Tribunal Criminal Tribunal for the Former Yugoslavia

Page 13147

 1                           Tuesday, 16 August 2011

 2                           [Open session]

 3                           [The accused entered court]

 4                           --- Upon commencing at 2.20 p.m.

 5             JUDGE ORIE:  Good afternoon to everyone.

 6             Madam Registrar, would you please call case.

 7             THE REGISTRAR:  Good afternoon, Your Honours.

 8             This is case IT-03-69-T, The Prosecutor versus Jovica Stanisic

 9     and Franko Simatovic.

10             JUDGE ORIE:  Thank you, Madam Registrar.

11             Before we continue, I'd like to put on the record that we

12     received an e-mail today at 1.25 p.m.  We received it from

13     Mr. Scott Martin, who adds to the information about the outstanding

14     translations.  There seems to be a disagreement between CLSS and the

15     Stanisic Defence.  And even if we take into account a few additional

16     matters such as rejected documents, that still there is no full agreement

17     on how many pages are outstanding or not.

18             Also, the Chamber is, of course, not aware of the reasons for the

19     rejection of certain documents.  We were informed that they'll be -- that

20     the Defence anticipates that they'll resubmit these documents.  The

21     e-mail also informs the Chamber that the Defence is currently

22     investigating why there exists such a difference.

23             The Chamber will ask, anyhow, for further submissions on the

24     matter, on short notice.  You will most likely receive an e-mail

25     indicating that very soon.  And we'll also ask for CLSS registry

Page 13148

 1     submissions under Rule 33(B) but also on very short notice in order not

 2     to lose any further time.

 3             Now, of course it would be helpful and the Chamber would

 4     encourage the Stanisic Defence to communicate with CLSS in such a way

 5     that it's clear where the disagreement lies, so that we don't have to

 6     spend too much time on that.  And it's -- in general terms, if there is a

 7     disagreement between one of the teams, whether Prosecution or Defence,

 8     and one of the services of the registry, it's always preferred to first

 9     see whether -- to find out together what the basis of the disagreement is

10     and to see how to resolve that.

11             I put this already on the record, and the Chamber will, from -- I

12     think that we'll request for further information still to be delivered

13     this week, to be submitted this week, so that we can consider that

14     further information.  That might also include why the documents that were

15     rejected, why they were rejected, because that is not explained in the --

16     in the e-mail.

17             Then we move on.  Is the Stanisic Defence ready to call its next

18     witness?

19             Yes.  Now, we'll move into closed session.

20     [Closed session]   [Confidentiality partially lifted by order of the Chamber]

21                           [Trial Chamber and Registrar confer]

22             JUDGE ORIE:  Mr. Jordash, the first thing the Chamber intends to

23     do if the closed session is effective, and we'll hear from

24     Madam Registrar whether it is --

25             THE REGISTRAR:  We're in closed session, Your Honours.

Page 13149

 1             JUDGE ORIE:  Thank you, Madam Registrar.

 2             -- is to ask the witness whether he has any personal reasons for

 3     the protective measures which were requested by Serbia.  I don't know

 4     whether you have any information about that.  If not --

 5             MR. JORDASH:  That's why I was on my feet, Your Honour.  The

 6     witness isn't asking for protective measures for --

 7             JUDGE ORIE:  The witness may be brought into the courtroom.

 8             MR. JORDASH:  The witness isn't asking for protective measures

 9     for personal reasons.

10             JUDGE ORIE:  Okay.  Then we'll tell him that he testifies with

11     the protective measures exclusively because they were asked for by the

12     Republic of Serbia.

13                           [The witness entered court]

14             JUDGE ORIE:  Good afternoon, Witness DST-074.  Before you give

15     evidence in this court, the Rules require that you make a solemn

16     declaration, of which the text is now handed out to you by Madam Usher.

17             May I invite you to make that solemn declaration.

18             THE REGISTRAR:  I solemnly declare that I will speak the truth,

19     the whole truth, and nothing but the truth.

20                           WITNESS:  DST-074

21                           [Witness answered through interpreter]

22             JUDGE ORIE:  Thank you, Witness DST-074.  Please be seated.

23              Witness DST-074, we are in closed session, which means that no

24     one sees or hears out -- outside this courtroom what we are saying.  The

25     protective measures in place also include face distortion and voice

Page 13150

 1     distortion, which means that the recording doesn't show your face.  It's

 2     scrambled.  And on the recording, at this moment at least, no one can

 3     hear your own voice.  This is all done at the request of the

 4     Republic of Serbia.

 5             I was informed by Mr. Jordash, Defence counsel, that you had no

 6     personal reasons for asking for protective measures.  Is that accurate?

 7             THE WITNESS: [Interpretation] That is accurate.  I don't have any

 8     personal reasons to ask for protective measures.  I'm not ashamed of what

 9     I did.

10             JUDGE ORIE:  Then just for your information, the Chamber is

11     seeking additional information from the Republic of Serbia.  So the final

12     decision on whether the content of your testimony will be public or not

13     depends on the decision still to be taken by this Chamber on the basis of

14     additional information we've asked for.  So for you, don't be surprised

15     if at any later stage your testimony will become public.  That's also the

16     reason why I asked you whether you had any personal reasons, but

17     apparently you have not.

18             Then, Mr. Jordash, are you ready to start your examination?

19             MR. JORDASH: [Microphone not activated] Your Honours, yes.

20             JUDGE ORIE:  Yes, perhaps also for your information: Because of

21     these protective measures, we do not call you by your own name.  We call

22     you Witness DST-074.  But, again, it is possible that at a later stage

23     your own name will become public.

24             Mr. Jordash is counsel for Mr. Stanisic, and he'll start his

25     examination.

Page 13151

 1             Now, Mr. Jordash, initially the witness was scheduled for two and

 2     a half hours viva voce, and now he's still on two and a half hours under

 3     92 ter, which comes a bit as a surprise, but also looking at the rather

 4     extensive 92 ter statement.  But I -- as always, I encourage you to be as

 5     efficient as possible, not to waste any time, and to be as focussed as

 6     possible as well.  Please proceed.

 7             MR. JORDASH:  I will certainly do my best.

 8             Unfortunately, the pseudonym sheet isn't uploaded, but if I may

 9     hand out copies.  And one copy for the witness, and for the Trial Chamber

10     and the parties, please.

11             JUDGE ORIE:  Take care that it will be uploaded as soon as

12     possible.

13             MR. JORDASH:  Yes.

14                           Examination by Mr. Jordash:

15        Q.   Good afternoon, Mr. Witness.

16        A.   Good afternoon.

17        Q.   Would you please have a look at the document in front of you,

18     which contains personal details, name, and date of birth, and confirm

19     whether they are accurate?

20        A.   The information on this sheet is accurate.

21        Q.   Thank you.

22             MR. JORDASH:  May I tender this, Your Honour.

23             JUDGE ORIE:  Madam Registrar, the pseudonym sheet would receive

24     number ...

25             THE REGISTRAR:  This would be exhibit D333 under seal,

Page 13152

 1     Your Honours.

 2             JUDGE ORIE:  D333 is admitted under seal.

 3             MR. JORDASH:  Could document 1D5000 please be brought to the

 4     monitor.

 5        Q.   Mr. Witness, there's going to be a document on the screen - it's

 6     there now - purporting to be a statement given by you on the

 7     25th of May, 2011, and the 5th of August, 2011.  Do you recall giving a

 8     statement to members of the Stanisic Defence on those dates?

 9        A.   I gave the statement, I read it, and I signed it with my own

10     hand.

11        Q.   Do you recognise the signature?

12        A.   I've just told you that I signed it with my own hand.  This is,

13     indeed, my signature.

14        Q.   And did you sign every page?

15        A.   Each and every page.

16        Q.   And you've just said you have read it.  Did you have a good

17     opportunity to carefully review it before coming to court today, in your

18     own language?

19        A.   This is my statement.  I dictated it, I read it, and if there was

20     need to make any changes, I made them.

21             MR. JORDASH:  Could we have, please, on the screen 1D4976.

22        Q.   Do you recall reviewing the statement we've just had on the

23     screen and making amendments which were recorded in the document which

24     you have in front of you?

25        A.   Yes.  I signed that yesterday.

Page 13153

 1        Q.   Apart from those changes, is there anything else that you wish to

 2     change in the first statement we saw on the screen?

 3        A.   No.

 4        Q.   And the statement and the corrections which we have in front of

 5     us, are they in accordance with the truth?

 6        A.   I swore that I would be telling the truth.  I did it before, and

 7     I can -- I intend to do so in the future.

 8        Q.   And if asked the same questions in substance, would you give the

 9     same answers as you did within your statement and the corrections in the

10     proofing note?

11        A.   I told the truth.  There's no reason why I shouldn't repeat it.

12             MR. JORDASH:  May I tender the witnesses statement and the

13     proofing note.

14             MR. FARR:  Your Honour, I just wanted to put on the record that

15     this statement was disclosed on the 10th of August, which is

16     approximately two months after the disclosure deadline provided for in

17     Rule 67(A)(ii) and in the Chamber's order.  The late disclosure of

18     92 ter statements in this case is an ongoing problem that the Chamber is

19     well aware of and that the Defence acknowledges.

20             It's a problem not just with respect to this statement but also

21     with respect to witness statements from other witnesses who will testify

22     about the same matters as this witness, since we don't yet know the

23     entirety of the Defence case.

24             It was our understanding based on counsel's representations prior

25     to the recess that all 92 ter statements would be completed and disclosed

Page 13154

 1     before the end of the recess, but that doesn't appear to have happened.

 2     In this particular instance, and in the interest of efficiency, we don't

 3     object to the admission of this statement pursuant to Rule 92 ter, but we

 4     reserve the right to ask for other relief if it later becomes apparent

 5     that other relief is required as a result of a late disclosure.

 6             JUDGE ORIE:  Mr. Farr, your observations are on the record.

 7             Since the Defence does -- the Prosecution does not object to the

 8     admission of the statement and the proofing note, Madam Registrar, the

 9     number of the statement would be ...

10             THE REGISTRAR:  The number would be D334, Your Honours.

11             JUDGE ORIE:  And the number to be assigned to the proofing note

12     would be ...

13             THE REGISTRAR:  The number would be D335, Your Honours.

14             JUDGE ORIE:  D334 and D335 are admitted into evidence under seal.

15             MR. JORDASH:  May we have, please, on the screen 1D4929.

16        Q.   Before you, Mr. Witness, is a chart, as you can see.  Do you

17     recall being given in the last two days a number of documents to review

18     with this chart, with a space for comments on the right-hand side?

19        A.   I got a file containing some documents.  There was a chart in

20     front of those documents.  It contained the number of those documents.

21     And whatever I knew with regard to each particular document, I noted in

22     the chart.

23        Q.   And did you have an opportunity to review the chart and make any

24     clarifications or corrections that you wished to make?

25        A.   I've just told it, that I provided all the information that I had

Page 13155

 1     with regard to each and every document.  I recorded that information in

 2     the chart.

 3        Q.   And what you recorded was in accordance with the truth?

 4        A.   This is what I know.  This is the truth, and I adhere by that.

 5        Q.   And these are the comments you'd make in relation to these

 6     documents, and these are the answers you'll give in relation to any

 7     questions on the documents?

 8        A.   I could tell you differently only if I wanted to lie.  But I'm

 9     not here to lie.  This is the truth.  This is what I have noted.  And

10     this is all I have to say.

11        Q.   Thank you.

12             MR. JORDASH:  Now, could we have -- oh, could I tendered this

13     chart.  There is a number of objections or issues which need to be

14     resolved before all the exhibits -- until the Prosecution withdraw any

15     objections to a number of exhibits, but may I tender the chart and MFI it

16     at this point?

17             JUDGE ORIE:  Yes, if you would just give me one moment to look at

18     a few ...

19             One second, please.

20                           [Trial Chamber and Registrar confer]

21             JUDGE ORIE:  Sorry, but I have to verify one thing.

22             You called -- Mr. Jordash, you asked to have on the screen

23     1D4929, and that is a chart.  At the same time, Madam Registrar informs

24     me that 1D4929 was MFI'd as D327.  I'm unable to verify that because what

25     we see on our screen is a chart, so I'm slightly confused about

Page 13156

 1     the situation --

 2             MR. JORDASH:  And this isn't the right chart.  This is for

 3     DST-043.  This witness is DST-074, so ...

 4             JUDGE ORIE:  Yes, so perhaps you need to invent another number to

 5     get the right chart on your -- on the screen.

 6                           [Trial Chamber and Registrar confer]

 7             JUDGE ORIE:  Yes, Madam Registrar informs me that what was

 8     uploaded as a chart of exhibits for DST-074 as it is stated in the

 9     12.15 p.m. e-mail on the 16th of August is that the chart is 1D04977.

10             So if that's the chart you'd like to be shown on the screen --

11             MR. JORDASH:  It is.  Apologies.

12             JUDGE ORIE:  And we lost two minutes, but at least we avoided

13     further confusion.

14             Madam Registrar, could we have 1D04977 on the screen.

15             Is this the right chart, Mr. Jordash?  It looks as if it is.

16             MR. JORDASH:  Yes, it is.

17        Q.   Do you recognise the signature, Mr. Witness?

18        A.   Yes, this is my signature.

19        Q.   Do you recognise the comments against the description of the

20     documents?

21        A.   Can this be blown up a little?  I'm not -- unable to read

22     everything very clearly.

23             Yes, these are my comments.

24        Q.   And what you said a few minutes ago about filling in the chart,

25     it being the truth, and those comments reflecting what you had to say

Page 13157

 1     about the documents, do you stick by that in relation to this document

 2     which you signed?

