Tribunal Criminal Tribunal for the Former Yugoslavia

Page 16039

 1                           Tuesday, 17 January 2012

 2                           [Open session]

 3                           [The accused entered court]

 4                           --- Upon commencing at 2.25 p.m.

 5             JUDGE ORIE:  Good afternoon to everyone.

 6             Madam Registrar, would you please call the case.

 7             THE REGISTRAR:  Good afternoon, Your Honours.  This is case

 8     IT-03-69-T, the Prosecutor versus Jovica Stanisic and Franko Simatovic.

 9             JUDGE ORIE:  Thank you, Madam Registrar.

10             First of all, my apologies, not on behalf of the Chamber but on

11     my own behalf, for the late start.  I apparently had not properly

12     assessed the time I needed for other things I was busy with.  Apologies

13     for that.

14             Preliminaries, I've got one, but I was informed that both the

15     Prosecution and the Simatovic Defence had a matter to be raised.

16             Mr. Groome -- Ms. Marcus.

17             MS. MARCUS:  Good afternoon, Your Honour.  We have two brief

18     submissions I'd like to make in private session with your leave.

19             JUDGE ORIE:  We move into private session.

20                           [Private session]

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 16040











11 Pages 16040-16051 redacted. Private session.
















Page 16052

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18                           [Open session]

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

20             JUDGE ORIE:  Thank you, Madam Registrar.

21                           [The witness entered court]

22             JUDGE ORIE:  Good afternoon, Mr. Dimitrijevic.  Can you hear me

23     in a language you understand?

24             THE WITNESS: [Interpretation] Yes.

25             JUDGE ORIE:  Before you give evidence, the Rules require that you


Page 16053

 1     make a solemn declaration, of which the text is now handed out to you.

 2     May I invite you to make that solemn declaration.

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

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

 5                           WITNESS:  JOVAN DIMITRIJEVIC

 6                           [Witness answered through interpreter]

 7             JUDGE ORIE:  Thank you.  Please be seated.

 8             THE WITNESS: [Interpretation] Thank you.

 9             JUDGE ORIE:  Mr. Dimitrijevic, first of all, our apologies that

10     you had to wait for a while.  We had to deal with a few other urgent

11     matters.  You'll now be examined by Mr. Bakrac.  Mr. Bakrac is counsel

12     for Mr. Simatovic.

13             Please proceed.

14             MR. BAKRAC: [Interpretation] Thank you, Your Honour.

15                           Examination by Mr. Bakrac:

16        Q.   [Interpretation] Good day, Mr. Dimitrijevic.  Would you be so

17     kind as to tell me your full name.

18        A.   My name is Jovan Dimitrijevic.

19        Q.   When and where were you born?

20        A.   On the 20th of January --

21             THE INTERPRETER:  The interpreter did not hear the year.  Could

22     the witness please repeat the year.

23             MR. BAKRAC: [Interpretation]

24        Q.   What are you by profession, Mr. Dimitrijevic?

25        A.   I graduated in economy.

Page 16054

 1             JUDGE ORIE:  Yes, Mr. Dimitrijevic, the interpreters could not

 2     hear the -- your year of birth.  Could you please repeat it.

 3             THE WITNESS: [Interpretation] 1957.

 4             MR. BAKRAC: [Interpretation]

 5        Q.   Mr. Dimitrijevic, you said that you graduated in economy.  After

 6     you completed your studies in economy, did you find employment?  And

 7     when, if that was the case?

 8        A.   I found employment in 1980 in a company in Slovenia.  It had a

 9     branch in Belgrade.  The name of the company was Krka and it was from

10     Novo Mesto.

11        Q.   Where are you currently employed?

12        A.   I currently work as an official in the Football Association of

13     Serbia, and I have full-time employment there.

14        Q.   Up until when and where did you work in the Krka company, which

15     had its headquarters in Belgrade?

16        A.   I worked there until 1991, until the beginning of 1991.  First of

17     all, initially, I worked in the commercial department; and after three

18     years, I was a representative of the headquarters and -- or I was a

19     deputy director -- or, rather, an acting director and then I became the

20     director of that branch.

21        Q.   Why did you stop working in the Krka company?

22        A.   Given the events in Yugoslavia at the time, there was the

23     beginning of the war and the beginning -- there was the beginning of the

24     war in the territory of the former Yugoslavia, and Slovenia seceded from

25     Yugoslavia; and as a result, I was not only dismissed but everyone else

Page 16055

 1     was affected, everyone else working for that company.

 2        Q.   Did you at some point in time in 1991 report as a volunteer?  And

 3     where and when, if that was the case?

 4        A.   I reported as a volunteer towards the end of November in the

 5     military section of the municipality, which is the Palilula municipality

 6     in Belgrade.  That's my municipality.  But given my years, as I was told,

 7     given my age, they rejected me, because I believe I was 35 years old at

 8     the time.  They told me and in fact they suggested that if I was willing,

 9     I should choose some other unit where they accept volunteers.  And the

10     person in the military section mentioned the Serbian Volunteers Guard as

11     a unit I should attempt to join.

12        Q.   Did you then go to the Serbian Volunteers Guard?  Did you enlist?

13        A.   Yes.  I went to the headquarters of the Serbian Volunteers Guard.

14     The place was well-known in Belgrade, because it was Zeljko Raznatovic,

15     Arkan's home, across from the Red Star stadium, and I'm one of the team's

16     supporters.  Everybody knew about the place.

17        Q.   When did you enlist as a volunteer, and what happened next?

18        A.   I enlisted as a volunteer -- I can't remember the date, but I

19     remember it coincided with the fall of Vukovar.  I went to the

20     headquarters.  That's what the place was called at the time.  A few

21     individuals waited for me there.  I told them why I was there.  It was

22     not really customary for anybody to walk in from the street.  For the

23     first couple of days I stayed there, helping to sort out some military

24     equipment.  It was in a makeshift garage.  We tried to pair shoes and

25     complete uniforms.  That was my first encounter with the volunteers and

Page 16056

 1     that was my first obligation that I had with them.  And after that --

 2        Q.   Excuse me just for a moment.  Let me interrupt you.  You said

 3     that you sorted out some military equipment.  Had you served in the

 4     military?  Could you recognise the military equipment that you were

 5     sorting out?  Can you describe it for us?

 6        A.   When I say "military equipment," I mean uniforms and military

 7     boots, military footwear.  I had served from 1976 to 1978 in Pula.  That

 8     was a city in Croatia.  At that time I served in the JNA.

 9        Q.   When it comes to those uniforms and military footwear, did you

10     recognise them?

11        A.   Yes.

12        Q.   Can you tell us about them.

13        A.   Those were conventional olive-drab uniforms and military boots

14     that I remember from the time when I served in the JNA.

15        Q.   How many days did you spend sorting out the equipment, and what

16     happened next?

17        A.   I did that for a couple of days, maybe three.  And during those

18     two or three days another five or six volunteers arrived.  When that job

19     was completed, we were sent to Erdut.  First we loaded all the equipment

20     into a van.  We ourselves sat in the van and we went to Erdut, to the

21     training centre.  That was the place where we were supposed to go.  Erdut

22     is some 180 kilometres away from Belgrade in the direction northwards,

23     the Danube, i.e., towards Vukovar.  We arrived there and then we were

24     supposed to --

25        Q.   Just a moment, please.  When you arrived from Serbia in the

Page 16057

 1     Slavonia, Baranja, and Western Srem region, where did you cross the

 2     border?

 3        A.   We did it on the so-called Bogojevo bridge.  I didn't know it at

 4     the time.  I learned that only subsequently.  On the Serbian side there

 5     was the police and the military.  The driver was approached by a soldier

 6     and I suppose that the driver told him where we were headed.  We were not

 7     checked at all.  We crossed without any problems.  From the bridge to the

 8     centre of Erdut there is about a kilometre or a kilometre and a half,

 9     which means after having travelled that way we arrived at the

10     destination.

11        Q.   When you arrived at the Erdut camp, can you tell us the name of

12     the camp, i.e. -- or rather, tell us first:  Who was the first you saw

13     there, at the camp in Erdut?

14        A.   When we arrived at the camp, our first task was to unload the

15     van.  Upon our arrival, we changed from our civilian clothes into the

16     uniforms that we ourselves had brought.  And then Zeljko Raznatovic,

17     Arkan, appeared.  He came to greet us.  At first he shook hands with all

18     of us individually, and then he had a chat with every one of us.

19        Q.   Do you remember what you discussed with Zeljko Raznatovic?  What

20     did you talk about?

21        A.   We just introduced ourselves to each other.  I told him who I was

22     and where I was from.  And then he asked me about my professional

23     background.  I told him what I'd done and what my profession was, and

24     then his comment was, "Thank God that after such a long time finally I

25     have somebody literate in our midst."  I don't know how much that meant

Page 16058

 1     to me at the time.  However, as soon as that short conversation was over,

 2     he told me, "You're very welcome, and you will be our clerk."  When he

 3     said "clerk," he used a somewhat derogatory word, denoting somebody who

 4     is an administrative officer.  In the military hierarchy, those who

 5     served in the JNA will know what that word that he used - and that was

 6     the word "cata" - means.  I was not really prepared to do that.  That was

 7     not the reason why I had volunteered.  However, that was what he had in

 8     mind for me, and that's what I ended up doing.

 9        Q.   Mr. Dimitrijevic, let's now talk about the scope of your work.

10     In performing your duties, did you have a superior?  And if that was the

11     case, who was it?

12        A.   No, I didn't have a superior.  I didn't have a supervisor.  The

13     only person I had was the commander, Zeljko Raznatovic, Arkan.  As time

14     went on, our -- he increased my duties, so all of my communication with

15     regard the job was directly with him.

16        Q.   Can you tell us something about your duties.  What were your

17     tasks during that period of time?

18        A.   Upon my arrival, I started recording the names of the volunteers.

19     And those records had not existed up to then.  I maintained the record of

20     the numerical strength, the personal details, and everything that

21     constituted the administration of that unit.  In addition to those

22     administrative tasks that I had at the very beginning, my daily duties

23     were to compose daily orders that would be read out every morning as the

24     flag was raised.  Those daily orders concerned the training centre of

25     Slavonia, Baranja, and Western Srem.  It was known as the

Page 16059

 1     101st Training Centre.

 2             In addition to that, during the course of a day I would have some

 3     other regular duties, inter alia, looking after people who had been

 4     wounded in combat.  When I arrived, there was no combat ongoing, but I

 5     found that a certain number of combatants who had been hospitalised

 6     around Erdut or in rehabilitation centres.  That was a priority, because

 7     communications were hindered.  When their needs were met, I also had to

 8     deal with the logistical issues.  The military needed weapons, food,

 9     equipment, medicines, toiletries, and so on and so forth.

10        Q.   Let's now move on to that part, Mr. Dimitrijevic.  When you

11     arrived at the centre, did you come to learn who the centre belonged to?

12        A.   To be honest, my opinion upon my arrival was completely

13     different; however, with time I realised - or at least that was my

14     impression and it proved to be correct - that we were a very serious

15     organisation that enjoyed the support of all the institutions in the

16     field.  When I say that, I mean the Government of Slavonia, Baranja, and

17     Western Srem region, as well as the military structures, and I mean the

18     JNA.

19             The centre itself was known as the 101st Centre of the

20     Territorial Defence of Slavonia, Baranja, and Western Srem.  It was in

21     Erdut.  It was housed in the barracks of the former recruiting centre of

22     Osijek.  It looked, and it still looks, I suppose, as a military

23     facility, and it had everything that I had remembered from the military

24     that I had served in.  It had barracks, the cafeteria, the

25     training-grounds, football pitches, training areas, and things like that.


