1 Tuesday, 2 May 2006

2 [Open session]

3 [The accused entered court]

4 --- Upon commencing at 2.26 p.m.

5 JUDGE MOLOTO: Before we call the witness, maybe just one little

6 point to look at. There was an application, if I can find my glasses, by

7 the Prosecution, on the 25th of January 2006, to admit certain statements

8 in terms of Rule 92 bis. You will recall that the statement of M-28 was

9 sent back for the Prosecution to make certain corrections on it. The

10 Chamber is now ready to make the order in relation to the original motion

11 and the subsequent motion.

12 I'm going to read the order. It's an oral order.

13 The Trial Chamber will now render its decision on both the

14 Prosecution's motion for the admission of the statement of Witness MM-028

15 of the 25th of January 2006, and its subsequent motion for the admission

16 of additional statement of MM-028 pursuant to Rule 92 bis of the 30th of

17 March 2006.

18 2: The Trial Chamber considers that the Prosecution has complied

19 with the Trial Chamber's oral ruling of the 15th of January -- I beg your

20 pardon, 15th of February 2006 and that the Prosecution has demonstrated

21 sufficient reliability of the documents associated with the original

22 statement of Witness MM-028. The original statement of Witness MM-028 and

23 the documents associated therewith are admitted into evidence.

24 3: The Prosecution also seeks the admission pursuant to Rule 92

25 bis of an additional statement of witness MM-028 including attached

1 documents. The Trial Chamber recalls its decision of the 16th of January

2 2006 wherein it set out the applicable law pursuant to Rule 92 bis. The

3 Trial Chamber considers that the additional statement does not go to the

4 acts or conduct of the accused, that the original of the documents is

5 identified by the witness in the additional statement and that the

6 documents refer to events relevant to this case.

7 The Prosecution's motion is granted and the additional statement

8 and the attached documents are admitted pursuant to Rule 92 bis.

9 4: The Trial Chamber requests the Registrar to assign exhibit

10 numbers to the two statements of Witness MM-028 and the documents attached

11 to them.

12 Thank you very much. Mr. Whiting?

13 MR. WHITING: Thank you, Your Honour. If I might first take the

14 occasion briefly of Your Honour's return to express the Prosecution's

15 deepest condolences for Your Honour's loss.

16 JUDGE MOLOTO: Thank you very much.

17 MR. WHITING: We are deeply sorry for that.

18 JUDGE MOLOTO: Thank you.

19 MR. WHITING: To pass from the profound to the banal, if I might

20 deal with one other housekeeping matter which is Exhibit number 241, if

21 Your Honours will recall, this is an exhibit that came up, was offered by

22 the Defence, was going to be used by the Defence during the

23 cross-examination of Witness Milan Babic, as I recall. In any event it

24 was an exhibit for which there was no translation into English. And the

25 Court asked if the Prosecution would undertake having that document

1 translated.

2 The document has been translated. The translation is now

3 available in e-court. The exhibit was marked for identification. I

4 believe it's the only remaining -- it may be the only remaining document

5 that's marked for identification at this point. I don't know if the

6 Defence seeks its admission into evidence but if it does, the Prosecution

7 would have no objection to that.

8 JUDGE MOLOTO: Thank you very much, Mr. Whiting.

9 Mr. Milovancevic, any comments?

10 MR. MILOVANCEVIC: [Interpretation] Yes, Your Honour. First of

11 all, I wish to take this opportunity, Your Honour, on the occasion of the

12 tragedy that has befallen you and your family to express the deepest

13 condolences of the Defence team.

14 JUDGE MOLOTO: Thank you very much, Mr. Milovancevic.

15 MR. MILOVANCEVIC: [Interpretation] With respect to this document,

16 we tender it into evidence, Your Honour.

17 JUDGE MOLOTO: Thank you very much, Mr. Milovancevic. Then the

18 document will be admitted into evidence. And may it please be given an

19 exhibit number that was given Exhibit number 241 for identification.

20 I guess it will retain the number 241.

21 THE REGISTRAR: It will be Exhibit number 241, Your Honour.

22 JUDGE MOLOTO: Thank you very much.

23 Mr. Whiting?

24 MR. WHITING: Your Honour, Mr. Black will be handling the next

25 witness so I now defer to him.

1 JUDGE MOLOTO: Mr. Black?

2 MR. BLACK: Thank you, Your Honour. The Prosecution will now call

3 our next witness, Mr. Rade Raseta.

4 [The witness entered court]

5 JUDGE MOLOTO: May the witness please make the declaration.

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

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

8 WITNESS: RADE RASETA

9 [Witness answered through interpreter]

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

11 MR. BLACK: May I proceed, Your Honour?

12 JUDGE MOLOTO: You may proceed, Mr. Black.

13 MR. BLACK: Thank you very much.

14 Examination by Mr. Black:

15 Q. Good afternoon, Colonel. Can you understand me in your own

16 language?

17 A. Good afternoon. Yes, I can.

18 Q. If at any time you have difficulty understanding one of my

19 questions, please just tell me and I'll try to state it more clearly. Do

20 you understand that?

21 A. Yes, I understand you.

22 Q. Colonel, I'll begin with a few questions about your personal and

23 professional background. First, could you please state your name for the

24 Trial Chamber?

25 A. My name is Rade Raseta, and I'm a retired colonel.

1 Q. Were you born in Donji Lapac, Croatia, in 1947?

2 A. Yes, I was.

3 Q. And although you were born in Croatia, you were ethnically Serb;

4 is that correct?

5 A. That's correct, yes.

6 Q. Could you please briefly describe your education and your

7 professional posts up until the year 1993?

8 A. After completing primary school in the place of my birth, I

9 continued my education in the school for non-commissioned officers for

10 armoured units of the JNA and I graduated from there in 1964.

11 After I completed the secondary military school, I was sent to

12 serve in Skopje in the Republic of Macedonia.

13 From 1964 until 1975, I performed all troop command duties at a

14 lower level, commandeer duties, and in 1977 I passed an exam to become an

15 officer and I was promoted to commissioned officer status as second

16 lieutenant. In 1975, I was accepted in the security service of the JNA,

17 and in that same year, I was sent for training and education. In 1976, I

18 completed the training course for security. In the security services I

19 performed the following duties: I was chief of the security organ in the

20 command at brigade and regiment level. I was an officer in the division,

21 at the division level, for security. Then I was an officer in the

22 counterintelligence group of the army command. I was the chief of the

23 information analysis department in the army command, chief of the

24 information analysis department in the security department of the Main

25 Staff of the Serb Army of Krajina, chief of the security department of the

1 Main Staff of the Serb Army of the Krajina. In the Republic of Serbian

2 Krajina, I served from October 1993 until the second half of August 1995.

3 After the fall of the Krajina, at my own request, and because I fulfilled

4 the conditions for retirement, one of the conditions, on the 1st of

5 January 1996, I retired. That is it very briefly.

6 Q. Thank you, colonel. Just a couple of questions about what you've

7 just told us. Where did you serve between, let's say, 1975 and 1992? In

8 what location?

9 A. Throughout this time, I was in the Republic of Macedonia, in the

10 Kumanovo garrison and in Skopje.

11 Q. Did you change location in 1992?

12 A. Yes, I did. After the break-up of the SFRY, the command of the

13 army was relocated from Skopje to the Nis garrison. I was there from 1992

14 until I left for the Krajina in October 1993.

15 Q. Thank you very much, colonel.

16 Now, I'll ask you some questions about how you came to serve in

17 the army of the Republic of Serbian Krajina, known as the SVK. First of

18 all, did you volunteer to serve in the SVK?

19 A. To the SVK, I went under orders from the chief of the General

20 Staff of the army of the FRY, General Perisic. He sent me there to serve

21 on a temporary basis for up to one year.

22 Q. Just so I understand, did you volunteer for that position or you

23 were simply assigned?

24 A. No, I did not volunteer. I was assigned. I was issued an order

25 from the chief of the General Staff.

1 Q. And another question to make sure it's clear, did you leave the

2 Yugoslav army, the VJ, in order to serve in the SVK or did you remain in

3 the service of the Yugoslav army?

4 A. I retained the status of an officer of the VJ with all the

5 entitlements. For example, my family received my salary on my personal

6 account and in the Republic of Serb Krajina we had certain privileges.

7 For example, we were paid 15 per cent on our salary as a kind of hardship

8 allowance, and also our time of service there was counted double for

9 pension purposes. Those were the benefits we received.

10 Q. Who was it who paid your salary? Was it the Yugoslav army or the

11 army of the Republic of Serbian Krajina?

12 A. It was the Yugoslav army.

13 Q. Can you give us an idea of how many VJ officers, including

14 yourself, were serving in command positions in the SVK while you were

15 there in 1993, 1994 and 1995?

16 A. I can't tell you the precise number but approximately it was

17 between 150 and 200 officers in leading positions.

18 Q. Were these officers originally from the territory of the RSK or

19 not necessarily, do you know?

20 A. For the most part, an effort was made to have them from the RSK,

21 originally from there, or to have people who were born in the Republic of

22 Croatia. Someone might have been born in the Republic of Croatia but not

23 in the RSK. However, if he was an ethnic Serb, he could have been

24 assigned to work on a temporary basis in the Republic of Serb Krajina.

25 Q. That leads to my next question. What was the ethnic makeup of

1 this group of VJ officers serving in the SVK?

2 A. For the most part, the officers who were sent like me to work

3 there on a temporary basis were ethnic Serbs. There were, however, a few

4 officers, a small number of other ethnicities. I know about one Muslim,

5 one Macedonian and so on, who happened to be there.

6 Q. Do you know if these other officers, other than yourself, did they

7 volunteer to serve in the SVK or were they simply assigned, as you were?

8 A. According to my personal estimate, there were 20 or 30 per cent of

9 these officers who volunteered. All the others were sent there under

10 orders from the General Staff, like myself.

11 Q. And finally on this topic, was there a standard duration for

12 service in the SVK, a standard amount of time that you were sent there

13 for?

14 A. This was a time period of up to one year. Following the expiry of

15 which, everyone was entitled to return to the Federal Republic of

16 Yugoslavia. However, under the proviso that one applied for it in writing

17 and then some of these applications would be granted, others were not.

18 Q. You yourself served in the SVK for more than one year. How did

19 that happen in your case?

20 A. It happened the following way. After the expiry of my service

21 there, the department itself, the service, requested that I remain and my

22 commander, General Celeketic, insisted that I stay for a further period of

23 time.

24 Q. Colonel, now I'm going to change topic slightly and I'll ask you

25 some questions about your duties in the SVK security organs. First, you

1 briefly covered this when you told us about your professional positions

2 but please remind me which positions you held during the time you were in

3 the SVK.

4 A. On my arrival in Krajina, for one year I was chief of the

5 information analysis department of the security administration of the Main

6 Staff. This was the period up to December 1994. When my immediate

7 superior chief went to Belgrade, the commander of the Main Staff ordered

8 that I become chief of security of the Main Staff and I accepted that duty

9 on the 19th of December 1994 and I continued performing the duty until

10 such time as I left Krajina.

11 Q. Thank you, Colonel. Can you describe generally the tasks of the

12 SVK security services while you were there, while you served there?

13 A. For the most part, the duties stemmed from the duties held by the

14 security service of the army of the Federal Republic of Yugoslavia. First

15 of all, the service performed the duties aimed at monitoring and

16 intercepting the activities of the other foreign services and the adequate

17 services in the SVK were informed accordingly. Secondly, the preventive

18 activities, prevention of internal destructive forces in the SVK forces

19 aimed at undermining the morale and the combat readiness of the units.

20 Crime prevention, for the most part dealing with the crime against the

21 commands and units of the army, namely theft of combat hardware,

22 explosives and other type of weaponry. We also took part in drafting

23 regulations and rules of security, preventive measures, which were sent on

24 to the commands of units. We also administered units of the military

25 police, and lastly we organised and carried out cooperation with UNPROFOR

1 and other international institutions and organisations stationed in

2 Krajina, but only so far as the personal and collective security and

3 safety was threatened as far as there were attempts to misappropriate army

4 resources and so on. Generally speaking, these were the duties that the

5 service dealt with.

6 Q. And what were your own duties with relation to those tasks, first

7 as the head of the information analysis section and subsequently as head

8 of the entire security services of the SVK Main Staff?

9 A. As the head of the information analysis, I received all the

10 information, whereupon I analysed and examined the information, drafted

11 documents and proposed measures to the chief aimed at improving and

12 ensuring the execution of the duties that I have just mentioned.

