Tribunal Criminal Tribunal for the Former Yugoslavia

Page 11048

 1                           Monday, 8 September 2014

 2                           [Open session]

 3                           [The accused entered court]

 4                           --- Upon commencing at 9.13 a.m.

 5             JUDGE DELVOIE:  Good morning to everyone in and around the

 6     courtroom.

 7             Madam Registrar, call the case, please.

 8             THE REGISTRAR:  Good morning, Your Honours.  This is the case

 9     IT-04-75-T, The Prosecutor versus Goran Hadzic.

10             JUDGE DELVOIE:  Thank you.

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

12     Prosecution.

13             MR. STRINGER:  Good morning, Mr. President, Your Honours.  For

14     the Prosecution, Douglas Stringer; Alex Demirdjian; Thomas Laugel;

15     legal intern, Ljubica Vukcevic.

16             JUDGE DELVOIE:  Thank you.

17             For the Defence, Mr. Zivanovic.

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

19     Goran Hadzic, Zoran Zivanovic and Christopher Gosnell.

20             JUDGE DELVOIE:  Thank you.

21             The witness may be brought in.

22                           [Trial Chamber confers]

23                           [The witness takes the stand]

24             JUDGE DELVOIE:  Good morning, Mr. Vukcevic.  May I remind that

25     you're still --


Page 11049

 1             THE WITNESS: [Interpretation] Good morning.

 2             JUDGE DELVOIE:  May I remind you that you are still under oath.

 3             Mr. Zivanovic, please proceed.

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

 5                           WITNESS:  VOJISLAV VUKCEVIC [Resumed]

 6                           [Witness answered through interpreter]

 7                           Examination by Mr. Zivanovic: [Continued]

 8        Q.   [Interpretation] Mr. Vukcevic, good morning.

 9        A.   Good morning.

10        Q.   On Thursday, we left it off with you talking about the

11     negotiations with the HDZ in 1990, in the month of August of that year.

12     The representative of the HDZ was Mr. Vekic.

13             I would now like to show you some proposals that you prepared

14     which were subsequently published in the media.

15             MR. ZIVANOVIC:   May we see, please, 1D3744.  It is 1D3744.

16             JUDGE DELVOIE:  Tab number, please?

17             MR. ZIVANOVIC:  Frankly, I don't have tab number.

18        Q.   [Interpretation] Do you remember this text or, rather, this

19     article on the right-hand side of the screen?

20        A.   Of course I remember it because I wrote it myself.

21        Q.   As you can remember, there are eight proposals here.  You had

22     drafted them on behalf of the SDS.  Let's talk about proposal number 1.

23     You say:

24             "We propose that the implementation of a demand reminiscent of

25     Fascist behaviour, by the citizens of Sibenik ..." I am repeating because

Page 11050

 1     this has not been recorded.  "... to expel or drive out --"

 2        A.   "... reminiscent of Fascist behaviour ..."

 3        Q.   "Dr. Raskovic, SDS president; Branko Popovic, SDS general

 4     secretary; and Marko Dobrijevic, SDS executive committee member, to be

 5     stopped in an appropriate but firm manner, and that the decision

 6     terminating their employment because they failed to return on time from

 7     their annual leave be annulled."

 8             And you also say that it is against common sense to expel

 9     somebody out of a city where they live and work and especially if they

10     want to return to the city from which they had been expelled after the

11     annual leave.

12             Finally, you cite the provisions of the constitution which

13     indicate that this decision is against the law.

14             What kind of decision are you talking about?  What did the

15     citizens of Sibenik decide?  How come that these three people were

16     expelled from that city?

17        A.   I can't remember the details of that decision.  However, it was a

18     time when a little spark could cause a forest fire which spread really

19     quickly.  An atmosphere of intolerance was created.  Reasons were being

20     sought to blame people, to accuse them of things, to engage in illegal

21     and bad behaviour.  And then, based on that, if things were established

22     to be as they were purported to be - and I'm talking about the

23     accusations against the Serbs - the awareness was created about the Serbs

24     that they were a destructive, evil people who had to be blamed for all

25     the misfortune and hardship of the Croatian people.

Page 11051

 1             The three people in question, of whom two were natives of

 2     Sibenik, while Professor Jovan Raskovic also spent his entire life in

 3     that city, were supposed to be condemned after that.

 4        Q.   As we are reading this text, we see that you say in it - and this

 5     has not been recorded - you say that this had to be prevented in an

 6     appropriate and decisive manner.  Could you please tell us what you

 7     referred to, what you had in mind?

 8        A.   Well, I wanted people to stop talking, that they should be

 9     expelled from the city.  I wanted them to start saying that they should

10     stay living in the city where they had lived up to then.  As you can see,

11     and as can you read, I am referring to article 259, paragraph 1, of the

12     constitution of the Republic of Croatia, which is a legacy of the

13     civilisation and law contained in all the constitutions of the world.

14     According to that article, the citizens are guaranteed freedom of

15     movement and establishment of residence.  I had the right to move and

16     live where I see fit.

17        Q.   One more question about that.  That demand on behalf of the

18     citizens of Sibenik for the three Serbs in question to be expelled from

19     that city, how was it received among the Serbs, not only in Sibenik but

20     in the general area?

21        A.   Those were the first such extreme cases.  Obviously they confused

22     every normal person who didn't even have to be a Serb.  They couldn't

23     understand how things like that could happen so many years after the

24     Fascist rule had reigned.  Obviously the Serbian Democratic Party as an

25     organisation aimed at protecting the interests and positions of the Serbs

Page 11052

 1     in Croatia felt to have been put on spot.  They felt the need to protect

 2     the individuals belonging to their people.

 3        Q.   One more question about this.  Dr. Raskovic, Branko Popovic and

 4     Marko Dobrijevic, did they remain living in Sibenik or did they have to

 5     leave it?

 6        A.   They left Sibenik.

 7        Q.   Thank you.

 8        A.   My pleasure.

 9        Q.   Under 6, you requested that the legality and legitimacy of the

10     Serbian plebiscite should be recognised.  What plebiscite are you talking

11     about?

12        A.   On Thursday I spoke about the plebiscite and referendum and I

13     emphasised that I had insisted on the referendum not being organised but,

14     rather, that a plebiscite should be organised which was a more democratic

15     form of decision-making.  Its aim was to look at all the things that were

16     happening during the turbulent times and to legalize them in a certain

17     way, in a democratic way, to show that it was not a will of a mere few

18     individuals but the will of the entire people, and I mean the Serbian

19     people.  You will understand that this was of real interest, and this was

20     the desire of every political factor and every political people in all

21     countries and in all times.

22        Q.   What was the question asked at this plebiscite where the Serbian

23     people had to declare themselves?

24        A.   The Serbian people declared that they wish and demand, and here I

25     have to draw your attention to the fact that Serbs wanted and were

Page 11053

 1     defending a country called Yugoslavia from any attempt, especially the

 2     attempts of Croatia and the Croatian new ideology, to eliminate that

 3     country --

 4             JUDGE DELVOIE:  Mr. Vukcevic, could you please focus on the

 5     question Mr. Zivanovic put to you.  Mr. Zivanovic asked what the question

 6     was in the plebiscite.  What question did people have to respond to by a

 7     yes or a no?

 8             THE WITNESS: [Interpretation] Serbs wanted cultural autonomy, the

 9     use of their language and script in Croatia in the event that Croatia

10     should stay within Yugoslavia.  If Croatia were to separate from

11     Yugoslavia --

12             JUDGE DELVOIE:  Mr. Vukcevic, do you remember what the question

13     was in the plebiscite?  Was it one question?  Were there many questions?

14             THE WITNESS: [Interpretation] No, there were two questions.

15             JUDGE DELVOIE:  And what were the two questions, please.

16             THE WITNESS: [Interpretation] Do you wish culture autonomy if

17     Croatia remains within Yugoslavia?  And if Croatia should secede, do you

18     want political autonomy?

19             JUDGE DELVOIE:  Please proceed, Mr. Zivanovic.

20             MR. ZIVANOVIC: [Interpretation]

21        Q.   At this plebiscite, was the question ever asked whether, in the

22     event Croatia should secede, Serbs wished to stay within Yugoslavia?

23        A.   Did Serbs want to remain within Yugoslavia?  We didn't ask that

24     question, but we knew they wanted that.

25        Q.   In item 7, you asked for elections that would enable the Serbian

Page 11054

 1     people to independently propose and elect their own representatives

 2     within the Croatian parliament.

 3             Was this proposal accepted?

 4        A.   None of the proposals that are before you was accepted, and none

 5     of them was given due consideration.  It is curious that this particular

 6     proposal you mentioned under number 7 was decided upon in the way that I

 7     proposed only ten years later, when Croatia adopted the Law on the

 8     National List.  There was the state list that you receive in the ballot

 9     box, and you receive the national list, exactly as I proposed and

10     demanded, to choose from the national list the person you want to

11     represent you.

12        Q.   Can you tell us, do you know a person known as Borivoje Savic?

13        A.   I do.

14        Q.   When you spoke about these proposals and at the negotiations with

15     Mr. Vekic, was Borivoje Savic the one who decided that these negotiations

16     should be conducted?

17        A.   No.

18        Q.   Did Borivoje Savic perhaps prepare you for these talks and how

19     you should engage in them?

20        A.   No.

21        Q.   Did he send you to Dr. Raskovic in Sibenik for consultations,

22     maybe?

23        A.   No.

24        Q.   Were you a member of the Main Board of the SDS?

25        A.   Yes.

Page 11055

 1        Q.   Were you a member of the Main Board ex officio because you said

 2     you were the president of the Municipal Board of the SDS for Baranja?

 3        A.   For the province, yes, ex officio, I was.

 4        Q.   Was Goran Hadzic a member of that Main Board?

 5        A.   Yes, yes.

 6        Q.   Could you briefly tell us if you attended the meeting of the

 7     Main Board of the SDS in Lapac in February 1992; and, if you did, tell us

 8     what happened there.

 9        A.   We met there so that the highest officials of the party could

10     state their position as to whether we were going to follow the course

11     charted by Milosevic for us, through his representatives, or we were

12     going to show that we were aware we were living in a different area in

13     which we were not alone.

14             Milan Babic was in the faction that was spurred on by Milosevic,

15     but the number of people opposed to him, opposed to that faction, was

16     constantly growing.  We voted on that occasion, and Milan Babic, with

17     several of his faithful followers, lost this vote.  He was defeated.  He

18     was defeated by the Serbs, and it really happened the way I'm telling

19     you.

20             If you allow me to explain it a little more.  Those who defeated

21     Milan Babic and his faction were the Serbs who wanted to peacefully

22     co-exist with Croats and who believed that it was possible.

23             MR. ZIVANOVIC:  Your Honours, I would tender the document on the

24     screen.  It is 1D2401.

25             MR. DEMIRDJIAN:  Your Honours, I do not object to the

Page 11056

 1     admissibility of the proposals.  However, this is published in a

 2     newspaper article and we have a -- I believe what is the original on

 3     tab 3 of the Prosecution list.  I will also be using it in

 4     cross-examination.  I'm wondering, in order to avoid duplication, whether

 5     it would make sense to have the original.  And perhaps if my learned

 6     friend wishes to do so, he can display it on the screen now to ensure

 7     that Mr. Vukcevic agrees that this is the proposals he made.  The 65 ter

 8     is 6576 -- yes.

 9             MR. ZIVANOVIC:  Yes, I noticed this document on the Prosecution

10     list, and it is absolutely the same as the document published in this

11     article, newspaper article.  I don't object if this document would be

12     tendered instead of the one that we see on the screen.

13             JUDGE DELVOIE:  Okay.  Let's admit the original then.

14             THE REGISTRAR:  Exhibit --

15             MR. ZIVANOVIC:  If it was original, I'm not very -- if it was

16     original.

17             JUDGE DELVOIE:  Okay.  Let's see it on the screen, please.

18             THE WITNESS: [Interpretation] Yes, that's the photograph from the

19     cover page.

20             MR. DEMIRDJIAN:  We need to go to page 2.  This is not it.

21             MR. ZIVANOVIC:  I don't see the other pages because the proposal

22     had the eight items.

23             JUDGE DELVOIE:  Can we have the next page, please.

24             MR. ZIVANOVIC:  Yes.

25             JUDGE DELVOIE:  Seven, eight.

Page 11057

 1             MR. ZIVANOVIC:  Does it -- however, I would ask just two pages of

 2     this document to be admitted because the first page is not -- is not the

 3     proposals of Mr. Vukcevic.  And in that case, I would -- if not, I would

 4     ask the tendering of this document that I used for cross -- for the

 5     direct examination of Mr. Vukcevic.

 6             MR. DEMIRDJIAN:  We can remove the first page, Your Honours, and

 7     solve this during the break with Mr. Zivanovic.

 8             JUDGE DELVOIE:  Okay, let's do that.  So you'll come back to us.

 9     Okay, Mr. Zivanovic?

10             MR. ZIVANOVIC:  Okay.  Yes, yes, Your Honour.

11             JUDGE DELVOIE:  Thank you.

12             MR. ZIVANOVIC: [Interpretation]

13        Q.   Mr. Vukcevic, at this meeting in Donji Lapac, did Goran Hadzic

14     also attend?

15        A.   I believe so.

16        Q.   Can you remember what he voted for, what he favoured?

17        A.   Goran Hadzic was always in favour of peacefully co-existing with

18     the Croats, avoiding conflict, preferring negotiations and talks and

19     agreement.

20             MR. ZIVANOVIC:  May we see, please, 1D3745.

21             JUDGE DELVOIE:  Could you give us a tab number, please,

22     Mr. Zivanovic.

23             MR. ZIVANOVIC:  Just a moment, sorry.  It is tab 11.

24             JUDGE DELVOIE:  Thank you.

25             MR. ZIVANOVIC: [Interpretation]

Page 11058

 1        Q.   You probably remember this article on the screen, the newspaper

 2     articling titled:  "Who Shot" -- "Who Fired at the House of V.

 3     Vukcevic."

 4             Is it about your house?

 5        A.   Yes, it is about my house.  I am the one whose house was fired

 6     at.

 7        Q.   In the subheading, we see that, according to the unofficial

 8     version, it was discontented members of the SDS who fired at the house.

 9     Can you tell us something about it?

10        A.   From the early days of the Serbian movement in Croatia, there

11     were two factions:  One that wanted a humane and proper agreement with

12     majority people, the Croatian people; and another faction that stood in

13     its way.  This second faction was supported by people close to Milosevic.

14             This brave Serb who, in the small hours, parked his car outside

15     my house and fired through the window at a room upstairs was from the

16     ranks of this second faction, and the immediate reason for that was

17     precisely the meeting in Donji Lapac, where Milan Babic and his faction,

18     the faction that he led and spoke for, was defeated.  And the people who

19     were in the car with the shooter knew that I belonged to the other side

20     and that I advocated negotiations and talks with Croatia.  So to punish

21     me for that, they fired at my house.

22             That night the telephone rang, and my wife answered and a voice

23     said, "This time we fired at your house.  The next time we will fire at

24     your head."  I was still not at home that night.  I was not able to drive

25     because of bad weather, and I stayed that night at the hotel, but the

Page 11059

 1     next day when I came home, I heard what had happened.

 2        Q.   If I understood you correctly, this happened immediately after

 3     the meeting in Donji Lapac.

 4        A.   Yes, it happened the night after the meeting, because the news

 5     that the faction of Milan Babic was defeated and that the people around

 6     him, the people who were representing that option, were losing their

 7     positions and losing their importance came after the meeting, and they

 8     wanted to remain important.

 9        Q.   Do you remember and did you attend the meeting of the Main Board

10     of the SDS in Obrovac in March 1992?

11        A.   It was a meeting of the Executive Board of the SDS.  Yes, I

12     attended that meeting.  It was the Saturday of the Catholic Easter 1991.

13        Q.   Do you remember that just after that Borivoje Savic and

14     Goran Hadzic were arrested at Plitvice?

15        A.   Certainly.  We left the meeting in small groups or one by one,

16     and so Boro Savic, Goran Hadzic and I found ourselves in the street

17     together.  They were close friends of mine and I invited them to come to

18     Beograd on the sea and spend that night at my apartment to rest before

19     the trip that was ahead of us.  However, they said they couldn't because

20     the next morning they had to be in Vukovar; they already had commitments.

21     So I remember very well every detail about that date.

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

23     the screen into evidence.  Sorry, I'll repeat.  I would tender the

24     document from the screen into evidence.

