Tribunal Criminal Tribunal for the Former Yugoslavia>

Page 22061

1 Wednesday, 11 June 2003

2 [Open session]

3 [The accused entered court]

4 [The witness entered court]

5 --- Upon commencing at 9.04 a.m.

6 JUDGE MAY: Yes, Ms. Uertz-Retzlaff.

7 MS. UERTZ-RETZLAFF: Thank you, Your Honours.

8 WITNESS: WITNESS C-017 [Resumed]

9 [Witness answered through interpreter]

10 Examined by Ms. Uertz-Retzlaff: [Continued]

11 Q. Witness, yesterday, by the end of the day we were speaking about

12 the various different -- other Red Beret camps that you got information

13 about. And just briefly, was there a camp called Bilje near Osijek in

14 Eastern Slavonia, and who was in charge there?

15 A. To the best of my knowledge, the last information I have was that

16 the commander was Vlasto Mijovic.

17 Q. And before him?

18 A. Before him, Zika Crnogorac.

19 Q. And was there a camp Knezevi Vinogradi near Beli Menastir in

20 Eastern Slavonia? And who was in command there?

21 A. As I've already said, to the best of my knowledge, according to

22 what a man told me at the Bistrica Hotel in Jahorina, so according to his

23 story there was a camp in Knezevi Vinogradi and in Bilje, and he said to

24 me that Vaso Mijovic was practically in charge of all of Baranja.

25 Q. And the Pajzos camp near Bapska, did you actually see that camp at

Page 22062

1 some point in time? And do you know who the commander was?

2 A. I knew that Zvjezdan Jovanovic was commander of the camp. I was

3 never in the camp though. I know that Pajzos camp is near Bapska. I know

4 that from the time I was in Vukovar.

5 Q. And finally, the Tikves camp. What can you tell us about it?

6 A. As for what I know about the Tikves camp, this is really based on

7 what Pero Divljak told me. He said to me that they had come from that

8 camp when they came to Mostar.

9 Q. Let's turn -- return to the camp in Boracko Jezero. Was there a

10 time that the Red Berets and the recruits were transferred to a location

11 close to Mostar to enforce the Herzegovina Brigade?

12 A. Yes.

13 Q. And where were you taken and were there any other troops?

14 A. As I've already said, after about a month that I spent in that

15 camp - I don't know at whose request this was - but the local Serb forces

16 or rather, the Herzegovina Brigade had major problems in the region of

17 Podvelezje. I was never there before. I thought that Podvelezje was one

18 village, but there are actually ten villages there. In one of these

19 village, they met with resistance. They could not break through, so they

20 put in a request. I don't know how this happened. They asked for

21 reinforcements. And that's why they transferred us to Podvelezje.

22 MS. UERTZ-RETZLAFF: Your Honours, when you look back at the map

23 that you were given in the beginning, you see this -- it's a region

24 between Nevesinje and Mostar, right -- on the right side from Mostar.

25 There's a whole region with that name that we just mentioned.

Page 22063

1 Q. While you were there, did you -- did a politician come to visit?

2 A. Yes. Vojislav Seselj, accompanied by Zika Crnogorac.

3 Q. And what did the two -- what did they two do in that location?

4 A. What they really wanted is something that I actually don't know.

5 However, the two of them did come together. It was the first time I saw

6 Seselj. It was the first time I saw Zika Crnogorac too. Seselj brought

7 cigarettes for his volunteers. And immediately everybody gathered around

8 him. Whereas, Zika talked to Aco Legija.

9 Q. So the Seselj volunteers were also at that location and involved?

10 A. Yes. Yes. Seselj's volunteers too, and the men from Vukovar, the

11 Vukovarci, and these forces of the newly established Herzegovina Brigade.

12 MS. UERTZ-RETZLAFF: Your Honours, we would need to go briefly

13 into private session.

14 [Private session]

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12 [Open session]

13 THE REGISTRAR: We're in open session.

14 MS. UERTZ-RETZLAFF:

15 Q. The headquarters of the White Wolves, where were they located?

16 A. At Jahorina, in the forest-keeper's small house.

17 MS. UERTZ-RETZLAFF: Your Honour, when you look at the map, there

18 is the -- the whole region Jahorina indicated, and there is an "A," you

19 see the letter "A," that's where the camp was. The witness has marked

20 this map accordingly.

21 Q. Who was the commander of the White Wolves?

22 A. The commander of the White Wolves was the late Srdjan Knezevic.

23 Q. Was he a professional soldier?

24 A. No.

25 Q. Who was he, and what kind of a person was he?

Page 22067

1 A. Srdjan Knezevic was a local Serb from Pale. Before the war, he

2 had a coffee bar in Pale. Out of all these men I saw in these areas while

3 I was in Herzegovina and in Sarajevo, Srdjan Knezevic is the only one for

4 whom I can say that he was an honest man up to a degree. I mean, there is

5 no doubt about that, but he was a man who had a unit where there was some

6 kind of discipline.

7 Q. The unit, was it -- was it integrated in the VRS structure? And

8 if so, in which corps? To which corps did it belong?

9 A. Yes. It belonged to the Army of Republika Srpska. Officially it

10 belonged to the Sarajevo Romanija Corps. However, General Milosevic did

11 not have any influence whatsoever over Srdjan Knezevic directly.

12 Q. Who had the influence over Knezevic?

13 A. Ratko Mladic.

14 Q. And how do you know that?

15 A. Well, I know that on the basis of a million examples. For

16 example, many times Han Pijesak was contacted when Srdjan needed

17 something, and every action that Srdjan undertook was based on contacts

18 with Mladic before that.

19 Q. You mentioned Han Pijesak. Was that where Mladic was usually?

20 A. Yes.

21 Q. Did you ever hear or see Knezevic refuse to fulfil an order from

22 General Milosevic?

23 A. Yes, many times.

24 Q. And in such a case, what would happen?

25 A. Nothing would happen. Absolutely nothing. It would be the way

Page 22068

1 Srdjan said.

2 Q. The soldiers in the White Wolf unit, what kind of soldiers were

3 they? Where did they come from?

4 A. There were all kinds of people there. There were local Serbs from

5 Pale. There were Russians. There were Bulgarians. Seven languages were

6 spoken in the dorm. Most of these people had come from elsewhere.

7 Q. And what uniform did they wear? And did they have a particular

8 patch?

9 A. The uniforms were camouflage uniforms of the Army of Republika

10 Srpska. There were no patches whatsoever on the uniforms because these

11 were Srdjan's explicit orders that nobody should have any kind of patch or

12 insignia on them. The White Wolves never had any kind of patch or

13 insignia on except for the head of a white wolf on their vehicles.

14 Q. You have already mentioned that you were stationed in a building,

15 a wood building, at Jahorina. And you have actually prepared a sketch

16 with the help of the investigators. And it's tab 7. It is -- and I have

17 a few questions in relation to the buildings that you have indicated in

18 this sketch.

19 First of all, you have a building with the name "Mladic" in it.

20 What kind of a building was it and why is "Mladic" marked here?

21 A. It says "Mladic" here because that's what everybody called it in

22 the vernacular. This was a hotel where Mladic had most of his meetings.

23 I don't know how many times we saw his vehicles and his high-ranking

24 officers who had meetings with him.

25 Q. And you have also indicated this White Wolves's headquarters. And

Page 22069

1 did you actually -- the White Wolves, did you actually sleep in that

2 building when you were in Jahorina?

3 A. This is the headquarters of the White Wolves, and this is the

4 dormitory for the White Wolves, for people who came from elsewhere. But I

5 don't know whether I was there 20 times in total in this house, and

6 everybody else for that matter. Because we spent most of our time in

7 Trnovo and Treskavica.

8 Q. For what reasons did you go to this headquarters in Jahorina?

9 A. That would happen only when we would have time off. However, that

10 happened so seldom that I can count it on the fingers of one hand.

11 Q. And you have indicated also a place, Kosuta, and you put there the

12 name Goran Saric. What kind of a place was Kosuta and who was that

13 person?

14 A. Kosuta had been a hotel before the war. And when I came there, it

15 was the base of the special police brigade that was commanded by

16 Goran Saric. Its commander was Goran Saric.

17 Q. And you say "special police brigade," of the Republika Srpska? Is

18 that ...?

19 A. Yes.

20 Q. And you have also here the Hotel Bistrica. Who would use that

21 hotel?

22 A. Hotel Bistrica is also at Jahorina. It was used by the government

23 of Republika Srpska.

24 Q. Did you see government members there?

25 A. Yes, very often.

Page 22070

1 Q. What would they do there?

2 A. Some of them had rooms where they slept. Most of them came there

3 to gorge on food and drink.

4 Q. Did the White Wolves also use that -- the kitchen of the hotel to

5 eat and spend time there?

6 A. Yes. Every time they would have time off, or rather, when we

7 would have time off, Srdjan's orders were that they had to give us food

8 there.

9 Q. Was Srdjan Knezevic ever asked to join the police forces with this

10 unit?

11 A. Yes.

12 Q. And what was his reaction to this?

13 A. Well, when these two monkeys from the MUP came, they came with a

14 briefcase full of money, and they made this offer to Srdjan. They said

15 that there was no need for him to go into action, no need to do anything.

16 He was just supposed to provide security for Karadzic. At the end of this

17 story, there were four or five of us there, and we tried to save these two

18 men.

19 JUDGE MAY: I'm sorry to interrupt, but we can't use expressions

20 like "monkeys." It doesn't assist. Who are we talking about.

21 MS. UERTZ-RETZLAFF:

22 Q. You heard that. About whom are we talking?

23 A. These are men from the MUP, from the Ministry of the Interior of

24 the Republika Srpska.

25 Q. And did you know their names or not?

Page 22071

1 A. No. Srdjan knew them personally. They were some local men from

2 Pale. I had never seen them in my life.

3 Q. And why did Srdjan -- how did he react to the offer?

4 A. As I've already said, we tried to save those two from being killed

5 by him.

6 Q. So he rejected it?

7 A. Yes.

8 Q. You have already mentioned that you usually were in -- on other

9 location, and you mentioned Treskavica and Trnovo.

10 MS. UERTZ-RETZLAFF: Your Honours, it is indicated on the map

11 again, the region. It's an entire region. And indicated is here with

12 letter "B." It's indicated here with the letter "B." And Trnovo is

13 actually right above -- let's say 2 centimetres above the letter "B."

14 Q. Witness, when you were in Trnovo, where would the White Wolf unit

15 stay?

16 A. In the school building.

17 Q. Which other units did you see in Trnovo?

18 A. There were members of the police there, of the police of Republika

19 Srpska, mostly from Kula. Also, there was a police station from Trnovo.

20 There were members of the Army of Republika Srpska from the

21 Sarajevo-Romanija Corps. Their commander was Cedo Sladoje.

22 Q. Were any Seselj Chetniks there?

23 A. During the major offensive of the Muslim forces, there was Slavko

24 Aleksic from Grbavica.

25 Q. And when was that major offensive?

Page 22072

1 A. In 1995.

2 Q. You have mentioned just this person, Aleksic, Slavko Aleksic

3 from -- no, I'll come to him a little bit later.

4 In the school in Trnovo, were there only Serb soldiers housed or

5 also Muslims?

6 A. A platoon, a work platoon, from Doboj was accommodated there as

7 well.

8 Q. Where did they -- did they directly come from Doboj, or were they

9 from some other place, transferred from a different place?

10 A. What I know I know from what they said, that is, that they were

11 from Doboj. However, as far as I know, they were first transferred to the

12 prison at Kula in Sarajevo and from there they were transferred to Trnovo.

13 Q. Does that mean they were detainees?

14 A. Yes. Yes.

15 Q. And why were -- what were they used for in Trnovo? Why were they

16 there?

17 A. As I have already said, they called them a labour platoon and they

18 were used to dig trenches and dugouts along the frontlines at Treskavica.

19 Q. Did the White Wolves order them to do such things, or who?

20 A. I don't know who was their superior. They just slept there in the

21 same building. The White Wolves and Srdjan Knezevic couldn't give them

22 any orders because the White Wolves never held the lines, the frontlines.

23 Q. In early May 1995, did the White Wolves participate in a combat

24 operation in Debelo Brdo, above the cemetery -- the Jewish cemetery in

25 Sarajevo?

Page 22073

1 A. Yes, they did.

2 Q. What was the task given to the White Wolves and who gave them this

3 task?

4 A. First of all, a letter came from the command of the

5 Sarajevo-Romanija Corps, signed by General Milosevic, to the effect that

6 Ratko Mladic had given orders to Srdjan Knezevic to make a breakthrough at

7 Debelo Brdo.

8 Q. And -- yes. Can you continue?

9 A. Yes, I can. Srdjan in those days could not get in touch with

10 Mladic because Mladic was already somewhere around Bihac, I think; anyway,

11 at the other end of Republika Srpska. And there was a major dispute

12 between Srdjan and his deputy, Cvjetko Gacanin, because Srdjan wasn't

13 willing to undertake this operation on Debelo Brdo because it was very

14 heavily fortified. However, as he didn't wish to go against Mladic's

15 order, the decision was taken to carry out that operation after all.

16 Q. Who -- which other unit was involved in that operation?

17 A. Slavko Aleksic's Chetniks, acting from the direction of the Jewish

18 cemetery.

19 Q. Did you meet this person, this Chetnik, and what can you tell us

20 about his activities in the war?

21 A. I did see Slavko Aleksic, because often with Srdjan or some other

22 persons - I can't remember where - we went together to Grbavica. As for

23 any other units, I never heard that anyone hadn't committed any crimes in

24 Sarajevo or anything like that. I only heard this about Slavko Aleksic

25 and his men from Grbavica.

Page 22074

1 Q. Was he constantly in the region of Grbavica, and what was his task

2 there, his general task?

3 A. As far as I know, Slavko Aleksic was in Grbavica from the

4 beginning of the war and he held the line at the Jewish cemetery.

5 Q. We have now displayed on the -- on the Sanction system a picture.

6 Was that picture shown to you in -- it's tab 10 in the binder, but it's

7 actually an exhibit already used, Your Honours. It's Exhibit 451, tab 24.

8 Was this photo shown to you, and did you recognise the person,

9 despite the quality -- the bad quality of the photo?

10 JUDGE KWON: I think it's from the Exhibit 458.

11 MS. UERTZ-RETZLAFF: Oh, thank you, Your Honour.

12 Q. Who is that?

13 A. It's Slavko Aleksic.

14 Q. During the operation at Debelo Brdo, did the White Wolves have

15 heavy losses?

16 A. Yes, they did.

17 Q. Was the -- was Knezevic himself wounded?

18 A. Yes, he was.

19 Q. Were you present when -- did General Mladic appear at some point

20 in time at Debelo Brdo?

21 A. Yes, he did.

22 Q. Can you describe what you saw.

23 A. First of all, I have to refer to the beginning of the story,

24 because as I was saying, Srdjan couldn't contact Mladic, and this

25 operation was under preparation for some seven days, a little more or

Page 22075

1 less. I can't remember exactly. However, when it started, we suffered

2 very great losses within a span of five minutes, and upon

3 withdrawing - now, I can't remember whether we first went to the hospital

4 with Srdjan and came back and then met Mladic or whether this was

5 immediately after we had pulled out - but Mladic appeared suddenly,

6 unexpectedly, and I just happened to be there by chance because I was

7 helping Srdjan because he couldn't walk. And when Mladic appeared,

8 Milosevic was there all the time, coming and going. The first sentence

9 uttered by Mladic was, "Who told you to go to the president without my

10 permission?" And I found this very strange, because up until then I

11 hadn't heard that anyone went to the president, nor that he needed

12 permission.

13 Then he slapped him a couple of times, tore off his rank insignia,

14 and that is all I saw, because Srdjan just made a sign to me, indicating

15 that I should move away, I should get lost.

16 THE REGISTRAR: Can I just make a clarification for the record,

17 please. It's Prosecution's Exhibit 458, tab 24.

18 MS. UERTZ-RETZLAFF: Thank you.

19 Q. To clarify who slapped whom.

20 A. Mladic slapped Milosevic.

21 Q. Did you subsequently find out whether Mladic actually had ordered

22 this attack on Debelo Brdo or not?

23 A. Yes, we all found that out later on from Srdjan. Mladic hadn't

24 ordered that attack, and that was the reason why he slapped Milosevic,

25 because this had been done arbitrarily, or rather, in agreement with

Page 22076

1 Karadzic. Milosevic had used the White Wolves to capture Debelo Brdo,

2 thinking that the operation would succeed, so that Karadzic to say to

3 Mladic that he'd been around Sarajevo for three years and Milosevic had

4 managed to capture Debelo Brdo. So this was an attempt to remove Mladic

5 from the leadership of the Army of Republika Srpska.

6 Q. Did you get this information from Knezevic, or how do you know

7 that?

8 A. Directly from Knezevic.

9 Q. After the activity in Debelo Brdo, did you take part in this major

10 operation in Treskavica, when the Muslim offensive took place?

11 A. Yes, I did.

12 Q. Which Serb troops were involved?

13 A. At the beginning, when the Muslim forces launched the offensive,

14 the only people remaining in Trnovo were the White Wolves. All the others

15 had scattered. And then the Wolves from Drina, Marko Pavlovic, Legenda's

16 [phoen] Wolves arrived to help. And during this first attack, the Wolves

17 suffered considerable losses. And after that, upon Mladic's orders, we

18 were dispatched to Jahorina.

19 Q. When you were in Jahorina, did you see any troops arriving from

20 outside the area? And if so, which troops did you see?

21 A. Yes, I did. I first saw in Kasindol Ljubo Mauzer's Panthers and

22 when we arrived at Jahorina and went to the Bistrica Hotel, on the way to

23 the Hotel Bistrica, in front of the Kosuta Hotel, we first saw vehicles

24 with license plates of the Republic of Srpska Krajina. And after that,

25 people in black uniforms with markings of Arkan's Tigers and others with

Page 22077

1 Skorpije markings and people from the MUP of Srpska Krajina. Some of them

2 were in black uniforms and others in the standard police uniforms.

3 Q. Who was in charge of these troops coming from the Krajina and the

4 Tigers? Could you say?

5 A. Vaso Mijovic.

6 Q. Did you see him at Jahorina?

7 A. Yes, I did. I saw him.

8 Q. And had you seen him before in the Buna camp or in Jezero camp?

9 A. Yes. I saw Vaso Mijovic on one occasion at the camp at Boracka

10 Jezero. But what I was surprised by, because when I saw him at that time

11 he was a driver, and the young man that I spoke to at the Bistrica Hotel

12 on Jahorina, he said that Vaso Mijovic was a colonel.