13 When I assumed the duty of the chief of security, I managed the

14 entire service and dealt with intelligence -- the security issues in the

15 SVK but not only in the Main Staff. I also worked with the lower-ranking

16 security services directly involved in combat.

17 Q. Colonel, you mentioned crime prevention. Did your duties or the

18 tasks of the security organs also include the investigation of war crimes?

19 A. To my knowledge, for the duration of my stay there, there was a

20 team dealing with war crimes. I know that Savo Strbac headed the team and

21 out of the security department, Colonel Suput was involved in these

22 activities. Periodically, I was informed by my subordinates on the

23 results of their work, and as far as I remember, war crimes committed

24 against Serbs by Croat forces were being investigated. I don't remember

25 the specific cases at hand, but I do know that this was the procedure.

1 Q. Do you remember any cases of war crimes committed by Serb forces

2 against Croat forces being investigated or reported?

3 A. For as long as I was there in Krajina, this was not the case.

4 Q. And why do you think that was? Why do you think there were no

5 reports of such crimes?

6 A. I don't know. My personal opinion is that there was no wish to do

7 so. Based on what I learnt previously, there must have been such crimes

8 and there must have been space there for these crimes to be investigated.

9 Why this was not done, I cannot say, but I am certain that there were

10 instruments in place to investigate crimes on both sides.

11 Q. Colonel, from whom did you receive your orders when you were head

12 of the SVK security organs?

13 A. I received orders solely from the commander of the Main Staff,

14 General Celeketic and later on General Mrksic. However, from time to time

15 I received tasks from the then president, Milan Martic.

16 Q. About how many times did you have direct interaction with

17 Mr. Martic?

18 A. I had about ten contacts with President Martic. Some of these

19 were on my initiative and some on the initiative of the then president.

20 Q. And what tasks or topics were discussed on those occasions, if you

21 remember?

22 A. The advancement of the security service of Krajina was discussed,

23 namely the ways of unifying the service. Regardless of who headed the

24 service, there was time -- this was the time for the service to be brought

25 under one chapeau, as it were.

1 Furthermore, there were criminal activities taking place. For

2 instance, fuel tankers arriving from the Republic of Serbia were being

3 misappropriated, on their way from Republika Srpska to the RSK. I

4 remember well that once 16 fuel tankers and trucks with barrels entered

5 the country and president Martic ordered that we -- that I establish the

6 department of the military police and receive the convoy at Raca border

7 crossing. I did as I was ordered. However, the column was intercepted by

8 some armed, unidentified persons who disarmed my military policemen, and

9 these tankers went somewhere, nobody knows where. Only three of these 16

10 tankers actually reached the Main Staff of the RSK. This was one such

11 assignment.

12 I remember another such assignment when Captain Dragan

13 Vasiljkovic - I don't know where this took place, I can't remember - stole

14 some boat engines and then put them on a trailer-truck. There were some

15 other equipment there too but the engines were easy to be seen because

16 they were new and they were moth-balled, and he tried to take them to the

17 Republic of Serbia. However, I informed General Celeketic thereof. He in

18 turn informed Mr. Martic, and our president intervened through Milosevic.

19 Milosevic said that the convoy should be allowed to proceed towards Serbia

20 and that his men were to wait for the convoy there.

21 I also interacted with him when I was supposed to secure the

22 presidential palace where he worked. It was my guard that had to deal

23 with the security issues, and that was the one occasion when I had

24 contacts with him.

25 There were other such contacts but I can't remember them now.

1 Q. Thank you, colonel. Did Mr. Martic ever say anything to you about

2 his attitude towards Croats in general?

3 A. He did. On one occasion, I can't remember what this contact was

4 about, I remember him telling me that he could not be a nationalist, he

5 could not make himself hate Croats. He even told me that once he

6 completed the MUP school, his first service entailed him staying at the

7 home of Croats with whom he continued being in touch, even at that date.

8 He told me whoever was saying that I was a nationalist and hated Croats

9 was wrong. And I believed him.

10 Q. Were Martic's actions in 1994-1995 consistent with what he'd told

11 you, in your view?

12 A. I don't know which actions you have in mind.

13 Q. Just in general. Any actions. Did you feel like Mr. Martic acted

14 in accordance with what he told you, as you just explained to us?

15 A. Are you referring to the period of 1994 and 1995 or --

16 Q. Yes, yes, the entire time you were there.

17 A. Well, one could not put it that way, in view of the measures taken

18 against the Croat side. For instance, the shelling of Zagreb, then the

19 order to fire upon Sisak and some other towns, in the wake of Operation

20 Flash. Perhaps there were other such attacks. This went to directly

21 contradict Mr. Martic's statement concerning his attitude towards Croats,

22 if I've understood your question well.

23 Q. Yes, I think you understood my question. Let me change topics

24 slightly and ask you if there was any formal or informal collaboration

25 between the SVK security organs and the RSK minister -- Ministry of the

1 Interior while were you chief of the security organs.

2 A. That cooperation was pretty weak. We were in touch. However, the

3 tasks we agreed upon were never really carried out. In other words, there

4 were contacts but there was no cooperation.

5 MR. BLACK: Your Honour, could we go very briefly into private

6 session, please?

7 JUDGE MOLOTO: May the Chamber please move into private session.

8 [Private session]

9 (redacted)

10 (redacted)

11 (redacted)

12 (redacted)

13 (redacted)

14 (redacted)

15 (redacted)

16 (redacted)

17 (redacted)

18 (redacted)

19 (redacted)

20 (redacted)

21 (redacted)

22 (redacted)

23 [Open session]

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

25 JUDGE MOLOTO: Thank you very much.

1 You may proceed, Mr. Black.

2 MR. BLACK: Thank you, Your Honour.

3 Q. Colonel, now let me ask you about a different topic, about the

4 relations between the SVK and the Yugoslav army during the time that you

5 served in the Krajina.

6 You've already told us about the provision of Yugoslav army

7 personnel, such as yourself, to the SVK. Did the VJ also provide

8 logistical support to the SVK, do you know?

9 A. The army of the Republic of Serb Krajina and the army of the

10 Federal Republic of Yugoslavia were actually one and the same

11 organisation, but positioned at two different locations. Now, why do I

12 say this? In addition to the personnel that was assigned to the Republic

13 of Serbian Krajina at all levels, all the possible logistical support was

14 provided too, starting from fuel, ammunition, weaponry, foodstuffs,

15 quartermasters' supplies, professional support in planning and executing

16 actions, as well as a number of other kinds of support.

17 Q. Well, let me ask you some specific questions on this topic then,

18 about other kinds of support. Was there any similarity in the procedures

19 and methods applied by the SVK security organs and the security services

20 of the VJ?

21 A. No. As a whole our activities were based on the rules and

22 instructions issued by the security administration of the Federal Republic

23 of Yugoslavia. We therefore had the same rules and regulations, the same

24 operations methods, and procedures. There was no difference whatsoever.

25 Q. While you were serving in the SVK security organs, did you report

1 to anyone in the Yugoslav army about your activities?

2 A. Yes. Precisely because of what I've just told you, that we used

3 all the instructions, rules and operations and technical resources and

4 personnel from the security administration of the FRY, we were duty-bound

5 to inform the security administration of all our activities. This was

6 something that I myself had to do, just as all my predecessors.

7 Q. And whom in the VJ did you inform specifically?

8 JUDGE MOLOTO: Inform or report to?

9 MR. BLACK: Thank you, Your Honour.

10 Q. First of all, you've heard Judge Moloto's question. Was this

11 reporting or informing? Was there a difference there?

12 A. Yes, there is. We only submitted reports, or rather we reported

13 on our activities. We were not able to be held answerable for any

14 omissions on our part. I could be punished by Dimitrijevic and General

15 Celeketic, to make this clear. Or rather I could not be punished by

16 Dimitrijevic but by Celeketic only, so therefore we only informed them.

17 But this was the case precisely because we used the rules and instructions

18 and the methods of work employed by the army of the Federal Republic of

19 Yugoslavia. It was for this reason that we were duty-bound to inform

20 them.

21 Q. And you mentioned a General Dimitrijevic, as well as a

22 General Celeketic. Who were those two men, just so we are clear?

23 A. General Dimitrijevic, Aleksandar Dimitrijevic was the chief of the

24 security administration of the army of the Federal Republic of Yugoslavia,

25 and General Celeketic was the Commander of the Main Staff of the Serbian

1 army of Krajina.

2 Q. In your testimony, I believe is that you informed General

3 Dimitrijevic but you didn't report to him in the sense that you were not

4 answerable to him but you were answerable to General Celeketic of the SVK;

5 is that correct?

6 A. That's correct.

7 MR. BLACK: Does that clear it up, Your Honour, or should I

8 proceed?

9 JUDGE MOLOTO: Do we have to understand that it's your evidence

10 that there was nobody in the Yugoslav army to whom you reported?

11 THE WITNESS: [Interpretation] Yes.

12 JUDGE MOLOTO: How, then, do you explain vis-a-vis yourself, the

13 relationship between the VJ and the SVK? You said they are one and the

14 same thing, and you said that logistical support came from the VJ to the

15 SVK. Now, it does seem as if you had no responsibility whatsoever to the

16 VJ but only to the SVK.

17 THE WITNESS: [Interpretation] I was responsible in terms of having

18 to inform them of the way in which the resources were applied and which

19 activities were undertaken. All the information flowed to this one

20 location, and that was the security administration, but I repeat,

21 General Dimitrijevic was not able to apply any sanctions against me. It

22 was only General Celeketic who could do that. However, I still had the

23 obligation to inform him, to report on the activities.

24 JUDGE MOLOTO: The information that you passed on to

25 General Dimitrijevic, were you duty-bound to do so or were you just

1 informing him? I hear you talk of inform instead of report. And what I do

2 want to understand is did you just inform him because you wanted to inform

3 him or did you inform him because you were duty-bound to inform him?

4 THE WITNESS: [Interpretation] I was duty-bound to inform him

5 whenever we applied measures or used the military hardware and personnel,

6 and I'm referring to special hardware. I had to inform him about it.

7 JUDGE MOLOTO: Thank you very much.

8 MR. BLACK: Thank you, Your Honour.

9 Q. Colonel, and maybe you've alluded to this somewhat, but what kinds

10 of information did you forward, let's say, to General Dimitrijevic?

11 A. I don't understand, what kind of --

12 Q. What kind of information -- you've told us how you were duty bound

13 to inform General Dimitrijevic about certain activities or certain issues

14 and I'd like you to tell us what activities or issues those were. Just

15 generally.

16 A. It had to do with the activities where methods of work and

17 resources were used. I believe that this does come under the

18 confidentiality issue. I believe that there are certain issues I should

19 not touch upon. But these were some very specific measures and persons

20 that were involved.

21 Q. I think that's sufficient for our purposes now.

22 JUDGE MOLOTO: If I might just interrupt. To what extent does the

23 confidentiality go? In other words, do I understand the witness to be

24 saying if we went into private session he would disclose or would the --

25 the confidentiality prohibits him from even mentioning those in private

1 session.

2 MR. BLACK: I don't know, Your Honour. Perhaps the witness can

3 give an explanation.

4 JUDGE MOLOTO: Do you understand my question?

5 THE WITNESS: [Interpretation] I hope my answer will be clear.

6 There was a certain number of officers who were being dealt with by the

7 security service in the army of Yugoslavia. These were transferred to the

8 SVK. However, the operative surveillance of these officers continued and

9 they were the ones I was duty-bound to report about to the FRY. I don't

10 recall the names of the officers now but the continuity of surveillance

11 had to be maintained regardless of where they were.

12 MR. BLACK: May I proceed, Your Honour?

13 JUDGE MOLOTO: Thank you. You may proceed.

14 MR. BLACK: Thank you.

15 Q. Colonel, did you have the impression that the information that you

16 passed to the Yugoslavia Slav army and in particular to

17 General Dimitrijevic, was that information received and used? Did you

18 have any impression about that?

19 A. Yes. I did have an impression, in particular the specific cases

20 we've just been mentioning but also all other information of significance

21 to the armed forces, whatever the topic of my reports. Sometimes I was

22 told what further information I had to obtain, and, yes, this information

23 was used in the security administration.

24 Q. Based on your interaction with General Dimitrijevic and maybe

25 others in the VJ, did you form an opinion or an impression of the VJ's

1 position towards Mr. Martic, whether they supported or opposed Mr. Martic

2 or had no position whatsoever?

