Tribunal Criminal Tribunal for the Former Yugoslavia

Page 9578

 1                           Wednesday, 9 July 2014

 2                           [Open session]

 3                           [The accused entered court]

 4                           [The witness takes the stand]

 5                           --- Upon commencing at 8.59 a.m.

 6             JUDGE DELVOIE:  Good morning to 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,

16     case manager Thomas Laugel, legal intern Katherine Davis.

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 case manager

21     Negosava Smiljanic, and intern Milan Jovancevic.  Thank you.

22             JUDGE DELVOIE:  Thank you.

23             You may proceed, Mr. Zivanovic.

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

25                           WITNESS:  GORAN HADZIC [Resumed]


Page 9579

 1                           [Witness answered through interpreter]

 2                           Examination by Mr. Zivanovic: [Continued]

 3        Q.   [Interpretation] Mr. Hadzic, yesterday we talked about that

 4     letter that was written by Marin Vidic, Bili, about -- well, I mean, you

 5     said something about that.

 6             MR. ZIVANOVIC:  It's 1D762.

 7        Q.   [Interpretation] Could you please tell us, this letter and the

 8     situation that Mr. Vidic wrote about in that letter, was that a

 9     well-known thing in Slavonia, Baranja, and Western Srem?

10        A.   Yes, it was a well-known thing.  Practically everyone knew about

11     it.

12             MR. ZIVANOVIC:  I would tender this document, Your Honours.

13             JUDGE DELVOIE:  Admitted and marked.

14             THE REGISTRAR:  Exhibit D124, Your Honours.

15             JUDGE DELVOIE:  Thank you.

16             MR. ZIVANOVIC: [Interpretation]

17        Q.   Could you tell me now whether you remember the incidents that

18     occurred at that time, so we're already in the month of August, in

19     general terms, things that happened in the area, in the region of

20     Slavonia, Baranja, and Western Srem?

21        A.   Well, I remember most of these incidents.

22        Q.   Were any of your acquaintances or relatives or friends a direct

23     casualty of the activities taken by the Croatian side?

24        A.   I think that I mentioned some names yesterday.  There were quite

25     a few of my acquaintances and good friends who were casualties, who were

Page 9580

 1     killed, both in Vukovar and in Borovo Naselje, and throughout this area.

 2     Except for Baranja.  I didn't know anyone in Baranja at the time.  So

 3     it's Slavonia and Western Srem.  And the information I had from Baranja,

 4     well, I knew the names, but I did not know those people.  I hadn't known

 5     them before that.

 6        Q.   Can you remember the locations where these conflicts were taking

 7     place at the time, as well as these attacks of Croatian forces against

 8     Serb villages and Serbs?

 9        A.   Well, the closest incident to me was Brsadin.  That's the first

10     one I remember.  Simo Konjevic was killed there.  I think that was before

11     the 1st of August.  It was in June or the end of June.  There was this

12     incident in Sarvas where several civilians were killed.  I remember the

13     Adamovic family.  Maybe the largest numbers were in Vukovar itself and

14     Borovo Naselje.  And in Sotin, Mihajlo Nadj was killed there.  He was a

15     member of the Serb Democratic Party, but I think that one of his parents

16     was a Hungarian and the other one was a Serb, but I'm not sure about

17     that.  I know some names from Vukovar too.  I've already mentioned them.

18     Jovan Jakovljevic, Mladen Mrkic, Tomo Jakovljevic and his wife.

19     Vlado Skeledzija went missing and quite a few other people.

20     Savo Damjanovic, who worked at the hospital, he was a friend of mine, he

21     was killed.

22             So Mladen Mrkic and Savo Damjanovic.  I've just mentioned some

23     names now.  I don't want to go on because I don't really want to skip

24     anyone so I've just -- I've just mentioned a couple.

25             MR. ZIVANOVIC:  May we see, please, 1D299.1.  Sorry.  249.

Page 9581

 1     That's good.  241 -- 249.1.  Yes.

 2             [Interpretation] This is a press release of the Permanent Mission

 3     of the Federal Republic of Yugoslavia, the Permanent Mission of the

 4     Federal Republic of Yugoslavia to the UN.  So could we please take a look

 5     at the next page.

 6        Q.   Could you please take a look at Roman I-003.

 7        A.   Yes.

 8        Q.   Please take a look, and do you see that this incident involving

 9     Mihajlo Nadj is mentioned here?

10        A.   Yes, exactly.

11        Q.   Let me ask you something:  I see that the names of the

12     perpetrators of these crime, or, rather, the suspects are mentioned here.

13     Do you know whether any of them were held accountable for that?  Were any

14     proceedings instituted against them, against the perpetrators of this

15     crime?

16        A.   No, I'm not aware of that.  I don't know who the perpetrators

17     are.

18        Q.   You also mentioned the crime in Sarvas.  Could you please take a

19     look at one -- Roman numeral I-005 and then 006 at the same time.  It's

20     the same place, it's the same date.

21        A.   Yes.  Those are the crimes that I mentioned a moment ago.

22             MR. ZIVANOVIC:  Your Honours, I would tender this document into

23     evidence.

24             JUDGE DELVOIE:  Admitted and marked.

25             THE REGISTRAR:  Exhibit D125.

Page 9582

 1             THE WITNESS: [Interpretation] I'm sorry, yesterday I mentioned a

 2     friend of mine who had been killed and I said that his name was Slobodan.

 3     Out of respect for the deceased, I remembered his last name, Vuckovic;

 4     Slobodan Vuckovic.  He was executed in Borovo Naselje.  He was shot dead

 5     in front of a wall, just like in the Second World War.  That's what I

 6     heard later from eye-witnesses.

 7             MR. ZIVANOVIC: [Interpretation]

 8        Q.   Can you tell us when this happened, to the best of your

 9     knowledge?

10        A.   That happened either towards the end of June or mid-July, so it

11     was before the war.  I've just remembered his last name now.  I couldn't

12     remember before.

13        Q.   Do you know who it was that executed him?

14        A.   According to the information I had then, he was executed by the

15     Croatian reserve police force, but I don't know the actual names.  And

16     when I said the "reserve police force," that should be taken relatively

17     conditionally.  I don't know this exactly, but at any rate, he was killed

18     by the Croats.

19        Q.   You spoke to us about the situation with the refugees at the very

20     beginning of this crisis.  I would be interested in hearing what the

21     situation concerning refugees was at that time, when these conflicts had

22     become more widespread there, so the month of August.  Do you remember?

23     I'm talking about refugees from Slavonia, Baranja, and Western Srem, the

24     ones that found refuge in Serbia and Vojvodina.

25             JUDGE DELVOIE:  Mr. Zivanovic, yesterday I had a conversation

Page 9583

 1     with the interpreters and about the problem -- problems with their work.

 2     One of the problems is your microphone that is open when the witness

 3     answers the questions, and while you're moving around your papers,

 4     there's a lot of background noise.  So you should try to close your

 5     microphone as soon as Mr. Hadzic starts talking.  Thanks.

 6             MR. ZIVANOVIC:  I'll do my best, Your Honours.  Thank you.

 7             THE WITNESS: [Interpretation] May I answer?

 8             MR. ZIVANOVIC: [Interpretation]

 9        Q.   Yes, please go ahead.

10        A.   The number of refugees was proportionate to the increase in

11     combat operations.  So as combat operations increased, the number of

12     refugees increased, to the best of my knowledge.

13             MR. ZIVANOVIC:  May we see please 1D826.  826.  [Microphone not

14     activated].  826.1, please -- 826.1.  My microphone was not on.

15        Q.   [Interpretation] I would just like to ask you to take a look at

16     this text that has to do with refugees.  It is very short, and it says

17     here that -- this is the 29th of August, 1991.  And that 73.588 refugees

18     were registered then.

19             My question:  This number, was it realistic?  Were you aware of

20     it at the time?

21        A.   Well, yes, it was realistic.

22             MR. ZIVANOVIC:  I would tender this document, Your Honours.

23             JUDGE DELVOIE:  Admitted and marked.

24             THE REGISTRAR:  Exhibit D126, Your Honours.

25             JUDGE DELVOIE:  Thank you.

Page 9584

 1             MR. ZIVANOVIC: [Interpretation]

 2        Q.   Mr. Hadzic, yesterday you spoke about the operation of taking or

 3     liberating Dalj - depends on your angle - in 1991.  This is what I'm

 4     interested in:  After that, did you move to Dalj?  You said that until

 5     then you were in Borovo Selo.  Before that, you didn't really have the

 6     right conditions for working.  Did the moment come when you went to Dalj?

 7     Would you please describe that to us.

 8        A.   Yes.  In the beginning of August, maybe seven or six days after

 9     the 1st of August, I came to Dalj.  And there, for the first time, I was

10     given some offices, premises where I could stay.

11        Q.   What kind of premises?

12        A.   The locals continue to call that building Bozidar Maslaric house.

13     That's what I knew it as later.  I knew it as the town library.  Those

14     premises were not adequate but it was the only thing that I had at the

15     time.  Until then, I had absolutely nothing.

16        Q.   Was there anyone else there?

17        A.   I don't seem to remember that anybody else used it as offices,

18     but there were residents of Dalj who came and went.  There were people

19     there almost all the time.

20        Q.   When was the first time you met Radovan Stojicic, Badza?

21        A.   Quite soon after my move to Dalj, while I was on those large

22     premises.  It could have been perhaps on the third day after I moved

23     there.  Maybe the seventh day.  But it was, in any case, in the first

24     half of August.

25             He came into that library.  He was wearing a uniform and carried

Page 9585

 1     a Heckler with a silencer.  That was the first time I saw a silencer.

 2     And he had some sort of black uniform with the lettering "police."  Or

 3     maybe it was navy with some sort of insignia.  But it was a combat

 4     uniform, a dark combat uniform, of the police.  He introduced himself as

 5     Radovan Stojicic, Badza.  He said:  I am a high-ranking official of the

 6     MUP of Serbia, and I am here to take over the Territorial Defence.

 7             There were two other men with him in the same uniform, also armed

 8     with Hecklers, and I knew them by sight because they had earlier been

 9     checking on people crossing the Danube.  I thought they were the highest

10     ranking policemen in Serbia, and then I realised that Radovan Stojicic,

11     Badza, was their boss, so they were unimportant.  One was called Zavisic

12     and the other Bogunovic.

13             There was a fourth man, also carrying a Heckler with a silencer

14     on it, but he was wearing a green camouflage uniform.  It was not a

15     military uniform.  Badza said:  This man is Zeljko Raznjatovic, Arkan,

16     and he will be the commander of special units.  I don't remember if I

17     said anything or if I said:  Okay.  And then I watched through the window

18     as they got into their jeeps.  Some of the jeeps had police licence

19     plates, and one of them maybe had Belgrade licence plates.  And I watched

20     them drive away.

21        Q.   [Microphone not activated]

22             THE INTERPRETER:  We did not hear the question.

23             THE WITNESS: [Interpretation] They had the letter M, followed by

24     a number.

25             MR. ZIVANOVIC:  I repeat my question.

Page 9586

 1        Q.   [Interpretation] For the record, you have already answered it.

 2     What did the police licence plates look like?

 3        A.   There was a letter M followed by a number, and they were blue.

 4     Some of the vehicles were also blue.  They were of a make called Puch.

 5     And there were also Mitsubishi Pajero, also blue.  I had not seen such

 6     vehicles in Slavonia, Baranja, and Western Srem before, especially not so

 7     many of them.

 8        Q.   On that occasion, did Radovan Stojicic ask anything of you?  Did

 9     he have any demands during your first meeting?

10        A.   No, he didn't ask for anything, and he didn't ask me any

11     questions.

