Tribunal Criminal Tribunal for the Former Yugoslavia

Page 574

 1                           Tuesday, 30 October 2012

 2                           [Open session]

 3                           [The accused entered court]

 4                           --- Upon commencing at 1.30 p.m.

 5             JUDGE DELVOIE:  Good afternoon to everyone in and around the

 6     courtroom.  Mr. Registrar, would you please call the case.

 7             THE REGISTRAR:  Good afternoon, Your Honours.  This is case

 8     number IT-04-75-T, the Prosecutor versus Goran Hadzic.  Thank you.

 9             JUDGE DELVOIE:  Thank you.  May we have the appearances, please,

10     starting with the Prosecution.

11             MR. STRINGER:  Good afternoon, Mr. President and Your Honours.

12     Douglas Stringer appearing with my colleague Alexis Demirdjian; intern,

13     Antonio Garza; and Case Manager, Thomas Laugel.

14             JUDGE DELVOIE:  Thank you.  For the Defence, please.

15             MR. ZIVANOVIC:  Good afternoon, Your Honours.  For the Defence of

16     Goran Hadzic, Zoran Zivanovic and Christopher Gosnell.  Thank you.

17             JUDGE DELVOIE:  Thank you.  If there is nothing else.  Yes,

18     Mr. Demirdjian.

19             MR. DEMIRDJIAN:  Good morning, Your Honours.

20             JUDGE DELVOIE:  Good afternoon to you, too.

21             MR. DEMIRDJIAN:  That is good afternoon indeed.  It is good to

22     see some familiar faces in the courtroom.

23             Before we bring in the next witness, Mr. Savic, I'd just like to

24     raise a preliminary matter.  When the Trial Chamber ruled upon the

25     Rule 92 ter motion in relation to Mr. Savic, if you will remember, there

Page 575

 1     were a number of associated exhibits, two of which at the time were not

 2     yet on the Rule 65 ter list of exhibits.  Those two exhibits were added

 3     in our -- well, we proposed them in our second motion, and you ruled on

 4     the 19th of October in your decision that these documents were admitted

 5     on the Rule 65 ter list.  Just for the record, these are 65 ter 5866, and

 6     5867.

 7             So just for the sake of completeness, I just wanted to put that

 8     on the record, that when we will be tendering these associated exhibits,

 9     these two will be tendered, and they are now according to your ruling on

10     the Rule 65 ter list.

11             JUDGE DELVOIE:  Thank you.

12             MR. DEMIRDJIAN:  And that is all.

13             JUDGE DELVOIE:  Thank you.  Could the witness be escorted in,

14     please.

15                           [The witness entered court]

16             JUDGE DELVOIE:  Good afternoon, Mr. Witness.  Thank you --

17             THE WITNESS: [Interpretation] Good afternoon.

18             JUDGE DELVOIE:  Thank you for coming to The Hague to assist the

19     Tribunal.  First of all, do you hear me in a language you understand?

20             THE WITNESS: [Interpretation] I do, yes.

21             JUDGE DELVOIE:  Please tell us your name, your date of birth, and

22     your ethnicity, please.

23             THE WITNESS: [Interpretation] Borivoje Savic,

24     2nd of February, 1949.  I'm a Serb.

25             JUDGE DELVOIE:  Thank you.  You are about to read the solemn

Page 576

 1     declaration by which witnesses commit themselves to tell the truth.  I

 2     need to point out that the solemn declaration that you are about to make

 3     does expose you to the penalties of perjury should you give misleading or

 4     untruthful evidence to this Tribunal.  Would you now read the solemn

 5     declaration, please.

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

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

 8                           THE WITNESS:  BORIVOJE SAVIC

 9                           [Witness answered through interpreter]

10             JUDGE DELVOIE:  Thank you very much.  You may sit down.

11             THE WITNESS:  Thank you.

12             JUDGE DELVOIE:  Mr. Demirdjian, your witness.

13             MR. DEMIRDJIAN:  Thank you, Your Honours.

14                           Examination by Mr. Demirdjian:

15        Q.   Good afternoon, Mr. Savic.

16        A.   Good afternoon.

17        Q.   Mr. Savic, it is correct to say that you have given statements to

18     the Office of the Prosecutor in 2002 and 2003?

19        A.   Yes, correct.

20        Q.   You testified in the case against Stanisic and Simatovic in the

21     year 2009?

22        A.   Yes.

23        Q.   During the course of this summer, in July and August, you met

24     with members of the Office of the Prosecutor?

25        A.   That is correct, yes.

Page 577

 1        Q.   And as a result of these meetings, a new statement was prepared

 2     for the purposes of this trial.

 3        A.   Yes.

 4             MR. DEMIRDJIAN:  At this time could I ask for 65 ter 05868 to be

 5     displayed on the screen.  That is tab 71, Your Honours.

 6        Q.   Mr. Savic, do you recognise the cover page of this document?

 7        A.   I do, yes.

 8             MR. DEMIRDJIAN:  And can we scroll to the bottom of this

 9     statement in the B/C/S version, all the way down.  Very well.

10        Q.   And at the bottom left corner, is that your signature?

11        A.   It is, yes.

12             MR. DEMIRDJIAN:  And could we go to page 2, please, in the B/C/S

13     version.

14        Q.   Now, on this second page and every other following page, I

15     believe that your signature appears also at the bottom; is that right?

16        A.   Yes.

17        Q.   Thank you.

18             MR. DEMIRDJIAN:  And can we go to the last page, please.

19        Q.   At the top of the last page, Mr. Savic, do we also see your

20     signature under the Witness Acknowledgement?

21        A.   Yes.

22        Q.   Now, before signing this statement, were you given an opportunity

23     to read this statement?

24        A.   I was, yes.

25        Q.   And before signing this statement, were you given an opportunity

Page 578

 1     to make amendments to the statement?

 2        A.   Yes, we did make some changes.  Minor ones, names and just some

 3     details.

 4        Q.   Very well.  And when you arrived in The Hague yesterday, were you

 5     given a copy of this statement to read once more?

 6        A.   I did get it, yes, and I did read it again.

 7        Q.   Thank you very much.  Now, with regards to the answers recorded

 8     in your statement, would you give the same answers in the courtroom

 9     should you be asked the same questions?

10        A.   I would, yes.

11             MR. DEMIRDJIAN:  Your Honours, at this time may I ask to tender

12     65 ter 05868, which is the statement, the 92 ter statement of Mr. Savic,

13     as well as the associated exhibits.

14             JUDGE DELVOIE:  Admitted and marked.

15             THE REGISTRAR:  It should be assigned Exhibit P50.  Thank you.

16             MR. DEMIRDJIAN:  And I assume that the associated exhibits will

17     receive their numbers in due course.

18                           [Trial Chamber and registrar confer]

19             JUDGE DELVOIE:  The memo will be circulated later on.

20             MR. DEMIRDJIAN:  Thank you.

21        Q.   Mr. Savic, in addition to your statement, I have some additional

22     questions in relation to topics that are in your statement.  Now, as I

23     explained to you before, you can assume that the parties and the Judges

24     have read your statement.  Therefore, when I ask you additional

25     questions, you don't need to give us the entire context, but you can

Page 579

 1     restrict yourself to the specific question.

 2             Now, in your --

 3             JUDGE DELVOIE:  Mr. Demirdjian.

 4             MR. DEMIRDJIAN:  Yes.

 5             JUDGE DELVOIE:  Yes, Mr. Witness -- Mr. Savic.

 6             THE WITNESS: [Interpretation] I would just like to hear it a

 7     little better.  Can I have it a little bit louder, the sound.  [In

 8     English] Okay.  Okay.  [Interpretation] Thank you.

 9             MR. DEMIRDJIAN:

10        Q.   Now, Mr. Savic, in the initial part of your statement you talk

11     about the creation of the SDS and your relationship with members of the

12     party.  I would like to show you a document which is 65 ter 2887 at

13     tab 52.  Can you see the document on the screen, on the left side of the

14     screen?

15        A.   Yes.

16        Q.   Do you -- do you recognise this document?

17        A.   I do.  It's a list of the boards, board members, and it's

18     something that I drafted for my own records.  These were the boards that

19     we were establishing at the local level.

20        Q.   Now, when you say the local level, which region specifically

21     would that be?

22        A.   The local board would be a local commune or a village around

23     Vukovar.  For example, we have Vera.  This is a village in the area of

24     Vukovar, and we see the president, secretary, treasurer.  Then we have

25     Sotin, which is the next locality.  These are all locations around

Page 580

 1     Vukovar or it could be a local commune if we're talking about the town.

 2        Q.   Okay.  Now, you told us that these were established at the local

 3     level.  When was the document itself prepared?

 4        A.   This is from 1990-1991, as the boards were being established in

 5     order to have some sort of record and to know where the board members

 6     were.  I drafted this shortly after the boards were established in order

 7     to have a record of the membership and also for purposes of

 8     documentation.

 9        Q.   Okay.  Now, on page 1 at the right side of the B/C/S and English

10     versions, we see, for example, the local commune of Negoslavci.

11             MR. DEMIRDJIAN:  In English we need to droll down a little bit,

12     please.  Thank you very much.

13        Q.   Now, we see the name of the president here.  Are you familiar

14     with this person?

15        A.   Boro Bogunovic was the president.  The first president,

16     incidentally, was Nebojsa Uvalic.  However, after an intervention of some

17     kind, Boro Bogunovic was appointed in his stead, who actually in my

18     opinion was already a police insider.  Then they said that they intended

19     for Boro to be put there because he was better there, and then we just

20     said, Well, you can appoint whoever you like.  Do whatever you want.

21        Q.   Very well.

22             MR. DEMIRDJIAN:  Can we go to the next page in the English

23     version -- in the B/C/S version, page 2.  And in the English version,

24     that is page 3.

25        Q.   Now, in the B/C/S version on -- I believe it is on the top

Page 581

 1     right-hand corner, we see the membership of the Vukovar local commune?

 2        A.   Yes.

 3        Q.   And is that your name there?

 4        A.   Yes.  The seventh in line is me.

 5        Q.   And below that we see the village of Pacetin, and this is

 6     where -- this is Goran Hadzic's village.  Could you tell us, if we scroll

 7     down a little bit in the B/C/S version, please.  And in the English

 8     version we need to move to the right a little bit.  Very well.

 9             First of all, are you familiar with the second name,

10     Miomir Crnogorac?

11        A.   I am, yes.  Miomir Crnogorac was from Pacetin.  He lived there,

12     and he was a member of the Pacetin board.

13        Q.   And did Mr. Crnogorac later on occupy any functions in the SBWS

14     government?

15        A.   He was from Western Srem.  I think that he was a minister of

16     energy or commerce, more or less that.  I don't know if it was commerce

17     or energy.  I don't know which ministry, but he was in the board -- in

18     the government.

19        Q.   And still under Pacetin, we see two persons bearing the last name

20     Hadzic.  Are these related to Mr. Goran Hadzic?

21        A.   There are a number of Hadzic families in Pacetin.  Goranka Hadzic

22     is Goran's sister.  Slobodan Hadzic, I think they just have the same last

23     name, but they're not related.  So it's only Goranka, and she was Goran's

24     sister.

25        Q.   Very well.  And just to clarify matters here, Goran Hadzic

Page 582

 1     himself does not appear on this list?

 2        A.   Goran Hadzic was the president of the Municipal Board, so there

 3     was no need for him to be a member of the board in Pacetin.  It's a

 4     different case with me.  In Vukovar, people simply did not dare join in,

 5     get involved in the party work, so in my local commune, in order to fill

 6     in the required numbers, I was a member of the board.  There's only that

 7     difference, excuse me.  In the villages the situation was quite

 8     different.  People were more free, and it was more simple to establish

 9     the boards.

10             MR. DEMIRDJIAN:  Your Honours, may I ask for this document to be

11     admitted.

12             JUDGE DELVOIE:  Admitted and marked.

13             THE REGISTRAR:  Your Honours, 65 ter document 2887 shall be

14     assigned Exhibit P51.  Thank you.

15             MR. DEMIRDJIAN:  Thank you.

16        Q.   Now, in relation to Goran Hadzic himself, in your statement at

17     paragraph 22, you explain that you knew him through his father and that

18     your wife was a teacher in the village of Pacetin.  Could you tell the

19     Trial Chamber how long have you known Goran Hadzic?

20        A.   Since his high school days.  I think that in that period he was a

21     pupil in the Vinkovci gymnasium.  So maybe he was 17 or 18 years old.  So

22     that's since when I've known him.

23        Q.   And how would you describe the relationship between your

24     families?

25        A.   It was good.  We respected one another.  We got on well together.

Page 583

 1     Our relations were quite normal.

 2        Q.   Before getting involved in politics in the early 1990s, was

 3     Goran Hadzic involved in any organisation?

 4        A.   He was a member of the League of Communists of Yugoslavia, and he

 5     was elected in the 1991 elections for a deputy -- as a deputy of the

 6     Vukovar Municipal Assembly.

 7        Q.   Okay.  And in 1990 when he joined the SDS party, could you tell

 8     the Court what was the level of his education?

 9        A.   He had graduated from the high school in Vinkovci.

10        Q.   And to your knowledge did he obtain any other degrees later on?

11        A.   I really don't know.

12        Q.   That's fine.  Now, at paragraph 62 of this statement, you start

13     describing the events that happened at the Plitvice Lake on the

14     31st of March, 1991, and that you were detained for about three days

15     during this arrest, which also involved Mr. Hadzic.  Now, you discuss at

16     paragraph 70 of your statement how your ties with Mr. Hadzic were broken

17     after the Plitvice incident and that he came under the influence of

18     Milosevic following these events.  I would like to show you a video, and

19     this is 65 ter 4 -- sorry, 4809.  It is listed at tab 57.

20             MR. DEMIRDJIAN:  And for the interpreters the video bears the

21     ERN V000-1388.  Now, Your Honours, this clip lasts seven or eight minutes

22     and we'll see how long we need it.  Okay it's 65 ter 4809.3.

23                           [Video-clip played]

24             MR. DEMIRDJIAN:

25        Q.   Now, first of all, Mr. Savic, do you recognise the speaker?

Page 584

 1        A.   Yes.  That is Goran Hadzic.

 2                           [Video-clip played]

 3             THE INTERPRETER:  "[Voiceover] As a president of the

 4     Municipal Board which you belong to, it is my duty to say something about

 5     our Vukovar Municipal Board even though there are many topics we are

 6     going to discuss later on.  Our party was established on 10th of June

 7     last year in Vukovar and 19 boards had been established since then.

 8     Today the party has 21 boards and I congratulate you on establishing your

 9     two local boards.  We have faced many problems in our party.  You are

10     familiar with them and you know who caused them.  However, we managed to

11     get over them and we should thank our current leadership for uniting us

12     and helping us achieve unity.  We are stronger and united now.  As a

13     people we have never looked to God, not left to right.  We always knew

14     that we were stronger together and we have relied on that.  That's why we

15     always sang that song 'We are stronger together.'  I would like to tell

16     you now something about the programme that we discussed at the beginning.

17     As you know, at our rallies our main goal was united Yugoslavia, united

18     Yugoslav People's Army.  These are our goals even today.  We have

19     remained on the path of St. Sava, and I wish you all the best for this

20     holiday today."

21             MR. DEMIRDJIAN:  Just pause here for a second.

22        Q.   Now, Mr. Savic, first of all, we heard Goran Hadzic say here that

23     local boards were created in -- last year.  So which date would you say

24     this video was recorded roughly?

25        A.   January 1971.  This was St. Sava's day, and when I look at it

Page 585

 1     more carefully, I think that this is Borovo Naselje settlement and the

 2     forming of the board, and I can see that he's talking about two boards in

 3     the same day.  We would establish two or three boards in the same day

 4     depending on the preparations.  Then we would implement that immediately.

 5     I think that this is Borovo Naselje.

 6        Q.   I think there may be a little error in the transcript at page 11,

 7     line 25.  It reads January 1971.  Is that what you said, Mr. Savic?

 8        A.   Yes, January 1971.  This is what I said.  If we're talking about

 9     a year.  Since the establishment, then that would be that.

10        Q.   Sorry, it's the 1971 that I'm having a hard time with.  Is that

11     the right year?

12        A.   Well, now I'm confused.  If it was St. Sava's day, then it was

13     January.  Then it must be 1971, 1971.  1991.

14        Q.   Very well.  Thank you for clarifying that, because --

15        A.   Yes.  Yes.

16        Q.   Very well.  Let's carry on here.  So you said it's

17     Borovo Naselje, January 1991.

18                           [Video-clip played]

19             THE INTERPRETER:  "[Voiceover] As our great Serbian academician,

20     Matija Beckovic, would say, 'St. Sava walked the path and everyone barked

21     at him, but let's not forget that.  Let's follow his road.'  It is not

22     the time to talk about the organisation of the party and its work right

23     now.  I would rather say a few words about our current problems, because

24     I think that it is not the time for big speeches.  We Serbs from Croatia

25     are free-thinking democrats by conviction.  We even had radicals before

Page 586

 1     the war here, but where are we now?  We found ourselves in a situation

 2     where we have to split into two parties due to the politics of one

 3     nation, to divide into Serbs and Croats.  For us as people, it comes as a

 4     shock.  We're not nationalists.  Our views are broader, and we have to

 5     accept this as a fact and organise ourselves.  I believe and I'm sure

 6     that everyone who watched TV two nights ago felt the same as me.  This is

 7     what I think.  Not even 80.000 Serbs could we manage to find in the world

 8     and persuade them to talk badly about other people.  And others have

 9     80.000 machine-guns in their possession ..."

