Tribunal Criminal Tribunal for the Former Yugoslavia

Page 13169

1 Thursday, 21 November 2002

2 [Open session]

3 [The accused entered court]

4 [The witness entered court]

5 --- Upon commencing at 9.04 a.m.

6 JUDGE MAY: Yes, Mr. Nice.

7 MR. NICE: Can I return to the question of how much time should be

8 available for the evidence-in-chief of this witness?

9 JUDGE MAY: Well, we've heard submissions on this, if I may say,

10 very adequately presented by Ms. Uertz-Retzlaff. We've had the

11 opportunity of reflecting on the matter and we've made a decision. I'm

12 not sure there's really anything you can add to it.

13 MR. NICE: Your Honour, first -- two points I'd like to clarify --

14 three, if I may, and I am only doing it because of my role in charge of

15 the case as a whole and there's one thing I want to say.

16 First of all, in case there's any ambiguity, what we're seeking is

17 six days, not four, that is, two additional days. We hope that was clear.

18 Second, the Prosecution's position is that it would be wrong,

19 frankly wrong, given the quality, the integrity, and the detail of this

20 witness to exclude any of his evidence.

21 Third, and I think this was not available in detail last night,

22 there is the statistics of the number of witnesses who would be saved

23 having to give evidence, and some analysis of the material that would be

24 lost if it was other than the full six days available for evidence. And

25 the statistics may help the Court, and I hope they will enable you to

Page 13170

1 review any decision tentatively made or provisionally made other than to

2 grant the two additional days.

3 Originally, we were allowed 71 witnesses for Croatia. We forecast

4 - obviously these things are not capable of the greatest precision - that

5 the fifth day of evidence of this witness would enable us to save eight

6 witnesses who we otherwise had a settled intention to call; some four

7 experts, two low-level insiders, and two verifiers of a document. The

8 sixth day would enable us to save a further five crime-base witnesses and

9 one journalist witness dealing with crime-base matters. Accordingly, the

10 total potential saving for those two additional days would be some 14

11 witnesses, which is in the order of 20 per cent of the allocation.

12 And in our respectful submission, it is entirely right that the

13 witness should be heard in full. If he is not heard in full, material

14 that will be left out would include direct contacts between the witness

15 and other members of the joint criminal enterprise plus evidence simply

16 not available elsewhere of the military structures of the areas of the

17 crimes allegedly committed. In our submission, this is material that the

18 Chamber should have, can have in the most economic form from this witness,

19 and that it would be inappropriate or wrong to exclude.

20 Thank you for allowing me to add to the arguments that were, as I

21 entirely accept, fully expressed -- not fully expressed, but expressed

22 before she had an opportunity with the team to do the research last night

23 by my learned colleague.

24 JUDGE MAY: Well, I must say that I think this part of the case

25 has been going very slowly indeed. In twenty-plus days we've heard about

Page 13171

1 12 witnesses. And of course, it is a matter of concern as to how you're

2 going to get through your case by the dates which we've allocated, with

3 such adjustment as there must be for illness.

4 MR. NICE: May I respond? Or maybe Your Honour hasn't completed

5 what you're going to say. The suggestion that the evidence has been going

6 slowly is one that we couldn't accept. The evidence is entirely different

7 in character because it's so much denser in content and we have taken

8 every available procedure to make matters go swiftly. We are, of course,

9 bound by the decisions of the Chamber in relation to matters of 92 bis and

10 so on, but we forecast that the very character of the evidence that is

11 coming in at the beginning of this phase of the trial will in fact enable

12 us to prove our case in, we hope, and realistically expect, the original

13 overall time allocations made by the Chamber.

14 JUDGE MAY: Well, I think it was the 12th of May. That day stands

15 for the moment. We will make such adjustment as we can and we think

16 proper for illness, but that is the date which you must have in mind, Mr.

17 Nice.

18 MR. NICE: We have. And of course I will do, in respect of

19 remaining witnesses, everything that can be done, as the whole team has

20 been doing so far, to make use of procedural steps to abbreviate evidence.

21 But we are bound by the Rules of the Tribunal and the practices of the

22 Chamber. So we press you to say that it is simply inappropriate to

23 restrict this witness's evidence and economic --

24 JUDGE MAY: Well, it's not the evidence; it's the speed with which

25 it's being taken. It can be taken more expeditiously, in my view.

Page 13172

1 MR. NICE: Well, I respectfully differ from that view, and my

2 learned colleague is, of course, master of the detail, as is the witness,

3 and the evidence is necessarily delivered at a speed that is going to be

4 capable of being understood and assimilated. There are other ways

5 evidence can be given. I'm only too happy for that to be dealt with.

6 Statements can be read, pre-read, and a witness can adopt his statement,

7 but those are not practices that this Chamber is yet in a position to

8 accept, and therefore we have the viva voce system of question and answer,

9 and I would reject entirely any suggestion that my learned colleague has

10 not been proceeding with this matter other than at a good speed.

11 JUDGE MAY: Not my view. Not that -- no criticism, may I say, but

12 -- because counsel, of course, approach things in their own way, and I

13 accept that. And counsel, as we recognise, Ms. Uertz-Retzlaff considers

14 the duty which she has to put the matter before us and also the witness on

15 occasion replies at a bit of length.

16 Well, we'll consider the matter and we'll reflect on it.

17 MR. NICE: Thank you.

18 JUDGE KWON: Mr. Nice, I think I can see your point, but what was

19 the base then when the Prosecution at the outset had said that it expected

20 to conclude this witness in three days and a half and how was it changed?

21 MR. NICE: You know, until you -- until you do these things, you

22 can never be quite sure, and of course Ms. Uertz-Retzlaff was well aware

23 of the considerable pressure that would be on her from the Chamber to deal

24 with matters at a particular speed. Until you actually do it in court,

25 you can't know.

Page 13173

1 Now, this witness -- and again, this is something that we have to

2 take into account. Witnesses are not as we would like them to be; they

3 are as they are. He's a meticulous man who gives evidence in detail,

4 according to the process of his memory and thought processes, and there is

5 a limit to which you can make one witness into a witness of another type.

6 JUDGE ROBINSON: Mr. Nice --

7 MR. NICE: Yes. I'm grateful to Ms. Uertz-Retzlaff. Of course,

8 we have to remind the Chamber, we pressed you to apply the provisions of

9 92 bis, which would have saved many hours or days, but the Chamber took a

10 different view. We would have preferred all the background material to

11 have been pre-read in a way that we respectfully press on the Chamber is

12 entirely appropriate, safe, and preserving of the accused's rights. But

13 the Chamber took a contrary view, which we have, of course, respected.

14 JUDGE ROBINSON: Mr. Nice, I'm not saying that I would accede to

15 the request, but it would seem to me that if we were to consider it

16 favourably, we would have to hold you very strictly to the 14 witnesses

17 whom you say you will not call. I would like to see the names of those

18 witnesses.

19 MR. NICE: I would always hope my word in court is something that

20 will be accepted. As to holding us to account, if that's expressed in the

21 view that my word is accepted, then of course I have absolutely no problem

22 with that as a proposition. I'm in a position to provide the list of the

23 names of those who we at present regard as witnesses we would no longer

24 seek to call. Yes, I can provide you with a list.

25 JUDGE MAY: Very well. We'll consider the matter.

Page 13174

1 MR. NICE: Thank you very much.

2 JUDGE MAY: Yes, Ms. Uertz-Retzlaff.

3 MS. UERTZ-RETZLAFF: Thank you, Your Honours.

4 WITNESS: WITNESS C-061 [Resumed]

5 [Witness answered through interpreter]

6 Examined by Ms. Uertz-Retzlaff: [Continued]

7 Q. Good morning, Witness.

8 A. Good morning.

9 Q. Can you speak into the microphone? The interpreters couldn't hear

10 you.

11 Witness, yesterday we spoke about the removal of Frenki and

12 Captain Dragan from the region in August, and I would like to ask you in

13 this context about a meeting. I would like to do that in private session.

14 [Private session]

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24 [Open session]

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

Page 13177

1 MS. UERTZ-RETZLAFF:

2 Q. We have mentioned several times Mr. Martic. You have also

3 referred to the support that he received from Serbia. Was Mr. Martic

4 loyal to Mr. Milosevic? Can you say?

5 A. Yes.

6 Q. Did Mr. Martic acknowledge his loyalty publicly during the

7 election campaign that he held in 1993/1994?

8 A. Yes, publicly. During the election campaign and after the

9 campaign as well, he said that he would be the provisional president of

10 Krajina, and once -- that he would be only the provisional president and

11 that he would hand over the baton to Slobodan Milosevic, the relay baton,

12 sort of, hand over the office. And people made jokes about that in Knin,

13 saying that he would hand over his police baton to Milosevic.

