1 Thursday, 6 April 2006

2 [Open session]

3 [The accused entered court]

4 [The witness entered court]

5 --- Upon commencing at 2.19 p.m.

6 JUDGE MOLOTO: Who do I call, do I call Mr. Whiting or

7 Ms. Richterova? Ms. Richterova.

8 MS. RICHTEROVA: Yes, I'm calling the next witness.

9 JUDGE MOLOTO: Thank you. May the witness please make the

10 declaration.

11 WITNESS: JOSIP JOSIPOVIC

12 [Witness answered through interpreter]

13 THE WITNESS: [Interpretation] I solemnly declare that I will speak

14 the truth, the whole truth, and nothing but the truth.

15 JUDGE MOLOTO: Thank you very much. You may be seated.

16 Yes, Ms. Richterova.

17 Examination by Ms. Richterova:

18 Q. Witness, can you please state your full name and date of birth.

19 A. My name is Josip Josipovic, born on the 15th of February, 1967, in

20 Hrvatska Dubica.

21 Q. You are of Croatian nationality; is that correct?

22 A. Yes, I'm a Croat.

23 Q. You served your compulsory military service between March 1989 and

24 March 1990?

25 A. That's correct.

1 Q. And until 1991, you were switchman at the railway station?

2 A. Yes.

3 Q. You mentioned that you were born in Hrvatska Dubica. Which town

4 or which village in Dubica area did you live?

5 A. Predore village.

6 Q. Predore village, is it part of some other bigger village?

7 A. It's eight kilometres away from Hrvatska Dubica.

8 Q. Talking about Predore, is it a Croat or a Serb village?

9 A. It had a mixed population; Croats, Serbs and Muslims.

10 Q. How many people lived, approximately, in your village?

11 A. Not many. There were perhaps 15 houses.

12 Q. And how many of them belonged to Croats?

13 A. Five or six.

14 Q. To Serbs?

15 A. Around the same number.

16 Q. Can you tell us what other villages were there in the area of

17 Dubica?

18 A. Donji Cerovljani, Bacin, Sanac, Visnjica.

19 Q. Which of these villages you must mentioned belonged to Croats?

20 A. All of them were Croat. In fact, all the villages had a mixed

21 population, almost all of them.

22 Q. Was there any village with predominantly Serb population?

23 A. Yes, Zivaja.

24 MS. RICHTEROVA: Your Honours, just -- I forgot to mention where

25 you could find the village of Hrvatska Dubica. It's in the atlas on the

1 page 21, grid D3. Your Honours will see somewhere in the middle a town

2 called Bosanska Dubica, and right above it is the place called Dubica,

3 which is Hrvatska Dubica. It means that it is on the territory of

4 Croatia. Bosanska Dubica is on the territory of Bosnia.

5 Q. Can you very briefly describe the relationship between Croats and

6 Serbs until 1990 in the area of Dubica?

7 A. We lived normally, having no inkling of what would happen later.

8 Everything worked well in our human relations.

9 Q. Did there come a time when the situation changed?

10 A. Yes. The situation changed later. When Tito died, Yugoslavia was

11 supposed to get a new president. Two or three presidents, in fact,

12 changed before the end -- before the beginning of the war when Croatia

13 wanted to separate from the rest of Yugoslavia. However, it caused the

14 outbreak of a war.

15 Q. What -- what caused the outbreak of the war?

16 A. Well, Croatia wanted to be independent. Croatian wanted to have

17 its own government, and Serbs rebelled against that. They wanted a

18 Greater Serbia. In fact, at one stage they wanted Greater Serbia, and at

19 another point they wanted to stay in the former Yugoslavia, and that

20 caused a quarrel, and it caused the system to break down.

21 Q. Do you know whether Croatia formed their own armed forces? And I

22 am referring to 1990.

23 A. Yes. Croatia held its elections, and after the elections it

24 established its own Croatian police and the Croatian army that was called

25 ZNG, the Home Guards Corps. When that happened, those Serbs who worked on

1 the police force in the times of Yugoslavia rebelled. They used to wear

2 different emblems, Yugoslav emblems like the five-pointed star, and they

3 were very much against the introduction of the Croatian chequer-board

4 standard flag.

5 JUDGE MOLOTO: May I please interrupt?

6 In the answer to the previous question, did the witness not say in

7 fact at one stage they wanted Greater Serbia, and at another point they

8 wanted to stay in the former -- Croatia. I see it says the former

9 Yugoslavia. I'm not quite sure whether the witness said Croatia or the

10 former Yugoslavia.

11 MS. RICHTEROVA:

12 Q. Can you please clarify to the Judge whether they meant that they

13 wanted to stay in former Yugoslavia or whether they wanted to stay in

14 Croatia?

15 A. They wanted to remain part of Yugoslavia, and they wanted Croatia

16 as a whole to remain part of Yugoslavia.

17 JUDGE MOLOTO: I now understand.

18 MS. RICHTEROVA:

19 Q. What happened to these Serbs who didn't want to wear the

20 chequer-board sign?

21 A. The Serbs who didn't want to wear the chequer-board emblem stood

22 down from their posts in the police force of Croatia and became renegades.

23 They created their own units purportedly for the defence of Yugoslavia.

24 Q. Let's now talk about the area of Dubica, and tell us, were there

25 any ZNG units in 1990 or 1991?

1 A. Yes, just after the elections. The new Croatian police and the

2 Home Guards Corps were immediately established.

3 Q. When -- when we are talking about these Home Guards Corps, are you

4 referring to ZNG?

5 A. Right.

6 Q. Where is -- ZNG, where were they located? Where was their

7 headquarters?

8 A. The headquarters was in Hrvatska Dubica.

9 Q. Up until 1991, do you know of their strength in -- in the Dubica

10 area?

11 A. I didn't quite understand the question. You mean Croatian units,

12 the police, or the army, or the total?

13 Q. I'm referring now to ZNG. Do you know how many men approximately

14 were member of ZNG in the area of Dubica?

15 A. I don't know. Just a few. A couple of Croatian villages only

16 joined the Home Guards Corps and the police. Let me try to give you a

17 number. Perhaps a hundred men all in all.

18 Q. What about Serbs? Did -- did they form some armed units as well?

19 A. Yes. They formed their own units wishing to stay within the

20 former Yugoslavia, and they called them TO, Territorial Defence.

21 Q. Where was their headquarter? I'm talking about this Territorial

22 Defence.

23 A. Their headquarters was in Dubica hills, Dubicka Brda, overlooking

24 Hrvatska Dubica.

25 Q. What about police? You already talk about Croatian police. Was

1 there any Serb police?

2 A. Well, after the Croatian police and troops withdrew from Hrvatska

3 Dubica, the Serbs had their own police force there and their TO.

4 Q. We will talk about this little bit later, but when was it that

5 Croatian police and troop -- troops withdrew from Hrvatska Dubica?

6 A. The 13th or the 14th September 1991.

7 Q. Let's talk now about ZNG and TO. What kind -- did you join ZNG?

8 A. Yes, I did.

9 Q. What were the circumstances you joined ZNG?

10 A. I was not able to go to work and I couldn't keep my job, so I had

11 no choice by to join the ZNG, and that was in July, I think.

12 Q. Which we are?

13 A. 1991.

14 Q. What kinds of weapons ZNG -- did ZNG have at that time?

15 A. ZNG had hunting weapons at the time and some museum rifles.

16 Whatever they could lay their hands on.

17 Q. What about the Serb forces which were in the area? How were they

18 armed?

19 A. Serb forces had the support of the former Yugoslav People's Army,

20 and the Yugoslav People's Army supplied them with automatic and other

21 weapons.

22 Q. Did you ever see -- you say that JNA supplied them with weapons.

23 Did you ever see that JNA, any unit of JNA would provide or deliver these

24 weapons?

25 A. I did. When I was coming from Hrvatska Dubica to my own village,

1 Predore, helicopters were hovering over the village, and once when I was

2 going into Predore to visit my parents, I saw a JNA helicopter hovering

3 first over the village and then moving 500 metres away, perhaps, where it

4 landed on the road, and those renegade Serbs were waiting there. And then

5 they proceeded to unload weapons from the helicopter and put them into

6 trucks and some other passenger vehicles that they had seized earlier.

7 Q. Do you still remember which directions did they take these

8 weapons, or this truck drove which direction?

9 A. Towards Zivaja, which was a Serb-populated village.

10 Q. You -- you also mention "those renegade Serbs." Who are you

11 referring to? Who were they? Which unit did they belong?

12 A. I didn't really know to which unit they belonged. They wore a

13 variety of insignia, including the five-pointed star and emblems with the

14 inscription "SAO Krajina." They wore cockades. You couldn't tell any

15 more who was who and how they were -- who they were supposed to be. They

16 were TO, the police, local defence. We referred to them as Serbs or

17 Chetniks.

18 Q. I would like to show you three patches and ask you whether you

19 would be able to recognise any of these patches, whether any of them

20 was -- you could see wearing people -- Serb people in Dubica. The first

21 one is Exhibit 266, and I would provide hard copy, because it usually

22 takes a little bit of time to display it on the screen. So if we could

23 place it on the ELMO.

24 Can you please have a look at this patch and tell us whether you

25 ever seen this patch on any uniforms in Dubica? It's right next to you.

1 A. Yes. I saw this one worn on camouflage uniforms and the

2 olive-grey uniforms alike.

3 Q. Do you know who wore these -- who wore this -- this patch?

4 A. The police of the Krajina.

5 Q. We will talk about police Krajina little bit later.

6 Now I would like to show you another patch. It is -- it is 65 ter

7 number 641, and I will again provide a hard copy. We manage to display

8 it.

9 JUDGE MOLOTO: Could we first see the number of this?

10 MS. RICHTEROVA: 01187435.

11 JUDGE MOLOTO: Thank you.

12 MS. RICHTEROVA:

13 Q. Can you have a look at this patch and tell us whether you saw this

14 patch on any uniforms in Dubica?

15 A. Yes, on camouflage uniforms.

16 Q. Who -- who wore these patches?

17 A. Serb army and the Serb police, the special purpose police. I

18 don't know what they called themselves.

19 MS. RICHTEROVA: Your Honour, I would like to tender this document

20 into evidence.

21 JUDGE MOLOTO: This one, not the previous one?

22 MS. RICHTEROVA: The previous one has already been tendered.

23 JUDGE MOLOTO: Has it. Okay. This document with number 01187435

24 is admitted into evidence. May it please be given an exhibit number.

25 THE REGISTRAR: That will be exhibit number 288, Your Honours.

1 JUDGE MOLOTO: Thank you very much.

2 MS. RICHTEROVA:

3 Q. And there is a last one. Its number is -- 65 ter number is 640,

4 and ERN is 01187450.

5 Witness, did you see the similar sign or the same sign like this

6 in the patch in Dubica?

7 A. Yes, I did see it in Dubica.

8 Q. Witness, this one says down below "Ugljevik."

9 JUDGE MOLOTO: Where is "Ugljevik"?

10 MS. RICHTEROVA: It is in Cyrillic. It is down below.

11 Q. Can you please show the Judges where the word "Ugljevik" is

12 written on that document, please.

13 A. [Indicates].

14 JUDGE MOLOTO: Thank you.

15 MS. RICHTEROVA:

16 Q. Did people who you saw wearing this patch, did they have also the

17 sign of Ugljevik or was there something else?

18 A. I can't remember whether it said something else or whether it said

19 "Ugljevik," but I do remember this patch very well.

20 JUDGE MOLOTO: What does "Ugljevik" mean?

21 MS. RICHTEROVA:

22 Q. Do you know what "Ugljevik" means?

23 A. No, I don't.

24 MS. RICHTEROVA: Ugljevik is a town in Bosnia.

25 JUDGE MOLOTO: Is the witness able to tell us what the other

1 writing means or what the writing -- the rest of the writing says?

2 MS. RICHTEROVA:

3 Q. Would you be so kind and tell the Judges what we can see in

4 writing on this patch.

5 A. It says, "Special Police Units," "Blue," and then "Ugljevik."

6 JUDGE MOLOTO: Is "blue" also on this writing?

7 MS. RICHTEROVA: It is this word "Plavi."

8 JUDGE MOLOTO: Thank you very much.

9 MS. RICHTEROVA:

10 Q. You stated that you saw this patch on uniforms in -- in Dubica.

11 Which unit or which forces wore these patches?

12 A. These patches were worn by men who came from Bosna to help when

13 they were attacking Jasenovac, and then Lipan [phoen], Pakrac.

14 Q. And these people from Bosnia who came to help, what ethnicity did

15 they were?

16 A. They were of Serbian ethnicity.

17 MS. RICHTEROVA: I would like to tender this document into

18 evidence.

19 JUDGE MOLOTO: The document with ERN number 01187450 is admitted

20 into evidence. May it please be given an exhibit number.

21 THE REGISTRAR: That will be Exhibit number 289, Your Honours.

22 JUDGE MOLOTO: Thank you.

23 MS. RICHTEROVA: I'm -- I'm done with these. It can be removed.

24 Q. You mentioned that JNA supplied Serb -- Serbs with weapons, and

25 you describe how they delivered weapons in this helicopter. Did -- did

1 you see only one helicopter or were there more than one helicopters you

2 saw in Dubica area?

