Tribunal Criminal Tribunal for the Former Yugoslavia

Page 13068

 1                           Thursday, 26 August 2010

 2                           [Open session]

 3                           [The accused entered court]

 4                           [The witness takes the stand]

 5                           --- Upon commencing at 9.02 a.m.

 6             JUDGE MOLOTO:  Good morning, everybody in and around the

 7     courtroom.

 8             Mr. Registrar, would you please call the case.

 9             THE REGISTRAR:  Good morning, Your Honours.  Good morning to

10     everyone in and around the courtroom.  This is case number IT-04-81-T,

11     the Prosecutor versus Momcilo Perisic.  Thank you.

12             JUDGE MOLOTO:  Thank you so much.

13             Could we have the appearances for the day, starting with the

14     Prosecution, please.

15             MR. HARMON:  Good morning, Your Honours, counsel, everyone in the

16     courtroom.  Mark Harmon and Salvatore Cannata for the Prosecution.

17     Ms. Javier has been delayed by the inclement weather, and she will join

18     us during the proceedings.

19             JUDGE MOLOTO:  Thank you so much.

20             And for the Defence.

21             MR. LUKIC: [Interpretation] Good morning.  Good morning,

22     Your Honours.  Good morning to all the participants in the proceedings.

23     General Perisic is represented today by Boris Zorko and Novak Lukic.

24             JUDGE MOLOTO:  Thank you very much, Mr. Lukic.

25             Good morning, Mr. Novakovic.  Just to remind you that you're

Page 13069

 1     still bound by the declaration you made at the beginning of your

 2     testimony to tell the truth, the whole truth, and nothing else but the

 3     truth.  Thank you so much.

 4             Mr. Lukic.

 5                           WITNESS:  MILE NOVAKOVIC [Resumed]

 6                           [Witness answered through interpreter]

 7                           Examination by Mr. Lukic: [Continued]

 8        Q.   [Interpretation] Good morning, General.  Now that -- actually,

 9     now when you walked into the courtroom I think that you tried to tell me

10     something and I think that I understood what you were trying to say;

11     however, we are not allowed to communicate.  So could you please address

12     the Court.  Could you please say what it was.  I think that it was due to

13     the air-conditioning that you've started coughing or something, the

14     air-conditioning in the courtroom.

15        A.   Yes, I think I have a bit of a throat problem, but it's

16     meaningless really.

17        Q.   [In English] Okay.

18             JUDGE MOLOTO:  Nothing is meaningless, Mr. Novakovic.  If you do

19     not feel well, as I indicated at the beginning of your testimony

20     yesterday, please do indicate, and let's see what we can do to help.

21     If -- I don't know whether we can switch off the air con, but we might

22     perhaps give you a break to go and get fresh air outside, if it happens.

23             THE WITNESS: [Interpretation] Thank you very much, Your Honour.

24     I think that we can consider the situation to be normal.  If I cough a

25     bit every now and then, I do apologise.

Page 13070

 1             JUDGE MOLOTO:  Thank you very much.  I understand.

 2             Yes, Mr. Lukic.

 3             MR. LUKIC: [Interpretation] This just reminded me of something

 4     that I heard from witnesses after their testimony.  I just remember that.

 5     They told me that where they sat - I can't remember whether it was in

 6     this courtroom though - but they had the air-conditioning blowing right

 7     into them.  Maybe it was in another courtroom.  Never mind.  They said

 8     that they felt this flow of air coming right at them.  I think it was

 9     Witness Nikolic, but that is no reason for any objections or any kind of

10     dialogue with respect to that.

11             JUDGE MOLOTO:  Thank you.

12             MR. LUKIC: [Interpretation]

13        Q.   General, let us continue where we broke off yesterday.  I would

14     just like to go back to a topic that I omitted yesterday because I did

15     not have the adequate translation.  So we're going to go back into the

16     past again, the period of the autumn of 1991, or rather, more

17     specifically, December 1991, when you were part of the

18     1st Operations Group that was sent by the SSNO to the territory of

19     Baranja.

20             MR. LUKIC: [Interpretation] Could we have P1196 on the screen,

21     please.

22        Q.   As we can see, this document is the Law on Defence and it was

23     promulgated by the government.  I think that the Trial Chamber does not

24     have the first page of the document before them, but what is written on

25     the first page is that the Government of the SAO Krajina passed a

Page 13071

 1     Law on Defence on the 2nd of December, 1991.  The Prosecution tendered a

 2     few articles of this law.  This is a voluminous document.  It has quite a

 3     few articles, about 150 or 120.  I would be interested in Article 31.  I

 4     think that that is one of the articles that the Prosecution tendered into

 5     evidence as well.

 6             MR. LUKIC: [Interpretation] B/C/S page is page 6, page 6 of the

 7     document.  In English it starts at the end of page 2 and continues on

 8     page 3.

 9        Q.   General, I'm interested in the first paragraph.  Please read it

10     to yourself, the first paragraph of Article 31?

11        A.   I've read it.

12        Q.   Yesterday we discussed this --

13             MR. LUKIC: [Interpretation] Actually, could the next page in

14     English be brought up so that the Trial Chamber can follow.

15        Q.   The Territorial Defence that, on the basis of this law became -

16     if I can put it that way - part of the system of the then-Serb autonomous

17     region of the SAO Krajina on the 2nd of December, 1991.  According to

18     this particular regulation and according to the contacts you had then

19     with the members of the TO staffs at the time, what do they consider

20     themselves to be?  Were they part of the single system of defence and

21     armed forces of the SFRY or did they consider themselves to be something

22     separate?

23        A.   The actual practice was - and that was the understanding that

24     people had in the Territorial Defence - that they were, as was the case

25     until then, on the basis of regulations, part of the single armed forces

Page 13072

 1     of the Socialist Federal Republic of Yugoslavia.

 2        Q.   Now I would like to -- now I would like to look at Article 34.

 3     In the B/C/S it's the same page, and I'm going to call up the English

 4     translation because that article was not admitted into evidence when the

 5     Prosecution tendered it.

 6             MR. LUKIC: [Interpretation] So I would like to call up Article 34

 7     as ET 1D12-0969.

 8        Q.   This is a draft translation, may I say.  General, I'm interested

 9     in the first paragraph -- actually, the entire article.  I would like to

10     hear your comment.  In actual fact, you testified about this yesterday.

11     This has to do with control and command in this Territorial Defence.  You

12     said that there were staffs and units in the Territorial Defence.

13             According to this article here, it says that command and control

14     in the Territorial Defence has to do with the fact that these staffs

15     command the TO units.  What was the situation in December 1991 in

16     practice in relation to this provision of the law?

17        A.   In the autumn and winter of 1991, these staffs, where they had

18     been established - and they had been established up to zone level and

19     province level in the Serb autonomous region of Krajina - they did not

20     directly command units.  The units were directly commanded by the

21     commands of the Yugoslav People's Army that were in a particular area.

22     These staffs could not do that, they did not have the right conditions

23     for doing that, and they didn't do so in practice.

24        Q.   These TO units, these TO units that had been established

25     according to the old system of the armed forces of the SFRY -- or

Page 13073

 1     actually, are we talking about some newly established TO units?

 2        A.   These are units that were established according to the

 3     mobilisation plan that existed before the war.

 4        Q.   Thank you.

 5             MR. LUKIC: [Interpretation] Your Honours, since this is a draft

 6     translation, once we've received an official translation of this article,

 7     perhaps we could just attach that to the existing P exhibit.  Otherwise,

 8     in B/C/S Article 34 that I'm interested in is already part of this

 9     exhibit in B/C/S.  So that is what I'm primarily interested in.

10             JUDGE MOLOTO:  Thank you.  You're not asking for anything.  We'll

11     hear you when you make your request in future.

12             MR. LUKIC: [Interpretation] Yes.  Yes, once I've received an

13     official translation.  Thank you.  Thank you, Your Honour.

14             I don't need this document any longer.

15        Q.   And now we're going to go back to what you testified yesterday.

16     Yesterday we saw a document appointing you commander of the Serb Army of

17     the Krajina general.  It's October 1992.  Can you tell us, General, what

18     you did, what your first tasks were when you were appointed commander of

19     the Serb Army of the Krajina?

20        A.   My first task was to tour the entire area of the Serb Republic of

21     the Krajina to see the situation in the Territorial Defence and also the

22     PJMs.  Also, to see what kind of information existed about the enemy, to

23     talk to the leaders of the Republic of the Serb Krajina about their

24     expectations in relation to defence, and to carry out an analysis,

25     together with my co-workers, of the possible ways in which the Serb Army

Page 13074

 1     of the Krajina could be organised.  Several variants were involved.  We

 2     had to deal with the situation as it was.

 3        Q.   And what were the moves that followed?

 4        A.   First of all, all the solutions that were being offered to us as

 5     the possible ones had a serious constraint, and that constraint was the

 6     presence of UNPROFOR and our resolve not to go beyond the Vance Plan in

 7     any way.  In practical terms, that meant that at that point in time, as

 8     regards the Serb Army of the Krajina, we were establishing it from an

 9     administrative and organisational point of view; we are setting it up in

10     terms of personnel; we are making assessments of the possible ways in

11     which the population in the territory of the Republic of the Serb Krajina

12     could come under threat.  And we did all of that in accordance with the

13     rules covering military geographic assessments on the one hand; and on

14     the other hand, we had to look at what we had available, what we had in

15     our hands at the time.

16        Q.   Was the establishment of the army being set up then; and if not

17     then, when?  And who did it?

18        A.   The organisational order was written up then for establishing the

19     Serb Army of the Krajina.  That means that for the most part we proceeded

20     from the situation that we actually found on the ground, what had already

21     come to be in certain territories of the Republic of the Serb Krajina in

22     the armed conflicts that had taken place until then.  As for classical

23     formations in terms of internal regulations - I mean as the book of

24     establishment, that's where it always says what the name of the unit is,

25     what the number is, what the military post code is, then the duties

Page 13075

 1     according to establishment, ranks according to establishment, and so

 2     on - we didn't do any of that then.  The Main Staff didn't really have

 3     the resources to do that because it was undermanned itself.

 4        Q.   And how was the establishment organised?  What was the

 5     organisational structure according to which the units of the Army of the

 6     Serbian Krajina were set up?

 7        A.   It was a corps-brigade organisational system, which was common at

 8     the time in most of the armies of the world except for the US army.

 9        Q.   And whose decision or whose idea was it to adopt such an

10     organisational system for the Serbian Army of the Krajina?

11        A.   It was myself and my associates'.

12             MR. LUKIC: [Interpretation] Can we look at D164 now, please, on

13     the screen.

14        Q.   While we're waiting for the document, General, which structures

15     became part of the Army of the Serbian Krajina in relation to the

16     previous situation in the field?

17             General, what comprised the Serbian Army of the Krajina?

18        A.   The Army of the Serbian Krajina comprised the staffs of the TO,

19     units -- the Posebne Jedinice Milicije, the PJMs, and the ranks were also

20     replenished by all military conscripts, regardless of the fact whether

21     they were in the TO or the PJM at the time, but were able-bodied.

22        Q.   That organisation that you devised at the time, what was the

23     estimate of the strength of the Army of the Serbian Krajina?

24        A.   We felt at the time that in the conditions where the people in

25     the area of the Serbian Krajina were most in danger, the Army of the

Page 13076

 1     Serbian Krajina should number up to 80.000 men.  But with maximum

 2     efforts --

 3             JUDGE MOLOTO:  Mr. Novakovic, we know what your wishes may have

 4     been.  The question is:  What was the strength?  Not:  What is the

 5     strength that you wished for?

 6             THE WITNESS: [Interpretation] Your Honour, the army as such at

 7     that point in time did not exist.  We were planning to form these units

 8     then, in the event of the imminent and open danger.  And that is why on

 9     the basis of an incomplete insight into the demographic resources and the

10     official census of the population in the municipalities, we felt that we

11     could reach this number.

12             JUDGE MOLOTO:  Sure.  But did there come a time when you did

13     establish an army?

14             THE WITNESS: [Interpretation] Yes.

15             JUDGE MOLOTO:  And when that time came, what was the strength of

16     the army?

17             THE WITNESS: [Interpretation] If we are also including the PJMs

18     and the TO staffs, that number ranged from 15- to 18.000.

19             JUDGE MOLOTO:  Total army?

20             THE WITNESS: [Interpretation] Yes.

21             JUDGE MOLOTO:  Does that answer your question, Mr. Lukic?

22             MR. LUKIC: [Interpretation] I don't think so because my question,

23     Your Honour, Judge Moloto -- well, if you look at this line, I was going

24     to go in order, and I was planning to put all of those questions to the

25     witness.  So line 18 on page 8, my -- my question was:  What was the plan

Page 13077

 1     for the size of the army?  And then I was going to put the questions that

 2     you have just put to the witness yourself.

 3        Q.   But this answer that you just gave, General, 15- to 18.000 men,

 4     at what point in time did the Army of the Serbian Krajina number that

 5     much?

 6        A.   This was after the army was formed, and this number included the

 7     PJMs and all the municipal and area TO staffs as well as the Main Staff.

 8        Q.   After that point in time, in the next phase of the existence of

 9     the Army of the Serbian Krajina for as long as you were the commander of

10     that army, in relation to the planned strength of 80.000, did you have a

11     mobilisation, was there a response, were the units manned up to a larger

12     number, the units of the Army of the Serbian Krajina?

13        A.   After the Croatian forces carried out an offensive, an attack, in

14     the Maslenica inlet and the Ravni Kotari area and along the valley of the

15     Cetina River from Sinj towards Glina, all that we had we mobilised, and

16     that is when we approached that figure of 80.000, and that is when we

17     took the weapons from the UNPROFOR depots.

