Tribunal Criminal Tribunal for the Former Yugoslavia

Page 12709

 1                           Wednesday, 13 July 2011

 2                           [Open session]

 3                           [The accused entered court]

 4                           --- Upon commencing at 9.02 a.m.

 5             JUDGE ORIE:  Could the witness be brought into the courtroom.

 6             Ms. Marcus.

 7             MS. MARCUS:  Yes, Your Honours, perhaps while the witness is

 8     being brought in I can just raise one issue.  We have not yet received a

 9     statement or any submissions in relation to the witness after next who

10     will likely start next week.  I just wanted to also point out on the

11     record:  Your Honours had issued an order to the Defence to disclose all

12     witness statements.  Of course, we have made extensive submissions on the

13     provisions of Rule 67(A)(ii), but even apart from that, Your Honour on

14     the 23rd of June had issued an order for them to disclose witness

15     statements.  As we have seen with the last witness -- with this witness

16     the statement was completed on the 1st of June and we received it on the

17     6th of July.  And with the next witness, the statement was completed on

18     the 29th of June and we received it on the 12th of July.

19             So the delay in the disclosures I just wanted to raise.  Thank

20     you.

21             JUDGE ORIE:  Mr. Jordash, perhaps you later respond to this,

22     later today, and we would avoid that the witness has to wait.

23                           [The witness entered court]

24             JUDGE ORIE:  Good morning, Mr. Bosnic.  I would like to remind

25     you that you are still bound by the solemn declaration you've given

Page 12710

 1     yesterday at the beginning of your testimony, and Mr. Jordash will now

 2     continue his examination.

 3             Mr. Jordash.

 4             MR. JORDASH:  Thank you, Your Honour.

 5                           WITNESS:  MILE BOSNIC [Resumed]

 6                           [Witness answered through interpreter]

 7                           Examination by Mr. Jordash: [Continued]

 8        Q.   Good morning, Mr. Bosnic.

 9        A.   Good morning.

10             MR. JORDASH:  Please could we have on the screen 65 ter 1557.

11        Q.   We were discussing, if you recall, Mr. Bosnic, the re-opening of

12     Golubic, and I just wanted you to quickly look at an exhibit and confirm

13     if it accords with your knowledge of Golubic re-opening.

14        A.   This is consistent with my knowledge of Golubic, at least in

15     part, because I don't know all the individuals concerned or all the

16     activities that took place at the school.

17        Q.   You confirmed yesterday that the Golubic which re-opened in and

18     around September 1992 trained ordinary police officers; is that correct?

19        A.   Yes.

20        Q.   Now, just looking at the front page, it notes there that the

21     session was not attended by council member Toso Paic.  You see that about

22     seven lines from the top?

23        A.   Yes.

24        Q.   You spoke about Toso Paic yesterday; do you recall that evidence?

25        A.   Yes.

Page 12711

 1        Q.   How well did you know him in 1991 and 1992?

 2        A.   Very well.  He was one of the leaders of the police station in

 3     Vojnic.  Later on, at my proposal, he became Martic's assistant in charge

 4     of Kordun.

 5        Q.   Why did you propose him in the way you testified?

 6        A.   Milos Pajic told me, and I knew from my conversations with him

 7     that he was a highly-trained policeman who had worked with our

 8     representation offices in New York and Paris, representing the then

 9     socialist Yugoslavia.

10        Q.   How often did you see him in 1991?

11        A.   Very often because we had meetings with representatives of the

12     police who, sometime until mid-1991, refused to accept Martic as a

13     secretary and continued maintaining their contacts with Zagreb.

14        Q.   This is the Vojnic police; is that correct?

15        A.   Yes, yes, from Vojnic and Vrginmost.

16        Q.   How often would you see him in 1992?

17        A.   Quite often as well.  We had meetings to co-ordinate between the

18     civilian authorities, the police, and the army.  At the time I was

19     president of the municipality of Slunj and deputy in the Assembly of the

20     Republic of the Serbian Krajina.

21        Q.   Did he ever mention to you having any links with the Serbian DB?

22        A.   No.

23        Q.   Did he ever communicate any wish or desire of the Serbian DB in

24     terms of the events in the Krajina?

25        A.   No.  Until mid-1991 he co-operated with Zagreb.

Page 12712

 1        Q.   Let's move to a slightly different subject.  I want to ask you

 2     about some Babic allegations concerning the police.

 3             MR. JORDASH:  And before I do that, may I tender 1557 as an

 4     exhibit, please.

 5             MS. MARCUS:  No objections.

 6             JUDGE ORIE:  Madam Registrar.

 7             THE REGISTRAR:  This would be D317, Your Honours.

 8             JUDGE ORIE:  And is admitted into evidence.

 9             MR. JORDASH:

10        Q.   Now, I want to ask you about something Babic spoke about in the

11     Milosevic trial.

12             MR. JORDASH:  P1878, e-court page 354.

13        Q.   And if I can just read the allegation that Babic made and then

14     I'll ask you to --

15             JUDGE ORIE:  Could I first seek to clarify a matter in relation

16     to the previous document.  You asked a question about Toso Paic and then

17     the witness said that he was one the leaders of the police station in

18     Vojnic and later on he became Martic's assistant.  And you said "Why did

19     you propose him?"  And then he said "Milos Pajic told me, and I knew from

20     my conversations with him that he was a highly-trained ..."  So then the

21     qualities of Milos Pajic are set out, at least there could be some

22     confusion.  First we were talking about Toso Paic.  Now we see during the

23     meeting that Milos Pajic was present.  He was also a SUP Vojnic official.

24     So I'm a bit confused by the answer "Milos Pajic told me, and I knew from

25     my conversations with him," and then his qualities are mentioned, which

Page 12713

 1     seems to be an explanation for him being appointed in a certain position.

 2             Now, was it -- is it Toso or is it Milos?

 3             MR. JORDASH:  Well, I think yesterday the witness -- the witness

 4     is itching to answer, so, perhaps, I don't know if that's the way to deal

 5     with it, if the witness could answer, or I can offer my ...

 6             JUDGE ORIE:  Yes, well, at least question and answer here are a

 7     bit confusing.

 8             MR. JORDASH:  Yes, yesterday the witness said that Milos Pajic

 9     had recommended Toso Paic to Martic.

10             JUDGE ORIE:  So the "he" now on page 3, line 8, it is -- we have

11     to read that "Milos Pajic told me, and I knew from my conversations with

12     him that 'Toso Paic' was a highly-trained policeman."  That is --

13             MR. JORDASH:  I think that's --

14             JUDGE ORIE:  -- how we have to understand that.  I see the

15     witness is nodding, so that's now clear to me.  Please proceed.

16             MR. JORDASH:  Thank you.

17        Q.   Page 354 in e-court, and I think we've got that now.  Now,

18     Mr. Bosnic, just listen to what Mr. Babic has said and then I will ask

19     you to offer any insight into its truth or otherwise.

20             Babic is asked the following question, line 10:

21             "Q.  Now, you were mentioning a moment ago that there were some

22     parallel military units set up by them and led by them, and my question

23     to you is the following:  Are you aware, do you know that as far as

24     Serbia is concerned - now I'm being quite specific here, Serbia - as far

25     as Serbia is concerned, paramilitary units were only set up by opposition

Page 12714

 1     parties?  Do you know that?"

 2             Babic's answer:

 3             "A.  I am aware of the fact that Serbia or, rather, you," that's

 4     Milosevic, "via Jovica Stanisic, Radmilo Bogdanovic, and Franko Simatovic

 5     nicknamed Frenki, formed volunteer units, detachments, in the SAO Krajina

 6     starting with April 1991, and I know that you," that's Milosevic,

 7     "instructed and linked up the Secretariat of the Interior or, rather, the

 8     police stations on the territory of SAO Krajina, and also that you,"

 9     Milosevic, "through them, set up special units, the ones that the

10     Assembly of Krajina, on the 29th of May, 1991, called the

11     Krajina Milicija, militia."

12             And then just reading on so you get the full picture.  Question

13     from Milosevic:

14             "Q.  So the formation of your Krajina police force you considered

15     to be the formation of a paramilitary formation."

16             Answer, page 13507:

17             "A.  It was a paramilitary formation because it was not under the

18     control of the government.

19             "Q.  How can the police SAO Krajina not be under the control of

20     the government?

21             "A. Well, in the way I explained.  It had the right of might and

22     was not subjected to a government that did not have sufficient might.

23             "Q.  All right.  And what about the Ministry of the Interior?

24     Was he at the head of the police force?"

25             And then line 12:

Page 12715

 1             "In such a way that this was done by force, because he didn't

 2     wish to hand over his authority which the DB of Serbia and he," that's

 3     Martic, "himself had set up, the structure he had set up."

 4             MR. JORDASH:  And if I may, just to complete the picture, read

 5     you another part of Babic's testimony so we know what we're talking

 6     about.

 7             MR. JORDASH:  Page 1878, e-court page 348, 26 of November, 2002.

 8        Q.   And again Babic is being cross-examined by Milosevic.  And at

 9     line 8, Babic, again with reference to this so-called parallel structure,

10     says:

11             "What they were doing," that's Martic and the parallel structure,

12     "was not the structure of the institutions which were legally elected and

13     established at multiparty elections.  They were structures which had

14     illegally cropped up, arbitrarily, on their own initiative, and that is

15     why I call them parallel structures to the legal institutions.

16             "And I said that Martic was elected as secretary of SUP.  But the

17     Assembly of Krajina, following a proposal by the Prime Minister --"

18             JUDGE ORIE:  You're reading, Mr. Jordash.

19             MR. JORDASH:  Sorry.

20        Q.   "... appointed him Defence Minister for SAO Krajina on the

21     29th of May.  And the very next day, having been convinced by Frenki and

22     people from the DB of Serbia, he," Martic, "refused to hand over to the

23     Ministry of the Interior --"

24             JUDGE ORIE:  Mr. Jordash.

25             MR. JORDASH:  "... and to the newly appointed minister, to hand

Page 12716

 1     over his office to Dusan Vjestica.  And in that way, it was through the

 2     force of might, because, together with the DB of Serbia, he had control

 3     over the armed formations of both the police force and paramilitaries

 4     which had been set up in the camp of Golubic in April."

 5             Did you follow that --

 6             JUDGE ORIE:  The French booth is -- makes an observation that you

 7     did not provide them with a copy of this document you're reading.

 8             MR. JORDASH:  It should be on the screen, I think.

 9             JUDGE ORIE:  Yes, but perhaps if there are longer portions to be

10     read it would be good to have them provided in hard copy as well.

11             MR. JORDASH:  Certainly.

12             JUDGE ORIE:  Please proceed.

13             MR. JORDASH:

14        Q.   So, I want to speak to you, Mr. Bosnic, about Martic and the

15     police and about the allegations that Babic made.  Did Martic attend

16     government session meetings?

17        A.   As far as I know, yes, that was his obligation.

18        Q.   Did Babic ever complain to you at the time that Martic didn't

19     attend government meetings?

20        A.   No.

21        Q.   For what purpose did Martic attend government meetings?  What was

22     his obligation?

23        A.   As any other member of the government, the obligation was to

24     attend government meetings, take part in discussions in all the items of

25     the agenda, and issue decisions that would subsequently be implemented in

Page 12717

 1     the field or forwarded to the Assembly.

 2        Q.   And as minister of the interior, was his obligation to report on

 3     issues relating to Golubic?

 4        A.   Yes.

 5        Q.   Would issues relating to the Ministry of Interior or the police

 6     force in general be subject to any debate or voting within the Assembly

 7     or the government?

 8        A.   Certainly.  In certain periods of time reports are submitted on

 9     the work of each and every minister, and eventually the Assembly is made

10     aware of it as well.

11        Q.   In relation to Golubic, you've mentioned in your statement that a

12     decision was made by the Serbian National Council to set up Golubic; is

13     that correct?

14        A.   Serbian National Council?

15             MR. PETROVIC: [Interpretation] Your Honours, I think that this

16     was misinterpreted to the witness.  And if Mr. Jordash would repeat it,

17     then I'm sure the witness will understand.

18             JUDGE ORIE:  Mr. Jordash, could you please repeat your question.

19             MR. JORDASH:

20        Q.   Paragraph 40 of your statement, it states that the decision to

21     set up Golubic in April 1991 was made by the Serbian National Council of

22     which Milan Babic was the president.

23        A.   Yes, the Serbian National Council - the B/C/S being "vijece" and

24     not "savjet" - yes, it was headed by Milan Babic.

25        Q.   And in paragraph 41 you say:

Page 12718

 1             "Milan Martic was not a member of the Main Board of the SDS or a

 2     member of the SDS.  He was the secretary of the SUP, nominated by Milan

 3     Babic, and thus a member of the government?"

 4             Do you know how many government sessions were held in and around

 5     May and June and July and August of 1991?

 6        A.   Well, I don't know, but I suppose that it was frequent, given the

 7     situation prevailing in the field.

 8        Q.   Well, you say you suppose it was frequent.  Could you try and

 9     give some indication, from things you saw or heard, as to whether it was

10     frequent?

11        A.   Well, I do believe that it was frequent.  Some -- every seven,

12     eight, or ten days.  I know that these individuals came to Knin even more

13     frequently than just to attend Assembly sessions.  They had meetings and

14     consultations.

15        Q.   Did you speak to members of the government during the time we're

16     discussing, April to August of 1991, concerning the training at Golubic,

17     the setting up of the Krajina Milicija, and Martic?  Did you hear any

18     conversation about that or did you have any personal discussions?

19        A.   All of us took part in these discussions, and I mean the

20     political leadership, because we were looking for a way to resist the

21     National Guards Corps and special units of Croatia in view of the fact

22     that we didn't have trained personnel.  We were trying to find solutions

23     to the problem.  The incursion at Plitvice was the straw that broke the

24     camel's back.  That's why it was decided to ask from the Ministry of the

25     Interior of Serbia and the Government of Serbia to provide assistance in

Page 12719

 1     training young individuals, with a view to setting up a unit that would

 2     be capable of successfully resisting the Croatian forces.

 3        Q.   You say at paragraph 41 of your statement:

 4             "If Milan Babic --

 5             MR. PETROVIC: [Interpretation] Your Honours, I apologise for

 6     interrupting.  I'd like to intervene in the transcript.  The witness did

 7     say who took this decision that he is referring to, but that's not

 8     reflected in the transcript.

 9             JUDGE ORIE:  We'll have this verified.  You mean the decision

10     which appears at page 10, line 17?

11             MR. PETROVIC: [Interpretation] Yes, Your Honour.

12             JUDGE ORIE:  Witness, you said that a decision was taken to

13     provide assistance in training young individuals.  And who took that

14     decision seeking assistance from the Ministry of the Interior of Serbia

15     and the Government of Serbia to provide assistance?  Who took that

16     decision?

17             THE WITNESS: [Interpretation] The Serbian National Council.  And

18     it was signed and forwarded to Belgrade by Milan Babic.

19             JUDGE ORIE:  Thank you.

20             Please proceed.

21             MR. JORDASH:

22        Q.   Do you know who it was forwarded to?

23        A.   To the Government of Serbia and the Ministry of the Interior of

24     Serbia.

25        Q.   Do you know who in the Ministry of Interior?

Page 12720

 1        A.   Presumably to the minister.  I suppose that the president of the

 2     Serbian National Council addressed the minister, and I think that it was

 3     Mr. Bogdanovic at the time.

 4        Q.   Now, you make mention in your statement that if Milan Babic had

 5     not accepted Milan Martic, he would not have gotten the post, the post of

 6     the minister of interior.  Was it possible -- let me just rephrase that.

 7             Was the continuation of a post in the Government of the

 8     SAO Krajina subject to votes within the government?

 9        A.   Yes.  After the SAO Krajina, if that is what you mean, was

10     declared the Republic of the Serbian Krajina, the ministers were again

11     elected and so was the government, and as Babic had been proclaimed the

12     president of the Republic of the Serbian Krajina, if that is the period

13     that you're referring to.