3 A. There were several of them, and on a number of occasions this

4 helicopter flew over, and that was something that happened before I'd

5 joined the ZNG.

6 Q. And after you joined ZNG, were you aware whether the supply of

7 weapons continue?

8 A. Yes, I was aware of that.

9 Q. How did you know it?

10 A. Well, I knew because I was in Hrvatska Dubica. I left Hrvatska

11 Dubica to visit my parents in their village, and my mother told me that

12 the helicopter had landed again, and on one occasion when I went there my

13 mother told me the same again, and I went and saw it for myself.

14 Q. You mention JNA helicopters. Did you also see JNA forces? Did

15 you see JNA soldiers in -- in Dubica area?

16 A. Well, it would be difficult to say JNA soldiers. They wore all

17 sort of insignia, so it's difficult to say whether it was a TO soldier or

18 member of the special police or of the Krajina police or whether it was a

19 Chetnik.

20 Q. What do you mean that it was difficult to -- to distinguish? Can

21 you be more specific? You cannot say whether someone was a JNA soldier or

22 whether someone was a TO member or that someone was a policeman?

23 A. Yes. It was difficult to distinguish them. All we knew is that

24 they were fighting for the same objective, a Greater Serbia and in order

25 to preserve Yugoslavia.

1 Q. What was the role of ZNG in Dubica? You were a member of ZNG.

2 What was the role?

3 A. To exercise authority, to implement the law, to enforce the law.

4 ZNG was there at the time of the former Yugoslavia. And what the TO was

5 was also the ZNG at the time.

6 Q. How would you describe what was happening in summer of 1991 in

7 Dubica? Were there any clashes? What was happening in summertime of

8 1991?

9 A. In the summer of 1991, the police was carrying out its duties, and

10 the ZNG was helping the police at the time. The Serbs who lived in that

11 area, in Hrvatska Dubica, were creating hatred amongst themselves, and

12 they were scaring each other by referring to the ZNG and the Croatian

13 police, and at such times they would cross the River Una at night, and

14 they would go to Bosanska Dubica. The JNA was present in Bosanska Dubica,

15 and naturally they reported to the JNA and gave them false information as

16 to the situation in Dubica. They spread hatred in this way and made the

17 JNA hate the Croats; the Croatian police and the Croatian army.

18 Naturally, the JNA provided them with weapons. This all happened at night

19 because they were afraid to sleep in Hrvatska Dubica and in their

20 villages, so they went to Bosna. That's where they got the weapons, and

21 then they would open fire at night. They would open fire over the Una.

22 They would open fire on the Croatian troops, and they would fire at

23 Croatian houses. At night they would return as if nothing had happened.

24 THE INTERPRETER: Could the witness please be asked to speak up or

25 to approach the microphone as the interpreter is having difficulty hearing

1 him.

2 MS. RICHTEROVA:

3 Q. Witness, would you be so kind and lean against the microphone a --

4 closer to microphone because the interpreters cannot hear.

5 JUDGE MOLOTO: And also speak loud, please.

6 MS. RICHTEROVA:

7 Q. You said that these Serbs left for Bosanska Dubica, to stay there

8 overnight. Did they always return in the morning?

9 A. Yes, they would always return in the morning.

10 Q. What was your task? You were a member of ZNG. What did -- you

11 specifically, what did you do?

12 A. I was a member of the ZNG at the very beginning. At the very

13 beginning I was issued with a sniper rifle, and I was assigned to patrol a

14 bridge, to be present at a bridge, at the border between Hrvatska and

15 Bosanska Dubica.

16 Q. Now, how long did you have this sniper rifle? How long did you

17 hold this assignment?

18 A. For a brief period of time. I had that rifle, as I said, and on

19 one occasion shooting broke out, and at the time someone ordered me to

20 return fire. I don't know who issued this order, but I refused to comply

21 with the order. I didn't want to open fire. I was a sniper in the former

22 JNA. I know what my duty is. I know what I'm supposed to do. And now I

23 was no longer a desirable individual, and my sniper rifle was taken away

24 from me and given to someone else.

25 Q. And after that, what did you do?

1 A. After that, I received an M-48 rifle which I carried around with

2 me. I was in a state of readiness.

3 Q. Were you involved -- after this, were you involved in any attacks

4 on Serb forces, or did you stay in the town?

5 A. I stayed on in town.

6 Q. Were you able to go back to your village to visit your parents?

7 A. No. It was difficult. I had to go there at night to reach my

8 village, and then I could visit my home and stay at my home during the

9 day.

10 Q. You stated no, but then you said it was difficult, you had to go

11 overnight. So did you go or you -- you didn't go?

12 A. I did.

13 Q. How often did you go home?

14 A. I don't know how many times I went home throughout that entire

15 period while I was a member of the ZNG in Hrvatska Dubica. Perhaps I went

16 there between eight and 10 times.

17 Q. You already mentioned that at some point in September ZNG and

18 Croatian police left Hrvatska Dubica. At the time when they left, where

19 were you? Were you in Dubica or at home in Predore?

20 A. I was at home in Predore.

21 Q. Do you know why ZNG and why Croatian forces left Hrvatska Dubica?

22 A. Yes. The JNA launched an attack, as well as the rebellious Serbs

23 we have already mentioned. They launched an attack, and they wanted to

24 put Hrvatska Dubica under their control as well as the surrounding places

25 and villages. At that point, the Croatian police, the ZNG, and the

1 population withdrew.

2 Q. When you say population withdrew as well, are you talking about

3 civilian population of Croat ethnicity or Serb ethnicity or both

4 ethnicities?

5 A. Yes. I'm referring to those of Croatian nationality, but there

6 were several Serbs and Muslims who also fled before the JNA and the

7 rebellious Serbs.

8 Q. When -- when you -- you keep repeating the "rebellious Serbs." So

9 Dubica was attacked by JNA, and which other forces were together with JNA?

10 A. Well, the Serbian forces were there, Serbian forces who were

11 fighting for the SAO Krajina. I don't really know what their objective

12 was though.

13 Q. Now, you -- you said that at the time when ZNG and Croatian forces

14 left Dubica you were in your village Predore. What happened in Predore?

15 How did you -- first, how did you learn that civilians left Dubica?

16 A. Yes. I heard about that because I was in Novska at one point in

17 time. I returned home, and upon returning I saw a -- people I knew who

18 were playing at war. I asked them what they were doing, and they said

19 what the situation was like. They said that the JNA and rebellious Serbs

20 had launched an attack and that they had to withdraw, that the Croatian

21 army and police had to withdraw, as well as the population. They said

22 that the -- they had to ensure that the civilian population could

23 withdraw.

24 I entered my village where my mother lived, and we got ready to

25 flee, naturally. Once we had packed everything, the Serbs came from all

1 sides. They encircled the village, and they then imprisoned us and --

2 Q. I'll stop you here --

3 A. -- assembled you all together.

4 JUDGE MOLOTO: Can I just get clarification? What is meant

5 by "people playing at war"?

6 MS. RICHTEROVA: I just wanted to ask, Your Honour, the same

7 question.

8 Q. Can you please explain what do you mean by they were "playing at

9 war"?

10 A. There was some sort of a -- a train with some carriages in which

11 there were rocks, and there was a diesel machine behind those carriages

12 which was moving the carriages, and there were mortars, handmade mortars

13 on those -- in the carriages that had been made by amateur workers in the

14 ironworks. These mortars didn't have site-setters, didn't have devises to

15 measure the distance. Two idiots would have to use such mortars. One

16 would have to hold onto it and the other would have to put the shell in

17 the device.

18 Q. Why did they bring this train with mortars?

19 JUDGE MOLOTO: And who are the "they"?

20 MS. RICHTEROVA: Yes.

21 Q. First, who brought this train, and why did they bring this train?

22 A. As I have already said, that train arrived so that the Croatian

23 population could withdraw. It was in the possession of the Croatian army,

24 the ZNG.

25 Q. And were they able to use these mortars?

1 A. Yes. Yes, of course. But no one knew where the shell would fall

2 or whether the shell would explode.

3 Q. Now I would like to return to your village. When you said that

4 Serbs arrive from four sides, who were these Serbs?

5 A. Yes. They came from all sides. They were members of the JNA, of

6 the Territorial Defence, the police of SAO Krajina. They were Chetniks,

7 people fighting for a Greater Serbia. I don't really know who they were.

8 They had all sorts of insignia on them. Anyone who got hold of insignia

9 of any kind would -- would wear such insignia.

10 Q. Did you know anybody from these people? Did you know anybody by

11 name?

12 A. Yes, I did know about perhaps a dozen men by name.

13 Q. Can you tell us who you knew by name?

14 A. Yes. Paukovic, Rajko; Paukovic, Dubravko; Mico Tepic; Djordje

15 Ratkovic; Djuro Jerinic; Branko Kotur, and others. I can't remember any

16 other names.

17 Q. Do you know a person by name Veljko Radjunovic?

18 A. Yes. Yes. There was a Zeljko [as interpreted] and Stevo

19 Radjunovic. And Momcilo Kovacevic.

20 Q. I'm sorry, did you say Zeljko or Veljko?

21 A. Veljko. Veljko.

22 Q. Do you know who Veljko Radjunovic and Stevo Radjunovic were?

23 A. Stevo Radjunovic, he was the most important person in the police,

24 in the TO, in the JNA, and within the Chetnik command.

25 Q. What about Veljko Radjunovic?

1 A. Veljko Radjunovic, Stevo's father, was sort of an advisor to him

2 and to Momcilo Kovacevic.

3 Q. And who was Momcilo Kovacevic?

4 A. Momcilo Kovacevic and Stevo had a lot of influence in the Croatian

5 army. I don't know whether Stevo was the main person or Momcilo.

6 Q. I'm sorry, did you say that Momcilo Kovacevic and Stevo had lots

7 of influence in Croatian army?

8 A. No. They weren't in the Croatian army.

9 Q. So what -- what kind of army? It was probably some mistake. What

10 kind of army? Was it Croatian or Serb army or Bosnian army?

11 A. We're talking about the Serbian army, the Serbian police, the

12 Serbian Territorial Defence, the Serbian population.

13 Q. And these three men, were they also present when these Serbs

14 arrived to your village?

15 A. Yes, they were.

16 Q. After they arrived to your village what happened? What did they

17 do?

18 A. They gathered the people in one place. They separated six or

19 seven of us from the others. There was one slightly younger person. They

20 created a live shield, and they forced us to head down to the Sava River

21 so that they could reconnoiter the area and check out the situation to see

22 what Croatia had at its disposal, how many troops they had, what the

23 strength of the police force was, et cetera.

24 Q. And after that where did they take you?

25 A. After that, they returned us to the village, and then they took us

1 from the village to Hrvatska Dubica or, rather, to Dubicka Brda where they

2 had their command. And they had a headquarters there for mortars,

3 howitzers, tanks, cannons, et cetera.

4 Q. When you say, "They took us to Dubicka Brda," how many of you were

5 taken to Dubicka Brda?

6 A. Two of us. My nephew and I.

7 Q. What is the name of your nephew?

8 A. Mico Coric.

9 Q. Just one clarification. You said they had a headquarters there.

10 Who -- who are you referring to?

11 A. Well, we're talking about Serbs again, the Serb army, and in that

12 Serb army there was, of course, the TO. Anyway, I was just referring to

13 Serbs.

14 Q. How long -- how long did you stay in this headquarter in

15 Dubicka Brda?

16 A. I stayed a while, maybe a month.

17 Q. And from Dubicka Brda, where were you taken then?

18 A. From there we were taken to Hrvatska Dubica where they had their

19 command post and their headquarters. There was Kovacevic, Momcilo and

20 Stela Radjunovic -- rather, Stevo. Correction.

21 Q. Going back to Dubicka Brda, which place did you stay? We already

22 heard that it was headquarter, but I am -- I am more interested to know

23 which part of the building you were -- you were kept in.

24 A. They kept us in a private house, in fact in one room of that house

25 where the tank crews and mortar crews and cannon crews slept. And they

1 dedicated one room for prisoners so that they could keep an eye on us.

2 Q. Apart from you two, was there anybody else? Were there some other

3 prisoners?

4 A. Yes, later. Another two or three were brought later.

5 Q. How were you treated in this headquarter in -- in Dubicka Brda?

6 A. During the day they would take us outside to work, and the work

7 consisted of looting, looting for the Serbs. We looted Croat houses. We

8 would gather all the livestock. And later we worked on the bridge that

9 had been destroyed.

10 During the night they gave us hot meals, as they called it. And

11 it was kept warm, that meal, so that we could continue working tomorrow.

12 And they also kept our bodies warm. That's what they called beatings.

13 And in addition to the beatings, they made us sing songs with lyrics that

14 went something like "Get ready, get ready, Chetniks. There will be a big

15 battle." And we had to run around like in training and sing those songs.

