Tribunal Criminal Tribunal for the Former Yugoslavia

Page 37082

 1                           Wednesday, 18 February 2009

 2                           [Open session]

 3                           [The accused entered court]

 4                           [The witness entered court]

 5                           --- Upon commencing at 9.03 a.m.

 6             JUDGE ANTONETTI: [Interpretation] Mr. Registrar, kindly call the

 7     case.

 8             THE REGISTRAR:  Good morning, Your Honours.  Good morning,

 9     everyone in and around the courtroom.

10             This is case number IT-04-74-T, the Prosecutor versus Prlic

11     et al.

12             Thank you, Your Honours.

13             JUDGE ANTONETTI: [Interpretation] Very well.

14             Today, let me greet the accused, the Defence counsel present in

15     the courtroom.  And good morning, Witness.  Good morning, Mr. Scott.

16     Good morning to your associates.  Good morning, Ms. West.  And good

17     morning, Mr. Court Reporter assisting us, whose work is extremely

18     difficult.  Good morning to the Registrar and the usher.

19             We have to complete Ms. Alaburic's cross-examination.  I'll ask

20     the legal officer to tell us how much time is left.  And without further

21     adieu, I'll ask Ms. Alaburic to proceed.

22                           WITNESS:  VESO VEGAR [Resumed]

23                           [The witness answered through interpreter]

24             JUDGE ANTONETTI: [Interpretation] Ms. Alaburic, I'm told that you

25     have 13 minutes left.  Try to remain within the next quarter of an hour

Page 37083

 1     so that Mr. Scott can start with his cross-examination.

 2             MS. ALABURIC: [Interpretation] Your Honour, good morning to you.

 3     Good morning, Mr. Vegar.  Good morning to everyone in the courtroom.

 4                           Cross-examination by Ms. Alaburic:  [Continued]

 5        Q.   [Interpretation] Now, Mr. Vegar, shall we go back briefly to the

 6     topic of the foreign median their reporting.

 7             Tell me, to the best of your knowledge, did foreign media, such

 8     as agencies Reuters and AFB, have their own correspondents in Mostar or

 9     elsewhere in Herceg-Bosna?

10        A.   No, they did not.

11        Q.   Can you tell us how they came by information about the events and

12     developments in the area of Herceg-Bosna?  Did they get their information

13     by perusing domestic media, contacting local journalists, getting press

14     releases from domestic institutions?

15        A.   Yes, that's how they came by their information, mostly

16     indirectly, except for the cases when they would come to Mostar

17     themselves.

18        Q.   Tell me, foreign reporters came to Mostar as a rule to prepare

19     one story, one report, they would stay briefly, and then return to their

20     base, or was it a different practice?

21        A.   They stayed briefly when they came, for an hour or two, several

22     hours at most, and then they would go back.

23        Q.   In this way of work, when you are using other sources, is it

24     possible for several media to publish one and the same story, based on

25     one and the same source?  For instance, if Reuters comes out with one

Page 37084

 1     story that contains a mistake, and other media take over the same story,

 2     can the same mistake be perpetuated in many reports?

 3        A.   Yes.  If a mistake occurs and several media take over the story,

 4     then the mistake would be perpetuated.

 5        Q.   Yesterday, we spoke about the vertical and horizontal

 6     organisation.  I just wanted to look at one more document, 2D 853.  It's

 7     also a document of the Prlic Defence, 1D 1672.

 8             JUDGE ANTONETTI: [Interpretation] One moment.  I did not want to

 9     interrupt, because we have little time, time is of essence, but I have a

10     technical question because you were a journalist.

11             Mention was made of foreign reporters.  When they would go to

12     Mostar, for instance, if they went at all, you seem to say that they

13     would stay for very short periods of time.  But when they went, did they

14     meet with their colleagues, their Croatian colleagues, or did they go and

15     have a whiskey at the hotel bar, and would they go back after gathering a

16     few pieces of information from the hotel porter?  You were a journalist,

17     you were able to assess the work they would do.  Was it serious, the work

18     they did?  Were they fast, efficient, or were just very superficial?  How

19     would you qualify their work?

20             THE WITNESS: [Interpretation] As we said previously, there were

21     more than 2.000 reporters, many of them foreign, and you cannot lump them

22     in the same heap.  Others did their -- ones did their work very

23     thoroughly; others would come, size things up in 10 or 15 minutes, and

24     return to wherever they came from.

25             The situation in Mostar was critical.  Of course, when they would

Page 37085

 1     come, they would ask me for a statement, and then they would focus on the

 2     topic for which they came.

 3             JUDGE ANTONETTI: [Interpretation] One last question.  The major

 4     agencies, Reuters, AFP, did they have permanent correspondents in Mostar

 5     or were there reporters or journalists in Zagreb?

 6             THE WITNESS: [Interpretation] Their correspondents were mostly in

 7     Zagreb.  When they came to Herzegovina, they would go to Medjugorje

 8     without going to Mostar at all.

 9             JUDGE ANTONETTI: [Interpretation] And as part of their work,

10     would they try and make contact with you?  You knew them?

11             THE WITNESS: [Interpretation] Of course, I knew those who came

12     more than once.  If they came only once, how would I know them?

13             JUDGE ANTONETTI: [Interpretation] When you would read their

14     reports, were their reports objective or exaggerated?  How would you

15     qualify their reports?

16             THE WITNESS: [Interpretation] What bothered me in their reporting

17     was one-sidedness and their enslavement to their prejudice about what

18     they called sides to the conflict.

19             JUDGE ANTONETTI: [Interpretation] And when you would observe

20     inaccuracies in their reports, would you ask them to be corrected

21     officially, sir?

22             THE WITNESS: [Interpretation] If there was a factual mistake,

23     yes.  If it was an opinion expressed in the story, then I didn't think I

24     had the right.

25             JUDGE ANTONETTI: [Interpretation] Thank you.

Page 37086

 1             Please, Ms. Alaburic.

 2             MS. ALABURIC: [Interpretation] Your Honours, if you allow me,

 3     another few follow-up questions on this that would not go against my 13

 4     minutes.

 5        Q.   Mr. Vegar --

 6             JUDGE ANTONETTI: [Interpretation] No.  Questions by Judges do not

 7     give you any more credit.  It's part of your time.  Otherwise, I won't

 8     ask any questions anymore, ever.  If that is your purpose, I won't ask a

 9     single question anymore.

10             MS. ALABURIC: [Interpretation] All right, Your Honour.

11             We submitted a request to be decided about additional time for

12     the Defence regarding Judges' questions.  I'll proceed like this:

13        Q.   Mr. Vegar, in Mostar did you receive AFP service, Reuters --

14             JUDGE ANTONETTI: [Interpretation] Ms. Alaburic, you noticed that

15     my questions were essential ones, that they really encapsulated the whole

16     topic, so I fail to see what you could add to it.

17             MS. ALABURIC: [Interpretation] Your Honours, I would appreciate

18     it if you allow me to finish, and then you will see my purpose.

19        Q.   Mr. Vegar, President Antonetti asked you if you corrected

20     information published in the foreign media.  I would like to clarify for

21     the Trial Chamber, what did you know at all about foreign reporting

22     sitting in Mostar at the time?  To begin with, did you receive Reuters,

23     AFP, Associated Press Service, or other foreign agencies?

24        A.   No, I did not have that facility, but I had a certain insight

25     into their reporting through the stories in the domestic media that were

Page 37087

 1     taken over from the foreign media.

 2        Q.   So you did not know directly?  You did not have direct insight

 3     into foreign reporting.  You knew about those stories only if one of the

 4     domestic sources would refer to a foreign source?

 5        A.   Correct.

 6        Q.   At that time in Mostar, did you have occasion to receive US,

 7     British, French weeklies and dailies, other publications, watch TV

 8     reports of foreign agencies reporting from Bosnia?

 9        A.   No, I did not.

10             MS. ALABURIC: [Interpretation] Because of lack of time, I will

11     skip the document I had called before.

12             JUDGE ANTONETTI: [Interpretation] Witness, regarding this

13     question, does this mean that the HVO, in its civilian or military

14     components, that nobody had a satellite dish able to receive, through

15     satellites, CNN, Sky News, or other stations?  There was nobody in Bosnia

16     and Herzegovina with a dish capable of receiving foreign broadcasts?

17             THE WITNESS: [Interpretation] Some people probably did, but we in

18     the HVO did not have a service of that kind, nor did we have a person

19     whose job it was to follow these programmes.

20             JUDGE ANTONETTI: [Interpretation] You had individuals -- I

21     suppose that if you had a Croatian worker who used to work in Frankfurt

22     and had a second residence somewhere, he must have put a satellite dish

23     in order to receive ZDF, a German channel, or not - I guess so - in order

24     just to see the football matches of his local team.  Wasn't it so?

25             THE WITNESS: [Interpretation] Probably.

Page 37088

 1             JUDGE ANTONETTI: [Interpretation] But the HVO did not think it

 2     useful, in terms of media, to know what the world was saying about what

 3     was happening in Bosnia and Herzegovina?

 4             THE WITNESS: [Interpretation] Of course, that was important to

 5     us, but I'm telling you we did not have the technical facilities or the

 6     personnel who would do that.

 7             JUDGE ANTONETTI: [Interpretation] Very well.

 8             MS. ALABURIC: [Interpretation]

 9        Q.   Mr. Vegar, to follow up on this question, which I really believe

10     to be very important, did you hear about the programme of the Croatian

11     Television called "Picture Against Picture"?  Some of those were

12     presented here as evidence by the Prosecution.  Did you hear about the

13     programme?

14        A.   Yes.

15        Q.   Because of lack of time, I'll go on with leading questions.  Is

16     that a programme that portrayed reports by foreign television stations

17     about the region of the former Yugoslavia?

18        A.   Yes.

19        Q.   Tell me, if you know, at that time was it one of the most popular

20     programmes in all the areas covered by the Croatian Television signal?

21        A.   I think so.

22        Q.   Was one of the reasons perhaps the fact that the overwhelming

23     majority of citizens of the former Yugoslavia did not have satellite

24     aerials and were not able to follow foreign programmes on their own?

25        A.   Yes, the media isolation was rather bad.

Page 37089

 1        Q.   Very well.  Let us now go back to the topic of my

 2     cross-examination.

 3             You told us, Mr. Vegar, and that was on page 31 of the transcript

 4     of the first day of your evidence, you said that you had several sources

 5     of information for your own work, employees of the IPD sector on all

 6     levels, then other sectors within the Defence Department, the Defence

 7     Department itself, and the Main Staff.  Further on, you spoke a lot about

 8     the Main Staff as your source of information.  I want some clarification

 9     here.

10             Did you receive daily combat reports from the Main Staff?  Daily

11     combat reports, they were practically summaries of reports from all the

12     operation zones, all the four of them?

13        A.   Yes.

14        Q.   To the best of your knowledge, were they summary reports that the

15     Main Staff also forwarded to other competent bodies in Herceg-Bosna, if

16     you know?

17        A.   I really don't know all the other recipients, but I received

18     them.

19        Q.   Can you tell us how and with what regularities did you receive

20     information from other sources; for instance, from IPD personnel on other

21     levels, that is, assistant commanders of units and operation zones?

22        A.   I received them, but I would have liked to have received more.

23     They were rather irregular.

24        Q.   Were they supposed to be daily, weekly, or on some other basis?

25        A.   From the operation zones, they were supposed to be daily.  From

Page 37090

 1     other levels, depending on the importance of the events.

 2        Q.   All right.  What about other sectors of the Defence Department?

 3     From which sectors did you receive information, on what basis, and what

 4     kind of information?

 5        A.   That was information relevant to the HVO, but also to the public,

 6     and it was much more seldom; for instance, the Health Sector.

 7        Q.   When you said that you used to receive information from the

 8     Defence Department itself, could you please explain what you meant by

 9     that?

10        A.   I meant information about the Defence Department itself, maybe

11     from head of the Defence Department or some other people within the

12     Defence Department.

13        Q.   I presume that I have still two more minutes.  Let's hear some

14     explanations about the college of assistants and heads of departments

15     within the Defence Department.  This is the last set of my documents.  It

16     is not important for me to discuss individual documents.

17             P 05032, please take a look at it.  P 05032, invitation from

18     Bruno Stojic to you, Mr. Vegar, on the 14th of September, 1993, to attend

19     the college session.  And then the next document, P 05045, identical

20     invitation to -- addressed to Slobodan Praljak.  Please, Mr. Vegar, tell

21     us whether you remember having received such invitations to attend

22     college meetings.

23        A.   Yes, I used to receive them.

24        Q.   Fine.  Let's take a look at this document, and the document is

25     P 04576 -- P 04756.  These are minutes from a session of the college of

Page 37091

 1     the Defence Department.  Yes, now the number has been correctly reflected

 2     in the transcript.  This is the last document in this set of documents.

 3     At least this is how it's supposed to be.  Please take a look at the

 4     first sentence.  It says here, Head of the Defence Department drew

 5     attention to the fact that in the future, chief of the Main Staff should

 6     attend every college meeting.  From this note, I conclude that the chief

 7     of the Main Staff did not attend every session of the Defence Department

 8     college.  Isn't that so?

 9        A.   Well, I suppose so, because I did not attend every session.

10        Q.   It is important for us, Mr. Vegar, to determine very exactly what

11     was the importance of such college sessions and whether members of the

12     college took decisions from the purview of the Defence Department, and

13     this is why I ask you whether you, as a member of the college, did take

14     part in taking decisions which concerned SIS, military police, or the

15     Main Staff, or any other segment of the Defence Department which would be

16     outside your sector?

17        A.   No, I think that I did not have the right to take part in

18     decision-making about other sectors.

19        Q.   Tell us, please, whether any other participants at such a session

20     of the college had the right to decide on matters outside their purview?

21        A.   No.

22             MS. ALABURIC: [Interpretation] Thank you very much, Mr. Vegar.

23             Your Honours, I believe that I've remained within the limits of

24     the time that you allotted me.  And if you allow me, I have one technical

25     remark.  General Petkovic Defence team submitted an objection to the list

Page 37092

 1     of evidence tendered by the Prosecution through the witness Buljan.  Our

 2     objection was given an IC number, 926, IC 926.  The objection referred to

 3     the lists coming from the Prosecution, which is P 924.  Since the

 4     Prosecution rectified their IC list yesterday and specified the correct

 5     number of the document that they want to be approved, then the Defence

 6     team of General Petkovic has withdrawn their objection and the IC number

 7     can be then released for another evidence.

 8             JUDGE ANTONETTI: [Interpretation] Very well.  Well, the Trial

 9     Chamber will check this later.

10             Mr. Scott.

11             MR. SCOTT:  Good morning, Your Honours.  It will take us a moment

12     to distribute the binders.

13             JUDGE ANTONETTI: [Interpretation] Mr. Scott, the binders have

14     been distributed.  Now you can begin.

15             MR. SCOTT:  Thank you, Your Honours.  And good morning to all of

16     you, to each of Your Honours.  Good morning to counsel.  Good morning to

17     everyone in and around the courtroom.

18                           Cross-examination by Mr. Scott:

19        Q.   Good morning, Mr. Vegar.

20        A.   Good morning.

21        Q.   My name is Ken Scott.

22             Sir, just to touch on this one topic very briefly again, in terms

23     of your position, it seems that it's come up several times, but just to

24     be absolutely clear:  Beginning on approximately the 31st of January,

25     1993, you became the head of what we have described in this courtroom in

Page 37093

 1     the last couple of days as the Moral Guidance or Moral Education Sector

 2     of the HVO Department of Defence; correct?

 3        A.   The Sector for Moral Guidance, yes.

 4        Q.   And even though you did not receive an official appointment until

 5     sometime, I believe, around the 27th of August, there's no disagreement,

 6     I don't think, that from the end of January until sometime when you left,

 7     I believe in the summer of 1994, you continued in the position as head of

 8     that sector; correct?

 9        A.   Until 1993, towards the end of 1993.

10        Q.   All right.  Well, that will suffice for now.  And there were

11     times, if I understood your testimony, sir, in the last day or two, there

12     were times where the terminology "IPD" might be used by you, perhaps by

13     others, and in documents, to refer not only to the specific section by

14     that name, but to what the -- the Department or Sector of Moral Guidance

15     more generally; is that correct?

16        A.   Apart from the official title, Moral Guidance Sector, we used

17     also the Information and Psychological Activities.  That's IPD.

18        Q.   All right.  And at least until November of 1993, again just to be

19     abundantly clear, your immediate superior, if you will, you would

20     directly report to Mr. Bruno Stojic; correct?

21        A.   Yes.

22        Q.   Now, I'd like to touch again -- as the Chamber probably knows by

23     now, I'm a bit of a stickler for locations, dates, and times, and I'd

24     like to go to the question of locations.  Counsel took you through, at

25     one point, various locations of your offices and of the offices of the

Page 37094

 1     Department of Defence.  If I heard you correctly, sir, I think I heard

 2     you say at one point that in the summer of 1993, the Department of

 3     Defence moved to some other building in Mostar, the one -- a different

 4     building than the one it had apparently occupied in the spring.  Now,

 5     maybe I misunderstood, but sometime during the summer of 1993, the

 6     Department of Defence, including your office and Mr. Stojic's office,

 7     moved to another location in Mostar?

