1 Thursday, 15 May 2008

2 [Open session]

3 [The accused entered court]

4 --- Upon commencing at 2.20 p.m.

5 JUDGE ANTONETTI: [Interpretation] Madam Registrar, can you cite

6 the case.

7 THE REGISTRAR: Good afternoon, Your Honours.

8 This is case number IT-03-67-T, the Prosecutor versus

9 Vojislav Seselj.

10 JUDGE ANTONETTI: [Interpretation] Thank you, Registrar.

11 We are Thursday, 15th of May, 2008. I would like to greet the

12 members of the Prosecution, Mr. Seselj.

13 First, a few housekeeping matters, but first I would like to ask

14 for a closed session. I have a decision to communicate in closed

15 session.

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23 [Open session]

24 THE REGISTRAR: Your Honours, we are back in open session.

25 JUDGE ANTONETTI: [Interpretation] So we're in open session. I

1 would like to inform Mr. Seselj that the internet connection is working,

2 so normally the entire world can follow this hearing.

3 Mr. Mundis, would you like to say anything?

4 MR. MUNDIS: Thank you, Mr. President.

5 Good afternoon, Your Honours, and to everyone in and around the

6 courtroom.

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13 JUDGE ANTONETTI: [Interpretation] Mr. Mundis, apparently this

14 motion is confidential.

15 MR. MUNDIS: Perhaps the Chamber ordered it to be filed

16 eventually. It's certainly not indicated thus on the cover of the

17 document. Perhaps for the benefit of the doubt, we could go into private

18 session.

19 JUDGE ANTONETTI: [Interpretation] Let's move on to private

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22 [Open session]

23 THE REGISTRAR: Your Honours, we are back in open session.

24 JUDGE ANTONETTI: [Interpretation] Prosecutor, I think the witness

25 is waiting outside.

1 MR. DUTERTRE: [Interpretation] Yes.

2 Good afternoon, Your Honours.

3 There are two points I would like to address briefly. I would

4 like to introduce the intern who is assisting us today, who -- her name

5 is Sara Grujin. It's the first time she's with us today.

6 Also a procedural matter I would like to address. The Court

7 binder of the next witness is not quite as complete as it should be. We

8 mentioned a video. I intend showing two video clips, one clip which has

9 no sound and no transcript. The other one is very short. It's silent --

10 THE INTERPRETER: Sorry, interpreter's correction: I have handed

11 out the transcript of the second video clip.

12 MR. DUTERTRE: [Interpretation] It's not what the person is saying

13 in the video clip that I'm interested in. It's just to be able to

14 identify the person that I wish to show this video.

15 These are two matters that I wished to bring to the attention of

16 the Trial Chamber because it was not mentioned in the Court binder which

17 we prepared at the last minute given we had to replace a witness wasn't

18 able to come.

19 JUDGE ANTONETTI: [Interpretation] So you still confirm that you

20 need two and a half hours for this witness?

21 MR. DUTERTRE: I shall try and make it shorter, if I can.

22 JUDGE ANTONETTI: [Interpretation] Very well. Whatever the case

23 may be, we shall listen to all of this extremely carefully, and let's

24 bring in the witness into the courtroom, please.

25 In the meantime, Mr. Mundis, as far as next week is concerned,

1 the upcoming witnesses, well, there's a fair chance that this witness

2 today will have to come back on Tuesday. What happens after that?

3 MR. MUNDIS: The next scheduled witness, Professor Riedlmayer,

4 would then testify immediately upon the conclusion of the current

5 witness's testimony. Of course, in the event that the next witness is

6 not able to remain, it might be the case -- I don't know, it might be the

7 case that he has to return home and would need to return at a later date

8 to complete his testimony. I simply don't know. I haven't spoken to the

9 witness about that possibility. We would then immediately go to

10 Dr. Riedlmayer on Tuesday. But the plan would be once this witness is

11 complete, to immediately go to Dr. Riedlmayer.

12 [The witness entered court]

13 JUDGE ANTONETTI: [Interpretation] I shall put the question to him

14 directly.

15 Good afternoon, sir. I would like to check that our technical

16 equipment is working properly. If you can hear me, please let me know.

17 THE WITNESS: [Interpretation] Good afternoon. Yes, I'm able to

18 follow.

19 JUDGE ANTONETTI: [Interpretation] Very well. Sir, can you give

20 me your first name, last name, and date of birth, please.

21 THE WITNESS: [Interpretation] I am Asim Alic. I was born on the

22 8th of March, 1959.

23 JUDGE ANTONETTI: [Interpretation] Sir, do you have a job

24 currently, and if so, what is your occupation?

25 THE WITNESS: [Interpretation] I do not understand the question.

1 JUDGE ANTONETTI: [Interpretation] Do you have an occupation

2 currently or do you not do anything?

3 THE INTERPRETER: The interpreter could not catch it.

4 JUDGE ANTONETTI: [Interpretation] Today, are you currently

5 employed? Do you have an occupation or are you retired?

6 THE WITNESS: [Interpretation] Oh, yes, I am working. Yes, I do

7 have a job.

8 JUDGE ANTONETTI: [Interpretation] And what do you do?

9 THE WITNESS: [Interpretation] I work for the Ministry of the

10 Interior.

11 JUDGE ANTONETTI: [Interpretation] In what capacity?

12 THE WITNESS: [Interpretation] I'm a police inspector.

13 JUDGE ANTONETTI: [Interpretation] Very well.

14 Sir, have you ever before testified before a court of law on

15 questions relating to the former Yugoslavia or is it the first time you

16 testify today?

17 THE WITNESS: [Interpretation] Yes, I testified before the Special

18 Court in Belgrade two years ago.

19 JUDGE ANTONETTI: [Interpretation] So you testified before the

20 Special Court in Belgrade. Who did you testify against?

21 THE WITNESS: [Interpretation] The case which was against

22 Mr. Brano Grujic et al.

23 JUDGE ANTONETTI: [Interpretation] As far as you know, is this

24 trial still ongoing or has there been a judgement?

25 THE WITNESS: [Interpretation] I'm not quite sure. I believe that

1 the case is still going on.

2 JUDGE ANTONETTI: [Interpretation] Sir, please take the solemn

3 declaration.

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

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

6 WITNESS: ASIM ALIC

7 [The witness answered through interpreter]

8 JUDGE ANTONETTI: [Interpretation] Thank you, sir. You may sit

9 down.

10 THE WITNESS: [Interpretation] Thank you.

11 JUDGE ANTONETTI: [Interpretation] Sir, I have something to share

12 with you which is of a practical nature.

13 Since we are running late, there was a witness who came to

14 testify before you, and we can only hear you today. According to our

15 schedule, you will have to resume your testimony next week, i.e., on

16 Tuesday, which means that you would have to stay over until Tuesday. Is

17 that a major problem for you or not?

18 THE WITNESS: [Interpretation] It is no problem.

19 JUDGE ANTONETTI: [Interpretation] Very well. So you will spend

20 the weekend here, and I hope the weather will remain fine.

21 Sir, let me just inform you about the way in which these

22 proceedings will unfold. Since you are a police inspector, you have some

23 understanding and knowledge of what a court case is about.

24 Today, this is a special court. The Judges are not the main

25 protagonists, unfortunately, as far as I'm concerned, and this trial is

1 conducted by the parties, which means that it is the Prosecutor who will

2 put questions to you, first of all, and he will put questions to you and

3 show documents to you. He will show you videos, since he told us that

4 that was his intention. After that stage, Mr. Seselj, who's sitting on

5 your left, will have the same time as the Prosecution to put questions to

6 you, and that is part of what we call the cross-examination.

7 I would like you to rest assured the cross-examination has two

8 purposes; (a), test the credibility of the witness, so some questions

9 will relate to your credibility, and, (b), the second part of the

10 cross-examination is devoted to the substance of the case, based on the

11 answers you gave the Prosecutor.

12 The three Judges who form the Bench, who are in front of you,

13 fortunately have rules of procedure which have entitled us to put

14 questions also, and you will see that we will put questions to you.

15 Generally, we put our questions once each party has put its questions,

16 and our questions usually relate to the merits of the case.

17 Please try and be as accurate as you can when you answer the

18 questions, because all your answers will be recorded on the screen you

19 have before you. It's in English, unfortunately for you, and you might

20 not understand what's being said, but all of this is translated in

21 realtime and is recorded in English on your screen. This is why it is

22 most important that the questions are concise and that the answers are

23 concise.

24 If you don't understand the meaning of a question, please turn to

25 the person who has put the question to you and ask this person to

1 rephrase the question.

2 As a rule, we have a break every hour and a half, and we have a

3 20-minute break, sometimes a 15-minute break. Today, we shall finish at

4 6.00 p.m., so we have three hours before us, and this is an exception.

5 If at any point in time you do not feel well, do not hesitate to

6 raise your hand so that we may adjourn the hearing, and I will adjourn

7 instantly if you have such a problem. And the Bench will answer any

8 questions you may have.

9 I would also like to draw your attention to the fact that from

10 now on you are a witness of the Court, which means that you cannot have

11 any contacts with the Prosecution. You are going to stay here over the

12 weekend, and you cannot contact the Prosecution. You are prohibited and

13 banned from doing so. And the same applies to the Defence.

14 So much for the information I wish to share with you.

15 The Prosecutor, you have the floor, and the clock is beginning to

16 tick.

17 Thank you very much. It is 3.00 sharp.

18 Examination by Mr. Dutertre:

19 Q. [Interpretation] Mr. Alic, when did you join the police, on what

20 date?

21 A. I joined the police in October 1983, in Belgrade.

22 Q. You answered my second question, which was: In which town?

23 Which unit in Belgrade did you join?

24 A. In Belgrade, in the City Secretariat, I joined the Police

25 Brigade.

1 Q. Until when did you keep your position in Belgrade?

2 A. Until October 1991.

3 Q. Where were you posted?

4 A. After that, I started working for the Public Security Station in

5 Zvornik, in Bosnia and Herzegovina.

6 Q. Who was commander of the police forces in Zvornik when you got

7 there in October 1991?

8 A. Dragan Spasojevic. Mr. Dragan Spasojevic was the commander.

9 Q. Was there someone above him or was he the police officer with the

10 highest rank?

11 A. No, there was the chief of the Police Administration, who was

12 hierarchically above him, and his name was Osman Mustafic.

13 Q. Thank you. Could you briefly describe to us how the various

14 departments in the Zvornik police were organised when you got there in

15 1991? Was there a traffic police department, a crime investigation

16 department? Could you briefly tell us how the police was organised in

17 Zvornik?

18 A. Yes. The police was organised in this way: There was a chief of

19 the Police Administration. He was the general chief of the police. Then

20 there was the commander or the commander of the police station who had

21 three assistants. One of the assistants was for the general police. A

22 second assistant was for crime affairs. And the third assistant was for

23 the regulation and control of traffic.

24 In addition to that, there was also a section of the crime police

25 as well as an administrative and support section.

1 Q. Thank you. I'll get back to these various departments, but

2 before that: Do you remember how many active policemen were working in

3 Zvornik when you got there in October 1991?

4 A. It was between 110 and 120 active policemen.

5 Q. What was their ethnicity?

6 A. The complete force -- the complete police force was balanced.

7 The ratio was approximately 50 per cent Bosniaks and 50 per cent Serbs.

8 Q. Thank you. You said that there was a crime investigation

9 department. Who headed that department?

10 A. Mr. Fadil Mujic was the chief of the criminal police.

11 Q. Who headed the general police force?

12 A. Mr. Marinko Vasilic was.

13 Q. Who headed the traffic police department?

14 A. Mr. Slavko Eric.

15 Q. Who headed the administrative unit of the police?

16 A. Madam Sehija Taljic was the chief of that unit.

17 Q. And you, yourself, you were in charge of what unit, what

18 department? What was your position in the police station?

19 A. I was one of the assistants of the commander of the police

20 station. According to the decision assigning me to my work post at that

21 moment in time. And at the same time, I also acted as deputy commander

22 of the police station.