18        Q.   We will come to that question quite soon.  But now that we're on

19     this topic, I'm interested in the officer cadre of this Army of the

20     Serbian Krajina, the commissioned and non-commissioned officer cadre.

21     What was the plan, and how many men did you have at the begin?  That's

22     the first question.

23        A.   The officer and non-commissioned officer cadre in the Army of the

24     Serbian Krajina mostly consisted of reserve-strength officers, both

25     commissioned and non-commissioned officers from that area, and a slightly

Page 13078

 1     smaller number were officers and non-commissioned officers of the

 2     Yugoslav People's Army from that area.

 3        Q.   Here in our court documents we do have some numbers.  But what

 4     I'm interested in:  In relation to the planned organisational structure

 5     of the Army of the Serbian Krajina, what was the percentage, in the

 6     beginning, of the planned number of officers and non-commissioned

 7     officers pursuant to this organisational structure?

 8        A.   I think that now we're going into an area where I really am not

 9     able to give you specific numbers, and this is why:  We needed to have

10     battalion commanders of the rank of major, those who had completed

11     military academy.  We just had 50 per cent of such officers as battalion

12     commanders.

13        Q.   Well, just a moment.  Let us be precise.  When you say "who

14     completed the military academy," this is what we were talking about

15     earlier, the professional cadre of the former JNA.  I don't want to

16     suggest anything to you, but that would be that, a person who completed

17     military academy is somebody who is understood to be an active-duty

18     professional military man.  Is that correct?

19        A.   Yes.  That would be so because there was no other military

20     academy in the area of the former Yugoslavia.  If I may continue now --

21        Q.   Yes, yes, yes.

22        A.   I cannot say now if we had the other 50 per cent of battalion

23     commanders or not.  I mean, all the battalions had commanders, but we had

24     what we had.  Some places, these were non-commissioned officers also who

25     had proved themselves in battle and who had gained some kind of authority

Page 13079

 1     among the men.

 2        Q.   When you say "non-commissioned officer," do you mean active JNA

 3     non-commissioned officers or those who had been given that status within

 4     the Army of the Serbian Krajina?

 5        A.   I mean both, Mr. Lukic, both.  It wasn't important to us which

 6     one it was, particularly at that time, whether somebody had been in the

 7     JNA or not.  The main thing was whether the person was fit for such duty.

 8        Q.   General, we see a map now on the screen and it has some terms in

 9     English.  But tell us, are you able to comment on this map?  I'm

10     interested in it in the sense that you were talking about in the

11     corps-brigade organisation system of the Army of the Serbian Krajina.

12     Can you tell us how the territorial organisation of those corps was, and

13     was that the same situation that was in effect from the beginning until

14     the end of the war?

15        A.   When we were setting up the organisation of the Army of the

16     Serbian Krajina, certain areas of the Republic of the Serbian Krajina -

17     and you can see that on the map - we're talking about Northern Dalmatia.

18        Q.   Perhaps the usher can help and he can set up the marker for you

19     so that you can point things out for us on the map.

20        A.   Northern Dalmatia --

21        Q.   Well, let's go in order.  It says something here in the English

22     language, what you wrote just now.  What was that corps?  What was its

23     name?  And was it there throughout the whole war?

24        A.   All right.  I will skip a part of the answer, as you wish.  So we

25     have Northern Dalmatian where we had the 7th Corps in the Lika area,

Page 13080

 1     which was a topographic whole, there was the 15th Corps.  In the Kordun

 2     area, the 21st Corps was formed.  In the Banija area there was the

 3     39th Corps that was formed.  And then in Western Slavonia you had the

 4     18th Corps.  And then you had the 11th Corps in east Slavonia, Baranja,

 5     and Western Srem.

 6             MR. LUKIC: [Interpretation] For the needs of the transcript, I

 7     would just like to note that the witness circled the corps names --

 8     numbers.

 9        Q.   You mentioned the term topographical.  So for an army or a

10     country as a whole, what would you say was the main characteristic

11     specific to the Republic of the Serbian Krajina?

12        A.   What you can see right away when you analyse the geographical

13     area is that the eastern area is completely separate and physically

14     remote from the rest of the territory.  The western part is elongated and

15     very shallow, looked at from a military perspective in case of action by

16     forces along the line -- the front line between the forces of the Serbian

17     Krajina and the Croatian forces.  The depth of the territory or the width

18     of the territory, if you wish, was from 30 to 50 kilometres broad.  But

19     when you look from the Dinara Mountains via Benkovac, in this area it was

20     some 80 kilometres broad.  All the other area was quite shallow, quite

21     elongated, and exposed to being cut off.

22             What I tried to tell you in the beginning was this:  When we were

23     looking at this, we had zone staffs there.  And this wasn't something

24     that was set up just like that.  The Dalmatia is separated from the

25     Dinara, and that was a border there.  So there was also a border between

Page 13081

 1     areas of responsibility between Lika and Kordun.

 2     There was also a boundary between Kordun and Banija.  And

 3     Western Slavonia, although there was a physical connection, there was no

 4     possibility of actually reaching the area.  In order to reach that area,

 5     you had to go through Republika Srpska in order to reach Western Slavonia

 6     or the area of responsibility of the 18th Corps, which was quite

 7     unfavourable.

 8        Q.   Let us be precise because of the map.  We don't want to be

 9     confused later.  So let's clarify.  The territory controlled by the

10     39th Corps, in order to reach the area controlled by the 18th Corps,

11     there was no direct access.  It did exist physically, but it was not

12     actually used.  The way to reach it was through the territory of

13     Republika Srpska.  Is this what you wanted to say?

14             JUDGE MOLOTO:  Yes, Mr. Harmon.

15             MR. HARMON:  Your Honour, that's a leading question and I object.

16     The witness can say what he wanted to say, not Mr. Lukic.

17             JUDGE MOLOTO:  Mr. Lukic.

18             MR. LUKIC: [Interpretation] I apologise.  I'm sorry.  I just

19     wanted to help, but in a wrong way.  And eventually I did something I am

20     not allowed to.

21        Q.   General, could you please explain whether there was any physical

22     connection there; and if not, why.

23        A.   In this part that I proximately marked, the territory of Banija

24     and the territory of Western Slavonia join -- are joined on the

25     Sava River, and there is a railway bridge there.  There's only a railway

Page 13082

 1     bridge there.  This bridge was never operational for passenger transport,

 2     and the land around it is a marsh land.  Therefore, one had to go, as I

 3     said, across the territory of Republika Srpska, or rather, under the

 4     control of the Army of Republika Srpska.

 5        Q.   Thank you.  While we are still looking at the map, two more

 6     things.  There is something that we are going to discuss at a later

 7     stage, but since the Trial Chamber has the map in front of themselves, I

 8     would like to discuss an area which is outside the territory of the

 9     Republic of Serbian Krajina which is called Velika Kladusa.  Can you

10     explain where this area was and in what way, if any, was it strategically

11     important for the territory of the Serbian Republic of Krajina?

12             JUDGE MOLOTO:  Mr. Lukic.  Mr. Lukic, you know, I know that

13     Mr. Harmon seldom stands up to object, but your questions are leading.

14     You are assuming -- you are telling us that Velika Kladusa was of

15     strategic importance.  We are not being told by the witness.  The way you

16     phrase your question is -- you are actually telling us that that area was

17     of strategic importance, and you are not testifying.  The person who is

18     testifying is the witness.  You can ask -- frame your question in such a

19     way that you don't tell him that that area was of strategic importance.

20             MR. LUKIC: [Interpretation] I honestly believe that I didn't make

21     any suggestions to the witness.  I asked him whether it was of any

22     strategic importance or not.  I can understand in a certain sense that I

23     may have suggested this to the witness, but I really don't believe --

24             JUDGE MOLOTO:  Okay.  Let's read how you have been interpreted:

25             "While we are still looking at the map, two more things.  There

Page 13083

 1     is something that we are going to discuss at a later stage, but since the

 2     Trial Chamber has the map in front of themselves, I would like to discuss

 3     an area which is outside the territory of the Republic of Serbian Krajina

 4     which is called Velika Kladusa.  Can you explain where this area was and

 5     in what way, if any, was it strategically important for the territory of

 6     the Serbian Republic of Krajina?"

 7             THE WITNESS: [Interpretation] Your Honours, if you allow me, I

 8     wouldn't believe Mr. Lukic if he were to tell me whether this was

 9     strategically important or not.

10             JUDGE MOLOTO:  That's not important.  That's not the point.  The

11     point is he mustn't suggest that to you.  He must ask you questions and

12     you must tell us, if you do know, whether the area was of strategic

13     importance to you; and if so, why.

14             MR. LUKIC: [Interpretation] There is perhaps a discrepancy

15     between the English interpretation of what I said, but as a schoolboy if

16     I put a question whether this was of strategic importance or not, I don't

17     think I can qualify that as a leading question because we are constantly

18     talking about the subject relating to organisation and the functioning of

19     an army.  If I put a question of what importance this is, we have to

20     focus on the strategy.  And if I ask if this was strategically important

21     or not, I don't believe that's a leading question.  At any rate --

22             JUDGE MOLOTO:  You don't believe that was a leading question.  I

23     tell you, it is a leading question, Mr. Lukic.  And if you can try to

24     avoid asking leading questions.  Thank you.

25             MR. LUKIC: [Interpretation] Can we go back to my first

Page 13084

 1     question --

 2             JUDGE MOLOTO:  Let him answer the question.  After all, you've

 3     asked the question anyway.

 4             MR. LUKIC: [Interpretation]

 5        Q.   General.

 6        A.   Mr. Lukic, as a first part of my answer to your question, I will

 7     tell you that in the geographical and military assessment made up in the

 8     former SFRY, a conclusion was reached that there were several strategic

 9     features that were crucial for the whole SFRY - and Mr. Perisic knows

10     well about that.

11             Secondly, the area between Zagreb and Sisak, which is here,

12     including Karlovac and Bihac, was considered to be held by someone to the

13     disadvantage -- to the advantage of them having access to the sea,

14     coastline, and other areas.

15             In our view -- in our view, in the Republic of Serb Krajina, this

16     particular area was exceptionally significant.  Our main interest was:

17     If we cannot have friends there, to avoid at least having enemies there.

18     We were anyway outnumbered in the ratio 8:1 in comparison to the Croatian

19     forces.  Now, if you add to that an enemy behind our backs with regard to

20     this front line facing the Croatian forces, then that would be a lost

21     cause in advance.  This danger was enhanced by the fact that in this area

22     there was a huge number of personnel.  There were many young men fit for

23     military service in that area, unlike our area which was demographically

24     very drained.

25        Q.   We're going to complicate the map too much.

Page 13085

 1             MR. LUKIC: [Interpretation] I don't know, Your Honours, if in

 2     this manner we are going to be able to enter this map into evidence.  Do

 3     I have to state anything else, or is it possible for you to follow the

 4     testimony by way of the transcript?  We are going to look at another map

 5     anyway.

 6             JUDGE MOLOTO:  We are in your hands, Mr. Lukic.

 7             MR. LUKIC: [Interpretation] I suggest that we enter the map as it

 8     is into evidence and then I will have another copy for more markings to

 9     be made.

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

11     please be given an exhibit number.

12             THE REGISTRAR:  Your Honours, this document shall be assigned

13     Exhibit D436.

14             JUDGE MOLOTO:  Thank you very much.

15             MR. LUKIC: [Interpretation]

16        Q.   General, did you want to say something about Korenica?

17        A.   In the Socialist Federal Republic of Yugoslavia, the municipality

18     of Korenica was the least populated one.  It had 18 inhabitants per

19     square kilometre.  This is just for the sake of comparison with the other

20     areas that we discussed on the Bosnian side of the border.

21        Q.   Under which name was this area also known in the map where we see

22     the name "Velika Kladusa"?  How was it called apart from that?

23        A.   The international community used to call it the Bihac pocket

24     because that was the Bihac protected area, and it was -- also used to be

25     called the autonomous province of Western Bosnia at the time when

Page 13086

 1     Mr. Fikret Abdic established such an entity in this area.

 2        Q.   Now we'll still have the map on the screens.  I'm going to ask

 3     you to make another marking.  You mentioned that a minute ago as

 4     something that had certain importance to -- for the Army of

 5     Republika Krajina.  You mentioned the Maslenica bridge.  Can you tell us

 6     what happened and what the consequences of that attack were as you

 7     mentioned.

 8        A.   In January of 1993, the Croatian forces launched a massive attack

 9     here in the area of the Maslenica strait and in the zone of Ravni Kotari

10     and in the valley of the Cetina towards Knin.  Those were the main axes

11     of their attack.  There was another attack against Mount Velebit.

12             Perhaps if we enter too many details into this map maybe we

13     should have a new one.

14        Q.   No problem.

15             MR. LUKIC: [Interpretation] I would like Your Honours to tender

16     the map as it is into evidence.

17             JUDGE MOLOTO:  The map is admitted into evidence.  May it please

18     be given an exhibit number.

19             THE REGISTRAR:  Your Honours, this document shall be assigned

20     Exhibit D437.  Thank you.

21             JUDGE MOLOTO:  Thank you.

22             MR. LUKIC: [Interpretatio.

23        Q.   General, perhaps you would be sorry to hear that I am reluctant

24     to discuss this conflict any further, but I just wanted to know what the

25     consequence of that attack was with respect to the protected areas

Page 13087

 1     according to the Vance Plan.

