Tribunal Criminal Tribunal for the Former Yugoslavia

Page 11726

 1                          Thursday, 17 October 2002

 2                          [Open session]

 3                          [The accused entered court]

 4                          [The witness entered court]

 5                          --- Upon commencing at 9.05 a.m.

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17                          [Open session]

18            THE REGISTRAR:  Your Honours, we're in open session.

19            JUDGE MAY:  The Trial Chamber is hearing this part of the session

20    in open session only to make this ruling:  The circumstances having

21    changed, we shall hear the rest of this witness's evidence in closed

22    session, the Trial Chamber being satisfied that it is in the interests of

23    justice to do so.

24            We shall go into closed session.

25             [Closed session made public by later order of the chamber]

Page 11728

 1            THE REGISTRAR:  Your Honours, we're in closed session.

 2            JUDGE MAY:  Yes, Mr. Groome.

 3            Yes, Mr. Milosevic.

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

 5            JUDGE MAY:  No.  We have ruled on this matter.  We ruled without

 6    argument.  It's an extremely serious situation and one which we must take

 7    prompt action.

 8            Now, yes, Mr. Groome.

 9                          Examined by Mr. Groome: [Continued]

10       Q.   Mr. Dulovic, yesterday we concluded, or you concluded your

11    testimony speaking about leaving Zvornik -- I'm sorry, leaving Visegrad

12    and speaking about an event that happened as you left Visegrad.

13            Sometime after you left Visegrad, did you return to Zvornik and

14    attempt to enter the town of Zvornik once again?

15       A.   Yes.

16       Q.   And can you tell us when that was?

17       A.   That was on the 10th of May, 1992.

18       Q.   Now, I'm going to ask you during your testimony to describe a

19    number of locations in Zvornik.

20            MR. GROOME:  And to assist the Chamber, I'm going to ask that the

21    witness be shown Exhibit 342, tab 4, and ask that it be placed on the

22    overhead projector.  And I'd ask if the director could zoom out so that we

23    can see more of the map.  That's good.  Thank you.

24       Q.   Mr. Dulovic, does this map indicate a rough representation of the

25    streets of the city of Zvornik?

Page 11729

 1       A.   Yes.

 2       Q.   I'm going to ask you to point, for the Chamber, to the bridge

 3    crossing from Mali Zvornik into Zvornik.

 4       A.   [Indicates]

 5       Q.   Mr. Dulovic, prior to your testimony before the Chamber, were you

 6    asked to label this map with a number of markings to indicate different

 7    places?

 8       A.   Yes.

 9       Q.   And did you indicate the bridge with the number C4-1?

10       A.   Yes.

11       Q.   I want you to next indicate to the Chamber the location of the

12    headquarters of the Territorial Defence.

13       A.   [Indicates]

14       Q.   And can you tell us what number you used to indicate that

15    location?

16            THE INTERPRETER:  Could the witness repeat that number, please.

17            MR. GROOME:

18       Q.   Mr. Dulovic, could you please repeat that number.

19       A.   C4-2.

20       Q.   Can you indicate the place where you will testify regarding a

21    meeting you had with a person by the name of Cele?

22       A.   Somewhere here.

23       Q.   Can you tell us --

24       A.   Not far from where it is indicated on the map.

25       Q.   Can you tell us how you marked that on the map?

Page 11730

 1       A.   D4-2.

 2       Q.   Could you please indicate where the Ciglani brick factory is

 3    located.

 4       A.   It's here.

 5       Q.   And how did you mark that?

 6       A.   The Ciglani brick factory is here.  D4-4.

 7       Q.   Is that D4 or C4 with which you marked that location?

 8            THE INTERPRETER:  Could the witness please repeat the letter,

 9    please?  We're not sure if it's D or T.

10            MR. GROOME:

11       Q.   Could you please repeat the letter that you used to indicate that

12    location.

13       A.   With a C.

14       Q.   Can I asked you to indicate the area of Celopek.

15            Perhaps if the map can be moved over to the left.

16       A.   Celopek is on this road towards Zvornik, and it is marked with

17    C4-5.

18       Q.   Thank you, Mr. Dulovic.

19            MR. GROOME:  I'd ask that that be left on the overhead, but I

20    won't be asking any questions now or in the immediate future.

21       Q.   Mr. Dulovic, when you returned to Zvornik area, can you describe

22    what, if anything, was remarkable about the Mali Zvornik side of the

23    Drina.

24       A.   Yes.  On the side of Mali Zvornik, on the bridge, towards the end

25    of the bridge, on that side, there was a line-up of sacks of sand,

Page 11731

 1    sandbags, and there were people there, some of them in uniform, others not

 2    in uniform, in civilian clothing, and on top of these sandbags was a

 3    machine-gun and a soldier who had -- was targeting the opposite side, the

 4    Muslim side.  He had his machine-gun pointing in that direction.

 5       Q.   Now, you've described seeing uniformed people there.  Can you

 6    identify -- or can you identify the units or institutions they were from

 7    by their uniforms?

 8       A.   Yes.

 9       Q.   Please do so.

10       A.   Or, rather, some of it I could see and not the others.  I could

11    distinguish the police uniforms and the military uniforms.  I was able to

12    distinguish those.  The man at the machine-gun was wearing a military

13    uniform or, rather, a camouflage army uniform.

14       Q.   And the men in police uniforms, were they from the Republic of

15    Serbia?

16       A.   Yes.  That's what the soldier told me, the one that I had a

17    lengthy conversation with who was up by the machine-gun, manning that.

18       Q.   What was the purpose of this particular visit to the Zvornik area?

19       A.   I wanted to see what was going on in Zvornik, because at that

20    time, there was large-scale propaganda to the effect that the Serbian

21    population in Zvornik was threatened and that crimes were being committed

22    against them, and I wanted to see for myself whether that was true or not,

23    because it didn't sound very convincing, what the papers were writing

24    about.

25       Q.   Now, when you arrived at the bridge, can you tell us what, if

Page 11732

 1    anything, you noticed about the bridge was different this time you were at

 2    Zvornik.

 3       A.   Yes.  On the other side of the bridge, there was a plaque or sign

 4    turned towards the Serb side, and on that plaque, it said "Republika

 5    Srpska."  That was written up on it.

 6       Q.   And did you attempt to cross the bridge?

 7       A.   Yes.  There was no problem.  They allowed me to go through and I

 8    passed across the bridge.  Before that, they had advised me that I was

 9    going at my own risk and suggested that I should not cross the bridge to

10    go into the Muslim side, cautioned me against it.

11       Q.   Prior to crossing the bridge, did you have a conversation with the

12    person behind the machine-gun?

13       A.   Yes.  I talked to that soldier.

14       Q.   Can you tell us in substance what he told you about the situation

15    at the bridge?

16       A.   He told me or, rather, I asked him why that machine-gun was

17    pointing to the other side when it says "Republika Srpska" there, and he

18    told me that they were on the bridge because there were various

19    paramilitaries or other units who were trying by force to cross the

20    bridge.  They had tried several times with weapons and with what they had

21    seized, the goods and material they had seized and wanted to bring over to

22    the Serbs.

23       Q.   And that is to cross from the Bosnian side of the bridge back into

24    the Serbian side?

25       A.   Yes, yes.

Page 11733

 1       Q.   Did there come a time when you did cross the bridge and stand foot

 2    in the Bosnian municipality of Zvornik?

 3       A.   Yes, I did.

 4       Q.   Can you please describe for us what you observed and what you did

 5    once you'd arrived in Zvornik.

 6       A.   As soon as I crossed the bridge, I saw a lot of people, mostly

 7    wearing civilian clothes, but armed.  Some of them were wearing camouflage

 8    uniforms or combined army uniforms with, for example, one part army

 9    uniform and the rest in ordinary trousers or jeans or whatever, and not

10    with army boots, but for the most part they were wearing ordinary civilian

11    shoes or sneakers.  And I knew that it wasn't the regular army and that

12    like the man up over there who I described during the last session, that

13    they were like that.

14       Q.   Now, you described for us yesterday that the first time you were

15    in Mali Zvornik, you could see Yugoslav army tanks in the Bosnian

16    municipality of Zvornik.  Could you see tanks there on this occasion?

17       A.   Yes, there were tanks there and artillery pieces.

18       Q.   And could you see whether those tanks and artillery pieces were

19    manned by regular members of the Yugoslav army or by members of these

20    paramilitary groups that you've just described for us?

21       A.   At the end of the bridge, edge of the bridge on the Bosnian side,

22    there was a tank right up by the bridge itself, and in that tank there was

23    a soldier, and he was coming out of the turret.  You could see his head

24    sticking out of the turret.  And I exchanged a few words with him.  I

25    don't remember what we actually talked about, but we exchanged a few

Page 11734

 1    sentences not of any importance.

 2       Q.   Did there come a time when you asked one of the people on the

 3    street to direct you to whomever was in charge in Zvornik?

 4       A.   Yes.  I asked several people, and I was told straight away, and I

 5    checked this out by asking others, they directed me towards the

 6    headquarters of the Territorial Defence in one of the streets in the

 7    centre of town itself.  At least, I had the feeling that this was the

 8    centre of town.

 9       Q.   And did they tell you the name of the person who was in charge?

10       A.   Yes.  Yes, they did.

11       Q.   What did they tell you his name was?

12       A.   They said it was a man called Marko Pavlovic.

13       Q.   Did any of these people indicate to you whether he was a native of

14    Zvornik or whether he was from somewhere else?

15       A.   They told me that it was Major Marko Pavlovic.  Nobody -- I asked,

16    "Is he from these parts, from here?  Is he from the Territorial Defence?"

17    And they said, "No.  He's a man who came here from somewhere else."

18       Q.   Is this the same Marko Pavlovic who you later learned had another

19    name, that is Branko Popovic, and who you later learned was associated

20    with Mihalj Kertes?

21       A.   It was Branko Popovic, in fact.  I learnt that his name was Branko

22    Popovic, and he himself, several years after that, confirmed that when I

23    talked to him in Sombor, because he was from the town of Sombor, and his

24    name was in fact Branko Popovic.

25       Q.   Did you go and speak with this man on the 10th of May?

Page 11735

 1       A.   Yes.  I went to see him in his office.  There was some sort of

 2    security detail, some armed persons in front by way of security.  I showed

 3    my journalist's ID card, and they let me go through.  I went up some

 4    stairs and went into the office, introduced myself, and that's where we

 5    had our conversation.

 6       Q.   Before I ask you about that conversation, I would ask you to

 7    describe for the Chamber the general appearance of the office.  Did it

 8    have things such as maps and other types of equipment one might expect to

 9    find in a command centre?

10       A.   I didn't notice that.  I don't know, actually.  I don't remember.

11    But it was an ordinary sort of office.  It was no different from any other

12    office in an administrative building, for example, as far as I remember.

13       Q.   Could you please tell us in substance what you discussed with

14    Major Pavlovic.

15       A.   I asked him what was going on over there in Zvornik.  He was

16    rather upset, visibly afraid and concerned because, as he said to me just

17    before that, he had had a problem.  It consisted of the following:  A

18    certain leader of a certain paramilitary group, his nickname was Cele,

19    that is the only thing that is known as far as he is concerned, and he

20    came and he mistreated him at his office.  He took out his pistol and he

21    placed it against the man's head.  That is what the man said to me, all of

22    this.

23       Q.   Mr. Dulovic, so that it is clear, who put the gun against whose

24    head?  If you would please use the names just so that we're clear on what

25    happened.

Page 11736

 1       A.   Cele came into the office of Marko Popovic or, rather, Marko

 2    Pavlovic, i.e., Branko Popovic, and he placed a pistol against his head.

 3       Q.   Now, did Cele belong to a particular paramilitary organisation?

 4       A.   Yes.  If it can be put that way, he was one of Seselj's men.  This

 5    was one of Seselj's units.

 6       Q.   And did Major Pavlovic say what it was that Cele wanted from him?

 7    Why did he put the gun to his head?

 8       A.   Yes.  Cele thought - now, I don't know whether that's correct -

 9    that Major Pavlovic was also taking part in that, namely that Cele cannot

10    cross the bridge with his men, with his booty, and with his weapons

11    because there were Serb forces on the other side that did not allow the

12    weapons and the booty to be carried in.

13       Q.   Now, did Major Pavlovic tell you about any phone calls he may have

14    made regarding this situation?

15       A.   Yes.  He said to me that he had called Radmilo Bogdanovic and

16    Seselj and that Seselj told him that Cele and his unit were out of control

17    and that they had nothing to do with him.  I don't know what he talked

18    about with Bogdanovic.  He didn't say that to me.

19       Q.   Is it that he didn't tell you what Bogdanovic said to him or did

20    he also not tell you what he said to Bogdanovic?

21       A.   No.  No.  At that time, Bogdanovic was a retired person but still

22    a person of considerable influence in the republican police.

23       Q.   And did Major Pavlovic tell you what he said to Bogdanovic?

24       A.   He didn't tell me.  He only said that he had called him.

25       Q.   Now, did there come a time that you left Major Pavlovic's office

Page 11737

 1    and encountered Cele himself on the streets of Zvornik?

 2       A.   Yes.  Not far away from there, I encountered Cele who was

 3    accompanied by two young men who were also armed.  He recognised me

 4    because it seems that we had seen each other before, in Borovo Selo or in

 5    some village around Borovo.

 6       Q.   And can you describe your encounter with him at that location?

 7       A.   I spotted them and they spotted me.  We were walking towards each

 8    other, and we had to meet.  Then he recognised me.  He spread his arms out

 9    and he introduced me to his two men as "the greatest Serbian journalist."

10       Q.   Did he --

11       A.   I accepted this conversation.  I spoke to him, although I did not

12    really remember him.

13       Q.   Can you describe for us how he was dressed and what, if any,

14    weapons he had with him.

15       A.   He had ammunition belts with ammunition.  He also had grenades at

16    his belt.  He was wearing a camouflage uniform.  He also had a Serb cap,

17    called sajkaca, with a cockade on it.  He wore a beard.  It was a pretty

18    long beard.  What I noticed was that he wasn't wearing leather shoes or

19    trainers.  He had a type of slippers on made of some kind of soft cloth.

20    It looked like sneakers, but it wasn't really sneakers.  That was quite

21    strange because it didn't really fit into what else he was wearing.  I

22    assumed that he had some problems with his feet.

23       Q.   Did you notice whether he had a knife with him?

24       A.   Yes.  He had a knife, a long kama, a double-edged knife, which is

25    characteristic, because at the top there was a crown, top of the handle.

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Page 11739

 1       Q.   And where was he carrying this knife?

 2       A.   On his hip, on his belt.

 3       Q.   And you've just indicated with your hand your right side; is that

 4    correct?

 5       A.   I don't know whether it was on the right side or on the left side,

 6    I can't remember any more, but it was on the hip.  It was on his belt, as

 7    this is usually worn.

 8       Q.   Did there come a time when Cele took you somewhere?

 9       A.   Yes.

10       Q.   And where did he take you?

11       A.   He said that we could go and have lunch together at a restaurant.

12    All four of us got into a car - I know that it didn't have any licence

13    plates - and we set out along the road, as I've shown on the map.

14       Q.   And the place that you indicate on the map where he took you is

15    C4-3; is that correct?

16       A.   Yes.  I had skipped that part, but before going -- or, rather, it

17    was at the end that we went to this restaurant.

18       Q.   Mr. Dulovic, the Judges have a copy of what you have before you,

19    so I think at this point now, it would be sufficient if you just let us

20    know the code name of how you indicated these different places.

21       A.   Yes.  He took me to where his unit was.  This was the first time I

22    ever saw this.  I didn't even know that it existed before.  It was like a

23    big factory.  Probably it was a factory.  It was called Alhos.

24       Q.   Did there come a time while at that factory that Cele took you to

25    a room and showed you some property in that room?

Page 11740

 1       A.   Yes.

 2       Q.   Can you describe for us what he showed you.

 3       A.   He showed me his medical team in a room where there were a few

 4    beds.  There were lots of TV sets there, video recorders, also music

 5    players and all kinds of other equipment.

 6       Q.   Did you form an impression whether these were new TV sets and

 7    other electronic equipment or whether they were used pieces?

 8       A.   The first thing I realised and noticed was that none of this was

 9    new.  All of it had been used.  That was obvious.  Also, it wasn't packed

10    in the boxes the way these things come, but the TV sets and the video

11    recorders were stacked like books.

12       Q.   Did he also take you to introduce you to some women that were

13    present there?

14       A.   Yes.

15       Q.   And who did he indicate that these women were?

16       A.   He said to me that that was the medical company, his medical

17    company.

18       Q.   And what did you understand that to mean?

19       A.   I was supposed to understand that they were nurses.  They didn't

20    look like nurses.  They were wearing mini skirts, short ones.

21       Q.   Did he describe a confrontation that he had with somebody

22    regarding these women?