14        Q.   Had Babic wanted to get rid of Martic in 1991, what would have

15     been the process by which he would have gone about doing that?

16        A.   Well, he should have either proposed a reconstruction of the

17     government or a new cabinet.

18        Q.   Sorry, I'm not -- let me repeat the question.

19             If Babic had wanted to get rid of Martic in 1991, what would have

20     been a process by which he would have gone about doing that?

21        A.   He would not have proposed his remaining as member of the

22     Government of the Republic of the Serbian Krajina on the 19th of December

23     in 1991.  But he was in favour of Martic's remaining, and Martic did

24     remain minister of the interior in the Republic of the Serbian Krajina.

25        Q.   Sorry, what's the significance of the 19th of December, 1991?

Page 12721

 1        A.   The Republic of the Serbian Krajina was proclaimed.

 2     Conditionally speaking, the SAO Krajina was abolished and the Republic of

 3     the Serbian Krajina was declared in order to keep abreast of Croatia's

 4     demands, and Croatia was pursuing independence.

 5        Q.   Were those who held government posts at the time of the

 6     proclamation subject to re-election?

 7        A.   Not all of them.

 8        Q.   Was Martic?

 9        A.   Yes, he was, and he was re-elected.

10        Q.   What was the process by which he was re-elected?

11        A.   The prime minister designate, who was a representative of the

12     SDS, was given a mandate by Milan Babic to form a government, and at the

13     Main Board there were meetings, there were discussions, about the

14     composition of that government.  That was accepted and was as such

15     referred to the Assembly, where it was properly -- where the proper

16     procedure was conducted and they were elected.

17        Q.   Who was the prime minister designate?

18        A.   Risto Matkovic was the prime minister designate, but essentially

19     it was Babic.  It was Babic and we, members of the Main Board, who

20     discussed the members of the government at our session.

21        Q.   Were you present at the Main Board during the discussions about

22     the re-election of Martic?

23        A.   There was no discussion at all, in fact.  Babic only said or,

24     rather, proposed that Milan Martic should be the minister of the

25     interior.

Page 12722

 1        Q.   Did Babic express any misgivings or doubts or in any way appear

 2     under pressure about that decision?

 3        A.   No, not in a single moment.  This could not be discerned at all

 4     and he never said anything of the kind.  So it was quite clear that there

 5     had been no pressure exerted on either him or anyone else in that regard.

 6        Q.   Now let's return to your statement, D313, and paragraph 56, where

 7     you talk about the Knindzes.

 8             While that's coming up:  Just to wrap up the last issue, why, as

 9     far as you could see, did Babic propose unambiguously for Martic to be

10     re-elected?  Do you know the reason for that?

11        A.   Well, from the very beginning of these events, these people from

12     Knin who knew each other prior to the events and from before, so these

13     were people who knew each other from before, and I believe that

14     Milan Babic trusted him.

15        Q.   And did you know Dusan Vj estica, the man Babic claimed Martic

16     refused to hand over his office to?

17        A.   Yes.

18        Q.   Are you able to cast any light on Babic's allegations in that

19     regard?

20        A.   I was not at that Assembly session as I was not an MP at that

21     time, and Babic came up with the idea that a civilian should assume

22     control of the MUP and that Milan Martic should be the minister of

23     defence.  However, when this decision reached the people in the field,

24     members of the police actually would not accept Vjestica as minister.

25     They even said that he had had a falling out with the law.  I don't know

Page 12723

 1     anything about that, mind you.  But soon after that the situation was

 2     restored to normal and Martic was again the minister of the interior.

 3        Q.   Are you able to give some names of people who were in the field

 4     or members of the police who would not accept him as a minister?

 5        A.   I do not know the name of the secretaries of the police stations

 6     in the various municipalities.  That was not within my remit.  But as far

 7     as I know it was all the secretaries of the police stations in the areas

 8     of Lika and Northern Dalmatia.

 9        Q.   Okay.  Let's move to the Knindzes.  Were you aware of -- well,

10     you clearly were aware of a group known as the Knindzes during 1991?

11        A.   Yes, I was.

12        Q.   Could you give the Court some assistance in relation to the size

13     of the Knindzes, how many people formed the Knindzes?

14        A.   I don't know exactly.  It was a small group, some 30-odd people.

15        Q.   At what point did these 30-odd people become visible to you and

16     other politicians in the region?

17        A.   Well, they became visible after the first actions which took

18     place in the area of the Krajina in which they participated.

19        Q.   Which action or actions were those?

20        A.   Well, there was the action in Glina, in Skabrnja, I believe in

21     Bruska.  That's it, more or less.

22        Q.   That's it, more or less.  Do you know, and I want you to think

23     carefully, apart from Glina and Bruska, are you aware of any other place

24     where the Knindzes participated in combat during 1991?

25        A.   Right now I cannot recall whether there had been any other ones.

Page 12724

 1     It is quite possible.

 2        Q.   Now, you don't know this but I can tell you this, that in

 3     Mladic's diary in 1991 the Knindzes are not mentioned.  Is that a

 4     surprise to you in terms of military issues and what was going on on the

 5     ground militarily, the Knindzes don't warrant a mention in Mladic's

 6     diary?

 7        A.   Well, it is surprising because all military operations which were

 8     taking place in the area were in concert, i.e. -- concert with, i.e.,

 9     under the command of, the JNA.

10        Q.   Did you at the time, you and your colleagues, think of the

11     Knindzes as a significant military force?

12        A.   In the moral [as interpreted] sense.

13        Q.   What do you mean by that?

14        A.   That a unit had appeared which was successful, which was taking

15     part in successful operations in co-ordination with units of the

16     Yugoslav People's Army, and that it was a sort of a basis for future

17     sources that would be set up throughout the SAO Krajina, which was later

18     to become the Republic of the Serbian Krajina.

19             MR. JORDASH:  Could we have, please, P2659.

20        Q.   Why do you use the word "moral" in this context, Mr. Witness?

21        A.   Because our people were afraid.  We were afraid that the

22     incursions of the special units of the Croatian police or the

23     National Guards Corps would entail crimes, because we had a negative

24     experience from the period of the Second World War when our people were

25     defenceless.

Page 12725

 1             THE INTERPRETER:  Interpreter's correction:  The word was

 2     "morale."

 3             JUDGE ORIE:  And the correction relates to page 16, line 4, the

 4     sense of morale, is that ...

 5             THE INTERPRETER:  Yes, Your Honour.

 6             JUDGE ORIE:  Thank you.

 7             Mr. Jordash, please proceed.

 8             MR. JORDASH:  Thank you.

 9        Q.   This is a speech given by Captain Dragan.  You've commented on it

10     at page 4 of the chart, D315, and I just want to ask you about some of

11     what Captain Dragan said.

12             If we can -- do you remember this exhibit, Mr. Bosnic?

13        A.   Yes.

14             MR. JORDASH:  Let's go to page 2 of the English and page 3 of the

15     B/C/S.

16        Q.   And at the bottom of the English page, Captain Dragan says:

17             "I'm not saying that some other units did not take part in this

18     operation."  And he's referring to the operation in Glina.  "After all,

19     that was a big operation, so-called stinger operation.  That was a

20     continuation of wasp operation, where the aim was to clear the

21     MUP forces."

22             Do you have that, Mr. Bosnic?

23        A.   Well, it is the third page actually here and you said that in

24     Serbian it was the second page.

25        Q.   Oh, I beg your pardon.  Do you have the section?  It's two-thirds

Page 12726

 1     of the way down the page, I think, or perhaps not.  It's the section

 2     where the heading should say:

 3             "Journalist:  Would you like to say something about officer

 4     Grujica Boric?"

 5        A.   Could we go back to page 3.  After all, I can see it in the

 6     English but not in the Serbian.

 7        Q.   It is page 3, you're right, in the B/C/S.  I can see it.

 8        A.   Yes, I have found it.

 9        Q.   Okay.  Just read through that to yourself, please, and I'll then

10     ask you --

11        A.   [No interpretation]

12        Q.   From the point where the journalist asks a question and

13     Captain Dragan says "Just before I move to that issue."

14        A.   "The journalist:  Would you like to say something about officer

15     Grujica Boric?"

16        Q.   Just read it to yourself, please.

17        A.   I just wanted to check whether that was it.

18        Q.   Yes, that's it.

19        A.   I've read it.

20        Q.   And if we go over the page, Captain Dragan describes the

21     operation or an operation concerning Glina, and you'll see there where he

22     talks about 21 men from Knin.  Do you see that?

23        A.   Yes.

24        Q.   Do you know if that figure represents the -- at that time the

25     full complement of the Knindzes?

Page 12727

 1        A.   I cannot claim that with certainty.  I said that there were some

 2     30 of them.  I never counted.  And we never asked for the actual number.

 3     I suppose that there were only a few of them and they were used more to

 4     boost morale than for other purposes, and had they been a larger unit,

 5     they would have been much more visible, that's for sure.

 6        Q.   Did you see them in -- moving around?

 7             JUDGE ORIE:  Where and when, Mr. Jordash?

 8             MR. JORDASH:

 9        Q.   In the areas that Mr. Bosnic was active and in 1991?

10        A.   Never, on no occasion did I see the mentioned unit in Kordun.

11     Never ever.

12        Q.   Did you speak to Babic about the Knindzes at any stage?  Did he

13     complain about the Knindzes?

14        A.   Not up to the point when Captain Dragan gave a statement which

15     had to do with politics or the incompetence of the SDS or something along

16     those lines, some statement of Captain Dragan along those lines.  Babic

17     interpreted that as Captain Babic's [as interpreted] attempt to interfere

18     in political events in the Krajina.

19             MR. JORDASH:  Could we have, please, on the screen 03879.  It's

20     another exhibit relating to Captain Dragan.  In the chart it's D298.  And

21     it's page 4 of the chart.

22             JUDGE ORIE:  When you talked about an attempt to interfere in

23     politics in the Krajina, you were referring to Captain Dragan, were you?

24             THE WITNESS: [Interpretation] Yes, yes.  Yes.

25             JUDGE ORIE:  Please proceed.

Page 12728

 1             MR. JORDASH:

 2        Q.   When was that, Mr. Witness?  When did Captain Dragan give a

 3     statement which had to do with politics?

 4        A.   I believe that was after these operations in Glina or

 5     thereabouts.  I cannot be a hundred per cent sure, however.

 6        Q.   When was that?  When were the operations in Glina?

 7        A.   At the end of June or July.

 8        Q.   Thank you.  Now, this is a portrait, as we can see, of

 9     Captain Dragan.  It's dated July of 1991.  And the author was an

10     Aleksandra Plavevski.  Do you know that person?

11        A.   No.

12             MR. JORDASH:  Now, just let's go to page 2 of the English and

13     stay with page 1 of the B/C/S.

14        Q.   And it's noted, under the title "discipline":

15             "Now, the defenders of the SAO Krajina have highly-mobile assault

16     units ready to act in any part of the territory within only 50 minutes.

17     Special purpose units are positioned in all strategic places in the

18     Krajina, which is now defended in the outer rim areas.  They have all the

19     weapons they need, including artillery.  Preparations are well underway

20     for the foundation of their own navy and air force."

21             What do you think about that, Mr. Bosnic?  Do you have any

22     comment on that journalism?

23        A.   My comment is the same:  This is just nonsense.  I have no better

24     word to describe this with.  What aircraft are we talking about?  Come

25     on.

Page 12729

 1        Q.   What about "highly-mobile assault units ready to act in any part

 2     of the territory within only 50 minutes"?

 3        A.   I wish.  Had we had such units, we would have reached Austria and

 4     I would not have ended up in Pancevo as a refugee.

 5        Q.   Reading on:

 6             "Captain Dragan says that the goal of his units is to lend

 7     maximum support to the Yugoslav People's Army, whose legitimacy they

 8     recognise fully and which they are ready to defend if required.  The

 9     function of the special unit is to support the army and the police of the

10     Krajina, and their task is to neutralise the enemy and to eliminate them

11     from the territory of the SAO Krajina if need be."

12        A.   This clearly demonstrates that Captain Dragan is confirming what

13     all of us knew and what I have said here, that no military operation

14     could have been carried out without co-ordination with the

15     Yugoslav People's Army.

16        Q.   Did -- sorry, were you going to say something?

17        A.   And without the knowledge of the Yugoslav People's Army.  There

18     was no possibility for independent military action.

19        Q.   Did Captain Dragan, as is claimed here, have units, in the

20     plural, or just a unit, as far as you're concerned, as far as you were

21     aware?

22        A.   As far as I'm aware, Captain Dragan had just this one unit which

23     was called the Knindzes and which had specific patches, the Serbian coat

24     of arms with the four Ss turned upside-down or in the other -- facing the

25     other direction from the regular one.

Page 12730

 1             JUDGE ORIE:  Mr. Jordash, could we please better explore the

 2     basis of the knowledge of the witness.

 3             You said you had never seen them.  How do you know about their

 4     patches?

 5             THE WITNESS: [Interpretation] I never saw them in action, but

 6     these men who completed their training and returned to the area of Kordun

 7     wore the uniforms of the Krajina Milicija.  And I saw Captain Dragan in

 8     Knin and I also saw a man by the nickname of Cigo and I saw the commander

 9     of the armoured train, his name was Blagoje Guska, and they wore these

10     uniforms and they had red berets.

11             JUDGE ORIE:  Yes.  Now, let me try to understand your testimony.

12     You said you saw these men who had completed their training and returned

13     to the area of Kordun wearing these uniforms.  Now, in your written

14     statement you are talking about part of the first group that was trained

15     in Golubic stayed there to train others, and you said that was the group

16     known as the Knindzes, and they became a special unit of the police.

17     Then you described where they came from, that they participated in combat

18     on the territory of Dalmatia and Lika if necessary, and that they

19     participated in an operation in Glina, and you said they were never in

20     Kordun.  Apparently describing the patches, you are talking about people

21     that were trained, not part of the first group but apparently a follow-up

22     group, who went back to Kordun.  You described their patches, although

23     you say Knindzes, that was the first group that in part stayed for

24     purposes of training others, I take it that these are your volunteers,

25     and they later participated in combat actions and they never came to

Page 12731

 1     Kordun.  When I ask you how you knew about the patches of the Knindzes,

 2     you tell me that you saw them at the uniforms of people who came back to

 3     Kordun, but that is not the group which in your written statement is

 4     described as the Knindzes.  So I'm totally confused by what you are

 5     telling us.

 6             Mr. Jordash, if you could create any clarity in this respect.

 7     And the reason why I ask for the basis of the knowledge is that of course

 8     the witness says, I assume that there were little - without or what that

 9     assumption was based is rather unclear at numbers.  He never counted

10     them, he never got reports about the numbers, so he assumes that they

11     were smaller numbers.  Why he does assume so is -- again, is also totally

12     unclear to me.

13             So it's -- this is just an example of what I find confusing at

14     this moment.  And if you could clarify it, that certainly would assist me

15     and hopefully my colleagues as well.

16             MR. JORDASH:  Certainly.  I'll do my best.

17        Q.   You followed the President's query, Mr. Bosnic?  Let's try to

18     break it down.

19        A.   Yes.

20        Q.   Do you include within the Knindzes those who were trained at

21     Golubic who then returned to, for example, Kordun?

22        A.   No.  They were members of Martic's Police.  That's how they were

23     called.  Only those who stayed back in Knin under Captain Dragan's

24     command, in other words, the best men of those who had trained, were

25     under his command.  And that's why they had, being the Knindzes,

Page 12732

 1     different sort of uniforms.

 2        Q.   And those who did not stay in Knin under Captain Dragan's

 3     command, where did they operate from?