25             JUDGE DELVOIE:  Admitted and marked.

Page 11060

 1             THE REGISTRAR:  Exhibit D183, Your Honours.

 2             JUDGE DELVOIE:  Thank you.

 3             MR. ZIVANOVIC:  May we see, please, 1D3746.  It is tab 12.  Would

 4     you move the original text to the left.  Yes.

 5        Q.   [Interpretation] Mr. Vukcevic, you will see here a newspaper

 6     story from Politika of 31 April 1991 speaking about the situation in

 7     Borovo Selo.  It was a time when Savic and Hadzic were in prison.  I had

 8     not ask you about it, but I want you to look at the box on the right-hand

 9     side where it says, "Vukcevic may not represent us."  You will see it now

10     enlarged on the screen so you can read it.

11        A.   Yes, I see it, and I have it in my collection of documents.  Yes.

12     What is your question?

13        Q.   My question is:  Are you aware that, on the 1st of April or

14     perhaps the day before, on the 31st of March, such a decision was made

15     that you may not be a representative?

16        A.   I learned about it from the newspapers, like everyone else.  Of

17     course, that decision was not possible.  It was impossible to make that

18     decision there.  There was a body above the body indicated on the screen

19     that had decided that I would be the only authorised representative of

20     the Serbian community with the Croatian Democratic Union and only the

21     Executive Board could repeal that decision.  Certainly a local body could

22     not repeal it.  And what we see here is a local body.

23             MR. ZIVANOVIC:  Your Honour, I would tender this document into

24     evidence.

25             JUDGE DELVOIE:  Admitted and marked.

Page 11061

 1             THE REGISTRAR:  Exhibit D184, Your Honours.

 2             MR. ZIVANOVIC: [Interpretation]

 3        Q.   You were in Beli Manastir at the time when the armed conflict in

 4     Croatia had already begun.  Can you tell us if the municipality of

 5     Beli Manastir had taken any steps to prevent this conflict?  Tell us

 6     briefly and then we will look at a document.

 7        A.   Beli Manastir is a relatively small place, small town.  It has

 8     the status of a town in a part of Croatia which historically is a

 9     province called Baranja.  The population is made up of three communities:

10     Serbs, Croats, and Hungarians.  There was a fourth group that declared

11     themselves as Yugoslav.  Unfortunately, or fortunately, they were not

12     recognised after the time we are discussing as Yugoslavs.  They were

13     required to declare themselves as Serbs, Croat, or Hungarians.

14             None of this was accepted.  People were very distrustful, had a

15     lot of misgivings.  The parliament was elected from all the three, or,

16     let's say, four communities, including the Yugoslavs, and every

17     representative wrote his ethnicity next to his name.  There was a total

18     of 250 of them.  That parliament, such as it was, adopted a decision to

19     oppose any change of border, any change at all, in the territory of

20     Yugoslavia, a decision that Baranja was part of Yugoslavia and would

21     remain so and would oppose any change.  That is the environment in which

22     I lived.

23             MR. ZIVANOVIC:  May we see, please, 1D --

24             MR. DEMIRDJIAN:  I apologise.  Your Honours, I'm looking at the

25     65 ter summary provided for Dr. Vukcevic, and this subject and this line

Page 11062

 1     of question is not included at all, nor is it included in the 92 ter

 2     statement.  So, on that basis, we have no notice that any questions are

 3     expected in relation to the situation in Beli Manastir or any measures to

 4     prevent the conflict.

 5             MR. ZIVANOVIC:  That's correct.  However, during the proofing

 6     with Mr. Vukcevic, I got one document - it is a one-page document - about

 7     the situation in Beli Manastir on 3rd of July, 1991, and the decisions of

 8     the municipal assembly related to the situation.  I informed the

 9     Prosecution in the form of proofing notes about this document and my

10     intention to use this document.  I put it both on our amended Rule 65 ter

11     list and the document was on our Defence list for this witness.

12             MR. DEMIRDJIAN:  May I inquire:  Are the questions going to be

13     limited to this one document?

14             MR. ZIVANOVIC:  That's correct.

15             MR. DEMIRDJIAN:  In that case then, I withdrew my objection,

16     Your Honours.

17             JUDGE DELVOIE:  Thank you.

18             MR. ZIVANOVIC:  May we see, please, 1D3747.  It is tab 13.

19        Q.   [Interpretation] Mr. Vukcevic, I believe that you have that text

20     in front of you.

21        A.   Yes, I do.

22        Q.   Let's first look at the text on the left-hand side of the screen

23     or, rather, the first column in the B/C/S text headed, "Conclusion."  I'm

24     interested in the second sentence which reads:

25             "Fear and distrust have led to the emigration of children, women,

Page 11063

 1     even whole families, and almost every village is organising some sort of

 2     self-defence."

 3             Did you find it?  In the first paragraph under "Conclusion"?

 4        A.   No, I can't find it.

 5        Q.   The second sentence --

 6        A.   Yes, now I've got it, "Fear and distrust," yes.

 7        Q.   My question is this:  When it comes to this sentence, does it

 8     faithfully reflect the situation in Baranja at that time?

 9        A.   Well, look, the sentiment changed from one village to the next,

10     from one environment to the next.  In one village, there were people who

11     really did move out, and in another village, there were people who

12     prevented such behaviour and they were saying that there was no need to

13     move out because nothing would happen to anybody.

14             In any case, the general sentiment and the general state of

15     affairs was that of sickness of abnormality and one would say that it

16     sooner reflected this.  I repeat:  There were 250 members of the local

17     parliament, including members of all the peoples.

18        Q.   And now let's look at the second paragraph and read the last

19     sentence in it.

20        A.   Yes, I understand.

21        Q.   The last sentence which reads:

22             "Unlike the earlier assembly structure, the present composition

23     of the assembly has no powers over the MUP, the judiciary, the

24     prosecutor's office ... "

25        A.   "The health care, the secondary education," et cetera?

Page 11064

 1        Q.   Yes.  I would like to invite your comment on just one thing.

 2     What does this mean?  What does it mean that the present composition has

 3     no powers over the MUP and the judiciary?

 4        A.   I should use a few words.  I don't know whether I may be allowed

 5     to use a lot of words.  The election in Croatia was in 1992 and the

 6     document was drafted in 1991.  As soon as they took power, the HDZ and

 7     its representatives, they instilled changes in the organisation of

 8     powers.

 9             Up to then I was the president of the court in Beli Manastir.

10     And up to then, us judges and the president of the court were either

11     elected or appointed or nominated by the local parliament.  As of

12     April 1990 that practice stopped.  The state took over in order to be

13     able to control the election of people into various positions, and so on

14     and so forth.

15             In the space of just one year, from April 1990 to July 1991, when

16     this conclusion was issued, many changes had taken place.  However,

17     despite that, among the people, there was still the awareness, the desire

18     and the need to live together.  That is a fact.  There's no two ways

19     about it.

20        Q.   Mr. Vukcevic, I would also kindly ask you to look at the other

21     document on the same page, and this is the amendments to the resolution

22     on the peaceful co-existence of the citizens of Baranja.

23             MR. ZIVANOVIC:  May we move to next page of the English

24     translation, please.

25        Q.   [Interpretation] You've told us that the municipal assembly of

Page 11065

 1     Baranja made the decision that the borders should not be changed.  Could

 2     you please look at the text of the document --

 3        A.   Of course.

 4        Q.   -- and can you tell us whether this was the document that

 5     established that the borders shouldn't be changed, as you have just told

 6     us.

 7        A.   Well, you have to understand that I have to go back to the fact

 8     that this was a decision issued by the local parliament and that the

 9     local parliament had been elected directly by all those who had the right

10     to vote, and that the local parliament encompassed representatives of all

11     the three peoples.  Even a year into the HDZ rule in Croatia, they still

12     managed to decide that the borders shouldn't be changed, that Baranja

13     should be part of Croatia and that Croatia should be part of Yugoslavia

14     and that they didn't want those facts and that community to be altered in

15     any way.

16        Q.   At that time on the eve of the clashes and during the clashes,

17     you had plenty of opportunities to listen to the statements given by the

18     politicians on both sides.  We've also had opportunities to hear verbal

19     threats addressed at each other.

20             First of all, tell us whether such statements were typical of

21     only one side, or the other side, or of both sides?

22        A.   It was a time when people behaved aggressively.  Their conscience

23     was distorted.  It was a crazy time.  One didn't know whether you would

24     wake up in the morning, having gone to bed the previous night.  Both

25     sides, unfortunately, were equally mad.  The less numerous ones that I

Page 11066

 1     belonged to tried and fought hard to adhere to the form of consciousness

 2     that had existed and persisted from the end of the Second World War, and

 3     that was the awareness of the importance of a community; whereas, those

 4     who were more numerous were very, very aggressive.  It was painful.  You

 5     can't even begin to understand how terrible that was.

 6        Q.   You communicated with Goran Hadzic.  How well did you know him?

 7     What did you think of him and his behaviour under the circumstances?

 8        A.   We met quite often.  We often travelled together.  Whenever we

 9     went to the meeting of the Main Board of the Serbian Democratic Party,

10     which usually took place in Knin, and that was 650 kilometres away from

11     the cities where we lived.  We travelled together, and during such long

12     journeys we talked about all sorts of things.

13             I know Goran's family.  I know where he was born, his social

14     environment, where he grew up.  It was a very tame environment, a very

15     regular family, and nobody who hailed from that family could even have

16     dirty shoes, let alone something bad on his mind.  There was a lot of

17     order in that family, so there could be nothing disorderly about anybody

18     who hailed from such a family.  He was well nurtured.  He was well fed,

19     well clothed.  He had everything that he needed in life.  He could not be

20     spiteful, he could not be evil, he could not be a bad man.

21        Q.   Mr. Vukcevic, just one more question for you.  You said that

22     there was a stream that strongly advocated co-existence with Croats and

23     there was another stream which -- where would you classify Goran Hadzic?

24        A.   I would certainly put him among those of us who wanted to live

25     together with the others.

Page 11067

 1        Q.   And now, after all the developments, in hindsight, that desire

 2     for Croats and Serbs to live together in Croatia, has that materialised?

 3        A.   It is very hard to talk about other people's opinions about other

 4     people's fortunes or misfortunes.  Everyone can speak for themselves.

 5     However, from what one hears and from what one knows, things as they are

 6     now are a far cry from what they used to be before.

 7        Q.   Thank you, Mr. Vukcevic.  I have no further questions for you.

 8        A.   You're welcome.

 9             MR. DEMIRDJIAN:  Your Honours.

10             JUDGE DELVOIE:  Mr. Demirdjian.

11             MR. DEMIRDJIAN:  Thank you, Your Honours.  Before I begin my

12     cross-examination, the document that we were exchanging about earlier has

13     been altered in order to be admitted now.  It's 65 ter 6576 if we want

14     have it displayed just for Mr. Zivanovic's assurance.

15             JUDGE DELVOIE:  Yes, please.

16             MR. ZIVANOVIC:  Sorry, Your Honour.  It seems that I did not

17     ask the tendering of the last document and I would do it now, and

18     apologise.

19             JUDGE DELVOIE:  If there's no objection.

20             MR. DEMIRDJIAN:  No objection, Your Honours.

21             JUDGE DELVOIE:  Admitted and marked.

22             THE REGISTRAR:  Is it 1D3747?

23             MR. ZIVANOVIC:  [Microphone not activated].

24             JUDGE DELVOIE:  Thank you.

25             MR. ZIVANOVIC:  It is document 3747, 1D.


Page 11068

 1             THE REGISTRAR:  Yes, thank you.  Exhibit D185.

 2             JUDGE DELVOIE:  Thanks.

 3             MR. DEMIRDJIAN:  Maybe we'll deal with that document with

 4     Mr. Zivanovic during the break to save court time.

 5             JUDGE DELVOIE:  Okay.

 6             MR. DEMIRDJIAN:  Thank you, Your Honours.

 7                           Cross-examination by Mr. Demirdjian:

 8        Q.   Good morning, Mr. Vukcevic.

 9        A.   Good morning.

10        Q.   We haven't met before.  My name is Alex Demirdjian, and I will

11     have some questions for you this morning on behalf of the Prosecution.

12     And if at any time my questions are not clear, please don't hesitate to

13     ask me for clarification.

14             Let me begin with where you just left off with respect to

15     Mr. Hadzic.  In your statement you stated that:  "Until I left the SDS in

16     April 1991, Goran Hadzic was in the moderate wing of the SDS."

17             Are you suggesting that this changed after April of 1991?

18        A.   In April, the decision was made which denied me the right to

19     represent the Serbian people in Croatia.  It was a very aggressive and a

20     not-well-thought-through decision made by certain individuals, but it was

21     a watershed for counting the time before and after.

22             I don't know if I made myself clear.  On the 1st of April, that

23     is, a decision was made to deprive me of that right, and they did it

24     because they knew that I was a peace-loving person and that I could not

25     represent their aggressive behaviour and their aggressive positions.  In

Page 11069

 1     that case, the period up to the 1st of April is one kind of time, and

 2     after that, another kind of time.

 3             I don't know if I'm making myself clear and why I am defining the

 4     1st April as a certain watershed.

 5        Q.   I understand where are you going but it doesn't answer my

 6     question with respect to Mr. Hadzic specifically.  Are you suggesting

 7     that after the 1st of April, his views changed?

 8        A.   His views did not change because his views were different up to

 9     the 1st of April.  His opinions never changed, at least this is what I

10     could conclude from my conversations with him.  Therefore, he could not

11     change.  He always remained the same.  He was always a well-meaning and

12     peace-loving person.

13        Q.   So why does it say in your statement "until the 1st of April, he

14     was in the moderate wing"?

15        A.   We defined the 1st of April as the day that I've just spoken

16     about.  Maybe the story about that event in temporal terms is something

17     that was imposed on me, i.e., to start thinking about the time before the

18     1st of April and after the 1st of April.  In the heads of the people who

19     didn't change, including his head, means that he couldn't change.  He was

20     always the same, always equally well-meaning, always equally

21     peace-loving.

22        Q.   Okay.  I'll come back to this topic a little bit later but I

23     would like to ask you to place your mind back to June 1990 when you

24     joined the SDS.  Is it correct to say that at the time you were a

25     professor of law at the faculty in Osijek, at the law faculty?

Page 11070

 1        A.   Correct.

 2        Q.   And would it be fair to say that you were one of the founding

 3     members of the SDS in the Slavonia Baranja region?

 4        A.   A found -- a founder.  I did found it.

 5        Q.   And at the time you had the trust of the party's leader,

 6     Dr. Jovan Raskovic; is that right?

 7        A.   That's right.

 8        Q.   And as a trusted member of the SDS, you were allowed to meet with

 9     members of the Croatian government led by the HDZ in Zagreb.  We saw a

10     document earlier about that; is that correct?

11        A.   Yes, but it was only after a decision was made and after I got

12     the green light from the highest body of the Serbian Democratic Party.

13        Q.   Yes.  Now, as a trusted member of the SDS, did you feel that as a

14     representative of the Serb people you had very large responsibilities on

15     your shoulders in dealing with the Croatian government?

16        A.   Of course.  Of course.

17        Q.   And these meetings you had with the Croatian government were

18     reported in the press, weren't they?

19        A.   Yes, yes.

20        Q.   I'd like to show you a document before we go on break.  It's 65

21     ter 6576.1, at tab 3, please.  You will see it appear on your screen in a

22     moment.

23        A.   Yes.

24        Q.   And this is an article which was published in Vijesti, if that

25     the name of the newspaper --

Page 11071

 1        A.   It is actually Vjesnik.  It was a Croatian daily at the time.

 2     Vjesnik.

 3        Q.   Now, do you recognise at least the three individuals we see on

 4     this picture?

 5        A.   I recognise them, of course.  I'm the first on the left without

 6     hair.  Next to me, Boro Savic.  And, on the right, Ivan Vekic.  The last

 7     was the representative of the Croatian Democratic Union.

 8        Q.   Okay.  Now, were you familiar with Mr. Vekic?

 9        A.   I apologise, I need to tell you this.  Mr. Vekic was born in the

10     same year as myself.  Mr. Vekic and I attended the same grammar school in

11     Osijek.  He was in one class, I was in another class, for five years from

12     grade 4 to grade 8.  And obviously when we sat at the table and started

13     talking, Vekic started by saying, "Gentlemen, Vojo," - that's me - "and I

14     were classmates."  We cannot address each other in second person

15     singular.  For a number of years we were -- we have been on first-name

16     terms.  Don't think that if we continue addressing each other that way

17     that we are both corrupt.  In other words, I know him perfectly well.