 8        A.   Yes, it was relocated.

 9        Q.   And when was that, sir, and where?  Where was the new location?

10        A.   It was in the summer of 1993, and the location was in Mostar, but

11     further away from the delineation line.

12        Q.   Okay.  Well, I'm going to press you a bit more on both aspects.

13     When you say the summer of 1993, do you recall whether it was in June,

14     July, or August?

15        A.   I cannot recall specifically.  Most probably in July.

16        Q.   And when you say you moved to another location in Mostar, can you

17     help us as much as you can, sir, to give us the name of the building, the

18     street address, the closest major intersection?  Just assist us, please,

19     as much as you can so that in future we'll know the location of that

20     particular office.

21        A.   I'm in two minds, whether -- do you ask me about locations where

22     I was located or the Main Staff of the Defence Department?  Which

23     institution do you want me to tell you about?

24        Q.   Apologies to the interpreters.  Let me come to those things in

25     turn.  At the moment, I'm talking about the Department of Defence in

Page 37095

 1     general.  Well, when I say the "Department of Defence," the headquarters

 2     or senior management offices, if you will, if I can describe it that way,

 3     that included Mr. Stojic's office.  So the question I'm asking you now

 4     is:  In the summer of 1993, you've indicated that the Department of

 5     Defence moved its management offices.  You think that was most likely in

 6     July.  Can you give us, please, the approximate location of that office

 7     after you moved -- after the office moved in approximately July?

 8        A.   I think there were locations found out of necessity.

 9        Q.   All right.  Sir.  What we're looking for is the location, a

10     street address, a building name, the closest major intersection.  That's

11     what I'm looking for, please.

12        A.   It was at Cim, but I'm not sure.  The settlement of Cim, but I'm

13     not sure.

14        Q.   All right.  Can you spell that for the -- just so the record is

15     very clear, when you say "Cim," in the transcript it's just been spelled

16     C-i-m.  Is that correct?

17        A.   That's correct, C-i-m.

18        Q.   Now, let me turn to the second aspect you said a moment ago,

19     which I had also intended to ask you.  Now, did there also come a time,

20     if I heard you correctly over the past couple of days, in the summer of

21     1993, where the offices of the IPD or the Morale or Moral Sector were at

22     a location different than Mr. Stojic's office?

23        A.   Yes, it was on another location.

24        Q.   When -- at what point did you move into two separate locations,

25     where your office was at one location and Mr. Stojic was at a different

Page 37096

 1     location, approximately?

 2        A.   In circumstances when it was too dangerous to remain in the

 3     building that we used to occupy, then.

 4        Q.   Sir, I haven't asked you the reasons why you moved.  I've asked

 5     you about the location.  When you did move, can you tell us when that

 6     was, when you went to a separate office than the one Mr. Stojic used, and

 7     the location of the moral guidance office once you moved to that

 8     location?  Here I'm talking about date and location.

 9        A.   I cannot give you the date because I don't recall.  I recall the

10     location very well.  It was on the avenue street, as it was called then.

11        Q.   And how far was that office, the office of moral guidance, at

12     that point from where Mr. Stojic's office was at that time?

13        A.   When he later left -- the Defence Department left the building

14     that I had left before, and they moved to a location maybe one or two

15     kilometres away.

16        Q.   Now, moving again to sources of education -- information, excuse

17     me, as counsel was just talking about a few moments ago, you told us that

18     at various press conferences and in the course of issuing press

19     statements, you received -- on the one hand, you received, and then on

20     the one hand you put out, if you will -- you distributed battle-field

21     information.  I think I heard you say something to the effect of casualty

22     reports, et cetera.  And my question again to you is:  Where did you

23     receive that information, talking about what was happening on a given

24     battle-field, what the -- how many people had been killed, how many

25     people had been wounded?  Where did you receive that information?

Page 37097

 1        A.   From the Main Staff.

 2        Q.   And who, in particular, at the Main Staff?  Because I'm going to

 3     ask you, in the course of the day, not just to tell us about the

 4     Main Staff generally, but I'm going to talk -- I want actual human

 5     beings.  So you said you received it from the Main Staff.  Who at the

 6     Main Staff did you receive the information from?

 7        A.   Of course, I could not get every time not -- to see the chief of

 8     the Main Staff or his deputy, but there was always somebody on duty at

 9     the Main Staff who provided that.

10        Q.   If the chief of the Main Staff or his deputy were available, I

11     take it that you received your information from them, based on your last

12     answer.

13        A.   Sometimes, yes, but more often than not I did not receive it from

14     them.

15        Q.   Well, here's what I'm going to suggest to you, sir, given just

16     human nature and the way most organisations work:  You were doing this on

17     a regular basis, and I suspect, if you'll allow me, that there was

18     someone there, there was a person you had more contact often than others;

19     there was a person that you normally would pick up the phone on a daily

20     basis or go across the street or whatever, a kilometre away, and collect

21     information.  So I'm putting to you, sir, there must have been some sort

22     of a more or less regular contact person at the Main Staff.  Who was

23     that?

24        A.   There was no such special person.

25        Q.   So if Mr. Praljak or Mr. Petkovic weren't available, then you

Page 37098

 1     just called a general number at the Main Staff, and whoever answered,

 2     that's who you talked to?  Is that what the Judges should understand?

 3        A.   I would either call or call on the Main Staff, but whoever was

 4     available at the moment.

 5             JUDGE ANTONETTI: [Interpretation] Mr. Praljak, what is the

 6     problem?

 7             THE ACCUSED PRALJAK: [Interpretation] Well, when my name is

 8     mentioned in terms of the distance between the Defence Department and the

 9     Main Staff, let it be precisely stated where the Main Staff was located

10     while I was chief of Main Staff.

11             MR. SCOTT:  Excuse me, Your Honour.  I'm going to take a very

12     active role in this, in terms of Mr. Praljak getting on his feet.  If

13     there's an objection, counsel can make legal objections.  There's no

14     reason for Mr. Praljak to make running commentary or give evidence by

15     standing -- by popping to his feet whenever he feels like it, so I reject

16     that participation.  I'm not going to take direction from Mr. Praljak.

17     If counsel -- if his counsel has a legal objection, then counsel can

18     certainly state that, and I'll certainly do my best to be guided by that.

19        Q.   Now, sir, you would receive, then, information from the

20     Main Staff, and when you received this information from whomever you

21     received it from, did someone have to essentially clear to you or

22     indicate which information could be disseminated and which could not?

23     And I'll take it further, sir.  Normally, when there's an ongoing, for

24     example, military operations, one does not disseminate all the detailed

25     information about where certain troops are located, what your combat

Page 37099

 1     plans are, so who would tell you, when going in -- when you were walking

 2     into a press conference or preparing a press release, who told you, This

 3     information can go out, this information should, of course, remain

 4     confidential?

 5        A.   I think I was clear yesterday when I said that nobody would

 6     specify that.

 7        Q.   So you could get up, sir, or you could issue a press release and

 8     you could say whatever you wanted.  You might divulge the -- you might

 9     divulge sensitive information, you might divulge the location of HVO

10     troops that were in -- actually engaged in combat operations at the time,

11     and no one would say, Well, that's not particularly helpful, sir, or that

12     sort of information shouldn't go out?  No one gave you that kind of

13     guidance?

14        A.   No.

15        Q.   Let's turn to Exhibit P 00601.  It will be probably in the first

16     binder, please, if we have that, sir.  And the binders will work

17     essentially, I think, similar to what you've seen from the various

18     Defence teams.  They should be, hopefully, in numerical order, and to the

19     extent there are Defence-marked exhibits, like 1D, or 2D, or what have

20     you, those will be separately listed probably in the second -- the back

21     of the second binder.

22             P 00601.  I believe you mentioned -- may have mentioned this the

23     other day.  Maybe I'm confusing it with another document by Mr. Rajic,

24     but I think we might have looked at this.  This is a document dated the

25     19th of October, 1992, from the Sector for Moral Guidance.  It appears to

Page 37100

 1     have gone out under the name of Bozo Rajic when he was the head of that

 2     sector.  I suggest to you, sir, and the Chamber that it provides a pretty

 3     good summary or overview of the work of that sector.

 4             Let me ask you to direct your attention, in particular, to the

 5     Roman numeral II, section Roman numeral II entitled "Work Plans, Methods

 6     and Means."

 7             Under item 1, "Information and Propaganda," it says:

 8             "Informing in units I see as a twofold and concurrent process:

 9     Incoming --" or excuse me, I'm sorry, "informing within units and

10     informing the public.  Both processes are of the same importance.  The

11     work should be carried out in such a way that the relevant facts,

12     occurrences, observations, information, objections, suggestions, or

13     requests are systematised two times a day at 1700 hours and 0700 hours,

14     in principle, submitted to the higher level of the service, IPD, for

15     compiling and submission, and then deliver the compiled information in

16     the shortest possible time to the highest level of the IPD in the units

17     so that the situation in the zone could be forwarded to the appropriate

18     administration of this sector."

19             Now, does that continue to be an accurate overview, if you will,

20     statement, of the work of the IPD in that respect, both in October 1992

21     and throughout the time in 1993 that you were part of that organisation?

22        A.   This is a -- describes an ideal situation which could not be

23     realised in real life.

24        Q.   In this next paragraph, it says:

25             "On the basis of the gathered reports, the Administration for

Page 37101

 1     Information makes a selection of the received information and decides

 2     which information, of what kind, and of which scope will be presented to

 3     the public through press conferences, announcements for public

 4     statements, commentaries, and other usual forms of public appearance."

 5             Sir, I asked you about that a few moments ago, and I suggested to

 6     you certainly there was some sort of screening or editing process which

 7     is described -- I put to you, which is described in the language I just

 8     to you a moment ago.  Now, who, in the IPD section, would make those

 9     determinations?

10        A.   At that moment, that is to say, while the assistant chief for

11     moral guidance was Bozo Rajic, he did that.

12        Q.   And after Mr. Rajic departed, that became your responsibility?

13        A.   Yes.

14        Q.   Now, the language I just read to you, and I apologise that the

15     paragraphs are not numbered, so it makes it a bit more difficult for me

16     to assist you, but if you -- the language we were just reading a moment

17     ago through press conferences, announcements, et cetera, if I can ask you

18     to skip two paragraphs, and you should come to a paragraph that says:

19             "Based on the collected and analysed information, the

20     administration will issue a daily bulletin."

21             And you said -- in among there -- and this also relates back to

22     something counsel asked about a few moments ago, "... it would also

23     contain other information related to activities, work, achievement of the

24     units and the civil authorities, the highest bodies of the HZ-HB and the

25     life of Croatian people."

Page 37102

 1             So what efforts can you tell me -- what information collection

 2     efforts, if you will, were engaged in to collect information from the

 3     highest bodies of the HZ-HB as part of your work and for distribution to

 4     the public and others?

 5        A.   I'm sorry.  I didn't understand the question.

 6        Q.   Sir, if you'll look in that paragraph I directed your attention

 7     to, skipping two paragraphs, it talks about also the collection and

 8     distribution of other -- other information, perhaps not strictly military

 9     or Department of Defence, but the civil authorities, including "the

10     highest bodies of the HZ-HB."  What information collection efforts were

11     there by the IPD to collect such information for distribution to the

12     public and others?  Sir?

13        A.   As far as I remember, we did not get the information.  In fact,

14     we did not receive the information from the highest bodies of the HZ-HB.

15        Q.   Well, let's -- let's take that up in the context of the next

16     language I'd like to point you to.

17             In that same paragraph, several lines down, there is a sentence

18     that continues on, saying this:

19             "... bearing in mind that the essential points of the state

20     policy, that is, the policy of the HZ-HB, be emphasised."

21             Now, what state policy is being referenced here?

22        A.   The state policy of Bosnia-Herzegovina, whose integral part was

23     HZ-HB.

24        Q.   Sir, in the parens, it says:  "That is the policy of the HZ-HB."

25     Do you see that?

Page 37103

 1        A.   Yes, I can see that, but I'm saying that it was the integral part

 2     of HZ-HB.  In fact, HZ-HB was an integral part of the state policy.

 3        Q.   And when you had any question about the policy of the HZ-HB as it

 4     impacted the work of your section, albeit the larger section, Moral

 5     Guidance or IPD, how would you determine the policy of the HZ-HB in order

 6     that your work could be guided and could bear in mind at all times the

 7     essential points of that policy?  How would you determine that?

 8        A.   I did not need to determine that state policy every day.  The

 9     policy was clear.  Its basic principles were constant, and I adhered to

10     that.  I answered a specific question based on specific information and

11     new facts that arose out of political talks, negotiations, agreements,

12     international conferences led by the representatives of the three ethnic

13     communities.

14        Q.   So on those particular occasions where you did have a question --

15     so you didn't always have a specific because you kind of knew what it

16     was, but when you did have a question, something came up and said, "Hmm,

17     I wonder what the state policy is on that," who would you contact and go

18     to for that information, to get an answer, to get guidance?

19        A.   I did not contact anyone.  I regularly followed, though, all

20     reports, all the conclusions from all meetings, primarily of the

21     president of the Croatian Community of Herceg-Bosna, Mr. Mate Boban.

22        Q.   Sir, you make it sound as if you conducted the operations of this

23     Moral Guidance Sector in a vacuum, in isolation, somehow just on your

24     own.  Now, I put it to you that simply can't be the case, sir.  You had

25     to take direction from your superiors, Mr. Stojic.  You had to have

Page 37104

 1     collected information from other, as it says in this document, highest

 2     bodies of the HZ-HB.  You simply weren't operating in a vacuum, sir.  Who

 3     were some of the people that you turned to for that information?

 4        A.   I'm telling you, with full responsibility, that as far as

 5     political positions are concerned, I never sought out any -- anyone to

 6     provide me with interpretation.  I always put out press releases and

 7     information based on something that already happened.  I did not

 8     anticipate anything or make any judgements in advance.

 9        Q.   We saw, in the course of your testimony so far, some documents,

10     and they were typically -- the ones we've seen so far have a date at the

11     top.  There would be a certain body of text, and following the text we

12     would see the capital initial -- initials "V.V."  Do you recall that?  Do

13     you recall documents like that?

14        A.   I have to admit I did not pay attention to this system of

15     numbering of documents.  I just looked for specific numbers.

16        Q.   Okay.  I'm not sure how that got garbled, but maybe I'll try it

17     again.

18             Sir, we saw documents that were apparently produced by you or

19     your section in the course of its business.  They would typically have a

20     date on the top of them.  They would typically have a certain amount of

21     text, and then they would be followed by the initials "V.V."  And I'm

22     saying "V.V." is your name, your initials, correct, "Veso Vegar"?

23        A.   Yes.

24        Q.   What were those kind of documents, how were they prepared, and

25     what was the purpose of those particular kinds of documents?

Page 37105

 1        A.   Depending on the contents of the document.  Mostly, those were

 2     press releases, statements made to some specific media.

 3        Q.   And who drafted those statements that said "V.V." on them?

 4        A.   In most cases, me.

 5        Q.   Let's go forward to 2D -- it will be in the second binder, toward

 6     the back probably, sir, 2D 01353.

 7             If you have that, sir, this is a 21 September 1992 document over

 8     the name of Milivoj Petkovic, directed to the Defence Department.  In the

 9     first paragraph, it says:

10             "Following a request of the HZ-HB Government for a report on the

11     implementation of the priority duties and tasks regarding the

12     establishment of the HVO Main Staff," et cetera.

13             Would you agree with me, sir, that this document was being

14     specifically prepared at the request of the HVO HZ-HB so that it could be

15     informed on the work of the Main Staff?  Do you see the language, sir?

16     Have I read it correctly?

17        A.   Yes.

18        Q.   And if we go to paragraph number 7, toward the end of the

19     document, over Mr. Petkovic's name, does it not say:

20             "With regard to providing the information for the public, the

21     GS," the Main Staff, "will forward reports of subordinated commands to

22     the IPD department so that it can prepare information for the public."

23             That information would have come to you or your section; correct?

24        A.   From what I see here, the Main Staff cedes reports, not makes

25     reports, so the Main Staff makes the reports available.

Page 37106

 1        Q.   Well, I'm not going to argue with you about that, sir.  It would

 2     involve -- paragraph 7 makes reference to providing information to your

 3     operation, correct, IPD?  Yes or no?

 4        A.   Yes.

 5        Q.   Would you please go next to Exhibit P 00518.

 6             JUDGE ANTONETTI: [Interpretation] Witness, just one minor detail.

 7     Under item 6 in this document, it appears that General Petkovic recalls

 8     that all the units in the HZ-HB territory are under HVO command.  No

 9     other unit will be allowed to act independently.  And then we have

10     parentheses.  The case is mentioned of the so-called Bregava Brigade.  I

11     have a question, therefore.  What does that mean?  Does this mean that

12     the so-called Bregava Brigade was acting somewhat independently?  Were

13     you aware of that or not?  If you weren't, just tell us so and we can

14     move on.

15             THE WITNESS: [Interpretation] I think the Bregava Brigade was the

16     brigade at Stolac, but I really don't know that it acted independently.