 3        A.   [No interpretation]

 4             MR. JORDASH:  No interpretation.

 5             THE INTERPRETER:  Interpreter's apologies.  It was the wrong

 6     channel.

 7             The witness said:  There's no reason why I shouldn't stick by

 8     what I said, namely that these are my comments and the documents I

 9     reviewed.

10             JUDGE ORIE:  Please proceed, Mr. Jordash.

11             MR. JORDASH:  Thank you.  May I tender this chart.  If it could

12     be MFI'd until certain issues are resolved between myself and Mr. Farr.

13             JUDGE ORIE:  Mr. Farr.

14             MR. FARR:  Your Honour, if Mr. Jordash is just asking it to be

15     marked for identification, then obviously there's no objection to that.

16             JUDGE ORIE:  Yes.  Could the number -- could a number be assigned

17     to this document to be marked for identification under seal.

18             THE REGISTRAR:  This would be D336, Your Honour.

19             JUDGE ORIE:  D336 is marked for identification, under seal.

20             Madam Registrar, perhaps you could already anticipate

21     for [Realtime transcript read in error "four"] numbers to be assigned to

22     documents appearing in this chart which have not yet received exhibit

23     numbers so that we know how many numbers to reserve.

24             Please proceed.

25             MR. JORDASH:  Could we have, please, 1D5001.

Page 13158

 1                           [Defence counsel confer]

 2             MR. JORDASH:  I don't know if this is correct or not, but in

 3     relation to the last exhibit number, I think we have skipped D333.  I

 4     don't know if that that's correct or not, but --

 5             THE REGISTRAR:  D333 is pseudonym sheet.

 6             MR. JORDASH:  Right.  Thank you.

 7        Q.   Look at the screen, Mr. Witness.  Have you seen the map before?

 8     Are these the locations which you wish to discuss and have discussed in

 9     your statement and will discuss in your testimony in court?

10        A.   These are the places where I spent about four and a half months

11     working.

12             MR. JORDASH:  Could I just inquire as to whether Your Honours

13     have a paper copy.

14             JUDGE ORIE:  We received a paper copy.

15             MR. JORDASH:  Thank you.

16        Q.   I have been asked by the Prosecution to have you identify

17     Novi Sad.  Would you indicate, please, where Novi Sad is?

18        A.   We would need to move the map a little for me to find it.  It's

19     not here.  Zrenjanin, Backi Jarak, Backi Petrovac, Becej.  I can't see

20     it.  Give me a moment.  Right.

21             How come I can't find it?  After Backi Jarak I should see

22     Novi Sad, but it's not there.

23             It's not on the map.  There's Petrovaradin.  Petrovaradin is a

24     suburb of Novi Sad.

25             JUDGE ORIE:  Mr. Farr.

Page 13159

 1             MR. FARR:  Your Honour, that's why I brought it up, just because

 2     it's an important location that for some reason didn't print on this map.

 3     We agree with the witnesses that it's next to Petrovaradin.  If he could

 4     perhaps just mark an S for Novi Sad by the location that he's just

 5     circled, then the map would be useful to everyone looking at his

 6     testimony.

 7             JUDGE ORIE:  Yes.  So where we -- where the witness marked this

 8     document with the red circle, that's the area where we are supposed to

 9     find Novi Sad.

10             MR. FARR:  That's our understanding, Your Honour, yes.

11             JUDGE ORIE:  Yes.  Now, I guess that the Chamber would have found

12     Novi Sad anyhow.

13             MR. JORDASH:  I'm not sure why it's missing, actually.  It's --

14             JUDGE ORIE:  Neither do I.

15             MR. JORDASH:  I hadn't even noticed that.

16             JUDGE ORIE:  Yes.  Okay.  Let's proceed.

17             May I take it that you would only need a number to be assigned to

18     the marked map, which contains all the information and, in addition to

19     that, the red circle indicating where approximately to find Novi Sad?

20             MR. JORDASH:  Yes, please.

21             JUDGE ORIE:  Madam Registrar, the number for this map would

22     be ... as marked by the witness ...

23             THE REGISTRAR:  The number would be D341, Your Honours.

24             JUDGE ORIE:  D341 is admitted into evidence.  Although the red

25     circle has now disappeared, I take it that, as marked, it is admitted

Page 13160

 1     into evidence.  There is no need to have it under seal, I take it.

 2             Then, talking about admission of documents, Mr. Jordash, I

 3     earlier encouraged you to upload the pseudonym sheet.  Now, the witness

 4     has told us that the information is accurate.  The form, however, says

 5     something about the signature.  I'm not urging you to have it signed, but

 6     if you use forms where a signature is expected to be put on the form,

 7     then perhaps for the future it would be better to really have that

 8     signature.  But there's no doubt, I think, about, even without a

 9     signature, that the witness stated that the information is accurate.

10             Please proceed.

11             MR. JORDASH:  Thank you.

12        Q.   Now, Mr. Witness, I'd like to take you through some of the

13     evidence which is now before the Court and ask you to elaborate on some

14     of it and clarify some of it.  Bear in mind that the Court now has your

15     statement and the corrections and the chart.

16             Please could we have D334 on the screen.

17             Could we go to page 3, paragraph 6.

18             JUDGE ORIE:  Would it be preferable to have both the B/C/S and

19     the --

20             MR. JORDASH:  Yes, it certainly would.

21             JUDGE ORIE: -- and the English?  And not two times the English

22     text.  Yes, we have it now.

23             Could we move to the right paragraph in B/C/S.

24             Yes, please proceed.

25             MR. JORDASH:

Page 13161

 1        Q.   Now in paragraph 6 you testify to the engagement of PJM units in

 2     1991.  "... engaged to assist because of an increased level of security

 3     risk."  And in paragraph 7, you speak and elaborate about these PJM

 4     units.

 5             Are you able to describe the nature of their tasks, generally?

 6        A.   Within the provincial SUP, Secretariat for Internal Affairs at

 7     Vojvodina, there was also a specialised police unit at the time, and they

 8     would be engaged on an ad hoc basis depending on the assignment put

 9     before them.  Their basic tasks were to keep law and order, especially

10     during mass events such as football matches and rallies.  Their second

11     task was to provide VIP security for VIPs coming to Vojvodina.  And from

12     1990 to 2000 we were engaged in Kosovo, especially the border area and

13     the border area with Croatia.

14        Q.   And in which way were they specialised?

15        A.   They were not the special unit.  They were not specially trained

16     for any kind of operation.  Those were members of the regular police,

17     mainly young people who had completed training in various courses aged up

18     to 35.  They were drawn from police stations across the territory of

19     Vojvodina, and that is how several such units were formed within the

20     provincial SUP.

21        Q.   And just so that we're clear: When you say "within the provincial

22     SUP," are we -- are you talking about the public security or the state

23     security?

24        A.   I can only speak to the sector of public security, because I

25     never worked in state security.

Page 13162

 1        Q.   Did the PJM units have anything to do, in terms of chain of

 2     command or reporting, to the DB of Vojvodina?

 3        A.   No, we were not under the command or in obligation to report to

 4     state security employees.

 5        Q.   What was the basic structure of the provincial SUP, the

 6     Vojvodina provincial SUP?

 7        A.   Unlike other republics, the Republic of Serbia had three

 8     secretariats, one for central Serbia, Serbia proper, and two for each of

 9     the autonomous provinces.  As far as Vojvodina is concerned, it had a

10     provincial SUP with its public and state security sectors, and each of

11     them had a chain of command.  There was six secretariats:  Sombor,

12     Apatin, Zrenjanin, Novi Sad, Mitrovica, and Subotica.

13             If you want me to, I can explain the structure in greater detail

14     within each secretariat.  For instance, there were OUPs, organisational

15     units, but I don't think it's relevant to the case.

16        Q.   You've named, I think -- well, what's been picked up by

17     translation, of the six secretariats we have Novi Sad, Mitrovica,

18     Subotica.  What were the other three secretariats of the Vojvodina SUP?

19        A.   Sombor, Subotica, Mitrovica, Pancevo, Zrenjanin, Novi Sad.

20        Q.   And just briefly, what was the relationship between the

21     Vojvodina SUP and the Serbian MUP in 1991?

22        A.   We had our own secretary of the provincial SUP, whereas the

23     republic SUP had its own secretary at the level of the republic.  But I

24     can say we worked autonomously.

25        Q.   And the secretary was the top of the organisation; is that right?

Page 13163

 1        A.   Yes.  The provincial secretary headed the secretariat and had two

 2     under-secretaries, one in charge of public security, another in charge of

 3     state security.  At that time, Markov was the name of the provincial

 4     secretary.  Predrag Markov.

 5        Q.   Looking at paragraph 7, you testified to the four PJM units being

 6     subordinated to Zavisic, who was the commander of the police station in

 7     Novi Sad and the commander of the four PJM units.

 8             Who did Zavisic report to?  Who -- what was the hierarchy above

 9     him?

10        A.   At that time, Zavisic was commander of the police station in

11     Novi Sad, in charge of duty service and interventions.  Within the PJP,

12     he was company commander.  And he commanded a unit that covered the

13     sector from Mitrovica to Apatin.

14        Q.   And who did he report to?  Let me try to shortcut this.

15             In paragraph 8, you note that Zavisic was reporting to a

16     department within the public security service and he was answerable to

17     the head of the public security of the PSUP, Vojvodina.  Do you see that?

18        A.   I can see that passage.  As far as reporting is concerned, within

19     the provincial SUP there was a department for the PJP, and the detachment

20     commander was Momo Stojanovic, and there were also Stanoje Milanovic,

21     Marinko Kresoja, and a large number of officers from the provincial SUP

22     were part of that leadership.

23             I understand I need to speak more slowly for the court reporter

24     and the interpreters.

25             That means that Zavisic reported to the people that I just

Page 13164

 1     enumerated.

 2        Q.   Now, paragraph 9, you testify to being the commander of the

 3     police station up until May of 1991; is that right?

 4        A.   Yes.  Before I joined the PJP, I worked in the intermunicipal

 5     secretariat OUP Srbobran and OUP Becej, and I was stationed in the police

 6     station in Becej.

 7        Q.   And in relation to the beginning of 1991, before joining the PJM,

 8     did you notice any change in the type of work you were doing as a result

 9     of the breakout of conflict or violence in Croatia?

10        A.   As far as my area in Becej is concerned, it was relatively quiet

11     and peaceful, because Becej has a population of 60 per cent Hungarians

12     and 40 per cent others.  I was born in Croatia, and most of my family

13     from both the paternal and maternal sides were in Croatia.

14             JUDGE ORIE:  Mr. Jordash one of your previous questions was to

15     whom did Zavisic report; what was the hierarchy above him.

16             In the answer, mention is made of PJP, and you later repeated

17     that question, but PJP here doesn't appear in one of these paragraphs,

18     and I would like to know exactly what the acronym stands for.

19             MR. JORDASH:  Certainly.

20             JUDGE ORIE:  If -- unless it's a mistake, but...

21             MR. JORDASH:

22        Q.   Could you clarify, Mr. Witness:  First of all, is there a

23     difference between PJM and PJP?

24        A.   There is no difference.  For a while, we were PJM, standing for

25     Posebna Jedinica Milicija, milicija being the old name for police.

Page 13165

 1     That's why the acronym changed from PJM to PJP.  So perhaps it was just a

 2     slip of the tongue when looking at these documents.

 3        Q.   And do you recall when the acronym changed?  Approximately which

 4     year?

 5        A.   I really couldn't tell you the year.  But I believe that was the

 6     milestone year, between 1991 and 1993, when all the changes occurred.

 7     1992, I think.  I think 1992 is when the acronym changed.

 8        Q.   Let's move to paragraph 12.  And you testify to being tasked to

 9     protect the area from Backa Palanka to Apatin.  How many people were

10     tasked with you to protect that area and what kind of distance did you

11     cover?

12        A.   Sometime around 12 May 1991, I and members of a part of the units

13     from Srbobran and Becej were invited to report to OUP Odzaci that

14     belonged to SUP Sombor where we were met by four officers of my rank and

15     four other officers, Momo, Kresoje, Mr. Stojanovic, and Mr. Zavisic,

16     where we were given our assignments and were told what our objective was,

17     because the Croatian paramilitary units and MUP units had already crossed

18     over into the territory of Serbia and they were carrying out illegal

19     arrests, taking away and mistreating Serbian citizens.  After receiving

20     our assignments, we were assigned between Backa Palanka and Apatin, in

21     three units.  I was in Vajska; Nikolic was in Apatin; and another

22     colleague from Pancevo was stationed in another location, so we covered

23     that border with about 70 to 90 members of the PJM.

24        Q.   And what was your basic objectives and your basic tasks?

25        A.   Considering that a large number of refugees had already arrived

Page 13166

 1     from Croatia into Serbia, moving mostly in boats that could hold four to

 2     five people, and there were already unrests and anxiety among citizenry

 3     along this invisible border between Serbia and Croatia, and there were

 4     many volunteers who were in that area helping out those people and some

 5     clashes had already occurred between paramilitary units on both sides,

 6     our objective was to calm down the situation, to receive all the fleeing

 7     people, and to remove people who were in possession of weapons illegally

 8     and legally, and to calm down the people, because the local police force

 9     had already lost control over the situation.

10        Q.   And was there a particular ethnicity who -- who were fleeing?

11        A.   From the time I came, people of various ethnicities were crossing

12     over, Croatians and Hungarians and Ruthenians, because that crossing from

13     Backa Palanka and Apatin is an area where the population is mixed.  There

14     were Serbians and Croatians and Hungarians.  Practically all ethnicities

15     were represented.  And even the composition of my unit was very mixed.