14 MS. UERTZ-RETZLAFF: Private session, please.

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17 [Open session]

18 THE REGISTRAR: We're in open session.

19 MS. UERTZ-RETZLAFF: With the help of the usher, I would like to

20 put to the witness the Exhibit tab 64 in Exhibit 352.

21 Q. Witness, it's an appointment of Milan Martic to the position of

22 deputy commander of the TO of the SAO Krajina. Why was he appointed into

23 this position, and what competence did go along with this position?

24 A. He was appointed because he was the Minister of the Interior, and

25 in that way the police in Krajina were incorporated into the new system

Page 13180

1 and placed under the authority of the government of Krajina.

2 Q. Witness, yesterday we spoke about a report. It was an exhibit,

3 tab 67, a report on the military activities in the region in August 1991.

4 This report that also went to Frenki. And in this report, there was

5 mentioned a ceasefire, an order that Mile Martic gave regarding a

6 ceasefire. Was a ceasefire actually agreed upon on the 6th of August,

7 1991?

8 A. Yes, it was.

9 Q. Despite the ceasefire, was Kijevo attacked in August 1991?

10 A. On the 26th of August, it was attacked, yes. And before that,

11 Milan Martic laid down an ultimatum to the police and inhabitants of

12 Kijevo, telling them to leave Kijevo, on the 18th of August, I believe.

13 MS. UERTZ-RETZLAFF: With the help of the usher, I would like to

14 put to the witness tab 68 from Exhibit 352.

15 Q. Is that the ceasefire -- the ultimatum that you just mentioned?

16 A. It is.

17 MS. UERTZ-RETZLAFF: Private session.

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Page 13182

1 THE REGISTRAR: We're in open session.

2 MS. UERTZ-RETZLAFF:

3 Q. While you were away from Knin in this conversation that you just

4 had, was it on that exact day Kijevo attacked?

5 A. That's right. It was attacked on that day, in the morning.

6 Q. Which forces were involved in this attack?

7 A. The JNA corps from Knin, units of the Krajina police, and the

8 local TO.

9 Q. How do you know that? Did you see anything to this effect?

10 A. The next day, I passed through the area and I saw the commander of

11 the Knin brigade, Colonel Djukic, and officers from his group. And he

12 said that the chief of staff of the corps, Ratko Mladic, was in front of

13 him, going towards Otisic. I saw a tank column of which Djukic was in

14 command, and this was in front of Vrljika. I saw a unit of TO of Cetine

15 on the edges of the village of Cetine, towards Vrljika. And they told me

16 that the police had been there too, Martic and Milenko Zelenbaba. And

17 this was shown on Belgrade television as well.

18 Q. Did you see that on Belgrade television, Martic in Kijevo?

19 A. Yes. Belgrade television showed two scenes from Kijevo. One was

20 Martic and Zelenbaba removing the Croatian flag from the police station

21 and embracing each other, and the other was Vesna Jugovic, a reporter of

22 Belgrade television, interviewing a soldier of the JNA on the road through

23 the village of Kijevo. That is, a talk between him and an old man from

24 Kijevo, an old Croat who had stayed behind. And this soldier asked him

25 the following: "Did you kill my grandfather in 1941?" And the man says,

Page 13183

1 "I did not."

2 Q. [Microphone not activated] Let me stop you there. Witness, you

3 said that you came through this region a day later. What did Kijevo look

4 like? Did you see any Croats? Was it intact?

5 A. The place was deserted. The inhabitants could not be seen. It

6 had been destroyed by artillery fire.

7 Q. On that day, did you see Mr. Mladic actually in the field? On

8 this day or the next days?

9 A. In the next day or two, after I was again passing along that road,

10 that is, through Vrljika.

11 Q. What was he doing when you saw him?

12 A. He was returning from Otisic. He was accompanying a group of

13 representatives of the Croatian authorities from Sinj and Split. He was

14 accompanying them to Vrljika, which was under his administration.

15 Q. Mr. Mladic, did he actually participate in fighting activities on

16 the ground? Do you know that?

17 A. Yes. Yes. He participated and he was in command. The reporters

18 even said that he was in the front lines and that he de-mined obstacles

19 and he appeared on all parts of the front suddenly, on his own, with

20 groups. And I remember that when the new Corps Commander arrived, General

21 Vukovic, and Mladic asked him to report to him where the corps units were

22 deployed. Then Mladic showed on the map that there were small groups of

23 units of the corps on various parts of the front in the area of northern

24 Dalmatia. And then the general said, "Where is the corps?" But that is

25 the way Mladic commanded the corps.

Page 13184

1 Q. You said that Mladic commanded the corps. Was he the Corps

2 Commander or what was his position?

3 A. Mladic, from the summer and through the autumn of 1991, he was

4 Chief of Staff of the corps. For a time, that is, in September, when

5 Spiro Nikolic, the previous general, was moved to another position before

6 Vukovic arrived, he was the most senior officer. In 1992, he was for a

7 time the Corps Commander, that is, Mladic.

8 MS. UERTZ-RETZLAFF: I would like to go into private session again

9 for the next meeting with Mr. Milosevic.

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8 [Open session]

9 THE REGISTRAR: We're in open session.

10 MS. UERTZ-RETZLAFF:

11 Q. Did the -- did Colonel Maksic actually arrive, and his ten

12 officers?

13 A. Some ten days went by and they didn't arrive, and I called

14 President Milosevic's secretary on the phone and I asked for the

15 president, and she said he wasn't there but she would connect me to him.

16 And I asked him, "What about the officers?" And he said, "They're coming

17 tomorrow." They didn't come tomorrow, but they came five or six or seven

18 days later. But not ten officers; Maksic and another two.

19 Q. Did they arrive, and what position did they take?

20 A. Colonel Dusan Kasum came as the chief of staff of the TO SAO

21 Krajina; Colonel Vuletic, as the chief of communications; and Colonel

22 Maksic, as the operative chief. They came to Martic's at the Knin

23 fortress, and they called me to come there and I arrived and I saw only

24 three of them, and they just shrugged their shoulders. And I asked, "Is

25 Martic the commander?" And he said, "Call General Simovic." He was the

Page 13187

1 Minister of Defence of Serbia. And I called him and I asked, "Is Maksic

2 the commander of the TO staff of SAO Krajina?" And he said, "We have

3 designated General Djujic." And he gave an explanation for Martic, an

4 excuse why he couldn't hold that position.

5 Q. And what was the reason why General Djujic was supposed to take

6 the position?

7 A. Simovic said that Maksic was an alcoholic.

8 Q. Did --

9 MS. UERTZ-RETZLAFF: With the help of the usher I would like just

10 to put to you the decisions made in this regard. It's tab 69, appointment

11 of General Djujic, Maksic, Kasum and Vuletic; tab 70, appointment Colonel

12 Djujic; tab 71, appointment Maksic; tab 72, order to relieve Djujic; tab

13 46 -- sorry, 49.6 is a decision to appoint Colonel Tabok; and tab 51.1 and

14 50.2, decisions to relieve Dusan Starevic from -- and Velibor Matijasevic

15 from their positions.

16 Q. Are these decisions taken in relation to the TO command and the --

17 A. Yes.

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21 A. These were formal, legal decisions confirming decisions taken by

22 the competent authorities in Belgrade, in this case, the General Staff and

23 the Secretary of National Defence. These two documents about Matijasevic

24 and Starevic, they are not directly linked to the Main Staff of the TO but

25 rather linked to the obstruction of the Assembly, which was done by a

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Page 13189

1 parallel structure with a view to influencing negotiations in The Hague.

2 Q. Witness, those TO commanders that were then appointed, were they

3 controlled by the politicians in the Krajina? Did they report to the

4 politicians in the Krajina or not?

5 A. No, they did not. They themselves didn't establish control over

6 the unified TO of SAO Krajina, but it remained subordinated to the

7 competent units of the JNA, according to various regions, and they

8 themselves were subordinated to the JNA command.