13 Q. You mentioned the person Mauzer. Do you know what his correct

14 name was and where did he come from?

15 A. As far as I know, his name is Ljubisa Savic. His nickname is

16 Mauzer, and he's from Bijeljina.

17 Q. Did you see any soldiers with scorpion patches as well?

18 A. Yes, I did.

19 Q. Who were they?

20 A. At that point in time, I had no idea, because that was the first

21 time for me to see people with such insignia, and it was the first time I

22 had heard of the name Scorpions. But later on, staying in Vukovar, I

23 learnt that it was a unit from that area whose commander was a certain

24 Boco.

25 Q. I would like to show you now just a few patches. And this -- this

Page 22078

1 is here Exhibit 349, tab 5. What -- what patch is that? Which -- what is

2 written on the patch and which unit wore it?

3 A. It is the special guards, the Panthers. They were Ljubo Mauzer's

4 panthers from Bijeljina.

5 Q. And then Exhibit 349, tab 4. What kind of a patch is that?

6 A. Arkan's Tigers.

7 Q. And now I would like to put to you tab 8 of the witness Exhibit

8 460. It is a note dated the 24th of July, 1995 from the commander of the

9 IKM [phoen] Staff Savo Cvjetinovic. And it refers to the situation at the

10 Trnovo battlefront. First of all, do you know this person Savo

11 Cvjetinovic and what position he had?

12 A. No, I don't know that man. I've never even heard of him in my

13 whole life.

14 Q. At that time you see here 24th of July, 1995. Were you still at

15 the frontline in Treskavica and Trnovo, or had you already left?

16 A. No, I wasn't there.

17 Q. And reference in this document is made to the Scorpions unit of

18 the Serbian MUP. Do you -- were you aware that the Scorpions were a

19 police unit related to the Serbian MUP, or is that not known to you?

20 A. No, that was not known to me.

21 Q. And reference is made here -- there is a sentence saying: "During

22 the day, we will organise part of the company from Trebinje to go to

23 Nevesinje and attend Commander Zirgjevic's funeral, Dragan Zirojevic was

24 deputy commander to the late Nebojisa Sukic." Do you know this person

25 Zirojevic? Who was he?

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Page 22080

1 A. Yes, I do know Dragan Zirojevic. He's from Nevesinje. He was

2 also one of the first 57 Red Berets. Dragan Zirojevic came together with

3 all of the Red Berets to Mostar. And after the Red Berets, that is, those

4 from Serbia had gone to Serbia, he became the commander or chief of the

5 police station in Nevesinje.

6 Q. And were you aware that he got killed?

7 A. Yes, I heard about it.

8 Q. Do you know whether he was killed in -- on Treskavica or any other

9 combat action?

10 A. Dragan Zirojevic was killed at Treskavica.

11 Q. That should be enough for this.

12 While you were still in the region of Sarajevo and Treskavica, did

13 international forces start bombing Pale?

14 A. Yes, they did.

15 Q. Do you recall the time of the year?

16 A. All I can say is that it was immediately after the operation on

17 Debelo Brdo, because we attended the funeral of White Wolves members when

18 the bombing started.

19 Q. Did you get information in relation to activities of a certain

20 Nikola Ribic?

21 A. Yes. Nikola Ribic, also known as Kanada, was a member of the

22 White Wolves.

23 Q. What did he do in relation to the bombing?

24 A. Nikola Ribic, on his own initiative, without receiving orders from

25 anyone, captured two members of UNPROFOR or observers, whatever they were,

Page 22081

1 took their jeep, and tied them to a mast at Pale -- to a bridge at Pale.

2 Q. Were you present when Knezevic got a -- a call on the Motorola

3 related to that issue?

4 A. Yes, I did.

5 Q. What -- can you explain what you heard and what the circumstances

6 were?

7 A. After Kanada had done what he did, I think that we were at the

8 Sandro coffee bar and he came there. And shortly after him Knezevic

9 arrived. Kanada told him what he had done. And quickly after that a call

10 came over the Motorola and the White Wolf was being looked -- asked for by

11 Vihor. I can't remember whether it was Vihor I or II, but it was Vihor.

12 I am 100 per cent sure of that. And Srdjan was given permission for the

13 operation to continue, that he had done well and that he should continue

14 with it.

15 Q. What were the exact words? Do you recall the words that you heard

16 this Vihor I or II say?

17 A. I can't remember exactly what the words were, but what I can

18 remember is that it was in connection with what Kanada had done, that it

19 was a good thing, and that the operation should be continued.

20 Q. And Vihor I or II, did you know who used that caller ID?

21 A. Yes, I do know. Vihor I or II - I'm not sure which - is the code

22 name for Momcilo Krajisnik, or rather, his office.

23 Q. How do you know that?

24 A. During the preparations for the operation against Debelo Brdo,

25 just by chance - because code names are changed frequently - Srdjan for

Page 22082

1 the crew of recoilless gun used the code name Vihor, upon which a man from

2 the security unit of Radovan Karadzic came to Srdjan to tell him

3 personally that that code name could not be used because it was Momcilo

4 Krajisnik's code name. And we also received information of the same

5 contents from the communications centre at Jahorina, of which the code

6 name is Labud III.

7 Q. And after this conversation on the Motorola that you heard, were

8 more hostages taken and were the White Wolves involved in that?

9 A. I was personally present, close to the hotel - I think its name

10 was Panorama - and a house was there in which the observers or UNPROFOR

11 were put up. And Srdjan was also there. And it was explicitly ordered

12 that all the military equipment should be collected and that personal

13 belongings could not be taken.

14 Q. And I forgot to ask you: You mentioned that you were in a place

15 like Sandro cafe or bar. Where is that? Where is it located?

16 A. The Sandro coffee bar is at Pale, and its owner was a man who

17 worked in a unit of Srdjan Knezevic. He was in the logistics.

18 Q. Did you know how this whole hostage-taking affair ended? Did you

19 get information to that effect?

20 A. As I was saying, I was present when that house was being searched

21 and when the hostages were taken from there, the operation acquired broad

22 proportions, so that at Grbavica Slavko Aleksic's Chetniks had a conflict

23 with the French Foreign Legion, also the military barracks at Lukavica.

24 And towards the end of the day, together with Knezevic and I think a

25 couple of others from the White Wolves, we went to the Lukavica

Page 22083

1 headquarters where Knezevic went to attend a meeting with General

2 Milosevic. Because you can't go inside, I went to the building of the

3 military police to see their commander Cvoro, who told me that Jovica

4 Stanisic and the Red Berets from Serbia were involved in this operation

5 regarding the hostages and their equipment.

6 Q. While you were in the wider Sarajevo region in the years 1994 and

7 1995, did you observe deliveries of weapons coming from Serbia?

8 A. Yes, many times, especially in front of the building of the

9 military police. There were civilian trucks with license plates from

10 Serbia. I personally never got into the truck to see what was inside, but

11 from people who were members of that unit I learnt that there were new

12 rifles or ammunition or whatever it was they were delivering.

13 Q. You say "in front of the building of the military police." Can

14 you be more specific? What kind of a building are you referring to?

15 A. It's the building in which the military police was housed of the

16 Sarajevo-Romanija Corps. Their commander was Captain Cvoro. And they

17 used the military police building and the trucks always entered at night,

18 because at the other gate there were UNPROFOR members or, rather, members

19 of the French Foreign Legion who controlled everything coming in and going

20 out from the barracks.

21 Q. Did you see these kind of trucks also in Pale?

22 A. Yes, many times in front of the police building at Pale, or in the

23 area where the warehouses are, where the timber mill is at Pale. On many

24 occasions, yes.

25 Q. While you were in combat actions, did you happen to notice where

Page 22084

1 the ammunition you used came from and when it was produced?

2 A. Yes. Many times I would say, for instance, PPU, which meant Prvi

3 Partizan Uzice and the year of production, now, whether it was 1993 or

4 1994 -- but anyway, it was one of the years of the war.

5 Q. After the NATO bombing, you said you were in Harli [phoen]: Did

6 you come across a partly blown-up storage facility, and what did you see?

7 A. Yes. That was when we went to see Sljivo, who was a security man

8 in the White Wolves, and his house is right next to the warehouse of the

9 Army of Republika Srpska. As during the shelling the -- half of the

10 warehouse no longer existed, and that was the first time that I saw

11 rockets which they call Krmace or sows.

12 Q. Can you describe these rockets?

13 A. All I can say -- that is all I can say about them, because I saw

14 them from a distance, and this was something enormous. And it wasn't in

15 boxes but it was on some kind of stands. And I never in my life saw such

16 a rocket being launched, nor did I ever see the effects of such a rocket.

17 That was the first and last time I saw them in my life.

18 MS. UERTZ-RETZLAFF: Your Honours, we need to go now into private

19 session.

20 [Private session]

21 [redacted]

22 [redacted]

23 [redacted]

24 [redacted]

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Page 22085

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Page 22088

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9 [redacted]

10 [Open session]

11 THE REGISTRAR: We're in open session.

12 THE ACCUSED: [Interpretation] Before I begin my cross-examination

13 of this witness, I should like to draw your attention one and all to the

14 fact that these secret witnesses are being significantly abused in order

15 to place information which is wholly untrue and incorrect. And I'm going

16 to prove that.

17 JUDGE MAY: Your job at the moment is to ask questions of the

18 witness, not make observations.

19 Cross-examined by Mr. Milosevic:

20 [redacted]

21 [redacted]

22 [redacted]

23 [redacted]

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25 [redacted]

Page 22089

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9 [redacted]

10 JUDGE MAY: Yes. Private session. This was all --

11 THE ACCUSED: [Interpretation] Why, Mr. May?

12 [Private session]

13 [redacted]

14 [redacted]

15 [redacted]

16 [redacted]

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Page 22090

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25 [Open session]

Page 22091

1 THE REGISTRAR: We're in open session.

2 MR. MILOSEVIC: [Interpretation]

3 Q. Very well, Mr. C-017. You spoke here about the events in Mostar

4 and the surrounding parts at that material time, the time you testified

5 about. That's right, isn't it?

6 A. Yes.

7 Q. I assume that the events in Mostar from those times are well known

8 to you; right?

9 A. Generally speaking, yes.

10 Q. All right. Fine. Now, I'm going to ask you a few questions to

11 which you can give me brief answers. You can say whether you know about

12 it or don't know about it. Do you know that at the end of the summer of

13 1991, that is to say, the time you mentioned yourself, this period, in

14 Mostar the Patriotic League, a paramilitary Muslim formation, was formed?

15 Did you hear anything about that? Do you know about that?

16 A. What I can say on the subject is this: I knew that there was a

17 strong stronghold of the SDA. As far as the Patriotic League is

18 concerned, that was the only time -- the only time I saw it or heard about

19 it was on BH television, whether before the war or a little after the war

20 had started in Sarajevo. That's as far as I know about the Patriotic

21 League.

22 Q. All right. Fine. When you say there was a strong stronghold of

23 the SDA in Mostar, what do you mean by that?

24 A. I mean that at that particular time, most of the inhabitants of

25 Mostar were Muslim by ethnicity and that they had a very strong party

Page 22092

1 there.

2 Q. All right. And do you remember some other events? Because at

3 that particular time, as far as I understood it, you were there in the

4 area throughout. Is that right?

5 A. Yes, I was.

6 Q. Well, do you remember the attack launched by the Muslim forces on

7 Djuro Salaj on the Buna on the 1st of April, 1992?

8 A. I can't remember that, because at that particular time I was in

9 Mostar, which means during April. Whether it was the end of March or the

10 beginning of April, I can't quite remember, but I ended up being in prison

11 in Mostar.

12 Q. All right. And do you know that from the motel called the Buna

13 Motel, the Muslim extremists started shooting at a military vehicle? Do

14 you happen to remember that particular event and that the JNA members

15 arrested five reserve policemen? They released them the same day, by the

16 way. But there was shooting at the members of the Yugoslav army in those

17 days.

18 A. As far as I can recall, yes, there were incidents, sporadic

19 gunfire or whatever you like to call them, between the reserve or active

20 composition of the JNA, and these local police forces. Under whose

21 command they were, I really can't say. But as I've already said, I was in

22 a cell.

23 Q. All right. Fine. Now, do you know about the terrorist attack on

24 the JNA barracks called Severni Logor, Northern Camp, at the beginning of

25 April? Did you hear about that?

Page 22093

1 A. Yes, I did. If we're thinking of the same thing, if we're

2 thinking about the truck where some explosive devices were planted.

3 Q. Yes, I am thinking about that cistern truck that caused an

4 explosion and the explosion could be heard far wider than Mostar. That's

5 right, isn't it?

6 A. Yes, it is. That's right.

7 Q. That took place on the 3rd of April?

8 A. Didn't it?

9 A. Well, I really can't say. I'm not very good with dates. I can't

10 remember. It was in April, yes, it was. Now, what the exact day was, I

11 don't know. I can't say.

12 Q. Now, do you remember that 30 civilians were wounded and that one

13 soldier was killed following that incident and that four were seriously

14 wounded and three men less seriously wounded? Do you remember that? I

15 assume you do because it was an event that everybody knew about in Mostar.

16 Mostar isn't a big town.

17 A. As far as the fact that a certain number of people were injured

18 and that considerable material damage was caused to the JNA barracks, I do

19 know that, yes. Because yes, it was a well-known event in Mostar. But

20 once again, as to the figures of who was wounded and killed, I really

21 can't say.

22 Q. All right. Now, how did this event and occurrence impact on the

23 citizens of Mostar?

24 A. Well, there was fear. And what I can tell you, what I know and

25 can say, is that the Serbs began to leave Mostar in masses.

Page 22094

1 Q. Well, how many Serbs lived in Mostar before the war, to the best

2 of your knowledge?

3 A. Well, for me personally, it's a difficult question to answer,

4 because I consider myself to be a Yugoslav, from the Socialist Federal

5 Republic of Yugoslavia, the country I was born in. So I really never

6 asked anybody in my life whether they were a Serb, a Croat, or Muslim.

7 Q. All right. I just asked you. If you don't know, say so.

8 A. No, I don't know.

9 Q. Now, after that attack, the attack that everybody in Mostar knew

10 about, did you hear about attacks by the HOS and Green Berets on military

11 facilities, especially the military airport, airstrip, and these attacks

12 became frequent later on? On the 9th of April, for example, a soldier was

13 killed and several others were wounded and the armed attacks around the

14 JNA became more and more frequent and gained in intensity during those

15 days.

16 A. As I've already said, the events that took place round about,

17 there were rumours going round, but I personally was in prison.

18 Q. And do you happen to remember the event that took place when close

19 to Mostar ten soldiers were captured and three superior officers after the

20 truce that was agreed upon in Sarajevo and related to the entire territory

21 of Bosnia-Herzegovina?

22 A. Which truce are you talking about? Which cease-fire?

23 Q. The 13th of April. You don't know about that?

24 A. No.

25 Q. And do you remember another event, when some pilots were

Page 22095

1 kidnapped, Major Milan Micic and Captain First Class Dragan Arsovski from

2 the airport in Mostar? Do you remember them?

3 A. Partially. It rings a bell. I'm vaguely -- I vaguely remember

4 something like that happening, but I really can't remember the details

5 around the whole event.

6 Q. All right. Did you know what was going on, for example, on the

7 26th of April, what happened then, when these formations, the ones we're

8 discussing, attacked the barracks of the Mostar battalion? Do you know

9 where the Mostar Battalion barracks are located?

10 A. I know where the northern and southern camps are located, but I

11 don't know the names.

12 Q. All right, you don't know names. But do you remember the attack

13 on the barracks on the 26th of April?

14 A. No.

15 Q. All right. Fine. Now, do you remember this: That on the 27th of

16 April this time in Mostar, we saw the arrival of UNPROFOR forces?

17 A. No.

18 Q. And then there was some provocations, and there was artillery fire

19 coming from both sides, precisely when the UNPROFOR forces arrived. And

20 there are facts and figures about that, information about that.

21 A. No, I don't know anything about that.

22 Q. All right, then. Do you know who controlled at the time, apart

23 from the soldiers who were in the barracks there, the JNA soldiers, who

24 was in control of the Mostar region?

25 A. As I've already said, the situation was very murky, because I

Page 22096

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2 [redacted]

3 [redacted]

4 [redacted]

5 [redacted]

6 Q. All right. Now, is it quite clear that it was for the most part

7 these paramilitary formations, that is to say, the HOS and the Green

8 Berets or, rather, the Muslim forces, and these paramilitary forces as

9 well, that they controlled the town itself - is that clear - and all the

10 main facilities in the town?

11 A. As I've already said, it was a very murky situation, because the

12 northern camp facility, for example, is in the town itself. The southern

13 camp is towards the exit of the town. And the northern camp was across

14 the road from the Zalik settlement, which means in town, and the army was

15 there. As to the Konak barracks, for example, which before the war was

16 linked to the JNA command or something like that - I really can't say -

17 but you could see military personnel moving about there. That remained

18 under the command, for example, of the Serb forces, or rather, the JNA.

19 Now, between the Konak and the northern camp, that part of town, there was

20 a sort of reserve police force, so the formation that I saw and that took

21 me into custody was officially HOS.

22 Q. So you were arrested and taken into custody by the HOS. Do you

23 know what the HOS is?

24 A. Yes, Croatian Defence Forces.

25 Q. Do you know that it is a paramilitary formation?

Page 22097

1 A. I do know that, yes. I do know that it is a paramilitary

2 formation. At that time it was, anyway.

3 Q. I'm asking you this because the HOS was treated as a paramilitary

4 formation even by the Croatian authorities, both in Bosnia and in Croatia

5 too.

6 A. Yes, I do know that.

7 Q. Now, do you know that because it's Paraga [phoen] and his

8 extremists; right?

9 A. There was particular fear in Mostar from HOS because they knew

10 that Blaz Kraljevic was commander of the unit. So when I was in prison

11 myself, the way in which I was exchanged, for example, was precisely

12 because of this, because people learnt about it. So the people who helped

13 me, actually, were Croats. But they came to learn that they would be

14 transported to Dretelj. And anybody ended up in Dretelj never left it in

15 one piece. And if he did leave it in one piece, he was a bit deranged. So

16 the people were there from Blaz Kraljevic's unit, that is to say, people

17 from Western Herzegovina.

