Tribunal Criminal Tribunal for the Former Yugoslavia

Page 10686

 1                           Monday, 1 September 2014

 2                           [Open session]

 3                           [The accused entered court]

 4                           [The witness takes the stand]

 5                           --- On resuming at 9.01 a.m.

 6             JUDGE HALL:  Good morning to everyone.

 7             Before I invite the Registrar to call the case, let the record

 8     reflect that we reconvene this morning under Rule 15 bis, Judge Delvoie

 9     being absent.

10             Yes, Mr. Registrar.

11             THE REGISTRAR:  Thank you.  And good morning, Your Honours.

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

13             JUDGE HALL:  Thank you.

14             May we have the appearances, please.

15             MR. STRINGER:  Yes.  Good morning, Your Honours.

16             For the Prosecution, Douglas Stringer, Ms. Clanton; Case Manager,

17     Thomas Laugel; and legal intern, Moritz von Normann.

18             JUDGE HALL:  Thank you.

19             For the Defence.

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

21     Goran Hadzic, Zoran Zivanovic and Christopher Gosnell.

22             JUDGE HALL:  Thank you.

23             Before I invite Mr. Stringer to resume his cross-examination, I

24     give Mr. Hadzic the usual reminder that you're still on your oath.

25             Yes, Mr. Stringer.

Page 10687

 1             MR. STRINGER:  Thank you, Your Honour.  And before I begin, I

 2     have just a couple of preliminary or housekeeping matters that I wish to

 3     address with regard to Mr. Hadzic's cross-examination and its completion

 4     today.  The first of those is that over the course of the

 5     cross-examination, there are some number of documents, probably five

 6     maximum, that I failed to tender into evidence after having discussed it

 7     with Mr. Hadzic.  And rather than going back to those taking the time to

 8     look at the record from before and to see what was said about them, the

 9     request would be to seek the Chamber's leave to simply file a motion or

10     to tender them by way of a written motion.  We could provide all the

11     record references to the Chamber and perhaps might be a more efficient

12     way of dealing with that.  That was the first request I had and then I

13     also did want to tender --

14             JUDGE HALL:  Sorry, before you move on to the second matter --

15             MR. STRINGER:  Yes.

16             JUDGE HALL:  -- I suppose what you have suggested would work, but

17     would an alternative be, if, for example, during a break you and the

18     Defence would get together and agree that the documents should be

19     tendered to save you the exercise of doing a written motion?  I don't --

20     I don't except that answer now but something that you and Mr. Zivanovic

21     can consider.

22             MR. STRINGER:  Certainly, Your Honour.  I'm happy to raise it

23     with Mr. Zivanovic during the break and see whether we can reach some

24     resolution on that.

25             MR. ZIVANOVIC:  As to the first matter, I would say that we would

Page 10688

 1     prefer the written motion.

 2             JUDGE HALL:  You don't want to think about it?  You may after

 3     discussion see that there is nothing to concern you.  That's why I

 4     suggested that alternative.

 5             MR. ZIVANOVIC:  I -- I think that there are more than one

 6     document and I'm afraid that we will not be able to see all it and to --

 7     to -- think about all of it just during the break.  But I'll try.

 8     Anyway, I'll --

 9             JUDGE HALL:  I said during the break.  I didn't mean during the

10     ordinary -- necessarily during the 30-minute break.  I mean, for

11     instance, tomorrow.

12             MR. ZIVANOVIC:  That's -- that's better option.  Thank you.

13             JUDGE HALL:  Thanks.

14             MR. STRINGER:  We could even draft the motion and provide it to

15     counsel, Your Honour, and then depending on how that goes either we will

16     file it or we'll present some sort of a resolution to the Chamber.

17             Your Honour, the next item was to actually tender into evidence

18     Exhibit 65 ter 6561 which is now given an MFI number.  This was the one

19     that I tendered last week.  Mr. Zivanovic pointed out that the Defence

20     had request from the Prosecution information about the chain of custody

21     and where had it come from.  And that information was provided to

22     Mr. Zivanovic yesterday, and I don't know what the Defence's position on

23     that is, but we wish to tender that at this time now.

24             JUDGE HALL:  Mr. Zivanovic.

25             MR. ZIVANOVIC:  I just started to -- to write e-mail to


Page 10689

 1     Mr. Stringer on his inquiry.  I got it this morning.  We'd like to

 2     double-check, actually, whether this document was indeed provided from

 3     the Serbian government or not.  This -- the document, as far as I recall,

 4     was not complete, and I'd like to -- to double-check it before I give my

 5     consent.

 6             JUDGE HALL:  Fair enough.

 7             MR. STRINGER:  Third item, preliminarily, Your Honour, and I

 8     don't know whether it would be necessary entirely, but I do wish to

 9     respectfully request up to an additional 30 minutes to complete the

10     cross-examination this morning.  There are a number of loose items that

11     I'd actually like to go back to -- to clarify with Mr. Hadzic as well as

12     a couple of ones that were always on my list.  But, in any event, the

13     request is if the Chamber would consider allowing us an additional 30

14     minutes this morning, which I think I would make for a total of 70

15     instead of where we are now at 40.

16                           [Trial Chamber confers]

17             JUDGE HALL:  Leave was prayed, Mr. Stringer.

18             MR. STRINGER:  Thank you, Your Honour.

19                           WITNESS:  GORAN HADZIC [Resumed]

20                           [Witness answered through interpreter]

21                           Cross-examination by Mr. Stringer: [Continued]

22        Q.   Mr. Hadzic, just a couple of quick questions and I'm going to go

23     through a number of things that relate to matters that were already

24     mentioned during your cross-examination or otherwise.  The first couple

25     of questions at page 9425 of the transcript, you were talking -- this was

Page 10690

 1     in your direct examination, I believe.  You were talking about the events

 2     in Plitvice at the beginning of April, end of March 1991, when you were

 3     arrested.  And you indicated that at the time you were arrested they took

 4     away your papers, some of your personal items, and that you subsequently

 5     went back to Zagreb in order to try to get those items back from the

 6     police.  And you indicated that when you went back to the police in

 7     Zagreb to get those things, you went with a friend of yours.  And the

 8     question is:  Who is the person who accompanied you when you went back to

 9     Zagreb for those things?

10        A.   This is a friend of mine from school, otherwise from my village,

11     my generation, born the same year, his name is Marko Alavana.

12        Q.   Another question I wanted to follow up on was -- this is at

13     page 10252 of the transcript on your cross-examination.  You made

14     reference to your secretary and your driver.  This is during the period

15     when you were president of RSK.  The question here is:  Who was your

16     secretary during that period of time?

17        A.   There was lady from Knin.  Her name was Nena Sain.  That's still

18     her name.  She is still alive.

19        Q.   Was she -- did you have a secretary or an administrative

20     assistant during the SBWS phase in 1991 when you were at the government

21     offices in Erdut?

22        A.   I did not have a secretary in Erdut at the government there.

23     There was just the secretary of the entire government, Mr. Pejakovic, but

24     he acted not as my secretary but as secretary of the entire government.

25        Q.   Thank you.

Page 10691

 1             MR. STRINGER:  Your Honour, one other item relates to

 2     Exhibit 65 ter 1458, which I don't think we need to bring it up.  We

 3     had -- we had during the hearing -- it's a confidential FBIS document and

 4     what we've done now is to actually redact it.  It was dealt with in the

 5     hearing as a confidential document in private session, and so we have now

 6     made a redacted version and we would now re-tender or we would tender

 7     65 ter 1458 into evidence as redacted.

 8             JUDGE HALL:  Does the Defence have any objection?

 9             MR. ZIVANOVIC:  We just like to see this document because I

10     cannot --

11             MR. STRINGER:  We can -- if the Registrar could bring it up then.

12             MR. ZIVANOVIC:  No objection.  Sorry.  No objection, Your Honour.

13             JUDGE HALL:  Did I understand you, Mr. Stringer, to say

14     re-tender?  Do I understand you refer to the 65 ter number was it ever

15     exhibited?

16             MR. STRINGER:  No.  In fact, I did not tender it at the time,

17     Your Honour.  And so when I just said re- tender, I misspoke.  It wasn't

18     tendered.  It was dealt with in the hearing confidentially and we are

19     tendering it now as redacted.

20             JUDGE HALL:  Admitted and marked.

21             THE REGISTRAR:  As Exhibit P3234, Your Honours.

22             MR. STRINGER:  And just for completeness, Your Honour, the

23     Prosecution can inform the Chamber of the corresponding pages of the

24     transcript that were in private session and if it is minded to then could

25     make those pages now public as well since the document is public as

Page 10692

 1     redacted.

 2             JUDGE HALL:  Yes.  So ordered.

 3             MR. STRINGER:

 4        Q.   Mr. Hadzic, just one other -- actually, not the last

 5     clarification.  But one clarification regarding when you had your first

 6     meeting with Slobodan Milosevic.  And because in your direct examination,

 7     this was on the 4th of July, at page 9387, your counsel, Mr. Zivanovic,

 8     asked you about having -- when did you meet Mr. Milosevic.  And you

 9     mentioned that you saw Slobodan Milosevic at a short meeting with the

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

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

12     Spiegel movie.  And you went on to say that this could have been a month

13     before Plitvice, perhaps a bit more than that; is that correct?  Is that

14     your best recollection of your first time to meet Slobodan Milosevic?

15        A.   Well, I think it was the end of February 1991 but I didn't talk

16     to him then.

17        Q.   And the reason I ask it is because then a few days later, on the

18     10th of July, it came up again during your direct examination, and this

19     is what you said.  Again on when did you meet Slobodan Milosevic, you

20     said:

21             "I've already mentioned that before that I had one contact.

22     Perhaps in the month of September 1991 when Professor Raskovic called me

23     from Knin to be on this delegation of the Serb Democratic Party."

24             And I don't know whether you misspoke there or whether this is

25     what you intended to say or what was interpreted, but this is in the

Page 10693

 1     record.  Now it says September 1991 and I wanted to clarify that, in

 2     fact, it was earlier as you've just indicated, in February or so?

 3        A.   Yes.  Raskovic invited us.  That was the end of February 1991.

 4     And the first time I spoke to him in my life was in September but that

 5     was over the telephone.

 6        Q.   And that was the conversation you describe that was related to

 7     the negotiations in Borovo Selo with Mr. Wijnaendts?

 8        A.   Right.

 9        Q.   The next item, Mr. Hadzic, if we could bring up, please,

10     Exhibit 65 ter 4869.4.

11             Now, Mr. Hadzic, this is a still photograph that comes from the

12     video that we looked at just, I think, on Thursday of last week; the

13     video being P244.  Do you remember us looking at this?

14        A.   I remember.

15        Q.   And there was a little bit of discussion or confusion about the

16     name of this gentleman, and I wanted to try to clarify this a little bit.

17             We're looking here at the television broadcast with the Cyrillic

18     script.  Can you just read what the Cyrillic script says in the photo

19     that we're looking at.

20        A.   I can read it.  I would have made a mistake once again.  Again,

21     it's a question of perception, as they say.  So this is what it says

22     precisely:  Zeljko Filipsic.  It is a very unusual surname, so you assume

23     that it is the more usual form that we know.  So it is Zeljko Filipsic

24     from Bilje.

25        Q.   All right.

Page 10694

 1             MR. STRINGER:  And this is more sort of a record clarification,

 2     if I may, Mr. President.  I'm looking at page 10671.  Because during the

 3     course of our discussion on -- on this video, Mr. Hadzic, the name

 4     Filipovic worked its way into the transcript, and actually it's indicated

 5     there that I was suggesting to you that this is someone named Filipovic.

 6     And if I said that, I misspoke, because I was intending to suggest that

 7     it was someone named Filipcic.

 8             So can we agree that in fact at least according to what we see on

 9     the image here the name attributed to this person is Filipcic?

10        A.   As I've already said, what is written here is Zeljko Filipsic.

11     So I agree it is not Filipovic.

12        Q.   The next item, Mr. Hadzic, again, this relates just to the

13     cross-examination --

14             JUDGE HALL:  Yes, Mr. Zivanovic.

15             MR. ZIVANOVIC:  I see in the line 9 -- in the -- at the page 9

16     line 1, again, the error in -- in the last name of the witness.  It is

17     stated "Filipcic" instead "Filipsic."

18             MR. STRINGER:

19        Q.   Mr. Hadzic, perhaps -- could you -- well, first of all, do you

20     know the gentleman whose image we see in this photograph?

21        A.   No.

22        Q.   Could you just spell the name as it appears on the image.  Just

23     give us the letters.

24        A.   In Serbian you mean, in my language?

25        Q.   Yes.

Page 10695

 1        A.   F-i-l-i-p-s, with a diacritic which is sh, i-c with a diacritic

 2     ch.  Maybe it would be easier for the interpreters if I would do it in

 3     the Latin script rather than Cyrillic?

 4        Q.   Please.

 5        A.   F-i-l-i-p-s, with a diacritic, i-ch which is c with a diacritic.

 6        Q.   Thank you.

 7             MR. STRINGER:  And before I forget, Mr. President, Your Honour,

 8     we would tender this into evidence, this 65 ter 4869.4.

 9             JUDGE HALL:  Admitted and marked.

10             THE REGISTRAR:  As Exhibit P3235, Your Honours.

11             MR. STRINGER:

12        Q.   Mr. Hadzic, last week on Thursday we were discussing two of the

13     incidents that are referred to in the indictment.  The first of which

14     related to the disappearance of people from the Dalj Planina region, the

15     Hungarian people, the names Pap came up during the course of that, and I

16     actually want to clarify or correct a mistake that I made that I think

17     was confusing to you because I didn't put it to you correctly, and so I

18     want to correct my mistake and ask you to comment on it.  We were

19     referring also to your suspect interview that you gave to Mr. Dzuro back

20     in 2002, and at that time, you had told him that in regard to Hungarian

21     people living in that area, the Dalj Planina area, you knew someone whose

22     nickname was Sabonija; correct?

23        A.   You mispronounced it.  The nickname is Sobonja.

24        Q.   Thank you.  And in my cross-examination, I was suggesting that he

25     was a member of the Pap family and you were disagreeing with me.  And


Page 10696

 1     just to make it correct, this gentleman, Sobonja, was, I believe you

 2     said, the brother or he was related to someone -- a person who actually

 3     testified in this trial.