9 Q. I have to put to you just another document in this context, and

10 it's tab 73 of the Exhibit 352. This is an order -- a certificate,

11 actually, by the SFRY Presidency signed by Vice-President Branko Kostic

12 and Colonel Milo Kostic, in relation to promotion of Colonel Kasum to the

13 Chief of Staff of the TO Defence in April 1992; correct?

14 A. He's promoted to the rank of general, but he was previously

15 appointed to the Chief of Staff of the TO of the Republic of Serbian

16 Krajina.

17 Q. Does that mean afterwards - we are talking now about April 1992 -

18 this relationship between the TO --

19 A. Yes, that's right.

20 Q. This relationship of the TO staff, the officers there, and the

21 JNA, or VJ, as it later was called, remained the same?

22 A. It remained the same until August 1995. Virtually, it was

23 Slobodan Milosevic who appointed the commanders of the Serbian army of the

24 Republic of Serbian Krajina.

25 Q. Witness, in relation to the TO in the Krajina, did you have

Page 13190

1 opportunity to review, during your conversations here in The Hague, a lot

2 of documents that related to appointments, related to organisation of

3 units? Did you review these documents?

4 A. I did.

5 Q. Could you authenticate all these documents? Could you -- did you

6 know them?

7 A. Yes, that's right.

8 MS. UERTZ-RETZLAFF: Your Honours, I do not want to put all these

9 documents to the witness. I just want to read to you, and for the record,

10 which documents the witness reviewed and confirmed as being made by the

11 authorities there. And it's actually all from the Exhibit 352, and it is

12 tabs 114, 115, 117 to 119, 121 to 141, 145, 148, 150, 151. These are the

13 documents that I would like to refer to in this regard. It's all

14 appointments and all formations.

15 Q. These decisions taken, were they respected by the JNA and the

16 Martic police?

17 A. Some decisions, yes; some, no. The decisions relating to

18 active-duty officers in their role were respected. A part of the

19 decisions that were passed in July, August, and September of 1991 were not

20 respected.

21 MS. UERTZ-RETZLAFF: Private session, please.

22 JUDGE KWON: For the record, 151 was dropped; yes?

23 MS. UERTZ-RETZLAFF: Oh, yes. Yes, Your Honour. I just got the

24 note from my colleague here. Thank you.

25 [Private session]

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6 [Open session]

7 THE REGISTRAR: We're in open session.

8 MS. UERTZ-RETZLAFF: With the help of the usher, I would like to

9 put to the witness the document tab 74 of Exhibit 352.

10 Q. Witness, what kind of a document is this and who prepared it?

11 A. This document was compiled in the Main Staff of the TO of SAO

12 Krajina, and it was a report, in fact, on the situation in the SAO TO of

13 the Krajina in 1991, October.

14 Q. Did you --

15 A. 10th of October.

16 Q. For whom was this prepared and to whom was this given?

17 A. Well, it was prepared for the Prime Minister, first and foremost,

18 and then it was drafted for the General Staff of the JNA, to be handed on

19 to them.

20 Q. Was it handed to General Adzic?

21 A. I don't know that exactly, but he did receive information about

22 these issues, as we had discussed them previously.

23 Q. Those matters raised here, the needs of the TO, were these the

24 matters that were discussed with General Adzic on the occasion that you

25 described?

Page 13193

1 A. Yes, they were, briefly.

2 Q. Witness, I would like now to move on to discussions held about the

3 Carrington plan and the future Yugoslavia. What were the proposals for

4 the Krajina? What were the proposals for the Krajina?

5 A. In Lord Carrington's general plan, proposals were made for three

6 types of relationships amongst the republics of the former Yugoslavia.

7 For areas inhabited in individual republics with ethnic communities having

8 certain characteristics, it was provided that they should be granted a

9 special territorial status, and this referred to Krajina as well.

10 Q. What was -- was there stated a certain autonomy within the

11 Croatian context?

12 A. Yes, that's right. Territorial autonomy within Croatia.

13 MS. UERTZ-RETZLAFF: Private session, please.

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

10 --- On resuming at 10.55 a.m.

11 JUDGE MAY: Let's go into open session for one matter.

12 [Open session]

13 THE REGISTRAR: We're in open session, Your Honours.

14 JUDGE MAY: Ms. Uertz-Retzlaff, we've considered the application

15 which you and Mr. Nice make. We will grant it. You will have the six

16 days. But we will expect the list of 14 witnesses within seven days.

17 MS. UERTZ-RETZLAFF: Yes, Your Honour. We actually have

18 identified the 14 witnesses, and we can provide it, actually, in one day.

19 Tomorrow you will have your list.

20 JUDGE MAY: Very well. Thank you very much.

21 Yes. Do we need to go back into private session?

22 MS. UERTZ-RETZLAFF: No, Your Honour. We can stay in open

23 session, and I would like to clarify a few points in relation to the Vance

24 plan, to make it perfectly clear what the provisions were, the suggestions

25 were.

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Page 13209

1 Q. First of all, Witness, did the Vance plan foresee the

2 re-integration of the three SAOs into the Republic of Croatia within

3 certain time periods?

4 A. The plan didn't address that directly, except in the introduction,

5 which referred to areas that were in Croatia. That is all that it said.

6 The plan did not address the political solution. It explicitly said that

7 a political solution would be found later. "Until a political solution is

8 found." So the plan refers to a period until a political solution is

9 found, except in the first paragraph, which said what I said.

10 Q. And the provision was demilitarisation of the -- all three SAOs,

11 with only a police force remaining, with the weapons that a police force

12 usually have. Was that what you referred to?

13 A. That's right. That was the substance of the plan; the

14 demilitarisation of those regions.

15 Q. Did the plan foresee the arrival of UN troops, and where would the

16 UN troops be?

17 A. Yes. The plan did envisage, after the demilitarisation, the

18 deployment of peace forces of the United Nations across the territory

19 within the territory of those regions, and those forces would control

20 roads, checkpoints, the entries and exits from the regions. They would

21 check that no weapons were being introduced or carried within those areas.

22 Q. And --

23 JUDGE KWON: Ms. Uertz-Retzlaff, do we have the document among our

24 binders, the Carrington plans and Vance plans? If you assist us later on.

25 Thank you.

Page 13210

1 MS. UERTZ-RETZLAFF: Yes. I'm not aware of this. I think we

2 don't.

3 JUDGE MAY: Perhaps we can get a copy. If we can, it would be

4 helpful.

5 MS. UERTZ-RETZLAFF: Yes.

6 Q. And if I understood you, your concerns, some of the

7 Serb-controlled areas were not included in this zone that UN troops would

8 supervise.

9 A. That's right.

10 Q. And was there a provision also in the Vance plan regarding the

11 return of displaced persons into this territory?

12 A. Yes. That was one of the objectives of the international mission.

13 Q. Was there also a provision in the Vance plan regarding joint

14 police forces of Croats and Serbs within that territory?

15 A. Yes. As I said, it would be in proportion to the ethnic

16 composition of the population prior to the conflict.

17 Q. Witness, at that time when the Vance plan was discussed, and you

18 said it took almost two months to discuss this, the pros and the cons, did

19 the -- was the RSK, the Republic of Serbian Krajina, established?

20 A. Yes, on the 19th of December, 1991.

21 MS. UERTZ-RETZLAFF: With the help of the usher, I would like to

22 put to the witness tab 68 of Exhibit 351, just to have a look at it, sir,

23 not to discuss the details.

24 Q. Is this the constitution and constitutional law on implementation

25 of the RSK of 19 December 1991?

Page 13211

1 A. Yes, that's right.

2 Q. Why was the RSK formed at that time? What was the purpose?

3 A. The international conference in The Hague had stated that it would

4 recognise all the republics of the former Yugoslavia that requested

5 recognition. That virtually meant that the former Yugoslavia had

6 disintegrated, as was stated by the Badinter Commission named by the

7 conference. That was one of the reasons why a part of the territory of

8 the former Yugoslavia, that is, the SAO Krajina, proclaimed itself a

9 republic.

10 Q. Did the Republic of Serbian Krajina actually request international

11 recognition?

12 MS. UERTZ-RETZLAFF: And in this context I would like to put to

13 the witness tab 71.1 and 71.2 of the binder --

14 A. Yes, it did.

15 MS. UERTZ-RETZLAFF: -- Exhibit 351.

16 Q. Are these the two letters to the international officials?

17 A. Yes, that's right.

18 Q. And were you recognised?

19 A. No.

20 Q. The territory of the RSK, was that identical with the SAO Krajina

21 territory, or did that include all three SAOs at that time, on the 19th of

22 December?

23 A. On the 19th of December, the SAO Krajina became the Republic of

24 Serbian Krajina. On that day, the Assembly of Eastern Slavonia, Baranja,

25 and Western Srem proclaimed unification with the Republic of Serbian

Page 13212

1 Krajina, and two days later, the Assembly of SAO Western Slavonia also

2 proclaimed its unification with Krajina. But until the 26th of February,

3 1992, they were not united. All three regions on that date united, and

4 that was when the unified Republic of Serbian Krajina was constituted,

5 covering all three regions.