 2        A.   Yes, you now told me precisely what you want me to tell you.  So

 3     the Croatian forces attacked what for the United Nations was

 4     Sector South, i.e., an area under the UN protection.  In that area, in

 5     this particular point that was under the most threat --

 6        Q.   There's no need for that, General.  Let's not dwell on this for

 7     too long.  Can you just answer my question.

 8        A.   So a United Nations protected zone was attacked.  The UNPROFOR

 9     units deployed in that area did not respond in any way whatsoever.  They

10     simply vanished from the face of the earth.  And these units operated in

11     this area, as they did in any area where there were no UNPROFOR forces,

12     and as a consequence we lost this particular area and never managed to

13     re-capture it.  That was basically what happened.

14        Q.   What were the consequences with regard to this attack concerning

15     your obligations stemming from the Vance Plan?  Did you continue to

16     adhere to these obligations?

17        A.   On that morning, we had no other way but to take up arms from the

18     UNPROFOR depot and to defend themselves if UNPROFOR was not prepared to

19     do so.  The UNPROFOR units reacted in a variety of ways:  Some of them

20     disappeared as an element of the situation prevailing at the time; some

21     of them were in our way because the Croatian forces were operating from

22     their positions; and some UNPROFOR units did help us in an attempt to

23     pull out our heavy artillery to our positions as soon as possible.  I can

24     say that openly because I am grateful to those people that this was done

25     by --

Page 13088

 1             THE INTERPRETER:  Interpreters didn't hear the name of the

 2     battalion.

 3             JUDGE MOLOTO:  Sorry, the interpreters didn't hear the name of

 4     the battalion.

 5             MR. LUKIC: [Interpretation]

 6        Q.   Could you please repeat, General.

 7        A.   Nigerian Battalion.

 8        Q.   Did you, General, or some other representatives of the

 9     authorities of the Serbian Krajina have contacts with UNPROFOR and the

10     international community concerning this incident?

11        A.   We had very intensive contacts with representatives of the

12     international community.  I myself didn't have so many of those contacts

13     because I was on the front line.  However, representatives of the

14     government and people from the Main Staff in charge of liaising with the

15     international community did have such contacts.

16        Q.   First of all, how did that incident end?  Until when did combat

17     go on, if any?

18        A.   That incident was never fully brought to an end.  There was

19     intensive combat in January, February, March.  Later on, the intensity of

20     these operations subsided and an agreement was reached to the effect that

21     the Croatian forces should withdraw to their starting positions.  I can

22     say that one of the elements involved in this alleviation of the

23     situation was the presidential statement from the United Nations that

24     asked for the same thing.

25             The Croatian forces never fully withdrew from this area.

Page 13089

 1     According to that agreement, I think that our milicija was supposed to

 2     enter the area; however, they didn't.  For me the most important matter

 3     in all of this was the fact that the protection force of the UN was not

 4     protecting the territory or could not protect the territory.  I thought

 5     that they would do that not by way of weapons but by way of the authority

 6     of the United Nations.

 7             Perhaps my thinking was wrong at the time.  Perhaps my thinking

 8     is wrong to this day.  However, it seemed to me then - and I still think

 9     so to this day - that Croatia had actually attacked the UN.  If that was

10     a UN protected area and if that area was being protected by UN forces,

11     what is this superpower that can attack the United Nations?  My

12     understanding, my perception of the situation, was along those lines, and

13     that led me to very pessimistic conclusions in respect of our own

14     destiny.

15        Q.   Could you explain to us -- could you explain how these

16     pessimistic conclusions of yours were reflected.

17        A.   It seemed to me that foreign political conditions were created in

18     such a way because of the strong international support enjoyed by Croatia

19     at that moment, which was shown by the fact that there was no serious

20     condemnation of what they did on the one hand; and on the other hand,

21     there was the fact that we did not have that kind of international

22     support.  Therefore, the balance of power would shift considerably to our

23     detriment.

24        Q.   What was your forecast after March 1993 in terms of whether there

25     could be other attacks against the UNPA, attacks by Croatia, that is?

Page 13090

 1        A.   Our assessment was that that was possible.  Through our

 2     intelligence resources we tried to find out about that, namely, what was

 3     the next area that could be in danger, according to this principle of

 4     tacit crawling occupation.  The situation was as it was in the area, and

 5     we were isolated from other parts of the territory that was under our

 6     control within the UNPA.

 7        Q.   All right.  Now, what happened to that heavy weaponry that you

 8     took from the depots that had previously been with a double key; were

 9     they retained by your forces or not?

10        A.   Both options were there.  In this area that proved to be

11     particularly threatened, that is to say, Northern Dalmatia, Lika, Kordun,

12     and Banija, that weaponry remained in their respective firing positions.

13     We could not run the risk of being attacked by Croatian forces and then

14     trying to pull our weapons out of depots.  However, in the zone of the

15     18th Corps in Western Dalmatia and in the area of the eastern part of the

16     Republic of the Serb Krajina, that is to say, in the area of Baranja,

17     Western Srem, and Eastern Slavonia, these weapons and our artillery

18     pieces remained under the double-key principle.

19        Q.   What was the reaction of the representatives of UNPROFOR and the

20     international community in relation to these decisions of yours?

21        A.   None of them put that question to me anymore, at least not to me

22     personally, why these weapons of ours were at firing positions.  Part of

23     their reaction was that preparations would be underway for a cease-fire.

24     I think that that was their assessment, that that should be done next.

25        Q.   A few moments ago when we discussed the structure of the

Page 13091

 1     organisation of the Army of the Serb Republic of Krajina, you showed us

 2     what happened before the incident and what the situation was afterwards.

 3     In relation to what happened in the Maslenica strait, January 1993, what

 4     was the organisation and the structure of the Serb Army of the Krajina

 5     like then -- actually, I don't want to go into compound questions yet

 6     again.

 7        A.   The structure was identical or almost identical, as it was stated

 8     in the organisational order.  However, the artillery units in the

 9     18th Corps and in the 11th Corps in the eastern part were not fully

10     developed because their weaponry was in UNPROFOR depots.

11        Q.   Now I'd like to go back to the personnel levels, especially in

12     terms of officers, commissioned and non-commissioned.  In that period of

13     time and further on, can you tell us in your assessment what the

14     percentages of personnel levels were for officers in the Serb Republic of

15     the Krajina.

16        A.   The level was about 20 per cent.

17        Q.   In relation to that first period, the beginning of 1993, in the

18     forthcoming period, were there increases in the number of officers?  Let

19     me put a specific question:  Did officers of the Army of Yugoslavia come

20     to the Serb Army of the Krajina?

21        A.   Yes, officers from the Army of Yugoslavia did come to the Serb

22     Army of the Krajina.

23        Q.   Can you tell us, to the best of your recollection, whether there

24     were increases then and what was the level of manning and what was the

25     situation later -- actually, I'm referring to the personnel level in the

Page 13092

 1     ranks of the officers of this army.

 2        A.   Again you are --

 3             JUDGE MOLOTO:  Yes, Mr. Harmon.

 4             MR. HARMON:  Your Honour, perhaps we could have a very specific

 5     questions because there are about two questions or three questions

 6     embedded in this.  The first question is whether there were increases,

 7     what the level of manning was, what the situation was later, et cetera.

 8     So if we could have a precise question, it would make it clearer.

 9             JUDGE MOLOTO:  Mr. Lukic.

10             MR. LUKIC: [Interpretation]

11        Q.   General, you talked about the percentage of manning in terms of

12     the personnel levels in officers' ranks, 20 per cent.  I'm talking about

13     January 1993 onwards.  Was that number on the rise; and if so, until

14     when?

15        A.   That number rose over the following two months and then it went

16     down.  However, Mr. Lukic, if possible, let us not create any confusion

17     here.  When we're talking about officers, commissioned and

18     non-commissioned, of the Serb Army of the Krajina, it's save 5.000 men.

19     Now I don't know whether you are asking me about all of those officers

20     and NCOs of the Serb Army of the Krajina, or are you just asking me about

21     the officers of the former JNA?  These are two different things,

22     completely different.

23             Please, if you are asking me about officers and NCOs who are

24     reserve officers who were never members of the JNA but who were officers,

25     commissioned and non-commissioned, of the Serb Army of the Krajina, that

Page 13093

 1     is one thing.  I can respond as far as they are concerned.  Namely, that

 2     in January, February, and March, April, for as long as the intensive

 3     combat operations were on, that number was at maximum level.  However, at

 4     the moment when combat operations between our forces and the Croatian

 5     forces went down in intensity, the number went down as well.  These were

 6     people who had their own families, their own problems, and from time to

 7     time we had to let them go so that they could provide a living to their

 8     own families.

 9             As for commissioned and non-commissioned officers of the former

10     Yugoslav army who at that moment had the status of officers of the Army

11     of Yugoslavia as well, likewise their number went down once the intensity

12     of combat was reduced.  There wasn't a drastic reduction because

13     individuals from the Army of Yugoslavia agreed to come as if they were

14     tourists on a tour, purportedly waging war for two or three months and

15     then going back.  However, from mid-1993 that number was decreased in

16     absolute terms.

17             JUDGE MOLOTO:  Would that be a convenient point?

18             MR. LUKIC: [Interpretation] Yes, Your Honour.

19             JUDGE MOLOTO:  We'll take the break and come back at quarter to

20     11.00.  Court adjourned.

21                           --- Recess taken at 10.15 a.m.

22                           --- On resuming at 10.45 a.m.

23             JUDGE MOLOTO:  Mr. Lukic.

24             MR. LUKIC: [Interpretation]

25        Q.   General, before the break you gave an answer that relates to the

Page 13094

 1     arrival of officers from the Army of Yugoslavia to you, to the Army of

 2     the Serbian Krajina.  And in the English it was translated as "tourists

 3     on tour."  You mentioned the term in Serbian, so I don't need to quote it

 4     in Serbian.  In the following period, were there officers and

 5     non-commissioned officers of the JNA who came to the Army of the Serbian

 6     Krajina and became officers of the Army of the Serbian Krajina?

 7        A.   Yes, there were.

 8        Q.   And how long did they come for?  How long were the periods?  What

 9     was the situation with that?

10        A.   They would usually come for a period of a few months.

11        Q.   And is that what you said earlier, before the break, as them

12     coming for tourism, as you said on page 26, line 4?

13        A.   Yes, perhaps it was a little bit of a picturesque description,

14     but my intention was to say that they came there out of duty, not because

15     they were really motivated to come.

16        Q.   And were there those who came and then stayed until the end of

17     the war or for a longer period of time in the Army of the

18     Serbian Krajina?

19        A.   Yes, there were such cases too.  Some of them were killed in

20     1995.

21        Q.   And what was the position of the members of the Army of the

22     Serbian Krajina, the soldiers and the officers, towards those who would

23     come for brief periods -- towards those who didn't want to stay there for

24     longer?

25        A.   The position was generally not favourable.  It was a position of

Page 13095

 1     rejection.  They were not appreciated, because the people who were at the

 2     front from the beginning believed -- thought that their position in terms

 3     of the defence of the people was insincere, it wasn't genuine.

 4             As far as we were concerned, us in the commands of the Army of

 5     the Serbian Krajina, we also had problems because of the -- these people

 6     who came.  These were usually people of higher rank who mostly sat around

 7     in the command, and there was not much use to be had from them.  And

 8     that's why the commands and the staffs as well lost authority among the

 9     fighters.

10        Q.   You mentioned earlier the command cadre at the level of the

11     battalion.  What was the command cadre at the higher level, the command,

12     the corps, in terms of their origin; were they former non-commissioned

13     officers or reserve officers or were they active JNA officers?

14        A.   At the higher levels of command - brigade, corps level, and the

15     Main Staff level - the cadres were trained JNA officers even though there

16     were some brigade commanders who were reserve officers who were never JNA

17     active officers or active officers of the Yugoslav Army.

18        Q.   I'm going to put a number of questions to you now about the

19     financial situation of the Army of the Serbian Krajina for the period

20     from early 1993 until the arrival of General Perisic as Chief of Staff.

21     In terms of the planned organisation of the Army of the Serbian Krajina,

22     what was the situation with weapons in that period, in the period of

23     1993?  And I am thinking about all types of weapons.

24        A.   As far as light infantry weapons are concerned, there was enough

25     of such weaponry.  However, a large number of such weapons had already

Page 13096

 1     expended their combat resources.  That means that a barrel of a rifle is

 2     designed to fire a certain number of projectiles.  After firing that

 3     number of projectiles, the fighter on the front is no longer able to hit

 4     his target.

 5             As for artillery weapons for support and anti-armour weaponry

 6     that are at the level of the battalion and the brigade, there were

 7     sufficient such weapons but not enough to provide artillery fire-power to

 8     cover the entire front line.  And because that line of the front was very

 9     long and the weapons when they're placed at the firing positions have a

10     specific area of fire and they can be moved within that area to the left

11     and right but because of their range they need to be close to the

12     front -- so without going into any more detail, let me just say that the

13     number of the artillery batteries for support was insufficient to be able

14     to provide fire support for all the sections of the front.

15             As far as artillery support -- missile and rocket weaponry for

16     support is concerned, there were plenty of these weapons because these

17     weapons can quickly change their positions.

18             As for armoured combat vehicles, it was our estimate that we did

19     have a sufficient number of them, but they also had expended their combat

20     resources and were already in the stage that because they had already

21     fired a specific number of projectiles and the engine had been working

22     for a specific number of hours they needed maintenance.  And so because

23     of all these things, as we saw before, I would always ask - and we never

24     had enough of those, and these were actually the transport vehicles --

25     modern warfare had indicated that armoured units, in case of need, would

Page 13097

 1     have to be transferred 200, 300 kilometres further along; and for that we

 2     needed vehicles in order to be able to move the weaponry.  So we were not

 3     able to do this because there was a shortage of these vehicles.