16     There were Hungarians, Serbs, Croatians, Ruthenians.  We never

17     discriminated.  We helped out all the people who were coming our way.

18        Q.   What kind of assistance did you provide to those who were

19     fleeing?

20        A.   The first thing we did was regarding the boats, because the boats

21     were handled by skippers who were not trained.  We asked them not to take

22     in too many people per boat, and we admitted all these incoming people

23     and turned them over to the Red Cross.

24        Q.   In paragraph 14, you testify to a situation at the Danube, and

25     you note that your PJM platoon controlled the direction Backa Palanka,

Page 13167

 1     Sombor, and the check-point Vajska.  How big was the check-point at

 2     Vajska, what kind of check-point was it, how far from the Danube, and how

 3     many people were manning it?

 4        A.   From Backa Palanka to Apatin, the population could not cross the

 5     river across the bridges because they were controlled by the Croatian

 6     paramilitary formations.  People from Vukovar and the surrounding

 7     villages as well as from Backa Palanka, Becej, and all the other villages

 8     up to Apatin who had land across the river and family there tended to

 9     cross the river in boats.  There were a few crossings there --

10             JUDGE ORIE:  Mr. Jordash, I think your question was:  "How big

11     was the check-point at Vajska, how far was it from the Danube, and how

12     many people were manning it."  That is, about the check-point.

13             Your answer is focussing on why people want to cross or whether

14     they could cross or not.

15             Could you please focus your answer on the question.

16             First question:  How big was the check-point?

17             THE WITNESS: [Interpretation] The check-point was about 10 square

18     metres big.  There were three check-points in that position and a group

19     of 25 to 30 members of the PJP was assigned to control those three

20     crossings and the stretch from Backa Palanka to Odzaci.

21             JUDGE ORIE:  And how far was it from the Danube?  Or was it at

22     the Danube river.

23             THE WITNESS: [Interpretation] Each of those crossings was on the

24     Danube river itself.  The first one, the so-called Rakic Ovsalas [phoen],

25     was across the river from Vukovar.  The second one was across the river

Page 13168

 1     from Borovo Naselje.  And the third one was across the river from

 2     Borovo Selo.

 3             MR. JORDASH:

 4        Q.   Was there any reason why check-points were put at those locations

 5     rather than at other places along the Danube?

 6        A.   Those had been legal crosses -- crossings even before.  This is

 7     where the bank was conducive to crossing.  But when we arrived, the

 8     population wanted to cross elsewhere and that's why they set up illegal

 9     crossings.  With the few people that we had, we tried to control those

10     illegal crosses by way of setting up patrols and to direct the population

11     to the three legal crossings.

12        Q.   Now, a moment or two ago you noted that "From Backa Palanka to

13     Apatin, the population could not cross the river across the bridges

14     because they were controlled by the Croatian paramilitary formations."

15             First of all, who were the Croatian paramilitary formations?

16     What kind of organisations were they?  What were they constituted of --

17     or who were they constituted of?

18        A.   At that time, I knew very little about them.  However, when I

19     arrived at the crossing, I learned a lot.  They were criminals who had

20     been armed by the legal institutions of the Republic of Croatia.  They

21     wanted Croatia to secede from the former Yugoslavia, or the

22     then-Yugoslavia, as it were.

23             I couldn't understand that because I worked in a state

24     institution and I had been brought up to believe that arms can be carried

25     only by the -- by those who had a licence to carry arms, and that means

Page 13169

 1     the police and the military and a few individuals who had a special

 2     permit to carry arms, given to them by the Ministry of Interior.

 3        Q.   And what were these criminals doing to prevent people from

 4     crossing the bridges?

 5        A.   Every citizen who was not of Croatian ethnicity was ill-treated.

 6     His personal effects were seized, money, jewellery.  And if they were

 7     travelling in a good passenger vehicle, that was confiscated as well.

 8     That is why people resorted to other means of crossings.  Meaning barges

 9     and boats.  This was a riskier way to cross but at least they managed to

10     keep their personal effects.

11             I can say that at the time in the territory of the Republic of

12     Croatia people used false IDs, or, rather, IDs were undergoing changes,

13     and that people of Serbian ethnicity had different last -- digits on

14     their IDs to make sure that everybody knew that they were Serbs, that

15     they were of Serb ethnicity.

16        Q.   How long -- are you able to put a time on this?  How long were

17     the Croatian paramilitaries in control of the bridges in 1991?

18        A.   The bridge in Backa Palanka was closed and mined, so it couldn't

19     be used at all.  And the bridge near Dalj could not be used before Dalj

20     was liberated.

21        Q.   And are you -- do you know when that was, when Dalj was

22     liberated?

23        A.   In 1991, on the 2nd of August.  But, really, I'm trying to

24     provide you with as much information as possible.  I'm trying to retrieve

25     all that information from my long-term memory.  So I may be mistaken on

Page 13170

 1     some names and dates.  Please do not hold it against me.

 2        Q.   It's okay.  If you don't remember, you don't remember.  It's a

 3     long time ago.

 4             Paragraph 13 of your statement, you make mention of an incident

 5     when members of the ZNG entered the territory of Vojvodina, and you

 6     testified to the control of the check-points being intensified.

 7             In which way were the check-points intensified at this point in

 8     time, following this incident?

 9        A.   After that incident, we arrived in the area that I described in

10     my statement.  One of the reasons or pretexts, as it were, was the fact

11     that a group of ZNGs crossed over to the territory of Serbia.  They

12     captured a number of fishermen and women, they ill-treated them, and then

13     released them.  After a report was filed by those individuals, we were

14     sent to that sector.

15        Q.   Were there any incidents in Apatin when you were tasked to

16     protect that area in 1991, or thereabouts?

17        A.   At that time, ZNGs crossed one more time.  They were masked in

18     military uniforms, and they crossed over to the territory of Serbia in

19     military vehicles.  They wreaked havoc there.  The police had to

20     intervene, and a number of people were arrested and their further

21     intentions were thus thwarted.

22        Q.   Do you recall roughly or approximately when that was?

23        A.   That was probably in 1991.  In late 1991 or early 1992.  Again,

24     I'm not sure about the year.  I know that there were two incidents, and

25     I've just described the second one.

Page 13171

 1        Q.   And do you know which police had to intervene and make the

 2     arrests?

 3        A.   Our forces tried to arrest them, but they were not trained for

 4     such tasks.  Therefore, the military had to intervene and carry out the

 5     task.

 6             I know that Radovan Stojcic, also known as Badza, was involved in

 7     that mission.  But he couldn't do anything because they were in armoured

 8     vehicles and we didn't have any tools or weapons to carry out such a

 9     demanding task.

10             MR. JORDASH:  Could we go to paragraph 17, please.

11        Q.   There, you testify to the conflict starting and the situation

12     changing "with the PJM being sent to the border to protect the entering

13     of people with weapons."

14             Could you explain what this change meant?

15        A.   When I arrived on the 15th of May and when I joined men at the

16     check-point, I found a group of civilians there.  They were armed with

17     hunting rifles and carbines.  And since I'm a man who understand people

18     and I don't lose my temper easily, I tried to reason with them.  I told

19     them that there was no need for them to be there.  I told them that I

20     represented the state and that nobody else should be there but me,

21     especially if they were carrying arms.  Jovo Ostojic was also there with

22     two or three men of his.  He reacted vehemently because he --

23        Q.   Sorry to interrupt.  I was just asking -- I'm going to come to

24     the man you've just mentioned shortly.  But could I just ask you, first

25     of all:  What were your tasks and how did they change, as indicated in

Page 13172

 1     paragraph 17.  You note there that:  "Once the conflict started, the

 2     situation changed, with the PJM being sent to the border to protect the

 3     entering of people with weapons."

 4             Was that a change from when the usual tasks of the PJM that

 5     you've been talking about up till now?

 6        A.   Yes.  Changes did happen.  An armed conflict had already broken

 7     out in Borovo.  Arms were being used and there were casualties.  PJMs had

 8     had to remove anybody who was moving about illegally, and especially

 9     those who were carrying hunting rifles, for which they had appropriate

10     licences from the regional organs.  We did that to provide for the

11     security of members of the police and the citizens who were crossing the

12     river there.

13             MR. JORDASH:  Your Honour, I notice the time, and I wondered if

14     that's convenient.

15             JUDGE ORIE:  Yes, Mr. Jordash, I think it's a convenient moment.

16             If you would allow me, because it might be difficult to get back

17     to that after the break.

18             You said that you couldn't arrest those who had entered Serbia

19     and that the intervention of the army was needed.  Where were they

20     finally arrested?

21             THE WITNESS: [Interpretation] All those individuals who were in

22     the area from the moment we arrived were arrested.  Either they crossed

23     from Croatia or from Serbia.  If they had arms, they were arrested.

24             JUDGE ORIE:  Well, that doesn't answer my question, really.

25             Let me just --

Page 13173

 1             MR. JORDASH:  Sorry, I think Your Honour may be at odds with the

 2     witness.  I think the witness doesn't appreciate you're talking about

 3     Apatin, I think.

 4             JUDGE ORIE:  Yes.  Let's try to go back to the transcript.  One

 5     second, please.

 6             Yes, you told us - and I'll take you back to the relevant part of

 7     your evidence - you said that there were two incidents.  You had

 8     described the second of these incidents.  You were then asked:  "And do

 9     you know which police had to intervene and make the arrests?"

10             You said:  "Our forces tried to arrest them, but they were not

11     trained for such tasks.  Therefore, the military had to intervene and

12     carry out the task."

13             Which I understand to be the task of arresting those persons.

14             You said Badza was involved in that mission.  He couldn't do

15     anything because they had armoured vehicles.

16             Now, finally:  Were they arrested?

17             THE WITNESS: [Interpretation] After a day and a half, they were

18     arrested by the JNA.  So it was on the second day of their stay in the

19     territory of Serbia.

20             JUDGE ORIE:  Where was that?  Was that on the Vojvodina territory

21     or was it in Croatia?

22             THE WITNESS: [Interpretation] Apatin is in Vojvodina, which means

23     that it was in the territory of Serbia.  Or, in Vojvodina.

24             JUDGE ORIE:  Yes.  That's where they were arrested.

25             THE WITNESS: [Interpretation] Yes.

Page 13174

 1             JUDGE ORIE:  Do you know what then happened to them?  Were they

 2     brought to court or ...

 3             THE WITNESS: [Interpretation] A group of them were tried.  But as

 4     far as I know, eventually they were exchanged for the members of the

 5     other side.

 6             JUDGE ORIE:  Yes.  Thank you.

 7             Let's take a break first.

 8             We'll resume at 4.00.

 9                           --- Recess taken at 3.34 p.m.

10                           --- On resuming at 4.10 p.m.

11             JUDGE ORIE:  Two brief matters before we continue.

12             An e-mail was sent by the Prosecution in relation to the

13     protective measures.

14             Mr. Groome, first of all, I would like to put that on the record,

15     that you do oppose finally to grant the protective measures.  There's a

16     bit of a dilemma for us.  We have not finally decided.  The request was

17     there.  You have responded to that request.  We have not yet asked, for

18     this specific witness, further details from the Government of Serbia and

19     I might have overlooked that.

20             If you go not far enough, then you're in trouble, if you want to

21     grant the request as a whole.  If you go too far, not in every respect,

22     the redaction of the protection can be achieved.  So therefore this is a

23     bit of a dilemma there.  The Chamber is aware of it.

24             We have proceeded in the past in a similar way.  I do understand

25     the objections raised by the Prosecution.  This is on the record, unless

Page 13175

 1     you would like to add anything.

 2             MR. GROOME:  No, Your Honour.  I appreciate the difficult

 3     circumstances of such a situation and appreciate that the Chamber

 4     considered it.  Thank you.

 5             JUDGE ORIE:  Yes.  Thank you, Mr. Groome.

 6             Then, finally, I may not have pronounced well, when I asked

 7     Madam Registrar to anticipate for assigning numbers, or for reserving

 8     numbers, whether I said "for," f-o-r, or f-o-u-r, as it appears in the

 9     transcript.  I blame my own pronunciation for that.  However,

10     Madam Registrar has followed the transcript, where far more numbers

11     needed to be reserved, which results in the following.

12             Madam Registrar, have you a suggestion how to resolve it; could

13     you please tell us.

14             THE REGISTRAR:  We will re-assign a number that was assigned to a

15     document ID 5001 marked by the witness in court, which received number

16     D341.  We receive instead number D337 and numbers -- so number D341 will

17     be vacated.

18             And instead I will later on file a chart with the pre-assigned

19     exhibit numbers for 26 documents without an exhibit number assigned in

20     the chart.

21             JUDGE ORIE:  Yes.  And I'll seek some additional training in

22     properly pronouncing the difference between "for" and "four."

23             D341 is vacated and will be most likely in the range of

24     pre-assigned numbers for 26 documents.

25             And then in order to avoid further confusion, Madam Registrar,

Page 13176

 1     instead you -- of D341, you would assign what number to what is, until

 2     now, D341?

 3             THE REGISTRAR:  Number would be D337, for the map marked in court

 4     by the witness.

 5             JUDGE ORIE:  I'm a bit surprised, because we ended up at D341

 6     after we had used the previous numbers, isn't it?  Including D337, if I'm

 7     not mistaken.

 8             THE REGISTRAR:  The last number that was assigned to the chart

 9     was D336, and then I reserved four numbers, and then ...

10             JUDGE ORIE:  Yes, I see your point.  So from the four reserved

11     numbers, now we used the first one, which is D337, for the map marked by

12     the witness.

13             So D337 now is a map marked by the witness; and the following

14     26 numbers then are reserved, and we'll find that on your chart to be

15     produced soon.