 4             And if we could briefly go into private session, Your Honour.

 5             JUDGE HALL:  Yes.

 6                           [Private session]

 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   (redacted)

25   (redacted)

Page 10697











11 Page 10697 redacted. Private session.















Page 10698

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 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   (redacted)

25                           [Open session]


Page 10699

 1             MR. ZIVANOVIC:  I think I indicated -- I already indicated that

 2     at this point --

 3             JUDGE HALL:  Mr. Zivanovic, just a moment, please.

 4             THE REGISTRAR:  Your Honours, we're in open session.

 5             MR. ZIVANOVIC:  Sorry.

 6             JUDGE HALL:  Yes, Mr. Zivanovic, please continue.

 7             MR. ZIVANOVIC:  I think that I already indicated that this part

 8     of interview was given when Mr. Hadzic was provided with Milosevic

 9     indictment and all his answers follows from the -- from Milosevic

10     indictment.  I said that I will clarify it during my re-direct.  We

11     discussed it, as far as I recall, two or three days ago or something like

12     that.

13             JUDGE HALL:  So do I understand your position to be that you have

14     no difficulty with the proposal, well, the application, to tender the

15     written document for the sake of tidiness, if nothing else?  And as

16     Mr. Stringer has said, it is intended solely for impeachment purposes as

17     a previous inconsistent statement.

18                           [Defence counsel confer]

19             MR. ZIVANOVIC:  Your Honours, may I see again this portion of --

20     of the exhibit before I take the position.

21             MR. STRINGER:  65 --

22             JUDGE HALL:  I was going to suggest that perhaps we could defer

23     this application until after the break.  Perhaps Mr. Zivanovic could look

24     at it during the break and we could return to it then.

25             MR. STRINGER:  Yes, Your Honour.  That's fine.  We're talking

Page 10700

 1     about two incidents here, one is referred to in paragraph 27 of the

 2     indictment.  The other one relates to the Klisa, the people who came from

 3     Klisa, and that's in paragraph -- that's the incident at paragraph 29.

 4     Just -- just so Your Honour knows, in the paragraph 27 incident,

 5     Mr. Dzuro was not referring to the Milosevic indictment.  He was actually

 6     reading Mr. Hadzic part of a witness statement.  It was only in regard to

 7     the paragraph 29 Klisa incident in which Mr. Dzuro read or had Mr. Hadzic

 8     read part of the Milosevic indictment.  And he also read a different

 9     witness statement.

10             And so it's a little bit complicated.  But, in any event, we'll

11     provide this to counsel.  We'll confer and perhaps we can reach an

12     agreement.

13        Q.   Mr. Hadzic, in your direct examination on the 14th of July, you

14     were asked about Ilok, and your counsel asked:

15             "Did you or the government enter Ilok or go to Ilok after the

16     Croats had moved out?  Did you establish any organs of SBWS there at the

17     time in this territory?"

18             And your answer was:

19             "No, we didn't establish any organs of power or authorities.  We

20     did not have physical access at the time.  We couldn't reach it.  There

21     was military administration in Ilok.  It was completely sealed off."

22             Do you recall that testimony?

23        A.   I remember when Croatians left, the military took over and

24     occupied everything.

25        Q.   And then on page 9726 again your counsel asked:

Page 10701

 1             "Were you in Ilok or in the rounding area when the Croats were

 2     moved out of Ilok?"

 3             And you said:

 4             "No, I wasn't either in Ilok or in the surrounding area and I did

 5     not have any information about this, any direct information, except for

 6     what I learned from the media."

 7             Do you remember that?

 8        A.   I remember that.

 9             MR. STRINGER:  Now, if we could please have tab -- from tab 1087.

10     This is 65 ter 4974.06.

11        Q.   You were asked about Ilok and whether you went there by

12     Mr. Dzuro, Mr. Hadzic, and I want to show you the answer you gave at that

13     time.

14             MR. STRINGER:  If we could go to page 51 of this.

15        Q.   Mr. Dzuro asked --

16             MR. ZIVANOVIC:  Excuse me.  May we see B/C/S text, please, at the

17     screen.

18             MR. STRINGER:  I'll give that page number just as soon as I've

19     got it, Your Honour.  I don't have it at the ready.

20                           [Prosecution counsel confer]

21             MR. STRINGER:  The B/C/S of this is in e-court, this document.

22     It should be available.

23             Perhaps we can try this.  If we could try 4974.06C, the letter C.

24     It's a shortened version.  It might have the redaction on it that the

25     Chamber indicated it wished to avoid, but it might at least move things

Page 10702

 1     along quickly, more -- more quickly.  Looks like we're there.

 2        Q.   Mr. Hadzic, I'm looking obviously at the English, and about

 3     two-thirds of the way down the page Mr. Dzuro asks:

 4             "Back to Ilok.  Did you -- did you go to Ilok after it was taken

 5     over by the JNA?"

 6             And your answer was:

 7             "I said that I passed through Ilok.  So, I did go?"

 8             Vladimir Dzuro then asks:

 9             "Did you go to Ilok right after the Croats left on the

10     17th of October, 1991?"

11             JUDGE HALL:  Yes, Mr. Stringer, please continue.  I'm having a

12     little technical problem here but that shouldn't interfere with you're

13     continuing.

14             MR. STRINGER:  Very well, Your Honour.

15        Q.   Mr. Hadzic, so Mr. Dzuro then asks:

16             "Did you go to Ilok right after the Croats left on the 17th of

17     October, 1991?"

18             And again your answer:

19             "I don't remember having gone there immediately afterwards,

20     meaning within a period of two or three days, but maybe in a week or ten

21     days.

22             "I remember having met with Colonel Grahovac, who was the

23     commander there.  But it was just a courteous conversation, because Ilok

24     was under military administration."

25             MR. STRINGER:  And then we can go to the next page so that every

Page 10703

 1     can see that's pretty much the end of your answer on Ilok.  But if we

 2     could take a quick look at page 52?

 3             THE REGISTRAR:  Mr. Stringer, it's a one-page document.

 4             MR. STRINGER:  Oh.  Okay.

 5        Q.   So, Mr. Hadzic, actually despite what you indicated in your

 6     direct examination, you did, as you told Mr. Dzuro, go and have the

 7     ability to go down to Ilok within a week to ten days after the Croat

 8     population left there in mid-October.  Isn't that true?

 9        A.   That's not correct, Mr. Prosecutor.  You made a mistake.  And you

10     can see that in the terminologic discussion that I had Dzuro.  I said

11     that I passed through Ilok, and according to that logic your -- the

12     answer to your question would be yes because I passed through Ilok, but I

13     couldn't pass through Ilok before 20th of October when Vukovar was

14     liberated.  When I went from Pacetin to Vukovar, it was only then that I

15     could pass through Ilok.  And I said that I could -- didn't do it within

16     a short space of time.  It must have been later.  It must have been

17     perhaps within 15 or 20 days.

18             I did not finish.  So it could be 15 or 20 days later but

19     obviously it must have been more than a month.  I happened to meet

20     Colonel Grahovac by chance and we spent about a couple of minutes talking

21     in the street.

22             MR. STRINGER:  Your Honour, the Prosecution would tender this

23     excerpt from the suspect interview, 4974.06C.

24             JUDGE HALL:  If I may have a moment, please.

25             Yes, Mr. Stringer.  Please continue.

Page 10704

 1             MR. STRINGER:  Your Honour, just a moment ago I was going to

 2     tender this excerpt into evidence, but I'm not going to do that actually.

 3     I've read the relevant passages from the suspect interview into the

 4     record and put those to Mr. Hadzic, and so I think that the record is

 5     sufficient on that issue.

 6             JUDGE HALL:  Please continue.

 7             MR. STRINGER:

 8        Q.   Mr. Hadzic, can we agree that back in 2002 you told Mr. Dzuro

 9     that, in fact, it was seven to ten days, a week to ten days after the

10     Croats left Ilok that you went down there?

11        A.   I didn't say that.  Mr. Dzuro asked me whether I had arrived in

12     Ilok immediately after Croats left it.  I said no.  I said I certainly

13     didn't do it within a couple of days.  I told him that it was later and I

14     can see now that I gave him a period of time that is certainly shorter

15     than it -- it actually was.

16        Q.   Well, just to make sure we're all able to know what it was you

17     said to Mr. Dzuro, Mr. Hadzic, let's just play the corresponding video

18     from the suspect interview for this part.

19             MR. STRINGER:  And for the interpreters, this is 4974.06C, as in

20     Charlie.  We'll wait to -- for them to let us know when they're ready.

21             THE INTERPRETER:  We are ready.

22                           [Video-clip played]

23             "Vladimir Dzuro:  Back to -- back to Ilok.  Did you -- did you go

24     to Ilok after it was taken over by the JNA?

25             "Goran Hadzic:  So I did not --

Page 10705

 1             "Vladimir Dzuro:  Did you go to Ilok right after the Croats left

 2     on the 17th of October, 1991?

 3             "Goran Hadzic:  I don't remember having gone there immediately

 4     afterwards, meaning within a period of two or three days, but maybe in a

 5     week or ten days.

 6             "I remember having met with Colonel Grahovac, who was the

 7     commander there.  But it was just a courteous conversation because Ilok

 8     was under military administration."

 9             MR. STRINGER:

10        Q.   So, Mr. Hadzic, now having seen that, does that remind you of

11     what you said to Mr. Dzuro?  You went down there seven to ten days after

12     the 17th of October, 1991?

13        A.   I heard seven to ten days in the interpretation.  I don't know

14     whether you are doing this on purpose or you just didn't hear me saying

15     on the video that I went there within ten to 15 days.

16        Q.   Well, I hate to spend more time on this, but perhaps this time we

17     could re-play the video, and if it's possible for the interpreters to

18     take Mr. Hadzic's question on the video and to indicate whether the

19     interpretation given in the interview by that interpreter is -- is

20     correct or not because, clearly, we've got a week to seven days in --

21     in -- in our interpretation.

22             JUDGE HALL:  So could we have the video re-played, please, with

23     the interpretations Mr. Stringer has suggested.

24                           [Video-clip played]

25             "Vladimir Dzuro:  Back to -- back to Ilok.  Did you -- did you go

Page 10706

 1     to Ilok after it was taken offer by the JNA?

 2             "Goran Hadzic:  I said that I did pass through Ilok.  I did go.

 3             "Vladimir Dzuro:  Did you go to Ilok right after the Croats left

 4     on the 17th of October, 1991?

 5             "Goran Hadzic:  I don't remember that I went immediately after

 6     that.  I believe that I went after 10 to 15 days.  Within a period of two

 7     or three days but maybe in a week or ten days.

 8             "I remember that I met with Colonel Grahovac" --

 9             MR. ZIVANOVIC:  Sorry, it was an error in interpretation of

10     interpreter who was present to the meeting, because Mr. Hadzic did not

11     mention week.  He said ten to 15 days.

12             MR. STRINGER:  And that I believe's what the interpreters gave us

13     Your Honour, and so we will take that as the answer.

14        Q.   Mr. Hadzic, you were in Ilok by early November then 1991?  You

15     had the ability to go to Ilok by early November, ten to 15 days after the

16     17th of October?

17        A.   This is not correct.  I have already answered that question.

18     Mr. Dzuro asked me and I answered from the top of my head without really

19     thinking.  I did not have anything to hide, but I said it clearly now

20     that I answered Mr. Dzuro that I passed through Ilok.  I couldn't do that

21     before the 20th of October.  I couldn't pass through Ilok because there

22     was fighting going on for Vukovar.  When I said after ten to 15 days, I

23     should have said after a month.  That was my mistake.

24             MR. ZIVANOVIC:  Sorry, again, it's page 21, line 4 -- line 3,

25     sorry, Mr. Hadzic mentioned November, not October.

Page 10707

 1             JUDGE HALL:  Mr. Hadzic, could you repeat your answer to

 2     Mr. Stringer's question, please, if you remember it.

 3             THE WITNESS: [Interpretation] I remember.

 4             And now I'm going to repeat for the third time.  In the interview

 5     I could not define the time very precisely.  This is my problem.  I could

 6     not pass through Ilok before the 20th of November when the passage

 7     through Vukovar became free because you have to go through Vukovar, Ilok,

 8     Backa Palanka, and then to Novi Sad.  I could not pass through Ilok

 9     before the 20th of November.  When Dzuro put that question to me, I

10     provided a hasty answer.  I did not know that he was implying a -- that

11     there was a meeting of some sort there, so my answer to Mr. Dzuro's

12     question was not really precise.

13             MR. STRINGER:  Could we please have P61.50, tab 111.

14        Q.   Mr. Hadzic, this is an item again that -- I'm going back to your

15     direct examination.  This is a form that you testified about on your

16     direct examination, the form that was submitted in Vukovar on the

17     formation of the Serbian Democratic Party in August of 1990.  Do you

18     remember seeing this form on your direct?

19        A.   I remember that.

20        Q.   And in your direct examination, it was -- you observed that

21     although the date of the signature there in August of 1990 is actually

22     after the date of the form, the printed form from June of 1990, and we

23     weren't clear whether you were suggesting that there was some problem in

24     terms of the authenticity of this document.  Are you challenging the

25     authenticity of this document?

Page 10708

 1             MR. ZIVANOVIC:  Sorry, it is not the date of the form.  It is the

 2     header of Official Gazette of Croatia at the very top of this page.

 3             MR. STRINGER:  Well, the heard it says 25 June 1990; is that

 4     correct?

 5             MR. ZIVANOVIC:  Correct.

 6             MR. STRINGER:

 7        Q.   And on your direct examination, Mr. Hadzic, you observed that the

 8     Gazette was from June of 1990, although it had your -- the form in it

 9     from August and we weren't sure whether you were somehow contesting this

10     form or its authenticity.  So that is my question now:  Do you challenge

11     this form?  Is there something irregular about it, in your view?

12        A.   To my best recollection, as the president of the Municipal Board,

13     it was my duty to register in the state where I was that was Croatia

14     within SFRY.  I did it in the municipality of Vukovar, and now I really

15     can't tell you why there is a problem with the date, why this was done in

16     this way.  In any case, this is my signature.  I'm not denying that.

17             MR. STRINGER:  Well, let's just take a moment and go to tab 1686

18     which is 65 ter 6553.  I'm going suggest to you what happened here.

19             And, Your Honour, what we're seeing in the English is - when it

20     comes up -- is we're seeing the English translation of a blank form with

21     25 June 1990 in the header.  And if we could go to the last page of this

22     Gazette in the B/C/S version.

23        Q.   So, Mr. Hadzic, are we seeing -- are -- I know perhaps you don't

24     want to say whether the B/C/S corresponds to the English that we're

25     seeing on the screen, but let me just put it to you that what happened is

Page 10709

 1     that the forms for various registrations were published in the Gazette in

 2     June of 1990, the blank forms, and that what you then did was to take the

 3     blank form from June of 1990 when it was published and then simply to

 4     fill it out and submit it, then, in August of 1990, and that's why we

 5     have your signature.