12        Q.   Did he perhaps ask where they could find accommodation?  There

13     were quite a few of them.

14        A.   As I said, he asked me absolutely nothing, which means he didn't

15     ask me about accommodation either.  I thought it was their first day

16     there.  I thought they had just arrived.  But when I heard the testimony

17     of Witness 003, I realised they had arrived earlier.  I think, at least,

18     that it's 003; I'm not sure.

19        Q.   Did Radovan Stojicic, Badza, ask of you or of the government of

20     Slavonia, Baranja, and Western Srem to be appointed commander of the

21     Territorial Defence of the SBWS?

22        A.   Never.  And that was never even discussed.  To us, Badza was a

23     representative of the federal state and that's the capacity in which he

24     arrived.

25             MR. STRINGER:  Excuse me, counsel, I -- Mr. President, I was just

Page 9587

 1     noticing, I think that one of the names that Mr. Hadzic mentioned has

 2     been left out of the transcript at page 8, line 9.  He said that there

 3     were two people arrived with Badza and only one of the names, I think,

 4     appears in the transcript.

 5             MR. ZIVANOVIC:  I repeat the question.

 6        Q.   [Interpretation] I'll repeat the question.

 7             Mr. Hadzic, would you repeat for the record the names of the

 8     people who arrived with Badza.

 9        A.   Badza was accompanied by two men wearing the same uniform as

10     Badza and a third man wearing a slightly different uniform.  All of them

11     had the same weapon, namely, a Heckler with a silencer on it.  The one in

12     the different uniform was Zeljko Raznjatovic, Arkan; whereas the others

13     wearing blue uniforms were Nebojsa Zavisic and Milorad Bogunovic.

14     Miodrag Zavisic and Nebojsa Bogunovic.  Zavisic is spelled Z-a-v-i-s-i-c.

15             JUDGE DELVOIE:  Just one moment, Mr. Zivanovic.  I take it ...

16     no, it's already corrected.  Sorry.

17             Please continue, Mr. Zivanovic.

18             MR. ZIVANOVIC:  Thank you.

19        Q.   [Interpretation] Would you tell me, please, when did you learn

20     where they found accommodation?

21        A.   I thought they were in Erdut because I didn't know they had come

22     earlier.  I learned that from the witness.  I heard then that they had

23     been in the village but, in fact, after that, they went to the centre in

24     Erdut.  That's where they were staying.  That's when I saw them.

25             As far as Arkan is concerned, I heard he was in Tenja.  The

Page 9588

 1     village of Tenja near Osijek.

 2        Q.   In that period of June, July, August, did you go to Tenja?

 3        A.   No, I didn't go to Tenja.  And I even wasn't able to go; I didn't

 4     have a car.

 5        Q.   When did you learn that Radovan Stojicic, Badza, and

 6     Zeljko Raznjatovic, Arkan, and their men were accommodated in Erdut?

 7        A.   I heard from some friends of mine that later become members of

 8     the government, specifically, I think, Vojo Susa who was not from this

 9     part of Slavonia and Baranja that was under our control.  His house had

10     been left behind in Vinkovci and he had nowhere to sleep when he was in

11     Slavonia and Baranja.  He told me that there was a centre in Erdut that

12     belonged either to the former TO of Croatia or the JNA where he spent

13     nights.  And I went to see that, and I found accommodation there for

14     myself because I had nowhere to spend nights either.  I wasn't able to go

15     to Pacetin because I couldn't use a normal car.  Only an all-terrain

16     vehicle could use that road, so I either slept there or I would across

17     the Danube and sleep in Serbia.  I went there, and I met

18     Dragomir Lastavica who had been the manager of that centre even before

19     the war.  This man, Dragomir Lastavica, introduced me to a

20     lieutenant-colonel, and I can't remember whether the last name was Stosic

21     or Raskovic.  I realise the two are not similar but I can't remember.

22     Witnesses mentioned different names and I can't recall myself.

23             So they gave me a room upstairs where I could spend nights when I

24     needed to.  I spent nights there, maybe two or three times within those

25     15 or 20 days, and after that, Arkan and Badza showed up.  My driver,

Page 9589

 1     Milenko Japundzic, told me that Arkan had beaten up that

 2     lieutenant-colonel and thrown him out, literally kicked him in the butt.

 3     I couldn't believe it.  So I asked Dragomir Lastavica whether that was

 4     true, and he said yes.

 5        Q.   Does that mean that at some point in Erdut you saw

 6     Zeljko Raznjatovic, Arkan, and Radovan Stojicic, Badza, with your own

 7     eyes?

 8        A.   Yes, I saw them with my own eyes.  During the day, they were not

 9     there; at least not by the time I got up.  They would be already gone,

10     either into combat or for training.  But when I came at night to spend

11     the night there, I saw them sitting together, because the stairs that I

12     used to go upstairs to my room overlooked that large mess room.  I didn't

13     spend nights there often, but I did see them once or twice.

14        Q.   Can you tell us how long you stayed in that building?  How long

15     did you use that room that you described?  Was there a moment - and

16     when - when you moved somewhere else?

17        A.   Even when I was there, I did not sleep there often, perhaps once

18     a week or maybe twice a week.  But then I moved to a flat.  I moved to a

19     flat which was next to the building that was used by the government for

20     its sessions.  It was a manor building.

21             And, yes, now I have just remembered that I need to explain

22     something else.  I learned about that manor from Slavko Dokmanovic

23     because before all the others, he found accommodation there in the best

24     of the rooms in the manor that used to belong to the CO of the winery.

25     And then I was given an office as well, which you entered from the

Page 9590

 1     corridor.  It could not just be a little room with a secretary, like

 2     Dokmanovic said, because that's how things were.  I was happy with that

 3     because the conditions that I had to live in before were worse, and I

 4     even got a telephone line there.

 5        Q.   Does that mean that before that you did not have a telephone

 6     line?

 7        A.   There was a telephone in the library in Dalj in a small room

 8     there, but it was just for local calls within Dalj and even that was

 9     erratic, as far as I can remember.  Before we moved to Erdut, a telephone

10     number was introduced with the 025 aerial code.  That was for Sombor.

11     But I never used it before we moved to Erdut.  The secretary of the

12     government used that telephone, the one who remained in Dalj.

13        Q.   I didn't quite understand your last answer about your

14     accommodation.  Were you accommodated in the manor building or in the

15     building next to the manor building?

16        A.   It was a building 4 metres away from the manor building itself, a

17     newer building that was built for the former IPK Osijek, which was an

18     industrial and agricultural company of Osijek.  It was built for their

19     CEO.  It was quite a nice building with very expensive furniture.

20        Q.   As you have just told us, apart from Slavko Dokmanovic and

21     yourself, did any other government members find accommodation in Erdut?

22        A.   As far as I can remember, the entire government was in Erdut.

23     However, in the main part of the manor building where Dokmanovic was, and

24     that was the first room on the left-hand side as you enter the corridor,

25     and the next room was a big room where the government sessions were held.

Page 9591

 1     And then straight on, along the corridor, was the room where I was.

 2             Next to my room or my office there was another office where

 3     Dr. Hadzic and Sabljakovic were accommodated.  On the right-hand side was

 4     the toilet and there was also a restaurant in that main building.  The

 5     outbuilding or, rather, the building that was an extension to the manor,

 6     there were a few more rooms where ministries were housed or, rather, two

 7     or three ministers shared an office.  I never entered any of those rooms

 8     where the ministers were sitting, or perhaps just once.

 9             There was just one secretary there in the main building.  She was

10     Dokmanovic's secretary.  I didn't have a secretary.  I didn't have any

11     members of staff.  It was only when I became the president of the

12     republic, after I arrived in Knin, that I was given my first secretary.

13        Q.   Mr. Hadzic, when you say that the ministers had rooms there, did

14     they use those rooms as offices or as their private accommodation?

15        A.   No, those were their offices.  Nobody lived on the ground floor,

16     although there was the circular staircase leading to the first floor but

17     I don't know who slept there.  I never climbed that staircase.  The most

18     important thing for us was the restaurant because when I was in Dalj,

19     there was no place for me to eat.  In Dalj, I ate in a soup kitchen for

20     the poor.  I had to have a meal a day at least, and there were no other

21     public restaurants where you could go and eat.

22        Q.   Did you know anything before you saw the four people who arrived

23     in Dalj?  Did you know anything about Zeljko Raznjatovic, Arkan; and, if

24     you did, what did you know?

25        A.   I knew two things perhaps and that was that he was the leader

Page 9592

 1     Crvena Zvezda football fans and that he been arrested in Croatia but I

 2     don't know why.  I read that in newspapers but I didn't pay too much heed

 3     to all that.

 4        Q.   Could you please repeat the first part of your answer about

 5     football fans.

 6        A.   Zeljko Raznjatovic, Arkan, was the leader of the Crvena Zvezda

 7     football fans, and I myself rooted for Partizan, and the two teams were

 8     fierce competitors.

 9        Q.   From their arrival in Slavonia, Baranja, and Western Srem, i.e.,

10     from your first encounter in Dalj, what was your relationship with

11     Radovan Stojicic, Badza?  What kind of contacts did you have with him?

12        A.   I didn't have any special contacts with Badza, i.e., I never

13     called him or asked him things.  It was only when he arrived in the

14     government's courtyard or in the government's building that I got to see

15     him.  And later, he attended the government sessions, but he stayed only

16     during the first item of the agenda and he spoke about some situation on

17     the ground.  That's how the thing was presented to us.  And as soon as he

18     presented his case, he would leave the government's session.  He never

19     stayed for longer than ten minutes, perhaps.

20             THE INTERPRETER:  Microphone.

21             MR. ZIVANOVIC: [Interpretation]

22        Q.   Did Radovan Stojicic, Badza, attend all the meetings of the

23     government of Slavonia, Baranja, and Western Srem that you yourself

24     attended?

25        A.   No, he did not.  I don't know.  In percentages, he may have

Page 9593

 1     attended a half of them, but I'm not sure.  Because he wasn't duty-bound

 2     to attend government sessions.  He attended them at his own will.

 3        Q.   When he did attend the sessions of the government, what did his

 4     participation consist of?  What did he say?  What was the content of his

 5     presentations to the government?

 6        A.   It was the situation on the ground.  Because we wanted to know

 7     the number of dead on our side because we did not have any contacts with

 8     the villages in the area, and we didn't know what was going on.

 9     Telephone lines were down.  We didn't have all-terrain vehicles to tour

10     the villages, so we had to accept what he told us.  That was our only

11     source of that information.

12        Q.   And did he also give instructions to the government, to the

13     members of the government, or to yourself personally at some of those

14     sessions?

15        A.   No.  We were not in a subordination relationship.  He was

16     independent from us, we were independent from him.  We had our own

17     programme.  We did what we did.  And when he came, he only attended the

18     first item.  He was not interested in any of the political issues or our

19     political decisions.

20        Q.   Did he ever object to a government's decision?  Did he ever say

21     that a decision should not be implemented or that it should be revised or

22     that some higher authorities should be consulted, I mean, in Serbia or in

23     Yugoslavia, before a decision of that kind was passed?

24        A.   No, he never said that in so many words.  Or, rather, none of our

25     decisions concerned any of the important things.  The only influence

Page 9594

 1     Badza exerted was when the minister of the police was being removed from

 2     office and that was not at a government session but, rather, he did it

 3     through his associates.  Once he told me that Boro Bogunovic could not be

 4     the police minister because the Serbian police would not want to

 5     co-operate with him.  I didn't say that -- when he said that he would be

 6     the TO commander, he also said that he would take over the police, and

 7     effectively he did that because the police were under him.