18        Q.   Very well.  And the other individual here is Mr. Savic.

19             MR. DEMIRDJIAN:  Oh, I apologise.

20             MR. ZIVANOVIC:  Sorry, I just noted one error in the transcript.

21     It is in line 8, page 24.  It is "in second person singular."  I think

22     that is should be "second person plural."

23             MR. DEMIRDJIAN:  Yeah, that's correct.

24             JUDGE DELVOIE:  Noted.

25             MR. DEMIRDJIAN:  That's noted.

Page 11072

 1        Q.   And very quickly before the break, the other person we see on the

 2     screen is Mr. Savic.  This is the man that you called an altar boy on

 3     Thursday?

 4        A.   Yes.

 5        Q.   Now, I don't know whether the connotation is the same in the

 6     Serbian language, but labelling someone an altar boy is not necessarily

 7     casting someone in a positive light.  Is that the same in the Serbian

 8     language?

 9        A.   Well, those who come from mixed environments know what the

10     meaning of the altar boy is.  Those serve in church.  Mr. Raskovic told

11     me, "Don't go on your own to talk to the HDZ.  Don't go on your own

12     because unpleasant things can happen to you like they did to me when I

13     had spoken to Tudjman.  Takes one of our men with you and choose whoever

14     you want."  That's how I chose Boro Savic.

15        Q.   We'll continue this after the break.  And when we come back, I'd

16     ask you to focus on your answers because you did tell us that during your

17     examination-in-chief.  So to make sure that we can finish as quickly as

18     we can, just give me directly the answer.  We will carry on after the

19     break.

20             MR. DEMIRDJIAN:  Your Honours, I believe this is an appropriate

21     time.

22             JUDGE DELVOIE:  Thank you, Mr. Demirdjian.  Court adjourned.

23                           [The witness stands down]

24                           --- Recess taken at 10.30 a.m.

25                           --- On resuming at 11.01 a.m.

Page 11073

 1             JUDGE DELVOIE:  Yes, please.

 2                           [Trial Chamber and Registrar confer]

 3                           [The witness takes the stand]

 4             JUDGE DELVOIE:  Mr. Demirdjian, please proceed.

 5             MR. DEMIRDJIAN:  Thank you, Mr. President.

 6        Q.   Mr. Vukcevic, let me pick up where we left off.  Again, we still

 7     have the picture on the screen.  I was asking you whether this term you

 8     used with respect to Mr. Savic had a pejorative connotation.  Were you in

 9     [Realtime transcript read in error "contact"] conflict with this man,

10     Savic?

11        A.   Never, never.

12        Q.   And perhaps just to answer my question on that point.  Is the

13     term "altar boy" in the way that you used it meant to be pejorative?

14        A.   No, no.  It was not pejorative.  I don't mean to denigrate his

15     role or to underestimate it.  He had an important role because he was

16     providing me with moral support, and I felt better in the company of the

17     person whom I chose than without him.

18             MR. ZIVANOVIC:  Your Honours, you see in line 3, page 26, I don't

19     know whether the witness -- the Prosecution used the word "contact".

20             MR. DEMIRDJIAN:  Conflict.  "Conflict" was the word.

21             MR. ZIVANOVIC:  Okay.

22             MR. DEMIRDJIAN:

23        Q.   Very well.  Now, is it correct to say that the newspaper article

24     we see on the screen was issued, was it, the day after the talks you held

25     with Mr. Vekic?

Page 11074

 1        A.   Yes, yes.

 2        Q.   Very well.

 3             MR. DEMIRDJIAN:  Your Honours, I would tender this newspaper

 4     article.

 5             JUDGE DELVOIE:  Admitted and marked.

 6             THE REGISTRAR:  Exhibit P3246, Your Honours.

 7             JUDGE DELVOIE:  Thank you.

 8             MR. DEMIRDJIAN:

 9        Q.   Now, during this meeting on the 30th of August, you submitted a

10     number of proposals and we saw them earlier this morning.  I'd like you

11     to take a look at these proposals.  The version we have is 65 ter 6576.

12     It's at tab 3 of the Prosecution's list.

13             Now, this morning I used the word "original."  Perhaps you can

14     help the Trial Chamber understand.  What is this version that we have on

15     the screen here?

16        A.   On the left is the text that I typed on a typewriter, an Olympia.

17     I used my private mechanical typewriter.

18        Q.   Can I take you down to item number 3.  Here you're denouncing the

19     use of certain terms such as rebels, highwaymen, Chetniks and other

20     abusive terms when referring to Serbian people.  Do you see that part?

21        A.   I see it in the newspaper article, but I also know it from the

22     text on the left-hand side of the screen.

23        Q.   So it would be appropriate to say that you were not in favour of

24     the use of such terms at the time that you typed this document.

25        A.   Correct.  You are right.

Page 11075

 1        Q.   And would it be fair to say that you advocated against the use of

 2     such terms against all people, of all ethnicities?

 3        A.   Absolutely, absolutely.  It was not a time when brigands or

 4     highway robbers were coming in force, nor were we such people.

 5        Q.   Well, for example, one term that was quite in fashion at the time

 6     was the use of the word "Ustasha," wasn't it?

 7        A.   Yes.

 8        Q.   And how did you feel about the use of that term?

 9        A.   Ustasha was a term used for the Croatian people.  I could not

10     feel offended by it myself, except that I found it ugly, no matter who

11     was using it.

12        Q.   You say that the term was used for the Croatian people.  In

13     general?

14        A.   It is pejorative, offensive, negative.

15        Q.   And now I'd like to take you to item 4, which I believe might be

16     on the next page in both Serbian and English.  Yes, at the top of the

17     page.  And here you write that:

18             "We propose that the use of the term 'armed rebellion' be stopped

19     because the gathering of armed individuals is organised with the aim of

20     self-defence and self-protection and thus does not constitute an armed

21     rebellion ..."

22             The question I have for you is here which gathering of armed

23     individuals were you referring to?  And this is August 1990.

24        A.   Those were already days and events that brought unrest among the

25     Serbian people because they were informed and it really happened that the

Page 11076

 1     Croats, through their special forces which already existed, including the

 2     Home Guards Corps, and they had weapons that been imported already in

 3     1990 and these weapons found their way to irresponsible people, the Serbs

 4     believed that such people would be prepared to attack them using those

 5     weapons so they got ready to defend themselves.

 6             I sent a telegram to the chief of the General Staff of the

 7     Yugoslav People's Army, asking that the parts of the Serbian people who

 8     were considered as the reserve force of the JNA - because all of us were

 9     reservists of the JNA - should have uniforms and weapons distributed to

10     them because we shouldn't worry ourselves how to get hold of weapons.

11     And thus equipped with regular uniforms of the reservists of the JNA and

12     with weapons received from the army, they would be able to defend

13     themselves, if necessary.  And it was necessary in certain communities

14     where certain forms of violence were already happening.

15             Was I clear enough?

16        Q.   Yes, but you mentioned a telegram to the General Staff of the

17     JNA.  Do you remember when you sent that telegraph -- telegram?

18        A.   I can't remember exactly, but that was a time when the first

19     serious unrest began.  I'm sorry, I can't remember the time.  I thought

20     it was legal.  In my eyes, it was legal because we were the reserve

21     force.  We were in the reserve of a regular army.

22        Q.   In any event, this would have been before you wrote this letter,

23     the telegram that you sent?

24        A.   Yes, yes.

25        Q.   Thank you.

Page 11077

 1             MR. DEMIRDJIAN:  Before I move on, Your Honours, this the

 2     document that we were discussing with Mr. Zivanovic.  We could tender it

 3     at this time.  65 ter 6576.

 4             JUDGE DELVOIE:  Admitted and marked.

 5             THE REGISTRAR:  Exhibit P3247, Your Honours.

 6             JUDGE DELVOIE:  Thanks.

 7             MR. DEMIRDJIAN:

 8        Q.   Dr. Vukcevic, you were mentioning that leadership of the SDS,

 9     some members at least of the SDS, were in favour of talks and

10     negotiations.  Would it be correct to say that however this position may

11     have been, there were elements at least in Krajina which were beginning

12     to establish self-rule in areas inhabited predominantly by Serbs?  And in

13     terms of time-frame I'm talking as early as June of 1990.  Would that be

14     right?

15        A.   I don't have such information, especially as far as June 1991 was

16     concerned.  I don't know.

17        Q.   Are you familiar with the establishment of the Community of

18     Municipalities of Northern Dalmatia and Lika on the 27th of June, 1990,

19     by Mr. Milan Babic?

20        A.   I remember that.

21        Q.   And were you familiar with the 25th of July, 1990 declaration on

22     sovereignty and autonomy of the Serb people in Croatia which is also

23     authored by Mr. Babic?

24        A.   I knew that the declaration had been adopted.  It was on the 25th

25     of July in a place called Srb, in Lika.  It was a large gathering of

Page 11078

 1     Serbs, but I was indisposed at that time.  I could not attend.

 2        Q.   Are these the first steps towards self-governance by the Serbian

 3     people within the Republic of Croatia, at least as far as the Krajina

 4     area is concerned?

 5        A.   I can't say what the people who were doing it were thinking

 6     because I didn't speak to them.  But thinking about this event and

 7     looking back, I believe those were the first attempts at self-governance.

 8        Q.   And through your interactions with the representatives of the HDZ

 9     and the Republic of Croatia, were you aware of how they received such

10     initiatives or how they reacted to them?

11        A.   They received them with a lack of understanding and with serious

12     objections that what was going on was not good and they didn't support

13     it.  They wanted themselves to create a legal framework for our activity.

14     They wanted a legal framework of their own design.  I don't know what

15     that legal framework was to be, but the Serbs were very offended that

16     they had been deleted from the constitution, that they were no longer a

17     constituent people in Croatia, whereas they had contributed to the

18     creation of Croatia as an anti-Fascist state.  It was a great insult to

19     the Serb people and threat to their existence.

20        Q.   When you say "threat to their existence," would you agree with me

21     that looking at the constitution of 1990, putting aside the fact that

22     Serbs were removed as a constituent people, the rights of minorities were

23     preserved in the constitution.  Would you agree with that?

24        A.   I couldn't agree with that.  They recognise Italians, Hungarians,

25     Ruthenians, Slovaks, as minorities but not the Serbs.  Even today when

Page 11079

 1     you drive through Croatia, you will not see a single sign in Cyrillic.

 2     And those Cyrillic signs that existed had been removed but there are

 3     signs in all the other languages.  So you could say that minorities have

 4     rights, but why don't Serbs have any?

 5        Q.   Sir, I wasn't going to delve into this, but I have the

 6     constitution before me and Serbs are listed as minorities.  I can display

 7     it for you, if you wish.  But are you saying, just so I understand your

 8     answer, are you saying that Serbs were not listed as minorities in the

 9     constitution or did I misunderstand you?

10        A.   I know.  I know.  The way in which they were introduced as a

11     minority and the way in which they are referred to in the constitution of

12     1990 is not remotely similar to the way they were referred to before.

13     You get the impression that in this union of peoples, the Serbs already

14     have their place but it's wrong.  I know what sovereignty means.

15     Sovereignty is a legal term for violence.  If you are not sovereign, you

16     cannot decide your own fate in the same way as when you have sovereignty.

17        Q.   Let me move on to a slightly different topic because earlier you

18     mentioned that you sent this letter to the General Staff with respect to

19     the arming of the reservists.  Is it correct to say that in the fall or

20     autumn of 1990, the SDS leadership from Croatia was seeking support from

21     the SFRY Presidency?

22        A.   I, too, was at that meeting with the Presidency of the SFRY when

23     Borisav Jovic was the president of that Presidency.  We were invited and

24     we came there to describe the situation on the ground and the sentiment,

25     the prevailing sentiment among our people.  Depending on the speaker and

Page 11080

 1     their education, the descriptions varied, but all of them spoke about the

 2     fear from the new state and they had in common the desire to preserve

 3     Yugoslavia.

 4             Borisav Jovic, who was president of the Presidency, did not make

 5     any promises, did not say anything was black or white.  He just listened

 6     and listened, and I don't know what he conveyed to others of our

 7     proposals.  All I know is that the state of emergency was not imposed and

 8     one member of the Presidency who was to vote for it did not vote for it,

 9     and he was a Serb from Bosnia-Herzegovina.

10        Q.   Let's take this one by one.  You said:  "I, too, was at that

11     meeting."

12             Just to clarify it for the Trial Chamber, when did this meeting

13     take place?

14        A.   I think it was September 1990.  I don't know the date.

15        Q.   And you wrote -- you said here that "the Presidency invited us."

16     Who was invited to attend this meeting?

17        A.   Prominent activists of the Serbian movement from Croatia.  Better

18     known individuals from all over Croatia, from Vukovar to Dalmatia.

19        Q.   Before I go on, I see here that your first answer at page 32,

20     line 5, reads "At that meeting with the Presidency of SFRY when

21     Borivoje Savic was the president," I think it's the name "Borisav Jovic"

22     which was said.

23        A.   Borisav Jovic.

24        Q.   Very well.  And could you tell us some of the names of these

25     prominent activists who were present at this meeting.

Page 11081

 1        A.   Veljko Dzakula.  Several people from Knin; I can't remember the

 2     names.  I don't want to enumerate them now because my memory has faded,

 3     and my head is full of new people and new memories that pushed out the

 4     old one ones.

 5        Q.   Was Mr. Dusan Vjestica present?

 6        A.   Yes, he was there.

 7        Q.   And was Mr. Goran Hadzic present?

 8        A.   I think so.

 9        Q.   You're not entirely sure?

10        A.   No, certainly not.

11             MR. DEMIRDJIAN:  Could we quickly display 65 ter 6577, at tab 5

12     in the Prosecution's list.  And for the purposes of the version in B/C/S,

13     could we zoom in to the top left-hand corner.  Thank you very much.

14        Q.   Now, this is the 4th of October, 1990, a newspaper article

15     called, "Which Serbs Went To See Jovic."  And you see all the names

16     listed there.  Does that refresh your memory a little of who else

17     attended this meeting?

18        A.   I believe, and I remember now when I see the names, that these

19     people whose names were published in the newspaper were there.

20        Q.   And can you just maybe clarify for us.  Earlier you said that you

21     were invited by the SFRY president, Mr. Jovic.  How did this invitation

22     come across?  Was it first initiated by yourself or did Mr. Jovic invite

23     this delegation on his own initiative?

24        A.   The initiative was not mine.  That's all I know.  I don't know

25     whom Jovic invited.  I was invited by my friends and acquaintances who,

Page 11082

 1     at that time, lived in Belgrade.  I don't know the other details.

 2        Q.   Very well.

 3             MR. DEMIRDJIAN:  Your Honours, may I tender this exhibit.

 4             JUDGE DELVOIE:  Admitted and marked.

 5             THE REGISTRAR:  Exhibit P3248, Your Honours.

 6             JUDGE DELVOIE:  Thank you.

 7             MR. DEMIRDJIAN:  Thank you.

 8        Q.   Now, Dr. Vukcevic, this was not the first --

 9        A.   Vukcevic.

10        Q.   I believe that's what I said but never mind.

11        A.   You said "Vuckovic."

12        Q.   Very well.  I apologise if I did.

13             Now, Dr. Vukcevic, would you agree that this was not the first

14     contact made with Mr. Jovic, with Mr. Borisav Jovic, at the time by Serbs

15     in Croatia, or the Serb leadership in Croatia?

16        A.   If there were any contacts, I don't know anything about them.

17     Nobody ever told me about them.  Nobody ever invited me to be present

18     either.

19        Q.   Did you attend any meetings of the Serbian National Council from

20     Knin during the summer of 1990?

21        A.   No, I didn't attend any meetings because I was not a member of

22     the Serbian National Council.  They were very selfish.  They were a very

23     closed group.  They hid from the others, from the other members, as far

24     as I can remember, if my memory serves me well.

25        Q.   I'd like to show you a document, which is minutes of this Serbian

Page 11083

 1     National Council.  It's Exhibit P1195, at tab 1 of the Prosecution's

 2     list.

 3             Now, what you will see on the screen --

 4             MR. DEMIRDJIAN:  And could we go to page 2 for both documents,

 5     please.  Yes.

 6        Q.   It might be a bit of a challenge for you because these are

 7     handwritten notes, but I'll ask you to make a bit of an effort, if I may.

 8             The header says here "Minutes" and from the 2nd session of the

 9     Serbian National Council, held on the 16th of August, 1990 in Dvor na

10     Uni.  Item 1, are you able to see item number 1 which starts with:

11     "Milan Babic submitted a report ..."?

12        A.   I can see that there are letters on the screen, but not very

13     legible.  I can't read anything.  Now I can, I think.

