1 Monday, 8 February 2010
2 [Open session]
3 [The accused entered court]
4 --- Upon commencing at 2.20 p.m.
5 JUDGE ORIE: Good afternoon to everyone.
6 Madam Registrar, would you please call the case.
7 THE REGISTRAR: Good afternoon, Your Honours. Good afternoon to
8 everyone in and around the courtroom. This is the case IT-03-69-T, The
9 Prosecutor versus Jovica Stanisic and Franko Simatovic.
10 JUDGE ORIE: Thank you, Madam Registrar.
11 I would like to move, only for a very short moment, into private
13 [Private session]
1 [Open session]
2 THE REGISTRAR: We're in open session, Your Honours.
3 JUDGE ORIE: Thank you, Madam Registrar.
4 Before I give an opportunity to the Prosecution to call its next
5 witness, I'd like to read an oral decision on a request for protective
6 measures for Witness B-1459.
7 The Chamber will now deliver an oral decision on the remainder of
8 the Prosecution's motion for protective measures for witnesses filed on
9 the 6th of January, 2010, and on the remainder of the Prosecution request
10 for leave to reply to the Stanisic Defence response to the Prosecution
11 motion for protective measures for witnesses filed on the
12 21st of January, 2010, in as far as they relate to Witness B-1459.
13 The Chamber recalls that, on the 25th of January, 2010, it ruled
14 on these motions in as far as they concerned Witness B-1048.
15 In its 6th of January motion, the Prosecution requests that
16 Witness B-1459 be granted a pseudonym and face distortion. The
17 Prosecution states that this witness is a survivor of a so-called human
18 shield incident who was originally scheduled to testify as a Prosecution
19 witness about the same incident in a domestic case before the Court of
20 Bosnia and Herzegovina, to which I will now refer to as the BiH Court
21 Witness B-1459 reported that, in 2008, he received two telephone
22 calls from an unidentified caller who warned him, inter alia, to be
23 extremely careful. Witness B-1459 also reported that he believes that
24 these phone calls were related to his expected testimony before the
25 BiH Court
1 The Stanisic Defence, in its response of the
2 20th of January, 2010, argues that Witness B-1459's fears are subjective
3 that they were expressed only after being solicited by the Prosecution.
4 In relation to the two telephone calls, the Stanisic Defence contends
5 that there is little evidence that the calls were related to the
6 witness's intended testimony in the BiH Court and even less that they
7 could be related to his testimony in the present case. The
8 Simatovic Defence did not respond to the motion.
9 In the 21st of January request to reply, the Prosecution states
10 that it seeks to address certain alleged inaccuracies and incorrect
11 assumptions made by the Stanisic Defence.
12 The Chamber recalls that the party seeking protective measures
13 for a witness must demonstrate an objectively grounded risk to the
14 security or welfare of the witness or the witness's family, should it
15 become known that the witness has given evidence before the Tribunal.
16 This standard may be satisfied by showing that a threat was made against
17 the witness or the witness's family.
18 In examining the request for protective measures, the Chamber has
19 therefore given particular consideration to the threats received by
20 Witness B-1459, as reported by him. The Chamber notes that these threats
21 are of a potentially serious nature and considers that there is a
22 considerable risk that they may have been connected to Witness B-1459's
23 anticipated testimony before the BiH Court. The Chamber further notes
24 that Witness B-1459 is scheduled to testify in the present proceedings
25 about the same incident.
1 Pursuant to Article 20(1) of the Tribunal's Statute and Rule 75
2 of the Tribunal's Rules of Procedure and Evidence, out of an abundance of
3 caution and considering that the requested protective measures would not
4 affect the public character of the trial, the Chamber therefore grants
5 the protective measures requested by the Prosecution and orders that
6 Witness B-1459 shall be referred to by his pseudonym in all public
7 proceedings and filings and that he shall testify with the protective
8 measures of face distortion - where I said measures, of course, I meant
9 the protective measure of face distortion.
10 Furthermore, in light of this decision, the Chamber denies the
11 remainder of the Prosecution's request for leave to reply, in as far as
12 it concerns Witness B-1459.
13 And this concludes the Chamber's decision.
14 Is the Prosecution ready to call its next witness? No protective
16 MS. MARCUS: Yes, Your Honour, correct.
17 JUDGE ORIE: Yes. Only one matter which I'd like already to draw
18 your attention to is that part of the 92 ter statements are -- were given
19 in private session. If I say 92 ter statements, I should have said
20 92 ter testimony. And I do not know what consequences you will attach to
22 MS. MARCUS: Just a moment, please, Your Honour.
23 [Prosecution counsel confer]
24 MS. MARCUS: Your Honours, perhaps private session for one moment
25 to answer the question fully, if you will.
1 JUDGE ORIE: We move into private session.
2 [Private session]
5 [Open session]
6 THE REGISTRAR: We're in open session, Your Honours.
7 JUDGE ORIE: Thank you, Madam Registrar.
8 [The witness entered court]
9 JUDGE ORIE: Good afternoon, Mr. Lazarevic.
10 THE WITNESS: Good afternoon, sir.
11 JUDGE ORIE: Before you give evidence in this Court, the Rules
12 require that you make a solemn declaration, the text of which is now
13 handed out to you by the Usher.
14 May I invite you to make that solemn declaration.
15 THE WITNESS: I solemnly declare that I will speak the truth, the
16 whole truth, and nothing but the truth.
17 WITNESS: SLOBODAN LAZAREVIC
18 JUDGE ORIE: Thank you. Please be seated, Mr. Lazarevic.
19 You gave your solemn declaration in English. Do you prefer to
20 give your testimony in English as well, Mr. Lazarevic, because we --
21 THE WITNESS: [Overlapping speakers] ... Your Honour.
22 JUDGE ORIE: We have interpreters here who could translate your
23 words if you would prefer to speak your own language, your native
25 THE WITNESS: Actually, I would rather speak in English.
1 JUDGE ORIE: You'd rather speak in English.
2 Mr. Lazarevic, you will first be examined by Ms. Marcus.
3 Ms. Marcus is counsel for the Prosecution.
4 Please proceed.
5 MS. MARCUS: Thank you, Your Honour.
6 Examination by Ms. Marcus:
7 Q. Good afternoon, Mr. Lazarevic.
8 A. Good afternoon.
9 Q. Could you kindly state your full name, date, and place of birth
10 for the record.
11 A. Slobodan Lazarevic, 26th of February, 1947, Belgrade.
12 Q. Can you please tell the Court where and when -- sorry. Where and
13 what it was that you studied?
14 A. Languages at university of philosophy.
15 Q. Do you recall giving evidence before this Tribunal in the case
16 against Slobodan Milosevic on 29th through 31st of October of the
17 year 2002?
18 A. Yes, I do.
19 Q. And have you --
20 THE INTERPRETER: Could you make pauses, breaks between questions
21 and answers. Thank you.
22 MS. MARCUS: My apologies.
23 JUDGE ORIE: Mr. Lazarevic, from reading the transcripts in the
24 Milosevic case, it's not the first time that you are reminded to -- not
25 to go into -- too high a speed.
1 THE WITNESS: My brain goes too fast.
2 JUDGE ORIE: Take your time.
3 THE WITNESS: Thank you. I will.
4 MS. MARCUS:
5 Q. Mr. Lazarevic, have you had the opportunity to review the
6 evidence that you gave during that testimony before coming to court today
7 in a language which you understand?
8 A. Yes, I have.
9 Q. Now that you have taken the solemn declaration, do you affirm the
10 truth and accuracy of your prior evidence?
11 A. Yes, I do.
12 Q. If I were to ask you the same questions today which you were
13 asked then, would you provide the very same answers?
14 A. Absolutely.
15 MS. MARCUS: Your Honours the Prosecution tenders Mr. Lazarevic's
16 testimony in the Slobodan Milosevic case, dated the 29th through the
17 31st of October, 2002, into evidence under seal.
18 JUDGE ORIE: No objections.
19 Madam Registrar, the number would be?
20 THE REGISTRAR: Exhibit P224, under seal, Your Honours.
21 JUDGE ORIE: P224 is admitted into evidence, under seal.
22 I hereby inform the public that this evidence is admitted under
23 seal because there are smaller portions of the evidence given in private
24 session. However, the remainder of the evidence is accessible through
25 the Internet web site of the ICTY, cases, Slobodan Milosevic case. If
1 you are looking for the transcript, you'll find them sorted by date, and
2 it is the transcript of the 29th, the 30th, and the
3 31st of October, 2001 [sic].
4 This is for purposes of the public character of this trial. I
5 said 2001 and I meant to say 2002.
6 Please proceed.
7 MS. MARCUS: Thank you, Your Honour.
8 The Prosecution would also like to tender the associated exhibits
9 to that prior testimony. We have, as has become our custom, prepared a
10 list of the prior -- the associated exhibits. We can distribute hard
11 copies to those present if that would be of assistance. For your
12 information and for the record, there are no 65 ter exhibits which have
13 already been admitted, so there is no green row on this. And with
14 Your Honours' leave, I would be happy to submit this around. We're
15 tendering, with your leave, the associated exhibits to the prior
17 JUDGE ORIE: Are there any objections against admission, because
18 we have the -- I would say the administrative matter that numbers should
19 be assigned to them, but I'd first like to know whether there are any
20 objections against admission into evidence of the associated exhibits.
21 We'll any way invite Madam Registrar to assign numbers to them.
22 No decision will be taken until this has been done. So, therefore, the
23 parties -- of course, were aware of the associated exhibits still have an
24 opportunity to express themselves on it.
25 Then, meanwhile, please proceed.
1 MS. MARCUS: Thank you, Your Honour.
2 Q. Mr. Lazarevic, in your prior evidence in the Milosevic case, you
3 explained that you served in the Serbian military intelligence unit. Can
4 you describe briefly for the Chamber the structure of the Serbian
5 Military Intelligence Service, KOS?
6 A. Very briefly, there are two strains within the KOS, and one is to
7 deal with internal security of the country, another one is to deal with
8 the external security of the country. My role was in external security
9 of the country.
10 Q. Could you tell the Chamber the years of your service in KOS.
11 A. Basically from 1968 to 1998.
12 Q. And who was your direct handler?
13 A. Colonel Nicola Zimonja.
15 A. In 1991, very early 1991.
16 Q. Who was it who originally placed you there?
17 A. Well, I attended a meeting late 1991, between Toso Pajic,
18 Djuro Skaljac, and Colonel Zimonja. And it was suggested that I should
19 transfer to Samarice which then was a command post for the
20 8th Operational Group under the command of General Mrksic, and that's --
21 I went there.
22 Q. Where precisely were you deployed then within the Krajina?
23 A. Originally it was the HQ of the JNA in Samarice which is also
24 known as the 8th Operative Group. And upon the formation of the corps, I
25 was transferred to the area of the 21st Corps or, as it is also known,
1 Kordun Corps.
2 Q. Now just for clarification, when I asked you when you were first
3 deployed to the Krajina, your answer was in very early 1991. And then
4 when I asked you who placed you there, you described a meeting in late
5 1991 where it was decided that you would be transferred.
6 Could you possibly clarify the dates for us?
7 A. It's a mistake, obviously a mistake that I just made.
8 I arrived to the Krajina region late 1991. I would say probably
9 around 22nd or 23rd of December. And within a week to ten days, I was
10 transferred to Samarice which is in the vicinity of Glina. So that would
11 be the beginning of 1992. I'm sorry. I'm just getting too old.
12 Q. Thank you, sir. Now what was your sector called, the sector
13 where you were deployed?
14 A. It was named according to the UN as Sector North, but in our own
15 naming of the sectors it was actually the sector which is AOR of the
16 21st Corps. And that falls between the two corps and my right-hand side
17 would be Banja Corps, 39 Corps; and on my left would be Lika Corps, or
18 the 19th Corps. So all those three --
19 THE INTERPRETER: Could the witness slow down, please.
20 Thank you.
21 THE WITNESS: I'm sorry.
22 All those three corps areas were under the Sector North
24 MS. MARCUS:
25 Q. Officially --
1 JUDGE ORIE: Mr. Lazarevic, if you say to your right or to your
2 left, for us to understand --
3 THE WITNESS: If I'm facing Zagreb
4 Banja Corps would be on my right and the Lika Corps on my left.
5 JUDGE ORIE: Lika to the west, the other one to the east?
6 THE WITNESS: Yeah.
7 JUDGE ORIE: Yes, thank you.
8 MS. MARCUS:
9 Q. Officially, within the Krajina, what was your job, officially?
10 A. I was liaison officer for the 21st Corps.
11 Q. Can you define for us the role of the liaison officer. What did
12 it mean to be the liaison officer?
13 A. Basically organising the meetings between the command of the
14 Sector North of the UN and the HQ of the 21st Corps, and dealing with all
15 the other international bodies that would come up, like
16 International Red Cross or ECMM or even journalists. It would go through
18 Q. Officially, within the Krajina, to whom did you report?
19 A. I had two -- two lines of reporting. One was to my CO,
20 Colonel Cedo Bulat, who was a commanding officer of the 21st --
21 THE INTERPRETER: Can the witness slow down when he gives names.
22 JUDGE ORIE: Mr. Lazarevic.
23 THE WITNESS: I'm fighting for a breath that's why I'm trying to
24 squeeze too much in.
25 JUDGE ORIE: Yes. If you take a breath first and then continue
1 speaking, then that might assist the others.
2 THE WITNESS: Thank you. My apologies again. [Overlapping
3 speakers] ... back there were two lines of reporting as far as I was
4 concerned: One as a liaison officer, 21st Corps, I would report directly
5 to Colonel Cedo Bulat. The other line was the reporting -- virtually on
6 a daily basis to my KOS
7 between, I also had a few times to report other requests of the KOS to
8 report to the local police.
9 MS. MARCUS:
10 Q. From whom did you receive your salary?
11 A. Again, from two different sources. As an officer of the
12 21st Corps of the Army of the Republika Srpska Krajina, I would receive
13 my monthly salary from Knin. But some other benefits I would receive
14 from -- from Belgrade
15 Q. Mr. Lazarevic, can you tell us how were the corps of the army of
16 the Republika Srpska Krajina, the ARSK, how were the corps formed?
17 A. I can really only try to explain how it happened in the
18 Sector North. I don't know what happened in Sector East or Sector South.
19 But in my own AOR
20 accordance with the position they held on the ground. So if the Banja
21 had their positions there, it would be a Banja Corps. The 21st Corps
22 would cover the area of -- from Glina to Slunj and that was called
23 Kordun Corps or 21st Corps and would directly join the 19th Corps further
25 Q. In which -- now just to repeat and clarify, your corps, again,
1 was -- tell us what the name of your corps was?
2 A. 21st Corps. Also known as Kordun Corps. It was covering the
3 area of Kordun.
4 Q. Thank you. Now, in your prior evidence, you discuss the
5 demobilisation of the Army of the Serb Republic
6 demobilisation of the ARSK, pursuant to the Vance Plan. I'd like you to
7 tell us, and please tell us slowly, prior to this demobilisation, from
8 whom did the corps of the ARSK take their directives?
9 A. From the general HQ of JNA which was still then JNA, turns into
10 VJ later on.
11 So instructions and operational movement and everything else
12 would come straight from Belgrade
13 After the point of us being disarmed in accordance with the
14 Vance Plan, and that meant that there was no more uniformed or military
15 dressed personnel on the ground, over night, we all transformed into
16 police force. Not only the uniforms but also the transportation were
17 over night coloured in blue, which the militia or police colours, instead
18 of being the olive-green, as the military.
19 Q. Okay. We're going return to that topic in just a moment.
20 But, first, can you tell us, while the corps of the ARSK were
21 being set up, what was taking place with respect to the political
22 structures in the Krajina?
23 A. One has to take into consideration the situation on the ground.
24 Everything was happening very fast. Even your smallest police station,
25 for example, would have a diminished number of police officers because
1 all those of Croatian origin had left the area. The same applies to all
2 political structures. If you had a mayor and the mayor was a Croatian,
3 he was no longer there so it was needed to elect another mayor for
4 municipalities. So all this was happening within a short space of time
5 of approximately three month, electing the officials, placing them into
6 positions, setting up the numbers with the police, things like that.
7 Q. Now, you've told us that were the liaison officer for the 21st or
8 the Kordun Corps. What area of responsibility did the 21st or
9 Kordun Corps cover precisely from where to where, and what the territory
10 that was covered?
11 A. The length of the territory which was considered to be area the
12 of 21st Corps would be approximately 70 kilometres long, between 17 to
13 20 kilometres wide. And it was going from Glina to the right or to the
14 east, all the way to Slunj to the left, or to the west.