23       A.   Yes.  After having introduced these nurses, he told me that Peja

24    - that's Arkan's deputy who was also in Zvornik - while they were

25    somewhere out in the field cleansing the field, he gathered them up, put

Page 11741

 1    them on a bus and transferred them across the Drina River to Serbian

 2    territory.

 3       Q.   Now, yesterday you described two men by the name of Peja that were

 4    associated with Arkan.  Were you able to ascertain which one of these two

 5    men Cele was referring to?

 6       A.   I think it was the Peja who was nicknamed Ciganin, the Gypsy.  I

 7    can't remember any longer exactly whether it was one or the other.  I did

 8    not know them.  I had heard about them but I did not really know them.

 9       Q.   Did there come a time when you left this headquarters building of

10    Cele and go to another facility in the town of Zvornik?

11       A.   Yes.  He insisted that we go together to the brick factory, and

12    that wasn't very clear to me, that is to say why we were going, but I did

13    go.

14       Q.   And can you describe for us your observations once you arrived at

15    the brick factory.

16       A.   They told me that in Zvornik, only the brick factory was still in

17    operation.  There were finished products there, rather, bricks, that were

18    stacked up as usual at a brick factory, and he took me to see the manager,

19    who was in his office.  We talked there.

20       Q.   What ethnicity was the manager?

21       A.   Obviously a Serb.  He was introduced to me as the manager.

22       Q.   And what, in substance, did the manager say to you?

23       A.   Until the present day, I cannot -- I cannot understand what Cele

24    did.  He told me about some business deals and that this factory would be

25    prosperous and contribute to the development of Zvornik as a town, as if

Page 11742

 1    he had an interest involved, a business interest.  That is the only way in

 2    which I could interpret his interest in the brick factory.

 3       Q.   Aside from the manager, were there any other workers around that

 4    you could see?

 5       A.   No.  No.  It's interesting that I didn't see any workers at all.

 6       Q.   And do you recall what day of the week this was?

 7       A.   I do not recall which day it was, but later on, we established

 8    that it had been a Sunday.

 9       Q.   And is that by looking -- you were able to establish that by

10    looking at a calendar from that year?

11       A.   Yes.

12       Q.   Now, after you left the brick factory, did Cele take you somewhere

13    else?

14       A.   After leaving the brick factory, we went to have that lunch that

15    he said that we should go to.  We went to this restaurant.

16       Q.   And where was that restaurant?

17       A.   Approximately, as far as I can remember, about four or five

18    kilometres away from Zvornik.

19       Q.   And was that travelling northward or southward?

20       A.   This road.  That is to say to the north, if the south is there.

21    Or, rather, if the north is there and the south is down here, and this is

22    the west, according to this map -- or, rather -- or, rather, this was

23    downstream.  This road also went by the Drina River, so it was down the

24    Drina River.

25       Q.   And did you mark the area where you were taken for lunch on that

Page 11743

 1    map as C4-5?

 2       A.   Yes, that's the road.  That's the road that goes there.

 3       Q.   And what is that area of Zvornik popularly known as?

 4       A.   I don't know.  Maybe I knew before but I've forgotten.

 5       Q.   How long did the lunch last?

 6       A.   As far as I can remember, several hours.  I cannot establish the

 7    exact time.

 8       Q.   Can you describe for us some of the things that you discussed with

 9    Cele?

10       A.   He did most of the talking.  He told me about the successes of his

11    unit in, as he had put it, "cleansing the field."  I had no idea then what

12    this meant, "cleansing the area," the field.  I understood that from what

13    he was saying.

14       Q.   Did you ask him to tell you what he meant by "cleansing of the

15    field"?

16       A.   Yes.  "Cleansing the field" means liberating it from the Muslim

17    population.

18       Q.   And did he describe for you an operation of such cleansing that he

19    had participated in the night before, the 19th of May?

20       A.   Yes.  He said to me that they were cleansing the field all night

21    and that they did not fire a single bullet, but that they were working

22    only with cold steel.  I understood what he meant.  And then when he said

23    that, he used his hand to touch that knife.  I have a very vivid memory of

24    that.

25            Then I asked him, "Was it everybody?"  And I sort of showed

Page 11744

 1    children like this with my hands, and he said, "Yes, so that they would

 2    never return."  That is something that you remember forever.

 3       Q.   And for the record, you held out your hand about a metre off the

 4    ground.  Is that what you did to indicate you were asking him what

 5    happened to the children?

 6       A.   Like this.  I meant children, and he understood it that way, yes.

 7    That meant that children were also killed the way he had put it to me, and

 8    that is how I understood it, because he said, "So that they would never

 9    return again."

10            JUDGE MAY:  You put, Mr. Groome, the 19th of May.  I thought

11    earlier the date of this visit to Zvornik was the 10th of May.

12            MR. GROOME:  My apologies, Your Honour.  You are correct.  I'll

13    correct that with the witness.

14       Q.   Mr. Dulovic, your visit to Zvornik was indeed on the 10th of May;

15    is that correct?

16       A.   Yes.  Yes.  That's what it says in my diary -- in my notes,

17    rather.

18       Q.   So I was incorrect when I said the night before was the 19th.  In

19    fact, it was the 9th of May, is that correct, that he's describing this

20    event to you?

21       A.   I don't know the date really.  I just know that above these notes

22    it says the 10th of May.

23       Q.   Before the lunch concluded, did Cele ask you to call several

24    people on his behalf?

25       A.   Yes.  He asked me whether I knew Vojislav Seselj.  I said to him

Page 11745

 1    that I know him but that I don't know where he might be and how I could

 2    get in touch with him.  Then he gave me some telephone numbers that I

 3    wrote down; the home telephone number and the office telephone number.

 4       Q.   Are you able to recall those telephone numbers as you sit here in

 5    court today?

 6       A.   No, but I did have them at the moment when I talked about this

 7    before.  I had the originals of all my notes, and all of this became part

 8    of the record, as far as I can remember.  I cannot recall now.  I never

 9    even tried to remember them.

10       Q.   Did you record those numbers in your statement to the Office of

11    the Prosecutor of the Tribunal?

12       A.   Yes.

13            MR. GROOME:  Your Honour, I would ask that the witness be

14    permitted to refresh his recollection as to those numbers by looking at

15    his statement.

16            JUDGE MAY:  Yes.

17            MR. GROOME:

18       Q.   I've opened up your statement to page 9.  I'd ask you to look at

19    the paragraphs towards the bottom of that page and ask you if that

20    refreshes your recollection as to the numbers you were asked to call.

21       A.   Yes.

22       Q.   What was the office number of Vojislav Seselj?

23       A.   Yes, yes.  444-8712.

24       Q.   And what was the home number?

25       A.   848-3428.  That is what he had dictated to me.

Page 11746

 1       Q.   Thank you.

 2            MR. GROOME:  If I could have the statement back.

 3       Q.   Now, what was the message that Cele asked you to convey to

 4    Mr. Seselj?

 5       A.   What I found in my writing pad said the following:  "Pejo is after

 6    Cele to arrest him."  That is what I had written down.  And then it also

 7    said:  "Five per cent of the population of Zvornik will join the Radical

 8    Party, and I await further instructions."

 9       Q.   Did you ever call Mr. Seselj and pass on this message?

10       A.   No.

11       Q.   Whom else did he ask you to call?

12       A.   As far as I can remember -- oh, yes.  Yes.  Yes.  He also asked me

13    whether I knew Zeljko Raznjatovic.

14       Q.   And that is Arkan?

15       A.   Arkan.  And he also dictated to me what I was supposed to tell

16    him.  He said to me, "Pejo --" or, rather, "With all due respect" - he

17    addresses him, "With all due respect" - "Pejo is working against the Serb

18    cause."

19       Q.   And did you take this to mean the Pejo who you described as being

20    an associate of Arkan?

21       A.   Yes.  Yes.  One of his senior officers in the guard.

22       Q.   Did you ever pass that message on?

23       A.   No.

24       Q.   Now, did there come a time before you left the area of Zvornik and

25    Mali Zvornik that you once again saw Major Pavlovic?

Page 11747

 1       A.   Yes, I did see him again.  I think it was several years later.  I

 2    can't remember exactly in what year.

 3       Q.   Did you ever see him again on the 10th of May, before you left

 4    Zvornik this time?

 5       A.   Yes, I did.  I saw him on the Serbian side in a cafe.  It was

 6    called either Mali Zvornik or Mali Raj.  I don't recall exactly what its

 7    name was, but it was the only cafe on the bank of the river.  It was

 8    actually part of a hotel.

 9            I saw him in the evening, and he said that his family was being

10    threatened somewhere, he didn't say where, and that he had to go to

11    Belgrade urgently.  As far as I know, he did go.

12       Q.   Did there come a time when you had a conversation with some of the

13    soldiers along the Drina regarding large birds that were flying in the sky

14    on the 10th of May?

15       A.   Yes.  It was with one of the people on the bridge, on the Serbian

16    side.  Eagles were flying around in large numbers, and I noticed that.  I

17    told him that, and he was a little -- I was a little surprised.  And he

18    said to me, "There have never been more corpses floating down the Drina

19    River than there are now."

20       Q.   Now, sometime later did you become aware of and set out to

21    investigate a set of serious allegations regarding events in the area of

22    Celopek in Zvornik?

23       A.   I forgot to mention that I believe the man's name was Marko

24    Pavlovic, but Cele then told me that that was not his real name and that

25    he came from somewhere in Vojvodina.  I was very interested in this, and

Page 11748

 1    then I heard, when I was writing about this topic, somebody rang me up and

 2    told me that Marko Pavlovic was in fact Branko Popovic and that he came

 3    from Sombor.

 4       Q.   Is Sombor in Vojvodina?

 5       A.   Yes.  Sombor is in Vojvodina, yes, yes.  I managed to find out

 6    beyond any doubt by going to Sombor and interviewing Branko Popovic, alias

 7    Marko Pavlovic.  Respectable people from Sombor told me that he was a

 8    member of the local State Security Service.

 9       Q.   Now, I want to draw your attention to the events in Celopek.  Did

10    you as a journalist set out to investigate allegations that you became

11    aware of of certain events in Celopek?

12       A.   Yes.

13       Q.   Can you give us a general description of the allegation that you

14    were investigating.

15       A.   I investigated a massacre of civilians in Celopek or, rather, in

16    the local community centre which is by the roadside, along the road that

17    leads to Celopek.  The civilians who were inside were shot at, and it was

18    Vuckovic, Dusan Vuckovic, also known as Repic, who killed -- I don't

19    remember the exact number, but some 15 people and wounded about 30.

20       Q.   Did -- are these the same Vuckovics that you referred to as being

21    members of the Yellow Wasps yesterday?

22       A.   Vucko Vuckovic.  Yes.  Yes.  His -- he was the elder brother of

23    Vojin Vuckovic.  His brother Vojin Vuckovic was the commander of the

24    Yellow Wasps, and the other brother was called Dusan, also known as Repic.

25       Q.   Now, in the course of your own investigation into the events at

Page 11749












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Page 11750

 1    Celopek, did you cooperate in the production of a documentary of what

 2    happened in Celopek?

 3       A.   Yes, we did make a documentary and interviewed the protagonists of

 4    these events.  Well, not Dusan but his brother, the commander of the

 5    Yellow Wasps, Vojin Vuckovic.

 6       Q.   And did you personally interview Vojin Vuckovic?

 7       A.   No.  It was a colleague of mine who did that, but it was a man we

 8    had worked with who was a filmmaker, as we say.

 9       Q.   Did you personally interview Vojislav Seselj in the creation of

10    this documentary?

11       A.   Yes.

12       Q.   And did you also interview a person by the name of Jose Mendiluce?

13       A.   Yes.

14       Q.   Now, earlier this week were you asked to view a videotape of this

15    documentary?

16       A.   Yes.

17            MR. GROOME:  Your Honour, I ask that the witness be shown a

18    videotape, just the physical cassette and not the playing of it, and it is

19    marked as Prosecution Exhibit 342, tab 13, and the translation is in the

20    binders.  I would just ask that the witness be shown the actual video

21    cassette.

22            JUDGE MAY:  Yes, he can do that.

23            MR. GROOME:

24       Q.   Mr. Dulovic, is that the cassette that you looked at?  And how do

25    you know that --

Page 11751

 1       A.   Yes, I marked it myself.

 2       Q.   Did you write the date that you looked at it and C-004 on that

 3    cassette?

 4       A.   Yes.  It's my handwriting.

 5            MR. GROOME:  Your Honour, I'm going to propose the following:  I

 6    think it's probably more appropriate to view -- for the Chamber to view

 7    this videotape at the time we deal more specifically with Zvornik, but

 8    there is a 30-second or 40-second portion of the tape of an interview that

 9    Mr. Dulovic did with Mr. Seselj that is cued up and ready to be played

10    now.  I'd ask that this --

11            JUDGE MAY:  Let's just examine the matter for the moment.  The

12    transcript which we have deals, I take it, with the entire video.

13    Plainly, at this stage that is not admissible because it deals with

14    comments by witnesses and that sort of thing which we wouldn't admit.  But

15    you're asking for the passage of the interview with Seselj to be admitted.

16            MR. GROOME:  That's on page 14, Your Honour.

17            JUDGE MAY:  Page 14 of the transcript.  Yes.

18            MR. GROOME:  Your Honour, the Prosecution would ask the Chamber to

19    consider the admission of the entire tape as an investigative documentary,

20    produced by an independent organisation and person unrelated to the Office

21    of the Prosecutor, realising that it may have less weight than the people

22    who give interviews, but certainly there are some interviews which the

23    Prosecution would argue should have some significant weight, namely that

24    of Vojin Vuckovic, one of the perpetrators of the crime.

25            JUDGE MAY:  Well, we need to consider this, because we don't admit

Page 11752

 1    videos.  We haven't so far admitted videos in which people describe what

 2    has happened, on the grounds that it's not the best evidence.  I seem to

 3    remember several such instances.

 4            Plainly what somebody in the conspiracy or the joint enterprise

 5    mentions, such as Seselj, that could be -- that's admissible, and indeed

 6    if there are other admissions of crime, they may or may not be admissible.

 7    But at this stage, you want simply to introduce page 14, that passage; is

 8    that right?

 9            MR. GROOME:  Yes, Your Honour.

10            JUDGE MAY:  Yes.  And I think we would leave the admissibility of

11    the rest of the video until we've heard further evidence.

12            MR. GROOME:  Yes, Your Honour.  Can I make just one further point

13    on that?  This video also does show the areas involved.  Can I lay a

14    foundation with that with the witness?  It may be of benefit to the

15    Chamber at least to see the area of Celopek.

16            JUDGE MAY:  Yes.  Yes.

17            MR. GROOME:

18       Q.   Mr. Dulovic, does the documentary also show Celopek, Zvornik, and

19    other areas related to the crimes that occurred in Zvornik?

20       A.   Yes.

21       Q.   Does it also contain some footage from Vukovar which you've

22    testified and show the areas of Vukovar that you described yesterday?

23       A.   Yes.

24            MR. GROOME:  Your Honour, at this time I'd ask that that 40-second

25    portion be played and that we view that and I'll ask the witness some

Page 11753

 1    questions afterwards.

 2            JUDGE MAY:  Yes.

 3                          [Videotape played]

 4            "Dulovic:  Yesterday you said on television that Milosevic was the

 5    one who supplied the weapons to your men, that he participated actively in

 6    all of this and then just turned his back on you.

 7            "Seselj:  Yes, that's a fact.  [Interpretation] In 1991 and 1992

 8    Milosevic was a leading nationalist and a patriot at that time we had

 9    close cooperation.  When 30.000 paramilitary volunteers were sent to the

10    fronts where Serbian people had to fight he was the one who supplied the

11    arms, the ammunition, the clothes and the food, he provided the

12    transportation, he allowed the use of military facilities and so on, and

13    so on."

14            MR. GROOME:

15       Q.   Mr. Dulovic, the voice on the tape was a translator purportedly

16    translating the statement made by Mr. Seselj.  My question to you is:  As

17    the person who interviewed Mr. Seselj, was that an accurate translation --

18    or is that an accurate statement of what Mr. Seselj said when you

19    interviewed him?

20       A.   When I interviewed Dr. Vojislav Seselj, I don't speak English, but

21    this is what he told me, because this part referred to particular matters.

22       Q.   Now, can you tell us approximately when it was you interviewed

23    Dr. Seselj on this matter?

24       A.   I don't remember the year.  It's on the tape, the date when it was

25    made.  I think it might have been 1996, perhaps, but I can't be sure.

Page 11754

 1       Q.   Now, when you put the question to Mr. Seselj regarding the supply

 2    of volunteers and paramilitaries, were you referring to the paramilitaries

 3    and volunteers that you had personally observed in Vukovar, Zvornik, and

 4    Visegrad?

 5       A.   Yes.

 6       Q.   Now, when Mr. Seselj said that Mr. Milosevic supplied 30.000

 7    paramilitary volunteers with weapons and clothes and et cetera, did he at

 8    any time later in the interview say that that was an exaggeration or

 9    retract that statement in any way?