10             MR. DEMIRDJIAN:  Just stop.

11        Q.   Sorry.  I'm stopping the video here for a second.  What do we see

12     here on this image?

13        A.   There is this image and underneath the image we can see the

14     writing St. Sava.

15             MR. DEMIRDJIAN:  Thank you.

16                           [Video-clip played]

17             THE INTERPRETER:  "[Voiceover] 80.000 machine-guns in their

18     possession and they keep them so they could use them against us.  It's

19     ridiculous.  1941 happened and 1941 happened -- 1945 happened too.  Then

20     in 1971, we thought we would forgive them.  It would never happen again.

21     But I'm telling you now ..."

22             MR. DEMIRDJIAN:

23        Q.   Sir, did you recognise some of the people we showed so far, under

24     the flag at the desk?

25        A.   I recognise Mile Vukas, who was from the local commune in Borovo.

Page 587

 1     A member of the board there.  I recognise some of the faces, and to my

 2     great surprise I can actually recognise myself too.

 3        Q.   Are you on this -- on this still?

 4        A.   Yes.  That's me in the middle.  But I don't remember any details.

 5     There's nothing really specific that I can say apart from what we have

 6     seen and heard.  This is the session at which the board was established.

 7     Judging by the clothes I'm wearing, I had just arrived.  I had been

 8     underway somewhere or I was about to travel somewhere.  You see that most

 9     people are wearing their everyday clothes unlike me, but it's very

10     difficult for me to think back and recall the exact details where I'd

11     been off to, where I'd just arrived from, or indeed where I would soon

12     go.

13             MR. DEMIRDJIAN:  Okay.  Play the rest of the video here.

14                           [Video-clip played]

15             THE INTERPRETER:  "[Voiceover] If the Croatian people do not

16     publicly renounce on their Ustasha policy, we will propose through our

17     Serbian National Council that we cut all ties between Serbs and Croats.

18     A perfidious policy pursued since the 1850s, since the time of

19     Ante Starcevic has now reached its final stage but they were not that

20     perfidious.  They let -- had they pursued their perfidious policy for

21     another couple years, the Serb people would not have managed to unite.

22     They can do nothing to us now.  In the work of our party at a regional

23     level, republican federal level, we face problems.  Let me tell you why:

24     Because we are democrats.  We have not thought about things they had said

25     and we thought whether or not they really meant it.  However, I thank

Page 588

 1     them for that.  We are united and there will be no division within the

 2     party.  We understood that people should talk to each other, but there is

 3     no dialogue with people who are not people with inhuman people.  I would

 4     not discuss this anymore.  I would like to invite you to join the

 5     Serbian Democratic Party instead.  You don't have to become members of

 6     the party, but you have to follow its policies and participate in its

 7     activities."

 8             MR. DEMIRDJIAN:

 9        Q.   Mr. Savic, we just heard a moment ago Goran Hadzic saying that:

10             "If the Croatian people do not renounce their Ustasha, we will

11     propose through our Serbian National Council to cut all ties between

12     Serbs and Croats."

13             Now, in your statement at paragraph 132 and 133, you described

14     the use of the word "Ustasha."  Was it usual for Mr. Hadzic to use this

15     terminology?

16        A.   Every now and then.  Nevertheless, may I explain.  These are

17     activities that were triggered by the daily goings-on in terms of

18     politics.  When people spoke publicly, they spoke based on what they'd

19     seen on TV, what they'd read in the papers, and so on and so forth.  One

20     had to take every opportunity to garner applause, to be publicly

21     acclaimed.  So it was a perfectly normal type of register to use when

22     addressing an audience depending on the audience, the people who were

23     actually there.  So, yes, one tended to use that kind of expression at

24     the time.  It was very difficult to convince people.  When you spoke

25     about the Ustasha, you actually were helping the Croatian side.  The

Page 589

 1     Croats had their own platform.  They were pursuing that platform.  They

 2     were telling us openly what they would do, and we needed our own

 3     platform, too, instead of following the Croats or indeed anyone else.

 4             I myself opposed these unnecessary acrobatics and making daily

 5     political references like this during these speeches.  I tried to exert

 6     my influence to keep people from using such expressions.

 7        Q.   And why would you try to influence people to keep from using such

 8     terminology?

 9        A.   You see, if you think about the idea behind the establishment of

10     the board and the Serbian Democratic Party in this area, the idea was

11     mine and mine alone.  I tried to talk to the people in Vukovar, the whole

12     town.  I must have talked to about 300, 400 people.  I informed them all

13     about what it was that it would be doing and that we were aiming to get

14     the party off the ground, but not a single time did I ever use the word

15     "Serb" during my contacts with these people.  But each and every one of

16     them told me invariably, You know I'm a Serb.  As soon as someone told me

17     that, You know I'm a Serb, what that meant to me is that there was

18     nothing more for me to expect from that particular person.  I should

19     meddle no more.  I'll just try to help as much as I can.  So it was all

20     moving in that general direction.  And then we started canvassing the

21     villages around the town itself where the atmosphere prevailing there was

22     very different and people were acting a different way.  They were somehow

23     freer, and we in turn were freer to do our work.

24        Q.   I would like to -- we can remove this clip now.  I would like to

25     show some of the stills so we could help us identify some of the people

Page 590

 1     on the video.

 2             MR. DEMIRDJIAN:  Could we have on the screen 65 ter 4809.4.

 3             JUDGE MINDUA: [Interpretation] Before going to another topic,

 4     sorry.

 5             Mr. Savic, I would like to go back to the Ustasha terminology.

 6     If I understood you correctly, and please tell me if I did, the word

 7     "Ustasha" coming from Goran Hadzic is a pejorative term for Croats;

 8     right?

 9             THE WITNESS: [Interpretation] Yes, that's right.

10             JUDGE MINDUA: [Interpretation] Thank you very much.  And I won't

11     ask a second question, because I was going to ask you if at that time

12     Croats themselves would call themselves Ustasha.  Where there were Croats

13     that would call themselves Ustasha?

14             THE WITNESS: [Interpretation] No.  The Croats were not referring

15     to themselves as Ustasha, but I believe you've heard a lot already about

16     the Ustasha and about the Chetniks.  These were two very backward

17     movements among the Serbs and among the Croats respectively.  During the

18     Ustasha time, half of Croatia was under Italy.  The Chetnik movement in

19     Serbia split the nation up into two halves.  You had the Partisans on the

20     one hand and the Chetniks on the other.  And what this led to was a

21     fratricidal war.  So these are two backward movements politically and

22     ideologically speaking.  So the ideologues behind these movements were

23     Communists.  That's what it means.  They were particularly skilful at

24     manipulating these Ustasha and these Chetniks.

25             JUDGE MINDUA: [Interpretation] Thank you very much.  That was

Page 591

 1     very clear.  Thank you.

 2             MR. DEMIRDJIAN:  [No interpretation]

 3        Q.   [In English] And just to follow up on His Honour's question,

 4     Mr. Savic, what does this speech tell us in relation to Goran Hadzic's

 5     views at the time?

 6        A.   What can I say about his views?  As soon as we were set up as a

 7     board, obviously there was a lot of focus on us by other services

 8     operating in the area, some legal, some illegal.  Nevertheless, the

 9     ground was covered by a network of these services.  Goran, nevertheless,

10     was president, and he had a certain freedom in terms of who he was

11     getting in touch with and how he was talking to people.  At that time and

12     while we were still primarily in the town itself, we were still quite

13     united, as simple as that.  But I was the first to fall under the

14     influence of these services and agents operating there, but I refused to

15     settle for any of the arrangements that were on offer, particularly those

16     across the Danube.

17             I can explain that, and it's simple enough really.  The

18     Serbian Democratic Party had a platform, and the platform covered the

19     Republic of Croatia in territorial terms.  We were to operate in the

20     Republic of Croatia, and we would be a party to Croatia's parliamentary

21     life.  I did not believe that it was in our interest to link up with

22     anyone in Serbia or any other service.  It was often said that the

23     Croat-Serb issue was the heart of the matter in terms of how the crisis

24     might be resolved.  Nevertheless, this was really an issue between Zagreb

25     and Belgrade.  That's what it was.  The Serb-Croat issue was not

Page 592

 1     something for the Serbs in Croatia.  The Serbs in Croatia were an issue

 2     for Croatia, a democratic issue that Croatia had to come to terms with.

 3     And that, I think, is the simplest explanation if you want to understand

 4     the direction that our work as a party took at the time.

 5        Q.   Very well.  Can you see the -- the image, going back to this

 6     video, on this screen?

 7        A.   Let me see.

 8        Q.   The image might be a little bit blurry.  I don't know if you can

 9     identify anybody on this picture.

10        A.   This is Mile Vukas, the man on the left at the edge of the table,

11     who appears to be writing something.  The one with the moustache.  He's

12     sitting at the edge of that table.

13             I don't recognise the rest.  Nevertheless, having watched that

14     footage a minute ago, I caught a segment where I could recognise

15     Vukcevic, Professor Vukcevic.  And now understand one thing.

16     Professor Vukcevic and I were off to another meeting right after this

17     one, and that's why I was waiting for the Assembly to conclude, and I am

18     talking of Borovo of all places.

19        Q.   Yes.  Can we go perhaps to page 6 of this set of photos.  Is this

20     the same person you were telling us earlier?

21        A.   Yes, that's right.  That's Mile Vukas.

22        Q.   Very well.

23             MR. DEMIRDJIAN:  Your Honours, we have a set of eight or nine

24     photos.  Perhaps it would be useful to just identify this person with the

25     letter A.  Maybe the usher can help us marking this picture with the pen.

Page 593

 1        Q.   Perhaps in the top right-hand corner of this image you could

 2     write the person's name.

 3        A.   Mile Vukas; right?

 4        Q.   Yes.

 5        A.   My hand's a bit unsteady.

 6             MR. DEMIRDJIAN:  Very well.  If we could see --

 7             THE WITNESS: [Interpretation] You can see what I wrote, can't

 8     you?  My hand was at an awkward angle, but I think you can actually read

 9     what I wrote, can't you?  Or perhaps you want me to write it all over

10     again, do you?

11             MR. DEMIRDJIAN:

12        Q.   I think it's on the record as well as.  So it'll be fine.

13             MR. DEMIRDJIAN:  If we could seize image and if I could tender

14     it.

15             JUDGE DELVOIE:  Admitted and marked.

16             THE REGISTRAR:  Your Honour, 65 ter 4809.4, page 3 in e-court

17     marked by the witness shall be assigned Exhibit P52.  Thank you.

18             MR. DEMIRDJIAN:  Can we go to the next page.  I'm sorry.  The

19     next one.  No.  We already saw that one.  And the last one, please.

20        Q.   The person to the right of this image, who would that be, if you

21     remember?

22        A.   The face is familiar, but I can't remember his name.  I can't

23     remember his name.  He left Vukovar, so I haven't seen him for a very

24     long time.

25        Q.   Okay.  So you just mentioned Professor Vukcevic.  We hadn't

Page 594

 1     discussed him earlier.  Is he in any of these images or was he in the

 2     video-clip that you saw earlier?

 3        A.   I did catch sight of him just very fractionally.  He was to my

 4     left somewhere.

 5        Q.   Okay.  Moving on, you just mentioned the work of the party.  I'd

 6     like to show you another document which is at tab 10, that is 65 ter

 7     00102.

 8             MR. DEMIRDJIAN:  And, Your Honours, I'm just reminded that the

 9     video-clip that we just viewed hasn't been tendered.  Perhaps I could

10     make a submission after the first break about this video, because it's

11     about an hour, and we would be seeking to tender the entire video.  So at

12     this stage perhaps we can mark it for identification.

13             JUDGE DELVOIE:  You would not be seeking --

14             MR. DEMIRDJIAN:  We would be seeking to tender the --

15             JUDGE DELVOIE:  The entire.

16             MR. DEMIRDJIAN:  -- entire.  Yes.  It's a clip of about seven or

17     eight minutes.

18             JUDGE DELVOIE:  Okay.

19             MR. DEMIRDJIAN:  The entire video is about an hour.

20             JUDGE DELVOIE:  Okay.

21             MR. DEMIRDJIAN:  You see.  So perhaps we could mark it for

22     identification now and I will make a submission after the first break.

23             JUDGE DELVOIE:  Okay.  Let's mark it for identification.

24                           [Trial Chamber and registrar confer]

25             JUDGE DELVOIE:  What is the 65 ter number of the entire video,

Page 595

 1     Mr. Demirdjian?

 2             MR. DEMIRDJIAN:  The entire video is 65 ter 4809.

 3             JUDGE DELVOIE:  4809.

 4             MR. DEMIRDJIAN:  Yes.

 5             JUDGE DELVOIE:  Okay.

 6                           [Trial Chamber and registrar confer]

 7             JUDGE DELVOIE:  The Registrar tells me that they don't have it.

 8             MR. DEMIRDJIAN:  They don't have the whole video.  Okay for now

 9     let's just tender the clip and we'll deal with the whole video later.

10             JUDGE DELVOIE:  Marked for identification or just marked?

11             MR. DEMIRDJIAN:  For admission, full admission.

12             JUDGE DELVOIE:  Admitted and marked.

13             THE REGISTRAR:  Your Honours, video-clip under 65 ter 4809.3

14     shall be assigned Exhibit P53.  Thank you.

15             MR. DEMIRDJIAN:  Thank you.

16        Q.   Mr. Savic, do you recognise this document?

17        A.   Yes.  This is the platform of the Serbian Democratic Party

18     Regional Board for Slavonia and Baranja.

19        Q.   And when you say Slavonia, Baranja, does that apply to both

20     Slavonias?  Both eastern and western?

21        A.   Yes.  We just tried to keep it short, so we said Slavonia and

22     Baranja, which includes both east and west.  We wanted to avoid using any

23     really long names like the Communists did.

24        Q.   Now, at the top of this page we could see that it was -- it was

25     prepared at a session of the 3rd of February, 1991, in Lipik.  Could

Page 596

 1     you -- just to situate ourselves could you tell the Trial Chamber where

 2     Lipik is.

 3        A.   It's right next to Pakrac.  It's a thermal resort from

 4     Austro-Hungary.  It's very old.  So the meeting was held there because

 5     they actually have a hall that was big enough to hold all of us, all the

 6     candidates, and on the 3rd of February that was where we assembled to

 7     establish our board.

 8        Q.   Now, on this page we can see that's the programme of the work of

 9     the SDS, and I'd like to bring your attention to item number 2.  In the

10     English version could we scroll down a little bit.  Thank you very much.

11             Under item 2, in the second paragraph of item 2 it is written

12     here that:

13             "In the present order of things and relations, any kind of

14     contact with the party in power in Croatia is out of the question until

15     the abolishment of the legal institutional and other norms and practices

16     which deprive the Serbian people of their rights."

17             Now, in what context was this issued, Mr. Savic?

18        A.   As we were preparing for the multi-party elections in Croatia,

19     during that time the Croatian Democratic Union was set up as a party that

20     was meant to unite all Croats and their interests and also to articulate

21     the interests of the Croatian people.  The party was set up first and

22     foremost in order to finish the work -- the groundwork laid by the

23     Communists.  Their approach was quite open about one thing, the Serbs in

24     Croatia, and this was always seen as something of a problem for the

25     Croats, the percentage of Serbs -- Serbian population in Croatia.  They

Page 597

 1     were loud and clear about this, that we would have our rights taken away,

 2     our property taken away, that we would be driven out and eventually

 3     liquidated.  So what they ended up doing, they had been very up front

 4     about it previously.  So you have to see this story against that

 5     background.  First came the constitutional changes.  The Serbs saw some

 6     of their rights taken away pursuant to the new constitution.  People were

 7     angry and dissatisfied as they were being manipulated by both sides at

 8     the same time.  So this is the background against which you must see

 9     these things.

10             MR. DEMIRDJIAN:  And if we could go to page 3 in the B/C/S

11     version, and that is page 4 in the English version.  Under item 7 -- in

12     the B/C/S we need to scroll down a little bit.  Yes.  Thank you.

13        Q.   Now, by this time, this is the 3rd of February, 1991, we see here

14     that the SDS is working actively to establish Serbian autonomy.  Was this

15     an item that was high on the agenda already at the time?

16        A.   Well, you know, amid all this chaos and everything that was going

17     on, it was very difficult to prioritise.  A platform and our positions

18     really depended on how the political situation continued to evolve.

