Tribunal Criminal Tribunal for the Former Yugoslavia

Page 11744

 1                           Tuesday, 23 September 2014

 2                           [Open session]

 3                           [The accused entered court]

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

 5             JUDGE DELVOIE:  First of all, I want to apologise for the late

 6     start, entirely my fault.  And I've just been told now that you have been

 7     told five minutes' late start and I asked for a 15-minute late start

 8     because I knew I couldn't make it, so that makes two apologies.

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

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

11     IT-04-75-T, the Prosecutor versus Goran Hadzic.

12             JUDGE DELVOIE:  Thank you.

13             Could we have the appearances, please, starting with the

14     Prosecution.

15             MS. BIERSAY:  Good morning, Your Honours.  Lisa Biersay, on

16     behalf of the Prosecution, with Case Manager, Thomas Laugel.

17             JUDGE DELVOIE:  Thank you.

18             Mr. Zivanovic, for the Defence.

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

20     Goran Hadzic, Zoran Zivanovic and Christopher Gosnell.

21             JUDGE DELVOIE:  Thank you.

22             Your next witness is ready, Mr. Zivanovic?

23             MR. ZIVANOVIC:  Yes, he is ready, Your Honours.

24             JUDGE DELVOIE:  Thank you.

25             The witness may be brought in.

Page 11745

 1             Yes, Mr. Zivanovic.

 2             MR. ZIVANOVIC:  Sorry, before the witness come in, I would

 3     just -- I would just inform the Chamber that we obtained the revised

 4     translation of the statement of DGH-199, and we would replace it with

 5     previous one.  It is in e-court 1D113896 through 3890.

 6             JUDGE DELVOIE:  Okay.  And was -- was that statement admitted?

 7     Is there an exhibit number?

 8             MR. ZIVANOVIC:  Yes -- yes, Your Honours.  The exhibit number, I

 9     can't say it right now.  I'll tell you it after the break.

10             JUDGE DELVOIE:  No problem.

11             MR. ZIVANOVIC:  Thank you.

12             JUDGE DELVOIE:  So then it will be replaced.  Thank you.

13                           [The witness entered court]

14             JUDGE DELVOIE:  Good morning, Mr. Witness.  Can you hear me in a

15     language you understand?

16             THE WITNESS: [Interpretation] Yes, I can.

17             JUDGE DELVOIE:  First of all, thank you for coming to The Hague

18     to assist the Tribunal.  Secondly, I want to apologise for the late

19     start.

20             And now, then, could you tell us your name and date of birth,

21     please.

22            THE WITNESS: [Interpretation] Sergija Veselinovic.  2nd of August,

23     1962.

24             JUDGE DELVOIE:  Thank you.  You are about to make the solemn

25     declaration, by which witnesses commit themselves to tell the truth.  I


Page 11746

 1     have to point out to you that by doing so, you expose yourself to the

 2     penalty of perjury should you give false or untruthful information to the

 3     Tribunal.

 4             Could you now read the solemn declaration the Court Usher will

 5     give to you.

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

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

 8                           WITNESS:  SERGIJA VESELINOVIC

 9                           [Witness answered through interpreter]

10             JUDGE DELVOIE:  Thank you very much.  You may be seated.

11             Mr. Zivanovic.

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

13                           Examination by Mr. Zivanovic:

14        Q.   [Interpretation] Good morning, Mr. Veselinovic.

15        A.   Good morning.

16        Q.   Although we know each other, I'll still introduce myself for the

17     record.  My name is Zoran Zivanovic, and I represent Goran Hadzic in

18     these proceedings.

19             Mr. Veselinovic, do you remember that you gave a statement, a

20     written statement, to the Goran Hadzic Defence team?

21        A.   Yes, I do.

22             MR. ZIVANOVIC:  Your Honour, I have the copy of this statement

23     for the witness and for Your Honours, if you wish.

24             JUDGE DELVOIE:  Thank you.

25             MR. ZIVANOVIC:  May we have, please, 1D3616 on the screen.  It is

Page 11747

 1     tab 4.

 2        Q.   [Interpretation] Do you have that statement in front of you?  You

 3     have it on the screen and you also have it in hard copy.

 4        A.   Yes.

 5        Q.   Could you please go through the statement and see whether you can

 6     recognise your signature on each of the pages.

 7        A.   Yes.

 8        Q.   Here in The Hague, while being prepared for this testimony, you

 9     made certain corrections and you added certain things to your statement.

10     Therefore, I'm going to ask you to be so kind to look at the statement

11     together with the rest of us.

12             The first correction was made in paragraph 1.

13        A.   Yes.

14        Q.   Please look at it and first tell me -- you said where you

15     graduated.  Did you want to correct that?

16        A.   I completed elementary school in Obrovac and grammar school in

17     Zadar.  And then I continued studying at the Zadar university for three

18     years, and then I completed my studies in Sarajevo.

19        Q.   Before you took your first employment, rather, before you started

20     working in Zadar, did you work somewhere else?

21        A.   I worked at the archives of Bosnia and Herzegovina.  Professor

22     Marko Sunic [phoen], who was my professor, asked me to join him in

23     translating some documents regarding a travel writer, Aleksander Diviling

24     [phoen], and we also arranged the archives.

25        Q.   Also in the first paragraph, you wanted to tell us something

Page 11748

 1     about the time when multi-party elections were held in Croatia.

 2        A.   That was in April 1990.

 3        Q.   In paragraph 6, you spoke about the association of

 4     municipalities.  You wanted to expand, and you wanted to tell us the

 5     regions from which those municipalities came.

 6        A.   Those were municipalities from Lika and Northern Dalmatia are

 7     mostly those municipalities in which the Serbian Democratic Party won the

 8     elections.  Perhaps I could also add to that, that the association of

 9     municipalities of Zadar and Northern Dalmatia and Lika was set up because

10     we were constantly obstructed by Zagreb and Split in trying to implement

11     certain projects.  The only way for us to protect ourselves was to set up

12     our own association of municipalities.

13        Q.   In paragraph 8, you mentioned an incident when Stevan Veselinovic

14     and Dmitar Ceprnja were attacked.  Where did that incident happen?

15        A.   That incident happened in the village of Pridreglija between

16     Obrovac and Zadar, perhaps halfway between those two municipalities.  The

17     village was an ethnically pure Croatian village.

18        Q.   In paragraph 12, you referred to the issuing of licences for

19     hunting weapons.  What hunting weapons did you have in mind when you said

20     that licences were issued for them?

21        A.   Mostly for the conventional hunting carbine for big game.

22        Q.   In paragraph 15, you stated the time up to which you served as

23     president of Obrovac municipality.  I believe that you wanted to make a

24     correction there as well.

25        A.   Yes.  It was not up to September but, rather, until May.  I don't

Page 11749

 1     remember the exact date.

 2        Q.   But that was in 1993; right?

 3        A.   Yes.

 4        Q.   And now can you please look at the following paragraph,

 5     paragraph 16.  Again, there is a reference to September 1993.  Do you

 6     think that you should make certain corrections in here as well?

 7        A.   Yes.  Again, the month would be May, not September.

 8        Q.   In paragraph 18, you spoke about conflicts between Martic and

 9     Babic, and Babic's attempts to remove Martic from position.  What period

10     did you have in mind, and can you give us some more details of those

11     happenings?

12        A.   At that time, Babic was the prime minister of the RSK.  At the

13     same time, Martic was the minister of the interior.  A conflict arose

14     between the two of them.  I believe that they didn't agree on the overall

15     concept.  They were at odds.  And Babic removed Martic at a government

16     session.  However, after that, no single public security station accepted

17     that.  All chiefs, commanders, and police officers gave their full

18     support to Martic who was an authority for the police.  Babic appointed

19     Dusan Vjestica to replace Martic.  However, that decision was never

20     implemented.  It never took off the ground.  In the field, Martic

21     continued being the minister of the interior, even after that.

22        Q.   I will kindly ask you to slow down so that your words may be

23     correctly recorded.

24             You mentioned the name of a man who was supposed to replace

25     Martic.  Could you please repeat it?

Page 11750

 1        A.   His name was Dusan Vjestica.  Before he was appointed to that

 2     position by Babic, Dusan Vjestica was the president of the Executive

 3     Council of Gracac municipality.

 4        Q.   Let's just be very clear on the period.  When was Babic prime

 5     minister or, rather, up to when was he prime minister?

 6        A.   Babic was prime minister until the moment the government was set

 7     up headed by Zdravko Zecevic, so we're talking April 1992.

 8        Q.   Are you sure about April 1992?  Perhaps you -- no, I won't -- I

 9     won't ask you anything there.

10             In paragraph 22, you said that Croats were a majority in Zaton

11     and Medvidja; those were local communes.  I believe that you wanted to

12     correct something there as well.

13        A.   In some parts or in some hamlets, they were a majority.  They

14     lived in groups in Modrici, Marici, Nekici [phoen], but they were not a

15     majority in the entire local commune.

16        Q.   And, finally, in paragraph 24, you wanted to give us an account

17     of your movements around the time when you left the Republic of Serbian

18     Krajina, i.e., when you arrived Belgrade, and when you decided to stay in

19     Serbia for good.  Could you please expand on that.

20        A.   Well, you see, every time there was an attack on the Republic of

21     Serbian Krajina, and there were many such incidents, every time when we

22     felt threatened, I would send my wife and my older son to Belgrade.  That

23     started in 1991 and lasted until 1993.  I did that on several occasions.

24     They left on several occasions.  Our younger son was born in 1992, and

25     that's when we would spend more time in Belgrade, a fortnight or even a

Page 11751

 1     month, because that younger child had some medical problems.  We had to

 2     undergo physical therapy with him and rehabilitation.

 3             And as for our final decision to move to Belgrade for good and

 4     remain living there, we made that decision in October [Realtime

 5     transcript read in error "April"] 1993.

 6        Q.   Sir, in the record, it says that you made that decision in

 7     "April 1993," the decision on your final departure to Belgrade.  Not in

 8     your statement, but in the record.  I believe that you mentioned a

 9     different month.  Did you not?  When did you finally decide to move to

10     Belgrade?  I believe that you're looking at the statement.

11        A.   Paragraph 24?

12        Q.   Yes, paragraph 24.  But I believe that you --

13        A.   It was April.  It was April.

14        Q.   April 1993?

15        A.   Yes.

16        Q.   Very well then.  I thought that you misspoke.

17        A.   It says September here, September 1993.  That's when I left the

18     Republic of Serbian Krajina and -- and I went to Belgrade with my wife

19     and my older son.  That's what I'm reading in the statement.

20        Q.   We are having some little problems with the transcript now.  Do

21     you see that?  We're no longer looking at the statement but at what is

22     recorded in the transcript.  It's on the screen, though you may not be

23     able to understand it because it's in the English language?

24        A.   No, I don't speak English.

25        Q.   I was just about to tell you what it was about so that we clarify

Page 11752

 1     it.  What is recorded here is that you said that you made the final

 2     decision to move to Belgrade in April 1993.  A little while ago, you said

 3     that it reads there that you made the decision in September 1993.  So for

 4     the sake of clarity, if you could tell us, if you remember, if you don't,

 5     you don't have to tell us exactly, but if you do remember, please tell us

 6     when did you make this decision to definitely move to Serbia and

 7     Belgrade.

 8        A.   Well, we began discussing that option in April, but I don't

 9     remember the exact date when we definitely moved.  Probably between

10     April and September, we went to Belgrade at least three or four times and

11     spent there 10 to 15 days each time.

12        Q.   Mr. Veselinovic, I will ask you if what is recorded in your

13     statement with all the corrections that we have now entered and which are

14     now on the record, whether all of that is truthful to the best of your

15     recollection?

16        A.   As far as I remember, that's it.

17        Q.   If I were to ask you the same questions today as the ones on the

18     basis of which you have given this statement, would you give essentially

19     the same answers as recorded in the statement and as now corrected in the

20     transcript?