10       A.   No.  No, he didn't.  While I was interviewing him, he didn't say

11    that that was an exaggeration, nor did he ever deny what he had said, at

12    least not to me.

13       Q.   And the period of time that Dr. Seselj alleged that he received

14    this support from Mr. Milosevic was both in 1991 and in 1992; is that

15    correct?

16       A.   Yes, it is.  Yes.

17       Q.   So at least a portion of that support --

18            MR. GROOME:  Your Honour.

19            MR. TAPUSKOVIC: [Interpretation] Your Honours, I only wish to say

20    that this is a recording made in 1996.  A few days ago, we discussed this

21    extensively.  I think no one can explain what somebody else meant to say,

22    what somebody else thought.  We discussed this several days ago, and you

23    took up a position.

24            JUDGE MAY:  Yes.  It's a matter for us to determine.

25            MR. TAPUSKOVIC: [Interpretation] Of course.

Page 11755

 1            MR. GROOME:

 2       Q.   So my question to you was:  So at least a portion of the support

 3    that Mr. Seselj is referring to occurs after the urgent --

 4            JUDGE MAY:  Well, this is the point he makes:  We can determine

 5    this.  It's not really for the witness to comment on.

 6            MR. GROOME:  Yes, Your Honour.

 7       Q.   Mr. Dulovic, I want to ask you a few questions regarding the role

 8    of the media and from your own experience as a journalist during this

 9    time, and I want to begin by asking you:  During the course of the

10    conflict, can you approximate for us how many stories or articles you

11    submitted to Politika Ekspres per week?

12       A.   It depended on the situation and on the events that were taking

13    place, but I tried to send a longish text or a piece of information every

14    day.  Whenever I was able to do so, whenever I had material, I did.

15       Q.   And in your view, was the reporting that you submitted, was it an

16    accurate reflection of the events that you observed and interviewed people

17    about?

18       A.   Yes.

19       Q.   And were all of your submissions printed or published?

20       A.   No.  No.  Most of them were not.

21       Q.   Of the ones that were published, were any of the words that you

22    had written, originally written, were they ever changed?

23       A.   Yes, they were.

24       Q.   Can you give us an example?

25       A.   For example, during the siege of Vukovar, I never used the word

Page 11756

 1    "Ustasha" or "bojovnik," meaning "soldier."  I referred to the Croatian

 2    army and Croatian volunteers.  What happened was that someone in a

 3    position of responsibility in the editor's office would change my words

 4    and use the expressions "Ustasha" and "bojovnik."  I didn't like this, and

 5    I protested.  I asked that this not be done any more.

 6       Q.   And what was the -- what response did you receive?

 7       A.   They said it wouldn't happen again.

 8       Q.   Were you -- and did it happen again?

 9       A.   No, but then my stories were no longer printed at all.

10       Q.   Did there come a time when -- during a meeting of yourself and

11    your editor-in-chief when your editor-in-chief received a phone call?

12       A.   Yes.  We were all in the room where meetings were held and the

13    phone rang.  The editor-in-chief, Slobodan Jovanovic, spoke on the phone,

14    and when he put down the receiver, he said that we had greetings from

15    Slobodan Milosevic.

16       Q.   Now, Mr. Dulovic, you personally witnessed the JNA's entry into

17    the town of Visegrad.  Did there come a time after that that you were able

18    to read and see the media coverage of that event?

19            JUDGE KWON:  Mr. Groome, before that, could we get the date when

20    Mr. Milosevic had called the editor-in-chief?

21            MR. GROOME:  Yes, Your Honour.

22       Q.   Mr. Dulovic, can you tell us, as best you're able, when that

23    meeting took place?

24       A.   Meetings took place every day, so it's really impossible to

25    remember the date.  But the only thing I can say was that it was during

Page 11757

 1    the time when Slobodan Jovanovic was editor-in-chief of Politika Ekspres.

 2    Exactly when he was appointed and when he was dismissed, I don't know.  I

 3    didn't feel it necessary to remember these dates, and I can't remember

 4    them now.

 5            JUDGE KWON:  What's the year then?  Do you remember the year?

 6            THE WITNESS: [Interpretation] Not even the year.

 7            MR. GROOME:

 8       Q.   Do you remember when -- when you left the employment of Politika

 9    Ekspres?

10       A.   Yes, in 1990 something.  I don't know.  I have a written document,

11    but I don't recall the date.  I don't have a good head for dates unless I

12    write them down.

13       Q.   Are you able to say whether this meeting occurred during the

14    conflict or after the conflict?

15       A.   After the conflict, I think.

16       Q.   Now, I want to return to the issue of Visegrad.  Can you describe

17    for us the press coverage and the media coverage of the JNA entry into

18    Visegrad and express your opinion whether or not you felt it was accurate?

19       A.   I was present when they entered Visegrad.  There was no

20    resistance, but the papers said that after hours of intensive fighting,

21    the army entered Visegrad.

22       Q.   And was that just one or two papers or was that the general view

23    of all of the newspapers?

24       A.   It was in all the state-sponsored newspapers, which were in the

25    vast majority.  There were hardly any others.

Page 11758

 1       Q.   Thank you, Mr. Dulovic.

 2            MR. GROOME:  Your Honour, I have no further questions of

 3    Mr. Dulovic at this time.  In response to Your Honour's suggestion

 4    yesterday that we have a stock-taking, I propose just to state for the

 5    record the exhibits that I believe sufficient foundation has been

 6    established for, if that suits the Court.

 7            JUDGE MAY:  Yes.

 8            MR. GROOME:  In Prosecution Exhibit 342, the Prosecution would

 9    tender all exhibits from 1 -- tab 1 to 13, subject to the limitations the

10    Chamber has expressed on the record.  And with respect to Prosecution

11    Exhibit 343, that is the maps, the Prosecution would tender tabs 1 through

12    4.

13            JUDGE MAY:  We will admit the 40 seconds of the video.  The rest

14    will simply be marked for identification, no more.  I'm sure the registry

15    could work out a way of doing that.  Very well.

16            THE REGISTRAR:  Yes, Your Honour.

17            JUDGE MAY:  Thank you.

18            MR. GROOME:  Your Honour, may I make one suggestion regarding

19    maps, if I may?  I expect during the course of the case, we'll be asking

20    other witnesses to make marks on a copy of the same map.  May I suggest

21    that the maps that Mr. Dulovic marked on, that the suffix C4, his witness

22    number, be added to that and that, when future witnesses testify, that

23    their witness number be added as a suffix to the same tab -- tab number.

24    Perhaps in that way, at the end of the case, all of the same maps will be

25    in the same tab.

Page 11759

 1            JUDGE MAY:  Yes, we could do that or they could be given numbers.

 2    All right.  Or the initials, the registrar recommends.  But we'll keep

 3    them together in some way, which obviously is the important thing to do.

 4            MR. GROOME:  And would Your Honour also like for the Prosecution

 5    to submit a blank copy of all photographs and maps so that the Chamber

 6    also has an unmarked version of all of these maps and documents?

 7            JUDGE MAY:  I think we're all right, speaking for the Bench.  We

 8    don't need any more.  We've got them.  Has the registry got a copy?  They

 9    may have a view.

10            THE REGISTRAR:  I only have copies of the marked.  I would prefer

11    to have --

12            JUDGE MAY:  Yes.  Let the registry have the clean copy.

13            MR. GROOME:  Thank you, Your Honour.

14            JUDGE MAY:  We're going to adjourn now, Mr. Dulovic.  Could you be

15    back, please, in 20 minutes.

16                          --- Recess taken at 10.30 a.m.

17                          --- On resuming at 10.55 a.m.

18            JUDGE MAY:  Yes, Mr. Milosevic.

19            THE ACCUSED: [Interpretation] Mr. May, I would like us first of

20    all to clarify this question of a closed session for the

21    cross-examination.  The witness testified publicly all day yesterday, so

22    it is my right, with respect to what he was testifying about yesterday

23    publicly, to cross-examine him also publicly, because this is quite

24    obviously a media operation, and I have emphasised on several occasions

25    thus far that you are making -- you are working in a media environment and

Page 11760












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Page 11761

 1    not a legal environment.  So if he was enabled to testify publicly

 2    yesterday throughout the whole day, I also have the right to cross-examine

 3    him publicly about the matters that he testified to yesterday.

 4            I will not be asking him, of course, in the public session of the

 5    cross-examination anything about what he testified today in today's closed

 6    session.  We can leave that for a closed session, although some of the

 7    matters raised yesterday and today -- some of the matters he raised today

 8    were raised by him yesterday as well.  But I would like to cross-examine

 9    him publicly only on his testimony yesterday, otherwise, we can't speak of

10    any equality of arms between the two parties.

11            JUDGE MAY:  Mr. Milosevic, this is what you call a legal

12    environment.  It is we who are the Judges who hear the evidence.  As to

13    whether the public hear it or not, that is a matter which may be subject

14    to the security considerations which we've mentioned already, but we'll

15    hear what the Prosecution have to say and then we'll allow the witness to

16    address us on it.

17            MR. GROOME:  Your Honour, it's difficult to address you on it

18    because I'm not sure what the witness's view is on it.  May I have an

19    opportunity to address you after we hear Mr. Dulovic's views?  Of course,

20    our primary concern is the security of his family.

21            JUDGE MAY:  Yes.  Mr. Dulovic, the accused is asking to

22    cross-examine you in open session about those matters which were the

23    subject of open-session evidence yesterday.  Now, we have ordered that

24    your evidence be heard in closed session because of the threats which have

25    been made to your wife.  The only reason could be for an open session are

Page 11762

 1    something to do with the public nature of the proceedings, but it is, of

 2    course, subject to security matters.

 3            Yes.

 4                          [Trial Chamber confers]

 5            JUDGE MAY:  Mr. Dulovic, on reflection, we're not going to ask you

 6    your views about the matter.  We've come to the conclusion that this is a

 7    matter entirely for us.  We're going to remain in closed session.

 8            Yes, Mr. Milosevic.

 9            THE ACCUSED: [Interpretation] Mr. May, in view of the fact that I

10    would like to challenge everything that this witness has said, everything,

11    I think that the interests of justice have been deeply harmed by your

12    decision not to allow this to go public.

13            JUDGE MAY:  Mr. Milosevic, we shall hear your challenge.  And

14    since it's we who are judging the case and nobody else, no harm is done to

15    the interests of justice.  Now, we've ruled on the matter.

16            Now, would you like to begin your cross-examination.

17            THE ACCUSED: [Interpretation] Mr. May, you are well aware of the

18    fact that secret trials belong to the very distant past, and I have evoked

19    that on several occasions.

20            JUDGE MAY:  And, Mr. Milosevic, you should be aware of the

21    seriousness of threats being made to the families of these witnesses.

22    This Court will take very seriously its duties to protect its witnesses.

23            Now, get on with the cross-examination and stop arguing.

24            THE ACCUSED: [Interpretation] Very well, Mr. May.

25                          Cross-examined by Mr. Milosevic:

Page 11763

 1       Q.   [Interpretation] Mr. Dulovic, you have behind you a long

 2    professional career as a journalist.  Did you ever read that very lucid

 3    sentence of the famous German Otto von Bismarck who said the following:

 4    Lies are made most before voting, during a war, and after hunting"?

 5            JUDGE MAY:  That's not a relevant question.

 6            MR. MILOSEVIC: [Interpretation]

 7       Q.   I think that what we have been hearing here for a day and a half

 8    shows just how relevant it is and how very true the quotation I stated a

 9    moment ago.

10            Mr. Dulovic, you made two statements, one in October 2001 and one

11    five years before that, in the month of May, 1996.  That's right, isn't

12    it?

13       A.   Yes.

14       Q.   I'm going to read something out from the first two or three pages

15    of your statement of the year 2001, and then I'll go on to ask you some

16    questions about that.

17            Let's skip all this about when you met people from the OTP and so

18    on, but you say:  "At the beginning of August 2001 in Belgrade, an

19    employee of the state security centre was killed, Momir Gavrilovic.  He

20    was a high-ranking official."  And you go on to say that:  "A lot was

21    talked about in Serbia and it was said that the man had been killed

22    because he went to President Kostunica and disclosed information with

23    respect to the links between the State Security Service and the Mafia.

24    I'm also deeply convinced that Gavrilovic was killed because he did

25    recount to Kostunica some of the things about well-known Mafia people and

Page 11764

 1    their security with the -- and their links with the state security as well

 2    as the extent of the corruption that was involved.  Later on, the

 3    minister, Minister Mihajlovic, he was Minister of the Interior, in a

 4    television programme, disclosed the names of some well-known criminals and

 5    their possible links to the State Security Service.  And Minister

 6    Mihajlovic mentioned the following names:  Sreten Lukic, Luka, from the

 7    Svezdera team; Ljubisa Buke, nicknamed Cume, the head of the so-called

 8    Surcin clan in Serbia.  And in that same programme, the chief of police in

 9    Belgrade, Bosko Buha, and the head of the police station in Novi Sad,

10    Knezevic, were mentioned as people having links to the Mafia.  It was said

11    that Kostunica went quite berserk when he saw the programme and all this

12    was to be treated as highly confidential stuff.

13            "Zoran Djindjic, the present Prime Minister, and his democratic

14    party asked that a highly confidential note be sent to the Prosecution on

15    the conversation between Kostunica and this man.  Nothing was published

16    before Mihajlovic disclosed the names.

17            "In Belgrade, it is common knowledge that between Kostunica and

18    Djindjic, there is a conflict going over the matter of state security and

19    the ties with the Mafia as well as the ties between criminal endeavours

20    and certain members of the government, and your -- you have in mind the

21    present government.

22           "At a meeting of Dos in the night between the 28th and 29th of

23    August, 2001 went on throughout the night.  I know that the subject of the

24    meeting was the DB, the state security system, and the links with the

25    Mafia and I do consider that this matter will be solved using political

Page 11765

 1    means.

 2            "For a certain amount of time after Gavrilovic was -- after

 3    Gavrilovic was killed, I realised that I had known him.  I had met him in

 4    Croatia, in Vukovar, and one of the places that I met him was the centre

 5    for training in Erdut.  At the time, he was there with Arkan.  Momir

 6    Gavrilovic introduced himself as being a colonel of the JNA, Peric, and

 7    this happened after the fall of Vukovar.  After Gavrilovic was killed, his

 8    photographs were published in the media and I recognised him straight away

 9    as the man who had introduced himself as being Colonel Peric.  I learnt

10    from reliable sources that members of the DB, the security service, worked

11    as instructors and members of the Territorial Defence and paramilitary

12    forces who were regularly not well trained.  They were there to prevent

13    chaos and to introduce law and order in the places where they worked as

14    instructors," and so on and so forth.

15            Then once again, at the end of page 2, you go on to say --

16            JUDGE MAY:  Mr. Milosevic, we must come to a question.  I haven't

17    stopped you yet, but you're supposed to be asking questions, not reading

18    large parts of the statement.  What is the question for the witness?

19            THE ACCUSED: [Interpretation] Well, I have to read another portion

20    before I can ask my question, because he goes on to say that:  "There were

21    links between the present members of the DB, the security service, with

22    the Mafia, and they have a lot to answer for, and that people who know

23    Zoran Djindjic, the present Prime Minister, says he uses 100.000

24    Deutschmarks a month on bodyguards and they're wondering who's paying for

25    that.  Everyone knows that Djindjic is into the cigarette smuggling

Page 11766

 1    business and that some rich people involved in the import business get

 2    preferential treatment from him in their day-to-day business.  You used to

 3    say that you think that Zoran Djindjic is a dangerous person," et cetera,

 4    et cetera.

 5            And then you say:  "If you ask me about the fear of a military

 6    putsch, my answer to you would be that I'm not afraid of that, I think the

 7    army has no one strong enough to be in charge of any coup.  Personally, I

 8    am at war with the army leadership and I would describe the present chief,

 9    Pavkovic, as a pompous little person, pompous little man."

10            JUDGE MAY:  Now, Mr. Milosevic, all this is about current

11    politics.  None of it has, as far as I can see, any bearing on the

12    indictment.  Now, could you please ask a relevant question.

13            THE ACCUSED: [Interpretation] That's just what I wanted to say.

14            MR. MILOSEVIC: [Interpretation]

15       Q.   What has this to do with me, and what has this to do with your

16    testimony, and is it quite clear that the party over there, the opposite

17    party, is involved in political intrigue, using observations of this kind?

18            JUDGE MAY:  That's not a matter for the witness as to what the

19    Prosecution are involved in or not.  But the fact is that none of this is

20    relevant to the trial.  Now, if you want to ask a question that's

21    relevant, of course, about it, you can, but it's not a matter which we

22    shall take account of.  If you want to ask the witness why it's in the

23    statement, you can do so.

