Tribunal Criminal Tribunal for the Former Yugoslavia

Page 10638

1 Friday, 3 November 2006

2 [Open session]

3 [The accused entered court]

4 --- Upon commencing at 2.21 p.m.

5 JUDGE MOLOTO: Good afternoon. Just two housekeeping matters

6 before we call the next witness.

7 The first one is that the Chamber has received a motion for safe

8 conduct for Witness MM-121, and what we just want to raise with you,

9 Mr. Milovancevic, for the Defence, is that the Chamber is not yet in

10 possession of the 92 bis statement of this witness. I don't know whether

11 the Prosecution has a -- has it, but the Chamber doesn't and it looks like

12 this witness is going to be coming to testify very soon. What is the

13 position?

14 MR. MILOVANCEVIC: [Interpretation] Your Honour, as far as I know,

15 we are expecting that witness on Thursday, and we'll try to resolve the

16 matter as soon as possible, but I can't tell you anything at present. I

17 can't really answer your question now until I check it out with my

18 colleagues on the Defence team and I'll do that as soon as possible. But

19 quite certainly, the witness, according to the information we have, will

20 not be appearing before Thursday.

21 JUDGE MOLOTO: That is true, but the point is just that we don't

22 have to receive the statement just as the witness appears. I would

23 imagine the Prosecution, if they haven't received it yet, they also need

24 to use that statement to prepare. The Chamber also needs the statement to

25 prepare. And if I'm not mistaken, there are times when the Prosecution

Page 10639

1 wants to respond to the statement, to have certain things struck out or

2 amended or whatever. So we need time to do that. Okay? So what I'm

3 suggesting, therefore, is that if you can talk to your team at the next

4 break so that they can investigate this, and it would be nice if maybe by

5 sometime today you can give us an idea when to expect the statement.

6 Okay? I don't know whether Mr. Whiting for the Prosecution has anything

7 to add on that this.

8 MR. WHITING: Just that we have not received the statement. We

9 have repeatedly requested it from the Defence, and Your Honour is correct

10 that we would like to have it, and so we would be grateful for any

11 indication as to when it might be coming.

12 JUDGE MOLOTO: Okay. For the first time today I hear a voice

13 coming out this way as we speak. Is there an open -- an open microphone

14 somewhere?

15 Am I the only one who hears it?

16 There it goes. Okay. That's fine.

17 The next point was -- relates to the Prosecution's motion to

18 exclude the military expert's report of the Defence. I know that the

19 parties are still exchanging documents with regard to that motion, but

20 because of a request made in that motion that the Defence be asked to give

21 a -- a response, the Chamber would like to give some order, oral order, on

22 that request only. And it goes as follows: The Trial Chamber is seized

23 of the Prosecution's motion to exclude certain sections of the military

24 expert report of Milisav Sekulic filed yesterday 2nd November 2006. The

25 Trial Chamber notes that the Prosecution have requested an expedited

Page 10640

1 Defence response to this motion.

2 Thank you so much. It's off now.

3 The Trial Chamber finds that it is in the interests of justice,

4 particularly having regard to the scheduled date for the close of the

5 Defence case, that an expedited response be filed by the Defence.

6 However, the Trial Chamber finds that the Prosecution's requested date of

7 Monday, the 6th November is too short a deadline.

8 The Trial Chamber therefore orders the Defence to file any

9 response to the Prosecution's motion by no later than 4 p.m. on Thursday,

10 the 9th November 2006.

11 Okay. We can call in the next witness, Mr. Milovancevic.

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

13 MR. WHITING: We are receiving something on the English channel.

14 THE INTERPRETER: The interpreters apologise. The microphone was

15 on.

16 JUDGE MOLOTO: Mr. Milovancevic, are you able to give us the

17 name of the next witness and we can be writing it down while we are

18 waiting?

19 MR. MILOVANCEVIC: [Interpretation] Your Honour, the next witness

20 is Dragana Knezevic, Dragana Knezevic will be coming into court -- Dragan

21 Knezevic.

22 [The witness entered court]

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

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

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

Page 10641


2 [Witness answered through interpreter]

3 JUDGE MOLOTO: Thank you very much. You may be seated, sir.

4 THE WITNESS: [Interpretation] Thank you.

5 JUDGE MOLOTO: Yes, Mr. Milovancevic?

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

7 Examination by Mr. Milovancevic:

8 Q. Witness, good afternoon.

9 A. Good afternoon.

10 Q. As the lead counsel in the Defence team, I'm going to conduct your

11 examination today, and before we go on to your CV and asking you questions

12 I'd like to ask you one thing. Since you and I speak the same language,

13 would you please make pauses between my question and your answer, to

14 facilitate the work of the interpreters. And I should also like to ask

15 you if possible to speak as slowly as possible for the same reasons.

16 A. Yes. But might I just say something?

17 Q. Go ahead.

18 A. Since I speak quickly, my natural speech is fast, please slow me

19 down when I go to fast and I'll do my best to speak as slowly as possible,

20 although it's not in my nature to do so.

21 Q. Can you give us your full name and surname and your date of

22 birth?

23 A. My name is Dragan Knezevic, the 2nd of January 1962.

24 Q. Where were you born? And what ethnicity are you and what

25 religion?

Page 10642

1 A. I was born in the village of Cetina, Knin municipality, and I'm a

2 Serb and I'm Orthodox.

3 Q. Thank you. What education have you had and where have you worked?

4 A. I completed secondary school of internal affairs in Zagreb and I

5 worked as a policeman doing patrol work in Zagreb, in the Crnomerec police

6 station until 1983. In 1983, I moved to Djordjiceva Street to join the

7 crime and drugs department there and in 1985 I moved to Knin to the police

8 station of Knin.

9 Q. Thank you.

10 A. You're well come.

11 Q. Can you tell us how you came to move to Knin and what work you

12 were engaged in, in the Knin police station, what was your job there?

13 A. I asked to be transferred from Zagreb to solve my accommodation

14 problem. That is to say I didn't have adequate accommodation in Zagreb so

15 I asked to be transferred to Knin. That is why I moved. And I worked in

16 the patrol section of Knin, on the beat.

17 Q. Thank you. You were born in the village of Cetina. Can you tell

18 us where that village is located in relation to Knin, how big is it, what

19 is the composition of the inhabitants?

20 A. The village is southeast of Knin, in the direction of Sinj. The

21 village -- most of the inhabitants, 98 per cent, in fact, were Orthodox.

22 The total number of inhabitants was 1500 or 600, not more than that.

23 There were 270 households roughly.

24 Q. Can you tell us, since we are discussing this topic, what the

25 nearest neighbouring villages are?

Page 10643

1 A. The neighbouring village on the left is Kosola [phoen] and

2 Vrlika. Then Ciljane [phoen] is in front and Bosna on the right, and the

3 village of Kijevo.

4 Q. Thank you.

5 A. You're welcome.

6 JUDGE MOLOTO: May I interrupt you a little bit, Mr. Milovancevic?

7 Was this witness not supposed to be 92 bis fully?

8 MR. MILOVANCEVIC: [Interpretation] Your Honour, it says in my

9 notes that this is a viva voce witness. That's why I set off in the way I

10 did. Perhaps there was a misunderstanding because there were a number of

11 people named Knezevic.

12 JUDGE MOLOTO: You're right. I'm wrong.

13 MR. MILOVANCEVIC: [Interpretation]. Thank you. I feel better

14 now.

15 Q. You said you were educated in Zagreb and that you worked in Zagreb

16 in the police force and after that, that you moved to Knin and worked for

17 the police force there. Can you tell us up to 1990, how would you

18 describe interethnic relations? And when I say that, I mean interethnic

19 relations in the police force, the policemen, the Serbs, the Croats and

20 others on the police force?

21 A. Well, you couldn't notice any difference in ethnic affiliation.

22 It did not gain expression in any way.

23 Q. Thank you.

24 A. We all thought as one.

25 Q. What were the interethnic relations in your village, and in Knin,

Page 10644

1 when you arrived there to take up your work from Zagreb, up until 1990?

2 A. Well, in Knin and the surrounding villages, the villages of the

3 municipality, the interethnic relations were extremely proper. Great

4 respect and tolerance for each other, a lot of understanding, people

5 helped each other, they would go to each other's feast days, holidays,

6 festivities, they would socialise, and it was a pleasure to work in a

7 place like that.

8 Q. Did those relations change at any point in time and what was the

9 basic reason for that, if they did?

10 A. Well, the relations became disturbed in 1989, as far as I

11 remember. In 1989, the reason why the relationships became disturbed and

12 upset was the campaign launched by the Croatian Democratic Party, which

13 introduced unrest among the people with the slogans it put out and its

14 calls for a sort of Croatian state that they had envisaged in that time.

15 I don't know what kind of state they envisaged because it was still

16 Yugoslavia at that time, but fear was instilled in the people, fear of

17 these rallies that were being held, demonstrations, and so on. The

18 various slogans put out, the graffiti on the walls that appeared. You

19 found slogans in the media, newspapers, everywhere where there were

20 Croatian inhabitants. I can't say that this is true of all the Croatian

21 inhabitants. They were extremists mostly, aided and abetted by the newly

22 established powers that be.

23 Q. Thank you. Do you remember when the first multi-party elections

24 were held in Croatia just briefly?

25 A. Well, yes, I do. But I can't comment on that.

Page 10645

1 Q. Thank you. Now, after those elections, this situation as you

2 described it, did it deteriorate or improve?

3 A. The situation became worse from one day to the next. We tried to

4 calm the situation down by holding various negotiations, talking to people

5 that we knew, that we had gone to school with, to ask for understanding on

6 their part, but all to no avail because the official authorities in

7 Croatia were not interested in peace. And that wasn't my own feeling,

8 that was what the population over there felt. Not only the Serbs but the

9 Croats, too, shared that view.

10 Q. You said that you tried to calm the situation down.

11 A. Yes, I did, that's right.

12 Q. You were working as a policeman, so how did you go about trying to

13 calm the situation down? What did you do?

14 A. Well, as I was working in Knin four or five years before the war,

15 and that's enough time to get to know the population of a municipality

16 like Knin which is a small municipality. I was good friends both with

17 Croats and Serbs. I went to attend their feast days, weddings, birthdays,

18 and so on. There were no tensions. It didn't matter that the person was

19 a Croat or a Serb. And negotiations were held in 1990, in August, the

20 month of August, the police forces from Solina, special units commanded by

21 Romac Ivica, who was a schoolmate of mine from Zagreb. We went to school

22 for four years together. I went to Zagreb, he went to the military

23 academy in Belgrade, and then he became commander of the special units in

24 Solin and on the 20th of August, round about that date --

25 Q. Just a moment, witness, please. We'll come to that in due course.

Page 10646

1 Thank you, you've answered my question. Now I'll just move on, and we'll

2 come to what you were saying in due course. You said you, "took part in

3 the negotiations and we tried to calm the situation down and the official

4 authorities were not in favour or didn't want peace." That's what you

5 said.

6 Now, how can you say that? What are the grounds for you saying

7 that? You were a policeman and now you are presenting us with that view?

8 MR. BLACK: I apologise for the interruption. Your Honour, I

9 would object on the fact that this issue of negotiations and things like

10 that, as far as I can see, it's not on the 65 ter summary. It's also

11 pre-1991, although it's not one of the specific topics that was listed by

12 the Chamber the other day, but I would object on that ground.

13 JUDGE MOLOTO: Mr. Milovancevic, I've actually had my finger on

14 the button to intervene myself to ask if -- is this not part of the

15 background information that we agreed yesterday or the day before that

16 we can skip and get to the real issues that go to the acts and conduct

17 of the accused? We already know, as the Chamber, the position of the

18 Defence on these topics. We know the position of the Prosecution on

19 these topics. We note that. So maybe if you can just move on to the

20 charges themselves.

21 MR. MILOVANCEVIC: [Interpretation] Your Honour, I am fully

22 cognizant of what you just said. I am bearing that in mind. I just wish

23 very briefly to deal with one topic and that is the behaviour of the

24 members of the SUP of Knin, and the Prosecution claims that Mr. Martic is

25 responsible for their attitude and relationship towards the population and

Page 10647

1 the situation, and so on. So it was only along those lines that I wished

2 to --

3 JUDGE MOLOTO: Don't mention those things because that's part of

4 the testimony you want to extract from the witness. You know? I don't

5 know why you keep doing this, Mr. Milovancevic.

6 MR. MILOVANCEVIC: [Interpretation] Your Honour, I won't deal with

7 that topic any more. So I withdraw the question, my last question. I

8 didn't wish to suggest or lead the witness in any way. I just wanted to

9 respond to the remarks made by the Prosecution, because Mr. Martic is

10 being held for everything that a living being can be held responsible for

11 and stands accused of --

12 JUDGE MOLOTO: Will you please stop. Will you deal with the

13 objection, then, by your learned friend that what you are testify -- what

14 you are eliciting from the witness at this stage is not on the 65 ter

15 statement.

16 MR. MILOVANCEVIC: [Interpretation] In the statement summary, in

17 paragraph 4, it says that the witness took part in talks with the Croatian

18 side in which they agreed, et cetera, et cetera, to de-block the roads,

19 the JNA positions and so on. So if the witness took part in the talks, I

20 assume that that is the subject that I'm dealing with now.

21 JUDGE MOLOTO: Yes Mr. Black?

22 MR. BLACK: Your Honour, I suppose it's conceivable that I'm

23 mistaken but when you -- you read the summary this is talking about Kijevo

24 and the events in Kijevo in August of 1991. Not 1990, which seemed to be

25 what we were talking about now. And I think it was quite clear that the

Page 10648

1 witness has been discussing August 1990. It's a year earlier than what

2 appears to be these talks with the Croatian side on which it was agreed

3 that the blockade be lifted. Apparently it's referring to a blockade of

4 Kijevo. I don't see how that could possibly refer to August of 1990, Your

5 Honour.

6 MR. MILOVANCEVIC: [Interpretation] I accept that, Your Honour.

7 Yes, I accept that objection, and I'll move on.

8 JUDGE MOLOTO: Thank you, Mr. Milovancevic. Please move on.

9 MR. MILOVANCEVIC: [Interpretation] Thank you.

10 Q. When you refer to this disruption of relations that used to be

11 good, can you tell us how was this manifested in 1990? What manifestation

12 of forms did it have, did it assume, in your place, where you came from,

13 on the ground?

14 JUDGE MOLOTO: Mr. Milovancevic, your learned friend says

15 according to your statement, this witness's statement talks of relations

16 in August of 1991 in Kijevo, not 1990 in Knin. Now you're going back to

17 1990 in Knin.

18 MR. MILOVANCEVIC: [Interpretation] Your Honour, we informed our

19 colleagues from the OTP today by additional information that this witness

20 would be also dealing with such subjects as the signing of the petition in

21 June in 1990, then another petition as well.

22 JUDGE MOLOTO: Why didn't you say so when you objected,

23 Mr. Milovancevic? You should have told him that. That was the answer.

24 Then he could have dealt with it. Instead you accept the objection.

25 MR. MILOVANCEVIC: [Interpretation] I took the objection to mean,

Page 10649

1 Your Honours -- I thought that he was objecting to the witness's

2 participation in the negotiations, that that is what his objection

3 specifically referred to.

4 JUDGE MOLOTO: His objection is you are leading evidence on a

5 period and place that you have not mentioned in the 65 ter statement.

6 That's the objection. Unless I misunderstand the objection.

7 MR. BLACK: I think slightly, Your Honour. Maybe I wasn't clear.

8 Mr. Milovancevic is quite righting that my specific objection was that

9 the -- whatever negotiations might have been in August of 1990, that was

10 not on the 65 ter summary. Where it might have been confusing is I also

11 mentioned that all these events are pre-1991 and I referred to Your

12 Honour's decision earlier in the week, but -- it's true that relations in

13 Knin are in the 65 ter summary, just so that's clear, nothing about

14 negotiations or something like that but the general topic of relations is

15 in the 65 ter summary.


17 MR. BLACK: Yes, Your Honour.

18 JUDGE MOLOTO: So he may proceed.

19 MR. BLACK: If Your Honour is inclined to hear more evidence about

20 relations in 1990, then he's entitled --

21 JUDGE MOLOTO: The Trial Chamber is not [inaudible] earlier in the

22 week, but Mr. Milovancevic insists so I don't know what to do here.

23 Yes, Mr. Milovancevic. Go ahead.

24 MR. MILOVANCEVIC: [Interpretation] Thank you, Your Honour. Can I

25 now move on with your permission to some very concrete things?

Page 10650

1 Q. Mr. Witness, do you know anything about a petition that was signed

2 by the members of the police station in Knin? When was this and what was

3 this about?

4 A. Yes. I know about that petition. I was a signatory of it also.

5 I believe that was in June 1990. I'm not quite sure but I believe that

6 that was the date. And this petition was signed after our colleagues from

7 Zadar had also signed a petition and referred it to all institutions in

8 the former Republic of Yugoslavia and the Republic of Croatia, to the

9 SUPs, to the Ministries of Justice, to all the factors in the state. They

10 were revolting because of the emblems --

11 Q. Thank you. Thank you. I will have to interrupt you at this

12 point. When we speak about this petition by policemen in the station in

13 Knin, can you tell us what the basic reason for that petition was? What

14 was it that you wished to achieve by it, in your view?

15 A. The reason for the petition were the emblems that were being

16 offered to us by the new Croatian authorities, which, actually, conjured

17 up images of the dark past of the Second World War in our minds, in which

18 past many people had lost their lives.

19 Q. Do you know whether that petition -- first of all to whom was this

20 petition addressed?

21 A. It was addressed to the Ministry of the Interior of the Republic

22 of Croatia, and to the federal Ministry of the Interior, the Ministry of

23 Defence, the SUPs in Croatia. Some supported it, others didn't, but those

24 were the addressees.

25 Q. Thank you. What was the attitude of the policemen employed in the

Page 10651

1 Knin police station vis-a-vis that petition? How many signed it, how many

2 didn't, do you remember that?