21        A.   Yes, as corrected in the transcript right now.

22             MR. ZIVANOVIC:  Your Honours, I would ask to admit -- I would

23     admit -- I would tender this document into evidence.  Sorry.

24             JUDGE DELVOIE:  Admitted and marked.

25             THE REGISTRAR:  Exhibit D209, Your Honours.

Page 11753

 1             JUDGE DELVOIE:  Thank you.

 2             MR. ZIVANOVIC: [Interpretation]

 3        Q.   Mr. Veselinovic, inter alia, in your statement, in paragraph 3,

 4     you talked about the secret arming of the Croats which took place before

 5     the outbreak of all the armed conflicts.  This was done by the HDZ and

 6     the Croatian MUP.

 7             I wanted to ask you this:  Where were you living at the time when

 8     all that was taking place?

 9        A.   I lived in Zadar, in the Zadar municipality.

10        Q.   Were there many Serbs living in the Zadar municipality at the

11     time?

12        A.   Yes.

13        Q.   Could you tell us what sort of impact did this have on the Serbs

14     who were living there once they learned that the secret arming of the

15     Croats was taking place?

16        A.   It was disastrous, especially the impact on the Serbs who lived

17     in the urban centres --

18             THE INTERPRETER:  Could the witness please repeat the list of

19     towns.

20             THE WITNESS: [Interpretation] It was also because they believe

21     that the past would be repeated.

22             JUDGE DELVOIE:  Mr. Zivanovic, the interpreters asked for the

23     witness to repeat the list of towns.

24             MR. ZIVANOVIC:  Yes, Your Honours.  I repeat my question.

25        Q.   [Interpretation] Mr. Veselinovic, can you please list again, but

Page 11754

 1     slowly, the towns you mentioned a while ago.

 2        A.   These were the Croatian urban centres where the Serbs were not

 3     the majority population but were, rather, in the minority but they worked

 4     there.  Those were Sibenik, Zadar, Rijeka, Pula, Zagreb, Osijek,

 5     Vinkovci.

 6        Q.   In paragraph 10, you also talked about an incident in which a

 7     Croatian policeman was killed, Franko Lisica.  You said that his

 8     colleagues organised the crystal night or "Kristallnacht" in Zagreb.  Can

 9     you tell us what did you imply by this?  What did actually happen?

10        A.   In a conflict between the National Guard Corps and the Krajina

11     police, a member of the national Guard Corps or maybe the Croatian MUP

12     was killed.  His name was Franko Lisica.  After that, the Croats

13     organised the classical "Kristallnacht" in which they smashed all the

14     Serbian restaurants, cafe and patisseries, companies from Serbia, shoe

15     repair shops.  Companies in question were Rad, Beko [phoen], Kluz

16     [phoen], Novi Dom, the branch office of the Yugoslav air transport.

17        Q.   I will interrupt you because you are speaking way too fast.

18        A.   I apologise.

19        Q.   I will not insist that you keep listing because this is

20     sufficient.

21             You also said that at the multi-party elections in Croatia in

22     1990 you were elected as president of the Obrovac municipality.

23        A.   That's right.

24        Q.   Could you tell us whether, in the territory of the Obrovac

25     municipality, there were any Croats who lived there?

Page 11755

 1        A.   Yes.  They made up around 25 per cent of the population, of the

 2     total population of this municipality.

 3        Q.   After you assumed your position, did they perhaps move out in the

 4     year when you came into power in 1991 --

 5             MS. BIERSAY:  Objection.

 6             JUDGE DELVOIE:  Yes, Ms. Biersay.

 7             MS. BIERSAY:  I object as to the leading nature of the question.

 8             JUDGE DELVOIE:  Mr. Zivanovic.

 9             MR. ZIVANOVIC:  I'll rephrase my question, but I don't believe

10     that it is leading.

11        Q.   [Interpretation] What happened with the Croats after you assumed

12     your position as the president of the municipality in 1990?  I mean the

13     Croats in Obrovac.

14        A.   All the Croats who had worked in the municipal administration

15     organs remained in their positions.  None of the Croats who were employed

16     in the territory of the Obrovac municipality was declared to be a

17     technological surplus or was relieved of his duty or dismissed or

18     demoted.  The Croats remained in their positions, and the situation

19     remained unchanged.  It was as we found it when we assumed power.

20             If I may also say, even though it wasn't like that in the

21     municipalities where the HDZ won power.  I know from personal experience

22     that because my wife was employed in a municipal administration organ in

23     Zadar, in the committee for agricultural.  She had completed law studies

24     and she was dismissed.  My best man, Nikola Kosovic, who worked at the

25     Secretariat of People's Defence in the Zadar municipality was also

Page 11756

 1     declared to be technological surplus and he was dismissed.  I know many

 2     Serbs who have experienced the same thing.

 3        Q.   From the day when you came to the position of the president of

 4     Obrovac municipality, were there any movements of the Serbian population,

 5     whether out of the Obrovac municipality or into it?

 6        A.   The Serbs mostly arrived to the Obrovac municipality.  The

 7     greatest number came from Rijeka and Zadar and a few were from the

 8     Sibenik municipality, because they were dismissed there.  Their

 9     apartments had been taken away.  The houses were torn down in a

10     systematic manner, and so they would come to the territory of the Obrovac

11     municipality.

12        Q.   Could you tell us where these people were accommodated in the

13     territory of the Obrovac municipality once they would arrive there?

14        A.   As the Obrovac municipality has 32 kilometres of the sea coast,

15     it had many settlements and weekend cottages that were totally empty.  It

16     was out of season.  These places would be full during the summer season.

17     The owners would occupy them then.

18             As we had so many people who had arrived to our territory, we had

19     to provide for them.  Our secretary of municipal administration,

20     Jovo Vukcevic, made a plan, and he issued decisions.  Of course, those

21     were temporary decisions allowing them to use these facilities.  All

22     people who had moved into these houses had signed that they would return

23     them in the same condition in which they were found with all the

24     inventory.  The inventory in the houses and weekends cottages was listed

25     for each person who was issued such a decision and moved into this type

Page 11757

 1     of house.

 2        Q.   In your statement, you said that every municipality had a

 3     Territorial Defence brigade.  That's in paragraph 14.  You also said that

 4     they were under the command of the Yugoslav People's Army.

 5             I'm interested in this:  Did you, as the representative of the

 6     Obrovac municipality, have any jurisdiction over this Territorial

 7     Defence?  Could you issue them any orders or anything of the kind?

 8        A.   The armed forces of Yugoslavia were comprised of the Yugoslav

 9     People's Army and the Territorial Defence.  The Territorial Defence was

10     part of the federal organs.  The municipality did not have any

11     jurisdiction vis-a-vis the Territorial Defence.

12        Q.   And as for the police, could you issue any orders to the police

13     stations or specifically to the police station in Obrovac?

14        A.   No, no.  That was also centralised at the republican level.  They

15     were responsible for their work to the Ministry of Interior in Zagreb.

16        Q.   We are now talking about the period while the entire Yugoslavia

17     still existed.

18        A.   Yes.

19        Q.   I'm now asking you about the period when there were already the

20     separations.  Did you have any such responsibilities in that period or,

21     in other words, could you command either the Territorial Defence or the

22     police?

23        A.   Neither.  When there was an item on the agenda of the municipal

24     assembly, that is to say, the security situation, I could invite a

25     representative or chief of the police so that they would inform the

Page 11758

 1     municipal assembly about what was happening on the ground.  But

 2     personally I had no jurisdiction whatsoever over the police forces.

 3        Q.   Among Territorial Defence members - and I'm now talking about the

 4     period after the outbreak of the conflicts - among Territorial Defence

 5     members in Obrovac, were there any Croats?

 6        A.   Both in the police and in the Territorial Defence there was a

 7     proportionate number that corresponded to the ethnic composition of the

 8     population in the municipality.  In other words, the answer is:  Yes,

 9     there were ethnic Croats, both in the police and in the Territorial

10     Defence throughout the war.

11        Q.   Can you remember when exactly did you join the government of

12     Republika Srpska Krajina?  When were you elected as a member of the

13     government of the RSK?

14        A.   I think it was in April 1992, as far as I remember.

15             MR. ZIVANOVIC:  May we see, please, 1D3763.  It is tab 50.

16        Q.   [Interpretation] On the screen in front of you, on the left, you

17     will see the list of salary payments, and we can see the people who held

18     various positions listed there.  That's the first column.  The second

19     column is a description of their positions.  And the last column shows

20     the date of their entry on duty.

21             Under number 20, you will see your own name.  It says that your

22     position was that of a minister and the entry on duty is recorded as the

23     18th of May, 1992.

24             Does that correspond and does that refresh your memory about the

25     time --

Page 11759

 1        A.   Yes, it corresponds.  It is possible that was when I received my

 2     first salary.  Probably since the time I joined the government and the

 3     appointment at the session of the Assembly of the Republic of Serbian

 4     Krajina which had to approve of the appointment, it's possible that this

 5     date is correct.

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

 7     evidence.

 8             JUDGE DELVOIE:  Ms. Biersay.

 9             MS. BIERSAY:  I have no objection to that.  But just to put on

10     the record I believe that this is not on the Defence's 65 ter exhibit

11     list.

12             MR. ZIVANOVIC:  It is -- it is on Defence exhibit list -- oh.

13     Yeah, yeah, yeah.  You think about Rule 65 ter list?

14             MS. BIERSAY:  Correct.

15             MR. ZIVANOVIC:  It -- it might be -- it might be that it is not

16     on -- on our list --

17             JUDGE DELVOIE:  It should be -- it should be, Mr. Zivanovic.

18             MR. ZIVANOVIC:  Yes, it should be.  However, I'd like to just

19     to -- to add same document under the same number -- under -- the same

20     document was admitted into evidence by the Prosecution.  I cannot find

21     right now -- right now the number.

22             JUDGE DELVOIE:  Could -- could the Registrar assist.

23                           [Trial Chamber and Registrar confer]

24                           [Trial Chamber confers]

25             JUDGE DELVOIE:  Mr. Zivanovic, if ...

Page 11760

 1                           [Trial Chamber and Registrar confer]

 2             JUDGE DELVOIE:  If you are sure, Mr. Zivanovic, that it is

 3     admitted as a Prosecution document.

 4             MR. ZIVANOVIC:  Yes, as P57.

 5             JUDGE DELVOIE:  P57.

 6             MR. ZIVANOVIC:  Yes.

 7             JUDGE DELVOIE:  Then we don't have to admit it again.

 8             MR. ZIVANOVIC:  No, no, I withdraw my request to --

 9             JUDGE DELVOIE:  Thank you.  --

10             MR. ZIVANOVIC:  -- admit this document.

11        Q.   [Interpretation] Mr. Veselinovic, do you remember -- or, rather,

12     let me ask you this:  Were you ever a member of a government commission?

13     Or, to be more precise, I'm going to ask you very specifically were you a

14     member of a commission which was supposed to establish the situation in

15     Gracac municipality?

16        A.   As far as I remember, there was a commission.  It had five

17     members.  I was one of them.

18             MR. ZIVANOVIC:  May we see, please, P1862.  It is tab 8.  May we

19     see B/C/S page 9 and English page 12, please.

20        Q.   [Interpretation] What happened in Gracac municipality to

21     necessitate the establishment of a commission that was supposed to

22     establish what the situation was?

23        A.   A unit --

24             MS. BIERSAY:  Excuse me, Your Honours.

25             JUDGE DELVOIE:  Sorry, yes, Ms. Biersay.

Page 11761

 1             MS. BIERSAY:  I remain open to be guided by my colleague,

 2     Mr. Zivanovic, but I -- I don't see anything indicating that the witness

 3     would be speaking about this issue regarding Gracac.