14        Q.   The sentence that I'm looking at in English reads:  "Milan Babic

15     submitted a report about the talks with Borisav Jovic held by Babic with

16     Raskovic and Bogoljub Popovic ..."

17             Do you see that sentence?  Do you see the sentence, Dr. Vukcevic?

18        A.   Yes, yes.

19        Q.   And one sentence -- we skip one sentence here.  The next sentence

20     begins with:

21             "Jovic gave support to all political battles for the rights of

22     the people and that the referendum be led under the legal regulations and

23     that the army will support and protect the political battle of the

24     Serbian people."

25             Do you also see that sentence?

Page 11084

 1        A.   Yes, I can see it.

 2        Q.   Were you aware of this position by Borisav Jovic with respect to

 3     the support to the Serbian people in Croatia?

 4        A.   This is the first time I hear that Borisav Jovic said something

 5     of that kind.  When I met with him and when I was with the group of

 6     people that we mentioned a while ago, he didn't say that.

 7             MR. DEMIRDJIAN:  Could we go to the next page in both English and

 8     B/C/S, and could we scroll down to item number 4.  Actually, in B/C/S,

 9     it's the very next page.  Yes, could we zoom in to item number 4, in the

10     middle of the page.

11        Q.   Now, here the translation that I have says --

12             JUDGE DELVOIE:  I'm sorry, Mr. Demirdjian --

13             MR. DEMIRDJIAN:  Sorry.

14             JUDGE DELVOIE:  -- turn over the page in English as well?

15             MR. DEMIRDJIAN:  Actually, it's the very bottom of that page,

16     Your Honour --

17             JUDGE DELVOIE:  I see that.

18             MR. DEMIRDJIAN:  I'm sorry, I apologise, Your Honours.

19             JUDGE DELVOIE:  Oh, okay.  It's only that one sentence.  Sorry.

20     We can go back to the previous page.

21             MR. DEMIRDJIAN:  Yes.

22        Q.   Now, item number 4, as it is translated in English here, says:

23     "Legal council.  The president of the legal council - Vukcevic,

24     unanimous."

25             Do you have any idea as to what this refers to?

Page 11085

 1        A.   There were not many renowned legal professionals, especially

 2     full-time university professors but me in the ranks of the Serbian

 3     movement.  And when I was chosen and elected and I was barely aware of

 4     that - I'm trying very hard to remember the whole thing - they tried to

 5     give me more significance to that position.  Although I was in charge of

 6     the plebiscite which took place on the 19th of August, this was as much

 7     as I did as the president of the legal council.  That was my only role,

 8     the only significant role that I had in the whole matter.

 9             MR. DEMIRDJIAN:  Very well.  And if we turn to page 6 in the

10     English version and the next page in the B/C/S version, please.

11        Q.   This is a list of those people who were present at this meeting

12     of the Serbian National Council.  And under number 16, we read:

13     "Vukcevic Vojislav, MD, from Beli Manastir."

14             Does that refresh your memory that you were present at this

15     meeting?

16        A.   I was at several meetings in Knin.  I can't remember whether this

17     was a meeting of the Main Board or whether that was the meeting that is

18     mentioned here.  I really can't remember.  It was a long time ago, first

19     of all; and second of all, as I've already told you, I went there on

20     several occasions.

21        Q.   Now, earlier when I showed you the newspaper article which was

22     entitled, "Who Went To See Jovic," you said that at the time Mr. Jovic

23     did not react much.  Would you agree that with time Belgrade did support

24     the activities of Serbs in Croatia?

25        A.   Yes, I would agree with that.  Belgrade thought that it was their

Page 11086

 1     duty for national reasons because we did not have another state.  We did

 2     not have any other assistance and help by any other Serbs but the Serbs

 3     who were in Belgrade.  And they thought and felt invited to help us when

 4     they start feeling that way.  I can give you an example when the Serbs

 5     from Belgrade did not help the Croatian Serbs the way that they expected,

 6     and that was on the 3rd of March, 1991, when Dzakula started a rebellion

 7     in Pakrac.

 8        Q.   Would you agree that eventually Belgrade started exerting

 9     pressure on some members of the SDS in your region?

10        A.   Belgrade sent its commissioners and envoys to place under their

11     control the Serbian people who had gathered and rallied in that way.  The

12     trouble with that was that those envoys and commissioners usually found

13     and selected bad people, bad Serbs, and they failed in achieving what

14     they had set out to achieve with the help of such bad people.

15             JUDGE DELVOIE:  Mr. Demirdjian, just one moment.

16             MR. DEMIRDJIAN:  Yes, Your Honours.

17             JUDGE MINDUA: [Interpretation] Yes, sorry, Mr. Prosecutor.

18             Out of the list that is on the screen, I would like to know

19     whether number 16 -- well, we can see number 16, "Vukcevic Vojislav, MD."

20     Is it the same person as the witness?  And what does "MD" mean?

21             MR. DEMIRDJIAN:  Your Honours --

22             THE WITNESS: [Interpretation] That is me but I'm not a physician.

23     I'm not an MD.

24             MR. DEMIRDJIAN:

25        Q.   And you don't have any idea as to why the letters MD are

Page 11087

 1     indicated there?

 2        A.   I don't.  No, I don't.

 3             JUDGE MINDUA: [Interpretation] Okay.  So this is a mistake.  It

 4     is a mistake.  Thank you.

 5             MR. DEMIRDJIAN: [Interpretation] Your Honour, I will clarify this

 6     with the witness because I think that there is a mistake in the

 7     translation.

 8        Q.   [In English] Sir, in the original version, we see your name,

 9     first of all, we see number 16, your last name.  It is followed -- is it

10     followed by the letters "DR" in Cyrillic?

11        A.   Yes.  However, I am a doctor of science.  I'm a doctor of law,

12     not of medicine.

13        Q.   Very well.

14             MR. DEMIRDJIAN:  We'll revise this translation, Your Honours.

15     Thank you.

16        Q.   Sir, I was going to ask you about these commissioners you said

17     which were sent from Belgrade.  Who do you have in mind?

18        A.   A few of them have died, and as dead, they are not important.  As

19     for the rest, I can't remember their names.

20        Q.   Would it be correct that Mr. Ilija Koncarevic would be one of

21     those commissioners who was sent to the region?

22        A.   Yes.  Yes, yes.

23        Q.   And would Mr. Ilija Petrovic also fit within this category?

24        A.   Yes, him as well.

25        Q.   Now, with respect to this issue, I'd like you to take a look at

Page 11088

 1     an article in the Borba, which was published in Borba, in Belgrade.

 2             MR. DEMIRDJIAN:  This is at 65 ter 6606 at tab 13.  Yes.  Thank

 3     you.

 4        Q.   Sir, the original of this clipping is in English, as it was

 5     reported in the international press.  The article is entitled:  "The

 6     Strength and Weakness of Reasonable People."  It is dated the 5th of

 7     April, 1991, and it talks about recent talks with Dr. Franjo Tudjman.

 8     And then the second paragraph here mentions your name.  It says that:

 9             "Dr. Vojislav Vukcevic ... adds that the centre of power,

10     Belgrade, has been exerting strong pressure on him because he influences

11     the Serbs in Baranja to act calmly and responsibly and not to cause

12     incidents."

13             Does this accurately reflect words you would have used at the

14     time?

15        A.   What is the time of this report?

16        Q.   5th of April, 1991.

17        A.   I owe it to tell that you I resigned from all positions in the

18     Serbian Democratic Party on the 24th of April, 1991, and I parted with

19     people whom I liked and others whom I didn't, and some I have never met

20     after that.

21        Q.   I will actually get to your resignation in a minute.  But before

22     that, I wanted to confirm with you that you held the view at that time

23     that Belgrade had been exerting strong pressure on individuals like you

24     who were trying to influence Serbs to keep calm in the Baranja region.

25        A.   If on the term "Belgrade" you mean Milosevic's regime, then I

Page 11089

 1     have to say that people who represented him were not naive and they made

 2     sure who they spoke to and how they behaved.  I can't say that pressure

 3     was put on me because I was already getting on.  I had an integrity that

 4     they couldn't influence.  They were in pursuit of some other more -- less

 5     stable people, I suppose, sir.

 6        Q.   You claim that:

 7             "The Serbian Democratic Party has split into two parts which do

 8     not acknowledge each other, and the influence of the Krajina part can

 9     also be felt in Slavonia and Baranja."

10             Is this accurate?

11        A.   Unfortunately, it is.

12             MR. DEMIRDJIAN:  I move to tender this exhibit Your Honours.

13             JUDGE DELVOIE:  Admitted and marked.

14             THE REGISTRAR:  Exhibit P3249, Your Honours.

15             MR. DEMIRDJIAN:

16        Q.   I'd like to move on now to the issue of your resigning from the

17     party, Dr. Vukcevic.  In your statement, you say that you left the party

18     because you were accused of being too soft.  In fact, I'd like you to

19     comment on an article that came out at the time in the Nin magazine.

20             MR. DEMIRDJIAN:  This is 65 ter 6582 at tab 16 of the Prosecution

21     list.

22        Q.   Have you seen this newspaper article before, doctor?  I believe

23     you have it in front of you.  Yes, very well.

24             And do you remember giving this interview to the journalist Momir

25     Ilic?

Page 11090

 1        A.   I remember this very well.

 2        Q.   Now, the first question in the English version is at the bottom

 3     of page 1, and I think for you it's at the bottom of the first column.

 4     The question is here:  "What prompted you to resign from all these

 5     positions in the SDS?"  And here your answer is:  "I'm doing this under

 6     the pressure of lies, defamation and all kinds of fabrications to which I

 7     have been exposed for the past five months."

 8             And you associate these or you attribute these lies and

 9     defamations to the Association of Serbs of Croatia based in Belgrade.

10             Dr. Vukcevic, do you know who was the head of this association?

11        A.   I've forgotten his name; however, sometime in 1998 that man

12     visited me.  The man hails from Osijek, just like I do.  I can't remember

13     his name.  And I spoke to him in a very serious manner, in a very

14     decisive manner, and I told him that he had played a very ugly and

15     dishonourable role on behalf of the Serbs.  He swore that that was not

16     true.  And that would be my memory of the leader of the Association of

17     Serbs from Croatia in Belgrade.

18        Q.   Do you know whether a retired general by the name of Dusan Pekic

19     had any role in that association?

20        A.   Yes.

21        Q.   And what was that role?

22        A.   The role that I have just described.

23        Q.   I see.  And do you know whether General Pekic had any

24     relationship with Mr. Goran Hadzic?

25        A.   No, I don't.  No.

Page 11091

 1        Q.   The next question here --

 2             MR. DEMIRDJIAN:  And this is on page 2 in the English version; in

 3     the Serbian version it would be in the second column.

 4        Q.   The next question is here:

 5             "It is being claimed that the SDS has been divided into two

 6     streams almost from its beginning and that the conflict between these two

 7     streams is still ongoing."

 8             And you explain here two forms of consciousness that prevail

 9     amongst the SDS members.  Can I conclude from reading this article that

10     the distinction between these two streams are between those members of

11     the SDS who favoured dialogue and negotiations versus those who

12     championed activism and possibly the use of force?

13        A.   Yes, that would be more or less the main characteristics of the

14     two streams, or the two parts, as it were.

15        Q.   Dr. Vukcevic, I will ask you to now look at a different

16     interview, this time from 1996.

17             MR. DEMIRDJIAN:  It's 65 ter 6601, tab 45 of the Prosecution

18     list.  It's an article in Vreme magazine, and the headline is, "Unlearned

19     Lessons."  I'll wait for the English version to come up on the screen.

20     Thank you.

21        Q.   Are you familiar with this interview, Dr. Vukcevic?

22        A.   Yes, but I can't remember what I said during that interview.

23        Q.   I'll walk you through it.  The first section here deals with your

24     resignation from all functions in the SDS, and you explained when that

25     happened.  And you explain some shortcomings and your astonishment at the

Page 11092

 1     time, and you referred to people who lied and people who believed those

 2     lies.  This is -- the question here is:  "Could you describe those people

 3     and events in more detail?"

 4             Do you see that question?

 5             MR. DEMIRDJIAN:  Actually, we may have to move the original

 6     version.  This is the third question, so it would have to be on page 2,

 7     please, of the B/C/S version.  Yes, on the right -- on the left side of

 8     the screen, that's the question.  Thank you very much.

 9        Q.   If you can take a moment to read that answer, the answer you gave

10     here.  In the first section here, you mention:

11             "Among them there were plain activists from the government --"

12     sorry, "from the movement as well as people who came to visit us and took

13     care of us, if you want, even the highest ranking person in this nation

14     and the people who were closest to him, all of them repeating one and the

15     same thought which at the time went as follows:  All Serbs in a single

16     state."

17             Now, sir, when you said "the highest ranking person in this

18     nation," you were referring to President Milosevic, weren't you?

19        A.   Yes, yes.

20        Q.   Your answer carries on here.  You say:

21             "My attempts to get from them a more concrete definition of that

22     state regarding its size, its borders and national structure, remained

23     fruitless because the protagonists and activists who promoted this idea

24     were not able to explain it fully."

25             And then you continue saying:

Page 11093

 1             "The task of the activists was to keep on repeating this idea

 2     they had learned by heart.  The fulfilment of that idea and everything

 3     connected to it was supposed to follow only at the later stage and that

 4     task was to be assigned to some other people and activists.  That is why

 5     I believe that some of those names, some of which I have forgotten, do

 6     not deserve attention.  Unfortunately those names became our big

 7     misfortune."

 8             Sir, who did you have in mind with respect to those people who

 9     became your big misfortune?

10        A.   For example, the president of the Association of the Serbs of

11     Croatia, whose name I couldn't remember, and then also the late Dusan --

12     oh, well.  Maybe I will remember his family name later.  I can't remember

13     it now.

14        Q.   If it comes back to you, feel free to tell me at that moment.

15             However, what is it that made them your biggest misfortune?  What

16     is it that they did?

17        A.   They did so much evil.  They caused so much evil that it remains

18     living to this very day, and God knows how long it will go on living and

19     whether it will ever die.

20        Q.   Could you give us, in practical terms, what is the evil that you

21     are referring to?

22        A.   There is no country where you were born where you lived.  The

23     only country you thought was ever possible.  Could there be any bigger

24     evil than that?

25        Q.   I'd like to take you to another part of this interview for one

Page 11094

 1     last question you were asked here.

 2             MR. DEMIRDJIAN:  In the English version, we need to go to page 3,

 3     and in the Serbian version we stay on the same page but could we go to

 4     the middle column.  Yes, right there.

 5        Q.   Here the question is - and may I remind you this is an interview

 6     in August 1996 - "How do you see the future of Eastern Slavonia, Baranja,

 7     and Western Srem?"  You answer here is saying that:

 8             "Since the beginning of current events, there was an idea for

 9     which I never had much understanding.  It says that you must ask for more

10     in order to get less.  However, the problem isn't the fact that these

11     people do not know what they want and when they're offered something,

12     they do not know how to take it.  I'm afraid that tackless statements and

13     actions of Goran Hadzic and the leadership in Eastern Slavonia are simply

14     repetition of what happened to Serbs in Krajina."

15             Now may I ask you, Dr. Vukcevic, what are these tackless

16     statements you referred to?

17        A.   I really can't remember these statements now, and I remind you

18     again of the fact that I stopped to think and to speak and to meet with

19     people after I resigned.  They lived in one area.  I lived in another.

20     All of us had our own problems, and I really can't remember now what I

21     was thinking then and what these statements ...

22        Q.   Do you remember perhaps whether these are statements that were

23     made during or after the conflict?

24        A.   I don't know that either, really.

25             JUDGE DELVOIE:  Mr. Zivanovic.

Page 11095

 1             MR. ZIVANOVIC:  Maybe for the answer on this question, the

 2     witness should have an opportunity to read this text to the end.

 3             MR. DEMIRDJIAN:  That's fair enough.  We can keep scrolling down.

 4        Q.   As a matter of fact, Dr. Vukcevic, I will leave this to

 5     Mr. Zivanovic to raise it in re-examination as I have more material to go

 6     through at this stage, if you don't mind.

 7             Because if we scroll to the next question - and that's on the

 8     very right side, thank you - here it says you are one of the Serbian

 9     politicians who actively negotiated with Dr. Franjo Tudjman and his

10     associates before the war.  "How did those negotiations start and what

11     was their result?"

12             Your answer here explains the release of 450 Serbs who had taken

13     part in the events of the 3rd of March, 1991, in Pakrac, and you referred

14     to that earlier this morning.  And you carry on and you explain that you

15     maintained a dialogue with Mr. Slavko Degoricija.