3 A. 90 per cent of them signed it. Some were absent because they

4 had -- they declined to sign it because they thought that perhaps they

5 would remain without employment if they did, but most of them did sign it.

6 Q. I believe that it was in July 1990 that a petition was, in fact,

7 published in the press. Do you know which petition that was?

8 A. That is the petition which we signed in Knin.

9 Q. Thank you. What did you want to achieve as policemen by that

10 petition? What was your objective?

11 A. Our objective at that time was primarily to prevent any blood

12 letting, which could be felt in the air. The people could feel it. The

13 policemen could feel it. It was hovering in the air and people were

14 expecting things to happen and things did happen later. As the state of

15 Yugoslavia existed at the time, we were loyal to that state at the time,

16 and we couldn't accept those emblems because those emblems were precisely

17 offering that -- this something else which indeed happened later.

18 Q. In addition to the petition signed by the policemen in Knin, there

19 was also a petition signed by policemen in Zadar. What kind of a petition

20 was that? Do you know that?

21 A. Yes. I know. The petition in Zadar was signed by almost 150

22 members of the regular police force of the then state, many people who

23 were professionally trained to discharge those duties. That was a mixed

24 composition. In fact, the ratio was 70 to 30 per cent. 70 per cent of

25 them were Croats and 30 were Croats [as interpreted] and a total of 150

Page 10652

1 signed the petition and they also were protesting against the evil that

2 was in the offing.

3 Q. Thank you. Would the usher please deliver this document to the

4 Trial Chamber, to our learned colleagues from the OTP, to the witness, and

5 we also have copies for the interpreters. The translation, Your Honours,

6 is after the B/C/S text.

7 JUDGE MOLOTO: Thank you, Mr. Milovancevic.

8 MR. MILOVANCEVIC: [Interpretation].

9 Q. Can you read at the very top of this document, who is this letter

10 addressed to, who is it sent by, and who are all the addressees to whom it

11 is to be delivered?

12 A. "Open letter of the policemen of SUP Zadar to the Ministry of the

13 Interior of the Republic of Croatia."

14 THE INTERPRETER: And the interpreters still haven't got their

15 copy.

16 THE WITNESS: [Interpretation] So: "Open letter of the policemen of

17 SUP Zadar to the president of the Republic of Croatia, to the government

18 of the Republic of Croatia, to the Minister of the Ministry of the

19 Interior of the Republic of Croatia, to the Minister of National Defence

20 of the Republic of Croatia, and to all the Secretariats of the Interior in

21 the Republic of Croatia. To the Presidency of the SFRY. To the Federal

22 Executive Council. To the Federal Secretariat of the Interior's secretary

23 and to the Federal Secretary of National Defence."

24 MR. MILOVANCEVIC: [Interpretation].

25 Q. Thank you.

Page 10653

1 A. You said that I should read the first sentence?

2 Q. No, thank you. That will suffice. Please turn to the very end of

3 this text. That is page 3 in the B/C/S version, which bears the date and

4 the place where this letter was drafted and it is followed by a signature.

5 Can you read for us where this letter was written and on what day?

6 A. In Zadar, on the 5th of November 1991.

7 THE INTERPRETER: Interpreter's correction: 1990.

8 MR. MILOVANCEVIC: [Interpretation].

9 Q. In connection with this letter, I'm going to turn your attention

10 to two or three paragraphs. The second paragraph on the first page.

11 "Why, after the order of the MUP of the Republic of Croatia on

12 activating reserve police forces, why were weapons and ammunition

13 distributed to people who had not originally been designated to serve on

14 the reserve force and who had not previously gone through the compulsory

15 checks? Why were these members of the police reserve force [without

16 uniforms] as well as the newly admitted and trained-in-a-hurry policemen

17 allowed to bring long barrelled and short barrelled weapons and

18 ammunitions to their houses, if it is known that they do not have any

19 legal authorisation whatsoever to undertake any kind of police actions and

20 thus also no right to possess weapons?"

21 Then the fifth paragraph, I'm going to read for you the fifth and

22 the sixth paragraphs on this page.

23 "Why has the special purposes unit of this SUP been disbanded? It

24 was a nationally mixed unit and regular in every respect, [declared to be

25 the best special purposes unit in the whole Croatia]." This last part was

Page 10654

1 in brackets. "After that, this unit was created again exclusively from

2 the newly accepted policemen of Croatian nationality, the great majority

3 of whom were over 25, meaning that they did not meet one of the basic

4 requirements for the creation of such a unit. Some of them are not

5 sufficiently qualified, some of them have finished only primary school."

6 And then the last paragraph: "Why have policemen of Serbian

7 nationality been excluded from all the above-mentioned by which

8 differentiation on a national basis is being done between members of the

9 service without any grounds and justification. This causes justified

10 revolt, doubt, dissatisfaction, uncertainty and distrust among personnel

11 of both Serbian and Croatian nationalities."

12 Do you see this text, Mr. Witness?

13 A. Yes, I do.

14 Q. Does this text which is in this -- on these pages, does it

15 correspond to reality, as far as you know?

16 A. It fully corresponds to reality.

17 Q. Thank you.

18 MR. MILOVANCEVIC: [Interpretation] I propose, Your Honours, that

19 this document be admitted into evidence.

20 JUDGE MOLOTO: But you have read it all, virtually all. Do you

21 still need it in evidence after you've read it?

22 The document is admitted into evidence. May it please be given an

23 exhibit number.

24 MR. MILOVANCEVIC: [Interpretation] Your Honour, there are 142

25 signatures and there is more text that I did not wish to burden the Trial

Page 10655

1 Chamber with.

2 JUDGE MOLOTO: That's fine.

3 THE REGISTRAR: Your Honours, this becomes Exhibit number 1005.

4 JUDGE MOLOTO: Thank you very much.

5 Yes, Mr. Milovancevic.

6 MR. MILOVANCEVIC: [Interpretation].

7 Q. Can you tell us what the reaction was after you sent this letter

8 from the Knin police station? Was there any reaction to it? Were there

9 any consequences that you had to bear? Were any measures taken?

10 A. Well, we were laid off, all of us. Those were the direct

11 consequences, as far as we were concerned, the members of the SUP Knin.

12 JUDGE HOEPFEL: Excuse me, Mr. Milovancevic, was the witness one

13 of the signatories? Could you establish that? I'm just asking because

14 the witness said something about "we".

15 MR. MILOVANCEVIC: [Interpretation] Your Honours, the witness has

16 explained that he signed the letter from the Knin station and I'm going to

17 ask him about this other one referred to in your question.

18 Q. Mr. Knezevic, you have explained that you signed the police

19 petition from Knin. Were you a signatory of this petition as well?

20 A. No. No. But this one we just received by way of information. We

21 did not sign it.

22 Q. In order to clarify things to the full, who signed this other

23 petition that we just saw now?

24 A. Our colleagues from the Zadar SUP did.

25 Q. So I'm not mistaken to say that members of the SUP of the

Page 10656

1 Secretariat of internal affairs in Zadar, right?

2 A. Yes.

3 Q. Do you know anything about barricades? When did they appear,

4 Mr. Knezevic?

5 MR. BLACK: I'm not sure how Your Honour wants me to deal with

6 this but this is a specifically mentioned topic from which the Trial

7 Chamber advised the Defence to refrain from leading evidence. It's at

8 transcript page 10471, line 14, the barricades.

9 JUDGE MOLOTO: Mr. Milovancevic? Let's try to move on,

10 Mr. Milovancevic, on to the charges. I think this -- the question of

11 barricades, we indicated that we have heard a lot about them.

12 MR. MILOVANCEVIC: [Interpretation] Your Honours, the objection is

13 apparently logical but it is not grounded. I'm not trying to deal with

14 the subject of barricades as such. What I'm interested in is a specific

15 situation in the village of Civljani where the witness was, and he knows

16 how the special police forces, Croatian police forces, acted on that

17 particular occasion in 1990 so that this is not covered by the instruction

18 of the Trial Chamber.

19 JUDGE MOLOTO: Why don't you ask him clearly about that, about the

20 situation in the village of Civljani rather than about barricades?

21 MR. MILOVANCEVIC: [Interpretation] Yes, you're quite right,

22 Your Honour. I shall rephrase my question along those lines.

23 JUDGE MOLOTO: Thank you.

24 MR. MILOVANCEVIC: [Interpretation].

25 Q. What do you know in relation to events at the barricades in the

Page 10657

1 village of Civljani? Do you know when that was approximately and what

2 actually happened?

3 A. Yes. I'm aware of that. I know about it. But I will have to go

4 into some detail to explain to the Trial Chamber. I believe that it was

5 the 20th of August. But don't hold me to that. I think it was on the

6 20th of August at 2315 hours, it was 1990, yes, 1990, I apologise, the

7 20th of August, 1990 at 2315 hours in the evening. I was coming from --

8 back from work from the second shift in Knin, and I reached Civljani at

9 about quarter to 11. There were about 15 to 20 people standing around

10 next to a shop. Some of them were armed with hunting rifles, hunting

11 weapons. They had trophy weapons, we are talking about 1990, that's the

12 year, and at 2315 hours, you could hear somebody over the megaphone. It

13 was night time. And as that part of the road is surrounded by hills, it

14 sounded terrible. And the people dispersed when they heard this megaphone

15 just a little after 11.00 at night.

16 Q. I have to interrupt you, Witness, but in order to find your way on

17 the map, if you look at page 32 of the map, the atlas, you have Vrlika,

18 Kijevo, Cetina, and the other villages on both sides of the road, and

19 that's the area that the witness is referring to now.

20 Continue, please, Witness.

21 A. There was a voice which warned, "Take down the barricade," over

22 the megaphone, the barricades and obstacles on the road. There were none

23 but the people were there. Then the next time over the megaphone there

24 was a voice saying, "Take away the barricade or else we'll resort to other

25 measures." And the third time it said, "I hereby order that the barricade

Page 10658

1 be removed." I saw that the situation was serious and I happened to be

2 there. I recognised the voice of Romac Ivica, my school friend. I went

3 out on to the road and I shouted to him, "I'm coming to talk to you."

4 MR. MILOVANCEVIC: [Interpretation] Just a moment, Witness.

5 JUDGE NOSWORTHY: Mr. Milovancevic, before you proceed you didn't

6 give us a grid number and letter for page 32 of the map, in relation to

7 the location.

8 MR. MILOVANCEVIC: [Interpretation] Yes, Your Honour. It is page

9 31, and it is C 2, the grid reference is C 2. In the middle of the atlas,

10 the map. At the level of -- it is between Knin and Drnis on the right.

11 JUDGE NOSWORTHY: Thank you.

12 MR. MILOVANCEVIC: [Interpretation].

13 Q. Please continue, witness, and I apologise for interrupting.

14 A. Thank you. I went to see Mr. Romac, went up to Mr. Romac. I

15 recognised me -- he recognised me, I recognised him. And when I asked

16 him, "What are you doing there?" He said, "And what are you doing here?"

17 And I said, "I'm doing the same as you." At that point in time -- well,

18 this exchange went on for just a few minutes. And then somebody shot,

19 fired a shot from the left side, as far as I was able to notice. And then

20 shooting started in a circle around us. We didn't know who was doing the

21 shooting. There was panic among the people. You could hear them rushing

22 up the hill, Kozjak hill. It was night-time, so you could hear all this.

23 And in that shooting, my colleague, my former school colleague, said,

24 "What's all this about?" And I said, "I don't know." And I really

25 didn't. I just said that he and I were in the same situation.

Page 10659

1 Q. Thank you. That will do. Just stop there. Now, when you started

2 talking to him, up until that moment, did you discuss why they had come,

3 what their task was?

4 A. Yes. I asked my school friend, my colleague --

5 JUDGE MOLOTO: Why who had come? You asked him, "Did you discuss

6 why they had come." Who are the "they" and their task?

7 MR. MILOVANCEVIC: [Interpretation] We'll hear through the

8 witness's answers who the "they" were.

9 Q. Could you explain to us who those others were, the "they," and who

10 this colleague or friend, school friend of yours, was representing when he

11 spoke over the megaphone?

12 A. Romac Ivica was my colleague. He was commander of the special

13 units from Solin, Solina. When I asked him what his intention was in

14 coming there, he said, "To remove the barricade." I said, "The barricade

15 is no problem because there is no barricade. And what next?" And he

16 said, "It depends on the orders. I understand police work. Orders are

17 issued by a superior authority." And that's when the shooting started.

18 My colleague asked me what I could do about that, to calm the situation

19 down. And I said, "Hand over that megaphone of yours." The megaphone was

20 in a Landrover, the man who handed me the megaphone -- I got into the

21 Landrover and I asked the people to stop shooting. They didn't react at

22 all. The first time when I said this they didn't react. When I said it a

23 second time, I repeated, "Do not shoot." And the third time I introduced

24 myself and I told them not to shoot, that it was Dragan Knezevic talking

25 to them, addressing them, and then the shooting stopped. And then my

Page 10660

1 colleague Romac withdrew his men, the men who had been deployed in a

2 firing line. I did not know that until then. Buses were there. There

3 were 60 people there who were fully equipped. This special unit, they had

4 flak jackets, helmets, snipers, automatic weapons, they had everything.

5 Q. May I stop you there? You said that they were people equipped

6 with a full BK. Could you tell us what you mean by BK?

7 A. They are combat kits. BK are combat kits.

8 Q. So these were with specials, members of the special unit from

9 Solin, and who did they belong to? Whose command were they under?

10 A. They were under the command of the SUP of Croatia.

11 Q. Thank you. What happened next?

12 A. The buses started moving along the road without their lights on

13 because it was night time. I used the megaphone again and told the people

14 that heard me and who knew me that I would go in my car in front of them

15 to Vrlika and I said, "If you're going to shoot, shoot at me." That's

16 what I said to them. And then I went to the police station in Vrlika with

17 this colleague of mine, this man named Romac and he invited me to have a

18 whiskey. We stayed there for about an hour. So I went to their police

19 station in Vrlika. The man did withdraw his men and we continued to

20 cooperate very well. We held negotiations to quell the people in Civljani

21 and the other villages.

22 Q. We'll get to that witness but since you mentioned these

23 negotiations in that village and the other two villages, now this good

24 cooperation during the negotiations it was period is this in view of --

25 relating to these three villages?

Page 10661

1 A. 1990 to 1991 until the redarstvenici forces arrived in Knin, when

2 everything changed and the situation deteriorated.

3 JUDGE MOLOTO: I have a question to ask before we move on. The

4 people who were shooting, were they the people, the 15 to 20 people that

5 you found standing at the shop or were they part of this unit of -- that

6 was travelling in buses?

7 THE WITNESS: [Interpretation] No, Your Honour. Those were the

8 locals, those 15 or 20 people, and around them there were all the

9 villagers. They were locals of the villages but I don't know who. They

10 were shooting out of fear, because to hear a megaphone at 2315 hours,

11 that's a terrible sound to behold.

12 JUDGE MOLOTO: They were the people who were shooting, the 15 to

13 20 people?

14 THE WITNESS: [Interpretation] Well, whether it was one of them, I

15 can't say. I was with Mr. Romac negotiating so I can't confirm who

16 actually did the shooting. Because behind us there was a Croatian

17 village, there was shooting coming from there as well, from that location

18 so I can't really say. Everybody was shooting, the Orthodox people were

19 shooting, the Croats were shooting, and we were in the centre holding

20 talks, negotiations.

21 JUDGE MOLOTO: The shooting didn't come from your friend's unit,

22 the people in the bus, in the buses? Didn't come from those?

23 THE WITNESS: [Interpretation] No. They were distributed in a

24 line.

25 JUDGE MOLOTO: Thank you.

Page 10662

1 Thank you, Mr. Milovancevic.

2 MR. MILOVANCEVIC: [Interpretation].

3 Q. And linked to that question that Judge Moloto just asked you let's

4 try to clarify one more point. When this shooting started, was it

5 shooting at you and the policemen you were talking to or was it something

6 else again?

7 A. No. Nobody was wounded or killed. It was mostly shooting up in

8 the air, I assume, because none of us, nobody was wounded or injured or

9 killed while I was talking to Romac.

10 Q. Did you establish what the assignment was in talking to Romac and

11 others? What was the assignment of this special unit made up of the 60

12 men you mentioned with the combat kits and all the rest of it?

13 A. Well, we couldn't know what the assignment of that unit was but we

14 assumed that they were to advance towards Knin. That was my assumption.

15 The next day, we learnt that in Drnis, the police had thrown down their

16 arms and did not wish to attack Knin, and this was a synchronised action

17 which was an abortive one. But we learned that the next day when our

18 colleagues from Drnis arrived, when they threw down their arms and left

19 the SUP. But the previous night we didn't know about any of this.

20 Q. These police forces from Drnis Zadar and Sinj, whose forces were

21 they, under whose authority?

22 A. Well, the Republic of Croatia.

23 Q. Thank you. Now, after this event, what happened next?

24 A. After this occurrence, I and Mr. Romac, that is my colleague,

25 Romac, took it upon ourselves, and we informed Mr. Martic about this, to

Page 10663

1 negotiate with the people, to try and calm the situation down, and he lent

2 his support. We went to the village of Lelasi and I had another colleague

3 in that village. He occupies a high-ranking post in Croatia today. We

4 went to his house, Mr. Romac and I did, and we talked to the locals there.

5 Q. Just a minute. Can you tell us the village of Lelasi, what ethnic

6 composition is it?

7 A. It's a 100 per cent Croatian village, Croatians.

8 Q. Thank you. Now tell us what you talked about?

9 A. We discussed the security and safety of the people, to see what

10 was going on, what was bothering them, how to reduce tensions, how to calm

11 the situation and the people down, and the people accepted this. They

12 said they were in favour of law and order and peace, for people and goods

13 to be able to move around freely, that there should be no check-points or

14 control points along the roads, the army held a buffer zone in the area.

15 We went to the village of Civljani and also talked there, to the locals

16 there, and they are exclusively an Orthodox population. I, and Mr. Romac

17 talked to the people there. They said they it were just interested in

18 having quiet time and going about their work so we did well there too. We

19 came upon a good reception.