 4             MR. ZIVANOVIC:  Generally, the witness was called to speak about

 5     the work of the government of RSK whose member he was.  And it is a part

 6     of -- of the work of the -- in the government of RSK, and the Prosecution

 7     knows of the minutes from RSK government, and they're -- they're familiar

 8     with this matter.

 9             JUDGE DELVOIE:  Yes, Ms. Biersay.

10             MS. BIERSAY:  I think the fair question is whether or not the

11     Prosecution was given notice that the witness would be discussing what I

12     think he's been asked to do about situations on the ground in Gracac, and

13     there's nothing in either the proofing note or his witness summary or,

14     frankly, even in his statement that would indicate that this topic would

15     be covered.

16             MR. ZIVANOVIC:  My question was what the witness has to do as a

17     member of the government, as a member of the government related to the

18     establishment of the -- establishment of the situation in the

19     municipality of Gracac.  It is a part of his -- his role in the

20     government.

21             JUDGE DELVOIE:  Your question was, Mr. Zivanovic, what happened

22     in Gracac municipality to necessitate the establishment of a commission.

23             Isn't that a plain question about what happened on the ground

24     in -- in -- in that municipality?

25             MR. ZIVANOVIC:  I -- precise -- I'll clarify my question.

Page 11762

 1             JUDGE DELVOIE:  Please do.

 2             MR. ZIVANOVIC:  Okay.

 3        Q.   [Interpretation] Mr. Veselinovic, why was this commission set up?

 4     What was it supposed to do?

 5        A.   The commission was set up because of an incident that happened in

 6     Gracac municipality.  Members of our armed forces were on Mount Velebit

 7     very close to Sentros [phoen] and that was a point which was held by our

 8     armed forces.  They were there during a truce and our unit was moving

 9     very peacefully in order to replace their colleagues on their positions,

10     and the Croatian forces massacred 22 fighters of the Republic of Serbian

11     Krajina.  I remember that among them there were four men who bore the

12     same family name as me, Veselinovic.

13        Q.   Just one more question:  Was a truce in place or what?

14        A.   Yes, it was a cease-fire.

15        Q.   Do you remember that the government ever received information and

16     considered issues relative to the cutting off of the corridor leading to

17     Serbia?

18        A.   The government did look at that issue, the issue of the corridor

19     in the territory of the Republic of Serbian Krajina and Republika Srpska.

20     Actually, we're talking about three municipalities in the Sava valley.

21     They were Modrica, Derventa, and Obuduvci, if I'm not mistaken.  That

22     route was a blood line for Republika Srpska and Republic of Serbian

23     Krajina.  That corridor was used to transport medicines and all the other

24     necessities.  People travelled to Belgrade on that road.  It was the

25     throbbing way and the main artery, to use the lingo of medicine.

Page 11763

 1             MR. ZIVANOVIC:  May we see the document from the Rule 65 ter

 2     list, Prosecution list, it is 1148; tab 32.

 3             [Interpretation] Let's look at page 2 in the original and in the

 4     English translation as well.  I apologise.  It will be page 3 in the

 5     English translation.  I believe that it even spills over to page 4.

 6     Actually, it is page 4 in the English translation.

 7        Q.   Could you just briefly look at bullet point 1.  There's a report

 8     there on the cutting off of the corridor and the necessity to

 9     re-establish that corridor as soon as possible.  Do you remember what

10     Milan Martic said?

11        A.   Yes, I do.

12        Q.   What was the position of the government regarding that problem?

13        A.   The government voiced a position and concluded that the opening

14     up of the corridor is absolutely necessary and, in that sense, it

15     authorised the minister of interior of Republic of Serbian Krajina, Milan

16     Martic, and his assistant - I believe at that time it was Colonel Boro

17     Djukic - to assign units which would participate in the operation to

18     re-establish the corridor and ties with the Republic of Serbia.

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

20             JUDGE DELVOIE:  Admitted and marked.

21             THE REGISTRAR:  Exhibit D210, Your Honours.

22             JUDGE DELVOIE:  Thank you.

23   (redacted)

24   (redacted)

25   (redacted)

Page 11764

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

19   (redacted)

20             JUDGE DELVOIE:  Thank you.

21             MR. ZIVANOVIC: [Interpretation]

22        Q.   Mr. Veselinovic, do you remember anything about the relationship

23     between the authorities of the Republic of Serbian Krajina, on the one

24     hand, and the Yugoslav authorities, on the other hand, after the Vance

25     Plan was signed in 1991?  Were there any mutual obligations between the

Page 11765

 1     two?

 2        A.   On several occasions, in contacts with representatives of the

 3     government of the Republic of Serbia and federal institutions, i.e., the

 4     authorities of Yugoslavia, we received very firm guarantees that the

 5     Republic of Serbian Krajina would never be abandoned at a session at

 6     which the Vance Plan was adopted.

 7             JUDGE DELVOIE:  Mr. Zivanovic, sorry for the interruption, but

 8     the previous document is said to be under seal in e-court.  There is

 9     mention that it should be under seal; is that right?

10             MR. ZIVANOVIC:  Yes.  Yes, that's correct.  That's correct.

11             JUDGE DELVOIE:  Okay.

12             MR. ZIVANOVIC:  Sorry for my mistake.

13             JUDGE DELVOIE:  We'll admit it under seal.

14             MR. ZIVANOVIC: [Interpretation]

15        Q.   Please continue.

16        A.   Yes, gladly.  On several occasions, the representatives of the

17     Federal Republic of Yugoslavia persuaded us that we would not be left to

18     our own devices and we would not be left at the mercy of Croatian armed

19     forces.  At a session of the Assembly of the Republic of Serbian Krajina

20     in Topusko, I remember there were five generals of the JNA, they,

21     together with Professor Gavro Perazic, who was an international law

22     expert, tried to convince us that in case of an aggression of -- by the

23     Republic of Croatia against the Republic of Serbian Krajina that they

24     would have an instrument, i.e., an iron fist, that be would able to

25     respond within an hour and establish a separation line between the

Page 11766

 1     Republic of Serbian Krajina and the Republic of Croatia.

 2        Q.   Do you remember, Mr. Veselinovic, immediately after this event,

 3     when the cutting off of the corridor, did any armed action of the

 4     Croatian forces against the Republic of Serbian Krajina take place?

 5        A.   There were several instances of aggression.  The first one

 6     occurred at the Miljevci plateau.

 7        Q.   I would stop there and then later on we would move on to the

 8     others.

 9             Could you tell us if the government discussed and examined the

10     situation which arose due to the aggression on the Miljevci plateau?

11        A.   It did examine this.

12        Q.   Do you remember what the government did?  What sort of position

13     did it take, if you remember?

14        A.   Well, we mostly had objections to the work of the defence

15     ministry.  It seemed to us that everything was too slow and too

16     complicated.  They justified themselves by saying that our weapons were

17     under the control of international forces, whereas the Croatian forces

18     were completely free and could plan their actions.  In such a skirmish as

19     this, it was a significant advantage when you plan an action and you plan

20     to surprise the enemy side.

21             MR. ZIVANOVIC:  May we see, please, Exhibit 1175 from the

22     Prosecution list.  It is tab 11.

23             Do we have translation?  I think there's translation of this

24     document.  No translation?

25        Q.   [Interpretation] Never mind.  I won't ask you anything about this

Page 11767

 1     document because it seems there is no translation.

 2             Would you tell us what was the position taken at the time by the

 3     Yugoslav authorities, in view of the guarantees that you have told us

 4     about?

 5        A.   They did not fulfil our requests, nor did they comply with the

 6     guarantees that had been provided.

 7        Q.   And do you remember the position of the UNPROFOR at the time when

 8     that attack was launched?  Was the UNPROFOR already deployed in the RSK?

 9        A.   Yes, the UNPROFOR was there, present in the RSK.  But after an

10     operation, they would mostly just note the actual situation on the

11     ground, and they no longer did anything about it.

12        Q.   Could you please tell us, if you remember, whether during your

13     tenure in the government when you attended the sessions whether

14     Goran Hadzic attended any of these sessions?

15        A.   As far as I remember, this period of around a year and a half

16     during which I was a member of the government, the RSK president,

17     Goran Hadzic, came twice, just before the London Conference and once

18     immediately after it, when he was the rapporteur.  He reported to us

19     about the negotiations that the Yugoslav delegation took part in, in

20     London.

21             MR. ZIVANOVIC:  May we see, please, 1D2581.

22             JUDGE DELVOIE:  Ms. Biersay.

23             MS. BIERSAY:  I'd be greatly assisted by having a tab number, if

24     possible.

25             I think I found it.  Is it tab 2?

Page 11768

 1             MR. ZIVANOVIC:  Two, yes.

 2             May we see, please, page 2, both in B/C/S and English.

 3             [Interpretation] It seems to be on the following page, after all.

 4     No, no, no.  [In English] That's okay, sorry.

 5        Q.   [Interpretation] If could you please look at item 1.

 6             It says here that the prime minister gave an introductory

 7     presentation and believed that that should be the platform for the work

 8     of the government.  The concept is put forward to be used at the London

 9     Conference.  Is that the session that you told us --

10        A.   Yes, yes.

11        Q.   I see that the government adopted the conclusion to form a

12     working group that would comprise the president of the republic, the

13     prime minister, and some other ministers.  Do you remember that?

14        A.   Yes, I remember that there were Dusan Ecimovic, David Rastovic,

15     Nebojsa Mandinic, and Mile Dakic, master of arts.

16        Q.   Do you also remember whether after the London Conference

17     Goran Hadzic reported to the government on the developments that took

18     place at the conference?

19        A.   At the government session, which took place after London, Hadzic

20     attended it and submitted a report.  He talked in positive terms and said

21     that this was the first time that at an international conference the name

22     of the Republic of Serbian Krajina was heard and appeared.  So he talked

23     about the London Conference in very positive terms.  He represented it as

24     our chance.

25        Q.   I will ask you something about the work of the Assembly of the

Page 11769

 1     Republic of Serbian Krajina.  You did say something about that in

 2     paragraph 17 of your statement.  Inter alia, you mentioned that deputies

 3     of the Party for Democratic Changes were also members of the assembly.

 4             Can you tell us where was the seat of the Party of Democratic

 5     Changes?

 6        A.   Its seat was in Zagreb.  There was another --

 7        Q.   Just a little -- I'm sorry.

 8             Can you please tell us who was the president of that party?

 9        A.   Ivica Racan.

10        Q.   You also mentioned that the Social Democratic Party --

11        A.   Party, yes.

12        Q.   The Social Democratic Party led by Zeljko Madjar [phoen] also had

13     its deputies in the assembly.  Can you tell us something more about this

14     party and its leader?

15        A.   The party itself was registered at the level of the Republic of

16     Croatia.  Its headquarters were in Rijeka.  It was social democratic by

17     orientation.  Some of the Serbian voters voted for this political option.

18             MR. ZIVANOVIC:  Mr. President, I see the time.

19             JUDGE DELVOIE:  Thank you, Mr. Zivanovic.

20             Mr. Veselinovic, this is the time for our first break, 30

21     minutes.  We will be back at 11.00.

22             Court adjourned.

23                           [The witness stands down]

24                           --- Recess taken at 10.29 a.m.

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

Page 11770

 1             JUDGE DELVOIE:  Mr. Zivanovic.

 2             MR. ZIVANOVIC:  Yes --

 3             JUDGE DELVOIE:  This morning you asked for the replacement of

 4     translation of a statement, a witness statement, and, on the record, it

 5     is witness statement of DGH-119.

