Tribunal Criminal Tribunal for the Former Yugoslavia

Page 13486

1 Tuesday, 26 November 2002

2 [Open session]

3 [The witness entered court]

4 [The accused entered court]

5 --- Upon commencing at 9.14 a.m.

6 JUDGE MAY: Yes. We're just being handed, marked D57, the

7 transcript of the interview. Yes.

8 MS. UERTZ-RETZLAFF: Your Honour, I just wanted to mention that

9 you find in the interview a part shaded in grey, and these are the parts

10 that were not played.

11 JUDGE MAY: Very well. We've got the entire interview in front of

12 us.

13 Yes, Mr. Milosevic.

14 WITNESS: WITNESS C-061 [Resumed]

15 [Witness answered through interpreter]

16 Cross-examined by Mr. Milosevic: [Continued]

17 THE ACCUSED: [Interpretation] Today, to begin with, let us start

18 with the map that this witness commented on. I think it was not in

19 private session, so I assume we don't have to go into private session now.

20 JUDGE MAY: This, I take it, is the map of the RSK.

21 THE ACCUSED: [Interpretation] Yes. That is the map that this

22 witness started his testimony with. So --

23 JUDGE MAY: Just a moment. For the record, it must be noted it's

24 Exhibit 326, tab 11. The witness has a copy? Yes. Yes.

25 THE ACCUSED: [Interpretation] Before I continue, I should just

Page 13487

1 like to draw attention to the fact that, according to my accounts, the

2 examination-in-chief lasted 24 hours. You told me I would have 20 hours.

3 So would you please reconsider and establish whether my calculations are

4 right. I may be wrong. It is quite possible that I made a mistake.

5 JUDGE MAY: Mr. Milosevic, let me deal with that. You are wrong,

6 in fact. It was 20 hours. I noted it.

7 THE ACCUSED: [Interpretation] Very well.

8 MR. MILOSEVIC: [Interpretation]

9 Q. First of all, is it true to say that this was no secret map?

10 A. This was a public document.

11 Q. I see. A public document. It was all over the Krajina. It was

12 like a leaflet; isn't that right?

13 A. No, not a leaflet but what it is; a map with data.

14 Q. Yes, with data: A summary, information on the back of the map,

15 even a summary in the English language should it have to be shown or

16 distributed to foreigners.

17 A. I don't know for what purposes it was used. I obtained it in

18 1994.

19 Q. And this was issued by the Serbian army of Krajina with the help

20 of the journal Vojska from Belgrade; is that right?

21 A. Yes. That is what it says, with the assistance of the publishing

22 institution Vojska of Belgrade.

23 Q. And there's the stamp of the Republic of Srpska Krajina, and the

24 stamp of the Serbian army of Krajina?

25 A. Yes. The new emblem from 1994, or coat of arms.

Page 13488

1 Q. Would you now please comment, as you did before, with regard to

2 this map, but first of all, before you do that, please tell me, what was

3 the percentage share of the population in Knin municipality by ethnicity.

4 In Knin municipality.

5 A. Knin municipality had about 90 per cent of the population were

6 Serbs, or up to 90 per cent, and 10 per cent were others. Nine per cent

7 were Croats, about 1 per cent were Yugoslavs.

8 Q. So that would roughly be the composition in 1981.

9 A. I may be wrong, plus or minus 1 or 2 per cent.

10 Q. Do you remember that the leadership of the Republic of Srpska

11 Krajina would frequently emphasise the fact that Croats in Knin were

12 living on a footing of equality like all other citizens and that the

13 authorities of the Republic of Srpska Krajina are not behaving towards the

14 Croats in the way in which the Ustasha authorities are behaving towards

15 the Serbs? Is that right or not?

16 A. The Croats know best how they lived in Knin, as do the people from

17 Serbia and Knin. I will give you just three examples. There is no doubt

18 that they didn't feel at ease during the time of inter-ethnic

19 disagreements and conflicts, but it is also a fact that already in October

20 some citizens of Croatian ethnicity and Albanians suffered damage because

21 of the events in Knin.

22 In April 1991, the police of Krajina selectively started seizing

23 weapons from citizens - not all of them, but from Croats - and this

24 especially happened in the village of Potkonj in Kninsko Polje, and

25 Vrpolje. They experienced unpleasantness or worse than that, certain

Page 13489

1 suffering. The inhabitants of the Croatian village of Kijevo, on the 26th

2 of August, 1991, during the attack of the JNA.

3 Also in 1993, Croats in Knin felt not only unsafe, but they were

4 physically mistreated by refugees from Benkovac after the attack of the

5 Croatian army on Ravni Kotari, especially people from Islam Grcki and the

6 surroundings who would come to Knin. The police brought them there in an

7 organised fashion and instigated them to move into Croatian houses so that

8 the Croats had to flee and seek shelter in the centre in Vrpolje, and then

9 the police organised their resettlement by buses via Zitnic towards the

10 territory controlled by the Croatian government.

11 That is as far as Knin is concerned. I don't want to be cynical,

12 but the Croats in Knin fared better, in spite of what I just said,

13 compared to how they fared in areas where there were armed conflicts.

14 Q. I remember, for instance, that Milan Martic said with pride that

15 Croats in Knin were living in conditions of complete equality, which we

16 received with the greatest measure of approval, and another colleague of

17 yours, a protected witness, not quite as protected as you but also

18 protected, confirmed that in Knin, the Croats did indeed live on a footing

19 of equality. Are you denying that now?

20 A. I'm just telling you how equal they were.

21 Q. So you are claiming that they were not equal in Knin.

22 A. I don't -- I know that they didn't feel comfortable and that I

23 know many Croats in Knin who felt in jeopardy.

24 THE INTERPRETER: Microphone, please.

25 MR. MILOSEVIC: [Interpretation]

Page 13490

1 Q. You held a very important position. I won't name it now in public

2 session. If you found that there were such cases of mistreatment, why

3 didn't you prevent it?

4 A. The authorities in Knin acted in several ways to calm the

5 situation. First of all, the staff for the defence of Knin, for the

6 barricades, was disbanded. It was formed in Golubic or, rather, to be

7 more precise, it was formed on the 16th of August, 1991, in Padjeni, and

8 it was based in Golubic. And then also, efforts were made to disband the

9 Council of National Resistance which caused the greatest amount of

10 confusion and disturbance when that was not necessary. And also,

11 endeavours were made through the government of the Republic of Srpska

12 Krajina to place the police under the control of the government and

13 civilian authorities, and a lawyer was appointed to the position of

14 Minister of Internal Affairs in the government of SAO Krajina.

15 Also, at the beginning of August, also through the government of

16 Krajina, measures were undertaken for the police and the DB to be

17 subordinated to the legal authorities of Krajina. This was also done on

18 the 21st of November, 1991, through the Assembly of SAO Krajina. Such

19 measures were also taken in February 1992, but by then, the position of

20 the authorities that were behind these measures had weakened. This was

21 not achieved because you supported those structures.

22 Q. Well, this witness, your colleague who spoke before you, said

23 quite the opposite. Which structures? I hear for the first time this

24 term of parallel structures. This is information that I received from you

25 now, that you had parallel structures in Krajina.

Page 13491

1 A. These were structures formed by the DB of Serbia, Jovica Stanisic,

2 Frenki, and you personally. Those structures, in 1991, on the 16th of

3 August, 1990, sought to obtain legitimacy by winning support of the

4 Serbian Democratic Party, and they did get it at a meeting of the Main

5 Board in Padjeni on the 16th of August, 1990. However, those structures

6 started operating in a manner that was not originally thought necessary.

7 The idea was for the Croatian government should not affect the

8 position of the Serbs regarding autonomy. However, those structures that

9 were formed in Golubic referred to the authority of the SDS and the

10 authority of the president of the municipality, and they didn't form a

11 staff to control the barricades but a war camp. And upon the initiative

12 of the president of the Assembly, the Executive Board of the SDS, at the

13 beginning of September 1990, decided that those structures be disbanded.

14 And the president of the Assembly persisted in that direction, and that

15 camp was disbanded. Martic was in charge of it in a wood at a first, then

16 in a meadow, then at Cinobadova Glavica, the memorial home, then the Knin

17 fortress. And from the 30th of September onwards, it moved to the police

18 station in Knin.

19 Jovica Stanisic, in August 1990, was already in contact with those

20 structures. And those structures took over control over the Centre for

21 Information of Knin municipality.

22 JUDGE MAY: One at a time. Let the witness finish. But can you

23 keep your answers fairly short, Witness C-061, so that the accused can

24 have the opportunity to ask his questions.

25 Is there anything more you want to add to what you were just

Page 13492

1 saying about the structures?

2 THE WITNESS: [Interpretation] This structure started to be formed

3 in 1990. It was publicly announced over the Council for National

4 Resistance, and later on, that structure operated in conjunction with the

5 Secretariat for Internal Affairs and the Ministry of Interior of SAO

6 Krajina as a parallel structure to the extent that they were not

7 subordinated to the legal authorities of the SAO Krajina, though the

8 authorities of Krajina did take part in the nomination of certain

9 individuals in that structure for a particular purpose, such as was the

10 case with Milan Martic.