 6             Isn't that how it worked back in those days?

 7        A.   I can't say yes or no to that question.  I told you that the

 8     signature was mine, and, as for the rest, I really don't know what to

 9     say.

10        Q.   In your cross-examination, Mr. Hadzic, we were looking at a

11     document at tab 561, 65 ter 1278.  This was an article from "Politika,"

12     page 2 of the English.  This is the article, Mr. Hadzic, called:  We are

13     in favour of peace and agreement.  This related to your trip to

14     Beli Manastir on the 25th of September, 1992.  Do you remember discussing

15     this document with me?  I was asking you about Mr. Borivoje Zivanovic at

16     the time.

17        A.   I remember that we mentioned Mr. Borivoje Zivanovic on several

18     occasions; however, you would have to show me this document to jog my

19     memory.  Actually, I am looking at it, but the letters are too small.

20     Can it be zoomed in a little?

21        Q.   Let me see if I can refresh your recollection.  What I was asking

22     you about were comments on your position on whether the Belgian Battalion

23     of UN peacekeepers should be withdrawn from Beli Manastir.  At page 10259

24     at your evidence on cross, you said --

25             MR. ZIVANOVIC:  Your Honours, I would propose that Mr. Hadzic be

Page 10710

 1     provided with this text to see that before he give any answer to this

 2     question.

 3             MR. STRINGER:  We can go to the very end of the article entitled:

 4     We are in favour of peace and agreement.  It's the very last part of it.

 5     It's referring to:

 6             "In Zivanovic's opinion even in those critical days when the

 7     return of the refugees ... was announced, the Belgians did not succeed in

 8     hiding their favour for the Croatian side."

 9             It continues.  And then it says:

10             "'We demand and we shall do it officially through our RSK

11     government that the UN forces in Baranja pertaining to the

12     Belgian-Luxembourg Battalion be withdrawn from Baranja,' said Zivanovic."

13             "Hadzic agreed with that statement and promised that the

14     government was going to officially forward the request to the competent

15     authorities."

16        Q.   And, Mr. Hadzic, on page 10259 of your cross-examination, I asked

17     you about that.  I suggested that you were with -- you were in agreement

18     with Mr. Zivanovic on this issue of the UNPROFOR.  And you said:

19             "No, this was the journalist's comment.  I said that I would pass

20     it on to the government as far as my authority went, to send a protest

21     because of the Belgian Battalion's conduct, but I did not want the

22     Belgian Battalion to withdraw nor was that under my jurisdiction."

23             Do you remember that was your answer.

24        A.   Yes, I remember.  That's what happened, yes, and that's what I

25     said.

Page 10711

 1             MR. STRINGER:  Could we please have tab 1715, Exhibit 4890.1.

 2     It's a very short video-clip.

 3             And we'll wait for the interpreters.

 4             THE INTERPRETER:  We haven't got the 65 ter number.

 5             MR. STRINGER:  It's 4890.1.

 6             THE INTERPRETER:  Thank you.  We've got it.

 7                           [Video-clip played]

 8             THE INTERPRETER: [Voiceover] "The president of the Republic of

 9     Serbian Krajina, Goran Hadzic stated yesterday that he will request from

10     UNPROFOR to pull out the Belgian-Luxembourg Battalion from Baranja

11     because of, as he said, the battalion's improper conduct.  In connection

12     with that, the state committee for co-operation with UNPROFOR said that

13     they are familiar with the complaints of the representatives of the

14     Republic of Serbian Krajina about the conduct of the

15     Belgian-Luxembourg Battalion.  Relevant factors are still not able to say

16     anything concrete about the resolution of this issue."

17             MR. STRINGER:  Could we now have tab 1714, please, 65 ter 4818.2.

18             THE INTERPRETER:  We've found it.

19             MR. STRINGER:  Let's try it again.  I don't think we're getting

20     sound.

21                           [Video-clip played]

22             THE INTERPRETER: [Voiceover] "We will never accept this

23     blackmail.  According to the Belgian daily "Soir," this is the reaction

24     of the Belgian government to the demand of the president of the

25     Serbian Republic of Krajina, Goran Hadzic, for the immediate withdrawal

Page 10712

 1     of Belgian Blue Helmets from Baranja to replace them with soldiers from

 2     another country.  Belgium, it is stressed, has no intention of forsaking

 3     its obligations to the United Nations and dismisses the claim of the

 4     Serbian leader that members of its detachment are biased."

 5             MR. STRINGER:

 6        Q.   Now, Mr. Hadzic, despite what you said on the cross-examination

 7     in response to my question on this, you did, in fact, yourself want the

 8     Belgian Battalion to withdraw, and you did, indeed, believe it was under

 9     your jurisdiction since you were advocating that publicly.  Isn't that

10     true?

11        A.   Well, it's not true.  This was this comment regarding the meeting

12     in Baranja and Borivoje Zivanovic's statement and now these are

13     journalists' comments and my picture was shown.  I don't remember that I

14     wrote or explicitly asked for that because the commentary that we heard

15     before this one, it says that the representatives of the Krajina

16     government had asked for this, not the president.  They asked for the

17     replacement of or whatever, reexamining the influence of the

18     Belgian Battalion.  The problem was that they had heavy weaponry on their

19     vehicles, the Belgians, and they would point them at civilians when they

20     were patrolling villages.  This caused nervousness among people, among

21     women and children, and they were not actually guarding the border.

22     That's how the problem escalated.

23             MR. STRINGER:  Your Honour, the Prosecution would tender first

24     the newspaper article, 65 ter 1278, as well as these two video-clips that

25     we've just seen, 4818.1 -- sorry.  4890.1 and 4818.2.

Page 10713

 1             JUDGE HALL:  Any objection from the Defence?

 2             MR. ZIVANOVIC:  No objection, Your Honour.

 3             JUDGE HALL:  Admitted and marked.

 4             THE REGISTRAR:  Your Honours, 65 ter number 01278 will be

 5     Exhibit P3236.

 6             65 ter number 04890.1 will be Exhibit P3237.

 7             And 65 ter number 04818.2 will be Exhibit P3238.

 8             MR. STRINGER:

 9        Q.   Mr. Hadzic, a couple of times, actually, during your evidence and

10     also in your own statement that you gave to the Trial Chamber at the

11     beginning, you discussed your flight, the fact that you didn't come to

12     the Tribunal when you were indicted.  And I know that you've described

13     that and given your reasons for that in private session for the Chamber,

14     so I'm not going to go into the reasoning that you gave, but I do want to

15     ask you a couple of questions about your flight and the fact that you

16     were a fugitive from the time you were indicted in 2004.

17             And I'm going to put it to you that despite what you said it was

18     never your intention to come voluntarily to the Tribunal, and it starts,

19     actually, back when you testified as a Defence witness in the Dokmanovic

20     case back in 1998.  And this is 65 ter 2320, page 3118 of the Dokmanovic

21     transcript.

22             And it was put to you on cross-examination by the Prosecutor in

23     that case at the top of the page here.  He said:

24             "Now, on the evening of the 27th of June, 1997, after you found

25     out about Mr. Dokmanovic's arrest, you fled from eastern Slavonia in a

Page 10714

 1     boat across the Danube into Serb, didn't you? "

 2             And you denied it.

 3             And you went on to say that you crossed Erdut and went to

 4     Novi Sad.  You were with your son.  You denied fleeing.  And, again, on

 5     line 13 the Prosecutor put to you:

 6             "Isn't it a fact that you left on the same day of

 7     Mr. Dokmanovic's arrest; correct?

 8             And you said:

 9             "That is a fact which had nothing do with it.  It can have

10     something to do with it and need not have."

11             But on this issue of flight, Mr. Hadzic, isn't it so that even as

12     early as 1997 when other accused linked to these events were arrested, it

13     was then that you left Croatia immediately and moved yourself to Serbia,

14     isn't that true, in order to avoid being arrested and being brought to

15     the Tribunal?

16        A.   Well, that is not correct.  I wouldn't want to defend this Court

17     from you now, but how could they have arrested me because I was not

18     indicted?  So how do you get it the other way around?  How can somebody

19     be arrested first and then have a indictment issued?  Going to Novi Sad

20     and Croatia, these are completely different connotations.  I didn't want

21     to integrate into Croatia.  I didn't want my children to go to a Croatian

22     school, and I left Croatia just like many of my friends and co-workers

23     did.  However, at the time of the arrest of Dokmanovic, this culminated

24     this reintegration and this was sort of a cross on the T, that this

25     peaceful reintegration should be completed and that I should leave the

Page 10715

 1     area.  I did leave the area, as I said then, in my car.  I sat in the

 2     back.  My son, Srecko, sat next to me.  At that time he was about ten

 3     years old.  He was nine years old, actually.

 4        Q.   Mr. Dokmanovic was arrested on a secret indictment, and you

 5     didn't know if there was a secret indictment out for you as well.  True?

 6        A.   Well, it could be partly true, but it is not true.  I'm sorry, I

 7     repeated the Croatian word because the interpreter was speaking Croatian

 8     to me.  There were some indictments against me from Croatia.  They had

 9     been withdrawn in the meantime.  But at that time, I didn't know and that

10     was a difficult situation.  With Croatia I have been accused of things

11     that I did not even know about.  I didn't even know what had happened.

12     So I have been pardoned for most things in Croatia.  The things that I

13     stand accused of here are things that I do not stand accused of in

14     Croatia because they know who is to be blamed for what.

15             MR. STRINGER:  Could we please have tab 1619,

16     Exhibit 65 ter 6546.

17        Q.   And as that is coming up, Mr. Hadzic, we're going to move forward

18     now to the 13th July, 2004.  You were in Novi Sad.  And on the day that

19     the sealed indictment in your case here at the ICTY, when it was

20     forwarded to the authorities in Serbia, that's, in fact, when you got in

21     your car, fled, and went into hiding for the next seven years.

22             If we go to the next page, we can see a photograph, I believe.

23             And then the next image on the next page.

24             That's you, isn't it, standing out in the front of your house on

25     the day that you got in that car and fled?

Page 10716

 1        A.   I did not take that photograph.  I don't know who took the

 2     photograph.  And I don't know which day this is.  There's no way I can

 3     tell that it was that day.  Maybe you are right, but I really don't know

 4     who took this.

 5        Q.   You did get information that you had been indicted by the ICTY

 6     and that's when you loaded the car and fled; correct?

 7        A.   I received quite a bit of this information which mostly was not

 8     correct.  This was probably the 30th piece of information of this kind

 9     that proved to be correct.  It was sort of semi-information.

10        Q.   And that's when you fled and went into hiding; correct?

11        A.   Well, now you're asking me to confirm something that is not in

12     dispute.  Everybody knows that I had fled and was a fugitive for seven

13     years.  And, as for this photograph --

14             THE INTERPRETER:  Interpreter's note:  We did not understand the

15     end of the sentence.

16             MR. STRINGER:

17        Q.   Mr. Hadzic, they -- interpreters did not get the end of your last

18     answer.  You were going to say something about the photograph.

19        A.   Well, I'm saying I don't know when the photograph was taken.  I

20     had the feeling, based on your question, that you were saying that this

21     photograph was taken on the day when I fled.  I don't know about that.

22             MR. STRINGER:  Could we please have tab 1579,

23     Exhibit 65 ter 6505.

24        Q.   Mr. Hadzic, this is an internal memorandum that was written by

25     Mr. Dzuro and it relates, in part, to his contact with you when he was

Page 10717

 1     organising -- or in contact with you about the suspect interview and

 2     making arrangements for that to happen back in 2002.  And we see here

 3     under the 16th of January, 2002, he said, he wrote that:

 4             "At 1100 hours, Dzuro called Goran Hadzic on his office phone at

 5     the Nis oil company in Novi Sad.  After initial explanation, Goran Hadzic

 6     agreed on a meeting on Sunday, 20 January 2002, at 1100 hours at the

 7     Park Hotel in Novi Sad."

 8             Do you remember Mr. Dzuro contacting you - I know it was a long

 9     time ago - about trying to organise this suspect interview, or meeting?

10        A.   I did speak to him, but I don't know what the date was.

11        Q.   And then if we go to the next page of the English, he then refers

12     to the meeting taking place on the 20th of January.  He says:

13             "At 1100 hours, Dzuro and someone met Goran Hadzic in Hotel Park

14     in Novi Sad.  The meeting went" --

15             MR. STRINGER:  Your Honour, counsel has an intervention so I'll

16     stop reading it.

17             MR. ZIVANOVIC:  Excuse me, may we see this document unredacted?

18             MR. STRINGER:  The unredacted parts relate to other things that

19     Mr. Dzuro was doing in connection with other investigations in other

20     cases.  We could provide it to counsel.  We can provide it, I believe.

21     I'd like to take a look at it.  But it's redacted the parts that relate

22     to other things, not Mr. Hadzic.

23             MR. ZIVANOVIC:  I don't understand why not to Mr. Hadzic.  But I

24     agree if the Prosecution provide it to me.

25             MR. STRINGER:  Your Honour, if I can continue my cross on this,

Page 10718

 1     we can provide an unredacted version to counsel.  It's an internal

 2     memorandum.  It relates to a lot of things Mr. Dzuro was doing.  We could

 3     provide it to him during the break, but I would like to conclude my

 4     inquiry on this point now and also like to conclude my cross-examination

 5     before the break.

 6             JUDGE HALL:  Yeah.  Mr. Zivanovic, is that acceptable?

 7     Mr. Stringer continues and you could look at it during the break and see

 8     whether you have been handicapped by not having seen it beforehand?

 9             MR. ZIVANOVIC:  Yes, Your Honour.  That's acceptable for me.

10     Thank you.

11             MR. STRINGER:

12        Q.   Mr. Hadzic, Dzuro writes:

13             "The meeting went in relatively friendly mood but the lobby of

14     the hotel was secured by some 10 to 15 body-guards.  Hadzic informed

15     Dzuro that he was armed with a pistol and that he would not hesitate to

16     use the weapon in case somebody attempted to arrest him.  Hadzic greed to

17     be interviewed as a suspect and the interview was set for the

18     1st of March, 2002, at 1000 hours in Novi Sad."

