1 Thursday, 17 April 2003

2 [Open session]

3 [The accused entered court]

4 --- Upon commencing at 9.04 a.m.

5 THE REGISTRAR: Your Honours, we're in open session.

6 JUDGE MAY: Yes, Mr. Nice.

7 MR. NICE: May we go into closed -- private session, please.

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2 [Open session]

3 THE REGISTRAR: We're in open session, Your Honours.

4 [The witness entered court]

5 JUDGE MAY: Yes.

6 MR. NICE: Your Honour, we are on page 16 of the transcript,

7 paragraph 100.

8 WITNESS: B-129 [Resumed]

9 [Witness answered through interpreter]

10 Examined by Mr. Nice: [Continued]

11 Q. Witness B-129, can we turn now to the Treskavica operation in June

12 and July of 1995. Were Tigers sent there?

13 A. Yes.

14 Q. How many and what was the purpose?

15 A. The number of Tigers in Treskavica was between 60 and 70 Tigers.

16 Their task was, together with a unit of the state security which was led

17 by Vaso Mijovic, to cut the Muslim communication lines around Sarajevo.

18 Q. Did Arkan tell you who had given instructions that the Tigers

19 should do this?

20 A. Arkan informed me and the entire staff about this operation, even

21 though the group went directly from Erdut. But he wanted us to know about

22 the operation as well, and he was given instructions by the state

23 security, as he himself told me, as well as the fact that the state --

24 head of the state security would be Vaso Mijovic.

25 MR. NICE: Your Honours can find this location on Exhibit 432, tab

1 20, at the bottom, to the right and south of Sarajevo.

2 Q. Who were the commanders for the Treskavica operation under Vaso

3 Mijovic?

4 A. Do you mean members of the Serbian Volunteer Guard?

5 Q. Yes.

6 A. There was Colonel Kajman, Major Mladen Sarac, and Captain Svetozar

7 Pejovic, also known as Peja.

8 Q. And did Jugoslav Simic fill a role?

9 A. Yes. He was in charge of radio communications and for telephone

10 communications with us at the headquarters in Belgrade.

11 Q. Now, Vaso Mijovic was DB. Did you see him in Belgrade?

12 A. Yes, I did.

13 Q. Did he come to your headquarters in the course of this operation?

14 A. He would come during the operation and slightly before the

15 operation at Treskavica. During the operation at Treskavica, whenever he

16 was in Belgrade, he would come to the headquarters to pass on information

17 from the field to the commander.

18 Q. How did you know that he was DB?

19 A. It was a rule at headquarters that when a person from the DB came,

20 that person wouldn't wait outside but would be allowed to enter the

21 headquarters immediately and would be escorted to the commander's office.

22 Whereas, the others had to announce their arrival at the porter's, at the

23 guard at position 01, and only then could they enter the headquarters.

24 Q. To your knowledge, did Arkan ever visit Vaso Mijovic anywhere?

25 A. He visited him at the camp in Beli Manastir after the Operation

1 Storm in 1995, that is, in August of that year.

2 Q. [Previous interpretation continues] ... Beli Manastir on Exhibit

3 432, tab 20, towards the top of the page and about five inches from the

4 right-hand side.

5 At Treskavica, did this Tigers and the Serbian DB have separate or

6 shared command post?

7 A. They had a shared command post. The man in charge of the

8 operation was Vaso Mijovic. Our officers were below him, which meant that

9 they were accountable to him but they went into action together.

10 Q. And when you contacted the post, were you always answered by one

11 or the other or sometimes by one and sometimes by the other type of

12 person?

13 A. I and headquarters only had telephone contact with them, and

14 usually at the other end of the line was Jugoslav Simic, though sometimes

15 Vaso Mijovic himself would answer the telephone.

16 Q. How were the Tigers at Treskavica paid?

17 A. Regarding their payments, I don't know anything because all that

18 happened on the ground.

19 Q. Do you know anything about where the money came from or whether

20 the money came to the headquarters in Belgrade?

21 A. Are you referring to the Treskavica operation or do you mean in

22 general?

23 Q. No, Treskavica.

24 A. I don't know anything about that.

25 Q. Did Jugoslav Simic, on return to Belgrade, tell you something of

1 what had been done to prisoners in the Treskavica operations?

2 A. Yes.

3 Q. Namely?

4 A. He said that members of the state security had tortured most of

5 the captured Muslims and then killed them.

6 Q. Could you describe some, in any event, of the methods of torture

7 that had been employed?

8 A. Yes.

9 Q. Namely?

10 A. What has been imprinted in my memory most is that he said that on

11 one occasion they pushed a bottle into the anus of one of the prisoners.

12 MR. NICE: Exhibit 432, tab 15, please, for the witness. And Your

13 Honour, because of time, I'm going to deal with documents swiftly.

14 Q. Is this a document that you had not seen before coming to testify

15 but that you've reviewed here, it being dated the 30th of June of 1995,

16 coming from the forward command post of the special police brigade at

17 Trnovo, signed by Ljubisa Borovcanin and referring to the 29th of June,

18 when a police combat group, consisting of the 4th Special Police

19 Detachment and the Kajman Detachment together carried out an attack on

20 Lucevik?

21 A. I saw this document for the first time here, but it indicates the

22 date because the guards were in Treskavica at the end of June 1995. And

23 at the end of June, that is, the 30th of June, we had losses at

24 Treskavica. Two men were killed, two were seriously wounded. The latter

25 two were immediately transferred to Belgrade and they passed away. One of

1 the two was called Zoran Maric and he is from Sehovici in Republika

2 Srpska.

3 Q. This letter in referring to the Kajman Police Detachment and

4 making further reference to establishing control over the Trnovo-Sarajevo

5 route, does this connect with your evidence about the Tigers being in the

6 Treskavica area?

7 A. Yes, because this Kajman relates to the unit led by the late

8 Dragan Petrovic Kajman, an officer, a colonel of the Serbian Volunteer

9 Guard.

10 Q. Thank you.

11 MR. NICE: Exhibit 432, tab 16.

12 Q. Similarly, briefly. Is this a document you only -- you first saw

13 when you came here to prepare to give evidence?

14 A. Yes.

15 Q. This is a document from the Ministry of the Interior, the same

16 forward command post, same signature, and deals with activities commencing

17 the previous day and makes further reference to the Kajman Detachment.

18 Same general conclusion from this letter, supporting your account of

19 involvement in Treskavica?

20 A. Yes.

21 Q. Thank you.

22 THE ACCUSED: [Interpretation] Mr. May.

23 JUDGE MAY: Yes.

24 THE ACCUSED: [Interpretation] I was saying I can't see it on the

25 screen and I don't have that document.

1 JUDGE MAY: Have you not got the clip of documents we've been

2 referring to?

3 THE ACCUSED: [Interpretation] Yes. The last one was this one from

4 the Centre for Special Training of the Territorial Defence of Slavonia,

5 Baranja, and Western Srem. And there's no other documents attached.

6 JUDGE MAY: You should have 15 and 16. Have you got them, those

7 tabs?

8 THE ACCUSED: [Interpretation] Let me have a look. I do have 15.

9 Which document are you referring to, please?

10 JUDGE MAY: [Previous interpretation continues] ... the next one

11 should be 16.

12 THE ACCUSED: [Interpretation] Under 16 I have a transcript.

13 JUDGE MAY: Just would you hand that -- hand that, your clip, back

14 to the Prosecution and just see what's gone wrong.

15 Well, if the accused is not going to do that, let's go on.

16 MR. NICE:

17 Q. On this document, on the last paragraph, we see reference --

18 JUDGE MAY: Let the usher come back.

19 MR. NICE:

20 Q. We see reference to members of the 4th Special Detachment and

21 wounding of four detachment members in hospital in Srbinje. Does that fit

22 with your recollection of events?

23 A. It's not Srebreno but Srbinje. And at the time it was called

24 Foca.

25 Q. And were there people wounded and in hospital at Srbinje to your

1 recollection?

2 A. Yes, because the lady doctor that treated them, I'm referring to

3 the two seriously wounded, informed me that they had been transferred to

4 Belgrade, and they were transferred to the emergency centre in Belgrade.

5 MR. NICE: Your Honour, we will not seek to produce tab 17.

6 Before I move to paragraph 112, just a couple of questions to deal with

7 matters that may be obvious and may not be.

8 Q. Arkan's headquarters, were they, as it were, publicly visible in

9 Belgrade, the office where you were working?

10 A. Yes. It was across the road from the Zvezda stadium. The

11 Ljutice Bogdana Street, 1A.

12 Q. Any difficulties should anybody wish to identify the building or

13 what was going on inside?

14 A. Could you please put a specific question to me?

15 Q. Yes. The identity of the operation, was it -- was it easily

16 discoverable? Was there a notice at the door or what?

17 A. There was no notice at the door, but everyone in town knew that it

18 was the headquarters of the Party of Serbian Unity and the headquarters of

19 the Serbian Volunteer Guard. And if you were to ask anyone in the street,

20 they would show it to you. But no one could see from the outside what was

21 going on inside because the doors were closed.

22 Q. And the last question on this topic: When people from Arkan's

23 Tigers travelled around Belgrade, were their vehicles marked in any way?

24 A. Regarding Belgrade and trips in town, the vehicles were not

25 marked. But if they were going from Belgrade to Erdut, we had a tiger

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1 painted on the front of the car.

2 Q. Page 18, paragraph 11, Exhibit 432, tab 20, the map, the area

3 marked at A towards the west or left of the map, north-east of Knin. The

4 Banja Luka operation of autumn 1995, what's your recollection in summary

5 of that operation, please, Witness 129?

6 A. That operation started in September, the beginning of September.

7 When I say "the Banja Luka operation," I mean Sanski Most, Mrkonjic Grad,

8 Kljuc, and Prijedor. In that operation, about 200 Tigers took part and

9 Arkan himself was there too. 16 members of the Serbian Volunteer Guards

10 were killed and a large number were wounded, some more, some less

11 seriously. The unit set off from Erdut. I was informed about the

12 movement of the unit by the late commander.

13 Q. The purpose of the operation, was it connected with the position

14 of the VRS army in their retreat from areas of Sanski Most and Kljuc?

15 A. Yes, because they were abandoning their positions and fleeing.

16 The guards went there to try and stop or prevent the fall of Banja Luka.

17 They feared that Banja Luka would fall into enemy hands.

18 Q. Who of the Serbian DB was in charge of this operation?

19 A. On the ground, the man in charge was Radojica Raja Bozovic. And

20 the Commander Arkan was with them.

21 Q. Were the Tigers subordinate to the Serbian DB?

22 A. Yes.

23 Q. You've spoken of Arkan being at this operation. Did you speak

24 with him directly while he was there, from time to time?

25 A. Yes, frequently, almost every day.

1 Q. And did you receive a report from Borislav Pelevic, also known as

2 Pele, about what Arkan was doing in the field?

3 A. Yes, because Borislav Pelevic spent three days there. And upon

4 returning, he told me that he had assisted Arkan and General Talic to hold

5 onto Banja Luka.

6 MR. NICE: Exhibit 432, tab 18 the Chamber will find is a short

7 transcript of two clips of film. They're not marked as to their division

8 very clearly, but you'll see that at the bottom of their page of

9 transcript there's a counter reference. And I'm in fact, I think, if it

10 works, going to play that clip first. So it's the last line of tab 18.

11 [Videotape played]

12 MR. NICE: No sound, but it doesn't matter. We saw the

13 transcript. We may get the sound for the next clip.

14 Q. Witness 129, you saw that. Who was shown on that clip?

15 A. On that clip was the commander Arkan. And behind him, Borislav

16 Pelevic, Pele, in uniform.

17 Q. And we see from the transcript that Arkan is speaking of his

18 inability to enter Kljuc.

19 A. Yes.

20 Q. Pressure of time means that although the sound may now be

21 available, I'll simply press on to the next part of the clip, starting at

22 the top of the page, please.

23 [Videotape played]

24 MR. NICE: Preferably with sound, if we can have it.

25 Well, apparently the network is down in the entire building, and

1 --- On resuming at 10.51 a.m.

2 JUDGE MAY: The position is this: That the problems with the

3 generator which led to our not being able to use the first courtroom have

4 not been resolved, but we have been able to use this courtroom, although

5 with some adaptation, and we're grateful to those who have adapted to

6 allow us to do that and for the hearing to continue.

7 It is imperative that we finish the witness of this -- the

8 evidence of this witness today. Accordingly, the sitting will be now from

9 10.50, when we began, we will sit for an hour and a half, and that will be

10 until 12.20. We will then adjourn for half an hour, and then sit until

11 2.35, with the indulgence of the interpreters, who, for once, are in front

12 of us.

13 Mr. Nice, having made a calculation, it seems that if you would

14 finish up very rapidly, it may just be possible for us to finish today,

15 and indeed, if possible, address some of the administrative matters. But

16 if you could wind up in five minutes or so.

17 MR. NICE: Your Honour, may I, without breaching the recent ruling

18 on written statements, deal with it in this way: I'll lead.

19 JUDGE MAY: Yes, as much as possible, of course.

20 MR. NICE: And when we separated in the last court, we'd been

21 looking at 432, tab 18, two video clips, the second of which showed Arkan

22 dealing with some Muslim prisoners whom he was addressing in terms

23 revealed in tab 18. They were told they would be taken to a hotel for

24 coffee.

25 Q. Witness 129, in one sentence, what were you told later by Tigers

1 about the fate of those Muslim prisoners?

2 A. As I saw the tape like most of the people in Serbia, I saw the

3 footage of television, actually, I asked them what happened to those

4 Muslims, and afterwards I was told that I was never to ask that again,

5 never to ask about that again, and that's what I did -- or rather, didn't

6 do.

7 Q. The other man seen on that tape, Ljuban Ecin, was he the commander

8 of the Banja Luka DB who worked closely with Arkan in that operation,

9 visiting Frenki when he came to Belgrade but also visiting Arkan? Yes or

10 no, please, if I'm right about that.

11 A. Yes.

12 Q. Did Ljuban Ecin and Arkan see Frenki during -- regularly during

13 the Banja Luka operations and a man known by the surname Kajkut, and

14 Radomir Sejmanovic, known as Subara from Banja Luka? Did they also visit

15 the Belgrade headquarters in October 1995?

16 A. Yes.

17 Q. Turning from that to the Prijedor area specifically, did two

18 Tigers, Ristic and Sarac, speak to you about being in Prijedor with Arkan

19 where 16 Tigers were killed in combat and, in a phrase, their explanation

20 for the loss of those Tigers was?