23 Q. Very well. And the commander of the police station was Barijovic

24 [as interpreted]. I think that's the name you mentioned, wasn't it?

25 A. Yes, that is right.

1 Q. Who is Marinko Vasilic?

2 A. Marinko Vasilic was one of the assistant commanders of the

3 commander of the police station.

4 Q. I shall rephrase my question. What was his ethnicity?

5 A. He was a Serb.

6 Q. At some point, did you call on reserve policemen? I don't mean

7 you, personally. I mean your police station.

8 A. Yes. In October 1991. In October 1991, we were given an order

9 by the then Republican Secretariat of the Interior of Bosnia-Herzegovina,

10 to the effect that we were to mobilise a complete reserve police force.

11 Q. Overall, this reserve police force amounted to how many men?

12 A. Their number was double that of the active policemen on the

13 active force, so it was between 110 and 120.

14 Q. Can you specify? Are you saying that there were 220 reservists

15 or are you saying there were reservists plus the active policemen

16 amounted to double the amount of active policemen?

17 A. The number of the reservists was equal to that of active

18 policemen.

19 Q. Thank you. That's perfectly clear. After the call-up, did all

20 these men remain in Zvornik or were they dispatched here and there and

21 sent to various police stations?

22 A. After mobilisation, these forces did not all remain in the town

23 of Zvornik. They were assigned to another five localities in the Zvornik

24 Municipalities; namely, five police stations or branch stations,

25 substations, were established in five different locations.

1 Q. Would you list us the names of these places, please?

2 A. One of the police stations remained at the seat in the town of

3 Zvornik, and it was in the same building as the Public Security Station

4 of the town of Zvornik. Then there was another police station that was

5 set up in the village of Orahovac. Another one was set up in a place

6 called Sapna, and the third one in Kozluk, another one in Pilica, and

7 another a fifth one in Drinjaca.

8 Q. Thank you. How many men were there, on average, per police

9 station? And what I mean by that is I mean this includes the active

10 policemen and the reserve policemen?

11 A. That particular moment in time, we could not assign more than 10

12 to 15 active policemen to these branch stations or 15 to 20 reserve

13 policemen, which in total was about 30 or 35 people.

14 Q. The Sapna, Orahovac and Kozluk, these police stations -- well,

15 the commanders of these police stations reported to whom?

16 A. They all reported to the police station commander in Zvornik and

17 of course to the chief who was the overall commander, the overall chief

18 of the police.

19 Q. When you talk about the overall chief, commander of the police,

20 could you give us his name again, please?

21 A. The chief of the Public Security Station was Osman Mustafic, and

22 the commander, commandeer, was Dragan Spasojevic.

23 Q. Very well. Do you remember having been proofed Monday, Tuesday

24 and Wednesday of this week?

25 A. Yes, I do.

1 Q. Do you remember having drawn a diagram of the police station at

2 the time you were there?

3 A. Yes.

4 MR. DUTERTRE: Your Honour, I would like to display Exhibit

5 number 65 ter 7225, please.

6 We have a translation that arrived rather late today. It's not

7 in the binder, but it is in e-court.

8 Q. Mr. Alic, do you recognise this document as being the diagram you

9 drew of the police station in Zvornik?

10 A. Yes.

11 Q. Do you recognise your signature at the bottom of this document?

12 There it is.

13 A. Yes, I do.

14 MR. DUTERTRE: Your Honour, I would like to tender this document

15 into evidence, so please.

16 JUDGE ANTONETTI: [Interpretation] Madam Registrar, could we have

17 an exhibit number, please.

18 THE REGISTRAR: Your Honours, that would be Exhibit P438.

19 MR. DUTERTRE:

20 Q. Mr. Alic, on this sketch, which -- we can see that Mustafic is

21 Mr. Spasojevic's superior. Could you tell us in what circumstances

22 Mustafic headed the SBS and that things didn't happen the other way

23 around?

24 A. After the elections in Zvornik Municipality and the victory by

25 one of the parties, the party that was victorious, that won, they had the

1 key posts in the municipality, and in all these organs as well.

2 Q. Could you tell us more? Could you tell us which elections you

3 are talking about? On what date did these take place?

4 A. I was working in Belgrade at the time, not in Zvornik, in the

5 1990s.

6 Q. Thank you. Could you tell us which party won the elections?

7 A. In Zvornik Municipality, it was the SDA party that won, and it

8 was at its proposal that the Osman Mustafic came to be the chief, and the

9 SDS provided the second post.

10 Q. Could you specify what SDS and SDA mean?

11 A. The SDA is the Democratic Action Party, and the SDS is the

12 Serbian Democratic Party.

13 Q. And SDA had a particular ethnicity? What part of the population

14 did they represent?

15 A. They were mostly parties that rallied exclusively a population

16 from that same ethnic group. So the SDA rallied Muslims, Bosniaks, and

17 the Serbian Democratic Party rallied Serbs.

18 Q. Thank you. What was the -- what were the ethnic groups in

19 Zvornik?

20 A. Zvornik Municipality had a population of about 80.000. Of that

21 number, 51 per cent were Muslims, 47 or 8 per cent were Serbs, and the

22 rest were others; that is to say, Croats, Romanians and so on, all the

23 other ethnicities.

24 Q. Thank you. Do you know the ethnic makeup of Mali Zvornik?

25 A. Mali Zvornik is located in Serbia, but even there the population

1 is mixed. I can't give you the percentages, but I do know that there

2 were many Muslims living there.

3 Q. Thank you. Now, to remain on the issue of political forces, can

4 you tell us who the mayor of Zvornik was until April 1992?

5 A. The mayor was Abdulah Pasic.

6 Q. Is what was his ethnicity?

7 A. He was a Muslim, and he was from the SDA, the Democratic Action

8 Party.

9 Q. Who is Alija Kapidzic?

10 A. Alija Kapidzic was the chief of the National Defence Department,

11 and he was a Muslim.

12 Q. Was he a member of the SDA?

13 A. Yes.

14 Q. What other names of people belonging to the SDA in Zvornik can

15 you remember at the time?

16 A. I can't remember any names now. I wouldn't want to make a

17 mistake.

18 Q. Okay. Who set up the SDS in Zvornik?

19 A. The SDS of Zvornik was a municipal organisation of the Serbian

20 Democratic Party, and Mr. Brano Grujic headed it.

21 Q. Who were the other leading members of the local branch of SDS in

22 Zvornik?

23 A. I think there was Jovo Ivanovic, who was the President of

24 Executive Power in Zvornik Municipality, and some other people whom I

25 couldn't name now, because I don't want to get it wrong.

1 Q. Was Dragan Spasojevic a member of the SDS in Zvornik?

2 A. Dragan Spasojevic was appointed commander of the Public Security

3 Station in Zvornik, as being a member of the SDS.

4 Q. Do you know if he had relations with Brano Grujic?

5 A. Yes. They would see each other often at the police station. I

6 would see them there, and I attended their meetings regularly.

7 Q. What did Dragan Spasojevic call Brano Grujic; do you remember?

8 A. He called him "Big Daddy or "Veliki Tata." That's what he called

9 him. For whatever reason, I can't say; that he liked him or something

10 else.

11 Q. Which brings me back a little bit. When you're saying that

12 Dragan Spasojevic headed the SDS in Zvornik, do you mean that he was the

13 chairman? What was his title, exactly, within the SDS in Zvornik?

14 A. The president of the SDS. That's how my perception of him was,

15 the president of the Serbian Democratic Party, that was his political

16 function.

17 Q. Do you know if Brano Grujic had relations with Arkan?

18 A. Yes.

19 Q. Could you describe the relations between Brano Grujic and Arkan,

20 and how do you know about that?

21 A. I happen to know that because I was present on two occasions at

22 Crisis Staff meetings that were held at the time, and Abdulah Pasic, the

23 president of the municipality, held talks exclusively with the opposite

24 side, if I can put it there, his opposite number, and that was the

25 Serbian Democratic Party. Brano Grujic did maintain contacts with Arkan,

1 because he called Arkan and his forces to come to Zvornik to help him out

2 in taking over power and authority, taking over control there.

3 Q. Did you see Brano Grujic and Arkan together?

4 A. [No verbal response]

5 Q. Then how do you know that Brano Grujic had contacts with Arkan?

6 A. That's what he -- what Abdulah Pasic told us. Upon returning

7 from the meeting with Arkan, he reported to us and informed us what the

8 topics of discussion were and how the discussion evolved.

9 Q. Could you be more specific? What did he tell you, exactly? Did

10 he see both men together? What was his information based on, regarding

11 relations between Arkan and Brano Grujic?

12 A. Well, I can explain it in the following way: When the meeting

13 was organised in Mali Zvornik, at the Jezero Hotel, the meeting was

14 organised with Arkan, and the mediator was Mr. Grujic. He was the

15 go-between. And they all found -- they all happened to be at Jezero

16 Hotel, Alija Kapidzic, Pasic and all the people there that were there at

17 the time. They had discussions there. They discussed the problems that

18 were looming, the ultimatum of the Serbian Democratic Party and Arkan,

19 that the Bosniaks in the town of Zvornik should lay down their arms, hand

20 over power and authority. And when Abdulah Pasic returned from the

21 meeting, he informed us about that, and so at that Staff meeting they

22 tried to make some decisions and reach some conclusions.

23 Q. Okay. I'll come back to that meeting later. But since we don't

24 have a date yet, it might be not fully clear for the Chamber, but I'll

25 come back to that later on.

1 Do you know if Brano Grujic had relations with Mr. Seselj?

2 A. I don't know. I really can't say. I do know, as a member of the

3 service, that Mr. Seselj was supposed to visit Bosnia-Herzegovina or,

4 rather, the town of Bratunac, and his arrival was postponed, the reason

5 being that at that time on this side, there were strong police forces and

6 they were ready to arrest him. However, the Public Security Service at

7 the time reported this, and Mr. Seselj gave up on the idea of visiting.

8 JUDGE ANTONETTI: [Interpretation] There might be a mistake in the

9 transcript, Mr. Dutertre. At line 10 of page 28, the page we have here,

10 in the English version it is said "Mali Zvornik," in the English version,

11 whereas it seems that in the French version you said "the municipality of

12 Zvornik or Prevnik [phoen]."

13 MR. DUTERTRE: In English, page 28, line 10, the witness said:

14 "When the meeting was organised in Mali Zvornik --"

15 It's not up to me to give evidence. I don't see any mistake to

16 be corrected here, but we'll come back to that at a later stage, because

17 we'll take it in chronological order. I wanted him to give information

18 about relations with the accused.

19 JUDGE ANTONETTI: [Interpretation] Mr. Witness, the Prosecution

20 asked you at some point if you were aware of relations between Grujic and

21 Mr. Seselj, inducing us to believe that Mr. Seselj was internationally

22 known. Who was Mr. Seselj for you at the time?

23 THE WITNESS: [Interpretation] Mr. Seselj was the president of the

24 Serbian Radical Party.

25 JUDGE ANTONETTI: [Interpretation] And you knew that?

1 THE WITNESS: [Interpretation] Yes.

2 THE ACCUSED: [Interpretation] Objection. Since the Prosecutor's

3 already forgotten about it, we should set the time period, because the

4 witness said that I was supposed to visit Bratunac. When was that?

5 MR. DUTERTRE: That was exactly the point of my next question.

6 JUDGE ANTONETTI: [Interpretation] I believe the Prosecution will

7 make everything clear.

8 MR. DUTERTRE: Mr. Seselj, it's exactly the point of my next

9 question, but you're leading me to it. Thank you for that.

10 Q. Yes. It was still unclear in the chronology, but what time

11 period was that visit by Mr. Seselj to Bratunac planned?