3 A. He received their full support.

4 Q. Can you explain a little bit what leads you to say that?

5 A. I say that because on one occasion, General Dimitrijevic

6 personally told me, when I was reporting to him in his office, that we

7 should do everything to support President Martic, that he was on the right

8 track, and that he was doing everything in his power for the Serbs in the

9 Republic of Serbian Krajina to survive.

10 Q. What about Milan Babic? Did you have an impression of the VJ's

11 position towards Milan Babic?

12 A. Milan Babic did not enjoy any authority or respect with the army

13 of the Federal Republic of Yugoslavia.

14 Q. And do you have any opinion about where this differing policy

15 towards Mr. Martic and Mr. Babic --

16 THE INTERPRETER: Microphone, please.

17 MR. BLACK: I'll repeat the question because we had a microphone

18 problem.

19 Q. Colonel, do you have any opinion about where this policy

20 originated, the support of Martic and the lack of support for Babic? Did

21 you have an impression at the time as to who was driving this policy?

22 A. The policy supporting Mr. Martic was driven by Mr. Milosevic, and

23 the Federal Republic of Yugoslavia, of course. However, the policy of the

24 Federal Republic of Yugoslavia was not to support Mr. Babic. That's how

25 things were.

1 Q. Do you know if your superiors in the SVK, in particular General

2 Celeketic, or Mr. Martic, knew that you were informing the VJ about your

3 activities?

4 A. I reported to General Celeketic from time to time, as needed. But

5 I did not report to President Martic because he was not my immediate

6 superior at the time. If need be, it was General Celeketic who informed

7 Mr. Martic. I was not duty-bound to report to Mr. Martic directly.

8 Q. You've described now for us the way in which you cooperated with

9 your, let's say your counterparts in the VJ. Do you know if other

10 officers in the SVK Main Staff also cooperated with their counterparts on

11 the VJ General Staff?

12 A. I know that occasionally the assistant commander for logistics,

13 for example, or the assistant commander for morale, or for organisation

14 and mobilisation, or the chief of the intelligence department, would

15 occasionally go to the FRY General Staff for consultations, exchange of

16 information, and so on, and I don't know whether I've answered all of your

17 question. There was, however, communication between the chiefs of these

18 various sectors.

19 Q. Colonel, I'd like to show you a document. It will appear on the

20 screen in front of you in just a moment. The 65 ter number is 1878, if

21 the Court officer can please bring that up on e-court.

22 Are you able to see the document on your screen there, Colonel?

23 Colonel, what is this document?

24 A. This document was compiled in the Main Staff of the Serb Army of

25 the Krajina, and it refers to the daily reporting. It's an order from the

1 Main Staff of the Serb Army of Krajina, saying that combat reports were to

2 be sent to the General staff of the army of Yugoslavia and that they were

3 to contain the information listed below.

4 Q. If we could look at the second page briefly, please, it's the

5 second in both B/C/S and English, colonel, can you see who signed this

6 order?

7 A. This order was signed by the then commander of the Main Staff,

8 Brigadier General Mile Novakovic.

9 Q. Do you know if this order was in fact implemented?

10 A. This order was drawn up at about the time when I arrived in the

11 Krajina, but at that time, I was not able to contact the commander of the

12 Main Staff and his assistants in view of the nature of my work. But when

13 I was chief of the security organ of the Main Staff, this kind of

14 reporting continued. These issues listed here were those on which regular

15 reports were sent to the Main Staff, army of Yugoslavia.

16 Q. What if anything does this tell us about the relationship between

17 the SVK Main Staff and the General Staff of the VJ?

18 A. Well, this shows that there was almost a relationship of

19 subordination of the SVK Main Staff towards the General staff of the army

20 of Yugoslavia. They had the obligation imposed upon them to send combat

21 reports. The Main Staff of Yugoslavia imposed the obligation on the

22 General Staff of the SVK to send them these reports.

23 MR. BLACK: Your Honour, I would offer this document into evidence

24 and ask that it be assigned an exhibit number, please.

25 JUDGE MOLOTO: The document is admitted into evidence. May it

1 please be given an exhibit number.

2 THE REGISTRAR: It will be Exhibit 456, Your Honour.

3 JUDGE MOLOTO: Thank you very much.

4 MR. BLACK: Thank you, Your Honour.

5 Q. Just one very, very short topic before we take the next break.

6 Colonel, do you know -- this is a slight change of topic, but do you know

7 if there was any formalised exchange of information between the SVK

8 security organs and the security organs of the Bosnian Serb army, the VRS?

9 A. I'm not sure about the time before I became chief of the security

10 organ of the Main Staff. However, from that time, I attempted to

11 establish cooperation with the then general, Zdravko Tolimir, but I was

12 not successful in this. He was not in favour of cooperation.

13 MR. BLACK: Your Honour, I'm about to start another topic.

14 Perhaps it would be a convenient time for the break.

15 JUDGE MOLOTO: It's a convenient time for the break. Shall we

16 take a break and come back at 4.00?

17 Court adjourned.

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

19 --- On resuming at 4.02 p.m.

20 JUDGE MOLOTO: Mr. Black?

21 MR. BLACK: Thank you very much, Your Honour.

22 Q. Colonel Raseta, we've been discussing cooperation and I'm going to

23 move to a new topic in just a moment but there are actually one or two

24 questions I'd like to ask you before we change topics.

25 We've been speaking mostly about the military but do you know if

1 members of the police of the Republic of Serbia served in the RSK police

2 in the same general way that you, as a member of the VJ, served in the

3 SVK?

4 A. I did not observe that.

5 Q. And as the head of the SVK security organs, did you cooperate with

6 any officials from the police of the Republic of Serbia on the territory

7 of the RSK?

8 A. When Mrksic was appointed commander of the Main Staff on the 18th

9 of May 1995, he introduced me to the state security organ from the Federal

10 Republic of Yugoslavia, whose name was Milan Knezevic, who had arrived to

11 unify all the security services in the Krajina. He's the only organ I

12 know of.

13 Q. And you say that Mr. Knezevic belonged apparently to the state

14 security organ of the FRY. Could you just explain to me whether that's a

15 military or police position?

16 A. That is a civilian post, or a police post. It doesn't belong to

17 the military service.

18 Q. Thank you for the clarification.

19 Colonel Raseta, now I'm going to turn to --

20 JUDGE MOLOTO: Can I just clarify one thing? I'm going to ask you

21 the same question but in relation to a different police force. Did you,

22 in your capacity as a chief in the SAO Krajina, cooperate with the police

23 of the SAO Krajina at all?

24 THE WITNESS: [Interpretation] Let me repeat. We did have

25 contacts, but not cooperation. Not the kind of cooperation envisioned in

1 our former instructions.

2 JUDGE MOLOTO: What kind of contact did you have with the SAO

3 Krajina Police?

4 THE WITNESS: [Interpretation] I had contacts with the

5 representatives of the MUP and the State Security in order to further

6 mutual cooperation. This is what President Martic insisted on at the

7 time. However, we would get together and agree on joint tasks and then

8 nothing would happen. It would all fail to materialise.

9 JUDGE MOLOTO: But do I understand you to be saying that you had

10 this contact to agree on joint tasks at the insistence of Mr. Milan

11 Martic?

12 THE WITNESS: [Interpretation] That's correct, yes.

13 JUDGE MOLOTO: Thank you.

14 JUDGE NOSWORTHY: Before we move on, I just want to get it on the

15 record, the witness has referred to the state security organ and he has

16 spoken of a Milan Knezevic. What office did this person hold? Because I

17 see a reference to chief security organ which would tend to refer to a

18 body. What was his actual office? You have told us what his duties were,

19 what he was attempting to do but can I hear what office he held, please?

20 THE WITNESS: [Interpretation] I don't know his precise office, but

21 he was introduced to me as a representative of the State Security Service

22 of the Federal Republic of Yugoslavia, who had been sent to the Krajina, I

23 assume by Jovica Stanisic, to coordinate and unify the work of all State

24 Security Services and the Military Security Services of the territory of

25 the Republic of Serb Krajina.

1 JUDGE NOSWORTHY: Thank you so much.

2 MR. BLACK: Thank you, Your Honours.

3 Q. Colonel Raseta, now I'm going to ask you to turn to another topic

4 and that's command and control within the SVK. First of all, can you

5 explain what the RSK Supreme Defence Council was?

6 A. The RSK Supreme Defence Council was the highest body commanding

7 the armed forces in the republic. It consisted of the president,

8 Mr. Milan Martic, who was also the Commander-in-Chief, then

9 General Celeketic, who was the commander of the Main Staff, the Minister

10 of Defence, the Prime Minister, the speaker of parliament when needed, the

11 Minister of the Interior. These people were the members of the Supreme

12 Defence Council.

13 Q. You may have mentioned this in your previous answer, but who was

14 the Supreme Commander of the SVK?

15 A. The Supreme Commander was Mr. Milan Martic.

16 Q. Was Mr. Martic the de jure Supreme Commander or the de facto

17 Supreme Commander of the SVK or both?

18 A. Both de jure and de facto, both.

19 Q. Could you explain a little bit your basis for saying that he was

20 the de facto commander of the SVK? Supreme Commander, I mean.

21 A. Well, this was provided for by the constitution. That's the first

22 thing. And secondly, at the proposal of the Commander of the Main Staff

23 on the use of the armed forces of the Republic of Serbian Krajina, a

24 decision would be made and issued by the President of the republic. All

25 operative work was done by the Main Staff, but it was the president of the

1 republic who gave his blessing, and who also issued the decision on the

2 use of the armed forces.

3 Q. What was Mr. Martic's role in the Supreme Defence Council?

4 A. To command the armed forces.

5 Q. Is there anything more specific that he did in the meetings of the

6 Supreme Defence Council?

7 A. I'm not sure I understand your question.

8 Q. Let me ask it in a different way. Who presided over the meetings

9 of the Supreme Defence Council?

10 A. The president of the republic, Milan Martic.

11 Q. How would you characterise Mr. Martic's knowledge of military

12 matters, or his understanding of military matters?

13 A. The president of the republic, Milan Martic, did not know -- he

14 did not have the same knowledge about the use of the armed forces that

15 professional soldiers have, but that's why he had the chief of the Main

16 Staff and other military men who made proposals to President Martic about

17 the use of the armed forces. It was up to him to hear them out and then

18 to either agree or disagree with the decision they proposed.

19 Q. You made reference to the chief of the Main Staff and other

20 military men. Was there anyone in particular who Milan Martic relied upon

21 for advice on military matters?

22 A. The commander of the Main Staff, General Celeketic.

23 Q. Do you know when General Celeketic became the Commander of the

24 Main Staff?

25 A. I'm not sure but I think it was in 1994.

1 Q. Do you know who appointed him to that position?

2 A. The president of the republic, Milan Martic.

3 Q. How would you describe the relationship between Martic and

4 Celeketic?

5 A. The appointment of General Celeketic shows that Mr. Milan Martic

6 had the most confidence in him of all the others in the Krajina, all the

7 other officers, which is why he appointed him. In Martic's estimation, he

8 was the most able officer and therefore he appointed him to command the

9 Main Staff. Nobody told me this, but that's how things worked.

10 Q. Separate from the actual appointment of General Celeketic, were

11 there any other indications of this relationship between the two men that

12 you personally observed?

13 A. One could observe that the two of them had been on close terms,

14 even before, that they were good pals and that their friendship dated from

15 before. I don't know from where, when, exactly, but they respected each

16 other.

17 Q. Did General Celeketic consult with Martic on military matters or

18 did he take decisions independently at any time?

19 A. As far as I was able to observe, he was in contact with Milan

20 Martic. However, he always tried to first take a decision with his own

21 staff and then inform Mr. Martic about the decision taken and the proposed

22 measures and the ways of carrying them out, which would be efficient. As

23 far as the armed forces of the RSK were concerned, he always prepared

24 everything beforehand and then put forth his proposals to Milan Martic,

25 who would then accept such decisions.

1 Q. To your knowledge, did General Celeketic ever take a decision and

2 implement a decision without the approval of Milan Martic?

3 A. I am not aware of anything of the sort.

4 Q. Colonel, now I'm going to ask you about Martic's relations with

5 several other senior figures in the FRY and the RSK and elsewhere, in

6 fact. We've already discussed a little bit General Celeketic. So now

7 I'll ask you about Slobodan Milosevic. First of all, what position did

8 Mr. Milosevic hold at this time, while you were serving in the SVK?

9 A. He was the president of the federal Republic of Yugoslavia -- no,

10 the president of the Republic of Serbia, and then at a later date the

11 president of the federal Republic of Yugoslavia, I believe, unless I'm

12 mistaken. I know for a fact that he was president of the Republic of

13 Serbia. I cannot say exactly when it was that he was elected president of

14 the FRY. There was Zoran Ilic, who was his predecessor there.