21 A. The 16 Tigers were killed in that entire Banja Luka operation, and

22 Prijedor was included in that.

23 Q. And what was the comment on why they died? What was the comment

24 on Arkan's military capability?

25 A. What was said was that Arkan knew nothing about military -- or

1 rather, had no military capabilities for leading soldiers into battle.

2 Q. Simo Drljaca came to Belgrade twice in 1995, and did Arkan tell

3 you that he and Drljaca had been together in Prijedor, and did Drljaca

4 receive a formal certificate of thanks from the SDG although he was a

5 commander of the Prijedor DB?

6 A. Yes.

7 Q. Mihajlo Ulemek, head of the Tigers military police section for the

8 Banja Luka operation in the way you described generally yesterday, was he

9 once required to return to base on grounds of torturing Serb deserters but

10 he was subsequently reengaged when there was a requirement for him?

11 A. Yes.

12 Q. I will skip Exhibit 432, tab 19.

13 Did Ristic, Momir, and Mladen Sarac tell you of the killing of

14 civilian Muslims in Sanski Most and were they in a state when they came

15 back home from Sanski Most?

16 A. Yes.

17 Q. Indeed, did they give a description of killing Muslims in the

18 mosque as they prayed and they described this as -- in terms of it being

19 hell and their hardest operation?

20 A. Yes. They described it and said that in a mosque in Sanski Most,

21 while the Muslims were praying, they killed them.

22 Q. In 1995, August, after Operation Storm in Erdut camp, did you see

23 five to six hundred men arriving in a convoy of civilian buses, they being

24 mostly refugees from the Knin Krajina, some of them, though, having been

25 in Belgrade for many years? Did you discover that they'd been arrested in

1 Serbia, briefly detained in the Sremska Mitrovica prison before being

2 brought to Erdut where they were lined up, had their heads shaved, given

3 uniforms and rifles, and then sent the next day to hold the demarcation

4 line between East Slavonia and Croatia under the command and direction of

5 the Tigers?

6 A. Yes.

7 Q. Mladen Sarac saying that the operation in Erdut involved the

8 arrest of about 500 such men -- 5.000 such men, I beg your pardon. I'm

9 grateful to Ms. Pack.

10 A. Yes.

11 Q. The decision to round up those men being made by Serbian

12 authorities apparently?

13 A. Yes.

14 Q. Thank you, B-129. I'm sorry to have had to deal with that at such

15 speed. You'll be asked further questions.

16 JUDGE MAY: Yes. We'll just go into closed session -- private

17 session for one moment.

18 [Private session]

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11 [Open session]

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

13 JUDGE MAY: We must finish this witness today, Mr. Milosevic, so

14 don't take up too much of your time with argument.

15 THE ACCUSED: [Interpretation] Would you please check what you have

16 just stated, because the witness, except for the first few minutes when

17 she spoke about her identification, she was speaking in open session.

18 Take a look for yourselves in the transcript.

19 JUDGE MAY: Just -- just don't argue. Just deal with the matters

20 in the way that we have -- has been suggested. There are those areas

21 which should be dealt with in private session. Apart from that,

22 everything is in open session.

23 THE ACCUSED: [Interpretation] You yourselves will be able to

24 assess, and you'll be able to see that what I am able to ask her will be

25 referring to what she spoke about in open session because I do not wish to

1 go into private session.

2 Secondly, Mr. May, can we clear up a technical matter, a rather

3 exact matter, actually? Up until this interruption which occurred because

4 of the breakdown with the generator - that's not important, you know what

5 I'm talking about - the witness was -- testified for a full three hours.

6 Yesterday, exactly from 11.00 to quarter to 2.00, minus a break, which

7 means two hours and 20 minutes. This morning before the break, she

8 testified for 35 minutes, which makes it three hours. And now in this

9 continuation, she had another 15 minutes, which makes it three hours and

10 15 minutes in total. So please bear in mind --

11 JUDGE MAY: The total was three hours, in fact. I've noted it at

12 the time. For instance, you're wrong about this morning's times, but --

13 it was only ten minutes just now, probably less, and only 25 minutes

14 earlier. But you've got three hours, so let's get on with it. If you

15 need it -- if you need this -- to take up three hours with this witness.

16 THE ACCUSED: [Interpretation] Well, those are exact facts, and you

17 can check them out on the transcript. My associate checked it out and

18 looked at the minutes to the minute. So I assume that as you have the

19 transcript available, you can also --

20 JUDGE MAY: [Previous interpretation continues] ... this is going

21 to count against you, all this argument. Now, let's get on with it.

22 THE ACCUSED: [Interpretation] Very well, Mr. May. This is not the

23 first time that we do not agree, even about figures and numbers, which are

24 very exact things.

25 Cross-examined by Mr. Milosevic:

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1 Q. [Interpretation] Witness 129, you worked first within the election

2 campaign for the Serbian Unity Party. That's right, isn't it?

3 A. Yes.

4 Q. And for a brief period of time, as I can see from your statement,

5 at the very beginning. And that was the autumn of 1993; that's right,

6 isn't it?

7 A. Yes, that's right.

8 Q. All right. It says October/November here, but I don't mind. Does

9 that mean that you worked for two months within the frameworks of the

10 election campaign?

11 A. Yes.

12 Q. And that was your first contact, the first activities linked to

13 the Party of Democratic Unity, Serbian Party of Democratic Unity.

14 A. Yes.

15 Q. The elections passed, this was a temporary job, and you no longer

16 worked there; is that right?

17 THE INTERPRETER: The interpreters note that they have to change

18 channels between the speakers, so could the speakers make breaks between

19 question and answer, otherwise we lose the answer. Thank you.

20 JUDGE MAY: Just one moment. We had an intervention by the

21 interpreters. Can you pause, both of you, between question and answer to

22 allow them to change channels.

23 So Mr. Milosevic, would you kindly do that.

24 And Witness B-129, when you hear the question, pause and then

25 answer. Yes?

1 THE ACCUSED: [Interpretation] Very well, Mr. May. I will bear

2 that in mind, and I hope that I always do bear that in mind after the long

3 experience I have had with you here.

4 MR. MILOSEVIC: [Interpretation]

5 Q. In 1993, that brief time -- for the brief time that you worked,

6 was -- there was an intensive campaign going on; right?

7 A. Yes.

8 Q. You didn't do any other jobs, just dealt with the campaign, the

9 election campaign; right?

10 A. Yes.

11 Q. So it was only later, from September 1994, when you got a job

12 again, you worked in affairs concerning the SDG, the Serbian Volunteer

13 Guard; right?

14 A. Yes.

15 Q. Could you explain what jobs you did, what work you did, from the

16 autumn of 1994.

17 A. Yes, I will explain. At the end of August 1994, they needed

18 somebody to work in the offices and premises of the Party of Serbian

19 Unity, because at the time the guard had been disbanded.

20 Q. All right. Fine. So you never did anything, any jobs, linked to

21 the Serbian Volunteer Guard, as it says here, from about September 1994

22 when you took up your job again, because the Guard had been disbanded. Is

23 that right?

24 A. Yes.

25 Q. And when, roughly speaking, did you have any connection with --

1 anything to do with the Serbian Volunteer Guard? When did you start

2 working for them again? Because you were working for the Unity Party.

3 A. From November 1994, when the Guard was involved in the operations

4 once again, all of us who had worked at the headquarters of the Serbian

5 Unity Party on Ljutice Bogdana Street automatically began to work for the

6 SDG, or jobs related to it.

7 Q. Right. So that means that your personal experience linked to work

8 -- the work of the Serbian Volunteer Guard dates from November 1994. Have

9 I understood you correctly?

10 A. Yes.

11 Q. Now, tell me this, please: How is it possible that as, according

12 to your own testimony and your personal experience related to the

13 activities of the SDG as it dates back to November 1994, how can you

14 testify here in this courtroom about 1991, 1992, 1993, 1994; that is to

15 say, for almost four years before you came into contact with the affairs

16 of the SDG in the first place?

17 A. Whenever I testified, the period from 1991 inclusive with February

18 1993, which was the last operation in Knin, I always stated that these

19 were the -- what the people said, what the members of the Serbian

20 Volunteer Guards said and talked about, those of them who worked at the

21 headquarters, because they were wounded. Because most of them, most of

22 those who had taken part from 1999 onwards -- 1991 onwards, in the

23 operations, when they were wounded, after that they would work in the

24 headquarters once they were wounded. The soldiers who had their memories

25 and recollections of the things they had experienced would usually talk

1 about where they had been and what they had experienced.

2 Q. All right. Can we just clear that up. Everything that relates to

3 November 1994 is something that you heard from someone else; right?

4 A. Heard, seen through the documents, because there were always facts

5 and information at the headquarters written down in documents which

6 related to the operations they were engaged in, and every year when the

7 Guards' Day was celebrated, they would mention all the battles they had

8 been in, ranging from 1991 up until the year the celebration was held.

9 Q. All right. And a lot of that was written up in the press too,

10 those ceremonies of yours.

11 A. Yes, that's right.

12 Q. So the activities of the Serbian Volunteer Guard was no secret.

13 A. No, it wasn't.

14 Q. You said that the -- the building itself, the Serbian Unity Party

15 building which was used as headquarters, had no plaque on it. Didn't it

16 have the party flag outside? Wasn't it flying the flag?

17 A. There was a flag, but there was no plaque with a title. It didn't

18 say anywhere as a plaque that the Party of Democratic -- of Serbian Unity

19 was there.

20 Q. Well, I assume we're not challenging the fact that it was a

21 regular party, registered just like some 100 other parties in Serbia, that

22 it took part in the elections, and that its president was elected as a

23 deputy, parliamentary deputy.

24 A. I have to put you right. He was not a deputy in parliament, its

25 representative. He was elected as a candidate. He was put forward as a

1 candidate on the part of a group of citizens when the Party of Serbian

2 Unity was founded. It was at those elections, and they took place on the

3 12th of November -- no, I'm sorry, the 12th of December, 1993, the Party

4 of Serbian Unity did not receive a single seat in parliament, in the

5 Serbian parliament.

6 Q. All right. I just remember that what happened was that Zeljko

7 Raznjatovic, nicknamed Arkan, was a poplar deputy at one time.

8 A. Yes, but before the party was set up.

9 Q. Yes, put forward on the part of a group of citizens.

10 A. Yes.

11 Q. Now, tell me this, please: Let's clear one point up first. We're

12 not disputing the fact that we're talking about the Serbian Volunteer

13 Guard, the SDG. That's right, isn't it?

14 A. Yes.

15 Q. Now, does that apply not only in formal terms but informally as

16 well that they were -- the Guard was made up of volunteers; is that right?

17 A. Yes.

18 Q. Was any member of the Guard recruited forcibly?

19 A. No.

20 Q. And do you happen to remember during those years that there was

21 some other parties as well which set up their own Guards Corps?

22 A. Yes, I remember that too.

23 Q. You'll remember the Serbian Guard of the Serbian Revival Movement,

24 for instance?

25 A. Yes.

1 Q. And I'm sure you'll remember all the other movements that were

2 burgeoning.

3 A. Yes.

4 Q. And do you remember that all those parties which set up their own

5 guards or certain units and formations were in fact opposition parties in

6 Serbia?

7 A. Yes. However, the Serbian Unity Party was not an opposition

8 party.

9 Q. How do you come to that conclusion?

10 A. Because it states in the statute of the party that it is a party

11 of the centre.

12 Q. A party of the centre does not mean that it is a party that takes

13 part in power and authority and ruling the country. The fact that it was

14 a party of the centre means that it was neither the left nor the right but

15 it was the centre.

16 A. Yes. But the Serbian Unity Party was never in a coalition with

17 the other opposition parties and so on and so forth.

18 Q. All right. Fine. Now, as you spoke about this matter in open

19 session, what I'm going to ask you next, please warn me if you think that

20 there is anything that I'm going to ask you which you spoke about in

21 private session.

22 A. Yes, I will.

23 Q. It is not my intention to present any piece of information that

24 wasn't stated in open session.

25 A. All right. Yes, I'll do that.

1 Q. So this question of volunteer members, we've cleared that up both

2 in the title of the party and as things stood on the ground, in reality;

3 they were all volunteers who put themselves forward to help the defence of

4 the Serb people where the Serb people were in jeopardy; is that right?

5 A. Yes.

6 Q. So there's no dilemma or dispute there.

7 A. No, there isn't.

8 Q. Now to go back to an assertion you made in open session to the

9 effect that the Serbian Volunteer Guard was under the control of the state

10 security, the DB, of Serbia. Did you say that?

11 A. Yes, I did.

12 Q. Or rather, that the state security of Serbia was in charge of the

13 SDG.

14 A. At the front line, yes. But with respect to the call-up for the

15 SDG, no.

16 [redacted]

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21 JUDGE MAY: Just stop here.

22 We'll go into private session.

23 THE ACCUSED: [Interpretation] Mr. May --

24 JUDGE MAY: You know quite well that this should be in private

25 session.

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23 [Open session]

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

25 MR. MILOSEVIC: [Interpretation]

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1 Q. Since you mentioned -- but let us conclude first with what I

2 challenged, and that is your assertion that the state security had

3 control. There is a segment that I am quite sure you spoke about in open

4 session; namely, the transcripts that were read out were not in private

5 session, were they?

6 A. No, they weren't.

7 Q. In one of the transcripts of one of the conversations, Arkan uses

8 a derogatory term, "stinkers," for certain people, doesn't he?

9 A. Yes.

10 Q. And you were asked here by the side opposite what -- to whom did

11 he refer, and you answered that it referred to the state security and the

12 police; is that right?

13 A. Yes.

14 Q. Now, tell me, this fact, though it is much less significant than

15 the previous one, regarding this alleged control by the state security of

16 the Serbian Volunteer Guard, doesn't that fact too show that this was not

17 a relationship of cooperation or -- I don't know how to put it --

18 customary, friendly, constructive links, if, as you say, that expression

19 that was used by Zeljko Raznjatovic, the expression "stinkers," applied to

20 the state security and the police?

21 A. Could you ask a specific question, please.

22 Q. When somebody uses an expression of that kind, as you yourself

23 allege, and it refers to members of the state security and the police,

24 would he use such an expression to describe people he collaborates with?

25 A. It was normal when we are talking about the late commander.

1 Q. I see. So that is how describe -- he described people he was

2 collaborating with.

3 A. Yes.

4 Q. Very well. Fine. You say - now that we are on page 5 of your

5 statement - that only volunteers were sent to Bosnia; is that right?