12 A. I can't be precise as to the date, but I do know with certainty

13 that the visit by Mr. Seselj was announced and that, from Tuzla, the

14 Public Security Centre there sent a special unit, and they were present

15 in the police station throughout the time and waited for his visit to

16 Bratunac.

17 Q. Maybe so we can clarify matters, were you already in your

18 position in Zvornik or weren't you in your position? Is it before or

19 after October 1991?

20 A. Afterwards, after October. I think it was in 1992, in the first

21 few months of 1992.

22 Q. Understood. So to wrap up on the political forces and the

23 political composition of the municipality, do you know the ethnic makeup

24 of Zvornik today?

25 A. Today, there are very few Muslims there; exclusively a Serb

1 population. I don't think there are even 10 per cent of Muslims there

2 now.

3 Q. Good. Now, let's move on to military forces. Do you know if JNA

4 forces were stationed in the Zvornik area between October 1991 and April

5 1992?

6 A. Yes, I do know. In a place called Celopek, there was a complete

7 armoured battalion that was withdrawn from Jastrebarsko, from Croatia, so

8 it was stationed there in Celopek.

9 Q. What time did the battalion arrive in Celopek, if you remember?

10 A. That was during their withdrawal from Croatia, that period, and

11 they were located in this place called Celopek. And after that, at the

12 bridge in Karakaj, they set up the tanks, they positioned the tanks

13 there, and also at Divic, on the hydroelectric power plant there; dam, in

14 fact.

15 Q. Let's try and be more accurate. Could you indicate a month

16 during which they arrived? Was it in November, December? Could you give

17 us more detail to shed like on the subject?

18 A. The end of 1991. I think it was November or December 1991, when

19 they returned. Perhaps earlier, but certainly then.

20 Q. Who was the commander of this JNA military unit?

21 A. You mean the unit that was in Celopek, their commander?

22 Q. Yes.

23 A. I don't know the man's name.

24 Q. Who is Colonel Tacic?

25 A. He was an officer of the Yugoslav People's Army, and he had his

1 seat in the barracks in Tuzla. That's where his headquarters were.

2 Q. Understood. Were there members of the TO in Zvornik over that

3 period between October 1991 and April 1992?

4 A. Yes, there were.

5 Q. Apart from the Territorial Defence and the JNA, did you notice

6 whether any volunteers arrived between October 1991 and April 1992?

7 A. I apologise, but could you explain what you mean, please?

8 Q. Do you know if paramilitary volunteers arrived in the area of

9 Zvornik between October 1991 and April 1992?

10 A. Yes, I do know that.

11 JUDGE ANTONETTI: [Interpretation] Prosecution, in the question

12 there are "paramilitary volunteers." The question is somewhat

13 complicated.

14 The Prosecution asked you about volunteers, saying "paramilitary

15 volunteers." Were there paramilitary units? You know what are

16 paramilitary units, do you, and what is a volunteer for you?

17 THE WITNESS: [Interpretation] Yes, I do know that. The

18 volunteers were the people who were outside the system, outside the

19 system. The system was the regular army and the regular police force,

20 and also regular was the Territorial Defence. Everybody else was outside

21 that system, and that's where the volunteers belonged to, outside, those

22 who nobody could engage according to the law and pursuant to the law, but

23 they came in of their own will, voluntarily, or they were persuaded to

24 report.

25 JUDGE ANTONETTI: [Interpretation] Mr. Witness, you're a police

1 inspector. You're well educated and well informed. According to the law

2 at the time on defence matters, weren't volunteers taken into account,

3 people who would volunteer to be joining regular units? Wasn't that a

4 possibility legally provided for?

5 THE WITNESS: [Interpretation] During that period of time, the

6 system that we had was as follows: In case of imminent danger of war,

7 the Secretariat for National Defence had a reserve force, and he would

8 call that reserve force up in writing. The Ministry of the Interior had

9 its reserve force, and they would be called up in writing. These were

10 institutions regulated by law.

11 Then there was the regular Yugoslav People's Army, so that way

12 everybody knew where the reserve force was and had his reserve post.

13 Everything that happened within that system was according to the system

14 and governed by law. Everything else was irregular and outside the law.

15 JUDGE LATTANZI: [Interpretation] Mr. Witness, when you're saying

16 that it was irregular and outside the law, are you saying that on the

17 basis of Bosnian law or do you take into account the law still prevailing

18 in former Yugoslavia? Because if I understood what you said correctly,

19 here you're talking about volunteers or paramilitary people who are in

20 the fighting fields, but the non-Bosnian fighting fields?

21 THE WITNESS: [Interpretation] At that time, the laws that were in

22 force were Yugoslav laws. They were in force for everyone, and that

23 included us in Bosnia. So we all acted pursuant to the laws.

24 JUDGE LATTANZI: [Interpretation] You're saying "at that time."

25 What year was it?

1 THE WITNESS: [Interpretation] I'm thinking of all the time up

2 until -- at least as far as Zvornik is concerned, April of 1992, and I'm

3 speaking for Zvornik. After that period, for a time the laws were still

4 applied, but then new laws were in force because the states became

5 independent, they proclaimed their own constitutions. New constitutions

6 and new laws were made.

7 JUDGE ANTONETTI: [Interpretation] Your country,

8 Bosnia-Herzegovina, became independent at which date, exactly?

9 THE WITNESS: [Interpretation] I'm ashamed to say it, but I really

10 don't know the answer to that question.

11 JUDGE ANTONETTI: [Interpretation] Okay. But when the volunteers

12 arrived, was it still Yugoslavia, or Bosnia-Herzegovina already existed

13 with a president, Izetbegovic, so --

14 THE WITNESS: [Interpretation] I see. Before the arrival of the

15 volunteers in Zvornik, Bosnia-Herzegovina was a sovereign and independent

16 state, independently recognised, before the arrival, before their

17 arrival. So all volunteers that came in arrived to a state that was

18 internationally recognised and independent, sovereign.

19 JUDGE ANTONETTI: [Interpretation] Are you certain of that?

20 THE WITNESS: [Interpretation] 100 per cent.

21 JUDGE ANTONETTI: [Interpretation] Mr. Dutertre, you can move on.

22 MR. DUTERTRE: [Interpretation]

23 Q. Mr. Alic, you said you knew something about those volunteers.

24 Can you tell us what you knew about them?

25 A. As a member of the service at that time in Zvornik, I worked as

1 assistant commander of the police station, and all the work that that

2 entailed. After April 1992, four volunteers who had arrived from Serbia

3 were arrested at one of the barricades that was erected by the citizens

4 of Zvornik. They were stopped there, taken into custody, and handed over

5 to us at the police station.

6 Q. I will come back to that incident at a later stage. To stick to

7 the chronological order once again, and it might clarify a question I've

8 just asked.

9 What day did the attack on Zvornik take place?

10 A. The attack on Zvornik took place on the 8th of April, 1992.

11 Q. Understood. Okay, I will now try to go over the period between

12 October 1991 and April 1992, in a chronological manner, so as to point to

13 some salient events.

14 The first question: What were the relations like between Serbs

15 and Bosnian when you arrived in Zvornik in October 1991?

16 A. Relations were good, proper. At least my service, working in the

17 field, we had contacts with lots of people, and the relationships weren't

18 bad. They were good.

19 Q. You explained that official positions were allocated on the basis

20 of electoral results. When you arrived in October 1991, what were the

21 SDS claims on position allocation and administration? Did the SDS

22 accepting of the allocation? Did they object to the allocation or was

23 their position neutral on that?

24 A. Well, what I can say is this: When I arrived in Zvornik and was

25 sent to the Public Security Station, I came across the situation as it

1 was. However, the Serbian Democratic Party at the time was not satisfied

2 with its positions in the distribution of power and authority, and it

3 demanded that it be changed to its advantage. There were negotiations

4 that went on for days. The leaders of the SDA and SDS held consultations

5 about the different posts and adjustments that were supposed to be made,

6 and when the Serbian Democratic Party didn't like something, they decided

7 to reach those posts by force.

8 Q. Do you know whether crisis staffs were set up within the local

9 branches of SDS and SDA at Zvornik, and at what period of time?

10 A. I know for a fact that the crisis staffs existed at the time both

11 in the Serbian Democratic Party and in the Party of Democratic Action. I

12 know that for a fact, that is, that they existed. When they were

13 founded, I don't know. I cannot confirm that. I do know that they

14 convened and met, and the Crisis Staff of the Party of Democratic Action

15 met on two occasions at the police station, where I, as a present

16 officer, wanted to hear what was going on and was present at that

17 meeting.

18 Q. Very well. When you say you don't know exactly when these were

19 set up, could you tell us this: At the time you arrived in Zvornik in

20 1991, whether these crisis staffs in the SDA and SDS existed already or

21 not?

22 A. I believe that they did. The task of the crisis staffs at the

23 time was as follows, and this is what our police sources tell us and the

24 other information that we had at the time: The crisis staffs had the

25 task of homogenizing each one, its own ethnic structure, and to arm them

1 and prepare them for war.

2 Q. Very well. You anticipated my next question. Did you

3 notice - this is something you mentioned - that they were wearing weapons

4 or were arming each --

5 A. Yes.

6 Q. Getting weapons?

7 A. Armed. The Serbs were being armed by the army, and we know that

8 for a fact because military lorries actually brought in weapons and

9 distributed it to the Serbs. The Bosniaks, on the other hand, bought

10 weapons and they also armed themselves, but the Serbs had a much better

11 supply and much more pieces of weapons, because they received them, and

12 the Bosniaks bought their armaments. That is the difference. But both

13 peoples were arming.

14 Q. According to you, according to what you know, when did the

15 Serbian and Bosniak people start?

16 A. When I arrived in Zvornik, the situation was like that already.

17 Q. Very well. Did you notice any incidents while you were in

18 Zvornik, between October 1991 and April 1992, incidents which could have

19 been ethnic in nature?

20 A. Yes. Incidents of an ethnic nature started happening, and we, as

21 the police, were confronted with huge problems, trying to prevent such

22 incidents from happening, and to simply calm tensions and to see to the

23 establishment of some normal order in order to prevent any further

24 escalations of the situation.

25 Q. How many incidents do you remember?

1 A. There were many minor incidents, but there are two incidents

2 which merit attention, and I'm going to elaborate on these two on this

3 occasion.

4 When I arrived in Zvornik, one of these incidents had already

5 happened in a place which is also in Zvornik Municipality, in a place

6 called Kiseljak. A taxi driver was killed there brutally. His throat

7 was slit. And this was a citizen -- a Serbian -- a Serb citizen of

8 Zvornik. This incident created enormous problems for us, and we sought

9 to shed light on it in every possible way. But we never managed to do

10 so, because we were prevented because the war. I believe that this was

11 orchestrated incident at the time in order to, indeed, create an incident

12 situation between the Bosniaks and the Serbs, to raise tensions and to

13 give -- and to provoke the erection of barricades and all the other

14 things that attended the situation.

15 The second incident was in Sapna. There was a column of soldiers

16 of the Yugoslav People's Army approaching. Whenever they passed through

17 these places, they would also have reservists with them, and they would

18 shoot from the columns at the settlements that they were passing through,

19 at the mosques and different buildings, and the locals returned fire.

20 The locals of the village of Sapna returned fire, and one military

21 officer, who I believe was a warrant officer, was killed. And that is

22 the second incident which happened and which was also used as calls

23 for -- also brought about a tumultuous situation and the heightening of

24 tensions. Although we had the Tuzla police from their centre actually

25 undertaking the investigation, and the investigation was conducted by an

1 investigative judge, with Mr. Marinko Vasilic also from our station as

2 representing the Serbs, and Mr. Fadil Mujic representing the Muslims, we

3 composed a team intentionally in such a way for them to see to the

4 observance of the regularity of procedure, because we didn't want anyone

5 to tell us that we didn't act according to proper procedure.

6 MR. DUTERTRE: Thank you. It might be time to have a break.

7 JUDGE ANTONETTI: [Interpretation] Well, please, now, because

8 we'll only have one break today.

9 MR. DUTERTRE: [Interpretation]

10 Q. The simplest question to begin with: The second incident, what

11 date did that occur on, please?