Page 16060

 1        Q.   Was training going on in that centre, and who was trained?

 2        A.   The very name of the centre says it all.  It was a training

 3     centre.  Training was going on.  And the subject of the training were all

 4     the volunteers that had enlisted as the Serbian Volunteer Guard's

 5     volunteers.  They arrived from Belgrade, they were brought in the same

 6     way I had been brought, and they also arrived from all over Slavonia.

 7     And they reported at the gate.  They were received by the reception

 8     service that looked after the volunteers.  And then they came to me as

 9     individuals.  They talked to me.  They gave me their name and all the

10     other personal details that were required.

11        Q.   Did the centre have a military post designation when you arrived

12     or sometime later?

13        A.   Yes.  It was designated as a military post.  I can't remember the

14     exact number, but it did bear the military post designation.  That number

15     changed.

16        Q.   Mr. Dimitrijevic, I would like to call up P500 for your benefit.

17     Could you please look at the document and tell me --

18             THE REGISTRAR: [Previous translation continues] ... is a

19     confidential document.

20             MR. BAKRAC: [Interpretation] Your Honour, I apologise.  This is

21     an exhibit under seal, so I would like the Chamber to move into private

22     session, please.

23             JUDGE ORIE:  We move into private session.

24                           [Private session]

25   (redacted)

Page 16061











11 Pages 16061-16063 redacted. Private session.
















Page 16064

 1   (redacted)

 2   (redacted)

 3                           [Open session]

 4             THE REGISTRAR:  We're in open session, Your Honour.

 5             JUDGE ORIE:  Thank you, Madam Registrar.

 6             We take a break.  And we'll resume at 4.00.

 7                           --- Recess taken at 3.29 p.m.

 8                           --- On resuming at 4.07 p.m.

 9             JUDGE ORIE:  Mr. Bakrac, for your information:  On the matter

10     raised by Ms. Marcus in relation to disclosure, the Chamber would like to

11     receive an oral response from you tomorrow morning, first thing in the

12     morning.  As far as the other matter, that is -- is concerned, that is,

13     the disclosure of documents to be used with future witnesses, the Chamber

14     would like to receive your answer orally not later than Thursday morning

15     or, if time allows, later tomorrow, but we're sitting in the morning.

16     That's the -- these are the time-limits.

17             Please proceed.

18             MR. BAKRAC: [Interpretation] Thank you, Your Honour.

19        Q.   Mr. Dimitrijevic, before the break I put a question to you but

20     you didn't have time to answer.  From the time that you arrived in the

21     Serbian volunteer unit and performed the duties you performed, from that

22     time onwards or during that period did you ever receive a uniform from

23     the MUP in Serbia or the security service in Serbia?  Or if you

24     personally did not receive such uniforms, did you hear anything about

25     such uniforms being delivered to the Serbian voluntary guard unit?


Page 16065

 1        A.   No, never.

 2        Q.   Mr. Dimitrijevic, was there a weapons warehouse when you arrived

 3     in the training centre in Erdut?

 4        A.   Yes.

 5        Q.   What sort of weapons were there in that warehouse and what sort

 6     of weapons were issued to members of the Serbian voluntary guard unit?

 7        A.   The warehouse had already been set up when I arrived.  And when I

 8     arrived, it contained automatic rifles, M-70; semi-automatic rifles;

 9     hand-grenades; Zoljas; Osas; and ammunition.

10        Q.   The weapons that you found there -- well, with regard to those

11     weapons, do you know how they were obtained before you arrived there?

12        A.   According to information obtained from members that I met there,

13     I know something about certain cases.  And given the duties that I

14     performed, I also found out some information.  The first weapons were

15     obtained, to a certain extent, from the JNA.  Some of the weapons that

16     the officers had, but not all of them, the Heckler weapons, for example,

17     were treated as war booty.  There was one particular event when there was

18     a dispute with the Croats and some Hecklers were found in a warehouse in

19     Zenga and some of the officers had these weapons on them.  As for the

20     other weapons that I have already mentioned, they were obtained from the

21     JNA.

22        Q.   Were there any situations when in the course of action,

23     operations, or training courses ammunition was used and there was the

24     need for new weapons; and if so, how was the situation dealt with?

25        A.   Yes.  That's quite natural, because it was a training centre.  We

Page 16066

 1     had these areas for physical training.  We also had a shooting range

 2     where the troops were trained and taught how to use those weapons.  So

 3     ammunition was something that was constantly needed in the course of the

 4     training provided.  So sometimes we would also need a certain amount of

 5     rifles to provide for the warehouse.  The volunteers were issued with

 6     rifles, and when the volunteers completed their duties they would return

 7     the rifle to the warehouse.  They would then leave the training centre;

 8     someone else would appear and get a weapon.  But there were defective

 9     weapons as well and some weapons would be lost in operations, so it was

10     necessary for us to remain in constant contact with the JNA, or, rather,

11     with the Territorial Defence, in particular the TO from Western Srijem.

12     We had to remain in constant contact with them in order to provide the

13     warehouse with the relevant supplies.

14        Q.   Can you tell us whom you had contact with in order to obtain

15     supplies for the warehouse, ammunition and weapons for the warehouse?

16        A.   We had contact in particular with the Territorial Defence command

17     in Western Srijem.  We would list our needs and I personally would take

18     that list to Dalj, which is where I would hand over the list of our needs

19     for that day.  And on the following day I was provided with a response in

20     Erdut, but in some cases I directly contacted the army, that is to say

21     the JNA, and requested their assistance if it wasn't possible to obtain

22     assistance in the first place I have mentioned, if it wasn't possible for

23     them to satisfy my needs.

24        Q.   We have also spoken about obtaining uniforms, and now we are

25     speaking about obtaining weapons.  Could you tell us whether you paid for

Page 16067

 1     the uniforms and how, if you did, and I have the same question for the

 2     ammunition that you tried to obtain.

 3        A.   We didn't pay for any of these things.  It wasn't possible for us

 4     to pay to anyone because we were members of the Territorial Defence of

 5     Slavonia and Baranja, and Western Srijem.  So it was also quite logical

 6     for me, too, that I shouldn't have to pay for anything.  This was quite

 7     customary and quite normal for me at the time, and I think that is still

 8     the case today.  Naturally, as far as the army is concerned, since we

 9     were under their command, the Novi Sad Corps was in the field at the time

10     and there were good relationships between our units ...

11        Q.   Could you conclude?  Between your unit ...

12        A.   Between our unit and the leadership of the corps, or, rather, the

13     JNA, because we participated in these operations together.

14        Q.   Mr. Dimitrijevic, you mentioned providing weapons.  A little

15     earlier on we spoke about uniforms.  You said that you would obtain them

16     from Junk, from someone called Kamenac, a private businessman.  Did you

17     pay for those uniforms?

18        A.   No, I didn't.  We received some donations as the

19     Serbian Volunteer Guards unit, and we used these donations to pay for

20     those uniforms or we would find sponsors who would have direct contact

21     with the producers and would deal with those obligations.  So we had

22     absolutely no expenses as far as that is concerned.

23        Q.   Could you tell us who the sponsors who paid for these items were,

24     do you remember?

25        A.   There were a lot of companies who volunteered to be sponsors.

Page 16068

 1     There were private businessmen, individuals who would appear with certain

 2     funds that they would give, in fact, to the Serbian volunteer guards.

 3     There were many private companies, too, that in this way wanted to

 4     demonstrate their patriotism.  They would give these funds to the Serbian

 5     volunteer guards, and there were also some state companies that

 6     participated in the entire process.

 7             I can give you the names of some of them.  The Karic brothers,

 8     whatever their company was called, saxin gegoma [phoen],

 9     Giovani di Stefano.  So these are the individuals that appeared at the

10     time when I was in Erdut for two and a half or three months.  Later there

11     were far more individuals or companies of that kind.

12        Q.   Mr. Dimitrijevic, you started speaking about the terms you were

13     on with the Novi Sad Corps.  At the time that you were in Erdut, at the

14     end of 1991 and 1992, who was the commander of the Novi Sad Corps?

15        A.   General Biocevic.

16             THE INTERPRETER:  If the interpreter heard the name correctly.

17             MR. BAKRAC: [No interpretation]

18             JUDGE ORIE:  Could we verify whether the name was correctly

19     understood by the interpreter.

20             Could you please slowly repeat the name of the commander of the

21     Novi Sad Corps.

22             THE WITNESS: [Interpretation] General Giorcevic.

23             JUDGE ORIE:  Could you perhaps check on the transcript,

24     Mr. Bakrac, that the name appears --

25             MR. BAKRAC: [Interpretation] Yes, Your Honour.  You have noticed

Page 16069

 1     correctly that the first letter in the transcript is G, but it should be

 2     B.  That's how the witness repeated the name.

 3             JUDGE ORIE:  With a B?

 4             MR. BAKRAC:  Yes.

 5             JUDGE ORIE:  Then would it then be B-i-o-r-c-e-v-i-c?  Would that

 6     be the correct spelling?  And I left the diacritics.

 7             MR. BAKRAC: [Interpretation] Yes, Your Honour, you're quite

 8     right.

 9             JUDGE ORIE:  Please proceed.

10             MR. BAKRAC: [Interpretation]

11        Q.   Let's now have a look at a video extract.

12             MR. BAKRAC: [Interpretation] Your Honour, it's 2D980.  40 minutes

13     and 37 seconds up until 41 minutes and 21 seconds is the extract we are

14     interested in.  It doesn't have a translation.  It doesn't have any sound

15     either, Your Honour.  I would just like the witness to have a look at the

16     individuals who appear and at the places that we can see in the

17     video-clip.

18                           [Video-clip played]

19             MR. BAKRAC: [Interpretation]

20        Q.   Mr. Dimitrijevic, tell us, first of all, with regard to this

21     video, did you manage to recognise the place where this event occurred?

22        A.   It's the entrance to the centre, or, rather, this is where the

23     army had its line-up early in the morning.  And this individual who

24     appeared and greeted the troops is General Biorcevic, who would go and

25     visit us at the centre.

Page 16070

 1        Q.   So if I have understood you correctly, this video extract is an

 2     extract of your training centre in Erdut; is that correct?

 3        A.   Yes.

 4        Q.   Did General Biorcevic often go to your centre?

 5        A.   One could say so, and that means three or four times a month

 6     approximately.

 7        Q.   Did Zeljko Raznatovic, Arkan, go to see General Biorcevic; and if

 8     so, where did he go to see him?

 9        A.   Yes, he did go to see him frequently.  And I could also say that

10     I went to see him frequently.  General Biorcevic's command was on a boat

11     on the Danube not far from the centre of Erdut, and I can no longer

12     remember the name of the boat.

13        Q.   When you say that you went and that Zeljko Raznatovic, Arkan,

14     went to see General Biorcevic too, can you say what the purpose of your

15     visit was?

16        A.   I usually went there officially to deal with certain needs that

17     the army would help us with.  They'd provide us with some rifles and

18     ammunition and so on and so forth.  This relates to your previous

19     questions too.  As for Zeljko Raznatovic's visits, I don't know what the

20     purpose was because I wasn't present when he met the general.  Sometimes

21     I attended lunches, but these were unofficial occasions.  The

22     conversation was unofficial at the time.

23        Q.   Did you have any other contact with members of the army, that is

24     to say, of the Novi Sad Corps?

25        A.   Yes, I did.  I could mention two names, the then-Major Jovanovic

Page 16071

 1     and Lieutenant-Colonel or Colonel Enes Taso.  I'm not sure what his rank

 2     was.

 3             MR. BAKRAC: [Interpretation] Could we now see the following

 4     document on the screen, D166.

 5        Q.   And while waiting for the document to appear on the screen,

 6     Mr. Dimitrijevic, tell me, do you know what the relationship was between

 7     the Serbian Volunteer Guards and the JNA in the field when it came to

 8     engaging in combat and so on and so forth?