 4             As for anti-aircraft fire, we lacked artillery and rocket systems

 5     in a sufficient number to be able to defend the skies above our

 6     territory.

 7             As for planes --

 8        Q.   Are you talking about the PVO system?  When you're saying "in

 9     order to defend our skies," are you thinking about the PVO systems?

10        A.   Yes, these are the PVO systems, anti-aircraft defence systems,

11     yes.

12             As for planes, their number was also reduced to just a few

13     fighter bombers.  And planes that would be able to deal with other

14     fighter planes attacking our territory, we didn't actually have any of

15     those planes.  This is a brief description of the situation.

16        Q.   Thank you.  Just one more question:  All these items that you

17     said that you had, how did you acquire them?  Was that something that you

18     already had?  Was it given to you from -- by somebody?  Did you procure

19     them?

20             MR. HARMON:  Your Honour, I'm going to object.  The question that

21     was asked is:  How did you acquire them?  That is sufficient.  Mr. Lukic

22     is now suggesting a number of possibilities, and I think it's up to the

23     witness to answer the first question.

24             JUDGE MOLOTO:  Mr. Lukic.

25             MR. LUKIC: [Interpretation] I accept the objection.  I'm going to

Page 13098

 1     rephrase my question if I did create a problem.

 2        Q.   So how did the Army of the Serbian Krajina obtain all of these

 3     weapons?  How did it come to have them?

 4        A.   In response to this question, I can state only what is true.  And

 5     the truth is that this was weaponry that had remained after or behind the

 6     Yugoslav People's Army.

 7        Q.   And what was the situation with ammunition in that period, in the

 8     course of 1993?

 9        A.   Ammunition expenditure was enormous, and this was so on all

10     sides.  In war we always had a problem with ammunition.  The least

11     problem was rifle ammunition, and this is where we could count on the

12     help of the Army of Yugoslavia.  But as far as artillery ammunition, tank

13     projectiles, rockets were concerned, that was always a major problem, and

14     we never had enough of such ammunition.  In answering this question, I

15     also have to say that the Republic of the Serbian Krajina did not have

16     its own facilities for the production of ammunition.

17        Q.   And what was the situation in the beginning?  I would like to

18     know.  And later?  Perhaps I didn't get a precise answer about that

19     regarding ammunition.  Was there enough ammunition from the beginning, or

20     was this shortage something that occurred right from the start?

21        A.   In the beginning, there was enough ammunition.  But during

22     intense combat, during the Croatian offensive around the Maslenica inlet

23     and the Ravni Kotari and the Cetina River valley and Mount Velebit,

24     ammunition was spent very intensively, and then we were in a situation

25     when we had insufficient amounts of the types of ammunition that I had

Page 13099

 1     spoken about before.

 2        Q.   Did the Serbian army of the Krajina have an established system of

 3     communications?

 4        A.   Yes.

 5        Q.   Can you please tell us how this was set up, based on what?

 6        A.   The communications system of the Army of the Serbian Krajina was

 7     set up using means of communication, the communication facilities which

 8     had remained behind after the Yugoslav People's Army.  Operators of those

 9     communications devices were members of the Army of the Serbian Krajina,

10     i.e., there was a small number of professional officers from the

11     Yugoslav People's Army and later the Army of Yugoslavia; and the majority

12     of others were from the reserve force who were trained in their capacity

13     as non-commissioned officers, officers, and reserve officers in the JNA

14     to use these communications devices.

15        Q.   Can you please tell us, In an army, what should this signals or

16     communications system be like?

17        A.   All military documents state that the communications system

18     should be such as to satisfy the requirements of command.

19        Q.   And did this system of communications satisfy the requirements of

20     command that you were using on the basis of this infrastructure?

21        A.   This system of communications in essence did make command

22     activities possible.  However, it was not at the level required.  And if

23     you would like me to, I can explain why it wasn't.

24        Q.   Yes, please, go ahead.

25        A.   Pursuant to the principles of the tactics of the signals or

Page 13100

 1     communication service, it has to be such a system as to meet the

 2     requirements of command.  The first one is that it should be

 3     uninterrupted.  The system of communications should be such that in the

 4     event of enemy action when one source of communication is cut off, one

 5     type of communication is interrupted, another kind of communication is

 6     activated.  And the communications for command and other types of

 7     communication continue to work without interruption.

 8             Because of a limited number of resources that we had, this

 9     principle could not be secured.  And later this became evident in combat.

10     Then there has to be a sufficient number of protected channels of

11     communication.  We found a small number of encryption communication

12     devices in order to be able to have secure communications only for some

13     basic communications channels that were covering the command.  Then the

14     system has to be such that it is protected from radio surveillance, what

15     in these documents is being treated as an intercepted conversation.

16     Because of a small number of communication devices for such type of

17     communication, we were unable to have this facility at the required

18     level.

19             So these would be the main things.  I don't need to go into this

20     any further.

21        Q.   In the period when you were a commander and later, are you aware

22     if the Army of the Serbian Krajina kept perfecting this system that it

23     had available from the beginning?

24        A.   I told you that I -- that we were relying on existing devices and

25     facilities that were previously used by the Yugoslav People's Army in

Page 13101

 1     that area.  However, our requirements and the deployment of our units and

 2     our commands was quite different from that one of the Yugoslav People's

 3     Army in that area.  The command before the war, the command of the

 4     north-western theatre of operations that commanded the bulk of the forces

 5     in Croatia, Slovenia, and a part of Bosnia, was located in Zagreb.  Of

 6     course, all those communications lines were then directed at that area

 7     and also connected to the General Staff that was located in Belgrade.

 8             So, now, what did we have to do?  These communications facilities

 9     with those devices for the operative levels of communication were

10     something that we now took; let's say there was a facility in Petrova

11     Gora and there were many other radio nodes.  For example, there were

12     25 devices, 15 directed towards Belgrade, 15 directed towards Zagreb.  We

13     would then have to connect those devices to antennas that were facing our

14     corps commands, let's say 95 per cent of them.  And then 5 per cent of

15     those devices or even less would still be turned towards the areas

16     controlled by the Army of Republika Srpska and which could then, if

17     needed, be used and directed for communications with Belgrade.

18        Q.   Could the system function independently?

19        A.   It did function completely independently for our purposes, for

20     communications in our area, that is to say, with the eastern part, the

21     11th Corps in Slavonia, Baranja, and Srem, and then you had to actually

22     go through the territory of Republika Srpska, or rather, the Federal

23     Republic of Yugoslavia.  As a matter of fact, I think that you didn't

24     have to go through the territory of the Federal Republic of Yugoslavia.

25     From Mount Majevica --

Page 13102

 1             JUDGE MOLOTO:  Slow down, slow down.  The interpreter is

 2     struggling to keep pace.

 3             THE WITNESS: [Interpretation] I apologise, Your Honours.  I seem

 4     to be carried away.

 5             JUDGE MOLOTO:  That's fine.

 6             MR. LUKIC: [Interpretation]

 7        Q.   Yes, please continue.

 8        A.   This is a technical detail.  I cannot say right now whether our

 9     communications channel vis-à-vis the 11th Corps went from Mount Majevica.

10     I think it was that way according to the schematic in Eastern Bosnia and

11     Semberija straight towards our 11th Corps.  Technically that would have

12     been fine.  Or it went via Mount Avala, the node near Belgrade.  I think

13     it was the first variant, but I'm not sure.

14        Q.   No problem whatsoever.  General, after you became commander of

15     the Serb Republic of the Krajina, did you establish contact with the

16     commanders of some other armies?

17        A.   Yes, yes.  But not with all immediately.  I established contact

18     with the Chief of Staff of the Army of Yugoslavia General Panic.  I did

19     not see General Mladic - I know that very well - up until the summer or

20     spring, spring or the beginning of the summer of 1993.

21        Q.   Can you give us a general picture as to how often you saw

22     General Panic while he was Chief of General Staff?

23        A.   It was perhaps once or twice during 1992, then -- actually, up

24     until mid-January 1993 when the Croatian offensive started in

25     Northern Dalmatia.  Then I did not see him for at least two months.

Page 13103

 1     After that, while he still held that position, it was at least once or

 2     twice a month.

 3        Q.   Briefly, what was the objective of these meetings with

 4     General Panic?

 5        A.   First of all, I wished to inform the then-Chief of General Staff

 6     of the Army of Yugoslavia directly about the elements involved in our

 7     assessment of the situation in our area.  Secondly, it was my effort to

 8     resolve the basic problems I had in the army.  The way we understood

 9     things, the main problems were of a materiel nature and personnel nature.

10        Q.   In simple words, did you ask him for some help?

11        A.   Yes, I did ask for help.  First of all, I asked for assistance in

12     terms of officers.  I saw that the level of training of the reserve

13     commissioned and non-commissioned officers was insufficient if you look

14     at the requirements of modern technology and equipment.  Through my

15     officers in the Krajina who were in the General Staff of the Army of

16     Yugoslavia at the time, I received a computer list with the names and

17     surnames of -- age included, type of professional training of officers

18     and NCOs, and the garrisons where they were serving in the Army of

19     Yugoslavia.  It was about 6.000 names all together.

20        Q.   Just a moment, please.  You said that your officers gave it to

21     you.  They were originally from Krajina, right, these 6.000 that you

22     referred to?  Are they all officers of the Army of Yugoslavia or are they

23     your group?

24        A.   No, no, they were natives of the Krajina, but they were officers

25     of the Army of Yugoslavia at the time.

Page 13104

 1        Q.   That's what I was asking about in more specific terms.  So

 2     originally they came from where?

 3        A.   In terms of their place of birth, they came from the Krajina;

 4     however, at that moment they were serving in different garrisons in the

 5     Army of Yugoslavia.

 6        Q.   Thank you.  Can you please go on.  What did you do with this

 7     computer list once you received it?

 8        A.   Together with my associates, I compiled a list -- we compiled a

 9     list, trying primarily to get people who would change the quality of our

10     units, that is to say, people for command positions; say platoon

11     commanders, company commanders, battalion commanders, even brigade

12     commanders, even corps commanders.  That was a very specific list,

13     including specific names.  I took that list and went to see

14     General Panic.

15        Q.   And what happened at General Panic's in relation to that list?

16        A.   General Panic said that if he were to give me these 750 men in

17     total that I had asked for that he might as well disband the Army of

18     Yugoslavia.  That was his interpretation.  The explanation was that these

19     people headed the best-trained units that the Army of Yugoslavia had.

20     However, I was not satisfied with that answer of his.

21        Q.   Let us look at a document first.  Prosecution Exhibit P1132.

22             MR. LUKIC: [Interpretation] Could we have that on the screen,

23     please.

24        Q.   I think that it is in the context of what you're testifying about

25     now.  This is a document that you signed; isn't that right, General?

Page 13105

 1        A.   Yes.

 2        Q.   The date is the 20th of June, 1993.  Who was Chief of

 3     General Staff of the Army of Yugoslavia at the time?

 4        A.   General Panic.

 5        Q.   Please have a look at the document, and I would just like to ask

 6     you for a brief comment in relation to that document.

 7        A.   I told you that I had asked for 750 officers for command

 8     positions, at that.  Now, you can see here that it says that what had

 9     been agreed upon was to send 300 officers and non-commissioned officers.

10     I don't know -- if necessary, I can explain how that happened that I

11     asked for 750 and that ultimately it was decided it would be 300.

12        Q.   Please go ahead.

13        A.   After I was dissatisfied with General Panic's answer when he said

14     that he might as well disband the army if he were to give me these

15     750 commissioned and non-commissioned officers, I went to see

16     President Milosevic with the very same request.  He organised a meeting

17     then between General Panic and myself in his presence.  Now, that looked

18     like bargaining to me.  I presented my arguments; General Panic presented

19     his arguments why he could not give me this personnel; I saw that I did

20     not really have much support from Mr. Milosevic; and then the agreement

21     was that it would be 300 commissioned and non-commissioned officers,

22     however, those that were essential to me for the quality of command and

23     control.

24             You see here, on the 20th of June I state on the basis of reports

25     and records in the Main Staff of the Serb Army of the Krajina that

Page 13106

 1     instead of the 750 agreed upon, it was -- or rather, 300 officers agreed

 2     upon, only 78 had arrived ultimately.  I got officers, commissioned and

 3     non-commissioned, who belonged to the navy and technical services.  We

 4     had no navy at the time.  I got an expert for computers, and thereby I

 5     was in a position to establish a computer centre that would have been at

 6     European level.  I got a pharmacist and I did not have a pharmaceutical

 7     industry at all; we don't have one in the territory of the Serb Krajina.

 8     I also got a few commissioned and non-commissioned officers from the air

 9     force and its technical service, and I didn't really need them either.

10     Now, that is the reason why I am going back to what I had asked for in

11     the previous period.

12        Q.   General, a question that stems from your answer, and I believe

13     that the others in court will be interested in that:  Why did you address

14     President Milosevic after that first conversation with Panic?

15        A.   Well, because it was generally known that he was the main

16     political authority in Serbia and in the Federal Republic of Yugoslavia.

17     If he could not resolve that, then there was no one who could have

18     resolved it.

19        Q.   Very well.  Let us now look at another document, and we'll

20     discuss these personnel issues later as well.  However, I would like to

21     deal with the general subject now.

22             MR. LUKIC: [Interpretation] P1617, could we have that on our

23     screens now, please.