 8        Q.   [Microphone not activated]

 9             THE INTERPRETER:  Microphone.

10             MR. ZIVANOVIC: [Interpretation]

11        Q.   When you say that you took over the police, what police do you

12     have in mind?

13        A.   I mean the police that had been the Croatian police before the

14     war and those officers who left the Croatian MUP and joined the police of

15     Slavonia, Baranja, and Western Srem.  Later on they were joined by some

16     civilians, and they all got uniforms and weapons.

17        Q.   You say that later they were joined by some civilians.  What

18     civilians did you have in mind?  I'm reading what's in the transcript.

19        A.   From before the war, there were not that many active-duty

20     policemen, so when police stations were set up in villages and somewhat

21     larger places, the core membership were former active-duty policemen but

22     the number had to be increased.  And there were, therefore, civilians who

23     were locals but were civilians before the war who joined those newly

24     established police stations.

25        Q.   Do you know who was involved in the selection procedure before

Page 9595

 1     those civilians could join the police force?

 2        A.   I don't know.  It was not an issue to be discussed by the

 3     government.  I suppose they were selected by the former pre-war

 4     active-duty policemen who chose their associates.  And obviously Badza

 5     and Zavisic at higher levels.

 6        Q.   In addition to what you have told us about the demand to remove

 7     Boro Bogunovic from office as the police minister, did you receive any

 8     other indirect instructions or requests from Badza?  Did he want the

 9     government to do something else or not to do something else?

10        A.   No.  I didn't receive any instructions, either direct or

11     indirect.  Although this matter involving Boro Bogunovic might be called

12     an indirect instruction.  He didn't tell me:  Remove Boro Bogunovic.  He

13     told me:  Do as you will.  However, if Bogunovic remains, minister, we

14     will not co-operate with him.  At least that's how I understood him.

15     Although it's probably the same, in a way.

16        Q.   Did he tell you why?  Did you ask him about the reasons why he

17     told you that?

18        A.   I did.  Of course I did.  Although I already knew the reason.

19     The problem was that he -- that Boro was not professional.  He didn't

20     have any experience.  When we set up the government, he was like an

21     interim solution to the problem that we had.  That was the most important

22     thing.  He was just not professional enough.  He did not have the

23     required knowledge.  I don't remember any other details.

24        Q.   Did you say that to Bogunovic?  Did you convey that to him, this

25     conversation that you had with Radovan Stojicic, Badza?

Page 9596

 1        A.   Of course I told him.  Since Boro is my friend, I tried to

 2     explain, first of all, indirectly, and then he wouldn't accept that.  And

 3     then I said we could not exist and he asked:  Whose position is that?

 4     And I said:  That is Badza's position.  And he said:  Who is Badza?  I

 5     don't recognise Badza.  And I said:  Badza represents Belgrade, and this

 6     is the position of Belgrade.  I see that somehow he agreed to be deputy

 7     prime minister rather than minister of police.  Although he never really

 8     worked as minister of the police.  He was in Sid and he was involved in

 9     humanitarian matters to a larger degree.  However, this really hit Boro

10     bad, and I don't know why.

11        Q.   When you said that this is the position of Belgrade, too, what

12     were you actually trying to hint at?  Did you know that this was the

13     position of Belgrade, as you had put it, or did you say that to him for

14     some other reason?

15        A.   Well, I said that in order to cheer him up and to make him

16     relent.  He was very obstinate.  He had even quarreled with Badza and I

17     didn't even know about that.  He said:  No way, what do I care?  And I

18     said:  How are we going to work?  How is the police going to work?  And

19     then ultimately he agreed.

20        Q.   Was he convinced that the request for his removal was made by

21     Badza only or did he think that some authority superior to Badza had

22     asked for that?

23             MR. STRINGER:  Excuse me, Mr. President.  That's a leading

24     question.  Counsel is just now feeding suggestions to the witness rather

25     than the witness just giving his own account of the events.  We object.

Page 9597

 1             JUDGE DELVOIE:  Mr. Zivanovic.

 2             MR. ZIVANOVIC:  I don't believe that it is a leading question.

 3     The witness has the option to -- to respond.

 4             JUDGE DELVOIE:  Yes, Mr. Stringer.

 5             MR. STRINGER:  It's a suggestion, Mr. President.  And, sure, the

 6     witness doesn't have to lead where counsel is trying to take him.  But

 7     counsel is leading the witness rather than just allowing the witness to

 8     describe it.  He could ask the question differently, in our view.

 9             JUDGE DELVOIE:  I agree with Mr. Stringer, Mr. Zivanovic.  Please

10     rephrase or move on.

11             MR. ZIVANOVIC: [Interpretation]

12        Q.   Can you say what kind of impression you had of your conversation

13     with Bogunovic that had to do with the request to have him dismissed from

14     the position of minister of the interior?

15        A.   Well, Bogunovic had overestimated his role.  He thought that

16     Belgrade meant somebody above Badza, although nobody in Belgrade had

17     known of Bogunovic.  And he took that very personally.  He thought that

18     this was some kind of directive from Belgrade but it wasn't.  Nobody knew

19     who Bogunovic was over there in Belgrade.  Half of Slavonia didn't know

20     who Bogunovic was anyway.  Maybe it's my fault.  I could have put it in

21     harsher terms, but I didn't want to.

22        Q.   Can you tell us whether you could see what the relationship was

23     like between Radovan Stojicic, Badza, on the one side, and

24     Zeljko Raznjatovic, Arkan, on the other?

25        A.   That question was put to me when I gave a statement to the

Page 9598

 1     investigators in 2003, and I think about that often.  I personally never

 2     saw them -- I mean, I never saw them at an official meeting either, so I

 3     couldn't see who was superior to who.  But for me, they were part of the

 4     body of the same state, in a way.  They were not opposed to one another.

 5        Q.   Can you tell us whether you met Zeljko Raznjatovic, Arkan, and

 6     what your relationship was?

 7        A.   Well, it would be hard for me to explain this concept of

 8     "relationship" here.  There was no relationship.  I only saw him when he

 9     wanted that to happen.  I never took the initiative for these meetings.

10        Q.   Can you tell us what happened during these meetings that he

11     initiated?  Did he make certain proposals to you, certain requests,

12     demands, suggestions?

13        A.   Well, basically he would say that my security was threatened,

14     that the Croats would pay someone to kill me, that they would send a

15     terrorist group, and I think that wasn't true and there was no reason for

16     that.  And he said that my security detail was not properly trained, that

17     I should be taken care of by professionals, that he had people who were

18     capable of doing that, that I would not have any costs involved for this

19     security detail.  And, of course, I thought that was unnecessary, and in

20     a skillful way, I managed to avoid this.  But, still, I was cautious.  I

21     could not say this openly, what it was that I thought.  In a way, these

22     were his main objections up until that situation concerning the plan, but

23     that was later.

24        Q.   When he said that your security detail should be professional,

25     did he say to you who these professionals would be, the ones who should

Page 9599

 1     take over your security?

 2        A.   Well, yes, yes, I've just said that.  His people were supposed to

 3     provide for my security and then that would be proper, and I would not

 4     have any expenses involved.  But, of course, I refused that.

 5        Q.   And can you tell us whether you had any security then at all;

 6     and, if so, who was it that was on your security detail?

 7        A.   I had no security before I arrived Dalj.  Whenever I went to

 8     Serbia, I always had to ask someone to come with me because I had no

 9     documents.  When I was in Dalj, a few days later, while I was walking

10     through Dalj on my own because I could not just go on sitting there at

11     the library all the time, in the street I bumped into a good friend of

12     mine.  For a while, he was my karate trainer.  He was the best-known

13     karate man in Slavonia, Baranja, at the time, Ljubo Mudrinic.  He was

14     also just walking around, he did not have any particular duties in Dalj.

15     He was a refugee from Osijek.  We chatted a bit.  I asked him whether he

16     wanted to keep me company, in a way, because he was sort of lost in Dalj

17     too, and he agreed, and then he started just being there with me.

18             When I got a car - it was a old Renault 25 - Ljubo and I took

19     turns driving that car.  He was not a very good driver.  He said that

20     himself, that he was not.  And he suggested that he call another friend

21     of mine who used to work in Germany who was a professional driver.  He

22     was a truck driver in Germany.  So he suggested that he join us too.  His

23     name was Milenko Japundzic.  He was also a professional karate man.  So

24     he showed up very quickly, the beginning of September, and he was the one

25     who drove us.  They were my security detail during 1991, the two of them

Page 9600

 1     only.  Everybody knew that because they were popular in Slavonia and

 2     Baranja, especially Ljubo Mudrinic.  That was the best-known name in

 3     sports then in Slavonia and Baranja.

 4        Q.   You said that you refused Arkan's offer but that you were looking

 5     for a way and, I mean, you did not want to say what the real reasons were

 6     for that.  In a way, you were being cautious.  Can you tell us now what

 7     the reasons were, why you did not accept his offer to have his men

 8     provide security for you?

 9        A.   Well, this is what I was thinking about.  What I heard from my

10     driver, how he beat up that lieutenant-colonel, and I saw that he held

11     everything under his own control.  He would not allow for any

12     improvisations.  If I were to accept his security, I think that I would

13     simply disappear.  I didn't mean disappear physically but I couldn't say

14     anything without him.  I would depend on him, and I didn't want to agree

15     to that.  And I didn't go into any political topics with him and no other

16     topics either.  In his presence, I didn't even mention Partizan, the

17     football team that I was a fan of, because I didn't know how he would

18     react.

19        Q.   After this conversation and this refusal, did you have the

20     impression -- or, rather, how did this develop further?  Was this kind of

21     request made by him yet again for this security?  I mean your security.

22        A.   Well, there were a few things in the beginning, and I thought

23     that this was a coincidence.  When I showed up, he would show up.  I

24     thought that this was a coincidence, but when it happened for the third

25     time or the fourth time, I realised that he was sort of following me.  I

Page 9601

 1     became suspicious, and it did not feel right.  I felt uncomfortable.

 2        Q.   Can you say whether you thought about this, why he would be

 3     following you?  What was the reason for that, these several situations

 4     when you would show up somewhere and then he would show up too?

 5        A.   Well, this was this problem that was following me everywhere,

 6     that I was Croatia's man, that I was in favour of negotiating with

 7     Croats, that I had been given an injection in Plitvice, that I was

 8     drugged, that I was not safe.  So I thought that, in a way, he was

 9     checking on that.

10             Because when I was in released from Plitvice -- well, it had

11     nothing to do with Arkan.  This was earlier on.  A group of men showed

12     up, and they went to local communes and they were lobbying against me.

13     They were asking for my removal, and they were saying that I had been

14     drugged and that I was working for the Croatian side.

15        Q.   And was there some other way, I mean, in which you were shown

16     that he was actually following your movement?

17        A.   Well, I did not have a service that could report that to me.  I

18     was on my own with these two drivers.  But I had already noticed that

19     this was no coincidence that he would show up.  He came in front of the

20     government building, he came to the government yard, he'd show up on the

21     road.  It was impossible for that to be a coincidence.  It's a very small

22     area but still.  That dilemma was resolved towards the end of the year,

23     when the Vance Plan was discussed.

24   (redacted) [Confidentiality partially lifted by order of the Chamber]

25   (redacted)


Page 9602











11 Pages 9602-9603 redacted.
















Page 9604

 1   (redacted)

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 3   (redacted)

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 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24        Q.   I should now like to go back to one matter we've discussed before

25     because I think it needs more clarification.  We will go back to the

Page 9605

 1     arrival of Radovan Stojicic, Badza, in Dalj in the beginning of

 2     August 1991 and your first meeting with him and the group that arrived

 3     with him.  Can you tell us how large was the group that came with

 4     Radovan Stojicic, Badza?

 5        A.   You mean the group that I then saw in Dalj?

 6        Q.   Yes.

 7        A.   In my rough estimate, there were perhaps ten to 12 men with Badza

 8     and about ten with Arkan.  Because they were wearing different uniforms.