18 Q. And do you know that when it comes to HOS, the Croatian

19 authorities themselves ordered that HOS had to be subordinated to the

20 Croatian army or disbanded? If they refused to join the Croatian army and

21 become subordinated to it, in Bosnia-Herzegovina that they had to be

22 subservient to the HVO? So they, too, were absolutely astounded by the

23 atrocities that HOS carried out in the region. Do you remember that?

24 A. As far as all this is concerned, I stressed in my statement and my

25 testimony that I'm a sportsman myself, so I am apolitical, totally

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Page 22099

1 apolitical. And I was there not of my own free will. So all the events

2 around HOS and the military and paramilitary formations, I really can't

3 say anything about that. The only thing I can say is that yes, there was

4 a great deal of fear. Even Croats were afraid. And the young man -- the

5 guy who helped me had a lot of problems with the HOS after I was

6 transferred to Serb territory.

7 Q. Well, this man Blaz Kraljevic and his escorts precisely on the

8 Cule-Mostar road and Croatian territory, they themselves killed because

9 they couldn't come to terms with them.

10 A. Yes, I did hear about that story.

11 Q. Because of his self-will, lack of discipline, the atrocities he

12 carried out, and all the rest of it, because everybody suffered from this,

13 both the Serb, Croats, and the Muslims, everybody. It was to their

14 disadvantage.

15 JUDGE MAY: Let us deal with the witness's evidence, not your

16 comments on it. He can deal with what he knows himself. He can't give

17 evidence -- he can't deal with political matters or what the Croats did.

18 That's for them, and you can give evidence about it if you want.

19 MR. MILOSEVIC: [Interpretation]

20 Q. Do you remember, as this was the time when you could have known

21 about this - and I told you when UNPROFOR arrived in Mostar - do you

22 remember that on the 3rd of May, in a place between Mostar and Citluk, the

23 representative of the European mission was killed, he was a Belgian,

24 Bertrand Dore [phoen] was his name, and due to that the European mission

25 transferred its offices to Split temporarily because of the security

Page 22100

1 situation there?

2 A. I really don't know about that.

3 Q. You don't remember? All right. Fine.

4 Now, let's move on to the main subject of your testimony. You

5 said that on the 6th of May for St. George's Day, Djurdjevdan?

6 A. Yes, as far as I remember.

7 Q. On the left bank there was one group, on the right bank there was

8 the JNA and the attack on Mostar.

9 A: Yes

10 Q: And you were very categoric in stating that it was Djurdjevdan,

11 St. George's Day, the 6th of May, the attack.

12 A. Yes, I do remember it was St. George's Day.

13 Q. Mr. 017, there was no attack on Mostar.

14 A. That's not correct.

15 Q. Is that right or is that not right? On the 6th of May, there was

16 absolutely no attack on Mostar, none whatsoever, because in the southern

17 camp and in the northern camp was the JNA. Is that right?

18 A. That is right.

19 Q. So then how could the JNA come and attack Mostar from somewhere

20 else when it was in Mostar? It withdrew from Mostar on orders later on.

21 So what kind of attack are you talking about? And once they withdrew,

22 there was no attack on Mostar.

23 A. When the JNA withdrew, there was no attack. On the 6th of May, on

24 St. George's Day, on Djurdjevdan, since the area between the southern camp

25 and the northern camp is called the town of Mostar, this is where the

Page 22101

1 attack was carried out, from the right side and from the left side. Or as

2 they called it, the cleansing of Mostar was carried out.

3 Q. What are you talking about? What kind of cleansing of Mostar?

4 JUDGE MAY: The witness has given his evidence. He says that was

5 the day. So no real point arguing about it now.

6 But let us adjourn. Twenty minutes.

7 Could you be back, please, Witness C-017 in 20 minutes.

8 --- Recess taken at 10.31 a.m.

9 --- On resuming at 10.54 a.m.

10 JUDGE MAY: Yes, Mr. Milosevic.

11 MR. MILOSEVIC: [Interpretation]

12 Q. Do you know, in view of this blockade and the major presence of

13 various paramilitary formations in Mostar, the army could not even move

14 through Mostar; they had to go by helicopter from one barracks to the

15 other or to the positions where they were deployed?

16 A. I don't know about that. I did hear helicopters many times

17 though.

18 Q. Do you know that there was an order issued by General Perisic, who

19 at that time was garrison commander in Mostar -- or rather, corps

20 commander down there, not to respond to provocations? These provocations

21 were gunfire at military facilities coming from different sides. Do you

22 know anything about this gunfire directed at military facilities and

23 everything else that was going on, and are you aware of this order issued

24 by General Perisic not to respond to provocations, for the army to make an

25 effort to distance itself in every possible way from such conflicts?

Page 22102

1 A. I'm not aware of that.

2 Q. Oh, you're not aware of that. All right. You were saying that,

3 in addition to the army, there was the Serb Territorial Defence; is that

4 right?

5 A. Yes.

6 Q. Within this Territorial Defence, there were volunteers too; right?

7 A. Within the Territorial Defence, no. The volunteers, as they

8 called themselves, yes.

9 Q. Are you trying to say that they were not within the Serb

10 Territorial Defence ranks?

11 A. No. Because the local Serbs were more afraid of these volunteers

12 than the members of the other local ethnic groups.

13 Q. All right. I'm going to ask you for an explanation now, because

14 you claimed here that there were some Red Berets over there and that they

15 were dominant, as you had put it.

16 A. Yes.

17 Q. You said that this was a group from Knin or, rather, as you had

18 put it, Knindzas who had been trained by Captain Dragan.

19 A. My knowledge about that, specifically about that, the Knindzas and

20 the fact that they were trained by Captain Dragan, comes from them

21 themselves. I heard about it from them.

22 Q. All right. Various patches were shown to you here, and then you

23 recognised one, saying the police of the Krajina, Milicija Krajina, and

24 other such things. So these were the people who were dominant there.

25 That's what you said.

Page 22103

1 A. Yes.

2 Q. Later, when you talked about the Boracko Lake, Mrs. Uertz-Retzlaff

3 asked you how many of them were there, and you said about ten. Is that

4 right?

5 A. Yes.

6 Q. And then you confirmed that actually all of them but one went

7 there.

8 A. Yes.

9 Q. Tell me now, how is this possible that about ten of them dominate

10 over there, among all these people who you say were there?

11 A. Quite simply, first of all, on the basis of what you were saying

12 and also on the basis of what Seselj's volunteers were saying later, it is

13 well known that all of them, all of them who called themselves volunteers,

14 Seselj's volunteers, or the White Eagles, were trained in Golubic within a

15 27-day period under the command of these very same Red Berets that were

16 down there.

17 Q. Do you know where this Golubic is?

18 A. I heard that it was near Knin. I was never there.

19 Q. Oh, you were never there. Then explain another thing to me:

20 Since you said yesterday during your testimony that when you got a cap and

21 somebody put it on your head, you didn't even want to take it. Somebody

22 put it on your head. Is that right?

23 A. First of all, since there was a lot of talk about this cap, yes,

24 this man actually put my cap on my head. I did not ask for the cap. And

25 at the time when this was happening, this was not a significant event at

Page 22104

1 all. The fact that he put a cap on my head, because in fact in this

2 formation he was just a little nobody.

3 Q. I'm just interested in one detail: You say that there was a

4 two-headed eagle on the cap and that on it there was the letters "DB,"

5 State Security, Drazavna Bezbednost.

6 A. Yes, Pero Divljak is the only one who I saw with that.

7 Q. All right. Since you are linking this up, although you say that

8 these are people who came from Knin, and you're linking this up with the

9 state security of Serbia, do you know that it is quite impossible for the

10 state security of Serbia to have some kind of a two-headed eagle with the

11 letters saying "State Security" on it?

12 A. I don't know anything about the state security of Serbia in a

13 general context. I can only say what I saw. So as for the state security

14 and Frenki and everything else, I just heard about this from them.

15 Q. Oh, you heard about it from them?

16 A. But I did see this sign on the patch. This is what I saw on

17 Pero Divljak's cap. The two-headed eagle with the letters "DB" on it.

18 Q. All right. Now we're going to get to Pero Divljak too. But was

19 it clear to you then that the two-headed eagle could certainly not be the

20 sign of the state security of Serbia?

21 A. How could I know that? I have nothing to do with them. The first

22 time I saw these men, I did not know who they were and where they came

23 from and why they were there.

24 Q. All right.

25 JUDGE MAY: Could the legal officer come up, please.

Page 22105

1 [Trial Chamber and legal officer confer]

2 MR. MILOSEVIC: [Interpretation]

3 Q. In your statement, you refer to a large number of persons who you

4 know by name but not in person; is that right?

5 A. I said explicitly in my statement what I saw and what I heard.

6 Q. All right. Apart from this attack that you say took place on the

7 6th of May -- well, there was no attack, and there weren't any force

8 movements, troop movements. Do you know that the army left on orders?

9 You talked about Perisic's speech to the soldiers. He gave some

10 explanation of his. I'm not going into all of that now. I am not going

11 into that, whether he had information available at the time. But he was

12 probably giving this explanation with the best of intentions, that the

13 army had withdrawn from Mostar actually and that until then the army had

14 been in Mostar.

15 A. Yes.

16 Q. It was in the southern camp and northern camp, in these barracks?

17 A. At the time when the JNA withdrew from Mostar. So we are talking

18 about the period from the 6th of May until the 15th of June. The army

19 completely held under its control the left bank because people talked

20 later on and said that Karadzic had said that Neretva, the Neretva River

21 was a natural boundary, because the paratroopers had taken the other bank

22 one day and then they withdrew the same day.

23 Q. It has to be the left bank. If it's the eastern bank, because you

24 say which bank is which one if you look at the confluence.

25 A. For me I did not find this quite clear because for me there are no

Page 22106

1 different banks in Mostar. I can't remember who was the first person from

2 whom I heard this, the eastern bank and the western bank.

3 Q. At any rate, the army could not take Mostar when it was in Mostar

4 in the first place. And once it withdrew from Mostar, afterwards it did

5 not take it any more. Is that right or is that not right?

6 A. No, that is not correct. Now we're talking about the JNA.

7 Before, the army was at the airport, at the Heliodrom. At the Heliodrom

8 actually. Because this is on the right side. That's where a military

9 high school was, called Marsal Tito. And underneath was the Heliodrom.

10 This is Rodoc and Jasenice, those settlements. And before the 6th of May,

11 the army was there, the JNA was there, at the Heliodrom. The army was at

12 the airport, and the other side too, because the aviator's bridge has to

13 be crossed in order to reach the airport.

14 Before entering Mostar, the 63rd Airborne Brigade completely

15 levelled the village of Gnojnice, which is above the airport, with the

16 assistance of reservists from Montenegro. And there were large numbers of

17 them there. [redacted]

18 [redacted]

19 [redacted]

20 As for Sarajevo, the army was in the northern camp and in the

21 Konak barracks that was in town. On the right side, that is to say, the

22 neighbourhoods that are on the road to Listica -- or rather, in that

23 direction. They were totally under control. I don't know how to call

24 them, the Croat-Muslim forces. I don't know who commanded them at the

25 time. I really don't know about that particular point in time. However,

Page 22107

1 as for what you're saying, that the army was in Mostar, if the army were

2 in Mostar, I and the rest - I don't know how many of us were in the

3 cell - would not have ended up in prison, because it would have been

4 impossible for me to be in prison arrested by the HOS. And if this same

5 town were held by the Serb forces. This is quite illogical.

6 Q. This is exactly what I wanted to hear from you. When I say "in

7 Mostar," you said just a few minutes ago, you confirmed, that the army was

8 at the airport, at the Heliodrom, at the military high school, and its

9 barracks, the southern camp and the northern camp. So the army was in its

10 own facilities. Is that right?

11 A. Correct, until the 6th of May.

12 Q. And the army did not hold Mostar. It was in these military

13 facilities, and the army was being shot at from various quarters.

14 A. I already said that at that time I was in prison, when there was

15 this sporadic gunfire and all the rest that was going on between these

16 formations and the JNA formations.

17 Q. So it was the Croat and the Muslim forces that held Mostar.

18 That's what you confirmed just now.

19 A. Yes.

20 Q. And the army did not carry out an attack against Mostar, and it

21 did not take Mostar. It never took Mostar.

22 A. That's not true, because the army started an attack on the 6th of

23 May. And as far as I can remember, this attack went on for two days only,

24 because they left the northern camp and the southern camp simultaneously.

25 And I already mentioned all the units that were on that side where I was,

Page 22108

1 on the right side, where the paratroopers were. The composition of the

2 units from the northern camp is something I am not aware of, but I did see

3 people -- these people when the Serb forces, the JNA - call them what you

4 will - when they finally linked up by the Rasvita [phoen] department

5 store. That was the end of this action that they called the cleansing of

6 Mostar.

7 Q. How can you talk about the cleansing of Mostar when nobody

8 cleansed Mostar? Mostar was under the control of the Croat and Muslim

9 forces.

10 A. Well, I don't know. If the JNA forces and the Serb forces, the

11 Territorial Defence and everybody else, enters Mostar, I mean, I don't

12 know. They weren't carrying flowers. As far as I could see, they were

13 carrying lighter weapons or heavier weapons.

14 Q. All right. However, they made communication possible. And then

15 the army withdrew from Mostar. Is that right?

16 A. The army withdrew on the 15th of June from Mostar. So what I can

17 claim, in relation to this period, and what I saw at the airport, or

18 rather, what I saw at the northern camp barracks, and perhaps two or three

19 days later - I can't remember exactly, because I don't find this important

20 at all - as far as I know, from their stories, it was the Uzice Corps.

21 But I did see the army withdrawing from Nevesinje. That is the only thing

22 I saw concerning the withdrawal of the army.

23 Q. The army left Mostar. It left its facilities, the facilities

24 where they were. And until then, they held these facilities of theirs.

25 And Mostar was held by the forces that you mentioned. Is that right?

Page 22109

1 A. No. I said, and I underlined awhile ago, that the army from the

2 6th of May until the 15th of June, actually, until the army -- when the

3 JNA withdrew -- perhaps it was a few days before that. I don't know.

4 They started this operation, the Croats and the Muslim side called this

5 the liberation of the left bank. I don't know when this really started.

6 But the army, with the population and with all the Serb forces, withdrew.

7 I think that the date when I got out of Mostar, the Neretva Valley, rather

8 because I was not in Mostar; right? I mean, at the time of the

9 withdrawal. It was approximately the 17th of June. So it was two days

10 later.

11 Q. All right. Do you know that the JNA, according to the orders they

12 received, left Bosnia-Herzegovina and therefore Mostar as well?

13 A. What I can say about this is what I saw myself, and what I heard

14 myself, what Perisic said.

15 Q. All right. In addition to this peril concerning the attack on

16 Mostar on the 6th of May, which never happened, actually, I can see here

17 that on page 3 you say that at the beginning of 1990 the representatives

18 of Serbs from Borovo Naselje went to meet Rade Kontic, who was the prime

19 minister of Yugoslavia or Serbia at the time. You say that that is 1990.

20 Well, do you know that in 1990 Ante Markovic was prime minister of

21 Yugoslavia?

22 A. As for that paragraph, could you please read it in its entirety?

23 Because it says here quite explicitly that I heard this story.

24 JUDGE MAY: Let the witness have a copy of his statement.

25 Just a moment.

Page 22110

1 Yes. What was the -- do you have the passage, Witness C-017? Or

2 we'll get the accused to mention it again. You do.

3 Yes, Mr. Milosevic.

4 THE WITNESS: [Interpretation] Yes, I've found it.

5 MR. MILOSEVIC: [Interpretation]

6 Q. Well, that's precisely what I'm saying. In this voluminous

7 statement of yours, you mainly talk about various rumours, gossip that you

8 heard, including jokes, like the one how -- who introduced themselves to

9 Kontic. Well, read it yourself. You say. "In the beginning of the

10 1990s -- 1990, Milenko, as a representative of the Serbs from Borovo

11 Naselje, went to meet Rade Kontic, who was at the time prime minister of

12 Yugoslavia or Serbia." He could not have been prime minister of Serbia.

13 He comes from Montenegro; much later he was prime minister of Yugoslavia.

14 That is correct. However, in 1990, Kontic was not prime minister. In

15 1990, Ante Markovic was prime minister. Do you remember that?

16 A. I already said at the beginning that I'm totally apolitical. That

17 is the first thing.

18 And secondly, if you're reading this sentence, it says at the end,

19 "I'm not sure." So these people are quite irrelevant to me. It was

20 actually another person that was being referred to here, and I only talked

21 about what had to do with him -- or rather, what I heard.

22 As for your claims concerning rumours and things like that, I

23 still have scars here from prison. Here I do not have my own teeth.

24 Q. I'm not going into that, how the HVO tortured you, kicked out your

25 teeth, et cetera.

Page 22111

1 A. Here I'm talking about the Serb prison in Trebinje, because for me

2 there is no difference whatsoever, because there were beasts in human form

3 on both sides, but they just wore different insignia. That's the only

4 difference. I mean, so much for rumours.

5 Q. All right. What I said to you about Kontic, I imagine that's not

6 being disputed. It's not difficult to establish who was prime minister

7 when.

8 Now, let us take this in order, please, because you devote a large

9 part of your statement to different people. So judging by your statement,

10 I assume that you did not put all of their names down according to

11 significance but, rather, according to the alphabet, from A onwards.

12 You have some 13, 14 pages of persons whose names you mention. So

13 I'd like to take this in order, although we don't have to go through all

14 of this. The first person you mention on page 2 - you mentioned him just

15 now as well - in your statement, a certain Slavko Aleksic.

16 A. Yes.

17 Q. You said that he was a Chetnik commander and that he committed

18 various atrocities.

19 A. Yes.

20 Q. And then you said that he held the line. The frontline you mean;

21 is that right?

22 A. As for that, the frontline, the Jewish cemetery is less than 50

23 metres away from Grbavica. So he was there. His men were on this line,

24 but every shift has yet another shift coming, so they slept at Grbavica.

25 Q. Talking about him and his men, is it in dispute, is it an issue

Page 22112

1 that all these people were from Sarajevo, as you say, mostly from Grbavica

2 and other parts of Sarajevo? I'm reading your own statement here.

3 A. Mostly, yes. First and foremost, I know them in passing. I

4 didn't have a lot of contact with them. The only person that I can really

5 remember and who was not from Sarajevo was a certain Valera from Russia.