11 MR. MILOSEVIC: [Interpretation]

12 Q. There's a Serbian saying which implies causing confusion. Now,

13 tell me specifically, who were the people who constituted that parallel

14 structure? Tell me the names of the people in that parallel structure in

15 1990 in Knin and the surroundings. Who were they?

16 A. Milan Martic, Jovo Vitas, Nebojsa Mandinic, Jovica Stanisic, the

17 journalist Cvetkovic, an unknown individual whose name I don't remember

18 from the room for encoding, and other people who were connected to them

19 from the SDS and from among the citizenry. That was the structure that I

20 identified in 1990, beginning with August through the autumn, until

21 January 1991.

22 In 1991, that structure consisted of Jovica Stanisic, Franko

23 Simatovic, Milan Martic, Dusan Orlovic - of course, Dusan Orlovic was

24 there in 1990 as well - and people under their control and influence right

25 through the presidents of the municipalities of Lapac, Korenica, Benkovac,

Page 13493

1 the vice-president of the government, Dusko Starevic. And later, Veljko

2 Matijasevic, the president of the Assembly, under the influence of

3 Stanisic, joined in in 1992. Under your influence and that of Jovica

4 Stanisic and Budimir Kosutic, Mile Paspalj joined in, and from the 16th to

5 the 26th of February, that structure managed to assert its formal and

6 legal authority in the Republic of Serbian Krajina.

7 Q. I see. It's becoming clearer to me now. Do you consider all the

8 officials in the Republic of Srpska Krajina and, before that, in SAO

9 Krajina, who were in confrontation with you to constitute a parallel

10 structure?

11 A. No, but those who did not respect the decisions of the government

12 and Assembly of SAO Krajina and who used coercion upon members of the

13 government to be tolerated, they prevented by force the government and the

14 Assembly to assert their legal authority over them.

15 Q. What were they? Were they a faction in the SDS or were they

16 members of other parties? What were they? What kind of a structure were

17 they?

18 A. They were members of the DB of Serbia, members of the so-called DB

19 in Krajina, members of the police of Krajina headed by Milan Martic, a

20 part of the politicians in the SDS and outside it, and other people who

21 were not in the SDS but who collaborated with the DB of Serbia.

22 Q. What do you mean the DB of Serbia in 1990?

23 A. Cooperation, obedience, coordination. That's what I mean by

24 collaboration. The DB of Serbia had no competence over the territory of

25 Croatia in 1990. In formal terms, it could have no competence to govern

Page 13494

1 or to run the police in SAO Krajina and the Republic of Krajina in 1990

2 and later, and it did that nevertheless. So its presence in the area was

3 illegal.

4 Q. The fact that the DB of Serbia was not competent in Krajina I

5 quite agree with you.

6 A. In formal and legal terms, it was not competent, but it did have a

7 command position over the structure, consisting of the people I have

8 listed.

9 Q. Now, please don't get so excited. Without any excitement --

10 A. No, I'm not getting excited. I'm trying to be as brief as

11 possible in response to what Judge May has said.

12 JUDGE MAY: Now, both of you, both of you bear in mind that this

13 has to be interpreted, and bear in mind too what I said earlier, before

14 the cross-examination began, about breaks between question and answer.

15 Yes, Mr. Milosevic.

16 THE INTERPRETER: Microphone, please, for Mr. Milosevic.

17 THE ACCUSED: [Interpretation] Yes, of course, Mr. May. I'll join

18 in in what you said, because quite obviously this is highly interesting,

19 not to say amusing.

20 MR. MILOSEVIC: [Interpretation]

21 Q. Now, you've enumerated Martic, Vitas, Orlovic, a man called

22 Nebojsa whose surname you don't know.

23 A. Mandinic Nebojsa, the president of the Assembly of Associated of

24 Labour of the municipal Assembly of Knin.

25 Q. And Man -- what was the other name?

Page 13495

1 A. Mandinic.

2 Q. Right, Mandinic, the president of a Chamber of the municipality of

3 Knin because the chamber had the Chamber of Associated Labour and the

4 Citizens' Chamber.

5 A. No, socio-political one.

6 Q. All right, socio-political.

7 A. Socio-political and the Chamber of Associated Labour.

8 Q. Well, one of the presidents of the three chambers. And what was

9 Martic? Tell me that.

10 A. He was a police inspector at the police station in Knin.

11 Q. At the time that the SAO Krajina was formed, is that it?

12 A. Yes. When the SAO Krajina was formed, he was in the Council for

13 National Resistance, and on the 4th of January, 1991, the Executive

14 Council, Provisional Executive Council of SAO Krajina promoted David

15 Rastovic, president of the Municipal Assembly of Knin and vice-president

16 of the Executive Council of SAO Krajina and appointed him secretary of the

17 interior for internal affairs.

18 Q. You had nothing to do with that, no participation in that, did

19 you?

20 A. Yes, I did.

21 Q. Well, at the proposal and so on and so forth, as a man behind the

22 looking glass, as you said yesterday. So Martic was Minister of the

23 Interior for Krajina?

24 A. Secretary of the SUP, the Secretariat for Internal Affairs of

25 Krajina.

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Page 13497

1 Q. And where is Martic from?

2 A. Martic was born in the village of Zagrovic, near Knin.

3 Q. So Martic was secretary of the SUP of Krajina. He was from Knin.

4 That first man. Now, who is Vitas? Who is this other one?

5 A. Jovo Vitas; he was a businessman in Knin.

6 Q. A businessman in Knin?

7 A. Well, he lived in Knin. Where he was born, I can't say.

8 Q. Is he from Krajina, Jovo Vitas?

9 A. I don't know where he was born exactly. The surname Vitas existed

10 around Bosanska Krupa as well.

11 Q. All right. That's not too important. But he was in Knin as well;

12 is that what you're saying? And this man Orlovic, what was he? Who was

13 he?

14 A. Dusan Orlovic was a medical student. He never graduated. And he

15 was a native of Lika. And he sort of did nothing much, went around

16 without a job. But from 1989, we knew that he was always present when any

17 of the events took place in the area, any important events.

18 Q. And what was his function, his post?

19 A. He was member of the Council of National Resistance. Martic

20 appointed him as head of the DB, the state security in Krajina.

21 Q. So the head of the state security in Krajina. And you say that he

22 was originally from Krajina himself. That's right, isn't it? And were

23 they members of any party, any one of them?

24 A. Martic wasn't. Orlovic, as far as I know, wasn't either. Jovo

25 Vitas, as far as I know -- I'm not quite sure whether he was a member of

Page 13498

1 the Socialist Party of Croatia, of a Yugoslav orientation, but he did have

2 some participation in preparations -- in the organisation. Then there was

3 Nebojsa Mandinic, who was a member of the SDS.

4 Q. All right. Tell me this: This man Nebojsa, Nebojsa Mandinic,

5 apart from the fact that he was president of this Council of Associated

6 Labour, or whatever it was called, of the Municipal Assembly of Knin, did

7 he hold any other post?

8 A. Post, you're asking about, what post he held. Well, together with

9 Bogoljub Popovic and Martic, he had something to do with some security

10 matters. I can't really be specific what the name and title was.

11 Q. Well, I assume you were together there. They weren't there alone,

12 the two of them on one side and you on the other side. I assume that all

13 of you were together.

14 A. Each one of us in our own way.

15 Q. All right. I understood it --

16 THE INTERPRETER: Microphone, please, for Mr. Milosevic.

17 JUDGE MAY: The interpreters are having trouble hearing. Is your

18 microphone on?

19 [Trial Chamber and registrar confer]

20 JUDGE MAY: The problem is not allowing pauses and not allowing

21 the registrar time to switch it on, so can you bear that in mind.

22 THE ACCUSED: [Interpretation] Okay. So that means that we

23 can -- we have to make pauses; is that it, Mr. May?

24 JUDGE MAY: Yes.

25 MR. MILOSEVIC: [Interpretation] Very well.

Page 13499

1 Q. So you were saying Martic, the secretary of the SUP; Vitas was an

2 official there; Orlovic was the head of the DB state security for Krajina;

3 Mandinic was the president of one of the chambers of the municipality of

4 Knin. How can they be parallel structures, then? How can a parallel

5 structure be made up of people who hold official posts in the regular

6 structure, even before the SAO Krajina was proclaimed? What kind of

7 parallel structure were they, then?

8 A. What they were doing was not the structure of the institutions

9 which were legally elected and established at multiparty elections. They

10 were structures which had illegally cropped up, arbitrarily, on their own

11 initiative, and that is why I call them parallel structures to the legal

12 institutions.