20 Q. Can you tell us, please, in this village, Lelasi and Civljani,

21 when was this?

22 A. That was in August 1990.

23 Q. Thank you. Now, what happened next?

24 A. We visited the village of Kijevo next. There was a larger meeting

25 there, there was Romac, there was Zeljko Golisija from Split. He was the

Page 10664

1 chief of SUP Split. And president of the local commune, Joso Juric-Orlic

2 was there. Petar Alvir was another man. And another colleague who

3 happened to come by and joined in the meeting. In Kijevo we discussed

4 having the situation return to normal, that people could travel to see

5 Sinj and Knin normally. What happened on one occasion was that a bus from

6 Knin to Cetina was stoned along the route. I drew their attention to

7 that. Mr. Joso Juric said that that was something that the children had

8 done, and I said, "They are your children, children from Kijevo, sir."

9 And I said, "They are our children, too, which have to be better brought

10 up, if they are not brought up already." And he said, "Well, I can do

11 nothing about the children."

12 Any way this happened several times. We discussed others matters

13 at the meeting, too, which were not linked to the war. But the situation

14 became more complicated when some 300 people gathered together calling for

15 arms, and they were in front of the school, the school building in Kijevo.

16 Also at the meeting there was a teacher named Varnica - I don't know what

17 his first name was - and he said, "They are asking for arms," and I had

18 just arrived to the negotiations. He said, "You're provoking us." I said

19 "No, I came to your village with no weapons, well intentioned, I wanted

20 to talk to the representatives of the village and the police to calm the

21 situation." Mr. Romac went outside, saw that the situation had come to a

22 head, and that they were calling for bloodshed. We made -- we passed

23 through this group, went to our car, and took off. Thanks to Mr. Romac,

24 we were able to do that.

25 Q. Do you know anything about the establishment of the police station

Page 10665

1 in Kijevo, the MUP of Croatia police station, how it was set up in Kijevo?

2 A. The police station, Postaja as it was called in Kijevo, suddenly

3 emerged one morning. There was no need to set up a police station in

4 Kijevo which numbered at the time 150 men, for a small village with 1500

5 or 600 inhabitants. People lived in Zagreb, in Split and so on. And

6 that's when the problems started, that's when the big problems started.

7 As far as I was concerned it was a sort of army.

8 Q. Well, tell us where -- who did the SUP of Kijevo come under?

9 A. The SUP of the Republic of Croatia, that is to say the Ministry of

10 the Interior of Croatia. I think the headquarters were in Split, perhaps,

11 or Sibenik.

12 Q. Thank you. Who made up this police station in Kijevo or police

13 department in Kijevo and do you know what kind of equipment those people

14 had?

15 A. Yes. I talked to the man who was commander in Kijevo, Mr. Vucic.

16 I talked to him, and when they entered Kijevo to set up that police

17 station, they put up check-points at the entrance and exit to Kijevo on

18 three roads around Kijevo and they controlled the whole area, and

19 mistreated the people. They mistreated small children. I know about

20 several instances. Mr. Vucic had on a camouflage uniform, he was wearing

21 a camouflage uniform, which didn't exist where we were from at that time.

22 Whose it was, I don't know. He had short-barrelled weapons at the -- a

23 short-barrel weapon at the negotiations but the others had weapons and

24 flak jackets, bullet-proof vests. Mr. Vucic was born in Kasteli. I know

25 that in talking to him. Mr. Romac attended those negotiations as did a

Page 10666

1 representative of the army, Babic Dusin was his name. The object of the

2 negotiations was to lift the blockade on the Vrlika-Knin road or

3 Knin-Sinj-Vrlika road, because the village of Kijevo cut off all

4 communication with our basic municipality, that of Kijevo, and we were

5 under siege. We were encircled.

6 Q. Thank you. When you said cut off all communication, who do you

7 mean when you say us?

8 A. I mean the villages of Cetina and Civljani, because I lived there

9 and I couldn't go to work because the blockade lasted for a month. And

10 this was in 1991.

11 Q. Before we take our break, I shall ask you another question. Was

12 this road through Kijevo the only road? Couldn't one take another perhaps

13 longer and safer and passable road?

14 A. No. This was the only road. One would only walk across the hill,

15 over the hill, or take the road on the other side via Sinj which we

16 couldn't do because we were blockaded. We were surrounded. We had no

17 exit.

18 Q. These negotiations which involved the commander of this police

19 station, where were they held?

20 A. They were held in a tent right on the outskirts of Kijevo. So at

21 the very entrance to Kijevo, in a military tent which was make shift

22 facility offered by the army and we agreed that the road communication

23 would be left to the army and the army was in charge of that particular

24 section of the road, and was to see to it that there was no bloodshed,

25 that there should be no clashes between the villagers of the surrounding

Page 10667

1 villages. So the army was in control of the three buffer zones separating

2 the people in the villages where emotions were already running very high.

3 Q. These three buffer zones were between what villages, whose

4 villages?

5 A. Between Orthodox and Croatian villages.

6 Q. Thank you. For how long did those buffer zones exist and did they

7 function? Did the JNA manage to perform its duty, that particular task?

8 A. It was -- they were honoured, they were respected for a while. We

9 all abided by them, and after a while, Mr. Vucic -- Mr. Vucic also

10 respected them for a while and allowed communication to unfold, but at

11 night nobody could use the road except the army, possibly some people

12 could go but with escorts.

13 Q. This last thing which you said, does that mean that it was only

14 possible to pass through Kijevo if accompanied by the army, if escorted by

15 the army?

16 A. Yes, that is what I said.

17 MR. MILOVANCEVIC: [Interpretation] Your Honours, I believe that

18 now is a convenient time for our break.

19 JUDGE MOLOTO: Thank you very much, Mr. Milovancevic. We will

20 take a break and come back at 4.00. Court adjourned.

21 --- Recess taken at 3.29 p.m.

22 --- On resuming at 4.00 p.m.

23 JUDGE MOLOTO: Yes, Mr. Milovancevic.

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

25 Q. Mr. Knezevic, the issue we discussed before the break was the

Page 10668

1 situation in Kijevo, and the police station there. You mentioned the

2 buffer zones set up by the JNA. Which part of the year was that, do you

3 recall, or at least which year it was?

4 A. That was 1991, I believe.

5 Q. Thank you. You said that for a while the agreement was honoured

6 and that Kijevo could be passed through. How long did it last, this

7 period?

8 A. 20 days at the most. Then it was violated by the police force in

9 Kijevo under the command of Mr. Gucic [phoen], the so-called

10 redarstvenici.

11 Q. What does it mean when you say that the agreement was violated by

12 the police officers in Kijevo? How did it manifest itself?

13 A. This meant that again they controlled all the roads and mistreated

14 the civilians who went past along the road from Vrlika to Knin and the

15 road went through Kijevo.

16 Q. Can you tell us which civilians were being mistreated? And I mean

17 their ethnicity. And how were they mistreated?

18 A. Specifically, when a person came down the road in a car with their

19 family, the forces there would force them to get out of the car, search

20 the car, open the boot, detain them unnecessarily, as if searching for

21 something. That's what mistreatment meant.

22 Q. Do you know anything about the JNA action at Kijevo, when it took

23 place, and how it came about? Or rather why it came about? Do you have

24 any knowledge about that?

25 A. Yes, I do. The JNA action on Kijevo took place in 1991. One day

Page 10669

1 ahead of the action a tragedy occurred which shook all of us deeply, in

2 particular the residents of my village. Mr. Dragisa Vranjes worked in

3 Switzerland. He was taken off a bus on his way home. He ended up in the

4 prison in Sibenik. Dragisa Vranjes, before the attack on Kijevo, was

5 brutally murdered in Sibenik. This was proved later on. He was killed in

6 prison. He was the -- resident of my village. People heard stories about

7 it through their different family ties, it doesn't really matter, to the

8 effect that it was the residents of Kijevo who were behind this, or rather

9 the police officers who were working in Sibenik and hailed from Kijevo.

10 The day before the attack on Kijevo, carried out by the JNA, the JNA

11 forces came under attack in the area of Kosori by the police force of the

12 Republic of Croatia.

13 JUDGE MOLOTO: Yes, Mr. Black?

14 MR. BLACK: I apologise for interrupting, but it wasn't clear to

15 me from the question that this is what was intended to get at. But none

16 of this about this person's death in prison the day before, the day before

17 the attack the JNA -- the attack on Kijevo the JNA forces came under

18 attack in Kosovoj [phoen], none of this is on the 65 ter summary, Your

19 Honour.

20 JUDGE MOLOTO: Mr. Milovancevic?

21 MR. MILOVANCEVIC: [Interpretation] Your Honour, in paragraph 5 of

22 the summary, it says that after the agreement, Kijevo was blocked again

23 and several Serbs were killed in the month of August of 1991 and the JNA

24 carried out the action in order to lift the blockades and so on and so

25 forth.

Page 10670

1 MR. BLACK: Do Your Honours have a copy of the 65 ter summary?

2 Because what it says is "Soon" -- it talks about the -- whatever these

3 negotiations were. "Soon afterward, the roadblock was put again.

4 JUDGE HOEPFEL: This is paragraph 4, isn't it?

5 MR. BLACK: Yes, Your Honour, then it goes into paragraph 5.

6 Several Serbs were killed. In August 1991 the JNA undertook an action to

7 lift the blockade. Now, that's different. Now the suggestion is that it

8 was an action in response to someone who died in prison or it was a

9 response to an attack the day before. That's not in here, Your Honour. I

10 would also mention that none of this was ever put to Prosecution

11 witnesses. It wasn't until the last witness who talked about Kijevo was

12 the first time we heard about this idea, that maybe there was an attack on

13 the JNA right before and now we hear it again in this witness's testimony

14 although it's not in the 65 ter summary. It's impossible for to us

15 prepare for cross-examination when we don't know what the witness is going

16 to say about something, besides the fact he's going to talk about Kijevo

17 in general.

18 JUDGE MOLOTO: The objection is upheld. While I'm talking,

19 Mr. Milovancevic, you have 20 minutes to go. This witness is scheduled

20 for three hours.

21 MR. MILOVANCEVIC: [Interpretation] Your Honour, I will finish

22 within five minutes.

23 JUDGE MOLOTO: Thank you Mr. Milovancevic.

24 MR. MILOVANCEVIC: [Interpretation] As for the information

25 mentioned now were testified to in great detail by a general who was

Page 10671

1 called to testify here. Therefore, the Prosecutor cannot say that he was

2 not prepared for this when this was the subject of evidence which lasted

3 five hours here in front of the Trial Chamber, and I'm referring to

4 General Djukic. And now, it's not that the witness stated that the murder

5 of this person was the immediate cause of the attack. He merely relayed

6 that particular incident which preceded the attack. May I proceed, Your

7 Honour?

8 JUDGE MOLOTO: Mr. Milovancevic, you've raise issues here. You're

9 saying General Djukic testified on this topic. That's not the point. The

10 point is you've got to give your learned friends advanced warning on what

11 your witnesses are going to testify on so that they can prepare. Now, it

12 may very well be that General Djukic has testified on it. Did now they

13 read what General Djukic said in preparation to cross-examine this

14 witness? The answer is no because they say they haven't prepared on this

15 point because it was not mentioned in your 65 ter summary.

16 Proceed, Mr. Milovancevic. The objection is upheld, as I said.

17 MR. MILOVANCEVIC: [Interpretation] Your Honour, I will bear this

18 in mind. However, for fairness's sake I have to say that in paragraph 3

19 of the summary, which is quite brief, I accept that, it says that the

20 witness took part in the talks with the Croatian side where it had been

21 agreed that the blockade be lifted and that the JNA remain in the area as

22 a guarantor of the agreement. After that, it says that the blockade was

23 lifted and several Serbs were killed. And this is what the witness is

24 talking about right now. He is about to talk about the JNA action on

25 Kijevo. At any rate, I accept and I have to accept your ruling and I will

Page 10672

1 carry on.

2 Q. Mr. Knezevic, can you tell us what, to your knowledge, the reason

3 behind the JNA attack was?

4 A. I can. The reason for the attack, or, rather, for the action of

5 the army of Yugoslavia, the JNA, on Kijevo, was the fact that their forces

6 were attacked near Kosori and Civljani where three people were killed.

7 Q. You say that three people were killed?

8 A. Yes.

9 Q. Who killed whom?

10 A. The Croatian police forces killed --

11 MR. BLACK: Your Honour?

12 JUDGE MOLOTO: Yes, Mr. Black?

13 MR. BLACK: Objection, Your Honour. This is exactly what I

14 objected to because it wasn't in the 65 ter summary and he's gone right

15 back to it.

16 JUDGE MOLOTO: Mr. Black, when there is reference to several

17 people being killed, can't they be mentioned?

18 MR. BLACK: No, Your Honour, he said, "Can you tell us the reason

19 behind the JNA attack?" The reason was that the -- was -- for the attack

20 or rather for the action of the army was the fact that their forces were

21 attacked near Kosori and Civljani where three people were killed but there

22 is nothing about -- there is nothing here about an attack on Kosori or

23 Civljani, much less connected, and say that that's the reason for the

24 attack on Kijevo. There were two things, I objected earlier to the person

25 who is -- apparently died in prison and then this other idea that there

Page 10673

1 was an attack immediately preceding the Kijevo action which caused the

2 Kijevo action. That's not in the 65 ter summary, Your Honour, and I think

3 it's important. And it's something that they obviously knew about. They

4 knew about the details. They could have told us. In fact, we received a

5 supplementary information sheet today from the Defence at noon which says

6 nothing about this.

7 JUDGE MOLOTO: Mr. Milovancevic?

8 MR. MILOVANCEVIC: [Interpretation] I accept that, Your Honour.

9 JUDGE MOLOTO: Thank you very much, Mr. Milovancevic. You may

10 proceed.

11 MR. MILOVANCEVIC: [Interpretation].

12 Q. Do you know whether in August 1991, the JNA carried out an action?

13 A. Yes, I do know. The JNA had to go through Kijevo to reach its

14 forces at Kosori because there was no other way to reach that location.

15 Q. In that JNA action were there any people killed or wounded?

16 A. No, none of them were killed or wounded. There were people

17 captured, 60 uniformed people were captured in Kijevo, among whom there

18 were two women.

19 Q. How did you come to know that during the JNA action in Kijevo, 60

20 uniformed persons were taken prisoner?

21 A. Because I was contacted at the Kijevo police station to transport

22 the people to Knin which I did.

23 Q. Thank you. Can you tell us who told you to do that and what did

24 you transport the prisoners with?

25 A. I don't know who it was, a duty officer, who informed me there,

Page 10674

1 and 40 persons were transported in a civilian bus and 22 in a military

2 bus.

3 Q. Thank you. The persons who were captured, you said, were in

4 uniform. What sort of uniform was it?

5 A. Camouflage uniform and they all had long weapons. They were with

6 full combat gear. Not all of them had bullet-proof vests. Only 10 of

7 them. This was their special squad at Kijevo that was part of these two

8 platoons.

9 Q. Where did you ferry the people to?

10 A. Bozo Ceko and I took them over to the police station in Knin.

11 From there, I believe they were taken to the southern barracks or I don't

12 know where they were but they were taken over by the duty officer there.

13 Q. Thank you.

14 A. Another important point, none of the people were mistreated, none

15 of those who were taken prisoner at Kijevo. I can guarantee that. And

16 one other thing: As we were taking them to Knin, Mr. Martic came to

17 inspect and he told us, "Please make sure that none of the people are

18 harmed or killed." And then my colleague Bozo Ceko asked him, well, why?

19 And then he answered, "Well, these people have to be exchanged. They are

20 prisoners."

21 Q. Thank you. Do you know what happened to the people captured in

22 Kijevo?

23 A. None of them were residents of Kijevo. All of them hailed from

24 Kasteli, and they were all exchanged quite soon, some 15 or 20 days later.

25 Q. In the course of your duties in the police station in Knin, did

Page 10675

1 you have occasion to get to know Mr. Martic as a colleague?

2 A. Yes.

3 Q. Can you tell us what his work ethic was and what his attitude

4 towards people was?

5 A. I can. Mr. Milan Martic was the sort of person who tried to solve

6 the most difficult of problems through -- by looking at the funny side of

7 things, sunny side of things, through humour, and I know that he solved

8 matters as he went along. And he was the sort of person who did his job

9 easily, with ease.

10 Q. The last question: Do you know if he differentiated between

11 people along ethnic, religious or any other bases?

12 A. I know of no such instances. I only know that regardless of

13 ethnicity, he sought to assist people and that is how we were taught and

14 brought up at the time, not to distinguish between people along any ethnic

15 lines.

16 MR. MILOVANCEVIC: [Interpretation] Thank you, Your Honour. I have

17 completed my examination-in-chief.

18 JUDGE MOLOTO: Thank you very much, Mr. Milovancevic. Mr. Black?

19 MR. BLACK: Thank you, Your Honour.

20 Cross-examination by Mr. Black:

21 Q. Mr. Knezevic, my name is Mr. Black. As you may have already

22 gathered I'm one of the prosecutors on the case, so now it's my turn to

23 ask you a few questions, okay? Do you understand that?

24 A. Yes, I do.

25 Q. First of all on the topic of petitions, one thing, just so that I

Page 10676

1 can get it clear, you said that the petition in Knin was followed --

2 excuse me, that it followed a similar petition in Zadar, but, in fact, the

3 Knin petition came first in June or July of 1990 and then the Zadar one

4 followed on later, around October of 1990. Is that the right chronology?

5 A. This is written here when the petition in Zadar was and I know

6 when the petition in Knin was.

7 Q. Okay. So if it says here the petition in Zadar -- actually, could

8 we look at Exhibit 1005 briefly just so that I can have clarity on this

9 from the witness? And we agree that the petition in Knin was in June or

10 perhaps the beginning of July 1990, right?

11 A. Yes.

12 Q. Okay. Well, let's see if we can establish when the Zadar petition

13 was.