6 A. Do you mean the operation of 1995, September and October?

7 Q. Yes, September/October 1995, you say that 5.000 men were arrested.

8 And as far as I understand it, this was mobilisation of members of the

9 Army of Republika Srpska Krajina and they were in the Republic of Serbian

10 Krajina and Eastern Slavonia; isn't that right?

11 A. Those -- that was not the army of the Republic of Serbian Krajina.

12 Those were refugees, men, refugees who had fled to Serbia in August, after

13 the Operation Storm of 1995.

14 Can I finish? Can I finish my answer?

15 JUDGE MAY: Yes, of course.

16 THE WITNESS: [Interpretation] When they arrived in Serbia, they

17 were asked to show their IDs everywhere, in coffee bars, in the streets,

18 et cetera. And they would end up in the prison in Sremska Mitrovica and

19 from there they would be sent to our camp in Erdut. I know that because

20 by mistake a young man from the Guards who was from Krajina was also

21 arrested in this way, and he called me up from prison and upon my

22 intervention - that is, I called up Sladjana, Frenki's secretary - and he

23 was released.

24 MR. MILOSEVIC: [Interpretation]

25 Q. Do you know that the authorities of the Republic of Serbian

1 Krajina, these people that you consider refugees, were considered by them

2 to be military deserters and they were mobilised so that in Eastern

3 Slavonia they should fulfil their military duty?

4 A. I personally do not consider them deserters because, after the

5 Operation Storm in August 1995, those people lost everything. And if you

6 had seen them at the camp in Erdut, you would share my opinion.

7 Q. Very well. But doesn't this appear to be an argument in favour of

8 what I'm saying? I'm not saying what I believe but what the authorities

9 of the Republic of Serbian Krajina felt about it. You say that only

10 volunteers were sent to Bosnia; nobody forced anyone to go to Bosnia among

11 them, even those people from the Republic of Serbian Krajina. But they

12 were requested to join the forces of the Republic of Serbian Krajina in

13 Eastern Slavonia, Baranja and Western Srem, which was a part of the

14 Republic of Serbian Krajina.

15 A. They didn't ask them to do that; they were forced to do that.

16 Q. I'm just making a distinction between what you said and --

17 regarding this and the other point that you made when you said that only

18 volunteers went to Bosnia. Is that clear?

19 A. Yes, it is.

20 Q. And were those people originally from Krajina?

21 A. Yes.

22 Q. And were they militarily engaged in Krajina?

23 A. The majority of them, when they arrived, those that I saw at the

24 camp in Erdut, were wearing civilian clothes, so I can't say whether they

25 were militarily engaged when they were being arrested all over Belgrade.

1 Q. Very well. You have given three statements to the investigators;

2 is that right, so far?

3 A. Yes.

4 Q. Did they call you all three times, or did you report to them

5 whenever you remembered something?

6 A. They called me.

7 I would just like, Your Honours, to ask whether this applies to my

8 first contact. Did I report myself or did somebody ask me to testify? So

9 I want to be quite clear on that as to be able to give a correct answer.

10 Q. My question was quite clear: Did they call you all three times or

11 did you report to them?

12 A. They called me all three times.

13 Q. And since you are testifying here about events covering a period

14 of almost four years before you started working, can you tell me who

15 assisted you in presenting all these facts in such -- with such apparent

16 precision when you weren't working for those four years?

17 A. No one assisted me. I think I was intelligent enough, and if I

18 was working for two years and if I had documents in front of me that I had

19 access to, I can put them in chronological order myself in my mind.

20 Q. Tell me, apart from what you provided as a diary, did you provide

21 any other documents?

22 A. Documents from the SDG headquarters could not be taken out because

23 in the headquarters whatever was being done during the day would be

24 destroyed in the evening.

25 Q. So tell me now, if everything that was done over the day would be

1 destroyed in the evening, how, then, did you have access to documents four

2 -- covering a period of four years prior to when you started working?

3 A. Because some documents relating to combat stayed behind, documents

4 relating to operations in which the Serbian Volunteer Guard participated.

5 But papers and documents relating to day-to-day obligations, either of the

6 staff or members of the Serbian Volunteer Guard, after the work was done,

7 would be destroyed.

8 Q. Very well. Do you know, then, that the Serbian Volunteer Guard

9 did not conceal at all the activities it participated in in defence of the

10 Serbian people in Krajina and in Bosnia-Herzegovina?

11 A. It did conceal things, like Velika Kladusa.

12 Q. We'll come to Velika Kladusa too. But tell me, are you aware that

13 when the Serbian Volunteer Guard was, shall we say, in the Republic of

14 Serbian Krajina, or to be more specific, in a part of that republic that

15 is called Eastern Slavonia, Baranja, and Western Srem, that it was under

16 the command of the Serbian Army of Krajina? The Serbian Army of Krajina

17 had its own staff.

18 A. Are you talking about 1991?

19 Q. I am talking about any period of time when the Serbian Volunteer

20 Guard was engaged either in Bosnia-Herzegovina or in Krajina.

21 A. I don't agree with you regarding 1995.

22 Q. Does that mean that my assertion that the Serbian Volunteer Guard,

23 whenever it participated in extending aid in combat operations either in

24 Bosnia or in Krajina, was under the command of the Serbian Army of Krajina

25 or of the army of Republika Srpska or the police of Krajina and the police

1 of the Republika Srpska?

2 A. That may be right in the period from 1991 to 1993, but when the

3 camp was reopened in 1995, in May, the camp was opened with the assistance

4 of the state security.

5 Q. And do you know that in 1995, regardless of what you're saying

6 about the opening of a camp and that it was done with the assistance of

7 the state security, do you know that in Eastern Slavonia, Baranja, and

8 Western Srem there were no combat operations in 1995?

9 A. The camp was opened after the fall of Western Slavonia, so after

10 May 1995 -- or rather, during May, after the Operation Flash in Western

11 Slavonia, and you can't just open a military camp just like that, without

12 somebody's approval.

13 Q. I'm not saying whether somebody opened a camp in the territory of

14 the Republic of Serbian Krajina without the permission of the authorities

15 of that republic. But as you're talking about the opening of that camp in

16 1995, you're talking about Eastern Slavonia, aren't you?

17 A. Yes.

18 Q. I'm asking you, then: Are you aware that there were no combat

19 operations in 1995 in Eastern Slavonia?

20 A. There were not, but that camp was opened out of fear that the

21 events from Western Slavonia could spread to Eastern Slavonia.

22 Q. Very well. Do I understand you correctly, then: That camp was

23 opened out of precaution so as to prevent any possible attack on Eastern

24 Slavonia?

25 A. Yes.

1 Q. You mentioned the army in Eastern Slavonia, Baranja, and Western

2 Srem, and yesterday, towards the end of the day, you mentioned General

3 Loncar.

4 A. Yes, I did.

5 Q. You spoke about him as being the commander of units of the army of

6 Yugoslavia and Eastern Slavonia, Baranja, and Western Srem; is that

7 right?

8 A. Yes, because that is how he introduced himself.

9 Q. I don't know what he said when he introduced himself to you, but

10 do you know that General Loncar was the commander of the forces of the

11 Serbian Army of Krajina in Eastern Slavonia, Baranja, and Western Srem?

12 A. Yes. But all his documents which came from his headquarters, even

13 to our headquarters in Belgrade, bore the military post of the Army of

14 Yugoslavia. I can even give you the number: VJ9189/9.

15 Q. The military post in this case can be used for communication and

16 certainly not for marking or for indicating that somebody was a member of

17 the army of Yugoslavia. Do you know that towards the end of 1995 the war

18 stopped throughout the territories of the former Yugoslavia, that the

19 Dayton Accords were signed? Do you know that at that time the agreement

20 was signed on the transitional state for the territory of Eastern

21 Slavonia, Baranja, and Western Srem and that same General Loncar, as the

22 commander of the army of the Republic of Serbian Krajina, cooperated

23 directly with an international mission which was led at the time by

24 William Walker. Are you aware of that?

25 A. No.

1 Q. Well, do you know that that cooperation lasted for two years and

2 it wasn't cooperation which --

3 JUDGE MAY: The witness doesn't know about the cooperation.

4 THE ACCUSED: [Interpretation] All right. Very well, Mr. May. All

5 I wanted was to challenge the assertion that it was -- it referred to the

6 formation of the army of Yugoslavia. Or rather, I'm quite certain that

7 the other side over there knows full well that what all this is about is

8 the military units of the Serbian Army of Republic of Krajina.

9 JUDGE MAY: You can make your speeches in due course. Just ask

10 the witness questions.

11 MR. MILOSEVIC: [Interpretation]

12 Q. All right. Tell me this: Did you decide to make statements to

13 the investigators on your own, independently, or did you consult anybody

14 before doing so? Did you ask for permission from anyone, or at least

15 advice from anybody? Because I have the impression, in view of the fact

16 that you stated everything you stated here, that you had a very good

17 consultant.

18 A. My decision to speak was made by myself. I, myself, decided to do

19 so.

20 Q. All right. Did you consult anybody as to the contents of what you

21 were going to say? Did you talk to anybody to have them remind you of

22 certain details and events? Because it seems to me rather improbable for

23 you to be able to testify about four years when you didn't work on the

24 basis of your recollections or on the basis of what people said and in

25 those particular years.

1 A. I have to tell you that you over there -- had you worked over

2 there, you would have remembered things your entire life, because to bury

3 12 young men who were fighting for the Serbian people is a very difficult

4 thing, and that is why I wanted to say what I know, because it would

5 appear that the war boiled down to smuggling and that those young men had

6 died for no reason whatsoever.

7 Q. Who was it who engaged in smuggling over there?

8 A. You want to know who engaged in smuggling? You want to say that

9 the war was actually smuggling? And you're very well aware of that.

10 Q. Certainly there were war profiteers, but do you want to say that

11 the SDG engaged in smuggling?

12 A. Yes.

13 Q. All right. Very well. That's something that you're testifying

14 about on the basis of your knowledge; is that right?

15 A. How do you mean on the basis of my knowledge?

16 Q. On the basis of your knowledge and information that the

17 institution, that particular institution, the SDG, because officially you

18 were working in the SDG, were you not?

19 A. I'm sorry, the Party of Serbian Unity. The Party of Serbian Unity

20 headquarters and the SDG headquarters were in the same building. The

21 difference was that when there were operations, Borislav Pejovic was the

22 president of the party and the late commander was the commander of the

23 SDG, and he was honorary president of the Serbian Unity Party.

24 Q. All right. But at any rate, he was the main personage in the

25 Serbian Unity Party.

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1 A. Who do you mean?

2 Q. Well, I mean Zeljko Raznjatovic.

3 A. Yes.

4 Q. You mentioned Pelevic. Pelevic is a professor, isn't he?

5 A. Well, I can't really say. When I stopped working, he wasn't a

6 professor at that time.

7 Q. All right. But as you mention him in connection with the military

8 activities, from the information I have, he dealt with the political

9 aspects of the Party of Serbian Unity. He never engaged in any combat,

10 military operations. Is that true?

11 A. Yes. But during the Banja Luka operation, he did spend time,

12 three or four days, in fact, in Banja Luka. And upon his return, when he

13 came back, he told us that together with the late commander and also with

14 General Talic, he took part -- or, rather, he said he defended Banja Luka

15 together with them, as he put it.

16 Q. All right. And do you know that Banja Luka was on the territory

17 of Republika Srpska and that, thank God, it is still in the territory of

18 Republika Srpska?

19 A. Yes, I do know that.

20 Q. Do you know that Prijedor itself is very close to Banja Luka?

21 A. Yes, I do know that. But I also know that Banja Luka in 1995 was

22 on the brink of falling into enemy hands.

23 Q. All right, then. Is it clear to you, then, that the fact that

24 they were defending Prijedor and Banja Luka, that that was a defensive

25 operation, or rather, that they were defending those towns from the

1 offensive that was being launched by the Croatian and Muslim forces in

2 that part of the territory of the Republika Srpska?

3 A. Yes.

4 Q. So it was no offensive. It was the defence of Prijedor and Banja

5 Luka. Are you aware of that?

6 A. Yes, I am.

7 Q. Where do you see, then, in all that something that you don't

8 consider to be in order and proper?

9 A. My testimony was not as to whether I considered something to be

10 proper or improper. All I was doing was presenting some facts or my

11 knowledge about them. So I haven't come here to testify, to say what is

12 proper and improper or correct conduct or not.

13 Q. Well, that's okay. Yes. Now, you mentioned General Talic, and

14 General Talic was the commander of the corps of the army of Republika

15 Srpska precisely with its headquarters in Banja Luka. That's right, isn't

16 it?

17 A. Yes.

18 Q. So they helped Talic's forces and they actually became part of

19 Talic's forces, troops.

20 A. Yes.

21 Q. Well, in that particular operation, don't you assume, then, that

22 they had to be within the composition of the Army of Republika Srpska?

23 A. The Guard took part in the area together, but it wasn't in the

24 composition of the Army of Republika Srpska. The Guard, that is to say,

25 the task of the Guard was, to all intents and purposes, to keep the

1 positions from which the Army of Republika Srpska had fled, to maintain

2 those positions.

3 Q. At any rate, they were there to defend the territory of Republika

4 Srpska; right?

5 A. Right.

6 Q. You're not challenging that?

7 A. No, I'm not.

8 Q. All right. Let's move on because we've been discussing different

9 areas. You say that later on they made you the proposal of becoming a

10 member of the special DB unit; is that right?

11 A. Yes.

12 Q. And you filled out some forms, as far as I understood.

13 A. Yes.

14 Q. And from what I've read from your statement, you were not admitted

15 because of your hatred towards me.

16 A. Not because of hatred. I do not feel any hatred towards anyone.

17 I was not taken on because I didn't share the political views of the then

18 -- that is to say, the political leadership, and quite obviously the

19 climate that prevailed was such in the DB that you had to agree.

20 Q. Yes, but you mentioned my name. You don't talk about the

21 political leadership and the political climate and things of that sort,

22 you say Slobodan Milosevic. So was there a question in the form which

23 said: Do you like or dislike Slobodan Milosevic?

24 A. No. But it did ask what I thought about the party.

25 Q. You mean the Socialist Party?

1 A. Yes.

2 Q. Well, were you asked about any other party, what you thought about

3 any other party?

4 A. No.

5 Q. So they just asked you about the Socialist Party.

6 A. Yes, that's right.

7 Q. But yesterday you said that they didn't take you on because you

8 mad had taken part in the 1991/1992 demonstrations.

9 A. Yes. That was the second time they called me up and told me that

10 I was undesirable politically because I had been a participant in the

11 demonstrations in 1991 and 1992. What they do is they first invite you

12 for an interview, you fill out a form, then a month or two goes by, they

13 check out all the information you have entered into the form. That's the

14 procedure. I'm speaking in general terms. And after that, I was told

15 that I was a participant in the events of 1991 and 1992.