12 A. I couldn't say with precision, but I do know that at the time I

13 was one of the commanding officers in the police station in Zvornik. So

14 it was in 1992.

15 Q. Very well. You mentioned that the first incident had been

16 orchestrated. Could you explain this to us? Who had orchestrated this

17 first incident, according to you?

18 A. I couldn't confirm that, but according to our information, the

19 information available to the police and the sources available to the

20 police from our intelligence sources on the ground, actually told us that

21 this was done -- had been done deliberately, that it was done in order to

22 heighten inter-ethnic tensions and to have the situation in the area

23 deteriorate.

24 MR. DUTERTRE: Thank you. If this is the right time to have a

25 break, well --

1 JUDGE ANTONETTI: [Interpretation] We shall have the break now and

2 resume at a quarter past 4.00, and then we will run on until 6.00 without

3 having a break.

4 MR. DUTERTRE: [Interpretation] Could you please let me know how

5 much time I have left?

6 JUDGE ANTONETTI: [Interpretation] You still have a lot of time

7 left. Madam Registrar, could you give us the countdown, please.

8 THE REGISTRAR: Your Honours, the Prosecution used 47 minutes so

9 far.

10 MR. DUTERTRE: [Interpretation] Thank you.

11 --- Recess taken at 3.55 p.m.

12 --- On resuming at 4.18 p.m.

13 JUDGE ANTONETTI: [Interpretation] Mr. Dutertre, you have the

14 floor.

15 MR. DUTERTRE: [Interpretation] Thank you.

16 Q. Mr. Alic, what happened in Celopek with members of the Serb

17 police in 1992?

18 A. At the time, a review was conducted of what they called the Serb

19 militia, the Serb police. These were policemen who also were part of the

20 Public Security Station in Zvornik, and they were on the active force.

21 This lineup and review of that unit was carried out by Spasojevic, the

22 then commander of the unit.

23 Q. Were there only Serbian policemen or also Bosnian police

24 officers, and if not, why?

25 A. There were no Bosniak policemen among them. It was only Serb

1 policemen who attended the -- this event, which was some sort of a dress

2 rehearsal of the Serbian police force in the town of Zvornik. This was

3 the last preparation, as it were, that took place.

4 Q. How did you find out about the event? What was your source of

5 information?

6 A. My source of information was the intelligence available to the

7 police, which was present there, and they wrote official records,

8 official notes, which were submitted to us, and we discussed them on the

9 next day at the meeting of the Staff Collegium in the police station.

10 Q. Can you tell us what was discussed at that meeting, what were the

11 conclusions of the meeting?

12 A. The staff meeting at the police station met very often and

13 convened on a daily basis, if necessary, and on the agenda were different

14 problems about the situation -- concerning the situation on the ground,

15 et cetera. On that occasion, I asked Mr. Dragan Spasojevic, in

16 connection with this problem, I said, "Dragan, please tell us, what kind

17 of a review was this that you undertook, what does it signify? Who was

18 obliged to attend?" Dragan just laughed, and he told me, "Well, this is

19 the police of the future Republika Srpska."

20 Q. Could you clarify at what point in time the incident in Celopek

21 took place; what month, what year?

22 A. I believe it was the end of February or the beginning of March,

23 1992.

24 MR. DUTERTRE: [Interpretation] Thank you.

25 JUDGE ANTONETTI: [Interpretation] Witness, a few dates. Just so

1 you know where you are, these are dates in the Prosecution's document on

2 the 27th [Realtime transcript read in error "28th"] of March, 1992,

3 Republika Srpska was officially proclaimed in Pale. On the 27th of

4 March, not the 28th. And on the 6th of April, 1992, the United States of

5 America and the European Community officially recognised

6 Bosnia-Herzegovina as an independent state. So these are two dates which

7 might be helpful to you and us.

8 MR. DUTERTRE: [Interpretation] Thank you, Presiding Judge. This

9 is extremely precious information.

10 Q. What happened in April, April 1st, 1992?

11 THE ACCUSED: [Interpretation] [Previous translation continues]

12 ... the United States of America and the European Community recognised

13 independence of Bosnia-Herzegovina means absolutely nothing. I insist

14 that you give the witness the date of the admission of Bosnia-Herzegovina

15 to the United Nations. That can be, in a certain sense, legally

16 relevant. The fact that the Americans and the European Community

17 actually recognised it is something that you can really discard as

18 totally immaterial.

19 JUDGE LATTANZI: [Interpretation] Mr. Seselj, to be part of the

20 United States, you need to be an independent state, so not even that date

21 would be helpful to us.

22 JUDGE ANTONETTI: [Interpretation] We also recall the issue of the

23 United Nations, but that comes at a later stage. Before you become a

24 member of the United States -- the United Nations, sorry, you first need

25 to become a state, and for that you need to be recognised.

1 Mr. Dutertre.

2 MR. DUTERTRE: [Interpretation] Thank you. I repeat my

3 question --

4 THE ACCUSED: [Interpretation] I have an additional objection.

5 Why did it not occur to you to say on which date Russia

6 recognised it, and China and India, on what day did China recognise? Why

7 do you always give precedence to America and the European Community,

8 which to me are hostile states?

9 JUDGE ANTONETTI: [Interpretation] If you have the dates, you can

10 provide them to us. I've read the Prosecution document which is attached

11 to the document. It's attachment 1. So I referred to the aforesaid

12 document. Now, if you have any other known date, the dates at which

13 Russia and China and India recognised, we will acknowledge those dates

14 quite willingly. But so far, I don't have these dates in the Prosecution

15 documents.

16 Okay, let's move on.

17 THE ACCUSED: [Interpretation] Mr. President, I'm not going to

18 interfere in the examination-in-chief, and I'm not going to provide you

19 with this information. I'm just stating my objection. The one who gave

20 you the previous information should supply you with the rest of the

21 information. This is the examination-in-chief, and I'm not going to

22 interfere.

23 JUDGE ANTONETTI: [Interpretation] Very well.

24 MR. DUTERTRE: [Interpretation] Thank you, Mr. Seselj.

25 Bosnia was admitted in the United Nations in May 1992.

1 THE INTERPRETER: The interpreter did not get the day.

2 MR. DUTERTRE: [Interpretation]

3 Q. Do you remember what happened on the 1st of April, 1992, in

4 Sarajevo, Mr. Alic?

5 A. On the 1st of April in Sarajevo, we had a scheduled meeting of

6 all members of the police. We all had to be present up there, and by our

7 presence, to show our shared commitment to having a united police force

8 remain as such in Bosnia-Herzegovina. So we were against any divisions

9 on an ethnic basis or any other sorts of divisions.

10 Q. What ethnic members of the police were present at that meeting on

11 the 1st of April?

12 A. No one was present of the Serb policemen at that meeting.

13 Q. Thank you. Did you notice whether Serbs or people of their

14 family left Zvornik at the beginning of April 1992?

15 A. Yes. They did so on a number of occasions, and I believe

16 personally observed that. This took place during the weekends. They

17 would leave in the afternoons. They would pack and put whatever they

18 could into their cars, and they would then cross the Drina River.

19 Q. And exactly how long before the attack on Zvornik did they start

20 leaving the town?

21 A. Almost a month or a bit more than that before that.

22 Q. Now I'll come back to the second incident mentioned by two

23 witnesses. You will remember that the witnesses mentioned two incidents,

24 one with a Serb taxi driver and others with shots in Sapna, so I'd like

25 to jog your memory, Mr. Witness, regarding the date of the incident.

1 Mr. Alic, do you remember testifying or providing evidence on the

2 13th of July, 1993, before an investigator of the Tribunal? It's a

3 written statement.

4 A. Yes.

5 Q. I will read part of paragraph 4, page 2, of that statement, and

6 I'll start reading:

7 [In English] "Ever since the war in the former Yugoslavia

8 started, JNA troops went through the Zvornik area and on their way to the

9 battlefields in Croatia on a regular basis."

10 THE ACCUSED: [Interpretation] Objection. There's absolutely no

11 reason for the Prosecutor to read out this portion of the statement. He

12 didn't ask any questions referring to that at all, so now he has to

13 remind the witness of a detail, so he has to ask the witness questions.

14 And if the witness can't remember a detail, then he can go and say,

15 "Well, this is what you said. Do you stand by that?" So it's, in fact,

16 refreshing his memory on the basis of the statement. So that's very

17 leading.

18 There were leading questions before this as well, but I didn't

19 decide to react because I didn't think it was too important. But this

20 has gone too far now.

21 JUDGE ANTONETTI: [Interpretation] Mr. Dutertre, Mr. Seselj is

22 voicing an objection I need to deal with. You're jogging the witness's

23 memory by reading a paragraph from a statement. This statement was

24 drafted over ten years ago, about twelve years ago, and understandably

25 it's possible to forget about things that you've written and find twelve

1 years before. I would be unable to remember that sort of thing. That is

2 why you've read to him this paragraph, because you felt that there were

3 uncertainties in his previous answers; is that the issue?

4 MR. DUTERTRE: [Interpretation] Your Honour, the witness mentioned

5 two incidents. He mentioned the date of the first one, approximately.

6 He didn't indicate the date for the second incident. Regarding the

7 second incident and the statement, a date is mentioned on the fourth line

8 of the paragraph which I started quoting. This is why I wanted to ask

9 the witness if that's what he remembers.

10 JUDGE ANTONETTI: [Interpretation] Go on, then.

11 Mr. Seselj, the Trial Chamber has decided that the Prosecution

12 can read the paragraph. Objection overruled. You don't have to comment

13 on this issue.

14 We understood that on the second incident, he was not able to

15 give accurate dates. This is why we are reading the paragraph to him, to

16 jog his memory.

17 What do you, yourself, do? When you have your own statements,

18 you read them to a witness. What is valid for you should be also valid

19 for the Prosecution.

20 Now, regarding whether it is a leading question or not, and the

21 dangers in that, this is only a question to have a more accurate date. I

22 don't see where the danger of a leading question would be. What do you

23 mean?

24 THE ACCUSED: [Interpretation] What I want to say is this: You

25 cannot say that what holds true for me holds true for the Prosecutor.

1 There are a set of rules for the examination-in-chief and other rules for

2 the cross-examination. The Prosecutor could have asked the witness

3 whether he remembers having said this in the statement, that the event in

4 Sapna happened on the 5th of April, 1992, on such-and-such a page, and

5 not reading an entire paragraph from the statement. That is not

6 refreshing his memory, in the sense of the Appeals Chamber ruling. What

7 he can do is say, "You said here that it was the 5th of April. What do

8 you have to say to that?" Because it's in my interest to hear when the

9 exact date was, and it was in fact three days before the final clash in

10 Zvornik took place. So it's in my interests for that to be stated. But

11 in principle, the way in which the witness's memory is refreshed and by

12 reading out this whole passage is not the right way to go about it.

13 JUDGE ANTONETTI: [Interpretation] As Mr. Seselj was speaking, I

14 was looking at the paragraph. The date is on the fourth line of that

15 paragraph, so read up until the fourth line, until the comma, the full

16 stop.

17 MR. DUTERTRE: [Interpretation] I would have said the date myself.

18 Maybe I would have been blamed for not reading the paragraph. If I read

19 the paragraph, I'm now being blamed for not giving the date. But

20 Mr. Seselj has given the date, the 5th of April, 1992. Now I can ask the

21 question directly to the witness.

22 Thank you, Mr. Seselj.

23 Q. Do you remember, Mr. Alic, that the second incident you mentioned

24 before took place on the 5th of April, 1992?

25 A. I said a moment ago that I cannot confirm the exact date. But

1 now I've heard what the date was, so I do believe that that is correct,

2 that it was, indeed, that date.

3 Q. Thank you, Mr. Alic. You indicated that Mr. Mujic and

4 Mr. Vasilic took part in the investigation. Could you tell us what

5 happened to them on the 5th of April, 1992, during their investigation?