 9        A.   Well, I think that there wasn't a single operation at the time --

10     well, in fact, while I was in Erdut there wasn't much significant

11     activity; but given what I heard and saw and given the documents that I

12     also consulted subsequently, I would say that all the operations were

13     carried out together with the Yugoslav People's Army, the JNA.  There was

14     the command of the Territorial Defence and of the JNA that acted together

15     with the Serbian Volunteer Guards.

16        Q.   Mr. Dimitrijevic, could you have a look at this certificate.

17     This is a certificate dated the 4th of December, 1991.  At the time were

18     you in Erdut?

19        A.   Yes, I was.

20        Q.   This is a certificate on Markovic Nenad who was seriously

21     wounded.  Do you know him?

22        A.   Yes, I know him.  His nickname was Sitsko.  He lost a leg; it was

23     amputated.  His left leg was amputated.  He was in hospital in Sombor for

24     a long time, and part of my duties consisted of visiting him almost on a

25     daily basis and of trying to provide for his needs.

Page 16072

 1        Q.   Mr. Dimitrijevic, have you already seen this certificate?

 2        A.   I typed it out.  I typed this certificate out.  And this

 3     certificate was typed out to deal with the cost of treating the wounded

 4     soldier.  There were several such certificates.  The procedure was such

 5     that I would type out the certificate, Arkan would sign it, it would then

 6     be registered, and it would then be taken to the corps command for them

 7     to certify.  Having certified such a certificate, once the corps command

 8     had done that, it was possible to regulate all expenses incurred as a

 9     result of the treatment that was required and all expenses incurred for

10     purposes of paying pensions.

11        Q.   I see a signature in the left-hand corner, Mr. Dimitrijevic.  Did

12     you take this to Commander Enes Taso so that he could sign it?

13        A.   Yes, I did.  Enes Taso didn't sign this, though; somebody signed

14     on his behalf.  But I did take it there, and part of my duties consisted

15     of also taking such documents to them to be certified.

16        Q.   On the basis of this certificate we can see that on the

17     7th of August, 1991, Nenad Markovic was transferred to the military

18     hospital in Belgrade, which is where his left lower leg was amputated.

19     Could you tell me why it was taken -- why he was taken to the military

20     hospital?

21             And later you were involved in taking care of wounded soldiers.

22     Where were these wounded soldiers from the Serbian Volunteer Guard taken

23     for treatment?

24        A.   Well, if there were urgent cases in the field and it wasn't

25     possible to transfer a wounded person to that location, then the first

Page 16073

 1     medical clinic would be used.  All those who could be transported to the

 2     military academy would be taken there and they would be treated there.

 3        Q.   Do you know why wounded soldiers from the

 4     Serbian Volunteer Guards were taken to the military medical academy in

 5     Belgrade?

 6        A.   I don't know.  I suppose there was an agreement to that effect at

 7     a higher level.  There was no way for me to know that.

 8             Maybe I can add something to what I've already stated.  All the

 9     fallen soldiers from various front lines were also transported to the

10     military academy, where a post mortem was carried out.  We would then

11     receive their death certificates.  And based on those death certificates,

12     we would then proceed.

13        Q.   Since you were involved in all those administrative tasks, what

14     about the pensionable years spent with the Serbian Volunteer Guards, was

15     that recorded in their military booklets?

16        A.   Yes.  However, certificates had to be issued and those

17     certificates would be taken to the General Staff in Nemanjina Street, and

18     the administrative clerk who was there would stamp the certificates.  And

19     then the individuals in question would take those certificates to the

20     relevant institution, where those years would be recorded as pensionable

21     years.

22        Q.   Let's now look at P1189, Mr. Dimitrijevic.  This is another

23     certificate signed, seemingly, by the centre commander,

24     Mr. Zeljko Raznatovic.  And while we are waiting for the document to

25     appear on the screen, could you please tell us whether the name

Page 16074

 1     Ranko Strbac rings a bell?

 2        A.   No, it does not.

 3        Q.   Please look at the document.

 4        A.   Yes, this is precisely what I was talking about.  This is a

 5     certificate acknowledging that a person was wounded, where the person was

 6     treated, how the person was treated, for how long; and based on all that,

 7     based on the certificate stamped by the JNA, that individual could claim

 8     benefits later on.  Some were not even fit to do that, so I would go

 9     instead of them.  That was also one of my tasks.

10        Q.   When you say that you completed the paperwork for them, what does

11     that mean?  Where would you take this certificate before it was sent to

12     the municipal secretariat for health care and social services?

13        A.   I would take it to the General Staff in Nemanjina Street, the

14     administrative clerk would stamp it, then I would return it to Erdut.

15     And then if the person was from Novi Sad, for example, I would hand it

16     over to him, he would go to Novi Sad, and he would regulate the matters

17     there.  If the person was either from Belgrade or elsewhere in Serbia,

18     they would regulate the matters there.

19        Q.   We don't see the military command stamp.  Do you remember if such

20     a certificate was issued in several copies?

21        A.   Yes.  One of the copies would be kept in the archives of the

22     General Staff, another one in the archives of the

23     Serbian Volunteer Guards, and the individual would receive his own copy.

24        Q.   My question was a bit different.  When you issued a certificate,

25     would you keep a copy with the Serbian Volunteer Guards?

Page 16075

 1        A.   Yes, yes.  One copy would be filed with us, one copy would be

 2     given to the individual, and a third copy would be filed at the

 3     General Staff, for their records.

 4        Q.   Mr. Dimitrijevic, we discussed General Biorcevic's visits to your

 5     camp.  Did Radovic Stojcevic -- Radovan Stojcevic, Badza, arrive in your

 6     camp; and if he did, how often and in what capacity?

 7        A.   Yes, I'm sure he arrived.  I can't tell you how many times, but I

 8     would say that he arrived at least five or six times in a month.  Every

 9     time when he arrived the troops would be lined up, which meant that his

10     visit was important.  His visit was given importance.  At that time

11     Radovan Stojcevic, Badza, was the TO commander of Slavonia, Baranja, and

12     Western Srem, and it was only normal that his visits received such a

13     level of attention.

14        Q.   Do you remember if at any point in time somebody replaced him;

15     and if that was the case, who was it and when was that?

16        A.   In early 1992 Zivorad Trajkovic, whose nickname was

17     Zile Trajkovic, I believe.

18        Q.   Mr. Dimitrijevic, in your oral testimony you spoke about the

19     relationship with the Novi Sad Corps and about your joint combat

20     activities.  Could you please look at a video-clip, 2D976.

21             MR. BAKRAC: [Interpretation] Your Honour, I failed to tender

22     2D980, the previous clip, from 40 minutes, 37 seconds, to 41 seconds --

23     41 minutes, 22 seconds.

24             JUDGE ORIE:  Ms. Marcus.

25             MS. MARCUS:  Your Honour, the video had been provided without any

Page 16076

 1     information about it, but the witness provided a lot of confirming

 2     information, therefore we don't object.

 3             JUDGE ORIE:  Madam Registrar, the number for the previous video

 4     played by Mr. Bakrac would be ...

 5             THE REGISTRAR:  Number for document 2D980 will be D640,

 6     Your Honours.

 7             JUDGE ORIE:  And is admitted into evidence.

 8             Mr. Jordash, I interpreted your silence as having no objections,

 9     and I will continue to do so if you are silent.

10             Then, Mr. Bakrac, the next video.

11             MR. BAKRAC: [Interpretation] Yes, Your Honour, 2D976.1.  We have

12     a transcript, Your Honour.  The transcript has been distributed.  It

13     starts at 17.52.

14                           [Video-clip played]

15             THE INTERPRETER: [Voiceover] "They have laid the mines.  I'm sure

16     that they know where they are.  They don't know that each of our men can

17     clear the minefields.  We want to do that to have everything clear in the

18     morning.  In this attack the troops will participate with two makeshift

19     bridges.  Two makeshifts bridges will be placed there, tanks will pass

20     and proceed, and we have to carry out a blitz attack.  The army promised

21     that they would fire from the tanks on the first houses here.  The army

22     will not enter with the tanks.  The army has nothing to do there.  They

23     are prepared for anti-armoured fight.  It is up to us now to do our job."

24             MR. BAKRAC: [Interpretation]

25        Q.   Mr. Dimitrijevic, we now saw the video-clip.

Page 16077

 1             THE INTERPRETER:  May it be noted that the interpreters were not

 2     given ample time to find the appropriate transcript.

 3             MR. BAKRAC: [Interpretation] Thank you, Your Honour.

 4        Q.   Mr. Dimitrijevic, we saw Zeljko Raznatovic, Arkan, providing

 5     instructions.  Did you recognise the soldiers that were also depicted in

 6     the video-clip?

 7        A.   Yes.  I did recognise some of them.

 8        Q.   Could you please tell us whom you recognised .

 9        A.   Ranko Zivanovic, Holma [phoen], Nebojsa Djordjevic.

10        Q.   Did they have green helmets and who did you receive the helmets

11     from?

12        A.   Yes, they did have green helmets on their heads, and we received

13     them from the JNA.  We also received some dressings, gas masks.  What I'm

14     saying is that we did not receive only ammunition, but, rather, complete

15     sets that included the helmets.

16        Q.   Can we infer from the video-clip that this is one of the

17     operations that you spoke about as those that were carried out in concert

18     with the military?

19        A.   Yes, you can tell that from the clip.  I was never present in any

20     of such situations, but this is how things happened and this is what I

21     subsequently heard from the soldiers when they returned to the centre.

22             MR. BAKRAC: [Interpretation] Your Honour, before I tender

23     [Realtime transcript read in error "turn"] the video-clip into evidence,

24     I would like to say that this is a DVD that we received from DFS-009

25     during the break.  And I believe that the Case Manager provided a copy of

Page 16078

 1     the DVD to the Prosecutor.  I would like to tender the video-clip into

 2     evidence.  If the Prosecutor needs more time to watch the DVD again, I

 3     agree that it should be marked for identification for the time being.

 4             MS. MARCUS:  Your Honour, we did not know the origin until we

 5     were just informed just now.  Indeed, there's a lot of confusion about

 6     the number of videos and the way they were disclosed.  So we're not

 7     prepared to express our position as to right now, so we agree that it

 8     should be MFI'd for the moment.

 9             JUDGE ORIE:  Madam Registrar, the number to be assigned to the

10     video-clip would be ...

11             THE REGISTRAR:  The number to be assigned to video-clip 2D976.1

12     will be D641, Your Honours.

13             JUDGE ORIE:  Did you provide a transcript to the booth before,

14     Mr. Bakrac?

15             MR. BAKRAC: [Interpretation] Yes, Your Honour, I believe that

16     that was done.

17             JUDGE ORIE:  Yes, because the booth says that they need some time

18     before you start playing it to find the relevant transcript.

19             Now, you said you received this video during the break, the last

20     break, is that correctly understood?

21             MR. BAKRAC: [Interpretation] No, Your Honour.  My colleague has

22     provided the booths with several transcripts.  I apologise to the booths.

23     Maybe they're not in the right order.

24             JUDGE ORIE:  My question is about receiving the video, because I

25     think that -- but let me check in the transcript exactly what you said

Page 16079

 1     about that.  "... we received -- " you said:  "Before I turn" - I take it

 2     "tender" - "the video-clip into evidence, I would like to say that this

 3     is a DVD that we received from Witness DFS [sic] during the break."

 4             Is that during the last break?  Or when was that?  Or during the

 5     recess?

 6             MR. BAKRAC: [Interpretation] Your Honour, I meant the winter

 7     recess, not the last break in today's sitting.  I apologise if I was not

 8     clear enough.  When I returned to The Hague I made copies of the DVD and

 9     I provided one to the Prosecution.

10             JUDGE ORIE:  And was there any reason why you didn't disclose to

11     the Prosecution where you got it from?  Because that's what I would have

12     expected you to add as information to the video.