13 And I said that Martic was elected as secretary of SUP. But the

14 Assembly of Krajina, following a proposal by the Prime Minister, appointed

15 him Defence Minister for SAO Krajina on the 29th of May. And he himself,

16 on that particular day, took the oath of office. And the very next day,

17 having been convinced by Frenki and people from the DB of Serbia, he

18 refused to hand over to the Ministry of the Interior, and to the newly

19 appointed minister, to hand over his office to Dusan Vjestica. And in

20 that way, it was through the force of might, because, together with the DB

21 of Serbia, he had control over the armed formations of both the police

22 force and the paramilitaries which had been set up in the camp of Golubic

23 in April. So quite simply, he had might and power behind him, and the

24 government and Assembly were not able to impose Vjestica, or rather, to

25 force him to hand over his office to Vjestica.

Page 13500

1 But one month elapsed, and on the 27th of June, in Grahovo, the

2 Assembly was forced to accept his will in order to avoid an internal

3 conflict in Krajina or a civil war at a point in time when the conflict

4 was escalating with Croatia. So it was in that sense that he and they

5 made up the parallel structure, once again in power in Krajina. They

6 imposed their own will through force.

7 Q. Now, explain this to me, please: As you have just said - I hope

8 I'm making sufficient pauses, Mr. May - that the Assembly lent its support

9 to the positions of Milan Martic, how, then, did you say that he achieved

10 his goals by force? Did he perhaps cock his rifles at the deputies in the

11 National Assembly, or did he perhaps arrest a national deputy, or did

12 anything else of that kind? So why are you fabricating nonsenses of that

13 kind?

14 A. Well, he did do that in 1995, and I complained to you personally

15 that units of the police force had stormed the area. They had come in

16 from Bihac and stormed the Municipal Assembly of Knin. I complained to

17 you personally and asked you to intervene to quell the situation.

18 And in 1991, he had the power because he was in control, together

19 with the DB of Serbia, the state security system of Serbia. He controlled

20 the regular police force and the police force of Krajina, the one that was

21 established as the Krajina police, that is to say, the paramilitary

22 formations that had already been formed. And after Dusan Vjestica took

23 over power - or rather, he didn't take over power, I beg your pardon, but

24 the Assembly nominated him and appointed him to the post of Minister of

25 the Interior - he passed decisions to replace at least two deputies, two

Page 13501

1 of Martic's deputies. And they, Martic and his assistants, tore up those

2 decisions by the newly appointed minister and made fun of him and the

3 decisions. So there was no other structure, nor was there any possibility

4 of imposing -- of having Minister Vjestica take up his role.

5 Now, to avoid an interior conflict, an interior clash and a civil

6 war between the Serbs in Krajina, or amongst the Serbs in Krajina, this

7 was accepted as a fact, that is to say, the authority of the DB and the

8 authority of Martic, who was in command of the police force, because they

9 had their own political goals, that is to say, the same political goals,

10 which were that of defending a Krajina. So from that time, this parallel

11 structure began to function; not only from that time, but it was

12 functioning with those same political goals: to preserve Krajina within

13 Yugoslavia, or rather, within the state that you yourself created. And

14 the interests of the Assembly and government was also to preserve Krajina

15 and defend it from attacks by the armed forces of the Croatian government,

16 and that formed a symbiosis of a kind.

17 However, this parallel structure - the paramilitary formations,

18 the police of Krajina, the DB of Serbia, with its paramilitary units - did

19 not only protect and defend the inhabitants of Krajina but caused

20 provocations towards Croatian threats to create clashes and to pull in the

21 Yugoslav People's Army, to pull it into the conflict, as you yourself had

22 planned. And that is why the policy of these parallel structures differed

23 from the political goals and endeavours made by the government and the

24 Assembly, that is to say, the legal structures of the SAO Krajina.

25 Q. Tell me this: Wasn't it your objective too to preserve Krajina?

Page 13502

1 A. I was precisely saying that yes, it was.

2 Q. Well, let me ask you something now. Did you say, on the first day

3 in court here, that in 1990, what had happened there was that the head of

4 the state security of Serbia turned up, Jovica Stanisic, along with his

5 assistant, or whatever you called him, Franko Simatovic? Isn't that

6 right?

7 A. Jovica Stanisic came for the first time in August 1990, and at the

8 beginning of April, Jovica Stanisic and Franko Simatovic; Fica; your

9 personal security detail or somebody from your security, Captain Dragan;

10 another man who had a name that associated -- that brought to my mind

11 France; and some other instructors turned up after their meeting with you,

12 that is to say, after the second half of May, in order to -- I apologise.

13 JUDGE MAY: [redacted] you should remember that -- try and

14 keep your answers fairly short, because otherwise time is going to go on.

15 Yes, Mr. Milosevic.

16 THE INTERPRETER: Microphone, please, for Mr. Milosevic.

17 Microphone.

18 MR. MILOSEVIC: [Interpretation]

19 Q. Well, let's see. The head of security of the DB, Jovica Stanisic,

20 was in Knin.

21 A. I didn't hear the start of your question. The question wasn't

22 interpreted into Serbian.

23 Q. I'm talking about 1990. The head of the DB of Serbia, Jovica

24 Stanisic, was in Knin?

25 A. I didn't know his function in 1990. Martic said that it was a man

Page 13503

1 from the MUP of Serbia.

2 Q. All right. Very well. Now, in 1991, you said again that with

3 Radmilo Bogdanovic, this minister, this head of the DB, attended a meeting

4 that was held at my office in March, and you mentioned something along

5 those lines.

6 A. Radmilo Bogdanovic at that time was the outgoing minister.

7 Q. All right. And Stanisic was the head of the DB; right?

8 A. Well, I don't know whether he was the head of the DB, but from the

9 month of April, he told me that he was the head of the DB, the state

10 security. I heard this in April.

11 Q. All right. So he told you that. So once again that is another

12 lie. Jovica Stanisic was not head of the DB, either in 1990 or in 1991,

13 when you're talking about this meeting. I didn't even know him in 1991.

14 Nor could he have been there at that particular time on any assignment

15 whatsoever. You could have said that I was in Croatia at the time,

16 because I was holidaying in Dubrovnik, or rather, Kupari. And yes, I was.

17 I was there.

18 A. He was the head, and he talked to me about his personal conflict

19 with Janackovic, and that was in March. He had these clashes with

20 Janackovic, who was his boss. He had an office right next to Janackovic

21 in the old building of the MUP of Serbia in Knez Milos Street, and he told

22 me about his clashes with Janackovic. After that, Janackovic left, and he

23 was the head. Whether his title was "head" or "chief" or whatever it was,

24 I don't know.

25 Q. Oh, I see. So you say he had an office in the MUP building of

Page 13504

1 Serbia; is that right?

2 A. The MUP of Serbia had a new building in Knez Milos Street, and his

3 office where he received me was in the old building. Now, whether it was

4 the MUP building, but it was an old building right next door to the new

5 MUP building of Serbia.

6 JUDGE MAY: One at a time.

7 MR. MILOSEVIC: [Interpretation]

8 Q. All right. Very well. I heard in part of your testimony that he

9 had an office in my office or, rather, in the building of the Serbian

10 state Presidency, and now I hear he has an office in the MUP of Serbia,

11 and this is quite a large evolution in comparison to your previous

12 statement.

13 A. In September 1991, his seat was in his office next to Goran

14 Milinovic, I think the man's name was, your man, your chef de cabinet, and

15 he personally showed me, before I arrived at my meeting with you, the

16 reporting room. It was a semi-oval room with a table in it. It had a

17 stand for a map, and the room was empty. And that was in September 1991.

18 And I met him in your office there in the autumn of 1991 and once more, I

19 think. I said that he was in your office in March with Bogdanovic. I met

20 him there once again in September 1994. I met him in your offices. You

21 had invited him to come in April 1995.

22 Q. All right. When I ask you that, you can tell me your answers.

23 Very well, Mr. Croatia-061.

24 A. And he had an office later on --

25 JUDGE MAY: Witness C-061, let the accused finish his question and

Page 13505

1 don't interrupt. He should not interrupt you.

2 THE WITNESS: [Interpretation] I apologise, Your Honour. He

3 interrupted me.

4 MR. MILOSEVIC: [Interpretation]

5 Q. All right. Let's put it that way. I interrupted you. That's

6 just as exact as what you were saying beforehand.

7 JUDGE MAY: Don't comment either.

8 THE ACCUSED: [Interpretation] All right. Very well.

9 MR. MILOSEVIC: [Interpretation]

10 Q. Now, you were mentioning a moment ago that there was some parallel

11 military units set up by them and led by them, and my question to you is

12 the following: Are you aware, do you know that as far as Serbia is

13 concerned - now I'm being quite specific here, Serbia - as far as Serbia

14 is concerned, paramilitary units were only set up by opposition parties?

15 Do you know that? Are you aware of that, Mr. C-061?

16 A. I am aware of the fact that Serbia or, rather, you, via Jovica

17 Stanisic, Radmilo Bogdanovic, and Franko Simatovic nicknamed Frenki,

18 formed volunteer units, detachments, in the SAO Krajina starting with

19 April 1991, and I know that you instructed and linked up the Secretariat

20 of the Interior or, rather, the police stations on the territory of SAO

21 Krajina, and also that you, through them, set up special units, the ones

22 that the Assembly of Krajina, on the 29th of May, 1991, called the Krajina

23 Milicija, militia.

24 Q. So the formation of your Krajina police force you considered to be

25 the formation of a paramilitary formation.

