Tribunal Criminal Tribunal for the Former Yugoslavia

Page 9356

 1                           Friday, 4 July 2014

 2                           [Open session]

 3                           [The accused entered court]

 4                           [The witness takes the stand]

 5                           --- Upon commencing at 9.00 a.m.

 6             JUDGE DELVOIE:  Good morning, everyone in and around the

 7     courtroom.

 8             Madam Registrar, could you call the case, please.

 9             THE REGISTRAR:  Good morning, Your Honours.

10             This is the case IT-04-75-T, the Prosecutor versus Goran Hadzic.

11             JUDGE DELVOIE:  Thank you.

12             May we have the appearances, please, starting with the

13     Prosecution.

14             MR. STRINGER:  Good morning, Mr. President, Your Honours.

15             For the Prosecution, Douglas Stringer, Sarah Clanton, legal

16     intern Marija Knezevic, case manager Thomas Laugel.

17             JUDGE DELVOIE:  Thank you.

18             Mr. Zivanovic for the Defence.

19             MR. ZIVANOVIC:  Good morning, Your Honours.  For the Defence of

20     Goran Hadzic, Zoran Zivanovic and Christopher Gosnell, with

21     Negosava Smiljanic, case manager, and Jolana Makraiova, legal assistant.

22     Thank you.

23             JUDGE DELVOIE:  Thank you very much.

24             Mr. Zivanovic, you may proceed.

25             MR. ZIVANOVIC:  Thank you, Mr. President.


Page 9357

 1                           WITNESS:  GORAN HADZIC [Resumed]

 2                           [Witness answered through interpreter]

 3                           Examination by Mr. Zivanovic: [Continued]

 4        Q.   [Interpretation] Mr. Hadzic, good morning.

 5             The first questions I'm going to put to you will concern your

 6     yesterday's evidence.  There are some things that need to be clarified.

 7     Once again, I will ask you to speak slowly when answering my questions.

 8             On page 9323, line 18, it says that you saw a list of the

 9     population in Pacetin.  That list dates back to 1990.  And according to

10     that list, Pacetin had 1100 inhabitants of whom 100 were Orthodox Roma

11     and 1.000 Orthodox Serbs.  Please look at the year, the year is 1990.  Is

12     that year correct?

13        A.   Good morning to everybody.

14             This is a big mistake.  That was the 1900 or 1903 census --

15             JUDGE DELVOIE:  Just one moment, please.  We have a technical

16     problem, Madam Registrar.

17                           [Trial Chamber and Registrar confer]

18             JUDGE DELVOIE:  Sorry about that.  Please continue, Mr. Hadzic.

19             THE WITNESS: [Interpretation] As I said, this is a big mistake.

20     I suppose it is due to the interpretation or perhaps I spoke too fast,

21     and the blame lies on me.

22             That census was made over 100 years ago, and at that time the

23     population was 100 per cent Orthodox, of them 11 per cent were Roma.

24     They were all killed in 1941 and there are no longer any Roma in Pacetin.

25     Maybe it will be interesting for the Trial Chamber that there are

Page 9358

 1     currently, 650 to 700 people living in Pacetin, which means over a period

 2     of 100 years, the population has been reduced by 50 per cent.  A lot of

 3     the people were killed in the Second World War.  All of the Roma were

 4     killed, and some 30 per cent of the Serbs were killed in the

 5     Second World War.

 6        Q.   I would also like to clarify another detail which concerns a

 7     question that I put to you yesterday about poetry and your attitude

 8     towards poetry.  This is on page 9034, line 5.

 9             You said that you sometimes read poetry with a girlfriend but

10     never with a man or a male friend.  You said that you also accompanied

11     your friend Branko Kovacevic to a poetry reading evening.  That was

12     before the war.  Did you go somewhere where poetry was read, or did you

13     go somewhere else?  What was it?

14        A.   I have to say when you asked me about reading or writing poetry,

15     I have to say that I never wrote poetry.  When I read poetry, since I

16     graduated from grammar school and a grammar school gives a broader

17     education, I did read poetry when I attended secondary school.

18             THE INTERPRETER:  Could Mr. Hadzic please be reminded to slow

19     down.  Thank you.

20             JUDGE DELVOIE:  Mr. Hadzic, please slow down when you speak.  It

21     is very difficult for the interpreters to follow you.

22             THE WITNESS:  Yes.

23                           [Trial Chamber confers]

24             JUDGE DELVOIE:  Mr. Zivanovic, could you -- is it okay?  Okay.

25     Thank you.

Page 9359

 1             Please continue, Mr. Zivanovic.

 2             MR. ZIVANOVIC:  Thank you, Mr. President.

 3        Q.   [Interpretation] Please continue, Mr. Hadzic.

 4        A.   I don't want to make an impression that I did not like poetry.  I

 5     did read poetry.  I read well-known poets like Yesenin, Lorca, to mention

 6     but a few.  As a result of having been grammar school student, I also

 7     read Croatian poets, Vujovic, Matos, but I never read amateur poetry, nor

 8     did I ever follow any friend's work or did it with a friend as a witness

 9     said.

10             When it comes to attending that poetry reading evening, I went

11     with my wife at the invitation of my friend Branko Kovacevic to his book

12     presentation.  I didn't go with Branko.  Branko was the host who had

13     invited us.  That was a few years before the war, perhaps five or

14     six years before the war.  And, at that time, I still didn't sport a

15     beard.

16        Q.   On page 9337, line 8, you said that the SDP lost the elections in

17     Croatia.  Could you please tell us in a bit more detail what did you mean

18     when you say they lost?  Did they win any seats in the Croatian

19     parliament at all?  What did you mean when you say that they lost?

20        A.   What I meant was that the HDZ won, i.e., that it got a majority

21     in the Croatian parliament.  The SDP was the second-most powerful party

22     in Croatia.  It had fewer MPs than the HDZ, but it did win in many

23     municipalities in Croatia, including Vukovar, where the SDP was the

24     victorious party.

25        Q.   And now let us look at two more pages, 9337 and 9338.  That

Page 9360

 1     question concerned a debate in the Vukovar municipality with regard to

 2     the constitution and amendments to the constitutions and things like

 3     that.

 4             Let me ask you this:  Did you have in mind the Croatian

 5     constitution according to which the Serbs would no longer be a

 6     constituent people or did you have another constitution in mind?

 7        A.   Another constitution.  The constitution that portrayed Croatia as

 8     an independent state.  That's how we perceived it.  We called it the

 9     so-called separatist constitution.  All of us who were on the SDP list in

10     our -- part of our platform was that we wanted Croatia to stay in

11     Yugoslavia.  That is the message that we sent to the people.  I don't

12     know when that happened.  I know that it was in 1990.  I can't even give

13     you the month.  Most of the Croatian MPs, SDP members, opted for that

14     constitution, were in favour of that constitution.

15        Q.   Let me just ask you this:  You spoke about your contribution at a

16     meeting in the Municipal Assembly.  Did that debate take place before

17     that constitution which you have just called a separate constitution was

18     adopted?

19        A.   I'm not 100 per cent sure.  I know it was adopted by the

20     parliament and that all the municipal assemblies were supposed to adopt

21     it as well.  Or whether it was the other way around.  In any case, the

22     Municipal Assembly of Vukovar adopted that constitution but it also

23     proposed very important amendments.  That was never publicised anywhere.

24     The only thing that we could read in the papers was:  Well, there you go,

25     even Vukovar has adopted that new constitution.  That was the message in

Page 9361

 1     the press.

 2             I can't remember whether that comprised Slavica Bajan's [phoen]

 3     proposal that Serbs should be eliminated from the constitution or was it

 4     an entirely new version of the constitution.  I can't remember, as I sit

 5     here today.

 6        Q.   I know that you're not a legal professional, you're not a lawyer,

 7     and you cannot discuss any amendments, but you did mention amendments and

 8     we know that a municipality cannot adopt a state's constitution.  When it

 9     comes to those amendments, did they mean that the constitutional proposal

10     could be changed with those amendments.

11             Did you understand me?

12        A.   Yes, I did understand you.  That was the gist of the whole thing.

13     A majority of us didn't have anything against the Croatian constitution,

14     of course.

15             MR. STRINGER: [Microphone not activated]

16             JUDGE DELVOIE:  Sorry, yes --

17             MR. STRINGER: [Microphone not activated]

18             THE INTERPRETER:  We can't hear Mr. Stringer.

19             JUDGE DELVOIE:  Mr. Stringer, something --

20             THE INTERPRETER:  Could Mr. Zivanovic switch his microphone off.

21             JUDGE DELVOIE:  Mr. Zivanovic, could you --

22             MR. STRINGER:  [Microphone not activated] Can you hear me now?

23             JUDGE DELVOIE:  No, not me.

24             MR. STRINGER:  My microphone is ... on.

25             JUDGE DELVOIE:  Well, I think now it's okay.

Page 9362

 1             MR. STRINGER:  Is it okay?

 2             JUDGE DELVOIE:  Yes, now it's okay.

 3             MR. STRINGER:  Sorry.  Well, the question and then the answer

 4     have long since gone into the record, but, Your Honour, we will be

 5     objecting to leading questions and the objection would have been that the

 6     last question from my learned friend was a leading question.  Because

 7     they both speak the language, Mr. Hadzic answered the question before I

 8     could raise the objection, but I did want to note that we are watching

 9     for leading questions and will object.

10             JUDGE DELVOIE:  Mr. Zivanovic.

11             MR. ZIVANOVIC:  I rephrase the question --

12             JUDGE DELVOIE:  Please do.

13             MR. ZIVANOVIC:  -- Your Honours.  Thank you.

14        Q.   [Interpretation] Could you tell me, please, in view of your

15     previous answer, and you have partially answered my previous question,

16     what was the subject of debate at that Assembly meeting in Vukovar?  What

17     was your proposal and what was the proposal of those who were in favour

18     of amendments?

19        A.   As far as I can remember, a high percentage of us supported the

20     constitution of our republic, the Croatian constitution.  However, I and

21     some other Serbs, not a majority of the Serbs, also supported the

22     amendment that was supposed to alter 1 per cent of the constitution, and

23     that concerned Croatia staying in Yugoslavia and not being an independent

24     state.  That should have been a public proposal, and together with that

25     amendment, we voted in favour of the constitution.  I was against, all

Page 9363

 1     the other Serbs were in favour, fully confident that that amendment would

 2     be adopted.  But it never happened.  To be honest, only one other MP

 3     voted together with me against.  All the other -- all the SDP and HDZ MPs

 4     were in favour.

 5        Q.   This means in -- effectively that they were in favour of Croatia

 6     seceding from Yugoslavia.  Did I understand you properly?

 7        A.   No, you did not.  Some of the HDZ MPs and the other parties were

 8     in favour of what you just said, but the party that I belonged to was in

 9     favour of the 90 per cent of the constitution and the amendment that

10     would change that one bit.  I thought that that amendment was pointless,

11     that we should not vote in favour of that constitution, that we should

12     turn it down.

13        Q.   I'm now going to read one part of the minutes because, honestly,

14     I didn't understand what exactly you said in that part of the record.

15             THE INTERPRETER:  Could Mr. Zivanovic repeat the number of the

16     page in the transcript and the number of the line.

17             MR. ZIVANOVIC: [Interpretation] Page 9343, line 13.

18             [In English] "Also there were some messages that had to do with

19     specific things related to liquidations and we heard what was said by the

20     TO and also arming Spegelj, et cetera, but all of this was before the

21     arming."

22        Q.   [Interpretation] Could you please shed some light on this?  What

23     did you mean?

24        A.   I noticed that mistake in the transcript, but it was -- it is not

25     up to me to correct that.  I believe that this will be corrected when

Page 9364

 1     they listen to the tape.  Instead of TV they recorded my words as TO.  I

 2     meant TV, meaning television, when the news was about Spegelj and arming

 3     which was a notorious fact.  But instead of the abbreviation TV, the

 4     abbreviation that was recorded was TO.  And if that is changed, I suppose

 5     that the situation will be a bit clearer, but if it's not I can explain.

 6             THE INTERPRETER:  Could the witness and the counsel please make

 7     pauses between questions and answers.

 8             MR. ZIVANOVIC: [Interpretation]

 9        Q.   Yes, since we're talking about that, can you please explain.

10        A.   As far as these quiet liquidations are concerned, I heard about

11     it for the first time on TV.  Unofficially stories circulated among the

12     Serbs that something was being planned, but that was the first time it

13     was publicly confirmed.

14        Q.   Can you tell us briefly how it was confirmed on TV by

15     Mr. Spegelj?

16        A.   All of us saw it.  Everybody can still see it.  It's the famous

17     footage where Spegelj dispenses advice on how to settle scores with

18     Yugoslav officers but also all those who support Yugoslavia, to come to a

19     house and when the owner opens the door to fire two bullets in his

20     stomach.  And that story reminded me of the scenario from 1971, when the

21     nationalist movement in Croatia was raging.  I was a young student by

22     now -- at that time.  They also at that time distributed weapons among

23     their supporters and also gave them postmen's uniforms, and the same

24     instructions.  Tudjman himself went to prison because of that.

25        Q.   We'll come back to this topic later.  But now I should like to

Page 9365

 1     look at document P70.50.

 2             MR. ZIVANOVIC:  70 -- [Interpretation] 70.50.

 3        Q.   You have seen this text.  It has been shown before during the

 4     trial, and this story mentions your name, among others, in the context of

 5     a peaceful protest in Vukovar.  Do you remember this event?

 6        A.   Yes, I do.

 7        Q.   This text says that you read a proclamation to the leadership

 8     regarding the police, asking that the police not protect you anymore.