16             MR. DEMIRDJIAN:  And I believe that to see this, we have to --

17     no, we can remain on this same page in the B/C/S version, scroll all the

18     way to the bottom.

19        Q.   The very last sentence begins with:  "As we were satisfied with

20     the results with President Tudjman we continued talks ..." and here we

21     need to go to the next page in the B/C/S version.  "We continued talks

22     with Degoricija ..."

23             And you explain here your talks with Mr. Degoricija and that he

24     had offered to solve issues relating to the Serbs in Croatia, including

25     constitutional status, economic relations, and cultural and educational

Page 11096

 1     matters.  And you explain here the reaction of Serbs in Croatia in the

 2     following words.  You say here:

 3             "Unfortunately, the Serbs did not accept this offer.

 4     Unfortunately, on that day, a group of feeble-minded and aggressive

 5     individuals from Baranja made itself heard and broke unity of the Serbian

 6     movement."

 7             If we skip a sentence you then say:

 8             "Several days later, the Serbian National Council passed a

 9     decision about separation of this region from Croatia and by doing so,

10     became the first one, in the territory of the former Yugoslavia, that

11     broke Yugoslavia.  That evening, at this very session they passed a

12     decision that professor Vojislav Vukcevic is not authorised any longer to

13     speak on behalf of the Serbian people."

14             Dr. Vukcevic, does this answer accurately represent your answers

15     at the time?

16        A.   It does.  But there were worse statements and even worse

17     happenings than that.

18        Q.   I'll get to that in a moment.

19             MR. DEMIRDJIAN:  Your Honour, may I tender this article, please.

20             JUDGE DELVOIE:  Admitted and marked.

21             THE REGISTRAR:  Exhibit P3250, Your Honours.

22             MR. DEMIRDJIAN:

23        Q.   You mentioned "worse statements and even worse happenings at that

24     time."  Would it be correct to say that at the time threats were made

25     against you by individuals such as Vojislav Seselj and Jovo Ostojic?  Are

Page 11097

 1     you familiar with that?

 2        A.   Yes, especially Jovo Ostojic and a man called Paroski from

 3     Vojvodina were throwing their weight about and competed who would find a

 4     worse name to call me and denigrate my work more.

 5             Can I explain just one more detail?  Coming back from Zagreb

 6     after talking to President Tudjman, I turned on my car radio to Radio

 7     Belgrade because it was time for the news bulletin, and then quite

 8     unexpectedly I heard the speaker saying, "Our correspondent from

 9     Beli Manastir informs us that negotiations were just held in Zagreb

10     between a representative of the Serbs and the Croatian president,

11     Tudjman.  The Serbian team included Mr. Vukcevic about whom we insist on

12     saying that he is not a representative of the Serbs and has no

13     authorisation to negotiate anything," although they knew about the

14     decision authorising me.

15             It was so ugly that I didn't know what to do.  What can you do in

16     that situation if you want to fight and do good and you are rejected by

17     people?  Can you imagine it?  We hadn't even reached home.  We were

18     coming back from Zagreb, we were still on the highway, and we hear the

19     voice on the radio saying these things about us.  Of course, the people

20     at that radio station were under the influence of the Belgrade regime.

21        Q.   Thank you for that explanation.  I apologise.  My attention was

22     attracted to the very next item I was going to show you at this moment.

23             Sir, before I move to that, these words that were uttered against

24     you were made during a rally in the village of Jagodnjak in April 1991,

25     and I would like you to take a look at the footage that we have now in

Page 11098

 1     Sanction.

 2             MR. DEMIRDJIAN:  If we can play the first clip which starts at

 3     the -- sorry, I must announce also the 65 ter number, 4785, at tab 17.

 4             THE INTERPRETER:  We haven't got it yet.  Just a minute.

 5             MR. DEMIRDJIAN:  Yes.  For the interpreters, the first clip will

 6     not have any translation or any sound or any words.

 7             THE INTERPRETER:  We have it now.

 8             MR. DEMIRDJIAN:  Thank you.  Can we play the first clip which is

 9     about 20 seconds.

10                           [Video-clip played]

11             MR. DEMIRDJIAN:

12        Q.   We can pause that here.  You see the date on the screen which is

13     the 21st of April, 1991, Dr. Vukcevic.  I'd like to us go to the second

14     clip, which starts at the 4 minutes and 10 second mark, and this is from

15     page 1 of the transcript for the interpreters.  Bottom of the page where

16     you see the initials "V" and "Sh."  If the interpreters want to give me

17     the signal that --

18             THE INTERPRETER:  Yes.

19             MR. DEMIRDJIAN:  Thank you.  Can we play that, please.

20                           [Video-clip played]

21             "THE INTERPRETER: [Voiceover] Brothers and sisters Serbs, the

22     Serbian people of Serbian Slavonia, Western Srem and Baranja have made a

23     decision through their Serbian National Council to join the present

24     Republic of Serbia directly.  This decision of the Serbian people is

25     incontestable and has met with acclamation and support throughout Serbdom

Page 11099

 1     in general."

 2             MR. DEMIRDJIAN:

 3        Q.   Dr. Vukcevic, did you hear Mr. Seselj here saying that this

 4     decision was brought through the Serbian National Council?

 5        A.   Yes, I heard it now.

 6        Q.   And on the 21st of April, were you aware of who was the president

 7     or the head of the Serbian National Council?

 8        A.   You mean Eastern Slavonia, Baranja, and that?

 9        Q.   Yes.

10        A.   I didn't give it any thought because I knew that whoever the

11     president was, he was not defending his own opinion or policies.  They

12     got their opinions from elsewhere.  Seselj was the chief person for

13     Slavonia and Baranja and all that area, "of all the Serbdom," as he put

14     it.

15             MR. DEMIRDJIAN:  Your Honours, is this the appropriate time for

16     the break?

17             JUDGE DELVOIE:  That's right.  Thank you, Mr. Demirdjian.

18             Thirty-minute break.  Court adjourned.

19                           [The witness stands down]

20                           --- Recess taken at 12.14 p.m.

21                           --- On resuming at 12.46 p.m.

22             JUDGE DELVOIE:  Mr. Demirdjian, if I take a few minutes for

23     planning purposes, I take you still can finish with this witness today?

24             MR. DEMIRDJIAN:  I could try, Your Honours, as much as I can.

25     There may be a small spill-over into tomorrow morning, but I'll try my

Page 11100

 1     best to shorten --

 2             JUDGE DELVOIE:  Okay.

 3             MR. DEMIRDJIAN:  Yeah.

 4             JUDGE DELVOIE:  To discuss the next two witnesses:  One is a

 5     closed-session witness, I think, and one is a public-session witness.  Is

 6     that right, Mr. Zivanovic?

 7             MR. ZIVANOVIC:  The next witness is for the public session.

 8             JUDGE DELVOIE:  It's for the public session.  That is --

 9             MR. ZIVANOVIC:  And the witness after him, I must double-check,

10     but I think also that he is for the public session.

11             JUDGE DELVOIE:  Okay.

12             MR. ZIVANOVIC:  I'm sure for the next witness.

13             JUDGE DELVOIE:  The next witness there's no problem.  It's

14     Mr. Seselj; right?

15             Now, it's about that witness that we might a problem.  I saw your

16     last e-mail, Mr. Zivanovic, about the problems you have with the

17     Detention Unit.  Is the second witness available?  Would he be available

18     tomorrow?

19             MR. ZIVANOVIC:  Second witness or the next witness?

20             JUDGE DELVOIE:  So the next witness after Mr. Seselj.

21             MR. ZIVANOVIC:  He arrived, but I don't believe he is -- he is

22     ready to enter courtroom tomorrow.

23             JUDGE DELVOIE:  Okay, because I will think --

24             MR. ZIVANOVIC:  But, anyway, we can start with the next witness

25     after this one.

Page 11101

 1             JUDGE DELVOIE:  So we can start with Mr. Seselj --

 2             MR. ZIVANOVIC:  Disregarding some problems that we met with --

 3             JUDGE DELVOIE:  Which then you will solve during the time

 4     Mr. Seselj is on the stand; is that right?

 5             MR. ZIVANOVIC:  Yes.  Yes, that's correct.

 6             JUDGE DELVOIE:  Okay.

 7             Okay.  We can bring the witness in, please.

 8                           [The witness takes the stand]

 9             THE WITNESS: [Interpretation] Your Honours, I have a request,

10     with your leave.  I would kindly ask that we finish today, if at all

11     possible.  I need to return tomorrow because I am to attend a very

12     important trial on Wednesday, and I would appreciate it very much if we

13     could speed up a little and finish today.

14             JUDGE DELVOIE:  Mr. Demirdjian.

15             MR. DEMIRDJIAN:  I'll try my best to restrict my questions to the

16     essentials, Your Honours.  I don't know if there's any re-direct.

17             JUDGE DELVOIE:  Oh, yes, of course, the re-direct.

18             Mr. Zivanovic?

19             MR. ZIVANOVIC:  That's correct, we have re-direct.

20             JUDGE DELVOIE:  And, Madam Registrar, just one moment.

21                           [Trial Chamber confers]

22                           [Trial Chamber and Registrar confer]

23             JUDGE DELVOIE:  We'll check whether we can have one extra session

24     this afternoon, just in case.

25             MR. DEMIRDJIAN:  Thank you, Your Honours.

Page 11102

 1             JUDGE DELVOIE:  Please proceed, Mr. Demirdjian.

 2             MR. DEMIRDJIAN:  Thank you.

 3             JUDGE DELVOIE:  And, of course --

 4             THE WITNESS: [Interpretation] Thank you very much.

 5             JUDGE DELVOIE:  You're welcome, Mr. Vukcevic.  And, of course,

 6     the length of your answers are of some importance now as well, aren't

 7     they?

 8             Please proceed, Mr. Demirdjian.

 9             MR. DEMIRDJIAN:  Thank you, Mr. President.

10        Q.   Dr. Vukcevic, just before the break, you were answering my

11     questions with respect to a video we saw on the screen with

12     Vojislav Seselj referring to the Serbian National Council, and I asked

13     you whether you knew who the president was.

14             MR. DEMIRDJIAN:  Could I ask that we display on the screen, 65

15     ter 1D02959.  This is at tab 14 of the Prosecution's list.

16        Q.   The article will appear on the screen in front of you,

17     Dr. Vukcevic, and -- okay.  We're having some problems with the monitor

18     here.  Do you see the article in front of you?

19        A.   Yes.

20        Q.   There we are.  Okay.  It's at the bottom right-hand corner - yes,

21     that's what it is.  The article is entitled:  "Negotiations About

22     Negotiations."  And for your information, Dr. Vukcevic, it is dated the

23     10th of April, 1991, and it was published in Vecernje List.  Could you

24     confirm that this is a Croatian daily; is that right?

25        A.   It is.

Page 11103

 1        Q.   Now, the first paragraph starts with "Vukovar."

 2             "After two relatively calm days, the population of the Vukovar

 3     district is attentively expecting the negotiations that should commence

 4     today in the municipal assembly of Vukovar."

 5             And towards the end of this first paragraph, we can see here:

 6             "Goran Hadzic, one of the leading SDS persons for Slavonia,

 7     Baranja, and Western Srem, as well as the president of the so-called

 8     Serbian National Council, also announced that negotiations would last

 9     long."

10             Now, this is the 10th of April, 1991, and the video we saw

11     earlier with Mr. Seselj was 11 days later, the 21st of April, 1991.

12     Would you agree that at the time Mr. Hadzic's role in the SNC was

13     publicly available?

14        A.   To the extent that the public read this and other newspapers that

15     mentioned it, that covered it, to that extent, the public was aware.

16        Q.   Now, of course, I was not there at the time you were.  Can you

17     tell us if this information at least was known to you in April of 1991?

18        A.   Which one?

19        Q.   The fact that Mr. Hadzic was the president of the Serbian

20     National Council of Slavonia, Baranja, and Western Srem.

21        A.   I heard people say that, the people around me.

22             MR. DEMIRDJIAN:  Your Honour, may I tender this exhibit.

23             JUDGE DELVOIE:  Admitted and marked.

24             THE REGISTRAR:  Exhibit P3251, Your Honours.

25             MR. DEMIRDJIAN:

Page 11104

 1        Q.   In fact, I'd like to show you a document, which is at tab 11.

 2     This is 65 ter 1939.13.  At the very top, we see here:

 3             "At the session that took place on 17 March 1991 in Sid, National

 4     Council of Serbs has elected for the council chairman, Mr. Goran Hadzic,

 5     from Pacetin."

 6             The document --

 7             MR. ZIVANOVIC:  Sorry, may I just object because this document,

 8     the translation of this document is not complete; namely, the footnote of

 9     this document was not translated.  And in the original, if we can scroll

10     down a little bit, we see the footnote reads -- it is too small.

11                 [Interpretation] "The decision was drafted after the session

12     of the Great National Assembly of 25 June 1991."

13             MR. DEMIRDJIAN:  Very well.  We can ask for a revision of the

14     translation to include the footnote.

15        Q.   Dr. Vukcevic, this is a decision which was published in a book

16     which was prepared by Mr. Ilija Petrovic himself, and it shows a date

17     here, 17th of March, 1991.  Would this appointment at this position in

18     the Serbian National Council correspond to the time-period where the

19     Serbian National Council was created?

20        A.   I was excommunicated very early on from many events because they

21     harboured and fostered mistrust towards me.  So there are many things I

22     do not know.  You have to believe me.  It's a fact.

23             MR. DEMIRDJIAN:  Your Honour, may we MFI it at this moment until

24     we have an updated translation.

25             JUDGE DELVOIE:  Yes.  Let if be MFI'd.

Page 11105

 1             THE REGISTRAR:  65 ter 1939.13?

 2             MR. DEMIRDJIAN:  That's the one, yes.

 3             THE REGISTRAR:  Exhibit 3252 marked for identification.

 4             JUDGE DELVOIE:  Thank you.

 5             MR. DEMIRDJIAN:  Thank you very much.

 6             MR. ZIVANOVIC:  I would just tell that I would object if it had

 7     to be tendered into evidence because the witness said that he doesn't

 8     know anything about this.

 9             JUDGE DELVOIE:  Mr. Demirdjian --

10             MR. DEMIRDJIAN:  Yes.

11             JUDGE DELVOIE:  -- perhaps it would be better to solve this

12     immediately --

13             MR. DEMIRDJIAN:  Yes, Your Honours --

14             JUDGE DELVOIE:  -- with your answer to the objection.

15             MR. DEMIRDJIAN:  Yes.  Your Honours, we saw an article just

16     earlier which showed that Mr. Hadzic's appointment to the Serbian

17     National Council was in the public.  This one gives us a more precise

18     date of his appointment.  Dr. Vukcevic told us a few minutes ago that he

19     was aware, that at least by April 1991 Mr. Hadzic was holding this

20     position.

21             So this document, we would suggest, provides you a more precise

22     date, and other excerpts from the -- Mr. Petrovic's book have been

23     tendered through Mr. Hadzic's testimony, at least four of them.  So this

24     is another one of those decisions published in this book.  So it is

25     strictly for the sake of precising [sic] the date of his appointment.

Page 11106

 1             JUDGE DELVOIE:  Mr. Zivanovic.

 2             MR. ZIVANOVIC:  I believe that there is no foundation for the

 3     tendering of this document with this witness, this particular witness,

 4     and in particular because of the footnote was not translated and from

 5     which we can see that in the written form this decision did not exist

 6     before June, 25th of June, 1991.  And ...

 7             MR. DEMIRDJIAN:  Your Honours, perhaps putting aside the footnote

 8     issue which we agreed we would translate, the witness just said a moment

 9     ago that he was familiar with the fact that at least by April Mr. Hadzic

10     held this role, and it is publicly published in newspaper articles as

11     well.  So I think that there is a nexus to the witness.  It showed that

12     not only did he know at the time but here we have a more precise date in

13     this document.

14             And perhaps I could -- there's four exhibits that have been

15     tendered so far from this book which have been shown to be reliable and

16     which have been shown to actually connect to evidence about the events at

17     the time.  These are Exhibits P3214, P3215, 3216, and 3217.

18             MR. ZIVANOVIC:  Sorry, the tendering of the other documents from

19     this book have nothing to do with the tendering of this particular

20     document.

21             THE WITNESS: [Interpretation] If I may be allowed to say

22     something and supplement my testimony by saying that, first and foremost,

23     I did not respect either Petrovic or Koncarevic because in my mind the

24     two of them were people who were not worthy of anybody's respect.