6 As for the others, there were all kinds there, but most of them were from

7 Sarajevo and the surrounding villages.

8 Q. You say, and I quote you, "His unit was full of criminals from

9 Sarajevo. It didn't have a particular name. They were known as Seselj's

10 Chetniks from Grbavica." How come Seselj had Chetniks at Grbavica?

11 A. Where did Slavko Aleksic get his Vojvoda title, of which he was so

12 proud?

13 Q. They seem to have distributed titles over there at will. But tell

14 me, as you say that he killed six members of the French Foreign Legion in

15 Sarajevo, did you see his men killing those six people?

16 A. No. I heard this from Slavko Aleksic in person.

17 Q. I see, you heard it from him.

18 A. Yes, from his own lips.

19 Q. Very well. You know of hunters of wartime stories.

20 A. Yes.

21 Q. So do you believe that to be true?

22 A. I think it was true, because later on - I can't remember with whom

23 I was talking; somebody from the military police - as the legionnaires

24 were stationed at the bridge at Vrbanja, because there was an organisation

25 at the time that people from the Serbian side could go to the Muslim side

Page 22113

1 and vice versa.

2 Q. But we've cleared that up. You didn't see him kill those people.

3 A. No. I heard it from Slavko Aleksic himself.

4 Q. I see. So that is what you say.

5 Then you go on to say that a certain Rajo Bozovic was a close

6 associate of Frenki Simatovic. Is it true that you didn't really know

7 this man, that you met him in a coffee bar in Belgrade?

8 A. Correct.

9 Q. Very well. Then you go on to say Dragan Bozovic, known as Giska,

10 he was killed by Zeljko Raznjatovic, Arkan's men. Is it true that you

11 know about this only on the basis of certain stories?

12 A. As it says here, I learnt this from Aco Legija, so not just any

13 stories but from him personally.

14 Q. What I meant was on the basis of what he said.

15 A. Yes, that's right.

16 Q. You also say of him that he was one of those members of the Red

17 Berets who were trained in Knin. Is that right?

18 A. Are we talking about Aco Legija.

19 Q. Yes. And you say that he was about 45 years old, thinning hair,

20 worker's features, as you put it, and he always wore a green beret and a

21 red one only when he reported to Frenki -- or rather, when he calls up

22 Frenki on the telephone, he puts a red beret on his head.

23 A. That's very shallow. I said this because I remember that Aco

24 Legija always wore a green beret.

25 As for Frenki, I was talking about the report that he -- the way

Page 22114

1 he reported to Frenki, that at that time he wore a red beret.

2 Q. But I read out to you what you said here.

3 A. To avoid any confusion, I didn't write anything. I made a

4 statement, which was taken down.

5 Q. Oh, I see. Other people took it down.

6 A. I didn't write anything. I made a statement. And as has been

7 said, during the proofing, when I came here, many details were corrected

8 and I approved of those corrections.

9 Q. Let us move on, then. You mention a certain Gajo, a Montenegrin.

10 You say that he was a Serb extremist, that he blew up a railway bridge in

11 Vrapcici near Mostar.

12 JUDGE MAY: Where is this in the statement?

13 THE ACCUSED: [Interpretation] It's on page 3, Mr. May.

14 MR. MILOSEVIC: [Interpretation]

15 Q. Did you see him do that?

16 A. I know Gajo Crnogorac from the day I was born.

17 Q. I'm not asking you whether you knew him. But you say that he blew

18 up a railway bridge at Vrapcici near Mostar?

19 A. I saw the bridge destroyed, but I didn't see him do it, but I

20 heard it from him.

21 Q. My question was whether you saw it and you said you didn't.

22 A. The bridge was at Vrapcici near Mostar.

23 Q. You say, with respect to some of these people that you list here a

24 moment ago, "I mentioned they went to see Kontic," who of course was not

25 the prime minister in 1990 or 1991 -- you say that they took part in

Page 22115

1 breaking through the Croatian defences in Borovo Selo. That's what you

2 said, and that he hit a truck full of Croatian soldiers with Zolja, a

3 hand-held rocket launcher, and killed everyone except the person sitting

4 next to the driver, who was wounded in the leg and this leg was later

5 amputated. This is the one but last paragraph on page 3.

6 A. That doesn't matter what page it is. First of all, it's not

7 correct that I mention Borovo Selo. I said Borovo Naselje. As regards

8 this story, it comes directly from this man, because I worked in providing

9 security for that man.

10 Q. Now, tell me, please: Did you ever inquire about the actual event

11 in Borovo Selo and what really happened there?

12 A. I didn't really make any inquiries, because as I have underlined,

13 I am apolitical as far as those things are concerned, but I did hear as to

14 what had happened in Borovo Selo.

15 Q. Well, do you know what happened there?

16 A. Yes. I heard of the story that the Croats entered, creating a

17 circus, that there was shooting. I heard that, yes.

18 Q. Do you know that there was no such incident as somebody hitting a

19 truck with a hand-held launcher and killing everyone?

20 A. We are talking about the Kozaracka Street in Borovo Naselje, not

21 Borovo Selo. I underline, Borovo Naselje.

22 Q. You heard all this from somebody; is that right?

23 A. Yes, that is what it says here. It is the story of the person who

24 lost his leg. It is his story and not mine. As far as I know and as far

25 as I was able to see - and I'm not blind - the man really doesn't have a

Page 22116

1 leg.

2 Q. But this need not have anything to do with this. Do you know that

3 then the Croatian policeman who raided Borovo Selo was saved thanks to the

4 intervention of a JNA unit, who made it possible for them to leave

5 Borovo Selo and for the conflicts to quiet down that had broken out then?

6 A. We're talking about two different incidents here. We started with

7 the story about the man without a leg. I was talking about

8 Borovo Naselje.

9 Q. Do you know, since obviously you listened to all those stories

10 about what was going on over there, that groups were organised, groups of

11 Croatian extremists to terrorise Serb populations, to carry out silent

12 liquidations, et cetera? Did you hear anything about that?

13 A. Yes, I did.

14 Q. You mention on page 4, fourth paragraph, a certain Pasko Cibaric

15 from Vukovar. You say that his house was used as a disco club, and that

16 in a well in his yard a certain Seljo threw in two Croats that he had

17 killed. Is this something that you stated on the basis of rumours and

18 stories that you heard from others?

19 A. Since you are mentioning that incident, will you please read the

20 following sentence, in the same paragraph, because it goes on to say that

21 such and such a man told me about this incident, and he personally was

22 working on the renovation of that house where the well is located. So it

23 says clearly on the basis of what I made that statement, it says, "Cibaric

24 Pasko, he's a Croat from Borovo Naselje, Trpinski Put, I believe number

25 31. He fled from Vukovar, and his house was later used as a disco club.

Page 22117

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Page 22118

1 His name, unknown, somebody called Seljo, allegedly killed two Croats and

2 threw them in a well that was in the yard of the house. Later on they

3 covered the well with a concrete slab. Zoran Manov told me about this

4 incident. He was personally working on the renovation of the house and he

5 saw where the well was located. Zoran Manov currently lives in Canada."

6 That is all it says.

7 So I think it is quite clear on what basis I said that. You have

8 Zoran Manov there.

9 Q. Is so this man Zoran Manov who is in Canada he told you he had

10 renovated this house and he found two corpses there? Is that what he told

11 you?

12 A. He told me exactly what is stated here.

13 Q. So even he didn't mention that he saw this but that he heard that

14 this Seljo, whose surname is unknown, threw those two Croats into the

15 well.

16 Now, tell me, please: You speak about Pero Divljak, who allegedly

17 was a member of the Red Berets, and you say - and this is on page 4,

18 paragraph 6 - that he was accused for the criminal act of drug trafficking

19 and that allegedly Franko Simatovic saved him from prison by linking him

20 to Mihalj Kertes, who immediately engaged him to distribute weapons in the

21 Knin theatre of war.

22 A. Yes, that is Pero Divljak's story.

23 Q. Rather an unbelievable story.

24 A. It's his story.

25 Q. The story of this Pero Divljak?

Page 22119

1 A. Yes.

2 Q. And you keep mentioning him. Where is he now?

3 A. As far as I know, the most recent information is that he is in a

4 psychiatric institution.

5 Q. I see. Is it true that at the time when these things allegedly

6 occurred that you spoke about you didn't even know this Pero Divljak?

7 A. Which things?

8 Q. That he was connected to Kertes, Simatovic, and so on. At the

9 time these things were happening, you didn't even know him.

10 A. Yes, that is true.

11 Q. And you're saying that he's in a mental care institution?

12 A. Yes.

13 Q. A man who's a drug addict?

14 A. No, no, he's not a drug addict, at least not in the period I knew

15 him. But on the basis of what I saw with my own eyes and on the basis of

16 what he told me, I'm not in the least bit surprised that he is in a mental

17 care institution.

18 Q. If he's in such an institution, do you then assume that what he

19 told you has to be true?

20 A. Probably, because I saw him in action.

21 Q. Fine. But you don't know, nor you ever saw Kertes, I assume?

22 A. No, I didn't.

23 Q. And did you ever see Franko Simatovic?

24 A. Yes, I did.

25 Q. You claim you saw him with long hair, et cetera?

Page 22120

1 A. That's a paragraph from a statement where it says that I went to

2 Pule and not -- I didn't go to Pule. I went to Rijeka. When I saw him in

3 civilian clothes, he had longer hair. But not as far as his shoulder. I

4 never said that.

5 Q. I didn't say as far as his shoulder. I said long hair.

6 A. I just said he had longer hair. It means it wasn't cut properly.

7 Q. I see. I see. You say that Miroslav Duka was a chief of police

8 in the Serbian Autonomous Region of Herzegovina and that he and

9 Boro Todorovic was tasked with ethnic cleansing in Herzegovina.

10 A. Yes.

11 Q. How do you know that?

12 [redacted]

13 [redacted]. And that is why I ended up the way I did and on

14 the basis of statements of people from Trebinje of Muslim ethnicity that I

15 spoke to in Niksic and all of them remember Duka and the Red Berets.

16 Q. Can we again note that you don't know personally about any of

17 these things but that you heard it from others?

18 A. That is true. I wasn't in Trebinje at the time this was

19 happening. I wasn't.

20 Q. And what were they to have been tasked for any kind of operations

21 over there? You said that he was the chief of police. And what was this

22 other man, this Todorovic?

23 A. In that statement, it says nicely they saw Boro Todorovic only

24 once, [redacted]

25 [redacted]. And it says very nicely that I only saw

Page 22121

1 them once, so that this man in a red beret who I saw then, I didn't -- I

2 have no idea who he was. He ended up in Trebinje. How long he stayed

3 there, what exactly he did, I don't know.

4 Q. Very well. Are we now in -- did we mention in open session that

5 you feared the Red Berets when you left? We spoke about that in public

6 session?

7 A. I don't remember whether it was in open or closed session. I

8 think it was in open session. I really don't know. I have no idea.

9 Q. Please explain to me: It appear that is the lady opposite is

10 confirming that it was in open session -- explain to me, please, since in

11 your statement later on you say that you met -- I mentioned Rajo Bozovic,

12 I don't know who else, in a coffee bar in Belgrade later on. When was

13 this?

14 A. That is the period roughly in 1996.

15 Q. Fine. Now, if they were the Red Berets and you were terribly

16 afraid of them, thinking that they might kill you, how did you dare then

17 go and meet with them, talk to them, when you were afraid of them killing

18 you?

19 A. Regarding Rajo Bozovic himself, I pointed out very clearly that a

20 man showed me Rajo Bozovic. Until then, I had never seen him, nor did he

21 see me.

22 As for my movements --

23 Q. So you didn't see him either, but somebody pointed him out to you

24 and said, "That is Rajo Bozovic"?

25 A. I think that is what it says in the statement.

Page 22122

1 Q. Fine. I just want to establish that. You didn't meet him

2 personally; somebody pointed him out to you and said, "That is that man"?

3 A. That is what it says in the statement.

4 Q. So you were in Belgrade. You had contact with those people, the

5 people you feared.

6 A. No, I didn't contact them. I had no contact with them at all. I

7 was there. That means, as far as the Red Berets are concerned, the only

8 man I contacted was Captain Dragan.

9 Q. Captain Dragan?

10 A. Yes, Dragan Vasiljkovic.

11 Q. But somewhere in your statement - and I'm sure you'll

12 remember - you said that I wrote him a letter of some kind. How can you

13 say something like that?

14 A. I don't claim that you wrote a letter to him. I saw a piece of

15 paper with your signature on it.

16 Q. With my signature?

17 A. Yes, with your signature. And it was an order that was sent to

18 General Perisic, and the unit, I think it's name was Suncokreti, sun

19 flower, at the 4th of July barracks should be disbanded urgently because

20 members of that unit, Captain Dragan's men, were from the camp in Fruska,

21 people from Serbian Krajina --

22 Q. Let me tell you. My position with regard to the paramilitaries

23 has been common knowledge for the past ten years. I consider that they

24 should all be disbanded. But there was no letter or order to

25 General Perisic in this connection. You couldn't have seen something like

Page 22123

1 that, because quite simply it did not exist.

2 A. I saw this with my own eyes from Captain Dragan.

3 Q. All right, fine. So then I suppose the document would have to

4 exist in the general staff, if it existed at all.

5 A. Ask Vasiljkovic.

6 Q. I don't need to ask him. Quite simply, it's not true.

7 Now, let's move on. Although my position was always that the

8 paramilitaries couldn't be tolerated - this was a common stance of mine,

9 well known to everyone; it was no secret - but you mention - and tell me

10 this now, please - a certain man called Duka, Sinisa, in fact, Duka

11 Sinisa, who allegedly exhumed bodies that had been killed by the Red

12 Berets. That's what you say. Now, is it true that you never actually saw

13 anything like that, you never saw him exhuming bodies of any kind, nor

14 that these were the bodies of people killed by members of the Red Berets?

15 A. When those people were killed, that means the very act of killing

16 them, killing these innocent civilians, people who were born in the same

17 place I was born in, I saw that. Sinisa Duka is just like me. He's a

18 Serb who ended up in a Croatian and Muslim prison. The name of the prison

19 was Celovina. And those volunteers, as they liked to call themselves very

20 proudly at that, did this. What they did was that if anybody had a chance

21 of surviving in the prison, they were beaten to death. Because of those

22 killed civilians -- now, I grew up in the same area as Sinisa Duka, and I

23 saw -- I didn't see him actually exhume bodies. I wasn't able to see

24 that.

25 Q. That was my only question to you. That's all I asked you. You

Page 22124

1 didn't see that either.

2 Now, second point: Tell me, please, because nobody in Mostar

3 knows of any kind of mass killing of people which you allegedly saw take

4 place on the embankment, on the river bank of the Neretva River --

5 A. Allegedly, this term of yours, allegedly.

6 JUDGE MAY: Go on. Yes.

7 THE WITNESS: [Interpretation] This term "allegedly" has no place

8 here, because it was more than 100 people. So allegedly" is quite out of

9 order. That's provocation. There's something that cannot be wiped out,

10 and those are the grave, graves that I visited in 1998. And I saw the

11 names and surnames of people whom I knew from those parts. So this

12 "alleged," the term "alleged" that you use, is completely out of place.

13 MR. MILOSEVIC: [Interpretation]

14 Q. So you saw the graves of some people in 1998, did you? I'm not

15 asking you about that. I'm not asking whether you saw graves in 1998.

16 What I'm claiming is that you could not have seen any killings going on in

17 1992, the ones that you said you saw and watched from the roof of some

18 house and that you were watching and saw this man Divljak -- is Divljak

19 his nickname, I assume?

20 A. Yes.

21 Q. That you saw him slaughter some people.

22 A. As far as this fact goes, not to enter into a debate on that

23 point, there's a problem if you wish to prove the opposite. There's a

24 man, he's a man now; he was a child then -- who survived the massacre. And

25 it will be a little difficult for you to prove that nothing actually

Page 22125

1 happened.

2 Q. Let me just explain to you. It is not up to me to prove anything

3 here. It is up to you to prove that what you're saying is the truth.

4 A. Yes, it is true. The massacre existed.

5 Q. How come nobody knows about it in Mostar?

6 A. That's not true. The whole of Mostar knows about it, and it is

7 precisely because of those volunteer units that the Serbs of Mostar that

8 have nothing to do with anything. They were normal people who spent their

9 entire life working from that time on and people who have returned

10 have -- are facing very great problems precisely because of that event,

11 because that is something that the Muslims cannot forget. And I

12 completely understand them on that score.

13 Q. Of course crimes can't be forgotten. If one man is killed, that

14 is a major event. And you say you saw many more of them killed and you

15 say that ten, in fact, in your statement.

16 A. Yes.

17 Q. Yesterday you said you saw 500 killed.

18 A. I didn't say 500.

19 JUDGE MAY: Wait a moment. Just wait a moment. You must pause.

20 Remember the interpreters who have to keep up. If you would both remember

21 that.

22 Yes.

23 THE WITNESS: [Interpretation] I never mentioned the figure of 500.

24 You're trying to put that in many mouth.

25 MR. MILOSEVIC: [Interpretation]

Page 22126

1 Q. You said yesterday, that's what you said, that there were 500 of

2 them?

3 A. What I said was this, and I said it exactly and precisely as we're

4 playing around with words.

5 Q. I'm not playing around with words. I've noted what you said.

6 A. That's not true. I said yesterday that had I -- that I knew at

7 least 500 people from that settlement. That's what I said, I knew at

8 least 500 people from those parts. And the context in which I said this

9 was as follows: I said I couldn't see the faces. I couldn't see the face

10 of the victim and say, "This is Osman or this is Ibro." But in that

11 context, I said that some of the people amongst the people whom I knew

12 were there.

13 Q. All right. Let's not waste time on that. So you said the 500,

14 you mentioned the 500 in a different context, and you said you saw him

15 kill ten; is that right?

16 A. Yes.

17 Q. So you counted this. And these killings were perpetrated by

18 Divljak; is that right?

19 A. I didn't count them. I said at least ten. But as I wasn't

20 watching Pero Divljak alone -- he wasn't alone there. So he wasn't the

21 only one I watched.

22 Q. But I understood it that you were with him all the time.

23 A. No, you're trying to put words into my mouth again. I wasn't with

24 him. You have it precisely described in my statement, where I was, the

25 course I traversed, and why I was there.

