Tribunal Criminal Tribunal for the Former Yugoslavia

Page 27754

1 Tuesday, 21 October 2003

2 [Open session]

3 [The accused entered court]

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

5 JUDGE MAY: The protections for the next witness which have been

6 applied for will be granted.

7 While we're waiting for the witness, I will deal with some

8 administrative matters dealing with hearings at the end of November and

9 the beginning of December.

10 The week commencing Monday the 24 of November contains a UN

11 holiday on Wednesday the 26th of November. To accommodate this, the

12 hearings that week will be on Monday the 24th of November, Tuesday the

13 25th of November, and Thursday the 27th of November.

14 Judge Robinson will not be able to attend the hearings on Tuesday

15 the 25th and Thursday the 27th of November for medical reasons; therefore,

16 Judge Kwon and I will be sitting alone on those days under the Rule.

17 In the week of Tuesday the 2nd to Thursday the 4th of December,

18 the hearings will take place as usual on Tuesday to Thursday, but Judge

19 Robinson, for the same reason, cannot attend those hearings, and Judge

20 Kwon and I will sit alone.

21 In the week commencing Monday the 8th of December, there is a

22 Plenary meeting of the Judges and therefore there will be no hearings on

23 those days. That is Thursday the 11th and Friday the 12th of December.

24 The Trial Chamber will therefore sit that week on the days of Monday the

25 8th to Wednesday the 10th of December.

Page 27755

1 Yes. Is there anything before the witness comes in?

2 MR. GROOME: Just two preliminary matters, Your Honour. I will

3 not be seeking to lead any evidence in closed session. I would ask that

4 if the amici or the accused wish to inquire about the specific position

5 that this gentleman held in the municipality, that that be done in closed

6 session.

7 I'd also ask that his -- his wife and his daughter were both

8 subjected to prolonged and extremely grievous sexual abuse. I would ask

9 if that is going to be inquired into that that be done, out of respect for

10 those family members, that that be done in closed session.

11 And I would ask that a binder containing three exhibits be

12 assigned a number at this stage.

13 JUDGE MAY: Yes. And I understand there is a matter of a ruling

14 under Rule 92 bis in relation to this witness which has not been dealt

15 with. In fact, we had made the ruling but no written form had appeared.

16 That will be granted.

17 [The witness entered court]

18 JUDGE MAY: Yes. Let the witness take the declaration.

19 THE WITNESS: [Interpretation] I solemnly declare that I will speak

20 the truth, the whole truth, and nothing but the truth.

21 JUDGE MAY: If you'd like to take a seat.

22 THE WITNESS: [Interpretation] Thank you.

23 WITNESS: WITNESS B-1122

24 [Witness answered through interpreter]

25 JUDGE MAY: And we will have the exhibit number, yes.

Page 27756

1 THE REGISTRAR: 566, Your Honour, with tab 1, 2, 3 under seal.

2 Examined by Mr. Groome:

3 Q. Sir, you have been granted -- sir, you have been granted

4 protective measures pursuant an order of the court. You will therefore be

5 referred to as B-1122 during the course of your testimony here. I would

6 ask you to begin your testimony by taking a look at tab 1 of Exhibit 566

7 and tell us whether you recognise that document.

8 A. Yes.

9 Q. Is that your name at the top of that document and is it also a

10 brief summary of your professional and educational background?

11 A. Yes.

12 Q. I'd ask you now to take a look at tab 2 of that document. It is a

13 two-part document, an English translation of a statement and a statement

14 in the B/C/S language. Do you recognise whose statement that is?

15 A. Yes. It's my statement.

16 Q. And after coming to The Hague, did you review that statement and

17 notify the Office of the Prosecutor of some corrections that you wished to

18 make?

19 A. Yes.

20 Q. I'd ask you to look at tab 3 of that binder, Exhibit 566, and ask

21 you, is that an addendum to your statement, making several corrections to

22 your original statement?

23 A. Yes. Yes, this is it.

24 Q. I'd ask you to return to tab 2, page 11, and my question to you

25 is: Is that your signature on that page?

Page 27757

1 A. Yes.

2 Q. And did you initial every page of that statement?

3 A. Yes.

4 Q. And do you verify the truthfulness and the accuracy of that

5 statement here now being a sworn witness?

6 A. Yes, I do.

7 Q. I would ask you to once again turn to tab 3 and if you would look

8 at the second page in tab 3. Is that also your signature to the addendum

9 of your statement?

10 A. Yes, it is.

11 Q. And now being a sworn witness, do you verify the truthfulness and

12 accuracy of that statement?

13 A. Yes. Yes.

14 MR. GROOME: Your Honour, pursuant to Rule 89(F), I would tender

15 both tabs 2 and 3 into evidence.

16 JUDGE MAY: Very well.

17 MR. GROOME:

18 Q. Sir --

19 JUDGE MAY: Just help us with the atlas so we can find this. I

20 think this is the first witness from this municipality.

21 MR. GROOME: Your Honour, my apologies. I don't have our copy of

22 the atlas here. Perhaps I could ask the witness to explain where

23 geographically Gacko is located and then I'll have a page reference for

24 the Chamber at the break.

25 Q. Sir, can I ask you to describe for the Chamber where Gacko is

Page 27758

1 located in Bosnia-Herzegovina.

2 A. Yes. Gacko is in Eastern Herzegovina. The neighbouring

3 municipalities are to the north Foca and Kalinovik, to the east

4 Montenegro, to the south Bileca and Stolac, and to the west Nevesinje.

5 Q. Sir, the Chamber is in possession of your statement which is a

6 full account of the events as you witnessed them in Gacko. I want to ask

7 you some specific questions regarding that evidence.

8 The first question I would like to ask you is: In your statement,

9 you describe the presence of White Eagles in Gacko, and could I ask you to

10 identify the earliest period in time when you saw White Eagles, members of

11 the White Eagles in Gacko?

12 A. It was in March 1992.

13 MR. GROOME: Your Honour, in the atlas reference is page 33,

14 sector D3.

15 JUDGE MAY: We have it, thank you.

16 MR. GROOME:

17 Q. And sir, how were you able to identify them as White Eagles?

18 A. They wore the White Eagle insignia on their sleeve here.

19 Q. Now, during the course of the time that they were in Gacko, can

20 you describe or did you form an opinion with respect to the relationship

21 between the White Eagles and official members of the JNA?

22 A. Well, you see, when the White Eagles arrived in Gacko, they were

23 quartered in the barracks 3 kilometres to the east of Gacko, and these

24 were barracks used by the Yugoslav army. And then we could see them

25 socialising in town, going to cafes together. I think they acted together

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Page 27760

1 as far as we could see, completely.

2 Q. Did you make any observations with respect to the weapons that

3 were carried by these members of the White Eagles?

4 A. Yes, I did. They wore -- they carried Yugoslav army weapons,

5 mostly automatic rifles. They also had heavy weapons, mortars. They had

6 guns. One could see that when they went off to the Mostar battlefield.

7 They had uniforms and all the logistics of the JNA, and this was obvious.

8 Q. Now, I'd like to jump ahead to a meeting that you describe in your

9 statement on the 28th of April, 1992, a meeting that was held with General

10 Momcilo Perisic. Can I ask you to summarise to the Chamber what, if any,

11 assurances the Muslim community sought from General Perisic; and secondly,

12 what assurances did he give the Muslim community?

13 A. I remember there was a meeting of representatives of the Serb and

14 the Muslim peoples, and this meeting was also attended by General Perisic,

15 who was commanding operations near Mostar. In view of the fact that some

16 events had taken place in Gacko, violent events against the Muslims, the

17 Muslims asked General Perisic to guarantee that he would protect the

18 civilian populations. There were only civilians there.

19 General Perisic addressed the meeting promising this, and the

20 representatives of the Muslim side asked about the paramilitary

21 formations. They asked who the White Eagles were and what they were doing

22 in Gacko, because General Perisic said that in his area of responsibility,

23 he would not tolerate any sort of paramilitary organisations. When he was

24 asked about the White Eagles and who they were, he didn't give a reply,

25 but he did promise to protect the civilian population in the area of

Page 27761

1 Gacko. However, he failed to keep his promise.

2 Q. Now, the day after General Perisic said that he would not permit

3 paramilitaries in the area, what, if anything, happened to the members of

4 the White Eagles in Gacko?

5 A. I know that representatives of the Bosniak side told General

6 Perisic about the activities of the White Eagles, and on the following

7 day, the White Eagles went to the Mostar front, and on their way through

8 the town, they started firing wildly on the main square. They fired

9 shots, a lot of shots, and then they went to the Mostar front. I don't

10 think that they stayed in Mostar long, only about a week. And after that,

11 they came back to Gacko, and again they were quartered in the barracks,

12 the military barracks.

13 Q. So the day after General Perisic addressed the combined Serbian

14 and Muslim communities, the White Eagles left for a period of about a week

15 before returning to Gacko; is that correct?

16 A. Yes. Yes.

17 Q. Now, if I can draw your attention to the 1st of June, 1992. Your

18 statement refers to another meeting, a meeting with Colonel Parezanin of

19 the JNA. Can I ask you to summarise for the Chamber what it was

20 Colonel Parezanin said to the people assembled or people present at that

21 meeting?

22 A. On the 1st of June, 1992, arrests of the Bosniak population in

23 Gacko began, and on that day there was another meeting between

24 representatives of the Serbs and Muslims or, rather, Bosniaks, and in the

25 morning, this was in the Municipal Assembly, and in the afternoon in the

Page 27762

1 police headquarters.

2 While the meeting was going on, a gentleman came in and said he

3 was Colonel Parezanin. I think he was assistant of the corps commander

4 for the rear. The topic of the negotiations was that the Serbs wanted the

5 Muslims to give up some weapons which they didn't have, and Colonel

6 Parezanin said, "Discuss this with the official authorities and fulfil

7 your promise, otherwise I will raze this Muslim village to the ground,"

8 and he pointed to a Muslim village, and then he left the room.

9 Q. Did there come a time when he returned and introduced another

10 person who was present at that meeting?

11 A. Yes. When he reached the door, he turned back and said, "I forgot

12 to introduce this gentleman." And there was a man sitting there whom I

13 didn't know, and he said, "This is Colonel -" and I forgot his name, but

14 he said he was the commander of the Red Berets. This was the first time I

15 had heard of the name Red Berets.

16 This gentleman said, "Yes, I am" such-and-such a person, "fulfill

17 the requirements of the Serbian side. If not, I can bring 5.000 specials

18 here." And then I think they both left the meeting.

19 JUDGE MAY: Yes. Yes, Mr. Milosevic.

20 THE ACCUSED: [Interpretation] Mr. May, the witness said, as far as

21 I can interpret what he said in Serbian, that they were to fulfil the

22 promises and that he was able to raze to the ground a hill over there, and

23 the witness said there was also a Muslim village there. The record says,

24 as it was interpreted, "Fulfil your promises or I will raze this Muslim

25 village to the ground." So the interpretation is completely different.

Page 27763

1 JUDGE MAY: Let us -- let us -- we needn't -- We needn't go on

2 further but we will clarify what it was the colonel said.

3 Can the witness do that.

4 THE WITNESS: [Interpretation] Yes. Yes, I can assist. The

5 colonel addressed us and asked us to fulfil the demands of the Serbian

6 side, and if we failed to do this, he said, "I am able to raze that hill

7 to the ground," but there were Muslim villages on that hill. That's how

8 it was.

9 MR. GROOME:

10 Q. I want to now return not to Colonel Parezanin but the other

11 colonel whose name you do not recall but who was introduced as the

12 commander of the Red Berets. My question to you is: Was he wearing at

13 that time any type of red headgear that you could see?

14 A. No. No. No.

15 Q. When he made this reference to 5.000 specialists, what was your

16 understanding of what a "specialist" was?

17 A. I didn't know who the Red Berets were, to be quite honest. I

18 didn't know who they were. At that moment, we were under enormous

19 pressure. It was a very unpleasant situation and I took this seriously.

20 Q. Did you know what he meant when he referred to the term

21 "specialist"?

22 A. Probably a Special Purpose Unit. It was afterwards that I learned

23 who the Red Berets were. They were a special unit from Nis, of the JNA.

24 At that moment, I didn't know who they were.

25 Q. From what source did you learn this information about where the

Page 27764

1 Red Berets came from?

2 A. Well -- well, you find out. People talk. You ask people. In

3 communication with other people. So I didn't learn it from any official

4 source. We were simply struggling to survive at that time, to save

5 ourselves somehow.

6 MR. GROOME: I have no further questions.

7 JUDGE MAY: Yes, Mr. Milosevic.

8 Cross-examined by Mr. Milosevic:

9 Q. [Interpretation] Mr. 1122, you say in your statement that prior to

10 the elections -- and you're talking about the elections in

11 Bosnia-Herzegovina, I assume; is that right?

12 A. Yes.

13 Q. You say that in the time that preceded those elections, the SDS,

14 the Serbian Democratic Party -- you say that in paragraph 4. "In the time

15 leading up to the elections, the SDS held large rallies in Kosovo and

16 Belgrade and other places." Were they rallies of the Serbian Democratic

17 Party, in fact? When you say, "Many Serbs from Gacko attended these

18 rallies and they were strong Serb nationalists." That's what you say.

19 A. Yes, that is in the statement. However, I corrected that

20 subsequently and said that during the time the elections -- during the

21 time large-scale rallies in Kosovo and Belgrade were taking place, and

22 other places, that a large number of nationalists from Gacko, from the

23 Serbs, attended and went to attend those events. So I made this

24 correction in the addendum.

25 Q. All right, Mr. 1122. Now, these large-scale rallies at Gazimestan

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Page 27766

1 and Usce, did you hear a single word said at Gazimestan or Usce which

2 could be qualified as being nationalistic or nationalism?

3 A. Well, I think that the contents and subject of those rallies is

4 common knowledge.

5 Q. All right. So your answer is in fact yes; you're claiming that it

6 is.

7 A. Yes.

8 Q. In that brief examination-in-chief, and I'm not going to present

9 you with all the different rallies because we'd use up a lot of time that

10 way, but tell me this, please: Did you see the rallies of the SDA party?

11 A. Yes.

12 Q. Is it true that the first nationalist party that was established

13 in Bosnia-Herzegovina was precisely the Democratic Party of the SDA on the

14 26th of May, 1990? Isn't that right?

15 A. I really don't know the dates.

16 Q. You don't know the dates?

17 A. No, I don't. The SDA, the SDS, the HDZ, I really don't know when

18 they were formed, but I do know about the local level in Gacko. I know

19 that the Serbian Democratic Party was set up on the 2nd of August, for

20 example, 1990, whereas on the 1st of September, the Party of Democratic

21 Action was formed. So I just know this at a local level.

22 Q. All right. Now tell me what the rallies were like of the SDA

23 party, the Party of Democratic Action. What were their rallies like?

24 A. They were pre-electoral activities, in fact, where the political

25 parties or, rather, the political party, the Party of Democratic Action,

Page 27767

1 the SDA, tried to win over the electorate in order to gain power, come

2 into power, and this was in fact a power struggle.

3 Q. Now, did you at those rallies notice any exclusiveness in the

4 positions taken by the Party of Democratic Action that was expressed in

5 the fact that there was room in Bosnia only for Muslims and nobody else,

6 or anything of that kind?

7 A. No. That was never the case.

8 Q. It was never the case?

9 A. No. It wasn't even in the programme of the Party of Democratic

10 Action at all. It wasn't set out there either.

11 Q. All right. Now, is it true and correct that the basis for the

12 party's activities was the Islamic declaration by Izetbegovic, in fact?

13 A. I don't know about that. I'm not informed in that respect, so I

14 can't answer your question. I haven't read the Islamic declaration

15 either.

16 Q. You haven't read it?

17 A. No, I haven't, quite certainly.

18 Q. And yet you were an SDA functionary, official.

19 A. I think that's got nothing to do with it. If I was an official, I

20 still didn't have to read the declaration.

21 Q. Now, you say in paragraph 4 that there was propaganda which

22 promoted Serb nationalism and invented crimes which the Muslims were

23 supposed to have committed against the Serbs and that some articles

24 mentioned Gacko and invented incidents and crimes which the Muslims were

25 supposed to have committed.

Page 27768

1 A. Yes.

2 Q. That's what you say.

3 A. That's how my statement reads, and that's the truth of it.

4 Q. So was that remembrance of history? Is that what this is

5 referring to, when Islamism was being revived and with respect to the

6 breakdown of Yugoslavia?

7 A. When I gave this statement, this referred to what was going on in

8 Gacko, and it was a revival or burgeoning of Serb nationalism, because

9 literary evenings were being held which did not resemble literary evenings

10 at all, in fact. They represented political manifestations. And then I

11 have in mind the guslevski evenings which were characteristic for the

12 area. Mr. Milosevic, you know that through that that is a good way of

13 reviving nationalism. Then I also have in mind the important people that

14 came to Gacko to make speeches, who weren't from the area originally, who

15 didn't live in Gacko but who at one time originated from Gacko.