25             Second of all, that was a time when you couldn't know what was

Page 11107

 1     information and what was just the opposite or misinformation.  People say

 2     whatever they wanted, whatever pleased them, whatever suited them, and

 3     then they tried to convince you that they told you the truth, and then

 4     some other days you would hear the exactly opposite thing.

 5             Go ahead.

 6             JUDGE DELVOIE:  Excuse me, Mr. Vukcevic.  Sorry.  We are dealing

 7     here with a technical matter so just give us a minute, please.

 8                           [Trial Chamber confers]

 9             JUDGE DELVOIE:  The objection is overruled.  So the document

10     stays MFI'd until we have a translation with the footnote.  Thank you.

11             MR. DEMIRDJIAN:  Thank you, Your Honours.

12        Q.   Dr. Vukcevic, I would like us to return to the video that we were

13     looking at of the rally at Jagodnjak.  If you remember earlier I

14     mentioned to you that there were some utterances made by Seselj with

15     respect to you, and I would like us to take a look for a moment as to

16     what was said during this rally.  You will see it in front of you on the

17     screen.

18             MR. DEMIRDJIAN:  And before we go on, I'd like to make sure that

19     the interpreters have the transcript.  This is 65 ter 4785, tab 17, and

20     we'll need to turn to page 2 in both the English and the B/C/S version.

21             THE INTERPRETER:  Yes.

22             MR. DEMIRDJIAN:  Thank you.

23                           [Video-clip played]

24             "THE INTERPRETER: [Voiceover] The Serbian people will never

25     accept any confederal rearrangement of Yugoslavia.  No confederation.

Page 11108

 1     The present authorities in Croatia hit on the idea to form in divisions,

 2     arguments and conflicts among the Serbs because they realised they cannot

 3     achieve anything against Serbs when they are united and harmonious.  They

 4     can always find a few, a handful of Serbian traitors, like this

 5     Djuna Djukic, assistant to the Ustasha minister of police, who formed a

 6     new Serbian national party with the sole aim of introducing a Trojan

 7     horse into the Serbian ranks.  That party will never have any success

 8     among the Serbian people.  After all, in World War II, during a genocide

 9     in which 1 million Serbs were killed, the Ustasha leader Pavelic had a

10     Serbian deputy, Besarevic.  There will always be such traitors, but we

11     shall always recognise them and brand them on time.

12             "Here, among you in Baranja, another such traitor has appeared.

13     It is Vojislav Vukcevic whom the Serbian people has already driven out.

14     What is the aim of these traitors?  Today they speak in favour of the

15     cultural autonomy of the Serbian people in Croatia, but they also argue

16     in favour of Croatia remaining within the borders given to it as a

17     present by the criminal and crook Josip Broz Tito.  The Croatian

18     authorities are now willing to give the Serbs any form of autonomy -

19     cultural, political, or territorial - anything the Serbs want, as long as

20     they get a confederation in return.

21             "What is their aim?  The present internal borders in Yugoslavia

22     are purely administrative and they are not protected by any norm of

23     international law.  We can change them at will insofar as our political

24     strength allows, and the world does not dare interfere.  If we agree to a

25     confederation, these borders suddenly become borders between states,

Page 11109

 1     protected by the norms of international public law, and can never be

 2     changed again."

 3             MR. DEMIRDJIAN:

 4        Q.   Dr. Vukcevic, you heard the term "traitor" being used when

 5     Mr. Seselj spoke of you.  What impact did such speeches have on your life

 6     at that time?

 7        A.   They caused revulsion, but I don't know what other people thought

 8     about either him or me.

 9        Q.   And, sir, these type of speeches at the time made by Seselj and

10     later on we'll see Paroski or Ostojic, didn't these speeches have a

11     impact on their followers?

12        A.   You heard the clamour of the people who supported him.  Those

13     same people applauded me only a year earlier.  This is the lot of the

14     politicians everywhere.

15        Q.   So would you say that there had been a radicalisation of this

16     population?

17        A.   He arrived with a mission and the mission was to do things the

18     way he did them.  Very few people were so skilled and successful at

19     manipulating the people the way he did.  And I'm sure that he had his

20     supporters and like-minded people.  You heard people applauding when he

21     said that I was a traitor.  I established the Serbian party in that same

22     village, and I managed to put -- restore order among two factions in the

23     same village.  One faction were former Chetniks; the other, former

24     partisans.  And they applauded me when I did that, and only a year later,

25     you heard what happened.

Page 11110

 1        Q.   Now, did you hear also at the end of his speech Seselj seems to

 2     be challenging the established borders of the republics within the former

 3     Yugoslavia, and he challenges those borders drawn, as he says, by Tito.

 4     What did you think of such views at the time?

 5        A.   Personally what I thought, I thought that it was too late, that

 6     things like that should have been said well in time and not when he said

 7     them; and that his only goal was not only to change the borders but also

 8     to create misfortune which appeared very soon after that.

 9             MR. DEMIRDJIAN:  Your Honour, may I tender this video, please.

10             JUDGE DELVOIE:  Admitted and marked.

11             MR. DEMIRDJIAN:  65 ter 4785.

12             THE REGISTRAR:  Exhibit P3253, Your Honours.  Thank you.

13             MR. DEMIRDJIAN:  Thank you.

14        Q.   Dr. Vukcevic, were you familiar with the fact that after the

15     rally was held at Jagodnjak the police from Osijek investigated the

16     content of these speeches?

17        A.   There were a lot of rumours.  A lot was written about things.  I

18     can't remember what happened because by then I had already been revolted

19     by the whole thing, by all of the events, by some of the people.  And I

20     really can't remember what the Osijek police did, whom they questioned.

21     I really don't know.

22        Q.   Were you familiar with or were you in contact with the police

23     chief, Mr. Josip Reihl-Kir?

24        A.   Yes, I was in contact with him but I can tell you why and when.

25     The Serbs wanted me to supply them with arms.  I said I didn't have any

Page 11111

 1     and that I couldn't give them any arms.  And then I called an activist

 2     from our movement.  I wanted the two of us to go after see the chief of

 3     police Kir.  His name was Dragica Radic.  He went with me.

 4             I came to see the chief of police and I told him what the Serbs

 5     required from me, and I asked him to come and meet with the Serbs and

 6     told them what was possible.  And that's what happened in late

 7     February 1991.  I brought him to a meeting of the SDS board for Baranja.

 8     I could have knocked them out with a feather when they saw whom I had

 9     brought to that meeting.  They thought that it was a terrible

10     provocation, that it was not possible.

11             However, he was not just a common policeman.  He was very

12     extraordinary.  He was very smart, very well-meaning, and he said, "I

13     promise you" - and I have the minutes of that meeting - "I promise you

14     you will get weapons if you apply for them but on one condition, not

15     because you're Serbs or you're not Serbs.  You just have to prove that

16     you are not under criminal investigation, that there are no proceedings

17     instituted against you.  If not, you will get arms."

18             And that's the same all over the world and Croatia is not an

19     exception.  That's how it was.  Those who wanted to get weapons, or at

20     least that's what I think, nobody complained or bragged about that.

21     However, I heard that those who had applied did receive weapons.

22             On that occasion, he also asked us try and influence those Serbs

23     who were members of the police to come back to work because he personally

24     promised them that nothing bad would happen to them if they would only

25     come back to work.  And when that tragedy happened to Kir, Serbs in

Page 11112

 1     Baranja used a slogan and that slogan was "No peace after Kir."

 2        Q.   And very briefly could you please tell me, do you know whether he

 3     made a genuine effort at investigating those speeches made by Seselj,

 4     Ostojic, and Paroski, specifically threats that were made -- or words

 5     used against you?

 6        A.   Believe me, I don't know.  However, I never doubted his good

 7     intentions or his goodness as a man.  If it did not cost him anything, I

 8     mean in his position, I'm sure that he did it.  He was a good man.

 9     That's how I saw him and perceived him.

10        Q.   I'd like to move to a different topic, Dr. Vukcevic, and it

11     relates to your testimony where you stated that -- and this was on

12     Thursday of last week.  You stated you met Goran Hadzic on the 9th of

13     June, 1990, when the SDS border was created in your region, but you also

14     said that you had met him before as his wife was a student.

15        A.   You mean Vukovar?

16        Q.   Yes.  You also stated that you had met him before as his wife was

17     a student of yours.

18        A.   Yes, yes.  And that's correct.

19        Q.   Can you tell us how frequent had you met Mr. Hadzic before 1990

20     and how close were you to him?

21        A.   Those were just chance meetings.

22        Q.   Okay.

23        A.   I just happened to meet him.  We would greet each other.  We

24     would be polite and civilised when we happened to see each other, but

25     that was all.

Page 11113

 1        Q.   Earlier this morning you mentioned that you -- I believe you said

 2     you knew his family; is that right?

 3        A.   Yes.

 4        Q.   And by "his family," who did you mean exactly?

 5        A.   I was one of the guests at his christening in 1990, on the 14th

 6     of October or 14th September or, rather, it was his patron saint's day,

 7     on Saint Michael's Day.  And then I saw all of them in one place, his

 8     mother, his father, and all those who were his family members.  They were

 9     decent people, ordinary, decent people.

10        Q.   Mm-hm.  And did you happen to entertain each other or invite one

11     another for dinners?

12        A.   No.  Those were just the beginnings of our work in the Serbian

13     Democratic Party.  Later we did what we had to.  Each day was more

14     complex and more complicated than the previous ones.  It brought new

15     problems, new activities.  We didn't socialise at that time.  We would

16     see each other at meetings and gatherings.

17        Q.   And following the 9th of June of 1990, did that relationship

18     develop a little more?

19        A.   Well, yes, it did, insomuch as we travelled together to Knin.  We

20     attended the sessions of the Regional Board of the SDS, when we met on

21     party business, on the business of the Serbian Democratic Party, and

22     there was nothing else but that.  Nothing special.

23        Q.   Now, you mentioned last Thursday a discussion you had with

24     Mr. Hadzic in relation to a speech given by a man named Kresojevic in

25     Belgrade.  You remember talking about that last Thursday?

Page 11114

 1        A.   Yes, I remember that.

 2        Q.   Now, you stated that you discussed this speech with Mr. Hadzic

 3     during a car ride to Knin, and I'd like to ask you if you remember

 4     approximately --

 5        A.   Yes.

 6        Q.   -- when did this car ride take place.

 7        A.   Immediately after his speech in Belgrade.  And that event was

 8     still fresh, very fresh in our memories.

 9        Q.   Okay.  And this event in Belgrade took place when.

10        A.   I don't know.  I can't remember.

11        Q.   Was it in 1990 or 1991?

12        A.   In 1990.

13        Q.   And I assume this would have been the second half of 1990.

14        A.   Yes.  Most probably, yes.

15        Q.   Okay.  And if I understand well, the substance of what

16     Mr. Kresojevic said in his speech was that Serbs from Eastern Slavonia

17     fully supported Milosevic.  Is that what it was about?

18        A.   I believe so.

19        Q.   Okay.  And if I look at your statement, you say there that:

20     "Goran Hadzic said at the time that he would not make a speech supporting

21     Milosevic..."

22             Is that the gist of his reaction?

23        A.   Who was it who was not going to speak in favour of Milosevic?

24     Goran Hadzic or Milosevic?  I didn't quite understand your question, sir.

25        Q.   The sentence reads as follows:  "Goran Hadzic said at that time

Page 11115

 1     that he would not make a speech supporting Milosevic on any account."

 2        A.   Yes.

 3        Q.   Now, did he tell you why he considered it objectionable to

 4     support Milosevic?  Did he explain that to you?

 5        A.   Well, he believed that I shared his opinion, and we thought that

 6     the Serbs in Serbia did not understand the Serbs in Croatia and that they

 7     had a different view of the space, time, and people, the people's

 8     sentiment and desires.  And although we were Serbs just like the Serbs in

 9     Serbia, in some historical moments, we were two entirely different

10     worlds.

11        Q.   Now, you mentioned that in doing so, Hadzic displayed a great

12     deal of courage in telling you his position with respect to

13     Mr. Milosevic.

14        A.   Yes.  Yes.

15        Q.   Now --

16        A.   Yes, yes, yes.

17        Q.   -- he never stated this position in public, did he?

18        A.   I don't know what he said, where he said it, whether yes or no.

19     I don't know.  I didn't follow the events so closely and so precisely, so

20     I wouldn't know.

21             I have to tell you, though, that the Serbs in Croatia differed

22     and that they were distinguished into those who supported Milosevic and

23     those who didn't.  Milosevic was not supported by those who were better

24     acquainted with the circumstances of the Serbs in Croatia because people

25     who came from Serbia and who behaved in the way they did could not be

Page 11116

 1     supported.  However, whoever did not praise Milosevic was not a good

 2     Serb.

 3        Q.   Sir, I'd like you to take a look at an interview, Exhibit P1742.

 4     It's at tab 55.  This is an article entitled:  "Man For Tough Talk."  It

 5     was published on the 25th of March, 1992, in Borba.  And in the English

 6     version, I would like us to turn to page 3, and in the B/C/S version,

 7     could we go to the bottom of the second column.

 8             There's a question there put to Mr. Hadzic which reads as

 9     follows:  "What is your position towards the SPS and Slobodan Milosevic?"

10             Now, Mr. Hadzic gives a lengthy answer at the end of which he

11     says the following.  We have to turn to page 4 in the English version,

12     and in the B/C/S version, we need to go to the top of the third column.

13     Yes.

14             There's a sentence here that reads as follows:  "I have a good

15     relationship with Milosevic for whom I believe ... is the greatest living

16     Serb politician and I have great respect for his work ..."

17             Now, Dr. Vukcevic, this is March 1992.  Perhaps Goran Hadzic

18     displayed some courage in a one-on-one conversation with you, but I would

19     put it to you that he had great respect for Milosevic, just as he says

20     publicly in this interview.  Would you agree that this courage he

21     displayed was only in private?

22        A.   I know what he said, but I don't know what he was thinking when

23     he said it.  It's very hard to speak on somebody's behalf.  It's very

24     difficult to say what one person thinks when he says what he does.  As

25     I've told you, after the 15th or 20th of April, 1991, I excommunicated

Page 11117

 1     myself of my own will.  I removed myself from everything that I had been

 2     doing up to then.

 3        Q.   And I can imagine that as a founder of this political party,

 4     these were shocking moments in your life.

 5        A.   Very, very.

 6        Q.   And in the same -- or in the same topic, if you remember at least

 7     in your statement, you state that up until April 1991, when you left the

 8     party, Hadzic was in the moderate wing of the SDS, and I asked you this

 9     morning if it meant that this changed.  But you were not in touch with

10     him anymore after you left the leadership of the SDS?

11        A.   I was no longer in contact with him.

12        Q.   And I want to show you a small clip which is dated January 1991.

13             MR. DEMIRDJIAN:  It's Exhibit P53 in Sanction, please.  This is

14     tab 9.  For the interpreters, this will be page 1 of both English and

15     B/C/S versions.

16        Q.   Now, Dr. Vukcevic, the clip I'm going to show you is on the

17     occasion of the celebration of Sveti Sava, which I understand is held on

18     27th of January each other.  Is that right?

19        A.   Correct.  27 January.

20             MR. DEMIRDJIAN:  Are the interpreters ready with the transcript?

21             THE INTERPRETER:  Yes, we are.

22             MR. DEMIRDJIAN:  Thank you.

23             Can we show the first clip, please.

24                           [Video-clip played]

25             "THE INTERPRETER: [Voiceover]

Page 11118

 1             "Goran Hadzic:  Brothers and sisters, I greet you with our

 2     traditional Serb greeting:  May God be with you.

 3             "As president of the Municipal Board which you belong to, let me

 4     say, as it is my duty, a few words about our Vukovar Municipal Board.

 5     Even though there are many topics we're going to discuss later on, our

 6     party was established on 10 June last year in Vukovar and 19 boards have

 7     been established since then.  Today the party has 21 boards and I

 8     congratulate you on establishing your two local boards.  We have already

 9     faced many problems in our party.  You are familiar with them and you

10     know who caused them.  However, we managed to overcome them and we should

11     thank our current leadership ..."

12             MR. DEMIRDJIAN:

13        Q.   Sir, I just wanted you to listen to this original portion of the

14     clip which establishes the date when the local boards were created, and

15     you've testified about that earlier.  I'd like you now to look at the

16     second clip.

17             MR. DEMIRDJIAN:  And for the interpreters, we need to turn to

18     page 2 in both of English and the B/C/S.  The time code for this one will

19     be 3 minutes, 29 seconds onwards.

20        Q.   Sir, while we're fixing some technical issues, can I ask you, are

21     you -- were you present at this rally by any chance?