17             JUDGE ANTONETTI: [Interpretation] Very well, thank you.

18             Mr. Scott.

19             MR. SCOTT:  Thank you, Your Honour.

20             If we could go --

21             THE INTERPRETER:  Microphone, please.

22             MR. SCOTT:

23        Q.   If you could go, Mr. Vegar, to the next document, which is

24     P 00518.  This appears to be a report from Mr. Stojic to the HVO HZ-HB

25     the very next day, on the 22nd of September, 1992.  And, sir, if you can

Page 37107

 1     look at -- just scan through that document, please, and if you can recall

 2     generally what you saw in the previous document, which was the report

 3     from Mr. Petkovic to the Defence Department, and then we have this one,

 4     dated the next day, going from Mr. Stojic to the HZ-HB -- or HVO HZ-HB.

 5     Would you agree with me, sir, that essentially what Mr. Stojic passes on

 6     is largely, I'm not saying word for word - don't anyone suggest that I'm

 7     verbatim - but generally is passing on and incorporating the information

 8     received by -- from Mr. Petkovic the previous day; correct?

 9        A.   Sorry, am I supposed to -- in fact, I would need to read the

10     document before I answer that question.

11        Q.   We'll give you the time to take a look at -- to look at the

12     document briefly.  I'm not going to ask you in detail, but I'll suggest

13     to you, and I'll suggest in the interests of time in the courtroom, that

14     if you put the documents side by side, they're not the same, but they're

15     very similar.

16        A.   Yes, I can see the similarity.

17        Q.   Now, because our time is limited, sir, if I can just ask you to

18     go to a section in the second document, the 518 document.  In the

19     English, it will be on the fifth page.  In Croatian, sir, it will be the

20     third paragraph from the end.  So if you go to the last page or your last

21     item above the date, and if you work at -- yourself up, please, to the

22     third paragraph above, you'll see a paragraph that begins with:

23             "The Moral and Propaganda Sector have begun holding press

24     conferences every week on Tuesday and Friday."

25             And we don't have the time to read the entire paragraph, but it

Page 37108

 1     talks about radio and TV, reviewing the newspapers on a daily basis,

 2     issuing press releases, daily monitoring and analysis of the newspapers.

 3             "We will issue denials, make comments, or start polemics about

 4     certain issues whenever we find it necessary."

 5             Now, again, does that, generally speaking, state at the time and

 6     continue to describe, at least in substantial part, the work of the Moral

 7     Guidance and IPD Sector?

 8        A.   That's what the IPD was supposed to do.

 9        Q.   If we can go next to Exhibit P 01593 in binder number 1, P 01593.

10     You'll see that this appears to be an HVO document dated the 3rd of

11     March, 1993, issued over the name of Mr. Stojic and yourself, Veso Vegar,

12     directing the collection and provision of certain information.  Do you

13     see that?

14        A.   Yes, I see that.

15        Q.   "Submit the following documentation to the HVO Defence Department

16     in Mostar:  Film material; audio and videocassettes; photographs, books

17     and war issues of newspapers," et cetera.  "Your own and enemy propaganda

18     material.  Testimony by prisoners and detainees."

19             When it makes reference to sending your own -- when you and

20     Mr. Stojic directed these people to send your own and enemy propaganda

21     material, what kind of material was that?

22             Sir, I apologise but time is precious.  Can you tell us, please,

23     when you and Mr. Stojic said "send your own and enemy propaganda

24     material," what material did you want them to send you?

25        A.   Their own material that they developed themselves.  Let's focus

Page 37109

 1     on that.  It didn't have to be something targeted at the enemy.  It could

 2     have been the brochures that we distributed to the troops from the ICRC.

 3     It could have been information developed by IPD personnel for their own

 4     troops.  But I don't believe they had any enemy material or targeting the

 5     enemy.

 6             MS. PINTER: [Interpretation] I'm sorry, I think it is an

 7     interpretation problem.  It says in the original "your own and enemy,"

 8     enemy material.

 9             JUDGE ANTONETTI: [Interpretation] Please start again, because

10     there was a problem for a moment.

11             MS. PINTER: [Interpretation] I was about to say that it's the

12     problem of translation, in fact, the translation of this document.

13             In the original of the document, it says "your own and the

14     enemy's propaganda material."  It wasn't "your own enemy material."

15             MR. SCOTT:  The document appears to be correctly translated.  I'm

16     not clear -- not sure about the issue, but I appreciate counsel's effort

17     to assist.

18        Q.   Sir, because again our time is limited or I would ask more

19     questions about that, the next item that says "Testimonies by prisoners

20     and detainees."  Now, what did you and Mr. Stojic expect to receive in

21     terms of testimonies by prisoners and detainees, and why were you

22     collecting that information?

23        A.   Well, by that I meant statements of people who had been in camps

24     and information they could provide on how they had been treated there,

25     and the people who had perhaps remained in the camps, how they were

Page 37110

 1     treated, what health condition they were in, et cetera.

 2        Q.   If you'll go next, please, to P 02331 in the first binder,

 3     P 02331.  Sir, this is a document that we've seen before, and I believe

 4     counsel may have used it again in the last day or two.  It's dated the

 5     12th of May, 1993, a communication from Mr. Petkovic to Mr. Stojic.  And

 6     as counsel has previously pointed out, it's correct to say that the word

 7     "Order" on the middle of the first page should have been translated as

 8     "Request."  There's no dispute about that.  But what Mr. -- at least in

 9     terms of its going to Mr. Stojic, I mean.  But what Mr. Petkovic is

10     saying here is:

11             "The IPD shall, based on reports and information received from

12     all the operations zones, regularly and on time inform all HVO units

13     about events in the territory of the community.

14             "I suggest that this should take place at least once a day ..."

15             Now, the information that's being collected here referenced by

16     Mr. Petkovic.  Can you confirm to us, sir, that it was some of that

17     information, that kind of information, that would then find its way or

18     come to you and to the IPD for the purposes of conducting your various

19     work?

20        A.   I understand this request by Mr. Petkovic like this:  He believes

21     that the IPD section should regularly and in a timely manner inform all

22     HVO units, because I think he felt it wasn't being done properly, and

23     that's why he suggested that at least once a day one summary report

24     should be received by every unit.

25        Q.   But in producing the report, again, I guess the other side of the

Page 37111

 1     coin, so to speak, is the IPD would have to collect that information in

 2     order to prepare and distribute it; correct?

 3        A.   Yes, but it can only distribute information if it has

 4     information.

 5        Q.   Certainly.  If you'll go, please, to Exhibit P 03274.  P 03274 in

 6     the first binder.  This appears to be a document coming from Mr. Stojic

 7     on the 7th of July, 1993, a rather wide distribution of 10 -- 10 items in

 8     the list, starting with "HVO Chief of Staff."  And looking at the first

 9     paragraph, sir, do you agree with me that what this document does is

10     Mr. Stojic says to all these people:

11             "At its session on 5 July 1993, the HZ-HB HVO," that is, the

12     HZ-HB government, "adopted a conclusion that all HVO bodies should submit

13     their reports for the period between January-June 1993."

14             Correct?

15        A.   Correct.

16        Q.   And below that, it says at one point:

17             "The following officers are responsible for the implementation of

18     this conclusion:  HVO Chief of Staff Petkovic...," the assistant heads,

19     the chief of the Military Police Administration, the chief of the

20     Personnel Department and others?  Do you see that?

21        A.   I can see that.

22        Q.   And when such information projects were underway, it did often --

23     often also involved IPD, given the information business that you were in,

24     that part of the information to prepare such reports would come from IPD?

25        A.   Yes.

Page 37112

 1        Q.   I want to -- the courtroom will see that -- I think we saw most,

 2     if not all of these next couple of documents previously, but I'd like to

 3     revisit them briefly again.

 4             If you can turn, please, to 2D 00687 in the second binder,

 5     2D 00687.  Sir, this is a document dated the 24th of November, 1992, over

 6     the name of Mr. Petkovic.  I'm going to paraphrase it, if I might be

 7     allowed.  Everyone in the courtroom will have it.  But again as I think

 8     we saw before, it's Mr. Petkovic's attempt to impose controls on contacts

 9     with the media and information going to the media; correct?

10        A.   This is an attempt by Mr. Petkovic to prevent out-flow of

11     confidential information and provision of information by people who would

12     not be authorised to do so.

13        Q.   And item 3, in particular, specifically says:

14             "Press conferences are responsibility of the Defence Department's

15     IPD (Information and Propaganda).  All others within the zones,

16     headquarters, and formations can organise conferences based upon my

17     permission."

18             Now, when it refers to the Defence Department IPD, that's your

19     section; correct?

20        A.   Yes.

21        Q.   And if you can go to Exhibit P 00797 -- well, I'll tell you what.

22     Hopefully, this -- we'll skip them in order, because -- since you're

23     closer to the next one, to try to assist you in the courtroom.  If you

24     can turn while you're in the second binder to 2D 00637.  It should be

25     close by.  2D 00637.  This a document dated 20 September 1993, over the

Page 37113

 1     name of Slobodan Praljak:

 2             "I command:  All informations for the media about the situation

 3     at the battle-field will be exclusively approved by the Public Relations

 4     officer from HVO main staff --" excuse me, it doesn't staff, "HVO main

 5     headquarters," and among others it's distributed to Mr. Veso Vegar; do

 6     you see that?

 7        A.   Yes, addressed, delivered to.

 8        Q.   Sorry.  Is this not again a similar attempt by Mr. Praljak to

 9     impose, what I'll suggest, pretty strict control on contact with the

10     media by the HVO; correct?

11             MS. ALABURIC: [Interpretation] Your Honours, I have an objection

12     for misinterpretation of this document.  It is clearly seen from this

13     document that it goes for information about the situation in the -- at

14     the battle-field that doesn't concern other contacts with the media, so

15     I'd like to ask my learned friend from the Prosecution to be precise in

16     describing this document and its character.

17             MR. SCOTT:  I think I just read it in full a moment ago.

18        Q.   Sir, it's an effort to control the distribution of such

19     information quite strictly, isn't it?  One person, apparently,

20     exclusively approved by public relations officer of the HVO main

21     headquarters; correct?

22        A.   I must admit that many things are not clear to me regarding this

23     command, this order, the fact that public relations officer of the

24     Main Staff of the HVO is authorised to give information to the media

25     about the situation on the battle-field.

Page 37114

 1             JUDGE ANTONETTI: [Interpretation] Witness, isn't there a very

 2     classic conflict here in this document between those who are on the

 3     ground and those who are sitting comfortably in their offices?  Those on

 4     the ground seek to control media information, and this is a document

 5     coming from Mr. Praljak.  It is a very clear document.  It says that all

 6     the information has to be approved by the public relations officer from

 7     the main headquarters, and you are one of the addressees for information.

 8             If you compare this document with other documents from the

 9     Defence Department, you can see that here there is a conflict in terms of

10     power or competence.  What do you think of this?

11             THE WITNESS: [Interpretation] Your Honour, when you mentioned

12     people on the ground, let me, please, to finish my answer about the

13     locations of the Main Staff and the Defence Department.  I mentioned just

14     one location, asked by the Prosecutor, where we went to when we left the

15     main or the original locations.  There are two other locations of the

16     Main Staff, and this is why Mr. Praljak intervened as he did.  One was

17     five or six kilometres away from the original one, and the next at twenty

18     kilometres away in the town of Citluk.  And after -- shortly afterwards,

19     the date of this command, the location was 50 kilometres away, and I

20     believe that this is something the Chamber should know.  I can't remember

21     exactly.  This is September 1993, autumn.  I believe that the Main Staff

22     was reorganised around that time, but don't hold me to that, and maybe

23     this order is based on that reorganisation.

24             JUDGE ANTONETTI: [Interpretation] Your explanation comes from the

25     fact that locations were changed, and you date that back to the month of

Page 37115

 1     September.  Very well.  It's been recorded.

 2             The time has come to have a break.  Mr. Scott, a 20-minute break.

 3     We shall resume then.

 4                           --- Recess taken at 10.29 a.m.

 5                           --- On resuming at 10.53 a.m.

 6             JUDGE ANTONETTI: [Interpretation] We're resuming our session.

 7             MR. SCOTT:

 8        Q.   Mr. Vegar, we were looking at 2D 00637 a few moments ago, and I

 9     want to come back to that in a moment.  But before we get too far ahead,

10     I'd like to go back and ask you to look at P 00797, which is in the first

11     binder, P 00797.

12             This is a document which again I think we saw, but dated the 24th

13     of November, 1992, over the name of Milivoj Petkovic, ordering, and again

14     I'll paraphrase, that any contact be had with UNPROFOR and the European

15     Community members only with the permission by the chief of the HVO

16     Main Staff.  Do you see that?

17        A.   Yes, I can see that.

18        Q.   Sir, before going on to other points, wouldn't you agree with me

19     that when we look at the three documents we've last looked at, 2D 00687,

20     Mr. Petkovic's 24 November order about control over information going to

21     the media, this one, P 00797, and 2D 00637, the September order by

22     Mr. Praljak that we were also looking at a moment ago, there was an

23     effort from the top down to control the information going out to the

24     media and to the international agencies; correct?

25        A.   I think it goes for a desire to systematically order the area of

Page 37116

 1     information provision and not control in terms of prohibition.

 2        Q.   If you'll turn back to -- and I'm sorry to -- to everyone in the

 3     courtroom, but we'll need to go back, please, to 2D 00637, the Praljak

 4     order in the second binder, because there's a second point that I'd like

 5     to address, please.  2D 00637.

 6             Now, again, what Praljak says here is all information about --

 7             "All information for the media about the situation at the

 8     battle-field will be exclusively approved by Public Relations officer

 9     from HVO Main Headquarters."

10             Now, who was the public relations officer at HVO main

11     headquarters who would exclusively approve this information going to the

12     media?

13        A.   You mean at the Main Staff or generally in the Defence

14     Department?

15        Q.   Sir, this document, I'm reading -- you have the document in front

16     of you.  I've read it now to you twice.  It's very short.

17        A.   Yes.

18        Q.   "Public Relations officer from HVO Main Headquarters," so who was

19     that, when Mr. Praljak issues such an order referring to such a person?

20        A.   I really can't recall.

21        Q.   Well, sir, the only other individual that's copied by name on

22     this document is Veso Vegar.  You see that, don't you?  Yes?

23        A.   Yes, I can see that.

24        Q.   Sir, I'm going to put to you quite directly that at least for

25     most of 1993, if not all of it, you really were that person, weren't you?

Page 37117

 1     You wore both hats, if you want to put it that way?  You were the

 2     spokesperson for the Department of Defence and the spokesperson for the

 3     HVO Main Staff, weren't you?

 4        A.   No, I was just the spokesperson for the Defence Department.

 5        Q.   Tell us, sir -- give us the name of the person who fulfilled that

 6     function at the HVO Main Staff, if it wasn't you.

 7        A.   No, I really can't recall.  I don't recall who that person was.

 8        Q.   I put it to you again, sir, that the reasons you were saying

 9     earlier today that perhaps journalists might perhaps attribute to you the

10     position as spokesman for the Main Staff, or spokesman for the Department

11     of Defence, or spokesman for the HVO, is because, in fact, you did wear

12     all those hats, didn't you?

13        A.   Journalists attributed to me all those duties and posts, and for

14     the main part the reason for that is their ignorance of the structures of

15     the Defence Department and the HVO and the military structure.  They very

16     frequently mistook the Main Staff for the Defence Department and thought

17     it was one single body, which was not true.

18        Q.   During 1993, sir, in terms of the regional media, that is, the

19     media in the former Yugoslavia, Bosnia, Serbia, Croatia, et cetera, in

20     terms of the regional media, who were your principal media contacts in

21     carrying out your function as head of IPD and Moral Guidance?

22        A.   First of all, all correspondents who worked out of Mostar and

23     Herzegovina, meaning correspondents of the media based in Sarajevo, they

24     were the most numerous.  Then media correspondents from the Republic of

25     Croatia.

Page 37118

 1        Q.   All right.  Let me come back to some of those individual ones in

 2     a moment.  I'm not sure if we've explicitly, at least, referred to or

 3     clarified this.  In some of the documentation over the past couple of

 4     years, the courtroom has seen references to HINA, H-I-N-A.  That is the

 5     state press agency of the Republic of Croatia; is that correct?

 6        A.   Yes.

 7        Q.   And we may have seen or may see yet today a reference to

 8     something called Habena, H-a-b-e-n-a.  That was the public agency, news

 9     agency, press agency, if you will, of Herceg-Bosna; is that correct?

10        A.   Yes, this was the news agency of the Croatian Community of

11     Herceg-Bosna.

12        Q.   Who was the director of Habena?

13        A.   I think that Mr. Bozo Rajic was either the director or

14     editor-in-chief, but he was there in Habena.

15        Q.   And did that continue to be the case after Mr. Rajic left the

16     position as head of Moral Guidance, that you then took over, and did he

17     then go and become head of Habena at that time?

18        A.   No.  Habena did not exist at the time, only after a couple of

19     months while he was minister of defence of the Croatian Republic of

20     Herceg-Bosna, and then after a couple of months from that date, the

21     Habena agency was established.

22        Q.   So when you say "a couple of months," we're talking sometime in

23     March or April of 1993?

24             MS. NOZICA: [Interpretation] I apologise to my learned friend.

25     There is a mistake.  Like the day before yesterday, I would like the

Page 37119

 1     witness to state which position Mr. Bozo Rajic occupied when he left the

 2     post of the assistant to the head of the Defence Department.