16 They surrounded us in two circles, and we had to run. Everybody had some

17 sort of weapon. Each one of them had a gun, or an axe, and they would use

18 those things to beat us as we run by.

19 When we were completely exhausted and unable to run anymore and

20 our lips were unable to form those words, they would push us to one side

21 and make us run again. And when we were completely exhausted and couldn't

22 move, they would take their guns and pistols and fire to give us

23 inspiration to run some more.

24 There was one of them, Zeljko Abaza -- rather, one of us was

25 called Zeljko Abaza, and one of the bullets grazed him on the hip. I was

1 behind him and helped him up. I asked him, "Can you manage? Is it too

2 bad?" And he said, "I'll go on."

3 There were also interrogations accompanied by music, the Serb

4 song "March on the Drina." I didn't know the meaning of that song, of

5 that music at that time. I remembered it from some sort of movie. He

6 asked me to explain what kind of music it was, and I couldn't answer, so

7 he hit me on the head with a crowbar.

8 There was another -- another one of us whose turn it came to

9 answer the question. He was -- he was also hit on the head. And Abaza

10 was the third one, and he gave the correct answer. He said, "March on the

11 Drina" is the name of the song, but they hit him anyway. And when he got

12 up, they asked him, "How do you know this is it?" And Abaza said, "I just

13 know."

14 There was also Ante Knezevic among us, a man of about 50. He --

15 he lived through the same thing.

16 Q. I'm sorry to interrupt you at this moment, but let's take it

17 step-by-step. I will ask you to clarify certain things.

18 You were talking now about the beating, but at the beginning you

19 started talking about looting, that you were looting for Serbs. Who was

20 involved in this looting? And I'm talking who from the Serbs? Which

21 forces were involved in this looting?

22 A. All the Serb forces that I have enumerated so far, be it the JNA

23 or the TO or the police, or the police of SAO Krajina. Everybody took

24 part in the looting. And they made us loot for them.

25 Q. Then you started talking about how you were beaten, how you were

1 forced to run until you were exhausted. Was this something which happened

2 in this Serb headquarter in Dubicka Brda, or was it something which

3 happened already in Dubica?

4 A. That happened later in Hrvatska Dubica, in the old school

5 building. Before, that building used to be a school. After that, it was

6 adapted into some sort of farm building or outbuilding. Anyway, they

7 chose it for their command post. When I say "they," I mean Serbs.

8 Q. When kind of command post? Was there a post of TO or police? Who

9 was there? Who did you see there?

10 A. I don't know whose command post I saw. All kinds of uniforms

11 there. The police, Chetniks, TO. I can't tell you to whom they belonged

12 and what uniforms they wore, whether they were TO or Chetnik or whatever.

13 Q. Did you see Veljko Radjunovic and Momcilo Kovacevic at this

14 building, at this old school building?

15 A. Yes. I used to see them there. They were the gang leaders there.

16 They were the ones who issued orders, who decided what would be done.

17 Q. You then describe how you were beaten. Did these men participate

18 in beating as well?

19 A. Yes.

20 Q. You started talking about interrogation. What did they question

21 you about?

22 A. They interrogated us about the Croatian army, the Croat police,

23 what kind of weapons they had, how many, where their weapons come from,

24 et cetera.

25 Q. And while you were interrogate -- while you were interrogated,

1 were you beaten?

2 A. Yes, every time.

3 Q. And where did -- where did they take you in this building, old

4 school building? Where did you stay?

5 A. They held us in a toilet that was perhaps two metres long and 70

6 centimetres wide. It was the kind of toilet that didn't have a proper

7 watercloset but a hole in the ground where you had to crouch. There were

8 four of us there, myself, Coric, Knezevic, and Abaza. And I almost forgot

9 to mention the fifth man, Idriz Causevic.

10 Q. While you were kept -- kept in this toilet room, did you have

11 something to sleep on?

12 A. No. No. It was a concrete floor. Later they gave us some

13 jackets left behind by the Croatian police. We knew that because they had

14 patches on the sleeves saying "Croatian police."

15 Q. Did you get water?

16 A. Yes. After a while we got a jerrycan that earlier had oil in it,

17 petrol.

18 Q. So what kind of water it was? Was it fresh water you get?

19 A. Well, it was drinkable for us, because we couldn't get hold of any

20 other water. Of course it wasn't clean water. It had remnants of oil in

21 it.

22 Q. What did you eat? What kind of food did you receive?

23 A. We got small -- small liver pate packages and two pieces of bread.

24 MS. RICHTEROVA: Your Honour, I think it's a suitable time for the

25 break --

1 JUDGE MOLOTO: Thank you very much. We will take a short break

2 and come back at 4.00.

3 Court adjourned.

4 --- Recess taken at 3.30 p.m.

5 --- On resuming at 4.04 p.m.

6 JUDGE MOLOTO: Yes, Ms. Richterova.

7 MS. RICHTEROVA:

8 Q. Before the break we talk about the conditions in the detention

9 place. Now I would like to return to your treatment. I interrupted you

10 when you were talking about how were you made to run, how you were hit

11 over your head. When you were beaten, did you stay conscious all the

12 time?

13 A. All the time. In fact, after a while when we were no longer able

14 to withstand that, we would faint.

15 Q. Do you know whether anybody died in this old school place where

16 you were detained?

17 A. Right. When I came to -- before all that, they splashed us with

18 water. It was very cold. And I don't know how much time passed while I

19 was unconscious. And when I came round, I heard the moaning of Mico

20 Coric. He repeated like a mantra, "They will kill us. They will kill

21 us." And that's the first sound that I heard as I was coming to. And I

22 asked him what had happened in the meantime, and he told me.

23 And after that -- in fact, while we were still unconscious, they

24 dragged us back to the toilet where we were held. And when we came to,

25 they took us to a tractor with a trailer, and we had to load two corpses

1 onto the trailer so they can drive to the river and throw them in the

2 water.

3 Q. Did you --

4 A. But we were unable to stand on our feet, and we had great

5 difficulty loading the bodies.

6 Q. Did you recognise who were these would bodies? Who were these

7 people?

8 A. Yes. One was Antun Knezevic, and the other was Zeljko Abaza.

9 Q. These were the two men who were detained together with you in the

10 toilet?

11 A. Right.

12 Q. Were you able to see what happened to them, whether they had any

13 injuries?

14 A. Yes. Since we were unable to stand on our feet, it was them who

15 loaded the bodies onto the trailer, and they told us to get on. We were

16 unable to do that, so they threw us onto the trailer. They ordered us to

17 lie down on top of the bodies. So I ended up lying on the body of Zeljko

18 Abaza. And I could still feel the vibrations through the body.

19 Q. What -- what else --

20 THE INTERPRETER: The interpreter didn't hear the last part. Can

21 he repeat just the few last words?

22 MS. RICHTEROVA:

23 Q. Mr. Josipovic, the interpreters didn't hear the last sentence you

24 said. We understood that you felt the vibrations through the body, but

25 what did you say after that?

1 A. I said that I had also remarked that he had his throat slit with a

2 knife or something.

3 Q. You were constantly referring to "they." "They loaded the bodies.

4 They told us." Who were present when you were ordered to load these body

5 on this truck? Who were they?

6 A. I mean the Serbs, because there was Stevo Radjunovic, Momcilo

7 Kovacevic, Mirko Sarac, Milan Petrovic, Djordje Ratkovic, Djuro Jerinic,

8 Marjan Prvalo, all Serbs. Mladen Pozar.

9 Q. And all these were present when you were -- you were ordered to

10 load these bodies on the truck and then when you climb on the truck and

11 lie on -- lied on these bodies?

12 A. Yes. They were all there.

13 JUDGE NOSWORTHY: Ms. Richterova, before you carry on, may I ask

14 for some clarification, please? The witness has mentioned that a throat

15 was slit. Whose throat was it? Was it Antun or Zeljko's? And earlier on

16 you had asked him about whether there were injuries. He said yes. Could

17 we hear what type of injuries there were? Thank you very much.

18 MS. RICHTEROVA: Thank you.

19 Q. Mr. Josipovic, you heard the Judge. Can you tell us what kinds of

20 injury did you see on these bodies?

21 A. Yes. I saw the injuries while I was lying on Zeljko's body. I

22 could see that he had stab wounds and his throat was cut.

23 After we arrived from that yard to the bridge across the Una River

24 where they ordered us again to take the bodies out of the trailer and

25 throw them off the bridge into the water, I noticed that Knezevic Antun

1 also had his throat cut.

2 Q. What happened to these body -- bodies?

3 A. I was ordered to throw them off the bridge, but we were so

4 exhausted that we were not able to lift the bodies. So these Serbs,

5 including Mirko Sarac and Milan Petrovic and all the others, they took the

6 bodies and threw them.

7 JUDGE MOLOTO: Just for clarity's sake, is Abaza's first name

8 Zeljko or Veljko? I thought earlier the witness had corrected it to say

9 Veljko, V instead of Z at the beginning. Can we just get that clarified?

10 MS. RICHTEROVA:

11 Q. Was it Zeljko Abaza or Veljko Abaza. Can you please clarify this

12 point?

13 A. It was Zeljko Abaza.

14 Q. After these Serb bodies were thrown into river, what happened

15 then?

16 A. They ordered me to put one leg over the fence and in fact to go on

17 the other side of the fence on the bridge so that they could shoot us and

18 we would end up in the river.

19 Q. What happened then? Did -- did you end up in the river?

20 A. No. Because at that time a patrol showed up, their own Serb

21 patrol, and stopped them from committing this crime.

22 Q. After they stopped, what happened to you? Where -- where were you

23 taken after that?

24 A. We were sent back to the command, to that building and to the

25 toilet, and that's where we stayed until the morning.

1 Q. And it was you and who else returned?

2 A. I and Mico Coric.

3 Q. You also mentioned before that there was one Idriz Causevic

4 detained together with you in that toilet. Do you know what happened to

5 Idriz Causevic?

6 A. Yes. About three days earlier, he was taken out of the toilet.

7 We heard moaning, groaning coming from Idriz, and then after a while when

8 it was our turn, when Ante and Zeljko were killed that night, they told us

9 that he had been moaning and groaning. We wondered what would happen to

10 us. He was moaning and wondering what would happen to him. And then we

11 found out that he had been killed. We knew he would never return again.

12 Q. And did you ever see Idriz Causevic again?

13 A. No.

14 Q. You testified that you and your -- your nephew returned back from

15 that bridge back to the old school building, back to the toilet. What

16 happened after that? How long did you stay in this building?

17 A. After we had returned to the building, they gave us some water and

18 some brooms to wash away the blood with from the asphalt parts. We had to

19 clean up the blood from the asphalt parts. We did that. And once we had

20 done that, we were sent back to the toilet, and we stayed there until the

21 morning. Son was on duty. He spent the entire night there on duty. He

22 observed what was happening throughout the night. Although he did not

23 authorise them to act in the way that they did, he was quite simply

24 helpless. He couldn't do anything for us or for the other two or three

25 individuals whom they killed.

1 Q. After these three men were killed, did they continue with the same

2 treatment as before, I mean the beatings every day, or did something

3 change?

4 A. Yes. All sorts of things happened. They took us away to work.

5 We would gather the livestock and drive them to a farm. That's where we

6 drove the livestock to. And at one point in time while we were working we

7 noticed a helicopter. And the Serbs who worked with us, who guarded us

8 and who ordered us to work commented on the event and said that Martic had

9 arrived by helicopter from Krajina. They said that he couldn't come to

10 Hrvatska Dubica, that he had flown over Serbia, that he was keeping to the

11 Serbian side, and they said he would land there and would be driven to

12 Zivaja from there.

13 Q. Do you know why he couldn't come to Hrvatska Dubica? Do you know

14 why? Did they explain why he couldn't come to Hrvatska Dubica?

15 A. Yes. There was some sort of a conflict, some sort of a quarrel

16 between the president of the SDS, Mile Misljenovic, and the Jovo

17 Misljenovic. I don't know why there was a quarrel. Apparently their own

18 rebellious Serbs had opened fire on Misljenovic's house and they wanted to

19 kill him. But he managed to flee to Knin. He got away. And he told

20 Martic about what had happened in Hrvatska Dubica. And that's how I know

21 that Martic was present.

22 After a while, they took us to Zivaja, the village of Zivaja,

23 which was inhabited by Serbs, and there was a command there. I found out

24 that Martic was a guest. And they took us to show two Ustashas to him.

25 They took us there so that Martic could see us.

1 After a while they returned. They said Martic didn't want to

2 bother with us. They were going to take us back to Hrvatska Dubica. He

3 didn't want to spoil the fun and the celebration apparently. I don't know

4 what kind of a celebration was on. And they returned us or took us back

5 to Hrvatska Dubica.

6 Q. So you never -- you didn't see Martic in Dubica or Zivaja

7 personally, only heard that he was present?

8 A. No, I didn't see him there. I only heard that he was present.

9 That's what the Serbs said. And they told us why they were taking us from

10 Hrvatska Dubica to Zivaja.

11 Q. For how long were you detained?

12 A. For five months.

13 Q. Was there any time when the people who detained you and you -- you

14 also stated their name, including Stevo Radjunovic and Kovacevic. Was

15 there a time when these people left or were replaced?