19             So, Mr. Hadzic, despite what you've said in this trial or what

20     you've indicated, the fact is that you've never, ever intended

21     voluntarily to come to the Tribunal.  And, in fact, here you've indicated

22     you would use force not to come.  Isn't that so?

23        A.   That's not correct.  He was a decent gentleman.  This never

24     crossed my mind, the possibility of an arrest.  I have to give a comment

25     because the distinguished Trial Chamber may get the wrong impression.

Page 10719

 1     This hotel, Park, is one of the biggest hotels in Novi Sad and the owner

 2     is a person who is deceased today, Ratko Butorovic, not called

 3     Bata Kankan, a controversial businessman as they say in Serbia.  I don't

 4     know why, but he had lots of security people, body-guards.  They were

 5     sitting there and they also followed him in three cars wherever he went,

 6     so they sat there.  I just came with my driver, whereas all of these

 7     other people were people I did not even know.  They were his body-guards.

 8        Q.   You informed Mr. Dzuro that you were armed with a pistol and that

 9     you would not hesitate to use it in case someone attempted to arrest you?

10        A.   I don't think I said that.  I'm not really that thick.

11     Dokmanovic was arrested by about 30 soldiers.  That is what I heard.

12     Although Dokmanovic was not that dangerous.  I was that literate from a

13     league and political point of view to know that some foreign policemen

14     could not arrest me in Novi Sad.  That is not serious.  How can that be

15     recorded there?  It was only the police of Serbia that could have

16     arrested me in Serbia.  That would have to be clear to me.  Dokmanovic

17     was arrested in an UN protected area so it was the UN forces that

18     arrested him.  If it weren't sad, I'd find it funny.  Well, I did carry a

19     pistol around all the time, that's no secret and that's not in dispute,

20     for my personal protection and I had a proper permit for this pistol.  I

21     never used it though, and I never even threatened anybody with it.

22        Q.   You told Mr. Dzuro that you had the pistol with you.  True?

23        A.   I did not.  Why would I do that?  I'm not crazy.  Mr. Dzuro is a

24     decent man, very well mannered.  He did not say a single word that was

25     bad.  He was a very decent gentleman, apologised every time he would say

Page 10720

 1     something that might sound wrong.  I mean, I would not threaten him with

 2     a pistol.  On the contrary, I would protect him if anybody threatened

 3     him.  He was in my town.  I would be prepared to protect him in my town

 4     with his own -- with my own body.  I was his host and that is sacred in

 5     our part of the world.  If somebody were to attack me guest, that would

 6     be worse than attacking me or killing me.  This is really not true.  What

 7     you said, whether I would surrender or no, I said that in closed session

 8     and if you're interested in that, I can tell you what I think about that

 9     in closed session, if we move into closed session.

10             MR. STRINGER:  Your Honour, that completes my cross-examination.

11             JUDGE HALL:  Thank you, Mr. Stringer.

12             Mr. Zivanovic -- yes, Mr. Zivanovic.

13             MR. ZIVANOVIC:  Your Honours, I would start my re-direct after

14     the break.

15             JUDGE HALL:  Yes, I was going to suggest that, although we're a

16     few minutes short -- shy of the usual time, we take the break now and

17     resume at 11.00.

18                           --- Recess taken at 10.27 a.m.

19                           --- On resuming at 11.02 a.m.

20             JUDGE HALL:  Yes, Mr. Zivanovic, are you ready?

21             MR. ZIVANOVIC:  Your Honour, before we start, I would address

22     the -- the proposal of the Prosecution as to document 4974.08.  In

23     e-court, this document has 24 pages, and we are provided with a document

24     with seven pages.  So we would see that and see -- see -- seeing this

25     documents after -- after the -- today's sitting, and the rest we


Page 10721

 1     will answer to tomorrow.

 2             JUDGE HALL:  Very well.

 3                           Re-examination by Mr. Zivanovic:

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

 5        A.   Good morning.

 6        Q.   I will start by reminding you of some questions that were put to

 7     you by the Prosecutor on the first day of his examination, on the

 8     17th of July.  I'm going to read just one part -- or, rather, an

 9     assertion of his that was a part of his question on pages 9942 and 9943.

10     The question was:

11             [In English] "The fact is, Mr. Hadzic, that a peaceful

12     reintegration of the SBWS, the Eastern Slavonia region that we heard

13     about through the trial, that, in fact, could have been achieved for

14     Western Slavonia and the Knin Krajina as well, if you, as the leader of

15     the Serb people in Croatia, the political leader, had advocated something

16     other than separation of the people and in order to achieve a Serbian

17     state on the territory of Croatia.  Isn't that true?  A peaceful

18     reintegration could have been achieved at any point along the way through

19     your tenure as the leader if you had wanted that to happen.  It's just

20     that you didn't want it to happen."

21             [Interpretation] First of all, I would like to ask you or,

22     rather, I would like to clarify certain things.  You provided your

23     answers already.  The Prosecutor, as you can see, claimed that the

24     peaceful reintegration was what you wanted as a leader.  Please tell us

25     whether that's correct or not.

Page 10722

 1        A.   This is not correct.  As a matter fact, this is 100 per cent

 2     wrong.  It was not up to me to have a say in that, at all.  It's a

 3     thousand per mille incorrect.

 4        Q.   Could you please tell us what was the sentiment among the Serbs

 5     in the Knin Krajina at the time?  Do you know if there was a belief among

 6     them or a conviction that they could still remain living there if the

 7     Republic of Serbian Krajina did not exist?

 8        A.   We just said something about 1992, whereas, the

 9     Republic of Serbian Krajina emerged only later.  When I started

10     co-operating with them, it was at the beginning of 1992.  However, in the

11     course of 1991, the sentiment was that they couldn't exist in Croatia the

12     way Croatia proposed it and that their safety would be jeopardised.  This

13     is at least what I knew about the work of the Serbian Democratic Party.

14     I knew that that was their position.  They were not very convinced about

15     good intentions of the bodies of Republic of Croatia, and that's why they

16     erect the barricades, due to that fear.  It's a well-known fact.

17        Q.   My question may have been too broad.  I'm not interested

18     specifically in 1991 or 1992.  I'm talking about the entire duration of

19     your term of office as the president of the Republic of Serbian Krajina

20     in 1992 and 1993.  I am interested in the sentiment of the Serbian

21     population at that time, of the population in the Republic of

22     Serbian Krajina.  Was there any concern among them about their survival

23     there if the bodies of the Republic of Serbian Krajina stopped existing?

24        A.   Yeah, there were dilemmas to that effect.  They did not trust

25     Croatia, and if the Serbian bodies of government had not existed there,

Page 10723

 1     the people would not have stayed.

 2        Q.   Again, let's go back to 1992 and 1993.  According to what you

 3     learned and based on your experience and contacts that you had with the

 4     Croatian side and the international negotiators, what was your

 5     impression?  Was there a desire among the Croatian authorities to keep

 6     the Serbian population in that area?  I am referring to Knin Krajina,

 7     Western Slavonia, Eastern Slavonia.

 8        A.   I did not notice that desire.  I -- I don't think it existed,

 9     although there was a lot of lip service paid to that, but there was no

10     real desire for the Serbian people to remain living there.

11        Q.   Could you please tell us what happened to the Serbian population

12     that lived in Croatia, the Serbian population after the Croatian forces

13     reintegrated Western Slavonia and Knin Krajina.

14        A.   The biggest ethnic cleansing in Europe after the Second World War

15     happened there.  The Serbs almost disappeared from the area.  They were

16     like precious metal.  They remained only in traces, as the chemists would

17     put it.

18        Q.   Could you please tell us what happened to the part of the

19     population which did not leave which remained living in the territory of

20     Western Slavonia and Knin Krajina after Operations Storm and Flash?

21        A.   They feared very badly.  They faired very badly.  We all could

22     see that.  I'm sure that you know that, the Prosecution know that.  I

23     don't know whether the Trial Chamber knows about the conversations or

24     discussions in the Brioni isles before that operation.  That plan was

25     drafted there and they said that their safety should be guaranteed only

Page 10724

 1     formally.  But the plan was the expel all the Serbs from Croatia.  Those

 2     who believed the words that were said were elderly people who actually

 3     lost their lives during the incidents.  Nobody was tried for those

 4     incidents although there were some attempts to bring people to justice in

 5     Zagreb, but nothing came out of that, as far as I know.

 6        Q.   I read Prosecutor's question to you a while ago.  Amongst other

 7     things, it says in that question that you did not want the peaceful

 8     reintegration.  You -- you wanted the peoples to be separated from each

 9     other.

10             My question is this:  When it comes to the reintegration of

11     Knin Krajina and Western Slavonia, did it result in the separation of the

12     peoples or not?

13        A.   That reintegration of Knin Krajina and Western Slavonia was

14     forcible.  The Croatian side simply cleansed the territory and separated

15     the Serbian people from the Croatian people.  In other words, nothing of

16     that was up to me.  The Croats did it the way they did it.

17     Unfortunately, they enjoyed support by a segment of the international

18     community as well.

19        Q.   When if comes to Operations Storm and Flash, they took place over

20     20 years ago.  According to what you know, have the authorities allowed

21     the return of those Serbs who had been expelled from Knin Krajina and

22     Western Slavonia --

23             JUDGE HALL:  Yes, Mr. Stringer.

24             MR. STRINGER:  Your Honour, the Prosecution is going to object to

25     this line of questioning.  It is relating to events that took place in

Page 10725

 1     1995 after the relevant parts in the indictment in this case.  It goes to

 2     tu quoque but probably most significantly of all, the Chamber has heard

 3     volumes of evidence and testimony throughout the trial on these issues.

 4     They're not seriously in dispute in terms of what happened to the Serbian

 5     population in these areas in 1995, for example, but we're taking up

 6     valuable court time for an issue that has been gone into in length and

 7     it's of marginal relevance to the extent it's not tu quoque at all.

 8             JUDGE HALL:  Mr. Zivanovic.

 9             MR. ZIVANOVIC:  I quote the Prosecution's question where he said

10     that Mr. Hadzic insisted on -- sorry.  On -- on -- on the separation of

11     people -- of the people.  And I just like to clarify whether the

12     separation of people occurred, and if separation of people occurred, when

13     it occurred and why it occurred, and -- and my last question was:

14     Whether the separation of people still exists or not?

15             JUDGE HALL:  And with that, you move on.  When you said your last

16     question, you mean your last question on this topic, not nearly the last

17     question you asked.  In other words, what I'm suggesting is that -- in

18     response to the objection raised by Mr. Stringer, that you wrap it up

19     with that last question.

20             MR. ZIVANOVIC:

21        Q.   I don't ... I don't know whether Mr. Hadzic already answered

22     something of --

23        A.   I did not answer but I can.  That separation still exists.  Serbs

24     did not return to those regions of Croatia and their numbers there are

25     not nearly as significant as it was before those events.

Page 10726

 1        Q.   [Interpretation] Can you tell me what happened to the houses and

 2     apartments of those people, the people who had abandoned Croatia in 1995?

 3        A.   Those apartments were systematically confiscated, those

 4     apartments in the city.  And a lot of the houses were destroyed also as

 5     part of a systematic campaign.  They were either torched or blown up.

 6        Q.   The Prosecutor also asserted in the courtroom that you wanted to

 7     gain control over the territories where Serbs predominated by way of

 8     expelling non-Serbs.  According to what you know, the houses that were

 9     abandoned by the non-Serbs between the year 1991 and 1993, were they also

10     torched, destroyed?

11        A.   Both what I know and the truth about it are proportionate.  What

12     I know is the truth.  That is to say, that the houses were not torched or

13     torn down.  I think that it's quite opposite to what happened in Croatia

14     with the Serbs' houses because you've heard the testimony of Mr. Dzakula

15     and other witness who testified about the systematic destruction of as

16     many as 184 villages in Western Slavonia.  There were such incidents

17     during 1991 and 1992 but this was a systematic campaign, both the

18     expulsion and the destruction of houses in 1995.  The example of Ilok

19     showed the Trial Chamber that the Serbs from Western Slavonia were

20     temporarily moved into the houses.  They preserved them.  They have

21     abandoned them.  And the Croats normally returned to their houses, which

22     were preserved intact, and most of them even included and still had the

23     furniture.

24        Q.   Mr. Hadzic, if you remember, we had an opportunity to see, inter

25     alia, many video-clips from Vukovar and we also heard many testimonies

Page 10727

 1     about the circumstances in the town after the end of combat operations

 2     and you saw that it was almost completely destroyed.  What I'm interested

 3     in is whether you know if, during the combat operations and otherwise,

 4     only the non-Serbs' houses were destroyed in Vukovar or not.

 5        A.   Vukovar was destroyed unselectively, so both the Serbs and the

 6     Croats' houses were destroyed.  In my view, it was a totally stupid war

 7     and it was an unnecessary destruction of facilities and people.  We

 8     concluded that, and I saw it for the first time when I came to Vukovar

 9     for the first time on the 20th of November, because it cannot be

10     described in words how horrible that was for all of us who saw that.

11        Q.   [Microphone not activated]

12             THE INTERPRETER:  Microphone, please.

13             MR. ZIVANOVIC: [Interpretation]

14        Q.   From what you know, were the houses torn down, destroyed during

15     the combat operations or later when the combat operations were no longer

16     underway?

17        A.   As far as I know, that's the true.  And everybody knows that.  It

18     only happened during the combat operations.

19        Q.   One section of the cross-examination was devoted to the

20     Vance Plan and your position regarding that plan.  I will read out to you

21     a part of the Prosecutor's question on page 10378:

22             [In English] "You just said that we did not deal with the problem

23     of settlement and resettlement at all.  In fact, Mr. Hadzic, that's not

24     true.  You were the lead negotiator in the international negotiations

25     taking place about the Vance Plan, and the Vance Plan and your

Page 10728

 1     involvement in it was all about settlement and resettlement.  How can you

 2     claim that you didn't have any involvement or participation or deal with

 3     the problem of settlement and resettlement?"

 4             [Interpretation] You can see here two claims suggested by the

 5     Prosecutor.  We'll begin with the first one; namely, that you were a

 6     leading negotiator in the international negotiations taking place about

 7     the Vance Plan.  Can you tell us whether you, indeed, were the lead

 8     negotiator with regards to the Vance Plan?

 9        A.   I was not the lead negotiator.  I did have a meeting with

10     Mr. Goulding once and with Mr. Vance once.  But that was unimportant.  I

11     think that I was the last one on the list of negotiators, not that I

12     wasn't only the lead one, but I was a completely unimportant negotiator.