15 Q. In your evidence in the Milosevic case, on the
16 29th of October, 2002, at transcript page 12319, you explained that the
17 original HQ of the 21st Corps was in Topusko, opposite the UN compound,
18 and that from there the HQ moved to Petrova Gora and from Petrova Gora
19 you moved -- the headquarters moved in early 1993. Can you explain to us
20 what prompted the move of the headquarters of the 21st Corps in early
21 1993 to Petrova Gora?
22 A. Well, we have found ourselves to be in very close proximity of
23 the HQ of the Sector North, the UN forces. As the crow flies, less than
24 150 metres away. So the general idea was, This is great; we can actually
25 observe what they do. Then we realise, at the same time, they are
1 observing what we do. So we decided we are going to remove this place,
2 the HQ, to Petrova Gora, with me being left behind in a hotel in Topusko
3 as an officer of the liaison office.
4 Q. And then what was it that prompted the move later from
5 Petrova Gora to Vojnic?
6 A. That was an order issued to us simple to move from Petrova Gora
7 to -- in the vicinity of Vojnic there was, I don't know, a villa there,
8 and I believe that belonged to Minister Spegelj of Croatia. We were
9 taking that position because apparently the special police force from
11 was off limits to us, the members -- or most of the members of the
12 21st Corps. They had secured the parameter. You could go there only by
14 MS. MARCUS: Could the Court Officer please call up 65 ter 14.
15 This is a map that was marked by the witness during his testimony
16 in the Milosevic case. And I think it would be helpful if the
17 Court Usher wouldn't mind giving this to the witness and putting it on
18 the ELMO. Perhaps, with a pen, the witness can indicate to us what he is
19 talking about as he describes it.
20 JUDGE ORIE: I think you're invited -- could you put the map on
21 the ELMO, please.
22 This is a copy which you do not want the markings to be
23 tendered -- the marked version to be tendered into evidence?
24 MS. MARCUS: The marked version, this very document, with the
25 markings on it, is an associated exhibit, Your Honour.
1 JUDGE ORIE: Yes. But you do not want any further markings --
2 MS. MARCUS: I don't foresee the need for that, Your Honour.
3 JUDGE ORIE: Then could this be put on the ELMO so the witness,
4 without further marking the document could, nevertheless, with a pen
5 could explain to us what is he talking about.
6 [Trial Chamber and Registrar confer]
7 JUDGE ORIE: The ELMO is not functioning. Therefore, I suggest
8 that whatever the witness wants to explain to us he would do that by
9 marking on the screen, although the markings then not to be further
10 tendered into evidence.
11 MS. MARCUS: No, problem, Your Honour.
12 JUDGE ORIE: Yes.
13 MS. MARCUS:
14 Q. Mr. Lazarevic, do you see the map in front of you which you
15 marked during your Milosevic testimony?
16 A. Yes, I do.
17 Q. Could you please kindly identify to us what is shown on this map,
18 what were the locations that you marked.
19 A. There are several locations on this map that I have marked.
20 So let me start with the well, Petrova Gora is right in the
21 middle. Then you have the line going to the MUP Serbia HQ. Right there.
22 Little red dot now.
23 MS. MARCUS: Mr. Lazarevic, you could circle it just so that we
24 know what you're talking about.
25 JUDGE ORIE: Well, what the witness is talking about is what he
1 is reading. It seems to be ...
2 If he says MUP Serbia headquarters, I take it that he is
3 referring to what we find on the screen as the MUP Serbia headquarters
4 and nothing else. I mean ...
5 MS. MARCUS: Yes.
6 JUDGE ORIE: -- that is clear for everyone who looks at it.
7 There is, I see, a reference to the 21st Corps' headquarter. And to the
8 original 21st Corps; perhaps that is headquarters as well. We could ask
9 him because that is it not clear from the text itself yet.
10 THE WITNESS: If I can be of any help. I am pointing at the area
11 of Topusko now. That's where the original HQ of the 21st Corps was
12 situated and the command of the Sector North of the UN. From this
13 position, we moved to Petrova Gora, and then we got displaced by the
14 police from Serbia
15 All the other points here, and that is Pauk HQ -- headquarters, and then
16 RSK parade ground in 1995. That's about it that this map shows.
17 MS. MARCUS:
18 Q. Thank you, Mr. Lazarevic. It was precisely that progressive move
19 and to orient the Court that I wanted to -- to show the map that you had
20 previously marked.
21 MS. MARCUS: Now, we can -- now we can leave the map. Thank you.
22 Q. In the Milosevic case, you mentioned -- and just earlier today
23 you also mentioned Colonel Bulat. Can you tell us who he was, with
24 respect to the 21st Corps?
25 A. Colonel Bulat is a career officer with the JNA. When I met him,
1 he a rank of Colonel and he was Chief of Staff to General Mrksic in
2 Samarice, 8th Operational Group, HQ. Upon the formation of the corps, he
3 was promoted to a corps commander of the 21st Corps in Kordun area.
4 Q. In your prior evidence you describe a so-called anti-terrorist
5 unit of the Kordun Corps. Can you tell us, was this anti-terrorist unit
6 present within the corps throughout the time-period that you were there?
7 A. Yes, they were from 1992 -- from 1992 to the fall of 1995. When
8 I say fall, I meant the fall of RSK.
9 Q. In the Milosevic case, on the 29th of October of 2002, on page
10 12323, you said that this anti-terrorist unit carried out "dirty jobs."
11 You then said of this group:
12 "They are used to scare people. They are used to create
14 Why would there have been tasks to scare people or create
16 A. There are a number of reasons for it. If the things were not
17 tense enough in the area, it will affect the black market, the prices
18 will go down. So they would create disturbance anywhere along the
19 frontier of the 21st Corps to Croatia
20 down all the roads leading to these points of sale, if you like. And the
21 prices will go up within ten days. That was the reason on the ground.
22 But there were other reasons as well. One was a purely political reason.
23 Because every time the situation would go little bit, let's call it
24 reasonable, Belgrade
25 international organisations would start suggesting that we should start
1 negotiating with Croatia
2 Now, I don't think that Belgrade
3 negotiation. So that would also now create the situation with a -- well,
4 we cannot really negotiate because cease-fire agreement was broken here,
5 and was broken there. Things like that.
6 Q. To your knowledge, who provided the funding for the
7 anti-terrorist unit of the 21st Corps? Were they on the payroll of the
8 21st Corps?
9 A. They were not on the payroll of the 21st Corps, but -- according
10 to themselves, Because I knew, I would say, 90 per cent of those boys.
11 There were all young men in their early 20s. The only thing in common
12 that they had was an extensive police record at that young age. And they
13 claimed they got paid by the police, Serbia
14 they did not pay through our -- they did not get paid through our pay
15 master of the 21st Corps.
16 Q. Mr. Lazarevic, prior to the demobilisation under the Vance Plan,
17 can you describe the relationship between the military forces and the
18 police forces on the ground in the Krajina?
19 A. In my former country of Yugoslavia
20 between the police and the military. Two of the biggest soccer clubs in
22 Partizan by army. And that's just to show you what the really
23 relationship between two was. There was always kind of a competition;
24 who was going to come up front as bigger and better than the previous
1 Now, in RSK at the time, early 1992, admittedly the army had the
2 upper hand, simply because of the situation that developed or did not
3 development at the time gave more importance to the army. But they were
4 the one to defend the population in -- in Krajina. So the police kind of
5 took a second stand, if you like.
6 Q. On page 12330, when you were asked how the Vance Plan affected
7 the army of the RSK, you said:
8 "The Vance Plan required total demilitarisation and demobile of
9 all units within the RSK. Us being co-signatories of the plan, what we
10 did, we changed the uniform overnight from military olive-green into the
11 police blue and within a very short period of time, I'd say within ten
12 hours, we have repainted all the military vehicles into the blue colour,
13 being -- representing the police."
14 Did this change affect you directly, and if so, how?
15 A. Well, the only difference that I kind of felt directly, I guess,
16 is I was issued the police ID, I was transformed into a police officer or
17 still within the same area I had the same duties, the officers were still
18 the same, some of them were in police uniforms and some were in civilian.
19 I would attend all the meetings in the Sector North command of the UN
20 dressed as a civilian, really. For the time being.
21 Q. On that same page, 12330, you were asked further about the
22 relationship between the army and the police in the RSK, and you said:
23 "Well, at the very beginning, the army had the upper hand in
24 everything that was happening. When I'm talking about the beginning, I'm
25 talking about 1992. Later on, with the presence of the special forces
1 from Serbia
2 Can you be more specific about what you meant when you said "with
3 the presence of the special forces from Serbia, that power had gone into
4 the hands of the police"?
5 A. From the very beginning of creating the RSK, most of the
6 conscripts came from the population within the RSK. So the army had
7 advantage of selecting the best for them, not the police. So the police,
8 really, at the beginning, was very shorthanded. They couldn't do
9 virtually apart from this daily routine jobs like patrols or
10 investigation, likes that. After demobilisation, suddenly we are now all
11 in the police. Now the police could actually keep those who were
12 educated, who were trained, keep them in their own ranks. After we had
13 mobilisation again, they never returned them to us. They stayed with the
15 Q. Can you explain a bit more about what you were referring to here
16 when you said the special forces from Serbia?
17 A. There so many names attributed to this unit that came across
18 that -- well, I'm using "special force." Maybe they used another name; I
19 don't know. But the point of the fact is we had a sudden influx of
20 uniformed personnel within the area of the 21st Corps. They had
21 different uniforms, different shoulder insignias, different badges on
22 their soldiers. And if you managed to speak to any one of them, you'd
23 realise very clearly that they are coming from Serbia, by the accent they
24 use. And as I said, it was a sudden influx, at least myself, personally,
25 I was not prepared for that. And I remember being asked by the military
1 observers of the UN and the sector commander of the UN, Who are these
2 people suddenly on ground? And my instruction was to tell the UN general
3 on the ground, Well, they are really only passing through.
4 I had no idea they were going to stop or be involved in anything
5 until we were asked to leave the Petrova Gora HQ and give it to them.
6 Q. How did the increased presence of the special forces from Serbia
7 affect operations of the 21st Corps?
8 A. Affected it in many ways, really. I think, suddenly, we find
9 ourselves to have a secondary importance in the area of the 21st Corps.
10 There were areas of the 21st Corps that we were not allowed to go into
11 anymore. There were parts of the 21st Corps that the military observers
12 wanted to go; we had to prevent them from going there. I think that the
13 special force from police just didn't want to be known that they are
14 there for the time.
15 MR. BAKRAC: [Interpretation] Your Honours.
16 JUDGE ORIE: Yes.
17 MR. BAKRAC: [Interpretation] I apologise. I just waited for the
18 witness to finish. I would like to ask my colleague and also the Chamber
19 and that would be easier for us to prepare for the cross-examination if
20 we could be told the time-period that this witness is referring to.
21 We're talking about all of this, but we don't know to which time-period
22 this refers.
23 It will be easier for us for the cross-examination, because our
24 time is also limited for -- to be able to explore exactly the time-period
25 he is thinking of.
1 JUDGE ORIE: Apparently in relation to the last answer, could you
2 tell us when this was that you were instructed to tell that they were
3 just passing by and when they came to the area?
4 THE WITNESS: Beginning of 1993.
5 JUDGE ORIE: Beginning of 1993.
6 Please proceed, Ms. Marcus.
7 MS. MARCUS:
8 Q. Now, was this when the 21st Corps HQ moved from Petrova Gora to
9 Vojnic, as you said before?
10 A. Correct.
11 Q. Who was ultimately responsible for events on the ground at this
12 stage, so after the Vance Plan's demobilisation?
13 A. I'm sorry, I didn't quite understand the question.
14 Q. Let me repeat.
15 Who was ultimately, to your knowledge, responsible for events on
16 the ground after the demobilisation?
17 A. Well, apparently it was supposed to be the Army of
18 Republika Srpska Krajina. But basically all the supplies, the
19 ammunition, and fuel, everything came from Belgrade. So I can suggest
20 that their needs were supplied in a written form to the HQ of the JNA to
22 So if you want the ultimate responsibility, was the JNA.
23 Q. And again, for time-period, are you talking about before the
24 demobilisation or after the demobilisation?
25 A. Before and very, very brief time after. It was taken over by
1 police. Because suddenly there was actually a police force on the
3 MS. MARCUS: Your Honours, I'd like to ask the Court Officer to
4 call up 65 ter 653 which is a chart that was used by the witness,
5 prepared by the witness, to explain the relationships of different organs
6 in the Krajina.
7 Perhaps the B/C/S version might be put on one side for ease of
8 reference for those who don't speak English.
9 Q. Mr. Lazarevic, can you tell us what time-period does this command
10 structure which you prepared, what time-period does it cover?
11 A. I made -- I made this map in 1999. But this would cover anything
12 from early 1992 to the -- May 1995.
13 MS. MARCUS: Your Honours, due to the horizontal nature of the
14 chart, I can either suggest, as Your Honours wish, that we call it up
15 only in English on the screen, full screen; or, again, that we try to use
16 the ELMO for the witness to point. I don't -- again I don't envisage any
17 marking necessary, but I'm at your disposal.
18 JUDGE ORIE: I suggest that we use the English.
19 MS. MARCUS:
20 Q. Can you tell the Court, please, what this chart represents?
21 A. Basically it represents the power structure of what was happening
22 in RSK in Sector North that I know of. If you look at it very carefully
23 you can see the squares. And the whole squares within the scares,
24 they're all interconnected. So really they're working as one body. You
25 have your army structure to your right on the screen, going all the way
1 down to the anti-terrorist unit. Then have you a line that goes straight
2 to General Momcilo Perisic at the General HQ. And they leaned to Pauk
3 formation of the commander Pauk right there in the middle. And to the
4 left you have Arkan forces. You have SDB of Serbia there with
5 Mr. Stanisic on top, and Simatovic below, and Colonel Bozovic. Then you
6 have a little corner there with Toso Pajic who was the chief of police
7 who became minister of internal affairs in the RSK. Next name, you have
8 a representative of the DB of Serbia, Milos Pajic, who was originally
9 there before the conflict. Then you have some RSK politicians which are
10 mostly in the eye of the public at the time.
11 Q. We're going to elaborate a little bit on some of these
12 relationships as we move forward.
13 I'm going to ask you -- I'm going to refer, again, to some of
14 your prior testimony and ask you to clarify or further explain some of
15 the things you said in -- in connection with these relationships.
16 When you were asked at page 12362 about the box marked SDB
18 part of the diagram. And your response was:
19 "At the head of the SDB Serbia at the time was
20 Mr. Stanisic, Jovica. His direct assistants were Frenki, also known as
21 Simatovic or Stamatovic, followed by Colonel Ulemek, Legija, and
22 Colonel Bozovic. And then within the circle you also see Mr. Toso Pajic
23 was the chief of police and liaison officer of the RSK, and his direct
24 line goes to the SDB Serbia, Mr. Stanisic, and RSK MUP minister of the
25 Internal Affairs, also Milos Pajic, head of state security. And all
1 connected directly to Jovica Stanisic."
2 Can you elaborate specifically on what you meant when you said
3 that that "all connected directly to Jovica Stanisic"?
4 A. All and any police structure on the ground was ultimately
5 responsible to Mr. Stanisic, including the Pauk commanders which
6 consisted from three different sources. I mean, if you look at it,
7 Major-General Mile Novakovic at the head of the Pauk, and yet he was an
8 officer of the RSK. And you had Fikret Abidc who was leading his own
9 western Bosnia
10 Colonel Pejovic, Colonel Sarac, all the way to Colonel Bozovic,
11 Colonel Ulemek, and "Gospodine" Simatovic and "Gospodine" Stanisic. So
12 they are really all kind of a package deal.
13 Q. How did you know this to be the case?
14 A. Well, I was there. I was present on the ground when these things
15 were happening.
16 Q. Who was the head of the state security division within the RSK?
17 A. In my sector was Mr. Milos Pajic, at least he introduced himself
18 as one.
19 Q. Now, you also described Toso Pajic whose name we see on this
20 chart as well. What was his role as compared with the role of
22 A. In real terms, I believe that Toso Pajic had more influence than
24 RSK, but he was in a -- he was in constant connection with all these
25 people SDB Serbia which led me to believe that actually he worked for SDB
3 SDB building. And he had another office within the building which was
4 considered to be a government in exile were to retain his position as
5 minister of internal affairs.