16 And I also have in mind the books that had a highly negative

17 effect in the area and revived and garnished nationalism. Vuk Draskovic's

18 book is a case in point, called Noz, or The Knife.

19 Q. All right, Mr. 1122. You wrote all this in point 4, and you've

20 just stated that they were writers who lived in Belgrade or elsewhere but

21 originated from the area.

22 A. Not only authors; I mention important people.

23 Q. You mention Gojko Djogo, you mention Vuk Draskovic; is that right?

24 A. Yes.

25 Q. And you have particularly highlighted Draskovic's book. And as

Page 27769

1 far as I know, all that came out far before these events took place.

2 A. Yes, but it was a good topic, a good subject for the nationalists.

3 Q. Is it true that the events which are described in the book were

4 actually based on historical facts, on events which took place? And the

5 -- and the book was published much before any of these events took place.

6 A. I think that this is a very vulnerable area, region, and whenever

7 the situation was unstable in the region, then there were things on both

8 sides, inhumane acts, killings, crimes, they did take place, but far more

9 on the Serb side than the Bosnian side, and history proves that.

10 Q. You mean in World War II?

11 A. Before World War II as well and in the Second World War also.

12 Q. All right. Now, as you're explaining -- as you've just mentioned

13 the guslevski evenings, for those of you who are not familiar with this

14 term, the gusle were a national instrument to accompany folksongs that

15 were being sung; isn't that right?

16 A. Yes.

17 Q. And these are folksongs that have been sung for centuries and

18 decades; isn't that right?

19 A. Yes. But it is a time when exclusively nationalist songs are

20 sung, and that's the subject, that's the topic of it.

21 Q. So the gusle, the instrument the gusle, a string instrument,

22 contributed to the development of nationalism. Is that what you're

23 saying?

24 A. Yes, absolutely so.

25 Q. So you count the gusle evenings among the nationalist

Page 27770

1 manifestations and events that took place?

2 A. Absolutely so, yes.

3 Q. All right. Mr. 1122. If the people whose ancestors originated

4 from the area or have relations there, have houses there, if they came to

5 the area, if they were authors, public personages, took part in the

6 various cultural events or whatever you like to term them, what has that

7 got to do with Serbia?

8 A. Mr. Milosevic, I remember very well a meeting held by the Serbian

9 Democratic Party in Gacko at which Budimir Kosutic took the floor, and he

10 just originated from Gacko, but he was very close to the SPS party and

11 your own party, very close to your own party. And he made a speech there,

12 and it was quite obvious what the subject and goal of what he was saying

13 was. That was quite evident. We knew what he was saying, what the

14 subject was, what it was geared towards.

15 Q. Well, do you know that Budimir Kosutic is a professor at the

16 faculty of law in Belgrade?

17 A. Yes.

18 Q. And you said that Budimir Kosutic, he wrote down that Budimir

19 Kosutic was my chef de cabinet?

20 A. That's how he introduced himself, and I think that he took part in

21 television programmes in that capacity fairly frequently, Yugoslav

22 television, the former Yugoslavia television. He would be on television.

23 Q. Mr. 1122, he quite certainly couldn't have appeared in that

24 capacity because he never worked in my cabinet, let alone the fact that he

25 was the -- my chef de cabinet. Throughout the time that you're referring

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Page 27772

1 to he was in actual fact a professor of law at the Faculty of Law. So

2 what you're saying that he introduced himself on television as being my

3 chef de cabinet is quite untrue. He couldn't have introduced himself as

4 being that.

5 JUDGE MAY: Depends on what the man said on television. Whether

6 he was telling the truth or not is an another matter.

7 THE ACCUSED: [Interpretation] Well, Mr. May, can you imagine a law

8 professor coming on television, known by so many people, and saying, "I am

9 President Milosevic's chef de cabinet"? That is nonsense.

10 JUDGE MAY: Well, law professors can say a great many things, but

11 let's move on.

12 THE ACCUSED: [Interpretation] I agree with you there. I quite

13 agree, yes. That is true for men of the law.

14 MR. MILOSEVIC: [Interpretation]

15 Q. Anyway, Mr. 1122, isn't -- wasn't that equally true both for the

16 Serbs and the Muslims and for the Croats, for the Macedonians, the

17 Slovenes, that regardless of where they lived, they always have some

18 connections with their roots, with their region of origin? They would go

19 back from time to time to take part in certain activities. It wasn't

20 specific to Gacko.

21 A. Mr. Milosevic, his speech there was full of nationalism, and his

22 speech wasn't suited to this kind of event, an event held by people who

23 wanted peace. It served to burgeon nationalism.

24 Q. Tell me, when did Budimir Kosutic deliver that speech?

25 A. It was an event, a manifestation. I can't remember the exact

Page 27773

1 date. It was sometime, I think, in the autumn of 1991.

2 Q. Was it a cultural event?

3 A. No. It was a political event of the party of -- of the Serbian

4 Democratic Party, in fact.

5 Q. So it was a meeting of the Serbian Democratic Party. Was Kosutic

6 a member of the SDS?

7 A. This is how it was: It was a manifestation of the SDS party in

8 Gacko, and at that event there were many speakers. One of them was

9 Budimir Kosutic.

10 Q. All right. Now, I don't have Kosutic's speech here with me, and I

11 don't think we need discuss his speech at all either with you, that is,

12 but as in point 10 you say that the first large scale rally of the SDS was

13 held on the 2nd of August, 1990, in the village of Nadanici?

14 A. Nadanici.

15 Q. Right, Nadanici. I don't know the names of those places in that

16 region. Anyway, it was organised by the church and it was held in front

17 of the church, and it was held on the date of an Orthodox holiday?

18 A. Yes, that's right.

19 Q. Now, do you have an explanation as to what was happening there?

20 Now, if the church organises for an Orthodox religious holiday, a rally of

21 citizens, Serbs who are of the Orthodox faith, to have them meet in front

22 of the church for an Orthodox holiday, what about it?

23 A. Well, the Orthodox holiday of the 2nd of August is well known as

24 Ilindan, St. Ilija's Day.

25 Q. Yes, everybody knows that.

Page 27774

1 A. And on that day, on St. Elijah's Day, there was a traditional

2 festival that was held, but that particular day, St. Elijah's Day was used

3 to set up the Serbian Democratic Party, and it was from the SDS

4 headquarters, I think, that Velibor Ostojic was present.

5 Q. Velibor Ostojic was from the headquarters in Sarajevo; is that

6 right?

7 A. Yes, quite.

8 Q. So they were there for St. Elijah's Day and they formed the SDS

9 branch of Gacko; is that right?

10 A. Yes.

11 Q. Very well. Now, was that after the SDA party had been formed?

12 A. No. It was before the SDA party had been formed.

13 Q. You mean in Gacko?

14 A. Yes.

15 Q. After the SDA had been set up throughout Bosnia. I assume you

16 know that.

17 A. Well, in Gacko, the SDA party was formed on the 1st of September

18 of that same year.

19 Q. So in Gacko it was formed 28 days before the --

20 A. After.

21 Q. All right. After the party in Gacko.

22 A. The SDS was established before it was established first in

23 Sarajevo and then in Gacko later on.

24 Q. Now in addition to the SDA, was there a Muslim, the MOS branch of

25 the SDA party, the youth Muslim organisation?

Page 27775

1 A. No.

2 Q. You didn't have a Muslim youth alliance?

3 A. No. There were only 3.800 Muslims in Gacko at that time, and our

4 only goal was to survive, to save our heads.

5 Q. So you know nothing about this Muslim youth alliance. You have no

6 experience with that.

7 A. No, I know nothing about it, I have no experience of it.

8 Q. All right. So I'm not going to ask you anything about that then.

9 A. Thank you.

10 Q. Now, in Gacko with respect to the elections in 1990, the autumn of

11 1990, in fact, when the elections were held, establish a coalition of any

12 kind?

13 A. No.

14 Q. You were independent, were you?

15 A. Well, there were three political parties at the elections; the

16 SDS, the SDA, and the SDP. Those three parties had their list of

17 candidates, their ticket.

18 Q. The HDZ, wasn't there?

19 A. Well, there were no Croats there, no Croat inhabitants.

20 Q. SDP is the Social Democratic Party; is that right?

21 A. Yes, that's right.

22 Q. Tell me this now, please: How come or how was it that the

23 distribution was made? How were the positions and posts after the

24 elections distributed in your municipality? Was this done on the basis of

25 a proportionate ratio, Serbs/Muslims? And I'm referring to point 8 of

Page 27776

1 your statement, because you say that the SDS held all the influential

2 positions.

3 A. Yes.

4 Q. You say that none of the SDS members could act independently.

5 What about the secretary for national defence? Was he Safet Skaljic?

6 A. Yes, he was.

7 Q. So he was in charge of defence on behalf of the SDA party?

8 A. He was chief of the Territorial -- the chief of Territorial

9 Defence was a Serb, and he was the next man. He was the administrative

10 man and had an administrative post.

11 Q. So he was the municipal defence secretary?

12 A. No. There was a chief there and the structure was quite

13 different.

14 Q. And Elvedin Zugur, the police chief, was he also from the SDA?

15 A. Yes, he was on paper, but he wielded no influence whatsoever.

16 Q. Well, how could a police chief not wield any influence if he is in

17 command of the police?

18 A. We wasn't in command of the police because the deputy police chief

19 was a Serb, Branko Popic.

20 Q. So the commander, the chief, was a Muslim and the deputy a Serb,

21 is that it, on paper?

22 A. On paper.

23 Q. What does that mean?

24 A. May I be allowed to explain? The mayor of the municipality was a

25 Serb. The Prime Minister was a Serb. The chief of MUP was a Serb. The

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Page 27778

1 commander of the Territorial Defence was a Serb. So those were the key

2 positions in the municipal organs. Anything underneath that, below that

3 -- the chief of police comes below the chief of MUP, for instance. So in

4 actual fact, they were just figureheads, directors of companies, for

5 example, general managers. There were some Muslims before but there were

6 none afterwards. The Serbs took all key positions. I don't know that

7 there was a single Muslim director except in the hospital when he was

8 replaced by a medical technician whereas he had the title of "primarius"

9 before that.

10 Q. Yes, but the defence secretary, Safet Skaljic, from the SDA and

11 the chief of police, Elvedin Zugur, from the SDA as well, they did hold

12 those posts. You're not challenging that.

13 A. No, I'm not.

14 Q. Now, in the police structure generally were there Muslim

15 policemen, as many, for instance, as there were Muslims in the

16 municipality, proportionate to the Muslim population?

17 A. Yes, until the SAO, the Serb autonomous region of Herzegovina was

18 formed, and then the Muslim policemen left the police force.

19 Q. So they left it.

20 A. Yes, because they weren't given any tasks to do. They were just

21 figureheads. They had no power.

22 Q. Very well. You say in point 10 that when the conflict in Croatia

23 started, the Serbs organised a "Jurisni Bataljon," an attack battalion,

24 which was a name used by a Chetnik unit in World War II.

25 A. Correct.

Page 27779

1 Q. Can any atrocities, as you say, committed by the Serbs be compared

2 to the atrocities committed against the Serbs in World War II? There is a

3 mass grave there, isn't there?

4 A. Yes, but this mass grave was called Dizdarusa previously, and a

5 large number of Muslim families were slaughtered, many of them called

6 Dizdaruvic, which is why the place was called Dizdarusa.

7 Q. In 1941 were Serbs thrown into this pit, into this ravine?

8 A. I read about this but I wasn't alive at the time.

9 Q. Well, no, you weren't alive in 1918 and yet you're pointing out

10 this answer.

11 A. I'm saying that this was a vulnerable area where many atrocities

12 were committed on all sides.

13 Q. Tell me, how many Serbian women and children were thrown into this

14 ravine in World War II?

15 A. I really wouldn't know.

16 Q. You say that the SDA called on soldiers and officers born in

17 Bosnia to leave the JNA, and at the same time they prevented the calling

18 up of JNA soldiers from Bosnia and Herzegovina.

19 A. Where did I say this?

20 Q. I'll find this for you.

21 It's in paragraph 9. The last third of this paragraph: "We

22 discussed the mobilisation call in this manner and made a recommendation

23 that SDA did not have to answer the mobilisation call. We stated that the

24 war in Croatia and Slovenia was not our war, and that we would join the

25 effort when the borders of our municipality were attacked. Therefore no

Page 27780

1 Muslims joined the mobilisation."

2 A. Yes. This is quite true. We did not sign a document with the SDA

3 or, rather, there was an inter-party commission of the SDS and SDA where

4 the SDA said they did not want to join in this conflict because we were

5 not in favour of war. We were in favour of peace. This was not our war,

6 and we said that we would go to war when our municipality was attacked.

7 Q. Yes, but as you know, the JNA was the armed force of all the

8 peoples of Yugoslavia.

9 A. All this was taking place, I think, after Bosnia and Herzegovina

10 was internationally recognised. No, no. This was 1991, so you're right.

11 Yes, that's correct. We did not respond to the mobilisation; correct.

12 Q. Do you know that the JNA attempted to prevent the conflict and

13 that was its main role precisely at the time when you refused to join the

14 mobilisation?

15 A. I wouldn't say that's how it was.

16 Q. Very well. Do you know that the SDA continuously de-legitimised

17 the armed forces and that this was one of your standpoints, that the JNA

18 should be abandoned, that the mobilisation should not be responded to, and

19 that the Muslims should boycott the JNA in every way? Do you remember

20 when the SDA proclaimed its own war command?

21 A. No. No, I'm not familiar with that.

22 Q. Did the SDA party say that the Territorial Defence Staff was

23 pro-Serb and an occupying army?

24 A. General Gosaluvic [phoen] was the chief of staff.

25 Q. He was a Serb.

Page 27781

1 A. Yes. All I know is that he was the commander of the Territorial

2 Defence.

3 Q. And then he was replaced and the Territorial Defence Staff was

4 disbanded and their own staff was set up.

5 A. I was hiding in the mountains at the time when this happened in

6 Sarajevo, so I'm not familiar with the details. At that time, I was in

7 the wilderness, in the mountains in Zelengora with my children and my

8 wife, trying to save our lives. So I was not able to follow the events

9 that were taking place then.

10 Q. Well, if you were not able to follow these events, I won't ask you

11 about them. Somebody else will probably be able to say more about this.

12 You say that the weapons of the Territorial Defence were stored in

13 your area and that in 1989 the republican authorities decided to move

14 these weapons from Gacko to Konjic.

15 A. That's how it was in all municipalities in 1989. The weapons were

16 taken to central depots. So they were taken to Konjic.

17 Q. To keep them safe there; right?

18 A. Yes, but three truckloads were separated off - I don't know under

19 what regulations - and brought to Gacko and distributed to the Serbs, and

20 they were trained to use these weapons. We could hear them practising

21 shooting in the mountains around Gacko.

22 Q. Very well. Let's look into this. So on the 10th of July, 1990,

23 you were mentioning this incident, a police patrol from Gacko noticed a

24 truck passing close to Gacko.

25 A. Yes.

Page 27782

1 Q. They tried to stop it and this was a patrol consisting of one

2 Muslim and one Serb.

3 A. Yes.

4 Q. And they stopped the truck near the exit from the town?

5 A. Yes.

6 Q. They took the driver to the police station where they held him for

7 a day or two, and then on the 12th of July, 50 cars full of people from

8 Nevesinje arrived at the police station.

9 A. Yes.

10 Q. And set the driver free?

11 A. In quotation marks.

12 Q. Yes. And fired shots from automatic weapons I suppose into the

13 air. Is that correct?

14 A. Yes, yes, yes.

15 Q. And they behaved in a wild manner.

16 A. Yes.

17 Q. Is it clear that this is some sort of local smuggling of weapons?

18 A. No. That's not clear, Mr. Milosevic. The Yugoslav army was

19 arming the Serb population. It's true there was a mixed patrol consisting

20 of Savo Stojanovic who was a Serb and the Kampala [phoen]. If this man

21 was a Serb, it doesn't mean that he took part in this arming. It's true

22 that they arrested the driver and brought him to Gacko and that on the

23 12th of July, and I think that this is an Orthodox holiday but I'm not

24 sure, yes, yes. They came from Nevesinje, a column of cars to Gacko in

25 front of the police. No one dared opposed them. They fired shots. They

Page 27783

1 acted wildly, and then they took off the driver. He was from Nevesinje.

2 Q. So the driver was from Nevesinje?

3 A. Yes, yes.

4 Q. And the other two participants were two policemen, one Serb and

5 one Muslim who had nothing to do with it?

6 A. Yes.

7 Q. So the people from Nevesinje who came and behaved wildly?

8 A. Yes.

9 Q. These are all the participants in this event?

10 A. Yes.

11 Q. What has that to do with this then, because that's the

12 neighbouring municipality. There was a local arms smuggler, two local

13 policemen. What has Serbia got to do with any of this? What has the JNA

14 got to do with any of this?

15 A. Arms are not produced in Nevesinje or in Gacko. Weapons are

16 produced in factories that in the former Yugoslavia were controlled by the

17 JNA.

18 Q. Yes, controlled by the JNA.

19 A. You could not go and buy weapons in a kiosk.

20 Q. Of course not. You're putting this in the context of the illegal

21 arming and the paramilitary formations. Do you know that the first

22 paramilitary formations set up in Bosnia and Herzegovina was the party,

23 para-army of the SDA called the Patriotic League?