16 A. Yes. There was a transfer of power. I don't know on how many

17 occasions. Changes of authority. Some people were thrown out of the

18 command. The JNA, the military police arrived. They took over, and after

19 a certain period of time the JNA and military police were expelled, and

20 they returned to power again and stayed in power.

21 Q. When you said that some people were thrown out, do you know

22 exactly who was thrown out?

23 A. Yes. I'm referring to Momcilo Kovacevic and Stevo Radjunovic.

24 Q. You stated that you were detained for about five months. After

25 you were released, where did you go?

1 A. I stayed on in Hrvatska Dubica until the end of November or the

2 beginning of December. And then an officer from the JNA arrived and from

3 the military police. They were going to take me to Prijedor, to a prison

4 in Prijedor. But, in fact, with the help of a Serbian friend of mine, he

5 helped me to save myself. They took me to Prijedor, and I spent some time

6 in Prijedor. I was then transferred to Banja Luka. And after a while, on

7 the 10th of February, 1992, I was exchanged and I went to Slavonski Brod.

8 Q. I would like to return a little bit back when you were still in

9 prison. First, you mentioned this Kovacevic and Radjunovic, that they

10 were thrown out. Do you know by whom?

11 A. I don't know. There are all sorts of stories circulated when the

12 JNA arrived, the military police arrived and took power. Well, I don't

13 know who threw them out, who expelled them. It was said that the

14 White Eagles, that Seselj's men had arrived from Belgrade and that they

15 had put the military police and the JNA in power. Naturally, after they

16 left, when they returned to Belgrade these people returned from Bosnia and

17 toppled over the power structure. They expelled the JNA and the military

18 police, and they once again took -- took power, and they were the lords

19 and masters in the area.

20 Q. While you were in police, did you learn what happened to people

21 who lived in Croatian villages?

22 A. I don't understand your question.

23 Q. While you were still in prison [Realtime transcript read in error

24 "police"], did you have opportunity to learn from either soldiers or

25 somebody else what happened to civilian who stayed behind in Croatian

1 villages like Cerovljani, Bacin, Dubica, et cetera?

2 A. Yes, I did. I found out that they had been taken away -- rather,

3 they had been assembled in a hall, a club, where they were guarded. And

4 naturally, while we were involved in rounding up the livestock, while we

5 were involved in performing our duties we saw these people. Naturally, we

6 heard from Serbian soldiers who were with us and who were guarding us that

7 they had rounded up these people. Apparently they were going to be

8 exchanged in Glina, but in fact captain first class went to see Mico

9 Coric. He addressed him and told him what had happened on that occasion.

10 And Mico Coric's mother had been placed in that club, in that hall, and

11 taken to Glina for an exchange. But in fact they did not end up in Glina.

12 They were not exchanged. They were taken to Rezani [phoen] near a place

13 called Bacir, and they were killed there.

14 When this captain spoke to Mico Coric, he didn't in fact tell him

15 that is what had happened, but in the course of their conversation he

16 tried to address this matter in an indirect way and tell him what had

17 happened. He tried to insinuate certain things.

18 Q. First, I would like to -- there needs to be a correction on

19 page 31, line 24. I asked were you were in prison, and this line says

20 while you were in police. So that needs to be corrected.

21 I think the interpreters also didn't get the name of the place

22 where these people were supposedly killed. You said Bacina -- Bacin. It

23 was near of which place?

24 A. You mean Bazan Knezevic [as interpreted]?

25 Q. No, I apologise. You stated that --

1 A. We're referring to civilians. The place was called Bacin Krecane

2 near Bacin. I've mentioned this place. Krecane near a place called

3 Bacin.

4 Q. Thank you, Witness. We just didn't understand, so I wanted you to

5 repeat this -- this place so we have it correctly in the transcript.

6 Do you know approximately how many people were -- were,

7 altogether, killed?

8 A. It's difficult to say. I don't know how many people were killed,

9 but since an exhumation was carried out and it's a mass grave, all those

10 from the Croatian villages and all the people -- well, some of them were

11 identified, whereas others are still recorded as missing. I don't know

12 what the number is, but perhaps about 90 individuals are concerned.

13 Q. And you also mentioned that Mico Coric was asking about his

14 mother, what happened to his mother. Do you know what happened to

15 Mico's -- Mico Coric's mother?

16 A. Yes. After Operation Storm and after Croatian authority had been

17 established within the borders of Croatia, an exhumation was performed,

18 and Mico Coric's mother was discovered. Her body was exhumed.

19 Q. Did you also return to your village after the Operation Storm?

20 A. Yes, I did.

21 Q. What did you find? How did the village look like?

22 A. When I returned to my village I couldn't recognise it. A lot of

23 things had been destroyed and burnt down. Excavators had been used to

24 remove the rubble of houses. Later I found out that they had transported

25 this through the forest in lorries, and they had made sort of roads there

1 so that they could attack the Croatian defence forces with cannons and

2 tanks and other equipment.

3 Q. You said that everything was burned down. Were -- were all houses

4 burned down? Were all Serb and Croatian houses, or were there only houses

5 of one of these ethnicities?

6 A. Yes. Only Croatian and Muslim houses had been burnt down and

7 destroyed.

8 Q. Thank you, Witness.

9 MS. RICHTEROVA: Your Honour, I concluded my examination-in-chief.

10 JUDGE MOLOTO: Thank you very much, Ms. Richterova.

11 Mr. Milovancevic.

12 MR. MILOVANCEVIC: [Interpretation] Thank you, Your Honour.

13 Cross-examination by Mr. Milovancevic:

14 Q. [Interpretation] Witness, I am counsel for Milan Martic. I will

15 now be conducting the cross-examination. I assume that you know what this

16 means. To make sure that the interpreters can do their work, I'd be

17 grateful if you could pause once I have put a question to you before

18 answering the question.

19 In the statement you gave to the Prosecution, you said that you

20 were born in Hrvatska Dubica and that you spent your entire life there.

21 You also said that the Croats were in the majority there; is that correct?

22 A. Yes, that's correct.

23 JUDGE MOLOTO: [Previous translation continues] ... from the

24 statement of the witness, Mr. Milovancevic, and the Chamber?

25 MR. MILOVANCEVIC: [Interpretation] Thank you, Your Honour. We

1 will distribute copies of the statement for all those who are present in

2 the courtroom.

3 Your Honour, the first statement given to the Prosecution is not

4 in English. We have provided you with a copy of this statement. So

5 perhaps I could ask my learned friend for the Prosecution to be of

6 assistance to the Trial Chamber.

7 MS. RICHTEROVA: We have an English version. Are you referring to

8 2000 -- 2000?

9 MR. MILOVANCEVIC: [Interpretation] Yes, that's correct. Thank

10 you.

11 May I continue, Your Honour?

12 JUDGE MOLOTO: You may continue if you will please indicate which

13 statement you are using. Is it the 2000 one or the 2002 one?

14 MR. MILOVANCEVIC: [Interpretation] Your Honour, since there are a

15 number of statements, whenever I put a question to the witness I will

16 specify which statement my question concerns, whether it's the one given

17 in the year 2000 or the one given in the year 2001.

18 I will now put some questions to the witness which won't relate to

19 any particular statements or in which I won't be quoting anything from his

20 statements.

21 Q. In your testimony, you mentioned the house of your parents in the

22 village of Predore. Where is that village in relation to Hrvatska Dubica?

23 How far away is it from Hrvatska Dubica?

24 A. In my statement and when giving evidence I have already said that

25 my village is eight kilometres from Hrvatska Dubica. I will repeat this

1 if you can't remember it.

2 Q. Thank you. You said that you did your military service, your

3 regular military service. When did you do your military service, and was

4 it in the JNA?

5 A. Yes. It was in 1989 and 1990 in the JNA, the Yugoslav People's

6 Army.

7 Q. When you were serving in the military, were there soldiers and

8 officers in the JNA who were members of all the ethnic groups in

9 Yugoslavia, Serbs, Croats, Macedonians, Albanians, et cetera?

10 A. Well, at the time I wouldn't put it in that way. At the time the

11 system was falling apart. It was breaking up. The Serbs and the Serbian

12 army were in power, although it was called the Yugoslav army. But at the

13 time I was in Kosovo, and problems had arisen with the Albanians in

14 Kosovo, and it was possible to notice, although I wasn't a soldier at the

15 time, the JNA were using force. I had to serve in their army. And at the

16 time, Slovenia wasn't allowing its inhabitants to cross the Slovenian

17 border and to do their military service outside of Slovenia.

18 Q. Can you tell us, already in 1989 when you were doing your military

19 service, problems with Albanians in Kosovo were already in evidence. What

20 kind of problems?

21 A. I can't tell you what kind, but I can tell you that already in

22 1990, in end December and all the way up to March 1990, while I was doing

23 my military service, we all knew what was going to happen, what the JNA

24 was, and what it was all about. I sensed this very clearly. And many

25 officers often told me, in very obscene terms, that I am Tudjman's

1 motherfucker. Stipe Mesic was then the Croat president. They didn't let

2 him assume his post in the Presidency. And all of us who were non-Serbs

3 realised what was going on.

4 Q. You said in 1989 and 1990 the Slovene leadership wasn't allowing

5 its conscripts to do the military service.

6 A. They didn't want them to serve outside the borders of Slovenia. I

7 don't know why exactly this came about, but from my understanding they

8 could no longer agree who was going to be president of the former

9 Yugoslavia, whether a Slovene or a Croat or a Bosnian or an Albanian or a

10 Serb would be the president.

11 Q. We now move to a subject that I wasn't intending to raise, and I

12 don't really want to extend your testimony to what is not covered by your

13 statement.

14 Tell me just one thing: In 1990, is it the case that Stipe Mesic

15 was a member of the Presidency, being a Croat? The Prime Minister was

16 also a Croat, Ante Markovic? The chief commander of the air force was a

17 Slovene? His name was Anton Tus. Is that true?

18 A. I'm not a politician. I don't want to talk about things I don't

19 know and who occupied which post.

20 Q. Regarding the army, because you happened to be doing your military

21 service right at that time in 1990, I'll ask you one more question.

22 Apart from the JNA, which was the regular army, you mentioned that

23 there was also the Territorial Defence in existence.

24 A. That's correct. In the times of Yugoslavia, it existed.

25 Q. Would I be right in saying that according to the laws and the

1 constitution of Yugoslavia each republic, each autonomous province and

2 even each local commune had its own Territorial Defence and that all

3 ethnicities were included in this Territorial Defence, all who were able

4 to carry a rifle?

5 A. I don't know if you would be right, but that was how it was.

6 Q. Thank you. Your testimony covers the period from 1990 onwards.

7 You said that up to 1990, in fact until the elections, human relations,

8 regardless of ethnicity, were good.

9 A. Perhaps you could say that. All the way up to the elections. But

10 once the elections were over and when Croatia formed its own government,

11 those people who served in the police, depending on which ethnicity they

12 belonged to, wore different emblems. Croats wore the chequer-board emblem

13 and Serbs continued with the five-pointed star.

14 Q. You mean to say that after the 1990 elections the Croatian

15 authorities insisted on their own independent state, whereas Serbs

16 insisted on continuing to wear the five-pointed star that symbolised the

17 former Yugoslavia?

18 A. Yes, something like that.

19 Q. Elections were held in Dubica in 1990 like in other places. Can

20 you tell us if it is the case that the greatest majority of the people in

21 Dubica voted HDZ?

22 A. I don't know who they voted for, but I know the HDZ won the

23 elections, the Croat Democratic Union.

24 Q. In your statement given to the OTP in 2000, page 2, paragraph 6,

25 you mention that soon after the elections in 1990 Croats stepped out of

1 the Territorial Defence and formed their own Home Guards Corps, ZNG, as a

2 separate armed formation.

3 A. I no longer remember what I stated five or six years ago.

4 Q. But is it true? Did it happen this way? The Croats left the

5 Territorial Defence after the elections in 1990 and established the ZNG,

6 the Home Guards Corps?

7 A. If I said that and if it's recorded in the statement, there is no

8 reason to retract from that now.

9 Q. When you say that Croat residents stepped out of the Territorial

10 Defence that covered the entire population of Yugoslavia, does it mean

11 that they left it of their own will?

12 A. What do you mean?

13 Q. You said that Croats stepped out of the Territorial Defence after

14 the elections in 1990, and I'm asking you does this mean that they left of

15 their own free will?

16 A. Well, I don't know what would be more correct to say, that they

17 were expelled or that they left on their own free will. It's true that

18 they left and that after that they formed their own police force and their

19 ZNG, the Home Guards Corps.

20 JUDGE MOLOTO: Mr. Milovancevic, can I ask that you give each

21 other space between question and answer.

22 MR. MILOVANCEVIC: [Interpretation] Thank you, Your Honour. I'll

23 pay more attention to that.