14 JUDGE MOLOTO: It's dated the 5th of November 1990.

15 MR. BLACK: Okay. Thank you, Your Honour. There is also -- just

16 for the witness's edification, there is also a reference there. It

17 says -- I can just read it out, we don't need to wait for it to come up.

18 It says, "About 100 policemen, among whom there were ten Croats, requested

19 answers to these and some other questions on the 22nd of October 1990.

20 Q. Does that help you remember, sir that it would have been the end

21 of October or maybe the beginning of November, when the Zadar petition was

22 done?

23 JUDGE MOLOTO: Wasn't it done on the 5th of November?

24 THE WITNESS: [Interpretation] I cannot give you an accurate

25 response to that question. I don't remember.

Page 10677

1 JUDGE MOLOTO: Dated the 5th of November.

2 MR. BLACK: Okay, Your Honour, I wasn't clear whether this was the

3 petition or whether this other thing that's referred to in October was the

4 petition, and this was a different open letter but --

5 JUDGE MOLOTO: My understanding is that on the 22nd of October,

6 there was some kind of discussion with the leadership in Zadar and because

7 maybe that discussion did not bear fruit, a petition was then drafted on

8 the 5th of November.

9 MR. BLACK: Okay, that makes sense to me, Your Honour and I think

10 if we haven't gotten it right then certainly Mr. Milovancevic on redirect

11 will clarify it. But I think that's fine for now.

12 Q. Mr. Knezevic, the Knin petition was followed by a meeting with

13 Croatian authorities around the 5th of July 1990. Do you remember that?

14 A. Yes. I believe that Mr. Boljkovac attended this meeting at that

15 time and Josko Moric [phoen] as well.

16 Q. I think that's the same meeting I was referring to. It's correct,

17 isn't it, that those Croatian authorities actually required an escort in

18 order to be able to get out of that meeting unharmed because a big crowd

19 had gathered at the police station, et cetera, right?

20 A. Mr. Prosecutor, then, at that time, perhaps a large number of

21 people assembled but no one asked for escort, nor was any escort

22 necessary. I don't know about that. I was just a policeman. Perhaps

23 some superior authorities or my superiors may have been asked for an

24 escort. None was requested from me. So I can't say.

25 Q. Okay. Very well. You made that clear.

Page 10678

1 A. Excuse me, as regards this petition, perhaps the date it bears is

2 when it was addressed, whether it was sent to the different institutions

3 which are indicated in the address, and it may have been signed before

4 that date. That is quite possible.

5 Q. Okay, but regardless of the specific day it was late -- it was

6 later on, it was in the fall, sometime possible probably in October,

7 right? Does that fit with your recollection as to when the Zadar petition

8 was signed and that all happened?

9 A. I heard about the Zadar petition from my colleagues. Someone had

10 obtained it and read it and it spread by word of mouth so that everybody

11 knew about it - not only us at the police station - so that the people

12 knew what it was about as well. I cannot give you a precise answer to

13 that question. As regards the Knin one, yes, I can, because I am a

14 signatory.

15 Q. Okay, very well. That's clear. Going back to the meeting at the

16 beginning of July where Mr. Boljkovac and other people were there from the

17 Croatian MUP or the Croatian authorities in any event, it was really after

18 that point, after that meeting, that the police in Knin at least the Serb

19 police in Knin no longer recognised the authority of the Croatian MUP,

20 correct?

21 A. After the meeting in Knin, and I think that that is also a

22 question for those who were my superiors at the time and not for me, and I

23 believe that that Mr. Vujko was the secretary at the Knin SUP. Chief, the

24 head, Mr. Slobodan Vujko.

25 Q. Actually he arrived a little bit later, right? It was after the

Page 10679

1 petition, some maybe a few weeks after the petition, that Slobodan Vujko

2 became the chief of the Knin police station, right?

3 A. What year are you referring to? 1990?

4 Q. Right.

5 A. 1990. I know for a fact that on the 17th of August he was at the

6 police station and I cannot assert that that was the case before that. I

7 know that he was there on the 17th of August and I can tell you how I know

8 that, if you are interested.

9 Q. No. That's fine. I don't think we need to go into detail on it.

10 I want to go on to something else. And just so you know, based on one of

11 the answers before, it's quite all right if you don't know the answer to

12 one of my questions, you can always say -- you can agree with me or say

13 no, but if you just don't know the answer it's quite all right to say you

14 don't know, just so you know that. Do you understand?

15 A. Yes, yes, I do.

16 Q. Okay?

17 A. Yes, I shall try to follow that.

18 Q. Okay. Around the same time, a little bit after the petition, is

19 it correct or isn't it correct that there was also a leaflet going around

20 Knin which identified eight Serb policemen who had not signed the

21 petition? Do you remember that, remember seeing or hearing about that

22 leaflet?

23 A. I don't know about this leaflet, but I know that people's names

24 were called out, that people were pointed to. I was very -- on very good

25 terms with those people who had not signed the petition including Stevan

Page 10680

1 Trivic, who was a personal friend of mine, and it goes without saying that

2 I wouldn't do anything against a friend, and we are still friends today.

3 As for the leaflet I really don't know anything about it. I don't know

4 that a leaflet was produced or written by anyone, and then Knin is a small

5 place so one would have heard of it.

6 Q. Do you know anything about some of those people who you said --

7 there was -- talked about, the people who hadn't signed it. Did you know

8 that some of those people were attacked and nearly killed by a mob outside

9 the police station either on the 17th of August 1990 or perhaps a day or

10 two after that? Did you hear about such an incident?

11 A. That people were attacked? Those who declined to sign the

12 petition? Is that what you're saying? Is that the question?

13 Q. [Microphone not activated] Anyhow, some of those people who had

14 not signed the petition were sort of threatened and nearly attacked or

15 attacked or something like that around the 17th of August, did you hear

16 about that at the police station? Or did you see it yourself?

17 A. First of all I wasn't there. But no one was attacked physically,

18 and as for any verbal attacks, you cannot forbid anyone to attack somebody

19 else in that way. I know for a fact that there were no physical assaults

20 and, as for verbal ones, that may have been the case. Verbal

21 provocations.

22 JUDGE HOEPFEL: Excuse me, may I interrupt? Witness could you

23 repeat the name of your close friend, colleague, who was one of those who

24 had not signed, Stevan or Stefan so and so? The one who I used -- who you

25 are still in good terms with, on good terms with? What was his name?

Page 10681

1 A. Stevan Trivic and Vlado Babic, two of them, in fact. And, in

2 fact, Zivko Ognjenovic as well, and I'm on good terms with him as well.

3 JUDGE HOEPFEL: Could you repeat these three names once more and

4 then I'm satisfied, Stevan Trivic or -- with a V?

5 THE WITNESS: [Interpretation] Trivic with a V.

6 JUDGE HOEPFEL: Trivic or Strific?

7 A. TRIVIC, Trivic with a V. Then Mr. Ognjenovic, Zivko Ognjenovic.

8 JUDGE HOEPFEL: Thank you for the spelling of these names. Thank

9 you very much.

10 And Mr. Black, you may continue.

11 MR. BLACK: Thank you, Your Honour.

12 Q. Mr. Knezevic, let me keep moving along. You said earlier that

13 after this petition you said, "we were all laid off," and just so that I'm

14 clear about that, in fact, Martic was -- Mr. Martic was suspended and

15 three other people were suspended. But no one else was suspended or

16 dismissed from their jobs on the basis of this petition; isn't that right?

17 From Knin, I mean.

18 A. We were all suspended, the entire force on the Knin police

19 station, by a decision of the then president of the Republic of Croatia,

20 Mr. Franjo Tudjman.

21 Q. When?

22 A. A cable came, a telegram came that we were all dismissed, that our

23 employment thenceforth terminated.

24 Q. When did that happen?

25 A. After the petition, whether it was the 30th or the 31st, I can't

Page 10682

1 be sure but in 1991, basically.

2 JUDGE MOLOTO: May I just --

3 THE WITNESS: [Interpretation] It was in July, in fact.

4 JUDGE MOLOTO: Were you suspended or were you dismissed? You've

5 used the words "suspended" and you said "employment terminated

6 forthwith." Were you suspended or were you dismissed?

7 THE WITNESS: [Interpretation] I apologise, Your Honours. We were

8 dismissed. All of us.

9 MR. BLACK: Thank you, Your Honour.

10 Q. Mr. Knezevic so did you all stop working then, when you were

11 dismissed?

12 A. Yes.

13 Q. So according to you, after the 30th or 31st of July there was no

14 working police in Knin any more?

15 A. It wasn't working. Sorry. Actually, it wasn't functioning under

16 the authority of the Republic of Croatia. It was not under the authority

17 of the Republic of Croatia.

18 Q. Okay. But there is still police doing work, you and the other

19 policemen in Knin, you were no longer under the authority of the Republic

20 of Croatia, but you continued to do police duties, is that right?

21 A. That's right.

22 Q. Okay. Earlier you -- you -- you spoke about this event or I think

23 in August of 1990 and you said that you were trying to calm the situation

24 and that you went to Mr. Martic and he approved of that. Do you remember

25 telling us that?

Page 10683

1 A. I do.

2 Q. Let me just show you a clip, if we could -- oh, actually we may

3 have to wait a minute. I forgot to tell our case manager that we have a

4 Sanction clip. I can come back to it in just a second.

5 JUDGE HOEPFEL: Meanwhile, can I make sure what you mean by, "we

6 all were dismissed," Witness? I have the question, if you mean every

7 officer or every signatory of the petition? Which was not identical, was

8 it?

9 THE WITNESS: [Interpretation] Regardless of those signatures, we

10 were all collectively dismissed, namely all the policemen were dismissed.

11 So they were all dismissed.


13 Q. Sir, while we are waiting for this to come up, just let me go back

14 to something. You explained that you were no longer under the authorities

15 of Croatia but you continued doing police duties. Whose authority were

16 you under then since you were no longer under the authority of the

17 Croatian MUP?

18 A. While Mr. Slobodan Vujko was there, and I cannot recall the exact

19 date, we worked under the authority of the SUP of the Republic of Croatia,

20 and when he left we no longer were under their jurisdiction.

21 Q. And whose jurisdiction did you fall under at that point, after you

22 were no longer under the authority of -- under the jurisdiction of the

23 Croatian MUP?

24 A. At that time, the SAO Krajina was established and the people were

25 self-organised at that time, as far as I can recall, and as we had all

Page 10684

1 remained jobless, most of us, practically all of us, we were discriminated

2 against by the then Croatian authorities.

3 JUDGE MOLOTO: [Microphone not activated] That you then came under

4 the authority of the SAO Krajina? Because we just want an answer to that

5 question specifically.

6 THE WITNESS: [Interpretation] Well, upon its establishment, yes.

7 MR. BLACK: Your Honour, let me -- can I explore this a little

8 bit? Because I think Mr. Knezevic -- it's a little confusing about the

9 dates so let me ask you some specific questions.

10 Q. This -- the petition and all that happened in July -- June or July

11 of 1990. The SAO Krajina wasn't established until later, until the

12 beginning of 1991. Also Mr. Vujko was there in the Knin police station

13 until January of 1991. So when -- when was it in relation to those things

14 that you ceased being under the authority of Croatia? That was after the

15 petition, right? In July or August of 1990.

16 A. I remember that a telegram came from Zagreb, we received a

17 telegram to the effect that our employment terminated and that referred to

18 all the people working at the SUP Knin. I cannot be sure about the date.

19 I really cannot recall the date. I just remember that there was this

20 telegram about the termination of our employment and the striking us off

21 the payroll and that's it.

22 Q. Okay but that could have been as late as the beginning of January

23 or the beginning of 1991, you don't -- you can't really recall the date?

24 A. I don't remember the date.

25 Q. Okay. Think about it this way and I'll try to get past it, but

Page 10685

1 maybe this question will help. After the barricades went up and the

2 so-called log revolution and all that in the middle of August 1990, whose

3 authority were you under up until the establishment of the SAO Krajina?

4 If you can recall, if you can help us out with that.

5 A. In 1990, we were still under the authority of the SUP of the

6 Ministry of the Interior of the Republic of Croatia.

7 Q. Okay. Even after the petition? And even after the log

8 revolution? Sorry.

9 A. I apologise. Yes. After the petition for a while, I don't know

10 for how long, I can't remember that, but for some time after the petition

11 as well.

12 Q. Okay. Well, let me show you now this clip that we are able to get

13 ready and it will be on the screen in front of you. If we could all push

14 the e-court button and somebody will come and help you out, Mr. Knezevic.

15 A. All right.

16 MR. BLACK: This is from Exhibit 4, Your Honour, and then the

17 transcript is Exhibit 5, and this is, I believe, from July of 1990.

18 August, excuse me, 1990. We can play the chip now, please.

19 JUDGE MOLOTO: [Microphone not activated].

20 [Videotape played]

21 MR. BLACK: Your Honour, Exhibit 4 is the video and then Exhibit 5

22 is the transcript.

23 JUDGE MOLOTO: I was just --

24 MR. BLACK: No problem.

25 [Videotape played]

Page 10686


2 Q. Mr. Knezevic, do you remember ever seeing this on TV at the time?

3 Is this a video that you're familiar with?

4 A. No. I have not seen this video ever, this footage on television.

5 Q. Okay, did you hear about Mr. Martic making statements like this

6 at the time in July and August of 1990, about how they no longer were

7 under the authority of Croatia and it was the people's police, things like

8 that?

9 A. Well, he did make a statement but I cannot tell you when he made

10 that statement. I mean, the exact time. It was quite a long time ago. I

11 don't know when exactly.

12 Q. Okay but you do remember hearing statement -- hearing statements

13 like that or statements -- hearing about statements like that, whether or

14 not you can tell us the exact time, right?

15 A. I personally did not hear it because I wasn't there. Perhaps he

16 said it, he may have said it, perhaps he was actually seeking to gain some

17 popularity by some statements of his.

18 Q. Okay. The reason I asked you that question was because you in

19 response to my prior question you'd said, "Well did he make a statement

20 but I cannot tell you when he made that statement." And I just wondered

21 what you meant when you said, well, he did make a statement. Can you

22 explain what it was you were referring to? Was that something that you

23 heard or something that you heard about? Can you just explain, please?

24 A. Well, believe you me that I never heard him utter a similar

25 statement, because I was a man who was almost all the time in the field

Page 10687

1 doing work in the field, on the ground, and I spent very little time at

2 the police station in Knin proper. And when these statements like the one

3 that you just showed on the video here were given, I cannot confirm that

4 they were uttered in that way because I wasn't there at the time.

5 Q. Okay.

6 JUDGE MOLOTO: Where were you?

7 THE WITNESS: [Interpretation] Well, I was probably in my native

8 village where I hail from, and where I lived, and that is some 39

9 kilometres away.

10 JUDGE MOLOTO: But you continued to work at Knin police station,

11 didn't you, according to what you told us?

12 THE WITNESS: [Interpretation] Yes, yes, I did.

13 JUDGE MOLOTO: So you were attending the Knin police station on a

14 daily basis. You had to report for duty every day.

15 THE WITNESS: [Interpretation] That's correct.

16 JUDGE MOLOTO: So you can't then say you were not there unless, if

17 you had gone out on patrol.

18 THE WITNESS: [Interpretation] Well, that is possible, that I had

19 gone out on patrol. I would report for duty and then I would remain there

20 for five or ten minutes and then I would be issued with my daily task and

21 probably go out in the field.

22 JUDGE MOLOTO: But then when such a momentous statement is made

23 about the group that you belong to, which signed a petition, you don't

24 see, you don't hear it made, and you don't hear about it at all? Nobody

25 mentions it? When you come back to knock off, nobody says, "Hey,

Page 10688

1 Mr. Martic made a statement today to say A, B, C, D"?

2 THE WITNESS: [Interpretation] Well, if I had heard of it, I would

3 say so. I cannot say that I heard or saw something which I didn't see or

4 hear. Your Honours, I did sign that petition but I did not attend this --

5 JUDGE MOLOTO: I understand you may not have attended this meeting

6 or this occasion when Mr. Martic talked, but I find it a little odd, and I

7 wonder whether you wouldn't agree with me that it is a little odd, that

8 while you worked there, at the police station, you never came to hear of

9 this speech that Mr. Martic made, at the police station, on this very

10 issue, that was so close to your heart. Isn't it odd, would you agree?

11 THE WITNESS: [Interpretation] Well, I cannot agree with that. I

12 said what the truth was and the truth is that I didn't hear it.

13 JUDGE MOLOTO: I'm not suggesting you're not telling the truth.

14 I'm just saying it is a bit odd that you didn't hear about it. It's odd

15 that you didn't hear it specifically. It's even odder, if I can make that

16 comparison -- that degree of comparison, that you didn't hear at all about

17 it. And I'm not questioning your truthfulness. I'm just saying it is

18 funny. But that's fine.

19 You may proceed, Mr. Black.

20 MR. BLACK: Thank you, Your Honour.

21 Q. Mr. Knezevic, having now seen the video clip, do Mr. Martic's

22 statements strike you as calming the situation or is it -- isn't it quite

23 the opposite, that this is kind of stirring things up?

24 MR. MILOVANCEVIC: [Interpretation] Your Honour.

25 JUDGE MOLOTO: Yes, Mr. Milovancevic?

Page 10689

1 MR. MILOVANCEVIC: [Interpretation] In view of your questions and

2 in view of what the Prosecutor has just asked, perhaps it would be a good

3 idea to take a look at the statement again so that he can see whether it

4 was a press conference, whether it was in the police station, whether in

5 the street, whether it was filmed publicly or secretly. Shall we take a

6 look at the clip again, the clip and footage we just saw? Whether

7 Mr. Martic is wearing civilian clothes or uniform.

8 JUDGE MOLOTO: Mr. Black?

9 MR. BLACK: I don't think any of that stuff matters but let's look

10 at the clip again. I'm happy to watch it again.