19     Would Croatia secede and become independent?  Would there be a

20     confederation?  Or would there be a third solution in terms of localising

21     the existing crisis?  No serious discussion on our political status could

22     possibly take place.  The pendulum kept swinging between political

23     autonomy, territorial autonomy, and so on and so forth, but in practical

24     terms it was all on a day-to-day basis and it was impossible to define

25     what course events would take.

Page 598

 1        Q.   And who -- who received this -- this document or who was it

 2     meant -- who was it meant to be written for?

 3        A.   This document, the party platform, was drafted by Milun Karadzic,

 4     who was secretary of the Slatina board.  He was very active, an elderly

 5     gentleman who tended not to move about too much, but we spent most of our

 6     time travelling around.  So it was up to him to draft the platform.  But

 7     it wasn't really carefully designed platform.  It was just a spur of the

 8     moment thing, a sudden inspiration.  We were the first movement, and then

 9     we had to set ourselves up as a proper political party.  Therefore, we

10     needed as many documents as we could possibly get and as much political

11     material to legitimise our position as a political party.

12        Q.   And who was the document distributed to?

13        A.   Candidates were appointed at the Assembly meeting who were people

14     from Municipal Boards.  Mr. Hadzic from Vukovar and Mr. Bogunovic as

15     well.  A number of others, too.  All of the delegates were familiar with

16     the platform.  They were shown the platform and served a copy.

17     Milun Karadzic was in charge of the Presidency's work.  I was a member of

18     this Presidency.  The entire board was familiar with this.

19             There was another noteworthy situation.  Mr. Hadzic and

20     Mr. Bogunovic were the names put forward as members of the board.

21     Following the Assembly meeting, I had come under a lot of pressure by

22     Veljko Dzakula, Ilija Sasic, and someone else whose name escapes me.

23     They wanted me to join the board as well.  I said, Goran is the board

24     president.  Bogunovic has now been appointed.  There's no need for me to

25     join.  Nevertheless, they were adamant that I should join as well.

Page 599

 1             I'm not sure what their intentions were, but they were very

 2     unhappy about me not joining, but that's what it was.  The people who

 3     were appointed eventually became board members, and that was that.

 4             MR. DEMIRDJIAN:  Could I offer this document, Your Honours.

 5             JUDGE DELVOIE:  Admitted and marked.

 6             THE REGISTRAR:  Your Honours, 65 ter document 102 shall be

 7     assigned Exhibit P54.  Thank you.

 8             MR. DEMIRDJIAN:

 9        Q.   Now, in your statement, Mr. Savic, you explain how after the

10     events at the Plitvice Lakes your ties with Mr. Hadzic were broken.  Did

11     you have any contacts with him following this incident?

12        A.   We were in the prison hospital in Zagreb for two days separately.

13     On the first day I had a meeting with Degoricija and assistant justice

14     minister, Hajdukovic.  The second day, the minister of the interior

15     Mr. Boljkovac and his assistant came, and we agreed then that we should

16     go home, that they would escort us.  After that, I was brought home and

17     they left me there.  So we didn't have any more direct contacts for a

18     couple of days at least.  I was not free to move around.  I had to be

19     careful.  I had to be careful where I went, why I went.  Simply the goal

20     was for me to be expelled from Vukovar.  There was a lot of noise in the

21     media.  There was a lot of pressure.  There were attacks on the house by

22     telephone and in all other possible ways, but I stayed.

23        Q.   And after your release, what happens to the -- what happened to

24     the SDS party?

25        A.   Many things began to change quickly after that, and things moved

Page 600

 1     along quickly.  I couldn't get involved with that that much anymore.  All

 2     the activities were taken over by Vukasin Soskocanin within the party,

 3     who was the president of the board in Borovo.  That was the biggest board

 4     that we had.  From time to time they contacted me about co-ordinating

 5     activities and tasks, but within a couple of days, actually, I was told

 6     by the people from the HDZ board in Vukovar that an order had arrived

 7     about my liquidation.  Why did I say the HDZ?  Because very often the HDZ

 8     is discussed in a negative context as the party exclusively to blame for

 9     everything that happened.  However, the Vukovar board and the people in

10     Vukovar there, I was in very good terms with them.  Even before I take

11     over the board I contacted them.  I asked them what they thought about

12     it, and they were in favour of it.  They said, Well, something has to be

13     tried.  We have to try something.  So they reported to me from the board,

14     and they said, You know that now no harm will come to you from us, but

15     there are a lot of people who have been brought in from the outside, so

16     just be careful where you go.

17             After that, I was summoned by the Croatian radio Zagreb,

18     Mirjana Rakela, the editor, called me and asked if I was willing at 1630

19     hundred hours on the 2nd of May to participate in a programme that would

20     be broadcast live on radio Zagreb.  I cannot remember the name of the

21     programme anymore.  And then she said, Mr. Savic, you will be broadcast

22     live.  Everything you say will be broadcast live.  She was very willing

23     to go through with this.  I said, Well, I cannot tell you anything right

24     now about this but let's talk in a couple of days, but as far as I'm

25     concerned, there's no problem.

Page 601

 1             After that -- so this was planned for the 2nd of May.  So one day

 2     I received information that Mr. Hadzic was in Zagreb to see the assistant

 3     minister of the interior, Mr. Degoricija.  I didn't know anything about

 4     this, so I was a little surprised about it, even though he had the

 5     right -- in any case, I think Degoricija invited him to come.  Simply I

 6     was a bit reluctant.  I didn't insist about anything.  I didn't want to

 7     create any problems about this, particularly because there was a

 8     completely different order that had come about myself.  So I then just

 9     took it a notch down about all of these activities, or I controlled

10     myself, in any case.

11        Q.   And to wrap up on the topic, what happened to the political

12     activities of the SDS party during the summer of 1991?  Did it continue

13     carrying out its activities?

14        A.   There was a lot of pressure already after the formation of the

15     Serbian National Council.  People were falling away.  There was a

16     parallel group of people who introduced themselves as a constituent

17     organ.  They were saying that the party could not be a constituent organ

18     and the Serbian National Council would take over all the functions in

19     this area.

20        Q.   Very well.  Moving on to a slightly different topic, at paragraph

21     123 of your statement, you explain that a retired JNA general,

22     Radojica Nenezic, had recommended Goran Hadzic to Slobodan Milosevic to

23     make him the man who would represent the SBWS.  Could you tell the Court

24     when this took place?

25        A.   Since I was first offered to go to Belgrade for talks but I

Page 602

 1     didn't go, but in any case, I controlled who would go and through whom

 2     this -- these contacts would proceed.  So Goran proceeded in this way.

 3     We contacted.  We spoke openly.  We were together.  We drove together a

 4     lot, and I asked him, What does it mean to get close to Milosevic in this

 5     way, and what does it mean to you to go to Belgrade?  And he said to me,

 6     Well, listen.  Milosevic is a true Serb.  He is a good man.  He doesn't

 7     have any major political ambitions.  Let's just have this resolve itself

 8     and then he will step back.  And it was all a lot of nonsense.  I mean, I

 9     didn't really go into it whether he would stop with his activities or

10     not.

11             Secondly, anyone who went to Belgrade, they would always say, I'm

12     going to see Milosevic, but the road to Milosevic through -- leads

13     through some alternative ways, through the SPS political party or the old

14     retired functions from the Military Intelligence Service, the KOS.  So

15     this Nenezic was a person from this area.  He was quite correct in his

16     conduct, popular among people.  So at one time when we met each other

17     during the summer and we met each other at his initiative, he told me

18     that he regretted very much recommending Goran and for -- and I can tell

19     you he even died with this burden.  He was very unhappy and very sad that

20     things had taken this turn.

21             So there was this line through which probably some other people,

22     too, did it.  I mean, there were more lines to Belgrade than telephone

23     lines.

24        Q.   Thank you.  I'm skipping a little bit ahead in time, sir, because

25     I want to show you a video so you can help us identify a few individuals.

Page 603

 1             MR. DEMIRDJIAN:  Could I ask for 65 ter 04982 to be played on

 2     Sanction.  Okay.  So that's 04982.1, and the ERN is V000-6733.  We can

 3     start playing it from the beginning.

 4                           [Video-clip played]

 5             MR. DEMIRDJIAN:

 6        Q.   Can you see the video on your screen, Mr. Savic?

 7        A.   Yes, I can.

 8        Q.   Now, we showed you this video yesterday.  Is it correct you saw

 9     this for the first time yesterday?

10        A.   That's right, yes.

11        Q.   Okay.  And it is correct to say you're not able to identify the

12     location?

13        A.   Correct.

14        Q.   I'll ask you to help us with some of the people we see on the

15     screen.  Do you recognise this person right here?

16        A.   Yes.  This is Milan Martic.

17        Q.   What do we see behind him?  What's the emblem there?

18        A.   Well, that ought to be some kind of emblem with eagles.  This is

19     one of those Serbian insignia.  It's some sort of Serbian insignia.  I

20     would often say that whoever would make something up, they would

21     immediately implement it.  So this is the same with this symbol.  I think

22     it says "Baranja" on it or something.  There is a name on the -- on the

23     symbol, but I cannot really tell what it is.

24        Q.   Okay.

25        A.   It says "Krajina," I think.  Captain First Class Mladic.  I think

Page 604

 1     that the person in the glasses behind him is Frenki Simatovic in the

 2     second row.  Jugoslav Kostic is in the first row.  I don't know this

 3     older man next to Mladic.  Vojin Susa is behind in the second row next to

 4     Frenki.  Mile Paspalj, Goran Hadzic.  I cannot recognise the person next

 5     to Goran.  I simply don't know who that is.  And here is Jaja, chief of

 6     the Slavonia, Baranja and Western Srem security service, Stevo Bogic.

 7        Q.   Very well.  Perhaps we could at this time pull up the stills we

 8     have from this video so you can mark the individuals with letters so we

 9     can record this.  So this would be which 65 ter number?  4982.2 for the

10     stills.  Yeah.

11             MR. DEMIRDJIAN:  Yes, Your Honours?

12             JUDGE DELVOIE:  Do you intend to tender only stills or the video

13     as well.

14             MR. DEMIRDJIAN:  In this case, Your Honour -- in this case,

15     Your Honour, we will tender the stills.  We will have another witness to

16     identify the location and the time, et cetera.  Thank you.

17             JUDGE DELVOIE:  Thank you.

18             MR. DEMIRDJIAN:  Okay.  On this first still, maybe if you can

19     mark the first person to the left with the letter A and tell us who that

20     person is on the record.

21        A.   This is Mr. Hadzic.

22        Q.   Okay.  Maybe with the assistance of the usher redo that letter A,

23     please.

24        A.   [No interpretation].

25             [Marks]

Page 605

 1        Q.   I know it's not very easy on the screen, but let's give it a shot

 2     again.

 3        A.   Mm-hmm.  This is not the best thing for me.  I cannot manage to

 4     do this.  It's not working.

 5             JUDGE DELVOIE:  Would a circle work?

 6             MR. DEMIRDJIAN:  We will have two circles on this image, that's

 7     the problem.  But we can say person to the left, person to the right.

 8        Q.   Very well.  Who is the person on the far left in the first row?

 9     Okay.  Well, yes.

10        A.   Mr. Goran Hadzic is on the left.  That's marked by the letter A.

11     It was supposed to be a letter A.  On the right-hand side is Stevo Bogic,

12     marked with a B.  So this is not the person right next to Goran but the

13     one -- the second person from -- standing from him.

14        Q.   Very well.

15             MR. DEMIRDJIAN:  Can I ask for this image to be admitted and

16     marked.

17             JUDGE DELVOIE:  Admitted and marked.

18             THE REGISTRAR:  Your Honours, 65 ter document 4982.2, e-court

19     page 1 marked by the witness, shall be assigned Exhibit P55.  Thank you.

20             MR. DEMIRDJIAN:  And can I ask to go to the next page, please, in

21     this set of photos.

22        Q.   Yes.  And can you tell us in this image next to Mr. Hadzic who is

23     the person there?

24        A.   Mile Paspalj.

25        Q.   Very well.  Can we go to the very last page, please.  And I'm

Page 606

 1     sorry -- how can we do this?

 2             MR. DEMIRDJIAN:  Perhaps we could tender the image we just saw

 3     with the comment that it's Mr. Paspalj.  The whole set.  Okay.  Let me

 4     just deal with this one too.  On this picture I would need the assistance

 5     of the usher to mark a few persons, please.

 6        Q.   You already gave us some comments while watching the video.  Can

 7     you mark the individuals again starting from the far left, the persons

 8     that you recognise with the letter A, B, C, and D, if possible.

 9        A.   This is Captain First Class Mladic.

10        Q.   Very well.  Who else do you recognise?

11        A.   I don't know the person standing next to him, but the person next

12     to that one is Jugoslav Kostic.  Are we going to use A and B again?

13        Q.   Yes.  And for the individuals behind that you were talking about

14     you can use the letters C and D?

15        A.   Frenki Simatovic is behind, then.  That's C.  And Vojin Susa is

16     D.

17             MR. DEMIRDJIAN:  Very well.  Can we capture this image as well.

18             JUDGE DELVOIE:  Very well, admitted and marked.

19             THE REGISTRAR:  Your Honours, 65 ter 4982.2 page 9 marked by the

20     witness shall be assigned Exhibit P56 thank you.

21             MR. DEMIRDJIAN:

22        Q.   Now, you mentioned earlier Stevo Bogic, Mr. Jaja.  To your

23     knowledge, you already told us his function.  You said he was head of the

24     state security.  Now, how long did he remain in that position, to your

25     knowledge?

Page 607

 1        A.   I really don't know for how long, but I know that Goran boasted,

 2     saying that the appointment of Mr. Stevo Bogic for chief of security

 3     service would guarantee peace in the area of Slavonia, Baranja, and

 4     Western Srem.  That's what he said.  Bogic was a problematic person, a

 5     provocateur, somebody who might even threw out from meetings, sometimes.

 6     And once at a meeting with some people were Belgrade at one time when I

 7     prompted him a little bit he said, Do you know that he threw me out of

 8     meetings?  And I said, Yes.  And as for you and me, nothing has changed

 9     there.  I don't why Goran appointed him.  I don't know what his reasons

10     were, but there it is.

11        Q.   Very well.  Can I show you a document.  It's at tab 38.  It's

12     65 ter 05869.  Now, you can see that this is a list.  It says here "List

13     of salary payments."  On the next page in a moment we will show you the

14     date of this document.  You can see the list of members here.  You have

15     president of the republic, Goran Hadzic, and under number 7 you still see

16     Mr. Stevo Bogic.

17             Can we go to page 2, please.  In English as well.  Do you see the

18     date on this document, Mr. Savic?

19        A.   Yes.  The 15th of June, 1992.

20        Q.   Now, you were -- you were still in the region at the time in

21     1992.  Does it fit with your recollection that Mr. Bogic was still a

22     member of the government at that time?

23        A.   I think that he was, yes.  In 1992, I was in Vukovar, in my

24     house.

25        Q.   And I apologise.  Could we return to the first page.  Now, you

Page 608

 1     see the list of ministers and by this time I assume that this is the

 2     government of the Republic of Serbian Krajina; is that correct?

 3        A.   I think that I saw Knin at the bottom.  I think that this would

 4     be the Knin people, because Paspalj, Zdravko Zecevic, this is all Knin.

 5     The prime minister.  Paspalj was a speedily elected president of the

 6     Assembly when the Vance-Owen Plan was supposed to be signed.  They

 7     brought him from the forest and appointed him to be as the president of

 8     the Assembly, because some document needed to be signed.  He is a

 9     forestry engineer.  Then you have Dzakula.  He was the president of the

10     municipality.  I think that he was doing something in the Red Cross.

11     That's Knin.  It's Knin.  Bogic, Stevo, then that's the government of the

12     Serbian Republic of the Krajina then.  Because we had so many Assemblies

13     and governments that's now it's very difficult to tell which one is

14     which.  Then this is the Republic of the Serbian Krajina after it was

15     formed up there in the village.  Then Stevo was the chief of the security

16     service of the Krajina then.  Koncarevic, Ilija; Veljko Vukelic.  I know

17     all of these people from the list and I know where they are, but I don't

18     know what they were doing.  Well, here the secretary of the government,

19     Dusan Starovic, Jelica Radmila, secretary of the Assembly but this is the

20     government of the Krajina.

21             MR. DEMIRDJIAN:  May I offer this document, Your Honours.

22             JUDGE DELVOIE:  Admitted and marked.

23             MR. DEMIRDJIAN:  Before we take the break -- sorry.

24             THE REGISTRAR:  Your Honours, 65 ter document 5869 shall be

25     assigned Exhibit P57.  Thank you.

Page 609

 1             MR. DEMIRDJIAN:  Just before we take the break, Your Honours, can

 2     I clarify one answer the witness just gave.

 3             JUDGE DELVOIE:  Of course.

 4             MR. DEMIRDJIAN:

 5        Q.   You mentioned that Paspalj was speedily elected president of the

 6     Assembly when the Vance-Owen Plan was supposed to be signed.  Is that

 7     correct?  Is that what you meant by it?