 6             MR. ZIVANOVIC:  199.

 7             JUDGE DELVOIE:  099, I suppose it is.  Is it Dafinic?

 8             MR. ZIVANOVIC:  Yes.  099.

 9             JUDGE DELVOIE:  099.  Okay.  Thank you.

10                           [The witness takes the stand]

11             MR. ZIVANOVIC:  And exhibit number is 199.  D199.

12             JUDGE DELVOIE:  Okay.  It's on the record now.  Thank you.

13             You may proceed, Mr. Zivanovic.

14                           [Trial Chamber and Registrar confer]

15             JUDGE DELVOIE:  So the exhibit number is D --

16             MR. ZIVANOVIC:  Exhibit number is D199.

17             JUDGE DELVOIE:  And now we lift the MFI status; right?

18             MR. ZIVANOVIC:  Yes.

19             JUDGE DELVOIE:  Now it's admitted.

20             MR. ZIVANOVIC:  Thank you.

21             JUDGE DELVOIE:  Okay.

22             Yes, Ms. Biersay.

23             MS. BIERSAY:  Thank you, Your Honour.

24             I just wanted to note that we are checking the translation and

25     just to alert the Court that in the event we find something amiss, we'll

Page 11771

 1     take the issue up with the Court again.

 2             JUDGE DELVOIE:  Perhaps.  Perhaps we are a little bit too fast

 3     indeed.

 4             MS. BIERSAY:  Okay.

 5             JUDGE DELVOIE:  It's noted.

 6             MS. BIERSAY:  Thank you.

 7             JUDGE DELVOIE:  Please proceed, Mr. Zivanovic.

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

 9        Q.   [Interpretation] Mr. Veselinovic, my next question is this:  What

10     was the influence of Goran Hadzic in Knin Krajina at the time and during

11     the time you spent there?

12        A.   In view of the fact that Mr. Goran Hadzic spent very little time

13     in our territory and that he did not have his own political party or

14     headed a political -- an influential political party there, he had very

15     little influence on the political processes which were happening in

16     Krajina at the time.  His influence was very small and limited, if any.

17        Q.   Could you please tell us who had a strong political influence in

18     the Republic of Serbian Krajina at that time?

19        A.   The two central political figures during that period of time were

20     Milan Babic and Milan Martic.  In an interview that I gave to the "Duga"

21     magazine which is published in Belgrade, I spoke with journalist Zvonko

22     Bogavac, and I told him that Mile Martic was the most important person

23     there and that the influence of Milan Babic [as interpreted] in the

24     government is really minimal.

25        Q.   Let's clarify something.  Did you say that Milan Babic's

Page 11772

 1     influence in the government was minimal?

 2        A.   No, I said Goran Hadzic.

 3        Q.   Please wait.

 4        A.   I'm sorry.

 5        Q.   Wait till I finish my question.  I'm going to read the entire

 6     sentence:

 7             [In English] "The two central political figures during that

 8     period of time were Milan Babic and Milan Martic.  In an interview that I

 9     gave to the "Duga" magazine which is published in Belgrade, I spoke with

10     journalist Zvonko ... and I told him that Mile Martic was the most

11     important person there and that the influence of Milan Babic in the

12     government is really minimal."

13             [Interpretation] Did you say that or did you say something else?

14        A.   No.  The journalist was Zvonimir Bogavac and I said during that

15     interview that Milan Martic was a real Gauleiter and that Goran Hadzic's

16     influence and the government itself headed by President Zecevic was very

17     limited.

18        Q.   Can you please explain the term "Gauleiter"?  What does that

19     mean?

20        A.   Gauleiter is a commissioner, a governor, a manager, a person of

21     the highest authority in an area.  This is a German word which dates back

22     to the times of the Third Reich.

23        Q.   During 1992 and 1993 while you were in the Republic of Serbian

24     Krajina, did the Croatian population move out of the area; to be more

25     precise, from your municipality of Obrovac?

Page 11773

 1        A.   Yes, people did move out.

 2        Q.   Why?  Why did people move out?  Why did the Croatian population

 3     move out from that area?

 4        A.   There was an incident in the village of Bruska.  Two Croats were

 5     killed there as well as a Serb, and the last person, the Serb, was a

 6     postman.  As a result, the Croats who lived in the area became seriously

 7     concerned for the first time.  During that time, in my municipality, in

 8     two local communes where Croats were rather numerous, and those were

 9     Zaton near Obrovac and the village of Medvidja, on several occasions, I

10     held meetings with representatives of the local Croats, i.e., the

11     president of the local commune, the principal of the local elementary

12     school, and the most reputable figures from the area.  I begged them not

13     to leave the territory of Krajina.  My rationale for that was that the

14     most important thing in life was to preserve one's own home.  Since we

15     were very mixed in the area, we were all related, we were all Kums,

16     therefore, I -- I thought it was only good for them to stay in the area.

17     And the second guiding motive was the fact that in Krajina, we had a

18     pluralist society, and that we also had to have a minority population

19     there.  I believed that the best solution for the states which are

20     multi-ethnic and multi-confessional was that, to have a minority.

21             The second meeting that I held was in the clay factory in

22     Obrovac, in the administrative building.  I held a meeting there with the

23     inhabitants of Zaton, a village near Obrovac.  My proposal to them was

24     the same and that was not to move out.  I believe that my idea to talk to

25     them was very much supported by an elderly man whose name was Modric and

Page 11774

 1     who had been a participant in the Second World War.  He thought that that

 2     was a good thing that we should also send a police patrol that would

 3     patrol the area 24/7 and that they should stay in their homes.

 4             Unfortunately, some 20 days later, 20 days after the meetings

 5     that I've just mentioned, the civilian -- UNPROFOR police and the

 6     commander of the French Battalion, Colonel Meille, and also

 7     Lieutenant-Colonel Vladimir Kononenko, who was UNPROFOR CIVPOL, informed

 8     me that the Croats wanted to leave the territory after all, that they

 9     wanted to leave Obrovac municipality.

10             And then, through the Red Cross and UNPROFOR bodies, the transfer

11     of a certain number of Croats was arranged, and they left our

12     municipality.  I even remember a woman who worked in the administrative

13     services of the municipality of Obrovac.  She left her job, she left her

14     house, and she moved to Zadar.

15        Q.   Now, of the people who moved out, who left, how old were they?

16     What was their age structure?  Were they older, younger?  Can you give us

17     a rough idea.

18        A.   We're talking about older people, older than 65.  But there were

19     also younger people among them as well.

20             What was the problem, in my view?  The families were divided.

21     Some of them lived in Zadar, Zagreb, or Rijeka and the rest lived in our

22     territory.  Some of them expressed the desire to join up with their

23     families, and, as for the rest, I suppose that they had economical

24     reasons for wanting to move to Croatian side, because at that time we did

25     not pay out salary.  We did not have a pension fund.  We did not have any

Page 11775

 1     funds for that matter.  Whereas, at the same time, the Croatian state

 2     provided all that to their citizens.  They were given accommodation in

 3     holiday homes.  They have been given pensions.  And all those who had

 4     worked in the administrative organs in Krajina, and I can talk

 5     specifically about Obrovac municipality, for example, that woman who left

 6     her job, when she moved to Zadar she was immediately given a job there

 7     because the Croats had established their own municipality of Obrovac

 8     which operated in the territory of the municipality of Zadar.  So there

 9     was dual administration.

10        Q.   I wanted to ask you something else.  You mentioned pensions.

11     Could you tell us whether pensions were paid to those people who, before

12     the war, before 1991, had been of pensionable age in Croatia?  I

13     apologise, I need to finish.  In other words, those who had received

14     regular pensions from the pension funds of the Republic of Croatia, after

15     the war started, did they continue receiving pensions from the Croatian

16     retirement fund who had paid their pensions up to then?

17        A.   The Croats immediately stopped the payment of all pensions and

18     any other benefits that the Serbs were entitled to.

19        Q.   Very well.  Were those payments stopped only to the Serbs or

20     everybody who resided in the territory of Serbian Krajina?

21        A.   Everybody.  Croats as well.

22        Q.   What about those pensioners?  What did they live on?  Did they

23     receive any monies at all?  Since they lost their pensions, what did they

24     live on, the aged and infirm?

25        A.   Most of them lived in rural areas.  They grew their on produce,

Page 11776

 1     and we were also able to provide them with aid from the Red Cross.  There

 2     was also a soup kitchen for anybody who could not feed themselves, could

 3     come to the soup kitchen and have at least one warm meal a day.

 4        Q.   And just one more question:  Those people who left Krajina, for

 5     example, those elderly people who were already pensioners, when they

 6     arrived Croatia, do you know if they continued receiving pensions?

 7        A.   As soon as they crossed over to the Croatian territory, they were

 8     able to exercise all their rights.  That's why I believe that was one the

 9     main reasons why they crossed over to the Croatian territory was that

10     they were in -- better off financially or economically, if you will.

11        Q.   Do you know if either in Obrovac or elsewhere during that period

12     of time while you were there in 1992 and 1993, were there any cases of

13     forcible transfer of the Croatian population which was carried out in an

14     organised manner?

15        A.   No, there were none.  All the commands, the government, the

16     Presidency ordered local structures to be very mindful and very

17     considerate towards the Croats.  It was very important for us to be

18     different from them.  The things that our fellow citizens experienced in

19     Croatia or in the territory under the control of the Croatian government,

20     we didn't want the same things to happen to ethnic Croats in the

21     territory of the Republic of Serbian Krajina.  We tried to protect them

22     as much as we possibly could.

23        Q.   You said, inter alia, that there was a crime in Bruska when two

24     Croats and a Serbian postman were killed.  According to our information,

25     that was not the only crime against Croats that happened in the Republic

Page 11777

 1     of Serbian Krajina during that time.  Do you know if such crimes were

 2     investigated?  Were perpetrators sought?

 3        A.   Absolutely.  When it comes to Bruska, as far as I know, that

 4     heinous act was motivated by financial gain.  In the territory of the

 5     local commune of Medvidja there was also a number of murders --

 6        Q.   Let me interrupt you.  We'll come to that.

 7             My question is this:  Were you in Obrovac when the Croatian

 8     forces launched the attack on Maslenica?

 9        A.   Yes, I was in Obrovac.

10        Q.   I don't have a map, but it's not important.  Can you tell us how

11     far is Obrovac from the locations along the separation line and the

12     places which came under the Croatian attack in the Republic of Serbian

13     Krajina?

14        A.   The city itself was no more than 5- or 600 metres as the crow

15     flies.  We had a factory of hydroelectric cylinders there, the Djuro

16     Djakovic factory, the Dalmatia bauxite mines, the stone quarry.  All

17     those were occupied by the Croatian forces.  All that was part of our

18     industrial zone.

19        Q.   And during those military operation do you know if Croatian

20     troops committed crimes in that area in the territory of the municipality

21     of Obrovac?

22        A.   Yes.

23        Q.   I interrupted you when you started talking about Medvidja.  Can

24     you come back to that and tell us what happened there.  What happened in

25     Medvidja?

Page 11778

 1        A.   A man, Simon Sadaro [phoen], and his wife were killed.  They were

 2     both Croats.  After that, as far as I remember, a man called Erstic was

 3     also killed, and then Branko Genda was also killed.  I can't remember any

 4     other crimes, but I assume there were other murders as well.

 5        Q.   Do you remember a Serb or Serbian people who were killed during

 6     the Maslenica operation?

 7        A.   In the local commune of Zaton, which was very close to the

 8     industrial zone that were -- that was entered by the Croatian forces,

 9     three Serbian women were killed.  I can't remember their names.

10             MR. ZIVANOVIC:  May we see, please, 1454.  It is from Prosecution

11     exhibit list, tab 22.

12             It is not this exhibit, sorry.

13             MS. BIERSAY:  I think it was perhaps the P number that you were

14     giving, not the 65 ter number, if that helps.

15             MR. ZIVANOVIC:  Yes, it is P1902.  Sorry.

16        Q.   [Interpretation] I'd like to draw attention to the bottom part of

17     the text where you will find a reference to the names and ethnic

18     affiliations of the three woman whom you have mentioned.  The site where

19     those women's bodies were found is described.

20             Is that the case that you referred to just a while ago --

21        A.   Yes.

22        Q.   -- when you testified about the crimes?

23        A.   Yes.

24        Q.   At the very bottom of the statement, it says that the statement

25     was given by a man called Vuksic.  Do you know him?