13             MR. BAKRAC: [Interpretation] Your Honour, to be honest, I was

14     busy proofing the witness and I asked my assistant to disclose the DVD to

15     the Prosecutor.  It is my mistake that I didn't check how that was done,

16     whether there was an accompanying letter with the DVD; I apologise.  My

17     colleague just tells me that there was an accompanying letter, but let me

18     be honest and admit that I never checked that because I was busy proofing

19     this witness.

20             JUDGE ORIE:  Ms. Marcus, when did you receive the video?

21             MS. MARCUS:  This morning or yesterday.  This morning or

22     yesterday, Your Honour.

23             JUDGE ORIE:  Mr. Bakrac, if you received the video during the

24     recess and if you provide it then only yesterday or this morning to

25     Ms. Marcus, of course that could have been done last week easily.  I'm

Page 16080

 1     not going to spend a lot of time on it, but I look at the matter also in

 2     relation to the request by the Prosecution --

 3             MR. BAKRAC: [Interpretation] Your Honour, I arrived last week on

 4     Friday or perhaps Thursday.  In any case, towards the end of last week.

 5     And then I asked my assistant to make copies and then the first working

 6     day after the weekend we handed that copy over.  And if I was late again,

 7     I can only apologise for that.

 8             JUDGE ORIE:  Let's proceed.  Unless you would like to make any

 9     further submissions, Ms. Marcus.

10             MS. MARCUS:  Your Honour, just in order to save us all time at a

11     later housekeeping session, with respect to this video, I think the

12     information that would be missing from the line of questioning that was

13     asked is -- because Mr. Bakrac asked quite a leading question about

14     inferences that could be drawn from what we see, and the witness said

15     that he had -- was never present in such situations; therefore, although

16     he identified some of the individuals and he made a comment about what

17     they're wearing, he didn't give any information about the timing of the

18     video.  And because we don't know any origin information about it,

19     it's -- that's the piece of information I would say right now that is

20     still missing.  It's just to give you an opportunity while the witness is

21     here to clarify that.

22             JUDGE ORIE:  Yes, there is some text in Cyrillic on the video,

23     Ms. Marcus, which may give a clue to the timing.  So did --

24             MR. BAKRAC: [Interpretation] Your Honour, I --

25             JUDGE ORIE:  Did I see November?

Page 16081

 1             MR. BAKRAC: [Interpretation] Yes, November 1991.  The script is

 2     Cyrillic and I believe that the Prosecution has done the same thing.  I

 3     don't know why the witness shouldn't be allowed to look at the video-clip

 4     and tell us whether situations like this were talked about, why he

 5     shouldn't be allowed to recognise certain individuals in the video-clip.

 6             JUDGE ORIE:  You misunderstood Ms. Marcus.  I take it that she

 7     didn't say that you're not allowed, but she invited you to seek further

 8     clarification, as the timing is concerned, with the witness, if possible;

 9     and otherwise, to give clues to the Prosecution as to the timing of the

10     video.  Let's proceed.

11             MR. BAKRAC: [Interpretation] Thank you, Your Honour.

12             And now can we look at 2D978 from 32 minutes, 27 seconds, to

13     32 minutes, 45 seconds.

14             JUDGE ORIE: [Previous translation continued] ... I think, as a

15     matter of fact, that I may have forgotten to ask for a number to be

16     assigned to the last video or ...

17             THE REGISTRAR:  The number is assigned D641, Your Honours.

18             JUDGE ORIE:  And that was marked for identification.  Yes, I

19     think I should have -- Ms. Marcus asked for it to be marked for

20     identification and that is what it is now.

21             Please proceed.

22             MR. BAKRAC: [Interpretation] Your Honour, 2D978, it doesn't have

23     any sound.  Could we please have a look at that video-clip.  There is no

24     transcript.  From 32 minutes and 27 seconds up until 32 minutes and

25     45 seconds.  The video-clip is on the same DVD.

Page 16082

 1                           [Video-clip played]

 2             MR. BAKRAC: [Interpretation]

 3        Q.   Mr. Dimitrijevic, do you know what is happening in this clip?

 4     Can you recognise the situation?

 5        A.   I assume that you have the tanks that you can see in the clip in

 6     mind.  This took place around Vukovar.  It concerned the fighting around

 7     Vukovar.  There was a unit from the Serbian Volunteer Guards that

 8     captured four tanks that had been so damaged that they couldn't be used.

 9     They were immobile.  And two tanks were taken from those locations to the

10     centre in Erdut.  After the fall of Vukovar, when I arrived in Erdut, I

11     found two tanks there as part of the weapons listed.  As we had no tank

12     operators, anyone who had been trained to operate tanks, we gave

13     General Biorcevic those two tanks.  I was present there.  And he, in

14     return, gave us a certain quantity of weapons that we needed in the

15     warehouse at the time.

16        Q.   Do you recognise one of those two tanks in this clip?

17        A.   Yes, I do.

18             MR. BAKRAC: [Interpretation] Your Honour, could we mark this

19     document for identification too, please.

20             JUDGE ORIE:  Madam Registrar, the number would be ...

21             THE REGISTRAR:  2D978 will receive number D642, Your Honour.

22             JUDGE ORIE: [Microphone not activated]

23             D642 is marked for identification.

24             MR. BAKRAC: [Interpretation]

25        Q.   Mr. Dimitrijevic, I asked you who went to the centre, and you

Page 16083

 1     answered my question.  Now I would like to ask you whether you remember,

 2     when you were in the centre, whether there were any official visits to

 3     your centre from high UN representatives, from foreign UN

 4     representatives?

 5        A.   Yes.  And that was almost on a daily basis.  There were visits

 6     from the Government of the TO in Baranja and Western Srem and there were

 7     their guests as well that went to have conversations with the government

 8     in Baranja and Eastern Srijem.  The government centre was across the

 9     road.  I don't know what the name was.  So there was just a distance of

10     5 metres between our doors.  And all of the officials who went to visit

11     Western Srijem, Slavonia, and Baranja, and the field, the battle-field,

12     they would be taken by government representatives to visit the centre

13     too.  Among them, there were American congressmen as well, senators.

14             MR. BAKRAC: [Interpretation] Let's now have a look at 2D979.

15     It's another clip from the same DVD.  Item 1.  I do apologise.  Perhaps

16     it was my mistake.  2D979, item 1, from 36 minute 00 up until 37 minutes

17     00.  Could we just wait a minute.  I want to see whether the booths have

18     found the relevant part in the transcript.  Yes.  So with your leave we

19     can have a look at the clip.

20                           [Video-clip played]

21             "Arkan hopes his men will eventually form the nucleus of a

22     Serbian army.  Many ordinary Serbs are angry with the federal army for

23     signing so many cease-fires, when they'd like to see the war carried

24     further forward into Croat territory.  The Serbian opposition has

25     criticised the government for relying too heavily on federal troops, and

Page 16084

 1     not forming its own army.  Arkan's men could one day have a bigger

 2     political role to play.  Linda Duffin, Sky News."

 3             [Indiscernible]

 4             "Glad to meet you.

 5             "Thank you."

 6             MR. BAKRAC: [Interpretation]

 7        Q.   Mr. Dimitrijevic ... Mr. Dimitrijevic, do you remember these

 8     visits in November/December 1991 and in January 1992?

 9        A.   Yes, yes.  In addition to the individuals I have just seen here,

10     there were many others who visited the centre almost on a daily basis.

11             MR. BAKRAC: [Interpretation] Your Honours, could we also mark

12     this video-clip for identification.

13             JUDGE ORIE:  Ms. Marcus.

14             MS. MARCUS:  Your Honour, our only comment is a question to

15     Mr. Bakrac whether he intends to rely on the words of the narrator.

16             JUDGE ORIE:  Yes, that would also be my question.

17             MR. BAKRAC: [Interpretation] No, Your Honour, it's not my

18     intention to rely on that.  It's just that there was that comment.  But

19     to be brief:  No, it is not my intention to rely on what the journalist

20     said.

21             JUDGE ORIE:  I'm just wondering, was the question to the witness

22     about what was seen in the video?  Reference to "these visits," was that

23     a reference to what was seen in the video?  Is that ... because I'm

24     trying to understand.  We have looked at a video with some comment, then

25     the question asked by you is:

Page 16085

 1             "Mr. Dimitrijevic, do you remember these visits ..."

 2             Was that a reference to what we had seen on the video?  Because

 3     we saw a lot of short ...

 4             MR. BAKRAC: [Interpretation] Yes, Your Honour.  We saw three

 5     visits of three high-ranking officials.  I asked the witness whether he

 6     remembered those visits, and the witness said that in addition to those

 7     visits there were many other visits made by high-ranking officials to the

 8     centre at the time that he was there.

 9             JUDGE ORIE:  Yes.  Let's then -- I've no problem with the video,

10     but I want to know exactly what -- what it establishes.

11             Did you recognise in each of the small portions that it was a

12     visit and who visited?

13             THE WITNESS: [Interpretation] Are you putting that question to

14     me?

15             JUDGE ORIE:  Yes.

16             THE WITNESS: [Interpretation] I didn't receive the interpretation

17     of your question.

18             JUDGE ORIE:  Well, looking at the video, did you recognise all

19     these smaller portions as the visits, the type of visits you refer to?

20             THE WITNESS: [Interpretation] Your Honour, I'm not receiving any

21     interpretation.

22             JUDGE ORIE:  Still not.

23             Could Madam Usher -- could we have a -- could we check, first of

24     all that the -- one second, yes, I'm dealing with it.

25             Could we check whether the witness is at the right channel and

Page 16086

 1     could we check whether there's any technical problem.

 2             THE WITNESS: [Interpretation] That's fine.  Now I can hear you.

 3             JUDGE ORIE:  Okay.

 4             Now, what I -- a question was put to you by Mr. Bakrac.  Let me

 5     check.  He asked you:

 6             "... do you remember these visits in November/December 1991 and

 7     January 1992 ..."

 8             Was -- were these visits the ones you saw in the video-clip?

 9             THE WITNESS: [Interpretation] Yes.  But I think I arrived after

10     this visit at the centre.  This video is a video of three individuals

11     visiting the centre.  First there was Owen, Newman, Moody.  I think those

12     were the names.  I think Owen arrived sometime before I arrived at the

13     centre, and these two gentlemen paid a visit once I had already arrived

14     at the centre.

15             JUDGE ORIE:  Yes, so for some of the visits you were present

16     during the visits, whereas for other visits you were not but you just

17     conclude on the basis of what you see on your screen that this must have

18     been similar visits as you had been present at.  Is that correctly

19     understood?

20             THE WITNESS: [Interpretation] Of the three here, yes, I was

21     present for the visit of two of them.  But there were far more officials

22     who visited the place.  This is just -- here we just have a few visitors.

23             JUDGE ORIE:  Yes.

24             Mr. Bakrac, you will understand you had a very simple question:

25     Do you remember these visits?  Although, if you put precise questions to

Page 16087

 1     the witness, he can't remember them because he wasn't there, for some of

 2     them at least.  If something is shown to the witness, you should

 3     carefully establish what is seen and what the witness himself can tell us

 4     about it.  Apparently for one of the visits he remembers that that person

 5     visited the camp.  Could you please be --

 6             MR. BAKRAC: [Interpretation] Yes, Your Honour.  I fully accept

 7     your criticism.  But I'm short of time and I want to get through as much

 8     as possible with this witness.  I apologise if I do make mistakes.

 9        Q.   You mentioned the fact that you weren't present when Cyrus Vance

10     visited but you were present for the other two visits.  With regard to

11     all three visits, were you able to recognise the place of the visit?  Was

12     it -- were these visits, visits to your centre in Erdut?