 8        A.   Yes, yes.  Babic was against that.  He didn't want to sign it.  I

 9     don't know exactly what this was about, but anyway, that was the

10     principle of how they resolved problems, to find somebody from the area,

11     no matter who, no matter what, and then if they appointed -- if they

12     agreed and were appointed, if a signature was necessary, then they would

13     immediately proceed towards appointing that person.

14        Q.   And I just wanted to clarify.  For the plan, you said Vance-Owen.

15     Is that the right name of the plan?  Because we're in 1992 here.

16        A.   Some of the peace agreements.  Don't hold me exactly to the word.

17     I mean I just said Vance-Owen like that.  It was one of the peace

18     agreements that was used then as a pretext to appoint Paspalj as the

19     president of the Assembly and the Vance-Owen Plan was not there in 1991.

20     That's -- that's right.

21             MR. DEMIRDJIAN:  Maybe this is an appropriate time, Your Honours.

22             JUDGE DELVOIE:  How long will you need after the break,

23     Mr. Demirdjian?

24             MR. DEMIRDJIAN:  I have one video and two maps to show, so I

25     would expect about 15 minutes, Your Honours.

Page 610

 1             JUDGE DELVOIE:  Thank you.  Mr. Witness, we'll take -- Mr. Savic,

 2     we'll take the break now and come back at 3.30.  You will be escorted out

 3     now.

 4                           [The witness stands down]

 5             JUDGE DELVOIE:  Court adjourned.

 6                           --- Recess taken at 3.00 p.m.

 7                           --- On resuming at 3.30 p.m.

 8             JUDGE DELVOIE:  Can the witness be escorted in, please.  Thank

 9     you.

10             MR. DEMIRDJIAN:  Your Honours, I've been informed that I have

11     about seven minutes left on the time we estimated, so I'll try to wrap it

12     up as quickly as I can.

13             JUDGE DELVOIE:  Thank you.

14                           [The witness takes the stand]

15             JUDGE DELVOIE:  Yes, Mr. Demirdjian.

16             MR. DEMIRDJIAN:  Thank you, Your Honours.

17        Q.   Mr. Savic, in your statement, at paragraph 140, you explained the

18     organising of volunteers who were sent from Serbia to the area of

19     Vukovar.  Do you remember that?

20        A.   Yes.

21        Q.   Can I show you the next video-clip, which is 65 ter 4873.1, and

22     the ERN is V000-2233.

23                           [Video-clip played]

24             THE INTERPRETER: "[Voiceover] Anchor:  As previously announced,

25     Goran Hadzic, president of the Serb region of Slavonia Baranja and

Page 611

 1     Western Srem, is in our studio.  Good evening.

 2              "Goran Hadzic:  Good evening.

 3              "Anchor:  When did you arrive in Belgrade?

 4              "Goran Hadzic:  Well, I arrived last night.

 5              "Anchor:  Can I ask you as a reporter what the current situation

 6     in the theatre of war is?

 7              "Goran Hadzic:  Well, the situation is much clearer

 8     military-wise.  We have a big part of free liberated territory in our

 9     area, that is the whole of Baranja, Western Srem from Vinkovci in the

10     direction of Sid and the bigger part of this Osijek field.  That is

11     between Osijek and Vukovar.  Vukovar is currently blocked.  We expect

12     denouement of the situation in Vukovar any day.  We are capable of

13     dealing with this quickly but we are thinking of human lives and taking

14     care that this will be done slowly and securely with as few casualties as

15     possible; that is, we do not want any casualties.

16              "Anchor:  Do you have information on events in Vukovar?  Do you

17     have information on Serb people in Zagreb?"

18             MR. DEMIRDJIAN:  Thank you.  I just pause it here for a second.

19        Q.   Here Mr. Hadzic is mentioning that some parts of the territory is

20     free.  Vukovar is still blocked.  Could you situate for the Trial Chamber

21     around which time this interview would have taken place?

22        A.   This interview might have occurred just before the fighting in

23     Vukovar ceased, which was sometime on the 18th or the 19th.  So I would

24     place this sometime back in early November 1991.

25             MR. DEMIRDJIAN:  Thank you.  Let's play the rest of the clip.

Page 612

 1                           [Video-clip played]

 2             THE INTERPRETER:  "[Voiceover] Do you have any information on the

 3     Serb people in Zagreb?

 4             "All communications lines are down.  There are no phone lines

 5     available and people cannot talk to their families.

 6             "As I said, I'm not concerned with the military issue.  I am

 7     positive a final solution will follow.  I am, however, concerned about

 8     some information I personally received from some of our services.  They

 9     tell me what the situation is in Zagreb and we know what happened in

10     Vukovar, mass crimes against the civilian population.  We will

11     interrogate perpetrators and bring them to face a court a law, a national

12     court.  I'm certain they will be punished accordingly for their misdeeds.

13     It is no use whining.  This is neither asked nor expected of us.  The

14     Serbs never whine.  Serbs should fight and will fight to protect their

15     people.

16              "You have already appealed to all able-bodied men to return to

17     their homes and join their comrades who are already on the front line.

18     Was the appeal successful?

19              "The appeal was success fell in every way.  A number of our

20     combatants who fled have now returned.  They are now fighting along the

21     front lines.  We also called in volunteers from Serbia irrespective of

22     their party affiliations, Serbs to join or ranks and fight with Serb

23     insignia for the Serbian people who are at risk.  They came.  I will take

24     this opportunity to thank all of them to came to fight.  The group from

25     Belgrade stands out.  They are always on the first lines of combat.  They

Page 613

 1     fight and they are killed just like us but do not hesitate to go all the

 2     way and win."

 3             MR. DEMIRDJIAN:

 4        Q.   Now, at this clip at the last section we hear Mr. Hadzic talking

 5     about the volunteers who joined from Serbia.  Having regard to what

 6     you've said in your statement, to your knowledge who on the side of the

 7     SBWS was co-ordinating -- co-ordinating or responsible for the reception

 8     of the volunteers?

 9        A.   The Territorial Defence board of Vukovar was set up in Sid.  This

10     boards would spend their days registering people who came over from

11     Vukovar to register with the board.  They would give them weapons.  They

12     would give them appropriate clothes to wear, and they would take them to

13     Vukovar.  So the Territorial Defence Staff of Vukovar in Sid was in

14     charge of doing that for everyone from -- from our area.  That is from

15     the Vukovar area.

16        Q.   And could you tell the Trial Chamber who was in charge of this

17     staff in Sid?

18        A.   Dusko Filipovic was the commander, and Slobodan Grahovac was the

19     head.

20        Q.   And at paragraph 142 of your statement, you mentioned that

21     Borislav Bogunovic was also at the headquarters in Sid.  What was his

22     role there?

23        A.   The staff was housed on the premises of the Socialist Party of

24     Serbia in the town centre of Sid.  Day-time activities proceeded as per

25     usual.  Sometimes Boro Bogunovic, Kertes and other people would visit

Page 614

 1     during the times that I was there.  So these, roughly speaking, would be

 2     the people who dropped by.  Boro Bogunovic was minister of the interior

 3     of the Slavonia, Baranja and Western Srem.  I suppose that was the

 4     capacity, official capacity in which he appeared there.

 5             MR. DEMIRDJIAN:  May I offer this video, Your Honours.

 6             JUDGE DELVOIE:  Admitted and marked.

 7             THE REGISTRAR:  Your Honours, 65 ter document 4873.1 shall be

 8     assigned Exhibit P58.  Thank you.

 9             MR. DEMIRDJIAN:  Thank you.

10        Q.   The last topic that I'd like to deal with, Mr. Savic, is the

11     issue of Lovas, where you explain in your statement that you stayed there

12     for several weeks in October and November 1991.  Now, it is correct to

13     say you stayed there until the end of the operations in Vukovar; is that

14     right?

15        A.   Yes.

16        Q.   And you indicated that you knew a number of people there, and

17     you've indicated also a number of locations in paragraph 150 onwards of

18     your statement.  What I would like to do is mark these locations on an

19     aerial image we will be displaying on the screen.  That is 65 ter 6276 at

20     tab 64.  And with the assistance of the usher I hope we can mark some of

21     these locations.

22             Are you able to situate yourself on this map, Mr. Savic?

23        A.   Yes, I am.

24        Q.   First, could you indicate with a line the main road leading into

25     Lovas on this map.

Page 615

 1        A.   The main road leading into Lovas is on the left-hand side of the

 2     screen.  So this is the main line leading all the way into Lovas town

 3     centre or village centre.

 4        Q.   Okay.  In your statement you mention a police station.  Are you

 5     able to locate the police station on this map?

 6        A.   The police station was here, in the middle of the village.  You

 7     go up to access the village, and the police station was the first

 8     building on the left.  The house used to belong to someone, a person who

 9     used to work in Germany.  It was a new house, well equipped.  It would

10     not have been right for the police not to enjoy an appropriate degree of

11     comfort, would it.

12        Q.   Now, I know it's a little bit difficult.  Would you be able to

13     mark it with -- let's start with number 1 this time instead of letters,

14     see if that could make it easier.

15        A.   This is number 1, in which case that should be over here.

16     There's a bit of a blot here now.

17             MR. DEMIRDJIAN:  Could the usher perhaps help us clean that up

18     and write number 1 again.

19        Q.   Could you just mark number 1 there without putting a line.

20        A.   There you go, number 1.

21        Q.   Then you also mention that when the government had meetings in

22     Lovas, they held meetings in a building next to the police station.  Can

23     you mark that with a 2.

24        A.   It was right across the way from that building.  There was a

25     residential building there containing also some business premises.  It's

Page 616

 1     a building that belonged to the Lovas co-op.  It was right across the

 2     way.  There was some separate rooms on the ground floor, and a grocery,

 3     whereas the last two floors were reserved for residential flats.

 4        Q.   You also mention that shortly after the takeover of Lovas a

 5     headquarter was established by Ljuban Devetak.  Where would that be

 6     located?

 7        A.   That building and those premises were used for the purposes of

 8     the staff as well.  There was enough room there, and that building was

 9     used for everything that was going on.

10        Q.   Okay.  Can you say -- when you say that building, do you mean the

11     building you marked with number 2 just now; is that right?

12        A.   Number 2, yes.

13        Q.   Okay.  And are you able to locate the Zadruga building on this

14     map?

15        A.   The workshop and the machine factory as well as the kitchen, it

16     was down the street from that building in the opposite direction towards

17     the lower corner of this photograph.  It was right here.  You can see

18     that there are actually some hangars there.

19        Q.   And did the JNA have any headquarters in Lovas?

20        A.   The JNA were using a house that is further down the street from

21     the police station.  It was here somewhere, also to the left and further

22     down the street from that house.

23        Q.   And just for the record, you've marked the JNA house with the

24     number 4; is that right?

25        A.   Number 4, yes.

Page 617

 1        Q.   And again for the record, you marked the Zadruga as number 3.

 2        A.   That's right.

 3        Q.   You also mention in your statement that the JNA had a check-point

 4     at the entrance of the village.  Is that visible on -- would that be

 5     visible on this map?

 6        A.   That would be on the left-hand side of this image.  So this is

 7     the start of the access road, and you can see the co-op facilities here.

 8     It's a large-scale yard.  You can see a number of hangars there.  There's

 9     a silo over here, and this is where the check-point was, on the -- right

10     next to the gate that people used to access the yard.

11        Q.   Could you mark that area with the number 5.

12        A.   [Marks]

13             MR. DEMIRDJIAN:  Thank you.  Very well.  Is that visible enough,

14     Your Honours?  Okay.  Can I ask to mark this document as well.

15             JUDGE DELVOIE:  Admitted and marked.

16             THE REGISTRAR:  65 ter document 6276 marked by the witness in

17     court shall be assigned Exhibit P59.  Thank you.

18             MR. DEMIRDJIAN:  Thank you.

19        Q.   And my last question on this topic, at paragraph 193, you state

20     that Goran Hadzic -- you had seen him in Lovas.  Can you indicate to us

21     how many times you had seen him in Lovas?

22        A.   Goran was sometimes there.  We met several times, even along the

23     access road.  We would exchange greetings, that sort of thing, but I

24     never attended any meetings there.  I don't know who he was with.  I

25     suppose with Ljuban, but he would sometimes come and, yes, I did see him

Page 618

 1     there.

 2        Q.   Just to be clear, you were there during the months of October and

 3     November?  Is that -- would that be right, or can you specify how long

 4     you were in Lovas?

 5        A.   I was there until the cessation of hostilities in Vukovar.  As

 6     soon as one could go to Vukovar, I went immediately.

 7        Q.   Okay.  And you told us that you didn't -- you don't know who he

 8     was with when he came to Lovas.  Did you know what he was doing when he

 9     came to Lovas?

10        A.   When I saw him, he was on his own.  We met twice at the very

11     gate.  We just greet each other.  He would go his way, and I would go

12     mine.  That's what happened.  I never really asked any questions as to

13     his reason for being there.

14        Q.   Very well.  And you were saying that you never attended meetings

15     there.  To your knowledge were there meetings in Lovas?

16        A.   I know there were some dinners and lunches that Ljuban organised

17     for the government of Slavonia, Baranja, and Western Srem or individual

18     ministers.  He was particularly fond of organising parties for Jaja.  I

19     don't know of any other meetings except for the 2nd of October.  I think

20     a government meeting took place on that date.  I was in charge of

21     organising that meeting.  The objective of that particular meeting was

22     for the government to show up in this area, the government from Erdut.

23     All the people from the villages across the area were assembled.  This

24     was harvest season, but they didn't have anything to use in terms of

25     equipment or anything like that.  So we talked about the harvest mostly.

Page 619

 1     That was the subject discussed at the meeting and people came from as far

 2     afield as Erdut, about seven or eight of them.  If you need their names I

 3     could enumerate them for you.  I think there are actually minutes from

 4     that meeting that are available somewhere.

 5        Q.   Yes, and those minutes are mentioned in or statement.  I just

 6     want to clarify.  When you say Ljuban, can you give us his last name?

 7        A.   Ljuban Devetak.  Whenever I say Ljuban, that's who I mean.

 8        Q.   Thank you.

 9             MR. DEMIRDJIAN:  Your Honours, that's all I ask.  I'm told that I

10     have to mention something for the record in relation to the clips.  If I

11     may be given a second.

12                           [Prosecution counsel confer]

13             MR. DEMIRDJIAN:  Your Honours, I'll deal with it after the next

14     break just to clarify.  It's in relation to the video-clips and as

15     associated exhibits.  I'll get back to you.

16             JUDGE DELVOIE:  Thank you.

17             MR. DEMIRDJIAN:  Thank you.

18             JUDGE DELVOIE:  Cross-examination.

19             MR. ZIVANOVIC:  Thank you, Your Honour.

20                           Cross-examination by Mr. Zivanovic:

21        Q.   [Interpretation] Mr. Savic, good afternoon.  My name is

22     Zoran Zivanovic and I represent Mr. Hadzic in the proceedings.

23        A.   Good afternoon.

24        Q.   You answered a question by my learned friend the Prosecutor,

25     saying that you gave two statements to the OTP, one in 2002, the other in

Page 620

 1     2003; is that right?

 2        A.   Yes, that's right.

 3        Q.   You also testified in the Stanisic case, did you not?

 4        A.   Yes, I did.

 5        Q.   Previously you had met with the Prosecutor twice in order to

 6     prepare you for your testimony in that case in 2008 and 2009, had you

 7     not?

 8        A.   Yes, indeed.

 9        Q.   Finally, we see this new consolidated statement from you which

10     the Prosecutor has shown you and which you signed.  I will be asking you

11     a series of questions in relation to that amalgamated statement.  I will

12     tell you right off it was very difficult for me to distinguish some

13     things based on that statement, namely the things you said which you know

14     by means of direct knowledge, direct experience, meaning you actually

15     heard or saw something yourself on the one hand and on the other your own

16     views, your own positions and theories which you somehow acquired at the

17     time.  So it was very difficult for me as I was reading your statement to

18     keep the two apart.

19             Now this statement has been admitted into evidence.  You make a

20     total of 74 references to Slobodan Milosevic in that statement in a total

21     of 39 different paragraphs of your statement.  What I want to know is

22     this:  Did you ever actually meet Slobodan Milosevic?

23        A.   No.

24        Q.   You gave the first two statements in 2002 and 2003 at a time when

25     the Milosevic trial was underway before this Tribunal.  Did the OTP call

Page 621

 1     you as a witness in that case?

 2        A.   No, they didn't.

 3        Q.   I also noticed that you make several references to

 4     Vojislav Seselj in your statement, Vojislav Seselj and his acolytes or

 5     members of his party, a total of 53 references in a total of 25 different

 6     paragraphs throughout your statement.  Did the OTP ever call you to

 7     appear as a witness that at that case?