24            THE ACCUSED: [Interpretation] Well, that's precisely what I'm

25    asking him, Mr. May, what all this is about.  Is it quite clear that what

Page 11767

 1    we're dealing with here are political manipulations and not a trial, in

 2    fact?

 3            JUDGE MAY:  That's not a proper question.

 4            Mr. Dulovic, you heard the passages read out by the accused, and

 5    his question is:  How do they come to be in the statement?  Can you help

 6    us as to that, since they appear to have absolutely nothing to do with

 7    this particular trial.  Can you help us or not?

 8            THE WITNESS: [Interpretation] That was what I was saying, and I

 9    had the impression that the Prosecution was interested in these things,

10    and I recounted the things I had heard, what I thought about them, and so

11    on.  Now, whether they have anything to do with this question in hand,

12    it's not for me to say.

13            MR. MILOSEVIC: [Interpretation]

14       Q.   Mr. Dulovic, do you believe that it is precisely journalists who

15    very often create events themselves for the eyes of the public on the

16    basis of their impressions and sometimes on the basis of their political

17    options too?  At other times, it would be perhaps because of interest,

18    through their own interests, and sometimes it is to the detriment of the

19    truth.

20       A.   Yes, that is possible.

21       Q.   Your previous colleague, Mr. Anastasijevic, also works for the

22    same paper, for the magazine Vreme.  Do you know that in our country there

23    is the widespread conviction that that magazine of yours is an extended

24    arm of the services which in fact worked against Yugoslavia, and the

25    editorial staff of the Vreme magazine, to all intents and purposes, is the

Page 11768

 1    only editorial office which endeavours to show the Serbs as being wholly

 2    responsible for the war and thereby confirming that it is working for the

 3    services working against Yugoslavia?  Are you aware of that?

 4       A.   No, I don't know that.  I'm not aware of that.

 5       Q.   All right.  Now, do you know -- do you think that one can say you

 6    are an impartial witness when you describe these events?  Could you be

 7    characterised that way in your descriptions of what happened in the former

 8    Yugoslavia and your testimony here in court?

 9       A.   Yes.

10       Q.   Well, is it quite clear, then, that you, in your testimony, refer

11    to the talks you had and interviews and who told you what?  You refer to

12    these all the time, so that the bulk of your testimony is not testimony as

13    to fact but testimony about what you heard from others and on the basis of

14    what your political positions are.  Is that true or not?

15       A.   No.

16       Q.   So you're not testifying about what you heard from others.

17    Everything you have described to us, you say, "This person told me that,"

18    "I had lunch with so-and-so," "I talked with so-and-so," "I was sitting

19    around with 10 people and one of them said such-and-such."  You keep

20    telling us what other people told you.  But did you personally see a

21    killing take place?  Did you personally see one of the crimes perpetrated

22    that you described all day yesterday here and today?

23       A.   No.

24       Q.   Is it true, Mr. Dulovic, that you were an associate of the State

25    Security Service or, rather, that you were in cahoots with them?

Page 11769

 1       A.   No.

 2       Q.   Is it also true that when you visited the battleground and

 3    collected up the Zolja type of weapon, that you yourself said that you

 4    didn't know how many Zoljas you had in your apartment?

 5       A.   That is absolutely not true.  It's nonsense.

 6       Q.   Mr. Dulovic, were you ever in prison?

 7       A.   No.

 8       Q.   You were never arrested?

 9       A.   No.

10       Q.   Did anybody prevent you from carrying out your duties as a

11    journalist?

12       A.   I cannot remember.  Ask me specifically what you mean.

13       Q.   I mean on the whole.  You worked as a journalist.  Did anybody

14    hinder you, from the authorities or anybody?  Did anybody hinder the

15    performance of your journalistic duties?  Did you have any negative

16    consequences on the basis of what you did as a journalist, at the papers

17    you worked at or where you work now?

18       A.   Well, only what was important to all journalists and which is the

19    only thing that could be a hindrance, that is closing off important

20    channels of communication.

21       Q.   I did not understand this very well.  What was the point of the

22    explanation you gave towards the end of the examination-in-chief today,

23    that I spoke on the telephone to Slobodan Jovanovic, your editor-in-chief?

24    You said that this was after the conflict, et cetera.  So what's this all

25    about?  I assume that you remember that Slobodan Jovanovic was a high

Page 11770

 1    official of the Socialist Party of Serbia.  For a while he was even

 2    Chairman of the City Committee of the party in Belgrade.  So what?  Did he

 3    say something to you to the effect that I had intervened as to what the

 4    paper should write or something like that, or are you simply stating that

 5    I had a telephone conversation with him?

 6       A.   Yes, that you were in close touch.

 7       Q.   On the basis of that telephone conversation, it is your assessment

 8    I was in close touch?

 9       A.   Not only that.  On the basis of the fact that at the eighth

10    session of the Central Committee of the League of Communists of Serbia, he

11    was one of those who strongly supported you.

12       Q.   Well, I did say that he was a high official of the Socialist Party

13    of Serbia at the time that we were discussing.

14       A.   Yes.

15       Q.   Are you objecting to something he did, that he committed a crime

16    or that he did something wrong?

17       A.   Yes.  Yes, he did something wrong.

18       Q.   So what is this wrong thing he did, improper?

19       A.   He let all kinds of nonsensical lies into -- be published in the

20    newspapers.  For example, that in the village of Mirkovci a barrel full of

21    eyes was found, Serb eyes, and that Ustashas were making pies out of them;

22    things like that.  That kind of propaganda.

23       Q.   As for propaganda, you probably know that the main propaganda was

24    carried out by opposition newspapers whereas the state-controlled media

25    tried to act in a very moderate fashion, although all of you wrote

Page 11771












12  Blank page inserted to ensure pagination corresponds between the French and

13  English transcripts.













Page 11772

 1    whatever came to your minds.

 2            Tell me, please, since in your statement you mention events in

 3    Vukovar, your stay, and as you said, the impermissible behaviour or

 4    violence -- actually, do you think that an event can be viewed in an

 5    isolated manner outside the general context of events, as you do in your

 6    testimony?

 7       A.   That is only one of the examples involved.

 8       Q.   Mr. Dulovic, I assume that you know full well that there is no war

 9    that is worse than a civil war and that nothing can be corrected in that

10    respect.  Only those who care for the good can do their best to have the

11    war stopped altogether, not to have things merely corrected.  Is that

12    clear to you?

13       A.   Yes.

14       Q.   Are you aware that Serbia's policy throughout the time was that

15    this war should be brought to an end at all costs?

16       A.   This was a lie, an ordinary lie, because Serbia was waging a war,

17    or, rather, you were.

18       Q.   Mr. Dulovic, don't you know that Serbia was not at war with

19    Croatia or Bosnia-Herzegovina?  A short while ago, you gave evidence about

20    our police not allowing anyone to enter the territory of Serbia with

21    weapons, across the Drina River.  That's the example that you gave.

22            So if that were true, if these were people who were sent by

23    Serbia, then it would probably be possible for them to enter Serbia.  Is

24    that logical to you or is it not logical to you?

25       A.   It's not logical.

Page 11773

 1       Q.   You say that already in May 1991 you travelled in Slavonia and

 2    that you saw many places there that the army was getting there in larger

 3    and larger numbers.  Do you know why?

 4       A.   I don't know.

 5       Q.   As a journalist, did you find out anything about the enormous

 6    pressures that were brought to bear against the JNA throughout the

 7    territory of Croatia, about attacks against military barracks, the

 8    killings of soldiers, practically making it impossible to observe any kind

 9    of agreement that would bring the violence to an end?

10       A.   I did not see that.  I don't know.

11       Q.   Mr. Dulovic, in your statement you mention some kind of Vojna

12    Linija in the Ministry of the Interior.  You say that in this Vojna Linija

13    of the Ministry of the Interior where Zivota Panic, Mihalj Kertes, Jovica

14    Stanisic, Franko Simatovic, Radmilo Bogdanovic, Radovan Stojicic Badza,

15    that's what it says here on page 2 of your first statement, and that that

16    was established in 1990.

17            And then yesterday -- well, the first page is the second page,

18    sir.  Mr. Dulovic, I see that you are looking at the second page.  I often

19    make the same mistake, because the first page here is the cover page,

20    actually, and then the text starts with the second page where it says

21     "Witness statement" in the middle and then further on.  It was said that

22    it was established in 1990, the Vojna Linija, and then all these names I

23    mentioned.

24            Now, could you please explain the following to me:  Yesterday when

25    you were questioned about the Vojna Linija, you gave the following

Page 11774

 1    explanation, that these were people who would graduate from the military

 2    academy while being members of the Ministry of the Interior.

 3       A.   Yes.

 4       Q.   A small number of MUP members indeed did graduate from the

 5    military academy, but very few of them.  For the most part, the highest

 6    positions were held by people who had a degree in law or social sciences,

 7    but this Vojna Linija of the Ministry of the Interior, let's see who this

 8    is.  Zivota Panic, a general.  He never worked in the MUP nor was he ever

 9    linked to the MUP.  He was in the army all the time and he was even chief

10    of staff for a while and, after that, he retired.

11            Mihalj Kertes also did not graduate from any kind of military

12    academy.  He's a social worker.

13            Jovica Stanisic, who was head of the State Security Service of

14    Serbia for the longest period of time, did not graduate from any military

15    academy.

16            Franko Simatovic also.

17            Bogdanovic also did not graduate from any military academy.

18            Radovan Stojicic also.

19            So none of them actually fall under the explanation that you

20    provided yesterday, people who graduated from the military academy and

21    worked at the MUP, the Ministry of the Interior.  So what you say is

22    incorrect; isn't right, Mr. Dulovic?

23       A.   You misunderstood this.  Yesterday I talked about people who were

24    in the field, and I was told that this was the top leadership, and I

25    pointed that out, that that is what I heard from a man who should know

Page 11775

 1    about this.

 2       Q.   If you heard this from a man who should know about this, the

 3    question always arises as to whether this man does actually know, and

 4    secondly, whether this man speaks the truth, and thirdly, whether you are

 5    saying the truth as to whether you've heard it or not.  So there are a few

 6    question marks involved before such a statement can be made or, rather,

 7    before this kind of evidence can be taken into consideration.  Are you

 8    aware of that?

 9       A.   Yes.

10       Q.   Who is the man you heard this from, Mr. Dulovic?

11       A.   I don't want to say his name.

12       Q.   Because this is an absolute falsehood.  Could you explain to me

13    how they operated?  Because if you say there was this Vojna Linija, how

14    did it operate?

15       A.   I did not go into that.

16       Q.   So you are just making a broad-based statement that it did exist.

17    Do you know that, at that time, the republics - and also later - the

18    republics did not have any jurisdiction over the Yugoslav People's Army or

19    could they have had any?

20       A.   I don't know.

21       Q.   You don't know?

22       A.   No.

23       Q.   All right.  Mr. Dulovic, you say --

24            JUDGE ROBINSON:  Just a second, Mr. Milosevic.  I'm asking the

25    interpreters whether it's possible to translate "Vojna Linija."

Page 11776

 1            THE INTERPRETER:  "Vojna Linija" literally means "military line."

 2            THE ACCUSED:  Military line.

 3            JUDGE ROBINSON:  Thank you.

 4            THE ACCUSED: [Interpretation] I assume that that's the

 5    interpretation that the interpreters gave.  I didn't look at the

 6    transcript.

 7            MR. MILOSEVIC: [Interpretation]

 8       Q.   You say that in July and August 1991, you were in Borovo Selo, a

 9    suburb of Vukovar, and you say that you visited a prison there, and you

10    describe what a guard demonstrated to you, that when he would bang at the

11    door, that they would sing, sing the song "Who is saying, who is lying,"

12    et cetera, and then this other song dedicated to Vojvoda Sindjelic.  Does

13    it seem to you that this kind of an anecdote could not even be recounted

14    in a pub in Serbia?

15       A.   Unfortunately, this is not an anecdote; this is the truth.

16       Q.   That's what you're saying.

17       A.   No.  This is what I saw, this is what I heard.

18       Q.   This had to be seen or heard by somebody else too in addition to

19    yourself, if such things did exist.

20       A.   Yes, many did.

21       Q.   Can you mention anybody else who saw this or heard this?

22       A.   I don't know any names.

23       Q.   Let me ask you, then, although I do not believe what you're saying

24    at all:  Did you see near that prison any soldier of the JNA or, for

25    example, a policeman from Serbia, Yugoslavia?

Page 11777

 1       A.   No.

 2       Q.   How long were you in Borovo Selo?  Do you actually know what

 3    happened in Borovo Selo?

 4       A.   I heard about things.  I don't know.

 5       Q.   You don't know.

 6       A.   No.

 7       Q.   As a journalist who stayed in Borovo Selo, did you establish what

 8    the then Minister of the Interior of Croatia, Josip Boljkovac ascertained

 9    and which was later admitted, seven years later, in December 1998, that

10    bloodshed in Borovo Selo was caused by the members of the MUP of Croatia?

11       A.   I never heard of that.

12       Q.   All right.  Do you know that Boljkovac himself said that members

13    of the Croatian MUP entered Borovo Selo, caused a conflict, took the flag

14    down, et cetera?

15       A.   I don't know about that.

16       Q.   Do you know that this same Minister of the Interior of Croatia,

17    Boljkovac, said that the mortar attack on Borovo Selo that was commanded

18    by Gojko Susak and Vice Vukojevic, Ivica Vukojevic were a call to war?

19       A.   I don't know.

20       Q.   You don't know about that either.  Do you know the statement that

21    the aim of this attack was to render impossible the peaceful break-up of

22    Yugoslavia, also that this was not a mere incident but an action

23    prepared --

24            JUDGE MAY:  The witness has said he doesn't know about it, so

25    there's no point going on.

Page 11778

 1            THE ACCUSED: [Interpretation] Well, what I'm asking him about, I

 2    mean, he is a journalist and he is interested in this.  This was published

 3    in a special edition of Croatian Globus on the 18th of May, 2001.

 4            JUDGE MAY:  You can produce it to us in due course, but the

 5    witness -- there's no point asking the witness about it.

 6            THE ACCUSED: [Interpretation] Mr. May, since the witness is giving

 7    evidence about only a fraction of these events and he is taking this out

 8    of the context of these horrors of Vukovar, I am trying to establish

 9    whether he is aware of the origins of the conflict, whether he knows how

10    they started, what the intensity was, and how many victims were the result

11    of this, in order to clarify the role of the Yugoslav army.

12            JUDGE MAY:  Why don't you ask him asking else, then?  There's no

13    point asking something about which he doesn't know.

14            MR. MILOSEVIC: [Interpretation]

15       Q.   Tell me, please, during your stay in Vukovar, in Borovo Selo, for

16    example, or generally in that area, did you come to the conclusion that

17    the HDZ was being armed, that is to say the ruling party in Croatia?  Not

18    only did they get weapons but also dynamite in order to blow up Serb

19    houses, business facilities that were owned by Serbs.  For example,

20    precisely in Borovo Selo where you were, they blew up --

21            JUDGE MAY:  Let the witness -- let the witness deal with the

22    general question first.

23            THE WITNESS: [Interpretation] I wasn't there at the time, nor did

24    I see the members of the HDZ, so I don't know anything about what the

25    accused is talking about.

Page 11779

 1            MR. MILOSEVIC: [Interpretation]

 2       Q.   Well, you didn't see many of the things you testified about but

 3    only heard about then.  Did you know that the restaurant Sarajica, owned

 4    by a Serb from Borovo Selo --

 5            THE INTERPRETER:  The interpreters did not catch the name.

 6            MR. MILOSEVIC: [Interpretation]

 7       Q.   -- was blown up by the HDZ?

 8       A.   No, I didn't hear that.

 9       Q.   You say that you avoided using the term "Ustasha."  Is that

10    correct, sir?

11       A.   Yes.

12       Q.   Are you aware of the fact that the perpetrators of crimes in the

13    surroundings of Vukovar, and of course elsewhere, called themselves

14    Ustasha?  They referred to themselves as Ustasha and were proud of it.

15       A.   I don't know that.

16       Q.   You didn't hear about that?

17       A.   No, I didn't.

18       Q.   Very well.  You explain that in September, October, and November

19    1991, the shelling of Vukovar did not stop.  How long were you in Vukovar?

20       A.   Well, almost throughout the entire three months.

21       Q.   Do you know how the conflict in Vukovar came about?

22       A.   I wasn't there when it broke out.

23       Q.   Did you hear that first a decision was made on the ethnic

24    cleansing of Vukovar in February 1991 at the meeting of the HDZ branch for

25    Trpinje Cesta in Borovo Naselje?  Did you hear about this?

Page 11780

 1       A.   No.

 2       Q.   Did you hear about Mercep, Vekic [phoen], Seks who organised this

 3    entire pogrom activity on the territory of Vukovar?

 4       A.   The names are familiar to me but not in a context I could connect

 5    with this.  I only heard the names.