16             That is clear.

17             Mr. Jordash, are you ready to continue?

18             MR. JORDASH:  Your Honour, yes, thank you.

19        Q.   Mr. Witness, could we have a look at paragraph 25 of your

20     statement, please.

21             At paragraph 25 you discuss your first day of work and a man

22     called Jovo Ostojic and an incident where he tried to go through the

23     crossing with arms.

24             Who was Jovo Ostojic?

25        A.   Jovo Ostojic was a resident of Serbia.  He resided in Prigravica.

Page 13177

 1     He was a man who belonged to either the Serbian Chetnik movement or to

 2     some other political option.  A man who used to wear a leather jacket.

 3     He sported a beard.  He had long hair, bulging eyes.  He looked

 4     terrifying to me when he came out of the woods.  But I'm not easily

 5     intimidated.  I stood in front of him.  I had a conversation to him, and

 6     I made him aware who the boss was in the area.  He was quite displeased,

 7     and he --

 8        Q.   He told you that he was involved in the organisation of

 9     acceptance of refugees.  Did you accept that; and, if not, what did you

10     learn, if anything, about what he in fact wanted to do?

11        A.   I'm sure that he did work on the reception of civilians quite a

12     lot.  The civilians had started arriving from the 1st of May.  I myself

13     arrived on the 13th of May.  However, when I arrived, I didn't want

14     anybody else to be involved in that but me.  I was the only

15     representative of the state, and I was the only one in a position to be

16     involved in that.  He protested but he left.  I did not disarm him

17     because that was my first encounter with him.  If he had been impertinent

18     after that or if he had disobeyed, I'm sure that I would have disarmed

19     him.

20        Q.   He "returned on several occasions to cross the border but then he

21     came more polite and came unarmed."

22             Do you know why he was crossing the border?

23        A.   After that, on several occasions he did arrive.  But having

24     realized who was the boss, he was polite, well-mannered, and I allowed

25     him to cross because he had relatives in the area.

Page 13178

 1        Q.   Looking at paragraph 29, you speak about Seselj crossing the

 2     point as an unarmed citizen.  Did Seselj ever cross as an armed citizen?

 3        A.   I've already said that I'm telling the truth, and I said it in my

 4     statement that he did cross on several occasions.  He attended

 5     Soskocanin's burial.  He was always unarmed.  And he was escorted by two

 6     or three men who also didn't carry any arms.

 7             MR. JORDASH:  Could we have on the screen, please, P1344.

 8        Q.   This is a speech that -- or, sorry, an interview, an excerpt from

 9     an interview that Seselj gave, I think, in 1991 or 1992.

10             MR. JORDASH:  Could we turn to page 4 of the English and page 2

11     of the B/C/S.

12        Q.   And just to confirm, you've seen this interview before,

13     Mr. Witness?

14        A.   I have.

15        Q.   Now, the section I'm interested in begins with Seselj saying

16     this:

17             "There are no troops from Serbia or from Montenegro.  That is a

18     fact.  However, there are volunteers who have come to fight for the

19     liberty of the Serbian people, and no one can prevent them from coming.

20     We had a lot of problems, you know.  Everything was much easier during

21     the war for Srpska Krajina.  Then, at first, we had to smuggle volunteers

22     across the Danube to Slavonia.  We feared the Serbian police and the

23     Yugoslav Army more than we feared the Ustashas as we smuggled them across

24     the Danube.  And then, when the war broke out with full intensity, then

25     we cooperated fully with the army."

Page 13179

 1             Do you accept or do you agree with what Mr. Seselj said then

 2     about his fear of the Serbian police and his having to smuggling Serbian

 3     volunteers across the Danube?

 4        A.   I had orders that nobody is to be allowed to cross over to the

 5     other side carrying weapons, and I obeyed that order in full.  Which

 6     means that he was not able to cross.  And if he did, it could have been

 7     only in areas where I had no control.

 8        Q.   Were you aware if any of your colleagues on the other

 9     check-points had the same objectives as yourself and whether, in fact,

10     they sought to achieve those objectives?

11        A.   All four senior officers received the same orders, the same

12     assignments, and I can say that there's no reason for me to believe that

13     these orders were not followed, knowing well the colleagues who were

14     working with me.

15        Q.   Seselj then goes on to say, in relation to cooperating fully with

16     the army at a later stage:

17             "And in agreement with the army, we sent volunteers.  We even had

18     some barracks, depots, uniforms, and so forth at our disposal."

19             Do you know anything about that?

20        A.   I know after I returned to Becej from that area the Yugoslav

21     People's Army providing barracks in Belgrade where volunteers gathered

22     and were sent from there, unarmed and organised.

23        Q.   Did you encounter these men at the check-points?

24        A.   No.  In my time, even if they had come, they would not have been

25     able to cross.  Because approval was required for crossing.

Page 13180

 1        Q.   Are you able to identify when that changed, when it was that

 2     Seselj's Men were travelling, as you've said, organised and unarmed?

 3        A.   1992/1993.

 4             MR. JORDASH:  Could I have on the screen, please, 1D01950.  I beg

 5     your pardon.  It's D291, MFI.

 6        Q.   Now, what you're going to see, Mr. Witness, is a State Security

 7     Service for Belgrade report, dated 15th of July, 1991.  Please have a

 8     read through.

 9        A.   "The State Security Administration for Belgrade, 3rd Department,

10     Official Note --"

11        Q.   [Previous translation continues] ... I didn't mean for you to

12     read it aloud.  Just read the document to yourself, just to familiarize

13     yourself with the contents.  Then I'll ask you some questions.

14        A.   Sorry.

15             I have read this Official Note several times before, so you can

16     ask the question.

17        Q.   Thank you.  On page 1, I want to ask you about the reference to

18     Pekic.  Page one of the English and page 1 of the B/C/S.  And the

19     Official Note, as we can see, discusses the gathering of volunteers by

20     the Serbian Radical Party and the Serbian Chetnik movement.  And towards

21     the bottom of the page, it's noted that retired General Dusan Pekic and

22     Dragoljub Bulat were involved in the way described.

23             Do you know anything about that?

24        A.   As I arrived at the crossing to Vajska, I heard the names of

25     Jovic and Pekic and all these people.  I know that Mirko Jovic had a few

Page 13181

 1     members in Borovo Selo before he arrived.  I got this information from

 2     the locals and I passed it on to my superiors.  And even during my time

 3     at the crossing the retired general was mentioned as having crossed over,

 4     not at my crossing, but it was said that he had been in Borovo Selo,

 5     Dalj, and other places.

 6        Q.   And was it said what he was doing?

 7        A.   No, no.  Even if he had been active, it must have been in concert

 8     with the Yugoslav People's Army because all the retired staff, all the

 9     retired personnel, were still in contact with the army.  I don't know

10     that man personally.

11             MR. JORDASH:  Page 2, please, of the English and the B/C/S.

12        Q.   The report, or the Official Note, states:

13             "According to our intelligence, besides ... Petkovic and Rankic

14     from the SRS, Bulat and Ciganovic [phoen] also participate in the direct

15     transfer of the volunteers to the Slavonia and the SAO of Krajina.  Thus,

16     on the 8th of July, 1991, they organised a ferry crossing on the Danube

17     for a group of volunteers being sent to Borovo Selo."

18             Did you ever learn about these men and their involvement in the

19     direct transfer of volunteers?

20        A.   I know that Jovo was trying, because we met a couple of times, to

21     persuade me to let a certain group through, but I didn't.

22        Q.   When you say "Jovo," are you referring to the Jovan Ostojic we

23     see in the paragraph there?

24        A.   Yes, I mean him.  The one who was mentioned in the paragraph.

25             He didn't come with that group.  The information that I had was

Page 13182

 1     that he had a certain number of volunteers who wanted to cross over.  I

 2     told him that was not on, and I did not make it possible for that group

 3     to cross, because for every group that was to be let through, there had

 4     to be a written approval signed by superior authorities.  Only two such

 5     approvals were received during my tenure in that area.

 6        Q.   Now, going to page 3 of the B/C/S but page 2 of the English, I

 7     just want to ask you about a training ground referred to here.

 8             The paragraph I'm interested in starts with:

 9             "The entire action of sending volunteers was reorganised after

10     this.  It was decided that this would be led by Petkovic from his

11     apartment and not from the SRS premises, together with Bulat.  It was

12     also decided that until a suitable training ground was found near

13     Belgrade the volunteers would be sent to the training ground in

14     Prigravica, where they would be given equipment and weapons and undergo

15     brief training.  According to Ostojic, the training ground in Prigravica

16     was fully equipped to take in 200 or 300 volunteers for training and send

17     them to Slavonian villages.  A troop review of the volunteers of the

18     Serbian army was scheduled for 1900 hours on the 13th of July, 1991, in

19     this training ground, but it was postponed and only a rally was held."

20             Do you know anything about this training ground and the facts or

21     references made here in this Official Note?

22        A.   Since I disallowed these volunteers to cross, they were with

23     Jovo Ostojic in Prigravica where they spent a couple of days trying to

24     find training grounds.  But in the meantime, Jovo Ostojic, untrained as

25     he was, inflicted an injury upon himself while handling a weapon, and

Page 13183

 1     that's how it all ended.  It never came to anything.

 2             Also, a criminal complaint was filed against Jovo Ostojic for all

 3     these things.

 4        Q.   And Prigravica, did it become a training ground at any point?

 5        A.   As far as I know, no.

 6        Q.   Let's move to paragraph 32 of your statement.

 7             MR. JORDASH:  Could we have, please -- one second.  1D5000,

 8     please.  D334.

 9        Q.   You're referring here in paragraph 32, Mr. Witness, to viewing a

10     permit signed by Bogdanovic.  And you testify that:

11             "Only people with a permit from the highest level would be

12     allowed to cross the border with a weapon.  This was a permit signed by

13     Bogdanovic or the secretariat of the Vojvodina MUP, Markov."

14             Who gave you that order?

15        A.   I got that order from Zavisic and the superior officers who had

16     sent me from my police station in Odzaci.

17        Q.   Do you know if that order was an order which was in place at your

18     check-point or all the check-points?

19        A.   When we were receiving our assignments, all the officers were

20     present.  That means that order applied to all of us.

21        Q.   Do you know how long that order was in place?

22        A.   For the duration of my engagement on that assignment, the order

23     was not changed.

24             JUDGE ORIE:  Mr. Jordash, could I seek some clarification of one

25     of the previous answers.

Page 13184

 1             Witness, you were asked whether Prigravica did become a training

 2     ground at any point.  And then you said:  "As far as I know, no."

 3             Do you have any specific knowledge which would allow you to more

 4     positively say that it did not become a training ground; or is it that

 5     you just never heard about it to ever have become a training ground?

 6             So is there any specific knowledge which allows you either to

 7     more positively say it never was a training ground; or is it that you

 8     just do not have any information?  Because the report that was just put

 9     to you is, to some extent, detailed.  It says it was fully equipped; it

10     would take 200 or 300 men; people were sent from there to Slavonia; there

11     was something scheduled for the 13th of July, which finally did not take

12     place.

13             So there are quite a lot of details.  My question to you

14     is - where you say not to your knowledge it ever became a training

15     ground - what is the basis specifically for that answer?

16             THE WITNESS: [Interpretation] Because I knew Jovo Ostojic and the

17     people around him.  I know he was a man from Prigravica, and he was the

18     one who would have organised all that.  But after he wounded himself, his

19     close associates came by the crossing, by the check-point, several times,

20     and I heard from them that the idea never came through.  And I know from

21     a colleague who worked at another check-point that SUP Sombor did its

22     job.  All the weapons and everything found in the house of Jovo Ostojic

23     and his friends was confiscated, and a criminal complaint was filed

24     against all of them.

25             JUDGE ORIE:  So I do understand that there was a concentration,

Page 13185

 1     then, of weapons in or around his -- in -- in his house and that those

 2     weapons were confiscated.

 3             THE WITNESS: [Interpretation] Correct.

 4             JUDGE ORIE:  Yes.

 5             I'm addressing the parties.  Is there anything known about the

 6     criminal complaint filed against Mr. Ostojic in this respect which would

 7     shed additional light on what exactly was found?  Was it just weapons in

 8     a house; or was it, as the report seems to suggest, that there was a

 9     training grounds?

10             MR. JORDASH:  Off the top of my head, no.  But we can do some

11     research into the exhibit, perhaps.

12             JUDGE ORIE:  Mr. Groome.

13             MR. GROOME:  I'm not aware of any such evidence, Your Honour, but

14     I will ask that it be investigated.

15             JUDGE ORIE:  Please report to the Chamber at the earliest

16     possibility.

17             Please proceed.

18             MR. JORDASH:

19        Q.   Let me ask you, Mr. Witness, to have a look at P18.

20             MR. JORDASH:  Could we have that on the screen.

21        Q.   This is another speech or interview with Seselj somewhat later; I

22     think 1993 or 1994.

23             MR. JORDASH:  And if we could have page 14 of the B/C/S and 14 of

24     the English.

25        Q.   And just to confirm:  You've seen this before; is that correct?

Page 13186

 1        A.   Yes.  I've read it a couple of times.

 2        Q.   I just want to see if you can shed any light on some of the

 3     remarks made by Seselj.

 4             He's asked the question:

 5             "Can we briefly, since you were not in Borovo Selo, and in

 6     principle, we are working for somebody who was in touch, can you explain

 7     once more regarding Bogdanovic?  He was not, he was -- he was not

 8     officially ... actually, he was sacked and reinstated again."

 9             And then going over the page in the B/C/S:

10             "No, he wasn't sacked.  He was replaced from the position of

11     minister.  That is, he was made to submit his resignation.  However, his

12     resignation only had a formal significance.  In essence, he remained the

13     main police chief in Serbia, and he is still the key police figure,

14     because Sokolovic mainly doesn't interfere in every affair, and the

15     domestic public knows it."