24 A. I really don't know these dates. And this Patriotic League, was

25 it a formation, a unit? What was it?

Page 27784

1 Q. It was established all over Bosnia and Herzegovina.

2 A. But not in Gacko.

3 Q. Not in Gacko?

4 A. Certainly not.

5 Q. Do you remember they had nine regional staffs, 103 municipal

6 staffs?

7 A. No, I'm not aware of that. That was at a higher level.

8 Q. Do you know that as part of these activities in August 1992, there

9 were --

10 THE INTERPRETER: Could Mr. Milosevic please slow down.

11 MR. MILOSEVIC: [Interpretation]

12 Q. -- battalions. Do you know all this?

13 A. I don't know all this. I think this is pure propaganda.

14 Q. Very well.

15 JUDGE MAY: You're being asked to slow down, Mr. Milosevic, by the

16 interpreters.

17 THE ACCUSED: [Interpretation] Very well.

18 MR. MILOSEVIC: [Interpretation]

19 Q. Do you know that the leadership of this Patriotic League was

20 entrusted to form a JNA officer, Sefer Halilovic, who was later appointed

21 Commander-in-Chief of the army of Bosnia and Herzegovina and then to

22 Lieutenant Colonel Meho Karisik --

23 JUDGE MAY: The witness has said he doesn't know anything about

24 this. He describes it as propaganda. Whether it is or not we'll have to

25 determine in due course.

Page 27785

1 THE ACCUSED: [Interpretation] Very well.

2 MR. MILOSEVIC: [Interpretation]

3 Q. Tell me, did these clashes, all the conflicts you are talking

4 about, did they begin after the 6th of April, 1992, when the so-called

5 international recognition of Bosnia and Herzegovina took place based on

6 that rump referendum? Is that so?

7 A. You see, before this, the Muslim population in my municipality was

8 mistreated. Two of our young men were killed. I think it was in March.

9 Their names were Boskovic and Grebovic. People were beaten in Gacko.

10 Their shops, the Muslim shops, were bombed. Muslim cafes were bombed. At

11 that time, we were suffering under repression and mistreatment, so we

12 didn't know much about what was going on outside our municipality.

13 Q. Well, as you don't know anything further away from your

14 municipality, do you know about the Green Berets, the directive given to

15 the Green Berets and other Muslim formations that barracks and JNA

16 officers and soldiers should be attacked?

17 A. No. This did not happen in Gacko.

18 Q. You know that the Presidency of Yugoslavia, on the 4th of May,

19 reached a decision that the JNA should withdraw from Bosnia and

20 Herzegovina?

21 A. What Presidency are you talking about?

22 Q. The Presidency of the SFRY.

23 A. I know about this. To what extent this was actually respected,

24 that's a different matter. I think it was not, for the most part.

25 Q. Do you think today that it was a good thing for the JNA to

Page 27786

1 withdraw from Bosnia and Herzegovina when all these paramilitaries were

2 running amok in Bosnia and Herzegovina?

3 A. They were all part of the JNA. The White Eagles were part of the

4 JNA, and all the other paramilitary units were part of the JNA. The JNA

5 armed them. At least, they did in our area. That's what I saw and that's

6 how I experienced it.

7 Q. Very well. The Muslim units and the HVO, they were also part of

8 the JNA?

9 A. They weren't there in our area. These units weren't in our area.

10 I can't talk about them.

11 Q. I won't ask you about things you can't talk about. Just let me

12 see.

13 You say in paragraph 17 that "... this 'attacking battalion' were

14 armed with automatic weapons, they held military exercises ... They were

15 not dressed like soldiers at that time. In March 1991 there was a special

16 police unit who had been sent to Bileca to calm the situation down when

17 the weapons had been seized. When the police unit was on the way back to

18 Sarajevo, the Serbs of the 'attacking battalion' and some other

19 paramilitary units, led by Obren Govedarica, who was the head of the White

20 Eagles for Herzegovina --" Let's stop here.

21 This man whom I've just mentioned - and I was reading from your

22 statement - is he from Herzegovina?

23 A. Yes.

24 Q. This unit of the White Eagles which you mention, were they also

25 from Herzegovina?

Page 27787

1 A. The attacking battalion is mentioned here.

2 Q. I'm talking about the White Eagles. You said at the beginning

3 that in this -- during your testimony here. Were these White Eagles from

4 Herzegovina?

5 A. You see, their commander was a certain Ljubo, and a song was

6 written about his heroism, his heroism in killing unarmed civilians during

7 the attack on Kula, which is a Muslim village. This Ljubo was killed,

8 Captain Ljubo, at that place, and a poem was written about his heroism

9 saying he was born in Valjevo. That's what the song says. And this was

10 published in 1992. It's a song written to be sung accompanied by the

11 gusle.

12 Q. Govedarica, the commander of the White Eagles in Herzegovina, was

13 a Herzegovinian and so were the members of the unit.

14 A. What I meant when I said that -- well, Govedarica was not a

15 military commander. He was the president of the regional committee for

16 Herzegovina, and of course as a civilian commander, he had influence on

17 the White Eagles, but their commander was Ljubo, and I think his last name

18 was something like Moljevic or Mocevic.

19 Q. You say Govedarica, leader of the White Eagles in Herzegovina.

20 And then you say that the commander of the special police unit was named

21 Vikic.

22 A. Yes.

23 Q. He was a Serb too, was he?

24 A. I -- I added something to this. This is Dragan Vikic, and he was

25 from the special unit of the republican MUP. So I'm not referring to the

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Page 27789

1 MUP of Gacko but the republican MUP.

2 Q. But this Dragan Vikic has to be a Serb?

3 A. No, he doesn't have to be a Serb. I don't know what he was.

4 Dragan Vikic was one of the well-known commanders for the defence of

5 Sarajevo. He's still living in Sarajevo, and he is an eminent person. I

6 don't know.

7 Q. This is what you say: "I think that in the case that this police

8 unit did something contrary to what the Serbs wanted, the ambush would

9 have shot at them."

10 A. Yes.

11 Q. So they didn't actually shoot, but you think that they would have

12 shot had the other side done something they didn't like?

13 A. Yes. Why would they have rallied there otherwise, gathered there

14 and set up an ambush in the first place.

15 Q. Well, was it an ambush?

16 A. Well, they didn't do any shooting. Mr. Milosevic --

17 Q. Just tell me if they shot or not.

18 A. It was like this, Mr. Milosevic: This man Obren Govedarica came

19 to the municipality wearing a military uniform. He went to the

20 president's office. That's where he was seen. He was our -- our

21 representative was sitting there and when Obren came in and everybody knew

22 each other there because you know what all that was about. It was the

23 weapons seized from the Yugoslav army, from the national deputy named

24 Kozic. The demonstrations ensued in Bileca and the republican MUP went to

25 calm the situation down, and I think you know -- I think you know that it

Page 27790

1 was all they could do to save their skins from Bileca.

2 Q. Who is that?

3 A. From the specials of the republican MUP. And they escaped. Now,

4 there was an ambush here as nothing happened in Bileca, as there was no

5 shooting there, these here did not, but all that was coordinated and of

6 course these people didn't have to shoot.

7 Q. How do you say you -- to me that I should know? How should I know

8 what was happening in another -- different republic in Gacko? What has

9 Serbia got to do with that?

10 A. Well, I see that you have a lot of information.

11 Q. I receive information when I have a witness, but I know nothing

12 about Gacko to be quite frank.

13 A. All right. But this is true.

14 Q. Then you say: "That day, I was sitting in Lazetic's office when

15 Obren Govedarica entered right after that." That's the event you've just

16 described. "He was dressed in regular JNA uniform without any insignia,

17 he was full of enthusiasm, enthusiastic because he had managed to gather a

18 large number of volunteers who were armed and ready for action." So these

19 White Eagles that you're talking about under Obren Govedarica were local

20 volunteers, in fact, who were now putting on the insignia of the White

21 Eagles and didn't want to display their insignia of the JNA.

22 A. Here it says "Serbs from the Assault Battalion and other

23 paramilitary units including the White Eagles." That's what it says.

24 Q. So all these were in fact people from the ranks of the local

25 population; is that right?

Page 27791

1 A. It was like this: In the White Eagle units there were some local

2 inhabitants, yes, there were, but the commander at the time was this man

3 Ljubo.

4 Q. You mean the Ljubo who was killed?

5 A. Yes, that's right.

6 Q. And when was he killed? In 1991, is that it?

7 A. He was killed during an attack on the Muslim village of Medjunici

8 on the 17th of June, 1992. July, I'm sorry. I meant to say July.

9 Q. All right.

10 A. So it was absolutely certain that he was within the White Eagles

11 composition. They were from Serbia and I even sat with that man Ljubo

12 with some municipal representatives. There was one of our men who had a

13 political function there and he would often talk to these people. And

14 then at this point this man Ljubo told the other one that he was the

15 commander of the White Eagles and that he had the veterans, and I repeat,

16 veterans from the Vukovar battlefield among its -- this unit.

17 Q. Who organised that?

18 A. Well, of course that was organised by the SDS and that there was

19 this feedback mechanism that was set in place.

20 Q. All right. Now you're talking about incidents that took place

21 between the SDA and SDS, that is to say, between the Serbs and Muslims of

22 your region?

23 A. Yes, but where is that here?

24 Q. That's what you say in point 22, paragraph 22. Now, was it

25 precisely in order to decrease tensions that the JNA had gone to Gacko?

Page 27792

1 A. I'm not following you. Are you talking about the Muslims and the

2 Serbs or the SDS?

3 Q. I'm talking about both the Muslims and the Serbs and the tension

4 that existed.

5 A. Yes. I see.

6 Q. Now, my question is this: Was it precisely due to that tension

7 that the JNA came to Gacko?

8 A. The JNA came to Gacko as it was withdrawing from Croatia and

9 before that it was at the barracks at Bileca, that well-known barracks,

10 and the Hercegovina Corps and units of the Uzice Corps were moving towards

11 Mostar and I don't think that I can say that they came there to quell the

12 situation. They came to perform quite another task.

13 Q. All right. But at that time, the army of Republika Srpska was

14 already in existence; isn't that right?

15 A. I do believe so, yes.

16 Q. I hope -- are you not challenging that this was made up of

17 soldiers and officers that were either born there or lived there before

18 the war, the members of the Republika Srpska army?

19 A. The Republika Srpska army had -- well, we were expelled from Gacko

20 at the time, but I do know that there were people from the area of

21 Republika Srpska and from the broader area of Serbia as well, and

22 Montenegro, and Montenegro.

23 Q. All right. Just explain this to me: You mentioned a moment ago

24 the killing that took place in March 1992 of -- you say in March 1992, the

25 White Eagles killed Zoran Grebovic who was from a Serb-Muslim marriage; is

Page 27793

1 that right?

2 A. Yes, but just tell me what paragraph that's in.

3 Q. I think it's paragraph 23 where you say that, but you know about

4 all this.

5 "On the 2nd of March, 1992, Serbian paramilitary units had a

6 checkpoint in the direction of Foca. They stopped two Muslims who were

7 returning from Foca, they took them with their car to the mountain called

8 Cemerno and killed them."

9 A. Yes.

10 Q. Their names were Zoran Grebovic, who was from a mixed Serb-Muslim

11 marriage, and Amir Poskovic, a Muslim.

12 A. Yes.

13 Q. And then you go on to say who the killers are.

14 A. Yes.

15 Q. "... Mastilovic and Vukovic from Gacko. The bodies were

16 discovered by a policeman," and all the rest of it, et cetera, et cetera.

17 A. Yes.

18 Q. Therefore all this was taking place between the local Serbs and

19 the local Muslims; isn't that right?

20 A. This particular event was an event like that, yes, this specific

21 event.

22 Q. Now, does that have anything to do with anyone from Serbia?

23 A. Of course it does, because it was organised there. They had come

24 to organise it. Ljubo had come to organise it. And I know on one

25 occasion --

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Page 27795

1 Q. Haven't we just established that this event had nothing to do with

2 people who weren't local Serbs or local Muslims?

3 A. Yes. We can accept that for this particular incident.

4 Q. All right. Let's move on now. You said a moment ago that the

5 army, when it was withdrawing from Croatia, withdrew to your area.

6 A. Yes, among other things.

7 Q. Where, where else could it have gone? It could have gone to

8 Bosnia, to Serbia, to Montenegro. Where else could the army have gone if

9 it had left Slovenia and left Croatia? Because it was on its own

10 country's territory, the territory of its own state.

11 JUDGE MAY: There is no need to answer that. Yes, Mr. Milosevic,

12 let's move on.

13 MR. MILOSEVIC: [Interpretation]

14 Q. Very well. Now, this killing for which we established a moment

15 ago was an incident which happened exclusively between local participants,

16 and this disturbed people in Gacko a great deal.

17 A. Yes.

18 Q. And that's quite understandable?

19 A. Yes, absolutely.

20 Q. Then you mention a meeting that was held -- actually, it was a

21 large rally held with respect to that killing because the people were

22 upset. And then you mention General Perisic, who came to attend the

23 rally.

24 A. No, Perisic didn't come to that rally.

25 Q. But the meeting held because of the incident.

Page 27796

1 A. Not even that, because the incident took place, I think, in March,

2 the 5th of March -- the rally took place on the 5th of March, whereas the

3 meeting with Perisic was on the 28th of April, in actual fact. So this

4 isn't tied in.

5 Q. But it's tied into the situation, the general situation.

6 A. That's right, not meeting but the situation.

7 Q. And what meeting was it that Perisic attended?

8 A. It was a party meeting.

9 Q. Did you attend the meeting yourself? Were you there?

10 A. Well, I don't want to answer that question.

11 Q. All right, you don't have to.

12 A. This meeting was at a broader level, held at a broader level

13 because the meeting was presided over by the president of the SAO of

14 Herzegovina, and present were the representatives of the Serb

15 municipalities from the area, from Stara Herzegovina, and several

16 representatives by the Muslims from Gacko, I think, somebody along those

17 lines. And the meeting was chaired by Milan Bojovic, the Prime Minister

18 of the government of the Serb autonomous region of Herzegovina. And at

19 the meeting the commander of the Yugoslav army was also present, and as

20 far as I know, SAO Herzegovina was never a constitutional legal entity

21 within Yugoslavia; it was in Bosnia-Herzegovina.

22 Q. It was a meeting at which Perisic attended, and did he say he was

23 a commander in the Yugoslav army?

24 A. Yes.

25 Q. Which was composed of all the nations, all the ethnic groups.

Page 27797

1 A. That was the story he told us but it wasn't a true story. That

2 wasn't true.

3 Q. What do you mean it wasn't a true story? Wasn't the Yugoslav army

4 composed of all the nations, all the ethnic groups?

5 A. It was beforehand but not at that time.

6 Q. But he emphasised that he would remain commander until all the

7 three ethnic groups were there as part of the Yugoslav army.

8 A. Yes, that's what he told us.

9 Q. He emphasised, therefore, he stressed that the Yugoslav army was

10 an army of all the nations, all the ethnic groups?

11 A. Yes, that's what he said.

12 Q. And did he also say that he would prohibit paramilitary formations

13 and their activities in his area of responsibility?

14 A. That's what he said, but he didn't prohibit them.

15 Q. Do you know how much effort the JNA put in to place the

16 paramilitaries under their control?

17 A. Well, no. In my area, they gave logistic support to them.

18 Q. Well, do you know that Radovan Karadzic reacted with respect to

19 the operations of the paramilitaries in Gacko?

20 A. I don't know about that. I'm not aware of that. I'd like to see

21 the document.

22 Q. I'll let you see an order here. I have an order.

23 THE ACCUSED: [Interpretation] Mr. May, it's been translated into

24 English, of the 3rd of July, 1992. That's the date of it.

25 MR. MILOSEVIC: [Interpretation]

Page 27798

1 Q. The Presidency of the Serb Republic of Bosnia-Herzegovina, at a

2 meeting held on the 3rd of July, proclaimed an order to undertake an

3 investigation on the activities of paramilitary groups in the area of the

4 municipalities of Gacko and Nevesinje - which makes it your municipality

5 and the neighbouring municipality - and it charges the Ministry of the

6 Interior of the Serb Republic of Bosnia-Herzegovina to conduct an

7 investigation on the activities of paramilitary groups in the

8 municipalities of Gacko and Nevesinje. And after the investigation, the

9 ministry will table an extensive report with the facts established in the

10 area of the two municipalities mentioned. The President of the

11 Presidency, Dr. Radovan Karadzic. That's the signatory, and you can take

12 a look at that document.