 6       Q.   Very well.  Are you aware, then, that following the policy then

 7    adopted by Zagreb they issued decisions to have all Serbs dismissed from

 8    leading posts in the area, that they should be intimidated, made to leave,

 9    and those who did not do what was required would be liquidated?  Do you

10    know about these conclusions?

11       A.   No.

12       Q.   Are you aware that as early as February 1991, the HDZ branch for

13    Borovo Naselje set up several branches in the local communes and that in

14    March 1991, for example -- I have precise information:  On the 10th of

15    March in the Bratstvo and Jedinsko local commune, which is what this was

16    called, now it's called the Alojzije Stepinac hall, that a meeting was

17    held of that Borovo Naselje branch and it was this that they discussed,

18    the expulsion and liquidation of the Serbs.  Are you aware of any of this?

19       A.   No.

20            JUDGE MAY:  I'm going to stop this.  There's no point asking this

21    witness these questions.  He knows nothing about it.  It doesn't add to

22    the case in any way.  Mr. Milosevic, you've been told, in due course if

23    you want to call evidence about these things, you can, but we're wasting

24    time in cross-examination by this.

25            THE ACCUSED: [Interpretation] I hope, Mr. May, that you will give

Page 11781

 1    me at least as much time for cross-examination as this witness of yours

 2    has had.

 3            MR. MILOSEVIC: [Interpretation]

 4       Q.   Tell me, please, do you know anything about the review of the

 5    future paramilitary formations of the Republic of Croatia in March 1991,

 6    precisely in this area?

 7            JUDGE MAY:  I'm going to stop these questions.

 8            Do you know -- Mr. Dulovic, can you help us at all about what the

 9    Croats were doing, whether there were meetings of this sort, or anything

10    at all in relation to this?

11            THE WITNESS: [Interpretation] I know nothing of this.

12            MR. MILOSEVIC: [Interpretation]

13       Q.   Do you know anything about the ethnic cleansing of Borovo Naselje

14    which then spread to other parts of the Vukovar municipality?  Do you know

15    anything about this?

16       A.   No.

17       Q.   When you wrote about Vukovar, you mentioned the hospital.  Do you

18    know that Dr. Rade Popovic, the head of the hospital, was dismissed and

19    Vesna Bosanac was appointed in his place?  Do you remember this?

20       A.   I only know Vesna Bosanac.  I know she was the head of the

21    hospital.  I didn't hear about the other name.

22       Q.   Does it seem abnormal to you that you know nothing about the

23    enormous pogrom against the Serbs and the attacks in the army --

24            JUDGE MAY:  This is a matter of comment.  This is all your case

25    that there was a pogrom.  Nobody else has said so.  So to put it to the

Page 11782












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Page 11783

 1    witness as a criticism that he knows nothing about it is absurd.  Now,

 2    could you just deal with questions which the witness can deal with.  It

 3    may be you want to go on to the hospital and what the witness said he saw

 4    happening there.

 5            THE ACCUSED: [Interpretation] We'll come to this.

 6            MR. MILOSEVIC: [Interpretation]

 7       Q.   Tell me, please, did you know anything about the fact that a large

 8    part of the Croatian population, primarily women, children, civilians, and

 9    so on, were evacuated from Vukovar but the Serbs were not allowed to leave

10    the town?

11       A.   I don't know what was done before, but there were a lot of

12    civilians, Croats, in Vukovar who were in the shelters together with the

13    Serbs.  I know about this because the Serbs who were in these cellars, in

14    these shelters, told me this.  They had been there together with the

15    Croats.

16       Q.   Would you like to see the certificate issued by the Republic of

17    Croatia, Vukovar municipality, Municipal Secretariat for National Defence,

18    and then there is a seal with the chequerboard symbol and signature

19    allowing Petar Kordo to leave the town and go from Vukovar in the

20    direction of Osijek and Zupanja?  So this is a permit.  Without a written

21    permit of the Croatian authorities, a civilian could not leave Vukovar if

22    he was a Serb.  Are you aware of this?

23       A.   I'm hearing this for the first time.

24       Q.   Well, please have a look at this permit, and I would like to

25    tender it into evidence.  I can give you several more of these.

Page 11784

 1            JUDGE MAY:  Yes.  Let the usher get the document.

 2            Mr. Milosevic, I doubt the witness can say very much more than

 3    he's said already, that he heard from the Serbs that there were Croats in

 4    the -- in the town.  But by all means let the witness have a look at it.

 5            Yes, to the Prosecution.

 6            Yes, Mr. Milosevic.

 7            MR. MILOSEVIC: [Interpretation]

 8       Q.   Do you know, since you were there on the spot at the time, that

 9    the top military command of the -- of Yugoslavia said that Croatia had

10    done everything it had planned by then, had perpetrated crimes and mass

11    persecutions of the Serbs in order to take Vukovar and its surroundings?

12    I assume that you were keeping up with events then because you were

13    already there.

14       A.   I don't remember this.  All I know is what I saw, what I talked

15    about with people.  I know that in the shelters there were Serbs and

16    Croats together.

17       Q.   Very well, then.  Are you aware of the fact that until the

18    beginning of the fighting for Vukovar, before the fighting began, several

19    thousand -- up to a thousand Serbs were killed there?

20       A.   I never heard this.

21       Q.   Very well.  I assume that it's common knowledge that on the 26th

22    of July 1991, only a month before the decision on the secession of

23    Croatia, the president of Croatia, Tudjman, issued a decree disbanding the

24    Municipal Assembly of Vukovar.

25       A.   I don't know that.

Page 11785

 1       Q.   Do you know that there were many more Serbs living in that

 2    municipality in comparison to the Croats?

 3       A.   I don't know what the proportion was, but I know that there were

 4    both Croats and Serbs.

 5       Q.   Do you know that the HDZ, the party of the then President Tudjman,

 6    at the first multi-party elections in Croatia lost?  They were badly

 7    beaten in Vukovar because the citizens in the area voted for the League of

 8    Communists of Croatia and the Serb Democratic Party.

 9       A.   I don't remember that.

10       Q.   You don't remember that?  Do you know that the dissolution of the

11    Assembly and the pressure --

12            JUDGE MAY:  Just a moment.  We're going to confer.

13                          [Trial Chamber confers]

14            JUDGE MAY:  Yes, Mr. Tapuskovic.

15            MR. TAPUSKOVIC: [Interpretation] Your Honour, if I may, may I

16    assist you to reach a decision which of course it is for you to make?  Why

17    is all this important?  In the statement he gave to the OTP, in paragraph

18    2, the witness said that:  "From May 1991 onwards, in company with two

19    other colleagues, I travelled around the towns and villages in Eastern

20    Slavonia, watching the developments unfolding as the country approached

21    the war."  And he spent the following several months in the area

22    constantly.

23            So the questions that were put concern events in the area, in

24    these towns and villages which the witness was constantly visiting and

25    observing.  And it is for you, of course, to decide whether the questions

Page 11786

 1    that were put are admissible.

 2            How is it possible that the witness does not know anything about

 3    all these events?

 4            JUDGE MAY:  Yes.  Very well.  Yes, Mr. Milosevic.  You can have

 5    the same time as the Prosecution; it will be four hours and a quarter.

 6            THE ACCUSED: [Interpretation] Very well.  That means until the

 7    middle of tomorrow?

 8            JUDGE MAY:  We'll see how the time goes, but that's the time you

 9    can have.  Yes.

10            THE ACCUSED: [Interpretation] So, Mr. May, I am trying to show

11    that it is incredible that the witness claims to have very good knowledge

12    of certain crimes perpetrated by Serbs afterwards but that he knows

13    absolutely nothing about the events that preceded this and gave rise to

14    the conflict, the violence, the murder.  A thousand people were killed.

15            JUDGE MAY:  He's given his answer.  I expect what you say is

16    contentious, it isn't accepted anyway by the Prosecution.  We might get

17    the Prosecution, actually, to shorten this.  What we might do is, so it's

18    not put to every witness that there was this referendum, there was this

19    and that, we might get some agreed facts on what the -- if you can agree,

20    some of the facts that the accused keeps putting to people, to save a bit

21    of time.

22            MR. NICE:  Can I just observe in respect of that, we still have

23    very limited, if any, contact with his associates.

24            JUDGE MAY:  No, I know that.  I'm meaning on the basis of what's

25    been put to witnesses already.  I don't know if there's some facts you

Page 11787

 1    can --

 2            MR. NICE:  We can give thought to that.

 3            JUDGE MAY:  -- you can extract out of it so that we don't get

 4    every witness being asked if they know about this referendum or that.

 5            MR. NICE:  We'll give thought to it, but once things are raised a

 6    certain number of times, the Chamber may just decide that they just don't

 7    need to be raised again.

 8            JUDGE MAY:  Well, it would help if they could be agreed so we knew

 9    they didn't have to be raised again.

10            The other matter - it's a pity this isn't in open session because

11    it's an important point - there may be matters which you can agree, from

12    what the accused is putting, the more tendentious matters, that maybe some

13    can be agreed, some can't, but --

14            MR. NICE:  We'll give thought to it.

15            JUDGE MAY:  Yes, give some thought to it in order to save time.

16            Mr. Milosevic, I'm saying to the Prosecution there may be some

17    matters which you're putting to witnesses which can agreed by them so you

18    don't have to keep putting it to these witnesses, but go on.

19            THE ACCUSED: [Interpretation] Very well.  Mr. May, I didn't put

20    any questions -- I haven't put any questions so far about the conflicts to

21    the witnesses.  Vukovar.  As I said, I have not previously put any

22    questions regarding Vukovar to other witnesses, nor did I ask this witness

23    about issues concerning the referendum and so on.

24            MR. MILOSEVIC: [Interpretation]

25       Q.   So as you have just said, you have heard of Tomislav Mercep who

Page 11788

 1    perpetrated enormous crimes while leading these units.  Of course you know

 2    nothing about these crimes, but do you know about the crimes that were

 3    committed in Vukovar immediately before these events, by the 204th Brigade

 4    of the National Guard Corps under the command of Mercep?

 5       A.   No.  I didn't see that.

 6       Q.   Well, you didn't see anything of what you're testifying about.

 7            JUDGE MAY:  No.  The question is did you hear about any crimes

 8    committed by this group?  We don't know if there were or not, but it may

 9    be you can help us.

10            Let the witness --

11            THE ACCUSED: [Interpretation] Very well.

12            JUDGE MAY:  Put it this way:  Were there allegations about this

13    group committing crimes, or indeed any other Croats, committing crimes in

14    Vukovar before the -- before the siege?

15            THE WITNESS: [Interpretation] As far as I can recall, I remember

16    these names.  I remember them in a negative context.  There were stories

17    and allegations that crimes were committed, but I had no relevant or valid

18    evidence about this.  Most probably these things did exist, but I did not

19    go back in time when I arrived.  I started reporting on what I saw and

20    heard.  I did not go into previous events after I arrived.

21            MR. MILOSEVIC: [Interpretation]

22       Q.   Very well.  Since these were events that certainly attracted

23    enormous attention because of their cruelty, I have here a statement made

24    by Marin Vidic Bili, an authorised representative of the Croatian

25    government for Vukovar.  It's 52 pages long, and I will read only half a

Page 11789

 1    page to you and then you can tell me whether you ever heard anything about

 2    this.  His statement is 52 pages long, and I will tender it into

 3    evidence.

 4            JUDGE MAY:  No, you won't tender it into evidence.

 5            MR. MILOSEVIC: [Interpretation]

 6       Q.   As I see --

 7            JUDGE MAY:  You can call him.  You can call him to give evidence,

 8    if you want, but you can't simply put a statement in like that.

 9            THE ACCUSED: [Interpretation] Very well.  But simply listen to

10    what the authorised Croatian representative for Vukovar said in late 1991.

11    This is 52 pages long.  He says the following, this is on page 30:

12    "The action against Borovo Naselje was carried out in early July.  I

13    cannot say exactly on what day.  Apart from the fact that I knew the

14    action would take place, we were informed by Zadro Blago, who led the

15    action, as to how it was to take place.  I was in the Secretariat for

16    National Defence, under Mercep Tomislav, who contacted with Blago Zadro by

17    way of a Motorola.  Blago Zadro came to the secretariat at around 2200

18    hours.  He informed us that the action in Borovo Naselje had been very

19    successful, that there had been no wounded or killed members of the

20    Ministry of the Interior and the guard, that Borovo Naselje had been

21    cleansed of the Serbian population and the Chetniks and that in the

22    cornfields behind it, the last row of houses of Borovo Naselje, in the

23    direction of Borovo Selo, that there about 50 Chetniks had been killed as

24    we were informed by Blago Zadro.  The chief of the police administration

25    was also present and he also confirmed this.  I sent a report to the

Page 11790

 1    Crisis Staff in Osijek, and I gave the information that had been given to

 2    me by Blago Zadro.  I know that Tomislav Mercep sent a report to the

 3    Crisis Staff in Zagreb, to its chairperson, Josip Manolic.  He was then

 4    the Minister of the Interior.  However, Mercep made a statement for the

 5    public in which he said that the Chetniks had attacked Borovo Naselje and

 6    that this had been successfully opposed by the guards and the members of

 7    the Ministry of the Interior and that they had driven out the Chetniks

 8    from Borovo Naselje and broken up their ranks.  Tomislav Mercep's

 9    statement was broadcast by Croatian television and the aim of this was to

10    inform the public --"

11            JUDGE MAY:  Very well.  I'm going to stop this because it's

12    absolutely pointless asking this witness something as long as this,

13    particularly as he may or may not know anything about it.

14            Can you help us as to this allegation about an attack on Borovo

15    Naselje?  Do you know anything about this attack?

16            THE WITNESS: [Interpretation] I don't know anything about that.  I

17    was a journalist who was following daily events.  I wasn't writing stories

18    and articles about things that had happened in the past or forecast the

19    future.  I was just giving the actual state of affairs of what was going

20    on in the theatre of operations at the time I was there.

21            MR. MILOSEVIC: [Interpretation]

22       Q.   Mr. Dulovic, these are quite legitimate questions, because in your

23    statement, you yourself say that the Serbs were doing the attacking and

24    that the Croats were defending themselves.  That's how you explain it.

25    And then you give a completely distorted picture of the situation.  This

Page 11791

 1    is a statement of their representative.  It's 52 pages long.

 2            THE ACCUSED: [Interpretation] If you don't want to accept this,

 3    Mr. May, that's up to you, but I'm offering it up --

 4            JUDGE MAY:  Not at the moment.  If in due course it becomes

 5    admissible, we'll rule on it, but we don't accept statements unless

 6    there's good reason to do so.

 7            THE ACCUSED: [Interpretation] And would you like -- all right.

 8    Very well.  Fine.

 9            MR. MILOSEVIC: [Interpretation]

10       Q.   But would you like to comment on a document?  You haven't got the

11    document, of course, but from the aspects of your testimony, this is an

12    official letter sent on the 18th of August, 1991, to the president of the

13    Republic of Croatia, to the Prime Minister of Croatia, the Defence

14    Minister, the minister in the Ministry of the Interior, and copies were

15    sent to four addressees, the presidents of four parliamentary parties in

16    the Croatian Sabor or parliament, the SDB among them, of Ivica Racak, the

17    Prime Minister now, Sabkadacevic [phoen] Kuca, the president of the HNS,

18    the HLS, Budisa and the HDS Veselica, and it was signed and stamped by a

19    representative of the Republic of Croatia in the Vukovar municipality,

20    Marin Vidic Bili.  It has a stamp, it has a signature and all the rest,

21    and this is what it says.  It is titled "The Political Security in the

22    Vukovar municipality, Report."  "The nomination of Tomislav Mercep as

23    secretary of the municipal secretariat in Vukovar came -- led to the

24    usurping of power and focusing it in one person, in the person of the HDZ

25    representative and therefore, the commander, to all practical purposes of

Page 11792

 1    the ZNG, the police and the organs of power and authority.  He has

 2    surrounded himself by dubious people, former criminals, and by that they

 3    have taken over control of everyone in the municipality of Vukovar and

 4    they stop at nothing, repressive measures," et cetera, in the

 5    municipality.  Then he goes on to state the measures that they have

 6    adopted; the unlawful storming of an apartments, looting, taking away

 7    vehicles, detaining people brutally, and this goes on as far as executions

 8    and liquidations.

 9            This is something that he writes about in this report.  He is

10    informing all the organs at the top echelons of Croatia, and says that

11    this has led to a feeling of general fear among the Serbian and Croatian

12    population, and there is a general exodus from the town, a blockade of the

13    police, the ZNG, the organs of power and authority and has led to a

14    general situation of confusion.  And then it goes to say that Tomislav

15    Mercep, upon the intervention of the minister from Zagreb, was withdrawn

16    and dismissed as Minister of the Interior, and this was made public in the

17    information media.

18            And then he goes on to say later on that in addition to this, the

19    head of the ZNG, Hipa [phoen] Radas, was replaced.  He was a professional.