11 JUDGE MOLOTO: [Microphone not activated].

12 [Videotape played]

13 JUDGE MOLOTO: Maybe then the record can show, Mr. Milovancevic,

14 that Mr. Martic is in a blue uniform and it looks like a press conference.

15 Would you agree with that?

16 Would you confirm that, Mr. Knezevic?

17 MR. MILOVANCEVIC: [Interpretation] Well, the witness ought to say

18 that, Your Honour. He should tell us what the trousers and --

19 JUDGE MOLOTO: What would you say Mr. Martic is wearing there?

20 THE WITNESS: [Interpretation] He's got a denim shirt and I think

21 he's wearing jeans.

22 JUDGE MOLOTO: Can we see the clip again and stop at Mr. Martic?

23 JUDGE NOSWORTHY: Could we freeze the portion where he's in his

24 uniform? Sorry, where he appears in his --

25 [Videotape played]

Page 10690

1 MR. BLACK: Your Honour, my pausing skills aren't that great but

2 hopefully this is good enough.

3 JUDGE MOLOTO: What does that look like, that shirt?

4 THE WITNESS: [Interpretation] This is not a police uniform. It's

5 a denim shirt.

6 JUDGE MOLOTO: Do you see the person next to him on the right?

7 THE WITNESS: [Interpretation] I can't see the person on the

8 right -- left, oh, yes you're right, on the right, yes.

9 JUDGE MOLOTO: Are they not wearing similar shirts?

10 THE WITNESS: [Interpretation] No, Mr. President, they are not.

11 The man on the left has a blue shirt. Martic has a denim shirt and jeans,

12 and next to him is Mr. Neso Maric, I know him very well. He's also

13 wearing civilian clothes. And to the right is Mr. Jovan Mitrovic. I

14 don't know who the man on the left is.

15 JUDGE MOLOTO: I guess it's a question of ipso loquitur.

16 MR. BLACK: You're right, Your Honour.

17 JUDGE MOLOTO: You can carry on.


19 Q. Sir, having again seen this, Mr. Knezevic, where Mr. Martic refers

20 to himself as inspector Martic and says they don't support the Croatian

21 authorities and those sorts of things, does that strike you as calming the

22 situation or isn't it really more like kind of stirring up the situation?

23 A. Well, Mr. Prosecutor, I'm not a politician to be competent enough

24 to answer questions like that.

25 Q. We understand that you're not an expert or anything like that but

Page 10691

1 your impression is he's not trying to calm things down, he's kind of

2 stirring things up, right? Just your impression.

3 A. It is my opinion that Mr. Martic tried to gain something else

4 there.

5 Q. Well --

6 A. Not to stir the situation up.

7 JUDGE MOLOTO: I'm going to have to intervene here.

8 See, you have testified that Mr. Martic was calming the situation,

9 that you were also calming the situation, everybody was calming the

10 situation. Now, you see here a clip in which Mr. Martic is talking about

11 that very situation. Now, I think you don't have to be a politician, you

12 just have to be a human being like you are, look at this clip and be able

13 to say whether or not that looks like calming. You don't need to be a

14 rocket scientist to know that, to make that opinion.

15 THE WITNESS: [Interpretation] Your Honour, I understand what

16 you're asking me but when I said, "calming the situation," I meant when I

17 went to negotiate to Kijevo with my colleague. I'm not talking about this

18 situation with Martic. I was referring to the other situation.

19 JUDGE MOLOTO: I understand that clearly but remember you did

20 testify about Mr. Martic. You did tell us that Mr. Martic was an easy

21 going person, very humorous and, of course, there is a bit of humour in

22 what he's saying here, and solving problems, and he was a person who

23 solved difficult problems.

24 THE WITNESS: [Interpretation] Correct.

25 JUDGE MOLOTO: Now, the question is does that look like solving

Page 10692

1 the problem that had to do with the police at that police station?

2 THE WITNESS: [Interpretation] It seems to me that this was solved

3 in a communist way here, that this is communism. It was said just for the

4 sake of saying something.

5 JUDGE MOLOTO: I'm afraid I don't understand you now, when you say

6 it was solved in a communist way. [Microphone not activated].

7 THE WITNESS: [Interpretation] Not, Your Honour, not communist,

8 humorous, humouristic.

9 THE INTERPRETER: The interpreter heard communist and apologises.

10 THE WITNESS: [Interpretation] Lots of humour in humouristic way.

11 JUDGE MOLOTO: But look at the words he says, the humour we

12 understand in the tone but do those words go to solving the problem? Or

13 do they say, no, we declaring ourselves to be uncooperative now, we are

14 not a Croatian police force, we are these people who -- we are the

15 people's force, what is -- that's what -- those are the words he's using.

16 What do they convey to you as a listener? And what do they convey to the

17 other policemen who are working in that police station and other police

18 stations? Do they convey cooperation?

19 THE WITNESS: [Interpretation] What is the date of this statement

20 here? Could you tell me that, Mr. Prosecutor? Could you be of

21 assistance? What date are we talking about here?


23 Q. It's sometime after the 18th of August 1990 but I believe still in

24 August 1990. I'm afraid I don't have the exact date on hand, Your

25 Honours?

Page 10693

1 JUDGE MOLOTO: Is there no date on this clip itself?

2 MR. BLACK: I don't believe so.

3 JUDGE MOLOTO: Or on the transcript? Can we -- but while we are

4 waiting for the date, sir, I guess you should be able to answer the

5 question without knowing the date. Does -- do the words uttered convey --

6 what do they convey to you as a listener, if you just came in there and

7 you didn't know anything about this incident?

8 THE WITNESS: [Interpretation] Well, that someone's interests were

9 in jeopardy.

10 JUDGE MOLOTO: Who is that someone and how are they in jeopardy

11 and what interests are they?

12 THE WITNESS: [Interpretation] In what way they were in jeopardy,

13 is that the question?

14 JUDGE MOLOTO: Yes. And whose interests are these and what

15 interests are they?

16 THE WITNESS: [Interpretation] When I meant interests, when I said,

17 "interests," the conduct towards the Serbian people through the HDZ

18 campaign, for instance. Those interests, as far as the Serbian people in

19 the whole of Krajina are concerned, and in the Republic of Croatia. They

20 were -- everything was withheld from them. Our relationship towards the

21 Croatian MUP was not geared towards the state of Croatia and the Croatian

22 people but the Croatian leadership and the Croatian authorities.

23 JUDGE MOLOTO: I'm sorry, I'm sorry, I don't understand how you

24 get that. I'm not asking you to interpret. I'm just asking you what

25 these words convey to you, you know, the words uttered by Mr. Martic

Page 10694

1 themselves. I think it's a very simple question. Shouldn't take us 15

2 minutes to get the answer.

3 THE WITNESS: [Interpretation] Mr. Martic's statement can be

4 interpreted in two or more ways. And to be quite frank, people

5 interpreted in the way they saw fit. The Croatian side, the Serb side,

6 and so on.

7 JUDGE MOLOTO: The question that is being put to you is how do you

8 interpret it? What does it convey to you?

9 THE WITNESS: [Interpretation] What it conveys to me is that Mr.

10 Martic was fighting for the interests of the Serb people in Krajina, in

11 this particular case, the police, to protect their rights. That's my

12 opinion.

13 JUDGE MOLOTO: Thank you.

14 MR. BLACK: Thank you, Your Honour.

15 Q. Since you mentioned it just very quickly, how do you think the

16 Croats, the Croat people in the area, would have reacted to this statement

17 of Mr. Martic?

18 A. Well, it's quite logical. You needn't ask me that question. I

19 think that the answer is obvious. If it suited one side, then it wouldn't

20 have suited the other side given the prevailing conditions generally.

21 Q. Sir, it may be logical and obvious but the nature of our

22 proceedings here is that I have to ask you questions and you just try your

23 best to answer them so please just go ahead and tell us how Croat people

24 in the area would have reacted to this statement of Mr. Martic?

25 A. Well, Your Honours, or rather, Mr. Prosecutor, you should ask the

Page 10695

1 Croatian people or a representative of the Croatian people how they

2 reacted to Mr. Martic's statement. I wasn't in that position, in a

3 position to be able to answer your question.

4 Q. Sir, but since you're sitting here and even referred to the

5 Croatian side and their interpretation before, I want to move on but

6 before I do I just want to get to you give us your impression of how

7 Croats in the area would have reacted to the statement by Mr. Martic.

8 Would they have been calmed by it or would it have had the opposite affect

9 on them?

10 MR. MILOVANCEVIC: [Interpretation] Your Honour, first of all, the

11 witness should be asked whether the statement was made public and

12 disclosed, who disclosed it, whether the witness had seen it, and then

13 whether it had any public consequences. The witness hasn't told us about

14 any of that.

15 JUDGE MOLOTO: Mr. Milovancevic, if you want to ask those

16 questions in re-examination you'll do so. I don't think you can tell the

17 other side how to ask their questions. You either object to a question

18 because it is objectionable or you wait for -- just wait for me -- or you

19 wait for your turn to clarify those issues that are not clear, and that's

20 a question of clarification. I think I must rule you out of order,

21 please. I'm sorry. I'm sorry, Mr. Milovancevic. I must rule you out of

22 order. Sit down.

23 Mr. Black?

24 MR. BLACK: Thank you, Your Honour.

25 Q. Mr. Knezevic, let's try one more time. I just want to get your

Page 10696

1 impression of how Croats in the area would have reacted to this statement

2 by Mr. Martic. Would they have been calmed by it or would it have had the

3 opposite effect on them?

4 A. Mr. Prosecutor, I said a moment ago when you asked me that

5 question that I don't know because I can't -- I'm an Orthodox -- of the

6 Orthodox faith. I can't put my shoes into somebody who is Croatian and

7 tell you that. It depends on the people, on the situation. That's what

8 it all depends on. Because in Knin, in the Knin municipality, there were

9 Croats whom I knew who were no different from us. We were the same, the

10 Orthodox population, the Croatians. Of course, later on when things

11 became more heated it was quite a different matter. But I can't really

12 answer that. Perhaps some of them reacted in one way and others in

13 another way. Some of them might have thought that this raised tensions

14 and other people thought that it was calming the situation.

15 Q. Is it that you can't answer the question or you don't want to

16 answer the question? Because the answer is obvious, as you stated

17 earlier.

18 A. Well, I'm not competent enough to answer that question.

19 Q. You can't imagine how Croats in the area might have received these

20 words? You just -- you can't recall -- you don't know, you can't imagine,

21 you don't have any opinion on how they might have seen these -- a

22 statement such as this one?

23 A. Well, they probably wouldn't have supported it. They wouldn't

24 have supported it, the statement. As to anything else, I don't know. I

25 don't know about the other reactions that they might have.

Page 10697

1 Q. Okay. Well, let me go on. I think we've taken that as far as we

2 can.

3 Are you familiar with the Council for National Resistance which

4 was active in Knin and that area from let's say August 1990 onward?

5 A. No.

6 Q. You never heard of that organisation or that council?

7 A. No.

8 Q. Good. I can move on then.

9 When -- I'll try to get through there very quickly because mostly

10 I want to talk to you about 1991 but when barricades were erected on the

11 17th of August 1990, you your self organised and commanded one of those

12 barricades, correct? Near Knin?

13 MR. MILOVANCEVIC: [Interpretation] Your Honour, objection. We

14 said that we wouldn't deal with that topic any more. I tried but wasn't

15 allowed to go ahead. And now the Prosecutor wishes to continue.

16 JUDGE MOLOTO: Mr. Black says he withdraws the question.

17 Thank you very much, Mr. Milovancevic.

18 MR. BLACK: Yeah. I withdraw that question.

19 Q. After August 1990 and into 1991 you became a commander in what was

20 being called Martic's Police, correct?

21 A. No, I did not become any kind of commander. I just found myself

22 through force of circumstance in the area I was born in, as I was present

23 at the local commune in that time so -- at that time, so that was just

24 through force of circumstance that I happened to be there.

25 Q. Okay. Well, let's not focus I guess on the title or whatever but

Page 10698

1 you found yourself assuming a position of responsibility among this group

2 called -- being called Martic's Police, right?

3 A. No. I didn't have any responsibility either. And please believe

4 me when I say that.

5 Q. Were you involved in -- well, you were involved, weren't you, in

6 the operation of the training camp in Golubic and now I'm moving into

7 1991.

8 A. Golubic, the camp? Yes. I was there at the training for a period

9 of 21 days, I personally. It was training, not the establishment of a

10 camp. It was just training, training for special units.

11 Q. Right. Okay. Sorry if I used the word camp. I didn't mean to be

12 confusing, but we are talking about the same thing. And in Golubic young

13 men came from various places in the Krajina and there they received

14 training in arms and then they went back to their own areas, right?

15 That's the way things worked generally? I think Mr. Martic has a note for

16 his counsel too when there is a chance?

17 JUDGE MOLOTO: Mr. Perovic, can you help us, please? Mr. Perovic,

18 a note from Mr. Martic?

19 THE WITNESS: [Interpretation] All I can say is this: That

20 Mr. Martic, when the training was underway at Golubic, it was turned into

21 a sort of course or school for the training of policemen because Mr.

22 Martic didn't want to place people in the field who were not trained or

23 who were illiterate or things like that.


25 Q. And I'm correct, right, that people would come from other places

Page 10699

1 in the Krajina, they would come to Golubic to receive training in weapons,

2 and then they would go back to their home towns and villages, that was the

3 pattern, right? I mean not everyone who trained at Golubic was from

4 Golubic or Knin obviously, right?

5 A. When I was there, they were mostly people from Knin. Later on the

6 camp was abolished as far as I remember. It was closed down after some

7 time.

8 Q. Well, in June 1991, for instance, there were people from many

9 different parts of the Krajina there, in Golubic, correct?

10 A. When I was at the camp, it was the Knin municipality. I don't

11 know about later on.

12 Q. Okay.

13 JUDGE MOLOTO: When were you at the camp, sir?

14 THE WITNESS: [Interpretation] In 1991. In the first stage, and I

15 was among the first people that attended training at the camp. I don't

16 know the exact date but I think it was summertime any way. Or perhaps the

17 spring. I'm not quite sure.

18 JUDGE MOLOTO: You can't remember the month?

19 THE WITNESS: [Interpretation] I cannot, no. I really can't.

20 MR. BLACK: It's just about time for our regular break but one

21 quick question before we do in the last 30 seconds. The training at

22 Golubic included various military type training, such as setting mines,

23 preparing ambushes, defending against ambushes, sniper fire, and those

24 types of things, correct?

25 A. No. It was how to climb down a slope, down a rope, martial arts,

Page 10700

1 that kind of thing.

2 Q. So nothing about blocking towns or using rifle, grenade launchers

3 or anything like that? That wasn't part of the training? Is that what

4 you're saying? Nothing military?

5 A. While I was there, no.

6 MR. BLACK: Your Honours, I think it's time for the regular break.

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

8 and come back at quarter to 6.00. Court adjourned.

9 --- Recess taken at 5.14 p.m.

10 --- On resuming at 5.44 p.m.

11 JUDGE MOLOTO: How much longer do you think you'll be, Mr. Black?

12 MR. BLACK: Your Honour, I'm aware of the time and I'm going to

13 speed up as much as I possibly can and, frankly, up till now it's gone

14 much slower than I expected. Some answers were extremely hard to get, but

15 I think I should have no problem finishing today and hopefully with plenty

16 of time for re-examination or questions from Your Honours.

17 JUDGE MOLOTO: That would be much appreciated.

18 MR. BLACK: That's my intention, Your Honour.

19 JUDGE MOLOTO: We also do have some housekeeping to deal with at

20 the end of the day.

21 MR. BLACK: Okay, thank you. I'll move as quickly as I can.

22 Q. Mr. Knezevic, as you have heard, we want to try to cover a lot of

23 ground quickly. So please if you can just focus on my questions and just

24 try to answer the question I ask you.

25 Just before the break, I was asking you about Golubic and you said

Page 10701

1 that while you were there it was just Knin people although you weren't

2 sure about other times and that there wasn't military training while you

3 were there. I'd like you to look at a document, it's Exhibit 622, and it

4 will come up on the screen in front of you in just a moment.

5 There you can see it, Mr. Knezevic.

6 This document is minutes -- it's in evidence in our case -- it's

7 minutes of a meeting on the morning of 14 June 1991?

8 MR. BLACK: Your Honours I would note that on the English, the

9 date just has 14, 1991, but on the B/C/S you can see it's clear there is a

10 6 there so there is just a typo in the English translation.

11 JUDGE MOLOTO: [Microphone not activated].

12 THE INTERPRETER: Microphone, Your Honour, please.

13 JUDGE MOLOTO: You say the English version says 14 what?

14 MR. BLACK: The date the first line in the English translation the

15 recording started at 830 hours on 141991 and just the June or 6 is

16 missing, that's all, but it's clear from the B/C/S.

17 JUDGE MOLOTO: Mine has a six.

18 MR. BLACK: Oh, really?


20 MR. BLACK: Sorry.

21 Q. Mr. Knezevic, the important part is I'd like you to read that

22 first paragraph, maybe you're already looking at, it says that you

23 attended a meeting with a number of others including Frenki and some

24 others and Captain Dragan. Do you remember this meeting or such a meeting

25 in June of 1991?

Page 10702

1 A. No. I don't remember this meeting at all.

2 Q. Okay. But this -- it clearly refers to you here in the first

3 paragraph, right, Dragan Knezevic?

4 A. It does say Dragan Knezevic but there are other Dragan Knezevics

5 so I cannot claim -- I cannot say with certainty that that refers to me.

6 Q. But you remember meeting with people like -- you met with Frenki,

7 this refers to Franko Simatovic, correct? You remember meeting with him

8 in 1991?

9 A. I only met once with Franko Simatovic at the police station in

10 Knin.

11 Q. What about Captain Dragan? You remember meeting with him, right?

12 A. Yes.

13 Q. Dragan Karna, is that someone you remember meeting with?

14 A. Dragan Karna is a colleague who used to work at Sinj and later he

15 was transferred from Sinj to Knin and came to work with us. So I just

16 knew him. I didn't have any concrete dealings with him.