6 A. This investigation was conducted by the investigating judge from

7 Tuzla. It was under his leadership, and the crime police from Tuzla, the

8 Security Centre, carried out an on-site examination, and we were included

9 in the team, and Fadil Mujic, the chief of the crime police, and Vasilic,

10 Marinko, supervised it, the assistant commander of the police station,

11 they supervised it. But the investigation was never completed, because

12 three days later in the town of Zvornik, everything had already escalated

13 and everyone went their own way.

14 Q. Did anything happen to Mr. Vasilic and Mr. Mujic on that day, on

15 the 5th of April, 1992, in the course of their investigation, which we

16 now know didn't --

17 A. Yes, at one of the barracks that was located between Karakaj and

18 Sapna.

19 Q. Who controlled the road blockage?

20 A. The locals, the citizens, the Serbs who were from the village.

21 Q. And what happened to Mr. Mujic and Vasilic at the roadblock

22 controlled by the Serbian inhabitants in the village?

23 A. They -- to all intents and purposes, they were arrested there,

24 and Mr. Mujic and him could not identify the people who had arrested

25 them, but they underwent great unpleasantness, and then even told that

1 the town of Zvornik could be attacked and razed to the ground.

2 Q. How did you find out about this? Did they tell you about it or

3 other people did?

4 A. Well, that story was told at the professional staff meeting, and

5 I was present there, and it was held the very next day.

6 Q. Who told that story?

7 A. Mr. Mujic and Mr. Vasilic. Both of them were members of the

8 Collegium, the staff.

9 Q. In the night between 5th and 6th of April, 1992, what happened in

10 Zvornik and the surrounding area?

11 A. In Zvornik, what happened was this: When the policemen, Serb

12 policemen, left the legal, regular Public Security Station, taking with

13 them a certain quantity of weapons and equipment, they went to Karakaj,

14 to the Standard building, where they set up a new police station.

15 Q. And during that night, did something happen regarding access to

16 the city of Zvornik?

17 A. Yes. On all the approach roads, barricades were set up, which

18 quite literally cut off the town of Zvornik from all the other places and

19 prevented exit and entrance.

20 Q. Who set up the roadblocks in the night between the 5th and 6th of

21 April, 1992, on the road to Zvornik?

22 A. They were set up by the citizens of Zvornik of Serb ethnicity.

23 Q. Do you remember drawing a map during your written statement to

24 the OTP investigator in 1997, showing the location of these roadblocks?

25 A. I did give statements, and I did make some sketches, but I can't

1 be precise.

2 THE ACCUSED: [Interpretation] Objection. I want to see this 1997

3 statement. All I have is the 1996 statement.

4 MR. DUTERTRE: [Interpretation] The 1997 statement was

5 communicated -- disclosed to the accused, so he should have it. But we

6 might be able to print it out again, but he received it.

7 THE ACCUSED: [Interpretation] Perhaps I did receive it at some

8 point, but I have no trace of it. I just have the 1996 statement in

9 front of me now.

10 MR. DUTERTRE: [Interpretation] It was communicated to the

11 accused. I'm formal on that. But we'll try to print it as soon as

12 possible.

13 I'd like to display Exhibit 65 ter 7223, please.

14 Q. Mr. Alic, is this drawing the one you did yourself at the time in

15 1997? That's the English version appearing. Do you recognise your

16 signature at the bottom of the drawing?

17 A. Yes.

18 Q. The various stations set up after the reserve policemen were

19 mobilised, you talked about Pilica, Orahovac. Do these various stations

20 appear on the drawing?

21 A. Yes, yes, they do.

22 Q. Could you show us, on the sketch, what the double lines in read

23 show? They appear on what seems to represent a road.

24 A. Those red lines, double lines, denote the place where barricades

25 had been erected.

1 MR. DUTERTRE: [Interpretation] Your Honours, I'd like to tender

2 the sketch into evidence.

3 JUDGE ANTONETTI: [Interpretation] An exhibit number, please.

4 THE REGISTRAR: Your Honours, that will be Exhibit P439.

5 MR. DUTERTRE: [Interpretation]

6 Q. Mr. Alic, what was the Bosnian inhabitants' in Zvornik reaction

7 when the aforesaid barricades were set up?

8 A. Well, you can well imagine what the reaction was when the

9 barricades suddenly crop up and stop all traffic.

10 Q. You indicated that during the night, the Serbian policemen left.

11 Could you tell us the names of some of these Serbian policemen who left

12 Zvornik?

13 A. Yes, the then commander Dragan Spasojevic was the commander up

14 there, and his assistants were Slavko Tadic and Marinko Vasilic, and they

15 were assistants in this other Zvornik Public Security Station, and all

16 the other Serb policemen.

17 Q. Very well. I'd like to move on now to the 7th of April, 1992, in

18 Zvornik. What happened in the morning of the 7th of April, 1992?

19 A. The 7th of April, 1992, that was a -- well, just prior to the

20 war, a state of siege, and a crisis staff meeting was held. I was

21 present to see what was being done there, and also present were

22 Abdulah Pasic, the mayor, Alija Kapidzic, and various other people, and

23 they said at that staff meeting that they had to go to Mali Zvornik

24 because they were called there, because Arkan was waiting for them there,

25 and that they were to conduct certain negotiations over there.

1 Q. You mentioned that Arkan was waiting for them there,

2 Abdulah Pasic and Alija Kapidzic. How had they been informed, through

3 what means?

4 A. They were called -- well, the liaison was Mr. Brano Grujic.

5 Mr. Brano Grujic attended the meeting, himself, in Mali Zvornik, at the

6 meeting in the Jezero Hotel.

7 Q. When you -- well, what happened at this meeting?

8 A. At the meeting, they failed to reach any agreement. And after

9 returning back from the meeting, they informed us what had happened over

10 there, and Mr. Pasic and Mr. Kapidzic said that they had many unpleasant

11 situations there and that Arkan sort of slapped them, and that they had

12 to compile a written report to the effect that there were 7.000 Green

13 Berets in the town of Zvornik and that this was some kind of a Muslim

14 army that was a threat to the Serbs and instilled fear in them. However,

15 that was not true, not correct.

16 Q. Very well. On the 7th of April, 1992, did you see Colonel Tacic?

17 A. Yes. Yes. Colonel Tacic said that he was going to come to the

18 municipal building from Tuzla, and the chief gave me orders that I should

19 go there and escort Colonel Tacic from the first barricade, from the

20 Karakaj direction. I forget the name of the place, Tereze [phoen] or

21 something. Anyway, I escorted him to the municipal building, and then I

22 waited for the meeting to be over to escort him back to Tuzla. Now, in

23 -- well, I talked to Colonel Tacic while escorting him, and he asked me

24 what was going on. And I said, "Well, Colonel, I ought to ask you what

25 was going on, because I see that all the military equipment is here, all

1 the military weapons, so I assume you should know what's going on." But

2 he never answered my question.

3 Q. Just a point of detail. You told us that you took him to the

4 mayor. We mentioned Mali Zvornik a few moments ago. Do you mean the

5 mayor of Mali Zvornik or Zvornik?

6 A. Zvornik Municipality, headquarters in Zvornik, not Mali Zvornik.

7 Q. Very well. What time was it, approximately?

8 A. It was about, well, between 12.00 and 2.00 p.m. That's when he

9 arrived.

10 JUDGE ANTONETTI: [Interpretation] A point of detail that could be

11 important. You escorted Colonel Tacic, and after that you take him back

12 because he has to attend a meeting at the town hall or municipality.

13 When he tells you, "What is happening here," was it on the outbound

14 journey or when you went back?

15 THE WITNESS: [Interpretation] While we were arriving, because he,

16 himself, could not pass through that barricade, to begin with.

17 JUDGE ANTONETTI: [Interpretation] Right. So when he is saying,

18 "What is happening," did you have the feeling that he had no idea of what

19 was going on, or did he say that by the by and you felt that he was fully

20 informed? What was your feeling about this at that time? I mean, one

21 doesn't escort a colonel every day, so this is something which you

22 certainly remember.

23 THE WITNESS: [Interpretation] I think that he was having me on

24 that day. I think that he was in complete control of the situation, that

25 he had all the information, firsthand information, about what was going

1 on.

2 JUDGE ANTONETTI: [Interpretation] Well, let's assume that he

3 wanted to mislead or abuse you. Why do you think he wanted to do that?

4 Do you have any explanation for that?

5 THE WITNESS: [Interpretation] Perhaps he was afraid, he was

6 afraid. He certainly knew -- he knew the date of the attack, and the

7 organisation, and now he was coming to the center of town which was only

8 populated by the Muslims and police members at that point in time. So he

9 was coming into a centre where the Muslims were.

10 JUDGE ANTONETTI: [Interpretation] If what you say is true, if you

11 were moving into an area which was controlled by the Muslims, he might

12 have been risking his life. So what was the point of going there? Can

13 you tell us?

14 THE WITNESS: [Interpretation] I wasn't present at that meeting

15 held in the municipal building. It was the party presidents and

16 Abdulah Pasic and Brano Grujic who were there and the rest, from the

17 leadership of both sides, both political parties. Colonel Tacic had

18 already positioned his tanks at the bridge at Karakaj a long time ago,

19 and at the dam, Divic, so that he had all the information at his

20 disposal, and nothing could have happened without his knowing about it.

21 And before that, I set up patrols of our police force at the time and

22 members of the army so that together we could perform our duties and

23 provide security for vital facilities. So the army was included in all

24 that to a maximum degree and disposed of all the information.

25 JUDGE ANTONETTI: [Interpretation] Very well. Please proceed,

1 Mr. Dutertre.

2 MR. DUTERTRE: [Interpretation]

3 Q. Have I understood you correctly? You were there to ensure his

4 safety while he was in the Zvornik area, where only the Muslims were

5 left, the Bosnian were left?

6 A. [Previous translation continues] ... and I escorted him from the

7 barricade to the municipal building. Then I waited in front of the

8 municipal building after the meeting to take him back in the direction he

9 wanted to go. Of course, before the barricade. I wasn't able to go

10 through the barricade itself, because I would have run the risk of

11 danger, whereas it wasn't dangerous for him.

12 Q. Very well. Do you know who attended the meeting on the Bosnian

13 side at the town hall in the presence of Colonel Tacic?

14 A. Abdulah Pasic, the mayor; Alija Kapidzic was there. He was in

15 the Secretariat for National Defence. Brano Grujic was the president of

16 the Serbian Democratic Party, and Jovo Mijatovic, yes, Mijatovic, he was

17 the president of the executive powers of the Zvornik Municipality, the

18 Executive Council, and some other people on both sides whose names I

19 don't know, and there was my chief of my police station, Osman Mustafic.

20 JUDGE ANTONETTI: [Interpretation] Do we have a problem?

21 [Technical difficulties]

22 MR. DUTERTRE: [Interpretation] Very well. It's working again.

23 Thank you.

24 Q. I don't know if this was a translation issue. Did you say

25 "Mijatovic" or "Jovo Ivanovic?"

1 A. Ivanovic, Ivanovic.

2 Q. Very well. Did you discover what the outcome of this meeting

3 was? Did you discover what had been decided there?

4 A. The result of the meeting was nil. The meeting was expected to

5 reach an agreement, and to provide protection -- for the JNA to provide

6 protection, but since at that time there was strong pressure and

7 propaganda for the Serbian Democratic Party to be handed over power, and

8 that weapons be laid down and the town handed over, those were conditions

9 that were completely unacceptable at the time, and that's how the whole

10 thing ended, without any major decisions and results.

11 Q. What happened in the afternoon between Arkan and the negotiators

12 Pasic and Kapidzic?

13 A. At that meeting - that's what they called it - they told us, both

14 Pasic and Kapidzic, that Arkan on the occasion had slapped them around a

15 few times and placed a knife under their throats and provided a piece of

16 paper so they could write down certain statements, which they in fact did

17 do. And upon their return to the police station, they informed us about

18 this and said, "We did what we did under pressure."