6 Q. Can you describe what relationship you had with Toso Pajic, if
8 A. My relationship with Mr. Pajic as extremely cordial and I liked
9 the man, really, as a person. He was well educated. I believe he was
10 studying in France
11 to deal with the French Battalion in the Velika Kladusa area. And I
12 found him to be a perfect gentleman, so. And we spent a lot of time
14 Q. On pages 12336 and 12337, you were asked whether, during your
15 daily contacts with Toso Pajic, he told you who he works for. You
17 "On numerous occasions, he stated that he actually works for
18 Jovica Stanisic who was head of the state security in Serbia proper."
19 Can you elaborate further on your knowledge of Toso Pajic's
20 relationship to Jovica Stanisic?
21 A. As I have stated before, I had at least five times a week
22 meetings with Mr. Pajic, because simply we were coordinating our work
23 between the military and the police as far as the UN forces on the ground
24 are concerned. So quite frequently I would be in his office and he would
25 tell me, like, you know, Daddy's on the ground; daddy's coming tomorrow;
1 he will be here.
2 And I was led to believe that Daddy is Mr. Stanisic. And he had
3 always this little smile on his face when he was talking about Stanisic.
4 He never -- actually, I have to be honest about it, he never
5 directly said, I am working for Stanisic. But he did do all the work.
6 It has been proven that actually he did work for Stanisic in the end.
7 Q. What do you mean when you say "it has been proven that he
8 actually did work for Stanisic in the end"?
9 A. He was relocated to Belgrade
10 DB building and he got his office there. I visited him there. And in
11 his office, within the building, which was taken over by the government
12 of RSK in exile.
13 Q. How long did the Serbian DB maintain their presence in the
14 Krajina, to your knowledge?
15 A. DB Serbia?
16 Q. Yes.
17 A. Probably through the last three days of existence of the RSK;
18 they pulled out first.
19 Q. In your prior evidence and also here today, you've been referring
20 to something called Pauk. Your prior evidence describes a
21 Pauk Joint Command, "Pauk" meaning "spider."
22 In describing the Pauk Command's establishment, you said during
23 your testimony on page 12352:
24 "Special forces were deployed in our area prior to establishment
25 of a new HQ on the Bosnian side in the vicinity of Velika Kladusa,
1 code-named Pauk, meaning spider."
2 Could you clarify what you meant in this case, when you referred
3 to special forces being deployed?
4 A. It does need a bit longer an explanation than a simple sentence
5 or two. At the time in 1993 most of us were distracted to revive our
6 relationship with Fikret Abdic. There were a few of us that were against
7 it, but, then again, the order came from Belgrade so we went along with
9 The situation developed that the forces from Serbia, the special
10 police force in Serbia
11 Joint Command of a special forces from Serbia military personnel from the
12 21st Corps, military personnel of Zapadni Bosnia, under Mr. Fikret Abdic.
13 And also the Arkan's Tigers, they were there to.
14 So, the HQ of the Pauk was established approximately 200 yards
15 inside Bosnia
16 Then approximately 6-, to 800 metres away was the second command of the
17 Pauk which was held by Mr. Frenki Simatovic. So there was a close
18 coordination between what was happening in Pauk and in Bosnia and Pauk in
20 Q. Just for clarification, the second command of the Pauk which was,
21 you say, headed by Mr. Frenki Simatovic, in which territory was that
23 A. In Croatia
24 RSK was a part of Croatia
25 Q. Now you were asked on this very point on page 12356 to describe
1 what, if any, relationship Arkan's group, Arkan's Tigers had with the
2 Army of the Republic of Serbian Krajina, and your answer was:
3 "Well, Arkan's" --
4 MR. JORDASH: Sorry, could I object to the leading nature of this
5 question. This evidence is extremely contentious. And to lead the
6 witness to the answer he previously gave, in our submission, is not a
7 fair way to proceed. What my learned friend should do is ask the witness
8 what his evidence is.
9 JUDGE ORIE: No. As a matter of fact, if Ms. Marcus quotes from
10 his previous evidence, she just goes back to what is already in evidence.
11 Isn't it? That's -- what is on page 12356, I take it that Ms. Marcus
12 wants to give -- to seek follow-up evidence or -- but that's evidence at
13 this moment. The witness has testified that he has reviewed this and
14 that he would give the same answers, and then, when tendered, these
15 transcripts were admitted into evidence.
16 So to say you're leading the witness, you're taking the witness
17 back to what is already in evidence.
18 MR. JORDASH: If that's the position, then I withdraw the
20 JUDGE ORIE: Please proceed, Ms. Marcus.
21 MS. MARCUS: Thank you, Your Honour.
22 Q. So in answer to that question --
23 THE INTERPRETER: The speakers are kindly asked to slow down for
24 the interpretation.
25 MS. MARCUS: My apologies.
1 Q. In answer to that question of what relationship Arkan's group,
2 Arkan's Tigers had with the Army of the Republic of Serbian Krajina
4 "Well, Arkan's forces were deployed in the Pauk HQ and were then
5 put with the MUP of Serbia and the members of the 21st Corps."
6 Can you show us on your command chart where this joint
7 Pauk Command is reflected.
8 A. Do you mean on the map in front of me?
9 Q. Yes, the command chart in front of you.
10 A. Okay. Under the heading of Pauk HQ Bosnia,
11 Major-General Milo Novakovic, you have Fikret Abdic. To the left you
12 have Captain Sarac, Colonel Pejovic, which are the officers of the
13 Arkan's Tigers. Arkan himself, personally, maybe, I don't know, maybe
14 went once or twice. He wasn't there throughout, but these people were.
15 And above them you have Colonel Bozovic, Colonel Ulemek, and
16 Frenki Simatovic as members of the DB. So these are the three sides that
17 make the combined HQ.
18 Q. Can you explain briefly who Fikret Abdic was?
19 A. I used to work for the man. I was employed by Agrokomerc before
20 the conflict. And he is the man who had the vision of creating Kladusa
21 to be the food maker of the world. And he did succeed to the one point
22 and something went bad, and he -- you know. But it was an extremely
23 large company employed most of the people from the region there. It was
24 a food producing plant. It was making biscuits and chicken and I don't
25 know what not. It was making everything; chocolates. His idea was - if
1 I can just go back to the elections in Bosnia-Herzegovina at the time -
2 when he beat Alija Izetbegovic in elections hands down and then refused
3 to become the first president of the Bosnia, didn't want it, he wanted to
4 go back and deal with Agrokomerc which he considered to be his child.
5 When they had decided to make these arrangements with Fikret Abdic to
6 secure the position of Velika Kladusa and all the plants around it, how
7 they came about it, I don't know. But apparently they did make an
8 agreement. Hence, the people like Simatovic and Ulemek and Bozovic and
9 everybody else that was there moved in to secure the sector which was
10 then called western Bosnia
11 fighting the Muslims with aid of special police from Serbia.
12 If you could picture, I don't know if it's possible, really, the
13 21st Corps didn't really like the idea of having behind them 5th Corps.
14 They would rather have these command forces of Fikret Abdic as some of
15 other fighters there and have their lines secured. So as a military
16 point, from the 21st Corps of getting involved in that.
17 The other one is a pure marketing. Mr. Abdic had warehouses in
19 Velika Kladusa had to be transported to Rijeka then to be shipped all
20 over the world. But he can only do it going through the AOR of the
21 21st Corps, because we're in position between Croatia and them. The
22 length of about, as I said before, maybe 17 kilometres. So you had to
23 secure this passageway to Croatia
24 So the whole deal was, kind of, working for all sides involved.
25 Q. Now on page 12422, when you were asked a bit more about the Pauk
1 Joint Command, and when you became aware of this Joint Command, you
3 "It was late 1993 when there was a sudden influx of these men,
4 uniforms I had never encountered before. Talking to them in our own
5 language it was obvious they're not from the area. Also, it was obvious
6 they're not a paramilitary unit as far as we're concerned, because they
7 were given a free passageway and also they were given our old HQ in
8 Petrova Gora."
9 Can you explain what you meant when you said that talking to them
10 in your own language it was obvious they were not from the area?
11 A. There was one officially language of former Yugoslavia called
12 Serbo-Croatian which kind of split into Serbia and then in Croatia
13 you can -- by just listening people speak, you can tell whether they are
14 Croatian or Serbs or which part of Serbia
15 are from Montenegro
16 a very thick Montenegrin accent; you cannot miss it. If you talk to
17 Colonel Ulemek, he spoke Ekavski. Now people from the area, they all
18 speak Ijkavski. If they're born in Kordun and lived in Kordun or even if
19 they're Croatian were [indiscernible] behind, so you had a
20 Ekavski/Ijkavski/Chakavski/Ikavski [phoen] -- I mean, you know, there is
21 a multitude of all these little dialects that would separate same nation
22 into smaller groups where they come from.
23 Q. So which dialect was it that was spoken?
24 A. Ekavski in the majority of the cases. If you were talking to the
25 members of the special police, yes, absolutely, Ekavski. Which I speak
2 Q. And, just for clarification, Ekavski come from what region?
3 A. Serbia
4 Ekavski. I mean, when I say Serbia
5 If you speak Ekavski, you're Serbian from Serbia, end of story. There
6 are some situations around Banja Luka when they wanted now to sound more
7 Serbian then they really are, they are forcing Ekavski in their schools
8 and in public meetings and everything. But it's not natural. They do
9 speak a version of Serbian which is spoken in Bosnia which is Ijkavski?
10 Q. Now, what did you mean when you said they were given free
12 A. Well, simply they could go where I couldn't. As a liaison
13 officer. As I said before, for me to go to Pauk, I need a special pass
14 to go into Bosnia
15 stay there and in dealing with people that I had to go there. And
16 Colonel Bulat gave me a permanent pass for Pauk. So I couldn't just sit
17 in my car and drive straight into Bosnia
18 There were check-points. Before you enter there were check-points there
19 on both sides of the border. And they would check your documents, and
20 they let you go if you had the pass. If you didn't have the pass, you
21 can't go through. You're entering another country and yet nobody asked
22 for passport.
23 MS. MARCUS: Your Honours, if you would like to take a break,
24 perhaps this is a breaking point.
25 JUDGE ORIE: If this would be a suitable moment for you, then we
1 would take the break now.
2 We will resume at 4.00.
3 --- Recess taken at 3.31 p.m.
4 --- On resuming at 4.05 p.m.
5 JUDGE ORIE: Before we continue, I'd like to briefly raise a
6 different matter, which is we need a housekeeping session, and the
7 Chamber is considering to have a housekeeping session either on Thursday
8 morning or Thursday afternoon.
9 Now, it is well known that not all accused are always interested
10 in attending housekeeping sessions which is about numbers and about all
11 kind of practicalities. If Mr. Stanisic would want to attend, then
12 the -- we'll not change the rhythm and then we'll schedule it for the
13 afternoon. If, however, Mr. Stanisic would waive his right to be present
14 at such a housekeeping session, then we would consider to have it in the
15 morning. And assuming that it will not take any longer than from 9.00 to
16 12.00 - and I don't have any reason to believe that - then we could
17 schedule it for the morning.
18 I'd like to hear from the parties at a later moment what their
19 preference is.
20 I see already some body language from Mr. Stanisic.
21 MR. JORDASH: I think Your Honour has his opinion. He'd rather
22 not attend. Thank you.
23 JUDGE ORIE: Yes. He'd rather not attend. Yes.
24 Mr. Bakrac.
25 MR. BAKRAC: [Interpretation] My colleague Petrovic and I have
1 requested from the Secretariat to be issued a ticket so that we may leave
2 for Serbia
3 investigations. And my request is, if that is not possible, to postpone
4 for this a later date because we have already appointments with some
5 witnesses that we want to meet with in order to rehash some issues, and I
6 don't want to go into all the explanations that you are already familiar
7 with. But we would really appreciate it if you could move this to a
8 later date because we already have all the arrangements made, the tickets
9 prepared, everything arranged with the Registry, and meetings in Serbia
10 with these witnesses.
11 JUDGE ORIE: Yes. Would you please be so kind to -- to
12 communicate with Chamber staff days on which you are -- for days on which
13 it is not possible for you to attend due to these kind of commitments,
14 always for the morning or the afternoon of that day, so that we can
15 further consider the matter.
16 Mr. Groome, I think for the Prosecution it is a bit less of a
17 problem because usually there is one or two members of the team always
18 available here in The Hague
19 MR. GROOME: I will available, Your Honour, and it's at the
20 convenience of the Chamber and Defence counsel.
21 JUDGE ORIE: Yes, we will further consider it, and we'll
22 certainly also keep in mind your commitments, Mr. Bakrac, so ...
23 Then, Ms. Marcus, are you ready to continue?
24 MS. MARCUS: Yes, Your Honour.
25 JUDGE ORIE: Then please proceed.
1 MS. MARCUS: Thank you.
2 Q. Mr. Lazarevic, I am going to return to the topic that we left
3 off, which was the Pauk Joint Command. I'm going to ask you for some
4 more elaboration and clarifications in relation to some of your prior
6 You were asked on page 12426 of your prior testimony to give more
7 detail with respect to the numbers and composition of the different
8 forces which made up the Pauk Joint Command. And you replied:
9 "I believe that the members of the 21st Corps were numbered about
10 400 strong. I would place MUP to about 200, in Arkans to about 100. And
11 I have no knowledge of how many of Abdic's forces were there."
12 When you mentioned MUP, to whom were you referring in this
13 portion of your prior evidence?
14 A. MUP that came from Serbia
15 Q. Thank you. Now, in relation to the MUP from Serbia, in your
16 prior evidence, on the same page, you stated:
17 "That was actually the special force of police from Serbia
18 proper, headed by Colonel Bozovic, Colonel Ulemek, also known as Legija,
19 apparently he was a former Legionnaire, and Frenki Stamatovic.
20 Frenki Stamatovic held the command in Petrova Gora while the others were
21 across the border in Bosnia
22 Now, how did you know of the involvement of these individuals in
23 the Pauk Joint Command?
24 A. By virtue of actually visiting the command and meeting them
25 there, I don't know whether they were aware of me being there, but I had
1 an instance where I had a meeting with Colonel Bozovic in Kladusa itself.
2 That's how I got my knowledge.
3 Q. What can you tell us about the type of weaponry that the
4 Pauk Command had under its control?
5 A. We were actually envious of the MUP from Serbia because they had
6 a superior weapons than we did. Example: Officers that I met carried
7 Heckler & Koch automatic weapons; I don't know if people know or not. A
8 side-weapon was issued to them, Sig Sauer, another very superior gun to
9 ours that we had which were produced in former Yugoslavia and stored it
10 in different places. And then when the conflict started, we were issued
11 with that.
12 So the quality of the uniforms were better than ours.
13 Originally, when I saw them first, I thought the NATO forces are here.
14 That's how good their uniforms looked. And we had uniforms, you know,
15 variety of styles and -- so it was the weapon.
16 JUDGE ORIE: Could you please repeat the name of the side-arm
17 because I think --
18 THE WITNESS: Sig Sauer. It's a Swiss-made handgun.
19 JUDGE ORIE: Thank you.
20 Please proceed.
21 MS. MARCUS: Could I ask the Court Officer to call up 65 ter 406,
23 Q. Mr. Lazarevic, you commented at length on this document during
24 your prior evidence. Could you, here, just briefly for us comment on the
25 significance of this order.
1 A. Well, if you -- if you look at the heading of the letter itself,
2 it says more an order actually than a letter. And it's done by the
3 command of the Pauk. And then in the third line you have all these
4 people that it was addressed to. And then have you a command -- a
5 command of the 21st Corps and 29 Corps. Tactical Group 2;
6 Tactical Group 3; the command of Pauk; and command of the ZB which is a
7 western Bosnia
8 who are heavily involved in information of Pauk and actively taking part
9 in all the decisions, so whatever is happening on the ground.
10 And then, from 1 to 6, it's listed to send this information back
11 to the Pauk Command, about the number of weapons, the number of
12 ammunition, what the requirements are. So it's that type of document.
13 Q. So --
14 A. And then -- I'm sorry, I was just reading through. Then in the
15 second-last paragraph you have then this should include also the units of
16 MUP. Well, in this case, the MUP is MUP Serbia is not -- not MUP
17 Krajina. And also the units of the RS which is Republika Srpska in
19 JUDGE ORIE: Could -- could we move the document so that we can
20 follow the -- and apparently the witness was referring to the portion
21 after number 6. Yes.
22 MS. MARCUS:
23 Q. So, Mr. Lazarevic, based on your direct knowledge, what do we
24 learn from this order?
25 A. Well, what we learn from this order is actually the -- the number
1 of different units that were involved in Pauk. You got them from Bosnia
2 you got them from Serbia
3 from Bosnia
4 really. And yet they all worked together. And, by the way, the
5 signature on the bottom, it is Colonel Bulat's signature, because I have
6 seen it so many times.