22        A.   No.

23        Q.   Very well.

24             MR. DEMIRDJIAN:  Are the interpreters ready with page 2?

25             THE INTERPRETER:  We are.

Page 11119

 1             MR. DEMIRDJIAN:  Thank you.  Just waiting for the video.

 2                           [Video-clip played]

 3             "Goran Hadzic:  For the moment we have to accept it and organise

 4     ourselves which you had occasion to see on the TV two nights ago.  I'm

 5     sure that you experienced it just as I did.  This is what I think.  In

 6     the whole world we cannot find 80.000 Serbs who would just say something

 7     bad about another people, who would just verbally say something offensive

 8     about other people.  Whereas, those others have 80.000 machine-guns in

 9     their possession and keep them so they could use them against us.  It is

10     ridiculous.  1941 has happened again.  1945 has happened again.  Then in

11     1971, we thought we would forgive them.  It wouldn't happen again.  I'm

12     telling you now, if the Croatian people do not renounce their Ustashas

13     publicly, we will propose through our Serbian National Council that we

14     cut all ties between Serbs and Croats."

15             MR. DEMIRDJIAN:

16        Q.   Dr. Vukcevic, would you able to hear what was said?  I know the

17     volume was not perfect but were you able to hear?

18        A.   I heard it, yeah.

19        Q.   And this is the 27th of January, and Mr. Hadzic here talks about

20     1941, 1945, and that the Croatian people should renounce their Ustasha.

21             If you remember earlier today, we talked about these sorts of

22     terms - Chetnik, Ustasha - being used around that time.  Is this the type

23     of speech you favoured at the time?

24        A.   I myself did not use these terms.  But you have to understand the

25     frame of mind that prevailed in that time.  This is a typical moment when

Page 11120

 1     the masses expect you to say the words they are harbouring in their

 2     hearts and minds, traumatised as they were.

 3             To make a rapprochement with them and to convince them that you

 4     feel the same, sometimes you have to say even things you don't mean in

 5     order to be closer to them, and then they would accept you as one of

 6     their own, as one they hold dear.

 7             You should not take Goran Hadzic always at his word when you

 8     listen to his speeches.  His speeches were tailored to the occasion in

 9     order to make him accepted by the crowd.  We ourselves did not always

10     feel comfortable in such places.  Here and now, it is very difficult for

11     you to understand the state of mind that prevailed among the people then.

12     You can't understand what it was really like.  When, in your own country,

13     you cannot walk freely, you cannot speak freely, you cannot act like

14     before, then you can hardly avoid the reaction of the kind you just

15     heard.

16        Q.   Now, in your statement, you tell us that while you were in the

17     party leadership, "We kept appeasing the Serbs and telling them that the

18     genocide of the Second World War would not be repeated."

19             Now, sir, this speech we heard a moment ago - and this is a just

20     a small clip; there is more - this speech we heard a moment ago clearly

21     goes against your efforts to appease the Serb population, doesn't it?

22        A.   I have been telling you things as I saw them but you must believe

23     me that behind these words is a very sincere, open heart.  It's not

24     exactly as it sounds.  Things are not as they appear.

25        Q.   But publicly to those who are in the gathering here and listening

Page 11121

 1     to his words, those words are not going to appease them, are they?

 2        A.   Look, you can try to find peace and appease others, but when you

 3     get out of that place and you know that you will not be allowed to stay

 4     in peace, that somebody would raise a hand at you, would shoot at you,

 5     then you cannot be surprised at this sentiment among these people and

 6     that they wanted to hear words like this.  They expected, they wanted to

 7     hear this, if I am at all good at reading people's emotions.

 8             It all depends on the educational attainment, on their personal

 9     experience, on their age, if they had already lived through something

10     similar before, then they would be more sensitive, more receptive to

11     these words.

12             I've already told you that I was not very popular.  My house was

13     fired at.  I was attacked.  People didn't like me because I was telling

14     the truth.  People don't want to hear the truth.  They want to hear what

15     they wish for.  And you have to be very careful in evaluating what is

16     publicly said, what is actually meant.  In Belgrade I gained some

17     experience in politics and I learned one thing:  People do not like the

18     truth.  They expect you to say the things they want to hear.

19        Q.   If I may cut you here so that we carry on.  Dr. Vukcevic, it is

20     correct, however, that would you not have made this speech?

21        A.   I would not, but it doesn't mean that others would not.

22        Q.   During this speech, which we just heard, he also makes a

23     reference to the Serbian National Council which was created perhaps three

24     weeks before this rally.  You were not in favour of the creation of the

25     Serbian National Council, were you?

Page 11122

 1        A.   No, I was not because Serbs had their own national council based

 2     in Knin.  And Milan Babic was president of that Serbian National Council,

 3     and we believed that they were some kind of Serbian shadow government and

 4     that one was enough.  We didn't need another.  However, there were people

 5     who made it happen, that another Serbian National Council be established

 6     for Eastern Slavonia as well, had certain purposes in mind.

 7             Goran Hadzic, who has in his life uttered many words which he

 8     didn't mean, is not the greatest culprit.  You should not consider him as

 9     the greatest culprit.  There are many others who are more responsible

10     than he and who are no longer alive.

11             I remembered, by the way, two names you asked me about before.

12     One was Dusan Kulic, another was [Realtime transcript read in error

13     "Milan"] Jovan Popovic, and a third one was Jovan Krkobabic.  He died

14     recently.  He was the deputy prime minister of Serbia.  He demanded that

15     I follow their instructions; otherwise, I would not fare well and I

16     indeed didn't fare well.

17             So judge for yourself:  Did Goran Hadzic say these things because

18     he meant them or because he had to say them?

19        Q.   Sir, on the topic of the Serbian National Council, I'd like you

20     to look at an interview you gave on the 15th of January, 1991.

21             MR. DEMIRDJIAN:  This is 65 ter 6580, at tab 8.

22             MR. ZIVANOVIC:  Sorry, I just think that one of the names was not

23     transcribed correctly.  It is in line 19.  After Dusan Kulic, it was

24     written Milan Popovic.  But as far as I heard, the witness mentioned

25     another name.

Page 11123

 1             MR. DEMIRDJIAN:  Yes.

 2        Q.   Dr. Vukcevic, if you could specify --

 3        A.   Once again, Dusan Kulic, Jovan Krkobabic, and Jovo Kokot.

 4        Q.   Thank you very much.  We see here a newspaper article entitled:

 5     "New Serbian National Council Founded in Secret."  This was published in

 6     Vjesnik on the 15th of January, 1991, and I'd like to take you to the

 7     third column in the B/C/S version and that's page 2 in the English

 8     version.  Yes, we can scroll down a little bit for the B/C/S version.

 9     Thank you.

10             I believe the title of this section is called "They Surprised the

11     SDS," and it reads here:

12             "Ilija Koncarevic was elected the Secretary-General of the

13     Serbian National Council.  However, it is unclear what this had to do

14     with what is in Knin, but it is clear that the scenario of their actions

15     is the same.  However, its formation surprised even some of the

16     responsible leaders of the SDS.  Vojislav Vukcevic, the vice-president of

17     the SDS Executive Committee, speaking about the current events in

18     Croatia, called the council ... unconstitutional.  In Vukcevic's opinion,

19     if something was formed, it could only be a board of the already existing

20     Serbian National Council formed in Knin."

21             And if we scroll up in the B/C/S version all the way to the top

22     of the fourth column, the following sentence says:  "It is obvious that

23     the Knin-ification of Slavonia and Baranja is starting ..."

24             Now, sir, by calling or by stating that this council was

25     unconstitutional, can you tell us what you meant by that?

Page 11124

 1        A.   I meant what is written and what I said.  I said that the Serbs

 2     already had their Serbian National Council based in Knin and it was valid

 3     for all the Serbs in Croatia.  I thought that every fragmentation and

 4     every separation of any part of Croatia from the whole amounted to a

 5     breakup of Yugoslavia, that it was contrary to the interests of

 6     Yugoslavia, and we were fighting to preserve Yugoslavia.  That's why I

 7     was saying we don't need a national council for Slavonia and Baranja

 8     because we already have one national council based in Knin for all the

 9     Serbs, and that's exactly as we read here.

10        Q.   Now, Dr. Vukcevic, I heard you earlier when you stated that --

11     well, let me actually get the words exactly so I don't misquote you.  You

12     said that:  "Goran Hadzic, who has in his life uttered many words which

13     he didn't mean, is not the greatest culprit."

14             Now, sir, whether he meant those words or not, he did say them

15     and they did have an impact on the people on the ground; is that right?

16        A.   I was not among the people on the ground, and I don't know what

17     kind of impact it made.

18        Q.   You didn't remain in Baranja until September 1991, however.

19     That's what I mean by "on the ground."

20        A.   Yes, but until the 6th of September, I had spent one year in the

21     monastery of Hilandar, on Sveta Gora, the holy mountain.

22        Q.   I'm sorry, that's not very clear to me here.  One year in a

23     monastery?

24        A.   No, only one month, but in that year, 1991, before I definitively

25     left Beli Manastir.  In fact, I was expelled from Beli Manastir.  They

Page 11125

 1     had seized my car and told me that the staff of Baranja had made a

 2     decision that I had to leave.  That was my activity for that year.

 3             And as for Sveta Gora and the monastery of Hilandar, I spent the

 4     entire month of July 1991 there.  And then I returned briefly to

 5     Beli Manastir and then again I travelled again to Belgrade and so on.

 6        Q.   Now, sir, I understand that you have some sympathy for

 7     Mr. Hadzic.  However, considering what you were trying to achieve, I'm

 8     putting it to you that you may have been a negotiator, someone who was

 9     ready to talk, but what we see here goes against your every effort, a

10     creation of a Serbian National Council, speeches which are not aimed at

11     appeasing the population, the use of terms that you did not condone, such

12     as Ustasha and the like?

13        A.   The other side, the side that demanded it from Goran Hadzic, was

14     much stronger than I.  I was just an ordinary man.

15        Q.   Sir, you said a moment ago that you were expelled from

16     Beli Manastir and that they seized your car and told you that the staff

17     of Baranja had made a decision that you had to leave.  Was this staff led

18     by a man named Borivoje Zivanovic?

19        A.   No, he was always a very small man and remained a small man.  He

20     was just an assistant to another Borivoje who was the commander of the

21     Baranja Defence Staff.

22        Q.   Do you remember the last name of this commander?

23        A.   Boro Dobrokes.

24             MR. DEMIRDJIAN:  Your Honour, I notice the time.  Looking at the

25     questions I have, I will probably need another 20 minutes.  I'm not sure

Page 11126

 1     if we have made arrangements for an extra session to complete the

 2     witness's testimony today.

 3             JUDGE DELVOIE:  We did, Mr. Demirdjian.

 4             Mr. Zivanovic, your re-direct, time-wise?

 5             MR. ZIVANOVIC:  My estimate is half an hour.

 6             JUDGE DELVOIE:  Okay.  Then we will -- is this the time for

 7     you -- the best time for you to break?

 8             MR. DEMIRDJIAN:  Your Honours, yes, because I will enter a topic

 9     which will last more than two, three minutes.

10             JUDGE DELVOIE:  So we will break now and come back at 3.00 for a

11     one-hour session.

12             MR. DEMIRDJIAN:  Thank you, Your Honours.

13             JUDGE DELVOIE:  And I'll keep you to that, both of you.

14             MR. DEMIRDJIAN:  Thank you, Your Honours.

15             THE WITNESS: [Interpretation] I'm very grateful to you.  Thank

16     you very much.

17             JUDGE DELVOIE:  You're welcome, Mr. Vukcevic.

18             Court adjourned.

19                           [The witness stands down]

20                           --- Luncheon recess taken at 1.56 p.m.

21                           --- On resuming at 2.59 p.m.

22                           [The witness takes the stand]

23             JUDGE DELVOIE:  Yes, Mr. Demirdjian, please proceed.

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

25        Q.   Dr. Vukcevic, I will try to go as fast as I can so we can


Page 11127

 1     complete your testimony this afternoon.

 2             So I'd like us to take a look at a document which is 65 ter 6588,

 3     at tab 44.  And, Dr. Vukcevic, this is in line with the topic that we

 4     left off with respect to your role as a negotiator and the comparison we

 5     made with the words uttered by Mr. Hadzic in early 1991.

 6             What we have here --

 7             MR. DEMIRDJIAN:  And I apologise, Your Honours, we need to go

 8     into private session for this document.

 9             JUDGE DELVOIE:  Private session, please.

10                           [Private session]

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 11128











11 Pages 11128-11129 redacted. Private session.
















Page 11130

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4                           [Open session]

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

 6             JUDGE DELVOIE:  Thank you.

 7             MR. DEMIRDJIAN:  Thank you.  And, Your Honours, before the break

 8     I did use a newspaper article which captured Dr. Vukcevic's reaction to

 9     the creation of the Serbian National Council but I failed to tender it.

10     This was 65 ter 6580.  May I move to tender it at this stage, please.

11             JUDGE DELVOIE:  Admitted and marked.

12             THE REGISTRAR:  Exhibit P3255, Your Honours.

13             JUDGE DELVOIE:  Thank you.

14             MR. DEMIRDJIAN:  Thank you.

15        Q.   Dr. Vukcevic, after you left Baranja in September of 1991, you

16     went to establish yourself in Belgrade; is that right?

17        A.   Yes.

18        Q.   And is it correct to say that in early 1992, you started to work

19     before the Belgrade Military Court?

20        A.   True.

21        Q.   Now, this does not appear anywhere in your statement that we have

22     here.  Is there any reason why this was not included in your statement?

23        A.   I don't know why.  However, to your question, I can only say that

24     there was no reason for me not to include that.  The supreme military

25     prosecutor was my friend.  He hailed from a village near Osijek.  He

Page 11131

 1     offered me an opportunity and he told me, "You lost your job.  I am

 2     offering you to be an attorney-at-law to represent the people who were

 3     arrested as members of the ZNG," the national guards in Croatia.  "Defend

 4     them as much as you can and as much as you wish."  That's how I became

 5     a defence counsel ex officio.

 6        Q.   Now, as a defence counsel, you represented, as you just said a

 7     moment ago, members of the ZNG.  And may I ask you, first of all, what is

 8     the name of the prosecutor you were mentioning, the supreme military

 9     prosecutor?

10        A.   Miladen Papic.  Unfortunately, he died.

11        Q.   According to the information that I have found, you seem to have

12     defended quite a few members of the ZNG; perhaps somewhere around 15 or

13     20.  Would that be right or is it more than that?

14        A.   No, no, no, no.  Three or four.

15        Q.   Okay.  Is it correct to say that in some cases you did represent

16     two or three accused in the same trial?

17        A.   No, no.  The most attractive trial for the most heinous of crimes

18     had Cibaric as the accused, Nikola Cibaric.  I also represented Ksenija

19     Piplica and Marko, whose family name escapes me at the moment.  That's

20     all.

21        Q.   And in none of these trials did you represent more than one

22     defendant?

23        A.   No.

24        Q.   Now, during these -- during the time that you were working before

25     the Belgrade Military Court, did you at any time represent any members of

Page 11132

 1     the JNA or SFRY armed forces?

 2        A.   No, nobody.

 3        Q.   Were you --

 4        A.   I apologise.  I did represent a young soldier.  I believe that he

 5     deserted from the JNA.  He was a Croat from Zagreb.  I represented him.

 6        Q.   Very well.  Were there -- in fact, to your knowledge, were there

 7     any proceedings against JNA soldiers or members of the Serbian

 8     Territorial Defence for alleged crimes committed in Croatia?

 9        A.   No, no.  I spoke to the prosecutor and his deputies - I'm

10     referring to the late Papic - and I asked them how come you're only

11     charging people with armed rebellion?  It's a trivial crime when

12     everything indicates that what they did was they committed war crimes.

13     They were surprised by my question, but they were first and foremost

14     surprised that I dared ask them that.  They were not so much surprised

15     with the essence of my question because they had read a lot and they knew

16     a lot, and they knew that those crimes were war crimes, on both sides.

17        Q.   And to come back to my question, I was not asking about the

18     qualification of the crime; I was asking whether there were any

19     proceedings against not ZNG or Croatian defenders but against JNA and

20     Serb TO defenders -- fighters.  Do you know whether there were any

21     proceedings against JNA soldiers?

22        A.   There was a case against a Serb who opened fire on another Serb

23     for private reasons.  However, the proceedings against him were not

24     conducted in the same way the proceedings were conducted against the

25     members of the ZNG, no.