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

17             MR. JORDASH:  Sorry.  Sorry.

18             "I had my first contact with Bogdanovic in July 1991.  Until

19     then, the contacts went through Vukasin Soskocanin.  He was later found

20     dead under very suspicious circumstances.  They say that he had drowned

21     in the Danube.  We were suspicious about it, and there are indications

22     that he was executed due to certain matters that were never cleared."

23        Q.   So, first question:  Do you know anything about the drowning of

24     Soskocanin?

25        A.   I'd heard stories about Vukasin Soskocanin when I came to the

Page 13187

 1     check-point.  And a couple of days into my stint, Petar Licanin handed

 2     him over to me personally.  Petar Licanin is the man who found him in the

 3     Danube.  After that, Soskocanin was brought to the territory of

 4     Vojvodina, where a team of prosecutors and forensic experts did their job

 5     on the body and then they -- it was turned over to the family for burial.

 6             I cannot say anything about Soskocanin because I never met him.

 7     I only saw him when he was dead, that one time.  But I can say that the

 8     residents of Borovo Selo and others had a lot of praise for the man.

 9        Q.   Now, reading on, Seselj says that:

10             "My first meeting with Bogdanovic took place in July 1991 when I

11     was elected deputy in the national assembly and we met at the Serbian

12     Assembly.  We really didn't have any contact before that."

13             Going over the page, to page 15 of the English:

14             "However, we established a close relationship and met often."

15             Were you aware of any relationship between Bogdanovic and Seselj?

16     Is that something that you heard about?

17        A.   I worked in the Ministry of Interior.  I was on assignment.  I

18     was never a politician.  Politics never interested me, and I'm not

19     interested in those interrelations.  I know Radmilo Bogdanovic because he

20     was the secretary for internal affairs for a while.

21        Q.   Let me read on a bit, to page 16 of the B/C/S and page 15 of the

22     English.

23             Seselj says that:

24             "We regained [sic] this trust very quickly and then the regime

25     also put the army barracks in Bubanj Potok at our disposal.  An entire

Page 13188

 1     army barracks was provided only for the Serbian Radical Party's

 2     volunteers, and we were gathering our volunteers in Belgrade.  Here we

 3     received uniforms and weapons for them, buses to take them to

 4     battle-fields, and so forth.  This was very well organised."

 5             Do you go anything about that?  Is that something you can comment

 6     on?

 7        A.   Regarding the Bubanj Potok barracks in Belgrade, it was not

 8     placed at the disposal of the Serbian Radical Party.  What did happen was

 9     that all volunteers who reported, regardless of their political

10     affiliation, reported there, and the army took them into their ranks.

11             I don't know what Seselj is talking about.  I'm telling you the

12     information that I have.

13        Q.   Do you know if there was any training there?

14        A.   I don't know.

15        Q.   Thank you.

16             Let me ask, please, for you to look at P02990.

17             Now, in the chart that you've completed - Your Honour, page 8 -

18     you note:  "I recognise the signature.  This is the same signature that

19     was included on the permission, Arkan and Kostic."

20             Could you just clarify which signature you recognise?

21        A.   I recognise the signature on the left-hand side of the document,

22     Radmilo Bogdanovic.  This is a signature that I saw on the certificate at

23     the crossings.  I confiscated those two certificates, and I forwarded

24     them to Zavisic with my report.

25             Since I was rewarded by Radmilo Bogdanovic, I am quite familiar

Page 13189

 1     with this signature.

 2        Q.   Sorry, what did you just say?  Since you were, what, by

 3     Radmilo Bogdanovic?

 4        A.   I was decorated as a member of the Ministry of the Interior.

 5        Q.   When was that?  And what was the decoration for?

 6        A.   In 1990, I was decorated for my work and the results achieved in

 7     elucidating crimes and catching the perpetrators of those crimes.

 8        Q.   At the time when you met Arkan and he produced permission signed

 9     by Bogdanovic -- or perhaps just going back one step.  At the time when

10     Arkan insisted he had a relationship with Bogdanovic, had you been aware

11     of that relationship prior to that moment?

12        A.   My first contact with Arkan was on that day.  I stated that in my

13     statement.

14             I was an employee of a very small police station in a town that

15     numbered 20.000 and the municipality had 40.000 inhabitants.  I had never

16     come in touch with criminals of that calibre.  My first contact with him

17     was as follows:  He said, I am Arkan, and I replied, I am Bogunovic.  He

18     wanted to cross; I told him no.  To which he jumped, started screaming

19     and calling me names.  However, I explained to him what he could do and

20     then he said who he was sent by.  And then I said:  Okay, if you were

21     certainty by him, let him give you a permission and sign it and then I

22     will let you go.  I didn't allow him to cross that night.

23             He came back the following morning with a permission with an

24     appropriate heading, all the names of the people were listed, as well as

25     the number of vehicles, and then I allowed him to cross.  There were the

Page 13190

 1     names of some five or six or perhaps seven people, but it doesn't really

 2     matter.  What matters is the fact that he did cross but with an adequate

 3     permission.  And I know that he went to Tenja.

 4        Q.   [Previous translation continues] ... try to understand the

 5     situation a bit more.  This was July of 1991, as you've said in your

 6     statement.  Did Arkan have a reputation at that point in time?  Was he

 7     known to you by reputation or not?

 8        A.   I said that that was my first contact with him.  Before that, I

 9     had never heard of Zeljko Raznjatovic, also known as Arkan.  Once he

10     crossed, I had a chat with my colleagues, policemen, and other people.  I

11     heard stories about him, but I had never been aware of those stories

12     before that.

13        Q.   Thank you --

14        A.   I was not interested in him.  He was not a problem in my area.

15     He was a problem in Belgrade, and it was up to the police in Belgrade to

16     deal with him and to solve that problem.

17             I carried my orders.  I respected the law.  I did not allow him

18     to cross before he managed to obtain the necessary document.

19        Q.   Thank you.  Could we have your statement back on the screen,

20     please.  D334.  And paragraph forty -- paragraph 41.

21             And this is the subject of operatives of intelligence services

22     crossing the border.

23             Now, at your particular crossing, were there any permanent DB,

24     whether from Vojvodina DB or the Serbian DB, stationed at your crossing?

25             Let me rephrase that.  I think it's a bit confused.

Page 13191

 1             At your particular crossing, were there any DB from either

 2     Vojvodina DB or the Serbian DB stationed on a permanent basis?

 3        A.   At the crossing where I served, as well as in the others, no

 4     members of the DB of either Vojvodina or Serbia were stationed.  Members

 5     of the state security of Vojvodina did come to my crossing from time to

 6     time during the day.  They were briefed either by me or my colleagues as

 7     to what was going on.  Since we were all members of the Ministry of the

 8     Interior, we shared all the information with those people.  None of them

 9     ever crossed the river, which means that no members of the DB from Serbia

10     came to my check-point.  They did come from Vojvodina.  I gave you their

11     names.  I'm sure that there were others, but you have to understand that

12     I can't remember all of their names at this point.

13        Q.   How often would you see the operative Lemic?

14        A.   Not that often as Glusica and Sarac.  Lemic did not cross as many

15     times as Glusica and Sarac, and two other members whose names I don't

16     know.

17             I know that they were members of the state security in Novi Sad.

18     Until the moment I left the service, they were still affiliated with the

19     state security of Vojvodina.

20        Q.   Did you ever see or hear of Lemic doing anything other than

21     collecting information?

22        A.   There was nothing for him to do at the crossing but that.

23        Q.   And away from the crossing, do you know if he did anything other

24     than collect information?

25        A.   If he had done anything else, I suppose I would know.

Page 13192

 1             I had daily patrols.  I set up daily ambushes.  And we never

 2     noticed that man.  All the vehicles of the regional SUP were known to us.

 3     They were of a newer make and not a common sight in the area.  That's why

 4     we knew them well.

 5        Q.   Were you ever able to form an opinion about the way in which

 6     Lemic acted as a professional in gathering information?

 7        A.   Whatever information DB officials received they received either

 8     from me or my colleagues or the persons who were being interviewed at the

 9     crossing at the time when they appeared.  If they received any other

10     information, they could receive it from other people in the depth of the

11     territory.

12             I did not see them talking to anybody else at the crossing more

13     often than they did to us.

14        Q.   In relation to Lazar Sarac, did you ever hear that he was

15     involved in anything other than collecting information?  Or did you see

16     him involved in anything other than collecting information?

17        A.   Lazar Sarac was a young operative, just like I was at the time.

18     I don't think that he was capable of doing anything else but collecting

19     information.

20        Q.   And what about Branko Glusica?

21        A.   Branko Glusica was at the check-points every day, and he talked

22     to me.  He inspected the records that we kept at the check-points.

23     Whatever information we had we conveyed to him.

24             Moreover, I had an argument with the operative Glusica because we

25     had information about some arms being kept at the farm of Mile Jerenkic

Page 13193

 1     and we wanted to seize those weapons as soon as possible.  He actually

 2     conveyed that information to my superior, which is why I lost credibility

 3     with my informer, a person who helped me to make the area as secure as

 4     possible and as weapons-free as possible.

 5             That was my argument with Glusica about [as interpreted].

 6        Q.   Let's go to paragraph 46.  And you, there, discuss a man called

 7     (redacted).

 8             JUDGE ORIE:  Mr. Jordash, may I remind you that the whole story

 9     about Arkan at the border, your whole examination hardly revealed

10     anything what we could not yet read in the statement.

11             Now, more or less, operatives of intelligence services crossing

12     the border is approximately the same.  Of course, there's some additional

13     information.  If he says they received information, they sought

14     information, then you asked whether you -- he is aware of any other

15     activity, then the witness says no.  Of course, if it's not in his

16     statement about other activities, we take it on the basis of the

17     statement that that was what he knew about that person.  I hope that

18     we're not going on another area through the same repetitious exercise.

19             Please proceed.

20             MR. JORDASH:

21        Q.   Why did you consider (redacted) to be unimportant?  Why did you

22     conclude he was doing nothing?

23        A.   He crossed quite often.  His conduct and his manner of talking to

24     us and the others made me conclude that he wasn't interested in anything

25     but money.  He wanted to do as little as possible and to be paid as much

Page 13194

 1     as possible at the same time.

 2             He always asked me about my salary, about my bonus for being

 3     there, whether I had any daily allowance, and things like that.  That was

 4     the main thing on his mind: money.

 5        Q.   Let's go to paragraph 48.  And we're dealing now --

 6             JUDGE ORIE:  46 is approximately the same story as for the

 7     previous ones.  Of course, that little details, that he would like to be

 8     paid for doing nothing and that, that's because he asked about daily

 9     allowances, et cetera, but it doesn't add, really, to the information

10     unless there's any specific issue in relation to that which you would

11     like to draw our attention to.  But I have not heard any of that,

12     although I asked you to avoid a similar thing as with Arkan crossing the

13     border and the operatives crossing the border.

14             MR. JORDASH:  Well --

15             JUDGE ORIE:  Could you please try to -- to provide new, relevant,

16     focussed information if you further examine the witness on this

17     statement.

18             MR. JORDASH:  The problem is, Your Honour, that (redacted) is a

19     man who has been raised by the Prosecution.  We're not sure exactly why.

20     But he has been attributed to the DB.  And we're not sure what he's

21     supposed to have done or why he is to be attributed to the accused.  So

22     we try to raise the details we can to deal with any possible allegation

23     which we know is coming at some point.

24             JUDGE ORIE:  I'm not saying that you should not have introduced

25     the evidence which we find in paragraph 46.  My issue is that giving

Page 13195

 1     details as "What showed that he was interested in money," which, of

 2     course, is now directly contradicting what the Prosecutor says, and is

 3     just, I would say, illustrative for what we find in paragraph 46.

 4             I'm not complaining about what we find in 46.  What I'm

 5     complaining about is about asking questions and -- the same is true for

 6     the whole Arkan story.  More than one page of transcript where there's

 7     hardly anything which we do not find yet in 33, 34, 35, 36, and it's --

 8     don't misunderstand.  I'm not saying that you're not raising relevant --

 9     that you're raising irrelevant issues; I'm saying that it's repetitious

10     to what we find already in the statement.

11             And to the extent you give further details, it is so limited

12     compared to what we find in the statement, that I wonder whether there

13     are not more important questions to be put to the witness.

14             Please proceed.

15             MR. JORDASH:

16        Q.   At paragraph 48, Mr. Witness, you describe there being instructed

17     by Badza to go to Eastern Slavonia.  And you used the term that you were

18     asked if you were willing to go as a volunteer.  Why do you describe

19     yourself as a volunteer in this circumstance?

20        A.   Goran Hadzic and Ilija Kojic insisted, as well as a number of

21     citizens from Borovo Selo and surrounding villages, that I should cross

22     over and help them after having seen the kind of discipline that had been

23     instituted at the check-point and what we did.  And then Badza and my

24     superior Zavisic asked me if I was prepared to cross over as a volunteer,

25     and then I said, I don't see why not.  If necessary, I'll go.

Page 13196

 1             I was born in Croatia.  Lots of my relatives were there in the

 2     area.  I spoke to my parents on a daily basis.  They complained how

 3     difficult it was for their relatives.  That's why I agreed to cross over

 4     as a volunteer.  Not as a member of the Ministry of Interior but, as all

 5     the other volunteers who had crossed over, with a piece of paper.

 6        Q.   In paragraph 49 you describe that everybody continued to be paid

 7     by the MUP Serbia as if they were still working in their function in

 8     Serbia.  For example, "I was paid by the OUP Becej, as the commander of

 9     the police."