 9        Q.   Could you tell us what kind of weapons the people in the group

10     had?  You only described the weapons of the four men who entered your

11     office.

12        A.   Only those four that I mentioned had Hecklers.  The rest were

13     also armed but with automatic rifles.  At least the men that I saw.

14        Q.   Could we clear up one more thing concerning that conversation you

15     had about Boro Bogunovic and his dismissal from the post of minister of

16     the interior.  When did that conversation take place?

17        A.   I talked to Boro Bogunovic maybe in the end of November or in the

18     beginning of December.  It's more likely December.  I'm not sure.  I

19     can't remember when Boro was replaced, when he became deputy

20     prime minister.

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25             MR. ZIVANOVIC: [Interpretation]


Page 9606

 1        Q.   Mr. Hadzic, could you tell us, to the best of your recollection,

 2     and what impressions you had about the relationship between Arkan and the

 3     JNA.

 4        A.   My impression was that there was no difference between the two,

 5     that they were one body.

 6        Q.   From what did you draw that conclusion?

 7        A.   From what I was able to see not only in media reports but also on

 8     the ground, they co-operated constantly, they were constantly in touch.

 9     As much as I was able to see because I was often away.

10        Q.   Did you have occasion to see that somebody from the JNA publicly

11     criticised the conduct of Zeljko Raznjatovic, Arkan, and the members of

12     his unit?

13        A.   I don't know of any such thing.  If it happened, I never saw it.

14        Q.   You were able to see during the trial a large number of reports

15     that members of the JNA sent out, describing some acts by

16     Zeljko Raznjatovic, Arkan, in a very negative light.  We can look at some

17     of them again, such as P103.  It's tab 78.

18             You can see that the title of such documents was:  "Information."

19     In the left upper corner, it says that these documents were sent to the

20     Security Administration of the Federal Secretariat for National Defence.

21             If you wish, you can take a look.  You will see that it says here

22     that Zeljko Raznjatovic, Arkan, conducted badly towards some officers of

23     the JNA.  More specifically, a reference is made to Lieutenant-Colonel

24     Jovanovic.

25             Did you ever receive a piece of information of this kind from

Page 9607

 1     military bodies?  Did they convey such information to either you or the

 2     government?  Did any military body do that?

 3        A.   We have never received any information from the army.  When I say

 4     "never," we never received any information from the military whatsoever,

 5     not only the information of this kind.  When I say this, I mean in an

 6     official form.  Colonel Ristic did attend a government session and we

 7     spoke to him.  So when I say "never," what I have in mind is official

 8     communication.  There may have been some brief notes or notifications but

 9     that's all.

10        Q.   Did he inform you that Zeljko Raznjatovic, Arkan, i.e., his unit,

11     had committed crimes in the territory, that they were involved in some

12     matters that were against the law or were not in keeping with the law?

13        A.   No, nobody ever informed us about that, including the military.

14        Q.   Did you possibly receive such information indirectly through some

15     civilian bodies of authority, either from Serbia or from Yugoslavia?

16        A.   No.

17        Q.   Did you gain an impression about the relationship between

18     Zeljko Raznjatovic, Arkan's units, on the one hand, and the units of the

19     JNA which were deployed in Slavonia, Baranja, and Western Srem at the

20     time?  Was there a relationship of superiority or inferiority between

21     them?

22        A.   My impression was - and it still is - that Arkan was a part of

23     that system, that he was subordinated to them.  I don't know who was

24     whose superior.

25        Q.   When you say you don't know who was whose superior, do you have

Page 9608

 1     in mind individuals from the JNA or do you perhaps think that Arkan may

 2     have been superior to the entire JNA?

 3        A.   No, I mean individuals at lower levels.  When there was an

 4     operation, I didn't know whether a major was in charge or whether Arkan

 5     had -- had the lead.  I don't know -- I didn't know who was in command.

 6     Of course, I know that Arkan was not superior to the JNA as a whole, as a

 7     military.

 8        Q.   Were you familiar with an initiative or a document issued by the

 9     JNA, according to which Arkan's unit or, rather, him and his unit, should

10     withdraw from the area and go back to Serbia or, rather, Yugoslavia?

11        A.   I don't remember any such thing.  I'm not familiar with that, if

12     there was a thing like that.

13             MR. ZIVANOVIC:  May we see P3115, please.  It is tab 1326.  Oh,

14     sorry.  Sorry.  It is P2715.  Tab 742.  Actually, we -- we put 1D328, but

15     we established that this document has already been admitted into

16     evidence.  On our list, it is 1D328.

17        Q.   [Interpretation] This is an interview that General Panic gave in

18     1994.  I believe that the date was 4 October 1994.  I believe you

19     remember this interview.

20             MR. ZIVANOVIC: [Interpretation] I'm interested in page 37 in the

21     original, which is page 35 in the English translation.  The question

22     starts already on the previous page, on page 36, i.e., 34 of the original

23     and the English translation respectively.  The question is about Arkan

24     and other paramilitary units as they were called at the time.

25        Q.   On the page that I am showing you now, you will see where it says

Page 9609

 1     that they were supposed to go back, Arkan and his unit, but that

 2     Goran Hadzic, the president of Serbian Krajina, kept them as his personal

 3     security detail.  Can you find it?  Did you find it?

 4        A.   Yes.  But this is not correct.  They were never my own personal

 5     guard.  I never advocated their stay.  It was not up to me to decide

 6     whether they should stay or go.  I was the president of the Serbian

 7     Krajina only from 1992.

 8        Q.   Can you tell us - and you said already that there were two people

 9     who were members of your security detail in 1991 - but later on, from the

10     moment you became the president of the Republic of Serbian Krajina, which

11     was in February 1992 until the end of 1993, who were the men in your

12     security detail?

13        A.   Let me try and remember them.  Milenko proposed a relative of his

14     who was a policeman in Baranja.  His name was Perica Obradovic.  Since we

15     extended the escort, we had another vehicle so we needed another driver,

16     so Perica proposed his own father who was a professional driver,

17     Milan Obradovic.  Then I invited my friend from Vukovar who had trained

18     karate together with me, Savo Petrovic.  Perica Obradovic then invited

19     his best man, who had been at the police academy in Zagreb together with

20     him, Velibor Ilincic; he was a refugee in Belgrade.  And we were joined

21     by Jovan Vranic, who was also a refugee from Zagreb, and Jovo Batalo

22     [phoen], a refugee from Cepin who drove the third car.  I believe that

23     I've given you all the names.

24             And then at the end of 1993 or in the second and a half of 1993,

25     I had two locals from Pacetin who joined us.  And for a short while,

Page 9610

 1     Ljubinko Kukic from Borovo Naselje was also together with us.  That was

 2     in 1993, I believe.  Velibor Ilincic had already left my escort detail by

 3     then, whereas Ljubo Mudrinic was killed in 1992, so obviously he also was

 4     no longer my security guard.

 5        Q.   You told us about Ljubinko Kukic, that he was with us.  Where was

 6     he from?

 7        A.   He was from Borovo Naselje.

 8        Q.   Were all these people your security guards at the same time, or

 9     did they act as your security guards at different periods of time?

10        A.   During those three years, 1992, 1993, 1994, they were my security

11     guards but not at the same time.  Some joined and some left.  But these

12     are all the ones that I remember from that period when I was the

13     president of the SAO Slavonia and Baranja.  And there were only two,

14     Ljube -- Milenko and Ljubo Mudrinic.  And the others, they were with us

15     in 1992 and 1993 but in different periods of time.

16        Q.   Would you please repeat the names of the two guards who were with

17     you while you were the prime minister of Slavonia, Baranja, and

18     Western Srem?

19        A.   I had a driver, Milenko Japundzic, and a security guard, Ljubo,

20     Ljubomir Mudrinic.  Both were from Osijek.

21        Q.   Did any of the men whose name you have -- names have you just

22     told us belong to the Serbian Volunteer Guards of Zeljko Raznjatovic,

23     Arkan?

24        A.   No, none of them.  They were all locals.  They were all Croats.

25     From current Croatia or the former Socialist Republic of Croatia, that

Page 9611

 1     is.  They were Serbs.  They were not Croats.

 2        Q.   While you were the president of the Republic of Serbian Krajina,

 3     did General Panic or anybody else from the military talk to you about

 4     Arkan and their possible wish to remove them from the Republic of

 5     Serbian Krajina?

 6        A.   No, nobody from the military ever spoke to me about Arkan.  They

 7     never wanted to talk to me about him.

 8             MR. ZIVANOVIC: [Interpretation]

 9        Q.   On page 36 of the original statement, which is page 34 in the

10     translation, General Panic says that Arkan was there, as he puts it,

11     i.e., in the territory of Slavonia, Baranja, and Western Srem, even

12     before the military launched its operations.  And he says that he had

13     made an arrangement with local leaders.  When was it that the military

14     launched its military operations in that territory; do you know that?

15        A.   The first operation started on the 2nd of May in Borovo Selo, and

16     they remained there thereafter.  The following one was on the 7th of July

17     in Tenja, and they remained there as well.

18        Q.   Were they still there after the operation in Dalj on the

19     1st of August, 1991?

20        A.   Sorry, since we were talking about Dalj, I thought that it went

21     without saying that once they arrived Dalj they stayed there, so I

22     mentioned these two things that happened before Dalj.

23        Q.   Do you know that Arkan came there to Slavonia, Baranja, and

24     Western Srem in agreement with some local leaders?

25             MR. STRINGER:  Objection to the leading question, Mr. President.

Page 9612

 1             JUDGE DELVOIE:  Could you rephrase, Mr. Zivanovic.

 2             MR. ZIVANOVIC: [Interpretation]

 3        Q.   Do you know with whom Arkan had agreements in terms of coming to

 4     Slavonia, Baranja, and Western Srem and whether he had any agreements of

 5     that kind in the first place?

 6        A.   I don't know about that.  When I saw him, I saw him with Badza.

 7     And I don't know who it was that he had reached agreements with before

 8     that, if any.

 9        Q.   In this statement of General Panic's, it is stated that he

10     ordered the local commander of the JNA to place Arkan under his control

11     and that Arkan agreed to that.  Do you have any information?  Do you know

12     of any such thing?  Do you know anything that could either confirm or

13     deny that?

14        A.   Well, I don't have any direct knowledge what Panic ordered, but I

15     think it was obvious on the ground.

16        Q.   On page 38 of the original, or, rather, 36 of the English

17     translation, it says that at various meetings in April, May, June 1992,

18     Arkan was mentioned.  This is what I would be interested in -- actually,

19     General Panic is speaking there.  So did you attend these meetings?

20        A.   I did not attend.  I was not present.

21             MR. ZIVANOVIC: [Interpretation] Could we please take a look at

22     P152.  It is tab 111.

23        Q.   This is what I wanted to ask you.  Did you know that the command

24     of the 12th Corps was in Dalj?

25        A.   I knew, but I did not know from the very outset that they had

Page 9613

 1     come, and I did not know when they came.  But later on, I found out when

 2     Biorcevic was the commander, when General Bratic was killed.

 3        Q.   This is a document stating that weapons are being given to

 4     three men as war trophies.  I'm interested in the person under number

 5     two, and it says here that this person is the deputy commander of the

 6     Slavonia, Baranja, and Western Srem TO.  Can you tell me whether you knew

 7     about that; and, if so, when was it that you found out?