 4        A.   They operated from the municipalities whence they had originally

 5     come, and they were under the command of the MUP of the Krajina, in other

 6     words, Mr. Martic.

 7        Q.   And what uniforms did they wear?

 8        A.   They had blue camouflage uniforms with a large sign saying

 9     Milicija Krajina, Krajina's Police.

10        Q.   And did you see that?  Did you see the uniform?  Did you see

11     Krajina's Police wearing that uniform?

12        A.   Yes, I saw Ilija Saula, Medakovic, and others.

13        Q.   Now, putting that group of people aside and returning to the men

14     in Knin under Captain Dragan's command, where were they based in 1991?

15        A.   They were stationed in Golubic, and Captain Dragan was in the

16     Knin fortress.

17        Q.   Did you actually see that group in Golubic or outside of Golubic?

18        A.   The individuals that I named I saw in town.  As for those others,

19     I heard about them at the meetings where we discussed these issues.  But

20     the three individuals I mentioned before were ones that I saw in town,

21     and that's why I can tell you what their uniforms were like.  But I

22     didn't see them in action.

23        Q.   Which three individuals did you see?

24        A.   Captain Dragan; Blagoje Guska, who was the commander of the

25     armoured train which was part of the Knindze unit; and a local, a man

Page 12733

 1     they referred to as Cigo, I forgot his last name.

 2        Q.   Now, you saw those three and then you said that you also

 3     discussed the others at meetings.  Which meetings were these men the

 4     subject of discussion?

 5        A.   When it was said that the training at Golubic was successful in

 6     churning up a small number of individuals from the general area who would

 7     make up this special unit, whereas others were to remain -- to go back to

 8     the areas they had originally come from for that specific training in

 9     Knin.

10             JUDGE ORIE:  Mr. Jordash, would you mind to go back now to the

11     original question where it all started.

12             What patches then did these Knindzes have?  Not the ones who

13     returned to their own locations, but where you said you saw three of them

14     in town.

15             THE WITNESS: [Interpretation] They had camouflage uniforms but

16     they were military uniforms, green.

17             JUDGE ORIE:  I wasn't asking about uniforms.  I was asking about

18     patches on the uniforms.  Could you describe those?

19             THE WITNESS: [Interpretation] The Serbian coat of arms but one

20     where the Ss are facing away from each other, whereas normally they would

21     be facing one another.

22             JUDGE ORIE:  Did they wear red berets?

23             THE WITNESS: [Interpretation] Yes.

24             JUDGE ORIE:  On what is your knowledge based that there was only

25     one unit and not several units of these Knindzes?

Page 12734

 1             THE WITNESS: [Interpretation] Well, at the meetings we discussed

 2     only this one unit.  I didn't have any information to the effect that

 3     there were any in Banija and I knew that there weren't any in Kordun.

 4     Had there been any other units of the sort, we would have known it.  We

 5     were politically active and had contacts at these meetings with

 6     representatives of the police and the army.  There was never any mention

 7     of units other than this one.

 8             JUDGE ORIE:  Yes.  But you have no positive knowledge, it's just

 9     what you discussed and that you never discussed more than one unit, you

10     never saw more than one unit, so therefore you assume that it was one

11     single unit; is that correctly understood?

12             THE WITNESS: [Interpretation] I am certain to a great extent

13     because I travelled the area and I had never heard of another unit

14     existing.  But in substance, my answer to what you just said is yes.  The

15     travels I made in the area would have put me on notice of the existence

16     of another such unit.

17             JUDGE ORIE:  Yes.  It's at least clear from where your level of

18     certainty derives.

19             Please proceed, Mr. Jordash.

20             MR. JORDASH:

21        Q.   Who were you talking to at that point in time who you might have

22     expected to hear about the existence of more than one unit?  Please give

23     a selection of people who you might have expected to hear that from but

24     didn't.

25        A.   For the area of Kordun, I would certainly have heard it from

Page 12735

 1     Milos or Toso Paic, from the commanders of TO staffs, or representatives

 2     of the JNA at the meetings I attended.  At times there were discussions

 3     about actions that had been conducted, but there had never been any

 4     mention of another special unit, hence my opinion that there could not

 5     have been another one.

 6             JUDGE ORIE:  Your opinion was that there was not another one.

 7     I'm just trying to understand.  If not -- if there was no conversation

 8     about a second unit, to conclude that there could not be one is quite a

 9     different opinion from that there was not another one.

10             And, Mr. Jordash, I'm really concerned about mixing up opinions,

11     assumptions, facts known to the witness.  Could you please try, in what

12     now follows, to always clearly distinguish between knowledge of facts,

13     personal observation, or hearsay so that it's always clear what we are

14     hearing.

15             MR. JORDASH:  But I --

16             JUDGE ORIE:  If you say "I never heard talking about it, so there

17     could not have been another one," that's a kind of an opinion which

18     really doesn't assist the Chamber.  But if you say I have no reasons to

19     believe that there was another one, that's fine.  That's a conclusion you

20     can draw.  But to say that it was never discussed so that on that is

21     based my opinion that there could not be another one is of course

22     something totally different.  I take it that you're aware of that.

23             MR. JORDASH:  Well, I'm --

24             JUDGE ORIE:  The one excludes a possibility and the other one

25     leaves it open that there may have been or there may not have been but --

Page 12736

 1     yes.

 2             MR. JORDASH:  Well, I think there's overlap between the two

 3     depending upon where the witness received his -- what conversations the

 4     witness had.  There comes a point when the number of conversations the

 5     witness has had about a unit reaches the point where the witness can be

 6     certain there wasn't more than one unit.

 7             JUDGE ORIE:  It is a kind of a conclusion which is not --

 8     unless -- you need a lot of factual bases before you can come to such a

 9     conclusion, and not just a few conversations here and there in a

10     relatively large area where a unit apparently is 30 people, 30 to 40.

11     But let's not end up in a discussion.  I tried to explain what was on my

12     mind.

13             MR. JORDASH:  Well, the witness has described the basis for his

14     opinion, as Your Honour sees it, and I'll move on.

15             JUDGE ORIE:  Yes, please do so.

16             MR. JORDASH:

17        Q.   Well, perhaps I should try to clarify it since it's still on the

18     basis of opinion.  Let's break it down, Mr. Bosnic.  You spoke to

19     Toso Paic; why would you have expected him to mention if there was more

20     than one unit?

21        A.   Well, representatives of the civilian government and the SDS

22     would have been informed of a unit appearing in the area of Kordun coming

23     from elsewhere.  We attended meetings of the zone TO staff where no other

24     unit had been mentioned.  After the operation Slunj, Mr. Cedo Bulat only

25     referred to TO and JNA units.  The TO Vojnic, Plaski, and Korenica units,

Page 12737

 1     as well as the JNA and police units from these areas.

 2        Q.   Same question:  Milos Pajic; what would you expect him to have

 3     said and why would you have expected him to say if there was more than

 4     one unit?

 5        A.   Because it would have been an obligation on his part to make

 6     aware us, representatives of the civilian authorities, of the appearance

 7     of a unit in the territory where we were politically active.  For

 8     instance, I was active in the territory of the -- of Kordun.

 9        Q.   Same question in relation to commanders of the TO staffs; what

10     kind of discussions were you having with them where you might have

11     expected there to have been mention of more than one unit?

12        A.   Because Milan Babic had appointed them to these posts.  We had

13     meetings of the civilian authorities, TO, and the police discussing the

14     general situation in Kordun.

15        Q.   And finally:  Which meetings involved the representatives of the

16     JNA wherein you might have expected to hear about more than one unit?

17        A.   In October of 1991 I became a member of the zone staff charged

18     with providing information.  I became director of radio and television

19     Petrova Gora.  Where military and other issues were discussed, I would

20     attend these meetings, as well as others, Mr. Paspalj and Cedo Bulat who

21     was the head of the military training-grounds Slunj.  And the elements of

22     the command structure of the 5th Military District was there.  So

23     Cedo Bulat and other officers, Mirko Radak, would also attend these

24     meetings.

25        Q.   And what did the meetings involve?  What was the purpose of them?

Page 12738

 1        A.   To see how the TO could help man JNA units, to see what their

 2     strength was, what the general situation was in the area covered by the

 3     zone staff, what the situation was like for the population, and the

 4     developments in the area in general.  The zone staff also covered Banija

 5     at the time; in other words, it was the zone staff for Kordun and Banija.

 6             MR. JORDASH:  Your Honour, I notice the time.  I've only got

 7     about 10 minutes, if Your Honour would allow that, after the break.

 8             JUDGE ORIE:  Yes, I'm -- of course, primarily, we take the

 9     75 minutes instead of the usually 90 because of Mr. Stanisic.  If

10     Mr. Stanisic would enable you to have the next ten minutes, then of

11     course it's fine as far as the Chamber is concerned.

12             MR. JORDASH:  To be honest, I would rather have a break just so

13     that I can gather the material and be efficient after the break if

14     that's ...

15             JUDGE ORIE:  That's -- yes, that's -- I'm not going to say it's

16     fine, but it's accepted.

17             MR. JORDASH:  Thank you.

18             JUDGE ORIE:  We take a break, and we resume at ten minutes to

19     11.00.

20                           --- Recess taken at 10.22 a.m.

21                           --- On resuming at 10.54 a.m.

22             JUDGE ORIE:  Mr. Jordash.

23             MR. JORDASH:  Thank you.

24        Q.   Mr. Witness, I want to just very briefly discuss a period around

25     the time of the Vance Plan negotiations.

Page 12739

 1             MR. JORDASH:  Please could we have on the screen 65 ter 1385.

 2        Q.   What is going to come up on the screen are minutes or a

 3     stenographic record of the 188th Session of the Presidency of the

 4     Socialist Federative -- Federal Republic of Yugoslavia, held on the

 5     25th of February, 1992.  And you can see there who attended the session.

 6     And you can see there the participants included Petar Gracanin, federal

 7     secretary of the interior.

 8             Now, did you attend this session or were you privy to the

 9     preparations for the session or the subjects that were discussed during

10     the session?

11        A.   This has to do with Vance Plan.  You said Vance-Owen Plan,

12     whereas it's the Vance Plan.

13             I didn't attend this Presidency session.  But in the capacity of

14     the Presidency of the Assembly of the Republic of the Serbian Krajina, I

15     attended several meetings of the Presidency where the Vance Plan was

16     discussed.  This is already at the stage where the Vance Plan is being

17     accepted, in preparation of the Assembly session which was to take place,

18     I believe, in Borovo Selo.

19        Q.   And Mr. Babic's position was that he opposed the Vance Plan; is

20     that correct?

21        A.   Yes, absolutely.

22        Q.   And did you agree with that position?

23        A.   I did, and I suppose that was the reason why I was chosen to be

24     part of the delegation of the RSK, one of the seven delegates taking part

25     in the negotiations in the Presidency of Yugoslavia in late 1991 and

Page 12740

 1     early 1992.

 2             MR. JORDASH:  Let's go to page 8 of the English and 8 of the

 3     B/C/S.  And we can see there that Petar Gracanin is speaking.  Now, just

 4     now we've oriented ourselves with who is speaking.  Let's move on to

 5     page 11 of the English and 11 of the B/C/S.

 6        Q.   And halfway down the English page Petar Gracanin notes:

 7             "As for the Internal Affairs organs in the Republic of

 8     Serbian Krajina, we need to find a proper balance there, from the request

 9     from these 34.000 people, and what we did on Saturday and Sunday together

10     with their organs, but these are organs that were consulted more from the

11     legal aspect, and a balance should probably be found there.  We gave

12     around 4.000 for the entire --"

13             JUDGE ORIE:  You are --

14             THE WITNESS: [Interpretation] Please scroll down.

15             MR. JORDASH:  Sorry, Your Honour.

16        Q.   "We gave around 4.000" ...

17             JUDGE ORIE:  Please proceed.

18             MR. JORDASH:  Thank you.

19        Q.   "We gave around 4.000 for the entire area, but that is just the

20     core.  We should look to find a middle way where the police force is

21     needed."

22             So we have the Federal Secretary of the Interior talking about

23     giving 4.000 people for the entire area of the Republic of

24     Serbian Krajina.  "We should look to find a middle way where the police

25     force is needed."  Are you able to cast any light on what the federal

Page 12741

 1     secretary of interior is talking about?

 2        A.   This is one of the provisions of the Vance Plan, which reads that

 3     in the area of the RSK or, rather, in the UN-protected area, the only

 4     presence allowed is that of the police force, and now discussions are

 5     taking place about the strength of the police force that should remain in

 6     the area after the arrival of the United Nations peace forces.

 7        Q.   And Gracanin is talking about the Federal Ministry of Interior --

 8     or the federal Secretary of the Interior giving 4.000.  Are you aware of

 9     this?

10        A.   It is not the federal secretariat providing the men.  They are

11     charged with co-ordinating this issue with the bodies of the RSK, because

12     the RSK had asked for 34.000 men hailing from our area to be trained as

13     policemen.  The co-ordinator was Petar Gracanin because the negotiations

14     around the Vance Plan were conducted on the level of Yugoslavia.  In

15     other words, it was Yugoslavia negotiating with the United Nations the

16     implementation of the Vance Plan.

17        Q.   Who gave 4.000 men?

18        A.   We were supposed to provide them, at their proposal.  In other

19     words, these were supposed to be individuals present in the RSK.

20     However, the original agreement -- or, rather, the agreement was only in

21     respect of 4.000 men, rather than 34.000 that we had requested, and I

22     suppose this was the result of the negotiations conducted between

23     Petar Gracanin and the United Nations.

24        Q.   Did any of this involve the Republic of Serbia MUP?

25        A.   The negotiations and meetings I attended did not include

Page 12742

 1     representatives of the MUP of the Republic of Serbia.  There were

 2     representatives of the federal organs, General Staff, representatives of

 3     what was at that time -- well, the Serbian part of Bosnia-Herzegovina.

 4             MR. JORDASH:  Let's go to page 27 of the B/C/S and 28 of the

 5     English.

 6        Q.   And to orientate yourself, the speaker here is Andjelko Maslic,

 7     who was the general secretary of the Presidency of the SFRY.  And he

 8     notes, at page 28 of the English:

 9             "They think that they will stay the day after tomorrow to hold a

10     session of the government and to adopt specific conclusions, obligations

11     that concern the arrival of the peace forces.  There is a proposal that

12     Martic should explain the organisational plan of the Internal Affairs in

13     Krajina.  A team working on producing the Law on Internal Affairs or,

14     rather, joining the laws that already exist in these parts, together with

15     certain amendments where they differ, adopt a single law.  This has been

16     proposed for other laws too."

17             Are you able to cast any light on that remark?

18        A.   After the refusal on the part of Milan Babic and some of the

19     deputies of the SDS to accept the Vance Plan, without his approval the

20     Assembly meeting in Glina accepted the Vance Plan.  These were

21     preparations for a large Assembly session which was held in Borovo Selo,

22     where a new leadership of the RSK was elected.  Goran Hadzic was elected

23     president, Mila Paspalj re-elected speaker of the Assembly, and I think

24     Mr. Zecevic was prime minister.

25             At that Assembly session there was no one from among Babic's

Page 12743

 1     followers, if I can call him that, and I wasn't there either, where there

 2     was the -- where there was a representation from Yugoslavia as well, as

 3     we can see from these discussions.

 4        Q.   Did Mr. Stanisic, as far as you were aware, take part in any of

 5     these meetings and negotiations and discussions?

 6        A.   As far as I know, no.  And for the two or three Presidency

 7     sessions that I attended, once there was Mr. Milosevic on behalf of

 8     Serbia, once there was Mr. Bozovic, I think he was the prime minister of

 9     Serbia, but also included were representatives of Montenegro,

10     Mr. Bulatovic and Momir Bulatovic, Biljana Plavsic, Radovan Karadzic from

11     Bosnia, at that last session when we were under pressure from them to

12     accept the Vance Plan and we refused.  In other words, the meetings that

13     I attended did not include Mr. Stanisic.  I'm sorry if I expanded in

14     answering your question.