7 Q. Thank you. You'll find me just observing a pause. I was
8 reprimanded by our colleagues in the translation booth, so I'm trying to
9 observe a pause between question and answer.
10 Now, when did you first provide the Office of the Prosecutor with
11 information in relation to the Pauk Joint Command; do you remember?
12 A. Yes, absolutely. In 1999.
13 MS. MARCUS: For the record, I would like to note that
14 Mr. Lazarevic gave his first statement to the Office of the Prosecutor in
15 July of 1999.
16 Q. Now, on pages 12351 and 12352, you described Toso Pajic showing
17 you a document from Mr. Stanisic regarding cooperation with Fikret Abdic.
18 You explained:
19 "It was a time when, for unknown reason to me, Fikret Abdic and
21 only through Stanisic through Toso Pajic also, through the military
22 channels, was to establish a good, neighbourly cooperation with Abdic's
23 forces, which were actually boarding with the 21st Corps area."
24 What do you know about Mr. Stanisic's role with respect to the
25 Joint Pauk Command?
1 A. Well, I don't know nothing personally about Mr. Stanisic's
2 involvement apart from -- analysing the situation and seeing that his --
3 the right-hand man or his number two man in command, Frenki Stanisic, is
4 on the ground. And also from conversation with Toso Pajic and everybody
5 else that Mr. Stanisic does come every now and then but it is not like a
6 24/7 as Mr. Stanisic is -- I mean, sorry, as Mr. Simatovic is. And I
7 can't really see that Frenki Simatovic has carried all this on his own,
8 without really informing Mr. Stanisic or being directed by Mr. Stanisic
9 in this instance.
10 Q. What was your personal position on this issue of cooperation with
11 Abdic's forces?
12 A. My personal condition was, no; adamant no. Because after that
13 point in time in fighting the forces of Fikret Abdic, including the the
14 5th Corps, Because they were the members of the 5th Corps. So they were
15 the enemies officially. And my knowledge -- some other officers were
16 also against this cooperation.
17 Q. Are you familiar with a man named Colonel Raja Bozovic?
18 A. Yes, I think I mentioned him before. He is a Colonel; he is,
19 obviously, of Montenegrin origin because he really, really have this
20 thick Montenegrin accent. And I met him in -- in a huge store in --
21 where his command was or part of his command in Velika Kladusa when I
22 needed to see him about some exchange of -- of soldiers which have died
23 in combat for exchange. And, might I add, he was very unpleasant. If I
24 can quote him, we were asking for a dead and he said, Well, if you need
25 dead, you go and kill him yourself, find him yourself. But he's not
1 going to offer any.
2 Q. In relation to Colonel Bozovic on page --
3 JUDGE ORIE: Mr. Lazarevic, part of what you say is just lost
4 because you speak too quickly.
5 THE WITNESS: I'm sorry.
6 JUDGE ORIE: When you said -- you quoted him that -- if you would
7 ask for bodies that you would say, I'm not going provide them; you have
8 to kill them yourself. That's what I heard from you, but it does not
9 appear on the transcript. If you want your testimony to be reflected on
10 the transcript, I again urge you to slow down.
11 Please proceed.
12 THE WITNESS: Thank you.
13 MS. MARCUS:
14 Q. On page 12443 of your Milosevic testimony, you were explaining
15 about this exchange of bodies to which it seems you've just referred.
16 And you stated that at one point Colonel Mlado Karan, had asked you to go
17 to the headquarters, and you said:
18 "He directed me to go to Pauk Command and speak to
19 Colonel Bozovic and Colonel Pejovic, one was the MUP Serbia, Bozovic was
20 MUP Serbia, and Pejovic was Arkan's Tigers. See if they can assist."
21 You have just mentioned the circumstances of this meeting. Can
22 you elaborate briefly? What was the circumstance of that meeting to
23 which you're referring?
24 A. Through the international mediation, we were offered to exchange
25 the deads with the 5th corps, apparently they claim to have 100 dead
1 Serbian soldiers there and they requested 100 Muslim soldiers for
2 exchange. At that time, the arrangement we had was one for one. So I
3 had a problem finding 100. So I looked all over the place; I went to
4 local police stations -- I don't know. They might have a -- remembering
5 there was one buried here and one buried there; we go and dig them out.
6 Anyway, to make a long story short, we were short people, or
7 short bodies. So when I was discussing this with Colonel Mlado Karan who
8 is in charge of the internal security of the 21st Corps, he suggested I
9 go and see Bozovic and Pejovic, both colonels, since they had been
10 involved in heavy fighting against the 5th Corps, the Bosnian 5th Corps.
11 And that's what I did. And, unfortunately, Colonel Bozovic didn't offer
12 any assistant in that respect. However, Colonel Pejovic did.
13 Q. Do you know what Colonel Bozovic's reporting line was?
14 A. Directly to Mr. Stanisic, or through Frenki.
15 Q. You mentioned earlier, briefly, about Arkan. Can you elaborate?
16 Is there anything else you know about Arkan and his role in the
17 Pauk Joint Command?
18 JUDGE ORIE: Let me -- you asked, Do you know what
19 Colonel Bozovic's reporting line was. And I understood the answer of the
20 witness to be a request for clarification of that question. Or have I
21 misunderstood you?
22 You said: Directly to Mr. Stanisic or through Frenki.
23 Did you want to have more details as far as the question was
24 concerned, or did you give an answer saying that he was reporting
25 directly to Mr. Stanisic, or, as the case may have been, through
1 Mr. Simatovic?
2 THE WITNESS: Former is correct, meaning he was reporting
3 directly to his superior in command within Pauk, and that was referring
4 to Simatovic. And Frenki Simatovic continued his reporting line to
5 Mr. Stanisic.
6 JUDGE ORIE: So you were not seeking further explanation, but you
7 were answering the question?
8 THE WITNESS: Yes.
9 JUDGE ORIE: Then I misunderstood you.
10 Please proceed, Ms. Marcus.
11 MS. MARCUS: Thank you, Your Honour.
12 Q. Mr. Lazarevic, can you explain how you know about Bozovic's
13 reporting line.
14 A. Well, I had opportunity to see him on both sides of the border in
16 I'd say maybe two, three times a month at the headquarters of the
17 21st Corps. And he is a remarkable person when you see him. That would
18 be the only officer I have ever seen to carry a sawn-off shotgun at the
20 Q. Now, to return to the matter of Arkan, what is your direct
21 knowledge, if any, of Arkan and his involvement in the Pauk Joint
23 A. To my knowledge, Arkan was just supplying the additional --
24 additional soldiers or additional fighters to the Pauk Command. Arkan
25 wasn't there himself personally, but he had his people on the ground.
1 And if I know Arkan from his previous involvements, it's got to be the
2 money, otherwise he wouldn't be there.
3 Q. Do you know anything about Arkan's role in RSK before Pauk?
4 A. I only met him once, personally, and it was the meeting in hotel
5 Topusko probably very early in 1992, just prior to arrival of UN forces.
6 There were meetings of high-ranking officer of the JNA in the
7 hotel. And they were trying to figure out what is the best way and
8 fastest way to somehow normalise the life in the area. And
9 Zeljko Raznjatovic busted in on this meeting and really abused the hell
10 out of these people there. They were all generals who were very close to
11 retirement. You know, they were not really, you know, a fighting unit,
12 if you like. But -- and you can see on their faces they are really
13 afraid of him.
14 Q. Do you know who Arkan was answerable to?
15 A. To my knowledge, to the DB of Serbia, even before the conflict.
16 Are we talking about the same man that the half of the Interpol in Europe
17 was looking for? And he had a safe-haven in former Yugoslavia protected
18 by the state security? The man is a known criminal, gangster. He was
19 charged with bank robberies, he was charged with attempted murders,
20 charged with escaping from prisons in Europe. That is not my kind of
21 hero, I'm sorry.
22 Q. On page 1 --
23 JUDGE ORIE: Ms. Marcus, could we ask the witness to clearly
24 distinguish between who Arkan was answerable to, where his answer was
25 primarily focussing on by whom he was protected. Even if I'm protected
1 by someone, it doesn't necessarily mean that I'm answerable to that same
3 Could you make that distinction and also explain to us what the
4 basis of your knowledge is for -- for being answerable to, rather than
5 being protected by.
6 THE WITNESS: If I may, Your Honour, I will give you a little
7 known fact that I haven't mentioned this in this Court before. But there
8 was an incident when Arkan was transporting weapon. And in the area of
10 weapons. They were stopped by police, searched, and arrested. This is
11 just about the beginning of the conflict in Croatia. He was taken to
13 and people from Croatia
14 him and not charge him.
15 So he was working at the time both sides of the borders, for
16 Serbian DB and the Croatian DB.
17 JUDGE ORIE: Could you give us a time-frame for this incident.
18 THE WITNESS: October 1991. But that is a wild guess now,
20 JUDGE ORIE: Let's refrain --
21 THE WITNESS: [Overlapping speakers] ... it was in the newspaper,
22 it was on TV. So it is not something that I've discovered or come up by
23 chance or ...
24 JUDGE ORIE: Please proceed, Ms. Marcus.
25 MS. MARCUS: Thank you, Your Honour.
1 Q. On page 12359 of your Milosevic testimony, you describe a meeting
2 you were going to attend with the RSK minister of defence in
3 UN Sector East. And you describe a chance meeting between a man named
4 Stojkovic [phoen], aka Badza, and Arkan.
5 Do you recall this event?
6 A. Yes, I do. I was a part of the team that went to Sector East
7 with Admiral Rakic who was appointed the minister of defence for RSK,
8 even though we didn't have the navy. I always finds that amusing.
9 Admiral Rakic.
10 Anyway, as we were driving through Sector East --
11 MR. JORDASH: Sorry to leap up.
12 JUDGE ORIE: Yes.
13 MR. JORDASH: I can see the interpreters throwing up a hand in --
14 JUDGE ORIE: Yes. I fully can imagine that they do --
15 Again, Mr. Lazarevic --
16 THE WITNESS: Guilty as charged.
17 Okay. I will try to slow down.
18 As I said, we were going to Sector East with the Admiral Rakic
19 who was the minister of defence of the RSK, and I was in the car with
20 him. There was a driver, Minister Rakic, and myself. The reason I
21 happened to be there was purely for make it possible for Admiral Rakic to
22 speak to the sector commander of Sector East.
23 JUDGE ORIE: Yes.
24 THE WITNESS: And as we were driving through, passing by the
25 petrol station which incorporated, like, a little restaurant with it,
1 Rakic said, No, stop the car, stop the car. There's Arkan over there.
2 So we stopped the car. I didn't get out of the car. He went in and he
3 hugged Arkan and he hugged another man with him. And I was told by
4 Minister Rakic that that was Badza, which I had no idea who he is. Later
5 on, when I asked, they told me he is one high-ranking police officer from
7 MS. MARCUS:
8 Q. Mr. Lazarevic, what is your familiarity with Captain Dragan?
9 A. Captain Dragan, I haven't met personally, ever. All I know is
10 what I heard about him.
11 There was this myth going around that he was a superior in
12 everything he does. So he was engaged to train the special police of
13 RSK, and they would be wearing red berets so they can be recognised. He
14 was, at the time, in the Sector South. And then, within a year, he just
15 kind of dissolved in the air. And the last time I saw him was during the
16 Saint Vitus Parade in Slunj, which is about like a three and a half years
18 Though did I read about him, I have to admit.
19 Q. Can you tell the Court what your knowledge is of a man named
20 Mile Novakovic?
21 A. Mile Novakovic is a JNA colonel who became in a very short period
22 of time a two-star general. So from lieutenant-colonel to two-star
23 general, he made a very quick progress through there. And he was in
24 command of Pauk, officially.
25 Q. Now, you just mentioned the Saint Vitus Day parade in Slunj, so
1 were you present during that celebration of the 28th of June, 1995
2 A. Yes, I have been there, during the parade.
3 MS. MARCUS: Now, I'm going ask our Case Manager to play a clip
4 from the recording, the video-tape of that celebration of
5 Saint Vitus Day.
6 The clip is from 65 ter 267, which is a segment from the full
7 video. The full video being 65 ter 597, which is a related exhibit from
8 the Milosevic case. Now the clip in 627 is from 29 seconds to the end.
9 And that is -- corresponds to 1 hour, 32 minutes, 35 seconds; to
10 1 hour, 34 minutes from 65 ter 597.
11 JUDGE ORIE: Ms. Marcus, I'll just briefly jump in here because
12 Madam Registrar has assigned numbers to your list of documents. And in
13 order to avoid that we are talking about 65 ter numbers rather than to --
14 about exhibit numbers ...
15 Madam Registrar, could you tell us, we have a list of
16 24 associated exhibits. The numbers for those associates exhibits
17 would be?
18 THE REGISTRAR: The numbers would be Exhibit P225 through
19 Exhibit P248. And the 65 ter the counsel is referring to is not in the
20 92 ter package, I understand.
21 JUDGE ORIE: I think she said it was, but I may have
22 misunderstood her.
23 MS. MARCUS: 65 -- the 65 ter 627 is a segment of the 65 ter 597,
24 which is in the -- in the exhibit list.
25 JUDGE ORIE: Yes. 597 would -- in this system, would be 2 --
1 P238. It's an excerpt from -- if I did not make any mistake ...
2 Yes, as far as I can see the sequence on the list, it is part of
3 P238, video of Saint Vitus Day celebration on 28th June, 1995.
4 Let's look at the video.
5 MS. MARCUS: Thank you, Your Honour.
6 Q. Now, Mr. Lazarevic, as we watch the video, please explain to us
7 what you can tell us about what is taking place. And then afterwards I
8 will show you two stills taken from this video and ask to you identify
9 those whom you can recognise in those stills.
10 [Video-clip played]
11 THE WITNESS: The day that I attended was the big parade to
12 celebrate the Saint Vitus Day which was also the day that the battle of
13 Kosovo was waged some 500 years ago. And it's a very special moment in
14 the Serbian history which kind of beats me why would you celebrate your
15 worse defeat ever? But something to do with the mentality, I guess.
16 Now, the [indiscernible] was set up that in the middle within the
17 military components of the parade and to the left where the guests of --
18 excuse me, the guests of the command and to the left were actually the
19 international -- members of the international community, some military
20 observers, officers from the UN Sector North, which I was leading because
21 they were called in as guests.
22 JUDGE ORIE: One ...
23 MS. MARCUS: Could you explain to the --
24 JUDGE ORIE: One -- one second.
25 MS. MARCUS: Sorry, sir.
1 JUDGE ORIE: We've -- we have now looked at this video. There
2 was text under it, apparently transcribing what was said. Since the
3 witness was speaking at the same time, this text, I understand, is of no
4 significance for this piece of evidence, or would it have any
6 MS. MARCUS: If I understand correctly, Your Honour, the text is
7 a narration from a video, the recording, so it was more important to us,
8 Your Honours, what the witness would say about it, than the text.
9 JUDGE ORIE: Yes, I see it is of more importance. But since it
10 appears, I think it should be clear for reasons of transparency that we
11 have not listened, neither was the text translated to us, so, therefore,
12 what is in evidence is the video without the textual part of it, and so
13 the pictures, the footage, as we saw it, and what the witness told us
14 about it.
15 That's what is in evidence.
16 And if I say "it is in evidence," I was anticipating on the
17 decision of the Chamber, that is, that P225 up to and including P248 are
18 admitted into evidence.
19 Please proceed.
20 MS. MARCUS: Thank you, Your Honour.
21 Q. Now, can you explain to us, Mr. Lazarevic, what we saw as we
22 watched that video-clip?
23 A. What we saw? The beginning of the parade. Which happened
24 [B/C/S spoken] or Saint Vitus Day, which was organised in the area of
25 Slunj, basically was a PR stuff. You got a lot of guests, lot of
1 officers from different countries, and we are going to show you how
2 strong we are. The weapons shown there from the lunar rockets was
3 borrowed from a neighbouring Republika Srpska and it was returned to them
4 the following day. Nobody even tried to hide it. But you could notice
5 on the trucks that were going in the parade that some them would carry
6 the number plates from our own corps, and some of them wouldn't have any
7 number plates whatsoever, making sure that nobody really can trace them.
8 Which, since we allowed the TV crews to be there, we wanted actually
9 everybody to see it.
10 JUDGE ORIE: Mr. -- Mr. --
11 Please proceed.
12 MS. MARCUS: Your Honours --
13 JUDGE ORIE: I'm now and then, apart from transcribers,
14 interpreters also have great difficulties in following your speed of
16 Please proceed, slowly.
17 MS. MARCUS: Thank you, Your Honour.
18 With your leave, Your Honour, in light of the Chamber's comment
19 and the witness's comment, with your leave we could replay that without
20 the witness's commentary. I think the questioning will be more fluid
21 thereafter. With your leave, Your Honour.