 3             THE WITNESS: [Interpretation] He went to occupy the post of the

 4     minister of defence of the Croatian Community of Bosnia-Hercegovina --

 5     Herceg-Bosna.

 6             MR. SCOTT:  Counsel -- Your Honour, I'll clarify and ask.

 7     There's no dispute that Mr. Rajic left for a time and became the minister

 8     of defence of the Republic of Bosnia and Herzegovina.  That's correct,

 9     Counsel?

10             MS. NOZICA: [Interpretation] Thank you, my learned friend.  The

11     witness's answer is incorrect two times in a row, so an impression is

12     gained that he is not -- doesn't know what he's talking about in the

13     courtroom.

14             MR. SCOTT:  There won't be a dispute about that, at least from

15     the Prosecution.

16        Q.   Sir, if I can go back to the agencies -- not the agencies, the

17     outlets, if you will, which -- we are talking about the regional media

18     and you mentioned Sarajevo and you mentioned Croatia.  Can you give us

19     the names a few -- name a few of the -- like, for instance, the

20     newspapers, the regional newspapers that you had most of your contacts

21     and dealings with ?  And in the interests of time, sir, let me suggest,

22     did that include "Vecernji List," did it include "Slobodna Dalmacija"?

23     Did it include "Vecernji"?

24        A.   Yes, "Oslobodjenje" and so forth.

25        Q.   "Oslobodjenje" in Sarajevo?

Page 37120

 1        A.   Yes.

 2        Q.   And in terms of television, television stations, did that -- was

 3     your principal contact -- did it include, at least, Croatian TV,

 4     sometimes abbreviated HTV?

 5        A.   Yes, among others.

 6        Q.   Were there any other radio stations -- excuse me, television

 7     stations that you had more frequent or regular dealings with others --

 8     other than Croatian TV?

 9        A.   When technical circumstances allowed, Television Sarajevo would

10     work out of Mostar every day.

11        Q.   And as far as radio stations, would it be fair to say your

12     principal dealings were with Radio Herceg-Bosna in Mostar?

13        A.   Yes.  After its establishment in 1993.

14        Q.   Approximately when in 1993, sir, approximately?

15        A.   I can't remember precisely.  The autumn 1993.

16        Q.   We'll see a document that will give us that in a moment.  And any

17     other radio stations, apart from Croatia Radio, Herceg-Bosna, any other

18     radio stations that you had, again, more regular or more frequent

19     dealings with the connection with your work?

20        A.   Yes, two radio stations in Mostar, Radio Sarajevo, Radio Zagreb,

21     et cetera.

22        Q.   The two other stations in Mostar, can you give us the names,

23     please?

24        A.   One was Radio Mostar.  And it's a radio station that had existed

25     before the war in Mostar.  And the second and newly-established War

Page 37121

 1     Studio of Mostar.

 2        Q.   The so-called War Studio was, if you will, the alternative radio

 3     station established by the Muslims sometime during 1992/1993; correct?

 4        A.   Yes.

 5        Q.   Because of the clarification on Mr. Rajic's position, I'm

 6     reminded that we didn't actually get an answer on the question about

 7     Habena.  You had indicated that that was formed, I think you said,

 8     approximately two months after Mr. Rajic left his position at the HVO

 9     Department of Defence, and I was suggesting to you at the time of the --

10     we went into the clarification, two months would mean, then, that Habena

11     was formed sometime in approximately March or April of 1993; is that

12     correct?  Would you agree with me?

13        A.   I think it was later than that.  I believe it was towards the end

14     of 1993.

15        Q.   All right.  Well, again, perhaps we'll see documents that will

16     assist us.  Your initial answer was that it was a couple of months after

17     Mr. Rajic ceased being the head of the Moral Guidance Sector, which was

18     in January, but let's go on.

19             Now, I've asked you about the regional media, and let me ask you

20     about international media.  I take -- would it be fair to say that two of

21     your principal electronic media contacts were with, for example, CNN,

22     BBC; is that correct?

23        A.   I don't think so.

24        Q.   No?  How about newspapers?

25        A.   As I say, there were hundreds of foreign journalists.  I cannot

Page 37122

 1     highlight the main ones, so to speak.  There was "Daily Telegraph," "The

 2     Guardian," "Frankfurter Allgemeine Zeitung," "Sky News," among -- ITN

 3     among TV stations, then CNN and so forth.

 4        Q.   All right.

 5        A.   "Rajuno."

 6        Q.   Thank you, sir, for assisting on that.  Let me show you,

 7     just a -- very briefly, a video-clip, P 02157, which I think we can play

 8     in Sanction, P 02157.  It's very short, but just to illustrate the kind

 9     of press conference or appearance that might have occurred at the time.

10     This is from May 1993, I believe.

11                           [Videotape played]

12             MR. SCOTT:  Go back to the beginning of it.  It's fairly short.

13                           [Videotape played]

14             "The battle is being fought in the centre of Mostar, said a co-op

15     military spokesman who blamed the conflict on Muslim units who had come

16     to Mostar from Eastern Bosnia, upsetting the ethnic and military

17     balance."

18             MR. SCOTT:  Can we go back, please, can we go back to the

19     beginning and -- please.  Stop, please.

20        Q.   Sir, is that you giving a press conference in about May 1993 on

21     CNN or to CNN?

22        A.   Yes.

23             MR. SCOTT:  All right.  Since it's so -- just can -- now that

24     we've -- can you just play that again very briefly?

25                           [Videotape played]

Page 37123

 1             "The battle is being fought in the centre of Mostar, said a co-op

 2     military spokesman, who blamed the conflict on Muslim units who had come

 3     to Mostar from Eastern Bosnia, upsetting the ethnic and military

 4     balance."

 5             MR. SCOTT:  All right, thank you.

 6        Q.   Now, sir, was it also part of the information effort, if you

 7     will, information propaganda, I take it, each side would try to monitor

 8     the media communication -- media contacts and communication of the other

 9     side; is that fair to say?

10        A.   I have to remind you again of the technical limitations we faced

11     in following the work of the other side.  Of course, in wartime you

12     always want to hear what the other side thinks and tells, but my

13     technical facilities for monitoring that, and even the time, were

14     limited.

15        Q.   Let's go to Exhibit P 08115 in the second binder, P 08115.  Sir,

16     this appears to be a report or a note from the SIS on the 25th of March,

17     1994.  Subject:  Monitoring of the Mostar Radio War Studio broadcasting.

18     Now, you confirmed for us just a few moments ago that the Radio War

19     Studio was the Muslim radio in Mostar; is that correct?

20        A.   Yes, that was the radio station of the 4th Corps of the Army of

21     Bosnia and Herzegovina.

22        Q.   And you and your office, the IPD, in various documents I think we

23     showed this, sir, you worked quite closely from time to time with SIS,

24     the intelligence agency, didn't you?

25        A.   Not closely.

Page 37124

 1        Q.   And they were one -- but they were one of the organisations from

 2     which you received information; correct?

 3        A.   Yes.  Very rarely, though, because that's a service that gathered

 4     intelligence information, secret information.

 5        Q.   Now, why would the SIS, to your understanding -- why would the

 6     HVO authorities want information about the Mostar Radio War Studio's

 7     coverage of who the Muslim side considered to be the most notorious

 8     perpetrators of crimes against detained Muslims?

 9             Sir, why would the authorities want to know this information?

10     Please.

11        A.   I think that all authorities want to know what other media are

12     saying about them; in this case, the other side, the enemy side.

13             MS. NOZICA: [Interpretation] Your Honours, I believe it would be

14     a good idea if the Prosecutor first asked Mr. Vegar about the position

15     where he was when this report was made, and then we'll see if he was in a

16     position to know anything about it.

17             MR. SCOTT:

18        Q.   Sir, if we can go to Exhibit P 0 -- excuse me, P 10627, P 10627,

19     which will be in the second binder.  P 10627.  Sir, this is a report

20     concerning the work of Croatian Radio Herceg-Bosna, dated the 27th of

21     September, 1993, and if you look at the document, I think in the second

22     paragraph on the first page, I think you'll see then this -- relating to

23     one of the questions we discussed earlier, the broadcast of the programme

24     started a month before the anticipated dead-line, i.e., on 14 May, 1993.

25     So does that refresh your memory as to when Croatian Radio Herceg-Bosna

Page 37125

 1     went on the air?

 2        A.   Yes.  Well, I thought I remembered it was a bit later, but --

 3        Q.   All right.  And if you can please go -- if you'll go to find, by

 4     way of a landmark, if you will, to paragraph 6.  I'm not going to ask you

 5     about paragraph 6, but if you can find paragraph 6.  And for the English

 6     speakers or readers, the second -- page 3, second paragraph.  Sir, you

 7     should find a paragraph that starts with these words:  "The total

 8     programme orientation, editorial policy, and programme scheme ..."

 9             Tell me when you have found that, please.  The first paragraph

10     under paragraph numbered 6:  "The total programme orientation ..."  Do

11     you have it?

12        A.   Yes, I can see that.

13        Q.   "The total programme orientation, editorial policy, and programme

14     scheme are defined by the basic documents of the Croatian Republic of

15     Herceg-Bosna, with an emphasis on presenting the survey of the activities

16     of the official bodies," HVO Main Staff, soldiers, refugees, et cetera.

17             Skipping down one sentence:

18             "One can state that the defence of the area of Herceg-Bosna is

19     very much present in the programme of the Croatian Radio of Herceg-Bosna

20     through the statements issued by the Main Staff."

21             That's a fair description of the work of the radio station, isn't

22     it?

23        A.   Yes, but there's a mistake here.  There were no press releases

24     from the Main Staff.  It's repeated again, this confusion that I

25     mentioned between the Main Staff and the Defence Department.

Page 37126

 1        Q.   Just so the record is clear, sir, this isn't a foreign

 2     journalist.  This is an HVO document.  That's apparently what Mr. Srecko

 3     Vucina, management board of the radio station, apparently thought that

 4     they were issued by the Main Staff; correct?

 5        A.   I don't see the name of the author of this report.

 6        Q.   If you look at the last page, sir, I think you'll see

 7     Mr. Vucina's name, and another name, Zlatko Prlenda.  But in any event,

 8     sir, the paragraph I just referred to --

 9        A.   I suppose it could be Zlatko Prlenda, because he was the director

10     of the radio, but this radio was not part of the military structure of

11     the HVO or the Defence Department, where I was.

12        Q.   The next paragraph, sir, you will see -- the one that we just

13     referred to, it says:

14             "One should particularly single out the fact that a large number

15     of information from all battle-fields, as well as the information from

16     Herceg-Bosna in general, have been broadcast to the whole world by the

17     London BBC (which takes over the Croatian Radio of Herceg-Bosna's news

18     programme one to four times a day ..."

19             And then also goes on to talk about the cooperation and

20     distribution through HINA, the Croatian state news agency.  Those are

21     both correct statements, aren't they?

22        A.   Yes, BBC certainly took over some programmes, for a long time

23     even after the war, I believe.

24        Q.   Could I ask you, please, to turn to Exhibit P 05551, 5551, just

25     ever so briefly.  Sir, this is the record of the minutes -- the English

Page 37127

 1     translation is wrong on the date.  It should be the 1st of October, 1993,

 2     rather than "March," and the date under the -- in the phrase "convene"

 3     should also say "on 4 October 1993."  I apologise for the error.  But,

 4     sir, in reference to the document we were just looking at, if you look in

 5     this agenda, item number 9, I think that you will see that

 6     Mr. Jadranko Prlic had put, as agenda item 9:

 7             "An examination of the report on the performance of work and task

 8     to establish and set in operation Croatian Radio Herceg-Bosna," which is

 9     the report which is marked as Exhibit P 10627 that we were just looking

10     at.  Do you see that?

11        A.   Yes, I do.

12        Q.   Sir, when we were -- when we first began your testimony on

13     Monday, and you were questioned about what you were doing, your

14     profession as a journalist, I think it was one of the Judges, perhaps it

15     was the President, but in any event you were asked about what you were

16     currently doing, and I believe at one point you said -- you were talking

17     about being a journalist, but you said you were retired?  Did I hear you

18     correctly or is that a misunderstanding?

19        A.   Yes.

20        Q.   And so do we understand correctly, sir, that you're not presently

21     involved in any -- engaged in any form of employment or means of making a

22     livelihood?

23        A.   No regular income, except for my pension.

24        Q.   And do you have irregular sources of income, then; consulting

25     fees, work on behalf of political parties, media consulting?

Page 37128

 1        A.   I don't have compensation, but I work as a consultant and I am

 2     engaged in a political party.

 3        Q.   What kind of consulting work do you do?

 4        A.   I lead an office in a political party, the information office.

 5        Q.   And what political party is that, sir?

 6        A.   HDZ 1990.

 7        Q.   How long have you been involved with that party, sir?

 8        A.   Around two years.

 9        Q.   What political party were you involved in prior to that, prior to

10     approximately 2007, two years ago?

11        A.   I did not work in political parties before, but I worked in the

12     electoral campaign of the HDZ BH in 2002.

13        Q.   And were you a member of that party, sir?

14        A.   No.

15        Q.   Were you a member of the HDZ party in the Republic of Croatia?

16        A.   No.

17        Q.   I'm still -- I'm just a little curious, sir, because on the first

18     day of your testimony, you gave what Judge Trechsel also observed was a

19     rather odd and qualified answer.  When you were asked about whether you

20     had ever been a member of the HDZ, you said:

21             "If you mean the BiH, my answer is no."

22             And to my way of thinking, sir, you never really gave a clear

23     answer of what you meant by that.  So if you were not a member of the

24     BiH, were you a member of some other political party at that time?

25        A.   Yes.  Now I am a member of the HDZ 1990.

Page 37129

 1        Q.   How about in 1993/1994?

 2        A.   I was not a member of any political party then.

 3        Q.   Well, now let's be clear here, because a few moments ago you made

 4     the distinction between being a member of a party and working for a

 5     party.  So in 1993/1994, maybe you weren't the member of a party, but

 6     were you engaged in activities in connection with -- on behalf of a

 7     party?  Did you work for a political party at that time?

 8        A.   No.

 9        Q.   I don't want to play word games with you, sir, about whether it

10     was employment or something else.  Were you associated with a political

11     party in 1992, 1993, 1994, in any aspect?

12        A.   No.

13        Q.   Sir, I put to you that you've worked quite hard these last few

14     days to portray yourself as something of a technocrat, but the reality

15     is, sir, you've been closely and actively involved in Croat nationalist

16     politics since at least 1992, haven't you?

17        A.   I was not involved in Croat nationalist politics, and at the time

18     of the war and in the post-war years, I was not a member of any political

19     party.  If you ask me about party activities, I was a member of the HDS

20     party from 1990, when HDS was established in Zagreb, and then in Bosnia

21     and Herzegovina, but with the end of the war this party ceased to exist,

22     it stopped to be active and is not active today, so that in that year, my

23     party activities ceased.

24        Q.   When did you obtain your Croatian citizenship?

25        A.   In 1993, I think.

Page 37130

 1             JUDGE ANTONETTI: [Interpretation] Witness, one minor problem.

 2     Line 2 on page 47, you said that you were a member of the HDZ in 1990,

 3     and now, on line 22, page 47, you said that you were a member of a party

 4     called "HDS."

 5             MR. SCOTT:  If I can be allowed -- if I can be allowed to assist.

 6             JUDGE ANTONETTI: [Interpretation] Sir, is it "HDZ" or "HDS"?

 7             THE WITNESS: [Interpretation] HDS.  I was a member of that party

 8     in 1990.

 9             MS. NOZICA: [Interpretation] I'm sorry.  The answer of the

10     witness was not recorded in full.  The witness said that in 1991, his

11     engagement, even in that party, ceased.  I think that should be on the

12     record.

13             MR. SCOTT:  And can I also -- sorry.

14        Q.   Can I also clarify, Witness.  Perhaps this may be a source of

15     confusion; maybe not, but let me try.

16             When you say you were a part -- you were a member of a party, HDZ

17     1990, that's the name of the party; correct?  It's not the date of your

18     membership.  There is a political party now in Bosnia-Herzegovina called

19     "HDZ 1990"; correct?

20        A.   Correct.

21        Q.   Now, you said a moment ago that you obtained your Croatian

22     citizenship in 1993.  Can you tell the Judges how you made your

23     application and where you submitted your application for Croatian

24     citizenship?  Was that in Mostar?

25        A.   I think it was in Mostar, but I don't really remember.  And if I

Page 37131

 1     applied, I didn't apply only for myself, but for my family as well.

 2        Q.   And going back to your political involvement, you say -- you say

 3     you haven't been a member of HDZ, but Mr. -- there's a man named

 4     Mr. Jelavic who has been an actively involved, one of the leaders of that

 5     party in the second half of the 1990s; correct, Mr. Jelavic?

 6        A.   Yes, that's true.

 7        Q.   And you have been, at various times, a very close adviser and

 8     associate of Mr. Jelavic, haven't you?