24        Q.   This is a document of the General Staff of the Army of Yugoslavia

25     from February 1993.  Again, I'm going to ask you who the Chief of

Page 13107

 1     General Staff of the Army of Yugoslavia was at the time, although I

 2     believe that the question is superfluous now.

 3        A.   All right.  General Panic.

 4        Q.   General, what do you know in relation to this document?  As we

 5     can see, it was sent to you as well, that is to say, to your Main Staff.

 6        A.   You see that this document is being sent by the operations centre

 7     of the General Staff of the Army of Yugoslavia.  That means that that is

 8     the kind of organisational unit that any army has.  It follows the

 9     situation on a daily basis, both on the territory of its own state and

10     the territory in the surrounding area and even beyond that.  As regards

11     armed forces and their activities that are of interest for that

12     particular army.

13             In this particular case, information is requested about the most

14     important activities in the areas engulfed by war.  This is the area that

15     this administration believes it should follow and record on a daily basis

16     what was going on there; they should record it in their own operations

17     centre.  You see, that's what they say here themselves:  To facilitate

18     timely and more complete information, the assessment of and the

19     monitoring of -- it is the paragraph above item number 1.  They say

20     please.  In military terms, there is a clear distinction.  They are

21     asking us to inform them, not to report to them.  They cannot issue an

22     order like that to us.  If you look at the activities that followed after

23     this document, that would probably be of interest, then you would see how

24     things developed in relation to this request of theirs.  I think that

25     this is a normal, professional attempt to follow the situation in the

Page 13108

 1     surrounding area.

 2        Q.   This information that is being requested specifically from

 3     numbers 1 through 4, why do you think that they are important for the

 4     General Staff of the Army of Yugoslavia?  Why do they need to know about

 5     this?

 6        A.   Because these are elements that are the basic elements of the

 7     situation as it is.  You can see that here.  You can see here the

 8     composition, deployment, and strength of the enemy and probably the

 9     directions in which their activity could take place and also on our side

10     what it is that we intend to do and whether there is anything else.

11     Basically, they want to have insight into the situation in the war zone.

12     What was selected here was selected for that reason, because these are

13     elements that are essential for assessing the situation.

14        Q.   And why was it important for them to have this insight?

15        A.   It is important because the operations centre must monitor the

16     situation in the surrounding areas.  For the requirements of command of

17     the VJ, there is no such centre that can afford to be such a laid-back

18     institution and fail to follow the situation.  There is no such centre in

19     the world.

20        Q.   Thank you.  Do you remember back in February 1993 and this

21     request, did you provide them with this information that they asked for?

22        A.   I believe that for a certain period of time we did provide this

23     information; however, the Main Staff was extremely understaffed and the

24     existing members of the Main Staff worked around the clock.  Quite

25     simply, we were unable and we didn't have the capacity to do whatever was

Page 13109

 1     not a top priority in the operation of the Main Staff.

 2        Q.   Thank you.  A while ago when you asked about the purpose of your

 3     meeting with General Panic, you highlighted two problems: personnel and

 4     financial resources.  We talked about the personnel.  Let's move now to

 5     this second topic.  Did you ask General Panic for resources to replenish

 6     the Serbian Army of Krajina, and what was the situation in that sphere?

 7        A.   In that period, our main concern was ammunition.  And I know that

 8     I asked General Panic to try and solve at least some of our problems.  I

 9     believe that we did receive a certain amount of ammunition from

10     General Panic at that point.

11        Q.   Thank you.

12             MR. LUKIC: [Interpretation] Can we please have 65 ter document of

13     the Defence 01006-D.

14        Q.   General, can you please look at this document.  And it says here

15     that it was drafted by you.  Can you please comment on it.

16        A.   This is an order of the Main Staff of the Serbian Army of Krajina

17     issued to the command of the 18th and 11th Corps of the Army of the

18     Republic of Serbian Krajina asking them or requesting them to participate

19     in carrying out certain obligations with regard to making a solemn

20     pledge.  That was a procedure that had been applied previously by the

21     JNA.  However, in the Serbian Army of Krajina we now had a different

22     wording of the pledge to be given by the troops from the one that had

23     been in use by the Yugoslav Army at the time.  According to the protocol

24     for such occasions that we ourselves set up at the Main Staff of Krajina,

25     this ceremony was participated by a priest as well, and the wording ended

Page 13110

 1     with the phrase "so help me God."

 2             Therefore, it was a different phrasing that was used by the VJ,

 3     and the protocol itself was different.  That is why the corps command

 4     were obligated in this respect to make sure that these recruits make this

 5     solemn pledge.

 6        Q.   Just a moment, please.  When you say that these recruits were

 7     there, for the benefit of the Trial Chamber, it says "Subotica."  It says

 8     on the occasion of taking a solemn oath in Subotica.  We are talking

 9     about April 1993 and the personnel of the RSK.  So first tell me where

10     Subotica is, and why is it written in this way in this document?

11        A.   Subotica was a VJ garrison situated in the far north of Serbia,

12     close to the Hungarian border.  This is where at the time an armoured

13     brigade of the VJ was deployed.  According to an agreement with the

14     General Staff of the VJ, we sent recruits for training to the Subotica

15     garrisons for such military specialties for which we in the Republic of

16     Serbian Krajina did not have conditions to provide training for.  As far

17     as I can remember, those were such duties that were carried out by tank

18     crews or by anti-armour launch-rocket weapon operators.

19        Q.   Why was it important for you that those recruits take this solemn

20     pledge there according to the rules of the Serbian Army of Krajina?

21        A.   Well, Mr. Lukic, I find this question a little bit odd.  Whose

22     else solemn pledge would they take other than the one that was in force

23     in the Serbian Army of the Krajina?

24        Q.   I am satisfied with your answer, although you're not happy with

25     my question.

Page 13111

 1             MR. LUKIC: [Interpretation] Your Honours, can we have a number

 2     for this document.

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

 4     please be given an exhibit number.

 5             THE REGISTRAR:  Your Honours, this document shall be assigned

 6     Exhibit D438.  Thank you.

 7             JUDGE MOLOTO:  Thank you.

 8             Yes, Mr. Lukic.

 9             MR. LUKIC: [Interpretation] On this same subject, can we have a

10     Prosecution exhibit, P940, please.

11        Q.   This is now February 1994.  You are still the commander of the

12     Serbian Army of Krajina.  Can you briefly comment on this document,

13     General.

14        A.   This is again to do with making a solemn oath by the recruits in

15     the Army of Yugoslavia.  However, here we are informing the General Staff

16     and the office of the Chief of the General Staff of VJ that for this

17     ceremony of giving a solemn pledge we were going to drive these recruits

18     and soldiers to the territory of the Serbian Republic of Krajina to the

19     village of Vojnic in Kordun and that that would be the place where they

20     would take their solemn oath.  Therefore, there was no question raised

21     again about whether co-operation was going to be good, whether somebody

22     else should be helping us with this.  We took full responsibility for

23     this ceremony of giving a solemn pledge, of course with allowing for a

24     possibility, as the tradition goes, for this ceremony to be attended by

25     family members and friends as well as the tradition in the former

Page 13112

 1     Yugoslav People's Army.  Because this kind of ceremony had always been a

 2     solemn one and always attended by family members.

 3             MR. LUKIC: [Interpretation] Can I have a moment, please.

 4                           [Defence counsel confer]

 5             MR. LUKIC: [Interpretation] I have an intervention in the

 6     transcript.  Probably there is some misunderstanding.

 7        Q.   It reads here that you stated that this again refers to giving a

 8     solemn oath by the recruits in the Yugoslav Army.  I suppose that's not

 9     what you said, so can you please be more specific.  Whose recruits are we

10     talking about here?

11        A.   If necessary, we can read the document.  But it is obvious that

12     this refers to the recruits of the Serbian Army of Krajina who at this

13     juncture when this order was being written --

14        Q.   It's clear now.  That was all we wanted to clarify.  General, one

15     question relating to this topic and the stay of these recruits from the

16     Republic of Serbian Krajina in the Army of Yugoslavia and their training

17     there.  What kind of information did you receive as a feedback regarding

18     their relationship with members of the VJ [sic] and officers of the VJ at

19     the time?

20        A.   The information we received indicated that there were problems in

21     that area.  There were conflicts between the trainees and the VJ officers

22     who were instructors.  To put it simply, they did not want to recognise

23     them as their own officers.  They did not wear the same insignia on their

24     caps.  They did not believe to be, themselves, part of one and the same

25     army, and therefore they could not be commanded by members of another

Page 13113

 1     army.

 2        Q.   Thank you.

 3             JUDGE MOLOTO:  Sorry, Mr. Lukic.  I guess you might need an

 4     intervention again here at page 44, line 23:  "... relationship with

 5     members of the VJ and ..." -- "... members of the SVK and officers of

 6     the VJ ..."  I think is what you wanted to say.  Can you see it?

 7             MR. LUKIC: [Interpretation] Well, I expanded my question and I

 8     put my question --

 9             JUDGE MOLOTO:  That's the answer -- look at line 23.  It says

10     "members of the VJ and officers of the VJ at the time."  Is it not

11     supposed to be members of the SVK and officers of the VJ?

12             MR. LUKIC: [Interpretation] Yes, yes, that's right.  You're

13     absolutely right.  So on page 44, line 23, I asked about the relationship

14     between the recruits from the Serbian Army of Krajina who were undergoing

15     training there, and I thank Your Honour for this.

16             JUDGE MOLOTO:  You're welcome.

17             MR. LUKIC: [Interpretation]

18        Q.   General, let's move to another topic now.  I'm interested now in

19     your contacts with General Perisic starting from August 1993.  We have

20     information that General Perisic was appointed to the position of the

21     Chief of General Staff of the VJ.  Can you remember when you first met

22     him in your capacity, and can you recall anything about this meeting?

23        A.   Of course I cannot give you the exact date, but I do know that it

24     might have taken place some ten days after he had been appointed to that

25     post.  I wanted to meet Mr. Perisic because from our previous meetings I

Page 13114

 1     got the impression that he was a smart man and a capable officer and my

 2     expectations were that he would demonstrate at least some professional

 3     understanding of the situation in which the army of which I was the

 4     commander found itself.

 5             During this first meeting that we had, I informed him about the

 6     basic elements pertaining to the situation.  This was done more or less

 7     on the principle of the document that was shown here in which the

 8     operations centre of the General Staff asked information from us about

 9     four subjects or items.  So those were basically these elements of the

10     situation relating to the enemy and what was known about the situation

11     relating to our forces about what we thought we could and should do in

12     the forthcoming period and about the influence of the external factors

13     involved in the situation, starting from UNPROFOR to those at the

14     political and diplomatic levels.

15        Q.   And did you speak about the topics that you discussed with

16     General Panic -- if not then, when was the first time that you discussed

17     those topics?  This is your cadre problem and the problem of the

18     financial situation with the army.

19        A.   We talked about that as well, of course, because that was part of

20     that item 2 that was on the document, own forces.  If you want, I can

21     tell you what I told General Perisic about the situation of our own

22     forces, the forces of the Army of the Serbian Krajina.  I began by

23     describing its strategic position, operations position at certain sectors

24     of the front, combat morale, and the situation with materiel and

25     equipment, logistics, including also the medical aspect of it.  I did

Page 13115

 1     this to the extent that I believed necessary at the level of the Chief of

 2     the General Staff, which was the position of General Perisic at the time.

 3        Q.   And on that occasion or later, did you ask him for assistance?

 4     I'm primarily thinking about materiel, equipment, and so on.  What was

 5     his position about that?

 6        A.   Of course.  Just as was the case with General Panic before him, I

 7     asked for material assistance from him, personnel, and also in certain

 8     kinds of materiel and equipment.  I felt that General Perisic understood

 9     the situation in terms of these being realistic requirements.

10     Unfortunately, however, I did not encounter - and I can begin like that

11     and I can end in the same way as well - his actual ability to resolve

12     these problems, either the materiel and equipment or the personnel

13     matters.

14        Q.   Do you remember what he specifically told you about the request

15     for funds or material assistance?

16        A.   Since we knew each other from before, at one point he opened his

17     cash box, his safe, that was in his office, and it was full of -- it was

18     full of secrets, just like the ones that we're looking at now.  And he

19     said, Here, take a look for yourself.  And the things that

20     General Perisic showed me then, it was enough to make a grown man cry - I

21     mean we could put it like that in Serbian.  That Army of Yugoslavia and

22     in relation to the things that I needed the most, ammunition was in a

23     very, very sorry state indeed.

24             If you have a tank, for example, and the -- a tank -- each tank

25     has to have 50 projectiles, 50 shells.  This is part of the combat kit.

Page 13116

 1     It's a requirement.  And then you have three times as much in a brigade

 2     and then seven times as much up to the level of the Supreme Command.

 3     This means that a regular army would require 4- or 500 projectiles per

 4     tank.  And what the Army of Yugoslavia had at the time was just enough to

 5     supply the requirements of -- at the level of a unit.  This was from 100

 6     to 150 projectiles [as interpreted].

 7             If we're talking about rockets; for example, each launcher should

 8     have six rockets.  I remember that the best for anti-armour rockets.  I

 9     can still see that number now.  A combat kit is six rockets.  At that

10     point in time, he had 0.3 of that combat kit.  That means less than two

11     rockets per projectile.

12             THE INTERPRETER:  Interpreter's correction:  Before, it was

13     supposed to be "from 150 to 180 projectiles."

14             MR. LUKIC: [Interpretation]

15        Q.   All right.  What you have just said now -- I apologise to the

16     interpreters.

17             What was your conclusion, General, from this information that you

18     were able to find out, read, at that time?