 9             My first question is:  Did you indeed read such a proclamation?

10        A.   I gave a speech at the time to the people gathered, and there

11     were several thousand, and I remember the atmosphere was very tense

12     because we were surrounded by the special police with crowd-control

13     equipment, with dogs, et cetera, and nobody dared come close to me

14     because the usual thing is for somebody to announce the speaker and the

15     programme, et cetera, so I had to read the agenda, the programme, myself

16     so maybe the journalists understood that as a proclamation.  I can't

17     remember the details anymore.  But what I said is that we don't need so

18     many policemen with rifles in Vukovar.  I didn't know who they were

19     protecting and I didn't know why they had arrived.  In fact they were not

20     policemen.  They were later to become their new army, but at that time I

21     didn't know it.  And by that time we had already been stricken out of the

22     Croatian constitution, we, the Serbs.

23        Q.   This text also says that you had some comments to make on the

24     Croatian constitution.  It's in the second column on the -- on this page.

25        A.   Yes.  That's true, that's what I said.  And that was the thinking

Page 9366

 1     shared by most Serbs.

 2        Q.   Can you tell us how the Vukovar board of the Serb Democratic

 3     Party took place?  Can you describe it.

 4        A.   Yes, I can.  After the second round of elections in Croatia,

 5     when, as I said before, the HDZ won and the SDP lost - it didn't

 6     disappear, it just lost, meaning that it had to two or three deputies

 7     less - I realised that nobody was protecting Serb interests anymore.

 8     Both the HDZ and the other pro-Croatian parties that were in coalition

 9     with the HDZ.  And when I say "pro-Croat" I don't mean anything bad, it

10     was just a fact.  The SDP was supposed to represent the Serbs but it was

11     too busy promoting its own interests so that nobody represented the

12     interests of the Serbian people.  Then at the initiative of four or five

13     of us we went to Knin to meet with Professor Raskovic, in the month of

14     May sometime, mid-May, I think, and we asked if he would agree that we

15     establish the Serbian Democratic Party in the municipality of Vukovar

16     because both Vukovar and Knin were in Croatia.

17             He agreed and we scheduled a founding Assembly meeting for the

18     10th of June in Vukovar, in a place close to Vukovar.  We did that, and

19     then followed the technical aspects that I can describe later, if you

20     wish.

21        Q.   Can you tell us what was later done to establish this board after

22     this talk you had with Professor Raskovic?

23        A.   I skipped a very important thing.  Just after we returned from

24     Knin, we formed a so-called initiative board and named the chairman.  He

25     was my colleague from Vupik, now late Slobodan Tripic.  We were 15 on

Page 9367

 1     that board, and we organised this founding Assembly in Vukovar for the

 2     10th of April [as interpreted].  We organised security for the meeting.

 3     We obtained a permit for this meeting from the police, and we had talks

 4     in various local communes.  We advertised it so that people would come

 5     and listen to Professor Jovan Raskovic, member of the academy.

 6        Q.   Could you just repeat when the Assembly was to take place?  I

 7     don't think the date we have on the LiveNote is correct.

 8        A.   I believe the founding Assembly was held on the 10th of June,

 9     1990.

10        Q.   In this first contact with Professor Raskovic, what impression

11     did he make on you?

12        A.   My first impression was later confirmed when I got to know him

13     better.  He was one of the smartest people I've ever met.  The impression

14     he left was of a very composed, reasonable man, and his work later proved

15     that he was, indeed, a calm, reasonable man promoting peace, completely

16     contrary to the Dinarian type of person in the Balkans who are mostly

17     impulsive.

18        Q.   When you were in Knin, did you meet anyone else from the SDS?

19        A.   I met Marko Dobrijevic who was a lawyer in Knin.  He had some

20     technical job assisting Professor Raskovic and later Milan Babic, who was

21     president of the Knin municipality.  But I didn't talk to him.

22        Q.   Before this rally on the 10th of June, could you tell us where

23     this rally was to take place?

24        A.   It was supposed to take place, and it was held, in Adica, which

25     is a picnic place in the town of Vukovar.  Perhaps 300 metres from the

Page 9368

 1     house of Mr. Boro Savic, at the end of his street.

 2        Q.   What was going on at that meeting, if you could tell us briefly.

 3     Who attended, were there any speakers?

 4        A.   Well, the main -- the keynote speaker was Professor Raskovic.

 5     There were other speakers from Knin, I believe, including Branko Popovic,

 6     who maybe attended some later rallies, so I might be confused about him.

 7     Also Slobodan Tripic addressed the people as chairman of the initiative

 8     board and Mr. Milan Paroski also spoke.  I don't know who invited him but

 9     he introduced himself as an MP from Serbia.  I don't know whether that

10     was true.  And I gave a very short speech.  In fact, I only thanked the

11     people for electing me as chairman of the Municipal Board.

12        Q.   And how did you come to be elected president or chairman of the

13     Municipal Board?

14        A.   I was nominated by the 15 people who were members of the

15     initiative board who had met perhaps five or six times before this

16     founding Assembly.  In fact, they had to talk me into it because when I

17     became a member of the Serbian Democratic Party, it didn't cross my mind

18     that I could one day become a high-ranking official.  Maybe I can tell

19     you a story to describe the situation.

20             When I returned home after being elected president, my father,

21     who was by that time old and much wiser than I, when everybody was

22     congratulating me, my father didn't.  Instead he asked me what my salary

23     would be.  I thought that he didn't know anything about these things so I

24     said:  This is a honorary position.  I'm just supposed to work.  There's

25     no salary.  And my father said:  Well, that's precisely why they elected

Page 9369

 1     you.  If it were a good job, they would have taken someone else.  They

 2     know that you will work for free.

 3             That's what I will always remember.

 4        Q.   Can you tell us, did Professor Raskovic ever make clear what his

 5     position was concerning the Serbs in Croatia and their position, whether

 6     they should stay within Yugoslavia, et cetera?

 7        A.   It was said so many times at many rallies:  Serbs will stay in

 8     Croatia to the extent that Croatia stays in Yugoslavia.  That was the

 9     main thing.  And he always mentioned in all his speeches that from the

10     times of Ante Starcevic, Serbs had been called disruptive, a disruptive

11     factor in Croatia, which, of course, wasn't correct, and he explained why

12     it wasn't.

13        Q.   Just -- if could you add something to your previous answer, when

14     you said you were elected president of the Municipal Board.  Which

15     municipality was that?

16        A.   The municipality of Vukovar, within the boundaries of the

17     municipality of Vukovar as per Croatian law that prevailed at the time.

18        Q.   You will recall that Boro Savic was heard by this Court.  Can you

19     tell -- tell us, since when have you known him?

20        A.   I've -- had known him perhaps for ten or 12 years before the war,

21     which means from 1977 or 1978 or 1979.

22        Q.   And how did you come to know him?

23        A.   Boro was born in Sabac, Serbia.  He was some sort of travelling

24     salesman.  He didn't have a serious job.  He was married to a teacher

25     from my village, who was a friend of mine and my then-girlfriend.  And

Page 9370

 1     that woman teacher had a small studio, and Boro, when he came to visit,

 2     he stayed at her place because he didn't have an apartment.  And later

 3     they got married and moved to Vukovar.  I mean, Boro came to Pacetin

 4     almost as a homeless person.

 5        Q.   Could you say, I mean, well, how often did you see him?  How did

 6     this go, this acquaintance of yours, or socialising, if we can call it

 7     that?

 8        A.   Before all of these things happened in relation to the SDS we did

 9     not really socialise.  He is a considerably older than I am, and he had a

10     different circle of friends.  Perhaps -- well, that's characteristic.  He

11     did not make friends with people that he could not take advantage of, so

12     I was not really part of his circle.  So we had these relations within

13     the party for about a year, from mid-May 1990 until 1991 mid-May, or,

14     rather, last time -- actually the last time I saw him was around the

15     1st of June, 1991.

16        Q.   Ou say that the last time you saw him was around the

17     1st of June, 1991.  Can you remember what the situation was when you

18     actually saw him?

19        A.   I can.  It was at Vukasin Soskocanin's funeral in the village.

20     And I think that after that I saw him only once before the war, during

21     those ten days or so during the month of June or perhaps not even that.

22     And then I only saw him in 1995 or 1996.

23        Q.   Could you please repeat the name of the person whose funeral it

24     was when you saw -- well, actually, you don't have to, because it's been

25     corrected.  I mean ...

Page 9371

 1             Now I'd like to ask you to take a look at the statement that you

 2     gave to the Prosecution.  That is P50.  It has to do with paragraph 7.

 3             You see, in paragraph 7, it says that he made you president of

 4     the board; is that correct?

 5        A.   Well, that's not correct.  I was selected by the initiative

 6     board, and I said there were about 15 members there, and everybody was in

 7     favour, and Boro Savic was among those 15 who were in favour.  So his

 8     participation was just one-fifteenth, like the remaining 14 persons, so

 9     this is a strange way of putting it.

10        Q.   Further on he says that he was secretary of the SDS in Vukovar

11     and that he wanted to appoint serious people.  Can you say when it was

12     that he was appointed secretary of the SDS for Vukovar, if that actually

13     did happen?

14        A.   I'm not sure whether he was appointed on the 10th of June, when I

15     was selected, but I'm certain that he could not have been selected before

16     that because the SDS did not exist before that in Vukovar.  So what he

17     said here is mind-boggling.

18        Q.   Was he a person who made appointments at all?  As he put it here,

19     he appointed these people to the board, or was it a body of the party

20     that did that?

21        A.   Well, he said that he was secretary, and that office speaks in

22     itself, how powerful he was.  Let me be as mild as possible and as a fair

23     as possible.  He was an equal member.  He was not inferior but he was not

24     dominant either.  We were all on a footing of equality but I cannot

25     define it now.  It was after Plitvice, after his suffering there, and I'm

Page 9372

 1     not sure that he -- well, this is a kind of egocentrism.  I did not

 2     really know him to be that way before.

 3        Q.   Another question:  He says that at the time there was this big

 4     problem, namely, the Socialist Party of Serbia of Slobodan Milosevic, as

 5     they considered that there should not be any other political party apart

 6     from the SPS [Realtime transcript read in error "SBS"].  At the time were

 7     you confronted with that problem?

 8        A.   Since we will be talking about his entire statement now for a

 9     while, if I understand you correctly, I really feel ashamed because I

10     used to work with Boro.  I have to deny all of that and say that all of

11     this is crazy.  A normal person cannot be saying all of these things.  It

12     is crazy.  What kind of influence did the Socialist Party have in the

13     1990s at Croatia.  The SPS appeared only when the Krajina was

14     established.  He completely confused things here.  And there's no

15     chronological logic involved.

16             JUDGE DELVOIE:  Mr. Zivanovic, a clarification in the transcript.

17             At line 23 of the current page, it is said -- the acronym there

18     is said to be SBS.  And in line 5 -- well, no, 23 is the previous page.

19     Line 5 of the -- of the actual page there is an acronym missing.

20             Could you clarify that with the witness, please.

21             MR. ZIVANOVIC: [Interpretation]

22        Q.   Could you please repeat once again the acronym of this political

23     party.  Or, rather, could you repeat what you said -- or actually I'm

24     going to repeat the question to you because it actually has to do with my

25     question.

Page 9373

 1             So my question was:  It actually has to do with paragraph 7 of

 2     the statement, where it says that a special problem at the time was the

 3     Socialist Party of Serbia, abbreviated as SPS, the party of

 4     Slobodan Milosevic.  Because they believed, allegedly, that only the SPS

 5     should exist there in Slavonia, Baranja, and Western Srem?

 6        A.   Well, I've already said that was crazy.  The SPS, this party of

 7     Slobodan Milosevic, did not appear there in any form during 1990.  It was

 8     Croatia at the time.  So not a single party from Serbia was there except

 9     for some of these opposition MPs from Serbia who came there, that's a

10     very well-known thing, but the Serb authorities did not come at all.

11        Q.   In paragraph 8, he claims that the Party for Democratic Change of

12     Ivica Racan, the SPD, won only a few seats.  Can you tell us whether that

13     is correct that this party, the SDP, had only a few seats?

14        A.   That's not correct either.  He said that in just a silly way, a

15     stupid way.  The SDP had many MPs, and in the Municipal Assembly of

16     Vukovar they had an absolute majority of assemblymen.

17        Q.   When you say "many MPs," what did you mean?

18        A.   In the parliament of Croatia, I mean the SDP.  I'm just saying

19     that in accordance with what he said here, several, a few.  You can

20     either say 50 or 70 or 30 and then everybody can conclude what is a lot

21     or many, in relation to 150.

22        Q.   Could we please take a look at paragraph 11.

23             It says that a meeting was held of the Serb Democratic Party in

24     August 1990 and that he could not attend and that the party split at that

25     meeting.  Is that the truth?

Page 9374

 1        A.   Well, it is not the truth.  These are conclusions -- well, when I

 2     read this entire paragraph 11, I see that those who support conspiracy

 3     theories would be envious of these conclusions of his because this is

 4     simple fantasizing, not based in reality at all.

 5        Q.   Why you saying that this is fantasizing, that in August 1990 the

 6     SDS split or fell apart?

 7        A.   Well, the SDS was established on the 17th of February, 1990.  So

 8     from February to August, it is, what, six months, and it was only then

 9     that they had gained momentum and that they started operating, so they

10     were getting stronger and stronger rather than falling apart.

11        Q.   Was that manifested in some way at the time, in that period,

12     August 1990?

13        A.   Well, in Vukovar we only started organising local boards and

14     rallies, and Professor Raskovic appeared at some of them, so we were in

15     full sway.  He confused everything that happened there.  After two or

16     three years, all of this got mixed up in his head.  I mean, I assume that

17     this was needed for some other testimony so then it was just inserted by

18     way of some compilation because this is totally senseless.  It makes no

19     sense whatsoever to say all of this.  It never existed, these names.

20        Q.   Which names?

21        A.   The influence of Jovica Stanisic in 1990 over Milan Babic.  That

22     is totally impossible.