6 Q. We have talked about the Vance plan and what the provisions were,

7 and in relation to demilitarisation of this region, did you in the Krajina

8 oppose that? I do not mean you personally, but the politicians in the

9 Krajina. Did you oppose the demilitarisation?

10 A. That's right.

11 Q. Why did you do that?

12 A. Because the Vance plan covered a period of six months, upon which

13 there would be a discussion as to whether it should be extended or not,

14 and under those conditions, Krajina would be demilitarised, Croatia would

15 not, and Krajina would have to face the Republic of Croatia imposing a

16 political solution to Krajina by force of arms.

17 Q. Did you have any -- did you object also against the arrival of the

18 UN troops?

19 A. To the concept of their arrival. We didn't oppose their coming

20 but the way in which they were to come. The deployment was envisaged

21 according to the so-called green line, based on the Cypriot model.

22 Q. What does that mean?

23 A. It meant separation of the warring parties, that is, the Croatian

24 and the Serbian side, and not demilitarisation of the area as a whole.

25 And that is the amendment to the Vance plan that was requested. It was

Page 13213

1 accepted in principle, but this modification was requested regarding

2 certain elements of the plan.

3 Q. Was there an option? Was that an option, to get a modification of

4 the Vance plan, or was that out of question?

5 A. As far as I know, there was an option, and some provisions were

6 modified. Regarding the initial deployment for a period of six months,

7 and then it was extended to one year by the Security Council, the

8 Secretary-General of the UN, in his report to the Security Council, made

9 such a proposal, and that was accepted, and that is that Croatian laws

10 should not apply to those territories but the laws in force at the time.

11 There was also a discussion that the Territorial Defence should remain,

12 that the possibility should be given that it should be incorporated into

13 the police without long weapons, long barrels, but this was not resolved.

14 There was just the discussion about it. So some elements were modified.

15 Q. You mentioned that for about two months the Krajina Serbs opposed

16 the Vance plan, and did all of them oppose the Vance plan, or was there a

17 split within the Krajina politicians?

18 A. At first they were all opposed, and gradually, more and more

19 politicians accepted the plan fully and unconditionally in the way that

20 President Milosevic had accepted it. And finally, the president of the

21 Republic and the government and part of the Assembly continued to oppose

22 it, requesting modifications of the plan, and a part of the Assembly and

23 the politicians in Eastern Slavonia and Western Srem and part of the

24 Assembly of SAO Krajina and some politicians accepted the plan. And the

25 Assembly, which met in Glina on the 9th of February, 1992, approved the

Page 13214

1 plan after the pressure that came from President Milosevic, the Presidency

2 of Yugoslavia, the General Staff of the army of Yugoslavia, the media

3 campaign, and the like.

4 MS. UERTZ-RETZLAFF: I would like to request private session to go

5 into some details on the meetings in relation to the Vance plan.

6 [Private session]

7 [redacted]

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13 [Open session]

14 THE REGISTRAR: We're in open session.

15 MS. UERTZ-RETZLAFF:

16 Q. While Mr. Paspalj authorised -- accepted the Vance plan in the

17 Krajina, the politicians in the Krajina who opposed it, did they continue

18 to oppose it and even call for a referendum on the matter within the

19 Krajina?

20 A. Yes, that's right. Part of the Assembly and the politicians who

21 were opposed called a referendum for the people to state their views about

22 the plan. And the two questions of the referendum were: Were they in

23 favour of the plan completely and unconditionally as the plan had been

24 accepted by Kadijevic, Milosevic and Jovic -- no, I beg your pardon,

25 Tudjman was the third one -- or whether they were in favour of a modified

Page 13224

1 plan, following the lines of the Krajina government draft.

2 Q. Witness, you have already mentioned the Assembly session in Glina

3 on the 9th. And this Assembly session, was it an official Assembly

4 session called by the president of the Assembly? Did all Assembly members

5 take part in it?

6 A. No, not all of them did. My information told me that it was a

7 minority, in fact, which participated. But the delegation from Belgrade

8 did take part.

9 Q. You mentioned the delegation from Belgrade did take part. Who

10 took part from Belgrade in this meeting?

11 A. The members of the Presidency of the SFRY, Branko Kostic and

12 Yugoslav Kostic; the head of the General Staff, Adzic; and several other

13 generals and their escorts and the people who accompanied them; the

14 ministers and people from Serbia. Actually, it was a very numerous

15 delegation.

16 MS. UERTZ-RETZLAFF: Your Honours, we have prepared tab 88 of the

17 Exhibit 352, and it is a video. A part, a small speech given on this

18 Glina session by the president of the Presidency, Kostic, or rather,

19 vice-president, and the translation of what is said you actually have

20 under this tab. It will only be -- you have actually the speech, the

21 entire speech, but we will only play the section page 35, the last

22 paragraph, to page 36, the middle of the page.

23 And when you are ready in the technical booth, we could do that

24 now. Thank you.

25 [Videotape played]

Page 13225

1 MS. UERTZ-RETZLAFF:

2 Q. Is this the Belgrade delegation arriving, sir?

3 A. Yes, it is; Branko Kostic, Adzic, and his escorts.

4 THE INTERPRETER: Interpreters apologise but they do not have the

5 text of this tape.

6 THE INTERPRETER: [Voiceover] Mr. Kostic, good day to you. Welcome

7 to Glina. You have come here to attend the Krajina Assembly. What do you

8 expect of the meeting?

9 Well, we have come and there are quite a lot of us here, and after

10 a rather extensive discussion held in the Yugoslav state Presidency to

11 take part in the work of the Assembly of Srpska Krajina and on the one

12 hand to reject all the accusations, refute all the accusations that have

13 been unfoundedly spread among these people, that we are leaving those

14 people in the lunch. Also to tell the Assemblymen of the Serbian Krajina

15 Assembly, as well as to all the people, that that is a crude lie, flagrant

16 lies, that we have been and are remaining by the side of these people. In

17 addition, to help inasmuch as we can, for reason to prevail, and that

18 these people, as well as the Assemblymen, realise that that which has been

19 gained through war until now can be defended by peace in the best possible

20 way from now on, with the assurances of the Security Council, a world

21 organisation, and the engagement of the Blue Helmets.

22 Thank you very much on behalf of the Novi Sad television.

23 Thank you too.

24 Mr. Kostic, what is your message to the people of Glina and

25 Krajina?

Page 13226

1 That we have stood by and are going to stand by these people.

2 However, choosing between the peace option and the war option, the time

3 has come to defend peace, what these people have gained by war, not by

4 continuation of a long and precarious war that might be spread out to the

5 hinterland and Bosnia and sweep over the entire Yugoslavia or even wider

6 in the Balkans. That can obviously finally result in the loss of

7 everything that these people have gained by war so far.

8 Thank you.

9 MS. UERTZ-RETZLAFF: We can stop here. We can stop here. Thank

10 you.

11 Your Honours, as you can see from the transcript, there is

12 following a speaker of the RSK Assembly on the conference giving a small

13 speech, listing all the people that are present there from Belgrade.

14 That's actually following in that next chapter on page 36, and I don't

15 think we need to play it on the video. You can read it and Mr. Milosevic

16 can read it also, and the amici.

17 Q. You already mentioned another Assembly session in Glina. Was

18 there an Assembly session in Glina on the 16th of February, 1992, and was

19 the then Prime Minister dismissed?

20 A. That's right. The Prime Minister of Srpska Krajina was dismissed.

21 THE INTERPRETER: The president of the Republic of Srpska Krajina.

22 Interpreter's correction.

23 MS. UERTZ-RETZLAFF:

24 Q. And in the subsequent meeting on the 26th of February, 1992, was

25 Goran Hadzic elected the next president of the RSK?

Page 13227

1 A. That's right, yes.

2 Q. Did any officials from Belgrade attend this session? Do you know?

3 A. I heard that will Budimir Kosutic was there. I don't know about

4 anybody else. They said that some people were there, but as I wasn't

5 there myself, I can't say.

6 MS. UERTZ-RETZLAFF: With the help of the usher, I would like to

7 put to the witness tab 74 of the binder Exhibit 351, and it is actually

8 the decision of the RSK Assembly, dated the 26th of February, 1992, in

9 which the SAO Eastern Slavonia, Baranja, and Western Srem and the SAO

10 Western Slavonia join the RSK officially.

11 Q. Is that correct?

12 A. Yes, that's correct.

13 Q. We do not need to go into details of this decision.

14 A. Rather, note is taken that they have united into the territory of

15 Serbian Krajina.

16 Q. Thank you. Goran Hadzic, what was his position before the war?

17 A. Goran Hadzic, from the summer of 1990, was the president of the

18 municipal board of the SDS in Vukovar. Later on, he was elected as

19 president of the Serbian National Council of Eastern Slavonia, Baranja,

20 and Western Srem. And then, subsequently, at the beginning of the autumn

21 or at the end of summer of 1991, he was elected Prime Minister of the

22 government of Eastern Slavonia, Baranja, and Western Srem.