22 JUDGE ORIE: And would you like to us pay attention to the text
23 as well?
24 MS. MARCUS: I that I would be of assistance, yes. Thank you.
25 JUDGE ORIE: Yes. Then we'll replay the video, and we'll receive
1 the text transcribed and translated to us. And Mr. Lazarevic, therefore
2 you are supposed not to say a word about it at this moment.
3 Take a breath.
4 Let's, again, listen to the video and look at the video.
5 Have you provided the transcript to the booth?
6 MS. MARCUS: Yes, Your Honour.
7 JUDGE ORIE: Yes.
8 Please proceed.
9 [Video-clip played]
10 THE INTERPRETER: [Voiceover] "This is how the ceremonial Vidovdan
11 parade of troops, which had been prepared for several days, was over in
12 the best way possible. We had the opportunity to see our mainstays, the
13 mainstays of our children's serene sleep, the mainstays of our future and
14 our perspective. We had the opportunity to see that we have something
15 more to hope for, even more than we had so far. We also have a modernly
16 equipped, well-trained unit, which is composed of hardened and
17 experienced soldiers. And all those who are here today at Slunj, and all
18 of our honoured spectators who had the opportunity to follow our direct
19 TV coverage from the Slunj parade ground, I'm convinced that
20 you will ..."
21 MS. MARCUS:
22 Q. Mr. Lazarevic, we saw a line-up and an introduction of
23 individuals. Can you describe, in that particular clip, what we were
24 looking at?
25 A. Are we going to see the clip again, or you just want me to tell
1 what happened?
2 Well, in the clip itself, actually, you see just prior to the
3 beginning of parade, you have president at the time Mr. Milan Martic
4 being introduced by General Mrksic and by General Novakovic, the people
5 in front of him on the parade ground there.
6 If you look at it again, you could see General Mrksic,
7 President Martic, and General Novakovic getting introduced to the people
8 of the Pauk Command. First, on the left, would be Colonel Bozovic. Next
9 to him was Colonel Ulemek, Legija, and there's a number of officers from
10 western Bosnia
11 MS. MARCUS: Could I ask the Court Officer, please, to call up a
12 still from this video, which is 65 ter 3223, which is taken from the
13 48-second mark of that particular clip.
14 And if the Court Usher could provide Mr. Lazarevic with a pen to
15 mark the clip, the still, that would be helpful.
16 I'm sorry, I'm advised it's 5223, not 3223. Sorry.
17 A. Right there in the middle, you can see President Martic. Shall I
18 put Martic on the screen?
19 Q. Before you mark --
20 JUDGE ORIE: One second. One second. I see on other screens
21 what I'm supposed to see on my screen as well, but which is not on my
22 screen. And there it is.
23 Please proceed. Could you please repeat your question so the
24 witness can answer it.
25 MS. MARCUS: Yes. Before the witness -- before I ask the witness
1 a question, I wanted to seek your leave to tender this still into
2 evidence unmarked so that other witnesses might also mark it separately.
3 JUDGE ORIE: Madam Registrar, a number for this still, still
5 THE REGISTRAR: Exhibit P249, Your Honours.
6 JUDGE ORIE: May I take it that there's no objection against it,
7 because that wouldn't make much sense, as a matter of fact.
8 P249 is admitted into evidence.
9 Please proceed.
10 MS. MARCUS: Thank you, Your Honour.
11 Q. Now, Mr. Lazarevic, could you tell us whom we see in this still,
12 and we'll mark them one by one.
13 You said, just before, you can see President Martic. Can you
14 take your pen and write Martic, where you see Martic, please.
15 A. Right there in the middle. That is Martic with his hand
16 extended. To the left on your screen you see the silhouette there, but
17 in actual footage of the video, you can see this is a General Novakovic
18 there. I put just G and N.
19 Right there on the top of Mr. Martic is General Mrksic.
20 General Mrksic.
21 The gentleman right there, this is --
22 Q. Just to interrupt you, sir.
23 MS. MARCUS: For the record, the General Novakovic has been
24 marked with GN, for Novakovic; and General Mrksic has been marked General
25 with GM for Mrksic.
1 Continue, please, sir.
2 THE WITNESS: To the right, this young gentleman here, that's
3 Colonel Ulemek. So I'll just put Colonel U. Behind him, you can only
4 see the part of the face, that would be Colonel Bozovic. I'll put
5 Colonel B.
6 Now, this gentleman here, I have no idea who he is. Down there.
7 Q. For the record, when you said have you no idea who he is, you're
8 talking about the gentleman to the far extreme right on the photo. Is
9 that correct?
10 A. Right. The one with the mustache and the beret.
11 Q. Could you please now sign your name on the bottom of the photo.
12 MS. MARCUS: And with that, Your Honours, we would like to tender
13 this marked photograph into evidence, with your leave.
14 JUDGE ORIE: Madam Registrar, the number would be ...
15 THE REGISTRAR: Exhibit P250 Your Honours.
16 JUDGE ORIE: P250, no objections.
17 Therefore, P250 is admitted into evidence.
18 Please proceed.
19 MS. MARCUS: Could the Court Officer please call up 65 ter 53,
20 which is a still taken from later on in this video which is now admitted
21 as Exhibit P238.
22 Q. Sir, can you confirm that that is your handwriting on this photo?
23 A. Yes, it is.
24 Q. Now I'm going to ask our Case Manager, Mr. Laugel, to play a clip
25 from Exhibit P61 -- sorry, yes, Exhibit 61 - from minutes 43:15 to 43:51.
1 And after we watch this very brief clip, Mr. Lazarevic, I will ask you to
2 tell us if you recognise anyone in the clip.
3 JUDGE ORIE: Any text on the clip, Ms. Marcus?
4 MS. MARCUS: Yes, I believe, there is, Your Honour.
5 JUDGE ORIE: And are we supposed to hear the translation?
6 Is that ...
7 MS. MARCUS: Yes, please, Your Honour.
8 JUDGE ORIE: Yes.
9 Let's look at and listen to the video.
10 [Video-clip played]
11 THE INTERPRETER: [Voiceover] "I'm proud to present you with ...
12 I'm proud to present you with this award."
13 MS. MARCUS:
14 Q. Mr. Lazarevic, did you recognise anyone in that video-clip?
15 A. Yes, I have. Mr. Stanisic giving an award to Captain Dragan, a
16 civilian. I mean, he's dressed as a civilian, not in uniform.
17 Q. I'm going to ask you just a few more clarifications and
18 elaborations in relation to your prior evidence.
19 On page 12350, you were asked whether you became aware that
20 Mr. Jovica Stanisic was present in the RSK when you were there. In
21 answer, you stated:
22 "Yes, I think I had the opportunity to meet the gentleman on two
23 or three rather informal occasions in Knin."
24 You were then asked if you were aware that he was present in
25 relation to a dispute between Mr. Babic and Mr. Martic, and you replied:
1 "Yes, indeed. And I believe that particular meeting with
2 Mr. Stanisic came from Belgrade
3 Mr. Slobodan Milosevic to Mr. Babic."
4 Can you explain how you became aware of that event?
5 A. The first time I met Mr. Stanisic was during the -- or after the
6 Assembly session of declaring the RSK. We had a joint dinner. So this
7 is the first time I met him.
8 Admittedly, I have seen him before, I knew about him, but I have
9 never met him. There was a bit of a turmoil going on, on political scene
10 in the RSK at the time. Belgrade
11 the idea of Babic remaining a president of the RSK. Apparently Babic did
12 not follow to the fullest the ideas of Mr. Milosevic how things should be
13 run. Somehow he believed that Krajina is his, he can do whatever he
14 wants, he is the president. So he had to be replaced. And he got
15 replaced by Milan Martic, a police officer. And since he refused to step
16 down, in the end, he was forced to step down. And Mr. Stanisic came to
17 tell him that.
18 Q. Can you tell us who invited to you that event?
19 A. I think the minister of information of RSK with
20 Colonel Kosta Novakovic.
21 Q. You were then asked, on page 12350, whether you were aware of
22 other times that Mr. Stanisic was present in the Krajina from your
23 conversations with other officers.
24 To that question, you replied that Toso Pajic would tell you that
25 Stanisic had been --
1 THE INTERPRETER: Thank you for slowing down.
2 MS. MARCUS: Sorry.
3 Q. To that question, you replied that Toso Pajic would tell you that
4 Stanisic had been there or was coming. Although you were not in the
5 police and thus you were not present at those other meetings, you said:
6 "I'm pretty certain that Mr. Stanisic did come reasonably
7 frequently to Krajina."
8 Can you elaborate on what you meant when you said that you were
9 "pretty certain that Mr. Stanisic came reasonably frequently to Krajina"?
10 A. My relationship with Mr. Toso Pajic was a very close one. We met
11 at least five times a week. If not more, five times at least. And
12 sometimes he would offer me information which I didn't even ask for. But
13 that's how close we were. I don't know, he believed that I should know,
14 maybe, even though I was a member of the police force.
15 So if I would happen to be in his office and he would say that he
16 has to take a call from Belgrade
17 then I would ask him, Do you want me to leave the office? No, no, it's
18 okay. Stay. And then he would address him as daddy -- which, kind of --
19 I find it rather unusual that your superior is called daddy. I don't
21 Any way, those situations were quite a few in three half years.
22 So if he wasn't on the ground, I'm pretty sure he had a constant contact
23 with the people on the ground, whether it is Pauk Command or whether it
24 is Toso Pajic in area of the 21st Corps.
25 Q. In relation --
1 JUDGE ORIE: One ...
2 MS. MARCUS:
3 Q. In relation to Mr. Stanisic's presence on the ground in the RSK
4 in your area of responsibility, you stated in your prior evidence on page
6 "I know at the beginning those visits were more frequent. I
7 think probably due to organisational problems than anything else. At a
8 later stage, Mr. Stanisic had his deputies or his right hands, or
9 whatever you want to call them, who were actually present on a daily
10 basis within the RSK."
11 Who were these deputies or right hands to whom you were referring
12 who were present on a daily basis within the RSK?
13 A. Mr. Frenki Simatovic would be one and Rajo Bozovic would be the
14 other. Rajo Bozovic is Colonel.
15 Q. With the -- with respect to the second accused, Frenki Simatovic,
16 you referred in your prior evidence to the name Stamatovic or Simatovic
17 alternatively. Is this in fact the same person or is it two different
19 A. Well, 90 per cent of population in -- in Krajina knew him as
20 Frenki. But some of the people would pronounce his surname as Simatovic
21 and some would say Stamatovic. But it is referring to the same person.
22 Q. When asked if you had personal knowledge of him, you stated, on
23 page 12352:
24 "He was actually in possession of our former HQ in Petrova Gora.
25 That's when he formed his own HQ with the special forces of the police
1 from Serbia
2 What did you mean when you said "his own HQ"?
3 A. I meant -- I meant Pauk.
4 Q. And how did you know that he had formed his own HQ with the
5 special forces of the police from Serbia
6 A. You have to understand that if you live in an area of
7 responsibility which is only about 70 kilometres long and 15 kilometres
8 wide not many things can happen that are you not aware of, especially if
9 you are in a position to be -- I'm sorry, it says 730 kilometres; it's
10 70 kilometres. I'm looking at the screen here.
11 Not many things can happen that are you not aware of or you
12 haven't been told by others. And yet we are talking, here, maybe about,
13 I don't know, five square miles.
14 So first, as the 21st Corps, we were told to move out, that the
15 MUP Serbia is coming to take over that command post officially. Later
16 on, we discovered that a part of the command is going across the border
17 into Bosnia
18 you will see that HQ which is -- the HQ of Pauk ...
19 HQ of Pauk in Bosnia
20 the rest of the Pauk Command is in Petrova Gora which is in Krajina,
21 about let's say 700 metres away. So between two commands, there's only
22 about 800 to 900 metres in two countries.
23 Q. Was there a particular insignia worn by these special forces from
25 A. They had a shoulder patch which depicted a drawn upside down
1 sword with a Serbian flag on it.
2 Q. Did you have occasion to see that emblem with your own eyes?
3 A. Frequently.
4 MS. MARCUS: Could the Court Officer please call up 65 --
5 JUDGE ORIE: No, no.
6 Please proceed.
7 MS. MARCUS: Could the Court Officer please call up 65 ter 49.
8 I'm sorry, I'm waiting for it on my screen. Does everyone else,
9 see it?
10 Q. Can you identify what we see in this photo?
11 A. Actually, if you look at the side, you see it better than if you
12 like directly at it. There is that drawn sword, you got those inverted
14 Q. Is this the patch to which you previously referred as the emblem
15 worn by the special forces from Serbia
16 A. Yes.
17 MS. MARCUS: Thank you, Your Honours. I have no further
19 JUDGE ORIE: Thank you, Ms. Marcus.
20 Will it be the Stanisic Defence or the Simatovic Defence who will
21 cross-examine the witness first?
22 MR. JORDASH: The Stanisic Defence, Your Honour.
23 JUDGE ORIE: Mr. Jordash, I would like to continue for another
24 12 minutes, approximately, until the break.
25 Mr. Lazarevic, you will now be cross-examined by Mr. Jordash.
1 Mr. Jordash is counsel for Mr. Stanisic.
2 Mr. Jordash is also making some pauses between questions and
3 answers, as you will do as well.
4 THE WITNESS: I will try to.
5 Cross-examination by Mr. Jordash:
6 MR. JORDASH: Sorry.
7 THE INTERPRETER: Could counsel use the microphone with the long
8 stem, to the right of him? Thank you.
9 MR. JORDASH:
10 Q. Good afternoon, Mr. Witness.
11 A. Good afternoon, sir.
12 Q. You spoke earlier today about the special police force in Serbia
13 getting into the area of the 21st Corps. They came into that area at the
14 time, is this right, when the 21st Corps moved from Petrova Gora. Were
15 those two events simultaneous?
16 A. No, I wouldn't call it simultaneous. Most of the -- or some of
17 the members of the MUP Serbia came earlier on.
18 Q. Who came earlier on and how many of them --
19 A. Some of the members. To understand the situation, on the roads
20 straight through the area of the 21st Corps, there were check-points,
21 roads blocks. And at one stage, I can't pin-point the date, we were told
22 they will be coming, the trucks with supplies and manpower, that we are
23 not to stop as they come to the check-points.
24 Q. So members of the MUP Serbia came and started manning
25 check-points in preparation -- no.
1 A. No, misunderstanding. We, as the RSK, had the check-points, some
2 held by police. But to go to Petrova Gora from whatever direction you're
3 coming in, you have to go through the check-points along the roads
4 somewhere. And we were told there will be members of the MUP Serbia
5 coming through and to let them go without stopping or checking what they
7 Q. So the members were coming through on the way to Petrova Gora; is
8 that correct?
9 A. Probably.
10 Q. Well, do you know, or do you not?
11 A. I wasn't present when the very first one showed up. I'm aware of
12 them moving into the HQ on Petrova Gora, setting it up. I am aware the
13 members of the MUP Serbia coming for supplies in Topusko where I was,
14 because the store where would they come is about 50 yards away from me.
15 So I recognised the uniform.
16 Q. So their presence was, as you saw it, or heard about it, in
17 preparation for the takeover of the Petrova Gora site?
18 A. More than likely, yes.
19 Q. And are we talking days or weeks or months before they actually
20 moved into that site?
21 A. Between the times when we moved out and dislocated -- dislocated.
22 Displaced the HQ of the 21st Corps, and the time they took over, I don't
23 think it is more than a month, in total.
24 Q. So approximately -- should we say approximately a month?
25 A. Yeah.
1 Q. Before you moved from Petrova Gora, the special forces of the MUP
2 of Serbia
3 A. Okay. Let's try to sort this out. We moved out of the
4 Petrova Gora compound which is the old military compound. We moved out
5 into new HQ. MUP Serbia started moving in. The moment they started
6 moving in, the whole area was off limits to us. I couldn't go there or
7 military observers or anybody.
8 Q. We're talking about a month from when the members of the MUP
10 A. Yes.
11 Q. And then slowly moving into Petrova Gora, and you, 21st Corps,
12 moving out?
13 JUDGE ORIE: Let me see whether there is any confusion.
14 One month. Is that one month after you moved out until they
15 moved in; or did they move in and did you move out only a month later?
16 Which of the two?
17 THE WITNESS: We moved out. Within the month, they were in.
18 JUDGE ORIE: Yes, Mr. Jordash, from your questions it seems that
19 you had understood perhaps the previous answer in a different way than I
21 MR. JORDASH: Your Honour, yes.
22 Q. So the whole process from the first Serbian MUP members coming
23 into the Republika Srpska Krajina to them occupying Petrova Gora,
24 approximately a month or two months?