 8        A.   I never knew that Trajkovic was deputy commander.  And I never

 9     knew that Badza had a deputy in Slavonia and Baranja, or, rather, that he

10     had appointed a deputy.

11        Q.   And did you know that Zeljko Raznjatovic, Arkan, bore the title

12     of the commander of the Special Volunteer Unit of the -- of the

13     Territorial Defence of Slavonia, Baranja, and Western Srem?

14        A.   I did not know about that.  This is the first time I hear of it.

15             MR. ZIVANOVIC: [Interpretation] Can we take a look at P237.140.

16     Tab 186.

17        Q.   You do remember this order.  It was shown earlier on.  I see that

18     it was signed by Milanovic, Milan.  You know why -- or, rather, it says

19     here in big letters that it's Ilija Kojic, but do you know whether this

20     is Ilija Kojic's signature?

21        A.   This was signed by Milan Milanovic instead of Ilija Kojic because

22     the date is the 21st of December, 1991, when Ilija Kojic was in hospital.

23     He was seriously wounded.  He barely survived.  He was still in hospital.

24     I think he was still in hospital in Belgrade then, but I'm not sure.

25        Q.   Can you tell us, because it is written here that this order was

Page 9614

 1     issued by the minister of defence, was the government aware of this

 2     appointment?

 3        A.   No.  And I was not aware of it either.  And the government wasn't

 4     made aware of it, either officially are unofficially.

 5        Q.   Can you tell us about the relationship between Milan Milanovic,

 6     on the one hand, and Radovan Stojicic, on the other?

 7        A.   I know that they had a very good relationship, and Milanovic was

 8     Stojicic's guide through Slavonia for a certain amount of time.

 9        Q.   Tell us, please, Mr. Hadzic, when Zeljko Raznjatovic, Arkan,

10     offered his men to you as a security detail, physical security, what was

11     your impression of the sincerity behind that offer?

12        A.   I had the feeling that this offer was not sincere, that there was

13     something lurking behind.  I didn't know what, though.  My suspicion was

14     that what was behind it was some kind of a wish to exercise control.  I

15     had these strange things happening and first I thought that these were

16     coincidences.  I've already said I would show up in the road and he would

17     catch up with me in the car, and I thought that was just by chance.  And

18     then afterwards, when I returned from somewhere where I was just with two

19     other men, he said:  Why did you go there?  It's dangerous there.  And I

20     thought:  How did he know?  How did he know where I was when he wasn't

21     even present?  And I had the impression that he either had my phone

22     bugged or something like that.

23             MR. ZIVANOVIC:  May we see, please, P1836.

24             JUDGE DELVOIE:  Tab number, please.

25             MR. ZIVANOVIC:  It is tab 419.

Page 9615

 1        Q.   [Interpretation] If you remember, this is a piece of information

 2     from the JNA.  It's about Zeljko Raznjatovic, Arkan's attack against a

 3     military man on the 22nd of February, 1992, near the Vukovar Hospital.

 4     There's a description here of what had happened.  But I would like to ask

 5     you to tell us about what had happened and especially to tell us how come

 6     it happened that Arkan was there at the same time when you were.

 7        A.   I first saw this information now, when I came here.  I never knew

 8     that this was written up.  I remember that I had announced my visit to

 9     the hospital and that I went in two cars.  I just heard from the drivers

10     from the second car who stayed on in the yard that Arkan had a physical

11     fight with someone, but I did not know why or anything else.  Now I see

12     that it's this Lukic.  I knew him too.  He was military police, but he

13     was a local person there in the municipality of Vukovar.

14        Q.   Can you tell us the following:  At the time when you went on this

15     visit, did you know that Zeljko Raznjatovic, Arkan, was going too?  Did

16     you agree with him that he should also come along?  How did that happen?

17     Do you know how come he showed up there?

18        A.   I did not reach any kind agreement with him, and I do not know

19     how it was that he showed up as well.

20        Q.   It says here that you arrived there around 2.30 on that day,

21     accompanied by four vehicles.  Did you have four vehicles escorting you?

22        A.   No.  I was in one vehicle, and there was one vehicle escorting

23     me.

24        Q.   There's a description here of that incident now.  Did you see

25     that?  Did you see what happened?  Where it says here that Arkan got out

Page 9616

 1     of -- or, rather, got out and tried to enter by force, were you present?

 2        A.   No, I was not present.  We passed that way and we went to the

 3     entrance on the right so this remained behind us.

 4        Q.   When you say "we entered," who are you referring to?

 5        A.   I'm referring to the vehicle that I was in.  One vehicle.

 6             JUDGE DELVOIE:  Could we go to the next page in English, please.

 7     Thank you.

 8             MR. ZIVANOVIC: [Microphone not activated] We can move to the next

 9     page in B/C/S, too, please.

10        Q.   [Interpretation] And did you see or, rather, did you notice

11     anything as you were leaving the hospital?  Did you see an incident

12     there, or did you see anyone who had been injured?  Did you see anything

13     happening?

14        A.   No, no, the door was open, and we raced through in the car.  We

15     didn't notice anything.  As far as I heard from the escorts who stayed

16     behind, it wasn't that there was anybody injured there.  It was a

17     physical fight in the sense of slapping around, but it wasn't that

18     anybody was injured.  It wasn't a big fight.

19             MR. ZIVANOVIC:  May we see, please, P3115.

20        Q.   [Interpretation] As you remember, that's an incident that

21     occurred in 1993, in October, on the bridge at Batina, in the same place

22     Arkan was involved in an incident with members of the Belgian battalion

23     of UNPROFOR.

24             Could you please tell us, to the best of your recollection, what

25     exactly happened?

Page 9617

 1        A.   That incident was reported in the media.  At that time, I already

 2     had a chef de cabinet and two secretaries, and it was the usual

 3     procedure, when going to Baranja, that one of them announce me to the

 4     police in Baranja that I was coming.  And then one car of the Baranja

 5     police would meet me halfway across the bridge where the Republic of

 6     Serbia finishes and Baranja begins, and then they would turn on the

 7     rotating lights on the roof and escort me with two vehicles.  And that's

 8     how I passed through.

 9             It's not the same as the incident at the hospital where Arkan's

10     car was just behind mine.  He was rushing behind us.  He was in pursuit

11     but he was not part of our motorcade.  Otherwise I would have seen it.

12     He was 5 or 6 kilometres behind us when we were on the bridge.

13        Q.   Let's clear up one thing.  That first time, which is not similar

14     to this situation, you say that he was part of your motorcade.  Did you

15     notice him in the motorcade as you were driving towards the

16     Vukovar Hospital?

17        A.   No, I didn't, but he turned up immediately.  I understood that he

18     had been parked outside the hospital, waiting for us.  In the other

19     incident, he started out behind us.  He appeared six to ten minutes after

20     I passed through.  The time intervals are different.  That's why I

21     thought it was not the same case.

22        Q.   This time, did you expect him to be part of your escort when you

23     were crossing the Batina bridge?

24        A.   No, I was not expecting it, and it was not part of my escort.

25     From Erdut to Baranja, you have to cross the territory of Serbia, and

Page 9618

 1     there was no need for anybody to escort me.  I mean, driving across

 2     Serbia, there were no war zones there.

 3        Q.   [Microphone not activated]

 4             JUDGE DELVOIE:  Microphone.

 5             MR. ZIVANOVIC:  Sorry.

 6        Q.   [Interpretation] When did you learn about this incident on the

 7     Batina bridge?

 8        A.   That same day, while I was in Baranja for an Assembly session, I

 9     think it was.  Two or three hours after the event.

10        Q.   Did you ever have occasion to talk to Zeljko Raznjatovic, Arkan,

11     about these incidents?  Let me split this question.  Concerning this

12     incident at the Vukovar Hospital, how did he happen to be there?

13        A.   No, we were not on such terms that I would have been able to

14     discuss it with him.  I didn't want to interfere with his movements.  And

15     I couldn't do anything about their behaviour.

16        Q.   In view of the fact that this incident involving the Belgian

17     battalion was widely publicised, did you ever ask him how it had come

18     about that he had arrived ten minutes after you?

19        A.   He was going on his own business, and I didn't interfere with

20     that, but men from his detail complained about it to people from my

21     detail.  They talked about the fight, fist-fight.

22             JUDGE DELVOIE:  Mr. Zivanovic, I see you're -- you'll move on to

23     another topic.  But you realise that we have been discussing an incident

24     at the Batina bridge on the basis of a document on the screen of which we

25     have only seen the cover page.

Page 9619

 1             MR. ZIVANOVIC:  Yes, we'll see the other pages too.

 2             JUDGE DELVOIE:  Okay.  Thanks.

 3             MR. ZIVANOVIC:  May we see the second page, please.

 4        Q.   [Interpretation] In this report, which describes the incident, it

 5     says it happened on 9 October at 11.14.  You crossed the bridge at Batina

 6     with a police escort.  Is it consistent with the truth?

 7        A.   Yes, that's true.

 8        Q.   It also says that at 11.25 on the same day, a convoy of

 9     three civilian vehicles arrived.  The first vehicle neglected the first

10     stop at the first check-point until members of UNPROFOR stopped them at

11     the second check-point.  Were you there?

12        A.   No.  If you look at this timeline, I was, by that time at least,

13     15 kilometres away.

14        Q.   I think you also have the translation of this document which has

15     been admitted into evidence.

16        A.   I don't have a translation.

17        Q.   I will read this out to you and I will ask you to confirm that it

18     is the same as what you heard:

19             [In English] "The driver of the first car just gave a sign, all

20     soldiers left immediately the cars.  They immediately armed their guns,

21     pointed them at the soldiers on the check-point and at all important

22     locations from where the platoon could react, in a well-prepared way.

23     Some of them tried to replace the road obstacles and it was at this point

24     that Master Corporal Gusbin got hurt at his head.  He was hit with a

25     rifle-butt."

Page 9620

 1             [Interpretation] Did you hear that one of the members of the

 2     Belgian battalion was injured?

 3        A.   No, I didn't hear about that.

 4        Q.   [In English] "When the obstacles had been removed, the first car

 5     intended to continue.  The P1 commander jumped on the front of the car

 6     after having his pistol armed.

 7             "The company commander went on the spot and saw the P1 commander

 8     being beaten and hit on head and back by rifle-butts.  Corporal Rutte

 9     tried to get on the M113, which was stationed on the bridge to take

10     possession of the MG.50.  As he was unarmed, the soldier hit him at the

11     throat with the butt of his rifle.  Then the P1 commander was hit again,

12     this time at his face with the barrel of a gun."

13             [Interpretation] Did you hear about those details?

14        A.   No, I only heard about a fist-fight.

15             MR. ZIVANOVIC:  May we scroll down a little bit, please.  [No

16     interpretation].

17        Q.   [In English] "The company commander tried then to discuss

18     diplomatically with the chief of the Arkan soldiers (the driver of the

19     first car).  He rejected the responsibility of the incident to our P1

20     commander.  The company commander asked him that his soldiers don't aim

21     anymore the UN personnel, this to decrease the tension.  The Arkan

22     soldiers did this but they succeeded to take three weapons of the

23     UN personnel (at the end of the incident they gave back these weapons)."

24             [Interpretation] This was paragraph 6.  Do you know, did you hear

25     that they had seized - albeit temporarily - some weapons from UNPROFOR

Page 9621

 1     soldiers?

 2        A.   I don't know anything about it.

 3        Q.   Mr. Hadzic, I already asked you about this but I'm going to go

 4     into more detail now.  The men who came with Badza and Badza himself, did

 5     they ask you where they could find accommodation?  And you said no.  I'll

 6     show you a document that has been reviewed at length during the trial.