24 Q. You have stated to the OTP in your first statement that after the

25 1990 elections the Home Guards Corps was established, and its commander

1 for the region was Tomislav Mateljak. Is that so?

2 A. Yes, that's correct.

3 Q. On page 2, paragraph 8 of your first statement to the OTP from the

4 year 2000 you mentioned that you personally thought of Mateljak as a

5 criminal, unemployed scum who had lived in a shanty in Dubica before the

6 war, and he came into power during the war. He became powerful.

7 A. That's correct.

8 Q. Also in paragraph 8, you say that Mateljak was in charge of

9 organising and arming the Croats. Do you mean to say the Croat population

10 there?

11 A. Yes.

12 Q. In your statement to the OTP from year 2000 in the seventh

13 paragraph you say that after the ZNG was established, the relationship

14 between Serbs and Croats in the village started to change, that the first

15 signs of mistrust between the two sides appeared, and they started to fear

16 each other. Nobody felt safe anymore.

17 A. Yes, I said that. After the Croats formed their authorities,

18 however, the Serbs continued on the police force, but they did not accept

19 the new emblem of the Croatian state, the chequer-board. They continued

20 to wear the five-pointed star, and the Croatian authorities would not

21 allow this kind of inconsistence. They tried to enforce their new emblem,

22 and Serbs of course didn't give in. They went to the woods, became

23 renegades, and started to form their own units, some Chetnik units on the

24 pretext that they represented the defence forces of the old Yugoslavia,

25 namely the TO, the Territorial Defence.

1 Q. Witness, we'll come to the JNA and the TO later. Let us now stick

2 to these developments in your village.

3 You stated earlier today, and it's in your statement, too, that

4 Serbs would go across the Una River to spend the night in Bosanska Dubica,

5 and they would return every morning. But now you also say that they

6 spread false rumours and they returned during the day.

7 A. That's what I said. They went to Bosnia, across the river. They

8 spread propaganda. They lied to the JNA and the military police in order

9 to make the JNA believe, and other Serbs as well, that it's necessary to

10 topple the new Croatian authorities and to enable them to be back with

11 their five-pointed stars and cockades.

12 When I say that they went across the river to Bosnia, I mean to

13 say that they were going there to solicit assistance, to present

14 themselves as being in jeopardy. And their actions actually put them in

15 danger and the whole of Croatia in danger, because it was causing a

16 quarrel between Croatia and the JNA.

17 Q. Is that your position, your understanding of what happened?

18 A. No. It's just what happened. It's the reality.

19 Q. When you talk about those Serbs who went during the night to

20 Bosnia, who were they? Grown men, women, elderly men? Who went to

21 Bosnia?

22 A. Can you repeat that.

23 Q. What kind of people went to Bosanska Dubica during the night to

24 return in the morning? Who were they? Men, women?

25 A. No. Women and children stayed at home because they didn't think

1 they were in danger. They didn't think it necessary to go and spend the

2 night in Bosnia. Able-bodied younger men went across, people who were

3 able to carry a gun.

4 Q. Some witnesses we've heard earlier mentioned women and children

5 going to Bosnia, but you are saying something entirely different. So I'm

6 going to ask you what you meant when saying that Serbs spread false

7 rumours. Do you mean to say that the arming of the Croat population in

8 Hrvatska Dubica after the elections in 1990 was in the hands of a man whom

9 you yourself called the criminal, and how can it be perceived in a mixed

10 community?

11 A. Whatever I thought of him, I didn't think of him as a war criminal

12 and a murderer. That was simply my opinion of him.

13 Q. In your statement to the OTP, again paragraph 8, you said the

14 situation changed dramatically after the Territorial Defence arrested some

15 Croats, including this Tomislav Mateljak, and Predrag Vucicevic. What was

16 Vucicevic's ethnicity?

17 A. Croat.

18 Q. You said about Vucicevic that he had joined the police after the

19 Serbs left the police force. Does that mean that he was admitted to

20 replace some Serb policemen who left?

21 A. Yes, of course. But in fact, not necessarily, because he had been

22 a policeman before. He had served on the police force while Serb

23 policemen were still there.

24 Q. You said that those people who were arrested were taken by a

25 civilian truck to Kostajnica, that Mateljak managed to escape on the way,

1 whereas Vucicevic was exchanged for a Serb who had been captured. Who

2 captured that Serb?

3 A. The Croat police or the Croat army. I don't know who. What

4 mattered was that one Serb was captured and that was enough for the

5 exchange with Vucicevic.

6 Q. In your statement to the OTP from year 2000, paragraph 10, you

7 said that Serbs operating in the region wore the olive-drab uniforms of

8 the JNA or green camouflage uniforms with the insignia of SAO Krajina, a

9 crown and a cross with four S's in Cyrillic letters. Did you state that?

10 A. Yes.

11 May I ask the Honourable Trial Chamber for a break?

12 MR. MILOVANCEVIC: [Interpretation] In view of this request and

13 looking at the clock as well, could we -- or maybe I am premature in

14 asking for a break. Yes. I see now that it's my mistake, that we are to

15 go on a break on only 15 past 5.00, but maybe we can take into account

16 what the witness just asked.

17 JUDGE MOLOTO: The witness asks for a break, isn't it?

18 MR. MILOVANCEVIC: [Interpretation] Your Honour, the witness asked

19 for the break, and I thought it coincided with our regular break anyway,

20 but I was wrong.

21 JUDGE MOLOTO: Okay.

22 MS. RICHTEROVA: Your Honour, I would just want to inform that

23 this witness flew in today after -- after working yesterday, so I assume

24 that he must be very tired.

25 JUDGE MOLOTO: Okay. Can we take a break for -- our normal break

1 for 30 minutes, and then we will come back at half past 5.00.

2 Court adjourned.

3 --- Recess taken at 5.01 p.m.

4 --- On resuming at 5.31 p.m.

5 JUDGE MOLOTO: Mr. Milovancevic. Just before you proceed,

6 Mr. Milovancevic.

7 Is the witness in a position to carry on until the end of the day,

8 7.00 today?

9 MS. RICHTEROVA: Your Honour, you will have to ask. I have no

10 contact. I'm not allowed to have contact with the witness. We only

11 informed VWU that he wasn't feeling well, or, let us say, he was tired,

12 but I haven't received any further information on that issue.

13 JUDGE MOLOTO: Okay.

14 Witness, can I just ask, are you -- do you feel in a position to

15 go on? We're supposed to knock off at 7.00 tonight. Can you make that?

16 And if you can't, please say so that we break off at some stage to give

17 you time to take a break.

18 THE WITNESS: [Interpretation] I can continue. It's not a problem.

19 Everything is fine.

20 JUDGE MOLOTO: Thank you. But just do mention it when you need a

21 break. Thank you very much.

22 You may proceed, Mr. Milovancevic.

23 MR. MILOVANCEVIC: [Interpretation] Thank you, Your Honour.

24 Q. Witness, I'll now continue with my cross-examination. If you feel

25 you need a break, please don't hesitate to inform us of the fact.

1 A. I'll do so.

2 Q. When describing the circumstances under which you joined the ZNG,

3 you said it was in the summer of 1991. Is that correct, Witness?

4 A. Yes, that's correct.

5 Q. In the statement that you gave to the Prosecution in the year 2000

6 on page 3, paragraph 12, you stated that towards the end of July, 1991,

7 you and your brother Dragan and your cousin Mico Coric went to Kutina

8 because you were not members of the HDZ and you didn't want to fight

9 anyone. However, the Croatian police found you and returned you to Dubica

10 and said that you had to join the ZNG. Is that in fact what happened?

11 A. I don't know which month that happened in. It's difficult for me

12 to remember exactly what I said, but that is in fact what happened.

13 Q. In the summer of 1991 when you returned from Kutina to Dubica, who

14 else was active apart from the ZNG? Which other Croatian forces were in

15 existence? Were there any members of the Croatian police?

16 A. When I returned from Kutina, there were Serb members of the police

17 force. They were still members of the police force at the time.

18 Q. Were these policemen part of the Ministry of the Interior of the

19 Republic of Croatia at the time?

20 A. They should have been part of that ministry.

21 Q. At the time was there a local police station in Hrvatska Dubica,

22 in the summer of 1991, and before that time? I'm referring to the period

23 1990 to 1991.

24 A. Yes. From the period of the former Yugoslavia. It was the former

25 police.

1 Q. You're referring to the Yugoslav police; is that correct? Does

2 that mean that the Croatian Ministry of the Interior in 1991 took over the

3 police station that had previously existed, that had existed in the -- the

4 former Yugoslavia, in Hrvatska Dubica? Is that what you are claiming?

5 A. Yes, that's correct.

6 Q. Thank you. Apart from the ZNG and the so-called local police

7 force, the MUP, the Ministry of the Interior in Dubica, were there any

8 other Croatian policemen who came from outside, from other areas in

9 Dubica?

10 A. Well, there were very few of them, very few policemen who had

11 actually trained as policemen, but there were some.

12 Q. In the statement that you gave to the Prosecution in the year

13 2000, on page 3, paragraph 14, you said that Croatian policemen from

14 Moslavina were at the bridge and that they ordered you to open sniper fire

15 on soldiers who were on the other side of the river. Is that what

16 happened?

17 A. Yes. There were policemen from Moslavina there, and I don't know

18 from which other parts of Croatia they came from.

19 Q. At the time you were a member of the ZNG. Were you issued with a

20 uniform and a weapon?

21 A. I had some sort of a rusty weapon, but I didn't have a uniform at

22 the time.

23 Q. In the statement you gave to the Prosecution in the year 2000

24 paragraph 13 on page 3, you said that you thought that all HZD [as

25 interpreted] members had uniforms. You said that you didn't have a

1 uniform but that all members of the HZD had uniforms at the time. Is that

2 correct?

3 A. Yes, one could say so. Some had such uniforms, but there were

4 others who didn't. Not everyone had a uniform.

5 Q. Do you know where these uniforms and weapons came from, the

6 uniforms and weapons that were distributed?

7 A. Well, that's a very difficult question. I really wouldn't know.

8 Q. When you became a member of the ZNG, you said that Tomislav

9 Mateljak issued a sniper rifle to you. It had a sight, a scope, a sniper

10 scope. Is that correct?

11 A. Yes, that's correct.

12 Q. In the continuation of the statement that you gave to the

13 Prosecution in the year 2000, you explained that you refused to obey the

14 orders issued to you by the Croatian police men from Moslavina. They

15 ordered you to open fire on the soldiers on the other side of the river

16 and after your refusal Mateljak took your rifle from you and you were

17 reassigned to work in the kitchen. Is that correct? Is that what you

18 said?

19 A. That's correct. That's what I said.

20 Q. This statement that we have been referring to, the statement that

21 you gave to the Prosecution in the year 2000, you also said that several

22 days after this event with the sniper rifle you were informed of the fact

23 that Stojan Bekic's house was on fire. What was the ethnicity of Bekic

24 and where was his house located?

25 A. Stojan Bekic, he was a Serb. He had a house in Hrvatska Dubica.

1 And in my village, the village of Predore, he had a ranch, and his ranch

2 was on fire and a little house on the ranch.

3 Q. Do you know why his house had been set on fire? Do you know what

4 the cause of the fire was?

5 A. No, I don't know why it was on fire. I don't know how -- how the

6 house caught fire.

7 Q. Thank you. In the statement that you gave to the Prosecution in

8 the year 2000, you said that when you heard that Bekic's house was on fire

9 you went to the village of Predore and the local inhabitants had said that

10 they had seen a JNA helicopter land near the house. They had delivered a

11 lot of weapons that were taken the neighbouring Serbian villages of Zivaja

12 and Sas. They were taken there by lorry. Is that what you said?

13 A. Well, what I said about Stojan Bekic, yes, I didn't know that his

14 house was on fire, but I was informed that there was a house on fire in

15 the village of Predore. I didn't know that it was his house. But when we

16 arrived in the village, we heard that the house in question was in fact

17 Stojan Bekic's house or, rather, it was his ranch that was concerned.

18 That's what we heard and that's what we saw.

19 Q. So what you have just said explains why you went to the village of

20 Predore. You heard that there was a fire there and you went to see your

21 mother's house. Have I understood you correctly? And then you realised

22 what had happened there once you reached the village. Is that correct?

23 A. Yes, that's correct. You're quite right about that.

24 Q. You haven't answered my question about how the inhabitants told

25 you that they had seen that a helicopter had landed in the vicinity of

1 their houses, a helicopter with a lot of weapons. When you were in

2 Predore, when this house was on fire, did the inhabitants tell you that

3 they had seen this helicopter with the weapons?

4 A. No. That's not what I said. I didn't say that the inhabitants

5 had told me that they had seen this helicopter, that my mother and a

6 neighbour had told me that a helicopter had landed in the forest. I said

7 that I had seen the helicopter and the weapons. I didn't say that it was

8 the inhabitants who had seen the helicopter.

9 Q. That's correct, Witness. That was your evidence today. However,

10 in the statement that you gave to the Prosecution in the year 2000, you in

11 fact said that when you went to the village of Predore because of the fire

12 that was there, the inhabitants told you that a JNA helicopter had landed

13 and that weapons had been unloaded from the helicopter. Is that what you

14 stated to the Prosecution?