25 A. A month.
1 Q. A month, thank you.
2 And you, the 21st Corps, moved to Vojnjik; is that right?
3 A. Vojnic.
4 Q. Vojnic. I think you may have to correct me several times. My
5 pronunciation is quite bad, but I'm getting there.
6 So you moved to Vojnic and that was, am I correct, 1994?
7 A. No, I believe it is in 1993.
8 Q. Whenabouts in 1993?
9 A. Let's speculate now. We moved -- we move from -- from -- above
10 hotel Topusko, late 1992, moved to Petrova Gora ... let's say May 1993.
11 Q. Could I suggest that it was more like 1994. Could that be right?
12 A. No. Unless we look at my previous statement, then we can both be
14 Q. Well, your previous statement in the Milosevic trial, page 12320,
15 suggests - let me just turn it up, so I don't misquote it. Now, if I
16 actually turn to 12319, where you state, at line 20:
17 "A. We have moved that HQ to Petrova Gora, used to be a JNA
18 installation, and then from Petrova Gora to vicinity of Vojnic was the
19 third and last displacement of the HQ.
20 "Q. Can you approximate for us when the headquarters was moved
21 to Petrova Gora?
22 "A. It would be earlier 1993.
23 Over the page:
24 "Q. And can you approximate for us when you moved to Vojnic?
25 "A. It was in the same year, at a later stage, when the Serbian
1 MUP moved into Petrova Gora."
2 So were you trying to say that it was later in 1993?
3 A. Yes.
4 Q. Could it have been at the end of 1993/1994? I suggest that the
5 Serbian MUP did move into Petrova Gora but in November of 1994.
6 A. No, absolutely incorrect. But May of 1995, we're done. And they
7 were much longer there than just the six months.
8 Q. Now, I want to ...
9 MR. JORDASH: Would you like me to continue, Your Honour?
10 JUDGE ORIE: Well, it depends. As I said before, we'll have a
11 break soon, a couple of minutes from now. If you would find this a more
12 suitable moment, then we will have the break now before you start a new
14 MR. JORDASH: Okay.
15 JUDGE ORIE: Then we have a break and we resume at quarter to
17 --- Recess taken at 5.15 p.m.
18 --- On resuming at 5.49 p.m.
19 JUDGE ORIE: Mr. Jordash, you may proceed.
20 And, Mr. Lazarevic, breaks between question and answer, and
21 between answer and question.
22 Please proceed.
23 MR. JORDASH: Thank you, Your Honour. I'm sorry I'm going have
24 to return to the subject before the break.
25 Q. Could I refer to your previous testimony page 12422, and line 4
1 where you state:
2 "It was late 1993 when there was a sudden influx of these
3 uniformed men, uniforms I had never encountered before. Talking to them
4 in our own language, it was obvious they were not from the area. Also it
5 was obvious they were not a paramilitary unit, as far as we're concerned,
6 because they were given a free passageway and also they were given our
7 old HQ in Petrova Gora."
8 So, please, would you think again whether you're suggesting that
9 it was May 1993 or late 1993.
10 A. It was in 1993, I'm absolutely convinced.
11 MR. JORDASH: Could I also then ask for Exhibit 405, please, the
12 Pauk diary, to --
13 Q. But, before that comes, could I ask you this: Am I correct that
14 the Serbian MUP arrived at the same time as other groups which you say
15 were involved in Pauk?
16 Let me put that differently: When the Serbian MUP arrived, Pauk
17 started almost immediately?
18 A. We have to make one thing clear first. I belonged to the
19 military personnel. The movement of police within the RSK was not my
20 focus. It wasn't my interest. This is just my observation. So if I'm
21 saying late 1993, I believe it's late 1993.
22 Q. Well, Mr. --
23 A. Whether the other units belonging to the Pauk Command came at the
24 same time, at a different times, then I don't know.
25 Q. Well, let me ask you this: You obviously noted, as you've said
1 in your evidence, that the arrival of the Serbian MUP was a significant
2 affair. Was their arrival -- did their arrival coincide with the
3 beginning of the Pauk operations?
4 A. Yes, I think so.
5 MR. JORDASH: Could I please have Exhibit 405 on the screen,
7 JUDGE ORIE: Your reference is to --
8 MR. JORDASH: Sorry --
9 JUDGE ORIE: -- a 65 ter number or?
10 MR. JORDASH: Sorry, Milosevic -- yeah, the 65 ter number,
11 Your Honour. This is the -- exactly this. This is the exhibit I wanted.
12 JUDGE ORIE: Yes. Segment of Pauk diary.
13 MR. JORDASH: It's P00235.
14 JUDGE ORIE: Meanwhile, it is P235.
15 MR. JORDASH:
16 Q. Now, have you seen this --
17 JUDGE ORIE: Yes, I see it.
18 MR. JORDASH:
19 Q. Have you seen this diary before, or this log-book?
20 A. Yes I have.
21 Q. And have you confirmed, as far as you're concerned, it was
23 A. That is difficult for me to say. I saw it for the first time
24 only a couple days ago. I haven't seen it before.
25 Q. So you can't confirm the contents of it are accurate?
1 A. I read it. I find it amusing. There is a mention of me in there
2 as well, so I thought, well ...
3 Q. Can you have a look at the first page, there, operations log-book
4 number 1 and then the date --
5 JUDGE ORIE: Could I ask a question. We're talking about years.
6 The one thing apparently is not translated is the year on the title page.
7 MR. JORDASH: The --
8 JUDGE ORIE: I don't know who is responsible for this
9 translation, but ...
10 MR. JORDASH: Yeah, could the first page be raised a little.
11 JUDGE ORIE: You see, I read in the original 16th/11/1994, G.
12 Whereas I see there: 16 November 1990
14 MR. JORDASH: If we can have the bottom of the left-hand screen,
15 please, I think that might assist Your Honour.
16 JUDGE ORIE: Yes, it certainly does -- I'm primarily focussing on
17 accuracy in whatever I see on paper. And perhaps we could -- this first
18 page could be ... could be corrected.
19 MR. JORDASH:
20 Q. I'm not going to labour the point, Mr. Lazarevic. But if that
21 front page of the diary doesn't trigger your memory that the Serbian MUP
22 arrived in November of 1994, then I'll move on.
23 A. I do not agree with you. And I tell you why: This is a front
24 page of operational diary. Somebody was writing down what was happening
25 from day to day. Might be accurate. It doesn't necessary mean that the
1 front page is accurate.
2 Secondly, that is when already the combat situation according to
3 this diary has started. Now, I'm referring to late 1993 when the first
4 MUP units started arriving, so this is where we disagree. This is a time
5 of operation, the combat.
6 Q. Well, I'm not going to labour the point, but did you make the
7 point, didn't you, that the arrival of the Serbian MUP had --
8 A. Late 1993.
9 Q. -- had occurred at around the same time as the Pauk operations
10 had commenced? If you made that -- you accept you made that point? We
11 can move on, if you don't want to accept it, it's okay.
12 A. No.
13 Q. Okay.
14 A. I'm still -- I'm still absolutely convinced it happened in late
15 1993 that the MUP made it to the Petrova Gora compound.
16 Q. And before that time, before the arrival of the Serbian MUP at
17 Petrova Gora, you hadn't heard of them in the Republika Srpska Krajina as
18 a group, had you?
19 A. No.
20 Q. And am I correct that you are unable to assist the Court with the
21 training of the special police of the RSK in Knin, that you don't really
22 know much about that?
23 A. Not really. I can't help you there.
24 Q. All you know about that from what you heard at the time, what you
25 saw at the time, was that Dragan, Captain Dragan was training special
1 police --
2 A. I never said I saw him training the special police. I heard
3 about it.
4 Q. You heard about it?
5 A. Yes.
6 Q. You heard he was training the special police on behalf of Martic?
7 A. Yes. And it was called Martic's police.
8 Q. Exactly. And some of those men who had been trained at Dragan's
9 camp wore red berets; is that correct?
10 A. So I heard, yes.
11 Q. And answered to Martic. Is that what you heard?
12 A. Well, they were called Martic's police; it is natural to assume
13 they are responsible to Martic.
14 Q. Yeah. And you, at that time, had a good knowledge, would you
15 say, of what was going on in the Republika Srpska Krajina?
16 A. No. I never claimed I had a good knowledge.
17 Q. Well, I think you said that if events that were occurring in a
18 70 kilometres by 50 kilometres there were not many things that would
19 happen that you wouldn't be aware of. Is that fair?
20 A. All the population living in that area would be aware what is
21 going on, including myself.
22 Q. Exactly. And the news coming out of Knin and Golubic was that
23 Martic is training a special force?
24 A. More or less, yes.
25 Q. Called the Martic's police?
1 A. Yeah.
2 Q. On behalf of Babic?
3 A. On whose behalf, I don't know.
4 Q. Okay. Now you yourself wore a red beret; didn't you?
5 A. On occasion.
6 Q. Why was that?
7 A. I thought I looked better.
8 Q. Were you trying to associate yourself with Martic's police?
9 A. Absolutely not.
10 Q. Did Martic's police, wearing red berets, have a particular
11 reputation at that time?
12 A. No, I don't think so.
13 Q. Let me ask you about a different subject. I just want to make
14 sure I understand your bibliography, your work bibliography, correctly.
15 In 1991 you joined the JNA?
16 A. Late 1991.
17 Q. Late 1991.
18 A. Probably December 1991.
19 Q. And in early 1992, you were a liaison officer to the 21st Corps?
20 A. Originally I was assistant liaison officer to General Mrksic of
21 the 8th Operational Group in Samarice.
22 Q. Okay. And at that time you started -- and this is your evidence,
23 I think, that you started at around that time working with various
25 A. That come much later.
1 Q. When did that happen?
2 A. The UN was deployed on the ground. They started looking for
3 local people to work for them. So I'd say probably May/June 1992.
4 Q. May/June 1992, you're employed by KOS to --
5 A. No, I was deployed by KOS
6 Q. Yes, sir, if you would just let me finish.
7 A. Sure.
8 Q. You were employed by KOS
9 let me put that differently - to covertly obtain information from the UN
10 and various international organisations, and you did that through taking
11 information from the various translators involved in the international
13 A. What was the date again?
14 Q. May/June 1992, when you started --
15 A. Yes. But you said in there that I was engaged in KOS by that
16 time to gather the information through the translators in local --
17 Q. Mm-hm.
18 A. -- workforce.
19 Q. Were you not?
20 A. That was much earlier than that.
21 Q. When did you start working as an interpreter, taking --
22 organising other translators, and using that work in order to obtain
23 information on behalf of others [Overlapping speakers] ...
24 A. [Overlapping speakers] ... I never worked as interpreter. I was
25 a liaison officer of the 21st Corps. I was assisting the situation on
1 the ground. But, obviously, you couldn't be everywhere at the same time,
2 so they needed to employ more people. And everyone did employ their own
3 translators, obviously.
4 Q. Okay. Let me try to be a bit more specific.
5 A. Sure.
6 Q. Let me just move backwards a bit.
7 Is it your evidence that Stanisic received his information in
8 1991 and 1992, 1993, from the Republika Srpska Krajina mainly through
9 Toso Pajic?
10 A. Yeah, I believe it to be the case, yes.
11 Q. Were you aware of anyone else giving him information?
12 A. Milos
13 Q. Anyone else?
14 A. Not that I know of.
15 Q. Toso Pajic, though, was his, according to you, main information
17 A. Well, he was my information source as much as we exchanged ideas
18 and thoughts and what is going on.
19 Q. Okay. Now, let's return to the issue of the translation and
21 When did you start organising translators to provide information
22 through your work as a KOS
23 A. Well, as soon as they started giving them the jobs on the ground.
24 It was the question of getting those informations which they attend to
25 across to us.
1 Q. When?
2 A. Mid-1992.
3 Q. And how long did that job last?
4 A. To the very end.
5 Q. Date, please.
6 A. 5th of August, 1995.
7 Q. And is this correct: Your job involved organising and briefing
8 translators who were heading to various international or national
9 meetings with the UN and so on?
10 Please, you describe the job to me.
11 A. The idea was, is they are, within the sector of the 21st Corps,
12 they're going have a bunch of these interpreters to work for them on a
13 local level. We're not talking about the international conferences and
14 stuff like that. I never had to deal with those people. I'm talk about
15 the local populace there.
16 If -- if either of the general wanted to have his own interpreter
17 to take him to Bihac when he goes over there, I wanted to know, or,
18 rather, we wanted do know what was discussed on that particular meeting.
19 So that that was the idea of getting them together, talking about the
20 local interpreters.
21 Q. And this was your main work for KOS from --
22 A. No, it was not.
23 Q. What was your main work for KOS during this time-period?
24 A. If I was given a task -- well, I'll give you an example: During
25 one of the international meetings, my only reason being there is to
1 observe General -- Admiral Rakic because he was security risk to us. And
2 that was not my -- that I made up that. I was told that he has got two
3 sons living in Croatia
4 is a military risk to us. But that is, for example, one of the tasks.
5 Q. How often did you arrange translators between 1992 to 1995 to
6 provide information?
7 A. Every time there was any meeting that we had put some relevance
8 do it, yes, I would ask for information.
9 Q. How often would that occur between 1992 and 1995? Was it a
10 weekly, a monthly, a daily affair?
11 A. No. It happened as it happened.
12 Q. Well, give us --
13 JUDGE ORIE: Everyone is going to make a break.
14 I take you back at page -- because I was a bit confused. You
15 asked earlier, Mr. Jordash, what the main source of information for
16 Mr. Stanisic was. You suggested to the witness that it was mainly
17 Toso Pajic. He said that he believed that that was case. You ask about
18 another source of information. He mentioned Milos Pajic. And then, in
19 the follow-up of that question, the explanation was that it was a source
20 apparently for this witness, not primarily for Mr. Stanisic. I was a bit
21 confused about whether Milos Pajic, where the witness said - and part of
22 it is lost in the transcript at this moment:
23 As much as we exchanged ideas and thoughts of what was going on.
24 So, apparently, the conversation moved from the source of
25 information for Mr. Stanisic to your source of information. I'm a bit
1 confused by that. I just wanted to let you know that.
2 And since we had to intervene anyhow, I do it at this moment.
3 MR. JORDASH:
4 Q. Could we just clarify that quickly, Mr. Lazarevic.
5 Milos Pajic was not your main source of information. He was
6 Mr. Stanisic's, according to you?
7 A. No. I never said that. Officially, Mr. Milos Pajic was the
8 member of the SDB.
9 Q. Go on.
10 A. Right. Toso Pajic I consider to be my personal friend, and along
11 the line of him being a liaison officer for the police in the area of
12 21st Corps and I was a military liaison officer, that we should meet and
13 exchange what is going on, on the ground.
14 So I wouldn't even call him my personal source of information
15 about anybody. I want to make clear I didn't go and --
16 Q. Mr. Witness, we get the point. Thank you.
17 A. Okay.
18 Q. Now, one of your principal jobs was to organise the translators;
19 is that correct?
20 A. Yes, I would test them.
21 Q. Right. And one of the ways in which you obtained information was
22 directly from the translators who obtained it from the various meetings
23 they attended; is that correct?
24 A. Correct.
25 Q. Now could you explain exactly how it worked, how it worked that
1 the information came to you, and how it was it was passed on from you.
2 A. It's very simple. If I, for example, heard that the, I don't
3 know, Red Cross of Krnjak [phoen] needed to be -- International Red Cross
4 in the presence of the UN, and we would have an interpreter there to
5 translate. When it is done, I would ask him to write a very brief
6 information what was discussed, what was the point of the meeting. And
7 it was begin to me.
8 Now, if I would get through the day three or four different
9 information about the meetings, then I would compile them and try to make
10 some sort of an overview of the informations, make my own conclusions, or
11 try to draw what is going on from what I have got. And then I would pass
12 that along to Nikola Zimonja or anybody in that sector.
13 Q. What did you pass on? The original report or your composite
15 A. I would give a composite. I would give -- it was original
16 report. I mean, if the person attended a meeting in a capacity of
17 translator, I would ask him, What did you discuss? Do you remember what
18 the points of the meetings? And things like that. In the information I
19 got, I could get it either in writing or being told to me. This is what
20 we talked about. There is a Croatian family needs, requests --
21 Q. Mr. Witness, can I just try to -- I'm going to be limited with
22 time, so if we can just focus on the question.
23 Did you write a composite report from the reports that were given
24 to you?
25 A. Depending how important it was. And it was my decision how
1 important it was or wasn't.