13 JUDGE MAY: Yes. Let the witness have a look at the original, the

14 B/C/S version, and we will have the translation.

15 THE ACCUSED: [Interpretation] Yes.

16 THE WITNESS: [Interpretation] Yes. I -- I don't know -- I am not

17 aware of this document, but it is quite obvious here that they were

18 working in just one direction. At least that's my opinion, to start

19 ethnic cleansing in Gacko which was to take place soon after this act,

20 this document, Mr. Milosevic. I don't think that Mr. Karadzic considered

21 Serb units to be paramilitaries. It is the Muslim civilian population

22 here of an unarmed, empty-handed population. They considered that to be

23 paramilitary organisations and that's where this is addressed to, because

24 this was a forerunner. This preceded at, I would say, the best time to

25 undertake preparations for ethnic cleansing in Gacko which began on the

Page 27799

1 17th of July of this same year, 1992.

2 MR. MILOSEVIC: [Interpretation]

3 Q. All right, Mr. 1122. I really -- I've really heard a lot of

4 things here, but can you really deduce from this document which states

5 that the actions of paramilitary formations are to be established in the

6 municipalities of Gacko and Nevesinje and you precisely said that there

7 were no Muslim paramilitary formations, that this, in fact, refers to the

8 Muslim and not to all paramilitary formations and that this, in fact, was

9 addressed as an in -- as a set of instructions for ethnic cleansing. What

10 are the grounds that you're able to state that on because you read it from

11 start to finish? I read it out to you both these two points.

12 A. Well, this order is quite clear. I can see what it says, but I

13 think that it is actually intended in quite a different direction, because

14 I don't think that anybody looking around that -- that they would go on

15 providing logistic support and support generally and be a component part

16 of the armed forces unless that was the case. But one -- what was afoot

17 here was that you had to invent an enemy and that there were Muslims

18 somewhere.

19 JUDGE MAY: Wait a moment. There is an objection from Mr. Groome.

20 Yes, Mr. Groome.

21 MR. GROOME: Your Honour, I would query the witness's ability to

22 deal with the order. The order does refer to an extensive report. I

23 would ask that that be placed before the witness if it is so available so

24 that he may be able to more properly comment on what it is.

25 JUDGE MAY: He can deal with this. Of course he can. He can look

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Page 27801

1 at it and he's made his comments on it. Now, Mr. Milosevic, your time is

2 coming up. You've got two minutes left.

3 THE ACCUSED: [Interpretation] Well, I should like to ask you to

4 extent my time a little because I can't complete my cross-examination of

5 this witness within the space of two minutes

6 [Trial Chamber confers]

7 JUDGE MAY: Very well. What we'll do is this. We will take the

8 break now. We will then give you ten minutes more and conclude the

9 witness then.

10 Do you want this document exhibited, Mr. Milosevic?

11 THE ACCUSED: [Interpretation] Yes.

12 JUDGE MAY: Very well. It will be given the next D number.

13 THE REGISTRAR: Defence Exhibit 202, Your Honour.

14 JUDGE MAY: We will adjourn now.

15 Witness B-1122, you've heard there is another ten minutes

16 cross-examination. There may be a few more minutes, a few more questions

17 after that. Could you remember not to speak to anybody during this break

18 until your evidence is over. Don't speak to anybody about it.

19 Very well. We will adjourn now

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

21 --- On resuming at 10.52 a.m.

22 JUDGE MAY: Yes, Mr. Milosevic.

23 MR. MILOSEVIC: [Interpretation]

24 Q. Mr. 1122, please give brief replies to my questions because we

25 have very little time.

Page 27802

1 Is it true that General Perisic at that meeting agreed to your

2 proposal that in order to protect the civilians joint patrols had to be

3 established composed of one Muslim, one Serb, and one JNA soldier?

4 A. Yes.

5 Q. And for paramilitaries to withdraw from the municipality? You

6 even made a joint statement about that. Is this correct?

7 A. Yes.

8 Q. Is it true that several hundred Serbs gathered in front of the

9 police station and that the JNA practically saved you on that occasion?

10 A. Mr. Milosevic, Perisic promised this but it was never implemented,

11 and --

12 Q. I didn't hear you properly. What did you say?

13 A. General Perisic promised these joint patrols but this was never

14 actually implemented. It was just an empty promise. As for the arrests

15 you mentioned on the 1st of June, it's true that in front of the police

16 administration while the negotiations were going on there were several

17 hundred people present. These were reservists, not paramilitaries. They

18 were shooting in the air, drinking, running amok, and the Muslim

19 negotiators were under enormous pressure.

20 Q. And did the army save you on that occasion?

21 A. The army wasn't there.

22 Q. But nothing happened?

23 A. Well, that's when the arrests began, and they continued.

24 Q. Tell me, is it true that on the 16th of April, 1992, you sent a

25 message on behalf of the Muslim people of Gacko to the Territorial Defence

Page 27803

1 Staff of Bosnia-Herzegovina where you say: "That the Muslim people of the

2 municipality of Gacko on the day the TO of Bosnia and Herzegovina was

3 established were put under command of that institution and please count on

4 our full contribution and participation and all the tasks you entrust to

5 us." Is this correct?

6 A. I'm not familiar with this document.

7 Q. So it's not correct?

8 A. What I'm saying is I'm not aware of the document. I'm not saying

9 it's the not true, but I am not aware of this document.

10 Q. Very well. Is it true that in May 1992 sabotage was carried out

11 in the thermonuclear -- thermoelectric plant?

12 A. No.

13 Q. And it was perpetrated by Zijad Mehic according to the

14 investigation who destroyed a conveyer belt.

15 A. It was not sabotage. I do know that a belt was damaged but not

16 due to sabotage.

17 Q. And did this Mehic then flee to Fazlagica Kula near Gacko?

18 A. He didn't flee there, he lived there. It's the village of Kljuic.

19 Q. Is it true that the attempts of the organs of law and order to

20 bring him in were -- ended in shooting?

21 A. This is not correct. There was a patrol of some 20 armed men who

22 went to that village purportedly to arrest him, but it was then that the

23 shooting on Gacko started. So it's not true that they went to arrest him

24 and that they were shot at. That's not true.

25 Q. Is it true that in the meantime the Muslim part of the population

Page 27804

1 withdrew to Fazlagica Kula and Borac?

2 A. Borac, yes that's true and one part remained in the town of Gacko.

3 Mostly intellectuals who thought that nothing would happen, that they owed

4 nothing to anyone and that nothing would happen. Later they were rounded

5 up with their families, separated off, and atrocities were committed

6 against their families.

7 Q. Is it correct that at the time you're testifying about you had

8 about 1.500 armed men in your ranks?

9 A. No, we didn't have any kind of formation either armed or unarmed.

10 We lived -- we simply lived in the forests, in the woods, but we weren't

11 organised.

12 Q. Well, as you weren't organised or armed, as you say, and I have

13 information that the 1.500 men under arms who perpetrated the terrorist

14 attack on the village of Zaborani in Nevesinje municipality on the 28th of

15 June.

16 A. This is not true. As for Gacko municipality, I'm hearing this for

17 the first time, and I'm certain that this is not true.

18 Q. Do you know that six Serbs were killed on that occasion? Do you

19 remember that? Even a 90-year-old man called Milan Milovic [phoen], and

20 Asanka Milovic [phoen], aged 80?

21 A. What village?

22 Q. Zaborani, near Nevesinje.

23 A. That's a different municipality, I don't know about that. This is

24 the first time I've heard of it. I don't think that's true.

25 Q. It's your neighbouring municipality?

Page 27805

1 A. Yes.

2 Q. So these fighters weren't there at the time?

3 A. No.

4 Q. There was no fighting between the Serb and Muslim forces around

5 Fazlagica Kula?

6 A. No, there was no fighting, but the Muslims when the village was

7 attacked, yes, there were men who had some weapons, some hunting weapons,

8 but there were very few of these weapons. I don't think anyone had

9 military weapons. And they did return fire, but this was so insignificant

10 and while the families were fleeing to Bjelasnica, the civilians were

11 running off to the mountain of Bjelasnica.

12 Q. What do you know about the Gatacki Battalion of the army of Bosnia

13 and Herzegovina and its formation?

14 A. Nothing. The Gatacki Battalion -- I apologise, yes. This was

15 established, I think, on the territory of Mostar, after we were expelled

16 from Gacko to Mostar.

17 Q. And this Gatacki Battalion, was it not formalised on the 3rd of

18 November, 1992, according to an order, and wasn't it part of the Mostar

19 brigade?

20 A. This is military information. I know that in Mostar there was a

21 Gatacki Battalion, but I don't know anything else about it.

22 Q. And when was this Gatacki Battalion set up?

23 A. It was formed in Mostar when we were expelled, and when we arrived

24 in Mostar that's where it was set up. I don't know the date.

25 Q. Are you trying to say that there were no armed Muslim formations

Page 27806

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Page 27807

1 on the territory of Gacko at the time you are testifying about?

2 A. Yes, that's correct.

3 Q. Is it correct that this independent battalion of the Muslims of

4 Gacko was called Sargan?

5 A. Yes, correct.

6 Q. So first it was called Sargan and then it became part of the

7 Mostar brigade by decision of the Supreme Command of the Army of Bosnia

8 and Herzegovina. When was it set up as Sargan?

9 A. I told you; when we arrived in Mostar, when they came to Mostar,

10 the free territory.

11 Q. It was called Sargan earlier, before they came to Mostar.

12 A. No. It didn't exist before at all.

13 Q. Very well. Is it correct that the conflict in your area was a

14 conflict between the Serbian units from the area and the Muslim units from

15 the area?

16 A. There was no conflict. There was persecution. We -- that is, the

17 Muslim side didn't have anything to fight with, nor did we want a

18 conflict. We were simply saving our lives. There was a total of 3.800

19 civilians, including women, children, elderly.

20 Q. In paragraph 39, you say that you -- the women and children were

21 left in the Muslim villages and that the men tried to break through. How

22 could they have tried to break through if they didn't have weapons?

23 A. They were retreating. I don't know. I'm not a military person, I

24 don't know what "breaking through" means. They were hiding. But this is

25 correct. These villages were on the territory of Kalinovik municipality.

Page 27808

1 When we crossed Zelengora, going in the direction of Olovo, that's when

2 what it says here happened. Yes, this is correct.

3 Q. Who organised the departure of the Muslims, large number of

4 Muslims from Gacko?

5 A. It was self-organised. Everybody was fleeing, trying to save

6 themselves.

7 Q. Were there any problems? According to my information, there were

8 very moving scenes and neighbours weeping, Serbs and Muslims, when they

9 were separating, saying farewell.

10 A. This was not as theatrical as you described, but there were very

11 positive examples of Serbs helping certain families, friends of theirs.

12 Yes, this did happen. It was very positive.

13 JUDGE MAY: Mr. Milosevic, the time is now up, but you can ask one

14 more question.

15 THE ACCUSED: [Interpretation] Very well.

16 MR. MILOSEVIC: [Interpretation]

17 Q. Were there very many examples of good relations between Serbs and

18 Muslims in Gacko, and that nobody forced the Muslims to leave Gacko?

19 A. No, Mr. Milosevic. They were forced to leave Gacko. Gacko has

20 among the largest numbers of casualties. Five per cent of the population

21 was killed or wounded. There were many positive -- or some positive

22 examples but not too many.

23 Q. Very well.

24 JUDGE MAY: Yes, Mr. Kay.

25 Questioned by Mr. Kay:

Page 27809

1 Q. Witness, just dealing with matters that Mr. Milosevic raised a

2 moment ago, did you, as a prominent member of the SDA in your area, help

3 to organise the Muslims from leading -- leaving the territory?

4 A. To be quite honest, I was not as prominent a person as you seem to

5 think. I think that there was general chaos and that people were simply

6 attempting to save their lives. I don't think it was organised.

7 Q. In relation to the earlier decisions by the SDA not to respond to

8 the mobilisation call for the JNA during the war in Slovenia, was that a

9 decision that was made on a political level by your party?

10 A. You see, when the attack on Slovenia and Croatia began, the

11 so-called Yugoslav army, which had become the army of one nationality,

12 there was an inter-party agreement between the SDA and the SDS, and it was

13 then that we agreed that the Muslims of Gacko would not join the war. It

14 was not their war. We would only defend ourselves with all the people who

15 wanted to live in the municipality when our municipality was attacked.

16 That was it. I think the SDS has this document. Our representatives were

17 unable to take these documents with them when they were fleeing.

18 Q. So there was a mobilisation call that went to all citizens, but

19 citizens who were a member of your party, the SDA, did not respond to that

20 call.

21 A. You see, this was a call for the reservists of the Gatacki

22 Battalion. I don't know whether it was a battalion or brigade on the

23 territory of Gacko. This existed before the war, and it was a reserve

24 unit which had exercises. There were Bosniaks.

25 I think at that one or two men did respond. The party didn't tell

Page 27810

1 people they had to go or that they shouldn't go. Everyone could decide

2 for themselves as they saw fit.

3 Q. But in your statement, and I'm looking at paragraph 9, it says:

4 "We discussed the mobilisation call in this manner and made a

5 recommendation that SDA did not have to answer the mobilisation call."

6 So it seems on a political level you were telling the people who

7 supported you that this was something that could be avoided. And in

8 paragraph 10, you state: "More mobilisation calls were issued, but we

9 managed to avoid joining in the call-ups."

10 So the question is this: Didn't you, your party, and you were a

11 member of that party, create the condition whereby your people did not

12 assist the JNA, did not involve themselves? You were creating the

13 conditions about which you then complained.

14 A. You see, in paragraph 9 it says: "In May or June of 1991, before

15 the war in Slovenia started, SDS organised the first mobilisation of

16 reserves. SDS and SDA had separate party commissions and then came

17 together." So we met. The commissions did, that is. "To make a joint

18 decision acceptable to all." And we agreed that the Muslims would not

19 join the war. This was between the SDS and SDA, and everything was based

20 on this document, everything that happened later.

21 Q. How do you deal with then that which is said in paragraph 10:

22 "More mobilisation calls were issued, but we managed to avoid joining in

23 the call-ups."

24 That gives an impression that on a national level, there was a

25 request for you to be involved, members of your party, but you were

Page 27811

1 avoiding committing people to the service of the JNA.

2 A. You see, there was a war, and nobody felt like going to war if

3 they could put it off. And the JNA at that party -- at that time

4 represented a single nationality.

5 Q. Just dealing with the political meetings that were happening at

6 this time, and I'm looking at paragraphs 5 and 6 of your statement. You

7 mention SDS meetings, but would it be also right to say that your party,

8 the SDA, were also holding local meetings?

9 A. The SDA party was established in Gacko on the 1st of September in

10 the town, on a field. We went neither to a church nor to a mosque,

11 because our aspirations were democratic. And this was the way we worked.

12 We did not hide behind any religious or other institutions.

13 Q. So the answer to the question is this: Is yes, your party, the

14 SDA, was also holding meetings.

15 A. Yes. This was the constituent meeting. We didn't organise

16 events. We had our internal structure. We had sessions, but the only

17 public meeting was the meeting at which the party was founded, the

18 constituent meeting.

19 Q. So those meetings that your party was holding, they were meetings

20 that were only open to those members of the SDA; is that right?

21 A. No, no. Anyone who wanted could -- wanted to could attend.

22 MR. KAY: Thank you. No further questions.

23 MR. GROOME: No re-examination, Your Honour.

24 JUDGE MAY: Witness B-1122, that concludes your evidence. Thank

25 you for coming to the International Tribunal to give it. You are now free

Page 27812

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Page 27813

1 to go, but would you wait until the blinds have come down.

2 THE WITNESS: [Interpretation] Thank you.

3 [The witness withdrew]

4 JUDGE MAY: Yes, Mr. Nice.

5 MR. NICE: Your Honour, while we're in closed session --

6 THE REGISTRAR: We're in public session.

7 MR. NICE: I'm sorry. I beg your pardon. May we go into private

8 session very briefly for two matters.

9 [Private session]

10 [redacted]

11 [redacted]

12 [redacted]

13 [redacted]

14 [redacted]

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Page 27816

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7 [redacted]

8 [redacted]

9 [Open session]

10 THE REGISTRAR: We're in open session, Your Honour.

11 JUDGE MAY: Yes, Mr. Nice.

12 MR. NICE: Your Honour, the next witness, who went by the number

13 C-028, is going to give evidence in open session. A summary of evidence

14 was taken from her when she was last here on an occasion when the evidence

15 couldn't be given, the accused being unwell. A copy of that was served,

16 both in English and in B/C/S, on the accused last week or before -- two

17 weeks ago. The witness returned yesterday and signed the B/C/S version

18 subject to one correction, I'm sure a small correction, as an accurate

19 account. We make the same application that I explained I would make in

20 respect of all witnesses, and provided the documents to the Chamber I

21 think yesterday for consideration, namely that her evidence in chief may

22 to such extent as the Chamber thinks appropriate be covered by her

23 adoption of the signed summary.

24 JUDGE MAY: This is the first of this application that we have

25 known. Also we have not had the opportunity yet of thoroughly looking at

Page 27817

1 this document. Is there any part of the document which deals with the

2 accused himself?