 8        A.   No, they didn't.

 9        Q.   Based on your testimony in the Stanisic and Simatovic trial, I

10     noticed that you were asked an explicit question by one of the Defence

11     counsel, I believe, and you said that you were never directly in contact

12     with either Stanisic or Simatovic.  Is that true?

13        A.   Yes that's true.

14        Q.   When you say that, does that mean, Yes, that's true, that's what

15     I said, or, That's true, I was never directly in contact with either of

16     them?

17        A.   I was never directly in contact with either of them.

18        Q.   There is something I'd like to ask you first just to shed light

19     on some of your movements following the 2nd of May, 1991.  I'm reading

20     your statement and I get the impression that up until that time, the

21     2nd of May, you were living in Vukovar.  Am I right?

22        A.   Yes.

23        Q.   That is the day you left for Serbia; right?

24        A.   Yes.

25        Q.   Can you tell us exactly where you settled down when you arrived

Page 622

 1     in Serbia on the 2nd of May?  Where did you live?

 2        A.   In Sabac, in my parents' home, also in Odzaci, in a studio that I

 3     got from the Hypol general manager, Mr. Knezevic.  He allowed me to use

 4     it.

 5        Q.   How long were you in Sabac for, roughly speaking?

 6        A.   My mother was there and I would come and go.  It's really

 7     difficult to pinpoint a time period.  I would go there every couple of

 8     days, whenever I needed some rest.  Whenever I needed to calm down a

 9     little, that was what I would go.  So it wasn't something definite.  It

10     was whenever I needed to go, that's when I went.

11        Q.   So you were not in Sabac all the time?

12        A.   No.  No.  Mostly I moved from Vojvodina in Backa Palanka to

13     Apatin, Sombor.  That's the area that I moved in.

14        Q.   I asked you where you lived.  Does that mean you also lived in

15     Backa Palanka, Apatin, Sombor, in Odzaci, or you lived in a specific

16     place?

17        A.   Well, between Backa Palanka, Odzaci, Sombor, there's only half an

18     hour distance.  When I was in my studio apartment, I was in Odzaci, and

19     all these other places I went to on day trips.

20        Q.   In other words, you lived in Odzaci, and from time to time would

21     go to visit your mother in Sabac, and you went to other places as well.

22        A.   That's right.  That's right.

23        Q.   Can you tell me how long were you in Odzaci?

24        A.   I think until late May 1991.  Until the 20th of May, let's say.

25     Then I moved to Belgrade.

Page 623

 1        Q.   Did you rent an apartment there or did you live --

 2        A.   In Belgrade I lived either in a hotel or I would just go to

 3     Sabac.  I had some sort of accommodation.  I mean, we were putting up

 4     refugees in a place in Zvezdara.  There was a kindergarten that we were

 5     given for our use, so very often I was up there in that kindergarten.

 6     There were dorms that were prepared for refugees.  That was a working

 7     kitchen.  That's it, more or less.  But if I stayed in the centre late,

 8     then I would sleep in one of the hotels there, most often in the

 9     Union Hotel.

10        Q.   So from time to time you stayed at the Union Hotel.  From time to

11     time you were at this refugee centre in Zvezdara.

12        A.   Or I went to the Hotel Moskva.

13        Q.   The Hotel Moskva too?

14        A.   Yes.

15        Q.   Were you there by yourself?  I know that you have a wife.  Did

16     you arrive there with your wife or were you by yourself?

17        A.   I was by myself then.  My wife was with me for a certain period

18     of time when I was at the medical military hospital, then I transferred

19     her in March to get out of all of that crowded area, but for a brief

20     period of time she stayed with me at the Hotel Moskva where we were

21     together.

22        Q.   I'm sorry, when you say March are you talking about 1991 or 1992?

23        A.   1991.  I'm talking about 1991.  This is all 1991.

24        Q.   And what was the fuss in March 1991?

25        A.   When I left the prison hospital, when I came home, there were

Page 624

 1     attempts to attack the house.  There were telephone threats, all of these

 2     things, and my health wasn't all that good either.  However, I could not

 3     go for treatment to the city hospital.  I had to go to Belgrade, and I

 4     was at the Military Medical Academy for a week.

 5        Q.   I'm asking this because you said that this was in March.  I

 6     understood that you were released from prison in Zagreb in April.

 7        A.   Yes, yes, April.  You are correct.

 8             THE INTERPRETER:  The speakers are kindly asked not to overlap

 9     because of the translation.

10             MR. ZIVANOVIC: [Interpretation]

11        Q.   I just want to round off this part.  So in this period from the

12     20th of May you were in Belgrade.  Were you by yourself or were you with

13     your wife?

14        A.   I was by myself.

15        Q.   And your wife remained in Croatia?

16        A.   She stayed in my father's or her father's house in Borovo Selo.

17             THE INTERPRETER:  It's not clear what the witness said.

18             MR. ZIVANOVIC: [Interpretation]

19        Q.   Did you say that it was your father's or her father's house?

20        A.   It was her father's house in Borovo Selo.

21             JUDGE DELVOIE:  Mr. Savic, as you are both speaking the same

22     language and that has to be translated, you should try to avoid

23     overlapping.  So please wait until you can see that on the screen the

24     translation has finished before you answer the question of Mr. Zivanovic.

25     Thank you.

Page 625

 1             THE WITNESS:  Thank you.

 2             MR. ZIVANOVIC: [Interpretation]

 3        Q.   And how long did you stay in Belgrade?  Can you please tell me

 4     that?

 5        A.   [Interpretation] Until October.  October or November.  When the

 6     staff in Sid was established, the Territorial Defence Staff, that's when

 7     I transferred to Sid.  This was in late October, early November.  I don't

 8     recall the exact date.

 9        Q.   And when this Territorial Defence Staff in Sid was formed, you

10     went there, and you slept in Sid practically.

11        A.   Yes.  I had a friend in the village of Adasevci in front of Sid

12     as you take the highway.  That's where I would sleep.

13        Q.   And in your answer to a question by the Prosecutor, you said that

14     for a while you were in Lovas.  Can you just tell us when it was exactly

15     that you were staying in Lovas?  When did you leave Sid and go to Lovas?

16        A.   Well, I can't really give you the dates, but when the Tovarnik,

17     the action in Tovarnik and Lovas stopped, when the combat actions in that

18     area stopped, that's when I went to Lovas.

19        Q.   If these dates are correct or the approximate time periods,

20     October, November, that means that you went to Lovas after staying in Sid

21     or in this village of Adasevci for a while; is that correct?

22        A.   Yes, yes.  Afterwards.

23        Q.   And think that you said that you stayed in Lovas until Vukovar

24     was liberated, when you returned to your house.

25        A.   Yes.

Page 626

 1        Q.   Can you please tell me, Mr. Savic, before you joined the

 2     Serbian Democratic Party, you were a member of the League of Communists

 3     of Croatia?

 4        A.   Yes, just like the majority of people were.

 5        Q.   Are you able to tell me why you decided to leave the League of

 6     Communists of Croatia and join the Serbian Democratic Party?

 7        A.   Well, in a single-party system, everyone is a member of the

 8     party.  That applies to the League of Communists as well.  And the main

 9     reason is the membership fee, the membership dues.  My ideological

10     leanings are not of Communist type.  Even in my last term of office,

11     actually, I was at the post of the secretary of the local organisation.

12     When I was appointed secretary of the local organisation, and when I was

13     supposed to give a speech, I said something to this effect:  Evidently,

14     the party has reached an end, because a term of office was given to me.

15     That seems to be the end of the party.  And I will not regret being the

16     person to dig a grave for the party.  So then the other members wanted me

17     to face disciplinary proceedings, and then I said I didn't know of any

18     secretary who had sent himself for a disciplinary procedure.

19             What am I trying to say?  For ten years there had been a general

20     crisis in the state, a crisis of Communism, actually.  The party had used

21     up all of its credits.  It had to hand over power, and it was the most

22     difficult thing for them to do, to hand over or to give up their power.

23     So it was evident that there would be turbulent changes, especially

24     because after the elections in Croatia where the Party of Democratic

25     Action, actually the League of Communists changed its name to the Party

Page 627

 1     of Democratic Changes, party the SDP, and they got the vote of all the

 2     Serbs in the elections and then simply left them high and dry.  The Serbs

 3     were no longer necessary following the elections in a multi-party system.

 4     The Serbian Democratic Party was established in Knin.  It won seats in

 5     the parliament.  It became a parliamentary party.  Its area of activity

 6     was the Republic of Croatia, and in some estimate of mine it seemed

 7     logical that we would need to join in these activities.  So this is the

 8     only reason.  There was no major sadness or regret at leaving the

 9     League of Communists of Yugoslavia, no.

10        Q.   Well, one thing is odd in this answer of yours.  If you were not

11     a person with Communist convictions, why did you have to join the party

12     at all?

13        A.   Well, because of the membership dues.  Like I said, the party

14     exerts pressure on you to join, because they want you to pay the

15     membership dues.  So it wasn't even complicated to join the party.  You

16     could do that on the spot in the course of a day, so ...

17        Q.   And did that bring any privileges with it perhaps?

18        A.   Well, the privileges went to the political establishment.  I was

19     working.  I didn't have any political ambitions, and I didn't expect any

20     privileges that would come to me from the party, no.

21        Q.   But the fact that you accepted to become secretary of the party

22     organisation, I mean, that is an official function after all,

23     particularly in a situation where you don't share those convictions.  But

24     on the other hand, would that give you some privileges?  Did party

25     secretaries receive any privileges from the Communist Party?

Page 628

 1        A.   Well, the party disappeared silently.  It was no longer there.

 2     After the elections, the party just disappeared from view.

 3        Q.   Well, I'm saying this because I understood from your answer that

 4     the party changed its name and that it was called the

 5     League of Communists of Croatia Party of Democratic Changes.  So it

 6     didn't disappear.  It stayed, but it had a modified platform and a

 7     different name?

 8        A.   After the election and the election of the new municipal

 9     leadership, the president of the municipality was Slavko Dokmanovic.

10     Slavko Dokmanovic was my colleague who also worked in the Vupik

11     enterprise.  I tried to provide a kind of guideline to Slavko Dokmanovic

12     so that his direction of activity would be Zagreb, because a lot of

13     information was already coming from Belgrade data of the intelligence

14     type and so on, but he told me, Nobody wants to receive me in Zagreb.  I

15     tried through one of my friends who was a representative in the Croatian

16     Assembly from our list from Vukovar to try to see with Racan whether it

17     was possible for someone to receive him, and he literally told him -- he

18     told me, I went to see Racan.  He's making some sort of calculation with

19     4 million German marks in order to purchase mortars and he said he

20     doesn't want to talk to me.

21             Well, the Communists in any case tacitly transferred their power

22     to the HDZ, and this changeover of power was very quick and very quiet.

23        Q.   In 1989 or in 1990, but I think that it was in 1989, the

24     multi-party system was introduced in Croatia, so there were a lot of

25     parties.  Can you please tell me why was it that you chose the

Page 629

 1     Serbian Democratic Party in particular?

 2        A.   Well, I explained a little bit before what the position of Serbs

 3     in Croatia was, especially after the decision to embark on multi-party

 4     elections and after the HDZ became active.  The party began to spread a

 5     very unfavourable climate.  There was a lot of fear.  They publicly

 6     attacked Serbs, and that was the only topic that mobilised the party in

 7     the elections that it was participating in.  And so when it became an

 8     open fear that the Serbs, and it would be -- was quite normal to try to

 9     encourage people to get out of the blockade and to try to start thinking

10     in a different way.  So I cannot go for the Croatian parties when -- when

11     they don't need me.  Perhaps in some normal circumstances that would be

12     possible.  I mean, if somebody tells you, I don't need you.  You don't

13     need to bother with me, why would I offer myself up to them?  So then the

14     natural choice in that situation seemed to be the

15     Serbian Democratic Party.

16        Q.   You said, I think at pages 16 and 17 of today's LiveNote, that

17     you spoke to about 300 or 400 people, that there was fear among them,

18     that they were afraid of political involvement with the

19     Serbian Democratic Party, I assume you meant.

20             I would like to ask you the following question:  Who were they

21     really afraid of, or what were they afraid of?

22        A.   I believe that I've shared that with you already.  There was a

23     large-scale attack on Serbs by the political leaders of the states.

24     People somehow believed that by not becoming involved, by doing nothing,

25     they would be best protected and eventually saved.  It was very difficult

Page 630

 1     to convince people that what was being said was actually true and that

 2     these actions would be taken, although just to be perfectly clear about

 3     this, I fully understood the strategy of the Croatian Democratic Party,

 4     the period that was defined as Croatia's silence, which was roughly the

 5     same time as the happening of the people in Serbia, as they called it.

 6             This was an interesting moment in time, because Croatia as a

 7     country defined its political objective and its general direction for the

 8     future, and they said this in no uncertain terms.  It's not something

 9     they were trying to conceal.  They received international support for

10     their goals.  They publicly spoke about the fact that they enjoyed the

11     support for their future actions.

12             Those of us living alongside Croats were fully aware of this.  We

13     all knew that the Croats wanted an independent state, an independent

14     country, which as a desire was something that I viewed as natural, and I

15     respected that.  I said so many times that we were told this in public,

16     so many times, which I appreciated.  The only thing I didn't appreciate

17     is those who said they would be standing up for me, defending me.  Now,

18     that was something that I couldn't understand.  Why would someone defend

19     me and protect me when I needed no defending or protecting.  So it was

20     the defenders who actually played a much more prominent role in this than

21     the Croats.

22             Now, we the Serbs, and this is why I fail to understand the

23     policies pursued by Belgrade, the Serbs failed to capture this moment of

24     social change.  In a democracy, what really matters is the numbers.  They

25     were the largest single group in Yugoslavia, and obviously they would

Page 631

 1     lead any changes, and obviously they would have been the first to

 2     organise elections.  Why weren't they in pure historical terms?  Well

 3     that's a different matter altogether, isn't it?

 4        Q.   But that is beyond the scope of my question.

 5        A.   Yes.  I'm just trying to explain.

 6        Q.   In your statement to the OTP in 2003, you spoke in detail about

 7     these attacks on Serbs.  You said that after the 2nd of May and what

 8     happened at Borovo Selo, these attacks became more intense.  We have

 9     information suggesting that Serbs were being fired from their jobs

10     throughout the area, and I think you said that too.  Some were even

11     killed, some were threatened, and so on and so forth.  Was that the

12     reason that the people you spoke to, the 3- or 400 persons that you

13     mentioned were afraid to get politically involved?

14        A.   Yes, absolutely, an enormous fear.

15        Q.   The Prosecutor showed you some video footage today, and you were

16     asked about the concept of Ustasha.  I know that your family were not in

17     Croatia during the war, and I know that that is not where you hail from

18     originally, but we have information suggesting that among the people who

19     were living there, there were many persons who had very unfortunate

20     memories of that time.  I'm talking about World War II, people whose

21     families had been killed by the Ustasha during World War II.  I'm sure

22     you've heard of these instances as well, haven't you?

23        A.   Yes, yes.  That is certainly true, but I would like to explain

24     something else.  That period was never sufficiently clarified.

25        Q.   Yes, but I'd rather we just don't go into that now.  We don't

Page 632

 1     want to be explaining this now.

 2        A.   Yes, but this is something that is abused, so we're looking at an

 3     abuse here.

 4        Q.   Likewise, we heard about people who survived, but they still had

 5     these unpleasant memories about the fates met by their families, and our

 6     people were wary of this emerging Independent State of Croatia, lest

 7     something might happen again, the same sort of thing that happened back

 8     in World War II.  Did you ever come across people feeling that way?

 9        A.   Yes.  Yes, I did, and I said so, didn't I.

10        Q.   You know that between the two wars, during that time there were

11     some Ustasha organisations, not in Yugoslavia, abroad for the most part.

12     But are you aware that in 1989 or 1990, some members of those

13     organisations arrived back in Croatia and began to organise themselves?

14        A.   Yes, but the Communists were still in power at the time; right?

15        Q.   Yes.  That's what I'm talking about.

16        A.   Yes.  The borders were opened up, and all those who wished to go

17     back were free to do so.  That's what the propaganda was like at the

18     time.  That's true.

19        Q.   So we may therefore conclude that groups like that existed in

20     Croatia at the time, didn't they?

21        A.   Yes, but nobody was even trying to conceal their existence.

22     Everyone knew that those people were there.

23        Q.   The Ustasha groups, is that who you mean?

24        A.   Well, let me tell you, all the immigrants come back were labelled

25     as Ustasha.

Page 633

 1        Q.   May I just --

 2             JUDGE DELVOIE:  Are you trying to control the witness?

 3             MR. ZIVANOVIC:  Yes.

 4             JUDGE DELVOIE:  Okay.  Sorry.

 5             MR. ZIVANOVIC: [Interpretation]

 6        Q.   There's something else that I would like to ask you.  I know that

 7     not everyone, not every person who had gone on aboard was an Ustasha and

 8     whoever said this was the case was certainly wrong.  That is most

 9     certainly not the case, but my question is very specific.  I'm talking

10     about 1989, 1990.  Were there any Ustasha groups in Croatia?  I'm talking

11     about groups.  I'm not saying that everyone who moved back to Croatia

12     from somewhere else abroad was automatically an Ustasha.  I'm asking you

13     about the existence of any groups like that.