 7             MR. ZIVANOVIC: [Interpretation] It's P194.140.

 8             JUDGE DELVOIE:  Tab number, please.

 9             MR. ZIVANOVIC:  Tab number 152.

10             JUDGE DELVOIE:  [Microphone not activated] Thank you.

11             MR. ZIVANOVIC: [Interpretation]

12        Q.   Have you seen this order?  I should like to ask you:  Have you

13     ever signed this order?

14        A.   Never.  And I never heard it -- saw it before The Hague.

15        Q.   The signature that you see on this document, is it yours?

16        A.   I believe so.

17        Q.   How do you explain your signature on this document, if you say

18     you had never seen it before coming to The Hague?

19        A.   I didn't sign it, but it doesn't mean that the signature is not

20     mine or very similar to mine.  I could have given an autograph to

21     somebody and then somebody could have copied it or placed it on a

22     different paper.  I don't know anything about forgery because I've never

23     forged anything myself, but I've never signed an order like this, and I

24     didn't know that the order existed.  And I never heard of these concepts

25     that are mentioned here.

Page 9622

 1             Starting from the top, for instance, the Secretariat of the

 2     President, did not exist at all.  All of it is completely false.  It's

 3     entirely a forgery.

 4             Then the next thing, I, as prime minister of the

 5     Autonomous District, I had no right to make such a decision without the

 6     government.  And also this concept:  Conclusions of staff commanders.

 7     I've never heard of such a thing.  During the entire war, I never heard

 8     of conclusions of staff commanders.  Even if we put this document aside,

 9     no such thing existed.  Staff commanders did not exist as an institute.

10     At least I never heard of it.

11             And if we look at the date, 21st September, Arkan was already at

12     the centre at that time.  He had already occupied it.  Why would he need

13     this paper?  All that I've said, I said as a layperson.  I'm not an

14     expert in these matters.

15        Q.   I believe there is a mistake in the translation of the first

16     sentence which reads:

17             "Pursuant to the headquarters commanders' conclusion ..."

18                           [Defence counsel confer]

19             MR. ZIVANOVIC:  Sorry.

20        Q.   [Interpretation] We'll come back to this part a bit later.

21             But something else I wanted to ask you.  The date here is the

22     21st of September, 1991.  Could you please tell me whether Arkan and his

23     unit had been in the centre already before that?

24        A.   As far as I can remember, they were in the centre perhaps seven,

25     eight, or even ten days before that.

Page 9623

 1        Q.   When Radovan Stojicic, Badza, arrived with him and when he

 2     introduced him to you, can you tell us, if you remember, what exactly did

 3     he tell you about Zeljko Raznjatovic, Arkan?  How did he present him to

 4     you?

 5        A.   I remember that he told me this, if I may quote him:  He will be

 6     the commander of special units.  But I didn't know whose units those

 7     were.  I didn't understand whether that will be the TO or the police or

 8     his own units.  I didn't understand that.  The only thing I understood

 9     was that there was some special units from Serbia.  But that's the extent

10     of my understanding at that moment.

11        Q.   Tell me one more thing:  At the time when this order was

12     allegedly drafted, according to the date on it, had the government

13     already been set up?  Was there a government of Slavonia, Baranja, and

14     Western Srem?

15        A.   No, not officially.  There was an Assembly on the 25th [as

16     interpreted] September and that's when the government was established.

17     I'm not sure that on -- on this particular day we already had stamps, but

18     it is possible that we did, on the 21st of September.

19             MR. ZIVANOVIC:  Mr. President, I think it is appropriate time for

20     the break.

21             JUDGE DELVOIE:  Thank you.

22             Court adjourned.

23                           --- Recess taken at 12.14 p.m.

24                           --- On resuming at 12.45 p.m.

25             JUDGE DELVOIE:  Please continue, Mr. Zivanovic.

Page 9624

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

 2             Mr. President, we noticed one error in the transcript.  It is on

 3     page 2, line 6, and line 14.  Namely, as a result of this error, the

 4     Defence document 1D762 was admitted as D124.  Actually, 1D275 had to be

 5     admitted as D124.

 6                           [Trial Chamber and Registrar confer]

 7             JUDGE DELVOIE:  Mr. Zivanovic, according to the Registrar's note,

 8     1D762 was shown on the screen and admitted.  Are you trying to convey

 9     that 1D725 was on the screen and admitted?

10             MR. ZIVANOVIC:  No.  The document 1D275 had to be admitted as

11     D124.

12                           [Trial Chamber and Registrar confer]

13                           [Defence counsel confer]

14             MR. ZIVANOVIC:  It ...

15             JUDGE DELVOIE:  Okay.

16             MR. ZIVANOVIC:  It is document --

17             JUDGE DELVOIE:  One moment, Mr. Zivanovic.

18             MR. ZIVANOVIC:  Sorry.

19             JUDGE DELVOIE:  We're just trying to get on the same path.  1D275

20     has indeed been shown but then 1D72 -- 1D ...

21                           [Trial Chamber and Registrar confer]

22             JUDGE DELVOIE:  1D7 -- then 1D762 was shown.  Now, when you

23     tendered -- you asked to -- that the document should be admitted, did you

24     mean 1D275 and we admitted 1D762.  Is that what happened?

25             MR. ZIVANOVIC:  That's correct.

Page 9625

 1             JUDGE DELVOIE:  That's what happened.  Okay.  If we substitute

 2     the admitted document, the result will be that 1D762 is not tendered and

 3     not admitted.  Is that what should happen?

 4             MR. ZIVANOVIC:  As far as I recall, 1D762 was shown to the

 5     witness, but, right now, I cannot recall what -- what is this document --

 6     what was this document.  So --

 7             JUDGE DELVOIE:  Okay --

 8             MR. ZIVANOVIC:  -- I double-check if --

 9             JUDGE DELVOIE:  Okay.  So --

10             MR. ZIVANOVIC:  -- we ask --

11             JUDGE DELVOIE:  -- for the moment --

12             MR. ZIVANOVIC:  -- for this document to be tendered.  Yes, we --

13     we'd like to have 2 -- 1D275 as D124.

14             JUDGE DELVOIE:  Okay.  Madam Registrar, can we substitute the

15     document and have 1D275 admitted and marked as 1D -- as D124.

16             So the answer is yes.  And then you take your time,

17     Mr. Zivanovic, to check what, if -- if anything needs to be done with

18     1D762.

19             MR. ZIVANOVIC:  Your Honour, I'll double-check it and --

20             JUDGE DELVOIE:  Okay --

21             MR. ZIVANOVIC:  -- get back to you.

22             JUDGE DELVOIE:  Yes.  Thank you.

23             MR. ZIVANOVIC:  Before I continue -- oh, sorry.

24                           [Trial Chamber confers]

25             JUDGE MINDUA: [Interpretation] I have a proposal.  Sometimes the

Page 9626

 1     Defence counsel or the Prosecutor present a document, first one and then

 2     the next one, and then they tender that document, and then the Registrar

 3     says the document is admitted but we don't know which one.  It is much

 4     better to first state the number of the document under which it is

 5     presently listed and then under the number which it is admitted.

 6             Would that be a suitable proposal?

 7                           [Trial Chamber and Registrar confer]

 8             JUDGE DELVOIE:  Could be a good suggestion, Mr. Zivanovic, that

 9     you and -- and OTP, if that's the case, would repeat the document number

10     that you asked to be admitted.

11             You may proceed.

12             MR. ZIVANOVIC:  Thank you.

13             Before I continue, I -- I would indicate to one translation error

14     in the document.  It is in first paragraph.  We submit that the part --

15     the part of sentence of the first sentence was not correctly translated.

16     It reads:

17             "Pursuant to the headquarters commanders' conclusion ..."

18             Namely, the translation booth correctly translate this part of

19     sentence at page 45, line 8.  It reads:

20             "Pursuant to the conclusions of commandants of the staffs."

21             MR. STRINGER:  We agree with that, Mr. President.  We looked at

22     it over the break and actually we've asked that the document be sent to

23     CLSS just to do a translation so that it's correct.  And when it is

24     received, we'll move to substitute it.

25             JUDGE DELVOIE:  Okay.  Noted.

Page 9627

 1             MR. ZIVANOVIC: [Interpretation]

 2        Q.   Mr. Hadzic, you said that there was no office of the president or

 3     a Secretariat.  Do you know if there was a Secretariat of the Government;

 4     do you remember?

 5        A.   There was the secretary of the government.  I don't remember

 6     whether he had an office or not.  I know that there was just one staff

 7     member and that was him, and I don't know whether there was anybody else.

 8        Q.   Could you please tell us his name.

 9        A.   His name was Jovica Pejakovic.

10             MR. ZIVANOVIC:  May we see P1809.

11             JUDGE DELVOIE:  Tab number, please.

12             MR. ZIVANOVIC:  [Microphone not activated] Sorry.  It is tab 406.

13     Sorry.  It is tab 406.  Thank you.

14             However -- however, we asked the -- the translation is not the

15     same as the original of document, because we asked translation of

16     assignment of Mr. Jovan Pejakovic.  It seem there is no such translation

17     of this document.

18             Okay.  We'll remove ...

19                           [Trial Chamber and Registrar confer]

20             JUDGE DELVOIE:  The Registrar tells me that there is only one

21     page in English and two in -- in B/C/S.  Would that explain the problem?

22     Or is the translation another document?

23             MR. ZIVANOVIC:  It seems that the decision on assignment of

24     Mr. Pejakovic was not translated, so I'll skip this document.  Or I -- I

25     could read just one sentence.  It is just one sentence of the document.

Page 9628

 1             JUDGE DELVOIE:  Mr. Stringer, would you have an objection to

 2     that?

 3             MR. STRINGER:  No, Mr. President.

 4             JUDGE DELVOIE:  Thank you.

 5             MR. ZIVANOVIC: [Interpretation]

 6        Q.   Mr. Hadzic, this is a decision on appointment.  Under 1 it says:

 7     Jovan I. Pejakovic, a lawyer by profession, is hereby appointed as the

 8     secretary of the government of the Serbian Autonomous District of

 9     Slavonia, Baranja, and Western Srem.

10             I'll skip Article 2 because it is not important.  And the date is

11     10 September 1991.

12             My question is this:  Do you remember this appointment?

13        A.   I do.

14             JUDGE DELVOIE:  Mr. Zivanovic, just to make sure, is what -- the

15     document you were just reading to Mr. Hadzic, is that the document we

16     have on the screen in B/C/S?

17             MR. ZIVANOVIC:  Yes.  Yes, Your Honours.

18             JUDGE DELVOIE:  Okay.  Okay.

19             MR. ZIVANOVIC: [Interpretation]

20        Q.   You spent a long time working with Mr. Pejakovic.  You knew him

21     well.  Would you say that Mr. Pejakovic would write in the heading "the

22     Secretariat of the Government" as we saw in the previous document?

23             MR. ZIVANOVIC: [Interpretation] Can we return the previous

24     document?  Can we bring it back on the screen.

25             JUDGE DELVOIE:  Mr. Stringer.

Page 9629

 1             MR. STRINGER:  Well, Mr. President, I was about to object to what

 2     sounded like a leading question in terms of how Mr. Pejakovic prepared

 3     the documentation that he wrote.  And I think it was suggesting to the

 4     witness that the documentation was prepared in a certain way rather than

 5     simply asking how Mr. Pejakovic prepared it.  Maybe I'm being

 6     oversensitive but I think that there was a suggestion.  And also I don't

 7     know that the witness has yet testified that he knew Mr. Pejakovic well

 8     and worked with him a lot, or words to that effect.