15        Q.   And finally, in relation to this Presidency session, you can see

16     at page 27 of the B/C/S and 27 of -- sorry, 28 of the English, the

17     continuation of that speech wherein it says:

18             "Just before going to the session, comrades from the federal SUP

19     informed me that when Martic comes today, they will try to co-ordinate

20     this again, but that there is an inclination to increase this number,

21     possibly by one battalion.  I do not think that it should go beyond

22     10.000 or 12.000."

23             Can you cast any light on this and the discussions between the

24     federal SUP and Martic?

25        A.   I didn't attend these discussions, so I wouldn't know about it.

Page 12744

 1     It was only natural for Martic to be present there, in view of the fact

 2     that a new government had not been elected yet.  And the federal

 3     government and its organs were a guarantor for our side in the

 4     Vance Plan.  That's why they co-ordinated their activities with Martic,

 5     because the 4.000 men we asked for were supposed to constitute the local

 6     police force.

 7        Q.   Thank you.

 8             MR. JORDASH:  May I tender this as an exhibit, Your Honours,

 9     please.

10             MS. MARCUS:  No objection.

11             JUDGE ORIE:  Madam Registrar.

12             THE REGISTRAR:  This will be D318, Your Honours.

13             JUDGE ORIE:  D318 is admitted into evidence.

14             Please proceed.

15             MR. JORDASH:

16        Q.   So this is the final questions, Mr. Bosnic.  You mentioned you

17     first met Mr. Stanisic in 1994; correct?

18        A.   Yes.

19        Q.   Did you ever meet him after that point?

20        A.   No, not until I was called to testify to the events happening in

21     the Krajina and Croatia for the Defence.

22        Q.   Did you speak to him during 1994 and afterwards until the point

23     where you were called to testify?  Did you have any personal contact

24     whatsoever?

25        A.   No.

Page 12745

 1        Q.   Now, you spoke yesterday about speaking to Babic before he came

 2     to The Hague, and are you able to just shed a little light on what you

 3     perceived of his mental state at that point?

 4             MS. MARCUS:  Objection, Your Honour.  I don't know that the

 5     witness is a psychologist or can comment on someone's mental state.

 6             JUDGE ORIE:  Mr. Jordash.

 7             MR. JORDASH:  Well, I think the witness has said he was one of

 8     his closest friends.  He can indicate whether he felt --

 9             JUDGE ORIE:  He can make factual observations in relation to what

10     he considers may be in relation with the mental state of Mr. Babic.  And

11     he should limit himself to that.  Please proceed.

12             MR. JORDASH:

13        Q.   Did you follow that, Mr. Bosnic?  Could you limit yourself to

14     what you observed about Mr. Babic's mental state before he left to

15     The Hague?

16        A.   The madam was right in saying that I am not a psychologist, but

17     we did know each other for a long time.  What I experienced was first

18     great disappointment and then rage because nobody in Serbia would respond

19     to his requests to advise him on his subsequent steps and to help him

20     with his family.  He was disappointed and angry.  That's how I would

21     characterise him, in layman's terms.

22        Q.   And you never saw him again before his sad and unfortunate

23     suicide; is that correct?

24        A.   No, the last time I saw him was when he said that he would drag

25     into the mud everyone else along with himself.  I saw him in person on

Page 12746

 1     that occasion for the last time, and then I saw him while he was in

 2     The Hague and I was shocked by his statements and demeanour.  How shocked

 3     I was you could tell from the opening remarks I made where I said, as the

 4     saying goes in our people, that it is better for a man to lose his life

 5     than his honour and honesty.

 6             JUDGE ORIE:  Mr. Jordash, I think we asked for factual

 7     observations in relation to the mental state of Mr. Babic.  What we get

 8     in an answer to that is the apparent -- what this witness thinks about

 9     Mr. Babic's behaviour.  And I don't think that that's what we were asking

10     him for, because he is implicitly saying that Mr. Babic was not a man

11     honour, that's at least how I understand that, and that's not something

12     that I would expect as an answer to your question.

13             MR. JORDASH:  Your Honour, if that's Your Honour's view, I accept

14     that.

15             JUDGE ORIE:  Yes.  Let's proceed.

16             MR. JORDASH:

17        Q.   So finally, Mr. Bosnic, having not known Mr. Stanisic but known

18     Mr. Babic very well, why did you decide to give evidence for the

19     Stanisic Defence?

20        A.   Because Mr. Babic was not telling the truth, even though he was a

21     friend of mine and I still regard him as one.  The Milan Babic I knew

22     between 1991 and 1995 and 1996 is not the same Babic who appeared before

23     this Tribunal.

24             MR. JORDASH:  I've got nothing further.

25             Thank you, Mr. Bosnic.  Thank you, Your Honours.

Page 12747

 1             JUDGE ORIE:  Thank you, Mr. Jordash.

 2             Mr. Petrovic, are you ready to cross-examine the witness?

 3             MR. PETROVIC: [Interpretation] I am, Your Honour.

 4             JUDGE ORIE:  Mr. Bosnic, you will now be cross-examined by

 5     Mr. Petrovic.  Mr. Petrovic is counsel for Mr. Simatovic.

 6             MR. PETROVIC: [Interpretation] Thank you, Your Honours.

 7                           Cross-examination by Mr. Petrovic:

 8        Q.   [Interpretation] Good morning, Mr. Bosnic.

 9        A.   Good morning.

10        Q.   I should like to follow up with a couple of questions, the topic

11     that you just discussed with my colleague, Mr. Jordash.  Did you know

12     Mr. Babic's wife?

13        A.   Yes, I do know her.

14        Q.   Do you know whether Mr. Babic's wife addressed the public after

15     the demise of her husband?  Do you know anything about it?

16        A.   After coming to Belgrade she talked to the public, after actually

17     returning to Belgrade.

18        Q.   Do you know anything about the content of her public address?

19        A.   I read something about it.  It was published in the "Politika,"

20     but I cannot recall the exact text.

21        Q.   Thank you.  Let us go through the questions which were raised

22     awhile ago while it is still fresh in our memories.

23             We looked at these minutes of the session of the SFRY Presidency

24     and a question was raised regarding the 4.000 policemen mentioned by

25     Petar Gracanin.  My question to you is:  Do you know that the federal

Page 12748

 1     Secretariat of the Interior with Petar Gracanin at the helm at the time

 2     was only proposing the structure of the MUP of the Republic of

 3     Serbian Krajina; it actually only proposed how under the circumstances

 4     that the ministry should look?

 5        A.   Yes, how it should look and what strength it should have when the

 6     United Nations representatives came, because according to Vance Plan only

 7     the police could carry arms.

 8        Q.   And the personnel and the command structure of the ministry would

 9     remain as envisaged under the the laws of the Serbian Krajina at the

10     time; right?

11        A.   Absolutely, that is correct.  I cannot say in respect of every

12     individual, but to the best of my knowledge all the chiefs of the SUPs,

13     all the komandirs, all the chiefs remained working as policemen but only

14     had a larger complement of people assigned to them.

15        Q.   Please, Mr. Bosnic, let us pause between question and answer

16     because we speak the same language and it is difficult for the

17     interpreters to keep abreast of us.

18             Tell me, let us briefly touch upon the question of the Vance

19     Plan.  Perhaps it was not quite clear to me what capacity you

20     participated in the negotiations regarding the Vance Plan Assembly?

21        A.   The Assembly actually elected 7 MPs who represented the Assembly

22     of the Serbian Krajina in these negotiations in the Presidency of

23     Yugoslavia.

24        Q.   So you were one these seven elected representatives?

25        A.   Yes.

Page 12749

 1        Q.   The seven-member delegation that we are talking about negotiated

 2     with whom; who was the second or the third negotiating side in the

 3     process?

 4        A.   These meetings in the Presidency were actually pressure exerted

 5     on the leadership of the Republic of the Serbian Krajina to accept the

 6     Vance Plan.  In addition to ourselves, to us seven, there were four

 7     members of the Presidency:  Yugoslav Kostic, Branko Kostic,

 8     Sejdo Bajramovic, and a fourth one whose name I cannot recall at this

 9     point.  So representatives of the federal government, the minister of the

10     interior, the federal one, Petar Gracanin, the Chief of General Staff

11     Blagoje Adzic, representatives of Montenegro, Milo Djukanovic,

12     Momir Bulatovic, et cetera.

13        Q.   Thank you.  Mr. Bosnic, were you familiar with the draft of that

14     agreement which was to be signed on behalf of both the Republic of the

15     Serbian Krajina and the Socialist Federal Republic of Yugoslavia at the

16     time?  Do you know what the basic content of the agreement was?

17        A.   Yes, of course.

18        Q.   Can you tell us:  What was in the proposed draft agreement that

19     posed the greatest problem to you from the Republic of the

20     Serbian Krajina for you to accept the offered text of the agreement?

21        A.   Well, the basic thing was that in the preamble of the Vance Plan

22     it was written that it was Croatian territory under the protection of the

23     United Nations, whereas we thought that they were coming to conditionally

24     return us to the Republic of Croatia.  Secondly, we asked in the military

25     section to apply the system of dividing the warring parties and not an

Page 12750

 1     ink-blot system.  And thirdly, we were not sure how much -- we were not

 2     certain how secure we would be if the JNA left the territory, and we

 3     wanted the Serbian areas which did not belong to the Serbian

 4     municipalities in the area of the Republic of Serbian Krajina to be also

 5     covered by the Vance Plan.

 6        Q.   As far as I understood your answer now, these are the sticking

 7     points between you and what the positions of the Socialist Federal

 8     Republic of Yugoslavia were at the time; is that correct?

 9        A.   Yes.

10        Q.   Tell us, was this agreement finally accepted and how was it

11     accepted?

12        A.   Well, eventually it was accepted with opposition on the part of

13     Milan Babic, myself, and some other people.  It was accepted on behalf of

14     the Assembly of the Republic of the Serbian Krajina by the president of

15     the Assembly and a member of our delegation, Mile Paspalj, who, like

16     ourselves, up to the last minute of that meeting which lasted about

17     50 minutes was opposed to the Vance Plan.

18        Q.   On the basis of -- on what basis did Mile Paspalj accept that

19     agreement on behalf of the Republic of the Serbian Krajina?

20        A.   It was actually a trick.  Although Milan Babic was in Belgrade,

21     he was not in the Presidency then.  The explanation was that Milan Babic

22     could not attend the session and being absent and he was deputised for by

23     the speaker, by the president of the Assembly.

24        Q.   Just a second.  In listing the present members of the SFRY

25     Presidency, Borislav Jovic was not mentioned.  Did he participate in

Page 12751

 1     these negotiations?

 2        A.   Yes, he did participate.  And sometimes he chaired the sessions

 3     and sometimes it was Branko Kostic, the representative of Montenegro, who

 4     presided over these sessions.

 5        Q.   Thank you.  After the signing of this agreement in the way that

 6     you have described, did the peace forces of the United Nations deploy --

 7     start to deploy in the field in the territory of the Republic of Croatia,

 8     i.e., the Republic of the Serbian Krajina?

 9        A.   Yes.  Because we could do nothing through our organs of

10     authority, in agreement with Serbia we opted to accept the United Nations

11     forces.  But according to the Vance Plan, they communicated with, as they

12     put it, the local authorities and the local leaders, including myself.

13        Q.   By the signing of this agreement and the deployment of their

14     forces, did the UN -- of the UN, after that did the war stop in the area?

15        A.   In that stage, yes, it did.

16        Q.   What were the relations like between Milan Babic and the

17     representatives of the SFRY, later the FRY, after the events that we are

18     talking about, namely the signing and acceptance of the Vance Plan?

19        A.   The relations cooled and Milan Babic practically remained without

20     any levers of power, but he managed to remain the mayor of Knin

21     municipality.

22        Q.   Did Milan Babic try to form some sort of a new military

23     organisation after the signing of the Vance agreement?

24        A.   I don't know, unless you mean the "Garda King Peter,"

25     King Peter's Guard.

Page 12752

 1        Q.   Well, I should ask you specifically.  First let me ask you this,

 2     although you have already said so:  So the Vance Plan prohibited the

 3     existence of military units in the territory of the Republic of the

 4     Serbian Krajina; right?

 5        A.   Right.

 6        Q.   Are you aware of the fact that in April 1992 Babic gathered some

 7     members of the territory in the defence of the MUP of the Krajina and

 8     tried to establish the so-called Serbian army?  This was in the village

 9     of Kosevo, not far from Knin.

10        A.   I did not participate in that, but I had heard about it.

11             MR. PETROVIC: [Interpretation] Will the witness be shown

12     Exhibit P1999.

13        Q.   Mr. Witness, please take a look at the first paragraph of this

14     document of the Prosecutor and tell me whether what is in the first

15     paragraph is consistent with your memory of the events that we have just

16     discussed.  Just the first paragraph.

17        A.   I know the people who are referred to here.  They are from the

18     SDS leadership, so that they probably attended this gathering, but I

19     myself did not, so --

20        Q.   All right.  Please just tell us, if you know, who Mirko Jovic is,

21     who is mentioned as one of the people attending this gathering.

22        A.   Mirko Jovic was the president of one right-wing party in Serbia,

23     and I believe that he had some sort of a paramilitary unit.  Whether they

24     were some White Eagles or something like that, I'm not quite certain

25     about that.

Page 12753

 1        Q.   Do you know anything about the political options of Mirko Jovic?

 2        A.   No, nothing in particular, except that he was of the

 3     right-wing hue and that he did not represent any relevant force in Serbia

 4     and that he had this unit.  This paramilitary unit which I believe

 5     participated in fighting in Western Slavonia and Bosnia, but don't take

 6     my word for it.

 7             JUDGE ORIE:  Mr. Petrovic, I hear that you're encouraging the

 8     witness to make a pause.  I encourage you to do the same.

 9             MR. PETROVIC: [Interpretation] I apologise, Your Honours.  I

10     should do my best.

11             Can we have page 3 shown to the witness in the B/C/S.  I believe

12     that it is also the third page in the English version.

13        Q.   Mr. Witness, please take a look at the first paragraph on page 3.

14             MR. PETROVIC: [Interpretation] And for Your Honours, I believe

15     that we shall -- I hope that we shall soon have the English-language

16     version on the screen.  Yes, it is the second paragraph in the English.

17        Q.   Mr. Witness, have you taken a look at it?

18        A.   Yes.

19        Q.   My question to you is this:  Did the Vance Plan foresee that all

20     weapons of the former Army of the Republic of the Serbian Krajina would

21     be stored and would be kept under key, practically that the army would be

22     disarmed?

23        A.   Yes, according to the double-key system.  The keys to the

24     storehouse would be held by a representative of the United Nations and a

25     representative of the Territorial Defence after the disarming.

Page 12754

 1        Q.   The call, which we can see in this paragraph, to the effect that

 2     weapons should not be returned, which was actually made by Mirko Jovic,

 3     is a call to violate the Vance agreement which had been accepted a couple

 4     of months before that?

 5        A.   Yes.

 6        Q.   This attempt at creating a Serbian army, had it been successful,

 7     would have been a violation of the provisions of the Vance agreement; is

 8     that not correct?

 9        A.   Yes, it would.  It would have been that.

10        Q.   Mr. Witness, yesterday you referred to the fact that the policy

11     of the SDS was to actually pre-empt every step of the Croatian status by

12     an adequate move on the part of the Republic of the Serbian Krajina?

13        A.   Yes, that was the general concept in principle how we functioned.

14        Q.   And if I understood you correctly, that meant that if Croatia

15     organized a referendum, the Serbian Krajina would organise a referendum

16     also.  And, in fact, before, if Croatia was to amend its constitution,

17     the Serbs would also adopt their constitution.