16 Q. Well, how did you get the idea of mentioning my name in your

17 statement and linking me up to the fact that you were not admitted, not

18 taken on?

19 A. The accused was the president of the Socialist Party of Serbia at

20 the time, and I said after my work in the Serbian Volunteer Guard and the

21 Party of Serbian Unity, but first of all my work in the SDG, I said I did

22 not agree with the politics and policy of your party and your own

23 policies.

24 Q. But as far as I am able to understand you now, from your

25 explanations, you didn't mention me specifically at the time.

1 A. Where? In my testimony or what?

2 Q. No. In the interview that you had when you applied for the unit.

3 A. I just said at the time that I did not agree with the SPS policies

4 and with your own policies and politics.

5 Q. And you think that that was the reason for which you were refused.

6 A. Yes.

7 Q. And not because of what you said yesterday, for taking part in the

8 demonstrations.

9 A. For both reasons; because of one and the other.

10 Q. All right. Fine. Tell me, how did you come to work for the Party

11 of Serbian Unity the first time?

12 A. The first time?

13 Q. Yes, the first time.

14 A. Well, the first time they needed people to work for them at their

15 headquarters. It was located in Savska Street, number 7 or number 9,

16 close to or, rather, opposite the railway station in Belgrade. And an ad

17 appeared, and I responded and I began working there, and I also became a

18 member. I'll tell you that straight away. I also became a member of the

19 party because they preferred having members work for them rather than

20 non-members.

21 Q. So you became a member of the Party of Serbian Unity exclusively

22 in order to get a job there.

23 A. Right.

24 Q. But you didn't share their political opinions, did you?

25 A. I didn't think about their political positions at all at that

1 time.

2 Q. All right. But I assume that the work you were supposed to do

3 there then was confidential in many respects, in view of the large number

4 of contacts and your access to documents and so on and so forth, the

5 documents that you're talking about, and there were many of those.

6 A. Let me correct you. When I was taken on board, all that existed

7 was the Party of Serbian Unity at that time, because the Serbian Volunteer

8 Guard at that point in time only had a camp open in Erdut. The

9 headquarters were separate, so it didn't matter who worked there. And my

10 job was to draw up the cards. So you didn't need anybody confidential,

11 trustworthy for that, in that respect.

12 Q. Well, in one of the exhibits that were shown here - and I see that

13 you have attached your entire diary - you have a stamp with the facsimile

14 of Zeljko Raznjatovic, Arkan's signature; is that right?

15 A. Yes.

16 Q. Did you have that stamp available to you?

17 A. Yes. In 1995 at the SDG headquarters I did have the use of that

18 stamp. It was available to me.

19 Q. All right. So the stamp with his signature was used to authorise

20 and certify certain documents in his own name, so that they should be

21 considered as having been signed by him.

22 A. Yes.

23 Q. Well, doesn't that mean that you were somebody of the greatest

24 credentials and confidentiality if you were allowed to place the stamp

25 with his signature on documents coming out of the party or the SDG?

1 A. Only documents in the course of 1995 coming out from the SDG.

2 Q. All right. But if somebody gives you the use of a stamp which you

3 can then use for any document whatsoever, I think we can assume that you

4 were somebody who was very confidential and trusting, because if you

5 wanted to abuse it, you could put it down on any document. And if you

6 were entrusted with the stamp, that means that they had maximum confidence

7 in you and that they thought you wouldn't misuse that highly placed trust.

8 Is that right?

9 A. Yes.

10 MR. NICE: Your Honour, I don't know if the witness wants to give

11 any consideration to the degree to which she's giving more detail now

12 about the use of the stamp and the issue that arose earlier. It's a

13 matter for her, of course.

14 JUDGE MAY: Yes. The witness will have heard that.

15 Yes, Mr. Milosevic, keep going.

16 THE WITNESS: [Interpretation] We can keep going. It's fine.

17 MR. MILOSEVIC: [Interpretation]

18 Q. All right. Not to have to go back into private session again, and

19 bearing in mind the facts that you presented and the ones that I quoted to

20 you in private session, and the reasons and consequences that emanated

21 from that, how is it then possible that a highly trusted individual as

22 yourself, of that kind - how shall I put this? - how can they be qualified

23 as -- or termed as a hostile element, if I can put it that way, in that

24 group of people?

25 A. I was never a hostile element in the group. All I did was do my

1 job seriously. It was just up to me to work, and I always took my job

2 seriously, and that's what I did. I did my job properly. And I think

3 that that's why they -- or rather, the commander had placed a great deal

4 of trust in me.

5 THE ACCUSED: [Interpretation] All right, Mr. May. As you insist

6 that this be in private session, I should like to quote --

7 JUDGE MAY: We are not. We are in open session now. Now, are you

8 going to go into private session in? Is this something that should be

9 dealt with?

10 THE ACCUSED: [Interpretation] I just want to ask the witness a

11 more precise question, because you said that it shouldn't be mentioned in

12 open session.

13 JUDGE MAY: All right. We'll go into private session.

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18 [Open session]

19 THE REGISTRAR: We are in open session.

20 MR. MILOSEVIC: [Interpretation]

21 Q. Witness 129 --

22 THE REGISTRAR: We are in open session, Your Honours.

23 MR. MILOSEVIC: [Interpretation]

24 Q. Witness 129, I hadn't realised that we were in private session

25 still, so I asked a number of questions that would not require a private

1 session. I had asked you about your notes which were given to me by the

2 side opposite as some sort of a diary of yours.

3 Now, will you please show on the ELMO, without any selection, ten

4 or so pages from that diary.

5 True enough, I can't see anything here.

6 Will you please leaf through ten or so pages of that diary. Go

7 on, please. Go on, please. Without any selection at all.

8 I think that will be sufficient, so that we don't use up too much

9 time, et cetera, et cetera.

10 On various pages one can see that you need to wake up someone at a

11 certain time or things like that. Do you call this a diary?

12 A. Yes, it is a diary of my daily duties.

13 Q. So what was shown on one page is your duty for that day; is that

14 right?

15 A. No. We had two books, two notebooks. One was always in front of

16 us at headquarters. It was a notebook for the duty person, who would

17 write down everything. And then the next morning the page would be torn

18 out from the previous day. And this other diary - and I have provided two

19 notebooks - these refer to me personally, things that I myself needed to

20 do. And I took note of those things in separate notebooks so as not to

21 forget, because most things everyone in the staff would be doing. But as

22 there were many events during the day, and if they couldn't do it, I had

23 to note it down and do it.

24 Q. So this is a kind of agenda and reminder for you as to what you

25 needed to do during that day.

1 A. Yes.

2 Q. Will you please turn another page or so. A meeting, et cetera ...

3 lightbulbs, then a telephone.

4 I have a page here which was apparently torn out of the agenda as

5 an exhibit. They probably thought this to be something very important.

6 It is tab 8. I don't know whether you can find that page in the diary.

7 It ends with 1140. It's tab 8.

8 JUDGE MAY: Let the witness have tab 8.

9 MR. MILOSEVIC: [Interpretation]

10 Q. It's given here as some sort of exhibit. This is the one that

11 says "pistols."

12 JUDGE MAY: Tab 9, according to my records. I may be wrong. Tab

13 9, and if that could go on the ELMO.

14 MR. MILOSEVIC: [Interpretation] Yes, please. No, not that one.

15 Q. Again, I can't understand what all this is about, to send

16 something to someone.

17 THE ACCUSED: [Interpretation] I have it here, Mr. May.

18 JUDGE MAY: What are we talking about? Start again. Start again,

19 Mr. Milosevic. What is it you want on the -- what is the entry you want

20 on the ELMO? What does it say? And then we can find it.

21 THE ACCUSED: [Interpretation] It's given here as an exhibit.

22 JUDGE MAY: No. Tell us what it says. And then we can discern

23 whether it's an exhibit or not.

24 MR. TAPUSKOVIC: [Interpretation] Your Honours, it's tab 9.

25 THE ACCUSED: [Interpretation] In my batch, it's 8.

1 JUDGE MAY: Is this what you want, Mr. Milosevic? "At 8.30,

2 Erdut, pistols." Is that what you want?

3 THE ACCUSED: [Interpretation] Yes. Yes.

4 JUDGE MAY: Put it on the ELMO, please.

5 Very well. Now, what do you want to know about this?

6 MR. MILOSEVIC: [Interpretation]

7 Q. Tell me, since this has been exhibited, what does this prove,

8 please?

9 A. Let me see. On that day -- that day was St. Nikolas Day and it

10 was being celebrated at the headquarters in Erdut. The commander had

11 prepared pistols for the officers and men who had merits for the Serbian

12 Volunteer Guard, and each of those pistols had an inscription on it.

13 Q. Very well. So we're talking about gifts, are we?

14 A. Yes, gifts as pistols.

15 Q. Among us Serbs, it is quite frequent to give a pistol as a gift,

16 especially to men.

17 A. Yes. But each of those pistols had a document attached containing

18 a licence, a permit, from the military post in Erdut.

19 Q. The military post in Erdut could normally issue permits to members

20 of the units belonging to it, because they were in Erdut and that was

21 within the competence of the army of the Republic of Serbian Krajina.

22 A. Yes. But allow me to finish.

23 Q. Yes, please do.

24 A. But those pistols just needed to be presented over there at a

25 formal ceremony, upon which all of them returned with those pistols and

1 wore them in Belgrade, with the permit issued by the military post in

2 Erdut.

3 Q. Is it a problem that the authorities in Serbia recognised the

4 documents of the authorities of the Republic of Serbian Krajina?

5 A. I'm just speaking of facts. I don't know whether that is a

6 problem or not.

7 Q. But Mr. Nice asked you: Could Vukovar license plates be used in

8 Belgrade? The license plates of all over the place were used.

9 JUDGE MAY: If you're going on to ask about license plate, it's

10 another -- it's another topic. Now, have you finished with the diary or

11 not? If so, can the usher remove it and we can go on with the rest of the

12 evidence. Have you finished with the diary, or do you want to ask

13 anything else?

14 MR. MILOSEVIC: [Interpretation]

15 Q. Tell me, as we -- [no interpretation]

16 JUDGE MAY: The interpretation --

17 MR. MILOSEVIC: [Interpretation]

18 Q. What does that telephone number mean that can be seen on that same

19 page?

20 THE INTERPRETER: The interpreter apologises, the microphone

21 wasn't switched on.

22 MR. MILOSEVIC: [Interpretation]

23 Q. I was asking you -- the interpreters couldn't hear me. What does

24 this telephone mean on this same page?

25 A. I can't remember.

1 Q. You can't remember?

2 A. No.

3 Q. My associates have checked. It's the telephone number in a

4 restaurant at the Red Star stadium.

5 A. Possibly. I don't remember.

6 Q. But is your building across the street from the Red Star stadium?

7 A. Yes.

8 Q. And you called up somebody in the restaurant there at the

9 stadium?

10 A. Possibly.

11 Q. Please -- very well. Let us not dwell on that diary any more. I

12 think we've established that it is not a diary but a simple reminder of

13 your own.

14 JUDGE MAY: Let the diary go back to the accused.

15 MR. MILOSEVIC: Yes, thank you.

16 Q. [Interpretation] Mr. Nice asked you whether the Serbian Volunteer

17 Guard was also known as the Serbian National Guard, and you said no.

18 A. No.

19 Q. And do you know that Mauzer's guards in Bosnia called themselves

20 the Serbian National Guard?

21 A. No. We called them the Panthers.

22 Q. Very well. You probably called them that later on, when their

23 commander was killed whose name was Pantelic.

24 But will you please now answer a few questions having to do with

25 these intercepted telephone conversations.

1 THE ACCUSED: [Interpretation] But I would like to hear first,

2 Mr. May, what is the source of those intercepts. Can we be told the

3 source of those transcripts?

4 JUDGE MAY: Yes.

5 MR. NICE: I'm not in a position to give the source at the moment,

6 not least because the computer system is down and my ability to retrieve

7 information of that kind is not immediately available to me.

8 If there's no other impediment in providing information, I can do

9 it after the break. Well, I -- I hope I can. Again, it may be dependent

10 on the computer access.

11 JUDGE MAY: Very well.

12 THE ACCUSED: [Interpretation] Very well. Then we'll leave that

13 area -- that matter out and we'll move on to the transcripts of those

14 intercepted conversations.

15 MR. MILOSEVIC: [Interpretation]

16 Q. Before you were given the transcripts of these conversations, you

17 were asked by the side opposite how Arkan arrived in Bijeljina. Do you

18 remember that?

19 A. Yes. Yes.

20 Q. And your answer was that he came there upon the invitation of

21 Biljana Plavsic.

22 A. Yes, because he himself repeated that several times at

23 headquarters.

24 Q. Very well. Now, this transcript was rather later, some 20 days

25 after these things in Bijeljina, when Biljana Plavsic called him up and

1 spoke to this Rus.

2 A. Rus. Yes, I see.

3 Q. So according to my information, it was not just Biljana Plavsic

4 but the local leadership and this same Mauzer who was the commander of the

5 Serbian National Guard and who is also from Bijeljina. You know that.

6 A. Yes. But the commander always spoke with pride of the fact that

7 Biljana Plavsic had called him to fight there.

8 Q. I see. He spoke with pride of the fact that Biljana Plavsic had

9 called him to fight there. Well, then was he sent there by the Serbian

10 state security, or upon the invitation of Biljana Plavsic?

11 A. Are you talking about Bijeljina?

12 Q. Yes, I'm talking about Bijeljina.

13 A. She invited him, yes.

14 Q. So it wasn't the state -- the Serbian state security that sent him

15 there.

16 A. I was only speaking about the Serbian state security during the

17 period that I was employed at the headquarters.

18 Q. Yes, that's fine. But you said in general terms in your

19 statement, and I quote from your statement, on page 6 of your first

20 statement: "Arkan did not fall from the sky. His units would never have

21 been able to act in the way they did had they not been an integral part of

22 the state security of Serbia."

23 A. Yes.

24 Q. And on the second page of your second statement, in paragraph 8,

25 speaking about Arkan, you say: "Arkan was always on good terms with the

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1 DB. Even before the war, he was an agent working for the DB outside the

2 borders of Yugoslavia." You said all that, didn't you?

3 A. Yes, I did.

4 Q. So what you're saying now is something else. What I quoted you as

5 saying, you are saying related to the period after 1994. As for

6 Bijeljina, you say that he told you with pride that he was invited by

7 Biljana Plavsic.

8 JUDGE MAY: [Previous translation continues]... try as possible to

9 follow that question. Can you put it clearly what it is you want to say.