19        A.   It was possible to draw a number of conclusions; the main one

20     being that the Army of Yugoslavia really without endangering the basic

21     purpose for its existence could not provide us with ammunition.

22        Q.   Just one more question and then we'll go on a break.  We don't

23     have to discuss this very first meeting, this specific meeting.  But on

24     the basis of your meetings with General Perisic, what was the conclusion

25     you drew -- actually, we heard yesterday that the Yugoslav People's Army

Page 13117

 1     took an active part in the combat; you said that yesterday.  What was his

 2     position in relation to any kind of active participation of the

 3     Yugoslav Army in the war?

 4        A.   We absolutely did not discuss that during that conversation.

 5        Q.   What about subsequent conversation; did you get the impression

 6     that he had some sort of position in relation to that matter?

 7        A.   From what he said, you could draw the conclusion -- I mean, you

 8     could draw the conclusion - I don't think he could have said it openly at

 9     the time - the Army of Yugoslavia did not have the basic prerequisites

10     for waging war.  And this did not apply only to the materiel situation

11     either.

12        Q.   Thank you.

13             MR. LUKIC: [Interpretation] Your Honours, I suggest that we go on

14     our second break for today.

15             JUDGE MOLOTO:  We will take a break and come back at half past

16     12.00.  Court adjourned.

17                           --- Recess taken at 12.00 p.m.

18                           --- On resuming at 12.31 p.m.

19             JUDGE MOLOTO:  Yes, Mr. Lukic.

20             MR. LUKIC: [Interpretation]

21        Q.   General, can you tell us whether in the autumn of 1993 there were

22     some new incidents in the territory of the Republic of the Serb Krajina;

23     and if so, where and what happened?

24        A.   Yes.  In the beginning of September 1993, the Croatian forces

25     attacked a zone in Lika, which was later known as the Medak pocket.

Page 13118

 1        Q.   Let's be practical.  While you continue speaking, let us have

 2     D164 on the screen, that's a map, so that we have it there while you're

 3     speaking.

 4        A.   That is an area that is between the very high mountain of Velebit

 5     and the town of Gospic, which was under Croatian control.  That area, I

 6     mean the part of the area that was under our control, was in the shape of

 7     a triangle vis-à-vis the area that was held by Croatian forces, and it

 8     was below a part of Mount Velebit that was held by the Croatian forces.

 9     Visocica is the elevation there where, according to our information,

10     there was the staff or headquarters of the special Croatian police.  If

11     necessary, I can indicate that.

12        Q.   Yes, please.

13             MR. LUKIC: [Interpretation] Could the General actually mark that,

14     could he mark that area on the map.

15             THE WITNESS: [Marks]

16             MR. LUKIC: [Interpretation]

17        Q.   Could you please go on.

18        A.   The Croatian forces started grouping their forces for this attack

19     a few days in advance.  There was a strong unit of the Croatian special

20     police that our intelligence people discovered as they were moving from

21     their headquarters in Zagreb, and we knew that this group was headed

22     towards the area of Lika.  However, we did not know specifically which

23     part of the front they were heading to.

24             Also, they discovered some unusual activity on their part on

25     Mount Velebit --

Page 13119

 1             MR. HARMON:  Excuse me, Your Honour.

 2             JUDGE MOLOTO:  Yes, Mr. Harmon.

 3             MR. HARMON:  The question that was asked is essentially to tell

 4     us what happened, and we are going into extraordinary detail that I think

 5     is unnecessary for purposes of the question that was asked by Mr. Lukic.

 6     So I would ask the Court to instruct the witness to answer the question

 7     that he was asked.

 8             JUDGE MOLOTO:  Mr. Lukic.

 9             MR. LUKIC: [Interpretation] I will accept the objection,

10     Your Honour.

11        Q.   Because, General, we have a great many topics that we have to

12     discuss that are quite important for this trial, I believe that you would

13     like to tell us a lot about this action and you could indeed, however, I

14     would like you to focus and to be as specific as possible.  In your view,

15     what was the objective of this operation?  Please give us the briefest

16     possible answer, and let's move on to other topics.

17        A.   It's quite clear.  It's unequivocal.  And I can give further

18     explanation if necessary, but I don't really think it's needed.  The only

19     objective of this Croatian operation was to demonstrate to us, Serbs, the

20     method of scorched earth.

21        Q.   Are you trying -- could you please tell us what "scorched earth"

22     means?

23        A.   On the basis of this exemplary example, as it were, this

24     exemplary case, the scorched earth method means kill all living

25     creatures, persons and animals included, in a given area and destroy

Page 13120

 1     everything that was created by human hands.

 2        Q.   Who did you hear this term from, scorched earth?

 3        A.   I heard this term several times earlier on in different -- on

 4     different occasions, but in this particular case I heard this term from

 5     General Jean Cot, UNPROFOR commander.  He's the one who used the term.

 6        Q.   On which occasion did he use that term?

 7        A.   When he first met me, after he personally toured the area.

 8     General Cot was an officer who wanted to see this personally and indeed

 9     he did so.

10        Q.   What was it that he conveyed to you then, which information did

11     he come across on that occasion?

12        A.   Let me try to be as brief as possible again.  General Cot stated

13     in the briefest possible terms that he was totally astounded by what he

14     had seen.

15        Q.   In view of the position that you had then as the commander of the

16     Army of the Serb Krajina, did you see General Cot again, and did you see

17     any representatives of the international community in relation to this

18     incident?

19        A.   Yes.  I saw General Cot several times in relation to this

20     incident.  As far as I can remember, General Bo Pellnas was always with

21     him.

22             MR. LUKIC: [Interpretation] I see now that what the general drew

23     simply disappeared.  Would that be right?  Oh no.

24        Q.   General, I'm sorry, I made a mistake.  This is a technical

25     problem.  Could you please draw the area of the Medak pocket again on

Page 13121

 1     this map.

 2        A.   [Marks]

 3        Q.   In your view, General, is this territory strategically important

 4     for the Croatian army, the Croatian armed forces?

 5        A.   Absolutely not.  As a matter of fact, it's not even important

 6     from the point of view of the explanation that the Croats, the official

 7     Croatian authorities, gave, namely, that that was their response to the

 8     shelling of Gospic.  If you look at this part of the front line that is

 9     jutting out, as it were, there was nothing of the kind.  They could see

10     that from the dominant elevations that they held.

11             MR. LUKIC: [Interpretation] Can we please admit this into

12     evidence now, Your Honours, before we actually lose this image.

13             JUDGE MOLOTO:  It's admitted into evidence.  May it please be

14     given an exhibit number.

15             THE REGISTRAR:  Your Honours, this document shall be assigned

16     Exhibit D439.  Thank you.

17             JUDGE MOLOTO:  Thank you.

18             MR. LUKIC: [Interpretation]

19        Q.   Was this attack halted?  Did it stop in any way?  What happened

20     after that aggression?

21        A.   The attack of the Croatian forces was stopped at the line of the

22     village of Medak and the road that goes through the village of Medak.

23     This is a continuation of this straight line from Gospic and then further

24     down south.  That is to say that they only entered this area that is

25     jutting out; however, operations continued nevertheless.  General Cot

Page 13122

 1     and, as far as I know, the international representatives in Zagreb tried

 2     to reach some kind of agreement in order to end the hostilities.  I was

 3     told that the Croatian side is refusing to discuss anything with anyone

 4     from the international community with regard to this case.

 5        Q.   Who said that to you?

 6        A.   That's what I was told by General Cot and General Pellnas.

 7        Q.   What happened then?

 8        A.   At the same time, as for those who were withdrawing from the

 9     area, I heard the same thing from them that I heard from General Pellnas,

10     namely, that the civilian population was being massacred and that all

11     living creatures were being destroyed in the said area.  Because of that,

12     I decided to threaten the Croatian side in order to force them to stop

13     doing such terrible things.

14             For a few days, all the media that were under our control stated

15     publicly and persistently repeated the list of military objectives in the

16     territory of Croatia - I repeat - exclusively military targets that would

17     be targeted by the Serb side unless what is happening in the area that

18     they had taken is brought to a halt.  At the same time, the civilian

19     population was asked to move away from these military objectives.  These

20     military objectives or targets were exclusively of a military nature,

21     namely, the basis of the special Croatian police that we knew was

22     participating in this action, the bases and the command posts of the

23     Croatian army.

24             After there was no change in the situation, as a matter of fact,

25     their activity continued unabated, we did target some military facilities

Page 13123

 1     of this kind.  The first facility that we targeted was the base of the

 2     special police at the former airfield with a grass runway, Lucko it was

 3     called.  It is to the west of Zagreb.  Further on, it was the barracks in

 4     Jastrebarsko which is between Zagreb and Karlovac.  I think that that was

 5     the barracks of the communications unit of the Croatian Main Staff in the

 6     Samo barracks.

 7        Q.   To the best of your knowledge, were there any civilian casualties

 8     during these attacks?

 9        A.   I did not have any reports stating that there were civilian

10     casualties sustained during these attacks.  This base of the special

11     police in Lucko that is outside built-up areas, it was not hit.  Also,

12     the barracks in Jastrebarsko were not hit, and the town of Jastrebarsko

13     wasn't hit either.  This Luna rocket fell closer to the highway, fell

14     onto an empty space there.  That is what I know about these targets of

15     ours and civilian casualties.

16        Q.   I want the transcript to reflect this:  What were the rockets

17     that you used for carrying out these operations?

18        A.   When the firing positions were being changed at the time, we

19     temporarily had a battery of Luna M -- or, rather, R-65 missiles.

20     According to the NATO marking, it is --

21             THE INTERPRETER:  The interpreter did not hear the word.

22             THE WITNESS: [Interpretation] -- number 7.

23             JUDGE MOLOTO:  The interpreter didn't hear the word.

24             THE WITNESS: [Interpretation] FROG-7.  Frog, as in the animal,

25     frog.

Page 13124

 1             MR. LUKIC: [Interpretation]

 2        Q.   General, and what was the reaction, if there was any, of the

 3     UNPROFOR to this action of yours?

 4        A.   Shortly afterwards, General Cot reported that the Croats had

 5     agreed, the Croatian authorities, President Tudjman primarily and the

 6     chief of their Main Staff General Bobetko, agreed to speak with them.

 7     General Pellnas told me that he was glad - I repeat - that he was glad

 8     when he heard that our FROG was flying towards Belgrade -- towards

 9     Zagreb.

10             THE INTERPRETER:  Correction:  Towards Zagreb.

11             THE WITNESS: [Interpretation] Because up until then, they were

12     completely ignored in their requests to be received by both the Croatian

13     civilian and military authorities.

14             MR. LUKIC: [Interpretation]

15        Q.   Thank you.  In relation to this incident, what was the impression

16     this incident made on you - I asked you this about Maslenica earlier - in

17     terms of further possible attacks against the Krajina and the position of

18     the Croatian authorities on that?

19        A.   It was our assessment that the Croatian side would continue with

20     merciless armed actions in order to establish complete control over the

21     territory and areas under the protection of the UN, namely, the territory

22     of Republika Srpska.  The second conclusion was that the population in

23     the territory under our control was of no interest to them; rather, they

24     were interested in an empty territory only.

25        Q.   Thank you, General.  We're going to move to a different topic

Page 13125

 1     now.

 2             In preparations for this testimony, I was able to show you some

 3     documents that we referred to as the notebooks or notes of General Mladic

 4     in the courtroom.  My question was:  Did I show you any documents like

 5     that?

 6        A.   Yes, that is correct.

 7             MR. LUKIC: [Interpretation] I think in view of the decision of

 8     the Trial Chamber we can remain in public session, and I would like to go

 9     through some of these documents from batch 410 with the witness.

10        Q.   General, these documents, did they refresh your recollection

11     about some event and meetings that you had?

12        A.   Yes, that is correct.

13        Q.   The first document that I would like to look at with the General

14     is a document --

15             MR. LUKIC: [Interpretation] Now, Your Honour, we are going to

16     follow this procedure that we had earlier, and that is primarily I'm

17     going to ask the -- your agreement to introduce into our 65 ter list of

18     exhibits of the Defence this document, that is, a document that I'm

19     marking with the mark 65 ter 03382D, which in the B/C/S starts from

20     0668-2627 - that is the ERN page - until 2637 -- actually, in the e-court

21     it goes up to 2640.

22             This is notes from a meeting with President Milosevic of the 24th

23     of September, 1993.  So let me first hear the position of the Prosecution

24     before we are able to use the document.

25             MR. HARMON:  I have no objection to this document being added to

Page 13126

 1     the Defence 65 ter list, Your Honour.

 2             JUDGE MOLOTO:  Thank you.

 3             Yes, Mr. Lukic, it's so added.

 4             MR. LUKIC: [Interpretation] Before I start going through the

 5     document with the witness - and there will be a number of them - I just

 6     wanted to inform the Trial Chamber that what you see before you is an

 7     official translation we received from the translation service.  However,

 8     when we were going through the document of this official translation, we

 9     encountered certain translations which we find are inadequate.  Some of

10     them are not so important, but there are a few that we do consider

11     important.  I've informed Mr. Harmon about it, and I marked the parts

12     which we believe are in dispute, and his suggestion was to ask the

13     translation service to retranslate this document and then we can tender

14     this new translation into evidence.

15             So when I'm going through the documents with the witness, I'm

16     going to ask the witness to read certain parts or I can read them and the

17     witness can confirm that that is what is said in the translation.  We

18     have also provided copies to the interpreters in the booths.  And we have

19     marked those parts that we believe are inaccurate, and we've asked them

20     to pay special attention to those parts.