18             Tell me, what was the position vis-à-vis secession; what was the

19     position of the Serbian Democratic Party with Milan Babic at the helm

20     regarding the question of secession?

21        A.   We were absolutely against Croatia leaving Yugoslavia.  We as a

22     constituent people were absolutely against it.  And if it remained in

23     Yugoslavia, we wanted to have a certain form of territorial autonomy.

24     But if they wanted to leave Yugoslavia by force, we also wanted to

25     exercise our right as the second constituent people and remain within

Page 12755

 1     Yugoslavia.

 2        Q.   If my understanding is correct, the SDS policy under the

 3     leadership of Milan Babic was as follows:  If Croatia were to secede from

 4     Yugoslavia, the next step would be the secession of Krajina from Croatia?

 5        A.   Absolutely.  Because the Serbs and Croats had formed the Croatia

 6     of AVNOJ, A-V-N-O-J, together; and if we are parting ways, then this was

 7     the way it was going to unfold.

 8        Q.   Thank you, witness.

 9             MR. PETROVIC: [Interpretation] I would like you to look at 2D874

10     now.  Your Honours, this is a document we received as part of disclosures

11     from the Prosecution.  Unfortunately, we don't have a translation of the

12     document, so I won't be tendering it at this stage.  I would only like

13     the witness to look at the document, tell us if he knows anything about

14     it, and to comment on the signature.

15             JUDGE ORIE:  If Ms. Marcus sent you an e-mail, Mr. Petrovic, I

16     would certainly read that next time.  The Chamber was copied on it.

17             "Dear," and then one of your team members, "please note that the

18     Prosecution has identified 2D0874 as contained within P1884, pages 4

19     to 8."

20             Ms. Marcus, this was your message, wasn't it?

21             MS. MARCUS:  Yes, Your Honour.

22             JUDGE ORIE:  So therefore, Mr. Petrovic, never forget to open

23     your inbox.  Please proceed.

24             MR. PETROVIC: [Interpretation] Thank you, Your Honour.  I spoke

25     to my learned friend just before the start of the session but I didn't

Page 12756

 1     realise that she was so prompt and managed to send an e-mail.  Thank you,

 2     Your Honour, for correcting my mistake.

 3        Q.   Witness, let's look at P1884 then, pages 4 in English -- or 4 in

 4     B/C/S, sorry, and 3 in English.  Let's look at the last page as well.

 5     Witness, were you able to look through the document and do you know what

 6     this is about?  Are you familiar with the letter?

 7        A.   Yes.

 8        Q.   It was sent on the 11th of January, 1992.  Do you know what this

 9     is all about?

10        A.   Yes, I do.

11        Q.   Can you tell us briefly what sort of document this is, and what

12     circumstances was it drafted and sent out?

13        A.   This is a letter that Milan Babic sent out in response to

14     Mr. Milosevic's letter.  In that letter, Milosevic criticised Babic's

15     position and our position in respect of the Vance Plan, and this is where

16     Babic responds to that criticism.

17        Q.   Rather than reading the contents of the document, can you tell

18     us, from your memory, what sort of response Babic wrote?

19        A.   From what I remember, Babic laid out the reasons for our

20     objections to the Vance Plan.

21        Q.   Their Honours will have an opportunity to read through and

22     examine the letter.  I would not wish to dwell upon it.

23             Mr. Witness, I'd like to put several questions to you now

24     concerning your statement.  I will be looking to clarify certain issues

25     that I believe important.  In paragraph 4 of your statement, which is

Page 12757

 1     D313, reference is made to the arming of the reserve police.  Can you

 2     tell us where these weapons were kept, what their intended purpose was,

 3     and how the weapons were stored in the pre-war period.

 4        A.   The weapons were kept in the police station under key and would

 5     be distributed only in times of war or imminent threat of war to the

 6     reserve force.  These were individuals who went about doing their day

 7     jobs and would only under these circumstances become part of the reserve

 8     police.

 9        Q.   These members of the reserve force, where would they report to

10     duty and pick up these weapons that were intended for them?

11        A.   This would take place in the municipalities where they resided.

12        Q.   Thank you.  In paragraph 5 of your statement, mention is made of

13     a joint commission for night guards.  Can you tell us who was in charge

14     of the night guards you mentioned in paragraph 5?

15        A.   I was speaking about Kordun, and the SDS was in charge of the

16     night guards.

17        Q.   Thank you.  In paragraph 11 of your statement, the events of the

18     17th and the 18th are discussed.

19             MR. PETROVIC: [Interpretation] Your Honours, can the witness be

20     shown D313, please, paragraph 11, so that the witness may know exactly

21     what I'm referring to.  Paragraph 11, please.  Page 4 in B/C/S and page 4

22     in English.

23        Q.   Witness, the events of August 1990 are related here.  You say the

24     Croatians who had come to take their weapons were thrown out.  Which

25     Croatians does this refer to?

Page 12758

 1        A.   They were not allowed to come over and take the weapons, the

 2     Croatian police from Split, Sibenik, or Zadar; they were supposed to take

 3     over the weapons of the reserve force.  They were not allowed to do so.

 4     They were stopped on their way by the roadblocks.

 5        Q.   That's clear.  Thank you.  Let's look at paragraph 14, page 5 in

 6     both versions.  A host of individuals are mentioned here, Mile Martic in

 7     Knin, David Rastovic in Lapac, Sergej Veselinovic in Obrovac, and

 8     Zdravko Zecevic in Benkovac.  Can you tell us, what were the elections at

 9     which these individuals were elected to the posts you relate in

10     paragraph 14?

11        A.   At the multi-party elections in the Socialist Republic of Croatia

12     in 1990.

13        Q.   The legality of their activity in occupying these posts was

14     achieved through the multi-party elections held across Croatia; is that

15     right?

16        A.   Yes.

17        Q.   Witness, I have several questions which concern your town.

18     First, your statement mentions General Pekic and Admiral Branko Mamula as

19     individuals who took part in the procurement of weapons of the JNA for

20     the members of the TO and other formations of what was SAO Krajina at the

21     time.  Can you tell us who these two individuals, Pekic and Mamula, were?

22        A.   One of them is a retired general and the other a retired Admiral

23     who had for a while been the Chief of the General Staff of the JNA who

24     hailed from the area of Kordun, specifically Vojnic and Vrginmost.

25        Q.   Unless I'm mistaken, Mamula was also a federal minister of

Page 12759

 1     defence for a long period of time in the former SFRY?

 2        A.   Yes.  Yes, I must have mistaken it for the Chief of

 3     General Staff.  I knew that he had the highest-ranking position in the

 4     Army of the SFRY.

 5        Q.   Witness, what was the ethnic makeup of the population in Slunj

 6     before the outbreak of hostilities?

 7        A.   Before the outbreak of hostilities, the majority population of

 8     the municipality were Croats.  And this was the consequence of the Serbs

 9     who up until the Second World War were a majority there but had perished

10     during the war.

11        Q.   So we will agree that in the municipality of Slunj the majority

12     population was Croat?

13        A.   Yes.

14        Q.   Where was the location of the JNA unit closest to the town of

15     Slunj?

16        A.   The closest JNA unit was the one stationed at the Slunj

17     training-grounds, but it was a very small unit.  In fact, it was just a

18     technical maintenance service.

19        Q.   Did there come a time in the autumn of 1991 that the command of

20     the 5th JNA district was relocated to the Slunj training-grounds?

21        A.   Yes.  I don't know if it was just elements of the command or the

22     entire command.  There was a Macedonian who was commander, and the chief

23     was Cedomir Bulat, an individual who hailed from the area and who we were

24     in communication with.

25        Q.   Very well.  When did you leave Slunj, when did you leave town?

Page 12760

 1        A.   I never lived in Slunj, but you probably meant the Serbian -- the

 2     Serb population.

 3        Q.   Yes, the Serb population.

 4        A.   In late July and early August.

 5        Q.   And at that point in time there only remained the Croat

 6     population in Slunj; right?  For the most part.

 7        A.   The great majority of the Serbs left Slunj, I think 90 per cent

 8     of them.

 9        Q.   Can you tell us, at which point did the JNA get involved in the

10     combat activities in the area of Slunj?

11        A.   In the second half of November 1991.

12        Q.   Can you tell us, how did the JNA come to be involved in the

13     fighting in the area of the municipality of Slunj?

14        A.   What I know is from what Mr. Cedo Bulat told me.  He asked the

15     Croatian authorities to lay their weapons down, to discontinue the siege

16     of the training-grounds and to stop firing on them, because they did, and

17     told them that if they did so, they would be able to remain to live in

18     the area.

19        Q.   Did at some point Mr. Cedo Bulat issue an ultimatum to the

20     authorities in Slunj?

21        A.   I think that it happened on the 15th of November, 1991.

22        Q.   What was the ultimatum exactly and what was the response to it?

23        A.   As I said a moment ago, the Croats did not respond to the

24     ultimatum.  However, during the night, the better part of the civilian

25     population, members of the Croatian National Guard, and the Croatian

Page 12761

 1     forces withdrew from Slunj in the direction of Velika Kladusa and then on

 2     to the Republic of Croatia.

 3        Q.   How many Croats remained in Slunj after the departure you

 4     referred to?

 5        A.   Very few.  100, 200.  I can't tell you exactly.

 6        Q.   So practically the entire population of Slunj moved out on this

 7     particular occasion?

 8        A.   Those who stayed behind were mostly elderly people or people who

 9     refused to leave their homes.

10        Q.   But can you give me an assessment of their numbers?  I don't mean

11     absolute numbers, I mean percentages.  In other words, what percentage of

12     the Croat population stayed in the town of Slunj after this particular

13     incident?

14        A.   Several.  Five per cent.

15        Q.   Thank you.

16             MR. PETROVIC: [Interpretation] Your Honours, can we now play a

17     video-clip for the witness.  This is an exhibit marked 2D872.1.  It's a

18     video that was disclosed to us by the Prosecution.  The interpreters were

19     given transcripts.  Can we look at the clip that starts at 10 minutes,

20     51 seconds, until 12:35, with your leave.

21             JUDGE ORIE:  Please.

22                           [Video-clip played]

23             THE INTERPRETER: [Voiceover] "Look, I have come here as the

24     so-called Milorad Pupovac from, as you say, the so-called Croatia, here

25     to the so-called Krajina, as they say there where I come from ... and I

Page 12762

 1     came not to tell you how everything around us is so-called in various ...

 2     Because things have gotten serious a long time ago.

 3             "Presenter:  This sensible message was simply laughed at by the

 4     assembled Serbian people of Knin.  Milan Babic, accompanied by the Knin

 5     political elite, walked out of the hall insolently.

 6             "Milorad Pupovac:  None of you will say, I'm certain, that you're

 7     against peace, and none of you, I'm certain, will say that they are

 8     against a national agreement, because if they were to do that, they would

 9     be condemning something that it certainly neither in the interest of the

10     individual, nor of the Serbian people on the whole, nor of the Serbian

11     people in Croatia, and neither of those with whom you live side by side

12     here who are a majority, and that is the Croats.

13             "Zoran Pusic:  There are many of you in the large hall, where I

14     and my colleagues and my friends have come to talk with you.

15             "Unidentified voice:  And you are cowards, Ustashas, criminals,

16     cowards, wretches, vampires.

17             "Presenter:  The colours of Croatia and the city of Zagreb were

18     also defended at this peace forum in Knin by Messrs. Palasek, Viskovic,

19     and Pusic.  For all those who had assembled, they were just Ustashas and

20     traitors."

21        Q.   Witness, I have several questions concerning this clip.  First

22     off, do you -- did you recognise the first speaker whom we just saw?

23        A.   Milorad Pupovac, a Serbian intellectual from Benkovac who lives

24     in Zagreb.

25        Q.   Mr. Witness, to the best of your knowledge, today is

Page 12763

 1     Milorad Pupovac the vice-president of the Autonomous Serbian Democratic

 2     Party, which is part of the ruling coalition in the Republic of Croatia?

 3        A.   Yes.

 4        Q.   Do you know about this meeting or about any other meetings that

 5     Pupovac and his -- those of the same ilk as Pupovac tried to organise in

 6     the territory of the Republic of the Serbian Krajina in the spring of

 7     1991?

 8        A.   There were a number of such attempts, one was in Karlovac, for

 9     Serbian intellectuals to issue a communique in which they are invited to

10     talks.  The second was this by Pupovac.  We from Banija and Kordun also

11     had a talk with Pupovac in Petrinje but not as a panel meeting but only a

12     couple of representatives.

13        Q.   Do you know about this event when Milan Babic demonstratively

14     walked out of this gathering with his associates?

15        A.   I only know from what people said that they demonstratively left

16     the meeting because Milan Babic [as interpreted] had come to pull the

17     wool over their eyes from Zagreb, as it were.

18             THE INTERPRETER:  Interpreter's correction:  Milorad Pupovac, not

19     Milan Babic.

20             MR. PETROVIC: [Interpretation]

21        Q.   I should like to tender this document as a Defence exhibit.

22             JUDGE ORIE:  Ms. Marcus.

23             MS. MARCUS:  Yes, Your Honour, we're trying to look into

24     information.  It's true that this came from our archives.  We're trying

25     to look into the origin of it.  So I can't provide my response until we

Page 12764

 1     find out what the origin is.  So it if could be MFI'd for now.

 2             MR. PETROVIC: [Interpretation] Perhaps I could be of assistance.

 3     That is V00425-1-A.  That is your number.  I believe that that can be of

 4     assistance in locating the actual cassette.

 5             MS. MARCUS:  Thank you.

 6             JUDGE ORIE:  Yes, the video will be MFI'd.  Have you upload the

 7     transcript as well, Mr. Petrovic?

 8             MR. PETROVIC: [Interpretation] Your Honours, it is in the B/C/S,

 9     uploaded in the B/C/S, and we got the English translation only prior to

10     this session, so it will be uploaded in the shortest time possible.

11             JUDGE ORIE:  Thank you for that.

12             Madam Registrar, the number would be ...

13             THE REGISTRAR:  The number would be D319 MFI'd, Your Honours.

14             JUDGE ORIE:  D319 keeps that status until we have further heard

15     from Ms. Marcus.

16             Mr. Petrovic, the Chamber is wondering how far we are away from

17     the case which is before us with these questions.  The relevance of quite

18     a lot of details is rather unclear to us.  Please proceed.

19             MR. PETROVIC: [Interpretation] Thank you, Your Honours.  I shall

20     try to focus on other questions.

21             JUDGE ORIE:  And how long do you think you would need?

22             MR. PETROVIC: [Interpretation] Your Honours, I believe

23     25 minutes, half an hour at most.

24             JUDGE ORIE:  Yes.  So I'm just asking myself whether that would

25     be possible to conclude before the next break if we would take the break

Page 12765

 1     slightly later.

 2             But, Mr. Jordash, I also leave it to some extent to the

 3     Stanisic Defence.  Often it's good to finish before the break a portion

 4     of the examination.  If that would be possible, it would be appreciated.

 5             Mr. Petrovic, could you please be very focused.  We'll see how

 6     matters develop.  Please proceed.

 7             MR. PETROVIC: [Interpretation] I shall do my best, Your Honours.

 8     The break is at 12.20; am I correct?

 9             JUDGE ORIE:  Yes, that's usually the time where we take a break,

10     even a bit earlier, 75 minutes.  I think we restarted at 5 minutes to

11     11.00 approximately, and so 75 minutes is the usual time.  If it would be

12     five or ten minutes more and if you could conclude, we could consider

13     that.  If not, we would give you a certain portion of time after the

14     break.  Please proceed.

15             MR. PETROVIC: [Interpretation] Thank you, Your Honours.  I shall

16     do my very best.