13        A.   Yes, all these visits were visits to our centre in Erdut.  And

14     these visits took place on a daily basis.

15             JUDGE ORIE:  Yes.

16             Madam Registrar, had we assigned already a number to this

17     video-clip?

18             THE REGISTRAR:  No, Your Honour.  Document 2D979.1 will receive

19     number D643 MFI, Your Honours.

20             JUDGE ORIE:  Yes, it is MFI'd.

21             Please proceed, Mr. Bakrac.

22             MR. BAKRAC: [Interpretation] Thank you, Your Honour.

23        Q.   Sir, Mr. Dimitrijevic, was there a press centre next to your

24     centre?

25        A.   Yes.  But I'd like to provide a somewhat detailed explanation if

Page 16088

 1     possible.  The centre in Erdut is in the actual visit of Erdut next to

 2     the wine-producing shop in Erdut which was very popular before the war.

 3     That wine-producing shop was taken over by the Government of Slavonia,

 4     Baranja, and Western Srem -- well, taken over by them, what I mean, in

 5     fact, was the building was a solid one, it was well-equipped, and they

 6     had the headquarters of the government based in that shop, on those

 7     premises, just across the road from the training centre in Erdut.  And in

 8     front of the building there was another building that was an

 9     international press centre for Slavonia, Baranja, and Western Srem.  And

10     in that press centre that was connected to the Government of Slavonia,

11     Baranja, and Western Srem you could find all accredited journalists who

12     were in the area at the time, and they would go to obtain their

13     accreditation from the government.  So they were directly across the

14     road.  Our centre wasn't walled in, as you could see in the clips.  It

15     had a gate, a guard at the gate, but everything else was quite

16     transparent 24 hours a day.

17        Q.   In addition to these visits that you have spoken about, were

18     there foreign journalists who also entered your centre to report on it?

19        A.   Yes, they had such freedom.  But they had to announce their

20     arrival in advance.  It wasn't possible for anyone to just enter the

21     centre whenever it occurred to them.  Volunteers didn't have the right to

22     issue or to give statements of any kind.  That was part of the discipline

23     imposed on the Serb Volunteer Guards.  Only Zeljko Raznatovic could

24     provide answers to any questions that were put.

25        Q.   We've now spoken about the visits of high-ranking officials.  Did

Page 16089

 1     anyone from the state security department of Serbia go to visit the

 2     training centre, with you being aware of the fact that such an individual

 3     was from that centre?

 4        A.   Not with my knowledge.

 5        Q.   Did you hear from any members of the SDG that they went to visit

 6     the training centre while you were there?

 7        A.   No.

 8        Q.   Do you remember who from the Government or Ministry of Slavonia,

 9     Baranja, and Western Srem went to your centre, and how frequently?

10        A.   Well, as far as the government is concerned, the entire

11     government would visit the centre.  Mrgud Milovanovic, for example,

12     Rade Leskovac, some other individuals whose names I have forgotten, but

13     they came on a regular basis, on a daily basis, on a number of occasions,

14     a number of times, in fact.  And naturally Goran Hadzic as well, that was

15     obvious.  So they would pass through the gate, leave, and this was

16     registered.  But they visited the centre quite regularly, on a daily

17     basis.

18        Q.   Did Goran Hadzic -- or was Goran Hadzic the president of the

19     government at the time?

20        A.   He was the president of the government.

21        Q.   Did he stay in your training centre on occasion?  Would he spend

22     the night there?

23        A.   Yes.  For a period of time his security was also there.  They had

24     some facilities, some premises in the barracks where he would sleep over

25     if he had a lot of duties to perform.  I don't know where he lived, but

Page 16090

 1     he would come and sleep over.  He would eat there.  So he was in the

 2     training centre itself very frequently.

 3        Q.   Mr. Dimitrijevic, before I move on to a different topic, can you

 4     tell me whether you know anything, and if you do what is it, about the

 5     intimate relationships between Zeljko Raznatovic, Arkan, and the federal

 6     security service and Stane Dolanc.

 7        A.   This is part of an urban myth.  An urban myth that could be heard

 8     all over the city of Belgrade.  After an incident that involved Arkan and

 9     some police officers and after -- I'm just speculating, you know.  This

10     is not what I know first hand.  I'm just sharing stories and rumours with

11     you, that he had something to do with the federal SUP of Yugoslavia, of

12     the republic and the state of Yugoslavia, as it was at the time mand that

13     federal SUP was headed by Mr. Stane Dolanc.  But I have nothing to

14     corroborate that.  I didn't hear this from him.  And if this was to be

15     one of your following questions, I still believe that it was just a myth

16     more than anything else.  I don't think that it really did happen.

17        Q.   However, as far as I understood you, that was a rumour that

18     everybody was familiar with in Belgrade?

19        A.   Yes, you're right.  The rumour is still being spread.  The story

20     is still popular among people.

21        Q.   Mr. Dimitrijevic, at one point in time in 1992 you left Erdut and

22     the training centre.  Could you tell us when you left and where you went?

23        A.   I left in late February or early March 1992.  Arkan gave me an

24     order to take over the headquarters of the Serbian Volunteer Guards in

25     Belgrade, in Ljubica Bogdana Street 1.  My job description there did not

Page 16091

 1     differ much from what I did in Erdut.  It was a bit more encompassing.

 2     And the main task that I had was to care for the families of the wounded

 3     and fallen volunteers.  The number two task was to be involved with the

 4     procurement to allow the functioning of the guards.  I was supposed to

 5     obtain materiel that was required.  I was also concerned with the

 6     well-being of Zeljko Raznatovic, Arkan's, family because the headquarters

 7     of the volunteers was in his own family home.  So those were the main

 8     tasks that I was involved with at the headquarters.  And one of those

 9     tasks was also the reception of volunteers.

10        Q.   Mr. Dimitrijevic, I moved on to that part in a bit of a haze, but

11     before that I wanted to ask you something about the period where you were

12     still at the training centre in Erdut.  You said that you were in charge

13     of procuring food.  How did you do that?

14        A.   Given the numerical strength at any one time, we were provided

15     by -- food by the Government of Slavonia, Baranja, and Western Srem.  A

16     while ago you asked me about weapons; the same applied to food.  I would

17     take the list to Dalj, to the government offices there.  They were the

18     ones who provided us with salt, flour, sugar, oil, and such bare

19     necessities.

20        Q.   Let me stop you there.  While you are talking about that I would

21     like to call up document P1187.  This is a document issued in 1992 by the

22     Ministry of Defence of Vukovar.  It says here:

23             "We hereby agree that the expenses of the Territorial Defence

24     centre for the training of volunteers in Erdut will be reimbursed to the

25     socially-owned enterprise Dalj," and this document was signed by

Page 16092

 1     Mile Milanovic.

 2             Was that one of the ways to obtain provisions?  Does this

 3     approval apply to your centre?  Do you know?

 4        A.   Yes.  This was the only way.  There was no other centre.  When

 5     you say the centre in Erdut, that was the 101st Training Centre.

 6     Mile Milanovic, who was also known as Mrgud, was a then-minister in the

 7     government.  He was the one who signed the procurement orders that I

 8     would bring to him, and he was the one in charge of paying the invoices.

 9     He was the one who made it possible for us to get bare necessities, such

10     as oil, flour, sugar, rice.  We also needed toiletries, of course.  We

11     needed meat and other such things.

12             I had a vehicle.  I had a driver as well.  I went on visits to

13     companies in Slavonia and I would present them our needs.  I would travel

14     even further afield in Serbia to places such as Apatin, Odzaci, Sombor,

15     all close to Erdut.  I would also visit companies there and seek

16     assistance with such provisions.  This was all well regulated.  People

17     were benevolent towards our requirements and requests.  We usually sought

18     toiletries which were in short supply due to war.  We never paid for

19     those; however, we reimbursed them by issuing thank-you notes to both

20     individuals and companies that helped us.

21        Q.   Thank you, Mr. Dimitrijevic.  Let's now bring this part to an

22     end, the part which concerns your tour of duty in Erdut.

23             Can you please tell us which vehicles you had in the Erdut centre

24     while you were there.

25        A.   We didn't have a huge fleet of vehicles.  We had two

Page 16093

 1     Pajero jeeps, small jeeps.  We got them from the Vela auto company based

 2     in Belgrade, as a gift, as a donation.  We had two 5- or 6-passenger

 3     vehicles of different makes and different ages.  We had two vans, or

 4     people-movers; one van for the transportation of goods.  That was the one

 5     that I most frequently used.  We had three lorries, two of which we had

 6     obtained from the Army of Yugoslavia.  They were nothing much, but they

 7     were in a workable order.  And we also had a lorry that we had found at

 8     the centre.  We repaired it and made it workable.  In addition to that,

 9     the centre also had all the things that I mentioned.  We also had a car

10     repair shop, a joinery shop, and we had some people who were very handy

11     and did the repairs themselves.

12        Q.   Mr. Dimitrijevic, at the time when you arrived in late November

13     or early December 1991 until the end of February or beginning of March

14     1992, while you were there, do you know what registration plates those

15     vehicles had?  Did they have registration plates at all?

16        A.   Pajeros had Belgrade registration plates because they had arrived

17     from Belgrade.  The others didn't have any registration plates, but they

18     were marked with big stickers on the doors and on the bonnet.  On the

19     doors the sticker depicted a Serb Volunteer Guards coat of arms which was

20     large enough for everybody to see, and on the bonnet the vehicles were

21     marked by a different type of stickers depicting tigers' heads.  This was

22     our moniker; we were known as Tigers.

23        Q.   You mentioned two Pajeros with Belgrade registration plates.

24     Were those civilian registration plates or some other plates?

25        A.   Those were civilian plates.

Page 16094

 1        Q.   The van that you most commonly used, what kind of registration

 2     plates did it have?

 3        A.   Yes, it had registration plates.  This vehicle was registered in

 4     Sombor, which is 35 kilometres away from Erdut.

 5        Q.   And what about the other vehicles which did not have any

 6     registration plates but, rather, just the stickers, did you ever cross

 7     the border to Serbia driving those vehicles?

 8        A.   No.

 9        Q.   How did you move about the area?

10        A.   The stickers that we had on the doors and on the bonnet were

11     enough for the area.  Everybody recognised those vehicles as vehicles

12     belonging to the Serbian volunteers.  Nobody else but us had those

13     labels.  The van with the Sombor plates that I used, and I say that I

14     used it because that was the logistics -- vehicle for logistics, I didn't

15     have those labels, I just had Sombor registration plates.

16        Q.   Mr. Dimitrijevic, did the vehicles in question later on receive

17     any registration plates?  And if they did, what kind of registration

18     plates were those?

19        A.   Yes.  They received registration plates after the Vance Plan was

20     introduced.  When the TO was abolished and when we became the

21     Krajina Police, then we received blue registration plates with the

22     marking M for police, without a five-pointed star that had existed before

23     on our registration plates.  Instead of that, there was a three-coloured

24     flag and a four-digit number.

25        Q.   Were those registration plates of the police of the Republic of

Page 16095

 1     Serbian Krajina or the Republic of Serbia?

 2        A.   The police of the Republic of Serbian Krajina.

 3             MR. BAKRAC: [Interpretation] Your Honour, I have the impression

 4     that you suggested that we should have our next break.

 5             JUDGE ORIE:  Yes.  We are a little bit over the time we usually

 6     have, but I was a bit misled by your phrase "let's now bring this part to

 7     an end."  I thought you would finish that part.  Let's take a break.  And

 8     resume at five minutes to 6.00.

 9                           --- Recess taken at 5.24 p.m.

10                           --- On resuming at 6.01 p.m.