Page 22127

1 Q. All right. Fine. Very well. That's just fine.

2 Now, you mention a certain man called Dusan Durutovic, nicknamed

3 Duco, and then another man called Tosa, and you don't know his proper

4 name, but you say that they were instructors in the centre for training at

5 Tara. Did you see these men at Tara, at Mount Tara, the people working as

6 instructors?

7 A. I didn't see them up at Mount Tara. The police uniform and

8 US-manufactured uniforms with red berets -- Dusan Durutovic, yes, I did

9 see him wearing that. Or let me apologise. I mean with the brown wolf as

10 the insignia.

11 Q. So these Brown Wolves, who are they?

12 A. Well, I saw that insignia for the first time at the camp at Buna

13 worn by the Red Berets.

14 Q. The Brown Wolves?

15 A. Yes.

16 Q. So how did you link them up to the police of Serbia?

17 A. It's not up to me to link them up. What I said was that they were

18 wearing the police uniform of Dusan Durutovic. I saw his uniform, and the

19 US-manufactured uniform, I did see that. I saw it in his -- on his

20 premises, behind the discotheque that he was rented out. I think that the

21 discotheque's name was Leonardo, but I can't remember. It was in Samobor,

22 actually.

23 Q. Now, in your statement, you mentioned Captain Dragan a moment

24 ago -- this is on page 10, last paragraph -- and you say you saw him in a

25 cafe in Belgrade.

Page 22128

1 A. Yes. Yes, I did. Yes.

2 Q. How did you get to know him at all?

3 A. Well, I didn't want to meet him. That's the first point.

4 Secondly, the man who is the proprietor of the cafe is part

5 proprietor with a man they call Doc. I don't know what his real name is.

6 But he was a sort of doctor. And he was a member of Captain Dragan's

7 units. And that's how he comes to know Captain Dragan, and that's why

8 Captain Dragan frequented his cafe.

9 Q. Just a moment. You said you talked to Captain Dragan?

10 A. Yes. Yes, I did.

11 Q. Do you claim you talked to Captain Dragan?

12 A. Yes, I do claim that.

13 Q. All right. Fine.

14 JUDGE KWON: Mr. Milosevic, when you cite the statement, could you

15 just indicate the paragraph number handwritten on the left side. Do you

16 have that kind of statement? Yes. Thank you.

17 THE ACCUSED: [Interpretation] Yes. Very well, Mr. Kwon. What I

18 was asking him is on -- on page 10, last paragraph.

19 JUDGE KWON: Yes. That's paragraph 69. We found it. But we

20 would be assisted if you indicate the number, the paragraph number.

21 MR. MILOSEVIC: [Interpretation]

22 Q. On page 6, paragraphs 1 and 2 this time, you speak about the

23 people who were in command of the camp, the Red Berets, a man named

24 Pajzos -- a place called Pajzos. Have you ever been to Pajzos?

25 A. Yes, to Bapska, but not the Pajzos camp itself.

Page 22129

1 Q. So you weren't actually there?

2 A. No, I was not.

3 Q. Now, can you tell me of any operation, any action undertaken by

4 the people in the camp that you were not in?

5 A. I don't see that -- what that's got to do with my statement.

6 Because in my statement, I spoke about an operation undertaken by the Red

7 Berets in the place I was at, so I don't know what Pajzos has got to do

8 with it.

9 Q. Well, I don't know either. That's why I'm asking myself, why do

10 you have in your statement something that has nothing to do with you. You

11 say you weren't there, and yet you speak about people in a camp and a base

12 of some kind of these forces where you never were. Now, you're talk about

13 their activities. So what's that got to do with your statement? That's

14 my question to you.

15 A. I was asked about the camps I knew about and how I came to know

16 about the camps. Now, as to the activities of these people from Pajzos,

17 Zvjezdan Jovanovic, case in point, I know that from another man who was

18 from Ilok, and he was an instructor from the Red Berets from the very

19 beginning. His name was Ilija Vuckovic, nicknamed Rambo.

20 Q. All right. So these different pieces of information you managed

21 to collect from this Ilija Vuckovic, Rambo, person.

22 A. Yes.

23 Q. So that's what you talk about in your statement.

24 A. Yes.

25 Q. So it wasn't on the basis of your own experience or you as an

Page 22130

1 eyewitness but on the basis of what other people told you.

2 A. In my statement, I did my best to underline what was my own

3 personal experience and what I had heard from others. So when they asked

4 me, I explained this in great detail. I said what happened and what I had

5 seen take place, if I was present, and also I said what I had heard from

6 others. I was very careful to do that.

7 Q. All right. But you mention various people throughout your

8 statement. I would have to quote a lot of places. You mention Krajisnik.

9 You've mentioned Martic. You've mentioned Simatovic. Seselj, Maras,

10 Perisic, Ante Roso, Captain Dragan, a host of people here and so on and so

11 forth. And then you tell us what you think about those people. So what

12 has that got to do with anything? What does it matter what you think

13 about Ante Roso, Perisic, Martic, or anyone else? What are you actually

14 saying? What are you stating? Explain that to me, please. I can't

15 understand what you're on about.

16 A. I don't see why you're treating me like somebody working in the

17 Tribunal. I was asked. They asked me what happened and what I know about

18 these events, and I stated that loud and clear. I answered their question

19 very clearly. So it's a simple matter. The people I knew about and whom

20 I saw doing what they did, that's what I said. As to the things I heard

21 about, I underlined this and said I heard about them and we don't have to

22 go into that any more. But I don't know if you know; I don't work for the

23 Tribunal. I don't write the statements. I'm just a witness here.

24 Q. All right. That's a very good answer. Excellent.

25 Now, you go on to say on page 6, the penultimate paragraph --

Page 22131

1 THE ACCUSED: [Interpretation] Mr. Kwon, page 6, one but last

2 paragraph.

3 MR. MILOSEVIC: [Interpretation]

4 Q. You mention a certain man called Tomo Kovac, the Minister of the

5 interior of Republika Srpska. I know the name and I know he was the

6 Minister of the Interior, Tomo Kovac.

7 Now, you say you saw an order which in April 1992 was signed by

8 him, an order of some kind --

9 MS. UERTZ-RETZLAFF: -- Your Honours.

10 THE INTERPRETER: Microphone, please. Microphone.

11 MR. MILOSEVIC: [Interpretation]

12 Q. That called for criminals to be put under RS MUP control, the

13 control of the MUP of Republika Srpska. And you say you saw the document

14 in the Sarajevo -- in Sarajevo in Kula.

15 A. The document that you've just mentioned, I did see in the police

16 station at Kula, and the chief of the police station was, very

17 interestingly, Goran Sehovac, Cena. He was an assistant to the baker.

18 Q. Well, let's not go into the fact of who was a deputy in the police

19 station in Sarajevo. Tell me this, please: What does this mean, that

20 criminals should be placed under the control of the RS MUP? I assume that

21 it is the role of the minister to place criminals under somebody's

22 control, under the control of the police. I assume that that is his task.

23 A. Yes, in a normal state. But down there, it was just one unit that

24 had looted anything it came across. So it was a unit led by a man whose

25 name was Pinjo [phoen]. And I heard about him in Mostar even before the

Page 22132

1 war, because he was such a major criminal, this Pinjo, generally known,

2 and that's why I underlined that the head of the police station was in

3 fact a baker who's in prison now. So you can see what Tomo Kovac had in

4 mind when he wrote this down and said they should be placed in control of

5 the MUP units.

6 Q. Well, as I understand it from all this, he intervened precisely

7 because of the criminal offences that these people were carrying out, and

8 that's his job, as chief of police. It's his job to intervene if

9 criminals are engaged in criminal acts.

10 A. No. First of all, Tomo Kovac, I know him personally, you see, so

11 it's not that I'm -- I haven't heard of him; I know him personally and I

12 can tell you that. He cannot react against criminals because Tomo Kovac

13 is a major criminal himself.

14 And secondly, this unit, when he said that they should be placed

15 under the control of these men, these men were in the MUP unit commanded

16 by this Goran Sehovac, Cena.

17 Q. The one who was a baker?

18 A. Not a baker. He was a deputy baker, even lower down on the rank.

19 Q. All right. Now, page 7, paragraph 5 you mention a man called

20 Ranko. His name was -- his surname was Maglov. Ranko Maglov. And you

21 say he was a commander of the camp in Bruska in Knin. Did you ever go

22 there?

23 A. No.

24 Q. Well, how do you know this, then?

25 A. I can't remember. I can't remember who I talked to. I have no

Page 22133

1 idea.

2 Q. So you don't know how you came by that information?

3 A. I just can't remember. They asked me what I knew about Bruska and

4 that was my answer. It was in the Bruska camp.

5 Q. So they asked you a question. They say: What do you know about

6 such and such a man? And you tell them what you heard from somebody else

7 and that's all?

8 A. No. When the statement was compiled - and I can see that you're

9 very skilled in bypassing what I actually saw and want to base your

10 questions on what I heard - what I said was - and I'm going to tell you

11 this for the last time - I'm going to tell you what I saw and where I was,

12 where I was present. So when they asked me what I heard about, if I said

13 I heard something, then I underlined this. I stressed that I had heard

14 it. So I really don't think there's any need for me to tell you that for

15 the fifteenth time.

16 Q. Well, what you heard about, it makes up 90 per cent of your

17 statement. And I'm asking you because you say you allegedly say --

18 JUDGE MAY: This is a pointless exchange. We've heard the point

19 over and over again, and there's no need to go on about it.

20 Now, have you got any more substantial questions arising from

21 this?

22 THE ACCUSED: [Interpretation] Oh, I do, Mr. May. As far as I can

23 see, this witness testified for about three and a half hours in chief.

24 JUDGE MAY: No. No. It was two and three-quarters, and you will

25 have the same.

Page 22134

1 THE ACCUSED: [Interpretation] Very well, Mr. May. Your arithmetic

2 and mine often do not coincide. But let me go on.

3 MR. MILOSEVIC: [Interpretation]

4 Q. You say on page 8 that a certain Milosevic whose name you don't

5 know but you only know his nickname, Boco, was in direct contact with

6 Simatovic and said that he was coming to Belgrade in order to get weapons

7 and equipment that was needed in Bosnia. Were you ever present during any

8 such contact between this Boco and Simatovic?

9 A. No, not between them personally. No.

10 Q. How do you have this kind of information, then?

11 A. Well, this is a bit slippery, but you got this wrong. I've known

12 Boco since I was born, but I don't know his name until the present day.

13 [redacted]

14 Q. I will not go into all of that. I'm asking you about what you

15 know about his connection with Simatovic?

16 A. I know what he said to me.

17 Q. Oh, what he said to you. Let's go on, then.

18 Then also you say Ribic Nikola, nicknamed Kanada, was he an emigre

19 who had come from Canada?

20 A. He's no emigre. He came for a safari, to hunt people.

21 Q. He came from Canada?

22 A. Yes, as a volunteer.

23 Q. So he lived in Canada?

24 A. Yes.

25 Q. So he came from Canada straight to Bosnia; right?

Page 22135

1 A. Yes.

2 Q. And where did he fight? In which unit?

3 A. I found him in the White Wolves unit. I don't know where he was

4 before that.

5 Q. The White Wolves were a unit of the Army of Republika Srpska.

6 A. Yes.

7 Q. And you say that they were under the direct control of Ratko

8 Mladic, not the commander of the Romanija Corps?

9 A. Yes.

10 Q. So that also has nothing to do with Serbia or any forces from

11 Serbia; is that right?

12 A. I don't understand this question. You asked me about Ribic. You

13 asked me who he was. And I said --

14 Q. I just wanted to establish that.

15 A. I think that this was also highlighted in the statement.

16 Q. You say that a certain Vuckovic, Ilija, was a member of the DB,

17 and that he was in charge of Krajina.

18 A. Yes.

19 Q. Do you know anything about this?

20 A. From him, yes.

21 Q. Oh, from him. Very well. All right. On page 11, in the one but

22 last paragraph, you give information about some men. You talk about Crni,

23 Danijel, Boco, Goran, and you don't know what their names are. Is that

24 right? Or do you perhaps know their names? Can you identify them?

25 A. You are asking me about Boco, Crni. I know these people. I saw

Page 22136

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Page 22137

1 Crni. I never asked him what his name was because I wasn't interested.

2 An absolutely irrelevant person in my life.

3 Q. I don't want to make any assumptions to that effect, as to whether

4 they were important in your life or not. I just want to ask you about

5 your testimony, what you know about these men.

6 A. Crni, I know, was commander of the unit that called itself

7 Vukovarci. They had come with Novica Gusic. I know about Crni, that he

8 was one of the main people involved in the ethnic cleansing of Nevesinje,

9 cleansing of the Muslim population. And Crni, I know he took part in the

10 action in Podvelezje. And that's about it.

11 Q. All right. While we're still on the subject of Mostar, since you

12 say that you were not interested in politics and since you are a Yugoslav

13 by ethnicity, you do not distinguish between people on the basis of ethnic

14 backgrounds, but there were clashes there between predominantly Serb,

15 predominantly Croat, and predominantly Muslim forces; is that right? You

16 know that, don't you?

17 A. Yes.

18 Q. So do you know about these events from 1991 to 1995, how many

19 Serbs were killed in the area of Mostar?

20 A. In the period from 1991 to 1995?

21 Q. In that period when various clashes started, various killings,

22 1991 to 1995. In 1995, the war was over.

23 A. I've already said that as for the killing of civilians or abuse of

24 civilians, I made a statement about that. I can say that while I was down

25 there in prison, there were quite a few civilians there of Serb ethnicity,

Page 22138

1 in the prison that was held by the Croat Muslim forces. As for killings

2 in the surrounding area in the villages, mountains, et cetera, I really

3 know nothing about that. I've already said -- I pointed out that I

4 absolutely was not interested. Had I been interested, I would have gotten

5 out of Mostar, because I did not believe that any such thing could happen.

6 Q. Nobody believed it. [redacted]

7 there were very close relations in Mostar for decades, especially between

8 Serbs and Muslims.

9 (redacted)

10 [redacted]

11 [redacted]

12 [redacted]

13 [redacted].

14 (redacted)

15 Bosnia-Herzegovina, their research centre for investigating crimes

16 committed against the Serb people, and it pertains to Mostar only --

17 THE ACCUSED: [Interpretation] Gentlemen, if you are interested in

18 the truth, I don't know whether you will express any interest in this

19 report at all, but half of this report are lists of persons who actually

20 perpetrated the crimes. I cannot read it, but I'm going to read it to

21 you. I'm going to give you the first name. I won't go any further.

22 Again, they started from A.

23 MS. UERTZ-RETZLAFF: Your Honour, I suggest we go into private

24 session, because we have observed now that even when Mr. Milosevic poses

25 the question quite in a neutral way, the answer is very specific and

Page 22139

1 related to the witness as such and his being in a certain place and --

2 JUDGE MAY: Let's see how we get on.

3 Yes. Ask the question. We'll see how we get.

4 THE ACCUSED: [Interpretation] None of this can identify the

5 witness. I'm reading out of a book of reports. I'm reading the first

6 and -- I can give the second and third names if you wish as well. Abaz

7 Dervo, from Mostar, place of birth, Sarica. Date and place of crime, 7th

8 of April, 1992 in Mostar. Participant in the liquidation of 19 Serbs who

9 were tied up and taken out of Mostar to Herzegovina. They were then

10 killed and thrown into a pit."

11 Then after him, yet another participant. A few of them did this.

12 It wasn't only one man. So it was --

13 JUDGE MAY: Let's deal with these one at a time. One at a time.

14 MR. MILOSEVIC: [Interpretation]

15 Q. Yes. Do you have any knowledge about these crimes? I can give

16 you this book as a present, [redacted]. Half of the

17 book is a report about the criminals who committed these crimes. And

18 since you deal with volunteers, there's even a chapter about volunteers

19 here.

20 JUDGE MAY: Let the witness answer these points.

21 Now, you are being asked about a crime, when it's alleged that on

22 the 7th of April, 1992, it said there was a liquidation of 19 Serbs who

23 were thrown into a pit. Now, do you know anything about any such event?

24 Have you any information as to whether there was such an event or not?

25 THE WITNESS: [Interpretation] I've already pointed out that if

Page 22140

1 we're talking about the beginning of April, that I was in prison. So not

2 even theoretically could I have known about any such thing while I was in

3 prison. As for the book itself, I read it a long time ago, and I know

4 what this is all about. The crime itself that you referred to, I think it

5 took place on the 7th of April. I'm not sure.

6 MR. MILOSEVIC: [Interpretation]

7 Q. Yes.

8 A. I've already presented the reason why I cannot be aware of this.

9 I heard about it, and I -- what I know -- I mean -- I know a lot of Serbs.

10 I have Croat friends, Muslim friends, and I have Serb friends as well,

11 [redacted]

12 [redacted] A lot

13 of people did not manage to get out. And I have already said why I

14 personally cannot know about what happened on the 7th of April.

15 Q. All right, Witness. I hope that you understood me. I gave you

16 the name of the first person on this list of criminals just to give me

17 some information if you know anything about this. But half of the book

18 are perpetrators of these crimes. It's not really a book. It's a report

19 with names. And you say that you saw this.

20 In addition to the introduction where the dates are specified as

21 to what happened when, the next chapter that starts with a list is called

22 "Victims," victims. The total number is 502, 502 Serbs were killed in

23 Mostar at the time. Did you perhaps see any of their graves? Did you

24 establish how any of them were killed? Do you know anything about this?

25 A. I've already said that I know that quite a few Serbs were killed

Page 22141

1 down there, [redacted],

2 [redacted]

3 [redacted]

4 Q. I'm not asking you about mass graves. I'm asking you whether you

5 know anything about these 502 Serb victims in Mostar.

6 A. I probably do, because there have to be people among them who I

7 had known personally.

8 THE ACCUSED: [Interpretation] Gentlemen, if you are interested in

9 the truth, the truth that is quite contrary to this impression that you've

10 gained on the basis of this testimony, I will give it to you.

11 JUDGE MAY: Don't make a speech. At the moment you haven't yet

12 produced that. The witness, to produce it, you can call in evidence in

13 due course, if that's what you want. We'll see.

14 THE ACCUSED: [Interpretation] All right.

15 MR. MILOSEVIC: [Interpretation]

16 Q. You mention on page 13 a certain Major Fico, or a certain Marko

17 from -- Marko Sasovac and you claim that they had trained the Red Berets.

18 Is it correct that you actually never saw these people, actually?

19 A. I saw Major Fico on a cassette, as I said there.

20 Q. Oh, on a cassette. But I asked: Is it true that you never saw

21 any one of them in person?