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Page 13507

1 A. It was a paramilitary formation because it was not under the

2 control of the government.

3 Q. How can the police SAO Krajina not be under the control of the

4 government?

5 A. Well, in the way I explained. It had the right of might and was

6 not subjected to a government that did not have sufficient might.

7 Q. All right. And what about the Minister of the Interior? Was he

8 at the head of that police force?

9 A. I explained how he came to be the Minister of the Interior.

10 Q. Well, you explained that he was nominated and appointed by the

11 Assembly. That's what you said.

12 A. In such a way that this was done by force, because he didn't wish

13 to hand over his authority which the DB of Serbia and he himself had set

14 up, the structure he had set up.

15 Q. Is it a fact that Milan Martic was appointed by the Assembly of

16 Krajina to the post of Minister of the Interior? Is that a fact?

17 A. I said that he even took an oath of office, but he didn't want

18 to. I apologise. He was appointed Minister of Defence, but he didn't

19 want to hand over the Ministry of the Interior, and he took over this

20 position by force.

21 Q. The Assembly decided that he should hold both posts?

22 A. In formal and legal terms, the Assembly did grant him both posts

23 because he demanded that and took it by force, and did he not hand over

24 the other office to the Minister of Defence who was supposed to take

25 charge of the special militia.

Page 13508

1 Q. Was any information ever published about this or was anybody

2 informed of the fact that this decision by the Assembly of the Krajina on

3 the appointment of Martic came about by force and that he did this by

4 force?

5 A. It's the people who took part in all this who know that.

6 Q. You are explaining your quarrels to us as if they are political

7 events. What do I care about your quarrels?

8 A. These were not quarrels. This was the way you controlled and

9 influenced events in the Krajina. You took over the armed forces in the

10 Krajina through the DB and through Martic.

11 Q. Since I took over under power in the Krajina, what were you doing

12 there?

13 A. Fighting for the Krajina in -- by political means and taking part

14 in those armed formations that were defending the Krajina.

15 Q. Well, let's go back to the paramilitary units. You say that what

16 became the Krajina police was in fact a paramilitary formation. Do you

17 know anything about paramilitary formations? Who set them up? Did the

18 parties you cooperated with, and that was the entire opposition in Serbia,

19 was it they who set up the paramilitary units in Krajina?

20 A. As far as I'm concerned, I started cooperating with the opposition

21 in Serbia in 1993. In 1991, up to March, we supported you and your

22 policy, and we did this publicly.

23 THE INTERPRETER: Microphone, please.

24 MR. MILOSEVIC: [Interpretation]

25 Q. Would you please take a look at page SA035981, which you handed

Page 13509

1 over as an exhibit. When I say "you," I'm referring to the OTP. I don't

2 know whether you personally gave it to them since you also belonged to the

3 other side.

4 JUDGE MAY: Now, that's a quite unnecessary comment.

5 Can you identify, so that we can have it for the record, what this

6 is and we'll find the number.

7 THE ACCUSED: [Interpretation] I want to read what it says here, as

8 Ratko Mladic, the Commander of the Knin Corps, is sending his daily combat

9 report to the commander of the 2nd Military District in Zagreb.

10 JUDGE MAY: What is the date of this document and the author?

11 THE ACCUSED: [Interpretation] The date is the 8th of April, 1992,

12 and it says:

13 "In the town of Knin and in the units, leaflets have turned up -"

14 I'm reading slowing - "calling on citizens to attend the ceremonial

15 launching of the brigade of the Serbian army in the village of Kosovo.

16 Another brigade will be established in Lika, and the organisers forming

17 these forces are," and then these are listed. And this was scheduled to

18 take place at a certain time in 1992.

19 And then it says: "The corps command, with the Main Staff of the

20 Territorial Defence and the police of the Republika Srpska Krajina, have

21 taken appropriate measures to suppress these intentions."

22 So they have taken measures to thwart this.

23 JUDGE MAY: I'm going to stop you. It's important that everybody

24 else at a least has a copy of what you're reading from. Is this an

25 exhibit?

Page 13510

1 Can you help, Ms. Uertz-Retzlaff, as to what this is?

2 MS. UERTZ-RETZLAFF: I do not think that this is an exhibit, and

3 we are trying to find the document with the help of the number given, but

4 at the moment we are not yet successful. We don't know what it is at the

5 moment.

6 JUDGE MAY: Mr. Milosevic, was this one of the documents which

7 were exhibited by the Prosecution or not?

8 THE ACCUSED: No, Mr. May. This is disclosure Rule 68, 31

9 October.

10 JUDGE MAY: Very well. Very well. We'll try and track it down.

11 Witness C-061, can you follow what's being put?

12 THE WITNESS: [Interpretation] I can assume what this refers to.

13 If it refers to April 1992, I can assume what this is about. Is the date

14 correct, April 1992?

15 JUDGE MAY: 8th of April, 1992.

16 Yes, Mr. Milosevic. Finish your question which I interrupted.

17 THE INTERPRETER: Microphone, please.

18 MR. MILOSEVIC: [Interpretation]

19 Q. Can you comment on the fact that obviously the corps command and

20 the Territorial Defence Staff and the police of the Krajina are taking

21 appropriate steps to thwart these intentions of forming wildcat renegade

22 brigade? And as you can see in this text, because I can't say your name,

23 C-061, you yourself were the organiser of this. And Mladic responded, and

24 the police responded in order to prevent this -- this running wild in the

25 Krajina. Here it is. This was sent to the corps command and yet you are

Page 13511

1 talking of paramilitary formations.

2 JUDGE MAY: Let the witness answer. Yes, you can comment on

3 that.

4 THE WITNESS: [Interpretation] Yes, I can. The question was put in

5 the context of cooperation with the opposition in Serbia, but now I also

6 see that it comes within the context of paramilitary structures. The

7 events that took place in April 1992 on Dalmatinsko Kosovo near Knin was

8 the formation of the so-called Serbian army when the Petar Mrkonjic unit

9 was established.

10 MR. MILOSEVIC: [Interpretation]

11 Q. Allow me one question about this. You organised this Petar

12 Mrkonjic Brigade, didn't you?

13 A. No. If you mean personally, no, I didn't.

14 Q. I mean you personally organised it.

15 A. No.

16 Q. You say you didn't. I will prove that you did. And secondly, is

17 it correct that this brigade consisted entirely of criminals recruited by

18 you?

19 A. Please may I answer?

20 JUDGE MAY: Yes, answer. You've already said that you weren't the

21 organiser, so you needn't answer that, but you can give an explanation, if

22 you wish.

23 THE WITNESS: [Interpretation] This brigade was organised by part

24 of the Regional Board of the SDS headed by Ljubica Solaja and Cubrilo. I

25 personally attended that gathering and gave my support, for political

Page 13512

1 reasons. In my estimation, this was a political demonstration and a

2 protest against the demilitarisation of the Krajina. I can explain my

3 personal and political reasons to the Court, if necessary, for doing this,

4 but in closed session.

5 JUDGE MAY: Of course. You can just help us, though, as to what

6 this brigade was. It's been alleged that it was a brigade of criminals.

7 What was it?

8 THE WITNESS: [Interpretation] This was a political protest against

9 the demilitarisation of the Krajina.

10 THE ACCUSED: [Interpretation] Mr. May, the witness said that he

11 could explain this but that he had to do so in closed session. I agree.

12 Let us go into closed session for a minute, because I would really like to

13 hear his explanation.

14 JUDGE MAY: Very well. Yes.

15 THE ACCUSED: [Interpretation] I'd like to hear his explanation.

16 [Private session]

17 [redacted]

18 [redacted]

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8 [redacted]

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

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

11 [redacted]

12 [redacted]

13 [redacted]

14 [redacted]

15 [Open session]

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

17 MR. MILOSEVIC: [Interpretation]

18 Q. Let us clear up this business around Franko Simatovic, as you are

19 accusing him of participating in the so-called parallel structure. Do you

20 know what his position was in the State Security Service of Serbia?

21 A. First of all, I'm not accusing anyone. I'm just saying what I

22 know. Secondly, I know that Franko Simatovic was subordinated to Jovica

23 Stanisic and that you advocated, requested, demanded that he be in

24 Krajina. You said that he was a good guy.

25 Q. Will you please answer my question. What was his position in the

Page 13525

1 State Security Service of Serbia?

2 A. He was subordinated to Jovica Stanisic.

3 Q. Very well. Do you know that he was head of the Intelligence

4 Administration?

5 A. On one occasion before the events in August 1991, you mentioned a

6 man from the administration. I don't remember which number you used. You

7 used a number, the second or third administration, and you said that there

8 were certain criticisms about an individual as to why he was heading that

9 service whereas he was a Croat by ethnicity. And then you said his father

10 was a partisan and that he had chased the Ustashas and that he was a good

11 guy.