Page 11779

 1        A.   Yes, I know him personally.  He was an employee of the

 2     Secretariat of the Interior in Obrovac.  I don't know what his name was.

 3     His nickname was Neno; he was a Croat.  We followed the practice of

 4     sending Croats to the sites where an ethnic Croat had been killed because

 5     we wanted to avoid any suspicion of bias when it came to the work of our

 6     own police officers.

 7        Q.   Did the Army of the Republic of Serbian Krajina manage to repel

 8     the attack on Maslenica?

 9        A.   No, we didn't.

10        Q.   Were your troops reinforced by troops from either Yugoslavia or

11     elsewhere?

12        A.   As far as I can remember, there was a unit, a unit of the

13     Volunteer Guards, and a small unit from the territory of

14     Republika Srpska.  I'm talking about the Wolves from Vucjak commanded by

15     Veljko Milankovic, and the guards were headed by Zeljko Raznjatovic,

16     Arkan.  With the help of those forces, we managed to return some of the

17     trigger points and the points that were of importance to us.

18        Q.   In the first part of this report, if you can read it, one can see

19     that events of the day are being reported on and towards the end of the

20     first paragraph, the word is underlined.  It says that:

21             "The morale of our forces has significantly improved since Arkan

22     came to this area."

23             Would you tell me, first of all, whether it was so; and, if it

24     was, how was the morale improved by his arrival?

25        A.   It's true.  It's true that the morale was improved.  So, firstly,

Page 11780

 1     any help coming from the side in such a difficult situation was

 2     God-given.  It had a psychological impact.  The population would be

 3     calmed down because perhaps more new forces would be expected.  And,

 4     secondly, it was precisely those units that were able to counter-attack

 5     the enemy, and all of the actions carried out in the area of Tula Regrede

 6     [phoen] and Velebit.  I'm talking about some villages at the foot of

 7     Mount Velebit.  This was done by those units, Milankovic's and Arkan's

 8     units.  Of our units, that part of the front was covered by the Light

 9     Obrovac Brigade, which was not trained to infiltrate enemy territory.  We

10     didn't have anyone expert for sabotage or navy infantry or any special

11     units, and these guys were trained for that kind of a counter-attack.

12             MR. ZIVANOVIC:  May we see, please, 1D3053.  It is tab 25.

13        Q.   [Interpretation] While we are waiting for this document to appear

14     on the screen, you also mentioned Milankovic and his units which had come

15     from the Republic of Serbian Krajina.  So I will ask you to look at a

16     document which will appear on the screen just now, if you can tell us if

17     that is what you were talking about.

18             Can you see this document?

19        A.   Yes.

20        Q.   Just tell me whether this document portrays accurately what

21     happened in the fighting with regard to these units.

22        A.   Yes, it absolutely corresponds to the situation on the ground.

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

24             JUDGE DELVOIE:  Admitted and marked.

25             THE REGISTRAR:  Exhibit D212, Your Honours.

Page 11781

 1             JUDGE DELVOIE:  Thank you.

 2             MR. ZIVANOVIC: [Interpretation]

 3        Q.   Could you please tell me how these volunteer units which had

 4     arrived from other areas were received by Martic and Babic in the

 5     Krajina?

 6        A.   In a very short period, after the arrival of this unit commanded

 7     by Zeljko Raznjatovic, Arkan, a conflict arose between him and the

 8     minister of the interior of the RSK, Milan Martic.  Martic took measures.

 9     He refused to welcome them.  I don't think that there was any use of

10     force, but they withdrew from the territory of the Republic of Serbian

11     Krajina.

12        Q.   Do you remember if, during the action at Maslenica, Goran Hadzic

13     appeared in the Republic of Serbian Krajina?

14        A.   On one occasion.  He stayed for about a week.  We saw each other

15     several times then.

16        Q.   Could you tell us something else.  You have told us when you

17     ceased to be a member of the government of the RSK, approximately.  Could

18     you also perhaps tell us some of the reasons why that happened?

19        A.   After the fall of Zecevic's government, Djordje Bjegovic became

20     the RSK prime minister.  He was a man who very often changes his

21     political affiliations from Racan's SDP to the -- the League of

22     Communists Movement for Yugoslavia.  I refused to participate in such a

23     government and to co-operate with a man of such political affiliation.

24        Q.   Mr. Veselinovic, I will ask you another question; namely, if you

25     could explain something a little.  We talked about an incident which

Page 11782

 1     occurred in Krusevac in 1993, so if you could just very briefly tell us

 2     what happened in Krusevac in 1993?

 3        A.   I can say that this was the most fatal incident in my life.  It

 4     had to do with this:  On the premises of the Society of Serbian Jewish

 5     Friendship, I met Aleksandar Andjelkovic.  I was introduced to him

 6     through Enriko Josif, and Klara Mandic.  After a while, I developed

 7     closer relations with him.  Initially he was very favourably disposed to

 8     everything that was happening in the area of the Krajina.  As he was

 9     living in Belgrade and had his private company and two business premises,

10     one at the Sava Centre and the other one in Zmajinova Street close to the

11     pedestrian zone of Knez Mihajlova Street.  I had saved 7.000

12     Deutschemarks and 1700 Guilders, and I borrowed that money to

13     Mr. Andjelkovic.  He was to pay me back within a month.  However, upon

14     expiry of this period, I insisted on several occasions that he should pay

15     me back the money that I had lent to him.  I could see from his answers

16     that he was going through some sort of financial problems.  He would

17     mention various people.  Specifically I remember that he very often

18     mentioned a Hungarian, Balint Pastor, who owned a company in Vrnjacka

19     Banja and also a man in Krusevac from whom he expected to receive a large

20     amount of money.  They owed that money to him.  He suggested that I come

21     to Krusevac and see for myself that the man really owed him money which

22     he could not pay back to me at the moment.

23             So I went to Krusevac, and we met in the patio of a cafe

24     restaurant in the very centre of the town.  Sasa showed us for the first

25     time the house where this man lived, but we didn't find him.  The house

Page 11783

 1     was locked.  During our second attempt, we found the man in front of the

 2     house.  He told us to come inside and talk so we wouldn't talk in the

 3     street.  As the man hailed from Kosovo, I suppose that that was part of

 4     the local culture:  He suggested that we take our shoes off, which all

 5     the four of us did.  We expected the arrival of this Mr. Andjelkovic who

 6     was in a car with a friend of his, Basic.  However, they did not show up

 7     inside the house.

 8             One of the people who was there with us, and I hadn't known these

 9     people from before, that was the first time I saw them, took out a

10     contract from his pocket and presented it to the owner of the house.  He

11     denied the validity of the contract or having any obligations towards

12     anyone.  All the while, I was sitting on the sofa together with this

13     gentleman's wife and his mother-in-law.  I asked them to fulfil their

14     obligation and at least pay me back if they could do that anyway, even

15     though they were not directly involved in the whole affair in which I had

16     given the money.

17             I remember that this Katanic and this Nikola whose last name I

18     don't remember, went away twice with this Mr. Spasic, if I remember his

19     last name properly, because it was a two-storey house.  They would go

20     upstairs, and after no more than five minutes, police showed up, and the

21     three of us were arrested.  At the moment, I did not know what happened

22     with this Nikola and how he had disappeared.  I later heard that he had

23     left through the back garden and thus reached another street.

24             I would like to note one very important thing.  The weapons that

25     I had on me at the time, it was a pistol produced by the Crvena Zastava

Page 11784

 1     factory from Kragujevac.  I had a licence for it that was in order and I

 2     had crossed the border of the Republic of Serbia countless times with it.

 3     When asked by the border police if we had any weapons, every time we

 4     would answer in the affirmative.  Sometimes they would check our

 5     licences; sometimes they didn't.  My official driver at the time also had

 6     the licence.  Sometimes there would be another man as my escort.  He was

 7     also armed.  We never had any problems as far as the Serbian police was

 8     concerned.  As far as I remember, during the trial, I was charged with

 9     illegal possession of weapons.  I believe that the sentence was three

10     months.  As far as I remember, the entire sentence was five or six months

11     for the -- for the whole incident.  On appeal, the sentence was changed

12     and became a suspended one.

13             I want to say that for the act itself, we did not have to serve

14     any time in prison, neither I nor any of the other three men.

15        Q.   I shall not ask you anything else about this event.  It will

16     probably be a topic during the cross-examination later on.

17             That was all I had.  Those were all my questions.  Thank you for

18     the answers.

19        A.   You're welcome.

20             MR. ZIVANOVIC:  Your Honours --

21             JUDGE DELVOIE:  Thank you, Mr. Zivanovic.

22             MR. ZIVANOVIC:  I just forgot to tender the last document from

23     the screen into evidence.  It is 1D3053, tab 25.

24                           [Trial Chamber and Registrar confer]

25             JUDGE DELVOIE:  It has been admitted as D212, Mr. Zivanovic.


Page 11785

 1             MR. ZIVANOVIC:  It's admitted?

 2             JUDGE DELVOIE:  Yes.

 3             MR. ZIVANOVIC:  Thank you.

 4             JUDGE DELVOIE:  Ms. Biersay, cross-examination?

 5             MS. BIERSAY:  Yes, Your Honour.  If I may have one moment.

 6             JUDGE DELVOIE:  Take your time.

 7             MS. BIERSAY:  Thank you, Your Honour.

 8                           Cross-examination by Ms. Biersay:

 9        Q.   Well, I see we're on the cusp of afternoon.  Good afternoon,

10     Witness.  My name is Lisa Biersay.  I will be asking you questions on

11     behalf of the Prosecution today.  I have been granted I believe four

12     hours.  And we'll see if we need that time.  It depends on how efficient

13     we are.

14             Now, before I begin, I wondered if I was correct in noticing you

15     silently greet Mr. Hadzic before you took the oath and he smiled back at

16     you in acknowledgment.  Do you recall that?  Did you make a silent

17     acknowledgment to Mr. Hadzic when you came into the courtroom and before

18     you took the oath?

19        A.   When I saw him, I just nodded.

20        Q.   And he --

21        A.   I may have smiled as well.

22        Q.   And he smiled at you; right?

23        A.   Yes.

24        Q.   And before the last -- the first break of the morning, you again

25     acknowledged him and he again smiled at you; right?

Page 11786

 1        A.   Probably.

 2        Q.   So it's fair to say that you and Mr. Hadzic are old friends.

 3        A.   You could put it that way.

 4        Q.   I do put it that way.  I want to know if you agree with that.

 5             MR. ZIVANOVIC:  The witness asked and answered.

 6             MS. BIERSAY:

 7        Q.   Well, Mr. Veselinovic, you say that you first met Mr. Hadzic in

 8     1990; is that correct?

 9             MR. ZIVANOVIC:  Sorry, may we have reference where the witness

10     said that he first met Hadzic in 1990?

11             MS. BIERSAY:  Well, let me ask the question.

12        Q.   When did you first meet Mr. Hadzic?

13        A.   I first met Mr. Hadzic in my office in the Obrovac municipality.

14     He came there together with a professor of the faculty of law in Osijek,

15     Vojislav Vukcevic.  That was the first time we met.

16        Q.   Do you remember what year that was?

17        A.   1990.  1990.

18        Q.   So just to recap, could you tell us exactly where you were living

19     in 1991 for that year.  Where -- where were you?

20        A.   I lived in the Zadar municipality.  That is where my father had

21     his family house and that was where I was living.  My wive lived there

22     too, and so did my older son.  I believed that I did say so at one point

23     that my wife used to work in the administration organisation in the Zadar

24     municipality in the committee --

25        Q.   [Previous translation continues]... one moment.  I just wanted to

Page 11787

 1     know where you were living and it's okay for the other details.  And I

 2     believe that you've answered it.  You lived in the Zadar municipality;

 3     correct?