15 THE INTERPRETER: Zoran Lilic.

16 THE WITNESS: [Interpretation] But he was definitely the president

17 of the Republic of Serbia.

18 MR. BLACK: That's fine, thank you.

19 Q. The more important question is how would you describe the

20 relationship between these two men, Milan Martic and Slobodan Milosevic?

21 A. Slobodan Milosevic wielded his full influence over Milan Martic.

22 He respected Milan Martic and did everything in his power to ensure that

23 Milan Martic remained president of the RSK. All his efforts were directed

24 at fulfilling this goal to the full.

25 Q. Can you give any specific examples of this support or this

1 influence?

2 A. The most overriding example is the logistical support provided to

3 the army of the Republic of Serbian Krajina. Secondly, this is something

4 that General Dimitrijevic told me personally, that it was Milosevic's

5 position that we should do everything in our power to make sure that Milan

6 Martic remained head of state, that this was the guarantee for the

7 survival of the Serbs in Krajina and of the existence of the link with the

8 mother country. That was the prevalent feeling among the top military

9 leadership, that this was the sort of attitude and sentiments that

10 Mr. Milosevic had vis-a-vis Milan Martic.

11 Q. Do you know if Mr. Milosevic had any influence on Mr. Martic's

12 position towards the Z-4 peace plan?

13 A. The only thing I know is that on that day when a team from the

14 Krajina led by President Martic set out to discuss the Z-4 plan, I believe

15 that they used an UNPROFOR helicopter for that purpose. Although I don't

16 know the -- what the contents of the plan were precisely, I know that the

17 helicopter flew out holding our representatives for these negotiations and

18 I believe that Mr. Akashi chaired the meeting. Before the helicopter took

19 off from Knin, the chief of office of Mr. Martic, I believe his name was

20 Knezevic, reached the Heliodrom and told him that Mr. Milosevic had said

21 that the plan, the Z-4 plan, be a priori rejected without any prior

22 discussion. I heard this from Mihajlo Knezevic who told me that the main

23 boss in Belgrade had said that the Z-4 plan be rejected.

24 Q. Did Mr. Milosevic exercise his influence over Martic directly or

25 personally or indirectly or both -- in both ways?

1 A. I meant both ways. One was the direct communication with

2 Mr. Martic, and the second was whenever Jovica Stanisic came over, he

3 relayed any instructions he had from Mr. Milosevic to Milan Martic.

4 Q. Do you know how often Mr. Martic had direct communication with

5 Mr. Milosevic?

6 A. I don't know. I was not privy to such information.

7 Q. Do you know if he ever had direct communication with

8 Mr. Milosevic?

9 JUDGE MOLOTO: Hasn't that question been answered already? I

10 thought the witness said he had both direct and indirect influence over

11 Milan Martic.

12 MR. BLACK: You're right, Your Honour. Thank you. I withdraw the

13 question.

14 Q. Colonel, now I'd like to show you another document.

15 MR. BLACK: This is 65 ter number 1470 and I'd ask the assistance

16 of the Court officer to bring that up on e-court, please.

17 Q. Colonel, if you could just look at the first page of this document

18 and tell us what this is if you can tell.

19 A. This is a regular operations report compiled at the Main Staff of

20 the Serb Army of Krajina and was delivered to the Office of the President

21 of the Republic of Serbia, Mr. Milosevic, to the office of the president

22 of the Serbian Krajina, Mr. Milan Martic, and the chief of the

23 General Staff of the Yugoslav army personally to Colonel General

24 Momcilo Perisic.

25 Q. According to JNA and VJ doctrine, was it normal for a regular

1 combat report to be sent to the president of another republic, in this

2 case the Republic of Serbia?

3 A. No.

4 Q. Which persons ordinarily receive regular combat reports?

5 A. A report such as this one was supposed to be sent first to the

6 office of President Martic and second, in view of the obligation we have

7 mentioned earlier, that there was the order to submit written reports to

8 the General Staff of the Yugoslav army, it was quite logical that a report

9 where it was intended to be sent to the Army of Yugoslavia, it should have

10 been addressed to the chief of the General Staff of the Yugoslav army,

11 Colonel General Momcilo Perisic.

12 Q. My question is actually -- it's a little bit more general than

13 that and if you don't understand it let me know and I'll try to ask it in

14 a different way. Which kinds of persons ordinarily receive regular combat

15 reports? Are these widely distributed or are there certain kinds of

16 people who ordinarily receive them?

17 A. This particular report was supposed to be sent to General Momcilo

18 Perisic, and that's based on the obligations the SVK had, in terms of

19 writing reports to the General Staff of the Yugoslav army. Therefore it

20 was Perisic who was supposed to receive it.

21 Q. I understand that. My question is more general, not just with

22 regard to this document but with all regular combat reports, would those

23 be delivered widely or through the chain of command or to a particular

24 person? What kinds of people ordinarily receive such reports under

25 standard military doctrine?

1 A. Under the customary military doctrine, one had to follow the chain

2 of command. President Milosevic was not a person who was supposed to

3 receive such reports; on no account, if I understand your question well.

4 Q. And can any conclusion be drawn from the fact that Mr. Milosevic

5 personally was an addressee of this report?

6 A. The conclusion takes us back to what I touched upon earlier, and

7 that's the influence that Milosevic wanted to have, not only over the

8 political events but also over the army of the RSK. I can't see that

9 there is anything else. He tried to make sure to have influence over all

10 the infrastructure in the RSK, including the army of the RSK.

11 MR. BLACK: Your Honour, could this document be admitted into

12 evidence, please, and be assigned an exhibit number?

13 JUDGE MOLOTO: The document is admitted into evidence. May it

14 please be given an exhibit number.

15 THE REGISTRAR: That will be Exhibit number 457, Your Honour.

16 JUDGE MOLOTO: Thank you very much.

17 Mr. Black?

18 MR. BLACK: Thank you, Your Honour.

19 Q. Colonel Raseta, now I'm going to turn to another person. Someone

20 you've mentioned already in your testimony. Who was Jovica Stanisic?

21 A. Jovica Stanisic was the chief of the State Security of the

22 Republic of Serbia.

23 Q. And what role, if any, did he have in the affairs of the RSK?

24 A. He had a command at Petrova Gora, where a certain number of

25 members of the Serbian MUP were located, and he visited them on several

1 occasions, and very often he appeared in the RSK as a special envoy of the

2 president of the Republic of Serbia, Mr. Milosevic. It was in this

3 capacity that he toured the Krajina, visiting the special units at Petrova

4 Gora. I know that on one occasion, for a fact, he contacted Mr. Martic,

5 and the commander of the Main Staff when he was at the forward command

6 post at Titova Korenica. He was a person who was respected everywhere in

7 Serbia and even beyond, including the Krajina, because of his close

8 relations with Mr. Milosevic.

9 Q. And how would you describe his relationship with Milan Martic?

10 A. I don't know what their relationship was but I know that Jovica

11 Stanisic contacted Milan Martic. Now, whether Martic respected him or

12 not, I don't know. At any rate, he implemented whatever Stanisic told him

13 had to be done.

14 Q. Let me ask you about someone else now. Who was Dragan

15 Vasiljkovic? You've also referred to him earlier in your testimony.

16 A. When I arrived in the Krajina, Dragan Vasiljkovic was commander of

17 the Alpha Centre in Bruska. It was a centre for the training of Special

18 Forces. However, Dragan was involved in some dishonourable business as

19 well. I already said that he misappropriated property such as boat

20 engines and some other items I can't recall at present. We had

21 circumstantial evidence but because we didn't have enough time, we did not

22 investigate into that. There were allegations of him dismantling some

23 UNPROFOR vehicles and then transporting them over to the Republic of

24 Serbia. This was the person and this is my assumption who was installed

25 there by the State Security Service of the Republic of Serbia for their

1 own purposes, that he executed over there. He was carrying around a

2 topographical map and he said that he had carried out some 137 operations

3 aimed at the Republic of Serbia which consisted of reconnaissance of

4 different towns.

5 THE INTERPRETER: Interpreter's correction, operations aimed at

6 the Republic of Croatia.

7 THE WITNESS: [Interpretation] He did not carry out any sort of

8 training, at least not for the operations he professed to do. He had a

9 squad or a platoon of young girls who for the most part were of dubious

10 moral integrity or simply had no where else to go but to be accepted down

11 there. Most of the soldiers he trained down there were deserters from our

12 units, from the army of the RSK, after whom we sent out searches because

13 of desertion and they were in hiding among his units, and that's the way

14 things stood until we sent over our own security official at the centre

15 who was a subordinate of Captain Dragan's, but had to report and be

16 answerable to our security body and it was through him that we obtained

17 most of the information which had to do with the misconduct of Captain

18 Dragan's. He ruined one helicopter, and I believe that as a result of

19 this the pilot involved was permanently disabled. He took part in some

20 very significant meetings at the command of the Main Staff. When I

21 assumed my duty, I reported to General Celeketic and told him that we

22 could not discuss our matters in the same office where Captain Dragan was

23 and from that point on, he never appeared again. I know that he would

24 drop by president Martic's office. I know that he went every where in an

25 attempt to secure his stay there as long as he could. I believe that

1 prior to the fall of Krajina, he left the area. I'm not sure about that,

2 but I never saw him there again. And that's the story concerning him in

3 the briefest of terms.

4 MR. BLACK:

5 Q. How would you describe his relationship with Mr. Martic?

6 A. The same way I did for all the others. In view of the fact that

7 the MUP of Serbia or the state security department appointed him down

8 there, we had to respect him on that account. I know that this went for

9 Mr. Martic as well. I don't know whether he respected him indeed but he

10 did receive him in his office. I don't know what opinion he held in his

11 regard.

12 Q. Let me ask you now about another person. What was the

13 relationship between Milan Martic and Milan Babic?

14 A. The two of them could not get along at all. This sort of

15 situation existed even before I arrived there. As for the reasons

16 underlying their disagreement, I am not aware of them. But I know that

17 the Republic of Serbia did not accept Mr. Babic. I know that they

18 supported Mr. Martic, and that's the long and the short of what I know of

19 him. Regardless of the fact that he was in the executive government. I

20 believe that he was the foreign minister.

21 Q. Did Mr. Babic run for president against Mr. Martic in 1994, do you

22 know?

23 A. He did. I remember that quite well. The elections were won by

24 the late Milan Babic. However, I suppose this was a reaction from the

25 Republic of Serbia, where they asked for the annulment of the elections

1 and for a new round of elections to make sure that Milan Martic won them.

2 In connection with this, there were some ballot boxes that were being

3 disposed of. One such box was found in the park next to the command of

4 the Main Staff. We found them and we handed them over to the MUP. I

5 apologise.

6 The elections were found to have been irregular and rigged, and

7 the second round of elections was won by Mr. Martic.

8 Q. Colonel, just to let you know, there is some water next to you so

9 if you need to take a drink of water, feel free to do so.

10 A. Thank you.

11 JUDGE MOLOTO: Let me just get the point. The elections that were

12 won by Mr. Martic, are these the ones that were rigged?

13 MR. BLACK:

14 Q. Colonel, if you understand the question, please go ahead and

15 answer.

16 A. Yes. That's correct.

17 Q. Colonel Raseta, who was Radovan Karadzic?

18 A. Radovan Karadzic was the president of the Republika Srpska.

19 Q. How would you describe his relationship, if any, with Milan

20 Martic?

21 A. Based on what could be heard from the mass media and from

22 conversations with the officers, I knew that they were on good terms. I

23 remember a visit by President Karadzic to the RSK when he was received

24 with all state honours by President Martic and this was at the fortress.

25 The story went at the time and still goes around today that the

1 relationship between the two was such that President Martic called --

2 addressed him as "scholar" and Karadzic addressed Martic as "warrior." I

3 wasn't involved in the visit except for counterintelligence activities but

4 I heard from my chief that the objective of the visit was to make a

5 preliminary -- to make preliminary agreements about -- or for the

6 unification of the RSK and the Republika Srpska. There was discussion of

7 a referendum following which the two republics were supposed to be

8 unified. Several days later, a reaction followed from Mr. Milosevic to

9 the effect that no referendum should be held at all and that the situation

10 should remain as it was at the time. And that's as much as I know about

11 it.

