Thank you.  When did you see the decision in its paper form?

10        A.   This decision of the 16th of June?

11        Q.   Yes?

12        A.   Well, perhaps a week or two after it was issued.

13        Q.   Thank you.

14             Who planned anti-terrorist operations in the summer of 1998 and

15     during the war in 1999?

16        A.   They were planned, organised, and executed by the MUP staff for

17     the suppression of terrorism.

18        Q.   Thank you.

19             Do you have any knowledge of any meetings during the war in 1999

20     being held with the state leadership where General Vlastimir Djordjevic

21     was in attendance?

22        A.   I don't have any such knowledge.

23        Q.   Thank you.  Can you tell us who decided on admitting people to

24     the reserve force of the Ministry of the Interior?

25        A.   People became members of the reserve force of the Ministry of the

Page 14144

 1     Interior on the decision by the minister of the interior.

 2        Q.   Thank you.

 3             Was there any RJB plan for defence that existed?

 4        A.   I don't understand the question.

 5        Q.   Did ever exist a plan of the public security sector for defence?

 6        A.   Yes, there was a plan.

 7        Q.   What sort of plan was it?

 8        A.   A regular plan.  The Ministry of the Interior as a state organ

 9     had its own defence plan with different segments, and it was supposed to

10     be drawn up by the police administration and its relevant department.

11        Q.   Does such a plan entail planning, organising, and implementing

12     any military activities?

13        A.   No, it does not.

14        Q.   Thank you.  Who informed you of the existence of a global plan

15     for combatting terrorism in mid-1998?

16        A.   The global plan for combatting terrorism was supposed to have

17     been implemented together with the Army of Yugoslavia, and we were

18     informed of it by the interior minister, Mr. Stojiljkovic, at a collegium

19     meeting.

20        Q.   Thank you.  After the 4th of December, 1998, at collegium

21     meetings, did the minister of the interior issue tasks to the chief of

22     the public security sector?

23             THE INTERPRETER:  Interpreter's correction:  State security

24     sector.

25             THE WITNESS: [Interpretation] After the 4th of December when the

Page 14145

 1     minister collegium was set up, representatives of the state security

 2     attended its meetings, but the minister never issued specific tasks to

 3     the state security sector.

 4             MR. DJURDJIC: [Interpretation]

 5        Q.   Thank you.

 6             After the 4th of December, 1998, did the minister collegium

 7    meetings include chiefs of administrations from the state security sector?

 8        A.   After the 4th of December?  Well, after that date, but before as

 9     well, the various chiefs of the state security sector did not take part.

10     Such meetings were only attended by the chiefs of the administrations of

11     the state --

12             THE INTERPRETER:  Interpreter's correction:  Public security

13     sector.

14             MR. DJURDJIC: [Interpretation] Could we please have P263.

15        Q.   General, this is a dispatch dated 4 June, 1997, by Minister

16     Vlajko Stojiljkovic.  We see the addressees.  He informed them of the

17     appointment of assistant ministers.  Tell us this, please, when did

18     Vlajko Stojiljkovic become the minister of the interior, as far as you

19     know?

20        A.   As far as I recall it was in mid-May 1997, around that time in

21     any case.

22        Q.   Thank you.  When did Mr. Stojiljkovic begin presiding over the

23     collegium?

24        A.   Only after the dispatch of the 4th of June was issued.  Before

25     that we only had public security collegium meetings.

Page 14146

 1        Q.   Thank you.  Who issued tasks at collegium meetings when Minister

 2     Vlajko Stojiljkovic took over?

 3        A.   The minister of the interior issued tasks at such collegium

 4     meetings.  As the assistant ministers, we put forth our own proposals and

 5     measures, some of which were considered.  Unfortunately, others were not.

 6     Some were even completely ignored by the minister.

 7        Q.   Thank you.  Could the interior minister issue decisions forming

 8     organs or bodies, as well as to issue them tasks, competencies, and

 9     accountability?

10        A.   Yes.  Pursuant to Article 6 of the Rules on Internal

11     Organisation, the minister could establish such bodies.  Also pursuant to

12     Article 6, I believe, of the Law on the Interior, he could establish

13     units, staffs, Working Groups, et cetera.  That was his legal authority.

14     Actually, he was the only one who had such powers.  Chiefs of sectors or

15     secretariats could have staffs or Working Groups, but not without a prior

16     consent or approval from the minister.  If this is what you meant by your

17     question.

18        Q.   Thank you, General.

19             MR. DJURDJIC: [Interpretation] I have no further questions,

20     Your Honours.  This concludes my redirect.

21             JUDGE PARKER:  Thank you, Mr. Djurdjic.

22                           Questioned by the Court:

23             JUDGE FLUEGGE:  I just want to know who was the deputy of

24     General Djordjevic in his position as chief of the public security sector

25     of the MUP in 1998 and 1999?

Page 14147

 1        A.   In 1998 and 1999, Mr. Vlastimir Djordjevic, chief of sector, did

 2     not have a deputy.