3 MR. NICE: Yes, there are several parts. Indeed, it's probably

4 better to say many parts. I can identify for you paragraph numbers where

5 he's dealt with specifically with ease. It's paragraphs 2, 6, 10, 11, 12,

6 13, 14, and then there's quite an extensive passage starting at paragraph

7 16 and going on to paragraph 22 where his -- in fact going on right over

8 to paragraph 25, which is an account of support, and his name features,

9 the accused's name or identity, features specifically in paragraphs 18,

10 20, 21, 22, 23, and 25. So that one way of dealing with that passage of

11 evidence would be, if the Chamber thought it appropriate, to take the

12 summary of events without reference to the accused from the summary itself

13 but to get her to give all the detail that she is of the accused's direct

14 knowledge of those matters.

15 The accused then features in paragraphs 26 and 27. Over the page

16 in paragraph 7 [sic] at the foot of paragraph 29, and paragraphs 33, 34,

17 and 35, 38, 41, 42, and is mentioned again in paragraph 48.

18 MR. KAY: 50 and 51.

19 MR. NICE: 50, 51 and 53, I think. Thank you, Mr. Kay.

20 JUDGE KWON: Can the -- sorry. I wonder the date when the accused

21 was served with this document, be confirmed by the amici or the accused.

22 MR. NICE: The accused and amici each had it two weeks ago and the

23 precise date is coming from Ms. Dicklich, I think, and it went in both

24 English and B/C/S. English was two weeks ago, I don't have the precise

25 date, and the B/C/S was a week and a half ago, I think. I can get --

Page 27818

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Page 27819

1 JUDGE MAY: I'm concerned about the book which I see is here.

2 MR. NICE: I'm not asking for her to produce the book by going

3 through it. The importance and significance of the book includes that

4 everything that she's saying is contained within the book. The document

5 that's been not only available for general comment and challenge but has

6 been specifically adopted by Minister Simovic who features, of course,

7 extensively in her evidence. And there's a document at the end of your

8 exhibits signed by him effectively acknowledging, as she will say in

9 evidence, that he reviewed and checked for accuracy what she had said.

10 JUDGE MAY: I'm concerned about the principle of admitting these

11 books. I am not happy about the notion of a whole mass of information

12 coming in in this way. And speaking for myself, I would not admit it. If

13 there is some relevant part of the witness's evidence which she wishes to

14 refer to to the book, then the passage may be admissible, but the notion

15 of just introducing a whole book written by somebody else seems to me to

16 be wrong in principle.

17 MR. NICE: This book's written by her, but --

18 JUDGE MAY: I'm sorry. I'm mistaken. Yes. Very well, if it's

19 written by her, of course it's a different position, but again, we need to

20 be sure that we just get the relevant parts in.

21 MR. NICE: Your Honour, I don't disagree. Can I respectfully

22 suggest that one reviews the position at the end of the cross-examination,

23 because, in a position like this, if a witness gives evidence sourced in a

24 book but isn't taken to the book to challenge or for further passages,

25 then the book really isn't going to add materially to the witness's

Page 27820

1 evidence and we wouldn't want to seek to burden you with it. But can I

2 also respectfully suggest we deal with it on a case-by-case basis because

3 there may be other witnesses of a different type who produce books and it

4 maybe sensible to work on that basis.

5 JUDGE MAY: That seems a sensible way to go on with it. We will

6 then consider the book at the end of the evidence altogether and see how

7 much of it we need put in.

8 We will consider the matter of admitting the statement under

9 89(F). Speaking for myself, I would think that it's right that the matter

10 dealing with the accused should be given in full. Also any other matter

11 which really we should hear and the accused should hear so that he

12 understands the relevance of the document.

13 Yes, Mr. Tapuskovic.

14 MR. TAPUSKOVIC: [Interpretation] Your Honours, I should like to

15 caution you of one matter. Judging by what she says, there's no dispute

16 that she worked on the book but that the book was -- went through a

17 redaction by Mr. Simovic in its entirety, and she states that herself. So

18 she doesn't say she wrote it herself alone but that her text was also

19 revised by Minister Simovic. So that's what I'd like to point out and ask

20 you to bear in mind in the proceedings.

21 [Trial Chamber confers]

22 JUDGE MAY: We'll grant the application under Rule 89(F), subject

23 to the evidence relating to the accused, any evidence relating to him to

24 be given live.

25 MR. NICE: We're much obliged. May the witness come in.

Page 27821

1 [The witness entered court]

2 JUDGE MAY: Yes. If the witness would take the declaration.

3 THE WITNESS: [Interpretation] I solemnly declare that I will speak

4 the truth, the whole truth, and nothing but the truth.

5 JUDGE MAY: Thank you very much. If you'd like to take a seat.

6 WITNESS: DOBRILA GAJIC-GLISIC

7 [Witness answered through interpreter]

8 Examined by Mr. Nice:

9 Q. Your full name, please.

10 A. My name is Dobrila Gajic-Glisic.

11 Q. Ms. Gajic-Glisic, did you make a statement to officer -- to

12 representatives of the Office of the Prosecutor, and subsequently, while

13 here in The Hague, has a summary of your evidence been made on 11 sides,

14 in both English and B/C/S, that you have had a chance to review in detail

15 including yesterday?

16 A. Yes.

17 Q. Did you check the B/C/S version for its accuracy, and did you sign

18 the document yesterday to signify that it was indeed an accurate account

19 in summary of evidence you can give?

20 A. Yes.

21 MR. NICE: May that document, please, be exhibited and given its

22 own number.

23 THE REGISTRAR: 567, Your Honour.

24 JUDGE KWON: Have we received the signed version?

25 MR. NICE: It should be with you, I think.

Page 27822

1 Q. Ms. Gajic-Glisic --

2 JUDGE MAY: Yes, Mr. Nice.

3 MR. NICE:

4 Q. Ms. Gajic-Glisic, the Trial Chamber has agreed to accept the

5 signed summary as your evidence-in-chief subject to your dealing live and

6 in sufficient detail with all matters that occur -- concern the accused

7 himself, and so I shall be asking you to deal with matters focusing on

8 what you can say about particular topics in relation to the accused. Do

9 you follow?

10 A. Yes.

11 Q. To give some context for this thus abbreviated evidence, is it

12 right that following experiences that you cover in your summary, did you

13 write a book about these events and other matters?

14 A. Yes, I did write a book called The Serbian Army, Srpska Vojska,

15 first published in 1992 in August. Before that, I also published a series

16 of ten articles in a magazine -- a weekly magazine called Nin.

17 Q. That book, which is not going to be exhibited at the moment to the

18 Judges, they won't be taking it away with them, but that book which is

19 available to the accused and the amici for reference purposes, was it

20 checked as to its content for accuracy by a man called Simovic, of whom we

21 will be hearing in due course?

22 A. That book and all the notes from the defence minister's cabinet

23 were written following my work assignment and orders from General Tomislav

24 Simovic. As we concluded our work period, General Simovic checked the

25 exactitude of my notes, handwritten notes, and I have all these

Page 27823

1 handwritten notes with me. He also checked through the first printing of

2 the texts of the book The Serb Army, the proofs.

3 Q. When you say "checked," did he check in the sense of saying that

4 they were accurate or draw to your attention errors or changes that he

5 thought were required to be dealt with?

6 A. Both. There weren't many errors, just some slight ones, and he

7 put those right. And if Their Honours would like to take a look at the

8 documents, I have them with me.

9 Q. Thank you. We'll do that if and only if it becomes necessary, I'm

10 sure.

11 I'm now going to take you chronologically through events.

12 Paragraph 2, and we can deal with this very briefly in light of the fact

13 that the summary is before the Judges as evidence. Did you suffer

14 difficulties at work in May of 1989 and subsequently, and following that,

15 did you go to Belgrade with somebody called Moma Brkic, and did he take

16 you to see the accused?

17 A. Yes, I did have some problems, mostly for my writings and my

18 opinions and disagreement with my work environment while I was working

19 as --

20 Q. I'm going to interrupt you because all this material is before the

21 Judges, so having told us that you were taken to see the accused, just

22 tell me this: To whom did the accused then refer you?

23 A. Mr. Moma Brkic, who was the editor of Komunist of which I was a

24 correspondent, took me to an office, actually directly to the offices of

25 the president, Comrade Slobodan Milosevic, and Comrade Milosevic invited

Page 27824

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Page 27825

1 Kertes and Kertes called Radmilo Bogdanovic. It was thanks to the

2 assistance given me by Comrade Slobodan Milosevic at that point in time

3 that I was able to overcome many of my difficulties, and to the present

4 day I think that I am alive thanks to Mr. Slobodan Milosevic, and this is

5 an occasion for me to express my gratitude and say thank you to him.

6 Q. Very well. Let's move on now to paragraph 5 in the summary. You

7 don't have the summary before you, but you no doubt can if you would like

8 to have it there, but I want you to help just from your recollection of

9 events.

10 You became the chef de cabinet to Minister Tomislav Simovic?

11 A. Yes.

12 Q. He told you make a record of events that were happening, and this

13 is all in the last quarter of 1991. Did he explain to you and just in a

14 sentence, please, Ms. Gajic-Glisic. Just in a sentence, what did he say

15 to you why you should keep a record of events?

16 A. May I answer in more than one sentence?

17 Q. Very brief for the moment.

18 A. I went to see Mr. Tomislav Simovic, thinking that General Jokic

19 was there, and that I could complain of the problems I was having in

20 Cacak --

21 Q. I'm going to interrupt you. This material is before the Judges.

22 They know the history because they can read it. Could you please just

23 explain very briefly what the reason was that Tomislav Simovic gave for

24 why you should record events that were happening?

25 A. General Simovic said that he didn't agree with the policy being

Page 27826

1 pursued by the President of Serbia, Slobodan Milosevic, and that because

2 people born in Serbia were being mobilised and called to attend military

3 training and then were being sent to war areas, the theatre of war, and

4 that war laws were not being respected and that he as a general and as a

5 man could not take this. He did not agree with it. And he wanted to see

6 all the measures of preparation and emergency being respected for a state

7 of emergency, that urgent measures were to be introduced faced with an

8 emergency situation, and then only once that had been done could people be

9 to where the action was.

10 Do you want me to explain in greater detail?

11 Q. No. That will do. You've set out at the foot of paragraph 5 one

12 of his observations which doesn't relate to the accused, and so I can read

13 it. He also said that, "the current events in Yugoslavia would be

14 something the whole world would prosecute us for." Is that correct?

15 A. Oh, yes.

16 Q. Thank you. That's fine.

17 A. I would like to explain, please. Mr. Simovic --

18 Q. I'm sorry. You're going to have to be guided by me because it may

19 be these matters will come up in cross-examination, but we must move on to

20 paragraph 6.

21 Simovic had been appointed to become Minister of Defence of

22 Serbia. You learnt from him and all your dealings in his office who

23 appointed him and with what objective. Can you tell us, please, who

24 appointed Minister Simovic and then tell us what the purpose of his

25 appointment was?

Page 27827

1 A. General Simovic was the commander of the 3rd Skopje Army District,

2 and according to what he told me, he was called upon by General Kadijevic

3 to go to Serbia for an urgent meeting and that he was supposed to talk to

4 President Milosevic in order to be appointed to the post of Minister of

5 Defence of Serbia. General Simovic took over duties from General Jokic

6 post haste and directly pursuant to our rules the minister is appointed by

7 the president of -- or, rather, the Prime Minister of Serbia who was in

8 Zelenovic, and it was okayed by the Assembly. General Simovic was

9 officially appointed to the post of minister, Minister of Defence of

10 Serbia on the 26th of September at an Assembly meeting of the Assembly of

11 Serbia.

12 Q. What, if anything, did the accused tell him was to be his

13 principle function, and what, if anything, did the accused tell him about

14 the publicity to be associated with this function or not?

15 A. General Simovic told me that his first and foremost task was to

16 work on the draft law for the armed forces of Serbia. The constitution of

17 Serbia had already been adopted several months prior to that, and pursuant

18 to that constitution all the laws were supposed to have been passed by the

19 31st of December, 1991. As General Simovic told me, the law governing the

20 armed forces was to be worked on secretly and quickly. And this was to

21 perform the backbone of the Serb army, which was to be composed of

22 volunteers and that the Yugoslav People's Army was to be disbanded and

23 transformed to become the Serbian army.

24 MR. NICE: Your Honour, there are several exhibits to be produced.

25 I think they are before you in a file. May be the file be given a number?

Page 27828

1 We know that the largest item is likely to be withdrawn at the end of the

2 day. May the bundle as it stands at the moment with its tabs be given --

3 THE REGISTRAR: 568, Your Honour.

4 MR. NICE:

5 Q. And if we can look very briefly at tab 1 for the highlighting

6 which will assist the Chamber. You can see in tab 1 of Exhibit 568 in a

7 newspaper article three highlighted passages. The first reads and it

8 comes from your Minister: "The JNA as the foundation --" this is on page

9 1 if you can find it in the hard copy, about 6 lines down -- "The JNA as

10 the foundation of our armed forces engaged the Territorial Defence units

11 as well and has until now been in the function of protecting the

12 population of the Serb borderlands through its combat activities."

13 If we go to the second page, towards -- second column, I think it

14 may be, but the second page of the English version. The following: "It

15 is clear that through the transformation of our existing armed forces, the

16 JNA before all, and within the context of the outcome of the Yugoslav

17 crisis, the answer to something called the Armed Forces of the Republic of

18 Serbia is to be found."

19 The third highlighted passage on page 3 reading: "It is difficult

20 to accurately determine --" if the Chamber -- if it can't come up on

21 Sanction it's on page 3 of 5, it's in the middle of the page, just above

22 the bolded subheadline. "It is difficult to accurately determine the

23 exact numbers of volunteers at the time being since there are multiple

24 ways of volunteering and the assignment of volunteers. However, it is

25 sure that they are the framework of deployed troops at the time being

Page 27829

1 alongside the conscripts and soldiers doing their military service in the

2 JNA."

3 And just yes or no, please: Does that newspaper article of an

4 interview with your minister reflect what you've just said about the

5 functions in which he was engaged?

6 A. He gave this interview I think to Mr. Ivica Dacic who was sent to

7 our cabinet directly from the cabinet of President Milosevic, and these

8 sentences have been extracted from the context of the entire text. I

9 think in the spirit of our language, you have to look at the entire

10 paragraph for the whole text. However, the answer is yes.

11 Q. Thank you. Paragraph 10 of the summary. You having organised

12 that your minister issue a press release, did your minister then have to

13 go to see the accused; and if so, tell us, please, what you learnt about

14 that meeting.

15 A. Could you please explain your question?

16 Q. You were ensured by persuasion of Simovic that there should be a

17 press release. Following the press release, did Minister Simovic go to

18 see the accused; and if so, what did you learn the accused had said to

19 him?

20 A. Do you mean the information about the bill on the armed forces of

21 Serbia?

22 Q. Yes, I do.

23 A. If this is the information you want, I considered that everything

24 that was not published or written down would be as if it had never

25 happened. That's why I wrote down this information about the beginning of

Page 27830

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Page 27831

1 the drafting of the bill on the armed forces of Serbia, and Minister

2 Simovic went to see President Milosevic in order to report to him about

3 how and why this information reached the press.

4 As far as I can recall, President Milosevic thought that this

5 information had been issued by Buda Kosutic, the Deputy Prime Minister,

6 because he was the one who most frequently had contacts with the media at

7 the time. And Mr. Simovic told me, "We have created an unfortunate

8 situation for Buda, because President Milosevic has blamed him and he is

9 not to blame." In fact, I was to blame.

10 Q. Did the accused indicate whether he favoured publicity and whether

11 there were to be more press releases about your work?

12 A. As far as the minister told me, President Milosevic said that this

13 was to be worked on secretly and that no information was to be given to

14 the media about the law on the armed forces of Serbia.

15 Q. The transcript refers to Buda Kosutic in one place. I think the

16 name that you've given is "Budimir." Is that correct?

17 A. Budimir Kosutic, who at that time was the Deputy Prime Minister of

18 Serbia. I think he was a university professor, and he was a very

19 important person at the time.

20 Q. Paragraph 12. On the 12th of December -- paragraph 11. On the

21 12th of December of 1991, was there supposed to have been a debate by the

22 government of Serbia on the adoption of the draft law on the armed forces?

23 A. Yes. We agreed with President Zelenovic that the draft bill on

24 the armed forces of Serbia should be presented to a narrow circle of the

25 cabinet and that it should be discussed at a cabinet session.

Page 27832

1 Q. Did you learn, from the accused's secretary on this occasion, of

2 events that happened in the accused's cabinet?

3 A. Before the beginning of the session, the secretary of

4 Mr. Milosevic's cabinet, Mira, called me up and said, "Dobrila, don't give

5 any information to the media about the draft bill on the armed forces of

6 Serbia because this could be a big problem. General Panic has just rushed

7 in in full war gear with his suite to see Mr. Milosevic, and solutions

8 will follow very soon."

9 Q. What did you discover about those solutions? What happened

10 consequent on Panic's arrival in that way?

11 A. I didn't take this secretary Mira so seriously, and I didn't tell

12 General Simovic about this right away. When he got back from the cabinet

13 session, he came back very quickly, and he said, "Zelenovic has resigned."