12 Q. Thank you, colonel. Now I'm going to move to yet another topic

13 and I'd like to focus your attention on May of 1995. And I'd like you to

14 look at a document.

15 MR. BLACK: This is trial Exhibit 93, if it could be brought up on

16 the e-court, please.

17 Q. If you'll just be patient, Colonel. We are having a bit of a

18 technical problem. In a moment we'll blow it up so you can look at it

19 more clearly.

20 MR. BLACK: Is it possible to zoom in a bit on the document or is

21 it not working?

22 Q. Colonel Raseta, do you see the document on the screen in front of

23 you now?

24 MR. BLACK: Actually, if we could scroll just up a little bit so

25 the heading of the document is clear.

1 Q. Colonel, do you recognise this document?

2 A. Yes.

3 Q. What's the date of this document?

4 A. The 26th of May 1995. That's when it was created.

5 MR. BLACK: Could we please look at the last page of the document?

6 Q. Colonel Raseta, does your signature appear here on the last page?

7 A. Yes. That's right.

8 Q. Did you draft this document?

9 A. This document was created by the intelligence officer in the

10 intelligence department. I copied this and used it for my own needs in

11 order to check certain information.

12 MR. BLACK: If we could again look at the first page, please, if

13 we could scroll down to about the second paragraph there that kind of has

14 a bracket around it.

15 Q. Now, Colonel, what is being referred to here on the first page of

16 this document?

17 A. General Celeketic ordered the commander of the 39th Corps to open

18 artillery fire on Sisak out of retaliation against the Croatian forces who

19 had committed aggression on Western Slavonia. The commander of the 39th

20 corps --

21 Q. I'm sorry to interrupt. It's not necessary to read it out. I

22 think you've explained now generally what it was about.

23 Who was present on this occasion when General Celeketic ordered

24 artillery fire on Sisak?

25 A. All the assistants of General Celeketic were there, General

1 Bjelanovic, General Loncar, myself, Colonel Mihajlo Knezevic, the

2 assistant for morale and moral guidance, and for operations and training,

3 Colonel Milisav Sekulic. In the meantime, before the command was issued,

4 before the order was issued to the commander of the 39th corps to fire on

5 Sisak, President Martic came into General Celeketic's office. He heard

6 General Celeketic's decision and after the order was issued to Gacic to

7 fire on Sisak, President Martic left the office.

8 That's what I know about this.

9 Q. On what date --

10 JUDGE MOLOTO: Can I just get clarity here? Some of the names,

11 Mr. Raseta, that you have mentioned as having been present during this

12 order are not mentioned at the bottom of page 1 of this document. Are

13 those names in addition to these names that are at the bottom of the page?

14 MR. BLACK: Your Honour, I would just note for the assistance

15 perhaps of the witness that the footnote in the B/C/S version is on the

16 first page and the second page, so if the Court usher could perhaps pass

17 to the second page, the witness would know better who Your Honour is

18 referring to. At least I think that's the case. There is a footnote on

19 the second page, I'm not sure if it's a continuation or a part of the

20 same -- or a part of a new footnote.

21 Your Honour, we are doing our best to do everything through

22 e-court because we understand that to be the preference of the Trial

23 Chamber. I do have a hard copy in B/C/S. Given the flipping of pages,

24 I'd be happy to provide it to the witness. I think it would make it

25 easier for him, if that's an appropriate procedure.

1 JUDGE MOLOTO: After the witness has seen it, if it could be

2 passed on to the Defence counsel to have a look at it. Maybe if there is

3 a hard copy of the English version that has any more names than what we

4 are able to see in page one of the English version, we would appreciate

5 it.

6 MR. BLACK: No, Your Honour. I think that the English version you

7 have is the English version that we have.

8 JUDGE MOLOTO: Thank you.

9 THE WITNESS: [Interpretation] I don't recall the presence of Milan

10 Babic. Pavkovic, the Minister of the Interior, I do know that President

11 Martic was there, as well as the close associates of the commander of the

12 Main Staff, but I cannot recall whether the late Milan Babic, Pavkovic,

13 and Prijic were there.

14 JUDGE MOLOTO: On the footnote on page 1, Mr. Milan Babic is

15 mentioned and indeed, yes, Mr. Milan Martic is also mentioned, so also

16 General Celeketic, and then Mr. N. Pavkovic and Mr. I. Prijic, yourself,

17 Mr. Raseta.

18 THE WITNESS: [Interpretation] Prijic.

19 JUDGE MOLOTO: Prijic, okay, and Mr. Knezevic. But certainly,

20 Mr. Loncar and some other member, some other person you mentioned earlier

21 are not mentioned there. But all I want to know is whether those who are

22 not mentioned there, whom you mentioned, were also present? Were they

23 just omitted when this document was written or what the position is?

24 THE WITNESS: [Interpretation] It's possible they were left out,

25 but quite honestly I don't remember that Milan Babic, Pavkovic, and Prijic

1 were there. As for the others, and as for the contents of the remainder

2 of the report, yes, I know that that is how it was.

3 JUDGE MOLOTO: But you do remember that Mr. Milan Martic was there

4 when the order was issued? And he left the office after that? That's

5 what you testified.

6 THE WITNESS: [Interpretation] Yes, yes. I'm certain of that.

7 This footnote is not contained in the document I had. I have my own

8 document in front of me. This footnote was added by the chief of the

9 intelligence department. I just extracted certain passages I needed in

10 order to check certain information.

11 JUDGE MOLOTO: Thank you very much. You may proceed, Mr. Black.

12 I'm sorry for interrupting your leading.

13 MR. BLACK: No problem at all, Your Honour. Thank you very much

14 for the clarifications.

15 Q. Colonel Raseta, one further point of clarification, several

16 members of the Supreme Defence Council are mentioned by you and also in

17 this footnote. Was this a meeting of the full Supreme Defence Council?

18 A. No. To the best of my recollection, it was a meeting of the

19 collegium, General Celeketic with his immediate associates. We were in

20 the office and President Martic came in when General Celeketic issued his

21 order. I'm really confused by what it says here referring to Babic,

22 Pavkovic and Prijic. I don't remember ever sitting in a meeting together

23 with them, but I may be wrong. I'm not sure. I'm just not sure.

24 Q. Very well. What was your own reaction when you heard

25 General Celeketic give this order to shell Sisak?

1 A. Neither I nor any of those present reacted to the commander's

2 order.

3 Q. Were you surprised by the order in any way?

4 A. Yes, because later it turned out that Gacic did not carry out this

5 order because the targets had not been pinpointed precisely. He knew that

6 were he to open artillery fire on Sisak there would be a lot of innocent

7 victims which is why he did not open fire. Celeketic was angry. I don't

8 think anyone of those present opposed him.

9 Q. Do you remember whether Milan Martic had any reaction to this

10 order?

11 A. No. None of those present had any reaction to Celeketic's order.

12 Q. Thank you.

13 MR. BLACK: Your Honours, Mr. Whiting has helpfully pointed out to

14 me, just as a matter of information that Sisak appears on page 21 of the

15 atlas, Exhibit 23, and it's in grid C-3 if it's helpful to Your Honours in

16 putting a context and location to what's being discussed right now.

17 JUDGE MOLOTO: Grid number C-3?

18 MR. BLACK: That's correct, Your Honour.

19 JUDGE MOLOTO: As Commander-in-Chief, Mr. Milan Martic had the

20 power to countermand that order by Mr. Celeketic, did he.

21 THE WITNESS: [Interpretation] That's correct, yes.

22 MR. BLACK: Thank you, Your Honour. That's all my questions for

23 this document. It's already admitted into evidence so there is no need to

24 go through that procedure right now.

25 JUDGE MOLOTO: Thank you.

1 MR. BLACK:

2 Q. Colonel Raseta, you referred to the meeting that was referred to

3 in this document on the 1st of May 1995 was not a meeting of the Supreme

4 Defence Council. Did you attend a meeting of the regular Supreme Defence

5 Council in the early days of May 1995?

6 A. Yes, yes.

7 Q. Do you remember on which date that meeting was held?

8 A. I think it was on the 1st of May.

9 Q. Who was present at that meeting, to the best of your recollection?

10 Just tell us what you can remember.

11 A. This was the meeting after the fall of Western Slavonia. Is that

12 the one you're referring to? I'm not sure which one you're referring to.

13 Q. Yes. That meeting of the Supreme Defence Council, I think you

14 said it was on the 1st of May 1995. That's the one I mean.

15 A. You mean the extended meeting where the members, the ministers

16 were, the members of the cabinet? Is that the one you mean? After

17 Operation Flash? Is that the meeting you're referring to? There was more

18 than one meeting so I don't know which one to focus on.

19 Q. Well, let's focus on that one for the time being. Tell us who was

20 present at that meeting.

21 JUDGE MOLOTO: But that's the witness's problem. He's not quite

22 sure what meeting. Maybe if you're able to indicate what was being

23 discussed in that meeting or the agenda of the meeting, he might be able

24 to focus on it.

25 MR. BLACK: Okay.

1 Q. Perhaps I can focus it this way. It was a meeting where the

2 members of the Supreme Defence Council -- it was a meeting of the Supreme

3 Defence Council and other politicians were present. Do you have in mind

4 the meeting that I mean? You just referred to it just a moment ago.

5 JUDGE MOLOTO: You referred to an extended meeting with cabinet

6 members.

7 THE WITNESS: [Interpretation] If that's the meeting referred to,

8 the Supreme Defence Council, in an expanded composition, the ministers

9 were there of the government, General Celeketic with his assistants, all

10 of them, General Loncar, General Bjelanovic, Colonel Alavanja, Colonel

11 Raseta, Colonel Knezevic, and President Martic who chaired the meeting.

12 The purpose of the meeting was to analyse and explain the fall of Western

13 Slavonia. At this meeting, which was opened by President Martic,

14 Lieutenant Colonel Knezevic was first given the floor, and he spoke about

15 the axes along which the Croatian forces had gone into action. After

16 that, General Celeketic took the floor and spoke about how the Croat

17 forces were supported by the 18 -- how the resistance was supported by the

18 18th Corps and that Western Slavonia should not have fallen. After

19 Celeketic's speech, a decision had to be made as to how to proceed

20 further.

21 There were several ministers, I can't remember all their names,

22 who proposed that there was no point in engaging in any further military

23 operations and have soldiers and civilians get killed as a result, but

24 that work had to be coordinated with the FRY and President Milosevic and

25 that a solution had to be found to solve this situation by political

1 measures and return the population that had fled from Western Slavonia to

2 their homes. That's how the meeting ended. It ended on that note.

3 Celeketic did not say anything, nor did President Martic, to the effect

4 that weapons should be used to restore this territory. That's how the

5 meeting ended.

6 MR. BLACK:

7 Q. When you say that Celeketic did not say anything, nor did

8 President Martic, to the effect that weapons should be used, was there any

9 mention made of the possibility of an attack on Zagreb?

10 A. Not at that meeting, no. There was no mention of any operations

11 against Zagreb or any other town.

12 Q. Was there any mention of the Orkan multiple-barrel rocket

13 launchers at that meeting?

14 A. I don't remember anyone mentioning it.

15 Q. Were you generally aware of the use and location of the Orkan

16 rocket launchers during 1995?

17 A. I never saw those artillery pieces but I knew of their existence,

18 and I knew that they were physically guarded by my squad in the military

19 police battalion, but I did not know of the precise location of that

20 artillery piece. The first time when I took up my duties, I asked

21 General Celeketic what my duties were with regard to the

22 counterintelligence protection of that artillery piece, as it was the most

23 important artillery piece in the possession of the army. He said to me,

24 "That artillery piece is in a safe place and you have no obligations

25 concerning it." After that, I no longer inquired about it.

1 Q. Do you know to whom the Orkan rocket launchers were subordinated?

2 A. The commander of the Main Staff. I don't exclude the chief of

3 artillery at the Main Staff, that he also knew where it was located. And

4 the servicing of this multiple-barrel rocket launcher but I'm sure

5 Celeketic knew.

6 Q. Just so it's 100 per cent clear, I think you stated this already

7 many times, but Celeketic was the Commander of the Main Staff. That's who

8 you're referring to, correct?

9 A. The -- yes, the Commander of the Main Staff, that's right.

10 Q. Colonel, I'm going to show you another document, with the

11 assistance of the Court officer and the usher I'd like to show trial

12 Exhibit 92, please.

13 Colonel, please have a look at the document that's on the screen

14 in front of you and just tell me what this document is. If you need us to

15 scroll down so you can see the rest of the document, please just say so.