19 Now, if you consider that they should be prosecuted, go ahead.

20 JUDGE ANTONETTI: [Interpretation] Witness, you mentioned Arkan.

21 Who was Arkan, in your eyes?

22 THE WITNESS: [Interpretation] Arkan was a man from amongst the

23 ranks of the Serb people who had proclaimed himself some kind of military

24 leader over there. He had a group of volunteers, and he went to various

25 battle fronts with them. And those who belonged to him were known as

1 Arkan's Tigers, his men were known as Arkan's Tigers.

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

3 MR. DUTERTRE: [Interpretation]

4 Q. Could you clarify one point for us, please. Between Arkan and

5 the two negotiators, there was one meeting in the morning, one meeting in

6 the afternoon, is that right, or was there just one meeting? Could you

7 specify, please? We're still talking about the 7th of April, 1992.

8 A. I believe that there was just one meeting held, and that was the

9 first and the last one.

10 Q. Very well. How did the town mayor react to this meeting between

11 Arkan and the two negotiators; did he take any decision?

12 A. Upon returning from that meeting, the Crisis Staff met hastily in

13 order to inform us what transpired at the meeting. In view of the fact

14 that no conclusion or a decision could be taken that could actually

15 redress the situation and bring some sort of a solution, but only

16 featured pressures and ultimatums, it was these ultimatums that were

17 discussed at the Crisis Staff meeting.

18 One of the ultimatums was that by 10.00 on the next day, all arms

19 were to be laid down, that meaning the police had legal weapons and that

20 which had been collected by the Territorial Defence, and that authority

21 was to be handed over or that there would be war. Simply, the town had

22 to be abandoned. That was the option that we were confronted with, or

23 war.

24 Q. What option did the Crisis Staff take?

25 A. The Crisis Staff decided not to give in to the ultimatum, that

1 they would not lay down their arms, that we would defend the citizens,

2 the people and their property.

3 JUDGE ANTONETTI: [Interpretation] Witness, there was an ultimatum

4 on the 7th of April to disarm. This we understand. If I reminded you of

5 a date a few moments ago, this date was that of the 6th of April, when

6 Bosnia-Herzegovina had been recognised at that time, was this all

7 factored in by the Crisis Staff or not?

8 THE WITNESS: [Interpretation] He had in mind -- I have in mind

9 that Bosnia-Herzegovina had been recognised. Everybody knew this, but

10 one of the sides did not recognise that fact, nor does so today.

11 MR. DUTERTRE: [Interpretation] Thank you, Your Honour.

12 Q. Mr. Alic, I would like to address another issue now.

13 What happened on the 8th of April at 8.00 in the morning, please?

14 A. Yes. During -- for several days, I was in Zvornik all the time,

15 in the city of Zvornik, because I was unable to go home on account of the

16 barricades. I was literally cut off from my place of residence. I did

17 not live in Zvornik, so I was put up with my friends and spent nights in

18 different houses. Between the 7th and 8th, I slept at the house of the

19 mother-in-law of Mr. Mujic. It was only the police, the officer on duty,

20 who knew where we were spending the night. And sometime around 0100

21 hours on the 8th of April, 1992, they called us on the phone and told us,

22 "You should come to the police station immediately, as soon as possible,

23 because we have here four armed persons whom we have stopped and

24 arrested, deprived of liberty, at one of the barricades erected in the

25 city of Zvornik." They explained who it was -- I explained who it was,

1 and I explained what they should do in the police; namely, that all of

2 these people who had been deprived of liberty should be held in custody

3 separately in different offices in the presence of police guards, and

4 that they should wait for the morning hours until we came.

5 Q. Just a -- yes, fine. Let me take it one step at a time. What

6 was the ethnicity of these four men?

7 A. These four men were Serbs.

8 Q. In what car were they driving around in?

9 A. They were in a Mercedes passenger car.

10 Q. Where had this Mercedes been registered?

11 A. In Belgrade.

12 Q. I understand that they were all, the four of them, in the same

13 car. Is that right?

14 A. Yes, that's right.

15 Q. Where exactly were they arrested, if you know?

16 A. They were arrested at one of the barricades. The spot is called

17 Meterize. This is between the iron bridge on the Drina in Zvornik and

18 the bridge in Karakaj.

19 Q. Who was controlling this barricade?

20 A. This barricade was manned by citizens of Zvornik, Muslims by

21 ethnicity.

22 MR. DUTERTRE: [Interpretation] Your Honour, I would like to

23 display Exhibit number 7224, which is on the 65 ter list. This is a map.

24 Q. Mr. Alic, can you tell me whether you can see the location where

25 these four men were arrested on the map?

1 Perhaps Madam Usher can come and help the witness with the

2 pencil, if need be.

3 A. Well, all these little dots mark the city of Zvornik, so we would

4 have to actually identify the position of the iron bridge across the

5 Drina. That is in the city of Zvornik. And then from that, point back

6 in the direction of Karakaj. This is not a very precise map, in fact.

7 THE ACCUSED: [Interpretation] Objection. Judges, this is not a

8 sufficiently-large-scale map. It does not encompass all the points that

9 the Prosecutor asked about. We need a map that would cover a broader

10 area. One cannot see Karakaj on this map at all, nor can one see the

11 bridge in Karakaj, nor is the place marked where the Muslim barricade

12 was. Perhaps there are some dots, but it can't be seen, obviously.

13 MR. DUTERTRE: [Interpretation] Well, if it's not on the map, then

14 I'll move on to something else.

15 Q. What were these four men doing at this barricade where they were

16 arrested?

17 A. They had this task, and they proceeded with the intention of

18 meeting with some contact persons at the Jezero Hotel in Mali Zvornik.

19 But since they were did not -- were not familiar with the route, they

20 made a mistake and crossed at a previous crossing or made a previous

21 turn, so they crossed from the territory of Serbia into Bosnia, and

22 actually as they were looking around for a -- to find their bearings,

23 they actually came across -- ran across this barricade.

24 Q. Very well. And how do you know that; who told you?

25 A. In the early-morning hours, we arrived at the station, and I

1 personally talked to these people, and this they stated to me personally.

2 Q. What time did you reach the Zvornik police station?

3 A. This was sometime around 4.00 a.m., in the morning.

4 Q. And when you got there, had these men been searched?

5 A. Yes, they had been searched, and they were handcuffed with

6 regulation handcuffs.

7 Q. What objects had been taken off them after the search?

8 A. When I arrived at the station, everything that had been found on

9 them had been put on a table, on a desk in my office, and I saw the

10 weapons which they had. They had automatic rifles. They all had rounds

11 of ammunition; a combat kit, as it's called. They had short-barrelled

12 weapons, i.e., pistols. They had their IDs. They had strangulation

13 garrots. They had fingerless gloves, they had balaclavas, and this kind

14 of equipment which actually -- actually pointed to the conclusion that

15 they were headed for the front.

16 Q. You mentioned that you interrogated them. How much time did you

17 have to interrogate them ?

18 A. I interrogated them throughout the day, so I had other

19 businesses -- business to attend to. So actually I interrogated them on

20 a number of occasions, not just on one occasion.

21 Q. Until what time, approximately, during that day?

22 A. Until the afternoon hours, around 4.00 or 5.00 p.m.

23 Q. During these interrogations, did you gather them all together or

24 were they interrogated separately? Did you get any answers out of them

25 when you interrogated them?

1 A. Initially, I got different responses, different answers which did

2 not fit into my picture of the real truth. But as I said, I had several

3 interviews on several occasions, and when I put it all together, I got

4 the story that was expected and that was truthful, in fact.

5 Q. Very well. Out of these four people, were any of them relatives?

6 A. Yes. Of these four, two were brothers.

7 Q. I'd like to start with one of the two, the elder brother. How

8 old was he, approximately?

9 A. These two brothers, whose surname, I believe, was Vuckovic --

10 yes, it was Vuckovic, they were from the vicinity of Belgrade, or more

11 precisely Obrenovac, which is a suburb of Belgrade. Or more precisely

12 the place is called Umka. And the other brother was about 30 years old,

13 and the younger brother was around 26 or 27 years of age.

14 Q. Very well. For the time being, I would like to focus on the

15 elder brother. Do you remember that an ICTY investigator showed you some

16 photo boards in 1997?

17 A. Yes, I do remember.

18 MR. DUTERTRE: [Interpretation] Your Honour, I wish to display

19 number 65 ter 2524, page 2, please. Page 2. I would like to show page 2

20 of this document, please. This is in the court binder.

21 Perhaps we could place it on the ELMO to save time. Madam Usher,

22 could you perhaps try, please.

23 THE ACCUSED: [Interpretation] Judges, what is now shown on the

24 screen is something which cannot be shown to the witness for the

25 Prosecution. Photographs can be shown. If the witness does have any

1 problems with identification, well, then, remove this from the screen,

2 take it off.

3 JUDGE ANTONETTI: [Interpretation] I fully agree with that.

4 Mr. Dutertre, could you tell us where the photo spreads come

5 from.

6 MR. DUTERTRE: [Interpretation] Page 1, I didn't want it

7 displayed, and I can only agree with Mr. Seselj. As to the second page,

8 which I asked to be displayed, it's from a photo spread established by

9 the Tribunal and looked at by the witness during his second hearing in

10 1997.

11 Q. Mr. Alic, what you see here on the ELMO, is that part of the

12 photo spreads?

13 Can you narrow it down? Thank you.

14 Was it a photo spread shown to you?

15 A. Yes, it does -- it is.

16 Q. Your signature, bottom right?

17 A. Yes, I do recognise it.

18 Q. Did you recognise from the photo spread if anybody --

19 A. On the spread, I recognise the person under number 8.

20 Q. Who is that person?

21 A. That is one of the two men who had been arrested in the Zvornik

22 police station, and they are brothers. This is the older of the two

23 brothers, of the two Vuckovic brothers. I do not think but I claim, I

24 assilerate [as interpreted], that he had a nickname, Zuti.

25 Q. Very well. Circle number 08, and I'll come back to that.

1 A. [Marks]

2 MR. DUTERTRE: [Interpretation] I'd like to tender the photo

3 spread.

4 JUDGE ANTONETTI: [Interpretation] Registrar, a number.

5 THE REGISTRAR: Your Honours, that will be Exhibit P440.

6 MR. DUTERTRE: [Interpretation] Thank you.

7 I would now like to display a video clip from 65 ter 6059, clip

8 B, coming from the documentary film "Anatomy of a War Crime." Part of it

9 was tendered into evidence, but not that clip.

10 THE INTERPRETER: "Anatomy of a Crime by the Yellow Wasps."

11 Interpreter's correction.

12 THE ACCUSED: [Interpretation] I cannot hear a thing.

13 MR. DUTERTRE: [Interpretation] It's not what is said which I'm

14 interested in, but maybe you can show the clip again, the video again.

15 [Videotape played]

16 THE INTERPRETER: [Voiceover] "So that at first Slavonia was an

17 experience of pure defence of the place. It did not have an aggressive

18 character or anything like that. It was simply pure defence, setting up

19 the lines of defence."

20 MR. DUTERTRE: [Interpretation]

21 Q. Mr. Alic, who is the person speaking on the video?

22 A. This is the person that I circled, whose image I circled a minute

23 ago.

24 Q. Very well. What does "duty" mean?

25 JUDGE ANTONETTI: [Interpretation] Do you want to tender the

1 exhibit?

2 Registrar, a number for the video clip.

3 THE REGISTRAR: Your Honours, that will be Exhibit P441.

4 MR. DUTERTRE: [Interpretation]

5 Q. Mr. Alic, what does the term "Zuti" mean?

6 A. Zuti was his nickname.

7 Q. Is it the same thing as Zuco; is it two different ways of

8 pronouncing the same term?

9 A. Zuti or Zuco, it has the same meaning.

10 Q. What does it mean?

11 A. I don't know how he got his nickname, whether it was by the unit

12 that he belonged to, but when I saw him, he had long, lanky, greasy hair.