14 I said, "How could he have resigned?" And he said, "He explained,

15 explained, he made a brief statement in one or two sentences that he

16 distributed, saying he was resigning, and none of us ministers knows what

17 this is all about." So I asked Minister Simovic, "Well, what does it

18 mean?" And he said, "Well, it means that the government has fallen." I

19 said, "How has it fallen?" And he said, "Well, the government has fallen

20 and all of us with it." And then I said, "Do you know what the secretary

21 of President Milosevic told me? She said that General Panic rushed in to

22 see President Milosevic and that solutions will follow very soon."

23 General Simovic then said, "Oh, God. Do you know what this means?" I

24 said, "General, what does it mean?" He said, "This means that General

25 Panic has just committed a coup d'etat." "What sort of coup d'etat?" I

Page 27833

1 said. And he said, "It's coup d'etat."

2 Q. In the event - and this is in December - was Simovic himself

3 replaced following these events by General Marko Negovanovic?

4 A. Yes.

5 Q. So that your period of time with Simovic was from September until

6 the 12th of December, as your summary makes clear, you staying on in the

7 office until mid-January 1992.

8 A. Yes.

9 Q. Now turning to another topic, the relationship between Simovic and

10 the accused, paragraphs 12 to 15. During your time in this office, with

11 what frequency did Simovic speak to the accused?

12 A. As far as I can remember, General Simovic talked to President

13 Milosevic almost every day. I say "almost every day" because there were

14 days when he talked to him several times, more than once, but there were

15 other days when he didn't talk to him at all. And I can tell you the

16 exact days when he did not talk to him.

17 Q. Your records, if that becomes necessary, I'm sure they can be

18 looked at.

19 Did Minister Simovic have information about what was happening on

20 the battlefield reported to him? And if the answer to that question is

21 yes, can you tell as to what degree he passed that information on to the

22 accused?

23 A. The information about what was happening in the battlefield came

24 from various sources. These were few and far between, and they were often

25 incomplete. They arrived from people who came to the cabinet to complain

Page 27834

1 to us. We received the most information from the staff of Vojislav

2 Seselj. We also got information from Mr. Zoran Sokolovic, who was a

3 minister, and from time to time we got information from General Aco

4 Vasiljevic. All important information that required a speedy response

5 were immediately transmitted to President Slobodan Milosevic.

6 Q. Information coming from the battlefield, did that include

7 information about heroic deeds of volunteers but also information about

8 such events as looting?

9 A. Most of the pieces of information were about the heroic deeds of

10 volunteers protecting the lives of the Serbian population in the

11 war-affected areas, liberating the sick and the wounded from the areas.

12 There was terrible information about children locked up in barracks in

13 Croatia, but there was also information pertaining to various kinds of

14 looting, looting of both Serbian and Croatian houses.

15 Q. When Minister Simovic went to see the accused, and indeed when he

16 went to the government, did he act entirely and always on his own

17 initiative with and his own opinion or was he to any extent subordinate to

18 the opinions of the accused?

19 A. When Minister Simovic went to see President Milosevic, it was

20 mostly because he was called from the cabinet of President Milosevic. The

21 general would put on his cap, and we would usually have a brief -- no,

22 already prepared as to all the things he was to tell President Milosevic

23 about. And most often he came back from President Milosevic's cabinet

24 very nervous.

25 Q. Did you once see him in the accused's cabinet and see the dynamic

Page 27835

1 of the two men, how they were positioned and so on?

2 A. I often disagreed with the president, that is, with my minister,

3 my boss General Simovic. I would say to him, "Why didn't you tell Comrade

4 Milosevic this or that? Why didn't you tell him such things?" And I said

5 to him [as interpreted], "Well, he's my president. I can't address him

6 the way you address people, Dobrila, you tell everyone everything to their

7 faces." And I said, "I will tell him everything you can't tell him." And

8 he said, "Well then, you come with me." I accompanied the general

9 intending to stand before Mr. Milosevic and tell him all the things I was

10 writing about and everything I wanted to tell him. When we reached the

11 door, President Milosevic's door, the general went in, he was wearing his

12 uniform. He went in first, and President Milosevic was sitting on a

13 chair. I think he was smoking at that moment. The general stood at

14 attention and Goran Milinovic arrived. He was the chef de cabinet of

15 Mr. Milosevic, and he stood next to me and he said, "We're going to my

16 office. We will talk to each other as one chef to another." And General

17 Simovic was expecting me to come in after him, but it wasn't possible. I

18 had to go to the office of the chef de cabinet of President Milosevic and

19 I talked to him.

20 Q. Very well. As between the minister and the president, did you see

21 anything approaching an equality of status in the time you saw them

22 together or was there and inequality and a manifest inequality of status?

23 A. Well, the president was the president, and General Simovic always

24 said that he had to respect his president. General Simovic stood at

25 attention in his general's uniform while the president was sitting down.

Page 27836

1 Q. Very well. Very well. Let's move on. Did you become aware of

2 things that you thought were outside the general's jurisdiction, and one

3 of them to do with the retirement of generals?

4 A. General Simovic, in fact, had no powers at all. I used to say he

5 didn't even have the powers of an accountant. The Minister of Defence was

6 a minister without an army, a minister with no authority. He had two

7 assistants who were appointed by the government and who had areas they

8 were in charge of. Minister Simovic contacted mostly the Serbian Assembly

9 after receiving approving from President Milosevic and after going to see

10 President Milosevic. Simply Minister Simovic could do absolutely nothing

11 on his own initiative, nor could he make any decision. I didn't

12 understand this. I had far greater powers as the chief of the observation

13 and information service than the minister did in the Serbian cabinet.

14 Q. Then let's just go back, end of paragraph 13, to this business of

15 the retirement of generals on grounds, I think, of incompetence. What

16 passed between the accused and Minister Simovic in relation to this?

17 A. As General Simovic told me, President Milosevic asked

18 General Simovic to make a list of incompetent generals and to prepare

19 lists for their pensioning off. I asked the general how he intended to do

20 that when he had no authority in this respect, and why didn't he tell the

21 president that. And he said, "Well, my president probably knows." And I

22 said, "Why do you say he knows that?" He said, "He's always asking me to

23 pension off incompetent generals and to draw up lists, and I don't know

24 who to apply to or how to do this, nor can I do it."

25 Q. Moving on to another topic, support for volunteers, which is

Page 27837

1 covered in your summary extensively between paragraphs 16 and 25. I want

2 you --

3 JUDGE KWON: Just we go on, I'd like to hear from the witness what

4 exact role she did have as the chef de cabinet, whether she can further

5 elaborate on that.

6 MR. NICE:

7 Q. You've heard His Honour Judge Kwon's question?

8 A. Thank you. My role was to be always at the general's side, to

9 make notes of everything that was happening, to draw up official notes, to

10 report to President Milosevic about the official notes I had drawn up and

11 typed up. I always took them to the door of President Milosevic's

12 cabinet. Then my chief task, as I was also advisor to the Minister of

13 Information, was to have contacts with the media.

14 During the time I was the chef de cabinet, Minister Simovic gave

15 about 200 interviews to the media at home and about 70 interviews to

16 foreign journalists. Some of these interviews I attached to my report,

17 and many of the interviews are still in my keeping. I have not preserved

18 some of them, unfortunately, but I think they can be found.

19 Apart from this, I contacted -- I had contacts concerning the

20 procurement of equipment and materiel for volunteers, and this was perhaps

21 my main task. I also had the obligation which was not part of my job

22 description but had to do with my personal interests. I knew many

23 directors of companies, so I would call them, ask them to provide buses

24 for the volunteers to take them to the battlefield. One of the greatest

25 and most terrible tasks I had was to provide buses so that mothers of

Page 27838

1 imprisoned soldiers who were then imprisoned in barracks and prisons in

2 Croatia, and there were several tens of thousands of them, perhaps more,

3 to provide transport for those mothers to go and see their sons in the

4 prisons in Croatia. These were weeping women who asked to see their

5 children, who would rush into the cabinet offices of Serbia. Their

6 husbands went off as volunteers to fight in the battlefields only to save

7 their children. Unfortunately --

8 JUDGE KWON: Sorry to interrupt you, Ms. Gajic-Glisic, that is

9 more than enough. But do you mean that such procurement of buses or some

10 logistic business was done by the minister himself?

11 THE WITNESS: [Interpretation] No, I did that.

12 JUDGE KWON: As a chef de cabinet?

13 THE WITNESS: [Interpretation] Yes.

14 JUDGE KWON: How many staff did you have at the time?

15 A. You mean how many members of the cabinet? There were three

16 advisors, five typists, two or three technical secretaries.

17 JUDGE KWON: Thank you. Mr. Nice, I took it --

18 MR. NICE:

19 Q. On the 26th --

20 JUDGE ROBINSON: Excuse me, Mr. Nice.

21 Witness, you said that Mr. Simovic did not have much power.

22 Indeed, you said you thought accountants had more power than he had. I'm

23 not sure that accountants will care very much for that allusion, but can

24 you tell me, if he did not have the power, where did the power reside?

25 THE WITNESS: [Interpretation] No. Unfortunately, as a general,

Page 27839

1 his military duty did not allow him to resign. He had to carry out the

2 orders that were issued to him --

3 JUDGE ROBINSON: I didn't say "resign." What I'm asking you is,

4 in light of your comment that he didn't have much power and he was a

5 minister, I'm asking you who had that power? Where did that power reside,

6 not resign.

7 THE WITNESS: [Interpretation] Under our law on national defence,

8 power that had to do with the defence of Serbia, the Territorial Defence

9 and the SUP, was in the hands of President Milosevic, and I quoted this

10 provision of the law in my statement, and I have the law here. It gives

11 all power to the president of the republic.

12 JUDGE ROBINSON: Thank you.

13 MR. NICE: Paragraph 16. On the 26th of September, as you say in

14 your summary, you learnt from a volunteer called Mira that weapons were

15 being transported from Serbia to the conflict zones.

16 I think on the 30th of September, Minister Simovic had a meeting

17 with the accused. Can you help us, please, with what the accused then

18 said in relation to volunteers of the Serbian army. Or volunteers

19 generally, what they should do, what should happen.

20 A. Volunteers were supposed to be the backbone of the future Serbian

21 army. It was to be above political parties, a national army for the

22 defence of Serbian interests. When President Simovic [sic] got back from

23 President Milosevic and he was very angry, he started dictating, and he

24 said that President Milosevic had told me that a volunteer battalion of

25 1.200 volunteers was to be established, that additional volunteers were to

Page 27840

1 be mobilised for the war-affected areas, that means were to be found to

2 assist the volunteers, that a list of generals to be pensioned off was to

3 be drawn up, and I listed some other matters that I noted down. I still

4 have them in my diary, and I think you have them here too.

5 Q. I can help you without breaking the rules of the Court, was

6 anything said about training? Was anything said about elite units?

7 A. Training was already being carried out, and this was before the

8 arrival of General Simovic, and there were centres for the training of

9 volunteers, first in Knin and then in Erdut, and after that, some others

10 were established in other places.

11 Q. Sorry. I'm going to stop you again. In respect of what the

12 accused said to Simovic, was anything said about training by the accused

13 to Simovic? Anything said about elite units but the accused to Simovic?

14 A. General Simovic told me that all these volunteers who were

15 reporting to the notification centres were first to be sent to training

16 centres for their training to be completed and updated. And when they

17 were ready, they were to be sent to centres in Erdut in Knin, and from

18 there they were to be sent on to the units of the Territorial Defence in

19 war-affected areas.

20 Q. Did the accused say anything to Minister Simovic on this occasion

21 about Goran Hadzic?

22 THE ACCUSED: [Interpretation] Mr. May.

23 JUDGE MAY: Just a moment.

24 THE INTERPRETER: Microphone, please.

25 JUDGE MAY: Yes. What is it, Mr. Milosevic?

Page 27841

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

2 THE ACCUSED: [Interpretation] I fail to understand the sense of

3 asking this witness, who herself says was not present at any of these

4 meetings, what I said. How can she testify about this? I don't

5 understand.

6 JUDGE MAY: You know that hearsay is admitted here. You can ask

7 any questions you want in cross-examination about it.

8 Is that a convenient moment?

9 MR. NICE: Certainly.

10 JUDGE MAY: We're going to adjourn now for 20 minutes.

11 Ms. Gajic-Glisic, could you please remember during this

12 adjournment and any others there may be not to speak to anybody about your

13 evidence until it's over, and would you be back, please, in 20 minutes.

14 --- Recess taken at 12.17 p.m.

15 --- On resuming at 12.45 p.m.

16 JUDGE MAY: Yes, Mr. Nice.

17 MR. NICE:

18 Q. Ms. Gajic-Glisic, before the adjournment we were dealing with what

19 Minister Simovic said the accused had told him at that meeting on the 30th

20 of September. There are only perhaps a couple more points I will trouble

21 you with at the moment. Did the accused say anything to Minister Simovic

22 about assistance to Hadzic?

23 A. Yes, that full support should be given to Goran Hadzic, the

24 president of SAO Slavonia, Baranja, and Western Srem.

25 Q. Did he say anything --

Page 27842

1 A. But he should be given full media support, too, and to introduce

2 him to the information media and to give him material assistance and

3 military assistance as well. But as President Milosevic said a moment

4 ago, I really never actually heard that from President Milosevic, I am

5 just telling you what General Simovic told me.

6 Q. Was anything said by the accused following this meeting on the

7 30th of September about the appointment of Radovan Stojicic as commander

8 of the Territorial Defence in Eastern Slavonia, Baranja, and Western Srem?

9 A. Yes, but I also heard a telephone conversation between President

10 Milosevic and General Simovic, and in it they said or, rather, President

11 Milosevic told General Simovic, "Well, once again there's a been a mix-up

12 there in that Western Slavonia. Just imagine had Goran Hadzic appointed

13 that man Radovan Stojicic as president of the Territorial Defence." And

14 General Simovic, on that occasion when he told me that, he said that there

15 was a mix-up and that Goran Hadzic had appointed Stojicic as commander of

16 the Territorial Defence of Slavonia, Baranja, and Western Srem.

17 Q. Before I go on to deal with the rest of your evidence about

18 volunteers, let's go back to something I overlooked. You told us --

19 paragraph 14. You told us a little about Simovic's visits to the Serbian

20 government and how he acted on the accused's orders and so on. Did he

21 tell you anything about who else was present at meetings he had with the

22 accused, Minister Simovic?

23 A. Your question is actually two questions. First, General Simovic

24 very rarely went to meetings of the Serbian government. Usually it was

25 General -- or, rather, he was Colonel at the day, Mladen Kovacevic, who

Page 27843

1 went to Serbian government meetings, or General Branko Kuzmanovic,

2 depending on the different departments and depending on what the

3 government was discussing on its agenda. On several occasions General

4 Simovic attended a government session as well, and I went with him. I sat

5 behind him to take notes, but very rarely.

6 As far as the second part of your question is concerned, General

7 Simovic did go to see President Milosevic for the most part before going

8 to attend Assembly meetings, meetings of the Assembly of Serbia. And he

9 would always say to me that what we had prepared he had to read out at the

10 Assembly and present a report to the Assembly, and that prior to doing so

11 this had to be okayed by President Milosevic.

12 And I remember on one occasion, because of the good relationship

13 and the gentlemanly behaviour of Vojislav Seselj, in my report which

14 General Simovic was supposed to read out to the Assembly I wrote some very

15 nice sentences about Vojislav Seselj, when --

16 Q. Sorry to interrupt you. Can I try to bring you back to the topic.

17 It's my error for putting two questions in one, and I apologise. But at

18 those meetings with the accused to which you have referred, were there

19 other people present from time to time; and if so, who? Other members of

20 government or other ministers?

21 A. General Simovic would tell me that usually at the meetings with

22 President Milosevic it was individuals who would go, or the minister of

23 the interior would go alone, Zoran Sokolovic, or sometimes together,

24 General Jokic, commander of the Territorial Defence, but he would always

25 say that present there was Mr. Radmilo Bogdanovic, he was always there,

Page 27844

1 whom General Simovic called the emminence grise. And during that time he

2 would say nothing, he would give no advice, counselling, instructions or

3 anything of the kind, but he was always present. That's what General

4 Simovic said.

5 Q. I'm now going to move in summary through paragraph 17 to 25.

6 Simovic was asked to buy equipment for volunteers when the national

7 defence fund was empty, and in your summary you explain how you made

8 contacts with financial experts, with Jezdimir Vasiljevic, and other

9 people. As a result of certain meetings, and I want to deal with this in

10 summary, were there arrangements made to purchase all sorts of equipment,

11 binoculars, rifles, freight vehicles, Land Rovers, pistols, things like

12 that? Just yes or no.