10             Was there a stated arrangement?  Was there a meeting where this

11     arrangement was discussed with members of the public security?  That is,

12     that you would go as a volunteer but continue to receive your salary.

13        A.   No meeting took place at the ministry level.  Badza and Zavisic

14     were the only ones behind that, and they spoke to me.  All the volunteers

15     who crossed over were paid by their original companies, which means that

16     I was paid by the ministry, which -- with which I was affiliated.

17        Q.   At paragraph 60, you say:  "We went to Eastern Slavonia together

18     with Goran Hadzic, who decided that we would be based in Erdut."

19             How do you know that it was Hadzic who made that decision?

20        A.   Hadzic was there waiting for us on the bridge.  He escorted us to

21     Erdut, to what then became the centre.  Before that, it was an area where

22     recruits had been trained.  Us five officers and 16 members of the PJP

23     were billeted there.  And he told us what we would be doing, where and

24     how.  After that, we received all of our instructions from

25     Radovan Stojcic, also known as Badza.

Page 13197

 1        Q.   You note in paragraph 50 that Badza addressed you and told you

 2     that you would be training members of the TO.

 3             What was the purpose of the training, as you understood it?

 4        A.   Since I had already worked at the crossing, I was aware of the

 5     situation and I knew that a lot of wounds were self-inflicted, that

 6     people lost their lives as a result of inability to handle arms.

 7             We knew that the first thing we had to do was to train members of

 8     the TO.  In other words, the locals in the area.

 9        Q.   Now, I want to talk to you about training at this point.

10             When you arrived in Eastern Slavonia in August/September 1991,

11     had any of the locals been trained?

12        A.   As far as I know, there had been some attempts, several attempts,

13     to train the local population, members of the TO of those settlements.

14     But all those attempts failed, as far as I know.

15             The first time something like that was organised, it involved a

16     person who had been training in Golubic as a member of the famous

17     Knindze.  He tried to train them but he couldn't accomplish much.

18        Q.   What was his name, please?

19        A.   If I'm not mistaken, his family name was Radenkovic.  I don't

20     know what his first name was.  I really don't know now.  But if it's

21     important, when I come back to Serbia I'll try to find his name and I

22     will send it to you.

23        Q.   Okay.  When you say he tried to train, who had he tried to train

24     and why hadn't he accomplished much?

25        A.   He tried to train the locals of all the villages.  But he did not

Page 13198

 1     have the necessary authority to impose himself upon the members of the TO

 2     there.  He simply did not display the necessary knowledge to train them.

 3        Q.   Which areas had he tried to train members of the TO in?

 4        A.   In Borovo Selo and the surrounding villages.  All those villages

 5     are marked on the map that we saw at the beginning.  Borovo Selo, Tenja,

 6     Erdut, Bobota.  I'm sure that I will omit one or two.  But we're talking

 7     about the villages in that area.

 8        Q.   So were you aware of any other attempts to train before you began

 9     your training?

10        A.   There were attempts on the part of various people, locals or

11     reserve officers.  The training never took off the ground.  If anything

12     had happened, the results were disappointing.  It was very difficult for

13     anybody to -- to impose themselves upon those people who were in such a

14     situation, especially if those people didn't trust them.  Then nothing

15     could be done.  People were simply afraid for their lives, their

16     property, their children's lives.

17        Q.   And you've -- you tell us at paragraph 53 that you trained locals

18     from various settlements, including those marked on the map.

19             Whilst you were training locals and the volunteers who came from

20     Serbia, were you aware of anybody else conducting training in the region?

21        A.   When we crossed over, nobody else was involved in training.  We

22     were the only ones who had taken the task upon ourselves.

23        Q.   Did you come across a man called Baja?

24        A.   When I toured the area in order to obtain information from the

25     military and everybody else to be able to accomplish my mission, and that

Page 13199

 1     was to mark all the units in the area on the map, starting with the

 2     military, the Territorial Defence, and others, I did come across a person

 3     called Milovac [phoen] who was a former member of the Novi Sad SUP.  He

 4     was fired.  His nickname was Baja.  He sported a red beret.  He bragged

 5     about some training that he conducted.  However, knowing him, I'm sure

 6     that he did not have the necessary knowledge to do it.  Even if he had

 7     been involved in training, I'm sure that his group was small and that the

 8     intention for them was not to defend the population there.

 9        Q.   Where did you claim to have conducted training?

10        A.   As far as I can remember, I think it was Ilok.

11        Q.   Did you ever meet a recruit from Ilok whilst you were in

12     Eastern Slavonia?

13        A.   Never.  Nobody but him.

14        Q.   And in relation to your training, what precise role, then, did

15     you play?  How did it work?

16        A.   Since I was the Chief of Staff, my role was to make a rota and

17     inform members of the TO as to what would be done on what day and in what

18     settlement.  More specifically, I can tell you that each day a group of

19     three or four members of the police who had crossed over together with us

20     would go to one part of a settlement, for example, Borovo Selo.  The

21     first neighbourhood as you entered was Savola [phoen].  On that day, we

22     conducted training or, rather, we stayed for three or for days, then we

23     moved to Srepulje [phoen], and then we moved to the centre.  It was just

24     the basic infantry training, familiarization with the weapons, in most

25     cases weapons that could no longer be used.  Obsolete.  We also trained

Page 13200

 1     them about moving around the area and the bit about defence.

 2             Those were the A, B, Cs that we could teach them within the scope

 3     of three days, and this is what we did.

 4        Q.   And after you had finished training a particular individual, did

 5     you have a role in directing where they should then be stationed or who

 6     they should be subordinated to?

 7        A.   We conducted training in settled areas, which means that those

 8     men were members of the local TO and they stayed there.

 9             However, a couple of volunteers that we trained, who had crossed

10     across the bridge in the centre, we are talking about 10 or 15 people,

11     underwent a training of 10 to 15 days.  If they were good.  Because

12     Badza's intention was to set up a unit that would be equipped with

13     weapons and vehicles.  They would have been a mobile unit.  However, that

14     never materialised.  We did not have the resources.  In other words, we

15     never received either the vehicles or the weapons.

16             We had requested all of that from the TO or, rather, from

17     Goran Hadzic and Ilija Kojic.  But nothing came out of that.

18        Q.   Let me just ask you if you would look at 1D5001, the map.

19             JUDGE ORIE:  Mr. Jordash, before we move to the next subject, I'm

20     looking at the clock.  This would be approximately the time we take

21     another break.

22             MR. JORDASH:  I'm happy to stop here, Your Honour.  Thank you.

23             JUDGE ORIE:  We'll take a break and we resume at ten minutes to

24     6.00.

25                           --- Recess taken at 5.24 p.m.

Page 13201

 1                           --- On resuming at 5.56 p.m.

 2             JUDGE ORIE:  Mr. Jordash, are you ready to proceed?

 3             MR. JORDASH:  Yes, please.

 4             JUDGE ORIE:  I would like to inform you that you used, net time,

 5     two hours and four minutes.

 6             MR. JORDASH:  I hope to finish within 30 minutes.

 7             JUDGE ORIE:  Yes.  Please proceed.

 8             MR. JORDASH:

 9        Q.   Mr. Witness, you -- we were discussing training, and you noted

10     that your role was to make a rota and inform members of the TO as to what

11     would be done, on what day, and in which settlement.

12             When you used the word "settlement," what do you mean by that

13     precisely?

14        A.   The training of the Territorial Defence was conducted in every

15     populated area.  One populated area was divided, for instance, into three

16     stages.  The first stage is one day; the second stage, the next day; and

17     the next stage in the third part of the populated area.  Or, if it was a

18     smaller place, it was all conducted in one day.

19        Q.   Well, how -- how was it -- are we talking about towns and

20     villages or regions?  How were you dividing up the regions, in terms of

21     developing a rota system?

22        A.   Considering that there were just a few instructors, we were able

23     to conduct training in four places.  That means on one day it was

24     conducted in Borovo Selo, to take that example, in Sevovi [phoen], the

25     second in Srepoja [phoen], the third in another area, and the fourth

Page 13202

 1     group remained in the centre itself, in Erdut.  That group underwent

 2     training in the town itself, in the village itself.  Not on training

 3     ground, but the very place where the trainees lived.

 4             We did not hold any towns because not a single town was under the

 5     control of Serbs.

 6             MR. JORDASH:  Could we have on the screen, please, P61.

 7        Q.   Now, P61, as you're going to see, Mr. Witness, is a transcript of

 8     part of the Kula award ceremony.  You've read this transcript before; is

 9     that correct?

10        A.   You're right.

11        Q.   And you were present at the award ceremony; is that correct?

12        A.   I was present at the celebration of the anniversary of the unit

13     in Kula.

14        Q.   Now I'll come back to the ceremony in general shortly, but I want

15     to just ask you to look at one part of the speech given by Mr. Simatovic.

16             MR. JORDASH:  Page 11, please, of the English and page 8 of the

17     B/C/S.

18        Q.   Now, Mr. Simatovic says, amongst a number of things, that the

19     unit of the DB was involved, as we can see at the top of the English page

20     at line 3, in setting up 26 training camps for special police units of

21     Republika Srpska and Republic of Serbian Krajina.  And he lists a number

22     of places in the Serbian Krajina, and I want to ask you about three of

23     them; Lezimir, Ilok, and Vukovar.

24             Did you ever meet a recruit from Lezimir when you were present

25     training TOs in Eastern Slavonia?

Page 13203

 1        A.   Not a single trainee came to our area, nor do I know that there

 2     were any training centres there.

 3        Q.   And in relation to Vukovar, did you have any information about

 4     any training being conducted in Vukovar around the time you were present

 5     in Eastern Slavonia?

 6        A.   The only thing I can say is that training in Vukovar was

 7     conducted in Petrova Gora barracks, and a military man nicknamed Kole was

 8     in charge of that training.  And he was also a member of the staff when I

 9     transferred.

10        Q.   A member of which staff?

11        A.   The one headed by Mr. Badza, the staff of the

12     Territorial Defence.

13        Q.   And when you say he was a military man, did he have a military

14     background before coming to the staff of the Territorial Defence?

15        A.   Yes, yes.  He was a member of the Yugoslav People's Army.

16             MR. JORDASH:  Could we have on the screen, please, D341.

17        Q.   I just want to return briefly to the subject of Ilok and the

18     subject of any training there.

19             THE REGISTRAR:  It is D337 now; it's changed.

20             MR. JORDASH:  Oh, I beg your pardon.  I'm sorry.

21        Q.   Now, we can see Ilok to the left of Backa Palanka, a little

22     outcrop of Croatia.  Now, you were present - is this right? - up until --

23     let me be sure about this.

24             When did you leave Eastern Slavonia?

25        A.   I didn't understand the question.

Page 13204

 1        Q.   How long were you working under Badza in Eastern Slavonia?  When

 2     did you leave?

 3        A.   After the liberation of Dalj, a couple of days after the

 4     liberation of Dalj, we crossed over, and I had spent two months in that

 5     area because I had some family problems.  I was divorced from my wife,

 6     and I got custody of the children, had to take care of them.

 7        Q.   Did you leave before or after the fall of Vukovar?

 8        A.   Before the fall of Vukovar.  I left a couple of days before

 9     Bogdanovci fell.

10        Q.   In order to get from Vukovar to -- no, let me ask this

11     differently.  In order to get from Borovo Selo to Ilok at the time when

12     you were in Eastern Slavonia, what was the route you would take?

13        A.   Considering that we were based in Erdut not Borovo Selo, but even

14     when I was around Borovo Selo, I had to go to Backa Palanka to go to Ilok

15     from Croatia.  I couldn't go straight to Ilok.  I had to go via Serbia.

16        Q.   So is this -- does this follow, then:  If there was training in

17     Ilok, the recruits would have to go through Serbia and back into Croatia

18     to get to Erdut?

19        A.   Correct.

20        Q.   The -- when you were in Eastern Slavonia, what was the population

21     of Ilok?  What, in terms of ethnicity, was the population?

22        A.   It was a mixed population.  There were more Croats than Serbs and

23     others, and that is so to date.

24        Q.   Did you ever have any complaints from Croats about training by

25     Serbs in Ilok?

Page 13205

 1        A.   No.  It's quite certain if training had been conducted there that

 2     people would have complained.

 3        Q.   Are you able to explain how big Ilok is?  How long would it take

 4     to walk across Ilok.

 5        A.   Ilok is a small place with a population of about 1.000-plus, so

 6     that you would cross it rather quickly, depending on how fast you walk.

 7     But it's a small place.  You couldn't do anything without being noticed.

 8     If anything had gone on, it involved a small number of people.  I don't

 9     think that I, as a graduate of the academy, would have chosen that place

10     for -- for that kind of thing.

11        Q.   What do you mean by that?  You, as a graduate of the academy,

12     wouldn't have chosen that place for training.  What do you mean by that

13     sentence, please?

14        A.   Strategically it is not a suitable place, especially because it's

15     a multi-ethnic community and it would cause tensions in that community.

16     And there is no link with the places where the trainees would be going.

17     That's my thinking, at least.  That's why I wouldn't do it there.

18     Because if the unit had been trained there, the time it would take them

19     to go to Erdut, they could have reached Belgrade.

20        Q.   Did you ever meet a recruit whilst you were in Eastern Slavonia

21     who had been trained at Pajzos?

22             You didn't get the question.  Did you ever meet a recruit while

23     you were in Eastern Slavonia who had been trained at Pajzos?