13 Whether it was blonde or not, maybe he got his nickname by his hair.

14 Q. Very well. Did he have a card of a member --

15 JUDGE ANTONETTI: [Interpretation] One detail. You've just said

16 he had long hair, but from the video or the picture, my feeling is he had

17 short hair. On picture number 8, the hair is extremely short, and on the

18 video it's short hair. So was it the unit members who had very long

19 hair? Why do you say that?

20 THE WITNESS: [Interpretation] I can speak concretely about these

21 two persons who were at the station. I wouldn't venture to say anything

22 about the rest of these individuals.

23 MR. DUTERTRE: [Interpretation]

24 Q. Did he have a card showing that he was a member of an

25 organisation whatsoever?

1 A. Yes. When we searched -- inspected the people, all the

2 documentation which they had on them was seized, and these two members

3 had identity cards, and I remember well they had double identity cards;

4 that is to say, in addition to identity cards which they had, they also

5 had other identification papers. First of all, they had the IDs of the

6 Serbian Chetnik Movement, that is, the Vuckovic brothers, and then they

7 also had IDs of the Serbian Radical Party. So both had both badges with

8 their particulars indicated in them, their photographs on them, and they

9 were duly stamped.

10 Q. Let's deal with the card -- membership card of the Serbian

11 Radical Party. Was it the first time you saw that card?

12 A. This is the first time I saw their newer identity cards, but the

13 older ones, which were marked on the front left side, there was written

14 "SCP," which meant the Serbian Chetnik Movement, and I believe they had

15 these IDs initially, and then later they changed the name for reasons

16 known to them.

17 Q. We'll come back to the explanation you've just provided.

18 Later on, did you have the opportunity to see other SRS

19 membership cards?

20 A. Later, I did have occasion to see that on soldiers that had been

21 taken prisoner. When they were taken prisoners, their IDs would be

22 seized, so I had occasion to see such identification papers.

23 Q. Was Zuco's SRS membership card identical, similar or different

24 from the other membership cards you saw later on?

25 A. I have underlined that these two brothers had double identity

1 cards. This second identity card which I saw was identical to the

2 identity cards that I had occasion to see later.

3 Q. For the purpose of clarity, the Zuco membership card was

4 identical to other SRS membership cards that you saw later on; did I

5 understand what you said correctly?

6 A. That's right.

7 Q. Line 8, page 12, I talked about the membership card of Zuco. It

8 doesn't appear on the transcript. Did you ask Zuco if it was his card,

9 membership card?

10 A. Yes, I did ask him, and as their photographs were inside, I

11 personally asked them whether they were the holders of these identity

12 cards, and they confirmed that, yes, they were.

13 Q. When you say "them," is it the two brothers?

14 A. Yes, that's right.

15 Q. Did you ask, to Zuco and his brother, whether they were members

16 of the SRSS?

17 A. Yes, I did ask them that.

18 JUDGE ANTONETTI: [Interpretation] The Judges scrutinize

19 everything, and we've just realised one thing, Mr. Dutertre. In the

20 written statement dating back to 1996 -- I'm checking whether it's the

21 right year. Yes, it is 1996. Page 5, English version, first paragraph,

22 top, these two brothers had identity cards from the Chetnik Movement.

23 The SRS is not mentioned. Why is it appearing now?

24 Look at the paragraph I'm mentioning.

25 MR. DUTERTRE: [Interpretation] I can only say the same thing

1 you're saying, Your Honour. Maybe you should ask the witness.

2 JUDGE ANTONETTI: [Interpretation] Mr. Witness, we're going to try

3 and jog your memory.

4 Back in 1996, a few years after the events, you mentioned those

5 two identity cards, but you said that they mentioned the Chetnik

6 Movement. Now it seems all of a sudden there's one card of the Chetnik

7 Movement and one card of the SRS.

8 MR. DUTERTRE: [Interpretation] Your Honour, page 4, 1, 2, 3, 4,

9 5 [indiscernible].

10 JUDGE ANTONETTI: [Interpretation] Do you have an explanation for

11 that? Are you sure that there was a card of the SRS?

12 THE WITNESS: [Interpretation] Absolutely certain.

13 THE ACCUSED: [Interpretation] Objection. Mr. President, I didn't

14 force you to notice this inter-react [as interpreted] but now don't allow

15 the Prosecutor to mislead you. It says here that they had an

16 identification of the Serbian Chetnik Movement, and then in brackets

17 "Seselj's Serbian Radical Party," which means they had one ID card of the

18 Serbian Chetnik Movement, and then the explanation is given, or

19 interpretation given, that it is the Serbian radical movement. That's

20 what it says here, so don't allow the Prosecution lead you astray. It is

21 obvious it is one ID card here, not two.

22 JUDGE ANTONETTI: [Interpretation] It would take a lot to mislead

23 me, but I'll check on what you've just said.

24 Mr. Dutertre, you were talking about page 4, paragraph 4 or 5?

25 No, page 4, paragraph 4.

1 MR. DUTERTRE: [Interpretation] So I read it out loud.

2 JUDGE ANTONETTI: [Interpretation] Very interesting, very

3 interesting.

4 Do you read English, Mr. Witness?

5 Well, in the English version, what is mentioned is cards from the

6 Serbian Chetnik Movement, and then between brackets "Seselj's Radical

7 Serbian Party." So I would need to check what appears in the B/C/S

8 version, which I do not have, to see whether the brackets were there as

9 well.

10 THE ACCUSED: [Interpretation] It's the same in Serbian,

11 Mr. President.

12 JUDGE ANTONETTI: [Interpretation] So who put that between

13 brackets? Did you tell the investigator, "Whenever it's the Chetnik

14 Movement, you have to say that it's Seselj's Serbian Radical Party," or

15 did you do that? Since you carried out crime investigation, you know

16 better than I do how things occur when you write out minutes. So who put

17 that mention in brackets? Was it your instructions or is it the

18 investigator's doing?

19 THE WITNESS: [Interpretation] In my statement, I said that two ID

20 cards existed, and that's the truth of it, that's correct. One ID said

21 "SCP" for "Serbian Chetnik Movement." That was one ID and that was

22 separate. The other ID card was of the Serbian Radical Party. That's

23 another type of ID. So it is true that they had double IDs.

24 Now, what it says there and how it was translated, I don't know.

25 I was answering questions just the way I am now.

1 THE ACCUSED: [Interpretation] Mr. President, take a look at the

2 statement that was given in 1997. Over there, this same witness says

3 that they carried ID cards which were issued by Seselj's paramilitaries,

4 so there's no Chetnik Movement or Serbian Radical Party. But once again

5 it is just one ID card, or membership card, rather, and you'll find that

6 on page 6 of the 1997 statement.

7 JUDGE ANTONETTI: [Interpretation] Very well. I do not have the

8 1997 statement. It wasn't provided to us by the Prosecution. But it

9 seems that there's still another version. You add the map -- the card,

10 sorry, by paramilitaries, whereas in the 1997, it wasn't indicated. So

11 it seems that a year later, you add the paramilitaries. How can you

12 account for that?

13 THE WITNESS: [Interpretation] Well, the paramilitaries -- of

14 course it was the paramilitary. The regular army was only the Yugoslav

15 Army. All the rest were paramilitaries.

16 JUDGE ANTONETTI: [Interpretation] Very well.

17 Move on, Mr. Dutertre. I was trying to clarify the matter. I'm

18 not sure I've succeeded, but I've tried.

19 MR. DUTERTRE: [Interpretation] Thank you, Your Honour.

20 Q. Did you ask Zuco whether he was a member of the SRS?

21 A. Yes, I did ask him, and he answered in the affirmative.

22 Q. Did you ask him whether he had an ideological leader?

23 A. Yes, I did ask him. And with those gentlemen -- I talked to

24 those gentlemen several times that day, and I asked them many questions,

25 but I didn't receive answers to them. And among other things, I asked

1 them, "Who is your main leader? Who is equipping you? Who provides the

2 logistics, the logistical support? Who is your liaison? How did you set

3 out? What was your objective? What did you have in mind?" I asked them

4 many of those questions, and they answered the way it says in my

5 statement.

6 THE ACCUSED: [Interpretation] Objection. I insist the witness

7 says what they answered, because there's none of that in his statement.

8 So all answers to all those questions, who their leader was, who equipped

9 them, and all the rest.

10 JUDGE ANTONETTI: [Interpretation] [Previous translation

11 continues] ... constantly interrupted. I believe the Prosecutor was

12 going to do that.

13 MR. DUTERTRE: [Interpretation] That's what I'm trying to do,

14 Your Honour, but I'll do it in the planned order, follow your order.

15 Q. So did you ask him who sent them to Zvornik?

16 A. Yes, I did, I asked them that. When I talked to them, I asked

17 them, "What is the reason for coming to Zvornik?" And they said that on

18 television, they had seen such news and footage according to which the

19 Serbs were jeopardized by the Muslims, and that they had their

20 organisations in several places, they had their headquarters, and were

21 sent by their superiors to contact the contact person who would meet

22 them. And I asked them, "Who is your leader," and they said,

23 "Mr. Seselj, the chief, the party chief." And I asked them, "Who

24 supplied logistic support, because you all have military equipment and

25 weapons." And they said they got it from the Yugoslav People's Army.

1 And I asked them how, and they said, "Well, our chiefs, our leaders, made

2 arrangements with some officers from the Yugoslav People's Army."

3 Q. I believe the answer actually answers all the questions I've

4 asked previously. Did you say with whom the agreement was signed with

5 the Yugoslav People's Army? You said "Our leaders, our chiefs." Did

6 they tell you who they were?

7 A. The main responsible person or leader was Mr. Seselj. Nobody

8 could have made any arrangements without him, without him giving his --

9 without him acquiescing, agreeing.

10 Q. Is did you ask Zuco whether the card from the Serbian Chetnik

11 Movement was his?

12 A. Yes, I did ask him, and he confirmed that by showing the

13 photograph that was inside the ID.

14 Q. I think you already answered that, but had you the opportunity to

15 see other membership cards of the Chetnik Serbian Movement?

16 A. Before that, I did see them.

17 Q. But Zuco's card, was it identical, similar, or different from

18 other Chetnik Movement cards you saw before?

19 A. The same.

20 JUDGE ANTONETTI: [Interpretation] Mr. Witness, we've already had

21 the opportunity to see investigation proceedings by the police, either in

22 Serbia, in Bosnia-Herzegovina, or Serbia, and based on my observations,

23 such investigations are not much different from investigations in my own

24 country. Therefore, when you interviewed those four people, did you

25 register or record the interviews on minutes, and were the objects seized

1 from them put under seal? How did that happen? Was it just a friendly

2 conversation for a few hours with four individuals?

3 THE WITNESS: [Interpretation] It was a proper official meeting,

4 and everything that we found on those people was taken away. And it was

5 my intention to compile a written report, although I'd already reported

6 the Tuzla Security Centre with our dispatch system, and the Ministry of

7 the Interior in Sarajevo, and the Republican SUP, I sent a telegram to

8 them, and I sought concrete instructions as to what I should do, because

9 at the time I was cut off from everybody, nobody could come and give me

10 assistance. And all the barricades around Zvornik, they were manned by

11 armed members belonging to different paramilitaries; and in fact the

12 conversation I had with them, I taped it, I recorded it, and it was my

13 intention to send the videotape to the then Republican television station

14 so that it could be shown on television and the news bulletin, so that

15 they could see what was going on, because in their statements they said

16 they had been duped, misled, tricked, that they had such-and-such an

17 agreement and set out with the intention of protecting the Serbs. But

18 when they saw everything, they said that they'd been tricked.

19 Now -- well, that's it. So all those membership cards, IDs,

20 permits that they carried on them -- they had different permits for

21 carrying weapons and moving around in the war zones unhindered, they had

22 in the station, and I had to leave the station under strong shelling, I

23 had to withdraw, and all that stayed there.