10 MR. MILOSEVIC: [Interpretation]

11 Q. All I want is to clear this up. According to your own knowledge -

12 and I don't want you to say anything that is not part of your own

13 knowledge - that he went to Bijeljina at the invitation of Biljana Plavsic

14 and not by being sent there by anybody from the DB of Serbia.

15 A. He said that he had been invited by Biljana Plavsic herself.

16 Q. Very well. Now, look at this transcript, please, of the

17 conversation of the 23rd of April, 1992 that we listened to yesterday.

18 And it says: "I still haven't reached home. A small section is blocked.

19 But I wanted --" This is at the beginning of the second half of this

20 transcript. Can you find it?

21 A. Yes, I've found it.

22 Q. "A small section is blocked, but I just wanted, and would you ask

23 him in principle if we were to call for him to come here, would that be

24 possible?" So what -- do you understand her question?

25 A. I understand. But all I was asked to do was to identify the

1 persons and not to comment on their conversation.

2 Q. Very well. But does that agree with what your commander said to

3 you about him going there upon the invitation of the leadership, or

4 rather, one of the main members of the leadership of Republika Srpska?

5 A. Yes.

6 Q. So this question relates to going there to some other location.

7 Is that clear from this conversation?

8 A. Yes, it is.

9 Q. Now, will you please look at it. It says, "I don't have the

10 authority." And she says, "Yes, I understand that." And he says he will

11 pass on the message immediately. "Please convey to him that once I am in

12 my apartment, I will call him up." Yes. And then, "I won't ask him

13 this." She says, "I won't ask him this, but I will only ask him whether

14 he will bring those goods if he can." Is that right?

15 A. Yes.

16 Q. Does that mean that this will be in place of this question as to

17 whether they could go there?

18 A. I can't know that.

19 Q. But yesterday Mr. Nice asked you what kind of goods were referred

20 to. Isn't it clear from this conversation that this is an expression to

21 be used instead of going there? Because she says, "I won't put the

22 question in this form, but I will ask whether those goods can be

23 brought."

24 A. As far as I can remember, the Prosecutor Nice didn't put the

25 question quite in that form.

1 JUDGE MAY: That will be a matter for us to decide.

2 It's time that we adjourn. We'll adjourn now, as I said, for half

3 an hour, and we'll come back then --

4 Oh, yes.

5 MR. KAY: Your Honour, can I raise a matter? It's to do with the

6 scheduling of matters due to rearrangements today. It causes difficulty

7 for us, for obvious reasons.

8 Mr. Tapuskovic is in fact dealing with this witness. The other

9 matters, the legal argument, was going to be dealt with by me. I doubt

10 whether we're going to have time to deal with it today, realistically, but

11 I had personal arrangements which it's impossible to break due to the

12 particular date.

13 JUDGE MAY: Very well. It's unsatisfactory, completely

14 unsatisfactory, impossible to get this work done. It's not your fault.

15 Not your fault.

16 We must finish this witness today. And Mr. Tapuskovic, I fear

17 that your cross-examination will have to be necessarily very limited in

18 order to do so. I will give a ruling so that parties may know what --

19 what the position is about those witnesses on whom we have ruled.

20 Very well. We'll come back, finish this witness after the break.

21 --- Recess taken at 12.29 p.m.

22 --- On resuming at 1.08 p.m.

23 JUDGE MAY: Yes. We've got one session left.

24 Mr. Tapuskovic, how long would you want with this witness, in the

25 circumstances?

1 MR. TAPUSKOVIC: [Interpretation] I'm afraid I didn't hear your

2 question. There was no interpretation.

3 JUDGE MAY: How long would you want with the -- this witness,

4 there being just this session left?

5 MR. TAPUSKOVIC: [Interpretation] I did my best to shorten it as

6 far as possible during the break, so I think perhaps five or six minutes,

7 maybe a few minutes more.

8 JUDGE MAY: Very well.

9 Yes, Mr. Milosevic.

10 Mr. Nice, one matter: We'll have to deal with these

11 administrative matters first thing on Monday morning. It's absurd that we

12 miss the opportunity so regularly because of circumstances quite beyond

13 the control of the Court. But so the first session next Monday we will

14 deal with the matters concerning the witnesses on which we must rule.

15 Yes, Mr. Milosevic.

16 THE ACCUSED: [Microphone not activated]

17 THE INTERPRETER: Microphone, please.

18 The microphone was not switched on.

19 JUDGE MAY: Yes.

20 THE ACCUSED: [Interpretation] I was saying we ought to go back

21 into open session.

22 JUDGE MAY: If we aren't in open session, we certainly should be.

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

24 JUDGE MAY: My impression is we've been in open session for some

25 time.

1 MR. MILOSEVIC: [Interpretation]

2 Q. Would you please take a look at the second transcript of the

3 conversation played yesterday, and that is tab 6. And talking there are

4 Legija and Raznjatovic. I won't read out the whole of the transcript

5 because I've already asked you about it, about what it refers to and who

6 the speakers are, we've already established that, the stinkers and so on.

7 But at the end of the page, he says that 7.200 refugees were

8 stopped, and he speaks about Mladic, who was the commander of the military

9 district at that time. I assume you know about all that.

10 A. Yes.

11 Q. And I assume you knew that it was still the JNA which was

12 withdrawing and being attacked. Are you aware of that?

13 A. Yes.

14 Q. And then he goes on to say that he called Panic, the superior in

15 Belgrade, and he says, "Panic said that they should be released," that is

16 to say, that the people who had been stopped there - and he mentions 7.200

17 people - should be released, "That we are a humane people." That's what

18 he said. And he's making fun of Panic a little bit for saying that, but

19 without a doubt Panic is calling for the release of those people. He

20 wants the people to be released and not to have them stopped. Did you see

21 that?

22 A. Yes, I saw it in the transcript.

23 Q. So it's the transcript of that particular conversation.

24 A. Yes, and I heard the conversation.

25 Q. So the only person, as we can see from the transcript, that they

1 are communicating with in Belgrade, General Panic is insisting upon the

2 release of those individuals; is that clear?

3 A. Yes.

4 Q. And is it also clear that Legija in this conversation speaks about

5 an attack by the Green Berets which started shooting at the soldiers and

6 convoy? And that is towards the end of the second page -- well, not

7 really at the end, but what he says is this: "They should have released

8 the soldiers when the convoy left the barracks. These Jukina men --" he's

9 thinking about Juka Prazina, who committed the massacre of the soldiers

10 leaving the barracks. Do you remember the event?

11 A. Yes, I do. I saw it on television and read about it in the

12 papers.

13 Q. All right. And you remember events which did not take place while

14 you were working there, and yet you know nothing about this event and the

15 comments made in the Party of Serbian Unity, or the SDG, when he says that

16 the main man for the Green Berets - and he's talking about Juka Prazina -

17 he started shooting at them and they turned back. That's what it says,

18 and so on. I'm sure you know about that event, do you?

19 A. Not about the event, but I know about Juka Prazina, yes.

20 Q. Now, this man, Juka Prazina, you say you know only from the

21 papers, is that it?

22 A. Yes.

23 Q. Do you know that he committed a massacre of a column of soldiers

24 who were withdrawing from the barracks, and the JNA was withdrawing from

25 the whole territory, in fact?

1 A. No.

2 Q. I also asked you who else came to the party headquarters, and in

3 your statement it says that the late Zoran Djindjic would come by too.

4 When was that?

5 A. Zoran Djindjic was there in 1994.

6 Q. And what was the topic discussed? Why did he come at all? Do you

7 happen to know? What was the purpose of his coming?

8 A. He came in early autumn, which means September, when the Party of

9 Serbian Unity was just operating at that time.

10 Q. You know nothing more about that?

11 A. No.

12 Q. Did you cease being a member of the Party of Serbian Unity when

13 you left your job at the party?

14 A. How do you mean whether I stopped being a member?

15 Q. Well, you said you became a member of the Party of Serbian Unity.

16 Did you cease to be a member once you left your job in the party?

17 A. No. I kept my membership card.

18 Q. Are you a member of the Party of Serbian Unity today?

19 A. Well, I'm probably registered as a member, because anybody who

20 left the party would still have a membership card and therefore be on

21 their files.

22 Q. So you're not a member of any other party, are you?

23 A. No.

24 Q. What about your family members? Are they also members of the

25 Party of Serbian Unity or perhaps members of some other party?

1 A. My family members are not members of any political party.

2 Q. All right. As you spoke about volunteers yourself and said that

3 the volunteers were led by Arkan or sent by Arkan to certain operations in

4 Republika Srpska and the RSK, at that time did you know or perhaps comment

5 or anything else, learn anything else about how many volunteers, for

6 example, went from Serbian and Sandzak, in particular, the so-called men

7 from Sandzak, Sandzaklija [phoen], went to fight on the side of Alija

8 Izetbegovic? Do you know about that?

9 A. No.

10 Q. And do you know about this phenomenon at all that people did?

11 A. Well, I read about it in the papers, but I can't say anything more

12 than that.

13 Q. Well, as you say that the volunteers were mostly under the

14 auspices of some DB, some state security, can you assume, then, that these

15 volunteers were sent by the DB of Serbia?

16 A. No.

17 Q. You also speak about a forcible and -- forcible and irregular

18 conduct on the part of the SDG members, the Guards, and you testified

19 about that; isn't that right?

20 A. Could you be more specific? What do you mean by "forceful

21 behaviour," or "forcible"?

22 Q. Well, you said they looted, they perpetrated various unlawful

23 acts, they mistreated people.

24 A. I didn't say they looted or mistreated people. All I said was

25 that -- I just talked about the mistreatment of prisoners of war in Sanski

1 Most during the operation in Banja Luka and also the prisoners who were

2 killed in Velika Kladusa. And when I spoke about the looting and theft,

3 if I happened to mention this by chance, I just meant the smuggling that

4 went on. I didn't speak about any looting or thefts otherwise.

5 Q. All right. But you did testify, at least I think you did, and I

6 think you were a bit contradictory on this point, that a unit of the

7 military police was formed within the Guards and that they were in charge

8 of the members of the SDG, only them, for quite the opposite reasons, to

9 prevent them from looting, mistreating civilians, and so on, theft and

10 anything else. And then once the operation was completed, these were

11 disbanded, this unit was disbanded. Is that right?

12 A. Yes, that's right.

13 Q. Well, does that then mean that Zeljko Raznjatovic, or rather, the

14 Serbian Volunteer Guard, had a code of conduct, rules which would not

15 permit unlawful acts on the part of its members which could be perpetrated

16 in the course of a military action? Is that right?

17 A. Yes, rules did exist, but the facts show that at times those rules

18 were violated.

19 Q. Yes. But if a military police unit was set up to ensure, even by

20 using force, the application of those rules, doesn't that mean that it was

21 the position on the part of the command and Raznjatovic himself that any

22 unlawful acts must not be allowed to take place?

23 A. Yes, that was the position and view taken. That's right.

24 Q. Thank you very much. Now, you go on to talk about the prisoners

25 themselves, and Mr. Nice asked you something in that regard. Your

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1 response was, "He said they didn't have any prisoners," that that's what

2 he would say. And then you went on to explain that you understood that to

3 mean that the prisoners were killed. Is that what you said?

4 A. Yes.

5 Q. All right. And at the same time, simultaneously, you are

6 testifying to the fact that there was a man in charge of the exchange of

7 prisoners of war whose name was Voja, I believe, and that he was working

8 in the Party of Serbian Unity; isn't that right?

9 A. Yes. But that same individual worked on the exchange of prisoners

10 during 1991 and 1992.

11 Q. Well, yes. Does that then mean that the prisoners were not

12 killed? Doesn't it mean that? Or does it mean that the prisoners were

13 killed, as you claimed a moment ago?

14 A. The prisoners were killed, according to my knowledge, during the

15 Banja Luka operation and in Velika Kladusa.

16 Q. All right. Now, when you say to the best of your knowledge, where

17 do you get the knowledge from, this information that the prisoners were

18 killed?

19 A. Are you talk about Velika Kladusa and Banja Luka?

20 Q. Well, let's take Velika Kladusa first. What about that?

21 A. The wounded men, the volunteers who were wounded in Velika

22 Kladusa, once they had been returned to Belgrade, as they were

23 incapacitated and not capable of going back to Velika Kladusa, they would

24 remain at the headquarters in Belgrade and they would talk during the day

25 sometimes. They'd talk about it.

1 Q. All right. Now, did you at least from the papers learn about the

2 formation of the Autonomous Province of Western Bosnia whose president was

3 Fikret Abdic?

4 A. Yes, I did know that.

5 Q. Well, did you know that Velika Kladusa is precisely the centre of

6 that Autonomous Province of Western Bosnia?

7 A. Yes.

8 Q. Well, do you know from those times that the authorities of the

9 Autonomous Province of Western Bosnia had control over that territory, the

10 territory that was not held by the forces of Alija Izetbegovic?

11 JUDGE MAY: [Previous interpretation continues] ... the witness.

12 All she can say is what she heard, not what she knows from reading the

13 papers.

14 THE ACCUSED: [Interpretation] Well, she's talking about what she

15 learnt and heard about, and I'm asking, Mr. May --

16 JUDGE MAY: Did you learn -- what you can talk about are these

17 conversations.

18 Did the men say that they were under the control of Fikret Abdic

19 or anything of that sort? Did they say who they were under the control of

20 or not, or did they simply say what happened?

21 THE WITNESS: [Interpretation] They just said -- they just talked

22 about -- actually, they went there and were under the control of the units

23 of Fikret Abdic; however, they went off together with the members of the

24 Red Berets, and it was their task to train Fikret's men. But at the same

25 time, they did take part in operations together with them, and the result

1 of that was that we had two men killed and about ten -- between 10 and 15

2 others wounded.

3 Now, after that, they would come back to headquarters to work

4 there and they would talk about it, talk about how people behaved towards

5 the prisoners. And I'm thinking about the prisoners on Alija's part, how

6 Alija -- and some of those people are Zenica [phoen], Mali Rambo, Little

7 Rambo, and Gvozdeni. Those were the men who were wounded in Velika

8 Kladusa and later on worked at the headquarters of the Serbian Volunteer

9 Guard in Belgrade.

10 MR. MILOSEVIC: [Interpretation]

11 Q. All right. Fine. Now, I just want to make one point clear: As

12 in the Autonomous Province of Western Bosnia the authorities were from the

13 Autonomous Province of Western Bosnia, did they tell you who held these

14 prisoners, who the prisoners were controlled by, whether by the

15 authorities of Western Bosnia or your SDG?