 4        A.   Mm-hm.

 5        Q.   Yes?

 6        A.   That's correct.

 7        Q.   And in 1992, where were you living?

 8        A.   In Obrovac.  In Obrovac municipality.

 9        Q.   And in 1993, where were you living?

10        A.   Until May, if I'm not mistaken, in Obrovac.

11        Q.   And then -- and then?

12        A.   And then in Belgrade.  Occasionally in Belgrade.  I still had not

13     moved completely.  I split my time between Belgrade and Obrovac, because

14     you have to understand that moving one's family is a very complex thing

15     and that it cannot be done overnight, not even within a month.  It takes

16     some time to start a new life, to find jobs, and things like that.

17        Q.   And regarding your -- your duties, your political duties, were

18     you still carrying those out in this period of transition, as you

19     describe it?

20        A.   What do you mean, the "period of transition"?  What time-frame

21     would that be?

22        Q.   Well, I believe you described thinking about moving to Belgrade

23     and then finally making the decision later on, in September,

24     October 1993.

25        A.   Yes.

Page 11788

 1        Q.   So between -- between May of 1993 and, let's say, October of

 2     1993, were you still carrying out your -- your duties with the assembly,

 3     with the Obrovac assembly and also with the RSK government?

 4        A.   No, not in the government and the assembly.  I was a deputy in

 5     the Assembly of the Republic of Serbian Krajina during that period.

 6     After the fall of the government headed by Zecevic, I told you that my

 7     term of office finished.  I didn't want to be a member of

 8     Djordje Bjegevic's government, and that government was established

 9     sometime in May 1993.

10        Q.   When you say that you did not want to be a member of

11     Djordje Bjegevic's government, how did you terminate your membership

12     officially?  Did you take any steps?

13        A.   No.  Under the Krajina laws, we were at disposal for six months.

14     We were given six months to find new jobs and, in the meantime, we

15     received regular salaries from the government.  In other words, for the

16     next six months on every first day of the month, we would still receive

17     our dues.

18        Q.   And how would they know not to give you your dues?

19        A.   That was regulated by the law.

20        Q.   Now, you spoke a lot with Mr. Zivanovic about various issues.

21     You spent a lot of time talking about Krusevac.  Krusevac is in Serbia;

22     is that correct?

23        A.   Yes.

24        Q.   And am I correct that it's in the most eastern part of Serbia?

25        A.   Southeastern.  It would be in the south-east.

Page 11789

 1        Q.   What I haven't really heard much about are your duties as

 2     minister of culture and religion.  From -- during what periods did you

 3     hold that position?

 4        A.   From April 1992, or thereabouts, until May, the beginning of

 5     May 1993, for approximately a year.

 6        Q.   And during that year, could you explain to the Trial Chamber what

 7     duties you exercised as the minister of culture and religion in the RSK

 8     government.

 9        A.   Could you please repeat your question?

10        Q.   What did you do as minister of culture and religion?

11        A.   Now I understand.  You mean what my job description was?  What my

12     tasks were?

13             As soon as I joined the ministry, we set up the state archives of

14     the Republic of Serbian Krajina.  We took certain measures to set up the

15     state theatre of the Republic of Serbian Krajina.  I introduced religious

16     education into the elementary and secondary school syllabus.  I dealt

17     with a number of issues within the sphere of culture, guest appearances,

18     public gatherings.

19        Q.   Could we have some more information about the introduction of

20     religious education into the elementary and secondary school syllabus

21     of -- what was the nature of that religious education?

22        A.   In co-operation with the Ministry of Education and the

23     then-minister was Milan Knezevic, we had to co-ordinate our activities in

24     order to introduce religious education into elementary and secondary

25     schools.  We had to print textbooks.  We had to define the issues that

Page 11790

 1     would be dealt with.

 2        Q.   And when you say "issues," what do you mean?  "Issues to be dealt

 3     with."

 4        A.   How shall I explain that?  The work of the Ministry of Education

 5     entailed dealing with all the subjects:  Biology, geography, foreign

 6     languages.  They had to define what the children will learn, every day,

 7     and what issues will be covered within the syllabus, within the

 8     curriculum on each and every day when that subject was taught.

 9        Q.   And so, if I understand you correctly, religious education became

10     compulsory in schools for elementary and secondary school-aged children?

11        A.   Yes, that's correct.

12        Q.   Had it been compulsory before?

13        A.   No.  We were part of the eastern bloc, where the League of

14     Communists was the ruling party, and any mention of religion was

15     condemned.  So the answer to your question would be, no.  There was no

16     religious education.

17             As far as I can remember, there was the theory of Marxism --

18        Q.   It's okay.  I understand your point.  What was the religion that

19     was compulsory in the schools pursuant to your work and the minister of

20     education?

21        A.   The syllabus covered three biggest world religions:  Orthodox,

22     Catholic, and Islam religions.  There were no Protestants in our midst so

23     we mainly covered those three religions.  If there had been Buddhists, I

24     suppose that they would also be given an opportunity to learn about their

25     own faith, so Buddhism would also have made it into our religious

Page 11791

 1     education as part of the syllabus.

 2        Q.   In the -- the decision that addressed this issue of religious

 3     education in the schools, was there -- were all the religions named or

 4     was there only one religion named?  How did that work?

 5        A.   They were all named; the three religions were named, because we

 6     closely co-operated with the authorities of Republika Srpska.  A host of

 7     priests of various churches were involved in the process.  We were also

 8     in communication with the Catholic priests, with Archbishop Oblak from

 9     Zadar.  On one occasion when we presented our programme to him, he agreed

10     that it was okay and that our concept should, indeed, take off the

11     ground.

12             MS. BIERSAY:  Your Honours, I see the time.

13             JUDGE DELVOIE:  Yes, indeed, Ms. Biersay, if this is an

14     appropriate moment.

15             Mr. Witness, we'll take the second break; 30 minutes as well.  We

16     will be back at 12.45.

17             Court adjourned.

18                           [The witness stands down]

19                           --- Recess taken at 12.13 p.m.

20                           --- On resuming at 12.46 p.m.

21                           [The witness takes the stand]

22             JUDGE DELVOIE:  Please proceed, Ms. Biersay.

23             MS. BIERSAY:  Thank you, Your Honour.

24             Before we begin, may I please have, I believe it's tab 72, which

25     would be the Defence 65 ter number 1D03543, and I understand that it's to


Page 11792

 1     be used under seal.  So perhaps it's best to go in private session.

 2             JUDGE DELVOIE:  Could we go into private session, please.

 3                           [Private session]

 4   (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 11793











11 Pages 11793-11795 redacted. Private session.
















Page 11796

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7                           [Open session]

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

 9             JUDGE DELVOIE:  Thank you.

10             MS. BIERSAY:

11        Q.   Mr. Veselinovic, is it -- isn't it true that you helped to

12     organise certain groups before the conflict officially started?  Certain

13     militant groups to be specific.

14        A.   I don't know what this has to do with.

15             MS. BIERSAY:  May I now have -- this is 60 -- excuse me, tab 44,

16     Exhibit P2989.  And it has been admitted.

17        Q.   I will describe it.  It is described as a former RSK minister on

18     Belgrade hegemony who is a real authority in the Serbian Krajina.  And it

19     is an interview with, at this point in time, former RSK defence minister,

20     Stojan Spanovic.  And you described knowing Mr. Spanovic; correct?

21        A.   Yes.

22        Q.   Now, on the second page, that's what I'm interested in, the

23     second page of this exhibit, the very last line, if you will, block and

24     he was asked:

25             "In your opinion, how long will the situation in the RSK

Page 11797

 1     develop?"

 2             And Mr. Spanovic replies, it starts with:

 3             "I think that our people will be able to separate the wheat from

 4     the chaff."

 5             But I am interested in the sentence that begins:

 6             "Both the Serbs and the Croats have been betrayed ..."

 7             Do you see that?

 8        A.   Yes.

 9        Q.   And he says:

10             "Before the first elections in Croatia, Milosevic, through the

11     Knin branch of Jugobanka and some people from Zagreb organised militant

12     groups under the leadership of Sergija Veselinovic, Jovo Dopudja, and

13     Dusan Zelenbaba."

14             I think it says Zelenbaba, but do you know someone by the name

15     Dusan Zelembaba?

16        A.   Yes, yes.

17        Q.   And who is Dusan Zelem - with a M, as in money - baba?

18        A.   Dusan Zelembaba is a doctor.  His speciality was -- he was a

19     doctor at the Knin hospital, a gynecologist by speciality.

20        Q.   And was he in any way involved in the declaration of independence

21     and autonomy of the -- the Serb people?

22        A.   No.

23        Q.   And who is Jovo Dopudja?

24        A.   Jovo Dopudja is a textile engineer.  For a while he was the

25     commander of the Obrovac Brigade.  And he is a reserve officer, holding

Page 11798

 1     the rank of major.

 2        Q.   So is it true, sir, that before the very first elections, you and

 3     these people were organising militant groups in the Knin area?

 4        A.   There weren't any groups.  I never met this Zivota Abramovic.  I

 5     met Ratko Mladic only at some point in late 1991 and the elections were

 6     held in April 1990.  So none of this is true.  This Menso Sakotic

 7     [phoen], never heard of him or met him in my life.  I have no idea who

 8     that is.

 9        Q.   Well, according to what I've read, the association is not with

10     you and the people in the next sentence, which begins "in the army," the

11     association is with you, Jovo Dopudja and Dusan Zelenbaba, and that's

12     what I'm asking you about?

13        A.   I had nothing to do with Jovo Dopudja and Dusan Zelenbaba in

14     connection with arming or forming of any armed groups.  I never had

15     anything to do with them in connection with anything like that, ever.

16             This Jovo Dopudja had a completely different political

17     orientation than me.  He was Communist.  I had no co-operation with him

18     in this period.

19             MS. BIERSAY:  If I could now turn to 65 ter number 6516.  And I

20     believe it can be found at tab 53.  And this is described as a report of

21     the Republic of Croatia service on the roles of various people in the

22     territory of Republic of Croatia and believe that this is sometime after

23     May 1991.

24        Q.   And so I'd like to direct your attention to page 4 of this

25     document, which I will read to you.

Page 11799

 1             And the -- the section of this report is entitled:  Assistance

 2     with weapons, food and equipment derived from Serbia, and other contacts.

 3             And I'm interested in the sentence or the little paragraph that

 4     begins with your name, Sergija Veselinovic.  I will read it now:

 5             "Sergija Veselinovic, the president of the Obrovac council,

 6     stressed that he had organised the delivery of various kinds of goods

 7     from Serbia, goods worth a great deal of money (3,000 billion old dinars)

 8     as well as three cars from Pristina for the use of the Knin police, and

 9     that he was personally responsible to Slobodan Milosevic for the results

10     of his activity.

11             "Bosko Bozanic, the president of the T. Korenica council, managed

12     to get hold of a number of uniforms through the mediation of S.

13     Veselinovic.  The bill was paid by the Belgrade progress company ..."

14             So isn't it true that you were involved in collecting various

15     goods, including cars?

16        A.   No vehicles, none to do with Pristina or progress or uniforms.

17     Never.  I never had any contact with any of that.

18        Q.   If we could now move to --

19        A.   And especially not those millions.

20        Q.   So which is it?  Is it that it's the value wasn't those millions

21     or you didn't have anything to do with collecting cars and goods?

22        A.   No, not at all.  I had nothing to do with any sort of money.

23             MS. BIERSAY:  If we could now move to page 8, please.

24        Q.   And I'd like to direct my attention to the section that has the

25     header --

Page 11800

 1             JUDGE DELVOIE:  Mr. Zivanovic.

 2             MR. ZIVANOVIC:  Sorry, I cannot see the answer of the witness

 3     after the question in -- on page 55, line 7.  There is just continuation

 4     of previous answer and especially not those millions.  It is 56 -- page

 5     56, line 1.  But I cannot see his previous answer to -- to the question

 6     of Ms. Biersay.