 9             JUDGE DELVOIE:  Could you --

10             MR. ZIVANOVIC:  The previous -- sorry.

11             JUDGE DELVOIE:  Yes, go ahead, Mr. Zivanovic.

12             MR. ZIVANOVIC:  The previous document just suggests what

13     Mr. Pejakovic was and that he was well aware of his position.  And I do

14     not really understand it as a leading question, but I could rephrase it

15     as well.

16             JUDGE DELVOIE:  I don't -- I don't think - and I think

17     Mr. Stringer pointed that out as well - that it is really a leading

18     question, but the foundation -- the foundation for the question would --

19     would be appropriate.

20             MR. STRINGER:  Apologise for the interruption, sincerely.

21             Just to inform the Chamber that the same decision on appointing

22     Mr. Pejakovic is in evidence at L57, which is the gazette in its

23     entirety, and so at page 14 of the English translation, the Chamber would

24     be able to actually see the decision in L57.

25                           [Trial Chamber confers]

Page 9630

 1             JUDGE DELVOIE:  We don't think that we need to have that on the

 2     screen, Mr. Stringer, but thank you for the suggestion.

 3             Mr. Zivanovic.

 4             MR. ZIVANOVIC: [Microphone not activated]

 5             JUDGE DELVOIE:  Microphone, please.

 6             MR. ZIVANOVIC:  May we see the previous document, 194.140,

 7     please.

 8        Q.   [Interpretation] Mr. Hadzic, in your presence, did

 9     Mr. Zeljko Raznjatovic, Arkan, ever introduce himself as the commander of

10     the special units of the Territorial Defence of the AO Slavonia, Baranja,

11     and Western Srem?

12        A.   Never.  He never introduced himself that way in my presence.

13        Q.   Do you have any explanation concerning this document?

14        A.   My explanation -- well, I'm going to say something now.  I'm not

15     sure whether it's relevant or not, but I think that Arkan didn't need

16     this document.  It was made later.  Perhaps for the purposes of some

17     defence here before this Tribunal.  But that is just my assumption.

18        Q.   Can you tell us something about whether the government of

19     Slavonia, Baranja, and Western Srem financed this centre of the

20     Territorial Defence or, rather, this unit that Zeljko Raznjatovic had?

21     Zeljko Raznjatovic, Arkan.

22        A.   The government of Slavonia, Baranja, and Western Srem did not

23     finance that centre or that unit.  Also, in my presence, the government

24     never discussed any of that.  I never heard anything like that.

25             MR. ZIVANOVIC:  May we see, please, P215.140.

Page 9631

 1             JUDGE DELVOIE:  Mr. Zivanovic.

 2             MR. ZIVANOVIC:  Oh, sorry.  It is tab 170.

 3             JUDGE DELVOIE:  With the microphone, please.

 4             MR. ZIVANOVIC:  Tab -- sorry.  Tab 170.

 5             JUDGE DELVOIE:  Thank you.

 6             MR. ZIVANOVIC: [Interpretation]

 7        Q.   You remember this document that was shown.  Can you tell us --

 8     actually, can you tell us whether you know anything about this problem

 9     that is referred to in this document?

10        A.   I first saw this document here.  I never knew anything about

11     this.  When I say "here," I mean the Prosecution.  I don't know whether

12     it was Investigator Vladimir Zuro [phoen] that showed it to me, but ...

13        Q.   Did you know that at some point in time, the expenses of the

14     government and of this centre were dealt with cumulatively, as is stated

15     in this document?

16        A.   I was not aware of that.

17        Q.   And did Zeljko Raznjatovic, Arkan, perhaps familiarize you with

18     that problem, that they tried to get him to pay for the expenses of the

19     government as well?

20        A.   Of course not.

21        Q.   Do you know whether the government of Slavonia, Baranja, and

22     Western Srem or later on, in general, Republika Srpska, or, rather, the

23     Republic of Serbian Krajina - sorry - whether -- whether they covered any

24     of the expenses of this unit?

25        A.   To the best of my knowledge, no, never.  I could hear about this

Page 9632

 1     in the media because Arkan bragged in public that he covered his own

 2     expenses, and I heard that several times.

 3        Q.   In which respect did he claim that?  How did you understand that?

 4     Did he provide an explanation?  How was it that he himself covered the

 5     expenses of this unit that had, say, 100 members, according to some of

 6     the information here?

 7        A.   Well, I can say how he explained it, and, of course, I can give

 8     you my understanding of that, if that is relevant.  He said that he is

 9     not anyone's burden in any way, that he finances his own unit through

10     sponsors from Serbia.  That was my understanding of it.

11        Q.   And did he ever ask for any kind of financial assistance or any

12     assistance from the government or from you personally?

13        A.   No, never.

14        Q.   Did Zeljko Raznjatovic, Arkan, attend meetings of the government

15     of Slavonia, Baranja, and Western Srem?

16        A.   He did not attend regularly.  Sometimes he would come in, spend a

17     few minutes there, and then leave.  According to what I remember, it was

18     very rarely.  It's not written here, but I said that when Badzo [as

19     interpreted] was present at a session.

20        Q.   Did he take part in the work of the government in any way through

21     some proposals of his, suggestions, requests?

22        A.   He did not take part.  And before the government sessions, he

23     never discussed the agenda with me.  He was simply not interested.

24        Q.   Did he ever say that the government should not make any decisions

25     before consulting him or Badza or some third person from Belgrade,

Page 9633

 1     something like that?  Do you remember whether any such thing ever

 2     happened?

 3        A.   I do not remember any such thing, and I don't think that anything

 4     like that ever happened.

 5        Q.   Two times you mentioned some conversation you had with him during

 6     the time of the Vance Plan, so now I'd like to ask you to tell us what

 7     that was all about, what kind of conversation this was.

 8        A.   I will try to explain briefly.

 9             It is well known that Milan Babic and the western Krajina

10     rejected the Vance Plan and that Slavonia, Baranja, and Western Srem

11     accepted the plan.  At the time, when this was in the making and when the

12     Vance Plan was being negotiated and when it was already known that Babic

13     would reject the plan, we in the eastern part had already agreed, my

14     ministers and I, that we would accept that.  However, we had not stated

15     that publicly yet.

16             Once Arkan came to see me unannounced and he started talking

17     about that plan, which took me by surprise because he never talked about

18     political developments.  As a matter of fact, I thought that he did not

19     even know what was going on in the political sphere at all.  Whenever he

20     was in contact with me, he always behaved as a big Serb, a big Serbian

21     patriot.  He never glorified Slobodan Milosevic.  I thought that he was

22     some kind of opposition to Milosevic.  I even thought that there could be

23     a problem with him if we were to accept that plan, that he could create

24     certain problems.

25             However, all of a sudden, he started threatening Babic in front

Page 9634

 1     of me, although Babic was not there.  Babic was in Knin.  And I remember

 2     what he said exactly.  I can even quote that.  He said:  What does

 3     Milan Babic think?  Does he know who it is that he is opposing and who it

 4     is that he does not want to obey?  He is not obeying our president,

 5     Milosevic.  That's the first time I heard that from his mouth, that he

 6     thought that Milosevic was his president.  He also said something else

 7     that surprised me even more.

 8             I saw something then that I hadn't seen before that and that I

 9     never saw after that in the case of any human being.  You could no longer

10     see the pupils of his eyes, the way he rolled them.  You could just see

11     the white, and he said:  Does Babic know that we are going to kill him

12     and all the children he has and all the relatives he has if he does not

13     accept that?

14             Then, in a way, everything was much clearer to me.  He didn't

15     address threats to me but to Babic, and then I understood there won't be

16     any problem because our government decided to accept the peace plan

17     because Arkan considered that should be accepted and that nobody would

18     have to kill my children.

19        Q.   At that time, was he already familiar with the position of your

20     government, although you hadn't publicly expressed it?

21        A.   I said at the beginning, if you followed me, that the position

22     was not yet known to Arkan or to official Belgrade.  It was a decision of

23     a narrow circle of ministers.

24        Q.   Could you please clarify what you've just said, that nobody would

25     kill your children.  What did you mean by that?

Page 9635

 1        A.   Well, I knew that my government would accept the plan.  We have

 2     already accepted it at that moment and there won't be any problem.

 3     Because I understood the message:  Whoever fails to accept the plan, his

 4     children would be killed.  That, in fact, was a message directed at me,

 5     not Babic, as I finally understood.

 6        Q.   During that conversation, did you understand the threat was

 7     serious, that he actually means it?

 8        A.   I understood it was very serious, 100 per cent serious.  And I

 9     thought at that moment that Arkan must have been sent by someone to tell

10     me that, but to this day, I don't know who it could be.

11        Q.   Do you know if he had a similar conversation with anyone else

12     from your government, for instance, or from your circle?

13        A.   Possibly.  Because I was very often away from Erdut, and it's

14     possible that he also talked to some ministers about the same conclusion,

15     that the plan needs to be accepted.

16             MR. ZIVANOVIC:  May we see P144, please.  It is tab 105.

17        Q.   [Interpretation] Do you remember this interview?  You had

18     occasion to read it here during the Prosecution case.

19        A.   I remember seeing it here, but I don't remember the interview

20     itself or the context in which I gave it originally.

21        Q.   Was it an authorised version of your interview?  In other words,

22     were you given this text to review before publishing?

23        A.   No, it wasn't.  I just talked to the journalist, and I'm not sure

24     that he even recorded it.  He only made notes.

25        Q.   Look at the third subheading in the English translation.  You

Page 9636

 1     were discussing the general situation in Slavonia, Baranja, and

 2     Western Srem, and you said -- it straddles page two in English.

 3             You describe the situation, but what I want to ask is this:  At

 4     that time, on 4 September, did you know what the general situation in

 5     that area was, and if you did know, what were your sources of

 6     information?

 7        A.   I was born in that area, and I knew the situation from before the

 8     war.  I knew which villages were Croat or Serb or mixed.  And the other

 9     information I obtained from media reports, to the extent I was able to

10     follow them, because I didn't have a special information service that

11     would keep me posted on the situation on the ground.  I also heard some

12     things from ministers who toured refugee centres, and I met with refugees

13     on the other side of the Danube myself.  And I had a lot of information

14     which was sometimes accurate, sometimes exaggerated.

15        Q.   You said, among other things, that the situation was the best in

16     Baranja, that 80 per cent of that territory had been liberated.  Did you

17     visit Baranja at some point during the month of August 1991?

18        A.   I'm not sure it was in August but perhaps early in September, I

19     went to Baranja once, when it was possible, before the Croatian authority

20     was established there.

21        Q.   You said, among other things, that the state of affairs was the

22     worst in Western Srem.  Did you have occasion to travel there?

23        A.   No, I didn't.  Because, as I heard towards the end of June or the

24     beginning of July, at the time of the attack at Tenja, there was also an

25     attack at Mirkovci village, and from that time until complete liberation,

Page 9637

 1     Mirkovci had been completely encircled for nine months.  That entire

 2     area, Mirkovci, Sidski Banovci, et cetera, they were isolated.  They

 3     couldn't go to our places, we couldn't go there.  They had a border -- a

 4     boundary with Vinkovci.  They couldn't go there.  And on the Serbian

 5     side, there was the village of Slakovci that was inaccessible to them, so

 6     they just couldn't -- had nowhere to go.

 7        Q.   You say, among other things in this interview, and I will quote

 8     this passage:

 9             "Croat old-timers, known as Sokci, are passive.  Croats,

10     Herzegovina men, Dalmatians, even Zagorje men, all of those who settled

11     there after 1941, they are very dangerous as they know that one of our

12     goals when we gain control is to return all Pavelic's volunteers, to turn

13     them back."