12 At the time, I didn't know who you were talking about. Later on,

13 I learnt that you meant Franko Simatovic, who was a Croat.

14 Q. Very well. Now you've added another fact. Do you consider that

15 someone who is by ethnicity a Croat had ill-intentions towards the Croats,

16 the Croatian people to which he himself belonged?

17 A. What are you asking me?

18 Q. I'm asking you whether you believe, since you yourself have said

19 that he has said that he's a Croat --

20 JUDGE MAY: Mr. Milosevic, it's not a proper question, that. It's

21 a pure comment. The witness can give evidence about facts as he knows

22 them, and he's given the evidence about this man. That's purely a comment

23 that you're making.

24 THE ACCUSED: [Interpretation] Very well.

25 MR. MILOSEVIC: [Interpretation]

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Page 13527

1 Q. I asked: Do you know whether Franko Simatovic was head of the

2 Intelligence Administration?

3 A. I don't know what he was head of. I know he was subordinated to

4 Jovica Stanisic and to you.

5 Q. That he was subordinated to Jovica Stanisic goes without saying,

6 as he worked in the state security service. And from the time that

7 Stanisic became head of the state security, he was certainly subordinated

8 to him. But I asked you whether you knew that he was head of the

9 Intelligence Administration, which means that he collected intelligence.

10 A. I said what I know.

11 Q. Very well. You said that from the DB of Serbia certain parallel

12 structures had been formed, and you listed all people from Krajina, not

13 from the DB of Serbia; Martic, Vitas, Orlovic, Nebojsa, Martinovic or

14 whatever, and so on. And since you are claiming that the DB of Serbia was

15 omnipresent there, tell me, throughout that five-year period, can you list

16 people, ten names from the DB of Serbia who may have come to Krajina even

17 for ten minutes throughout that five-year period? Can you give us those

18 names?

19 A. Just now I can remember Jovica Stanisic, Franko Simatovic, Fica,

20 Captain Dragan.

21 Q. Excuse me. What has Captain Dragan got to do with it?

22 JUDGE MAY: Let the witness -- let the witness finish what he's

23 saying, then you can ask the questions.

24 Now, are there any other names that you want to add,

25 Witness C-061, to those names?

Page 13528

1 THE WITNESS: [Interpretation] Marko, I think, from later years.

2 Just now I can't think of any other names.

3 MR. MILOSEVIC: [Interpretation]

4 Q. I see. So you've listed four names of which Jovica Stanisic was

5 based in Belgrade.

6 A. I've said about Jovica Stanisic, who told me that Captain Dragan

7 was in their service in August 1991, and he even mentioned some money.

8 Q. He couldn't have told you that, because Captain Dragan was never

9 in the state security service.

10 A. Please. I ask the Court to be allowed to answer the question.

11 Q. Who is preventing you?

12 A. Jovica Stanisic told me that in August 1991 in the Seher

13 restaurant in Belgrade.

14 Q. Very well. That's what you say. You say he told you.

15 A. Well, his wife was there too, and she was born in the environs of

16 Knin.

17 Q. All right. Fine. That's great. You were at a private lunch with

18 Jovica Stanisic and his wife.

19 A. He invited me to explain to me that Captain Dragan was a very

20 strong-headed man and that they found it difficult to control him.

21 Hot-headed.

22 Q. Well, how could they have trouble in bringing to heel somebody who

23 belonged to their own service?

24 A. Well, they wanted to divert attention from Frenki. I asked you to

25 withdraw Frenki from this structure, and they wanted a public debate with

Page 13529

1 Captain Dragan and people from the Krajina, as if this were a political

2 conflict, to make it appear as if Captain Dragan was a political personage

3 and not a member of the DB of Serbia.

4 Q. Well, you know whether he was a political figure or not, but you

5 do know that he wasn't a member of the DB of Serbia.

6 A. I know he was in the service of the DB of Serbia.

7 Q. Neither was he in the service of the DB of Serbia, but let's leave

8 that alone and let's move on.

9 You were shown here a solution or, rather, a judgement by the

10 court in Sibenik where an investigation was launched, and you stated your

11 views about that. I think that was in open session. I think it was the

12 judgement of the court in Sibenik that we were talking about. And the

13 number of that document was 01397042.

14 JUDGE MAY: Have we got that document?

15 THE ACCUSED: [Interpretation] Have you got the document. Right.

16 MR. MILOSEVIC: [Interpretation]

17 Q. You said, as far as I was able to jot down --

18 MS. UERTZ-RETZLAFF: I just want to clarify whether it is the

19 court in Split or Sibenik, and we would have to go into private session if

20 that is the judgement referring to the leadership of the Republika -- the

21 leadership of the RSK, because that was discussed in private session.

22 JUDGE MAY: Sibenik was referred to.

23 MR. TAPUSKOVIC: [Interpretation] May I assist the Court, Your

24 Honours?

25 JUDGE MAY: Yes.

Page 13530

1 MR. TAPUSKOVIC: [Interpretation] It is the arrest warrant for

2 Milan Martic and the document that attends it.

3 JUDGE MAY: Have we got the document?

4 MS. UERTZ-RETZLAFF: Yes, Your Honour. It's Exhibit 352,

5 tab 111B, and it was discussed in open session.

6 JUDGE MAY: Yes. Thank you.

7 THE ACCUSED: [Interpretation] So it was in open session, I

8 gather.

9 MR. MILOSEVIC: [Interpretation]

10 Q. Now, have you read the document in detail?

11 A. If I remember correctly, if that is the document that I'm thinking

12 of, there are two parts to the document. One part relates to crimes and

13 the second to political crimes, if that is the document I'm thinking of.

14 JUDGE MAY: Let the witness just have a look at the document.

15 THE WITNESS: [Interpretation] This is a decision made by the

16 District Court in Sibenik, and the decision is to launch an investigation,

17 and it is indeed in two parts in the explanations given. The first part

18 relates to the person in question, and the second statement are reasons,

19 and under number 1 it enumerates crimes, and under 2 it is for political

20 crimes.

21 THE INTERPRETER: Microphone, please, for Mr. Milosevic.

22 THE ACCUSED: [Interpretation] Is this a public session, an open

23 session? Are we in open session?

24 JUDGE MAY: Yes.

25 THE ACCUSED: [Interpretation] Very well.

Page 13531

1 MR. MILOSEVIC: [Interpretation]

2 Q. So this decision was discussed in open session. Do you recall

3 that in your examination-in-chief you stated, when you were shown this

4 decision, this decree, that the facts were correct? That's what you

5 stated.

6 A. Under what is listed in point 1 and point 2.

7 Q. All right. Very well. So let's look at point 1. It says the

8 following, that from October to the present day, having formed an

9 association of the so-called Council of People's Resistance... From

10 October 1990 until today. So that is the Council of People's Resistance,

11 or National Resistance. And you said that the facts contained therein

12 were correct. Now, if the facts are indeed correct - and according to

13 what you say, they are - then it is also true that the person under number

14 1 here, listed under number 1, was accused, and an investigation was

15 launched against him. Is that correct, Mr. C-061?

16 A. I said who the members of the Council of National Resistance were,

17 and when questioned before this Tribunal, in my testimony, and over the

18 past few days I spoke about the facts that I am aware of, stemming from

19 this decision: the mining of the kiosk, and so on.

20 Q. Please, I'm asking you the following: You gave a very brief

21 answer during the examination-in-chief. When you were shown and presented

22 with these facts and this decision, you said that the facts were correct.

23 Now, the fact stands here that the Council of People's Resistance, as it

24 says here, and as you can see, you are considered responsible. Is that

25 right or is it not?

Page 13532

1 JUDGE MAY: We'll go into private session.

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25 [Open session]

Page 13536

1 THE REGISTRAR: We're in open session, Your Honours.

2 THE INTERPRETER: Microphone for Mr. Milosevic, please.

3 MR. MILOSEVIC: [Interpretation]

4 Q. Mr. C-061, what parallel structure are you talking about then?

5 A. A structure which was not under the control of the government and

6 the Assembly of the SAO Krajina.

7 Q. Well, I see here that this is precisely, this document that I

8 showed you, is precisely evidence of the opposite, proof of the opposite,

9 that you had that control and not Jovica Stanisic or Franko Simatovic,

10 that it was you yourself.

11 A. This was a document that was in keeping with the provisions of SAO

12 Krajina and its regulations.

13 Q. Well, I'm not challenging that. I'm saying that in keeping with

14 the rules and regulations, you functioned to the full possible extent and

15 not that the parallel structure was in operation.

16 A. This was outside the line of parallel structure. This was along

17 the lines of, first, a political decision to establish the Territorial

18 Defence for SAO Krajina as an independent armed formation under the

19 control of the organs of the SAO Krajina and one which would, in combat,

20 function on the basis of the laws of Yugoslavia and the principles of a

21 total national defence, or, rather, which would, should a war break out,

22 be placed under the command of the competent structures within the JNA and

23 the Yugoslav state Presidency during combat, in fighting. And it was be

24 on the basis of the laws that would be applied as of the 1st of October.