16 A. Those prisoners were held by the members of the Autonomous

17 Province of Western Bosnia. However, the members of the Serbian Volunteer

18 Guard, as well as the Red Berets, also had access and were allowed

19 entrance into the prisons.

20 Q. All right. Now, according to what you know, were the prisoners

21 mistreated by the authorities which had control of the prisons or were

22 they mistreated by members of the SDG? Which is it?

23 A. According to what they said, the prisoners of war were mistreated

24 by the people who would be in prison at the time and the people who could

25 have been in prison at the time could have been members of the SDG and

1 members of the Red Berets and members of the regular army, that is to say,

2 Fikret Abdic's men; all the people who were there.

3 Q. Yes. But do you know that the regular army of the Autonomous

4 Province of Western Bosnia was in control of the prisons? I assume you

5 know that.

6 A. Yes, that's right.

7 Q. You were asked yesterday by Mr. Nice about the volunteers, and

8 your answer was that they were -- had to fill out a form of some kind; is

9 that right?

10 A. Yes.

11 Q. You did your best to establish that no people with psychological

12 problems or drug addicts, criminals, or anything of that sort applied;

13 isn't that right?

14 A. As far as criminals are concerned, we weren't able to establish at

15 first glance whether they were criminals or not because we didn't have

16 access to any criminal files, to checking out whether they had any

17 criminal files in the police force.

18 Q. That was precisely my next question. That's what I wanted to ask

19 you. As I made a note of this, your answer, exact answer to Mr. Nice's

20 question, when asked whether they had any criminal record in the police,

21 your answer was that you were not able to check that out because you

22 didn't have the ability and possibility of doing so; isn't that right?

23 A. Yes.

24 Q. Well, what kind of cooperation, then, are you talking about

25 between the police and the Serbian Volunteer Guard in the sense of some

1 sort of sponsorship, auspices, patronage or anything else, or command if

2 you were not able to access files of that kind, you weren't on a position

3 to find out whether somebody was a criminal or not?

4 A. We and the public security, or police, had absolutely no contact

5 with them, but there were so many volunteers that it would be quite

6 impossible for us to check each and every one of them out and to send

7 requests of that sort out every day to the -- and send lists to the DB for

8 them to have these people checked out and return the lists to us.

9 Q. All right. That means that you're changing your testimony now.

10 So you did have the possibility of doing so, whereas you said you did not

11 have the possibility of checking this out with the police, whether they

12 had criminal records or not.

13 A. When I said we didn't have the possibility of doing so, that's

14 what I was thinking of. There were just too many of them. We couldn't

15 send out the information on a daily basis and have the information

16 returned to us on a daily basis. That's what I meant.

17 Q. Very well. And you say that the state security of Serbia,

18 whenever it lacked personnel to take control of a location, that they took

19 members of the Serbian Volunteer Guard. That's what you said yesterday,

20 didn't you?

21 A. Yes.

22 Q. Tell me, which is the location that the DB of Serbia captured in

23 Bosnia or anywhere else in the Republic of Serbian Krajina? Which

24 location was captured by the state security of Serbia?

25 A. Maybe I misspoke when I said "captured." What I meant was when

1 they undertook certain operations, such as the one in Velika Kladusa, and

2 they lacked personnel, then they called up the late commander.

3 Q. And did you read the papers at the time and did you know about the

4 establishment of normal relations between the Autonomous Province of

5 Western Bosnia with the centre in Velika Kladusa, the Republika Srpska,

6 the Federal Republic of Yugoslavia, the signing of trade agreements, and

7 the possibilities that were ensured for the free passage of people

8 throughout those territories and for the normal traffic of goods and

9 persons?

10 JUDGE MAY: This is something -- did you -- let me ask the

11 witness. B-129, you're being asked about a whole lot of political

12 matters. Did you in the course of your business or work know anything

13 about any of this?

14 THE WITNESS: [Interpretation] No.

15 JUDGE MAY: Move on, Mr. Milosevic.

16 THE ACCUSED: [Interpretation] I am moving on.

17 MR. MILOSEVIC: [Interpretation]

18 Q. But didn't you read the papers, at least?

19 JUDGE MAY: That's the question --

20 MR. MILOSEVIC: [Interpretation]

21 Q. You could have seen --

22 JUDGE MAY: That is the question which I've said you can't ask.

23 It's no point what somebody read in the papers. It's totally irrelevant.

24 Now, move on.

25 THE ACCUSED: [Interpretation] Mr. May --

1 JUDGE MAY: Don't argue all the time. Just move on.

2 THE ACCUSED: [Interpretation] Very well, Mr. May. You consider it

3 irrelevant if the institutions of Western Bosnia, Serbia, and the

4 Republika Srpska cooperated?

5 JUDGE MAY: Do you want to continue with this cross-examination?

6 If you do, you'll get on with it. Or otherwise, I shall take it that

7 you've stopped and you prefer to argue about things.

8 THE ACCUSED: [Interpretation] Very well.

9 MR. MILOSEVIC: [Interpretation]

10 Q. On page 6 of your first statement, or rather, page 2 of your

11 second statement, in paragraph 8, you say that Arkan was an agent of the

12 state security; is that right?

13 A. Yes.

14 Q. And that you heard this from somebody called Kale who worked with

15 him.

16 A. Yes.

17 Q. And do you know that this had to do in those days to the state

18 security of the Socialist Federal Republic of Yugoslavia?

19 A. Yes. And when I said that, I meant the state security of SFRY. I

20 didn't mean that he worked as an agent for the state security of the FRY,

21 as an agent, or for the state security of the Republic of Serbia.

22 Q. Now, let us specify the period of time of which you say that he

23 was linked to the state security of SFRY. That was during the period

24 which Stane Dolanc, a Slovene, was still the Minister of the Interior,

25 wasn't it?

1 A. Yes.

2 Q. Well, I'm glad we've cleared that point up, at least.

3 On the second page of your first statement, you say that Radovan

4 Stojicic, Badza, and Arkan cooperated very well in 1991; is that right?

5 A. Yes.

6 Q. You know that from some confidential source, I assume, because you

7 weren't working there at the time.

8 A. I know that because the commander spoke about it. And even in the

9 office he had a photograph of him with Badza - I mean, the late Stojicic -

10 and later on, he removed it.

11 Q. Tell me, please, since you said yesterday that he said something

12 offensive about Badza, let me remind you that on the second page --

13 actually, the first page of your statement, but it bears the number "2,"

14 in the second paragraph, you say, "Smuggling was always a strain on their

15 relationship." You're talking about the relationship between Arkan and

16 the police. This is the paragraph in which you speak about Radovan

17 Stojicic.

18 And then you say, and I quote: "The police and the state security

19 didn't approve of it. At least, that is how it appeared to me." But

20 yesterday you said something to the effect that even they had been

21 smuggling. Did I understand you correctly or not?

22 A. The state security did not approve smuggling to such an extent.

23 They were aware that the Guard has to finance itself in some way, and part

24 of the money came from them but not all of it. We had to buy food,

25 clothing, and the rest. So that they tolerated it up to a degree.

1 Q. How do you know that they tolerated smuggling at all? As you

2 know, it is the duty of the police to prevent smuggling, and this was a

3 constant issue that was addressed at political meetings, at government

4 meetings, in police reports, and so on. And you say here that the police

5 and the DB didn't approve of it. So are you saying that up to a point

6 they approved, and beyond that, they didn't?

7 A. Yes, I believe that there was a degree up to which they would

8 tolerate it. For instance, for them it was normal for one truckload to

9 get through but not two or three.

10 Q. And how do you know that?

11 A. What?

12 Q. That they would tolerate one truck and not two or three?

13 A. Because they made comments to that effect, or rather, the

14 secretary with me.

15 Q. Which secretary?

16 A. Frenki's secretary.

17 Q. Did you personally meet that secretary?

18 A. Yes.

19 Q. And you knew her personally?

20 A. Yes.

21 Q. And you were on friendly terms with her?

22 A. I wouldn't say friendly. It was more of an acquaintance.

23 Q. Yesterday in the examination-in-chief you were asked by Mr. Nice,

24 when you spoke about Frenki and Jovica Stanisic, whether she ever told

25 you whether they had commented on their relationship with me. Is that

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1 right?

2 A. Yes.

3 Q. And you said no.

4 A. Yes, that's right; no.

5 Q. Did I or any of my associates ever have any contact with you? Not

6 with you personally but I mean the Volunteer Guard and so on.

7 A. No.

8 Q. I'm talking about your personal associates, from your cabinet,

9 from your office.

10 A. No. The answer is no.

11 Q. Since you say that they finance themselves among other ways by

12 smuggling, and here there's a whole paragraph - I don't wish to read it so

13 as not to waste time - the various donors of the Serb Volunteer Guard.

14 A. Yes, there were donors too.

15 Q. And then Mr. Nice interrupted you and said you'd needn't go on.

16 You just read out Giovanni di Stefano and the Karic brothers. You said

17 that yesterday.

18 A. Yes.

19 Q. Yesterday, on television, I hear the Karics denying that they ever

20 sponsored any formation that waged war anywhere in the territory of the

21 former Yugoslavia.

22 JUDGE MAY: This is not a matter of what the Karics said on

23 television. No doubt they would say that. Yes, let's move on.

24 MR. MILOSEVIC: [Interpretation]

25 Q. But you're naming here attorney Tomo Fila, which is working for

1 this institution here too. Was he Defence counsel for a member of the

2 Serbian Volunteer Guard and was in contact with you on that basis, or are

3 you saying that he financially assisted the Serbian Volunteer Guards?

4 A. He was one of the sponsors, the donors for the Serbian Volunteer

5 Guard. He may have -- not have provided money, but he could have assisted

6 in other ways.

7 Q. And what other ways could he assist the Guard?

8 A. With the help of his attorney's office.

9 Q. Which means he could act as Defence counsel.

10 A. Yes.

11 Q. But surely that's his job.

12 A. It is.

13 Q. So what's illegal there? What's wrong with that if an attorney is

14 doing his own work?

15 Regarding tab 4, you said, according to my notes -- but true, I

16 only received that tab in English, not in Serbian. You probably compiled

17 the list in Serbian, though, didn't you?

18 A. Yes.

19 Q. You said that you entered in the list members --

20 MR. NICE: Your Honour, the list is in Serbian. It's on the

21 right-hand side of the page.

22 MR. MILOSEVIC: [Interpretation]

23 Q. You said that on the basis of your recollection, I assume, you

24 entered members of the Serbian Volunteer Guard and the Red Berets; is that

25 right?

1 A. Yes.

2 Q. Now, explain a few names for me, please. For instance, Abdic

3 Fikret.

4 A. Yes.

5 Q. Do you consider him to have been a member of the Serb Volunteer

6 Guard or the Red Berets?

7 A. No.

8 Q. But you put him on the list as number 1. He certainly wasn't a

9 member of the Guards or the Berets, was he?

10 A. No.

11 Q. Giovanni Di Stefano, whom you mentioned as a sponsor, and

12 according to data available to me, he was a member of the Party of Serbian

13 Unity.

14 A. Yes.

15 Q. And a general of the Serbian Volunteer Guard. Did he fight in any

16 theatre of war?

17 A. He did not.

18 Q. So he was given this rank as some sort of an honorary title

19 because of his membership in the party and the reputation that he enjoyed

20 in business circles.

21 A. And because of the money he contributed.

22 Q. Yes, probably because of the money too. But he didn't fight

23 anywhere, did he?

24 A. No.

25 Q. Then you mention Ljuban Ecin. Was he a member of the Serbian

1 Volunteer Guard?

2 A. He was a person who was with the guards in the area of Banja Luka.

3 He was the leader of the Red Berets for Banja Luka.

4 Q. Doesn't it say here that he was head of the state security of

5 Republika Srpska in Banja Luka?

6 A. Yes, that's what he was.

7 Q. Therefore he's not a member of the Serbian Volunteer Guards or the

8 Red Berets but, rather, the head of the state security of Republika

9 Srpska. Is that right or not?

10 A. Yes, that's right.

11 Q. Then you put the Karics in the list. Were the Karics members of

12 the Serbian Volunteer Guards or the Red Berets?

13 A. That list was compiled to include all the persons that I mentioned

14 who in any way whatsoever had any contact with us. They were not just

15 members of the Serbian Volunteer Guards. I put on the list people who

16 came into contact with the Serbian Unity Party and the Serbian Volunteer

17 Guards in any way whatsoever. The Karic brothers even bought an ambulance

18 for the Serbian Volunteer Guards in the summer of 1995.

19 Q. That is something else. Wait a moment. It is well known that

20 they assisted medical institutions and probably purchased ambulances for

21 many and made contributions to hospitals on a non-discriminatory basis.

22 You are aware of that.

23 A. Yes. But I also know that they paid in money on the account for

24 the Delijes.

25 Q. For the purchase of an ambulance?

1 A. No. They bought an ambulance separately and gave it as a gift,

2 but they also invested money into the Delije cooperative.

3 Q. And what is that cooperative?

4 A. The Delije cooperative was one of the companies owned by the late

5 Zeljko Raznjatovic, Arkan.

6 Q. Was that some sort of a business relationship?

7 A. No.

8 Q. Well, if it's a company --

9 A. Yes. But the Delije cooperative didn't have any business with the

10 Karics.

11 Q. How can you know that when you weren't in that cooperative?

12 A. The Delije cooperative would bring us money and we would take

13 money to them. The money from the bakery and from the cake shop would be

14 carried to them and paid into their account. If they wanted to buy

15 something for us, they would frequently say that they didn't have the

16 money to do it. That firm was not working very well.

17 Q. You put Mihajl Kertes the list who was director of the customs

18 service for while. Was he a member of either of these?

19 A. No, he was not a member of Red Berets or the SDG. He would be the

20 person to call when a truck would be detained at the border crossing.

21 Q. Yes. But you explained yesterday that that truck, according to

22 the way in which you operated, just transited the territory of FRY from

23 one border to another and went on to Eastern Slavonia.

24 A. Yes. And then those same goods would come back to Belgrade.

25 Q. Well, what, then, has Kertes got to do with it if the sealed truck

1 crosses the border at both ends and is not importing goods to Yugoslavia,

2 what has he got to do with your smuggling when afterwards, in small

3 vehicles, you transport those goods to Slavonia?

4 A. Because if the truck was stopped, it would never wait. Usually

5 trucks had to wait for a long time. And once Milica [phoen] called up,

6 and she was the secretary of Kertes, and she would be called by Arkan, the

7 truck would be released.