15 A. Perhaps that is what I stated to the Prosecution, but perhaps an

16 error was made. The fire took place in the evening hours. And after I

17 had arrived there, the inhabitants told me and my mother told me that a

18 helicopter had flown over during the day. A helicopter had flown over the

19 area.

20 JUDGE MOLOTO: Mr. Milovancevic, this is not your problem, but we

21 do have a slight problem. You keep referring to the number of the

22 paragraph. The English version is not numbered, and we find it very

23 difficult to follow. I'm particularly interested to see in his statement

24 on this point that you are now talking about. Could you tell us how the

25 paragraph begins?

1 MR. MILOVANCEVIC: [Interpretation] Your Honour, I would just like

2 to tell you that we received the statement from the Prosecution, and each

3 paragraph is marked in pencil in order to make it easier to find our

4 bearings. I'll tell you where this paragraph is. When I say paragraph,

5 well, in fact, these are just various passages so that we can find on

6 various pages.

7 The part of the text that I was referring to when questioning the

8 witness is on page 3 of the B/C/S version of the statement, the statement

9 given to the Prosecution in November 2000. It's the last paragraph at the

10 bottom of the page. The number is 02964236. So the passage starts

11 with the words: "After that I was transferred to the kitchen," and then

12 the text that follows describes the fire in Predore and the visit to his

13 mother. That is the paragraph I was referring to.

14 Thank you, Your Honour.

15 Q. Witness, I was just trying to refer to what you stated in your

16 statement, and I think it doesn't quite tally with your evidence given

17 today. This is why I'm asking you what is in fact correct. You said that

18 you went to visit your mother when this fire occur. You said that you

19 reached your family house. Your mother was afraid, and the inhabitants

20 said that they had seen a JNA helicopter landing in the vicinity of the

21 houses. JNA was inscribed on the helicopter, and many weapons were loaded

22 onto a civilian lorry from the helicopter, civilian lorry that belonged to

23 Electra. The civilian inhabitants saw this lorry transferring the weapons

24 to the neighbouring Serbian villages of Zivaja and Sas. And now my

25 question is: Do you remember having given such a statement to the

1 Prosecution?

2 A. Yes, I remember that statement very well.

3 JUDGE MOLOTO: Ms. Richterova was on her feet. Can we hear what

4 she's got to say, Mr. Milovancevic.

5 Yes, Ms. Richterova.

6 MS. RICHTEROVA: In fact, I referred to Mr. Milovancevic's

7 question, what is correct that what he said today is something different

8 what is in his statement from 2000 and -- from 2000, and I just want to

9 refer to his statement from 2002 in which he says that he saw it. And to

10 that effect, he testified today.

11 JUDGE MOLOTO: Thank you, Ms. Richterova. Maybe that's something

12 you could have raised in re-examination. It's okay.

13 MR. MILOVANCEVIC: [Interpretation]

14 Q. Witness, can you tell me whether these neighbours of yours told

15 you how it was that they knew that this Electra lorry was transporting the

16 weapons to the villages of Sas and Zivaja? Did they tell you how they

17 knew that?

18 A. I didn't say that they told me that they had seen the weapons.

19 I'll repeat this. I don't remember having said that the local people told

20 me that they had seen the helicopter delivering weapons. I said that I

21 had seen that, but the local people said that prior to that event on a

22 number of occasions a helicopter had landed at the same site. And as I

23 have already said, on one occasion when I was going home my mother told me

24 that a helicopter had landed than it was there. I went and saw what had

25 happened.

1 Q. Can you tell me how far the village of Zivaja is from Predore and

2 in which direction is the village located?

3 A. Well, I'm not quite sure what you mean when you say in which

4 direction it is. You mean to the south, to the east, to the north? I

5 think it's to the north from my village, from the village of Predore. And

6 if you take the path that goes through the forest, it's perhaps 15 or 20

7 kilometres away. Perhaps less than that. And if you go through my

8 village, then it would be about six or seven kilometres.

9 Q. In your second statement to the OTP from 2002, on page 2, in what

10 I would call paragraph 2, you said that JNA helicopters carrying

11 ammunition and weapons landed in the forest near Zivaja and Sas villages,

12 several occasions, and then their load would be transferred by trucks to

13 surrounding villages.

14 A. No, I didn't say Zivaja and Sas. I said they landed near my

15 village only 600 metres away from the village itself and then they

16 probably transferred the load by trucks.

17 Q. What do you mean by "probably"?

18 A. That means that I was there and saw with my own eyes what that

19 helicopter was doing and what was going on, and I concluded that on all

20 the other occasions they came, they came for the same purpose, to bring

21 weapons.

22 Q. You say that you concluded that as soon as the helicopter came

23 there their mission was to bring weapons. Did you look as it happened?

24 A. I'll tell you this again: My mother told me that the helicopter

25 had come several times before. So I went to the woods to see for myself

1 what was going on when the helicopter lands. And indeed, they transferred

2 the load, the weapons and ammunition to Electra company trucks, and all

3 the other things that I've already mentioned.

4 Q. You said that those villages, Zivaja and Sas, to which the

5 weaponry was destined was several kilometres away from the landing site.

6 Can you explain to me why the helicopter didn't land right in that

7 village, Zivaja or Sas? Why would the trucks go 10 kilometres back and

8 forth?

9 A. I couldn't answer that. I couldn't quite understand myself.

10 Q. You also said that those trucks and pickups drove the weapons to

11 Zivaja and Sas. Did you ever go to Zivaja and Sas to see those trucks

12 arrive carrying weapons?

13 A. No, I did not. But I know very well that those same weapons were

14 brought to Hrvatska Dubica as well.

15 Q. At that time when you became member of the ZNG, when you were on

16 the bridge and when you were issued with a sniper, you were a member of

17 the ZNG, and you spent very little time in your own village.

18 A. Correct.

19 Q. So how can you say that in the period when the helicopter landed

20 in Zivaja and Sas it occurred almost on a daily basis if you yourself were

21 in Dubica?

22 A. I told you that I went several times to visit my mother and that

23 my mother told me about it. And I'm telling you again the helicopter

24 didn't land in Zivaja or Sas. It landed about 800 metres from my village.

25 Q. Does all this mean, Witness, that it is on the basis of your

1 mother's words and what you heard from other people that you concluded the

2 helicopters were carrying weapons?

3 A. What was I supposed to conclude, that they were carrying crisps?

4 Q. Thank you. In your statement to the OTP, page 2000 [as

5 interpreted], paragraph 17 as I marked it. That would be the third

6 paragraph from top of the page. You said that on the order of Croatian

7 President Franjo Tudjman Tomislav Mateljak ordered the Croat population to

8 be evacuated from Dubica and surrounding villages. Is that so?

9 A. Yes. That happened sometime after Dvor Na Uni and Hrvatska

10 Kostajnica fell. Maybe two or three days later the order came that we,

11 the Croatian army, the ZNG, were too weak to keep Hrvatska Dubica under

12 control and that we had to withdraw before the Chetniks, the JNA and all

13 the rest.

14 Q. Is -- was that an order to the effect that civilians should

15 withdraw or that you, the troops, should withdraw?

16 A. I don't know what the order exactly was, but first of all

17 civilians were to retreat and then the troops.

18 Q. Do you know where the civilians went from Hrvatska Dubica?

19 A. I know they went to Jasenovac, across the Sava River towards

20 Moslavina. They found places to stay just to be able to survive.

21 Q. After the civilians left Dubica, did the Croatian police and

22 members of the ZNG remain?

23 A. Could you repeat that?

24 Q. I said after the civilians left Hrvatska Dubica, did Croat

25 policemen and members of the Home Guards Corps remain in Dubica?

1 A. No, they did not. They, too, pulled out.

2 Q. You mentioned in your statement that Serb positions were then

3 shelled by the Croat side from a moving train.

4 A. I said there were mortars mounted on the train, and I explained

5 what their purpose was. They had no precision to speak of, and they could

6 hardly even reach the Serb positions with their range. It was more of a

7 propaganda move and perhaps designed to gain some time to pull out the

8 Croatian population, and the Serbs were victims of their own propaganda,

9 and they were fanning their own fears.

10 Q. You just said that mortar shells fired from the moving train were

11 a propaganda move.

12 A. No. I said that that was meant to secure a retreat, to sort of

13 gain time before the Serbs, to intimidate them a little so that Croat

14 civilians and troops have time to move out.

15 Q. You said that it was Tudjman's order to pull out the civilian

16 population, that Mateljak passed this order on, and that the train

17 continued firing even after that was done.

18 A. Ask me something easier. I've told you this many times, that an

19 order came from Tudjman that we did have enough men, we didn't have the

20 kind of weapons that would repel the Serb aggression, and that we had to

21 retreat.

22 Q. You said in your statement and in your testimony earlier today

23 that at one point the bridge near Hrvatska Dubica was destroyed. When and

24 who destroyed it?

25 A. Croatian troops and Croatian police, because as they were running

1 away before JNA tanks and howitzers, they destroyed the bridge in order to

2 prevent Serb reinforcements and JNA reinforcements to come from Bosnia.

3 Q. I'm sorry about this. Did I interrupt you?

4 A. No, no. Please go on.

5 Q. Would I be right if I remind you that the bridge was destroyed on

6 the night of the 13th September 1991? That's what you testified. Does

7 that date mean anything to you?

8 A. Yes, of course it means something to me. On that night, that date

9 when the bridge was destroyed, there was shooting from the Bosnian side on

10 several occasions. On the Croatian side they fired on churches as well.

11 The Croat side was targeted from mortars. Shells were hitting houses, the

12 road, the church. Cannons were firing at the church. JNA aeroplanes

13 broke the sound barrier, and walls cracked and windows were shattered.

14 Q. You said that Croats held power and all the official positions in

15 Hrvatska Dubica. You said that Hrvatska Dubica had a headquarters of the

16 ZNG, that it was an Assembly point for Dubica, Bacin, and Cerovljani units

17 of the ZNG?

18 A. Yes. In the defence sense. We had defence structures in

19 Cerovljani, Dubica and Bacin.

20 Q. If I understood you correctly, that's September 1991. The

21 Socialist Federal Republic of Yugoslavia was still in existence together

22 with its federal army, the JNA. So who was the ZNG defending in Croatia?

23 A. You mean who was it defending? Is that some sort of provocation,

24 this question?

25 Q. No, it didn't certainly, but if you don't like it, we'll move on

1 to another one.

2 A. Yes, please.

3 Q. When you are describing the situation surrounding the destruction

4 of the bridge, would you say that the Croatian police destroyed the bridge

5 between Bosanska Dubica and Hrvatska Dubica to prevent the JNA tanks from

6 crossing?

7 A. Yes, but you didn't ask me who was manning those JNA tanks. Do

8 you want me to answer? Or perhaps you know the answer already.

9 Q. I know that that -- at that time the president of the Yugoslav

10 Presidency was Stjepan Mesic and the federal Prime Minister was another

11 Croat, Ante Markovic.

12 But as for your statement to the OTP from 2000, on page 4 you said

13 that on the 15th of September, 1991, around 50 persons of Serb ethnicity

14 wearing green camouflage uniforms and olive-green uniforms of the JNA

15 surrounded the Predore village. Is that so?

16 A. Which date did you say?

17 Q. It's actually you who said that it was on the 15th of September,

18 1991.

19 A. Yes. Yes.

20 Q. You said earlier in your testimony, and it's also in both your

21 statements, that you recognised among them Momcilo Kovacevic, Stevo

22 Radjunovic, and Veljko Radjunovic. Is that so?

23 A. Yes, and many others.

24 Q. You said they searched houses and that those among you who had

25 weapons had discarded those weapons earlier.

1 A. Yes. There were two hunting rifles, and they had been thrown into

2 a well.

3 Q. You said they were making inquiries about the presence of soldiers

4 or policemen in the village, about the kind of weapons they had and the

5 presence of heavy weaponry on the Croat side.

6 A. I said they were pushing us in front of them like a live shield.

7 They were forcing us to the bank of the Sava River. On the other side of

8 the Sava River, there was Drenov Bog village. They asked us about the

9 population of that village, and I said I didn't know and that they should

10 look for themselves, which they did. And I told them, "You can have a

11 look and decide for yourselves how big the village is, how densely it's

12 populated," et cetera.

13 Q. Thank you. You also stated that after you were arrested eight of

14 you were taken to the old school building which housed, as you put it, the

15 Serb command in Hrvatska Dubica.

16 A. I didn't say eight of us were taken there. I said Mico Coric and

17 I were taken there.

18 Q. Both today and in your statement of year 2000 on page 5, you said

19 at one point you were sent to repair the bridge. Is that the bridge

20 between Hrvatska Dubica and Bosanska Dubica that had been destroyed by the

21 Croatian police in September 1991?

22 A. Yes, that's the bridge.

23 Q. Thank you. In the statement you said that there were some Serbs

24 who were also involved in repairing the bridge together with you. Were

25 they prisoners too?