23 Q. What was his profession before the war?

24 A. I didn't hear that from him personally, but everybody said that he

25 was a warehouse clerk, or rather, an official, a clerk, a worker, in some

Page 13228

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Page 13229

1 warehouse, something to that effect.

2 Q. Did you have opportunity to see him during meetings?

3 A. Yes, quite a few times.

4 Q. Did he have the political skills and intellectual level to fulfil

5 the position of the President of the RSK? You observed him. Can you

6 comment on this?

7 A. It's a little difficult for me to speak about somebody's

8 qualifications for a particular job, the job that he did anyway, but what

9 I can say is that he wasn't particularly eloquent, and his political

10 appearances did not correspond to the model we have, the image we have, of

11 a politician. But people from Eastern Slavonia told me that he had been

12 elected to these posts because he was brave and courageous in standing up

13 to the Croatian police in Vukovar and that he first jumped up onto a

14 tractor and thus became a well-known personality.

15 Q. Was he actually the dominant political authority in the RSK, or

16 someone else?

17 A. Well, in the RSK, no. The authority, the power -- he had power

18 and authority. Milan Martic and his structures had power and authority,

19 parallel structures, in fact, and they were the powers that be in that

20 part of Krajina. Goran Hadzic, for the most part, spent his time living

21 in Novi Sad. I don't know how far he was influential in Eastern Slavonia.

22 He would come to Knin from time to time.

23 Q. And when you speak about the parallel structure around Milan

24 Martic, is that the same parallel structure with Frenki that you mentioned

25 before, during the year 1991?

Page 13230

1 A. That's right, except at that time it was the official, formal

2 authorities in power in the RSK.

3 Q. Do you know -- you have already mentioned the person Stojicic

4 Badza. What was his relationship or position in the SAO Eastern Slavonia,

5 Baranja, and Western Srem?

6 A. He was the commander of Territorial Defence in the area.

7 Q. Did he have an influence on Mr. Hadzic? Do you know?

8 A. As far as I know, Hadzic made frequent mention of him, Badza, and

9 a certain man named Jajo, as the main people that he cooperated with.

10 Q. What was Mr. Hadzic's relationship with Mr. Milosevic? Can you --

11 did you make any observations to this effect?

12 A. Complete obeyance. Hadzic completely obeyed Milosevic. He was in

13 -- he completely obeyed Milosevic.

14 Q. What was Mr. Hadzic's relationship, if any, to Mr. Stanisic?

15 A. Very close. I know that Stanisic would accompany him sometimes to

16 the Presidency of Serbia, and people even said that he stayed in

17 Stanisic's apartment, that he slept there when he came to Belgrade and

18 that he was under Stanisic's complete control. At one time he was even

19 said to wear a camouflage uniform in Belgrade when he went to meetings

20 with Milosevic.

21 MS. UERTZ-RETZLAFF: With the help of the usher, I would like to

22 put to the witness the exhibit -- tab number 84 of Exhibit 352. It's a

23 photo. Can we put it on the ELMO, please.

24 Q. And looking at it, can you say where these photos were made and

25 can you point out to us Mr. Hadzic, if he is on these photos, of course.

Page 13231

1 A. This photograph was taken on the 31st of January, 1992. It is the

2 expanded meeting of the Presidency of the SFRY.

3 Q. And is Mr. Hadzic on any of these photos; and if so, can you point

4 him out to us?

5 A. These are members of his government.

6 Q. Can you move it?

7 A. Members of his government here. You can't see him on the

8 photograph. But he looked like this man here, although this is Rado

9 Leskovac, I believe, but they looked similar.

10 Q. Thank you very much, then. He's not on the photos. Thank you.

11 A. No, he isn't; at least, I can't see him.

12 Q. Witness, we can --

13 MS. UERTZ-RETZLAFF: Usher, we can put that away. Thank you.

14 Q. Witness, you have told us the provisions of the Vance plan, and I

15 would like to know from you now whether this Vance plan was actually -- if

16 it was actually executed within the Krajina or the RSK. Was it

17 implemented?

18 A. No, it was not.

19 Q. Were the territories demilitarised?

20 A. No, they were not.

21 Q. Why not?

22 A. Because the weapons and military equipment and materiel was not

23 taken away from the area completely, and most of the equipment was hidden,

24 and through the Krajina police force, which was in possession of those

25 weapons still, the military units and formations remained armed in the

Page 13232

1 area. And also, later on, from the beginning of 1993, in fact, the heavy

2 weapons were taken from the warehouses which were held by the peace

3 forces, and from the beginning of 1993 onwards, the armed formation

4 existed under the name of the Serb army of the RSK, although it existed

5 from May 1992 in actual fact, this Serbian army with part of the weaponry.

6 Q. Were multi-ethnic police forces, police units, established? That

7 is, Croats and Serbs?

8 A. No.

9 Q. Was the return of Croats to their villages implemented?

10 A. No, it was not.

11 Q. Why not?

12 A. They were not allowed to return, by the authorities in Krajina.

13 Q. When you say "the authorities in Krajina," whom do you mean? In

14 which way were they prevented to return?

15 A. The police prevented them, Martic did, and the political position

16 taken was that they shouldn't return. This position was taken up by the

17 government.

18 Q. Was Mr. Milosevic in any way involved in these reactions to the

19 Vance plan?

20 A. Could you explain what you mean, please, and repeat the question?

21 Q. You mentioned that the Krajina authorities did not implement the

22 Vance plan, and I was asking you whether Mr. Milosevic did in any way get

23 involved in this action or influence the authorities in Krajina not to do

24 that.

25 A. Yes, Milosevic did perform militarisation, or rather, he held the

Page 13233

1 position that demilitarisation shouldn't be put into effect. Then he

2 supported militarisation, or rather, the creation of military formations

3 and the creation of an army, another army in Krajina, the Serbian army of

4 the RSK. He appointed commanders, financed them, gave logistics support,

5 right up until 1995, August 1995, in fact.

6 Q. You mentioned that the JNA left the RSK. When did they start

7 leaving the RSK, and when was the withdrawal completed?

8 A. The withdrawal from Croatia across Krajina began in the month of

9 October 1991. Garrisons, Zagreb, Zadar, Sibenik, Sinj, and other parts

10 through the maritime coastal route, which I didn't see, but I heard about

11 them, and the withdrawal from Krajina itself, or that portion of Krajina,

12 was completed in May 1992.

13 MS. UERTZ-RETZLAFF: With the help of the usher, I would like to

14 put to the witness now two exhibits: Tab 75 and tab 76 of Exhibit 351.

15 Q. Tab 75 is a decision of the RSK Assembly dated the 18th May 1992,

16 amending the RSK constitution and law on defence to establish a Serbian

17 army of the RSK; and the other one is from 1993, a decision of the RSK

18 Assembly, dated the 20th of April, 1993, amending the RSK constitution to

19 change the structure of the Serbian army of the RSK and its command.

20 Is this the army that you referred to just a minute ago?

21 A. Yes, that's it.

22 Q. Yes. Thank you. I only want to refer to the document from 1992,

23 and there is the Article 1, where it says: "The Republic of Serbian

24 Krajina shall have a Serbian army in peacetime. The Serbian army shall

25 comprise TO units in the event of the imminent threat of war, and during

Page 13234

1 wartime, special purpose police units shall join the Serbian army."

2 Which special police forces are referred to in this article? What

3 does that mean?

4 A. They were the special police forces that existed since -- were in

5 existence since 1991, and we've already discussed that issue here, talked

6 about them. The ones that began to be established in April 1991.

7 Q. Yes. Witness, this Serbian army of the Krajina, did they take

8 over the property of the JNA and the weapons that were left behind?

9 A. Yes, that's right. Part of the weapons were hidden when the JNA

10 withdrew, and in 1993 it was taken from the warehouses which were guarded

11 by the UN peace keepers.

12 Q. Was it an independent army? We have already spoken about

13 financial dependence. Was it an independent army?

14 A. No. It was part of the military structures of Yugoslavia.

15 Q. What was the basis of -- in which way were they dependent, a

16 dependent part of the structure of Yugoslavia?