11             MR. JORDASH:  Your Honour.

12             JUDGE ORIE:  Yes, Mr. Jordash.

13             MR. JORDASH:  May I just alert the Court to the fact that

14     Mr. Stanisic had a nose bleed, having taken a pain relief, and may need

15     to leave on a more regular basis for the rest of the afternoon.

16             JUDGE ORIE:  Yes.  I -- as always, the Chamber respects whatever

17     Mr. Stanisic thinks he needs at that moment.  And if this has

18     consequences for the proceedings, we expect you to address us on that

19     matter.

20             MR. JORDASH:  Thank you.

21             JUDGE ORIE:  And if Mr. Stanisic just wants to leave for a

22     second, then that's accepted.  But if -- again, if he considers that his

23     right to be present during the proceedings would be -- not be fully

24     respected if we would continue, then of course you would tell us.

25             MR. JORDASH:  Thank you.

Page 16096

 1             JUDGE ORIE:  Then, Mr. Bakrac, if you're ready, you may proceed.

 2             MR. BAKRAC: [Interpretation] Yes, Your Honour.  Thank you.  Thank

 3     you very much.

 4        Q.   Mr. Dimitrijevic, I would like us to look at a video-clip,

 5     2D977.1.

 6             MR. BAKRAC: [Interpretation] Let me just check with the booths

 7     whether the transcript has been provided.

 8             Can we play the video-clip and then I'll have some questions for

 9     you, sir.

10                           [Video-clip played]

11             THE INTERPRETER: [Voiceover] "We cannot capture all of them.

12     They will all lead to" --

13             No sound.

14             JUDGE ORIE:  Mr. Bakrac, apparently there is no sound audible for

15     the booth.  And even if they have been provided with transcripts, then

16     still they should be able to verify --

17             MR. BAKRAC: [No interpretation]

18             JUDGE ORIE:  -- whether what is found in the transcript is what

19     was said by those appearing on the video.  So could you perhaps please do

20     something to put up the volume and perhaps then restart.

21             MR. BAKRAC: [Interpretation] Yes, I'm going to ask the

22     Case Manager.

23                           [Video-clip played]

24             JUDGE ORIE:  If I take the --

25             MR. BAKRAC: [Interpretation] Your Honour --

Page 16097

 1             JUDGE ORIE:  -- B/C/S channel, I do not hear anything.

 2                           [Video-clip played]

 3             JUDGE ORIE:  No, Mr. Bakrac, apparently it's not working.  So try

 4     to find a solution.  And perhaps meanwhile we proceed with other

 5     questions.

 6             MR. BAKRAC: [Interpretation] Yes.  Thank you, Your Honour.  We'll

 7     try and do that.

 8        Q.   Mr. Dimitrijevic, what was the focus of your attention in 1992

 9     when you returned to the headquarters in Belgrade?  What did you do

10     there?

11        A.   The first and foremost concern of mine was to look after the

12     wounded and the families of the fallen soldiers.  That was the utmost

13     priority.  The second-ranking, if I can rank my duties, was the daily

14     receipt of volunteers.  The third would be securing financing for Erdut.

15     And in addition to that I also looked after Zeljko Raznatovic, Arkan's,

16     family.  Their house was next to the headquarters.  His wife was there

17     together with their four children.  I looked after their safety.

18        Q.   When you say that you also secured financing for Erdut, could you

19     tell us where the financing came from, from which funds?  Did you fund

20     the headquarters in Belgrade as well as the Erdut requirements?

21        A.   There were two or three sources of funding.  The first and the

22     most important one was the Simina Mari [phoen] private company that had

23     been incepted.  Before Zeljko Raznatovic was the head of the Delije fan

24     club, he had a company that sold the football paraphernalia.  And the

25     third source of financing was the bakery that was his property.  And

Page 16098

 1     later on another company was incepted under the title SDG company.  My

 2     part of work was to co-ordinate all those companies.  The fifth link in

 3     that chain were the two shops that belonged to the bakery.  And the

 4     proceeds of their business also went into the funding of Erdut.

 5     Furthermore, we collected and raised money from donors and sponsors.  We

 6     were heavily involved in PR in order to procure the funds that were

 7     needed for certain payments or for helping the families of seriously

 8     wounded and fallen soldiers.

 9        Q.   Mr. Dimitrijevic, while you were in Erdut, and later on, did

10     troops, members of the Serbian Volunteer Guards, receive regular

11     salaries?

12        A.   No.  That never happened at any time.  The volunteers were never

13     paid or compensated in any way for the time that they spent in the

14     Serbian Volunteer Guards unit.

15        Q.   Were any warehouses in Erdut or Belgrade that you had warehouses

16     in which stolen goods from various battle-fields had been left?

17        A.   There were no such warehouses.  And it wasn't possible to supply

18     such warehouses from Belgrade.

19        Q.   You say you gathered funds for the families of killed and wounded

20     soldiers.  What sort of form did that assistance take?

21        A.   Well, it was mostly financial aid.  But there were other forms of

22     assistance.  We'd make it easier for there to be medical treatment for

23     the children of soldiers killed.  It would be easier for them to enroll

24     in school.  There would be care for them.  Provided -- various forms of

25     assistance were provided.  Whatever they requested from us was a matter

Page 16099

 1     of priority for us.

 2        Q.   Mr. Dimitrijevic, from March 1992 when you returned to Belgrade

 3     and onwards, how often did Zeljko Raznatovic, Arkan, go to the

 4     headquarters of the party in Belgrade?

 5        A.   Three or four times a month.

 6        Q.   Are you aware of any circumstances that relate to

 7     Mr. Zeljko Raznatovic leaving the Serbian Volunteer Guards to go to the

 8     battle-field in Bijeljina?

 9        A.   Yes, I'm aware of the reasons for that, and I know how they left.

10     At the time I was in Belgrade, and we checked the lists of the volunteers

11     in Belgrade and the situation in Erdut.  We did this on a daily basis.

12     So I had to be informed a day earlier that action was being prepared.

13     Or, rather, I was informed of the number of men who were to be involved

14     in that operation, and I took this information into account.

15             The reason for his departure -- well, according to what

16     Zeljko Raznatovic, Arkan, said, he was a patriot, he was proud of the

17     fact that the president of -- the Presidency of Bosnia and Herzegovina

18     had appealed to him to help with the situation in Bijeljina at the time.

19     He was asked to help the Serbs who were under threat there at the time.

20        Q.   I would just like to ask you something else.  You said at the

21     request of a member of the Presidency of Bosnia and Herzegovina, but the

22     name hasn't been recorded.  Whose name did you mention?

23        A.   Biljana Plavsic, a member of the Presidency of Bosnia and

24     Herzegovina.

25        Q.   Mr. Dimitrijevic, do you know how many SDG combatants went into

Page 16100

 1     the field --

 2             THE INTERPRETER:  The interpreter didn't hear the end of

 3     counsel's question, as the microphone was off.

 4             JUDGE ORIE:  Could you repeat your question because you switched

 5     off your microphone before you had finished the question, Mr. Bakrac.

 6             MR. BAKRAC: [Interpretation] Yes, I apologise, Your Honours.

 7     I'll repeat my question.

 8        Q.   Witness, do you know how many SDG members went together with

 9     Zeljko Raznatovic, Arkan, to Bijeljina?

10        A.   Sixty men.

11        Q.   Do you know where they left from to go to Bijeljina?

12        A.   They left Erdut.

13        Q.   Do you know what the capacity for accommodation was in the camp

14     in the centre in Erdut?  And at the beginning of March and at the end of

15     March and beginning of April in Erdut, how many volunteers were there in

16     the centre in Erdut?

17        A.   As for the accommodation capacity of the Erdut centre, the

18     maximum capacity was 260.  During certain periods we had some problems.

19     We had more volunteers than we could receive.  And in some cases they

20     were even on waiting lists.  So there were never more than

21     260 individuals in Erdut.

22             MR. BAKRAC: [Interpretation] Your Honours, could we please now

23     have a look at another video-clip from the collection that the

24     Prosecution disclosed to us.  2D972.1 is the number.  One hour,

25     23 minutes, and 15 seconds is where it starts, up until one hour,

Page 16101

 1     26 minutes, and 59 seconds.

 2                           [Video-clip played]

 3             THE INTERPRETER: [Voiceover] "At the time of the war in the

 4     Republika Srpska, you had troops?

 5             "A.  Yes, the Serbian Democratic Party appealed to us.  We had

 6     information that the Muslims had organised themselves.  Some members from

 7     our Serbian Volunteer Guard from here provided us with information.

 8     Curkovic, who is now involved in exchanges, did that.  They provided us

 9     with regular information on the situation in Republika Srpska.  In Bosnia

10     and Herzegovina at the time.  So we found out that the Muslims had armed

11     themselves, that there were over 300 Kalashnikovs in Janja, that there

12     were over 600 Kalashnikovs in Bijeljina itself, that a Croatian unit that

13     was composed of Albanians, of Siptars, had already infiltrated Bijeljina.

14     And during the night they were to take over power in Bijeljina.  There

15     was a list for prominent Serbs who were to be assassinated in the

16     following 24 hours.  In the course of the night we arrived.  Naturally at

17     the time, the Muslims arrived.  There were more Albanians amongst those

18     Croatian combatants.  They were holding check-points in Bijeljina.  They

19     had snipers.  It was night.  We entered Bijeljina and took over the

20     centre.  Naturally it was a merciless battle.  We didn't spare the

21     Croatian soldiers.  After the combat, Fikret Abdic and Biljana Plavsic

22     and Prascevic, the general, were present.  I showed them the weapons they

23     used.  They used automatic weapons with an Ustasha insignia on them.  It

24     said 'made in Croatia' on them.  They were green.  They'd been made for

25     these Muslims from Croatia.  So at the time we arrived at the last

Page 16102

 1     minute.  Four or five Serbs had already been slaughtered.  We had

 2     military experience.  We came from -- we'd had the experience of large

 3     battles, significant battles.  We entered Bijeljina and took it.  I also

 4     have to point out that we had a lot of help from the population here.

 5     They were confused initially.  But after one day of combat, they took

 6     weapons, what they had, hunting rifles and pistols, naturally later we

 7     distributed these things.  Major Gavrilovic who was the commander of the

 8     2nd Semberija unit, later he took weapons from warehouses to arm the

 9     population.  So there's much credit to be given to him.  There were about

10     1.500 armed individuals, later 3.000 individuals, and I have to point out

11     that Mauzer -- I conferred the rank of major on him later - helped a lot.

12     He was provided with military training by me, and later he became a

13     seasoned combatant and he established the Panther Guards Unit, which I

14     welcomed.  The more Serbian troops you have, the better."

15             The interpreter would like to point out that he didn't have the

16     time to find the relevant transcript.

17             JUDGE ORIE:  Yes, Mr. Bakrac, again there was a little problem in

18     that there was insufficient time to find the relevant transcript.  I got

19     the impression, however, that even without the transcript it was

20     translated and also that the French booth also could apparently on the

21     basis perhaps of reading the screen or the transcript was able to finish

22     its translation.  You may proceed.

23             MR. BAKRAC: [Interpretation] Thank you.  I do apologise to the

24     booths.  I thought that I had been given the go-ahead from the booths.  I

25     do apologise.

Page 16103

 1        Q.   Mr. Dimitrijevic, at the time of this battle for Bijeljina, did

 2     you ever go to Bijeljina; and if so, when?

 3        A.   I went to Bijeljina one day after the operation itself at the

 4     request of Zeljko Raznatovic to go there urgently because a soldier of

 5     ours had been wounded, Gojak Kasin [phoen].  Since we didn't know how

 6     long they would remain in Bijeljina, I had to go to Bijeljina to take

 7     charge of the wounded man and take him to the military academy.  I did

 8     that.  He had been wounded in the stomach.  They cut out a metre and a

 9     half of his intestines and treated his wound and for a certain period of

10     time he wasn't with us.