16 A. This is an order issued by the Main Staff concerning the raising

17 of combat readiness to the command of the 7th and 21st Corps and the

18 military police battalion and it refers to the Orkan, that it should be

19 ready for use on orders from Celeketic. All the preparations had to be

20 carried out so that when the order was issued, it could be fired. It says

21 in this document that there should be a march along certain axes, I don't

22 know whether you need me to read this, that the Vojnic area should be

23 reached at about 1400 hours on the 1st of May 1995.

24 Q. That's fine. Thank you very much. If we could just scroll

25 quickly to the bottom of the page --

1 A. It is Celeketic's signature.

2 Q. Is this document consistent with what you just told us about the

3 subordination of the Orkans to General Celeketic?

4 A. Yes, precisely so.

5 Q. Thank you of the that's all for that particular document. Again,

6 this is already a trial exhibit, Your Honours. It's Exhibit 92.

7 JUDGE MOLOTO: Thank you.

8 MR. BLACK: Your Honours, I'm about to ask him to look at another

9 document which will take more certainly more than three minutes. I'm

10 wondering if it might be convenient to take the break now and start with

11 the document after the break. But I'm happy to do it however you please.

12 JUDGE MOLOTO: We appreciate you letting us off early today more

13 than once.

14 Court will take a short adjournment. We'll adjourn and come back

15 at quarter to six.

16 Court adjourned.

17 --- Recess taken at 5.13 p.m.

18 --- On resuming at 5.46 p.m.

19 JUDGE MOLOTO: Mr. Black?

20 MR. BLACK: Thank you very much, Your Honour.

21 The next document which I'd like to show to the witness is trial

22 Exhibit 95. With the assistance of the court officer and the usher, if we

23 could bring that on to the screen, please.

24 Q. Colonel Raseta, if you could please just have a look at this

25 document and tell me whether or not you recognise it.

1 A. Yes.

2 Q. What is this document?

3 A. This is a security document which was created after the fall of

4 Western Slavonia.

5 Q. What's the date of this document?

6 A. The document is dated the 2nd of May 1995.

7 MR. BLACK: With the assistance again of the usher, if we could

8 look at the last page, please. If we could scroll down to the bottom,

9 please.

10 Q. Colonel, does your name appear at the end of this document?

11 A. That's correct.

12 Q. And did you in fact draft this document?

13 A. Yes.

14 Q. How did you do so? How did you compile this document? Do you

15 remember?

16 A. The better part of its contents I took over from a staff document

17 and a part of it dealing with security-related issues was produced by me.

18 Q. Now I'd ask you to please look at the top of page 2. In fact page

19 3 in the English version. And when that appears on your screen, Colonel,

20 if you could just tell me what is reported there. I don't need to you

21 read it out but just tell me generally what's addressed.

22 A. It says here that on that day, at 10.30, certain targets were

23 fired upon in Zagreb from eight Orkan rockets.

24 Q. Does it indicate any particular locations that were hit?

25 A. Yes. The Ministry of Defence, at Krizaniceva street, the

1 Zrinjevac area where the American embassy was partially damaged. Then the

2 crossroads at the railway station and the Esplanade hotel, the building at

3 Radnicka street as well as parts of Novi Zagreb.

4 Q. There is also a reference to people killed and wounded. What

5 numbers does it give for persons killed or wounded?

6 A. Yes. About 30 killed and 130 wounded.

7 Q. Did you have any information to indicate whether there were

8 civilians among these casualties, among those killed and injured?

9 A. I think that they were -- they were civilians for the most part.

10 Q. Is that something that you learned at the time or only later? Do

11 you remember?

12 A. This became general knowledge later on, that it was civilians who

13 were casualties of the rocket attack.

14 Q. On that same day, the 2nd of May, did you receive any other

15 information besides what was in this document, any other specific

16 information about the shelling?

17 A. There was discussion. I don't know who set that, that there were

18 30 people killed but I don't know who it was who talked about it. This

19 sort of information could only be provided by security organs.

20 Q. Do you know whether Milan Martic was informed about the

21 consequences of the shelling of Zagreb on the 2nd of May 1995?

22 A. I don't know about that. At any rate, the commander of the Main

23 Staff had to report on that.

24 Q. To whom did he have to report on that?

25 A. Who do you mean?

1 Q. I'm sorry, I just -- it was just a clarification, you said, at any

2 rate, the commander of the Main Staff had to report on that and I just

3 wanted you to make clear who he had to report to about that.

4 A. To the president of the republic, Milan Martic. He was also

5 duty-bound to inform the General Staff of the FRY, based on that standing

6 order issued by the General Staff, which we discussed earlier.

7 Q. When you yourself learned of the shelling of Zagreb on the 2nd of

8 May, what was your reaction?

9 A. My reactions were then and are still now that the persons who were

10 familiar with these artillery pieces knew that they were intended for

11 targeting wider areas and not points, and that as such they could entail a

12 lot of casualties. I did not support such a decision and I stand by that

13 view today.

14 Q. Colonel, I'd now ask you to look at the last page of the document

15 in B/C/S. This passage actually appears on pages 5 and 6 in the English

16 version.

17 JUDGE MOLOTO: Page?

18 MR. BLACK: Pages 5 and 6 in the English, Your Honour.

19 Q. Colonel, it's the part that is bracketed there that begins, "All

20 those who participated in the discussion." That's the part I'm focusing

21 on now. Did you draft this part of the report or is this something that

22 you copied from someone else's work?

23 A. I wrote this part.

24 Q. Could you please explain what you meant when you say that there

25 were different approaches on how to resolve the situation? And then you

1 talk about the position of Martic and Celeketic as opposed to others.

2 A. Yes. Everyone, except for -- and I'm referring to the meeting

3 where the Supreme Defence Council had an extended meeting with the

4 presence of members of the cabinet, all of those present, except for

5 Martic and Celeketic were in favour of a peaceful solution of the newly

6 arisen situation through negotiations, as I've already explained, with a

7 view to signing a cease-fire agreement binding on both sides, which meant

8 that the population would return to the areas they originally came from.

9 However, Martic and Celeketic were opposed to that.

10 Q. What was the preferred solution of Martic and Celeketic?

11 A. I think that it was Celeketic who suggested that the territories

12 lost be recaptured by combat, where the forces of the adjacent cause would

13 be engaged as support. I know for a fact, however, that the commanders of

14 the other corps which were supposed to take part in such an action were

15 not in favour of the action and the territories lost were not recaptured

16 because objectively speaking the 18th corps no longer had the strength

17 necessary to recapture the territory. This was therefore Celeketic's

18 proposal which was accepted by Mr. Martic.

19 Q. Just to be clear, when you mentioned recapturing territory, which

20 territory do you mean? Which territory would be recaptured?

21 A. I'm referring to Western Slavonia.

22 Q. Another question just for clarity, is this the same Supreme

23 Defence Council meeting or the extended meeting that you talked about a

24 little bit earlier in your testimony? Are you referring to the same

25 meeting?

1 A. I can't recall at present time whether this was that meeting or

2 whether it was the meeting that followed this one.

3 Q. That's fine. If you can't recall, I think we can move along,

4 unless Your Honour has a question.

5 A. Nevertheless, the contents are correct.

6 JUDGE MOLOTO: I just have one question. You say there were two

7 approaches, the one by Mr. Milan Martic and Mr. Celeketic to go on combat,

8 and the other one by the rest of the members to negotiate a peaceful

9 settlement. In the end, which of these two approaches prevailed?

10 THE WITNESS: [Interpretation] The action referred to recapture the

11 territories was not in fact carried out; however, what followed was the

12 decision to open fire on Sisak, Zagreb, and some other towns. I don't

13 know if I made myself clear. What followed was not a combat action aimed

14 at recapturing these territories, in view of the fact that the commands of

15 the Banija and Kordun corps were supposed to carry the action out together

16 with the 18th Corps. Since this did not take place, a decision was taken

17 to shell Zagreb and some other towns.

18 JUDGE MOLOTO: In retaliation, not in defence n retaliation?

19 THE WITNESS: [Interpretation] Yes, yes.

20 MR. BLACK: Thank you, Your Honour. Those are all my questions

21 with regard to that particular document.

22 If we could turn now to trial Exhibit 100, please? And if we

23 could just look at the first page.

24 Q. Colonel, what is this document?

25 A. This is a document issued by the Main Staff of the Serbian Army of

1 Krajina, namely the commission for establishing the responsibility for the

2 military organisation and the fall of Western Slavonia, which was signed

3 by the commander of the Main Staff of the RSK, Colonel Celeketic. In

4 other words, a commission was set up which investigated -- made an inquiry

5 into all the circumstances surrounding the fall of Western Slavonia, the

6 commission then produced a report and submitted it to the Main Staff of

7 the RSK. The document is dated the 13th of July 1995.

8 Q. Thank you, Colonel. Just one clarification, I think there may

9 have been a mistake. The transcript reads, that this was signed by the

10 commander of the Main Staff of the RSK. Was it signed by Celeketic or was

11 it submitted to Celeketic?

12 A. It was delivered to him. That's what the -- he's the addressee

13 but, of course, I would have to look at the end of the document to see

14 about the signature.

15 Q. Perhaps we could look briefly at the last page, please.

16 A. No. The members of the commission signed the paper.

17 Q. Colonel, were you aware of this document in 1995?

18 A. I was aware of it in so far as my official, Colonel Nikola Suput

19 was involved in the commission. However, there were no significant

20 omissions on the part of those in charge of the security situation

21 surrounding the fall of Western Slavonia, but I would have to read the

22 document to refresh my memory further.

23 Q. It's a fairly long document and I won't ask to you look at all of

24 it. I'd like to direct your attention to pages 10 and 11. It's page 16

25 in English. And in particular, conclusion number 9. Colonel if you could

1 just read that first line and then we'll pass over to the next page. I

2 think we can pass to the next page now, please.

3 A. Very well.

4 Q. Colonel, it says there that no opinions were sought from the

5 commanding officers of the SVK Main Staff. Is that consistent with your

6 own recollection of events at this time?

7 A. Yes.

8 Q. As far as you know, were members of the SVK Main Staff consulted

9 about the decision to shell Zagreb on the 2nd and 3rd of May 1995?

10 A. I was focused on the text. Could you please repeat your question?

11 Q. Of course, that's quite all right. As far as you know, were

12 members of the SVK Main Staff consulted about the decision to shell Zagreb

13 on the 2nd and 3rd of May 1995? And I mean members other than

14 General Celeketic, of course.

15 A. No, they weren't.

16 Q. The last sentence of this paragraph says the decisions were made

17 by the commander and the president and stances and orders were given on

18 the telephone. There are no written orders. Is that consistent with your

19 understanding of how things happened?

20 A. Orders may be issued over the phone and in writing. However, if

21 an order is put down on paper, although, of course, there was time for

22 that as well, in that case, a wider circle of people would have been

23 familiar with the order. What one can conclude on the basis of this is

24 that commander Celeketic tried to transfer the -- over the phone in order

25 to make sure that only he and the person receiving the order on the other

1 end of the phone were the ones familiar with the order. What I wanted to

2 say, of course, is that issuing orders over the phone is not something

3 that is in dispute. However, the decision should have been collectively

4 taken. We should all have been familiar with the order. In this case,

5 this went through the closest associates of the commander.

6 Q. Thank you, Colonel. That's all I have to ask you about that

7 document.

8 MR. BLACK: If we could now see trial Exhibit 101, please?

9 Q. Colonel, please take just a moment to look at this and then tell

10 us what this document is, please.

11 A. This is a document drafted by General Celeketic entitled, "Request

12 for the removal of commander of the Serbian Army of Krajina." And it is

13 addressed to the Commander-in-Chief, President of the RSK, Milan Martic.

14 And the document is dated the 15th of May 1995. Probably, or rather

15 certainly, feeling guilty for the fall of the -- of Western Slavonia,

16 because prior to him assuming the position of the Commander of the Main

17 Staff he was the commander of the 18th corps.

18 Q. Did you see this document in 1995?

19 A. General Celeketic did not show the document to his associates. He

20 only told us what the substance of the document was, and it is as one can

21 read it here.

22 Q. So did he tell you personally that he was leaving the post of

23 commander of the SVK?

24 A. Yes.

25 Q. Colonel, if you would, please look at the second paragraph of this

1 document. There, Celeketic writes, "I have acted in accordance with our

2 doctrine of reprisal at the chosen vital targets of the combatant." Do

3 you know what General Celeketic is referring to here?