13 A. Please, binoculars have nothing to do with your question. No,

14 rather, transmission lines have nothing to do with your question. I never

15 mentioned long distance transmission lines. That is electrical

16 engineering equipment. We didn't work with those. But what we had to do

17 was to procure equipment for the volunteers and we needed -- because the

18 funds for national defence were empty, the coffers were empty. And

19 General Simovic, in coming back once from President Milosevic, said, "How

20 can we ensure additional equipment and resources for the volunteers?" And

21 I said, "General, let's call in the experts from the financial realm."

22 And he said, "Which experts?" And I said, "I know an expert for whom I

23 believe to be a great expert. His name is Ljubivoje Sundic and he was the

24 financial director of the Centrotextil [phoen] company." And he told me

25 to call him, and I did call him, and Ljubivoje said, "But I have to speak

Page 27845

1 to my boss because I'm working in a privately owned firm now." And he

2 came with Jezdimir Vasiljevic --

3 Q. Pause. The detail of this is all in writing and you've

4 acknowledged its accuracy. And if we can move on, was there a meeting

5 between Simovic and the accused about this on the 1st of October of 1991,

6 and if so, what did Simovic tell you was the accused's response to the

7 plans that you were making? Paragraph 18.

8 A. That morning, General Simovic went to inform President Milosevic

9 about all the details from the meeting, the meeting that we held during

10 the night. And he returned from the meeting and said that President

11 Milosevic had said that a new account should be opened for assistance to

12 the volunteers, and then Jezdimir Vasiljevic gave a cheque for dinars, a

13 dinar cheque, which Mladen Kovacevic put on a new account which was opened

14 and which later was used for the procurement from the Crvena Zastava

15 enterprise for equipment and arms for the volunteers.

16 Q. And that cheque was roughly in how much? Can you remember?

17 Paragraph 22, I think.

18 A. I saw the cheque. However, I don't remember the figure on it. It

19 was said to be between 750 and 1 million German marks, the counter value

20 in dinars, in the dinar denomination. That was the figure bandied about

21 but I didn't actually see it.

22 Q. You set out the chronology of these meetings and I just want to

23 ask a couple of details. Paragraph 21. Was there a plan at some stage

24 involving carrying cash across a border in a suitcase?

25 A. Well, I wouldn't -- wouldn't put it that way exactly. There was

Page 27846

1 the need to procure helmets and flak jackets from abroad, bulletproof

2 vests, and for that foreign currency was needed. Now, as there was no

3 money in the accounts and as it was difficult to come by the money, we

4 sought for ways and means of ensuring the foreign currency needed to pay

5 for these goods abroad. Minister Zoran Sokolovic said, as Jezdimir did

6 have the money, that a man from the state security by the name of Savic

7 can take across the border cash in a suitcase which Jezdimir Vasiljevic

8 would use to pay for the bulletproof vests and all the rest of it for

9 equipment, and I underlined the word equipment, for the volunteers.

10 Q. Was the accused made aware of this part of the arrangement or

11 plan? If so, what was his attitude towards it?

12 A. Judging by what was happening in our cabinet, President Milosevic

13 was informed of all the details of what we were doing in the cabinet.

14 And, as far as I know, he didn't prohibit it.

15 Q. So likewise, paragraph 20, when at some stage in the details you

16 set out in your summary it was agreed that Jezdimir Vasiljevic would

17 contact the Israeli State Security Service and if he failed, Dusan

18 Matkovic would take over the negotiations. Was that something -- who was

19 the Minister of Industry, was that something that was known to the

20 accused?

21 A. When Jezdimir Vasiljevic went to Israel with Mrs. Klara Mandic to

22 attend the exhibition which Mrs. Klara Mandic had organised in Israel, it

23 was agreed at government level, at the level of President Milosevic, in

24 fact, although I wasn't present, that Dusan Matkovic should go with them

25 so that should anything happen to Jezdimir, Dusan Matkovic as Minister of

Page 27847

1 Industry could confirm the state of affairs, could confirm the exactness

2 of the fact that we needed assistance from Israel, that that was true.

3 You want more?

4 Q. No, not at the moment. Thank you.

5 And I think following Vasiljevic's - this is paragraph 23 - return

6 further efforts were made to obtain financing for weapons and money came

7 from the Jugoskandik bank; is that right?

8 A. Well, the money for the procurement of weapons from the Crvena

9 Zastava enterprise, that is to say, first and foremost from our own

10 enterprises that engaged in weapons productions, came from different

11 sources. First of all, it came from the National Defence fund, which was

12 intended for that particular purpose. Then we got money from the large

13 enterprises, large companies, and Jezdimir Vasiljevic helped too.

14 Q. Was the accused aware of this? Did he approve of it?

15 A. As far as they told me, he was informed of this and they did not

16 tell me that he did not approve it.

17 Q. And finally, paragraph 25, because the rest -- the detail is

18 covered in the summary. Were you aware of whether Jezdimir Vasiljevic

19 sought to get anything from the accused in return for the assistance he

20 gave?

21 A. Well, the first service for this was he wanted President Milosevic

22 to receive him, and we insisted that President Milosevic should receive

23 Mr. Jezdimir Vasiljevic. However, President Milosevic, they say, "Just

24 us?" "Well who is that man? Who is the man?" Now, whether later on they

25 had a contact of any kind and whether President Milosevic actually did

Page 27848

1 receive Jezdimir Vasiljevic, I can't say because I don't know.

2 And furthermore, Jezdimir Vasiljevic asked that the governor,

3 Atanackovic should put a stop to certain decisions passed by the National

4 Bank of Yugoslavia with respect to his own bank, Jugoskandik, and Jezdimir

5 Vasiljevic also asked that his own television station be opened, and he

6 also had another requirement that the army should help the opening of his

7 television station and I think that he turned up with a lawyer of his. I

8 think later on --

9 Q. [Previous translation continues] ... organisation and training of

10 volunteers comes next, paragraph 26. You set out how there were different

11 types of volunteers and under whose control they were, the Ministry of the

12 Interior, the Serbian Territorial Defence, or the JNA and how there were

13 volunteers of political parties.

14 Arkan's Tigers were under whom, under which body?

15 A. May I put you right on one point? The volunteers weren't under

16 the defence -- Ministry of Defence of Serbia. It was only through the

17 centre for information that we received all information with respect to

18 the volunteers who had signed up at the centres for information which were

19 within the composition of the Ministry of Serbia. So the volunteers were

20 tied to the Territorial Defence first and foremost in places in which they

21 were located. However, according to my information, there were several

22 types of volunteers in fact. We had volunteers which were --

23 Q. [Previous translation continues] ... Arkan's Tigers under which

24 body?

25 A. As to the Ministry of the Interior of Serbia, according to what

Page 27849

1 Mr. Zoran Sokolovic told us, that is to say under the Ministry of the

2 Interior of Serbia. Do you want -- need more?

3 Q. No. Did Sokolovic on any occasion say anything about criminals in

4 Arkan's forces?

5 A. On one occasion he came and said that some criminals had been

6 released from prison and that they had gone to the battlefield at Arkan's,

7 with Arkan. Simovic was astounded and said "Well, who allowed this to

8 happen? How can that happen? Is it possible?" And he just raised his

9 shoulders and said, "Boss."

10 Q. To whom was he referring, in your experience, by reference to

11 "boss"?

12 A. Well, I understood it to mean the president, but I'm not certain

13 today who all the bosses over there were, actually.

14 Q. Now, was there a decree passed with the force of law to set up

15 training centres for volunteers?

16 A. Yes. And that decree having the force of law pertaining to

17 volunteers was passed before Simovic's and my appointment in the Ministry

18 of the Defence. Minister Simovic showed me the decree at the very start

19 of my work in the Defence Ministry, and I saw the decree in your offices,

20 in the OTP, I mean, and I think that the decree had the force of law. I

21 think it did. And I deeply believe that everything that was done with the

22 volunteers and that we did with the volunteers was covered by our laws,

23 and I believed in them --

24 Q. Did the accused --

25 A. -- and --

Page 27850

1 Q. -- have anything to do with establishing this decree, to your

2 knowledge and on the information coming to you?

3 A. I do believe that President Milosevic had to have known about a

4 decree like that.

5 Q. The first training centres, I think you may have said, was under

6 Vasiljkovic and the second under Arkan, and you set out in your summary

7 what happened there. Can we just identify some documents in the same

8 exhibit, 56 --

9 THE REGISTRAR: 567.

10 MR. NICE: 567. Thank you very much. I'm sorry not to have

11 remembered.

12 THE REGISTRAR: 568.

13 MR. NICE: 568. I'm even further sorry.

14 Q. Tab 2. We look at it very briefly, please. This is a document

15 you've reviewed, signed by Vasiljkovic under his name Dragan, which says,

16 we can see it highlighted in English on the screen, in a letter dated the

17 8th of November, 1991, "I have the obligation towards the state security

18 service of the Republic of Serbia, and my activities within the

19 Territorial Defence have to be fully in accordance with the mentioned

20 service."

21 Did that accord with your understanding of Vasiljkovic's

22 performance of his function?

23 A. Minister Sokolovic insisted that Minister Simovic should receive

24 Dragan Vasiljkovic, and he told us that he was their man, and the state

25 security service organised a meeting in the Botic villa with Dragan

Page 27851

1 Vasiljkovic, and we had information according to which he was an associate

2 or employee of the state security service. Later on, according to what

3 you've shown me, and I have a document myself signed by Dragan and which

4 Dragan sent to the minister of defence of Serbia, in which contains this

5 sentence.

6 Q. Tab 3 of 568 is a document you've reviewed which is the minutes of

7 a meeting with Simovic where Dragan is present, and does that include on

8 page 2 of 2 in the English, in the middle of the page, Vasiljkovic's

9 history having been set out, him saying that, "The SDB invited him to our

10 country. He collaborated with Stanisic and Radmilo Bogdanovic. He had an

11 assignment to train volunteers and to work in cooperation with Babic."

12 A. Not Stojkovic, Stanisic.

13 Q. Did information about the training of volunteers of the kind

14 you've set out get passed up the chain of command; and if so, did it reach

15 the accused?

16 A. Information about training quite certainly went up the chain of

17 command, up the hierarchy, and I said that Dragan Vasiljkovic was supposed

18 to train volunteers at the proposal of Zoran Sokolovic and the rest of the

19 ministers, Sainovic and I don't know who else, and there was great

20 pressure being exerted that General Simovic should receive him. We had a

21 meeting and he said that he was working for the state security service and

22 that his assistants were in fact employees of the state security service

23 and that he himself was undertaking the training with them and that he had

24 responsibilities towards the state security service. And in my notebook I

25 have in my own handwriting written down when Dragan Vasiljkovic is talking

Page 27852

1 about the visit to Bor and the visit to Arkan when General Simovic asks

2 him was that in Stanisic's production, and said yes and continued to talk

3 about that.

4 Q. And this sort of information was passed up the management chain,

5 as it were, to the accused?

6 A. Please, this Official Note was compiled by me. I attended the

7 meeting and that Official Note I personally took to the cabinet of

8 President Milosevic, but -- and I continue to claim that I just reached

9 the door to his office.

10 Q. The next paragraphs don't concern the accused but if we can look

11 very briefly at tabs 4 and 5. Is tab 4 a newspaper article you've

12 reviewed which the first couple of lines of which reveal -- I don't have

13 the date of this newspaper article at the moment, unless it's on the

14 index. It's not. We ought to have the date of that. Perhaps you'll find

15 it. But reveal that during only four days between the 25th and 29th of

16 September, 1991, 1.377 volunteers reported to units of the JNA and the

17 Territorial Defence.

18 And then in tab 5 of Exhibit 568, there is, in an article entitled

19 "Red Star," on pages 3 of 7, a reference - and it's about a third of the

20 way down, Your Honours - "Serbia has got a constitutional duty to protect

21 the interests of Serbs out of administrative borders of the existing

22 republic. It is performing this duty of its by engaging its military

23 potentials, by deploying manpower in JNA units and by mobilisation of its

24 composition within the JNA." Does that accord with what indeed you

25 experienced?

Page 27853

1 A. Those texts relate to the end of September, more exactly, and the

2 beginning of October. That means the period of time before the

3 international community recognised the republics as independent states.

4 Therefore, in my opinion, that was in conformity with our constitution and

5 our laws at that time.

6 Now, as far as the number is concerned, 1.377 volunteers who

7 signed up in the first three days via the notification centre, this is a

8 piece of information collected by the notification centres, information

9 centres with which I contacted, so I also have this information jotted

10 down in my notebook now, and following approval by the minister, I further

11 passed it on to the information media.

12 Now, the other text that you mentioned as being a five-pointed

13 star, is the interview given by Serin Simic [phoen] to Zoran Bogavac,

14 which was never actually published.

15 Q. We move on to the next topic, the relationship between the

16 Ministry of Defence and Arkan. You set out a lot of it in detail in your

17 summary but on the 3rd of October, did Arkan find himself surrounded in

18 Vukovar, were steps taken to free him; and if so, what if any part did the

19 accused play in that? But briefly.

20 A. We received information from Dusan Stupar, the Kum, and other

21 people who were -- maintained contact with us that Arkan had remained

22 within the encirclement in Vukovar, and I am sure that President Milosevic

23 was informed about all the events. As far as General Simovic told me,

24 President Milosevic had asked him to ask the air force to fly over Vukovar

25 so that the volunteers who had stayed in the encirclement around Vukovar

Page 27854

1 would be able to pull out. And we spent 48 hours in the office at the

2 time. General Simovic really did entreat the air force to fly over

3 Vukovar, to have flights over Vukovar, to allow the volunteers who were in

4 the encirclement together with Arkan to pull out and return alive.

5 Q. The following day, did Arkan appear at the government building?

6 A. Oh, yes, he did. Arkan appeared in the government building with

7 Kum and on his shoulders he had a sniper rifle and an Ustasha cap on it,

8 all covered in blood. I think they went to see General Milisav Djordjevic

9 in working groups, and I asked them to go into General Simovic's office

10 and to come in to see us, because we still hadn't left the ministry. We

11 were still there waiting to see what would happened to them, and they

12 didn't even inform us that they managed to free themselves and that they

13 were actually arriving in the ministry building. And at the time, a brief

14 meeting was held with them. That was the only meeting in actual fact --

15 Q. Was something said about the taking of prisoners by Arkan when he

16 escaped from Vukovar?

17 A. You interrupted me just when I was about to say that this was the

18 only meeting between Simovic and Arkan, and yes, General Simovic did ask

19 him, among other things, "What do you do with prisoners?" And he said,

20 "General, we have taken prisoner only two hens. As for the others ..."

21 practically he said there were no prisoners. The general said, "How is it

22 possible that there are no prisoners in war?" And he said, "General, we

23 have no prisoners." Then he said that in the encirclement he had killed

24 24 Ustasha, that he had liquidated them. I was horrified, and he said,

25 "Madam, leave the room if you can't bear to listen to this." And the

Page 27855

1 General said, "She's more -- there's more of a man in her than you think."

2 Q. And the witness, as the Court will recall, but for the sake of the

3 record, gave the gesture of the hand across the throat attributing to that

4 to Arkan.

5 Now, this account that was given and horrified, was that reported

6 to the accused?

7 A. Yes. And General Simovic then swore that he would never again

8 receive Arkan or have any further conversation with him, because he, as a

9 general, could not talk to someone who was waging war without taking

10 prisoners, that it was not possible to be on the battlefield without --

11 without having prisoners.

12 MR. NICE: If we can look at a very short clip, which is tab 6 of

13 568.

14 [Videotape played]

15 MR. NICE: Thank you.

16 Q. That observation by Arkan, does that match what he said in this

17 meeting with Minister Simovic?

18 A. First I want to say that I have nothing to do with this videotape.

19 I have never seen it before. And simply, Arkan said that there were no

20 prisoners.

21 Q. Paragraph 35. On the 5th of October, did Dusanka Vorkapic from

22 Sid and a local Serb Territorial Defence from Vukovar come to your

23 ministry saying that the sewer system was being used by Croat forces as a

24 shelter from which to attack Serbs; and if so, what did Simovic do about

25 it?

Page 27856

1 A. A lady came to our cabinet dressed all in black who wouldn't

2 introduce herself. When I insisted, she said her name was Dusanka

3 Vorkapic, but she did not want her name to be published, ever. I am

4 stressing this because to this day I don't know whether this is really her

5 name. But she brought with her drawings or, rather, diagrams of the old

6 sewage system which in Vukovar had been turned into shelters used by

7 Ustasha, ZNG members, and all the paramilitaries who were in Vukovar and

8 who always went out behind the volunteers and the army and liquidated

9 large numbers of Serb soldiers and volunteers.

10 We were always very surprised, because --

11 Q. Can I --

12 A. -- we hadn't known about these old sewage canals.

13 Q. You realise a lot of this is in the summary and we take it briefly

14 in order to save time.

15 I want you to move on from the account that Dusanka Vorkapic, if

16 that was her name, gave to the resolution of the problem by Simovic. Did

17 he ask the accused about this? Was a plan made?

18 A. General Simovic took these diagrams, and as he told me, he went to

19 see President Slobodan Milosevic with them. When he got back from there,

20 he said, "Dobrila, the president said that Arkan's volunteers were to be

21 given the task of mining and stopping up these corridors with concrete,

22 and that Badza should assist them with his units."

23 I worked on this. I established contact with Arkan and Badza, and

24 several years later, when I asked for protection for my life and the life

25 of my family from President Milosevic, I wrote him an open letter which

Page 27857

1 was published in Nin, and this was very hard for me.