22 A. Yes.

23 Q. Are you sure that they do not originally come from Krajina?

24 A. Yes.

25 Q. Oh, you mean they are not from Krajina?

Page 22142

1 A. They are not.

2 Q. You're sure about that?

3 A. Yes.

4 Q. All right.

5 THE ACCUSED: [Interpretation] Mr. May, I have to ask the

6 witness -- actually, I have to put some questions to him that have to do

7 with questions that Ms. Uertz-Retzlaff put to him in private session at

8 the very beginning, and they have to do with him personally, so I don't

9 want to jeopardise his identity in any way.

10 MR. MILOSEVIC: [Interpretation]

11 Q. But could you please be as brief as possible in your answers so

12 this private session would not go on for too long.

13 [Private session]

14 [redacted]

15 [redacted]

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17 [redacted]

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20 --- Recess taken at 12.16 p.m.

21 --- On resuming at 12.50 p.m.

22 [Open session]

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

24 JUDGE MAY: Yes, Mr. Nice.

25 MR. NICE: May I interrupt, just to -- before the accused resumes

Page 22146

1 his cross-examination to explain what our position is on timetable for the

2 week. It might help the accused and I can't be here at 2.00.

3 If this witness finishes today, we will hope to deal with

4 tomorrow's witness, Mr. Selak, in one day. If we can deal with him

5 sufficiently briefly in chief, which I hope we can. We would still hope

6 to finish the two other witnesses scheduled for this week on Friday. I

7 hope that's possible. I can best achieve that - and this is why I want

8 the accused to know this in advance - by taking the expert, Dr. Babovic,

9 very briefly, as is allowed for in the rules and doing little more than

10 simply submitting his report with a few supplementary questions. And were

11 it possible for him to be concluded in the first two sessions on Friday

12 and were the application for 92 bis for B-1047, which has been heralded in

13 advance and will be formally before you soon, were that to be granted, we

14 would hope to conclude him in the third session.

15 We realise there has been a little overrun of the witnesses this

16 week, but we are anxious because of forthcoming time-tabled witnesses we

17 are anxious to finish it this week if possible. Obviously if there were

18 any additional time available to us, we would be grateful. But that is my

19 present time.

20 JUDGE MAY: Very well.

21 JUDGE ROBINSON: Mr. Milosevic, you will have until 2.00, which is

22 perhaps some 15 or 20 minutes more.

23 There's a matter I'd like to raise with you. You often refer to

24 Ms. Uertz-Retzlaff as the lady opposite. That's a discourtesy which is

25 gratuitous and it does your cause no good. It doesn't become you. She

Page 22147

1 calls you by your name, Mr. Milosevic, or the accused. You should show

2 her the same respect.

3 I should also say it's a discourtesy to the Chamber, because she's

4 an officer of the Court.

5 Continue your cross-examination.

6 THE ACCUSED: [Interpretation] Mr. Robinson, I very frequently use

7 the name of Mrs. Uertz-Retzlaff. However, it sometimes happens that I

8 forget her name and that is when I use that expression. It is quite true

9 that it is below one's dignity to be insulting and discourteous. That is

10 not at all my intention, regardless of what opinion I have of everyone's

11 role here, of all those present.

12 JUDGE ROBINSON: No explanation needed. Continue your

13 cross-examination now.

14 MR. MILOSEVIC: [Interpretation]

15 Q. Would you be kind enough to explain to me what Mr. Nice said a

16 moment ago? That is, the registrar told me that there would be no changes

17 this week in the order of witnesses. This witness is due to complete his

18 testimony today. Tomorrow we have Mr. Selak planned. And he mentioned

19 several witnesses for Friday. According to my list, there are another two

20 witnesses, no expert witnesses. I don't see when all these can fit into

21 the time available.

22 JUDGE MAY: Let's not take up any more time about it.

23 The order follows that which you already have. The expert who's

24 referred to is a Dr. Babovic, who's an expert on the police.

25 THE ACCUSED: [Interpretation] Very well. Very well. I have only

Page 22148

1 two more questions regarding this witness personally, so I wish that to be

2 clear.

3 [Private session]

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20 [Open session]

21 THE REGISTRAR: We're in open session.

22 MR. MILOSEVIC: [Interpretation]

23 Q. Do you remember, since you lived there, that as early as the end

24 of the '80s, in 1989 and even in 1988, in Western Herzegovina when people

25 were going to the army Ustasha songs were sung and songs in favour of Ante

Page 22151

1 Pavelic?

2 A. I really don't see what that has to do with my statement. But let

3 me try and explain with respect to that. When I say that I come from

4 there, it means that the people from the hills, that we call Brdjani,

5 people in Western Herzegovina and Eastern Herzegovina, what you are saying

6 is quite true, but also Chetnik songs were sung in Nevesinje, not in 1988

7 but in 1980.

8 Q. I just wanted you to tell me whether what I am saying is true.

9 Now, tell me: Is it true that when the HDZ appeared on the

10 scene - you know that is the Croatian Democratic Union - the explanation

11 of Herzegovina was that it was an all-national organisation called the

12 Herzegovina Democratic Union.

13 A. I have absolutely no knowledge about that. Because I've already

14 explained I'm an absolutely apolitical person.

15 Q. And do you know that many people who were not members of the

16 Croatian National Union, in April 1992 had problems with members of the

17 Croatian Armed Forces, the so-called HOS?

18 A. I explained that on the basis of my own example, personal example.

19 Q. So you do have some knowledge on the basis of your personal

20 experience and I assume on the basis of the experience of others as well.

21 A. Yes.

22 Q. And are you aware of examples of members of the HOS going to

23 people's apartments, of those people who did not belong to the HDZ,

24 informing them that all Serbs have to leave Mostar?

25 A. Yes.

Page 22152

1 Q. And tell me, please: Had you heard or do you have any knowledge

2 about it that in April and May 1992 several private improvised camps were

3 established, such as the JNA ambulance? These were established by the

4 HOS. Then the basement of the economics and law faculty in the Aleksa

5 Santic Elementary School, and two legal state prisons, HVO, in Celovina

6 and a HOS prison at the military clinic?

7 A. What you are saying about the military clinic and Celovina, that

8 is one in the same thing. That prison was a private prison of Mensur

9 Cumic. Whether he was linked to HOS or not, I don't know, because I

10 didn't see that man in my course of stay in Mostar. I explained the

11 reasons for this. I had heard about it.

12 As regards prisons, there were prisons on both sides, just as the

13 prison in Bileca was used.

14 Q. Very well. But I'm now asking you about this one. So is it true

15 what I'm saying about these private and what I would call official

16 prisons, penitentiary -- penitentiaries?

17 A. I said which prison I was in, and I had indeed heard about those

18 prisons that you mention.

19 Q. And do you know at least how many -- at all how many prisons and

20 camps there were in which Serbs were detained in Croatia and Bosnia and

21 Herzegovina?

22 A. No.

23 Q. I see. You don't know anything about that.

24 You spoke about a camp -- or rather, a base of the various units

25 at Buna; is that right?

Page 22153

1 A. Yes.

2 Q. And you were shown here the patch of the Serbian Chetnik Movement.

3 A. Yes.

4 Q. My understanding was that you explained that you saw that

5 patch -- I don't mean you personally, but any, any of the citizens who may

6 have been interested could have bought such a patch in the street. It was

7 in circulation as a kind of label or sticker.

8 A. Yes.

9 Q. Since you mentioned the White Eagles, do you know that they have

10 nothing to do with Seselj or the Serbian Radical Party?

11 A. Yes, I do know that.

12 Q. And in that camp, were there various volunteers from various parts

13 of the former SFRY?

14 A. As I have explained and as I said in my statement, the first time

15 I explained how I got there and what I found in that camp. I said, and

16 I'm saying again, that it was a group of criminals collected from here,

17 there, and everywhere, wearing all kinds of uniforms.

18 Q. Very well. You're speaking -- you mention a so-called

19 Boro Todorovic on page 18, paragraph 5, and you say that he was the

20 commander of the operative group 1 of the Red Berets.

21 A. Yes.

22 Q. We have established -- we had established earlier on where they

23 are from, and saying that there was a total of some ten of them. What

24 kind of operative or operational group 1 are you talking about? Is that

25 the group that you spoke about, or is this something else that you talk

Page 22154

1 about here?

2 A. In my statement, I said with precision that I saw Boro Todorovic

3 once on that occasion when I arrived. Boro Todorovic had with him another

4 group, and I don't talk about that group. The group I'm referring to in

5 my statement is the group that stayed at the Boracko Jezero.

6 Boro Todorovic's group, who they were, I have no idea, because that same

7 day they left with the police that had escorted me there. They left to go

8 to Trebinje.

9 Q. Since on page 19 in the last paragraph you say that you were a

10 member of the Red Berets of the Bosnian branch; is that right?

11 A. I never said that I was a member of the Red Berets. I was picked

12 up by force to be a guide. That is how it started.

13 Q. Let me just check something, because I'm not quite sure about it.

14 My emphasis is on the Bosnian branch. Do you know that the Red Berets of

15 Serbia did not even exist at that time?

16 A. That is not true.

17 Q. Did you see any Red Beret members from Serbia?

18 A. Yes.

19 Q. Who did you see?

20 A. All those I listed.

21 Q. Didn't you say that they were people trained by Captain Dragan at

22 the Knin fortress and that they had come from Krajina?

23 A. Yes.

24 Q. Is Krajina the same as Serbia?

25 A. It is not, but it wasn't Dragan Simantic [phoen], but Franko

Page 22155

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Page 22156

1 Simatovic who was also in Knin.

2 Q. Franko Simatovic headed the intelligence administration of the

3 state security service. He didn't engage in what you are saying.

4 A. Yes, yes, yes. But if he was engaging in those activities, the

5 journalists of Express Politika in Knin and he was that at the same time,

6 these two don't go together.

7 Q. People engaging in intelligence can do all kinds of things, as you

8 know very well.

9 You speak about the Eagles and other paramilitary formations. Is

10 it true that General Momcilo Perisic was very angry because of the

11 presence of those paramilitary formations?

12 A. Yes.

13 Q. Do you know that the position of the army was that volunteers can

14 only join the JNA and the Territorial Defence and place themselves under

15 their command, that it would not tolerate paramilitary units?

16 A. No, I don't know anything about that, and I explained why.

17 Q. Very well. In your statement, on page 18, you mentioned the

18 so-called punitive platoon, belonging to the Red Berets and under the

19 command of a certain Zivojin Ivanovic. Were you a member of that platoon,

20 that you have that information?

21 A. No, I wasn't. But Pero Divljak, whose -- whom Zika Crnogorac is

22 and Profa [phoen], Dule Bokser, Samir Catic, they were.

23 Q. All right. As far as I could see from your statement, you base

24 all your information on what you heard from this Divljak; isn't that

25 right?

Page 22157

1 A. That's not right. Not all information. Because you have been

2 asking me here all the time about what I had heard, and that's what I've

3 been answering you.

4 Q. All right. Do you know that this man, Zivojin Ivanovic, Zika

5 Crnogorac, was not in Herzegovina at all?

6 A. That's not correct.

7 Q. Did you see him yourself?

8 A. Yes.

9 Q. Where?

10 A. In Podvelezje.

11 Q. When did you see him in Podvelezje?

12 A. I said at the very outset that it was sometime in July

13 approximately, the same day when I escaped.

14 Q. What does this man look like?

15 A. What he looks like?

16 Q. Yes.

17 A. Well, what can I say about Zika? He's quite tall. He has a very

18 crooked nose. And I had a few close encounters with Zika.

19 Q. Oh, so he's a very tall man. All right.

20 You talk about the plunder of some neighbourhoods in Mostar by

21 reservists, and then you mentioned the White Eagles and you even mention

22 policemen. I assume because you're from the area that you knew these

23 policemen personally.

24 A. As for the policemen themselves, now that we're talking about

25 them, who were under Duka's command, I did know some of them from the area

Page 22158

1 but there were policemen there from Bileca, Nevesinje, Trebinje.

2 Q. All right. But all that is the same region, Mostar, Trebinje,

3 Nevesinje, Bileca. I mean, all of this is within 50 kilometres, isn't it?

4 A. Yes. But never in my life before that was I in Nevesinje, Gacko,

5 or Trebinje, because -- I mean, this part of Herzegovina was simply quite

6 irrelevant, as far as I was concerned.

7 Q. Did you have any possibility whatsoever to personally see some of

8 the looting that they were carrying out?

9 A. Yes.

10 Q. All right. You mean policemen?

11 A. As for policemen -- as for policemen, I have nothing to say

12 really, except to ask them what cars did they drive at the time in 1992,

13 with civilian license plates from Mostar.

14 Q. I'm asking you this for another reason, since you knew these

15 people, you saw them, you knew them, you established that they were

16 policemen from the area, that they were looting. So practically you did

17 not have the opportunity of reporting them to anyone, because you'd have

18 to report them to themselves.

19 A. I have nothing to report to anyone, because everybody who was

20 there - everybody - all these units that I mentioned, were involved in

21 plundering, all of them.

22 Q. All right. When you say "all of them" --

23 A. Yes.

24 Q. -- So you're only excluding yourself; is that right?

25 A. No, not only myself. There were other young men there too, who

Page 22159

1 really didn't take a thing.

2 Q. All right. So not everybody was involved in plundering. You

3 weren't, and there were some others who weren't involved in it.

4 A. There were others too, yes.

5 Q. All right. Let's clarify that too. You mentioned that somebody

6 who was close to me --

7 A. Yes.

8 Q. -- together with some other men at the proposal of an Albanian

9 who was doing his military service killed a Croat in the streets of

10 Mostar.

11 A. Yes.

12 Q. Did you see the killing?

13 A. Yes.

14 Q. Were you in a position then, at least, to approach any members of

15 the military and to report that?

16 A. I don't understand. I, as an individual who is absolutely

17 meaningless there and whose life is in jeopardy, I'm supposed to report

18 that and the captains, the security officers who were there, I mean the

19 regular JNA, Captain Rade Mihajlovic, officially, if he has nothing to

20 report, what have I got to say?

21 Q. Are you trying to say that this Captain Rade Mihajlovic saw that

22 too?

23 A. Yes, yes. He was right there.

24 Q. You saw that too?

25 A. Yes.

Page 22160

1 Q. All right. Tell me, please: You say on page 22 that there was a

2 lot of fighting around the bridge in Lucko. Is it correct that on the

3 other hand, there was some kind of a Muslim fortification, sandbags,

4 machine-guns, things like that?

5 A. Yes.

6 Q. You were sealed off for two hours there.

7 A. Yes.

8 Q. And what happened then? Did you withdraw?

9 A. As for that, this was the second day of the attack, because the

10 first night we came to a place which is called Mali Mejdan. On the other

11 side, the members of the 63rd Airborne Brigade were stuck by Lucki Most,

12 and the same night they were bombed from the hill of Hum by artillery. So

13 they didn't manage to destroy the bridge, it didn't fall all together, but

14 it was half-damaged. It's true that we were sealed off for about two

15 hours. After that, after a lot of gunfire, a tank got out from the Lucko

16 bridge on the side where I was.

17 Q. Tell me, please, since you talk about a meeting between Captain

18 Zoran Pejanovic, Mirko Simic, president of the Serb Democratic Party of

19 Herzegovina.

20 A. Yes.

21 Q. Were you present at that meeting?

22 A. Yes. I was present when Pejanovic was making a speech.

23 Q. And you were not present at the meeting?

24 A. No.

25 Q. How can you testify about the meeting, then?

Page 22161

1 A. I did not testify about the meeting. I testified about

2 Pejanovic's speech addressed to Muslims and Croats.

3 Q. Oh, about Pejanovic's speech. That's what you're testifying

4 about.

5 A. Yes.

6 Q. All right. Is it correct that in the fighting around Bijelo Polje

7 you were ambushed by the Croats when you entered the yard of the military

8 technical institute?

9 A. Yes.

10 Q. They surrounded you and opened fire?

11 A. Yes.

12 Q. Did you actively take part in this fighting around Bijelo Polje?

13 A. It was the first time I used a rifle.

14 Q. You say that the White Eagles, the local Chetniks, raped and

15 killed nuns and civilians at the Catholic monastery in Bijelo Polje.

16 A. I think that it is quite clearly stated in my statement that that

17 is what I heard.

18 Q. Oh, all right. You did not see it yourself?

19 A. No, I didn't.

20 Q. So that knowledge is also based on hearsay.

21 A. That knowledge comes from the Chetniks.

22 Q. Do you know that it was precisely in mid-April 1992, in the area

23 of the municipality of Mostar, that bridges in Grabovica on Neretvi on the

24 road between Mostar, Sarajevo and Rotimlja, on the road between Capljina

25 and Stolac were either destroyed or damaged?

Page 22162

1 A. No. And I explained why I could not know about that.

2 Q. And do you know about the bombing of the village and monastery of

3 Zitomislici?

4 A. If we are talking about the period when the JNA was withdrawing,

5 the 15th of June, yes -- then the answer is yes.

6 Q. So who did the bombing and who destroyed the village and the

7 monastery of Zitomislici?

8 A. I don't know. I was on the other side.

9 Q. Do you know towards the end of April 1992 that the units from

10 Zadar, Sibenik, and Imotski, belonging to HOS arrived at the time?

11 A. I don't know that they arrived. As for the Croatian units, I can

12 only talk about the 114th Split Brigade of Lora, that it was there at the

13 time when we were withdrawing from the Neretva River Valley.

14 Q. So you don't know about the others?

15 A. No, I don't.

16 Q. All right. And do you know about the 29th and 30th of April, when

17 the members of HOS engaged artillery, mortar artillery and gunfire against

18 military facilities, the airport, the northern camp, southern camp, the

19 JNA centre, when Major Branislav Jovanovic was killed and several soldiers

20 were seriously wounded? Do you remember that event?

21 A. No, I really don't.

22 Q. And what was the date mentioned in your question?

23 Q. The 29th and 30th of April.

24 A. I think that at that time I was either in prison down there or in

25 prison on the Serb side. But at any rate ...

Page 22163

1 Q. You don't know anything about that?

2 A. No, I really don't.

3 Q. You don't know that they approached the JNA centre and that they

4 controlled all roads leading to the JNA centre, the members of the HOS

5 did?

6 A. As for the JNA centre itself, I did hear that they were taken

7 prisoner but these same soldiers were released after Perisic threatened

8 that Western Herzegovina would be bombed. That's the only story I know,

9 as far as the JNA centre itself is concerned.