23        Q.   This is what I'm interested in here.  Another thing that he

24     mentioned.  That Raskovic -- or, rather, that Raskovic warned him that

25     the party would fall apart and that he specifically gave tasks to you and

Page 9375

 1     Vukcevic, Vojislav Vukcevic.  Can you tell us whether that happened, did

 2     he give you some assignments, tasks, or to Professor Vukcevic?

 3        A.   Borivoje Savic was secretary of the Municipal Board and I was

 4     president of that board, and he never gave me any assignments whatsoever.

 5     Now the Trial Chamber can take my word for it.  I'm speaking under oath.

 6     But as far as Professor Vukcevic is concerned, I don't want to say now

 7     whether Boro gave assignments to him, but let me say that

 8     Professor Vukcevic was a doctor of law and for a while he was also the

 9     dean of the law school in Osijek and also he was a judge in

10     Beli Manastir.  He is at least 15 years older and at least three times

11     smarter than Boro Savic, and Boro Savic could not give him any kind of

12     assignment, ever, whatsoever.

13        Q.   We can move on to paragraph 22.  Here, he says that he worked

14     with his father in Vupik -- with your father in Vupik; is that correct?

15        A.   My father did work in Vupik, and after that, I worked there.  I'm

16     not sure whether Boro got a job in Vupik before I did.  I think that I

17     got a job before he did, but that doesn't matter.  We worked together in

18     Vupik, but we were not in the same basic organisation, so I did not

19     really co-operate with him through our work.

20        Q.   It says that sometime in mid-May he called you and told you that

21     a board for Slavonia, Baranja, and Western Srem would be set up.  Can you

22     see that?  Did he really tell you that a board would be set up for

23     Slavonia, Baranja, and Western Srem?

24        A.   He didn't tell me that.  He could not tell me that at the time

25     because that didn't exist at the time.  Maybe this was written

Page 9376

 1     unbeknownst to him or he is totally insane; I mean, Boro Savic.  These

 2     are some elementary things.  It's like two plus two.  There's nothing for

 3     me to prove.  There is nothing for me to say about some things that did

 4     happen and cannot be changed, some things that are so obvious.  I

 5     apologise.

 6             We first established the Municipal Board of the SDS in Vukovar.

 7     And then Municipal Boards were established in all the municipalities in

 8     Eastern Slavonia, meaning, Osijek, Beli Manastir, and Vinkovci.  When it

 9     comes to Western Slavonia, Municipal Boards were set up in parallel with

10     us, in Podravska Slatina a day before Vukovar and then in other places,

11     and we did not take part in all that because the distance from us was

12     about 200 kilometres.  It was only towards the end of 1990 or the

13     beginning of 1991, at the initiative of Ilija Sasic, Veljko Dzakula,

14     myself, and Boro Savic that the Regional Board for Slavonia and Baranja

15     was eventually established.  And the term "Western Srem" did not appear

16     before 1991.  That term did not exist.

17             I really could not talk to Boro.  However, since I've known him,

18     this is not the way he was.  This is just a lot of nonsense.  Whatever he

19     knew, he merged together and told the story as if everything happened in

20     1991, but it didn't.  Some things happened in 1992 and 1993.

21             He mentions the Executive Board here.  I believe that what he had

22     in mind was the initiative board.  I don't -- I can't read his mind.

23     However, what I'm reading here is not correct.

24        Q.   Can you at least clarify this part because the Executive Board is

25     mentioned here as well as the Regional Board.  Could you please tell us

Page 9377

 1     which bodies or which organs did the Serbian Democratic Party have?

 2        A.   The Serbian Democratic Party was established in Knin on the

 3     17th of February.  It had its Main Board and its Executive Board,

 4     independently of Goran Hadzic and Boro Savic.  At the time we did not

 5     even hear of the SDS.  At least I didn't and I'm sure Boro didn't either.

 6     It was only in May that we started setting up our Municipal Board.  We

 7     established the initiative board, and then on the 10th of June, the

 8     Municipal Board was set up.  Before that, there was nothing.  From then

 9     on we started setting up local boards in local communes.

10        Q.   Can you please tell us, you mentioned the Main Board of the SDS

11     and the Executive Board.  Which body had the supremacy, which was the

12     highest party body?

13        A.   The highest party body was the Main Board and its president was

14     Jovan Raskovic.  At the time I was not a party member.  I don't know when

15     the Executive Board was established.  There was no need for me to know

16     that.

17        Q.   Do you know who was it who set up the Executive Board, i.e., who

18     selected the Executive Board members?

19        A.   The way things were done when I joined, it was the Main Board who

20     did that.  In politics, in the executive and judiciary power, you have to

21     imagine the Main Board as the Assembly and the Executive Board as the

22     government of a state.

23        Q.   Since we're talking about the Executive Board, were you elected?

24     Did you have a position in the Main Board of the Serbian Democratic

25     Party?  Specifically you.

Page 9378

 1        A.   According to the party statute, every president of any

 2     Municipal Board automatically becomes a member of the Main Board.  And

 3     later, as a member of the Main Board, I was elected as a member of the

 4     Executive Board.

 5        Q.   And now tell me, it says here that you were the president of the

 6     Regional Board in the same paragraph, 22.  Were you, indeed, the

 7     president of a Regional Board of the SDS?

 8        A.   No, never.  The president of the Regional Board of the SDS for

 9     Slavonia was Veljko Dzakula, for Slavonia and Baranja only because

10     Western Srem did not feature at the time.  That term was coined by

11     Ilija Petrovic.  I don't know why.  But it was only later.

12        Q.   And who were the members of that Regional Board?  Were they

13     elected, or were people just appointed based on their positions and

14     functions?

15        A.   They were presidents of Municipal Boards that -- and by virtue of

16     those positions in Slavonia and Baranja, they became members of the

17     Regional Board.  And there was also Boro Savic as the secretary.  This

18     means that every Municipal Board could put forth another candidate in

19     addition to their president.

20        Q.   He says that he was the one who helped you become a member of the

21     Main Board of the SDS; is that correct?  That's in paragraph 23.

22        A.   No, that's not correct.  I have to explain to this Honourable

23     Trial Chamber, that, at that time, in the Republic of Croatia where we

24     were, there were no candidates who would wholeheartedly accept any of the

25     positions that involved such activities, so nobody needed to push

Page 9379

 1     anybody.  We had a major problem to get members, to activate our

 2     membership.  Nobody was overly ambitious to hold a position because that

 3     was all without any pay, as I just told you when I told you the story

 4     about my father.  We only spent money because we used our cars, we bought

 5     our own petrol.  Nobody actually paid us expenses.  We -- as a result of

 6     our positions, we were out of our pockets.

 7        Q.   Let's look at paragraph 28.  He says that he established the

 8     SDS board in Vukovar; is that correct?

 9        A.   It's not correct.  He says that that happened on the 9th of June,

10     and that's also not correct.  He is so off here.  And, again, he mixes up

11     things, and he uses a wrong chronology.  He mentioned Slobodan Milosevic.

12     At that time, a majority of the SDS members were against

13     Slobodan Milosevic's policies and against the Serbian policies.  It was a

14     public matter.  He is talking with hindsight and distorting things while

15     doing that.

16        Q.   In paragraph 29, he mentions Ilija Petrovic and Ilija Koncarevic

17     as well as Milan Paroski.  He says that Koncarevic and Petrovic turned up

18     as SDS activists from Vojvodina, although that party had not been set up

19     there yet.  Do you know if the Serbian Democratic Party was established

20     in Serbia at that time?

21        A.   Yes, it was established and registered in Serbia as the

22     Serbian Democratic Party.  But it was independent from its counterpart in

23     Croatia.  Boro Savic and I were even invited as guests to a founding

24     meeting in Vojvodina.

25        Q.   Do you know that Ilija Koncarevic and Ilija Petrovic were members

Page 9380

 1     of that party, the Serbian Democratic Party, in Serbia?

 2        A.   Both Boro and I knew that because we were [as interpreted] our

 3     hosts there.  They were party members, and we were their guests.  That

 4     meeting took place in Novi Sad, and I believe that Professor Raskovic

 5     also attended.  I'm not sure, though.

 6        Q.   Milan Paroski is also mentioned here in the same paragraph,

 7     paragraph 29, together with Koncarevic and Petrovic.  He says that they

 8     put pressure on the SDS board in Vukovar.  Are you aware of any pressure

 9     that was put on you to bear by Paroski or Koncarevic and Petrovic?  And

10     when I say "you," I mean your board in Vukovar.

11        A.   Neither I know that nor was that possible, as a matter of fact.

12        Q.   Immediately on the following page and the paragraph actually

13     continues on that page, he says that -- or, rather, only Koncarevic and

14     Petrovic said that they were representatives of the state security of

15     Serbia and that they also represented President Milosevic.  Did

16     Koncarevic and Petrovic ever tell you any such thing?

17        A.   No, they never said that to me.  And it's not correct.  Boro is

18     just making things up.

19        Q.   Did they hear them say that to somebody else or did you hear from

20     somebody else --

21        A.   No, I never heard that.  They were members of the

22     Serbian Democratic Party for Serbia which means that could not be members

23     of any service or delegates representing a president who had his own

24     party.  They were members of an entirely different party, so this just

25     doesn't make sense.

Page 9381

 1             The Serbian Democratic Party in Serbia was an opposition party.

 2     It had its goals, and one of them was to take over power from the ruling

 3     party.

 4        Q.   It was an opposition party to what party?

 5        A.   The SPS party, Milosevic's SPS, which was the ruling party at the

 6     time.

 7        Q.   According to what you know, what was Ilija Koncarevic's position

 8     what was his profession?  What did he do at the time?

 9        A.   Ilija Koncarevic was a pensioner.  He was pensioned off as

10     captain first class in the JNA.

11             And Ilija Petrovic, when I met him, he was introduced to me as

12     the director of the postal services in Novi Sad.  However, when I got to

13     know him better, I realised that he was one of the junior managers in the

14     postal service, so he was not the general manager of the whole postal

15     service.

16        Q.   And now let's move to paragraph 35.  You will find it in the

17     middle of that paragraph.  It says there that a majority of Serbs in

18     Slavonia, Baranja, and Western Srem shared his opinion that the Serbs

19     should stay in Croatia.  Can you comment upon that, if you understand

20     what he meant?

21        A.   All the paragraphs that we have been discussing are just

22     nonsensical.  I can't say anything about the end of the paragraph before

23     I say something about the beginning.

24             He says that Raskovic listened to Milosevic.  Everybody in Serbia

25     knew that Raskovic was friends with Dobrica Cosic and that they -- their

Page 9382

 1     views were very opposite.  And when he says that Raskovic became a MP

 2     because Milosevic wanted him to do that, but it's impossible.

 3             This -- these are all stupidities.  They have nothing whatsoever

 4     to do with reality.  All members of the Serb Democratic Party in

 5     Slavonia, Baranja, and Western Srem supported Professor Raskovic's

 6     position and that position was Serbs will stay in Croatia to the extent

 7     Croatia stays in Yugoslavia.  These positions by Raskovic were positions

 8     that he adopted after the peaceful reintegration.  He seems to be

 9     defending himself here, although he was never charged with any crimes,

10     either by this Tribunal or anywhere in Croatia.  He says a majority of

11     the Serbs.  We had referendums, and 99.99 per cent of the Serbs were in

12     favour of the opposite.  These are elementary truths and it can be

13     mathematically proven.

14             He lives in Croatia now.  He wants to curry favour with Croats

15     that's why he is saying all these things which are not just lies but pure

16     fantasies.  Because when somebody has an ill-intent and lies, then he can

17     do it and it cannot be proven.  And he is lying about things that are so

18     easily proven because they are notorious and everybody is aware of them.

19        Q.   I think some parts of your answer are again missing from the

20     record because you are speaking much too fast.

21             When you said it was impossible that Dr. Raskovic rejected the

22     offer to be an MP in the Croatian Assembly, Croatian parliament, why was

23     it impossible that he did that?

24        A.   I'm saying that it was impossible the way Boro Savic explained

25     it, that Raskovic refused to be a member of the Croatian parliament

Page 9383

 1     because of pressure from Slobodan Milosevic.  I'm not saying that he

 2     didn't have his own reasons, but he certainly didn't refuse it under

 3     pressure from Slobodan Milosevic.

 4        Q.   Was Raskovic an MP in the Croatian parliament, ever?

 5        A.   Well, I was trying to anticipate what Boro Savic was thinking.

 6     It seems to me implausible that my own associate would talk such rubbish.

 7     I suppose that he meant one of those five deputies who were elected on

 8     the SDS ticket, but the way he explained it is completely implausible.

 9     It's beyond understanding.

10        Q.   At the end of this paragraph, he says that the chequer-board

11     emblem was also on the coat of arms of the Socialist Republic of Croatia.

12     Can you tell us now, because the chequer-board emblem was mentioned many

13     times as something that provoked the Serbs' discontent, could you tell us

14     why it was disturbing?

15        A.   What Boro said is true but he didn't invent hot water.  We all

16     know that.  The chequer-board emblem existed since the Kingdom of

17     Slovenes, Croats, and Serbs, and it was also in the coat of arms of the

18     Kingdom of Yugoslavia, together with the four letters S.  That's not in

19     dispute.  But the Serbs would not accept the chequer-board emblem as a

20     separate symbol placed on the flag.

21        Q.   Can you tell us what does the chequer-board emblem consist of?

22        A.   It has 25 fields, five by five, and in our documents while we

23     were in the republic of Croatia, the first field was red, the following

24     one white.  During the independent state of Croatia, the first field in

25     the left top corner was white so that a letter U could be placed in it,

Page 9384

 1     and the U meant Ustasha.  And that's why the Serbs rejected the

 2     chequer-board emblem at that time.

 3             As for me personally, in my position, Boro did not say anything

 4     new here.  I agree with it.  Yes, the chequer-board symbol was on every

 5     document of mine - my school diploma, my other documents - but that's a

 6     completely different issue.