 7             MS. BIERSAY:  I -- I agree that it's missing from the transcript,

 8     but I believe the follow-up questions clarified the witness's position

 9     regarding that.

10             JUDGE DELVOIE:  Indeed the witness answers starts, "No, I never

11     had anything to do with any contact."  That's where the answer starts.

12             MS. BIERSAY:  Yeah.

13             JUDGE DELVOIE:  So it's on the record now and it will be

14     corrected, Mr. Zivanovic.

15             MS. BIERSAY:

16        Q.   So now directing my attention to the header: "Contacts

17     between" --

18             MS. BIERSAY:  Sorry.  I saw counsel rise.  I'm ... I'll continue.

19        Q.   "Contacts between Serbian Democratic Party extremists and senior

20     officers in the army and members of the police in Serbia."

21             I'll go down, let's say, to the third indentation.  It begins,

22     "General Pekic ...":

23             "General Pekic is mentioned as being involved in Dakic's channels

24     for the transport of arms from Serbia to Croatia.

25             "Sergija Veselinovic from Obrovac also had intentions of solving

Page 11801

 1     the problem of obtaining large quantities of arms with the help of a

 2     number of generals ..."

 3             Sir, did you receive the help of a number of generals to obtain a

 4     large -- large quantities of arms?

 5             JUDGE DELVOIE:  Mr. Zivanovic.

 6             MR. ZIVANOVIC:  Sorry, may we know the source of this document.

 7     What -- who -- who compiled this document, who is author of this

 8     document.

 9             MS. BIERSAY:  I have already stated on the record that it's a

10     report from the -- a service from the Republic of Croatia, and that's the

11     information that we have.  And I believe I am entitled to put

12     propositions to the witness without even showing a document.  I'm merely

13     doing it so that I can show my good faith basis for putting the

14     proposition to him.

15             JUDGE DELVOIE:  Mr. Zivanovic.

16             MR. ZIVANOVIC:  May we -- how we can identify the source of this

17     documents.  It is for our use to -- we have to -- to -- to see about the

18     authenticity of the -- this document and other -- other -- other things.

19     Because of that, I think we -- we should be informed about the source and

20     to establish the source of this document.

21             MS. BIERSAY:  I -- I don't believe in the Prosecution's case the

22     Defence was ever held to the standard of showing the authenticity or the

23     reliability or provenance of propositions that they put to witnesses in

24     cross-examination.  The Trial Chamber has never made that a requirement

25     in these proceedings.

Page 11802

 1                           [Trial Chamber confers]

 2             JUDGE DELVOIE:  Objection is overruled.

 3             Please proceed, Ms. Biersay.

 4             MS. BIERSAY:  Thank you, Your Honour.  If I could have one

 5     moment.

 6                           [Prosecution counsel confer]

 7             MS. BIERSAY:  And I am informed that it was disclosed, I believe,

 8     in June of -- of 2014.  So it was previously disclosed to the Defence.

 9     We're not trying to play a game of ambush here.

10        Q.   Would you like me to repeat the question, or do you recall that

11     it was about whether or not you had the help of generals in obtaining

12     arms?

13        A.   No.  I was not involved in obtaining a large quantity of weapons,

14     nor did I contact any of those generals.

15        Q.   Now, sir, we received what we call here a proofing note which is

16     a note that's generated by counsel when they meet with witnesses before

17     they testify.  It's different from the statement.  And we received one

18     pertaining to information that you gave to the Defence in this case, and

19     it reflected that a newspaper article was read to you and you were asked

20     to comment upon it.  Do you remember that article?

21        A.   Only what Mr. Zivanovic read to me.  Otherwise I never read it

22     before.

23        Q.   And you hadn't read it by the time you gave your statement in

24     April of this year; right?

25        A.   No.

Page 11803

 1        Q.   And in April of this year, the statement that you signed in three

 2     places uses a September 1993 date as the date you left the president's --

 3     you ceased to be the president of the Obrovac municipality; right?  So

 4     when you signed the statement, it said that until September of 1993, you

 5     served as president of Obrovac municipality; correct?

 6        A.   That's a mistake.

 7        Q.   I -- I -- I understand your position about it --

 8        A.   Until May 1993.

 9        Q.   I understand what your position is now.  I'm asking you about

10     what you signed in April of this year.  What you signed was that until

11     September 1993, you served as the president of Obrovac municipality;

12     correct?

13        A.   You mean what is signed?

14        Q.   Yes, that's what I mean.

15        A.   Yes, but it's an obvious mistake.

16        Q.   And also you used the September 1993 date as the date that you

17     stopped being a member of the -- the government.  That's in your

18     statement; right?

19        A.   Yes, but the government in which I was the minister of culture

20     and religious affairs with Prime Minister Zecevic stopped working in

21     April or May 1993.  Perhaps it had to do with the fact that we continued

22     receiving our salaries for another six months.

23        Q.   And in paragraph 24 of your statement, you again say:

24             "In September 1993, I left the RSK and went to Belgrade ..."

25             That's the date you used then; right?

Page 11804

 1        A.   No, that's an error.

 2        Q.   I'm asking about what's written there.  It's what's written there

 3     and it's what you signed; correct?

 4        A.   Yes.  Yes, yes.

 5        Q.   I'd like to address the article that was discussed with you

 6     during your proofing session.

 7             MS. BIERSAY:  And if we could go to, I believe it's tab 61, and

 8     it's 65 ter 6653, and it's dated 26 July 1993.

 9        Q.   And in this article, it's in my experience a bit unusual where

10     the -- the person doing the interview talks about how he came to

11     interview you, where you were.  And in the middle of the -- well, it's

12     difficult to say, but I'd say the first third of the page, the bottom

13     third, it reads:

14             "The author of these lines was informed at the time in Nusic

15     [phoen] Street that Sergija Veselinovic, at that time the 31st-year-old

16     president of Obrovac opstina, was Babic's possible heir."

17             He's talking about something in the past.  And then it continues:

18             "A meeting at that time between the author of this article and

19     Veselinovic occurred only a month and a half later in Krusevac thanks to

20     the help of Aleksandar Andjelkovic, better known as Sasa Bomba to people

21     in Krusevac."

22             If we move a couple of lines down, it says, "This time," "This

23     time," he is talking about meeting you:

24             "This time in the Krusevac pre-trial custody prison where the now

25     former minister of religion and culture in the Krajina government and

Page 11805

 1     deputy of the assembly of the Republika Srpska is now sitting with two

 2     others from Krajina awaiting the beginning of a trial on the basis of an

 3     indictment that accuses him of the criminal act of physical coercion and

 4     extortion.

 5             "In the evening of 19 June, four young men, some them in the

 6     uniforms of the Krajina police, broke into the dwelling of Slavisa

 7     Spasic, owner of a private boutique in Krusevac ..."

 8             Do you recall meeting with Ljubisa, I believe, Popovic?  Do you

 9     remember meeting with the journalist?

10        A.   I remember.

11        Q.   And it is true that you were accused of physical coercion and

12     extortion?

13        A.   I was, yes.

14        Q.   Towards the bottom of the page, I'd say the latter quarter of the

15     page, there begins a sentence:

16             "The criminal tribunal of the opstina court in Krusevac rejected

17     the motion of Defence counsel that the Krajina men be discharged from

18     pre-trial custody."

19             And towards the very end of this, it mentions then Goran Hadzic

20     intervened in order to help you with your criminal difficulties.

21             JUDGE DELVOIE:  Mr. Zivanovic.

22             MR. ZIVANOVIC:  It is misrepresented.  It could be --

23             MS. BIERSAY:  I will --

24             MR. ZIVANOVIC:  -- from the record.

25             MS. BIERSAY:  I will read what -- I'll quote the language:

Page 11806

 1             "Goran Hadzic sent a letter to the judges requesting that they

 2     release me on bail pending trial.  'I am hoping for a favourable

 3     outcome,' Sergija says."

 4             It continues on the next page as well.

 5        Q.   Now, it is -- it is true that Mr. Goran Hadzic intervened in an

 6     attempt to quash the pre-trial detention preceding the trial; correct?

 7        A.   Well, before I answer you, I have to tell you several things in

 8     connection with the article.  First of all --

 9        Q.   We'll get to that.  One moment.  One moment.  I understand your

10     position --

11        A.   All right.

12        Q.   But what I would like to a question -- an answer to is whether or

13     not it is true, as quoted here, that Goran Hadzic sent a letter to the

14     judges requesting that they release you on bail pending trial:

15             "I am hoping for a favourable outcome."

16        A.   The judges didn't read such a statement.  And I'm not aware --

17        Q.   Mr. Veselinovic, I wasn't asking you if they read such a

18     statement.  I am asking whether or not he sent a letter to them

19     requesting that they release you.

20             MR. ZIVANOVIC:  He started his answer, as far as I understood.

21             JUDGE DELVOIE:  Let ...

22                           [Trial Chamber confers]

23             JUDGE DELVOIE:  Please proceed, Ms. Biersay.

24             MS. BIERSAY:  Thank you.

25        Q.   I'll repeat it again.  Perhaps it's not clear.

Page 11807

 1             Did Goran Hadzic send something in a written form, whatever it

 2     can be called, a letter, a petition, to the court asking that you be

 3     released?

 4        A.   I'm not privy to that.  I don't know whether he sent a letter, a

 5     petition.  I really don't know.  I never heard anything about that.

 6        Q.   I will quote from your proofing note.

 7             MS. BIERSAY:  Page 2.

 8        Q.   Which is actually not on the Defence's or the Prosecution's

 9     lists, but what it reads is, the first one, which bears the date 19, 20,

10     21st September, 2014, so three days.  And what this says is:

11             "The witness was informed that his friends, including

12     Goran Hadzic, sent a petition asking the Krusevac municipal court to

13     quash the pre-trial detention for the witness."

14             So it appears from your proofing note received a day ago and this

15     article that Goran Hadzic is attempting to have you released from

16     pre-trial detention.

17             Isn't it true that Goran Hadzic intervened to help you get

18     released from pre-trial detention?

19        A.   In contacts with my family and my lawyer, I did not hear any such

20     thing.  I really don't know whether anything sent -- anybody sent

21     anything.  I never saw anything like that in writing.

22        Q.   I'm not asking if you saw anything.  I'm asking you about the

23     quote that ended up in an article in July of 1993, saying that

24     Goran Hadzic intervened in an attempt to have you released, number one,

25     and number two, in a proofing note that we received on the 21st of this

Page 11808

 1     month where it said that he sent a petition asking the court to quash the

 2     pre-trial detention for you.

 3             JUDGE DELVOIE:  Mr. Zivanovic.

 4             MR. ZIVANOVIC:  I think that it is asked -- asked and answered.

 5             MS. BIERSAY:  And I would submit respectfully that the witness is

 6     doing anything but to answer the question.

 7             JUDGE DELVOIE:  Please proceed, Ms. Biersay.  The objection is

 8     overruled.

 9             MS. BIERSAY:

10        Q.   We have four hours, Mr. Veselinovic.  And I am asking you, again,

11     for possibly the fourth time --

12        A.   Very well.  Very well.

13        Q.   -- about whether or not in July of 1993 you had information,

14     whichever form it came in, that Goran Hadzic intervened in order to have

15     you released from pre-trial detention?

16        A.   No.  I don't know anything about that.  I didn't have that

17     information.

18        Q.   You didn't have it in 1993?  Is that what you're saying?

19        A.   That's what I'm saying.

20        Q.   And you're saying -- so when did you learn that?

21        A.   To be honest, I actually never inquired where any such thing

22     could ever happen.  After the judgement was issued, and after I was given

23     a suspended sentence, I was no longer interested in any such thing.

24        Q.   You weren't interested in the help of your friends, including

25     Goran Hadzic, the people who were trying to get you released from

Page 11809

 1     pre-trial detention?  You weren't interested in that?  Is that what

 2     you're telling the Court?