25 The political concept was that this structure should be the

Page 13537

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Page 13538

1 exclusive control of the autonomous -- the autonomous control of the legal

2 organs of the SAO Krajina.

3 THE INTERPRETER: Microphone, please.

4 JUDGE MAY: There's a point being made.

5 MS. UERTZ-RETZLAFF: Yes, Your Honour. It's a technical point --

6 THE INTERPRETER: Microphone for Ms. Uertz-Retzlaff.

7 MS. UERTZ-RETZLAFF: We have just found that it is already in

8 evidence, and it is Exhibit 352, tab 118.

9 JUDGE MAY: Thank you. Remove the earlier number. Yes.

10 MR. MILOSEVIC: [Interpretation]

11 Q. All right. Let's go back for a moment to the map that you started

12 off with and its background, because there are a lot of facts on it. I

13 should just like you to comment briefly.

14 Now, the introductory text that we received from you as to how the

15 Republic of Srpska Krajina came into being, and according to this

16 photocopy that I have here, it is on page 01132357. And it says here:

17 "With the evermore aggressive Croatian chauvinism, the Serb

18 people, in 1989, responded with the formation of the Serbian Cultural and

19 Arts Society, named Zora, in Kistanje, and rallying ranks around national

20 symbols and myths."

21 Is that correct? Just answer yes or no.

22 JUDGE MAY: Let's see if the witness has got the passage first.

23 Have you got it, Witness C-061?

24 THE WITNESS: [Interpretation] I do now.

25 JUDGE MAY: Page 9.

Page 13539

1 THE WITNESS: [Interpretation] It's correct that the Serbian

2 Cultural Society --

3 MR. MILOSEVIC: [Interpretation]

4 Q. Please answer with yes or no, because there's no time for you to

5 explain everything. I've read your quotation. Just tell me whether it's

6 correct or not.

7 A. Conditionally speaking, because I don't know what the word

8 "Croatian chauvinism" means here in this context. We used the word

9 "Croatian nationalism" and "ethnocentrism." What the author wanted to

10 say here, I don't know. The rest is correct.

11 Q. Very well. Now, please comment on the following passage where it

12 says:

13 "The Croatian communist government, which together with the

14 clerical nationalists sought for a way in which to trick the Serbs,

15 responded with arrests."

16 Is this correct? In 1989, you created the Serbian Cultural

17 Society Zora in Kistanje, and the government responded with arrests. Is

18 that correct or not?

19 A. The arrests came about not because the Zora Society was

20 established but because of the incidents that occurred at the celebration

21 of the anniversary of the Battle of Kosovo near Knin when Zoran Jovan

22 Opacic, the president of the Zora association, was arrested and a number

23 other participants were detained.

24 Q. That was in June 1989; is that correct?

25 A. Yes, when your pictures first appeared in Knin.

Page 13540

1 Q. And then they say:

2 "However, the nucleus around which the Serbian people will

3 articulate their political platform was offered by the Serbian Democratic

4 Party which was founded on the 17th of February, 1990, and Jovan Raskovic

5 was elected its president."

6 Is this correct?

7 A. Yes, it is.

8 Q. Then it says that: "This party was transformed into a movement of

9 the Serbs, especially after the HDZ won the elections in Croatia in 1990,

10 and their first step was the formation of paramilitary formations and

11 illegal arming, and their platform was founded on secession and threats

12 against the Serbian people." Is this correct or not?

13 A. Well, I don't know whether it was the first or the second step,

14 the one that refers to the establishment of the paramilitary formations

15 and illegal arming by the Croatian government, but the police formations

16 and the increase in the number of policemen carried out by the Croatian

17 government was understood by the Serbs as being paramilitary formations,

18 and it was so understood by the JNA as well. And there were associations

19 of citizens belonging to the HDZ. And this was spoken of at the time.

20 Q. And what was the National Guard Corps? Was that the police?

21 A. As far as I know, this was a police formation, but it was set up

22 like an army. In other words, on organisational terms, it was a military

23 formation but by its position it was part of the Ministry of the Interior

24 of Croatia.

25 Q. Well, then, tell me -- see what it says here:

Page 13541

1 "Immediately after taking power, Franjo Tudjman and the clerical

2 nationalists started introducing the symbols and signs of the Independent

3 State of Croatia from World War II, opening up old wounds and inciting

4 fear, often Ustasha genocide."

5 A. The second sentence, "Franjo Tudjman and the clerical

6 nationalists, immediately after taking over power, started with a

7 party-of-right programme," this is exaggerated.

8 Q. When was the HDZ established?

9 A. The HDZ was established in late 1989, and it was legalised a year

10 later. Yes, in 1989.

11 Q. Did you read the platform of the HDZ?

12 A. I heard what it was. I also listened to Franjo Tudjman speaking

13 on Zagreb television during the pre-election campaign, explaining the

14 party platform.

15 Q. And did you read then in the party platform that there was a

16 historical chance of establishing an independent state?

17 A. I listened to Franjo Tudjman on television saying that Croatia had

18 an irregular geographical shape. It was boomerang shaped, and that it

19 should be shaped by drawing a line along the River Drina. And he showed

20 this on a map. So his conception was that Croatia should consist of the

21 then-Republic of Croatia and the then-Socialist Republic Bosnia and

22 Herzegovina.

23 Q. So this was the territory that used to be the Independent State of

24 Croatia during World War II.

25 A. As far as I know about history and the tales of people who were

Page 13542

1 alive at the time, this was the territory covered by the Independent State

2 of Croatia which also covered Srem, but the NDH did not cover a long part

3 of the Primorje region which, when Yugoslavia was divided up by the

4 fascist powers, belonged to Italy.

5 Q. I'm speaking of the second part. Tell me, then, is it correct

6 that what it says here further on, the Serbian Assembly in Srb, on the

7 25th of July, 1990, issued a declaration on the autonomy of the Serbs in

8 Croatia and a plebiscite of the Serbian people starting from the Avnoj

9 decisions and the rights of nations and peoples to self-determination

10 without denying this right to others. Is this correct?

11 A. Yes, it is.

12 Q. Then it says:

13 "The attempt by the Croatian police to hinder the plebiscite by

14 force, to stop it, and the events of the 17th of August, 1990, marked the

15 beginning of the armed struggle of the Serbs for survival on their ethnic

16 and historical territories."

17 Is this correct?

18 A. Yes, it's correct.

19 THE INTERPRETER: Would the speakers please slow down for the

20 interpreters.

21 MR. MILOSEVIC: [Interpretation]

22 Q. But --

23 JUDGE MAY: You're both being asked to slow down for the

24 interpreters.

25 THE WITNESS: [Interpretation] I haven't finished. Could you

Page 13543

1 please allow me to finish.

2 On the 17th of August, the resistance to the attempts to prevent

3 the referendum began, and later on during October 1991, this grew into --

4 into the causing of incidents by the Serbs in Croatia.

5 MR. MILOSEVIC: [Interpretation]

6 Q. This referendum, what I read to you, was this initiated by someone

7 from Serbia or was it a spontaneous reaction by you in the Krajina?

8 A. As far as I know, Serbia got involved in these events in such a

9 way as to help the Serbs to organise a plebiscite. Serbia helped to

10 define correctly the question that was to be put at the referendum in

11 order for it to be within a legal framework. Serbia guaranteed with the

12 JNA that the plebiscite, as we called it, or the vote, would actually be

13 carried out.

14 Serbia later got involved in these events in order to use them for

15 its own purposes. This political conflict was used by Serbia, which got

16 involved by setting up a parallel structure and causing incidents with a

17 view to getting the JNA involved and the federal state to intervene in

18 order to introduce a state of emergency and suspend the Croatian

19 government.

20 Q. These are your assumptions.

21 A. May I be allowed to reply?

22 Q. These are your assumptions as to what happened and what the

23 responses were. Was the initiative -- did it come from Serbia or was it a

24 logical reaction to the pressures and the repression to which the Serbs

25 were exposed from the very beginning? Is this correct or not?

Page 13544

1 A. What I said was not my assumption. These are facts for which I

2 have personal knowledge and which I heard from the academician

3 Mr. Raskovic. There are minutes from a session where he said that these

4 clashes -- and he was speaking on the 10th of September in Srb in the

5 evening, and he said there was a third party who wanted conflicts to break

6 out in Croatia, that there were those in Yugoslavia who are bloodthirsty

7 and who want to make use of the clash between the Serbs and the Croats in

8 Croatia to introduce a state of emergency. These are facts, not my

9 assumptions.

10 Q. Who was he referring to, since you are putting forward these

11 facts? Who in Yugoslavia was able to introduce a state of emergency in

12 Croatia, and who was it who was bloodthirsty?

13 A. Legally, it could be done by the Presidency of Yugoslavia, or it

14 could be done by the JNA illegally.