10 Q. All right. Have you heard of mass breakings into Serbian

11 apartments and various people illegally moving into these apartments,

12 people who came predominantly from Western Herzegovina?

13 A. Yes.

14 Q. Did you hear about arrests of ethnic Serbs in April and that they

15 were taken to Grude and other villages in Western Herzegovina where they

16 were exposed to mistreatment?

17 THE INTERPRETER: Microphone, please.

18 THE WITNESS: [Interpretation] As for that period, I've already

19 said that I myself was arrested at the time. There were prisons, yes. As

20 for having people taken to Western Herzegovina, I can say that the people

21 who saved me did so because they heard that they would be transported from

22 Celovina to Dretelj. So I did hear about these transports, but it's not

23 that I personally know of anybody being transported there had.

24 MR. MILOSEVIC: [Interpretation]

25 Q. But you did hear that after this torture in Mostar prisons many

Page 22164

1 Serbs were transferred to other camps, like this Dretelj, the one that

2 you've been talking about?

3 A. Yes.

4 Q. Do you know anything -- this is a former warehouse in Capljina,

5 isn't it?

6 A. As far as I know, I already mentioned that Eastern and Western

7 Herzegovina, before the war, was not a place where I went at all. Dretelj

8 is in Western Herzegovina. The only thing I know about it is that it was

9 used as a concentration camp for Serbs.

10 Q. Do you know anything about the conditions there and about the

11 treatment of people who were detained at Dretelj?

12 A. I know what I heard from people who got out.

13 Q. Just say briefly what you heard from them, from the people who got

14 out?

15 A. Well, these are terrible things, as regards the conditions and

16 mistreatment.

17 Q. And how many of them managed to get out, out of the total number

18 who were detained there, and how many of them forever stayed behind?

19 A. I really don't know, but the majority stayed behind.

20 Q. That is to say, they were killed?

21 A. Yes.

22 Q. All right. You have to know about this, because it happened on

23 the 9th of May, when the village of Pribiloici was victimised and other

24 villages, Vrapcici, Lokve, Hodbina, Blagaj, Potoci, Prigradjani, were also

25 attacked.

Page 22165

1 A. The 9th of May?

2 Q. Yes.

3 A. That's not correct. The date cannot be correct, because all Serb

4 villages that are around Mostar were attacked on the moment -- at the

5 moment when the JNA was withdrawing. Before that, nothing.

6 Q. All right. When the JNA was withdrawing, all the Serb villages

7 were attacked.

8 A. Yes.

9 Q. What happened to these villages?

10 A. Including Mostar, the left bank.

11 Q. All right. Is this information that I have correct, namely that

12 then all these villages were looted and destroyed and many of the local

13 villagers were killed?

14 A. The villages were destroyed and looted; that is correct. It is

15 also correct that people were killed. But how many, that is something I

16 don't know.

17 Q. Have you heard of the attack of the HVO on Goranci and Bogodol,

18 Serb villages when all the men were killed or taken into prison in

19 Santiceva Street.

20 A. Bogodol is a village which is on the road to Western Herzegovina.

21 So it was always, if we can put it this way, it was always part of their

22 territory. And I did hear about all the inhabitants of that village.

23 That they were brought into custody in Mostar. But my information was

24 that they were incarcerated at the mechanical faculty.

25 Q. In prison.

Page 22166

1 A. Yes.

2 Q. Did you hear the massacre of Serb civilians, mostly women,

3 children, and old men, towards the end of May in the neighbourhood of

4 Krusevica in the area of Raska Gora which was carried out by the members

5 of the HOS?

6 A. No.

7 Q. Do you know mean these armed forces of the HOS primarily used

8 multiple rocket launchers to set on fire the Serb Orthodox cathedral and

9 when they destroyed the church in Bilusine [phoen] as well as the old Serb

10 school and old Serb church erected in 1833?

11 A. Since this is an area I know well, the old Serb church was blown

12 up by dynamite, so there weren't any multiple rocket launchers involved.

13 The old Serb church was blown up, also when the JNA was withdrawing from

14 Mostar.

15 Q. Was this down by HOS or by the Muslim forces?

16 A. I really don't know.

17 Q. All right. Do you know that in November 1993 the Croatian forces

18 used tank grenades to destroy the old stone bridge that was the symbol of

19 the town of Mostar?

20 A. Yes, I know about that.

21 Q. Do you know that a lot of the media were accusing the Army of

22 Republika Srpska of having done that?

23 A. Yes, I read about that.

24 Q. Do you know who did that?

25 A. Well, yes, everybody knows. The entire world knows who Praljak is

Page 22167

1 and what he did. So there's no need to discuss it.

2 Q. This is the HOS?

3 A. Well, what formation is concerned, I really don't know. But it is

4 certain that Praljak issued the order. Now, whether they are the HVO or

5 the HOS, I really don't know. As a matter of fact, I don't think it was

6 the HOS, because after Blaz Kraljevic was killed in Western Herzegovina,

7 on the right bank where the Croats were it was the HVO that was in charge.

8 Q. All right, the Croat Defence Council, they did that; right?

9 A. Yes.

10 Q. All right. Do you know when the JNA units from all of

11 Bosnia-Herzegovina withdrew?

12 A. I don't know.

13 Q. But you say they withdrew from the area of Mostar in May 1992.

14 A. No, I gave the exact date, the 15th of June.

15 Q. That is to the best of your knowledge.

16 A. That's what I saw. No. I don't know when they got the order, but

17 the artillery and other heavy weaponry was taken out of the airport in

18 Heliodrom and that's what I saw on the 15th of June.

19 Q. I have very little time left. Now, do you know that the Muslims

20 in mid-June 1992 in Podvelezje massacred Colonel Tomo Pusara who during

21 the preceding months provided protection to them and gave them food

22 supplies and other things they needed? This was a well-known incident.

23 A. Together with him, his driver Sasa Indjic was killed. Yes, I know

24 about that.

25 Q. And do you know that he was -- supplied them with food and

Page 22168

1 protection, supplied them generally in the months that went before that?

2 A. Yes, I did know, but I wasn't actually there in the field during

3 those months.

4 Q. All right. On page 30, you take about a camp, a training camp, in

5 fact, at Boracko Lake. And as far as I was able to understand, they had

6 collected up recruits from Konjic and the villages around Boracko Lake.

7 Is that right?

8 A. Yes.

9 Q. And you say that it was at the lake that you saw Franko Simatovic,

10 who came to visit there; is that right?

11 A. Yes.

12 Q. All right. Now, is it true that you never had any document to

13 officially confirm that you were a member of those formations?

14 A. Yes, that's right. I never did have a document. Neither did any

15 of the others who were there. I'm talking about the guys from Borac and

16 Konjic.

17 Q. Well, that's what I'm talking about too. That's what I'm saying.

18 Those Red Berets that you describe have nothing to do with the Red Berets

19 of Serbia.

20 A. That's not true, because I saw with my very own eyes the official

21 ID cards of state security issued to the name of Pero Divljak, both the

22 red variety and the blue variety.

23 Q. Well, I don't know about your blue and red variety, but this

24 Pero Divljak of yours couldn't have had an official ID card.

25 A. Well, as far as I know from Tito's Yugoslavia, a state security ID

Page 22169

1 card is not a lottery ticket and can't be bought at a kiosk anywhere.

2 Q. Well, of course that's quite true. But he couldn't have had an

3 ID, because as you say, he was a criminal.

4 A. Yes, they were all criminals. There was no difference among them.

5 And as I say, all of them had ID cards. But I happened to see

6 Pero Divljak's.

7 Q. So you saw Pero Divljak's, but you say that he was taken out of

8 the court. I assume that nobody can be taken out of prison without a

9 court order.

10 A. That would be normal in a normal state and country.

11 Q. So what you're saying is that in Serbia we didn't have a proper

12 state?

13 A. That's what I'm saying, in comparison to the former Yugoslavia.

14 Q. And is it true that you were not registered in a single unit in

15 Herzegovina?

16 A. Yes, that's right; quite true.

17 Q. You said you were exchanged.

18 A. Yes.

19 Q. According to my review of the list, your name wasn't on any one of

20 them. Is that true?

21 A. Yes, that's quite true.

22 Q. So how could you have been exchanged without being on any exchange

23 list?

24 A. I said in my statement, and when I read through my statement there

25 was some things that weren't correct. But let me explain. The people who

Page 22170

1 helped me were Croats, in fact, from Mostar. And they had --

2 MS. UERTZ-RETZLAFF: This section was in private session.

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Page 22171

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10 [Open session]

11 MR. MILOSEVIC: [Interpretation]

12 Q. Mrs. Uertz-Retzlaff asked you whether you knew anything about some

13 checkpoints or, rather -- yes, checkpoints, towards Montenegro and in

14 Montenegro.

15 A. Yes.

16 Q. Your answer was - and I made a note of it - "There were countless

17 checkpoints of that sort because anybody and everybody had their

18 checkpoints set up close to their homes, houses."

19 A. Yes.

20 Q. All right. Tell me, if people were guarding their houses and

21 protecting their houses, was it every little nobody who did this living

22 along the border with Bosnia-Herzegovina? Were these all nobodies, as you

23 said?

24 A. Well, the question was: Who were they protecting their homes

25 from? Because it was 50 kilometres in depth of the territory. Now, the

Page 22173

1 reason I called them nobodies - and they are, in fact, nobodies - is that

2 they were people who had left Mostar and had been forced to stay up at the

3 lines, the frontlines, to protect these lines of some sort; whereas, the

4 local ones that made a show of manning the checkpoints to control who

5 knows whom just did that to be able to remain, because they weren't

6 allowed to leave.

7 Q. But you said that everybody had a checkpoint in front of their own

8 houses.

9 A. Well, don't take me literally.

10 Q. All right. Now, you describe at one point when asked

11 directly -- I think you said something to the effect that what was going

12 on had something to do with Belgrade, something along those lines.

13 A. In what connection?

14 Q. Well, you were asked quite specifically how come you knew that the

15 deserters were being arrested in Montenegro, that this had something to do

16 with Belgrade.

17 A. Yes.

18 Q. And your explanation was as follows - and I made a note of

19 that - this is what you said: "In Montenegro, they arrested or the

20 Yugoslav police arrested people in Montenegro. They did the arresting.

21 Whereas, the police of Republika Srpska came up to the border and took the

22 deserters off to prison."

23 A. Yes.

24 Q. Well, my first question is this: In Montenegro, they had the

25 Montenegrin police; right?

Page 22174

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Page 22175

1 A. Well, I can't see it that way, because the period we're talking

2 about, which is 1994, I think Serbia and Montenegro were still called

3 Yugoslavia. Or am I wrong on that score?

4 Q. Yugoslavia, yes. But where do you get this idea from according to

5 which somebody arrests deserters on Montenegrin territory on the basis of

6 an order from Belgrade?

7 A. Ah, well, as far as that's concerned, I explained why. The

8 country's name was Yugoslavia at the time.

9 Q. Yes, that's right. But the Ministry of the Interior, the

10 Ministries of the interior, there was the Ministry of Serbia and the

11 Ministry of the Interior of Montenegro. I assume you know that.

12 A. Well, these are not familiar institutions. As far as I'm

13 concerned. I never had anything to do with the law, so I don't actually

14 know about that. But as you're asking me about these arrests in

15 Montenegro, I can confirm that there were people in prison in Lukavica

16 with me who were brought in from Subotica, Novi Sad, Belgrade, et cetera.

17 Q. That's not what I'm talking about. I'm not talking about whether

18 deserters were arrested. I'm saying that you're drawing the conclusion

19 that these orders came from Belgrade, that Belgrade ordered deserters to

20 be arrested on the basis of the fact that you were actually arrested in

21 Montenegro.

22 A. Yes.

23 Q. All right. Never mind. Let's move on.

24 Is it true that you heard that in this unit, the unit that you

25 mention, under the name of the White Wolves, that mercenaries fought

Page 22176

1 within that unit? Is that true?

2 A. No.

3 Q. Take a look at page 33 of your statement now, please, if you will,

4 the last paragraph, which reads as follows: "At that time during

5 the -- Srdjan Knezevic was in charge of the White Wolves. The White

6 Wolves were made up of mercenaries of many nationalities. For example, in

7 my room, seven different languages were spoken. I remember that in my

8 unit we had people from Russian --

9 MS. UERTZ-RETZLAFF: [Previous translation continues] ... 182, Your

10 Honours.

11 MR. MILOSEVIC: [Interpretation]

12 Q. Naval sabotage unit, for example. Then there were Romanians that

13 had formerly been members of the Securitat, members of a Bulgarian

14 parachute unit, criminals from Cyprus, and local Serbs." So that's what

15 you say. That's the whole paragraph. And I quoted you. It begins, "At

16 that time the White Wolves." And I asked you whether they were

17 mercenaries and you said no. Whereas here you said they were, they

18 comprised of mercenaries.

19 A. I don't know whether you saw the corrections that were made to the

20 statement. Now, as far as these misunderstandings with respect to

21 translations goes, I have nothing to do with that. I know exactly what I

22 said. Now, as far as the criminals were concerned, that is quite true.

23 As for the naval diversionary units from Russia, I said that with respect

24 to Jure Rus, who was one of them, Jure the Russian. So I know exactly

25 what I said. They were not mercenaries. They were people fleeing from

Page 22177

1 something. And Dima was the ex-Securitat member, the Romanian, Dima.

2 That was his story. And what I recounted here was on the basis of what he

3 told me.

4 Q. So do you want to say that this has not been correctly interpreted

5 and you put that correction into the statement, they were not mercenaries?

6 Is that what you claim?

7 JUDGE MAY: He has said that in his corrections, which have been

8 attached to the statement.

9 THE ACCUSED: [Interpretation] All right. We've cleared that up

10 now.

11 MR. MILOSEVIC: [Interpretation]

12 Q. But I must say that this is the first time I hear about all these

13 different nationalities, the Russians, Romanians, Bulgarians et cetera.

14 A. Never in my life did I encounter anything like that until I

15 arrived there.

16 Q. All right. Let's move on, then. So there was one Russian man.

17 A. Several Russians.

18 Q. All right. Several Russians. How many Bulgarians, how many

19 Romanians?

20 A. Two Bulgarians, one Romanian, and several of them from Cyprus. I

21 can't remember exactly. It was a unit which, as I have already stated,

22 was made up of people from outside.

23 Q. Were they volunteers from different countries?

24 A. Well, I can say that they were volunteers as far as the unit was

25 concerned, but I can only say that as far as Srdjan Knezevic himself.

Page 22178

1 Q. All right. Now, is it true that this unit of the White Wolves

2 didn't take part in committing any crimes?

3 A. While I was there, up to my last day, that is true and correct,

4 because the unit was generally stationed in the Treskavica area.

5 Q. So it did not take part in committing any crimes.

6 A. That's right; it did not.

7 Q. And is it true that they were part of the corps, the special units

8 of the Army of Republika Srpska?

9 A. As far as I know, yes, they were.

10 Q. In your statement on page 35 you say that "In the winter of 1994,

11 the White Wolves captured some Muslims who were smuggling cigarettes," et

12 cetera, "and that on that occasion you saw that four men were dead, the

13 fifth was still alive, and he was killed later on allegedly, and that all

14 that had been committed by a man named Petar, one Petar." Did you see him

15 do -- commit all those things?

16 A. Let me put you right first. It says: "In the winter of 1994 was

17 the only time while I was in the White Wolves unit." So the White Wolves

18 never captured anybody. And I'm talking about the time I was there, while

19 I was with the White Wolves in the winter of 1994. What happened was with

20 the police.

21 Q. So they didn't do this.

22 A. The police did.

23 Q. Did you see it happen?

24 A. Yes, I did.

25 Q. That the police committed this?

Page 22179

1 A. Yes.

2 Q. And where was that?

3 A. I can't remember what the place was called exactly. It was a

4 feature of some kind.

5 Q. I'm not talking about this feature, but which local police force

6 was in charge in that area?

7 A. The Trnovo police, in collaboration with the police station of

8 Kula in Sarajevo, because they had a mixed battalion together with the

9 army. I really can't tell you more than that. I can't remember.

10 Q. All right. So these were men from Trnovo and Sarajevo; right?

11 A. Yes, that's right. And I've already said that it was the Sarajevo

12 Romanija Corps which was in charge, as far as I know, of Trnovo, and that

13 they set up this mixed battalion where there were members of the police

14 force and the commander was Cedo Sladoje.

15 Q. All right. I'll skip over a few questions that could disclose

16 your identity. Just tell me this: At the beginning of 1995, you took

17 part in two military operations, one in Mala Orliste and the other one at

18 Debelo Brdo.

19 A. Right, yes.

20 Q. And as far as I was able to gather, there was a strong clash and

21 your unit, as you yourself say, lost 12 men in the space of ten minutes.

22 A. Yes, that's right.

23 Q. So they suffered serious casualties and losses. Is it true that

24 the battles at Debelo Brdo was held without the authorisation of

25 General Ratko Mladic?

Page 22180

1 A. Yes, that's right.

2 Q. Now, tell me this, please: You mentioned a certain man by the

3 name of Ribic, nicknamed Kanada, who when the NATO bombing started

4 captured one or two UNPROFOR soldiers and tied them to the bridge in Pale,

5 seized the UN vehicle, et cetera. Is that right?

6 A. Yes.

7 Q. And taking of hostages at that time was rampant; is that right?

8 A. Yes.

9 Q. So you link this up, as you explained to us today here, to the

10 fact that you saw Stanisic later on and members of the police unit from

11 Serbia?

12 A. I said I heard about that from Captain Cvoro. And it was shown on

13 television, it was broadcast. But the first information I received was

14 from him.

15 Q. All right. Fine. Now, let's clear this matter up. Do you know,

16 are you aware, that Stanisic was sent from -- by me and it was broadcast

17 that he was going as my special envoy to take these people over because we

18 were holding negotiations with the leadership of Republika Srpska, that

19 they had to set the hostages free?

20 A. As far as that is concerned, I can only repeat what I've already

21 said. The first information I received from Captain Cvoro, the rest was

22 broadcast over television, but I didn't attach any importance to it. I do

23 know that Jovica Stanisic was sent from Serbia.

24 Q. Yes, to take over the hostages, or rather, to have them released

25 ultimately.

Page 22181

1 A. Well, in my statement, I describe and state what I know about

2 those events.