 3             JUDGE DELVOIE:  Mr. Zivanovic.

 4             MR. ZIVANOVIC:  I think that -- that the question is incorrect in

 5     the part where it says, "... the people who are trying to get you

 6     released ..."  it is question -- the witness clearly stated that he

 7     didn't know about the people who tried -- who tried to -- to get him

 8     released from pre-trial detention.

 9                           [Trial Chamber confers]

10             JUDGE DELVOIE:  Could you move on, Ms. Biersay.

11             MS. BIERSAY:  Yes.  If I could now move to 65 ter 6645.  That's

12     tab 54.  And if we could -- excuse me.  If we could move to the second

13     page.

14             And for the -- the record, this is described as a "VIP" daily

15     news report publication number 33, and the main title is:  Co-chairmen

16     propose comprise.  And there are other articles as well.  And this, we

17     believe, is dated around July 1993.  And I am interested in going to page

18     2 of this document.  Excuse me, page 3.  Sorry.

19        Q.   So this Belgrade publication, just by way of background, I'll --

20     I'm direct your attention to -- it reads -- Blood money, is the title of

21     this article.

22             And in the first column, if we go down to the third full

23     paragraph, it begins, "Rade Leskovac ..."

24             I'll read it to you because I understand that you don't -- you

25     can't read it because it's in English, so I'll read it to you and have it

Page 11810

 1     translated.  But this is just an introduction to what I want to ask you

 2     about that comes later.  It reads:

 3             "Rade Leskovac, leader of the Serbian Radical Party in the

 4     Republic of Serb Krajina, last week accused the president of the

 5     self-proclaimed republic, Goran Hadzic, of pocketing large sums of money

 6     from oil deals."

 7             In the next column, Mr. Hadzic is quoted as saying:

 8             "'Those who attack me are Serb Ustashas.  Fortunately, there are

 9     still Serb patriots who help our army and at my personal request they

10     lent us the oil.  We still have not paid for all of it,' Hadzic said."

11             Now it reads that:

12             "Hadzic said that the real target of the radicals' attack was

13     Serbian President Slobodan Milosevic whose representative in Krajina,

14     Hadzic, is widely seen as being."

15             And this is the part that pertains to you:

16             "At almost the same time, the district court in Krusevac opened

17     the trial of the RSK's former minister of religion and culture,

18     Sergija Veselinovic, who is charged with extortion and illegal possession

19     of arms."

20             So, Mr. Veselinovic, were you aware of the accusations that were

21     being levied against Goran Hadzic at the time?

22        A.   No, I was not aware of that.

23        Q.   You never heard accusations regarding specifically here the

24     smuggling of oil?

25        A.   As far as I know, all the oil that entered Krajina had to be

Page 11811

 1     covered with a complete paper documentation from the customs, from the

 2     sender, everything about the driver and the vehicle and the registration

 3     plates and the destination.  I don't think that any -- anybody could have

 4     done anything illegal in that respect.

 5             And I apologise, when it comes to Rade Leskovac, he was head of

 6     the Radical Party which was an opposition party in Krajina.  In political

 7     showdowns, I suppose that he used salvo fire, anything he could use to

 8     tarnish the leading structures, to have them replaced and to get into

 9     their positions.  That's the only comment I can proffer.

10        Q.   So you're saying that Rade Leskovac made up this accusation;

11     right?

12        A.   I suppose so.

13        Q.   And you're also saying that the article in which you're quoted as

14     saying that Hadzic attempted to have you released from pre-trial

15     detention, that is also inaccurate; right?

16        A.   I said that I didn't know that.  I didn't know that any attempts

17     on his parts were made to that effect.  To this very day, I don't know

18     that.  I never saw a piece of paper that would have been signed by him.

19     The Presiding Judge never read anything out.  Boguljub Popovic is the

20     only person that I know.  He was the first doctor of sciences in Serbia.

21     He was the one who wrote a letter about my character.  He described my

22     life in Zadar and the credits that I took during my political activities,

23     and he was the one who thought that I deserved a different attitude and a

24     different treatment.

25        Q.   So the journalist who wrote that about Goran Hadzic trying to

Page 11812

 1     help having -- to get you released was not truthful.  Is that what you're

 2     saying?

 3        A.   Yes, yes.

 4        Q.   And you're saying that the journalist made it up.

 5             JUDGE DELVOIE:  Mr. Zivanovic.

 6             THE WITNESS: [Interpretation] Since there are a series of errors

 7     in the article -- I apologise.  I can give you a list of those errors.

 8             He did not come to visit me as a journalist but as an

 9     acquaintance.  He never provided me with that text to read and to approve

10     its contents.  I apologise.

11             MS. BIERSAY:

12        Q.   And so the proofing note that says that you were informed that

13     Goran Hadzic sent a petition asking to quash the pre-trial detention for

14     you, that's also inaccurate; right?

15        A.   It was only at the level of speculations.  I have no concrete

16     information, no concrete proof of that.

17        Q.   And what was the basis for your speculation?

18             JUDGE DELVOIE:  Mr. Zivanovic.

19             MR. ZIVANOVIC:  It calls for another speculation.

20             JUDGE DELVOIE:  The witness may answer the question.

21             THE WITNESS: [Interpretation] Can you repeat the question, word

22     for word, please.

23             MS. BIERSAY:

24        Q.   "And so the proofing note that's saying that you were informed

25     that Goran Hadzic sent a petition asking to quash the pre-trial detention

Page 11813

 1     for you, that's also inaccurate; right?"

 2             MR. ZIVANOVIC:  It is asked and answered.

 3             JUDGE DELVOIE:  That was not the question -- that was not your

 4     last question, Ms. Biersay.  It is good that you read your previous

 5     question and the answer, but then there is the next question.

 6             MS. BIERSAY:  I am looking at 68, line 5.

 7             JUDGE DELVOIE:  Perhaps it's not on the record.  Let me check.

 8             MR. ZIVANOVIC:  It is in line 10, as far as I can see.

 9             JUDGE DELVOIE:  Could be.

10             MS. BIERSAY:  So I'd like --

11             JUDGE DELVOIE:  Indeed --

12             MS. BIERSAY:  I'd like to finish.  Can I -- I'll read that line

13     as well.

14             JUDGE DELVOIE:  Okay.

15             MS. BIERSAY:  He never answered that question, either, I'd point

16     out to the Trial Chamber, on the record.  I believe that he did respond.

17     So I will -- is it possible to get him to respond to that first question

18     and then I'll ask -- he answered, I believe, that it was -- it was

19     speculation.

20             JUDGE DELVOIE:  Yes.

21             MR. ZIVANOVIC:  Sorry --

22             JUDGE DELVOIE:  He -- after -- after the question --

23             MS. BIERSAY:  Yes --

24             JUDGE DELVOIE:  -- you were reading, Ms. Biersay --

25             MS. BIERSAY:  He says.

Page 11814

 1             JUDGE DELVOIE:  "It was only at the level of speculation."

 2             MS. BIERSAY:  Correct.

 3             JUDGE DELVOIE:  "I have no concrete information, no concrete

 4     proof of that."

 5             MS. BIERSAY:  Correct.

 6             JUDGE DELVOIE:  And then your question is, "What was the basis of

 7     your speculation."

 8             MS. BIERSAY:  Thank you, Your Honour.

 9        Q.   Is that clear, sir?

10        A.   Years of experience.  He knew me as a honourable man.  So I

11     could, based on that, assume that he could have sent a letter.  In the

12     Serbian language, a petition is something totally different.  A petition

13     means that a number of activists gather.  They ask other people to sign a

14     petition, to liberate somebody or to start some proceeding.  Everybody

15     has to endorse that with their ID card numbers.  That's a petition.  I

16     don't know what you had in mind.  I don't think that either Hadzic or

17     anybody else organised any such thing.  I'm sure that I would have

18     learned either from my wife or my lawyer that something like that had

19     happened and I would have learned that after the trial, after I was

20     released from detention.  I would have learned if there was a petition

21     drive, the way I described it.

22             MS. BIERSAY:  If I could now please have -- I believe it's

23     tab 63, 65 ter 6655.

24        Q.   This is an article from "Borba" and it's entitled:  Debt

25     extortion sentences announced in RSK.  And it appears to be dated 4

Page 11815

 1     August 1993.

 2             Now, the very middle -- essentially the stand-alone sentence that

 3     starts, "After deliberation ...":

 4             "After deliberation, the court, in part," referring to the court

 5     in Krusevac, "honoured the indictment with respect to the crime but did

 6     not sustain the insistence of the prosecutor's office that the accused be

 7     kept in pre-trial custody and stricter penalties pronounced against

 8     them."

 9             It goes on to say that:

10             "Sergija Veselinovic was sentenced to four months for extortion

11     and three months for carrying fire-arms without a licence and was thus

12     sentenced to a single term of five months in prison."

13             It names:

14             "Nikola Stefanovic who was tried in absentia, because he is at

15     large, received the same sentence for the same crime.  Miladin Katanic an

16     accomplice in this crime was sentenced to four and a half months of

17     prison for extortion but he was acquitted of the charge of carrying a

18     fire-arm because as a member of a purpose unit of the Serbian MUP he had

19     a service resolver."

20             Are those the two people who were arrested along with you,

21     Mr. Veselinovic?  Nikola Stefanovic, Miladin Katanic?

22        A.   Miladin Katanic, yes, and Gajic.  Nikola Stafanovic, no, he was

23     not arrested.

24        Q.   Because he -- he fled; is that correct?

25        A.   He did not serve a sentence.  I've already told you that, yes.

Page 11816

 1        Q.   And since you mentioned the name -- I just want to check to

 2     see -- I believe I heard in the translation the interpretation reference

 3     to Mr. Gajic.  Did you mention the name Gajic?

 4        A.   Yes, yes.

 5        Q.   There it is.  Now it appears.  And that paragraph I was reading

 6     ends:

 7             "Although the indictment charged him with the same crime as the

 8     first three, the defendant, Branko Gajic, member of the RSK MUP was

 9     acquitted of the charge because his lawyer, Veroljub Fukelic, proved that

10     he had the least to do with committing the crime of extortion."

11             Is that the Gajic you were referring to?

12        A.   Yes.

13        Q.   And does this article accurately represent the sentence that you

14     received in August of 1993?

15        A.   That sentence was passed at that trial, but then the judge

16     replaced that with a suspended sentence for each of the accused.  I don't

17     know for how many months.  In any case, none of the three served a full

18     prison sentence.  All of those sentences were replaced with suspended

19     sentences.

20             MS. BIERSAY:  I am mindful of the time, Your Honour, and I --

21     this would be a good stopping point.

22             JUDGE DELVOIE:  Thank you, Ms. Biersay.

23                           [Trial Chamber and Registrar confer]

24             JUDGE DELVOIE:  For the planning tomorrow, how long do you think?

25     Do you have any idea how long you will take?


Page 11817

 1             MS. BIERSAY:  It's a good question.  I think it would be safe to

 2     say at least a session.

 3             JUDGE DELVOIE:  Thank you.

 4             Mr. Veselinovic, we -- we end the -- the hearing today, and we

 5     will be back and we expect you to be back tomorrow at 9.00.  You must --

 6             THE WITNESS: [Interpretation] Okay.  Very well.

 7             JUDGE DELVOIE:  You continue to be a witness, and that has two

 8     consequences:  First of all, you cannot discuss your testimony with

 9     anybody, in the hotel, in town, whatever; and the second consequence is

10     that you cannot talk at all to any of the parties.

11             Is that clear?

12             THE WITNESS: [Interpretation] Yes, yes.

13             JUDGE DELVOIE:  Thank you.

14             Court adjourned.

15                           [The witness stands down]

16                            --- Whereupon the hearing adjourned at 1.59 p.m.,

17                           to be reconvened on Wednesday, the 24th day of

18                           September, 2014, at 9.00 a.m.