20    And Mercep's deputy was brought in to replace him.  And he goes on to say

21    that:  "A blockade was set up, that there was no work going on, there was

22    great confusion, great fear among the population prevailed, and that the

23    entire Croatian population did not justify this kind of conduct and

24    thought that it had been compromised and that mud had been thrown upon it

25    and it wishes to bear no responsibility for policies of this kind.  As we

Page 11793












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Page 11794

 1    consider that we are not able to clear up the situation with the use of

 2    local forces, would you please send competent people into the area

 3    urgently."

 4            So it is their representative who speaks about what Mercep's

 5    Ustashas were doing in Vukovar, the executions that were going on, the

 6    arrests that were taking place, and the way in which they ran amok.  We

 7    see that 50 people were killed.  They are referred to as Chetniks for the

 8    mere reason of being Serbs, et cetera.

 9            JUDGE MAY:  You've been speaking now for several minutes and it's

10    time there was a question.

11            This has been put to you, Mr. Dulovic.  Do you know anything about

12    this letter or indeed about the situation which it describes?

13            THE WITNESS: [Interpretation] This is the first time I hear of it.

14    While I was over there while it was still under siege, I heard that in

15    Vukovar that among the Croats there, there were certain rifts going on and

16    conflicts and clashes of opinion, but I really don't know any more about

17    the situation than that.

18            MR. MILOSEVIC: [Interpretation]

19       Q.   Mr. Dulovic, I didn't ask you about the letter itself.  I was

20    interested in hearing from you, as the letter was an official one from

21    official Croatian organs sent to the Croatian government and speaks about

22    events, I'm asking you whether you knew anything about those events and

23    that violence en masse and the killing of Serbs in Vukovar in the summer

24    months of 1991.  Did you know anything about that?

25       A.   No.

Page 11795

 1       Q.   So you know nothing about that?

 2       A.   No, because Borovo Naselje was under Croatian jurisdiction.  There

 3    was an airport, and then you get to Borovo Naselje.  So I don't know what

 4    was going on there.

 5       Q.   All right.  Now, in view of the statements that I quoted and the

 6    generally known facts about the violence, can you really say what you said

 7    yesterday during your testimony, that the Serbs from Vukovar, after the

 8    fall of Vukovar, as thousands of them had been killed up until that date,

 9    looted and everything else destroyed, that you said that the Croatian

10    authorities' conduct towards them was quite proper and that they had no

11    criticisms to make in that regard and they had no criticisms vis-a-vis

12    everything that was going on, and you claim that it was the Serbs from

13    Vukovar who actually told you that.

14       A.   Yes, that is what I'm saying.  I have their names, their first and

15    last names, their addresses noted down, and they told me what I recounted

16    yesterday during my testimony.

17       Q.   All right.  Fine.  These seem to be some very strange people, or

18    perhaps what I have just quoted was incorrect, and I quoted Croatian

19    sources at that.

20            All right, then.  Tell me this:  Were you ever in the Petrova Gora

21    Local Community in Vukovar?

22       A.   No.  That's on the other side of town from where I was.

23       Q.   All right.  But when you arrived in Vukovar, I assume that you

24    moved around throughout the whole town.  I don't know which parts you

25    visited, but that's why I'm asking you.  Did you know anything about that?

Page 11796

 1       A.   No.

 2       Q.   And did you learn, perhaps later on, that in Vukovar within the

 3    frameworks of the Mercep brigade was the first group that was set up for

 4    these liquidations?  Did you hear anything about that?

 5       A.   Well, if that is so, then this took place on both sides, on the

 6    Serbian side and on the Croatian side.  There was talk of the fact that on

 7    both sides these teams or groups were being set up, or units, for purposes

 8    of liquidation, and a lot of manipulation was done with rumours of this

 9    kind.

10       Q.   All right, Mr. Dulovic.  I quite understand the position you're

11    in.  Now, do you know that the first person to fall casualty, to fall

12    victim to the Mercep group was Zeljko Ostojic, who at the end of 1990

13    testified to the organs of the security of the Yugoslav army about the

14    formation of armed units and the plans of Tomislav Mercep for the ethnic

15    cleansing of Eastern Slavonia?  Do you know that?

16       A.   No.

17       Q.   As you spent such a long time in Vukovar, do you know that after a

18    film about Spegelj was broadcast over television, and he testified about

19    that, so right after the programme was televised, Ostojic was killed in

20    his apartment in Borovo Naselje because of that testimony, quite

21    obviously.  Did you ever learn about any of that?  Hear about any of

22    that?  Nobody told you anything about that?

23       A.   No, no, no.

24       Q.   So you're saying that throughout your stay in Vukovar, none of the

25    Serb population ever complained to you of the terror and killings that had

Page 11797

 1    been going on for months in Vukovar but that, as you yourself claim here,

 2    that all they said was that some mad Serbs were attacking Croats who were

 3    just defending themselves.  That is your thesis, isn't it?

 4       A.   No.  I am saying that there was fighting going on.

 5       Q.   Very well.  And how about this:  Do you know what the intention of

 6    the army was?  Do you know anything about the blocking of the barracks in

 7    Vukovar?  Did you hear anything about that?

 8       A.   Yes, I did hear about it.

 9       Q.   Well, tell me, please, what did you hear about it?  The blockade

10    set up in front of the barracks in the centre of Vukovar, what did you

11    hear about that?

12       A.   That it had been surrounded by the Croatian army, that there was

13    fighting, and that the forces -- the soldiers managed to pull out of the

14    barracks.

15       Q.   In your statement where you say you were called to be a witness,

16    and the statement has been tendered here along with your statement, it is

17    the records on witness interview -- witness interview that was conducted,

18    in the documents that I was given from that opposite party there, you say:

19    "I was present during the military activities of the JNA to deblock the

20    barracks in Vukovar, or, rather, the action and operation, in inverted

21    commas, you say of the liberation of Vukovar as it was called."  That is

22    in inverted commas.  And then you go on to say the following, where you

23    lived, where you resided, and so on.

24       A.   I would have to take a look at that.

25       Q.   Okay.  It's 0288148.  It is your own statement, at the beginning

Page 11798

 1    of your own statement, and you quoted from that statement as well.

 2            MR. GROOME:  Your Honour, I believe Mr. Milosevic is referring to

 3    tab 12.  That's in evidence as Prosecution Exhibit 323.  I would ask that

 4    the witness be shown that.  And I apologise; for the record, it's 342.

 5            JUDGE MAY:  Tab 12?

 6            MR. GROOME:  Yes, Your Honour.

 7            JUDGE MAY:  This is the statement made to the investigative judge,

 8    that's the one.

 9            MR. GROOME:  It appears that is the document Mr. Milosevic is

10    quoting from.

11            JUDGE MAY:  Yes.  Has the witness got it?  Tab 12.

12            JUDGE KWON:  First paragraph.

13            JUDGE MAY:  Yes, Mr. Milosevic.

14            MR. MILOSEVIC: [Interpretation]

15       Q.   Well, Mr. Dulovic, if we bear in mind everything that was going on

16    during that summer and the thousands of Serbs that had been killed up to

17    that time, and when we bear in mind what you yourself call the blockade

18    and deblocking of the Vukovar barracks, do you really think that the army

19    should not have saved not only its own soldiers in Vukovar but also other

20    citizens whose lives were in peril from one day to the next and who

21    disappeared in the rampage the Ustasha groups engaged in, and these people

22    called themselves Ustashas themselves, and we will be able to ascertain

23    that in due course.  Do you really think they should not have --

24            JUDGE MAY:  We must come to a question.

25            MR. MILOSEVIC: [Interpretation]

Page 11799

 1       Q.   My question is do you think that the army should not have

 2    intervened to deblock the barracks and to stop the slaughter of civilians

 3    in Vukovar and 1.000 had already been killed up until that time?  What did

 4    you say?

 5       A.   No, I did not know anything about that.

 6            JUDGE MAY:  If this were true, did you know anything about what is

 7    alleged here?  This is the accused's allegations, of course, that there

 8    was a slaughter of civilians.  I take it to mean a slaughter of Serb

 9    civilians.  Did you hear anything of that?

10            THE WITNESS: [Interpretation] No.

11            JUDGE ROBINSON:  Mr. Milosevic, are you saying 1.000 Serbs had

12    been killed?  If I understand you correctly.

13            THE ACCUSED: [Interpretation] Yes, according to the facts and

14    figures that I have.  Up until that time, right after the proclamation

15    of --

16            JUDGE ROBINSON:  [Previous translation continues]...

17            THE ACCUSED: [Interpretation] That all took place during the

18    summer of 1991, and everything happened much before the attack on Vukovar.

19    The barracks were blocked in Vukovar far before the attack on Vukovar took

20    place.  Electricity was cut off, water was cut off, and the barracks were

21    shot at from all sides in order to show that Croatian independence can be

22    gained through a war, although the army, the soldiers wished to leave the

23    barracks, but this was made impossible.  And this witness must have known

24    about all that.  He knows -- he says he knows nothing about that, and

25    there is an enormous amount of evidence and proof of that, and I myself

Page 11800

 1    have quoted a few.

 2            THE ACCUSED: [Interpretation] May I proceed or would you like to

 3    take a break now?

 4            JUDGE MAY:  Quite right.  It's break time.

 5            MR. GROOME:  Your Honour, may I say one thing before the break?

 6    As it appears we may continue on until tomorrow, the Prosecution is

 7    concerned about this very serious security consideration and is asking the

 8    Chamber to consider making inquiry from the Victims and Witnesses Unit if

 9    it's something they feel that they are competent to investigate, and if

10    they feel they are not, perhaps there would be an alternative where an

11    investigator from the Office of the Prosecutor could speak to Mr. Dulovic

12    in the presence of either the registry or the amici.  I would hate to lose

13    valuable time in getting to the bottom of the extent of the threat that

14    Mr. Dulovic's family is facing.

15            JUDGE MAY:  Yes, we'll consider that during the adjournment.

16            MR. GROOME:  Thank you.

17            JUDGE MAY:  Twenty minutes.

18                          --- Recess taken at 12.17 p.m.

19                          --- On resuming at  12.42 p.m.

20            JUDGE MAY:  Mr. Groome, dealing with the matter you raised before

21    the adjournment, we will permit an investigator to speak to the witness

22    about the matter.  Of course he can only speak about what happened

23    overnight, of course, not about the case.

24            MR. GROOME:  Thank you, Your Honour.

25            JUDGE MAY:  Mr. Dulovic, we said earlier on that you mustn't speak

Page 11801

 1    to anybody, of course, about your evidence, but because of the events

 2    involving your wife, we're going to permit an investigator to speak to you

 3    about that.  If you would keep the conversation just to that, of course,

 4    not talking about your evidence or the case, but he can speak to you about

 5    that limited purpose.

 6            Yes, Mr. Milosevic.

 7            MR. MILOSEVIC: [Interpretation]

 8       Q.   In view of the fact that you're a journalist, Mr. Dulovic, did you

 9    follow what was going on with the media at the time in Vukovar?  Do you

10    know, for example, that on the 2nd of May in this general pogrom

11    atmosphere in Vukovar, the HDZ forcibly took over radio Vukovar and

12    appointed Zdravko Seremet, member of the Municipal Council of the HDZ, to

13    be the new director of radio Vukovar?  Since this concerns your

14    colleagues, other journalists, did you know anything about that?

15       A.   No.  When I was there, Radio Vukovar was in the hands of the

16    Serbs.  There were two women journalists and one man there.

17       Q.   I'm asking you about what happened beforehand.

18       A.   Oh, I don't know about that.

19       Q.   You know nothing about that.  Do you know that, on the same day,

20    that is to say on the 2nd of May, there was a coordinated action of the

21    MUP of Croatia engaged in the ethnic cleansing in Borovo Selo?

22       A.   No.

23       Q.   Do you know, for example, of the fact that a Croat, the chief of

24    police of Croatia in Osijek, his name was Kir Reihl, who was energetically

25    opposed against such Ustasha rampages in Vukovar, was killed on the

Page 11802

 1    Osijek-Vukovar road by these same men of Mercep's because he wanted to

 2    calm the situation down, because he wanted such operations to start?

 3       A.   I know about that.  I read about that and heard about it.

 4       Q.   What do you know about that?

 5       A.   What you just said.

 6       Q.   So if it is so, that is to say that they were killing their own

 7    chiefs of police who opposed such rampages, can you assume what the

 8    proportions of these rampages were and the level of endangerment of the

 9    Serb population that went on throughout the summer?

10       A.   I cannot present any assumptions.

11       Q.   Do you know that in October and November 1991, when you say that

12    Vukovar was shelled all the time, that one-third of the total Croatian

13    forces, together with foreign mercenaries - and we saw some of them here

14    in a film - attacked Serbs in the area of Vukovar, precisely at that time?

15       A.   This is the first time I hear of this, especially about the

16    foreign mercenaries.

17       Q.   Do you know that in town itself at that time there was between

18    6.000 and 8.000 of these paramilitary formations of Croatia?  They

19    themselves called themselves Ustashas.

20       A.   I don't know about that.

21       Q.   Since you don't know about these groups, do you know that the

22    basis for these forces at that time - I don't want to use the word

23    Croatian forces because this, in a way, would smear the name of the

24    Croatian people, but this was done by the 204th Vukovar Brigade, the

25    brigade from Vinkovci, the brigade from Zagreb, 100 volunteers, 50 members

Page 11803

 1    of the MUP from Varazdin, Cakovec, 400 mobilised members of the guard

 2    corps, forces of the HOS unknown to me - that is to say HOS Croatian

 3    defence forces - and then these international mercenaries in the groups

 4    called Kondor, Chicago, 150 neo-fascists and mercenaries.  Did you find

 5    out about this at all?

 6       A.   I did not find out anything about that.  Either I or my

 7    colleagues.  This is the first time I hear about this.  Perhaps this was

 8    the case, but this is the first time I ever hear of it.  These precise

 9    figures are something that journalists and ordinary people did not know

10    about.

11       Q.   Did you know or did you hear later that, Dogriv Kiso [phoen],

12    Aleksandar Volter, Petar Binder, who were arrested in Austria, that is to

13    say not in Eastern Slavonia or in Serbia but in Austria, towards the end

14    of 1993, that they disclosed their own participation in that war, these

15    neo-fascists, mercenaries?  That's what I'm talking about.

16       A.   I don't know about that.

17       Q.   You don't know about that either.  All right.  But I assume that

18    it is not even being contested by you that when in October 1991 the army

19    set out to Vukovar, that their task was to deblockade the barracks.  Is

20    that something that is not being contested?

21       A.   I don't know.

22       Q.   Do you know that the Presidency of the Socialist Federal Republic

23    of Yugoslavia that was still operating and the JNA that was throughout the

24    territory of the country, they even asked the European Community to

25    mediate so that this deblockade could be carried out and so that the

Page 11804












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Page 11805

 1    slaughters could be stopped?  Only after the situation was quite clear

 2    that nothing would come out of that, it is only then that the army

 3    launched this attack in order to deblockade the barracks.

 4       A.   I don't know about that.  I don't know anything about that.

 5    Newspapers did not arrive in Vukovar.  For the most part, there was no

 6    electricity either.  So I did not have the opportunity of hearing about

 7    this, even if it was the case.

 8       Q.   All right.  Tell me, do you know about the all-out attack of the

 9    MUP of Croatia and the National Guard Corps and other paramilitary

10    formations against all blocked military barracks throughout the territory

11    of Croatia?  Do you know anything about that?

12       A.   No.  I know about Slovenia.  As for these, I don't know.  Oh.  I

13    know, I heard, yes, yes, there were such occurrences.

14       Q.   Mr. Dulovic, before that, during the summer, you were in Borovo

15    Selo; is that right?

16       A.   Yes.

17       Q.   Did you establish then that on the 4th of July the first mass

18    killings of Serbs were perpetrated?

19       A.   I don't recall.  No.  Which is not to say that this didn't happen.

20    I'm just saying that I don't remember.

21       Q.   Tell me, are you aware of the fact that 20 people were executed by

22    the children's medical centre in Vukovar, and then in Zelica Ulica again

23    over 20 people were executed by a firing squad?

24       A.   I was in both of these streets, but I did not hear about this,

25    about the execution of children.

Page 11806

 1       Q.   Did you hear --

 2            JUDGE MAY:  What's being put is there was an execution by the

 3    children's medical centre.  Which may or may not be true, we don't know.

 4    It's just being suggested by the accused.  As far as you're concerned, you

 5    didn't hear anything about it.  Is that right, Mr. Dulovic, if it did

 6    occur?

 7            THE WITNESS: [Interpretation] About 20 children --

 8            MR. MILOSEVIC: [Interpretation]

 9       Q.   I'm not talking about children, Mr. Dulovic.

10       A.   Are you talking about the execution of children?

11       Q.   No, I'm not talking about the execution of children.  I was saying

12    that 20 persons were executed near the children's medical centre in

13    Vukovar.  I'm not talking about the execution of children at all.

14       A.   No, I don't know about that.

15       Q.   The children's medical centre is a location --

16            JUDGE ROBINSON:  Who were these 20 people who were executed?  Of

17    what ethnicity?