13     That is incorrect in the question and everything else that was told is

14     also incorrect.  So I can explain that when you ask me about the

15     particulars.

16        Q.   Can you tell us from what you know who was or who were the lead

17     negotiators with regard to the Vance Plan.

18        A.   I did not have a full knowledge at that time, but as it seemed to

19     me, it was the federal state, that is to say, the SFRY.  And there was

20     also Serbia, that is to say, Slobodan Milosevic and some of his

21     associates.  I don't know who.  So both Serbia and SFRY.  They were held

22     in Belgrade, and the other side was in Zagreb.  So no one asked us

23     anything.  They would just let us know the information about what was

24     going on, Mr. Vance did, but we couldn't change anything important about

25     it.  And also in the question how the things are linked, the issue of

Page 10729

 1     settlement and resettlement is linked with the Vance Plan.  In my

 2     language it's called conflation of conclusions.  When I said that I

 3     didn't have anything to do with settlement and resettlement, I meant

 4     during the time when I was the president of the region and the president

 5     of the republic, and the Vance Plan talked about the return of refugees

 6     and that was our obligation, and we wanted them to return as soon as the

 7     conditions for that were created.

 8        Q.   We'll get to that topic but, first, to illuminate everything

 9     around these negotiations.

10             When you say that you couldn't change anything, do you imply

11     yourself personally, or do you imply the representatives of the

12     Serbian Krajina, that is to say, SBWS?

13        A.   I personally could not change anything, and, generally, my entire

14     side from SBWS couldn't.  We only expressed concern about the security of

15     the people.  We proposed that the UNPROFOR that was coming to keep the

16     border should prevent Croatian raids.  They didn't do it.  They

17     guaranteed security.  It was not at high level of guarantee but we had to

18     accept it because we had no choice.  And my goal was to end the war.

19     That was my goal.

20        Q.   Were you in a position to influence the adjustments of the plans

21     so that some of its provisions might be changed?  Was it ever discussed?

22        A.   No, it wasn't discussed, nor could I do any such thing.  The plan

23     was accepted by Zagreb and Belgrade and the United Nations.  They

24     formally adopted it and signed it.  We never even signed it.

25        Q.   According to your understanding of the Vance Plan, who had the

Page 10730

 1     obligation to implement the plan and to vouchsafe its implementation in

 2     the territory of SBWS and the Krajina, so I mean the Western Krajina and

 3     the Knin Krajina?

 4        A.   There were two stage, as far as I understood that.  The first

 5     stage was before the -- the definitive taking over of the UN and the

 6     guarantees were to be provided by the SFRY, the federal state.  And from

 7     that moment on, UNPROFOR guaranteed everything.  And it wasn't only my

 8     view, but that's how it was, that was the agreement, the UNPROFOR took

 9     over the responsibility for the security of the entire territory.

10        Q.   You have heard the Prosecutor's question in which he says -- I

11     will repeat that part:

12             [In English] "And the Vance Plan and your involvement in it, it

13     was all about settlement and resettlement?"

14             [Interpretation] Could you tell us whether that is a correct

15     interpretation, that the whole Vance Plan boiled down to settlement and

16     resettlement?

17        A.   Of course this is not correct.  That only had to do with the last

18     step, and there were many preceding steps and pre-conditions for this to

19     be fulfilled.  So, of course, it's not true.

20        Q.   When you say that that was the last step, do you remember whether

21     the Vance Plan envisaged something with regard to the security of the

22     people living in the zones that were under the UN protection; and, if it

23     did envisage anything, what was it?

24        A.   Well, they were called protected zones.  The Vance Plan implied

25     providing security to the population in these zones, so the very name

Page 10731

 1     included that meaning.

 2        Q.   Did that imply all of the population or just the minority that

 3     was present there at the time?

 4        A.   The plan, when we negotiated about it, and when it was adopted,

 5     it was quite the opposite.  It didn't have to do with the minority but

 6     the majority and, of course, all the people living there.  But there were

 7     negotiations because the Serbs were afraid that they wouldn't be provided

 8     with adequate protection.  The Vance Plan guaranteed protection to the

 9     Serbs that Croatia wouldn't attack them and the next step was to

10     guarantee security to all the population, including the minority and the

11     majority.

12        Q.   In your contacts with international representatives, you have

13     seen a number of documents relating to certain complaints about the

14     protection of some ethnic minorities; in particular, the Croats who lived

15     in the territory of the Republic of Serbian Krajina.  From what you know,

16     did these representatives in discussions with you ever express any

17     concern about the protection of the entire population, especially

18     protecting them in from armed attacks that were carried out across the

19     separation lines?

20        A.   Never in discussion with me, even though I received only one

21     report that in Eastern Slavonia the Russian Battalion returned fire

22     against the Croats.  They never responded.  Whenever the Croats attacked,

23     they would seek shelter, and they would allow the Croatian army to carry

24     out these raids.  That was the information I had.

25        Q.   Did these international representatives ever provide any

Page 10732

 1     explanation in view of the contacts you had with them, explanation as to

 2     why they did not fulfil this obligation that they had to protect the

 3     border from Croatian army raids into protected zones or --

 4             MR. STRINGER:  Mr. President, we object to the question.  We

 5     don't agree that it accurately sets out obligations in respect of the

 6     Vance Plan among peacekeepers when active military operations are

 7     underway.

 8             JUDGE HALL:  Mr. Zivanovic.

 9             MR. ZIVANOVIC:  My question was not as to the active military

10     operation.

11             MR. STRINGER:  Well, what was referred to, Your Honour,

12     Mr. Hadzic just said whenever the Croats attacked they would seek

13     shelter, they being the UNPROFOR.  And they would allow the Croatian army

14     to carry out these raids and then the question was:  Did these

15     international representatives ever provide any explanation in view of the

16     contacts you had with them, explanation as to why they did not fill this

17     obligation that they had to protect the border from the Croatian army

18     raids.

19             And our position is that this is not an obligation to engage in

20     military operations or to protect the population when the Croatian army

21     is attacking.  We can disagree, perhaps agree to disagree, on what Vance

22     provided in this respect, but it's our submission that counsel's not

23     accurately stating what the Vance Plan provided.

24             MR. ZIVANOVIC:  As far as I know, the Vance Plan provided the

25     security of the population in UN protected areas, and it implies the

Page 10733

 1     protection from -- on the raids across the borders too.

 2             JUDGE HALL:  To the extent that any of this is relevant at the

 3     end of the day, in terms of such decisions as the Chamber must make, may

 4     I suggest that this be reserved for your final submissions because

 5     there's some nuances which cannot, to my mind, be adequately addressed by

 6     trying to refine the question.

 7             So please continue, Mr. Zivanovic.

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

 9        Q.   [Interpretation] I apologise, Mr. Hadzic.  If you can please

10     repeat your answer, if you still remember the question I asked you.

11        A.   Yes, well --

12        Q.   If you'd like me to repeat the question --

13        A.   No, it's not necessary.  First of all, I have to say that

14     Mr. Vance or Goulding said what I now heard from one of the parties.  If

15     they had heard that, the Serbs wouldn't have stayed, they would have

16     moved out if they said they wouldn't guarantee security.  They did

17     guarantee security to us.  But, as I already said, during the Croatian

18     actions, they did not prevent that, and what is more, there were no

19     sanctions for Croatia because of those violations of the Vance Plan.

20        Q.   It's a bit unclear in the transcript.  It's all right now.  It's

21     been corrected.  I do apologise.

22             Another question that was raised here was -- it was actually in

23     relation to moving out, resettlement, and so on.  The Prosecutor put a

24     question to you that I'm going to read out, 10369 is the page reference:

25             [In English] "Well, under the Vance Plan which you agreed to

Page 10734

 1     wasn't under the Vance Plan that, in fact, those Croats who were no

 2     longer there were to come back, return of refugees; right?  That's what

 3     was supposed to -- that's -- that what was supposed to happen."

 4             [Interpretation] This is what I'm interested in.  In view of the

 5     way the question was put, can you tell us, to the best of your knowledge,

 6     did the Vance Plan only pertain to the return of Croats who had left or

 7     did it pertain generally to refugees who had left their homes during the

 8     war operations, regardless of ethnic affiliation?

 9        A.   In my understanding, the Vance Plan pertained to all persons, all

10     refugees, irrespective of ethnicity.  Had it been any different, there

11     would have been no point in discussing it.  It would have meant

12     discrimination.

13        Q.   Can you tell me, on the basis of contacts with international

14     representatives, precisely in respect of this topic, did you get the

15     impression that they equally cared about the return of Croat refugees to

16     the Republic of Serbian Krajina and the return of Serb refugees to

17     Croatia or, rather, those parts that were already under the control of

18     the Croatian armed forces?

19        A.   Well, not equally.  You asked whether it was equal.  Well, they

20     cared only about the Croats.  They didn't care about the Serbs at all.

21     It was 100 percent different, so it's not that there was some difference

22     but a total difference.  For example, the Serbs from Western Slavonia,

23     they were supposed to leave their temporary homes in Croatia and go

24     somewhere, and none of them knew what to tell them, where they should go,

25     because the Croats were supposed to return and they could have only gone

Page 10735

 1     to the moon because their houses had been burned.

 2             So in response to your question, my answer is that they did not

 3     take care of the Serbs adequately, as they did of Croats.

 4        Q.   In these talks, did you hear perhaps that they had a plan, that

 5     they were preparing some plan for the return of these refugees, and

 6     especially referring to refugees from Western Slavonia?  I'm actually

 7     asking about their return to Croatia.

 8        A.   No, this was not a question at all.  According to these

 9     negotiators and high officials of the UN, they were not being treated as

10     their problem or, in a way, as human beings.  They were not interested in

11     where they would.  They were just interested in having the Croats return

12     there.  And sometimes I would angrily say where should they go?  Into the

13     Danube?  Or as I said a moment ago, up to the moon?  Because they

14     couldn't go back to Croatia.

15        Q.   Can you remember what they would answer to you if you would put

16     that question or if somebody else raised that question?

17        A.   Well, I remember how I would put that question.  Because I did

18     not put it directly.  I would make an introduction in order to explain.

19     I said, We behave or, rather, the international community behaves towards

20     the Serbs as if we were rebels.  We are not being recognised as if we

21     were some kind of savages, and Croatia is an internationally recognised

22     state and a recognised member of the UN, and now the Serbs are being

23     asked to resolve this problem and they say that they cannot resolve it

24     with Croatia.  And then I said, since Croatia is a member of the

25     international community, that they should resolve it half with the Serbs

Page 10736

 1     and half with the Croats.  So at least to the extent to which they

 2     resolves the problem with us, they should resolve it with the Croats too.

 3     And they said, No, no, no, you have to work this out, but we don't talk

 4     to Croatia about this.  In a way, they didn't want to talk about the

 5     return of Serbs to Croatia at all, justifying it by not having the

 6     mandate to do that.  But I think that they did have the mandate.  In my

 7     view, from a human point of view and from a legal point of view, this

 8     could not have been resolved just in a one-sided way.

 9        Q.   I'm going to go back a bit to a question that has to do with your

10     contacts with international representatives, again, in relation to some

11     provisions of the Vance Plan, and that has to do with disarmament.  You

12     remember that, according to the Vance Plan, disarmament was envisaged,

13     inter alia.  So this is what I'm interested in.  In your contacts with

14     international representatives, did they insist on having this disarmament

15     carried out, regardless of these attacks that had already been referred

16     to at the Miljavac plateau, Maslenica, the Medak pocket, and so on?

17        A.   At first they insisted on having this implemented 100 per cent,

18     and we did hand over the heavy weaponry under this so-called double key.

19     When Croatia carried out attacks, then these weapons were taken for us to

20     defend ourselves.  So for this month or two while the fighting went on,

21     they didn't complain.  But then again they insisted on having these

22     weapons returned, although they did not guarantee security.  And, of

23     course, they couldn't when it was established on the ground that they had

24     not been providing it in the first place.  We had a double problem.  That

25     is to say, this constant fear of a Croat attack, then the UN, the -- they

Page 10737

 1     promised to protect us, did not protect us, and our soldiers were on the

 2     border protecting the territory.  They didn't know where Croatia would

 3     attack.  And, on the ground, there weren't any law enforcement forces so

 4     we had to face crime because we could not control everything on both

 5     sides.  We had a limited number of people.

 6        Q.   Can you just clarify this:  You say that they insisted that these

 7     weapons should be returned after combat, after the end of combat.  What

 8     did that mean "after the end of combat or fighting"?  Can you tell us

 9     this a bit more precisely.  What was meant by this "end of combat"?

10        A.   Well, after the incident at the Miljavac plateau, when we thought

11     that there would be no other incidents, when the situation calmed down,

12     they did not really ask us to do that while the fighting was still going

13     on, the shooting was still going on.  Their mortal was not at such a low

14     level.  But then afterwards they did ask that this be done.

15        Q.   And when the army of the Republic of Serb Krajina would get such

16     weapons again, when did this actually take place?  Was it after attacks

17     or in some other situation?

18        A.   Well, again, they had to take this either if Croatia would

19     secretly attack or if we would get information that Croatia would attack

20     in a day or two.  But I really have to tell you quite frankly that I did

21     not deal with these military questions very precisely so I cannot speak

22     about this under oath.

23        Q.   I would like us to touch upon another topic that was also

24     highlighted by the Prosecutor during the cross-examination.  This has to

25     do with Zeljko Raznjatovic, Arkan.  One of the assertions put forth by

Page 10738

 1     the Prosecutor was that Arkan was your security.  I'm going to read out

 2     that question to you.  It is on page 9945.  It reads as follows:

 3             [In English] "The fact is, Mr. Hadzic, that Arkan, in fact, did

 4     provide security for you on numerous occasions not only through 1991 but

 5     also 1992 and 1993.  Isn't that true?"

 6             [Interpretation] You have provided an answer to that question but

 7     I would like us to clarify this a bit.  To the best of your knowledge --

 8     well, of course, perhaps you cannot be quite precise, but can you tell us

 9     in this period from 1991 to 1993, how many people did Zeljko Raznjatovic,

10     Arkan, have under his command?

11        A.   I don't have precise information.  I couldn't count them.  I just

12     remember what he stated in public in the media on TV and some of the

13     comments of my drivers and friends who were better informed than I was.

14     That sometimes he would exaggerate this.  So I think it was between 100

15     and 200, 250 men maximum.  Usually around 100 men.