 7        Q.   Could we clear up another thing about this chequer-board.  You

 8     say that in your documents, in fact, the documents issued by the

 9     Socialist Republic of Croatia, the first field was red, whereas in

10     World War II the first field was white.  Now, when the chequer-board

11     emblem was to be reintroduced, how was it supposed to be introduced

12     again?  With the first field red or white?

13        A.   Well, I cannot say under oath that I'm sure, and perhaps I

14     shouldn't speculate.  But I suppose this is just the technical detail.

15     The chequer-board emblem should not have caused a war.  It shouldn't have

16     been such a problem to Serbs, and I also blamed myself -- I blame myself

17     now that I took it that way at the time.  It's perhaps the legacy of

18     Communism that it was so unacceptable to us.  That's the only thing I can

19     say I'm sure of under oath.

20        Q.   I'd like to move to paragraph 69.  I don't need to show you this

21     text because you probably remember this article from the newspaper.

22             JUDGE DELVOIE:  Mr. Zivanovic, as this is a new paragraph you are

23     discussing now, would this be a convenient moment?

24             MR. ZIVANOVIC:  Yes, Your Honour.

25             JUDGE DELVOIE:  Thank you.

Page 9385

 1             We'll take the break.  Be back at 11.00.

 2             Court adjourned.

 3                           --- Recess taken at 10.28 a.m.

 4                           --- On resuming at 11.00 a.m.

 5             JUDGE DELVOIE:  Please proceed, Mr. Zivanovic.

 6             MR. ZIVANOVIC:  Thank you, Mr. President.

 7        Q.   [Interpretation] Mr. Hadzic, could we now look at paragraph 69 of

 8     this statement.  Would you please at paragraph 69 of the statement we've

 9     been reviewing.

10        A.   Yes.

11        Q.   In this passage, Mr. Savic discussed an article published after

12     you were released from prison, both of you, following your arrest at

13     Plitvice, and he says that you were keen on accumulating, amassing

14     various positions in the SDS party.  Was that true?

15        A.   No, it's not.  I had only one position:  President of the

16     Municipal Board of the Serbian Democratic Party.  And under the statute

17     of the Main Board of the party, that was a position that implied certain

18     functions, regardless of who occupied it, and I was deputy to the

19     Regional Board.  What's interesting here is that Boro Savic was actually

20     a member of every body that I was a member of.  That's really curious.

21        Q.   He says the same journalist wrote, and Boro Savic agrees, that

22     Boro Savic was the SDS ideologist, a very knowledgeable one.  Do you

23     share this opinion?

24        A.   I don't.  Boro Savic and I happened to be in Plitvice completely

25     by chance, and it was by chance that we became public figures.

Page 9386

 1     Boro Savic was not the party ideologist.  The main person in the party

 2     was Dr. Raskovic.  And we came into the public eye quite by chance after

 3     Plitvice.  Boro Savic was completely unknown to people.  His speeches

 4     were never heard in public.  People couldn't know him.  I don't know what

 5     this journalist meant until -- unless he had parapsychological powers.

 6     Maybe he could read Boro Savic's mind.

 7        Q.   But to the best of your knowledge, was he really a knowledgeable

 8     ideologist of the SDS?

 9        A.   As far as I know, he was not.  He was not even very well

10     educated.  He said himself he had graduated from the secondary school of

11     agriculture in Sabac and some higher school in Vinkovci.  He didn't have

12     the kind of education that would enable him to be an ideologist.

13        Q.   Could we now look at paragraph 70 of his statement.  It relates

14     to the day when both of you were released from the remand prison.  And he

15     said you were allowed to make a phone call then, and you phoned

16     Ilija Koncarevic, whereas he had believed you would call your father.

17             Can you recall this?

18        A.   I don't recall that it happened that way.  Maybe we were allowed

19     to make a phone call, but I don't see why I would have called

20     Ilija Koncarevic.  Why would I do that?

21        Q.   And he says from that time on, he was no longer friends with you.

22        A.   That's not true.  During his testimony, I was able to read all of

23     his statement, and further on, he contradicts himself.  He complains that

24     I stopped calling him.  He complains that I stopped all contact with him.

25        Q.   Can you remember what day it was when you were released from jail

Page 9387

 1     in Plitvice?

 2        A.   I believe it was the 3rd of April, but I'm not sure.

 3        Q.   And now paragraph 74.  He says he was thinking about replacing

 4     Goran Hadzic because you were too much under the influence of

 5     Slobodan Milosevic and that you had come to be under his influence after

 6     these events at Plitvice.

 7             Can you tell us, is it the case that after these events at

 8     Plitvice you were indeed under the influence of Slobodan Milosevic, did

 9     you know him, did you have any communication with him?

10        A.   I was never under the direct influence of Slobodan Milosevic,

11     although I later met him and collaborated with him.  This is pure

12     nonsense, a lie.  I saw Slobodan Milosevic at a short meeting with the

13     delegation of members of the Serbian Democratic Party from all of

14     Croatia, and that was after the TV show about the arming of Croats, the

15     Spegelj movie.  At that time, I never talked to him, nor did I exchange

16     any views with him.  It was a large delegation, 30, maybe even 50 people.

17        Q.   And do you remember roughly when this took place?

18        A.   It could have been a month before Plitvice; perhaps a bit more

19     than that.  So after that -- after that TV show about Spegelj, 1990.

20        Q.   Could you just repeat the year.  Tell us, is it that year?

21        A.   I think it is 1991, the beginning of 1991.  Because the Serbs

22     were afraid when they heard about the arming of the Croats, and they

23     called me from Knin, from the party, saying that Milosevic would receive

24     a delegation in order to make us feel calmer, in a way.  Because we were

25     completely opposed idealogically to the positions taken by the

Page 9388

 1     then-ruling party in Serbia, the SPS.  I was surprised that he wanted to

 2     receive us at all.

 3        Q.   Can you tell us briefly what these opposed positions were?  On

 4     the one hand, the SDS, and on the other side, Slobodan Milosevic and his

 5     party?

 6        A.   Well, speaking in very rough terms, the SDS was an anti-Communist

 7     party with a pronounced democratic orientation.  Although many of us

 8     members were former Communists.  However, I and most of my friends

 9     realised what a delusion this was, this Communist delusion.  And the SPS

10     remained at least at that time in 1990, along the lines of the former

11     League of Communists.

12        Q.   Could we now take a look at paragraph 78.

13             JUDGE DELVOIE:  Mr. Zivanovic, I might have a problem here.  If I

14     understood your question well, you asked the witness what the opposed

15     positions were of, on the one hand, SDS, and on the other side,

16     Slobodan Milosevic's party.  And the witness gave an answer about SDS,

17     indeed, but on the other hand, the SPS.  Is that Slobodan Milosevic's

18     party?  Or is it a transcript issue?  On line 21 of page 32.  The witness

19     said about the former Communists, this Communist delusion, and the SPS

20     remained at least at that time in 1990.  Is he talking about the

21     Milosevic party there?

22             MR. ZIVANOVIC:  I think so.  He -- he spoke about the difference

23     between SDS and the SPS, but I could clarify with the witness.

24             JUDGE DELVOIE:  And SPS -- sorry about the fact that I'm not a

25     hundred per cent in these acronyms.  The SPS is Milosevic's party?

Page 9389

 1             MR. ZIVANOVIC:  Correct.

 2             JUDGE DELVOIE:  Thank you.  Then it's okay.

 3             MR. ZIVANOVIC: [Interpretation]

 4        Q.   Can we move on to paragraph 78 now.

 5             In this paragraph, he says that he met up with you again after

 6     what had happened in Borovo Selo on the 2nd of May.  He says that he met

 7     you again on the 7th or 8th of May on the Vojvodina side of the Danube.

 8     Do you remember whether you met up with him after the 2nd of May on the

 9     Vojvodina bank of Danube?

10        A.   I don't remember 100 per cent, but there is a high probability

11     that that did happen.

12        Q.   Further on, he says that you were with a man who you introduced

13     as your body-guard; is that correct?

14        A.   Well, that's not correct.  Because after the well-known events of

15     the 2nd of May, I was in Vukovar.  That was the first time that I crossed

16     the Danube, that I saved myself.  There was a group of people there that

17     I didn't know at all.  They were waiting for refugees and transporting

18     them to Serbia.  I had my first body-guard, I think, in the beginning of

19     September 1991 or the end of August.  So this is ridiculous.  And it's

20     also ridiculous when he says that I had an apartment in Novi Sad, on the

21     7th and 8th of May.

22        Q.   Now, you said that you crossed the Danube then.  Would you

23     explain that?  What do you mean by that?  Was that the occasion when you

24     say that you saw him?

25        A.   Well, I think that that is that possible occasion, the only one

Page 9390

 1     when I was at the Danube.  I fled from Vukovar on the 7th or 8th of May,

 2     crossed the Danube.

 3             As for my wife and daughter, I sent them off as refugees so that

 4     they could get that kind of accommodation, and I took a civilian car to

 5     Borovo Selo, and then I wanted to get my son in Pacetin so that I could

 6     give him a ride as well.  My sister was in Pacetin too.  It's not that I

 7     had an apartment in Novi Sad then.  We were in Pacetin then.  Again, he

 8     confused things, and he's speaking with hindsight.

 9        Q.   Can you say whether that was the only occasion when you came to

10     the Danube or did you come to the Danube afterwards too?  I mean, after

11     you left Croatia, after that incident in Borovo Selo?

12        A.   Well, I did come, I remember, perhaps seven or eight or ten days

13     later, once more.

14        Q.   Because I see that you are linking this possible meeting with him

15     to that particular event.  Is it possible that it was some other time

16     that you came, or is it for some other reason that you link this to that

17     meeting?

18        A.   In May, I was there, perhaps, two or three times, but I was a bit

19     perplexed by what he said, the 7th or 8th of May; whereas I fled from

20     Vukovar on the 7th or 8th of May.  If it were later, then that would be

21     more logical.

22        Q.   And at that time did you have someone standing next to you who

23     you introduced as your body-guard?

24        A.   No, I didn't have anyone there as my body-guard.  But Lazo Sarac

25     was there that second time, when Vukasin Soskocanin drowned.  I crossed

Page 9391

 1     the Danube only twice then, two or three times actually.

 2        Q.   I had intended to ask you about this later, but I see that now

 3     you -- well, you brought this up now, didn't you?  So now that you've

 4     mentioned Lazo Sarac there, the second time, what were you trying to say

 5     by that, that the second time you saw Boro Savic or was it this second

 6     time that you were doing something else?  Could you just clarify that?

 7        A.   I just wanted to say it honestly, the way I remember it.

 8     Because, in May, I did not have many opportunities to cross the Danube,

 9     and every time I crossed over, there was something important that

10     happened, and I remember that.  So the first time I fled from Vukovar,

11     that was the 7th or 6th of May.  I saved my life and I saved the life of

12     my daughter, who was with me.  And then around the 15th of May, I was at

13     the Danube when Soskocanin drowned.  So if Boro Savic was there, it was

14     one of those two times.  There couldn't have been a third time.

15             I have to point out that Boro Savic was a totally unimportant

16     person in my life.  I cannot remember when it was that I would see him.

17        Q.   Can you tell us whether this Mr. Lazo Sarac who is mentioned

18     here, whether he was ever your body-guard?

19        A.   Well, never.  To put it mildly, it's ridiculous to say something

20     like that.

21        Q.   We'll go back to this, to this topic, that is.  This is what I'm

22     interested in now.  Let us clarify this:  The text continues on the next

23     page.  It says here when Kertes took over the federal customs office,

24     Simo Stupar from Celarevo was in charge of Goran Hadzic's security.

25        A.   I don't know Simo Stupar but I know the last name Stupar from

Page 9392

 1     Celarevo.  There's Savo.  I mean, he wasn't my body-guard.  Savo Stupar

 2     has a doctorate in mechanical engineering.  He is ten years older than I

 3     am.  He was never even armed.  How could he be my body-guard?

 4        Q.   Do you know whether this Mr. Savo Stupar had some kind of a job

 5     at the time?  Was he employed?

 6        A.   He worked in Backa Palanka at a factory that manufactured

 7     agricultural equipment, but he also had some position in the Assembly of

 8     Vojvodina.  I don't know exactly what was.

 9        Q.   So Mr. Savo Stupar, was he or was he not your body-guard?

10        A.   As I've already said, no, he was not.

11        Q.   In paragraph 79, it says that you had a specific position towards

12     Savic because he protected you.  Tell me, is that correct?  Did he

13     protect you; and, if so, what did he protect you from, or who did he

14     protect you from?

15        A.   That's not true.  I was not in jeopardy at all so that he would

16     have to protect me.  Not politically, not physically.  Well, physically,

17     certainly not.  But, now, what was in his head, I cannot testify about

18     that.

19        Q.   The way I understand his statement, later on, he appointed you

20     president of the SDS Board.  Well, I mean, I don't want to infer anything

21     here, but does this correspond to the truth?

22        A.   Well, we've already talked about this, and I've already said that

23     that is not correct, that this is absolutely crazy.

24        Q.   Paragraph 80, in that paragraph, he says that he noticed that you

25     were hiding something, and he noticed that you were trying to distance

Page 9393

 1     yourself from him.  Tell me, was there a growing distance between the two

 2     of you after those events in Plitvice?

 3        A.   Sorry, I didn't hear the question because I was reading this.

 4     Could you repeat that?

 5        Q.   My question is the following:  He noticed that you were hiding

 6     something and that you were trying to distance yourself from him.  So I'm

 7     asking you now whether this did, indeed, happen after those events in

 8     Plitvice?

 9        A.   That did not happen.  This has nothing to do with reality.

10        Q.   In the same paragraph, he speaks about some pistols, 50 pistols,

11     that you received.  You were supposed to distribute them to your

12     associates in February 1991.  And he learned about this from

13     Trifun Ivkovic.

14             First of all, tell me, please, is it correct that you received

15     some pistols in order to have them distributed to your associates?

16        A.   That is not correct.  It's not only that it's not correct, it is

17     totally insane.