17 A. Well, most of the commanding cadre, commanding staff, were active

18 officers of the JNA who were on the JNA payroll. They were paid by the

19 General Staff of the Yugoslav army and appointed to those positions by the

20 personnel department of the General Staff of the Yugoslav People's Army.

21 The commanders of the army were appointed by the president of Serbia and

22 later the president of Yugoslavia - president of Serbia up until 1995,

23 Slobodan Milosevic - and it was financed, logistics support was given from

24 Yugoslavia. As far as personnel were concerned, Krajina supplied the men

25 for the army and the regulations and provisions for it to be able to

Page 13235

1 function.

2 Q. Witness, I would like to move now a little bit further in relation

3 to meetings with Mr. Milosevic, and I would like to know if, in 1994, RSK

4 officials took part in negotiations with the Croatian authorities. Do you

5 know that?

6 A. Yes, they did.

7 Q. When they went to meetings with the Croatian authorities, did they

8 have contacts with Mr. Milosevic beforehand?

9 A. That's right, yes. His approval was sought, and the contents of

10 the conversations, the discussions themselves, were determined by him. He

11 would also follow the discussions as they proceeded and was informed of

12 the process.

13 Q. Did you have to ask approval before committing to any agreements?

14 A. That's right, yes. It was a form of consultation. But actually,

15 he determined whether something would be accepted or not, and what would

16 be accepted.

17 Q. What would happen if anyone would not -- would take an isolated

18 action without consulting Mr. Milosevic first? Do you know?

19 A. Well, it couldn't have been done, because those people would have

20 been sanctioned and borne the consequences. There were even instances of

21 physical jeopardy. People were put in prison who had independently made

22 agreements with Croatia. The Daruvar agreement is a case in point, where

23 people from Western Slavonia drew up an agreement with Croatia, and the

24 Dzakula example as well.

25 Q. Did the officials from the Krajina ever make an agreement with the

Page 13236

1 Croats without an approval, beforehand consultation?

2 A. I think that the Daruvar one could have been a case in point, but

3 I'm not quite sure. What I do know is that the plan Z-4 was accepted

4 through Ambassador Albright. Not directly, without Milosevic's approval

5 beforehand, or prior to asking approval from Milosevic.

6 Q. Which negotiations took place in 1994? What kind of negotiations

7 were held with the Croats? Were they related to a political solution or

8 were they just on economical issues?

9 A. From mid-1994 until the beginning of 1995, there were -- they were

10 agreements about economic relations with Croatia: The oil pipeline, supply

11 of electricity, the water supply, the opening of the highway, the railway

12 transport system.

13 Q. And did Mr. Milosevic allow you to agree to such economical

14 relations?

15 A. Yes. Yes. And he took a very active part in the drafting of the

16 agreement itself, even with regard to the name of a mixed oil company that

17 had been established.

18 Q. Witness, I would like to go now to a meeting on the 5th of

19 September, 1994.

20 MS. UERTZ-RETZLAFF: And I have to ask for private session for

21 this meeting.

22 [Private session]

23 [redacted]

24 [redacted]

25 [redacted]

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25 [Open session]

Page 13240

1 THE REGISTRAR: We're in open session.

2 MS. UERTZ-RETZLAFF:

3 Q. Witness, you mentioned the Z-4 plan. What were the main points of

4 the Z-4 plan?

5 A. The main point, or the gist of the plan, was that the territory of

6 the Republic of Serbian Krajina, which had earlier been known as the

7 Serbian Autonomous Region of Krajina and which was now known as Sector

8 North and Sector South under the protection of the United Nations, should

9 be given political, territorial autonomy within the Republic of Croatia.

10 It would have a parliament, a government, institutions, a currency that

11 would be special in appearance but it would be printed by the National

12 Bank of Croatia, competence over the regional police and the courts, which

13 would imply a high level of autonomy.

14 Q. Who made this suggestion of the Z-4 plan? Was it an international

15 proposal?

16 A. The Z-4 was given that name because it was proposed by four

17 ambassadors in Zagreb, that is, by the international community.

18 Q. In the transcript earlier on, it was said that -- it is actually

19 on page 61 of the transcript, line 14, it says that Ambassador Albright

20 accepted the Z-4 plan. Is that correct, Ambassador Albright?

21 A. Ambassador Galbraith, the ambassador of the United States in

22 Croatia, Peter Galbraith. He was the main creator and proponent of that

23 plan.

24 Q. This plan, did that actually mean the reintegration of the three

25 regions of the RSK, that is, Krajina, Western Slavonia, Eastern Slavonia,

Page 13241

1 into the Croatian Republic?

2 A. That's right. Only the Western Slavonia would be settled

3 immediately, whereas Eastern Slavonia, within a period of five years, and

4 the territory of SAO Krajina would have a high degree of political and

5 territorial autonomy in Croatia.

6 Q. Were the politicians of the Krajina in a position -- did they

7 accept this Z-4 plan, you in the RSK?

8 A. At the beginning of March/end of February, the politicians in

9 Krajina rejected the plan. The plan was accepted only by the last Prime

10 Minister of the Republic of Serbian Krajina in August 1995.

11 Q. And when you said March and February, which year? Is it also

12 1995?

13 A. That's right, 1995.

14 Q. Who opposed the Z-4 plan?

15 A. The President of the Republic of Serbia, according to what Milan

16 Martic said, the President of the Republic of Serbian Krajina, and he said

17 half an hour prior to the beginning of the meeting with the international

18 community that President Milosevic had said that the plan should not be

19 even considered.

20 Q. When did Mr. Milan Martic consult with Mr. Milosevic, and of what

21 time period are you speaking when you say -- when you refer to a meeting

22 with the international community?

23 A. It was that week. I think it was the end of February/beginning of

24 March. So the beginning of the week, Martic went to Belgrade for

25 consultations. Whether it was Monday or Tuesday. And then on Thursday,

Page 13242

1 an announcement was issued of the supreme defence council of the Republic

2 of Serbian Krajina, in negative terms, about the plan, and then I think it

3 was the following Monday when there was the meeting with representatives

4 of the international community at which Martic said half an hour prior to

5 the meeting that Milosevic had said that the plan should not even be taken

6 into consideration. And at the meeting with representatives of the

7 international community, Ambassador Farista Djijan [phoen] handed it to

8 him. He wouldn't even take it into his hands.

9 Q. On that occasion, then, did the Krajina authorities reject the

10 plan, in that meeting then with the internationals?

11 A. Actually, it was not even taken into consideration, so it was not

12 accepted.

13 MS. UERTZ-RETZLAFF: We would need to go into private session for

14 a meeting of the witness.

15 [Private session]

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Page 13243

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21 --- Recess taken at 12.16 p.m.

22 --- On resuming at 12.40 p.m.

23 [Open session]

24 THE REGISTRAR: We're in open session, Your Honours.

25 JUDGE MAY: Yes.

Page 13244

1 MS. UERTZ-RETZLAFF: Thank you, Your Honours. And Your Honours,

2 for your orientation, we are at the moment at paragraph 280 of the

3 proofing summary, but I will also address paragraph 312, because it fits

4 into the context and would speed up matters.

5 Q. Witness, Martic or RSK force participation in Bosnia, did Milan

6 Martic and RSK forces participate in the fighting in Bosnia and

7 Herzegovina already as early as summer 1992?

8 A. That's right, in the so-called corridor in Bosnia and Herzegovina.

9 Q. Is that the Posavina corridor?

10 A. Yes, that's right.

11 Q. What is the importance of the Posavina corridor for Bosnia and for

12 -- for the Serbs in Bosnia and Herzegovina and for the Serbs in the

13 Krajina region? What was the importance of this corridor?

14 A. It is the corridor linking Bosnian Krajina and the Republic of

15 Serbian Krajina with Serbia, or rather, the Federal Republic of

16 Yugoslavia.

17 Q. And in which time period did RSK forces, with Milan Martic,

18 participate in the fighting in 1992?

19 A. At the beginning of the summer of 1992. In June already they were

20 there, at the end of June.

21 Q. And who was in charge, in overall charge of the operations in the

22 Posavina corridor?

23 A. The army of Republika Srpska and General Mladic.

24 Q. You have mentioned the fighting in 1994, 1995, in the region of

25 Livno in Herzegovina, and my question was before the break: Did forces

Page 13245

1 from the RSK also participate in the fighting around Bihac?

2 A. They did.

3 Q. Who -- what were the forces on both sides? Who was fighting whom

4 in Bihac?

5 A. On one side, there was the 5th Corps of the army of Bosnia and

6 Herzegovina, which was defending its territory, and it was being attacked

7 by the forces of the army of Republika Srpska and the forces of the

8 Republic of Serbian Krajina, consisting of the Serbian army, the police,

9 and the state security service of Serbia.