14             Can you tell us did you really put that way; and if you didn't,

15     what is this supposed to mean?  What did you exactly say?

16        A.   Well, it is certain that I didn't put it the way it is written

17     here.  I was explaining to the journalist that there had been no problems

18     between Serb old-timers and Croat old-timers who had lived in those areas

19     for hundreds of years, just as my family had.

20             You have to know that Slavonia and Baranja is a plain.  These

21     people are tamer and quieter, more peaceful.  The problems were caused by

22     Croats and Serbs from mountainous regions, such as Dalmatia, parts of

23     Bosnia, et cetera, and maybe he left out that part because he had some

24     vested interest of his own, and he left only this reference to Croats.

25     But it is certain that in my experience at least those people from

Page 9638

 1     mountainous regions tended to be more radical in their behaviour in 1991.

 2     More aggressive, perhaps.

 3        Q.   Below, talking about the JNA and the Serbian fighters, you say,

 4     among other things:

 5             "All of us, the government and primarily the people, are in

 6     favour of resolving this peacefully and democratically regardless of the

 7     fact that we have tragic experience with Ustashas from 1941.  We don't

 8     believe that the Croatian people are Ustashas.  We believe that there are

 9     good forces there who will understand our problems, who will understand

10     that we cannot live together anymore, that neither of them -- neither

11     them nor we want to live together anymore, that that must be resolved at

12     last.  We must draw the line."

13             Tell me, was it the stance of your government and your personal

14     stance?  And what did you imply?

15        A.   The stance of the Serbian Democratic Party from before the war

16     was common knowledge.  We discussed it yesterday and the day before

17     yesterday.  My stance was that we need to negotiate with the Croatian

18     side, and that was the reason why they attacked me or called me drugged

19     or a traitor.  That was the basic point.  All the other conclusions

20     follow from that.  I'm not sure I put it exactly that way, but I did

21     think that if Croatian people were allowed to determine their own fate

22     and what they were going to do and how they're going to live, Serbs

23     should be allowed to do the same.  People should not get killed over it.

24             I'm not quite sure that this interpretation is 100 per cent

25     accurate.

Page 9639

 1        Q.   In the box, under the subheading:  "The quota of slaughter" --

 2             MR. ZIVANOVIC: [Interpretation] That's on the following page in

 3     English.  Sorry, page 1.  It's the middle passage.

 4        Q.   You talk about information about the massacre of Serbs in

 5     Vukovar.  Can you tell us how you obtained that information?  Did you go

 6     to Vukovar at that time?  I mean, before, before this interview.

 7        A.   Of course not.  As I've already told you, I heard that from

 8     refugees or they learned that from their families and relatives.  But

 9     these are the conclusions reached by the journalist.  This is not my way

10     of expression.  I never used the word, I did not with an extra "I."  It's

11     his comment and his words.

12             MR. ZIVANOVIC:  It is the next page of translation, sorry.

13     Third page, sorry.  Third page of the translation.

14        Q.   [Interpretation] There's a title here:  With Serbia in

15     Yugoslavia.  The journalist asked you, amongst other things, or, rather,

16     he said that people hold it against you that you live in Novi Sad and not

17     in Slavonia, Baranja, and Western Srem.  You provided an answer.  Could

18     you tell us whether this answer reflects what you told the journalist?

19        A.   Yes, it does.  My children were refugees.  I didn't mention

20     Kragujevac, however, my children went there for sleep-overs with friends.

21     They didn't spend any time there as refugees.  The best illustration of

22     the way I was informed and how well I was informed at the time was the

23     fact that I didn't even have a telephone line at the time.  I expected

24     that it would be connected the following day but it didn't happen.  I

25     believe that this clearly illustrates the seriousness of my position.  I

Page 9640

 1     didn't have a telephone line; hence, I couldn't get by any information.

 2        Q.   Are you referring to your seriousness as a person or the

 3     seriousness of the institution that you represented?

 4        A.   No, not my personal seriousness but the seriousness of the

 5     government or the government in the making that I represented and the

 6     position that I held at the time.

 7        Q.   [Microphone not activated]

 8             THE INTERPRETER:  Microphone, please.

 9             JUDGE DELVOIE:  Microphone, please.

10             MR. ZIVANOVIC: [Interpretation]

11        Q.   There's also a reference to the problem which you had with the

12     idealogy and the symbols of that idealogy.  Could you tell us whether

13     your words are truthfully conveyed here; and if they are not, would you

14     please tell us what you actually said at the time?

15        A.   Well, when I reflect on that now, I know this newspaper.  I

16     believe that this is a Montenegrin newspaper, the official newspaper of

17     the Montenegrin government or the ruling party.  I believe that the

18     journalist was mindful not to say anything that didn't suit the

19     government in Montenegro.  At that time we did have some problems with

20     idealogy, especially at the beginning of that summer, the months of

21     June and July.  I had problems with Radojica Nenezic, as I've already

22     told you.  A lot more positive is said here about Communism than I would

23     every say or think.  I don't know whether the journalist misunderstood me

24     or whether he decided to misinterpret me ever so slightly.  Because I

25     believe that the five-pointed star was an ideological symbol; whereas it

Page 9641

 1     says here just the opposite, that I didn't consider it an ideological

 2     symbol.  Obviously we were talking at cross-purposes, the journalist and

 3     I.

 4        Q.   [Microphone not activated]

 5             THE INTERPRETER:  Microphone, please, counsel.

 6             MR. ZIVANOVIC: [Interpretation]

 7        Q.   And finally in this text you also spoke about the western

 8     borders --

 9             MR. ZIVANOVIC:  It is next page of translation.

10        Q.   [Interpretation] Inter alia, you said:

11             "The Ustashas have realised that we can no longer live together,

12     but they believe that they can deal with that by either killing us or

13     chasing us away."

14             Was that a general belief, i.e., that the extremists among the

15     Croatian forces really wanted to move the Serbs out of the area or kill

16     them if they didn't want to move out, whether that was the official

17     Croatian policy?

18        A.   With hindsight obviously we know much more.  You have a complete

19     picture of what happened in 1995.  I can only tell you what I thought in

20     1991.  We knew that during the Second World War the official policy of

21     the Ustasha government was to chase away one-third of the Serbs, kill

22     another third, and the last third of the Serbs were to be converted to

23     the Catholicism.  Obviously now all the cards are on the table, and the

24     third option was out of the window, so only the two options were still

25     viable and that was either for us to be killed or chased away.  And we

Page 9642

 1     said that we wouldn't accept any of the two and that we would fight for

 2     our rights.  And now whether I was right or wrong was later proved by

 3     what happened during Operation Storm in 1995.

 4        Q.   Mr. Hadzic, I wanted to move to another topic and that is the

 5     beginning of the month of September, when you had talks with some

 6     representatives of the international community who arrived in Slavonia,

 7     Baranja, and Western Srem.

 8             Can you tell us just briefly whether you remember any of those

 9     talks.  Who did you talk to?  Why?  What was the reason why you met them?

10        A.   I remember that I met with Mr. Henry Wijnaendts and Geert Ahrens.

11     They arrived from Belgrade, they had crossed the Danube river.  I can't

12     remember all of the topics, however, the main issue was to negotiate to

13     cease-fire and to sign a cease-fire with the Croatian side.  Before that,

14     several cease-fires had been signed but they all fell through.  Somebody

15     suggested - I don't know who - that I should put my name on a document of

16     that kind on behalf of the Serbian side, to reinforce that document.  I

17     thought that a cease-fire was absolutely necessary, that's why I

18     supported that idea.  I didn't see any harm in it.

19        Q.   Were there any problems during your talks with Messrs. Wijnaendts

20     and Ahrens?

21        A.   There were no problems during the talks.  The problem arose when

22     the document was put on the table before it was signed.  I was supposed

23     to sign it on behalf of the Serbian people and Vladimir Seks signed on

24     behalf of the Croatian parliament, I believe, or perhaps the Croatian

25     government.  I believe it was the Croatian government, not the

Page 9643

 1     parliament.  I apologise.  I didn't want to sign because there was no

 2     equality of arms.  He was not signing on behalf of the Croatian people

 3     but on behalf of the government; whereas I was supposed to sign on behalf

 4     of the entire Serbian people, not only the government.  So I refused to

 5     sign.  I gave them my condition but the negotiators did not accept my

 6     condition.

 7        Q.   When you say that Mr. Seks signed on behalf of the Croatian

 8     government, was he there?  How did he sign?

 9        A.   His signature was already on that piece of paper.  He himself was

10     not there, not in person, as far as I can remember.

11        Q.   And on that day but a bit later, did you, after all, sign this

12     agreement?

13        A.   Yes, at the end of the day, I did sign it.

14        Q.   Why did you change your mind?  How come you signed the agreement

15     after all?  First of all, what was the essence of that agreement?  Was

16     the document acceptable or unacceptable for you?

17        A.   The agreement was good for us.  The gist of it was to cease-fire

18     and that was the most important thing, to stop people dying.  In my view,

19     this was just a technical matter.  However, I could not sign on my own

20     behalf.  I had associates with whom I had to consult.  I didn't do

21     anything on my own, neither as the president of the SDS, let alone as the

22     prime minister of Slavonia, Baranja, and Western Srem.

23             This was a utopian position, a majority of the minister thought

24     if that I signed as the representatives of the government, the

25     international community would recognise us.  I thought that it was

Page 9644

 1     nothing but pure utopia.  They insisted I sign but I couldn't because I

 2     didn't have the mandate to sign any such document.

 3             And then somebody in that delegation - I believe that it was

 4     either Mr. Wijnaendts or somebody who had come with him - made a break

 5     and consulted somebody in Belgrade.  I was called to come to the phone in

 6     the elementary school in Borovo Selo.  That's where the troops were.

 7     That was the first time I went in.  I often passed by but I never went

 8     into the school.  I went upstairs to the first floor.  There was a

 9     communications centre there.

10             They gave me a -- a telephone, a metal telephone, like a field

11     telephone, and they told me:  Slobodan Milosevic wants to talk to you.

12     And I thought that they were pulling my leg.  I answered.  I recognised

13     his voice from television.  He spoke to me very kindly as if we had known

14     each other for a long time.  He asked me what the problem was.  I told

15     him.  And then he said:  Why is that a problem?  It's better for you to

16     be the representative of the people.  That's much broader than being just

17     representative of the government.  He tried to persuade me, but that was

18     not necessary because I was already convinced that that agreement should

19     be signed because it was a cease-fire agreement and that couldn't be bad.

20     And then he said:  Come on, sign this.  Let's start living in peace.

21     We've had enough of war.  So I said:  Okay, I will.

22             And then I returned to a group of my associates who were there.

23     I communicated that position to them, especially to those who were

24     against me signing that document at first.  I told them that I'd spoken

25     with Slobodan Milosevic and that it is in the interests of Belgrade,

Page 9645

 1     Serbia, and the SFRY as well as our -- ours to sign that document.  Then

 2     they changed the mandate that they had given me in order to allow me to

 3     sign that document, which is what I eventually did.

 4             MR. ZIVANOVIC:  Mr. President, I think it is appropriate time for

 5     break.

 6             JUDGE DELVOIE:  Yes, Mr. Zivanovic.  Thank you very much.

 7             We'll adjourn till tomorrow morning, 9.00.  Mr. Hadzic, I remind

 8     you that you're still under oath.

 9             Court adjourned.

10                           [The witness stands down]

11                            --- Whereupon the hearing adjourned at 1.59 p.m.,

12                           to be reconvened on Thursday, the 10th day of July,

13                           2014, at 9.00 a.m.