18        Q.   I understand you think it is not correct, but why do you think it

19     is insane?

20        A.   Because, in the beginning of the war, when weapons had already

21     arrived in Slavonia and Baranja, when the army had distributed these

22     weapons, pistols were highly appreciated.  People would give two rifles

23     in order to get one pistol.  I heard about that from various people.

24     There weren't any pistols around.  They were in very high demand.  And

25     this never happened.  Nobody ever distributed pistols.

Page 9394

 1        Q.   Very well.  He says that he learned that from somebody called

 2     Trifun Ivkovic.  Do you know who that is?

 3        A.   Yes, I do.  I know Trifun very well.

 4        Q.   Could you please tell us briefly what you know about him.

 5        A.   Trifun Ivkovic appeared in Eastern Slavonia as a member of an

 6     organisation known as Solidarity.  I heard about them.  They carried out

 7     some activities before that in Kosovo and Metohija, that same

 8     organisation Solidarity.  Trifun appeared either on his own -- or,

 9     rather, always on his own and toured Serbian villages there.  He did not

10     do anything specific.  According to what I know, a bit later, not much

11     later, a bit later, he undermined our authority, the authority of us

12     Serbs in Slavonia and Baranja.  I can tell you how I learnt that if that

13     would be of any interest to anybody.

14        Q.   Yes, you may.  Go on.

15        A.   That's why this story seems like a well-known cliche.

16     Trivo Ivkovic was at a gas station in Backa Palanka, and he saw a car

17     with the registration plates of Vukovar.  He asked the driver where he

18     was from.  He learned that the guy was from Borovo Selo.  He asked him:

19     Well, how are things in Borovo Selo then?  And the guy says:  Well, not

20     bad.  And the guy says:  Do you have money?  And the other says:  No, we

21     don't.  And Trivo Ivkovic then tells him:  How come you don't have money?

22     I gave a million German marks to Goran Hadzic a couple of days ago and he

23     was supposed to distribute that money among your people in Borovo Selo.

24     In his mind, this man cursed my mother and he thought:  Well, Goran took

25     the money for himself, the money that he was supposed to distribute.  In

Page 9395

 1     that same second, he remembered to ask Trivo:  Where did you get the

 2     million German marks from, and here you're driving this old rackety car

 3     that is worth nothing?

 4             I heard that story perhaps a month after the event, by accident.

 5     So this is the method that Trivo Ivkovic applied in order to create a

 6     rift among the Serbian population.

 7        Q.   When you mention this name "Solidarity," was that an

 8     organisation, a political organisation, or an association?

 9        A.   I believe that it was an association, but I don't know much about

10     it.  I only heard that Trivo Ivkovic belonged to that organisation.  I

11     did not meet any other of its members.

12        Q.   And the Serbian Democratic Party did not have much contact with

13     that organisation, or did it?

14        A.   No, we did not have any contact with them at all, either official

15     or unofficial.  But now I see that Boro Savic had communicated with them,

16     but I didn't know about that at the time.

17        Q.   Can you please look at paragraph 81.  It says in this

18     paragraph that until the beginning of 1991, all the contacts of Slavonia,

19     Baranja, and Western Srem with Belgrade went through him, exclusively

20     through him, although he did not want to play that role.  Is that

21     correct?  Are you familiar with the fact that Savic was the exclusive

22     liaison officer with Belgrade, as it were?

23        A.   I did not know that anybody had contacts with Belgrade at all,

24     let alone that it was Boro Savic.  I hear it for the first time.  I

25     believe that this is not correct, although I don't know.

Page 9396

 1        Q.   If he did have contacts with Belgrade, did the Vukovar SDS Board

 2     know about those contacts?  Was it informed about that communication?

 3        A.   He never mentioned that at SDS meetings.  He never spoke to me

 4     about that in private or in his official capacity at meetings.  Thinking

 5     about that, I don't understand what capacity would that have been.  What

 6     capacity would he have had to have in order to advocate our interests, if

 7     he was not a spy.  He could not have a political role to play in that.

 8        Q.   In paragraph 82, he says that you spoke with the political

 9     leaders in Belgrade and that he noticed that.  He says that he should go

10     with you, but you responded that you went to Belgrade because you were

11     fascinated by Milosevic.  Did such a conversation between you and

12     yourself [as interpreted] ever happen?

13        A.   That conversation could have only happened in Boro Savic's

14     imagination.  We never spoke about Milosevic.  Belgrade was never a topic

15     of any of our meetings at the SDS.

16        Q.   And now I'm interested in paragraph 166.  But before that, we

17     can -- to try tie this in with paragraph 165 which will give us a bit of

18     a context.  Please read this paragraph.

19             My question is this:  Although he never claimed that you attended

20     that occasion but since you knew Boro Savic and you also knew

21     Zeljko Raznjatovic, Arkan, according to how you see things, could a

22     conversation of this kind have ever happened between the two of them?

23        A.   I listened to Boro Savic's testimony.  He categorically claimed

24     that that was on the 15th of May because he remembered that on that day

25     Soskocanin had drowned.  So this is a product of a sick mind.  This is

Page 9397

 1     simply impossible.

 2        Q.   Why do you think that this is simply impossible?

 3        A.   Because on the 15th of May, Arkan was in prison in Zagreb.

 4     Physically it was impossible.  Second of all, Boro Savic was not a

 5     political factor in Slavonia, Baranja, and Western Srem.  There was no

 6     need for anybody to discuss anything with him.  It's just his wishful

 7     thinking about what he would have said to people if he had an

 8     opportunity.  So he convinced himself that that had happened.  After

 9     Plitvice, Boro Savic had to be admitted for treatment.  He suffered from

10     ill health, mental ill health.  He been beaten badly at Plitvice.  Before

11     Plitvice he was a normal person, but after that, I -- I wish I could say

12     this in private session because I really feel embarrassed when I have to

13     say about somebody that he is insane, and I have been repeating this all

14     the time.

15        Q.   Let me ask you something else.  Perhaps my previous question was

16     not clear enough.  Since you knew Boro Savic and you also knew

17     Raznjatovic and you knew how people treated him and vice versa, according

18     to what you know, did Boro Savic have enough courage to address

19     Zeljko Raznjatovic in the way he describes it here, in view of the fact

20     that he knew who Raznjatovic was?

21        A.   When I was talking about the rally that was banned and when I

22     said that I was on the stage on my own, that nobody dared join me, Boro

23     was among those who didn't dare to join me.  He never spoke publicly.

24     You will remember that the Prosecution showed images from a rally, the --

25     when the SDS was being founded in Borovo Naselje.  I spoke, and I said

Page 9398

 1     that the Croats have to renounce their Ustasha legacy.  Boro Savic was

 2     there, and he is sitting in the last row.  He is hiding behind somebody's

 3     back.  He never spoke publicly or otherwise.  Nobody knew about him.  He

 4     did not have that kind of courage.  This could not have happened, but I

 5     suppose he just got confused, and it was all in his imagination.  He was

 6     delusional.

 7        Q.   Very well --

 8        A.   I apologise.  I would like to say something about the

 9     chequer-board flag.  We spoke about that before the break.

10             Boro Savic apparently had strong views about the chequer-board.

11     Why did he not appear before 10.000 Serbs and voice his position openly?

12     It's only with hindsight that he said it 20 years after the war, not even

13     publicly but semi-publicly.  All the deceptions, I -- I faced all of my

14     mistakes I made, I will share with everybody publicly.  I'm not trying to

15     shun my responsibility.  I'm not trying to say that I am shunning away

16     from my political responsibility.  But I will share all that with you

17     publicly.

18        Q.   Let's leave Mr. Savic aside, as well as his statement.

19             I would like us to go back to the situation in the

20     Serbian Democratic Party in early 1991.  Could you please tell us whether

21     there were political differences in the party when it came to the

22     implementation of the party policies in how to approach the Croatian

23     authorities and talk to them?

24        A.   There were major differences.  My joking comment, which was based

25     on the facts, was that the poorer the land was, the Serbs were more

Page 9399

 1     extremist, whereas us Serbs in the fertile plain were more peaceful and

 2     ready to talk.  The Serbs in Knin, around Knin, were radical, whereas the

 3     Serbs in Eastern Slavonia were a more peaceful and calm option.

 4             I would like to single out a person that at the beginning of the

 5     party's work was the most extremist of all, more extremist than Babic's

 6     extremism when it was at his peak.  And I'm talking about Veljko Dzakula.

 7     Veljko Dzakula was the most extremist Serb that I had ever met before the

 8     developments at Plitvice.

 9        Q.   When we're talking about political differences, could you please

10     tell us whether there were any factions, any groups within the SDS?  Was

11     there any kind of polarisation?  Was there an inner struggle within the

12     party?

13        A.   Roughly speaking, although it will not present the picture

14     clearly because there was not a clear-cut division, one wing was headed

15     by Raskovic, that was a peaceful wing, and the other was Babic's wing.

16     Those were the two different opposing streams:  Babic's on the one hand,

17     and Raskovic's on the other.

18        Q.   Can you please tell us, briefly, what did Raskovic's faction

19     advocate as opposed to Babic's faction?

20        A.   I belonged to Raskovic's faction so I can speak on my own behalf

21     and behalf of those people who were with me.  We were in favour of

22     negotiating with the Croats, in favour of living together, in favour of

23     dealing with matters peacefully.  And Babic accused of us of high

24     treason.  He wanted to see us hanged and arrested.  They were against us.

25     That was the gist of the matter.  There were nuances, of course, but they

Page 9400

 1     are not important at the moment.

 2        Q.   What did Babic's faction hold against Professor Raskovic?  You

 3     told us that Professor Raskovic was the party president.  What did Babic

 4     have against him, what did he hold against him?

 5        A.   That conflict escalated after Raskovic's visit to Zagreb, where

 6     he went to see Croatia's president, Mr. Tudjman.  He was then attacked by

 7     all the deputies from Knin and the environs, and they called him all

 8     sorts of names.  It was embarrassing to listen to that.  I was at that

 9     time in Knin at the meeting of the Main Board, and Boro Savic and I did

10     not interfere because it was their internal conflict.  They were

11     neighbours and friends who had known each other from before.

12             It's curious from my experience that all these people who

13     attacked Raskovic - or should I say almost everybody - who advocated war

14     and fighting Croats, almost all of them, when the war broke out, just ran

15     away, somewhere to western Europe; whereas we who had advocated peace and

16     negotiations stayed in the middle of that war.

17        Q.   You say Professor Raskovic had a hard time from his own people

18     because he had talked to Tudjman.  How did this meeting happen?  Was it

19     announced in advance or was it only reported later?  How did it happen?

20        A.   I can remember only vaguely because it was before the war and

21     before the events at Plitvice.  The Croatian side was also not quite fair

22     in this matter.  They did some wire-tapping and then they published the

23     transcripts in newspapers, and then Raskovic was attacked.  If the

24     Croatian side had not done that, and Raskovic had had a chance to explain

25     this to his own people when he came back, at their own meeting, it would

Page 9401

 1     have been different.  I believe that's the gist of the problem.

 2             It's the same thing they tried to do to me at the negotiations in

 3     Norway, but we'll come to that later.

 4        Q.   You mentioned Veljko Dzakula.  Can you tell us something about

 5     the incident in Pakrac?  Just briefly tell us what you know about it, how

 6     well-informed you were.

 7        A.   I did not have first-hand information, but I do have information

 8     that I believe is 99 per cent accurate.

 9             I heard from people, including from Boro Savic, what exactly had

10     happened because he had closer relations with that board from Western

11     Slavonia.  Everybody was angry with Veljko Dzakula at the time because

12     Veljko Dzakula, off his own bat, agreed with somebody in Belgrade - at

13     least that was the story which later turned out to be not true - so he

14     agreed with somebody in Belgrade that they attack the Croatian police

15     somewhere in Pakrac and as soon as the shooting begins, the army would

16     come and interpose itself between them.  However, that didn't happen.

17     Serbs started shooting.  The Croatian police returned fire and arrested

18     them, and the army never showed up.  So Veljko Dzakula lied about that.

19     That's one of the reasons why we, the delegation of the SDS from SBWS

20     went to the president of Croatia to ask for amnesty for them, and after

21     this incident, Veljko Dzakula reversed his policy completely.

22        Q.   Before these events at Pakrac, did you know that something would

23     happen there?  How did you find out, if you remember?

24        A.   I remember well.  I don't remember the exact date, but I remember

25     we had a meeting of the Executive Board on that day in a place called

Page 9402

 1     Dvor on the Una river.  And I'm sure that not a single member of the

 2     Executive Board, which included representatives from Municipal Boards,

 3     knew that it would happen.  Because I know that the representative of the

 4     party from Podravska Slatina had prepared a brief on how to promote the

 5     work of the SDS.  That item was on the agenda when he was speaking.  And,

 6     at that moment, I heard from people who were not members of the

 7     Executive Board, who were standing outside near the hotel where the

 8     meeting was being held, we heard from them that the Croatian police had

 9     attacked Pakrac.  That came as a shock to all of us.  The meeting of the

10     Executive Board was interrupted, and Boro and I returned to Slavonia

11     because we were expecting that roads would soon be blocked.  We didn't

12     know what would happen.

13        Q.   You answered a moment ago that it was over Pakrac that you met

14     with Croatia's president, Tudjman?

15        A.   Yes, but I didn't know it was about Pakrac.  I later learned that

16     it was about other things, too, but including Pakrac.

17             MR. ZIVANOVIC:  May we have, please, 1D72.

18        Q.   [Interpretation] This is in English, but I believe you had

19     occasion to read it before in translation.

20             If you look at the top, you will see the date, 13 March 1991.

21     Zagreb, it's also written in the text.

22             Is it possible that this report is precisely about that meeting

23     you had with Tudjman?

24        A.   Yes, I believe so.  I believe it was the right date.

25        Q.   In the first paragraph, the people who attended this meeting were

Page 9403

 1     listed, the members of the delegation of the Serbian Democratic Party.