21             JUDGE MOLOTO:  Mr. Harmon.

22             MR. HARMON:  Yes.  Mr. Lukic and his team provided me with copies

23     of these documents and the portions that they assert need to be

24     retranslated.  I've looked at them with my language assistants.  I agree

25     with some of the suggestions; I don't agree with other suggestions.  When

Page 13127

 1     matters are read into the record, I would like to make it perfectly clear

 2     that I -- on disputed areas, I'm not accepting the - with all deference

 3     to the language booth - the interpreter's reading as the correct and

 4     definitive translation.  I think if these are submitted to CLSS, these

 5     portions that are in dispute, that we should be guided by CLSS's

 6     translation of these and not the oral reading and the quick

 7     interpretation of what's on these documents.

 8             So insofar as the procedure that Mr. Lukic has identified, if he

 9     will identify those portions to where we have a dispute, and then we can

10     have CLSS regulate that matter for us as the official document that would

11     be guiding the Court and the parties in their work.

12             JUDGE MOLOTO:  Is that acceptable to you, Mr. Lukic?

13             MR. LUKIC: [Interpretation] Yes, yes.  That is what I said.  That

14     can be a final version.  We can send it to the translation section, and

15     then their version would be the final one.

16             JUDGE MOLOTO:  Sure.  Okay.  You may proceed then.  We'll do

17     that.

18        Q.   General, we see in front of us the first page of several that

19     will follow, and it says:

20             "Meeting with President Milosevic" of the

21     24th of September, 1993.

22        A.   Yes, that is correct, the 24th of September, 1993.

23        Q.   Yes, that is correct, the 24th of September, 1993.  We're going

24     to go page by page.  But what we see from the document is that the

25     participants in this conversation are General Perisic, General Mladic --

Page 13128

 1     actually, this is General Mladic's notebook so I'm drawing the conclusion

 2     on the basis of that.  And you are also mentioned.  So I'm just asking

 3     you if you remember that this meeting was held at that time in Belgrade?

 4        A.   Yes, I remember.

 5        Q.   And do you perhaps recall whether, other than those persons

 6     mentioned as being present here, anyone else was present also, or were

 7     they only the persons that are actually referred to that attended this

 8     meeting?

 9        A.   I think that the meeting was only between the persons that you

10     mentioned.

11        Q.   We're now going to go section by section, and I will ask you to

12     comment based on your recollection of that conversation whether what is

13     written down here adequately reflects what that person, that participant,

14     said in the conversation.  General Perisic is mentioned first.  I am not

15     going to read the first two sentences.  Are you able to read, or should I

16     read?

17        A.   Yes.

18        Q.   Does this reflect General Perisic's words adequately?  According

19     to your recollection, is that what he said at the time?

20        A.   According to my best recollection, it does absolutely reflect

21     what was said because that was what his assessments -- that's what his

22     assessments were and his view about the situation.  I especially want to

23     mention the third point; they are very strong, logistical support,

24     logistics.

25        Q.   Yes, that is where my first remark was.

Page 13129

 1             MR. LUKIC: [Interpretation] As you can see, Your Honours, in the

 2     English version and the B/C/S version, this is my objection to the

 3     translation service:  They're placing something in parenthesis,

 4     interpreting what is being written there.

 5        Q.   General, please, what it says here is:

 6             "They are very strong PO."

 7             What does that mean?  What do you think that means?

 8        A.   According to the standard abbreviations used by General Mladic,

 9     and they were commonly used in the schools that we completed, this can

10     only mean the term that we used and that is "logistics support."

11     "Pozadinsko obezbedjenje."  This is a term that is practically identical

12     to the term "logistics."  It's not entirely the same, "pozadinsko

13     obezbedjenje," "rear support," but more or less those two terms mean the

14     same thing.

15        Q.   Very well.  When he says "they," who did he refer to,

16     General Perisic?

17        A.   He meant Croatia, which he mentions immediately before.

18        Q.   And in relation to the incident that we mentioned before, when we

19     look at the date here, can you please tell us the date of the Medak

20     incident in relation to this meeting here?

21        A.   The incident began on the 9th of September, and this is the

22     period immediately after General Stipetic and I signed some kind of an

23     agreement on the cessation of hostilities, and the Canadian Battalion

24     from UNPROFOR pushed the Croatians out of that area.

25        Q.   Now, General, I'm going to read the next paragraph, and you can

Page 13130

 1     just confirm to me whether I've read it adequately because of the

 2     translation.

 3             "Help in manpower (senior officers) everything is on a voluntary

 4     basis ... to go for a more radical position, that everyone who was born

 5     there should go."

 6             MR. LUKIC: [Interpretation] And I'm particularly reading the

 7     following sentence because of the translation, Your Honours.

 8             "To persuade them as much as we can to go there."

 9           For example, if I can comment now.  I'm quite satisfied with the

10     translation from the booth, but in any case --

11             JUDGE MOLOTO:  Mr. Harmon --

12             MR. LUKIC: [Interpretation] No, no.  No.  I agree.  I agree.

13             JUDGE MOLOTO:  Mr. Harmon.

14             MR. HARMON:  Mr. Lukic may be satisfied with the translation from

15     the booth.  This is a portion that we have an issue with, and this is the

16     area where I think we should be guided by the official CLSS translation

17     and not the translation from the booth.

18             JUDGE MOLOTO:  If you say so, Mr. --

19             MR. LUKIC: [Interpretation] Absolutely.  I just commented.  I

20     just wanted to draw your attention to what it was that we saw as the

21     discrepancy between the official translation and what we were pointing

22     to.  We don't want to go into details or we don't want to burden the

23     translation service in any event.

24             JUDGE MOLOTO:  Thank you.  We will send --

25             MR. LUKIC: [Interpretation]

Page 13131

 1        Q.   General, did I read this correctly, what I have just read to you?

 2     And I'm going to ask you, Can you please confirm?

 3        A.   Yes.

 4        Q.   Can you give us your comment on the position of General Perisic

 5     in relation to the departure of officers and which officers.  What does

 6     this exactly refer to?

 7             JUDGE MOLOTO:  Just a second, Mr. Lukic.  Doesn't the document

 8     speak for itself on that point, provided that we get a correct

 9     translation from CLSS?

10             MR. LUKIC: [Interpretation] I didn't understand you very well

11     now.

12             JUDGE MOLOTO:  Well, I have a problem with your question.  You're

13     saying:

14             "Can you give us your comment on the position of General Perisic

15     in relation to the departure of officers and which officers.  What does

16     this exactly refer to."

17             Now, there is a minute here written by General Mladic about which

18     there is a dispute between the parties on the interpretation.

19     Okay?  We are going to get CLSS to re-look at that translation and tell

20     us whether they stand by what's written here or whether they are prepared

21     to change.  And once we've got that, that will be the position of

22     General Perisic, which the witness's comment on that position doesn't --

23             MR. LUKIC: [Interpretation] Well, now I have to give you my

24     comment.  When we get this translation, that will be a position being

25     recorded in this document as being the position of General Perisic.  So

Page 13132

 1     what I'm going to ask Mr. Novakovic is, Does he recollect that, or What

 2     does he recollect was General Perisic's position on the basis of this

 3     document on this topic.

 4             JUDGE MOLOTO:  You're not asking for a comment; you're asking for

 5     his recollection?

 6             MR. LUKIC: [No interpretation]

 7             JUDGE MOLOTO:  Okay.  The first question was "comment."

 8             MR. LUKIC: [Interpretation]

 9        Q.   General, we've understood each other.  Yes, you can go ahead and

10     answer the question.

11        A.   This entry --

12             JUDGE MOLOTO:  Your recollection, General.

13             THE WITNESS: [Interpretation] -- which --

14             JUDGE MOLOTO: [Previous translation continues] ... no, your

15     recollection, Mr. Novakovic, sorry.

16     Forget about the entry.  What is your recollection of General Perisic's

17     position on the departure of officers?

18             THE WITNESS: [Interpretation] Your Honour, all I wanted to say is

19     that this reminds me of the position --

20             JUDGE MOLOTO:  Now that you remember the position -- [Previous

21     translation continues] ...

22             THE WITNESS: [Interpretation] -- because if I were honest, I

23     really couldn't say whether that was the position or not.

24             JUDGE MOLOTO:  I understand perfectly.  Now that you remember,

25     tell us, What is your recollection of that position?

Page 13133

 1             THE WITNESS: [Interpretation] The gist of the position of

 2     General Perisic on this matter on sending officers and non-commissioned

 3     officers who were born in our area who were at that time in the

 4     Federal Republic of Yugoslavia was that he didn't have a legal basis to

 5     send them there, that the dispatch up until that moment was on the

 6     principle of voluntarity, voluntariness, and that it did not depend on

 7     him, basically whether those people would go there or not.  And that was

 8     the practice as well at the time, Your Honour.

 9             JUDGE MOLOTO:  Thank you so much.

10             Yes, Mr. Lukic.

11             MR. LUKIC: [Interpretation]

12        Q.   Let us move on to the next page.  We're still dealing with the

13     words of General Perisic.  Now I would like to comment on the second and

14     third sentence.

15             "Issuing OB equipment (weapons, ammunition, fuel) ..."

16             What does the abbreviation "OB" mean?  Do you recall what it was

17     that Perisic was saying in respect of this entry?

18             MR. HARMON:  Objection, Your Honour.  There's two questions.  The

19     first is:  What does the abbreviation OB mean?  That's the first

20     question.  The second question is:  Do you recall what he was saying in

21     respect of this entry.  So if we could have the answer to the first

22     question, we could proceed to the second question.  But I object because

23     the question is compound.

24             JUDGE MOLOTO:  Mr. Lukic.

25             MR. LUKIC: [Interpretation] I don't think that that question was

Page 13134

 1     that complex that the witness cannot be in a position to answer it.  In

 2     order to speed things up --

 3        Q.   Okay, General, what do you believe "OB" means?

 4        A.   For me - and General Perisic completed the same school that I

 5     did - OB means "organ bezbednosti," "security organ."  However, what I

 6     find illogical is how come it is followed by "weapons, ammunition, fuel."

 7     So at this point in time I cannot confirm anything.  I cannot remember

 8     now what this exactly pertained to.

 9        Q.   Thank you.  The next entry that says:

10             "Regulating the status of officers (from retirement issues to

11     purchasing uniforms) ..."

12             Does this jog your memory in any way in terms of the words of

13     General Perisic at the time?

14        A.   Yes.  This is an answer to our constant requests to resolve the

15     questions of the status of professional officers who are still being

16     registered as serving in the Army of Yugoslavia but are actually in the

17     Army of Republika Srpska and the Serb Army of the Krajina.

18             Status-related questions are not resolved for them as they are

19     for those professional military personnel who are serving in the

20     garrisons of the Army of Yugoslavia, starting with the matter of not

21     having their years of service recorded properly, therefore they do not

22     have the necessary number of years of service as the administration

23     personnel put it but they actually do have a sufficient number of

24     service.  Then also their medical insurance for them and for their family

25     members so that they can receive medical treatment in military medical

Page 13135

 1     institutions.  Then the basic problem, the very ordinary problem of

 2     purchasing uniforms.  I was glad at that point in time to see

 3     General Perisic stating these problems for starters.

 4        Q.   What was your problem in terms of medical services being provided

 5     and uniforms being purchased?  I'm referring to the Army of Yugoslavia

 6     now.

 7             JUDGE MOLOTO:  Sorry, this witness was in the Army of the Serbian

 8     Krajina.  Would he know the problems within the VJ?

 9             MR. LUKIC: [Interpretation] I am asking him about his problem as

10     an officer of the SVK.  How did he get medical treatment --

11             JUDGE MOLOTO:  Look at --

12             MR. LUKIC: [Interpretation] I mean --

13             JUDGE MOLOTO: -- look at line 18 there, page 66:

14             "I'm referring to the Army of Yugoslavia now."

15             And that is preceded by a question --

16             MR. LUKIC: [Overlapping speakers] ...

17             JUDGE MOLOTO: -- which was:

18             "What was your problem in terms of medical services being

19     provided and uniforms being purchased?"

20             Now, his problem is a problem of the SVK, not of the Army of

21     Yugoslavia.

22             MR. LUKIC: [Interpretation] I do apologise.  I'm going to

23     rephrase the question now.

24        Q.   General, as a member of the SVK, could you purchase uniforms from

25     the depots of the Army of Yugoslavia just like officers of the Army of

Page 13136

 1     Yugoslavia could?

 2        A.   No.

 3        Q.   What was the problem?

 4        A.   The problem was because in my military ID there was not a

 5     military post code number or a military unit number from the Army of

 6     Yugoslavia.  If I have that kind of number in my military ID, I could

 7     have purchased a uniform.

 8        Q.   What was the problem with the medical insurance cards that you

 9     had for using medical services of the Army of Yugoslavia?

10        A.   A military medical insurance card of a military medical insuree

11     of -- that is to say, of a military officer of the Army of Yugoslavia and

12     family members of such military personnel who had the same rights on the

13     basis of that person's employment with the Army of Yugoslavia, namely, to

14     be treated in military medical hospitals, that depended at the time and

15     depends to this day in Serbia on the following:  Whether the medical

16     insurance card has been stamped, whether it has been verified, by way of

17     a stamp, that the military insuree is serving in a specific military post

18     in the Army of Yugoslavia, that is on the list of the military post of

19     the Army of Yugoslavia.

20        Q.   Now the next entry; does that jog your memory?  What were these

21     words that were uttered by General Perisic?  It says:

22             "Material financial support."