 9        A.   Correct.

10        Q.   You were -- did you receive payment from Mr. Jelesic or --

11     Jelavic, excuse me, or the party for the work that you did?

12        A.   No.

13        Q.   All right.  But just so we can be clear here, because that goes

14     back to why I was asking these questions a few minutes ago, sir:  So

15     you've told the Judges and you've left the impression that you haven't

16     been associated with the HDZ, and yet you were an adviser to the leader

17     of the party, weren't you?  Correct?

18        A.   Yes, and there were other people, his advisers, that were not

19     members of the HDZ.

20        Q.   Now, when you left your position at the Department of Defence and

21     went to work to "Slobodna Dalmacija," in about December of 1995 you

22     conducted an interview with a man named Vladislav Pogarcic, didn't you?

23        A.   Possibly, because I did many interviews.  Maybe with him too.

24        Q.   Let's look at Exhibit P 08623 in the second binder, P 08623.

25     08623.  It should be in the second binder.  If it's not, can we go to

Page 37132

 1     e-court, please, to try to save time, please.  My apologies if there's a

 2     problem.

 3             Sir, while we're looking for that, I'll represent that -- the

 4     Chamber has seen this before.  It won't be new to the courtroom.  It is

 5     an interview that you apparently conducted while employed at

 6     "Slobodna Dalmacija," an interview on the 9th of December, 1995, with

 7     Mr. Pogarcic.  Now, because our time again is so limited, I would like to

 8     direct your attention and I'll direct the courtroom's attention in the

 9     English version in the -- toward the bottom of the second page.  And,

10     sir, if you can find a paragraph -- you asked a question -- you'll see

11     that there's references to the questioner and the speaker.  So you'll

12     see -- you'll see:  "Vegar, Pogarcic, Vegar, Pogarcic."

13             So if you find one of the "Vegar" entries where you say -- you

14     put this question to Mr. Pogarcic:

15             "Do you really think that the peaceful division of Bosnia is

16     possible?"

17             Do you see that?  Do you see it, sir?

18             "Do you really think that the peaceful division of Bosnia is

19     possible?"  Vegar.

20        A.   I don't see that question on the screen.

21        Q.   All right.  We'll just have to keep scrolling, I guess, unless

22     can we get anything else as a reference?  It's probably roughly halfway

23     through the overall document in most formats, I would think.  Or no, I'm

24     sorry, I wouldn't -- well, probably not.  Let me read this to you, sir,

25     and I'll read slowly and for translation, and I'm sure that the courtroom

Page 37133

 1     will correct me if I'm wrong.  You put that question to Mr. Pogarcic, and

 2     Pogarcic says:

 3             "Yes.  In fact, that possibility is the only clear result of

 4     these four years of war.  Remember how Bosnia was described at the

 5     beginning of the war as a 'leopard skin.'  Today, however, it is a

 6     country of three ethnic communities, each having its own

 7     strictly-delineated territory.  This might be thought to be ugly, there

 8     are people who are even disgusted by this, but they should know that it

 9     is the result of the will of the population itself.  The Serbs, Muslims,

10     and Croats have ethnically cleansed territories wherever they could

11     (meanwhile, it must not be forgotten that the Pandora's Box of ethnic

12     cleansing was forced open by the Serbs, although the two other nations

13     could not resist the temptation to take a look into it), until they

14     reduced the members of the other ethnic communities to 10 per cent or

15     less of the total.  With 10 per cent or less of the total, one cannot

16     threaten the political position of the majority, while simultaneously the

17     minority functions as an ornament and can even serve as proof of the will

18     to create a 'multiethnic society.'"

19             My question to you, sir:  Did you share that same view as

20     Mr. Pogarcic in those statements?

21        A.   I, as a journalist, do not necessarily have to share political

22     views, the political views of the person I'm interviewing.  I would not

23     agree with all these statements by Mr. Pogarcic, but I recorded them, as

24     he said that.  At that time, he was deputy foreign minister of the

25     Federation of Bosnia and Herzegovina, and I thought it was important for

Page 37134

 1     the readership to hear his thinking, and that's why I conveyed it.

 2        Q.   My apology.  In the early part of the passage that I read to you,

 3     let me just break it down into some smaller pieces, Mr. Pogarcic suggests

 4     that the division of Bosnia was "the only clear result of these four

 5     years of war."  Do you agree with that statement?

 6        A.   The war ended with the peace agreement that divided Bosnia and

 7     Herzegovina into two entities.  If that's what he meant, then he's right.

 8     All the rest are very debatable theories about ethnic cleansing, the

 9     percentage of an ethnic community can have in an area without threatening

10     the other ethnic community.  That maybe derives from something he read.

11     But, again, I have to say I don't have to share his positions, because

12     I'm not writing a commentary here.  It was an interview.

13        Q.   That's correct.  You don't have to, you're absolutely right, but

14     my question is whether you do, in fact.  And, for example, do you agree

15     with the statement that all the three ethnic parties, the Serbs, the

16     Muslims, and the Croats, all three had engaged in ethnic cleansing?

17        A.   No.

18        Q.   Do you believe the Serbs engaged in ethnic cleansing?

19        A.   Yes.

20        Q.   Do you believe the Muslims engaged in ethnic cleansing?

21        A.   This is a consequence of war.

22        Q.   And do you believe that the HVO, the Croats -- excuse me, the

23     Croats - to follow through with Serbs, Muslims, and Croats - do you

24     believe that the Croats engaged in Muslim -- in ethnic cleansing, excuse

25     me?

Page 37135

 1        A.   No.

 2        Q.   So everyone did, except for the Croats; correct?

 3             MS. NOZICA: [Interpretation] Your Honours, if I may.  The

 4     Prosecutor showed a passage to the witness, and we don't have the

 5     document in the binder; neither does the witness.  But when he highlights

 6     the question by the witness, is peaceful division of Bosnia possible, had

 7     the witness been in a position to read the article, he would have read

 8     the previous answer which preceded that question, and this was taken out

 9     of context.

10             JUDGE ANTONETTI: [Interpretation] Witness, would you mind

11     reading, in your own language, the sentence starting with "Zar mitlite"?

12     Read in your language the question there.

13             THE WITNESS: [Interpretation] "Do you believe that a peaceful

14     division of Bosnia is possible?"  Do you mean the question or should I

15     read on?

16             JUDGE ANTONETTI: [Interpretation] Just the question.  I ask this,

17     because in the text as translated into English, we have "Really," so does

18     that mean -- it seems as though it meant, "Do you really think that?"  So

19     in the English translation, it's more as a question.  But the way you put

20     the question in your language -- as you read it in your language is, you

21     don't have this qualification; is that right?

22             THE WITNESS: [Interpretation] I'm asking a question and putting

23     forward a thesis in that question which was present in the public domain

24     then and now.  The question of the public and the readership was that it

25     was impossible for Bosnia to be divided in a peaceful manner, so I'm

Page 37136

 1     asking this individual, Do you really think that a peaceful division of

 2     Bosnia is possible?

 3             JUDGE ANTONETTI: [Interpretation] Thank you.

 4             Mr. Scott.

 5             MR. SCOTT:

 6        Q.   Sir, if we could move off this document to P 10826, also in the

 7     second binder, P 10826.  Sir, this is an article -- a media article from

 8     Agence France-Presse from the 3rd of March, 2001.  In the third

 9     paragraph, it says this:

10             "Veso Vegar, an adviser to leaders of HDZ, the main nationalist

11     Croat Democratic Union, told Friday that an inter-regional council made

12     up of areas with a Croat majority would probably be set up, such a

13     council would have its own parliament and government, he said."

14             Do you remember giving interviews like that around this time,

15     March 2001?

16        A.   Yes, at that time I did issue statements to the press.

17        Q.   And at the end, the very last paragraph of this particular

18     article, says:

19             "The Croat member of Bosnia's Presidency, Ante Jelavic, who also

20     heads the HDZ, also said Wednesday that the federation was 'a Muslim

21     entity without Croats,' and the government was 'illegal and illegitimate

22     and we will no longer either participate or recognise it.'"

23             My apologies, apologies to the interpreters for being so quick.

24     Shall I repeat any of it?  I think it's -- thank you.

25             And did you agree with Mr. Jelavic on that assessment, that the

Page 37137

 1     current government structure at that time was, quote, "illegal and

 2     illegitimate" and the HDZ would no longer either participate or recognise

 3     it?

 4        A.   I'm sorry, but I have to provide a wider explanation.  We are

 5     entering a political debate.  Such statements and such assessments issued

 6     by Mr. Ante Jelavic then have been repeated all those years since 2001 to

 7     date.  They were deeply founded sometimes --

 8        Q.   I apologise to you, sir.  If my time was not more -- less

 9     limited, I would certainly be happy to get a longer answer, but my

10     question to you is:  Do you agree?  Do you share the assessment stated by

11     Mr. Jelavic in this article?

12             MS. NOZICA: [Interpretation] Your Honours, I object.  I do

13     believe that the witness should be allowed to explain why this happened.

14     If this is not allowed to him, then it's impossible for him to answer in

15     the way that the Prosecutor wants.

16             JUDGE ANTONETTI: [Interpretation] Listen, Ms. Nozica.  If the

17     Prosecutor puts the question in an infelicitous way, too bad for him.

18     Don't try to rescue him.

19             MR. SCOTT:

20        Q.   Sir, let me --

21             THE WITNESS: [Interpretation] I can explain this statement.  It

22     is short, it's taken out of context of the overall discourse of

23     Mr. Jelavic.  At that moment, and this was not solely Mr. Jelavic's

24     opinion, the government did not include representatives of the strongest

25     Croatian political party which was voted for by 70 per cent of the

Page 37138

 1     Croatian voters at the time, so that party and the people represented by

 2     that party did not have a representative in that government of the time,

 3     the HDZ BiH.  So the HDZ BiH did not have any representatives in the

 4     federal government, a political party which reached 70 per cent of the

 5     Croatian vote in Bosnia-Herzegovina.  The federal government was

 6     established then, which included ministers, representatives of some

 7     Croatian political parties, who received 29 votes in total in that

 8     election.

 9             MR. SCOTT:

10        Q.   I apologise to -- excuse me.  I apologise to the courtroom, but I

11     don't have time, unless the Chamber wants to give me more time to get

12     into how many seats each of the parties won during these particular

13     elections.

14             Now, let me go on, sir, to some other documents and perhaps it

15     will clarify these issues.  I'll be happy to address it further if the

16     time is provided for me to do so, but there is no such time at the

17     moment.  And I apologise to you, Mr. Vegar, for that.

18             But if you could please turn to Exhibit P 10828, P 10828.  It

19     should be very close by, the same binder.  Sir, around this same time in

20     February 2001, do you recall supporting the possibility of actually

21     withdrawing the credentials of two international diplomats, including the

22     US ambassador to Bosnia and the head of the OSCE mission to Bosnia,

23     because of their concerns about certain anti-Dayton activities by the

24     HDZ?  Do you remember supporting that position?

25             In this article, about halfway down, it says:

Page 37139

 1             "Veso Vegar, adviser to Bosnia Croat Presidency member Ante

 2     Jelavic, says he also supports the possibility of withdrawing credentials

 3     to the two men."

 4             Is that right?

 5        A.   Your Honours, I here must --

 6        Q.   Does it accurately state your position in 2001?

 7        A.   I cannot recall whether this opinion of mine was credibly relayed

 8     and whether I spoke to anybody from Associated Press.  I can confirm,

 9     though, that there were --

10        Q.   Let's turn to P 10827 and ask if you remember talking again to

11     Agence France-Presse.  10827.  It should be the immediately-preceding

12     document, the 2nd of March, 2001, the second paragraph:

13             "Led by the national Croat -- nationalist Croat Democratic Union

14     HDZ, some 600 Bosnian Croat officials will be asked to sign on to a

15     document on setting up a new council made up of Croats, said Veso Vegar,

16     adviser to HDZ leaders.

17             "An inter-regional council made up of areas where a Croat

18     majority would probably be established, Vegar said, adding that such a

19     council would have its own parliament and government."

20             Did you make that statement or a statement like that in March

21     2001?

22        A.   In March of that year, it is true that Croatian Peoples Congress

23     was held, but none of this that had been announced to -- that was

24     supposed to happen after that congress, no institutions of executive

25     power, no government was established.  I did issue statements, but

Page 37140

 1     whether this was my statement and whether it was credibly relayed, I

 2     don't know; although, I could have issued a statement that there will be

 3     an inter-regional committee.  It was announced in all the media and

 4     there's no doubt about that.

 5        Q.   At the end of that article, it says that:

 6             "Mr. Jelavic's criticism escalated at a rally Wednesday in

 7     support of Dario Kordic and Mario Cerkez who have been sentenced to

 8     prison by the UN war crimes tribunal for their role in the massacre of

 9     hundreds of Muslims between 1991 and 1994."

10             I'm just wondering, sir, did you attend that same rally with

11     Mr. Jelavic?

12        A.   No.

13        Q.   Did you ever attend any rally like that on behalf of any Croats

14     indicted by the ICTY, or attend any fund raisers for their defence, for

15     example?

16        A.   I don't recall I've ever done so.

17        Q.   And it was this same Mr. Jelavic that was then removed, because

18     of these activities, removed from the Bosnian, BiH Presidency by the

19     Office of the High Representative because of his anti-Dayton activities

20     later in -- I think later in the same month of March 2001, or if not,

21     then certainly by April; correct?

22        A.   Yes, he was removed from the Presidency of Bosnia-Herzegovina.

23        Q.   And did you continue to be a close adviser to Mr. Jelavic after

24     that time?

25        A.   What do you mean, "close associate"?  Well, yes, I maintained

Page 37141

 1     contacts with Jelavic for several months afterwards.

 2        Q.   Did you continue to be an adviser to him in any capacity after he

 3     was removed from his position?

 4        A.   No, formally I could not be his adviser, because I also resigned

 5     my post in the Presidency.  It was only logical, because I no longer had

 6     anyone to advise there.

 7        Q.   What post did you hold in the Presidency at that time?

 8        A.   Adviser for culture and education.

 9        Q.   And you held that position as a part of Mr. Jelavic's government,

10     if you will?

11        A.   No, at the BiH Presidency, while he was a Croat member of the

12     Presidency of Bosnia-Herzegovina.

13        Q.   And you're saying when he was removed, you also left that

14     position; correct?

15        A.   Yes, 10 or 15 days afterwards.

16        Q.   If you can go, sir, to Exhibit P 04626 in the first binder,

17     turning to a different topic, P 04626.  It may not -- if it's not in the

18     binder, I think it was used yesterday by the Defence, so again I might

19     have to ask for the assistance of the e-court.  My apologies.  It was in

20     one of the Defence bundles, P 04626.  It is the -- it may not be that we

21     even need it.  It's so fresh in everyone's mind that perhaps the

22     courtroom will remember.

23             Sir, this was the HVO IPD document which was dated the 17th -- my

24     apologies, which was document number -- issue number 59, which you told

25     the courtroom you thought it was a bad joke.  Do you remember that?

Page 37142

 1        A.   Yes, very bad joke.

 2        Q.   And when do you recall first having seen that document?

 3        A.   This is a document, a bulletin, number 59.  I saw some -- I read

 4     some, but I could not read all of them, and I can't recall when I saw

 5     this first.  I really can't recall.

 6        Q.   Let me explore it with you, sir.  It obviously -- according to

 7     what you've told us in the courtroom, you suggest that it made quite an

 8     impact on you.  You thought it was improper.  Provided you read it at the

 9     time, what action, if any, did you take to respond to this IPD officer

10     who was in your chain of command, to the effect of, "Hey, that's not

11     really appropriate, take some action about that"?

12             MS. NOZICA: [Interpretation] Your Honours, I've already noticed

13     this, that the Prosecutor claimed that this was an IPD document.  No,

14     this is a document of the OZ South-East Herzegovina, as it's stated here,

15     so it should be precisely stated, so in terms of hierarchy and what the

16     witness could have done about it in the chain of command.

17             MR. SCOTT:  Excuse me, Counsel.  Your Honours, it was covered in

18     the testimony on the first day, or maybe yesterday -- yesterday, at

19     pages 19 and 21, Mr. Vegar testified, "I do know the IPD published a

20     document, the Operative Zone of South-East Herzegovina."  This is

21     number 59, IPD.

22             And I believe it was Ms. Alaburic who showed us -- among others

23     who may have showed us an organisational chart of IPD, and all those IPD

24     units were subordinate to Mr. Vegar, and I put that as the proposition to

25     him.  And that's what leads me to my question -- if I could just finish

Page 37143

 1     my submission first, and then I'll sit down.  That's why I put to the

 2     witness that if he says this is such a bad joke, what action, if any, did

 3     he take to deal with it, if he can assist us.

 4             THE WITNESS: [Interpretation] I will give you two answers.  First

 5     of all, I did not have this in my hands and I did not read it then.

 6             The other thing, I could not have done anything specific and

 7     officially against the authors of this bulletin of the IPD of South-East

 8     Herzegovina because I could not order them anything.

 9             MR. SCOTT:

10        Q.   Sir, you testified yesterday --

11             THE INTERPRETER:  Microphone, please.

12             MR. SCOTT:  My apologies.

13        Q.   Sir, you testified yesterday at pages 103 and 104 of the

14     transcript -- you were asked about the chain of command of the IPD, and

15     you gave this answer:

16             "Apart from their own commander, they were in communication with

17     employees of the IPD, IPD personnel at levels superior to their own, up

18     to the assistant chief of the Defence Department Sector for

19     Moral Guidance."

20             That was you, sir, that was you.  So the person who issued this

21     document was directly in your chain of command, and if you thought this

22     was such a bad joke, sir, what, if anything, did you do to discipline or

23     correct the person who issued it?