10 Q. Who --

11 A. And - sorry - the forces of Fikret Abdic.

12 Q. The forces of the police forces of the state security service of

13 Serbia that participated, who led them? Who commanded them in this

14 fighting?

15 A. I was told it was Frenki, that he was in command, or rather, the

16 DB from Petrova Gora.

17 Q. And who told you that?

18 A. People from Kordun, from the region, members of the government of

19 Krajina.

20 Q. This participation of the RSK forces in Bosnia and Herzegovina,

21 did this cause problems for the position of the RSK towards the

22 international community and the Croatian authorities?

23 A. Yes. In 1994 in particular, and in 1995, this compromised the

24 position of the Republic of Serbian Krajina in relation to the

25 international community, because the area of Bihac was a protected area by

Page 13246

1 the international community.

2 Q. Did it increase the danger of an all-out attack on the RSK by the

3 Croatian forces?

4 A. Yes. That was the reason why the Croatian army and the HVO from

5 the territory of Bosnia and Herzegovina launched an offensive to deblock

6 Bihac. That was what was publicly announced by the authorities in Croatia

7 in Bosnia and Herzegovina, and it meant cutting off the Republic of

8 Serbian Krajina from Republika Srpska and Yugoslavia.

9 Q. Did the RSK authorities and the Republika Srpska authorities

10 actually have a military agreement on assisting each other in that time

11 period?

12 A. I know there was an agreement between Martic and Karadzic, that

13 is, between the authorities of Republika Srpska and the Republic of

14 Serbian Krajina, and that agreement referred to brigades of the army of

15 Republika Srpska that would assist the army of the RSK. As for other

16 parts of the agreement, I'm not sure about that.

17 MS. UERTZ-RETZLAFF: With the help of the usher, I would like to

18 show the witness the Exhibit tab 96 of Exhibit 352.

19 Q. Witness, this is a document of the 30th of July, 1995, referring

20 to a visit by Mr. Akashi, the special representative of the

21 Secretary-General of the United Nations, and other persons, in relation to

22 an agreement, a proposed agreement. The proposed agreement referred to,

23 is that the Z-4 plan?

24 A. No. This was -- this should have been a component part of the Z-4

25 plan, or rather, a precondition for the implementation of the Z-4 plan.

Page 13247

1 So this was an agreement on the disengagement of the army of the Republic

2 of Serbian Krajina in the Bihac pocket; or, to be more precise, this was

3 not an agreement, it's an announcement on agreement, announcement of

4 approving the proposals made by Mr. Akashi to the leadership of the

5 Republic of Serbian Krajina.

6 Q. And the proposal was that no troops or individual soldiers of the

7 RSK would get engaged in the Bihac pocket, and refrain from any

8 cross-border activities; is that what is proposed here?

9 A. That's right.

10 Q. The person -- there is a handwritten note on it saying the 20th of

11 September -- or sorry. No. Thank you. I withdraw my question.

12 This proposal to disengage in the RSK, was that actually

13 implemented?

14 A. No.

15 Q. What did happen? What was instead done?

16 A. Combat continued. [Realtime transcript read in error "Maksic"]

17 Mrksic nor Milan Novakovic, who was in command there, nor Martic nor the

18 police nor the MUP of Serbia were they withdrawn from the fighting in that

19 region.

20 Q. In the transcript, it says Maksic. Is that correct or -- in the

21 document as such it says General Mrksic.

22 A. That's right. Mile Mrksic, General Mile Mrksic, the commander of

23 the army of the Republic of Serbian Krajina.

24 Q. Yes. Thank you.

25 MS. UERTZ-RETZLAFF: We can take this away.

Page 13248

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Page 13249

1 Q. Witness, in 1994, did the Minister of Interior of the RSK have a

2 problem to get control over the police in the territory of Eastern

3 Slavonia, Baranja, and Western Srem?

4 A. Yes, that's right.

5 Q. Why did he --

6 A. The Minister of the Interior; is that what you said?

7 Q. Yes. Yes. Who was the Minister of Interior in 1994?

8 A. Until the end of 1994, it was Ilija Prijic, who was replaced in

9 that capacity, and the Assembly nominated, appointed, Mr. Perisic, but he

10 didn't take up his post either in Eastern Slavonia or in the rest of the

11 RSK either. So from the end of 1994 until August 1995, the RSK did not

12 have a Minister for the Interior. One of the deputies was the acting

13 minister.

14 Q. Did a delegation from the RSK then meet Mr. Milosevic to consult

15 him in this problem?

16 A. Yes, that's right. In 1995, April, around the 26th of April, in

17 fact.

18 MS. UERTZ-RETZLAFF: Your Honour, I have to apologise, but we need

19 to go into private session for this.

20 [Private session]

21 [redacted]

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Page 13250

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25 [Open session]

Page 13251

1 THE REGISTRAR: We're in open session.

2 MS. UERTZ-RETZLAFF: With the help of the usher, I would like to

3 put a document to the witness, and it is tab 97 of Exhibit 352.

4 Q. Witness, this is a document referring to Minister Peric and his

5 position, and it is also referring to people and their affiliation to

6 certain police forces. Who prepared this document?

7 JUDGE KWON: Are we now in open session?

8 MS. UERTZ-RETZLAFF: Yes.

9 A. I learnt about this document from Slobodan Peric. I got it from

10 him.

11 Q. In this document, actually, at the -- the last paragraph, it says:

12 "At all the meetings, Milosevic agrees that Peric should take over the

13 MUP, while Stanisic immediately after that agrees with Martic that it

14 should be prevented."

15 Was the situation as described in this paragraph?

16 A. Specifically, I know what I have described. That was the

17 situation. But yes, although I didn't hear that Milosevic had agreed, in

18 fact.

19 Q. Was there a problem in May 1995 in relation to the commander of

20 the armed forces of the RSK after the Operation Flash?

21 A. Yes, that's right.

22 JUDGE KWON: You have something to say, Mr. Milosevic?

23 THE ACCUSED: [Interpretation] I can't find this document, because

24 in tab 97, the one I have, I have an announcement for Tanjug by the

25 president of the Republic of Srpska Krajina, and not the document that

Page 13252

1 you're talking about. So I have taken this out very carefully from tab

2 97.

3 JUDGE MAY: Coming up.

4 Yes.

5 MS. UERTZ-RETZLAFF: Your Honours, I have no explanation for this

6 situation.

7 JUDGE MAY: He's got a copy now.

8 MS. UERTZ-RETZLAFF: Oh, okay. Good. Tab 97. I don't think I

9 need to repeat this now.

10 JUDGE MAY: No.

11 MS. UERTZ-RETZLAFF: No.

12 Q. Just one more question in relation to tab 97. Did you provide

13 this document when you had your conversations with the Prosecutor in The

14 Hague?

15 A. Yes.

16 Q. I think you have not yet answered my question whether there was a

17 problem arising in relation to the commander of the armed forces of the

18 RSK after Operation Flash. Who was the commander of the armed forces of

19 the RSK during the Operation Flash?

20 A. General Celeketic.

21 Q. Was he dismissed after the Croatian forces took Western Slavonia

22 in their Operation Flash?

23 A. That's right, yes, around the 9th of May, 1995.

24 Q. Did you, in the Supreme Defence Council in the Krajina - I don't

25 mean you personally, but the Supreme Defence Council of the RSK - agree

Page 13253

1 about a new candidate, Mile Novakovic?

2 A. I have to explain that the Prime Minister of the RSK, as member of

3 the supreme council, Defence Council, proposed General Mile Novakovic for

4 the new commander. However, Slobodan Milosevic refused, and he appointed

5 General Mile Mrksic for the new commander of the Serb army of the RSK.

6 Q. Witness, did the Supreme Defence Council of the RSK agree? Did

7 the authorities in the Krajina agree on Mr. Novakovic?

8 A. It agreed with the decision that it be General Mile Mrksic, and

9 this was formalised. It was officially stated.

10 MS. UERTZ-RETZLAFF: Your Honour, I have to ask for private

11 session, to clarify a matter.

12 [Private session]

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Page 13254

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21 [Open session]

22 THE REGISTRAR: We're in open session.

23 MS. UERTZ-RETZLAFF:

24 Q. Did the RSK government then approve the appointment -- or the

25 decision by an official appointment of General Mile Mrksic?

Page 13255

1 A. It followed the regular procedure via the Supreme Council of

2 Defence for the RSK and the Assembly of the RSK as well, and that's how it

3 was decided that Mrksic -- or rather, they adopted the proposal and

4 verified it legally, that Mile Mrksic should be the commander.