2 Q. If it wasn't important, what would happen? Would you send the
3 original report from the translator?
4 A. Yeah, I would never receive the report.
5 Q. You would never [Overlapping speakers] ...
6 A. When you say "report," I have the idea somebody is handing me a
7 minutes from the meeting written by hand. And this is it, this is your
8 copy, do whatever you want with it. This is it not the case. It was
9 done -- a report can be by mouth, a report can be written down. But it
10 is not an original document.
11 Q. No. Did the translators give you a written report?
12 A. From time to time, yes.
13 Q. Did the translators most of the time give you an oral report?
14 A. From time to time.
15 Q. Was there any other way the translators gave you a report?
16 A. [Overlapping speakers] ... no, there is only two possibilities.
17 Q. Thank you.
18 JUDGE ORIE: Overlapping speakers.
19 MR. JORDASH: Sorry.
20 JUDGE ORIE: Since the subject matter is translators, I thought
21 you would think about it.
22 MR. JORDASH: Sorry.
23 JUDGE ORIE: I think what the witness said is that -- no, let's
24 try to get that evidence again, because overlapping speakers even cause
25 great problems at a later stage.
1 The question was whether there was any other way the translators
2 gave you a report.
3 Your answer was? Two possibilities only: oral or written?
4 THE WITNESS: Or written, yes.
5 JUDGE ORIE: Yes. That apparently was it.
6 Please proceed.
7 MR. JORDASH: Thank you.
8 Q. If the -- if you considered the information you'd received
9 important, you would write your own report about that information; is
10 that correct?
11 A. Correct.
12 Q. And what would you do with that report?
13 A. First I would try to get it to whatever connection I had with
14 Colonel Zimonja. If he was on the ground, give it directly to him. If
15 not, find out who is the next one going to Belgrade so he can take it
16 with him.
17 Q. And is that a process you followed from 1992 to 1995?
18 A. Yes, sometimes I was called in Belgrade to give a report in
20 Q. To who?
21 A. Colonel Zimonja.
22 Q. Did you give anyone else a report?
23 A. I think I worked one -- one task for -- now I'll give you the
24 name; I'm not sure whether it is a real name or not. He was introduced
25 to me as Medo, and he was a member of state security.
1 Q. We'll come do that in a minute.
2 A. Sure.
3 JUDGE ORIE: One --
4 MR. JORDASH: Thank you.
5 Q. So written report by you if information is it important enough,
6 passed directly to Zimonja. That was the process.
7 A. Yes.
8 Q. So you cannot say, can you, what Zimonja did with that
10 A. I have no idea. For all I know, he picked it up and throw it in
11 the trash. I don't know.
12 Q. So you cannot confirm or deny the suggestion that that
13 information did not go to Mr. Stanisic?
14 A. Mr. Stanisic?
15 Q. Yes.
16 A. I never sent any report to Mr. Stanisic.
17 Q. And you don't know what Zimonja did with the reports?
18 A. No, no.
19 Q. And you never sent any report to Stanisic?
20 A. No.
21 Q. And you never gave any reports to anyone other than Zimonja, did
23 A. I did --
24 Q. Expect -- sorry?
25 A. I gave to Toso Pajic. If I would -- if I would get a certain
1 information, I'll give you an example: A battalion which was leaving the
2 sector, an UN battalion, got in touch with me and said -- interested to
3 sell all equipment they have, everything is, including those -- little
4 listening devices, I don't know, part of weaponry, including even the
5 mattresses for their beds, they were ready to sell everything. Now that
6 information was given to Zimonja. Zimonja suggested I should get in
7 touch with Pajic because the VJ was not interested in it. But,
8 Zimonja -- Pajic might be interested in it.
9 Q. So did you -- you gave the report to Pajic -- sorry. You gave
10 the report to Pajic if Zimonja suggested that you do so.
11 A. If he told me, yes, implicitly, You take this, you give it to
12 Pajic, yes.
13 Q. Otherwise, you just gave it to Zimonja?
14 A. Yes.
15 Q. Yeah. Could I suggest you never had this role of passing
16 information to Zimonja and, in fact, you were not a regular KOS agent.
17 A. You can suggest whatever you want.
18 Q. Let's now look at what your previous testimony was.
19 MR. JORDASH: 12386.
20 Q. Let me read it to you, Mr. Witness.
21 Referring to page -- to line 17 and the issue of the
23 "So I with have them go and come back and report to me about what
24 was discussed at the meeting, what decisions were made, if any was made.
25 And then I would compile all these reports in one major report which
1 would -- was sent to my HQ. I would do those in triplicate, really,
2 because one was going to Colonel Zimonja; one was going to the HQ,
3 Colonel Bulat; and one was going do Toso Pajic."
4 Isn't that quite different to what you just told the Court?
5 A. No it isn't quite different.
6 Q. It isn't?
7 A. No.
8 Q. No. Okay. How is it not different?
9 A. It is not different in that respect that I would give my report
10 to Zimonja. If Zimonja suggested I should give a copy to Toso Pajic, I
11 would give it to Toso Pajic.
12 Q. But in the Milosevic case you appeared to be saying that you did
13 your report in triplicate, that each was going to Zimonja, Bulat, and
14 Pajic, as a matter of course?
15 A. Can I have a look at that, please?
16 Q. Sure.
17 MR. JORDASH: Please could we have 12386 on the screen. I think
18 it's P224.
19 JUDGE ORIE: The document is under seal. Would it be limited it
20 to the -- if limited to the page and nothing else to be shown to the
21 public, that is public on the Internet as well. So, therefore ...
22 MR. JORDASH:
23 Q. Have you read that, Mr. Lazarevic?
24 A. Yeah. Line 20, 21, 22.
25 Q. Yeah. Any explanation? Or do you maintain that it is consistent
1 with your account of earlier today?
2 A. Well, apparently it was different here.
3 Q. Yeah.
4 A. That's obvious. I either place it on not remembering, seing that
5 the passage of time is 15 years. But I have an additional explanation
6 for that as well.
7 Q. [Previous translation continues] ...
8 A. There was -- there were situations where I was required to do a
9 single report and only to Zimonja and nobody else. There were situations
10 when I was told to do them in triplicate or in duplicate. But not on a
11 regular basis.
12 Q. Let me ask you, please, to turn to --
13 MR. JORDASH: Can we turn to the witness's first statement at --
14 made in 1999. I have forgotten whether this has been given a P number.
15 I don't think it has. It is ERN 0205-3036.
16 JUDGE ORIE: Mr. Jordash, have you verified whether, on the basis
17 of the limited portions of the testimony to be in private session,
18 whether there is any reason for this statement to be kept
19 confidential or ...
20 MR. JORDASH: The statement I'm now trying to refer to,
21 Your Honours?
22 JUDGE ORIE: Yes.
23 MR. JORDASH: Yes, I think it should be --
24 JUDGE ORIE: It should be confidential.
25 MR. JORDASH: Yes, I think so.
1 JUDGE ORIE: Then, therefore, it should then not been shown to
2 the public.
3 Please proceed.
4 MR. JORDASH:
5 Q. Who told you, Mr. Witness, that you should do reports in
6 triplicate or duplicate?
7 A. Zimonja.
8 Q. Zimonja?
9 A. Yes.
10 Q. Let me ask you to turn to the statement you made in 1999. You do
11 recall making the statement? You've been through it on a number of
12 occasions. I imagine --
13 A. I sincerely hope so.
14 Q. Yes.
15 MR. JORDASH: Let's turn directly to the eleventh page of the
16 English version, and it is page 0205-3046 on the right-hand corner. In
17 the B/C/S, perhaps I can be helped out by ...
18 I'm looking for -- at the paragraph, Mr. Lazarevic, which begins
19 with: "In early 1992, local and other Serbs interviewing for
20 interpreters with the UN" and so on.
21 I'm not sure what page it is. 10, in the B/C/S, thank you. 10.
22 Thank you.
23 Q. And if you read that paragraph, and I'm interested in the second
24 part of the paragraph where it says:
25 "All of the interpreters were required to submit frequent reports
1 back to me, and I forwarded these reports along with my own to Zimonja
2 and Pajic."
3 So "I forwarded these reports along with my own to Zimonja and
5 Isn't that -- did you find that?
6 A. Yeah, I'm looking at it. What about it?
7 Q. Well, isn't that quite different to what you've told us?
8 A. Why is it different?
9 Q. Well --
10 A. I'm telling you that I have been sending reports in accordance
11 with the importance of the report --
12 Q. Why are you suggesting there, in 1999, that you forwarded the
13 reports of the interpreters along with your own report and you forwarded
14 them on a routine basis to both Zimonja and Pajic?
15 A. Only if Zimonja was insisting for me to send the report to Pajic.
16 MS. MARCUS: Your Honours, I waited a while to see where counsel
17 was going with this. The witness has testified that he had two -- he had
18 a dual role in the region.
19 His testimony is that he had an official role within the
20 21st Corps and that he had a somewhat unofficial role with KOS. Which
21 in -- which he says he had two lines of reporting. That's on --
22 JUDGE ORIE: But let's not comment on the testimony of the
23 witness. I mean, if you have any objection against the question --
24 MS. MARCUS: Yes, sir.
25 JUDGE ORIE: -- that's fine. If you have the --
1 MS. MARCUS: Yes, the objection --
2 JUDGE ORIE: Yes. What's the objection?
3 MS. MARCUS: Sorry -- I'm sorry, Your Honour. The objection is
4 that the question should be clear to witness which exactly role he is
5 asking about in terms of reporting line. And that the two may be
6 confused in the manner of questioning.
7 JUDGE ORIE: Yes.
8 Mr. Jordash, I leave it to you at this moment. In general,
9 questions that confuse are not to -- put to a witness. At the same time,
10 the fact that the Prosecution thinks that something may confuse the
11 witness is not decisive of whether or not the question is confusing or
13 I leave it into your hands so --
14 MR. JORDASH: Thank you.
15 JUDGE ORIE: So know -- if you would be, yourself, convinced that
16 it's mixing up matters, then you should refrain. But if you have good
17 reasons to put it in the way you do it, please proceed.
18 MR. JORDASH: The whole paragraph -- just to be clear, the whole
19 paragraph is quite clearly dealing with the KOS role, the whole
21 JUDGE ORIE: So you are putting your questions in that context?
22 MR. JORDASH: Yes.
23 Q. And I can read the second sentence -- sorry, the sentence below
24 what I have just read because this will bring the context:
25 "The result was that every interpreter working with the UN and
1 the ECMM in the Krajina was reporting back to the SDB and was on our
3 That's what the statement says, Mr. Lazarevic.
4 A. I would like to have a look at that one, too. Because I'm pretty
5 sure never said that all -- what are you suggesting is the report from
6 all over Krajina coming to me, and I'm just sending them forward?
7 Q. Well, I'm just looking at your statement. I'm asking you about
8 it. So would you have a look at that paragraph?
9 A. Yeah, please.
10 Q. It's same paragraph we just looked at.
11 "All of these interpreters were required to submit frequent
12 reports back to me, and I forwarded these reports along with my own to
13 Zimonja and Pajic. The result was that every interpreter working with
14 the UN and the ECMM in the Krajina was reporting back to the SDB and was
15 on our payroll."
16 Are you not -- in 1999, suggesting that all the interpreters
17 were, by virtue of this surveillance scheme, let's call it that,
18 reporting to Pajic and Pajic was reporting to the Serbian DB?
19 A. On the area of the 21st Corps, yes.
20 Q. But is --
21 A. Not all over Krajina. There's got to be some misunderstanding
22 along the line somewhere.
23 Q. Well, the misunderstanding is that in 1999 you said that you were
24 reporting directly to Zimonja and Pajic; now you're saying that you're
25 reporting only to Zimonja except when told by Zimonja to report do Pajic.
1 And in the Milosevic trial you said something different again. That is
2 the confusion I'm trying to get to.
3 A. Go ahead.
4 Q. Well, could you explain it?
5 A. What was the difference that I said during the trial in 2002?
6 Q. Well, in the Milosevic trial, you said triplicate reports; in
7 1999 you said duplicate reports.
8 A. And now I'm saying nobody? What you're suggesting --
9 Q. [Overlapping speakers] ... trying to work out what you are saying
11 A. I'm going to try to be as clear as I possibly can.
12 To understand the situation at the time, there were a lot of
13 people involved in there from a different services; from a State Security
14 Service, from the military intelligence, from a local police, and
15 everybody else wanted to know what was going on.
16 Now, my first response was to Colonel Zimonja. If, for example,
17 you knew in advance where the meeting is going to be held and who is
18 going to attend the meeting, then Zimonja might say, Well, this could be
19 of interest to Pajic as well, so make a report to him. And I would do
21 I don't see nothing strange.
22 Q. If that's your answer, we can move on. Thank you.
23 A. You're welcome.
24 Q. Well, actually, before we do move on --
25 JUDGE ORIE: I'm slightly concerned about what is then shown to
1 the witness. Do I -- the portion you were reading was apparently the top
2 of page 11 in the English. And that was not -- the relevant portion
3 apparently was not on the screen for the witness. And I'm always -- or
4 am I wrong? In his own language?
5 MR. JORDASH: I hoped it was because we did say page 10. So I'm
6 not sure if --
7 Q. Did you, Mr. Lazarevic, see the section of the statement I was
8 reading from?
9 A. Now you got me lost because we've seen so many
10 things [Overlapping speakers] ...
11 JUDGE ORIE: let's try to be very precise on that. It can be
12 that it is somewhere, but.
13 MR. JORDASH: Perhaps it would have been better if I just refer
14 to the English version since, Mr. Lazarevic ...
15 JUDGE ORIE: Well, there are more people who want to follow the
16 proceedings. So, therefore, it's -- of course, the witness is the most
17 important one to be able to follow. But the others, like the accused,
18 and those who are observing these proceedings.
19 I just want always that we verify whether what we see in English
20 is visible for the ...
21 I haven't found it in the B/C/S version, but ...
22 THE INTERPRETER: Interpreter's note: In the B/C/S version it is
23 the central paragraph -- no, on the page that was shown earlier. Begin
24 where the near 1992 appears. Except it's only the last portion of that
25 paragraph that we see in English, on top of the English page.
1 JUDGE ORIE: I see it now. It's ...
2 MR. JORDASH: Page 10.
3 JUDGE ORIE: Yes, it's in the middle of page 10.
4 MR. JORDASH:
5 Q. Have you got that, Mr. Lazarevic?
6 A. Yes, "In early 1992, the local and other ..."
7 Is that the one that you're referring to?
8 JUDGE ORIE: Yes. And then later in this paragraph, close to the
9 end well, let's say the last ten lines approximately, that's where you
10 talk about the -- apparently about the interpreters being on the payroll.
11 You found it? Where it says:
12 "The result was that every interpreter working..." [B/C/S spoken]
13 That's where you're supposed to read.
14 You found it?
15 THE WITNESS: No, unfortunately, I haven't.
16 JUDGE ORIE: Page 10 in the B/C/S.
17 THE WITNESS: Those translators had our strict ...
18 JUDGE ORIE: Yes, it's the line above that, I think, at least in
19 the sentence before that.
20 THE WITNESS: Well, in that case you have to go all the way up
21 there and you see there was an agreement between Toso Pajic and
22 Zimonja --
23 JUDGE ORIE: No, no, I'm just asking whether you found what was
24 put to you as your statement which apparently is the the line starting
25 with the result was that every interpreter ...
1 THE WITNESS: [Overlapping speakers] ...
2 JUDGE ORIE: Yes?
3 THE WITNESS: Yeah, have I got it.
4 JUDGE ORIE: Let's always be certain that if we put a statement
5 or whatever to a witness, that he is able to read it and that everyone is
6 able to follow what we are talking about.
7 MR. JORDASH: Yes. Thank you. Sorry about that.
8 JUDGE ORIE: Please proceed.
9 MR. JORDASH:
10 Q. Have you read it, Mr. Lazarevic?
11 A. Yes.
12 Q. Any further comments to make?
13 A. Yes, if you go back a few lines, you will find out there was an
14 agreement between Mr. Pajic and Mr. Zimonja about the reporting line
15 there, engaging the interpreters.
16 Q. Sorry, I don't follow your answer. Could you explain that a bit
17 further, please?
18 A. Okay. Let me just find the English version of it now.
19 There's a line that goes: Those translators I have evaluated in
20 Topusko in accordance with instructions from Pajic and Zimonja.
21 Q. Yeah.
22 A. So they were aware of each other trying to get the information.
23 But Zimonja was -- who would be in advance decide who gets the
24 information first.