16        Q.   Do you know roughly what kind of weapons they had?

17        A.   Arkan and a few of these senior officers of his had Hecklers,

18     Heckler/Koch rifles, very expensive ones.  And the rest had the most

19     up-to-date infantry weapons, automatic rifles, things like that.  That's

20     what I could see when I came to that centre.  Every day I saw the guards

21     there.  In a way, they controlled this road that I had to take.

22        Q.   Did Zeljko Raznjatovic, Arkan, arrive with a unit like that to

23     Slavonia, Baranja, and Western Srem in order to provide security for you?

24     I'm referring to you personally.

25        A.   Of course not.  When he arrived, he probably didn't even know who

Page 10739

 1     I was.  I certainly didn't know who he was.  I never had a security

 2     detail of more than five or six men at one point in time, in a single

 3     day.  I've already mentioned that.  And I think I've already given the

 4     names of all of my body-guards from 1991 to 1993, and later on, from 1996

 5     to 1997, because I reactivated most of them.  So Zeljko Raznjatovic had a

 6     combat unit.  It wasn't my understanding that he was anybody's private

 7     security.  He came to fight with long-barrelled weapons.  That's what I

 8     managed to see.

 9        Q.   In this period between 1991 and 1993 and perhaps even later, did

10     you ever issue any orders, any instructions to Zeljko Raznjatovic, Arkan?

11        A.   Never.  Also as I moved about in the field, I did not see anyone

12     who gave him any kind of orders.  I really have no knowledge to that

13     effect.  I was never present at any one of their meetings, say, with

14     Biorcevic or something like that.  I could not see that.

15        Q.   In 1991, was it necessary for such a unit headed by him to come

16     to Slavonia, Baranja, and Western Srem to provide security for you?

17        A.   Well, that is completely wrong.  I mean, even to ask something

18     like that.  Right now, in hindsight, I can tell Their Honours when I see

19     all of that, what I know now, I couldn't -- I didn't need to have any

20     kind of security because I was not incident-prone in any way.  I did not

21     have any -- I was not involved in any incidents.  In 1991 I had this

22     driver who was my body-guard too and he suggested that bringing in

23     Japundzic because he said that he was not a good driver.  And as they

24     also said, we socialised more than we worked because there was really no

25     need for them to protect me.  I have never heard from anyone, except for

Page 10740

 1     Arkan and Badza, that I was in any kind of danger.  I didn't even hear

 2     that from the Croats.  They were just talking.  They were saying, You

 3     have poor security, et cetera, et cetera.  However, in 1991, I never

 4     reenforced my security detail.  I just stayed on with these two men.

 5        Q.   [Microphone not activated]

 6             THE INTERPRETER:  Microphone, please.

 7             MR. ZIVANOVIC: [Interpretation]

 8        Q.   On the same page, the Prosecutor, amongst other things, suggested

 9     that you socialised with him quite a lot in order to improve your

10     position in the authorities, and he also promised that he would

11     intimidate others on your behalf.

12             Please, was there any need of that kind in 1991?  Is this

13     correct?

14        A.   This is not correct.  This is completely distorted.  I believe

15     that the opposite was true.  I had already become president when I still

16     didn't know him.  When he turned up, he was a hindrance more than

17     anything else.  He was incident-prone and he was not very well loved by

18     the Serbs in Pacetin, Bobanje [phoen], Trpinja whom I talked to.  I'm not

19     saying that he went against my authority but he certainly never improved

20     it.  I never worked with him.  I only saw him from time to time.

21             MR. STRINGER:  Excuse me, Mr. President, Your Honour, just to say

22     that -- I don't know that we would agree with the characterisation of

23     what was put to Mr. Hadzic on his cross, whether there's a record

24     reference that Mr. Zivanovic can give us.  I don't know that it was

25     suggested by the Prosecution that Hadzic socialised with Arkan in order

Page 10741

 1     to improve his position.  I think the word that was put to Mr. Hadzic on

 2     the cross was that he associated with Arkan, which has a different

 3     meaning.  I could be wrong.  If counsel could direct me to the transcript

 4     where I said "socialised," then I would stand corrected.

 5             MR. ZIVANOVIC:  I didn't read that portion of transcript and

 6     maybe it was my -- my interpretation, but I'll do it now.  It is the same

 7     transcript page, 9945.  It is from line 6:

 8             "You associated yourself with him frequently.  Did you it -- you

 9     did this because it enhanced your own powers and enable you to intimidate

10     others and to get your way by associating yourself with

11     Zeljko Raznjatovic."

12        Q.   [Interpretation] Can you tell us whether your previous answer

13     actually covers what I've just read out to you or is there anything you

14     wish to add?

15        A.   Yes.  It suffices.  I would say that the opposite was true.

16     There was no intimidation at all.  You will certainly understand from the

17     witnesses that I never intimidated somebody.  So just the opposite was

18     true.

19        Q.   Can you please tell us whether you met with him by arranging

20     those meetings or did he arrange those meetings or was there anything

21     else involved?

22        A.   I don't remember that I ever looked for him, perhaps a couple of

23     times only.  The -- one of those times was when I had problems with

24     Klis [phoen] and then I went to the centre.  I would also -- always meet

25     him either on the road, in town, in the village.  When I was somewhere,

Page 10742

 1     he would follow me.  At first I thought that those were chance meetings

 2     but then I started suspecting that he was actually really following me.

 3     He mostly came to Erdut to the courtyard of the government building.  He

 4     just turned up.  I never called him.  I never invited him.  And then when

 5     he threatened me about the Vance Plan, I actually realised -- I was

 6     certain that he was following me.  Actually, it was a threat against

 7     Babic, and then I realised that it was addressed at me as well, when he

 8     said to Babic that he would kill his children and I don't know what.  But

 9     I have to be honest and say that he never threatened me personally and

10     directly.

11        Q.   When we are talking about the security detail provided to you by

12     Zeljko Raznjatovic, Arkan, the Prosecutor also asked you about his

13     presence in Velepromet on the 29th November, 1991.  I'm going to read

14     that transcript page.  It's 9957:

15             [In English] "Isn't it true that he provided security for you to

16     get from Erdut to the Velepromet facility in Vukovar on the 20th of

17     November 1991?

18             "A.  That is not true.  He did not provide security for my route

19     to Erdut in 1991, 1992 or 1993."

20             [Interpretation] And later on page 9958, the next page, you were

21     shown a portion of your interview with the investigator Dzuro.  I'm

22     talking about the part about Zeljko Raznjatovic, Arkan, going to

23     Velepromet and why he did that.  And your answer is on page 9958 and I

24     quote:

25             [In English] "We needed that.  It's not that we had to penetrate

Page 10743

 1     through the area but we didn't want any incidents to occur in Vukovar

 2     because Arkan had sufficient authority in order to prevent this kind of

 3     incident."

 4             [Interpretation] I'm sure you remember this part of the

 5     examination.

 6        A.   Yes, I do.  But the interpretation I received - and that may be

 7     due to the differences between Croatian and Serbian - that Arkan had

 8     competencies.  I said "authority."  If it is one and the same, then it's

 9     okay.  He was not authorised but he had his own personal power.  I

10     believe that's what I said.  He was not officially authorised to do

11     anything, and I think it's a very big difference.

12        Q.   Yes, I know that you used the word "authority."  And that's what

13     I see in the original text as well.  However, I just wanted to ask you

14     what you meant when you said "we needed that"?

15             MR. STRINGER:  Apologise for the interruption Your Honour.  Just

16     to say that I believe counsel's referring to the suspect interview with

17     Mr. Dzuro and, in fact, here Mr. Hadzic's prior statement as from his

18     testimony in the Dokmanovic case, not from his suspect interview.  So,

19     just for the record.

20             MR. ZIVANOVIC:  That's correct, Your Honour.  It was my error.

21             THE WITNESS: [Interpretation] I understood the question.

22             MR. ZIVANOVIC: [Interpretation]

23        Q.   Let me just correct something -- yes, that is your prior

24     testimony, the Dokmanovic case.  I misspoke when I quoted the source.

25             Let me repeat the question.  As a matter of fact, what did you

Page 10744

 1     want to say when you said "we needed that"?

 2        A.   When I used the personal pronoun "we," I meant the government.

 3     What I meant was that the government needed to prevent any possible

 4     incidents in Velepromet because some members of the government were

 5     afraid and didn't even dare to go to Vukovar.  I said I will go at any

 6     cost.  I have nothing to fear.  They requested additional guarantees -

 7     Dr. Hadzic particularly - and that's why they invited Arkan to provide

 8     security for the entire government.  And the conflation started from

 9     there.  That was the beginning of the rumours that Arkan was my security

10     detail, and then the JNA and everybody else exploited that.  And it was a

11     good enough reason for them to cover up Arkan's role and mask his order

12     givers.  They actually masked his role under the pretense that he was my

13     security detail, but he wasn't.  That's simply not true.

14        Q.   Mr. Hadzic, I'm going to read yet another part of the

15     Prosecutor's questions and your answers.  I don't believe that you will

16     have the time to answer my question.  I will read first and then during

17     the break, you can actually think about the answer.

18             MR. ZIVANOVIC:  I'm quoting from page 9966:

19             [In English] "And in what capacity then is he standing next to

20     you?  What's the reason why he's there with you at this press conference

21     in Erdut?

22             "A.  It's difficult for me to answer now, considering that Arkan

23     is dead and I don't know.  I'm not sure whether he was standing there

24     already when I started giving the interview, or he came later and stopped

25     there in order to be in the picture.

Page 10745

 1             "Q.  So could it be one of those occasions you've described where

 2     he was just trying to get close to you or was attempted to follow you

 3     around to get close to you?

 4             "A.  That's the way it always happened.  This is just one more

 5     such situation."

 6             MR. ZIVANOVIC:  I see the -- it is appropriate time for the

 7     break, Your Honour.

 8             JUDGE HALL:  I heard your point about allowing him time to think

 9     about it, but is it something that requires a -- is it a question that he

10     couldn't answer at this point?  We could take the break, but ...

11             MR. ZIVANOVIC:  Yeah, we could take the break.  Because there are

12     many questions after that.

13             JUDGE HALL:  Very well.  So we take the break at this point.

14                           --- Recess taken at 12.14 p.m.

15                           --- On resuming at 12.46 p.m.

16             JUDGE HALL:  Yes, Mr. Zivanovic, you may continue.

17             MR. ZIVANOVIC:

18        Q.   [Interpretation] Mr. Hadzic, I believe that you still remember my

19     question, i.e., that you remember the quote which was Mr. Stringer's

20     question.  Amongst other things, let me remind you of what you said in

21     your answer.  You said that you didn't know whether he was standing next

22     to you only to be in the photo.  My question is this:  According to you,

23     did Arkan like publicity?

24        A.   Yes, that was one of his main features.  That's why he tried to

25     engage the journalist van Lynden to be his private journalist.  However,

Page 10746

 1     I remembered something else about that interview.  When the Prosecutor

 2     showed me that, the journalist asked me about the visit of the mayor of

 3     Belgrade.  When Mr. Unkovic was there, I wasn't with him.  I was

 4     prevented from hosting him.  However, I saw in the photo that somebody

 5     received him on behalf of the government.  I believe it was Dr. Hadzic

 6     and I also saw Arkan.  And I remember that in a way.  Arkan was his host

 7     because they had known each other from Belgrade.  I suppose that he stood

 8     next to me because he expected that the journalist would ask him about

 9     the visit.  He was always on TV, every day, so his photo could have been

10     taken even without me in it, but I suppose that he expected that he would

11     be asked about the visit because Unkovic visited him as well, as far as I

12     can remember.  So I believe that explains the whole situation.  Maybe it

13     would be interesting to learn something about my security detail.  I

14     didn't tell you either but maybe the Trial Chamber would like to know

15     when I lost in the election, Martic sent the police to confiscate my car

16     since they couldn't --

17             MR. STRINGER:  Excuse me, Mr. Hadzic.

18             Apologies for the interruption.  Your Honour, I'm look at Rule 90

19     on testimony of witnesses.  90(F) says that the Trial Chamber shall

20     exercise control over the mode and order or interrogating witnesses and

21     presenting evidence so as to make the integration and presentation

22     effective for the ascertainment of the truth and avoid needless

23     consumption of time.  And I would respectively suggest, Your Honour, that

24     much of what we've heard so far in this redirect is actually just a

25     rehash, sort of just a restating of the direct examination.  I know

Page 10747

 1     counsel has referred to some questions that were put to Mr. Hadzic during

 2     cross but it's largely just saying again what was said before.  And it's

 3     not true re-direct in that sense, in our submission, and just now where

 4     Mr. Hadzic is sort of taking the floor to provide some more information

 5     on an issue that was dealt with on the cross without really having been

 6     asked to is really taking a step further, so we object to the -- what we

 7     think is a needless consumption of time and not a proper form of

 8     re-direct examination.

 9             JUDGE HALL:  Mr. Zivanovic, sorry, you were going to say

10     something --

11             MR. ZIVANOVIC:  Yes.

12             JUDGE HALL:  -- in reply.  Yes.

13             MR. ZIVANOVIC:  All my questions were put in order to clarify the

14     question -- the answers the accused gave to the -- on the Prosecution's

15     questions, and I quoted all the Prosecution questions, and all of these

16     questions are closely related to the matters raised by the Prosecution in

17     course of their cross-examination.  And, as far as I see, Mr. Hadzic

18     gave -- give -- gave his answers in a way he -- he -- he find it

19     appropriate.

20             JUDGE HALL:  The observation that frames Mr. Stringer's objection

21     is, of course, not a -- an uncommon problem in these proceedings, and in

22     that vein, I would remind you, Mr. Zivanovic, that you should focus your

23     question on the points that would have arisen in cross-examination which

24     you would wish to have clarified for the benefit of such future

25     submissions as you would make to the Trial Chamber.

Page 10748

 1             And, Mr. Hadzic, I would remind you that you should listen to the

 2     question and only answer the question asked.  And the way a question is

 3     phrased should not be used as an opportunity to make -- to volunteer

 4     information that you -- you -- you want to somehow get in.

 5             So counsel on his feet is the one who is to guide this process,

 6     so, Mr. Zivanovic, I would ask you to keep your witness under control.

 7             MR. ZIVANOVIC:  I'll do, Mr. President.

 8        Q.   [Interpretation] Mr. Hadzic, I'm not sure about the previous

 9     question.  You did begin, actually, to give an answer and gave it

10     partially but then you were interrupted.

11             What I'm interested in is whether you wanted to answer the

12     question I already asked you, or if you wanted to say something else, if

13     you wanted to answer my question, then please complete your answer.