18            THE ACCUSED: [Interpretation] Serb civilians, Mr. Robinson.  Serb

19    civilians.

20            MR. MILOSEVIC: [Interpretation]

21       Q.   So, Mr. Dulovic, let it be quite clear:  I'm talking about all

22    these crimes that were committed during the course of the summer and

23    considerably before the attacks that were aimed at deblockading the

24    military barracks.  Are you aware of what happened on the 15th of August

25    when soldiers were attacked, soldiers who did not even have any weapons?

Page 11807

 1    They were attacked by the railroad.  There is information concerning two

 2    Ustashas, as they called themselves, Miljkovic and Zrinjic.  This Zrinjic

 3    took the gold teeth of this soldier out with a knife and then slit his

 4    throat.  Do you know about the kind of war that was being waged there in

 5    Vukovar and are you aware of the degree of cruelty involved?

 6       A.   I am not aware of that event.  As for the degree of cruelty, I

 7    heard a lot about that, and I read about it in the newspapers.  For

 8    example, that in Borovo Naselje, 40 Serb babies, young children from

 9    kindergarten, were slaughtered and put in plastic bags.  This is what all

10    the newspapers wrote.  I was there, my colleague Gulan from Borba also.

11    We checked this out.  Nobody ever gave a shred of evidence that this was

12    true.  These were lies in the media.  And their only objective was to

13    revolt the Serbs so that they would fight successfully.  So these

14    slaughters, all of this, I would have to see that in order to make any

15    such claims.  It was absolutely proven that none of these stories that

16    were written about all over and that were talked about over radio and

17    television were mere lies, lies.

18            JUDGE ROBINSON:  Just so I can get a better understanding of your

19    case, are you saying that the attack on Vukovar in the autumn was a

20    defensive response to the summer attacks on the Serbs?

21            THE ACCUSED: [Interpretation] Mr. Robinson, matters are actually

22    far more complex than that.  During the summer, 1.000 Serbs were killed in

23    Vukovar, and military barracks were blocked.  The witness referred to

24    that.  And the army launched an action to deblock the military barracks in

25    the centre of Vukovar.  Their power had been cut off, all supplies, and

Page 11808

 1    they were being shot at from all round.  So crimes were committed against

 2    the civilian population too.

 3            JUDGE ROBINSON:  When did the army launch this attack to deblock

 4    the military barracks?  What month was this?

 5            THE ACCUSED: [Interpretation] Well, the witness can say that for

 6    himself.  This was only in October, as far as I can see.  Or perhaps it

 7    was even the beginning of November.  But the witness can say this himself.

 8    Everything that happened during the summer preceded this action, that is

 9    to say, the deblockade -- the blockade of the barracks, the killing of

10    civilians, et cetera.

11            Mr. Robinson, I'm going to get to all of that.  I have here a

12    written statement that was taken out of a case file.  Dragutin Guzovski is

13    the name of the witness involved.  He was director of the public utilities

14    company.

15            JUDGE ROBINSON:  I have a good understanding now of the case that

16    you're putting.  So you may proceed with the cross-examination.

17            THE ACCUSED: [Interpretation] Let me just finish with this

18    Mr. Robinson.  He says here, because he was manager of the public

19    utilities and he had funerals and graveyards under his -- under him as

20    well, Croats were buried at the Catholic cemetery and Serbs were buried at

21    sports stadiums and various streets, et cetera, upon orders given by the

22    authorities in Vukovar.  Hundreds and hundreds of them.  And he talks

23    about this.  This is a handwritten statement of his.  This is to say that

24    he was not burying soldiers of the Yugoslav army.

25            JUDGE ROBINSON:  [Previous translation continues]... to that.  So

Page 11809

 1    let us wait until you get to that piece of evidence and you will try to

 2    adduce it.

 3            MR. MILOSEVIC: [Interpretation]

 4       Q.   Do you know at all why certain units, when all of this is borne in

 5    mind and certain volunteers, why they were in Vukovar itself or in the

 6    surrounding area?

 7       A.   In order to take Vukovar and enter it.

 8       Q.   Mr. Dulovic, are the reasons clear to you?  I mentioned at least

 9    some of them, that is to say, these mass killings, mass funerals --

10            JUDGE MAY:  Mr. Milosevic, this is something we're going to have

11    to determine, as to what the background is to this.  It's not for the

12    witness to say.  He gives his evidence as to what he saw himself and heard

13    himself.  We will have to make a decision as to why all this happened.

14    It's not for the witness.

15            MR. MILOSEVIC: [Interpretation]

16       Q.   Well, for example, do you know that on the 20th of August, those

17    who did it testified about it later and they were arrested by the military

18    authorities, a girl, Sladjana Petrovic, in block 1E, she was 25 years old,

19    she was carrying milk, they say:  "We stopped her, hit her, and she fell

20    onto the grass.  We tied her hands, took off her trousers, then we tied

21    her legs and we had her spread out that way, and I slit her stomach

22    because she said Zrnic was an Ustasha.  Zrnic then asked me to cut off her

23    jaw and I cut off her lower jaw and I gave it to Zrnic."  Did you hear

24    anything about such events?  Did you bear this in mind?  Or when he

25    said: "I slaughtered this soldier.  I grabbed him by the hair with one

Page 11810

 1    hand and then I slit his throat with -- halfway and then Zrnic grabbed me

 2    and then he cut his throat completely."

 3            JUDGE MAY:  How can the witness possibly answer a series of

 4    things?  It's not fair on him.

 5            Now, you were being asked first of all about an attack on a girl

 6    which apparently took place on the 20th of August.  Do you know anything

 7    about that?

 8            THE WITNESS: [Interpretation] Never heard of it.

 9            MR. MILOSEVIC: [Interpretation]

10       Q.   Not even the slaughter of this soldier, et cetera, et cetera?  I'm

11    just giving some individual examples here, because I realise that you were

12    using various individual examples.  So I don't find this very clear that

13    you do not have a single individual example referring to what was quite

14    well known in Vukovar and the surrounding area.  So you don't know

15    anything about this, and you've never heard of this?

16       A.   No.  No.  I have no reason not to speak about this if I knew about

17    it.

18       Q.   Do you know that, for example, even before the military court in

19    Belgrade there was a trial of some persons arrested by the army who had

20    committed crimes?  For example, they massacred people while cleansing

21    Vinogradska street.  That's a street in Vukovar.  You were probably there

22    at the time.

23       A.   I think this trial was held in closed session, was closed to the

24    public.  I would have gone to such a trial, always.

25       Q.   Yes.  I guess so, because you spent most of your career as a

Page 11811

 1    journalist following trials.  Here is the indictment and the judgement is

 2    also here.  For example, this is against Marko Filkovic, Zdenko Stefancic,

 3    Mire Dunatov.  It says that they brought in a Serb, Predrag Ciric, into

 4    the basement where Filkovic's headquarters were, then they started

 5    interrogating him about whether he belonged to the Serb Democratic Party.

 6       A.   Where is this taking place?

 7       Q.   In Vukovar.  And Stefancic put his pistol into Ciric's mouth and

 8    threatened to kill him.  And in order to intimidate Ciric and to coerce

 9    him to confess, they took him out to the backyard, showed him six males

10    corpses and, afterwards, Stefancic killed Ciric by firing eight bullets

11    from his pistol.

12            Did you hear anything about these crimes that trials were being

13    held about at that time?

14       A.   Do you have any details as to where this was happening?  I'm not

15    talking about Vukovar, but was this in a factory in Borovo, for example,

16    or something like that?

17       Q.   What I have here is the entire indictment.  It was happening in

18    Vukovar.  And this had to do with the cleansing drive of the Vinogracka

19    Ulica in Vukovar, and I assume you are familiar with that.

20       A.   Yes.  I don't know anything about this.  I know that what was

21    being referred to was that a woman was committing crimes in a factory.  I

22    don't know whether it was Vuteks or Borovo, the footwear factory.  But I

23    don't know anything more about that except that I heard about that.

24       Q.   Are you referring to a woman called Ksenija Piplica, also known as

25    Senka, born in 1967?

Page 11812

 1       A.   I can't remember her name.

 2       Q.   She took part in taking away three unidentified persons in the

 3    direction of Dunav, the old slaughterhouse, where these civilians were

 4    liquidated and she killed two of them by shooting from a pistol after

 5    which the corpses were pushed by her and the guardsman into the Danube.

 6       A.   I don't know about this.

 7       Q.   This is a judgement.

 8            THE ACCUSED: [Interpretation] If you wish, Mr. May, I can adduce

 9    it into evidence just like the one I have previously quoted.  However, I

10    do not have the impression that you are interested in this.

11            JUDGE MAY:  The Prosecution have any objection?

12            MR. GROOME:  Your Honour, if the Prosecution has an opportunity to

13    view these documents and they are certified copies of the court that

14    rendered the judgement, the Prosecution would not have any objection to

15    the entry of these documents.

16            JUDGE MAY:  Let us have the judgement.

17            THE ACCUSED: [Interpretation] I will give it to you a little

18    later, because I have another question to put.

19            JUDGE MAY:  Very well.

20            MR. MILOSEVIC: [Interpretation]

21       Q.   Let me just conclude:  You knew nothing about the fact that

22    several months before the events you describe in Vukovar, the liquidation

23    of Serbs in Vukovar was going on.

24       A.   No.

25       Q.   Very well.  Did you perhaps hear that Marin Vidic, who was a

Page 11813

 1    representative, an emissary of the Croatian authorities for Vukovar, said

 2    in his diary of the 4th of September, 1991, on page 111, he said:  "The

 3    Serbs are in town and we must get rid of all of them"?  Did you hear of

 4    these events?

 5       A.   No.  I didn't read about this.

 6       Q.   Do you know that among the murderers in Vukovar, there were many

 7    well-known criminals, such as Drazen Gazo who, before that, was convicted

 8    several times?  Did you hear of him and his crimes?

 9       A.   No.  I don't recall that name.  I don't remember this Drazen Gazo

10    you refer to.

11       Q.   Do you remember how the owner of the Grmec catering establishment

12    in Borovo Naselje was killed, and he was killed by this man?

13       A.   No.

14       Q.   I have here court files saying that on an unknown day in October

15    1991 - and this is about the murder in Grmec - the members of this unit,

16    this paramilitary unit, the Ustashas, threw an explosive into the Grmec

17    catering establishment owned by a man of Serbian nationality, Sucevic, who

18    was an invalid, and they killed him; and in July 1991, on an unknown date,

19    the facilities of the civilian defence, a Serb was brought in, his name

20    was Milenko --

21            THE INTERPRETER:  The interpreters didn't catch the last name.

22            MR. MILOSEVIC: [Interpretation]

23       Q.   -- he was tortured there and his body was thrown into the Danube.

24    And then there was a trial held against Zoran Sipos, also a member of

25    these groups of murderers who were marauding through Vukovar.  Do you know

Page 11814

 1    anything about this?

 2       A.   I don't know anything about this.  I'm not saying that such things

 3    did not happen, but I know nothing about them.  I could not have known.

 4    You're talking about Borovo Naselje.  The journalists first entered Borovo

 5    Naselje on the day Vukovar fell.  On that day, I was there, but even had

 6    these things happened, I did not have time to find out about them.

 7       Q.   Did you hear about the events on the 28th of October, this same

 8    Zoran Sipos's unit caught some civilians, Zorana Petranovic, Miladen

 9    Jovic, Radovana Vukicevic, Jovice Leskovac, also known as Vojo, a man

10    called Dekic, and made them dig trenches in a place where shells were

11    landing, after which they killed them.  Do you know anything about this?

12       A.   No.

13       Q.   Do you know anything about Nikola Cibaric, who was also killed by

14    that same group?  Do you know anything about this?  No, you don't, do you?

15       A.   No, I don't.

16       Q.   Very well.  I am reading all these examples from court files.  So

17    this is not taken from the papers which, as you say, were writing in a

18    sensationalist manner but from records of court proceedings.

19            Did you perhaps hear, because this is really a morbid event, when

20    you were in Vukovar what Nikola Pilipovic, also known as Siptar, did, who

21    committed sexual acts over the dead bodies of Serbian soldiers?  Did you

22    hear about that?

23       A.   No.

24       Q.   Do you know that General Spegelj mentions it in his book?

25       A.   I haven't read it.

Page 11815












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Page 11816

 1            JUDGE MAY:  Yes, Mr. Groome.

 2            MR. GROOME:  Your Honour, I'd object.  It seems clear that the

 3    witness has said he was only in Vukovar for three months.  I would ask

 4    Mr. Milosevic to confine any questions just to any of these events.  It

 5    seems he may be he entitled to question the witness regarding whether he

 6    knows of those events within that three-month period, but it seems now

 7    we're going into all sorts of matters that we have no connection to time

 8    and whether this witness has any possibility of having any relevant

 9    knowledge about them.

10            JUDGE MAY:  Yes, Mr. Milosevic.

11            THE ACCUSED: [Interpretation] Very well.  Very well.  Please,

12    then, take these court records, if you're interested, and have a look at

13    them, and after that you can decide -- yes, here you are.  The complete

14    files are in the possession of my associates, and I can deliver them to

15    you.  These are indictments and judgements, and you may be interested in

16    them.

17            JUDGE MAY:  The most straightforward course is to exhibit these as

18    one exhibit for identification.  At least, we'll exhibit them, give them

19    an exhibit number.  They will then be -- they will then be translated.

20    The Prosecution, meanwhile, can have a look at them, and if there's any

21    objection, we'll hear it in due course.

22            THE REGISTRAR:  Your Honours, it will be marked Defence Exhibit

23    54, marked for identification.

24            THE ACCUSED: [Interpretation] Let me just mention there are some

25    handwritten notes here, but I can get them from my associates without the

Page 11817

 1    markings that I made, and they will be handed over as court files.  I have

 2    underlined some things, marked certain passages, and so on and so forth.

 3    Very well.

 4            MR. MILOSEVIC: [Interpretation]

 5       Q.   Very well.  So you have not read Spegelj's book?

 6       A.   No.

 7       Q.   Very well.  Did you hear about the crimes perpetrated by Borislav

 8    Vukovic from Slatina and Pero Janjic, also known as Tromblon?  Did you

 9    hear anything about that while you were in Vukovar?

10       A.   I don't recall.

11       Q.   Very well, Mr. Dulovic.  Since you were interested in courts, do

12    you know that this Vukovic admitted to killing soldiers not only while he

13    was ambushing them but also at close range?

14       A.   As I have already said, I do not doubt that very probably things

15    like that happened, but I really don't know anything about them.  If I

16    knew anything about them, I would say so.  This was a long time ago.

17       Q.   Very well, Mr. Dulovic.  Does the name Jastreb mean anything to

18    you?

19       A.   Yes, it does.

20       Q.   Who was Jastreb?

21       A.   Jastreb was a man called Mile Dedakovic, and he was the commander

22    of the defence of Vukovar.  That was what he was called.

23       Q.   Very well.  Do you remember his order which read verbatim "Anyone

24    who imprisons a Chetnik, let him take him home because I have no use for

25    him"?  And everybody interpreted this to mean that prisoners should be

Page 11818

 1    killed.

 2       A.   I could not have heard this because this was happening inside

 3    Vukovar and I was outside Vukovar, not among the Croats but among the

 4    Serbian volunteers and soldiers, those who were holding Vukovar under

 5    siege.  So how could I have heard this?   How could I know what Dedakovic

 6    was ordering his men to do in Vukovar?

 7       Q.   Have you heard of the name of Zlatko Jankovic, who killed a

 8    fighter from World War II, an invalid of the national liberation struggle

 9    who had lost both legs?

10       A.   No.

11       Q.   Did you hear of Marka Filkovica, Knez; Zdenka Stefancic, Plavi?

12    Did you hear about them?

13       A.   No.  I noted down the names of people I interviewed, people who

14    told me things, but I know nothing about these names.

15       Q.   Very well, Mr. Dulovic.  Do you know anything about the blowing up

16    of Serbian houses?  For example, this was done by Ante Budimir.  Do you

17    know of this name or do you know anything about the blowing up of Serbian

18    houses in the area of Vukovar?

19       A.   No.  No.

20       Q.   Well, for example, in December 1983 [as interpreted] even The New

21    York Times' David Binder wrote of 10.000 Serbian houses that had been

22    blown up with dynamite in Croatia, and he said that Croatia had been

23    totally ethnically cleansed of Serbs, that it was the purest, ethnically

24    purest country in Europe.  So how come you know nothing of this and your

25    colleagues who were also there wrote about it?

Page 11819

 1       Q.   Well, maybe my colleague counted those houses and I did not have

 2    an opportunity to do so.

 3       Q.   Maybe you heard the statement made by the then Minister of Foreign

 4    Affairs, Granic, who said yes, 7.000 Serbian houses have been blown up,

 5    not 10.000.  So he himself agreed to the number of 7.000 and that no

 6    investigations were ever carried out.