24        A.   No, never.  I don't even know where that is.

25        Q.   Okay.  Let's return to your statement, please; D334, I hope.

Page 13206

 1     Yeah.  And paragraph 58.

 2              And this paragraph, Mr. Witness, discusses the arrival of a

 3     group of 40 police officers under Veljko Bogunovic.  And you say in

 4     paragraph 58 you were not involved in equipping the police stations and

 5     you don't know anything about that.

 6             But in relation to these 40 police officers, do you know what it

 7     is they did?  Did they, in fact, set up police stations?

 8        A.   At the staff, the person who was in charge of training people for

 9     police stations was Mr. Zavisic.  Three or four days after we arrived,

10     that group of policemen also arrived, and they were accommodated in Dalj,

11     in the kindergarten building.  Tarbuk, Knezevic, and Momcilo Radovic were

12     their leaders.  I know a couple of names, but I don't think they were

13     that important.  I have already mentioned the main people.  I can say

14     that they were the ones who went to populated areas.  And in areas where

15     the police had their bases, they started training and equipping police

16     stations.  I can say that there were Tarbuk, Knezevic, Radovic,

17     Boro Preradovic, and others, and in those places it worked.  But in

18     places where Veljko Bogunovic was in charge, it went rather sloppily, and

19     that's why Badza often tried to remove him from that position and replace

20     him.  And if you want more details, I can provide them.

21        Q.   Do you know where Knezevic was?

22        A.   Knezevic, I think, was in Ilok, and that was one of the better

23     police stations that really started operating.  From the information I

24     have, all the houses and all the population were registered.  It was an

25     exemplary station.  And Badza often praised him for the way he did his

Page 13207

 1     job, the way we were trained to do it, the way we were used to doing it.

 2        Q.   And when you in say places where Veljko Bogunovic was it was

 3     rather sloppy and Badza tried to remove him, why did Badza try to remove

 4     him, precisely?

 5        A.   Every job that he was given to do, he would not complete.  And

 6     nothing ever worked that he handled, in the police stations that were

 7     assigned to him.  Somebody else always had to come subsequently and do

 8     the job properly.  And I don't know if I mentioned this before, but that

 9     group that arrived consisted of policemen that before the conflict had

10     been members of the Croatian MUP and they had all come as volunteers to

11     help form those units and to help lead these units.  When I say "units,"

12     I mean police stations.  I'm sorry, I suddenly moved to military

13     terminology.

14        Q.   Well, were these police officers and police stations involved in

15     combat?

16        A.   No.

17        Q.   Just briefly, then we can move on:  What were they involved in?

18        A.   Their main job was to maintain law and order and normal life, to

19     put a stop to looting and theft and looting from abandoned houses, and to

20     take care of the property of all the Serbs and Croats who had abandoned

21     their homes so that people could feel safe and return to their homes so

22     that normal life could be restored to all these places.  They were doing

23     regular police work, and we all know what regular police work is.

24        Q.   Do you know where they received supplies from?

25        A.   As far as uniforms are concerned, they brought their own

Page 13208

 1     uniforms.  We from the staff did not procure uniforms, and I don't know

 2     where they were supplied from.  We did write up lists of requirements,

 3     both for the Territorial Defence and the police, and we sent these to

 4     Badza.  And where he forwarded these requests, I really don't know.

 5        Q.   Thank you.  Moving to paragraph 63 of your statement, a

 6     paragraph where you discuss Arkan.  And you say:  "Arkan and his unit

 7     were not under the command of the TO staff."

 8             Do you know who Arkan was subordinated to, if anybody, when on

 9     military operations?

10        A.   I explained to what extent I knew Arkan.  We had clashes with him

11     all the time.  Both we in the staff, excepting Badza, and the members of

12     the police who came with us.  He was involved in operations together with

13     the JNA.  But he always acted autonomously.  He was not subordinated to

14     anyone in the JNA.  He would receive his own axis of movement, and he

15     acted independently.

16        Q.   When you say "we had clashes with him all the time," who had

17     clashes with him and what were the clashes about?

18        A.   Arkan was a man who exploded very easily with a bad temper,

19     aggressive, and, above all, he was a criminal.  The people, the policemen

20     from Belgrade knew that, and he didn't want to be in the same centre as

21     him.  And we senior officers suggested that to Badza and insisted, and we

22     moved away from Erdut because we didn't want to be there because Arkan

23     was in charge of security of the training centre itself.  He was friends

24     with Goran Hadzic, and he met with him quite often, and I suppose that he

25     is the man to whom Arkan was subordinated.

Page 13209

 1        Q.   Did you have the opportunity to observe Arkan's relationship with

 2     Ilija Kojic?

 3        A.   I know Ilija Kojic rather well, and I did not see him often in

 4     the company of Arkan.

 5        Q.   Do you know if Ilija Kojic had formed a view about Arkan?

 6        A.   His opinion was no different from mine or the opinion of all the

 7     policemen who were there.  It was not good.

 8        Q.   How do you know that?

 9        A.   I spoke to Ilija Kojic quite often and he told me that directly.

10     And if he had had any power, it's certain that Arkan would not have been

11     there.

12        Q.   Why do you say that?  What did Kojic to say to give you that

13     impression or have you reach that conclusion?

14        A.   The entire population of that area was dissatisfied with the

15     presence of Arkan because he acted very arrogantly and never respected

16     any decisions that had been taken.  In terms of deadlines and methods of

17     work, he did as he pleased.

18        Q.   But what makes you think or conclude that Ilija Kojic would have

19     removed Arkan if he'd had the power?  What did Kojic say to you or anyone

20     else that led you to that conclusion?

21        A.   Well, considering that I was the one who had had contacts with

22     Ilija Kojic at the check-point even before when he was crossing with

23     Goran.  He told me that he had asked Goran, that Arkan should leave the

24     area.  However, that didn't happen while I was there.

25        Q.   Thank you.  Now just finally, just two brief subjects.  I want to

Page 13210

 1     return to the Kula awards ceremony.

 2             Yesterday you watched a video, D131 in this case, which was part

 3     of the Kula awards ceremony; is that correct?

 4        A.   Correct.

 5        Q.   And the video that you watched, D131, did it contain the whole of

 6     the ceremony?

 7        A.   No, not all of it.

 8        Q.   What did it show and what was missed out?

 9        A.   The granting of awards to individuals was shown.  However,

10     decorations were handed out by politicians to members of the unit,

11     members of the public security, members of the state security, members of

12     the political circle, and prominent businessmen who had helped build the

13     centre was left out.

14        Q.   And did you observe Kurtez [phoen] receiving an award?

15        A.   Yes.  Yes, that was shown in the video.

16        Q.   Do you know why Kurtez received an award?

17        A.   For his contribution to the building of that centre.

18        Q.   And how do you know that?

19        A.   The man who was director of the customs administration at the

20     time, Kurtez, gave a significant financial contribution to the building

21     of that centre.  I know that from my friends who knew him.

22        Q.   In which capacity were you invited to the ceremony?

23        A.   At the time, I was chief and also contributed to the building of

24     that centre, and members of that unit came to Becej for -- to be trained

25     in swimming.

Page 13211

 1        Q.   Members of which unit?

 2        A.   From the centre in Kula.

 3        Q.   Did you receive an award?

 4        A.   No, no.

 5        Q.   Do you know why that was?

 6        A.   It's a bit personal but it's not a problem, I'll answer.  I've

 7     told the truth all the way.

 8             The man who decided who would be given awards in the public

 9     security sector, when the name of Bogunovic was mentioned, he associated

10     it with Veljko and that made him strike out my name, and I can also say

11     that I am very sorry I did not receive an award from Mr. Stanisic.

12        Q.   Sorry, who struck out your name and who associated Bogunovic,

13     you, with Bogunovic, Veljko?

14        A.   I've already mentioned that.  Badza had a lot of trouble with

15     Veljko Bogunovic.  And as soon as that last name was mentioned, I

16     suffered the consequences.

17        Q.   Did other people of the public security receive an award at the

18     ceremony, and, if so, who made that decision to give them awards?

19        A.   Yes, yes, some people did.

20        Q.   And who made the decision?

21        A.   The chief of public security sector.

22        Q.   Now, on the video there are some men who are referred to as

23     veterans.  What was your understanding of that term?

24        A.   I saw those people as people who had fought at the various fronts

25     for the unit to take off the ground and to continue existing in view of

Page 13212

 1     the fact that in Serbia, Kosovo, and Vojvodina special operations units

 2     already existed.  I believed that the state did not have resources to

 3     finance another unit.  I believed that that was just bragging in order to

 4     provide funds for this unit to continue working and for the other one to

 5     be disbanded.

 6        Q.   Just try to break that down a bit.

 7             Who were the veterans at that awards ceremony, as you understood

 8     them to be?

 9        A.   I know most of the veterans.  They hail from different regions of

10     the former Yugoslavia.  That means that they were not all in the same

11     place.  That group consisted of people who had served in different

12     places.

13        Q.   When, as you understood it, did the state security unit, the JSO,

14     or any state security unit come into --

15             MR. JORDASH:  Mr. Farr's on his feet.

16             JUDGE ORIE:  Yes.  And usually we wait until the question has

17     been finished, unless there's any reason to intervene at any early stage.

18             MR. FARR:  I'll wait for the question to be finished,

19     Your Honour.

20             JUDGE ORIE:  Mr. Jordash, please complete your question.

21             Before you answer the question, would you please wait a second.

22             Yes.

23             MR. JORDASH:

24        Q.   Let me try to break down what I was going to ask you,

25     Mr. Witness.

Page 13213

 1             In the awards ceremony, Mr. Simatovic made a claim that there was

 2     a state security unit from 1991.  What's your understanding of the

 3     situation?

 4             JUDGE ORIE:  Mr. Farr.

 5             MR. FARR:  The objection is to foundation, Your Honour.  There's

 6     been no evidence based on which the witness could reach a conclusion on

 7     that issue.

 8             JUDGE ORIE:  Well, we do not know.  It may be part of his answer.

 9             Let's just ...

10             Witness, when Mr. Simatovic made a claim that there was a state

11     security unit from 1991, could you give us any information about the

12     existence and the date mentioned?

13             THE WITNESS: [Interpretation] As far as I know, that unit had

14     been established a year before that celebration and the award ceremony.

15             I had participated in the building of that centre.  And since my

16     parents lived very near Kula, when I went there, when I visited there, I

17     could see that refugees were housed in a very derelict building.  There

18     was no unit.  I am not aware of any such unit having been formed either

19     in Vojvodina, in Serbia, save for special units that belonged to the

20     public security.  There were three of them.  One in Pristina, one in

21     Belgrade, and one in Novi Sad.

22             JUDGE ORIE:  Yes.  You say as far as I know that unit had been

23     established a year before the celebration.  In your explanation, you very

24     much refer to the --

25             THE WITNESS: [Interpretation] That's correct.

Page 13214

 1             JUDGE ORIE: [Previous translation continues] ... centre.  And, of

 2     course, a centre is not the same as a unit.  As far as the unit is

 3     concerned, your answer is that you were not aware of any such unit having

 4     been formed in -- either in Vojvodina, and then you talk that you do not

 5     know of any such unit being formed.

 6             Do you have any further factual information about the

 7     establishment of that unit, which you believe was established a year

 8     before the celebration, as you told us?

 9             THE WITNESS: [Interpretation] I don't have any other information.

10             For a unit to exist, it had to have a base, a seat, as it were.

11             JUDGE ORIE:  That could be any base.  Would you agree with that?

12     Not necessarily the one you had on your mind.

13             THE WITNESS: [Interpretation] I agree with you.  However, that

14     unit had 500 members who required a lot of space.  They could not have

15     been billeted in a small place, and they would have been really difficult

16     to hide.

17             JUDGE ORIE:  Yes.  This is -- this is logic rather than factual

18     information.

19             Mr. Jordash, I'm looking at the clock.  You certainly went beyond

20     your 30 minutes.

21             MR. JORDASH:  If I can just take another five, then I can wrap

22     up, if I may.

23             JUDGE ORIE:  Yes, of course I'm also keeping in the back of my

24     mind what I said before about repetitiousness.  But take your five

25     minutes, but I'll be strict on that then.

Page 13215

 1             MR. JORDASH:

 2        Q.   Could we go to paragraph 67 of your statement.  Jovica Stanisic

 3     and the arrest of Erdemovic.

 4             During this process of arresting Erdemovic and sending him to

 5     The Hague, did you speak directly to Mr. Stanisic or receive instructions

 6     or directions or orders indirectly from him?

 7        A.   Erdemovic and Kremenovic were arrested in the territory where I

 8     was the chief of the OUP.  In the afternoon, I was called by a DB

 9     operative who was affiliated with the DB Novi Sad and he said that he had

10     guests from the security centre, from the MUP.  When they entered my

11     office, I received the deputy chief of the centre in Novi Sad.  I've been

12     here for three days and I have been trying to remember his family name.

13     He was at the celebration in the centre, but I can't remember his name.

14     There was also Operative Blisin [phoen] and two members from Belgrade.

15     They arrived and they told me that Stanisic sent his greetings and that

16     he wanted us to carry the mission through to the end and that Stanisic

17     said that those two men had to be sent to The Hague.

18             He sent us a message that we had locate them.  That activity

19     lasted two days.  And every evening when they returned to my office, they

20     repeated that Jovica insisted that the two had to be sent to The Hague to

21     be tried for what they had done, both the two of them as well as all the

22     others who had been involved in similar things.

23             At the end of the day, that operation was carried through

24     successfully, owing to Jovica.  They were sent to The Hague, and I hope

25     that they are serving their sentences that they deserve.

Page 13216

 1             The only thing that I'm not sure about as I sit here today is

 2     whether one of them was Franko Simatovic who arrived or perhaps it was

 3     Mr. Tepavcevic.  They look more or less the same and I didn't know any of

 4     them, so I would be mistaken to claim that it was either of them.  Maybe

 5     one of the two of them could tell you which one came to my office.