14             JUDGE HALL:  But, Mr. Zivanovic, isn't that precisely -- isn't

15     that precisely the problem that Mr. Stringer has put his finger on.  It

16     isn't for the witness to say something else if he wants.  Question and

17     answer, and only the answer.

18             MR. ZIVANOVIC:  And -- and, Your Honour, I am not aware whether

19     Mr. Hadzic completed his answer on my question.  That's my question.

20             JUDGE HALL:  Let's -- let's move forward quickly.

21             THE WITNESS: [Interpretation] I wanted to say something about

22     security, and I can tell you how it worked if you ask me that, because

23     the Prosecutor asked me that too.  I was asked whether Arkan was my

24     security.  I wanted to say that he didn't and to explain how I provided a

25     security myself.

Page 10749

 1             MR. ZIVANOVIC: [Interpretation]

 2        Q.   My question would specifically be linked with the Prosecutor's

 3     assertion that Arkan was your security.  Was there a need for him to

 4     provide security to you at Erdut during the meeting with Mayor Unkovic.

 5        A.   There was no need, at least 20 kilometres around there was no

 6     possibility of any enemy activities.  So there was no need for him to

 7     secure me.

 8        Q.   And was it necessary for him to provide security for you during

 9     the interview with the TV journalist?

10        A.   No, nor was he doing that.  He was either just standing there so

11     his photo would be taken or he was waiting in line to be interviewed

12     next.

13        Q.   During the cross-examination, you were shown Exhibit P2715.  It's

14     tab 742.

15             MR. ZIVANOVIC: [Interpretation] It's page 34 in English.  And I

16     would just like to look at it briefly.

17        Q.   It's the penultimate paragraph.  There is no need to include the

18     B/C/S text as well.  General Panic is speaking here and I will just read

19     out to you the first sentence where he says:

20             [In English] "He is a person who had some good contacts with the

21     press, and press loved him for several reasons.  He could speak several

22     languages, and that's why the foreign press maintained contacts with him.

23     He was a good host."

24             [Microphone not activated]

25             THE INTERPRETER:  Microphone, please.

Page 10750

 1             MR. ZIVANOVIC: [Interpretation]

 2        Q.   So my question is whether this is correct, what General Panic

 3     said on this occasion about Zeljko Raznjatovic, Arkan?

 4        A.   He obviously had better information than me, but I think that it

 5     was true that he was on good terms with foreign journalists.

 6             MR. STRINGER:  Apologies for the intervention.  I don't recall

 7     showing this to Mr. Hadzic on cross-examination.  I wonder if there's a

 8     reference for that.

 9             MR. ZIVANOVIC:  I think it was shown but not maybe this

10     particular part of this document.  Anyway, I'm not -- I'm not -- I'll not

11     put any other questions related to this document.

12        Q.   [Interpretation] Mr. Hadzic, the Prosecutor asked you also about

13     a meeting you had with Zeljko Raznjatovic, Arkan, and the Dutch

14     journalist van Lynden.

15             MR. ZIVANOVIC: [Interpretation] It's page 9960.

16        Q.   You probably remember his testimony before the Tribunal.

17        A.   Yes, I do.

18        Q.   I wanted to remind you of something from his statement and his

19     testimony about this meeting at the patisserie to leave alone everything

20     that happened later.  Could you tell me whether what he said at the time

21     is true -- or, rather, can you first tell me something about this meeting

22     and communication, whether you personally took part in this conversation

23     between the journalist, van Lynden, and Zeljko Raznjatovic, Arkan.  Did

24     you actively participate in it?

25        A.   No, I didn't participate in it at all.  I was just introduced to

Page 10751

 1     this man, and I was brought there by a trick.  Because a friend I knew

 2     said, Let us meet at the patisserie and then ten or 15 minutes later

 3     Arkan showed up and said, Let me introduce you to a journalist.  He is

 4     very important.  He works for the CIA.  I remember that very well.  So we

 5     shook hands, and I may have been there for five minutes.  When I heard

 6     that Arkan wanted some weapons from him and wanted him to follow Arkan

 7     around, film him, and make interviews with him for CNN or whatever other

 8     media companies, when I heard that, I just said goodbye and left.  I

 9     didn't want to participate in that because I thought it was crazy for a

10     journalist to be able to procure weapons and how could such things be?

11        Q.   Please tell me if you remember how they talked, in what language?

12        A.   They talked in English.  And my level of knowledge was not very

13     much at the time but I understood some parts of the conversation.  Weapon

14     and so on.  And if he worked for the CIA how could he do it?  No one

15     would allow him to do it at the time and he requested a pair of some

16     special pistols.  But it was all nonsense.  And van Lynden, of course,

17     did not agree to that, nor could he have done it.  I just went back and

18     sat at the table with the company that I had arrived there with and I

19     left soon afterwards, as soon as I had paid my bill.

20        Q.   And during the cross-examination, the Prosecutor also told you at

21     one point -- he made an assertion that Arkan was the commander of the

22     Serb Volunteer Guard.  From what you knew, you confirmed that, as far as

23     I remember?

24        A.   Yes.

25        Q.   On page 10.000, it's also stated that he continued commanding

Page 10752

 1     units of the Serbian Volunteer Guard in operations in the

 2     Republic of Serbian Krajina.  From what you know, did Zeljko Raznjatovic,

 3     Arkan, take part in combat operations in the first place and did he

 4     command any units?

 5        A.   I'm not sure if he personally participated, because as he was

 6     elected deputy in the assembly of the Republic of Serbia, he withdrew

 7     from the military operations, and I wasn't informed about his activities.

 8     I didn't ask him, nor was I on such terms with him, but I know from the

 9     media and from the conversations I had with Mile Novakovic that some of

10     those so-called his men took part in fighting around Obrovac and in

11     fighting on Velebit, and so on.  But it wasn't Arkan.  These were the men

12     that were called his men, in a way, or those who were part of the

13     Army of the Republic of the Serbian Krajina.  I'm not sure what it was

14     then.  But some people did call them the Tigers.

15        Q.   The Prosecutor showed you a document.  If we could please look at

16     it.

17             MR. ZIVANOVIC: [Interpretation] It's P1937, tab 803.  It's on

18     page 10.003.  I think it's on page 2, if we can please have a look at

19     that.

20        Q.   I will try to find it for you on this page, the B/C/S text,

21     regarding your -- your contacts with Arkan.  But it seems that -- yes.

22     Yes.  It's the second paragraph in English, and here -- I think that it's

23     the second paragraph in the first column.  Yes.  Can you see it well now?

24        A.   How does the text begin?

25        Q.   "The former first man of the Republic of Serbian Krajina" --

Page 10753

 1        A.   Yes, yes, I can see it.

 2        Q.   It says:

 3             "I was here with Arkan every day, bombs were exploding all

 4     around, if not for anything else then because of my personal courage and

 5     that's why Zeljko attended the government sessions [sic]."

 6             Could you tell us whether you really told this sentence to the

 7     lady who interviewed you at the time?

 8        A.   I can say that this is the biggest lie and fantasy that anyone

 9     could have imagined and written, not that I ever said it.  I never

10     thought that.  It's not true, not a single letter of it.  No bombs ever

11     exploded in my vicinity.  Arkan was never there.  I was never sitting

12     together with him.  It's probably her -- it's probably she who wrote that

13     in Belgrade but I don't know why.

14        Q.   Tell me, please, during the war, were you in your house in

15     Pacetin all the time?

16        A.   Well, I don't want to make a mistake now.  During the war,

17     perhaps only twice I was there briefly for five minutes to see my mom and

18     dad.  I could not have been there because the house did not have the

19     right amenities.  It didn't have a proper roof.  Had a mortar shell

20     fallen there, it would have killed everyone and we didn't even have a

21     basement where we could hide.  So it was not only that I was not there,

22     even if I wanted to, I ...

23        Q.   [Microphone not activated]

24             THE INTERPRETER:  Microphone.

25             MR. ZIVANOVIC:  [Interpretation]

Page 10754

 1        Q.   Although you've answered my next question in a way, I would like

 2     it to be on the record, nevertheless.  Is this correct that Arkan sat

 3     with you in Pacetin every day, there, in front of your house, while

 4     shells were falling?

 5        A.   Arkan never sat with me in front of my house.

 6        Q.   And is it true that he was at government meetings because he was

 7     brave?  I think that's the way she put it here; is that correct?

 8        A.   Well, no, that is not correct, and this has nothing to do with

 9     anything.  This is absolutely insane.  It wasn't that brave people

10     attended government sessions.  Government members attended the sessions,

11     and that is not an issue now, whether they're brave or not, and if Arkan

12     would enter a government session, he would not be there as a member of

13     the government.

14        Q.   [Microphone not activated]

15             THE INTERPRETER:  Interpreter's note:  Microphone, please.

16             MR. ZIVANOVIC: [Interpretation]

17        Q.   On the fifth page of the English translation here, it says, inter

18     alia, that you said when things were the most difficult in Knin, the

19     response to call-up was 8 per cent; is that correct?  Was that faithfully

20     transmitted?

21        A.   As far as I can remember, this was not recorded, this interview.

22     It was a conversation.  And the journalist took notes.  As for this

23     particular piece of information specifically, I think that after the

24     Maslenica operation, Spanovic, Stojan said to me that the response to

25     mobilisation in Knin was very poor and that it was very low, less than

Page 10755

 1     10 per cent, this first call-up response.  I don't know whether she got

 2     this information from me or from somebody else, but it's not that it's

 3     baseless.  It's the first day of the attack on Maslenica.  Later on, it

 4     increased.  I mean, the response to mobilisation.

 5        Q.   On the third page of this same document, it says that you said

 6     that you started growing a beard at the beginning of the war; is that

 7     correct?

 8        A.   No.  No.  This is an erroneous conclusion on her part or maybe

 9     she heard it from somebody else.  I don't remember these silly details

10     usually, but I do remember when I started growing a moustache and when I

11     started growing a beard.  A moustache in 1981, when I was in the army;

12     and a beard in the spring of 1990, after the second round of Croatian

13     elections, that is to say, a year before the war started.

14        Q.   There's another thing I wanted to ask you, and it's on page 4 of

15     the English translation.  It says that Seselj was an unwanted guest in

16     the Krajina.

17        A.   I'd have to see the context.  Could you please direct me to where

18     it is in the Serbian version.  I think it should be scrolled down.

19        Q.   To the right or to the left a bit?

20        A.   I think it's the next page.

21        Q.   Could be.  I think it's a bit --

22        A.   Yes, yes, I see it now.  Maybe we could zoom in on the left-hand

23     column.

24        Q.   The first paragraph.  Yes, that's it.

25        A.   I have to say that I had this bad clash with Mr. Seselj at the

Page 10756

 1     time and he was an unwanted guest as far as I was concerned and other

 2     people who supported me.  However, I did not meet with him, and I did not

 3     know when it was that he came there.  He never called me.

 4        Q.   On page 10.012, the Prosecutor asked you, inter alia, about a

 5     meeting in the Ministry of Defence of Serbia where the then-minister,

 6     General Simovic, was present, and you were present, and also Arkan and a

 7     person with the nickname Kum.  You wanted to say something -- or, rather,

 8     you were interrupted as you were providing your answer.  So I'd like to

 9     ask you to say what it was that you wanted to say on that occasion.

10        A.   I wanted to say that it was Simovic who invited me to come to

11     this meeting in Belgrade.  Now was it through the secretary, his

12     secretary, or how that Vlade, our secretary.  Arkan was there, and this

13     other person was there, and I don't know what that person's name is.  And

14     I did not take part in this meeting.  I didn't really say anything

15     because I saw that it was really not a serious meeting at all.

16        Q.   As far as I can remember, I think that you wanted to explain then

17     how it was that this meeting took place, or maybe I'm mistaken.

18        A.   I cannot remember now.  I think that my concentration is down a

19     bit.

20        Q.   Well, it's all right.  I'm not going to insist on that question

21     now.  On page 10.008, I'd like to ask you to clarify a particular matter.

22     I'm going to read it out to you, the question and the answer, and then

23     you're going to say what this pertains to exactly:

24             [In English]  "Q.  Continuing down a few lines you say that some

25     people objected, that Arkan attended RSK government sessions.

Page 10757

 1             "A.  I respected his knowledge of the military and thus he

 2     attended the sessions.

 3             "Q.  Now, Mr. Hadzic, what this suggests here is that, in fact,

 4     Arkan attended assembly sessions of the RSK because you wanted him to do

 5     so, isn't that how it was, because of his military skill?

 6             "A.  No, this is absolutely incorrect.  I did not say that nor

 7     can that stand in any sensible way.  In my interpretation, I heard

 8     Assembly but here it says government of the RSK.  I was not a member of

 9     the government.  I had no influence on the agenda.  I didn't attend the

10     meetings.  I personally attended the government meetings maybe two or

11     three times but when I attended, Arkan was not present, so I don't know.

12     These are some conclusions by the journalists and it's not anything that

13     I myself said."

14             [Interpretation] My question:  I see here that what is referred

15     to is Arkan's presence at assembly sessions and government sessions.  So

16     I just wanted to see whether we could clarify the matter.  Can you

17     explain this to us, this answer of yours?  Does it have to do with

18     assembly sessions or government sessions or both?

19        A.   Well, I thought that it pertained to assembly sessions when Arkan

20     could come on his own and sit there as a guest because nobody could expel

21     him or anybody else, and once he attended as a member of parliament of

22     the Republic of Serbia.  And when I said that this is incredible and that

23     it's silly, it's because somebody had said that he came as a military

24     expert.  He never discussed any such thing and nobody ever asked him for

25     his views on anything and these bodies did not discuss military matters

Page 10758

 1     or make decisions on military matters.  I never attended the government

 2     session when Arkan was present there, so I don't know.  According to some

 3     subsequent information, I think he was there only once and I heard that

 4     here when Martic said in a video-clip that Arkan attended a government

 5     session and that they quarrelled.  This is the government of the Krajina

 6     in Knin.  That was my understanding, not the government of Slavonia and

 7     Baranja.

 8        Q.   [Microphone not activated]

 9             THE INTERPRETER:  Microphone, please.

10             MR. ZIVANOVIC: [Interpretation]

11        Q.   Could you please explain the answer you've provided just now, the

12     first sentence, actually:

13             [In English] "I thought that it pertained to assembly sessions

14     when Arkan could come on his own and sit there as a guest because nobody

15     could expel him or anybody else and once ..."