14        A.   People who had previously lived abroad for a long time were now

15     returning, those who wished to return and those who had good reason for

16     returning.  Were they members of a Ustasha organisation or not is not

17     something I can say.  When we are talking about immigrants, then let's

18     cover the whole category.  Some people came back of their own free will,

19     some were duped into going back, but I think, yes, it would be logical to

20     see the whole thing in terms of people going back, those who wished to go

21     back and were now finally free to go back.

22             JUDGE DELVOIE:  Mr. Demirdjian.

23             MR. DEMIRDJIAN:  Your Honours, I hesitate to rise, but this has

24     been happening for the second time now.  I think we should be very

25     careful when putting questions to the witness not to give evidence.  It

Page 634

 1     is all right to put questions, but comments such as, People were most

 2     certainly wrong about this or that position, I think -- I would advise

 3     that counsel be careful about not putting his side of the story but

 4     putting questions to the witness rather than giving evidence.

 5             MR. ZIVANOVIC:  I think that I could put the leading question to

 6     the witness, and I could lead him in cross-examination.

 7             JUDGE DELVOIE:  Please proceed, Mr. Zivanovic.

 8             MR. ZIVANOVIC: [Interpretation]

 9        Q.   So I wasn't talking about emigres here.  You were living in

10     Croatia at the time, and you would have been able to tell.  Is that what

11     people said publicly?  Were any rallies like that held?  That's what my

12     question was about, about the nature of any rallies.  I'm not asking you

13     whether somebody who attended a meeting came from abroad or not.

14        A.   Yes, that was my understanding of your question, and that's what

15     determined my answer, but coast was now clear for any organisations that

16     wished to start operating.  That much is certain.

17        Q.   You've just explained that in your understanding the Serbian

18     Democratic Party was operating in Croatia and that was the way it should

19     be.  So it should look to Zagreb.  Based on your statement, I see that

20     sometime in May 1990, you went to Belgrade to be there for the meeting at

21     which the Serbian Democratic Party was established in Belgrade, so I'm

22     wondering about this opinion of yours.  Does this opinion go back to that

23     time or did you form that opinion at later stage?

24        A.   I'm talking about the Serbian Democratic Party in Knin.  It was

25     under the control of the State Security Service in Serbia.  The setting

Page 635

 1     up of the board in Belgrade was interpreted as an activity performed by

 2     people from the area of Knin, Dalmacija, Lika, and so on and so forth,

 3     but living in Belgrade.  So that's who the border's being set up for.

 4        Q.   There's something else that I'd like to know.  At the time

 5     Yugoslavia was a single country.  I don't know if there were any

 6     restrictions to the effect that a political party was only allowed to

 7     operate in a certain area and not throughout the former country.  Hence

 8     my question, I assume the meeting in Belgrade was perfectly legal and the

 9     Party of Democratic Action was free to set up its own boards wherever it

10     chose to, the same thing that applied to the work of any other political

11     party at the time.  Wasn't that the case, sir?

12        A.   We know what the platform was and that's what I'm telling you.

13     As long as Yugoslavia was single and intact -- there are different

14     interpretations of that to begin with.  But it would have been pointless

15     to get Yugoslavia involved.  I'm talking about our side, the

16     Serbian Democratic Party.  Each newly founded political party has its own

17     territory and ground that it covers.  Is that not right?

18        Q.   Did you actually say that at the meeting of the Serbian

19     Democratic Party in Belgrade when the Serbia board was established?  Did

20     you stand up?  Did you speak up that this wasn't right, that this wasn't

21     the way it should be, that the Serbian Democratic Party should only

22     operate in Croatia and that it wasn't right for its board to be

23     established in Belgrade of all places?

24        A.   I was there as an observer.  I had no right to take part in the

25     actual work of the meeting.  They followed an agenda with speakers on it,

Page 636

 1     and they had all these things that they would do, but I had no right to

 2     be involved in the discussion of that meeting, and that's not what I was

 3     after anyway.  What I was after was meeting up with Raskovic in order

 4     talk to him and see if there was anything that we could do together to

 5     enhance the work of our party in Slavonia.

 6        Q.   Was that the first time you met Raskovic?

 7        A.   Yes, that was the first time.

 8        Q.   You knew that on the 17th of February that same year, the

 9     Serbian Democratic Party had been established in Knin and that he was its

10     president, did you not?

11        A.   Yes, I did.

12        Q.   You knew that party's platform, did you not?

13        A.   Yes, I did.

14        Q.   And you told him at the time that you wanted a board established

15     in Slavonia, Baranja and Western Srem, did you not?

16        A.   Yes, Slavonia and Baranja.  The term "Western Srem" was only

17     mentioned later on, but during our original conversation, we talked about

18     Slavonia and Baranja.

19        Q.   Do you know one thing about the platform of the

20     Serbian Democratic Party?  Among other things, it talks about the

21     establishment of territorial autonomy.  Should that be the option chosen

22     by the population at a referendum?

23        A.   I said that all these things about autonomy had to do with how

24     things went elsewhere in Yugoslavia.  Would Croatia emerge as an

25     independent country?  Would there now be a confederation or a different

Page 637

 1     form of organisation?  So the autonomy issue and the right to autonomy

 2     very much hinged on these other contiguous developments.

 3        Q.   Are you aware of a political motto held by Raskovic at the time?

 4     He said the number of Serbs in Croatia should be the same as the number

 5     of Croats in Yugoslavia.

 6        A.   I can't remember that.  It's not a platform.  It's probably

 7     something that he said at a rally.

 8        Q.   Yes, but I believe this was misinterpreted.  My question was

 9     misinterpreted, hence I'll repeat it.  Raskovic's motto was Serbs should

10     be in Croatia to the same extent that Croatia is in Yugoslavia.

11        A.   I think this is probably something that he exclaimed at a public

12     rally or something like that.  It wasn't a proper political platform.

13     But there's one thing I would like to add if I may.  We are in no

14     position to impose an ultimatum on CroatiaCroatia as a country had its

15     own constitution, its own laws, and it was supposed to make room for

16     others too.  If it denied some political rights to the Serbs, then they

17     had to include the Serbs in some other category.  Okay.  So ethnic

18     minority was the category chosen.  The status of an ethnic minority might

19     be debatable, but amid all the chaos that reigned at the time, it was the

20     way in which this was done that was perceived as particularly

21     humiliating.  Nevertheless, the times being what they were, there was

22     nothing much you could do about it.  You had to wait for the whole thing

23     to calm down a little, and we had to wait for a better moment, a better

24     time to discuss these things in circumstances that were back to normal.

25     That's why we were in no position to impose an ultimatum on Croatia as a

Page 638

 1     country.  This is how you see us, so this is what we'll do back to you.

 2     No, that was impossible.

 3        Q.   Can you just tell me this, please:  What do you mean when you say

 4     when better times come, a better moment?  That's what you said, something

 5     to that effect, better circumstances.  Which circumstances would that be,

 6     because on one hand you have Croatia seeking independence, secession from

 7     Yugoslavia.  On the other hand, you have Serbs in Croatia who don't want

 8     that.  So what would be these better times that were supposed to come?

 9        A.   Sir, there was a clash between two concepts and between two types

10     of people, those who saw a solution of that chaotic situation within a

11     legal framework and those who saw that solution through the use of any

12     type of ammunition, as powerful as possible.  That would be it put

13     simply.  That's what the conflict was about.  That's what everything

14     resolved around.  But in a situation that was so chaotic, for you to

15     define your political goals and your rights was impossible.

16             Our position should have been to work to reach a legal framework.

17     Of course the Serbs did not accept the state as it was.  They had their

18     rights.  They had their property within their own state, so who was

19     saying that they were not wanted in at that state?  First of all, let's

20     see that.

21        Q.   Are you trying to say the following:  That there was a problem,

22     that the problem should have been resolved through legal means but that

23     there were people who were misusing that?  Are you saying that?

24        A.   Well, also the separation within the state should have been

25     resolved by legal means, because in a -- in a situation where a state is

Page 639

 1     trying to split up, there are no legal solutions for such a problem.

 2        Q.   Just one more question before the break.  Are you aware that in a

 3     referendum the Serbs voiced their position on the secession of Croatia

 4     from Yugoslavia?

 5        A.   Well, I implemented that referendum in Vukovar.  In the building,

 6     in the office in the centre of town was where that referendum was

 7     implemented.

 8        Q.   Well, this is not what I was asking you.

 9        A.   Well, I will tell you now.  I simply have no confidence in

10     referendums whose results are 98 or 99 per cent in favour.  That would be

11     my answer to your question.

12             Who initiated the whole holding of the referendum, and why was

13     this done?  In any case, we did a hundred crazy tasks which were imposed

14     on us regarding political rights.

15        Q.   Well, can you just tell me this:  You have already said that you

16     voiced your distrust in relation to such a referendum.

17        A.   Absolutely.

18        Q.   The one that was implemented by the Serbian Democratic Party.

19        A.   Well, can you -- yes, yes.  I'm just going to tell you one more

20     thing.

21        Q.   Just one more question and then we will finish before the break.

22     And you, at that time, did not leave the Serbian Democratic Party even

23     though in a way you knew and you asserted that this referendum was not

24     proper, that the results of the referendum were not accurate?

25        A.   I'm not a person who gives up.  I just follow the manipulation as

Page 640

 1     it develops, and I'm aware of the manipulation that somebody would impose

 2     on me, but I have to do something.

 3             MR. ZIVANOVIC:  We can have a break, Your Honours.

 4             JUDGE DELVOIE:  Okay.  Mr. Savic, we will take the second break

 5     now and come back at 5.15.  You will be escorted out of the courtroom

 6     now.

 7                           [The witness stands down]

 8             JUDGE DELVOIE:  Court adjourned.

 9                           --- Recess taken at 4.47 p.m.

10                           --- On resuming at 5.17 p.m.

11             JUDGE DELVOIE:  While the -- while the witness is brought in --

12     while the witness is brought in, we have a short oral ruling to put on

13     the record.  It's about joint motion seeking admission of agreed

14     documents.

15             On the 19th of October, 2012, the Prosecution and the Defence

16     filed a joint motion seeking admission of 56 documents.  One document

17     designed as Rule -- designated - sorry - as Rule 65 ter number 00809 has

18     already been admitted as Exhibit L3.  The Chamber finds that the

19     remaining documents are relevant and have probative value and shall be

20     admitted and marked.  The Registry is directed to assign exhibit numbers

21     beginning with P and L as outlined in the motion.

22             The Chamber notes that there was a typographical error in Annex A

23     to the motion and the document listed as ordinal number 12 should have

24     Rule 65 ter 00358.

25                           [The witness takes the stand]

Page 641

 1             JUDGE DELVOIE:  Mr. Zivanovic.

 2             MR. ZIVANOVIC:  Thank you, Your Honour.

 3        Q.   [Interpretation] Mr. Savic, I wanted to put one more question to

 4     you about your stay in Serbia after the 2nd of May, 1991.  Are you able

 5     to tell me what you did when you were in Odzaci?  What were you doing?

 6     What were you busy with?

 7        A.   Bosko Perosevic was the president of the municipality in Odzaci.

 8     We knew one another.  We tried to organise assistance for the refugees,

 9     and in co-operation with him and Brana Crncevic, that's what I did.

10        Q.   And what did this assistance or aid comprise?  Specifically, what

11     is it that you did?

12        A.   Well, I was trying to bring in medicines.  Look, everybody knew

13     me.  I received a truck full of medicines from the Sabac pharmaceutical

14     industry, for example.  There was help from the municipality of Zrenjanin

15     and other neighbouring municipalities.  And then we transferred that

16     across to Borovo, and since we had medical solutions from Sabac, we would

17     provide the hospitals along -- that to the hospitals by the -- using the

18     Danube River.  This is more or less what I did.

19        Q.   So if I understand you correctly, you were collecting medicines

20     and other types of assistance in Serbia and then you were sending it to

21     Borovo and other parts of Croatia.

22        A.   Also, we were sending it to centres that were receiving refugees.

23     For example, there was certain schools along the Danube River bank where

24     they were receiving refugees.  For example, there was a location in

25     Vajska, and we gave this help there.

Page 642

 1        Q.   On the 2nd of May, 1991, when you went there, I don't think that

 2     there were any refugees in Serbia.  The war hadn't started then.

 3        A.   They had already starting appearing after the 2nd of May.  We had

 4     a ferry in Borovo Selo, something that I arranged with Novakovic, because

 5     there they were working with small boats, but we obtained a proper ferry,

 6     and the wave of refugees already was beginning to cross over the Danube.

 7        Q.   And what was your reason to move to Belgrade?  I think you said

 8     that you went there sometime in June or after the 20th of May.

 9        A.   Because I didn't feel safe, personally, in Odzaci.  One morning

10     at approximately 7.00 a.m. somebody began to knock on my door.  My

11     neighbour said, You left your car.  You parked it and it was in the way.

12     But when I come to the building, I always park in a place where I don't

13     bother anyone.

14             I let the water run in the toilet in the bathroom, and I said,

15     I'm having a shower.  I will come down shortly, come downstairs.  And I

16     took a shower, I got my things, and after a certain period of time I went

17     out, went to my car, and I went to Belgrade.

18        Q.   And so you didn't go back there to sleep, did you?

19        A.   Yes, that's right, I didn't.

20        Q.   And this thing that your neighbour said, you took that as some

21     sort of threat against you; is that right?

22        A.   Yes, yes, I did.  I had very, very sharp instincts.

23        Q.   On three occasions in your statement, and you didn't mention

24     this, but in your statement you mention three times that you were

25     supposed to be killed.  I can read that part of your statement back to

Page 643

 1     you.  This is paragraph 171.  You said that this happened that day when a

 2     body -- when the body of Vukasin Soskocanin was taken out of the

 3     Danube River, and you said that this was ordered by Milosevic, that this

 4     Kertes was supposed to carry this out and that Ljubo Novakovic was an

 5     accomplice in all of this.  Well, we know who Milosevic is, but can you

 6     explain to us what Kertes was doing?  Who was he at that time?

 7        A.   Kertes was always God.  He was a man who was a close associate of

 8     Slobodan Milosevic.  He was involved in everything that had to do with

 9     personnel policy in the area of Slavonia, Baranja, and Western Srem.  He

10     was involved in all issues of any kind of assistance whatsoever, and he

11     controlled that area, simply speaking.

12        Q.   I have information that at that time he was assistant of the

13     federal minister of the interior.  Do you agree with me?

14        A.   Yes, yes.  I agree.  It's quite possible.

15        Q.   And Ljubo Novakovic, who was that?

16        A.   Ljubo Novakovic was the president of the Backa Palanka

17     municipality.  To us the municipality was a place to meet.  Goran would

18     stop by there, Vukasin.  Everybody from the area would come by.  That's

19     where our meeting place was.

20        Q.   And you managed to avoid this because you didn't go to the bank

21     of the Danube River, which you said in your statement.  Instead you went

22     to Odzaci; is that correct?

23        A.   Yes.

24        Q.   So if you can explain to me how do you explain the fact that such

25     powerful people at the time, Milosevic as the president of the state at

Page 644

 1     the time, Kertes's assistant, Ministry of the Interior and as you said

 2     God for that area, do not carry out what was planned, this alleged murder

 3     against you and that you managed just to evade that by going away and

 4     leaving, going some 10 kilometres farther?

 5        A.   I always had more information.  The way in which

 6     Vukasin Soskocanin was liquidated was something that I was familiar with.

 7     I know that the divers attached him to a -- a piece of wood, a log, and

 8     he could not float up.  So at a meeting that Kertes was presiding over,

 9     he asked me to give my support to him, because there were about 50 people

10     from that area.  They were talking about arms sales and for this to be

11     settled.  At the beginning of the meeting, Trifun Ivkovic came in from

12     Sremska Mitrovica he was, and I don't need to repeat what is in my

13     statement.  Trifun Ivkovic is a major provocateur, and you always have to

14     analyse the things he says and does between the lines.  The fact is that

15     I didn't want to be a president, and I didn't want to be involved in

16     anything.  And then he asked the question, Why is Goran the president

17     when we agreed that it should be Boro?  In the meantime Ljuba Novakovic

18     brought a paper to me on which it said that near Novo Selo, this is a

19     village right on the bank of the Danube River, a body has floated up, and

20     so that I should go and see to check if that's Vukasin Soskocanin.  So

21     what would you think after something like that?  I told Kertes, All

22     right.  I'm leaving now.  And I told Ljuba, I don't have a car.  And he

23     said, Well, my driver will take you.  And so when we set off, I told him,

24     You drive me to Odzaci.  And the police was already there on the left

25     bank of the Danube, and the executors of the act were together with the

Page 645

 1     police.