17        Q.   Mr. Witness, today you mentioned, and that is on page 19, that in

18     June or July 1991, as you said, some events happened in Glina.

19             MR. PETROVIC: [Interpretation] Can we look at 2D873.  This is a

20     document that the Prosecution received from the Republic of Croatia.  Can

21     we please have page 3 on the screen, that is, in the B/C/S.  And also

22     the -- and just a minute.  And also the third page in the English

23     language.

24        Q.   Mr. Witness, this is a decision on conducting an investigation

25     against Dragan Vasiljkovic, Captain Dragan, which was adopted by the

Page 12766

 1     county court in Osijek.  Please, I refer you to this part under 3.  It is

 2     stated there that on the 26th of July, 1991, in Glina during an armed

 3     conflicts, Captain Dragan, in agreement with JNA Captain Rapajic,

 4     perpetrated the criminal offence that they are charged with, which is not

 5     what we are right now interested in.  Do you accept that this event in

 6     Glina took place as described here in the decision on conducting an

 7     investigation of the 26th of July, 1991?

 8        A.   It is correct.  This took place in July.  I was not certain of

 9     the exact date.

10        Q.   Mr. Witness, it is stated here that Captain Dragan, in

11     co-ordination with a tank unit of the JNA, participated in that attack.

12     Is that consistent with what you know about events in Glina in the period

13     concerned?

14        A.   Not only in Glina but generally speaking all military actions and

15     operations were carried out in co-ordination with and under the command

16     of the JNA.

17        Q.   As regards this particular action in Glina in which

18     Captain Dragan also participated, was there perhaps special media

19     coverage of that action?  Was it widely covered by the media and

20     publicised?

21        A.   This action was very widely covered by the media.  It was in the

22     limelight.

23        Q.   Mr. Witness, you state in your statement --

24             MR. PETROVIC: [Interpretation] But, Your Honours, may I first

25     tender 2D873 as a Defence exhibit.

Page 12767

 1             MS. MARCUS:  No objection.

 2             JUDGE ORIE:  Madam Registrar.

 3             THE REGISTRAR:  That would be D320, Your Honours.

 4             JUDGE ORIE:  D320 is admitted into evidence.  Please proceed.

 5             MR. PETROVIC: [Interpretation] Thank you, Your Honours.

 6        Q.   Mr. Witness, in your statement you say in paragraph 58 that

 7     Captain Dragan started interfering in politics.  This interfering of his

 8     in politics, was that -- did that start after this action, after this

 9     publicity that Captain Dragan had acquired after this action in Glina?

10        A.   It was immediately after that action that he became, as they

11     said, a media star.

12        Q.   To the best of your knowledge did Captain Dragan actually

13     believe, come to believe, that he could play some sort of a political

14     role in the SAO Krajina?

15        A.   Well, he did make statements along those lines.  The parties were

16     not good, the people in charge of the parties were not good, in the JNA

17     there were quite a few incompetent officers, but he was competent as he

18     had demonstrated by that action.  He was ready, able, and willing to lead

19     and to make decisions.

20        Q.   Mr. Witness, immediately after this action, as I understand your

21     statement, there was a total falling out between Captain Dragan and

22     Milan Babic?

23        A.   Yes.  Because the stance was that by such statements and his

24     analysis of the work of the SDS, by that Captain Dragan actually sought

25     to interfere in political life and the functioning of the political

Page 12768

 1     system in the Republic of the Serbian Krajina, generally speaking, which

 2     then was the SAO Krajina.

 3        Q.   After this parting, did Captain Dragan immediately leave the

 4     territory of SAO Krajina?

 5        A.   I don't know exactly how much time had passed, but, yes, after

 6     that conflict Captain Dragan did leave the territory of Krajina.  And at

 7     a certain point Vojislav Seselj came to Benkovac, there was a gathering,

 8     and he asked Captain Dragan to respect the civilian authorities and to

 9     comply with the decisions of the civilian authorities with Milan Babic at

10     the helm whether he agreed with him or not.

11        Q.   In your statement you say that Milan Babic felt threatened by

12     Captain Dragan.  Can we conclude from that that Milan Babic actually

13     solved this conflict very efficiently to his advantage because

14     Captain Dragan left?

15        A.   Yes, this conflict was resolved in Babic's favour.

16        Q.   And Captain Dragan did not reappear in the Krajina until 1993,

17     until the camp in Bruska was established?

18        A.   As far as I know, no, he did not.  I never saw him nor was there

19     any information published about his coming in the media.  He was already

20     referred to for the first time after that when the so-called Alfa camp

21     was set up in Bruska.  I believe that that was what it was called.

22        Q.   Thank you.  Can you tell us - and now I will move on to a

23     different topic, trying to keep within my allotted time-limits - on the

24     31st of March, 1991, what happened at Plitvice?  Briefly.

25        A.   There was an incursion by special Croatian units.  There were

Page 12769

 1     skirmishes, there were shootings.  The first victims fell and the

 2     Croatian police actually took a feature at Plitvice lakes.

 3        Q.   Thank you.

 4             MR. PETROVIC: [Interpretation] We shall now see a video, a very

 5     short one.  It is only one minute.  It is 2D872.2.  It is from the same

 6     collection of the Prosecution as the video which I showed awhile ago.

 7     Let us see a very short piece of footage.

 8                           [Video-clip played]

 9             MR. PETROVIC: [Interpretation] And I refer the witness to the

10     equipment and to the armaments of the people that we can see.

11                           [Video-clip played]

12             MR. PETROVIC: [Interpretation] Thank you.  I believe that that is

13     sufficient.

14        Q.   Mr. Witness, can you recognise, although my question is senseless

15     in a way because it is written on the video, but was this filmed in

16     Korenica?  Do you recognise that this is Korenica?

17        A.   Well, I cannot recognise it from this angle.  I came to meetings

18     in my car, and if it were in Plitvice, I would probably recognise it but

19     not in this way.

20        Q.   I wish to ask you this:  You mentioned village guards armed with

21     hunting weapons in your statement.  Did those guards look like the people

22     that we see in these -- in this footage?

23        A.   Exactly.  And this person who -- this man who told me about the

24     ripping of the flag is carrying a hunting rifle used to hunt pheasant and

25     hare, rabbits.

Page 12770

 1        Q.   Thank you, witness.

 2             MR. PETROVIC: [Interpretation] Your Honours, I should like to

 3     tender this video as a Defence exhibit if there are no objections, of

 4     course.

 5             MS. MARCUS:  Same objection as before, Your Honour.

 6             JUDGE ORIE:  Yes, you would like to have it marked for

 7     identification.

 8             Mr. Petrovic, did I hear any sound?  Or ...

 9             MR. PETROVIC: [Interpretation] Your Honours, there should have

10     been sound, but I don't know whether there was.  The transcripts exist.

11     It was the same situation as with the previous video.  But I'm not sure

12     what the situation was on your channel.  In the B/C/S channel there was

13     no sound.  But there should be sound, there must be sound.  Shall we play

14     it again?

15             JUDGE ORIE:  Well, you may do so, but since the witness

16     apparently is referring to the words spoken, then before we accept it as

17     evidence I'd like to hear what was said.

18             Yes, now, one thing:  If it is just about hunting rifles and if

19     it's just about that the witness doesn't know where it is, then you could

20     even ask yourself what -- the Prosecution might agree with you - that the

21     people shown on this video, wherever it may come from, having hunting

22     rifles and are not in uniforms.  That's the most I think I can make of

23     it.  Is that what you want to establish?

24             MR. PETROVIC: [Interpretation] Yes, Your Honours.

25             JUDGE ORIE:  Let's see whether the Prosecution would agree with

Page 12771

 1     you that a video exists which says that it is from Korenica and the date

 2     you mentioned, that it refers to Plitvice and the date the witness

 3     mentioned, and that we see on that video several persons not in uniform

 4     apparently having hunting rifles on their shoulders.  If that is -- if

 5     the Prosecution could agree on that.

 6             MS. MARCUS:  Yes, Your Honour.  On that limited statement that

 7     Your Honour just put, yes, we agree.

 8             JUDGE ORIE:  What is there anything more, Mr. Petrovic?

 9             MR. PETROVIC: [Interpretation] Your Honours, nothing more.  I

10     thought that the witness would recognise the video.  Perhaps if I had

11     played a longer portion he would have recognised it, but I'm satisfied

12     with this --

13             JUDGE ORIE:  There seems to be full agreement between the parties

14     on what I just mentioned.  So therefore there's no need to replay, and I

15     take it that there's also no need further to tender this video.

16             Please proceed, Mr. Petrovic.

17             MR. PETROVIC: [Interpretation] Thank you, Your Honours.

18        Q.   Mr. Witness, in your statement you refer to Slobodan Lazarevic.

19     That is in paragraph 84 of your statement.  Do you know whether

20     Lazarevic, at the time that you speak about, namely from 1991 to --

21     rather, from 1992 to 1995 was stationed in Topusko?

22        A.   Yes, from 1992 to 1992 --

23             THE INTERPRETER:  As the witness said.

24             THE WITNESS: [Interpretation] -- he lived and worked in

25     Velika Kladusa.

Page 12772

 1        Q.   Perhaps I didn't understand you correctly.  So it was during the

 2     war.  From 1992 where was he?  Was he in Topusko or in Kladusa?

 3        A.   Up to 1992 he was in Velika Kladusa, up to the point when the

 4     conflict broke up in Bosnia-Herzegovina, and then he moved to Topusko.

 5        Q.   Did you ever visit him in his offices in Topusko?

 6        A.   No, not in his offices.  But I would see him in Topusko and Slunj

 7     because we became acquaintances in 1986 and we were on visiting terms as

 8     well, since I used to work in Velika Kladusa.

 9        Q.   Did he ever tell you that in the building housing his offices in

10     Topusko also housed representatives of certain forces from Serbia?  Did

11     he make any statements to that effect?

12        A.   No, he never told me that.

13        Q.   Do you happen to know if after the war Lazarevic was in real

14     estate business in Belgrade, in Serbia?

15        A.   We would come across each other in Belgrade, and I also came to

16     visit him in his flat in Belgrade with my wife.  He told me that he had a

17     company which was registered in the Hotel Serbia in Belgrade, and I think

18     he told me that his company was selling caravans, something to that

19     effect, in Spain.  Not the real estate.

20        Q.   Do you know under what circumstances Lazarevic left Belgrade and

21     Serbia?

22        A.   I didn't hear it from him but I heard it from our common

23     acquaintance that he was forced to leave because of the debts and

24     financial embezzlement in his company.

25        Q.   Thank you.  Let's kindly clarify one other point.  We agreed a

Page 12773

 1     moment ago that Captain Dragan left in August of 1991; is that right?

 2        A.   I don't know the precise date.  That's roughly the period.

 3        Q.   In the course of your testimony today you mentioned a place

 4     called Skabrnja.  Did you participate in any events connected to

 5     Skabrnja?

 6        A.   No.  I only have indirect knowledge from Ranko Lazaric, who was a

 7     party colleague and president of the executive body in Benkovac.

 8        Q.   Will you agree with me that the events in Skabrnja happened in

 9     the second half of November 1991?

10        A.   I suppose so.  I don't know the exact date.

11        Q.   You mentioned an armoured train today.  Do you know who made it?

12        A.   It was manufactured in Knin in order to show that we had a

13     running train, and the only operational railway check was between

14     Benkovac and Knin.

15        Q.   And did it have any defence significance?

16        A.   No, it was more of a support to boost the morale of the local

17     population.  I don't know that it was used in any operation.

18        Q.   Do you know who paid for its manufacture?

19        A.   As far as I know, the municipality of Knin or all of the

20     municipalities of Lika and Dalmatia.  But I know that it was the workers

21     in Knin working for the Tvik factory, I believe, who produced it.  I'm

22     not sure.

23        Q.   Thank you, witness.

24             MR. PETROVIC: [Interpretation] Thank you, Your Honours, I have no

25     further questions for the witness.

Page 12774

 1             JUDGE ORIE:  Thank you, Mr. Petrovic.

 2             We'll now take a break.  Ms. Marcus, are you ready to start your

 3     cross-examination after the break?

 4             MS. MARCUS:  Yes, Your Honour.

 5             JUDGE ORIE:  Mr. Jordash, I haven't heard a summary, and you know

 6     what we usually did if the Prosecution had no summary ready to be read --

 7     oh, you have one ready, because otherwise I would invite you to file it.

 8             MR. JORDASH:  I'm happy whichever way you want to proceed.

 9             JUDGE ORIE:  Yes, of course it is usually in order to inform the

10     public at the beginning so that they better understand the -- that they

11     better understand the evidence.  Would you please consider over the break

12     whether you would prefer to file it or to read it.

13             MR. JORDASH:  Your Honour, yes.

14             JUDGE ORIE:  And we'll resume at a quarter to 1.00

15                           --- Recess taken at 12.20 p.m.

16                           --- On resuming at 12.49 p.m.

17             JUDGE ORIE:  Ms. Marcus, you are ready --

18             Yes, Mr. --

19             MR. JORDASH:  Sorry to interrupt.  Could I just indicate that

20     we'll file the summary, if that's okay with Your Honours.

21             JUDGE ORIE:  That's as matters stand now.  Of course, we prefer

22     it to be read but then at the beginning of the testimony.

23             Mr. Bosnic, you'll now be cross-examine by Ms. Marcus.

24     Ms. Marcus is counsel for the Prosecution.

25             Please proceed.

Page 12775

 1             MS. MARCUS:  Thank you, Your Honour.

 2                           Cross-examination by Ms. Marcus:

 3        Q.   Good afternoon, Mr. Bosnic.

 4        A.   Good afternoon.

 5             MS. MARCUS:  Your Honours, before I commence the cross

 6     examination, I wanted to first of all request again that before we

 7     adjourn today, if possible, we receive some kind of a response from the

 8     Stanisic Defence with respect to the statements.  For DST-074, who is the

 9     witness after DST-043, we have received nothing, no applications, no

10     statement, no motions, et cetera.

11             JUDGE ORIE:  We'll reserve the last five minutes so that you have

12     an opportunity to respond, Mr. Jordash.

13             Please proceed.

14             MS. MARCUS:  Thank you.  I have one more point I wanted to put on

15     the record with respect to the RFAs.  The quantity actually turned out to

16     be about 400 pages of materials that we received from the Government of

17     Croatia.  That said, we are doing our absolute utmost to identify those

18     documents within that response that we may need to use and even to try to

19     get urgent translations of those selections.  We have identified some

20     duplications of documents that we may already of have.  I'm cautiously

21     optimistic that we might be able to go through that, but I would still

22     like to observe the option possibly needing to either re-call the witness

23     or keep him somehow for cross-examination on matters that arose in that

24     response.  We are doing our best, Your Honour.

25             JUDGE ORIE:  That's on the record.

Page 12776

 1             MS. MARCUS:

 2        Q.   Mr. Bosnic, in paragraph 3 of your statement, you say that the

 3     SDS was not regarded as an extremist party.  A bit later, in

 4     paragraphs 14 to 16, you describe the events leading up to the final

 5     split, as you called it, which resulted in Martic and Babic being the

 6     leaders of the SDS.  Would you agree with me that Raskovic and Soskocanin

 7     were moderates within the SDS?

 8        A.   Well, I wouldn't agree.

 9        Q.   How would you have viewed them, their positions, then?

10        A.   Our views coincided until Professor Raskovic and Zelenbaba and

11     that third individual suggested that we embark on the adventure of

12     participating in the elections in the Republic of Serbia.

13        Q.   Would you agree, then, that Raskovic was gradually marginalised

14     over time, as the party became more extreme?

15        A.   The party did not become more extreme, but I would agree

16     absolutely with the rest.  Professor Raskovic was marginalised, but this

17     was due to his own will, in part, and he left for the United States.

18        Q.   Can you recall which month and year it was when this final split,

19     as you called it, occurred, leaving Martic and Babic as the SDS leaders?