 2     You can see five names, including yours.  Were these the people who

 3     attended the meeting to the best of your recollection?

 4        A.   Yes.  But there is a typo here.  It says "Vojislav Vikcevic" and

 5     it should be "Vukcevic."

 6        Q.   Can you tell us from which constituencies, from which Municipal

 7     Boards these members of the delegation were?

 8        A.   Vojo Vukcevic was from Beli Manastir.  I from Vukovar, as you

 9     know.  Veljko Dzakula was from Pakrac.  I believe Ilija Sasic and

10     Dusan Ecimovic were also from Western Slavonia but I don't know exactly

11     which boards because they were not chairmen of their boards.  They were

12     elected into the Regional Board based on their political work.

13        Q.   I note that there is nobody from the Knin Krajina.  Was there a

14     particular reason for this?

15        A.   From talking to Sasic and Dzakula, as far as I was able to

16     understand, either they hadn't dared to ask anybody or everybody refused.

17     That's why the delegation is made up in this way.

18        Q.   Can you now tell us to the best of your recollection what

19     happened at that meeting.

20        A.   We had one meeting at Tudjman's office and we were also received

21     at the Croatian parliament where our host was Slavko Degoricija, and I

22     remember we had certain political demands.  And I learned at that

23     meeting, in addition to what I've already described, that Dzakula was

24     asking that those arrested in Pakrac be amnestied and that was, indeed,

25     done.  All the rest that we were promised was never done, and I can tell

Page 9404

 1     you later, if you wish, more about our demands.

 2        Q.   Yes, tell us.  What did you ask for?

 3        A.   First of all, we complained.  We asked that the parliament change

 4     the constitution in such a way as to make Serbs again a constituent

 5     nation as we had been for 50 years before.  It was a broader political

 6     issue, and we were aware that this was a kind of maximum goal, that it

 7     was not perhaps feasible, but we did ask for something realistic and

 8     possible.  And if we had received that little, the people would probably

 9     not have mobilised to wage war.

10             The lower request was for cultural autonomy, a little bit of

11     autonomy, although perhaps "autonomy" is too big a word.  At that time,

12     in the beginning of 1991, Serbs did not have any national iconography of

13     their own.  There were no newspapers in Cyrillic.  There were no

14     particular programmes on Croatian TV for Serbs.  There would be perhaps a

15     30-minute TV show for Serbian people per week, or maybe a special class

16     for Serbian children once a week, an hour per week.  It now exists

17     everywhere in the European Union.  It was nothing special.

18             I remember one of them said that Serbs, before the war, had asked

19     for much less than we were prepared to give, but that we didn't do.  We

20     didn't do -- ask for much.  We asked for the constitution, the

21     chequer-board, and the lowest possible level of cultural autonomy.  And I

22     must admit - it would not be fair to omit this - that we were received

23     very nicely, both by the Croatian president and the Croatian parliament.

24     That is the truth.

25        Q.   Speaking of the chequer-board emblem, what did you ask for

Page 9405

 1     specifically?

 2        A.   First of all, among our people it was a deep-seated, accepted

 3     opinion that the chequer-board emblem, if worn on the cap of the police,

 4     for instance, is a symbol of the Ustasha state, so we asked for that

 5     emblem to be either replaced or to be modified so as to avoid the white

 6     field in the top left corner.

 7        Q.   What did Tudjman reply to that, if you remember?

 8        A.   I remember perfectly well.  I remember almost every second of

 9     that conversation.  And, again, I have to be fair.  Tudjman was very

10     frank with us.  He said that he has the same opinion of Ustashas as we

11     do.  At first, I thought he was not sincere, but later I realised he was.

12     He said:  Perhaps the Ustashas killed some of your ancestors during the

13     war.  They did kill my grandfather.  But Tudjman says:  They killed my

14     own brother.  And he said it wouldn't be a problem to accommodate us, but

15     he has a problem with his own right wing in his own government.  He

16     didn't name any names, and I don't want to give you my interpretation of

17     what I think he was thinking.

18             MR. ZIVANOVIC:  Your Honours, I would tender this document into

19     evidence.

20             JUDGE DELVOIE:  Admitted and marked.

21             THE REGISTRAR:  As Exhibit D111.

22             JUDGE DELVOIE:  Thank you.

23             MR. ZIVANOVIC: [Interpretation]

24        Q.   Mr. Hadzic, when and why were you supposed to go to Obrovac for a

25     meeting in March 1991?

Page 9406

 1        A.   When I think back about what we discussed a moment earlier, the

 2     statement of Boro Savic, when he talked about the complement of the party

 3     and the crisis in August 1990, I believe he was mistaken.  The real

 4     crisis occurred in March 1991.  That was the time when open

 5     confrontations broke out within the Serbian Democratic Party.  In one

 6     camp were Jovan Raskovic and almost the entire board of Slavonia and

 7     Baranja and a small number of people from Knin, and in the other camp,

 8     Babic's people from Knin and the surrounding municipalities.

 9             I was quite fed up with it by that time, if not disgusted, and I

10     was quite hesitant about whether to go to that meeting at all.  Perhaps I

11     should say why.

12             My appointment as president of the Municipal Board in a political

13     party, I consider that to be a democratic thing, although it was just in

14     a political party.  I thought that I should do my best.  I established

15     each and every local board.  Every day I went to different villages,

16     sometimes to two villages per day.  I had meetings with people.  I told

17     them about the programme of work of the party, and I enrolled new

18     members.

19             Every time I went to Knin for meetings of the Main Board and

20     later on to Pakrac when the regional committee was formed for Slavonia

21     and Baranja, before that, I would convene a meeting of the

22     Municipal Board in Vukovar, that is to say, a day earlier or sometimes

23     even two or three days earlier.  We would make a plan.  We would adopt

24     positions, we would vote on these positions.  And I went to Knin to

25     attend the Main Board with firm positions of the Main Board.  My entire

Page 9407

 1     board was behind me.  Immediately upon my return, on the next day or the

 2     day after that I would convene a meeting of my Municipal Board and I

 3     would bring the positions of the Main Board and we would discuss that.

 4     That's how it went.

 5             When I saw how this Main Board in Knin operated, I realised that

 6     practically all members - except for me - they present their own views

 7     only.  Except for me.  And they quarrelled, and it was their own personal

 8     squabbles, and so on and so forth, and I got sick of all of that and

 9     that's why I didn't feel like going there at all.

10             MR. ZIVANOVIC:  Mr. President, I think it's time for the break.

11     Thank you.

12             JUDGE DELVOIE:  Thank you very much.

13             Court adjourned.

14                           --- Recess taken at 12.14 p.m.

15                           --- On resuming at 12.46 p.m.

16                           [Trial Chamber and Registrar confer]

17             JUDGE DELVOIE:  Mr. Zivanovic, please proceed.

18             MR. ZIVANOVIC:  Thank you, Mr. President.

19        Q.   [Interpretation] Before the break, Mr. Hadzic, you said that you

20     did not want to go to attend this meeting of the SDS in Obrovac, and you

21     explained the reasons.

22             Can you tell us now what the reason was for you to decide to go

23     there after all?

24        A.   I don't have the image here on the transcript.  Can they fix

25     this?  I cannot follow that cursor, you know?

Page 9408

 1             JUDGE DELVOIE:  That's very smart of you, Mr. Hadzic, to follow

 2     the cursor to know when the interpretation is finished.  Thank you.

 3             THE WITNESS: [Interpretation] Well, a day or two before that

 4     meeting, I think it was two days before that meeting in Obrovac, they

 5     called me.  They asked me to come to the Croatian police in Vinkovci.  A

 6     friend of mine from before the war asked me to come there, and he worked

 7     at the State Security of Croatia.  Ivan Zalezak [phoen] is his name.

 8     Ivan Zalezak.  We hadn't seen each other in a long time because when I

 9     went into politics, we stopped all contact.  And he asked me whether I

10     would stop by and see him.  I didn't know why he asked me to come.  I

11     agreed, but I did say to some of my friends that they were asking me to

12     come and that they know where I am, so if I would not be back for a long

13     time, they should know where I was.  At that time, I was president of the

14     SDS for Vukovar, so I thought that they should know, if I wouldn't show

15     up in a while.

16             Let me try to cut this short.  Ivan met me in front of the

17     Vinkovci SUP, and together with his boss, who had just been appointed,

18     whom I had not known personally but I had heard of him because I was good

19     friends with most of these employees there, of the State security Service

20     in Vinkovci.  His boss was Vlado Pletikosic.  We went to a restaurant by

21     the Bosut river, in town.  We went for a working lunch, as they called

22     it.  I saw that the restaurant had been prepared, that it had been

23     emptied.  There weren't any other guests there, so that's where this

24     meeting was held.

25             The first thing they asked me, as soon as we sat down, so that we

Page 9409

 1     could go on talking, they asked me whether I was in favour of the war

 2     option or the peace option.  Of course, I said that was in favour of the

 3     peace option.  Well, they said, if you're in favour of the peace option,

 4     then are you going to go to attend the SDS meeting in Obrovac?  I said

 5     that I hadn't planned to go for a variety of reasons, and I explained

 6     that a bit.  I explained what the main reasons were.  Of course, I did

 7     not tell them what that reason was because they really should not be

 8     interested in that.

 9             So then they asked that for their sake, in order to prevent a

10     possible war, that I go to Obrovac to the meeting and support

11     Professor Raskovic's stream.  That was not a special problem for me

12     because I supported that stream anyway.  It wasn't any different from my

13     own way of thinking, so I agreed to go to this meeting.  And that's why I

14     went to Obrovac.  Because I had promised them that I would go and support

15     the peace option so that war would not break out.

16             Then I called Boro Savic, I said that we would go together, and I

17     did not tell him that I had had this meeting because there was no need

18     for me to tell him.

19        Q.   Can you tell us from when you knew this man called Zalezak.

20        A.   Well, I knew him from, say, five or six years before the war, so

21     that would be the mid-1980s.

22             As for this state security of theirs in Vinkovci, there were

23     three employees there who were from Vukovar and their headquarters were

24     in Vinkovci.  So often when they would return to Vukovar they would stop

25     by to see me in Pacetin and then we played pool there, at the local cafe.

Page 9410

 1     At the time, we were all members of the League of Communists because

 2     their boss -- I mean, before Pletikosic was Stipo Brajcic.

 3     Stipo Brajcic, when I was president of the youth organisation in Pacetin,

 4     he was the president of the youth organisation for the municipality of

 5     Vukovar, so I knew him from these youth activities.

 6        Q.   You said that he was their boss before?

 7        A.   Vlado Pletikosic, before Vlado Pletikosic, the one that I've

 8     already mentioned.  Vlado Pletikosic.

 9             I also knew Darko Bekic.  We were very good friends.  Before all

10     of them.  He was the third person from Vukovar.  Darko Bekic, not Bjekic,

11     Bekic.

12        Q.   So you went to the meeting in Obrovac.  So how did this meeting

13     go?  What happened there?

14        A.   I kept my own record in my notebook.  Unfortunately, the police,

15     the Croatian police, took this away from me so I don't have it with me

16     now.  But the meeting had a few items on the agenda.  I think four or

17     five.  Among other things, we were supposed to elect Dr. Vojo Vukcevic

18     president of the Executive Board because Slavonia and Baranja were not

19     adequately represented in the top echelons of the party.  All the highest

20     positions were in Knin.  However, there was that quarrel there, precisely

21     with regard to this option of Professor Raskovic's in favour of

22     negotiating with Croatia and then the Babic option on the other side.

23             I remember after the meeting, some policeman, some plain-clothes

24     policeman.  To this day, I don't know who he is, what his name is, he

25     tried to interrogate us.  A Serb policeman of the SAO Krajina.  And he

Page 9411

 1     almost threatened us because of these political views of ours.  I think

 2     that he talked to Boro Savic and Vojo Vukcevic.  However, I managed to

 3     avoid them and evade that conversation.

 4             Since the meeting ended before dark, the sun was still high up,

 5     since Obrovac is close to the sea and the climate is therefore almost

 6     Mediterranean, Boro and I decided not spend the night in Obrovac.  We

 7     tried to cover as many kilometres as possible in the direction of Zagreb.

 8        Q.   Before you go on, can I just ask you something else.  Were any

 9     decisions made at that meeting?  Do you remember, I mean?

10        A.   I don't remember these decisions.  Something had to do with

11     Professor Vukcevic, but I cannot remember now.

12        Q.   You can go on now.  I interrupted you.  You were speaking about

13     your departure from Obrovac when you went towards Zagreb.

14        A.   Since we travelled all night, we hadn't slept during the previous

15     night, and then the meeting went on all day, we realised that we had to

16     spend the night somewhere before Zagreb.  We were planning on the Borje

17     motel which is just before Titova Korenica.  But when we got there we

18     were taken by surprise.  Although this is a big building, a big motel,

19     they did not have any rooms.  They just had a restaurant.  And they said

20     that the hotel in Plitvice is the closest to there.  Since this is

21     already a mountainous area, although it was the end of March, there was

22     snow there.  We stopped at Plitvice, had dinner there, and we went to

23     sleep.

24             And then, in the morning, we were awakened by automatic gun-fire

25     and we heard this megaphone.  We heard the Croatian police speaking

Page 9412

 1     through a megaphone:  This is the Croatian state.  This is the Croatian

 2     regular police.  Law and order has been established.  Nobody is going to

 3     have any problems, and so on.  That is what I personally heard from the

 4     room while Boro Savic was taking a shower.  This is a kind of tragic

 5     anecdote what he said.  He -- I asked him why he was taking a shower, and

 6     he said:  I want to die clean.

 7             It was Easter, both Catholic and Orthodox Easter on that day.  We

 8     came down to the restaurant.  There were a lot of tourists, especially

 9     Italian tourists.  There were two busloads of Italian tourists there.

10     And in the hotel there was no tell-tale signs that an incident happened.

11     Everybody behaved normally, both waiters and tourists.  Everybody had

12     their breakfast.