 7       A.   I never listened to Granic speaking.

 8       Q.   Did you hear of Mira and Zvonko Tvorov who themselves killed 30

 9    people from snipers during these actions in Vukovar?

10       A.   Nobody told me about this, nor do I know anything about it.

11       Q.   Do you know anything about the guardsman, the member of the

12    National Guard Corps Mate Loncar who was especially prominent in these

13    events and who cut off the genitals of his victims and killed in the sight

14    of Dedakovic, that is Jastreb, several civilians?  Do you know anything

15    about this?  Did anyone tell you about this when you were in Vukovar?

16       A.   No, no.

17       Q.   But you say that Vukovar was shelled without ceasing and that the

18    Croats only fired shots when they were defending themselves from the

19    Serbs.  That's what you claim?

20       A.   That's what I saw.

21       Q.   And throughout all this time you never saw a single event that was

22    taking place in Vukovar; is that correct?

23       A.   I did not have the opportunity to watch what was happening inside

24    Vukovar.

25       Q.   Did you hear anything about commander Ivica Sojic in Vukovar and

Page 11820

 1    what he and his group were doing, such as burning corpses, or about what

 2    Guzovski was doing since they were questioned by a court and you were a

 3    court reporter?  So were you ever interested in this?

 4       A.   I never heard anything about this nor were there any indications

 5    that these people were on trial or where these trials were being held.

 6       Q.   I have here a handwritten statement by Guzovski.  Each page is

 7    signed.  He says that they did not bury JNA soldiers, that they burned

 8    their bodies, the members of the National Guard Corps and the military

 9    police of the Republic of Croatia.  It says further that Ivan Sojic set up

10    a special group to burn corpses of JNA soldiers, and in the statement

11    here, he says 30, 120, 40 members of these groups or, rather, corpses were

12    buried in stadiums, streets, and so on.

13            Do you know anything about the number of people who were killed

14    and, as you can see, buried by -- there are some sketches of locations of

15    burial sites adduced to this statement; the old cemetery, the mini market,

16    the park, the hospital, the stadium, a mass grave?

17            THE ACCUSED: [Interpretation] Are you interested, Mr. May, in this

18    statement of the director of the public utilities company in Vukovar?

19            JUDGE MAY:  We'll consider it.

20            THE ACCUSED: [Interpretation] All right.  Go ahead, consider it.

21            JUDGE MAY:  Mr. Groome, have you anything to say about this?

22            MR. GROOME:  Yes, Your Honour.  The Prosecution would object to

23    the admission of this document into evidence.  We would certainly welcome

24    Mr. Guzovski, I believe is his name, to appear before the Chamber so the

25    Prosecution could inquire equally into the matters that he has allegedly

Page 11821

 1    witnessed.

 2                          [Trial Chamber confers]

 3            JUDGE MAY:  No.  We shan't admit this statement.  Hand it back to

 4    the accused, please.  You can call the witness, of course, Mr. Milosevic.

 5            MR. MILOSEVIC: [Interpretation]

 6       Q.   You say in your statement on page 3, in the one but last

 7    paragraph, that the Serb villages were not damaged, and here you say or,

 8    rather, you said yesterday during your oral testimony that the Serb

 9    villages were damaged as well but that the Croatian ones were damaged

10    more, as far as I was able to note down.  Now, could you be more specific?

11       A.   Yes.  And you can see that to this day.  If you take the car and

12    go to Vukovar, it depends from one village to the next, but it is quite

13    obvious that the Croatian villages were far more damaged than the Serbian

14    ones, and they follow on from each other, one after another, several of

15    them.  Some are smaller, some are bigger, some are more damaged, some are

16    less damaged.  So the degree of destruction is not the same in all the

17    villages.

18       Q.   All right.  Thank you.  You also explain in the last paragraph on

19    page 3 that you met Veselin Sljivancanin in --

20       A.   Negoslavci.

21       Q.   What did you say?

22       A.   I said in Negoslavci for the first time.

23       Q.   Right, yes.  And it was clear that he was not responsible to

24    anybody in this combat area.  Now, on the basis of what do you say that?

25    How was this clear to you?

Page 11822

 1       A.   On the basis of his relations with the rest of the officers.  That

 2    was the opinion I had formed, that he did not answer to anyone.

 3       Q.   Well, how can you assume that an officer is not responsible to

 4    anyone, did not answer to anyone?

 5       A.   Well, I mean in the field of operations.  That's what it says

 6    quite clearly in that section.

 7       Q.   All right.  Tell me, then, you say he pulled out 150 people from a

 8    cellar and that he asked -- invited the journalists to go with him to the

 9    location, and that they were mostly Croats but that there were also some

10    Serbs among them; is that right?

11       A.   Yes, that's right.

12       Q.   And what happened next?

13       A.   What happened was that a situation arose and that foreign

14    journalists were present and so were others as Major Sljivancanin, with a

15    Motorola, called on and allegedly had a conversation with Mile Dedakovic,

16    nicknamed Jastreb, or hook, and we heard him say this.  We heard him

17    talking.  He said, "Don't allow these people here to die, but you come out

18    and be courageous and share this duel.  Let's have a duel."

19       Q.   Well, yes.  That is a sort of epic sequence that related to the

20    fact that actually meant that it was a shame for innocent civilians to die

21    but that if anybody was called upon to die then it should be the two

22    commanders.  It was a little archaic and expressed in epic terms but I

23    don't see that it is a crime of any kind.

24       A.   Well, nobody said that.  You asked me what happened, and I told

25    you.

Page 11823

 1       Q.   You go on to say that on the 13th of November, you yourself were

 2    present when Miroslav Radic with a group of men and with an experienced

 3    volunteer prepared to go into action.  Are you quite sure that it wasn't

 4    the action to save the jeopardised civilians and deblock the barracks?

 5       A.   No.  It was an attack on a water tower.

 6       Q.   A water tower?

 7       A.   It was the Croats who were there.

 8       Q.   You mean the snipers up on the water tower.

 9       A.   I did not see them.

10       Q.   Do you think that civilians live and reside up on a water tower?

11       A.   No.

12       Q.   You say that Aleksandar Bojkovski, known as Sasa, called you to

13    show you the corpses of six persons who were members of the ZNG, the

14    Croatian National Guard Corps, and you ascertained that they had been dead

15    for two or three days.

16       A.   Well, I would have thought so.  I can't actually say what they

17    looked like.

18       Q.   Well, never mind about the details, but there was something

19    suspicious there.  You were suspicious because you didn't see any weapons

20    standing round about.  Do you always think that there should be weapons

21    round about people who had been killed in battle fighting the National

22    Guard Corps, Croatian National Guard Corps?

23       A.   I never said that I was -- that this was a suspicious factor.  I

24    just noted what I had seen.  I said what I had actually seen.

25       Q.   Well, you say that they were dead for a few days but that there

Page 11824

 1    were no weapons beside them, so I assume that you were indicating this and

 2    that you thought that there should have been some weapons found round

 3    about.

 4       A.   No, I just meant what I said, that there were no weapons to be

 5    seen standing round about.

 6       Q.   So these ZNG guard members who were dead for three -- had been

 7    dead for three days had no weapons standing round about them.  You also go

 8    on to say that they were not in uniform or, rather, as I understood you to

 9    say yesterday, one of them was wearing a uniform.  Others were -- the

10    others were not, or parts of uniforms.  Do you know how many participants

11    took place in these operations around Vukovar and people without uniform

12    taking part in them?

13       A.   I don't know.  There's no way I could know that.

14       Q.   All right.  Tell me, then, please, you say you heard the

15    conversation between Vojislav Seselj and a group of officers going on and

16    that you heard him say that it was a great test for the Serbs and that he

17    said that no Ustasha must be allowed to leave Vukovar alive, and you

18    ascribe those words to Seselj.  Are you quite certain that you heard him

19    say that?

20       A.   Yes, absolutely so.  Otherwise, I wouldn't have made a note of it.

21       Q.   Do you mean to say, then, Mr. Dulovic, that in your notebook you

22    recorded only the facts or did you make sketches for the articles you

23    wished to publish?

24       A.   I had several notebooks.  And this was important for me.  It was

25    important for me to hear what the vojvoda was saying.

Page 11825

 1       Q.   All right, Mr. Dulovic.  Is it quite clear that you were

 2    endeavouring in this testimony, too, to explain in every possible way, as

 3    has been the policy of your entire editorial office, that is to say the

 4    Vreme magazine, to put the blame on the Serbs for what had happened there

 5    and to all my questions about the crimes that came to pass before, the

 6    mass killings, the mass graves, the liquidations and executions of people,

 7    blockades of the barracks, your answer to all of that is that you know

 8    nothing about that?

 9       A.   I was not there.

10       Q.   Well, tell me at what distance you listened in to the conversation

11    that Seselj had.

12       A.   I was not listening in.  The door was half open, the door was

13    ajar.  I wasn't eavesdropping.

14       Q.   Well, tell me, then, what capacity was Seselj in there?

15       A.   You must ask him that.

16       Q.   As far as I recall, at the time, he was an MP in the Assembly, a

17    deputy there and a representative of his own party; right?

18       A.   Probably, yes.

19       Q.   And how many people attended that meeting?

20       A.   Five or six, thereabouts.

21       Q.   Do you know the names of those people?

22       A.   Some of them I've already stated.

23       Q.   You told us all the names you knew of; is that right?

24       A.   Yes.

25       Q.   You say that in Borovo you saw many people shut up in the Borovo

Page 11826

 1    shoe factory, that they were Croatian civilians, including women and

 2    children, that you saw a large quantity of weapons which had quite

 3    obviously been handed over.  Now, do you make a connection between the

 4    large number of persons and the weapons that you saw on the spot, saw

 5    there?

 6       A.   I do link up the two because I was there when they left and when

 7    they were boarded onto buses.  There were soldiers there and civilians

 8    there too, women as well.

 9       Q.   All right, then.  Explain this to me:  What happened to those

10    people?

11       A.   They got onto the buses and they left or, rather, they were taken

12    away.  Now, where they were driven to, we didn't know at that time.  We

13    were later told that they had been taken off to Sremska Mitrovica to the

14    prison there, but not only to Sremska Mitrovica - and this is the freshest

15    information that I have, the most recent - but that they were also taken

16    off to a kind of camp near Zrenjanin, to a settlement there or whatever.

17    It was called Begejci and a place called Stajicevo.  So the civilians were

18    separated from the soldiers.  And this is something that is going to be

19    published and investigated and proved that that was so, that two camps

20    existed in the vicinity of Zrenjanin, the town of Zrenjanin.

21       Q.   As for the soldiers that were taken into custody, I assume they

22    were treated like prisoners of war?

23       A.   I don't know.

24       Q.   And as for the women and children, do you assume that anybody

25    arrested women and children or was this some sort of operation that the

Page 11827












12  Blank page inserted to ensure pagination corresponds between the French and

13  English transcripts.













Page 11828

 1    army engaged in to care for the women and children, not to leave them in

 2    the war stricken area, to put them up somewhere?  Did anything happen to

 3    those people, the people who were put up in a collection centre?  There

 4    were no camps in Serbia, nor do I know that the army had any camps at all.

 5       A.   I don't know under whose competence they came, they were placed,

 6    but what I'm saying is quite correct.  These people were exchanged.

 7       Q.   Do you mean to say they were handed over to the Red Cross and

 8    then --

 9       A.   I don't know.  All I know is that they were exchanged with the

10    Serbs that had been held captive.  Some sort of bargain was struck along

11    those lines.

12       Q.   And do you have any knowledge or information that these people who

13    were either taken prisoner as soldiers or put up in collection centres as

14    civilians, that anything happened to any of those people?

15       A.   No.  Nobody is saying that.  Nobody is claiming that.

16       Q.   All right.  But you say that you noticed that the situation was

17    one of anarchy, that everybody did some shooting during the night, shooted

18    about as they saw fit.  You say you spoke to two volunteers who were

19    drunk.  What part of town were you visiting at that time?

20       A.   I was in the part of town that is referred to as Sajmiste.  It is

21    a part of town which is populated exclusively by Serbs.  At least, that

22    street was.

23       Q.   All right.  Now, you also say that a man, on the 21st of November,

24    told you that they went around killing in Ovcara from 5.00 in the

25    afternoon until 1.00 in the morning.  And I don't want to repeat all the

Page 11829

 1    other things that you stated.

 2       A.   Yes.  Yes.

 3       Q.   Now I'd like us to take a look at your statement together.  You

 4    referred to your statement yesterday, so let's take a look at it together.

 5    Let me just find the portion that I'm looking for.

 6            I assume that you were called in as a witness and that the events

 7    were the subject of an investigation.  Isn't that so, Mr. Dulovic?

 8       A.   Yes.

 9       Q.   And you say the following: That the criminal proceedings were

10    taken against perpetrators unknown, perpetrator unknown.

11       A.   Perpetrators.

12       Q.   Yes, it's in the plural, I made a mistake saying it in the

13    singular.  In the plural, against perpetrators unknown, persons unknown,

14    and on the basis of that, you note that the court or, rather, the

15    prosecution did not have the intention of identifying the actual

16    perpetrators.  Have I understood you properly, what you wanted to say?

17       A.   You understood very well, yes.

18       Q.   All right, then.  Now, you go on to say that -- and I understood

19    you to say yesterday --

20                          [Trial Chamber and senior legal officer confer]

21            JUDGE MAY:  Yes.  Sorry to interrupt, Mr. Milosevic.  Go on.

22            MR. MILOSEVIC: [Interpretation]

23       Q.   I assume that as an experienced journalist in court affairs,

24    because your job was to follow court trials, that you knew that a case is

25    raised against unidentified perpetrators when the perpetrators cannot be

Page 11830

 1    identified.  And you say on page 4 of your testimony or report here:

 2    "Later on, for many years on the basis of this description -- several

 3    years later, based on this description, I accidentally learnt that this

 4    could have been a certain Slavisa Pavlovic from Smederevo.  I do not know

 5    where this man is now or whether he is alive, nor did I check if this

 6    information was correct."

 7            So in this statement of yours, you do not -- the one you give as a

 8    witness, you say you do not know whether the facts are correct.  You

 9    indicate the possibility of this having been a man called Slavisa Pavlovic

10    from Smederevo who was responsible, and the proceedings, the lawsuit was

11    raised against perpetrators unknown.  And you are taking part as a

12    witness, and in your testimony you indicate the possibility, just the

13    possibility that it might be a man called Slavisa Pavlovic.  So before you

14    indicated the possibility of it having been this man, did you have in mind

15    a certain name, or if you pointed out this possibility, for you -- and you

16    yourself say that you didn't check the information out, that they were

17    able, and I'm asking you this as an experienced journalist who attended

18    the work of courts, that this indictment should be rephrased with the name

19    of Slavisa Pavlovic contained in it before further investigations were

20    undertaken?

21       A.   Ask me a question now, please.

22       Q.   My question is this:  As far as I remember, you said that the

23    state was not interested in uncovering this.

24       A.   I did not mention the state.

25       Q.   Well, all right.  The authorities.  The court.  It doesn't matter

Page 11831

 1    now.  That they weren't interested in uncovering, unravelling this whole

 2    affair, which means that the authorities bring this case to court, and I'm

 3    talking about the court authorities, how then are you able to conclude

 4    that the authorities weren't interested in ascertaining who was

 5    responsible for committing this act?

 6       A.   Because I think that at that particular point in time, the

 7    authorities were not interested in really and truly bringing perpetrators

 8    to justice but that this was all a farce.  All of this was a farce.  And

 9    this man, Slavisa Pavlovic, whom I talk about here, when he talked to me

10    or, rather, not me but there were several of us, when he told us what the

11    shooting in Ovcara looked like, I described this.  However, his name -- I

12    heard his name from a man who ought to have known about it, and he was in

13    charge of controlling and going after criminals.  So I didn't see him in

14    Vukovar, but he was there, and this is something that I heard from a

15    general, General Aleksandar Vasiljevic, who after a certain amount of

16    time, later on when I recounted the event to him, after that he told me

17    that the man in question was a man named Slavisa Pavlovic from Smederevo,

18    and I assume that that was something that the army had to have known or,

19    rather, the court, if it seriously wanted to persecute and bring to

20    justice, bring to trial war criminals.  But there was no serious intent in

21    that direction on the part of the authorities, as you call them.

22            JUDGE MAY:  I'm going to have to interrupt now because it's time

23    to adjourn.

24            Mr. Milosevic, we can continue in the morning.  You will have two

25    hours left for cross-examination of this witness on the time that we have

Page 11832

 1    allowed.

 2            We will adjourn now.  Would you be back, please, Mr. Dulovic, at

 3    9.00.

 4                          --- Whereupon the hearing adjourned at 1.48 p.m.,

 5                          to be reconvened on Friday, the 18th day of October,

 6                          2002, at 9.00 a.m.