2 Q. Thank you. Party armies you deal with in paragraphs 36, -7, and

3 -8 of your summary. I need only trouble you with one passage.

4 You reported -- you prepared a report at one stage about Seselj's

5 volunteers' courageous fighting, and did the accused give some

6 instructions to Simovic about whether this should be presented to

7 parliament or not?

8 A. I prepared a document for the Assembly in which I extolled Seselj

9 and his fighters. I asked General Simovic to present this to the Assembly

10 as a positive example. When I saw the report that General Simovic

11 submitted to the Assembly, that part was missing. When General Simovic

12 came back from the Assembly, I said to him, "Why didn't you put this

13 forward? This is true. Every day we get reports from Mr. Seselj. Why

14 didn't you say this? Why didn't you let everyone know about it?" And he

15 said, "The president's orders. He said, Why should we extol him and

16 praise him?"

17 Q. But I think on another occasion was help provided to Seselj when

18 they were on the front line, and did the accused have any part in that?

19 A. Oh, that was before that. That was when Mr. Seselj asked for a

20 helicopter to visit the fighters on the front lines. He asked for a

21 helicopter from the Ministry of Defence. He wanted to fly to the front.

22 I said we didn't have a helicopter and we couldn't give him one. And

23 General Simovic said that I should give him Brovet's telephone number, and

24 he said, "Brovet is not a Serb. He is a Serb traitor." I said,

25 "Kadijevic." And he said, "No, Kadijevic is a Croatian cart-wright, I

Page 27858

1 don't want to talk to him." I said, "General Adzic?" And he said, "Very

2 well. General Adzic is okay." After that, we followed Seselj's reports

3 from the front line.

4 Q. Thank you. You deal with information about crimes in paragraphs

5 39 and 40. I needn't trouble you about that.

6 Paragraph 41. Did a UN representative or functionary called Marek

7 Goulding come to Belgrade on the 18th of November of 1991?

8 A. Yes. He was a high under-secretary of the UN and the commander of

9 UN forces at the time of the war and a big friend of General Slavko Jovic.

10 He came to Belgrade, as we were told, in secret and had a meeting in a

11 cafe with General Jovic one evening.

12 In the morning, we received intelligence information that General

13 Jovic had talked to a very interesting man, but the security service was

14 unable to record their entire conversation. They asked General Simovic to

15 call General Jovic and ask him what this was all about.

16 General Jovic, on receiving the invitation, came to our cabinet.

17 In the meantime, General Simovic informed President Milosevic of the

18 arrival of General Jovic to our cabinet, and as soon as General Jovic had

19 arrived and President Hadzic was also there and several other people,

20 President Milosevic was called by a special line from the cabinet, and

21 General Slavko Jovic told President Milosevic about the details of their

22 conversation of the previous night.

23 I was given the task of taking notes of this conversation or,

24 rather, of what Slavko Jovic was saying.

25 Q. You made some notes. You were only hearing one part of the -- one

Page 27859

1 side of the conversation, but constructing it from what you could hear,

2 what did the accused say to Jovic about the number of volunteers on the

3 front lines?

4 A. Please, you misunderstood me. I heard both sides, because the

5 speaker phone was on. But I was not authorised to write down what the

6 president was saying or asking, but he kept silent for the most part. He

7 just put a few questions and said a few sentences. I wrote down only what

8 General Jovic was saying.

9 Q. What do you recall about what the accused told Jovic about the

10 number of volunteers on the front lines and how they should be referred

11 to?

12 A. General Jovic, who had been retired for a few years, I think, told

13 President Milosevic that he had told Merak Goulding that there were about

14 a thousand volunteers at the front line. To this President Milosevic

15 replied, "There are about 500 paramilitaries." I think he used the words

16 "paramilitary soldiers."

17 Q. And to that Jovic replied what?

18 A. "Oh, comrade president, I didn't know there were 500. I told him

19 there were not more than a thousand."

20 Q. This can be found in tab 7 of 568, the minutes that you prepared

21 of that meeting but only being authorised to write down, as it were, your

22 side, and on page 3 of 9, a few lines up from the bottom we see this

23 reply: "That I did not know. I did not know there were 500. I told him

24 the number does not go over 1.000. We did not finish the conversation."

25 To your knowledge, how many volunteers were there?

Page 27860

1 A. When they were asking for equipment and when they were asking for

2 assistance, they always mentioned 6.000, 8.000. They asked for 8.000

3 helmets, 8.000 long-barrels, 2.000 -- it was always in thousands. And I'm

4 saying this on the basis of what they were asking for by way of

5 assistance.

6 As to how many of them there actually were, this is information

7 that can be found in the notification centres, because the volunteers who

8 went with the front line legally and who wanted to defend the imperilled

9 Serbs in Croatia, they were registered in the centres for notification

10 throughout Serbia.

11 Q. Paragraph 42 --

12 JUDGE KWON: Mr. Nice, I note paragraph 40 also deals with some

13 conduct of the accused receiving information from Mr. Simovic.

14 MR. NICE: Thank you very much, and I apologise for having missed

15 that out. Yes.

16 Q. On information about war -- about crimes committed in war, did you

17 have information coming about the Dusan Silni unit of Mirko Jovic and some

18 other independent Chetnik groups?

19 A. We received from those who were returning from the front line and

20 demonstrating in front of the government building, we received information

21 from a large number of invalids who were sitting in front of the

22 government building asking to be received, from mothers protesting because

23 their sons were imprisoned in Croatian barracks. We received information

24 that certain groups of volunteers were committing various crimes, and they

25 were afraid that the Croats and the Ustasha would take revenge against

Page 27861

1 their imprisoned sons for what these volunteer units were doing in the

2 battlefield.

3 I must --

4 Q. Very well. Finish what you must say.

5 A. Thank you. Thank you. Thank you very much for allowing me to

6 finish. I only want to say that these units, Dusan Silni, the Paroski

7 units, the units of a certain Mauzer who was said to be from the

8 Democratic Party, that we had no connection with them. No one had any

9 information as to how many of them there were, when they were going to the

10 front, who was taking them there and how. And we in the ministry didn't

11 have any information about them.

12 I want to say this, that there were also those on the battlefield

13 who were not part of the system.

14 Q. Was this information about crimes committed by identified units

15 passed to the accused?

16 A. General Simovic went to see President Milosevic regularly, and I

17 trust that he transmitted all this to him.

18 Q. Paragraph 42. Was there an occasion when Simovic was supposed to

19 appear on television with Arkan and his volunteers, but in the event

20 somebody else appeared. If so, can you explain how -- how that happened?

21 A. I had agreed with Mr. Alimpijevic from Studio B to call

22 representatives of the volunteers and of the government and invite them to

23 speak about their participation in the legal systems and to put the

24 volunteers on an equal footing with regular reservists and conscripts. It

25 was agreed that General Simovic should make a TV appearance with groups of

Page 27862

1 volunteers -- with a group of volunteers, rather, and their

2 representatives.

3 Just before he was to set out to attend this meeting,

4 Colonel Mladen Kovacevic entered the cabinet and said, "General, I'm going

5 to the television station now. I received a call from President

6 Milosevic, and he told me that I was to appear on television with the

7 volunteers."

8 We kept silent. We just looked at him. He went off to the

9 television, and we just sat down in front of the TV set and watched the

10 broadcast. We were surprised, because Colonel Mladen Kovacevic with his

11 strict military demeanour was saying that he had nothing to do with the

12 volunteers, that they were paramilitaries, that we knew nothing about

13 them, that we didn't know how many of them there were, and I will never

14 forget General Fadjovic's [as interpreted] expression. "What's this?"

15 Q. You deal in your summary with coordination groups in the Ministry

16 of Defence. You don't, I think, touch the accused particularly in that

17 but just to give some context, as paragraph 45 reveals, the main task of

18 coordination groups was to coordinate activities amongst the government of

19 Serbia, the Territorial Defence, and the police forces of the autonomous

20 regions and the army; is that correct? Just yes or no.

21 A. Yes. Yes.

22 Q. And indeed, those regions in Croatia receiving legal, logistical,

23 military, and financial support from the government of Serbia did so

24 through all ministries of the government as your summary reveals; correct?

25 A. Yes, yes.

Page 27863

1 Q. Let's move briefly to Goran Hadzic. On the 29th of September of

2 1991, did your minister speak with the accused on the telephone, and

3 following that, did you have to go to the prime minister's cabinet, Prime

4 Minister Zelenovic, for a purpose connected with Hadzic?

5 A. This telephone conversation, no, I didn't hear it, but Minister

6 Simovic told me that President Milosevic had said that I was to go to see

7 President Zelenovic. Minister Zoran Sokolovic was there, and Goran

8 Hadzic, Arkan, and Kum were with him. They told me that I was to

9 introduce Goran Hadzic to the Serbian public, that we were to give him

10 publicity, because he was the president and he was to represent the Serbs

11 in The Hague.

12 I asked Goran Hadzic what he was president of, and he was unable

13 to say anything. I didn't know how I was to introduce him to the media

14 and what I was to say.

15 I called Zoran Bugavac, a journalist, and told him he was to

16 teach. Goran Hadzic was the president of something and that he was to

17 tell him what he was president of and what he was to talk about on the

18 media and on radio. I called my former editor Momir Brkic and asked him

19 to receive the representatives of the volunteer units and the

20 representatives from the war-affected areas and that he was to introduce

21 them to the public at the 3.00 broadcast which was a pre-time broadcast in

22 Belgrade. And then he called me back and said to me, "Dobrila, ask the

23 minister why he sent these criminals to my station. They have come in in

24 full combat gear and scared everyone to death. What sort of criminals are

25 they? Next time tell me who you're sending."

Page 27864

1 After that, they didn't say any -- they didn't ever say again that

2 Goran Hadzic and Arkan were criminals.

3 Q. Did you explain to your contact, Momir Brkic, who had instructed

4 that this man should be promoted over the television?

5 A. Of course, because how could I promote him without explaining it

6 to him? But then he kept quiet and he went on working.

7 Q. Paragraph 49, dealing with the Krajina. Did Babic come to the MOD

8 seeking assistance on a regular basis? Just yes or no to that.

9 A. Can you allow me to go back to the previous question for just a

10 little bit?

11 Q. Yes, go on.

12 A. President Milosevic, in a telephone conversation, asked who this

13 Goran Hadzic was, and General Simovic called General Nenezic to explain

14 who Goran Hadzic was. But then they concluded that Goran Hadzic had

15 already reached The Hague and that there was no way back.

16 What I'm trying to say is that General Nenezic fobbed Goran Hadzic

17 onto President Milosevic and that the president didn't know who Goran

18 Hadzic was. And when he had contacts with him, I apologised to the

19 president for saying this, but this was what I knew, and I was always

20 upset that this was the way things were done.

21 And to answer your question, we did have contacts with Milan

22 Babic. I can hear your question now.

23 Q. Very well. Did the accused make an observation to Simovic about

24 Babic's appointing personnel in the Krajina on his own?

25 A. Yes. President Milosevic complained to General Simovic about

Page 27865

1 Milan Babic's behaviour. His secretary Mira and I would often spend hours

2 looking for Milan Babic all over Belgrade. He never arrived on time for

3 meetings with President Milosevic.

4 Q. I'm running short of time, looking at the clock. I just want to

5 know what did the accused say, if anything, about Babic appointing

6 personnel in the Krajina on his own. What did he say about that?

7 A. He said, "He doesn't ask anyone, either Kadijevic or you or me.

8 He appointed Djujic, he appointed Lieutenant Colonel Mladic, who had a

9 member of his family killed and who is going to take revenge. What's he

10 doing there? That Milan Babic, I don't know --"

11 Q. Next question. Were you present at a meeting with General

12 Djujic at --

13 A. Yes.

14 Q. -- office when he wanted some money? If so, how was the request

15 resolved, what part did the accused play? But very briefly because we are

16 running out of time.

17 A. Yes. I was in the cabinet when General Djujic burst in with his

18 escort, several of them who remained outside our door, and no one could

19 come in any more. General Djujic said, "Money, Tomo; money, Tomo; money,

20 Tomo." The general called Zebic, he called President Milosevic, and then

21 he went off to see, as he said, President Milosevic. I couldn't leave the

22 cabinet nor could I answer the phone.

23 General Djujic waited in the cabinet for the money to be brought.

24 When General Simovic came back, he asked, "What happened? What happened?

25 What happened?" The general kept quiet.

Page 27866

1 After a certain time, Zebic arrived, brought a suitcase a little

2 larger than a briefcase and put it on the desk in front of General Djujic.

3 General Djujic just opened the lid, closed it again, lifted the suitcase

4 up like this, got up and walked out of the door.

5 General Simovic and Zebic just shrugged their shoulders and made a

6 gesture spreading out their arms, and General Zebic went to the door and

7 General Simovic didn't say anything further.

8 Q. Your summary deals with the influence of the Socialist Party of

9 Serbia and with propaganda. As to propaganda, when Radovan Karadzic was

10 promoted by Jevrem Damjanovic, editor-in-chief of Ilustrovana Politika and

11 Ekspres, on whose instruction was that?

12 A. The question is posed erroneously. I wrote an article which I

13 sent to my editor-in-chief of Ilustrovana Politika, and his name was

14 Jevrem Damjanovic. I apologise for having to say this to you, but this is

15 how it was, in fact. In the article, I dealt with a topic of Zoran

16 Raskovic and many others involved, and my editor Damjanovic told me,

17 "Dobrila, nobody must publish this article." And I said, "Why? Because

18 of Radovan Karadzic?" And he -- I said, "Why?" "Because President

19 Milosevic had ordered the promotion of Radovan Karadzic in the sense of

20 being a Serb leader. And I have been put in the post of the

21 editor-in-chief of Ekspres Politika to carry out that assignment, so don't

22 lose your head because of your silliness."

23 Begging your pardon for my correction of your question.

24 Q. No, I'm grateful. You've been asked to listen to and have

25 listened to an intercept. It can be found in its transcript form at tab 8

Page 27867

1 of Exhibit 568. I have no intention of playing it, but you will recall

2 the intercept, which you can see as to its content. Just have a quick

3 look at this. The question simply is this: What voices did you recognise

4 on that tape of an intercept? Just tell us. We're not going to ask you

5 any more than that.

6 A. I listened to the conversation twice and was very surprised. The

7 voices are similar to my voice, and then to General Simovic's voice and

8 Radovan Karadzic's voice. However, with all due respect to this Tribunal

9 and you yourself, I must state that I do not remember this conversation

10 and that I never anywhere made a note of it.

11 Q. We've heard about the book, which may or may not be dealt with by

12 others asking you questions. Can you go now, please, to tab 10 of Exhibit

13 568, which is a letter.

14 JUDGE MAY: Yes, time. So -- intercept for identification, of

15 course, only.

16 MR. NICE: Yes, of course. Your Honour, I've only got a couple

17 more questions to raise.

18 Q. We see at tab 10 a letter that you've reviewed. The signature at

19 the end of it, which the Chamber can see on the fifth or sixth sheet in,

20 is whose signature over "Tomislav Simovic"?

21 A. That is the letter -- or, rather, that letter was sent by General

22 Simovic to the new Minister, Marko Negovanovic, and the president of the

23 republic, Slobodan Milosevic, to protect me, and he wrote the letter

24 personally himself. And in your documents you have the entire letter

25 written out in his own hand, and you also have his signature at the end of

Page 27868

1 that letter.

2 Q. The passage that I'd like the Chamber to view and review is on

3 page 1, highlighted reads: "Only because, with my authorisation, she kept

4 record of the Ministry of Defence's works and events - interlocutors - and

5 compiled them into a diary, the parts of which have been published in Nin.

6 I personally gave my authorisation for the important parts. As for the

7 less important parts, I believed she wrote it down correctly and later on

8 I had the possibility to make sure it was correct, when I read the

9 feuilleton in Nin."

10 That concludes the exhibits. Two questions -- and I have two more

11 questions today or tomorrow morning, as Your Honour pleases.

12 JUDGE MAY: I think there is another case coming in, so we better

13 make it tomorrow morning.

14 MR. NICE: Your Honour, as to witnesses, the witness on Thursday

15 is a witness who must, if possible, start on Thursday. I don't know how

16 long this witness will take. We do have the potential to take another

17 witness after her. I am -- I must simply ask that the accused and amici

18 are in a position to deal with the witness on Thursday, on Thursday come

19 what may if the Chamber allows him to start then.

20 JUDGE MAY: Which is the witness on Thursday?

21 MR. NICE: 36, C-036. He's still protected at the moment.

22 JUDGE KWON: 62.

23 MR. NICE: I beg your pardon, 62.

24 JUDGE MAY: C-062.

25 MR. NICE: 62. So whatever happens else, we will start him on

Page 27869

1 Thursday, if we may.

2 JUDGE MAY: Very well. We will adjourn. Nine o'clock, please,

3 tomorrow morning.

4 --- Whereupon the hearing adjourned at 1.53 p.m.,

5 to be reconvened on Wednesday, the 22nd day of

6 October, 2003, at 9.00 a.m.

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