24        A.   I must also say something that I said yesterday.  I said that

25     assistant commanders for IPD were subordinated to their commander.

Page 37144

 1     Second thing:  They were not in my chain of command.  There I said in

 2     contact, in communication through the operation zone and the sector in

 3     the Defence Department.  The third thing:  I did not read this then.  Had

 4     I had the powers to command or sanction, I could not do it, because that

 5     problem did not reach me.  I was not aware of it, and I could not have

 6     done anything about it.

 7        Q.   Sir, because of the time, I only have one more question on that

 8     topic, and that is:  To your knowledge, if not by you, did you know then

 9     or did you ever learn later that the person who issued that press release

10     or document which you say is a bad joke, was that person ever admonished,

11     fired, punished, by any HVO authority on the inappropriateness of his

12     conduct?

13        A.   I don't recall that he was.

14        Q.   If we can turn to 2D 01316, 2D 01316 in the second binder.  Sir,

15     this is a public announcement dated the 12th of June, 1993, and based on

16     some of your answers in the examinations on Monday and Tuesday, I'd like

17     to just ask you a couple of things.

18             In the second paragraph, it says:

19             "There were a few attempts of infantry attacks.  These villages

20     find themselves completely surrounded and if forces of UN do not enter

21     those villages soon, there will be mass slaughter and massacre of the

22     civilians."

23             In the -- at the last paragraph -- at the last paragraph of the

24     document, and again we don't have time, unfortunately, to go through all

25     of it, it talks about the same roads used by Muslim women and children to

Page 37145

 1     run from Serbs are now full of Croat women and Croat children running

 2     from the Muslim knife.  Now, do you think that kind of language was

 3     intended to have a calming-down influence?

 4        A.   The wording is in keeping with the dramatic situation.  I would

 5     not have done -- I would have used such words if I had written it, most

 6     certainly, but the suggestion was of general threat to the survival of

 7     those people in that area, and such grave words should not surprise us at

 8     all in the light of that.

 9        Q.   Well, let's turn next to 2D 1309, which was shown to you

10     yesterday, I believe, or perhaps the day before, but in any event the

11     last couple of days.  And let me just say, sir, for the record and so

12     that you don't think that I'm not recognising the situation.  As I've

13     said before, some of these events, there were indeed some terrible events

14     that happened with Croat victims, which have my complete condemnation.

15     There's no question about that.

16             But if you look, please, sir, at 2D 01309, I asked you earlier,

17     sir, about these so-called "V.V." documents, and these appear to be

18     documents that you prepared or at least put your initials to.  And

19     looking at the first one, in the second paragraph, there is, among other

20     things, this language:

21             "Muslim criminals took pleasure in torturing helpless elderly,

22     women, and children --"

23        A.   I'm sorry, but I don't have the document.

24        Q.   I apologise.  2D 1309.  Sorry, sir.  I thought you had it.  It

25     may be in the Stojic -- excuse me, Your Honour, again I was drawing on a

Page 37146

 1     couple of these on the Defence binder.  My apology.  I believe it's in

 2     one of the Stojic binders or bundles.

 3             While they're doing that, Your Honour, to save -- hopefully save

 4     time again, I may also be referring to 2D 00648, which was also used by

 5     the Stojic Defence yesterday, I believe, if people want to also be

 6     finding that, and I apologise for the additional effort.

 7             Do you have 2D 01309 now, sir?  Sir?  Or in e-court?  2D 01309,

 8     do you have it?  If I can direct your attention, please, sir, to the

 9     second paragraph on the screen in the Croatian language version in front

10     of you.  I believe in that paragraph is the phrase:

11             "Muslim criminals took pleasure in torturing helpless elderly,

12     women and children... another Croat from Zuka's unit was murdered by

13     decapitation, after which his head was thrown in the Neretva.

14             "Sefer Halilovic and Rasim Delic, highest commandants of the

15     Muslim army, knew of the massacre and sent cigarettes to those who

16     committed it as a reward."

17             Now, once again, sir, these phrases and this information, first

18     of all, where did you obtain the information?  When you issued -- when

19     you prepared this document, where did you get this information that you

20     based it on?

21        A.   These information did not come from official sources, but came

22     from a source which I trusted, and unfortunately many information from

23     this report were proven to be correct.

24        Q.   And the statement that Mr.  Halilovic and Mr. Delic knew of the

25     massacre and sent cigarettes to those that committed it as a reward,

Page 37147

 1     what's your source of information for that statement?

 2        A.   I heard it from people who managed to flee that area and who saw

 3     Mr. Sefer Halilovic in Jablanica at the time.

 4        Q.   And when you wrote this, and then you -- going on down, there's a

 5     series of these -- the 25th, there's a second one, there's one for the

 6     24th, one on the -- two on the 24th, perhaps.  Again, did you write these

 7     with the -- with the concern in mind that they might have an inflammatory

 8     effect on those who might receive and read them?  Sir?

 9        A.   My duty was to inform about this tragic event.  Of course, one

10     should be mindful of possible consequences, of course, but at the time,

11     at the time when we heard every day news about tragic events,

12     unfortunately such bad news did not have consequences that they would

13     have in normal times.  It was just another bad crime, and it did not

14     elicit a reaction of those who were supposed to prevent such crimes.

15        Q.   If you go last on this topic to 2 -- also, and I mentioned it a

16     moment ago, if we could find 2D 00648 --

17             JUDGE ANTONETTI: [Interpretation] Please, may I ask you two brief

18     questions.

19             How did you know that Halilovic and Delic had thanked the

20     perpetrators of those crimes by giving them cigarettes?  How did you know

21     about that?

22             THE WITNESS: [Interpretation] I heard it from people who escaped

23     from that area.  They were lucky to be able to escape.  They saw

24     Mr. Halilovic several days after the massacre, and that was the story

25     that circulated around Jablanica.  At that time, cigarettes were very

Page 37148

 1     precious.

 2             JUDGE ANTONETTI: [Interpretation] All right.  So the person who

 3     gives the information had seen Mr. Halilovic handing out packs of

 4     cigarettes to the soldiers?

 5             THE WITNESS: [Interpretation] No, she only saw Mr. Halilovic, but

 6     that was the information that circulated around Jablanica.

 7             JUDGE ANTONETTI: [Interpretation] All right.  Second question.

 8     I can see that you were talking about the women who were in the Museum of

 9     the Revolution, where things that you have written may have happened, and

10     I'm not going to -- what is alleged has happened, I'm not going to say

11     that again.  Did you grasp what consequences the fact of writing about

12     that would have on families, people who were worried?  Did you think

13     about that?

14             In one or the other assumption, either what you write is true or

15     it's not, but in both cases did you grasp the potential consequences it

16     would have on the families, on the neighbours, et cetera, or is it mere

17     propaganda?

18             THE WITNESS: [Interpretation] My first and foremost aim at the

19     time was to present facts, and I believe that the information is

20     unfortunately true concerning that massacre that happened, but also the

21     camp that existed in Jablanica, detaining mostly civilians, because there

22     were very, very few soldiers.

23             JUDGE ANTONETTI: [Interpretation] All right.

24             You may proceed, Mr. Scott.

25             MR. SCOTT:

Page 37149

 1        Q.   Sir, if we can just look briefly --

 2             THE INTERPRETER:  Microphone, please.

 3             MR. SCOTT:

 4        Q.   2D 00648, another one that was shown to you previously.  Again,

 5     sir, it's over your initials, and in part -- this is for the April 16th,

 6     and it says:

 7             "Over radio connections, they clearly tell Croats that they will

 8     be slaughtered and that this will be land 'Muslimanija'."

 9             Do you see that?  Do you see that, sir?

10        A.   I can't see it on the screen at this moment.

11        Q.   I can see it.  It's the bottom -- it's the last sentence above

12     your initials "V.V.," sir.  Do you see that?

13        A.   Yes, I see it.

14        Q.   Sir, because our time is so limited, can I just put this to you:

15     Isn't it correct, sir, that all sides, all sides, engaged in propaganda

16     and hate speech and inflammatory language in connection with the events

17     that were going on at the time, including the HVO, including sometimes

18     you, yourself, sir?

19        A.   I have to say again that I only presented the information and the

20     facts that I received, I put it on paper.  There is no expression of my

21     opinion, my comments, or any statements of mine.  This word

22     "Muslimanija," was used by the soldiers who looted the houses, burned

23     those villages, not by the person who relayed this information to me.  I

24     also did not have that word in my vocabulary, I didn't use it in my

25     reports.

Page 37150

 1        Q.   Sir, I'd like you to go next to -- changing topics, unless the

 2     Chamber has any questions on that, I'd like you to go, please, to P 10675

 3     in the second binder.  Yes, second binder, P 10675.  Sir, this is a

 4     compilation -- the Chamber has seen it before -- the courtroom has seen

 5     it before -- of four articles all written around early April 1993 -- ones

 6     that -- well, three are early, one is the 20th.  We have a 4 April

 7     article by Reuters.  We have a 6th of April article by

 8     Agence France-Presse.  We have a 7th of April article by the "Christian

 9     Science Monitor," and we have a 20 April article by the Financial Times.

10             And I'll just make it very clear to you, sir, that they all deal

11     with certain statements made by the HVO in April of 1993.  And let me

12     direct your attention, because time is short, specifically to the 6th

13     April Agence France-Presse article.  It will be the second article in

14     your bundle, please.

15             In the third paragraph from the bottom of that article, this

16     statement is made:

17             "A communique published on Monday by the Zagreb daily 'Vijesnik'

18     said the HVO had decided to force the Bosnians to implement the plan,

19     regardless of the Serbs.  'It is definitely an ultimatum,' said HVO

20     spokesman Veso Vegar, adding, 'We cannot wait indefinitely to put the

21     peace plan into practice.'"

22             That's what you told Agence France-Presse; correct?

23        A.   No, I didn't say this to the Agence France-Presse.  I never used,

24     in these statements, the word "ultimatum."  And I cross-checked this

25     through the media.  The Zagreb "Vijesnik" does not quote that statement

Page 37151

 1     of mine or that I gave anyone an ultimatum.  All that appeared in those

 2     days was a statement from the session of the Croatian Defence Council but

 3     during those days I did not give any statements, and I couldn't have

 4     given an ultimatum if there hadn't been one from the HVO.  I was not in a

 5     position to make decisions for someone else.

 6        Q.   Sir, I'm not suggesting or never intended to suggest that it was

 7     your personal ultimatum.  It was an ultimatum given by the HVO; correct?

 8     And that's what you're addressing; yes?

 9        A.   I couldn't have said that, because the HVO that not issued an

10     ultimatum either.

11        Q.   Excuse me.  Let's look back at the 4 April 1993 Reuters article.

12     About halfway through that article issued in Zagreb on the 4th of April,

13     you'll find this statement:

14             "'If Izetbegovic fails to sign this agreement by April 15, the

15     HVO will unilaterally enforce its jurisdiction in cantons 3, 8 and 10,'

16     the statement from HVO headquarters in the south-west Croat stronghold of

17     Mostar warned.  Croatian Radio said, 'Bosnian Croat chieftain Mate Boban

18     had already signed the proposed communique and the president's signature

19     was ''expected'' ..."

20             THE INTERPRETER:  Would you mind reading slowly.

21             MR. SCOTT:  My apologies, interpreters.

22        Q.   Sir, isn't that -- when someone says, If this doesn't happen,

23     something else is going to happen.  Now, the word "ultimatum" might not

24     appear in that particular passage, but isn't that exactly what it is?

25     If you don't do this, we are going to do this.  That's the definition of

Page 37152

 1     "ultimatum," isn't it?

 2        A.   Not in my understanding.  But I have to say again, I'm not here

 3     to interpret the positions expressed at the session of the HVO.  I

 4     understood that there was no ultimatum, and in my statements I could not

 5     have said to anyone that the Croats would do this and that if somebody

 6     does not withdraw, or that we would do anything to make them withdraw.

 7        Q.   Well, let's go to the 7 April 1993 "Christian Science Monitor"

 8     article, the third article in the bundle, the "Christian Science Monitor"

 9     for the 7th of April.  The third paragraph from the -- no, forgive me,

10     it's a longer article.  You will see, sir, and I'll simply read it to

11     you, and I will read slowly - for the English readers, it's at the bottom

12     of the first page - there's this paragraph, sir.  I'll read two

13     paragraphs to you:

14             "But Jadranko Prlic, the self-styled acting prime minister of

15     'Herceg-Bosna,' says the ultimatum reflects only HVO's intention to

16     implement the demilitarisation clause of the Vance-Owen Plan.  'We signed

17     the document and the Muslims signed the document, and it is one of the

18     real ways to overcome problems between Muslims and Croats,' he says.

19             "Mr. Prlic concedes, nonetheless, that the HVO ultimatum could

20     lead to bloodshed.  'We expect everything.  We don't want this struggle.

21     We don't have any reason for this struggle,' he says."

22             Do you see that, sir?

23        A.   Yes, I found it, I see it.

24        Q.   Is that an accurate statement of the HVO position at the time, at

25     least in part?

Page 37153

 1        A.   No.  I was not aware at that time that that was the HVO's general

 2     position.  I did not understand it that way.

 3        Q.   Well, sir, I put it to you that in the Agence France-Presse

 4     article that I put to you initially, and your statements about this being

 5     an ultimatum, "it is definitely an ultimatum," I put it to you, sir, that

 6     Agence France-Presse got it exactly right, and that is indeed what you

 7     said at the time, isn't it?

 8        A.   I don't think you're right.

 9        Q.   It is --

10             JUDGE ANTONETTI: [Interpretation] Witness, several months ago we

11     saw this document, and I had put the question to the witness then.  You

12     are a professional.  You know the AFP, you know the Reuters agency.  You

13     must know that when a quote is given of a sentence, that means that the

14     sentence was said by someone.  Now, this regards you, because you are

15     being mentioned in this story.

16             If I understand properly, there was a press release issued on

17     Monday by the Zagreb newspaper "Vjesnik" in which those sentences were

18     quoted, so I suppose you are at the origin of this press release.  The

19     Agence France-Presse only relays something that was published in

20     "Vjesnik"; is that right or not?

21             THE WITNESS: [Interpretation] Yes.  I said that I spoke to

22     "Vjesnik," but "Vjesnik" did not carry an ultimatum.  It only relayed the

23     information from the session of the HVO.

24             MS. NOZICA: [Interpretation] If I may be of assistance, please.

25     We have that "Vjesnik" issue of the 5th to which this article refers.  It

Page 37154

 1     contains neither the communique, nor the statement.  If you wish, if the

 2     Trial Chamber allows, we can provide this issue and put it in e-court

 3     during the break.  There's nothing to translate.  There is no communique

 4     and no statement in the "Vjesnik" issue of the 5th of April.

 5             JUDGE ANTONETTI: [Interpretation] Sir, you were ahead of me.  You

 6     knew what question I wanted to put to Mr. Scott.  I wanted to ask him how

 7     it was that the Prosecution did not try to find that newspaper to check

 8     that, and the Defence just told us that they have the press cutting and

 9     that the quotes are not present in that communique, so now it's on the

10     transcript.

11             Mr. Scott, you have a few minutes before the break.  In terms of

12     time, I'll tell you soon how much time you have left.

13             MR. SCOTT:  Your Honour, thank you very much.  I would appreciate

14     it, so that I can review and determine the use of the rest of my time.

15             Your Honour, I'd also remind the Chamber, with great respect,

16     that there was also additional direct examination time taken by several

17     of the other accused, and of course I will ask that that time be included

18     in the time that I have, since the Prosecution gets the same amount as

19     direct examination, I believe.  So if the Registrar can assist us both in

20     that respect, it would be much appreciated.

21             MS. NOZICA: [Interpretation] I'm sorry, Your Honours.  My

22     examination was under three hours, if I am not mistaken, and since

23     cross-examination is proportionate to direct examination, I'm just giving

24     this as a reminder.

25             MR. SCOTT:  Your Honours, I'm certainly in the hands of the

Page 37155

 1     Registrar and I will abide -- absolutely strictly abide by any numbers

 2     that they come up with.  May I --

 3             THE COURT:  I'm going to tell you.  You have 49 minutes left.

 4             MR. SCOTT:  Well, I have 49 minutes based -- the Stojic Defence

 5     took, as I understood it, three hours and ten minutes.  I also understand

 6     that both the Praljak Defence and one of the other Defence teams took

 7     direct examination time, so I'll ask the Registrar to please assist us in

 8     determining how much additional direct examination time was also taken by

 9     the other co-accused.

10             JUDGE ANTONETTI: [Interpretation] Mr. Scott, the quality of

11     Prosecution or Defence is not the time it takes, it is the quality of the

12     questions that are put.  In the matter of a few minutes, you can raise a

13     fundamental issue.  You can also spend hours on nothing.

14             We're going to have a 20-minute break.

15                           --- Recess taken at 12.30 p.m.