8 Q. So he asked for some sort of intervention for the goods to be

9 allowed to pass on to Eastern Slavonia.

10 A. Yes. But for Eastern Slavonia, not Yugoslavia.

11 Q. Yes. But afterwards those goods ended up in Belgrade.

12 A. That's a matter of your smuggling and it has nothing to do with

13 the customs.

14 Q. You also mentioned Dusan Loncar. Was he a member of the Red

15 Berets or of the Serbian Volunteer Guards?

16 A. No.

17 Q. You have included Aleksandar Martinovic, who carried flour for

18 Arkan's bakery, and he was a driver in the headquarters. Was he a fighter

19 or a member of the Serbian Volunteer Guards, or was he working as a driver

20 carrying flour for the bakery?

21 A. The flour is important because that flour was taken from the Red

22 Cross and carried for Arkan's bakery.

23 Q. How could you get the flour from the Red Cross for the bakery when

24 that is a commercial establishment? A bakery is a commercial

25 establishment. How could you get flour from the Red Cross?

1 A. Because the Serbian Volunteer Guard could, on the basis of

2 something, I don't know what myself. Aleksandar Martinovic was a driver

3 in the headquarters of the SDG, and he would go to the Red Cross and he

4 would always say that he would have to wait until Frenki's men took what

5 they needed from the Red Cross, after which he would take flour and

6 cooking oil, which were essential for the bakery.

7 JUDGE MAY: Just a moment. Pause. Pause between question and

8 answer.

9 MR. MILOSEVIC: [Interpretation]

10 Q. All right. Matovic Tomo -- Mirko Tomo, as you say, a journalist

11 who wrote about the SDG, was he a member of any military unit or was he a

12 journalist who attended -- who followed the unit and informed the public,

13 wrote in the papers about it?

14 A. He was a journalist, and he worked for the Party of Serbian Unity.

15 Q. So he wasn't a fighter of any kind.

16 Ask then you speak about Jugoslav Micic, Juga, who was a driver at

17 the headquarters in Belgrade, and he died in Kladusa. He was one of the

18 two killed. Is that right?

19 A. Yes.

20 Q. All right. Do you allow for the fact that he might have perhaps

21 been killed because as a driver transporting something was hit by a shell

22 of some kind, or do you claim that he was involved in a military operation

23 of some kind?

24 A. I claim and know that Juga died in action, in combat.

25 Q. You're very sure about that. How come you know that?

1 [redacted]

2 [redacted]

3 Q. All right. But you are not somebody who was there in combat with

4 him so that you know that he was killed in action.

5 A. But when the body of a soldier arrives in Belgrade, questions are

6 asked about how he was killed at the front.

7 Q. All right. Now, do you know that it was precisely the leadership

8 of the Autonomous Province of Western Bosnia that they were hired out to

9 help as instructors, to help the army of the Autonomous Province of

10 Western Bosnia? Do you know that?

11 A. Yes.

12 Q. Well, do you, therefore, also know that the money which was sent

13 for those purposes, you say through the SDG, was the money that the

14 authorities of the Autonomous Province of Western Bosnia paid out for the

15 jobs that they were supposed to do; that is to say, the training for the

16 instructors and so on?

17 A. Yes. They received money from Fikret Abdic during the Velika

18 Kladusa event. But it didn't stop there with training. The members of

19 the guard were at the front. They fought for Fikret Abdic.

20 Q. All right. You also mention a female --

21 MR. NICE: Sorry to interrupt. [redacted]

22 [redacted]

23 [redacted]. A matter, of course, for the witness.

24 MR. MILOSEVIC: [Interpretation]

25 Q. You also mention a female here. Her name was Mirjana.

1 A. Not Mirjana but Marijana.

2 Q. All right, Marijana. And you say that she killed a prisoner in

3 Kladusa.

4 A. Yes.

5 Q. Was she a member of the Serb Volunteer Guard?

6 A. Yes.

7 Q. So you had female members too in the SDG, did you?

8 A. She was the only one, the only woman up at the front.

9 Q. How do you know that she killed a prisoner?

10 A. Because the wounded men talked about it.

11 Q. And you believe everything that people say?

12 JUDGE MAY: That's a comment.

13 MR. MILOSEVIC: [Interpretation]

14 Q. I asked you about Pelevic. Pelevic was a political figure. He is

15 still the president of the Serbian Unity Party, and he's still a deputy

16 today; right?

17 A. Yes.

18 Q. So he was in the political realm of the Party of Serbian Unity.

19 He wasn't a member of the SDG in a combat sense.

20 A. While I was there, it was as you put it, as you said, that's

21 right.

22 Q. All right. Fine.

23 Let me try and get through this as quickly as possible. I have

24 very little time.

25 Tell me, please, you spoke here at one point - and I'd like to ask

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1 you to remember, think back - that if something had to be transferred

2 across Vrace, they would do it by night, something to that effect. And in

3 fact, it was something being smuggled. Right?

4 A. The smuggling didn't refer to the transfer across the Vrace. I

5 was talking about some goods there, and I was referring to the period of

6 the Banja Luka operation and after that. So this crossing point Vrace

7 would be used. We would call up a certain number and our vehicle would be

8 able to cross at that point.

9 Q. All right. Now, you are aware of the fact that our authorities,

10 after the rejection of the Vance-Owen Plan at Republika Srpska in May

11 1993, introduced a blockade? Are you aware of that? Do you remember

12 that?

13 A. Yes.

14 Q. And do you also remember that the international monitors arrived

15 to monitor and supervise the blockade?

16 A. Yes.

17 Q. And do you know that that monitoring applied to Vrace and all the

18 border-crossing points?

19 A. Yes.

20 Q. Well, how then were they able, with those international monitors

21 in place, to transport all those goods and freight?

22 A. We were just asked that whenever we had something for a unit which

23 was located in Banja Luka, that all we had to do was to tell them at Vrace

24 and that the goods would be delivered to Banja Luka.

25 Q. All right. And is that all you know about the whole business?

1 A. How do you mean the only thing?

2 Q. Well, do you know that the international observers -- not

3 observers, but controllers, were in place at all those crossing points?

4 A. Yes, that's why we'd informed the DB when we were crossing. We

5 didn't, for example, call in for the crossing at Erdut.

6 Q. All right. Now, you also say that on two or three times a week

7 you would talk to Frenki's secretary; is that right?

8 A. Yes.

9 Q. And she would tell you that he would not be able to make a

10 decision without approval from Jovica Stanisic; right?

11 A. Yes. Yes, that's what she told me.

12 Q. Well, I'm not quite clear here. How is a secretary able to tell

13 another secretary and explain to another secretary what her boss can or

14 cannot decide? What's that got to do with your line of business, your

15 job? Who told you to say that?

16 A. I'm not sure I follow you. Could you be more specific?

17 Q. Well, your claim is fairly absurd, and that's why I'm asking you.

18 How is it possible, how come the secretary of a functionary in the state

19 security goes into explanations as to what her boss can or cannot decide?

20 Does that seem to you to be logical? I am putting it to you that you

21 thought all that up or otherwise somebody told you to say that.

22 A. That is not something I thought up myself. It's her statement,

23 her sentence, so I'm just conveying to you what she said. I didn't think

24 it up myself nor did anybody suggest that I say it. If it is not logical,

25 then it is up to her and not me. That's her affair.

1 Q. So you claim that she explained to you how her boss worked and who

2 he had to ask for permission, et cetera.

3 JUDGE MAY: [Previous interpretation continues] ...

4 THE ACCUSED: [Interpretation] All right. Very well.

5 JUDGE MAY: I said that's a comment.

6 Just a moment, please.

7 THE INTERPRETER: Microphone, please.

8 JUDGE MAY: Something is not right. Let's get it right.

9 The transcript should say, "That's a comment."

10 Now, let's go on.

11 THE ACCUSED: [Interpretation] I would be very grateful to you,

12 Mr. May, if you would correct the transcript when they record erroneously

13 what I myself am saying.

14 JUDGE MAY: You could always -- you could do it yourself,

15 Mr. Milosevic, if you're concerned.

16 MR. MILOSEVIC: [Interpretation]

17 Q. Witness 129, you said that Arkan would always go to see Frenki.

18 A. Yes.

19 Q. And you never saw Frenki come and see Arkan.

20 A. He only came once, and it was early in the morning in the parking

21 lot.

22 Q. Yes, I heard you say that yesterday. So you saw him in a parking

23 lot. You saw him coming in to his car or leaving his car.

24 A. He was standing in our parking lot when I came to work in the

25 morning. I asked the guard who the gentleman was, and he said that that

1 was a person looking for the commander.

2 Afterwards, I called the commander up, the commander came from

3 home with the 05, and they left then, and the commander later on told me

4 who the man was.

5 Q. You said that there were close ties with the DB. Did anyone from

6 the -- was anyone from the SDG a member of the DB?

7 A. Do you mean during the war operations?

8 Q. What I mean is throughout, throughout all the things and time you

9 know about. Or let me be more specific. Did any one of them have an ID

10 card affiliating him to the DB?

11 A. No.

12 Q. That's fine.

13 You also say that some sort of weaponry was transported. Mr. Nice

14 asked you something about that. And your answer was, "Just pistols and

15 uniforms." Is that right?

16 A. Yes.

17 Q. He also asked you whether in Belgrade they could use vehicles with

18 Vukovar license plates. Do you remember that question?

19 A. Yes, I do.

20 Q. Well, do you also remember that people would drive around with

21 number plates from all the former Yugoslav republics? You could see cars

22 on the streets of Belgrade with different license plates, from Skopje,

23 from Vukovar, from Zagreb, from Bijeljina, from Slovenia, and so on?

24 A. Yes.

25 Q. So there was nothing special in the use of Vukovar license plates.

1 This was nothing out of the ordinary; isn't that right?

2 A. Yes, right.

3 Q. Very well. Fine. He also asked you -- Mr. Nice also asked you

4 about money, the money that came in from the Velika Kladusa operation, or

5 rather, where they were paid. He said -- he asked you where Abdic got his

6 money from, and your answer was that you don't know. What do they have to

7 do with the source of Abdic's money? Did you ever establish a link?

8 A. What do you mean links with Fikret Abdic's money or funds? How do

9 you mean?

10 Q. The leadership of the Autonomous Province of Western Bosnia, the

11 authorities who engaged the instructors in the first place, and experts,

12 professionals, from the SDG. They paid for the services rendered; right?

13 A. Yes.

14 Q. So that was the money that reached you and which was used to pay

15 out the people who did the job.

16 A. The money reached me -- only money for the wounded. They would be

17 directly paid in the field, the fighters, the combatants.

18 Q. All right, in the field because they were there. And the wounded

19 men who were in Belgrade, they would get their salaries from over there

20 and you would distribute their salaries to them in Belgrade. That's

21 right, isn't it?

22 A. Yes.

23 Q. And that money belonged to the authorities of the Autonomous

24 Province of Western Bosnia. They were their funds. Is that right?

25 A. Yes.

1 Q. Right. Fine. Yesterday you commented on a photograph shown to

2 you by the opposite side as being a photograph from Bijeljina, and you

3 said that it wasn't Bijeljina but Brcko. That's right, isn't it?

4 A. Yes.

5 Q. And you said that you recognised Srdjan Golubovic, nicknamed Max;

6 right?

7 A. Yes. Yes, that's right.

8 Q. Is it true and correct that that man, Srdjan Golubovic, Max, had

9 nothing to do with the killing or any responsibility for the killing of

10 the person seen on the photograph?

11 A. Yes. And I said that too. That's what I stated, that to the best

12 of my knowledge he went up to the woman when the woman was already dead.

13 Q. So the photograph was made when they arrived and tried to identify

14 what had happened or to see whether it was a wounded person or somebody

15 who had already died; that is to say, that the killing had nothing to do

16 with the activities of the Serbian Volunteer Guard.

17 A. As far as that particular photograph was concerned, why they went

18 up there, I can only guess. All I know is that the man Max said that he

19 had a lot of problems because he approached that woman with a rifle in his

20 hands, trying to turn her over, turn her body over. That's what Max told

21 me.

22 Q. Well, he had problems because he was in the vicinity of a dead

23 person generally. And as far as I understand it, you have no information

24 or knowledge as to his accountability or that he was responsible or that

25 any of the members of the SDG was responsible for the death of that

1 particular individual. That's right, isn't it?

2 A. Yes, that's right.

3 Q. You never saw Radovan Stojicic, Badza, did you?

4 A. Personally, no.

5 Q. But you heard that he threw Arkan out of Erdut and that Arkan was

6 angry because of that.

7 A. Yes.

8 Q. Well, do you know that he helped introduce law and order when he

9 was invited to do so by the authorities of Srpska Krajina? In view of the

10 fact that he wielded a great deal of authority, he was the only one that

11 could have thrown them out of Erdut.

12 A. No.

13 Q. But you yesterday mentioned Radovan Stojicic and his links to some

14 kind of smuggling, as he was a very respected man and a patriot, do you

15 have any knowledge whatsoever that he in fact did engage in smuggling of

16 any kind?

17 JUDGE MAY: Wait a moment. Just wait a moment. The accused is

18 alleging that Stojicic was a respected man. Do you know if that's right?

19 THE WITNESS: [Interpretation] I don't know.

20 JUDGE MAY: No. That's your suggestion. All the evidence is that

21 he was involved in the smuggling.

22 Yes, let's move on.

23 THE ACCUSED: [Interpretation] No, Mr. May. I understood the

24 witness to say quite the opposite, that she has no information of him

25 participating in any kind of smuggling.

1 MR. MILOSEVIC: [Interpretation]

2 Q. Is that right, Witness 129?

3 A. You didn't allow me to complete what I was saying.

4 Q. Well, please go ahead, then.

5 A. According to the stories told by Arkan as to why he was angry, he

6 was angry because of the camp and he was also angry because the two of

7 them had, as he said, stopped the trading. And he was referring -- he

8 meant the smuggling. Because according to him, Badza wanted to keep the

9 bulk of it for himself, the bulk of the proceeds for himself.

10 Q. Just a minute, please. But in your statement you say that they

11 quarrelled and that their relations became tense. And I'm quoting exactly

12 what you said, "The police and the DB did not approve of it." They did

13 not approve of the smuggling, in other words.

14 A. I was referring to the period in 1995. That sentence refers to

15 that period, the sentence you quoted. It refers to 1995. But I'm telling

16 you now about my knowledge linked to Stojicic, Badza, and the comments or,

17 rather, what the late commander said about him.

18 Q. Very well. So you have no other knowledge about any involvement

19 of Radovan Stojicic in those dishonourable activities.

20 A. No.

21 Q. Very well. And when you say that their relations were not good,

22 did all that happen in 1993?