24 THE ACCUSED: [Interpretation] Mr. President, the Prosecution

25 never provided us with a copy of the dispatch which this person sent

1 allegedly to the Tuzla Security Service. It is possible that in Zvornik,

2 all the documentation was destroyed, but certainly not in Tuzla. So if

3 that dispatch was sent and if he told the Prosecution of all that, they

4 had to -- they must have found a copy of it.

5 THE WITNESS: [Interpretation] All the documentation is stored for

6 a period of ten years. After ten years, everything is destroyed. So

7 even if it did exist, it's been more than ten years, and all the

8 documents have since been destroyed.

9 JUDGE ANTONETTI: [Interpretation] So you're saying that you were

10 in Tuzla, the Ministry of Interior in Sarajevo, the SUP, and you've

11 recorded a videotape. Were you given any instruction or were you not

12 told anything?

13 THE WITNESS: [Interpretation] Yes, by phone, what I was able to

14 do by phone.

15 JUDGE ANTONETTI: [Interpretation] [Previous translation

16 continues] ... telephone?

17 THE WITNESS: [Interpretation] To investigate as much as possible

18 to see who these people were, because at first we didn't know who these

19 people were, we didn't know their intentions. And during the

20 interrogation during the day, we would learn new things, new information,

21 and after that certain people from Serbia were very interested and called

22 up and demanded that these people must be returned. We said that

23 these -- that they were important people, and they -- or, rather, they

24 said they were important people, and they said, "If you don't send us

25 those four people back to us, we'll kill the Muslims -- 20 Muslims that

1 we have in detention."

2 JUDGE ANTONETTI: [Interpretation] We're now being flooded with

3 information. Generally, when Judges start asking questions, we find out

4 quite a lot.

5 So you're saying that you received telephone calls from Serbia,

6 bringing some pressure to bear so that they would be released. Who was

7 calling from Serbia?

8 THE WITNESS: [Interpretation] Nobody talked to me, but they

9 talked to my colleague, Fuad Mujic. A man called Major Marko Pavlovic

10 rang up. That's how he introduced himself over the phone and he exerted

11 pressure. He talked to him. I didn't want to talk to this person,

12 Marko, and I didn't really don't know the man.

13 JUDGE ANTONETTI: [Interpretation] Just one last point of detail

14 before giving the floor back to Mr. Dutertre.

15 You said a number of things. Maybe I got this wrong, but you

16 said that these four individuals came for whatever reason and then

17 realised that they had been misled or that they hadn't been given the

18 right information. What did you mean by that?

19 THE WITNESS: [Interpretation] That's what they said, that

20 somebody had tricked them and that they set out with the intention of

21 assisting the Serb people, helping them, because they had information

22 saying that Serb people in Zvornik were under threat, that the Muslims

23 were setting fire to houses, raping and so on. And so in solidarity with

24 the Serb people, they set out to protect them, but when they arrived

25 there, they saw that this was not the case and they said that they were

1 tricked. And we said, "Who tricked you?" And they said, "Well, they

2 sent us from up there." They had their staffs or headquarters or

3 whatever in various locations from which they received those directives.

4 JUDGE ANTONETTI: [Interpretation] Mr. Dutertre.

5 MR. DUTERTRE: [Interpretation] Thank you, Your Honour.

6 Q. I would now like to move on to the second brother, Vuckovic. You

7 mentioned his name a few moments ago. He is a younger brother, and you

8 gave us his age, in approximate terms.

9 I would like to display Exhibit number 65 ter 2525, on page 2,

10 please. It's page 2 I would like to see and not page 1.

11 Mr. Alic, do you remember whether you were shown this photo

12 spread in 1997, when you gave a written statement? Do you recognise your

13 signature at the bottom of this document?

14 A. Yes, certainly.

15 THE ACCUSED: [Interpretation] Just a moment, please. Judges,

16 let's see that signature that Mr. Alic recognised. I didn't see it.

17 It's not here in front of me. I don't see it.

18 MR. DUTERTRE: [Interpretation] I think it's fairly easy to see,

19 but maybe --

20 THE ACCUSED: [Interpretation] I can see it.

21 MR. DUTERTRE: [Interpretation]

22 Q. Did you recognise anyone on this photo spread?

23 A. Yes, I did recognise number 6. He's one of the two men -- the

24 two brothers who were at the police station that day, and I think --

25 well, I don't think, I claim that this was the younger brother of the

1 Vuckovic brothers.

2 Q. Could you take the electronic pen and circle this person, draw a

3 circle around this person's picture?

4 A. [Marks]

5 JUDGE ANTONETTI: [Interpretation] Registrar, could we have a

6 number, please.

7 THE REGISTRAR: Your Honours, that will be Exhibit P442.

8 JUDGE ANTONETTI: [Interpretation] Madam Registrar, can I have the

9 countdown, please?

10 MR. DUTERTRE: [Interpretation] I would like to show 65 ter

11 number 6059. It's an excerpt from the same video clip, but has not been

12 tendered into evidence yet.

13 [Videotape played]

14 MR. DUTERTRE: [Interpretation] Can we show it again, please.

15 [Videotape played]

16 MR. DUTERTRE: [Interpretation]

17 Q. Mr. Alic, do you recognise the person who's standing in the

18 middle of the picture here, dressed in civilian clothes?

19 A. Yes, I do recognise him. That's the individual that I circled

20 the number 6.

21 MR. DUTERTRE: [Interpretation] Thank you.

22 I would like to tender this video clip into evidence, please,

23 Your Honours.

24 JUDGE ANTONETTI: [Interpretation] Mr. Dutertre, where does this

25 video clip come from?

1 MR. DUTERTRE: [Interpretation] As I told you, it's the

2 documentary called "The Yellow Wasps."

3 JUDGE ANTONETTI: [Interpretation] On this picture, Witness, which

4 you're discovering at the same time as we are - I don't know - but we

5 have the feeling that this gentleman is being handcuffed or somebody is

6 holding him by the arm. Who are the people wearing beret bearing an

7 insignia? Who are these people?

8 THE WITNESS: [Interpretation] I assume that they are the officers

9 of -- well, either members of the security service of the Detention Unit,

10 the prison, the police or whatever. We did not have that kind of thing

11 in --

12 JUDGE ANTONETTI: [Interpretation] From what prison, in what

13 country?

14 Mr. Dutertre, you've had one hour and 52 minutes.

15 MR. DUTERTRE: [Interpretation] Thank you, Your Honour.

16 Could I have an exhibit number for the video clip, please.

17 JUDGE ANTONETTI: [Interpretation] A number, please.

18 THE REGISTRAR: Your Honours, the video will become Exhibit P443.

19 JUDGE ANTONETTI: [Interpretation] Just a minute. I'm going to

20 put the question again, because my colleague has just told me that the

21 name of the country has not been recorded on the transcript, the name of

22 the country where this person seems to have been detained by some civil

23 servants.

24 Could you tell me which country this is?

25 THE WITNESS: [Interpretation] Are you asking me?

1 JUDGE ANTONETTI: [Interpretation] Yes.

2 THE WITNESS: [Interpretation] It's Serbia, the state of Serbia.

3 JUDGE ANTONETTI: [Interpretation] Very well.

4 MR. DUTERTRE: [Interpretation]

5 Q. Mr. Alic, did this person have a nickname, and if so, what was

6 it?

7 A. Both of the Vuckovic brothers had nicknames. The elder one had

8 the nickname of "Zuti," and the younger Vuckovic brother, and one we've

9 just seen, was "Repic," his nickname was "Repic."

10 Q. You anticipated my question. When did you find out that they

11 went by those nicknames?

12 A. When I talked to them, they did not tell me their nicknames.

13 However, on the 8th of April, late in the afternoon, they were exchanged.

14 They were taken back to Serbia. However, during that period, there

15 were -- well, the Muslim people would rally together in certain places,

16 locations, and those people appeared where the people were abused, they

17 took it out on the people, they would beat them up, and so these people

18 would refer to them as "Zuti" and "Repic." And I was told this by the

19 people who were exchanged from the camps and with whom I had official

20 interviews and sent them further on.

21 JUDGE ANTONETTI: [Interpretation] If you say that these were

22 exchanged, had you been given an order for them to be exchange?

23 THE WITNESS: [Interpretation] No, we didn't receive any

24 instructions or orders. The shelling of Zvornik began around 11.00, and

25 as time passed, there was more and more -- there was a fiercer -- the

1 attack became fiercer and fiercer. So at that point in time, as a police

2 officer, I remained alone in the station, and I tried, in all ways

3 possible, to protect the people, to protect the patients in hospital,

4 because the doctor had called me and asked for my assistance, and the

5 citizens called upon me, businessmen. People from the bank asked for my

6 assistance. They said, "They're coming in, they're looting, they're

7 destroying things." I couldn't do anything. However, my colleague, the

8 man who worked with me, he conducted an interview with Marko Pavlovic all

9 the time and reached an agreement without my knowledge or without

10 anybody's permission to escort those people across the Drinjaca dam, and

11 to hand them over, over there, and in return they would enable him to

12 have free passage through Serbia and into Germany and further on.

13 JUDGE ANTONETTI: [Interpretation] Very well. Mr. Dutertre.

14 MR. DUTERTRE: [Interpretation]

15 Q. You mentioned that some people who had been gathered in certain

16 locations mentioned "Zuti" and "Repic" to you. Could you tell me where

17 these people had been detained? Where had they been regrouped? Where

18 had these people come from?

19 A. They were the citizens of Zvornik who were Muslims, mostly, and

20 there was several locations, several venues where they would gather, and

21 those places were camps. One of those places was in the Municipal Court

22 in Zvornik, that building. Another was in the Standard factory. Another

23 was in an educational centre, another in Pilica, and many other places

24 where these camps existed, and where Bosniaks were, and where they were

25 mistreated in various ways, beaten, raped and so on.

1 Q. Could you make an effort and remember those other locations where

2 there were camps, as you say, and could you provide us as comprehensive

3 an answer as possible, please?

4 A. I've already said, at a number of locations in Zvornik. These

5 camps existed in several places. One of those places was in Liplje as

6 well, and subsequently I had an opportunity of talking to people from

7 Liplje because they were allowed to leave and exchanged, all of them.

8 And we took down their statements, we on free territory, of course. We

9 would talk to them and send them on further to certain other addresses.

10 Q. Do you remember any other names of camps which were given to you

11 by these people whom you interviewed?

12 A. They said that there was a camp in the Standard building in

13 Karakaj and the secondary school centre, that building, and in Drinjaca,

14 in Pilica, and many other places as well.

15 JUDGE ANTONETTI: [Interpretation] We will stop for now. You will

16 have 30 minutes left. So you will resume your examination-in-chief on

17 Tuesday. For the remaining 30 minutes, Mr. Seselj will have two and a

18 half hours for his cross-examination.

19 MR. DUTERTRE: [Interpretation] Would you allow me to put one last

20 question, which is connected to the previous one?

21 JUDGE ANTONETTI: [Interpretation] Well, yes, all right, put your

22 last question.

23 MR. DUTERTRE: [Interpretation]

24 Q. Mr. Alic, you mentioned having heard about these people called

25 "Repic" and "Zuco" by the people released. How did you establish a

1 connection between them and the people whom you had interrogated? How

2 did you find out that these were the two men you had interrogated?

3 A. [Previous translation continues] ... people who witnessed the

4 executions and who were subjected to torture described them in such great

5 detail that I realised straight away that that's who they were, because I

6 had spent whole days in the police building with them.

7 MR. DUTERTRE: [Interpretation] Thank you, Your Honour.

8 JUDGE ANTONETTI: [Interpretation] We shall resume the

9 examination-in-chief on Tuesday at 8.30, and the Witness Section will

10 escort you back into the courtroom on Tuesday.

11 --- Whereupon the hearing adjourned at 6.00 p.m.,

12 to be reconvened on Tuesday, the 20th day of

13 May, 2008, at 8.30 a.m.

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