4 A. He's talking about reprisals against selected vital targets of the

5 opponent. However, I'm telling you this from my knowledge, from my

6 military knowledge, based on the military schools I completed, this notion

7 of reprisal is not something we encounter. What he is referring to here,

8 under -- or by mentioning reprisals is the attacks that were launched

9 against Zagreb, Sisak, and some other towns.

10 Q. Thank you, Colonel. That completes my questions on the issue of

11 the shelling of Zagreb. I just have a few more topics to cover with you

12 very, very briefly and then the Defence counsel will have a chance to ask

13 his questions of you.

14 First, were you present in Croatia at any time during 1991 and

15 1992?

16 A. No. I wasn't until 1993.

17 Q. Do you have any knowledge or information about crimes that were

18 committed in Croatian villages such as Saborsko or Skabrnja during 1991

19 and 1992?

20 A. No, I don't have any knowledge or information about that.

21 Q. When the RSK fell in August of 1995, where did you go? What

22 happened to you?

23 A. Are you referring to me personally or to the service I was in

24 charge of?

25 Q. To you personally.

1 A. Together with the Main Staff, we were relocated, first to Srb in

2 Donji Lapac municipality, and after that, via Republika Srpska and

3 Prijedor, we arrived in Banja Luka. So we were relocated in stages. This

4 took several days. Then from Banja Luka, I returned to the Federal

5 Republic of Yugoslavia and I think it was on the 14th of August 1995. I

6 reported to my home unit, which had sent me to the war front.

7 Q. In effect, did you then return to the service of -- to your prior

8 service in the Yugoslav army, leaving the service of the SVK?

9 A. No. Because my post had been filled, and I could not be given an

10 appropriate position, in view of my rank and the work I had done. I

11 solved the remaining -- my financial problems I still had and other

12 material issues, the writing of official evaluations and so on. This took

13 a few months. And because I met the conditions on the 1st of January

14 1996, I retired.

15 Q. When you retired -- I think earlier in your testimony you referred

16 to the fact that service in the SVK resulted in certain benefits,

17 including double time in terms of seniority or pension. Did you in fact

18 receive double time for retirement purposes for the time you served in the

19 SVK?

20 A. Yes, yes.

21 Q. Thank you, Colonel. I'd like to show you one final document.

22 It's a photograph --

23 JUDGE MOLOTO: Just before you do that, can I just get clarity

24 here?

25 Mr. Raseta, you say that on the 14th of August 1995 you reported

1 to your home unit which had sent you to the war front. When they accepted

2 you there, as you returned, as what -- in what capacity did they receive

3 you back? I'm asking the question because you say your position had been

4 filled and you just had to finish off your reports. You were not -- in

5 what capacity were you received back?

6 THE WITNESS: [Interpretation] In the capacity of an officer not

7 assigned to a particular duty. I was waiting to resolve all my

8 administrative issues and then to retire. I filled in the application and

9 it was accepted.

10 JUDGE MOLOTO: Thank you.

11 MR. BLACK: Thank you, Your Honour.

12 The photograph which I'd like to show bears the ERN 04696912. In

13 fact there are two photographs on the same page. If that could be put on

14 e-court, please.

15 Q. Colonel, I'd simply like to ask you if you can recognise -- first,

16 if you can recognise any of the people in these two photographs.

17 A. I recognise my former president, Milan Martic. I'm not sure but,

18 yes, next to him is General Borislav Djukic in uniform.

19 Q. Are you referring to the picture on the left or the picture on the

20 right?

21 A. On the left, the one on the left.

22 Q. And there are two gentlemen there in uniform -- well, actually

23 there are two gentlemen in green camouflage uniform. Can you describe

24 which one of those gentlemen you're referring to, please?

25 A. To the right of President Martic is General Borislav Djukic.

1 Q. And then looking for a moment at the other photograph, are you

2 able to tell us where that photograph was taken? Can you recognise the

3 location?

4 A. I'm not sure, but I think it's the fortress. I'm not sure,

5 however.

6 Q. The fortress in which city?

7 A. Knin.

8 MR. BLACK: Your Honour, I would ask that this document containing

9 the two photographs be admitted into evidence, please, and assigned a

10 number.

11 JUDGE MOLOTO: The document is admitted into evidence. May it

12 please be given an exhibit number.

13 THE REGISTRAR: This will be Exhibit 458, Your Honour.

14 JUDGE MOLOTO: Thank you so much.

15 MR. BLACK: Your Honour, that completes my direct examination.

16 Thank you.

17 JUDGE MOLOTO: Thank you very much, Mr. Black.

18 Mr. Milovancevic?

19 MR. MILOVANCEVIC: [Interpretation] Your Honour, my co-counsel,

20 Nikola Perovic, will conduct the cross-examination.

21 JUDGE MOLOTO: Mr. Perovic?

22 Cross-examination by Mr. Perovic:

23 Q. Good afternoon, Mr. Raseta?

24 A. Good afternoon.

25 Q. I assume that you know I am one of the Defence counsel appearing

1 for the accused. I am attorney at law, Nikola Perovic. I will now

2 cross-examine you according to the Rules of Procedure and Evidence. I

3 would like to ask you one thing. As we speak the same language, let's

4 avoid overlapping. Please make a pause after each question so that the

5 interpreters can do their job. Thank you.

6 From the statement you gave to the Office of the Prosecutor, I

7 conclude that from the second half of October 1993, until the 14th of

8 October 1995, that is for almost two years, you were first the chief of

9 the analysis department and then the chief of the security organ with the

10 Main Staff of the Serb Army of the Krajina; is that correct?

11 A. Yes.

12 THE INTERPRETER: Interpreter's correction: 14th of August, not

13 October.

14 MR. PEROVIC: [Interpretation]

15 Q. On page 6, in paragraph 14 of your statement, you say that while

16 you were serving in the security organs of the SVK, the security organs

17 did not register a single war crime or carry out an investigation of one.

18 My question is the following: Were there such crimes or not?

19 A. I don't have any information about that. I don't know.

20 Q. In the same paragraph, you say, "I was in the region in the area

21 during Operation Storm, August 1995 but I have no concrete knowledge of

22 crimes committed by members of the HV, the Croatian army."

23 A. No, I don't, because all communications with subordinate commands

24 have been cut off. That was the only reason why we were unable to receive

25 information, not just I but none of the subordinate organs could obtain

1 relevant information.

2 Q. I see. In the next paragraph, under number 15, you say that --

3 MR. BLACK: I apologise for interrupting. I would just ask if we

4 are going to continue to go through the statement if the witness could be

5 provided a copy of it so that he can see what it was he actually included

6 in the statement in order to answer the questions.

7 JUDGE MOLOTO: If I may extend the request, Mr. Perovic, you could

8 also provide the Bench with copies of the statement.

9 MR. PEROVIC: [Interpretation] I don't have any other copies apart

10 from the one I'm holding in my hand. If the Prosecution has an extra

11 copy, would they be kind enough to show it to the witness?

12 MR. BLACK: Certainly. I think we have a copy in English and a

13 copy in B/C/S and I think I can also provide another English copy,

14 Your Honour, if that's of assistance.

15 JUDGE MOLOTO: Won't you need your copy?

16 MR. BLACK: I have yet another marked-up copy for myself,

17 Your Honour.

18 JUDGE MOLOTO: Thank you.

19 MR. BLACK: Here is an English copy. And the translation for the

20 witness. And I believe I have another set as well.

21 MR. PEROVIC: [Interpretation] Thank you. I thank my learned

22 friends.

23 Your Honours, may I continue?

24 JUDGE MOLOTO: You may continue, Mr. Perovic. Sorry for the

25 interruption.

1 MR. PEROVIC: [Interpretation]

2 Q. Mr. Raseta, on -- we are on page 6, and in paragraph 15 you speak

3 of your contacts with Milan Martic. You say there were about 10 of these

4 and that he asked you several times to use your security organs to prevent

5 smuggling by SVK members, and you go on to say that Martic also wanted to

6 achieve better cooperation between the civilian and military security

7 services and that he told you that you could contact him whenever you felt

8 the need to do so. How did you make use of this opportunity?

9 A. You mean these ten contacts?

10 Q. I mean the proposal Martic made to you.

11 A. First of all, I haven't found this on page 6, in paragraph 15.

12 That's what you said, isn't it?

13 Q. Yes. It's at the bottom of the page, the last paragraph.

14 A. During the time period?

15 Q. Yes.

16 A. Your question was?

17 Q. My question was, how did you make use of the opportunity created

18 for you by Milan Martic when he asked you to use your security organs to

19 prevent smuggling and crime?

20 A. I made use of it in the following way. The corps bordering with

21 the 5th Muslim Corps, that was the Lika Corps, the Banija Corps, and the

22 Kordun Corps, the security organs recruited their military police to take

23 up check-points and to confiscate weapons and fuel that were being

24 smuggled.

25 Q. Thank you. The Prosecutor asked to go into private session when

1 he put a question to you in relation to something I'm going to ask you

2 about now. I don't see any reason for it but out of an abundance of

3 caution I now move that we go into private session?

4 JUDGE MOLOTO: May the Chamber please move into private session.

5 [Private session]

6 (redacted)

7 (redacted)

8 (redacted)

9 (redacted)

10 (redacted)

11 (redacted)

12 (redacted)

13 (redacted)

14 (redacted)

15 (redacted)

16 (redacted)

17 (redacted)

18 (redacted)

19 (redacted)

20 (redacted)

21 (redacted)

22 (redacted)

23 (redacted)

24 (redacted)

25 (redacted)

1 (redacted)

2 (redacted)

3 (redacted)

4 (redacted)

5 (redacted)

6 (redacted)

7 (redacted)

8 (redacted)

9 (redacted)

10 (redacted)

11 (redacted)

12 (redacted)

13 (redacted)

14 (redacted)

15 (redacted)

16 (redacted)

17 (redacted)

18 [Open session]

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

20 JUDGE MOLOTO: Thank you very much.

21 You may proceed, Mr. Perovic.

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

23 Q. When responding to some questions put by the Prosecutor, you spoke

24 about the relationship between the Serb Army of Krajina and the Army of

25 Yugoslavia. What I'm interested in was the following. Did the Army of

1 Yugoslavia, apart from the logistical support you described, provide any

2 other kind of support for the Serb Army of Krajina?

3 A. Yes. A group of officers arrived, three of them, who participated

4 in drawing up the defence plans of the Republic of Serb Krajina, and also

5 what I said before.

6 Q. In the period from 1992 to 1995, Mr. Raseta, five acts of

7 aggression by Croatian forces on the territory of the RSK have been

8 registered. Did the Army of Yugoslavia respond in any of those cases?

9 A. You mean physically?

10 Q. Yes.

11 A. No.

12 Q. So not a single platoon or company or squad was sent to assist

13 from the Army of Yugoslavia?

14 A. No, not from among the active-duty soldiers, and I'm referring

15 only to the period when I was there.

16 Q. I'm asking you whether you know about this in general.

17 A. No, I don't.

18 Q. You've heard of the Vance Plan --

19 A. Yes.

20 Q. -- from January 1992. Are you aware that according to this plan,

21 the Army of Yugoslavia was duty-bound, if UNPROFOR was unable to do so, to

22 protect the Serbs in the RSK?

23 A. I don't recall this but I don't have any reason to disbelieve you.

24 Q. In paragraph 19, on page 7 of your statement, you say that

25 although you did not receive an explicit order to inform him about events

1 in the RSK or the SVK, you did this. I'm referring to Dimitrijevic, the

2 chief of the security administration. Did you make this decision on your

3 own initiative?

4 A. It was something that not only I but all my predecessors did.

5 They reported too. If need be, I can explain why.

6 Q. I'm asking you this because in paragraph 21, on page 8, you say

7 the following: You say that your predecessors, whom you name, Vuk

8 Dimitrijevic and Dusan Smijanic, did not systematically inform the head of

9 the VJ security administration. In this respect, your activity would be

10 exceptional; is that correct?

11 A. Yes.

12 Q. In the previous paragraph, paragraph 20, you say, "I did not tell

13 Milan Martic, president of the RSK, and Lieutenant General Milan

14 Celeketic, CGS SVK that I kept Dimitrijevic informed, Dimitrijevic being

15 the chief of the security administration of Yugoslavia; is that correct?

16 A. Yes. I had the right not to inform them of this. To inform them

17 of matters relating to my professional counterintelligence activities.

18 Q. Let's clarify something. Today, when answering a question put by

19 the Prosecutor, you said that you did not tell Milan Martic about your

20 sending information to the chief Dimitrijevic but that you did tell

21 Celeketic?

22 A. Yes.

23 Q. So which is correct, what you're saying now or what you said in

24 your statement?