23 A. In 1993, 1994, and until the end of my work for the SDG, they did

24 not communicate, they were not on speaking terms.

25 Q. I see. Their relations were not good, but you're claiming that it

1 was under the sponsorship of the police that the Serbian Volunteer Guard

2 went to various battlefronts.

3 A. As far as I know, the late Stojicic was in the public security

4 service, and the Serbian Volunteer Guard had contact with Frenki, who was

5 working in the state security.

6 Q. Very well. And do you then assume that the public security and

7 the state security of the same Ministry of the Interior were engaged in

8 two contradictory activities?

9 A. Could you please more specific, please?

10 Q. It is -- you know that the Ministry of the Interior had two

11 departments; public security and state security.

12 A. Yes.

13 Q. Are you now claiming that the public security and the state

14 security services were doing -- working against one another, that is, they

15 were in dispute with the public security while cooperating with the state

16 security service? Can that be possible at all?

17 A. Yes, because I saw it.

18 Q. You saw Frenki having contact with Arkan. That's what you saw.

19 A. Yes, but he was not having any contact with Stojicic.

20 Q. And you are now saying that the late Arkan confided in you, who

21 was a student at the time and an administrative clerk doing a part-time

22 job, he confided in you about his relationships with the highest level

23 officials in the police; with whom he was on good terms and with whom he

24 was on bad terms. Were you so intimate with him?

25 A. Arkan was prone to commenting on his relationships in the office.

1 When I say "comment on his relationships with others," I mean with people

2 he was in contact with. So he would comment and recount these things.

3 These were not confidential, non-confidential things. Whoever happened to

4 be there could have heard it.

5 Q. So whoever was there, he explained to those people that Frenki had

6 asked him that the Serbian Volunteer Guard should assist them.

7 A. As far as I know, your previous question related to Stojicic. You

8 were speaking about high-level officials.

9 Q. Yes.

10 A. As for Frenki, when he said that, he said that to me and maybe to

11 three other people in the office. So he didn't comment on future

12 activities with everyone, but he would comment on things from the past.

13 Q. Very well. So you're talking about this Operation Pauk, or

14 Spider, and that Frenki called Arkan on the phone and to ask him for

15 assistance and then Arkan told you why this other one had called him. Is

16 that right?

17 A. He just said that Frenki had called him and that I need to call a

18 list of names that consisted of 40 people.

19 Q. Very well. Since you were obviously a person of the greatest

20 trust, tell me, under what terms did he agree on the engagement of his men

21 in Velika Kladusa, since money was coming from there, salaries, and so on?

22 So do you know on what terms he negotiated his involvement with the

23 authorities of Western Slavonia?

24 A. I don't know.

25 Q. But you do know that he made arrangements with them.

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1 A. Yes.

2 Q. Were you in Velika Kladusa?

3 A. No.

4 Q. You even say that Arkan didn't go there either.

5 A. Yes, he wasn't there either.

6 Q. So neither you nor Arkan was in Velika Kladusa.

7 A. No, we weren't there. We didn't go there.

8 Q. Very well. There's a contradiction which I'm unable to explain

9 without your assistance. You said that the authorities in Velika Kladusa

10 sent money via the DB, whereas on the other hand, that the fighters told

11 you that they saw an Abdic follower giving money to Legija and him

12 distributing it to members of the SDG.

13 A. Yes. But there's no contradiction there. Men who were on the

14 ground would receive money in such a way that Legija would go to see

15 Fikret and he would get money from him and distribute it to the members;

16 whereas, through the DB money would come which would be distributed to

17 fighters who were wounded in Velika Kladusa.

18 Q. I see. So that was your explanation. So he went to the

19 headquarters of the Autonomous Province of Western Bosnia; is that right?

20 A. Yes.

21 Q. And those headquarters of Western Bosnia, were they in command of

22 the operations in Velika Kladusa?

23 A. I can only assume so. I cannot claim that they were not. I

24 wasn't there.

25 Q. Can you please tell us the names of the members of the Serbian

1 Volunteer Guards who gave you that information so that we might call them

2 here too? If necessary, we can go into private session for you to do

3 that. Will you tell us the names of those people.

4 A. The first person is Milorad Lukovic, Legija.

5 Q. When did you see Milorad Lukovic Legija for the last time?

6 A. When did I see him for the last time? In 1999.

7 Q. And when did he tell you about that?

8 A. When he came to the headquarters during the Velika Kladusa

9 operation.

10 JUDGE MAY: The position is this: Apparently in the building, so

11 that everybody should know, there is to be a complete shutdown at 3.00.

12 Everybody is going to be asked to leave the building.

13 In order to give us sufficient time to do that, we will finish

14 today at no later than 2.45, which means that, if possible, a few minutes

15 before.

16 Mr. Milosevic, will you bring your cross-examination to a close at

17 or before half past.

18 Mr. Tapuskovic, you will have five minutes. There will be no

19 re-examination. I will give this ruling, which I have been meaning to

20 give for several days and we will then adjourn.

21 Yes.

22 THE ACCUSED: [Interpretation] Very well, Mr. May. I obviously

23 will not have the time I should, but that is not the first time.

24 JUDGE MAY: You will have very nearly the same as the Prosecution.

25 On one occasion - this will be, as far as I can see, the first one in the

1 trial - you will have five minutes less than them.

2 Yes. Let us go on.

3 THE ACCUSED: [Interpretation] Very well.

4 MR. MILOSEVIC: [Interpretation]

5 Q. Everything about this, as to whether Frenki went to Velika Kladusa

6 or not and when, you know from his secretary; is that right?

7 A. Yes, from the secretary and from the wounded who were in Velika

8 Kladusa, people who were in Kladusa and were wounded and then came to the

9 headquarters of the SDG.

10 Q. Very well. And who were the Tigers that you mentioned who told

11 you that they went first to the centre at Tara, Mount Tara?

12 A. You want their names?

13 Q. Yes.

14 A. Nebojsa Djordjevic, Suca, Vlasdenovic [phoen], known as Gvozdeni,

15 Slavica Stavanovac [phoen], known as Zenica [phoen], Zarko Aleksic

16 [phoen], known as Marinac [phoen]. Those were some of the men from the

17 first group.

18 Q. Very well. Since you know all that, tell me, how many men were

19 trained at the centre on Mount Tara from among your members of the SDG?

20 A. They were there very briefly, and that is what I said in my

21 statement. They were there not longer than seven days. And I'm talking

22 about the first group. I don't know about the second group. They were

23 there for seven days. And after that, they were transferred to Velika

24 Kladusa.

25 Q. And tell me, what kind of training is that that lasts seven days?

1 Do you have any idea about that?

2 A. I don't know what they were doing over there, so I don't know at

3 all whether it was any kind of training. When they left, they spent a

4 week at the camp in Tara. Now, whether that was training or waiting, I

5 don't know.

6 Q. Maybe it could have been a rest, a vacation.

7 A. I don't believe it was a vacation.

8 Q. What else would they be doing on Mount Tara? Were they untrained

9 for war operations, those men that you just mentioned? Were they men who

10 needed training?

11 A. No.

12 Q. But do you have any idea what they were doing at Tara?

13 A. No.

14 Q. Well, why are you testifying about that, then?

15 JUDGE MAY: Yes. Let's move on. That's a pointless comment.

16 MR. MILOSEVIC: [Interpretation]

17 Q. Very well. In your statement of the 9th and 10th of November,

18 2002, on page 4, third paragraph, you say that I and Jovica Stanisic were

19 close. Who told you that? Was it Jovica Stanisic who told you that?

20 A. No, no one told me that.

21 Q. Well, how do you make that inference?

22 A. On the -- it is normal for the chief of the state security to be

23 accountable to the president of the Republic of Serbia.

24 Q. So you are drawing a conclusion on the basis of the positions

25 people held and not because you had any knowledge about our closeness.

1 A. That was just a statement. I have no knowledge about you or about

2 Mr. Stanisic. All I said was that, according to our law, it is normal and

3 logical for the chief of the state security to be accountable to the

4 president of the state.

5 Q. That's very fine. I'm just -- I just wanted to know on what

6 grounds you make that assertion. If you base it on the law, that's fine,

7 we can move on.

8 A. No, no. Only on the basis of the laws.

9 Q. You say that Mihajlo Ulemek granted an interview to the Belgrade

10 Journal Interview, after which Frenki called up Arkan and asked, "What is

11 that fool of yours doing?" Were you listening in to that conversation?

12 A. No, I wasn't. But the late commander told me furiously, "Call him

13 because this Frenki has gone crazy and he granted an interview to the

14 Journal interview," and he told me to send somebody to buy a copy of that

15 journal so that he could see what he said.

16 Q. I see. So he again gave you some explanations. But in your

17 statement of the 8th and 9th of July, 2002, in the last paragraph on the

18 last page, you say you were not familiar with the way looted goods were

19 divided up.

20 A. You mean on the ground, the looted goods on the ground?

21 Q. I don't know. I'm just asking you this because you said that

22 there was no looting, which I believe. Therefore, is it true that the

23 investigator asked you about how the looted goods were shared out?

24 A. They did, and I said that there were no looted goods that I saw,

25 nor did I hear about it, nor did anyone bring any such goods.

1 Q. That's very good, Witness 129. So the investigator asked you to

2 explain how looted goods were shared, which means that somebody looted the

3 goods.

4 A. They asked me whether anybody did any looting and whether I saw

5 anything, and I said that I hadn't seen or heard or seen any goods.

6 Q. I see. So they suggested to you that they had been involved in

7 looting.

8 A. They didn't suggest anything. They just asked me a question about

9 it, as they did regarding everything else. There were no suggestions by

10 the Prosecutor.

11 Q. So you don't think it's a leading question if I ask you how did

12 you share the looted goods? Surely that implies that you did some

13 looting.

14 A. I wouldn't call it a suggestion; I would call it lack of knowledge

15 or misinformation.

16 Q. Would you agree with me that the task of the military police

17 formed by the Guards was to prevent stealing, looting, and disorder?

18 A. Yes.

19 Q. And did you explain that to them?

20 A. Yes, I did.

21 Q. So I think that you owe this to your dead commander so that his

22 name shouldn't be slandered and that things should not be attributed to

23 him that he didn't do.

24 A. I don't owe him anything.

25 Q. Since you know everything about the SDG, tell me, what was the

1 relationship between Arkan and his men, if they committed any kind of

2 offence, stealing, or any kind of offence?

3 A. You mean towards the officers or generally?

4 Q. Both.

5 A. The punishment was severe, between 50 and 100 lashes on the

6 backside.

7 JUDGE MAY: Mr. Milosevic, it's -- it's now almost 2.29. I will

8 allow you one more question.

9 We now discover that we have to leave the building altogether at

10 3.00. The building is going to close until Tuesday morning. Therefore,

11 in order for everyone to have enough time to get out...

12 Mr. Tapuskovic, I'm afraid we'll have to forego your

13 cross-examination.

14 Mr. Milosevic, one more question, if you want.

15 MR. MILOSEVIC: [Interpretation]

16 Q. Very well. If it's just one question: Witness, you explained

17 that every document which was kept in the premises -- You're not hearing

18 me?

19 A. No, could you repeat the question? I didn't hear the beginning.

20 Q. You explained that every document, every written piece of paper

21 which was kept in the premises of the SDG or in the Serbian Unity Party,

22 was destroyed every evening.

23 A. Yes, or the next day.

24 Q. Or the next day. I see. Tell me, please, how is it then that

25 your entire diary was never destroyed? Or maybe no one considered this to

1 be a serious document?

2 A. They knew of my notebook. But when I left, no one asked me to

3 leave it there. I took it with me. It was my personal agenda in which I

4 kept my notes.

5 Q. I see. Your personal agenda.

6 JUDGE MAY: There we are. We've got the answer, and we cannot go

7 on.

8 It is now 2.30, I note.

9 I'm sorry, Mr. Tapuskovic, that we can't allow your

10 cross-examination, and no re-examination either.

11 MR. TAPUSKOVIC: [Interpretation] I can be very brief.

12 JUDGE MAY: No.

13 MR. TAPUSKOVIC: [Interpretation] I think it would be useful.

14 JUDGE MAY: I'm sure it would be, but circumstances are against

15 us. In particular, it's necessary to get the accused out of the building.

16 MR. TAPUSKOVIC: [Interpretation] Several things were omitted which

17 are very important for you, Your Honours, for the Judges.

18 JUDGE MAY: Well, you can put it into writing, if you want.

19 Yes.

20 MR. NICE: Witnesses for Monday week, in light of administrative

21 problems, slightly changed. Can I just give the list so that the accused

22 can prepare over the weekend?

23 JUDGE MAY: Yes.

24 MR. NICE: B-14 -- if he'd like to write it down, because there's

25 no way he's going to get a written version today, there's no procedures, I

1 think. B-1489, followed by C-48, followed by B-108, followed by Patrick

2 Ball, followed by Dzevad Guzic, followed by {redacted}.

3 JUDGE MAY: Very well. That will be Monday week. But we'll begin

4 with administrative matters, to deal merely with the witnesses.

5 And let me give this ruling so that the parties -- now, I won't

6 give it in any detail. It follows from our earlier rulings, and the same

7 principles apply. It deals with these witnesses: C-1072, 1073, 1102,

8 1160, 1166, 1186, 1192, 1202, 1205. These witnesses will all be admitted

9 Rule 92 bis, although four of them were identified as part live by the

10 Prosecution. Their statements will all be admitted. All must be

11 available for cross-examination for the reasons which we've set out in our

12 earlier reasons.

13 THE ACCUSED: [Interpretation] Mr. May.

14 JUDGE MAY: Mr. Milosevic, time is against us. Now, what is it?

15 THE ACCUSED: [Interpretation] I'll just take up ten seconds.

16 On the transcript there's a number that's not complete. I'd like

17 to just check out the order of witnesses, whether I've got it noted down

18 correctly by listening to it. B-1489 is the first one; is that right?

19 MR. NICE: Yes.

20 THE ACCUSED: [Interpretation] And then 14 -- C-48, B-108, Patrick

21 Ball, Dzevad Guzic, [redacted]; right?

22 MR. NICE: Correct.

23 THE ACCUSED: [Interpretation] Thank you.

24 JUDGE MAY: Witness B-129, we shouldn't forget to thank you for

25 coming to the Tribunal to give your evidence. It is concluded, and

1 you're free to go.

2 [The witness withdrew]

3 --- Whereupon the hearing adjourned

4 at 2.34 p.m., to be reconvened on Monday,

5 the 28th day of April, 2003, at 9.00 a.m.

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