17 Q. Okay. Well, let's look at the substance of this document and you

18 can tell me whether -- maybe this will remained you of the meeting. If we

19 could scroll down in the B/C/S, please, there is -- it says, it talks

20 about the three objectives of the meeting, and then underlined it says

21 "agreement on further work in Golubic," and what appears there are a

22 number of place names along with numbers, correct? You see where I'm

23 indicating?

24 A. Yes, I do.

25 Q. In those, those places and the numbers refer to the number of

Page 10703

1 trainees at Golubic from particular locations, correct?

2 A. Believe me, I don't know.

3 Q. So you do not remember ever being at a meeting where it was

4 discussed, trainees from different locations at Golubic?

5 A. Of this kind, no. Certainly not. I was in charge of leading my

6 eight people from Cetina and Civljani and to train them. As members of a

7 reserve force that would later be placed in the streets to work as

8 policemen. That was my task. As for this meeting, I can guarantee that I

9 wasn't there and I didn't sign this document.

10 Q. Well, yeah, that's -- just so that it's clear I'm not suggesting

11 you signed it. It purports to be minutes. They were typed up after a

12 meeting. So whether you've seen the document is a different thing but you

13 don't recall, you think that you were not in fact at this meeting? It

14 refers to another Dragan Knezevic, is that right?

15 A. Possibly, possibly. I certainly did not attend that meeting. I

16 can guarantee that.

17 Q. Okay. Well, let me ask you just about another part and then we

18 can move on from it. If we turn to the second page in B/C/S, please, and

19 it's page 3 in English, if we could zoom in a bit at the top and

20 Mr. Knezevic there it says 275 firearms need to be given to the areas in

21 the rear towards the Zagrava [phoen] river and Pakrac, then it says,

22 Medak, special training for mining, destruction of roads, luring into

23 ambush and defence from ambush, under Glina and Vojnic, it says, mining of

24 cars, buildings, features, sniper fire, and you can see it continues.

25 Under Plaski, it refers to rifle, grenade-launcher work, ambush. This --

Page 10704

1 JUDGE MOLOTO: Sorry, mine has only two pages and what you have

2 been reading, I don't have.

3 MR. BLACK: I suspect maybe I have a different translation, Your

4 Honour, I apologise. There is -- actually I would have another -- it

5 would be at the bottom of page 2, perhaps.

6 JUDGE MOLOTO: Page 2 there is nothing at the bottom. There is

7 only three lines on page 2.

8 MR. BLACK: Do you see anywhere that it says 270 firearms, Your

9 Honour?


11 MR. BLACK: I'm working on the hard copy. I'll have to check to

12 see if I have a different translation.

13 JUDGE MOLOTO: What's at page 2 says, Plaski, the construction of

14 defensive position, the blocking of a town, operating with rifle,

15 grenades, ambush.

16 MR. BLACK: That's the same, Your Honour, and then it's just a few

17 lines before that. Perhaps it's on the prior page.

18 JUDGE MOLOTO: The prior page says, 270 of long barrels are to be

19 given in the area to what's the -- Zagrabija river and Pakrac.

20 MR. BLACK: It's the same document, Your Honour. Somehow I've

21 come up with a different translation but obviously the one in the system

22 is the one that governs.

23 Q. My question is simply, Mr. Knezevic, in June of 1991, this was the

24 kind of training which was being done at Golubic, correct?

25 A. Believe me that I'm not familiar with this. Not with a single

Page 10705

1 segment of it.

2 Q. Okay but putting aside I guess the document whether you're

3 familiar with the document, are you aware that there was this kind of

4 training going on at Golubic in 1991? And if you're not, you can say so

5 or if you just don't know.

6 A. I don't know.

7 Q. Okay. Well, let me move on to something else, then.

8 JUDGE MOLOTO: What's the number of this exhibit?

9 MR. BLACK: 212, Your Honour.

10 Q. Mr. Knezevic, you emphasised earlier in your testimony that there

11 was -- the Croatian MUP established a police station in Kijevo where there

12 had never been one before. First of all --

13 JUDGE HOEPFEL: Just a moment.

14 MR. BLACK: Your Honour, 622.

15 JUDGE MOLOTO: Thank you very much. The registrar has helped.

16 MR. BLACK: Thank you. The court officer is keeping me on my

17 game.

18 Q. Mr. Knezevic, first of all, it was perfectly understandable that

19 they would want to strengthen the police presence in Kijevo because Kijevo

20 found itself between Knin and other Serb villages, right? And tensions

21 were high at the time.

22 A. Yes. It was a very important at that time but there was no need

23 for 150 policemen to be stationed there. This was -- actually, Kijevo was

24 not endangered at any moment from the people surrounding the area of

25 Kijevo even though they were of a different ethnicity.

Page 10706

1 Q. Well, that may be your opinion but you accept that the people of

2 Kijevo may well have felt afraid, right, under the circumstances?

3 A. Actually was the Croatian press and the Croatian media generally

4 that stressed no end the importance -- the importance of Kijevo by stating

5 that if Kijevo fell, that would be the fall of the Alamo and they call

6 Kijevo the Croatian Alamo is and, of course, everyone knows what the

7 significance of the Alamo.

8 Q. But you accept, don't you -- you agree with me that the Croat

9 villagers at Kijevo at the time, they were afraid. They were at least

10 very concerned about their situation under the circumstances, right, and

11 that makes sense, that's understandable?

12 A. Mr. Prosecutor, you were quite right when you say that they were

13 concerned but both sides were concerned the Croats in Kijevo, and the

14 Orthodox folk on the other side were just as concerned seeing what kind of

15 a situation obtained.

16 Q. Okay so just focusing on my question you agree with me then that

17 the Croats in Kijevo were concerned, right?

18 A. I agree that they were concerned, but with their redarstvenici,

19 their police force, they had such reinforcement that they actually were

20 creating problems, so that this actually entailed a countereffect.

21 Q. In 1991, Milan Martic appointed you to be the chief of the police

22 in Civljani, correct, to be -- to head up the police there?

23 A. There was just a branch office in Civljani of the Knin police

24 station.

25 Q. But there had never been a police station or a branch office in

Page 10707

1 Civljani before, had there?

2 A. It was in fact or there had been a check-point because it borders

3 on the municipalities of Knin and the -- that of Sinj.

4 Q. But there had never been a police station or a branch office there

5 before, that was something new, right, when you were appointed to head it

6 up?

7 A. I don't know about before. I heard that there was something after

8 the war but I really don't know because after the war that would all be

9 encompassed under Vrlika.

10 JUDGE MOLOTO: I'd like to go back to the earlier question you

11 asked. Do you agree, sir, that Mr. Martic appointed you chief of that

12 police station at that time in Civljani? The question was in 1991,

13 Mr. Milan Martic appointed you to be the chief of the police in Civljani,

14 correct, to be head -- to head up the police there, and you said there was

15 just a branch office in Civljani of Knin police station. You never

16 answered the question put to you. I just want you to answer the

17 question: Were you appointed by Mr. Martic to head the police station in

18 Civljani, whether it was a branch or not a branch.

19 THE WITNESS: [Interpretation] Yes. Mr. Martic did appoint me but

20 it was just eight people.

21 JUDGE MOLOTO: Doesn't matter how many people. When you got

22 there, did you set it up or had it been an ongoing institution? Did you

23 find a functioning police station when you got there or did you have to

24 start it?

25 THE WITNESS: [Interpretation] There was not a police station

Page 10708

1 there, but there were barricades there and Mr. Martic sent us there to

2 take that over, namely not to have untrained people manning them, the

3 peasants.

4 JUDGE MOLOTO: Thank you very much.

5 MR. BLACK: Thank you, Your Honour.

6 Q. Mr. Knezevic, isn't it the case that you were sort of outraged by

7 a new police presence in Kijevo but it doesn't bother you at all that you

8 had now a new police presence in Civljani? Doesn't that seem like a --

9 you know, a double standard there on your part?

10 A. Mr. Prosecutor, the police from Knin was also in charge of the

11 local communes of Cetina and Cviljane. There was no need nor the

12 redarstvenici police forces to come to either Kijevo or Civljani but they

13 separated Cetina and Civljani from the Knin municipality when they set

14 themselves up in Kijevo, their police station in Kijevo.

15 Q. Whether or not you thought there was a need, the Croatian MUP was

16 perfectly entitled to establish a police presence in any town or village

17 on the territory of Croatia, right? There was nothing unlawful about

18 that.

19 A. I agree with you that there was nothing illegitimate about it but

20 not in so large a number. I don't see why 150 policemen had to be

21 deployed there.

22 Q. On the 26th of August 1991, the JNA attacked Kijevo together with

23 the SAO Krajina Police, correct?

24 A. The JNA attacked Kijevo without the police, because their forces

25 had been attacked at Kosori and Vrlika. Their forces which were in the

Page 10709

1 so-called buffer zone between the Orthodox and Catholic villages, and in

2 that operation, as I indicated earlier, three people were killed.

3 Q. Let's focus on the 26th of August 1991. You personally

4 participated in this attack, right?

5 A. No, no, no. I only came to get the prisoners, having been called

6 to do that. And I was called by the duty officer at the Knin police

7 station. That of course can be seen as participation.

8 Q. What time did you arrive in Kijevo?

9 A. That was sometime in the afternoon, around 3.00 p.m. I cannot be

10 precise, between 3.00 and 4.00 p.m.

11 Q. Isn't it a fact that Milan Martic was also involved in this and

12 that he had even helped plan and personally was involved in this operation

13 against Kijevo?

14 A. I don't know that, and I don't know about that. As far as I know,

15 this operation was mounted by the JNA, the army, commanded by General

16 Djukic.

17 Q. So as far as you know the police had nothing to do with this other

18 than, like you say, coming to take custody of the captured people, is that

19 what you're saying?

20 A. The police went in after the army to secure the village, but you

21 know or maybe you don't know how one provides security in war conditions,

22 when streets and villages are concerned.

23 Q. You're right. Maybe I don't know. So the police did enter Kijevo

24 on the 26th and they were there still on the 27th of August 1991, correct?

25 Have I understood you correctly? Whether it was, as you say, to secure

Page 10710

1 the village or whether it was part of the actual attack, they were there

2 on the 26th and the 27th of August, right?

3 A. I went back to Knin with the people who were captured at Kijevo

4 and I went back to the police station, i.e., then I went to my

5 brother-in-law's house to spend the night in Knin.

6 Q. Okay. So before you arrived around 3.00 p.m., you don't -- you

7 weren't present in Kijevo and then after you went back, after that point

8 whether you took the prisoners, you weren't present in Kijevo either, it

9 was just -- that trip to pick up the prisoners was the only time you were

10 present there, have I understood you correctly?

11 A. Yes.

12 Q. Okay. So you can't -- you have no personal knowledge in fact of

13 anything that happened there before 3.00 p.m., and you don't really know

14 what happened there after you left or on the 27th of August, is that what

15 you're saying?

16 A. No. I don't know anything that may have happened after that.

17 JUDGE MOLOTO: May I interrupt? When did the police come to

18 Kijevo to secure the place?

19 THE WITNESS: [Interpretation] After this military operation. And

20 that was in the afternoon.

21 JUDGE MOLOTO: Is that on the 26th of August or on the 27th of

22 August?

23 THE WITNESS: [Interpretation] I'm not sure whether -- whether it

24 was the 26th or the 27th, when these people were taken prisoner at Kijevo.

25 If that was on the 26th, then this was also on the 26th.

Page 10711

1 JUDGE MOLOTO: You mean the day you came to take the prisoners

2 from Kijevo to Knin?

3 THE WITNESS: [Interpretation] That is correct.

4 JUDGE MOLOTO: Do I understand you to be saying the police arrived

5 there on the same day as you were there?

6 THE WITNESS: [Interpretation] That is correct.

7 JUDGE MOLOTO: What time did the police arrive?

8 THE WITNESS: [Interpretation] Well, they preceded me and I don't

9 know exactly by how long.

10 JUDGE MOLOTO: So you cannot say, if indeed -- if this day was the

11 26th, you cannot say whether they were still there on the 27th?

12 THE WITNESS: [Interpretation] No, I cannot say that.

13 JUDGE MOLOTO: Thank you very much.

14 MR. BLACK: Thank you, Your Honour.

15 Q. Mr. Knezevic, are you familiar with the ultimatum that was made by

16 Mr. Martic on the 18th of August 1991, to Kijevo?

17 A. I heard that Mr. Martic had made an ultimatum but it was to the

18 police station in Kijevo, that they should get out of there, and he warned

19 the people of the possible consequences in the event any actions took

20 place, because at that time the army was playing the role of peace forces,

21 of negotiators, they agreed that the Kijevo police station should be

22 dismantled, removed, but this was not honoured and then there was the

23 attack at Kosori, at the armed forces, and they actually had to pass

24 through Kijevo to reach their lines.

25 Q. Did the -- did the Croatian police get out of Kijevo as requested

Page 10712

1 or as demanded by Mr. Martic in the ultimatum? Did they get out before

2 the 26th of August?

3 A. No, no. They stayed on, and they were taken prisoner on the 26th,

4 and the rest certainly left, and I can tell you, when I went there to take

5 those prisoners that I did not see a single civilian in Kijevo, not a man,

6 a woman, an elderly person, no one, at least not along the main road.

7 Q. In fact, the civilian population of Kijevo fled, didn't they?

8 A. They had either fled or were resettled by -- on the basis of an

9 agreement. It had to be one of the two.

10 Q. But you don't know anything about being resettled on the basis of

11 an agreement, you're sort of speculating about that, right?

12 A. Stories were being bandied about that there had been an agreement

13 and with the army, that the army had transported those who wished to go.

14 Not all of them, of course.

15 Q. Sir, well, let me put it straight to you: Isn't it a fact that

16 the attack on Kijevo had two purposes, to get the Croatian police out and

17 to scare and to drive out the Croatian villagers, the Croat villagers?

18 Weren't those really the purposes, the goals, of the operation?

19 A. Mr. Prosecutor, I will tell you that your presumption that the

20 goal was to expel the Croatian police, that is correct. But to scare the

21 people off, no, that one isn't.

22 Q. It's -- well maybe -- maybe you didn't see this but when you went

23 to Kijevo in the afternoon of the 26th, did you see that many houses and

24 other civilian buildings had been destroyed?

25 A. When I entered Kijevo, there was just one house by the post office

Page 10713

1 in Kijevo that was on fire, and nothing more. And I believe that house

2 was the so-called Babic house which had been notorious in the Second World

3 War and it was torched by people from Polaca because in 1941, 49 men from

4 Polaca had been slaughtered in the village of Kijevo.

5 Q. Okay. So who were these people from Polaca? Were they part of

6 the JNA or were they policemen? Or who were these people that torched

7 this particular house, if you know?

8 A. I don't know that. I don't know. All I heard was that they were

9 people from Polaca, and Bozo Ceko told me that.

10 Q. Okay. Did you -- did you see that the church, St. Michael's

11 church in Kijevo had been damaged when you were there in the afternoon on

12 the 26th?

13 A. No. I didn't see that.

14 Q. Okay. So you -- is it that you didn't see the church at all or

15 you saw the church and it wasn't damaged?

16 A. I was along the main road, and the church is on the left-hand side

17 up on the hill so you can't see it. It's a kilometre away. I don't know

18 whether it was damaged. I came to Kijevo. It is the Knin-Vrlik-Sinj main

19 road.

20 Q. Just one last topic, sir. You talked a little bit about Milan

21 Martic's attitude towards Croats and how he dealt with people of different

22 ethnicities. It's true, isn't it, that Milan Martic frequently used the

23 term "Ustasha," both privately and also publicly?

24 A. Well, up to 1997 or not [as interpreted], I can guarantee that.

25 Later on, maybe here and there, but you know when you're tired and nervous

Page 10714

1 you come out with all sorts of things but not until 1990, certainly not.

2 Nobody used that term.

3 Q. The date we heard was 1997, the first time. Could you just repeat

4 it so that we are clear on what the date was that you mentioned, the year?

5 Maybe you said 1990. Is that right?

6 A. I don't understand your question.

7 Q. Sorry, it was you know I think it's an interpretation thing or

8 maybe a slip of the tongue on our transcript and in English we heard you

9 said not until 1997?

10 THE INTERPRETER: The interpreter meant to say 1990.

11 MR. BLACK: Okay, I see.

12 Q. Mr. Knezevic, the interpreter just corrected this?

13 A. No, no. Everything was over by 1997. That is impossible.

14 Q. Okay. Right. That's okay, we have cleared that up.

15 But during 1990 and afterwards, Mr. Martic did use the word

16 Ustasha, right? Both privately and publicly.

17 A. Sir, we didn't have any electricity at that time where we were.

18 We had no electricity at all. I was in the rural areas in the village.

19 Q. Sorry, if you -- maybe I interrupted you too soon, but do you know

20 whether or not Mr. Martic used the word Ustasha? If you don't know of any

21 occasions, you can say that.

22 A. I never heard him say that. I personally never ever heard him say

23 that, not on any occasion.

24 Q. Okay. Much of what you testified about here was about Kijevo.

25 You'd agree with me wouldn't you that the attack on Kijevo on the 26th of

Page 10715

1 August had a devastating effect on the villagers of Kijevo; most of them

2 left and any who stayed behind were in very difficult circumstances,

3 right?

4 A. Well, Mr. Prosecutor, every move of that kind was terrifying to

5 someone. As to the villagers of Kijevo, they weren't there at all. The

6 elderly and children couldn't have crossed the hill. They took the main

7 road. That's 100 per cent true. If we look towards Kijevo from my area,

8 you have Dinara mountains on one side and on the other, hills, so they

9 certainly couldn't have gone on foot.

10 Q. So according to you, well, you weren't in Kijevo before 3.00 so

11 you don't really know if there were civilians there when I attack started

12 or not, do you? You can't know that.

13 A. The army was there before us. Before I arrived in Kijevo, the

14 soldiers were there, the army.