15 Q. Did Raskovic criticise the JNA?

16 A. He said, literally, that it was a third party who wanted a

17 conflict, not the Serbs and the Croats in Croatia. But I quote what he

18 said: In Yugoslavia there are those who are bloodthirsty and who want to

19 make use of this conflict to have a state of emergency introduced on that

20 territory. And everybody knows who was able to introduce a state of

21 emergency.

22 Q. You said that Raskovic criticised the army as being impotent.

23 A. Raskovic criticised you, and in February 1992, he said that the

24 army was weak. In February, after the Spegelj affair, when the army did

25 not arrest Spegelj nor introduce a state of emergency in Croatia, he

Page 13545

1 doubted that the army was able to do this. The army did this in a way

2 later organised by you, starting on the 1st of March, 1991, and onwards;

3 as far as I know, from April and May 1991 onwards.

4 Q. What was it that I organised from April and May 1991?

5 A. You organised a parallel structure in the Krajina to cause

6 incidents, and then you deployed the army on the confrontation line, in

7 May 1991.

8 [redacted]

9 [redacted]

10 [redacted]

11 MR. MILOSEVIC: [Interpretation]

12 Q. -- what is on the map, when the Croatian parliament, the 25th of

13 December, 1990, in brackets, proclaimed Croatia the national state of the

14 Croats and declared the Serbs to be a national minority.

15 A. I brought this in order -- this map in order to show what the

16 factual situation was and to show the participation of the JNA and the

17 results of the war in the Krajina because of this. And I can comment on

18 what the author here said; the cup runneth over and all of that, this is a

19 literary way of expressing oneself. The rest is correct. In the

20 constitution of 1990, Croatia excluded the Serbs as a constituent nation

21 in the Republic of Croatia. That is correct.

22 Q. Well, let us go back to the position of the Croats. You said that

23 the government of the Krajina would never do to the Croats what the

24 Ustasha government had done to the Serbs, and that the Croats were safe on

25 the territory of the Krajina. And you even complained that the Croatian

Page 13546

1 government was offering luxury hotels, Solaris near Sibenik, and Medena

2 near Trogir, to accommodate citizens from those areas in order to get them

3 away from the territory of the Krajina, and that this was a sly move --

4 JUDGE MAY: If we're to follow these questions, we need to know

5 what you're referring to, and I take it you're referring to the witness's

6 evidence. If so, you should put the matter shortly to him so he can

7 follow it.

8 Have you followed this, Witness C-061, what the accused has put to

9 you?

10 Start again, Mr. Milosevic. What's the question?

11 MR. MILOSEVIC: [Interpretation]

12 Q. Mr. C-061, is it true that you all said to us in Belgrade that

13 there was nothing for us to worry about because no one would touch a

14 single Croat over there, that the Croats were equal in the Krajina, and

15 that you had no intention of doing what the Ustasha government was doing

16 to the Serbs outside of Krajina? Is that what you all said?

17 A. As far as I can remember, you were asked to say how you intended

18 to protect the Serbs, that is, to carry out your promise that they would

19 be protected by the JNA. As far as I know, that's what the discussions

20 with you were about.

21 JUDGE MAY: No. Witness, listen to the question. What is said is

22 that you and others were saying they were not to worry, Croats were equal

23 in the Krajina, there was no intention of doing what the Ustasha

24 government was doing to the Serbs. Was that ever said?

25 THE WITNESS: [Interpretation] Yes, things to that effect were

Page 13547

1 said. What events exactly were referred to, I don't know, but if it would

2 be put to me, I would comment on it, in early 1991. I have to say that

3 the rhetoric, especially public rhetoric, escalated starting from 1990 and

4 early 1991, after the Spegelj affair, after the outbreak of armed clashes,

5 especially after the outbreak of war operations in the autumn of 1991.

6 The mutual rhetoric, both Serbian and Croatian, escalated, so that in the

7 1990s, from the Serb side and the Serb Krajina side, the Croatian

8 government and Tudjman and all their supporters were called Ustasha; and

9 on the other hand, the Croatian authorities referred to the JNA as a

10 Serbo-Chetnik army. So there was an escalation of rhetoric from 1990 to

11 the autumn of 1991.

12 MR. MILOSEVIC: [Interpretation]

13 Q. Very well, then. Do you remember that when we asked you

14 questions, saying: If that is so - and we are glad to hear that you are

15 making sure that nobody should be in jeopardy - why are Croatian families

16 moving out of Krajina? And you answered: Tudjman is offering them luxury

17 hotels: Solaris, near Sibenik, on the coast; Medena, near Trogir. These

18 are large hotels. I personally visited them in the old days. And this is

19 attractive to them, so they wish to give the impression that we are doing

20 something against them, and that is not true.

21 Is that true, that that was how you answered our questions?

22 JUDGE MAY: We'll go into private session.

23 [Private session]

24 [redacted]

25 [redacted]

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7 [Open session]

8 THE ACCUSED: [Interpretation] I don't see a single reason,

9 Mr. May. You asked for us to go into private session.

10 THE REGISTRAR: We're in open session.

11 MR. MILOSEVIC: [Interpretation]

12 Q. Is it clear that in 1991 the JNA was legally present within the

13 territory of SFRY, regardless which territories in Croatia we're talking

14 about, not only the territories that are on the map marked as territories

15 of the Republic of Serbian Krajina, but in many cities throughout Croatia,

16 where it had been for 50 years? Is that right or not?

17 A. What is the question: whether the JNA was the legal army of SFRY?

18 Q. Yes. Throughout the territory of Croatia, not just Krajina. I'm

19 talking about its legal presence throughout the territory of Croatia.

20 A. Well, my God. The JNA was the armed forces of SFRY, of course.

21 Q. Fine.

22 A. Only it performed illegal acts as of August 1991.

23 Q. As to what is legal and illegal, let's leave that for later.

24 But you say that in autumn 1991, you wanted to negotiate with the

25 Croatian side, but no talks occurred because of your personal weaknesses.

Page 13553

1 Is that right?

2 A. I don't understand the question.

3 Q. You said -- you gave explanations that you wanted to talk.

4 A. When?

5 Q. In the autumn of 1991, with the Croatian side. Is that right?

6 You spoke about that here in this courtroom.

7 A. Yes, there was an opportunity through the international conference

8 to establish a dialogue with Croatia and resolve the issue. That's what I

9 did say. It was a good chance, but unfortunately, it was a missed

10 opportunity, and I was one of those who made errors and omissions not to

11 take advantage of that opportunity. It was a good opportunity.

12 Q. Yes. You could have answered simply with a yes without going into

13 all those explanations.

14 You said that you had proposed that Krajina should be a Zupanja in

15 Croatia.

16 A. In 1990, during the discussions on the new constitution of the

17 Republic of Croatia.

18 Q. And is it true that up to the formation of the Serbian Democratic

19 Party in Glina and when you became one of the top leaders, you were an

20 official of the League of Communists of Croatia? Is that right?

21 A. I was in the League of Communists of Croatia, and I held certain

22 positions which I have already mentioned here in this Tribunal at the

23 beginning of my testimony.

24 Q. Will you please answer with a yes or no so that we can save time.

25 You've already said yes with a rather lengthy, complex sentence. So --

Page 13554

1 A. In substance, no, because when you say "official," that means

2 somebody with executive powers in the body of the League of Communists,

3 starting from the Municipal Committee through the Regional Committees, the

4 Central Committee, et cetera, et cetera. So when you say an official, you

5 mean someone with executive powers in the structure of the League of

6 Communists. So my answer is no, or exactly what I said in answering your

7 question for the first time.

8 Q. Are you claiming then that you were not in the Presidency of the

9 Municipal Committee of Glina?

10 A. No.

11 Q. Were you an official of the League of Communists of Yugoslavia

12 and, as such, a delegate at the congress of the League of Communists of

13 Croatia?

14 JUDGE MAY: We'll deal with this in private session.

15 [Private session]

16 [redacted]

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19 [Open session]

20 THE REGISTRAR: We're in open session, Your Honours.

21 MR. MILOSEVIC: [Interpretation]

22 Q. You started explaining something to do with the president of the

23 SDS, Jovan Raskovic, which is incorrect, and therefore, I want to ask you

24 the following. I think I can do this in open session. I won't mention

25 your name.

Page 13563

1 Is it correct that you held it against Jovan Raskovic that he went

2 to Zagreb and had talks with Franjo Tudjman and other leaders in Croatia?

3 A. There were two members in the Main Board. Both were

4 vice-presidents of the party. One was the president of the Executive

5 Board. And they laid great emphasis on such things.

6 There was also a discussion at the Main Board of the party. Jovan

7 Opacic, Zelenbaba, Branko Peric, and several other people asked that Jovan

8 Raskovic be replaced, but they did not gain the support of the majority at

9 that session of the Main Board. Jovan Raskovic was not dismissed. These

10 people left the SDS after that session and went to the Serbian Renewal

11 Movement of Draskovic. They said that the SDS was the Serbian infantry,

12 that it was weak and inefficient and that they were crossing over to the

13 artillery, to the SBO.