5 Q. When did Mile Mrksic arrive in the RSK as commander?

6 A. He was seen on the 16th of May, 1995. The Assembly appointed him

7 between the 18th and 20th of May, 1995.

8 Q. What position did he have before he came to the RSK? Do you know

9 that?

10 A. He was the commander of the Guards Brigade of the JNA in Belgrade,

11 and he was in command of it during the attack on Vukovar. And before

12 that, he was something in the General Staff, held some post, but I don't

13 know what exactly.

14 Q. When he arrived in the RSK, did he officially become an employee

15 of the RSK forces, or did he remain to be employed as a VJ officer?

16 A. He was an officer of the army of Yugoslavia.

17 Q. And the previous two commanders that you mentioned, Mile Novakovic

18 and Celeketic, were they also members of the VJ throughout their time in

19 the RSK?

20 A. Yes.

21 Q. During your conversation with the Prosecution in The Hague, did

22 you review several orders signed by Milan Martic related to the

23 appointment, promotions, and release of General Celeketic? Do you recall

24 that?

25 A. Yes.

Page 13256

1 MS. UERTZ-RETZLAFF: Your Honours, I don't think we need to put it

2 all to the witness. It's tabs 98, 99, 100, and 101 of Exhibit 352. They

3 all deal with General Celeketic, his promotion and his release.

4 Q. But I would like to put to you tab 102, and it's 102 of that same

5 exhibit, 352. And that is actually a document by Dusan Zoric, the

6 military post 1740 -- 90, Belgrade, from 21st December, 1994, regarding

7 the promotion of Colonel Milan Celeketic to the rank of Major General.

8 Can you tell us who this person Dusan Zoric is, what position did he have?

9 A. He was head of the personnel department of the General Staff of

10 the army of Yugoslavia, or was the acting head.

11 Q. Yes. Thank you.

12 MS. UERTZ-RETZLAFF: Your Honour, we have to go into private

13 session, and I'm dealing now with paragraph 293 and the following two in

14 the proofing summary.

15 [Private session]

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Page 13257

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Page 13264

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15 [Open session]

16 THE REGISTRAR: We're in open session.

17 MS. UERTZ-RETZLAFF:

18 Q. Did the refugees from the RSK actually end up in Kosovo or in

19 Bosnia and Herzegovina, or where did they go?

20 A. At first, that same day, as soon as the refugees started coming

21 from Krajina, Ratko Mladic, the commander of the army of Republika Srpska,

22 blocked the bridge across the Vrbas, and he wouldn't let refugees go any

23 further. [redacted].

24 MS. UERTZ-RETZLAFF: We should go into private session for this

25 meeting.

Page 13265

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25 THE REGISTRAR: We're in open session.

Page 13266

1 MS. UERTZ-RETZLAFF:

2 Q. Witness, you said that able-bodied males were separated from their

3 families. For what reason? What were they supposed to do?

4 A. They were integrated into the army of Republika Srpska, and those

5 who had crossed into Serbia, they were arrested and taken to Eastern

6 Slavonia, to a camp under Arkan or to the front line, the so-called front

7 lines.

8 Q. Does that mean they were forcefully recruited into the VRS and

9 into the army -- into Arkan's unit?

10 A. That's right.

11 Q. Where did those who reached Serbia, where did they settle?

12 A. They were accommodated in two ways: First, people who had

13 relatives, close relatives, the first generation, could stay with their

14 families. All the others were transported by the police to certain

15 centres all over Serbia, including Kosovo, in columns of tractors or cars

16 or in trains. I heard the stories of many people when they arrived by

17 train in Pristina and other towns in Kosovo. They were flabbergasted and

18 they took the first chance to flee from there.

19 Q. Witness, did refugees from the Krajina arrive in Vojvodina?

20 A. Yes.

21 Q. Were Croatian inhabitants then driven out of Vojvodina? Do you

22 know that?

23 A. There was some incursion into Croatian homes and throwing the

24 inhabitants out; however, the Serbian police intervened and prevented

25 people moving into Croatian homes.

Page 13267

1 Q. Witness, I would like to go now into an entirely different

2 chapter, and that refers to Milan Martic. Was he arrested at some point

3 in time in Bosnia?

4 A. Yes, in September 1991.

5 Q. Was there an arrest warrant against him?

6 A. Yes, issued by the Croatian government.

7 MS. UERTZ-RETZLAFF: With the help of the usher, I would like to

8 put to the witness tab 111A.

9 Q. Witness, is this the arrest warrant, or rather, the decree, in

10 relation to Milan Martic?

11 A. That is what it says here, but I know from the media that it

12 existed.

13 Q. Were you shown this document during your conversation with the

14 Prosecutor?

15 A. Yes.

16 MS. UERTZ-RETZLAFF: Your Honours, for your information, the

17 Prosecution office received this document from the government of the

18 Republic of Croatia in a submission in May 2002.

19 With the help of the usher, I would like to put now to the witness

20 tab 111B of that same exhibit, 352, and that's also a document that was

21 received from the Croatian government, attached to the arrest warrant.

22 Q. Witness, it is a decree in relation to an investigation conducted

23 into activities of Milan Martic and others. And did you have time to read

24 this document? Did you read it during your conversation with the

25 Prosecutor?

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Page 13269

1 A. I did.

2 Q. In this document, there is referred to the Council of Peoples

3 Resistance that you have already mentioned as being the source of

4 provocations, and there is listed a lot of events from October 1990

5 through to April 1991, referring to attacks on the police, the Croatian

6 police; the shooting on civilians, the destruction of shops, houses, and

7 vehicles with explosive devices; and the attacks on railroad tracks.

8 When you reviewed this document, did you find it to be correct?

9 Those facts given in the document, were they correct?

10 A. They are correct, yes.

11 Q. Those people, or those properties that were destroyed, or people

12 that were harmed, were they Croats or, as you mentioned also earlier,

13 public property?

14 A. Yes. These were all Croats and public property, and Albanians.

15 Q. Yes. Thank you.

16 MS. UERTZ-RETZLAFF: That should be enough for this document.

17 Q. When Mr. Martic was arrested in Bosnia, what was he doing there,

18 and together with whom was he arrested?

19 A. He was passing through Otoka, a village inhabited by Muslims next

20 to Bosanska Krupa. Also with him was his escort and people from the JNA,

21 officers of the JNA.

22 Q. Do you know what they were doing in Bosnia?

23 A. I don't know exactly.

24 Q. Where they were apprehended, was that a route used for the

25 transfer of weapons and equipment for the military forces in the Krajina?

Page 13270

1 A. Yes.

2 Q. At that time, was that the only route that was open, or were there

3 various routes?

4 A. There were two routes.

5 Q. Which routes were taken for the transport of weapons?

6 A. Through Bosanski Novi and through -- via Grahovo.

7 Q. The weapons, where did they come from?

8 A. The weapons came from two sources: One was Serbia, and the other

9 was from JNA warehouses in the territory of Krajina.

10 Q. Was there also a military warehouse, or sort of, in Bihac, where

11 you would receive weapons from?

12 A. Yes. Zeljava.

13 Q. Is that near the Bihac airport?

14 A. Yes. It's actually the base of the Bihac airport.

15 Q. To receive -- to receive weapons from the Bihac airport, to whom

16 would the authorities in the Krajina have to turn? Who would facilitate

17 this?

18 A. I know of Colonel Smiljanic.

19 Q. Who was he?

20 A. Chief of security of the JNA Zagreb Corps, when I met him.

21 MS. UERTZ-RETZLAFF: Your Honour, I just see that it's time.

22 JUDGE MAY: Yes, it is time. Ms. Uertz-Retzlaff, contrary to what

23 was said earlier, we seem to have made good progress today.

24 MS. UERTZ-RETZLAFF: Yes, Your Honour, but there is one problem

25 for tomorrow, actually, upcoming. It's not a problem, but it's a

Page 13271

1 time-consuming exercise for tomorrow, because tomorrow we will go into the

2 details of the Martic arrest and we will also go into a lot of intercepts.

3 Today I skipped the intercepts to just make progress, but we have to

4 come to the intercepts tomorrow, and I intend to do that in a group,

5 because I think it's more expeditious to do that.

6 JUDGE MAY: Very well. We've been warned. We'll adjourn now.

7 Could you be back, please, Witness C-061, 9.00 tomorrow.

8 --- Whereupon the hearing adjourned at 1.45

9 p.m., to be reconvened on Friday, the 22nd day of

10 November 2002, at 9.00 a.m.

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