15 Q. Right. So you weren't there so you can't say whether the civilian

16 population, the villagers of Kijevo, were present when the attack started

17 or not. I mean, you just don't know, right?

18 A. Mr. Boro Djukic told me personally that there was not a single

19 civilian in Kijevo, nor did anybody suffer, there were no casualties,

20 nobody was wounded, there were 62 of --

21 Q. What about after Kijevo? Do you know if there were any villagers

22 who remained after the 26th and 27th? Or was the whole village gone after

23 that? Or do you not know?

24 A. I really don't know whether anybody remained in Kijevo. I never

25 went into Kijevo, nor do I know if anybody remained there or not.

Page 10716

1 Q. And you accept, don't you, that -- that Milan Martic was one of

2 the commanders and one of the people who was responsible for the Kijevo

3 operation? Or do you reject that?

4 A. I am quite convinced that the operation on Kijevo was launched by

5 the JNA. Now, what Martic had to do with and what their relations were I

6 really can't say. And whether they cooperated in any way at all, I can't

7 say. I can't testify about that.

8 Q. Thanks very much for answering my questions.

9 MR. BLACK: No further questions, Your Honour.

10 JUDGE MOLOTO: Thank you very much, Mr. Black.

11 Mr. Milovancevic, any re-examination?

12 MR. MILOVANCEVIC: [Interpretation] Yes, Your Honour.

13 Re-examination by Mr. Milovancevic:

14 Q. Do you remember, Mr. Knezevic, the footage that we saw where Mr.

15 Martic was saying something -- well, what we heard here on our monitors?

16 A. Yes, I saw that footage.

17 Q. Right. You remember that.

18 A. You mean today? I remember what we saw today.

19 Q. That's right. Now, on that footage, did you see whether it was a

20 public film or let me restate that. Do you see a microphone on any of

21 that footage? Do you remember having seen a microphone anywhere there?

22 A. There are no microphones. I didn't see a microphone anywhere.

23 JUDGE HOEPFEL: Let me clarify, Mr. Milovancevic, what kind of

24 microphone you mean? You mean such a microphone as in this room, a fixed

25 microphone or a microphone a journalist held in his hand, in his or her

Page 10717

1 hand, and put to Mr. Martic? What kind of microphone do you mean?

2 MR. MILOVANCEVIC: [Interpretation] Thank you, Judge, for that

3 question. I meant the microphone that the journalist had, going up to the

4 person he was interviewing.

5 Q. Do you remember that? Now can that be found on the footage?

6 A. There is none of that on the footage. At least you can't see it

7 on the footage, nothing like that. When I looked at the footage, Rado

8 Zarko told me on one occasion, he was a colleague of mine, that allegedly

9 the lady journalist from one of the newspapers, filmed something secretly.

10 I don't know whether that was the particular footage or not. Heni was her

11 name, yes.

12 Q. Do you remember that we see different people on the footage and

13 it's only later on that we hear what Mr. Martic is saying so you -- the

14 voice is separated from the people, the -- on the footage?

15 MR. MILOVANCEVIC: [Interpretation] Need I show the footage again,

16 Your Honour, or is what I'm asking clear enough?

17 Q. On the basis of what you saw, can you tell us which television

18 station filmed what we saw?

19 A. I can't say.

20 Q. A more general question, was it the Croatian side, Croatian

21 television, or someone else? Can you give us your views on that?

22 A. Well, I assume on the basis of what I was able to see, that it was

23 Croatian television. I assume that but I cannot be sure of course.

24 Q. Looking at the location, do you think it was an interview with

25 Mr. Martic, was it a press conference, was it a statement made at some

Page 10718

1 public gathering or something else again?

2 A. It was something else, as far as I was concerned. None of those,

3 something that had nothing to do with a -- it wasn't an interview, it

4 wasn't a public gathering.

5 Q. Thank you. Now do you remember that the Prosecutor asking you

6 what effect this footage could have had on the Croatian population? Do

7 you remember him asking you that?

8 A. Yes, I do.

9 Q. I'm interested in the following: Can you tell us your opinion

10 about what the television station, the Croatian television, if that is

11 what it was, if it played it to the Croatian population, what was the

12 purpose, what was the goal of showing that to the Croatian population?

13 A. Well, to raise tensions among the people, to give rise to general

14 panic, to bring about an untoward situation.

15 Q. Showing footage of this kind publicly, would that have contributed

16 to fanning the names of interethnic passions or to calming the situation?

17 What would you say?

18 A. Well, I think it fanned the flames of national passions because

19 the media will be the media. It is the most powerful weapon that exists.

20 MR. MILOVANCEVIC: [Interpretation] Thank you, Your Honours. I

21 have no further questions.

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

23 Questioned by the Court:

24 JUDGE HOEPFEL: I didn't want to ask but it's interesting what

25 Mr. Milovancevic now brought up, and may I remind you now of a broadcast

Page 10719

1 about General Spegelj? You remember that?

2 A. I do remember it, yes.

3 JUDGE HOEPFEL: That was also something quite extreme, wasn't it?

4 A. It was something that was the height of extremity, the most

5 extreme that anybody could have uttered on this planet.

6 JUDGE HOEPFEL: Would you say that this statement of General

7 Spegelj was a formal interview or a press conference or a public statement

8 or also something else, as you said?

9 A. To be quite frank, it was also something else, and that was

10 secretly filmed, that's for sure. Perpetrated by the services that knew

11 how to do that kind of thing. Services, I'd like to underline. I think

12 it was the KOS at the time.

13 JUDGE HOEPFEL: The final thing -- I didn't understand -- the

14 KOS?

15 A. Counter-intelligence service of the former JNA.

16 JUDGE HOEPFEL: Thank you. Excuse me, Mr. Milovancevic, I just

17 had to ask this question. You may understand because it may be some

18 parallel, but maybe not.

19 And you had not seen this, what we now saw, these pictures of

20 Mr. Milan Martic? Did I understand you correctly? You don't remember

21 having seen it at the time?

22 A. I'm not quite sure, Your Honour.

23 JUDGE HOEPFEL: Can you --

24 A. I didn't. Certainly, Your Honour.

25 JUDGE HOEPFEL: Yes. But you had a lot of conversations at that

Page 10720

1 time, I suppose, among your colleagues in this difficult days and

2 especially with the people which you mentioned, your friends, among them

3 such friends who had not signed the petition but you were in a constant

4 contact with them?

5 A. Yes. I still maintain contacts with them today.

6 JUDGE HOEPFEL: That's nice. And do you think was there any talk

7 at that time about this broadcast on the Croatian TV, presumably Croatian

8 TV?

9 A. I now remember that a colleague of mine called Rados Zarko told me

10 that Heni filmed some footage secretly. Now, I can't be sure whether he

11 meant this footage or something else. I can't say.

12 JUDGE HOEPFEL: Okay. Now to the more general question I wanted

13 to ask you. When you -- it deals with Kijevo. Did I understand you

14 correctly, you said you came in after the police but you didn't stay

15 there, you came between 3.00 and 4.00 p.m. or so, in order to take these

16 prisoners to Knin?

17 A. Correct. About 3.00. I can't be specific.

18 JUDGE HOEPFEL: And how did you then manage taking these prisoners

19 to Knin and where in Knin did you bring them to?

20 A. Your Honour, I'll repeat that. They were lined up next to the old

21 local office along the road. 40 people got into the bus. It was a Jadran

22 Trans company bus transporting passengers along that route. I and Ceko

23 Boro [as interpreted] escorted them to the police station in Knin.

24 Whereas the other 20 left with a military bus, a small military bus, and

25 they were transported by the army in that small bus of theirs. They were

Page 10721

1 taken over to the police station in Knin. I don't know who was the duty

2 officer. And then later on they were transported to the south barracks

3 and exchanged. That's what I heard and that's the truth of it. Of the

4 40, which we brought to Knin, not a hair of their head was harmed while

5 they were there in the bus.

6 JUDGE HOEPFEL: They were regarded prisoners of war?

7 A. Of course, of course.

8 JUDGE HOEPFEL: Thank you very much.

9 A. You're welcome.

10 JUDGE HOEPFEL: Do you know the detention facility which was set

11 up in the old hospital of Knin?

12 A. No. All I know is that the people slept there, nothing more

13 than that. Not about any detention facility, prison. They slept there,

14 yes.

15 JUDGE HOEPFEL: And then something, a final question. Maybe you

16 know this person from Golubic or from somewhere else. Do you know Stevo

17 Plejo?

18 A. Stevo Plejo? Possibly, but the name doesn't ring a bell now. I

19 might recognise him if I saw him. I might know the face.

20 JUDGE HOEPFEL: Okay. Thank you, no further questions.

21 JUDGE MOLOTO: Thank you, Judge. Judge?

22 JUDGE NOSWORTHY: I just have a few questions for you.

23 Now, in respect of the 21 day training at Golubic, during the

24 time, did you learn or were you instructed in anything more than climbing

25 down a slope, climbing down a rope, and martial arts? Was that the full

Page 10722

1 extent of your training?

2 A. At the time, yes.

3 JUDGE NOSWORTHY: So you received training at a later time,

4 additional training? And if yes, what was it?

5 A. Well, in Zagreb I attended and graduated from the secondary school

6 of internal affairs. We had martial arts which we trained our young

7 generation in.

8 JUDGE NOSWORTHY: No. I mean after the training in Golubic.

9 A. No, Your Honour, no.

10 JUDGE NOSWORTHY: Now, I want to ask you a bit about the persons

11 who did training with you. What ages were they?

12 JUDGE HOEPFEL: There was something about young men, he said, I

13 remember, and I didn't -- that -- that didn't say too much actually.

14 JUDGE NOSWORTHY: What were their ages? Are you able to recall?

15 Were they in their 40s, 18 or 19 year olds or what was it that you

16 recall?

17 A. They were mostly people between 20 and 24, not older than that.

18 One or two might have been old -- slightly older but most of them were

19 that age.

20 JUDGE NOSWORTHY: These people were trained and then they would

21 join a unit, that's correct?

22 A. Yes. Mostly in the police force, but usually with older

23 colleagues who were more experienced. They weren't allowed to work on

24 their own.

25 JUDGE NOSWORTHY: Could you tell me what sort of uniform you would

Page 10723

1 wear?

2 A. I had a police uniform.

3 JUDGE NOSWORTHY: Please describe it for me, including any

4 insignia and any headgear, fully.

5 A. In Golubic? Or while I was training or generally?

6 JUDGE NOSWORTHY: Both when you were at Golubic and then

7 afterwards.

8 A. Well, in Golubic, it was a camouflage uniform and a beret.

9 JUDGE NOSWORTHY: Any emblem or insignia?

10 A. At the time, we didn't have any insignia. I didn't have an emblem

11 or insignia. That's for sure.

12 JUDGE NOSWORTHY: Nothing at all on this camouflage uniform?

13 A. I didn't have anything, certainly not.

14 JUDGE NOSWORTHY: Anything on the beret? I beg your pardon. I

15 didn't put on my microphone. Anything on the beret?

16 A. I think that there was the Yugoslav tricolour on the beret, the

17 flag of the former Yugoslavia, three-coloured.

18 JUDGE NOSWORTHY: Now, what about after?

19 A. The tricolour remained until the end.

20 JUDGE NOSWORTHY: When you say the end.

21 THE INTERPRETER: Interpreter's correction: Until later, until

22 later. The witness said, "until later."

23 JUDGE NOSWORTHY: Later meaning when?

24 A. Well, I was there until 1993. After that, I don't know.

25 JUDGE NOSWORTHY: And up to that point, your uniform remained the

Page 10724

1 same as you have just described or did it change?

2 A. Well, for the most part, they were camouflage, blue camouflage

3 uniforms. People who went in the field. The people who were in town,

4 they had the normal type of police uniform, a shirt, trousers and the

5 Titovka-type cap, not the Satka-type cap.

6 JUDGE NOSWORTHY: What was the colour of that uniform? And what

7 if anything was on the cap?

8 A. There was the three-coloured Yugoslav flag on the cap, nothing

9 more than that. Perhaps somebody might have placed something else of

10 their own accord but the official cap had the three-coloured flag.

11 JUDGE NOSWORTHY: Was there any insignia on your uniform itself?

12 Any badge, any patch? You seem to have to think harder.

13 A. No. It's not that I'm thinking hard. I know what you're asking

14 me. There was the militia or police of SAO Krajina; SAO Krajina is what

15 it said.

16 JUDGE NOSWORTHY: And you began wearing that uniform when?

17 A. I'm not quite sure. I don't know. I don't know the date when we

18 started wearing that.

19 JUDGE NOSWORTHY: Now I want you to cast your mind back. You

20 mentioned Knin and you said in respect of the -- should I repeat? In

21 respect of the Knin police station, you would go in, report for duties for

22 five minutes, receive your assignment, and then leave. You would leave

23 for beat duties in Knin or outside of Knin? Or where would you leave for,

24 having got your assignment usually?

25 A. Yes, beat patrol.

Page 10725

1 JUDGE NOSWORTHY: Yes. Where I'm asking. Where would it be?

2 A. Throughout the territory of Knin municipality. We would regulate

3 traffic and go out on patrols, on beats, Kistanje, Erdvenit [phoen],

4 Strmica, Kosovo, Civljani, Polaca, Biskupija, all those directions. We

5 covered the whole area. We would go to one area one day, to another the

6 next day, depending on where they sent us.

7 JUDGE NOSWORTHY: Right. Now, there is a final area I'm going to

8 touch on. You recall having given evidence in respect of -- one moment,

9 please -- the prisoners which were for exchange, and Mr. Martic came to

10 inspect them, and he told us, "Please make sure none of these people are

11 harmed or killed." And your colleague, I think it was Bozo Ceko, asked

12 why, and Mr. Martic said, "Well, they have to be exchanged." Do you know

13 why Mr. Martic said that to you?

14 A. I do. Bozic, and his cousin, Vaso Pecir, was killed in May and

15 Bozo Ceko was angry about that, and the two of us took them to Knin, to

16 the police station. So that's why, to prevent the man reacting in a way

17 he shouldn't react. And Bozo Ceko was in prison in Zagreb, so he was

18 angry at everyone. That's why Martic said that.

19 JUDGE NOSWORTHY: So Mr. Martic had a fear that - is it Bozo

20 Ceko? - might do some physical harm or injury to the prisoners? And he

21 was issuing a caution that because they had to be exchanged, you had to be

22 careful as to the condition they were in? And ensure that no harm befell

23 these particular prisoners? Is that so?

24 A. Not only because of that. That was standard practice with us,

25 when anything like that happened. Of course, we didn't take many

Page 10726

1 prisoners. There weren't many operations like that. Mostly the

2 population left before the action took place so there was no capturing,

3 either on our side, the Orthodox side, or the Catholic side, the Croatian

4 side. The same would have applied.

5 JUDGE NOSWORTHY: Thank you. What was standard practice?

6 A. What do you mean?

7 JUDGE NOSWORTHY: I'm not quite sure what you mean, what do you

8 mean by standard practice. You said not only that, that was standard

9 practice with us or something like that.

10 A. I meant to -- that the conduct towards the prisoners had to be

11 according to the Geneva Conventions. That's what I meant. That was the

12 practice.

13 JUDGE NOSWORTHY: But it wasn't the practice for Mr. Martic to

14 warn you, then? For your superiors to warn you?

15 A. Mr. Martic drew our attention to that because of Bozo Ceko who had

16 spent three months in Zagreb in prison. That's why he drew our attention

17 to that.

18 JUDGE NOSWORTHY: Thank you very much, Mr. Knezevic? Have I

19 pronounced your name properly? Have I done you enough justice in

20 pronouncing your name?

21 A. Yes, it is.

22 JUDGE NOSWORTHY: Thank you.

23 A. You're welcome.

24 JUDGE MOLOTO: Thank you very much.

25 Mr. Knezevic, how many Dragan Knezevics were there at Golubic?

Page 10727

1 A. Your Honour, there were Knezevics in all places in Srmik [phoen],

2 in Civljani, in Cetina, all over the place. So I simply don't know.

3 JUDGE MOLOTO: Can I interrupt you? We don't have much time.

4 Listen to my question. How many Dragan Knezevics were there in Golubic,

5 at the camp, where you were -- when you were there?

6 A. Believe me that I don't know. It may have been just me. There

7 may have been another one. I really don't know because there were between

8 250 and 300 people there so that I really don't know that.

9 JUDGE MOLOTO: You're not aware of any other Dragan Knezevic who

10 was ever at Golubic?

11 A. I know that there was a Dragan Knezevic from Strmica; now, whether

12 he was there at that time, that I don't know.

13 JUDGE MOLOTO: Mr. Knezevic, please let's not talk about Strmica.

14 I'm talking about Golubic. At Golubic, to your knowledge, you were the

15 only Dragan Knezevic, to your knowledge?

16 A. It is possible but I cannot assert that, namely it could have been

17 just me and there may have been some others. I can't say.

18 JUDGE MOLOTO: Listen to the question, please. We haven't got

19 much time. When you say it's possible, what is possible? My question to

20 you is, to your knowledge, you should know, you either know that there was

21 another or you don't know. To your knowledge, you were the only Dragan

22 Knezevic at Golubic. To your knowledge.

23 A. I don't know. I just don't know.

24 JUDGE MOLOTO: You don't know if -- okay.

25 A. I only know about me. I don't know about any others.

Page 10728

1 JUDGE MOLOTO: That's what I'm saying. To your knowledge, you

2 know only of yourself. That's the question I'm asking you, sir. I don't

3 know why it's so difficult about answering that question.

4 A. That's correct.

5 JUDGE MOLOTO: Thank you.

6 A. You're welcome.

7 JUDGE MOLOTO: You said that Kijevo was a Croat Alamo. What is an

8 Alamo?

9 A. The Croatian media actually extolled Kijevo, calling it the

10 Croatian Alamo, and Mr. Franjo Tudjman said himself that when Kijevo fell,

11 Croatia would fall, and I don't know what exactly he meant.

12 JUDGE MOLOTO: My question is what is an Alamo.

13 A. Alamo is a city in the United States. It is a symbol of the

14 United States. It is a symbol of their fight for freedom against the

15 Indians. I'm not quite sure. I'm not that familiar with their history.

16 JUDGE MOLOTO: Thank you very much.

17 JUDGE HOEPFEL: It's against the Mexicans, not the Indians, the

18 fight against the Mexicans. And they lost the Alamo, in San Antonio.