11        Q.   In order to transport the wounded man, was it necessary for you

12     to obtain a certificate?  And if so, from whom?

13        A.   At the time, no, we had no such need.  But later on we asked for

14     such certificates, especially if the conditions for transporting people

15     were difficult.  In such cases we had to have certificates from the army,

16     the JNA.

17        Q.   When you went to take charge of the wounded man, did you speak

18     with Zeljko Raznatovic, Arkan, about the operation in

19     Arkan [as interpreted]?

20        A.   Very briefly, given the fact that it was a matter of urgency.

21     But while we were placing Gojak in the vehicle, I heard certain

22     information from the officer, according to which everything went smoothly

23     and efficiently.  So the operation itself in Bijeljina didn't result in a

24     lot of losses for us.  We had this one wounded man and everything else

25     had been done efficiently and as it should have been done.  That was the

Page 16104

 1     general impression we had of our engagement in that battle in Bijeljina.

 2             What I subsequently discovered, but I wasn't present at the time,

 3     was that in the Bijeljina area and in the town of Bijeljina itself after

 4     the operation Biljana Plavsic arrived, escorted by Fikret Abdic, or,

 5     rather, together with Fikret Abdic.  General Prascevic was also present,

 6     and he welcomed the entire operation.  There was Gavrilovic; Zeljko

 7     mentioned him in this clip.  The troops didn't go out into the streets at

 8     that point in time to avoid more intense conflicts.  It was in town and

 9     we didn't want any innocent people to come to harm.  So as one would say,

10     everything went very smoothly.  And the impressions one had of the entire

11     operation were extremely positive.

12             MR. BAKRAC: [Interpretation] Your Honour, could this video-clip,

13     2D972.1, please be admitted into evidence.

14             JUDGE ORIE:  Ms. Marcus.

15             MS. MARCUS:  Your Honour, we do not object to this.  However, can

16     I suggest that there be some way to cross-reference in e-court this

17     65 ter number with the ERN of the video.  I think that would help

18     everybody later on.  There have been several other exhibits admitted

19     which were subsets of this video.  I can -- I can give the ERN if that --

20     if that would help, but if you have the ERN -- at least the surrogate

21     sheet could possibly reference the ERN.  It took quite a long time to

22     cross-reference everything in the preparations.

23             JUDGE ORIE:  Yes, if you have the ERN number, perhaps it would be

24     good to have it.

25             MS. MARCUS:  I will give it to you in one moment, Your Honour.

Page 16105

 1             MR. BAKRAC: [Interpretation] Your Honour, if I may be of

 2     assistance:  0268, V000268.

 3             JUDGE ORIE:  Mr. Bakrac, the Prosecution has no objection to

 4     admitting this video into evidence.  The Chamber will therefore admit it.

 5     But what the witness testified, of course, was about Bijeljina, and the

 6     one thing -- one of the few things that is also found in the video is

 7     that Arkan was there.  Now, I think that there's no dispute about the

 8     presence of Arkan in Bijeljina, neither is there a dispute, may I take

 9     it, that Biljana Plavsic went to Bijeljina.  But apart from that, what

10     Arkan tells us is, apart from that it was a smooth operation, but what

11     triggered it and what they found, et cetera, of course, the witness

12     couldn't tell us anything about that.  Therefore, the probative value of

13     this video is primarily that we now know what Arkan said.

14             MR. BAKRAC: [Interpretation] With your leave, Your Honour, we

15     wanted to have this part admitted into evidence because the witness

16     confirmed the fact that he also heard that my -- Major Gavrilovic from

17     the Army of Yugoslavia helped the people to arm themselves.  He heard

18     this from Zeljko Raznatovic, Arkan.  And we think that this is very

19     important in order to challenge the claims made by the Prosecution.  In

20     the video-clip, Zeljko Raznatovic mentions Major Gavrilovic and the fact

21     that he helped the people to arm themselves.  The witness said that he

22     remembered that Zeljko Raznatovic told him about this, and we believe

23     that one of the Prosecution's claims is that the accused and the Serbian

24     state security helped in some way this unit led by Zeljko Raznatovic,

25     Arkan, to arm itself and supported them.

Page 16106

 1             JUDGE ORIE:  Yes.  Did you see Major Gavrilovic in Bijeljina?

 2             THE WITNESS: [Interpretation] No, I didn't.

 3             JUDGE ORIE:  You say there was Gavrilovic, Zeljko mentioned him

 4     in this clip.  Does that mean that your knowledge about the presence of

 5     Gavrilovic, does that come from the clip?

 6             THE WITNESS: [Interpretation] No, no, Your Honour.

 7             JUDGE ORIE:  What, then, is the source of knowledge of the

 8     presence and the role played by Gavrilovic?

 9             THE WITNESS: [Interpretation] The Serbian Volunteer Guards didn't

10     return to Erdut immediately.  It remained in the barracks of the

11     Army of Yugoslavia in Bijeljina, and they stayed there for seven or eight

12     days after the operation until the situation in the town of Bijeljina had

13     calmed down, until it was assumed that there would no longer be any sort

14     of disruptive activity, there wouldn't be any combat.  I had direct

15     contact with the Serbian Volunteer Guards in the field to see how they

16     would return to Erdut.

17             MR. BAKRAC: [Interpretation] Your Honour.

18             JUDGE ORIE:  Yes.

19             MR. BAKRAC: [Interpretation] One thing has not been recorded.

20     The witness mentioned something, and I'm going to repeat the question.

21        Q.   Who was in charge of the JNA barracks in Bijeljina?

22        A.   [No interpretation]

23             THE INTERPRETER:  Could the witness please repeat.

24             MR. BAKRAC: [Interpretation]

25        Q.   Could you please repeat.

Page 16107

 1        A.   Major Gavrilovic.

 2             JUDGE ORIE:  Yes.

 3             Now, Mr. Bakrac, what I just read to the witness is all he said

 4     about Gavrilovic in his previous answer.  Now I asked him what the source

 5     of knowledge of the presence and the role played by Gavrilovic was, and I

 6     now do understand that he says Gavrilovic was in charge of the JNA

 7     barracks in Bijeljina and all the rest comes from Arkan rather than from

 8     this witness.  I'm just trying to fully understand what evidence you are

 9     presenting at this moment.  And by giving you an idea of what our initial

10     understanding of the evidence is - I'm not talking about what it finally

11     will prove or not - to give you some guidance as to what might need some

12     supplement or what really the evidence seems to be at this moment so that

13     you are not mistaken and that you consider that this witness has

14     confirmed everything that Arkan said, because that's not how I understand

15     his evidence.  Although it's now clear that to the extent Mr. Gavrilovic

16     was mentioned by Arkan, that the witness tells us that he has never seen

17     Gavrilovic there but -- although not yet giving the source of his

18     knowledge, that Gavrilovic was in charge of the JNA barracks in

19     Bijeljina.  That's it as matters stand now.

20                           [Trial Chamber confers]

21             JUDGE ORIE:  And that's the understanding of the Chamber as a

22     whole.

23             Please proceed.

24             MR. BAKRAC: [Interpretation] Your Honour, if you will allow me

25     just briefly, and I will follow your guidance.  I may be wrong, but it is

Page 16108

 1     possible that this part about Bijeljina, this part of Zeljko Raznatovic,

 2     Arkan's, interview could have been bar tabled.  However, I wanted to be

 3     helpful and help the Trial Chamber to see where Arkan's guards stayed,

 4     who helped the arming of their engagement in Bosnia and Herzegovina.

 5     That's why I asked the witness what he knew about that.  He told us.  So

 6     I wanted the witness to confirm what he knew and --

 7             JUDGE ORIE:  Yes, it's appreciated that you want to be helpful,

 8     and it's also very helpful if you would now proceed.

 9             MR. BAKRAC: [Interpretation] Thank you, Your Honour.

10             Could the booths try and locate 2D973.1 transcript.

11        Q.   In the meantime, Mr. Dimitrijevic, I'm going to ask:  You when

12     you were in Bijeljina, did you talk to Zeljko Raznatovic, Arkan, about

13     Tuzla?  If that was the case, what did you say to each other?

14        A.   I stayed in Bijeljina for a very short time, in view of the

15     circumstances.  I asked him how long he and the troops would stay in the

16     area, and he answered that he wanted to proceed in the direction of

17     Tuzla.  However, that was out of the question, that he would stay in

18     Bijeljina for a while, I don't know for how long.  Tuzla was no longer on

19     the table because Biljana Plavsic, Vladika Kacavenda, and

20     General Prascevic convinced him and told him that Tuzla was safe and that

21     there was no need for the troops to go there.

22        Q.   Thank you, Witness.

23             MR. BAKRAC: [Interpretation] Your Honour, can we now play the

24     same ERN number.  This is 2D973.1.

25             JUDGE ORIE:  One second, please.

Page 16109

 1             MS. MARCUS:  Your Honours, I can't see the relevance of this --

 2     of this excerpt or this matter relating to Tuzla.

 3             MR. BAKRAC: [Interpretation] Your Honour, I can --

 4             JUDGE ORIE:  The question has been asked.  The question has been

 5     answered.  In the evaluation of the evidence, it will turn out whether

 6     there's any relevance or not.  One second, please.

 7                           [Trial Chamber and Registrar confer]

 8             JUDGE ORIE:  One second, Mr. Bakrac.

 9             No, no number has yet been assigned to the video-clip in which

10     the interview with Arkan is presented and where the Prosecution have no

11     objection against admission.  The number would be, Madam Registrar ...

12             THE REGISTRAR:  2D972.1 will receive number D644, Your Honours.

13             JUDGE ORIE:  And is admitted into evidence.

14             Please proceed, Mr. Bakrac.

15             MR. BAKRAC: [Interpretation] Thank you, Your Honour.

16        Q.   Mr. Dimitrijevic, do you know anything about the participation of

17     Zeljko Raznatovic, Arkan, and the Serbian volunteers in the liberation of

18     Zvornik?

19        A.   Yes.  I know that after Bijeljina seven or eight days later, I'm

20     not sure about any of the dates, however, the volunteers went to Zvornik,

21     following Biljana Plavsic's instructions and based on the information

22     received from the field, and they participated in fighting, in liberating

23     Zvornik.  They acted in concert with the Army of Yugoslavia, i.e., the

24     JNA.

25        Q.   Before I proceed and put the following question to you ...

Page 16110

 1             MR. BAKRAC: [Interpretation] Could the booths now locate 2D974.1.

 2        Q.   How did you obtain the -- that information, the information that

 3     you have just shared with us?

 4        A.   When I returned to Belgrade, I continued working there.  And then

 5     I received a call from Zeljko Raznatovic, who asked me to go urgently to

 6     Zvornik, the reason being was the killing of two of our combatants,

 7     Ivan Okiljevic [phoen] and Branko Zivanovic.  I was supposed to take over

 8     their bodies, and following the established procedure I was supposed to

 9     transport the bodies to Belgrade.

10             MR. BAKRAC: [Interpretation] Your Honour, I would like to call-up

11     video-clip 2D974.1.  This is the same Prosecutor's ERN number.  Like the

12     previous video-clip.  Can we start with one hour, 29 minutes, 34 seconds,

13     to one hour, 33 minutes, and 31 seconds.

14                           [Video-clip played].

15             THE INTERPRETER: [Voiceover] "After that you consolidated power

16     here in Bijeljina, that is to say the Serbs consolidated power, a little

17     bit later Operation Zvornik commenced.