 2             I am not guessing, but that is the way.  This is how they get rid

 3     of people.  Why would I go and check something that I know for a fact was

 4     impossible?  Well, that's my conclusion.

 5        Q.   This is the first time you mentioned the fact that the

 6     perpetrators were there on the riverbank.  The perpetrators of what

 7     exactly?

 8        A.   The perpetrators or the executors of death penalties.  It wasn't

 9     about swimming, that's for sure.

10        Q.   In other words, you have been sentenced to death by someone from

11     that group you refer to.  Okay.  And now these people are here, and they

12     are supposed to execute your sentence.  Is that what you're talking about

13     when you say "perpetrators"?

14             Mr. Savic, you were driven to Odzaci by Ljubo Novakovic's driver;

15     right?

16        A.   Yes, that's right.

17        Q.   He probably said where he drove you to.

18        A.   Yes.  I told him to say that, Tell Ljubo that you dropped me off

19     at Odzaci.

20             JUDGE DELVOIE:  Mr. Zivanovic, if you would allow -- you seemed

21     to ask the witness:

22             "In other words, you have been sentenced to death by someone from

23     that group you refer to.  Okay.  And now these people are here and they

24     are supposed to execute you -- your sentence.  Is that what you're

25     talking about when you say 'perpetrators?'"

Page 646

 1             And then without asking for -- without waiting for an answer, you

 2     go about:

 3             "Where you were driven to Odzaci by Novakovic's driver; right?"

 4             So now I'm -- aren't we missing something here?

 5             MR. ZIVANOVIC:  Yes.

 6             JUDGE DELVOIE:  When you say:

 7             "In other words, you have been sentenced to death," do you mean

 8     the witness or do you mean a person in general?

 9             MR. ZIVANOVIC:  I mean about the witness.

10             JUDGE DELVOIE:  Okay.

11             MR. ZIVANOVIC:  That the witness was sentenced to death.  It was

12     his testimony as far as I --

13             JUDGE DELVOIE:  Okay.

14             MR. ZIVANOVIC:  -- understood.

15        Q.   [Interpretation] I'll repeat the question:  Did you say that you

16     were, as a matter of fact, sentenced to death?

17        A.   Yes.  That's my assessment, which I believe to be correct, and

18     that's what I said.

19        Q.   And these perpetrators were there in order to execute you, to

20     carry out this death sentence?

21        A.   We'd be speculating, wouldn't we.  But why else would they want

22     me to go to the riverbank?  Listen, I'm not paranoid.  My anti-war

23     activity was very unpopular.  Even the government -- when the government

24     was set up for Slavonia, Baranja and Western Srem, they banned [Realtime

25     transcript read in error "banded"] all of their members from talking to

Page 647

 1     me.  I knew what this was about, and this wasn't the first time I faced a

 2     situation like that, starting with Plitvice and you can take it from

 3     there.

 4        Q.   This is precisely what I wanted to ask you.  How do you explain

 5     the fact that these perpetrators were there to carry out your own death

 6     sentence on the banks of the Danube.  How come they didn't drive over to

 7     Odzaci later on, because they knew that you were there.  It's a well

 8     known fact.  It was known to Ljubo Novakovic, for example, who you define

 9     as one of the people involved, an accomplice.

10        A.   This was still not a time of large-scale executions, which is

11     what came later on as the conflict escalated.  It's about taking

12     advantage of someone's gullibility, getting that person killed as

13     smoothly and as trouble free as possible.  I can tell you how they

14     liquidated Soskocanin.  It is not a subject that is unfamiliar to me.

15     It's not something that I couldn't cope with.

16             MR. DEMIRDJIAN:  I have a small intervention for the transcript,

17     Mr. Zivanovic.  At page 73, line 6, when the witness says, "when the

18     government was set up for Slavonia, Baranja and Western Srem, they

19     banned," I think the word "banned" is misspelled there.  I just wanted to

20     put that on the record.

21             MR. ZIVANOVIC:  Thank you.  Thank you to my learned friend.

22        Q.   [Interpretation] You said that you were banned or forbidden in

23     terms of communicating with the members of the government.  It's about

24     the interpretation.  That's why I'm asking.

25        A.   Yes, I was banned.

Page 648

 1        Q.   Now that we have come to that, in paragraph 191 of your

 2     statement, and if that's required, I can always go back to the original

 3     text if you want me to.  You can see it on your screen too.  It's 5868.

 4             You said you were on a list of persons to be killed.  This was

 5     ordered by the service, and the government members were banned from

 6     contacting you.

 7        A.   A list.  Okay.  I did not see a list.  Banned from contacting me,

 8     that's what the government members themselves told me, you see.  The way

 9     in which persons were selected to be liquidated, I don't know.  Maybe

10     that too is an interpretation matter.  So -- list.  I wouldn't say me, a

11     list, no.  But it's a fact that all those who opposed the way in which

12     the area was operating - I'm talking about Slavonia, Baranja and

13     Western Srem and the area right across the Danube - all those were

14     undesirable in terms of staying there.  They didn't want them there any

15     more.  That's a fact.

16        Q.   But at the time you weren't in the area, were you, when the

17     government was set up, if I understand you correctly.

18        A.   Everybody in that area knows me.  It doesn't matter if I'm

19     physically there at a certain point in time or not.  Do you understand

20     that?  I had lots of contacts with people from across the river starting

21     with the municipal presidents, Backa Palanka, Sombor, factory managers,

22     doctors, lawyers.  I would practice once a month.  We would meet at

23     Banja Junakovic more often than not.  And then we would meet there, then

24     I would explain to them at these meetings how they could best help us.

25     So I was co-ordinating.  This was about co-ordinating different tasks.

Page 649

 1             So to come back to this, it's an area in which I'm a familiar

 2     face.  In anybody wants to know anything, if there's anything they need

 3     to raise, they get in touch with me.  They ask the question.  As for me

 4     physically staying in that area, because this is what I'm talking about,

 5     and where else should I go after all?

 6        Q.   You said the government members told you that any contact with

 7     you was banned.  Can you specify which government members told you that?

 8        A.   Bogdan Vorkapic was one of them.  I think he was the economy

 9     minister, something like that.  Milos Vojnovic was another.  He was the

10     justice minister.  He was a nice lad.  Our relations were great.  And

11     that's all I remember.  But I don't think it takes more people than that.

12     It's quite enough if one person says it.  I hadn't even known about this,

13     but I met Bogdan Vorkapic in Belgrade at Terazije.  I was about to ask

14     him a question and there he was running away from me and I said, Bogdan,

15     hold it right there.  I want to ask you a question.  And he says

16     literally, Listen, I'm sorry, but I'm not allowed to talk to you.  It's

17     not that I was necessarily greatly taken aback by this.  I said, Okay.

18     Fine.  Let it be, if that's the way it is.  It's not that I was pressing

19     him or anything.  I wasn't actively seeking contact anymore after that.

20        Q.   He and this other man, Vojnovic, did they perhaps tell you that

21     your name was marked for liquidation, that the service ordered your

22     killing, in other words?

23        A.   No.  Why would I ask them such a question?  And it's not really

24     something that they would have been told anyway.  They are just doing

25     their jobs, and this is something external.  It was extraneous to their

Page 650

 1     work.

 2        Q.   So who was it that told you about the fact the service had

 3     ordered you to be killed?

 4        A.   Well, I told you my instincts were alive and well.  It's not that

 5     I went rummaging about or asking questions, you see.  I wasn't nosing

 6     around.  It was just the general impression I got based on my contacts

 7     with different people.  I knew how far I was allowed to go, but there is

 8     no need to insist on this point.  There's no need to push this point.

 9     It's just something that my instinct told me, and I tried to steer clear.

10     This was nothing that stood out at the time, nothing particularly

11     special.

12        Q.   In paragraph 180, of your statement, you also say that you were

13     informed in July 1991 by Djordje Bozovic, also known as Giska --

14             JUDGE DELVOIE:  Mr. Zivanovic, just in case you're moving to

15     another topic, we have heard several times that the discussion was about

16     the service, the service having ordered this, and having banned -- I

17     suppose, banned the witness as well.  Could we clarify with the witness

18     which service we are talking about just for the record.

19             MR. ZIVANOVIC:  Yes, I will, Mr. President.  Thank you.

20        Q.   [Interpretation] Mr. Savic, you make numerous references also in

21     the paragraph that I just mentioned and elsewhere in your statement to

22     "the service."  Could you please be more specific about what this means.

23     What do you mean by "the service"?  What is the context for that

24     particular usage?

25        A.   Well, the only service that I could possibly mean in this context

Page 651

 1     were that being the State Security Service.

 2             JUDGE DELVOIE:  The State Security Service of?

 3             THE WITNESS: [Interpretation] Serbia.  That's what we're talking

 4     about, aren't we?

 5             JUDGE DELVOIE:  Thank you.

 6             MR. ZIVANOVIC: [Interpretation]

 7        Q.   Paragraph 180 of your statement, you say that in July 1991,

 8     Djordje Bozovic, also known as Giska, offered to help you if you ever

 9     felt threatened in Belgrade, and then one night he warned you that you

10     should escape because there were threats coming from Hadzic, he

11     suggested, but your take on it was that the threats actually originated

12     from Knin, the people in Knin.  So the first thing that I wish to

13     clarify, if you look at this paragraph, you'll see a reference there to a

14     man named Borcevic.  Is that the same person or is this a typing mistake?

15        A.   Djordje Bozovic.  I think that's who we're talking about.

16        Q.   So that's the same person, Djordje Bozovic?

17        A.   Yes, that's right.

18        Q.   Did that person perhaps tell you anything about why you were

19     encountering these difficulties, why you were receiving threats?

20        A.   Giska was the commander of the volunteer brigade belonging to the

21     SPO.  He was one of the state perpetrators, so to speak, as well as

22     Arkan, Martic, and the others.  I asked him why he wasn't with Arkan.

23     Since they had this guard, why wasn't he with them.  And he said, They're

24     all Communists over there, and I had no business being with then.

25             When I came to Belgrade after Plitvice, I told you about my

Page 652

 1     instinct; right?  I have feelings, you know.  I know that the way I

 2     pursued my own peace mission was at odds with the historical moment.  So

 3     I pleaded with him.  I said, You're moving about in these circles.  I

 4     have to tell you, I'm not feeling particularly safe in Belgrade.  I don't

 5     have anybody in particular that I can name, but I assume we're talking

 6     about a certain type of people who are in the know, you know, and they

 7     exchange a lot of info.  So you see, you're actually the only guy around

 8     here that I trust so I'm telling you this.  Just let me know.  No need to

 9     ask any further.  Everything after that is up to me.

10             I was sleeping at the union, and he came about 10.00.  He said,

11     Listen, bro, because that's how we talked to each other, he said, Get up.

12     Get ready to leave.  You've got to be off this very minute.

13             Do you want me to go on or -- so I said to him, Who is this from?

14     He said, Goran.  And I said, Well, you know what?  I don't buy it for a

15     minute.  It's not Goran, but okay.  There are all sorts of people doing

16     all sorts of things here, but all I can do is the next morning first

17     thing I'll check what this is about.  And he said, I'll stay with you

18     till next morning, and we did, as a matter of fact.

19             I left for Matica that morning to see Brana Crncevic.

20     Brana Crncevic and I were sitting in the same office.  Actually, I was

21     sitting in his office.  And I said, Could you please call Radmilo.  I

22     want to talk to him.  So Radmilo showed up in no time at all.  The

23     shortest time possible it would have taken him to get there from the

24     government building.  So he realised that we knew each other.  So this

25     was a man I trusted and there was nothing I couldn't share with him.

Page 653

 1             So we greeted each other and he said, Well, where have you been?

 2     What's up?  And I said, Listen, aren't you surprised to see me still

 3     alive, and he said, Well, what on earth do you mean?  And then I told him

 4     the whole story about what transpired and then he said, I know nothing

 5     about that.  I really can't confirm.  Be that as it may, if there's

 6     anything that needs doing, I'll give you hand.

 7             So that was that.  And then I told him, Listen, I have three

 8     lawyers in Belgrade.  I have left my materials and documents evenly

 9     distributed with these three.  So no matter who ends up being the one

10     doing it, these lawyers have my permission to use these materials and

11     actually publish them.

12             So that's how the whole thing ended in the roughest of terms.

13        Q.   Well, you mentioned this material.  Can you please tell me

14     whether the material refers specifically to these events which could then

15     present some sort of danger to you?  Is that something that happened in

16     1990 or 1991?

17        A.   Well, it's just a bluff.  There was no material at all.  However,

18     in that situation, you know what it means to publish something.  And even

19     if you say that you have something, people think that you do have it, you

20     know?  So, well, you know, there's a saying that depending on the market,

21     the goods are like that.

22        Q.   So in this period from the 2nd of May until June, your life was

23     in danger, you're saying, from members of the security service.  Is that

24     what you're saying?  Am I correct?

25        A.   Yes.  Let's assume that.  Actually, I assumed that.  I don't know

Page 654

 1     as to what sort of service it was.  I mean, there were many of those who

 2     were there for liquidations.  I mean, there were some informal

 3     condemnations to death, not just from the service.

 4        Q.   And the reasons for that were your political beliefs or your

 5     opposition at the time to the policies that were implemented in

 6     Yugoslavia or Serbia?

 7        A.   Well, I was spreading anti-war ideas, and would I always say that

 8     the Croats have the right to do what they're doing, and then they would

 9     say, Well, what are you talking about the Croats?  And I would say,

10     Well, they have the right to do that.  Why are you bothering me with

11     Croats and it's a fact that we're there and we're not in Croatia.  Why

12     don't you clean up your own house first?  That was more or less what I

13     said.  I'm not somebody who would keep quiet.  I would tend to provoke

14     discussions from -- with people.  So that's what the discussion and the

15     stories were about.

16        Q.   Mr. Savic, you know that in 1991, there were many opponents of

17     Slobodan Milosevic's policies; right?

18        A.   Yes, I do.

19        Q.   You know that on the 9th of March, 1991, there were major

20     demonstrations which were attended by over 100.000 people?

21        A.   But there were many more who respected his policies.

22        Q.   You mean at the demonstrations or are you saying generally

23     speaking?

24        A.   Generally speaking.  Those who had power in their hands would

25     determine the direction that things were moving in.

Page 655

 1        Q.   I know that in those demonstrations there were many political

 2     parties participating from Serbia at the time and these parties had many

 3     followers.  Are you aware of that?

 4        A.   Yes, yes.

 5        Q.   Can you explain to me?  You see, I don't know at that any of the

 6     people who took part in the demonstrations, the leaders of those parties,

 7     those prominent figures who had a large number of followers.  I don't

 8     know that any of them were killed either by Milosevic or by any of those

 9     secret services.  So I wanted to ask you what was your reason for

10     believing that the regime was so angry at you?  You didn't have an army

11     behind you or a political party.  You didn't have a large number of

12     followers and so on and so forth.

13        A.   Well, I don't think that I rated highly enough for something like

14     that, but they did acknowledge that in the area where I worked I did have

15     a certain amount of influence, that I had a large number of people who

16     trusted me to whom I did not lie and with whom I didn't play any

17     politics.  In that area, I still have people.  Many of my friends paid

18     with their heads because of that.  This is why I withdrew, because of the

19     people who trusted me.  I told them, Don't touch any of these people any

20     more.

21             So you cannot really compare the political scene in Belgrade.

22     This is something that is co-ordinated and done.  All of those parties at

23     one point in time were in the opposition, and at one point became the

24     organs of power, but they all had the same master.  The

25     League of Communists split into a lot of parties, but they did it in such

Page 656

 1     a way that everybody was ours.

 2             I mean, if you look at Vuk Draskovic, did he do better because he

 3     was just beaten instead of being killed?

 4        Q.   Well, I'm not going to deal with what you said about Draskovic in

 5     any way, but I wanted something else now.  You just said that you told

 6     someone, Don't touch them.  Who did you say this to?

 7        A.   I said that to Radmilo Bogdanovic at the time when we were

 8     sitting at Brana's:  Please don't touch people who trust me.  I am

 9     getting out of all of this.  I am not interested in this.  You can reach

10     Vienna if you want, wherever you like, but I'm no longer interested in

11     any of this.

12             I always had contacts with whomever I wanted to, and in Belgrade

13     they would always tell me that all the doors were open to me, but I

14     didn't go to any of these doors.  You understand.

15             So like I said, I'm not a paranoid person and so on, but it's

16     quite normal in certain circumstances to think about oneself, and this is

17     not something that should dwell on a lot.  That's what the circumstances

18     were like at the time.  I managed to come out of all of that.  This is

19     not some major topic for discussion, you know, but I left Belgrade and

20     went to Sid because it was not safe for me in Belgrade anymore.  Then I

21     left Sid, then I went to Lovas because it was not safe for me in Sid

22     anymore.  Simply this was my assessment.  That's how I was moving, you

23     know?

24        Q.   You said that you spoke with Radmilo Bogdanovic and that you said

25     this to him, not to touch these people who shared your beliefs.  Is this

Page 657

 1     something that he was intending to do?  Was it your impression that -- I

 2     thought that he came to your summons because you felt threatened that

 3     night.