25 Q. Why would --
1 JUDGE ORIE: And this is now found, apparently, on page 10 in the
2 English, if I ...
3 MR. HOFFMANN: [Previous translation continues] ... in the last
5 JUDGE ORIE: Yes.
6 MR. JORDASH:
7 Q. So you were suggesting in 1999 it was a joint operation between
8 Zimonja and Pajic, a joint operation to work - let's put it like that -
9 work the translators to obtain information for both of them?
10 A. I wouldn't call it a joint operation. That's suggesting two of
11 them decided it's going to be like that.
12 Q. Well you said --
13 A. What I'm suggesting is that information which was interested to
14 the police and there are information which are of interest to the
15 military. They are not always one and the same.
16 Q. Mr. Witness, Mr. Lazarevic, you said in 1999, according to your
18 "I screened these translators into Topusko under instruction from
19 Pajic and Zimonja, yes."
20 So you were suggesting it was direct and joint operation, those
21 two instructing you.
22 A. Now you are reading something that I never said.
23 Q. So you didn't say that it was under instruction?
24 A. No, no, I did say. But I'm not -- I have never mentioned that as
25 a joint operation between the two of them. You have to realise that -- I
1 was working basically two jobs there.
2 Q. Mr. Witness, let me ask you a question.
3 A. Sure.
4 Q. Did you say, as the paragraph states, they wanted to be in a
5 position to control all of the interpreters?
6 A. I don't see any conflict there.
7 Q. Did you say that? I'm just asking.
8 A. Yes.
9 Q. Thank you. Did you say: I forwarded these reports, along with
10 my own to Zimonja and Pajic?
11 A. Yes, I have.
12 Q. Thank you. Did you say that as a consequence of that or the
13 interpreters who were on the payroll of the SDB?
14 A. Yes.
15 Q. And now what you say is, in fact, I gave the reports to Zimonja,
16 and Zimonja made a decision about whether he gave any of the reports
17 to Pajic.
18 A. Yes, if it is relevant to Mr. Pajic.
19 Q. Okay. Let's leave it at that. I think we might have exhausted
20 the subject.
21 Was there any other KOS
22 years between 1991 and 1995?
23 A. Yes.
24 Q. Who?
25 A. I don't remember the names anymore, but there would be people
1 coming in uniform, JNA uniform, from Belgrade asking for me and telling
2 me Zimonja sent him. And I had no reason to doubt.
3 Q. Did you ...
4 JUDGE ORIE: Please proceed.
5 MR. JORDASH:
6 Q. Did you see the same KOS
7 wasn't there to receive the reports?
8 A. Not that I remember.
9 Q. So you always got a new KOS
10 Zimonja wasn't around?
11 A. More or less, yes.
12 Q. So, according to you, then, only Zimonja would be able to confirm
13 your important work for KOS
14 saying? Could anyone else?
15 A. There were a lot of people who knew me there, what I'm doing, and
16 how I'm doing, and everything else. I don't quite understand
17 [Overlapping speakers] ...
18 Q. [Overlapping speakers] ... would Toso Pajic know that you were a
20 A. I don't think so.
21 Q. How would he not know, given that you were acting on his and
22 Zimonja's behalf?
23 A. Because I was a liaison officer for the 21st Corps, and they both
24 needed me at the time.
25 JUDGE ORIE: Yes. If we continue this way, then I have to
1 introduce a different regime, that is, I'll tell you you can now put a
2 question; then I will give a sign that can you answer the question. But
3 this is an impossible way of proceeding.
4 Now, I give you a last chance to do it without my assistance as a
5 traffic agent, or conductor, whatever you want to call it. Last chance.
6 Otherwise, we really are going do split it up, because part of your
7 testimony will be lost. Overlapping speakers just doesn't work.
8 MR. JORDASH:
9 Q. When I asked you, Mr. Witness, how would Pajic not know, you
11 "Because I was a liaison officer for the 21st Corps, and they
12 both needed me at the time?"
13 Could you explain that, please?
14 A. At the time, police did not have their own liaison officer.
15 Toso Pajic got given this task much later as a liaison officer for the
16 police. So most of the time Toso Pajic relied on me to let him know what
17 is going on, in relations to international community. So ...
18 Q. But is this what you're suggesting to the Court, that, despite
19 being instructed by Pajic to take information from the interpreters,
20 despite seeing Pajic, I think you said five times a week, despite being
21 in the office when Pajic speaks to Stanisic, Pajic would not know you
22 were working for KOS
23 A. No I didn't --
24 JUDGE ORIE: No, no, one ...
25 If you look at me, I'll give you a sign.
1 Please answer the question.
2 A. No. There was no need what he should know. Officially, I was --
3 I was a liaison officer for the 21st Corps. My work concentrated on the
4 war for KOS
5 Toso, you know, I'm working for KOS
6 is simply not done.
7 MR. JORDASH:
8 Q. What about Colonel Kosta Novakovic? Would he know? Wasn't he
9 also working for the KOS
10 A. He worked for external [sic] security.
11 Q. I know. That's what you're saying --
12 JUDGE ORIE: Whoa ...
13 MR. JORDASH: Sorry.
14 Q. But Novakovic worked for internal security, yes?
15 A. That was my understanding.
16 Q. And Novakovic was Zimonja's superior?
17 A. Not that I knew of. That is news to me. If you claim that
18 Kosta Novakovic was a superior to Zimonja, no.
19 Q. So despite Novakovic working for the KOS, he wouldn't know about
20 you either?
21 A. No. I was not part of the internal security. You have to make a
22 difference there.
23 Q. Well, Colonel Milos --
24 A. My life I have spent outside of Yugoslavia working. So people on
25 the ground in Yugoslavia
1 am except those who I work with.
2 Q. Colonel -- you've given this diagram which we looked at earlier,
3 which I think is Exhibit 653, and you also named Colonel Petar Surla as
4 working for KOS
5 A. Correct.
6 Q. And Colonel Mlado Karan?
7 A. Mlado Karan. Correct.
8 Q. How was it that you knew about them working for KOS if they
9 didn't know about you?
10 A. I don't -- I don't get your question, really.
11 Q. Well --
12 A. Why they didn't know what I do and I knew what they do? Because
13 they were in position within the corps in a position of the -- of the
14 internal security for the military. That was their corps.
15 [B/C/S spoken].
16 THE INTERPRETER: Security officer.
17 THE WITNESS: Thank you.
18 Q. So the sum total then, is this a fair summary that no one can
19 confirm, other than you, that you worked for KOS?
20 A. Probably some people who are aware of that.
21 Q. Could you consist the Court so that we might then, from the
22 Defence, investigate?
23 A. I don't know. People who dealt with me.
24 Q. Can you give us some names to assist our investigation?
25 A. No, I can't remember any.
1 Q. Can't remember any?
2 A. Really, why don't you get in touch with Colonel Zimonja and ask
4 Q. So from 1968 until 1995 the only name you can give who might
5 assist is Zimonja?
6 A. Yes.
7 Q. Okay, fair enough. Let me ask you this about Mr. Pajic. You
8 said today, earlier - and I will try to quote you - at page 27 of the
9 draft transcript:
10 "As I have stated before, I had at least five times a week
11 meetings with Mr. Pajic because," something, "our work between the
12 military and police, as far as UN forces on the ground are concerned. So
13 quite frequently I would be in his office and I -- and he would tell me
14 like, you know," something, "will be here. And I was led to believe that
15 Daddy is Mr. Stanisic. He never actually, I have to be honest, he never
16 said directly, I am working for Stanisic. But he did do all the work.
17 It has been proven that he actually did work for Stanisic in the end."
18 Right? So Pajic never confirmed to you that he worked for
19 Stanisic. Am I correct?
20 A. Not in as many words.
21 Q. So in the -- well, how long were you working with Pajic?
22 A. Early 1991 -- I mean, late 1991 to 1995, the last person getting
23 out of Krajina at the time.
24 Q. So not once during that period did Pajic say to you he worked for
1 A. Never.
2 Q. No. And your confirmation of -- sorry, let me put that
4 What you said to the Court earlier today was that it was proven
5 that he actually did work for Stanisic because he ended up with an office
6 in the DB headquarters in Belgrade
7 A. Correct.
8 Q. And that's your evidence, that he worked for Stanisic?
9 A. Now?
10 Q. What's your evidence?
11 A. Well, my evidence is that what is happening on the ground, who
12 was reporting to, who was he talking to, who was he being visited by, who
13 we went -- who he went to see in Belgrade
14 Q. Well, at some point, he was a minister of the interior.
15 A. That's very late.
16 Q. Yeah. But he was, according to you, a member of the -- he was
17 the chief the police in -- in Vojnic; is that right?
18 A. Yes, I think so.
19 Q. Right. So you don't know what was discussed, if and when he went
20 to Belgrade
21 A. No.
22 Q. And what did he discuss when you were present during telephone
23 calls to Stanisic?
24 A. I wasn't really sitting there and spying on Mr. Toso Pajic. It
25 would just happen that he would have a telephone call.
1 Q. Mm-hm.
2 A. And he would have very brief answers on the phone. So I don't
3 know what the other side is saying to him. If the first side says, Yes,
4 yes, I understand, thank you, see you, bye, that's about it, that I can
5 convey to you from the content of conversation.
6 Q. So basically you cannot confirm the contents of the conversation
7 between Stanisic and Pajic, even though you were present?
8 A. No, you can only hear one side of it.
9 Q. Can you recall any of that conversation from the one side?
11 A. No, I can't.
12 Q. Okay. Thank you. You mentioned earlier today, I think after the
13 last break, that, on one occasion - is this right - you took a tape to
14 someone called Medo who, you say, worked for the DB?
15 A. Other way around. I was given a tape by Medo and returned it to
16 him after the meeting was done.
17 Q. Could you explain a little more? Where did you meet Medo, and
18 what was the tape he gave you?
19 A. In the office of the DB, in Belgrade
20 consisting of a tape which would be initiated by the sound, start
21 working. To take it to -- I believe it was Vukovar to a meeting with the
22 former German ambassador and to record the full conversation that I had
23 with him.
24 Q. So you attended the DB office in Belgrade and was given a blank
1 A. I was given the whole unit.
2 Q. The tape recorder?
3 A. Yeah. Which was built into a folder.
4 Q. And the instruction was to take that to Vukovar to record the --
5 A. To a meeting.
6 Q. To record the former German ambassador? In a meeting.
7 A. Yes.
8 Q. And what did you -- did you do that?
9 A. Yes.
10 Q. What did you do with the tape afterwards?
11 A. Brought it back to this person called Medo.
12 Q. And who instructed you to go to pick up the tape from Medo in the
13 first instance?
14 A. Zimonja.
15 Q. And how do you know that Medo worked for the DB?
16 A. That's what he said.
17 Q. What did he say then? Can you recall the words?
18 A. Yeah, I don't remember the words. But I was led to believe that
19 he represents the Sluzba Drzavne Bezbednosti, state security.
20 Q. What was recorded from the German ambassador? What was contents
21 of the tape?
22 A. I'm trying to think of it. I think the original, the whole idea
23 was to get in touch with him and talk about his liaison with the
24 journalist from "Duga" newspaper in Belgrade. That it was apparently his
25 girlfriend or something like that, to get as much as I can out of this
2 Q. Did you ever do that again for Medo?
3 A. No.
4 Q. Or the state security?
5 A. Not that I'm aware of. Now you got me doubting myself that Medo
6 was from the state security. I believe he was. I was taken to a
7 building which everybody knew was a state security building. With
8 somebody from military going in there, how the hell do I know?
9 Q. Did you ever do it again for the state security?
10 A. Not that I was aware of, no.
11 Q. Could I ask you please to turn to your --
12 MR. JORDASH: Can we have on the screen, please, the witness's
13 1999 statement, page 13 of the English version, and it's paragraph 4 of
14 page 13. I'm going need to some help with getting the B/C/S.
15 It's the -- sorry, it's not the diagram. It's the statement,
16 which is P -- sorry, it's not P anything. It's -- that's the one.
17 Now I want to have the B/C/S version too so that the witness can
18 follow it clearly. It's the paragraph beginning: "I was being paid by
19 both the RSK police/military and by KOS
20 A. I got the passage there.
21 Q. Right. There's a number of things which arise from this passage,
22 Mr. Lazarevic.
23 First, the first three sentences, or two sentences, three
24 sentences: "I was being paid by both the RSK police/military and by KOS
25 I was required to submit my reports to Petar Surla throughout 1992 and
1 1993. In 1993, he was replaced by Mlado Karan, who remained in charge of
3 Do you see that?
4 A. Yeah, I'm reading, sir, but I have no idea what is happening
5 here. Petar Surla left in 1992.
6 Q. Well, if -- did you -- this contradicts what you said earlier,
7 didn't it, about Surla and Karan not knowing that you worked for KOS?
8 A. No, they didn't.
9 Q. So you didn't say this to the Prosecution in 1999?
10 A. I'm looking at it. I don't remember saying it. In all honesty.
11 Looking at it, why would I say in 1999 that Surla was there in
12 1993 and in 1993 was replaced by Mlado Karan, which is totally incorrect?
13 Q. Well, if that's -- if you cannot explain, then, how it got into
14 your statement or why it hasn't been corrected in the very many
15 interviews you've had with the Prosecution since --
16 A. Nobody ever paid any attention to it. I haven't.
17 Q. Okay. Let's move on.
18 A. We're talking about 40-odd pages of very important material.
19 Q. Thank you. Let move on, Mr. Witness: "Surla and Karan sent all
20 of my reports to Zimonja in Belgrade
21 meetings were forwarded to a subordinate of Stanisic, who I knew only as
22 Medo. He would take the tapes directly to Belgrade."
23 A. -- surprise to you as much as it is a surprise to me. I do not
24 remember making this statement.
25 Q. Okay. Fair enough.
1 A. I'm looking at that time. There are so many inconsistencies in
2 that that I remember. First be, Mlado Karan and Petar Surla didn't work
3 together. They replaced each other in the 21st Corps. Secondly, I never
4 gave them anything to carry for me in Belgrade.
5 Q. Okay. If that's your -- you didn't say that to the Prosecution
7 A. No. You can squeeze my thumbs, but I don't remember saying it.
8 Q. Okay. Fair enough. Let's move on. And the point, then, about
9 "tapes of meetings being forwarded to a subordinate of Stanisic, who I
10 knew only as Medo," do you know how that got into your statement?
11 A. I remember one tape that I did for this person called Medo. I
12 don't remember a multitude of tapes been sent.
13 Q. Do you know how it got into your statement?
14 A. No, I don't.
15 Q. And then:
16 "He would take the tapes directly to Belgrade."
17 To -- from what you've told us, you went to Belgrade to give the
18 one tape to Medo?
19 A. Yes. This is it not happened in 1993.
20 Q. Yeah.
21 A. This particular case happen after the Krajina has fallen. I was
22 in Belgrade
23 Q. "It was Surla and Karan's decision what they would send to Knin."
24 Do you know how that got into your report --
25 A. No.
1 Q. No.
2 JUDGE ORIE: Mr. Jordash, I'm looking at the clock. We're close
3 to where we have to conclude for the day.
4 Could I inquire with you how much more time you would need?
5 MR. JORDASH: I would like an hour, if that's possible.
6 JUDGE ORIE: How much time would the Simatovic Defence need, as
7 matters stand now?
8 MR. BAKRAC: [Interpretation] Your Honours, at least two hours.
9 We have a large number of documents that we would like to present to this
10 witness, so we will not just chat here. We will have specific documents
11 to confront this witness with.
12 So we need at least two hours.
13 JUDGE ORIE: Mr. Groome, I've already three hours on the list of
14 wishes. What does that mean for the next witness to be called?
15 MR. GROOME: Your Honour, by our calculation, we're not going to
16 get to that witness so that we haven't brought that witness to The Hague
17 but they are readily available, if necessary.
18 JUDGE ORIE: No, it's -- my concern was the other way around, as
19 a matter of fact, that the witness would be here.
20 Under those circumstances, I think we -- we should endeavour to
21 conclude the testimony of this witness tomorrow. Three hours is a little
22 bit over two sessions. Let's -- let's try to -- to be as efficient as
23 possible and to see where we come.
24 Mr. Lazarevic, before we adjourn, I would like to instruct you
25 that you should not speak to anyone or communicate in any other way with
1 anyone about your testimony, whether that is what you have told us today,
2 or what you'll tell us tomorrow. Refrain from any communication or
3 conversation on your testimony.
4 We adjourn, and we'll resume tomorrow, the 9th of February,
5 quarter past 2.00 in this same courtroom, II.
6 --- Whereupon the hearing adjourned at 7.03 p.m.
7 to be reconvened on Tuesday, the 9th day of
8 February, 2010, at 2.15 p.m.