 3             JUDGE FLUEGGE:  And who stood in for him in his absence?

 4        A.   That was not determined.  No person was assigned that duty.

 5     We insisted with the minister that there ought to be a deputy minister

 6     and a deputy chief of sector.  However, he did not find it to be

 7     necessary.  Hence, no assistant minister was authorised to stand in for

 8     the chief of sector.  We were each accountable for our own lines of duty,

 9     and we were directly linked to the minister.  He issued us tasks.  The

10     chief of the sector did not have a deputy of his.

11             JUDGE FLUEGGE:  While Mr. Djordjevic was touring around Kosovo in

12     1998, who did his work in his office?

13        A.   No one did.  The minister covered that area.  When the chief of

14     the sector was absent, each one of the assistant ministers was in charge

15     of their own respective areas and was directly answerable to the

16     minister.  The minister held collegium meetings, even when the chief was

17     present.

18             JUDGE FLUEGGE:  Thank you very much.

19             JUDGE PARKER:  Thank you.  You will be pleased to know that

20     concludes the questioning for you.  We have managed to complete within

21     the time available.  The Chamber would thank you for your attendance here

22     in The Hague and for the assistance you have been able to give.  And you

23     may now, of course, return to your normal activities.  A Court Officer

24     will assist you out now.  Thank you.

25             THE WITNESS: [Interpretation] Thank you, Your Honours.

Page 14148

 1                           [The witness withdrew]

 2             JUDGE PARKER:  There's a question whether it is convenient at

 3     this time to speak briefly of a timetable for written submissions.

 4             But first, Ms. Kravetz, are you in a position to indicate whether

 5     a motion is contemplated for additional evidence by the Prosecution in

 6     any form?

 7             MS. KRAVETZ:  Your Honours, I am unfortunately not.  I would need

 8     to consult with Mr. Stamp on that matter.  I believe the answer is no,

 9     but I would prefer to consult with him.

10             JUDGE PARKER:  We'll work on your belief at the moment,

11     Ms. Kravetz.  Time for written submissions?

12             MS. KRAVETZ:  Our proposal was sometime in the beginning of July,

13     specifically we were thinking of the 2nd of July.

14             JUDGE PARKER:  That would be some five or six weeks?

15             MS. KRAVETZ:  Yes, we were thinking of -- I think, depending on

16     which day we conclude the evidence of the proposed expert by the Defence,

17     it would be somewhere around five to six weeks after the conclusion of

18     evidence, yes, Your Honour.

19             JUDGE PARKER:  Thank you.

20             Mr. Djurdjic.

21             MR. DJURDJIC: [Interpretation] Your Honours, I absolutely support

22     Ms. Kravetz, not only do I support that, but I think that perhaps this

23     time-period should be extended, too, because the Prosecution has already

24     worked with much evidence, many exhibits, and has some idea, and also a

25     part of their job has already been completed.  I have received

Page 14149

 1     information from my associate that we have 14.000 pages of our

 2     transcripts, 50.000 pages of exhibits -- or, rather, pages to work with,

 3     and 2.528 exhibits.  I think this is a vast quantity of material which

 4     our Defence, which comprises only two legal assistants and two counsel,

 5     has to deal with in an appropriate time-period.  I would like to say

 6     right away that in the interest of justice and the accused, the

 7     proceedings have been proceeding quite efficiently, and you would be

 8     hard-pressed to find a more efficient proceedings at the Tribunal.  We

 9     proceeded mostly with our work five days a week, sometimes three days a

10     week when we didn't work during the holidays.  At the very beginning of

11     our presentation of our case, we did work three days a week, so we would

12     request that we be given six weeks for our closing arguments.

13             We, I believe, had proceedings which proceeded in an excellent

14     way and that our co-operation with our learned friends from the

15     Prosecution was such so that a week or two weeks more would be quite a

16     moot subject of discussion.  But of course, we will be guided by your

17     decision be on this matter.  Thank you very much.

18             If we need to put a date on it, then we would like to ask for at

19     least one week more.  If Ms. Kravetz had asked for the 2nd of July, we

20     would then request that it be the 9th of July at the earliest.

21                           [Trial Chamber confers]

22             JUDGE PARKER:  The Chamber is encouraged to find at this stage of

23     the trial such complete concurrence between Prosecution and Defence.

24     It's heartening, but we do propose to look at your proposals, and we'll

25     let you have our decision in the course of next week as to the date for

Page 14150

 1     written submissions, and with oral submissions to follow a little later.

 2             Thank you very much.  We now adjourn until Monday the 17th of

 3     May, as I understand it, and in that week to finish the three remaining

 4     witnesses; one Prosecution, and two Defence.  We now adjourn.

 5                           --- Whereupon the hearing adjourned at 7.06 p.m.

 6                           to be reconvened on Monday, the 17th day of May,

 7                           2010, at 9.00 a.m.

 8

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