 4        A.   In any case, Radmilo Bogdanovic was a person whom I trusted.  I

 5     already said that.  So when I tell him something, I expect in view of his

 6     range of activities and his people and everything, I tell him so if

 7     there's any need for anything further.  Let him explain, you understand?

 8     I don't think that he's the one doing all of this, and leading in all

 9     these matters, but he has a broad circle of people, so it's something

10     that should be put through their ears.  I mean, it's not something that

11     was specifically aimed in any way.

12        Q.   You told us here that you went to Sid in late October sometime, I

13     think, and that you sheltered in Sid because you felt threatened in

14     Belgrade.  Before you left for Sid, did you have any threats or was there

15     any reason for you to feel in danger from anyone or anywhere?

16        A.   Matica had a warehouse in Belgrade at the fair where the

17     assistance was collected and passed on.  I was working on that, and a lot

18     of our people from the Slavonia area were working there.  Since weapons

19     and weaponry was also sent out from that warehouse, I didn't get involved

20     in that.  Simply people were doing that.  And they, those people who were

21     dealing with that, were in contact with the services, and they would be

22     regularly reporting back to me what was going on, who was coming and

23     going without any major insistence on my part.  And at one time I was at

24     the -- in the warehouse and a friend came by and he said, A friend wants

25     to see you.  All right.  Let's get in the car.  We went to the

Page 658

 1     Knez Mihajlova Street.  I don't know which number, but it was a different

 2     building from the federal SUP building when you enter.  Actually, it was

 3     the Knez Milosa Street, not the Knez Mihajlova Street.  And I went to

 4     these premises and colonel, a colonel appeared, Colonel Djokovic, who at

 5     the time was the deputy chief of the Military Intelligence Service KOS.

 6     It was some sort of stage like that.  So we greeted each other.  We

 7     introduced one -- ourselves and he said, You don't have to say anything

 8     to me.  I know everything.  Meaning we don't have time.  There's no time

 9     for nothing.  And he said, Tell me what you are intending to do.  I said,

10     I'm not intending to do anything.  I'm waiting for the fighting to stop

11     and then I am going home.  And he said, Well, do you know that you cannot

12     go there?  You're not allowed to go there.  You mustn't go there.  I

13     said, Well, all right.  Then you know that I will go.  If you know that I

14     am not allowed to go there, then you know that I will also go there.  And

15     he said to me, Listen, the only thing that I can help you with -- well,

16     do you have any weapons?  I said, No, I don't.  He said, The only thing I

17     can help you with is to give you weapons.  What are you going to do with

18     the weapons?  I said, Look, I don't have any weapons.  I don't want to

19     have anything to do with that, and if I did receive any weapons it would

20     only be with an accompanying permit.  And he said, All right, what do you

21     want?  There was a large number of things on offer and I said, All right,

22     just give me a Skorpion.  I mean, I didn't know much about it but a

23     Skorpion was a status symbol, so I received this Skorpion.  He said,

24     Well, I don't have any ammunition but you can get some at the fair.  Take

25     a box.  And so what I was supposed to do?  They were controlling

Page 659

 1     everything.  Was I supposed to ask him what all this was about, what was

 2     going on?  You understand?  General Nenezic, whom I used to visit at his

 3     home and we would meet regularly, he always used to say to me, Be

 4     careful, you're being followed.  He is an old KOS person.  He knows all

 5     these principles.  My car was broken into in front of the Sumatovac.  My

 6     bag was taken, my files, everything that was in the car.  Everything that

 7     was inside.  So what was I supposed to check further?  I don't have time

 8     or any need to check anything.  I have my own path and I have an instinct

 9     that guides me.

10        Q.   And when you received this Scorpion you went to Sid?

11        A.   After a couple of days.  After a couple of days there was

12     something like this that a staff was being formed in Sid and that they

13     were going to commit a massacre, that they were going to push people

14     there to get killed.  That was the assessment of General Nenezic.  I told

15     him, Listen, I will go to Sid and I came to Sid with only one sole

16     objective and that was to try to prevent some major casualties from

17     occurring or from some put up conflicts or clashes from breaking out.

18        Q.   At the time, what was General Nenezic?  What was his rank?

19        A.   Well, he was retired.  He was retired.  However, every Friday he

20     would go to see Milosevic.  Well, I don't know Milosevic had a couple of

21     these generals in an advisory role.  I don't know exactly.  Well, for

22     consultations and things like that, and he told me openly, You know this

23     is not some kind of mystique surrounding this whole area.  So when

24     this -- when I was there when he would come back from Milosevic, he would

25     call me and then he would tell me everything that was discussed.  And on

Page 660

 1     one occasion he came and he told me the Vozd, the ruler is very

 2     dissatisfied.  The situation is not very good at all and then he

 3     mentioned all the problems, the situation, and then he said and I told

 4     him that I have a man who can resolve these matters.  I'm literally

 5     retelling you the conversation between us.  There was no influence on my

 6     behalf, no urging or anything like that.

 7             And then when he asked who, I told him about you, and he just

 8     laughed and didn't say anything.  And he would always stress to me, I

 9     always treat you as my protege but I never push you.  It's your decision

10     whether you want to do something or not.  So these were my relationships

11     with people.

12        Q.   And when did you have this conversation with General Nenezic

13     before you went to Sid?

14        A.   Yes, before I went to Sid.  I cannot give you an exact date.  I

15     simply couldn't remember everything, dates, you know.  But this was just

16     before.  After that, I went to see General Simovic.  Are you interested

17     in --

18        Q.   You talked about that in your statement.

19        A.   Well, I don't want to take your time, but I can just continue.

20        Q.   At the time when you talked with General Nenezic, do you remember

21     how old he was, what is his state of health?

22        A.   Well, he was an elderly man.  And he wasn't in the best of

23     health.  However, he was very down and he was very much affected by the

24     situation.  He was very unhappy because of the situation in the region,

25     and he always used to say all the people that I had contacts with, yes,

Page 661

 1     they were members of the party, but they were not Communists.  He would

 2     always be saying, Why are they still holding on to these Communists?

 3     They are an anathema to the whole world but they're still propagating

 4     these political beliefs and trying to spread them.  This is what he said.

 5        Q.   When General Nenezic said that in this alleged conversation with

 6     Milosevic that he had a person who could resolve the situation and

 7     suggested yourself, do you know what he was thinking of?  In what way

 8     could you resolve the situation?  General Nenezic knew some of your

 9     positions your views?

10        A.   All of them.

11        Q.   So are you able to tell us how was it exactly that you were

12     supposed to resolve the situation then in October 1991?

13        A.   Then I have to go back to General Simovic and then that would be

14     the answer to this.  And then he asked me he said, Do you want to go to

15     General Simovic?  The agreement was that he should be in charge of the

16     cadre policy for that area.  Of course I cannot refuse him everything.  I

17     said, All right, I will, and he was even surprised.  And he said, You

18     really want to?  I said, Yes, in an hour I'm going to be at

19     General Simovic's.

20        Q.   I'm sorry to interrupt you.  Why was he surprised?

21        A.   Because I never wanted nobody and I never wanted to listen to

22     anybody and he was really pleasantly surprised.  And I already told you

23     that in the end I actually agreed to do that only because of him.

24        Q.   Just one moment.  Since we're already on this topic, in other

25     words, he didn't even expect that you would accept something like that;

Page 662

 1     is that right?

 2        A.   That's right.  I set aside that hour on purpose to prepare the

 3     situation at General Simovic's, and I know.  I will explain my reasons.

 4     So in one hour I was in front of the government building, and I came to

 5     General Simovic directly to his desk without any controls.  I mean even

 6     the door was open.

 7        Q.   Just for the transcript, could you please tell us what was

 8     General Simovic's position at the time?

 9        A.   He was the defence minister, the minister of defence.

10        Q.   Of Serbia or of Yugoslavia?

11        A.   Of the FR Yugoslavia, Yugoslavia.  But actually he, a sinner,

12     wanted to make a Serbian Army while he was in the post of the minister of

13     defence of the Yugoslavia, but this is a different situation.  General

14     Simovic was sitting at his desk surrounded by a lot of papers.  There was

15     a conference table behind him of some 10 to 12 chairs and there was a

16     person sitting at the table and he said to me, In 15 minutes I have to

17     send a report to the president, so can you please talk to this man here.

18     I told him, General, sir, I came to talk to you, and if you don't have

19     time, I'm sorry, but I don't have time either.  The gentleman who was

20     sitting behind him said to me, How can you be talking to the General like

21     that?

22             I said, I'm sorry, I was very polite, I don't know what your role

23     is here.  He said, Well, I'm his adjutant.  I said, I'm sorry, but

24     adjutants are not at my level.  And then he said, You think that we don't

25     know what it is that you want.  It's all clear to us.  I told him, Look,

Page 663

 1     listen --

 2        Q.   Excuse me for interrupting, but when he said, What it is that you

 3     want, did he mean you personally or a group that you were representing?

 4        A.   He meant me personally.  Let me explain.  This person was Zvonko,

 5     Milosevic's advisor.  Milosevic had two advisors.  Well, fine leave it

 6     be.  I'll remember later on.  It was a person from Kosovo.  And I said to

 7     him, You know something?  I'm surprised frankly you know what everybody

 8     else wants you just don't know what it is you want yourself.  So I stood

 9     up and left.  As simple as that.  Having conducted a conversation like

10     that, do you think you can be entirely safe?  Secondly, within that one

11     hour that I was there Milosevic had dispatched Zvonko his advisor to be

12     there, and there wasn't much that I could offer.  I was always one to

13     offer solutions, but simple ones.  It -- it wasn't about any great

14     mysteries, you know.  These are matters that could have been resolved

15     after talking for no more than 15 minutes.

16        Q.   But could you please share that with us?  What exactly did you

17     tell General Nenezic so that he then put your name forward to Milosevic

18     as the man who could take care of the situation?

19        A.   It's not that I told him anything.  He knew the whole situation.

20     He knew all the people there, what they were doing, where they were

21     going.  It's not like he needed me to tell him or indeed to advise him.

22     He was looking into those things.  He knew.  The KOS has a thousand

23     different services.  It's hard to tell them apart.  It's hard to know

24     who's doing what.  Who knows.  But every day the KOS, every morning

25     receives a report from the people out in the field.  Colonel Djokovic

Page 664

 1     gets these reports submitted every day, local reports, about certain

 2     localities so he reads these and I'm able to guess the actual locations

 3     for each and every one of these reports and he said, You're totally

 4     insane.  How can you know these things?  And I said, Well, I know the

 5     situation.  But one thing that I can tell you is they had all the info.

 6     They knew exactly what was going on.

 7        Q.   It's not information that I had in mind.  I was more wondering

 8     about the solutions.

 9        A.   But you're asking me why did he do that and how could he know

10     that.  It was based on the information that he had and that's what he

11     based his recommendation on.

12        Q.   We'll not discuss this at length because we know about these

13     events at Plitvice.  We know about your arrest and Goran Hadzic's arrest

14     on the 1st of March, 1991.  We know that the Croatian police gave you

15     very rough treatment, both you and Goran Hadzic, and both of you were

16     actually injured as a result of the treatment you received on the hands

17     of the Croatian police.  What I want to know is did you receive any

18     treatment for those injuries?

19        A.   We were not arrested at Plitvice.  What you call an arrest was

20     not really an arrest.  We were ID'd.  I told them who we were and what we

21     were doing, and they clearly said to us that we were the target of their

22     attack.  I had been listening in on the co-ordination conducted by the

23     police officers on the one hand and the centre on the other, and at one

24     point the centre asked that we should be sent back.  It was a decision

25     taken by someone or other, and we said, Okay, let's be off a bit sooner.

Page 665

 1     So this was mistreatment, mistreatment of which I was the target.  And

 2     Goran Hadzic could tell, because they said, Don't touch this guy, touch

 3     the fat one, the other one over there, which I found a bit ridiculous but

 4     there you go.  I was able to neutralise any consequences of this attack

 5     because I was mentally prepared for this you see.

 6             All this harassment, all these blows that I received, all I was

 7     trying to do was to remain standing and remain conscious.  It was -- in

 8     the morning it was cold so I was trying to take in as much oxygen as I

 9     could with my mouth wide open.  So I did all of this preemptively to do

10     what I could to withstand.  I survived the mistreatment.  Once the

11     peaceful integration had been completed and when doctors arrived at the

12     Vukovar Hospital, I went to see an ear, nose and throat specialist.  I

13     had some medical documentation from the military hospital in Belgrade,

14     but I wanted to have something official, black and white, from the

15     Vukovar Hospital as well.  There was a young doctor there ear, throat,

16     and nose, he said, Let's take this one step at a time.  So he looked at

17     my nose and he said, Jesus Christ what have you been through?  And I

18     said, Why?  And he said, Everything inside your nose is shattered.

19     Nothing is really in its place.  Nothing is where it belongs, and then I

20     explained briefly just to spare him any lengthy explanations whereupon he

21     drew up a two-page report, medical report detailing his medical

22     examination and explaining everything that he found.  The next time I was

23     there the doctor was gone and I said what became of that doctor and he

24     said he got a transfer.  So I no longer went.  I should assume that he

25     had been transferred because of that report, although it's not something

Page 666

 1     that he did because I pushed him to do it.  It was a matter of simple

 2     ethic for him to write up that report I expect.

 3             As far as the physical aspect is concerned, you know I try to

 4     keep in shape and I generally look after myself.

 5        Q.   You believe that the doctor was transferred because he wrote up

 6     that report for you about your injuries; right?

 7        A.   Who else could it possibly have been?

 8        Q.   And what do you think?  You say that you were not arrested at

 9     Plitvice, and you say that you of all people were the target of that

10     particular attack, you Boro Savic, as opposed to Goran Hadzic.

11        A.   Well --

12             THE INTERPRETER:  Could the witness please be asked to repeat his

13     answer.  Interpreter's note.

14             JUDGE DELVOIE:  Mr. Savic, the interpreters asked that you repeat

15     your answer.  Could you do that?

16             THE WITNESS: [Interpretation] What am I supposed to interpret?

17     Can they tell me what they want from me?

18             JUDGE DELVOIE:  You're certainly not asked to interpret anything,

19     Mr. Savic.  You -- I suppose it's about the last question -- it's about

20     the last question Mr. Zivanovic -- yes, Mr. Zivanovic.  Can you assist?

21             MR. ZIVANOVIC: [Interpretation]

22        Q.   I'll repeat the question:  Why do you think that you of all

23     people were the target of that attack and not Mr. Hadzic?

24        A.   Yes.  As I said, because of my peace-related activities and

25     views.  The people who were more desirable at the time were aggressive

Page 667

 1     people who would taunt others which would eventually lead to conflict.

 2     And there were such people around.  As for the action at Plitvice,

 3     Ilija Sasic and Veljko Dzakula knew about this.  They were with us at the

 4     Obrovac meeting because we arrived at Plitvice directly from Obrovac.

 5     And then they left through Bosnia.  But I always took the main roads.  So

 6     we drove back through Plitvice, and we all know what happened.  Other

 7     than that, there was no excuse for that to cause for something like that

 8     to happen.  We weren't there to taunt anyone.

 9        Q.   You say that Mr. Dzakula and Sasic knew about the action or the

10     operation.  Which action?  Something that was done by the Croatian side

11     or the Serb side?

12        A.   The activities at Plitvice.  That's what they knew about.

13        Q.   You mean the action by the Croatian police?

14        A.   Yes.  Yes.  That's what I mean, and that's all I could possibly

15     mean because there was nothing else happening apart from that, the police

16     action taken at Plitvice.

17             MR. ZIVANOVIC:  When do you wish to finish?

18             JUDGE DELVOIE:  This is the moment Mr. Zivanovic.

19             MR. ZIVANOVIC:  Thank you, Your Honour.

20             JUDGE DELVOIE:  So if it's appropriate for you, we will excuse

21     the witness now.  Mr. Witness -- Mr. Savic, as you are aware of, your

22     testimony did not come to an end, so you will be back in the Tribunal but

23     in another courtroom, but it will be no problem, tomorrow morning at

24     9.00.  I have to warn you that in the meantime, you are not allowed to

25     speak to anybody about your testimony, and you're not allowed to speak in

Page 668

 1     generally -- in general, sorry, with any of the parties as long as your

 2     testimony is not ended.  Do you understand?

 3             THE WITNESS: [Interpretation] Yes, I do.  Thank you.

 4             JUDGE DELVOIE:  Thank you very much.  The usher will escort you

 5     now.

 6                           [The witness stands down]

 7             JUDGE DELVOIE:  We reconvene tomorrow morning at 9.00 in

 8     Courtroom II, if I'm not mistaken.  Court adjourned.

 9                           --- Whereupon the hearing adjourned at 6.30 p.m.,

10                           to be reconvened on Wednesday, the 31st day

11                           of October, 2012, at 9.00 a.m.