13             Boro went to the reception and inquired about the situation.

14     When he returned, he told me that the people at the front desk told him

15     that the road to Zagreb was passable, that the Croatian authorities had

16     established order, and that a busload of Italian tourists had already

17     gone to Zagreb.  I said we had better stay in the hotel and see what

18     would happen.  Boro said:  No, let's better leave.  There's nothing for

19     us to do here.

20             As soon as we got in the car, it was cold.  Boro took off his

21     jacket.  He drove.  It was his car.  I kept my short coat on, and somehow

22     it saved me because Boro had only a shirt on, and as soon as we left in

23     the parking, the police came from behind a house.  They jumped out with

24     automatic rifles.  Obviously we got out of the car.  We put our hands on

25     the car.  They came to search us.  Other people came to search us while

Page 9413

 1     we were held at gunpoint by the first group.

 2             I had a pistol for which I had a licence to carry from the

 3     Croatian police.  I had it at my belt.  And one of the policemen said:

 4     This man here, he has a pistol.  I said:  But also I have -- I have a

 5     licence to carry it.  He told me:  Can I see the licence?  I took out my

 6     wallet to show him the licence.  However, in the wallet I also had a

 7     booklet, a membership booklet of the Serbian Democratic Party, and he saw

 8     that as well.  He no longer wanted to see my licence to carry a pistol.

 9     He just shouted:  Look, these are Chetniks.  We have captured some

10     Chetniks.

11             That was before the war.  Before the war even started - I'd like

12     to emphasise that - the Serbian Democratic Party was a regular party in

13     the Croatian parliament.

14             They took us to the road.  I was taken by surprise when I saw

15     police vehicles, jeeps, and police officers squatting with automatic

16     rifles, four of them, by each of the vehicles.  So the action was still

17     ongoing, it was not over as we were told at the hotel reception.

18             When we appeared, they all rose.  They lifted their rifles.  They

19     were going to beat us with rifle-butts.  I was the first, and the one who

20     was leading me told them:  Don't beat them.  We have to check, but it

21     seems that they are hotel guests.  The one who wanted to hit me with the

22     rifle lowered his rifle.  Boro came after me, and he didn't hear what was

23     said before.  Boro was immediately hit a metal rifle-butt and from then

24     on, Boro was semi-conscious.  He was beaten, and he no longer knew what

25     was going on.

Page 9414

 1             I see when Boro had been hit, but it was only when we arrived at

 2     the police station in Karlovac did I see that his jaw was broken.  I

 3     didn't realise before that -- then that he had been so heavily beaten.

 4             On the road, our hands were tied behind our backs and they

 5     ordered us to lay on the road covered with snow, and nobody had started

 6     beating us after Boro had been hit -- had been hit once.  And then the

 7     man who had taken away my gun ran up to me with my pistol and he started

 8     shouting:  Here's the pistol, but, look, he had fired shots from this

 9     pistol.  He had fired shots.  The pistol is still dirty.  My -- my pistol

10     was never fired, but I had kept it around my belt for such a long time

11     that it got dirty from the woollen clothes.  And as I was lying down, he

12     used my pistol to hit me in my head and he broke my skull in two places.

13     He hit me as hard as he could.  He also kicked me in his boot shot leg

14     [as interpreted].  In karate, this kick is called yoko-geri-kekomi.  He

15     hit me in the left kidney and injured it.  After that, I peed blood for

16     two months.

17             And then an ambulance arrived and a vehicle with a Croatian TV

18     crew arrived.  I recognised a man, he was either a doctor or a paramedic

19     from Vukovar.  I was happy to see him because I thought that he would

20     explain the misunderstanding.  He, however, looked at me with spite in

21     his eyes.  He almost spat at me.

22             The TV crew came with a camera and then the police came with

23     the -- the key for the handcuffs.  They unlocked the handcuffs, and then

24     just for the camera, they went over the whole procedure again.  They told

25     us:  Hands up, and they arrested us again for the TV.  When the TV crew

Page 9415

 1     recorded that, they left, and then they tied our hands behind our backs

 2     again and they started beating us, but they were not hitting us with

 3     rifles or any other implements.  They just kicked us and beat us with

 4     their hands.

 5             They continued doing that for some ten minutes or so, and all

 6     that time, we were shouting:  People, we are hotel guests.  They did not

 7     pay heed to that.  And then one of them - probably their boss - said:

 8     Ah, you're hotel guests.  We're going to return you to the hotel.  That

 9     was a mistake because they took us to another group, to barricades, some

10     kilometre or 2 kilometres away from that place.  There were about 30 or

11     40 police officers there.  And now the second group didn't know anything

12     about that being a possible mistake.  They thought this we must be

13     Chetniks and must be guilty of a crime.  So we were handed over by the

14     first group to the second group, and the latter group continued beating

15     us.  All that time our hands were tied behind our backs.

16             And then they took us to the third barricade in a police vehicle,

17     in a Puch jeep.  Boro and I were sitting in the back and there were two

18     police officers in front of us and there were two police officers on each

19     of our sides.  Then one of them took my chin in his hands.  He took a

20     knife and said:  Now I'm going to slit his throat.  And then the

21     co-driver said:  Don't slit his throat now.  There'll be blood all over

22     the upholstery in the car.  Wait until we stop.

23             I started praying to God that we never stop because I really

24     thought that they would slit my throat.  And when we stopped, I realised

25     that we stopped by a third barricade where -- manned by some 20 or 30

Page 9416

 1     police officers, so I thought maybe they wouldn't slit my throat in front

 2     of them.  Then they threw us out of the car and they said to the third

 3     group:  Here they are.  You do whatever you want with them.  And the

 4     third group also beat us, continued beating us.  Our hands were tied all

 5     that time.

 6             When all that was over, the third round of beating, that is, they

 7     forced us to get into a police van without any seats.  There was just a

 8     floor.  And then two police officers entered.  They did not wear

 9     camouflage uniforms, but, rather, blue, regular police uniforms.  They

10     had two huge batons, the kind that I'd never seen before.  Boro and I

11     were still tied and there were two men, and these two men were beating us

12     for some ten minutes in that vehicle, from head to toe.  They injured my

13     leg muscle so badly that I couldn't stand without cramps.  I still get

14     cramps in my both legs when I stand longer.  And that was the end of the

15     physical ill-treatment.

16             Then they transferred us to another vehicle, a Citroen van,

17     similar to the previous one, and they took us into a forest.  They

18     undressed us.  They opened the windows.  We were almost naked.  And they

19     told us:  If there are shots we'll come and shoot you, so don't move.  We

20     were there in the vehicle, and the Croatian civilians who lived there

21     came up to us and they -- they were saying:  Let us gouge his eyes and I

22     will sell them and make money on that.  I was afraid all the time that

23     somebody would really come and slit my throat or torture me.  And then

24     they took us to the police station in Karlovac, and that's when the

25     ill-treatment finally stopped.

Page 9417

 1             While they were beating us, at first I thought I could reason

 2     with them and that I could explain.  I was shouting:  People, we're not

 3     guilty of anything.  I just went to see Tudjman as a member of a

 4     delegation in Zagreb.  I thought that that would help.  And one of them

 5     said:  If Tudjman received you, he will be beaten too.  So it was funny

 6     and sad at the same time.

 7             And I would like to say one more thing.  While I was being

 8     beaten, all that time I didn't feel any pain.  I suppose that my

 9     adrenaline was very high, and I only started feeling pain when all the

10     beating stopped.  I suppose that I was afraid for my own life, and that

11     was the first time that I was ever hit or beaten.

12        Q.   When you arrived Karlovac and later, did anybody tell you why

13     things were done to you?  Were you interrogated?  Did somebody explain to

14     you why you had been brought in?

15        A.   As I've already told you, the physical ill-treatment stopped in

16     Karlovac.  There were public security inspectors there who received us.

17     They offered us water.  I don't drink coffee but Boro may have been

18     offered some coffee.  And they told us that that was a misunderstanding,

19     a mistake.  They apologised.  And we thought that they really meant it.

20     Boro and I even suggested that they should take us back so that he could

21     take his car.  It was a Golf car, relatively new.  It was worth a lot of

22     money.  At that time it was very hard to buy a Golf car like that.  And

23     they said:  Don't worry, we will bring the car over.  And we believed

24     them.

25             And then we had an interview with two State Security Service

Page 9418

 1     inspectors.  They also apologised to us and they told us that we would be

 2     released.  However, something happened.  I don't know what.  Only later

 3     did I realise that a political decision had been reached, and that we

 4     were to be put together with the others who had been arrested.  I didn't

 5     know at that time that some 15 other Serbs from Plitvice had been

 6     arrested at the same time.  Of us 15 or 16, only one wore a Krajina

 7     police uniform.  Only one of them was a participant in the events.  All

 8     the rest were civilians.  Most of them were in slippers and it was

 9     snowing, which means that all these people had been arrested in their

10     homes.  They had all been badly beaten.

11             When I saw one of them, his mouth, his left side of his mouth,

12     and it was funny and sad at the same time when I saw him -- when I saw

13     him, and they kept us all in -- in a gym and later that evening we were

14     taken to Zagreb.  First to the prison hospital.  I was examined by a

15     doctor, actually, all of us were.  I was the last one to be checked.  The

16     rest left, and the duty officer who had brought us in asked the doctor:

17     How many have to stay in the hospital and how many will go to the prison

18     in Simunska Street?

19             It was only then that I realised, when I heard him say that and

20     when I heard the doctor's response, what my position was.  The Dr. told

21     him:  Are you normal?  They are not even for the hospital, they are for a

22     morgue.  And all the 15 or 16 of them have to be hospitalised and

23     assisted by doctors.  That's how badly they are all beaten.

24             So we were taken to various hospital rooms.  We -- we were not

25     allowed to share, any of us, the same room although I only knew Boro,

Page 9419

 1     nobody else.

 2             The following day, Degoricija came to visit us.  He greeted us,

 3     even kissed us as if we were the closest of kins.  And he told us that

 4     that was nothing more but a tragic mistake.  After that, on the following

 5     day, on the way to the toilet, a patient from another room who was free

 6     to walk around gave me a newspaper article to read.  When I was in the

 7     toilet, I read the newspaper article and I believe that the newspaper was

 8     Vjesnik.  After having visited us, Degoricija gave a statement and said:

 9     I visited Hadzic in the hospital.  He was crying on my shoulder and he

10     admitted that he had opened fire on Croats and he is sorry.  This was

11     even worse than any of the beating and the fear that I would be killed

12     because I realised that that was the end of the world, that there was

13     nobody I could talk to and explain things to, that there was no

14     institution that I could go to, to explain things.

15             And then the next day, Boljkovac and Degoricija came.  They said

16     that Boro and I should write statements, separate statements, and they

17     would release us.  We got ready.  We packed.  I went to the same

18     admission room where I had left my things, and I saw a newspaper on the

19     desk of the policeman on duty and a large headline said:  Chetnik hordes

20     from Serbia came to Borovo Selo.  And then I concluded that they were

21     releasing me not because they really wanted to but because something was

22     going on there that didn't suit them.  So we went in two cars to Vukovar,

23     Boljkovac and Degoricija were in the car ahead.

24        Q.   Did you know, did you get any notification in the days following

25     that meeting that there was any fighting around?

Page 9420

 1        A.   No, there was no fighting.  We didn't hear about anything.  If

 2     there was any talk, it was in the other camp.  We, in the Raskovic camp,

 3     didn't know anything about it.

 4             When we arrived at Plitvice after dinner, our waiter approached

 5     us, saying that there was talk about the Croatian police possibly coming

 6     to Plitvice, but I didn't think I had anything to be afraid of.  There

 7     was Croatian police in Zagreb as well.  Why shouldn't they be in

 8     Plitvice?  I had no reason to fear them.

 9             But I remember the waiter said:  They're not crazy after all, you

10     know, it's Easter for them too.  They would not make trouble on Easter

11     day.

12        Q.   What happened with that pistol that you had, the licence to carry

13     a fire-arm, all the documents that you had on you?

14        A.   All my documents were stolen.  When I say "stolen," they just

15     took them away from me, but it was pure theft because only the regular

16     police had to do -- only the regular police had the right to do that.  So

17     they took everything I had, including some cheques that I was supposed --

18     for costs that I was hoping to get reimbursement for from -- from the

19     SDS, and I was thinking that maybe if I get to Zagreb, they would be

20     returned to me.

21        Q.   Could you again enumerate all the documents that were taken away

22     from you.

23        A.   My ID and my driving licence that was in my wallet and the SDS

24     membership booklet and all the documents I had in my wallet.

25        Q.   You say a few days later they took you back.  They took you back

Page 9421

 1     in their own vehicle.

 2        A.   Yes, it was a car of the State Security of Croatia.

 3        Q.   Do you know if Savic got back his Volkswagen Golf?

 4        A.   They returned it to him later, but it was shot at.  It had holes

 5     from rifle bullets.  That was done on purpose.  But they did not pay him

 6     any damages, as far as I know.  Although, after this, I don't believe a

 7     single word he says.  But he said at the time that he never received any

 8     damages.

 9        Q.   Where exactly did they take you?

10        A.   They drove us to the Municipal Assembly of Vukovar.  We didn't

11     even know at the time that the -- the Assembly was in permanent session

12     and they didn't want to disband until we show up.  I wanted to go up, but

13     Degoricija said:  No need.  Go and have some rest.  What he actually

14     didn't want to happen is that people should see us with the traces of

15     beating on our faces.  In the hospital, we received some treatment but it

16     was still visible.

17             But then you a saw a group of my former schoolmates, Croats, who

18     were standing on the other side of the street, across from the Assembly.

19     I was just feeling happy I was alive at that moment and I waved at them

20     in greeting, but nobody responded.  I learned later they had come to

21     protest against the fact that we were released.  I still wonder do they

22     really think, did they really think, that we should go to prison?