1 A. The Serbs who worked with me, well, yes, they were Serbs

2 naturally, but they weren't prisoners. They were convicts. They had fled

3 from Lipki, Daruvar, Pacrevac [phoen], from the battlefield, and I don't

4 know from which other places they had fled. They were punished and they

5 been taken to work with us on the bridge.

6 Q. Thank you. In the statements you gave to the OTP in the year

7 2000, on page 5 you say that Idriz Causevic was taken away one day. You

8 heard moaning. You assume that he was killed, but you didn't see who

9 committed the act. You also said that the following morning you heard the

10 Serbs saying that someone had been killed and that they were quarreling

11 about this. Is that correct?

12 A. No, that's not correct. I said that one evening before Knezevic

13 was killed and Abaza perhaps two nights earlier on was taken to Causevce

14 [phoen]. We heard groaning, screams, moaning, and he never returned after

15 that.

16 Q. That's what my question was about. Did you mention the fact that

17 on the following morning you heard some Serbs who said that someone had

18 been killed and they were quarreling about this? And this has to do with

19 the death of Idriz Causevic.

20 A. No, you're not right. In my statement, I said that there was a

21 quarrel among the Serbs when Ante Knezevic and Zeljko Abaza were killed.

22 They shouldn't have been killed. They were supposed to be exchanged.

23 That's what the quarrel was about.

24 Q. Thank you. And in your statement to the OTP in the year 2000, on

25 page 5 you also said that the people who took you out into the courtyard

1 when this was happening with Ante Knezevic and Zeljko Abaza broke down the

2 door to the room that you were being kept in because they probably

3 couldn't get hold of the key from the duty officer; is that correct?

4 A. That happened at night, and that's what happened.

5 Q. Did you see who killed Antun Knezevic and Zeljko Abaza?

6 A. No, I didn't.

7 Q. Thank you. You described in detail what happened to the bodies of

8 Ante Knezevic and Zeljko Abaza. You said how they were thrown into a

9 river, and on page 6 of your statement to the OTP given in the year 2000

10 you also said that someone told the people who were around you that they

11 should stop. They even opened fire in your direction. And then the Serbs

12 at the checkpoint put you in the car around returned you to the room you

13 were being kept in. Is that correct?

14 A. Yes. When they had thrown Abaz and Knezevic into the River Una,

15 we were ordered to go to the other side of the fence, and they were

16 supposed to open fire on us, to kill us so that we, too, would fall into

17 the river. They didn't want to dirty their hands with us. And at that

18 point in time you hear the screech of tires. Some sort of a civilian

19 vehicle arrived, and a quarrel broke out between those who had killed

20 these men and the patrol that had arrived. It was probably some sort of

21 patrol. I don't know who they were. They said that they shouldn't kill

22 the two of us. They said that we would be used in an exchange.

23 Q. On page 7 of the statement that you gave to the OTP in the year

24 2000, it's the last paragraph, I think, you say that you think that the

25 killings in the village of Bacin, Hrvatska Dubica, Predore, Tanac,

1 Visnjica and Zivaja were killings that were ordered by Stevo Radjunovic

2 and Momcilo Kovacevic. Do you remember having made such a statement?

3 A. Yes, I do remember having stated that. Momcilo Kovacevic and

4 Stevo Radjun. They were the big shots there. That's what they thought

5 they were, and that was the case at the time in Hrvatska Dubica. Whatever

6 was done was something that they ordered.

7 Q. Something -- this was something that I wanted to ask you about.

8 The last sentence of yours in the statement to the Prosecution in the year

9 2002, you said that these two men, Stevo Radjunovic and Momcilo Kovacevic

10 were at the head of all the Serbian forces in that area. In paragraph 3

11 of that statement, you said that the Territorial Defence formed the

12 Serbian forces. And in paragraph 6, you said that it was difficult for

13 you to distinguish the Territorial Defence from Martic's Police and that

14 you thought that they were a single force and that in fact the same

15 people, the same men would only change their uniforms. Is that correct?

16 A. Yes, that's correct. The people were the same. Perhaps they were

17 a little younger. There was the police force, the reconnaissance force,

18 special forces, whereas these other men would change their insignia. It

19 was difficult to distinguish whether someone was a policeman. And I think

20 I have already mentioned this. It was difficult to distinguish whether

21 someone was a policeman, a Territorial Defence member, a member of a

22 reconnaissance unit, a Chetnik, et cetera.

23 Q. On page 6 of the statement that you gave to the OTP in the year

24 2000 you said that at one point in time the JNA and the military police of

25 the JNA took control of the area, not the local Serbs. Do you remember

1 when this happened, roughly speaking? You said that it was about a week

2 after about 90 people had been killed in Krecane. Do you remember having

3 made such a statement?

4 A. Well, I wouldn't agree with that. I don't mean to say that it's

5 just nonsense, but I can't remember whether I in fact made such a

6 statement.

7 Q. When you mentioned Krecane and the people who were killed there,

8 do you have in mind the people whose corpses were discovered in Bacin?

9 A. When the exhumation was carried out.

10 Q. When did you find out about the fact these people had been

11 killed? Immediately or was it subsequent to the event?

12 A. I think some time had passed after the event. It was when we were

13 carrying out our work, doing what I have already mentioned. There were

14 Bosnians, Serbs who would cross over and who would talk about things.

15 On one occasion when we were working on the bridge, we established

16 contact. The Serbs asked us who we were, the Serbian troops, the

17 Chetniks. I don't know what to call them. So we established contact, we

18 spoke to each other, and at one point they said that you would hear

19 screaming and moaning in the place called Bacin, in the Krecane area. And

20 there was another story. I'm telling you what I heard. I didn't see

21 anything myself.

22 There was another story that was spread. They said that there was

23 a foul stench that was spreading around the area.

24 Q. Thank you. In your statement to the Prosecution in the year 2000,

25 on page 7 you said that you knew that Martic came from Knin on a number of

1 occasions and that he met Radjunovic and Kovacevic. You said that on one

2 occasion while you were rounding up the livestock you heard the guards

3 mention Milan Martic's name, and they mentioned the fact that they had

4 arrived in a helicopter that you saw. You said that you heard the guards

5 saying that that helicopter was to land in the village of Zivaja. Is that

6 what you in fact stated in the year 2000? Can you remember that?

7 A. Yes, I remember that very well, and you are not correct. I didn't

8 say that Martic met Kovacevic and Radjunovic. I said that he -- this is

9 what the Serbs said amongst themselves and I listened to what they said.

10 I heard that he was visiting the field. He wasn't allowed or he couldn't

11 land in Zivaja but they said that he would land at the railway station in

12 Hrvatska Dubica and that he would be then transported by vehicle to see

13 Misljenovic and Mile.

14 Q. Thank you. That was the first statement you gave with regard to

15 Martic and his alleged meetings with Radjunovic and Kovacevic. This was

16 in your statement in the year 2000.

17 In the year 2002, you provided a supplement to your statement.

18 That was on the 17th of November, 2002. And in the second statement, you

19 said that you heard that Martic had gone to Dubica on a number of

20 occasions. And in the middle of October, 1991, you saw a helicopter

21 landing near the railway station in Dubica, and the guards told you that

22 Martic was arriving on that day and that he had left Dubica to go to

23 Zivaja on at that day. However, on that occasion when you saw the

24 helicopter, you did not see Martic. Is that correct?

25 A. Yes. When I saw the helicopter, naturally I didn't see Martic.

1 Q. In this same statement from the year 2002, you said that no one

2 told you what the purpose of his visit was, so you could only assume that

3 he had come to talk to Kovacevic and Radjunovic about the situation in the

4 field. Is that what you said?

5 A. I can't remember. I couldn't answer that question.

6 Q. In your second supplementary statement from the month of March

7 2002, on page 3, paragraph 2, you say that Momcilo Kovacevic and Stevo

8 Radjunovic worked in accordance with Milan Martic's orders whose

9 headquarters were based in Knin. "I heard that Kovacevic Stevo Radjunovic

10 would often go to Knin to see Milan Martic and to receive instructions

11 from him. That's what some friends told me."

12 Is that what you in fact stated in this second supplementary

13 statement?

14 A. I don't remember having made such a statement, but perhaps I said

15 something to that effect. But I don't think that I said he went to get

16 his orders there. And I don't remember saying that Kovacevic and

17 Radjunovic went to see Martic to receive orders but that they would

18 receive orders from Knin, from Martic.

19 Q. In your second supplementary statement from the year 2002, in

20 paragraph 3 on page 3 it says at the end of paragraph 3: "I saw his

21 helicopter arriving in the middle of October 1991."

22 You say that it landed in the vicinity of the railway station in

23 Hrvatska Dubica. And finally you say: "I am sure that this was before

24 the mass execution of civilians in Bacin."

25 Is that what you in fact said?

1 A. I don't know. If that's what it says in the statement, then

2 that's probably what I said. That's probably what I stated. But I didn't

3 see it landing. I heard that a helicopter would land. I did see a

4 helicopter, and I observed the helicopter.

5 Q. What I've just been quoting was from your supplementary statement

6 given in March 2002, after you had given your first statement to the OTP.

7 Now I want to refer to your third supplementary statement, which was

8 compiled on the 2nd and 3rd of June, 2003. And you say in that statement

9 on page 1 of that supplementary statement that you gave to the Prosecution

10 in 2003, with regard to paragraph 3 you say that you want to add that the

11 90 people killed in Krecane were civilians. "I heard about this from my

12 cousin Mico Coric."

13 In paragraph 36 you say: "I would like to say that I knew that

14 two local Serbian commanders, Radjunovic and Kovacevic, were fighting for

15 power with the local president of the SDS, Stevo Misljenovic. They even

16 attacked him. I heard that after the attack he went to see Martic in

17 Knin. While I was working in the field during my captivity, on one

18 occasion I saw a helicopter arriving. The local Serbs who were guarding

19 us said that the -- that Martic was arriving to deal with the situation

20 and to relieve those two commanders of their duties, which is what

21 happened very rapidly."

22 Do you remember having given such a statement in your

23 supplementary statement to the OTP in the year 2003?

24 A. I don't know. This is too detailed for me. There's something I

25 wouldn't agree with in what you have just said. You mentioned Mico Coric,

1 that he apparently told me about Krecane, about Bacin, but I'm not quite

2 clear about your question. Could you put a brief question to me?

3 Q. Witness, I'm only asking you about a conflict between Radjunovic

4 and Kovacevic and Misljenovic, and you said that Martic arrived to deal

5 with the situation. That's what the local Serbs said. You said that he

6 had come to relieve these two commanders of their duties. Is that what

7 you said in the statement you gave to the OTP in 2003? Is this contained

8 in the pile of paper that you have before you?

9 A. Yes, that's what I said. That's what I believed. That's what I

10 thought.

11 Q. Let me remind you that in your first supplementary statement from

12 the year 2002 you said that none of the local guards told you about the

13 purpose of Martic's visit. And now in your supplementary statement, in

14 your third supplementary statement, you say that the guards told you that

15 they had come to deal with the situation and to relieve the two commanders

16 of their duties. What is in fact correct?

17 A. Could you please slow down a bit? Because it's quite obvious that

18 you are trying to confuse me.

19 Q. Witness, I will slow down, but I'm not trying to confuse you. All

20 I am doing is saying that you've described Martic's alleged arrival in a

21 helicopter in one way. In your statement in 2002, you say you don't know

22 what the purpose of his visit was and that the guards hadn't told you

23 about the purpose of his visit, but in your supplementary statement to the

24 Prosecution in 2003 you say that Martic had come to relieve these two

25 individuals of their duties because that's what the guards had told you.

1 So you're describing the same event in two different ways. So what is in

2 fact correct? What you said in 2002, or what you said in 2003, or are

3 both versions correct?

4 A. It's correct that I cannot remember, and I don't know what I said

5 15 or 16 years ago, and after 10 or 12 years, and that's the time that has

6 passed since the event -- well, it's difficult for me to remember

7 everything, and I don't even feel the need to remember what I said when I

8 gave the statement in 2002 or when I said -- when I stated something in

9 1992. You don't have to compare this with what I said in 2002 if what I

10 said in 2002 was somewhat different.

11 JUDGE MOLOTO: Mr. Milovancevic, do you have a copy of this

12 statement of 2003 and does the witness have a copy of it? The Bench has

13 two copies. In fact, only I have two copies. The other two Judges have

14 got only one, the statement of 2002. They don't have the statement of

15 200. But the statement of 2003, it doesn't look like we have. Maybe it

16 might help the witness to jog his memory if he looks at his statement.

17 MR. MILOVANCEVIC: [Interpretation] Thank you, Your Honour. I'll

18 try to have a constructive approach as far as I can.

19 This supplementary statement given by the witness on the 2nd

20 and 3rd of June, 2003, is marked 02964254 in B/C/S, and it's two pages

21 long. On page 2 we have the signature of the witness. In English, it's

22 marked 02964257.