 6        Q.   Was Kremenovic sent to The Hague?

 7        A.   Yes.

 8        Q.   Now, during your time in contributing to this arrest and

 9     transfer, did you understand what it was that was motivating Stanisic to

10     send these men to The Hague?

11        A.   As far as I know Stanisic, he respects the law, he's honest, and

12     I believe that anybody who transgressed would be apprehended by him.  Why

13     not the Erdemovic and the other one?  What they did was certainly not

14     honest, and they deserve what happened to them.

15        Q.   Where do you -- sorry.  Let me start that again.

16             How did you form this opinion of Mr. Stanisic?  What -- can you

17     give us some facts to indicate where you came to that view.

18        A.   I had a couple of tasks that I carried out in Belgrade.  At that

19     time, Jovica was still an operative and we worked together.  I have a

20     very high opinion of him and Mr. Stanisic's professional attitude to

21     every task he was given.  I hope that he, indeed, carried out all the

22     tasks that were given to him successfully.

23        Q.   Did he make reference to war crimes at any stage during the

24     arrest of Erdemovic or subsequently?

25        A.   I was not at one celebration where Mr. Stanisic was present.  I

Page 13217

 1     attended a lot of ceremonies at the Ministry of the Interior in Belgrade,

 2     because I received awards and decorations.  Mr. Stanisic was always

 3     there.  And in every conversation he insisted and repeated that everybody

 4     who committed crimes had to face justice for what they did.

 5             JUDGE ORIE:  Mr. Jordash -- [Overlapping speakers] ...

 6             MR. JORDASH:  Finished.

 7             JUDGE ORIE: [Overlapping speakers] ... I would be strict.  The

 8     five minutes are over.

 9             MR. JORDASH:  Thank you.

10        Q.   Thank you, Mr. Witness.

11             JUDGE ORIE:  Mr. Bakrac, are you ready to cross-examine the

12     witness?

13             MR. BAKRAC: [Interpretation] Yes, Your Honour.

14             JUDGE ORIE:  You'll now be cross-examined by Mr. Bakrac.

15     Mr. Bakrac is counsel for Mr. Simatovic.

16             Do we have a time indication, Mr. Bakrac?

17             MR. BAKRAC: [Interpretation] Your Honour, I'll try to finish

18     before 7.00 today.  If not, maybe I will need another ten minutes

19     tomorrow, with your leave.

20             JUDGE ORIE:  Yes, let's proceed.  Thank you.

21             MR. BAKRAC: [Interpretation] Thank you, Your Honour.

22                           Cross-examination by Mr. Bakrac:

23        Q.   [Interpretation] Good evening, Mr. DST-074.

24        A.   Good evening.

25        Q.   During the examination-in-chief conducted by my learned friend

Page 13218

 1     Mr. Jordash, you mentioned several names of people whom you come across

 2     in Eastern Slavonia.  During this trial we have heard the names of two

 3     persons; I would like to check whether you're familiar with those names.

 4             Are you familiar with the names of Boro and Pujo?  Do you know

 5     those names?

 6        A.   Yes.

 7        Q.   Could you please tell us who they are.

 8        A.   Boro, his family name was Predragovic, and his first name is

 9     Borislav.  And Momcilo Radovic is Pujo.

10        Q.   Which service did they belong to?

11        A.   They were members of the public security service.

12     Momcilo Radovic belonged to the SUP of Novi Sad and Boro Predragovic was

13     employed by the training centre in Sremska Kamenica.

14        Q.   Thank you.  Sir, my learned friend Mr. Jordash also asked you

15     about training centres, and you mentioned training in Vukovar, in the

16     Petrova Gora barracks.  You said that the person in charge of that

17     training was a soldier whose nickname was Kole.  That's on pages 55 and

18     56.  Am I correct in saying that?

19        A.   Yes.  But his name was not Kostic, but Kovacevic.  His nickname

20     was Kole.  He was an officer.  He was a captain by rank.  And he was a

21     member of the Territorial Defence Staff.  We were not the only ones who

22     crossed over.  There were also officers, and all the commanders of the TO

23     were members of the staff.

24        Q.   Does the name Borislav Kostic ring a bell?  Is that perhaps Kole?

25        A.   Radoslav Kostic, Borislav Kostic.  Radoslav Kostic was killed and

Page 13219

 1     the centre bore his name.  What was the name?  Kostic?

 2        Q.   Borislav.

 3        A.   It is possible that that was him.

 4        Q.   That Kole whom you described as the person in charge of the

 5     training centre, did he sport a red beret?

 6        A.   None of us wore red berets.  And that includes him, as far as I

 7     know.

 8        Q.   Thank you, Witness.  And now we will go back to the part of the

 9     examination-in-chief when Mr. Jordash asked you about Arkan's arrival at

10     the crossing.  If I understood you properly, the first time you told him

11     to go back.  And then on the following day he returned with a permission

12     signed by Mr. Radmilo Bogdanovic.  Did he arrive in a vehicle, one or

13     more?  How many vehicles were there?

14        A.   He crossed over in jeeps of foreign make.  You will see it in my

15     statement there were three or four jeeps.  Those were Pajero Jeeps, and

16     he wore olive-drab American uniform or, rather, camouflage uniform.  I

17     don't know what to call it.

18        Q.   The Pajero Jeeps that he used, were those from civilian vehicles?

19        A.   Yes.

20        Q.   Thank you, Witness.  You also mentioned, on page 49,

21     lines 8, 9, and 10, that volunteers received salaries from their

22     companies or institutions.  Did I understand you properly?  Did you say

23     that those people who left Serbia and went to help people in these areas

24     received monies from their companies or institutions?

25        A.   Yes, they were paid regularly.  They received salaries in the

Page 13220

 1     same way as if they worked for their companies.  But they had to provide

 2     a certificate signed by Badza attesting to the fact that they were indeed

 3     deployed in that area.

 4        Q.   Was that done based on a regulation that prevailed in Serbia at

 5     the time regarding people who were volunteers and who were still to be

 6     paid from their companies?

 7        A.   I really don't know.  I only know that they wanted us to provide

 8     the certificates.  And as for any regulations, I'm not a man who follows

 9     regulations, really.

10        Q.   Thank you, Witness.  What you don't know, you don't know, of

11     course.

12             Let's move on.  And now let us look at Exhibit P1127.  I am

13     interested in the first paragraph.  Let's wait for the document to be

14     displayed.  P1127, we have it now.

15             Let us look at the first page and let us read the first

16     paragraph.  Tell me, please, whether you can see that this is a letter

17     sent by the Vukovar SUP to the Ministry of the Interior of the Republic

18     of Serbian Krajina in Knin.  Please look at the first paragraph and tell

19     me whether this reflects what you know about the area at the time.

20        A.   I cannot read.  It's rather blurred.  But judging by the date, I

21     can say that at the time when this was issued, I wasn't there.  I really

22     don't know what I could say about the document because I was already in

23     Becej and I proceeded with my regular tasks there.

24             So I wasn't there on this particular date.

25             As far as Arkan is concerned, I've already said several times

Page 13221

 1     that wherever he was, nobody could control him.  He did whatever he

 2     deemed proper and correct.  I can't read this.  It's blurred.

 3        Q.   Just a moment, please.  We heard you say that you can't say

 4     anything about this.  It says here that on the 3rd of August, 1992,

 5     information was received about a special-purpose unit being established

 6     in Ermestinovo [phoen].  Its name would be Red Tigers.  And it would be

 7     part of the 101st centre of the MUP of Serbian Krajina under the

 8     leadership of Arkan.

 9        A.   I really can't comment.  I wasn't there.

10        Q.   Thank you.  I just wanted to check whether you know anything

11     about this.  The second paragraph concerns a conflict between Kojic and

12     Arkan.  Since you mentioned that, I wanted to check whether you are aware

13     of this conflict, but the period is not relevant -- irrelevant

14     [as interpreted].

15        A.   As far as the conflict between Kojic and Arkan is concerned, that

16     started on day one, from the moment when he crossed over with the permit.

17     Ilija Kojic always expressed negative views of Arkan's deployment in

18     Tenja and everywhere else.  And those were not just Ilija's words.  Those

19     were the feelings of many other citizens who approached me with requests

20     to send him back.  But who was I to do that?

21        Q.   Witness, thank you.

22             MR. BAKRAC: [Interpretation] Your Honours, I have two

23     video-clips.  I would like to finish my cross-examination with them.  I

24     am -- I believe that I could do that within the next ten minutes.  We

25     received those video-clips during our investigation or, rather, during

Page 13222

 1     the break from the person who made the video-clips available to us.

 2     We're still talking to that person, and with your permission we will like

 3     to propose the video-clip as an addition to our 65 ter list.  These two

 4     video-clips are relative to the centre in Erdut.  We wanted to show those

 5     two video-clips without any text in order to see whether the witness is

 6     in a position to provide any comments about those places.  We don't have

 7     a transcript.  But the text is not important.

 8             Mr. Farr wanted an explanation about the origin of the

 9     video-clips.  With your permission, what we want to see is just the

10     image.  We would like to have them as 65 ter list exhibits at the moment.

11     Later on, we can transcribe them and tender them in any other form.  We

12     are now in closed session.  I can mention the name of the person who has

13     provided the video-clips.  He was a cameraman in the Serbian Volunteers

14     Guard, in Arkan's unit.  If this part of the trial is ever opened for

15     public, I would kindly ask for this part to remain in closed session

16     until the moment we see whether this person, the cameraman in question,

17     requests protective measures.

18             JUDGE ORIE:  That's on the record.  At this moment there's no

19     need to decide on that.

20             Mr. Farr, any further objections against showing the video

21     without sound?  And then if we only look at the pictures, I want the

22     sound to be switched off so that the witness does not receive any

23     information more than the Chamber and the non-B/C/S speaking persons.

24             MR. FARR:  The issue with respect to the video is simply that we

25     haven't been able to see them yet.  Ordinarily they would have been

Page 13223

 1     disclosed at the beginning of cross exam -- at the beginning of direct

 2     examination at the latest.  But we're happy for them to be played.  And

 3     then if we have an objection to admission, we can bring that up at that

 4     point.

 5             JUDGE ORIE:  Let the video be played.  We've spent already -- you

 6     said there were two videos.  If perhaps we start with the one.  And

 7     perhaps we might need five more minutes tomorrow.  But I would rather not

 8     add to my already bad reputation in going beyond time limits.

 9             The first video would be how long?

10             MR. BAKRAC: [Interpretation] The first one, 40 seconds.

11             JUDGE ORIE:  Let's start with the first one.

12             And could we ask the witness to take his earphones off so that

13     there's no way that he would -- yes.  Just look at your screen.

14             And may the video be played.

15                           [Video-clip played]

16             JUDGE ORIE:  Yes, you had not informed us that we would receive

17     the full text at the bottom of the ...

18             So do you read any English, Witness?  Could you please put on

19     your earphones again.  Yes, can you read English?

20             THE WITNESS: [Interpretation] No.

21             JUDGE ORIE:  So now we are just in the opposite position, that

22     now everyone has seen what has been said but that the witness apparently

23     is unaware of it.

24             Mr. Bakrac, put your question to the witness.

25             MR. BAKRAC: [Interpretation] I apologise for the omission,

Page 13224

 1     Your Honours.  I forgot to mention the titles.

 2        Q.   Witness, did you recognise anybody in the clip?

 3        A.   I didn't see a thing.  I did not have the image on the screen at

 4     all.

 5             JUDGE ORIE:  Well, I think it's ... could it be replayed; and

 6     could -- it's only 40 seconds.  But everyone is really trying to add to

 7     my bad reputation, I think.

 8             Could it be replayed.

 9             And could you take off your earphones.

10                           [Video-clip played]

11             MR. BAKRAC: [Interpretation]

12        Q.   Witness, did you recognise the person with the bull horn?

13        A.   Yes.  Zeljko Raznjatovic, Arkan.

14        Q.   Did you see people in uniforms with helmets whom he addresses?

15        A.   Yes.

16        Q.   Can you, based on this clip, recognise the formation that those

17     individuals belonged to?

18        A.   These are military uniforms.  JNA uniforms, to be more specific.

19        Q.   Thank you, Witness.

20             MR. BAKRAC: [Interpretation] Your Honours, with your permission,

21     I will show the next video-clip tomorrow morning.  And all in all, I will

22     need only ten minutes, and I will not have any more questions.

23             I believe that I have done my utmost to improve your reputation,

24     or repair it, as it were.

25             JUDGE ORIE:  I'm very grateful for that, Mr. Bakrac.  My

Page 13225

 1     reputation is saved by counsel.  I highly appreciate that.

 2             We would like to see you back tomorrow, tomorrow morning, at 9.00

 3     in this same courtroom.  Meanwhile, you are instructed that you should

 4     not speak with anyone about your testimony or communicate in any other

 5     way, whether that is your testimony you have given today or whether

 6     that's testimony still to be given tomorrow.

 7             Since we will adjourn in public session, I would like to invite

 8     you to follow the usher and leave the courtroom now.

 9                           [The witness stands down]

10             JUDGE ORIE:  We return into open session.

11                           [Open session]

12             THE REGISTRAR:  We are in open session, Your Honours.

13             JUDGE ORIE:  Thank you, Madam Registrar.

14             We'll adjourn for the day, and we'll resume tomorrow, Wednesday,

15     the 17th of August at 9.00 in the morning in this same Courtroom II.

16                            --- Whereupon the hearing adjourned at 7.01 p.m.,

17                           to be reconvened on Wednesday, the 17th day of

18                           August, 2011, at 9.00 a.m.