20        A.   This was on the eve of the elections in Serbia.  I don't know

21     which month exactly it was.  It was perhaps December.  At any rate, in

22     late 1990.

23        Q.   Now, you mentioned someone named Jovo Opacic along with

24     Zelenbaba.  Can you tell us what you know of Opacic.

25        A.   I know that he was one of the vice-presidents of the

Page 12777

 1     Serbian Democratic Party and one of its founders.

 2        Q.   Thank you.  Now, in paragraph 10 of your statement, you say that

 3     information had arrived that the Croatian forces sent their people to the

 4     police station in Knin and Northern Dalmatia to take weapons.  Then in

 5     paragraph 11 you state that the Croatians who had come to Knin to take

 6     the weapons were thrown out.  Earlier Mr. Petrovic asked you, his

 7     question was:

 8             "Witness, the events of August 1990 are related here.  You say

 9     the Croatians who had come to take the weapons were thrown out.  Which

10     Croatians does this refer to?"

11             Your answer was:

12             "They were not allowed to come over and talk the weapons, the

13     Croatian police from Split, Sibenik, or Zadar; they were supposed to take

14     over the weapons of the reserve force.  They were not allowed to do so.

15     They were stopped on their way by the roadblocks."

16             My question to you is:  Are you thus confirming that when you

17     said they were thrown out that was actually not the case because they

18     never actually made it in?

19        A.   Yes, they never made it to take the weapons over.  News reached

20     the people of their arrival, people got organised, and they never managed

21     to take the weapons.

22        Q.   When you say "news reached the people," this also is kind of what

23     you said in paragraph 10 of your statement where you said information

24     arrived that Croatian forces had sent their people.  So my question to

25     you is:  Where did that information arrive from?  Or, rather, more

Page 12778

 1     specifically:  From whom did you hear that information?

 2        A.   The information reached us through the early-warning information

 3     centre, the sort of centre which exists in every municipality.  I suppose

 4     that the information had originally come from the JNA, but I'm not sure

 5     who the source of information was.

 6        Q.   And where were you when you received this information?

 7        A.   I was in Vojnic.  The meeting of our board was summoned, and we

 8     received information from Knin of the attempts by the Croatian forces to

 9     advance towards Knin and these municipalities.

10        Q.   So just to clarify:  You were not in Knin at that time?

11        A.   No, not on the 16th and the 17th.  We were in Knin on the 18th

12     when we attended a rally in Benkovac held by Mr. Raskovic and which had

13     to do with the opposition to these actions taken by the Croatian police.

14        Q.   Thank you.  In paragraph 12 of your statement you say, and I

15     quote:

16             "I did not see any police from Serbia or heard anything about

17     their presence."

18             You say you were certain that this would have been communicated

19     to the Main Board.  By this you mean the main SDS board; is that correct?

20        A.   Yes.

21        Q.   Can you explain to us what makes you so certain that the SDS

22     board would have been informed of the presence or involvement of the

23     Serbian police?

24        A.   I think that after all we were the core leadership of the people,

25     and it was our duty to convey that sort of information to the general

Page 12779

 1     public as to what was going on and who was assisting us, et cetera.

 2        Q.   You were the core political civilian leadership; is that correct?

 3        A.   Yes.

 4        Q.   How often would you say you were in Knin in 1991?

 5        A.   Quite often.  Every seven or 15 days, depending on the situation,

 6     Babic would come to visit us along with his associates and we would

 7     organise meetings with other leaders in the field, but these meetings

 8     were quite frequent.

 9        Q.   The meetings --

10             JUDGE ORIE:  Could I try to understand the answer and also the

11     previous answer.

12             You were asked - previous question - how you could be so certain

13     that the information would have reached you.  And then you said you were

14     core leadership; that's understood.  And then you said it was our duty to

15     convey that sort of information, which means that if you receive it, that

16     you have to pass it on.  But it is not in any way -- at least I do not

17     understand that to be a reason, that you would receive it because you

18     have to pass it on.

19             Now, here we have the last question.  The question was:

20             "How often were you in Knin?"

21             And you said:

22             "Quite often.  Every 7 or 15 days, depending on the situation,

23     Babic would come to visit us along with his associates and we would

24     organise meetings with other leaders in the field."

25             It's, for me, difficult to understand that if Babic comes to you

Page 12780

 1     that that explains why you were in Knin.  I always thought if Mr. Babic

 2     was in Knin, Babic would go from Knin to your place.  So therefore

 3     it's -- I have great difficulties in understanding, now and then, your

 4     logic.

 5             So could you please focus very much on the question, try to

 6     answer that question rather in a factual way than in explanations and the

 7     type of logic which apparently is difficult for me to understand.

 8             Please proceed, Ms. Marcus.

 9             MS. MARCUS:  Thank you, Your Honour.

10        Q.   Yes, Mr. Bosnic, let's go back to the first question that

11     His Honour just asked you about.  The question I put was:

12             "Can you explain to us what makes you so certain that the SDS

13     board would have been informed of the presence or involvement of the

14     Serbian police?"

15             You then spoke about your duty to convey that sort of information

16     to the public.

17             Can you explain to us what -- again, the question is:  What makes

18     you certain that you would have been informed of the presence or

19     involvement of the Serbian police?

20        A.   The SDS Main Board was the biggest and most significant body

21     representing the Serbian people in Krajina.  We attended meetings of the

22     Main Board which adopted guide-lines for our future work in the field.

23     We would convey these guide-lines to our associates in the lines of work

24     we were directly engaged in.  We would frequently schedule meetings to

25     which we would invite Milan Babic to describe the political situation and

Page 12781

 1     the steps that the SDS would take with a view to setting up and

 2     consolidating power and resistance against the Serbian forces --

 3             THE INTERPRETER:  Interpreter's correction:  Against the Croatian

 4     forces.

 5             THE WITNESS: [Interpretation] -- as well as the setting up of the

 6     reserve force.

 7             MS. MARCUS:

 8        Q.   Do we understand your answer to mean that pursuant to an

 9     invitation, Babic would attend these meetings, give you a briefing on the

10     political situation and the steps that the SDS would be taking, and

11     through that information you would assume that you would have been

12     informed of Croatian -- of Serbian police involvement?  Is that how we

13     understand your answer?  And if not, please clarify.

14        A.   That's how the Main Board worked.  However, Babic would also come

15     out into the field, specifically in Kordun, to explain to the lower

16     levels what the situation was like.  So I attended meetings of the

17     Main Board as well as meetings held locally, which Milan Babic attended,

18     explaining the situation in Krajina and the relations between Krajina and

19     Croatia.  So we are speaking about two different levels at which

20     discussions took place, and it was only natural and normal for

21     Milan Babic to speak about the police force or anything else that had to

22     do with the RSK, or initially SAO Krajina, at both these levels.  And in

23     Kordun I was in contact with the existing police force and they never

24     mentioned to me that there was a police force from Serbia in my

25     communication with them.

Page 12782

 1        Q.   Thank you.  Okay, I'm going to ask you a few questions about the

 2     meetings again and then we'll return a little bit to this subject.

 3             So I go back again:  Of these meetings that you described, which

 4     you attended, you said, every 7 to 15 days, if I'm not mistaken - you

 5     also describe these meetings in paragraphs 15 to 20 of your

 6     statement - are those meetings that took place in Knin or are you

 7     including also the meetings that you had locally on the ground?

 8        A.   Meetings were held mostly in Knin.  However, at times meetings of

 9     the Main Board would take place in Benkovac, Lapac, and elsewhere.  Not

10     always were the meetings of the Main Board held in Knin, though for the

11     most part they were.  And when I was referring to meetings, I also

12     included my own activities that I had in the field as a member of the

13     Main Board, when I was referring to the overall number of meetings as

14     well as the frequency thereof.

15        Q.   The meetings of the Main Board, did Babic necessarily attend

16     those meetings or only periodically upon your invitation?

17        A.   No, Babic always attended meetings.  There may have been an

18     exception that I don't recall at this time, but he would attend meetings

19     as a rule.

20        Q.   And the meetings that you had in the field, as you say, as a

21     member of the Main Board, which you included in the number of meetings,

22     did Babic necessarily attend those?

23        A.   No.

24        Q.   At the Main Board meetings, were there police officials and

25     military officials, operational people, et cetera, or was it exclusively

Page 12783

 1     political, civilian officials who attended those meetings?

 2        A.   Political leaders.  Some of them also held positions in the TO.

 3     I'm not sure about the police.

 4        Q.   You're not sure whether -- just to understand what you're not

 5     sure about:  You're not sure whether some of the political leaders also

 6     played a role in the police, or you are not sure whether the police

 7     attended?

 8        A.   No, they didn't attend meetings.  But I'm not sure if any of the

 9     members of the Main Board also played a role in the police.  That, I

10     don't know.  In other words, there were no senior members of the police

11     represented at the meeting.  It was for the most part the political

12     leaderships.  It was just that I was saying that I don't know what other

13     roles these political leaders may have played in the municipality.  I

14     didn't know them all.

15        Q.   So you were not necessarily informed of all of the activities of

16     those involved in these meetings; is that -- do I understand you

17     correctly?

18        A.   Yes.

19        Q.   What was the role of the SDS Main Board with respect to the

20     police?

21        A.   It didn't have any direct influence over the police.  It could

22     issue guide-lines as to how the civilian authorities should operate and

23     the ways in which their work would be organised, meaning the work of the

24     police force, health care, and all the other elements of power.

25        Q.   I'm not sure I understood your answer.  My question was the role

Page 12784

 1     of the SDS Main Board with respect to the police, and you said:

 2             "It didn't have any direct influence over the police.  It could

 3     issue guide-lines as to how the civilian authorities should operate and

 4     the ways in which their work would be organised, meaning the work of the

 5     police force ..."

 6             So are you saying that the SDS Main Board could issue guide-lines

 7     with respect to the work of the police force?  Or did I misunderstand

 8     your answer?

 9        A.   The Main Board issued guide-lines to the Serbian National Council

10     because it had become apparent that there was a lack of unity in the

11     activity of the police forces.  Our intention was to unify these

12     activities.  Milan Babic agreed and proposed that Milan Martic be the

13     secretary of the overall police force as well as a member of the

14     National Council, meaning the government.  So the political idea came out

15     of the Main Board, Babic was the one who pushed for the idea and

16     suggested that Martic be the secretary in charge of all the political

17     stations, primarily -- or initially in the areas of Lika and

18     Northern Dalmatia, and later on Krajina.

19        Q.   Was there a system put in place for reporting between the police

20     and the SDS Main Board?  In other words, were the police providing

21     regular reports pursuant to some guide-lines to the SDS Main Board?

22        A.   No, they did not send any reports to the Main Board of the SDS.

23     It did so through the national -- Serbian National Council via which it

24     was referred to the Assembly.  And through the Assembly it also came to

25     the Municipal Assemblies where they discussed the work of the local

Page 12785

 1     police forces.

 2        Q.   And the information, this reporting that you're talking about,

 3     who reported this to the public?

 4        A.   The public was informed by the Serbian National Council and the

 5     Assembly, which discussed and adopted work reports.  So the

 6     Serbian National Council reported to the Assembly, informed the Assembly,

 7     and the Assembly would either adopt or refuse the report.  So the

 8     minister or the secretary would submit a report to the Serbian National

 9     Council, the Serbian National Council either accepted it or not.  If it

10     was accepted, it would then be referred to the Assembly.  And the final

11     discussion on the work would have been conducted by the Assembly.

12        Q.   Now, all this information that's being shared and assembled, did

13     that tend to contain details of police activities on the ground, or was

14     it more about political events and matters that effect the public at

15     large?

16        A.   These reports principally were on the work of the police, what

17     the police was doing on the ground, without any political qualifications.

18        Q.   Were you systematically informed of the details of training

19     activities?  You, as in a member of the SDS Main Board.

20        A.   If you are referring to the training in Golubic, no, I was not.

21     If that is what you mean.

22        Q.   What about intelligence activities?

23        A.   What I learned from Babic at the Main Board meeting was that

24     there also existed a State Security Service of the Krajina at the helm of

25     which was Orlovic.  These were mainly personnel who used to work in the

Page 12786

 1     State Security Service but that of Croatia, but they were of Serb

 2     ethnicity and they remained with us in our area, the area of the Krajina.

 3        Q.   Which Orlovic are you talking about?

 4        A.   The Orlovic who was the chief of the State Security Service of

 5     the Krajina.

 6        Q.   Do you know his first name?

 7        A.   I know the man in person.  I believe that his first name was

 8     Dusko, but I can't be sure.

 9             MR. JORDASH:  There's no dispute on that issue.

10             JUDGE ORIE:  Please proceed.

11             MS. MARCUS:  Thank you.

12        Q.   Now, you said you learned this form Babic.  My question was about

13     systematically being informed of these kinds of activities.  Are you

14     saying that Babic systematically informed the Main Board of state

15     security activities or are you saying that he informally gave you that

16     information?

17        A.   I'm saying that he gave this information informally to me.  We

18     did not discuss the work of the State Security Service at the Main Board

19     session.  He told me this because I knew Orlovic from before, I suppose.

20     He did not inform the Main Board in the sense of a report or any other

21     formal communication.

22        Q.   Was the SDS Main Board generally informed of covert operations?

23        A.   I don't know what covert operations you are referring to.  I

24     really don't know what operation you mean.  If you ask me a specific

25     question, perhaps I can then answer yes I have or I have not heard about

Page 12787

 1     that specific operation.

 2        Q.   I'm asking generally whether the Main Board was systematically,

 3     routinely informed of covert operations by the state security.

 4        A.   I don't know of any covert operations, and we were told nothing

 5     about any such operations.  I what not aware of their existence and

 6     nobody told us anything about any such operations.

 7        Q.   Were you informed of the movement and distribution of weapons?

 8     You, meaning the SDS Main Board.

 9        A.   No.  These things did not take place equally in all areas, and

10     there was not much discussion about these things.  According to what I

11     know, it was until July or August we did not even get any weapons.  What

12     existed were just personal weapons owned by members of the village guards

13     and the weapons that were under key in the TO and in the police.  And I

14     don't know about any other weapons.

15        Q.   You talked quite a lot about the Golubic training centre.  Were

16     you informed of the particular training activities that were carried out

17     there?

18        A.   Only in principle, not the specifics.  Not in detail.

19        Q.   And how did you receive that information; was it formally through

20     a reporting process or informally through conversations?

21        A.   In conversations conducted at the Main Board sessions.  The

22     initiative for the establishment of such a centre actually was launched

23     at a session of the Main Board.  And after the attack on Plitvice, the

24     Serbian National Council actually formulated in a request addressed to

25     the Ministry of the Interior of Serbia and the Government of Serbia.

Page 12788

 1        Q.   You are talking about the Golubic centre?

 2        A.   Yes.  We did not say at the time that it would be a centre at

 3     Golubic.  We asked for assistance, for help, and the result of this

 4     request of Babic's, i.e., of the decision of the National Serbian Council

 5     and Babic's request, was the setting up of the Golubic centre.

 6        Q.   Did you receive -- as a political leader, did you receive

 7     information regarding high-level visits to Knin?  So if Knin was visited

 8     by certain high-level leaders, did you receive information about that if

 9     they were visiting but not attending your meetings?

10        A.   Well, as a rule we received information as to with whom they had

11     talked, who came to Knin, with whom they had talked in Belgrade, what was

12     being planned, and such.

13        Q.   You say "as a rule," so was there a system of reporting,

14     briefing, in place for this kind of information?

15        A.   Well, we were more or less informed about what transpired between

16     the two meetings of the Main Board.

17        Q.   Did you have an influence over how much information you received?

18     So you say you were more or less informed; did you have an opportunity to

19     put questions and receive answers or were you just informally informed?