23        A.   Yes.  This is a continuation -- I mean this notebook is not

24     stenographic notes.  I remember this part.  It's not that I don't

25     remember it.  General Perisic was talking about insufficient material

Page 13137

 1     financial support.  First of all, the Army of Yugoslavia didn't have

 2     that, and he said that that was the main reason why he cannot meet our

 3     requests for material resources.

 4        Q.   Now an entry that pertains to you, so I'll just ask you what this

 5     means, what it says here, "min snage vojin."  Do you remember what this

 6     means?  Could you tell us briefly what the term "vojin" is?

 7        A.   Yes, I have an excellent recollection of that because that was a

 8     big problem for me.  This correctly reflects what I had asked for.  It

 9     means minimal forces for air surveillance, reporting, and guidance.

10     Minimum forces for air surveillance, reporting, and guidance.  That is a

11     system that controls the situation in the air-space.  That exists in

12     every army of the world, that is to say, above one's territory and on the

13     approaches to your territory by way of radar, visual equipment, and other

14     equipment; you monitor and observe everything that is in the air-space.

15     You identify enemy targets.  And also what it says here at the end,

16     "guiding," as for your own anti-aircraft equipment, you guide it so as to

17     destroy enemy targets.

18             Also, a clear distinction is being made here in terms of

19     identifications, what is an enemy target, and what are other aircraft in

20     the air-space.

21        Q.   General, at the time, did the SVK have a developed "vojin"

22     system?

23        A.   No, no.  At the time, we did not have a developed "vojin" system.

24        Q.   Up until the end of the war, did you manage to develop a "vojin"

25     system?

Page 13138

 1        A.   No, no.  We never managed to develop a "vojin" system for our

 2     territory.

 3        Q.   Thank you.  Let us move on.  I don't have to read.  Could you

 4     just give me your comment about the next entries.  What is the meaning of

 5     what you were saying then?

 6        A.   The next entry has to do with air-space control above our

 7     territory.  Because if your observation system detects an enemy target in

 8     the air-space and if you do not have an air force to down such aircraft,

 9     well then you don't really need observation equipment in the first place.

10        Q.   Let us move on a bit faster.  We had a bit of a problem here.

11     Can you explain to us this so that the translators can translate it

12     there.  It says here at the end:

13             "Six heavy-duty haulage vehicles to transport T."

14             Do you remember what "T" meant at the time?  We have a problem

15     with the translation there.  Could you just tell us that.

16        A.   During the course of my remarks today, I mentioned to this -- I

17     mentioned this problem of towing vehicles.  These are vehicles that have

18     a platform for loading tanks.  So "T" means "tanks" in this context.

19        Q.   Thank you.  The translation service correctly interpreted this in

20     this case.

21             MR. LUKIC: [Interpretation] So could we please see the next page.

22        Q.   Again, the entry says that this is what you had said.  So could

23     you give us your comments, briefly.  To the best of your recollection,

24     what was it that you were talking about at that point?  And this is what

25     it says:  "Joint 'vojin.'"

Page 13139

 1        A.   There is one before that too.

 2        Q.   Yes, please.  Do explain what this previous entry means.  What is

 3     "BROM"?  And what does this mean:  "For operations ZZ."

 4        A.   The first entry -- well, I'm saying this not because it is

 5     written here.  I'm saying it in that context because I remember this

 6     perfectly.  The Army of Yugoslavia had quite a few batteries.  "BROM"

 7     means "baterija raketa, obala, more," "battery of rockets, coast, sea."

 8     That's about 80 kilometres away.  And they were taken out when the navy

 9     of the Yugoslav People's Army of the JNA was being withdrawn from its

10     garrisons, from the military naval sector.  That was the territory of the

11     former Socialist Republic of Croatia.  These rockets were not being used

12     and were there, so we thought that we could perhaps use them, if

13     necessary, as surface-to-surface rockets, they have the same kind of

14     charge.  And we were saying, If you don't have what we need, give us what

15     you have.  We will improvise.

16             THE INTERPRETER:  The interpreters did not hear the last

17     sentence.

18             MR. LUKIC: [Interpretation] Do you remember what --

19             JUDGE MOLOTO:  The interpreters did not hear the last sentence of

20     the answer.

21             THE INTERPRETER:  Interpreter's note:  Could all microphones

22     please be switched off when the witness is speaking.

23             MR. LUKIC: [Interpretation]

24        Q.   I think that everything has been recorded, I think.

25        A.   Yes, yes.

Page 13140

 1        Q.   You said that everything --

 2        A.   This is what I said --

 3             THE INTERPRETER:  Interpreter's note:  Could all microphones

 4     please be switched off.

 5             THE WITNESS: [Interpretation] If they do not --

 6             JUDGE MOLOTO:  Mr. Lukic --

 7             Just hold, ma'am, now that you have asked us to do something.

 8             Could all microphones please be switched off while the witness is

 9     speaking.

10             You may proceed, Mr. Novakovic.

11             THE WITNESS: [Interpretation] What I said was that if they did

12     not have what it was that we were asking for, let them give us at least

13     this and we will improvise on that basis.

14             JUDGE MOLOTO:  Thank you so much.

15             Yes, Mr. Lukic.

16             MR. LUKIC: [Interpretation]

17        Q.   Did you get anything as far as these rockets were concerned?

18        A.   As far as I can remember, we did not.

19        Q.   Next entry says:

20             "Joint 'vojin.'"

21             General, do you remember, does that reflect some of your words at

22     that meeting?

23        A.   This accurately reflects my words at that meeting and at other

24     meetings as well.  I repeated that very often.  The actual entry here --

25     or, I mean, even if it hadn't been written up.  "Vojin" means what I

Page 13141

 1     said.  Its main characteristic is that as a system for securing the

 2     air-space, it can only be efficient if organised in a larger area.  What

 3     have you -- what business do you have detecting aircraft that have

 4     already entered a very limited air-space?  You should try to observe that

 5     as far away as possible so that your own units can be on the ready in a

 6     state of full combat-readiness to react.  That is why I said to

 7     General Perisic and to all other participants that from the Adriatic to

 8     Romania a joint system should be set up.  Technically that was feasible,

 9     and that could have been efficient, and it could have improved things.  I

10     was hoping that they would understand that, that that improved the

11     capacity of fighting enemy targets in the air-space of the Army of

12     Yugoslavia as well.

13        Q.   And was a joint "vojin" system set up?

14        A.   No, it never was.

15        Q.   And the next point in this list was:

16             "Joint PED and EI ..."

17             What were you talking about there?

18        A.   I remember this very well because this is not the first time that

19     I talked about this.  I spoke about this at other meetings as well.  My

20     war-time experience confirmed exactly what I knew from theory, and that

21     was that the use of electronic means and counter-electronic warfare

22     against the enemy meant just as much as the use of what we could describe

23     as hardware, meaning tanks, infantry, and other types of resources of

24     that kind.

25             And I have to say that it was strange to me and incomprehensible.

Page 13142

 1     And I had an objection about this in terms of General Perisic for as long

 2     as I was on duty and that was:  Why didn't he make sure as a professional

 3     military man to have this system organised jointly and to have all joint

 4     systems that could be of interest either to the Army of Yugoslavia, the

 5     JNA [as interpreted], or to our army.

 6             I knew, for example, of cases when people in the electronic

 7     surveillance battalion in the area of Prokuplje were monitoring on a

 8     monthly basis one to two foreign communications in the area of

 9     neighbouring states.  But when combat started in my area, suddenly

10     700 networks would be activated, 700 radio networks would be activated.

11     And I kept telling General Perisic, If you don't want a joint system, at

12     least send these people of yours so that they can see how things look as

13     far as electronic surveillance is concerned in war time.  You will

14     increase the value of those units in that way, and you will be of help to

15     us there.

16             The same thing applied to this PED.  These are counter-electronic

17     activities, and that means defence measures against the enemy electronic

18     warfare, meaning electronic surveillance.  I don't need to go into

19     details.  Jamming, ruses, and all these other techniques that are used.

20             And I can speak quite openly here and say that at the time I was

21     trying to explain both to Mr. Perisic and to Mr. Milosevic that this

22     would be useful for the Army of Yugoslavia also if they wanted to monitor

23     what was happening around them.  And for us it could help us without any

24     kind of participation in the war outside of the Federal Republic of

25     Yugoslavia that would be massive or of a compromising nature.  And I have

Page 13143

 1     to say, today even, that it was unclear to me why this was never done.

 2        Q.   You've already answered my next question with this, so I'm just

 3     going to ask:  Is it that this didn't happen for as long as you were the

 4     commander of the Army of the Serbian Krajina, or did this not happen all

 5     the way until the end of the war?

 6        A.   While I was the commander of the Serbian Army of the Krajina,

 7     this did not happen; and it did not happen, as far as I know and which I

 8     absolutely believed is accurate, it did not happen until the end of the

 9     existence of the Army of the Serbian Krajina.

10        Q.   And the next entry is:

11             "To send officers to K."

12             Is this accurately reflecting what you said at the time?

13        A.   Yes, yes.  Officers should be sent to the corps units, to the

14     Serbian Army of the Krajina.  I think that this text -- well, these are

15     not minutes.  When you translate it officially, you will see that these

16     are notes made by one man.  If I happened to have my notebook handy here,

17     it would have been different.  Evidently, if these are entries made by

18     General Mladic, this is actually not everything that I said.  I actually

19     said, Send officers to corps units of the Serbian army of the Krajina.

20             But we only have three dots here after that entry.

21        Q.   And then after the text that follows, we have the name of

22     President Milosevic.  It's a longer section, but we can begin, at least,

23     to go through it, even if we don't have too much time left for today.

24     Well, I don't need to read the first three sentences, and there's nothing

25     here to be disputed regarding the translation.  I'm asking you:

Page 13144

 1     According to your recollection does this accurately reflect the words of

 2     President Milosevic?  First answer that.

 3        A.   Yes.

 4        Q.   Yes, go ahead.

 5        A.   I actually remember exactly what this refers to because besides

 6     what is written here there was also a request made of me.  Mr. Milosevic

 7     here is dealing with the internal political situation in Serbia, and as

 8     you can see there were internal enemies and 5th column elements in Serbia

 9     which were being programmed, as he put it, by the foreign factor,

10     external factor.  What is interesting is that in that period - and I know

11     this perfectly well, and this is also something that can be seen in this

12     entry here - the most dangerous opponent in the internal plan was viewed

13     to be Mr. Seselj and the Serbian Radical Party because it was on the

14     ascent and in that part of the political arena which Mr. Milosevic felt

15     belonged to him.

16             I remember that at one point in time I, as the commander of the

17     Army of the Serbian Krajina and immediately after this, which affirms

18     what I'm saying here and what is said here, was asked to blacken the

19     reputation of volunteers of the Serbian Radical Party who were coming to

20     fight in the area of the Republic of the Serbian Krajina in a public

21     statement.

22             So I read a public announcement at a session of the Assembly,

23     which happened to be very tumultuous.  I was asked to do that.  Of

24     course, I didn't do that because I felt and I said that the volunteers

25     who were coming to the Republic of the Serbian Krajina to help in its

Page 13145

 1     defence we did not judge by their party affiliation; we saw them all as

 2     being equal, who were coming to fight.

 3        Q.   And who asked you to read this public announcement?

 4        A.   I don't remember, but I think it was the then-president of the

 5     Assembly of Serbia.

 6        Q.   Thank you.

 7             MR. LUKIC: [Interpretation] I would like to continue with this

 8     document, but I think it would be good to stop here, Your Honours,

 9     because we're about to change to another topic but remain on this

10     document.

11             Just one moment.  Perhaps I have one intervention to the

12     transcript.  Just give me a minute, Your Honours, please.

13                           [Defence counsel confer]

14             MR. LUKIC: [Interpretation] I didn't wish to interrupt the

15     General, but Mr. Zorko is indicating to me now that on page 73,

16     Your Honours -- page 73, line 8, when the witness was talking about the

17     AE and the PED system, he said it was in the interest of the Army of

18     Yugoslavia, the VRS, and my army, and what is said there is the JNA.  So

19     I just assume that it's a mistake in the transcript because the JNA was

20     not actually mentioned in that context.

21             JUDGE MOLOTO:  I don't see PED at line 8.

22             MR. LUKIC: [Interpretation] He's talking about that topic.  You

23     can see the question on line 20 in the previous page.  He's talking about

24     this system, EI and the PED; and then in his reply, page 73, line 8, what

25     is written is the JNA, but he actually referred to the VRS.

Page 13146

 1             JUDGE MOLOTO:  Do you confirm that, Mr. Novakovic?

 2             THE WITNESS: [Interpretation] Yes, yes, absolutely.  The JNA

 3     didn't exist at the time, Your Honour.

 4             JUDGE MOLOTO:  Thank you.

 5             Is that the end for the day -- end of the day?

 6             MR. LUKIC: [Interpretation] Yes, yes.  I would like to suggest.

 7             JUDGE MOLOTO:  Mr. Novakovic, unfortunately we are not going to

 8     be sitting tomorrow for logistical reasons within the Tribunal.  We will

 9     sit on Monday in the afternoon at 2.00 in the same courtroom.  Once

10     again, I remind you that you may not discuss the case with anybody and in

11     particular not with your Defence counsel.  And if you do have anything

12     outside the case that you would like to talk to him about, try to get in

13     touch with one of the Court Officers and arrange that.  Okay?  And they

14     will tell you whether you may or may not talk to him.

15             The Court stands adjourned to Monday, quarter past 2.00 in the

16     afternoon, Courtroom II.  Court adjourned.

17                           --- Whereupon the hearing adjourned at 1.45 p.m.,

18                           to be reconvened on Monday, the 30th day

19                           of August, 2010, at 2.15 p.m.