25 A. I informed him from time to time.

1 Q. In paragraph 22, on the same page, you state that there was no

2 formalised exchange of information between the SVK security organs and the

3 security organs of the army of the Republika Srpska; is that correct?

4 A. Yes.

5 Q. In paragraph 23, on page 9, you speak of the intelligence centre

6 of the VJ at Petrova Gora, Kordun, which was used to collect information

7 for the purposes and needs of the General Staff of the VJ; is that

8 correct?

9 A. Yes.

10 Q. The last sentence of this paragraph reads, "In my opinion, if the

11 VJ really wanted to share its information and intelligence with the

12 Serbian Army of Krajina, the main part of this intelligence centre would

13 have been located at Knin and not at Petrova Gora."

14 A. Yes.

15 Q. And can it be concluded on the basis of this that the Army of

16 Yugoslavia and the Serbian Army of Krajina operated under the

17 circumstances as a single tissue, as you put it?

18 A. The information from the centre went directly to the General

19 Staff, and it was precisely this Colonel Mihajlo Knezevic who was in

20 charge of it in the part that had to do with the army of the RSK.

21 Whatever was relevant for the RSK, Colonel Mihajlo Knezevic would receive

22 the information as part of the security administration of the VJ.

23 Q. This is what I'm interested in. Had the VJ General Staff really

24 wanted to share the security information and intelligence with the SVK,

25 your opinion was, as you put it, the intelligence centre would have been

1 located at Knin and not at Petrova Gora.

2 A. What I wanted to say was that the information was supposed to flow

3 directly to us and then from us to Belgrade. This is something that

4 should have been the case. For some reason, however, the information

5 first went to Belgrade and was only then forwarded to Knin.

6 JUDGE HOEPFEL: Could you just slow down a little bit?

7 MR. PEROVIC: [Interpretation]

8 Q. In paragraph 24, on page 9, you speak of the exchanges of visits

9 of some members of logistics support department, training, and operations

10 department, and so on and so forth. And you say that the purpose of these

11 visits was to draft plans of defensive -- for defensive operations of the

12 SVK. My question is as follows: Were these plans always of defensive

13 character? And I mean the plans that were drafted during such visits.

14 A. During these visits, plans for the defence of the RSK were

15 drafted. That was the purpose of the visits and I can tell you that for a

16 fact, when it comes to these plans.

17 Q. Therefore these were defensive plans?

18 A. Yes, for the defence.

19 Q. Mr. Raseta, on page 11, in paragraph 34, you mentioned that on one

20 occasion, Martic told you that he could not consider all the Croats his

21 enemies, and you repeated that today.

22 A. Yes.

23 Q. During your -- today's testimony, why did you call into question

24 his sincerity at the time?

25 A. He was able to order Celeketic to fire upon Zagreb, and I don't

1 know whether any other town was shelled too.

2 Q. Therefore this was the sole reason that led you to doubt the

3 sincerity of his words?

4 A. Yes.

5 Q. On page 12, in paragraph 35, you state that you were under the

6 impression that Milosevic had firm control over Martic, and as an

7 illustration of such influence wielded by Milosevic you mention the

8 rejection of the Z-4 peace plan in early 1995. How would you explain

9 Milosevic's negative reaction to the idea of unifying the two Krajinas,

10 Croatian and Bosnian Krajinas, and his anger at the shelling of Zagreb?

11 A. I can explain this. I am merely relaying to you what I heard.

12 And I have my opinion about it but what you're saying is correct.

13 THE INTERPRETER: Interpreter's correction: The witness said, "I

14 cannot explain this."

15 MR. PEROVIC: [Interpretation]

16 Q. In relation to the Z-4 plan, you said that it was good for the

17 Serbs and for Croatia today. This is what you state in your statement.

18 Today, in response to the Prosecutor's questions, you stated that you were

19 not that familiar with the plan. Then how could you comment today to the

20 effect that it was good for the Serbs in Croatia?

21 A. We talked about the plans -- the plan, and I mean the officers, as

22 it offered a possibility to the Serbs to remain in their homes, to enjoy a

23 certain degree of autonomy, and it opened the possibility for them to

24 maintain cultural and other links with the mother country of Serbia and

25 definitely had the plan been accepted, the Croatian action would not have

1 followed and the Serbs would not have been driven away. At any rate, the

2 plan offered the possibility for the Serbian population to remain in the

3 Krajina.

4 Q. And this is something you learned from these conversations by

5 hearing these comments without you actually obtaining any further

6 information about the plan?

7 A. Well, I was not able to, since I did not have the plan in my

8 hands.

9 Q. On page 14 of your statement, in paragraph 44, you state that you

10 did not know the nature of the relationship between Martic and Jovica

11 Stanisic but that you knew that Martic had to obey Stanisic, and you go on

12 to say, "At the moment I'm providing you with this statement, I do not

13 remember any concrete examples of this dominating position of Stanisic's

14 vis-a-vis Martic."

15 My question to you is: How did you arrive at the conclusion that

16 Martic had to obey Stanisic?

17 A. I know that when Stanisic was at Korenica, he was sent over there

18 by Milosevic, a part of the Main Staff headquarters was at the forward

19 command post at Korenica because we were supposed to carry out some plans

20 vis-a-vis the 5th Corps of the Republic of Bosnia-Herzegovina. Although I

21 was not present at that meeting, there was Colonel Smiljanic, who was

22 present there when Jovica Stanisic appeared on behalf of Milosevic, and

23 transferred assignments to them. Among other things, General Celeketic

24 said that he was not sure that -- whether he would be able to meet the

25 requests put forth by Stanisic on behalf of Milosevic and then Stanisic

1 said, well, if you can't do that, then someone else will. But he did ash

2 and I mean Celeketic did not oppose Stanisic.

3 Q. And this was the sole basis for your conclusion that Martic had to

4 obey Stanisic?

5 A. Well, Stanisic went to the Pauk command at Petrova Gora more than

6 once.

7 Q. This is something we will get back to later.

8 Do you know, Mr. Raseta, what Milan Martic's attitude was towards

9 Frenki Simatovic?

10 A. I'm not aware of that but I believe that they knew each other.

11 Q. Did you hear that Mr. Martic had asked that the -- he be removed

12 from the territory of the RSK?

13 A. I did not hear of that.

14 Q. Do you know what the relations between Milan Martic and Captain

15 Dragan or Dragan Vasiljkovic were?

16 A. Based on my knowledge of Milan Martic and on my knowledge of

17 Dragan Vasiljkovic, I believe that President Martic could not have a good

18 opinion of Captain Dragan, but since the Serbian State Security sent him

19 over there, he had to be tolerated.

20 Q. Do you know anything of the presence of the late Raznjatovic, aka

21 Arkan on the territory of the RSK?

22 A. I don't know anything.

23 Q. In paragraph 48, on page 15, you state your opinion that the state

24 security of the Republic of Serbia had imposed Captain Dragan, Dragan

25 Vasiljkovic on Milan Martic. Was this your opinion?

1 A. Yes.

2 Q. Is this your opinion today?

3 A. Yes, it is, because had we had the strength, we would have removed

4 Dragan Vasiljkovic from the RSK. He had no business being there.

5 Q. When discussing the relations between Milan Martic and Milan

6 Babic, you mentioned the presidential elections in the RSK. You said that

7 the elections were rigged in Milan Martic's favour. What is the source of

8 your knowledge in connection with this?

9 A. These were comments made publicly. It was discussed that Babic

10 must have won the elections but that Milosevic could not come to terms

11 with this and that the Republic of Serbia and the State Security there

12 staged several events or, rather, carried out these clandestine actions

13 which included the disposing of ballot boxes like the ones we found

14 outside our command in order to declare the elections rigged and have new

15 elections called and Martic elected.

16 Q. Therefore, these, the knowledge you had, and I would say it was --

17 these were allegations, which boiled down to the comments, the stories,

18 that went around Knin and the RSK. You have no other evidence in this

19 respect?

20 A. No. Except for the discarded ballot boxes we found.

21 Q. I reminded you of this a moment ago and I have a question for you

22 which has to do with this. On page 16, in paragraph 52, you state that in

23 the summer of 1994, Radovan Karadzic was in Knin where he talked to the

24 RSK leadership about the ways in which the RSK and the RS might come

25 closer on the political and military -- political, government, and

1 military levels, in view of possible future unification. Is that what you

2 stated?

3 A. Yes.

4 Q. Colonel Smiljanic, whom you mentioned a moment ago, told you, in

5 connection with this, that the big boss in Belgrade, did he refer to

6 Milosevic?

7 A. Yes.

8 Q. Was not happy with this initiative at all. Is that the case? Was

9 this in fact the case?

10 A. Yes.

11 Q. I'm asking you this because of your statement or position that

12 Milosevic wielded great influence over Martic. But this is something that

13 deviates from what you state.

14 A. Well, I don't see how it does deviate, since there was no

15 unification. In fact, it seems that Milan Martic went along with this

16 position.

17 Q. On page 17, in paragraph 55, you state that in 1994, there were

18 two forward command posts, the abbreviation being IKM, in order to

19 coordinate operations with the army of the Republika Srpska and with a

20 view to providing support to the Cazin and Cazinska Krajina and Fikret

21 Abdic. Do you wish to say that the RSK army formed the forward command

22 post and that the VJ security administration formed such a post at Kordun,

23 at Petrova Gora?

24 A. Yes.

25 Q. This parallel command post at Petrova Gora in Kordun was known as

1 the Pauk command; is that correct? And in paragraph 57 you go on to say

2 that according to my information, Martic and Celeketic opposed the

3 existence of a parallel command post at Petrova Gora. My question to you

4 is: Why?

5 A. Why they were opposed?

6 Q. Yes.

7 A. They were opposed to that because it was impossible for two

8 command posts to coordinate one action. You had to have one command post.

9 Q. If I understand you well, Martic and Celeketic thought that this

10 parallel post was being imposed on them?

11 A. Yes.

12 Q. And they were opposed to that?

13 A. Yes, they were opposed to that.

14 Q. On page 22, paragraph 71, you said that you had no information on

15 the possible involvement of the Army of Yugoslavia or the Federal Republic

16 of Yugoslavia in general or Perisic as the chief of the General Staff of

17 the VJ and Slobodan Milosevic in particular in the decision to shell

18 Zagreb on the 2nd and 3rd of May 1995. In the same paragraph, you state

19 that from -- that you heard from Mihajlo Knezevic that General Momcilo

20 Perisic ordered a VJ air force regiment stationed at Batajnica near

21 Belgrade to raise its alert status and prepare airplanes for strikes

22 against the Croatian forces outside the knowledge of Slobodan Milosevic.

23 This was August 1995, and Operation Storm. You go on to say that when

24 Milosevic found that out, the order was annulled, and no aircraft left

25 Batajnica. You learned that from Mihajlo Knezevic?

1 A. Yes.

2 JUDGE MOLOTO: How much longer do you intend to go, Mr. Perovic?

3 MR. PEROVIC: [Interpretation] Your Honour, I believe that I can

4 complete my examination in ten minutes. If you believe this to be

5 appropriate, in order for us not to resume the examination tomorrow, I can

6 complete my examination in some 10 to 12 minutes. Of course, if the

7 Prosecution agrees with that too.

8 MR. WHITING: Sorry, I don't know why I'm standing up but since I

9 am standing up, I can say, Your Honour, that the next witness actually is

10 not going to start testifying until Thursday. So I don't think there is

11 any reason to sit over the 7.00 time today. I think we can finish this

12 witness tomorrow.

13 JUDGE MOLOTO: If it doesn't terribly inconvenience you because in

14 any case there is still re-examination of the witness and questions by the

15 Bench, Mr. Perovic. But I don't mind if you just want to round off a

16 point and then you can carry on tomorrow.

17 MR. PEROVIC: [Interpretation] There are no problems, Your Honour.

18 I can complete my cross-examination of witness Raseta tomorrow.

19 JUDGE MOLOTO: Would this be a convenient moment?

20 MR. PEROVIC: [Interpretation] Yes, precisely.

21 JUDGE MOLOTO: Thank you very much, Mr. Perovic.

22 The Court will adjourn to tomorrow at quarter past 2 in the same

23 court. Thank you very much.

24 --- Whereupon the hearing adjourned at 7.03 p.m.,

25 to be reconvened on Wednesday, the 3rd day of May,

1 2006, at 2.15 p.m.

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25