20        A.   No, one could ask questions, one could make proposals, one could

21     seek clarifications and explanations.

22        Q.   Now, you talked about your role in the Main Board.  You also

23     talked about your role locally on the ground.  How many different

24     municipalities were represented in the Main Board meetings?

25        A.   All the municipalities were represented at the Main Board

Page 12789

 1     meetings, all the municipalities, what used to be SAO Krajina, I believe

 2     there were 13 of them.  Then Pakrac, Podravska Slatina, Daruvar,

 3     Grubisno Polje, and some other municipalities of Western Slavonia were

 4     also represented.  And there were representatives from Eastern Slavonia,

 5     Vukovar, and some other places.  I cannot recall all of them at this

 6     point.  So from all areas where Serbs lived and where chapters of the SDS

 7     had been set up.  Later when the situation became more critical and with

 8     a split in the SDS, it was only members from areas where the Serbs

 9     accounted for a majority, where they wished to create a compact

10     territory, that is, members of the Krajina SDS.

11        Q.   And you were representing Slunj municipality; is that accurate?

12        A.   I was representing Vojnic municipality because it was in the

13     municipality of Vojnic that the SDS was formed first.

14        Q.   Were you also informed of activities in other municipalities?

15        A.   Yes, as far as Kordun is concerned.  And I also took part in

16     them.  And of these, I would be informed occasionally if I was interested

17     in some specific issues or if something was of importance to the Krajina.

18        Q.   Yesterday you said that you were aware of those who were trained

19     in Golubic from Kordun but you were not aware of those who were trained

20     in Golubic from other municipalities.  Can you tell us about the

21     information that you received on the matter of training.  Was there a

22     system of reporting on training activities from the different

23     municipalities?

24        A.   There was a difference between Dalmatia and [indiscernible] on

25     the one hand and Kordun and Banija on the other hand.  Mainly, the police

Page 12790

 1     units, the existing police units, still failed to accept Martic as their

 2     secretary in Vojnic and Vrginmost, et cetera.  And because of that, the

 3     selection of the trainees was conducted through the parties.  And in

 4     municipalities where the police had already accepted Martic as the

 5     secretary and had accepted the statute and what have you, as everything

 6     as -- which was [indiscernible] by a unified territory, they proposed

 7     their candidates.

 8        Q.   Now, if you were not specifically aware of those who were trained

 9     from other municipalities, wouldn't it flow from that that you were in

10     fact not aware of events in relation to other municipalities unless it

11     reached the RSK political agenda?

12        A.   It was lads from all the municipalities in the Krajina area that

13     went for training to Golubic.  The task was that lads should be trained

14     from all municipalities.  It was just that they were selected in one way

15     in one part of the area and in another way in another part, but the

16     general stance was that people from all areas should be sent for training

17     there.

18        Q.   So when you said before that you were not aware of people sent

19     for training from other municipalities, you actually are aware of people

20     sent from other municipalities?  In other words, that wasn't accurate

21     what you said yesterday.

22        A.   I did not know the people.  I did not know those people.  And I

23     did know those hailing from Kordun and those who were trained.  That is

24     what I meant.  That is what I said.  From the area of Kordun, I knew the

25     people who went there for training and I did not know the others who went

Page 12791

 1     there from other areas, so I was talking about concrete people.

 2        Q.   Thank you for the clarification.

 3             Can you give us the names of the individuals from Kordun who were

 4     sent for training in Golubic?

 5        A.   I can give you some names that I can recall.  Zlatko Dmitrovic, a

 6     lad whose nickname was Oroz, then Topic, Ilija Saula, and I cannot

 7     remember any other names now.  It would take me some time to go back.

 8     These are the ones I could recall at this moment.

 9        Q.   We'll have an opportunity to talk again tomorrow.  I'd like to

10     ask you, if you could, to try to turn your mind to that and think of some

11     other names.

12             Now, while we do that, these individuals whose names you

13     mentioned, or nicknames, were they in the first group at Kordun or the

14     second group?  The first group from Kordun, sorry.

15        A.   I cannot remember now exactly who was in what group exactly.  I

16     believe that Mitrovic and Saula were in the first group, but I'm not sure

17     of that.  It is Dmitrovic.  Dmitrovic, not Mitrovic.  D-m-i.

18        Q.   Do you know if any of those individuals were among the ones who

19     stayed at Golubic for on-going training, to provide the training?

20        A.   Not as far as I know.  Not the people that I just named.

21        Q.   Can you name for us any of the individuals from Kordun whom you

22     knew to have remained behind and continued on-going training at Golubic?

23        A.   No, I cannot.

24        Q.   At the time were you provided with a list of those names?  Did

25     you receive a report, detailed reports, about those who were sent from

Page 12792

 1     Kordun to Golubic?

 2        A.   No.

 3        Q.   Your statement in paragraph 12 about never having heard that

 4     Jovica Stanisic had anything to do with Knin or Golubic is in contrast to

 5     your words in paragraph 70 in which you state categorically that Stanisic

 6     did not order the setting up of police stations.  If you had not heard

 7     that Jovica Stanisic had anything to do with Knin, then how are you able

 8     to state categorically what he did or did not do?

 9        A.   I was asked whether he did that.  I categorically said that he

10     didn't do it, that we did it, and that it had nothing whatsoever to do

11     with Jovica Stanisic.

12        Q.   Surely all you can say is what you knew of based on what you were

13     informed of; isn't that accurate?

14        A.   Well, absolutely.  It was me who negotiated with representatives

15     of the police in Kordun to accept Martic's secretary.  It was me, myself,

16     and some other activists of the SDS.  We had meetings with the police

17     representatives until the 31st of June -- who were until the 31st of July

18     in contact with Zagreb.  And that is when their relationship with the MUP

19     of Croatia was severed.  Jovica Stanisic has nothing whatsoever to do

20     with that story.  I was the one who exerted pressure on them at meetings

21     to join the police of the Krajina, pursuant to our position that all

22     municipalities in the area of the SAO Krajina should accept the statute

23     of the SAO Krajina and join the SAO Krajina.

24             This did not happen all at once.  This was a process.  The

25     process of the inclusion of the joining of the municipalities of Kordun

Page 12793

 1     and Banija to the SAO Krajina and their adoption of the statute of the

 2     SAO Krajina was a process which took some time.  It wasn't something that

 3     happened at one fell swoop.  The assemblies of the local governments had

 4     to adopt a decision to the effect that they were accepting the statute of

 5     the SAO Krajina and that they accepted and they were an integral part of

 6     the SAO Krajina.

 7             After that we exerted pressure on the existing police force to

 8     sever its relationship with Zagreb and to accept Martic as secretary.  So

 9     this was done by the SDS activists at meetings with representatives of

10     the local police.  I specifically with representatives of the Kordun

11     police.

12        Q.   Thank you.  Now, my question was about your comments in your

13     statement about Stanisic's involvement in Knin or Golubic, whereas your

14     answer was in relation to Kordun and Banija.

15             MR. JORDASH:  Well --

16             THE WITNESS: [Interpretation] You asked me about the involvement

17     of the police.  His involvement in the establishment of the police.  He

18     was not involved in the establishment of the police; the police already

19     existed.

20             MS. MARCUS:

21        Q.   And you're talking about in Kordun and Banija; is that correct?

22        A.   I was talking about the concrete way in which we asked for the

23     Kordun and Banija police to accept joining the SAO Krajina and to accept

24     Martic as the secretary of the Secretariat of the Interior of the

25     SAO Krajina.

Page 12794

 1        Q.   I have to ask you a clarification about paragraph 18 of your

 2     statement, where you say that Milan Martic had no influence in Kordun and

 3     Banija at this time.  That's what I wanted to clarify with you.

 4             In the next sentence you say that Martic's influence was accepted

 5     as of August 1991.

 6             Can you just clarify for us what time-period it was that you were

 7     referring to when you said Martic had no influence in Kordun and Banija?

 8     Do you mean prior to August 1991?

 9        A.   Yes, yes, prior to August.  Definitely.  The process of the

10     establishment of the entire system in the SAO Krajina, including Kordun

11     and Banija, ended at the end of July, sometime after these events in

12     Glina.  That's about the time when this process was completed, the

13     process of the institutionalised consolidation of the Serbian Autonomous

14     District of Krajina.

15             JUDGE ORIE:  Ms. Marcus, I'm looking at the clock.  I promised

16     Mr. Jordash five minutes, although it was also in your own interest that

17     he would use those five minutes.  Therefore I would -- if this would be a

18     suitable moment, we would adjourn for the day.

19             MS. MARCUS:  Yes, Your Honour, I was just going to suggest that.

20             JUDGE ORIE:  Yes.

21             Mr. Bosnic, we adjourn for the day.  We'll continue tomorrow

22     morning at 9.00 in the morning in this same courtroom.  I again instruct

23     you that you should not speak or communicate -- yes, if you just let me

24     finish then I give you an opportunity to say something.

25             That you should not speak or communicate in any other way with

Page 12795

 1     whomever about your testimony.

 2             You would -- you wanted to ask or say something?  Please.

 3             THE WITNESS: [Interpretation] Yes.  I should like to know

 4     approximately when my examination will be generally concluded because I

 5     have a private problem which I would have to deal with on Monday.  So I

 6     would appreciate knowing this as soon as possible because my presence is

 7     required there.  I hope to be able to deal with that problem personally,

 8     but if I am unable to do that, I hope to be able to do that through the

 9     services here.

10             JUDGE ORIE:  A short question to Ms. Marcus:  How much time would

11     you think you would need?

12             MS. MARCUS:  I think I would use two sessions, tomorrow,

13     Your Honour.

14             JUDGE ORIE:  Two sessions.  That would -- of course you do not

15     know yet, Mr. Jordash, what Ms. Marcus is going to ask about, but is

16     there a fair chance that we would finish tomorrow?

17             MR. JORDASH:  I think a very good chance.

18             JUDGE ORIE:  In view -- Mr. Petrovic, I'm also looking at you, I

19     therefore -- the parties have an expectation, Mr. Bosnic, that we might

20     conclude tomorrow.  Now, I have been disappointed now and then in my

21     life, but I hope that it's not going to happen tomorrow.  Could you

22     please follow the usher.

23             THE WITNESS: [Interpretation] I also hope so.  Thank you.

24                           [The witness stands down]

25             JUDGE ORIE:  Mr. Jordash.

Page 12796

 1             MR. JORDASH:  As I understand the Prosecution complaint, they

 2     suggest, one, that we are in position of a statement for the next

 3     witness, DST-043, sorry, the next-but-one witness, and the witness after

 4     that, DST-074, and they'd like that disclosed.  And, in short, we are not

 5     in possession of a statement for those two witnesses.  And perhaps it's

 6     our fault for the way in which the previous statements have been drafted,

 7     which perhaps hasn't made clear the process.

 8             But if I can use the present witness as an example, DST-031.  His

 9     statement details the interview dates 21st of September, 2006; 17 and

10     20th of May, 2011; and the 1st of June, 2011.  A statement was then

11     served on the Prosecution on the 5th of July -- 6th of July.  It was

12     completed on the 5th of July inasmuch as the witness -- it was compiled

13     between -- the notes were used to compile the statement between the

14     1st of June and the 5th of July, the witness then checked the statement,

15     it was translated in -- before the witness checked, into B/C/S so that

16     the witness could check it.  It was signed on the 5th and served on the

17     6th.

18             JUDGE ORIE:  Yes, it's clear that you say the difference in time

19     is explained by the way in which we process these statements.

20             MR. JORDASH:  I can assure the Court 100 per cent that as soon as

21     a statement has been completed - and what I mean "completed," I mean put

22     into a form which reads like a statement, not just signed by the

23     witness - it is served upon the Prosecution.

24             JUDGE ORIE:  Yes.  Okay.  That is -- that is as far as the

25     critical words are concerned about what happened in the past.  Now, you

Page 12797

 1     say for the next two witnesses there are no statements.

 2             MR. JORDASH:  There are no statements.

 3             JUDGE ORIE:  So a 65 ter summary should be the basis for the

 4     Prosecution to prepare?  Is that ...

 5             MR. JORDASH:  Yes, we are -- I mean, we appreciate that we are

 6     disclosing statements pursuant to 92 ter later than the rule suggests.

 7     We are trying to assist the process.  We didn't have the opportunity to

 8     complete those statements before the Defence started.

 9             JUDGE ORIE:  But do you expect for the next witnesses that

10     statements will be there, that you will tender them under Rule 92 ter?

11             MR. JORDASH:  Well, with the next witness, DST-074, we -- it

12     depends upon Your Honours, and this is a matter we wanted to address with

13     Your Honours, that the next witness may well start tomorrow.  If he

14     doesn't start tomorrow, he starts next week.  We anticipate he will take

15     probably two to two and a half sessions, depending upon the length of

16     cross-examination.  So we are at this moment in a quandary as to whether

17     we ask the witness after that to come to The Hague.  If he is coming to

18     The Hague next week, then we will not have the time to complete a 92 ter

19     statement.  If he's not coming until after the summer, we will certainly

20     produce that statement and disclose it over the summer.

21             JUDGE ORIE:  Yes.  Now, from the estimates given, I take it that

22     we'll need tomorrow for this witness.  And so there's -- it might not

23     make much sense to start for three or five minutes with the next witness.

24             Ms. Marcus, you have at least received an answer.  Whether you

25     are happy with it, of course, is a different matter.

Page 12798

 1             MS. MARCUS:  Thank you, Your Honour.  Yes, I'm not going to go

 2     into the position on what is a witness statement.  We are litigating that

 3     in writing, as Your Honours know.  The only thing I would mention is that

 4     the Defence did provide to us a statement for Mr. Bosnic which was in

 5     draft form.  So I just wonder -- it was not signed, it had a heading on

 6     the top that said "draft, to be reviewed, not confirmed by the witness,"

 7     et cetera.  Now, so it appears to me, then, that the time between the

 8     1st of June and that -- and the 6th of July was used to type it up.  It

 9     certainly wasn't used to confirm it with the witness, or I don't know if

10     it was or wasn't, but that's quite a long time.  And if it's simply about

11     form, it seems to me that the form, again, is over the substance in terms

12     of the notice requirements.

13             The last thing I would say, Your Honours, is that the 92 ter

14     statement for DST-043 was received, I think, yesterday with the witness

15     anticipating starting his testimony -- we all anticipated that he might

16     start tomorrow, so the -- it's somewhat of an understatement that my

17     colleague has said with respect to the lateness of the 92 ter filings.

18             JUDGE ORIE:  Yes.  Mr. Jordash, any need to respond to this?

19             MR. JORDASH:  Only that I think -- if I may, just briefly.  We

20     did serve a draft upon the Prosecution because it was in a format we felt

21     was sufficient for --

22             JUDGE ORIE:  Yes, you don't have to explain to us why you did

23     that.  It was apparently appreciated.  If there's any opportunity to do

24     it again, I think Ms. Marcus would be happy.

25             MR. JORDASH:  And we would do that for sure.  We certainly would

Page 12799

 1     do that.

 2             In relation to the next witness, we did serve the statement

 3     yesterday.  But with the anticipated length of cross-examination

 4     indicated by my learned friend and by the Simatovic team, we did not

 5     anticipate the witness would start tomorrow, hence we wanted to give the

 6     Prosecution a week to review that statement.

 7             JUDGE ORIE:  You say we may have been late but not as late as

 8     perceived by those who thought that the testimony would start tomorrow.

 9             MR. JORDASH:  Yes.

10             JUDGE ORIE:  Yes.  Let's keep matters short.  We adjourn for the

11     day.  And we'll resume tomorrow, Thursday, the 14th of July, at 9.00 in

12     this same Courtroom II.

13                           --- Whereupon the hearing adjourned at 1.50 p.m.,

14                           to be reconvened on Thursday, the 14th day of

15                           July, 2011, at 9.00 a.m.