16             [Interpretation] What were you actually trying to say?

17        A.   On the basis of my experience and on the basis of what I know,

18     when Arkan would walk into an assembly session he would just sit there.

19     He'd walk in and sit there.  Nobody had invited him but he'd just stay,

20     and other people, in a way, they could walk in and sit there because

21     nobody asked for identification and nobody was calling out names and

22     saying who could attend and who could not attend.  That is what I was

23     trying to say.

24        Q.   The Prosecutor showed you a document, P1845.


Page 10759

 1             MR. ZIVANOVIC: [Interpretation] It is tab 1282.  Could we have

 2     page 69, please, of the B/C/S original, and page 73 in the English

 3     translation.

 4             Maybe we should start with the previous page of the original.

 5        Q.   Can you see that at the bottom of the page where it starts?  I

 6     mean, what Zivota Panic is saying.  And he says Arkan carried out

 7     missions in this area very well.  At one point he broke away but then

 8     they brought him back, and so on.  However, he is doing Yugoslavia a

 9     disservice.

10             MR. ZIVANOVIC:  May we move to next page in original, please.

11        Q.   [Interpretation] He should be called and given a task.  Those who

12     sent him there should call him.  I do not know who sent him.  However,

13     Arkan was present in Bijeljina, Zvornik, around Sarajevo, Knin,

14     et cetera.

15             This is what I'm interested in now.  You spoke here about going

16     to Bijeljina in order to meet Fikret Abdic, but this is what I'm

17     interested in too.  Did you go to Zvornik when Arkan was there?

18        A.   Well, I went nowhere.  I went to none of these towns, except

19     Bijeljina that is on the road between Knin and Vukovar.  And I did not

20     even know where Arkan was waging war and who he had agreed with.  And I

21     never met with him and I never had the opportunity of discussing these

22     topics with him.

23        Q.   In the next sentence it says:

24             "Somebody is leading him and issuing tasks to him.  We should see

25     who this is.  It is certain that it is not us."

Page 10760

 1             Can you tell us now since it was stated here that Arkan was part

 2     of your security.  Did the members of your security go around Zvornik and

 3     Sarajevo even though you did not go there?

 4        A.   They didn't go anywhere without me.  When they were free, they

 5     were at their homes, and they rested with their families.  As for this

 6     route from Vukovar to Knin, I never went anywhere apart from that, and my

 7     security was never at any place where I did not go to.  So he really has

 8     nothing to do with me, and he was not part of my security.

 9        Q.   In view of the fact -- I'm going to read one portion from this

10     document which was shown to you by the Prosecutor and I'm also going to

11     read the answer you provided.  The page number is 10.041:

12             [In English] "Mr. Hadzic, before the break, we were looking at

13     P1845.

14             "Mr. Stringer:  And indeed the page of B/C/S that we wanted is

15     page 62 of the document in B/C/S which is -- ends with the ERN number

16     4965.  And towards the bottom, that's it.  Thank you.  Toward the bottom,

17     I should say the bottom third, Panic is talking here about the expulsions

18     in Lovas and that Lovas is constantly being watched by Jovic's Chetniks,

19     the White Eagles.  Now, Mr. Hadzic, Zivota Panic knew about this.  It is

20     your evidence that you didn't know anything about Mr. Jovic's activities

21     and those of his White Eagles in Lovas during this period?

22             "A.  Yes, that's what I said that I didn't know anything about

23     it.

24             "Q.  Well, in April of 1992, when this is happening, it was

25     possible for you to go to this area, isn't it?  You were able to move

Page 10761

 1     down through Western Srem.

 2             A.  Yes, it was the Republic of Serbian Krajina at the time, and

 3     it was all free, and then in the next paragraph he says that we must have

 4     a serious showdown with Arkan and the White Eagles.  He says Arkan is led

 5     by Hadzic."

 6             [Interpretation] Tell me, please -- as a matter of fact, I'm

 7     going to finish the quote so that I don't have to come back to it later:

 8             [In English] "Mr. Stringer:  Could we have tab 459, please,

 9     Exhibit P1845, page 86 of the English; page 62, 63 of the B/C/S.

10             "Q.  Mr. Hadzic, this is the record of the SFRU Presidency held

11     in April of 1992, the 16th, do you recall what Mr. Panic's position was

12     at that time?

13             "A.  I think that he was the commander of the

14     1st Military District but I'm not 100 per cent sure about it.

15             "Q.  We can go back to page 2 of this.  Indicates that as of that

16     time of this meeting, he was the acting chief of the General Staff or

17     Chief of the Main Staff of the JNA.  Would you disagree with that?

18             "A.  I agree.  I'm just a bit confused.  I know that he was

19     appointed a commander of the 1st Military District, but I don't know that

20     he was appointed commander.

21             "Q.  Now moving to page 86 ..."

22             [Interpretation] I'll stop here and invite you to provide an

23     explanation at this point regarding what we see on the screen.

24     General Panic, while saying that Arkan was in Bijeljina, Zvornik, around

25     Sarajevo and in Knin said, Somebody is leading him.  Somebody is giving

Page 10762

 1     him his tasks.  You had the opportunity to hear at that same meeting that

 2     somebody said that you were actually leading him, that Arkan was led by

 3     Hadzic.

 4             Tell me, please, do you think that, in your view, while

 5     General Panic was speaking at that meeting was he sincere?  Was he honest

 6     when he said that you were the one who was leading Arkan, or was he was

 7     sincere when he said that he didn't know who was leading Arkan and who

 8     gave him his task?

 9        A.   I don't think that he was sincere when he said it was me.  But he

10     was also not sincere when he said he didn't know who was it.  Because

11     before that, Panic says that Arkan carried out his task well which means

12     that it was the JNA who led him.  But then he realised that he made a

13     mistake, that he put his foot in his mouth so he tried to reiterate so

14     Arkan was led by the army, and the army were one and the same, so Panic

15     lied because he was speaking before the Presidency, the highest body of

16     Yugoslavia that appointed him.  He lied, so he actually made up that it

17     was me.  But everybody understood that he was lying.  I'm sure that

18     everybody understood then and still understand now.  I really didn't have

19     anything to do with Arkan.  I didn't have any information whatsoever

20     about Arkan's work or who was behind that work.  Obviously Panic knew

21     that very well, but he did not want to say.

22        Q.   Could you please tell me whether you can conclude from the text

23     or perhaps you know from some other sources what tasks did General Panic

24     have in mind when he said that Arkan carried them out really efficiently?

25        A.   I can only assume that Panic was satisfied with his activities in

Page 10763

 1     Slavonia and Baranja when he was a member of Biorcevic's corps.  I can

 2     only assume that because I didn't hear anybody from the army attacking

 3     him but I never attended meetings with him on those issues.  Nobody

 4     reported to me either orally or in written form about any of those

 5     things.

 6        Q.   Did you have an opportunity to either see or hear that some

 7     high-ranking officers said something good about the behaviour of

 8     Zeljko Raznjatovic, Arkan, and his unit?

 9        A.   Yes, I did have such opportunities.  I saw it in the newspaper --

10     newspapers.  General Biorcevic commended him, and also both him and Badza

11     were rewarded with some trophy weapons.  He moved in those circles in

12     Belgrade among very influential people, that is.  At that time I couldn't

13     do that, nor did I have any opportunity to meet with anybody of those

14     people and rub shoulders with them like Arkan did.

15        Q.   Do you know, do you remember who awarded him with those trophy

16     weapons in recognition of his work?

17        A.   It was the commander of the Novi Sad Corps, Andrija Biorcevic,

18     who did that.  That was the same general who, after the liberation of

19     Vukovar, was received by General Panic, who was the chief of the

20     General Staff.  He was the first next to him.  Panic congratulated him on

21     that occasion.  He was one of Panic's closest associates.

22        Q.   Amongst other things, I quoted a portion of a question relative

23     to Jovic's Chetniks, White Eagles, to be more precise, what General Panic

24     said about Lovas, Jovic, and all those things.

25             MR. ZIVANOVIC: [Interpretation] Can we now look at the same

Page 10764

 1     document, page 67, in the original, and in English, it would be page 70.

 2     [In English] If we could scroll down English text, please.  Oh.  Maybe

 3     you should move to the next page in English.  That's it.

 4        Q.   [Interpretation] This is paragraph 1 in English, as well in the

 5     original.  You'll find that in the first paragraph.  This is what

 6     Borisav Jovic said.  He said:

 7             "When it comes to the Eagles and Arkan, I believe that the

 8     military should arrest all of them pursuant to our order."

 9             Could you please tell me whether you remember what

10     Borisav Jovic's position was at the time.

11        A.   I believe that he was the acting president of the Presidency of

12     the SFRY, which means number one man of the Supreme Command.

13        Q.   The Supreme Command that you are talking about is the

14     Supreme Command of the armed forces of the SFRY.  Did I understand you

15     well?

16        A.   Yes, you did.  At that time, it was still the JNA, but he was the

17     number one man of its Supreme Command, I believe.

18        Q.   Tell me, please, in view of the time when this happened and in

19     view of everything that I told you about General Panic's words and I even

20     quoted from his discourse where he said that at one point you were the

21     one who was leading Arkan.  Were you at all informed about the

22     requirement to arrest Arkan?  Were you told that you should do something

23     about that?

24        A.   No, never.  At that time everybody knew that he was under the

25     direct subordination and control of Belgrade and that he had nothing

Page 10765

 1     whatsoever to do with the Krajina Serbs, that he had arrived as a member

 2     of federal institutions.  That's how he behaved.  Nobody from Belgrade

 3     ever sent me either a verbal or a written report or complaint about his

 4     conduct in the area.

 5             I understand why they didn't, because everybody knew that I was

 6     not responsible for any of that.  That's the most logical explanation.

 7        Q.   On the 21st of July, the Prosecutor showed you yet another

 8     document; it's P1878.

 9             He also showed you something.  In order to avoid rephrasing, I'm

10     going to read the question to you.

11             MR. ZIVANOVIC:  Could we have, please, P1878, tab 531:

12             "Q.  Mr. Hadzic, while it's come up, this is the Supreme Defence

13     Council of the FRU in July of 1992, about thee months after the meeting,

14     the Presidency meeting, we were just talking about.  Zivota Panic present

15     there.  And I would direct your attention to page 14 of the English, 16

16     of the B/C/S.  And here now in July of 1992, Panic is saying:  Many

17     things have been said about Arkan.  Measures had been taken.  However,

18     you should look for Goran Hadzic to find out what Arkan doing.  He keeps

19     him around as a body-guard and he leads him.  And then in the next

20     passage, Momir Bulatovic says essentially that Arkan is getting stronger

21     again.  That means someone was -- someone is behind these people.  The

22     question now, Mr. Hadzic, is again here in July of 1992, it is Zivota

23     Panic who is correct, isn't it, that, in fact, if somebody wanted to know

24     where Arkan was and what he was doing, they just should find you because

25     Arkan was close to you as a body-guard?"

Page 10766

 1        Q.   [Interpretation] I will kindly ask you to look at the following

 2     page in the same document.  We have not seen that page yet.  In English,

 3     it's actually on the same page.  You don't have to change the English

 4     page for the time being?

 5             Slobodan Milosevic also attended that meeting and he says -- the

 6     question was:

 7             "And he has units?"

 8             Slobodan Milosevic answers:

 9             "I don't think so.  No, according to the information that I

10     received from our ministry, he doesn't have any.  Arkan was also a

11     volunteer at the time when the army was operating on the battle-field and

12     he was under the army command.  He was not on his own."

13             I'm going to ask you this:  Do you think that Slobodan Milosevic

14     who shared the information that he received, that he didn't have any

15     other information.

16        A.   What he said at the end that he was under the control of the

17     army, that's correct.  And what he said before that, that he didn't have

18     information, I don't think that he was telling the truth.  I believe that

19     Milosevic knew very well what Arkan was doing and who was behind Arkan.

20     I believe that he had complete information, unlike me.

21        Q.   Can you explain why General Panic again brought him in connection

22     with you?  Obviously you can explain if you know.  Why did he put Arkan

23     in that same context again and claim that he was your body-guard?

24        A.   I believe that he was trying to deceive all those people at the

25     meeting, if that was at all possible.  Because everybody knew that he


Page 10767

 1     didn't have anything to do with me.  On the previous page, Bulatovic said

 2     that he was driving around Herzegovina in a car with police registration

 3     plates.  Everybody knew that this was a blatant lie, that Arkan enjoyed

 4     support from Belgrade.  You can look at the following page of the Serbian

 5     text.

 6        Q.   It's on the previous page.  However, in the English version,

 7     Bulatovic's words appear on the page that we have on the screen in the

 8     first line at the top of the page.

 9        A.   And let me just tell you that I was never in Herzegovina, not

10     during the war, not before the war.

11        Q.   The Prosecutor showed you a document, 1908; transcript page 1047.

12     And on page 1049 --

13             THE INTERPRETER:  The interpreter's correction:  10.049.

14             MR. ZIVANOVIC: [Interpretation]

15        Q.   He asked you a question that I will now read out to you.

16     Reads -- he is actually quoting General Panic.

17             MR. STRINGER:  Sorry, counsel.  I believe this was led in

18     private session, Your Honour.

19             MR. ZIVANOVIC:  Yes, yes, okay.  Maybe.

20             JUDGE HALL:  So should we go into private session for you to --

21             MR. ZIVANOVIC:  Yes.

22             JUDGE HALL:  -- put the question.  Yes.

23                           [Private session]

24   (redacted)

25   (redacted)

Page 10768











11 Pages 10768-10769 redacted. Private session.
















Page 10770

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4                           [Open session]

 5             MR. ZIVANOVIC:  Sorry.  Yes.  Yes, that's correct.

 6             JUDGE HALL:  Mr. Zivanovic the interpretation was still ongoing

 7     from your last question, so I missed the last thing you said.

 8             MR. ZIVANOVIC:  I can repeat it in open session as well.  I just

 9     said to Mr. Hadzic that I'll not show him this document that he mentioned

10     because they are already in evidence and they were not subject of the

11     cross-examination.

12             JUDGE HALL:  I thought you had said something after that.

13             MR. ZIVANOVIC:  No, no, after that nothing.  Yeah, I just said

14     that it is time for a break.

15             JUDGE HALL:  So we take the adjournment until tomorrow morning at

16     9.00.

17                            --- Whereupon the hearing adjourned at 2.00, to be

18                           reconvened on Tuesday, the 2nd day of September,

19                           2014, at 9.00 a.m.