3 Q. Well, what it says in your statement is not very clear. That's

4 why I wanted to get clarifications from you, because this was a well-known

5 occurrence.

6 A. What do you want me to explain?

7 Q. Well, you said that they were linked to this taking of hostages in

8 some way.

9 A. No. All I said was that when the hostages were taken and when all

10 this -- this incident began, that the first information that reached me,

11 because Srdjan on that same day in the evening went to be informed at

12 Lukavica of this event. At that time, I myself went to the military

13 police building. And the first information that reached me as to the

14 takeover of the hostages by Jovica Stanisic or whoever was the envoy sent

15 to do that, I heard this from Captain Cvoro. That's all that I say in my

16 statement; nothing more than that.

17 Q. Well, did you hear that they had been sent to take over the

18 hostages and release them?

19 A. As to the release of hostages, no. But that they had been sent to

20 take over the hostage, yes.

21 Q. They were not there with any unit. All he had was his own

22 security detail. Because the agreement on the release of hostages had

23 been reached by political means. There was no combat operation there. Are

24 you aware of that?

25 A. I didn't hear of any combat operations in that connection, nor did

Page 22182

1 I see any of them to be able to claim anything.

2 Q. Very well. You said on page 38 that members of the DB of Serbia

3 confiscated the equipment that your unit had taken from the UNPROFOR

4 soldiers. That is, you had to return the equipment that you had taken

5 from UNPROFOR. Is that right?

6 A. As far as that is concerned, that is the specific unit of which I

7 was a member. I know that Srdjan received an order to return the jeeps,

8 because it was the jeeps that were most frequently taken. As far as the

9 state security of Serbia is concerned, I must repeat: All I know is what

10 I heard from Cvoro, because they confiscated equipment from everyone.

11 This was a whole wave of hostage-taking from Pale to Sarajevo.

12 Q. And the had to return all that back.

13 A. Yes.

14 Q. I'll leave out a number of questions relating to you personally,

15 because we don't have time to go into private session again.

16 On page 40, you say that a friend of yours who was working in the

17 security of a certain person, who was not a state official - I won't

18 mention the name so as not to reveal your identity - told you that I,

19 after coming to power, wanted to form a unified Serbian police. Did they

20 entrust this task to this friend of yours?

21 A. I just said here what he told me. I didn't say that you had

22 entrusted him with that task. It says here quite loud and clear that he

23 told me that.

24 Q. Very well. On pages 41 and 42, you mention the camp at Knin, the

25 Knin fortress, Fruska Gora, Golubic, Bruska, Jodankovic [phoen], Kula, in

Page 22183

1 Vojvodina, Lokor -- no, Tara, Mitrovac. Did you personally see all those

2 training centres?

3 A. I really think it's clear. I can't keep on explaining one and the

4 same thing 50 times. I stated quite loud and clear how I know about those

5 camps.

6 Q. Very well. So you know nothing about the Knin fortress or who was

7 in command in Knin or who was in command of the Red Berets in Knin as

8 early as 1990, where they were.

9 A. What I know, I said how I learnt about it and from whom. So most

10 of those stories come from Pero Divljak and members of the Red Berets who

11 were there at the Boracko Jezero or lake. So I heard all these things

12 from them.

13 Q. I see, so you heard everything from them. But let's hurry up to

14 clear up a few more points. You spoke about various civilian lorries

15 coming to the warehouses at Pale, et cetera.

16 A. Yes.

17 Q. And that this was very frequent.

18 A. Yes.

19 Q. Do you know how much aid in food, clothing, medicines, and every

20 other necessity for the life of people was sent from Serbia? Where did

21 your assumption come from that those lorries were bringing weapons and

22 ammunition?

23 A. I don't know. But, for instance, if I see a bullet with the

24 inscription "PPU" 1994, standing for Prvi Partizan Uzice, as far as I know

25 Uzice is in Serbia, or maybe I'm wrong.

Page 22184

1 Q. There's no need for any sarcasm. The PPU is a factory

2 manufacturing ammunition. It was well known in the world, not only in

3 Yugoslavia. So that is not at issue at all. You could have found those

4 bullets in any warehouses.

5 A. Yes. But the year is important.

6 Q. I don't believe that you saw that year. I think you made it up.

7 A. I don't think so.

8 Q. On the contrary, I know that they had problems in the Army of

9 Republika Srpska because the munition that they had there and most of --

10 largest warehouses of equipment and ammunition from the former SFRY were

11 in Bosnia -- they had problems --

12 JUDGE MAY: You're just wasting time, you telling the witness what

13 you claim to know about. He's told you what his evidence is. Now, you've

14 got two minutes left.

15 THE ACCUSED: [Interpretation] If I only have two minutes left -- I

16 just need to leaf quickly through my notes.

17 MR. MILOSEVIC: [Interpretation]

18 Q. Kasindol, you saw Mauzer and representatives of the Army of

19 Republika Srpska Krajina; is that right?

20 A. I saw Mauzer in Kasindol, and representatives of the Republic of

21 Srpska Krajina I saw at the Kosuta Hotel.

22 Q. I see, both. This one was from Bijeljina and the other from the

23 Republic of Serbian Krajina.

24 A. Yes.

25 Q. And there was a unit called Scorpions. Where did you get the idea

Page 22185

1 that this was a unit of the MUP of Serbia?

2 A. That is information I received from people I spoke to. And it

3 says in my statement who I talked to up there.

4 Q. Very well. Let me just clear up one point, which I think has some

5 broader significance. You spoke about Perisic's speech when the JNA was

6 withdrawing from Mostar.

7 A. Yes.

8 Q. And then you said that the people who were from the area and who

9 wanted to stay behind could stay behind and that they could keep their

10 weapons; is that right?

11 A. Yes.

12 Q. Was -- were they, the people who were later transformed into the

13 Army of Republika Srpska?

14 A. As far as I know, yes.

15 Q. So the JNA withdrew or, rather, pulled out. The soldiers who were

16 from the territory of Serbia and Montenegro left. Whereas, the people

17 from the area stayed behind with their equipment and that was the way in

18 which the Army of the Republika Srpska was formed; is that right?

19 A. Yes.

20 Q. Well, it is very important to establish that.

21 JUDGE MAY: One more question.

22 MR. MILOSEVIC: [Interpretation]

23 Q. You mentioned that the Red Berets participated in certain battles

24 around Zeleni Jadar and Srebrenica. When was that?

25 A. That is what I saw on the map, the map of Zeleni Jadar, Rudnik,

Page 22186

1 Osmaca, Zepa, and Srebrenica, the whole area, was in Srdjan Knezevic's

2 office.

3 Q. When did you see that?

4 A. While I was there. That was in 1995 -- no, I'm sorry, 1994 in the

5 winter. And this operation, I think, took place in 1993, around

6 Christmastime, because at that time --

7 Q. I just wanted to clear up that your mention of Srebrenica has

8 nothing to do with the events in Srebrenica in 1995.

9 A. No, it hasn't.

10 Q. Very well. Thank you.

11 JUDGE MAY: Mr. Tapuskovic, we have word that this witness must

12 leave today, so we'll have to limit the time. If you can deal with it in

13 five minutes and we'll give the Prosecution five minutes to re-examine.

14 MR. TAPUSKOVIC: [Interpretation] Your Honours, give me, please, at

15 least a couple of minutes more, because there are so many topics. I have

16 chosen only two which I think are important.

17 I should first like to ask the Witness C-017, with all due respect

18 for his right to express himself in accordance with his feelings, which

19 is -- which every individual is entitled to, when he was asked what

20 ethnicity he was, he said he was a Yugoslav. At a time when there is even

21 no third Yugoslavia left. But that is not why I'm asking him this.

22 Questioned by Mr. Tapuskovic:

23 Q. [Interpretation] On the 17th of May, 2000, that is three years

24 ago, when he was asked as to what ethnicity he was, he said he was a Serb.

25 And today he says he's a Yugoslav, when even the last Yugoslavia no longer

Page 22187

1 exists. How can he explain that?

2 JUDGE MAY: Well, it doesn't matter. Does it really matter now,

3 how he describes himself?

4 But since you've been asked, just briefly.

5 THE WITNESS: [Interpretation] No problem. Even then I declared

6 myself to be a Yugoslav. However, when my statement was taken, they asked

7 me specifically what nationality I was.

8 MR. TAPUSKOVIC: [Interpretation]

9 Q. Thank you. Thank you. In the examination-in-chief, you said that

10 in May 1991 you were in a barracks in Zagreb and that fire was opened on

11 JNA soldiers that were killed in front of the barracks and that the

12 barracks was surrounded; is that right?

13 A. Yes.

14 Q. And you also said that you didn't know whether other barracks in

15 Croatia were also surrounded.

16 A. Yes.

17 Q. But in your statement here- this is paragraph 49 of the English

18 version- you spoke about the liberation of the JNA barracks in Capljina.

19 Was that barracks in Capljina surrounded for it to have to be deblocked?

20 A. The barracks in Capljina, which was the operation of the parachute

21 brigade in 1993, that is not in Croatia. It's in Bosnia-Herzegovina.

22 Q. Yes, that is slightly south of Mostar, near Neum. Was that

23 barracks surrounded and then the barracks had to be liberated, as well as

24 the men inside?

25 A. I don't know what exactly happened inside, but I do know that the

Page 22188

1 parachute unit performed an assault attack.

2 Q. You spoke about what happened to you in Slovenia and you said you

3 couldn't defend yourself because you had rubber bullets.

4 A. Yes.

5 Q. Do you know that many soldiers were killed in Slovenia because

6 they didn't have combat ammunition?

7 A. I didn't hear about it. I watched it. They were given -- they

8 weren't given the proper ammunition to be able to defend themselves.

9 A. I personally spent more than two hours lying under a tank or an

10 armoured vehicle - I can't remember which - for more than two hours.

11 Q. Is it true that in order to calm things down you spoke to former

12 JNA officers who had abandoned the JNA and joined Slovenian Territorial

13 Defence?

14 A. I can confirm that quite a number of officers switched sides while

15 I was still there. But who spoke to whom, I don't know. Who negotiated

16 with whom, I don't know.

17 Q. Did the same apply to the people living in Bosnia with the JNA.

18 When they switched to the Bosnian army in Krajina though they had

19 personally been members of the JNA?

20 A. Yes, I heard about that.

21 Q. I have something to ask you in connection with paragraph 175. You

22 were saying that the Muslims managed to get some artillery weapons and

23 other equipment partially from what the JNA had left behind and partially

24 from what they were given by the Croats. So do you know that out of the

25 weapons that the JNA could not take with it the Muslim army kept for

Page 22189

1 itself a part of the weaponry of the JNA?

2 A. Yes.

3 Q. And what about this reference to what was given to them by the

4 Croats?

5 A. I have no idea what exactly they were given by the Croats, but I

6 know that in those days they were acting together.

7 MR. TAPUSKOVIC: [Interpretation] Your Honours, I really don't have

8 enough time, though I would have many questions of interest to you and my

9 time is limited, so I'm forced to refer to something in paragraph 156,

10 which has already been discussed. But I need to come back to it.

11 I would like to ask Your Honours to bear in mind points 4 to 7 of

12 the indictment, paragraphs 36, extermination, killings, and murder, and

13 the Prosecution has not given any information linked to this event that

14 the witness witnessed. I think this needs to be assessed, especially in

15 the light of what he said. And he said the following: "I saw

16 Pero Divljak killing with a knife at least ten civilians. I saw numerous

17 men being stabbed several times, then thrown on the ground and shot

18 several times with a pistol."

19 Q. Is that what you saw?

20 A. I don't know how it's written down there, but all the acts that

21 you have enumerated I saw myself.

22 MR. TAPUSKOVIC: [Interpretation] I would just like the Prosecution

23 to provide evidence of some such thing happening, any of these things

24 actually happening, nothing more than that.

25 JUDGE MAY: The witness has given evidence about it, and we'll

Page 22190

1 have to assess it in due course.

2 MR. TAPUSKOVIC: [Interpretation] Thank you.

3 JUDGE MAY: Yes. Five minute, please, Ms. Uertz-Retzlaff.

4 MS. UERTZ-RETZLAFF: Your Honour, I have only one question to the

5 witness, and it actually refers to that massacre that he has described and

6 of which Mr. Milosevic mentioned to you during cross-examination it didn't

7 take place, and only -- because we didn't have much time to check, I can

8 only provide something to the witness. It's an official report that we

9 have in our rules of the road files. It's about Mostar and the mass

10 graves in Mostar. And unfortunately, we don't have any -- any Serbian

11 version because we didn't think it would come up in this way. But the

12 witness can read English.

13 Re-examined by Ms. Uertz-Retzlaff:

14 Q. And actually, the only thing I wanted to refer you to, witness, is

15 the reference on page 3, the mass grave --

16 JUDGE MAY: Let's have copies of it, please.

17 MS. UERTZ-RETZLAFF: Yes. It's a document called "Mass grave in

18 Mostar," and it's obviously a report that we have in our rules of the road

19 files. And it's a chronology of events with some mass graves.

20 Q. And I only would like you to look at the mass graves Uborak

21 [phoen], mentioned on page 3. And it says here, "On August 27, 1992, the

22 examination -- exhumation of 88 killed civilians at the city garbage dump

23 Uborak in the northern part of the town began. All the deceased were

24 civilians from the city quarters of Vrapcici, Kutiljevac, and Zalik." And

25 there is a list of 54 names of, as I can see, mostly Muslim people. And

Page 22191

1 if you look through this -- briefly through this list of 54 of the --

2 JUDGE MAY: Well, can we know, first of all, where Uborak is?

3 MS. UERTZ-RETZLAFF: Yes.

4 Q. Do you know -- yes. Witness, can you answer this? Uborak, where

5 is it? It says in the northern part of the town.

6 [redacted]

7 [redacted]

8 [redacted]

9 Q. And if we look at tab 4, that's actually the location --

10 MS. UERTZ-RETZLAFF: Can we have the witness briefly shown tab 4.

11 That's the sketch of the event.

12 Q. We have here, as you had indicated, a little circle. And it says

13 here Bakina Luka. Is that what is now referred to as Uborak?

14 A. It is the area stretching from Bakina Luka upwards. It is this

15 area here. I don't know how to explain it to you, but it is this region

16 over here.

17 Q. It's the wider region, as you just showed, the wider region,

18 upwards this word "Bakina Luka" at the river banks. And it refers here to

19 three different quarters, city quarters. Those three quarters, where

20 would they be? We have here only Zalik indicated on this map, tab 4. But

21 the other two, where would that be?

22 A. I don't understand. Which other districts are you referring to?

23 When I was testifying about the massacre, I spoke only about Zalik.

24 Q. Yes. But in this document where you find this sentence with the

25 mass grave Uborak, there's a reference to Zalik but also to other places,

Page 22192

1 that is Vrapcici and Kutiljevac. Where would that be?

2 A. Excuse me, my mistake. I was looking at the map. Vrapcici and

3 Kutiljevac are on the road from Mostar towards Sarajevo. These are the

4 first two districts on the outskirts of the town.

5 Q. And is that close to Zalik? Would we see that on --

6 A. Yes, yes.

7 [redacted]

8 [redacted]

9 [redacted]

10 [redacted]

11 MS. UERTZ-RETZLAFF: I think that we should stop now. And no

12 further questions.

13 JUDGE MAY: Yes. Dealing with these documents. First of all --

14 MS. UERTZ-RETZLAFF: Oh, Your Honour, I forgot. I would like to

15 tender this documents.

16 JUDGE MAY: I'm just going to deal with it. I'm not sure we're in

17 the position to accept this as a document. We might mark it for

18 identification, since we've got absolutely no evidence as to what it is.

19 Let's just let me consider.

20 [Trial Chamber confers]

21 MS. UERTZ-RETZLAFF: Your Honour, I'm just -- just to inform you,

22 I was just told that this document comes from the Mostar cantonal court.

23 It was sent to the Prosecution office as the rules of the road file and

24 the -- there is Ivica Kostovic who signs this.

25 [Trial Chamber confers]

Page 22193

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Page 22194

1 MR. KAY: If I can just raise a matter. Evidentially at this

2 stage, in my submission, the witness can -- can mention a name and confirm

3 something in the document, but I don't think that it causes then the

4 document to become an exhibit, because it has no real reference point from

5 this witness in his testimony. We simply don't know where it came from,

6 where it arose, what it's to do with.

7 JUDGE MAY: Well, we've just heard it's from the court. It would

8 seem to me that if some evidence can be produced that it is from the

9 court, it's admissible. At the moment, we've merely got something to the

10 effect that it's from the head of the department of information and

11 research. If that can be confirmed in some way, that it comes from the

12 court, we'll admit it. I suggest what we do at the moment is we mark it

13 for identification, we give it the next exhibit number.

14 [Trial Chamber and registrar confer]

15 THE REGISTRAR: Your Honour, Prosecution Exhibit 461, marked for

16 identification.

17 THE ACCUSED: [Interpretation] Mr. May.

18 JUDGE MAY: Yes, Mr. Milosevic. Yes.

19 THE ACCUSED: [Interpretation] This document speaks about people

20 who were buried. It cannot automatically be linked to an event that the

21 witness saw.

22 JUDGE MAY: No, we recognise -- let me interrupt you. We

23 recognise that. All it can do is to prove, if it's admitted, which at the

24 moment it isn't - it's merely marked for identification - all it can prove

25 is that there was an exhumation. Now, whether we choose to link it with

Page 22195

1 the event or not will depend on other evidence. It's no -- worth no more

2 than what it actually says. That's the case with any form of evidence.

3 We've also got here - let me deal with this next - the statement.

4 I must say, speaking for myself, I don't think we really need it

5 exhibited. And in those -- unless -- Mr. Kay, do you want to say

6 anything?

7 MR. KAY: No, I don't think it should be exhibited.

8 JUDGE MAY: No, we don't think it's taken things far enough.

9 What we'll do is return the statement and withdraw it from the

10 bundle.

11 Let me make one final point before we let the witness go. To

12 those watching and those reporting the proceedings today, that references

13 to where this witness is from have been redacted and should therefore not

14 be reported.

15 Witness C-017, that does conclude your evidence. Thank you for

16 coming to the Tribunal to give it. You are free to go.

17 THE WITNESS: [Interpretation] Thank you.

18 JUDGE MAY: Yes. We'll adjourn until tomorrow morning.

19 --- Whereupon the hearing adjourned

20 at 2.18 p.m., to be reconvened on Thursday,

21 the 12th day of June, 2003, at 9.00 a.m.

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