18             "That's right.  I obtained information that the Muslims had taken

19     over Zvornik, and quite by coincidence I set off with my adjutant.  We

20     set off for Mali Zvornik because they had called us urgently, could go

21     over there.  And when I arrived, I went straight to a meeting.  The

22     meeting was attended by the commander of the Zvornik SDA, the commander

23     of the Zvornik Crisis Staff, a Turk, and on the other side the commander

24     of the SDS Crisis Staff, and president of the Zvornik SDS.  In

25     Mali Zvornik on the other side of the Drina River and when asked what

Page 16111

 1     they were talking about, they said, You know the Muslims have taken

 2     Zvornik and we are looking -- we are insisting that they let the Serbs go

 3     and we will hand Karakaj over to them.  That was the story.  Of course I

 4     asked these two Serbs, Who authorised you to discuss treason?  No one has

 5     a mandate to discuss treason, and obviously I caught them and beat both

 6     of them up.  Both one and the other they were slapped a couple of times.

 7     We didn't touch the Turks.  I just gave them a pencil and paper to write

 8     how many weapons they had.  And when they saw us beating up Serbs, they

 9     wondered what we would do to them, and they wrote down the number of

10     700 armed men on pieces of paper, where their units were, how they were

11     deployed, who was leading them, and so on and so forth.  Then I asked,

12     Did you come to negotiate here?  They said we did.  I gave them an

13     ultimatum, to surrender the town by 800 hours otherwise I would destroy

14     it.  That's how it was.  At 500 hours they didn't want to surrender the

15     town.  I ordered artillery fire to be opened, and obviously we entered

16     Zvornik at 500 hours.  Fighting lasted throughout the day.  Zvornik was

17     taken.  We had a lot of prisoners.  There were many dead on their side

18     because they were not skilled in combat.  They died in sheaves.  They

19     died in sheaves.  They were fanatics.  There were a lot of fanatics.

20     There was fierce fighting going on and lasted a couple of hours, and we

21     came out as winners.  Kula was still theirs.  They resisted over there,

22     and two of my officers were killed there as a result of [indiscernible].

23     A group of Muslims was surrendering, about 40 of them, while snipers

24     waited on the other side, and when the two of them came out of the

25     shelter to accept those who were surrendering, the snipers killed them

Page 16112

 1     from the side.  And naturally we continued fighting until we captured --

 2     with the help of others, we captured Kula later, and so on and so forth.

 3     Later we left Zvornik after a couple of days.  A government was

 4     established over there which didn't function at first because a lot of

 5     trash came over from Serbia who even looted and stole from the Serbs.  I

 6     returned once to Zvornik after spending a couple of days in Erdut, and I

 7     had to impose discipline to slap the authorities around.  They were

 8     actually a band of rabble, and you know later special police units came

 9     from Pale and disarmed all those people who were in Zvornik and arrested

10     them."

11             MR. BAKRAC: [Interpretation]

12        Q.   Mr. Dimitrijevic --

13             JUDGE ORIE:  You may proceed.

14             MR. BAKRAC: [Interpretation]

15        Q.   Mr. Dimitrijevic, in this part of the interview with

16     Zeljko Raznatovic, Arkan, where he talks about Zvornik, he says I ordered

17     artillery fired.  Did the volunteers have artillery pieces?

18        A.   No, they didn't.  Never.

19        Q.   Do you know who it was -- or, rather, he stated, We took Zvornik

20     with the help of others.  Who were those others who helped them take

21     Zvornik?

22        A.   It was the JNA.  And it was only normal because the artillery

23     support that you have just mentioned was provided by the JNA.

24        Q.   Mr. Dimitrijevic, Mr. Raznatovic also mentioned that there were a

25     lot of prisoners.  Do you know what happened to the prisoners?  Did they

Page 16113

 1     tell you when you arrived to pick up the bodies of the fallen soldiers?

 2        A.   It was common practice to hand over all the prisoners to the

 3     army.

 4        Q.   Mr. Dimitrijevic --

 5             MR. BAKRAC: [Interpretation] Can we now look at 2D276.

 6             But while we are waiting for that to appear on the screen,

 7     Your Honours, I would like to tender 2D974.1 into evidence.

 8             MS. MARCUS:  This is already in evidence as P1601.

 9             THE REGISTRAR:  I apologise.

10             JUDGE ORIE:  2D974.1 is already in evidence is what Ms. Marcus

11     tells us.  You apparently agree.  Then please proceed.

12             MR. BAKRAC: [Interpretation] Your Honours, I would like to call

13     up D17 ...

14        Q.   Mr. Dimitrijevic, as you can see, this is a dispatch sent by the

15     17th Corps command of the 10th of April, 1992.

16             "We request from you to engage in air-strikes with 'fighter

17     bombers' on Kula in Zvornik on 11 April 1992 at 900 hours."

18             This was signed by Commander Major-General Savo Jankovic.  Does

19     the name ring a bell?

20        A.   I don't know him personally.  I never met him personally.  I

21     never saw him.  But I communicated with him.  I can explain, if you wish.

22             When I arrived in Zvornik, it was either on the 12th or the

23     13th of April after the killing of our two combatants in fighting, the

24     Serbian volunteers were billeted in Karakaj in the former hosiery

25     factory.  I arrived there to pick up the two bodies of our two fallen

Page 16114

 1     combatants.  I already mentioned their names, Branko Zivanovic and

 2     Ivan Okiljevic.  I had received my orders from Zeljko Raznatovic, Arkan,

 3     and I was supposed to take the two bodies back to Belgrade.  Zvornik was

 4     on the front line, and that's why I needed a written permit to allow me

 5     to transport those bodies.  I spent almost an entire day in Zvornik, in

 6     Karakaj, in the hosiery factory, where I was waiting for the paperwork

 7     that I needed to transport the bodies back to Belgrade.  The paperwork

 8     was supposed to come from Major-General Savo Jankovic.  So the same does

 9     ring a bell, but I never met the person himself.

10        Q.   Did you receive the paperwork?

11        A.   Yes, I did.  And I transported the bodies back to Belgrade during

12     the following night.  I took them straight to the military medical

13     academy, according to the procedure, and I handed the body over to

14     Captain Nikolic, who was a pathologist there.  He was in charge of post

15     mortems.  When the post mortems were completed, I took over the bodies,

16     not literally, but I looked after the bodies, because part of my duties

17     was also to provide the fallen soldiers with a dignified farewell, a

18     dignified burial.  It was my duty to inform the families of the fallen

19     soldiers, to knock on their doors and tell them that their brothers,

20     sons, husbands had died in combat.  It was a rather traumatic experience.

21     However, that was part of my duties.  And after that, together with the

22     family, I would bury the body following a procedure that was in place --

23        Q.   Mr. Dimitrijevic, we don't need to know about the entire

24     procedure, but did the army participate in the burial; and if so, in what

25     way?


Page 16115

 1        A.   Yes, the army did participate whenever there were burials.  A

 2     special army platoon would attend such burials, and this was to honour

 3     the deceased.

 4        Q.   Did the MUP of the Republic of Serbia or the DB, the security

 5     sector, also honour them in any way?

 6        A.   No.

 7        Q.   Let's now have a look at a document.

 8             MR. BAKRAC: [Interpretation] Your Honour, there's a mistake --

 9     it's been corrected, I apologise.

10             D158, could we see that on the screen, please.

11             Let's first have a look at the first page.

12             THE REGISTRAR: [Previous translation continues] ... is under

13     seal, Your Honours.

14             MR. BAKRAC: [Interpretation] I apologise, Your Honour.  Could we

15     please move into private session in that case.

16             JUDGE ORIE:  We move into private session.

17             MR. BAKRAC: [Interpretation] While we're waiting --

18                           [Private session]

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 16116











11 Page 16116 redacted. Private session.















Page 16117

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15                           [Open session]

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

17             JUDGE ORIE:  Mr. Bakrac, talking about time, we listen now to a

18     full explanation of whether there were three people killed or two and one

19     they thought would have been killed but finally was not killed.  That

20     seems to be the less relevant part, whereas the question which apparently

21     bears more relevance is the question why would the army report about

22     casualties among Arkan's men.  Now, if you look at the number of lines

23     taken by the first question and the second question, the first question

24     takes far more time and is by far the less relevant unless you convince

25     us that it has a specific relevance to know that where initially they


Page 16118

 1     thought there were three, that it turned out that the last one was not

 2     really dead.  It is a level of detail -- and if you're asking for another

 3     session tomorrow, I ask myself would you then please fill that whole

 4     session with the most relevant questions and would you then consider

 5     whether that could be done even in less than one session.

 6             MR. BAKRAC: [Interpretation] Your Honour, I apologise in advance.

 7     If that is the case, perhaps I have misunderstood something.  But

 8     tomorrow when we will be assessing the evidence, it will appear that

 9     Zeljko Raznatovic, Arkan, said there were three who had been killed.  One

10     report mentions three members of Arkan's group that were killed.  That

11     might give rise to confusion and reduce the probative value of this

12     evidence, and that is why I thought that a witness who knows why this

13     situation occurred might be of assistance and could explain this for us.

14     But provide -- he could provide the full names of the individuals

15     concerned.  I thought that might be of assistance to the Chamber.  I

16     apologise if I have made a mistake.  I'm acting with the best of

17     intentions, and believe me that when I say that I will use the session in

18     the morning to put relevant questions, that also relates to testimony

19     that has already been given.

20                           [Trial Chamber confers]

21             JUDGE ORIE:  Ms. Marcus, you're on your feet.

22             MS. MARCUS:  I just wanted to mention, Your Honours, that the

23     document Mr. Bakrac called up before, 2D276, is in evidence already as

24     D177.

25             JUDGE ORIE:  Thank you for that information.

Page 16119

 1             Mr. Bakrac, according to my briefing and information, you had

 2     required three hours for Mr. Dimitrijevic instead of three and a half, as

 3     you said at the beginning.  You have used two hours and 35 minutes until

 4     now.  You get another hour tomorrow.  And then that would be a total of

 5     three hours and 35 minutes, and that is in accordance with what you said

 6     today you would need.

 7             MR. JORDASH:  Could I indicate --

 8             JUDGE ORIE:  Mr. Jordash.

 9             MR. JORDASH:  -- that I think I will only take half as long as I

10     need, so if Mr. Bakrac wanted that, and it was something Your Honours

11     agreed with, then I'd be happy to do that.

12             JUDGE ORIE:  I think Mr. Bakrac will appreciate that you need

13     less time, but the Chamber is primarily focusing on receiving as much

14     relevant evidence in the shortest period of time, and that was the basis

15     for my ruling a minute ago.  And if Mr. Bakrac tomorrow would show that

16     every question has such relevance that it would be unfair to grant him

17     the last five or ten minutes he would then still need, the Chamber

18     certainly will consider that.

19             We adjourn for the day.  And we'll resume tomorrow, the

20     18th of January, 9.00 in the morning, in this same courtroom, II, but

21     not -- we'll not adjourn until I have instructed you, Mr. Dimitrijevic,

22     that you should not talk with anyone or communicate in any other way with

23     anyone about your testimony, whether it is testimony already given or

24     testimony still to be given.

25                           [Trial Chamber confers]

Page 16120

 1             JUDGE ORIE:  And apart from that, I would like also to instruct

 2     you that you should, not only not today, but also not at any other time

 3     in the near future talk about any information you have received about

 4     other witnesses that -- or statements given by other persons which you

 5     were informed about during the conversations you had with the

 6     Simatovic Defence.  So whatever they told you, you should keep

 7     confidential - names, content, whatever it is.  And if you would violate

 8     such an instruction, that would likely be contempt of court, which is an

 9     offence which can be heavily punished before this Tribunal.

10             We stand adjourned.

11                           [The witness stands down]

12                           --- Whereupon the hearing adjourned at 7.05 p.m.,

13                           to be reconvened on Wednesday, the 18th day of

14                           January, 2012, at 9.00 a.m.