Page 11133

 1        Q.   Well, you mentioned a moment ago the name of Nikola Cibaric who

 2     you represented before the military court.  Were you informed by

 3     Mr. Cibaric about the circumstances of his arrest and his detention?

 4        A.   It was a long time ago.  I don't remember what I heard from him,

 5     but the person was rather simple, retarded, that is.  He had killed a

 6     woman, the mother of three children, on the order or at the request of

 7     another man who told him, "Bring the woman out and kill her."  And so he

 8     did.

 9             At that time the prime minister of the Federal Republic of

10     Yugoslavia was Milan Panic.  He had been sent from the USA to conduct the

11     Serbian policy.  Cibaric was sentenced to death because death penalty was

12     still part of the legal system.  They were all sentenced to death.  I was

13     not able to defend them because the facts of the crime were

14     uncontestable.  Milan Panic, actually, exchanged them and returned them

15     to Croatia, and he got several Serbian pilots in exchange for those men.

16     I don't know who the pilots are; I never saw them.  But I know that those

17     people who had been sentenced to death were actually acquitted.

18        Q.   Now, sir, you said a moment that you don't remember what you

19     heard from him in relation to his arrest and his detention.  If I were to

20     put it to you that Mr. Cibaric was severely tortured, would that surprise

21     you?

22        A.   I'm trying to remember whether he told me that or not.  You know

23     what?  As I've already told you, he was of diminished mental capacities.

24     I'm sure that he was under a lot of pressure in view of the fact of what

25     he had done and what people did to him.  He didn't know who I was,

Page 11134

 1     whether I was a proper defence counsel or whether I was sent to provoke

 2     him.  I really can't remember whether he told me those things the way you

 3     say that he might have.  I really can't remember.

 4        Q.   Sir, is it correct that the bulk of the evidence against him was

 5     a statement that he gave, that he provided to the military court?

 6             MR. ZIVANOVIC:  I would object to this line of questioning.  We

 7     shall not review the proceeding -- criminal proceeding before the

 8     military court, and it is not in relation to this case at all.

 9             JUDGE DELVOIE:  Mr. Demirdjian.

10             MR. DEMIRDJIAN:  Your Honours, I'm not clear about the objection.

11                           [Trial Chamber confers]

12             JUDGE DELVOIE:  Well, Mr. Zivanovic, could you clarify?  Is it

13     relevance?  Is it --

14             MR. ZIVANOVIC:  Yes.  This subject is completely irrelevant, how

15     the military court of Yugoslavia worked in criminal proceedings against

16     this particular person.

17             JUDGE DELVOIE:  Mr. Demirdjian.

18             MR. DEMIRDJIAN:  Your Honours, it is part of the -- well, maybe I

19     shouldn't make these comments in front of the witness.  Perhaps he should

20     remove his headphones before I explain myself.

21             JUDGE DELVOIE:  Mr. Vukcevic?  Mr. Vukcevic, do you understand

22     English?

23             THE WITNESS: [Interpretation] No, unfortunately not.

24             JUDGE DELVOIE:  Then could I ask you to remove your headphones

25     off for a few moments.

Page 11135

 1                           [Prosecution counsel confer]

 2             JUDGE DELVOIE:  Yes, Mr. Demirdjian.

 3             MR. DEMIRDJIAN:  Yes.  Your Honours, it is part of the

 4     Prosecution's case that the Yugoslav armed forces obviously were part of

 5     the joint criminal enterprise - that is what we are saying - and that the

 6     military judicial system was one-sided and that it was biased.  This

 7     gentleman was in a position to give us some information about the

 8     functioning of the military judicial system.  He has given us already an

 9     answer in saying that only one group of people or one side to the

10     conflict were being tried by this military judicial system, and this is

11     the line of questioning that has the relevance.

12             JUDGE DELVOIE:  Yes, Mr. Zivanovic.

13             MR. ZIVANOVIC:  I was not informed that the military justice

14     system of Yugoslavia was a part of joint criminal enterprise.  It is

15     first time that I hear.

16             JUDGE DELVOIE:  That's not what Mr. Demirdjian said.

17     Mr. Demirdjian said JNA.

18             MR. ZIVANOVIC:  JNA, but these questions are about military

19     court.

20             MR. DEMIRDJIAN:  Which are part of the JNA.  We've heard the

21     military expert extensively on this matter.

22             MR. ZIVANOVIC:  I don't agree.

23                           [Trial Chamber confers]

24             JUDGE DELVOIE:  We'll allow the question, Mr. Demirdjian, if the

25     question and answer doesn't take more than a few minutes.


Page 11136

 1             MR. DEMIRDJIAN:  Thank you, Your Honours.  Much obliged.  Let me

 2     go back to the question.

 3        Q.   Dr. Vukcevic, you can put back your headphones.  Let me repeat

 4     the question, Dr. Vukcevic.  Is it correct to say that in the Cibaric

 5     case, the bulk of the evidence against him was a statement that was --

 6     that he provided to the military court?

 7        A.   No, it's not correct.

 8        Q.   Were you familiar with the circumstances of how the statement was

 9     taken from him?

10        A.   No.

11        Q.   He didn't tell you anything?

12        A.   I honestly don't remember.  It was such a long time ago.

13        Q.   Very well.  Let me show you one document, Dr. Vukcevic, and we'll

14     conclude with this.

15             MR. DEMIRDJIAN:  Could we show 65 ter 6600 at tab 43.  We can go

16     to page 5 in the English version and page 1 in the B/C/S version.

17             That's fine.  It appears that this topic was doomed from the

18     beginning, so I will conclude my cross-examination at this stage.

19             Dr. Vukcevic, I thank you for your answers this afternoon.

20             JUDGE DELVOIE:  Thank you, Mr. Demirdjian.

21             Mr. Zivanovic, cross -- sorry, re-direct?

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

23                           Re-examination by Mr. Zivanovic:

24        Q.   [Interpretation] Mr. Vukcevic, I'd like us to look at a document

25     that was shown to you by the Prosecutor, P3250.  This is an interview in

Page 11137

 1     the Vreme magazine published on the 10th of August, 1996.  I'm interested

 2     in page 2, both in the original and in the English translation.

 3             Only one part of interview was read out to you so you couldn't

 4     say what that part referred to.  That's why I'm going to read the entire

 5     passage.  The question was:  "How do you see the future of Eastern

 6     Slavonia, Baranja and Western Srem, i.e., the territory under the

 7     transitional administration of the United Nations?"

 8             Your answer was this:

 9             "At the beginning of all these developments from before, there

10     was a thought for which I did not have enough understanding.  It says

11     that you must ask for more in order to get less.

12             "However, the problem is in the fact that these people don't know

13     what they want, and even when they are offered something, they don't know

14     how to take it.  I am afraid that tackless statements and actions by

15     Goran Hadzic and the leadership in Eastern Slavonia are simply a

16     repetition of what happened to the Serbs in Croatia while they lived in

17     the Republic of Serbian Krajina.

18             "The representatives of that people ought to know what they can

19     ask for and how much they can ask for.  The UN Security Council extended

20     the Erdut agreement until July 1997 ..."

21        A.   I wouldn't say that the year was 1997.  It was, rather, 1995.

22        Q.   Yes, that's correct.  Could you please wait for me to finish and

23     then I will invite your comments.

24             Now I'll continue reading:

25             "... and one should not expect that this dead-line will be

Page 11138

 1     extended any further.  Therefore, in the remaining 12 months or less,

 2     they must adapt their demands not only to the mood of the other party to

 3     the agreement, that is Croatia, but also the interests of the

 4     international community which will not go back upon its word.  The

 5     situation in Bosnia shows this clearly, doesn't it?  Why is it that they

 6     cannot learn from their experience going back only a bit longer than a

 7     year ago?  How come that they have not learned to ask for much in order

 8     to get less but to ask exactly as much as they can get?  As much as they

 9     can get has already been written and signed by them in the Erdut

10     agreement.  Why do think now demand more than that?  In whose interests

11     are they doing that?"

12             First of all, let me tell you that what you said was said in

13     1995.

14        A.   I misspoke.

15        Q.   Could you now tell us -- you were very critical but when was

16     that?  Was that after the war or during the war or, rather, was this

17     happening during the period between 1991 and 1993?  This what we are the

18     most interested in.

19        A.   Thank you very much.  I was such an ardent advocate of the Z-4

20     plan which was offered to the Serbs by the international community.  I

21     thought that was the best for them.  Let me use just a couple of words to

22     explain --

23        Q.   Excuse me for interrupting you.  I am only entitled to ask

24     questions arising from the cross-examination by the Prosecution.  Since

25     the Z-4 plan was not a subject of their cross-examination, we have to

Page 11139

 1     limit ourselves to what I am entitled to ask.

 2        A.   Well, when you said that they were asking for more than they

 3     could get was precisely the Z-4 plan.  The public in Serbia was in total

 4     upheaval and so over-excited over it that it's difficult to even imagine

 5     today.

 6        Q.   Let me ask you, was this a kind of criticism for rejecting the

 7     Z-4 plan?

 8        A.   Yes, yes, yes.  That was the worst, the stupidest, the dumbest

 9     act of the Serbs from that time.

10        Q.   Can you just remember when the Z-4 plan was on the table?

11        A.   I can.  February 1995.  The mass media in Serbia reported at that

12     time that Milan Martic didn't want to take the Z-4 plan in his hands

13     even.  A man with modest education, almost without any education at all,

14     had the right to reject a text that the most eminent legal experts have

15     drafted and the most prominent diplomats brought to his feet.

16             MR. ZIVANOVIC: [Interpretation] Could we now look at D184.

17        Q.   While we are waiting, you heard the question of the Prosecution

18     whether the Serbian National Council ever adopted a decision to annex the

19     region to Serbia.

20        A.   Yes, I remember.

21        Q.   We have this document now --

22             MR. ZIVANOVIC:  Could we zoom in on the text "Vukcevic cannot

23     represent us" in the original.

24        Q.   [Interpretation] You are certainly able to read this.

25        A.   Certainly, I have my own copy as well.

Page 11140

 1        Q.   Here is my question then:  We see here in the first sentence:

 2     "The Serbian National Council for Slavonia, Baranja, and Western Srem, at

 3     its session last night, decided to annex these lands to Vojvodina,"

 4     et cetera.

 5             When you spoke about the decision of the Serbian National Council

 6     to annex the region to Serbia, did you mean this decision?

 7        A.   No, I meant another decision.  When I said that, I had lost sight

 8     of this fact, and you reminded me quite rightfully that I made a mistake.

 9     I should add to my answer.  What else can I say?  Stupidity and ignorance

10     have no limits.  They are immeasurable.

11        Q.   When you were saying that the Serbian National Council had made a

12     decision to join --

13        A.   Yes, it sounded as if it was presided over by Goran Hadzic, but

14     that's not true.  By that time, he was already outside of the district.

15        Q.   Can we look at this text's date?  When was it published?

16        A.   1st April 1991.

17        Q.   This text says that the decision was made at the session the

18     night before.

19        A.   Right, on the 31st of March.

20        Q.   It was one day after the meeting in Obrovac, on the 30th of

21     March.

22        A.   Yes, yes.

23             MR. ZIVANOVIC:  May we see, please, P1742.

24        Q.   [Interpretation] The Prosecutor asked you, among other things,

25     whether in his public appearances Goran Hadzic ever spoke against

Page 11141

 1     Milosevic and he showed you this text.  Could we look at the box with the

 2     subheading, "Monarchist, Royalist."  I will read out to you only the

 3     first sentence.  This is what Goran Hadzic says here:

 4             "I'm a royalist by conviction.  But I accept the majority

 5     decision of the people who are to state their own views and wishes.  It

 6     would be my wish for the people to vote for a monarchy, for the king to

 7     come back, but I would like to see a monarchy of the Swedish type."

 8             This is a quotation.  How would this sound to the ears of

 9     President Milosevic?

10        A.   It would be the same as if a wasp got into his ear and buzzed

11     inside.  Milosevic could not stand the idea of a monarchy and he couldn't

12     stand the people who were talking about it.

13        Q.   Tell me, was there a certain degree of civil disobedience or

14     courage for a political leader at that time to come out with something

15     like this in public?

16        A.   It was certainly civic courage, and he was taking great risks.

17     And, after saying something like this, he could well expect anything to

18     happen.

19             MR. ZIVANOVIC:  May we see, please, P53.  It is second page, both

20     in original and English translation.

21        Q.   [Interpretation] The Prosecutor showed you a video-clip filmed at

22     a rally in January 1991.  I will not play it again, but I will read to

23     you part of the text that was discussed.  I believe it is in the record.

24             Let me ask you first:  Do you recall that some illegal

25     distribution of weapons in Croatia was broadcast on TV in 1991?

Page 11142

 1        A.   Yes, that programme was seen by all of Yugoslavia.

 2        Q.   I'll read out to you only one passage from what he said.

 3             Goran Hadzic says on page 2:

 4             "This is my thinking.  In the entire world we could not find

 5     80.000 Serbs who would just verbally come out against another people,

 6     whereas they have 80.000 automatic rifles and keep them in store to use

 7     them one day against us.  This borders on lunacy."

 8             Can you -- can you even suppose which 80.000 automatic weapons he

 9     is referring to?

10        A.   Yes.

11        Q.   Do you think he's referring to the illegally distributed weapons,

12     the illegally imported weapons?

13        A.   Yes.  And what is the question?

14        Q.   What was the atmosphere among the Serbian people after this

15     programme was broadcast, after they saw how these weapons were being

16     imported illegally and how they intended to use them?

17        A.   Terrible fear reigned among the Serbs after that programme.  They

18     started saying, "We want weapons too."  They asked me to get them

19     weapons.  That's why I went to see Kir, and I asked him to go and explain

20     to the Serbs how they can get hold of weapons.  Only in that way and in

21     no other way.

22        Q.   How would it have been received if any of the current Serbian

23     leaders had come out before the people and said, "Let them have their

24     80.000 weapons.  Don't do anything.  Just keep quiet."

25        A.   First of all, they would have booed him off the stage and later

Page 11143

 1     they would probably stone him.  The reaction would have been very

 2     serious.

 3        Q.   I'll ask you one more thing regarding the Prosecution's last

 4     question.  (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 11144

 1   (redacted)

 2   (redacted)

 3        Q.   This is all, Mr. Vukcevic.  I have nothing further.

 4        A.   Thank you.

 5                           [Trial Chamber and Registrar confer]

 6             JUDGE DELVOIE:  Mr. Demirdjian, the document on the screen, was

 7     that the one we discussed in private session during your cross?

 8             MR. DEMIRDJIAN:  Your Honours, no.  This is a transcript of a

 9     video we showed earlier during my cross-examination and does not need to

10     be in private session.

11             JUDGE DELVOIE:  Okay.  Just one moment.

12                           [Trial Chamber and Registrar confer]

13             JUDGE DELVOIE:  It's not about the document on the screen.  It's

14     about the document that we just -- Mr. Zivanovic just discussed with the

15     witness, and there is perhaps a problem with confidentiality.

16             MR. DEMIRDJIAN:  Your Honours --

17             JUDGE DELVOIE:  6588.

18             MR. DEMIRDJIAN:  Yes, that's quite right.  For the sake of --

19     well, just to be on the safe side, perhaps it's better to redact the

20     portion which begins at page 94, line 5, and this is the question and

21     answer relating to 65 ter 6588, all the way to page 94, line 25.  It

22     doesn't reveal the originator or anything, but if you want to be on the

23     safe side, it doesn't hurt to redact it.

24             JUDGE DELVOIE:  So out of an abundance of caution, Mr. Zivanovic,

25     do you agree that we redact that --

Page 11145

 1             MR. ZIVANOVIC:  Yes, I agree, Your Honour.

 2             JUDGE DELVOIE:  Thank you.  It will be redacted.

 3             Mr. Vukcevic, this brings your testimony to an end.  We thank you

 4     for coming to The Hague to assist the Tribunal.  You are now released as

 5     a witness, and we wish you a safe journey back home.  The court usher

 6     will escort you --

 7             THE WITNESS: [Interpretation] Your Honours, I would like to thank

 8     you for your understanding and for everything that has been offered to me

 9     here, particularly the chance to tell the truth.

10             JUDGE DELVOIE:  Thank you.

11                           [The witness withdrew]

12                           [Trial Chamber confers]

13                           [Trial Chamber and Registrar confer]

14             JUDGE DELVOIE:  We thank the interpreters and the supporting

15     staff for making this extra hearing possible.

16             Court adjourned.

17                           --- Whereupon the hearing adjourned at 3.56 p.m.,

18                           to be reconvened on Tuesday, the 9th day of

19                           September, 2014, at 9.00 a.m.