19 A. As I said I'm not very familiar with the history.

20 JUDGE HOEPFEL: If you maybe had seen this or movie but just, it is

21 not against the Indians --

22 A. I apologise.

23 JUDGE MOLOTO: Who was Heni, the person who secretly filmed the

24 footage? You suggested he probably filmed the [Microphone not activated].

25 A. Yes, I did mention Heni Erceg, she was a correspondent for the

Page 10729

1 Slobodna Dalmatia, a Croatian lady journalist who worked in Split for the

2 Slobodna Dalmacija. I had heard of her. I had heard her name referred

3 to. She was a quite well known journalist in Croatia.

4 JUDGE MOLOTO: Now, did I hear you correctly to say that she is

5 the probably the one who filmed this film -- this footage of Mr. Martic

6 secretly? Or did I mishear?

7 A. I heard that from my colleague, Zarko, Rados, that she had filmed

8 it. I wasn't there then.

9 JUDGE MOLOTO: So you knew about there footage before you came to

10 court today. Because you were told it was filmed by -- you were told by

11 Zarko Rados that she filmed it.

12 A. Just one minute, Your Honours. I didn't know that that was this

13 particular footage. I knew of the existence of some video footage. I

14 didn't know that it was this particular one which I saw for the first time

15 today.

16 JUDGE MOLOTO: So you can't say that this footage was done by

17 Heni. You can't say it was done secretly. If you don't know, you have no

18 basis for talking about Heni and secretly footing -- filming this footage.

19 You were just speculating. Am I right?

20 A. Your Honours, I said that I had heard about this from my colleague

21 Zarko Rados, who had been there. I hadn't seen it myself. Had I seen it

22 myself, I would have described it differently. I cannot claim that it was

23 done secretly or publicly.

24 JUDGE MOLOTO: Please listen to the question. You were told by

25 Ratko -- Zarko Rados.

Page 10730

1 A. Yes.

2 JUDGE MOLOTO: About secret filming of a footage of some sort.

3 You don't know what film was the footage. Therefore when you say maybe

4 this is the one you are actually speculating. You are not -- you can't --

5 you have no basis for saying what you heard from him relates to this film

6 that we saw today.

7 A. That is correct.

8 JUDGE MOLOTO: Thank you. Now, you said that Mr. Martic ordered

9 you to make sure that nothing became of the prisoners that were being

10 taken to Knin. He said that to you because he was your superior, he was

11 in control, am I right?

12 A. That is right.

13 JUDGE MOLOTO: And you also referred in answer to question by

14 Judge Nosworthy, that the people, the police who went to the field wore

15 camouflage uniform and the police in town wore the normal type uniform.

16 Remember that? Just a few minutes ago.

17 A. Yes.

18 JUDGE MOLOTO: What was the colour of the normal-type uniform that

19 was worn by the police in town?

20 A. The shirt -- the jacket was light blue, and there was -- actually

21 the shirt was light blue and the jacket was dark blue and the trousers

22 were greyish blue. That is the summer uniform. And then the winter

23 uniform was greyish blue and it also had a light blue shirt and a tie was

24 worn with it.

25 JUDGE MOLOTO: When you say light blue are you talking of

Page 10731

1 something that looks like the screen of your -- the screen in front of

2 you? The screen of this monitor in front of you?

3 A. Just like this colour at the very top of the monitor. That blue.

4 At the very top of the screen.

5 JUDGE MOLOTO: Okay. Unfortunately, I don't see your screen and

6 I've got -- my two screens show different colour blue. So I'll leave it

7 at that but you say that -- do you see any blue in this room that you

8 can --

9 A. The colour of Mr. Martic's shirt.

10 JUDGE MOLOTO: The colour of Mr. Martic's shirt. Maybe you must

11 get Mr. Martic as an exhibit.

12 A. What can I do?

13 JUDGE MOLOTO: My last question to you: On what basis do you say

14 broadcasting this speech that we saw on the clip here would fan the flames

15 of national passions? You said so in answer to a question by the Defence

16 counsel.

17 A. Excuse me, what speech are you referring to?

18 JUDGE MOLOTO: Mr. Milovancevic asked you about the clip that we

19 saw here where Mr. Martic was speaking. You remember that clip? The

20 footage that we saw today. Right. And he asked you what company,

21 television, this was that broadcast it and you said it must have been a

22 Croatian television. He asked you what would be the effect of

23 broadcasting that kind of -- and what was the purpose of the television

24 company broadcasting and you said the purpose that -- the only purpose

25 that you could see was to fan the flames of national passions. You

Page 10732

1 remember that? Now, you seem to be lost. Let me take you back to your

2 words.

3 A. I do remember that, yes, yes.

4 JUDGE MOLOTO: You remember that. My question to you is: On what

5 basis do you say, why do you say, broadcasting that would fan the flames

6 of national passions? Broadcasting never fans national passions.

7 Broadcasts are broadcasts. Why do you say that?

8 A. Your Honour, I understand your question fully, and you are

9 suggesting the answer to me, and I will give you an answer right now. The

10 broadcasting of this footage that we have seen here on this screen could

11 have had a countereffect and it did have a countereffect among Croatian

12 people, namely they --

13 JUDGE MOLOTO: My question to you is why do you say that?

14 A. I say it because I, as a member of the interior forces, the

15 regular organ of the Interior of the Republic of Croatia, remained without

16 everything that I had in Croatia, and remained virtually without anything.

17 JUDGE MOLOTO: Sir, I'm sorry, you're not answering my question.

18 You're answering another question. My question is very simple. Why would

19 broadcasting that footage fan national passions? Just tell me that,

20 please. Just answer my question.

21 A. Well, I'll be frank. Someone needed that and who it served

22 somebody's interests and it was others who made the decisions that I don't

23 know whose purposes it served.

24 JUDGE MOLOTO: You're still not answering my question. I'm sorry,

25 I'm asking you why you say that broadcasting that clip would fan national

Page 10733

1 passions. Why would broadcasting fan national passions?

2 A. Because Mr. Martic stated that he didn't want the chequer-board

3 flag as an emblem, that he didn't want the police to be called the

4 redarstvenici in the police station at Knin, or in what was referred to as

5 the Republic of the Serbian Krajina, which was in existence at that time

6 because those were emblems that irritated. And he didn't want them

7 because they were reminiscent of a dark past.

8 JUDGE MOLOTO: Okay. So in fact, you're now talking about what

9 Mr. Martic said not the broadcasting so it was because of what was being

10 said that you think national passions would have been fanned. Am I

11 right?

12 A. Well, it depends, depends on whom you show it to. If you show it

13 to the Croatian public, it will certainly be inflammatory. If shown to

14 the Serbian public --

15 JUDGE MOLOTO: You didn't say that to Mr. Milovancevic. You said

16 it would fan national passions. You didn't say, it depends on what. I'm

17 asking you, you say so because of what was being said in that statement,

18 isn't it so? That's what fanned the national passion. What was said in

19 that statement, what fanned the national passion, isn't that so?

20 A. Mr. Martic stated that he didn't want the Croatian authorities

21 there.

22 JUDGE MOLOTO: Please answer my question. We are way past the

23 time we should knock off. I'm not asking you what Martic said. I'm

24 asking you what fanned national passions was the content of the statement.

25 Is that not so?

Page 10734

1 A. What was stated in the statement, which we have seen here, it is a

2 very complex issue and I cannot give you a simple answer.

3 JUDGE MOLOTO: You see, I asked you a very simple question in the

4 beginning. I said, why would the broadcasting fan the passions, because

5 that's what you said in your answer. And do you know what you said

6 amongst other things? You said because Mr. Martic mentions the

7 chequer-board, mentions these things and that thing, and he doesn't like

8 those things. That's why I've moved from broadcasting to the content. So

9 based on what you said, that it is because of what Mr. Martic said so you

10 are actually agreeing with me that it is the content of the speech that

11 fans the passions. Is that not so? It's a very simple question. Can you

12 just say yes or no?

13 A. That this -- Martic's statement actually led to the fanning of

14 passions, no, no. Because seeing that there was a generally negative --

15 the emotions were running high and were generally negatively charged, this

16 can be characterised in a number of ways.

17 JUDGE MOLOTO: Now, if you say that it's not the statement that is

18 fanning the passions, how does broadcasting fan the passions? Because you

19 never answered that question. Tell me now: Why is broadcasting fanning

20 passions?

21 A. Your Honour, it depends on when it is broadcast, to what audience

22 it is broadcast, before whom it is broadcast.

23 JUDGE MOLOTO: My question to you is simple, sir: Why is the act

24 of broadcasting fanning passions. The statement is clean. There is

25 nothing that fans passions you've just told us. Why is the act of

Page 10735

1 broadcasting fanning passions, it doesn't matter to whom. Why?

2 A. I believe that I have sufficiently responded to this question.

3 JUDGE MOLOTO: I'm not crazy. If you had sufficiently responded I

4 would have stopped asking you questions.

5 A. Your Honour, I wish to say this. It depends on how you interpret

6 or convey someone's statements and at what particular moment it is

7 broadcast. This is what it depends on the most. Perhaps it would not

8 have had an effect and then again it might have had a tremendous effect.

9 JUDGE MOLOTO: Why didn't you say to Mr. Milovancevic when he

10 asked you the question, it depends? You just said it fans the passions.

11 You didn't say it depends on who you say it to or how you broadcast it.

12 Why didn't you say to him, it depends? Why do you give me a different

13 answer from the one you gave Mr. Milovancevic?

14 A. No. I'm not giving you a different answer but the gentlemen

15 didn't ask me about the details and you're asking me about the details.

16 That is why I answered in such extensive fashion.

17 JUDGE MOLOTO: I'm not asking you about the details. I'm asking

18 you why broadcasting that statement fans passions. You said to

19 Mr. Milovancevic broadcasting it fans passions. I'm asking you why. And

20 you didn't say to Mr. Milovancevic, oh, it depends. Why do you say "it

21 depends" to me? That's a different answer you're giving me.

22 A. Your Honour, Mr. Milovancevic asked me, and I should quote him,

23 "Would the broadcasting of such a statement fan national passions? Or

24 not?" And I said, "Yes, it would." He didn't ask me anything more than

25 that.

Page 10736

1 JUDGE MOLOTO: Yeah. I'm just asking you one question. Why would

2 that fan national passions. If you answer me that, then we go home.

3 A. Well it goes without saying, because of the statement itself. But

4 I should like to add it depends where it is broadcast and before what

5 audience, to what audience.

6 JUDGE MOLOTO: What fans national passions is the statement. It's

7 not the broadcasting, it's what you're saying from what you just told me

8 now. It is the statement that fans passions, not the broadcasting. If

9 that broad statement was not made, there would have been no fanning of

10 passions. Do you agree with me?

11 A. Yes, I agree with you.

12 JUDGE MOLOTO: Thank you. Thank you very much. It has taken --

13 it was like extracting a tooth. Okay. There can obviously be no

14 re-examination --

15 A. Almost.

16 JUDGE MOLOTO: We are going to have to adjourn until next week

17 because -- okay. Yes, Mr. Black?

18 MR. BLACK: I apologise, Your Honour, I was just going to say I

19 don't have any follow-up questions.

20 JUDGE MOLOTO: I don't know whether Mr. Milovancevic has so --

21 MR. MILOVANCEVIC: [Interpretation] No, Your Honour.

22 JUDGE MOLOTO: You don't. Thank you very much.

23 In that event, sir, thank you very much for coming to court. This

24 brings us to the end of your testimony. On behalf of the Chamber, once

25 again I thank you. You are now excused. You may stand down.

Page 10737

1 [The witness withdrew]

2 THE WITNESS: [Microphone not activated].

3 THE INTERPRETER: What the interpreter could hear was, "Can I just

4 say hello to Mr. Martic?"

5 JUDGE MOLOTO: We are in court, please. Just go out, please. No,

6 just go out, you'll talk to -- sorry.

7 Mr. Milovancevic we have that housekeeping matter that you were

8 going to talk to your team about.

9 MR. MILOVANCEVIC: [Interpretation] Your Honours, at this moment, I

10 can only tell you that we shall endeavour to do that as urgently as

11 possible. If the period should prove to be too short, we shall postpone

12 that witness for somewhat later so that we shall be mindful of the OTP's

13 needs to have sufficient time to acquaints themselves with the statement

14 and the witness.

15 JUDGE MOLOTO: You said that that witness is coming to testify

16 only on Thursday.

17 MR. MILOVANCEVIC: [Interpretation] That is correct, Your Honours,

18 certainly not before that time.

19 JUDGE MOLOTO: We have other witnesses coming on Monday before

20 Thursday.

21 MR. MILOVANCEVIC: [Interpretation] Your Honours, for Monday and

22 Tuesday, we have no witnesses. In view of the instruction that we have

23 been issued from you, we are preparing a wholly new schedule of our

24 witnesses and we are seeking to finish the case within the deadline set by

25 you so that we are now selecting our witnesses and rescheduling our

Page 10738

1 witnesses. We will be informing you what witnesses will be appearing, of

2 course, always trying to fully abide by the deadline that you have set for

3 us. We shall, in fact, honour that deadline. There is no question mark

4 about it, to be more precise.

5 JUDGE MOLOTO: Thank you for that. But you're saying Monday and

6 Tuesday we have no witnesses?

7 MR. MILOVANCEVIC: [Interpretation] No, we don't have any witnesses

8 secured at this point in time. We have, in fact, informed you that we

9 have abandoned some witnesses and as regards the other witnesses, we are

10 reassessing everything which still needs to be presented in our case,

11 including expert reports, expert findings, and we shall be informing of on

12 all this on Monday the minute we have finish our preparations. We please

13 ask to you bear with us.

14 JUDGE MOLOTO: Yes, Mr. Whiting?

15 MR. WHITING: If I may, I'm grateful for the indications from

16 Mr. Milovancevic but it seems that Wednesday also would be -- there would

17 be nothing scheduled for Wednesday because the next witness that -- the

18 only witness that we've been told about is -- we have been told is coming

19 on Thursday at the earliest. We have been told about no other witnesses.

20 So I assume that Wednesday is also off, and if we could get some

21 clarification on that.

22 JUDGE MOLOTO: Mr. Milovancevic, can you clarify us, please? And

23 while your learned friend is grateful for the indication, I regret that we

24 get the indication so late.

25 Yes, Mr. Milovancevic?

Page 10739

1 MR. MILOVANCEVIC: [Interpretation] Your Honours, we were

2 confronted with the position of the Trial Chamber a few days ago and we

3 are seeking to honour your instructions. We had in mind certain witnesses

4 but we were unfortunate - and I'm not going to refer to any names - that

5 some of our witnesses had to be abandoned because of some health problems,

6 so that we are seeking to rearrange the other witnesses that we --

7 JUDGE MOLOTO: Mr. Milovancevic, listen to the point and the

8 question at issue. The question at issue is, we want you to confirm: Is

9 Wednesday also off? Just yes or no. You told us a whole lot and you

10 didn't answer the point.

11 MR. MILOVANCEVIC: [Interpretation] Your Honours, may I inform the

12 Trial Chamber about that on Monday? We have scheduled two witnesses who

13 might make it on time but I'm not quite sure. On Monday and Tuesday, we

14 certainly shall have no witnesses. Probably not on Wednesday either but I

15 cannot be sure at this point and I cannot tell you anything more to be --

16 if I want to be precise and serious. You are always criticising me,

17 Your Honour, saying words are binding and I cannot give you a binding

18 promise at this point. I'm quite aware of that fact. This is actually

19 self criticism because sometimes in the past we scheduled things which

20 then didn't actually occur. That is what I want to avoid, such

21 embarrassment again.

22 JUDGE MOLOTO: Mr. Milovancevic, to what day must we postpone now?

23 Do we postpone to Wednesday? Do we postpone to Thursday?

24 MR. MILOVANCEVIC: [Interpretation] Until Thursday, Your Honours.

25 JUDGE MOLOTO: Until Thursday. Okay.

Page 10740

1 MR. MILOVANCEVIC: [Interpretation] Yes, Your Honours, thank you.

2 JUDGE MOLOTO: So you are sure it's not standing there, That

3 Wednesday is off.

4 MR. MILOVANCEVIC: [Interpretation] That is correct, Your Honours.

5 JUDGE MOLOTO: That is what you should have said ten minutes ago,

6 okay.

7 MR. MILOVANCEVIC: [Interpretation] Well, I apologise.

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

9 Yes, Mr. Whiting.

10 MR. WHITING: I think it's clear that Monday, Tuesday, and

11 Wednesday there will be no court. Just to be clear that, if there is an

12 attempt to change that position on Monday and tell us suddenly that a

13 witness is coming on Wednesday, that's not possible. That's just not

14 possible. We cannot prepare for a witness in two days, so we are going to

15 the bank on the fact that there is not going to be any witnesses. Even if

16 he told us today, it wouldn't be possible. We have been told about one

17 witness next week. We can prepare for one witness and that's it.

18 MR. MILOVANCEVIC: [Interpretation] It is exactly as my learned

19 colleague, Mr. Whiting, has said.

20 JUDGE MOLOTO: All right. Thank you very much, Mr. Milovancevic.

21 It's a pity but I do hope that notwithstanding those three days gone, you

22 will still finish on the 20th of November or better still even before.

23 Well, the matter then stands postponed to Thursday, the 9th of

24 November, at 9.00 in the morning in Courtroom II. Thank you. Court

25 adjourned.

Page 10741

1 --- Whereupon the hearing adjourned at 7.18 p.m.,

2 to be reconvened on Thursday, the 9th day of

3 November, 2006, at 9.00 a.m.