16                           --- On resuming at 12.50 p.m.

17             JUDGE ANTONETTI: [Interpretation] The court is back in session.

18             Let's take stock of the situation.  Mr. Scott, you are entitled

19     to additional time because Ms. Pinter took 15 minutes to address new

20     issues, so you should make due with 10 minutes.  So all in all, you'll

21     have 59 minutes.  There's under an hour until the end of the hearing.  I

22     guess that Ms. Nozica may have some redirect; I don't know at all.  It

23     all hinges on you.  If you act swiftly and efficiently, we can finish

24     today.  Otherwise, everybody will have to be back tomorrow morning.

25             JUDGE TRECHSEL:  If I may just, for the transcript, I think it

Page 37156

 1     must be recorded in the transcript that Mr. Pusic has not attended the

 2     session since the break before this one, since after the first break he

 3     has suffered from heavy back pain and was allowed to return.  I think it

 4     must be reflected in the transcript.

 5             Thank you.

 6             JUDGE ANTONETTI: [Interpretation] One moment.  I thought it was

 7     not necessary to record this on the transcript, in as much as the accused

 8     was present at the beginning of the hearing.  He is represented by his

 9     counsel, and if he has to leave the courtroom due to medical reasons,

10     there's no need to have it on the record.  But this being said, each of

11     the Judges having stated their views, we can proceed.

12             MR. SCOTT:  Thank you, Mr. President, and I do appreciate the

13     time.  I will try to move as quickly as possible.  I represent to the

14     Chamber that even over the break, I made substantial adjustments in my

15     outline, so I'm hopeful.

16        Q.   Sir, I would like to next show you before moving on to the next

17     topic, and I would like to have this distributed, P 10850, for the

18     record, but I'm distributing it -- with the usher's assistance, I'm

19     distributing it now.  Apparently it didn't find its way in the binders.

20     I'm sure it's probably my fault.

21             JUDGE TRECHSEL:  The name didn't make it to the transcript

22     either, so if you would repeat the number.

23             MR. SCOTT:  One -- excuse me, P 10850.  Thank you, Judge.

24     P 10850.  It's also available in the e-court, if that assists anyone.

25        Q.   Sir -- I think everyone has it.  Sir, this appears to be a

Page 37157

 1     document that was put out over your name, "Veso Vegar."  On the top of

 2     the first page, we have handwritten:  "Received on 11 August 1993."  Do

 3     you see that?

 4        A.   Yes, I do.

 5        Q.   And this is a document that you prepared, isn't it?

 6        A.   I think so.

 7        Q.   Sir, this is directed to the attention "All is assistants for IPD

 8     and brigades, Uskoplje, Novi Travnik, Rama, or Prozor, Skopje also of

 9     course being Gornji Vakuf, Kiseljak, and Vitez, so in light of the

10     discussion we had earlier today I'm going to suggest to you that this was

11     a distribution from you to IPD assistants in the field, which would not

12     be surprising, correct, because you're communicating to people in your

13     structure?

14        A.   Yes, I'm addressing assistants for IPD in these brigades.

15        Q.   Now, our time as you heard is very limited.  In the second

16     paragraph of the document you'll see:

17             "It should be openly stated ..."

18             But then you go on to say:

19             "We have to strongly confront all troublemakers, all those, which

20     are spreading defeatism and even panic, and not even run from their

21     isolation.

22             "Urgently put out of action 'all knowing' gentlemen, those that

23     spread rumours about 'sold out' this and that, and this or that town was

24     given away to Muslims or Serbs.  The leadership of the Croatian Republic

25     of Herceg-Bosna ... gave nothing away."

Page 37158

 1             And so on.  Are those your words, sir?

 2        A.   Yes.

 3        Q.   What was the context in which this document was prepared, please?

 4        A.   In the context of massive disinformation and rumours, that

 5     someone on behalf of the HVO of the Croatian Community of Herceg-Bosna

 6     had sold out, namely, agreed to the hand-over of certain towns to be

 7     given to another, to a second or a third republic, this document was

 8     created after the third agreement that envisaged a union.  That's why it

 9     says in the first sentence that we have now received our own republic,

10     but within Bosnia and Herzegovina.  And now smart-alecks appear,

11     know-it-alls who disperse such information that they got from not only

12     Croats, but also from the second or the third side, and they spread chaos

13     in the minds of people.  This information had the objective of changing

14     the prevailing sentiment and refuting such rumours.

15        Q.   Sir, I only have time to point one other part of it to you,

16     unless of course the Judges have questions, but in the next paragraph

17     that begins under the words:  "Honourable HVO soldier ...," there is this

18     statement:

19             "We will not agree on any rotten compromises and proposals like

20     the one by Alija Izetbegovic on joint state from Neum to the Sava river."

21             What rotten compromise were you referring to?

22        A.   I think for people who lived in that area, it was understandable,

23     what I was trying to say.  I was talking about a political concept, an

24     idea that can be characterized as unitaristic, with a strong

25     centralisation of power in one place, that is to say, Sarajevo, wherein

Page 37159

 1     none of the three ethnic communities in Bosnia and Herzegovina would have

 2     been separate or able to develop their own separate identity.  This

 3     sentence does not mean that I was denying that state.  It means that

 4     Croats agreed to such a state, but that they should have their own

 5     separate identity within that state.  And, anyway, this agreement did

 6     envisage three entities within one state.

 7        Q.   And that was a separate Croat entity with a separate territory

 8     set aside for Croats; correct?  According to you?

 9        A.   It envisaged a separate republic where the Croats would be a

10     majority, just like the other two republics where the Serbs and Muslims

11     respectively would be the majority.

12        Q.   So the answer to my question is, yes, there would be a separate

13     entity and separate territory for Croats; correct?

14        A.   Yes.

15        Q.   Now, we have to move on to Exhibit, please, P 10837, P 10837 in

16     the second binder.  And I'm turning to the topic of events in Mostar in

17     May and June 1993.  Sir, this is an article from the Associated Press,

18     dated 11 May 1993.  And I'm going to have to move rather quickly, sir,

19     and I'm going to put statements attributed to you in this article.  Once

20     again, I'm sure that if I misquote or misstate, I'll be corrected.  But

21     in this article, and it's on the second page of the English version, I'll

22     read it very slowly, sir, this statement is attributed to you:

23             "Vegar said civilians of all ethnic groups were merely being

24     evacuated from combat zones."

25             And that was in response to UN officials, two paragraphs up, if

Page 37160

 1     you will:

 2             "UN officials said they were concerned about Muslim civilians

 3     reportedly cleared out of their homes in Mostar on Sunday.

 4             "'There have been a number of civilians taken from their homes,'

 5     said a US Army captain... 'We assume they are being detained or being

 6     taken out of the area against their will.'"

 7             And then in that context, sir, it's attributed to you:

 8             "Vegar said civilians of all ethnic groups were merely being

 9     evacuated from gather zones."

10             And before putting a question to you about that, can I just ask

11     you to turn very close by, P 10845.  It should be just a couple of

12     documents down in your binder, P 10845.  This is an article from -- on

13     the 12th of May, 1993, the following day, from the "Seattle

14     Post-Intelligencer."

15             Yet again -- sorry, sir, let me just point out, at the bottom of

16     that, the English page, the first page of the article -- excuse me:

17             "When asked about the evidence of civilian detentions Croat

18     military spokesman --"

19        A.   I'm sorry, I'm not getting any interpretation.

20        Q.   My apologies.  I'll start again, and please tell us:

21             "When asked about the evidence ..."

22             Are you getting translation?

23             "When asked about the evidence --"

24        A.   I don't see --

25        Q.   Maybe it's --

Page 37161

 1             JUDGE PRANDLER:  Mr. Scott, I'm sorry, but it is probably you

 2     might want to mention that it is on page 2.

 3             MR. SCOTT:  Thank you, Judge Prandler.  I think perhaps --

 4             MS. NOZICA: [Interpretation] Your Honours, the witness is saying

 5     there is no translation.  He means the paper, the translation.

 6             MR. SCOTT:  No, there is not a translation of this.  That's why

 7     I'm reading it to you, sir, which is not a new procedure.  It's a

 8     procedure we've followed for the last three years:

 9             "When asked about the evidence of civilian detentions, Croat

10     military spokesman Veso Vegar said civilians of all ethnic groups were

11     being evacuated from combat zones."

12        Q.   Now, sir, where did you form the opinion or form the position

13     that what was happening to the Muslims in early May 1993 was an

14     evacuation for their own safety?  Did you come up with that on your own

15     or is that what someone else told you?

16        A.   That evacuation did have the purpose to ensure their safety,

17     especially in war-affected zones, and that was all of Mostar because that

18     was a small town.  But as far as I know, the first to be evacuated were

19     the streets closest to combat activity.

20        Q.   Sir, my question was, and I apologise if it wasn't clear or if it

21     wasn't -- there was a problem in translation, but our time is short:  Is

22     that a position that you formed and stated on your own or is that a

23     position that was the HVO position at the time?  Were you stating that as

24     your -- in your capacity as spokesperson for the HVO Department of

25     Defence, and if so, who confirmed that position to you?  Who said, "This

Page 37162

 1     is our position"?

 2        A.   Nobody told me it was our position.

 3        Q.   Sir, that statement is just completely wrong, isn't it, because

 4     it wasn't all civilians, all ethnic groups -- civilians of all ethnic

 5     groups being evacuated; it was specifically only Muslims, wasn't it?

 6        A.   I still maintain that all the people who were in the immediate

 7     danger of war were evacuated.

 8        Q.   And they just happened to be only Muslims; is that correct?

 9        A.   There were not only Muslims, although Muslims were the majority.

10        Q.   Well, are you aware, sir, that this Tribunal has found, in fact,

11     and this Trial Chamber has so ruled on adjudicated facts, that this

12     effort was directed only at Muslims?

13             MS. TOMANOVIC: [Interpretation] Sorry.  I object on the basis

14     that the Prosecutor is leading evidence that is not admitted here in this

15     trial, in the sense that he is trying to make it out.  I invite the

16     Prosecutor to check the lists from Heliodrom that he tendered himself and

17     to check how many Serbs and Croats there are on the lists.

18             MR. SCOTT:  Well --

19             JUDGE ANTONETTI: [Interpretation] Mr. Scott.

20             MR. SCOTT:  -- I'll refer to the adjudicated fact in this case,

21     number 91, as issued by this Trial Chamber:

22             "The arrest and detention of the civilian population in Mostar

23     was carried out on a discriminatory basis, as the Bosnian Muslim

24     population was targeted specifically, while their Croat neighbours were

25     left unharmed.  It was unlawful, since there was no legal basis for this

Page 37163

 1     measure."

 2             That's the adjudicated fact.

 3        Q.   Sir, it wasn't --

 4             MS. TOMANOVIC: [Interpretation] Just a moment, please.  I would

 5     like to remind the Prosecutor of the status of adjudicated facts; namely,

 6     that they can be disproven, and the Prosecutor has himself led evidence

 7     in the form of these lists where it is obvious that there are Serbs and

 8     Croats and others on those lists.

 9             JUDGE ANTONETTI: [Interpretation] Please proceed, Mr. Scott.

10             MR. SCOTT:  Thank you.

11        Q.   Well, let me be very clear, sir.  So you're saying the statement

12     that the Muslims were being evacuated for their own safety and that this

13     was happening to all ethnic groups, this is something that Veso Vegar,

14     completely by himself, when the question was put, it was completely your

15     position, the answer you gave, without consultation with anyone else in

16     the HVO authorities or Mr. Stojic, your superior; is that what you're

17     telling the Chamber?

18        A.   Yes.  At that time, I'm sure I didn't contact anyone, although it

19     was not only my position; it was the position shared by many others.

20     That's why I put it, then and now.

21        Q.   Would you go, please, to Exhibit P 10838 in the second binder.

22     P 10838.  Sir, this is a document -- this is a report from Reuters on the

23     14th of May, 1993, titled "Croat Troops Free Some Muslim Detainees in

24     Mostar."  Apparently on that day, the second paragraph:

25             "Fifty women, children, and elderly were taken by bus from the

Page 37164

 1     helicopter complex where they had been interned after being removed from

 2     their home in the city on Sunday."

 3             Skipping to -- one, two -- the third paragraph below that, it

 4     says:

 5             "HVO spokesman, Veso Vegar, said all the Muslims would be free

 6     once Croats arrested by Bosnian Army troops in the Jablanica-Konjic

 7     pocket north-east of Mostar were released."

 8             Now, again, the position is stated that the HVO would free the

 9     others detained at the Heliodrom once Croats arrested and held by Bosnian

10     Army troops elsewhere were released.  Who formed that position and

11     communicated that to you, or was this again Veso Vegar acting as the

12     leader of the HVO and making that decision on your own?

13        A.   If I spoke to this subject at all, I could only have talked about

14     detained Muslim soldiers, certainly not those who were evacuated from

15     Mostar, so I think there's nothing illogical if I linked the release of

16     prisoners on one side with the release of prisoners on the other side

17     because at that time, in Konjic and Jablanica, there were many Croats

18     detained, fighting men, but also civilians.

19             JUDGE ANTONETTI: [Interpretation] Witness, this is a very central

20     issue to these proceedings.  You are saying that if the Muslims who were

21     arrested can be released -- well, they can be released if the Croats that

22     were arrested in the Jablanica-Konjic area are released as well.  The

23     problem is that -- well, I'm not aware of the situation in

24     Jablanica-Konjic.  I don't know which Croats were arrested.  But if there

25     were Croat civilians arrested in Jablanica, due to this sort of dual

Page 37165

 1     track, the Muslims arrested in Mostar could also be civilians.  Can you

 2     see the extent of your statements then?

 3             THE WITNESS: [Interpretation] Yes, I can look it up, but I'm not

 4     talking about the capture of civilians in order to exchange them for some

 5     other civilians in Jablanica and Konjic.  I am certain that I am talking

 6     here only about imprisoned soldiers and their possible exchange.  But I

 7     always referred to the freedom of movement for civilians.

 8             JUDGE ANTONETTI: [Interpretation] You're now speaking about

 9     military, but in this Reuters statement, there's no distinction between

10     civilians and military, just mention is made of Croats and --

11             THE WITNESS: [Interpretation] And the agency did not distinguish

12     between fighting men and civilians, but I did.

13             JUDGE ANTONETTI: [Interpretation] Mr. Scott.

14             MR. SCOTT:

15        Q.   Well, that's not entirely true, sir.  If you look at the first

16     sentence of the article Reuters says:

17             "Bosnian forces on Friday released about 50 of 2.000 Muslim

18     civilians detained in squalid conditions outside of Mostar as sporadic

19     fighting persisted around the south-western Bosnian city."

20             But my specific -- I persist in my question to you originally,

21     sir, I put it to you:  This was not Veso Vegar's only single decision,

22     this was a policy statement or decision taken, a strategy announced by

23     the HVO, and unless you were in a much more senior position than the one

24     you were in, that wasn't your decision, sir, about when other people

25     would be released.  Now, who told you that was the HVO policy or

Page 37166

 1     situation -- excuse me, strategy, that when people -- when Croats in

 2     Konjic would be released, then civilians being held at the Heliodrom

 3     would be released?  Who told you that was the position?

 4        A.   I fully agree this was not my decision, whether 50 would be

 5     released or all of them.  I did not discuss that at all and I did not

 6     take decisions, but pursuant to the erstwhile practice, I discuss the

 7     process of exchange which would always take place after decisive events

 8     where there would be more captured soldiers.  I'm sure I spoke about the

 9     soldiers, not civilians.

10        Q.   And the evictions of Muslims in Mostar continued throughout the

11     balance of May, and when I say "the balance," after the 10th of May,

12     1993, and continuing through June and thereafter; correct?

13        A.   Yes.  Muslims, Croats and Serbs.

14        Q.   No, sir.  The eviction of Muslim families and Muslims continued

15     throughout Mostar, in West Mostar, throughout the balance of May, June

16     and July; correct?

17        A.   Yes, all subsequent months, but not only of the Muslims, as I

18     said.  I can give you reliable data that in the eastern --

19        Q.   I will direct your attention to P 02557.  I apologise for cutting

20     you off, but the Chamber -- we only have so much time.  P 02557.

21             MR. SCOTT:  It should not be broadcast, I'm told, Your Honour.

22     We can use it in the courtroom, but the document itself should not be

23     broadcast outside the courtroom.

24             MS. TOMASEGOVIC TOMIC: [Interpretation] Your Honours, I

25     apologise, but I've been listening to the Croatian interpretation.  What

Page 37167

 1     I'm bothered about - maybe my English is not good enough - but in the

 2     headphones we heard, and I think this is important, the moving out as

 3     interpretation for the word "eviction."  I'm not sure that's the most

 4     fortuitous choice of words when the witness is asked questions about

 5     that.

 6             MR. SCOTT:  I can't -- unfortunately, I can't control the exact

 7     translations of my words.  I did use -- I believe I used the words

 8     "eviction" and "expulsion," and those are the words I intend to use.

 9        Q.   If you look at P 02557, sir, this is a report dated 29th of May,

10     1993.  Item number 6 --

11             MS. TOMASEGOVIC TOMIC: [Interpretation] Your Honours, I apologise

12     to my learned friend Scott.  The key thing happened again while I rose.