23 On the first page of this English text ending with numbers 257,

24 that's a subsequent statement of Witness Josipovic, paragraphs 4 and 5,

25 looking from the bottom, paragraphs 36 and 33 are mentioned. I put to the

1 witness his own paragraph 36 describing how two local commanders,

2 Radjunovic and Kovacevic, struggling with Misljenovic, SDS leader,

3 attacked him, after which he went to Knin to see Martic, and Martic,

4 according to the words of the local Serb guards, came and replaced these

5 two commanders. That was his way of dealing with the situation. That is

6 the statement that I'm now putting to the witness as something stated to

7 the Prosecution in 2003. The witness says he doesn't remember it.

8 JUDGE MOLOTO: I understand that. Does the witness have a copy of

9 that statement?

10 MR. MILOVANCEVIC: [Interpretation]

11 Q. Witness, did you manage to find your supplementary statement from

12 2003?

13 A. Yes, I have it.

14 Q. Now, if you will look at page 1. In the upper right corner the

15 number should end with 254. Can you see it?

16 A. Yes.

17 Q. Now, move to the passage mentioning paragraph 36. It refers to

18 this event involving commanders Radjunovic and Kovacevic and their

19 conflict with Misljenovic. You can read it, not aloud, and just tell us

20 if you can confirm giving that statement.

21 A. What exactly is your question concerning paragraph 36?

22 Q. Did you state this to the Prosecutor in 2003? Is that what you

23 know?

24 A. Yes. It also says in this paragraph: "I heard that after this

25 attack he went to see Martic in Knin."

1 Q. So you read this text regarding paragraph 36, and you are

2 confirming that you described it that way?

3 A. Correct. Correct.

4 Q. However, you went on to give a fourth supplement to your statement

5 to the OTP on the 12th of March, 2006, and you mentioned it today in the

6 examination-in-chief. This supplement, this addendum, is very brief. It

7 says that in November 1991 there was an incident in which a van carrying

8 Serbs drove over a mine. The driver was seriously wounded and succumbed

9 to his wounds later in Belgrade. And after his death, Martic came to

10 Zivaja village, and he wanted to see Croat prisoners. And you were

11 brought to Zivaja, actually, to be presented to -- to be shown to him, but

12 then he changed his mind. Did you say this -- today?

13 A. I don't know if that's in the statement. The van did drive over a

14 mine, but who actually laid the mine and who was killed in Serb ranks and

15 who was in the van I can't tell.

16 Q. You see, I'm asking you only about this passage related to

17 Martic's alleged visit to Zivaja village in November. Do you stand by

18 your statement that in November 1991, Martic did indeed visit Zivaja as

19 you describe?

20 A. Maybe. Maybe in November. But it was several days after this van

21 driver over a mine and after that Serb got killed. That Serb was an

22 important man in Zivaja, held a high position.

23 Q. I'm sorry, Witness. I'm just asking you this: Did you hear that

24 Martic visited Zivaja in November?

25 A. That's what people told me. And when this man was killed, that

1 Serb who was in the van, that night they killed Abaza and Knezevic by

2 cutting their throats, and then they drove us to Zivaja.

3 I think it was not actually the same night but one night two or

4 three days later that we were driven to Zivaja when we were told that

5 Martic was in this command post and all the other things that I have

6 already described.

7 Q. You see, you gave your first statement to the Prosecution in

8 November 2000. Then you were added to it in March 2002. You added to it

9 again in June 2003, describing how Martic came to resolve the conflicts

10 between local leaders Radjunovic, Kovacevic and Misljenovic, and then in

11 2002 you say -- sorry, in 2003 you say you don't know why he came. And

12 then you made another addendum in 2006.

13 You gave six different statements to the Prosecution. I'm asking

14 you, on the 1st of --

15 THE INTERPRETER: The interpreter missed the date. We're very

16 sorry.

17 MR. MILOVANCEVIC: [Interpretation]

18 Q. I have this Official Note of your interview to the police

19 administration of Sisak on the 1st April of 1992 recording your personal

20 details and recording the contents of their interview with you. It

21 contains a lot of information on three pages, including the signature of

22 the person who made this Official Note. This statement is ERN

23 number R0114473, and in English it's R0184936.

24 I want to show you something from that statement. You were

25 exchanged in February 1992, and just a month and a half later, in the same

1 year, you give a statement, and it says: "Momcilo Kovacevic is the

2 commander and Stevo is his deputy. Local Chetniks have control over that

3 area, and they are in conflict with Martic's men. Local Chetniks are

4 responsible for the crimes committed against civilians, looting, torching,

5 et cetera, where as the military police is trying to restore some order

6 and discipline. When in November 1991 Milan Martic came to visit the

7 area, he was in Zivaja, but he didn't dare to go to Dubica. Later on,

8 military police managed to seize control nevertheless. In the meantime,

9 there were several changes of authority."

10 I'm asking you now: Did you give this statement in the police

11 administration in 1992?

12 A. Well, if that's what's written, it means I did.

13 JUDGE MOLOTO: But that's not his statement. That's an Official

14 Note. Surely that's an interpretation by this person who wrote this note,

15 this Official Note, this Zeljko Vukovic. It's not the witness's

16 statement, Mr. Milovancevic.

17 MR. MILOVANCEVIC: [Interpretation] Thank you for this observation,

18 Your Honour. I just said to the witness that this is the contents of his

19 interview that he had with the police administration.

20 Q. And I want to ask him: Did he talk indeed to an officer at the

21 police station?

22 A. What do you want to know, the date?

23 Q. You seem to be tired.

24 A. No, you seem to be tired. You mentioned that I came on

25 the 10th --

1 JUDGE MOLOTO: Can we please have order in court.

2 Witness, when I'm talking to the counsel, give us a chance to

3 finish and I'm say to him he may continue, and then you can start talking

4 to him.

5 Your question, Mr. Milovancevic, you're saying that -- you read

6 the statement and you're asking him now, did he give this statement in the

7 police administration in 1992, and I'm saying to you this is not his

8 statement. This is an Official Note by this person who signed that. When

9 you say to him, "Did you give this statement," as you say here on the

10 record, and he says yes to that, we are obviously misleading, both him and

11 the Court.

12 Now, you know as an officer of the Court that that's not his

13 statement. That's an Official Note. Whatever interpretation that

14 official put into what took place on that day, this witness will not know.

15 You alleged that he made six different statements to the OTP. I'm still

16 aware of three that you have been referring to. This Official Note is the

17 fourth. I haven't seen the other three statements that you say he made to

18 the OTP.

19 Now, you have been confronting him with versions from the three

20 statements. I have no problem with that. But I do have a problem when

21 you attribute an Official Note to him as his statement.

22 Now, when you say "did you make this statement or not" and you

23 want to say did he say that point, that's not what he said. That's what

24 he said by the official.

25 You may proceed, Mr. Milovancevic, if you have -- or you can

1 answer to what I have been saying.

2 MR. MILOVANCEVIC: [Interpretation] You were abundantly clear, Your

3 Honour. Thank you. I will continue my questioning in such a way to

4 solicit answers that could shed light on what exactly happened with this

5 Official Note.

6 JUDGE MOLOTO: Thank you very much, Mr. Milovancevic.

7 MR. MILOVANCEVIC: [Interpretation]

8 Q. Witness, I have before you, as do you, a certain Official Note.

9 It says it was drawn up on the 1st of April, 1992, at the police

10 administration of Sisak in connection with an interview conducted with

11 you. It is written in the first paragraph.

12 In the third paragraph it says: "Josip Josipovic has stated the

13 following during this interview," and then follows a record of what you

14 stated.

15 My question is: Did you go to the police administration of Sisak,

16 to the section for economic crimes, and did you have an interview there?

17 A. Yes, I did.

18 JUDGE MOLOTO: Let's just understand that what follows is what the

19 official claims the witness said. It's not what the witness said. It's

20 what the official claims the witness said.

21 MR. MILOVANCEVIC: [Interpretation] Thank you, Your Honour.

22 Q. In paragraph 2 of this Official Note, the officer who compiled

23 this record, so this is an Official Note drawn up by an official of the

24 police administration of Sisak, and it reads: "The interview was

25 conducted at the Sisak police administration with a view to

1 re-establishing employment in the police administration of Sisak and

2 reinstating a residency in Dubica."

3 Is that what the interview was about?

4 A. When I came back from captivity, it was proven that I had not

5 joined the Chetniks or Serb paramilitaries as some people had thought. I

6 was not with Serb units. I was in captivity. That was the main purpose.

7 Q. Did you talk to this officer who conducted this interview about

8 the circumstances of your captivity in Dubica? Is that what you talked

9 about?

10 A. Yes.

11 Q. On page 2 of this Official Note, the officer wrote down the

12 following text which, according to this Official Note, should be a

13 reflection of the interview he had with you, and I am going to put to you

14 just a little passage from the second page of the B/C/S language you

15 understand. In paragraphs 3 and 4 it reads: "The official or the officer

16 recorded the following," after talking to you: "Momcilo Kovacevic is the

17 commander and Stevo Radjun is the deputy. The area is under the control

18 of local Chetniks who have a conflict with Martic's men. Local Chetniks

19 are responsible for crimes committed against civilians, lootings,

20 torchings and similar things, whereas the military police is trying to

21 restore order and discipline."

22 Another paragraph: "When in November 1991 Mile Martic came to

23 inspect the area, he was in Zivaja but he didn't dare go to Dubica. Later

24 on, military police managed to regain control. In the meantime, there had

25 been several changes of authority."

1 I just read out the text that the officer wrote down as a result

2 of talking to you. That means based on the information you provided to

3 that officer regarding your stay in Dubica.

4 My question now is: This text regarding Momcilo Kovacevic and

5 Stevo Radjun and their relationship with Milan Martic, is that a faithful

6 reflection of what you said?

7 A. You're really beginning to suffocate me or stifle me here.

8 Perhaps we could have a short break. I think I need a rest.

9 JUDGE MOLOTO: How long of a rest do you need?

10 THE WITNESS: [Interpretation] [No translation].

11 JUDGE MOLOTO: Can we have interpretation?

12 THE WITNESS: [Interpretation] Five or 15 minutes.

13 JUDGE MOLOTO: All right. If it's going to be 15 minutes, maybe

14 it might just be the correct time to retire for the day.

15 MR. MILOVANCEVIC: [Interpretation] Your Honour, if I have

16 understood the witness correctly, he needs a short break of about 15

17 minutes, but that would bring us to the end of this session, so perhaps it

18 would be best to finish by 7.00. I'm drawing to the end of my

19 cross-examination.

20 THE WITNESS: [Interpretation] It's not a problem. If we will end

21 at 7.00, I can continue.

22 MR. MILOVANCEVIC: [Interpretation]

23 Q. I have another couple of questions for you, Witness.

24 A. I can finish that then.

25 JUDGE MOLOTO: We'll go up to 7.00.

1 You may proceed.

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

3 Q. It's a brief question. What I've just read out to you, the

4 contents of the Official Note, do the contents of the Official Note

5 correspond to what you said to the police in 1992?

6 A. Well, how am I to know whether it corresponds to what I said to

7 the police in 1992?

8 Q. I have a few more very brief questions. You gave your first

9 statement to the Prosecution in the year 2000; is that correct? Can you

10 remember that, although it was a long time ago.

11 A. I can't remember the year or the date. I can't remember when I

12 gave my first statement to the Prosecution. I can't remember when I first

13 saw the OTP.

14 Q. And one more question. Do you remember how it came to pass that

15 you gave the Prosecution supplementary statements? Did you contact them

16 yourself, or did they contact you in order to conduct another interview

17 with you?

18 A. Yes. They wanted an additional interview with me.

19 Q. In those additional interviews, they put questions to you and you

20 answered them; is that correct?

21 A. Yes. I answered their questions, if I was able to, and I provided

22 them information I hadn't provided them with the first time I saw them. I

23 didn't think it was that interesting nor did I think that it had any

24 particular purpose or basis. I quite simply wanted to be done with it as

25 soon as possible, and I didn't want to have to remember all of these

1 events. I didn't think I had to say too much. As to whether there was

2 anything of importance or not, I don't know. But in any event, at the

3 time, The Hague Tribunal was interested in certain things and they wanted

4 a supplementary statement. They wanted some additional explanations of

5 certain events.

6 Q. Witness, I have no further questions for you. This concludes my

7 cross-examination. Thank you for your patience.

8 MR. MILOVANCEVIC: [Interpretation] Your Honours, I have now

9 concluded my cross-examination of this witness.

10 JUDGE MOLOTO: Thank you, Mr. Milovancevic.

11 It may very well be a convenient time. I don't think there is any

12 purpose starting any re-examination at this point in time, Ms. Richterova.

13 MS. RICHTEROVA: I agree that we should continue tomorrow because

14 it is clear the witness is tired.

15 JUDGE MOLOTO: Okay. Thank you very much.

16 And tomorrow we -- once again, I remind the parties we start

17 at 10.00. This is in Courtroom I.

18 Court adjourned until tomorrow at 10.00.

19 --- Whereupon the hearing adjourned at 6.56 p.m.,

20 to be reconvened on Friday, the 7th day

21 of April, 2006, at 10.00 a.m.

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