14 Q. It seems to me that things were somewhat different from this. You

15 criticised Jovan Raskovic strongly because of some compromising statements

16 he made in his talks with Tudjman.

17 A. You probably mean other talks he had later on.

18 Q. I'm referring to your attacks on Jovan Raskovic. That's what I'm

19 referring to.

20 A. What attacks? By me or by people from the SDS?

21 Q. You personally.

22 A. If you mean me personally, we can discuss that.

23 Q. Is it correct that it was you, together with someone I will not

24 mention here by name because I would then be in danger of revealing your

25 identity, on his return from America, you not only dismissed him but

Page 13564

1 almost hounded him out of the Krajina, out of the SDS, out of all public

2 life; is that correct?

3 A. First of all, Jovan Raskovic did not live in the Krajina. He

4 lived in Sibenik. Secondly, Dobrica Cosic suggested that he go to

5 Belgrade for certain reasons. And thirdly, the HDZ in Sibenik organised

6 the signing of a petition against Raskovic, Marko Dobrijevic and Branko

7 Popovic. And fourthly, from late 1990, a so-called Krajina faction of the

8 SDS began to emerge within the SDS.

9 Jovan Raskovic was never dismissed. He died as the president of

10 the SDS in 1992.

11 Q. Is it correct that it is because of their disagreement with you in

12 the way that Jovan Raskovic was treated that these people, Opacic and

13 Zelenbaba, the people you mentioned who were co-founders of your party,

14 left the party and went over to the SBO? Is this correct?

15 A. At the moment they were leaving the SDS, I was very close with

16 President Raskovic. They were one faction, and then later on, a harder

17 faction, a pro-Milosevic faction which supported you was established

18 consisting of Marko Dobrijevic and Petar Stikavac who were its leaders,

19 and that's why Jovan Raskovic dismissed them in February 1991.

20 After that, a faction was set up consisting of the Regional Board

21 of the Krajina SDS and President Raskovic said that this was a faction

22 which was not eliminated but tolerated because we were a democratic

23 party. And several political options were allowed. President Raskovic

24 said that anyone who uses his own head thinks a little differently from

25 the next person.

Page 13565

1 Q. It seems to me that you mentioned here that I had something

2 against Raskovic, but now you explained that he left for quite different

3 reasons and under quite different circumstances. And now you're saying

4 that there were some SDS members who supported me at the elections. But

5 why did I need their support in Knin when I was running at the elections

6 in Serbia?

7 A. There are two things: Firstly, in February 1991, you said that

8 Jovan Raskovic should be dismissed. I told you personally he could not be

9 dismissed; he was a popular leader. Secondly, you were waging an election

10 campaign in Serbia in 1991 for the parliament, as the Socialist Party of

11 Serbia, and you yourself were running for president. You had a conflict

12 with the national opposition, and it certainly suited you to have the

13 support of a party defining itself as a democratic and a Serbian party.

14 This suited you politically, in order to gain support among the voters in

15 Serbia, you and your party.

16 Q. C-061, you said just a moment ago that in 1990 the reach of this

17 party went only as far as Knin and maybe several kilometres beyond Knin.

18 A. In early 1990, in the elections up to -- leading up to May, but

19 after that, the party founded its first committee in Belgrade and another

20 in Novi Sad. And just before the elections in Serbia, the independent SDS

21 of Serbia was established, which took part in the elections.

22 Q. Your party was in the opposition at the elections in Serbia.

23 A. Part of the party split away and established an independent SDS of

24 Serbia, taking part in the elections in Serbia, and part of the people and

25 the Main Board of the central SDS party in Knin supported you, and that is

Page 13566

1 a fact.

2 Q. Very well. They supported me probably in their thoughts, because,

3 as you know, we won those elections by a landslide.

4 A. The support was in the media. I don't know what media transmitted

5 this.

6 THE INTERPRETER: Microphone, please.

7 MR. MILOSEVIC: [Interpretation]

8 Q. Tell me, please, since you are denying that you drove Raskovic

9 out --

10 A. That was your campaign, your underhand campaign, to disqualify him

11 politically.

12 JUDGE MAY: This argument is of no assistance to us, in which you

13 both interrupt each other. It's impossible to follow.

14 Now, we're going to adjourn again for 20 minutes.

15 --- Recess taken at 12.15 p.m.

16 --- On resuming at 12.39 p.m.

17 JUDGE MAY: Yes. We'll sit now until 2.00, and I understand the

18 Prosecution may want a few moments at the end.

19 MR. NICE: Just a couple of minutes.

20 JUDGE MAY: Yes. Thank you.

21 Yes, Mr. Milosevic.

22 MR. MILOSEVIC: [Interpretation]

23 Q. To continue: It follows that Raskovic was not handed from Knin in

24 your struggles for political prestige but for other reasons; is that

25 right?

Page 13567

1 A. To the best of my knowledge, yes.

2 Q. Explain, then, whether you launched a campaign in 1995 to replace

3 the then Prime Minister, Borislav Mikelic.

4 A. In 1995, or rather, in 1994, with the replacement of

5 Mikelic -- actually, this was initiated by the president, the then

6 president of Srpska Krajina, and he was replaced in 1995, in June, I think

7 it was. Mikelic was the Prime Minister, and he had a minority in the

8 Assembly of the RSK.

9 Q. I didn't ask you about the dates. I have the dates here. What I

10 asked you was whether you were at the head of the campaign to have Mikelic

11 replaced, you and your party.

12 A. If by that you mean whether there was a political decision to that

13 effect, to have Borislav Mikelic replaced before there was a vote in the

14 Assembly, the answer is yes.

15 JUDGE MAY: No. That wasn't the question. The question was:

16 Were you at the head of a campaign? Now, it is a fairly straightforward

17 question, Witness C-061, so perhaps you could just answer it simply.

18 THE WITNESS: [Interpretation] Well, I can, if you tell me what is

19 meant by "campaign." What does the word "campaign" imply?

20 JUDGE MAY: Let's go into private session. It's a perfectly clear

21 word, what "campaign" means.

22 THE ACCUSED: [Interpretation] Please, just a moment in open

23 session before we go into private session.

24 THE INTERPRETER: [Interpretation] Microphone for the accused,

25 please.

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Page 13569

1 THE ACCUSED: [Interpretation] As you want us to go into private

2 session, I'd like to ask one more question in open session, before we go

3 to private session, so that we can clarify some circumstances with regard

4 to the answer I'm going to get to my next question.

5 MR. MILOSEVIC: [Interpretation]

6 Q. What I want you to explain is this, the circumstances

7 surrounding -- or rather[redacted]

8 [redacted]

9 [redacted]

10 [redacted]

11 A. It is not correct.

12 THE ACCUSED: [Interpretation] A private session, please.

13 JUDGE MAY: Yes, we'll go into private session now.

14 [Private session]

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17 [Open session]

18 THE REGISTRAR: We are in open session.

19 MR. NICE: There will not now be time to conclude the evidence of

20 the witness next listed before Christmas, and the decision has been taken

21 that it would be inappropriate to have his evidence in two parts. He will

22 therefore not now be taken until January at the earliest, and we will find

23 and identify by Thursday morning at the latest other witnesses to fill the

24 three plus one days remaining after the conclusion of this witness's

25 evidence, by my calculation, on Friday of next week.

Page 13614

1 JUDGE MAY: Yes. He's got about 14 hours outstanding.

2 MR. NICE: That's right. As to the next listed witness, there

3 have been a number of difficulties. It is possible that, in respect of

4 documentary provision, we will apply to the Chamber in the next few days

5 for specific assistance, there being time between now and the date when

6 the witness would be coming to Court for the Chamber to assist in dealing

7 with that, a matter we regard as really non-compliance by the provider.

8 Second point: The chronology that the Chamber required has been

9 prepared and will be served tomorrow. It is at the moment sourced mainly

10 to either the indictments or to the pre-trial brief, but of course the

11 paragraphs in those documents provide further sourcing to raw material for

12 most entries. The Chamber might have wanted to say something to the

13 accused about how he might approach this document. We've sought to make

14 the entries in it, entries in it that should be capable of agreement, and

15 by indicating agreement to those entries, time can be saved, time which

16 will thus be available for evidence in chief and in cross-examination.

17 JUDGE MAY: Yes. Well, we'll see the chronology when it comes.

18 If there are matters which should not be subject of controversy, we'll

19 invite the accused to agree them. You will let the accused have your list

20 of witnesses, or your next witness, as early as you can, so you can

21 prepare.

22 MR. NICE: It will be tomorrow afternoon, or Thursday morning at

23 the latest.

24 JUDGE MAY: Yes. Thank you.

25 Very well. We'll adjourn now.

Page 13615

1 Witness C-061, would you be back, please, on Monday morning.

2 Monday morning.

3 --- Whereupon the hearing adjourned at 2.06 p.m.,

4 to be reconvened on Monday, the 2nd day of December,

5 2002, at 9.00 a.m.

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