23     Because at that time we were completely innocent.  We had done nothing

24     wrong.

25             Anyway, soon afterwards, I learned why they were standing there.

Page 9422

 1     And I also learned later they were members of the HDZ, but that doesn't

 2     matter.

 3        Q.   After your release from jail, can you remember, did you continue

 4     with your political activity as a member of the Assembly of Vukovar, for

 5     instance?

 6        A.   I continued with what I believed was normal activity at the time.

 7     I was not even aware of my real physical and mental condition.  Only

 8     later when I saw medical reports, including the findings of a

 9     psychiatrist I had spoken to, I realised I was in big trouble.  But the

10     very first evening after being released, I went to Borovo Selo.  We held

11     a meeting there, and I said:  We don't need roadblocks anymore, now that

12     Boro and I were released.  That was maybe on the following day, but I

13     believe it was the same evening.  In those other villages, the roadblocks

14     or barricades were removed immediately, and in Borovo Selo on the next

15     day, perhaps.

16        Q.   Can you just tell me, how did you find out about roadblocks in

17     the first place?  Did you go to Borovo Selo or did you go to your own

18     home and call them?

19        A.   When I arrived in that car of the MUP of Croatia, we were unable

20     to go through Brsadin village, which is a Serbian village, but people

21     recognised me.  I told them to remove the barricades.

22             My village is on a side road, not the main road, and I saw the

23     barricades and the roadblocks, and I couldn't fathom why this was

24     happening.  I thought it was all leading to a conflict that was

25     completely unnecessary, and I thought that neither Boro Savic nor I had

Page 9423

 1     done anything over which people should go into a conflict, so I continued

 2     with my normal work the very following day.  I cannot now say with exact

 3     chronology what happened when, whether it was on the first, second, or

 4     third day, but at any rate, the roadblocks were removed in Borovo Selo

 5     after we were released.  And I believe Veljko Dzakula and Ilija Sasic

 6     were there in Borovo Selo too.  Although I'm not quite sure.

 7        Q.   When you told people in Borovo Selo that they should remove the

 8     roadblocks, was it your own decision, something that you arrived at on

 9     your own, or was it a demand put to you by the Croatian side?

10        A.   The barricades had been set up because of me, practically.  And I

11     thought that since I had come back, they were no longer needed, but that

12     was also in keeping with the agreement I made before travelling to

13     Obrovac that we should work to normalise the relations between Serbs and

14     Croats.  And generally speaking, I have always been against barricades.

15     And those later barricades that were set up because of the attacks at

16     Borovo Selo in August, it was Degoricija who asked me to remove them.

17             THE INTERPRETER:  Witness's correction.

18             THE WITNESS: [Interpretation] It is not "attacks at Borovo Selo

19     in August."  It is attacks in Borovo Selo with a type of mortar called

20     Armbrust, A-r-m-b-r-u-s-t.  [In English] Yes.

21             MR. ZIVANOVIC: [Interpretation]

22        Q.   When you got into touch with people from Borovo Selo after you

23     were released, did they tell you what had happened while you were in

24     jail?  Was there any unrest or something like that?

25        A.   They told me everything, but I can't really recall it all now

Page 9424

 1     because I was still in a state of shock after the beatings.  I know

 2     Vukasin Soskocanin was in negotiations with the Croatian police, with

 3     Zagreb, demanding our release.

 4             MR. ZIVANOVIC:  May we see, please, P1778.

 5        Q.   [Interpretation] We see in this report that the Serbian National

 6     Council - I'm translating it differently than the translation we have.

 7     The translation says "Serbian National Alliance" but it is the original

 8     that is authoritative - called upon the Serbian people to refrain from

 9     any action.

10             Look through the text, please, and then we'll discuss it.

11             [In English] In English, it is under title:  "Serbs in Borovo

12     region form police force."  Is on the very bottom of the left side of the

13     screen.

14             [Interpretation] My question is:  Were you told that during your

15     absence while you were in prison about those 25 policemen who walked out

16     of their service?

17        A.   I heard then that 25 policemen had left the force, but I didn't

18     know at that time that it was connected to the incident and our arrest at

19     Plitvice.

20        Q.   After this event -- after this event, did you go to Zagreb for

21     any purpose?

22        A.   A couple of times I spoke to Mr. Degoricija on the phone.  I was

23     on good terms with him.  By that time, he was already chief of the

24     State Security of Croatia.  In fact, assistant minister for the

25     State Security.

Page 9425

 1             I complained that I did not have any documents, that they had

 2     taken money and documents away from me, everything.  And he said by way

 3     of a joke:  Why are you complaining?  I also said that I don't have a

 4     pistol either.  And he said:  What do you need a pistol for?  If you need

 5     it, we're going to give you a rifle.  That's what he told me on the

 6     phone, by way of a joke, of course.  And I didn't find that very funny.

 7     I asked him to try to find my things, and he called me about ten or 15

 8     days later and told me to come to Zagreb so that they could see what

 9     could be done, so that they could return this to me.

10             Since I had no documents at the time, I did not try to get new

11     ones.  I thought that they would return them to me.  I borrowed a car

12     from a friend from Vukovar and I asked my best friend to come along with

13     me to Zagreb.  And he had documents so that if the police would stop us,

14     then -- since I did my military service in Zagreb in the JNA, I knew

15     Zagreb well.  We went to the MUP directly to see Boljkovac.  He received

16     me immediately, jumping the queue.  Degoricija was waiting there as well,

17     and we started this comradely, friendly meeting, as if there were no

18     problems whatsoever.  I said:  Give me my money and my documents.  And

19     they said:  Oh, never mind that now.  If you can, try to speak to

20     Milan Babic and see whether he would remove barricades from the railroad

21     so that we could have trains running through Knin.  Although they were

22     aware of the relations within the SDS, I explained to them that Babic was

23     completely independent and that his political option was my complete

24     opposite and he would not really listen to what I had to say, but I did

25     promise to call him and tell him that.

Page 9426

 1             They said that it's not smart for us to quarrel, that I should

 2     influence Boro Savic, that Boro and I should withdraw the charges that we

 3     brought against Tudjman because of the mistreatment we had suffered in

 4     Plitvice on the hands of the Croatian police.  I said that on my own

 5     behalf I would withdraw these charges but I don't know, I cannot

 6     guarantee that Boro Savic would also drop his charges.  And they said:

 7     All right.  Now go to the centre of Zagreb, Zrinjevac, the prosecutor's

 8     office.  They gave me the name of some prosecutor - I've forgotten it by

 9     now - and report to him and he'll give you your things back.

10             I went there and this man returned only six bullets, the ones

11     that I had in the pocket of my jacket.  Nobody had searched me.  These

12     were reserve bullets for my pistol, and I didn't really need that.  He

13     said that the people who took away my documents and my pistol hid all of

14     that because they want to keep it as a trophy, and therefore they cannot

15     find any of it.  And after that, I just went back to Pacetin.  After

16     that, Degoricija continued to call me practically every day.

17        Q.   Could you just tell us what kind of charges did they want you and

18     Boro Savic to drop?

19        A.   Well, Boro Savic and I, a few days after our return from Zagreb,

20     went to Belgrade.  I went to the American embassy.  I had a meeting

21     there.  But before that, I went to see a group of lawyers together with

22     him and they agreed to represent us for free in our complaint against

23     Tudjman and the Croatian state.  Savo Andjelkovic and Mitar Lazovic were

24     their names.  Lazovic was old even at that time.  He was old even then.

25     We, or at least I at least, all the documents I had, the medical

Page 9427

 1     findings, actually, not the documents.  Medical findings.  That's what I

 2     handed over to the lawyers, and I don't have that now.  But it doesn't

 3     really matter, does it?

 4        Q.   So you were asked to come to Zagreb after the visit with these

 5     lawyers.  Or, actually, probably after charges were filed.

 6        A.   After the 15th of April.  As soon as they found out that we had

 7     filed charges, they said that that was not politically proper, what is

 8     Tudjman to be blamed for.  At that time, we did not know about this

 9     notion of command responsibility, what I am here for now.

10        Q.   You said after this contact with Boljkovac and Tudjman, there

11     were some other contacts too.  I mean, well, actually, now, were there

12     any contacts, and, if so, can you tell us with who from the Croatian

13     side?

14        A.   Well, from Degoricija there was constant contact.  So primarily

15     with Degoricija.  Maybe there were others, but I cannot recall right now.

16     I continued my contacts with the Croats in the municipality of Vukovar as

17     well.  In a way, well, perhaps it is inconceivable for me to say that

18     now, but I personally had good relations with the Croats in the

19     municipality of Vukovar.

20        Q.   Can you tell us now in relation to these contacts with

21     Degoricija, did he ask you for something, in the sense of certain

22     activity, political activities, that should be carried out?

23        A.   He didn't have to ask me for that because I supported the same

24     thing then, that barricades were not needed.  There's no reason for us to

25     wage war.  Officially what he asked for, and I've already said that, was

Page 9428

 1     to have the barricades removed, the ones that were set up in Borovo Selo

 2     yet again but for a different reason.  I remember that.  Because he was

 3     in constant contact with us and the members of the Regional Board of the

 4     SDS from Western Slavonia, Sasic and Dzakula.

 5        Q.   And do you remember perhaps in that period, in April 1991 --

 6     well, you said that there were contacts with people in the

 7     Municipal Assembly of Vukovar.  Do you remember whether any measures were

 8     taken there, in order to calm down the situation?

 9        A.   I cannot get this in the right chronological order now but

10     Degoricija often came to Vukovar and had meetings, both with us and joint

11     meetings.  We called this co-ordination of all political parties in the

12     municipality of Vukovar.  And I think at that moment both Boljkovac and

13     Degoricija were attending a meeting in the municipality of Vukovar, so

14     this could have been April.  But this meeting -- well, at least -- for at

15     least while I was there, that was a meeting with the Serbs, but I think

16     that before that they had a meeting with their own party.

17             I remember that Rade Leskovac was in that meeting and I remember

18     some parallel of his, or, rather, a digression when he said -- I'm going

19     to paraphrase now.  It would be strange for someone to walk around town

20     without any clothes on, but people should wonder why it is that way.  It

21     wouldn't be surprising if everybody did that.  It had to do with the

22     problem of the Serbs, and I remember that he wanted to draw this

23     parallel, and that's how I remember that he attended the meeting too.

24             MR. ZIVANOVIC:  May we see, please, 1D2191.

25        Q.   [Interpretation] This is one of the conclusions of the Presidency

Page 9429

 1     of the municipality of Vukovar on the 10th of April, 1991.

 2             Since you were a member of the Assembly of the municipality of

 3     Vukovar at the time, please do read this conclusion and let us see

 4     whether you remember when it was adopted, this conclusion.

 5        A.   Yes, I remember, and I see the date, the 10th of April.  Although

 6     it's a specific date.

 7        Q.   Can you tell us the following:  It says here that this decision

 8     was made by the Presidency of the municipality of Vukovar.  Who made up

 9     this Presidency?  What did that mean, "the Presidency of the municipality

10     of Vukovar"?

11        A.   Well, I'm a bit confused by this because, according to the

12     statute of the municipality, I think that that did not exist but I'm not

13     sure.  It could be some political group, something like that, of members

14     of the Assembly.

15        Q.   Were you present when this decision was being made, or did you

16     know about this decision at all, that it had been reached?

17        A.   Well, I cannot remember now with any precision, so I don't want

18     to be involved in any kind of guess-work.  I think it was when Boljkovac

19     and Degoricija were there, and, in a way, this would be acceptable,

20     invoking the peace option, if I saw all of this right.

21        Q.   Paragraph 2 is characteristic, where it says:

22             "We call upon all citizens, political parties and institutions of

23     the system to refrain from any activity that might aggravate what is

24     already an extremely difficult situation."

25        A.   Oh, what you read out is paragraph 3.

Page 9430

 1        Q.   In paragraph 2.  Yes, I was reading out number 2 and I see that

 2     there is something similar in paragraph 3.

 3        A.   Yes, yes, you're right.

 4        Q.   The essence of my question is whether you remember that the

 5     municipality of Vukovar, regardless of whether it's the Assembly itself

 6     or the Presidency or the president or anybody else, sent this kind of

 7     appeal to anyone?

 8        A.   I'm not sure that in the month of April the Assembly met - the

 9     full Assembly, that is - so it's the Presidency that had to decide

10     because the entire Assembly could not meet.  So I think it wasn't the

11     Assembly.

12             As for this notion of the Presidency, well, I'm not sure.  This

13     is basically the first time I'm coming across this.  It did not exist in

14     the political work of the municipality of Vukovar.

15        Q.   I see paragraph 4 of this document.  I see that all citizens of

16     the municipality of Vukovar are being called upon to mark the anniversary

17     of the liberation of Vukovar on the 12th of April in a solemn way.

18             Do you remember whether any such thing did take place on that

19     day?

20        A.   This is in vain.  It certainly didn't happen.  That was the day

21     of the liberation of Vukovar from fascism.  By then it was not really

22     being celebrated, in particular.  It was celebrated in Tito's day.

23             MR. ZIVANOVIC:  Mr. President, I have a new document, so -- I see

24     the clock.

25             JUDGE DELVOIE:  Yes, thank you, Mr. Zivanovic.

Page 9431

 1             MR. ZIVANOVIC:  Thanks.

 2             JUDGE DELVOIE:  We'll take the break.  Resume on Monday at 9.00.

 3             Mr. Hadzic, you know the drill, I suppose, about discussing your

 4     testimony with other people, which is not allowed, and you know our

 5     decision about contact with your Defence and, of course, you can't have

 6     contact with OTP.

 7             Court adjourned.

 8                            --- Whereupon the hearing adjourned at 1.58 p.m.,

 9                           to be reconvened on Monday, the 7th day of July,

10                           2014, at 9.00 a.m.