13     Now the witness received the word "protivanje," [phoen] "expulsion,"

14     which is something completely different from that, when -- what he heard

15     when Mr. Scott discussed "evictions."

16             JUDGE ANTONETTI: [Interpretation] Well, Witness, the Prosecutor

17     in English used the word "eviction."  In your language, what did you

18     understand?  What was it that was translated to you?

19             THE WITNESS: [Interpretation] I understood that he was talking

20     about moving out, temporary leaving the town of Mostar, and this is the

21     context that I spoke in, people fleeing war and war threat, but not on a

22     permanent basis.

23             JUDGE ANTONETTI: [Interpretation] All right.  You may proceed,

24     Mr. Scott.

25             MR. SCOTT:  Your Honour, I mean, if the whole record now for the

Page 37168

 1     last 15 minutes is contaminated by confusion, then it's -- we've lost the

 2     time and I can't -- I'm not going to be held hostage by the loss of time

 3     on that.  The specific word that I've used repeatedly is "eviction" and

 4     "expulsion," and that's what the documents use.  So it's to my prejudice,

 5     I'm afraid, but look at, sir, P 02557, item 6:

 6             "Both the UNHCR and the ICRC report the internment and eviction

 7     of Muslims in Mostar and the towns of the south ..."

 8             Skipping a line or two:

 9             "The UNHCR and the ICRC say report that Muslim families on the

10     west bank were evicted last night in organised raids, their homes

11     occupied by Croat families with 'permits' to occupy the flats.  In

12     addition to families which were squatting in homes vacated by Serbs,

13     regular residents were also evicted."

14             Now, as I said, that kind of eviction, that expulsion, was going

15     on through May, June, and July, Muslims being evicted from West Mostar;

16     correct?

17        A.   I can confirm that there were individual cases of people coming

18     into flats and evicting the inhabitants from those flats, on the part of

19     criminal and uncontrolled groups, but I cannot accept the statement which

20     is being put forward here, that this was done by official institutions,

21     that it was done by the HVO or a unit of the HVO.  Simply, there was no

22     plan of expulsion or of ethnic cleansing of Mostar.

23        Q.   Let's go to P 02538, P 02538.  Sir, this is a document issued --

24     a communique issued by Mr. Maric on the 27th of May, 1993, in connection

25     with flats in Mostar.  Quote in the first paragraph:

Page 37169

 1             "Pursuant to a verbal order issued by the head of the HZ

 2     Herceg-Bosna Defence Department," I put it to you the head of that is

 3     Mr. Stojic, "... with the aim of providing necessary accommodation for

 4     family members of soldiers from the Ludwig Pavlovic Regiment," et cetera,

 5     it's a communication, "the comission hereby places ten apartments at

 6     disposal allegedly previously owned by the JNA."

 7             Now, this has been copied to -- you'll see that this has been

 8     distributed to the head of the Defence Department, Mr. Stojic, and

 9     several other persons.  Now, sir, if you will keep that document in

10     mind --

11             MS. NOZICA: [Interpretation] Your Honours, Your Honours, I must

12     object to this.  Mr. Scott must bring into connection those flats with

13     what he was asking the witness about previously.  He seems to be implying

14     that somebody had been dislocated from those flats.  He must lay the

15     grounds, prove that the decree on the attribution of flats was taken,

16     there were criteria that were applied, and this has nothing to do with

17     this question.

18             JUDGE ANTONETTI: [Interpretation] Madam Nozica, there's no reason

19     to say that.  You've got professional Judges here who have been dealing

20     with this case for three years.  For 24 hours a day -- 20 hours a day

21     we're dealing with this case, we're hearing this case.  So you can easily

22     imagine that when Mr. Scott talks about it, we are all focused on this,

23     and so it's pointless to tell us, yes -- well, we'll see.  Wait and the

24     see the rest of the question.

25             Yes, Mr. Stojic.

Page 37170

 1             THE ACCUSED STOJIC: [Interpretation] Good afternoon, Your

 2     Honours.

 3             You know, I've been sitting here for three years, and I've been

 4     silent so far, but this is very difficult for me to suffer, because that

 5     person over there is airing lies.  I'm responsibly saying this.  This

 6     document has nothing to do with what Mr. Scott is talking about, no

 7     connection.  Your Honours, I cannot suffer this any longer.  You must

 8     understand us.  There used to be six of us here.  Now there are only two

 9     of us remaining.  I cannot suffer this any longer.

10             Thank you very much.

11             JUDGE ANTONETTI: [Interpretation] Mr. Stojic, the Judges have a

12     document which mentions apartments occupied by the JNA that are going to

13     be made at the disposal.  Now, it's up to the Prosecutor to establish the

14     connection between the apartments, Muslims who may have occupied the

15     apartments and who may have vacated them, for Mr. Serafinov [phoen],

16     Pesic, [indiscernible] and so on.

17             Mr. Scott.

18             MR. SCOTT:  If we can go to Exhibit P 02756, P 02756 in the first

19     binder.  This is an ECMM report dated the 14th of June, 1993.  I'll

20     direct your attention, Mr. Vegar, to paragraph number -- item number 6,

21     "Other matters."

22        Q.   Skipping a few lines, it says:

23             "We have got information from three different sources about,

24     again since Saturday afternoon, Muslim families are being expelled by HVO

25     soldiers from their homes via south-east quarter Donja Mahala, to the

Page 37171

 1     east bank.  Approximately more than 100 Muslim people were Sunday night

 2     and today expelled from the quarters Dum and Patikana [phoen].  On most

 3     of their apartments, there were HVO stickers found where the apartments

 4     were occupied by HVO soldiers."

 5             Item 6, "Assessment," the second item:

 6             "The ethnic cleansing on the west bank of Muslim families by the

 7     HVO still goes on."

 8             That's what was happening at the time; correct, sir?  Muslims

 9     were being -- Muslim families were being thrown out, HVO soldiers were

10     moving in; correct?

11        A.   Mr. Prosecutor, this is the first time I've seen this document.

12     I have to go through it.  I see that General Pasalic sent a protest note.

13        Q.   That wasn't my question, sir.  That's what -- these evictions

14     were what was going on in June and July of 1993, and you were aware of

15     it, weren't you, sir?

16        A.   I -- what I knew about this, I already told you.  I maintain that

17     HVO units did not do so.  Individuals did that, most probably civilians

18     wearing uniforms.  Everybody was wearing uniforms in Mostar at the time.

19     They had no other clothes.  I cannot tell you or know whether there were

20     any HVO soldiers among them.

21        Q.   Let's look at Exhibit P 03179 in the first binder, P 03179.  Sir,

22     this is an HVO military police report for the 3rd of July, 1993.  I would

23     like to direct your attention, please, to the headings which are -- it

24     gives by zone, and if you can find the part of the report under zone

25     number 2.  Then there are three numbered -- there are three names with

Page 37172

 1     numbers, 1, 2, 3, and I will begin at the next paragraph after the third

 2     name.

 3             MS. TOMASEGOVIC TOMIC: [Interpretation] I apologise to my learned

 4     friend Scott.  May I remind Their Honours that on several occasions, and

 5     this has been accepted as an exhibit and we stick by our objection, that

 6     this document does not bear the signature of the alleged author, nor the

 7     stamp, and nor the letterhead which is usual for military police

 8     communications.  Thank you.

 9             MR. SCOTT:

10        Q.   From 2000 --

11             JUDGE ANTONETTI: [Interpretation] Wait a second.  Madam -- let me

12     reply to the lawyer.  Counsel, okay, you challenged this report.  Fine.

13     You see that this report is signed by somebody named [indiscernible].

14     Why not summon here -- here with other witnesses for him to say, "I've

15     never written this document"?

16             MS. TOMASEGOVIC TOMIC: [Interpretation] Your Honours, can we move

17     into private session or closed session, please, for a moment?

18             JUDGE ANTONETTI: [Interpretation] Well, look, we'll deal with

19     this at some other point.  We have very little time left.

20             Mr. Scott, please.

21             MR. SCOTT:

22        Q.   Sir, it says:

23             "From 2000 to 2200 hours, eviction of refugees from the Pupils'

24     Hostel was carried out.  They were taken to the left riverbank.  There

25     were 310 persons.  From 2230 to 2330 hours, the eviction from the

Page 37173

 1     kindergarten in Liska Street was carried out and the persons were taken

 2     to the left riverbank.  There were 36 persons.  Regular patrolling duty

 3     was performed during the night."

 4             Those were Muslims being evicted from the west bank to the east

 5     side; correct?

 6        A.   No, I don't know of these events.  Particularly, not -- I can't

 7     believe that there was mass evictions of this sort.  This is the first

 8     time I've seen the document, and I don't know anything about the pupils'

 9     dormitory.  I can't recall this at all.

10        Q.   Sir, we don't have time to go through every single document I

11     might put in front of you on this topic, but I do want it to be very

12     clear.  Your position is, and what you're telling these Judges, under

13     oath, is that you were not aware of the mass eviction of Muslims from

14     West Mostar taking place from the 10th -- from 9th of May, through the

15     rest of May, into June, into July, and thereafter of 1993; you're telling

16     these Judges you didn't know that was going on?

17        A.   I really do not have any information, neither do I recall any

18     mass expulsion.  I remember and I said that there were individual cases,

19     repeated several times, but I don't know of any thought-out plan or

20     design about mass expulsions.  That, I really do not know.

21        Q.   Let's go to Exhibit P 10846, P 10846, second line.  Sir, this is

22     a Agence France-Presse article from the 9th of June, 1993, concerning the

23     movement of Muslims in Mostar.  It attributes this statement to you, in

24     quotation marks:

25             "'We (Croats) are doing their (the Serbs') job now,' Vegar said

Page 37174

 1     with a smile."

 2             What Serb job were the Croats doing in early June 1993?

 3        A.   It's a terrible lie.  I must protest.  I've never heard such a

 4     terrible lie in this courtroom, that I allegedly said that we were doing

 5     the Serbs' job.  No, I never would say that, and I never did say that.

 6        Q.   The third paragraph:

 7             "The Croats are now trying to convince the Muslims remaining on

 8     the west side to leave, but foreign sources say the residents are so

 9     intermingled that the operation is proving problematical."

10             Do you recall that?

11        A.   No, I don't recall a single such sentence.  I'm not sure whether

12     this is anybody's statement or whether this was just a conclusion of the

13     author, the journalist.

14             JUDGE ANTONETTI: [Interpretation] Very quickly, sir, very

15     briefly.  Now, if this journalist states that you smiled, it's probably

16     that he saw you.  So did you meet with this journalist on the 9th of

17     June, 1993?

18             THE WITNESS: [Interpretation] No, I cannot recall which

19     journalist I met on which day, but it's impossible that I've said that,

20     at any rate.

21             JUDGE ANTONETTI: [Interpretation] All right.  Mr. Scott.

22             MS. NOZICA: [Interpretation] Your Honours, if you'll allow me,

23     I'm sorry for this interruption, but even if we did say they -- let's see

24     how this is written.  Those are obviously not the words of Mr. Vegar, if

25     we take a look at what is attributed.  Why do we have "Croats" and

Page 37175

 1     "Serbs" in brackets?

 2             THE WITNESS: [Interpretation] I don't have the translation, so I

 3     can't really tell you what it's all about.

 4             JUDGE ANTONETTI: [Interpretation] Yes.  Ms. Nozica, I'll give you

 5     credit for what you're saying.  It's quite surprising that a journalist,

 6     who is supposed to faithfully give the words of a person, should put in

 7     between brackets these words and interpret those words.  I've never seen

 8     that up until now.

 9             Mr. Scott.

10             MR. SCOTT:  Could I just inquire from the Registrar --

11             THE INTERPRETER:  Microphone, please.

12             MR. SCOTT:  My apologies.  Could I inquire of the Registry,

13     please, as to the time-limits, because given what time I have left, I

14     mean, I've just -- I've pushed as fast as I could, but I think it's

15     unrealistic to think we'll be finished by 1.45.  If the Registry can

16     assist me, please.

17             JUDGE ANTONETTI: [Interpretation] Well, the main issue is whether

18     Ms. Nozica has additional questions in redirect.

19             MS. NOZICA: [Interpretation] Your Honours, I will have five to

20     ten minutes, not more than that.

21             JUDGE ANTONETTI: [Interpretation] Fine.  So we won't have the

22     five to ten minutes.

23             Mr. Scott, theoretically you have 26 minutes left.

24             MR. SCOTT:  Thank you, Mr. President.

25        Q.   Sir, I'd like to turn to the topic of convoys, and I'd like to

Page 37176

 1     start, please, if I could direct your attention to P 10831 in this

 2     second -- excuse me -- yes, the second binder, P 10831.  Sir, this is a

 3     Reuters article dated the 1st of March, 1993.  The first lead-in sentence

 4     says:

 5             "Bosnian Croat forces said on Monday they were enforcing a

 6     blockade of supply convoys for their estranged Muslim allies, despite

 7     Bosnian government reports that it had been lifted."

 8             I'm going to skip a paragraph.  This statement is attributed to

 9     you, sir, so you're on notice:

10             "'We're stopping all Bosnia-Herzegovina army convoys with

11     military equipment and weapons and any kind of supplies headed for areas

12     where there is tension or outright fighting between the HVO and Muslims,'

13     HVO spokesman Veso Vegar told Reuters.

14             "Bosnian Army columns destined for regions where HVO and Muslim

15     forces were jointly battling the Serbs, such as in north-east Bosnia

16     around Tuzla, were being allowed to pass."

17             Now, the statement attributed to you, sir, is that an accurate

18     statement as what was happening in the 1st of March, 1993?

19        A.   I cannot recall what was going on precisely on the 1st of March,

20     and I'm sorry about that, but I can tell you about the information about

21     the stopping of convoys.  There were such cases, yes.  Very often in

22     convoys containing humanitarian aid, weapons, munitions, military

23     equipment, were being transported, and of course somebody had to have

24     control over such convoys because very often -- well, so that we could

25     know who is carrying weapons for whom.

Page 37177

 1        Q.   Sir, again because of the shortness of time, I simply want to

 2     know.  Was it -- did you accurately state the HVO position at the time,

 3     that BiH Army convoys with military equipment and weapons and any kind of

 4     supplies headed for areas where there is tension or outright fighting

 5     between the HVO and Muslims were being stopped?  Is that an accurate

 6     statement by you of the HVO's position during this time-period?

 7        A.   If those convoys were stopped then to be examined, that was the

 8     HVO's position.  Of course, the HVO did that, not me.  I could just relay

 9     information if such things were happening at the time.

10        Q.   Now, if you could go, please, to 10832.  Perhaps we'll have time

11     to finish one more document today.  P 10832.  Sir, this is a Reuters

12     article by -- excuse me, the 24th of August, 1993, again about a convoy,

13     but this is about a different situation.  This concerns a humanitarian

14     convoy to Mostar.  I'll give people a chance to scan down a bit.

15     Nineteen trucks -- about halfway through the article, sir, this statement

16     is attributed to you, or this position or information is attributed to

17     you:

18             "Croat military spokesman Veso Vegar said the convoy would be

19     given safe conduct through Croat check-points into the Muslim quarter of

20     the divided city later on Tuesday or Wednesday."

21             Then it goes on to say:

22             "'Some of its cargo would be unloaded in Croat-controlled Central

23     Mostar as the price of passage,' he said.

24             "'The HVO (Bosnian-Croat forces) will let the convoy through

25     later today or tomorrow, despite the fact that 190.000 Croats are under

Page 37178

 1     siege by Muslims in Central Bosnia,' Vegar told Reuters by telephone from

 2     Mostar in South-West Bosnia."

 3             Now, did you make -- did you provide that sort of information?

 4     I'm not going to say -- I'm not going to hold you, sir, to the exact

 5     words stated here, but do you remember providing such information to

 6     Reuters and other journalists around the 24th of August, 1993?

 7        A.   If on that day a convoy planned for Mostar was -- Eastern Mostar

 8     was scheduled, then I can confirm that I had given that information.  And

 9     the second statement, that part of the cargo would be unloaded as the

10     price of passage, I can tell you that I never heard of such a price for

11     humanitarian convoys, I never received information that parts of the

12     cargo for humanitarian convoy would be taken and the other part being let

13     through.  I don't know anything about that, and no such information

14     reached me.

15             MR. SCOTT:  Your Honour, I think that will have to finish us for

16     the day, with the Court's permission.

17             JUDGE ANTONETTI: [Interpretation] So you want to continue.  You

18     still have 20 minutes.  You want to continue tomorrow?

19             MR. SCOTT:  Yes, Your Honour.  Thank you.

20             JUDGE ANTONETTI: [Interpretation] Very well.

21             Witness, you shall have to return tomorrow.  Ms. Nozica will

22     address questions in redirect tomorrow.  Mr. Coric's counsel can say

23     tomorrow what she wanted to say today.  She should remind me so that

24     I can give her the floor tomorrow.

25             It's quarter to.  We have to stop because there's the Popovic

Page 37179

 1     case sitting here after us.  Have a good afternoon.

 2                           --- Whereupon the hearing adjourned at 1.46 p.m.,

 3                           to be reconvened on Thursday, the 19th day of

 4                           February, 2009, at 9.00 a.m.